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Appeal Deciding Officer 26 of these explanations excuses the EA's failure to analyze and assess the Lease modification's impacts to ambient ozone concentrations. The Forest Service's argument that ozone analysis is too "complex" to perform contradicts both federal land management agency practice and EPA's recommendations for similar coal leases and other sources in Colorado. For example, the Clean Air Act and EPA guidance require every new major source in a NAAQS attainment area to demonstrate that its emissions will not cause or contribute to an ozone NAAQS violation, which involves the type of "complex" analysis that the Forest Service declined to do here. 42 U.S.C. § 7475(a)(3), (e).59 Moreover, BLM conducted a rudimentary ozone analysis in the draft EIS for the nearby Red Cliff coal mine in Colorado.60 The Forest Service does not explain why BLM conducted an ozone analysis for a nearby coal mine, but a similar analysis for the Lease Modification would be too complex. Agencies must rationally explain their actions and conclusions; the Forest Service failed to so do here. Motor Vehicle Mfrs. Ass'n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); see also S. Utah Wilderness Alliance v. Kempthorne, No. 08 -0411 (LFO) (D.D.C. Order Dec. 1, 2008) (rejecting unsupported BLM determination that ozone analysis is "too costly and time consuming," and enjoining decision approving oil leases), attached as Exh. 40. The Forest Service attempts to justify its failure to consider the Lease Modification's impacts on ambient ozone concentrations by asserting that "[a] detailed air quality assessment, including modeling, of the original mine was conducted as part of the environmental analysis for the Elk Creek Coal Lease Tract in 2000." The 2000 Iron Point FEIS the Forest Service refers to, however, did not analyze or assess impacts to ambient ozone concentrations. No agency expert specifically analyzed the Mine's impacts to ozone concentrations in the EA or the 2000 FEIS. Even if the 2000 Iron Point FEIS had analyzed impacts to ambient ozone concentrations, that analysis would be outdated and not appropriate for tiering for the EA. The Forest Service's efforts to "tier" to the 2000 Iron Point FEIS to justify the lack of ozone analysis in the EA violate NEPA. IV -A -I: THE EA FAILS TO ANALYZE NOx EMISSIONS Despite the significant impact of NOx emissions on ambient ozone concentrations, the EA makes no effort to quantify the NOx emissions that will result from the lease modification. Nor does the EA analyze the impacts to air quality of the Lease Modification's NOx emissions. IV-A-2: EA FAILS TO ADEQUATELY ANALYZE VOC EMISSIONS While the Forest Service failed to analyze the scope of VOC emissions for the Lease Modification, data from the nearby West Elk Mine — about five miles from the Lease Modification area — shows that non - methane hydrocarbons (i.e., VOCs) there constitute approximately 1% of the methane emissions from that mine's methane drainage wells. The EA fails to analyze or disclose VOC emissions at all. Nor can the Forest Service rely on the 2000 Iron Point FEIS for an analysis of the VOCs. That FEIS mentions VOC emissions only