FINAL

Environmental Impact Statement for the 

Wright Area Coal Lease Applications

July 2010

BLM

Wyoming State Office – High Plains District

Volume 1 of 2

Chapters 1 - 4

West Loadout Facilities

Black Thunder Mine, Wyoming

Elk on Reclaimed Rangeland

Jacobs Ranch Mine, Wyoming

Elk on Reclaimed Rangeland

Black Thunder Mine, Wyoming

Loadout Facilities in Porcupine Creek Valley

North Antelope Rochelle Mine, Wyoming
BLM/WY/PL-10/022+1320

The BLM manages more land – 253 million acres – than any other Federal agency. This land, 

known as the National System of Public Lands, is primarily located in 12 Western States, 

including Alaska. The Bureau, with a budget of about $1 billion, also administers 700 million 

acres of sub-surface mineral estate throughout the nation. The BLM’s multiple-use mission 

is to sustain the health and productivity of the public lands for the use and enjoyment of 

present and future generations. The Bureau accomplishes this by managing such activities 

as outdoor recreation, livestock grazing, mineral development, and energy production, and 

by conserving natural, historical, cultural, and other resources on public lands.
WRIGHT AREA COAL LEASE APPLICATIONS 

FINAL ENVIROMENTAL IMPACT STATEMENT

Prepared by 

WWC Engineering 

Sheridan, Wyoming

Under the Direction of 

U.S. Department of the Interior 

Bureau of Land Management 

High Plains District Office 

Casper, Wyoming

and 

Cooperating Agencies 

U.S. Department of the Interior 

Office of Surface Mining 

Reclamation and Enforcement 

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 and Air Quality Divisions 

Cheyenne, Wyoming

Wyoming Department of Transportation 

Cheyenne, Wyoming 

Converse County Board of Commissioners 

Douglas, Wyoming 

JXO\ 2010 
FINAL ENVIRONMENTAL IMPACT STATEMENT 

WRIGHT AREA COAL LEASE APPLICATIONS 

CAMPBELL COUNTY, WYOMING 

ABSTRACT 

Lead Agency: USDI, Bureau of Land Management, High Plains District Office, 

 Casper, Wyoming 

Cooperating Agencies: USDI, Office of Surface Mining Reclamation and Enforcement, 

Denver, Colorado 

 USDA, Forest Service, Medicine Bow-Routt National Forests 

and Thunder Basin National Grassland, Douglas, Wyoming 

 Wyoming Department of Environmental Quality, Land Quality 

and Air Quality Divisions, Cheyenne, Wyoming 

Wyoming Department of Transportation, Cheyenne, Wyoming 

 Converse County Board of Commissioners, Douglas, Wyoming 

For Further Information Contact: Sarah Bucklin, Bureau of Land Management, 2987 Prospector 

Drive, Casper, WY 82604; (307) 261-7541 

This Final Environmental Impact Statement (EIS) assesses the environmental consequences of decisions 

to hold competitive, sealed-bid sales and issue leases for six federal coal maintenance tracts in Campbell 

County, Wyoming as a result of coal lease applications submitted by Ark Land Company, Jacobs Ranch 

Coal Company, and BTU Western Resources, Inc. As applied for, the Wright area coal lease-byapplication (LBA) tracts include approximately 18,021.73 acres containing approximately 2.570 billion 

tons of federal coal. The tracts are referred to as the North Hilight Field, South Hilight Field, West 

Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine. The applicants propose to 

mine the tracts as maintenance leases for the existing adjacent mines, if lease sales are held and the 

applicant mines acquire the leases. At the time of application, the adjacent mines included Black 

Thunder, Jacobs Ranch, and North Antelope Rochelle. 

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

around the existing mines and the LBA tracts. The alternatives in the Final EIS consider the impacts of 

leasing the tracts as applied for, leasing reconfigured tracts in order to avoid bypassing federal coal or to 

increase competitive interest in the tracts, and not leasing the tracts. The focus for the impact analysis 

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

scoping conducted for these lease applications. Recent concerns related to leasing coal and its subsequent 

development include: impacts to groundwater, air quality, wildlife, cultural resources, paleontological 

resources, socioeconomics, loss of livestock grazing areas, conflicts with oil and gas development, 

cumulative impacts related to ongoing surface coal mining and other proposed development in the 

Wyoming Powder River Basin, greenhouse gas emissions, ozone, and climate change. 

This Final 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. 

The Final EIS is open for a 30-day review period beginning on the date that the U.S. Environmental 

Protection Agency publishes the Notice of Availability in the Federal Register. Comments that are 

postmarked or received on or before the end of the 30-day review period will be considered in the 

preparation of the Record of Decision. 
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-1 

EXECUTIVE SUMMARY 

This Environmental Impact Statement (EIS)1 analyzes the environmental 

impacts of leasing six tracts of federal coal reserves adjacent to the Black 

Thunder, Jacobs Ranch, and North Antelope Rochelle mines. All are operating 

surface coal mines in the southern Powder River Basin (PRB) of Wyoming, near 

the town of Wright. The operators of the Black Thunder, Jacobs Ranch, and 

North Antelope Rochelle mines filed four applications to lease the six tracts of 

federal coal included in maintenance coal tracts under the regulations at 43 

CFR 3425, Leasing On Application. 

The Division of Minerals and Lands at the Bureau of Land Management (BLM) 

Wyoming State Office reviewed all four applications and determined that the 

lease applications met the regulatory requirements for Lease by Applications 

(LBAs). These maintenance coal tracts, which would continue or extend the life 

of the applicant mines, are referred to as the North Hilight Field LBA Tract, the 

South Hilight Field LBA Tract, the West Hilight Field LBA Tract, the West 

Jacobs Ranch LBA Tract, the North Porcupine LBA Tract, and the South 

Porcupine LBA Tract. Figure ES-1 shows these six Wright Area Coal (WAC) 

LBA tracts, other currently pending LBA tracts, and the existing federal leases, 

including previously leased LBA tracts, in the Wyoming PRB. 

On October 7, 2005, Ark Land Company (ALC) filed an application with the 

BLM for federal coal reserves in two separate tracts located north and 

southwest of and immediately adjacent to the Black Thunder Mine in Campbell 

County, Wyoming. The tracts are referred to as the North Hilight Field and 

South Hilight Field LBA Tracts. The North Hilight Field tract is located 

approximately 5.5 miles east of Wright, Wyoming and the South Hilight Field 

tract is located approximately 7 miles southeast of Wright (Figures ES-1, ES-2 

and ES-3). The federal coal reserves were applied for as maintenance tracts for 

the Black Thunder Mine. BLM determined that the two tracts in the 

application would be processed separately and, if the decision is made to 

conduct a lease sale, would be offered for sale separately. ALC is a wholly 

owned subsidiary of Arch Coal, Inc. The Black Thunder Mine is operated by 

Thunder Basin Coal Company (TBCC), a subsidiary of Arch Western Resources, 

LLC. In this EIS, ALC is referred to as the applicant and TBCC is referred to in 

discussions of mine operations. ALC’s coal lease application was assigned case 

file numbers WYW164812 (North Hilight Field) and WYW174596 (South Hilight 

Field). 

On January 17, 2006, ALC filed an application with the BLM for federal coal 

reserves in a tract located west of and immediately adjacent to the Black 

Thunder Mine in Campbell County, Wyoming, approximately 4 miles southeast 

of Wright, Wyoming (Figures ES-1 and ES-4). The tract, which is referred to as 

the West Hilight Field LBA Tract, was assigned case file number WYW172388. 

 

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

Niobrara County

To Douglas 46 Miles

 LEGEND

GILLETTE

ROZET

MOORCROFT

To Buffalo 38 Miles

To Newcastle 29 Miles

North Antelope Rochelle Mine

Belle Ayr North

Belle Ayr Mine

Dry Fork Mine

Wyodak Mine

Rawhide Mine

Caballo Mine

Cordero Rojo Mine

Coal Creek Mine

Buckskin Mine

Eagle Butte Mine

Antelope Mine

Black Thunder Mine

Jacobs Ranch Mine

West Antelope II

Caballo West

Coal-Fired Power Plant

(Proposed or Under Construction)

SCALE: 1"= 10 MILES

West Coal Creek

WEST JACOBS RANCH

Hay Creek II

Maysdorf II

WEST HILIGHT FIELD

SOUTH HILIGHT FIELD

NORTH PORCUPINE

59

LBA Tracts As Applied For (This EIS)

LBA's Pending

LBA's Issued

Existing Leases (Prior to Decertification)

RENO

JUNCTION

Converse County

Johnson County

Campbell County

Campbell County

Crook County Weston County

Campbell County Weston County

Converse County

116

450

387

50

90

90

90 16

16

14

14

50

387

59

59

NORTH HILIGHT FIELD

SOUTH PORCUPINE

School Creek Mine

(Proposed)

North Rochelle Mine

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

Executive Summary

ES-2 Final EIS, Wright Area Coal Lease Applications
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R. 71 W. R. 70 W.

T.

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T.

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N.

Road Jacobs

Small

Hilight Road Hilight Road

Keeline Road

Road

State

450 Highway

BNSF & UP RR

Shroyer Road BNSF & UP RR

0 3000 6000 12000

GRAPHIC SCALE (FEET)

LEGEND

North Hilight Field LBA Tract as Applied for

Existing Black Thunder Mine Federal Coal Leases

Black Thunder Mine Permit Boundary

Additional Area Evaluated Under Alternative 2,

BLM's Preferred Alternative

Existing Jacobs Ranch Mine Federal Coal Leases

Jacobs Ranch Mine Permit Boundary

BLM's Study Area for the

North Hilight Field LBA Tract

Figure ES-2. North Hilight Field LBA Tract Alternatives.

Executive Summary

Final EIS, Wright Area Coal Lease Applications ES-3
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R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

43

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T.

42

N.

Antelope

Edwards Reno Road Hilight Road Hilight Road

Road

Road

BNSF & UP RR

State

450 Highway

BNSF & UP RR

0 3000 6000 12000

GRAPHIC SCALE (FEET)

LEGEND

Existing Black Thunder Mine Federal Coal Leases

Black Thunder Mine Permit Boundary

South Hilight Field LBA Tract as Applied for

Additional Area Evaluated Under Alternative 2,

BLM's Preferred Alternative

Existing Jacobs Ranch Mine Federal Coal Leases

Jacobs Ranch Mine Permit Boundary

BLM's Study Area for the

South Hilight Field LBA Tract

Figure ES-3. South Hilight Field LBA Tract Alternatives.

Executive Summary

ES-4 Final EIS, Wright Area Coal Lease Applications
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State

Edwards

Small

Matheson Road

Hilight Road

Road

Highway 450

Road

BNSF & UP RR

Shroyer Road

HilightRoad

R. 71 W.

Black Thunder Mine's

Northwest Rail Loop

Amendment Area

T.

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T.

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N.

T.

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N.

T.

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0 3000 6000 12000

GRAPHIC SCALE (FEET)

LEGEND

Existing Black Thunder Mine

Federal Coal Leases

Black Thunder Mine

Permit Boundary

West Hilight Field LBA

Tract as Applied for

Additional Area Evaluated

Under Alternative 2,

BLM's Preferred Alternative

Additional Area Evaluated

Under Alternative 3

BLM's Study Area for the

West Hilight Field LBA Tract

Figure ES-4. West Hilight Field LBA Tract Alternatives.

Executive Summary

Final EIS, Wright Area Coal Lease Applications ES-5
Executive Summary 

ES-6 Final EIS, Wright Area Coal Lease Applications

The federal coal reserves were applied for as a maintenance tract for the Black 

Thunder Mine. 

On March 24, 2006, Jacobs Ranch Coal Company (JRCC) filed an application 

with the BLM for federal coal reserves in a tract located approximately 0.75 

mile west of the Jacobs Ranch Mine in Campbell County, Wyoming. The tract, 

which is referred to as the West Jacobs Ranch LBA Tract, is located 

approximately 2.5 miles east of Wright, Wyoming (Figures ES-1 and ES-5). The 

federal coal reserves were applied for as a maintenance tract for the Jacobs 

Ranch Mine. On October 1, 2009, the Jacobs Ranch Mine was acquired by 

Arch Coal, Inc. ALC intends to consolidate the permits for the Jacobs Ranch 

Mine and the Black Thunder Mine in order to integrate the two separate mining 

operations. In this EIS, the applicant for the West Jacobs Ranch LBA Tract will 

be referred to as ALC. ALC’s coal lease application was assigned case file 

number WYW172685. 

On September 29, 2006, BTU Western Resources, Inc. (BTU) filed an 

application with the BLM for federal coal reserves in three separate tracts 

located west, northwest, and north of and immediately adjacent to the North 

Antelope Rochelle Mine in Campbell County, Wyoming. The two tracts on the 

north side of the mine were referred to as the North Porcupine LBA Tract, and 

the tract on the west side of the mine was referred to as the South Porcupine 

LBA Tract. On October 12, 2007, BTU filed a request with the BLM to modify 

the Porcupine LBA Tract configuration to increase the lease area and coal 

volume. The North Porcupine LBA Tract, which is located approximately 12 

miles southeast of Wright, Wyoming, was combined into one tract and its size 

was increased with additional lands (Figures ES-1 and ES-6). The South 

Porcupine LBA Tract, which is located approximately 14 miles southeast of 

Wright, was also increased in size with additional lands (Figure ES-1 and ES7). BLM reviewed the modified tract configuration and notified the company 

that their application had been modified. The federal coal reserves were 

applied for as maintenance tracts for the North Antelope Rochelle Mine. BLM 

determined that the two tracts in the application would be processed separately 

and, if the decision is made to conduct a lease sale, would be offered for sale 

separately. The North Antelope Rochelle Mine is operated by Powder River 

Coal, LLC (PRC), a subsidiary of Peabody Energy Corporation (PEC). BTU is 

also a subsidiary of PEC, and in this EIS, BTU is referred to as the applicant 

and PRC is referred to in discussions of mine operations. BTU’s coal lease 

application was assigned case file numbers WYW173408 (North Porcupine) and 

WYW176095 (South Porcupine). 

These federal coal lands are located within the Powder River Federal Coal 

Region, which was decertified in January, 1990. Although the Powder River 

Federal Coal Region is decertified, the Powder River Regional Coal Team 

(PRRCT), a federal/state advisory board established to develop 

recommendations concerning management of federal coal in the PRB, has 

continued to meet regularly and review all federal lease applications in the 

region. The PRRCT reviewed the North Hilight Field, South Hilight Field, West 
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N.

T.

43

N.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

Small

BNSF & UP RR

Hilight Road Hilight Road

Road

Road

State

450 Highway

BNSF & UP RR

State Highway 450

Shroyer

R. 72 W. R. 71 W.

R. 72 W. R. 71 W.

LEGEND

Existing Jacobs Ranch Mine Federal Coal Leases

Jacobs Ranch Mine Permit Boundary

West Jacobs Ranch LBA Tract as Applied for

0 3000 6000 12000

GRAPHIC SCALE (FEET)

Additional Area Evaluated Under Alternative 2,

BLM's Preferred Alternative

ALC's Northwest Rail Loop Amendment Area

Black Thunder Mine Permit Boundary

Existing Black Thunder Mine Federal Coal Leases

BLM's Study Area for the

West Jacobs Ranch LBA Tract

Figure ES-5. West Jacobs Ranch LBA Tract Alternatives.

Executive Summary

Final EIS, Wright Area Coal Lease Applications ES-7
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T.

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N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

42

N.

T.

41

N.

Reno Road

Mackey

Antelope Road

Road

BNSF & UP RR

Matheson Road

Mackey Road

Matheson Road

BNSF & UP RR

Antelope Road

3000 12000 0

GRAPHIC SCALE (FEET)

LEGEND

6000

North Antelope Rochelle Mine Permit BoundaryExisting North Antelope Rochelle Mine Federal Coal LeasesNorth Porcupine LBA Tract as Applied for

Additional Area Evaluated Under Alternative 2,

BLM's Preferred AlternativeBLM's Study Area for theNorth Porcupine LBA Tract

Figure ES-6. North Porcupine LBA Tract Alternatives.

Executive Summary

ES-8 Final EIS, Wright Area Coal Lease Applications
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R. 71 W. R. 70 W.

Converse County

Campbell County

R. 71 W. R. 70 W.

T.

42

N.

T.

41

N.

Antelope

Matheson Road

BNSF & UP RR

Road

Antelope Road

Matheson Road

0 3000 6000 12000

GRAPHIC SCALE (FEET)

LEGEND

Existing North Antelope Rochelle Mine Federal Coal Leases

North Antelope Rochelle Mine Permit Boundary

South Porcupine LBA Tract as Applied for

Additional Area Evaluated Under Alternative 2,

BLM's Preferred Alternative

BLM's Study Area for the

South Porcupine LBA Tract

Figure ES-7. South Porcupine LBA Tract Alternatives.

