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Appeal Deciding Officer 27 <br />once, in its analysis of emissions from mine operation and coal transport, stating that "trace <br />amounts of organic compounds [from diesel engines] ... can cause short-term odor problems. <br />The 2000 Iron Point FEIS completely fails to address pollutants found in vented methane. <br />Instead, the FEIS's brief discussion of methane emissions states only that methane is vented to <br />the atmosphere. The Forest Service cannot "tier" to or otherwise rely on an 11- year -old analysis <br />that omits any discussion of the most likely source of VOC pollution. <br />Discussion: <br />Also see the discussion above in Appeal IV issue. <br />Ozone is not emitted directly into the air but is formed by the reaction of Volatile Organic <br />Compounds (VOCs) and nitrogen oxides (NOx) in the presence of heat and sunlight. VOCs are <br />emitted from a variety of sources, including motor vehicles, and other industrial sources. NOx is <br />emitted from motor vehicles and other sources of combustion. <br />The appellant argues that ozone analysis should have been completed directly for this lease <br />modification based on the fact that the BLM conducted a rudimentary ozone analysis in the draft <br />EIS for the nearby Red Cliff coal mine. However, it should be noted that the BLM analysis was <br />for an impact of a whole mine including surface disturbance. This lease modification clearly <br />does not authorize any new surface disturbance which would lead to an increase of VOC's and <br />NOx emissions which is discussed in the EA (Section 3.2 pages 41 to 60). The fact that this <br />lease modification is significantly smaller in the amount of coal proposed for removal (35,000 to <br />235,000 tons equivalent to addition of 2 days to 3 weeks of mining) and allows no new surface <br />disturbance it was clearly stated in the EA that this will contribute such minor changes in the <br />amounts of NOx or VOCs to the air, that those changes would not be readily evident in further <br />modeling. The EA also states that "The equipment used for the lease modification will be the <br />same equipment that is being used in the current mining operations. Therefore, the air quality <br />impacts associated with the proposed mine expansion can be presumed to be equal to, or less <br />than, impacts predicted in the original air quality impact assessment due to more stringent <br />regulations." <br />The DN/FONSI was clear to state the Oxbow will be required to maintain their current APEN <br />with the State of Colorado who has been delegated the authority over air quality regulation and <br />enforcement. The proposed action is not anticipated to require any amendments or modification <br />to the APEN. The issue of NOx and VOCs emission as well as their relationship to ozone is <br />apparent in the analysis and was not overlooked. <br />Recommendation: <br />I recommend that the Forest Supervisor's decision be affirmed on this point regarding analysis of <br />ozone, NOx and VOCs. <br />