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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />26 <br />economy, air quality, etc.—are threatened by climate change, as the draft EIS itself recognizes, <br />and as a wealth of scientific literature demonstrates.76 In an order issued more than seven years <br />ago, the Secretary of Interior warned that “dramatic effects of climate change … are already <br />occurring,” and that “[t]he realities of climate change require us to change how we manage the <br />land, water, fish and wildlife, and cultural heritage … we oversee.”77 The draft RMP itself <br />includes as one of its objectives: “Reduce impacts from climate change on soil and water <br />resources, native vegetation and wildlife species and communities, and wildlife habitats,” <br />recognizing that climate change threatens all of those resources.78 <br /> <br />Second, the draft EIS claims neither alternative would meet the purpose and need for the <br />RMP because part of the RMP’s purpose is to adopt “management direction in accordance with <br />principles of multiple use and sustained yield.”79 As discussed above, the principle of multiple <br />use explicitly anticipates that some use would be prohibited on public lands. Further, the <br />keystone of multiple use is to “take[] into account the long-term needs of future generations for <br />renewable and nonrenewable resources.” 43 U.S.C. § 1702(3). There is no greater or more urgent <br />threat to public land resources in the long-term than climate change. Taking action on climate <br />change by limiting one use—fossil fuel extraction—to benefit all the others is the very essence <br />of the kind of trade-off anticipated by the multiple use mandate. <br /> <br />Further, the Tenth Circuit Court of Appeals has explicitly rejected the argument that <br />FLPMA’s multiple use mandate requires that public lands be made available for fossil fuel <br />extraction. <br /> <br />BLM’s obligation to manage for multiple use does not mean that development <br />must be allowed on [a particular piece of public lands]. Development is a possible <br />use, which BLM must weigh against other possible uses – including conservation <br />to protect environmental values, which are best assessed through the NEPA <br />process. Thus, an alternative that closes the [proposed public lands] to <br />development does not necessarily violate the principle of multiple use, and the <br />multiple use provision of FLPMA is not a sufficient reason to exclude more <br />protective alternatives from consideration. <br /> <br />New Mexico ex rel. Richardson, 565 F.3d at 710 (emphasis in original). <br /> <br />Third, BLM alleges that for coal as well as oil and gas, the authority for leasing derives <br />from the MLA, and that that law “directs field offices to apply the least restrictive management <br />constraints necessary to achieve resource goals and objectives for principal uses of public <br /> 76 See, e.g., Draft EIS at 3-16 (listing impacts of climate change in the Rocky Mountain West to <br />snowpack, drought, wildfire, insect epidemics, human health, river flows, agriculture, <br />groundwater, vegetation and wildlife, and forests). 77 Secretarial Order 3289, Addressing the Impacts of Climate Change on America’s Water, Land, <br />and Other Natural and Cultural Resources (September 14, 2009) (attached as Exhibit 26). 78 Draft EIS at 2-24. 79 Id. at 2-16.