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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />44 <br />The CEQ Final Climate Guidance is dispositive on the issue of federal agency review of <br />greenhouse gas emissions as foreseeable direct and indirect effects of the proposed action. 81 <br />Fed. Reg. 51,866 (Aug. 5, 2016). The CEQ guidance provides clear direction for BLM to <br />conduct a lifecycle greenhouse gas analysis because the modeling and tools to conduct this type <br />of analysis are readily available to the agency: <br />If the direct and indirect GHG emissions can be quantified based on available <br />information, including reasonable projections and assumptions, agencies should <br />consider and disclose the reasonably foreseeable direct and indirect emissions <br />when analyzing the direct and indirect effects of the proposed action. Agencies <br />should disclose the information and any assumptions used in the analysis and <br />explain any uncertainties. To compare a project’s estimated direct and indirect <br />emissions with GHG emissions from the no-action alternative, agencies should <br />draw on existing, timely, objective, and authoritative analyses, such as those by <br />the Energy Information Administration, the Federal Energy Management <br />Program, or Office of Fossil Energy of the Department of Energy. In the absence <br />of such analyses, agencies should use other available information. <br /> <br />81 Fed. Reg. 51,866 at 16 (Aug. 5, 2016)(citations omitted). <br /> <br />CEQ’s guidance even provides an example of where a lifecycle analysis is appropriate in <br />a leasing context: <br /> <br />The indirect effects of such an action that are reasonably foreseeable at the time <br />would vary with the circumstances of the proposed action. For actions such as a <br />Federal lease sale of coal for energy production, the impacts associated with the <br />end-use of the fossil fuel being extracted would be the reasonably foreseeable <br />combustion of that coal.127 <br /> <br />The volume of potential coal, oil and gas from the new parcels available for lease in the <br />UFO draft RMP and EIS is knowable, and the lifecycle GHG emissions impact from these new <br />lease parcels is also quantifiable. Indeed, BLM attempts to quantify direct and indirect GHG <br />emissions on pages 4-38 and 4-42 of the UFO RMP DEIS. However, the analysis falls short of <br />an accurate depiction of actual climate change emissions impact for this planning area, in <br />particular, for potential oil and gas leasing. We easily generated an accurate, site-specific impact <br />analysis for each alternative by utilizing BLM’s own Energy Policy and Conservation Act phase <br />III Oil and Gas Inventory Model geodatabase and the Uncompahgre draft RMP DEIS alternative <br />GIS shapefiles to establish future extractible oil and gas volume from the planning area.128 Then, <br /> <br />127 Id. at 16, n. 42 (attached as Exhibit 4). 128 Center for Biological Diversity, Maps and volume estimates of future extractible oil and gas <br />volume in the Uncompahgre planning area based on GIS mapping of U.S. Bureau of Land <br />Management’s EPCA Phase III Inventory GIS Data, published May 2008, found at <br />http://www.blm.gov/wo/st/en/prog/energy/oil_and_gas/EPCA_III/EPCA_III_geodata.html; U.S. <br />Bureau of Land Management, Uncompahgre Field Office draft Resource Management Plan <br />and Environmental Impact Statement GIS mapping shapefiles, published June 3, 2016 found at <br />http://www.blm.gov/co/st/en/fo/ufo/uncompahgre_rmp.html; Emails and Dropbox files from