Executive Summary

Final EIS, Wright Area Coal Lease Applications ES-9
Executive Summary 

ES-10 Final EIS, Wright Area Coal Lease Applications

Hilight Field, and West Jacobs Ranch maintenance coal lease applications at a 

public meeting held on April 19, 2006 in Casper, Wyoming. The PRRCT 

reviewed the Porcupine maintenance coal lease application at a public meeting 

held on January 18, 2007 in Casper, Wyoming. The PRRCT recommended that 

the BLM process all four lease applications at those respective meetings. 

Evaluation Process 

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

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

fulfill the requirements of the National Environmental Policy Act of 1969 

(NEPA) by evaluating the environmental consequences of leasing the federal 

coal. 

To evaluate the environmental impacts of leasing the coal, BLM must prepare 

an Environmental Assessment (EA) or an EIS to evaluate the site-specific and 

cumulative environmental and socioeconomic impacts of leasing and 

developing the federal coal in an application area. Due to the proximity of the 

North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, 

North Porcupine, and South Porcupine LBA Tracts, BLM made a decision to 

prepare a single EIS to evaluate the environmental impacts of coal mining that 

would be expected to result if leases are issued for these maintenance coal 

tracts. 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. Applicants 

must obtain permits from appropriate state and/or federal agencies to mine the 

coal. 

The Environmental Protection Agency (EPA) published a notice announcing the 

availability of the Draft EIS in the Federal Register on June 26, 2009. The BLM 

published a Notice of Availability and Notice of Public Hearing for the Draft EIS 

in the Federal Register on July 8, 2009. The 60-day comment period on the 

Draft EIS ended 60 days following EPA’s Notice of Availability (August 25, 

2009). A public hearing was held on July 29 in Gillette, Wyoming to solicit 

public comments on the Draft EIS, the fair market value, the maximum 

economic recovery, and the proposed competitive sale of coal from the six LBA 

tracts. Two individuals representing organizations presented statements on 

the Draft EIS during the hearing, and written comments were received from 15 

individuals, agencies, businesses, and organizations, as well as telephoned 

comments and hundreds of e-mails from interested individuals and entities 

during the comment period. A summary of the statements that were presented 

at the public hearing and the public comments, with agency responses, are 

included as Appendix I of this Final EIS. 

BLM will use the analysis in this EIS to decide whether or not to hold a coal 

lease sale for each of the federal coal tracts and issue federal coal leases. The 

LBA sale process is, by law and regulation, an open, public, competitive sealedbid process. If a sale is held for a tract, the bidding would be open to any 
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-11 

qualified bidder; it would not be limited to the applicant. If a separate lease 

sale is held for each of these six LBA tracts (North Hilight Field, South Hilight 

Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South 

Porcupine), the applicants (ALC and BTU) may not be the successful high 

bidders. If a lease sale is held for the federal coal included in each of the six 

LBA tracts, a federal sale panel selects the highest bidder at the sale. In order 

to be awarded a federal coal lease, the highest bid must meet or exceed the fair 

market value of the coal as determined by the BLM’s economic evaluation, and 

if the U.S. Department of Justice determines that no antitrust violations would 

result from assigning the lease to the high bidder. Additionally, the high bidder 

cannot have any antitrust violations. 

The successful bidder would then be required to submit a mine permit 

application, including detailed mining, monitoring, mitigation, and reclamation 

plans to the Wyoming Department of Environmental Quality/Land Quality 

Division (WDEQ/LQD) for review. The operator would also be required to 

submit a Resource Recovery and Protection Plan (R2P2) to the BLM for review. 

Before mining operations could begin in the new tract, the mining permit must 

be approved by WDEQ/LQD, the R2P2 must be approved by the BLM, and a 

Mineral Leasing Act mining plan must be approved by the Assistant Secretary 

of the Interior. In addition, a new coal mine, or a modification to an existing 

mine, must be permitted by the WDEQ/Air Quality Division (AQD). 

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

related to leasing and mining the federal coal in these six tracts. Cooperating 

agencies in the preparation of this EIS include the WDEQ, Office of Surface 

Mining Reclamation and Enforcement (OSM), U.S. Department of AgricultureForest Service (USFS), Wyoming Department of Transportation (WYDOT), and 

Converse County Board of Commissioners. 

Not all of the coal included in the North Hilight Field LBA Tract as applied for is 

considered mineable at this time. Some of the coal included in the tract is 

located within the Burlington Northern Santa Fe & Union Pacific (BNSF & UP) 

railroad right-of-way (ROW). TBCC does not consider the coal underlying the 

railroad ROW to be recoverable at this time because the cost that would be 

associated with moving the railroad would make it economically unfeasible to 

recover the underlying coal. In addition to the railroad, two county roads 

border or cross some of the coal included in the North Hilight Field LBA Tract. 

The Small Road (Campbell County Road 89) crosses the LBA tract, and the 

Shroyer Road (Campbell County Road 116) borders the LBA tract. The Surface 

Mining Control and Reclamation Act of 1977 (SMCRA) prohibits mining within 

100 feet on either side of the ROW of any public road unless the appropriate 

public road authority allows the road to be relocated or closed after public 

notice, an opportunity for a public hearing, and a finding that the interests of 

the affected public and landowners will be protected (30 CFR 761.11(d)). JRCC 

has obtained approval from the Campbell County Board of Commissioners, the 

authorized agency, to close the Small Road. The coal underlying the portion of 

Shroyer Road, its ROW and the 100-foot buffer zone within the North Hilight 
Executive Summary 

ES-12 Final EIS, Wright Area Coal Lease Applications

Field LBA Tract is included for consideration for leasing because that coal 

could be mined if the Campbell County Commissioners determines that the 

road can be closed or relocated (43 CFR 3461.5(c)(2)(iii)). If the road is not 

moved, including the coal underlying the road in the lease would allow 

maximum recovery of all the mineable coal adjacent to the 100-foot buffer zone 

on either side of the road ROW. 

Not all of the coal included in the South Hilight Field LBA Tract as applied for 

is considered mineable at this time. Some of the coal included in the tract is 

located within the BNSF & UP railroad ROW. TBCC does not consider the coal 

underlying the railroad ROW to be recoverable at this time because the cost 

that would be associated with moving the railroad would make it economically 

unfeasible to recover the underlying coal. 

Not all of the coal included in the West Hilight Field LBA Tract as applied for is 

considered mineable at this time. A portion of Wyoming State Highway 450 

borders the tract; therefore, the highway and its ROW overlie some of the coal 

included in the tract. SMCRA prohibits mining within 100 feet on either side of 

the ROW of any public road. However, the appropriate public road authority 

can allow the road to be relocated or closed after public notice, an opportunity 

for a public hearing, and a finding that the interests of the affected public and 

landowners will be protected [30 CFR 761.11(d)]. For State Highway 450 west 

of the BNSF & UP railroad mainline, an unsuitability decision (43 CFR 3461) is 

deferred subject to a finding under this process (BLM 2001a). The coal 

underlying the portion of Highway 450, its ROW, and the 100-foot buffer zone 

within the West Hilight Field LBA Tract is included for consideration for 

leasing. That coal could be mined if the Wyoming Department of 

Transportation (WYDOT), the authorized agency, determines that the road can 

be moved [43 CFR 3461.5(c)(2)(iii)]. Including the coal underlying the highway 

in the lease would allow maximum recovery of all the mineable coal adjacent to 

the 100-foot buffer zone beside the highway ROW if the highway is not moved. 

Not all of the coal included in the West Jacobs Ranch LBA Tract as applied for 

is considered mineable at this time. A portion of Wyoming State Highway 450 

and a portion of the Hilight Road (Campbell County Road 52) overlie some of 

the coal included in the tract. SMCRA prohibits mining within 100 feet on 

either side of the ROW of any public road. However, the appropriate public 

road authority can allow the road to be relocated or closed after public notice, 

an opportunity for a public hearing, and a finding that the interests of the 

affected public and landowners will be protected [30 CFR 761.11(d)]. For State 

Highway 450 west of the BNSF & UP railroad mainline (Figure ES-5), an 

unsuitability decision (43 CFR 3461) is deferred subject to a finding under this 

process (BLM 2001a). The coal underlying the portions of Highway 450 and 

the Hilight Road, their ROWs, and the associated 100-foot buffer zones within 

the West Jacobs Ranch LBA Tract is included for consideration for leasing. 

That coal could be mined if WYDOT and/or the Campbell County Board of 

Commissioners (authorized agencies), determine that the roads can be moved 

[43 CFR 3461.5(c)(2)(iii)]. Including the coal underlying the highway and 
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-13 

Hilight Road in the lease would allow maximum recovery of all the mineable 

coal adjacent to the 100-foot buffer zones beside the highway and road ROWs if 

the State Highway and Hilight Road are not moved. 

Not all of the coal included in the North Porcupine LBA Tract as applied for is 

considered mineable at this time. Some of the coal included in the tract is 

located within the BNSF & UP railroad ROW. PRC does not consider the coal 

underlying the railroad ROW to be recoverable at this time because the cost 

that would be associated with moving the railroad would make it economically 

unfeasible to recover the underlying coal. Moreover, the coal beneath those 

portions of the BNSF & UP railroad ROW on federally administered surface 

lands in the North Porcupine tract was determined to be unsuitable for mining 

according to the coal mining Unsuitability Criteria (43 CFR 3461). Some of the 

coal included in the North Porcupine tract is located within the Teckla 

Substation layback buffer zone. Due to the requirement that no blasting 

operations be conducted within 500 feet of a substation, the coal underlying 

the substation buffer zone is not considered mineable at this time by PRC 

because the cost that would be associated with moving the substation would 

make it economically unfeasible to recover. In addition to the railroad and 

substation, three county roads cross or border some of the coal included in the 

North Porcupine LBA Tract. The Antelope Road (Campbell County Road 4) 

overlies the tract; the Matheson Road (Campbell County Road 70) borders the 

tract; and the Mackey Road (Campbell County Road 69, Alternate 1) crosses 

and borders the tract. SMCRA prohibits mining within 100 feet on either side 

of the ROW of any public road unless the appropriate public road authority 

allows the road to be relocated or closed after public notice, an opportunity for 

a public hearing, and a finding that the interests of the affected public and 

landowners will be protected (30 CFR 761.11(d)). The coal underlying those 

portions of these roads, their ROWs, and the associated 100-foot buffer zones 

within the North Porcupine tract is included for consideration for leasing 

because that coal could be mined if the Campbell County Board of 

Commissioners, the authorized agency, determines that the roads can be 

closed or relocated (43 CFR 3461.5(c)(2)(iii)). PRC has obtained approval from 

the Campbell County Board of Commissioners to close and relocate those 

portions of the Antelope and Matheson roads that cross and border the North 

Porcupine LBA Tract. If the Mackey Road is not closed or relocated, including 

the coal underlying the road in the lease would allow maximum recovery of all 

the mineable coal adjacent to the 100-foot buffer zone on either side of the road 

ROW. PRC is evaluating the feasibility of relocating the Mackey Road. 

Not all of the coal included in the South Porcupine LBA Tract as applied for is 

considered mineable at this time. The BNSF & UP railroad line lies just west of 

the tract, and some of the coal included in the tract is located within a 1,000-

foot wide layback buffer zone on the east side of the railroad ROW centerline. 

PRC does not consider the coal underlying the railroad layback buffer zone to 

be recoverable at this time because the cost that would be associated with 

moving the railroad would make it economically unfeasible to recover that coal. 

In addition to the railroad buffer, a portion of the Antelope Road (Campbell 
Executive Summary 

ES-14 Final EIS, Wright Area Coal Lease Applications

County Road 4) crosses some of the coal included in the South Porcupine LBA 

Tract. SMCRA prohibits mining within 100 feet on either side of the ROW of 

any public road unless the appropriate public road authority allows the road to 

be relocated or closed after public notice, an opportunity for a public hearing, 

and a finding that the interests of the affected public and landowners will be 

protected (30 CFR 761.11(d)). The coal underlying the portion of Antelope 

Road, its ROW, and the 100-foot buffer zone within the South Porcupine LBA 

Tract is included for consideration for leasing because it could be mined if the 

Campbell County Board of Commissioners (authorized agency) determine that 

the road can be closed or relocated (43 CFR 3461.5(c)(2)(iii)). PRC has obtained 

approval from the Campbell County Board of Commissioners to close and 

relocate a portion (approximately 1.25 miles) of Antelope Road that crosses the 

tract. PRC plans to apply for approval to close and relocate the remainder 

(approximately 2.25 miles) of Antelope Road that crosses the South Porcupine 

tract. Including the coal underlying the 2.25-mile portion of Antelope Road in 

the lease would allow maximum recovery of all the mineable coal adjacent to 

the 100-foot buffer zone on either side of the road if the remainder of the road 

is not moved. PRC is evaluating the feasibility of relocating the remainder of 

this county road. 

A decision to lease the federal coal lands in these applications would be in 

conformance with the Approved Resource Management Plan for Public Lands 

Administered by the Bureau of Land Management Buffalo Field Office (BLM 

2001a) and with the Land and Resource Management Plan for the Thunder 

Basin National Grassland, Medicine Bow-Routt National Forest (USFS 2001). 

Proposed Actions and Alternatives 

The Proposed Actions and alternatives to those actions are analyzed in detail in 

this Final EIS. 

• Proposed Action - The Proposed Action for each LBA tract is to hold a 

competitive coal lease sale and issue a maintenance lease to the 

successful bidder for the North Hilight Field, South Hilight Field, West 

Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

LBA Tracts as applied for (Figures ES-2 through ES-7, respectively). The 

applicant mines’ estimates of the coal reserve, lease area and surface 

disturbance area for each tract as applied for are included in Tables ES1 through ES-12. The applicant mines’ estimated future coal 

production, remaining mine life, and employment are also given in 

Tables ES-1 through ES-12. 

• Alternative 1 - Under Alternative 1, the No Action Alternative for each 

tract, the LBA tracts would not be leased, but the existing leases at the 

adjacent Black Thunder, Jacobs Ranch, and North Antelope Rochelle 

mines would be developed according to the existing approved mining 

plans. The applicant mines’ remaining coal reserves, lease areas, future 

coal production rates, and employments are included in Tables ES-1 
Final EIS, Wright Area Coal Lease Applications ES-15 

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

Hilight Field LBA Tract and Black Thunder Mine – Shroyer Road is Not Moved Coal is Not Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing Black Thunder Mine) 

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 1,271.1 mmt 319.7 mmt Mineable Coal (as of 1/1/09)1 1,271.1 mmt 286.3 mmt Recoverable Coal (as of 1/1/09)2 1,169.4 mmt 263.4 mmt Coal Mined Through 2008 1,087.9 mmt -- Lease Area3 19,581.3 ac 2,613.5 ac Total Area To Be Disturbed3 26,490.2 ac 5,053.0 ac Permit Area3 29,212.0 ac 5,053.0 ac Average Annual Coal Production (by 2015)4 135 mmt 0 mmt Remaining Life of Mine (post-2008) 9.3 yrs 2.0 yrs Projected Number of Employees (by 2013)4 1,324 0 

Total Projected State Revenues (post-2008)5 $1,977.9 mm $488.5 – $584.4 mm 

Total Projected Federal Revenues (post-2008)6 $1,541.1 mm $390.1 – $486.0 mm 

1 Under the Proposed Action and Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath the BNSF & UP 

buffer zone and Shroyer Road ROW and associated buffer zone. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state and private coal within the permit boundary. The disturbe

(total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the lease blarger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defined lega

4 The mine projects to increase production rate from 100 mmtpy after 2008 to 135 mmtpy by 2015. The mine projects to increase emplo

projected production increases. 

5 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

6 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thr

mineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
Executive Summary 

 ES-16 Final EIS, Wright Area C

Table ES-2. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Hilight Field LBA Tract and Black Thunder Mine – Shroyer Road is Moved and the 

Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing Black Thunder Mine) 

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 1,271.1 mmt 319.7 mmt Mineable Coal (as of 1/1/09)1 1,271.1 mmt 295.8 mmt Recoverable Coal (as of 1/1/09)2 1,169.4 mmt 272.1 mmt Coal Mined Through 2008 1,087.9 mmt -- Lease Area3 19,581.3 ac 2,613.5 ac Total Area To Be Disturbed3 26,490.2 ac 5,053.0 ac Permit Area3 29,212.0 ac 5,053.0 ac Average Annual Coal Production (by 2015)4 135 mmt 0 mmt Remaining Life of Mine (post-2008) 9.3 yrs 2.0 yrs Projected Number of Employees (by 2013)4 1,324 0 

Total Projected State Revenues (post-2008)5 $1,977.9 mm $504.6 – $603.7 mm 

Total Projected Federal Revenues (post-2008)6 $1,541.1 mm $403.0 – $502.1 mm 

1 Under the Proposed Action and Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railro

zone. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state and private coal within the permit boundary. The disturbe

(total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the lease blarger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defined lega

4 The mine projects to increase production rate from 100 mmtpy after 2008 to 135 mmtpy by 2015. The mine projects to increase emplo

projected production increases. 

