Wyoming State Office – Casper Field Office

DRAFT 

Environmental Impact Statement for the

West Antelope II Coal Lease Application 

WYW163340 

February 2008
 
 

MISSION STATEMENT 

It is the mission of the Bureau of Land Management to sustain the health, diversity, 

and productivity of the public lands for the use and enjoyment of present and 

future generations. 

BLM/WY/PL-08/009+1320 


 

 

 

 

 

DRAFT ENVIRONMENTAL IMPACT STATEMENT 

WEST ANTELOPE II COAL LEASE APPLICATION 

CONVERSE AND CAMPBELL COUNTIES, WYOMING 

ABSTRACT 

Lead Agency:	 USDI Bureau of Land Management 

 Casper Field Office 

 Casper, Wyoming 

Cooperating Agencies: USDI Office of Surface Mining Reclamation and Enforcement 

Western Region 

Denver, Colorado 

USDA Forest Service 

Medicine Bow-Routt National Forests and Thunder Basin 

National Grassland 

Douglas, Wyoming 

Wyoming Department of Environmental Quality 

Land Quality Division and Air Quality Division 

Cheyenne, Wyoming 

Converse County Board of Commissioners 

Douglas, Wyoming 

For Further Information Contact: Sarah Bucklin 

Bureau of Land Management, Casper Field Office 

 2987 Prospector Drive 

 Casper, WY 82604 

 (307) 261-7541 

Abstract: This Draft Environment Impact Statement (EIS) assesses the environmental consequences of 

decisions to hold a competitive, sealed-bid sale and issue a lease for a tract of federal coal located 

adjacent to an existing surface coal mine in Converse and Campbell Counties, Wyoming, subject to 

standard and special lease stipulations. The West Antelope II Lease by Application (LBA) tract, as applied 

for by Antelope Coal Company, includes approximately 4,108.6 acres containing approximately 429.7 

million tons of in-place federal coal. Antelope Coal Company, the operator of the adjacent Antelope Mine, 

proposes to mine the tract as a maintenance lease for the existing mine, if a lease sale is held and they 

acquire the lease. 

This Draft EIS describes the physical, biological, cultural, historic, and socioeconomic resources in and 

around the existing mine and the LBA tract. The alternatives in the Draft EIS consider the impacts of 

leasing the tract as it was applied for, leasing a reconfigured tract in order to avoid bypassing federal coal 

or to increase competitive interest in the tract, and not leasing the tract. The focus for the impact analysis 

was based upon resource issues and concerns identified during previous coal leasing analyses and 

public scoping conducted for this lease application. Potential concerns related to development include 

impacts to groundwater, air quality, wildlife, and cumulative impacts related to ongoing surface coal 

mining and other proposed development in the Powder River Basin of Wyoming. 

Other Environmental Review or Consultation Requirements: 

This Draft EIS, in compliance with Section 7(c) of the Endangered Species Act (as amended), identifies 

any endangered or threatened species which are likely to be affected by the Proposed Action. 
WEST ANTELOPE II COAL LEASE APPLICATION 

DRAFT ENVIRONMENTAL IMPACT STATEMENT
 

Prepared by 

EDE Consultants 

Sheridan, Wyoming
 

Under the Direction of 

U.S. Department of the Interior 

Bureau of Land Management 

Casper Field Office 

Casper, Wyoming
 

and 

Cooperating Agencies 

U.S. Department of Interior 

Office of Surface Mining 

Reclamation and Enforcement 

Western Region 

Denver, Colorado
 

U.S. Department of Agriculture 

Forest Service 

Medicine Bow-Routt National Forests and 

Thunder Basin National Grassland 

Douglas, Wyoming
 

Wyoming Department of Environmental Quality 

Land Quality Division and Air Quality Division 

Cheyenne, Wyoming
 

Converse County Board of Commissioners 

Douglas, Wyoming
 

February 2008 
 

 

 Executive Summary 

EXECUTIVE SUMMARY 

On April 6, 2005, ACC1 filed an application with the BLM for a maintenance 

tract of federal coal adjacent to ACC’s Antelope Mine in Campbell and Converse 

Counties, Wyoming (Figures ES-1 and ES-2). The application, which was 

assigned case file number WYW163340, is referred to as the West Antelope II 

LBA coal lease application. As currently applied for, the West Antelope II LBA 

tract includes approximately 4,109 acres and ACC estimates that it includes 

465.1 million tons of in-place federal coal. The lands applied for in this 

application are located approximately 20 miles southeast of the town of Wright, 

Wyoming. 

This lease application was reviewed by the Division of Mineral and Lands at the 

BLM Wyoming State Office, who determined that the application and the lands 

involved met the requirements of the regulations governing coal leasing on 

application at 43 CFR 3425.1. The PRRCT reviewed this lease application at a 

public meeting held on April 27, 2005 in Gillette, Wyoming. The PRRCT 

recommended that the BLM process the West Antelope II lease application. 

In order to process an LBA, the BLM must evaluate the quantity, quality, 

maximum economic recovery, and fair market value of the federal coal and 

fulfill the requirements of the NEPA by evaluating the environmental 

consequences of leasing the federal coal. 

To evaluate the environmental impacts of leasing and mining the coal, the BLM 

must prepare an EA or an EIS to evaluate the site-specific and cumulative 

environmental and socioeconomic impacts of leasing and developing the federal 

coal in the application area. The BLM made a decision to prepare an EIS for 

this lease application. BLM does not authorize mining by issuing a lease for 

federal coal, but the impacts of mining the coal are considered in this EIS 

because it is a logical consequence of issuing a maintenance lease to an 

existing mine. 

The EPA will publish a notice announcing the availability of the Draft EIS in 

the Federal Register. A 60-day comment period on the Draft EIS will 

commence with publication of the EPA’s notice of availability. The BLM will 

publish a Notice of Availability/Notice of Public Hearing in the Federal Register. 

The BLM’s Federal Register notice will announce the date and time of a public 

hearing to be held during the 60-day comment period. The purpose of the 

public hearing will be to solicit public comments on the Draft EIS and on the 

fair market value, the maximum economic recovery, and the proposed 

competitive sale of federal coal from the LBA tract. The BLM will also publish a 

notice of public hearing in the Gillette News-Record and in the Douglas Budget 

newspapers. All substantive written comments received on the DEIS will be 

included, with agency responses, in the FEIS. 

1 Refer to page xv for a list of abbreviations and acronyms used in this document. 

Draft EIS, West Antelope II Coal Lease Application ES-1 
 

E

E

E

Executive Summary 

ST59 LEGEND

¥¦

West Hay Creek Existing Coal Leases (Prior to Decertification) 

tu

90 

16 

tu

tu

16 

14 

LBA's Issued
 

Hay Creek II
 Belco I90 LBA's Pending Exchange Lease LBA Tract As Applied For (This EIS) Buckskin Mine 

Urban Area 

County Boundary Rawhide Mine 

Eagle Butte Mine 

Eagle Butte West Dry Fork Mine 

Eagle Butte 

Wyodak Mine 

¥¦Rozet

90

GILLETTE

o To Buffal

38 Miles 

Campbell County
 

Crook County
 

Moorcroft

¥¦90

West Rocky Butte 

Caballo West 

Belle Ayr North Caballo Mine 

Belle Ayr Mine 

Johnson County 

Campbell County 

Cordero-Rojo Mine 

ST50 Maysdorf 

Maysdorf II 

West Coal Creek 

Coal Creek Mine 

ST59

Weston County 

West Jacobs Ranch 

Hilight Field 

Thundercloud Little Thunder 

ST116

North Jacobs Ranch RENO Jacobs JUNCTION Ranch 

Jacobs Ranch Mine 

WRIGHT West Black Thunder West Hilight 

Black Thunder Mine 

ST387 West Roundup 

NARO North 

ST450 North Rochelle 

School Creek Mine 

To Newcastle 

29 Miles 

0 £ Campbell County 

Converse County 

10 

Horse Creek 

West Antelope 

Porcupine 

West Antelope II 

20 ST59

Weston County 

Niobrara County 

Powder River 

NARO South 

North Antelope / Rochelle Mine 

North Antelope/ Rochelle 

Antelope Mine 

To Douglas 

GRAPHIC SCALE - MILES 46 Miles

Figure ES-1. General Location Map with Federal Coal Leases and LBA Tracts. 

ES-2 Draft EIS, West Antelope II Coal Lease Application 
 

 

Executive Summary 

Campbell County 

Converse County 

North Antelope / Rochelle 

Rail Line 

An telope Road 

B.N.S.F. & U.P RR 

T. 

40 

N. 

R. 72 W. R. 70 W. 

T. 

41 

N. 

T. 

41 

N. 

R. 71 W. 

T. 

40 

N. 

R. 71 W. 

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

9 

3 6 

8 

2 

7 

1 

8 

5 

8 

5 4

9 

7 8 

7 

1 6 

7 

4 

9 

1 

9 

6 5 4 3 2 1 6 5 4 

11 

12 

22 

11 

27 

13 

15 

24 

10 

20 

26 

18 

19 

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30 

20 21 

29 

23 

15 

14 

29 28 

14 13 

16 

12 

30 

12 

13 17

16 

25 

19 

17 18 

32 

17 

34 

10 

18 

31 32 33 35 31

18 

36 

13 

12 

28 

25 

33 

24 21 

36 

16 

16 

23 24 19 20 21 22 24 19 20 21 

31 32 33 34 35 36 31 32 33 36 

2 

11 

14 

23 

!(59 

LEGEND 

Antelope Mine Permit Boundary 

Anticipated Permit Amendment Study Area 

West Antelope II LBA Tract As Applied For 

Area Added under Alternative 1 

North Tract (Alternative 2) 

South Tract (Alternative 2) 

General Analysis Area 

£ 0 8,000 16,000 

GRAPHIC SCALE (FEET) 

Figure ES-2. General Analysis Area. 

B.N.S.F. & U.P. RR 

Draft EIS, West Antelope II Coal Lease Application ES-3
 
Executive Summary 

BLM will use the analysis in this EIS to decide whether to hold a competitive, 

sealed-bid lease sale for the tract as applied for, hold a competitive, sealed-bid 

lease sale for a modified tract, or reject the lease application and not offer the 

tract for sale at this time. A Record of Decision will be issued and, if the 

decision is to offer the tract for lease, then a sale will be held. If a sale is held, 

the bidding at the sale would be open to any qualified bidder. If a lease sale is 

held for this LBA tract, the applicant (ACC) may not be the successful high 

bidder. If the lease sale is held, a federal coal lease would be issued to the 

highest bidder at the sale if a federal sale panel determined that the high bid 

meets or exceeds the fair market value of the coal as determined by BLM’s 

economic evaluation, and if the U.S. Department of Justice determines that 

there are no antitrust violations if a lease is issued to the high bidder. 

Cooperating agencies in the preparation of this EIS include USDA-FS, OSM, 

WDEQ/AQD, WDEQ/LQD, and the Converse County Board of Commissioners. 

Other agencies, including OSM, will also use this analysis to make decisions 

related to leasing and mining the federal coal in this tract. 

A decision to lease the federal coal lands in this application would be in 

conformance with the BLM Resource Management Plan for the Buffalo and 

Casper Field Offices and with the TBNG Land and Resource Management Plan. 

The West Antelope II LBA tract is contiguous with the Antelope Mine. The 

analysis in this EIS assumes that ACC would be the successful bidder on the 

West Antelope II LBA tract if a sale were held, and that it would be mined as a 

maintenance tract for the Antelope Mine. 

A Proposed Action and three alternatives to that action are analyzed in detail in 

this DEIS. 

• Proposed Action - The Proposed Action is to hold a competitive coal 

lease sale and issue a maintenance lease to the successful bidder for the 

West Antelope II LBA tract as applied for (Figure ES-2). Under the 

Proposed Action, ACC currently estimates that average annual 

production would be between 36 and 42 million tons per year and the 

life of the existing mine would be extended by 10 to 12 years. The 

Antelope Mine presently has a workforce of 430 employees, and as many 

as 25 to 40 additional workers may be needed at times during the life-ofmine. 

• Alternative 1 - Under Alternative 1, BLM would hold a competitive lease 

sale and issue a maintenance lease for a tract that is larger than the 

applied-for configuration. BLM has identified 2,200.6 acres that are 

adjacent to the tract as applied for that could be added in order to 

maximize economic recovery and avoid bypassing potentially recoverable 

federal coal (Figure ES-2). If all of these lands are added to the tract, 

this alternative would add about 65 million tons of unleased federal coal 

to the West Antelope II LBA tract as applied for. Under this alternative, 

ES-4 Draft EIS, West Antelope II Coal Lease Application 
 Executive Summary 

production and average employment would be similar to the Proposed 

Action. 

• Alternative 2 - This alternative considers dividing the tract as applied 

for into two tracts and offering one or both of those tracts for sale. A 

separate, competitive sealed-bid sale would be held for each tract that is 

offered for sale (Figure ES-2). This alternative also includes the 2,200.6 

identified under Alternative 1 that BLM is considering adding to the 

tract. Production and employment would be similar to the Proposed 

Action. 

• Alternative 3 - Under this alternative, the LBA tract would not be 

leased, but the existing leases at the adjacent Antelope Mine would be 

developed according to the existing approved mining plans. Under the 

No Action Alternative, the Antelope Mine would mine its remaining 

leased coal reserves in approximately 9 to 11 years at an average annual 

production rate of 36 to 42 million tons per year and average 

employment would be approximately 430 persons. Rejection of the lease 

application would not preclude an application to lease the tract in the 

future. 

Surface ownership within the West Antelope II LBA tract as applied for under 

the Proposed Action and the lands added under Alternatives 1 and 2 consists 

primarily of private lands. A small tract of federal land is administered by 

USDA-FS. 

Tables ES-1 and ES-2 summarize coal production, surface disturbance, mine 

life, and revenues for the Proposed Action and Alternatives 1, 2, and 3 for the 

West Antelope II LBA tract for a base-case production rate of 36 mmtpy and for 

the currently permitted production rate of 42 mmtpy. The environmental 

impacts of mining the LBA tract would be similar under the Proposed Action 

and Alternatives 1 and 2. 

Other alternatives that were considered but not analyzed in detail include 

holding a competitive coal lease sale and issuing a lease to the successful 

bidder (not the applicant) for the purpose of developing a new stand-alone 

mine, and delaying the sale of the West Antelope II LBA tract as applied for to 

increase the benefit to the public afforded by higher coal prices and/or to allow 

more complete recovery of the potential CBNG resources in the tract prior to 

mining. 

Critical elements of the human environment (BLM 1988) that could potentially 

be affected by the Proposed Action or Alternatives 1 and 2 include air quality, 

cultural resources, Native American religious concerns, T&E species, 

hazardous or solid wastes, water quality, wetlands/riparian zones, invasive 

non-native species, and environmental justice. Five other critical elements 

(areas of critical environmental concern, prime or unique farmlands, wild and 

scenic rivers, floodplains, and wilderness) are not present in the general 

Draft EIS, West Antelope II Coal Lease Application ES-5 
Executive Summary 

Table ES-1. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and Revenues for 

Tract and Antelope Mine - Assuming Average Annual Post-2006 Coal Production is 36 mmt. 

Alternative 3-No 

Action Alternative 

(Existing Antelope 

Item Mine) 

In-Place Coal (as of 1/1/07) 428.6 mmt 

Mineable Coal (as of 1/1/07)1 428.6 mmt 

Recoverable Coal (as of 1/1/07)2 394.3 mmt 

Coal Mined Through 2006 318.9 mmt Potential Lease Area3 11,635.5 ac 

Total Area To Be Disturbed4 12,104.8 ac Permit Area4 14,280.1 ac 

Average Annual Post-2006 Coal 36 mmt Production Remaining Life of 11 yr Mine (post-2006) Average Number of Employees 430 

Total Projected State and $ 657.3 million Local Revenues (post-2006)5,6 

Total Projected Federal $ 473.7 million Revenues (post-2006)7 

Added by

Proposed Action 

(tract as applied for} 

465.1 mmt 

463.7 mmt 429.5 mmt 

⎯

4,108.6 ac 4,314.0 ac 4,490.2 ac 

0 mmt 

12 yr 

up to 25 

$ 780.4 - $ 924.3 million $ 580.5 - $ 724.3 million 

Added by

Alternative 2 

Added by Alternative 1 (North Tract) 

530.0 mmt 442.7 mmt 

490.0 mmt 403.2 mmt 453.9 mmt 374.6 mmt 

⎯ ⎯

6,309.2 ac 3,248.5 ac 6,624.7 ac 3,410.9 ac 7,405.3 ac 3,616.4 ac 

0 mmt 0 mmt 

13 yr 10 yr 

up to 25 

$ 824.7 - $ 976.8 $ 680.6 - $ 806.1 mi

million 

$ 613.4 - $ 765.5 $ 506.3 - $ 631.7 mi

million 

1	 Mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railroad ROW and public road ROWs. 2 Recoverable coal figure assumes 91.3 percent recovery (south tract, two seams) or 92.9 percent recovery (north tract, one seam) of 

mining losses that occur during normal mining operations. 

3 Includes federal and state coal leases 4 The disturbed area exceeds the leased area because of the need for highwall reduction, topsoil removal, and other mine supp

boundaries. The permit area is larger than the leased or disturbed area to assure that all disturbed lands are within the permit bdefined legal land description. Permit areas for the Alternative 2 North and South Tracts overlap; the sum of these areas is therefo1 permit area. 

5	 Revenues to the State of Wyoming and local governments include severance tax, property and production taxes, sales and use 

federal royalty payments, bonus bids, and AML fees. State revenues are based on an assumed price of $9.01 per ton of 'recoverab

percent of the value less 50.5 percent federal share, plus $0.315 per ton for AML fees x an assumed 25 percent state share, plu

$0.30 and $0.97 per ton of LBA leased coal per ton (based on average of last 6 LBAs in 2004 and 2005) x tonnage of recoverable plus $0.07 per ton estimated sales and use taxes, plus $0.33 per ton estimate for ad valorem taxes, plus $0.415 per ton in severuse taxes paid directly by the mine are considered, i.e., those generated by vendors and suppliers and by consumer expenditure su

by the mine are not included. 

6	 Revenues for Alternative 3 do not include the $43.9 million in scheduled coal lease bonus bids to be paid on the West Antelope LBA 7	 Federal revenues are based on an assumed price of $9.01 per ton, federal royalty of 12.5 percent x 50.5 percent share, plus $0

assumed 75 percent federal share, plus black lung tax of $0.00261 per ton, plus bonus payments of between $0.30 and $0.97 

(based on the range of the 6 most recent last 6 LBA sales in 2004 and 2005) x tonnage of recoverable coal minus x 50 percent feder

ES-6 Draft EIS, West Antelope 
Table ES-2. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and Revenues for 

Tract and Antelope Mine - Assuming Average Annual Post-2006 Coal Production is 42 mmt. 

Alternative 3-No 

Action Alternative 

(Existing Antelope 

Item Mine) 

In-Place Coal (as of 1/1/07) 428.6 mmt 

Mineable Coal (as of 1/1/07)1 428.6 mmt 

Recoverable Coal (as of 1/1/07)2 394.3 mmt 

Coal Mined Through 2006 318.9 mmt Potential Lease Area3 11,635.5 ac 

Total Area To Be Disturbed4 12,104.8 ac Permit Area4 14,280.1 ac 

Average Annual Post-2006 Coal 36 mmt Production Remaining Life of 11 yrs Mine (post-2006) Average Number of Employees 430 

Total Projected State and $ 657.3 million Local Revenues (post-2006)5,6 

Total Projected Federal $ 473.7 million Revenues (post-2006)7 

Added by

Proposed Action 

(tract as applied for} 

465.1 mmt 

463.7 mmt 429.5 mmt 

⎯

4,108.6 ac 4,314.0 ac 4,490.2 ac 

6 mmt 

10 yr 

up to 40 

$ 780.4 - $ 924.3 million $ 580.5 - $ 724.3 million 

Added by

Alternative 2 

Added by Alternative 1 (North Tract) 

530.0 mmt 442.7 mmt 

490.0 mmt 403.2 mmt 453.9 mmt 374.6 mmt 

⎯ ⎯

6,309.2 ac 3,248.5 ac 6,624.7 ac 3,410.9 ac 7,405.3 ac 3,616.4 ac 

6 mmt 6 mmt 

11 yr 9 yr 

up to 40 

$ 824.7 - $ 976.8 $ 680.6 - $ 806.1 mi

million 

$ 613.4 - $ 765.5 $ 506.3 - $ 631.7 mi

million 

1	 Mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railroad ROW and public road ROWs. 2 Recoverable coal figure assumes 91.3 percent recovery (south tract, two seams) or 92.9 percent recovery (north tract, one seam) of 

mining losses that occur during normal mining operations. 

3 Includes federal and state coal leases 4 The disturbed area exceeds the leased area because of the need for highwall reduction, topsoil removal, and other mine supp

boundaries. The permit area is larger than the leased or disturbed area to assure that all disturbed lands are within the permit bdefined legal land description. Permit areas for the Alternative 2 North and South Tracts overlap; the sum of these areas is therefo1 permit area. 

5	 Revenues to the State of Wyoming and local governments include severance tax, property and production taxes, sales and use 

federal royalty payments, bonus bids, and AML fees. State revenues are based on an assumed price of $9.01 per ton of 'recoverab

percent of the value less 50.5 percent federal share, plus $0.315 per ton for AML fees x an assumed 25 percent state share, plu

$0.30 and $0.97 per ton of LBA leased coal per ton (based on average of last 6 LBAs in 2004 and 2005) x tonnage of recoverable plus $0.07 per ton estimated sales and use taxes, plus $0.33 per ton estimate for ad valorem taxes, plus $0.415 per ton in sever

use taxes paid directly by the mine are considered, i.e., those generated by vendors and suppliers and by consumer expenditure su

by the mine are not included. 

6	 Revenues for Alternative 3 do not include the $43.9 million in scheduled coal lease bonus bids to be paid on the West Antelope LBA 7	 Federal revenues are based on an assumed price of $9.01 per ton, federal royalty of 12.5 percent x 50.5 percent share, plus $0

assumed 75 percent federal share, plus black lung tax of $0.00261 per ton, plus bonus payments of between $0.30 and $0.97 

(based on the range of the 6 most recent last 6 LBA sales in 2004 and 2005) x tonnage of recoverable coal minus x 50 percent feder

Draft EIS, West Antelope II Coal Lease Application	 
 

Executive Summary 

analysis area and are not addressed further. In addition to the critical 

elements that are potentially present in the general analysis area, this EIS 

discusses the status and potential effects of mining the LBA tract on 

topography and physiography, geology and mineral resources, soils, water 

quantity, alluvial valley floors, vegetation, wildlife, land use and recreation, 

paleontological resources, visual resources, noise, transportation resources, 

and socioeconomics. 

The project area is located in the PRB, a part of the Northern Great Plains that 

includes most of northeastern Wyoming. The West Antelope II LBA tract is 

located in the eastern part of the PRB, in an area consisting primarily of a 

dissected rolling upland plain with low relief, broken by steeply cut washes. 

Elevations range from about 4,500 ft to 5,100 ft above sea level and slopes 

range from flat to around 34 percent and average about five percent. There are 

four mineable coal seams at the Antelope Mine and within the West Antelope II 

LBA tract. Locally, these seams are referred to as the Anderson, Lower 

Anderson, Canyon/Upper Canyon, and Lower Canyon. These seams are part 

of what is more widely known as the Wyodak-Anderson coal zone of the Tongue 

River Member of the Fort Union Formation. Mining would remove an average 

of 280 ft of overburden and 60 ft of coal on about 4,109 acres under the 

Proposed Action. Mining would remove an average of 260 ft of overburden and 

50 ft of coal on about 6,309 acres under Alternatives 1 and 2. 

The existing topography on the LBA tract would be substantially changed 

during mining. A highwall with a vertical height equal to overburden plus coal 

thickness would exist in the active pits. Following reclamation, the average 

surface elevation would be lower due to removal of the coal. The reclaimed 

land surface would approximate premining contours and the basic drainage 

network would be retained; however, the reclaimed surface would contain fewer 

and gentler topographic features. This could contribute to reduced habitat 

diversity and wildlife carrying capacity on the LBA tract. These topographic 

changes would not conflict with regional land use, and the postmining 

topography would adequately support anticipated postmining land use. 

The geology from the base of the coal to the land surface would be subject to 

considerable permanent change on the LBA tract under the Proposed Action or 

Alternatives 1 and 2. After removal of the coal, the replaced overburden would 

be a relatively homogeneous mixture compared to the premining layered 

overburden. Development of other minerals potentially present on the West 

Antelope II LBA tract could not occur during mining, but could occur after 

mining. 

There are currently no producing conventional oil and gas wells on the West 

Antelope II LBA tract under the Proposed Action or Alternatives 1 and 2. 

Conventional oil and gas wells near the tract, if disturbed by mining, would 

have to be plugged and abandoned during mining but could be recompleted 

after mining if the remaining reserves justify the expense of the recompletion. 

ES-8 Draft EIS, West Antelope II Coal Lease Application 
 Executive Summary 

Forty CBNG wells have been completed in the Wyodak-Anderson coal zone in 

the sections that include the West Antelope II LBA tract under the Proposed 

Action and Action Alternatives. Thirty of these wells are capable of producing. 

CBNG resources that are not recovered prior to mining would be vented to the 

atmosphere and irretrievably lost when the coal is removed. BLM’s policy is to 

optimize recovery of both resources, ensure the public receives a reasonable 

return, and encourage agreements between lessees or use BLM authority to 

minimize loss of publicly owned resources. 

No significant or unique paleontological resources have been recorded in the 

general analysis area. 

Moderately adverse short-term impacts to air quality would be extended onto 

the West Antelope II LBA tract during the time it is mined if a lease is issued. 

Modeling for the current Antelope Mine permit predicted no exceedances of the 

annual PM10 WAAQS at a 42 mmtpy production rate. One exceedance of the 

PM10 WAAQS was recorded at one of the monitoring stations at the Antelope 

Mine, however, that exceedance was attributed by WDEQ/AQD to 

maintenance/construction operations on the adjacent railroad line and not to 

mining operations at the Antelope Mine. NOx modeling was also conducted in 

support of the most recent permit application, and impacts from the worst-case 

years fall well below the NAAQS. There have been no reported events of public 

exposure to NO2 from blasting activities at the Antelope Mine through 2005. 

Figure ES-3 shows the maximum modeled PM10 and NOx concentrations at the 

Antelope Mine for 2012. There have been no exceedances of the 24-hour or 

annual ambient air standards resulting from mining operations at the Antelope 

Mine through 2005 and none are expected from mining the LBA tract. 

Public exposure to emissions from surface mining operation is most likely to 

occur along publicly accessible roads and highways that pass through the 

areas of mining operations. Occupants of dwellings in the area could also be 

affected. Roads, highways, occupied dwellings, businesses, and school bus 

stops in the vicinity of the Antelope Mine and the study area for the West 

Antelope II LBA tract are shown in Figure ES-4. 

Mining would disturb the coal aquifer and the aquifers in the overburden above 

the coal within the West Antelope II LBA tract. The coal aquifer and any waterbearing strata in the overburden would be removed and replaced with 

unconsolidated backfill. The area of drawdown in the areally-continuous coal 

aquifer related to mining operations at the Antelope Mine would be expected to 

increase roughly in proportion to the increase in area affected by mining. 

Figure ES-5 shows the predicted extent of drawdown in the Anderson-Canyon 

coal seam over the life of the mine if the Antelope Mine acquires the West 

Antelope II LBA tract. The area of drawdown in the discontinuous overburden 

aquifers would be smaller. The data available indicate that, after reclamation, 

the hydraulic properties of the backfill would be comparable to the properties 

of the premining overburden and coal aquifers. TDS levels in groundwater 

from the backfill could initially be expected to be higher than in the premining 

Draft EIS, West Antelope II Coal Lease Application ES-9 
24

 

 

 

 

Executive Summary 

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Campbell County 

Converse County 

North Antelope / Rochelle 

Rail Line 

B.N.S.F. & U.P RR 

Antelope Road 

T. 

40 

N. 

R. 72 W. R. 70 W. 

T. 

41 

N. 

T. 

41 

N. 

R. 71 W. 

T. 

40 

N. 

R. 71 W. 

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

7 8 9

8 9 8

7 8 

7 7

9 

9 

1 

6 5 4 3 2 1 6 5 4 

11 

12 

22 

11 

27 

13 

24 

15 

10 

20 

26 

18 

19 

17 

30 

20 21 

29 

23 

15 

14 

29 28 

24 

14 13 

16 

12 

22 23

30 

12 

13 17

16 

20 

25 

19 

17 18 

32 

17 

34 

10 

21 

18 

19 

31 32 33 35 31

18 

36 

20 19 

28 

33 

13 

3 

21 

12 

2 1 5

25 

6 

24 

6 4 

36 

16 

5 4 

21 

1 

16 

25 30 29 28 27 26 25 30 29 28 

2 

11 

14 

!(59 

LEGEND 

Ambient Air Boundary 

Haul Roads 

Area Source 

! Receptor Location 

Existing Antelope Mine Federal Coal Leases 

West Antelope II LBA Tract As Applied For 

Area Added under Alternative 1 

North Tract (Alternative 2) £ South Tract (Alternative 2)

0 8,000 16,000 

GRAPHIC SCALE (FEET) 

County Rd. 37 

NOX=68 μg/m3 

PM10=49.9 μg/m3 

Figure ES-3. Maximum Modeled PM10 and NOX Concentrations at the Antelope Mine Ambient Air

 Boundary for the Year 2012. 

ES-10 Draft EIS, West Antelope II Coal Lease Application 
 

2

County Rd. 37 

J

B N. S. F. . & U P. . RR 

Antelope Rd. 

Executive Summary 

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

o
 T. T. 

43 43 

2

B N S F & U P . . . . . . RR

22

T. T.

41 o 41

N. o N. 

Campbell County 

Converse County 

2

o Antelope Mine Facilities 

2 2

N. N. !(450

2

o

2

T. T. 

42 42 

N. N. 

T. !(59 T. 

40 

N. 

40 

N. 

enne

lTrail Rd. 

l
 

R. 72 W. R. 71 W. R. 70 W. R. 69 W. 

LEGEND 

County Boundary l Bus Stop £
 Township - Range Border o Business

State Highway 2 Occupied Residence 

Paved Road 

Other Roads 

BNSF and UP Rail Line 

General Analysis Area 

10,000 20,000 30,000
 

GRAPHIC SCALE (FEET)
 

Figure ES-4. Roads, Highways, Occupied Dwellings, Businesses and School Bus Stops in the Vicinity of the 

Antelope Mine and the West Antelope II General Analysis Area. 

Draft EIS, West Antelope II Coal Lease Application ES-11

0 
 

 

Executive Summary 

Campbell County 

Converse County 

T.

42

N.

T.

43

N.

T.

39

N.

T.

41

N.

T.

40

N.

T.

42

N.

T.

43

N.

T.

39

N.

T.

41

N.

T.

40

N.

R.73W. R.72W. R.71W. R.70W. R.69W.

R.73W. R.72W. R.71W. R.70W. R.69W.

!(59 

£ 0 20,000 40,000 

GRAPHIC SCALE (FEET) 

Figure ES-5. Life of Mine Drawdown Map, Resulting from Currently Approved Mining with Addition of the

 West Antelope II LBA Tract. 

No Coal Line (Approximate) 

No Coal Line (Approximate) 

LEGEND

No Coal Line (Approximate) West Antelope II LBA Tract As Applied For 

Area Added under Alternative 1 

North Tract (Alternative 2) 

South Tract (Alternative 2) 

Existing Antelope Mine Federal Coal Leases 

Extent of Worst-Case Modeled and 

Extrapolated Life of Mine Canyon 

Coal Drawdown (5 ft) with 

West Antelope II LBA Tract 

ES-12 Draft EIS, West Antelope II Coal Lease Application 
 Executive Summary 

overburden and coal aquifers, but would be expected to meet Wyoming Class III 

standards for use as livestock water. 

Mining would not directly disturb aquifers below the coal. ACC has two water 

supply wells completed in aquifers below the coal and these wells would be 

used to supply water for a longer period of time if the West Antelope II LBA 

tract is leased. Antelope Mine probably would not require additional sub-coal 

wells to mine the LBA tract. 

Antelope Creek and its tributaries, most notably Horse Creek and Spring 

Creek, drain the existing Antelope Mine permit area and the West Antelope II 

LBA tract. Except for two crossings, Antelope Creek flows undisturbed from 

west to east across Antelope Mine’s current permit area. Horse Creek is 

currently disturbed by mining in the Horse Creek Amendment Area of the 

Antelope Mine. Spring Creek has recently been diverted to accommodate 

mine’s upcoming mining activities, and two other draws within the permit area 

are also slated for mine-related disturbance. Changes in runoff characteristics 

and sediment discharges would occur during mining of the LBA tract as a 

result of the destruction and reconstruction of drainage channels and the use 

of sediment control structures to manage discharges of surface water. In 

accordance with SMCRA and Wyoming State Statutes, the major channels 

would be restored after surface mining operations are completed on the West 

Antelope II LBA tract. Surface water flow, quality, and sediment discharge 

would approximate premining conditions. 

The West Antelope II LBA tract has not yet been formally evaluated for the 

presence of AVFs. However, there are stream-laid deposits in portions of Horse 

Creek and Spring Creek within the general analysis area that are potential 

AVFs. A site-specific study will be part of the mine permitting process if a lease 

sale is held and the LBA tract is proposed for mining. Declarations of the 

presence or absence of AVFs, their significance to agriculture, and the 

appropriate perimeters will then be made by the WDEQ/LQD. It is reasonable 

to assume that if the WDEQ/LQD determines AVFs are present within the LBA 

tract that is leased, mining would be permitted because all of the proposed 

lease area consists entirely of undeveloped rangeland. 

Wetland inventories have been completed on the West Antelope II general 

analysis area. Approximately 42.9 acres of wetlands and other waters of the 

U.S. have been identified. The majority of the wetlands are associated with the 

Antelope Creek, Horse Creek, and Spring Creek stream channels. The majority 

of the channel other waters of the U.S. are associated with the ephemeral 

stream channels present on the area. Existing wetlands located in the LBA 

tract would be destroyed by mining operations. Jurisdictional wetlands that 

are disturbed by mining must be replaced during the reclamation process. 

Consequences to soil resources from mining the LBA tract would include 

changes in the physical, biological, and chemical properties. Following 

reclamation, the soils would be unlike premining soils in texture, structure, 

Draft EIS, West Antelope II Coal Lease Application ES-13 
Executive Summary 

color, accumulation of clays, organic matter, microbial populations, and 

chemical composition. The replaced topsoil would be more uniform in type, 

thickness, and texture. It would be adequate in quantity and quality to 

support planned postmining land uses (i.e., wildlife habitat and rangeland). 

The predominant vegetation types, in terms of total acres of occurrence in the 

vegetation analysis area are the blue grama upland (41.65 percent) and blue 

grama roughland (20.36 percent), which occur primarily on the level uplands 

and adjacent breaks. Mining would progressively remove this native 

vegetation. Reclamation and revegetation of mined areas would occur 

contemporaneously with mining on adjacent lands. Reestablished vegetation 

would be dominated by species mandated in the reclamation seed mixtures, 

which are approved by the WDEQ/LQD. The majority of these species would 

be native to the LBA tract. Initially, the reclaimed land would be dominated by 

grassland vegetation, which would be less diverse than the premining 

vegetation. Estimates for the time it would take to restore sagebrush to 

premining density levels range from 20 to 100 years. An indirect long-term 

impact associated with this vegetative change would potentially be a decrease 

in available habitat for shrub dependent species. However, a diverse, 

productive, and permanent vegetative cover would be established on the LBA 

tract following reclamation and prior to release of the final reclamation bond. 

The decrease in plant diversity would not seriously affect the potential 

productivity of the reclaimed areas, and the proposed postmining land uses 

(wildlife habitat and rangeland) should be achieved even with the changes in 

vegetation composition and diversity. The reclamation plans for the LBA tract 

would also include steps to control invasion by weedy (invasive, nonnative) 

plant species. 

Direct impacts of surface coal mining on wildlife occur during mining and are 

short term. They include road kills by mine-related traffic, direct losses of less 

mobile wildlife species, restrictions on wildlife movement created by fences, 

spoil piles and pits, displacement of wildlife from existing habitat in areas of 

active mining (including abandonment of nests or nesting and breeding habitat 

for birds), increased competition between animals in areas adjacent to mining 

operations, and increased noise, dust, and human presence. Habitat for 

aquatic species would also be lost during mining operations. Indirect impacts 

are longer term and include alterations in topography and vegetative cover 

following reclamation which may decrease wildlife carrying capacity and 

habitat diversity. The West Antelope II LBA tract does not include any unique 

or crucial big game habitat, and habitat disturbance would be incremental, 

with reclamation progressing as new disturbance occurs. In the long term, 

following reclamation, carrying capacity and habitat diversity may be reduced 

due to flatter topography, less diverse vegetative cover, and reduction in 

sagebrush density. 

T&E plant and animal species that could be present on the tract include the 

Ute ladies’-tresses orchid and black-footed ferret. Areas of suitable habitat for 

the Ute ladies’-tresses orchid within the West Antelope II LBA tract and 

ES-14 Draft EIS, West Antelope II Coal Lease Application 
 

 Executive Summary 

adjacent study area were surveyed in August 2006 and in July and August 

2007, and no individuals were located. The black-footed ferret is a nocturnally 

active mammal that depends almost entirely upon the prairie dog for its 

survival. The West Antelope II EIS study area and its perimeter harbor some 

small prairie dog colonies, but black-footed ferrets have never been 

documented at the mine or in the surrounding region during surveys 

conducted over the last 20 plus years by a variety of private, state, and federal 

entities. The lack of black-footed ferret observations or scat in the EIS study 

area leads to the conclusion that ferrets are not present in the area. 

Active mining would preclude other land uses. Recreational and grazing use of 

the LBA tract would be severely limited during mining. Oil and gas 

development would be curtailed and CBNG that is not recovered prior to 

mining would be vented and irretrievably lost as the coal is removed. Access to 

approximately 240 acres of USDA-FS-administered federal surface included in 

the West Antelope II LBA tract under Alternatives 1 and 2 would be limited if 

that land is leased and mined. Approximately 100 of those acres are within the 

current Antelope Mine permit area and access to the public is currently limited 

on those lands as a result. Within 10 years after initiation of each reclamation 

phase, rangeland and wildlife use would return to near premining levels. The 

cumulative impacts of energy development (coal mining, oil and gas) in the PRB 

will continue to contribute to a reduction in hunting opportunities for some 

animals (pronghorn, mule deer, and sage-grouse). 

The West Antelope II general analysis area, with the exception of one 40-acre 

lot, has been surveyed for cultural resources at the Class I and Class III level. 

A total of 61 cultural sites were identified. Seven prehistoric sites are 

considered eligible for the NRHP by the cultural site recorder. Until 

consultation with SHPO has occurred and agreement regarding NRHP eligibility 

has been reached, all sites would be protected from disturbance. 

No sites of Native American religious or cultural importance have been 

identified on the LBA tract. If such sites or localities are identified at a later 

date, appropriate action must be taken to address concerns related to those 

sites. 

Mining activities on the West Antelope II LBA tract would be visible from 

Wyoming Highway 59 and several county roads. Mining would affect 

landscapes classified by BLM as VRM Class IV, and the landscape character 

would not be significantly changed following reclamation. No unique visual 

resources have been identified on or near the LBA tract. 

There are occupied dwellings and businesses in the vicinity of the West 

Antelope II LBA tract (Figure ES-4). The nearest occupied residence (the Don 

Jacobs residence) is approximately 2,800 feet west of the westernmost extent of 

the tract. If the tract is leased and mined, mining operations could be 

approximately 2,000 feet closer to this residence than the current lease would 

allow. Wildlife in the immediate vicinity of mining may be adversely affected; 

Draft EIS, West Antelope II Coal Lease Application ES-15 
 

 

Executive Summary 

however, anecdotal observations at surface coal mines in the area indicate that 

some wildlife may adapt to increased noise associated with coal mining activity. 

After mining and reclamation are completed, noise would return to premining 

levels. 

Leasing the West Antelope II LBA tract would extend the length of time that 

coal is shipped from the permitted Antelope Mine, which would extend the 

length of time that coal transportation facilities would be required under the 

Proposed Action or Alternatives 1 or 2. State Highway 59 crosses the 

southwestern corner of the south block of the tract under Alternatives 1 and 2. 

County Road 37 crosses the southeastern corner of the south block of the tract 

under Alternatives 1 and 2. Lands within 100 feet of the outside line of the 

ROW of a public road are considered unsuitable for mining; however, they 

could be included in the West Antelope II LBA tract to allow recovery of 

economically mineable coal outside of the ROW and buffer zone. Active 

pipelines and utility/power transmission lines would have to be relocated in 

accordance with previous agreements, or agreements would have to be 

negotiated for their removal or relocation. 

Royalty and bonus payments for the coal in the LBA tract would be collected by 

the federal government and split with the state. Assuming an average coal 

price of $9.01 per ton recovered and a potential range of bonus payments of 30 

to 97 cents per ton, the potential additional federal revenues would range from 

$581 to $766 million, depending on the alternative selected and the bonus 

price at the time the coal is leased. Potential revenue to the state would range 

from $780 to $977 million. Mine life, and thus employment, would be 

extended by up to 13 years at Antelope Mine. 

With regard to Environmental Justice issues, economic and demographic data 

indicate that neither minority populations nor people living at or below the 

poverty level make up “meaningfully greater increment” of the total population 

in Gillette, Wright, Campbell County, Douglas or Converse County than they do 

in the state as a whole. Also, the Native American population is smaller than 

in the state as a whole and there are no known Native American sacred sites on 

or near the study area for the West Antelope II LBA tract. 

Under the No Action Alternative, the coal lease application would be rejected 

and the area contained in the application would not be offered for lease at this 

time. The tract could be nominated for lease again in the future. Under the No 

Action Alternative, the impacts described in the preceding paragraphs to 

topography and physiology, geology and minerals, soils, air quality, water 

resources, AVFs, wetlands, vegetation, wildlife, T&E species, land use and 

recreation, cultural resources, Native American concerns, paleontological 

resources, visual resources, noise, transportation, and socioeconomics would 

occur on the existing Antelope Mine coal leases, but these impacts would not 

be extended onto the West Antelope II LBA tract. Portions of the LBA tract 

adjacent to the existing mine would be disturbed to recover the coal in the 

existing leases. 

ES-16 Draft EIS, West Antelope II Coal Lease Application 
 Executive Summary 

If impacts are identified during the leasing process that are not mitigated by 

existing required mitigation measures, BLM can include additional mitigation 

measures, in the form of stipulations on the new lease, within the limits of its 

regulatory authority. BLM has not identified additional special stipulations 

that should be added to the BLM lease or areas where additional or increased 

monitoring measures are recommended. 

Cumulative impacts result from the incremental impacts of an action added to 

other past, present, and reasonably foreseeable future actions, regardless of 

who is responsible for such actions. Cumulative impacts can result from 

individually minor, but collectively significant, actions occurring over time. 

Since decertification of the Powder River Federal Coal Region in 1990, 17 coal 

leases containing more than five billion tons of federal coal have been issued 

following competitive sealed-bid sales. Three exchanges of federal coal in the 

Wyoming portion of the Powder River Federal Coal Region have also been 

completed. Additional coal lease applications, including the West Antelope II 

application, are currently pending. The pending LBA applications contain 

approximately 4.9 billion tons of coal. 

Currently, BLM is completing a regional technical study, called the PRB Coal 

Review, to help evaluate the cumulative impacts of coal and other mineral 

development in the PRB. The study evaluates current conditions as of a 

baseline year (2003) and projects development levels and potential associated 

cumulative impacts related to coal and coal-related development, oil and gas 

and oil- and gas-related development, and other development through 2020. 

Due to variables associated with future coal production, two projected coal 

production scenarios (representing an upper and a lower production level) were 

developed. The projected development levels are based on projected demand 

and coal market forecasts and include production at the Antelope Mine during 

the baseline year and projected production for the mine for 2010, 2015, and 

2020. 

The Wyoming portion of the PRB is the primary focus of the PRB Coal Review, 

but the Montana portion of the PRB is included in some studies. A series of 

reports has been prepared (some reports in the series are in preparation) to 

present the results of the PRB Coal Review studies. The results of the PRB 

Coal Review studies that have been completed are summarized in Section 4.0 

of this EIS. 

Cumulative impacts vary by resource, with potential impacts to air quality, 

groundwater quantity, wildlife habitat, and socioeconomics generally being the 

greatest concerns. 

The PRB Coal Review air quality study documents the modeled air quality 

impact of existing operations during 2002 and of projected development 

activities in 2010. The model was used to evaluate impacts of existing and 

projected source emissions on several source groups, including near-field 

Draft EIS, West Antelope II Coal Lease Application ES-17 
Executive Summary 

receptors in Wyoming and Montana, receptors in nearby federally designated 

“Class I” areas, and receptors at “Class II” sensitive areas. The EPA guideline 

CALPUFF model system was used for the modeling analysis. 

The existing regional air quality conditions are generally very good, but the 

modeling showed some substantial impacts at some receptors for 2002 and 

2010. Table ES-3 presents the maximum modeled impacts on ambient air 

quality at the near-field receptors in Wyoming and Montana for 2002 and for 

the 2010 upper and lower coal development scenarios. Table ES-4 lists the 

projected modeled visibility impacts for 2002 for all analyzed Class I and 

sensitive Class II areas. For the upper and lower coal production scenarios, it 

shows the number of additional days that the projected impacts were greater 

than 1.0 dv (10 percent in extinction) for each site in 2010. 

The PRB Coal Review groundwater and surface water studies are in progress, 

but a number of modeling analyses have previously been conducted to help 

predict the impacts of surface coal mining on groundwater resources in the 

PRB. In addition, each mine must monitor groundwater levels in the coal and 

underlying and overlying aquifers and assess the probable hydrologic 

consequences of mining as part of the mine permitting process. The 

monitoring programs track the extent of groundwater drawdown propagation to 

the west and the extent of recharge and quality of the water in the backfill 

areas of the mines. The monitoring data indicate that recharge is occurring in 

the backfill and that water from the backfill will generally be acceptable for 

premining uses, which is primarily livestock watering. Modeling and 

monitoring indicate that the groundwater drawdown impacts of coal mining 

and CBNG development are overlapping. 

The PRB Coal Review studies include an evaluation of the impacts to wildlife 

and aquatic species as of 2003 and an evaluation of the projected levels of 

disturbance in the PRB in 2010, 2015, and 2020, based on the projected 

development levels in those years. Impacts to wildlife and fisheries can be 

classified as short-term and long-term. Short-term impacts are related to 

habitat disturbance during project development and operation. Long-term 

impacts result from changes in habitat after reclamation is completed. Habitat 

fragmentation can result from activities such as roads, well pads, mines, 

pipelines, and electrical power lines, as well as increased noise, elevated 

human presence, dispersal of noxious and invasive weed species, and dust 

from unpaved road traffic. 

ES-18 Draft EIS, West Antelope II Coal Lease Application 
Table ES-3. Projected Maximum Potential Near-field Impacts (μg/m3). 

2010 Lower 2010 Upper

Base Coal Coal 

Year Production Production 

Averaging (2002) Scenario Scenario Wyoming M

Pollutant Time Impacts Impacts Impacts NAAQS AAQS 

Wyoming Near-field 

NO2 Annual 37.3 42.4 49.0 100 100 

SO2 Annual 3.9 4.8 5.6 80 60 

 24-hour 14.5 33.5 34.8 365 260  3-hour 37.9 148.0 154.2 1,300 1300 

PM10 Annual 42.7 49.0 56.6 --2 50 

 24-hour 335.5 378.8 439.9 150 150 

Montana Near-field 

NO2 Annual 8.85 11.3 11.8 100 --1 

 1-hour 365.8 415.9 519.5 -- --1 

SO2 Annual 1.3 2.3 2.7 80 --1 

 24-hour 18.9 19.5 20.4 365 --1 

 3-hour 74.7 76.4 79.8 1,300 --1 

 1-hour 240.7 246.4 257.3 -- --1 

PM10 Annual 19.6 22.5 27.7 --2 --1 

 24-hour 175.8 200.0 247.7 150 --1 

1 No standard or increment. 2 On September 21, 2006, the EPA announced final revisions to the NAAQS for particulate matter, which were published 

October 17, 2006 and took effect December 18, 2006. The revision not only strengthened the 24-hour PM2.5 standard 

also revoked the annual PM10 standard of 50 μg/m3. Wyoming will enter into rulemaking to revise the Wyoming Ambie

Until that time, however, Wyoming will retain the 50 ug/m3 annual PM10 standard. See additional discussion in Chap

Bold values indicate projected exceedances of AAQS. Source: PRB Coal Review Task 3A Report (BLM 2006a) 

Draft EIS, West Antelope II Coal Lease Application 
 

 

 

 

 

 

 

 

 

Executive Summary 

Table ES-4. Modeled Change in Visibility Impacts at Class I and Sensitive 

Class II Areas. 

2010 Lower Coal 2010 Upper 

Production Coal Production 

2002 Scenario Scenario 

No. of Change in Change in 

Days No. of Days No. of Days 

Location >10% > 10% > 10% 

Federally and Tribally Designated Class I Areas 

Badlands National Park 1 238 19 26 

Bob Marshall WA 12 2 4 

Bridger WA 47 4 7 

Fitzpatrick WA 42 3 5 

Fort Peck Indian Reservation 69 8 9 

Gates of the Mountain WA 14 6 7 

Grand Teton National Park 26 2 5 

North Absaorka WA 47 6 6 

North Cheyenne Indian Reservation 305 5 10 

Red Rock Lakes 16 3 5 

Scapegoat WA 14 4 4 

Teton WA 40 4 5 

Theodore Roosevelt National Park 98 15 22 

UL Bend WA 49 4 5 

Washakie WA 53 2 3 

Wind Cave National Park 261 11 15 

Yellowstone National Park 42 7 8 

Sensitive Class II Areas 

Absaorka Beartooth WA 53 3 5 

Agate Fossil Beds National Monument 199 26 30 

Big Horn Canyon National Rec. Area 108 7 8 

Black Elk WA 263 16 22 

Cloud Peak WA 137 8 8 

Crow Indian Reservation 284 10 15 

Devils Tower National Monument 279 15 21 

Fort Belknap Indian Reservation 46 3 4 

Fort Laramie National Historic Site 153 27 30 

Jedediah Smith WA 23 1 2 

Jewel Cave National Monument 267 14 18 

Lee Metcalf WA 25 2 4 

Mount Naomi WA 8 6 8 

Mount Rushmore National Monument 248 19 25 

Popo Agie WA 47 7 8 

Soldier Creek WA 223 23 29 

Wellsville Mountain WA 6 5 7 

Wind River Indian Reservation 66 12 15 1 The U.S. Congress designated the Wilderness Area portion of Badlands National Park as a mandatory Federal PSD 

Class I area. The remainder of Badlands National Park is a PSD Class II area. 

Source: PRB Coal Review Task 3A Report (BLM 2006a) 

ES-20 Draft EIS, West Antelope II Coal Lease Application 
 Executive Summary 

The PRB Coal Review used the REMI Policy Insight regional economic model to 

project cumulative employment and population levels and associated impacts 

in the PRB for the upper and lower coal production scenarios in 2010, 2015, 

and 2020. Table ES-5 presents the recent and projected population levels for 

the counties included in the PRB Coal Review socioeconomic analysis. 

Table ES-5. Recent and Projected PRB Population. 

Six 

YEAR 

Campbell 

County 

Converse 

County 

Crook 

County 

Johnson 

County 

Sheridan 

County 

Weston 

County 

County 

PRB 

Total 

Census 

2000 33,698 12,104 5,895 7,108 26,606 6,642 92,053 

2003 36,381 12,326 5,971 7,530 27,116 6,665 95,989 

2006 38,934 12,866 6,255 8,014 27,673 6,762 100,504 

Lower Coal Production Scenario 

2010 45,925 13,103 6,542 8,389 28,459 7,108 109,526 

2015 48,905 13,671 6,759 8,867 30,016 7,174 115,392 

2020 50,995 14,193 6,989 9,326 31,467 7,208 120,178 

Upper Coal Production Scenario 

2010 47,662 13,160 6,570 8,424 28,579 7,137 111,532 

2015 51,558 13,763 6,802 8,924 30,214 7,219 118,480 

2020 54,943 14,313 7,045 9,403 31,733 7,266 124,703 

Source: U.S. Census Bureau (2006b - historical data) and PRB Coal Review Task 3C Report (BLM 

2005e) 

This DEIS presents the BLM’s analysis of environmental impacts under 

authority of the NEPA and associated rules and guidelines. The BLM will use 

this analysis to make a leasing decision. The decision to lease these lands is a 

necessary requisite for mining, but is not in itself the enabling action that will 

allow mining. The most detailed analysis prior to mine development would 

occur after the lease is issued, when the lessee files an application for a surface 

mining permit and mining plan approval, supported by extensive proposed 

mining and reclamation plans, to the WDEQ/LQD. 

Draft EIS, West Antelope II Coal Lease Application ES-21 
Table of Contents 

TABLE OF CONTENTS 

EXECUTIVE SUMARY ................................................................................ES-1 

1.0 INTRODUCTION ................................................................................. 1-1 

1.1 Background .............................................................................. 1-1 

1.2 Purpose and Need for Action...................................................... 1-8 

1.3 Regulatory Authority and Responsibility.................................. 1-10 

1.4 Relationship to BLM Policies, Plans, and Programs.................. 1-11 

1.5 Conformance with Existing Land Use Plans............................. 1-12 

1.6 Consultation and Coordination................................................ 1-16 

2.0 PROPOSED ACTION AND ALTERNATIVES.......................................... 2-1 

2.1 Proposed Action ........................................................................ 2-4 

2.1.1 Regulatory Compliance, Mitigation and Monitoring....... 2-8 

2.1.2 Hazardous and Solid Waste........................................ 2-14 

2.2 Alternative 1............................................................................ 2-15 

2.3 Alternative 2............................................................................ 2-18 

2.4 Alternative 3............................................................................ 2-21 

2.5 Alternative 4............................................................................ 2-21 

2.6 Alternative 5............................................................................ 2-23 

2.7 Summary of Alternatives and Environmental Consequences.... 2-25 

2.7.1 Background ............................................................... 2-25 

2.7.2 Summary of Alternatives ............................................ 2-25 

3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL 

CONSEQUENCES............................................................................... 3-1 

3.1 General Setting ......................................................................... 3-5 

3.1.1 Climate and Meteorology .............................................. 3-5 

3.2 Topography and Physiography................................................... 3-5 

3.2.1 Affected Environment................................................... 3-5 

3.2.2 Environmental Consequences ...................................... 3-7 

3.2.2.1 Proposed Action and Alternatives 1 and 2...... 3-7 

3.2.2.2 No Action Alternative..................................... 3-8 

3.2.3 Regulatory Compliance, Mitigation and Monitoring....... 3-9 

3.2.4 Residual Impacts ......................................................... 3-9 

3.3 Geology, Mineral Resources, and Paleontology........................... 3-9 

3.3.1 General Geology and Coal Resources............................ 3-9 

3.3.1.1 Affected Environment.................................... 3-9 

3.3.1.2 Environmental Consequences ..................... 3-13 

3.3.1.2.1 Proposed Action and 

Alternatives 1 and 2................. 3-13 

3.3.1.2.2 No Action Alternative ............... 3-13 

3.3.1.3 Regulatory Compliance, Mitigation and 

Monitoring .................................................. 3-13 

3.3.1.4 Residual Impacts......................................... 3-14 

3.3.2 Other Mineral Resources............................................ 3-14 

3.3.2.1 Affected Environment.................................. 3-14 

Draft EIS, West Antelope II Coal Lease Application i 
Table of Contents 

TABLE OF CONTENTS (Continued) 

3.3.2.1.1 Conventional Oil and Gas ........ 3-14 

3.3.2.1.2 Coal Bed Natural Gas (CBNG) .. 3-15 

3.3.2.1.3 Other Minerals......................... 3-16 

3.3.2.2 Environmental Consequences ..................... 3-17 

3.3.2.2.1 Proposed Action and 

Alternatives 1 and 2................. 3-17 

3.3.2.2.2 No Action Alternative ............... 3-18 

3.3.2.3 Regulatory Compliance, Mitigation and 

Monitoring .................................................. 3-18 

3.3.2.4 Residual Impacts......................................... 3-19 

3.3.3 Paleontology............................................................... 3-19 

3.3.3.1 Affected Environment.................................. 3-19 

3.3.3.2	 Environmental Consequences ..................... 3-21 

3.3.3.2.1 Proposed Action and 

Alternatives 1 and 2................. 3-21 

3.3.3.2.2 No Action Alternative ............... 3-21 

3.3.3.3 Regulatory Compliance, Mitigation and 

Monitoring .................................................. 3-22 

3.3.3.4 Residual Impacts......................................... 3-22 

3.4 Air Quality .............................................................................. 3-22 

3.4.1 Background ............................................................... 3-22 

3.4.1.1 Emissions Sources ...................................... 3-23 

3.4.2 Particulate Emissions................................................. 3-25 

3.4.2.1 Affected Environment for Particulate 

Emissions ................................................... 3-25 

3.4.2.2 Environmental Consequences Related to 

Particulate Emissions.................................. 3-28 

3.4.2.2.1 Proposed Action and 

Alternatives 1 and 2................. 3-29 

3.4.2.2.2 No Action Alternative ............... 3-32 

3.4.2.3 Regulatory Compliance, Mitigation, and 

Monitoring for Particulate Emissions ........... 3-34 

3.4.3 Emissions of Nitrogen Oxides ..................................... 3-37 

3.4.3.1 Affected Environment for NOx Emissions ..... 3-37 

3.4.3.1.1 Site Specific NOx Emissions ..... 3-38 

3.4.3.2 Environmental Consequences Related to 

Short-Term NOx Emissions ......................... 3-38 

3.4.3.2.1 Proposed Action and 

Alternatives 1 and 2................. 3-40 

3.4.3.2.2 No Action Alternative ............... 3-41 

3.4.3.3 Regulatory Compliance, Mitigation, and 

Monitoring for NOx Emissions...................... 3-42 

3.4.4 Visibility..................................................................... 3-45 

3.4.4.1 Affected Environment for Visibility............... 3-45 

3.4.4.2 Environmental Consequences for Visibility .. 3-47 

ii Draft EIS, West Antelope II Coal Lease Application 
Table of Contents 

TABLE OF CONTENTS (Continued) 

3.4.4.2.1 Proposed Action and 

Alternatives 1 and 2................. 3-47 

3.4.4.2.2 No Action Alternative ............... 3-49 

3.4.4.3	 Regulatory Compliance, Mitigation, and 

Monitoring for Visibility Impacts.................. 3-49 

3.4.5 Acidification of Lakes ................................................. 3-50 

3.4.5.1 Affected Environment.................................. 3-50 

3.4.5.2 Environmental Consequences ..................... 3-51 

3.4.5.2.1 Proposed Action and 

Alternatives 1 and 2................. 3-51 

3.4.5.2.2 No Action Alternative ............... 3-51 

3.4.5.3 Regulatory Compliance, Mitigation, and 

Monitoring .................................................. 3-51 

3.4.6 Residual Impacts to Air Quality.................................. 3-52 

3.5 Water Resources ..................................................................... 3-52 

3.5.1 Groundwater.............................................................. 3-52 

3.5.1.1 Affected Environment.................................. 3-52 

3.5.1.1.1 Recent Alluvium....................... 3-52 

3.5.1.1.2 Wasatch Formation.................. 3-54 

3.5.1.1.3 Anderson Coal ......................... 3-55 

3.5.1.1.4 Canyon Coal ............................ 3-57 

3.5.1.1.5 Subcoal Fort Union Formation.. 3-58 

3.5.1.2 Environmental Consequences ..................... 3-58 

3.5.1.2.1 Proposed Action and 

Alternatives 2 and 3................. 3-58 

3.5.1.2.2 No Action Alternative ............... 3-63 

3.5.1.3 Regulatory Compliance, Mitigation and 

Monitoring .................................................. 3-63 

3.5.2 Surface Water ............................................................ 3-64 

3.5.2.1 Affected Environment.................................. 3-64 

3.5.2.2 Environmental Consequences ..................... 3-66 

3.5.2.2.1 Proposed Action and 

Alternatives 1 and 2................. 3-66 

3.5.2.2.2 No Action Alternative ............... 3-67 

3.5.2.3 Regulatory Compliance, Mitigation and 

Monitoring .................................................. 3-68 

3.5.3 Water Rights .............................................................. 3-68 

3.5.3.1 Affected Environment.................................. 3-68 

3.5.3.2 Environmental Consequences ..................... 3-69 

3.5.3.2.1 Proposed Action and 

Alternatives 1 and 2................. 3-69 

3.5.3.2.2 No Action Alternative ............... 3-69 

3.5.3.3 Regulatory Compliance, Mitigation and 

Monitoring .................................................. 3-70 

3.5.4 Residual Impacts ....................................................... 3-71 

3.6 Alluvial Valley Floors ............................................................... 3-71 

Draft EIS, West Antelope II Coal Lease Application iii 
Table of Contents 

TABLE OF CONTENTS (Continued) 

3.6.1 Affected Environment................................................. 3-71 

3.6.2 Environmental Consequences .................................... 3-72 

3.6.2.1 Proposed Action and Alternatives 1 and 2.... 3-72 

3.6.2.2 No Action Alternative................................... 3-74 

3.6.3 Regulatory Compliance, Mitigation and Monitoring..... 3-75 

3.6.4 Residual Impacts ....................................................... 3-75 

3.7 Wetlands................................................................................. 3-75 

3.7.1 Affected Environment................................................. 3-75 

3.7.2 Environmental Consequences .................................... 3-78 

3.7.2.1 Proposed Action and Alternatives 1 and 2.... 3-78 

3.7.2.2 No Action Alternative................................... 3-78 

3.7.3 Regulatory Compliance, Mitigation and Monitoring..... 3-79 

3.7.4 Residual Impacts ....................................................... 3-79 

3.8 Soils........................................................................................ 3-79 

3.8.1 Affected Environment................................................. 3-79 

3.8.2 Environmental Consequences .................................... 3-82 

3.8.2.1 Proposed Action and Alternatives 1 and 2.... 3-82 

3.8.2.2 No Action Alternative................................... 3-83 

3.8.3 Regulatory Compliance, Mitigation and Monitoring..... 3-83 

3.8.4 Residual Impacts ....................................................... 3-83 

3.9 Vegetation............................................................................... 3-84 

3.9.1 Affected Environment................................................. 3-84 

3.9.2 Environmental Consequences .................................... 3-87 

3.9.2.1 Proposed Action and Alternatives 1 and 2.... 3-87 

3.9.2.2 No Action Alternative................................... 3-89 

3.9.3 Threatened, Endangered, Proposed, and Candidate 

Plant Species, and BLM Sensitive Species................... 3-89 

3.9.4 Regulatory Compliance, Mitigation and Monitoring..... 3-89 

3.9.5 Residual Impacts ....................................................... 3-90 

3.10 Wildlife.................................................................................... 3-91 

3.10.1 General Setting .......................................................... 3-91 

3.10.1.1 Affected Environment.................................. 3-91 

3.10.1.2 Environmental Consequences ..................... 3-93 

3.10.1.2.1 Proposed Action and 

Alternatives 1 and 2................. 3-93 

3.10.1.2.2 No Action Alternative ............... 3-94 

3.10.2 Big Game ................................................................... 3-95 

3.10.2.1 Affected Environment.................................. 3-95 

3.10.2.2 Environmental Consequences ..................... 3-96 

3.10.2.2.1 Proposed Action and 

Alternatives 1 and 2................. 3-96 

3.10.2.2.2 No Action Alternative ............... 3-97 

3.10.3 Other Mammals ......................................................... 3-97 

3.10.3.1 Affected Environment.................................. 3-97 

3.10.3.2 Environmental Consequences ................... 3-101 

iv Draft EIS, West Antelope II Coal Lease Application 
Table of Contents 

TABLE OF CONTENTS (Continued) 

3.10.3.2.1 Proposed Action and 

Alternatives 1 and 2............... 3-101 

3.10.3.2.2 No Action Alternatives............ 3-101 

3.10.4 Raptors .................................................................... 3-101 

3.10.4.1 Affected Environment................................ 3-101 

3.10.4.2 Environmental Consequences ................... 3-103 

3.10.4.2.1 Proposed Action and 

Alternatives 1 and 2............... 3-103 

3.10.4.2.2 No Action Alternative ............. 3-104 

3.10.5 Upland Game Birds.................................................. 3-104 

3.10.5.1 Affected Environment................................ 3-104 

3.10.5.2 Environmental Consequences ................... 3-107 

3.10.5.2.1 Proposed Action and 

Alternatives 1 and 2............... 3-107 

3.10.5.2.2 No Action Alternative ............. 3-110 

3.10.6 Other Birds .............................................................. 3-110 

3.10.6.1 Affected Environment................................ 3-110 

3.10.6.2 Environmental Consequences ................... 3-114 

3.10.6.2.1 Proposed Action and 

Alternatives 1 and 2............... 3-114 

3.10.6.2.2 No Action Alternative ............. 3-116 

3.10.7 Amphibians, Reptiles, and Aquatic Species............... 3-116 

3.10.7.1 Affected Environment................................ 3-116 

3.10.7.2 Environmental Consequences ................... 3-117 

3.10.7.2.1 Proposed Action and 

Alternatives 1 and 2............... 3-117 

3.10.7.2.2 No Action Alternative ............. 3-117 

3.10.8 Threatened, Endangered, Proposed, and Candidate 

Animal Species, and BLM Sensitive Species.............. 3-118 

3.10.9 Regulatory Compliance, Mitigation and Monitoring... 3-118 

3.10.10 Residual Impacts ..................................................... 3-120 

3.11 Land Use and Recreation....................................................... 3-121 

3.11.1 Affected Environment............................................... 3-121 

3.11.2 Environmental Consequences .................................. 3-129 

3.11.2.1 Proposed Action and Alternatives 1 

 and 2 ........................................................ 3-129 

3.11.2.2 No Action Alternative................................. 3-130 

3.11.3 Regulatory Compliance, Mitigation and Monitoring... 3-130 

3.11.4 Residual Impacts ..................................................... 3-131 

3.12 Cultural Resources................................................................ 3-131 

3.12.1 Affected Environment............................................... 3-131 

3.12.2 Environmental Consequences .................................. 3-138 

3.12.2.1 Proposed Action and Alternatives 1 

 and 2 ....................................................... 3-138 

3.12.2.2 No Action Alternative................................. 3-138 

3.12.3 Native American Consultation .................................. 3-139 

Draft EIS, West Antelope II Coal Lease Application v 
Table of Contents 

TABLE OF CONTENTS (Continued) 

3.12.4 Regulatory Compliance, Mitigation and Monitoring... 3-140 

3.12.5 Residual Impacts ..................................................... 3-140 

3.13 Visual Resources................................................................... 3-140 

3.13.1 Affected Environment............................................... 3-140 

3.13.2 Environmental Consequences .................................. 3-142 

3.13.2.1 Proposed Action and Alternatives 1 and 2.. 3-142 

3.13.2.2 No Action Alternative................................. 3-142 

3.13.3 Regulatory Compliance, Mitigation and Monitoring... 3-143 

3.14.4 Residual Impacts ..................................................... 3-143 

3.14 Noise..................................................................................... 3-143 

3.14.1 Affected Environment............................................... 3-143 

3.14.2 Environmental Consequences .................................. 3-145 

3.14.2.1 Proposed Action and Alternatives 1 and 2.. 3-145 

3.14.2.2 No Action Alternative................................. 3-145 

3.14.3 Regulatory Compliance, Mitigation and Monitoring... 3-145 

3.14.4 Residual Impacts ..................................................... 3-145 

3.15 Transportation ...................................................................... 3-146 

3.15.1 Affected Environment............................................... 3-146 

3.15.2 Environmental Consequences .................................. 3-149 

3.15.2.1 Proposed Action and Alternatives 1 and 2.. 3-149 

3.15.2.2 No Action Alternative................................. 3-149 

3.15.3 Regulatory Compliance, Mitigation and Monitoring... 3-150 

3.15.4 Residual Impacts ..................................................... 3-150 

3.16 Hazardous and Solid Waste................................................... 3-150 

3.16.1 Affected Environment............................................... 3-150 

3.16.2 Environmental Consequences .................................. 3-150 

3.16.2.1 Proposed Action and Alternatives 1 and 2.. 3-150 

3.16.2.2 No Action Alternative................................. 3-150 

3.16.3 Regulatory Compliance, Mitigation and Monitoring... 3-151 

3.16.4 Residual Impacts ..................................................... 3-151 

3.17 Socioeconomics ..................................................................... 3-151 

3.17.1 Local Economy......................................................... 3-152 

3.17.1.1 Affected Environment................................ 3-152 

3.17.1.2 Environmental Consequences ................... 3-155 

3.17.1.2.1 Proposed Action and 

Alternatives 1 and 2............... 3-155 

3.17.1.2.2 No Action Alternative ............. 3-156 

3.17.2 Population ............................................................... 3-157 

3.17.2.1 Affected Environment................................ 3-157 

3.17.2.2 Environmental Consequences ................... 3-158 

3.17.2.2.1 Proposed Action and 

Alternatives 1 and 2............... 3-158 

3.17.2.2.2 No Action Alternative ............. 3-158 

3.17.3 Employment............................................................. 3-158 

3.17.3.1 Affected Environment................................ 3-158 

3.17.3.2 Environmental Consequences ................... 3-159 

vi Draft EIS, West Antelope II Coal Lease Application 
Table of Contents 

TABLE OF CONTENTS (Continued) 

3.17.3.2.1 Proposed Action and 

Alternatives 1 and 2............... 3-159 

3.17.3.2.2 No Action Alternative ............. 3-159 

3.17.4 Housing ................................................................... 3-159 

3.17.4.1 Affected Environment............. 3-159 

3.17.4.2 Environmental Consequences ................... 3-161 

3.17.4.2.1 Proposed Action and 

Alternatives 1 and 2............... 3-161 

3.17.4.2.2 No Action Alternative ............. 3-161 

3.17.5 Local Government Facilities and Services ................. 3-161 

3.17.5.1 Affected Environment................................ 3-161 

3.17.5.2 Environmental Consequences ................... 3-163 

3.17.5.2.1 Proposed Action and 

Alternatives 1 and 2............... 3-163 

3.17.5.2.2 No Action Alternative ............. 3-164 

3.17.6 Social Setting ........................................................... 3-164 

3.17.6.1 Affected Environment................................ 3-164 

3.17.6.2 Environmental Consequences ................... 3-164 

3.17.6.2.1 Proposed Action and 

Alternatives 1 and 2............... 3-164 

3.17.6.2.2 No Action Alternative ............. 3-165 

3.17.7 Environmental Justice ............................................. 3-165 

3.17.7.1 Affected Environment................................ 3-165 

3.17.7.2 Environmental Consequences ................... 3-166 

3.17.7.2.1 Proposed Action and 

Alternatives 1 and 2............... 3-166 

3.17.7.2.2 No Action Alternative ............. 3-166 

3.17.8 Regulatory Compliance, Mitigation and Monitoring... 3-166 

3.17.9 Residual Effects ....................................................... 3-166 

3.18 Coal Mining and Coal-Fired Power Plant Related Emissions and 

By-Products .......................................................................... 3-166 

3.18.1 Global Warming and Coal Mining and Coal-Fired Power 

Plant Related Greenhouse Gas Emissions ................ 3-167 

3.18.2 Other Coal Mining and Coal-Fired Power Plant Related 

By-Products ............................................................. 3-171 

3.19 The Relationship Between Local Short-term Uses of Man’s 

Environment and the Maintenance and Enhancement of 

 Long-term Productivity .......................................................... 3-172 

3.20 Irreversible and Irretrievable Commitments of Resources....... 3-174 

4.0 CUMULATIVE ENVIRONMENTAL CONSEQUENCES ........................... 4-1 

4.1 Past, Present, and Reasonably Foreseeable Development........... 4-2 

4.1.1 Coal Development ........................................................ 4-4 

4.1.1.1 Coal Mine Development................................. 4-4 

4.1.1.2 Coal-Related Development........................... 4-12 

Draft EIS, West Antelope II Coal Lease Application vii 
Table of Contents 

TABLE OF CONTENTS (Continued) 

4.1.1.2.1 Coal Transportation ................. 4-12 

4.1.1.2.2 Electric Power Generation ........ 4-13 

4.1.1.2.3 Transmission Lines.................. 4-15 

4.1.1.2.4 Coal Conversion Technology..... 4-15 

4.1.2 Oil and Gas Development........................................... 4-17 

4.1.2.1 Conventional Oil and Gas............................ 4-17 

4.1.2.2 CBNG Development..................................... 4-18 

4.1.2.3 Oil and Gas Related Development................ 4-19 

4.1.2.3.1 Pipelines .................................. 4-20 

4.1.2.3.2 Refineries................................. 4-22 

4.1.3 Other Development Activity ........................................ 4-22 

4.1.3.1 Other Mining............................................... 4-22 

4.1.3.2 Industrial Manufacturing ............................ 4-23 

4.1.3.3 Reservoirs ................................................... 4-23 

4.1.3.4 Other Non-Energy Development .................. 4-24 

4.2 Cumulative Environmental Consequences............................... 4-25 

4.2.1 Topography and Physiography.................................... 4-27 

4.2.2 Geology, Mineral Resources, and Paleontology............ 4-29 

4.2.2.1 Coal ............................................................ 4-29 

4.2.2.2 Oil and Gas................................................. 4-29 

4.2.2.3 Other Mineral Resources ............................. 4-29 

4.2.2.4 Paleontology................................................ 4-30 

4.2.3 Air Quality ................................................................. 4-31 

4.2.4 Water Resources ........................................................ 4-41 

4.2.4.1 Groundwater............................................... 4-41 

4.2.4.2 Surface Water ............................................. 4-50 

4.2.5 Alluvial Valley Floors.................................................. 4-56 

4.2.6 Soils........................................................................... 4-56 

4.2.7 Vegetation, Wetlands and Riparian Areas ................... 4-58 

4.2.7.1 Vegetation................................................... 4-58 

4.2.7.2 Special Status Plant Species........................ 4-58 

4.2.7.3 Noxious and Invasive Weed Species ............. 4-59 

4.2.7.4 Wetland and Riparian Species ..................... 4-62 

4.2.8 Wildlife and Fisheries ................................................. 4-62 

4.2.8.1 Game Species.............................................. 4-63 

4.2.8.2 Non-game Species ....................................... 4-65 

4.2.8.3 Fisheries ..................................................... 4-67 

4.2.8.4 Special Status Species................................. 4-69 

4.2.9 Land Use and Recreation ........................................... 4-72 

4.2.9.1 Grazing and Agriculture .............................. 4-73 

4.2.9.2 Urban Use................................................... 4-75 

4.2.9.3 Recreation................................................... 4-75 

4.2.10 Cultural Resources and Native American Concerns .... 4-77 

4.2.10.1 Prehistoric Sites .......................................... 4-77 

4.2.10.2 Historic Sites............................................... 4-79 

viii Draft EIS, West Antelope II Coal Lease Application 
 

 

 

 

 

 

 

 

 

Table of Contents 

TABLE OF CONTENTS (Continued) 

4.2.10.3 Native American Traditional Cultural 

Places ......................................................... 4-79 

4.2.10.4 Site Protection............................................. 4-79 

4.2.11 Transportation and Utilities ....................................... 4-79 

4.2.12 Socioeconomics.......................................................... 4-82 

4.2.12.1 Employment and the Economic Base........... 4-83 

4.2.12.2 Labor Market Conditions............................. 4-85 

4.2.12.3 Personal Income.......................................... 4-86 

4.2.12.4 Population and Demographics..................... 4-86 

4.2.12.5 Housing ...................................................... 4-89 

4.2.12.6 Public Education......................................... 4-92 

4.2.12.7 Facilities and Services ................................. 4-93 

4.2.12.8 Fiscal Conditions ........................................ 4-95 

4.2.12.9 Social Setting .............................................. 4-97 

5.0 CONSULTATION AND COORDINATION............................................... 5-1 

6.0 REFERENCES CITED ......................................................................... 6-1 

7.0 GLOSSARY ......................................................................................... 7-1 

8.0 INDEX ................................................................................................ 8-1 

LIST OF TABLES 

Table ES-1. Summary Comparison of Coal Production, Surface 

Disturbance, Mine Life, and Revenues for West Antelope II LBA 

Tract and Antelope Mine - Assuming Average Annual Post-2006 

Coal Production is 36 mmt ......................................................ES-6 

Table ES-2. Summary Comparison of Coal Production, Surface 

Disturbance, Mine Life, and Revenues for West Antelope II LBA 

Tract and Antelope Mine - Assuming Average Annual Post-2006 

Table ES-4. Modeled Change in Visibility Impacts at Class I and 

Table 1-1. Leases Issued and Exchanges Completed Since Decertification, 

Table 2-1. Regulatory Compliance, Mitigation and Monitoring Measures 

for Surface Coal Mining Operations Required by SMCRA and 

Coal Production is 42 mmt ......................................................ES-7 

Table ES-3. Projected Maximum Potential Near-field Impacts ...................ES-19 

Sensitive Class II Areas .........................................................ES-20 

Table ES-5. Recent and Projected PRB Population....................................ES-21 

Powder River Basin, Wyoming ................................................... 1-4 

Table 1-2. Pending LBAs and Exchanges, Powder River Basin, Wyoming.... 1-6 

State Law for all Alternatives ..................................................... 2-9 

Draft EIS, West Antelope II Coal Lease Application ix 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table of Contents 

TABLE OF CONTENTS (Continued) 

Table 2-2. Summary Comparison of Coal Production, Surface 

Disturbance, Mine Life, and Revenues for West Antelope II LBA 

Tract and Antelope Mine - Assuming Average Annual Post-2006 

Coal Production is 36 mmt ...................................................... 2-26 

Table 2-3.	 Summary Comparison of Coal Production, Surface 

Disturbance, Mine Life, and Revenues for West Antelope II LBA 

Tract and Antelope Mine - Assuming Average Annual Post-2006 

Coal Production is 42 mmt ...................................................... 2-27 

Table 2-4.	 Summary Comparison of Magnitude and Duration of Direct 

and Indirect Impacts for the Proposed Action, Alternatives 1 

and 2, and the No Action Alternative for the West Antelope II LBA 

 Tract ....................................................................................... 2-28 

Table 2-5. Summary Comparison of Magnitude and Duration of 

 Cumulative Impacts ................................................................ 2-34 

Table 3-1. Comparison of Existing and Proposed Antelope Mine Disturbance 

Area and Mining Operations ...................................................... 3-4 

Table 3-2.	 Comparison of Average Overburden and Coal Thicknesses 

and Approximate Postmining Surface Elevation Changes 

Under the No Action Alternative and Alternatives 1 and 2.......... 3-8 

Table 3-3.	 Assumed Background Air Pollutant Concentrations, Applicable 

AAQS, and PSD Increment Values ........................................... 3-24 

Table 3-4. Summary of PM10 Monitoring Data for the Antelope Mine ........ 3-27 

Table 3-5. Summary of PM10 Monitoring Data for the Wright Area 

Subregion................................................................................ 3-28 

Table 3-6. Annual Ambient NO2 Concentration Data................................ 3-44 

Table 3-7. 2003 through 2006 Annual Ambient NO2 Concentration 

Data........................................................................................ 3-44 

Table 3-8.	 Approximate Distances and Directions from the West Antelope II 

General Analysis Area to Mandatory Federal Class I, Tribal 

Class I, and Federal Class II PSD Areas ................................... 3-46 

Table 3-9. Existing Acid Neutralizing Capacity in Sensitive Lakes............. 3-51 

Table 3-10. Water Supply Wells Possibly Subject to Drawdown if the 

Table 3-11. Vegetation Types Identified and Mapped Within the West Antelope 

West Antelope II LBA Tract is Mined........................................ 3-70 

II LBA Tract Vegetation Analysis Area...................................... 3-84 

Table 3-12. Distribution of Surface Ownership Within the West Antelope II LBA 

Tract as Applied for Under the Proposed Action and Additional 

Lands Added Under Alternatives 1 and 2............................... 3-121 

Table 3-13. Current Federal Oil and Gas Leases on the West Antelope II 

 LBA Tract.............................................................................. 3-125 

Table 3-14. Cultural Sites in the West Antelope II General Analysis Area . 3-136 

Table 3-15. Contribution of Coal Mining to the 2005 Assessed Valuation of 

Converse and Campbell Counties .......................................... 3-155 

Table 3-15. Projected Major Revenue Impacts from Leasing the West 

Antelope II LBA Tract Under the Proposed Action or Alternatives 

1 and 2 ................................................................................. 3-156 

x Draft EIS, West Antelope II Coal Lease Application 
 

 

Table of Contents 

TABLE OF CONTENTS (Continued) 

Table 3-17. Population Change, 2000 to 2006.......................................... 3-157 

Table 3-18. Demographic Characteristics, 2000....................................... 3-157 

Table 3-19. Total Housing Stock in 2000 and 2005.................................. 3-160 

Table 4-1. Status and Ownership of Wyoming PRB Coal Mines for 2003, the 

PRB Coal Review Baseline Year ................................................. 4-6 

