Laserfiche WebLink
CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />67 <br />nature of the climate change challenge, and is not an appropriate basis for <br />deciding whether to consider climate impacts under NEPA. Moreover, these <br />comparisons are not an appropriate method for characterizing the potential <br />impacts associated with ta proposed action and its alternatives and mitigation. <br /> <br />CEQ Guidance at 9. CEQ also provides that “[i]t is essential … that Federal agencies not rely <br />on boilerplate text to avoid meaningful analysis, including consideration of alternatives or <br />mitigation.” Id. at 5-6 (citing 40 C.F.R. §§ 1500.2, 1502.2). Indeed, the EPA has also cautioned <br />“against comparing GHG emissions associated with a single project to global GHG emission <br />levels” because it erroneously leads to a conclusion that “on a global scale, emissions are not <br />likely to change” as a result of the project.220 Applying the SCC, as provided above, takes these <br />abstract emissions and places them in concrete, economic terms. It also allows the agency to <br />easily perform the cost-benefit analysis envisioned by EO 12866, as well as BLM’s own policy. <br />Specifically, Instruction Memorandum No. 2013-131 (Sept. 18, 2013) is reflective of the <br />BLM’s attempt to internalize the costs of such emissions: <br /> <br />All BLM managers and staff are directed to utilize estimates of nonmarket <br />environmental values in NEPA analysis supporting planning and other <br />decision-making where relevant and feasible, in accordance with the attached <br />guidance. At least a qualitative description of the most relevant nonmarket <br />values should be included for the affected environment and the impacts of <br />alternatives in NEPA analyses…. <br /> <br />Nonmarket environmental values reflect the benefits individuals attribute to <br />experiences of the environment, uses of natural resources, or the existence of <br />particular ecological conditions that do not involve market transactions and <br />therefore lack prices. Examples include the perceived benefits from hiking in a <br />wilderness or fishing for subsistence rather than commercial purposes. The <br />economic methods described in this guidance provide monetary estimates of <br />nonmarket values. Several non-economic, primarily qualitative methods can <br />also be used to characterize the values attributed to places, landscapes, and <br />other environmental features. Guidance on qualitative methods for assessing <br />environmental values, including ethnography, interviews, and surveys, is in <br />preparation. <br /> <br />Ideally, economic analysis for resource management should consider all <br />relevant values, not merely those that are easy to quantify. Utilizing nonmarket <br />values provides a more complete picture of the consequences of a proposed <br />activity than market data alone would allow. The BLM's Land Use Planning <br />Handbook, Appendix D encourages inclusion of information on nonmarket <br />values, but does not provide detail. <br /> <br />The agency simply cannot continue to ignore its obligation to consider the costs of <br />GHG emissions in its decisionmaking, as it has done here. <br /> 220 See Light, 87 Tul. L. Rev. 511, 546.