5 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

6 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thromineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
Final EIS, Wright Area Coal Lease Applications ES-17 

Table ES-3. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Hilight Field LBA Tract and Black Thunder Mine – Reno Road is Not Moved and th

Not Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing Black Thunder Mine) 

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 1,271.1 mmt 273.3 mmt Mineable Coal (as of 1/1/09)1 1,271.1 mmt 232.2 mmt Recoverable Coal (as of 1/1/09)2 1,169.4 mmt 213.6 mmt Coal Mined Through 2008 1,087.9 mmt -- Lease Area3 19,581.3 ac 1,976.7 ac Total Area To Be Disturbed3 26,490.2 ac 1,126.0 ac Permit Area3 29,212.0 ac 1,126.0 ac Average Annual Coal Production (by 2015)4 135 mmt 0 mmt Remaining Life of Mine (post-2008) 9.3 yrs 1.6 yrs Projected Number of Employees (by 2013)4 1,324 0 

Total Projected State Revenues (post-2008)5 $1,977.9 mm $396.1 – $473.9 mm 

Total Projected Federal Revenues (post-2008)6 $1,541.1 mm $316.3 – $394.1 mm 

1 Under the Proposed Action and Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railro

zone. Under Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath Reno Road ROW and associated buffe

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state and private coal within the permit boundary. The disturbe

(total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the lease blarger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defined lega

4 The mine projects to increase production rate from 100 mmtpy after 2008 to 135 mmtpy by 2015. The mine projects to increase emplo

projected production increases. 

5 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

6 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thrmineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
Executive Summary 

 ES-18 Final EIS, Wright Area C

Table ES-4. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Hilight Field LBA Tract and Black Thunder Mine – Reno Road is Moved and thRecovered.

Item 

Alternative 1 - No Action Alternative 

(Existing Black Thunder Mine) 

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 1,271.1 mmt 273.3 mmt Mineable Coal (as of 1/1/09)1 1,271.1 mmt 232.2 mmt Recoverable Coal (as of 1/1/09)2 1,169.4 mmt 213.6 mmt Coal Mined Through 2008 1,087.9 mmt -- Lease Area3 19,581.3 ac 1,976.7 ac Total Area To Be Disturbed3 26,490.2 ac 1,126.0 ac Permit Area3 29,212.0 ac 1,126.0 ac Average Annual Coal Production (by 2015)4 135 mmt 0 mmt Remaining Life of Mine (post-2008) 9.3 yrs 1.6 yrs Projected Number of Employees (by 2013)4 1,324 0 

Total Projected State Revenues (post-2008)5 $1,977.9 mm $396.1 – $473.9 mm 

Total Projected Federal Revenues (post-2008)6 $1,541.1 mm $316.3 – $394.1 mm 

1 Under the Proposed Action and Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railro

zone. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state and private coal within the permit boundary. The disturbe

(total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the lease blarger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defined lega

4 The mine projects to increase production rate from 100 mmtpy after 2008 to 135 mmtpy by 2015. The mine projects to increase emplo

projected production increases. 

5 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

6 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thr

mineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
Final EIS, Wright Area Coal Lease Applications ES-19 

Table ES-5. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Hilight Field LBA Tract and Black Thunder Mine – State Highway 450 and Hilight and the Underlying Coal is Not Recovered. 

Item 

Alternative 1 – 

No Action Alternative 

(Existing Black Thunder Mine)

Added by 

Proposed Action 

Added by 

Alternative 2 

In-Place Coal (as of 1/1/09) 1,271.1 mmt 440.4 mmt 1,147.9 mmt Mineable Coal (as of 1/1/09)1 1,271.1 mmt 410.8 mmt 1,049.1 mmt 

Recoverable Coal (as of 1/1/09)2 1,169.4 mmt 377.9 mmt 965.2 mmt Coal Mined Through 2008 1,087.9 mmt -- -- 

Lease Area3 19,581.3 ac 2,370.5 ac 7,191.3 ac 

Total Area To Be Disturbed3 26,490.2 ac 6,351.4 ac 10,250.8 ac 

Permit Area3 29,212.0 ac 6,351.4 ac 10,250.8 ac 

Average Annual Coal Production (by 2015)4 135 mmt 0 mmt 0 mmt 

Remaining Life of Mine (post-2008) 9.3 yrs 2.8 yrs 7.1 yrs 

Projected Number of Employees (by 2013)4 1,324 0 0 

Total Projected State Revenues (post-2008)5 $1,977.9 mm $700.8 – $838.4 mm $1,789.9 – $2,141.3 m

Total Projected Federal Revenues (post-2008)6 $1,541.1 mm $559.7 – $697.3 mm $1,429.4 – $1,780.8 m

1 Under the Proposed Action, the mineable coal figure excludes all coal that would not be mined beneath State Highway 450 ROW and a

Alternatives 2 and 3, the mineable coal figure excludes all coal that would not be mined beneath State Highway 450 and Hilight Road ROW

Under Alternative 3, the mineable coal figure excludes all coal that would not be mined beneath the Northwest Rail Loop Amendment Area. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state and private coal within the permit boundary. The disturbe

(total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the lease blarger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defined lega

4 The mine projects to increase production rate from 100 mmtpy after 2008 to 135 mmtpy by 2015. The mine projects to increase emplo

projected production increases. 

5 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bisold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

6 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thr

mineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
Executive Summary 

 ES-20 Final EIS, Wright Area CTable ES-6. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Hilight Field LBA Tract and Black Thunder Mine – State Highway 450 and Hilight the Underlying Coal is Recovered. 

Item 

Alternative 1 – 

No Action Alternative 

(Existing Black Thunder Mine)

Added by 

Proposed Action 

Added by 

Alternative 2 

In-Place Coal (as of 1/1/09) 1,271.1 mmt 440.4 mmt 1,147.9 mmt Mineable Coal (as of 1/1/09)1 1,271.1 mmt 440.4 mmt 1,147.9 mmt 

Recoverable Coal (as of 1/1/09)2 1,169.4 mmt 405.2 mmt 1,056.1 mmt 

Coal Mined Through 2008 1,087.9 mmt -- -- 

Lease Area3 19,581.3 ac 2,370.5 ac 7,191.3 ac 

Total Area To Be Disturbed3 26,490.2 ac 6,351.4 ac 11,629.5 ac 

Permit Area3 29,212.0 ac 6,351.4 ac 11,629.5 ac 

Average Annual Coal Production (by 2015)4 135 mmt 0 mmt 0 mmt 

Remaining Life of Mine (post-2008) 9.3 yrs 3.0 yrs 7.8 yrs 

Projected Number of Employees (by 2013)4 1,324 0 0 

Total Projected State Revenues (post-2008)5 $1,977.9 mm $751.4 – $898.9 mm $1,958.4 – $2,343.0 mm 

Total Projected Federal Revenues (post-2008)6 $1,541.1 mm $600.1 – $747.6 mm $1,564.0 – $1,948.6 mm 

1 Under the Proposed Action, the mineable coal figure excludes all coal that would not be mined beneath State Highway 450 ROW and a

Alternatives 2 and 3, the mineable coal figure excludes all coal that would not be mined beneath State Highway 450 and Hilight Road ROWUnder Alternative 3, the mineable coal figure excludes all coal that would not be mined beneath the Northwest Rail Loop Amendment Area. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state and private coal within the permit boundary. The disturbe

(total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the lease blarger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defined lega

4 The mine projects to increase production rate from 100 mmtpy after 2008 to 135 mmtpy by 2015. The mine projects to increase emplo

projected production increases. 

5 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bisold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

6 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thr

mineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
Final EIS, Wright Area Coal Lease Applications ES-21 

Table ES-7. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Jacobs Ranch LBA Tract and Jacobs Ranch Mine – State Highway 450 and HMoved and the Underlying Coal is Not Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing Jacobs Ranch Mine) 

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 403.6 mmt 957.0 mmt Mineable Coal (as of 1/1/09)1 403.6 mmt 744.0 mmt Recoverable Coal (as of 1/1/09)2 379.4 mmt 669.6 mmt Coal Mined Through 2008 671.1 mmt -- Lease Area3 7,381.0 ac 5,944.4 ac Total Area To Be Disturbed3 15,261.5 ac 7,023.0 ac Permit Area3 15,625.0 ac 8,066.0 ac Average Annual Coal Production (post-2008) 40 mmt 0 mmt Remaining Life of Mine (post-2008) 9.6 yrs 16.7 yrs Projected Number of Employees 630 155 

Total Projected State Revenues (post-2008)4 $641.7 mm $1,244.1 – $1,493.4 mm 

Total Projected Federal Revenues (post-2008)5 $500.0 mm $994.1 – $1,243.3 mm 

1 Under the Proposed Action and Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath State Highway 45

associated buffer zones. 

2 Assumes 94 percent recovery of mineable coal that occurs during normal mining operation under Alternative 1, and 90 percent recovery 

during normal mining operation under the Proposed Action and Alternative 2. 

3 The lease area figure includes federal coal leases only and does not include state and private coal within the permit boundary. The disturbe

(total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the lease blarger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defined lega

4 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

5 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.0 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thr

mineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
Executive Summary 

 ES-22 Final EIS, Wright Area C

Table ES-8. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Jacobs Ranch LBA Tract and Jacobs Ranch Mine – State Highway 450 and Hiliand the Underlying Coal is Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing Jacobs Ranch Mine) 

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 403.6 mmt 957.0 mmt Mineable Coal (as of 1/1/09)1 403.6 mmt 957.0 mmt Recoverable Coal (as of 1/1/09)2 379.4 mmt 861.3 mmt Coal Mined Through 2008 671.1 mmt -- Lease Area3 7,381.0 ac 5,944.4 ac Total Area To Be Disturbed3 15,261.5 ac 7,023.0 ac Permit Area3 15,625.0 ac 8,066.0 ac Average Annual Coal Production (post-2008) 40 mmt 0 mmt Remaining Life of Mine (post-2008) 9.6 yrs 21.5 yrs Projected Number of Employees 630 155 

Total Projected State Revenues (post-2008)4 $641.7 mm $1,600.3 – $1,920.9 mm 

Total Projected Federal Revenues (post-2008)5 $500.0 mm $1,278.6 – $1,599.2 mm 

1 Under the Proposed Action and Alternative 2, the mineable coal figure includes all coal that would be mined beneath State Highway 450 

associated buffer zones. 

2 Assumes 94 percent recovery of mineable coal that occurs during normal mining operation under Alternative 1, and 90 percent recovery 

during normal mining operation under the Proposed Action and Alternative 2. 

3 The lease area figure includes federal coal leases only and does not include state and private coal within the permit boundary. The disturbe

(total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the lease blarger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defined lega

4 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

5 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thr

mineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
Final EIS, Wright Area Coal Lease Applications ES-23 

Table ES-9. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Porcupine LBA Tract and North Antelope Rochelle Mine – Mackey Road is Underlying Coal is Not Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing North Antelope Rochelle Mine)

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 1,049.9 mmt 756.9 mmt Mineable Coal (as of 1/1/09)1 1,015.0 mmt 653.5 mmt Recoverable Coal (as of 1/1/09)2 933.8 mmt 601.2 mmt Coal Mined Through 2008 1,230.8 mmt -- Lease Area3 16,666.1 ac 5,795.8 ac Total Area To Be Disturbed3 27,443.0 ac 9,864.0 ac Permit Area3 45,975.0 ac 1,760.0 ac Average Annual Coal Production (post-2008) 95 mmt 0 mmt Remaining Life of Mine (post-2008) 9.9 yrs 6.3 yrs Projected Number of Employees 1,150 0 Total Projected State Revenues (post-2008)4 $1,579.4 mm $1,114.9 – $1,333.8 mm $Total Projected Federal Revenues (post-2008)5 $1,230.6 mm $890.3 – $1,109.3 mm $1 Under the Proposed Action, the mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railroad ROW and 

Substation buffer zone, and Mackey Road ROW and associated buffer zone. Under Alternative 2, the mineable coal figure excludes all 

beneath BNSF & UP railroad ROW and associated buffer zone, Teckla Substation buffer zone, a portion of Matheson Road ROW and assocRoad ROW and associated buffer zone. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state coal within the permit boundary. The disturbed area excee

and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the lease boundaries. The leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defined legal land descriptio

4 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

5 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amouroyalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thr

mineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
Executive Summary 

 ES-24 Final EIS, Wright Area C

Table ES-10. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Porcupine LBA Tract and North Antelope Rochelle Mine – Mackey Road is Moved Coal is Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing North Antelope Rochelle Mine) 

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 1,049.9 mmt 756.9 mmt Mineable Coal (as of 1/1/09)1 1,015.0 mmt 688.3 mmt Recoverable Coal (as of 1/1/09)2 933.8 mmt 633.3 mmt Coal Mined Through 2008 1,230.8 mmt -- Lease Area3 16,666.1 ac 5,795.8 ac Total Area To Be Disturbed3 27,443.0 ac 10,167.0 ac Permit Area3 45,975.0 ac 1,760.0 ac Average Annual Coal Production (post-2008) 95 mmt 0 mmt Remaining Life of Mine (post-2008) 9.9 yrs 6.7 yrs Projected Number of Employees 1,150 0 Total Projected State Revenues (post-2008)4 $1,579.4 mm $1,174.4 – $1,405.0 mm Total Projected Federal Revenues (post-2008)5 $1,230.6 mm $937.9 – $1,168.4 mm 

1 Under the Proposed Action, the mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railroad ROW and ass

Substation buffer zone. Under Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railrozone, Teckla Substation buffer zone, and a portion of Matheson Road ROW and associated buffer zone. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state coal within the permit boundary. The disturbed area excee

and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the lease boundaries. The leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defined legal land descriptio

4 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

5 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.35 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thr

mineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
Final EIS, Wright Area Coal Lease Applications ES-25 

Table ES-11. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Porcupine LBA Tract and North Antelope Rochelle Mine – 2.25-Mile Section of AMoved and the Underlying Coal is Not Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing North Antelope Rochelle Mine)

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 1,049.9 mmt 422.2 mmt Mineable Coal (as of 1/1/09)1 1,015.0 mmt 336.6 mmt Recoverable Coal (as of 1/1/09)2 933.8 mmt 309.7 mmt Coal Mined Through 2008 1,230.8 mmt -- Lease Area3 16,666.1 ac 3,186.0 ac Total Area To Be Disturbed3 27,443.0 ac 3,366.0 ac Permit Area3 45,975.0 ac 200.0 ac Average Annual Coal Production (post-2008) 95 mmt 0 mmt Remaining Life of Mine (post-2008) 9.9 yrs 3.3 yrs Projected Number of Employees 1,150 0 

Total Projected State Revenues (post-2008)4 $1,579.4 mm $574.3 – $687.1 mm 

Total Projected Federal Revenues (post-2008)5 $1,230.6 mm $458.6 – $571.4 mm 

1 Under the Proposed Action and Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railro

zone and 2.25-mile section of Antelope Road and associated buffer zone. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state coal within the permit boundary. The disturbed area exceed

and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the lease boundaries. The 

leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defined legal land descriptio

4 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bisold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

5 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amouroyalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thr

mineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
Executive Summary 

 ES-26 Final EIS, Wright Area C

Table ES-12. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and R

Porcupine LBA Tract and North Antelope Rochelle Mine – 2.25-Mile Section oMoved and the Underlying Coal is Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing North Antelope Rochelle Mine) 

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 1,049.9 mmt 422.2 mmt Mineable Coal (as of 1/1/09)1 1,015.0 mmt 408.4 mmt Recoverable Coal (as of 1/1/09)2 933.8 mmt 375.7 mmt Coal Mined Through 2008 1,230.8 mmt -- Lease Area3 16,666.1 ac 3,186.0 ac Total Area To Be Disturbed3 27,443.0 ac 3,908.0 ac Permit Area3 45,975.0 ac 200.0 ac Average Annual Coal Production (post-2008) 95 mmt 0 mmt Remaining Life of Mine (post-2008) 9.9 yrs 4.0 yrs Projected Number of Employees 1,150 0 

Total Projected State Revenues (post-2008)4 $1,579.4 mm $696.7 – $833.5 mm 

Total Projected Federal Revenues (post-2008)5 $1,230.6 mm $556.4 – $693.2 mm 

1 Under the Proposed Action and Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railro

zone. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state coal within the permit boundary. The disturbed area excee

and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the lease boundaries. The leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defined legal land descriptio

4 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

5 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thr

mineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-27 

through ES-12. Rejection of the lease applications would not preclude 

applications to lease the tracts in the future. 

• Alternatives 2 and 3 - Under Alternative 2 for each of the six LBA tracts 

and Alternative 3 for the West Hilight Field LBA Tract, BLM would 

reconfigure the tract, hold a competitive coal lease sale for the lands 

included in the reconfigured tract, and issue a maintenance lease to the 

successful bidder for a tract that is larger than the applied-for tract. 

BLM identified a study area for each LBA tract in order to evaluate the 

potential that an alternate configuration of the tract would provide more 

efficient recovery of the federal coal, increase competitive interest in the 

tract, and/or reduce the potential that some of the remaining unleased 

federal coal in this area would be bypassed in the future. The BLM 

study area includes the tract as applied for plus adjacent unleased 

federal coal, which is depicted as the additional area evaluated under 

Alternatives 2 and 3 in Figures ES-2 through ES-7. These different tract 

configurations are considered as Alternatives 2 and 3 in this EIS. 