Table 4-2. Baseline Year and projected Wyoming PRB Coal Mine 

Table 4-3. Baseline Year and Projected Wyoming PRB Coal Mine 

Table 4-4. Baseline Year and Projected Wyoming PRB Coal-Related 

Table 4-5. Past, Present, and Projected Wyoming PRB Coal Mine and 

Table 4-6. Baseline Year and Projected Wyoming PRB Conventional Oil and 

Table 4-7. Baseline Year and Projected CBNG Development Scenario for the 

Table 4-8. Wyoming PRB Conventional Oil and Gas, CBNG, and Related 

Table 4-9. Baseline Year and Projected Wyoming PRB Total Development 

Development, Lower Coal Production Scenario ........................ 4-10 

Development, Upper Coal Production Scenario ........................ 4-11 

 Development Scenario............................................................. 4-12 

 Coal-Related Development Scenario......................................... 4-17 

 Gas Development Scenario ...................................................... 4-18 

Wyoming PRB ......................................................................... 4-20 

Development Disturbance and Water Production..................... 4-20 

Scenario – Task 3 Study Area .................................................. 4-26 

Table 4-10. Projected Maximum Potential Near-field Impacts ..................... 4-34 

Table 4-11. Maximum Predicted PSD Class I and Sensitive Class II Area 

Impacts................................................................................... 4-36 

Table 4-12. Modeled Change in Visibility Impacts at Class I and Sensitive 

Table 4-13. Predicted Total Cumulative Change in Acid Neutralizing 

Table 4-14. Recoverable Groundwater in the Fort Union/Wasatch Aquifer 

 Class II Areas .......................................................................... 4-38 

Capacity of Sensitive Lakes ..................................................... 4-39 

System.................................................................................... 4-42 

Table 4-15. Water Use as of 2002 in the Powder/Tongue River Basin......... 4-51 

Table 4-16. Surface Water Availability in the Powder/Tongue River Basin.. 4-51 

Table 4-17. Water Use as of 2002 in the Northeast Wyoming River Basins . 4-52 

Table 4-18. Surface Water Availability in the Northeast Wyoming River 

Basins..................................................................................... 4-52 

Table 4-19. Summary of Proposed Limits for SAR and EC.......................... 4-54 

Table 4-20. Potential Cumulative Disturbance to Pronghorn Ranges from 

Development Activities—Lower and Upper Coal Production 

Scenarios ................................................................................ 4-64 

Table 4-21. Potential Cumulative Disturbance to White-tailed Deer Ranges 

from Development Activities—Lower and Upper Coal Production 

Scenarios ................................................................................ 4-64 

Table 4-22. Potential Cumulative Disturbance to Mule Deer Ranges from 

Development Activities—Lower and Upper Coal Production 

Scenarios ................................................................................ 4-65 

Draft EIS, West Antelope II Coal Lease Application xi 
 

 

 

 

 

 

 

 

 

 

Table of Contents 

TABLE OF CONTENTS (Continued) 

Table 4-23. Potential Cumulative Disturbance to Elk Ranges from 

Development Activities—Lower and Upper Coal Production 

Scenarios ................................................................................ 4-65 

Table 4-24. Potential Cumulative Impacts to Greater Sage-Grouse Leks 

from Coal Mine Development—Upper and Lower Coal 

 Production Scenarios .............................................................. 4-72 

Table 4-25. Land Use by Surface Ownership.............................................. 4-73 

Table 4-26. AUMs and Acres of Cropland Estimated Unavailable on 

Lands Disturbed and Not Yet Reclaimed as a Result of 

 Development Activities ............................................................ 4-74 

Table 4-27. Square Miles of Projected Cumulative Disturbance and 

Number of Potentially Affected Cultural Resource Sites in 

the PRB Coal Review Task 3 Study Area – Lower and Upper 

 Coal Production Scenarios....................................................... 4-78 

Table 4-28. PRB Rail Lines Coal Hauling Capacity and Projected Use......... 4-81 

Table 4-29. Recent and Projected PRB Population...................................... 4-87 

Table 4-30. Rental Housing Vacancy Rates, 2004 Q4 and 2006 Q4............ 4-89 

Table 4-31. Total Housing Stock in 2000 and 2005.................................... 4-89 

Table 4-32. Monthly Housing Rents in 2006 in the PRB Study Area and 

Percent Change from 2004 ...................................................... 4-90 

Table 4-33. Summary of Mineral Development Tax Revenues Associated 

with Energy Resource Production Under the Lower Production 

Scenario.................................................................................. 4-96 

Table 4-34. Summary of Mineral Development Tax Revenues Associated 

with Energy Resource Production Under the Upper Production 

Scenario.................................................................................. 4-97 

Table 5-1. List of Contributors and Reviewers. ........................................... 5-3 

Table 5-2. List of Preparers ........................................................................ 5-5 

Table 5-3. BLM Distribution List for Coal Leasing ...................................... 5-7 

LIST OF FIGURES 

Figure ES-1. General Location Map with Federal Coal Leases and LBA ....ES-2 

Tracts
 

Figure ES-2. General Analysis Area .........................................................ES-3 

Figure ES-3. Maximum Modeled PM10 and NOX Concentrations at the 

Antelope Mine Ambient Air Boundary for the Year 2012 ....ES-10 

Figure ES-4. Roads, Highways, Occupied Dwellings, Businesses and School 

Bus Stops in the Vicinity of the Antelope Mine and the West 

Antelope II General Analysis Area......................................ES-11 

Figure ES-5. Life of Mine Drawdown Map, Resulting from Currently 

Approved Mining with Addition of the West Antelope II LBA 

Tract.................................................................................ES-12 

Figure 1-1. General Location Map with Federal Coal Leases and LBA 

Tracts ................................................................................... 1-2 

xii Draft EIS, West Antelope II Coal Lease Application 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table of Contents 

TABLE OF CONTENTS (Continued) 

Figure 1-2. Federal Coal Leases and West Antelope II LBA Tract 

as Applied for........................................................................ 1-7 

Figure 2-1. West Antelope II LBA Alternative Tract Configurations........... 2-3 

Figure 3-1. General Analysis Area ........................................................... 3-2 

Figure 3-2. Wind Rose Diagram for Antelope Mine................................... 3-6 

Figure 3-3. Stratigraphic Relationships and Hydrologic Characteristics 

of Upper Cretaceous, Lower Tertiary, and Recent Geologic 

Units, PRB, Wyoming .......................................................... 3-10 

Figure 3-4. North-South and East-West Geologic Sections, West 

Antelope II LBA Tract .......................................................... 3-12 

Figure 3-5. Air Quality and Meteorological Stations at the Antelope 

Mine ................................................................................... 3-26 

Figure 3–6. Annual Coal Production and Overburden Removal vs. Monitored 

PM10 for the Antelope Mine ................................................. 3-27 

Figure 3–7. Maximum Modeled PM10 and NOX Concentrations at the 

Antelope Mine Ambient Air Boundary for the Year 2010 ...... 3-30 

Figure 3–8. Maximum Modeled PM10 and NOX Concentrations at the 

Antelope Mine Ambient Air Boundary for the Year 2012 ...... 3-31 

Figure 3–9. Roads, Highways, Occupied Dwellings, Businesses and School 

Bus Stops in the Vicinity of the Antelope Mine and the West 

Antelope II General Analysis Area........................................ 3-33 

Figure 3-10. Visibility in the Badlands and Bridger Wilderness Areas...... 3-48 

Figure 3-11. Locations of Groundwater Monitoring and Water Supply 

Wells at the Antelope Mine .................................................. 3-53 

Figure 3-12. Life of Mine Drawdown Map, Resulting from Currently 

Approved Mining with Addition of the West Antelope II LBA 

Tract................................................................................... 3-61 

Figure 3-13. Surface Water Features Within and Adjacent to the 

West Antelope II Study Area ................................................ 3-65 

Figure 3-14. Declared Alluvial Valley Floors Within and Adjacent to the 

West Antelope II Study Area ................................................ 3-73 

Figure 3-15. Wetlands and Other Waters Within the West Antelope II 

General Analysis Area ......................................................... 3-77 

Figure 3-16. Raptor Nest Sites and Prairie Dog Colonies Within the West 

Antelope II Wildlife Two-Mile Perimeter Area........................ 3-99 

Figure 3-17. Wildlife Features and Survey Routes Within the West Antelope II 

Wildlife Two-Mile Perimeter Area ....................................... 3-100 

Figure 3-18. Average Male Sage-grouse Lek Attendance Within the Northeast 

Wyoming Local Working Group Area (1967-2005).............. 3-108 

Figure 3-19. Average Male Sage-grouse Lek Attendance Statewide, Within 

the Northeast Wyoming Local Sage-Grouse Working Group 

Area, and Within the Thunder Basin National Grasslands 

(1996-2005) ...................................................................... 3-109 

Figure 3-20. Surface Ownership Within the West Antelope II LBA 

Tract. ................................................................................ 3-122 

Draft EIS, West Antelope II Coal Lease Application xiii 
 

 

 

 

 

 

 

 

 

 

Table of Contents 

TABLE OF CONTENTS (Continued) 

Figure 3-21. Oil and Gas Ownership on the West Antelope II LBA 

Tract ................................................................................. 3-124 

Figure 3-22. Relationship Between A-Scale Decibel Readings and 

Sounds of Daily Life........................................................... 3-144 

Figure 3-23. Transportation Facilities Within and Adjacent to the 

West Antelope II LBA Tract ................................................ 3-147 

Figure 3-24. Oil and Gas Pipelines Within and Adjacent to the 

West Antelope II LBA Tract ................................................ 3-148 

Figure 4-1. Wyoming Study Area for PRB Coal Review Studies 

Evaluating Current and Projected Levels of Development ....... 4-3 

Figure 4-2. Tons of Federal Coal Leased Versus Tons of Coal Mined 

Since 1990 ............................................................................ 4-5 

Figure 4-3. Projected Total Coal Production from Campbell and 

Converse Counties Under the Lower and Upper Coal Production 

Scenarios.............................................................................. 4-9 

Figure 4-4. Wyoming Task 3 Study Area for PRB Coal Review Studies 

Evaluating Projected Environmental Consequences............. 4-28 

Figure 4-5. Extrapolated Extent of Cumulative Drawdown Within the 

Wyodak Coal Aquifer in the South Gillette Subregion .......... 4-46 

Figure 4-6. Projected Campbell County Population and Employment 

to 2020................................................................................ 4-88 

Figure 4-7. Projected Housing Demand in the PRB Study Area Under 

the Lower Coal Production Scenario..................................... 4-91 

Figure 4-8. Projected School Enrollment Trends to 2020 Under the 

Lower Coal Production Scenario .......................................... 4-93 

LIST OF APPENDICES 

Appendix A. Federal and State Agencies and Permitting Requirements 

Appendix B. Unsuitability Criteria for the West Antelope II LBA Tract 

Appendix C. Coal Lease-by-Application Flow Chart 

Appendix D. BLM Special Coal Lease Stipulations and Form 3400-12 Coal 

Lease 

Appendix E. CBNG Wells Capable of Production 

Appendix F. Supplemental Air Quality Information 

Appendix G. Non-Mine Groundwater and Surface Water Rights 

Appendix H. USDA-FS Region 2 Sensitive Species and Management Indicator 

Species and BLM Sensitive Species Evaluation for the West 

Antelope II Coal Lease Application EIS 

Appendix I. Biological Assessment 

xiv Draft EIS, West Antelope II Coal Lease Application 
 Abbreviations and Acronyms 

Abbreviations and Acronyms Used in this Report 

AAQS Ambient Air Quality Standards 

ac acre(s) 

ACC Antelope Coal Company 

ac-ft acre-foot, acre-feet 

ac-ft/yr acre-foot per year, acre-feet per year 

AM Antelope Mine 

AML Abandoned Mine Land 

ANC Acidification Neutralization Capacity 

ANFO Ammonium Nitrate Fuel Oil 

APD Applications for Permit to Drill 

APLIC Avian Power Line Interaction Committee 

AQRV Air Quality Related Values 

ARCO Atlantic Richfield Company 

AREV Advanced Revelation (SEO water rights database and program) 

AUM Animal Unit Month 

AVF Alluvial Valley Floor 

BACM Best Available Control Measures 

BACT Best Available Control Technology 

bcf billion cubic feet 

BLM Bureau of Land Management 

BNSF Burlington Northern Santa Fe 

BNSF&UP Burlington Northern Santa Fe and Union Pacific 

BOE Barrels of Oil Equivalent 

B.P. Before Present 

Btu British thermal units 

Btu/lb British thermal units per pound 

CAA Clean Air Act 

CAAA Clean Air Act Amendment 

CAGR Compounded Annual Growth Rate 

CANDO Converse Area New Development Organization 

CBNG Coal Bed Natural Gas 

CCEDC Campbell County Economic Development Corporation 

CCSD Campbell County School District 

CERCLA Comprehensive Environmental Response, Compensation, and 

Liability Act of 1980 

CFR Code of Federal Regulations 

cfs cubic feet per second 

CHIA Cumulative Hydrologic Impact Assessment 

CO carbon monoxide 

CO2 carbon dioxide 

COE U.S. Army Corps of Engineers 

CREG Consensus Revenue Estimating Group 

CWA Clean Water Act 

dBA A-weighted decibels 

DEIS Draft Environmental Impact Statement 

DM&E Dakota, Minnesota & Eastern Railroad Corporation 

DOI Department of the Interior 

dv deciview, a measure of view impairment 

EC elemental carbon particles (re: air quality) 

EIA Energy Information Administration 

EIS Environmental Impact Statement 

Draft EIS, West Antelope II Coal Lease Application xv 
 

 

 

Abbreviations and Acronyms 

Abbreviations and Acronyms Used in this Report 

ENCOAL Encoal Corporation 

EOR Enhanced Oil Recovery 

EPA Environmental Protection Agency 

EQC Environmental Quality Council 

ESA Endangered Species Act 

EVG Erathem-Vanir Geological, PLLC 

F fahrenheit 

FCLAA Federal Coal Leasing Act Amendments of 1976 

FDM Fugitive Dust Model 

FEA Final Environmental Assessment 

FEIS Final Environmental Impact Statement 

FERC Federal Energy Regulatory Commission 

FLPMA Federal Land Policy Management Act of 1976 

FMR Federal Mineral Royalties 

FR Federal Register 

ft feet, foot 

ft/day feet per day 

ft2/day square feet per day 

ft3 cubic feet 

g gram 

GAO General Accounting Office 

GAGMO Gillette Area Ground Water Monitoring Organization 

GIS Geographic Information System 

Gpd gallons per day 

gpm gallons per minute 

GSP Gross State Product 

HAP Hazardous Air Pollutant 

IBLA Interior Board of Land Appeals 

IMPROVE Interagency Monitoring of Protected Visual Environments 

ISCLT3 Industrial Source Complex - Long Term 

JCR Job Completion Report 

km kilometers 

kV kilovolts 

LAC Limits Of Acceptable Change (re: air quality) 

LBA Lease By Application 

Leq equivalent continuous noise level 

LOM Life Of Mine 

LRMP Land and Resource Management Plan 

LRPL Least Restrictive Proposed Limit 

MBHFI Migratory Birds Of High Federal Interest 

μeq/L microequivalents per liter 

μg/m3 micrograms per cubic meter 

MDEQ Montana Department of Environmental Quality 

mg/L milligrams per liter 

MIS Management indicator species 

MLA Mineral Leasing Act of 1920 

mm million 

mmbcy million bank cubic yards 

mmbo million barrels of oil 

mmcfpd million cubic feet of gas per day 

mmgpy million gallons per year 

xvi Draft EIS, West Antelope II Coal Lease Application 
 

 Abbreviations and Acronyms 

Abbreviations and Acronyms Used in this Report 

mmt million tons 

mmtpy million tons per year 

mph miles per hour 

MRPL Most Restrictive Proposed Limit 

MSA Metropolitan Statistical Area 

MSHA Mine Safety and Health Administration 

MW megawatts 

N2O nitrous oxide 

NAAQS National Ambient Air Quality Standards 

NADP National Atmospheric Deposition Program 

NARO North Antelope/Rochelle 

NEAP Natural Events Action Plan 

NEPA National Environmental Policy Act of 1969 

NIOSH National Institute of Occupational Safety and Health 

NO nitrogen oxide 

NOAA National Oceanic and Atmospheric Administration 

NO2 nitrogen dioxide 

NOx nitrogen oxides 

NPS National Park Service 

NRCS National Resource Conservation Service 

NRHP National Register of Historic Places 

NSPS National Source Performance Standards 

NWI National Wetlands Inventory 

NWLSWG Northeast Wyoming Local Sage-Grouse Working Group 

NWS National Weather Service 

O3 photochemical oxidants 

ORV Off Road Vehicle 

OSHA Occupational Safety and Health Administration 

OSM Office of Surface Mining Reclamation & Enforcement 

PECs Passive Enclosure Control systems 

PFYC Probable Fossil Yield Classification 

P.M. Prime Meridian 

PM2.5 particulates finer than 2.5 microns in effective diameter 

PM10 particulates finer than 10 microns in effective diameter 

PMT Post-Mining Topography 

POD Plans Of Development 

ppm parts per million 

PRB Powder River Basin 

PRES Powder River Eagle Studies 

PRRCT Powder River Regional Coal Team 

PSD Prevention of Significant Deterioration 

PTE Potential to Emit 

R2P2 Resource Recovery and Protection Plan 

RACM Reactionary Control Measures 

RH Relative Humidity 

RMP Resource Management Plan 

ROD Record Of Decision 

ROW Right-Of-Way 

RV Recreational Vehicle 

SAR Sodium Absorption Ratio 

SARA Superfund Amendment & Reauthorization Act of 1986 

Draft EIS, West Antelope II Coal Lease Application xvii 
Abbreviations and Acronyms 

Abbreviations and Acronyms Used in this Report 

scf/ton standard cubic feet per ton 

SEIS Supplemental Environmental Impact Statement 

SEO State Engineer’s Office 

SHPO State Historic Preservation Office 

SIP State Implementation Plan 

SMCRA Surface Mining Control and Reclamation Act of 1977 

SO2 sulfur dioxide 

STB Surface Transportation Board 

T&E Threatened and Endangered 

TBCC Thunder Basin Coal Company, LLC 

TBNG Thunder Basin National Grassland 

TDS total dissolved solids 

TPY tons per year 

TSS total suspended solids 

TSP total suspended particulates 

UP Union Pacific 

U.S. United States 

USC, U.S.C. United States Code 

USDA U.S. Department of Agriculture 

USDA-FS U.S. Department of Agriculture - Forest Service 

USDI U.S. Department of the Interior 

USGS U.S. Geological Survey 

USFWS U.S. Fish and Wildlife Service 

UW Upper Wyodak coal seam 

VOCs Volatile Organic Compounds 

VRM Visual Resource Management 

WA Wilderness Area 

WAAQS Wyoming Ambient Air Quality Standards 

WAQSR Wyoming Air Quality Standards and Regulations 

WARMS Wyoming Air Resources Monitoring System 

WDEQ Wyoming Department of Environmental Quality 

WDEQ/AQD Wyoming Department of Environmental Quality/Air Quality 

Division 

WDEQ/ISD Wyoming Department of Environmental Quality/Industrial 

Siting Division 

WDEQ/LQD Wyoming Department of Environmental Quality/Land Quality 

Division 

WFA Western Fuels Association 

WGFD Wyoming Game and Fish Department 

WMA Wyoming Mining Association 

WOGCC Wyoming Oil and Gas Conservation Commission 

WRCC Western Regional Climate Center 

WSFC Wyoming School Facilities Commission 

WSGS Wyoming State Geological Survey 

WSO-RMG Wyoming State Office Reservoir Management Group 

WYDOT Wyoming Department of Transportation 

yrs years 

xviii Draft EIS, West Antelope II Coal Lease Application 
 

1.0 Introduction 

1.0 INTRODUCTION 

This EIS1 analyzes the environmental impacts of leasing a tract of federal coal 

reserves adjacent to the Antelope Mine, an operating surface coal mine in the 

south-central PRB of Wyoming. The Antelope Mine is operated by ACC, a directly 

held subsidiary of Rio Tinto Energy. ACC filed an application to lease the federal 

coal included in a maintenance coal tract under the regulations at 43 CFR 3425, 

Leasing On Application. The Division of Minerals and Lands at the BLM Wyoming 

State Office reviewed the application and determined that the lease application 

meets the regulatory requirements for an LBA. The tract is referred to as the West 

Antelope II LBA tract. Figure 1-1 shows the West Antelope II LBA tract as applied 

for by ACC, other currently pending LBA tracts, and the existing federal leases, 

including previously leased LBA tracts, in the Wyoming PRB. 

1.1 Background 

On April 6, 2005, ACC filed an application with the BLM for federal coal reserves 

in a tract located west of and immediately adjacent to the Antelope Coal Mine in 

Campbell and Converse Counties, Wyoming, approximately 20 miles southeast of 

Wright, Wyoming and 55 Miles north of Douglas, Wyoming (Figure 1-1). The tract, 

which is referred to as the West Antelope II LBA tract, was assigned case file 

number WYW163340. The federal coal reserves were applied for as a maintenance 

tract for the Antelope Mine. The Antelope Mine is operated by ACC, a directly held 

subsidiary of Rio Tinto Energy America (formerly Kennecott Energy and Coal 

Company). 

The West Antelope II LBA tract is located within the Powder River Federal Coal 

Region, which was decertified in January, 1990. Although the Powder River 

Federal Coal Region is decertified, the PRRCT, a federal/state advisory board 

established to develop recommendations concerning management of federal coal 

in the region, has continued to meet regularly and review all federal lease 

applications in the region. The PRRCT reviewed this maintenance coal lease 

application at a public meeting held on April 27, 2005 in Gillette, Wyoming. The 

PRRCT recommended that the BLM process the West Antelope II lease application. 

In order to process an LBA, the BLM must evaluate the quantity, quality, 

maximum economic recovery, and fair market value of the federal coal and fulfill 

the requirements of NEPA by evaluating the environmental impacts of leasing the 

federal coal. BLM does not authorize mining by issuing a lease for federal coal, 

but the impacts of mining the coal are considered in this EIS because it is a logical 

consequence of issuing a maintenance lease to an existing mine. This EIS has 

been prepared to evaluate the site-specific and cumulative environmental impacts 

of leasing and developing the federal coal included in the application area. BLM 

will use the analysis in this EIS to decide whether to hold a competitive, 

Refer to page xv for a list of abbreviations and acronyms used in this document. 

Draft EIS, West Antelope II Coal Lease Application 1-1 

1 
 

E

E

E

1.0 Introduction 

ST59 LEGEND

¥¦

West Hay Creek Existing Coal Leases (Prior to Decertification) 

tu

90 

16 

tu

tu

16 

14 

LBA's Issued
 

Hay Creek II Belco I90 LBA's Pending
 

Exchange Lease
 LBA Tract As Applied For (This EIS) 

Buckskin Mine Urban Area 

County Boundary 

Rawhide Mine 

Eagle Butte Mine 

Eagle Butte West Dry Fork Mine 

Eagle Butte 

Wyodak Mine 

¥¦Rozet

90

GILLETTE

To Buffalo38 Miles 

Campbell County
 

Crook County
 

Moorcroft

¥¦90

West Rocky Butte 

Caballo West 

Belle Ayr North Caballo Mine 

Belle Ayr Mine 

Johnson County 

Campbell County 

Cordero-Rojo Mine 

ST50 Maysdorf 

Maysdorf II 

West Coal Creek 

Coal Creek Mine 

ST59

Weston County 

West Jacobs Ranch 

Hilight Field 

Thundercloud Little Thunder 

ST116

North Jacobs Ranch RENO Jacobs JUNCTION Ranch 

Jacobs Ranch Mine 

WRIGHT West Black Thunder West Hilight 

Black Thunder Mine 

ST387 West Roundup 

NARO North 

ST450 North Rochelle 

School Creek Mine 

To Newcastle 

29 Miles 

0 £ Campbell County 

Converse County 

10 

Horse Creek 

West Antelope 

Porcupine 

West Antelope II 

20 ST59

Weston County 

Niobrara County 

Powder River 

NARO South 

North Antelope / Rochelle Mine 

North Antelope/ Rochelle 

Antelope Mine 

To Douglas 

GRAPHIC SCALE - MILES 46 Miles

Figure 1-1. General Location Map with Federal Coal Leases and LBA Tracts. 

1-2 Draft EIS, West Antelope II Coal Lease Application 
 

1.0 Introduction 

sealed-bid lease sale for the tract as applied for, hold a competitive, sealed-bid 

lease sale for a modified tract, or reject the lease application and not offer the tract 

for sale at this time. A Record of Decision will be issued and, if the decision is to 

offer the tract for lease, then a sale will be held. If a sale is held, the bidding at 

the sale would be open to any qualified bidder; it would not be limited to the 

applicant. 

If the lease sale is held, a lease would be issued to the highest bidder at the sale if 

a federal sale panel determines that the high bid meets or exceeds the fair market 

value of the coal as determined by BLM’s economic evaluation and if the U.S. 

Department of Justice determines that there would be no antitrust violations if a 

lease is issued to the high bidder. 

In return for receiving a lease, a lessee must pay the federal government a bonus 

equal to the amount it bids at the time the lease sale is held (the bonus can be 

paid in five yearly installments), make annual rental payments to the federal 

government, and make royalty payments to the federal government when the coal 

is mined. Federal bonus, rental, and royalty payments are equally divided with 

the state in which the lease is located. 

Other agencies may use this analysis to make decisions related to leasing and 

mining the federal coal in this tract. OSM, USDA-FS, WDEQ/AQD, WDEQ/LQD, 

and the Converse County Board of Commissioners are cooperating agencies on 

this EIS. OSM has primary responsibility to administer federal programs that 

regulate surface coal mining operations and will use this EIS to make decisions 

related to the approval of the MLA mining plan if the tract is leased. USDA-FS 

must consent to leasing the federal coal before BLM can make a decision to hold a 

federal coal lease sale if any of the lands in the TBNG, which they administer, are 

included in the tract that is leased. WDEQ has entered into a cooperative 

agreement with the Secretary of the Interior to regulate surface coal mining 

operations on federal and non-federal lands within the State of Wyoming. The 

responsibilities of the Converse County Board of Commissioners include, but are 

not limited to, management and oversight of county roads and facilities and 

zoning rules in the county. 

Since decertification of the Powder River Federal Coal Region, 17 federal coal 

leases have been sold at competitive sealed-bid sales and three exchanges of 

federal coal in the Wyoming portion of the Powder River Federal Coal Region have 

been completed (Table 1-1). This is the fourth application for a maintenance coal 

tract submitted by the ACC since decertification (Table 1-1 and Figure 1-1). 

Table 1-2 summarizes the lease applications that are currently pending. 

The West Antelope II LBA tract as applied for and the existing federal coal leases 

in the adjacent Antelope Mine are shown in Figure 1-2. As applied for, the West 

Antelope II LBA tract consists of two separate blocks of federal coal and includes 

Draft EIS, West Antelope II Coal Lease Application 1-3 
1.0 Introduction 

Table 1-1. Leases Issued and Exchanges Completed Since Decertification, 

Powder River Basin, Wyoming. 

Leases Issued 

LBA Name (Lease Number) 

Applicant Mine 

Current Lessee Acres Mineable Tons Successful 

Effective Date Leased1 of Coal1 Bid 

Jacobs Ranch LBA (WYW117924) 

Jacobs Ranch Mine
 

Jacobs Ranch Coal Co. 

10/1/1992 

West Black Thunder LBA (WYW118907) 

Black Thunder Mine
 

Thunder Basin Coal Co. 

10/1/1992 

North Antelope/Rochelle LBA 

(WYW119554) 

North Antelope & Rochelle Mines 

Powder River Coal Co. 

10/1/1992 

West Rocky Butte LBA (WYW122586) 

No Existing Mine2
 

Caballo Coal Co. 

1/1/1993 

Eagle Butte LBA (WYW124783) 

Eagle Butte Mine
 

Foundation Wyoming Land Co. 

8/1/1995 

Antelope LBA (WYW128322) 

Antelope Mine
 

Antelope Coal Co. 

2/1/1997 

North Rochelle LBA (WYW127221) 

North Rochelle Mine
 

Ark Land Co. 

1/1/1998 

Powder River LBA (WYW136142) 

North Antelope Rochelle Mine
 

Powder River Coal Co. 

9/1/1998 

Thundercloud LBA (WYW136458) 

Jacobs Ranch Mine
 

Thunder Basin Coal Co., LLC 

1/1/1999 

Horse Creek LBA (WYW141435) 

Antelope Mine
 

Antelope Coal Co. 

12/1/2000 

North Jacobs Ranch LBA (WYW146744) 

Jacobs Ranch Mine
 

Jacobs Ranch Coal Co. 

5/1/2002 

1,708.620 147,423,560 $20,114,930.00 

3,492.495 429,048,216 $71,909,282.69 

3,064.040 403,500,000 $86,987,765.00 

463.205 56,700,000 $16,500,000.00 

1,059.180 166,400,000 $18,470,400.00 

617.200 60,364,000 $9,054,600.00 

1,481.930 157,610,000 $30,576,340.00 

4,224.225 532,000,000 $109,596,500.00 

3,545.503 412,000,000 $158,000,008.50 

2,818.695 275,577,000 $91,220,120.70 

4,982.240 537,542,000 $379,504,652.00 

1-4 Draft EIS, West Antelope II Coal Lease Application 
 

1.0 Introduction 

Table 1-1. Leases Issued and Exchanges Completed Since Decertification, 

Powder River Basin, Wyoming (Continued). 

LBA Name (Lease Number) 

Applicant Mine 

Current Lessee Acres Mineable Tons Successful 

Effective Date Leased1 of Coal1 Bid 

NARO South LBA (WYW154001)
 

North Antelope Rochelle Mine
 

BTU Western Resources, Inc. 

9/1/2004
 

West Hay Creek LBA (WYW151634) 

Buckskin Mine
 

Kiewit Mining Properties, Inc. 

1/1/2005
 

Little Thunder LBA (WYW150318) 

Black Thunder Mine
 

Ark Land LT Co. 

3/1/2005
 

West Antelope LBA (WYW151643) 

Antelope Mine
 

Antelope Coal Co. 

3/1/2005
 

NARO North LBA (WYW150210)
 

North Antelope Rochelle Mine
 

BTU Western Resources, Inc. 

3/1/2005 

West Roundup LBA (WYW151134) 

North Rochelle Mine
 

West Roundup Resources, Inc 

5/1/2005
 

TOTALS 

2,956.725 297,469,000 

921.158 142,698,000 

5,083.500 718,719,000 

2,809.130 194,961,000 

2,369.380 324,627,000 

2,812.51 327,186,000 

44,409.731 5,183,824,776 

$274,117,684.00 

$42,809,400.00 

$610,999,949.80 

$146,311,000.00 

$299,143,785.00 

$317,697,610.00 

$2,683,014,027.69 

Exchanges Completed 

Exchange Name 

Case File Number 

Exchange Proponent 

Exchange Type Acres Mineable Tons Federal Coal 

Effective Date Exchanged of Coal Exchanged for: 

EOG (Belco) I-90 Lease Exchange 599.170 106,000,000 Lease Rights to Belco 

WYW150152 I-90 Lease 

EOG Resources (formerly Belco)3 (WYW0322794) 

I-90 Lease Exchanged for New Lease 

4/1/2000 

Pittsburg & Midway Coal Exchange 2,045.530 84,200,000 6,065.77 acres of land 

WYW148816 and some minerals in 

Pittsburg and Midway Coal Mining Co. Lincoln, Carbon, and 

Private Land Exchanged for Federal Coal Sheridan Counties, 

1/27/2005 Wyoming. 

Powder River Coal Co. Gold Mine Draw 623 47,700,000 Lease Rights to 921.6 

WYW003397 and WYW83394 Acres of leased Federal 

Powder River Coal Company Coal underlying an AVF 

AVF Coal Lease exchanged for adjacent 

6/30/2006 bypass coal 

TOTALS 3,267.70 237,900,000 

1 Information from Sale Notice. 2 The West Rocky Butte LBA was originally leased to Northwestern Resources Co. 3 The EOG Resources Belco Exchange lease is now owned by the Buckskin Mine.
 

Draft EIS, West Antelope II Coal Lease Application 1-5 
 

1.0 Introduction 

Table 1-2. Pending LBAs and Exchanges, Powder River Basin, Wyoming. 

Pending LBAs 

Estimated as 

LBA Name Applied for

Lease Number Application Acres as Coal 

Applicant Mine Date Applied for (mmt) Status 

N. Maysdorf 9/20/2001 2,219.39 230.301 N. Maysdorf Sale 

WYW154432 Modified 10/18/2007 

S. Maysdorf 11/8/2004 Bid Rejected 

WYW174407 S. Maysdorf Sale 

Cordero Rojo 11/28/2007 

Bid Rejected 

Eagle Butte West 12/28/2001 1,397.64 231.002 FEIS available 

WYW155132 Modified 8/31/2007 

Eagle Butte 10/16/2003 ROD Available 

12/3/2007 

Belle Ayr North 7/06/2004 1,578.74 200.002 End of Scoping 

WYW161248 6/1/2007 

Belle Ayr DEIS in Preparation 

West Antelope II 4/06/2005 4,108.60 429.703 End of Scoping 

WYW163340 12/1/2006 

Antelope DEIS in Preparation 

N. Highlight Field 10/07/2005 2,613.50 588.202 End of Scoping 

WYW164812 Modified 9/3/2007 

S. Hilight Field 10/16/2007 1,976.69 DEIS in Preparation 

WYW174596 

Black Thunder 

West Hilight Field 1/17/2006 2,370.52 428.002 End of Scoping 

WYW172388 9/3/2007 

Black Thunder DEIS in Preparation 

West Coal Creek 2/10/2006 1,151.26 57.002 End of Scoping 

WYW172585 6/1/2007 

Coal Creek DEIS in preparation 

Caballo West 3/15/2006 777.49 87.521 End of Scoping 

WYW172657 6/1/2007 

Caballo DEIS in preparation 

West Jacobs Ranch 3/24/2006 5,944.37 956.003 End of Scoping 

WYW172685 9/3/2007 

Jacobs Ranch DEIS in Preparation 

Hay Creek II 3/24/2006 1,448.87 148.001 Scoping meeting 

WYW172684 scheduled 1/31/2008 

Buckskin 

Maysdorf II 9/1/2006 4,653.80 483.003 End of Scoping 

WYW173360 6/1/2007 

Cordero Rojo DEIS in preparation 

Porcupine 9/29/2006 8,981.74 1,097.00 End of Scoping 

WYW173408 Modified 9/3/2007 

North Antelope/Rochelle 10/12/2007 DEIS in Preparation 

TOTALS 39,222.61 4,935.72 

1 Estimated tons of mineable coal as reported in the lease application. 2 Estimated tons of recoverable coal as reported by the applicant. 3 Estimated tons of in-place coal as reported in the lease application. 

1-6 Draft EIS, West Antelope II Coal Lease Application 
-

 

1.0 Introduction 

Campbell County 

Converse County 

B.N.S.F. & U.P RR 

North Antelope / Rochelle 

Rail Line 

Antelope Road 

T. 

40 

N. 

R. 72 W. R. 70 W. 

T. 

41 

N. 

T 

4 

N 

R. 71 W. 

T 

4 

N 

R. 71 W. 

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

W-141435 

W-151643 

W-0321780 

W-0322255 

W-128322 

W 0322255 

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£ 0 8,000 16,000 

GRAPHIC SCALE (FEET) 

LEGEND 

Antelope Mine Permit Boundary 

West Antelope II LBA Tract As Applied For 

Federal Coal Lease W-0321780 

Federal Coal Lease W-0322255 

Federal Coal Lease W-128322 

Federal Coal Lease W-141435 

Federal Coal Lease W-151643 

County Rd. 37 

Figure 1-2. Federal Coal Leases and West Antelope II LBA Tract as Applied for. 

Draft EIS, West Antelope II Coal Lease Application 1-7
1.0 Introduction 

approximately 4,108.6 acres with an estimated 465.1 million tons of in-place coal 

reserves. ACC estimates that approximately 429.5 million tons of in-place coal 

reserves would be recovered from the West Antelope II LBA tract as applied for. As 

of January 2007, ACC estimates the in-place reserves on the existing Antelope 

Mine to be 428.6 million tons, of which 394.3 million tons are recoverable. 

Antelope Mine’s currently approved (by WDEQ/AQD) air quality permit allows 

mining of up to 42 million tons of coal per year. The Antelope Mine produced 

approximately 33.9 million tons of coal in 2006, 30.0 million tons of coal in 2005, 

29.7 million tons of coal in 2004, 29.5 million tons of coal in 2003, 26.8 million 

tons of coal in 2002, and 24.6 million tons of coal in 2001 (Antelope Mine 2000, 

2001, 2002, 2003, 2004, 2005, and 2006). 

As discussed above, the West Antelope II LBA tract as applied for consists of two 

separate blocks, both of which are contiguous with the Antelope Mine (Figure 1-1). 

Portions of both blocks lie within current ACC mine permit boundaries (Figure 1-

2). The area applied for is substantially similar to the adjacent mine for which 

detailed site-specific environmental data have been collected and for which 

environmental analyses have previously been prepared to secure the existing 

leases and necessary mining permits. 

The surface of the West Antelope II LBA tract is owned by ACC, Barbara H. Dilts 

Living Trust et. al., Jerry J. and Barbara Dilts Family Ltd. Partnership and Bridle 

Bit Ranch Co., and Patricia L. Isenberger Litton. Current land uses of the tract 

include grazing by domestic animals and wildlife and gas production. 

The mining method would be a combination of truck and shovel and dragline, 

which are the mining methods currently in use at this mine. The coal would be 

used primarily for electric power generation. 

After mining, the land would be reclaimed to a rangeland function suitable for use 

by livestock and wildlife as is the current practice at the Antelope Mine. Industrial 

postmining land uses, which include but are not limited to oil and gas wells, 

pipelines, roads, and utility easements, also will be reestablished as required. 

1.2 Purpose and Need for Action 

BLM administers the federal coal leasing program under the Mineral Leasing Act 

of 1920. A federal coal lease grants the lessee the exclusive right to obtain a 

mining permit for, and to mine coal on, the leased tract subject to the terms of the 

lease, the mining permit, and applicable state and federal laws. Before a new 

lease can be mined, the lessee must obtain approval of a detailed permit to 

conduct mining operations. 

This EIS is being prepared in response to an application BLM received from an 

existing mine, the Antelope Mine, to lease a tract of federal coal in the Wyoming 

PRB. In response to this coal lease application, the BLM must decide whether to 

1-8 Draft EIS, West Antelope II Coal Lease Application 
1.0 Introduction 

hold a competitive, sealed-bid lease sale for the tract as applied for, hold a 

competitive sealed-bid lease sale for a modified tract, or reject the current lease 

application and not offer the tract for sale at this time. 

ACC has applied for the coal reserves in the West Antelope II LBA tract in order to 

extend the life of the Antelope Mine. If production continues at the current (2007) 

average annual coal production rate of about 36 mmtpy, the applicant estimates 

that the post-2006 recoverable reserves at the Antelope Mine would be depleted 

within approximately 11 years. If Antelope Mine acquires a lease for the West 

Antelope II LBA tract as applied for and maintains a similar production rate, the 

applicant estimates that mine life would be extended by an additional 12 to 13 

years. If production increases to the permitted level of 42 mmtpy and ACC 

acquires the West Antelope II LBA tract, mining the LBA tract would extend 

production at the mine by an additional 10 to 11 years. 

If the LBA tract is leased to the applicant as a maintenance tract, the permit to 

conduct mining operations for the adjacent Antelope Mine would have to be 

amended to include the new lease area before it could be disturbed. This process 

takes several years to complete. ACC is applying for federal coal reserves now so 

that they can negotiate new contracts and then complete the permitting process in 

time to meet anticipated new contract requirements. 

As discussed above, the purpose of ACC’s application is to allow the Antelope Mine 

access to a continuing supply of low sulfur compliance coal, which it can continue 

to sell to power plants for the purpose of electric power generation. According to 

the Energy Information Administration, coal is currently responsible for about 50 

percent of the total generation in the electric power sector (EIA 2006, 2007a). 

Continued leasing of PRB coal enables coal-fired power plants to meet CAA 

requirements without constructing new plants, revamping existing plants, or 

switching to existing alternative fuels. This helps provide a stable supply of power 

to meet increasing demand without a potentially significant increase in power 

costs for individuals and businesses. 

A primary goal of the National Energy Policy is to add energy supplies from diverse 

sources, including domestic oil, gas, and coal, as well as hydropower and nuclear 

power. BLM recognizes that the continued extraction of coal is essential to meet 

the nation’s future energy needs. As a result, private development of federal coal 

reserves is integral to the BLM coal leasing program under the authority of the 

MLA, as well as FLPMA and FCLAA. The coal leasing program, managed by BLM, 

encourages the development of domestic coal reserves and reduction of the U.S. 

dependence on foreign sources of energy. As a result of the leasing and 

subsequent mining and sale of federal coal resources in the PRB, the public 

receives lease bonus payments, lease royalty payments, and a reliable supply of 

low sulfur coal for power generation. 

This EIS analyzes the environmental impacts of issuing a federal coal lease and 

mining the federal coal in the West Antelope II maintenance coal lease application 

Draft EIS, West Antelope II Coal Lease Application 1-9 
1.0 Introduction 

as required by NEPA and associated rules and guidelines. A decision to hold a 

competitive sale and issue a lease for the lands in this application is a prerequisite 

for mining but it is not the enabling action that would allow mining to begin. The 

BLM does not authorize mining operations by issuing a lease. After a lease has 

been issued but prior to mine development, the lessee must file a permit 

application package with the WDEQ/LQD and OSM for a surface mining permit 

and approval of the MLA mining plan. An analysis of a detailed site-specific 

mining and reclamation plan occurs at that time. Authorities and responsibilities 

of the BLM and other concerned regulatory agencies are described in the following 

sections. 

1.3 Regulatory Authority and Responsibility 

The West Antelope II maintenance coal lease application was submitted and will 

be processed and evaluated under the following federal authorities: 

• MLA, as amended; 

• Multiple-Use Sustained Yield Act of 1960; 

• NEPA; 

• FCLAA; 

• FLPMA; and 

• SMCRA. 

The BLM is the lead agency responsible for leasing federal coal lands under the 

MLA as amended by FCLAA and is also responsible for preparation of this EIS to 

evaluate the potential environmental impacts of issuing a coal lease. 

OSM is a cooperating agency on this EIS. After a federal coal lease is issued, 

SMCRA gives OSM primary responsibility to administer programs that regulate 

surface coal mining operations and the surface effects of underground coal mining 

operations. WDEQ is also a cooperating agency on this EIS. Pursuant to Section 

503 of SMCRA, the WDEQ developed, and in November 1980 the Secretary of the 

Interior approved, a permanent program authorizing WDEQ to regulate surface 

coal mining operations and surface effects of underground mining on nonfederal 

lands within the State of Wyoming. In January 1987, pursuant to Section 523(c) 

of SMCRA, WDEQ entered into a cooperative agreement with the Secretary of the 

Interior authorizing WDEQ to regulate surface coal mining operations and surface 

effects of underground mining on federal lands within the state. 

Pursuant to the cooperative agreement, a federal coal lease holder in Wyoming 

must submit a permit application package to OSM and WDEQ/LQD for any 

proposed coal mining and reclamation operations on federal lands in the state. 

WDEQ/LQD reviews the permit application package to insure the permit 

application complies with the permitting requirements and the coal mining 

operation will meet the performance standards of the approved Wyoming program. 

OSM, BLM, and other federal agencies review the permit application package to 

insure it complies with the terms of the coal lease, the MLA, NEPA, and other 

1-10 Draft EIS, West Antelope II Coal Lease Application 
1.0 Introduction 

federal laws and their attendant regulations. If the permit application package 

does comply, WDEQ issues the applicant a permit to conduct coal mining 

operations. OSM recommends approval, approval with conditions, or disapproval 

of the MLA mining plan to the Assistant Secretary of the Interior, Land and 

Minerals Management. Before the MLA mining plan can be approved, the BLM 

must concur with this recommendation. 

If a proposed LBA tract is leased to an existing mine, the lessee is required to 

revise its coal mining permit prior to mining the coal, following the processes 

outlined above. As a part of that process, a detailed new plan would be developed 

showing how the newly-leased lands would be mined and reclaimed. The area of 

mining disturbance would be larger than the newly-leased area to allow for 

activities such as overstripping, matching reclaimed topography to undisturbed 

topography, constructing flood control and sediment control facilities, and related 

activities. Specific impacts that would occur during the mining and reclamation of 

the LBA tract would be addressed in the mining and reclamation plan, and 

specific mitigation measures for anticipated impacts would be described in detail 

at that time. 

WDEQ enforces the performance standards and permit requirements for 

reclamation during a mine’s operation and has primary authority in 

environmental emergencies. OSM retains oversight responsibility for this 

enforcement. Where federal surface or coal resources are involved, BLM has 

authority in emergency situations if WDEQ or OSM cannot act before 

environmental harm and damage occurs. In preparing this EIS, BLM also has a 

responsibility to consult with and obtain the comments and assistance of other 

state and federal agencies that have jurisdiction by law or special expertise with 

respect to potential environmental impacts. 

Appendix A presents other federal and state permitting requirements that must be 

satisfied to mine this LBA tract. 

1.4 Relationship to BLM Policies, Plans, and Programs 

In addition to the federal acts listed under Section 1.3, guidance and regulations 

for managing and administering public lands, including the federal coal lands in 

the ACC application, are set forth in 40 CFR 1500 (Protection of Environment), 43 

CFR 1601 (Planning, Programming, Budgeting), and 43 CFR 3400 (Coal 

Management). 

Specific guidance for processing applications is provided by BLM Manual 3420, 

Competitive Coal Leasing (BLM 1989) and the 1991 Powder River Regional Coal 

Team Operational Guidelines For Coal Lease-By-Applications (BLM 1991). The 

National Environmental Policy Act Handbook (BLM 1988) has been followed in 

developing this EIS. 

Draft EIS, West Antelope II Coal Lease Application 1-11 
1.0 Introduction 

1.5 Conformance with Existing Land Use Plans 

FCLAA requires that lands considered for leasing be included in a comprehensive 

land use plan and that leasing decisions be compatible with that plan. The BLM 

Approved Resource Management Plan for Public Lands Administered by the Bureau 

of Land Management Buffalo Field Office (BLM 2001a), an update of the Buffalo 

Resource Area Resource Management Plan (BLM 1985a), governs and addresses the 

leasing of federal coal in Campbell County. The Record of Decision and Approved 

Casper Resource Management Plan (BLM 2007), an update of the Platte River 

Resource Management Plan (BLM 1985b), addresses the leasing of federal coal in 

Converse County. The Land and Resource Management Plan for the Thunder Basin 

National Grassland, Medicine Bow-Routt National Forest, Rocky Mountain Region 

(USDA-FS 2001) offers guidance for all resource management activities on the 

TBNG. 

The major land use planning decision that BLM must make concerning the federal 

coal resources is a determination of which federal coal lands are acceptable for 

further consideration for leasing. There are four screening procedures that BLM 

uses to identify these coal lands. These screening procedures require BLM to: 

•	 estimate development potential of the coal lands; 

•	 apply the unsuitability criteria listed in the regulations at 43 CFR 3461; 

•	 make multiple land use decisions that eliminate federal coal deposits from 

consideration for leasing to protect other resource values; and 

•	 consult with surface owners who meet the criteria defined in the regulations 

at 43 CFR 3400.0-5 (gg) (1) and (2). 

Only those federal coal lands that pass these screens are given further 

consideration for leasing. BLM has applied these coal screens to federal coal 

lands in the PRB several times, starting in the early 1980s. Most recently, in 

1993, BLM began the process of reapplying these screens to federal coal lands in 

Campbell, Converse, and Sheridan Counties. This analysis, which includes the 

portion of Converse County where the Antelope Mine is located, was adopted in 

the 2001 BLM Buffalo Field Office RMP update (BLM 2001a), and the results were 

included as Appendix D of the update, which can be viewed in the 2001 

documents section on the Wyoming BLM website at: 

http://www.blm.gov/wy/st/en/info/NEPA/documents.html. The coal screen was 

completed for use not only in updating the 1985 Buffalo RMP but also the TBNG 

planning documents. Appendix D of the 2001 RMP update was prepared in 

cooperation with the USDA-FS, Douglas Ranger District for lands within the 

TBNG. No revisions of the coal-screening determinations completed for the 

Buffalo Field Office RMP update are included in the approved Casper Field Office 

RMP and associated EIS (BLM 2007). 

Under the first coal screening procedure, a coal tract must be located within an 

area that has been determined to have coal development potential in order to be 

acceptable for further consideration for leasing (43 CFR 3420.1-4(e)(1)). The West 

1-12 Draft EIS, West Antelope II Coal Lease Application 
1.0 Introduction 

Antelope II coal lease application is within the area identified as having coal 

development potential by the BLM in the coal screening analyses published in 

2001 BLM Buffalo Field Office RMP update. 

The second coal screening procedure requires the application of the coal mining 

unsuitability criteria listed in the federal coal management regulations at 43 CFR 

3461. The coal mining unsuitability criteria were applied to high to moderate coal 

development potential lands in the Wyoming PRB, including the West Antelope II 

LBA tract and surrounding lands, during the coal screening conducted for the 

2001 BLM Buffalo Field Office RMP update. Appendix B of this EIS summarizes 

the unsuitability criteria, describes the general findings for the 2001 BLM Buffalo 

Field Office RMP update, and presents a validation of these findings for the West 

Antelope II LBA tract. 

The BNSF & UP railroad line crosses portions of the northern block of federal coal 

included in the West Antelope II LBA tract (Figure 1-2). As indicated in Appendix 

B, the lands in the West Antelope II LBA tract that are within the BNSF & UP 

railroad ROW and associated 100 foot buffer zone have been found to be 

unsuitable for mining under Unsuitability Criterion Number 2. Although lands 

within the railroad ROW have been determined to be unsuitable for mining, they 

are included in the LBA tract to allow recovery of all the mineable coal outside of 

the ROW and associated buffer zone and to comply with the coal leasing 

regulations, which do not allow leasing in less than 10-acre aliquot parts. A 

stipulation stating that no mining activity may be conducted in the portion of the 

lease within the BNSF & UP railroad ROW will be attached if a lease is issued for 

this tract. The exclusion of the coal underlying the railroad ROW from mining 

activity by lease stipulation honors the finding of unsuitability for mining under 

Unsuitability Criterion Number 2 for the BNSF & UP railroad ROW. 

Unsuitability Criterion Number 3 states that lands within 100 ft of the outside line 

of the ROW of a public road shall be considered unsuitable for surface coal 

mining, with certain exceptions. No public roads cross the West Antelope II LBA 

tract as applied for (Figure 1-2). However, as discussed in Chapter 2, BLM 

evaluates alternate tract configurations as alternatives to the Proposed Action for 

NEPA purposes. In evaluating the West Antelope II application, BLM has 

identified a study area for the tract which includes the tract as applied for and 

adjacent unleased federal coal. As shown in Figure 2-1, portions of Converse 

County Road 37 and Wyoming State Highway 59 cross the southern end of the 

BLM study area for the West Antelope II LBA tract. The 2001 BLM Buffalo RMP 

update and the 2001 TBNG LRMP deferred a decision on the unsuitability of the 

Wyoming State Highway 59 and Converse County Road 37 ROWs and associated 

buffer zones until a leasing action occurred. As indicated in Appendix B, BLM has 

determined that the portions of the West Antelope II LBA tract which include 

Wyoming State Highway 59 and Campbell County Road 37, their ROWs, and a 

100-ft buffer zone on either side of the ROWs must be considered unsuitable for 

mining under Unsuitability Criterion Number 3 at this time. 

Draft EIS, West Antelope II Coal Lease Application 1-13 
 

1.0 Introduction 

One of the exceptions to Unsuitability Criterion 3 allows surface coal mining in the 

ROW and buffer zone for a public road if the regulatory authority (or the 

appropriate public road authority designated by the regulatory authority) allows 

the public road to be relocated or closed after providing public notice and 

opportunity for a public hearing; and finding in writing that the interests of the 

affected public and landowners will be protected [30 CFR 761.11(d) and 43 CFR 

3461.5(c)(iii)]. At this time, there are no proposals to relocate either Wyoming 

State Highway 59 or Converse County Road 37, and the exception does not apply. 

Although the lands within the Wyoming State Highway 59 and Converse County 

Road 37 ROWs and associated buffer zones have been determined to be 

unsuitable for mining, they are included in the BLM study area for the West 

Antelope II LBA tract. If the portions of the tract that include the Wyoming State 

Highway 59 ROW and/or Converse County Road 37 are leased, including these 

lands in the tract would allow recovery of all the mineable coal adjacent to and 

outside of the highway buffer zones and would comply with the coal leasing 

regulations, which do not allow leasing in less than 10-acre aliquot parts. If a 

permit to relocate one or both of the roads is approved at some time in the future, 

including these lands in the tract would allow recovery of the coal underlying the 

public road ROWs and associated buffer zones. A stipulation stating that no 

mining activity may be conducted within the Wyoming State Highway 59 and 

Converse County Road 37 ROWs and associated 100-foot buffer zones unless a 

permit to move them is approved will be attached if a lease is issued for this tract. 

The exclusion of the coal underlying the public road ROWs and associated buffer 

zones from mining activity by lease stipulation honors the finding of unsuitability 

for mining under Unsuitability Criterion Number 3 for Wyoming State Highway 59 

and Converse County Road 37. 

There were no findings of unsuitability for the other criteria listed in the 

regulations; however, as indicated in Appendix B, several criteria will be further 

evaluated during the leasing process. 

The third coal screening procedure, a multiple land use conflict analysis, must be 

completed to identify and “eliminate additional coal deposits from further 

consideration for leasing to protect resource values of a locally important or 

unique nature not included in the unsuitability criteria”, in accordance with 43 

CFR 3420.1-4(e)(3). The 2001 Buffalo RMP update addresses two types of 

multiple land use conflicts: municipal/residential conflicts and multiple mineral 

development (coal versus oil and gas) conflicts. 

The West Antelope II LBA tract does not lie within or in proximity to an identified 

buffer zone surrounding an existing community. Therefore, no federal coal lands 

within the West Antelope II LBA tract have been eliminated from further 

consideration for leasing due to municipal/residential conflicts. 

The 2001 Buffalo RMP includes two decisions related to multiple mineral 

development conflicts in Campbell, Converse and Sheridan Counties. With 

1-14 Draft EIS, West Antelope II Coal Lease Application 
1.0 Introduction 

respect to oil and gas leasing in coal mining areas, the RMP update determines 

that oil and gas tracts that would interfere with coal mining operations would not 

be offered for lease but that, where possible, oil and gas leases will be issued with 

specific conditions to prevent a development conflict with coal mining operations. 

With respect to coal leasing in oil and gas fields, the 2001 Buffalo Update states 

that coal leasing in producing oil and gas fields would be deferred unless or until 

coal development would not interfere with the economic recovery of the oil and gas 

resources, as determined on a case by case basis. 

Both conventional and CBNG wells have been drilled within or around the West 

Antelope II LBA tract. BLM’s evaluation of the potential for conflict with the 

development of oil and gas resources within the LBA tract is included in the 

Mineral Resources discussion in Section 3.3 of this EIS. BLM’s policy and 

guidance on conflicts between surface coal mine and CBNG development is to 

optimize the recovery of both resources and ensure that the public receives a 

reasonable return, as explained in BLM Instruction Memorandum No. 2006-153 

(BLM 2006d). 

The fourth coal screening procedure requires consultation with surface owners 

who meet the criteria defined in the regulations at 43 CFR 3400.0-5 (gg) (1) and 

(2). Chapter 7 includes a definition of the term “qualified surface owner”, based 

on these regulations. Surface owner consultation was conducted as part of the 

coal screening analysis published in 2001 Buffalo RMP. Private surface owners in 

the Gillette coal development potential area (including Campbell County and 

northern Converse County) were provided the opportunity to express their 

preference for or against surface mining of federal coal under their private surface 

estate during that screening. At that time, no attempt was made to distinguish 

qualified surface owners and Appendix D of the 2001 Buffalo RMP states that “no 

area should be dropped from further consideration for leasing as a result of 

responses received from surface owners”. Therefore, no federal coal lands within 

the West Antelope II LBA tract have been eliminated from further consideration for 

leasing due to qualified surface owner conflicts at this time. The current surface 

ownership of the LBA tract is discussed in Section 1.1 of this chapter and in 

Section 3.11. BLM will review the current surface ownership in the tract that is 

considered for leasing prior to holding a lease sale for the tract. Surface owner 

consultation must be completed with any private surface owners who are 

determined to be qualified prior to holding a lease sale for the tract. 

In summary, the lands in the ACC coal lease application have been subjected to 

the four coal planning screens and determined acceptable for further 

consideration for leasing. Thus, a decision to lease the federal coal lands in this 

application would be in conformance with the current BLM Buffalo RMP, the BLM 

Casper RMP, and the TBNG RMP. 

Draft EIS, West Antelope II Coal Lease Application 1-15 
1.0 Introduction 

1.6 Consultation and Coordination 

Initial Involvement 

BLM received the West Antelope II coal lease application on April 6, 2005. The 

application was initially reviewed by the Division of Minerals and Lands at the 

BLM Wyoming State Office. The BLM ruled that the application and lands 

involved met the requirements of regulations governing coal leasing on application 

(43 CFR 3425). 

The BLM Wyoming State Director notified the Governor of Wyoming that ACC had 

filed a lease application with BLM for the West Antelope II LBA tract on April 13, 

2005. 

The PRRCT reviewed this lease application at a public meeting held on April 27, 

2005, in Gillette, Wyoming. ACC presented information about their existing mine 

and the pending lease application to the PRRCT at that meeting. The PRRCT 

recommended that the BLM continue to process this application. The major steps 

in processing an LBA are shown in Appendix C. 

The BLM published a Notice of Intent to Prepare an Environmental Impact 

Statement and Notice of Public Meeting in the Federal Register on October 17, 

2006. The publication served as public notice that the West Antelope II coal lease 

application had been received, announced the time and location of a public 

scoping meeting, and requested public comment on the application. Letters 

requesting public comment and announcing the time and location of the public 

scoping meeting were mailed to all parties on the distribution list. 

The BLM published a notice of public scoping meeting in the Gillette News-Record 

and in the Douglas Budget newspapers. The public scoping meeting was held on 

November 1, 2006 in Douglas, Wyoming. At the public meeting, the applicant 

orally presented information about their mine and their need for the coal. 

Chapter 5 provides a list of other federal, state, and local governmental agencies 

that were consulted in preparation of this EIS and the distribution list for this EIS. 

Issues and Concerns 

Issues and concerns that have been expressed by the public and government 

agencies relating to the potential impacts of leasing the West Antelope II LBA tract, 

specifically, and to previous coal lease applications in general include: 

• potential conflicts with existing conventional oil and gas development and 

existing and proposed CBNG development; 

• cumulative impacts of mineral development to all other resources; 

• validity and currency of resource data; 

• public access; 

1-16 Draft EIS, West Antelope II Coal Lease Application 
1.0 Introduction 

• potential impacts to threatened and endangered species and other species of 

concern; 

• potential air quality impacts (including cumulative impacts to visibility); 

• potential surface and groundwater quality and quantity impacts; 

• potential impacts of and possible mitigation for nitrogen oxide emissions 

resulting from blasting of coal and overburden; 

• the need to include reasonably foreseeable actions such as the construction 

and operation of the DM&E railroad and power plants in the cumulative 

analysis; 

• the need to address increasing coal production in the PRB in the cumulative 

analysis; 

• potential impacts on cultural and paleontological resources; 

• potential impacts to wetland resources; and 

• short- and long-term impacts on aquatic and terrestrial wildlife species. 

Draft EIS 

Parties on the distribution list were sent copies of this Draft EIS, and copies are 

available for review at the BLM offices in Casper and Cheyenne, Wyoming. The 

document is also available for review on the BLM Wyoming website at 

http://www.blm.gov/wy/st/en/info/NEPA/cfodocs/West_Antelope_II.html. 

A notice announcing the availability of the Draft EIS will be published in the 

Federal Register by the EPA. A 60-day comment period on the Draft EIS will 

commence with publication of the EPA’s notice of availability. The BLM will 

publish a Notice of Availability/Notice of Public Hearing in the Federal Register. 

The BLM’s Federal Register notice will announce the date and time of a public 

hearing to be held during the 60-day comment period. The purpose of the public 

hearing will be to solicit public comments on the Draft EIS and on the fair market 

value, the maximum economic recovery, and the proposed competitive sale of 

federal coal from the LBA tract. The BLM will also publish a notice of public 

hearing in the Gillette News-Record and in the Douglas Budget newspapers. 

Final EIS and Future Involvement 

All substantive written comments received on the Draft EIS will be included, with 

agency responses, in the Final EIS. Availability of the Final EIS will be published 

in the Federal Register by the BLM and the EPA. After a 30-day availability period, 

BLM will make a decision to hold or not to hold a competitive lease sale for the 

federal coal in the West Antelope II LBA tract. 

The USDA-FS must consent to leasing the federal coal underlying lands that they 

administer before BLM can make a decision to hold a federal coal lease sale. If 

any lands administered by the Forest Service are included in the tract that BLM 

considers for leasing, the USDA-FS will issue a separate ROD consenting to 

leasing those lands. The decision to consent to leasing the USDA-FS land can be 

appealed within 45 days from the date the USDA-FS ROD is issued. 

Draft EIS, West Antelope II Coal Lease Application 1-17 
1.0 Introduction 

A public ROD for the tract will be mailed to parties on the mailing list and others 

who commented on this EIS during the NEPA process. The public and/or the 

applicant can appeal the BLM decision to hold or not to hold a competitive sale 

and issue a lease for the tract. The BLM decision must be appealed within 30 

days from the date the Notice of Availability for the Record of Decision is published 

in the Federal Register. The decision can be implemented at that time if no appeal 

is received. If a competitive lease sale is held, the lease sale will follow the 

procedures set forth in 43 CFR 3422, 43 CFR 3425, and BLM Handbook H-3420-1 

(Competitive Coal Leasing). 

Department of Justice Consultation 

After a competitive coal lease sale, but prior to issuance of a lease, the BLM must 

solicit the opinion of the Department of Justice on whether the planned lease 

issuance creates a situation inconsistent with federal antitrust laws. The 

Department of Justice is allowed 30 days to make this determination. If the 

Department of Justice has not responded in writing within the 30 days, the BLM 

can proceed with issuance of the lease. 

1-18 Draft EIS, West Antelope II Coal Lease Application 
 

2.0 Proposed Action and Alternatives 

2.0 PROPOSED ACTION AND ALTERNATIVES 

This chapter describes the Proposed Action and alternatives to this action. The 

Proposed Action is to hold a competitive lease sale and issue a lease for the 

federal coal lands included in the West Antelope II LBA1 Tract as applied for by 

ACC. The proposed lease is contiguous with the existing Antelope Mine and 

would be mined as a maintenance lease for the existing Antelope Mine. 

Under the Proposed Action, the tract would be offered for lease as applied for at 

one competitive lease sale with sealed bids, subject to standard and special 

lease stipulations developed for the PRB and that tract. The boundaries of the 

tract would be consistent with the tract configuration proposed by the 

applicant. As applied for, the West Antelope II LBA tract consists of two noncontiguous blocks of federal coal. The Proposed Action assumes that the 

applicant would be the successful bidder on the tract, and that the tract would 

be mined as a maintenance lease for an existing mine. 

NEPA requires the consideration and evaluation of other reasonable ways to 

meet proposal objectives while minimizing or avoiding environmental impacts. 

Thus, NEPA requires the evaluation of a No Action Alternative and a practical 

range of other “reasonable” alternatives that may avoid or minimize project 

impacts. Reasonable alternatives are defined by NEPA as those that are 

technically, economically, and environmentally practical and feasible. 

Reasonable alternatives are formulated to address issues and concerns raised 

by the public and agencies during scoping. These alternatives should 

represent another means of satisfying the stated purpose and need for the 

federal action. 

Five alternatives to the Proposed Action are considered in this analysis: 

1) Reconfigure the tract and hold one competitive coal sale. 

2) Divide the tract as applied for or as reconfigured by BLM into two tracts 

and offer one or both for sale as separate competitive bids for each 

tract. 

3) Reject the application (No Action.) 

4) Assume that the applicant is not the successful bidder on the tract (as 

applied for or under Alternatives 1 or 2) and the coal is developed as a 

new mine. 

5) Delay the sale of tract (as applied for or under Alternatives 1 or 2). 

Alternatives 4 and 5 were considered but not analyzed in detail. The Proposed 

Action and all alternatives are discussed in greater detail in sections 2.1 

through 2.6. 

The BLM Competitive Coal Leasing Manual (BLM Manual 3420-1) requires the 

BLM to evaluate modifying the configuration of federal coal tracts based on 

1 Refer to page xv for a list of abbreviations and acronyms used in this document. 

Draft EIS, West Antelope II Coal Lease Application 2-1 
 

2.0 Proposed Action and Alternatives 

providing for maximum economic recovery of the coal resource, maintaining or 

increasing the potential for competition, and avoiding future bypass or captive 

tract situations. For NEPA purposes, BLM evaluates alternate tract 

configurations as alternatives to the Proposed Action. In evaluating this lease 

application, BLM has identified a study area for the tract which includes the 

tract as applied for and adjacent unleased federal coal, shown in Figure 2-1. 

The leasing on application regulations at 43 CFR 3425.1-9 state that: “The 

authorized officer may add or delete lands from an area covered by an 

application for any reason he/she determines to be in the public interest.” 

Accordingly, in evaluating alternative tract configurations, BLM could increase 

or decrease the size of the tract as applied for. 

Under Alternatives 1 and 2, the study area is evaluated for the purpose of 

identifying potential alternate tract configurations to the Proposed Action that 

would be technically, economically, or environmentally preferable to the 

Proposed Action. Under both alternatives, BLM is evaluating adding all or part 

of the additional coal included in the BLM study area to the tract as applied for 

and/or reducing the size of the tract as applied for. Under Alternative 1, one 

competitive sale would be held and a lease issued for federal coal lands 

included in an LBA tract as modified by the BLM. Under Alternative 2, BLM is 

evaluating splitting the application into two tracts (North Tract and South 

Tract). The lands included in the two tracts would be the lands included in the 

as-applied-for tract or the tract as modified by BLM. Two separate competitive 

sales would be held and two leases would be issued. The West Antelope II LBA 

tract as applied for (Proposed Action), the BLM study area (the tract as applied 

for and the additional area evaluated under Alternatives 1 and 2), and the two 

tracts formed under Alternative 2 are shown in Figure 2-1. 

The No Action Alternative (Alternative 3) is to reject the West Antelope II lease 

application. Under the No Action Alternative, the tract would not be offered for 

competitive sale, and the coal contained within the tract would not be mined as 

proposed. Rejection of the application would not affect currently permitted 

mining activities on existing leases at the Antelope Mine and selection of the No 

Action Alternative would not preclude an application to lease the rejected tract 

in the future. Portions of the surface of the LBA tract would probably be 

disturbed due to overstripping to allow coal to be removed from the adjacent 

existing leases. 

The alternatives considered but not analyzed in detail are: 

• holding a competitive lease sale and issuing a lease for federal coal lands 

included in the West Antelope II LBA tract (as applied for or as modified 

by BLM), with the assumption that the tract would be developed as a 

new mine (Alternative 4); and 

2-2 Draft EIS, West Antelope II Lease Application 
2.0 Proposed Action and Alternatives 

Campbell County 

Converse County 

B.N.S.F. & U.P RR 

North Antelope / Rochelle 

Rail Line 

Antelope Road 

County Road 37 

T. 

40 

N. 

R. 72 W. R. 70 W. 

T. 

41 

N. 

T. 

41 

N. 

R. 71 W. 

T. 

40 

N. 

R. 71 W. 

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

7 8 9

8 9 8

7 8 

7 7

9 

1 

5 4 3 2 1 5

9 

6 6

1 6 4 3 2 1 6 5

4 

5 

11 

12 

22 

11 

27 

13 

24 

15 

24 

10 

4 

20 

26 

18 

19 

17 

30 

20 21 

29 

23 

15 

14 

29 28 

24 

14 13 

16 

12 

23 22 

30 

12 

13 17

16 

20 

25 

19 

17 18 

32 

17 

34 

10 

21 

18 

19 

13 

31 32 31

12 

33 35 

18 

36 

19 20

25 

24 

36 

28 

33 

21 

16 

21 

16 

25 30 29 28 27 26 25 30 29 28 

2 

11 

14 

23 

26 

!(59 

£ 0 8,000 16,000 

GRAPHIC SCALE (FEET) 

Figure 2-1. West Antelope II LBA Alternative Tract Configurations. 

LEGEND 

Antelope Mine Permit Boundary 

Existing Antelope Mine Federal Coal Leases 

State Coal Lease 

West Antelope II LBA Tract As Applied For 

Area Added under Alternative 1 

North Tract (Alternative 2) 

South Tract (Alternative 2) 

Draft EIS, West Antelope II Coal Lease Application 2-3
 

2.0 Proposed Action and Alternatives 

• delaying the sale of the West Antelope II LBA tract as applied for in order 

to take advantage of higher coal prices and/or to allow recovery of the 

potential CBNG resources in the tract prior to mining (Alternative 5). 

Under this alternative, it is assumed that the tract could be developed 

later as a maintenance tract or a new mine start, depending on how long 

the sale was delayed. 

LBA tracts are nominated for leasing by companies with an interest in 

acquiring them but, as discussed in Chapter 1, the LBA process is, by law and 

regulation, an open, public, competitive sealed-bid process. If a tract is offered 

for lease, the applicant for that tract may or may not be the high bidder when 

the lease sale is held. The Proposed Action and Alternatives 1 and 2 

considered in this EIS assume ACC would be the successful bidder if the 

federal coal included in the tract is offered for lease, and that the West 

Antelope II LBA tract would be mined as a maintenance tract for the permitted 

Antelope Mine. 

If a decision is made to hold a competitive lease sale for a tract of federal coal 

and a lease is issued, the lessee must obtain a permit to conduct coal mining 

operations before mining can begin on the tract. As discussed in Section 1.3, 

this permit application would undergo detailed review by state and federal 

agencies as part of the approval process. The detailed permit application could 

potentially differ from the more general mining plan used to analyze the 

impacts of the Proposed Action and Alternatives 1 and 2 in this EIS, but the 

differences would not be expected to substantially change the impacts 

described here. These differences would typically be related to the details of 

mining and reclaiming the tract but major factors, like the approximate 

number of tons of coal to be mined and yards of overburden to be removed, the 

acres disturbed, etcetera, would not be substantially different from the plans 

used in this analysis. 

If the tract is leased under the Proposed Action or Alternatives 1 and 2, it is 

assumed that an area larger than the lease area would have to be disturbed in 

order to recover all of the coal in that tract. The disturbances outside the coal 

removal area would be due to activities like overstripping, matching 

undisturbed topography, and construction of flood control and sediment 

control structures. 

2.1 Proposed Action 

Under the Proposed Action, the West Antelope II LBA tract, as applied for by 

ACC, would be offered for lease at a sealed-bid, competitive lease sale, subject 

to standard and special lease stipulations developed for the PRB (Appendix D). 

The boundaries of the tract would be consistent with the tract configuration 

proposed in the West Antelope II lease application (Figure 2-1). The Proposed 

Action assumes that ACC will be the successful bidder on the West Antelope II 

LBA tract if it is offered for sale. 

2-4 Draft EIS, West Antelope II Lease Application 
 

 

 

 

 

 

 

 

 

 

2.0 Proposed Action and Alternatives 

The legal description of the proposed West Antelope II LBA tract coal lease 

lands as applied for by ACC under the Proposed Action is as follows: 

T.41N., R.71W., 6th P.M., Campbell County, Wyoming 

Section 9: Lots 9 through 16: 330.68 acres 

Section 10: Lots 11 through 15: 203.00 acres 

Section 14: Lots 3 and 4: 82.64 acres 

Section 15: Lots 1 through 5, 12, and 13: 289.35 acres 

Section 20: Lots 14 through 16: 122.89 acres 

Section 21: Lots 1 through 16: 651.74 acres 

Section 22: Lots 2, 7, 8, and 14 through 16: 252.93 acres 

Section 27: Lots 6 through 11: 250.51 acres 

Section 28: Lots 1 through 8: 322.50 acres 

Section 29: Lots 1 through 3 and 6 through 8: 247.76 acres 

T.40N., R.71W., 6th P.M., Converse County, Wyoming 

Section 5: Lot 18: 40.25 acres 

Section 8: Lots 1 through 3, 6 through 11, and 14 through 16: 478.14 acres 

Section 9: Lots 2 through 16: 597.22 acres 

Section 10: Lots 5, 6, and 11 through 14: 238.99 acres 

Total: 4,108.60 acres 

The land descriptions and acreage are based on the BLM Status of Public 

Domain Land and Mineral Titles approved Coal Plats as of April 15, 2004 and 

December 6, 2004. The coal estate included in the tract described above is 

federally owned. The ownership of the surface and oil and gas estates is 

discussed in Section 3.11. 

As discussed in Section 1.5, the BNSF & UP railroad crosses portions of the 

northern block of federal coal included in the West Antelope II LBA tract 

(Figure 2-1), and the coal that is located within the BNSF & UP ROW and an 

associated 100 foot buffer zone has been determined to be unsuitable for 

mining under Unsuitability Criterion 2. As a result, some of the coal in the 

above described lands is not currently considered to be recoverable. Although 

these lands would not be mined, they are included in the tract to allow 

maximum recovery of all of the mineable coal that is adjacent to but outside of 

the railroad ROW and its associated buffer zone and to comply with the coal 

leasing regulations that do not allow leasing of less than 10-acre aliquot parts. 

As applied for, the West Antelope II LBA tract consists of two separate blocks of 

federal coal (Figure 2-1), which includes approximately 4,108.6 acres with an 

estimated 465.1 million tons of in-place coal reserves. ACC estimates that 1.4 

million tons of the in-place coal would not be mineable because of the BNSF & 

UP railroad tracks and associated ROW. Of the 463.7 million tons of mineable 

reserves, ACC estimates that approximately 429.5 million tons would be 

recoverable from the West Antelope II LBA tract as applied for. This estimate of 

recoverable reserves assumes that approximately seven to nine percent of the 

Draft EIS, West Antelope II Coal Lease Application 2-5 
2.0 Proposed Action and Alternatives 

mineable coal included within the West Antelope II LBA tract would not be 

recoverable under normal mining practices, based on historical recovery 

factors. 

BLM independently evaluates the volume and average quality of the coal 

resources included in proposed LBA tracts as part of the fair market value 

determination process. BLM’s estimate of the mineable federal coal reserves 

included in the tract may not be in agreement with the mineable coal reserve 

and coal quality estimates provided by the applicant. BLM’s estimate of the 

mineable federal coal reserves included in the tract will be included in the Final 

EIS and published in the sale notice if the tract is offered for sale. 

The West Antelope II LBA tract would be mined as an integral part of the 

Antelope Mine under the Proposed Action. The West Antelope II LBA tract 

would be an extension of the existing Antelope Mine, the facilities and 

infrastructure would be the same as those identified in the WDEQ/LQD Mine 

Permit 525 Term T7 approved October 29, 2003 and the BLM R2P2, which was 

approved November 8, 2006. 

The currently approved air quality permit from the WDEQ/AQD for the 

Antelope Mine allows up 42 million tons of coal per year to be mined. The 

Antelope Mine produced: 

• 23.0 million tons of coal in 2000, 

• 24.6 million tons of coal in 2001, 

• 26.8 million tons of coal in 2002, 

• 29.5 million tons of coal in 2003, 

• 29.7 million tons of coal in 2004, 

• 30.0 million tons of coal in 2005, and 

• 33.9 million tons of coal in 2006 

(Antelope Mine 2000, 2001, 2002, 2003, 2004, 2005, and 2006). 

Under the currently approved mining plan (the No Action Alternative), the 

Antelope Mine would mine its remaining estimated 394.3 million tons of 

recoverable coal reserves in eleven years at an average production rate of 

approximately 36 mmtpy. Under the Proposed Action, ACC estimates that the 

life of the mine would be extended by 12 additional years at an average annual 

coal production rate of approximately 36 million tons. If the production rate 

increases to 42 mmtpy, the maximum rate allowed by the air quality permit, 

the life of mine would be extended by ten additional years under the Proposed 

Action. 

If ACC acquires the West Antelope II LBA tract as applied for, they estimate 

that a total of 823.8 million tons of coal would be recovered after January 1, 

2007, with an estimated 429.5 million tons coming from the LBA tract. As of 

December 31, 2006, approximately 318.9 million tons of coal had been mined 

from within the current permitted area of the mine. 

2-6 Draft EIS, West Antelope II Lease Application 
2.0 Proposed Action and Alternatives 

Prior to disturbance and in advance of mining, mine support structures such 

as roads, power lines, substations, and flood and sediment control measures 

would be built as needed. 

Topsoil removal with suitable heavy equipment, such as rubber-tired scrapers, 

would proceed ahead of overburden removal. Whenever possible, direct 

haulage to a reclamation area would be done, but due to scheduling, some 

topsoil would be temporarily stockpiled. As required by the reclamation plan, 

heavy equipment again would be used to haul and distribute the stockpiled 

topsoil. 

The Antelope Mine is one of several mines currently operating in the PRB. 

Mining would be conducted in five separate, semi-independent pits identified 

as the Horse Creek (HC) Pit, North West Mine Area North (NWMAN) Pit, South 

Mine Area (SMA) Pit, West Antelope South (WAS) Pit, and West Antelope North 

(WAN) Pit. The multi-pit concept has been and would be utilized to reduce 

operating costs by blending production from areas having different stripping 

ratios and coal quality, and also to help stabilize manpower requirements. 

Overburden removal has been and would continue to be conducted using 

trucks and shovels, draglines, and/or direct cast blasting. Other equipment 

used during overburden removal and backfilling would include dozers, 

scrapers, excavators, front-end loaders, graders, and water trucks. Most 

overburden and all coal have been and would continue to be drilled and blasted 

to facilitate efficient excavation. 

The design of the Antelope Mine seeks to confine disturbance to the active mine 

blocks. As overburden is removed, most would be directly placed into areas 

where coal has already been removed. 

Once the overburden has been replaced it is sampled and verified to be suitable 

for reclamation, then graded to approximate final contour, ripped and finally 

topsoiled. Material that is found to be unsuitable for reclamation (i.e., material 

that is not suitable for use in reestablishing vegetation or that may affect 

groundwater quality due to high concentrations of certain constituents, such 

as selenium, or adverse pH levels) would either be removed and treated, or 

adequately covered with suitable overburden material prior to grading and 

topsoiling. Elevations consistent with an approved PMT plan would be 

established as quickly as possible. Under certain conditions, the PMT may not 

be immediately achievable. This occurs when there is an excess of material 

that may require temporary stockpiling, when there is insufficient material 

available from current overburden removal operations, or when future mining 

could redisturb an area already mined. Once a seedbed has been formed, 

vegetation that is consistent with the postmining land use would be 

reestablished. 

Coal would be produced from two coal seams. ACC refers to these seams as the 

Anderson, which averages 34 ft thick, and the Canyon, which averages 35 ft 

thick. Coal would be mined at several working faces to enable blending of the 

Draft EIS, West Antelope II Coal Lease Application 2-7 
2.0 Proposed Action and Alternatives 

coal to meet customer quality requirements, to comply with BLM lease 

requirements for maximum economic recovery of the coal resource, and to 

optimize coal removal efficiency with available equipment. Coal would be 

loaded with electric-powered shovels into off-highway haul trucks for transport 

to crushing facilities. Coal haul roads would be temporary structures built 

within the mine areas. The Antelope Mine utilizes two separate, existing coal 

crushing facilities; the North East Mine Area and South Mine Area pit facilities 

located within the ACC permit area. These facilities provide the capacity to 

produce the permitted production tonnage. All coal crushing operations and 

conveying, transferring, and storage facilities are equipped with passive 

emission controls, atomizer/fogger systems or bag house collection systems for 

dust control. There are two existing coal storage silos. While sufficient storage 

capacity exists, future changes in facilities may be constructed to improve 

operating efficiency and air quality protection. For example, a covered slot 

storage barn, additional silos, covered dome, or other appropriate storage 

structure may be built at the plant. In addition, a covered overland conveyor 

and near-pit crusher system may be constructed and moved as the mining 

operation progresses away from the plant facilities. 

The Antelope Mine presently has a workforce of 430 employees. The expansion 

in reserves associated with the West Antelope II LBA tract under the Proposed 

Action would sustain current rates of production [about 36 mmtpy), and as 

many as 25 additional workers may be needed at times during the life-of-mine 

as mining progresses to different locations. Raising annual production to 42 

mmtpy could increase the incremental workforce needs to as many 40 workers, 

or 470 total employees, at times. 

