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202-912-7137 (office) 202-527-4685 (cell) jkruger@blm.gov Authorizations (February 1, 2005). It was replaced by BLM IM no. 2013-142 (see #1 above). 6. BLM National Environmental Policy Act Handbook, H-1790-1 (January 2008). Consistent with the CEQ regulations at 40 CFR 1508.20, this Handbook defines mitigation to include avoidance, minimization, and compensation. It also describes how mitigation can be used to reduce the effects of an action below the threshold of significance, thereby avoiding the need to prepare an EIS (i.e., to arrive at a "mitigated Finding of No Significant Impact (FONSI)"). It also provides guidance relating to BLM's description of any effects that remain after mitigation measures have been applied, incorporation of mitigation measures into decision documents, and discussions of monitoring to ensure implementation of adopted measures. 7. BLM IM No. 2008-050, Migratory Bird Treaty Act - Interim Management Guidance (December 2007). This IM provides direction to avoid, reduce, or mitigate adverse impacts to the habitats of migratory bird species of conservation concern to the extent feasible, and in a manner consistent with regional or statewide bird conservation priorities. 8. BLM IM No. 2005-069, Offsite Mitigation, Interim Offsite Compensatory Mitigation for Oil, Gas, Geothermal and Energy Rights-of-way Authorizations (February 1, 2005). This IM outlines interim policy for the use of compensatory (offsite) mitigation for oil, gas, geothermal, and energy rights-of-way on an "as appropriate" basis where it can be performed onsite and on a voluntary basis. It was replaced by BLM IM no. 2008 204 (see #5 above). 9. BLM land use planning regulations, 43 CFR 1610 and Land Use Planning Handbook H-1601-1 (2005). BLM's land use planning regulations and handbook provide broad guidance on the development of land use plans. The handbook guidance includes the consideration of mitigation measures, as appropriate, to address resource, social, and economic impacts. 10. BLM Protecting Cultural Resources Manual (MS-8140) (December 2004). This Manual provides general guidance for protecting cultural resources from inadvertent adverse effects associated with BLM land use decisions, pursuant to the National Historic Preservation Act, the National Environmental Policy Act, Executive Order 11593, and the National Programmatic Agreement regarding the manner in which the BLM will meet its responsibilities under the National Historic Preservation Act. 11. BLM hardrock mining regulations, 43 CFR 3809. Among the general performance standards for surface management within a mining plan of operations is the requirement to "take mitigation measures specified by BLM to protect public lands" (43 CFR 3809.420(a)(4)). 12. BLM FLPMA right of way regulations, 43 CFR 2800. These regulations require holders to "restore, revegetate, and curtail erosion or conduct any other rehabilitation measures BLM determines necessary" including conditioning agreements on compensatory mitigation (43 CFR 2805.12(i)). 13. BLM easement regulations, 43 CFR 2920. These regulations "direct BLM to include terms and conditions that... `minimize damage'" and "require the use to be located in an area which shall cause the least damage to the environment" (43 CFR 2920.7(b)). 5 Specifically, it describes three toolkits available for BLM staff to use when estimating emissions for NEPA or other purposes. 5. BLM IM 2017-037: Waste Mine Methane Policy. This IM establishes national policies and processes to foster voluntary activities by operators to capture waste mine methane from underground coal or other solid mineral mines. These policies allow waste mine methane to be put to productive use, where economical, and reduce environmental impacts, while ensuring continued safe underground mining operations on Federal lands 6. BLM Waste Prevention, Production Subject to Royalties, and Resource Conservation regulation. 81 Fed. Reg. 83008 (January 17, 2017). This new rule provided guidance on managing methane. Please see response to Section 5(c) for more information on this rule. PREVIOUS BLM CLIMATE CHANGE ACTIONS Prior to issuance of the documents listed in SO 3349, the BLM took the following actions of note related to climate change: 1. BLM New Mexico IM No. NM-2013-022, Availability of Updated Air Resources Technical Report (ARTR); Use of Environmental Assessment (EA) Template Air Quality and Climate Change Language for Applications for Permit to Drill (APDs) and Lease Sales (June 2013). This IM instructed District and Field Offices to use the latest version of the BLM New Mexico Air Resources Technical Report, and provided template language for use in NEPA environmental analysis documents to address air quality and climate change impacts. 2. BLM Oregon/Washington IM No. OR-2010-012, Analysis of Greenhouse Gas Emissions and Consideration of Climate Change in National Environmental Policy Act Documents (January 2010). This IM provided guidance on analyzing greenhouse gas emissions and addressing changing climate conditions in NEPA documents. The IM expired in October 2011. 3. BLM IM No. 2008-171, Guidance on Incorporating Climate Change into Planning and NEPA Documents (August 2008). This IM transmitted draft guidance on incorporating climate change considerations into the Land Use Planning/NEPA analysis process, and requested feedback from the BLM states on their experience with incorporating climate change into NEPA documents. 4. BLM Land Use Planning Handbook H-1601-1 (2005). BLM's land use planning regulations and handbook provide broad guidance on the development of land use plans. The handbook guidance includes the consideration of climate change. BLM has also developed tools and a report to assist in assessing emissions, including the following: 1. Tool: BLM Emissions Inventory Toolkit. The BLM Washington Office is developing an Emissions Inventory Toolkit, scheduled for completion in September 2017, which would consolidate and enhance existing emissions inventory tools that have been 7