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Comments on Climate Damages from Farmington Mancos-Gallup RMP

The Bureau of Land Management and the Bureau of Indian Affairs forecast that resource management in New Mexico's Farmington Mancos-Gallup region would produce more than 300 million metric tons of cumulative greenhouse gas emissions under their preferred alternative. Our joint comments explain that the agencies should better evaluate the proposal's climate impacts using the social cost of greenhouse gases. We also submitted comments focused on the agencies' obligation to conduct environmental justice analysis under Executive Order 12,898. We found that the agencies failed to consider how the project's climate impacts will disproportionately cause economic and health-related harms in low-income and minority communities.