Alternative 2, holding a competitive sale for a modified tract, is BLM’s 

Preferred Alternative for each of these six LBA tracts. The applicant 

mines’ estimates of the coal reserve, lease area and surface disturbance 

area for each tract under Alternative 2 and for the West Hilight Field 

tract under Alternative 3 are included in Tables ES-1 through ES-12. 

The applicant mines’ projected rates of coal production and employment 

would be similar to the Proposed Actions, although the life of the existing 

mines would be extended for a period of time, depending on if the public 

highway and/or county roads are or are not moved. 

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

the North, South and West Hilight Field LBA Tracts; ALC would be the 

successful bidder on the West Jacobs Ranch LBA Tract; and BTU would be the 

successful bidder on the North and South Porcupine LBA Tracts. Under the 

Proposed Actions and Alternatives 2 and 3, the leases would be subject to the 

standard and special lease stipulations developed for the PRB and for these 

tracts, which are listed in Appendix D of this EIS. 

One alternative that was considered but not analyzed in detail included holding 

competitive coal lease sales and issuing leases for one or more of the LBA 

tracts to the successful bidder (not the applicants) for the purpose of 

developing new stand-alone mines. Another alternative that was not analyzed 

in detail called for delaying the competitive sales of one or more of the LBA 

tracts 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 coal bed natural 

gas (CBNG) resources in the tracts prior to mining. 
Executive Summary 

ES-28 Final EIS, Wright Area Coal Lease Applications

Environmental Concerns 

Critical elements of the human environment (BLM 2008a) that could be 

affected by the Proposed Actions or Alternatives 2 and 3 include air quality, 

cultural resources, Native American religious concerns, threatened and 

endangered (T&E) plant and animal species, migratory birds, hazardous or 

solid waste, water quality (both surface and ground), wetlands/riparian zones, 

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

elements (areas of critical environmental concern, prime and unique farmland, 

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

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

critical elements that are potentially present in the general Wright analysis 

area, this EIS discusses the status and potential effects of mining the LBA 

tracts on topography and physiography, geology and mineral resources, soils, 

water quantity and quality, alluvial valley floors (AVFs), vegetation, wildlife, 

land use and recreation, paleontological resources, visual resources, noise, 

transportation resources, and socioeconomics. 

The environmental impacts of mining each of the LBA tracts would be similar 

under the Proposed Action and Alternatives 2 and 3. 

The general analysis area for each of these six LBA tracts represents the 

maximum surface area that could be disturbed by mining activities analyzed in 

this EIS. More specifically, each LBA tract’s general analysis area is defined as 

the BLM study area plus surrounding lands within a 1⁄4-mile perimeter that 

could be disturbed by mining the coal within the BLM study area where future 

mining disturbance could occur. Surface disturbance occurs outside of a coal 

lease area as a result of activities including, but not limited to, overstripping, 

highwall backsloping (including catch benches), highwall reduction after 

mining to match undisturbed topography, and construction of flood- and 

sediment-control structures. For the purpose of this analysis, the general 

Wright analysis area is defined as the area encompassing all six of these LBA 

tracts’ general analysis areas. 

► Topography 

The general Wright analysis area is located in the PRB, a part of the Northern 

Great Plains that includes most of northeastern Wyoming. The North Hilight 

Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, North 

Porcupine, and South Porcupine LBA Tracts are located in the southeastern 

part of the PRB, in an area consisting primarily of a gently rolling upland 

terrain of low relief, broken by minor drainages and internally-drained playa 

areas. Drainage densities are quite low, and the playas are common 

topographic and hydrologic features. Land surface elevations range from about 

4,690 to 5,170 feet above sea level. Gently rolling uplands comprise most of 

the general Wright analysis area; most of the land surface (between 75 and 90 

percent, depending on the particular LBA tract) seldom exceeds a 5 percent 

slope. The steepest slopes typically occur near the highest elevations along the 
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-29 

ridge lines and drainage divides, at the breaks or the broken land dissected by 

small ravines and gullies, or at the transitions between uplands and bottom 

lands. 

The existing topography on each LBA tract that is leased 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 typically contain fewer and gentler topographic features. This could 

contribute to reduced habitat diversity and wildlife carrying capacity on the 

LBA tracts. These topographic changes would not conflict with regional land 

use, and the postmining topography would adequately support anticipated 

postmining land use for each tract. 

► Geology 

The mineable coal seams in the PRB are part of the Tongue River Member of 

the Fort Union Formation. The nomenclature of the mineable coal seams in 

the Tongue River Member varies from mine operator to mine operator in the 

eastern PRB and are locally referred to as the Anderson and Canyon, Roland 

and Smith, Wyodak-Anderson, and Wyodak. Operators of the mines in the 

general Wright analysis area refer to the mineable coal zone as either the 

Wyodak (Upper Wyodak, Middle Wyodak and Lower Wyodak) or the WyodakAnderson. The number of coal seams varies from tract to tract. The combined 

average thicknesses of the mineable coal seams range between 61 feet within 

the North Hilight Field LBA Tract to 104 feet within the West Jacobs Ranch 

LBA Tract. Interburden thickness between the coal seams varies from 0 (West 

Jacobs Ranch) to around 94 feet (South Hilight Field), and average overburden 

thickness on each tract ranges from around 246 feet (North Hilight Field) to 

around 480 feet (West Jacobs Ranch). 

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

considerable permanent change on each LBA tract under the Proposed Actions 

or Alternatives 2 and 3. After removal of the coal, the replaced overburden 

would be a relatively homogeneous mixture compared to the premining layered 

overburden. 

► Other Mineral Resources 

With the exception of developing continuous oil and gas resources via 

horizontal wells completed in source rocks many thousands of feet below the 

mineable Wyodak-Anderson coal beds, other minerals present on the LBA 

tracts could not be developed during mining. Some of these other minerals 

could, however, be developed after coal mining and reclamation are completed. 

Development of other minerals potentially present on the LBA tracts could not 

occur during mining but could occur after mining. 
Executive Summary 

ES-30 Final EIS, Wright Area Coal Lease Applications

Conventional oil and gas resources in the general Wright analysis area have 

been extensively developed. According to the WOGCC database as of May 

2008, a total of 74 conventional oil and natural gas wells have been drilled and 

33 were capable of producing within the six LBA tracts as applied for and the 

lands added by the respective BLM study areas included in this analysis 

(WOGCC 2008a). No conventional oil or natural gas wells have been drilled 

within these six LBA tract study areas since 1990, so the area generally 

appears to be unfavorable for additional production from known conventional 

reservoirs. According to the January 2008 reserve estimate of conventional oil 

and gas resources that was prepared by Allen & Crouch (A&C) Petroleum 

Engineers, Inc. of Casper, Wyoming, of the 33 wells capable of producing oil or 

conventional gas that are located within the respective BLM study areas for 

these six LBA tracts, 16 wells are considered to have recoverable reserves using 

in-place recovery methods. The actively producing wells, as presently 

completed, appear to have exhausted most of their recoverable reserves. 

Estimated remaining recoverable reserves from these 16 wells are 

approximately 43,308 barrels of oil and 1.654 million cubic feet of natural gas 

(A&C 2008). Any conventional oil and gas wells on the tracts 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. 

Extensive development of coal bed natural gas (CBNG) in the Wyodak-Anderson 

coal zone has occurred in the general Wright analysis area. According to the 

WOGCC database as of May 2008, a total of 287 wells have been drilled for 

CBNG production and 248 were capable of producing within the six LBA tracts 

as applied for and the lands added by the respective BLM study areas included 

in this analysis (WOGCC 2008a). Although CBNG has been produced in this 

area for about 10 years, there are still some undrilled 80-acre spacing units in 

and around the general Wright analysis area. However, there has been little 

recent interest in drilling additional wells for completion in the WyodakAnderson coal zone in this area. CBNG is also being produced locally from 

other deeper seams in the PRB (e.g., Cook, Wall, and Pawnee coal seams of the 

Tongue River Member of the Fort Union Formation)., although no wells have 

been completed in the deeper seams on and immediately west of the North 

Hilight Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, North 

Porcupine, and South Porcupine LBA Tracts (WOGCC 2008a). 

The Wyoming BLM State Office-Reservoir Management Group (WSO-RMG) and 

the U.S. Geological Survey (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 Wyodak-Anderson coal 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 standard cubic feet per ton (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. Analyses by WSO-RMG, USGS, CBNG 

operators, and others have shown that dewatering of the coal beds, by both 
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-31 

CBNG production and mine dewatering, reduces the hydrostatic pressure in 

the coals and allows the CBNG to desorb and escape from the coal. These 

effects have been ongoing and it is likely that desorption has continued since 

2000; as a result, coal gas content and the gas-in-place adjacent to the existing 

mines would currently be expected to be less than in 2000. 

CBNG from the Wyodak-Anderson coal zone that is not recovered prior to 

mining, albeit slight, would be vented to the atmosphere and irretrievably lost 

when the coal is removed. CBNG production from coal zones underlying the 

Wyodak-Anderson coal zone would not be directly disturbed by surface mining 

operations and could be delayed as the parcel is mined. If production from 

these lower seams is established on the LBA tracts in the future, additional 

measures would be required to accommodate both mining and CBNG 

production. 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. 

The USGS reports significant undiscovered reserves of continuous oil and gas 

resources exist in the PRB of Wyoming and Montana. Drilling for these 

resources is currently occurring in the Keeline and Wild West Oil and Gas 

Units located just east of the Black Thunder and Jacobs Ranch mines. It is 

possible that horizontal wells could be drilled from surface locations outside of 

the LBA tracts and deviated to run horizontally beneath the tracts within 

source rocks that are many thousands of feet deeper than the mineable 

Wyodak-Anderson coal beds. Continuous oil and gas resources could be 

developed in this manner on the LBA tracts during mining. 

► Paleontology 

The two geologic formations that are exposed on the surface in the general 

Wright analysis area are the Eocene age Wasatch Formation and the Paleocene 

age Fort Union Formation. The Wasatch Formation has been known to 

produce abundant and significant paleontological resources in several basins 

throughout Wyoming (Delson 1971, Winterfeld 1978, EVG 2001). Occurrences 

of significant fossils in this formation within the PRB have been more sporadic 

and less common than in other basins. 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. Surficial 

geologic mapping of the general Wright analysis area by the USGS (Reheis and 

Coates 1987) indicate that unconsolidated surficial deposits (i.e., colluvial and 

eolian deposits) occur widespread over the area and actual outcrops of the 

Wasatch Formation that could be prospected for fossils occur infrequently. 

The landscape of the LBA tracts’ general analysis areas is not particularly well 

suited to bedrock and paleontological exposure. The upper-most member of 

the Fort Union Formation, the Lebo Member, is less significant in regards to 

paleontological resources. Fossils occur sporadically and significant vertebrate 

specimens have rarely been reported from the PRB. 
Executive Summary 

ES-32 Final EIS, Wright Area Coal Lease Applications

The entire general analysis areas for each of the six WAC LBA Tracts were 

examined for the presence of fossils. Paleontological surveys on federal lands 

administered by the USFS were conducted in 2009 by qualified paleontologists 

with USFS approval to conduct paleontological resource surveys on the 

Thunder Basin National Grasslands (TBNG). 

No fossils, scientifically significant or otherwise, were identified or collected 

during the survey of the North Hilight Field LBA Tract. No further 

paleontological work or specific mitigation measures prior to mining-related 

disturbances are recommended or required. 

No scientifically significant or unique paleontological resources were identified 

or collected during the survey of the South Hilight Field LBA Tract. No further 

paleontological work or specific mitigation measures, aside from the 

notification of potentially interested researchers that a relatively common fossil 

was found at a locality that places it near the Paleocene-Eocene Thermal 

Maximum (PETM) boundary, prior to mining-related disturbances are 

recommended or required. 

No scientifically significant or unique paleontological resources were identified 

or collected during the survey of the West Hilight Field LBA Tract. No further 

paleontological work or specific mitigation measures prior to mining-related 

disturbances are recommended or required. 

No scientifically significant or unique paleontological resource localities have 

been recorded in the West Jacobs Ranch tract’s general analysis area. No 

further paleontological work of mitigation measures prior to mining-related 

disturbances would be necessary. 

Scientifically significant vertebrate fossil materials were identified and recorded 

at two localities in the Wasatch Formation during the survey of the North 

Porcupine LBA Tract. Specimens discovered on the surface at one of the 

localities were collected and will be reposited with the Denver Museum of 

Nature and Science. Because no in-situ sources for the discovered vertebrate 

fossil fragments were identified, further efforts to recover additional fossil 

material are considered to be unlikely. No additional paleontological work or 

specific mitigation measures prior to mining-related disturbances are 

recommended. 

Ten new paleontological localities were discovered during the survey of the 

South Porcupine LBA Tract. Six of the localities contained fossil vertebrate 

material; three localities contained fossil invertebrate material; and one locality 

contained fossil plant impressions. Three vertebrate localities were discovered 

in the Wasatch Formation, while the remaining seven localities were discovered 

in the Lebo Member of the Fort Union Formation. Vertebrate specimens 

exposed on the surface that did not require excavation were collected from five 

localities. All collected specimens will be reposited with the Denver Museum of 

Nature and Science. None of the invertebrate or plant localities discovered 
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-33 

during the 2009 survey were considered rare of scientifically significant, and 

therefore no specimens were collected from them. No additional paleontological 

work or mitigation measures prior to mining-related disturbances are 

recommended for any of the invertebrate or plant fossil localities. Based on the 

field survey, it is highly likely that additional buried fossil material may be 

present at several vertebrate fossil localities. In order to avoid future impacts 

to potentially scientifically significant paleontological resources at these 

localities, it is recommended that mitigation efforts be conducted to determine 

if additional buried material is present, and to then collect any scientifically 

significant specimens. These mitigation efforts would ensure that mining 

operations would have no adverse effect on these localities. 

Fossils with scientific significance could be present on the tracts but not 

exposed at the surface. Additional surveys for paleontological resources may 

be required if discoveries are made during mining. If the tracts are leased 

under the Proposed Actions or Alternatives 2 or 3, undiscovered paleontological 

resources that are not exposed on the surface or detected during mining would 

be permanently lost during mining. 

► Air Quality 

Particulate and gaseous emissions are the two primary types of air pollutants 

directly associated with surface coal mining in the PRB; both of which are 

associated with a variety of health and environmental impacts. Mining 

activities generate fugitive dust particulates 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 of particulate emissions. Gases that contain nitrogen and oxygen in 

varying amounts are referred to as nitrogen oxides, or NOx. These are the 

primary fugitive gaseous emissions produced during surface coal mining 

operations. Nitrogen oxides are generated from the tailpipe exhaust emissions 

from mining equipment and other vehicular traffic within the mine permit area. 

Blasting is also responsible for another type of emission from surface coal 

mining. Overburden and coal blasting sometimes produces gaseous, orangecolored clouds that contain nitrogen dioxide (NO2). Exposure to NO2 may have 

adverse health effects. NO2 is one of several products resulting from the 

incomplete combustion of explosives used in the blasting process. 

Other non-mining air pollutant emission sources within the region include: 

• CO and nitrogen oxides (NOx) from internal combustion engines used at 

natural gas and CBNG pipeline compressor stations; 

• CO, NOx, particulates (PM10 and PM2.5), sulfur dioxide (SO2), and volatile 

organic compounds (VOCs) from gasoline and diesel vehicle tailpipe 

emissions; 
Executive Summary 

ES-34 Final EIS, Wright Area Coal Lease Applications

• 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; 

• NO2 and PM10 emissions from train locomotives used to haul coal; 

• SO2 and NOx from power plants. The closest coal-fired power plants are 

the Dave Johnston plant, located about 40-60 miles south-southwest of 

these six LBA tracts, and the Wyodak, Wygen, and Neil Simpson plants, 

located about 35-55 miles north of these six LBA tracts; and 

• Air pollutants transported from emission sources located outside the 

PRB. 

Since 1989, the regulated particulate pollutant in Wyoming has been PM10

(particulate matter with an aerodynamic diameter of 10 microns or less). 

Wyoming also adopted a fine particulate, PM2.5 (particulate matter with a mean 

aerodynamic diameter of 2.5 microns or less), standard in March 2000, but 

that standard is not yet part of the state’s air quality monitoring requirements. 

EPA has revoked the annual PM10 standard of 50 micrograms per cubic meter 

(μg/m3) but retained the 24-hour PM10 standard of 150 μg/m3. Until the state 

of Wyoming enters into rulemaking to revise the Wyoming Ambient Air Quality 

Standards (WAAQS), the annual PM10 standard of 50 μg/m3 is still effective. 

The federal and Wyoming air quality standard for annual NO2 is 100 μg/m3. 

This criteria air pollutant is not currently regulated at surface coal mines, 

although the WDEQ/AQD does require an assessment of annual NO2 impacts 

as part of an air quality permitting analysis for new surface coal mines and 

existing mine plan revisions. 

