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CONSERVATION GROUPS’ COMMENTS UNCOMPAHGRE FIELD OFFICE RMP AND DEIS 39 energy and minerals, comprehensive trails and travel management, lands and realty, renewable energy, ACECs, wild and scenic rivers, national trails and byways, watchable wildlife viewing sites, Native American tribal uses, and public health and safety. DEIS 4 -338 (emphasis added). Nevertheless, the BLM recognizes that renewable energy facilities are usually sited based on resource potential and proximity to transmission lines or end uses. Oil and gas development that will impinge on these areas would create conflicts with renewable energy development that must be addressed. The discussion of cumulative impacts does identify the impacts of oil and gas on renewable energy development as follows, but no further analysis is conducted: Past, present, and reasonably foreseeable future actions and conditions within the cumulative impact analysis area that have affected and will likely continue to affect renewable energy are energy and minerals development. DEIS 4-341. Given the urgent need to transition away from fossil fuels and toward renewable energy to meet our nation’s commitment to address climate change, it is incumbent upon the BLM to ensure that renewable energy development, especially photovoltaic solar development, is not precluded in the planning area by new oil and gas development. Further, the BLM is required to include a renewable energy alternative or include renewable energy as a priority element in each alternative to ensure that a thorough analysis of this important public lands resource is conducted. III. The UFO Failed to Take a Hard Look at Climate Change Impacts. If we are to stem the impacts of climate change and manage for sustainable ecosystems, not only must the BLM take a hard look at greenhouse gas (“GHG”) emitted by fossil fuel leasing and development in the planning area, but the agency’s decision must be reflective of the challenges we face. The EPA has determined that human emissions of greenhouse gases are causing global warming that is harmful to human health and welfare. See 74 Fed. Reg. 66,496 (Dec. 15, 2009), Endangerment and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act. The D.C. Circuit has upheld this decision as supported by the vast body of scientific evidence on the subject. See Coal. for Responsible Regulation, Inc. v. E.P.A., 684 F.3d 102, 120-22 (D.C. Cir. 2012). Indeed, EPA could not have found otherwise, as virtually every climatologist in the world accepts the legitimacy of global warming and the fact that human activity has resulted in atmospheric warming and planetary climate change.117 The world’s 117 See, e.g., INTERGOVERNMENTAL PANEL ON CLIMATE CHANGE, The Science of Climate Change (1995) (attached as Exhibit 47); U.S. Climate Change Science Program, Abrupt Climate Change (Dec. 2008) (attached as Exhibit 48); James Hansen, et. al., Global Surface Temperature Change, REVIEWS OF GEOPHYSICS, 48, RG4004 (June 2010) (attached as Exhibit 49); see also,