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CONSERVATION GROUPS’ COMMENTS UNCOMPAHGRE FIELD OFFICE RMP AND DEIS 82 Total estimated emissions as well as predicted increases in emissions were analyzed to develop air resource management goals, objectives, and actions that would be effective in minimizing future impacts on air quality. The resulting adaptive management strategy is described in detail in Appendix H (Colorado BLM Comprehensive Air Resource Protection Protocol). The RMP/EIS explains the relationship of monitoring and evaluation to adaptive management: Adaptive management. A type of natural resource management in which decisions are made as part of an ongoing science-based process. Adaptive management involves testing, monitoring, and evaluating applied strategies, and incorporating new knowledge into management approaches that are based on scientific findings and the needs of society. Results are used to modify management policy, strategies, and practices. The UFO seems to ignore the fact that methane emissions and waste are not monitored in the same manner and to the same degree as criteria and hazardous air pollutants. According to the EPA, reporting is only required of: … sources that in general emit 25,000 metric tons or more of carbon dioxide equivalent per year in the United States. Smaller sources … are not included in the Greenhouse Gas Reporting Program.236 EPA has identified many small sources that are encompassed by the RMP/EIS but that would not exceed the reporting threshold and would, in the absence of additional monitoring and reporting requirements established in the RMP/EIS, go unmeasured. These include: venting from workovers, pneumatic devices, liquids unloading, and small compressors, and equipment leaks throughout natural gas systems.237 Therefore, by its own admission, UFO’s reliance on adaptive management to address methane emissions and waste are “not possible” because the agency has failed to require monitoring of smaller—but cumulatively significant—sources of such waste in the oil and gas production process. The UFO must do more than cite the CARPP as a tool for future adaptive management. Rather, the agency must adopt the methane mitigation technologies, BMPs and planning tools identified above to address all future development authorized under the RMP/EIS, and to apply these tools, practices, and technologies not just to development on new leases but as RMP authorized stipulations on all new oil and gas development in the planning area. 236 EPA, Fact Sheet: Greenhouse Gas Reporting Program Implementation, available at: https://www.epa.gov/sites/production/files/2014-09/documents/ghgrp-overview-factsheet.pdf (attached as Exhibit 127). 237 EPA, Petroleum and Natural Gas Systems (Feb. 2013), available at: http://www.epa.gov/ghgreporting/documents/pdf/infosheets/OnshorePetroleumNaturalGasSyste ms.pdf (attached as Exhibit 128).