Laserfiche WebLink
CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />49 <br />analysis.141 In addition, Executive Order 12,866 also requires that “[e]ach agency shall avoid <br />regulations that are inconsistent [or] incompatible” with the regulations of any other agency.142 <br />Any subsequently prepared NEPA document must disclose whether each of the proposed <br />plan alternatives would interfere with efforts to meet federal and international greenhouse gas <br />emission reduction targets.143 As explained by the CEQ in its Final Climate Guidance, federal <br />agencies evaluating the climate impacts of their decisions should “discuss relevant approved <br />federal, regional, state, tribal, or local plans, policies, or laws for GHG emission reductions or <br />climate adaptation to make clear whether a proposed project’s GHG emissions are consistent <br />with such plans or laws.”144 <br />Here, the BLM must address whether the proposed alternative plans, and the additional <br />coal, oil and gas combustion they facilitate, are in line with the goals of President Obama’s Clean <br />Power Plan. The Clean Power Plan calls for reducing power sector greenhouse gas emissions to <br />30 percent below 2005 levels by 2030.145 EPA’s Regulatory Impact Analysis for the proposed <br />Clean Power Plan estimates that the plan will reduce coal-fired electricity generation by 16 to 22 <br />percent in 2020 and by 25 to 27 percent in 2030.146 <br />Additionally, in November 2014 the President announced a joint U.S.-China agreement <br />aimed at reducing climate pollution that calls for even more aggressively cutting net greenhouse <br />gas emissions to 26-28 percent below 2005 levels by 2025.147 Further, the BLM must address <br />whether the plan alternatives accord with the Paris Agreement, which represents an international <br />agreement to limit global temperatures to 1.5-2°C below pre-industrial levels. <br />As part of its analysis, BLM should disclose to the public the clearly competing interests <br />at stake: one the one hand, meeting these national and international climate emission reduction <br />targets set by EPA, the President, or agreed upon by 195 nations; and on the other, the fact that <br />the plan alternatives will likely benefit only one or two coal companies and a handful of oil and <br />gas operators. <br /> 141 See 40 C.F.R. § 1506.2(d) (EISs must discuss inconsistencies with state law); 40 C.F.R. <br />§ 1508.27(b)(10) (when examining whether actions are “significant” within the meaning of <br />NEPA, agencies must consider whether the action “threatens a violation of Federal, State, or <br />local law or requirements imposed for the protection of the environment.”). 142 Executive Order 12,866 (Sep. 30, 1993), Sec. 1(b)(10). 143 See 40 C.F.R. § 1506.2(d); 40 C.F.R. § 1508.27(b)(10). 144 Final Climate Guidance at 28 (attached as Exhibit 4). 145 EPA, Fact Sheet, Clean Power Plan (2014) (attached as Exhibit 44). 146 EPA, Regulatory Impact Analysis for the Proposed Carbon Pollution, Guidelines for Existing <br />Power Plants and Emission Standards for Modified and Reconstructed Power Plants, 3-26 to 3- <br />29 (June 2014), available at: http://www2.epa.gov/sites/production/files/2014- <br />06/documents/20140602ria-clean-power-plan.pdf (attached as Exhibit 45). <br />147 White House Fact Sheet, U.S.-China Joint Announcement on Climate Change and Clean <br />Energy Cooperation (November 11, 2014), available at: https://www.whitehouse.gov/the-press- <br />office/2014/11/11/us-china-joint-announcement-climate-change (attached as Exhibit 46).