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CONSERVATION GROUPS’ COMMENTS UNCOMPAHGRE FIELD OFFICE RMP AND DEIS 41 Renowned NASA climatologist Dr. James Hansen provides the analogy of loaded dice – suggesting that there still exists some variability, but that climate change is making these extreme events ever more common.122 In turn, climatic change and GHG emissions are having dramatic impacts on plant and animal species and habitat, threatening both human and species resiliency and the ability to adapt to these changes.123 According to experts at the Government Accountability Office (“GAO”), federal land and water resources are vulnerable to a wide range of effects from climate change, some of which are already occurring. These effects include, among others, “(1) physical effects, such as droughts, floods, glacial melting, and sea level rise; (2) biological effects, such as increases in insect and disease infestations, shifts in species distribution, and changes in the timing of natural events; and (3) economic and social effects, such as adverse impacts on tourism, infrastructure, fishing, and other resource uses.”124 The UFO RMP/EIS acknowledges that “mounting evidence suggests” that numerous climate change impacts are already occurring in the Mountain West and Great Plains region, including warming temperatures, less snowfall, earlier snowmelt, more drought, greater wildfire risk, and the expansion of grasslands and rangelands into previously forested areas. DEIS at 4- 41. The UFO RMP/EIS further acknowledges that these climate change impacts will cause ecosystem and wildlife damage and stress in numerous ways. For example, “[I]f global climate change results in a warmer and drier climate, increased particulate matter impacts could occur due to increased windblown dust from drier and less stable soils.” Id. “[E]xtinction of endemic threatened or endangered plants may be accelerated.” Id. And: “The population of some animal species may be reduced.” Id. The UFO concludes: “Increased fire activity and intensity would increase greenhouse gas emissions, providing for a negative feedback loop. In fact, most of the predicted changes on a global scale have some level of a predicted negative feedback loop, making the problem particularly vexing.” Id. (emphasis added). However, despite these acknowledgments, the UFO fails to adequately address climate change in its Plan or EIS, as NEPA requires, through robust consideration of reasonable 122 See, James Hansen, et. al., Climate Variability and Climate Change: The New Climate Dice (Nov. 2011) (attached as Exhibit 71); James Hansen, et. al., Perception of Climate Change (March 2012) (attached as Exhibit 72); James Hansen, et. al., Increasing Climate Extremes and the New Climate Dice (Aug. 2012) (attached as Exhibit 73). 123 See Fitzgerald Booker, et. al., The Ozone Component of Climate Change: Potential Effects on Agriculture and Horticultural Plant Yield, Product Quality and Interactions with Invasive Species, J. INTEGR. PLANT BIOL. 51(4), 337-351 (2009) (attached as Exhibit 74); Peter Reich, Quantifying plant response to ozone: a unifying theory, TREE PHYSIOLOGY 3, 63-91 (1987) (attached as Exhibit 75). 124 GAO Report, Climate Change: Agencies Should Develop Guidance for Addressing the Effects on Federal Land and Water Resources (2007) (attached as Exhibit 76); see also Committee on Environment and Natural Resources, National Science and Technology Council, Scientific Assessment of the Effects of Global Climate Change on the United States (2008) (attached as Exhibit 77); Melanie Lenart, et. al. Global Warming in the Southwest: Projections, Observations, and Impacts (2007) (attached as Exhibit 78) (describing impacts from temperature rise, drought, floods and impacts to water supply on the southwest).