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Southern Rockies of Colorado, Wyoming and New Mexico. SREP utilizes conservation science <br />principles and geographic information system (GIS) mapping technology to identify and protect <br />wildlands critical to the preservation of native biodiversity in the Southern Rockies, including the <br />wildlands of the GMUG National Forest. SREP provided written comments on the Project <br />DEIS. <br />Members of the above-listed organizations use lands in the West Elk Roadless Area and <br />environs for hiking, photography, wildlife viewing, and other recreational, aesthetic, and <br />educational purposes and intend to continue to do so. <br />STATEMENT OF REASONS <br />1. THE FOREST SERVICE VIOLATED NEPA BY INADEQUATELY ANALYZING <br />THE PROJECT'S EFFECT ON CLIMATE. <br />A. The Final EIS Failed To Analyze Properly The Project's Cumulative Effects <br />On Global Warming. <br />The National Environmental Policy Act of 1969 ("NEPA"), 42 U.S.C. § 4321 et seq., and <br />applicable regulations require the agency to analyze the cumulative impact of a proposed project <br />"when added to other past, present, and reasonably foreseeable future actions" regardless of the <br />source of the future actions. 40 C.F.R. § 1508.7. <br />The "harms associated with climate change are serious and well recognized." <br />Massachusetts v. EPA, 127 S. Ct. 1438, 1455 (2007). The Council on Environmental Quality's <br />(CEQ's) Draft Guidance on climate change unequivocally states that climate change is a <br />"reasonably foreseeable" impact of greenhouse gas emissions "as that phrase is understood in the <br />context of NEPA and the CEQ regulations" and that "[a]s a result, climate change should be <br />considered in NEPA documents." CEQ Draft Guidance Regarding Consideration of Global <br />Climatic Change in Environmental Documents Prepared Pursuant to the National Environment <br />APPEAL OF E SEAM METHANE DRAINAGE WELLS PROJECT, APRIL 28, 2008 PAGE 3