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percent in the Grand Junction azea, although the decrease has been up to 20 percent in other parts of the state (U.S. Environmental Protection Agency 1997, as cited in Ladyman 2003). Projections made by the Intergovernmental Panel on Climate Change and results from the United Kingdom Hadley Centre's climate model (HadCM2) indicate that by 2100, temperatures in Colorado could increase 3 to 4 °F in the spring and fall (range 1 to 8 °F) and 5 to 6 °F in the summer and winter (range of 2 to 12 °F) (Ladyman 2003). HadCM2 is a model that accounts for both greenhouse gases and aerosols. Further evidence indicating that climate change is already having an effect on the region was documented in a recent study of snowpack averages azound the West. The study, undertaken by the Rocky Mountain Climate Organization and Clear the Air, predicts increased frequency and intensity of droughts as a result of that climate change (Gould 2005). Hannah et al. (2002) listed some of the effects of climate change including "changing rainfall patterns, declining water balances, increased extreme climate events, and changes in oscillations such as El Nino." Although climate change is occurring on the global scale, its effects may show different patterns regionally. It is still unlatown whether these species have been affected by climate change already, or will be directly affected in the future. However, in assessing population viability, regional climate change is an important factor that must be analyzed. For some species, successful seed germination maybe dependent upon a minimum winter temperature (Baskin and Baskin 1989). This temperature dependency may leave some plant species vulnerable in that a warming trend could trigger a depression of seed germination. (Ladyman 2003). Because plant species play a critical role in any ecosystem, such as food, shelter, and refuge for insects and wildlife and soil stability, a depression of seed germination that ultimately diminishes the reproduction and population of certain plant species will, in turn, have an adverse effect on the entire ecosystem. Noxious weeds can out compete native species for valuable resources. Increases in noxious weeds are to be expected with increased temperatures (McCarty 2001). In fact, Alward et al. (1999) found that exotic forb density was positively correlated with minimum spring temperatures. Therefore, climate change may further upset the balance of the ecosystem by contributing to increases in density of noxious species. Climate change may further disrupt ecosystems through exacerbating the effects of habitat fragmentation (McCarty 2001) and human encroachment, leading to reductions in growth as well as reproduction among plants and animals, drying out wetlands, mazshlands, and streams, and completely extirpating less mobile species with very specific habitat requirements (USFWS 2004), such as the longnosed leopard lizazd, midget faded rattlesnake, grand buckwheat, Uinta basin hookless cactus, and razorback sucker. Reseazch by Thomas (2004), revealed that more than 1 million species, unable to adapt to the warming climate, could become extinct by 2050 if climate change is not curtailed. Drought conditions have existed in Colorado since 2002, and it is very likely that human driven climate change will lead to a greater frequency and intensity of drought (Houghton et al., 1996). Drought, especially multiple consecutive yeazs of drought conditions, will likely exacerbate the effects of all the other threats to these Sensitive species detailed in this comment. Center for Native Ecosystems Page 16 of 24 ' Scoping Comments for the Proposed Red Cliff Coa] Mine