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Case 1:13-cv-01723-RBJ Document 91 Filed 06127/14 USDC Colorado Page 23 of 36 <br />iii. The Lease Modification FEIS Adequately Considered the Effect of <br />Possible VOC Emissions. <br />Plaintiffs also claim the FEIS devoted insufficient attention to the possibility of volatile <br />organic compound ("VOC"} emissions from the methane wellss that would almost certainly be <br />drilled as a part of the Lease Modification. Methane itself is not a precursor to VOCs, but <br />hexane, propane, and a variety of other chemicals that often accompany coal -bed methane do <br />have the potential to create VOCs. 40 C.F.R. § S 1.100 (s)(1). The agencies acknowledged that <br />VOC pollution is a "key" issue, but they made no effort to quantify potential VOC pollution in <br />the FEIS. BLM—mods-9817 at 9826; see also BLM_mods7213 at 7222 (preliminary EA); <br />FSLeasing-0046776 at 0046872-73. <br />The parties devote several pages of briefing to this issue. In a nutshell, the defendants <br />argue that VOC emissions are highly variable; that existing data (which are sparse and relatively <br />old) suggest that regardless of the variability those emissions are low; and that the only evidence <br />suggesting emissions may be significant and worthy of additional study is the plaintiffs' faulty <br />mathematical extrapolation using the old data. In response, the plaintiff's claim that their math is <br />reasonable, existing facilities are unlikely to detect whether local VOC emissions are high, and in <br />any event, the agencies have an obligation to go out and collect more data to determine whether <br />VOC emissions are significant. <br />Just because the agencies called VOC pollution a "key" issue does not mean VOC <br />.pollution is likely to be significant. The agencies also offered several seemingly non -arbitrary <br />reasons why the existing data are too variable and the emissions are too low to be useful in <br />S These methane wells are designed to vent methane from the underground mine for safety reasons. They <br />are unrelated to the exploratory wells Arch plans to drill in order to determine the extent of the underlying <br />coal seam. <br />23 <br />