Moderately adverse, short-term impacts on air quality are currently present at 

the Black Thunder Mine due to existing mine operations, and would be 

extended onto the North, South, and West Hilight Field LBA Tracts during the 

time the tracts are mined if leases are issued. Air quality modeling for the 

current Black Thunder Mine permit predicted no exceedances of the annual 

PM10 particulate WAAQS and National Ambient Air Quality Standard (NAAQS) 

at the permitted production level of 135 million tons per year (mmtpy). The 

mine’s anticipated production rate by 2015 is 135 mmtpy. The dispersion 

model showed a maximum concentration on the Black Thunder Mine LNCM 

(lands necessary to conduct mining) boundary of 49.96 μg/m3 in 2017 (Figure 

ES-8), one of two projected worst-case years used for the model. 

Moderately adverse short-term impacts to air quality are currently present at 

the Jacobs Ranch Mine due to existing mine operations, and would be 

extended onto the West Jacobs Ranch LBA Tract during the time the tract is 

mined if a lease is issued. Air quality modeling for the current Jacobs Ranch 

Mine permit predicted no exceedances of the annual PM10 particulate WAAQS 

and NAAQS at the permitted production level of 55 mmtpy. The mine’s current 

and anticipated future production rate is approximately 40 mmtpy. The 

dispersion model showed a maximum concentration on the Jacobs Ranch Mine 
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Road Jacobs

State

Antelope

Edwards

Matheson Road

Reno Road

Hilight Road Hilight Road

Keeline Road

Highway 450

State

450 Highway

Road

Road

BNSF & UP RR

Shroyer

Road

Small Road

PM10=49.96 μg/m3

NOx=52.5 μg/m3

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Receptor Location

Area Source

Ambient Air Boundary

Haul Roads

Black Thunder Mine Permit Boundary

Existing Black Thunder

Mine Federal Coal Leases

LEGEND

North Hilight Field LBA Tract as Applied for

North Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA Tract as Applied for

South Hilight Field LBA Tract as Applied for

South Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA Tract Under Alternative 3

West Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure ES-8. Maximum Modeled PM10 and NOX

 Concentrations at the Black Thunder Mine Ambient Air

Boundary for the Year 2017.

Executive Summary

Final EIS, Wright Area Coal Lease Applications ES-35
Executive Summary 

ES-36 Final EIS, Wright Area Coal Lease Applications

LNCM boundary of 49.61 μg/m3 in 2015 (Figure ES-9), one of two projected 

worst-case years used for the model. 

Moderately adverse short-term impacts to air quality are currently present at 

the North Antelope Rochelle Mine due to existing mine operations, and would 

be extended onto the North and South Porcupine LBA Tracts during the time 

the tracts are mined if leases are issued. Air quality modeling for the current 

North Antelope Rochelle Mine permit predicted no exceedances of the annual 

PM10 WAAQS and NAAQS at the permitted production level of 140 mmtpy. The 

mine’s current and anticipated future production rate is approximately 95 

mmtpy. The dispersion model showed a maximum concentration on the North 

Antelope Rochelle Mine LNCM boundary of 39.24 μg/m3 in 2017 (Figure ES10), one of two projected worst-case years used for the model. 

There would be an increase in stripping ratio in each of the LBA tracts 

compared to the applicant mines’ current leases, which could result in an 

increase in fugitive emissions per ton of coal mined from current levels due to 

the increased volume of overburden that would have to be removed to recover 

the coal. The increase in fugitive dust emissions could potentially be 

moderated somewhat if removal of the larger volume of overburden material 

results in a slower rate of mining advancement through the LBA tracts, thus 

decreasing the total annual disturbance acreage and causing haul distances to 

increase more slowly. Particulate emissions are nevertheless expected to 

remain within daily and annual limits. 

There have been no exceedances of the annual PM10 standards documented by 

the Black Thunder Mine through 2009. There were a total of six exceedances 

of the 24-hour PM10 particulate standards at the Black Thunder Mine from 

2001 through 2006. All six exceedances were associated with elevated wind 

speeds exceeding 20 miles per hour (mph). Prior to 2007, there was no 

mechanism in place to account for exceedances demonstrated to be the result 

of natural events. The WDEQ/AQD collaborated with the Wyoming Mining 

Association (WMA) to develop a Natural Events Action Plan (NEAP) for the coal 

mines of the PRB, based on EPA Natural Event Policy guidance. Under certain 

conditions, excessive PM10 concentrations resulting from dust raised by 

exceptionally high winds or other natural events will be treated as 

uncontrollable natural events. There was one exceedance of the 24-hour PM10

particulate standards at the Black Thunder Mine reported in 2007, which was 

designated as an exceptional event under the NEAP due to high winds and no 

violation was issued to the mine. There was one exceedance of the 24-hour 

PM10 particulate standards at the Black Thunder Mine in 2008, and the EPA 

determined that it was not an exceptional event and a notice of violation was 

subsequently issued. There were no exceedances of the 24-hour PM10

particulate standards reported by the mine in 2009. 

There has been one exceedance of the 24-hour PM10 NAAQS since PM10

monitoring began at the Jacobs Ranch Mine and no exceedances of the annual 

PM10 NAAQS. 
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Keeline

Road Jacobs

BNSF & UP RR

Hilight Road Hilight Road

Road

Keeline Road

Road

State

450 Highway

BNSF & UP RR

State Highway 450

Shroyer

Small Road

PM10=44.70 μg/m3 (2013)

PM10=49.61 μg/m3 (2015)

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Receptor Location

Area Source (2013)

Ambient Air Boundary

Haul Roads

LEGEND

Existing Jacobs Ranch Mine

Federal Coal Leases

Jacobs Ranch Mine Permit Boundary

West Jacobs Ranch LBA Tract as Applied for

West Jacobs Ranch LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Area Source (2015)

Figure ES-9. Maximum Modeled PM10 Concentrations at the Jacobs Ranch Mine Ambient Air Boundary for

the Years 2013 and 2015.

Executive Summary

Final EIS, Wright Area Coal Lease Applications ES-37
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School Creek

Hilight

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Road

BNSF & UP RR

Matheson Road

Mackey Road

MathesonRoad

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PM10=39.2 μg/m3

NOx=55.2 μg/m3

EAST

PIT

MIDDLE

PIT

WEST

PIT

0 5000 10000 20000

GRAPHIC SCALE (FEET)

LEGEND

Existing North Antelope Rochelle

Mine Federal Coal Leases

North Antelope Rochelle Mine Permit Boundary

North Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

North Porcupine LBA Tract as Applied for

South Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

South Porcupine LBA Tract as Applied for

Receptor Location

Area Source

Ambient Air Boundary

Haul Roads

Figure ES-10. Maximum Modeled PM10 and NOX

 Concentrations at the North Antelope Rochelle Mine

Ambient Air Boundary for the Year 2017.

Executive Summary

ES-38 Final EIS, Wright Area Coal Lease Applications
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-39 

There have been no exceedances of the annual PM10 standards documented by 

the North Antelope Rochelle Mine through 2009. There were two exceedances 

of the 24-hour PM10 particulate standards at the North Antelope Rochelle Mine 

from 2001 through 2006. Both exceedances were associated with elevated 

wind speeds exceeding 20 mph, which could have qualified as a high wind 

event under the NEAP. There were two exceedances of the 24-hour PM10

particulate standards reported in 2007 at the mine, both of which have been 

designated by EPA as exceptional events under the NEAP and will not be 

considered when determining the region’s air quality designation. There were 

no exceedances of the 24-hour PM10 particulate standards reported by the 

North Antelope Rochelle Mine in 2008 and 2009. 

Low-lying, gaseous orange clouds containing NO2 that can be transported by 

wind can sometimes form from overburden blasting prior to coal removal. EPA 

has expressed concerns that NOx levels in some blasting clouds may be 

sufficiently high at times to cause human health effects. Because of these 

incidents, WDEQ/LQD has directed some mines to take steps designed to 

mitigate the effects of NO2 emissions occurring from overburden blasting. To 

date, there have been no reported events of public exposure to NO2 from 

blasting activities at the Jacobs Ranch and North Antelope Rochelle mines. 

The WDEQ has not required the mines to implement any specific measures to 

control or limit public exposure to NO2 from blasting, although the mines have 

instituted voluntary blasting restrictions to avoid NOx impact to the public. 

Black Thunder Mine received several reports of public exposure to NO2 from 

blasting prior to 2001. Measures to control or limit future such incidences, 

which are part of Black Thunder Mine’s settlement agreement, have been 

instituted when large overburden blasts are planned at that mine. 

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. NOx modeling was also conducted in 

support of the three applicant mines’ most recent air quality permit 

applications, and impacts from the worst-case years fall well below the annual 

NO2 NAAQS of 100 μg/m3. 

Motor vehicle exhaust and industrial emissions, gasoline vapors, and chemical 

solvents as well as natural sources emit NOX and VOCs that help form ozone 

(O3). Ozone monitoring is not required by WDEQ/AQD at the PRB coal mines, 

but levels have been monitored by WDEQ/AQD at its ambient air quality 

monitoring sites in the PRB since 2001. No exceedances of the O3 standard 

have occurred at either of the two monitoring sites when evaluated under the 

standard in place at the time the values were recorded. 

Public exposure to emissions from surface mining operations 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 North Hilight Field, South Hilight Field, West Hilight 
Executive Summary 

ES-40 Final EIS, Wright Area Coal Lease Applications

Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts 

are shown in Figure ES-11 through ES-16, respectively. 

► Groundwater

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

the coal within the six WAC LBA tracts. The coal aquifer and any waterbearing strata in the overburden would be removed and replaced with relatively 

homogeneous, unconsolidated backfill. 

A continuous cone of depression currently exists around the southern group of 

mines (Black Thunder, Jacobs Ranch, North Antelope Rochelle, and Antelope) 

due to their proximity to each other and the cumulative drawdown effects from 

pit dewatering and nearby CBNG development. Water level drawdowns have 

propagated much farther and in a more consistent manner in the Wyodak coal 

seam aquifer than in the overburden. Historical groundwater level monitoring 

data collected by the mines indicate that the groundwater flow directions in the 

Wyodak coal have been greatly influenced by surface mine dewatering and 

groundwater discharge associated with CBNG development. Groundwater 

levels observed near active mining areas prior to 1997 were likely due to mine 

dewatering alone and the groundwater flow direction within the coal aquifer 

was typically toward the mines where it would drain by gravity into the open 

pits. By year 2000, groundwater level decline rates had dramatically increased 

because drawdown caused by widespread CBNG development west of the 

mines was overlapping with drawdown caused by mining operations. Roughly 

30 years of surface mining and the more recent CBNG development have 

resulted in complete dewatering of the coal aquifer in localized areas, 

particularly near the mines’ pits and where the coal seams are structurally 

highest. The extent of drawdown in the coal aquifer west of each mine that is 

specifically attributable to mine dewatering can be estimated; however, the 

accuracy of those estimates cannot be tested or observed in the real world 

because drawdown related only to mining is a relatively small impact that is 

masked by the much larger drawdown that is due to CBNG development in the 

area. 

The rate and extent of the actual drawdown in the coal is currently much 

greater than the life-of-mine drawdown predictions. This has occurred as 

drawdown caused by extensive CBNG development west of the existing mine 

permit areas has overlapped with drawdown caused by mining operations. 

Continued drawdown effects from CBNG withdrawals are probable; therefore, 

future drawdown to the Wyodak coal aquifer from mining the approved leases 

and the WAC LBA tracts would be expected to be negligible due to the fact that 

the coal seam has essentially been dewatered in the general Wright analysis 

area. The area of drawdown in the discontinuous overburden aquifers would 

be smaller. 

Figure ES-17 depicts the extrapolated extent of the 5-foot cumulative 

drawdown contour within the Wyodak coal aquifer resulting from the group of 
Breen

Keeline

Road Jacobs

State

BNSF & UP RR

Hilight Road

Hilight Road

Road Lawver Road

Road

Highway 450

Small

Road

31

30

19

18

7

6

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

20

17

8

5

21

16

9

4

22

15

10

3

23

14

11

2

24

13

12

1

19

18

7

6

20

17

8

5

21

16

9

4

22

15

10

3

23

14

11

2

24

13

12

1

19

18

7

6

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

32

29

20

33

28

21

34

27

22

35

26

23

36

25

24

31

30

19

32

29

20

33

28

21

34

27

22

35

26

23

36

25

24

31

30

19

R. 70 W. R. 69 W.

R. 70 W. R. 69 W.

T.

45

N.

T.

44

N.

T.

45

N.

T.

44

N.

JACOBS RANCH

MINE OFFICE

BLACK THUNDER MINE OFFICE

B

B

B

Shroyer

Road

Black Thunder Mine Permit Boundary

Existing Black Thunder

Mine Federal Coal Leases

LEGEND

Single Occupied Residence

B School Bus Stop

Multiple Occupied Residences

Exist Within this Area

(Boundaries are Approximate)

North Hilight Field LBA Tract as Applied for

0 5000 10000 20000

GRAPHIC SCALE (FEET)

North Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure ES-11. Residences, School Bus Stops, Public Roads, and Other Publicly Accessible Facilities in the

Vicinity of the North Hilight Field LBA Tract Under Alternative 2.

Executive Summary

Final EIS, Wright Area Coal Lease Applications ES-41
Reno Road

State

Antelope

Edwards

Matheson Road

Reno Road

Hilight Road

Highway 450

Road

Road

BNSF & UP RR

Small Road

Mackey Road

31

30

32

29

33

28

34

27

35

26 25

31

30

32

29

33

28

34

27

35

26

36

25

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

25

24

13

12

36

25

36

25

24

13

12

1

25

24

13

12

1

30

19

18

7

6

29

20

17

8

5

28

21

16

9

4

27

22

15

10

3

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

29

20

17

8

5

28

21

16

9

4

27

22

15

10

3

26

23

14

11

2

25

24

13

12

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

R. 72 W. R. 71 W.

R. 72 W. R. 71 W.

BLACK THUNDER

MINE OFFICE JACOBS RANCH

MINE OFFICE

Hilight Road

South Hilight Field LBA Tract as Applied for

Black Thunder Mine Permit Boundary

Existing Black Thunder

Mine Federal Coal Leases

LEGEND

Single Occupied Residence

0 5000 10000 20000

GRAPHIC SCALE (FEET)

South Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

No school bus stops exist in the vicinity of the BLM

study area for the South Hilight Field LBA Tract.

Figure ES-12. Residences, School Bus Stops, Public Roads, and Other Publicly Accessible Facilities in the

Vicinity of the South Hilight Field LBA Tract Under Alternative 2.

Executive Summary

ES-42 Final EIS, Wright Area Coal Lease Applications
Cosner County

Road Jacobs

State

Antelope

Edwards

State Highway 387

Matheson Road

Reno Road

State 59 Highway

State

 59 Highway

Hilight Road Hilight Road

Highway 450

Road

Road

BNSF & UP RR

Small Road

31

30

19

18

32

29

20

17

33

28

21

16

31

30

19

18

32

29

20

17

33

28

21

16

34

27

22

15

35

26

23

14

36

25

24

13

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

33

28

21

16

34

22

15

35

26

23

14

36

25

24

13

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

16

9

4

15

10

3

14

11

2

13

12

1

18

7

6

17

8

5

16

9

4

15

10

3

14

11

2

13

12

1

18

7

6

17

8

5

16

9

4

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

R. 72 W. R. 71 W.

R. 72 W. R. 71 W.

BLACK THUNDER

MINE OFFICE

BUSINESS

BUSINESS

Road

Shroyer

Road

B

B

B

Wright, Wyoming

Town Site

Black Thunder Mine Permit Boundary

Existing Black Thunder

Mine Federal Coal Leases

LEGEND

Single Occupied Residence

B School Bus Stop

Multiple Occupied Residences

Exist Within this Area

(Boundaries are Approximate)

West Hilight Field LBA Tract as Applied for

0 5000 10000 20000

GRAPHIC SCALE (FEET)

West Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA Tract Under Alternative 3

Figure ES-13. Residences, School Bus Stops, Public Roads, and Other Publicly Accessible Facilities

in the Vicinity of the West Hilight Field LBA Tract Under Alternative 2.

Executive Summary

Final EIS, Wright Area Coal Lease Applications ES-43
33 34 35 32 33 34 35 R. 71 W. R. 70 W. 32 33 59 Hilight

R. 72 W. R. 71 W.

33

28

34

27

35

26

36 31 32

29

33

28

34

27

35

26

36 31 32

29 28

31

30

19

18

7

6

32

29

20

17

8

5

28

21

16

9

19

18

7

6

20

17

8

5

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

30

19

29

20

28

21

27

22

15

10

3

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

29

20

17

8

5

28

21

9

21

16

9

4

22

15

10

3

23

14

11

2

24

13

12

1

28

21

27

22

26

23

25

24

T.

45

N.

T.

44

N.

