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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />66 <br />because the Forest Service in November 2015 undertook an initial social cost of carbon analysis <br />for coal to be made available by the Colorado Roadless Rule coal mine exception. That analysis <br />– in which BLM is a cooperating agency – involves coal from the very same coal field (the <br />Somerset) and some of the very same mines (including the West Elk mine) that are at issue in the <br />Uncompahgre Field Office RMP.218 While the Colorado Roadless Rule’s social cost of carbon <br />analysis has many flaws,219 it is evidence that this metric can be, and is being, used by BLM and <br />other agencies to address the climate impacts of some of the same coal from the same mines at <br />issue in the Uncompahgre draft RMP. <br /> <br />An agency must “consider every significant aspect of the environmental impact of a <br />proposed action.” Baltimore Gas & Elec. Co. v. Natural Resources Defense Council, 462 U.S. <br />87, 107 (1983) (quotations and citation omitted). This includes the disclosure of direct, indirect, <br />and cumulative impacts of its actions, including climate change impacts and emissions. 40 C.F.R. <br />§ 1508.25(c). The need to evaluate such impacts is bolstered by the fact that “[t]he harms <br />associated with climate change are serious and well recognized,” and environmental changes <br />caused by climate change “have already inflicted significant harms” to many resources around <br />the globe. Massachusetts v. EPA, 549 U.S. 497, 521 (2007); see also id. at 525 (recognizing <br />“the enormity of the potential consequences associated with manmade climate change.”). <br />Among other things, the agency’s analysis must disclose “the relationship between local short- <br />term uses of man’s environment and the maintenance and enhancement of long-term <br />productivity[,]” including the “energy requirements and conservation potential of various <br />alternatives and mitigation measures.” 42 U.S.C. § 4332(c); 40 C.F.R. § 1502.16(e). As <br />explained by CEQ, this requires agencies to “analyze total energy costs, including possible <br />hidden or indirect costs, and total energy benefits of proposed actions.” 43 Fed. Red. 55,978, <br />55,984 (Nov. 29, 2978); see also Executive Order 13514, 74 Fed. Reg. 52,117 (Oct. 5, 2009) <br />(requiring government agencies to disclose emissions information annually from direct and <br />indirect activities). Failing to perform such analysis undermines the agency’s decisionmaking <br />process and the assumptions made. <br /> <br />Moreover, BLM measures the planning area’s GHG emissions against a baseline of <br />national and/or global GHG emissions—thereby marginalizing the Proposed Actions <br />contribution to our climate crisis while concluding the agency is powerless to avoid or mitigate <br />such impacts. CEQ warns against such a comparison, providing: <br /> <br />Government action occurs incrementally, program-by-program and step-by-step, <br />and climate impacts are not attributable to any single action, but are exacerbated <br />by a series of smaller decisions, including decisions made by the government. <br />Therefore, the statement that emissions from a government action or approval <br />represent only a small fraction of global emissions is more a statement about the <br /> <br />218 Forest Service, Rulemaking for Colorado Roadless Areas, Supplemental Draft Environmental <br />Impact Statement (Nov. 2015) at 98-101, available at <br />http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd485194.pdf (last viewed Nov. 1, <br />2016). 219 See, e.g., letter of Environmental Defense Fund et al. to Forest Service et al. (Jan. 15, 2016) <br />(attached as Exhibit 234); T.M. Power et al., Comments on the Rulemaking for the Colorado <br />Roadless Areas Supplemental Draft Environmental Impact Statement (Jan. 14, 2016) (attached <br />as Exhibit 235).