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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />31 <br />emissions of CO2. The only way to minimize the peak warming this century is to reduce <br />emissions of CO2 and [short-lived climate pollutants],” including methane.89 <br /> <br />Because of methane’s outsize role in near-term climate-forcing, the Obama <br />Administration, and BLM in particular, have specifically targeted methane pollution. In 2013, <br />the White House published a climate strategy that concluded: “Curbing emissions of methane is <br />critical to our overall effort to address global climate change.”90 In 2014, the Obama <br />Administration updated its policies, publishing a strategy to reduce methane pollution that <br />specifically identified the need for voluntary and regulatory actions to limit methane emissions <br />from coal mines.91 <br /> <br />The need to address methane’s damaging climate impacts spurred both BLM and EPA to <br />limit fugitive methane emissions from oil and gas operations in recent years. 92 Both agencies <br />concluded that reducing methane pollution would have significant social benefits, based in large <br />part on the significant social cost of continuing to permit unnecessary methane releases.93 <br />Earlier this year, the U.S. and Canada also signed a climate agreement which calls for significant <br />methane reductions from the oil and gas sectors.94 <br />3. Existing Technologies Could Significantly Reduce Methane Emissions <br />From Coal Mines in the Uncompahgre Planning Area. <br /> <br />Coal mine methane generally is removed from underground mines in one of two ways, <br />and in both instances coal companies can either capture the methane and put it to beneficial use <br /> 89 J.K. Shoemaker et al., What Role for Short-Lived Climate Pollutants in Mitigation Policy? <br />342 Science 1323-24 (2013), available at: http://www-ramanathan.ucsd.edu/files/pr200.pdf <br />(attached as Exhibit 29). 90 Executive Office of the President, The President’s Climate Action Plan (June 2013) available <br />at: https://www.whitehouse.gov/sites/default/files/image/president27sclimateactionplan.pdf <br />(attached as Exhibit 30). 91 The White House, Climate Action Plan: Strategy to Reduce Methane Emissions (attached as <br />Exhibit 1). 92 EPA, Proposed Rule, Oil and Natural Gas Sector, 80 Fed. Reg. 56,593, 56,598 (Sep. 18, <br />2015), available at: https://www.gpo.gov/fdsys/pkg/FR-2015-09-18/pdf/2015-21023.pdf; BLM, <br />Proposed Rule, Waste Prevention, Production Subject to Royalties, and Resource Conservation, <br />81 Fed. Reg. 6616, 6617 (Feb. 8, 2016), available at: https://www.gpo.gov/fdsys/pkg/FR-2016- <br />02-08/pdf/2016-01865.pdf. 93 EPA, Proposed Rule, Oil and Natural Gas Sector, 80 Fed. Reg. at 56,657; BLM, Proposed <br />Rule, Waste Prevention, 81 Fed Reg. at 6670-71; BLM, Regulatory Impact Analysis for <br />Revisions to Onshore Oil and Gas Leasing (Jan. 14, 2016) at 32, 130-49, available at: <br />http://www.blm.gov/style/medialib/blm/wo/Communications_Directorate/public_affairs/news_re <br />lease_attachments.Par.11216.File.dat/VF%20Regulatory%20Impact%20Analysis.pdf. 94 The White House, U.S.-Canada Joint Statement on Climate, Energy, and Arctic Leadership <br />(Mar. 10, 2016), available at: https://www.whitehouse.gov/the-press-office/2016/03/10/us- <br />canada-joint-statement-climate-energy-and-arctic-leadership (attached as Exhibit 31).