2.1.1 Regulatory Compliance, Mitigation and Monitoring 

SMCRA and Wyoming State Law require surface coal mines to collect extensive 

baseline information and implement extensive monitoring programs and 

mitigation measures. The currently approved permit to conduct mining 

operations for the Antelope Mine includes these requirements. Monitoring 

programs and mitigation measures that are required by regulation are 

considered to be part of the Proposed Action and the Action Alternatives 

considered in this EIS for the West Antelope II LBA tract. These data collection 

requirements, mitigation plans, and monitoring plans are in place for the No 

Action Alternative, as part of the current approved permit to conduct mining 

operations for the existing Antelope Mine. These data collection requirements, 

mitigation plans, and monitoring commitments would be extended to include 

mining operations on the West Antelope II LBA tract if it is leased and 

permitted for mining. A permit to conduct mining operations on the West 

Antelope II LBA tract would have to be approved before mining operations 

could be conducted on the tract, regardless of who acquires it. The major 

mitigation and monitoring measures that are required by state or federal 

regulation are summarized in Table 2-1. More specific information about some 

of these mitigation and monitoring measures and their results at the Antelope 

Mine are described in Chapter 3. 

2-8 Draft EIS, West Antelope II Lease Application 
2.0 Proposed 

Table 2-1. Regulatory Compliance, Mitigation and Monitoring Measures for Surface Coal Mining 

Required by SMCRA and State Law for all Alternatives. 

Regulatory Compliance or Mitigation Required by 

Resource Stipulations, State or Federal Law1 

Topography & Physiography Geology & Minerals Soil Air Quality 

Restoring to approximate original contour or other approved topographic configuration.
 

Identifying & selectively placing or mixing chemically or physically unsuitable
 overburden materials to minimize adverse effects to vegetation or groundwater.
 Salvaging soil suitable to support plant growth for use in reclamation; Protecting soil stockpiles from disturbance and erosional influences; Selectively placing at least four ft of suitable overburden on the graded backfill surface
 below replaced topsoil to meet guidelines for vegetation root zones.
 Dispersion modeling of mining plans for annual average particulate pollution impacts on ambient air; Using particulate pollution control technologies; Using work practices designed to minimize fugitive particulate emissions; Using EPA- or state-mandated BACT, including: 

Fabric filtration or wet scrubbing of coal storage silo and conveyor vents, Watering or using chemical dust suppression on haul roads and exposed soils, Containment of truck dumps and primary crushers, Covering of conveyors, Prompt revegetation of exposed soils, 

High efficiency baghouse dust collection systems or PECs, or atomizers/foggers on 

the crusher, conveyor transfer, storage bin and train loadout, meeting a standard of 0.01 grains per dry standard cubic foot (dscf) of exit volume, 

Watering of active work areas, 

Reclamation plan to minimize surface disturbances subject to wind erosion, 

Paving of access roads, 

Haul truck speed limits, Limited material drop heights for shovels and draglines. 

WDEQ/LQD approved topannual reporWDEQ/LQD advance of munsuitable oMonitoring vreclaimed arsoil amendmSampling regcompliance wOn-site air qPM10 and/or 

Off-site amband/or TSP; On-site comp

These requirements, mitigation plans, and monitoring plans are in place for the existing Antelope Mine in its current approved mining and reclaAlternative). If the West Antelope II LBA tract were leased, these requirements, mitigation plans, and monitoring plans would be part of a minin

West Antelope II LBA tract that must be approved before mining can occur on the tract under the Proposed Action or Action Alternatives. 

Draft EIS, West Antelope II Coal Lease Application 

1 
2.0 Proposed Action and Alternatives 

Table 2-1. Regulatory Compliance, Mitigation and Monitoring Measures for Surface Coa

Required by SMCRA and State Law for all Alternatives (Continued). 

Resource 

Air Quality (continued) 

Regulatory Compliance or Mitigation Required by 

Stipulations, State or Federal Law1 

Following voluntary and required measures to avoid exposing the public to NO2 

from blasting clouds, including: 

Phone notification of neighbors and workers prior to blasting, Monitoring weather and atmospheric conditions prior to decisions to blast, 

Timing blasts to avoid temperature inversions and to minimize inconvenience to neighbors, 

Closing public roads when appropriate to protect the public, Minimizing blast sizes, Posting signs on major public roads. 

Surface Water Building and maintaining sediment control ponds or other devices during mining; 

Restoring approximate original drainage patterns during reclamation; Restoring stock ponds and playas during reclamation. 

Monitorinsediment MonitorinMonitorinquality. 

Groundwater Quantity Evaluating cumulative impacts to water quantity associated with proposed mining; 

Replacing existing water rights that are interrupted, discontinued, or diminished by mining with water of equivalent quantity. 

Monitorinoverburdunderbur

Groundwater Quality 

Evaluating cumulative impacts to water quality associated with proposed mining; Replacing existing water rights that are interrupted, discontinued, or diminished by mining with water of equivalent quality. 

Monitorinin overbuunderbur

Alluvial Valley Floors 

Identifying all AVFs that would be affected by mining; Determining significance to agriculture of all identified AVFs affected by mining (WDEQ); Protecting downstream AVFs during mining; Restoring essential hydrologic function of all AVFs affected by mining. 

Monitorinof essentany decla

Wetlands Identifying all wetlands that would be affected by mining; 

Identifying jurisdictional wetlands (COE); Replacing all jurisdictional wetlands that would be disturbed by mining; Replacing functional wetlands as required by surface managing agency, surface landowner, or WDEQ/LQD. 

Monitorinusing samidentify pwetlands

These requirements, mitigation plans, and monitoring plans are in place for the existing Antelope Mine in its current approved mining and recAlternative). If the West Antelope II LBA tract were leased, these requirements, mitigation plans, and monitoring plans would be part of a min

West Antelope II LBA tract that must be approved before mining can occur on the tract under the Proposed Action or Action Alternatives. 

2-10 Draft EIS, West Antelo

1 
2.0 Proposed 

Table 2-1. Regulatory Compliance, Mitigation and Monitoring Measures for Surface Coal 

Required by SMCRA and State Law for all Alternatives (Continued). 

Regulatory Compliance or Mitigation Required by 

Resource Stipulations, State or Federal Law1 

Vegetation	 Permanently revegetating reclaimed areas according to a comprehensive revegetation 

plan using approved permanent reclamation seed mixtures consisting predominantly of species native to the area; Reclaiming 20 percent of reclaimed area with native shrubs at a density of one per square meter; Controlling erosion on reclaimed lands prior to seeding with final seed mixture using mulching, cover crops, or other approved measures; Chemically and mechanically controlling weed infestation; Direct hauling of topsoil; Selectively planting shrubs in riparian areas; Planting sagebrush; Creating depressions and rock piles; Using special planting procedures around rock piles; Posting reclamation bond covering the cost of reclamation. 

Monitorindiversity ureclamatioyears); Monitorinneed for cestablishmUse of conrevegetatisuitability 

Wildlife and Sensitive Species 

Restoring pre-mining topography to the maximum extent possible; Planting a diverse mixture of grasses, forbs, and shrubs in configurations beneficial to wildlife; Designing fences to permit wildlife passage; 

Baseline amonitorinMonitorinof Manage

Raptor-proofing power transmission poles; Using raptor safe power lines; Creating artificial raptor nest sites; Increasing habitat diversity by creating rock clusters and shallow depressions on reclaimed land; Cottonwood plantings along reclaimed drainages; Replacing drainages, wetlands, and AVFs disturbed by mining; Reducing vehicle speed limits to minimize mortality; Instructing employees not to harass or disturb wildlife; Following approved raptor mitigation plans; Avoiding bald eagle disturbance; Restoring bald eagle foraging areas disturbed by mining; Restoring mountain plover habitat disturbed by mining; Surveying for mountain plover; Surveying for black-tailed prairie dog. 

These requirements, mitigation plans, and monitoring plans are in place for the existing Antelope Mine in its current approved mining and recAlternative). If the West Antelope II LBA tract were leased, these requirements, mitigation plans, and monitoring plans would be part of a min

West Antelope II LBA tract that must be approved before mining can occur on the tract under the Proposed Action or Action Alternatives. 

Draft EIS, West Antelope II Coal Lease Application 

1 
2.0 Proposed Action and Alternatives 

Table 2-1. Regulatory Compliance, Mitigation and Monitoring Measures for Surface Coal 

Required by SMCRA and State Law for all Alternatives (Continued). 

Regulatory Compliance or Mitigation Required by 

Resource Stipulations, State or Federal Law1 

Threatened, Endangered, Surveying for Ute ladies'-tresses; Baseline Proposed, Searching for black-footed ferrets if prairie dog colonies are on or move onto tract; monitorinand Candidate Same as Wildlife Resource and Sensitive Species above. Species Land Use Suitably restoring reclaimed area for historic uses (grazing and wildlife); Monitorin

prior to b

Cultural Conducting Class I & III surveys to identify cultural properties on all state and federal MonitorinResources lands and on private lands affected by federal undertakings; during to

Consulting with SHPO to evaluate eligibility of cultural properties for the NRHP; of activitiAvoiding or recovering data from significant cultural properties identified by surveys, authoritiaccording to an approved plan; encounteNotifying appropriate federal personnel if historic or prehistoric materials are uncovered during mining operations; Instructing employees of the importance of and regulatory obligations to protect cultural resources. 

Native Notifying Native American tribes with known interest in this area of leasing action and No specifAmerican request for help in identifying potentially significant religious or cultural sites. Concerns Paleontological Notifying appropriate federal personnel if potentially significant paleontological sites are No specifResources discovered during mining. Visual Restoring landscape character during reclamation through return to approximate No specifResources original contour and revegetation with native species. Noise Protecting employees from hearing loss. MSHA inTransportation Facilities Relocating existing pipelines, if necessary, in accordance with specific agreement No specif

between pipeline owner and coal lessee. 

Socioeconomics Paying royalty and taxes as required by federal, state, and local regulations. Surveyin

No mitigation measures are proposed. documen

These requirements, mitigation plans, and monitoring plans are in place for the existing Antelope Mine in its current approved mining and recAlternative). If the West Antelope II LBA tract were leased, these requirements, mitigation plans, and monitoring plans would be part of a mini

West Antelope II LBA tract that must be approved before mining can occur on the tract under the Proposed Action or Action Alternatives. 

2-12 Draft EIS, West Antelo

1 
1 

2.0 Proposed 

Table 2-1. Regulatory Compliance, Mitigation and Monitoring Measures for Surface Coa

Required by SMCRA and State Law for all Alternatives (Continued). 

Regulatory Compliance or Mitigation Required by 

Resource Stipulations, State or Federal Law1 

Hazardous & Solid Waste Disposing of solid waste and sewage within permit boundaries according to approved No specifi

plans; required bStoring and recycling waste oil; and respoMaintaining of files containing Material Safety Data Sheets for all chemicals, compounds, and/or substances used during course of mining; Ensuring that all production, use, storage, transport, and disposal of hazardous materials is in accordance with applicable existing or hereafter promulgated federal, state, and government requirements; Complying with emergency reporting requirements for releases of hazardous materials as established in CERCLA, as amended; Preparing and implementing spill prevention control and countermeasure plans, spill response plans, inventories of hazardous chemical categories pursuant to Section 312 of SARA, as amended; Preparing emergency response plans. 

These requirements, mitigation plans, and monitoring plans are in place for the existing Antelope Mine in its current approved mining and recAlternative). If the West Antelope II LBA tract were leased, these requirements, mitigation plans, and monitoring plans would be part of a mini

West Antelope II LBA tract that must be approved before mining can occur on the tract under the Proposed Action or Action Alternatives. 

Draft EIS, West Antelope II Coal Lease Application 
 

 

2.0 Proposed Action and Alternatives 

If impacts are identified during the leasing process that are not mitigated by 

existing required mitigation measures, BLM can require additional mitigation 

measures, in the form of stipulations on the new lease, within the limits of its 

regulatory authority. In general, the levels of mitigation and monitoring 

required for surface coal mining by SMCRA and Wyoming State law are more 

extensive than those required for other surface disturbing activities; however, 

concerns are periodically identified that are not monitored or mitigated under 

existing procedures. 

2.1.2 Hazardous and Solid Waste 

Under the Proposed Action and Action Alternatives, the procedures and 

requirements for handling of solid and hazardous wastes would be the same as 

the procedures and requirements for the existing mining operation. Solid 

waste that is produced at the existing Antelope Mine consists of floor 

sweepings, shop rags, lubricant containers, welding rod ends, metal shavings, 

worn tires, packing material, used filters, and office and food wastes. A portion 

of the solid wastes produced at the Antelope Mine is disposed of within the 

mine’s permit boundary in accordance with WDEQ-approved solid waste 

disposal plans. Solid waste is also disposed of at the Campbell County landfill. 

Sewage is handled by WDEQ-permitted sewage systems present on the existing 

mine facilities. Maintenance and lubrication of most of the equipment takes 

place at existing shop facilities at the Antelope Mine. Major lubrication, oil 

changes, etcetera, of most equipment are performed inside the service building 

lubrication bays at the Antelope Mine, where used oil and grease are currently 

contained and deposited in storage tanks. All of the collected used oils and 

grease are then beneficially recycled off site or used for energy recovery. These 

practices would not change if the applicant acquires the LBA tract. 

Antelope Mine has reviewed the EPA’s Consolidated List of Chemicals Subject to 

Reporting Under Title III of the Superfund Amendments and Re-authorization Act 

(SARA) of 1986 (as amended) and EPA’s List of Extremely Hazardous 

Substances as defined in 40 CFR 355 (as amended) for hazardous substances 

used at the Antelope Mine. ACC maintains files containing Material Safety 

Data Sheets for all chemicals, compounds, and/or substances that are or 

would be used during the course of mining. 

Antelope Mine is responsible for ensuring that all production, use, storage, 

transport, and disposal of hazardous and extremely hazardous materials as a 

result of mining are in accordance with all applicable existing or hereafter 

promulgated federal, state, and local government rules, regulations, and 

guidelines. All mining activities involving the production, use, and/or disposal 

of hazardous or extremely hazardous materials are and would continue to be 

conducted so as to minimize potential environmental impacts. 

Antelope Mine must comply with emergency reporting requirements for 

releases of hazardous materials. Any release of hazardous or extremely 

hazardous substances in excess of the reportable quantity, as established in 40 

2-14 Draft EIS, West Antelope II Coal Lease Application 
 

 2.0 Proposed Action and Alternatives 

CFR 117, is reported as required by CERCLA, as amended. The materials for 

which such notification must be given are the extremely hazardous substances 

listed in Section 302 of the Emergency Planning and Community Right to Know 

Act and the hazardous substances designated under Section 102 of CERCLA, 

as amended. If a reportable quantity of a hazardous or extremely hazardous 

substance is released, immediate notice must be given to the WDEQ Solid and 

Hazardous Waste Division, WDEQ Water Quality Division, and all other 

appropriate federal and state agencies. 

Each mining company is expected to prepare and implement several plans 

and/or policies to ensure environmental protection from hazardous and 

extremely hazardous materials. These plans/policies include: 

• Spill Prevention Control and Countermeasure Plans; 

• Spill Response Plans; 

• Stormwater Pollution Prevention Plans; 

• Inventories of Hazardous Chemical Categories Pursuant to Section 313 of 

SARA, as Amended; and 

• Emergency Response Plans. 

All mining operations are also required to be in compliance with regulations 

promulgated under the Resource Conservation and Recovery Act, Federal 

Water Pollution Control Act (Clean Water Act), Safe Drinking Water Act, Toxic 

Substances Control Act, Mine Safety and Health Act, Department of 

Transportation, and the Federal Clean Air Act. In addition, mining operations 

must comply with all attendant state rules and regulations relating to 

hazardous material reporting, transportation, management, and disposal. 

Compliance with these rules is the current practice at the Antelope Mine. 

Acquisition of the West Antelope II LBA tract by ACC would not change these 

current practices nor the type and quantity of any wastes generated and 

disposed of by the mine. 

2.2 Alternative 1 

Under Alternative 1 for the West Antelope II LBA tract, BLM would reconfigure 

the tract and hold one competitive coal sale for the lands included in the 

reconfigured tract and issue a lease to the successful bidder. The modified 

tract would be subject to standard and special lease stipulations developed for 

the PRB and for this tract if it is offered for sale. Alternative 1 for the West 

Antelope II LBA tract assumes that ACC would be the successful bidder on the 

tract if a lease sale is held and that the federal coal would be mined as a 

maintenance lease for the existing Antelope Mine. Assumptions concerning 

mining methods, facilities, hazardous materials, mitigation and monitoring 

requirements, etc. are the same as described for the Proposed Action. 

As applied for, the West Antelope II LBA tract consists of two non-contiguous 

blocks of federal coal. In order to evaluate the potential that an alternate 

Draft EIS, West Antelope II Coal Lease Application 2-15 
 

 

 

2.0 Proposed Action and Alternatives 

configuration of the tract would provide for more efficient recovery of the 

federal coal, increase competitive interest in the West Antelope II LBA tract, 

and/or reduce the potential that some of the remaining unleased federal coal in 

this area would be bypassed in the future, BLM identified a study area. The 

BLM study area includes the tract as applied for and unleased federal coal 

adjacent to the northeastern, western, and southern edges of the tract as 

applied for (Figure 2-1). The study area includes lands on the TBNG, which is 

administered by USDA-FS. Under Alternative 1, the BLM could add all or part 

of the adjacent lands to the tract or BLM could reduce the size of the tract, as 

discussed in Section 2.0. 

The area BLM is evaluating adding to the tract as applied for includes the 

following lands: 

T.41N., R.71W., 6th P.M., Campbell County, Wyoming 

Section 10: Lots 9, 10, and 16: 123.42 acres 

Section 11: Lots 13 and14: 85.03 acres 

Section 20: Lots 9 through 13: 204.29 acres 

Section 29: Lots 4 and 5: 81.71 acres 

T.41N., R.71W., 6th P.M., Converse County, Wyoming 

Section 29: Lots 12 and 13: 81.09 acres 

Section 32: Lots 4, 5, 12, and 13: 162.36 acres 

T.40N., R.71W., 6th P.M., Converse County, Wyoming 

Section 5: Lots 8, 9, 16, and 17: 119.54 acres 

Section 8: Lots 4, 5, 12, and13: 159.52 acres 

Section 14: Lot 13: 39.99 acres 

Section 15: Lots 2 through 7, and 10 through 16: 514.01 acres 

Section 17: Lots 1 through 16: 629.62 acres 

Total: 2,200.58 acres 

The legal description of the Alternative 1 reconfiguration of the West Antelope II 

LBA tract is as follows: 

T.41N., R.71W., 6th P.M., Campbell County, Wyoming 

Section 9: Lots 9 through 16: 330.68 acres 

Section 10: Lots 9 through 16: 326.42 acres 

Section 11: Lots 13 and14: 85.03 acres 

Section 14: Lots 3 and 4: 82.64 acres 

Section 15: Lots 1 through 5, 12, and 13: 289.35 acres 

Section 20: Lots 9 through 16: 327.18 acres 

Section 21: Lots 1 through 16: 651.74 acres 

Section 22: Lots 2, 7, 8, and 14 through 16: 252.93 acres 

Section 27: Lots 6 through 11: 250.51 acres 

Section 28: Lots 1 through 8: 322.50 acres 

Section 29: Lots 1 through 8: 329.47 acres 

2-16 Draft EIS, West Antelope II Coal Lease Application 
 

 

 

 

 

 2.0 Proposed Action and Alternatives 

T.41N., R.71W., 6th P.M., Converse County, Wyoming 

Section 29: Lots 12 and 13: 81.09 acres 

Section 32: Lots 4, 5, 12, and 13: 162.36 acres 

T.40N., R.71W., 6th P.M., Converse County, Wyoming 

Section 5: Lots 8, 9, and 16 through 18: 159.79 acres 

Section 8: Lots 1 through 16: 637.66 acres 

Section 9: Lots 2 through 16: 597.22 acres 

Section 10: Lots 5, 6, and 11 through 14: 238.99 acres 

Section 14: Lot 13: 39.99 acres 

Section 15: Lots 2 through 7, and 10 through 16: 514.01 acres 

Section 17: Lots 1 through 16: 629.62 acres 

Total: 6,309.18 acres 

The land descriptions and acreage are based on the BLM Status of Public 

Domain Land and Mineral Titles approved Coal Plats as of April 15, 2004 and 

December 6, 2004. The coal estate in the tract described above is federally 

owned. The ownership of the surface and oil and gas estates is discussed in 

Section 3.11. 

As discussed in Sections 1.5 and 2.1, under the Proposed Action, the BNSF & 

UP railroad crosses portions of the northern block of federal coal included in 

the West Antelope II LBA tract (Figure 2-1). The coal that is located within the 

BNSF and UP railroad ROW and associated 100 foot buffer zone has been 

determined to be unsuitable for mining under Coal Unsuitability Criterion 2 

and would not be recoverable. 

As discussed in Section 1.5 and shown in Figure 2-1, State Highway 59 crosses 

the southwestern corner of the BLM study area for the south block of the tract, 

and Converse County Road 37 crosses the southeastern corner of the BLM 

study area for the south block of the tract, in Sections 17 and 14, T. 40 N., R. 

71 W., respectively. BLM has determined that the coal underlying these 

portions of State Highway 59 and Converse County Road 37, their ROWs, and 

a buffer zone extending 100 feet on either side of the ROWs are unsuitable for 

mining in accordance with Coal Unsuitability 3 and would not be recoverable. 

ACC estimates that the BLM study area under Alternative 1 contains 

approximately 490 million tons of mineable coal and that approximately 453.9 

million tons of that coal would be recoverable. ACC estimates that 

approximately 36 million tons of coal would not be mineable because of the 

railroad and public road ROWs and buffer zones. Although these lands would 

not be mined, they would be included in the alternative tract configuration to 

allow maximum recovery of all of the mineable coal that is adjacent to but 

outside of the ROWs and associated buffer zones and to comply with the coal 

leasing regulations that do not allow leasing of less than 10-acre aliquot parts. 

If a lease is issued for this tract, stipulations will be attached to the lease 

stating that no mining activity may be conducted in the portions of the leased 

Draft EIS, West Antelope II Coal Lease Application 2-17 
2.0 Proposed Action and Alternatives 

within the BNSF & UP railroad, State Highway 59, and Converse County Road 

37 ROWs and associated buffer zones. 

BLM independently evaluates the volume and average quality of the coal 

resources included in proposed LBA tracts as part of the fair market value 

determination process. BLM’s estimate of the mineable federal coal reserves 

included in the tract may not be in agreement with the mineable coal reserve 

and coal quality estimates provided by the applicant. BLM’s estimate of the 

mineable federal coal reserves included in the tract will be included in the Final 

EIS and published in the sale notice if the tract is offered for sale. 

Under Alternative 1 at an average annual coal production of 36 million tons, 

ACC estimates the life of the mine would be extended by 13 years. The average 

number of full-time employees could increase by as many as 25 additional 

workers (to approximately 455 employees). Raising annual production to 42 

million tons could increase the incremental workforce needs to as many 40 

workers, or 470 total employees, at times. The life of mine would be extended 

by 11 years at an average annual coal production rate of 42 million tons. 

2.3 Alternative 2 

Under Alternative 2 for the West Antelope II LBA tract, BLM is considering 

dividing the tract into two tracts and offering one or both of those tracts for 

sale. A separate, competitive sealed bid sale would be held for each tract that 

is offered for sale, and each tract would be subject to standard and special 

lease stipulations developed for the PRB and for that tract (Appendix D). If one 

or both of the tracts are offered for lease, Alternative 2 for the West Antelope II 

LBA tract assumes that ACC would be the successful bidder and that the 

federal coal would be mined to extend the life of the existing Antelope Mine. 

Assumptions concerning mining methods, facilities, hazardous materials, 

mitigation and monitoring requirements, etc. are the same as described for the 

West Antelope II LBA tract Proposed Action. 

As discussed under the Proposed Action and Alternative 1, the West Antelope II 

LBA tract consists of two non-contiguous blocks of federal coal. Under 

Alternative 2, the West Antelope II North LBA Tract would consist of the 

northern block of coal and the West Antelope II South LBA Tract would consist 

of the southern block of coal. BLM is considering dividing the tract because 

the northern tract would potentially be of competitive interest to more than one 

mine. 

As discussed under Alternative 1, BLM has identified a study area which 

includes the tract as applied for and unleased federal coal adjacent to the 

northeastern, western, and southern edges of the tract as applied for. The 

West Antelope II South LBA Tract study area includes lands on the TBNG, 

which is administered by USDA-FS. BLM is evaluating the potential that 

adding some or all of these lands to the area offered for lease would provide for 

more efficient recovery of the federal coal, increase competitive interest in the 

2-18 Draft EIS, West Antelope II Coal Lease Application 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 2.0 Proposed Action and Alternatives 

West Antelope II North and South LBA Tracts, and/or reduce the potential that 

some of the remaining unleased federal coal in this area would be bypassed in 

the future. Under Alternative 2, the BLM could add all, part, or none of 

adjacent lands to one or both tracts or BLM could reduce the size of one or 

both tracts, as discussed in Section 2.0. 

The lands that BLM is considering including in the north tract are: 

T.41N., R.71W., 6th P.M., Campbell County, Wyoming 

Section 9: Lots 9 through 16: 330.68 acres 

Section 10: Lots 9 through 16: 326.42 acres 

Section 11: Lots 13 and14: 85.03 acres 

Section 14: Lots 3 and 4: 82.64 acres 

Section 15: Lots 1 through 5, 12, and 13: 289.35 acres 

Section 20: Lots 9 through 16: 327.18 acres 

Section 21: Lots 1 through 16: 651.74 acres 

Section 22: Lots 2, 7, 8, and 14 through 16: 252.93 acres 

Section 27: Lots 6 through 11: 250.51 acres 

Section 28: Lots 1 through 8: 322.50 acres 

Section 29: Lots 1 through 8: 329.47 acres 

Total: 3,248.45 acres 

The lands that BLM is considering including in the south tract are: 

T.41N., R.71W., 6th P.M., Converse County, Wyoming 

Section 29: Lots 12 and 13: 81.09 acres 

Section 32: Lots 4, 5, 12, and 13: 162.36 acres 

T.40N., R.71W., 6th P.M., Converse County, Wyoming 

Section 5: Lots 8, 9, and 16 through 18: 159.79 acres 

Section 8: Lots 1 through 16: 637.66 acres 

Section 9: Lots 2 through 16: 597.22 acres 

Section 10: Lots 5, 6, and 11 through 14: 238.99 acres 

Section 14: Lot 13: 39.99 acres 

Section 15: Lots 2 through 7, and 10 through 16: 514.01 acres 

Section 17: Lots 1 through 16: 629.62 acres 

Total: 3,060.73 acres 

The land descriptions and acreage are based on the BLM Status of Public 

Domain Land and Mineral Titles approved Coal Plats as of April 15, 2004 and 

December 6, 2004. The coal estate in the tract described above is federally 

owned. The ownership of the surface and oil and gas estates is discussed in 

Section 3.11. 

As discussed under the Proposed Action and Alternative 1, the BNSF and UP 

railroad crosses portions of the federal coal included in the West Antelope II 

Draft EIS, West Antelope II Coal Lease Application 2-19 
2.0 Proposed Action and Alternatives 

North LBA Tract (Figure 2-1). The coal in the West Antelope II North LBA Tract 

that is located within the BNSF and UP railroad ROW and associated 100 foot 

buffer zone has been determined to be unsuitable for mining under Coal 

Unsuitability Criterion 2, and would not be recoverable 

As discussed under Alternative 1 and Section 1.5 and shown in Figure 2-1, 

State Highway 59 crosses the southwestern corner of the BLM study area for 

the south block of the tract, and Converse County Road 37 crosses the 

southeastern corner of the BLM study area for the south block of the tract, in 

Sections 17 and 14, T. 40 N., R. 71 W., respectively. BLM has determined that 

the coal underlying these portions of State Highway 59 and Converse County 

Road 37, their ROWs, and a buffer zone extending 100 feet on either side of the 

ROWs are unsuitable for mining in accordance with Coal Unsuitability 3 and 

would not be recoverable. 

Although these lands would not be mined, they would be included in the 

alternative tract configuration to allow maximum recovery of all of the mineable 

coal that is adjacent to but outside of the ROWs and associated buffer zones 

and to comply with the coal leasing regulations that do not allow leasing of less 

than 10-acre aliquot parts. 

ACC estimates that the BLM study area for the West Antelope II North LBA 

Tract contains approximately 403.2 million tons of mineable coal and that 

approximately 374.6 million tons of that coal would be recoverable. 

ACC estimates that the BLM study area for the West Antelope II South LBA 

Tract contains approximately 86.8 million tons of mineable coal and that 

approximately 79.3 million tons of that coal would be recoverable. 

BLM independently evaluates the volume and average quality of the coal 

resources included in proposed LBA tracts as part of the fair market value 

determination process. BLM’s estimate of the mineable federal coal reserves 

included in the West Antelope II North and South LBA Tracts may not be in 

agreement with the mineable coal reserve and coal quality estimates provided 

by the applicant. BLM’s estimate of the mineable federal coal reserves included 

in the tracts will be included in the Final EIS and published in the sale notice if 

the tracts are offered for sale. 

Under Alternative 2, ACC estimates that an average annual coal production 

rate of 36 million tons would extend the life of the mine by from 12 to 13 years, 

and the average number of full-time employees may at times increase to as 

many as 455. ACC estimates that an average annual coal production rate of 

42 million tons would extend the life of the mine by 11 years and increase the 

average number of full-time employees to up to 470. 

2-20 Draft EIS, West Antelope II Coal Lease Application 
 2.0 Proposed Action and Alternatives 

2.4 Alternative 3 

Under the West Antelope II LBA tract Alternative 3, the No Action Alternative, 

ACC’s application to lease the coal included in the West Antelope II LBA tract 

would be rejected, the tract would not be offered for competitive sale at this 

time, and the coal included in the tract would not be mined. 

Rejection of the application would not affect permitted mining activities and 

employment on the existing leases at the Antelope Mine. The Antelope Mine 

currently leases approximately 10,828 acres of federal coal and 807 acres of 

state coal; all of which are within the existing Antelope Mine permit 

boundaries. A total of approximately 12,105 acres will eventually be affected in 

mining the current leases. If the West Antelope II LBA tract is not leased, ACC 

estimates that the average annual production at the Antelope Mine after 

January 1, 2007 will be 36 million tons, and the average full-time employment 

level is expected to be 430 persons. Portions of the surface of the LBA tract 

would probably be disturbed due to overstripping to allow coal to be removed 

from existing contiguous leases. 

In order to compare the economic and environmental consequences of mining 

these lands versus not mining them, this EIS was prepared under the 

assumption that West Antelope II LBA tract would not be mined in the 

foreseeable future if the No Action Alternative is selected. However, selection of 

the No Action Alternative would not preclude leasing and mining of this tract in 

the future. If the decision is made to reject the West Antelope II lease 

application at this time, the tract could be leased as a maintenance lease in the 

future while the adjacent mine is in operation. If it is not leased while the 

existing adjacent mine is in operation, it may or may not be leased in the 

future. The tract being evaluated in this EIS does not include enough coal 

reserves to economically justify mining by a new operation; however, the coal 

reserves included in the tract could potentially be combined with unleased 

federal coal to the west and north to create a larger tract, which could be 

mined by a new operation in the future. 

2.5 Alternative 4 

Under this alternative, as under the Proposed Action, Alternative 1, and 

Alternative 2, the BLM would hold a separate, competitive, sealed-bid sale for 

the lands included in the West Antelope II LBA tract. Alternative 4 assumes, 

however, that the successful qualified bidder would be someone other than the 

applicant and that this bidder would plan to open a new mine to develop the 

coal resources included in the West Antelope II coal lease application. 

A company or companies acquiring this coal for a new stand-alone mine would 

require considerable initial capital expenses, including the construction of new 

surface facilities (i.e., offices, shops, warehouses, coal processing facilities, coal 

loadout facilities, and rail spur), extensive baseline data collection, and 

development of new mining and reclamation plans. In addition, a company or 

Draft EIS, West Antelope II Coal Lease Application 2-21 
2.0 Proposed Action and Alternatives 

companies acquiring this coal for a new start mine would have to compete for 

customers with established mines in a competitive market. 

BLM currently estimates that a tract would potentially need to include as much 

as 500 to 600 million tons of coal in order to attract a buyer interested in 

opening a new mine in the Wyoming PRB. This is based on several 

assumptions. First, it is assumed that an operator would construct facilities 

capable of producing 30 mmtpy to take advantage of the economies of scale 

offered by the coal deposits in the PRB. It is also assumed that 20 to 30 years 

of coal reserves would be needed to justify the expense of building the facilities 

described above. Given these assumptions, under the Proposed Action, 

Alternative 1, or Alternative 2, while the total amount of coal included in the 

two blocks of coal may be sufficient to consider opening a new mine, that coal 

is divided into two blocks, and neither block includes sufficient coal resources 

to consider opening a new mine. Therefore, it is unlikely that a company or 

companies would lease the West Antelope II LBA tract in order to open a new 

mine. 

The potential difficulty in obtaining an air quality permit is another issue that 

could discourage new mine starts in the PRB. A new mine would create a new 

source of air quality impacts. As discussed in Chapter 3, the WDEQ/AQD 

administers a permitting program to assist the agency in managing the state’s 

air resources. Under this program, anyone planning to construct, modify, or 

use a facility capable of emitting designated pollutants into the atmosphere 

must obtain an air quality permit to construct. Coal mines fall into this 

category. 

In order to obtain a construction permit, an operator may be required to 

demonstrate that the proposed activities will not increase air pollutant levels 

above annual standards established by the Wyoming Air Quality Standards 

and Regulations, which can be found on the internet at http://deq.state.wy.us 

/aqd/standards.asp. There were no exceedances of the 24-hour PM10 

standards anywhere in the PRB through year 2000. From 2001 through 2005, 

there were 29 monitored exceedances of the 24-hour PM10 standard at seven 

operating mines in the Wyoming PRB, four of which are located within the 

southern portion of the basin. Nineteen of these exceedances occurred in 2001 

and 2002, while two, three, and five exceedances occurred in 2003, 2004, and 

2005, respectively. One of the 2005 exceedances occurred at the Antelope 

Mine, but it was attributed to maintenance/construction operations on the 

adjacent railroad (WDEQ/AQD 2006a). In the first few months of 2007, there 

were nine exceedances at four mines. It may be difficult for an operator 

planning on opening a new mine to demonstrate that new operations would not 

result in air pollution levels that are above annual Wyoming standards. 

In view of the issues discussed above, development of a new mine on the West 

Antelope II LBA tract is considered unlikely and this alternative is not analyzed 

in detail in this EIS. 

2-22 Draft EIS, West Antelope II Coal Lease Application 
 2.0 Proposed Action and Alternatives 

The environmental impacts of developing a new mine to recover the coal 

resources in the West Antelope II LBA tract would be greater than under the 

Proposed Action, Alternative 1, Alternative 2, or Alternative 3 (the No Action 

Alternative) because of the need for new facilities, new rail lines, new 

employment, and the creation of additional sources of particulates (dust). In 

the event that a lease sale is held and the applicant is not the successful 

bidder, the successful bidder would be required to submit a detailed mining 

and reclamation plan for approval before any of the tract could be mined, and 

this NEPA analysis would be reviewed and supplemented as necessary prior to 

approval of that mining and reclamation plan. 

2.6 Alternative 5 

Under Alternative 5, the BLM would delay the sale of the West Antelope II LBA 

tract as applied for. The prices received for coal from the PRB have generally 

been increasing in recent years. If that trend continues, the bonus and royalty 

payments to the government might be higher if the tract is offered for sale at a 

later date. Also, delaying the sale of the tract would allow CBNG resources to 

be more completely recovered prior to mining. Under this alternative, it is 

assumed that the tract could be developed later as either a maintenance tract 

or a new start mine, depending on how long the sale was delayed. 

There is no assurance at this time that delaying the sale would result in a 

higher coal price or a higher bonus bid. Damage to train tracks in Wyoming 

and other states limited coal shipments during much of 2005. These shipping 

constraints combined with increasing world energy demands and natural 

disasters in other parts of the country led to large increases in coal prices in 

2005. Rail capacity increased in 2006 and prices have moderated in 2006 and 

2007. 

There are two major sources of revenue to state and federal governments from 

the leasing and mining of federal coal: 1) the competitive bonus bid paid at the 

time the coal is leased, and 2) federal and state royalties and taxes collected 

when the coal is sold. 

If coal prices do increase, the fair market value of the coal resources in the LBA 

tract could potentially increase, which could result in an increased bonus bid if 

the coal is leased at a later date. However, postponing a lease sale would not 

necessarily lead to higher royalty or tax income to the state or federal 

governments. Royalty and tax payments are the larger of the two revenue 

sources and they increase automatically when coal prices increase because 

they are collected at the time the coal is sold. They cannot be collected until 

the coal is leased and permitted, which takes several years. If leasing is 

delayed, then by the time the coal is mined, the higher coal prices may or may 

not persist. If the higher coal prices do persist, they may enable the coal lessee 

to negotiate longer term contracts at higher prices, which would result in 

longer term, higher royalty and tax revenues. On the other hand, if an existing 

mine runs out of coal reserves before prices rise, it would potentially have to 

Draft EIS, West Antelope II Coal Lease Application 2-23 
 

2.0 Proposed Action and Alternatives 

shut down before additional coal could be leased and permitted for mining. 

Under this scenario, the fair market value of the coal could actually decrease 

because the added expense of reopening a mine or starting a new mine would 

have to be factored into the fair market value. 

Other considerations include the value of leaving the mineable coal for future 

development versus the value of making low-sulfur coal available now, in 

anticipation of cleaner fuel sources being developed in the future. Continued 

leasing of PRB coal enables coal-fired power plants to meet CAA requirements 

without constructing new plants, revamping existing plants, or switching to 

existing alternative fuels, which may significantly increase power costs for 

individuals and businesses. If cleaner fuel sources are developed in the future, 

they could be phased in with less economic impact to the public. 

A range of the potential future economic benefits of delaying leasing until coal 

prices rise could be quantified in an economic analysis, but the benefits would 

have to be discounted to the present, which would make them similar to the 

Proposed Action and Alternatives 1 and 2. 

CBNG resources are currently being recovered from oil and gas leases on the 

West Antelope II LBA tract and there are several mechanisms in place that can 

be used to allow continuing recovery of the CBNG resources prior to mining if 

the federal coal in the tract is leased now: 

• BLM can attach a Multiple Mineral Development stipulation to the lease, 

which states that BLM has the authority to withhold approval of coal 

mining operations that would interfere with the development mineral 

leases issued prior to the coal lease. 

• Mining of the West Antelope II LBA tract cannot occur until the coal 

lessee has a permit to mine the tract approved by the WDEQ/LQD and a 

MLA mining plan approved by the Secretary of the Interior. Before the 

MLA mining plan can be approved, BLM must approve the R2P2 for 

mining the tract. Prior to approving the R2P2, BLM can review the 

status of CBNG development on the tract and the mining sequence 

proposed by the coal lessee. The permit approval process generally takes 

the coal lessee several years. This would allow time for a large portion of 

the CBNG resources to be recovered from the tract. 

• BLM has a policy in place on CBNG-coal conflicts (BLM Instruction 

Memorandum No. 2006-153), which directs BLM decision makers to 

optimize the recovery of both resources and ensure that the public 

receives a reasonable return (BLM 2006d). 

This alternative was not analyzed in detail because it would not produce 

substantially different impacts from other alternatives analyzed in detail. 

Rental and royalty provisions in the proposed lease provide for the U.S. to 

benefit if coal prices increase by the time of mining. Moreover, recovery of a 

2-24 Draft EIS, West Antelope II Coal Lease Application 
 2.0 Proposed Action and Alternatives 

large portion of the economically-recoverable CBNG resources on the tract 

would be anticipated after lease issuance because of the mechanisms 

discussed above. The environmental impacts of mining the coal later as part of 

an existing mine would be expected to be similar and about equal to the 

Proposed Action and the Action Alternatives. If a new mine start is required to 

mine the coal, the environmental impacts would be expected to be greater than 

if it were mined as an extension of an existing mine. 

2.7 Summary of Alternatives and Environmental Consequences 

2.7.1 Background 

The decision-making process for public lands in Wyoming is conducted in 

compliance with NEPA, which requires all federal agencies to involve interested 

publics in their decision making, consider reasonable alternatives to the 

proposed actions, develop measures to mitigate environmental impacts, and 

prepare environmental documents that disclose the impacts of proposed 

actions and alternatives. 

This draft EIS analyzes in detail four different alternatives for the West 

Antelope II LBA tract, described in the discussion above. 

2.7.2 Summary of Alternatives 

The West Antelope II LBA tract under the Proposed Action and Alternatives 1 

and 2 are shown on Figure 2-1. A summary comparison of projected coal 

production, surface disturbance, mine life, and federal and state revenues for 

the Proposed Action and Alternatives 1 and 2 for the West Antelope II LBA tract 

is presented in Table 2-2 for the 36 mmtpy production rate and in Table 2-3 for 

the 42 mmtpy production rate. 

Table 2-4 presents a comparative summary of the direct and indirect 

environmental impacts of implementing each alternative as compared to the No 

Action Alternative. The No Action Alternative assumes completion of currently 

permitted mining at the Antelope Mine for comparison to anticipated mining if 

the West Antelope II LBA tract is leased. Table 2-5 presents a comparative 

summary of cumulative environmental impacts of implementing each 

alternative. The environmental consequences of the Proposed Action and 

alternatives are analyzed in Chapters 3 and 4. These summary impact tables 

are derived from the following explanation of impacts and magnitude. 

Draft EIS, West Antelope II Coal Lease Application 2-25 
2.0 Proposed Action and Alternatives 

Table 2-2. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and Revenues for 

Tract and Antelope Mine - Assuming Average Annual Post-2006 Coal Production is 36 mmt. 

Alternative 3-No 

Item 

Action Alternative 

(Existing Antelope 

Mine) 

Added by 

Proposed Action 

(tract as applied for} Added by Alternative 1 

Added by 

Alternative 2 

(North Tract) 

In-Place Coal (as of 1/1/07) 428.6 mmt 465.1 mmt 530.0 mmt 442.7 mmt 

Mineable Coal (as of 1/1/07)1 428.6 mmt 463.7 mmt 490.0 mmt 403.2 mmt 

Recoverable Coal (as of 1/1/07)2 394.3 mmt 429.5 mmt 453.9 mmt 374.6 mmt 

Coal Mined Through 2006 318.9 mmt ⎯ ⎯ ⎯ 

Potential Lease Area3 11,635.5 ac 4,108.6 ac 6,309.2 ac 3,248.5 ac Total Area To Be Disturbed4 12,104.8 ac 4,314.0 ac 6,624.7 ac 3,410.9 ac 

Permit Area4 14,280.1 ac 4,490.2 ac 7,405.3 ac 3,616.4 ac 

Average Annual Post-2006 Coal 36 mmt 0 mmt 0 mmt 0 mmt Production Remaining Life of 11 yr 12 yr 13 yr 10 yr Mine (post-2006) Average Number of Employees 430 up to 25 up to 25 

Total Projected State and $ 657.3 million $ 780.4 - $ 924.3 million $ 824.7 - $ 976.8 $ 680.6 - $ 806.1 mi

Local Revenues (post-2006)5,6 million 

Total Projected Federal $ 473.7 million $ 580.5 - $ 724.3 million $ 613.4 - $ 765.5 $ 506.3 - $ 631.7 mi

Revenues (post-2006)7 million 

1	 Mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railroad ROW and public road ROWs. 2 Recoverable coal figure assumes 91.3 percent recovery (south tract, two seams) or 92.9 percent recovery (north tract, one seam) of 

mining losses that occur during normal mining operations. 

3 Includes federal and state coal leases 4 The disturbed area exceeds the leased area because of the need for highwall reduction, topsoil removal, and other mine supp

boundaries. The permit area is larger than the leased or disturbed area to assure that all disturbed lands are within the permit bdefined legal land description. Permit areas for the Alternative 2 North and South Tracts overlap; the sum of these areas is therefo1 permit area. 

5	 Revenues to the State of Wyoming and local governments include severance tax, property and production taxes, sales and use 

federal royalty payments, bonus bids, and AML fees. State revenues are based on an assumed price of $9.01 per ton of 'recoverab

percent of the value less 50.5 percent federal share, plus $0.315 per ton for AML fees x an assumed 25 percent state share, plu

$0.30 and $0.97 per ton of LBA leased coal per ton (based on average of last 6 LBAs in 2004 and 2005) x tonnage of recoverable plus $0.07 per ton estimated sales and use taxes, plus $0.33 per ton estimate for ad valorem taxes, plus $0.415 per ton in severuse taxes paid directly by the mine are considered, i.e., those generated by vendors and suppliers and by consumer expenditure suby the mine are not included. 

6	 Revenues for Alternative 3 do not include the $43.9 million in scheduled coal lease bonus bids to be paid on the West Antelope LBA 7	 Federal revenues are based on an assumed price of $9.01 per ton, federal royalty of 12.5 percent x 50.5 percent share, plus $0

assumed 75 percent federal share, plus black lung tax of $0.00261 per ton, plus bonus payments of between $0.30 and $0.97 

(based on the range of the 6 most recent last 6 LBA sales in 2004 and 2005) x tonnage of recoverable coal minus x 50 percent feder

2-26 Draft EIS, West Antelope II C
2.0 Proposed A

Table 2-3.	 Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and Revenues for 

Tract and Antelope Mine - Assuming Average Annual Post-2006 Coal Production is 42 mmt. 

Alternative 3-No 

Action Alternative Added by Added by 

(Existing Antelope Proposed Action Alternative 2 

Item Mine) (tract as applied for} Added by Alternative 1 (North Tract) 

In-Place Coal (as of 1/1/07) 428.6 mmt 465.1 mmt 530.0 mmt 442.7 mmt 

Mineable Coal (as of 1/1/07)1 428.6 mmt 463.7 mmt 490.0 mmt 403.2 mmt 

Recoverable Coal (as of 1/1/07)2 394.3 mmt 429.5 mmt 453.9 mmt 374.6 mmt 

Coal Mined Through 2006 318.9 mmt ⎯ ⎯ ⎯ 

Potential Lease Area3 11,635.5 ac 4,108.6 ac 6,309.2 ac 3,248.5 ac Total Area To Be Disturbed4 12,104.8 ac 4,314.0 ac 6,624.7 ac 3,410.9 ac 

Permit Area4 14,280.1 ac 4,490.2 ac 7,405.3 ac 3,616.4 ac 

Average Annual Post-2006 Coal 36 mmt 6 mmt 6 mmt 6 mmt 

Production Remaining Life of 11 yrs 10 yr 11 yr 9 yr Mine (post-2006) Average Number of Employees 430 up to 40 up to 40 

Total Projected State and $ 657.3 million $ 780.4 - $ 924.3 million $ 824.7 - $ 976.8 $ 680.6 - $ 806.1 mi

Local Revenues (post-2006)5,6 million 

Total Projected Federal $ 473.7 million $ 580.5 - $ 724.3 million $ 613.4 - $ 765.5 $ 506.3 - $ 631.7 mi

Revenues (post-2006)7 million 

1	 Mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railroad ROW and public road ROWs. 2 Recoverable coal figure assumes 91.3 percent recovery (south tract, two seams) or 92.9 percent recovery (north tract, one seam) of 

mining losses that occur during normal mining operations. 

3 Includes federal and state coal leases 4 The disturbed area exceeds the leased area because of the need for highwall reduction, topsoil removal, and other mine supp

boundaries. The permit area is larger than the leased or disturbed area to assure that all disturbed lands are within the permit bdefined legal land description. Permit areas for the Alternative 2 North and South Tracts overlap; the sum of these areas is therefo1 permit area. 

5	 Revenues to the State of Wyoming and local governments include severance tax, property and production taxes, sales and use 

federal royalty payments, bonus bids, and AML fees. State revenues are based on an assumed price of $9.01 per ton of 'recoverab

percent of the value less 50.5 percent federal share, plus $0.315 per ton for AML fees x an assumed 25 percent state share, plu

$0.30 and $0.97 per ton of LBA leased coal per ton (based on average of last 6 LBAs in 2004 and 2005) x tonnage of recoverable plus $0.07 per ton estimated sales and use taxes, plus $0.33 per ton estimate for ad valorem taxes, plus $0.415 per ton in sever

use taxes paid directly by the mine are considered, i.e., those generated by vendors and suppliers and by consumer expenditure suby the mine are not included. 

6	 Revenues for Alternative 3 do not include the $43.9 million in scheduled coal lease bonus bids to be paid on the West Antelope LBA 7	 Federal revenues are based on an assumed price of $9.01 per ton, federal royalty of 12.5 percent x 50.5 percent share, plus $0

assumed 75 percent federal share, plus black lung tax of $0.00261 per ton, plus bonus payments of between $0.30 and $0.97 

(based on the range of the 6 most recent last 6 LBA sales in 2004 and 2005) x tonnage of recoverable coal minus x 50 percent feder

Draft EIS, West Antelope II Coal Lease Application 
2.0 Proposed Action and Alternatives 

Table 2-4.	 Summary Comparison of Magnitude1 and Duration of Direct and Indirect Impacts 

Action, Alternatives 1 and 2, and the No Action Alternative for the West Antelope 

DESCRIPTION OF POTENTIAL IMPACT BY MAGNITUDE AND DURATION OF IMPAC

RESOURCE 

ALTERNATIVE 3 - NO ACTION PROPOSED 

RESOURCE NAME ALTERNATIVE 1 and ALTER

TOPOGRAPHY & PHYSIOGRAPHY Lower surface elevation Moderate, permanent on existing mine area Same as No Ac

Permanent topographic moderation, which could result in: Microhabitat reduction Moderate, long term on existing mine area Same as No Ac

Habitat diversity reduction Moderate, long term on existing mine area Same as No AcBig game carrying capacity reduction Moderate, long term on existing mine area Same as No AcReduction in water runoff and peak flows Moderate, beneficial, long term on existing mine Same as No Ac

area 

Increased precipitation infiltration Moderate, beneficial, long term on existing mine Same as No Ac

area 

Reduction in erosion Moderate, beneficial, long term on existing mine Same as No Ac

area 

Potential enhanced vegetative productivity Moderate, beneficial, long term on existing mine Same as No Ac

area 

Potential acceleration of groundwater recharge Moderate, beneficial, long term on existing mine Same as No Ac

area 

GEOLOGY AND MINERALS Removal of coal Moderate, permanent on existing mine area Same as No Ac

Removal and replacement of topsoil and overburden Moderate, permanent on existing mine area Same as No AcPhysical characteristic alterations in replaced overburden Moderate, permanent on existing mine area Same as No AcLoss of unrecovered CBNG though venting and/or depletion of Moderate to substantial, permanent on existing Same as No Achydrostatic pressure mine area Loss of access for development of sub-coal oil and gas Moderate, short term on existing mine area Same as No Acresources and other minerals Destruction of paleontological resources that are not exposed Moderate, permanent on the existing mine area Same as No Ac

on the surface AIR QUALITY Particulate Emissions:  Elevated concentrations associated with average Moderate, short term on existing mine and Same as No Ac

production of 36 to 42 mmtpy in compliance with surrounding area surrounding aambient standards years 

NOx Emissions from Machinery: 

 Elevated concentrations associated with average Moderate, short term on existing mine and Same as No Ac

production of 36 to 42 mmtpy in compliance with surrounding area surrounding aambient standard years 

1 Refer to Chapter 3 for a discussion on magnitude of impacts. 2 All impacts are assumed to be adverse unless noted otherwise. 

2-28 Draft EIS, West Antelope II C
2.0 Proposed A

Table 2-4.	 Summary Comparison of Magnitude1 and Duration of Direct and Indirect Impacts 

Action, Alternatives 2 and 3, and the No Action Alternative for the West Antelope 

(Continued). 

DESCRIPTION OF POTENTIAL IMPACT BY MAGNITUDE AND DURATION OF IMPAC

RESOURCE 

ALTERNATIVE 3 - NO ACTION PROPOSED 

RESOURCE NAME ALTERNATIVE 1 and ALTER

AIR QUALITY (Continued) NOx Emissions from Blasting: 

Potential for public exposure No reported events No events proj

Visibility: 

Elevated concentrations of fine particulate matter Moderate, short term on existing mine and Same as No Ac

associated with average production of 36 to 42 mmtpy surrounding area surrounding a

years 

Acidification of Lakes: 

SO2 emissions derived from burning Antelope Mine coal to Moderate, short term Same as No Ac

produce power 

WATER RESOURCES GROUNDWATER Removal of coal and overburden aquifers Moderate, short term on existing mine area Same as No Ac

Replacement of existing coal and overburden with Moderate, permanent on existing mine area Same as No Acunconsolidated backfill material Depressed water levels in overburden and coal aquifers Moderate, short to long term on existing mine and Same as No Acadjacent to mine surrounding area surrounding aChange in hydraulic properties in backfilled areas Negligible, long term on existing mine area Same as No AcIncrease in TDS concentrations in backfilled areas Moderate, long term on existing mine area Same as No AcUse of subcoal aquifers for water supply Negligible, short term on existing mine and Same as No Ac

surrounding area surrounding a

Decrease in water supply for groundwater-right holders within Moderate, long term on existing mine and Same as No Acthe five-foot drawdown area surrounding area surrounding aSURFACE WATER Diversion and disruption of surface drainage systems Moderate, short term on existing mine area Same as No AcReconstruction of surface drainage systems Permanent on existing mine areas Same as No AcIncreased runoff and erosion rates on disturbed lands due to Moderate, short term on existing mine area Same as No Acvegetation removal Increased infiltration on reclaimed lands due to topographic Moderate, beneficial, long term on existing mine Same as No Acmoderation area Increased runoff on reclaimed lands due to loss of soil Moderate, long term on existing mine area Same as No Acstructure Potential for adverse downstream effects as a result of Moderate, long term for existing approved mining Same as No Acsediment produced by large storms operation operation 

1 Refer to Chapter 3 for a discussion on magnitude of impacts. 2 All impacts are assumed to be adverse unless noted otherwise.
 

Draft EIS, West Antelope II Coal Lease Application	 
2.0 Proposed Action and Alternatives 

Table 2-4.	 Summary Comparison of Magnitude1 and Duration of Direct and Indirect Impacts 

Action, Alternatives 2 and 3, and the No Action Alternative for the West Antelope 

(Continued). 

DESCRIPTION OF POTENTIAL IMPACT BY MAGNITUDE AND DURATION OF IMPAC

RESOURCE 

ALTERNATIVE 3 - NO ACTION PROPOSED 

RESOURCE NAME ALTERNATIVE 1 and ALTER

ALLUVIAL VALLEY FLOORS While final determinations have not been made by WDEQ/LQD, it is believed that there are no AVFs significant to agriculture on the proposed lease tract Removal and restoration of AVFs determined not to be Moderate, short term on existing leases Same as No Ac

significant to agriculture Disruptions to streamflows supplying downstream AVFs Negligible, short term on existing leases Same as No Ac

WETLANDS Removal of jurisdictional wetlands and loss of wetland Moderate, short term on existing leases; Same as No Acfunction until reclamation occurs jurisdictional wetlands would be replaced as 

required under Section 404 of the Clean Water Act 

Removal of non-jurisdictional wetlands and loss of wetland Moderate, short term to long term on existing Same as No Acfunction until reclamation occurs leases; non-jurisdictional wetlands would be 

replaced as required by the surface land owner or WDEQ/LQD 

SOILS Changes in physical properties after reclamation would include: 

Increased near-surface bulk density and decreased soil Moderate, long term on existing mine area Same as No Ac

infiltration rate resulting in increased potential for soil erosion More uniformity in soil type, thickness, and texture Moderate, beneficial, long term on existing mine Same as No Ac

area 

Decreased runoff due to topographic modification Moderate, beneficial, long term on existing mine Same as No Ac

area 

Changes in biological properties in soils that are stockpiled before reclamation would include: 

Reduction in organic matter Moderate, short to long term on existing mine area Same as No Ac

Reduction in microorganism population Moderate, short to long term on existing mine area Same as No AcReduction in seeds, bulbs, rhizomes, and live plant parts Moderate, short to long term on existing mine area Same as No Ac

Changes in chemical properties would include: 

More uniform soil nutrient distribution Moderate, beneficial, long term on existing Same as No Ac

mine area 

1 Refer to Chapter 3 for a discussion on magnitude of impacts. 2 All impacts are assumed to be adverse unless noted otherwise.
 

2-30 Draft EIS, West Antelope II C
2.0 Proposed A

Table 2-4.	 Summary Comparison of Magnitude1 and Duration of Direct and Indirect Impacts 

Action, Alternatives 2 and 3, and the No Action Alternative for the West Antelope 

(Continued). 

DESCRIPTION OF POTENTIAL IMPACT BY MAGNITUDE AND DURATION OF IMPAC

RESOURCE 

ALTERNATIVE 3 - NO ACTION PROPOSED 

RESOURCE NAME ALTERNATIVE 1 and ALTER

VEGETATION During mining: 

Progressive removal of existing vegetation Moderate, short term on existing mine area Same as No Ac

Increased erosion Moderate, short term on existing mine area Same as No AcWildlife habitat and livestock grazing loss Moderate, short term on existing mine area Same as No Ac

After revegetation: 

Changes in vegetation patterns Negligible, long term on existing mine area Same as No Ac

Reduction in vegetation diversity Negligible, long term on existing mine area Same as No AcReduction in shrub density Moderate, long term on existing mine area Same as No AcDecreased big game habitat carrying capacity Moderate, long term on existing mine area Same as No AcDecreased habitat for shrub dependent species Moderate, long term on existing mine area Same as No AcPotential invasion of non-native plant species Moderate, short term on existing mine area Same as No Ac

WILDLIFE Big game displacement from active mining areas Moderate, short term on existing mine area Same as No AcIncreased competition on adjacent undisturbed or reclaimed Moderate, short term on adjacent area Same as No Aclands, especially big game Restriction of wildlife movement, especially big game Moderate, short term on existing mine area Same as No AcIncreased mortality of small mammals Moderate, short term on existing mine area Same as No AcDisplacement of small and medium-sized mammals Moderate, short term on existing mine area Same as No AcSurface and noise disturbance of active sage grouse leks Moderate, short to long term on existing mine area Same as No AcDisturbance of sage grouse nesting habitat during mining Moderate, short term on existing mine area Same as No AcLoss of sage grouse nesting habitat after reclamation Moderate, long term on existing mine area Same as No AcAlteration of plant and animal communities after reclamation Negligible, short term on existing mine area Same as No AcAbandonment of raptor nests Negligible, short term on existing mine area Same as No AcLoss of foraging habitat for raptors Negligible, short to long term on existing mine area Same as No AcLoss of nesting and foraging habitat for Migratory Birds of Negligible, short to long term on existing mine area Same as No AcManagement Concern Reduction in waterfowl resting and feeding habitat Negligible, short term on existing mine area Same as No AcLoss of habitat for aquatic species during mining Negligible, short term on existing mine area Same as No AcRoad kills by mine-related traffic Moderate, long term on existing mine area Same as No AcReduction in habitat carrying capacity and habitat diversity Moderate, long term on existing mine area Same as No Acon reclaimed lands Potential reduction in microhabitats on reclaimed lands Moderate, long term on existing mine area Same as No Ac

1 Refer to Chapter 3 for a discussion on magnitude of impacts. 2 All impacts are assumed to be adverse unless noted otherwise. 

Draft EIS, West Antelope II Coal Lease Application 
2.0 Proposed Action and Alternatives 

Table 2-4.	 Summary Comparison of Magnitude1 and Duration of Direct and Indirect Impacts 

Action, Alternatives 2 and 3, and the No Action Alternative for the West Antelope 

(Continued). 

DESCRIPTION OF POTENTIAL IMPACT BY MAGNITUDE AND DURATION OF IMPAC

RESOURCE 

ALTERNATIVE 3 - NO ACTION PROPOSED 

RESOURCE NAME ALTERNATIVE 1 and ALTER

THREATENED, ENDANGERED, PROPOSED, AND CANDIDATE SPECIES (See Appendix I) Black-footed ferrets Ute ladies’-tresses LAND USE AND RECREATION Reduction of livestock grazing Loss of wildlife habitat Loss of access for sub-coal oil and gas development Removal of oil and gas production facilities Loss of access to public land available for recreation and grazing CULTURAL RESOURCES Sites that are not eligible for NRHP Sites that are eligible for NRHP Sites that are unevaluated for eligibility NATIVE AMERICAN CONCERNS VISUAL RESOURCES During mining: 

Alteration of landscape by mining facilities and operations 

 Visibility of mining operations from highway 

Following reclamation: 

Smoother sloped terrain Reduction in sagebrush density 

As determined by previous consultation with USFWS for all species Moderate, long term on existing mine area Moderate, long term on existing mine area Moderate, short term on existing mine area Moderate, short term on existing mine area Moderate, short term on existing mine area Ineligible sites may be destroyed without further work Impacts to sites that are eligible for the NHRP are not permitted; eligible sites would be avoided or mitigated through data recovery prior to mining Impacts to unevaluated sites are not permitted; unevaluated sites would be evaluated prior to mining No impact identified on existing mine area Moderate, short term on existing mine area Moderate, short term on existing mine area Negligible, long term on existing mine area Moderate, short to long term on existing mine area 

No effect May affect, not Same as No AcSame as No AcSame as No AcSame as No AcSame as No AcSame as No AcSame as No AcSame as No AcSame as No AcSame as No AcSame as No AcSame as No Ac

1 Refer to Chapter 3 for a discussion on magnitude of impacts. 2 All impacts are assumed to be adverse unless noted otherwise.
 

2-32 Draft EIS, West Antelope II C
2.0 Proposed A

Table 2-4.	 Summary Comparison of Magnitude1 and Duration of Direct and Indirect Impacts 

Action, Alternatives 2 and 3, and the No Action Alternative for the West Antelope 

(Continued). 

DESCRIPTION OF POTENTIAL IMPACT BY MAGNITUDE AND DURATION OF IMPAC

RESOURCE 

ALTERNATIVE 3 - NO ACTION PROPOSED 

RESOURCE NAME ALTERNATIVE 1 and ALTER

NOISE Increased noise levels TRANSPORTATION FACILITIES Use of railroads to ship coal Employee and service contractor use of highways to and from mine sites Relocation of pipelines Relocation of utility lines HAZARDOUS AND SOLID WASTE Waste generated by mining operations SOCIOECONOMICS Employment Revenues from royalties and taxes to the state and local government Revenues from royalties and taxes to the federal government Economic development Additional housing and infrastructure needs 

Moderate to substantial, short term on existing mine, surrounding area and occupied dwellings and businesses Moderate, for duration of existing approved mining operations Moderate, for duration of existing approved mining operations Negligible, short to long term on existing mine area Negligible, short to long term on existing mine area Negligible for duration of existing approved mining operations Negligible, beneficial short term for existing approved mining operations Moderate, beneficial short term for existing approved mining operations Moderate, beneficial short term for existing approved mining operations Moderate, beneficial short term for existing approved mining operations No new impact related to existing approved mining operations 

Same as No AcSame as No Acyears Same as No Acyears Same as No AcSame as No AcSame as No AcUp to 25 to 40 life extended Same as No Acyears Same as No Acyears Same as No Acyears Same as No Acyears 

1 Refer to Chapter 3 for a discussion on magnitude of impacts. 2 All impacts are assumed to be adverse unless noted otherwise.
 

Draft EIS, West Antelope II Coal Lease Application 
2.0 Proposed Action and Alternatives 

Table 2-5. Summary Comparison of Magnitude and Duration of Cumulative Impacts1, 2. 

DESCRIPTION OF POTENTIAL IMPACT BY 

RESOURCE MAGNITUDE, TYPE, AND DURATION OF IM

ALTERNATIVE 3 - NO ACTION PROPOSED ACT

RESOURCE NAME ALTERNATIVE ALTERNATIVE 2 

TOPOGRAPHY & PHYSIOGRAPHY Alteration of topography following reclamation of coal Permanent topographic moderation following Same as No Actio

disturbance areas reclamation Alteration of topography to accommodate coal-related, Long term to permanent limited changes in Same as No Actio

oil and gas, and oil- and gas-related facilities discrete, scattered areas GEOLOGY AND MINERALS Recovery of coal resulting in reduction in coal resources Moderate, long term to permanent Same as No Actio

and disturbance and replacement of overburden and topsoil Surficial disturbance and reclamation on oil and gas Moderate, long term to permanent Same as No Actio

well sites and associated facilities PALEONTOLOGY Coal, coal-related, oil and gas, and oil- and gas-related Permanent potential adverse effects to Same as No Actio

development disturbance of PFYC Class 5 Wasatch and scientifically significant fossils that are present Class 3 Fort Union Formations but not visible prior to disturbance AIR QUALITY Impacts to Montana near-field receptors A maximum modeled impact in one area above Same as No Actio

- 24-hour PM10 NAAQS for the baseline year and both coal 

production scenarios for 2010 

- All other parameters Modeled impacts in compliance with NAAQS Same as No Actio

and Montana AAQS 

Impacts to Wyoming near-field receptors Modeled impact above NAAQS at some Same as No Actio

- 24-hour PM10 receptors for both coal production scenarios 

for 2010 

- Annual PM10 Maximum modeled impact above WAAQS at Same as No Actio

one receptor for the upper production scenario for 2010 

- All other parameters Modeled impacts in compliance with NAAQS Same as No Actio

and Wyoming AAQS 

1 Cumulative impact discussion in this table and in Chapter 4 is based on the PRB Coal Review analyses (BLM 2005a-f, 2006a2 All impacts are assumed to be adverse unless noted otherwise. 

2-34 Draft EIS, West Antelope II C
2.0 Proposed A

Table 2-5. Summary Comparison of Magnitude and Duration of Cumulative Impacts1, 2 (Cont

DESCRIPTION OF POTENTIAL IMPACT BY 

RESOURCE MAGNITUDE, TYPE, AND DURATION OF IM

ALTERNATIVE 3 - NO ACTION PROPOSED ACT

RESOURCE NAME ALTERNATIVE ALTERNATIVE 2 

AIR QUALITY (Continued) Non-regulatory PSD Impacts at Class I and Sensitive Class II Areas - Class I Northern Cheyenne Indian Reservation Modeled impacts above Class I increment Same as No Actio

levels for 24-hour PM10, annual PM10, 24-hour 

SO2, 3-hour SO2 for baseline year and both coal production scenarios for 2010; above Class I increment for annual NO2 for upper coal production scenario for 2010 

- Class I Washakie Wilderness Area and Wind Cave Modeled impacts above Class I increment Same as No Actio

National Park and Class II Crow Indian Reservation levels for 24-hour PM10 for baseline year and 

both coal production scenarios for 2010 

- All other Class I and Sensitive Class II modeled Modeled impacts within Class I increment Same as No Actio

receptors levels for baseline year and both coal 

production scenarios for 2010 

Visibility Impacts 199 or more days with a change of 1.0 dv or Same as No Actio

greater at three Class I areas and seven sensitive Class II areas for the baseline year and both coal productions scenarios for 2010 

Acid deposition Impacts All modeled impacts below the depositions Same as No Actio

threshold values for nitrogen and sulfur compounds 

- Florence Lake Modeled impact above 10 percent ANC Same as No Actio

- Upper Frozen Lake Modeled impact above 1 μeq/L Same as No Actio

- All other modeled sensitive lakes Modeled impact below threshold values Same as No Actio

GROUNDWATER RESOURCES Removal of coal aquifer and replacement with backfill Moderate, permanent for mining areas Same as No Actio

material Lowering of water levels in aquifers around the mines Moderate, long term in area immediately west Same as No Actio

of mines 

Water level decline in sub-coal aquifers as a result of all No cumulative impacts anticipated Same as No Actio

development Change in groundwater quality as a result of all No cumulative impacts anticipated Same as No Actio

development 

1 Cumulative impact discussion in this table and in Chapter 4 is based on the PRB Coal Review analyses (BLM 2005a-f, 20062 All impacts are assumed to be adverse unless noted otherwise. 

Draft EIS, West Antelope II Coal Lease Application 
2.0 Proposed Action and Alternatives 

Table 2-5. Summary Comparison of Magnitude and Duration of Cumulative Impacts1, 2 (Cont

DESCRIPTION OF POTENTIAL IMPACT BY MAGNITUDE, TYPE, AND DURATION OF IM

RESOURCE 

ALTERNATIVE 3 - NO ACTION PROPOSED ACT

RESOURCE NAME ALTERNATIVE ALTERNATIVE 2 

GROUNDWATER RESOURCES (Continued) Overlapping drawdown in the coal aquifer caused by surface mining and CBNG development SURFACE WATER RESOURCES Surface disturbance of intermittent and ephemeral streams and scattered ponds and reservoirs as a result of coal mining, coal-related, oil and gas, and oil- and gas-related development Discharge of coal mining and CBNG produced waters into intermittent and ephemeral streams Sediment input into intermittent and ephemeral streams and scattered ponds and reservoirs as a result of coal mining, coal-related, oil and gas, and oil- and gas-related development ALLUVIAL VALLEY FLOORS Coal mining disturbance of AVFs determined to be significant to agriculture Coal mining disturbance of AVFs determined not to be significant to mining SOILS Coal mining, coal-related, oil and gas, and oil- and gasrelated disturbance and replacement of soil resources CBNG water disposal impacts to soil resources 

Additive, long term in area immediately west of surface coal mines Moderate, short term Moderate, short term Moderate, short term Not permitted by regulation AVFs disturbed by mining must be restored to essential hydrologic function No cumulative impacts anticipated Moderate, short term and long term impacts through accelerated wind or water erosion, declining soil quality factors through compaction, reduced microbial populations and organic matter, and potential mixing of soil zones Potential increase in soil alkalinity depending on SAR levels in water and method of water disposal 

Same as No ActioSame as No ActioSame as No Actio

Same as No Actio

Same as No ActioSame as No Actio

Same as No ActioSame as No Actio

1 Cumulative impact discussion in this table and in Chapter 4 is based on the PRB Coal Review analyses (BLM 2005a-f, 20062 All impacts are assumed to be adverse unless noted otherwise. 

2-36 Draft EIS, West Antelope II C
2.0 Proposed A

Table 2-5. Summary Comparison of Magnitude and Duration of Cumulative Impacts1, 2 (Cont

DESCRIPTION OF POTENTIAL IMPACT BY 

RESOURCE MAGNITUDE, TYPE, AND DURATION OF IMP

ALTERNATIVE 3 - NO ACTION PROPOSED ACT

RESOURCE NAME ALTERNATIVE ALTERNATIVE 2 

VEGETATION Coal mining, coal-related, oil and gas, and oil- and gas- Moderate, short to long term impacts due to Same as No Actiorelated removal and replacement of native vegetation potential differences in species composition 

and presence and size of woody species on reclaimed lands 

Coal mining, coal-related, oil and gas, and oil- and gas- Potential incremental loss of alteration of Same as No Actiorelated impacts to Special Status Plant Species potential or known habitat Coal mining, coal related, oil and gas, and oil- and gas- Potential displacement of native species and Same as No Actiorelated dispersal of noxious and invasive species changes in species composition WETLAND AND RIPARIAN VEGETATION CBNG-related discharge of produced water Moderate, short to long term creation of Same as No Actio

wetlands in areas that previously supported upland vegetation 

WILDLIFE Direct and indirect coal mining, coal-related, oil and Moderate, short term Same as No Actiogas, and oil- and gas-related development impacts to game and non-game species, including direct mortality, habitat fragmentation, animal displacement, noise and increased human presence Coal mining, coal-related, oil and gas, and oil- and gas- Moderate, short term loss of all types of Same as No Actiorelated disturbance of game and nongame species habitat present in disturbed areas habitat during project development and operation Coal mining, coal related, oil and gas, and oil- and gas- Moderate, long term change in habitat with Same as No Actiorelated habitat changes after reclamation potential changes in associated wildlife 

populations 

FISHERIES Alteration or loss of habitat due to coal mining, coal- Moderate, short to long term Same as No Actiorelated, oil and gas, and oil- and gas-related development Changes in water quality as a result of surface Moderate, short to long term Same as No Actiodisturbance or introduction of contaminants into drainages caused by coal mining, coal-related, oil and gas, and oil- and gas-related development 

1 Cumulative impact discussion in this table and in Chapter 4 is based on the PRB Coal Review analyses (BLM 2005a-f, 20062 All impacts are assumed to be adverse unless noted otherwise.
 

Draft EIS, West Antelope II Coal Lease Application 
2.0 Proposed Action and Alternatives 

Table 2-5. Summary Comparison of Magnitude and Duration of Cumulative Impacts1, 2 (Cont

DESCRIPTION OF POTENTIAL IMPACT BY 

RESOURCE MAGNITUDE, TYPE, AND DURATION OF IMP

ALTERNATIVE 3 - NO ACTION PROPOSED ACT

RESOURCE NAME ALTERNATIVE ALTERNATIVE 2 

FISHERIES (Continued) Changes in available habitat as a result of water Moderate, short term Same as No Actio

withdrawals or discharges related to coal mining, coalrelated, oil and gas, and oil- and gas-related development SPECIAL STATUS SPECIES Direct and indirect coal mining, coal-related, oil and Moderate, short term Same as No Actio

gas, and oil- and gas-related development impacts, including direct mortality, breeding area, nest, or burrow abandonment, noise and increased human presence Moderate, short term loss of all types of special Same as No ActioCoal mining, coal-related, oil and gas, and oil- and gas- status species habitat present in disturbed related disturbance of habitat during project areas development and operation Moderate, long term change in habitat with Same as No ActioCoal mining, coal related, oil and gas, and oil- and gas- potential changes in associated populations of related habitat changes after reclamation special status species LAND USE AND RECREATION Loss of forage and range improvements and restriction Moderate, short term Same as No Actioof livestock movement due to coal mining, coal-related, oil and gas, and oil- and gas-related development Disturbance of developed recreation sites by coal Negligible, short term Same as No Actiomining, coal-related, oil and gas, and oil- and gasrelated development Reduction or degradation of opportunities for dispersed Moderate, short term on existing mine area Same as No Actiorecreation activities related to coal mining, coal-related, oil and gas, and oil- and gas-related development CULTURAL RESOURCES Disturbance of cultural resource sites Moderate, permanent Same as No Actio

TRANSPORTATION AND UTILITIES Movement of segments of existing highways, pipelines, Moderate, long term to permanent, disruptive Same as No Actiotransmission lines, or railroads to accommodate coal effects would be minimized mining development 

1 Cumulative impact discussion in this table and in Chapter 4 is based on the PRB Coal Review analysis (BLM 2005a-f, 2 All impacts are assumed to be adverse unless noted otherwise. 

2-38 Draft EIS, West Antelope II C
2.0 Proposed A

Table 2-5. Summary Comparison of Magnitude and Duration of Cumulative Impacts1, 2 (Cont

DESCRIPTION OF POTENTIAL IMPACT BY 

RESOURCE MAGNITUDE, TYPE, AND DURATION OF IM

ALTERNATIVE 3 - NO ACTION PROPOSED ACT

RESOURCE NAME ALTERNATIVE ALTERNATIVE 2 

TRANSPORTATION AND UTILITIES Increased vehicular traffic on roads and highways due Moderate, short term Same as No Actioto coal mining, coal-related, oil and gas, and oil- and gas-related development, and associated impacts including traffic accidents, road wear, air emissions, dust, noise, and vehicle collisions with wildlife and livestock Construction and operation of additional railroad and Moderate, short to long term Same as No Actiopipeline facilities and transmission lines to transport coal, oil and gas, and electricity SOCIOECONOMICS Increases in employment related to coal mining, coal- Significant, short to long term Same as No Actio

related, oil and gas, and oil- and gas-related development Increases in personal income due to employment Significant, beneficial, short to long term Same as No Actioincreases related to coal mining, coal-related, oil and gas, and oil- and gas-related development Increase in population due to employment increases Significant, short to long term Same as No Actiorelated to coal mining, coal-related, oil and gas, and oiland gas-related development Expansion of housing supply due to employment Significant, short to long term Same as No Actioincreases related to coal mining, coal-related, oil and gas, and oil- and gas-related development Increases in school enrollment due to employment Moderate, short term Same as No Actio

increases related to coal mining, coal-related, oil and gas, and oil- and gas-related development Need for additional local government facilities and Moderate, short to long term Same as No Actioservices due to employment increases related to coal mining, coal-related, oil and gas, and oil- and gasrelated development Increased federal state and local revenues related to Significant, beneficial, short to long term Same as No Actiocoal mining, coal-related, oil and gas, and oil- and gasrelated development 

1 Cumulative impact discussion in this table and in Chapter 4 is based on the PRB Coal Review analyses (BLM 2005a-f, 20062 All impacts are assumed to be adverse unless noted otherwise. 

Draft EIS, West Antelope II Coal Lease Application 
2.0 Proposed Action and Alternatives 

NEPA requires all agencies of the federal government to include, in every 

recommendation or report on proposals for legislation and other major federal 

actions significantly affecting the quality of the human environment, a detailed 

statement by the responsible official on: 

(i) the environmental impact of the Proposed Action, 

(ii) any adverse environmental effects which cannot be avoided should the 

proposal be implemented, 

(iii) alternatives to the Proposed Action, 

(iv) the relationship between local short-term uses of man’s environment 

and the maintenance and enhancement of long-term productivity, and 

(v)	 any irreversible and irretrievable commitments of resources which 

would be involved in the Proposed Action should it be implemented 

(42 USC § 4332[C]). 

Impacts can be beneficial or adverse, and they can be a primary result of an 

action (direct) or a secondary result (indirect). They can be permanent, longterm (persisting beyond the end of mine life and reclamation) or short-term 

(persisting during mining and reclamation and through the time the 

reclamation bond is released). Impacts also vary in terms of significance. The 

basis for conclusions regarding significance are the criteria set forth by the 

Council on Environmental Quality (40 CFR 1508.27) and the professional 

judgment of the specialists doing the analyses. Impact significance may range 

from negligible to substantial; impacts can be significant during mining but be 

reduced to insignificance following completion of reclamation. 

2-40 Draft EIS, West Antelope II Coal Lease Application 
 

3.0 Affected Environment and Environmental Consequences 

3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

This chapter describes the existing conditions of the physical, biological, cultural, 

and socioeconomic resources in the general analysis area for the West Antelope II 

LBA1 tract (the affected environment) and analyzes the potential associated direct 

and indirect impacts to those resources if the tract is leased and mined under the 

Proposed Action or Alternatives 1 or 2 (the environmental consequences). The 

potential environmental consequences of the No Action Alternative (Alternative 3, 

rejecting the application for the tract) are also considered in this chapter. 

In addition, this chapter considers regulatory compliance; mitigation; monitoring; 

residual impacts; the relationship between local short-term uses of man’s 

environment and the maintenance of long-term productivity; and the irreversible 

and irretrievable commitments of resources that would occur with the 

implementation of the Proposed Action or Alternatives 1 or 2. 

The West Antelope II LBA tract as applied for consists of two non-contiguous 

blocks of federal coal. Under the Proposed Action, the two blocks as applied for 

would be offered for lease at one sale. As discussed in Chapter 2, BLM has 

identified a study area for the tract which consists of the tract as applied for and 

adjacent lands that BLM is considering adding to the tract. Alternative 1 

evaluates holding one sale for a tract modified by BLM. Alternative 2 evaluates 

splitting the application and offering one or both blocks, either as applied for or as 

modified by BLM, for sale. The two tracts are referred to as the North and South 

tracts. Under Alternatives 1 and 2, lands included in the Thunder Basin National 

Grassland, administered by USDA-Forest Service, would potentially be included in 

the lands that would be offered for lease. The proposed North and South tracts 

are not considered separately in the following discussions of the affected 

environment and the potential consequences of mining the tract on the 

environment. 

Figure 3-1 shows the general analysis area for most environmental resources. The 

general analysis area for the tract includes the BLM study area for the tract (the 

West Antelope II LBA tract as applied for and the adjacent lands that BLM is 

considering adding to the tract) and the anticipated permit amendment study area 

for the Antelope Coal Mine. The anticipated permit amendment study area is 

defined as those lands adjacent to and outside of the mine’s current permit area 

that the applicant anticipates would be contained within the amended mine 

permit area if they acquire the tract. 

The resources that are addressed here were identified during the scoping process 

or interdisciplinary team review as having the potential to be affected. 

Refer to page xv for a list of abbreviations and acronyms used in this document. 

Draft EIS, West Antelope II Coal Lease Application 3-1 

1 
 

3.0 Affected Environment and Environmental Consequences 

Campbell County 

Converse County 

North Antelope / Rochelle 

Rail Line 

An telope Road 

B.N.S.F. & U.P RR 

T. 

40 

N. 

R. 72 W. R. 70 W. 

T. 

41 

N. 

T. 

41 

N. 

R. 71 W. 

T. 

40 

N. 

R. 71 W. 

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

9 

3 6 

8 

2 

7 

1 

8 

5 

8 

5 4

9 

7 8 

7 

1 6 

7 

4 

9 

1 

9 

6 5 4 3 2 1 6 5 4 

11 

12 

22 

11 

27 

13 

15 

24 

10 

20 

26 

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30 

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23 

15 

14 

29 28 

14 13 

16 

12 

30 

12 

13 17

16 

25 

19 

17 18 

32 

17 

34 

10 

18 

31 32 33 35 31

18 

36 

13 

12 

28 

25 

33 

24 21 

36 

16 

16 

23 24 19 20 21 22 24 19 20 21 

31 32 33 34 35 36 31 32 33 36 

2 

11 

14 

23 

!(59 

LEGEND 

Antelope Mine Permit Boundary 

Anticipated Permit Amendment Study Area 

West Antelope II LBA Tract As Applied For 

Area Added under Alternative 1 

North Tract (Alternative 2) 

South Tract (Alternative 2) 

General Analysis Area 

£ 0 8,000 16,000 

GRAPHIC SCALE (FEET) 

B.N.S.F. & U.P. RR 

Figure 3-1. General Analysis Area. 