R. 71 W. R. 70 W.

Cosner County Road

Keeline

Road Jacobs

Small BNSF & UP RR

State

 59 Highway State Highway

Hilight Road Road

Road

Road

Road BNSF & UP RR

Shroyer

R. 72 W. R. 71 W.

T.

44

N.

T.

43

N.

T.

44

N.

T.

43

N.

T.

45

N.

T.

44

N.

BLACK THUNDER MINE OFFICE

State

450 Highway

BUSINESS

B

Wright, Wyoming

Town Site

31

30

32

29

33

28

18

7

6

17

8

5

16

9

4

33

28

34

27

35 36

25

16

9

4

15

10

3

14

11

2

13

12

1

State

State Highway 450

387 Highway

BUSINESS

BUSINESS

26

B

B

LEGEND

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Single Occupied Residence

B School Bus Stop

Multiple Occupied Residences,

Businesses, and Roads Exist Within this

Area (Boundaries are Approximate)

Existing Jacobs Ranch Mine

Federal Coal Leases

Jacobs Ranch Mine Permit Boundary

West Jacobs Ranch LBA Tract as Applied for

West Jacobs Ranch LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure ES-14. Residences, School Bus Stops, Public Roads, and Other Publicly Accessible Facilities in the

Vicinity of the West Jacobs Ranch LBA Tract Under Alternative 2.

Executive Summary

ES-44 Final EIS, Wright Area Coal Lease Applications
31

30

19

32

29

20

33

28

21

34

27

22

35

26

23

36

25

31

30

32

29

20

33

28

21

34

27

22

35

26

23

36

25

31

30

32

29

20

28

21

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

28

21

16

9

31

30

19

18

7

6

32

29

20

17

8

5

28

21

16

9

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

6

8

5

7

6

8

5

9

4

10

3

11

2

1 6

8

5

9

4

10

3

11

2 1

T.

42

N.

T.

41

N.

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

Converse County

Campbell County

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

T.

42

N.

T.

41

N.

Reno Road

Mackey

Antelope

Edwards

Matheson Road

Reno Road School

Creek

BNSF & UP RR

Hilight Road

State

Highway 450

Road

Road

Road

Antelope Road

Road

Matheson Road

Mackey Road

T.

41

N.

T.

40

N.

T.

41

N.

T.

40

N.

25

24

25

24

13

12

13

12

T.

43

N.

T.

42

N.

T.

43

N.

T.

42

N.

NORTH ANTELOPE ROCHELLE

MINE OFFICE

BUSINESS

0 6000 12000 24000

GRAPHIC SCALE (FEET)

LEGEND

No occupied residences, school bus stops, or other

publicly accessible facilities exist in the vicinity of the

BLM study area for the North Porcupine LBA Tract.

Existing North Antelope Rochelle

Mine Federal Coal Leases

North Antelope Rochelle Mine Permit Boundary

North Porcupine LBA Tract as Applied for

North Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure ES-15. Residences, School Bus Stops, Public Roads, and Other Publicly Accessible Facilities in the

Vicinity of the North Porcupine LBA Tract Under Alternative 2.

Executive Summary

Final EIS, Wright Area Coal Lease Applications ES-45
31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

7

6

8

5

9

4

10

3

11

2 1

6

8

5

9

4

10

3

11

2

12

1

T.

42

N.

T.

41

N.

R. 71 W. R. 70 W.

Converse County

Campbell County

R. 71 W. R. 70 W.

T.

42

N.

T.

41

N.

Reno Road

Mackey

Antelope

Edwards

Matheson Road

Reno Road

School

Creek

Hilight

Road

Road Road Road

Antelope Road

Road

BNSF & UP RR

Matheson Road

Mackey Road

T.

41

N.

T.

40

N.

T.

41

N.

T.

40

N.

NORTH ANTELOPE ROCHELLE

MINE OFFICE

ANTELOPE MINE OFFICE

BUSINESS

0 5000 10000 20000

GRAPHIC SCALE (FEET)

LEGEND

Existing North Antelope Rochelle

Mine Federal Coal Leases

North Antelope Rochelle Mine Permit Boundary

South Porcupine LBA Tract as Applied for

South Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

No occupied residences or school bus stops

exist in the vicinity of the BLM study area for

the South Porcupine LBA Tract.

Figure ES-16. Residences, School Bus Stops, Public Roads, and Other Publicly Accessible Facilities in the

Vicinity of the South Porcupine LBA Tract Under Alternative 2.

Executive Summary

ES-46 Final EIS, Wright Area Coal Lease Applications
Savageton Road

Moore Road

Todd Road

Mills Road

Clarkelen Road

Cosner

Breen

Hoadley

Lawver Road Jacobs

Mackey

Antelope

Edwards

State Highway 50

State Highway 387

Matheson Road

Reno Road

BNSF & UP RR

State 59 Highway

State

 59

Highway

Hilight Road

Road

Road

Road Lawver Road

Keeline

Road

State 450 Highway

Road

Road

Antelope

Road

Road

Wagensen

Road

Matheson

Road

T.

46

N.

 R. 75 W.

Weston County

Campbell County

Converse County

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

T.

40

N.

T.

39

N.

 R. 74 W. R. 73 W. R. 72 W. R. 71 W. R. 70 W. R. 69 W.

 R. 75 W. R. 74 W. R. 73 W. R. 72 W. R. 71 W. R. 70 W. R. 69 W.

T.

46

N.

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

T.

40

N.

T.

39

N.

Campbell County

County Road

State Highway 387

5'

5'

5'

TOWN OF

WRIGHT

LEGEND

Existing Lease Boundary

0 18000 36000 72000

GRAPHIC SCALE (FEET)

Extent of WDEQ's Cumulative and Extrapolated

Life of Mine Drawdown (5 feet) with

Wright Area Coal LBA Tracts

Clinker

Approximate Wyodak Coal Outcrop

Clinker and coal outcrop information modified from

Plate 1 in Heffern and Coates (2000).

Groundwater cumulative impact area information taken

from Plate 1 in WDEQ-CHIA-19 (Ogle and Calle 2006).

West Jacobs Ranch LBA Tract as Applied for

South Hilight Field LBA Tract as Applied for

West Hilight Field LBA Tract as Applied for

North Porcupine LBA Tract as Applied for

North Hilight Field LBA Tract as Applied for

South Porcupine LBA Tract as Applied for

5'

Figure ES-17. Extrapolated Extent of Life of Mine Cumulative Drawdown Within the Wyodak Coal Aquifer

With the Addition of Wright Area Coal LBA Tracts.

Executive Summary

Final EIS, Wright Area Coal Lease Applications ES-47
Executive Summary 

ES-48 Final EIS, Wright Area Coal Lease Applications

four southern mines (Jacobs Ranch, Black Thunder, North Antelope Rochelle, 

and Antelope) in the Wright subregion with the addition of the six WAC LBA 

tracts. Analysis of the cumulative impacts as a result of mining was performed 

by qualitatively assessing the additive impacts of these mines. Each mine is 

required by WDEQ/LQD to evaluate the impacts to the hydrologic resources 

and will typically model groundwater level drawdown using the most 

conservative, worst-case scenario. The extent of the 5-feet drawdown contour 

is used by WDEQ/LQD to assess the extent of the impact to the groundwater 

system caused by mining operations. The predicted maximum 5-foot 

drawdown contour for the Wyodak coal aquifer from the four Wright area coal 

mines was superimposed by Ogle and Calle (2006) to generate the 5-foot 

cumulative estimate. 

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. Total dissolved solids (TDS) levels in groundwater from the 

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

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

standards for use as livestock water. 

Mining does not directly disturb aquifers below the mineable coal, but many 

PRB mines use them for industrial water supply wells. In a few cases there 

have been drawdowns in the subcoal aquifer due to leakage into mine pits, 

dewatering, and CBNG development (BLM 2001a). All three of the applicant 

mines located within the general Wright analysis area utilize water supply wells 

completed in aquifers stratigraphically below the Wyodak coal. If these six 

WAC LBA tracts are leased by the applicant mines, water would be produced 

from these wells for a longer period of time and the mines would probably not 

require additional sub-coal wells to mine and reclaim the LBA tracts. 

► Surface Water 

Tributary streams of the Cheyenne River drain the general Wright analysis 

area. From north to south, the general Wright analysis area is drained by 

Black Thunder Creek, North Prong Little Thunder Creek, Little Thunder Creek, 

Porcupine Creek, Horse Creek, and Antelope Creek. North Prong Little 

Thunder Creek is a tributary of Little Thunder Creek, which is a tributary of 

Black Thunder Creek. Porcupine Creek and Horse Creek are tributaries of the 

Antelope Creek. Black Thunder Creek and Antelope Creek are both major 

tributaries of the Cheyenne River. Typical of this semi-arid area, these 

streams, with the exception of Antelope Creek, are all ephemeral, receiving flow 

contributions primarily from convective thunderstorm runoff and, to a lesser 

extent, from snowmelt runoff in the spring. Surface water quality varies with 

flow and/or season. Playas that are formed by natural topographic 

depressions are common in the general Wright analysis area and portions of 

each tract’s general analysis area are internally drained. Springs are 

uncommon in this area and none have been identified within the general 

analysis areas of these six LBA tracts. 
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-49 

Changes in runoff characteristics and sediment discharges would occur during 

mining of the WAC LBA tracts 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 the SMCRA and Wyoming 

state statutes, once mining is complete the pits would be backfilled and 

drainage would be reestablished. Surface water drainages would be restored to 

approximate premine conditions and blend with the existing drainage system 

above and below the disturbance area. Surface water flow, quality, and 

sediment discharge would approximate premining conditions. 

► Alluvial Valley Floors 

AVF investigations conducted within and near the general Wright analysis area 

have identified AVFs that occur along Little Thunder Creek, North Prong Little 

Thunder Creek, and Porcupine Creek; however, those lands are located at 

considerable distances downstream of the six Wright area LBA tracts. Based 

on existing and preliminary AVF evaluations within the general Wright analysis 

area, AVF characteristics on drainages are negligible. An AVF assessment 

would be part of the mine permitting process if a tract is leased and proposed 

for mining, and formal declarations of the presence or absence of an AVF, its 

significance to agriculture, and the appropriate perimeter (areal extent) would 

be made by the WDEQ/LQD. AVFs that are not significant to agriculture can 

be disturbed during mining but must be restored as part of the reclamation 

process. It is reasonable to assume that the WDEQ/LQD would determine that 

no AVFs are present within any of the Wright area LBA tracts that are leased. 

Should declarations be made within any LBA tracts that are leased, it is 

reasonable to assume that mining would be permitted because all of the 

proposed lease areas consist entirely of undeveloped rangeland. 

► Wetlands 

Formal wetland delineations have been confirmed by the U.S. Army Corps of 

Engineers (COE) for wetlands and Other Waters of the U.S. (OWUS) included in 

the general analysis areas for the Wright area LBA tracts that lie within the 

applicant mines’ existing permit areas. Preliminary wetlands inventories of the 

LBA tracts’ general analysis areas that have not been formally evaluated, based 

on U.S. Fish and Wildlife Service (USFWS) National Wetlands Inventory (NWI) 

mapping, vegetation mapping, review of color infrared aerial photographs, and 

field survey reconnaissance were conducted in 2007 and 2008. Based on those 

previous wetland delineation surveys and the preliminary wetland inventories 

of the general analysis areas for the six Wright area LBA tracts, a maximum of 

approximately 602 acres of wetlands and OWUS would be disturbed if all the 

LBA tracts are leased and subsequently mined under Alternative 2, BLM’s 

preferred alternative for each tract. These wetlands and OWUS were found 

within five general land categories: ephemeral streams, playas, 

ponds/reservoirs, isolated depressions, and excavated upland areas. At this 

time, a distinction has not been made between jurisdictional and non-
Executive Summary 

ES-50 Final EIS, Wright Area Coal Lease Applications

jurisdictional acreages of wetlands and OWUS since only the COE has the 

authorization to make such determination. 

Formal wetland inventories covering the remainder of the general analysis 

areas for the LBA tracts that are leased would be conducted and submitted to 

the COE for verification as part of the process of obtaining a surface 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 number of jurisdictional wetland 

acreages. Disturbed non-jurisdictional wetlands would be restored as required 

by the authorized federal or state agency or private surface land owner as 

specified in the mine permit, which would have to be approved by WDEQ/LQD 

before mining operations could be conducted on the LBA tracts that are leased. 

► Soils

Baseline soil surveys cover the general analysis areas for these six LBA tracts. 

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. 

Consequences from the salvage and redistribution of soils during mining and 

reclamation of each LBA tract that is leased would include changes in physical, 

biological, and chemical properties of the soil resources. Following 

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

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

chemical composition. 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 reclaimed land. The baseline soils 

analyses indicate that the amount of suitable topsoil that would be available 

for redistribution on all disturbed acres within the six general analysis areas 

during reclamation would vary from an average depth of 2-3 feet. The 

redistributed soil would be more uniform in type, thickness, and texture, and it 

would be adequate in quantity and quality to support planned postmining land 

uses (i.e., wildlife habitat and rangeland). 

► Vegetation 

The vegetation analysis area for each of the six LBA tracts is the respective 

tract’s general analysis area. These vegetation analysis areas are either 

partially located within, contiguous to, or completely within applicant mines’ 

existing permit boundaries. Consequently, portions or all of these vegetation 

analysis areas were previously mapped and sampled in accordance with the 

current WDEQ/LQD mine permitting requirements. The balance of the 

vegetation assessments were completed in 2007. 
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-51 

In terms of total acres of occurrence within the combined vegetation analysis 

areas, the predominant vegetation types are the Big Sage Shrubland (42.2 

percent), Upland/Mixed Prairie Grassland (27.8 percent), and Crested 

Wheatgrass/Agricultural Pastureland (15.3 percent). The most common plant 

species on these types include Wyoming big sagebrush, western wheatgrass, 

needleandthread, blue grama, crested wheatgrass, red threeawn, Sandberg 

bluegrass, prairie junegrass, cheatgrass brome, sixweeksgrass, and upland 

sedges. Wyoming big sagebrush is the dominant shrub in the Big Sage 

Shrubland and Upland/Mixed Prairie Grassland vegetation communities. 

Annual grasses and forbs, lichens, and manyspine plains pricklypear cactus 

are frequently large components of the vegetation cover. 

Mining would progressively remove this native vegetation. Reclamation, 

including 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 tracts. 

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. A reduction in shrubs would result in a long-term reduction 

of habitat carrying capacity for some species and may delay use of the 

reclaimed area by shrub-dependent species. Following completion of 

reclamation (seeding with the approved seed mixture) and before release of the 

reclamation bond (a minimum of 10 years), a diverse, effective, and permanent 

vegetative cover would be established on the LBA tracts. 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 tracts would also include steps to 

control invasion by weedy (invasive, nonnative) plant species. 

► Wildlife

Background information on wildlife in the general Wright analysis area was 

drawn from several sources, including Wyoming Game and Fish Department 

(WGFD) and U.S. Fish and Wildlife Service (USFWS) records, the Wyoming 

Natural Diversity Database (WYNDD), recent PRB federal coal lease application 

EIS documents (available for public review on Wyoming BLM’s website at 

http://www.blm.gov/wy/st/en.html), and personal contacts with WGFD and 

USFWS biologists. Site-specific data for the North Hilight Field, South Hilight 

Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South 

Porcupine LBA Tracts were obtained from several sources, including baseline 

information contained in WDEQ/LQD mine permit applications and annual 

wildlife monitoring reports for the applicant mines and nearby coal mines. In 

accordance with the current WDEQ/LQD mine permitting requirements, 

wildlife baseline surveys and annual monitoring surveys extend 1 to 2 miles 

beyond the mine permit area, depending on the mine and the species. 
Executive Summary 

ES-52 Final EIS, Wright Area Coal Lease Applications

Due to the proximity of the proposed lease areas to the adjacent applicant mine 

permit areas, the general analysis areas for these six LBA tracts have received 

some level of coverage annually since the early 1980s. Increasing percentages 

of the general analysis areas were included in annual monitoring efforts as 

survey areas for the adjacent mines have been expanding due to previous coal 

lease acquisitions and subsequent permit area amendments. In addition, 

TBCC conducted baseline investigations during 2006 and early 2007 

specifically for the West Hilight Field LBA Tract with additional surveys 

targeting the North and South Hilight Field LBA Tracts in 2007 and 2008; 

JRCC conducted baseline investigations in 2007 and 2008 expressly for the 

West Jacobs Ranch LBA Tract; and PRC conducted baseline investigations 

during 2007 and early 2008 specifically for the North and South Porcupine 

LBA Tracts. These surveys covered the respective general analysis areas, and 

surveys for selected wildlife information such as raptor nest and Greater sagegrouse lek locations included in a 2-mile perimeter surrounding the general 

analysis areas. Site-specific surveys for each lease area and appropriate 

perimeters would be part of the mine permitting process if the tracts are 

leased. 

