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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />53 <br />Results of the bioclimatic model show that 52% of the current aspen distribution <br />on the GMUG is in the lost category and 42% is in the threatened category, <br />meaning it is conceivable that 94% of current aspen distribution may not continue <br />into the next century (Figure 5)…. Little suitable habitat is expected to remain on <br />the Uncompahgre Plateau, the southern and eastern fringes of the Grand Mesa, <br />and the western West Elks. The remainder is largely threatened, as persistent <br />habitat is mostly limited to the southeastern portion of the GMUG.156 <br />Maps in the Final EIS display the likely near-elimination of spruce and aspen on the <br />Uncompahgre Plateau and in the North Fork Valley in the next 44 years.157 <br /> The loss of wildlife, water, and recreation that these adjacent and nearby forests protect <br />on National Forest lands will have cross-boundary and downstream impacts on BLM lands in the <br />Uncompahgre field office. Aspen and spruce on BLM lands in the area will also likely be <br />similarly impacted.158 Forest loss will have economic and fiscal impacts on local communities <br />and the state. Yet the Uncompahgre draft EIS mentions aspen and spruce decline only in passing, <br />without addressing the cascading impacts to natural resources in the Uncompahgre field office <br />(other than lamenting the potential impacts to the logging industry).159 Further, the draft EIS fails <br />to use the same models and information that the Forest Service relied on earlier this year to <br />attempt to understand the potential impacts of the climate crisis on forests and other ecosystems <br />on BLM land in the same area. BLM must address these deficiencies in any subsequently <br />prepared NEPA document. <br />The RMP and EIS also fails to address adequately the fact that wildfire in the western <br />U.S., including within the Uncompahgre Field Office, is becoming more frequent and damaging <br />larger landscapes. For example, the New York Times published a story on its front page on <br />April 13 reporting that fire season in the United States and elsewhere is starting earlier and <br />lasting longer; that fires are burning with more intensity; and that firefighting is eating up an <br />ever-increasing amount of the Forest Service’s budget.160 <br />The article cites numerous experts, including Forest Service researchers, who all agree <br />that the fire season in the U.S., from Arizona to Alaska, is getting longer. <br />And one of the key drivers in the lengthening fire season is climate change. As the Times <br />puts it: “A leading culprit is climate change. Drier winters mean less moisture on the land, and <br /> <br />156 Id. at 17 (emphasis added). 157 Id. at 10, 17 (maps). 158 See Uncompahgre Draft EIS at 3-111; 3-20; 3-90 (describing forest type in BLM fire <br />management units). 159 Id. at 4-232 (acknowledging that aspen decline and spruce beetle epidemics may impact the <br />timber industry); id. at 4-480 (same). 160 M. Richtel and F. Santos, The New York Times, “Wildfires, Once Confined to a Season, <br />Burn Earlier and Longer” (Apr. 13, 2016) (attached as Exhibit 191).