3-2 Draft EIS, West Antelope II Coal Lease Application 
3.0 Affected Environment and Environmental Consequences 

Critical elements of the human environment (BLM 1988) that could potentially be 

affected by the Proposed Action or Alternatives 1 and 2 include air quality, 

cultural resources, Native American religious concerns, T&E species, hazardous or 

solid wastes, water quality, wetlands/riparian zones, invasive non-native species, 

and environmental justice. Five other critical elements (areas of critical 

environmental concern, prime or unique farmlands, wild and scenic rivers, 

floodplains, and wilderness) are not present in the general analysis area and are 

not addressed further. In addition to the critical elements that are potentially 

present in the general analysis area, this EIS discusses the status and potential 

effects of mining the LBA tract on topography and physiography, geology and 

mineral resources, soils, water quantity, alluvial valley floors, vegetation, wildlife, 

land use and recreation, paleontological resources, visual resources, noise, 

transportation resources, and socioeconomics. 

Table 3-1 shows the acreage leased and disturbance area for the existing Antelope 

Mine (which represents the No Action Alternative). As indicated in Table 3-1, the 

Antelope Mine’s coal leases currently include 11,635.5 acres and, under the 

approved mining and reclamation plan, the mine would disturb a total of 12,104.8 

acres in order to recover that coal. According to the 2005 Annual Report for the 

Antelope Mine, which was submitted to WDEQ/LQD, the mine had disturbed a 

total of 5,581.4 acres as of September 30, 2005 (ACC 2005). Of that area of 

disturbance, approximately 1,522.5 acres (27 percent) were occupied by 

permanent or temporary facilities (stockpiles, hydrologic control structures, mine 

buildings, coal loading facilities, railroad loop, environmental monitoring areas, 

etc.), 2,266.1 acres (41 percent) were occupied by mined and unreclaimed areas or 

areas of active mining, and 1,792.8 acres (32 percent) were occupied by reclaimed 

areas. 

If the West Antelope II LBA tract is leased to the applicant as a maintenance tract 

under the Proposed Action or Alternatives 1 or 2, the permit area for the adjacent 

Antelope Mine would have to be revised to include the newly leased area before the 

tract could be disturbed by mining activities. Table 3-1 shows how the leased 

area and disturbance area would change, for the tract as applied for and under 

Alternatives 1 and 2, if all the federal coal in the BLM study area discussed in 

chapter 2 is included in the tract that is offered for lease. Portions of the West 

Antelope II LBA tract lie inside the current mine permit area (Figure 3-1). If the 

tract is leased, the area that would have to be added to the existing mine permit 

area would be the portions of the LBA tract outside of the existing permit 

boundary plus an adjacent strip of land that would be used for highwall reduction 

after mining and such mine-related activities as construction of diversions, flood 

and sediment control structures, roads, and stockpiles. Portions of the LBA tract 

that are contiguous to the existing mine will be disturbed under the current 

mining plans in order to recover the coal in the existing coal leases. The 

environmental consequences of implementing the Proposed Action or Alternatives 

1 and 2 would be similar in nature, but selection of the Proposed Action would 

disturb a smaller area of land surface. 

Draft EIS, West Antelope II Coal Lease Application 3-3 
3.0 Affected Environment and Environmental Consequences 

Table 3-1. Comparison of Existing and Proposed Antelope Mine Disturbance 

Area and Mining Operations. 

No Action Alternative 

(Existing Permit Area) 

Proposed

Action 

Alternatives 

1 and 2 

Additional Lease Area (Acres) --- 4,108.6 6,309.2 

Total Lease Area (Acres)1 11,635.5 15,744.1 17,944.7 

Increase in Lease Area (Percent) --- 35.3 54.2 

Estimated Additional Mine 

Disturbance Area (Acres)2 --- 4,314.0 6,624.7 

Estimated Total Mine Disturbance 

Area (Acres) 12,104.8 16,418.8 18,729.5 

Increase in Estimated Disturbance 

Area (Percent) --- 35.6 54.7 

Estimated Additional Recoverable 

Coal (Million Tons)3 --- 429.5 453.9 

Estimated Recoverable Coal for 394.3 823.8 848.2 

Mine as of 1/07 (Million Tons) 

Increase in Estimated Recoverable 

Coal as of 1/07 (Percent) --- 108.9 115.1 

1 Includes federal and state coal 

2 Total Disturbance Area = area to be mined + area disturbed for mine facilities, access roads, 

haul roads, highwall reduction, railroad facilities, stockpiles, etc. 

3	 Estimated Recoverable Coal Resources = tons of mineable coal × recovery factor 

(approximately 91 to 93 percent). 

Surface mining and reclamation have been ongoing in the eastern PRB for over 

two decades. During this time, effective mining and reclamation technologies have 

been developed and continue to be refined. Mining and reclamation operations 

are regulated under SMCRA and Wyoming statutes. WDEQ technically reviews all 

mine permit application packages to ensure that the mining and reclamation 

plans comply with all state permitting requirements and that the proposed coal 

mining operations comply with the performance standards of the DOI-approved 

Wyoming program. BLM attaches special stipulations to all coal leases (Appendix 

D), and there are a number of federal and state permit approvals that are required 

in order to conduct surface mining operations (Appendix A). The regulations are 

designed to ensure that surface coal mining impacts are mitigated. 

Impacts can range from beneficial to adverse and they can be a primary result of 

an action (direct) or a secondary result (indirect). They can be permanent, longterm (persisting beyond the end of mine life and reclamation), or short-term 

(persisting during mining and reclamation and until the time the reclamation 

bond is released). Impacts also vary in terms of significance. The basis for 

conclusions regarding significance are the criteria set forth by the Council on 

Environmental Quality (40 CFR 1508.27) and the professional judgment of the 

specialists doing the analyses. Impact significance may range from negligible to 

substantial; impacts can be significant during mining but be reduced to 

insignificance following completion of reclamation. 

3-4 Draft EIS, West Antelope II Coal Lease Application 
3.0 Affected Environment and Environmental Consequences 

3.1 General Setting 

The general analysis area is located in the PRB, a part of the Northern Great 

Plains that includes most of northeastern Wyoming. Vegetation is primarily 

sagebrush and mixed grass prairie. 

3.1.1 Climate and Meteorology 

The climate in the general analysis area is typical of a semi-arid, high plains 

environment with relatively large seasonal and diurnal variations in temperature 

and seasonal variation in precipitation. The average annual precipitation at a 

NOAA/NWS meteorological station (Wright 12 W), located about 20 miles northnorthwest of the general analysis area (see Figure 1-1), is 13.27 inches (WRCC 

2007). May (2.00 inches) and June (1.99 inches) are the wettest months, whereas 

December (0.34 inch) and January (0.37 inch) are the driest. Snowfall averages 

55.3 inches per year, with most occurring in March (8.9 inches) and April (9.7 

inches). Potential evapotranspiration, at approximately 31 inches (NOAA 1969), 

exceeds annual precipitation. Summers are relatively short and warm, while 

winters are longer and cold. The annual mean temperature for the NOAA/NWS 

meteorological station at Wright for the period of record is 44.6 degrees F, and 

daily extreme temperatures have ranged from -39 degrees F to 107 degrees F. 

July is the warmest month, with a mean daily temperature of 69.7 degrees F, and 

January is the coldest month, with a mean daily temperature of 23.9 degrees F. 

The frost-free period is 100-120 days (Curtis 2004). 

The 2000 average annual wind speed at the Antelope Mine was 10.7 mph, with 

winter gusts often reaching 30-40 mph. Winds are predominantly from the 

southwest and west and tend to be strongest in the winter and spring and calmer 

in the summer. Local variations in wind speed and direction are primarily due to 

differences in topography. Wind velocity tends to increase during the day in 

response to solar isolation and decrease during the night. During periods of 

strong wind, dust may impact air quality across the region. An average of 15 airstagnation events occurs annually in the PRB with an average duration of two 

days each (BLM 1974). The wind rose diagram for the Antelope Mine is shown in 

Figure 3-2. 

3.2 Topography and Physiography 

3.2.1 Affected Environment 

The general analysis area is a high plains area within the eastern portion of the 

PRB. The name PRB has been used to refer to both a structural basin and a 

drainage basin. The structural PRB is an elongated, asymmetrical syncline that is 

bounded in Wyoming by the Black Hills on the northeast, the Hartville Uplift on 

the southeast, the Big Horn Mountains on the northwest, the Casper Arch on the 

southwest, and the Laramie Mountains on the south. The northern terminus of 

the structural basin in Montana separates the PRB from the Williston Basin. The 

Draft EIS, West Antelope II Coal Lease Application 3-5 
3.0 Affected Environment and Environmental Consequences 

Figure 3-2. Wind Rose Diagram for Antelope Mine. 

axis of the PRB trends from southeast to northwest near the western margin of the 

basin, and the Antelope Mine is located on the gently dipping eastern limb of the 

syncline. In general, geologic units dip to the west at 1 to 2 degrees toward the 

center of the basin on the eastern limb of the PRB. The structural PRB includes 

the Powder River drainage basin as well as the upstream portions of the Belle 

Fourche River, Cheyenne River, and Tongue River drainage basins. 

Broad plains, rolling hills, and tablelands dominate the PRB landscape. Playas 

are common in the basin, as are buttes and plateaus capped by clinker or 

sandstone. In general, the topography of the basin varies from open hills with 

500-1000 ft of local relief in the northern part of the PRB to plains and tablelands 

3-6 Draft EIS, West Antelope II Coal Lease Application 
 

3.0 Affected Environment and Environmental Consequences 

with 300-500 ft of local relief in the southern PRB. Elevations in the PRB range 

from less than 2,500 ft to greater than 6,000 ft above sea level. The major river 

valleys have wide, flat floors and broad floodplains. The drainages dissecting the 

area are incised, typically are ephemeral or intermittent, and do not provide yearround water sources. 

The general analysis area is characterized by gently rolling terrain broken by 

steeply cut washes. Elevations range from approximately 4,500 ft to 5,100 ft 

above sea level. Overall, the West Antelope II LBA tract is similar in topography to 

the rest of the Antelope Mine permit area where slopes range from flat to about 34 

percent and average about five percent. The area is drained by Antelope Creek 

and its tributaries, a series of south and north trending ephemeral drainages 

including Horse Creek and Spring Creek. 

3.2.2 Environmental Consequences 

3.2.2.1 Proposed Action and Alternatives 1 and 2 

Surface coal mining would permanently alter the topography of the LBA tract if it 

is leased and mined. Topsoil would be removed from the land and stockpiled or 

placed directly on recontoured areas. Overburden would be blasted and 

stockpiled or directly placed into the already mined pit, and coal would be 

removed. A highwall with a vertical height equal to overburden plus coal 

thickness would exist in the active pits. Spring Creek and Horse Creek channels 

would be diverted around the active mining area during the period of disturbance. 

Typically, a direct permanent impact of coal mining and reclamation is 

topographic moderation. After reclamation, the restored land surfaces are 

generally gentler, with more uniform slopes and restored basic drainage networks. 

The original topography of the West Antelope II LBA tract ranges from relatively 

flat to gently rolling hills. Slopes range from flat to around 34 percent, as 

discussed above, and the average slope is about five percent. The expected 

postmining topography would be similar to the premining topography, but 

somewhat gentler and more uniform. Following reclamation, the average surface 

elevation on the LBA tract would be from approximately two to eight feet lower due 

to coal removal. The removal of the coal would be partially offset by the swelling 

that occurs when the overburden (and interburden, if present) is blasted and 

removed. Table 3-2 presents the approximate postmining surface elevation 

change for the LBA tract as applied for under the Proposed Action and Alternatives 

1 and 2. After the coal is removed, the land surface would be restored to 

approximate original contour or to a configuration approved by WDEQ/LQD when 

the surface coal mining permit for the existing mine is amended to include the 

LBA tract. 

Direct adverse impacts resulting from topographic moderation include a reduction 

in microhabitats (e.g., cutbank slopes) for some wildlife species and a reduction in 

habitat diversity, particularly a reduction in slope-dependent shrub communities 

Draft EIS, West Antelope II Coal Lease Application 3-7 
3.0 Affected Environment and Environmental Consequences 

and associated habitat. These impacts, which would be greater in those areas 

characterized as rough breaks, may result in a long-term reduction in the carrying 

capacity for some species. A direct beneficial impact of the lower and flatter 

terrain would be reduced water runoff, which would allow increased infiltration 

and result in a minor reduction in peak flows. This may help counteract the 

potential for increased erosion that could occur as a result of higher near-surface 

bulk density of the reclaimed soils (Section 3.8.2). It may also increase vegetative 

productivity, and potentially accelerate recharge of groundwater. 

Table 3-2. Comparison of Average Overburden and Coal Thicknesses and 

Approximate Postmining Surface Elevation Changes Under the No 

Action Alternative and the Proposed Action and Alternatives 1 and 2. 

No Action Alternative 

(Existing Leases) 

Proposed Action

(As Applied For LBA Tract) 

Alternatives 1 

and 2 

Average Overburden 122 280 260 

Thickness (ft)1 

Average Coal 86.0 60 50 

Thickness (ft) 

Swell Factor 17 17 17 

(percent) 

Coal Recovery Factor 92.5 92.5 92.5 

(percent) 

Postmining Elevation 59 ft lower 8 ft lower 2 ft lower 

Change2 

1 The average overburden thickness includes the interburden where present. 

2 Reclaimed (postmining) elevation surface change calculated as: 

(overburden thickness + coal thickness )-((coal thickness × (1- coal recovery factor)) + ((1 + 

swell factor) × overburden thickness)). 

The approximate original drainage pattern would be restored and stock ponds 

would be replaced to provide livestock and wildlife watering sources. These 

topographic changes would not conflict with regional land use, and the postmining 

topography would be designed to adequately support anticipated land use. These 

impacts are occurring on the existing Antelope Mine coal leases as coal is mined 

and mined-out areas are reclaimed. Under the Proposed Action or Alternatives 1 

and 2, the areas that would be permanently topographically changed would 

increase as shown in Table 3-1. 

3.2.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and coal removal would not occur on the LBA tract. The impacts to 

topography and physiography described above and in Table 2-4 would continue as 

permitted on the existing adjacent Antelope Mine coal leases. Table 3-2 presents 

the approximate postmining surface elevation change for the existing mine. 

Portions of the West Antelope II LBA tract adjacent to the Antelope Mine would be 

disturbed to recover the coal in the existing leases. 

3-8 Draft EIS, West Antelope II Coal Lease Application 
3.0 Affected Environment and Environmental Consequences 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3.2.3 Regulatory Compliance, Mitigation and Monitoring 

The mined-out area must be restored to approximate original contour or other 

topographic configuration approved by WDEQ/LQD. If the West Antelope II LBA 

tract is leased, the topographic configuration would be developed and approved as 

part of the required revision to the mining and reclamation plan for the Antelope 

Mine. WDEQ/LQD monitors topographic restoration by checking the as-built 

topography in the annual report filed by the mine to see if it conforms to the 

approved topography. 

3.2.4 Residual Impacts 

Topographic moderation is a permanent consequence of mining. The indirect 

impacts of topographic moderation on wildlife habitat diversity would also be 

considered permanent. 

3.3 Geology, Mineral Resources, and Paleontology 

3.3.1 General Geology and Coal Resources 

3.3.1.1 Affected Environment 

Stratigraphic units that would be impacted if the tract under consideration for 

leasing is mined include, in descending order, recent (Holocene age) alluvial and 

eolian deposits, the Eocene age Wasatch Formation (the overburden), and the 

Paleocene age Fort Union Formation (which contains the target coal beds). Figure 

3-3 is a chart describing the surface and subsurface geologic units in the general 

analysis area and showing the stratigraphic relationships. 

Surficial deposits within the general analysis area include alluvial and eolian 

deposits, clinker, and weathered Wasatch and Fort Union Formations. Although 

clinker is present in the general analysis area, the tract has no appreciable 

amounts of clinker. There are thin alluvial deposits along ephemeral streams. 

These alluvial deposits typically consist primarily of poorly to well-sorted, 

irregularly bedded to laminated, unconsolidated sand, silt, and clay with minor 

intervals of fine gravel. The valley floors of Horse Creek, Spring Creek and 

Antelope Creek contain appreciable amounts of alluvium both in width and depth. 

The alluvial deposits in Horse Creek, Spring Creek and Antelope Creek contain 

much more coarse-grained material (sands and gravels) than the ephemeral 

tributaries that drain most of the general analysis area. 

Draft EIS, West Antelope II Coal Lease Application 3-9 
3.0 Affected Environment and Environmental Consequences 

Figure 3-3. Stratigraphic Relationships and Hydrologic Characteristics of Upper Cretaceous, Lower Tertiary, and Recent 

Geologic Units, PRB, Wyoming. 

3-10 Draft EIS, West Antelope II Coal Lease Application 
3.0 Affected Environment and Environmental Consequences 

The Eocene Wasatch Formation forms most of the overburden overlying the 

mineable coal seams in the general analysis area. It consists of interbedded 

lenticular sandstones, siltstones, shales, and thin discontinuous coals. There is 

no distinct boundary between the Wasatch Formation and the underlying 

Paleocene Fort Union Formation. From a practical standpoint, however, the top of 

the mineable coal zone is considered as the contact between the two formations. 

Overburden thickness averages 260 feet in the BLM study area (as indicated in 

Table 3-2) and ranges from around 20 ft to more than 460 ft. The overburden is 

relatively thin in the vicinity of the major channels within the tract and increases 

in thickness away from the channel bottoms. 

The Fort Union Formation consists primarily of shales, mudstones, siltstones, 

lenticular sandstones, and coal. It is divided into three members: Tongue River 

(which contains the mineable coal seams), Lebo, and Tullock, in descending order 

(Figure 3-3). 

The Tongue River Member of the Fort Union Formation consists of interbedded 

claystone, silty shale, carbonaceous shale, and coal, with lesser amounts of finegrained sandstone and siltstone. 

The nomenclature of the mineable coal seams in the Fort Union Formation varies 

from mine operator to mine operator. The U.S. Geological Survey (Flores et al. 

1999) refers to the thick mineable coals in the Gillette coal field as the WyodakAnderson coal zone of the Tongue River Member of the Fort Union Formation. 

Locally these beds are referred to as Wyodak, Wyodak-Anderson, Anderson, and 

Canyon. There are four mineable seams in the West Antelope II LBA tract 

(referred to by the operator as the Anderson, Lower Anderson, Canyon/Upper 

Canyon, and Lower Canyon). Figure 3-4 presents geologic cross sections through 

the tract. The total coal thickness ranges from 15 to 86 ft. Interburden between 

the coal seams varies from 5 to around 115 ft. The total overburden thickness 

(including interburden where present) ranges from about 20 ft to approximately 

550 ft. 

The Fort Union coal seams are subbituminous and are generally low-sulfur, lowash coals. Typically, the coal being mined has a higher heating value and lower 

sulfur content south of Gillette than north of Gillette. In the tract under 

consideration for leasing, the heating value of the coal seams is expected to range 

from 8,500 to 9,200 Btu/lb. The ash content in the coal seams is expected to vary 

from 3.5 to 8 percent, the sulfur content from 0.15 to 0.4 percent, and the 

moisture content from 23 to 28 percent. 

The Lebo and Tullock Members of the Fort Union Formation underlie the Tongue 

River Member (Figure 3-3). They consist primarily of sandstone, siltstone, 

mudstone, shale, and coal. In general, the Tullock Member contains more sand 

than the Lebo Shale Member. 

Draft EIS, West Antelope II Coal Lease Application 3-11 
3.0 Affected Environment and Environmental Consequences 

Figure 3-4. North-South and East-West Geologic Sections, West Antelope II LBA tract 

3-12 Draft EIS, West Antelope 
 3.0 Affected Environment and Environmental Consequences 

3.3.1.2 Environmental Consequences 

3.3.1.2.1 Proposed Action and Alternatives 1 and 2 

The geology from the base of the coal seam mined to the land surface would be 

subject to permanent change after the coal is removed on the LBA tract under the 

Proposed Action or Alternatives 1 and 2. The subsurface characteristics of these 

lands would be radically changed by mining. The replaced overburden and 

interburden (backfill) would be a mixture of the geologically distinct layers of 

sandstone, siltstone, and shale that currently exist. As a result, the physical 

characteristics of the backfill would be different from the physical characteristics 

of the existing layered overburden. 

Mining would remove an average of 280 ft of overburden and 60 ft of coal on about 

4,109 acres under the Proposed Action. Mining would remove an average of 260 ft 

of overburden and 50 ft of coal on about 6,309 acres under the tract configuration 

for Alternatives 1 and 2. These acreage figures represent the estimated area of 

actual coal removal under the Proposed Action and Alternatives 1 and 2. Table 3­

2 presents the average overburden and coal thicknesses for the tract as applied for 

and Alternatives 1 and 2. The replaced overburden and interburden would be a 

relatively homogeneous (compared to the premining layered overburden and 

interburden) and partly recompacted mixture averaging about 323 ft in thickness 

under the Proposed Action and about 310 ft in thickness under Alternatives 1 and 

2. Approximately 823.8 million tons of coal would be recovered under the 

Proposed Action, compared to an estimated 848.2 million tons under Alternatives 

1 and 2. 

3.3.1.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope coal lease application would be 

rejected and coal removal would not occur on the West Antelope II LBA tract. 

Mining operations, coal removal and the associated impacts described above 

would continue as permitted on the existing adjacent Antelope Mine coal leases. 

Table 3-2 presents the average overburden and coal thicknesses for the existing 

Antelope Mine permit area. Impacts to the overburden on portions of the West 

Antelope II LBA tract adjacent to the Antelope Mine would occur in order to 

recover the coal in the existing leases. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3.3.1.3 Regulatory Compliance, Mitigation and Monitoring 

Drilling and sampling programs are conducted on existing leases by all mine 

operators to identify overburden material that may be unsuitable for reclamation 

(i.e., material that is not suitable for use in reestablishing vegetation or that may 

Draft EIS, West Antelope II Coal Lease Application 3-13 
3.0 Affected Environment and Environmental Consequences 

affect groundwater quality due to high concentrations of certain constituents, 

such as selenium, or adverse pH levels). As part of the mine permitting process, 

each mine operator develops a management plan to ensure that this unsuitable 

material is not placed in areas where it may affect groundwater quality or 

revegetation success. Each mine operator also develops backfill monitoring plans 

as part of the mine permitting process to evaluate the quality of the replaced 

overburden. These plans are in place for the existing Antelope Mine and would be 

developed for the West Antelope II LBA tract if it is leased. 

3.3.1.4 Residual Impacts 

Geology from the base of the coal to the surface would be subject to significant, 

permanent change. 

3.3.2 Other Mineral Resources 

3.3.2.1 Affected Environment 

The PRB contains large reserves of fossil fuels including oil, natural gas (from 

conventional reservoirs and from coal beds), and coal, all of which are currently 

being produced. In addition, uranium, bentonite, and scoria are mined in the PRB 

(WSGS 2003). 

3.3.2.1.1 Conventional Oil and Gas 

Oil and conventional (i.e., non-CBNG) gas have been produced in the PRB for more 

than 100 years (Crockett 1999) from reservoirs that range in age from 

Mississippian to Oligocene (WOGCC 2007a). The USGS estimated means of the 

undiscovered oil and non-CBNG resource in the PRB are 639 million barrels of oil, 

1.21 trillion ft3 of gas, and 130.91 million barrels of natural gas liquids (USGS 

2006). Depth to gas and oil-bearing strata generally ranges from 4,000 ft to 

13,500 ft, but some wells are as shallow as 250 ft. 

There are several conventional oil and gas fields that produce in the vicinity of the 

West Antelope II LBA tract, including the Porcupine and Dennell Draw Oil and 

Gas Fields. The Porcupine Field is producing from or has produced from the 

Upper Cretaceous Parkman, Sussex, Teapot, and Turner Sandstones and the 

Niobrara Shale and the Lower Cretaceous Muddy and Dakota Sandstones, and the 

Dennell Draw Field produces from the Upper Cretaceous Turner Sandstone 

(WOGCC 2007b). 

There are no producing conventional oil and gas wells on the West Antelope II LBA 

tract under the Proposed Action or Alternatives 1 and 2. One productive well in 

the Porcupine Field, the Hedgehog State 1-16 operated by Nance Petroleum 

Corporation, is located adjacent to the West Antelope II LBA tract in the NE1⁄4NE1⁄4 

of Section 16, T.41N., R.71W. The well, which is currently shut in, produced gas 

and oil from the Cretaceous Turner Sandstone at a depth of 9,677 ft (WOGCC 

3-14 Draft EIS, West Antelope II Coal Lease Application 
 3.0 Affected Environment and Environmental Consequences 

2007b). There are two plugged and abandoned conventional wells located on the 

tract, one in the SW1⁄4SE1⁄4 of Section 21, T.41N., R.71W., and one in the 

SW1⁄4NE1⁄4 of Section 27, T.41N., R.71W. 

See Section 3.11 for a discussion of the ownership of the oil and gas resources in 

the BLM study area. 

3.3.2.1.2 Coal Bed Natural Gas (CBNG) 

CBNG has been commercially produced in the PRB since 1989 when production 

began at the Rawhide Butte Field, west of the Eagle Butte Mine. CBNG 

exploration and development is currently ongoing throughout the PRB in 

Wyoming. 

The following discussion is based on a report on CBNG resources in the lands 

adjacent to the existing surface coal mines in the Wyoming PRB, prepared by the 

WSO-RMG in May 2006 (WSO-RMG 2006). Extensive CBNG development has 

occurred on lands underlying and immediately west of the surface coal mines. 

The predominant CBNG production to date has occurred from coal beds that the 

USGS describes as the Wyodak-Anderson zone, which are the same coal beds (or 

equivalent to the coal beds) being mined by the surface coal mines. The WyodakAnderson zone appears to be gas-bearing throughout the PRB and the methane in 

the coal beds has been determined to be biogenic in origin. CBNG is being 

produced from other, deeper seams locally throughout the PRB, but not in this 

area. 

In order for CBNG to be produced, the hydrostatic pressure in the coal must be 

reduced to a level, which can vary from coal to coal, that allows the gas to desorb 

from the coal. This is accomplished by removing water from the coal seam. CBNG 

reservoirs can be affected by any nearby activities, including coal mining, that 

reduce the hydrostatic pressure in the coal seam. 

WSO-RMG and the USGS have collected coal gas content data from coal cores 

near the mines and in other areas of the PRB. Measured gas content was minimal 

in all of the cores collected in 2000 at locations near the surface coal mines, 

indicating that the coal seams were already substantially depleted of CBNG in the 

vicinity of the mines at that time. Average total gas content from the core 

desorption analyses was approximately 6.8 scf/ton near the coal mines in 2000, 

compared with an average measured gas content of 37.6 scf/ton from coal cores 

taken outside the mining areas. Ongoing reservoir depletion from both mining 

operations and CBNG production since that time has diminished and continues to 

diminish the gas in place adjacent to the mine areas. 

CBNG production was established near the northern and middle groups of coal 

mines earlier than it was established in the southern mine group, where the 

Antelope Mine is located. WOGCC well data from the areas adjacent to the 

surface coal mines generally show that operator interest peaked prior to 2000 and 

Draft EIS, West Antelope II Coal Lease Application 3-15 
3.0 Affected Environment and Environmental Consequences 

declined following 2001. By 2005, drilling activity in the areas adjacent to the coal 

mines had declined significantly, with only 128 applications to drill CBNG wells 

filed in all of the townships including and bordering the coal mines in 2005. 

Currently, there are no active, abandoned or proposed CBNG wells in the 

southern portion of the LBA tract in T.40N., R.71W. However, CBNG development 

has been extensive in T.41N., R.71W. WOGCC records show that as of April 2007, 

258 wells had been drilled for CBNG production and 181 wells were capable of 

producing from the Wyodak-Anderson coal zone in T.41N., R.71W. (Appendix E). 

In the sections that include the BLM study area for the West Antelope II LBA tract 

(the tract as applied for and the additional area evaluated under Alternatives 1 

and 2), 30 of the 40 permitted CBNG wells are capable of producing (WOGCC 

2007c). 

The ownership of the oil and gas resources in the BLM study area, which includes 

the CBNG resources, is discussed in Section 3.11. 

3.3.2.1.3 Other Minerals 

Bentonite, uranium, and scoria are commercially produced in the PRB in addition 

to conventional oil and gas and CBNG. 

Layers of bentonite (decomposed volcanic ash) of varying thickness are present 

throughout the PRB. Some of the thicker layers are mined where they are near 

the surface, mostly around the edges of the basin. Bentonite has a large capacity 

to absorb water, and because of this characteristic it is used in a number of 

processes and products, including cat litter and drilling mud. No mineable 

bentonite reserves have been identified on the West Antelope II LBA tract under 

the Proposed Action or Alternative 1 or 2. 

There are substantial uranium resources in southwestern Campbell and 

northwestern Converse Counties. There is one producing uranium operation in 

Wyoming, which is located in the southern Powder River Basin (WSGS 2006). No 

known uranium reserves exist on the West Antelope II LBA tract. 

Scoria, which is also referred to as clinker or burn, is present in the general 

analysis area and has been and continues to be a major source of aggregate for 

road construction in the area. Scoria consists of sediments that were baked, 

fused, or melted in place when the underlying coal burned spontaneously. No 

scoria is present within the West Antelope II LBA tract. 

A search of the BLM mining claim index revealed that no active mining claims are 

presently located within the West Antelope II study area. 

3-16 Draft EIS, West Antelope II Coal Lease Application 
 3.0 Affected Environment and Environmental Consequences 

3.3.2.2 Environmental Consequences 

3.3.2.2.1 Proposed Action and Alternatives 1 and 2 

During mining, other minerals present on the LBA tract could not be developed. 

Some of these minerals could, however, be developed after mining and reclamation 

is completed. 

The conventional oil and gas reservoirs are located below the mineable coal beds 

and would not be directly disturbed by removal of the coal. There are currently no 

producing conventional oil and gas wells on the West Antelope II LBA tract under 

the Proposed Action or Alternatives 1 and 2, as discussed above. In the event that 

productive conventional oil and gas wells are drilled before the coal is removed, 

they would have to be removed, along with any associated facilities, to a level 

below the coal before mining could occur. Following mining and reclamation, the 

oil and gas lessee could re-complete old wells or drill new wells to recover oil and 

gas resources from any productive subcoal oil and gas reservoirs. This would only 

occur if they believe that the value of the reserves would justify the expense of 

recompleting or drilling wells. 

WSO-RMG’s analyses have shown that CBNG depletion had already occurred near 

the mining areas in the Wyodak-Anderson zone by the time that CBNG 

development began to accelerate in the late 1990s (WSO-RMG 2006). Several 

analyses prepared in 2002, based on data compiled by GAGMO in 2000-2001 and 

earlier, show widespread pressure depletion in the coal beds near the active 

mines. Analyses in the southern and northern mine groups, based on 2000 and 

2001 groundwater measurements, indicated that hydrostatic pressure had 

declined by an estimated 20 to 60 percent since mining was initiated. Coal gas in 

place can be inferred to have been depleted by similar proportions. Ongoing 

reservoir depletion from mining and CBNG production has continued to diminish 

gas in place adjacent to the active mines. 

There are active CBNG wells in the northern portion of the West Antelope II LBA 

tract. Before mining operations could begin, these wells and associated facilities 

would have to be abandoned. However, mining operations could not be initiated 

until permitting is completed, which generally requires several years after a lease 

is acquired. By that time, it is likely that the most of the economically recoverable 

CBNG resource would have been produced. CBNG reservoirs below the mineable 

coal seams would not be directly disturbed by surface coal mining operations. 

CBNG resources that have not been recovered from the Wyodak-Anderson zone 

prior to mining would be lost when the coal is removed. Coal seam dewatering in 

advance of, and as a result of, open pit mining also reduces the hydrostatic 

pressure, which may allow CBNG to desorb and escape from the coal bed. 

Coal mining would not directly affect production of CBNG from coal seams below 

the Wyodak-Anderson, however, it would delay any proposed CBNG development 

Draft EIS, West Antelope II Coal Lease Application 3-17 
3.0 Affected Environment and Environmental Consequences 

in the deeper seams in order to avoid interference with mining. 

Section 3.11.1 includes a discussion on the ownership of the oil and gas resources 

on the LBA tract and the oil and gas facilities in the area of the tract. 

3.3.2.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and coal removal would not occur on the West Antelope II LBA tract. 

The limitations to the development of other mineral resources described above and 

in Table 2-4 would continue on the existing adjacent Antelope Mine coal leases 

and on portions of the West Antelope II LBA tract adjacent to the Antelope Mine, 

which would be disturbed to recover the coal in the existing leases. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3.3.2.3 Regulatory Compliance, Mitigation and Monitoring 

No conventional reservoirs containing producible quantities of oil and/or gas are 

known to underlie the West Antelope II LBA tract. There are CBNG wells actively 

producing on the tract, however, the analyses conducted by the BLM’s WSO-RMG 

indicated that most of the recoverable CBNG resources on the tract would be 

produced before mining operations would begin. 

If the federal coal in the tract is leased and conflicts do develop between the 

operators of the oil and gas wells and the surface coal mine operator, there are 

several mechanisms that can be used to facilitate recovery of the conventional oil 

and gas and CBNG resources prior to mining: 

•	 BLM will attach a Multiple Mineral Development stipulation to the 

federal coal lease, which states that BLM has the authority to withhold 

approval of coal mining operations that would interfere with the 

development of mineral leases issued prior to the coal lease (see 

Appendix D). 

•	 Conventional oil and gas wells must be abandoned while mining and 

reclamation operations are in progress but could be recompleted or 

redrilled following mining if the value of the remaining reserves would 

justify the expense of reestablishing production. 

•	 BLM has a policy in place on CBNG-coal conflicts (BLM Instruction 

Memorandum No. 2006-153), which directs BLM decision-makers to 

optimize the recovery of both resources and ensure that the public 

receives a reasonable return (BLM 2006d). This memorandum offers 

royalty incentives to CBNG operators to accelerate production in order 

3-18 Draft EIS, West Antelope II Coal Lease Application 
 3.0 Affected Environment and Environmental Consequences 

to recover the natural gas while simultaneously allowing uninterrupted 

coal mining operations. In addition, this memorandum also states that 

it is the policy of the BLM to encourage oil and gas and coal companies 

to resolve conflicts between themselves; when requested, the BLM will 

assist in facilitating agreements between the companies. 

•	 Mining of the West Antelope II LBA tract cannot occur until the coal 

lessee has a permit to mine the tract approved by the WDEQ/LQD and 

a MLA mining plan approved by the Secretary of the Interior. Before the 

MLA mining plan can be approved, BLM must approve the R2P2 for 

mining the tract. Prior to approving the R2P2, BLM can review the 

status of CBNG and conventional oil and gas development on the tract 

and the mining sequence proposed by the coal lessee. The permit 

approval process generally takes the coal lessee several years, during 

which time CBNG resources can continue to be recovered. 

•	 Prior to mining the federal coal, the coal lessee can negotiate an 

agreement with owners and operators of existing oil and gas facilities on 

the tract, including owners and operators of oil and gas well and 

pipeline facilities, regarding removal and relocation of those facilities 

prior to mining. 

3.3.2.4 Residual Impacts 

CBNG resources not recovered prior to mining would be vented to the atmosphere 

and permanently lost. 

3.3.3 Paleontology 

3.3.3.1 Affected Environment 

The formations exposed on the surface of the West Antelope II LBA tract are the 

sedimentary Paleocene Fort Union and Eocene Wasatch Formations, which are 

known to produce fossil vertebrates of scientific significance throughout Wyoming, 

including the PRB (Delson 1971, Winterfeld 1978, EVG 2001). The Probable 

Fossil Yield Classification, developed by the USFS and used by the BLM, is a 

planning tool used to classify geological units, usually at the formation or member 

level, according to the probability that they will yield paleontological resources 

that are of concern to land managers. This classification system is based largely 

on how likely a geologic unit is to produce scientifically significant fossils. BLM 

considers the Wasatch Formation to fulfill either the PFYC Class 4 or Class 5, 

depending on the nature of bedrock exposures present. The Fort Union Formation 

is classified as a Class 3 unit (BLM 2005c). PFYC classes 3, 4 and 5 are described 

as follows: 

Class 3 - Fossiliferous sedimentary geologic units where fossil content varies 

in significance, abundance, and predictable occurrence. 

Draft EIS, West Antelope II Coal Lease Application 3-19 
3.0 Affected Environment and Environmental Consequences 

Class 4 - These geologic units are Class 5 units (see below) that have lowered 

risks of human-caused adverse impacts and/or lowered risk of natural 

degradation. 

Class 5 - Fossiliferous geologic units that regularly and predictably produce 

vertebrate fossils and/or scientifically significant non-vertebrate (plant and 

invertebrate) fossils, and that are at risk of natural degradation and/or 

human-caused adverse impacts. 

Although the Wasatch Formation is known to produce fossil vertebrates of 

scientific significance in Wyoming, outcrops of the Wasatch Formation in the PRB 

are not generally well-exposed and the conditions of deposition of the formation 

have contributed to a low preservation potential for fossils. Vertebrate fossils that 

have been described from the Wasatch Formation include mammals such as early 

horses, tapiroids, condylarths, primates, insectivores, marsupials, creodonts, 

carnivores, and multituberculates; reptiles such as crocodilians, alligators, lizards, 

and turtles; birds; eggs; amphibians; and fish. Non-marine invertebrates such as 

mollusks and ostracods have also been described from the Wasatch. 

The Fort Union Formation is not as widely distributed as the Wasatch Formation, 

but occurs around the margins of the basin. This formation contains locally 

abundant fossil vertebrates, invertebrates, and plants, and displays an important 

time interval during the early Tertiary evolution of mammals. Invertebrate trace 

fossils (burrows) occur in sandstones in the Fort Union Formation. 

Fossil plant material, primarily leaves and fossilized wood, is common in the Fort 

Union and Wasatch Formations. The leaves usually occur as lignitic impressions 

in sandstone and siltstone and as compact masses in shale. Leaves are the most 

abundant fossils found during paleontological surveys and are frequently 

encountered during mining operations. Fossilized wood often occurs near the top 

of a coal seam, in carbonaceous shale or within channel sandstone. Exposures of 

fossil logs are common, but usually very fragmentary. Like fossil leaves, fossil logs 

can be readily collected in the PRB. 

The West Antelope II general analysis area was covered by pedestrian surveys, 

either specifically for paleontological resources in 2007 or in conjunction with 

cultural Class II block clearance surveys in previous years. All but the extreme 

southeastern corner of the general analysis area was included in those pedestrian 

surveys. The 1⁄4-mile strip in Sections 16 and 21-23, T40N, R71W was assessed 

based on comparisons between existing BLM fossil records and maps for the 

project area and results from extension field coverage of adjacent lands. 

Intensive pedestrian inventories by GCM Services (Ferguson 1998, 2000, 2001, 

2003; Munson and Ferguson, 1996; and Humphrey and Kingham, 1993) included 

inspections for paleontological resources. Fossil wood was observed at many 

unrecorded locations, particularly associated with coal. Invertebrate remains of 

mollusks, bivalves and gastropods were occasionally observed within weathering 

3-20 Draft EIS, West Antelope II Coal Lease Application 
 3.0 Affected Environment and Environmental Consequences 

shale exposures. These were typically fragmentary and are considered to be of 

minimal scientific significance. Because of the ubiquitous nature of fossilized 

plants and invertebrates, reporting was confined to vertebrate specimens or 

unique finds. None of these projects reported vertebrate specimens or unique 

finds. 

During 2007, the 240-acre tract on USFS lands in the general analysis area (W1⁄2 

E1⁄2 Section 15; SE1⁄4 SE1⁄4 Section 15; and SW1⁄4 SW1⁄4 Section 14) was intensively 

inventoried by foot. Fossilized wood, leaves and plant fragments, and invertebrate 

trace fossils (including Planolites) were observed, recorded and collected at several 

localities in SW1⁄4 SW1⁄4 Section 14, and in NW1⁄4 SE1⁄4 and SE1⁄4 SE1⁄4 Section 15. 

Just beyond the 240 acres, fossil wood in SE1⁄4 SW1⁄4 Section 15 and invertebrate 

trace fossils in NW1⁄4 NW1⁄4 Section 23 were observed and recorded. All areas 

covered in this paleontological survey were within the Paleocene Fort Union 

Formation. 

No significant or unique paleontological resource localities have been recorded on 

federal lands in the general analysis area, no specific mitigation was 

recommended for paleontology and no additional paleontological work is 

recommended. 

3.3.3.2 Environmental Consequences 

3.3.3.2.1 Proposed Action and Alternatives 1 and 2 

The rock outcrops present on the West Antelope II LBA tract were examined for 

the presence of fossils, as discussed above, and no scientifically significant fossils 

were located. Fossils with scientific significance could be present on the tract but 

not exposed at the surface. If the tract is leased under the Proposed Action or 

Alternatives 1 and 2, paleontological resources located on the tract that are not 

exposed on the surface would be destroyed when the overburden is removed. 

3.3.3.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II lease application would be 

rejected and coal removal would not occur on the West Antelope II LBA tract. 

Mining operations and the potential associated impacts to paleontological 

resources described above would continue as permitted on the existing adjacent 

Antelope Mine coal leases and on portions of the West Antelope II LBA tract 

adjacent to the Antelope Mine which would be disturbed to recover the coal in the 

existing leases. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

Draft EIS, West Antelope II Coal Lease Application 3-21 
3.0 Affected Environment and Environmental Consequences 

3.3.3.3 Regulatory Compliance, Mitigation and Monitoring 

If the West Antelope II LBA tract is leased, BLM will attach a stipulation to the 

lease requiring the operator to report significant paleontological finds to the 

authorized federal agency and suspend production in the vicinity of the find until 

an approved paleontologist can evaluate the paleontological resource (Appendix 

D). 

3.3.3.4 Residual Impacts 

Paleontological resources that are not identified and removed prior to or during 

mining operations would be lost. 

3.4 Air Quality 

The information in this section and in the air quality appendix (Appendix F) is 

based on the Air Quality Technical Support Document prepared for ACC by 

McVehil-Monnett Associates, Inc. for use in this EIS. The Air Quality Technical 

Support Document (MMA 2007) is a stand alone document which is available for 

review. This section summarizes the affected environment in the area of the 

Antelope Mine and the potential environmental impacts if the West Antelope II 

LBA tract is leased and mined. Appendix F provides background information on 

the air quality regulatory framework, regional conditions, dispersion model 

methodology, the BACT process, etc. Existing and projected cumulative air 

quality impacts are discussed in Section 4.2.3. 

3.4.1 Background 

The air quality of any region is controlled primarily by the magnitude and 

distribution of pollutant emissions and the regional climate. The transport of 

pollutants from specific source areas can also be strongly affected by local or 

regional topography and microscale and mesoscale meteorological effects. In the 

mountainous western United States, topography is particularly important in 

channeling pollutants along valleys, creating upslope and downslope circulations 

that may entrain airborne pollutants, and blocking the flow of pollutants toward 

certain areas. Generally, local effects are superimposed on the overall weather 

patterns and are most important when the large-scale wind flow is weak. 

The general analysis area, shown in Figure 3-1, is located in the southern portion 

of the PRB, a part of the Northern Great Plains that includes most of northeastern 

Wyoming. As discussed in Section 3.2.1, the topography is primarily rolling plains 

and tablelands of moderate relief (with occasional valleys and buttes). Elevations 

range from about 4,500 ft to 5,100 ft above sea level. The climate in the general 

analysis is semiarid with relatively short warm summers and longer cold winters. 

Evaporation exceeds annual precipitation. Section 3.1.1 includes additional 

information about the climate in the general analysis area. 

3-22 Draft EIS, West Antelope II Coal Lease Application 
 3.0 Affected Environment and Environmental Consequences 

Air Quality regulations applicable to surface coal mining may include 

NAAQS/WAAQS, PSD, NSPS, and the Federal Operating Permit Program (Title V). 

These regulatory programs are described in Appendix F. Air pollution impacts are 

limited by local, state, tribal, and federal air quality regulations and standards, 

and state implementation plans, or SIPs, established under the federal CAA and 

the CAAA of 1990. In Wyoming, air pollution impacts are managed by 

WDEQ/AQD under the WAQSR and the EPA-approved SIP. 

3.4.1.1 Emission Sources 

Air quality conditions in rural areas are probably better than in large 

urban/industrial centers. Rural areas generally have a smaller number of 

emission sources (few industrial facilities and residential emissions in the 

relatively small communities and isolated ranches) and favorable atmospheric 

dispersion conditions which can result in relatively low air pollutant 

concentrations. Occasional high concentrations of CO and particulate matter may 

occur in more urbanized areas (for example, the cities of Gillette, Sheridan, and 

Buffalo) and around industrial facilities in these areas, especially under the stable 

atmospheric conditions that occur during winter. 

Surface coal mining activities generate fugitive dust and particulate and gaseous 

tailpipe emissions from large mining equipment. Specifically, activities such as 

blasting, excavating, loading and hauling of overburden and coal, and wind 

erosion of disturbed and unreclaimed mining areas produce fugitive dust. Coal 

crushing, storage, and handling facilities are the most common stationary or point 

sources associated with surface coal mining and preparation. Particulate matter 

is the pollutant emitted from coal mine point sources, although small amounts of 

gaseous pollutants are emitted from small boilers and off-road diesel engines. 

Wyoming’s ambient air standards for particulates are shown in Table 3-3. 

Blasting is responsible for another type of emission from surface coal mining. 

Overburden blasting sometimes produces gaseous, orange-colored clouds that 

contain NO2. Exposure to NO2 may have adverse health effects, as discussed in 

Section 3.4.3. NO2 is one of several products resulting from the incomplete 

combustion of explosives used in the blasting process. Wyoming’s ambient air 

standards for NO2 are shown in Table 3-3. 

Other types of air pollutant emission sources within the PRB include: 

•	 CO and NOx from internal combustion engines used at natural gas and CBNG 

pipeline compressor stations; 

•	 CO, NOx, PM10, PM2.5, SO2, and VOCs from gasoline and diesel vehicle tailpipe 

emissions; 

•	 Particulate matter (dust) generated by vehicle travel on unpaved graded roads, 

agricultural activities such as plowing, and paved road sanding during the 

winter months, as well as windblown dust from neighboring areas; 

Draft EIS, West Antelope II Coal Lease Application 3-23 
3.0 Affected Environment and Environmental Consequences 

Table 3-3. Assumed Background Air Pollutant Concentrations, Applicable AAQS, and PSD Increm

Averaging Background Primary Secondary PSD C

Pollutant WAAQS Time1	 Concentration NAAQS2 NAAQS2 Increme

Carbon 1-hour 3,3364 40,000 40,000 40,000 None 

monoxide 8-hour 1,381 10,000 10,000 10,000 None 

Nitrogen dioxide Annual 55 100 100 100 2

Ozone	 8-hour 706 157 157 157 None 

Sulfur dioxide	 3-hour 1817 None 1,300 1,300 25 

24-hour 627 365 None 260 5 

Annual 137 80 None 60 2 

PM108	 24-hour 549 150 150 150 8 

Annual 1210 None None 50 4 

PM2.58	 24-hour 1311 35 35 65 None 

Annual 4.011 15 15 15 None 

1	 Annual standards are not to be exceeded; short-term standards are not to be exceeded more than once per year. 

2	 Primary standards are designed to protect public health; secondary standards are designed to protect public welfa

3	 All NEPA analysis comparisons to the PSD increments are intended to evaluate a threshold of concern and do not 

Increment Consumption Analysis. 

4	 Data collected by Amoco at Ryckman Creek for an eight-month period during 1978-1979, summarized in the Riley 5	 Data collected at TBNG, Campbell County, Wyoming in 2002. 6	 Data collected at TBNG, Campbell County, Wyoming in 2002-2004 (8-hour 4th high). 7	 Data collected by Black Hills Power & Light at Wygen 2, Campbell County, Wyoming, in 2002. 8	 On October 17, 2006, EPA published final revisions to the NAAQS for particulate matter that took effect on Decem

strengthens the 24-hour PM2.5 standard from 65 to 35 μg/m3 and revokes the annual PM10 standard of 50 μg/m3. Th

into rulemaking to revise the WAAQS. 

9 Data collected at the Eagle Butte Mine in 2002. 10 Background determination developed for recent permitting actions at the Antelope Mine, based on data collected a11 Data collected at Buckskin Mine in 2002 

Source: (BLM 2005a) and WDEQ/AQD 

3-24 Draft EIS, West Antelope 
3.0 Affected Environment and Environmental Consequences 

•	 NO2 and PM10 emissions from railroad locomotives used to haul coal; 

•	 SO2 and NOx from power plants. The closest coal-fired power plants are the 

Dave Johnston plant, located about 35 miles southwest of the West Antelope 

II LBA tract, and the Wyodak, Wygen, and Neil Simpson plants, located about 

50 miles north of the West Antelope II LBA tract; and 

•	 Air pollutants transported from emission sources located outside the PRB. 

3.4.2 Particulate Emissions 

3.4.2.1 Affected Environment for Particulate Emissions 

The federal standard for particulate matter pollutant was specified as total 

suspended particulates until 1987. This measurement included all particulates 

generally less than 100 microns in diameter. In 1987, the form of the standard 

was changed from TSP to PM10 to better reflect human health effects. PM10 

represents particulate matter with a mean aerodynamic diameter of 10 microns or 

less that can potentially penetrate into the lungs and cause health problems. In 

1997, EPA set separate standards for fine particles (PM2.5), based on their link to 

serious health problems. In 2006, EPA revised the air quality standards for 

particulate matter by tightening the 24-hour fine particle standard from the 

previous level of 65 μg/m3 to 35 μg/m3 and revoking the annual PM10 standard of 

50 μg/m3. EPA retained the existing annual PM2.5 standard of 15 μg/m3 and the 

24-hour PM10 standard of 150 μg/m3. These revisions took effect on December 18, 

2006. The current federal ambient air standards are shown in Table 3-3. 

While retaining the TSP standard until March 2000, Wyoming added the PM10 

standard in 1989. Wyoming also adopted a PM2.5 standard in March 2000. In 

view of the December 2006 revisions to the NAAQS for particulate matter, the 

State of Wyoming will enter into rulemaking to revise the WAAQS for particulate 

matter so that they remain as stringent as or more stringent than the NAAQS. 

Even with the evolution of state or federal small size particulate standards, TSP is 

still monitored in some PRB locations as a surrogate for PM10 and as an indication 

of overall atmospheric levels of particulate matter. 

WDEQ/AQD requires monitoring data to document the air quality at all of the 

PRB mines. TSP and PM10 data have been collected since 1980 and 1989, 

respectively. As a result, over 57,000 TSP and 27,000 PM10 samples were 

collected through 2004. Information about the monitoring network, the data that 

have been collected and PM10 concentration trends since monitoring began is 

included in Appendix F. 

Air quality and meteorological sampling locations for the Antelope Mine are shown 

on Figure 3-5. The wind rose diagram for the Antelope Mine is shown in Figure 3­

2. 

Draft EIS, Antelope Coal Company Lease Application 3-25 
 

3.0 Affected Environment and Environmental Consequences 

!

!

!

#

Campbell County 

Converse County 

North Antelope / Rochelle 

Rail Line 

An telope Road 

B.N.S.F. & U.P RR 

T. 

40 

N. 

R. 72 W. R. 70 W. 

T. 

41 

N. 

T. 

41 

N. 

R. 71 W. 

T. 

40 

N. 

R. 71 W. 

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

Antelope Site 6 

Antelope Site 5 

Antelope Site 4 

7 8 9

8 9 8

7 8 

7 

7 

9 

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5 4 

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1 

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2 

11 

14 

!(59 

LEGEND 

Antelope Mine Permit Boundary 

West Antelope II LBA Tract As Applied For 

Area Added under Alternative 1 

North Tract (Alternative 2) 

South Tract (Alternative 2) 

! PM 10 Monitoring Station 

# Meteorological Station 

£ 0 8,000 16,000 

GRAPHIC SCALE (FEET) 

County Rd. 37 

Meteorological Station 

Figure 3-5. Air Quality and Meteorological Stations at the Antelope Mine. 

3-26 Draft EIS, West Antelope II Coal Lease Application 
 

3.0 Affected Environment and Environmental Consequences 

Figure 3-6 presents the annual PM10 measured at the Antelope Mine monitoring 

sites. These data were collected from 2003 through 2006. Cumulative coal and 

overburden production for the Antelope Mine for these years are also shown in 

this figure. Table 3-4 presents a summary of 24-hour PM10 monitoring data for 

the Antelope Mine for 2003 through 2005. 

0 

20,000,000 

40,000,000 

60,000,000 

80,000,000 

100,000,000 

120,000,000 

Coal/Overburden Production (tons) 

0 

5 

10 

15 

20 

25 

30 

35 

PM10 Concentration (ug/m3 ) 

2003 2004 2005 2006 

Coal Production OB Production Antelope - Site 4 Antelope - Site 5 Antelope - Site 6 

Figure 3-6. Annual Coal Production and Overburden Removal vs. Monitored PM10 for the 

 Antelope Mine 

Table 3-4. Summary of PM10 Monitoring Data for the Antelope Mine 

(24-hr Highest Second-High Concentrations in μg/m3). 

Monitor ID Latitude Longitude 2003 2004 2005 

(degrees N) (degrees W) 

Site 4 43.83 105.45 44 38 40 

Site 5 43.46 105.33 55 65 114 

Site 6 43.48 105.31 65 91 68 

NAAQS 150 150 150 

Source: EPA web page http://www.epa.gov/air/data/reports.html 

Draft EIS, Antelope Coal Company Lease Application 3-27 
3.0 Affected Environment and Environmental Consequences 

There were no monitored exceedances of the PM10 standard in the PRB through 

2000. Between 2001 and 2006, there were 29 monitored exceedances of the 24­

hour PM10 standard at seven operating mines in the Wyoming Powder River Basin 

(WDEQ/AQD 2006a). In early 2007, nine exceedances were monitored at four 

mines. Many of these exceedances occurred in the group of mines located south 

and east of the town of Wright, which is identified as the Wright Area Subregion in 

Chapter 4 of the EIS. Although the Antelope Mine is located in that group of 

mines, most of the exceedances were located roughly ten to fifteen miles north of 

the Antelope Mine. In 2005, one exceedance was recorded at one of the 

monitoring stations at the Antelope Mine, however, that exceedance was 

attributed by WDEQ/AQD to maintenance/construction operations on the 

adjacent railroad line and not to mining operations at the Antelope Mine. In 

general these exceedances are likely attributable to a variety of causes including 

long-term drought conditions, associated high winds, contributions from nonmining sources such as increased traffic on unpaved roads proximate to some of 

the sampling locations, as well as proximity of un-reclaimed mining activity to 

sampler locations. 

PM10 monitoring results for the other mines in the Wright Area Subregion are 

summarized in Table 3-5. 

Table 3-5. Summary of PM10 Monitoring Data for the Wright 

Area Subregion (24-hr Highest Second-High 

Concentrations in μg/m3). 

Site 2003 2004 2005 

North Antelope Rochelle 

NA-5 95 84 149 

NA-6B 91 88 80 

RO-1 88 109 97 

Black Thunder 

31-1 79 105 109 

26-2 123 77 83 

36-1 144 436 112 

E&F 118 94 167 

Relocated #1 107 116 98 

J 92 83 100 

Jacobs Ranch 

JRM-3 75 67 83 

JRM-4 54 52 47 

JRM-5PM 84 109 103 

Source: EPA web page http://www.epa.gov/air/data/reports.html 

3.4.2.2 Environmental Consequences Related to Particulate Emissions 

Particulates include solid particles and liquid droplets that can be suspended in 

air. Particulates, especially fine particles, have been linked to numerous 

respiratory related illnesses and can adversely affect individuals with pre-existing 

heart or lung diseases (EPA 2007a). They are also a major cause of visibility 

3-28 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

impairment in many parts of the United States. While individual particles cannot 

be seen with the naked eye, collectively they can appear as black soot, dust 

clouds, or gray hazes. 

3.4.2.2.1 Proposed Action and Alternatives 1 and 2 

The West Antelope II LBA tract would be mined as an integral part of the Antelope 

Mine under the Proposed Action and Alternatives 1 and 2. ACC projects that the 

Antelope Mine would produce between 36 mmtpy and 42 mmtpy after 2007, 

regardless of whether the LBA tract is leased or not. Comprehensive studies 

demonstrating compliance with applicable ambient air standards would be 

required to obtain a permit modification if ACC proposes to increase their 

permitted production level in the future. 

ACC conducted a modeling analysis for a maximum coal production rate of 42 

mmtpy as part of a request for an air quality permit modification for the Antelope 

Mine submitted in May 2006 and issued by the WDEQ on April 23, 2007. For 

that analysis, mining years 2010 and 2012 were selected as “worst-case” based on 

Antelope Mine-specific and regional LOM emission inventories for PM10 and NOx. 

The highest model-predicted PM10 impact during year 2012 was 49.9 ug/m3 (as 

per WDEQ-AQD AP-4809 Application Analysis for the Antelope Coal Company -

Antelope Mine, dated February 1, 2007, application received May 2006). The 

highest model-predicted PM10 impact during year 2010 was 47.8 ug/m3 (Figures 

3-7 and 3-8). 

As discussed in Section 3.4.1.1, surface coal mines in the Wyoming PRB have not 

been subject to PSD requirements. The PSD rules, which are intended to prevent 

deterioration of air quality, are summarized in Appendix F. Only some fraction of 

the mine emissions included in the WDEQ/AQD air quality permit analyses 

consumes increment based on permits in place in the baseline year of 1997. As a 

result, the concentrations predicted by the WDEQ/AQD air quality permit 

analyses should not be compared to PSD increments. 

In Wyoming, monitoring results have been used in lieu of short-term (24-hour) 

modeling for assessing short-term coal mining-related impacts in the PRB. WDEQ 

has chosen this procedure in accordance with an agreement between EPA and the 

State of Wyoming. That agreement recognizes that appropriate models do not 

exist to accurately predict 24-hour impacts. In accordance with this policy, ACC 

also prepared a demonstration regarding compliance with the 24-hour PM10 

standard. The short-term compliance analysis focused on historical monitoring 

data and continuing employment of BACT on mine-wide emissions and concluded 

that mining operations would not be expected to cause exceedances of the 24­

hour PM10 WAAQS. 

ACC proposes using the same mining methods and emission mitigation methods 

to recover the coal on the West Antelope LBA tract as they are currently using to 

recover the coal on the existing leases. The mine would continue to utilize 

Draft EIS, Antelope Coal Company Lease Application 3-29 
24

 

 

 

 

3.0 Affected Environment and Environmental Consequences 

!

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Campbell County 

Converse County 

North Antelope / Rochelle 

Rail Line 

B.N.S.F. & U.P RR 

Antelope Road 

T. 

40 

N. 

R. 72 W. R. 70 W. 

T. 

41 

N. 

T. 

41 

N. 

R. 71 W. 

T. 

40 

N. 

R. 71 W. 

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

7 8 9

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!(59 

LEGEND 

Ambient Air Boundary 

Haul Roads 

Area Source 

! Receptor Location 

Existing Antelope Mine Federal Coal Leases 

West Antelope II LBA Tract As Applied For 

Area Added under Alternative 1 

North Tract (Alternative 2) £ South Tract (Alternative 2)

0 8,000 16,000 

GRAPHIC SCALE (FEET) 

County Rd. 37 

NOX=65 μg/m3 

PM10=47.8 μg/m3 

Figure 3-7. Maximum Modeled PM10 and NOX Concentrations at the Antelope Mine Ambient Air

 Boundary for the Year 2010. 

3-30 Draft EIS, West Antelope II Coal Lease Application 
24

 

 

 

 

3.0 Affected Environment and Environmental Consequences 

!

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Campbell County 

Converse County 

North Antelope / Rochelle 

Rail Line 

B.N.S.F. & U.P RR 

Antelope Road 

T. 

40 

N. 

R. 72 W. R. 70 W. 

T. 

41 

N. 

T. 

41 

N. 

R. 71 W. 

T. 

40 

N. 

R. 71 W. 

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

7 8 9

8 9 8

7 8 

7 7

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25 30 29 28 27 26 25 30 29 28 

2 

11 

14 

!(59 

LEGEND 

Ambient Air Boundary 

Haul Roads 

Area Source 

! Receptor Location 

Existing Antelope Mine Federal Coal Leases 

West Antelope II LBA Tract As Applied For 

Area Added under Alternative 1 

North Tract (Alternative 2) £ South Tract (Alternative 2)

0 8,000 16,000 

GRAPHIC SCALE (FEET) 

Figure 3-8. Maximum Modeled PM10 and NOX Concentrations at the Antelope Mine Ambient Air

 Boundary for the Year 2012. 

County Rd. 37 

NOX=68 μg/m3 

PM10=49.9 μg/m3 

Draft EIS, West Antelope II Coal Lease Application 3-31
3.0 Affected Environment and Environmental Consequences 

draglines, shovels, and trucks to remove and replace overburden and shovels and 

trucks to remove coal. Facilities shown in the current air quality permit would not 

change as a result of proposed mining of the LBA tract. Haul distances to 

transport the coal to the rail facilities are not expected to increase because 

overland conveyors are likely to be extended into the tract. ACC does not plan to 

change blasting procedures or blast sizes associated with the mining of the LBA 

tract. However, as indicated in Table 3-2, overburden thicknesses are greater and 

coal thicknesses are less on the West Antelope II LBA tract as compared to the 

existing leases at the Antelope Mine. As a result, blasting size and/or frequency 

may need to increase in order to recover the coal included in the tract, which 

could result in an increase in fugitive emissions per ton of coal mined. Therefore, 

blasting-related particulate emissions may increase. However, blasting makes up 

a very small fraction of the overall mine-wide emissions inventory, so the effect on 

mine-wide particulates will be minimal. 

Under the Proposed Action and Alternatives 1 and 2, mine life would be extended 

by up to 13 years, assuming a coal production rate from 36 to 42 mmtpy. If ACC 

acquires the tract, they would need an air quality permit modification from the 

WDEQ-AQD before they could initiate mining operations on the tract. New air 

quality modeling would need to be conducted in support of that application 

demonstrating on-going compliance with all applicable ambient standards. 

The modeling conducted for the current Antelope Mine permit predicted no 

exceedances of the annual PM10 WAAQS at the maximum mining rate proposed for 

the West Antelope II LBA tract. The maximum modeled concentrations predicted 

by the modeling would occur along the northeast portion of the Antelope Mine’s 

permit boundary, along the railroad right-of-way. Mining operations on the LBA 

tract will, in general, generate dust emissions farther from this high impact area. 

As a result, maximum predicted impacts should decrease as the tract is mined. 

Therefore, fugitive dust emissions should remain in compliance with daily and 

annual air quality standards. 

Public exposure to particulate emissions from surface mining operation is most 

likely to occur along publicly accessible roads and highways that pass through the 

areas of mining operations. Occupants of dwellings in the area could also be 

affected. Roads, highways, occupied dwellings, businesses and school bus stops 

in the vicinity of the Antelope Mine and the study area for the West Antelope II 

LBA tract are shown in Figure 3-9. 

3.4.2.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and the Antelope Mine would continue to operate as currently 

permitted. The currently permitted mining operations and projected impacts 

related to PM10 emissions are discussed in Section 3.4.2.2.1, above. Portions of 

the West Antelope II LBA tract adjacent to the Antelope Mine would be disturbed 

to recover the coal in the existing leases, but coal removal would not occur on the 

3-32 Draft EIS, Antelope Coal Company Lease Application 
 

 

2

County Rd. 37 

J 

B N. S. F. . & U P. . RR 

Antelope Rd. 

enne 

3.0 Affected Environment and Environmental Consequences 

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

o
 
 T. T. 

43 43 

2

B N S F & U P . . . . . . RR

22

T. T.

41 o 41

N. o N. 

Campbell County 

Converse County 

2

o Antelope Mine Facilities 

2 2

N. N. !(450

2

o

2

T. T. 

42 42 

N. N. 

T. !(59 T. 

40 

N. 

40 

N. 

lTrail Rd. 

l
 


R. 72 W. R. 71 W. R. 70 W. R. 69 W. 

LEGEND 

County Boundary l Bus Stop £ Township - Range Border Business 

State Highway 2 Occupied Residence 

Paved Road 

Other Roads 

BNSF and UP Rail Line 


 General Analysis Area

o

0 10,000 20,000 30,000
 


GRAPHIC SCALE (FEET)
 


Figure 3-9. Roads, Highways, Occupied Dwellings, Businesses and School Bus Stops in the Vicinity of the 

Antelope Mine and the West Antelope II General Analysis Area. 

Draft EIS, West Antelope II Coal Lease Application 3-33
 

3.0 Affected Environment and Environmental Consequences 

LBA tract and the related impacts would not be extended onto those portions of 

the LBA tract that will not be affected under the current mine plan. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3.4.2.3 Regulatory Compliance, Mitigation, and Monitoring for Particulate 

Emissions 

Control of particulate emissions at all PRB coal mines is accomplished with a 

variety of measures. The WDEQ/AQD permits for all of the surface coal mines in 

the Powder River Basin require the following dust control measures, which are 

considered to be BACT measures: 

1.	 No mines are allowed to have out-of-pit open coal stockpiles. All coal 

removed from the mine pits must be stored in totally enclosed coal silos or 

barns. 

2.	 Unless specifically exempted, all coal mine main access roads must be 

paved. 

3.	 As use and condition warrant, the minor access roads at coal mines which 

are unpaved must be watered or treated with dust suppressants. 

4.	 All coal conveyor transfer points must be shrouded or otherwise enclosed 

to direct coal fines from one belt to the next. 

5.	 The transfer point and crushers within coal processing plants must be 

equipped with control devices and measures specified in individual 

permits. These control devices and measures may include, but are not 

limited to, the use of dust collection baghouses, cyclones, scrubbers, fog 

systems, and controlled flow transfer chutes. 

6.	 All out-of-pit conveyors must be hooded or contained in a conveyor 

gallery. 

7.	 All out-of-pit coal dump hoppers must be fitted with a dust control stilling 

shed, water sprays, or a baghouse dust collector. 

8.	 Active longer-term coal haul roads must be treated with dust control 

chemicals and/or water. 

9.	 Active short-term mine haul roads which must be continuously relocated 

are maintained and watered while in use. 

10. All haul roads must be regularly maintained to reduce the amount of dust 

re-entrained by haulage equipment (WDEQ/AQD 2006a). 

Additional site-specific requirements related to mine-specific layout and mining 

practices may be included in individual mine permits. 

Fugitive emissions are also controlled with a variety of other measures that the 

WDEQ/AQD considers BACT. Haul truck speed limits are imposed to further help 

to reduce fugitive emissions from roads. Material drop heights for shovels and 

draglines (bucket to truck bed or backfill) are limited to the minimum necessary to 

conduct the mining operations. Timely permanent and temporary revegetation of 

3-34 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

disturbed areas is utilized to minimize wind erosion. All of these control measures 

are employed at the Antelope Mine. 

Mines often apply dust suppressants to adjoining county roads. In 2006, the 

Antelope Mine paved its access road. 

In April, 2006, the WDEQ in a joint effort with PRB mining stakeholders developed 

a detailed Natural Events Action Plan or NEAP for the coal mines of Campbell and 

Converse Counties, Wyoming. The NEAP was developed under the framework 

afforded by U.S. EPA’s Natural Events Policy of May 30, 1996. While PRB mining 

operators have already implemented these measures in practice, formal approval 

of the NEAP by EPA Region VIII is still pending. The Antelope Mine is presently 

complying with the NEAP developed jointly by the WDEQ/AQD and the PRB coal 

operators. 

The NEAP recognizes that certain NAAQS exceedances due to natural events are 

uncontrollable. While all practical mitigation measures need be implemented 

during those events, the exceedances should not be considered against the NAAQS 

attainment designation for the region. Specific NEAP goals include: 

•	 Provide for the protection of public health, 

•	 Develop public information program, 

•	 Provide a mechanism for “flagging” exceedances due to uncontrollable 

natural events, 

•	 Implement BACM and RACM based on the severity of the event, and 

•	 Provide mechanism for excluding flagged data when they meet specific 

wind speed criteria and BACM and RACM are in place. 

The NEAP identifies two categories of control measures designed to prevent 

exceedances during high wind events in addition to the BACT measures discussed 

above (WDEQ/AQD 2006a). One of these categories, BACM, is an additional list of 

control measures that the mines can implement continuously so that they are in 

place before a high wind event occurs. These measures are not current 

requirements in all of the mines’ air quality permits. They primarily address the 

principal mine-controlled sources of fugitive dust, which are large contiguous 

disturbed areas. These measures include: 

1. Stabilizing topsoiled areas as soon as practical following topsoil 

replacement. 

2. Ripping, windrowing, mulching, temporarily seeding or chemically treating 

areas greater than 300 contiguous acres in size that have been stripped of 

topsoil but will not be mined in the near future. 

3. Ripping, windrowing, temporarily seeding or chemically treating graded 

backfill areas greater than 300 contiguous acres in size. 

4. Ripping, mulching, temporarily seeding or chemically treating long-term 

out-of-pit overburden and topsoil stockpiles that have been graded. 

Draft EIS, Antelope Coal Company Lease Application 3-35 
3.0 Affected Environment and Environmental Consequences 

5. Applying non-vegetative barriers such as gravel or other large-diameter 

particles to erodible surfaces to reduce surface erosion where appropriate. 

6. Cleaning, treating, and maintaining pads in front of truck dumps to prevent 

accumulations of spilled materials from getting pulverized. 

7. Scheduling topsoil removal, backfill grading and topsoil replacements 

concurrently to minimize open areas when possible. 

8. Requiring contractors to apply water and/or chemical dust suppressants in 

their haulage areas. 

The third category of control measures discussed in the Natural Events Action 

Plan includes measures that are not currently required by all individual air quality 

permits but are actions that can be taken during a high wind event, depending on 

site specific conditions (WDEQ/AQD 2006a). These include: 

1. The mine operator will consider relevant information, including NWS 

forecasts and local meteorological information, to confirm that a high wind 

event is occurring. 

2. The mine operator will visually determine areas of mining activity that are 

generating excessive visible dust and direct water trucks to those areas. 

3. The mine operator should direct overburden operations to the shortest haul 

distance available during a high wind event. 

4. The mine operator will evaluate the practicality of dumping the overburden 

as low as possible. 

5. Mine employees will inspect for and extinguish coal fires. 

6. The mine operator will evaluate shutting down scoria crushing operations 

that appear to be generating excess dust. 

7. The mine operator will evaluate shutting down road maintenance activities 

that are generating dust. 

8. The mine operator will evaluate ordering contractors to increase water, 

reduce operating equipment or shut down haulage. 

9. The mine operator will evaluate the need to shut down and/or reduce 

earthmoving activities as the mine schedule and conditions will allow. 

WDEQ/AQD may require implementation of these control steps and continual 

evaluation of activity plans when exceedances are monitored at surface coal 

mines. Some of these measures have been formally implemented at the Black 

Thunder, Jacobs Ranch, and former North Rochelle mines through the 

establishment of a formal, site-specific mitigative response plan at each of those 

mines. A mitigative response plan will be developed by any mine that records an 

exceedance or violation of the NAAQS downwind of its mining operations. 

Other operational control measures that WDEQ/AQD may require at specific 

mines when exceedances occur include, but are not limited to, site-specific 

watering of inactive areas and problem areas; relocation of overburden truckdumping operations; and deferring blasting. The mines are experimenting with 

dust control treatments, including magnesium chloride, surfactants, and 

petroleum-based products. In addition, WDEQ/AQD may require additional 

3-36 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

monitoring, action levels based on continuous monitoring, expedited reporting of 

monitored exceedances, detailed reporting of contributing factors (e.g., 

meteorological conditions), and continual evaluation of activity plans when 

exceedances are monitored at surface coal mines. 

The WDEQ/AQD is continually reviewing the data and considering regulatory 

options, such as increasing the frequency of monitoring. WDEQ/AQD has 

increased monitoring frequency requirements and required installation of 

continuous PM10 monitors at all PRB coal mines. The agency has initiated 

enforcement actions where appropriate. Notices of violation have been issued on 

occasion, and consent decrees and modified permit conditions have been used as 

tools to mitigate dust problems. WDEQ/AQD is also coordinating with EPA to 

develop additional monitoring requirements in CBNG development areas, high 

PM10 mitigation action plans in permits, and additional mitigation measures under 

the SIP. 

WDEQ has required several mines to stop traffic on public roads during blasting 

due to concerns with fly rock and the “startle factor”. However, the WDEQ has not 

required that of Antelope Mine. Antelope has voluntarily implemented this 

measure from time to time, based on blast location and wind direction. 

The PRB has one of the most extensive networks of monitoring sites for PM10 in 

the nation; most of these monitoring sites are funded and operated by the coal 

mines. WDEQ/AQD requires the collection of information documenting the 

quality of the air resource at each of the PRB mines. A discussion of the 

monitoring network and monitoring requirements is included in Appendix F. 

3.4.3 Emissions of Nitrogen Oxides (NOx) 

3.4.3.1 Affected Environment for NOx Emissions 

Gases that contain nitrogen and oxygen in varying amounts are referred to as 

nitrogen oxides, or NOx. One type of NOx, nitrogen dioxide (NO2), is a highly 

reactive, reddish brown gas that is heavier than air and has a pungent odor. NO2 

is by far the most toxic of several species of NOx. NO2 can combine with 

atmospheric moisture to form nitric acid and nitric oxide. Because several NOx 

species can be chemically converted to NO2 in the atmosphere, NO2 emissions 

control is focused on all NOx species, while the ambient standard is expressed in 

terms of NO2. 

According to the EPA (EPA 2001a): 

•	 NO2 may cause significant toxicity because of its ability to form nitric 

acid with water in the eye, lung, mucous membranes, and skin. 

•	 Acute exposure may cause death by damaging the pulmonary system. 

Draft EIS, Antelope Coal Company Lease Application 3-37 
3.0 Affected Environment and Environmental Consequences 

•	 Chronic or repeated exposure to lower concentrations of NO2 may 

exacerbate pre-existing respiratory conditions, or increase the incidence 

of respiratory infections. 

Nitrogen oxides form when fuel is burned at high temperatures. They can be 

formed naturally or by human activities. The primary manmade sources are 

motor vehicles, electric utilities, and other fuel-burning sources. According to 

EPA, motor vehicles produce about 55 percent of the manmade NOx emissions, 

utilities and industrial/commercial/residential activities each produce about 22 

percent of the manmade NOx emissions, and other sources account for the 

remaining one percent of the manmade emissions (EPA 2007b). 

The primary direct source of emissions of nitrogen oxides during coal mining 

operations is tailpipe emissions from large mining equipment and other vehicle 

traffic inside the mine permit area. Blasting that is done to remove the material 

overlying the coal (the overburden) can result in emissions of several products, 

including NO2, as a result of the incomplete combustion of nitrogen-based 

explosives used in the blasting process. When this occurs, gaseous, orangecolored clouds may be formed and they can drift or be blown off mine permit 

areas. The rate of release is not well known but is believed to be dependent on a 

wide number of factors which likely include, but are not necessarily limited to: 

downhole confinement; downhole moisture; type/blend of ammonium nitrate, fuel 

oil (ANFO), and emulsion; and detonation velocity. 

3.4.3.1.2 Site Specific NOx Emissions 

Sources of NOx emissions at the Antelope Mine include the tailpipe emissions from 

the mining equipment and the emissions from the trains used to haul the coal 

from the mine. There are no NOx point sources at the mine. To date, there have 

been no reported events of public exposure to NO2 from blasting activities at the 

Antelope Mine. The WDEQ has not required the mine to implement any specific 

measures to control or limit public exposure to NO2 from blasting, although cast 

blasting has been conducted at Antelope and will be continued to be implemented 

in the west tract. Antelope has instituted voluntary measures based on blast 

locations and wind direction to mitigate exposure to railroad employees and other 

segments of the population as necessary. 

NOx modeling was also conducted in support of the May 2006 permit application. 

Similar in scope to the PM10 analysis, NOx emissions from the Antelope Mine and 

other regional sources were modeled for the two worst-case years of 2010 and 

2012 (Figures 3-7 and 3-8.) A maximum annual NO2 impact of 67.5 μg/m3 was 

predicted in 2012, as compared to the annual NO2 NAAQS of 100 μg/m3. 

3.4.3.2 Environmental Consequences Related to Short-Term NOx Emissions 

There are various compounds and derivatives in the family of nitrogen oxides, 

including NO2, nitric acid, nitrous oxide, nitrates, and nitric oxide, which may 

3-38 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

cause a wide variety of health and environmental impacts. According to EPA, the 

main causes of concern with respect to NOx are: 

•	 it is one of the main ingredients involved in the formation of ground level 

ozone, which can trigger serious respiratory problems; 

•	 it reacts to form nitrate particles, acid aerosols, as well as NO2, which also 

cause respiratory problems; 

•	 it contributes to the formation of acid rain; 

•	 it contributes to nutrient overload that deteriorates water quality; 

•	 it contributes to atmospheric particles which cause visibility impairment, 

most noticeably in national parks; 

•	 it reacts to form toxic chemicals; 

•	 one member of the NOx family, nitrous oxide or N2O, is a greenhouse gas 

that contributes to global warming; and 

•	 it can be transported over long distances (EPA 2007c). 

Potential health risks associated with inhalation of ground level ozone and NOxrelated particles include acute respiratory problems, aggravated asthma, 

decreases in lung capacity in some healthy adults, inflammation of lung tissue, 

respiratory-related hospital admissions and emergency room visits, and increased 

susceptibility to respiratory illnesses, including bronchitis and pneumonia (EPA 

2007d). 

Neither the EPA nor the WDEQ have established NAAQS for NO2 for averaging 

times shorter than one year. According to EPA, “...the exact concentrations at 

which NO2 will cause various health effects cannot be predicted with complete 

accuracy because the effects are a function of air concentration and time of 

exposure, and precise measurements have not been made in association with 

human toxicity. The information that is available from human exposures also 

suggests that there is some variation in individual response” (EPA 2001a). 

While extensive expert testimony was provided to the Wyoming EQC during 

hearings in 2002 arguing for the establishment of a de facto “standard” ranging 

from 0.5 to 5.0 ppm for a 10-minute exposure, the EQC determined there was 

insufficient evidence to establish a short-term exposure limit and concluded 

additional study was required. The primary control measure for mitigating 

exposures to offsite residences is to avoid shooting cast blasts when wind direction 

or atmospheric conditions are unfavorable. Such approaches are employed at 

Antelope and will be continued to be employed. Studies that have been conducted 

to evaluate NO2 exposures from blast clouds in the PRB are described in Appendix 

F. 

Although there is no NAAQS that regulates short-term NO2 levels, there is concern 

about the potential health risk associated with short-term exposure to NO2 from 

blasting emission. NIOSH, OSHA, and EPA have identified the following shortterm exposure criteria for NO2: 

Draft EIS, Antelope Coal Company Lease Application 3-39 
3.0 Affected Environment and Environmental Consequences 

•	 NIOSH’s recommended Immediately Dangerous to Life and Health level 

is 20.0 ppm (37,600 μg/m3); 

•	 EPA’s Significant Harm Level, a one-hour average, is 2.0 ppm (3,760 

μg/m3); 

•	 OSHA’s Short-Term Exposure Limit, a 15-minute time weighted average, 

which was developed for workers, is 5.0 ppm (9,400 μg/m3, which must 

not be exceeded during any part of the workday, as measured 

instantaneously); 

•	 NIOSH’s recommendation for workers is a limit of 1.0 ppm (1,880 

μg/m3) based on a 15-minute exposure that should not be exceeded at 

any time during the workday; and 

•	 EPA recommends that concentrations not exceed 0.5 ppm (940 μg/m3) 

for a 10-minute exposure to protect sensitive members of the public 

(EPA 2003). 

Blast clouds are of a short-term, transient nature. While disagreement still exists 

regarding acceptable exposure levels, a large amount of actual data are now 

available from which informed decisions can be made regarding blasting practices. 

The data show clearly that reduction in blast (agent) size and increases in setback 

distances are effective methods for mitigating the frequency and extent of public 

exposure to blasting clouds. See Appendix F for additional information about 

studies that were conducted to evaluate the levels of public exposure to NOx. 

3.4.3.2.1 Proposed Action and Alternatives 1 and 2 

The West Antelope II LBA tract would be mined as an integral part of the Antelope 

Mine. The average annual coal production is not anticipated to exceed the 

projected post-2006 coal production rate of 42 mmtpy, with or without the West 

Antelope II LBA tract. Coal production is anticipated to increase to a rate of 42 

mmtpy, then taper off during the mine’s later years, with or without the West 

Antelope II LBA tract. The Antelope Mine’s currently approved air quality permit 

from the WDEQ/AQD allows up to 42 million tons of coal to be mined per year. If 

the mine acquires the additional coal in the LBA tract, they would continue to 

produce between 36 and 42 mmtpy for a longer period of time (up to 13 more 

years). Potential NOx emissions related to mining operations at the existing 

Antelope Mine are described below. 

