Laserfiche WebLink
CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />51 <br /> <br />The draft EIS appears to rely largely on data concerning climate change from 2010 or <br />earlier, ignoring the wealth of new policies meant to guide BLM, and new studies and data <br />emphasizing the worsening nature of the climate threat. Such ignorance is impermissible. <br /> <br />For example, the description of climate change in draft EIS Chapter Three relies on three <br />studies: an EPA study published in 2007, and two state studies published in 2008. Draft EIS at 3- <br />14 – 3-16. The EIS’s description of projected climate change in Colorado relies on a single study <br />from 2008. Id. at 3-26 – 3-27, 3-57. To affirm that impacts from climate change are already <br />occurring, the EIS relies on a 2009 report. Id. at 3-93. <br /> <br />The information in Chapter Four of the EIS is also outdated. It describes potential <br />greenhouse gas emissions based on EPA reports from 2010 – 2012, and dismisses the relative <br />level of direct GHG emissions from activities in the planning area based on a discredited EPA <br />letter from 2008—drafted during waning days of the climate-denying Bush administration. Id. at <br />4-38 – 4-40. To discuss the cumulative impacts of climate change in the project area, BLM relies <br />on studies published between 1996 and 2010. Id. at 4-125. <br /> <br />As detailed above, there is abundant new data concerning the nature of climate change, <br />the contribution of anthropogenic sources to that change, the impacts of that change, and the <br />need for urgent action to address the climate crisis.149 No new information since 2012 is included <br />in or cited by the draft EIS. Any subsequently prepared NEPA document must include and refer <br />to this data. <br />C. The Draft EIS Fails to Address New Information Concerning the Impacts of <br />Climate Change in the Uncompahgre Area. <br /> <br />The draft EIS omits significant new information concerning climate impacts to the North <br />Fork Valley. In February, the GMUG National Forest published its Final EIS and proposed <br />decision for the Spruce Beetle Epidemic and Aspen Decline Management Response <br />(“SBEADR”) project on the GMUG National Forest, including lands directly adjacent to, and in <br />most cases upstream of, BLM lands in the Uncompahgre field office. The Forest Service <br />developed SBEADMR to respond to “the ongoing spruce beetle epidemic and sudden aspen <br />decline that is occurring across a broad landscape” of the forest.150 To address the epidemics, the <br />GMUG National Forest proposes to log aspen and spruce-fire stands in certain parts of the forest <br />“to reduce hazards to the public and infrastructure, salvage dead and dying timber, [and] <br /> <br />office/2015/03/31/fact-sheet-us-reports-its-2025-emissions-target-unfccc (last viewed Oct. 27, <br />2016). 149 See supra at Section I. 150 U.S. Forest Service, Final Environmental Impact Statement, Spruce Beetle Epidemic and <br />Aspen Decline Management Response (Feb. 2016) at iii (hereafter “SBEADMR Final EIS”), <br />available at: <br />http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/www/ne <br />pa/96623_FSPLT3_2720775.pdf (excerpts attached as Exhibit 100).