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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />43 <br />emissions elsewhere identified by the agency. Moreover, as explained by the CEQ, these <br />comparisons do not reveal anything beyond “the nature of the climate change challenge itself”; <br />i.e., the fact that many individual sources together make a big impact on the climate: <br /> <br />Climate change results from the incremental addition of GHG emissions from <br />millions of individual sources, which collectively have a large impact on a global <br />scale. CEQ recognizes that the totality of climate change impacts is not <br />attributable to any single action, but are exacerbated by a series of actions <br />including actions taken pursuant to decisions of the Federal Government. <br />Therefore, a statement that emissions from a proposed Federal action represent <br />only a small fraction of global emissions is essentially a statement about the <br />nature of the climate change challenge, and is not an appropriate basis for <br />deciding whether or to what extent to consider climate change impacts under <br />NEPA. Moreover, these comparisons are also not an appropriate method for <br />characterizing the potential impacts associated with a proposed action and its <br />alternatives and mitigations because this approach does not reveal anything <br />beyond the nature of the climate change challenge itself: the fact that diverse <br />individual sources of emissions each make a relatively small addition to global <br />atmospheric GHG concentrations that collectively have a large impact. When <br />considering GHG emissions and their significance, agencies should use <br />appropriate tools and methodologies for quantifying GHG emissions and <br />comparing GHG quantities across alternative scenarios. Agencies should not limit <br />themselves to calculating a proposed action’s emissions as a percentage of sector, <br />nationwide, or global emissions in deciding whether or to what extent to consider <br />climate change impacts under NEPA.126 <br /> <br />Meaningful consideration of GHGs is clearly within the scope of required NEPA review. <br />Ctr. for Biological Diversity v. Nat’l Highway Traffic Safety Admin., 538 F.3d 1172, 1217 (9th <br />Cir. 2008). As the Ninth Circuit has held, in the context of fuel economy standard rules: <br />The impact of greenhouse gas emissions on climate change is precisely the kind of <br />cumulative impacts analysis that NEPA requires agencies to conduct. Any given <br />rule setting a CAFE standard might have an “individually minor” effect on the <br />environment, but these rules are “collectively significant actions taking place over <br />a period of time” Ctr. for Biological Diversity v. Nat'l Highway Traffic Safety <br />Admin., 538 F.3d 1172, 1216 (9th Cir. 2008)(quoting 40 C.F.R. § 1508.7). <br />The courts have ruled that federal agencies should consider indirect GHG emissions <br />resulting from agency policy, regulatory, planning and leasing decisions. For example, agencies <br />cannot ignore the indirect air quality and climate change impact of decisions that would open up <br />access to coal reserves. See Mid States Coal. For Progress v. Surface Transp. Bd., 345 F.3d 520, <br />532, 550 (8th Cir. 2003); High Country Conservation Advocates v. U.S. Forest Serv., 52 F.Supp. <br />3d 1174, 1197-98 (D.Colo. 2014). <br /> <br /> 126 Final Climate Guidance at 9 (attached as Exhibit 4).