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). Direct impacts of 

surface coal mining on wildlife occur during mining and are therefore 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 active mining areas (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. Displaced animals by find equally 

suitable habitat that is not occupied by other animals, or occupy poorer quality 

habitat than that from which they were displaced. Indirect impacts are longer 

term and include alterations in topography and vegetative cover, particularly 

the reduction in shrub density, and could cause a decrease in carrying 

capacity for some species and a decrease in vegetation diversity. Mining 

companies have initiated efforts in recent years to increase the diversity of 

post-mine topography and to increase the amount of sagebrush in the 

reclamation. 

The six Wright area LBA tracts do not include any unique or crucial big game 

habitat or migration corridors. The two big game species that are common in 

suitable habitat throughout the general Wright analysis area are pronghorn 

and mule deer. A resident elk herd resides in the Rochelle Hills east of the 

general Wright analysis area, and elk do wander from the protection of the hills 

to forage in native and reclaimed grasslands in the vicinity of the general 

Wright analysis area. As more lands are reclaimed from mining, elk are 

shifting their winter use to these areas. Habitat disturbance and big game 

displacement would be incremental, occurring over several years and allowing 
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-53 

for gradual changes in distribution patterns. Big game have continued to 

occupy areas adjacent to and within active mining operations, suggesting that 

some animals may become habituated to such disturbances. 

Those raptor species that commonly nest in the general Wright analysis area 

are the golden eagle, ferruginous hawk, red-tailed hawk, Swainson’s hawk, 

burrowing owl, and great horned owl. American kestrels, northern harriers, 

and short-eared owls intermittently nest in the area, as occasional sightings of 

recently fledged young indicate that such activities do occur within the general 

Wright analysis area for one or more of those species, though the nest sites 

themselves may not have been located. Habitat is limited for those species that 

nest exclusively in trees or on cliffs, but several species have adapted to nesting 

on the ground, creek banks, buttes, mine highwalls, or rock outcrops. Roughlegged hawks are winter residents in northeast Wyoming, and breed in the 

arctic regions. Mining the LBA tracts would not impact overall regional raptor 

populations; however, individual birds or pairs may be impacted. Mining 

within or near raptor territories would impact availability of foraging habitat for 

nesting birds. However, increased acreage of reclamation within the permit 

areas would offset new habitat loss as mining progresses. All three applicant 

mines operate under a current USFWS approved Monitoring and Mitigation 

Plan for raptors and other migratory bird species of management concern, and 

have successfully executed mitigation techniques to protect nest productivity. 

Their respective plans would be amended to include the associated LBA tracts 

if they are leased and permitted for mining. The amended plans would be 

subject to review and approval by the USFWS before the amended mine plans 

are approved. 

Four upland game bird species have historically been documented within the 

general Wright analysis area. These species are the mourning dove, gray 

partridge, wild turkey, and Greater sage-grouse. The mourning dove, however, 

is the most prevalent upland game bird in this area, and the only species 

known to occur with any regularity. Based on annual lek searches since the 

late 1970’s, sharp-tailed grouse do not appear to inhabit the surface coal mine 

region of the southern PRB. 

The 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, and 

exhibit seasonal movements to utilize discrete sagebrush habitats. Since 1999, 

the USFWS has received eight petitions requesting that the sage-grouse be 

listed under the Endangered Species Act (ESA) as threatened or endangered. 

Three of the petitions requested that sage-grouse be listed as endangered 

across its entire range. On January 12, 2005, following a 12-month status 

review on the species, the USFWS concluded that listing was not warranted at 

that time. On December 4, 2007, U.S. District Court, District of Idaho, ruled 

that the USFWS 12-month petition finding on sage-grouse was in error and 
Executive Summary 

ES-54 Final EIS, Wright Area Coal Lease Applications

remanded the case back to USFWS for further reconsideration. On February 

26, 2008, the USFWS announced the initiation of another status review for the 

Greater sage-grouse. The USFWS announced on March 5, 2010 its decision to 

classify the Greater sage-grouse as a candidate species under the ESA. The 

USFWS found that listing the Greater sage-grouse (rangewide) was warranted, 

but precluded by higher priority listing actions. 

In 2007, Wyoming Governor Dave Freudenthal commissioned a Statewide 

Sage-grouse Implementation Team which emerged from the Governor’s 2007 

Sage-Grouse Summit. On March 17, 2008, the Implementation Team 

preliminarily identified and mapped recommended sage-grouse core breeding 

areas in Wyoming in an effort to better understand what types of habitat the 

grouse prefer and what areas should be protected. The general Wright analysis 

area is not located within the mapped core breeding areas. On August 1, 2008, 

the Governor Freudenthal released an executive order regarding sage-grouse 

core area protection (Office of the Governor of Wyoming 2008). The sagegrouse focus area protection concept came about as a result of work by the 

Sage-grouse Implementation Team. The Implementation Team developed a 

Core Population Strategy for the state of Wyoming “to maintain habitats and 

viable populations of sage-grouse in areas where they are most abundant.” 

The BLM Wyoming State Office is in the process of developing a state-wide 

sage-grouse management policy and has incorporated sage-grouse focus areas 

based on the core area concept in the draft management policy. 

The Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines have 

conducted surveys of known sage-grouse leks and searches for new leks as 

part of their wildlife baseline inventories and wildlife monitoring programs 

since the early 1980s. As a result, most of the general analysis areas for the 

six Wright area LBA tracts have been included in previous regular survey 

efforts. A total of 10 sage-grouse leks have been documented on and within 2 

miles of the six combined general analysis areas. Four of the leks have been 

active during recent survey years and are classified as occupied; two leks have 

not been attended by displaying grouse for at least the last 10 years and are 

classified as unoccupied/abandoned; two leks have been removed by mining 

activities and are classified as unoccupied/destroyed; there has been no 

documented activity for the last 10 years at two leks, but survey information is 

insufficient to designate them as unoccupied, so they are classified as 

undetermined. Two of the four occupied leks likely represent a shift in lekking 

activity rather than two distinct leks. 

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. 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, but monitoring of sage-grouse activities has indicated 

that the birds may change lek sites. Following reclamation, there may be a 

long term loss of nesting and winter habitat, depending on the amount of 
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-55 

sagebrush that is restored relative to the amount of sagebrush that is present 

before mining. Should these six LBA tracts 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. Until 

sagebrush returns to its premining density levels, there would be a reduction 

in potential habitat for wildlife species associated with the habitat in the 

general Wright analysis area. However, given the limited presence of sage 

stands in the area, it is not likely that many sagebrush obligates would be 

affected. Estimates for the time it would take to restore shrubs, including 

sagebrush, to pre-mine density levels range from 20 to 100 years, which may 

delay sage-grouse repopulation in the reclaimed areas. 

Two of the four occupied leks are within the BLM study areas for the North 

Hilight Field and North Porcupine LBA Tracts, and are therefore likely to be 

directly impacted if these two tracts are leased and mined under the Proposed 

Action and/or Alternative 2, BLM’s preferred alternative. The 3-mile radii of 

concern for the other two occupied leks (which are likely only one strutting 

ground that has been relocated slightly), overlap the North Porcupine LBA 

Tract. If the North Porcupine LBA Tract as applied for and/or the additional 

areas evaluated by BLM under Alternative 2, the BLM’s preferred alternative, is 

leased and mined, potential nesting habitat for grouse that were bred at these 

leks would likely be affected by mining activity in those areas. 

► Threatened and Endangered Species

T&E plant and animal species that could be present in the general Wright 

analysis area include the Ute ladies’-tresses orchid (threatened) and blowout 

penstemon (endangered). The habitat requirements for, occurrences of, and 

potential project effects on these species are included in Appendix G. 

Dormant Ute ladies’-tresses plants typically persist underground for one to 

many years and can only be reliably documented after several years of repeated 

surveys. Recent USFWS survey requirements therefore recommend that all 

potentially suitable habitat be surveyed annually for three consecutive years 

during the time of year that the orchids are known to flower. 

Areas of potentially suitable habitat for Ute ladies’-tresses within the general 

analysis areas for the North, South and West Hilight Field LBA Tracts were 

surveyed by qualified professionals in August 2008 and August 2009, and no 

orchids were found. In order to satisfy the USFWS survey requirements for the 

species, the third consecutive annual survey of each tract’s general analysis 

area is scheduled in 2010. 

Areas of potentially suitable habitat for Ute ladies’-tresses within the general 

analysis area for the West Jacobs Ranch LBA Tract were surveyed by qualified 

professionals in August 2007, August 2008 and August 2009, and no orchids 

were found. 
Executive Summary 

ES-56 Final EIS, Wright Area Coal Lease Applications

Areas of potentially suitable habitat for Ute ladies’-tresses within the general 

analysis areas for the North and South Porcupine LBA Tracts were surveyed by 

qualified professionals in 2005, 2006, 2007 and 2009, and no orchids were 

found. Those surveys covered only USFS lands (TBNG) and therefore did not 

include all areas of suitable habitat (on both USFS and private lands) within 

the general analysis areas for the North and South Porcupine tracts. In order 

to satisfy the USFWS survey requirements for the species, surveys of the tracts’ 

general analysis areas are scheduled in 2010 and 2011. 

The blowout penstemon, one of Wyoming’s rarest native plants, is a regional 

endemic species of the Sandhills of west-central Nebraska and the 

northeastern edge of the Great Divide Basin in Wyoming. In Wyoming, the 

species is currently known from just three populations, which all occur in the 

Ferris Dunes area located in the northwestern part of Carbon County. The 

general Wright analysis area is located approximately 150 miles northwest of 

the known occurrences in the Nebraska Sandhills and approximately 150 miles 

northeast of the three known populations in Carbon County, Wyoming. The 

species is most common in the open, sandy habitats or wind-excavated 

depressions (crater-like blowouts) in dune tops. In Wyoming, blowout 

penstemon is found in sparsely vegetated sandy blowouts in the early stages of 

plant community development. 

No areas of potentially suitable habitat for the blowout penstemon have been 

identified within the general analysis area for each of the six WAC LBA tracts. 

No blowout penstemon or plants commonly associated with the species 

(blowout grass, lemon scurfpea and thickspike wheatgrass) were found during 

the baseline vegetation surveys of all six tracts, which were conducted in 2007 

and/or 2008 by qualified professionals. 

► Land Use and Recreation 

Leasing and subsequently mining the Wright area LBA tracts would preclude 

other land uses. The temporary reduction of livestock grazing, incremental loss 

of wildlife habitat (particularly big game), and curtailment of oil and gas 

development while the areas are being mined and reclaimed would result. This 

would include the incremental removal of all existing oil and gas surface and 

downhole production and transportation equipment and facilities. The loss of 

accessibility to these lands would be long term (during mining and 

reclamation), but not permanent. 

The six Wright area LBA tracts configured under Alternative 2, BLM’s preferred 

alternative for each tract, include approximately 12,481 acres of TBNG surface, 

which is administered by the USFS; approximately 7,288 acres of which are 

currently accessible to the public. None of the lands included in the West 

Jacobs Ranch LBA Tract under Alternative 2 are managed by the USFS; thus, 

no federal lands would be removed from public access if that LBA tract were 

leased. Access to the 12,481 acres of federal grazing leases on TBNG surface, 

which are currently held by the Thunder Basin Grazing Association, would be 
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-57 

suspended during mining and reclamation operations on the other five LBA 

tracts. According to the USFS Douglas Ranger District, each mine can close 

access in areas that are actively mined for human health and safety reasons. 

Hunting and other recreational activities on the LBA tracts, including the 

federal surface, would be eliminated during mining and reclamation. The 

federal lands actually represent a relatively small portion of the currently 

accessible public surface lands for recreational opportunity within TBNG. 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). 

Within 10 years after initiation of each reclamation phase, rangeland and 

wildlife use (the historic land uses) would return to near premining levels. 

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 

(USFS). Public access to federal lands would be restored after mining and 

reclamation are complete. 

► Cultural Resources

The general analysis areas of the North Hilight Field, South Hilight Field, West 

Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA 

Tracts have been mostly surveyed for cultural resources at a Class III level. A 

total of 333 cultural sites have been document within the six combined general 

analysis areas (a total of approximately 43,445 acres). Of those 333 sites, 195 

are prehistoric cultural remains, 101 historic cultural remains, 27 multicomponent (both historic and prehistoric) remains, and 10 are of indeterminate 

age and cultural affiliation. 

Of those 333 sites, there are a total of 233 sites that have been evaluated as 

not eligible for nomination to the National Register of Historic Places (NRHP) by 

the State Historic Preservation Office (SHPO) and no further work is required at 

those sites. Nineteen sites have been determined to be eligible for the NRHP by 

SHPO and will have to be avoided or a mitigation plan approved and 

implemented prior to any disturbance. The remaining 81 sites are currently 

considered unevaluated by SHPO and will require additional evaluation and/or 

Native American consultation. The unevaluated sites are to be given the same 

protections as eligible sites and are to be avoided until a determination of 

eligibility have been made. Data recovery plans are required for all sites 

recommended eligible to the National Register following testing and 

consultation with SHPO. Until full consultation with SHPO has been 

completed and agreement regarding NRHP eligibility has been reached, all 

cultural sites within each WAC LBA tract’s general analysis area would be 

protected from disturbance. 

No sites of Native American religious or cultural importance have been 

identified on the North Hilight Field, South Hilight Field, West Hilight Field, 
Executive Summary 

ES-58 Final EIS, Wright Area Coal Lease Applications

West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts. If 

such sites or localities are identified at a later date, appropriate action must be 

taken to address concerns related to those sites. 

► Visual Resources

Currently, mine facilities and mining activities at the southern group of mines 

(Jacobs Ranch, Black Thunder, North Antelope Rochelle, and Antelope) are 

visible from various public-use roads in the general Wright analysis area, 

including State Highway 450, Jacobs Road, Shroyer Road, Keeline Road, 

Hilight Road, Edwards Road, Reno Road, Antelope Road, Mackey Road, and 

Matheson Road. 

Some mining activities on the North, South and West Hilight Field LBA Tracts 

would be visible from State Highway 450. Some of the existing mining 

operations at the Black Thunder and Jacobs Ranch mines are currently visible 

from this highway. Some mining activities on the West Jacobs Ranch LBA 

Tract would be visible from State Highway 450. Portions of the West Hilight 

Field and West Jacobs Ranch tracts may also be visible from State Highway 59. 

Not all of the mining activities on these four LBA tracts would be visible from 

these major highways because of the rolling terrain. Portions of these four LBA 

tracts would also be visible from Keeline Road, Jacobs Road, Shroyer Road, 

Hilight Road, Edwards Road, Reno Road, and Matheson Road. 

Some mining activities on both the North and South Porcupine LBA Tracts 

would be visible from Antelope Road and Matheson Road. Some mining 

activities on the North Porcupine tract would also be visible from the Edwards 

Road, Reno Road, and Mackey Road. Some of the existing mining operations at 

the North Antelope Rochelle Mine are currently visible from these public roads. 

Due to the existing mining activities in the general Wright analysis area, the 

predominant BLM visual resources management (VRM) class is Class IV. This 

classification would not be altered by the leasing and subsequent mining of the 

six WAC LBA tracts under the Proposed Actions or Alternatives 2 and 3. After 

reclamation of the LBA tracts and adjoining mines, the VRM Class IV 

conditions would be improved and the reclaimed land would resemble the 

surrounding undisturbed terrain. No unique visual resources have been 

identified on or near the WAC LBA tracts. 

► Noise

Noise levels on the WAC LBA tracts would be increased considerably by mining 

activities such as blasting, loading, hauling, and possibly in-pit crushing. The 

BNSF & UP rail line currently borders and/or traverses all six LBA tracts; 

therefore, rail traffic noise on the tracts would continue to be proportionate to 

the rate of coal production from the PRB mines in the future. Due to the 

remoteness of the LBA tracts and because mining is already ongoing in the 

area, noise would have few off-site impacts. The five occupied dwellings that 
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-59 

are located within the tracts (two within the North Hilight Field tract and three 

within the West Jacobs Ranch tract) would be vacated prior to advancing 

mining activities. No occupied dwellings would experience adverse noise 

impacts from mining activities if the South Hilight Field, West Hilight Field, 

North Porcupine, and South Porcupine LBA Tracts are leased as applied for or 

under Alternative 2. The two occupied dwellings that are located immediately 

adjacent to the North Hilight Field tract would experience adverse noise 

impacts if mining activities (particularly blasting) occur within 2,500 feet of 

them. 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. 

► Transportation

Essentially all of the coal mined on the Wright area LBA tracts would be 

transported by rail system. Since the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

LBA Tracts would be an extension of the operating applicant mines, the 

existing rail facilities and infrastructure would be used during mining of the 

proposed lease areas. 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 these LBA tracts. The construction of the 

proposed DM&E Railroad expansion into this area is not dependent on leasing 

one or more of the six LBA tracts. 