The WDEQ-AQD has determined that an assessment of annual NOx impacts must 

be included as part of an air quality permitting analysis for new surface coal 

mines and existing mine plan revisions. As discussed in Section 3.4.2.2.1, ACC 

conducted a modeling analysis for PM10 and NOx for a maximum coal production 

rate of 42 mmtpy as part of a request for an air quality permit modification for the 

Antelope Mine submitted in May 2006. On April 23, 2007, WDEQ issued Permit 

3-40 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

MD-1543 for this modification which allows 42 mmtpy production at the mine. 

There have been no reported events of public exposure to NO2 from blasting 

activities at the Antelope Mine through 2005. The mine has, however, employed 

measures to control/limit public exposure to intermittent, short-term (blasting) 

releases as discussed in Section 3.4.3.3. 

Public exposure to emissions caused by surface mining operations is most likely 

to occur along publicly accessible roads and highways that pass through the area 

of the mining operations. Occupants of dwellings in the area could also be 

affected. Figure 3-9 shows occupied dwellings, businesses, and bus stops in the 

vicinity of the West Antelope II LBA tract. If the West Antelope II LBA tract is 

mined, blasting operations will be conducted in closer proximity to Highway 59 

and some residences located west of the existing mine. However, because the 

prevailing wind direction is from the southwest (Figure 3-2), emissions from 

blasting are not expected to substantially affect public exposure. There will be no 

significant changes in blasting techniques except when mining occurs in the LBA 

tract. Because overburden is thicker in the LBA tract, Antelope would employ 

state-of-the-art methods to minimize any increases in blast sizes and/or total 

agent used. Those methods would include, but would not necessarily be limited 

to, the use of more efficient agent formulations and use of electronic detonators. 

Thus, emissions from blasting are not expected to increase significantly, 

notwithstanding the large overburdens to be excavated in the tract. 

If ACC acquires the West Antelope II LBA tract, current mining techniques (i.e., 

blasting, excavating, hauling, etc.) would be expected to continue for a longer 

period of time than is shown in the currently approved air quality permit. 

Modeling for the current Antelope Mine permit projected no exceedances of the 

annual NOx NAAQS at a 42 mmtpy production. Therefore, air quality impacts that 

result from mining the West Antelope II LBA tract by the applicant should also be 

within annual NAAQS limits. 

3.4.3.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and the mine would continue to operate as currently permitted. A 

discussion of the currently permitted mining operations and projected impacts 

related to NOx emissions is included in Section 3.4.3.2.1, above. Portions of the 

West Antelope II LBA tract adjacent to the Antelope Mine would be disturbed to 

recover the coal in the existing leases, but coal removal would not occur on the 

LBA tract and the related impacts would not be extended onto those portions of 

the LBA tract that will not be affected under the current mine plan. As discussed 

in Section 2.2, a decision to reject the West Antelope II lease application at this 

time would not preclude an application to lease the tract in the future. 

Draft EIS, Antelope Coal Company Lease Application 3-41 
3.0 Affected Environment and Environmental Consequences 

3.4.3.3 Regulatory Compliance, Mitigation, and Monitoring for NOx Emissions 

Several of the surface coal mines in the PRB have undertaken voluntary blasting 

restrictions to avoid NOx impact to the public. WDEQ has required several mines, 

including North Antelope Rochelle, Black Thunder, Belle Ayr, Eagle Butte, and 

Wyodak (Figure 1-1), to stop traffic on public roads during blasting due to 

concerns with fly rock and the “startle factor”. However, the WDEQ has not 

required that of Antelope Mine. The mine has voluntarily implemented this 

measure from time to time, based on blast location and wind direction. 

To date, there have been no reported events of public exposure to NO2 from 

blasting activities at the Antelope Mine. The WDEQ has not required the mine to 

implement any specific measures to control or limit public exposure to NO2 from 

blasting, although the mine has voluntarily committed to control blasting 

emissions. 

Voluntary measures that have been instituted, particularly when large blasts are 

planned include: 

•	 neighbor telephone notification (both private parties and other mining 

operations) in the general area of the mine prior to large blasts; 

•	 monitoring of weather and atmospheric conditions prior to the decision 

to detonate a large blast; 

•	 minimizing blast size to the extent possible; 

•	 posting of signs on major public roads that enter the general mine area 

and on all locked gates accessing the active mine area; 

•	 closing public roads that enter the general mine area, depending on 

wind conditions and blast location with respect to the road; and 

•	 providing post-blast notification to neighbors of potential exposure to 

the blasting cloud. 

After WDEQ received reports of public exposure to NO2 from blasting operations at 

some of the PRB mines prior to 2001, measures to prevent future such incidences 

were instituted at those mines when large overburden blasts are planned. Two 

mines in the Wyoming PRB, Black Thunder and Eagle Butte, currently have 

blasting restrictions in their permits to address NOx. 

Measures that have been instituted as mine permit requirements include: 

•	 notification of neighbors and workers in the general area of the mine 

prior to the blast; 

3-42 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

•	 blast detonation between 12:00 p.m. and 3:00 p.m. whenever possible 

to avoid temperature inversions and minimize inconvenience to 

neighbors; 

•	 monitoring of weather and atmospheric conditions prior to the decision 

to detonate a blast; 

•	 posting of signs on major public roads that enter the general mine area 

and on all locked gates accessing the active mine area; 

•	 closing public roads when appropriate to protect the public; and 

•	 establishment of safe setback distances for blasting operations from the 

mine boundary. 

Mine operators in the PRB have also been working with blasting agent 

manufacturers to reduce NOx emissions. Efforts to eliminate NOx production have 

included use of different blasting agents, different blends of blasting agents, 

different additives, different initiation systems and sequencing, borehole liners, 

and smaller cast blasts. Operators have tried adding substances like 

microspheres and rice hulls, using different blends of ANFO and slurries and gels, 

using electronic detonation systems that can vary shot timing, different shot hole 

patterns, and using plastic liners within the shot holes. No one single procedure 

or variation has proven consistently successful due to the numerous factors that 

are believed to contribute to the production of NO2. The most successful control 

measure has been reducing the size of the cast blasting shots (Emme 2003, 

Chancellor 2003). The Eagle Butte Mine, which does not use cast blasting 

techniques, has almost eliminated NOx production. The North Antelope Rochelle 

Mine has had success in eliminating NOx in over 75 percent of their cast blasting 

through the use of borehole liners and changing their blasting agent blends 

(Chancellor 2003). Both mines are shown in Figure 1-1. 

Annual mean NO2 concentrations have been periodically measured in the PRB 

since 1975. NO2 was monitored in Gillette from 1975 through 1983 and then 

from 2003 to 2006 in the PRB. The results of these monitoring programs are 

summarized in Tables 3-6 and 3-7. 

NO2 data have been measured in the vicinity of the Antelope Mine since 2003. The 

maximum annual average NO2 concentration measured at the Antelope site was 

9.4 μg/m3 in 2005 and again in 2006, as compared to the NAAQS of 100 μg/m3 

(Table 3-7). 

Due to public concerns about emissions of nitrogen dioxides as a result of blasting 

and a general concern of the WDEQ about levels of nitrogen dioxides as a result of 

development of all types in the PRB, the coal mining industry instituted a 

monitoring network in cooperation with WDEQ/AQD to gather data on NO2 

beginning in 2001. Industry funded and operated the network for approximately 

Draft EIS, Antelope Coal Company Lease Application 3-43 
 

 

 

 

 

 

3.0 Affected Environment and Environmental Consequences 

three years. The WDEQ now funds and operates the NO2 monitoring network 

along the east side of the basin. Ownership of the monitoring equipment was 

transferred to WDEQ by the mines and the mines have given ongoing access to the 

monitoring sites and provide electrical power for the instrumentation. 

WDEQ/AQD and respective mines maintain these monitoring stations. The 

WDEQ/AQD is relying on the ongoing monitoring data and emission inventories in 

air quality permit applications to demonstrate compliance with the annual NO2 

ambient air standard (Table 3-3). 

Table 3-6. Annual Ambient NO2 Concentration Data (μg/m3). 

Black 

Site Gillette, WY 

Thunder 

Mine 

Belle Ayr 

Mine Bill, WY 

Percent of Percent of Percent of Percent of 

Year Standard1 Standard1 Standard1 Standard1 

1975 6* 

1976 4* 1* 

1977 4* 5* 

1978 11* 

1979 11 

1980 12 

1981 14 

1982 11 

19832 17 

19963 16 16 22 22 

1 Based on arithmetic averaging of data. 2 Monitoring discontinued December 1983, reactivated March 1996 to April 1997.
 3 Arithmetic average – actual sampling ran from March 1996 to April 1997. 

* Inadequate number of samples for a valid annual average. 

Source: (McVehil-Monnett 1997) 

Table 3-7. 2003 Through 2006 Annual Ambient NO2 Concentration Data 

(μg/m3). 

Belle Ayr 

Year Antelope Mine Mine TBNG Tracy Ranch 

2003 7.5 13.2 5.6 

2004 7.5 13.2 3.8 7.5 

2005 9.4 15 3.8 

2006 9.4 15 3.8 

Source: EPA AIRDATA website 

3-44 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

3.4.4 Air Quality Related Values (AQRVs) 

AQRVs are evaluated by the land management agency responsible for a Class I 

area, according to the agency’s level of acceptable change (LAC). These AQRVs 

include potential air pollutant effects on visibility and the acidification of lakes 

and streams. The AQRVs, and the associated LAC, are applied to PSD Class I and 

sensitive Class II areas and are the land management agency’s policy and are not 

legally enforceable as a standard. 

3.4.4.1 Visibility 

Visibility refers to the clarity with which scenic vistas and landscape features are 

perceived at great distances. Visibility can be defined as the distance one can see 

and the ability to perceive color, contrast, and detail. Fine particulate matter 

(PM2.5) is the main cause of visibility impairment. Visual range, one of several 

ways to express visibility, is the furthest distance a person can see a landscape 

feature. Without the effects of human-caused air pollution, a natural visual range 

is estimated to be about 140 miles in the western U.S. and 90 miles in the eastern 

U.S. (EPA 2001b). 

Visibility impairment is expressed in terms of deciview (dv). The dv index was 

developed as a linear perceived visual change (Pitchford and Malm 1994), and is 

the unit of measure used in the EPA’s Regional Haze Rule to achieve the National 

Visibility Goal. The National Visibility Goal was established as part of the CAA in 

order to prevent any future, and remedy any existing, impairment of visibility in 

mandatory Federal Class I areas that result from manmade air pollution. The 

deciview index is a scale related to visual perception that has a value near zero for 

a pristine atmosphere. A change in visibility of 1.0 dv represents a “just 

noticeable change” by an average person under most circumstances. Increasing 

dv values represent proportionately larger perceived visibility impairment. 

3.4.4.1.1 Affected Environment for Visibility 

AQRVs, including the potential air pollutant effects on visibility, are applied to 

PSD Class I and Class II areas. The land management agency responsible for the 

Class I area sets an LAC for each AQRV. The AQRVs reflect the land management 

agency’s policy and are not legally enforceable standards. Table 3-8 shows the 

distances from 31 PSD Class I and Class II areas in the vicinity of the PRB and 

their distance from the West Antelope II general analysis area. 

The Wyoming State Implementation Plan for Class I Visibility Protection 

states:“Wyoming’s long term strategy will focus on the prevention of any future 

visibility impairment in Class I areas that can be attributed to a source or small 

group of sources as the Federal Land Managers have not identified any current 

impairment in the State’s Class I areas due to such sources” (WDEQ/AQD 2005d). 

WDEQ/AQD prepared the 2003 Review Report on Wyoming’s Long Term Strategy 

for Visibility Protection in Class I Areas, as required by WAQSR, which calls for AQD 

Draft EIS, Antelope Coal Company Lease Application 3-45 
 

3.0 Affected Environment and Environmental Consequences 

Table 3-8. Approximate Distances and Directions from the West Antelope II 

General Analysis Area to Mandatory Federal Class I, Tribal Class I, 

and Federal Class II PSD Areas. 

Distance Direction to 

Receptor Area (miles) Receptor 

Mandatory Federal PSD Class I Area 

Badlands Wilderness Area1 152 E 

Bridger Wilderness Area 219 W 

Fitzpatrick Wilderness Area 217 W 

Gates of the Mountain Wilderness Area 401 NW 

Grand Teton National Park 275 W 

North Absaroka Wilderness Area 256 WNW 

Red Rocks Lake Wilderness Area 330 WNW 

Scapegoat Wilderness Area 440 NW 

Teton Wilderness Area 234 WNW 

Theodore Roosevelt National Park (North Unit) 275 NNE 

Theodore Roosevelt National Park (South Unit) 259 NNE 

U.L. Bend Wilderness Area 266 NNW 

Washakie Wilderness Area 239 WNW 

Wind Cave National Park 94 E 

Yellowstone National Park 269 WNW 

Tribal Federal PSD Class I 

Fort Peck Indian Reservation 329 N 

Northern Cheyenne Indian Reservation 155 NNW 

Federal PSD Class II 

Absaroka-Beartooth Wilderness Area 255 WNW 

Agate Fossil Beds National Monument 109 SE 

Bighorn Canyon National Recreation Area 182 NW 

Black Elk Wilderness Area 94 ENE 

Cloud Peak Wilderness Area 108 NW 

Crow Indian Reservation 183 NW 

Devils Towner National Monument 86 NNE 

Fort Belknap Indian Reservation 363 NNW 

Fort Laramie National Historic Site 97 SSE 

Jewel Cave National Monument 78 ENE 

Mount Rushmore National Memorial 98 ENE 

Popo Agie Wilderness Area 202 WSW 

Soldier Creek Wilderness Area 127 ESE 

The U.S. Congress designated the Wilderness Area portion of Badlands National Park as a mandatory 

Federal PSD Class I area. The remainder of Badlands National Park is a PSD Class II area. 

3-46 Draft EIS, Antelope Coal Company Lease Application 

1 
3.0 Affected Environment and Environmental Consequences 

to review and revise, if appropriate, the Long Term Strategy every three years. The 

2003 Review Report is available on the WDEQ/AQD website at 

http://deq.state.wy.us/aqd/visibility.asp. 

The Regional Haze Rule calls for improved visibility on the most impaired days and 

no additional impairment on the least-impaired days. EPA participates in the 

IMPROVE visibility monitoring program as part of its visibility protection program. 

The IMPROVE monitoring sites were established to be representative of all Class I 

areas. Figure 3-10 shows annual averages for the 20 percent best, average, and 

worst visibility days at Badlands and Bridger Wilderness Areas from 1989 through 

2004. To date, Badlands National Park has statistically shown improved visibility 

on the least impaired days and no change in visibility on the average and most 

impaired days. Bridger Wilderness has shown no statistically significant change 

in visibility on the least, average, or most impaired days (IMPROVE 2005). 

3.4.4.1.2 Environmental Consequences for Visibility 

3.4.4.1.2.1 Proposed Action and Alternatives 1 and 2 

The impacts to visibility from mining the West Antelope II LBA tract have been 

inferred from the currently permitted impacts of mining the existing coal leases at 

the Antelope Mine. The West Antelope II LBA tract would be mined as an integral 

part of the Antelope Mine. The maximum annual coal production is not 

anticipated to exceed the projected post-2006 rate of up to 42 mmtpy, with or 

without the West Antelope II LBA tract. ACC’s currently approved air quality 

permit allows up to 42 million tons of coal to be mined per year. If the mine 

acquires the additional coal in the LBA tract, they anticipate that the coal 

production rate would continue to be between 36 and 42 mmtpy for up to 13 

additional years. Therefore, impacts to visibility under the Proposed Action and 

Alternatives 1 and 2 would be similar to the impacts under the No Action 

Alternative, but they would be extended by as many as 13 years. 

Current mining techniques for blasting, coal removal, and coal hauling would be 

expected to continue for a longer period of time than is shown in the currently 

approved air quality permit. Material movement would continue to utilize shovels 

and trucks in overburden and coal. ACC does not propose to change the facilities 

shown in the current air quality permit or the blasting procedures or blast sizes if 

they acquire the tract; however, the blasting processes and required mitigation 

measures would be reviewed when the mining permit is amended to include the 

new lease area. At that time, the blasting plan would be reviewed and modified to 

incorporate the BACT protection measures that are in effect at that time. No 

significant changes in blasting techniques are proposed except when mining 

occurs in the LBA tract. However, because overburden is thicker in the LBA tract, 

Antelope will employ state-of-the-art methods to minimize any increases in blast 

sizes and/or total agent used. Those methods will include, but not necessarily be 

limited to, the use of more efficient agent formulations and use of electronic 

detonators. Thus, emissions from blasting are not expected to increase 

Draft EIS, Antelope Coal Company Lease Application 3-47 
 

 

 

 

 

3.0 Affected Environment and Environmental Consequences 

Visibility in Bridger Wilderness 

20
 

18
 

16
 

14
 

12
 

20% Cleanest
 

10
 Average
 

20% Haziest
 

8
 

6
 

4
 

2
 

0
 

1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004
 

IMPROVE Station:BRID1 

Visibility (dv) Visibility (dv)

Visibility in Badlands National Park 

20
 

18
 

16
 

14
 

12
 

20% Cleanest
 

10
 Average
 

20% Haziest
 

8
 

6
 

4
 

2
 

0
 

1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004
 

IMPROVE Station: BADL1 

Figure 3-10. Visibility in the Badlands and Bridger Wilderness Areas. 

3-48 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

significantly, notwithstanding the large overburdens to be excavated in the tract. 

Surface coal mines are not considered to be major emitting facilities in accordance 

with Chapter 6, Section 4 of WDEQ/AQD Rules and Regulations. Therefore, the 

State of Wyoming does not require mines to evaluate their impacts on Class I 

areas; however, BLM considers such issues during leasing. 

3.4.4.1.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and the mine would continue to operate as currently permitted. 

Portions of the West Antelope II LBA tract adjacent to the Antelope Mine would be 

disturbed to recover the coal in the existing leases, but coal removal would not 

occur on the LBA tract and there would not be visibility impacts related to mining 

any portions of the LBA tract that will not be affected under the current mine 

plan. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3.4.4.1.3 Regulatory Compliance, Mitigation and Monitoring for Visibility Impacts 

As discussed above, fine particulate matter (PM2.5) is the main cause of visibility 

impairment. Mitigation measures being used to limit emissions of particulate 

matter are discussed in Section 3.4.2.3. 

Visibility monitoring within the State of Wyoming consists of both the WDEQ/AQD 

sponsored Wyoming Visibility Monitoring Network and the IMPROVE program. 

WDEQ has sited two visibility-monitoring stations in the PRB. One of these sites 

(the TBNG site) is 32 miles north of Gillette and includes a nephelometer, a 

transmissometer, an IMPROVE aerosol sampler, instruments to measure 

meteorological parameters (temperature, RH, wind speed, wind direction), a digital 

camera, instruments to measure ozone and instruments to measure oxides of 

nitrogen (NO, NO2, NOx). The second visibility monitoring station (the Cloud Peak 

Wilderness Area site) is located 14 miles west of Buffalo and includes a 

nephelometer, a transmissometer, an IMPROVE aerosol sampler, instruments to 

measure meteorological parameters, and a digital camera. 

These sites are being utilized to characterize the extent, frequency of occurrence, 

and magnitude of visual air quality. The IMPROVE Steering Committee approved 

the incorporation of the Thunder Basin and Cloud Peak sites into the IMPROVE 

network in June 2002. Although these stations are not located in areas classified 

as Class I areas, the collected data will be comparable to monitoring data available 

from the state’s Class I areas. This information can help scientists determine the 

types and concentrations of air pollutants and their direction of travel in order to 

project visibility impacts to Class I areas. The Wyoming Visibility Monitoring 

Draft EIS, Antelope Coal Company Lease Application 3-49 
3.0 Affected Environment and Environmental Consequences 

Network was recently supplemented with the development of a website at 

http://www. wyvisnet.com/all.html to allow public access to real-time monitored 

visibility and air quality conditions (WDEQ/AQD 2005a). 

3.4.4.2 Acidification of Lakes 

The acidification of lakes and streams is caused by atmospheric deposition of 

pollutants (acid rain). According to EPA, sulfur dioxide and NOx, primarily derived 

from the burning of fossil fuels, are the primary causes of acid rain. Most lakes 

and streams have a pH between 6 and 8, although some lakes are naturally acidic 

even without the effects of acid rain. Acid rain primarily affects sensitive bodies of 

water, which are located in watersheds whose soils have a limited ability to 

neutralize acidic compounds (called "buffering capacity"). Lakes and streams 

become acidic (pH value goes down) when the water itself and its surrounding soil 

cannot buffer the acid rain enough to neutralize it. In areas where buffering 

capacity is low, acid rain also releases aluminum from soils into lakes and 

streams; aluminum is highly toxic to many species of aquatic organisms. 

Several regions in the U.S. were identified in a national surface water survey as 

containing many of the surface waters sensitive to acidification. They include the 

Adirondacks and Catskill Mountains in New York state, the mid-Appalachian 

highlands along the east coast, the upper Midwest, and mountainous areas of the 

western U.S. 

Scientists predict that the decrease in SO2 emissions required by the Acid Rain 

Program will significantly reduce acidification due to atmospheric sulfur. Without 

the reductions in SO2 emissions, the proportions of acidic aquatic ecosystems 

would remain high or dramatically worsen (EPA 2005b). The USDA-FS has been 

monitoring air quality in the Wind River Mountain Range in Wyoming since 1984 

and is seeing a general trend of decreasing sulfates. Nitrates, on the other hand, 

have been increasing globally. 

3.4.4.2.1 Affected Environment 

AQRVs, including the potential air pollutant effects on the acidification of lakes 

and streams, are applied to PSD Class I and Class II areas. The land management 

agency responsible for the Class I area sets a LAC for each AQRV. The AQRVs 

reflect the land management agency’s policy and are not legally enforceable 

standards. Lake acidification is expressed as the change in ANC measured in 

microequivalents per liter (μeq/L), the lake’s capacity to resist acidification from 

acid rain. Table 3-9 shows the existing ANC monitored in some mountain lakes 

and their distance from the West Antelope II general analysis area. 

3-50 Draft EIS, Antelope Coal Company Lease Application 
 

3.0 Affected Environment and Environmental Consequences 

Table 3-9. Existing Acid Neutralizing Capacity in Sensitive Lakes. 

Distance from 

Background ANC General Analysis 

Wilderness Area Lake (μeq/L) Area (miles) 

Bridger Black Joe 69.0 200 

Deep 61.0 225 

Hobbs 68.0 221 

Cloud Peak Upper Frozen 5.81 106 

Emerald 55.3 120 

Florence 32.7 111 

Fitzpatrick Ross 61.4 225 

Popo Agie Lower Saddlebag 55.5 195 

1 The background ANC is based on only six samples taken between 1997 and 2001. 

Source: Argonne (2002) 

3.4.4.2.2 Environmental Consequences 

3.4.4.2.2.1 Proposed Action and Alternatives 1 and 2 

The West Antelope II LBA tract would be mined as an integral part of the Antelope 

Mine. In April, 2007, Antelope received a permit modification to have the 

opportunity to increase production to 42 mmtpy in the future. Therefore, impacts 

to air quality related to lake acidification under the Proposed Action and 

Alternatives 1 and 2 could be slightly higher than the impacts under the No Action 

Alternative and would be extended for 13 years. Antelope would employ the best 

measures available to mitigate any potential emission increases associated with 

mining the LBA tract. These would include, but would not necessarily be limited 

to, extension of overland conveyors to minimize haul distances and associated 

particulate and gaseous (nitrogen oxides, carbon oxides) emissions from coal 

haulage, as well as state-of-the-art blasting practices to mitigate any potential 

increases in nitrogen oxide emissions, which can also contribute to acidification. 

3.4.4.2.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and the mine would continue to operate as currently permitted. 

Portions of the West Antelope II LBA tract adjacent to the Antelope Mine would be 

disturbed to recover the coal in the existing leases, but coal removal would not 

occur on the LBA tract and there would not be any impacts that contribute to lake 

acidification related to mining any portions of the LBA tract that will not be 

affected under the current mine plan. As discussed in Section 2.2, a decision to 

reject the West Antelope II lease application at this time would not preclude an 

application to lease the tract in the future. 

3.4.4.2.3 Regulatory Compliance, Mitigation, and Monitoring 

Mitigation and monitoring for coal mine emissions, including the emissions that 

Draft EIS, Antelope Coal Company Lease Application 3-51 
3.0 Affected Environment and Environmental Consequences 

contribute to the acidification of lakes, are discussed in Sections 3.4.2.3, 3.4.2.4, 

3.4.3.3, and 3.4.3.4. Other air quality monitoring programs that are in place in 

the PRB include WARMS monitoring of sulfur and nitrogen concentrations near 

Buffalo, Sheridan, and Newcastle, and NADP monitoring of precipitation chemistry 

in Newcastle. 

3.4.6 Residual Impacts to Air Quality 

No residual impacts to air quality would occur following mining and reclamation. 

3.5 Water Resources 

3.5.1 Groundwater 

3.5.1.1 Affected Environment 

Within the West Antelope II LBA tract, there are five water-bearing geologic units 

that could be disturbed by mining. In descending order, these units are recent 

alluvium, the Wasatch Formation overburden, the Anderson coal seam, the Fort 

Union Formation interburden (where present), and the Canyon coal seam. 

Although saturated, the interburden between the Anderson and Canyon coal 

seams is not considered an aquifer because it is usually comprised of claystone 

and siltstone which are not considered aquifer materials though they can be 

water-bearing (i.e. saturated). The Antelope Mine WDEQ/LQD permit document 

(Antelope Mine 2006a) defines the interburden as a confining unit for the Canyon 

coal seam. As such, the interburden is not included in this discussion. The 

underlying sub-coal Fort Union Formation would not be physically disturbed by 

mining activities but is utilized for water supply by coal mines within the general 

area, including the Antelope Mine. 

Antelope Mine has completed 18 monitoring wells within and adjacent to the West 

Antelope II LBA tract: one in the alluvium of Horse Creek (PZ-HCAL-13), one in the 

Alluvium of Antelope Creek (WA-OWAL-1), four in the overburden (HC-OWO-7, 

WA-OWO-6, WA-OWO-5, WA-OWO-1), six in the Anderson coal seam (HC-OWA-8, 

WA-OWA-6, WA-OWA-5, WA-OWA-1, OWA-17, OWA-18), two in the interburden 

between Anderson and Canyon coal seams (WA-OWI-3, WA-OWI-2), three in the 

Canyon coal seam (HC-OWC-8, WA-OWC-3, WA-OWC-2), and one in the Anderson 

and Canyon combined seams (HC-OWAC-7). The locations of these monitoring 

wells, as well as other existing monitoring wells completed by the Antelope Mine, 

are shown on Figure 3-11. Data from these wells, as well as additional 

groundwater data collected at the Antelope Mine, were used to prepare the 

following description of baseline groundwater conditions within the LBA tract. 

3.5.1.1.1 Recent Alluvium 

Within the general analysis area, alluvium occurs along Horse Creek, Spring 

Creek and Antelope Creek. The Horse Creek alluvium typically consists of silty to 

3-52 Draft EIS, Antelope Coal Company Lease Application 
 

3.0 Affected Environment and Environmental Consequences 

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OWS-3 

OWS-5 

OWI-7 OWC-2 

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OWS-12 

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WA-OW0-3 

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WA-OWC-2 

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HC-OWU-1 

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Antelope Mine Permit Boundary 

West Antelope II LBA Tract As Applied For 

Area Added under Alternative 1 

North Tract (Alternative 2) 

South Tract (Alternative 2) 

£ 0 7,000 14,000 

GRAPHIC SCALE (FEET) 

Figure 3-11. Locations of Groundwater Monitoring and Water Supply Wells at the Antelope Mine. 

Draft EIS, West Antelope II Coal Lease Application 3-53
 

3.0 Affected Environment and Environmental Consequences 

clayey sand and varies from 5 to 15 ft thick within the Antelope Mine (Antelope 

Mine 2006a). The alluvium of Spring Creek consists of silty to clayey sand which 

varies from less than one foot in the upper reaches to about 20 feet thick near the 

confluence with Antelope Creek (Antelope Mine 2006a). The Antelope Creek 

alluvium generally consists of mixtures of silt and fine- to medium-grained sand 

and gravel which ranges in thickness from zero to 40 feet (Antelope Mine 2006a). 

Minor amounts of alluvium may occur in tributaries to Horse Creek and Antelope 

Creek such as Spring Creek and other unnamed, normally dry tributary draws. 

The alluvial and colluvial deposits associated with these tributary draws are 

generally thin and not laterally extensive enough to be considered aquifers. The 

unconsolidated deposits associated with these dry draws are typically very finegrained and have very limited permeabilities, precluding any significant storage 

and movement of groundwater. 

Antelope Mine (2006a) has conducted aquifer tests on wells adjacent to West 

Antelope II LBA tract: one well was completed in the alluvium of Horse Creek and 

one well was completed in the alluvium of Antelope Creek. The hydraulic 

conductivity calculated for the Horse Creek alluvium is 0.17 ft/day. The hydraulic 

conductivity calculated for the Antelope Creek alluvium is 33.2 ft/day. This value 

may be slightly high due to leakage from underlying coal seams. The hydraulic 

conductivity of the Spring Creek alluvium varies from 0.01 ft/day (WA-OWAL-13) 

to 51.3 ft/day (WA-OWAL-9) and averages 16 ft/day for the ten alluvial wells 

constructed along Spring Creek (Antelope Mine 2006a). 

The quality of the alluvial groundwater within and adjacent to the West Antelope II 

LBA tract is variable among the Horse Creek alluvium, Spring Creek alluvium and 

the Antelope Creek alluvium. 2006 TDS concentrations in the Horse Creek 

alluvial groundwater (Antelope Mine 2006b) were 3,770 mg/L. TDS 

concentrations in the Spring Creek alluvium range from 3,730 mg/L (WA-OWAL-3) 

to 20,800 mg/L (WA-OWAL-6) (Antelope Mine 2006a). TDS concentrations in 

2004 in the Antelope Creek alluvium were 4,705 mg/L. The alluvial groundwater 

is of the calcium-magnesium-sodium sulfate type, and only suitable for livestock 

and wildlife use. 

3.5.1.1.2 Wasatch Formation 

Within the PRB, the Wasatch Formation consists of interbedded sandstones, 

siltstones, and shale with occasional discontinuous coal stringers and clinker 

deposits. This description basically holds true for the West Antelope II LBA tract. 

Saturated strata within the Wasatch are limited in areal extent and are typically 

thin, lenticular sandstones which are separated laterally and vertically by finergrained siltstone and shale deposits. The hydraulic connection between 

sandstone lenses is tenuous due to the intervening shales; thus, groundwater 

movement through the Wasatch Formation overburden is limited. The sandstone 

and thin coal stringers, where saturated, will yield water to wells. This water is 

primarily used for livestock watering. Since the saturated sandstone and coal 

3-54 Draft EIS, Antelope Coal Company Lease Application 
 

3.0 Affected Environment and Environmental Consequences 

units within the Wasatch Formation are not continuous, the Wasatch is not 

considered to be a regional aquifer. However, discontinuous aquifers can be quite 

important locally if utilized for stock well or domestic well development. 

Another geologic unit that may be considered a part of the Wasatch Formation is 

scoria, also called clinker or burn, which is described in Section 3.3.2.1.4. 

Clinker deposits can be very permeable aquifers and can extend laterally for miles 

in the eastern PRB. The hydrologic function of clinker is to provide infiltration of 

precipitation and recharge to laterally contiguous overburden and coal beds. 

Scoria deposits are not present within the West Antelope II LBA tract. 

Recharge to the Wasatch Formation is from the infiltration of precipitation and 

lateral movement of water from adjacent clinker bodies. Regionally, groundwater 

is discharged from the Wasatch Formation by evaporation and transpiration, by 

pumping wells, by vertical leakage into the underlying coal seams, by drainage 

into mine excavations, and by seepage into the alluvium along stream drainages. 

For the Wasatch Formation as a whole, the discontinuous nature of the waterbearing units results in low overall hydraulic conductivity and low groundwater 

flow rates. Because of the varied nature of the aquifer units within the Wasatch, 

hydraulic properties are variable as well. Martin et al. (1988) reported that 

hydraulic conductivities within the Wasatch ranged from 10-4 ft/day to 102 ft/day, 

and the geometric mean hydraulic conductivity based on 203 tests was 0.2 ft/day. 

The geometric mean hydraulic conductivity from 70 aquifer tests using wells 

completed in sandstone in the Wasatch overburden was 0.35 ft/day, while that 

from 63 aquifer tests using wells completed in siltstone and claystone in the 

Wasatch overburden was 0.007 ft/day (Rehm et al. 1980). The hydraulic 

conductivity of the Wasatch Formation within and adjacent to the West Antelope II 

LBA tract ranges from a high of 5.6 ft/day to a low of 0.03 ft/day. 

Water quality in the Wasatch Formation near the West Antelope II LBA tract is 

variable, with TDS concentrations ranging from 380 mg/L to 2,610 mg/L. This 

compares with a median TDS of 2,000 mg/L in the Wasatch Formation for the 

group of mines south and east of Wright, as calculated by WDEQ/LQD based on 

1,052 samples, (Ogle et al. 2006). The water type is also somewhat variable, but 

predominantly of the sodium-sulfate type. This water is usually unsuitable for 

domestic use, marginal to unsuitable for irrigation and suitable for livestock and 

wildlife. 

3.5.1.1.3 Anderson Coal 

Due to its continuity, the Wyodak coal seam is considered to be a regional aquifer 

within the PRB. Historically, the coal seams have been considered a source of 

groundwater for domestic and livestock uses in the eastern PRB where they are 

shallow enough to be an economical source of water. 

The Wyodak coal is a single seam to the north and west of West Antelope II LBA 

Draft EIS, Antelope Coal Company Lease Application 3-55 
3.0 Affected Environment and Environmental Consequences 

tract. Within the tract, partings divide the Wyodak into two mineable seams: the 

Anderson and the Canyon (see Figure 3-4). The Anderson coal seam is the upper 

of the two seams and is exposed along the Antelope Creek channel due to 

erosional downcutting by Antelope Creek. Elsewhere within the West Antelope II 

LBA tract, the Anderson coal seam ranges from 30 to 40 ft thick and dips westnorthwest at less than 5 degrees. 

Hydraulic conductivity within the Anderson coal seam is highly variable and is 

reflective of the amount of fracturing the coal has undergone, as unfractured coal 

is virtually impermeable. The yield of groundwater to wells and mine pits is the 

smallest where the permeability of the coal is derived primarily from localized 

unloading fractures. These fractures, which are the most common, were created 

by the expansion of the coal as the weight of the overlying sediments was slowly 

removed by erosion. The highest permeability is imparted to the coal by tectonic 

fractures. These are through-going fractures of areal importance created during 

deformation of the south Powder River structural basin. The presence of these 

fractures can be recognized by their linear expression at the ground surface, 

controlling the orientation of stream drainages and topographic depressions. Due 

to their pronounced surface expression, these tectonic fractures are often referred 

to as “lineaments”. Coal permeability along lineaments can be increased by orders 

of magnitude over that in the coal fractured by unloading only. 

Aquifer test data collected by Antelope Mine in the vicinity of the West Antelope 

LBA tract indicate that the Anderson coal possesses higher permeability north and 

east of the tract along the Horse Creek lineament. Antelope Mine (2006a) reported 

Anderson seam hydraulic conductivity in the LBA tract to be 2.4 ft/day at TWA-2, 

while that east of the tract along Horse Creek is approximately 14 ft/day based on 

tests of wells (TWA-1, OWA-1, OWA-2, OWA-3). 

With the exception of the exposure along Antelope Creek, the Anderson coal 

aquifer is deeply confined in the West Antelope II LBA tract, which results in low 

storage coefficients. Storage coefficients measured in the vicinity of the LBA tract 

range from approximately 1.6x10-5 to 4.1x10-4. 

Groundwater from the Anderson coal aquifer in the vicinity of the West Antelope II 

LBA tract is of the sodium/bicarbonate type with TDS concentrations ranging 

from 370 mg/L to 5,610 mg/L. This compares to a median TDS of 952 mg/L in 

the Wyodak Anderson coal aquifer for the group of mines located south and west 

of the town of Wright, based on 832 samples, as calculated by WDEQ/LQD (Ogle 

et al. 2006). This water is usually unsuitable for domestic and irrigation use and 

suitable for livestock and wildlife because the TDS concentrations commonly 

exceed many suitability criteria for domestic uses. Further, at the higher TDS 

concentrations, the Anderson groundwater also sometimes exceeds the Wyoming 

agricultural standards for SAR of 8, rendering it unsuitable for agricultural uses. 

SAR values measured near the West Antelope LBA II tract range from 4.4 at well 

TWA-2 to 9.4 at WA-OWA-1 (Antelope Mine 2006b). The lower TDS groundwater 

may be suitable for domestic, irrigation, stock and wildlife use, however. 

3-56 Draft EIS, Antelope Coal Company Lease Application 
 

3.0 Affected Environment and Environmental Consequences 

Prior to mining, the direction of groundwater flow within the Anderson coal aquifer 

was generally from recharge areas near the outcrop into the basin, following the 

dip of the coal. Site-specific data collected by Antelope Mine in the vicinity of the 

West Antelope LBA tract and presented in the GAGMO 20-year report (HydroEngineering 2001a) indicate that the groundwater flow directions have been 

influenced by mining activities and CBNG development (Antelope Mine 2006b). 

Groundwater flow within the Anderson coal aquifer in the vicinity of the West 

Antelope LBA II tract is now toward a regional cone of depression located north 

and west of the LBA tract. 

3.5.1.1.4 Canyon Coal 

The Canyon coal seam is the lower of the two West Antelope LBA II tract coal 

aquifers, and is bounded above and below by Fort Union Formation claystones, 

siltstones and occasional sand lenses. Within the LBA tract the Canyon coal seam 

ranges from less than 15 ft to nearly 40 ft thick and dips west-northwest at less 

than 5 degrees. Just north of Antelope Creek, the Canyon coal seam splits into 

the Upper and Lower Canyon Coal seams. South of Antelope Creek, the splits in 

the Canyon coal seam are extensive and ACC considers the coal to be uneconomic 

for mining. In the northern portion of the LBA tract, in the vicinity of Horse 

Creek, the Canyon and Anderson seams coalesce into the single Wyodak seam 

(Figure 3-4). 

Hydraulic conductivity within the Canyon coal seam is dependent on the amount 

and type of fracturing. Localized unloading fractures are primarily responsible for 

Canyon coal permeability within the LBA tract. Secondary permeability caused by 

weathering is also thought to contribute to Canyon coal permeability near 

Antelope Creek. East of the LBA tract the Horse Creek lineament may also locally 

increase the permeability. 

Aquifer test data collected by Antelope Mine in the vicinity of the West Antelope II 

LBA tract indicate that hydraulic conductivity in the Canyon coal seam ranges 

from 0.17 ft/day to 1.9 ft/day for the three wells (WA-OWC-1, WA-OWC-2, WAOWC-3) evaluated. Measured storage coefficients ranged from approximately 

1.1x10-5 to 2.7x10-5. 

Based on 10 samples, groundwater from the Canyon coal aquifer at the West 

Antelope LBA tract is of the sodium-bicarbonate type with average TDS 

concentrations ranging from 300 mg/L to 620 mg/L and averaging approximately 

389 mg/L. Within this range, the water is suitable for domestic, irrigation, 

livestock and wildlife use. As discussed above, WDEQ/LQD has calculated a 

median TDS of 952 mg/L in the Wyodak Anderson coal aquifer for the group of 

mines locates south and west of the town of Wright, based on 832 samples (Ogle 

et al. 2006). 

Prior to mining, the direction of groundwater flow within the Canyon coal aquifer 

was generally from the southwest and north toward the suboutcrop beneath the 

Draft EIS, Antelope Coal Company Lease Application 3-57 
3.0 Affected Environment and Environmental Consequences 

Antelope Creek alluvium (Antelope Mine 2006a). This flow pattern has been 

reinforced by Canyon coal removal and dewatering in the Antelope Mine east of 

the LBA tract. According to the GAGMO 20-Year Report (Hydro-Engineering 

2001a), groundwater within the Canyon coal seam in the West Antelope LBA tract 

currently flows to the northwest toward a regional cone of depression (Antelope 

Mine 2006b). 

3.5.1.1.5 Subcoal Fort Union Formation 

In the vicinity of the West Antelope II LBA tract, the Fort Union Formation can be 

divided into three hydrogeologic units: the Tongue River aquifer, the Lebo 

confining unit, and the Tullock aquifer (Law 1976). The Tongue River aquifer 

consists of lenticular fine-grained sandstone, shale, and coal. The Lebo member 

of the Fort Union Formation consists of siltstones and claystones interbedded with 

discontinuous coal and sandstone lenses of varying thicknesses. The Tullock 

aquifer consists of lenticular fine-grained sandstone separated by interbedded 

shale and siltstone. 

Transmissivities are generally higher in the deeper Tullock aquifer than in the 

Tongue River aquifer, and many mines in the PRB have water supply wells 

completed in this interval (Martin et al. 1988). The average transmissivity for this 

member as reported by OSM (1984) is 290 ft2/day. The water quality of the Fort 

Union Formation underburden is generally good. The water is of the sodiumbicarbonate type and is marginal to suitable for domestic and irrigation use and 

suitable for livestock and wildlife watering. 

Mining does not directly disturb the hydrogeologic units below the mineable coal 

but many PRB mines use them for industrial water supply wells. The Antelope 

Mine has two water supply wells (WS-1 and WS-2) completed in the subcoal Fort 

Union Formation (Figure 3-11). In 2006, the measured TDS concentration in 

water collected from wells WS-1 and WS-2 was 590 mg/L and 470 mg/L, 

respectively. 

3.5.1.2 Environmental Consequences 

3.5.1.2.1 Proposed Action and Alternatives 1 and 2 

Surface coal mining impacts the quantity of the groundwater resource in two 

ways: 1) the coal aquifer and any water-bearing overburden strata on the mined 

land are removed and replaced with unconsolidated backfill, and 2) water levels in 

the coal and overburden aquifers adjacent to the mine pits are depressed as a 

result of seepage into and dewatering from the open excavations in the area of coal 

and overburden removal. 

If the West Antelope II LBA tract is leased, the area of coal removal and 

reclamation would increase, which would result in an increase in the area of 

impacts to groundwater quantity. While there would be variations in hydrologic 

3-58 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

properties, the time the pits are open, the distance from mining and dewatering 

that has occurred as a result of previous mining and CBNG development, the area 

subject to lower water levels would be increased roughly in proportion to the 

increase in area affected by mining. 

Currently approved mining will remove the overburden, interburden (if present), 

and coal on the existing leases at the Antelope Mine and replace these separate 

units with backfill material composed of an unlayered mixture of the shale, 

siltstone, and sand that makes up the existing Wasatch Formation overburden 

and Fort Union Formation interburden (if present). The existing leases currently 

include approximately 11,636 acres. Mining the LBA tract as a maintenance lease 

would extend these impacts onto an additional area ranging from about 4,109 

acres (Proposed Action) to about 6,309 acres (Alternatives 1 and 2). 

If the West Antelope II LBA tract is leased and mined, the coal and overburden 

aquifers within the tract would be completely dewatered and removed and the area 

of drawdown caused by coal and overburden removal would be extended further to 

the northwest and southwest of the active mine area. The extent that drawdowns 

would propagate away from the mine pits is a function of the water-bearing 

properties of the aquifer materials. In materials with high transmissivity and low 

storativity, drawdowns will extend further from the pit face than in materials with 

lower transmissivity and higher storage capacity. 

In general, due to the geologic makeup of the Wasatch Formation overburden 

(discontinuous sandstone lenses in a matrix of siltstone and shale), drawdowns in 

the overburden do not extend great distances from the active mine pits. Due to 

the varied nature of the water-bearing units within the Wasatch Formation 

overburden, the extent of water level drawdowns is variable as well. The change in 

the water levels for the overburden range from an increase in the water level of 

6.76 ft in WA-OWO-5 to a drawdown of 23.27 ft in WA-OWO-4, which is 

approximately 2,000 ft west of the active mine pit (Figure 3-11). The majority of 

the overburden wells have less then 2 ft of drawdown (Antelope Mine 2006b). 

Water level drawdowns propagate much farther and in a more consistent manner 

in the Anderson and Canyon coal seams than in the overburden because of the 

regional continuity and higher transmissivity within the coal aquifer. Drawdowns 

in the coal seam are primarily a function of distance from the pit, although 

geologic and hydrologic barriers and boundaries such as crop lines, fracture 

zones, and recharge sources can also influence drawdowns. Drawdowns within 

the coal from 1980 to 1995 were generally in excess of five ft within four miles of 

the active pits at the Antelope Mine (Hydro-Engineering 1996). In 2005 and 2006, 

Antelope Mine monitored water levels in 12 monitor wells completed in the 

Anderson coal seam and 10 monitor wells in the Canyon coal seam. 

Prior to 1993, mining occurred in relatively dry portions of the Anderson coal 

seam and little to no drawdown occurred within that aquifer. The maximum 

drawdown measured in 2005 and 2006 in an Anderson monitor well was about 

Draft EIS, Antelope Coal Company Lease Application 3-59 
3.0 Affected Environment and Environmental Consequences 

95.3 ft at well WA-OWA-5 located approximately 9,300 ft (1.76 miles) northwest of 

the active pit (Antelope Mine 2006b). 

The water level in the Canyon coal seam has shown a drawdown trend in most 

monitor wells since 1988, apparently due to mining activities to the north of the 

Antelope Mine. The downward trend accelerated from 1988 to the present as a 

result of mining a fully saturated Canyon coal seam in the northeastern part of 

the Antelope Mine. The maximum drawdown measured to date in the Canyon 

coal seam is about 146.6 ft at WA-OWC-2, located within 9,300 ft (1.76 miles) 

northwest of the active pit (Antelope Mine 2006b). 

Drawdowns in both seams have resulted not only from mining, but also from 

CBNG development. Water levels and maps showing drawdowns in the vicinity of 

the pit are included in the annual report for the Antelope Mine filed by Antelope 

Mine with WDEQ/LQD each year. 

Antelope Mine used a linear analytical model (line sink analysis) to predict the 

extent of water level drawdown in the Anderson and Canyon coal seam aquifers as 

a result of mining the existing leases at Antelope Mine. The results of the 

groundwater modeling are reported in the Mine Plan, Section MP5, Addendum 

MP-C of the Antelope Mine 525-T7 permit document (Antelope Mine 2006a). The 

predicted extent of drawdown (five ft contour) in the Anderson-Canyon coal seam 

over the life of the mine if the Antelope Mine acquires the West Antelope II LBA 

tract is shown on Figure 3-12. This prediction is approximate and is based on 

extrapolation of Antelope Mine’s earlier predictions by extending the drawdowns 

westward and northward by the dimensions of the West Antelope II LBA tract. 

More precise predictions of the extent of drawdowns would be required in order to 

revise the Antelope Mine permit to include the West Antelope II LBA tract, if the 

Antelope Mine acquires a lease for the tract. 

The subcoal aquifers are not removed or disturbed by mining, so they are not 

directly impacted by coal mining operations. As discussed above, Antelope Mine 

has two water supply wells completed in aquifers below the coal. If the LBA tract 

is leased by the applicant, water would be produced from these wells for a longer 

period of time, but Antelope Mine probably would not require additional sub-coal 

wells to mine the LBA tract. 

As discussed in Section 3.3.1.2.1, the existing layers of sediment and rock in the 

area of coal removal would be replaced by generally homogenous, unconsolidated 

backfill material, which would recover as a single hydrostratigraphic unit. The 

backfill unit in the LBA tract would be in hydraulic communication with the 

adjacent undisturbed coal, overburden and existing backfill aquifer units. Surface 

infiltration recharge rates for the backfill materials should be equivalent to or 

somewhat greater than infiltration recharge through undisturbed overburden, due 

primarily to the generally flatter topography resulting in less surface runoff. The 

hydraulic properties of the backfill aquifer, based on the results of aquifer testing 

at mines in the PRB, are quite variable although they are generally equal to or 

3-60 Draft EIS, Antelope Coal Company Lease Application 
 

 

 

3.0 Affected Environment and Environmental Consequences 

Campbell County 

Converse County 

T.

42

N.

T.

43

N.

T.

39

N.

T.

41

N.

T.

40

N.

T.

42

N.

T.

43

N.

T.

39

N.

T.

41

N.

T.

40

N.

R.73W. R.72W. R.71W. R.70W. R.69W.

R.73W. R.72W. R.71W. R.70W. R.69W.

!(59 

£ 0 20,000 40,000 

GRAPHIC SCALE (FEET) 

No Coal Line (Approximate) 

No Coal Line (Approximate) 

LEGEND

No Coal Line (Approximate) West Antelope II LBA Tract As Applied For 

Area Added under Alternative 1 

North Tract (Alternative 2) 

South Tract (Alternative 2) 

Existing Antelope Mine Federal Coal Leases 

Extent of Worst-Case Modeled and 

Extrapolated Life of Mine Canyon 

Coal Drawdown (5 ft) with 

West Antelope II LBA Tract 

Figure 3-12. Life of Mine Drawdown Map, Resulting from Currently Approved Mining with Addition of the

 West Antelope II LBA Tract. 

Draft EIS, West Antelope II Coal Lease Application 3-61
3.0 Affected Environment and Environmental Consequences 

greater than the undisturbed overburden and coal aquifers (Van Voast et al. 1978 

and Rahn 1976). The hydraulic properties of the backfill aquifer at the West 

Antelope II LBA tract would likely be similar to the hydraulic properties measured 

in existing wells completed in the backfill at nearby mines. To date, no sitespecific data are available for the hydraulic properties of the mine’s backfill. The 

hydraulic properties measured in existing wells completed in the backfill at North 

Antelope Rochelle Mine, located northeast of the Antelope Mine, are variable but 

in general comparable to the Wasatch Formation overburden and Wyodak coal. At 

North Antelope Rochelle Mine, the backfill aquifer has been tested at four wells, 

and the average hydraulic conductivity is 36 ft/day, which exceeds the average 

hydraulic conductivity (9.5 ft/day) reported for the Wyodak coal seam in the 

vicinity of the North Antelope Rochelle Mine. The data available indicate that the 

hydraulic conductivity of the backfill would be greater than or equal to premining 

coal values, suggesting that wells completed in the backfill would provide yields 

greater than or equal to premining coal wells. 

Mining and reclamation also impact groundwater quality; the TDS concentration 

in the water resaturating the backfill is generally higher than the TDS 

concentration in groundwater from the coal seam aquifer prior to mining. This is 

due to the exposure of fresh mineral surfaces to groundwater that moves through 

the backfill. Research conducted by Van Voast and Reiten (1988), who analyzed 

data from the Decker and Colstrip Mine areas in Montana, indicates that upon 

initial saturation, mine backfill is generally high in TDS concentration and 

contains soluble salts of calcium, magnesium and sodium sulfates. As the backfill 

is resaturated, the soluble salts are leached by groundwater inflow and TDS 

concentrations tend to decrease with time, indicating that the long term 

groundwater quality in mined and off-site lands would return to approximate premine conditions (Van Voast and Reiten 1988). Using data compiled from 10 

surface coal mines in the eastern PRB, Martin et al. (1988) concluded that backfill 

groundwater quality improves markedly after the backfill is leached with one pore 

volume of water. Clark (1995) conducted a study to determine if the decreases 

predicted by laboratory studies actually occur onsite. In the area of the West 

Decker Mine near Decker, Montana, his study found that dissolved solids 

concentrations increased when water from an upgradient coal aquifer flowed into 

a backfill aquifer, and apparently decreased along an inferred path from a backfill 

aquifer to a downgradient coal aquifer. 

Groundwater quality within the backfill aquifer at the West Antelope II LBA tract 

would be expected to be similar to groundwater quality measured in existing wells 

completed in the backfill at Antelope Mine. To date, seven wells have been 

installed to monitor water levels and water quality in backfill at the Antelope Mine. 

Four of these backfill monitoring wells are located in the southern part of the mine 

and have not yet been sampled due to a lack of saturation. Three backfill 

monitoring wells that were added to Antelope Mine’s monitoring program in 2000 

are located in the northeastern part of the mine and had sufficient saturation to 

be sampled. TDS concentrations in these three monitoring wells range from 2,660 

to 6,000 mg/L (Antelope Mine 2006b). WDEQ/LQD calculated a median TDS 

3-62 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

concentration of 3,670 mg/L for the backfill aquifer in the group of mines south 

and east of the town of Wright, which includes the Antelope Mine, based on 869 

samples (Ogle et al. 2006). 

3.5.1.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II lease application would be 

rejected and coal removal would not occur on the West Antelope II LBA tract. The 

impacts to groundwater resources described above would continue as a result of 

existing approved mining and CBNG development. The surface and potentially 

some shallow aquifers in portions of the West Antelope II LBA tract adjacent to the 

Antelope Mine would be disturbed to recover the coal in the existing leases. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3.5.1.3 Regulatory Compliance, Mitigation and Monitoring 

In order to obtain a surface coal mining permit, the Antelope Mine was required to 

evaluate regional and site-specific baseline hydrogeologic environments within and 

around the mine and use a groundwater flow model to predict the extent of 

cumulative water level drawdown in the Wyodak coal seam aquifer that would 

occur as a result of mining the existing leases at the Jacobs Ranch, Black 

Thunder, North Antelope Rochelle and Antelope Mines. Results of these studies 

are included in the WDEQ/LQD mine permit. If the West Antelope II LBA tract is 

leased and mined, the permit for the Antelope Mine will have to be amended to 

include the tract, and these studies will be revised accordingly. 

As discussed in Section 3.5.3, SMCRA and Wyoming regulations require mine 

operators to provide the owner of a water right whose water source is interrupted, 

discontinued, or diminished by mining with water of equivalent quantity and 

quality. 

The surface coal mines are also required to monitor water levels and water quality 

in the overburden, coal, interburden, underburden, and backfill. Groundwater 

monitoring wells installed by Antelope Mine within and around the current permit 

area have been used to evaluate groundwater conditions since 1979. Through the 

years, some of the wells have been removed by mining, some have become gaseous 

and were removed from the monitor plan, and others have been added as mining 

has progressed. The data gathered from these wells is included in the annual 

reports prepared by the mine. The locations of the current monitoring wells are 

shown on Figure 3-11. 

Draft EIS, Antelope Coal Company Lease Application 3-63 
3.0 Affected Environment and Environmental Consequences 

3.5.2 Surface Water 

3.5.2.1 Affected Environment 

The West Antelope II general analysis area is located within the Antelope Creek 

drainage basin, which is a major tributary of the Cheyenne River. The area within 

and surrounding the West Antelope II LBA tract consists of gently rolling 

topography. In general, the streams within this area are typical for the region, 

and their flow events are closely reflective of precipitation patterns. Flow events 

frequently result from snowmelt during the late winter and early spring. Although 

peak discharges from such events are generally small, the duration and therefore 

percentage of annual runoff volume can be considerable. During the spring, both 

rain and snow storms increase soil moisture, hence decreasing infiltration 

capacity, and subsequent rainstorms can result in both large runoff volumes and 

high peak discharges. The area’s surface water quality varies with streamflow 

rate; the higher the flow rate, the lower the TDS concentration but the higher the 

suspended solids concentration. 

The northern portion of the general analysis area is drained by several unnamed 

tributaries of Spring Creek and the upper reaches of Horse Creek (Figure 3-13). A 

short reach of Spring Creek and two short reaches of Horse Creek cross the 

general analysis area. Spring Creek and Horse Creek are southward-flowing 

ephemeral tributaries of Antelope Creek. 

The southern portion of the general analysis area is drained by a few small, 

unnamed tributaries of Antelope Creek. A short reach of Antelope Creek crosses 

the southern portion of the general analysis area (Figure 3-13). Antelope Creek is 

an intermittent stream that, prior to mining, received a small degree of baseflow 

from coal seams in the Antelope Mine area. 

Except for two crossings, Antelope Creek flows undisturbed from west to east 

across Antelope Mine’s current permit area. The Antelope Creek drainage area is 

796 square miles upstream of Station SW-2, which was established on Antelope 

Creek in March 1979 immediately downstream of the Spring Creek confluence 

(station SW-2 was removed from the monitoring network in 2006). 

Flows and water quality data in Antelope Creek, Spring Creek, Horse Creek, and 

several minor tributaries have been and continue to be monitored on and near the 

Antelope Mine and are reported annually to the WDEQ/LQD. According to 

hydrologic correlation using the mine’s SW-2 gauging station data on Antelope 

Creek, the annual average discharge is approximately 5.6 cfs (4,013 ac-ft/yr) (ACC 

2005). The surface water of Antelope Creek is generally classified as a calciumsulfate type, with an average TDS concentration of approximately 1,800 mg/L. 

Suspended sediment concentrations measured in samples collected from Antelope 

Creek within the Antelope Mine permit areas have historically ranged from 100 to 

300 mg/L for stream flows up to 21.5 cfs (ACC 2005). This water, when available, 

is usually unsuitable for domestic use, marginal for irrigation, and suitable for 

3-64 Draft EIS, Antelope Coal Company Lease Application 
Antelope Roa d 

County Road 37 

W. Logan Draw 

/John son Draw 

Haefele Draw 

Raw

E

les Draw 

. Logan Dra w 

Logan Draw 

13 

11 

14 

23 

Antelope Creek 

Horse Creek 

Spring Creek 

Sand Cr 

T omas Dra w 

ek 

3.0 Affected Environment and Environmental Consequences 

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

10 12 7 8 11 12 7 8 9 

Spring 

Spring 

13 

26

h

12 

e

18 

22 

Lazy Y Number 1 Reservoir 

18 17 16 15 14 18 17

# SW-25 

Horse Creek Flood Control 

Reservoir No. 1 

20 19 20 24 19 21 22 23 24

Gnarly Draw Diversion 

Campbell County 

28 27 25 30 Converse County 25 30 # 29 29 SW-29 Spring Creek Diversion Stock Pond Draw Reservoir 

# Blocking Dike SW-29
 


DITCH
 
 Spring Creek Diverison T.
 


41
 


36 31 32 33 #34SW-10 35 36 31 32 N.
 
 T. 

41 # SW-3A 

N. 

T. T. 

40 2 40 6 SW-28 5 4 3 2 1 6 5 N. # N. 1 

!(59

7 8 9 10 11 12 7

17 18 16 15 14 13 13 

24 19 20 23 19

21 24

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

£ LEGEND 

# Active Surface Water Monitoring Site Antelope Mine Permit Boundary 

Diversions and Embankments West Antelope II LBA Tract As Applied For 

Major Ephemeral Stream Area Added under Alternative 1 

Minor Ephemeral Stream North Tract (Alternative 2) 

Pond or Reservoir South Tract (Alternative 2) 

7,000 14,000 

GRAPHIC SCALE (FEET) 

Figure 3-13. Surface Water Features Within and Adjacent to the West Antelope II Study Area. 

Draft EIS, West Antelope II Coal Lease Application 

8 

17 

20 

0 

3-65
3.0 Affected Environment and Environmental Consequences 

stock and wildlife use. 

Spring Creek has a relatively large drainage area of approximately 66.8 square 

miles. It is classified as ephemeral because it receives no measurable base flow 

from groundwater and flows only in response to snowmelt and precipitation 

runoff. Two locally-named ephemeral tributaries of Spring Creek, Stock Pond 

Draw and Gnarly Draw, drain a portion of the LBA tract. Recently, there has been 

sustained flow from April through July that is due to discharge water from CBNG 

activity on Spring Creek. All of the water quality and TSS samples that have been 

collected from Spring Creek have been during low-flow conditions. TDS 

concentrations of all samples collected at Spring Creek range from 210 to 8,050 

mg/L, while TSS concentrations ranged from 3.3 to 2,510 mg/L. 

Antelope Mine recently constructed a channel to divert Spring Creek around its 

upcoming mining activities and plans to disturb Spring Creek in 2007. Gnarly 

Draw and Stock Pond Draw are within the current permit area for the Antelope 

Mine and will be disturbed under the currently approved permit. Gnarly Draw will 

be diverted and Stock Pond Draw will receive a flood control reservoir (Figure 3­

13). Both Gnarly Draw and Stock Pond Draw will be disturbed within the next five 

years of mining. 

Horse Creek has a drainage area of about 15 square miles. It is classified as 

ephemeral and the average annual runoff near its confluence with Antelope Creek 

is 140 ac-ft/yr for the years 1991 through 1996. In 1997 an anomalously large 

runoff volume of 3,134 ac-ft/yr was measured at Station SW-9. Horse Creek is 

currently disturbed by mining in the Horse Creek Amendment Area of the 

Antelope Mine. As part of the mining activities in Horse Creek, Station SW-9 was 

removed in 1998. Replacement monitoring stations have been installed, but these 

sites do not have a long history of data to obtain an effective average of annual 

runoff. The surface water in Horse Creek is typically of the calcium-magnesiumsodium-sulfate type. TDS concentrations range from 1,020 to 5,888 mg/L, and 

average 3,507 mg/L. 

3.5.2.2 Environmental Consequences 

3.5.2.2.1 Proposed Action and Alternatives 1 and 2 

Changes in runoff characteristics and sediment discharges would occur during 

mining of the LBA tract as a result of the destruction and reconstruction of 

drainage channels and the use of sediment control structures to manage 

discharges of surface water. Erosion rates could be high on the disturbed areas 

because of vegetation removal. However, both state and federal regulations 

require treatment of surface runoff from mined lands to meet effluent standards. 

Generally, the surface runoff sediment is deposited in ponds or other sediment 

control devices that are located inside the mine permit area before the surface 

runoff water is allowed to leave the permit area. 

3-66 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

Because the LBA tract would be mined as an extension of the existing mine under 

the Proposed Action and Alternatives 1 and 2, there would not be a large increase 

in the size of the area that is disturbed and not reclaimed at any given time as a 

result of leasing the tract. The presence of disturbed areas creates a potential that 

sediment produced by large storms (i.e., greater than the 10-year, 24-hour storm) 

could potentially adversely impact areas downstream of the mining operation. 

This potential for adverse downstream impacts would be extended if the LBA tract 

were leased. 

The loss of soil structure would act to increase runoff rates in reclaimed areas of 

the LBA tract after the coal is removed. However, the general decrease in average 

slope in reclaimed areas, as discussed in Section 3.2.2, would tend to counteract 

the potential for an increase in runoff. Soil structure would gradually reform over 

time, and vegetation (after successful reclamation) would provide erosion 

protection from raindrop impact, retard surface flows, and maintain runoff to 

approximately premining levels. 

Significant runoff from the West Antelope II LBA tract may occur in the Antelope 

Creek, Horse Creek, and/or Spring Creek drainages. No mining has been 

conducted on Antelope Creek nor on an adjacent buffer zone of 100 ft on either 

side of the creek within the existing Antelope Mine coal leases. No mining is 

planned through the Antelope Creek channel nor through the adjacent buffer 

zone; therefore, with the exception of two crossings, it passes unimpeded through 

the LBA tract and mine area. 

A flood control reservoir is located on Horse Creek upstream of the mining 

activities. Based on Antelope Mine’s permitted mine plan, another flood control 

reservoir is planned to be constructed upstream of the existing structure. An 

additional flood control reservoir may be required to provide flood control for the 

West Antelope II LBA tract. This structure would be located on Horse Creek west 

of the tract. Under the Proposed Action, the existing diversion on Spring Creek 

will provide adequate flood protection for the downstream mining activities. Under 

Alternatives 1 and 2, the channel would either be diverted or a large flood control 

reservoir would be constructed. The remaining channels within the West Antelope 

II LBA tract are small enough that flood control structures would not be 

constructed; flows would accrue to the mine pits and would be evacuated by 

pump. 

The impacts described above would be similar for both the Proposed Action and 

Alternatives 1 and 2, and they are similar to the expected impacts for the 

currently permitted mining operation. 

3.5.2.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope coal lease application would be 

rejected and coal removal would not occur on the tract. The impacts to surface 

water resources described above would continue within the existing mine permit 

Draft EIS, Antelope Coal Company Lease Application 3-67 
3.0 Affected Environment and Environmental Consequences 

area as a result of currently approved mining and CBNG development. The 

surface in portions of the West Antelope II LBA tract adjacent to the Antelope Mine 

would be disturbed to recover the coal in the existing leases. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3.5.2.3 Regulatory Compliance, Mitigation and Monitoring 

In accordance with SMCRA and Wyoming State Statutes, major channels that are 

disturbed by surface coal mining operations on the West Antelope II LBA tract 

would be restored. Surface water flow, quality, and sediment discharge would 

approximate premining conditions. The drainages that are disturbed when the 

coal is recovered from the tract would be reclaimed to exhibit channel geometry 

characteristics similar to the premining characteristics. The major channels 

would be restored in approximately the same location as the natural channel and 

hydrologic functions and features, including alluvial groundwater-surface water 

interaction and premining pools and runs, would be restored. 

Other WDEQ/LQD permit requirements for the existing Antelope Mine include 

constructing sediment control structures to manage discharges of surface water 

from the current mine permit area, treatment of all surface runoff from mined 

lands as necessary to meet effluent standards, and restoration of stock ponds and 

playas disturbed during mining. These requirements would be extended to 

include the West Antelope II LBA tract during the permitting process, if it is 

leased. 

Monitoring requirements for the existing Antelope Mine include a monitoring 

program to assure that ponds always have adequate space reserved for sediment 

accumulation and for collection of water quality samples from Antelope Creek at 

both the Upper (SW-28) and Lower (SW-3A) Stations (Figure 3-13) on a quarterly 

basis. These requirements would be extended to include the West Antelope II LBA 

tract when the mine permit is amended to include the tract. 

3.5.3 Water Rights 

3.5.3.1 Affected Environment 

Wyoming SEO administers water rights in Wyoming. Water rights are granted for 

both groundwater and surface water. Water Records of the SEO were searched for 

groundwater rights within a three-mile radius of the West Antelope II LBA tract, as 

required for WDEQ mine permitting. At the time of the search, SEO data 

indicated there are 980 permitted water wells within three miles of the tract. The 

majority of these wells (884) are owned by either coal mining companies or CBNG 

producers. Of the 96 other wells, 51 are permitted for stock watering purposes, 

15 are permitted for domestic and/or stock use, 3 for industrial purposes, and 27 

3-68 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

for monitoring or miscellaneous use. A listing of the non-coal mine related 

groundwater rights is presented in Appendix G. 

SEO records were searched for surface water rights using the SEO’s AREV 

program. The search was conducted for surface-water rights within one-half mile 

of the tract and three miles downstream from the tract, as required for WDEQ 

mine permitting. 

At the time of the search, SEO records indicated 260 permitted surface water 

rights within the search area for the LBA tract. One hundred eighty four of the 

surface water rights are held by coal mining companies. Of the remaining 76 

surface water rights, 71 are permitted for stock watering, 2 for irrigiation, 1 for 

stock watering or irrigation, and 2 for industrial purposes. A listing of the noncoal mine related surface water rights is presented in Appendix G. 

3.5.3.2 Environmental Consequences 

3.5.3.2.1 Proposed Action and Alternatives 1 and 2 

In November 2007, Wyoming SEO records indicate a total of 980 permitted water 

wells are located within three miles of the LBA tract. As discussed above, most of 

these wells are owned by coal mining or CBNG companies. Of the non-coal mine 

related wells within the search area, approximately 53 percent are permitted for 

stock watering, 16 percent are permitted for domestic and/or stock use, 28 

percent are permitted for monitoring or miscellaneous use, and three percent are 

permitted for industrial uses. 

Some of these privately permitted water wells would likely be impacted (either 

directly by removal of the well or indirectly by water level drawdown) by approved 

mining operations occurring at the Antelope and adjacent mines. Additional water 

wells would likely be affected if the LBA tract is leased and mined. Several of the 

permitted water wells listed in Section 3.5.3.1 are located within the expanded 

five-ft drawdown contour with completion depths that indicate they produce water 

from the coal seam (this excludes wells constructed for monitoring, mine 

dewatering, or CBNG production). These wells are presented in Table 3-10. 

3.5.3.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and coal removal would not occur on the tract. The impacts to water 

rights associated with existing approved mining and CBNG development would 

continue to occur. The surface of portions of the West Antelope II LBA tract 

adjacent to the Antelope Mine would be disturbed to recover the coal in the 

existing leases. 

Draft EIS, Antelope Coal Company Lease Application 3-69 
 

3.0 Affected Environment and Environmental Consequences 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

Table 3-10. Water Supply Wells Possibly Subject to Drawdown if the West 

Antelope II LBA Tract is Mined. 

SEO Well Depth

Permit Yield Depth to Water 

Number Applicant Use (gpm) (ft) (ft) 

P95333W Frances Putnam Domestic, Stock 6 360 45 

P5611P Robert E. Isenberger Stock 5 344 280 

P23598W Patricia L. Isenberger Stock 10 252 100 

P5612P Patricia L. Isenberger- Stock 1 350 60 

Litton 

P23601P Patricia L. Isenberger Stock 7 250 -1 

P23595P Patricia L. Isenberger Stock 10 525 -4 

P18856P Floyd C. Reno & Son's Stock 10 300 140 

P17459W Floyd C. Reno & Son's Stock 20 357 180 

P18149P WY Board of Land Stock 10 362 100 

Commissioners 

Floyd C. Reno & Son's 

P130523W Bill Moore, Jr., / W.I. Stock 4 370 190 

Moore Ranch Co. Moore 

P94894W Ray Bell Stock 5 549 230 

P29020W USDA Forest Service Stock 5 440 140 

P18147P Floyd C. Reno & Son's Stock 5 350 110 

Wyoming Board of Land 

Commissioners 

Note: Based on their reported completion intervals, wells in this table are believed to be 

completed in the Wyodak coal seam and are within the additional area of five ft or more 

drawdown caused by mining the West Antelope II LBA tract. Wells impacted by the No Action 

Alternative are already addressed in the Antelope Mine’s WDEQ/LQD mine permit document. 

3.5.3.3 Regulatory Compliance, Mitigation and Monitoring 

In compliance with SMCRA and Wyoming regulations, mine operators are required 

to provide the owner of a water right whose water source is interrupted, 

discontinued, or diminished by mining with water of equivalent quantity and 

quality; this mitigation is thus part of the Proposed Action and Alternatives 1 and 

2. The most probable source of replacement water would be one of the aquifers 

underlying the Anderson and Canyon coal seams. For example, the subcoal Fort 

Union Formation aquifers are not removed or disturbed by coal mining, so they 

are not directly impacted by coal mining activity. 

If the West Antelope II LBA tract is leased, the mine operator would be required to 

update the list of potentially impacted private water supply wells and predict 

impacts to those wells within the five-ft drawdown contour as part of the 

permitting process. The operator would be required to commit to replacing those 

water supplies with water of equivalent quality and quantity if they are determined 

to be affected by mining. 

3-70 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

3.5.4 Residual Impacts 

The area of coal and overburden removal and replacement of overburden and 

associated groundwater drawdowns would be increased under the Proposed 

Action and Alternatives 1 and 2 compared with the area of coal and overburden 

removal and overburden replacement and associated groundwater drawdowns if 

the West Antelope II LBA tract is not leased and mined. The postmining backfill 

may take in excess of 100 years to reach equilibrium water levels and water 

quality. Less time would be required near the mining boundaries. Monitoring 

data from wells completed in existing backfill area in the PRB suggest that there 

would be an adequate quantity of water in the backfill to replace current use, 

which is generally for livestock. Water quality in the backfill would generally be 

expected to meet the Wyoming Class III standards for use as stock water, which 

was the primary premining use of water from the coal seams. 

3.6 Alluvial Valley Floors 

3.6.1 Affected Environment 

SMCRA prohibits surface coal mining and reclamation operations that would 

interrupt, discontinue, or preclude farming on AVFs or cause material damage to 

the quantity or quality of water systems that supply AVFs. These prohibitions do 

not apply if the premining land use of the affected AVF is undeveloped rangeland 

that is not significant to farming or if the affected AVF is of such small acreage 

that it would have a negligible impact on a farm’s agricultural production. The 

prohibitions also apply to AVFs that are downstream of the area of disturbance 

but might be affected by disruptions of streamflow. If WDEQ determines that an 

AVF is not significant to agriculture, that AVF can be disturbed during mining but 

must be restored as part of the reclamation process. 

WDEQ regulations define AVFs as unconsolidated stream-laid deposits where 

water availability is sufficient for subirrigation or flood irrigation agricultural 

activities. Guidelines established by OSM and WDEQ/LQD for the identification 

of AVFs require detailed studies of geomorphology, soils, hydrology, vegetation, 

and land use. These studies are used to identify 1) the presence of 

unconsolidated stream laid deposits, 2) the possibility for artificial flood irrigation, 

3) past and/or present flood irrigation, and 4) apparent subirrigated areas and the 

possibility for natural flood irrigation. Areas that are identified as AVFs following 

these studies are evaluated for their significance to farming by WDEQ/LQD. 

Investigations have been conducted by the Antelope Mine to determine the 

presence of AVFs within the existing Antelope Mine permit area. These AVF 

studies were conducted as part of the WDEQ/LQD mine permitting process for the 

purpose of recovering coal in the mine’s existing leases. The results of these 

studies for the existing permit area are as follows: 

• Antelope Creek has been investigated for the presence of an AVF (ACC 

Draft EIS, Antelope Coal Company Lease Application 3-71 
 

3.0 Affected Environment and Environmental Consequences 

2005a). The area of the investigation extends more than a mile upstream of 

the current permit area and includes a portion of the West Antelope II LBA 

tract. A portion of Antelope Creek within the current permit area has been 

designated by WDEQ/LQD as “possible subirrigated AVF of minor 

importance to agriculture”. Antelope Mine’s approved mining plan avoids 

disturbing Antelope Creek and an adjacent buffer zone. 

• Horse Creek has been investigated for the presence of an AVF (ACC 2005a). 

WDEQ/LQD has designated 61.2 acres in a narrow band adjacent to the 

channel and extending about a half mile upstream of the current permit 

boundary as an AVF designation. ACC’s current mining plan would disturb 

50.6 acres of that AVF (ACC 2001a). The portions of Horse Creek that have 

been declared an AVF were determined to be insignificant to farming by 

WDEQ/LQD (ACC 2001a). 

• Spring Creek has been investigated for the presence of an AVF (ACC 2005a). 

Spring Creek was determined to contain 27.6 acres of AVF, however, 

historical efforts to employ flood irrigation within the Spring Creek Valley 

have not been successful (ACC 2006). The portions of Spring Creek that 

have been declared an AVF were determined to be non-significant to 

farming by WDEQ/LQD (ACC 2006a). 

The general analysis area for the West Antelope II LBA tract includes short 

reaches of Antelope, Horse, and Spring Creeks which have not yet been formally 

evaluated for the presence of AVFs. The portions of those creeks that have not 

been formally evaluated for AVFs are upstream of the areas that have been 

investigated for the presence of AVFs within the current permit area (Figure 3-14). 

As discussed previously, the declared AVF on Antelope Creek will not be disturbed 

by mining operations at the Antelope Mine. There are stream-laid deposits in 

portions of Horse Creek and Spring Creek within the general analysis area that 

are potential AVFs and may be mined and reclaimed in accordance with the 

WDEQ/LQD regulations. 

A site-specific study will be part of the mine permitting process if a lease sale is 

held and the LBA tract is permitted for mining. Declarations of the presence or 

absence of AVFs, their significance to agriculture, and the appropriate perimeters 

will then be made by the WDEQ/LQD. The BLM study area for the West Antelope 

II LBA tract is undeveloped rangeland; therefore, it is reasonable to assume that 

mining would be permitted if the WDEQ/LQD determines AVFs are present within 

the LBA tract that is leased. 

3.6.2 Environmental Consequences 

3.6.2.1 Proposed Action and Alternatives 1 and 2 

As indicated above, the entire West Antelope II general analysis area has not yet 

3-72 Draft EIS, Antelope Coal Company Lease Application 
Antelope Roa d 

County Road 37 

W. Logan Draw 

/John son Draw 

Haefele Draw 

Raw

E

les Draw 

. Logan Dra w 

Logan Draw Antelope Creek 

Spring

C r eek 

Horse Cre ek 

Sand Creek 

13 

11 

14 

23 

T omas Dra w

3.0 Affected Environment and Environmental Consequences 

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

10 12 7 8 11 12 7 8 9 

Spring 

Spring 

h

18 17 16 15 14 13 18 17

20 24 19 20 24 19 21 22 23 

Campbell County 

28 27 25 30 Converse County 25 30 26 29 29 

T. 

41 

32 N. 36 31 32 33 34 35 36 31 

T. 

41 

N. 

T. T.

2 40 40 6 5 4 3 2 1 6 5 N. N. 1 

!(59

12 7 8 9 10 11 12 7

18 

17 18 16 15 14 13 13 

22 24 19 20 23 19

21 24

R. 72 W. R. 71 W. Lazy Y Number 1 Reservoir R. 71 W. R. 70 W. 

£ Major Ephemeral Stream 

Minor Ephemeral Stream 

Pond or Reservoir 

LEGEND 

Antelope Mine Permit Boundary 

West Antelope II LBA Tract As Applied For 

Area Added under Alternative 1 

North Tract (Alternative 2) 

South Tract (Alternative 2) 

Antelope Creek: WDEQ/LQD Designated AVF. 

Less than 140 acres delineated as "Possible 

Subirrigated AVF of Minor Importance 

to Agriculture". Not to be disturbed by mining. 

Horse Creek: WDEQ/LQD Designated AVF. 

50.6 acres of subirrigated land. To be disturbed 

by mining. 

ALLUVIAL VALLEY FLOOR DELINEATION 

Spring Creek: 27.6 acres of apparently 

subirrigated vegetation (based on September 

0 7,000 14,000 

2003 color infrared aerial photography). To 

be disturbed by mining. 

GRAPHIC SCALE (FEET) 

Figure 3-14. Declared Alluvial Valley Floors Within and Adjacent to the West Antelope II Study Area. 

Draft EIS, West Antelope II Coal Lease Application 

8 

17 

20 

3-73
3.0 Affected Environment and Environmental Consequences 

been formally evaluated for the presence of AVFs, however, previous investigations 

have identified AVFs along Antelope Creek, Spring Creek and Horse Creek within 

and adjacent to the West Antelope II LBA tract. 

ACC’s approved mining plan avoids disturbing Antelope Creek and an adjacent 

designated buffer zone. Therefore, any portions of the Antelope Creek valley that 

are included in the BLM study area for the West Antelope II LBA tract would not 

be mined, if the tract is leased and ACC acquires the tract. 

WDEQ/LQD has determined that the AVFs on Horse Creek and Spring Creek 

within the current Antelope Mine permit area are not significant to agriculture 

(ACC 2006a). With the exception of an unsuccessful attempt at flood irrigation on 

Spring Creek, there is no present or historical record of agricultural use, other 

than undeveloped rangeland, in this area. Therefore, if WDEQ/LQD determines 

that an AVF is present in the general analysis area on either Horse Creek or 

Spring Creek, it would be reasonable to assume that mining would be permitted 

on that AVF because the lack of agricultural development in this area would 

preclude a determination of significance to agriculture. 

Streamflows in drainages within the West Antelope II LBA tract would be diverted 

around the active mining areas in temporary diversion ditches or captured in flood 

control reservoirs above the pit. If flood control impoundments are used, it would 

be necessary to evacuate them following major runoff events to provide storage 

volume for the next flood. Consequently, disruptions to streamflows that might 

supply downstream AVFs are expected to be negligible. Groundwater intercepted 

by the mine pits would be routed through settling ponds to meet state and federal 

water quality criteria, and the pond discharges would likely increase the frequency 

and amount of flow in these streams, thereby increasing surface water supplies to 

downstream AVFs. 

If the LBA tract is mined as an extension of existing operations, the mining would 

extend upstream on streams already in active mine areas. Therefore, no direct, 

indirect, or cumulative impacts are anticipated to off-site AVFs through mining of 

the West Antelope II LBA tract. 

3.6.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope coal lease application would be 

rejected and coal removal would not occur on the tract. The impacts to AVFs 

associated with existing approved mining would continue to occur. The surface of 

portions of the West Antelope II LBA tract adjacent to the Antelope Mine would be 

disturbed to recover the coal in the existing leases. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3-74 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

3.6.3 Regulatory Compliance, Mitigation and Monitoring 

As discussed above, AVFs must be identified because SMCRA restricts mining 

activities that affect AVFs that are determined to be significant to agriculture. 

Impacts to designated AVFs are generally not permitted if the AVF is determined 

to be significant to agriculture. If the AVF is determined not to be significant to 

agriculture, or if the permit to affect the AVF was issued prior to the effective date 

of SMCRA, the AVF can be disturbed during mining but must be restored as part 

of the reclamation process. The determination of significance to agriculture is 

made by WDEQ/LQD, and it is based on specific calculations related to the 

production of crops or forage on the AVF and the size of the existing agricultural 

operations on the land of which the AVF is a part. For any designated AVF, 

regardless of its significance to agriculture, it must be demonstrated that the 

essential hydrologic functions of the valley will be protected. Downstream AVFs 

must also be protected during mining. 

3.6.4 Residual Impacts 

No residual impacts to AVFs would occur following mining. 

