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CONSERVATION GROUPS’ COMMENTS
<br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS
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<br />the atmosphere by calculating carbon dioxide equivalent (CO2e) for the GHGs.” SIR at 1-2.246
<br />However, substantial questions arise when you calibrate methane’s GWP over the 20-year
<br />planning and environmental review horizon used in the SIR and, typically, by BLM, including
<br />the UFO. See SIR at 4-1 thru 4-45 (discussing BLM-derived reasonably foreseeable development
<br />potential in each planning area). Over this 20-year time period, the IPCC’s new research has
<br />calculated that methane’s GWP is 87247 – yet another substantial increase from its earlier
<br />estimate of 72, which was still over three times as potent as otherwise assumed by the SIR.248
<br />
<br />However, recent peer-reviewed science demonstrates that gas-aerosol interactions
<br />amplify methane’s impact such that methane is actually 105 times as potent over a twenty-year
<br />time period.249 This information suggests that the near-term impacts of methane emissions have
<br />been significantly underestimated. See 40 C.F.R. § 1508.27(a) (requiring consideration of short
<br />and long term effects). Further, by extension, BLM has also significantly underestimated the
<br />near-term benefits of keeping methane emissions out of the atmosphere. 40 C.F.R.
<br />§§ 1502.16(e), (f); id. at 1508.27. These estimates are important given the noted importance of
<br />near term action to ameliorate climate change – near term action that scientists say should focus,
<br />inter alia, on preventing the emission of short-lived but potent GHGs like methane while, at the
<br />same time, stemming the ongoing increase in the concentration of carbon dioxide.250 These
<br />uncertainties – which, here, the agency does not address – necessitate analysis in the RMP and
<br />EIS. 40 C.F.R. §§ 1508.27(a), (b)(4)-(5).
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<br />Additional, serious, yet unaddressed uncertainties pertain to the magnitude of methane
<br />pollution from oil and gas emissions sources. The U.S. GHG Inventory takes a top down
<br />approach to estimating emissions from the oil and gas industry, using national activity data and
<br />equipment counts from a host of sources and applying emissions factors of varying vintages,
<br />primarily those from a 1996 study by EPA and the Gas Research Institute using 1992 data.251 As
<br />provided in the EPA Inventory of Emissions and Sinks: 1990-2011, “[f]urther research is needed
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<br />246 BLM, Climate Change, Supplementary Information Report, Montana, North Dakota and
<br />South Dakota (2010) available at:
<br />www.blm.gov/mt/st/en/prog/energy/oil_and_gas/leasing/leasingEAs.html (attached as Exhibit
<br />133). 247 See IPCC Physical Science Report (attached as Exhibit 113). 248 See INTERGOVERNMENTAL PANEL ON CLIMATE CHANGE, Fourth Assessment Report, Working
<br />Group 1, Contribution of Working Group I to the Fourth Assessment Report of the
<br />Intergovernmental Panel on Climate Change, Ch. 2, p. 212, Table 2.14, available at:
<br />www.ipcc.ch/publications_and_data/ar4/wg1/en/ch2s2-10-2.html (attached as Exhibit 134). 249 Drew Shindell et al., Improved Attribution of Climate Forcing to Emissions, SCIENCE 2009
<br />326 (5953), p. 716, available at: www.sciencemag.org/cgi/content/abstract/326/5953/716
<br />(attached as Exhibit 135). 250 See, e.g., Limiting Global Warming: Variety of Efforts Needed Ranging from 'Herculean' to
<br />the Readily Actionable, Scientists Say, SCIENCE DAILY (May 4, 2010), available at:
<br />http://www.sciencedaily.com/releases/2010/05/100503161328.htm; see also, Ramanathan, et. al.,
<br />(attached above as Exhibit 54). 251 See U.S. EPA, Methane Emissions from the Natural Gas Industry (1996) (attached as Exhibit
<br />136).
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