2017-05-25_REVISION - C1996083 - Laserfiche WebLink

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CONSERVATION GROUPS’ COMMENTS UNCOMPAHGRE FIELD OFFICE RMP AND DEIS 25 The purpose of the Uncompahgre RMP is to provide broad-scale direction for the management of public lands and resources administered by the BLM Uncompahgre Field Office that are within the planning area. The RMP presents desired outcomes, which are expressed in terms of goals and objectives for resource conditions and uses. It also establishes the allowable uses, management actions, and special designations that will enable the BLM to achieve the desired outcomes. Management direction presented in the Uncompahgre RMP adheres to statutory requirements and is in accordance with principles of multiple use and sustained yield, as mandated by the provisions of the FLPMA, which establishes public land policy and sets forth the requirement for the BLM to develop, maintain, and when appropriate, revise or amend land use plans for the management of public lands. The RMP guides the Uncompahgre Field Office in the implementation of subsequent management actions within the planning area. Draft EIS at 1-2. Barring new leases to achieve national, regional and local greenhouse gas reduction goals would constitute “broad-scale direction” for the planning area. A desired outcome for a reasonable alternative could be reducing the planning area’s contribution to climate pollution. It would establish that certain uses—oil, gas, and coal production—would be allowable only on current leases, and it would enable BLM to achieve a desired outcome of reducing the chance of catastrophic climate change and increasing the chance for the U.S. to reach its greenhouse gas reduction goals set by the Paris Agreement. As discussed above, such management direction would adhere to the law and BLM’s multiple use mandate. As such, a no or limited fossil fuel leasing alternative would meet the purpose and need for the RMP. 3. The Draft EIS’s Justifications for Rejecting No-Leasing Alternatives Are Arbitrary and Capricious. The draft EIS explicitly rejects providing full consideration to alternatives that would “Prohibit Fluid Mineral Leasing throughout Decision Area” and “Prohibit Coal Leasing throughout Decision Area,”74 but the three grounds on which it does so lack legal or factual basis. First, in rejecting both alternatives, the draft EIS asserts that all fully-analyzed alternatives propose closing some areas to fossil fuel leasing, and that “[r]esource values that can only be protected by prohibiting all fluid mineral leasing throughout the decision area have not been identified.”75 This is both irrelevant and untrue. It is irrelevant because BLM need not identify some other resource value that “can only be protected” by barring fossil fuel leasing. It need only determine that leasing may not be in the public interest. It is untrue because virtually every resource value in the decision area—water, recreation, human health, wildlife, the 74 Draft EIS at 2-16. 75 Id.