3.7 Wetlands 

3.7.1 Affected Environment 

Waters of the U.S. is a collective term for all areas subject to regulation by the COE 

under Section 404 of the Clean Water Act. Waters of the U.S. include special 

aquatic sites, wetlands, and jurisdictional wetlands. Special aquatic sites are large 

or small geographic areas that possess special ecological characteristics of 

productivity, habitat, wildlife protection or other important and easily disrupted 

ecological values (40 CFR 230.3). Wetlands are a type of special aquatic site (that 

includes “those areas that are inundated or saturated by surface or groundwater 

at a frequency and duration sufficient to support, and that under normal 

circumstances do support, a prevalence of vegetation typically adapted for life in 

saturated soil conditions. Wetlands generally include swamps, marshes, bogs, 

and similar areas” (33 CFR 328.3(a)(7)(b)). 

There are effectively three categories of wetlands: 

• Jurisdictional wetlands, which are defined as those wetlands which are 

within the extent of COE regulatory review. They must contain three 

components: hydric soils, a dominance of hydrophytic plants, and wetland 

hydrology. 

• Non-jurisdictional wetlands, which are non-navigable, isolated intrastate 

wetlands (e.g., playas) and other Waters of the U.S. These wetlands are not 

considered to be jurisdictional as a result of a Supreme Court ruling (Solid 

Waste Agency of Northern Cook County v. United States Army Corps of 

Engineers, January 9, 2001 and consolidated cases Rapanos v. United 

Draft EIS, Antelope Coal Company Lease Application 3-75 
3.0 Affected Environment and Environmental Consequences 

States and Carabell v. United States, known as the “Rapanos” decision, 

June 19, 2006). Navigable, non-isolated wetlands and other Waters of the 

U.S. are still considered jurisdictional by the COE. 

• Functional wetlands, which are areas that contain only one or two of the 

three criteria listed under jurisdictional wetlands. The USFWS used this 

categorization in producing the NWI maps. These maps were produced 

using aerial photo interpretation, with limited or no field verification. 

Several types of wetland systems are present within the general analysis area 

(Figure 3-15). These wetland systems are limited in size; however, the vegetation 

in most of these environments is highly productive and diverse, and provides 

habitat for many wildlife species. Further, the systems as a whole play important 

roles in controlling flood waters, recharging groundwater, and filtering pollutants 

(Niering 1985). 

Wetlands occur in a variety of forms within the general analysis area. Palustrine 

wetlands defined by their close association with emergent herbaceous marshes, 

swales, and wet meadows, support a variety of lush plant life and occur along the 

major drainages. Palustrine wetlands are the most common and abundant 

wetland on the analysis area and occur primarily along Antelope Creek, Horse 

Creek and Spring Creek. These wetland areas are supported by the saturated 

soils along the banks of the drainages with hydrology provided primarily from 

surface runoff from adjacent uplands and discharged CBNG waters. 

In addition to wetlands, the general analysis area may include jurisdictional other 

waters of the U.S. as defined by 33 CFR 328.3. These other waters of the U.S. are 

primarily ephemeral stream channels, open water and other stream channels that 

carry water but do not meet the criteria for classification as wetlands. 

Wetland inventories were based on USFWS NWI mapping, 2006-2007 vegetation 

mapping in the field and wetland inventories completed for the Antelope Mine in 

areas within or adjacent to the general analysis area. The area of investigation 

includes the BLM study area for the West Antelope II LBA tract (the tract as 

applied for and the additional area evaluated under Alternatives 1 and 2) and a 1⁄4­

mile disturbance buffer for lands not located within a currently approved mine 

permit area. Some wetland areas previously mapped by the USFWS NWI project 

have been recently altered somewhat due to CBNG-related water production 

within and upstream of the general analysis area. Within the entire wetland 

analysis area (9,520.8 acres, of which 2,115.5 acres are within the current 

Antelope Coal Mine permit area), a total of approximately 42.9 acres of wetlands 

and other waters of the U.S. have been identified (Figure 3-15). Of this 42.9 acres 

identified, approximately 31.7 acres are vegetated wetlands and the remaining 

11.2 acres are pond or channel other waters of the U.S. The majority of the 

wetlands are associated with the Antelope Creek, Horse Creek and Spring Creek 

stream channels. The majority of the channel other waters of the U.S. are 

associated with the ephemeral stream channels present on the area. 

3-76 Draft EIS, Antelope Coal Company Lease Application 
Antelope Roa d 

County Road 37 

W. Logan Draw 

Johnson Draw 

Haefele Draw 

Raw

E

les Draw 

. Logan Dra w 

Logan Draw Antelope Creek 

Spring Cre ek 

Horse Cre ek 

Sand Creek 

13 17 

11 

14 

23 

T omas Dra w 

3.0 Affected Environment and Environmental Consequences 

R. 72 W.	 R. 71 W. R. 71 W. R. 70 W. 

P 10 12 7 8	 11 12 7 8 9 

ES ES 

ES 

IW ES ES
 

IS SP ES	 IW ES SP 

ES

h

18 17 16 IW 15 14 13 18 SP 

ES 

SP 20 SP 19 20 24 19 21 22 23 24

ES 

SP ES 

SP 

ES 

S 

ES
 ES SP ES Campbell County IW 29 28 ES 27 Converse County IW 26 25 30 25 30 IW 29 IW 

ES 

ES T. 

41 

32 N. 36 31 32 33 34 35 36 31 

T. 

41 

N.	 ES 

T. T.

40 SP 40 2 6 5	 4 3 2 1 6 5 N. N. IW 1	 S 

SP P 

ES 

!59 ES ( ES ES 

12 7 8 ES	 10 11 12 7

9 ES 

ES 

ES SP SP ES ES ES 

18 

ES 

18 17	 16 15 14 13 13 

ES ES 

ES ES 

ES ES ES 

ES ES

22 24 19 20 21 23 19

24 

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

£ LEGEND 

Wetlands Designation 

P - Playa West Antelope II LBA Tract As Applied For 

SP - Stock Pond 

Area Added under Alternative 1 S - Seep / Spring Wetland 

North Tract (Alternative 2) ES - Ephemeral stream other waters 

South Tract (Alternative 2)	 IS - Intermittent stream other waters 

S - Seep/Spring Wetland General Analysis Area 

IW - Intermittent stream wetland and other waters 7,000 14,000
 

GRAPHIC SCALE (FEET)
 

Figure 3-15. Wetlands and Other Waters Within the West Antelope II General Analysis Area. 

Draft EIS, West Antelope II Coal Lease Application 

8 

17 

20 

0 

3-77
3.0 Affected Environment and Environmental Consequences 

Non-jurisdictional wetlands or other waters of the U.S. were included in the above 

acreages and were not identified separately in the study area because only the 

COE has the authorization to make such determinations. However, two small 

playas (less than one acre) were observed in the general analysis area (Figure 3­

15). A formal wetland inventory would be completed and submitted to the COE 

for verification as part of the permitting process. 

3.7.2 Environmental Consequences 

3.7.2.1 Proposed Action and Alternatives 1 and 2 

Based on previous surveys approved by the COE, NWI mapping by USFWS, and 

the vegetation mapping completed in 2006-2007, a maximum of approximately 

42.9 acres of wetland and other waters of the U.S. would be disturbed if the LBA 

tract is leased and subsequently mined under the largest tract configuration 

(Alternatives 1 or 2). 

A formal wetland delineation has been confirmed by the COE for the wetlands and 

other waters in the 2,116 acres of the wetland analysis area that lie within 

Antelope Coal Mine’s current permit area. Wetland inventories covering the 

remainder of the wetland analysis area have been conducted but have not yet 

been submitted to the COE for verification. This wetland inventory would be 

submitted to the COE for verification as part of the process of obtaining a surface 

coal mining permit. In Wyoming, once the delineation has been verified, it is made 

a part of the mine permit document. The reclamation plan is then revised to 

incorporate the replacement of at least equal types and numbers of jurisdictional 

wetland acreages. 

During the period of time after mining and before replacement of wetlands, all 

wetland functions would be lost. The replaced wetlands may not duplicate the 

exact function and landscape features of the premine wetlands, but replacement 

plans would be evaluated by the COE and replacement would be in accordance 

with the requirements of Section 404 of the Clean Water Act as determined by the 

COE. 

3.7.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and coal removal would not occur on the West Antelope II LBA tract. 

The impacts to wetlands on the existing Antelope Coal Mine leases would occur as 

currently permitted. The surface portions of the West Antelope II LBA tract within 

the Antelope Coal Mine would be disturbed to recover the coal in the existing 

leases. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3-78 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

3.7.3 Regulatory Compliance, Mitigation and Monitoring 

The presence of jurisdictional wetlands and other waters on a mine property does 

not preclude mining. A wetland delineation must be completed according to 

approved procedures (COE 1987) and submitted to the COE for verification as to 

the amounts and types of jurisdictional wetlands and other waters present. There 

are special required permitting procedures to assure that after mining there will 

be no net loss of wetlands. The COE requires replacement of all impacted 

jurisdictional wetlands in accordance with Section 404 of the Clean Water Act. 

Section 404 of the Clean Water Act does not cover non-jurisdictional or functional 

wetlands; however, Executive Order 11990 requires that all federal agencies 

protect all wetlands. Mitigation for impacts to non-jurisdictional wetlands located 

on the tract will be specified during the permitting process as required by the 

authorized state or federal agency (which may include the WDEQ, the Office of 

Surface Mining, or the federal surface managing agency, if any federal surface is 

included in the tract) or the private surface owner. Surface land ownership on the 

West Antelope II general analysis area is private and federal (see Section 3.11). 

The federal surface is administered by the USDA-FS. WDEQ/LQD allows and 

sometimes requires mitigation of non-jurisdictional wetlands affected by mining, 

depending on the values associated with the wetland features. WDEQ/LQD may 

also require replacement of sites with hydrologic significance. If any playas with 

hydrologic significance are located on the tract that is leased, WDEQ/LQD would 

also require their replacement. 

Reclaimed wetlands are monitored using the same procedures used to identify 

pre-mining jurisdictional wetlands. 

3.7.4. Residual Impacts 

Replaced wetlands (jurisdictional or functional) may not duplicate the exact 

function and landscape features of the premining wetland, but all wetland 

replacement plans would be approved by the COE, which has special required 

permitting procedures to assure that there will be no net loss of wetlands after 

reclamation. 

3.8 Soils 

3.8.1 Affected Environment 

The soils analysis area for the West Antelope II EIS is the general analysis area, 

which includes approximately 9,521 acres. Part of the soils analysis area 

(approximately 2,116 acres or 22.2% of the general analysis area) lies within 

portions of three previously permitted Antelope Coal Mine areas: Antelope Permit 

Boundary (236.5 acres), Horse Creek Amendment (949.3 acres), and the West 

Antelope Amendment (929.7 acres). The entire soils analysis area is included in 

portions of the Natural Resources Conservation Service (NRCS) Order 3 soil 

Draft EIS, Antelope Coal Company Lease Application 3-79 
3.0 Affected Environment and Environmental Consequences 

surveys of southern Campbell County, Wyoming, (Westerman and Prink, 2004) 

and northern Converse County, Wyoming, (Reckner 1986). The permitted portions 

of the soils analysis area have been previously mapped to the detailed Order 1-2 

level as part of the Antelope Coal integrated baseline soil survey - Antelope 

(Commonwealth Associates 1980), Horse Creek (Sugnet and Associates, 1999), 

and West Antelope (Western Water Consultants 2004). The detailed soil survey of 

the remaining portion of the West Antelope II general analysis area not previously 

mapped to the Order 1-2 level (77.8% of the general analysis area, approximately 

7,407.3 acres), was started in 2007 and will be completed during the first half of 

2008. This survey includes detailed soils mapping, profile descriptions, and 

sampling for laboratory characterization of all dominant soils. 

All soil surveys were completed to the Order 1-2 or Order 3 level of intensity in 

accordance with criteria contained in WDEQ/LQD Guideline No. 1, Soils and 

Overburden (WDEQ 1996), which outlines the required soils information 

necessary for a coal mining operation. The inventories included soils field 

sampling, profile descriptions and observations at the requisite number of 

individual sites, and laboratory analysis of representative collected samples. Soils 

within the analysis area were identified by series, which consist of soils that have 

similar horizons in their profile. 

The soil types and depths on the soils analysis area are similar to soils currently 

being salvaged and utilized for reclamation at the adjacent Antelope Mine and 

other nearby mines in the southern PRB. Eighteen soil types have been mapped 

in twenty-three map units in the currently permitted, detailed Order 1-2 part of 

the soils analysis area (comprising 22.2 percent of the total soils analysis area). 

Soils in seven additional map units were identified by NRCS on the less detailed, 

Order 3 part of the area. The soil surveys have also located hydric soils and/or 

inclusions of hydric soils, which are one component used in identifying wetlands. 

Areas with soils that are not suitable to support plant growth include sites with 

high salinity, alkalinity, or excessive clay content. 

Soils vary depending upon where and how they were formed. Major factors 

involved in the formation of soils include whether or not the material was 

transported and how the material was weathered during transportation. Four 

primary soil formation processes causing different soil types were noted in the 

study area: 1) soils developing predominantly in thin residuum from sandstone or 

shale on upland ridges, 2) soils developing predominantly in slopewash, 

colluvium, or alluvial fan deposits from mixed sources on gently sloping uplands, 

3) soils developing predominantly in coarse-textured alluvium or sandy eolian 

deposits on rolling uplands, and 4) drainage soils developing in mixed stream laid 

alluvium on terraces and channels, and in fine-textured playa deposits in 

depressions and closed basins. The major soil series encountered within the 

study area were grouped according to these categories as follows: 

Soils developing predominantly in thin residuum from sandstone or shale on 

upland ridges 

3-80 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

•	 Samday clay, 0 to 15% slopes (map unit 24) 

•	 Shingle clay loam, 0 to 15% slopes (map unit 26) 

•	 Tassel sandy loam, 0 to 30% slopes (map unit 28) 

•	 Worf sandy loam, 0 to 6% slopes (map unit 37) 

•	 Samday-Shingle-Worf complex, 0 to 15% slopes (map unit 101) 

•	 Shingle-Samday complex, 3 to 30% (map unit 104) 

•	 Shingle-Worf-Rock Outcrop complex, 3 to 30% slopes (map unit 108) 

•	 Rock Outcrop-Shingle-Samday-Tassel complex, 3 to 30% slopes (map 

unit 110) 

•	 Hilight-Wags-Badland complex, 3 to 45% slopes (map unit 163) 

•	 Ustic Torriorthents, gullied (map unit 233) 

Soils developing predominantly in moderately fine-textured slopewash, colluvium, 

or alluvial fan deposits from mixed sources on gently sloping uplands 

•	 Cushman sandy loam, 0 to 10% slopes (map unit 7) 

•	 Forkwood loam, 0 to 9% (map unit 11) 

•	 Renohill clay loam, 0 to 6% slopes (map unit 23) 

•	 Ulm clay loam, 0 to 6% slopes (map unit 33) 

•	 Forkwood-Cushman complex, 0 to 15% slopes (map unit 38) 

•	 Decolney-Hiland fine sandy loams, 0 to 6% slopes (map unit 129) 

•	 Hiland-Bowbac fine sandy loams, 0 to 15% slopes (map units 157 and 

158) 

Soils developing predominantly in coarse-textured alluvium and sandy eolian 

deposits on rolling uplands 

•	 Orpha loamy sand, 0 to 15% slopes (map unit 34) 

•	 Vonalee fine sandy loam, 0 to 6% slopes (map unit 35) 

•	 Hiland-Vonalee fine sandy loams, 0 to 6% slopes (map unit 159) 

•	 Keeline-Tullock loamy sands, 6 to 30% slopes (map unit 170) 

•	 Keeline-Tullock-Niobrara, dry complex, 3 to 30% slopes (map unit 171) 

•	 Orpha-Tullock loamy sands, 6 to 30% slopes (map unit 188) 

•	 Vonalee-Terro fine sandy loams, 2 to 10% slopes (map unit 236) 

Drainage soils developing in mixed streamlain alluvium on terraces and channels, 

and in fine-textured playa deposits in depressions and closed basins 

•	 Absted-Arvada-Bone complex, 0 to 6% slopes (map unit 1) 

•	 Draknab loamy sand, 0 to 3% slopes (map unit 2) 

•	 Clarkelen sandy loam, 0 to 3% slopes (map unit 13) 

•	 Haverdad loam, 0 to 9% slopes (map unit 14) 

•	 Typic Fluvaquents, very wet (map unit 301) 

•	 Typic Fluvaquents (map unit 302) 

The soil surveys indicate that the amount of suitable topsoil available for 

Draft EIS, Antelope Coal Company Lease Application 3-81 
3.0 Affected Environment and Environmental Consequences 

redistribution on all disturbed acres within the soils analysis area during 

reclamation would have an average depth of about 18 inches (1.5 ft). Areas of 

unsuitable soils include sites with high salinity, high sodicity, or excessive clay 

content. The area is expected to have adequate quality and quantity of soil for 

reclamation. The soil surveys have located hydric soils and/or inclusions of 

hydric soils which are one component used in identifying wetlands. 

3.8.2 Environmental Consequences 

3.8.2.1 Proposed Action and Alternatives 1 and 2 

Potential impacts to soil resources on the LBA tract after final reclamation under 

the Proposed Action or Alternatives 1 or 2 are quantified as follows. Under the 

currently approved mining and reclamation plan, approximately 12,105 acres of 

soil resources will be disturbed in order to mine the coal in the existing leases at 

the Antelope Mine (Table 3-1). If the West Antelope II LBA tract is leased, 

disturbance related to coal mining would directly affect approximately 4,314 

additional acres of soil resources on and adjacent to the tract under the Proposed 

Action, and up to 6,625 additional acres under Alternatives 1 and 2 (Table 3-1). 

Average topsoil thickness would be about 18 inches (1.5 ft) across the entire 

reclaimed surface. The types of soils and quantities of suitable soil included in 

the West Antelope II LBA tract under the Proposed Action and Alternatives 1 and 2 

are similar to the soils on the existing leases at the Antelope Mine. 

Removal and replacement of soils during mining and reclamation would cause 

changes in the soil resources. In reclaimed areas, soil chemistry and soil nutrient 

distribution would generally be more uniform and average topsoil quality would be 

improved because soil material that is not suitable to support plant growth would 

not be salvaged for use in reclamation. This would result in more uniform 

vegetative productivity on the reclaimed land. 

The replaced topsoil should support a stable and productive vegetation community 

adequate in quality and quantity to support the planned postmining land uses 

(wildlife habitat and rangeland). 

There most likely would be an increase in the near-surface bulk density of the soil 

resources on the reclaimed areas. As a result, the average soil infiltration rates 

would likely decrease, which would increase the potential for runoff and soil 

erosion. Topographic moderation following reclamation would potentially decrease 

runoff, which would tend to offset the effects of decreased soil infiltration capacity. 

The change in soil infiltration rates would not be permanent because revegetation 

and natural weathering action would form a new soil structure in the reclaimed 

soils, and infiltration rates would gradually return to premining levels. The 

reclaimed landscape would contain stable landforms and drainage systems that 

would support the postmining land uses. Reconstructed stream channels and 

floodplains would be designed and established to be erosionally stable. 

3-82 Draft EIS, Antelope Coal Company Lease Application 
 

 

3.0 Affected Environment and Environmental Consequences 

Direct biological impacts to soil resources on the West Antelope II LBA tract would 

include short-term to long-term reduction in soil organic matter, microbial 

populations, seeds, bulbs, rhizomes, and live plant parts for soil resources that 

are stockpiled before placement. 

3.8.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and coal removal and the associated disturbance and impacts to soils 

would not occur on the portion of the 4,314 acres (Proposed Action) or 6,625 acres 

(Alternatives 1 and 2) of land that will not be disturbed under the currently 

approved surface coal mining permit. Soil removal and replacement would occur 

on the existing Antelope Mine leases as currently permitted. Soils on portions of 

the West Antelope II area adjacent to the Antelope Mine may be disturbed to 

recover the coal in the existing leases. As discussed in Section 2.2, a decision to 

reject the West Antelope II lease application at this time would not preclude an 

application to lease the tract in the future. 

3.8.3 Regulatory Compliance, Mitigation and Monitoring 

Soils suitable to support plant growth would be salvaged for use in reclamation. 

Soil stockpiles would be protected from disturbance and erosional influences. Soil 

material that is not suitable to support plant growth would not be salvaged. Soil 

or overburden materials containing potentially harmful chemical constituents 

(such as selenium) would be specially handled. 

At least four feet of suitable overburden would be selectively placed on the graded 

backfill surface below the replaced topsoil to meet guidelines for vegetation root 

zones. After topsoil is replaced on reclaimed surfaces, revegetation would reduce 

wind erosion. The mine would construct sediment control structures as needed to 

trap eroded soil. Regraded overburden would be sampled for compliance with root 

zone criteria. Vegetation growth would be monitored on reclaimed areas to 

determine if soil amendments are needed. 

These measures are required by regulation and are therefore considered to be part 

of the Proposed Action and Alternatives 1 and 2 for the West Antelope II LBA tract. 

3.8.4 Residual Impacts 

Existing soils would be mixed and redistributed, and soil-forming processes would 

be disturbed by mining. This would result in long-term alteration of soil 

characteristics. 

Draft EIS, Antelope Coal Company Lease Application 3-83 
3.0 Affected Environment and Environmental Consequences 

3.9 Vegetation 

3.9.1 Affected Environment 

The vegetation analysis area (9,520.8 total acres) is the general analysis area, 

which includes the BLM study area for the West Antelope II LBA tract (the tract as 

applied for and the additional area evaluated by BLM under Alternatives 1 and 2) 

and a 1⁄4-mile buffer, which is the assumed area that would be disturbed in order 

to recover the coal in the LBA tract. The 1⁄4-mile buffer includes only those lands 

that are not already approved for disturbance under currently approved coal 

leases and mine plans. Portions of the vegetation analysis area lie within the 

current Antelope Mine permit area and were previously mapped and sampled in 

accordance with the current WDEQ/LQD mine permitting requirements. The 

balance of this vegetation assessment was completed by Intermountain Resources 

of Laramie, Wyoming in 2006 and 2007. The vegetation communities in this area 

were appraised and mapped to provide a baseline assessment. 

The vegetation within the analysis area consists of species common to eastern 

Wyoming and is consistent with vegetation that occurs within the adjacent 

Antelope Coal Mine permit area. A total of nine vegetation types/map units have 

been identified and mapped within the West Antelope II LBA vegetation analysis 

area. Previously disturbed areas were also mapped. The vegetation types include 

blue grama roughland, blue grama upland, birdsfoot sagebrush upland, grassy 

bottom, big sagebrush upland, silver sagebrush lowland, greasewood lowland, 

wetland/water, and treated grazing land (“treated grazing land” is defined in 

WDEQ/LQD Rules, Chapter 1, section 2 (xi)). The predominant vegetation types, 

in terms of total acres of occurrence in the vegetation analysis area, are the blue 

grama upland (41.65 percent), blue grama roughland (20.36 percent), big 

sagebrush upland (14.10 percent) and birdsfoot sagebrush upland (14.14 

percent), which occur primarily on the level uplands and adjacent breaks (Table 3­

11). 

Table 3-11. Vegetation Types Identified and Mapped Within the West Antelope II 

LBA Tract Vegetation Analysis Area. 

Vegetation Type Acres Percent of Area 

Blue Grama Upland 3,965.38 41.65 

Blue Grama Roughland 1,938.35 20.36 

Big Sagebrush Upland 1,342.40 14.10 

Birdsfoot Sagebrush Upland 1,346.01 14.14 

Treated Grazing Land 475.50 4.99 

Grassy Bottom 102.57 1.08 

Disturbed Land 109.76 1.15 

Wetland/Water 42.90 0.45 

Silver Sagebrush Lowland 193.00 2.03 

Greasewood Lowland 4.88 0. 0 5 

Total 9,520.75 100.00 

Source: Intermountain Resources (2006 & 2007) 

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3.0 Affected Environment and Environmental Consequences 

The blue grama upland vegetation type was the dominant typed mapped on the 

analysis area and is characterized by perennial grasses. Dominant plant species 

are blue grama, needleandthread, western wheatgrass, Sandberg bluegrass and 

other upland grasses of the region. Threadleaf sedge, pricklypear cactus and 

alkali sacaton are also common on some areas. Annual grasses and forbs were 

common on this type in 2007 while full shrubs and subshrubs were generally 

uncommon. This type is generally found on relatively flat to gently sloping areas 

with loamy and sandy loam soils. 

The blue grama roughland vegetation type total vegetation cover is sparser than 

on the blue grama upland with the diversity of vascular plant species slightly 

lower. Common species include most of those found in the more extensive blue 

grama upland types, but in addition, such species as prairie sandreed, scarlet 

globemallow, birdsfoot sagebrush and broom snakeweed are also common. Full 

shrubs and subshrubs are present in more abundance than on the blue grama 

upland type but do not dominate these areas. The blue grama roughland type is 

generally found on sloping to steeply sloping and erosive topography with shallow 

to deep soils. 

The big sagebrush upland is dominated by big sagebrush and perennial grasses. 

Other common plant species, besides big sagebrush, are blue grama, 

needleandthread, pricklypear cactus and western wheatgrass. Annual grasses 

and forbs were common on this area in 2007. Big sagebrush is obviously the 

dominant full shrub and fringed sagewort is the most common subshrub. This 

type is predominantly found on relatively flat to gently sloping areas on moderately 

deep loamy soils. This type was also mapped in some small gently sloping draws, 

also with moderately deep loamy soils. 

The birdsfoot sagebrush upland type is typically composed of sparsely vegetated 

uplands which are on relatively flat to gently sloping areas with relatively shallow 

soils. Soils characteristically are somewhat clayey and slightly alkaline. 

Dominant plant species include blue grama, birdsfoot sagebrush, threadleaf 

sedge, needleandthread, Gardner saltbush, wild buckwheat, and western 

wheatgrass. Full shrubs are uncommon but the subshrubs birdsfoot sagebrush, 

Gardner saltbush, wild buckwheat and broom snakeweed are common. 

Treated grazing land is composed of lands where big sagebrush was removed. 

This type is found at one locale where big sagebrush was removed by a controlled 

burn. The treated grazing land type resembles the blue grama upland in terms of 

vegetation composition with blue grama, western wheatgrass, needleandthread, 

threadleaf sedge, Sandberg bluegrass and prickly pear cactus being the most 

common perennial plant species. Annual forbs and grasses were abundant on 

this area in 2007. Shrubs and subshrubs are generally absent. This type is 

found on gently rolling plains with moderately deep soils. 

The grassy bottom exists in the form of narrow bands that range from 

approximately ten to 50 ft in width along the edges of Antelope Creek, Spring 

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3.0 Affected Environment and Environmental Consequences 

Creek, Horse Creek and some other associated minor drainages. Although this 

vegetation type comprises limited acreage, these sites are the most productive 

within the analysis area. The predominant plants are usually some combination 

of Kentucky bluegrass, sedges, alkali sacaton, inland saltgrass, yellow sweetclover, 

western wheatgrass, other wheatgrasses, dandelion, and western yarrow. Full 

shrubs were generally absent from this type but the subshrub fringed sagewort 

was common. Soils are usually loamy and moderately deep. Some dense patches 

of the noxious weed Canada thistle are present within this map unit. 

Several areas of disturbed lands are located in the vegetation analysis area. These 

disturbed lands consist primarily of roads, pipelines and CBNG development. 

Some of these areas, such as roads and facilities, will remain disturbed into the 

future. Other disturbances, such as pipelines, will be reclaimed as soon as the 

work is completed. 

Wetlands and open water are found in several locations in the vegetation analysis 

area, primarily along Horse Creek, Spring Creek and Antelope Creek and 

qualifying tributaries. The stockponds found within the analysis area are also 

included in this category. These sites were identified based on COE criteria for 

wetlands and pond other waters but may or may not be jurisdictional as 

discussed in Section 3.7. Wetland vegetation consists primarily of cattails, 

bulrushes, rushes, spikerush, sedges, and horsetails. Typically the open water is 

surrounded by wetlands or the grassy bottom type. Soils are primarily loams, clay 

loams and sandy clay loams. 

A very small amount of silver sagebrush lowland is present on the vegetation 

analysis area for the West Antelope II LBA tract. This type is dominated by silver 

sagebrush, needleandthread, blue grama and western wheatgrass. Annual 

grasses and forbs were abundant on this type in 2007. Silver sagebrush was the 

most common full shrub while fringed sagewort was the most common subshrub. 

This map unit is found on relatively flat to gently sloping areas with typically 

sandy loam soils. 

A minor amount of greasewood lowland (0.05 percent of the total area) was 

identified in the vegetation analysis area. This type is dominated by greasewood, 

blue grama, needleleaf sedge, Sandberg bluegrass, and western wheatgrass. 

Annual grasses and forbs were abundant on this type in 2007. Greasewood was 

the most common full shrub while fringed sagewort and winterfat were the most 

common subshrubs. This type is found on relatively flat to gently sloping terrain 

with clayey and somewhat alkaline soils. 

Previous vegetation inventories and additional inventories completed in 2007 

identified approximately 223 plains cottonwood trees and five peachleaf willow 

trees within the vegetation analysis area. Most of these trees were found along 

Antelope Creek. Ten trees were found along Spring Creek. These trees were 

generally found associated with the bottomland grassland type or in the blue 

grama upland type adjacent to the bottomland grassland type. A few trees were 

3-86 Draft EIS, Antelope Coal Company Lease Application 
 

3.0 Affected Environment and Environmental Consequences 

also found in ephemeral drainages as well as adjacent to stockponds and adjacent 

to stock tanks. 

3.9.2 Environmental Consequences 

3.9.2.1 Proposed Action and Alternatives 1 and 2 

As indicated in Table 3-1, under the currently approved mining and reclamation 

plan, approximately 12,105 acres of vegetation will be disturbed in order to mine 

the coal in the existing leases at the Antelope Coal Mine. Under the Proposed 

Action, mining of the West Antelope II LBA tract as applied for would progressively 

remove the native vegetation on 4,314 additional acres. Under the Alternatives 1 

and 2, mining of the LBA tract would progressively remove the native vegetation 

on up to 6,625 additional acres. 

Short-term impacts associated with the removal of vegetation from the West 

Antelope II LBA tract would include increased soil erosion and habitat loss for 

wildlife and livestock. Potential long-term impacts include loss of habitat for some 

wildlife species as a result of reduced plant species diversity, particularly big 

sagebrush, on reclaimed lands. However, grassland-dependent wildlife species 

and livestock would benefit from the increased grass cover and production. 

Reclamation, including revegetation of these lands, would occur 

contemporaneously with mining on adjacent lands, i.e., reclamation would begin 

after an area is mined. Estimates of the time elapsed from topsoil stripping 

through reseeding of any given area range from two to four years. This would be 

longer for areas occupied by stockpiles, haulroads, some sediment-control 

structures, and other mine facilities. Some roads and facilities would not be 

reclaimed until the end of mining. ACC does not propose to locate any new life-ofmine facilities on the West Antelope II LBA tract under the Proposed Action or 

Alternatives 1 or 2 because the tract would be mined as an extension of an 

existing mine. 

Grazing restrictions prior to mining and during reclamation would remove up to 

100 percent of the general analysis area from livestock grazing. This reduction in 

vegetative production would not seriously affect livestock production in the region, 

and long-term productivity on the reclaimed land would return to premining levels 

within several years following seeding with the approved final seed mixture. 

Wildlife use of the area would not be significantly restricted throughout the 

operations. 

In an effort to approximate premining conditions, the applicant would plan to 

reestablish vegetation types that are similar to the premine types during the 

reclamation operation. Reestablished vegetation would be dominated by species 

mandated in the reclamation seed mixtures (to be approved by WDEQ). The 

majority of the approved species are native to the area. Initially, the reclaimed 

lands would be dominated by grassland vegetation, which would be less diverse 

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3.0 Affected Environment and Environmental Consequences 

than the premining vegetation. At least 20 percent of the native vegetation area 

would be reclaimed to native shrubs at a density of one per square meter or as 

required by current regulations. Estimates for the time it would take to restore 

shrubs, including sagebrush, to premining density levels range from 20 to 100 

years. The reclamation standards call for restoration of sagebrush or other native 

shrubs to at least 20 percent of the reclaimed area. As indicated previously, 

sagebrush is a component of the big sagebrush upland, birdsfoot sagebrush 

upland, and silver sagebrush upland vegetation types, which account for 

approximately 30 percent of the vegetation analysis area. The reduction in 

sagebrush would result in a long term reduction of habitat for some species and 

may delay use of the reclaimed area by shrub-dependent species, such as the 

sage-grouse. An indirect impact of this vegetative change could be decreased big 

game habitat carrying capacity. Following completion of reclamation (seeding with 

the final seed mixture) and before release of the reclamation bond (a minimum of 

10 years), a diverse, productive, and permanent vegetative cover would be 

established on the LBA tract. The decrease in plant diversity would not seriously 

affect the potential productivity of the reclaimed areas, and the proposed 

postmining land use (wildlife habitat and rangeland) should be achieved even with 

the changes in vegetation composition and diversity. 

Surface disturbance would occur on the tract under all of the alternatives. By the 

time mining ceases, over 75 percent of these disturbed lands would have been 

reseeded. The remaining 25 percent would be reseeded during the following two 

to three years as the life-of-mine facilities area is reclaimed. 

The reclamation plan for the existing Antelope Mine includes steps to control 

invasion by weedy (invasive nonnative) plant species because WDEQ/LQD 

requires surface coal mine operators to control and minimize the introduction of 

noxious weeds until bond release, in accordance with federal and state regulatory 

requirements. Section 3.9.4 includes a discussion of the steps that the Antelope 

Mine uses to control noxious weeds. As a result there are few occurrences of 

noxious weeds in the mine area. The reclamation plan for the West Antelope II 

LBA tract would also include steps to control invasion from such species. 

Wyoming, including the PRB, has been experiencing drought conditions for the 

past seven or eight years. The climatic record of the western U.S. suggests that 

droughts could re-occur periodically during the life of the mine. Droughts tend to 

hamper revegetation efforts because a lack of sufficient moisture reduces 

germination and could damage newly established plants. Same-aged vegetation is 

more susceptible to disease than plants of various ages. Severe thunderstorms 

could also adversely affect newly seeded areas. Once a stable vegetative cover is 

established, however, these events would have similar impacts as would occur on 

native vegetation. 

Changes expected in the surface water network on the LBA tract as a result of 

mining and reclamation would affect the reestablishment of vegetation patterns on 

the reclaimed areas to some extent. The postmining maximum overland slope 

3-88 Draft EIS, Antelope Coal Company Lease Application 
 

3.0 Affected Environment and Environmental Consequences 

would be 20 percent, in accordance with WDEQ policy. The average reclaimed 

overland slope on the LBA tract would not be known until WDEQ’s technical 

review of the permit revision application is complete. No significant changes in the 

average overland slope are predicted. 

Following reclamation, the LBA tract would be primarily a mixture of upland 

prairie grasslands with graminoid/forb-dominated areas. An overall reduction in 

species diversity, especially for the shrub component, would occur. Following 

reclamation bond release, management of the privately owned surface areas would 

revert back to the private surface owners, who would have the right to manipulate 

the reclaimed vegetation. 

There would be no net loss of jurisdictional wetlands. They would be restored 

under the jurisdiction of the COE (Section 3.7). Functional wetlands would be 

restored in accordance with the requirements of the surface landowner. 

The decrease in plant diversity would not seriously affect productivity of the 

reclaimed areas, regardless of the alternative selected. The proposed postmining 

land use (wildlife habitat and rangeland) would generally be achieved even with 

the changes in vegetative species composition and diversity, although there would 

be some long term reduction in habitat for some wildlife species. 

3.9.2.2 No Action Alternative 

Under the No Action Alternative (Alternative 3), the West Antelope II coal lease 

application would be rejected and coal removal and the associated disturbance 

and impacts to vegetation would not occur on from 4,314 up to 6,625 acres that 

would be disturbed under the Proposed Action or Alternatives 1 and 2, 

respectively. Coal removal and the associated vegetation removal and replacement 

would occur on the existing Antelope Mine leases as currently permitted. 

Vegetation on portions of the West Antelope II LBA tract adjacent to the Antelope 

Mine would be disturbed to recover the coal in the existing leases. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in 

the future. 

3.9.3 Threatened, Endangered, Proposed, and Candidate Plant Species, and 

BLM Sensitive Species 

Refer to Appendices H and I. 

3.9.4 Regulatory Compliance, Mitigation and Monitoring 

Reclaimed areas would be revegetated as specified in the approved mine plan 

using reclamation seed mixtures which would be approved by WDEQ/LQD. The 

majority of the species would be native to the LBA tract. At least 20 percent of the 

Draft EIS, Antelope Coal Company Lease Application 3-89 
3.0 Affected Environment and Environmental Consequences 

native vegetation area would be reclaimed to native shrubs at a density of one per 

square meter or as required by current regulations. Shrubs would be selectively 

planted in riparian areas and trees would be replaced in a one-to-one ratio. 

WDEQ/LQD Rules and Regulations require that: 

•	 Permit applications for surface coal mines include a description of any 

weeds or other plants listed by the local Weed and Pest Control District as 

harmful (Chapter 2, Section 2(a)(vi)(C)(2)); and 

•	 Surface coal mine operators control and minimize the introduction of 

noxious weeds in accordance with federal or state requirements (Chapter 4, 

Section 2 (d)(xiv)). 

Steps to control invasion by weedy (invasive nonnative) plant species using 

chemical and mechanical methods would be included in the amended mine plan. 

The mine currently has an active noxious weed control program. The most 

common and problematic noxious weed in the area is Canada thistle. The mine 

annually contracts with a weed control expert certified by the state of Wyoming. 

This contractor completes chemical applications to noxious weed infestations 

identified by mine personnel and also traverses the remainder of the mine permit 

area and applies chemical control to any other noxious weed infestations 

encountered. The Antelope Coal Mine works with the local county weed and pest 

control agents to control noxious weeds as necessary. The mine also conducts 

other control programs including mowing, tillage, and reseeding of weedy areas. 

Detailed wetland mitigation plans would be developed and approved by the COE 

during the permitting stage to ensure no net loss of jurisdictional wetlands occurs 

within the total disturbance area (Section 3.7). Non-jurisdictional and functional 

wetlands would be restored in accordance with the requirements of the surface 

landowner or as required by WDEQ/LQD. 

Revegetation growth and diversity would be monitored until the final reclamation 

bond is released (a minimum of 10 years following seeding with the final seed 

mixture). Erosion would be monitored to determine if there is a need for corrective 

action during establishment of vegetation. Controlled grazing would be used 

during revegetation to determine the suitability of the reclaimed land for postmining land uses. 

3.9.5 Residual Impacts 

Reclaimed vegetative communities may never completely match the surrounding 

native plant community. 

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3.0 Affected Environment and Environmental Consequences 

3.10 Wildlife 

3.10.1 General Setting 

This section discusses the affected environment and potential environmental 

consequences to wildlife in general. The subsequent sections address the 

potential impacts to specific groups of wildlife species. The balance of this wildlife 

assessment was completed by Jones & Stokes (formerly Thunderbird Wildlife 

Consulting), of Gillette, Wyoming in 2006 and 2007. 

3.10.1.1 Affected Environment 

The BLM study area for the West Antelope II LBA is defined as the original tract, 

as applied for, plus all lands added by the BLM under Alternatives 1 and 2. The 

wildlife general analysis area is defined as the BLM study area plus surrounding 

lands within a one-quarter mile perimeter that could be disturbed by mining the 

coal within the BLM study area. Coincidentally, the general analysis area for this 

discussion also represents the extent of the anticipated permit amendment study 

area for the Antelope Mine, should the mine acquire the tract. 

The wildlife general analysis area abuts the existing Antelope Mine permit area. 

Consequently, portions of the wildlife general analysis area lie within the current 

Antelope Mine permit area and were previously monitored in accordance with the 

current WDEQ/LQD mine permitting requirements. Those requirements include 

surveys that extend 0.5 mile to 2.0 miles beyond the current mine permit area, 

depending on the species. 

Background information on wildlife in the West Antelope II general analysis area 

and surrounding lands was obtained from several sources, including the South 

PRB Coal FEIS (BLM 2003a), records from the WGFD, BLM, USFWS, USDA-FS, 

and personal contact with biologists from those four agencies. Site-specific data 

for the West Antelope II general analysis area were obtained from several sources, 

including WDEQ/LQD mine permit applications and annual wildlife monitoring 

reports for the applicant and nearby coal mines. 

Surveys conducted during annual monitoring for existing permitted areas at the 

Antelope Mine include the permit area and a one-mile perimeter. A two-mile 

perimeter is used for big game and wildlife baseline studies. Due to the proximity 

of the proposed lease area to the existing mine permit area, all but the northern 

third of the West Antelope II general analysis area has been included in multiple 

baseline studies and annual wildlife monitoring efforts associated with the 

Antelope Mine since the early 1980s. Additional acreage within that area was 

included in annual monitoring since 1994, with yearly coverage over the entire 

general analysis area beginning in 1998. 

The Antelope Mine initiated baseline investigations in 2006 expressly for the West 

Antelope II LBA tract. As noted above, those surveys included the general analysis 

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3.0 Affected Environment and Environmental Consequences 

area plus a two-mile perimeter. Again, because the proposed LBA tract is adjacent 

to the existing Antelope Mine, much of the baseline two-mile perimeter had 

coincidentally been covered during previous annual or baseline monitoring studies 

for Antelope or the neighboring North Antelope Rochelle Mine over the last 25 

years. Annual wildlife surveys associated with unrelated CBNG projects in the 

same area have also included the northern portions of the baseline two-mile 

perimeter since 2004. A full description of the extent and timing of coverage 

during mine-related surveys is provided in Appendix H of this EIS document. 

Site-specific surveys for the entire leased area and appropriate perimeters would 

be part of the mine permitting process if the tract is leased. 

The West Antelope II LBA tract is dominated by rolling topography, with a few 

small areas of steeper and more heavily dissected terrain. The area surrounding 

the expansion is also characterized primarily by broken rolling hills and uplands, 

along with some prominent ridgelines and more level terrain along the terraces of 

Antelope and Spring Creeks. Surface mine lands, both active and reclaimed, 

dominate the landscape east and northeast of the southern portion of the tract. 

Elevations range from approximately 4,500 to 5,100 feet above sea level. 

In an undisturbed condition, the major vegetation types in the general analysis 

area would provide habitat for many species. Vegetation types occur in a broad 

mosaic across the landscape; therefore, many wildlife species can be expected to 

utilize more than one habitat type. Predominant wildlife habitat types classified 

on the LBA tract and adjacent area correspond with the major plant communities 

defined during the vegetation baseline survey; they consist primarily 

(approximately 67 percent) of various upland grasslands (Section 3.9, Table 3-11). 

Included within those grasslands are black-tailed prairie dog (Cynomys 

ludovicianus) colonies, roughlands and coulees, and treated grazing lands. 

Smaller proportions (less than 1 to approximately 17 percent) of other habitat 

types are also present, including big sagebrush, birdsfoot sagebrush, grassy 

bottomland, disturbed land, water, silver sagebrush lowland, and greasewood 

lowland. 

Mesic habitats include limited treed riparian corridors, and are restricted to 

narrow bands along primary drainages of Antelope Creek, Spring Creek, and 

Horse Creek as they pass through or adjacent to the LBA tract. Cheatgrass and 

crested wheatgrass have invaded some areas, and a growing network of road and 

well-pad disturbance areas occur in the grassland and sagebrush grassland 

vegetation areas, especially in the north. A few oil tank batteries and increasing 

numbers of natural gas pipelines and facilities are also present, with pipeline 

disturbance corridors in varying degrees of recovering vegetative cover. No 

designated critical, crucial, or unique habitats are present. 

Antelope Creek and Spring Creek (a primary tributary of Antelope Creek) flow 

generally west to east across the narrow band of the West Antelope II study area 

that connects the north and south blocks. Horse Creek, another primary 

tributary of Antelope Creek, flows north to south through the northern-most 

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3.0 Affected Environment and Environmental Consequences 

extent of the LBA tract. All three drainages are intermittent or ephemeral 

streams. Limited portions of the drainages may receive recharge from bank 

storage, making them locally intermittent. 

Historically, water was often present in the main creeks only as small, shallow, 

isolated pools within the deeper channels. However, water levels have increased 

within some drainages over the last year due to the influx of discharged flows 

associated with CBNG development in the area, and those areas are seldom 

completely dry anymore. That water appears to be affecting the chemical balance 

of soils along some portions of Spring Creek, with obvious sodic soils where 

standing water has accumulated. 

Despite this recent influx of water into the general analysis area, many channels 

are still reduced to isolated, shallow pools in the summer. Numerous named and 

unnamed ephemeral tributaries of these creeks also drain portions of the LBA 

tract. Several stock reservoirs are scattered throughout those drainages, and all 

are constructed with earthen berms or dams. Those water bodies provide shortterm habitat for migrating waterfowl, shorebirds, and other aquatic species (birds, 

fish, herptiles) during spring but are less reliable, and often dry, during other 

seasons. 

3.10.1.2 Environmental Consequences 

3.10.1.2.1 Proposed Action and Alternatives 1 and 2 

If the West Antelope II LBA tract is leased under the Proposed Action, or 

Alternatives 1 or 2, coal mining operations at the Antelope Mine would be 

extended by up to 13 years. Impacts to wildlife that would be caused by mining 

the LBA tract would be addressed as part of the review of the mine permit 

application by the WGFD, USFWS, and the WDEQ/LQD when the mining and 

reclamation permit is revised to include the LBA tract. 

Mining directly and indirectly impacts local wildlife populations. These impacts 

are both short-term (until successful reclamation is achieved) and long-term 

(persisting beyond successful completion of reclamation). The direct impacts of 

surface coal mining on wildlife occur during mining and are therefore short-term. 

They include injury and mortalities caused by collisions with mine-related traffic 

or mortalities due to loss of habitat (especially for species with limited mobility 

such as fish and some herptiles); restrictions on wildlife movement due to 

construction of fences, spoil piles, and excavation of pits; and displacement of 

wildlife from active mining areas. Displaced animals may find suitable habitat 

that is not occupied by other animals, occupy suitable habitat that is already 

being used by other individuals, or occupy poorer quality habitat than that from 

which they were displaced. In the latter two situations, the animals may suffer 

from increased competition with other animals and are less likely to survive and 

reproduce. If the West Antelope II LBA tract is leased and mined, the direct 

impacts related to mine traffic and mine operations would be extended within the 

Draft EIS, Antelope Coal Company Lease Application 3-93 
3.0 Affected Environment and Environmental Consequences 

general analysis area by up to 13 years. 

The indirect impacts are longer term than the direct impacts. Results from longterm surveys conducted at the Antelope Mine, and from those completed in both 

native and reclaimed habitats at other surface mines in the region, demonstrated 

that some reclaimed habitat types can support levels of species diversity and 

abundance equal to or greater than their native counterparts. However, wildlife 

species composition can be quite different between pre- and post-mining habitats, 

depending on the structure and composition of native habitats prior to 

disturbance. 

After the LBA tract is leased, mined, and reclaimed, alterations in the topography 

and vegetative communities would likely result in such changes in species 

composition from pre-mine conditions. Some vegetative communities currently 

present in the tract, such as low-growth species (e.g., blue grama, and birdsfoot 

sagebrush) and big sagebrush, are often difficult to reestablish through artificial 

plantings. Wildlife species associated with pre-mining vegetative communities 

would be replaced by species that are typically associated with the taller and/or 

denser vegetation that is often present in reclaimed areas, especially until 

reclamation matures to its target mix. 

Topographic changes would be permanent, and microhabitats may be reduced on 

reclaimed land due to flatter topography, less diverse vegetative cover, and 

reduction in sagebrush density. Changes in the composition between pre- and 

post-mining vegetation and wildlife species may be reduced if special efforts are 

made to reestablish low-growth and shrub habitat types. In the past, Antelope 

Mine has addressed low-growth specialized habitat needs with reclamation by 

creating new prairie dog colonies in reclaimed areas through translocation efforts, 

thus reestablishing the short-grass community present prior to disturbance. 

Such efforts have been curtailed by recent regulatory restrictions. 

3.10.1.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and the impacts to wildlife and wildlife habitat associated with coal 

removal described above would not occur on the West Antelope II LBA tract. 

Wildlife habitat on from 4,314 to 6,625 additional acres (under the Proposed 

Action, or Alternatives 1 and 2) would not be disturbed. Mining operations and 

associated impacts to wildlife and wildlife habitat would continue as currently 

permitted on the existing Antelope Mine coal leases but would not be extended 

onto portions of the LBA tract that will not be affected under the current mining 

and reclamation plan. Impacts to wildlife and wildlife habitat associated with 

CBNG development would continue where those activities overlap with the West 

Antelope II LBA tract. 

3-94 Draft EIS, Antelope Coal Company Lease Application 
 

3.0 Affected Environment and Environmental Consequences 

3.10.2 Big Game 

3.10.2.1 Affected Environment 

The two big game species that are common in suitable habitat throughout the 

general analysis area are pronghorn (Antilocapra americana) and mule deer 

(Odocoileus hemionus), though pronghorn are more abundant. White-tailed deer 

(Odocoileus virginianus) are occasionally observed along the cottonwood corridor 

bordering Antelope Creek. The nearest elk (Cervis elaphus) population is the 

Rochelle Hills Herd, approximately 13 miles east of the study area; elk are rarely 

recorded within the general analysis area. 

Pronghorn are the most common big game species in the general analysis area. 

However, pronghorn density within two miles of the LBA tract has consistently 

been lower than that of a larger multi-mine survey area over time. The differences 

are probably due primarily to the vegetative characteristics of the general analysis 

area. The majority of the West Antelope II LBA tract is comprised of grassland 

habitats, which are not preferred by wintering pronghorn (Sundstrom et al. 1973). 

The same is true for the current Antelope Mine annual wildlife monitoring survey 

area (current permit boundary plus a one-mile perimeter), which regularly 

supports fewer wintering pronghorn than other portions of the multi-mine survey 

block. Similarly, only small groups of pronghorn are regularly present in 

reclaimed habitats, which are currently dominated by grass species with only a 

modest shrub component. The home range for pronghorn can vary between 400 

to 5,600 acres depending on several factors, including season, habitat quantity 

and quality, population characteristics, and local livestock occurrence. In 

northeast Wyoming, daily movement typically does not exceed six miles. 

Pronghorn may make seasonal migrations between summer and winter habitats, 

but migrations are often triggered by availability of specific plants and not local 

weather conditions (Fitzgerald et al. 1994). 

The WGFD has classified the general analysis area as primarily yearlong 

pronghorn range, which means that a population or a portion of a population of 

animals makes general use of this habitat on a year-round basis. Within the LBA 

as-applied-for area, the SE 1⁄4 of Section 10, T.40N., R.71W. encompasses severe 

winter relief habitat for antelope, as classified by the WGFD. Severe winter relief 

habitat is defined as “a documented survival range which may or may not be 

considered a crucial range area...it may lack habitat characteristics which would 

make it attractive or capable of supporting major portions of the population during 

normal years but is used by and allows at least a significant portion of the 

population to survive the occasional extremely sever winter” (TWS Wyoming 

Chapter 1990). The Cheyenne River Pronghorn Herd Unit encompasses the entire 

general analysis area. The WGFD estimated the 2006 post-season pronghorn 

population to be approximately 39,621 animals; the herd objective is 38,000 

(WGFD 2006). 

Mule deer use nearly all habitats, but prefer sagebrush grassland, rough breaks, 

Draft EIS, Antelope Coal Company Lease Application 3-95 
3.0 Affected Environment and Environmental Consequences 

and riparian bottomland. Browse is an important component of the mule deer’s 

diet throughout the year, comprising as much as 60 percent of total intake during 

autumn, while forbs and grasses typically make up the rest of their diet (Fitzgerald 

et al. 1994). Mule deer are not abundant in the general analysis area, with most 

individuals recorded in eroded draws, riparian corridors, and reclaimed lands in 

that vicinity. In certain areas of the state, this species tends to be more migratory 

than white-tailed deer, traveling from higher elevations in the summer to winter 

ranges that provide more food and cover. However, monitoring indicates that 

mule deer are not very migratory in the vicinity of the West Antelope II LBA tract. 

The WGFD has classified the general analysis area as yearlong mule deer range, 

with the extreme southeastern portion as winter/yearlong. The entire area is 

located within the Thunder Basin Herd Unit. The WGFD estimated the 2006 postseason mule deer population to be approximately 22,036 animals, whereas the 

herd objective was 20,000 (WGFD 2006). No crucial or critical mule deer ranges 

or migration corridors occur on or within several miles of the West Antelope II LBA 

tract. 

White-tailed deer and elk are generally managed separately by the WGFD. Whitetailed deer prefer riparian habitats, whereas elk are typically observed in and near 

rough breaks and pine stands. Those habitat types are not common within the 

general analysis area, which accounts for the rare sightings of white-tailed deer 

and elk in that region. The WGFD classifies the entire area as out of the normal 

white-tailed deer and elk use range, with the exception of a narrow corridor along 

Antelope Creek which is classified as yearlong range. The majority of white-tailed 

deer sightings were confined to the Antelope Creek riparian corridor. Elk 

observations were limited to rare records in the extreme southeastern corner of 

the winter big game survey perimeter. 

3.10.2.2 Environmental Consequences 

3.10.2.2.1 Proposed Action and Alternatives 1 and 2 

Under the Proposed Action, and Alternatives 1 and 2, big game would be displaced 

from portions of the West Antelope II LBA tract to adjacent ranges during mining. 

Pronghorn would be most affected; however, no areas classified as crucial 

pronghorn habitat occur on or within two miles of the LBA tract, and this species 

is not as prevalent in the general analysis area as elsewhere within the region. 

Mule deer would not be substantially impacted, given their infrequent use of these 

lands and the availability of suitable habitat in adjacent areas. The WGFD does 

not consider the general analysis area to be within either white-tailed deer or elk 

use range, and sightings of those species in that vicinity are uncommon or rare, 

respectively. 

Big game displacement would be incremental, occurring over several years and 

allowing for gradual changes in distribution patterns. Big game residing in the 

adjacent areas could be impacted by increased competition with displaced 

animals. Noise, dust, and associated human presence would cause some localized 

3-96 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

avoidance of foraging areas adjacent to mining activities. On the existing coal 

leases, however, big game have continued to occupy areas next to and within 

active mining operations, suggesting that some animals may become habituated to 

such disturbances. 

Big game animals are highly mobile and can potentially move to undisturbed 

areas. But if the tract is leased, once surface disturbance begins, big game 

movement would be restricted on or through the tract due to the construction of 

fences, spoil piles, and pits related to mining. During winter storms or other 

stressful weather events, pronghorn may not be able to negotiate these barriers. 

WDEQ guidelines require fencing to be designed to permit pronghorn passage to 

the extent possible. Following reclamation, topographic moderation and changes 

in vegetation may result in long-term effects on big game carrying capacity. 

3.10.2.2.2 No Action Alternative 

The impacts to big game under the No Action Alternative would be similar to the 

impacts previously described in Section 3.10.1.2.2. 

3.10.3 Other Mammals 

3.10.3.1 Affected Environment 

A variety of small and medium-sized mammal species occur in the vicinity of the 

general analysis area, although not all have been observed on the LBA tract. 

These include predators and furbearers such as the coyote (Canis latrans), red fox 

(Vulpes vulpes), swift fox (Vulpes velox), bobcat (Lynx rufus), striped skunk 

(Mephitis mephitis), weasels (Mustela spp.), badger (Taxidea taxus), muskrat 

(Ondatra zibethicus), raccoon (Procyon lotor), and beaver (Castor canadensis). Prey 

species include various rodents [including mice, rats, voles, gophers, ground 

squirrels, chipmunks, and black-tailed prairie dogs (Cynomys ludovicianas)) and 

lagomorphs [jackrabbits (Lepus spp.) and cottontails (Sylvilagus spp.)]. These prey 

species are cyclically common, widespread throughout the region, and are 

important for raptors and other predators. Porcupines (Erethizon dorsatum) and 

bats [such as hoary (Lasiurus cinereus), big brown (Eptesicus fuscus), and 

Townsend’s big-eared (Corynorhinus townsenii)] have not been documented in the 

general analysis area, and have limited potential habitat in the vicinity. 

The black-tailed prairie dog was added to the list of candidate species for federal 

listing on February 4, 2000 (USFWS 2000a). The USFWS has since removed the 

black-tailed prairie dog from the list of candidate species (USFWS 2002a), but 

continues to encourage the protection of prairie dog colonies for their value to the 

prairie ecosystem and the myriad of species that rely on them (USFWS 2004a). 

The black-tailed prairie dog is a USDA-FS Region 2 Sensitive species and 

Management Indicator Species (see Appendix H), and is also recognized as a BLM 

Sensitive species. 

Draft EIS, Antelope Coal Company Lease Application 3-97 
3.0 Affected Environment and Environmental Consequences 

The black-tailed prairie dog is a highly social, diurnally active, burrowing 

mammal. Aggregations of individual burrows, known as colonies, form the basic 

unit of prairie dog populations. Found throughout the Great Plains in short-grass 

and mixed-grass prairie areas (Fitzgerald et al. 1994), the black-tailed prairie dog 

has declined in population numbers and extent of colonies in recent years. The 

three major impacts that have influenced black-tailed prairie dog populations are 

the initial conversion of prairie grasslands to cropland in the eastern portion of its 

range from approximately the 1880s through the 1920s; large-scale control efforts 

conducted from approximately 1918 until 1972 when an Executive Order was 

issued banning the use of compound 1080 (a predacide and rodenticide); and the 

introduction of sylvatic plague into North American ecosystems in 1908 (USFWS 

2000b). 

Currently, this species is primarily found in isolated populations in the eastern 

half of Wyoming (Clark and Stromberg 1987). Prairie dogs are considered a 

common resident in eastern Wyoming, utilizing short-grass and mid-grass 

habitats (Cerovski et al. 2004). The USFWS recently estimated that about 

125,000 acres of occupied black-tailed prairie dog habitat exists in Wyoming 

(USFWS 2004b). Prairie dogs construct extensive burrow systems in fine- to 

medium-textured upland soil types. Many other wildlife species, such as the 

black-footed ferret (Mustela nigripes), swift fox, mountain plover (Montanus 

charadrius), ferruginous hawk (Buteo regalis), and burrowing owl (Athene 

cunicularia) may be dependent on the black-tailed prairie dog for some portion of 

their life cycle (USFWS 2000b). 

According to USDA-FS observations on the TBNG, the largest concentrations of 

prairie dog colonies in the vicinity of the surface coal mines are found east of the 

coal burnline, which is east and beyond the area of surface coal mining (Tim Byer, 

personal communication 9/11/2003). The large prairie dog complexes in the area 

east of the coal burnline have been drastically impacted by outbreaks of plague in 

recent years. The colonies west of the burnline, including those within and near 

the West Antelope II LBA tract, are generally smaller and less densely 

concentrated. Nevertheless, some of those colonies have also been impacted by 

plague within the last three years (refer to Antelope Mine Annual Wildlife Reports, 

on file with WDEQ/LQD). 

Surveys have been conducted to locate prairie dog colonies on and within two 

miles of the LBA tract as applied for under the Proposed Action and Alternatives 1 

and 2 (BLM study area). The two-mile perimeter encompasses the general 

analysis area. Sixteen prairie dog colonies were found within this survey area, 

with 4 colonies (approximately 188 acres) within the LBA general analysis area 

(Figures 3-16 and 3-17). Additional discussion of prairie dog colonies identified in 

the vicinity of the West Antelope II area is included in the Biological Assessment 

(Appendix I) of this EIS. 

3-98 Draft EIS, Antelope Coal Company Lease Application 
18 17

 

 

 

 

 

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Campbell County 

Converse County 

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Antelope Cr. 

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

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!(59 

LEGEND 

Two-Mile Perimeter 

B.N.S.F. & U.P. RR 

PDC 

B Unknown Buteo Species 

BO Burrowing Owl 

FH Ferruginous Hawk 

GE Golden Eagle 

GHO Great Horned Owl 

RTH Red-Tailed Hawk 

SH Swainson's Hawk 

£ 0 10,000 20,000 

GRAPHIC SCALE (FEET) 

Figure 3-16. Raptor Nest Sites and Prairie Dog Colonies Within the West Antelope II Wildlife Two-Mile 

Perimeter Area. 

! Existing Raptor Nest 

# Existing Platform Nest 

" Nest Box 

( Former Raptor Nest 

* Former Platform Nest 

Prairie Dog Colony (PDC) 

WA II Wildlife Two-Mile Perimeter 

West Antelope II LBA Tract As Applied For 

Area Added under Alternative 1 

North Tract (Alternative 2) 

South Tract (Alternative 2) 

General Analysis Area 

Draft EIS, West Antelope II Coal Lease Application 3-99
 

 

3.0 Affected Environment and Environmental Consequences 

Y Y

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Campbell County 

Converse County 

Antelope Cr. 

B.N.S.F. & U.P. RR 

R. 72 W. R. 71 W. R. 71 W. R. 70 W.

T. 

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£ WA II Wildlife Two-Mile Perimeter 

West Antelope II LBA Tract As Applied For 

Area Added under Alternative 1 

North Tract (Alternative 2) 

South Tract (Alternative 2) 

General Analysis Area 

Lagamorph Driving Route 

Mule Deer Driving Route 

LEGEND 

0 10,000 20,000 

GRAPHIC SCALE (FEET) 

Two-Mile Perimeter 

An telope R d. 

County Rd. 37 

Y Active Mountain Plover Use Area (MPA) 

Recent Mountain Plover Use Area (MPA): 

Historical Mountain Plover Use Area (MPA): 

Prairie Dog Colony 

Active at least one year during current monitoring program (1994-2006). 

As mapped in 1989 using 1982-1988 data. [Included infrequently used, 

unoccupied suitable, and unsuitable habitat when originally mapped.] 

Inactive for 1 - 12 years during current monitoring program (1994-2006). 

As mapped in 1989 using 1982-1988 data. [Included infrequently used, 

unoccupied suitable, and unsuitable habitat when originally mapped.] 

Area Where Mountain Plovers were seen during current monitoring 

program (1994-2006). [Included infrequently used areas.] 

Figure 3-17. Wildlife Features and Survey Routes Within the West Antelope II Wildlife Two-Mile Perimeter Area. 

3-100
 Draft EIS, West Antelope II Coal Lease Application
3.0 Affected Environment and Environmental Consequences 

3.10.3.2 Environmental Consequences 

3.10.3.2.1 Proposed Action and Alternatives 1 and 2 

Medium-sized mammals (such as lagomorphs, coyotes, and foxes) would be 

temporarily displaced to other habitats by mining, potentially resulting in 

increased competition and mortality. However, these animals would rebound as 

forage is developed or small mammal prey species recolonize the reclaimed areas. 

Direct losses of small mammals would be higher than for other wildlife, since the 

mobility of small mammals is limited and many would retreat into burrows when 

disturbed. Therefore, local populations of such prey species as voles, ground 

squirrels, and mice would decline during mining. However, these animals have a 

high reproductive potential and tend to re-occupy and adapt to reclaimed areas 

quickly. A research project on habitat reclamation on mined lands within the PRB 

for small mammals and birds concluded that objectives to encourage 

recolonization of reclamation by small mammal communities are being achieved 

(Shelley 1992). That study evaluated sites at five separate mines. 

All or portions of four prairie dog colonies occur in the general analysis area and 

would be affected by leasing and mining the area described in the Proposed 

Action, or Alternatives 1 or 2. However, 74 percent of the total acreage (12 

additional colonies) within the two-mile perimeter would be either only partially 

disturbed or not disturbed at all by mining under those options. Refer to the 

Biological Assessment (Appendix I) of this EIS for further discussion of impacts to 

prairie dog colonies in the general analysis area. 

3.10.3.2.2 No Action Alternative 

Impacts to small mammals under the No Action Alternative would be similar to 

the impacts described in Section 3.10.1.2.2, above. 

3.10.4 Raptors 

3.10.4.1 Affected Environment 

The raptor species known or expected to occur in suitable habitats in the general 

analysis area include the golden eagle (Aquila chrysaetos), ferruginous hawk 

(Buteo regalis), red-tailed hawk (Buteo jamaicensis), Swainson’s hawk (Buteo 

swainsoni), rough-legged hawks (Buteo lagopus), northern harrier (Circus cyaneus), 

American kestrel (Falco sparverius), prairie falcon (Falco mexicanus), great horned 

owl (Bubo virginianus), burrowing owl, and short-eared owl (Asio flammeus). Many 

of these species are USDA-FS and BLM Sensitive Species (see Appendix H). 

The bald eagle (Haliaeetus leucocephalus) is a migrant and common winter 

resident of the Wyoming Powder River Basin region. On July 9, 2007, the USFWS 

published a Federal Register notice (72 FR 37346) announcing that the bald eagle 

(Haliaeetus leucocephalus) would be removed from the list of threatened and 

Draft EIS, Antelope Coal Company Lease Application 3-101 
3.0 Affected Environment and Environmental Consequences 

endangered species under the Endangered Species Act of 1973, as amended (16 

U.S.C 1531 et seq.) on August 8, 2007. However, the protections provided to the 

bald eagle under the Bald and Golden Eagle Protection Act (BGEPA), 16 U.S.C. 

668, and the Migratory Bird Treaty Act (MBTA), 16 U.S.C. 703, will remain in 

place. The bald eagle is now recognized as a Sensitive Species and is further 

discussed in the Sensitive Species Evaluation (Appendix H) of this EIS. 

Raptors that commonly nest in the general analysis area are the golden eagle, 

ferruginous hawk, red-tailed hawk, Swainson’s hawk, American kestrel, great 

horned owl, and burrowing owl. No nest sites have been documented in the 

general analysis area for northern harriers or short-eared owls, though occasional 

sightings of recently fledged young indicate that such activities do occur there for 

one or both of those species. Habitat is limited for those species that nest 

exclusively in trees or on cliffs, but several species are adapted to nesting on the 

ground, creek banks, buttes, or rock outcrops. Rough-legged hawks are winter 

residents in northeast Wyoming, and breed in the arctic regions. 

Figure 3-16 shows the locations of raptor nests identified within the West Antelope 

II general analysis area. The two-mile wildlife perimeter is also shown. Since 

1982, raptors have been monitored every year within this two-mile perimeter. 

Specific details regarding those nests, including their historical use by nesting 

raptors, will be provided in a future wildlife baseline report for that area. Previous 

information is available in the annual wildlife reports for the Antelope Mine. Over 

time, natural forces have destroyed many nests, while others have been relocated 

for mitigation or have been removed by mining activities. In some cases, nests 

have been created to mitigate other nest sites that were impacted by operations at 

the Antelope Mine. 

During surveys completed in 2006 by Thunderbird-Jones & Stokes (J&S, formerly 

Thunderbird Wildlife Consulting), a total of six raptor species (golden eagle, 

ferruginous hawk, red-tailed hawk, Swainson’s hawk, great horned owl, and 

burrowing owl) nested within the West Antelope II wildlife two-mile perimeter area 

(see Figure 3-16). Five of those six species have regularly nested within this area 

since annual monitoring began in 1982. Swainson’s hawks began nesting in the 

area more recently, with the first nest documented within the survey area in 1998. 

Based on sightings of young, it is likely that at least one pair of American kestrels 

nested in one of the many small cavities present in the snags along Antelope 

Creek. Eighty-three raptor nests were intact within the entire wildlife two-mile 

perimeter area during the 2006 breeding season; one nest was removed prior to 

mining in the autumn. 

In 2006, thirteen intact nests were on the LBA tract as applied for, including 1 

golden eagle nest, 5 ferruginous hawk nests (four territories), and 7 burrowing owl 

nest sites (four territories). One ferruginous hawk nest was removed during 

autumn, 2006, due to encroaching mine operations. Three additional raptor nests 

were present on lands added under Alternatives 1 and 2: a ferruginous hawk nest 

in one of the above territories, one burrowing owl nest site, and one nest used 

3-102 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

historically by red-tailed hawks and golden eagles (used solely by golden eagles 

since at least 1997). The remaining 67 intact nests were within two miles of the 

LBA tract. Only 5 of the 16 intact nests encompassed by the West Antelope II LBA 

tract or added lands were active during 2006: four on the tract itself and one on 

lands included with Alternative 1 and Alternative 2. 

3.10.4.2 Environmental Consequences 

3.10.4.2.1 Proposed Action and Alternatives 1 and 2 

Mining the LBA tract would not impact overall regional raptor populations, 

however, individual birds or pairs may be impacted. Mining activity could cause 

raptors to abandon nests proximate to disturbance, particularly if mining 

encroaches on active nests during a given breeding season. USFWS recommends 

a one-mile buffer around all ferruginous hawk nests. In 2006, 11 ferruginous 

hawk nests in four territories were present within the West Antelope II general 

analysis area, with 5 nests in the BLM study area itself (LBA tract as applied for 

under the Proposed Action plus additional lands added by BLM under Alternative 

1 and 2). A sixth nest was removed after that breeding season. Ferruginous 

hawks have actively nested (laid eggs) at only one of those sites in recent years, 

and that nest was last active in 2003. 

For the last 15 years, monitoring data has indicated that the majority of nests 

within the general analysis area (the tract as applied for plus the additional area 

evaluated under Alternative 1 and 2, plus a one-quarter mile buffer) have served 

as alternate nesting sites for other active nests elsewhere within raptors’ 

respective territories beyond that area. Nests of most other raptor species 

(including all of the others present on the LBA tract) are typically buffered by a 

one-quarter- or one-half-mile radius. 

USFWS and WDEQ/LQD approval would be required before mining would occur 

within buffer zones for active raptor nests. The Antelope Mine annually monitors 

territorial occupancy and nest productivity on and around their existing leases. 

Several raptor pairs from multiple species have successfully nested within 200­

1,000 feet of active mining at Antelope, including golden eagles, red-tailed hawks, 

and great horned owls. All five species represented on the LBA tract have 

successfully nested near active mining and construction areas throughout the 

PRB of northeast Wyoming. Those efforts have succeeded due to a combination of 

two things: 1) raptors becoming acclimated to the gradual encroachment of mine 

operations, and 2) successfully implemented progressive mitigation techniques to 

maintain viable raptor territories and protect nest productivity. Details 

documenting raptor nesting efforts and success near mine operations are available 

in the Antelope Mine Annual Wildlife Reports, on file with the WDEQ/LQD in 

Cheyenne, Wyoming. 

Mining within or near raptor territories would impact availability of foraging 

habitat for nesting birds. However, increased acreage of reclamation within the 

Draft EIS, Antelope Coal Company Lease Application 3-103 
3.0 Affected Environment and Environmental Consequences 

permit area would offset new habitat loss as mining progresses. Equipment yards 

associated with mining provide additional habitat for prey species such as 

cottontails, and several raptor pairs voluntarily nest near those areas. As at other 

surface mines throughout the region, raptor nesting efforts at Antelope Mine have 

typically been influenced primarily by natural factors such as prey abundance and 

availability of nesting substrates. Due to the lack of woody vegetation, raptors 

that nest in trees or on cliffs are not as abundant as those that either nest on the 

ground or are adaptable to nesting on mine facilities or other man-made 

structures (platform nests, etc.). During mining, new nesting habitat can be 

created through enhancement efforts like nest platforms, nest boxes, and tree 

plantings. 

3.10.4.2.2 No Action Alternative 

Impacts to raptor species under the No Action Alternative would be similar to the 

impacts described in Section 3.10.1.2.2, above. 

3.10.5 Upland Game Birds 

3.10.5.1 Affected Environment 

Four upland game bird species have historically been documented within the West 

Antelope II general analysis area. These species are the mourning dove (Zenaida 

macroura), wild turkey (Meleagris gallopavo), gray (or Hungarian) partridge (Perdix 

perdix), and greater sage-grouse (Centrocercus urophasianus). However, the 

mourning dove is the most prevalent upland game bird in the general analysis 

area, and the only species known to occur with any regularity. 

The mourning dove is a relatively common breeder in Campbell and Converse 

Counties. Doves are often seen in the area during migration, with fewer 

observations during the nesting season. Most sightings occurred near sites with 

water sources and trees, though they have occasionally been recorded in 

sagebrush or greasewood stands. 

Wild turkeys have been seen infrequently over time, with spans of several years 

between observations. All observations occurred during spring, when males were 

gobbling. This species has been recorded along Antelope Creek, generally east of 

the LBA tract. However, they have also been seen on the tract itself, or along the 

creek channel west of the tract. 

The gray partridge is an introduced species, and has also been occasionally 

documented in the general analysis area. Individual birds were observed in the 

vicinity of the study area in December 1984 and again in March 1985. No other 

sightings were recorded until December 1999, when snow tracks were seen within 

the current Antelope permit area, approximately one mile northeast of the 

southern block of the LBA tract, as applied for. No gray partridge have been 

observed in the general analysis area since then. 

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The greater sage-grouse, hereafter referred to as sage-grouse, is a species of 

concern throughout the West, and is considered a “landscape species” which 

means that large expanses of unfragmented land are required in order to provide 

all the habitat components for their annual life cycle. Relying on sagebrush for 

food, cover, and shelter, sage-grouse require sagebrush habitat year-round and for 

every phase of their life cycle. 

Sage-grouse breeding occurs on strutting grounds (leks) during late March and 

April. Leks are generally established in open areas surrounded by big sagebrush, 

which is used for escape and protection from predators. Generally, lek sites are 

used year after year and are considered to be the center of year-round activity for 

resident sage-grouse populations. On average, the majority of sage-grouse hens 

nest within 4 miles (6.2 km) of the lek. New spring plant growth, residual cover, 

and understory are important habitat components for nesting sage-grouse hens. 

Areas near the nest are used for several weeks by hens for brood rearing. The 

habitats used during the first few weeks after hatching must provide good cover to 

conceal the chicks and must provide essential nutritional requirements during 

this period of rapid development. Brood-rearing habitats that have a wide 

diversity of plant species tend to provide a variety of insects that are important 

chick foods. 

Summer habitat consists of sagebrush mixed with areas of wet meadows, riparian, 

or irrigated agricultural fields. As summer progresses and food plants mature and 

dry up, sage-grouse broods move to more mesic wet meadows where succulent 

plants and insects are still available. This can be especially important in drier 

years and during long drought periods. As fall nears, sage-grouse form flocks as 

brood groups break up. As fall progresses, sage-grouse move toward their winter 

ranges. 

During winter, sage-grouse feed almost exclusively on sagebrush leaves and buds. 

Suitable winter habitat requires sagebrush above snow. It is crucial that 

sagebrush be exposed at least 10 to 12 inches above snow level as this provides 

food and cover for wintering sage-grouse. Population and habitat analyses 

suggest that wintering habitat can be as limiting as breeding habitats. These 

seasonal movements are related to severity of winter weather, topography, and 

vegetative cover. 

Since 1999, the USFWS has received eight petitions requesting that greater sagegrouse be listed as threatened or endangered. Three of the petitions requested 

that greater sage-grouse be listed as endangered across its entire range. Following 

a 12-month status review of the best available scientific and commercial 

information on the species, the USFWS found that listing was not warranted at 

this time. However, USFWS continues to have concerns regarding sage-grouse 

population status, trends and threats, as well as concerns for other sagebrush 

obligates (USFWS 2005). The USFWS has indicated the need for continued efforts 

to conserve sage-grouse and sagebrush habitat on a long-term basis, and has 

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encouraged continued development and implementation of conservation strategies 

throughout the species’ range. The sage-grouse is also a USDA-FS Region 2 

Sensitive species and Management Indicator Species (see Appendix H). 

On September 11, 2003, the Wyoming Game and Fish Commission announced 

that the 2003 hunting season for sage-grouse in Johnson, Sheridan, and 

Campbell Counties would be closed, following the deaths of 11 sage-grouse in 

northeastern Wyoming from West Nile Virus in August and early September of 

that year. According to a press release, the commission took this action because 

the incidence of infection was much higher in northeastern Wyoming than the rest 

of the state and the area is on the fringe of sage-grouse range with marginal, 

fragmented habitat (WGFD September 11, 2003 press release). Recent lek, or 

strutting ground, count data indicate that Wyoming’s sage-grouse populations 

increased slightly from 2004 through 2007. Lower incidences of West Nile Virus 

mortalities were also documented in those years, primarily the result of cooler 

temperatures that reduced mosquito populations. Sage-grouse hunting seasons 

were consequently reopened in 2004 (Christiansen 2004). 

The Antelope Mine has conducted annual searches for sage-grouse leks within the 

existing permit area and one-mile perimeter as part of its wildlife monitoring 

program since 1982. Baseline inventories that encompassed a two-mile perimeter 

around the permit area were conducted in the late 1970s, 1998, and 2003. Most 

of the surveys conducted since the early 1980s have included the eastern twothirds of the West Antelope II general analysis area and its two-mile perimeter, 

with more complete coverage (up to 80%) in recent years. The entire general 

analysis area and most of its two-mile perimeter were surveyed in spring 2003 as 

part of annual monitoring or baseline studies for the Antelope Mine and its West 

Antelope expansion, respectively. Those surveys included the limited sagebrush 

stands in the general analysis area. At least 80% of the LBA general analysis area 

has been surveyed annually since then as part of annual monitoring efforts for the 

Antelope Mine. In May 2002, the USFWS office in Cheyenne, Wyoming, released a 

list entitled Coal Mine List of 40 Migratory Bird Species of Management Concern in 

Wyoming, which replaced the previous Migratory Birds of High Federal Interest List. 

The greater sage-grouse is included on the updated list, giving further impetus to 

ongoing annual survey efforts. 

The sage-grouse is a year-round resident throughout much of the PRB, but is rare 

in the vicinity of the West Antelope II general analysis area and the adjacent 

Antelope Mine. The lack of use of that region by sage-grouse has been well 

documented from the late 1970s through 2006. The most recent evidence of sagegrouse in the vicinity occurred in early July 2006, when grouse droppings and 

feathers were seen in a sage draw approximately 1.5 miles southeast of the 

general analysis area. The prevalence of sign in that area indicated that multiple 

grouse had recently foraged in that drainage. The last grouse sighting prior to 

that occurred in a draw approximately 1.25 miles southwest of the general 

analysis area in the early 1990s. 

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As discussed in Section 3.9, sagebrush is a component of the big sagebrush 

upland, birdsfoot sagebrush upland, and silver sagebrush upland vegetation 

types, which account for approximately 30 percent of the general analysis area. 

Potential sage-grouse habitat is limited to relatively small scattered sagebrush 

stands with no large expanses of contiguous sagebrush within several miles of the 

area. Consequently, few sage-grouse have ever been documented in the area, and 

no grouse leks, nests, or broods have ever been discovered on or within 2.0 miles 

of the West Antelope II general analysis area. Due to the ephemeral nature of the 

drainages in that area, little potential brood-rearing habitat is present. The 

nearest known sage-grouse lek (Payne) is located more than 5.0 miles to the 

northeast of the general analysis area, just east of the Payne County Road in 

T42N, R70W, SE1⁄4 NW1⁄4 Section 26. A thorough history of sage-grouse survey 

efforts and observations within two miles of the LBA tract is presented in 

Appendix H of this EIS document. 

3.10.5.2 Environmental Consequences 

3.10.5.2.1 Proposed Action and Alternatives 1 and 2 

Leasing and mining the West Antelope II LBA tract would affect some potential 

habitat for mourning doves, wild turkeys, and gray partridge. A portion of the 

best habitat (cottonwood corridor) along Antelope Creek is within the 100-foot 

non-disturbance zone on either side of the channel. Even though the corridor is 

protected by a 100-foot non-disturbance zone, as mining moves adjacent to the 

corridor the habitat will likely be less attractive and less accessible to upland 

game birds and other wildlife. While woody corridors are not abundant in the 

general analysis area, they also are not unique to the LBA tract. Similar habitat is 

present immediately west of the tract, where mining is not projected to occur in 

the near future. Additionally, sightings of turkeys and partridge are infrequent in 

the area, and doves are not restricted to treed habitats. 

Overall, the sage-grouse population has been steadily declining in Wyoming and 

across the rest of the West. A study prepared by the Western Association of Fish 

and Wildlife Agencies estimated that sage-grouse populations in western North 

America declined at an overall rate of 2.0 percent per year from 1965 to 2003 

(Connelly et al. 2004). The decline rate was larger from 1965 to 1985, with 

populations stabilizing and some increasing from 1986 to 2003. For Wyoming, 

this study estimated that sage-grouse populations declined at an average rate of 

9.66 percent from 1968 to 1986, and at an average rate of 0.33 percent per year 

from 1987 to 2003. Population lows were reached in the mid-1990s and there has 

been some gradual increase in numbers since that time (Connelly et al. 2004). 

The West Antelope II LBA tract is within the Northeast Wyoming Local SageGrouse Working Group (NWLSWG) Area, which includes portions of the WGFD 

Sheridan and Casper regions and the Thunder Basin National Grassland. Sagegrouse monitoring has occurred within the NWLSWG Area since 1967. Within this 

area, sage-grouse population trends have exhibited a cyclical pattern, with each 

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3.0 Affected Environment and Environmental Consequences 

successive peak of a cycle being lower than the preceding peak. This suggests a 

long term population decline since at least 1967 (Figure 3-18). 

Figure 3-18. Average Male Sage-Grouse Lek Attendance Within the Northeast Wyoming Local Working 

Group Area (1967-2005). 

