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also be emitted by the ventilation air handling system required by MSHA to reduce the combustion /explosion potential of the mine's underground atmosphere (this methane is also known as Ventilation Air Methane or VAM). BME also plans to drill gob vent boreholes (GVB) as part of its operations at the mine. GVBs act to drain any trapped methane gas in the coal formation, overburden, and surrounding strata to reduce the potential buildup of the gas within the mine as the coal is extracted. Methane emissions from these activities would require reporting to EPA under the previously mentioned Mandatory Reporting Rules if reporting thresholds are exceeded. Although methane is not a regulated volatile organic compound, recent analyses of CMM gas from other mines in Colorado, including the West Elk and Elk Creek mines in the North Fork Valley (Delta and Gunnison Counties), indicate that regulated volatile organic compounds make up a percentage of the CMM constituents, and these gases would be released as result of CMM venting. BME has yet to perform or initiate a thorough screening assessment of its operations to determine the mine's status for VOC emissions under the Clean Air Act. Although the BLM is not the regulatory agency for determining major source status for stationary sources of emissions (i.e., CDPHE), it is likely that a screening /CMM sampling analysis would need to be initiated for a sufficient period of time to determine if there is a reasonable correlation between the gases' methane and VOC percentages. This would allow the mine and /or CDPHE to perform a back calculation of the mine's known CMM releases from its required MSHA sampling data and determine a reasonable total for any VOCs released. If through sampling it is shown that a reasonable correlation does not exist (i.e., highly variable percentages), then more detailed and prolonged sampling and gas analysis would probably be required to make a determination of regulatory applicability. Given the low permitting thresholds for VOCs in Colorado, it is likely the mine would be subject to at least minor source permitting or Air Pollution Emission Notice (APEN) submissions. To reiterate, CDPHE, not the BLM, will determine an appropriate methodology and or requirements to determine regulatory applicability for these sources of emissions in Colorado. It is the BLM's understanding through personal communication with CDPHE staff that discussions within APCD are ongoing about providing resolution for this matter on a state -wide basis. Stationary sources (including any area and fugitive emissions) at the Deserado Mine are regulated by CDPHE where applicable and are authorized by several APCD permits (12R]3802- IF, 12RB802 -2, 12RB802 -3F, 12RB802 -5, 12RB802 -6, 85RB327F, 89RB317F, 93RB1171F, OORB0283).The permits provide limitations and requirements to limit potential emissions from the site to below major source thresholds for certain criteria pollutants. The Deserado Mine is currently classified as a synthetic minor source for all criteria pollutants and would therefore not be subject to the PSD rule requirements for permitting of those pollutants at this time. When pollutants are not explicitly addressed in an APCD permit it is due to the fact that those emissions are below CDPHE's permitting thresholds, or in the case of GHG's, are not part of the State's minor source permitting program. The Deserado Mine last had one if its air permits revised and issued by APCD on Jun. 25, 2009. It is not probable given the age of the permit that CDPHE evaluated the status of the mine for major source determination for GHG's. As previously stated Blue Mountain Energy does not anticipate modifying its permit to accommodate any additional production it would realize from the availability of additional coal DOI- BLM -CO- 110- 2012- 0023 -EA 20