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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />15 <br />both fossil fuel-producing and fossil fuel-using infrastructure.56 <br /> <br />Simply put, the timeframe to avoid catastrophic climate change is short, and the <br />management of our federal minerals is dangerously out of step with this reality. As noted above, <br />the UFO failed to consider any alternative that would meaningfully reduce the projected 3.11 <br />MMTCO2e of annual emissions from the planning area. Draft EIS at 4-39. <br />II. BLM Fails to Consider All Reasonable Alternatives. <br />A. BLM Has a Legal Obligation to Consider All Reasonable Alternatives. <br /> <br />The centerpiece of environmental regulation in the United States, the National <br />Environmental Policy Act (“NEPA”) requires federal agencies to pause before committing <br />resources to a project and consider the likely environmental impacts of the preferred course of <br />action as well as reasonable alternatives. See 42 U.S.C. § 4331(b) (congressional declaration of <br />national environmental policy); U.S. Dep't of Transp. v. Public Citizen, 541 U.S. 752, 756–57 <br />(2004). BLM must “rigorously explore and objectively evaluate all reasonable alternatives” to <br />the proposed action in comparative form, so as to provide a “clear basis for choice among the <br />options” open to the agency. 40 C.F.R. § 1502.14. At a minimum, the agency must identify and <br />analyze its preferred alternative, as well as a null or “no action” alternative that would occur if <br />the agency elected to maintain the current state of affairs unchanged. Id. In addition, the agency <br />should address all other reasonable alternatives to the proposed action. See Colorado Envtl. Coal. <br />v. Salazar, 875 F. Supp. 2d 1233, 1245 (D. Colo. 2012). <br /> <br />Through the RMP planning process, the UFO is required to “estimate and display the <br />physical, biological, economic, and social effects of implementing each alternative considered in <br />detail. The estimation of effects shall be guided by the planning criteria and procedures <br />implementing [NEPA].” 43 C.F.R. § 1610.4-6. Essential to any NEPA process is a robust <br />analysis of alternatives to the proposed action. Consideration of reasonable alternatives is <br />necessary to ensure that the agency has before it and takes into account all possible approaches <br />to, and potential environmental impacts of, a particular project. NEPA’s alternatives <br />requirement, therefore, ensures that the “most intelligent, optimally beneficial decision will <br />ultimately be made.” Calvert Cliffs’ Coordinating Comm., Inc. v. U.S. Atomic Energy Comm’n, <br />449 F.2d 1109, 1114 (D.C. Cir. 1971). <br /> <br />“[T]he heart” of an environmental analysis under NEPA is the analysis of alternatives to <br />the proposed project, and agencies must evaluate all reasonable alternatives to a proposed <br />action.” Colorado Environmental Coalition, 185 F.3d at 1174 (quoting 40 C.F.R. § 1502.14). An <br />agency must gather “information sufficient to permit a reasoned choice of alternatives as far as <br />environmental aspects are concerned.” Greater Yellowstone, 359 F.3d at 1277 (citing Colorado <br />Environmental Coalition, 185 F.3d at 1174); see also Holy Cross Wilderness Fund v. Madigan, <br />960 F.2d 1515, 1528 (10th Cir. 1992). Thus, agencies must “ensure that the statement contains <br />sufficient discussion of the relevant issues and opposing viewpoints to enable the decisionmaker <br />to take a ‘hard look’ at environmental factors, and to make a reasoned decision.” Izaak Walton <br /> 56 Id. at 30.