Population trends within the NWLSWG Area appear to be mirroring statewide 

trends in Wyoming, although the average number of males per lek in the 

NWLSWG Area, including in the Thunder Basin National Grassland, has typically 

been lower than those observed statewide (Figure 3-19). Since 1996, sage-grouse 

populations within the state and in northeast Wyoming have fluctuated but 

exhibited an overall increase, with a recent peak in male lek attendance occurring 

in 2000 or 2001. 

The causes of the range-wide decline in sage-grouse population levels are not fully 

understood, but they may be influenced by local conditions. However, habitat loss 

due to disturbance of leks, nesting and brood-rearing areas as a result of 

increasing development, drought, and the potential for West Nile virus, as well as 

loss of population connectivity are key threats to this species (Braun 1998, 

Wisdom et al. 2002, Naugle et al. 2004). 

Some potential impacts of mineral development (including coal mining and oil and 

gas development) on sage-grouse include: (1) direct habitat loss and fragmentation 

from mine, well, road, pipeline, transmission and power line construction, (2) 

alteration of plant and animal communities, (3) increased human activity which 

could cause animals to avoid the area, (4) increased noise, which could cause 

animals to avoid an area or reduce their breeding efficiency, (5) increased 

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motorized access by the public leading to legal and illegal harvest, (6) direct 

mortality associated with water evaporation ponds and production pits, and (7) 

reduced water tables resulting in the loss of herbaceous vegetation. Some of these 

impacts are short-term and related to specific periods of activity. In some cases, 

mineral development may result in positive effects, which may include increased 

forb production, habitat diversity, and additional water sources. Some impacts 

may be long-term (30 years or more), and rehabilitation of impacted habitats may 

take many years to complete (WGFD 2003). 

Figure 3-19. Average Male Sage-grouse Lek Attendance Statewide, Within the Northeast Wyoming Local 

Sage-Grouse Working Group Area, and Within the Thunder Basin National Grasslands (1996-2005). 

Areas of suitable habitat for nesting and strutting grounds are needed to sustain 

sage-grouse populations. One recent study suggests that availability of winter 

habitat may also affect sage-grouse populations (Naugle et al. 2006). When 

mining occurs in potential sage-grouse habitat, there is a short-term loss of 

potential nesting habitat and potential disturbance to breeding activities especially 

when mining operations occur in proximity to sage-grouse leks. Following 

reclamation, there may be a long term loss of nesting and winter habitat, 

depending on the amount of sagebrush that is restored relative to the amount of 

sagebrush that was present before mining. Should the BLM study area be leased, 

mined, and reclaimed, alterations in the topography and vegetative communities 

would likely result in such changes in species composition from pre-mine 

conditions. Some vegetative communities currently present in the tract, such as 

low-growth species (e.g., blue grama, and birdsfoot sagebrush) and big sagebrush, 

are often difficult to reestablish through artificial plantings. Until sagebrush 

returns to its premining density levels, there would be a reduction in potential 

habitat for wildlife species associated with this habitat in the West Antelope II 

general analysis area. However, given the limited presence of sage stands in the 

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3.0 Affected Environment and Environmental Consequences 

area, it is not likely that many sagebrush obligates would be affected. 

If mining activities disturbed a lek, sage-grouse would have to use an alternative 

lek or establish a new lek site for breeding activities. Fidelity to lek sites has been 

well documented (WGFD 2003), but monitoring of sage-grouse activities has 

indicated that the birds may change lek sites. 

Baseline (1978-1979, 1998, 2003) and annual monitoring studies (1982-2006) 

have repeatedly demonstrated that sage-grouse do not inhabit the Antelope Mine 

area, although some small areas with marginal potential habitat are present. As 

described previously, those surveys encompassed most of the West Antelope II 

general analysis area and its two-mile perimeter for much of that period. No sagegrouse leks, nests, or broods were observed in that region during any survey year. 

According to WGFD records (obtained from D. Thiele, Regional Biologist, WGFD, 

Buffalo, WY 2006) and USDA-FS records, no sage-grouse leks are known to occur 

within 5.0 miles of the West Antelope II general analysis area. Given the limited 

sightings of sage-grouse observations in the area, and the minimal quantity and 

marginal quality of potential sage-grouse habitat, implementation of the Proposed 

Action or either Alternative 1 or 2 is not likely to negatively impact any existing or 

potential sage-grouse leks, and will not impact prevalent sage-grouse habitats 

(expanses of sagebrush). Refer to Appendix H of this EIS document for more 

details regarding sage-grouse in the general analysis area. 

3.10.5.2.2 No Action Alternative 

Impacts to upland game birds under the No Action Alternative would be similar 

to the impacts described in Section 3.10.1.2.2, above. 

3.10.6 Other Birds 

3.10.6.1 Affected Environment 

USFWS uses a list entitled Migratory Bird Species of Management Concern in 

Wyoming, specifically the Coal Mine List of 40 Migratory Bird Species of 

Management Concern in Wyoming, for reviews related to existing and proposed coal 

mine leased land (USFWS 2002b). This list was taken directly from the Wyoming 

Bird Conservation Plan (Cerovski et al. 2001). The Migratory Bird Species of 

Management Concern in Wyoming replaced the Migratory Birds of High Federal 

Interest (MBHFI) list. The Antelope Mine has conducted annual surveys for avian 

species of concern since at least 1994, incorporating new lists and survey 

protocols as they are issued. Surveys occur in spring and summer to document 

migrating and breeding birds, and include the permit area and one-half-mile 

perimeter. 

Results from surveys for migratory birds at the Antelope Mine are available in 

baseline and annual wildlife reports, on file with the WDEQ/LQD in Cheyenne, 

Wyoming. Those reports include a tabulation of the regional status, expected 

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3.0 Affected Environment and Environmental Consequences 

occurrence, historical observations, and breeding records for each species on the 

current list of avian species of concern for a given report year, as well as two or 

more preceding years. Additional information for each species observed within the 

given year is provided in the text of those reports. 

Non-raptor avian species that have been documented within the Powder River 

Basin and are included on both the Coal Mine list of Migratory Bird Species of 

Management Concern and at least one more list of special status species include 

the mountain plover (Charadrius montanus), long-billed curlew (Numenius 

americanus), yellow-billed cuckoo (Coccyzus americanus), sage thrasher 

(Oreoscoptes montanus), loggerhead shrike (Lanius ludovicianus), Baird’s sparrow 

(Ammodramus bairdii), sage sparrow (Amphispiza belli), Brewer’s sparrow (Spizella 

breweri), and greater sage-grouse. Of those species, the mountain plover, longbilled curlew, loggerhead shrike, Brewer’s sparrow, and sage-grouse have been 

recorded within the general analysis area for the West Antelope II LBA tract; only 

the mountain plover, loggerhead shrike, and Brewer’s sparrow are known or 

suspected to nest in that vicinity. 

Raptor species that have been documented in the Powder River Basin and are on 

the Coal Mine list of Migratory Bird Species of Management Concern and on at least 

one other list of special status species include the bald eagle, ferruginous hawk, 

burrowing owl, and short-eared owl. Each of those species has been documented 

in the general analysis area, with all but the bald eagle known or suspected to 

nest there. Those species are discussed at length in Appendix H of this EIS. 

In sum, nineteen of the 40 species on the current list have historically been 

observed at least once within the general analysis area. Species that have been 

recorded nesting in the area include the mountain plover, ferruginous hawk, 

Swainson’s hawk, burrowing owl, and loggerhead shrike. Species that are 

presumed to nest in the area, based on their presence and behavior during the 

breeding season, include the McCown’s longspur (Calcarius mccownii), Brewer’s 

sparrow (Spizella breweri), lark bunting (Calamospiza melanocorys), chestnutcollared longspur (Calcarius ornatus), vesper sparrow (Pooecetes gramineus), and 

lark sparrow (Chondestes grammacus). Based on habitat requirements and 

infrequent sightings, long-billed curlews, short-eared owls, upland sandpipers 

(Bartramia longicauda), and grasshopper sparrows (Ammodramus savannarum) 

could potentially nest in the area, but have not been documented doing so. Most 

observations of those species were limited to spring, so they were presumed to be 

migrants. The remaining four species historically documented in the area have 

been restricted to specific seasons (bald eagle-winter), rarely observed (sagegrouse), or recorded only once each (red-headed woodpecker [Melanerpes 

erthrocephalus] and barn owl [Tyto alba]). The ferruginous hawk, burrowing owl, 

loggerhead shrike, both longspurs, Brewer’s sparrow, long-billed curlew, and 

greater sage-grouse are all discussed in detail in Appendix H of this EIS 

document. 

The mountain plover is included on the list of Migratory Bird Species of 

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3.0 Affected Environment and Environmental Consequences 

Management Concern in Wyoming. The mountain plover was designated as a 

proposed threatened species by the USFWS in October, 2001 (USFWS 2001). 

USFWS subsequently published a withdrawal of the proposed rule to list the 

mountain plover as threatened on September 9, 2003 (USFWS 2003). The USFWS 

continues to encourage provisions that would provide protection for this species, 

as it continues to be protected under the Migratory Bird Treaty Act, and as a 

sensitive species under BLM policy (Bureau Manual 6840.06 E. Sensitive Species). 

The history of mountain plovers at the Antelope Mine and surrounding area is well 

documented. Mountain plovers were first recorded in the general analysis area 

during baseline studies for the mine in 1978 and 1979. Annual monitoring for 

this species began in 1982 and continued through 2006, and coincidentally 

included much of the West Antelope II general analysis area. Because mountain 

plovers are known to nest in the general analysis area, the Antelope Mine 

specifically addressed this species in its Avian Monitoring and Mitigation Plan, 

which was approved by USFWS. The mine also incorporated species-specific 

protective measures into its state mining permit, providing additional guidance 

and mitigation options regarding mountain plovers. Further details regarding the 

occurrence of this species within and near the LBA tract are provided in Appendix 

H of this EIS document. 

The bald eagle, a USDA-FS and BLM Sensitive Species, is seasonally common and 

is most frequently observed during the winter months. Bald eagles are relatively 

common winter residents and migrants in northeastern Wyoming’s PRB, but only 

rarely nests in that region. No bald eagle nests or winter roosts have been 

documented within one mile of the West Antelope II general analysis area during 

either baseline or annual monitoring studies since they began in 1978 and 1982, 

respectively. 

The general analysis area includes only limited bald eagle nesting and roosting 

potential habitat in the form of scattered, decaying cottonwoods along Antelope 

Creek and isolated trees or small (five trees or less) stands of cottonwoods along 

Antelope or Spring Creeks, and their primary tributary draws. In general, the area 

does not contain consistent yearly, concentrated prey or carrion sources (e.g., 

fisheries, large groups of big game, waterfowl, sheep, etc.) that would be expected 

to attract bald eagles. This species is typically seen infrequently in the general 

vicinity of the West Antelope II LBA tract, and only during winter. Additional 

information about the observed occurrence of the bald eagle on the LBA tract can 

be found in the Sensitive Species Evaluation (Appendix H) of this EIS document. 

Swainson’s hawks have nested in the general vicinity of the Antelope Mine for the 

last few years. However, it wasn’t until 1998 that this species nested within the 

raptor survey area for the LBA tract. Since then, five separate territories have 

been identified, though only one or two have been active within a given year. 

Because of the limited number of trees in the area and the fact that Swainson’s 

hawks return to the region relatively late (mid-April) in the spring after most other 

raptor species have initiated nesting, few Swainson’s hawks nests have been 

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3.0 Affected Environment and Environmental Consequences 

established in the area. 

Burrowing owls were first recorded nesting in the Antelope Mine two-mile 

perimeter wildlife survey area in 1991, and owls have nested in that general 

vicinity during 14 of the last 16 years. All known burrowing owl nest sites 

throughout the entire West Antelope II general analysis area were in prairie dog 

burrows, and are therefore considered intact. Four additional artificial nest boxes 

have been constructed in the two-mile perimeter wildlife survey area for mitigation 

purposes since 1994, but no owls have ever been observed at or near them. Five 

pairs of burrowing owls have nested in the general analysis area, with all five pairs 

within the BLM study area itself (LBA tract as applied for plus added lands). Four 

of the five pairs have been active at least once in the last five years. 

Lark buntings and vesper sparrows have been recorded in the general analysis 

area during each of the last 13 years (1994-2006). Lark buntings generally return 

to the area from migration in early May, while vesper sparrows are typically 

present in April. Results from general surveys and breeding bird point counts 

over time indicate that the lark bunting is the most abundant breeding bird of 

management concern in the area. The vesper sparrow is also quite common in 

most years. Both species are typically observed in all habitats in the general 

analysis area throughout spring and summer, and are presumed to nest in the 

vicinity. 

Lark sparrows have also been recorded with some regularity in the general 

analysis area over the years. Lark sparrows inhabit a wide variety of habitats 

(Rising 1997), but were most often observed in relatively rugged terrain. It may be 

that some features associated with this species’ breeding habitat, such as open 

areas of low scrub or scattered trees (Harrison 1984, Peterson 1990), are more 

prevalent in the breaks, thus the higher number of sightings there. Grasshopper 

sparrows have occasionally been recorded in the general analysis area, but most 

sightings have been in the relatively mature stands of reclaimed grassland 

associated with the Antelope Mine, approximately one mile east of the LBA tract. 

In the Great Plains region, including the PRB, grasshopper sparrows are typically 

associated with taller grassland vegetation, such as that found in mature 

reclamation areas (Vickery 1996). 

Short-eared owls and upland sandpipers have occasionally been recorded in the 

general analysis area. Most observations of these species consisted of migrants 

and non-breeding adults. Although potential nesting habitat is present, neither 

species has been known to nest in the area. The barn owl and red-headed 

woodpecker each were recorded in the general analysis area once since wildlife 

surveys were initiated in 1978. A single adult barn owl was seen perched on the 

bank of a draw near Antelope Creek in NW1⁄4 Section 34, T.41N., R.71W., 

approximately 1.0 mile from the West Antelope II LBA tract, during lagomorph 

surveys in fall 2001. The first and only sighting of a red-headed woodpecker 

occurred in the cottonwood corridor along Antelope Creek in NE1⁄4 SW1⁄4 Section 

33, T.41N., R.71W. during breeding bird surveys for the West Antelope baseline 

Draft EIS, Antelope Coal Company Lease Application 3-113 
3.0 Affected Environment and Environmental Consequences 

studies in mid-June, 2003. That observation occurred approximately 1.25 miles 

from the nearest edge of the LBA tract. 

The remaining 21 migratory bird species of management concern have never been 

recorded in the general analysis area. Suitable habitat that would support these 

species like coniferous woodlands, large expanses of native prairie, lush riparian 

corridors, and large persistent bodies of water are scarce if not absent in the 

general analysis area. 

Under natural conditions, the West Antelope II LBA tract provides extremely 

limited and marginal habitat for waterfowl and shorebirds. The natural aquatic 

habitat, prior to CBNG development in the general analysis area, was mainly 

available during spring migration as ponds (primarily stock reservoirs) and 

ephemeral streams. Many of these water features generally were reduced to small, 

isolated pools or were completely dry during summer. However, the recent 

development of CBNG resources on and upstream of the general analysis area has 

enhanced the water resources available in the area in the last two years, resulting 

in somewhat improved habitat for waterfowl and shorebirds. Waterfowl and 

shorebird observations have primarily consisted of relatively low numbers of 

common species, often restricted to spring migration. Few broods have been 

recorded in the area during baseline or annual monitoring studies due to limited 

and unreliable water resources in the area. Avian species typically associated 

with aquatic habitats in the general analysis area include, but are not limited to, 

the mallard duck (Anas platyrhynchos), killdeer (Charadrius vociferus), and redwinged blackbird (Agelaius phoeniceus). 

3.10.6.2 Environmental Consequences 

3.10.6.2.1 Proposed Action and Alternatives 1 and 2 

Of the 19 Migratory Bird Species of Management Concern in Wyoming that have 

historically been observed in the general analysis area at least once, 11 species 

are classified as Level I (those identified as needing conservation action). Six of 

those 11 species are known or presumed to nest in and near the West Antelope II 

general analysis area: the mountain plover, McCown’s longspur, ferruginous 

hawk, burrowing owl, Brewer’s sparrow, and Swainson’s hawk. The first three 

species have regularly nested in the area over the last two decades of annual 

monitoring. In contrast, the latter three species nested less frequently, in part due 

to more limited nesting habitat (prairie dog colonies, small stands of sagebrush, 

isolated mature trees, respectively) present within the general analysis area. Bald 

eagles are seasonally present, and have been observed perched or foraging in the 

area in many years during winter. No bald eagle nests have ever been 

documented within several miles of the LBA general analysis. Other Level I 

species historically recorded in the area included the greater sage-grouse, longbilled curlew, short-eared owl, and upland sandpiper. None of those species have 

ever been documented to display breeding behaviors or nest in the general 

analysis area. 

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3.0 Affected Environment and Environmental Consequences 

When the West Antelope II tract is mined, current existing habitat within and near 

the tract for these 11 Level I species would be destroyed during mining. The 

habitat loss would be relatively short-term for some grassland species, but would 

last much longer for shrub-dependent species and other species requiring more 

specialized habitats. The current reclamation plan and practices for the Antelope 

Mine are designed to provide a mosaic of upland grass and sagebrush habitats 

that would potentially host most of these species. 

Natural regrowth of some habitats (e.g., birdsfoot sagebrush) and recolonization of 

others (prairie dog colonies) would contribute to those reclamation efforts. Trees 

within the general analysis area are limited to two isolated stretches along Spring 

Creek and Antelope Creek. No trees would be removed from the Antelope Creek 

corridor due to the required buffer zone along that channel. Approximately 15 

trees would be removed from the Spring Creek drainage. Some of the latter trees 

will be placed as snags in reclamation; all of those trees will be replaced with new 

trees along the drainage during reclamation. 

Prairie dog translocations are no longer authorized in the area, but natural 

recolonization would also enhance reclamation efforts for those species with more 

specialized habitat needs, such as mountain plovers and burrowing owls. Both 

species nest in prairie dog colonies within the general analysis area. Periodic 

breeding bird surveys at other surface mines with similar habitats in the region 

since the mid-1980s have demonstrated that species richness and abundance in 

reclaimed habitats are equal to or greater than in their native counterparts, 

though species composition may not be the same due to differences between preand post-mining vegetation. Antelope Mine survey methods and results are 

available in annual wildlife monitoring reports on file with the WDEQ/LQD in 

Sheridan, Wyoming. 

Specific impacts to and mitigation measures for avian species of management 

concern such as mountain plovers, bald eagles, sage-grouse, ferruginous hawks, 

and others are included in the preceding discussions or in Appendix H of this EIS 

document. In addition to those efforts, the availability of existing suitable habitat 

beyond the general analysis area may provide off-site options for displaced species 

and individuals, provided that those areas are not already at carrying capacity for 

the various species. 

Mining the LBA tract would have a negligible effect on migrating and breeding 

waterfowl and shorebirds. Sedimentation ponds created during mining would 

provide interim habitat for these fauna; such ponds are readily used by these 

species at other coal mines in the region. Antelope Creek would not be physically 

disturbed, but active mining on one or both sides could inhibit use by aquatic 

avian species. Any diverted creek channels would not provide the same habitat as 

the natural stream channel, though natural stream flow and the presence of 

CBNG discharge water in some areas would not be affected. 

The current reclamation plan for the Antelope Mine requires that any portion of a 

Draft EIS, Antelope Coal Company Lease Application 3-115 
3.0 Affected Environment and Environmental Consequences 

stream channel affected by currently permitted mining be reclaimed to restore its 

pre-mining functions and aquatic habitats (special provisions are in place for 

Horse Creek and Spring Creek AVF areas). If the West Antelope II tract is leased 

and mined, these reclamation efforts would be extended onto the portion of the 

stream affected by mining the new tract. Replacement of all impacted 

jurisdictional wetlands would be required in accordance with Section 404 of the 

CWA (Section 3.7). If the replaced wetlands on the tract do not duplicate the exact 

function and/or landscape features of the pre-mine wetlands, waterfowl and 

shorebirds could potentially be positively or adversely affected as a result. 

3.10.6.2.2 No Action Alternative 

Impacts to migratory bird species, waterfowl, and shorebirds under the No Action 

Alternative would be similar to the impacts described in Section 3.10.1.2.2, above. 

3.10.7 Amphibians, Reptiles, and Aquatic Species 

3.10.7.1 Affected Environment 

Wildlife surveys completed specifically for the applicant and other mines in the 

area, as well as biological research projects in the eastern PRB, have documented 

numerous other wildlife species that inhabit the region, including various 

amphibians, reptiles, and aquatic species. All of these species are locally common 

inhabitants of the area, depending on the quantity and quality of aquatic habitats 

present. 

Under natural conditions, aquatic habitat in the general analysis area is limited 

by the intermittent and ephemeral nature of surface waters. The lack of deepwater habitat and extensive and persistent water sources limits the presence and 

diversity of fish and other aquatic species. As discussed above, water discharged 

from CBNG wells has enhanced the water supply within some drainages in the 

general analysis area, including Spring Creek, which has increased potential 

habitat for some aquatic species. However, those enhanced areas are still 

relatively limited and/or isolated in nature, and no perennial drainages are 

present in the general analysis area. 

Baseline aquatic studies were completed for the Antelope Mine during the original 

baseline surveys and covered Antelope Creek at, and downstream from, the 

confluence with Spring Creek (Commonwealth Associates 1980). Several common 

fish species were found on the upper Antelope Creek sampling station (located at 

the Spring Creek confluence, east of the LBA tract) during those efforts: the plains 

minnow (Hybognathus placitus), green sunfish (Lepomis cyanellus), and plains 

killifish (Fundulus zebrinus). Those species are either tolerant of intermittency or 

are adapted to shallow, sandy bottom streams. Horse Creek, which crosses the 

northern extent of the general analysis area, was sampled in June 1998 during 

baseline studies; the green sunfish was the only fish species caught (PRES 1999). 

Spring Creek has not historically exhibited flow persistent enough to warrant 

3-116 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

aquatic sampling. Specific sampling was also not conducted during the West 

Antelope baseline, but no fish were observed in that tract during incidental 

observations during other wildlife surveys along Antelope and Spring Creeks. 

Few reptiles and amphibians have been recorded during wildlife surveys 

conducted in the general analysis area over the years. The relatively low quantity 

and quality of aquatic habitat in the area reduces its potential to attract these 

species, particularly amphibians and turtles. The boreal chorus frog (Pseudacris 

triseriata) has been the most common herptile observed in the area during 

baseline and annual monitoring surveys over the last two decades. These frogs 

have been heard in all three primary creeks in the area during spring. Other less 

common species recorded on or near the general analysis area over time included 

the Woodhouse’s toad (Bufo woodhousei), northern leopard frog (Rana pipiens), 

and tiger salamander (Ambystoma tigrinum). Prairie rattlesnakes (Crotalus viridis) 

have been observed in a prairie dog colony approximately one mile northeast of 

the southern portion of the tract. Other dry land species, such as the eastern 

shorthorned lizard (Phrynosoma douglassi) and bullsnake (Pituophis melanoleucas), 

are likely to occur in the general analysis area. Many of these fish, amphibian, 

and aquatic species are also USDA-FS Sensitive species (see Appendix H). 

3.10.7.2 Environmental Consequences 

3.10.7.2.1 Proposed Action and Alternatives 1 and 2 

Mining activities in the general analysis area would remove intermittent and 

ephemeral habitat for amphibians, reptiles, and other aquatic species in portions 

of Spring Creek and Horse Creek during active mining; Antelope Creek would not 

be physically disturbed. Under natural conditions, habitat for aquatic species is 

limited on the West Antelope II LBA tract as applied for, and few observations of 

those species have been recorded in the general analysis area over time. 

Additionally, primary channels and surface water flow affected during mining 

would be restored during reclamation. Aquatic species recorded in native and 

reclaimed channels at other mines in the PRB have been similar to those recorded 

at the Antelope Mine. 

Under jurisdiction of Antelope Mine’s current WDEQ/LQD mine permit, portions 

of Horse Creek and Spring Creek have been, or will be, disturbed or diverted in 

order to recover coal from existing coal leases (Section 3.5.2.1). Antelope Creek 

will not be physically disturbed under the current WDEQ/LQD mine permit and 

would not be disturbed by mining operations in the general analysis area. 

Reclamation of the stream channel and restoration of surface water flow quantity 

and quality after mining to approximate pre-mining conditions would restore 

aquatic resources of those creeks. 

3.10.7.2.2 No Action Alternative 

Impacts to reptiles, amphibians, and other aquatic species under the No Action 

Draft EIS, Antelope Coal Company Lease Application 3-117 
3.0 Affected Environment and Environmental Consequences 

Alternative would be similar to the impacts described in Section 3.10.1.2.2, above. 

3.10.8 Threatened, Endangered, Proposed, Candidate Species, BLM 

Sensitive Species, and USDA-FS Region 2 Sensitive Species and 

Management Indicator Species 

Refer to Appendices H and I. 

3.10.9 Regulatory Compliance, Mitigation and Monitoring 

Regulatory guidelines and requirements designed to prevent or reduce surface coal 

mining impacts to wildlife include: 

•	 fencing designed to permit pronghorn passage to the extent possible; 

•	 development of a Monitoring and Mitigation Plan for raptors and other 

migratory bird species of management concern that must be approved by 

the USFWS, including the following provisions: 

o	 creation of raptor nests and nesting habitat through enhancement 

efforts (nest platforms, tree plantings) to mitigate other nest sites 

impacted by mining operations; 

o	 relocation of active and inactive raptor nests that would be 

impacted by mining in accordance with the approved raptor 

monitoring and mitigation plan; 

o	 obtaining permits for removal and mitigation of golden eagle and 

other raptor species’ nests; 

o	 buffer zones for protection of raptor nests; 

o	 restriction of mine-related disturbances from encroaching within 

stipulated buffers of active raptor nests from egg-laying until 

fledging to prevent nest abandonment and injury to eggs or young; 

o	 reestablishment of the ground cover necessary to attract and 

sustain a suitable raptor prey base after mining; and 

o	 required use of raptor-safe construction for overhead power lines; 

•	 development of a Migratory Bird Species of Management Concern for Coal 

Mines in Wyoming Monitoring and Mitigation Plan, which must be 

approved by USFWS; 

•	 restoration of sage-grouse habitat after mining including reestablishment 

of sagebrush and other shrubs on reclaimed lands and grading of 

reclaimed lands to create swales and depressions for sagebrush obligates 

and their young; 

3-118 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

•	 restoration of short-grass habitat for species that nest and forage in 

those habitat types; 

•	 restoration of diverse landforms, direct topsoil replacement, and the 

construction of brush piles, snags, and rock piles to enhance habitat for 

wildlife; 

•	 restoration of habitat provided by jurisdictional wetlands; and 

•	 reclamation of the stream channels and restoration of surface water flow 

quantity and quality after mining to approximate pre-mining conditions. 

Antelope Mine’s current mine permit requires reconstruction of bed form features 

such as pools and runs in the stream channels of Spring Creek and Horse Creek. 

Those efforts should help restore the channels’ natural form and function, as well 

as provide habitat. Restoration will be achieved by salvaging sufficient material 

from channel terrace alluvium to reconstruct naturally-occurring features. 

Current reclamation, as well as future reclamation of those creeks by the Antelope 

Mine, would incorporate alluvium salvaged from the original channels. Similar 

measures would be incorporated in the amended mining and reclamation plans, if 

the LBA tract was leased and permitted for mining. 

Baseline wildlife surveys were conducted for the Antelope Mine before mining 

operations began. Annual wildlife monitoring has been ongoing since the early 

1980s. These surveys are required by state and federal regulations. The wildlife 

monitoring surveys cover the lands within the approved mine permit area and a 

surrounding perimeter that varies in size according to the species being 

considered. As a result, a majority of the West Antelope II general analysis area 

has been encompassed during the required monitoring efforts for the Antelope 

Mine. 

The required annual wildlife monitoring program currently consists of the 

following: 

•	 early spring surveys for new and/or occupied raptor territories and/or 

nests, upland game bird lek locations, T&E species, and migratory birds 

on and around the existing leases; 

•	 late spring surveys for migratory birds and raptor production at occupied 

nests, opportunistic observations of all wildlife species, and T&E species; 

•	 summer surveys for raptor production at occupied nests, migratory 

birds, and lagomorph density. 

Surface coal mines in the PRB were required to conduct seasonal surveys for big 

game species and brood surveys for upland game birds annually from 1994-1999. 

At the end of that period, the WGFD reviewed monitoring data and requirements 

for those species on mine properties. WGFD biologists concluded that the 

Draft EIS, Antelope Coal Company Lease Application 3-119 
 

3.0 Affected Environment and Environmental Consequences 

monitoring had demonstrated a lack of impacts to big game on existing mine sites, 

and that the brood surveys were not providing meaningful data. Additionally, no 

severe mine-related big game mortalities had occurred and no long-lasting impacts 

to big game had been documented on existing mine sites. The WGFD therefore 

recommended in late 1999 that big game monitoring and upland game bird brood 

surveys be discontinued on all existing mine sites. New mines will be required to 

conduct big game monitoring if located in crucial winter range or in significant 

migration corridors, neither of which are present within the West Antelope II 

general analysis area. 

Although big game surveys are no longer required, the Antelope Mine voluntarily 

elected to continue winter aerial and ground counts in alternate years to enhance 

previous annual data for those species. Numerous other mines in the PRB also 

conduct these voluntary surveys on the same schedule as Antelope Mine. 

The Antelope Mine operates under a current USFWS approved Monitoring and 

Mitigation Plan for raptors and other migratory bird species of management 

concern. The plan would be amended to include the West Antelope II LBA tract if 

it is leased and permitted for mining. The amended plan would be subject to 

review and approval by the USFWS before the amended mining plan is approved. 

If the current Coal Mine List of Migratory Bird Species of Management Concern in 

Wyoming is updated, or if additional species are documented nesting or using the 

area regularly, the current Monitoring and Mitigation Plan would be amended to 

incorporate and protect those birds and their habitats. 

3.10.10 Residual Impacts 

Although the West Antelope II LBA tract would be reclaimed in accordance with 

the requirements of SMCRA and Wyoming statutes, there would still be some 

residual wildlife impacts. The topographic moderation would result in a 

permanent loss of habitat diversity and a potential decrease in slope-dependent 

shrub communities. This would reduce the carrying capacity of the land for 

shrub-dependent species. Reclamation standards for bond release may also limit 

replacement of habitat for some species such as the mountain plover, which 

occupy somewhat specialized, low-growth form habitats. Those species may 

repopulate reclaimed areas, but populations may not attain pre-mining levels 

without special variances to accommodate those specific needs. For example, 

every effort would be made to preserve source populations of prairie dogs in the 

vicinity of development, as these animals can be valuable in restoring similar 

structural characteristics of pre-mine grassland species through regular clipping 

and harvesting of vegetation. 

Limited riparian and sagebrush-grassland habitat is present in the general 

analysis area. Areas that currently support sagebrush would be altered to a 

grassland community, perhaps for decades, during the interim between sage 

plantings and maturity in reclamation. Such habitat transformations would likely 

3-120 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

result in a change in wildlife species composition until pre-mining habitats had 

been fully reestablished. Because state and federal regulations require 

reclamation of specific habitats, minimal residual impacts to T&E, Candidate, or 

Proposed plant and animal species are expected to occur. 

3.11 Land Use and Recreation 

3.11.1 Affected Environment 

Within the West Antelope II LBA tract as applied for, surface ownership consists 

entirely of private lands. Federal land administered by the USDA-FS is included 

within the area added under Alternatives 1 and 2. The present land use of the 

general analysis area is primarily livestock grazing and wildlife habitat. Gas 

production and recreation are secondary land uses. Surface ownership for the 

West Antelope II LBA tract is shown in Table 3-12 and Figure 3-20. 

Table 3-12. Distribution of Surface Ownership Within the West Antelope II LBA 

Tract as Applied for Under the Proposed Action and Additional 

Lands Added Under Alternatives 1 and 2. 

Federal Ownership Private Ownership 

LBA Tract Configuration (Acres) (Percent) 1 (Acres) (Percent) 1 

Tract As Applied For 0 0 4108.6 65.1 

Additional Lands Added Under 

Alternatives 1 and 2 

237.2 3.8 1963.4 31.1 

Total 237.2 3.8 6072.0 96.2 

1 Based on total acres (Proposed Action plus Alternatives 1 and 2). 

As indicated in Table 3-12, approximately 240 acres of federal surface 

administered by the USDA-FS is included in the West Antelope LBA tract under 

Alternatives 1 and 2. This federal land is within Grazing Allotment #213, 

currently held by Thunder Basin Grazing Association. 

Areas of disturbance within and near the general analysis area include roads, oil 

and gas wells and associated production facilities, surface mine-related facilities, 

and activities associated with ranching. State Highway 59 is located west of the 

West Antelope II LBA tract as applied for. Highway 59 crosses the southwestern 

corner of the portion of the BLM study area that includes the south block of the 

tract under Alternatives 1 and 2. County roads that traverse and provide public 

and private access within and near the general analysis area include County Road 

37 (Antelope Coal Mine Road) in Converse County and County Road 4 (Antelope 

Road) in Campbell County. County Road 37 crosses the southeastern corner of 

the portion of the BLM Study area that includes the south block of the tract under 

Alternatives 1 and 2. The BNSF & UP railroad ROW crosses the northern block of 

the West Antelope II LBA tract (Figure 3-20). As discussed in Section 1.5 and 

Appendix B, the lands within the railroad ROW are considered to be unsuitable for 

mining under coal mining unsuitability Criterion 2 (43 CFR 3461.5 (c)(2)). The 

Draft EIS, Antelope Coal Company Lease Application 3-121 
 

 

 

3.0 Affected Environment and Environmental Consequences 

Campbell County 

Converse County 

Antelope Road 

B.N.S.F. & U.P. RR

T. 

40 

N. 

R. 70 W. 

T. 

41 

N. 

T. 

41 

N. 

R. 71 W. 

T. 

40 

N. 

R. 71 W. R. 70 W. 

7 8 9 7

4 1 5 6 3 2 6

8 9 7

8 

22 

11 

27 

15 

24 20 

26 

19 

17 

30 

21 23 

15 

14 

29 28 

14 13 

16 

12 

13 

16 

25 

17 

18 

34 

10 

18 

32 33 35 36 31

7 

18 

5 

8 

18 

19 

30 

11 

31 

29 

32 

10 12 

20 

17 

17 

19 20 21 22 23 24 19 20 

!(59 

SURFACE OWNERSHIP 

ACC 

Dilts Ranch Co. 

Dilts, Barbara H. Living Trust et. al. 

Dilts, Jerry J. & Barbara Family Ltd. Partnership and Bridle Bit Ranch Company 

Floyd C. Reno and Sons Inc. 

Haefele, Rodney J. et. al. 

Litton, Patricia L. Isenberger 

Powder River Coal Company 

USFS 

£

0 7,000 14,000 

GRAPHIC SCALE (FEET) 

Figure 3-20. Surface Ownership Within the West Antelope II LBA Tract. 

County Rd. 37 

Haefele, 

Rodney J. 

et. al. 

LEGEND 

West Antelope II LBA Tract As Applied For 

Area Added under Alternative 1 

Draft EIS, West Antelope II Coal Lease Application 3-122
 
3.0 Affected Environment and Environmental Consequences 

lands within the public road ROWs are considered to be unsuitable for mining 

under coal mining unsuitability Criterion 3 (43 CFR 3461.5 (c)(3)). 

The oil and gas estate within the West Antelope II LBA tract is federally and 

privately owned (Figure 3-21); the majority (approximately 95 percent) is federally 

owned. Not all of the federally owned oil and gas estate is leased. The current 

(April 2007) federal oil and gas lessees for the LBA tract (Proposed Action and 

Alternatives 1 and 2) are listed in Table 3-13. 

According to WOGCC records (WOGCC 2007c), two conventional oil wells were 

permitted and drilled on lands included in the BLM study area for the West 

Antelope II LBA tract (the tract as applied for and additional area evaluated under 

Alternatives 1 and 2, Figure 3-21). Both are permanently abandoned. 

The Supreme Court has ruled that the CBNG belongs to the owner of the oil and 

gas estate (98-830). Therefore, the oil and gas lessees have the right to develop 

CBNG as well as conventional oil and gas on the LBA tract.There are 40 permitted 

CBNG wells on lands included in the BLM study area for the West Antelope II LBA 

tract (the tract as applied for and the additional area evaluated under Alternatives 

1 and 2, Figure 3-21) (WOGCC 2007c). The status of these 40 well permits as of 

April 2007 was as follows: 20 producing, 3 flowing, 7 shut-in, 1 permanently 

abandoned, 1 denied or cancelled, 1 notice of intent to abandon, and 7 expired 

permits. CBNG wells capable of production on or in sections adjacent to the West 

Antelope II LBA tract are listed in Appendix E. 

Additional information on the conventional oil and gas and CBNG development in 

the West Antelope II LBA tract and surrounding area is included in Section 3.3.2. 

Certain ancillary facilities are needed to support oil and gas production. These 

support facilities may include well access roads; well pads; production equipment 

at the wellhead (which may be located on the surface and/or underground); well 

production casing (which extends from the surface to the zone of production); 

underground pipelines (which gather the oil, gas, and/or water produced by the 

individual wells and carry it to a larger transmission pipeline or collection facility); 

facilities for treating, discharging, disposing of, containing, or injecting produced 

water; central metering facilities; electrical power utilities; gas compressor 

stations; and high-pressure transmission pipelines for delivering the gas to 

market. Currently, some of these oil and gas production facilities, particularly oil 

and gas pipelines, exist on the LBA tract, as discussed in Section 3.15 of this EIS. 

Coal mining is a dominant land use to the north and east of the LBA tract. The 

Jacobs Ranch, Black Thunder, School Creek, North Antelope/Rochelle, and 

Antelope Mines form a group of contiguous surface coal mines located in Campbell 

and Converse Counties (Figure 1-1). Coal production from these mines increased 

by 65 percent between 1998 and 2006 (from approximately 155 million tons in 

1998 to approximately 255 million tons in 2006). Of the 17 leases issued in the 

PRB since decertification of the federal coal region, 14 have been issued within 

Draft EIS, Antelope Coal Company Lease Application 3-123 
 

 

 

 

3.0 Affected Environment and Environmental Consequences 

H

H

V

V V

V

VV

V V

V

V

V

V V

V V

V V

V

V

V

V V V

< <

<

<

<

< <

A

A

?

?

?

?

?

?

?

S

Campbell County 

Converse County 

B.N.S.F. & U.P. RR 

A

A

A

Private 

A

A

A

A

Private A A

A

A A

A

A

Private / State A

A

A

A

A

A

A

A

APrivate 

Private 

Not Leased A

R. 72 W. R. 71 W. 

A

Ante lope Rd. 

A

A

State Coal Lease A

County Rd. 37 

A

State Coal Lease A

T. 

40 

N. 

R. 70 W. 

T. 

41 

N. 

T. 

41 

N. 

R. 71 W. 

T. 

40 

N. 

R. 71 W. 

R. 71 W. 

R. 72 W. 

R. 70 W. 

WYW 136674 

WYW 142771 

WYW 136674 

WYW 136942 

WYW 130033 

WYW 133561 

WYW 136942 

WYW 138119 

WYW 136939 

WYW 127785 

WYW 043650 

WYW 138120 WYW 140769 

WYW 143685 

WYW 143507 

WYW 128995 

WYW 130033 

WYW 055069 

WYW 141206 

WYW 130033 

WYW 143684 

WYW 142771 

WYW 136674 

9 

7 8

8 9 

7 

7 7

8 

8 

4 1 5 1 6 3 2 6 5 

11 

22 

11 

27 

15 

24 

10 

20 

26 

18 

19 

17 

30 

21 

23 

15 

14 

29 

28 

14 13 

16 

12 

30 

12 

13 

16 

25 

19 

17 18 

34 

10 

18 

31 32 33 35 31

18 

36 

22 23 24 19

29 

32 

12 

20 

20 21 

13 

19 

17 

17 

24 

13 

12 

20 

25 

24 

36 

1 6 5 4 3 2 1 6 5

!(59 

LEGEND 

Existing Antelope Mine Federal Coal Leases 

West Antelope II LBA Tract As Applied For 

Area Added Under Alternative 1 

North Tract (Alternative 2) 

South Tract (Alternative 2) 

Oil and Gas Lease Boundary 

Federal Oil and Gas - Not Leased 

OIL AND GAS WELL TYPES 

V CBNG - Producing Gas Well 

< CBNG - Shut-In 

? CBNG - Permit Expired 

A CBNG - Abandoned or Intent to Abandon 

S CBNG - Permit Denied 

H Oil Well - Plugged and Abandoned 

£ 0 7,000 14,000 

GRAPHIC SCALE (FEET) 

Figure 3-21. Oil and Gas Ownership on the West Antelope II LBA Tract. 

Note: Well locations and status were derived 

from a download from the WOGCC website on 

4/11/07 

WYW 136674 Federal Oil and Gas Lease No. 

WYW136674 

142771 

WYW 128995 

3-124
 Draft EIS, West Antelope II Coal Lease Application 
 

3.0 Affected Environment and Environmental Consequences 

Table 3-13. Current Federal Oil and Gas Leases on the West Antelope II LBA 

Tract. 

For the following locations, both the oil and gas rights (including CBNG) and coal rights are owned 

by the federal government. 

Lease Number Location Lessees of Record 

T.40N., R.71W. 

WYW 136674 Section 5; Lots 8, 9 Antelope Coal Co. 

Section 8; Lots 9-11, 13-16 

Section 9; Lots 2-8 

Section 17; Lots 1-16 

WYW 136939 Section 15; Lots 2, 7,10, 15, 16 Liberty Petroleum Corp. 

WYW 143684 Section 14; Lot 13 Bill Barrett Prod. Co. 

WYW 143685 Section 15; Lots 11-14 Petro Atlas Corp. 

T.41N., R.71W. 

WYW 043650 Section 10; Lots 11-14 ABO Petro Corp. 

Cienaga LLC 

Hay Canyon LLC 

Marico Expl. Inc. 

Myco Industries Inc. 

Sharbro Oil LTD Co. 

Tulipan LLC 

Willian G. Helis Est. 

Yates Drilling Do. 

Yates Petroleum Corp. 

WYW 055069 Section 9; Lots 9, 16 Key Production Co. Inc. 

Lance O&G Co. Inc. 

Nance Petroleum Corp. 

Pathfinder Energy 

Wellstar Corp. 

Williams Prod. RMT Co. 

WYW 127785 Section 32; Lots 4, 5, 12, 13 Fred L. Engle 

WYW 128995 Section 10; Lots 10, 15 ABO Petro Corp. 

Section 11; Lots 13, 14 Lance O&G Co. Inc. 

Myco Industries Inc. 

Williams Prod. RMT Co. 

Yates Drilling Do. 

Yates Petroleum Corp. 

Draft EIS, Antelope Coal Company Lease Application 3-125 
3.0 Affected Environment and Environmental Consequences 

Table 3-13. Current Federal Oil and Gas Leases on the West Antelope II LBA 

Tract - Continued. 

Lease Number Location Lessees of Record 

WYW 130033 Section 9; Lots 10-15 

Section 10; Lots 9, 16 

Section 15; Lot 13 

ABO Petro Corp. 

Lance O&G Co. Inc. 

Myco Industries Inc. 

Sharbro Oil LTD Co. 

Williams Prod. RMT Co. 

Yates Drilling Do. 

Yates Petroleum Corp. 

WYW 133561 Section 15; Lots 1-4 Barbara Starr Shillington 

WYW 136942 Section 21; Lots 6, 7, 9, 10, 15, 16 

Section 27; Lots 6-11 

Gregor Klurfeld 

WYW 138119 Section 22; Lots 7, 8, 14-16 Bowers O&G Inc. 

Spring Creek Ranch 

WYW 138120 Section 28; Lots 3-6 Bowers O&G Inc. 

Spring Creek Ranch 

WYW 140769 Section 28; Lots 1, 2, 7, 8 Lance O&G Co. Inc. 

Williams Prod. RMT Co. 

WYW 141206 Section 22, Lot 2 Williams Prod. RMT. Co. 

WYW 142771 

WYW 143507 

Section 20; Lots 9-16 

Section 21; Lots 3-5, 11-14 

Section 29; Lots 1-4, 6-8, 13 

Section 21; Lots 1, 2, 8 

Lance O&G Co. Inc. 

Williams Prod. RMT Co. 

ABO Petro Corp. 

Myco Industries Inc. 

Yates Drilling Do. 

Yates Petroleum Corp. 

this group of five mines (Table 1-1). The West Antelope II LBA tract being 

evaluated in this EIS is one of five currently pending lease applications in this 

group of mines (Table 1-2). 

Campbell County does not have a county-wide land use plan, but is currently 

developing a comprehensive land use plan jointly with the City of Gillette (City of 

Gillette 1978 and Campbell County 2005). The City of Gillette/Campbell County 

Comprehensive Planning Program (City of Gillette 1978) provides general land use 

goals and policies for state and federal coal leases in the county. In August 1978, 

the Converse County Planning Commission completed a land use plan covering 

agriculture, recreation and minerals industries management (Converse County 

3-126 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

1978). The Antelope Coal Field lies approximately 55 miles north of Douglas in an 

area zoned primarily for agricultural use, and secondarily for mineral extraction. 

Big game hunting is the principal recreational land use within the general analysis 

area, with pronghorn, mule deer, and white-tailed deer present within the area 

(Section 3.10.2). On private lands, hunting is allowed only with landowner 

permission. Land ownership within the PRB is largely private (approximately 80 

percent), with some private landowners permitting sportsmen to cross and/or 

hunt on their land. There has been a trend over the past two to three decades 

towards a substantial reduction in private lands that are open and reasonably 

available for hunting. Access fees continue to rise and many resident hunters feel 

these access fees are unreasonable. This trend has created problems for the 

WGFD in their attempt to distribute and control harvest at optimal levels, as well 

as for sportsmen who desire access to these animals (WGFD 2004). 

In general, publicly owned lands (i.e., USDA-FS or BLM-administered federal lands 

and state school sections) are open to hunting if legal access is available. Due to 

safety concerns, however, public surface lands contained within an active mining 

area are generally closed to the public, further limiting recreational use. There are 

no BLM-administered public surface lands included in the West Antelope II LBA 

tract. About 240 acres of USDA-FS administered lands (TBNG) are included in the 

area added to the south block of the tract under Alternatives 1 and 2 (Figure 3­

20). Approximately 100 acres of the TBNG land within the area added under 

Alternatives 1 and 2 are within the current Antelope Mine permit boundary and 

thus may be inaccessible to the public. 

Specific information pertaining to WGFD big game herd management objectives 

within and near the general analysis area is contained in the 2006 Big Game Job 

Completion Reports for the Casper and Sheridan Regions (WGFD 2006). The 

WGFD classifies most of the general analysis area as yearlong habitat for 

pronghorn. A small portion of the south tract is classified as severe winter range. 

No crucial or critical pronghorn habitat is recognized by the WGFD in this area. 

The general analysis area is within pronghorn Hunt Area 27, which is contained in 

the Cheyenne River Herd Unit. In post-season 2006, the population of the 

Cheyenne River Herd Unit was estimated to be approximately 39,621 animals; the 

WGFD population objective is 38,000. 

Between 1995 and 2000, the Cheyenne River Herd Unit population was fairly 

stable at about 15 percent below the objective population. Pronghorn populations 

in this herd unit dropped in 2001, primarily because of lower productivity and 

survival caused by climatic factors. Population recovery began in the following 

years, with an increase of approximately 2,000 additional pronghorn each year 

between 2002 and 2005. The estimated population decreased slightly in 2006. 

Hunt Area 27 contains mostly privately owned surface lands with poor hunter 

access to limited publicly owned lands; therefore, the number of pronghorn is 

expected to steadily increase. If the population exceeds objective levels, more 

licenses will be needed and these may be difficult to sell in this mostly private land 

Draft EIS, Antelope Coal Company Lease Application 3-127 
3.0 Affected Environment and Environmental Consequences 

area. Nearly all landowners charge access fees for hunting and private land 

access is based on the desires and perceptions of the landowners. Increased 

harvest may be difficult to achieve because of the increased CBNG development, 

which is limiting rifle hunting on associated lands. 

The WGFD has classified the general analysis area as winter-yearlong, yearlong, 

and “OUT” mule deer use range (the OUT areas do not contain enough animals to 

be important habitat, or the habitat is of limited importance to a species). Crucial 

or critical mule deer habitat does not occur on or within several miles of the 

general analysis area. The general analysis area is located within mule deer Hunt 

Area 10, part of the Thunder Basin Mule Deer Herd Unit. The Thunder Basin 

Herd Unit encompasses 3,642 square miles; of this, 71 percent is privately owned. 

Hunt Area 10, however, contains substantial blocks of public land. According to 

WGFD, there has been an increase in the number of landowners leasing to 

outfitters, which is increasing hunting pressure on public lands. In 2006, 

measures taken to address landowner and sportsmen concerns about low deer 

numbers in Hunt Area 10 included switching to general license, antlered only 

hunting and reducing the length of the hunting season. The 2006 post-season 

objective for this mule deer herd was 20,000. The 2006 post-season population 

was estimated at 22,036, an increase of 4,230 animals since 2005. Because of 

drought-related forage conditions, WGFD believes the herd should be reduced to 

below the objective population; however, limited sales and use of certain types of 

licenses and limited hunting on private land may hamper the ability to reduce the 

population through hunting. 

White-tailed deer are now managed separately by WGFD. The herd occupying 

Hunt Area 10 is part of the Central White-tailed Deer Herd Unit. White-tailed deer 

are seldom observed within the general analysis area due to their preference for 

riparian woodlands and irrigated agricultural lands. WGFD classifies the entire 

general analysis area, with the exception of a narrow corridor along Antelope 

Creek, as OUT white-tailed deer use range. The narrow corridor along Antelope 

Creek is classified as yearlong range. There is no population model for this herd. 

The Rochelle Hills Elk Herd resides in the Rochelle Hills located approximately 13 

miles east of the general analysis area. The general analysis area is within Elk 

Hunt Area 113 of the Rochelle Hills Herd Unit. Elk Hunt Area 113 contains 

crucial winter, parturition, winter-yearlong, yearlong, OUT, and 

undecided/unknown use ranges. In post-season 2006, the population of the 

Rochelle Hills Elk Herd was estimated to be approximately 650 animals; the 

WGFD population objective is 400. The herd favors the ponderosa pine/juniper 

woodlands, savanna, and steeper terrain habitat offered by the Rochelle Hills. 

However, recent data indicate the population is larger than previously expected, 

with this herd also occupying the public lands found in TBNG located within Hunt 

Area 113. As more lands are reclaimed from coal mining adjacent to the Rochelle 

Hills, elk are shifting their winter use to those sites. Such lands typically offer 

excellent winter grass supplies, especially during more severe winters when other 

sites are less accessible. 

3-128 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

Under natural conditions, aquatic habitat is very limited by the ephemeral nature 

of surface waters in the general analysis area; therefore, public fishing 

opportunities are very limited. The lack of deep-water habitat and extensive and 

persistent water sources limits the presence and diversity of fish and other aquatic 

species. However, water discharged from CBNG wells has enhanced the water 

supply within some drainages in the general analysis area, including Spring 

Creek, which has increased potential habitat for some aquatic species. Those 

enhanced areas are still relatively limited and/or isolated in nature, and no 

perennial drainages are present in the general analysis area. 

3.11.2 Environmental Consequences 

3.11.2.1 Proposed Action and Alternatives 1 and 2 

The major adverse environmental consequences of leasing and mining the West 

Antelope II LBA tract with respect to land use would be the loss of livestock 

grazing and wildlife habitat (particularly big game) and curtailment of oil and gas 

development during coal mining and surface reclamation. This would include 

removal of all existing oil and gas surface and downhole production and 

transportation equipment and facilities. Wildlife and livestock use would be 

displaced while the tract is being mined and reclaimed. Under Alternatives 1 and 

2, access to approximately 240 acres of federal grazing leases would be suspended 

during mining operations. This federal land is within Grazing Allotment #213, 

currently held by Thunder Basin Grazing Association. Access for recreational and 

other (i.e., ranching, oil and gas development) activities would be restricted during 

mining operations. Estimated disturbance areas for the West Antelope II LBA 

tract and the tract configuration for Alternatives 1 and 2 are presented in Table 3­

1. 

Sections 3.3.2 and 3.11.1 and Appendix E of this document address producing, 

abandoned, and shut in oil and gas (conventional and CBNG) wells that presently 

exist on the LBA tract under the Proposed Action and Alternatives 1 and 2. Well 

location information, federal oil and gas ownership, and federal oil and gas lessee 

information are presented in Figure 3-21 and Table 3-13. BLM manages federal 

lands on a multiple use basis, in accordance with the regulations. In response to 

conflicts between oil and gas and coal lease holders, BLM policy advocates 

optimizing the recovery of both coal and CBNG resources to ensure that the public 

receives a reasonable return for these publicly owned resources. Optimal recovery 

of both coal and oil and gas resources requires negotiation and cooperation 

between the oil and gas lessees and the coal lessees. In the past, negotiations 

between some of the applicant mines and some of the existing oil and gas lessees 

have resulted in agreements that allowed development of both resources on 

portions of the LBA tract. Producing CBNG wells are present on the West 

Antelope II LBA tract. In the PRB, royalties have been and would be lost to both 

the state and federal governments if the federal CBNG is not recovered prior to 

mining or if federal coal is not recovered due to conflicts. State and federal 

Draft EIS, Antelope Coal Company Lease Application 3-129 
 

3.0 Affected Environment and Environmental Consequences 

governments can also lose bonus money when the costs of the agreements 

between the lessees are factored into the fair market value determinations. 

As discussed above, BLM is evaluating including up to approximately 240 acres of 

USDA-FS-administered federal surface under Alternatives 1 or 2. Access to those 

lands would be limited if they are leased and mined. Approximately 100 of those 

acres are within the current Antelope Mine permit area and access to the public is 

currently limited on those lands as a result. The loss of access to federal lands is 

long term (during mining and reclamation), but is not permanent. Public access 

to federal lands would be restored after mining and reclamation are complete. 

Hunting on the West Antelope II LBA tract, including the federal surface discussed 

above, would be eliminated during mining and reclamation. Pronghorn, white-tail 

deer, and mule deer occur on and adjacent to the LBA tract, as do mourning dove, 

waterfowl, rabbit, and coyote. The federal lands actually represent a relatively 

small portion of the currently accessible public surface lands for recreational 

opportunity within the respective animal hunt areas. 

Following reclamation, the land would be suitable for grazing and wildlife uses, 

which are the historic land uses. The reclamation standards required by SMCRA 

and Wyoming State Law meet the standards and guidelines for healthy rangelands 

for public lands administered by the BLM in Wyoming. Following reclamation 

bond release, management of the privately owned surface would revert to the 

private surface owner and management of the federally owned surface would 

revert to the federal surface managing agency (USDA-FS). 

3.11.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and coal removal and the associated disturbance and impacts would 

not occur on from 4,314 up to 6,625 acres that would be disturbed under the 

Proposed Action or Alternatives 1 and 2, respectively. Currently approved mining 

operations would continue on the existing Antelope Mine leases. Portions of the 

West Antelope II LBA tract adjacent to the Antelope Mine would be disturbed to 

recover the coal in the existing leases. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3.11.3 Regulatory Compliance, Mitigation and Monitoring 

Mined areas would be reclaimed as specified in the approved mine plan to support 

the anticipated post-mining land uses of wildlife habitat and rangeland. The 

reclamation procedures would include stockpiling and replacing topsoil, using 

reclamation seed mixtures, which would be approved by WDEQ, and replacing 

stock reservoirs. 

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3.0 Affected Environment and Environmental Consequences 

Steps to control invasion by weedy (invasive nonnative) plant species using 

chemical and mechanical methods would be included in the amended mine plan. 

Revegetation growth and diversity would be monitored until the final reclamation 

bond is released (a minimum of 10 years following seeding with the final seed 

mixture). Erosion would be monitored to determine if there is a need for corrective 

action during establishment of vegetation. Controlled grazing would be used 

during revegetation to determine the suitability of the reclaimed land for 

anticipated post-mining land uses. 

See Section 3.3.2.3 for discussion of regulatory requirements, mitigation and 

monitoring related to oil and gas development. 

3.11.4 Residual Impacts 

No residual impacts to land use and recreation are expected. 

3.12 Cultural Resources 

3.12.1 Affected Environment 

Cultural resources, protected under the National Historic Preservation Act of 

1966, are nonrenewable remains of past human activity. The PRB, including the 

general analysis area, appears to have been inhabited by aboriginal hunting and 

gathering people for more than 13,000 years. Throughout the prehistoric past, 

the area was used by highly mobile hunters and gatherers who exploited a wide 

variety of resources. Several thousand cultural sites have been recorded within 

the PRB. 

Several culture historic chronologies are pertinent to evaluating prehistoric 

occupations in Wyoming. Frison's (1978, 1991) chronology for the Northwestern 

Plains divides occupations from early to late into the Paleoindian, Early Plains 

Archaic, Middle Plains Archaic, Late Plains Archaic, Late Prehistoric, and 

Protohistoric periods. Frison’s chronology is used here. The Plains designation 

within the Early, Middle, and Late Archaic periods has been omitted. 

• Paleoindian period (13,000 to 7,000 years B.P.) 

• Early Archaic period (7,000 to 5,000-4,500 years B.P.) 

• Middle Archaic period (5,000-4,500 to 3,000 years B.P.) 

• Late Archaic period (3,000 to 1,850 years B.P.) 

• Late Prehistoric period (1,850 to 400 years B.P.) 

• Protohistoric period (400 to 250 years B.P.) 

• Historic period (250 to 120 years B.P.) 

The Paleoindian period dates from about 13,000 to 7,000 years ago and includes 

various complexes (Frison 1978). Each of these complexes is correlated with a 

distinctive projectile point style derived from a general large lanceolate and/or 

stemmed point morphology. The Paleoindian period is traditionally thought to be 

Draft EIS, Antelope Coal Company Lease Application 3-131 
3.0 Affected Environment and Environmental Consequences 

synonymous with “big game hunters” who exploited megafauna such as bison and 

mammoth (plains Paleoindian groups), although evidence of the use of vegetal 

resources is noted at a few Paleoindian sites (foothill-mountain groups). 

The Early Archaic period dates from about 7,000 to 5,000-4,500 years ago. 

Projectile point styles reflect the change from large lanceolate types that 

characterize the earlier Paleoindian complexes to large side- or corner-notched 

types. Subsistence patterns reflect exploitation of a broad spectrum of resources, 

with a much-diminished utilization of large mammals. 

The onset of the Middle Archaic period (4,500 to 3,000 years B.P.) has been 

defined on the basis of the appearance of the McKean Complex as the 

predominant complex on the Northwestern Plains around 4,900 years B.P. 

(Frison 1978, 1991, 2001). McKean Complex projectile points are stemmed 

variants of the lanceolate point. These projectile point types continued until 3,100 

years B.P. when they were replaced by a variety of large corner-notched points 

(i.e., Pelican Lake points) (Martin 1999). Sites dating to this period exhibit a new 

emphasis on plant procurement and processing. 

The Late Archaic period (3,000 to 1,850 years B.P.) is generally defined by the 

appearance of corner-notched dart points. These projectile points dominate most 

assemblages until the introduction of the bow and arrow around 1,500 years B.P. 

(Frison 1991). The period witnessed a continual expansion of occupations into the 

interior grasslands and basins, as well as the foothills and mountains. 

The Late Prehistoric period (1,850 to 400 years B.P.) is marked by a transition in 

projectile point technology around 1,500 years B.P. The large corner-notched dart 

points characteristic of the Late Archaic period are replaced by smaller cornerand side-notched points for use with the bow and arrow. Ceramic technology also 

appears with the Late Prehistoric Period. Around approximately 1,000 years B.P., 

the entire Northwestern Plains appears to have suffered an abrupt collapse or shift 

in population (Frison 1991). This population shift appears to reflect a narrower 

subsistence base focused mainly on communal procurement of pronghorn and 

bison. 

The Protohistoric period (400 to 250 years B.P.) witnesses the beginning of 

European influence on prehistoric cultures of the Northwestern Plains. Additions 

to the material culture include most notably the horse and European trade goods, 

including glass beads, metal, and firearms. Projectile points of this period include 

side-notched, tri-notched, and unnotched points, with the addition of metal 

points. The occupants appear to have practiced a highly mobile and unstable 

residential mobility strategy. 

The historic period (250 to 120 years B.P.) is summarized from Schneider et al. 

(2000). The use of the Oregon Trail by emigrants migrating to the fertile lands of 

Oregon, California, and the Salt Lake Valley brought numerous pioneers through 

the state of Wyoming, but few stayed. It was not until the fertile land in the West 

3-132 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

became highly populated, along with the development of the cattle industry in the 

late 1860s, that the region currently comprising the state of Wyoming became 

attractive for settlement. The region offered cattlemen vast grazing land for the 

fattening of livestock, which could then be shipped across the country via the 

recently completed (1867-1868) transcontinental railroad in southern Wyoming. 

The settling of the region surrounding Gillette, Wyoming began in the late 1800s, 

after a government treaty in 1876 placed the Sioux Indians on reservations 

outside the territory. Cattlemen were the first settlers to establish themselves in 

the area, with dryland farmers entering the area after 1900. The town of Gillette 

was established by the railroad in 1891 in an effort to promote the settling of 

undeveloped areas along the rail lines. The presence of the railroad allowed for 

the greater development of the cattle industry because it facilitated shipping cattle 

from the area. Several early ranches established in the region include the 4J 

Ranch (1875), Half Circle L Ranch (1880s), I Bar U Ranch (1888), and the T7 

Ranch (1881). 

The Dry Land Farming movement of the late 19th and early 20th centuries had a 

profound effect on the settlement of the PRB during the years around World War I. 

Although the principles of dry land farming were sound, success still required a 

certain amount of precipitation each year. Wyoming encouraged dry land 

settlement of its semi-arid lands through a Board of Immigration created in 1911. 

Newspapers extolled the virtues of dry land farming, and railroads conducted wellorganized advertising campaigns on a nationwide basis to settle the regions through 

which they passed. 

The most intensive period of homesteading activity in the Eastern PRB occurred in 

the late 1910s and early 1920s. Promotional efforts by the state and the railroads, 

the prosperous war years for agriculture in 1917 and 1918, and the Stock Raising 

Act of 1916 with its increased acreage (but lack of mineral rights) all contributed to 

this boom period. A large amount of land filings consisted of existing farms and 

ranches expanding their holdings in an optimistic economic climate. However, an 

equally large number of homesteaders had been misled by promotional advertising 

and were not adequately prepared for the experiences that awaited them in the PRB. 

It soon became apparent to the would-be dry land farmer that he could not make a 

living by raising only crops. Some were initially successful in growing wheat, oats, 

barley and other small grains, along with hay, alfalfa, sweet clover and other 

grasses for the increased number of cattle. 

A drought in 1919 was followed by a severe winter. The spring of 1920 saw market 

prices fall. Those homesteaders who were not ruined by the turn in events often 

became small livestock ranchers and limited their farming to the growing of forage 

crops and family garden plots. Some were able to obtain cheap land as it was 

foreclosed or sold for taxes. During the 1920s the size of homesteads in Wyoming 

nearly doubled and the number of homesteads decreased, indicating the shift to 

livestock raising (LeCompte and Anderson 1982). 

Draft EIS, Antelope Coal Company Lease Application 3-133 
3.0 Affected Environment and Environmental Consequences 

With serious drought beginning in 1932, several Federal actions were taken. In 

April of 1932, Weston, Campbell and Converse counties were eligible for a drought 

relief program. The Northeast Wyoming Land Utilization Project began 

repurchasing the sub-marginal homestead lands and making the additional acres of 

government land available for lease. This helped the small operator to expand the 

usable grazing land. Cropland taken out of production could be reclaimed and then 

added to the grazing lease program. Grazing associations were formed to regulate 

the grazing permits. In1934, the Agricultural Adjustment Administration began 

studying portions of Converse, Campbell, Weston, Niobrara and Crook counties. In 

all, 2 million acres were included in the Thunder Basin Project (LA-WY-1) to alter 

land use and to relocate settlers onto viable farmland. Nationally, the program 

hoped to shift land use from farms to forest, parks, wildlife refuges or grazing 

districts. In marginal areas cash crops were to be replaced by forage crops, the 

kind and intensity of grazing would be changed and the size of operating units 

would be expanded (USDA-FS n.d.). Land purchase work on the Thunder Basin 

Project began late 1934 and the purchasing of units started in 1935. 

During the development program to rehabilitate the range, impounding dams were 

erected, wells were repaired, springs developed, and homestead fences were 

obliterated while division fences were constructed for the new community pastures. 

Farmsteads were obliterated and the range reseeded. Remaining homesteaders and 

ranchers often purchased or scavenged materials from the repurchased farmsteads. 

Pits were dug on some homesteads and machinery and demolished buildings buried 

(many of these were dug up during the World War II scrap drives). Ironically, the 

rehabilitation project utilized a labor pool of former farmers who had spent years 

building what the government paid them to destroy. Their efforts were so 

successful that almost no trace remains of many homesteads. 

While counties lost much of their population base as a result of the Resettlement 

Administration relocation program, they were strengthened financially: schools 

were closed, maintenance of rural roads was restricted to main arterioles, and 

delinquent taxes were paid. The remaining subsidized ranches were significantly 

larger and provided a stabilizing effect on the local economies. Three grazing 

associations were formed: the Thunder Basin Grazing Association, the Spring Creek 

Association, and the Inyan Kara Grazing Association. These associations provided 

responsible management of the common rangeland. 

Class III Cultural Resources Survey 

A Class III cultural resources survey is an intensive and comprehensive 

inventory of a proposed project area conducted by professional archaeologists 

and consultants. The survey is designed to locate and identify all prehistoric 

and historic cultural properties 50 years and older that have exposed surface 

manifestations. The goal of the survey is to locate and evaluate for the NRHP 

all cultural resources within the project area. Cultural properties are recorded 

at a sufficient level to allow for evaluation for possible inclusion to the NRHP. 

Determinations of eligibility are made by the managing federal agency in 

3-134 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

consultation with the SHPO. Consultation with the SHPO must be completed 

prior to the approval of the mining plan. 

After completion of a Class III cultural resources survey, additional investigations 

may be undertaken to complete an individual site record. If necessary, sitespecific testing or limited excavation may be utilized to collect additional data 

which will: 1) determine the final evaluation status of a site; and/or 2) form the 

basis of additional work to be conducted during implementation of a treatment 

plan if the site is determined eligible for the NRHP. A treatment plan is then 

developed for those sites that are eligible for the NRHP and are within the area of 

potential effect. Treatment plans are implemented prior to mining and can 

include such mitigation measures as avoidance (if possible), large scale 

excavation, complete recording, Historical American Building Survey/Historic 

American Engineering Record documentation, archival research, and other 

acceptable scientific practices. 

Data recovery plans are required for sites which cannot be avoided by project 

development and are recommended as eligible for the NRHP following testing and 

consultation with the SHPO. Until consultation has occurred and agreement 

regarding NRHP eligibility has been reached, all sites recommended as eligible or 

undetermined eligibility must be protected from disturbance. If the West Antelope 

II LBA tract is leased, full consultation with the SHPO would be completed prior to 

approval of the mining plans. Those sites determined to be unevaluated or eligible 

for the NRHP through consultation would receive further protection or treatment. 

Numerous Class I (survey records review) and Class III cultural resource surveys 

associated with oil and gas field development, as well as with surface mining 

operations, have been conducted in the general area. The West Antelope II general 

analysis area has been entirely surveyed for cultural resources at a Class III level, 

with the apparent exception of 40 acres in SW NW Section 32, T41N R71W. 

A total of 61 cultural sites have been documented in the West Antelope II general 

analysis area (Table 3-14). Of these 61 sites, 37 are prehistoric (P), 19 are historic 

(H), and four are multi-component (containing both historic and prehistoric 

components (H, P). One site, a cairn, is of unknown age and cultural affiliation 

and has an undetermined NRHP status. 

Twenty-three of the prehistoric sites (including the four multiple component sites 

containing both historic and prehistoric components) have been determined not 

eligible for the NRHP. No further protection is afforded these sites, as recordation 

has exhausted their archaeological potential. Six prehistoric sites have been 

determined NRHP eligible under Criterion D, for the information potential they 

contain, and will require the implementation of approved mitigation plans prior to 

any disturbance, as their loss would be considered an adverse effect to cultural 

resources. Sites 48CA4998, 48CA2892, 48CO2720, 48CO2834, 48CO2920 and 

48CO480 will require planned avoidance unless an approved mitigation plan is 

implemented. There are twelve prehistoric sites with undetermined or unresolved 

Draft EIS, Antelope Coal Company Lease Application 3-135 
3.0 Affected Environment and Environmental Consequences 

Table 3-14. Cultural Sites in the West Antelope II General Analysis Area. 

Site NRHP Site 

Number Status Author(s) / Organization Report/ Study name Year Type
 

48CA3574 NE Ferguson & Meyer (GCM) West Antelope II 2005 H 

48CA4998 E (D) Quality Services Rochelle Hills POD CBM 2004 P 

48CA4999 NE Quality Services Rochelle Hills POD CBM 2004 H 

48CA5000 NE Quality Services Rochelle Hills POD CBM 2004 H 

48CA5001 NE Quality Services Rochelle Hills POD CBM 2004 H 

48CA5002 NE Quality Services Rochelle Hills POD CBM 2004 H 

48CA5003 NE Quality Services Rochelle Hills POD CBM 2004 H, P 

48CA5012 NE Meyer, et al (GCM) Powder River Coal's Tract L 1999 H 

48CA5013 NE Meyer, et al (GCM) Powder River Coal's Tract L 1999 H 

48CA3100 NE Ferguson, David (GCM) Horse Creek 1998 P 

43CA2892 E (D) Ferguson, David (GCM) Horse Creek 1998 P 

48CA3097 NE Ferguson, David (GCM) Horse Creek 1998 P 

48CA4719 UND Ferguson & Meyer (GCM) West Antelope II (site update) 2005 H 

48CA4720 UND Ferguson & Meyer (GCM) West Antelope II (site update) 2005 H 

48CA4718 UND WAS Antelope II POD 2003 P 

48CA1543 UND Greer Services Rule Fed A-1 well location 1983 H 

48CA1547 NE Munson & Ferguson (GCM) Fiddleback, LLC Land Exchange 1995 H 

48CA3064 NE Ferguson, David (GCM) Horse Creek 1998 P 

48CA884 NE Archaeological Services Jumping Creek Fed-1 well 1981 P 

48CA885 NE Archaeological Services Jumping Creek Fed-1 well 1981 P 

48CO2720 E (D) Ferguson, David (GCM) West Antelope LBA 2001 P 

48CA3927 NE Ferguson, David (GCM) West Antelope LBA 2001 H 

48CA3928 NE Ferguson, David (GCM) West Antelope LBA 2001 H 

48CA3929 UND Ferguson, David (GCM) West Antelope LBA 2001 P 

48CA3930 NE Ferguson, David (GCM) West Antelope LBA 2001 P 

/48CO2718 

48CA3972 NE Ferguson, David (GCM) West Antelope LBA 2001 P 

48CO2727 NE Munson, et al. (GCM) Antelope Coal Site Evaluations 2005 P 

48CA3925 NE Ferguson, David (GCM) West Antelope LBA 2001 H 

48CA3926 NE Ferguson, David (GCM) West Antelope LBA 2001 H 

48CA4783 UND Western Land Services Antelope II POD 2003 H 

48CO2868 NE Quality Services Rochelle Hills POD CBM 2004 P 

48CO2830 NE Ferguson, David (GCM) West Antelope Drilling Additions 2003 H 

48CO2831 NE Ferguson, David (GCM) West Antelope Drilling Additions 2003 P 

48CO2832 NE Ferguson, David (GCM) West Antelope Drilling Additions 2003 P 

48CO2833 NE Ferguson, David (GCM) West Antelope Drilling Additions 2003 P 

48CO2834 E (D) Ferguson, David (GCM) West Antelope Drilling Additions 2003 P 

48CO2835 NE Ferguson, David (GCM) West Antelope Drilling Additions 2003 P 

48CO2836 NE Ferguson, David (GCM) West Antelope Drilling Additions 2003 P 

48CO2837 NE Ferguson, David (GCM) West Antelope Drilling Additions 2003 P 

3-136 Draft EIS, Antelope Coal Company Lease Application 
 

3.0 Affected Environment and Environmental Consequences 

Table 3-14. Cultural Sites in the West Antelope II General Analysis Area ­

Continued. 

Site NRHP Site 

Number Status Author(s) Report Year Type
 

48CO2919 UND Ferguson & Meyer (GCM) West Antelope II 2005 P 

48CO2920 E (D) Ferguson & Meyer (GCM) West Antelope II 2005 P 

48CO2921 UND Ferguson & Meyer (GCM) West Antelope II 2005 P 

48CO2922 UND Ferguson & Meyer (GCM) West Antelope II 2005 P 

48CO2923 UND Ferguson & Meyer (GCM) West Antelope II 2005 P 

48CO1724 NE Humphrey & Kingham (USFS) Antelope Creek Land Exchange 1991 P 

48CO2838 NE Ferguson, David (GCM) West Antelope Drilling Additions 2003 P 

48CO0144 NE OWSA Antelope Creek Lease Area 1979 H 

48CO0480 E (D) WCRM Antelope Coal Mine Survey 1980 P 

48CO2613 NE AEC Rochelle Hills CS#1 Well, Access 1999 P 

48CO2924 UND Ferguson & Meyer (GCM) West Antelope II 2005 P 

48CO0417 UND OWSA Antelope Creek Lease Area 1977 P 

48CO0159 UND OWSA Antelope Creek Lease Area 1977 P 

48CO2934 UND Ferguson and Munson (GCM) CA/CO Joint Pipeline Corridor 2006 P 

48CO0047 UND OWSA Unknown ? P 

48CO1720 NE Humphrey & Kingham (USFS) Antelope Creek Land Exchange 1991 H 

48CO1721 NE Humphrey & Kingham (USFS) Antelope Creek Land Exchange 1991 H, P 

48CO1722 NE Humphrey & Kingham (USFS) Antelope Creek Land Exchange 1991 P 

48CO1723 NE Humphrey & Kingham (USFS) Antelope Creek Land Exchange 1991 H, P 

48CO2248 NE AEC Antelope Mines Fuel Pipeline 1996 H, P 

48CO2996 UND Meyer (GCM) West Antelope II Addition 2006 P 

48CO2997 UND Meyer (GCM) West Antelope II Addition 2006 unk 

WCRM=Western Cultural Resource Management; OWSA=Office of the Wyoming State Archaeologist 

USFS=United States Forest Service; AEC=Archaeological Energy Consulting 

WAS=Western Archaeological Services 

NRHP Status: NE=Not Eligible (SHPO); E(D)=Eligible for the NRHP under Criterion D; 

UND= Undetermined NRHP Status (Unevaluated - No SHPO review) 

NRHP status within the West Antelope II survey area. Unresolved sites are treated 

under the law as if they were NRHP eligible, that is, disturbance is to be avoided 

until they have been evaluated for the NRHP. Site 48CA4718 is recommended 

eligible by the recording organization but has not been evaluated by any agency. 

Site 48CA3929 is recommended not eligible by the recorder, but is considered 

unevaluated by the SHPO. Four sites (48CO2919, 48CO2921, 48CO2922, and 

48CO2923) are recommended not eligible for the NRHP by the recording 

organization and are considered not eligible by the lead Federal Agency, but have 

not been reviewed by SHPO. Five prehisitoric sites (48CO47, 48CO159, 

48CO2924, 48CO2934, and 48CO2996) are recommended as not eligible for the 

NRHP by the recording organization but have not been reviewed by the lead 

federal agency or the SHPO. 

Historic site categories documented within the West Antelope II general analysis 

area fall under the context of rural settlement. Specifically, historic sites in the 

Draft EIS, Antelope Coal Company Lease Application 3-137 
3.0 Affected Environment and Environmental Consequences 

West Antelope II survey area are associated with homesteading and stock raising, 

circa 1910s to 1940s. Nineteen of the historic sites recorded within the West 

Antelope II general analysis area (including the four multiple component sites 

containing both historic and prehistoric components) have been determined not 

eligible for the NRHP. No further work is required for those sites. Three of the 

Historic Sites (48CA4719, 48CA4720 and 48CA4783) have undetermined NRHP 

status, pending SHPO review, but are recommended not eligible by the recording 

organization and by the lead Federal agency. One historic site (48CA1543) has 

had no agency review. A determination of the NRHP status will need to be made 

for these sites prior to their disturbance. 

3.12.2 Environmental Consequences 

3.12.2.1 Proposed Action and Alternatives 1 and 2 

Data recovery plans are required for all sites recommended eligible to the National 

Register following testing and consultation with SHPO. Until consultation with 

SHPO has occurred and agreement regarding NRHP eligibility has been reached, 

all sites would be protected from disturbance. 

Full consultation with SHPO must be completed prior to approval of a mining 

plan. At that time, those sites determined to be unevaluated or eligible for the 

NRHP through consultation would receive further protection or treatment. 

Impacts to eligible or unevaluated cultural resources cannot be permitted. If 

unevaluated sites cannot be avoided, they must be evaluated prior to disturbance. 

If eligible sites cannot be avoided, a data recovery plan must be implemented prior 

to disturbance. Ineligible cultural sites may be destroyed without further work. 

The eligible sites on the West Antelope II LBA tract that cannot be avoided or that 

have not already been subjected to data recovery action would be carried forward 

in the mining and reclamation plan as requiring protective stipulations until a 

testing, mitigation, or data recovery plan is developed to address the impacts to 

the sites. The lead federal and state agencies would consult with Wyoming SHPO 

on the development of such plans and the manner in which they are carried out. 

Cultural resources adjacent to the mine areas may be impacted as a result of 

increased access to the areas. There may be increased vandalism and 

unauthorized collecting associated with recreational activity and other pursuits 

outside of but adjacent to mine permit areas. Unintended or uninformed impacts 

related to increased off-road traffic during mine related activities are the most 

frequents impacts to cultural resources. 

3.12.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and coal removal and the associated disturbance and impacts would 

not occur on from 4,314 up to 6,625 acres that would be disturbed under the 

3-138 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

Proposed Action or Alternatives 1 and 2, respectively. Currently approved mining 

operations would continue on the existing Antelope Mine leases. Cultural 

resources on the portions of the West Antelope II LBA tract adjacent to the 

Antelope Mine would be affected as a result of disturbance that would occur 

during recovery of the coal in the existing leases. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in 

the future. 

3.12.3 Native American Consultation 

Native American heritage sites can be classified as prehistoric or historic. Some 

may be presently in use as offering, fasting, or vision quest sites. 

Other sites of cultural interest and importance may include rock art, stone circles, 

various rock features, fortifications or battle sites, burials, and locations that are 

sacred or part of the oral history and heritage but have no man-made features. 

No Native American heritage, special interest, or sacred sites have been formally 

identified and recorded to date within the general analysis area. However, the 

geographic position of the general analysis area between mountains considered 

sacred by various Native American cultures (the Big Horn Mountains to the west, 

the Black Hills to the east, and Devils Tower to the north) creates the possibility 

that existing locations may have special religious or sacred significance to Native 

American groups. If such sites or localities are identified, appropriate action must 

be taken to address concerns related to those sites. 

Tribes that have been identified as potentially having concerns about actions in 

the PRB include the Crow, Northern Cheyenne, Shoshone, Arapaho, Oglala Sioux, 

Rosebud Sioux, Crow Creek Sioux, Lower Brule Sioux, Standing Rock Sioux, 

Cheyenne River Sioux, Apache Tribe of Oklahoma, Comanche Tribe of Oklahoma, 

and Kiowa Tribe of Oklahoma. These tribal governments and representatives have 

been sent copies of the EIS. They are also being provided with more specific 

information about the known cultural sites on the tract in this analysis. Their 

help is being requested in identifying potentially significant religious or cultural 

sites in the general analysis area before a leasing decision is made on the West 

Antelope II LBA tract. 

Native American tribes were consulted at a general level in 1995-1996 as part of 

an update to the BLM Buffalo Resource Area RMP. Some of the Sioux tribes were 

consulted by BLM on coal leasing and mining activity in the PRB at briefings held 

in Rapid City, South Dakota in March 2002. 

Draft EIS, Antelope Coal Company Lease Application 3-139 
3.0 Affected Environment and Environmental Consequences 

3.12.4 Regulatory Compliance, Mitigation and Monitoring 

Class I and III surveys are conducted to identify cultural properties on all lands 

affected by federal undertakings. Prior to mining, SHPO is consulted to evaluate 

the eligibility of the cultural properties for inclusion in the NRHP. Cultural 

properties that are determined to be eligible for the NRHP would be avoided or, if 

avoidance is not possible, a recovery plan would be implemented prior to 

disturbance. 

Mining activities are monitored during topsoil stripping operations. If a lease is 

issued for the West Antelope II LBA tract, BLM would attach a stipulation to the 

lease requiring the lessee to notify appropriate federal personnel if cultural 

materials are uncovered during mining operations (Appendix D). 

