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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />48 <br /> <br />The extreme urgency of the climate crisis requires BLM to pursue all means available to <br />limit the climate change effects of its actions, beginning with a robust and accurate quantitative <br />analysis of potential greenhouse gas emissions from fossil fuel development proposed in the <br />planning area. Any emissions source, no matter how small, is potentially significant, such that <br />BLM should fully explore mitigation and avoidance options for all sources. <br /> <br />BLM is, at the end of the day, responsible for the management of nearly 700 million <br />acres of federal onshore subsurface minerals.138 How the BLM chooses to manage this resource <br />has significant climate implications. Indeed, “the ultimate downstream GHG emissions from <br />fossil fuel extraction from federal lands and waters by private leaseholders could have accounted <br />for approximately 23% of total U.S. GHG emissions and 27% of all energy-related GHG <br />emissions.”139 This suggests that “ultimate GHG emissions from fossil fuels extracted from <br />federal lands and waters by private leaseholders in 2010 could be more than 20-times larger than <br />the estimate reported in the CEQ inventory, [which estimates total federal emissions from <br />agencies’ operations to be 66.4 million metric tons]. Overall, ultimate downstream GHG <br />emissions resulting from fossil fuel extraction from federal lands and waters by private <br />leaseholders in 2010 are estimated to total 1,551 [million metric tons of CO2 equivalent <br />(“MMTCO2e”)].”140 <br /> <br />To suggest that the agency does not, here, have to meaningfully analyze and mitigate <br />GHG pollution from activity authorized by the RMP and EIS, is to suggest that the collective <br />700 million acres of subsurface mineral estate is not relevant to protecting against climate <br />change. This sort of flawed, reductive thinking is problematic, and contradicted by the agency’s <br />very management framework that provides a place-based lens to account for specific pollution <br />sources to ensure that the broader public interest is protected. Therefore, even though climate <br />change emissions from the Alternatives may look minor when viewed in isolation, when <br />considered cumulatively with all of the other GHG emissions from BLM-managed land, they <br />become significant and cannot be ignored. <br />A. The Draft EIS Fails To Address Whether the Alternatives Considered <br />Are Consistent with National Climate Goals. <br /> <br />NEPA regulations require agencies to account for conflicts with existing laws and <br />requirements imposed for the protection of the environment when engaging in environmental <br /> <br />Mining Reclamation & Enf’t, 82 F. Supp. 3d 1201, 1213-1218 (D. Colo. 2015) (Court held that <br />the agency failed to adequately consider the reasonably foreseeable combustion-related <br />downstream effects of the proposed action. Also held that that combustion emissions associated <br />with a mine that fed a single power plant were reasonably foreseeable because the agency knew <br />where the coal would be consumed). 138 See DOI-BLM, Mineral and Surface Acreage Managed By BLM, available at: <br />http://www.blm.gov/wo/st/en/info/About_BLM/subsurface.html. 139 Stratus Consulting, prepared for: THE WILDERNESS SOCIETY, Greenhouse Gas Emissions from <br />Fossil Energy Extracted from Federal Lands and Waters (Feb. 1, 2012) (attached as Exhibit 24). 140 Id.