3.12.5 Residual Impacts 

Cultural sites that are determined to be eligible for the NRHP would be avoided if 

possible. Eligible sites that cannot be avoided would be destroyed by surface coal 

mining after data from those sites is recovered. Sites that are not eligible for the 

NRHP would be lost. 

Cultural sites are permanently destroyed by surface coal mining operations but, 

as a result of the intensive pedestrian inventories, site evaluations and excavation 

and analysis of prehistoric cultural resources discussed above, there is a more 

informed understanding of what types of resources exist in the region and a better 

understanding of local prehistory. 

3.13 Visual Resources 

3.13.1 Affected Environment 

Visual sensitivity levels are determined by people’s concern for what they see and 

the frequency of travel through an area. Landscapes within the general analysis 

area include rolling sagebrush and short-grass prairie, which are common 

throughout the PRB. There are also areas of altered landscape, such as oil fields 

and surface coal mines. Existing surface mines form a nearly continuous band on 

the east side of Highway 59 from Gillette south for about 50 miles. Other manmade intrusions include ranching activities (fences, homesteads, and livestock), 

oil and gas development (pumpjacks, pipeline ROWs, CBNG well shelters, and 

CBNG compressor stations), transportation facilities (roads and railroads), 

environmental monitoring installations, road signage, and electrical power 

transmission lines. The natural scenic quality in and near the general analysis 

area is fairly low because of the industrial nature of the adjacent existing mining 

operations and oil and gas development. 

The VRM system is the basic tool used by BLM to inventory and manage visual 

resources on public lands. Prior to 1986, the five VRM classes defined below were 

3-140 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

used to describe increasing levels of change within the characteristic landscape. 

The number of VRM classes was reduced from five to four in 1986 (BLM 2007), 

but the new resource management class objectives remain very similar to the 

original objectives of VRM Classes I through IV. 

The pre-1986 VRM Classes are summarized as follows: 

Class I: Natural ecologic changes and very limited management activity is 

allowed. Any contrast (activity) within this class must not attract attention. 

Class II: Changes in any of the basic elements (form, line, color, texture) 

caused by an activity should not be evident in the landscape. 

Class III: Contrasts to the basic elements caused by an activity are evident but 

should remain subordinate to the existing landscape. 

Class IV: Activity attracts attention and is a dominant feature of the landscape 

in terms of scale. 

Class V: This classification is applied to areas where the natural character of 

the landscape has been disturbed up to a point where rehabilitation is needed 

to bring it up to the level of one of the other four classifications. 

The 2001 Buffalo RMP revision (BLM 2001a) covers the Campbell County portion 

of the West Antelope II general analysis area. It retained and carried forward the 

VRM inventory from the 1985 Buffalo RMP (BLM 1985a). Visual classifications for 

the Converse County portion of the West Antelope II LBA tract (the south block of 

the lease application area) were included in the Platte River Resource Area RMP 

(BLM1985b). The Proposed Resource Management Plan and Final Environmental 

Impact Statement for the Casper Field Office, which was released June 8, 2007 

and will replace the 1985 Platte River RMP when it is completed, includes an 

updated VRM inventory (BLM 2007). 

At this time, the lands included in the general analysis area in both Campbell and 

Converse Counties continue to be managed in accordance with the VRM classes 

established in 1981 and the predominant VRM class is Class IV. Portions of the 

general analysis area adjacent to State Highway 59 in Converse County are 

currently classified as Class III, but the amount of Class III land would be reduced 

by adoption of the preferred alternative (BLM 2007) for the Casper Field Office 

RMP. Use of the post-1986 VRM classes in the Casper Field Office RMP will not 

affect the general analysis area VRM classification because the general analysis 

area does not include any lands that were classified as VRM Class V in the 1985 

Platte River RMP. 

Approximately 240 acres of the surface of the general analysis area is part of the 

TBNG, which is administered by the USDA-FS. The USDA-FS has established 

visual quality objectives for the TBNG. In the general analysis area, facilities and 

Draft EIS, Antelope Coal Company Lease Application 3-141 
3.0 Affected Environment and Environmental Consequences 

landscape modifications may be visible but should be reasonably mitigated to 

blend and harmonize with natural features according to the revised Land and 

Resource Management Plan for the Thunder Basin National Grassland (USDA-FS 

2001). 

Currently, mine facilities and mining operations at the Antelope Mine are visible 

from various public-use roads in the general analysis area, including Antelope 

Road (County Road 37) and State Highway 59. 

3.13.2 Environmental Consequences 

3.13.2.1 Proposed Action and Alternatives 1 and 2 

If the West Antelope II LBA tract is leased and mined, mining operations on the 

LBA tract would be visible from State Highway 59, which is approximately 0.75 to 

2.5 miles west of the tract. The portions of the general analysis area that would 

be disturbed under the Proposed Action or Alternatives 1 or 2 would be considered 

as VRM Class IV prior to reclamation. After reclamation of the LBA tract and 

adjoining mines, the VRM Class IV conditions would be restored and the 

reclaimed land would resemble the surrounding undisturbed terrain. No visual 

resources that are unique to this area have been identified on or near the West 

Antelope II LBA tract. 

Reclaimed terrain would be almost indistinguishable from the surrounding 

undisturbed terrain. Slopes might appear smoother (less intricately dissected) 

than undisturbed terrain and sagebrush would not be as abundant for several 

years; however, within a few years after reclamation, the mined land would not be 

distinguishable from the surrounding undisturbed terrain except by someone very 

familiar with landforms and vegetation. 

3.13.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and coal removal and the associated disturbance and impacts would 

not occur on from 4,314 up to 6,625 acres that would be disturbed under the 

Proposed Action or Alternatives 1 and 2, respectively. The current VRM Class 

designations would not change for those lands. Currently approved mining 

operations would continue on the existing Antelope Mine leases. Portions of the 

West Antelope II LBA tract adjacent to the Antelope Mine would be disturbed to 

recover the coal in the existing leases. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3-142 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

3.13.3 Regulatory Compliance, Mitigation and Monitoring 

Landscape character would be restored during reclamation to approximate 

original contour and would be reseeded with an approved seed mixture, including 

native species. 

See Section 3.2 and Section 3.9 for additional discussion of the regulatory 

requirements, mitigation, and monitoring for topography and vegetation. 

3.13.4 Residual Impacts 

No residual impacts to visual resources are expected. 

3.14 Noise 

3.14.1 Affected Environment 

Existing noise sources in the general analysis area include coal mining activities, 

traffic on the access and county roads, rail traffic, wind, and CBNG compressor 

stations. 

Noise originating from CBNG development equipment (e.g., drilling rigs and 

construction vehicles) is apparent locally over the short term (i.e., 30 to 60 days) 

where well drilling and associated construction activities are occurring. The 

amount of noise overlap between well sites is variable and depends on the timing 

of drilling activities on adjacent sites and the distance between the site locations. 

Studies of background noise levels at PRB mines indicate that ambient sound 

levels generally are low, owing to the isolated nature of the area. The unit of 

measure used to represent sound pressure levels (decibels) using the A-weighted 

scale is a dBA. It is a measure designed to simulate human hearing by placing 

less emphasis on lower frequency noise because the human ear does not perceive 

sounds at low frequency in the same manner as sounds at higher frequencies. 

Figure 3-22 presents noise levels associated with some commonly heard sounds. 

No site-specific noise level data are available for the general analysis area. 

However, in 2004, Matheson Mining Consultants, Inc. conducted a noise survey at 

the two occupied locations closest to the existing Antelope operations. 

Measurements were taken at the Don Jacobs residence located directly west of the 

mine on State Highway 59 and at the Dyno Nobel West Region office located 

northeast of the mine on County Road 37. The maximum daily time weighted (Leq) 

noise reading at the Don Jacobs residence was 51 dBA which is comparable to 

that of a normal office, 50 feet in the distance. The maximum measured Leq at 

Dyno Nobel was 52.6 dB(A) which is equivalent to the noise level of an average 

office environment. 

Draft EIS, Antelope Coal Company Lease Application 3-143 
Adapted From ABC's of Our Noise Codes published by

Citizens Against Noise, Honolulu, Hawaii

HOW IT FEELS EQUIVALENT DECIBELS EQUIVALENT HOW IT SOUNDS

SOUNDS SOUNDS

130

120

110

100

90

80

70

60

50

40

30

20

10

Near permanent damage

level from short

exposures

50 hp siren

(100 ft)

Pain to ears

Jet engine

Turbo-fan jet at

Uncomfortably

Discomfort

Scraper-loader

Very loud

Jet fly over

Conversation

Noisy newspaper

Intolerable for

Air compressor

Extra auditory

Power lawnmower

Quiet

Steady flow of

Sleep interference

10-HP outboard motor

Vacuum cleaner

Window air

Occasional private

Garbage trucks

Unmuffled motor bike

135 dB(A)

Unmuffled cycle

Diesel truck

Garbage disposal

Food blender

Muffled jet ski

Passenger car

Busy downtown area

Normal conversation

In a quiet house

phone use

stops

threshold

loud

physiological

effects

(75 ft)

takeoff power

(100ft)

(1000 ft)

press

(20 ft)

freeway trafic

Automatic

dishwasher

Window air

conditioner outside

at 2 ft.

conditioner

in room

auto at 100 ft.

evening

Quiet home during

Library

Bird calls

Soft whisper 5 ft.

Leaves rustling

at midnight

65 mph (25 ft)

(50 ft.)

(25 ft.)

and city buses

(25 ft.)

Rock and roll

Fire cracker

Chainsaw

Jackhammer

(2-3 ft.)

band

(15 ft.)

Car horn

Approx. 64 times

as loud as 75dB(A)

as loud as 75dB(A)

Approx. 32 times

125 dB(A)

as loud as 75dB(A)

Approx. 16 times

115 dB(A)

as loud as 75dB(A)

Approx. 8 times

105 dB(A)

as loud as 75dB(A)

Approx. 4 times

95 dB(A)

as loud as 75dB(A)

Approx. 2 times

85 dB(A)

75dB(A)

as loud as 75dB(A)

Approx. 1/4

55 dB(A)

45 dB(A)

Approx. 1/8

as loud as 75dB(A)

35 dB(A)

Approx. 1/16

as loud as 75dB(A)

Danger to hearing Very quiet

Figure 3-22. Relationship Between A-Scale Decibel Readings and Sounds of Daily Life.

3.0 Affected Environment and Environmental Consequences

3-144 Draft EIS , West Antelope II Coal Lease Application 
3.0 Affected Environment and Environmental Consequences 

3.14.2 Environmental Consequences 

3.14.2.1 Proposed Action and Alternatives 1 and 2 

Noise levels on the LBA tract would be increased considerably by mining activities 

such as blasting, loading, hauling, and possibly in-pit crushing. Since the LBA 

tract would be mined as an extension of existing operations, no rail car loading 

would take place on the LBA tract. The Noise Control Act of 1972 indicates that a 

24-hour equivalent level of less than 70 dBA prevents hearing loss and that a level 

below 55 dBA, in general, does not constitute an adverse impact. 

Because of the remoteness of the LBA tract and because mining is already ongoing 

in the area, noise would have few off-site impacts. MMA (2005) conducted a very 

conservative noise modeling analysis of the existing West Antelope North (WAN) pit 

which showed that, at a distance of 16,000 feet, maximum noise levels would not 

exceed 54 dBA, which is equivalent to the sound level expected in a suburban, 

residential town. The nearest occupied residence (the Don Jacobs residence) is 

approximately 2,800 feet west of the westernmost extent of the West Antelope II 

LBA tract. If the tract is leased and mined, mining operations could be 

approximately 2,000 feet closer to this residence than the current lease would 

allow (Figure 3-9). The minimum distance from current lease areas to the next 

nearest residence, located due west of the north part of the LBA tract, is 

approximately 16,300 feet. If the West Antelope II LBA tract is leased and mined, 

mining operations could be approximately 1,900 feet closer to this residence. 

Wildlife in the immediate vicinity of mining may be adversely affected; however, 

anecdotal observations at surface coal mines in the area indicate that some 

wildlife may adapt to increased noise associated with coal mining activity. After 

mining and reclamation are completed, noise would return to premining levels. 

3.14.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and coal removal and the associated noise impacts would not occur on 

the LBA tract. Currently approved mining operations and associated noise 

impacts would continue on the existing Antelope leases. 

3.14.3 Regulatory Compliance, Mitigation and Monitoring 

Mine operators are required to comply with MSHA regulations concerning noise, 

which include protecting employees from hearing loss associated with noise levels 

at the mines. MSHA periodically conducts mine inspections to ensure compliance 

with the requirements of the Federal Mine Safety and Health Act of 1977. 

3.14.4 Residual Impacts 

No residual impacts to noise are expected. 

Draft EIS, Antelope Coal Company Lease Application 3-145 
3.0 Affected Environment and Environmental Consequences 

3.15 Transportation 

3.15.1 Affected Environment 

Transportation resources near the West Antelope II LBA tract include State 

Highway 59, County Road 37 (Antelope Coal Mine Road) in Converse County, 

County Road 4 (Antelope Road) in Campbell County, several unimproved local 

roads and accesses (unnamed two-track trails), the BNSF & UP railroad, oil and 

gas pipelines, utility/power lines, telephone lines, and associated ROWs. Figure 

3-23 depicts the current transportation facilities, excluding the oil and gas 

pipelines, within and near the general analysis area. Figure 3-24 depicts the oil 

and gas pipelines within and near the general analysis area. 

Highway 59, a paved two-lane road located west of the West Antelope II LBA tract, 

is the major north-south public transportation corridor within the PRB. Access to 

the LBA tract is on Douglas Road and Antelope Coal Mine Road from the west 

(from Highway 59) or Antelope Road / Antelope Coal Mine Road from the 

northeast. The county roads provide public and private access within the general 

analysis area. The unimproved local roads and accesses in the area are primarily 

for private use. As shown in Figure 3-23, State Highway 59, County Road 37, and 

County Road 4 do not cross the West Antelope LBA tract under the Proposed 

Action. However, State Highway 59 does cross the southwestern corner of the 

portion of the BLM study area that includes the south block of the tract under 

Alternatives 1 and 2, and County Road 37 crosses the southeastern corner of the 

portion of the BLM Study area that includes the south block of the tract under 

Alternatives 1 and 2. 

The BNSF & UP Gillette-Douglas rail spur runs north-south along the eastern 

edge of the PRB, roughly parallel to and east of State Highway 59, with individual 

spur lines that connect each mine to the railroad for the purpose of transporting 

the coal that is mined in the eastern PRB. 

The DM&E Railroad has proposed an expansion into the PRB of Wyoming. If 

constructed, the DM&E project would be the largest railroad construction project 

in the United States in the last 100 years (Sheridan Press 2006). The STB 

completed an EIS and gave final approval to the expansion project in 2002. After 

the EIS was successfully appealed, the STB issued a final SEIS on the expansion 

project December 30, 2005, which addressed four issues that were remanded 

back to the STB as a result of the appeal, and granted final approval to construct 

the rail line on February 15, 2006. The SEIS was also appealed, but was upheld 

by the US Court of Appeals for the Eighth Circuit in December 2006. In early 

September, 2007, Canadian Pacific Railway Ltd announced it is in the process of 

buying DM&E. If it is constructed as proposed, the DM&E rail line would 

potentially be in a position to haul coal produced by the Antelope Mine. 

3-146 Draft EIS, Antelope Coal Company Lease Application 
 

 

 

3.0 Affected Environment and Environmental Consequences 

Campbell County 

Converse County 

North Antelope / Rochelle 

Rail Line 

An telope Road 

B.N.S.F. & U.P RR 

County Rd. 37 

T. 

40 

N. 

R. 72 W. R. 70 W. 

T. 

41 

N. 

T. 

41 

N. 

R. 71 W. 

T. 

40 

N. 

R. 71 W. 

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

9 

3 6 

8 

2 

7 

1 

8 

5 

8 

5 4

9 

7 8 

7 

1 6 

7 

4 

9 

1 

9 

6 5 4 3 2 1 6 5 4 

11 

12 

22 

11 

27 

13 

15 

24 

10 

20 

26 

18 

19 

17 

30 

20 21 

29 

23 

15 

14 

29 28 

14 13 

16 

12 

30 

12 

13 17

16 

25 

19 

17 18 

32 

17 

34 

10 

18 

31 32 33 35 31

18 

36 

13 

12 

28 

25 

33 

24 21 

36 

16 

24 23 24

16 

22 19 20 21 19 20 21 

31 32 33 34 35 36 31 32 33 36 

2 

11 

14 

23 

!(59 

LEGEND 

Electric Corridor 

B.N.S.F. & U.P. Rail Line 

State Highway 

Other Roads 

Paved Roads 

Existing Antelope Mine Federal Coal Leases 

West Antelope II LBA Tract As Applied For 

Area Added under Alternative 1 

North Tract (Alternative 2) 

South Tract (Alternative 2) 

£ 0 8,000 16,000 

GRAPHIC SCALE (FEET) 

Figure 3-23. Transportation Facilities Within and Adjacent to the West Antelope II LBA Tract. 

Douglas Road 

Draft EIS, West Antelope II Coal Lease Application. 3-147
 
 

 

 

3.0 Affected Environment and Environmental Consequences 

Campbell County 

Converse County 

North Antelope / Rochelle 

Rail Line 

An telope Road 

B.N.S.F. & U.P RR 

T. 

40 

N. 

R. 72 W. R. 70 W. 

T. 

41 

N. 

T. 

41 

N. 

R. 71 W. 

T. 

40 

N. 

R. 71 W. 

R. 72 W. R. 71 W. R. 71 W. R. 70 W. 

9 

3 6 

8 

2 

7 

1 

8 

5 

8 

5 4

9 

7 8 

7 

1 6 

7 

4 

9 

1 

9 

6 5 4 3 2 1 6 5 4 

11 

12 

22 

11 

27 

13 

15 

24 

10 

20 

26 

18 

19 

17 

30 

20 21 

29 

23 

15 

14 

29 28 

14 13 

16 

12 

30 

12 

13 17

16 

25 

19 

17 18 

32 

17 

34 

10 

18 

31 32 33 35 31

18 

36 

13 

12 

28 

25 

33 

24 21 

36 

16 

16 

24 19 20 21 22 23 24 19 20 21 

31 32 33 34 35 36 31 32 33 36 

2 

11 

14 

23 

!(59 

LEGEND 

Oil and Gas Pipelines 

B.N.S.F. & U.P. Rail Line 

State Highway 

Other Roads 

Paved Roads 

Existing Antelope Mine Federal Coal Leases 

West Antelope II LBA Tract As Applied For 

Area Added under Alternative 1 

North Tract (Alternative 2) 

South Tract (Alternative 2) £ 0 8,000 16,000 

GRAPHIC SCALE (FEET) 

Figure 3-24. Oil and Gas Pipelines Within and Adjacent to the West Antelope II LBA Tract. 

Relocated 16" Pipeline 

Relocated 6" Pipeline 

Relocated 16" Pipeline 

Relocated 6" Pipeline 

WGR 6" Pipeline 

Relocated 16" Pipeline 

Relocated 6" Pipeline 

WGR Pipeline County Rd. 37 

WGR Pipeline 

3-148 Draft EIS, West Antelope II Coal Lease Application 
3.0 Affected Environment and Environmental Consequences 

3.15.2 Environmental Consequences 

3.15.2.1 Proposed Action and Alternatives 1 and 2 

Essentially all of the coal mined on the LBA tract would be transported by rail. 

Since the West Antelope II LBA tract would be an extension of the existing 

Antelope Mine operations, the existing rail facilities and infrastructure would be 

used to recover the coal within the tract, if it is leased. As discussed in Section 

4.1, BNSF & UP have upgraded and will continue to upgrade their rail capacities 

to handle the increasing coal volume projected from the PRB, with or without the 

leasing of the West Antelope II LBA tract. The construction of the proposed DM&E 

Railroad expansion into this area is not dependent on leasing the LBA tract. 

As discussed above, State Highway 59 crosses the southwestern corner of the 

BLM study area for the south block of the tract under Alternatives 1 and 2. 

County Road 37 crosses the southeastern corner of the BLM Study area for the 

south block of the tract under Alternatives 1 and 2. As discussed in Chapters 1 

and 2, lands within 100 feet of the outside line of the ROW of a public road are 

considered unsuitable for mining under Criterion 3 of the coal unsuitability 

criteria (43 CFR 3461(c)). Although the lands underlying the ROWs for these 

public roads would be considered unsuitable, they could be included in the West 

Antelope II LBA tract to allow recovery of economically mineable coal outside of the 

ROW and buffer zone. A stipulation stating that no mining activity may be 

conducted in the portion of the lease within the public road ROW and buffer zone 

will be attached if a lease is issued for this tract. The exclusion from mining by 

lease stipulation honors the finding of unsuitability under Unsuitability Criterion 

3. 

If the tract is leased and mined, pipelines and utility/power transmission lines 

that currently cross the LBA tract would have to be removed and relocated if they 

are currently active. Any relocation of these pipelines and utility lines would be 

handled according to specific agreements between the coal lessee and the pipeline 

and utility owners, if the need arises. 

3.15.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and coal removal and the associated disturbance and impacts would 

not occur on from 4,314 up to 6,625 acres that would be disturbed under the 

Proposed Action or Alternatives 1 and 2, respectively. 

The transportation resources located in those areas would not be affected by 

mining. Currently approved mining operations and any associated impacts to 

transportation resources would continue on the existing Antelope Mine leases. 

Portions of the West Antelope II LBA tract adjacent to the Antelope Mine would be 

disturbed to recover the coal in the existing leases. 

Draft EIS, Antelope Coal Company Lease Application 3-149 
3.0 Affected Environment and Environmental Consequences 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3.15.3 Regulatory Compliance, Mitigation and Monitoring 

The regulatory requirements regarding transportation facilities require that 

existing pipelines and utility lines be relocated, if necessary, in accordance with 

specific agreements between the coal lessee and the pipeline and utility owners. 

3.15.4 Residual Impacts 

No residual impacts to transportation facilities are expected. 

3.16 Hazardous and Solid Waste 

3.16.1 Affected Environment 

Potential sources of hazardous or solid waste on the West Antelope II LBA tract 

would include spilled, leaked or dumped hazardous substances, petroleum 

products, and/or solid waste associated with coal and oil and gas exploration, oil 

and gas development, the BNSF & UP railroad, utility line installation and 

maintenance, or agricultural activities. No such hazardous or solid wastes are 

known to be present on the West Antelope II LBA tract. Wastes produced by 

current mining activities at the Antelope Mine are handled according to the 

procedures described in Section 2.1.2. 

3.16.2 Environmental Consequences 

3.16.2.1 Proposed Action and Alternatives 1 and 2 

If the applicant mine acquires the LBA tract, the wastes that would be generated 

in the course of mining the tract would be similar to those currently being 

generated by the existing mining operation. The procedures that are used for 

handling hazardous and solid wastes at the existing mine are described in 

Chapter 2, Section 2.1.2. Wastes generated by mining the West Antelope II LBA 

tract would be handled in accordance with the existing regulations using the 

procedures currently in use and in accordance with WDEQ-approved waste 

disposal plans at the Antelope Mine. 

3.16.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and coal removal and the associated disturbance and impacts would 

not occur on from 4,314 up to 6,625 acres that would be disturbed under the 

Proposed Action or Alternatives 1 and 2, respectively, and no waste materials 

would be generated as a result of coal removal on the tract. Currently approved 

3-150 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

mining operations would continue on the existing Antelope Mine leases. Portions 

of the West Antelope II LBA tract adjacent to the Antelope Mine would be 

disturbed to recover the coal in the existing leases. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3.16.3 Regulatory Compliance, Mitigation and Monitoring 

The regulatory requirements regarding production, use, and/or disposal of 

hazardous or extremely hazardous materials are discussed in Chapter 2. All 

mining activities involving the hazardous materials are and would continue to be 

conducted so as to minimize potential environmental impacts. 

3.16.4 Residual Impacts 

No residual hazardous and solid waste impacts are expected. 

3.17 Socioeconomics 

The social and economic study area for the proposed lease action and associated 

mining includes Converse and Campbell counties and the communities of 

Douglas, Gillette and Wright. These three communities are home to more than 95 

percent of the mine’s current workforce, as well as most of the mining services, 

retail and business and consumer service establishments in the area. Gillette and 

Douglas are also the county seats for the respective counties. 

The Antelope Mine presently has a workforce of 430 employees. The current 

workforce represents an increase of about 180 employees in the past two years 

following the acquisition of additional reserves in the West Antelope lease. The 

mine has also completed significant capital investments in mining equipment and 

rail loadout facilities to boost its production. The expansion in reserves associated 

with the West Antelope II LBA tract under the Proposed Action would sustain 

current rates of production [about 36 mmtpy) while extending the life of mine by 

approximately 12 years. The additional reserves associated with Alternatives 1 

and 2 would add about 1 more year to the life-of-mine beyond that associated with 

the Proposed Action. Assuming an increase in annual production to 42 mmtpy, 

the corresponding life-of-mine estimates are 10 additional years under the 

Proposed Action and 11 additional years under Alternatives 1 and 2. 

No major change in direct employment is anticipated at the Antelope Mine in 

conjunction with the Proposed Action or Alternatives 1 and 2 assuming annual 

production of 36 mmtpy, though as many as 25 additional workers may be needed 

at times during the life-of-mine as mining progresses to different locations. 

Raising annual production to 42 mmtpy could increase the incremental workforce 

needs to as many 40 workers, or 470 total employees, at times. 

Draft EIS, Antelope Coal Company Lease Application 3-151 
 

 

 

3.0 Affected Environment and Environmental Consequences 

Residency patterns of new employees would be expected to mirror that of the 

mine’s current workforce. Nearly 70 percent of the current workforce lives in or 

near Douglas, approximately 50 miles south of the mine. About 26 percent of the 

mine’s workforce live in Campbell County; 90 workers (20 percent) in Gillette 

(about 65 miles north) and 25 workers (6 percent) in Wright (about 20 miles 

north). Company-sponsored bus service to and from the mine operates several 

times daily for employees living in Gillette and Douglas. 

In 2006 the Antelope Mine had a total payroll, including benefits and incentives, of 

$36.7 million. In addition, the mine made outlays of $286 million for non-labor 

operating expenses, capital investments, and permits, licenses, fees and taxes. 

Approximately 20 percent of the latter sum was spent with vendors and suppliers 

in Wyoming or paid directly to state and local governments. The total also 

includes $62.7 million in Federal Mineral Royalties, reclamation and black lung 

taxes, a considerable portion of which returns to Wyoming. 

3.17.1 Local Economy 

3.17.1.1 Affected Environment 

Coal production reported to the Wyoming State Inspector of Mines showed 

Wyoming’s coal mines set a new annual production record of 444.9 million tons in 

2006, an increase of 41 million tons (10.2 percent) over the 403.9 million tons 

produced in 2005; itself a record. PRB coal production (from Campbell and 

Converse Counties, 13 active mines) represented nearly 97 percent of the 

statewide coal production in 2006 and accounted for all of the gains in statewide 

production from 2005 to 2006 (Wyoming Department of Employment 2007a). 

Energy resource development has been the primary stimulus behind a significant 

economic expansion across the state in recent years. Statewide total covered 

employment2 stood at 254,302 in the first quarter of 2006, more than 10 percent 

higher than the corresponding total of 230,429 jobs in 2003. Nearly one-of-three 

new jobs created in the state during the 3-year period was in the mining industry, 

with most of that increase concentrated in support industries for oil and gas 

development. During the same period, statewide coal mining employment 

increased by 762 jobs to 5,567 jobs, a 16 percent net increase (Wyoming 

Department of Employment 2007b) and total employment grew by 513 jobs (12 

percent) in Converse County and 4,422 jobs (22 percent) in Campbell County. 

Local job growth occurred across most industries, but was concentrated in 

mining, construction, transportation, and local government (Wyoming Department 

of Employment 2007b). Mining, including the oil and gas industry, accounts for 

2 Covered employment refers to those full- and part-time, private and government wage/salary 

workers covered under the state’s unemployment insurance program. About 97% of nonagricultural workers are included. Exclusions include insurance and real estate agents on 

commission; most railroad workers; self-employed; unpaid volunteers or family workers; members 

of the military; and many agricultural workers. 

3-152 Draft EIS, Antelope Coal Company Lease Application 
 

 

3.0 Affected Environment and Environmental Consequences 

30 percent of the total employment and 45 percent of the total payroll in Campbell 

County and 15 percent of employment and 25 percent of the total payroll in 

Converse County. Coal mining is the major constituent portion of the region’s 

mining industry, unlike in many other areas of Wyoming, where oil and gas 

development is the primary constituent. 

Labor market conditions in the region reflect recent economic expansion driven 

principally by energy resource development. Unemployment in both counties has 

declined since 2003. Average unemployment rates for 2006 were 3.4 percent in 

Converse County and 2.1 percent in Campbell County, even as the local labor 

force has grown due to immigration and the attraction of additional residents into 

the labor force (U.S. Bureau of Labor Statistics 2007). 

Recent estimates of the state’s Gross State Product (GSP)3 highlight the 

significance of the minerals industry to the statewide economy. Estimates of the 

2004 GSP indicate the mining industry, including oil and gas and support 

activities, accounted for 21.3 percent of the state’s total GSP of $24.1 billion. The 

contribution of mining was nearly twice that of government, the next largest 

sector, and more than three times the contribution of the real estate industry, the 

next largest private sector. Coal mining and mining of other minerals accounted 

for 8.3 percent of the Wyoming GSP (Wyoming Department of Administration and 

Information 2007). 

Wyoming, Converse and Campbell county governments, school districts, and local 

towns receive revenue from a variety of taxes and royalties on the production of 

federal coal. These include lease bonus bids, ad valorem taxes, severance taxes, 

royalty payments, sales and use taxes on equipment and other taxable purchases, 

and portions of required contributions to the federal AML program and Black Lung 

Disability Trust Fund. Lease bonus bids are paid for the right to enter into lease 

agreements for federal coal. 

In 1994, the University of Wyoming estimated the total fiscal benefit to the State of 

Wyoming for coal produced in the PRB at $1.10 per ton (Borden et al. 1994). 

Calculating the estimated total fiscal benefit to the State of Wyoming in 2005 by 

including half of the bonus bid payments, half of the federal mineral royalties 

based on current prices, half of the AML fees, and all of the ad valorem taxes, 

severance taxes, and sales and use taxes for coal produced in Campbell County in 

2004 results in an estimated $620 million, or $1.53 per ton (BLM 2006b). 

Revenues to the federal government from the leasing and production of federal 

coal include retention of one-half of the lease bonus bids and federal mineral 

royalties. Bonus bids are paid in five annual installments, with half returned to 

the state. In 2004 and 2005, BLM held competitive sealed-bid lease sales for six 

coal tracts (NARO South, West Antelope, West Hay Creek, Little Thunder, West 

3 GSP is a measure of the total market value of goods and services produced by the labor, capital 

and property in the state, after netting out the value of intermediate outputs imported to the state. 

Draft EIS, Antelope Coal Company Lease Application 3-153 
3.0 Affected Environment and Environmental Consequences 

Roundup, and NARO North). The successful bonus bids for these six sales ranged 

from 30 cents per ton to 97 cents per ton and totaled $1.69 billion, including 

$146.3 million for the West Antelope tract (BLM 2006b). 

Annual bonus bid payments from the six lease sales currently total $338.2 

million. Three years remain on the payments from those sales, with an annual 

bonus bid payment of $169.1 million to the State of Wyoming derived directly from 

federal coal in the PRB. Presently, coal lease bonus bids disbursements to the 

state are subsequently allocated to fund capital construction of schools, capital 

construction projects for cities, towns and counties, the state’s highway fund, and 

community colleges. 

Federal mineral royalties (FMR) are collected by the federal government at the time 

that produced coal is sold, with a royalty rate equal to 12.5 percent of the sale 

price. Following a deduction for administrative expenses (approximately one 

percent), 50 percent of the FMR are disbursed to the State of Wyoming. Total FMR 

disbursements to the state in fiscal year 2006, derived from all mineral 

production, not solely coal, was $1.07 billion (Wyoming CREG 2007). In 2006, the 

Antelope Mine paid $39.3 million in FMR. 

In addition to the FMR, coal mines pay 31.5 cents per ton of surface coal produced 

to fund abandoned mine land (AML) reclamation programs. Collectively about 83 

percent of the funds are returned to states and tribes with AML problems. Actual 

annual appropriations vary depending on Congressional authorizations and 

overall AML program priorities. Additional sources of revenue include federal 

income tax and annual rentals paid to the government. The Antelope Mine 

payments to the federal mining reclamation program exceeded $11.8 million in 

2006. 

Sales and use taxes are levied by the state and by local governments. 

Approximately 70 percent of the revenues generated from the statewide 4.0 

percent levy are retained by the state, the remainder being distributed to the 

counties, cities and towns according to statutory formula. In addition, Converse 

and Campbell county governments each impose a 1.0 percent general purpose 

local option tax and Campbell County imposes a 0.25 percent specific county 

option tax. Sales and tax revenues are vital for local governments. Statewide total 

sales and use tax revenues totaled $810.4 million in 2006. A direct accounting of 

sales and use taxes paid by coal mining firms is not available, however, it is likely 

substantial given the operating budgets of the mines. An internal analysis of the 

mine’s outlays yielded an estimated $3.5 million paid in sales and use taxes by 

the Antelope Mine in 2006. 

Local governments and school districts also rely heavily on ad valorem/ property 

taxes levied on the real property and value of production. Due to the location and 

configuration of the mine and actual mining areas, Converse and Campbell county 

governments as well as Converse County School District #1 and Campbell County 

School District #1 all benefit from operations of the Antelope Mine. The 

3-154 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

permanent facilities are primarily located in Converse County. Most of the active 

mining areas are presently located in Campbell County, but production has also 

occurred from reserves located in Converse County over time. 

Rising production and market values for oil and gas, and the increases in coal 

production tonnages have given rise to dramatic increases in the ad valorem tax 

bases of producing counties, particularly Campbell County. In 2005, Campbell 

County had an ad valorem tax base of $3.66 billion; more than 22 percent of the 

aggregate statewide assessed value on all real property and mineral production. 

Converse County had an assessed value of $432 million that same year, 14th 

among Wyoming’s 23 counties. The coal mining industry accounted for 59 

percent of Campbell County’s total assessed value and 23.5 percent of that in 

Converse County – see Table 3-15. The Antelope Mine accounted for a majority 

share of the coal-related value in Converse County and a substantial amount in 

Campbell County. The mine is a major taxpayer in both counties. 

Table 3-15. Contribution of Coal Mining to the 2005 Assessed Valuation of 

Converse and Campbell Counties. 

(1) (2) (3) (4) 

Total Assessed Coal Mining State Assessed Coal-related Share 

Value (Real Property) Minerals - Coal of the Total 

[(2) + (3)]/(1) 

Campbell County $ 3,660,527,493 $ 163,424,869 $ 1,995,307,606 59.0% 

Converse County $ 432,232,521 $ 16,355,912 $ 85,208,985 23.5% 

Sources: Wyoming Department of Revenue 2006 and Wyoming State Board of Equalization 2007. 

3.17.1.2 Environmental Consequences 

3.17.1.2.1 Proposed Action and Alternatives 1 and 2 

The federal and state revenues that would be generated by the leasing and mining 

of the West Antelope II LBA tract would depend on which alternative is selected 

and the eventual sales price of produced coal. For this analysis the average sales 

price of coal is assumed to be $9.01 per ton, equal to the forecasted price in 2009 

by the State of Wyoming’s Consensus Revenue Estimating Group (CREG) to 

estimate the state’s revenues from mineral severance and federal mineral royalty 

revenues over the next five years (Wyoming CREG 2006 and 2007). CREG 

assumes further increases of approximately 2 percent per year from 2009 through 

2012. Consequently, the $9.01 may be conservative. 

The projected federal and state revenues for the West Antelope II LBA tract 

presented in Table 3-16 are based on the coal production tonnages shown in Table 

3-1 and potential bonus bids on the leased recoverable coal ranging from 30 to 97 

cents per ton. Note that the projected revenues are based on the total tons of 

recoverable coal and hence are insensitive to changes in future annual production 

rates. If the West Antelope II LBA tract is leased and mined under the Proposed 

Action, the potential additional federal revenues would range from $581 to $724 

Draft EIS, Antelope Coal Company Lease Application 3-155 
 

3.0 Affected Environment and Environmental Consequences 

million. Under Alternatives 1 and 2, potential additional federal revenues range 

from approximately $613 million to $766 million. 

If the LBA tract is leased and mined under the Proposed Action, the potential 

incremental state and local revenues beyond those associated with No Action 

range from $780 to $924 million. Under Alternatives 1 and 2, potential additional 

state revenues range from about $825 to $977 million. 

The base of economic activity provided by wages and local purchases would 

continue for to up to 13 additional years, depending on the alternative and 

production rates. 

Table 3-16. Projected Major Revenue Impacts from Leasing the West Antelope II 

LBA Tract Under the Proposed Action or Alternatives 1 and 2.1 

No Action 

Alternative 

Item (Existing Mine) Proposed Action Alternatives 1 and 2 

State and Local + $ 780.4 to $ 924.3 $ 657.3 mm + $ 824.7 to $ 976.8 mm Revenues mm 

+ $ 580.5 to $ 724.3 Federal Revenues $ 473.7 mm + $ 613.4 to $ 765.5 mm 

mm 

12 yrs (36 mmtpy) 13 yrs (36 mmtpy) Increased Mine Life 0 yrs 10 yrs (42 mmtpy) 11 yrs (42 mmtpy) 

Additional Up to 25 (36 mmtpy) Up to 25 (36 mmtpy) 0 Employees Up to 40 (42 mmtpy) Up to 40 (42 mmtpy) 

1 Includes severance taxes, federal mineral royalties, and payments to the Abandoned Mined 

Lands and Black Lung Disability funds. State and local revenues include allowances for sales 

and use taxes on direct purchases by the mine and ad valorem/property taxes on real property 

and production. Revenues assume an average sales price of $9.01 per ton for coal. 

3.17.1.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and the coal included in the LBA tract under the Proposed Action 

(429.5 million tons of recoverable coal) or Alternatives 1 and 2 (453.9 million tons) 

would not be mined and the economic and fiscal benefits associated with mining 

that coal would not be realized by the state or federal government. Currently 

approved mining operations and associated economic benefits would continue on 

the existing Antelope Mine leases, but would cease between 10 and 13 years 

earlier than under the Proposed Action or Alternatives 1 and 2. Job losses, both 

those directly associated with the mine, as well as those secondary jobs supported 

by the mine, would occur following the cessation of operations. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3-156 Draft EIS, Antelope Coal Company Lease Application 
 

3.0 Affected Environment and Environmental Consequences 

3.17.2 Population 

3.17.2.1 Affected Environment 

Converse County had an estimated population of 12,866 in July 2006, an increase 

of 762 residents (6.3 percent) over its population of 12,104 in 2000. Statewide 

population grew by 4.2 percent during the same period – see Table 3-17. Douglas, 

the county seat and largest community in Converse County, had an estimated 

population of 5,581 in July 2005, compared to 5,288 residents in 2000. 

Table 3-17. Population Change, 2000 to 2006. 

Year Campbell County Converse County Total Study Area 

2000 33,698 12,104 45,802 

2003 36,381 12,326 48,707 

2006 38,934 12,866 51,800 

Change, 2000 - 06 5,236 762 5,998 

Percent Change 15.5% 6.3% 13.1% 

Source: U.S. Census Bureau (2006b). 

Campbell County’s population climbed from 33,698 in 2000 to an estimated 

38,934 in July 2006. This represents a 15.5 percent growth rate since 2000 

making Campbell County the second fastest growing county in the state. 

Campbell County’s population ranks it as the third most populous of Wyoming’s 

23 counties and Gillette’s 2005 population of 22,685 is the fourth largest city in 

the state, following Cheyenne, Casper, and Laramie (U.S. Census Bureau 2007). 

Based on the residency patterns of the mine’s employees and the concentration of 

mine service companies in the Gillette area, the majority of the mine’s current 

population likely reside in and are assimilated into the Douglas and Gillette 

communities. 

In comparison to the statewide population, the median age of Campbell County 

residents was substantially lower, while that of Converse County residents was 

higher. However, both counties had relatively fewer minority residents, a higher 

percentage of residents under 18, and had larger average household sizes – see 

Table 3-18. 

Table 3-18. Demographic Characteristics, 2000. 

Characteristic Wyoming 

Campbell

County Converse County 

Median Age 36.2 32.2 37.5 

Percent Residents < 18 Years Old 26.1 31.0 28.5 

Average Household Size (persons) 2.48 2.73 2.55 

Percent Minority Residents 7.9 3.9 5.3 

Source: PRB Coal Review Task1C Report (BLM 2005b) 

Draft EIS, Antelope Coal Company Lease Application 3-157 
3.0 Affected Environment and Environmental Consequences 

3.17.2.2 Environmental Consequences 

3.17.2.2.1 Proposed Action and Alternatives 1 and 2 

As indicated by Table 3-16, leasing and subsequently mining the LBA tract would 

extend the life of the Antelope Mine, and current employment at the mine, by up 

to 13 years. Relatively little change in employment is expected at the mine under 

the Proposed Action or Alternatives 1 and 2 (up to 40 additional jobs, depending 

on the annual production rates as discussed above). Consequently, leasing and 

mining of the LBA tract would not result in any noticeable incremental change in 

the study area population. Demands on public facilities and service would also 

see little change. 

3.17.2.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and the coal included in the LBA tract under the Proposed Action or 

Alternatives 1 and 2 would not be mined. Currently approved mining operations 

and associated employment levels would continue on the existing Antelope Mine 

leases. Without additional reserves, operations at the Antelope Mine would cease 

in about 2018, resulting in economic dislocations of the mine’s workforce, their 

households, and others supported indirectly by the mine’s operations. The net 

result would likely include population out-migration, with associated adverse 

impacts on local communities. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3.17.3 Employment 

3.17.3.1 Affected Environment 

Coal mining has changed substantially in recent times, with new technologies and 

higher capacity equipment major contributors to these changes. Local coal 

mining employment grew rapidly during the 1970s as more mines opened and 

production climbed. Between 1980 and 1998, overall production rose while 

employee numbers generally decreased or remained constant. The employment 

declines followed large industry capital investments in facilities and production 

equipment, the majority of which were aimed at increasing productivity (BLM 

2005b). Since 1998, direct employment in Powder River coal mines climbed as 

total annual production climbed by more than 45 percent (Wyoming Department 

of Employment 2007b). 

In 2006, the mining sector, which includes oil and gas workers, accounted for 

almost 28 percent of all employment in the two-county study area, nearly four 

times the statewide percentage. Approximately 4,800 people were directly 

3-158 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

employed by surface coal mines or coal contractors in Converse and Campbell 

counties, representing about 17 percent of total employment labor force (Wyoming 

Department of Employment 2004). 

3.17.3.2 Environmental Consequences 

3.17.3.2.1 Proposed Action and Alternatives 1 and 2 

Leasing and subsequently mining the West Antelope II LBA tract would extend the 

life of the Antelope Mine by 10 to 13 years, depending on annual production rates. 

As discussed above, limited increases in anticipated employment at the mine 

would occur under the Proposed Action and Alternatives 1 and 2. Consequently 

leasing the West Antelope II tract would also have limited effect on secondary 

employment in the region. Thus, there would be little net effect on the local labor 

market. The economic stability of the region would benefit by having the current 

Antelope Mine workforce living in the community and employed at the mine for up 

to 13 additional years. 

3.17.3.2.2 No Action Alternative 

Under the No Action Alternative, the coal included in the West Antelope II LBA 

tract under the Proposed Action or Alternatives 1 and 2 would not be mined. Mine 

life and existing employment levels would not be extended, though currently 

approved mining operations and associated employment would continue on the 

existing Antelope Mine leases. However, production would be completed and the 

direct jobs provided by the mine and those supported indirectly by its operations 

and the consumer expenditures of its workforce would be lost sooner than if 

leasing were to occur. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3.17.4 Housing 

3.17.4.1 Affected Environment 

The 2000 census tallied 5,669 housing units in Converse County, of which 82.8 

percent were occupied; 74 percent of which were owner-occupied and 26 percent 

renter-occupied. Of the 975 vacant units (17 percent), 316 were owned for 

seasonal or occasional use with 656 available for sale or rent, or otherwise vacant. 

The census counted 13,288 housing units in Campbell County, of which 12,207 

(92 percent) were occupied; 74 percent by owners. Of the 1,081 vacant units, 215 

were held for seasonal or occasional use and 866 were for sale, rent or vacant for 

other reasons (U.S. Census Bureau 2000). 

Population growth since 2000 has prompted new housing construction in the 

Draft EIS, Antelope Coal Company Lease Application 3-159 
3.0 Affected Environment and Environmental Consequences 

region. Net additions to the number of housing units from 2000 through 2005 

total 797 in Campbell County and 183 units in Converse County (Table 3-19). 

Building permits for 219 new units were issued by the City of Gillette in 2006. 

Construction has not kept pace with demand. As a consequence, vacancy rates 

are near record lows and housing prices have climbed. In the second half of 2006, 

vacancy rates of rental units were 0.4 percent (6 units) in Campbell County and 

1.4 percent (9 units) in Converse County (Wyoming Housing Database Partnership 

2007). 

Table 3-19. Total Housing Stock in 2000 and 2005. 

Year Campbell County Converse County 

2000 13,288 5,669 

2005 14,085 5,852 

Change 797 183 

Source: U.S. Census Bureau (2006a) 

A recent housing survey in Gillette yielded a vacancy rate of 0.2 percent for rental 

properties with many complexes having waiting lists of more than 50 people and 

wait times of up to nine months. That survey also estimated a vacancy rate of less 

than 10 percent among 11 mobile home parks (City of Gillette 2007). 

In the fourth quarter of 2006, average housing rental costs in Campbell County 

were $697 for a two-bedroom, unfurnished apartment, $283 for a single-wide 

mobile home lot and $975 for a two or three-bedroom single family home. In 

Converse County, the equivalent rates substantially lower; $515 for an apartment, 

$152 for a mobile home lot and $545 for a single family home (Wyoming 

Department of Administration and Information 2007). 

The average selling price of homes in Converse County in 2005, based on 195 

sales, was $147,560, nearly 29 percent higher than the preceding year. In 

Campbell County the average sales price, based on 458 sales, was $185,874. 

That average represents a 7 percent increase over that in 2004 and fifth highest 

among Wyoming counties (Wyoming Housing Database Partnership 2007). 

In addition to permanent housing, there is a substantial inventory of temporary or 

transient housing in the study area. Such housing includes hotels or motels, 

campgrounds, and possibly mobile home parks. Given the tight housing market 

in Gillette, some such units are reportedly being used for longer-term occupancy 

by workers and families waiting for traditional housing to become available 

(Langston 2005). 

There are 17 motels in Gillette with 1,346 guest rooms and a 27-room motel in 

Wright. Gillette has two year-round commercial campgrounds with 150 hookups 

for RVs plus tent areas (Gillette Convention and Visitor’s Bureau 2004). There are 

7 motels with a total of 364 rooms in Douglas, along with three commercial 

campgrounds with 119 trailer/RV spaces (Wyoming Travel and Tourism Division 

2007). 

3-160 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

3.17.4.2 Environmental Consequences 

3.17.4.2.1 Proposed Action and Alternatives 1 and 2 

As discussed above, limited change in direct employment at the Antelope Mine is 

anticipated in conjunction with the leasing and mining of the West Antelope II LBA 

tract under the Proposed Action or Alternatives 1 and 2. Consequently, no 

substantial population influx and additional demand on housing resources is 

expected. Furthermore, any new employees would most likely be attracted to the 

Douglas area, the principal community of residence for employees at the Antelope 

Mine. Housing is relatively more available and affordable in the Douglas area. 

3.17.4.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and the coal included in the West Antelope II LBA tract under the 

Proposed Action or Alternatives 1 and 2 would not be mined. Housing markets 

would not be affected by any additional employment at the Antelope Mine. 

Currently approved mining operations and associated employment levels would 

continue on the existing mine leases. When the existing leases are mined out, 

mining operations would cease, likely triggering population out-migration from the 

area and adversely affecting housing markets. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3.17.5 Local Government Facilities and Services 

3.17.5.1 Affected Environment 

The availability of revenues generated by mineral production has helped local 

government facilities and services address growing demands for public services. 

Current facilities and services are generally adequate for the current population, 

although several service providers are engaged in expansion plans to 

accommodate future growth and improve service delivery. 

Converse County School District #1 and Campbell County School District #1 are 

the districts most directly affected by the Antelope mine’s operations. Following 

steady declines between 1996 and 2003, enrollment in the Converse County 

School District #1 has stabilized at about 1,580 over the past three years. Total 

enrollment in Campbell County School District #1 declined by more than 500 

students between 1998 and 2004, but then climbed by nearly 140 students in 

2005 in response to economic and population growth in the county. In terms of 

enrollment, it is the third largest district in Wyoming (Wyoming Department of 

Education 2007). 

Converse County School District #1 operates eight schools; six elementary, one 

Draft EIS, Antelope Coal Company Lease Application 3-161 
3.0 Affected Environment and Environmental Consequences 

junior high, and one high school. Campbell County School District #1 facilities 

include 15 elementary schools, two junior high schools, and two high schools (one 

with two campuses in Gillette). Converse County School District #1’s facilities are 

adequate in terms of capacity for its present enrollment, however it has initiated 

planning and design for a new elementary school to accommodate recent and 

expected enrollment and is planning for the construction of new warehouse and 

transportation support facilities, access road improvements for schools, and 

systems maintenance and upgrades (Converse County School District #1 2007). 

The Campbell County School District is involved in a major five-year plan to 

replace several schools, modernize others and complete major systems 

maintenance and upgrades. The complete plan is budgeted at over $57 million. 

Plans for the next two years include completion of a new elementary school and 

additions to a high school (Wyoming School Facilities Commission 2007). 

The Converse County and Campbell County Sheriff’s departments provide police 

protection throughout their respective counties. In addition to general law 

enforcement, the Sheriff’s staff provides court security, detention facilities, and 

animal control. For the 2004 fiscal year, the Campbell County Sheriff budgeted 

for 60 law enforcement employees. Recent improvements have increased the 

Campbell County detention facility to 128 beds, which includes separate modules 

for women and juveniles (BLM 2005b). The Converse County Sheriff includes 12 

patrol deputies, plus additional staff in the communications and detention 

divisions. 

Fire suppression throughout Campbell County is provided by the Campbell 

County Fire Department, which is governed by a city-county joint powers board 

(Vonsik 2005). The department maintains four stations in Gillette and six 

dispersed throughout the county. Fire suppression in rural Converse County is 

provided by the Converse County Rural Fire Control Association. The Douglas 

Volunteer Fire Department covers the city of Douglas. The Antelope Mine 

maintains equipment and trained staff to fight fires on mine property. 

The primary medical care facilities serving the region are the Memorial Hospital of 

Converse County, a 25-bed acute care hospital located in Douglas, and the 

Campbell County Memorial Hospital, a 90-bed acute care hospital, located in 

Gillette. The Campbell County Memorial Hospital operates the Wright Clinic, a 

satellite clinic, located approximately 18 miles from the Antelope Mine. The clinic 

is staffed with a full-time, family practice physician. 

Ambulance service for Campbell County is provided by the hospital, which has a 

24-hour emergency service capability. The Campbell County Fire Department 

provides first responder service to emergency calls, but transport is the 

responsibility of the hospital affiliated ambulance service (Vonsik 2005). 

Emergency medical transport in Converse County is provided by an ambulance 

service operated by the Memorial Hospital of Converse County. The service 

presently maintains and operates three ambulances with a paid staff. Response is 

augmented by the Douglas Volunteer Fire Department (Leon 2007). 

3-162 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

The principal water and wastewater utilities are operated by the City of Douglas, 

City of Gillette and by the Wright Water and Sewer District. The City of Douglas 

has three water sources. The Little Boxelder Spring is a high-quality gravity-fed 

source located some 18 miles west of Douglas. This source provides up to 2 

million gallons per day and meets the water demands in the fall and winter. The 

second water source is a 1.5 million gpd Sheep Mountain Well. This well came 

into service in the fall of 1994 and supplements the city water supply during peak 

demand and allows for reduced usage of the more costly treated water. The water 

treatment plant treats up to 2.5 million gpd of North Platte River water during the 

summer and is used primarily during heavy irrigation periods. It was not 

designed to service the community in winter, but can be brought on-line under 

emergency circumstances. 

Douglas has multiple water storage facilities with a combined capacity of about 6 

million gallons. The current water system is designed to accommodate a 

population of 10,000 people (Sweeney 2004). However, as a result of drought, the 

city implemented watering restrictions during summer months of the last four 

years. The construction of a new water treatment plant, scheduled for completion 

in 2008, may ease the need for water restrictions, but continued drought 

conditions could also result in a continuation of these restrictions (Fitzhugh 

2007). 

The City of Gillette water system has ample capacity for its service area during 

most of the year, however, the system operates close to capacity during the peak 

demand months of June, July and August. In the short term, the city intends to 

add several wells to the system to augment water supply during peak months. 

The city is also conducting a Level II Water Study to identify longer term solutions 

to its water supply problems. The City implemented voluntary conservation 

measures during the summer of 2007 and is considering changes in the water 

rate structure to reduce peak period consumption. The Level II study is likely to 

identify well field, transmission, pumping station and treatment additions to the 

current system. If approved by the city and if funding is secured, these 

improvements are anticipated to come on line during the next three to five years 

(Petersen 2007). 

Gillette’s sewer treatment system was designed for a service population of 

approximately 35,000 and improvements begun in the fall of 2004 were designed 

to increase treatment capacity to accommodate a projected population of 41,000. 

Currently, the system serves an estimated 25,000 people in the city and 

surrounding areas. 

3.17.5.2 Environmental Consequences 

3.17.5.2.1 Proposed Action and Alternatives 1 and 2 

As discussed above, employment at the mine would not increase substantially 

under the Proposed Action and Alternatives 1 and 2. No additional demands on 

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3.0 Affected Environment and Environmental Consequences 

the existing community facilities or services in the county would be expected 

because little or no influx of new residents would be needed to fill new jobs. It is 

likely that the demand for public facilities and services would be satisfied by the 

existing facilities and services currently in place in Converse and Campbell 

Counties. 

3.17.5.2.2 No Action Alternative 

Under the No Action Alternative, the West Antelope II coal lease application would 

be rejected and the coal included in the West Antelope II LBA tract under the 

Proposed Action or Alternatives 1 and 2 would not be mined. Local government 

facilities and services would not be affected by any additional employment or 

associated population growth associated with the Antelope Mine. Currently 

approved mining operations and associated employment levels would continue on 

the existing Antelope Mine leases. 

As discussed in Section 2.2, a decision to reject the West Antelope II lease 

application at this time would not preclude an application to lease the tract in the 

future. 

3.17.6 Social Setting 

3.17.6.1 Affected Environment 

The social setting for coal development in the PRB, summarized in Section 

4.2.12.9, is described in the Task IC Report for the PRB Coal Review (BLM 2005b). 

That report emphasizes Campbell County and its communities as the nucleus for 

coal development in the PRB. Converse County and the City of Douglas, also 

discussed in the Task 1C Report, are also affected by the Antelope Mine which is 

located partly within Converse County and is a major contributor to the county 

tax base. The Douglas area is home to 70 percent of the Antelope Mine workforce. 

The Antelope Mine has been in production since 1985 and the mine and its 

employees contribute to the social and economic stability of Converse County and 

the City of Douglas. 

3.17.6.2 Environmental Consequences 

3.17.6.2.1 Proposed Action and Alternatives 1 and 2 

As discussed above, employment at the mine is not anticipated to increase 

substantially under the Proposed Action or Alternatives 1 and 2. Consequently, 

little or no change in the social setting of Campbell or Converse counties or the 

communities of Gillette, Wright or Douglas would be anticipated under these 

alternatives. 

3-164 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

3.17.6.2.2 No Action Alternative 

Implementation of the No Action Alternative would result in the eventual loss of 

approximately 430 relatively high paying mining jobs in the PRB. An estimated 70 

percent of those losses (315 jobs) would occur in Converse County and the 

community of Douglas. Loss of the Antelope Mine-related economic activity and 

tax revenues are described in preceding sections. These losses would likely result 

in a disruption in the social and economic stability of Converse County and the 

City of Douglas and some population relocation, unless Antelope Mine employees 

were able to find comparable employment within commuting distance of Douglas. 

Social effects of the No Action Alternative on Campbell County, the City of Gillette 

and the Town of Wright would be less substantial, because of the fewer number of 

employees involved and the potential for those employees to find other jobs in 

mines and other energy industries in Campbell County. 

3.17.7 Environmental Justice 

3.17.7.1 Affected Environment 

Environmental Justice issues are concerned with actions that unequally impact a 

given segment of society either as a result of physical location, perception, design, 

noise, or other factors. On February 11, 1994, Executive Order 12898, “Federal 

Action to Address Environmental Justice in Minority Populations and Low-Income 

Populations”, was published in the Federal Register (59 FR 7629). The Executive 

Order requires federal agencies to identify and address disproportionately high 

and adverse human health or environmental effects of their programs, policies, 

and activities on minority populations and low-income populations (defined as 

those living below the poverty level). The Executive Order makes it clear that its 

provisions apply fully to Native American populations and Native American tribes, 

specifically to effects on tribal lands, treaty rights, trust responsibilities, and the 

health and environment of Native American communities. 

Communities within Campbell and Converse Counties, entities with interests in 

the area, and individuals with ties to the area all may have concerns about the 

presence of surface coal mines in the area. Environmental Justice concerns are 

usually directly associated with impacts on the natural and physical environment, 

but these impacts are likely to be interrelated with social and economic impacts as 

well. Native American access to cultural and religious sites may fall under the 

umbrella of Environmental Justice concerns if the sites are on tribal lands or 

access to a specific location has been granted by treaty right. 

Compliance with Executive Order 12898 concerning Environmental Justice was 

accomplished through opportunities for the public to receive information on this 

EIS in conjunction with consultation and coordination described in Section 1.6 of 

this document. This EIS and contributing socioeconomic analysis provide a 

consideration of the impacts with regard to disproportionately high and adverse 

impacts on minority and/or low-income groups, including Native Americans. 

Draft EIS, Antelope Coal Company Lease Application 3-165 
3.0 Affected Environment and Environmental Consequences 

3.17.7.2 Environmental Consequences 

3.17.7.2.1 Proposed Action and Alternatives 1 and 2 

Economic and demographic data indicate that neither minority populations nor 

people living at or below the poverty level make up “meaningfully greater 

increment” of the total population in Gillette, Wright, Campbell County, Douglas 

or Converse County than they do in the state as a whole. Also, the Native 

American population is smaller than in the state as a whole and there are no 

known Native American sacred sites on or near the study area for the West 

Antelope II LBA tract. Furthermore, there are few residences in close proximity to 

the current mine boundary or proposed West Antelope II LBA tract. 

Consequently, implementation of the Proposed Action or Alternatives 1 or 2 would 

not adversely affect the environmental justice considerations in the area. 

3.17.7.2.2 No Action Alternative 

Economic and demographic data indicate that neither minority populations nor 

people living at or below the poverty level make up “meaningfully greater 

increment” of the total population in Gillette, Douglas or the two counties than 

they do in the state as a whole. Also, the Native American population is smaller 

than in the state as a whole and there are no known Native American sacred sites 

on or near the existing Antelope Mine. Furthermore, there are few residences in 

close proximity to the existing mine boundary. Consequently, the No Action 

Alternative would not adversely affect the environmental justice considerations in 

the area. 

3.17.8 Regulatory Compliance, Mitigation and Monitoring 

Surface coal mines are required to pay royalty and other taxes and fees as 

required by federal, state, and local regulations. The BLM compares the amount 

of coal reported as produced with the estimated amount of coal in the ground to 

verify that royalties are paid on all of the coal that is mined. 

3.17.9 Residual Effects 

No socioeconomic residual impacts are expected. 

3.18 Coal Mining and Coal-Fired Power Plant Related Emissions and ByProducts 

As discussed in Chapter 1, BLM does not authorize mining by issuing a lease for 

federal coal, but the impacts of mining the coal are considered in this EIS because 

it is a logical consequence of issuing a maintenance lease to an existing mine. The 

use of the coal after it is mined is also not determined at the time of leasing, 

however, almost all of the coal that is currently being mined in the Wyoming PRB 

is being used by coal-fired power plants to generate electricity. As a result, a 

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3.0 Affected Environment and Environmental Consequences 

discussion of emissions and by-products that are generated by burning coal to 

produce electricity is included in this section of the EIS. 

As discussed in Chapter 2, under the currently approved mining plan, which 

represents the No Action Alternative, ACC anticipates that the Antelope Mine 

would mine its remaining estimated 394.3 million tons of recoverable coal reserves 

in eleven years at an average annual production rate of approximately 36 million 

tons. Under the Proposed Action, ACC estimates that the life of the mine would be 

extended by about 12 additional years at an average annual coal production rate 

of approximately 36 million tons. If the average annual production rate increases 

to 42 million tons, which is the maximum rate allowed by the current air quality 

permit, the life of the mine would be extended by ten additional years under the 

Proposed Action. Under Alternatives 1 and 2, if the entire BLM study area is 

leased, ACC estimates the life of the mine would be extended by 11 to 13 years. 

3.18.1 Global Warming and Coal Mining and Coal-Fired Power Plant Related 

Greenhouse Gas Emissions 

Burning coal to produce power produces greenhouse gases, which are believed to 

be a contributing factor in global warming. The Fourth Assessment Report of the 

Intergovernmental Panel on Climate Change or IPCC is now available online at 

http://www.ipcc.ch. The final part, The Synthesis Report (Bernstein et al. 2007), 

which was released in preliminary form on November 17, 2007, summarizes the 

results of the assessment carried out by the three Working Groups of the IPCC. 

The observations and projections addressed in The Synthesis Report include: 

•	 “Warming of the climate system is unequivocal, as is now evident from 

observations of increases in global average air and ocean temperature, 

widespread melting of snow and ice, and rising global average sea level.” 

•	 “Observational evidence from all continents and most oceans shows that 

many natural systems are being affected by regional climate changes, 

particularly temperature increases.” 

•	 “Global atmospheric concentrations of carbon dioxide (CO2), methane (CH4), 

and nitrous oxide (N2O) have increased markedly as a result of human 

activities since 1750 and now far exceed pre-industrial values determined 

from ice cores spanning many thousands of years.” 

•	 “Most of the observed increase in globally-averaged temperatures since the 

mid-20th century is very likely due to the observed increase in 

anthropogenic greenhouse gas concentrations. It is likely there has been 

significant anthropogenic warming over the past 50 years averaged over 

each continent (except Antarctica).” 

•	 “There is high agreement and much evidence that with current climate 

change mitigation policies and related sustainable development practices, 

global greenhouse gas emission will continue to grow over the next few 

decades.” 

•	 “Continued greenhouse gas emissions at or above current rates would 

cause further warming and induce many changes in the global climate 

Draft EIS, Antelope Coal Company Lease Application 3-167 
3.0 Affected Environment and Environmental Consequences 

system during the 21st century that would be very likely to be larger than 

those observed during the 20th century.” 

•	 “There is high confidence that by mid-century, annual river runoff and 

water availability are projected to increase at high latitudes and in some 

tropical wet areas and decrease in some dry regions in the mid-latitudes 

and tropics. There is also high confidence that many semi-arid areas (e.g., 

Mediterranean Basin, western United States, southern Africa and northeast 

Brazil) will suffer a decrease in water resources due to climate change.” 

•	 “Anthropogenic warming and sea level rise would continue for centuries due 

to the time scales associated with climate processes and feedbacks, even if 

greenhouse gas concentrations were to be stabilized.” 

•	 “Anthropogenic warming and sea level rise could lead to some impacts that 

are abrupt or irreversible, depending upon the rate and magnitude of the 

climate change.” 

•	 “There is high agreement and much evidence that all stabilization levels 

assessed can be achieved by deployment of a portfolio of technologies that 

are either currently available or expected to be commercialized in coming 

decades, assuming appropriate and effective incentives are in place for their 

development, acquisition, deployment and diffusion and addressing related 

barriers.” 

Coal-fired power plant emissions include carbon dioxide (CO2), which is the 

principal anthropomorphic greenhouse gas. According to the Energy Information 

Administration (U.S. Department of Energy 2007a and 2007b): 

•	 CO2 emissions represent about 84 percent of the total U.S. greenhouse gas 

emissions. 

•	 Estimated CO2 emissions in the U.S. totaled 5,934.2 million metric tons in 

2006, which was a 1.8 percent decrease from 2005. 

•	 Estimated CO2 emissions from the electric power sector totaled 2,343.9 

million metric tons, or about 39.5 percent of total U.S. energy-related CO2 

emissions in 2006. 

•	 Estimated CO2 emissions from coal electric power generation in 2005 

totaled 1,937.9 million metric tons or about 33 percent of total U.S. energyrelated CO2 emissions in 2006. 

•	 Coal production from the Wyoming PRB represented approximately 42 

percent of the coal used for power generation in 2006, which means that 

Wyoming PRB surface coal mines were responsible for about 13.9 percent of 

the estimated U.S. CO2 emissions in 2006. 

There are methods of generating electricity that result in fewer greenhouse gas 

emissions than burning coal, including natural gas, nuclear, hydroelectric, solar, 

wind, and geothermal resources. However, coal-burning power plants currently 

supply about 50 percent of the electric power generated in the U.S. The demand 

for power is increasing in the U.S. and throughout the world. According to a 

recent report by the North American Electric Reliability Council, peak demand for 

electricity in the U.S. is expected to double in the next 22 years (Associated Press 

3-168	 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

2007). Many developing countries, including China and India, are also relying 

heavily on coal to meet their rapidly increasing power demands as coal is cheaper 

and more available than other sources of electrical generation. 

Technologies for producing cleaner, more efficient, and more reliable power from 

coal are currently available, although not yet commercially established. These 

include advanced pulverized coal, circulating fluidized bed, and integrated 

gasification combined cycle (IGCC) technologies. One project that is proceeding, 

the FutureGen project, proposes to produce electricity by turning coal into gas, 

remove impurities, including CO2, and then sequester the CO2 underground. A 

site in southeastern Illinois was recently selected for the plant, which has a goal of 

being operational in 2012 (Biello 2007). 

A number of bills were introduced in the U.S. Congress in 2007 related to global 

climate change. The Lieberman-Warner Climate Security Act, which was 

introduced in October, 2007 by Senators Joseph I. Lieberman (ID-CT) and John 

W. Warner (R-VA), would establish a cap-and-trade program within the U.S. 

requiring a 70 percent reduction in greenhouse gas emissions from covered 

sources, which represent over 80 percent of total U.S. emissions. It was voted out 

of the Senate Environment and Public Works Committee in December, 2007 

(http://www.pewclimate.org, accessed 12/21/2007). A number of U.S. financial 

and corporate interests have acknowledged that enactment of federal legislation 

limiting the emissions of CO2 and other greenhouse gases seems likely (National 

Association of Regulatory Utility Commissioners 2007). Uncertainty about these 

anticipated CO2 emissions limits and carbon capture and sequestration 

regulations has caused proponents of some projects that propose to use both 

existing and emerging technologies to produce electricity from coal to cancel or 

delay their proposed projects (Casper Star Tribune 2007b, 2007c). 

U.S. coal production increased from 1,029.1 million tons in 1990, when the 

Powder River Federal Coal Regions was decertified, to 1,161.4 million tons in 

2006, an increase of 12.9 percent (U.S. Department of Energy 2007c). Wyoming 

coal production increased from 184.0 million tons in 1990 to 444.9 million tons in 

2006, an increase of 242 percent (Wyoming State Mine Inspector 2006). The 

share of electric power generated by burning coal was consistently around 50 

percent during that time frame and the percentage of total U.S. CO2 emissions 

related to coal consumption was consistently around 36 percent during that time 

frame. The percentage of U.S. CO2 emissions related to the coal electric power 

sector increased from about 31 percent in 1990 to about 33 percent in 2006 (U.S. 

Department of Energy 2007a and 2007b). 

The Antelope Mine produced 33.9 million tons of coal in 2006, which represents 

about 7.8 percent of the coal produced in the Wyoming PRB in 2006, or about 1.1 

percent of the estimated U.S. CO2 emissions in 2006. Under the No Action 

Alternative, CO2 emissions attributable to burning coal produced by the Antelope 

Mine would be extended at about this level for approximately eleven years, or until 

about 2018, while the mine recovers its remaining estimated 394.3 million tons of 

Draft EIS, Antelope Coal Company Lease Application 3-169 
3.0 Affected Environment and Environmental Consequences 

currently leased coal reserves. It is likely that, by that time, regulations limiting 

CO2 emissions will be in place and, potentially, projects utilizing the emerging 

technologies to reduce and/or sequester CO2 emissions would be more 

established. 

Under the Proposed Action and Alternatives 1 and 2, the Antelope Mine 

anticipates producing the coal included in the West Antelope LBA tract at 

currently permitted levels using existing production and transportation facilities, 

which would extend CO2 emissions related to burning coal from the Antelope Mine 

for up to 13 additional years beyond 2018. It is not possible to project the level of 

CO2 emissions that burning the coal in the West Antelope II LBA tract would 

produce due to the uncertainties about what emission limits will be in place at 

that time or where and how the coal in the West Antelope LBA tract would be used 

after it is mined. It is not likely that selection of the No Action Alternative would 

result in a decrease of U.S. CO2 emissions attributable to coal-burning power 

plants in the longer term because there are multiple other sources of coal that 

could supply the demand for coal beyond the time that the Antelope Mine 

completes recovery of the coal in its existing leases. 

CBNG, which is composed primarily of methane, another greenhouse gas, is 

released into the atmosphere when coal is mined. According to the U.S. Energy 

Information Administration (U.S. Department of Energy 2007a and 2007b): 

•	 U.S. anthropogenic methane emissions totaled 605 million metric tons CO2 

equivalent in 2006. 

•	 U.S. 2006 methane emissions from coal mining were estimated at 64.7 

million metric tons CO2 equivalent, which represents approximately 10.7 

percent of the U.S. total anthropogenic methane emissions in 2006. 

•	 Surface coal mining operations in the U.S. were estimated to be responsible 

for methane emissions of about 14.2 million metric tons of CO2 equivalent 

in 2006, which represents about 2.35 percent of the estimated U.S. 

anthropogenic methane emissions in 2006, and about 22 percent of the 

estimated methane emissions attributed to coal mining of all types. 

•	 The Wyoming PRB produced approximately 53.7 percent of the coal mined 

in the U.S. in 2006 using surface mining techniques, which means that 

Wyoming PRB surface coal mines were responsible for approximately 1.26 

percent of the estimated U.S. anthropomorphic methane emissions in 2006. 

Since 1990, when BLM began leasing using the lease by application process, total 

U.S. anthropogenic methane emissions declined from 708.4 million metric tons 

CO2 equivalent to 605.1 million metric tons CO2 equivalent in 2006. Total coal 

mining related emissions declined from 97.7 million metric tons CO2 equivalent to 

64.7 million metric tons CO2 equivalent during the same time period. The Energy 

Information Administration (U.S. Department of Energy 2007b) attributes the 

overall decrease in coal mine emissions of methane since 1990 to the fact that the 

coal production increases during that time had been largely from surface coal 

mines that produce relatively little methane. 

3-170 Draft EIS, Antelope Coal Company Lease Application 
3.0 Affected Environment and Environmental Consequences 

CBNG is currently being commercially produced by oil and gas operators from 

wells within and near the West Antelope II LBA tract. CBNG that is not recovered 

prior to mining would be vented to the atmosphere during the mining process. 

Selection of the No Action Alternative would potentially allow more complete 

recovery of the CBNG from the West Antelope II LBA tract in the short term (ten 

years), during the time that the mine’s currently leased coal is being recovered. 

However, BLM’s analysis suggests that a large portion of the CBNG resources that 

are currently present on the tract would be recovered prior to mining under the 

Proposed Action or Alternatives 1 or 2. Selection of the No Action Alternative 

would not be likely to directly decrease U.S. methane emissions attributable to 

coal mining in the long term because there are multiple other sources of coal that 

could supply the coal demand beyond the time that the Antelope Mine recovers 

the coal in its existing leases. 

3.18.2 Other Coal Mining and Coal-Fired Power Plant Related By-Products 

Burning coal to produce power also releases mercury into the atmosphere. 

Atmospheric mercury settles into water or onto land where it can be washed into 

the water. Certain microorganisms can change it into methyl mercury, which is a 

highly toxic mercury compound that builds up in fish and shellfish when they 

feed. There are adverse health effects to humans and other animals that consume 

these fish and shellfish. Research has shown that most people’s fish consumption 

does not cause a health concern, but high levels of methyl mercury in the 

bloodstream of unborn babies and young children may harm the developing 

nervous systems of those children (EPA 2006). 

According to the EPA, coal-fired power plants account for more than 40 percent of 

all U.S. human-caused mercury emissions. However, these emissions contribute 

little to the global mercury pool. EPA estimated that mercury emissions from U.S. 

coal-fired power plants account for about one percent of the global total (EPA 

2007e). Coal production from the Wyoming PRB represented approximately 42 

percent of the coal used for power generation in 2006, which would represent 

about 0.4 percent of the global mercury emissions. The Antelope Mine produced 

about 7.9 percent of the coal produced in the Wyoming PRB in 2006, which would 

represent about .03 percent of the global mercury emissions. 

Under the No Action Alternative, mercury emissions attributable to burning coal 

produced by the Antelope Mine would be extended at about current levels for 

approximately eleven years, or until about 2018, while the mine recovers its 

remaining estimated 394.3 million tons of currently leased coal reserves. Under 

the Proposed Action or Alternatives 1 or 2, the Antelope Mine’s contributions to 

global mercury emissions would be extended from 10 to 13 additional years 

beyond 2018. As discussed above, uncertainties about what emissions limits will 

be in place at that time and where and how the coal in the West Antelope II LBA 

tract would be used after it is mined make the level of mercury emissions that 

burning the coal in the West Antelope II LBA tract would produce unpredictable at 

this time. 

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3.0 Affected Environment and Environmental Consequences 

Burning coal in electric utility boilers generates residual materials which are 

referred to as coal combustion residues. These residues include non-combustible 

materials left in the furnaces and ash that is carried up the smokestacks and 

collected by air pollution control technologies. Coal combustion residues can 

contain a variety of metals and other elements, including arsenic, cadmium, and 

lead. The use of air pollution control equipment at power plants has resulted in 

fewer emissions but also an increase in the amount of solid residues. 

In the past, coal combustion residues have generally been recycled or disposed of 

in landfills or surface impoundments. More recently, these residues have been 

disposed of in mines. There are risks of contamination of drinking water supplies 

and surface water bodies by coal combustion residues, particularly when they are 

disposed of in mines (National Academy of Science 2006, EPA 2002). The EPA is 

evaluating management options for solid wastes from coal combustion, including 

whether current management practices pose risks to human health or ecological 

receptors. A draft report, dated August 6, 2007, prepared for the EPA Office of 

Solid Waste, and entitled “Human and Ecological Risk Assessment of Coal 

Combustion Wastes”, is available at http://www.earthjustice.org/library; however, 

the report is labeled as a draft document which is not to be cited or quoted. 

As discussed above, the Antelope Mine produced about 7.9 percent of the coal 

produced in the Wyoming PRB in 2006. Coal produced by the Antelope Mine prior 

to this time has been shipped to coal-burning power plants around the country. It 

has not been burned by local power plants and, therefore, coal combustion 

residues produced from burning the Antelope Mine coal were not disposed of at 

the mine. Under the No Action Alternative, production of coal combustion residue 

attributable to burning coal from the Antelope Mine would be extended at about 

current levels for approximately eleven years, or until about 2018, while the mine 

recovers its remaining estimated 394.3 million tons of currently leased coal 

reserves. Under the Proposed Action or Alternatives 1 or 2, coal combustion 

residue related to burning coal mined at the Antelope Mine would be extended 

from 10 to 13 additional years beyond 2018. As discussed above, uncertainties 

about future regulatory requirements and where and how the coal in the West 

Antelope II LBA Tract would be used after it is mined do not make it possible to 

project what the impacts of disposing of coal combustion residues produced by 

burning the coal in the West Antelope II LBA Tract would be. 

3.19 The Relationship Between Local Short-term Uses of Man’s 

Environment and the Maintenance and Enhancement of Long-term 

Productivity 

The NEPA regulations at 40 CFR 1502.16 require a discussion of the “relationship 

between short-term uses of man’s environment and the maintenance and 

enhancement of long-term productivity” as part of an EIS. This requirement is 

duplicated in the BLM NEPA Handbook Chapter V, Section B.2.a.(3) and C.3.h.(2), 

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3.0 Affected Environment and Environmental Consequences 

If the West Antelope II LBA tract is leased, almost all components of the present 

ecological system, which have developed over a long period of time, would be 

modified as the coal is mined. In the long term, following reclamation, the land 

surface would be topographically lower and, although the reclaimed surface would 

resemble original contours, it would lack some of the original diversity of 

geometric form. 

Soils and vegetation would be disturbed and the associated grazing and wildlife 

habitat that the West Antelope II LBA tract currently provides would be lost in the 

short term, during mining and reclamation. During mining of the LBA tract, there 

would be a loss of native vegetation from 4,108.6 acres (Proposed Action) up to a 

maximum of 6,309.2 acres (Alternatives 1 and 2). This disturbance would occur 

incrementally over a period of years. Soils would be replaced and vegetation 

would be restored, as required by the mining plan (see Sections 3.8 and 3.9). In 

the long term, the reclaimed lands would provide equivalent or better forage 

production capacity for domestic livestock. This would be required before the 

performance bond is released. Long-term productivity would depend primarily on 

post-mining range management practices which, to a large extent, would be 

controlled by the private landowners. 

Mining would disturb pronghorn and mule deer habitat. As discussed in Section 

3.10.5, potential sage-grouse habitat is scarce throughout the general project 

area. There would be loss and displacement of wildlife in the short term but, 

based on monitoring of previously reclaimed lands, it is anticipated that the 

reclaimed lands would provide habitat that would support a diversity of wildlife 

species similar to premining conditions in the long term. The diversity of species 

found in undisturbed rangeland would not be completely restored on the leased 

lands for an estimated 50 years after the initiation of disturbance. 

Re-establishment of mature sagebrush habitat, which is crucial for pronghorn and 

sage-grouse, would be expected to take even longer. 

If the West Antelope II LBA tract is leased and mined, groundwater quality would 

be different from pre-mining conditions after reclamation. The water quality would 

remain adequate for livestock and wildlife. Depth to groundwater would increase 

in an area extending further to the west and south of the existing mine area. The 

water levels in the coal aquifer should return to premining levels at some time 

after mining has ceased because recharge areas would not be disturbed when 

recovering the coal in the LBA tract. 

Mining operations and associated activities would degrade the air quality and 

visual resources of the area on a short-term basis. Following coal removal, 

removal of surface facilities, and completion of reclamation, there would be no 

long-term impact on air quality. The long-term impact on visual resources would 

be minor. 

Short-term impacts to recreation values may occur from reduction in big game 

populations due to habitat disturbance and reduction in access to some public 

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3.0 Affected Environment and Environmental Consequences 

lands. These changes would primarily impact hunting in the lease area. However, 

because reclamation would result in a wildlife habitat similar to that which 

presently exists and access to any public lands affected by mining would be 

restored, there should be no long-term adverse impacts on recreation. 

The short- and long-term economy of the region would be enhanced as a result of 

the Proposed Action and Alternatives 1 and 2. The Proposed Action and 

Alternatives 1 and 2 would extend the life of the Antelope Mine from 11 to 14 

years (see Table 2-2). 

3.20 Irreversible and Irretrievable Commitments of Resources 

The major commitment of resources would be the mining and consumption of 

395.3 million tons (Proposed Action) up to a maximum of 487.6 million tons 

(Alternatives 1 and 2) of coal to be used for electrical power generation. CBNG 

that is not recovered prior to mining would also be irreversibly and irretrievably 

lost (see additional discussion of the impacts of venting CBNG to the atmosphere 

in Section 3.18). It is estimated that one to two percent of the energy produced 

would be required to mine the coal, and this energy would also be irretrievably 

lost. 

The quality of topsoil on approximately 4,109.6 acres (Proposed Action) up to a 

maximum of approximately 6,309.2 acres (Alternatives 1 and 2) would be 

irreversibly changed. Soil formation processes, although continuing, would be 

irreversibly altered during mining related activities. Newly formed soil material 

would be unlike that in the natural landscape. 

Direct and indirect wildlife mortalities caused by mining operations or associated 

activity would be an irreversible loss. 

Loss of life may conceivably occur due to the mining operations and vehicular and 

train traffic. On the basis of surface coal mine accident rates in Wyoming as 

determined by MSHA (1997) for the 10-year period 1987-1996, fatal accidents 

(excluding contractors) occurred at the rate of 0.003 per 200,000 man-hours 

worked. Disabling (lost time) injuries occurred at the rate of 1.46 per 200,000 

man-hours worked. Any injury or loss of life would be an irretrievable 

commitment of human resources. 

Disturbance of all known historic and prehistoric sites on the mine area would be 

mitigated to the maximum extent possible. However, accidental destruction of 

presently unknown archeological or paleontological values would be irreversible 

and irretrievable. 

3-174 Draft EIS, Antelope Coal Company Lease Application