Some of the coal included in each of the six LBA tracts under both the 

Proposed Action and Alternative 2, BLM’s preferred tract configuration, is 

overlain by portions of various public roads. SMCRA prohibits mining within 

100 feet of the outside ROW line of any public road unless the appropriate 

public road authority allows the road to be relocated or closed after public 

notice, an opportunity for a public hearing, and a finding that the interests of 

the affected public and landowners will be protected. As a result, the coal 

underlying the public road ROWs and adjacent buffer zones has been 

determined to be unsuitable for mining; however, it would be included in the 

LBA tract that is offered for lease in order to allow efficient recovery of 

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

stating that no mining activity may be conducted in the portion(s) of the lease 

within the public road ROW(s) and buffer zone(s) unless the authorized public 

road authorities determine that the road(s) could be abandoned or relocated 

will be attached if a lease is issued for an LBA tract. The applicant mines are 

currently evaluating options to close and/or relocate several county roads in 

order to recover the coal in the proposed leases. 

Vehicular traffic to and from the mines would continue at existing or slightly 

higher levels for an extended period of time, depending on which LBA tracts are 

leased and which alternatives are selected. 
Executive Summary 

ES-60 Final EIS, Wright Area Coal Lease Applications

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. 

► Socioeconomics

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

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

price of $11.06 per ton recovered and a potential range of bonus payments of 

30 to 97 cents per ton, the potential additional federal revenues from the six 

Wright area LBA tracts would range from approximately $3.6 to $7.2 billion, 

depending on the alternative selected and the bonus price at the time the coal 

is leased. The potential additional revenue to the state of Wyoming from the six 

LBA tracts would range from approximately $4.5 to $8.7 billion, depending on 

the alternative selected, the bonus price at the time the coal is leased, and the 

selling price of the coal. Mine life and employment (at or slightly above current 

levels) would be extended for over nearly 23 additional years, depending on the 

LBA tracts involved and which alternatives are selected. 

► Environmental Justice

Economic and demographic data indicate that neither minority populations nor 

people living at or below the poverty level make up a “meaningfully greater 

increment” of the total population in Gillette, Wright or Campbell County than 

they do in the state as a whole. Potentially adverse impacts do not 

disproportionately affect minorities, low-income groups or Native American 

tribes or groups. No tribal lands or Native American communities are included 

in the general Wright analysis area, and no Native American treaty rights or 

Native American trust resources are known to exist for this area. 

► Greenhouse Gas Emissions

Greenhouse gases (GHGs) are an issue because of global warming and climate 

change. Global warming is a theory that certain gases in the atmosphere 

impede the radiation of heat from the earth back into space, trapping heat like 

the glass in a greenhouse. This raises the average temperature of the surface 

of the earth and the lower atmosphere, which contributes to climate change. 

Among these GHGs are carbon dioxide, methane, water vapor, ozone, nitrous 

oxide, hydrofluorocarbons, perfluorocarbons and sulfur hexafluoride. GHGs 

are not currently regulated, but there is a consensus in the international 

community that global climate change is occurring and that it should be 

addressed in governmental decision making. 

Carbon dioxide equivalents (CO2e) is a measurement for describing how much 

global warming a given type and amount of greenhouse gas may cause. The 

total annual CO2e emissions are projected to increase at the Black Thunder, 

Jacobs Ranch and North Antelope Rochelle mines if the North Hilight Field, 

South Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, 
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-61 

and South Porcupine LBA Tracts are added to the mining operations. The 

increases in CO2e emissions are expected to result from the additional fuels 

(especially diesel) that would be used in consideration of the increased coal and 

overburden haul distances, as well as increased use of electricity and 

explosives related to increasing overburden thicknesses. Annual coal 

production rates may also increase over time at the applicant mines. 

The Center for Climate Strategies estimates that activities in Wyoming will 

account for approximately 60.3 million tonnes of gross CO2e emissions in 2010 

and 69.4 million tonnes in 2020. The total CO2e emissions from the three 

applicant mines in 2007 represents 2.22 percent of the 2010 state-wide 

emissions. With the addition of the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

LBA Tracts, the estimated total CO2e emissions at the three applicant mines 

would represent approximately 3.61 percent of the projected 2020 state-wide 

CO2e emissions. 

No Action Alternatives (Alternative 1) 

Under the No Action alternatives for each tract, the coal lease applications 

would be rejected and the areas contained in the applications would not be 

offered for lease at this time. The tracts could be nominated for lease again in 

the future. Under the No Action alternatives, the impacts described in the 

preceding paragraphs to topography and physiology, geology and minerals, air 

quality, water resources, AVFs, wetlands, soils, vegetation, wildlife, T&E 

species, land use and recreation, cultural resources, Native American 

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

occur due to mining the existing Black Thunder, Jacobs Ranch, and North 

Antelope Rochelle mine coal leases, but these impacts would not be extended 

by mining onto the North Hilight Field, South Hilight Field, West Hilight Field, 

West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts. 

Mitigation 

The Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines 

currently approved mining permits include extensive baseline information, 

ongoing monitoring information and commitments, and mitigation measures 

that are required by SMCRA and Wyoming state law. Compliance, mitigation, 

and monitoring measures that are required by regulation are considered to be 

part of the Proposed Actions and Alternatives considered in this EIS. These 

regulatory requirements, mitigation measures and monitoring commitments 

are in place for the No Action Alternative as part of the currently approved 

mining and reclamation plans for the three applicant mines and would be 

included in the permitting processes that would be required to mine the six 

WAC LBA tracts. 

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

existing required mitigation measures, BLM can include additional mitigation 
Executive Summary 

ES-62 Final EIS, Wright Area Coal Lease Applications

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

regulatory authority. Any special stipulations identified by BLM where 

additional or increased monitoring measures are recommended to be added to 

the BLM leases are included in Appendix D of this EIS. 

Cumulative Impacts

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, 20 coal 

leases containing approximately 5.8 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. Twelve additional coal lease applications, including the North 

Hilight Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, North 

Porcupine, and South Porcupine tract applications, are currently pending. The 

pending LBA applications contain over 3.8 billion tons of coal. 

Recently, the BLM completed 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 PRB Coal Review consists of three tasks: 

• Task 1 identifies existing resource conditions in the PRB for the baseline 

year (2003) and, for applicable resources, updates the BLM's 1996 status 

check for coal development in the PRB. 

• Task 2 defines the past and present development activities in the PRB 

and their associated development levels as of 2003 and develops a 

forecast of reasonably foreseeable development in the PRB through 2020. 

The reasonably foreseeable activities fall into three broad categories: coal 

development (coal mine and coal-related), oil and gas development 

(conventional oil and gas, coal bed natural gas, and major transportation 

pipelines), and other development, which includes development that is 

not energy-related as well as other energy-related development. 

• Task 3 predicts the cumulative impacts that could be expected to occur 

to air, water, socioeconomic, and other resources if the development 

occurs as projected in the forecast developed under Task 2. 

A series of reports have been prepared to present the results of the PRB Coal 

Review task studies. The Task 1, 2, and 3 reports represent components of a 

technical study of cumulative development in the PRB; they do not evaluate 

specific proposed projects, but they provide information that BLM is using to 

evaluate the cumulative impacts that would be expected to occur if specific 

projects or applications, such as the six WAC LBA tracts, are approved. The 
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-63 

PRB Coal Review is expressly not a NEPA analysis. It is a planning tool; a set 

of environmental impact analysis tools, and when maintained through time will 

provide a method to calibrate development projects and related estimation of 

effects. The results of the PRB Coal Review studies are summarized in Section 

4.0 of this EIS. 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. 

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

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

developed for the PRB Coal Review. The projected development levels are based 

on projected demand, coal market forecasts, and availability of adequate coal 

transportation. The projected coal production levels at the Black Thunder, 

Jacobs Ranch, and North Antelope Rochelle mines during the baseline year 

and for 2010, 2015, and 2020 are included. 

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 a baseline year, 2002, and of projected 

development activities in 2010. BLM updated the model and conducted the 

cumulative air quality impact analysis using a revised baseline year of 2004 

with development levels projected for year 2015. BLM recently updated the 

model for the second time, and conducted the cumulative air quality impact 

analysis for the year 2020 using the same baseline year of 2004 with revised 

projected 2020 scenarios. The revised baseline year emissions inventory was 

developed using 2004 actual emissions data or emissions estimates and 

incorporated the recent analyses of emissions in Wyoming and Montana, which 

were not available when the 2010 modeling study was done. The model was 

used to evaluate impacts of existing and projected source emissions on several 

source groups, including near-field receptors in Wyoming and Montana, 

receptors in nearby federally designated “Class I” areas, and receptors at other 

sensitive “Class II” areas. The EPA guideline CALPUFF model system version 

5.8 was used for the modeling analysis. 

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

but the modeling showed substantial, localized impact of the 24-hour 

particulate concentrations, exceeding the national and state ambient air quality 

standards at some Wyoming near-field receptors for the baseline year (2004), 

as well as for both development scenarios for 2015 and 2020. Impacts at 

Montana near-field receptors would be in compliance with the national and 

state ambient air quality standards for all pollutants and averaging periods. 

Table ES-13 presents the maximum modeled impacts on ambient air quality at 

the near-field receptors in Wyoming and Montana for the baseline year (2004) 

and for both coal production scenarios for 2015 and 2020. The model results 

should not be construed as predicting an actual exceedance of any standard, 
Executive Summary 

 ES-64 Final EIS, Wright Area C

Table ES-13. Projected Maximum Potential Near-field Impacts (μg/m3).

Pollutant 

Averaging 

Time 

Base Year 

(2004) 

Impacts 

2020 Lower 

Coal 

Development 

Scenario 

Impacts 

2020 Upper 

Coal 

Development 

Scenario 

Impacts NAAQS 

Wyoming 

AAQS 

M

A

Wyoming Near-field 

NO2 Annual 31.3 30.5 30.6 100 100 

SO2 Annual 15.3 16.4 16.5 80 60 

 24-hour 112.3 143.3 143.3 365 260  3-hour 462.0 936.7 936.7 1,300 1,300 

PM2.5 Annual 13.4 16.3 16.3 15 15 

 24-hour 87.6 218.4 218.4 35 35 

PM10 Annual 38.4 46.6 46.6 --- 50 

 24-hour 250.4 624.1 624.3 150 150 

Montana Near-field

NO2 Annual 3.3 2.5 2.6 100 --- 

 1-hour 409.0 440.1 442.7 --- --- 

SO2 Annual 1.6 3.0 3.1 80 --- 

 24-hour 16.1 24.7 27.1 365 --- 

 3-hour 65.0 138.9 138.9 1,300 --- 

 1-hour 162.9 237.0 259.1 --- --- 

PM2.5 Annual 1.0 0.9 0.9 15 --- 

 24-hour 10.2 10.2 10.2 35 --- 

PM10 Annual 2.8 2.5 2.6 --- --- 

 24-hour 29.1 29.3 29.3 150 --- 

1 No standard or increment Value units are microgram per cubic meter (μg/m3) 

Bold values indicate projected exceedance of AAQS Source: PRB Coal Review Task 3A Update Report (BLM 2009c) 
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-65 

but are at best indicators of potential impacts. Table ES-14 lists the projected 

modeled visibility impacts for the baseline year (2004) and for the lower and 

upper coal production scenarios 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 impacts were projected to be greater than 

1.0 deciview (dv) (10 percent in extinction) for each site in 2015. 

The PRB Coal Review provides an assessment of the cumulative impact to 

surface and ground water resources associated with future projected levels of 

coal mining, coal mine dewatering, CBNG groundwater withdrawal and surface 

disposal, and coal mine and conventional oil and gas surface disposal of 

groundwater. Several studies and modeling analyses have previously been 

conducted by various federal and state agencies, as well as the coal and oil and 

gas industries, to predict the cumulative impacts of surface coal mining and 

CBNG development on groundwater resources in the PRB. The most recent 

analysis, BLM’s PRB Coal Review, summarizes the modeled changes in 

groundwater levels projected for 2010, 2015, and 2020. The base years used 

for comparison of groundwater impacts were 2002 (the year used for 

calibration of the groundwater model) and 1990 (a time period prior to CBNG 

pumpage and before major expansion by the eastern PRB coal mines). 

Information from earlier studies was incorporated into the modeling effort for 

the PRB Coal Review analysis. The cumulative effects groundwater model 

domain is within approximately 25 miles of the coal mines. As expected, 

modeling indicates groundwater impacts from CBNG development and surface 

coal mining are additive in nature and that the addition of CBNG development 

has greatly extended the area experiencing a loss in hydraulic head to the west 

of the mining area. Drawdown in the Upper Fort Union coal aquifers 

attributable to mining only from 1990 to 2020 ranges from 25 to 125 feet in the 

active mine areas with up to 125 feet of rebound in the reclaimed areas. At 

distances greater than 3 miles west of the southern group of mines, drawdowns 

attributed to mining only were projected to be less than 25 feet, from 1990 to 

2010 as well as from 1990 to 2020. The effect of CBNG pumpage on the Upper 

Fort Union coal aquifers from 1990 to 2010 results in an extensive area of 

drawdown centered about 10 miles southwest of Wright, covering nearly 15 

townships, and drawdowns range from 25 feet on the southern margin to 575 

feet in the center of the depression. The modeled drawdown in the Upper Fort 

Union due to CBNG pumpage from 1990 to 2020 is also projected to primarily 

be located southwest of Wright, producing a groundwater depression of 

between 25 to 425 feet that covers roughly eight to nine townships. 

In addition to conducting detailed analyses to assess the probable hydrologic 

consequences of mining as part of the mine permitting process, each mine 

must monitor groundwater levels in the coal and underlying and overlying 

aquifers. 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 verify that recharge has 

occurred and is continuing in the backfill, and that the quality of water from 

the backfill will generally meet the state standard for livestock use. The PRB 
Executive Summary 

ES-66 Final EIS, Wright Area Coal Lease Applications

Table ES-14. Modeled Change in Visibility Impacts at Class I and Sensitive 

Class II Areas. 

Base Year 

(2004) 

2020 Lower 

Coal 

Development 

Scenario 

2020 Upper 

Coal 

Development 

Scenario 

Location 

No. of Days 

>10% 

Change in 

No. of Days 

>10% 

Change in 

No. of Days 

>10% 

Class I Areas

Badlands National Park 218 44 44 

Bob Marshall WA 8 0 0 

Bridger WA 144 5 5 

Fitzpatrick WA 91 6 6 

Fort Peck Indian Reservation 105 20 21 

Gates of the Mountain WA 55 4 4 

Grand Teton National Park 70 6 6 

North Absaroka WA 61 8 8 

North Cheyenne Indian Reservation 243 59 60 

Red Rock Lakes 42 3 3 

Scapegoat WA 27 2 2 

Teton WA 57 8 8 

Theodore Roosevelt National Park 178 24 24 

UL Bend WA 77 18 18 

Washakie WA 83 8 8 

Wind Cave National Park 262 28 31 

Yellowstone National Park 84 5 5 

Sensitive Class II Areas 

Absaroka Beartooth WA 101 10 10 

Agate Fossil Beds National Monument 251 26 26 

Big Horn Canyon National Rec. Area 331 1 1 

Black Elk WA 236 47 47 

Cloud Peak WA 126 29 30 

Crow Indian Reservation 360 3 3 

Devils Tower National Monument 274 31 32 

Fort Belknap Indian Reservation 66 14 15 

Fort Laramie National Historic Site 260 15 16 

Jedediah Smith WA 79 3 5 

Jewel Cave National Monument 261 36 37 

Lee Metcalf WA 97 2 2 

Mount Naomi WA 51 1 1 

Mount Rushmore National Monument 222 49 52 

Popo Agie WA 139 6 6 

Soldier Creek WA 268 19 19 

Wellsville Mountain WA 130 17 17 

Wind River Indian Reservation 217 9 10 

Source: PRB Coal Review Task 3A Update Report (BLM 2009c)
Executive Summary 

Final EIS, Wright Area Coal Lease Applications ES-67 

Coal Review predicts that resaturation of coal mine pit backfill to form backfill 

aquifers may take approximately 100 years after cessation of mining and is 

projected to result in the westward migration of groundwater with elevated TDS 

levels. Modeling of this westward migration indicates that TDS levels should be 

down to the average background (premine) value within 2,000 feet of the final 

westward extent of the coal mine boundaries. Thus, no impact to groundwater 

quality in either the Wasatch or Upper Fort Union aquifers is expected beyond 

approximately 2,000 feet west of the final coal mine boundaries. 

The PRB Coal Review summarizes the cumulative impacts to surface water 

quality and stream channel stability as a result of surface discharge of 

groundwater by CBNG development and coal mine dewatering projected for 

2010, 2015, and 2020 in the eastern PRB within approximately 25 miles of the 

coal mines. The base year used for comparison of surface water quality 

impacts was 2003. Projected cumulative surface water impacts primarily 

include the impacts of CBNG production water discharged to ephemeral 

drainages and the surface disturbance and subsequent reclamation of 

drainages that result from surface coal mining. For the coal mines, it was 

assumed that most, if not all, of the water produced was expected to be 

consumed during operation, and that any water discharged to nearby 

ephemeral drainages is in accordance with Wyoming Pollution Discharge 

Elimination System (WYPDES) permits. It was therefore projected that the 

primary source of water discharged directly to the receiving drainages in the 

PRB study area through 2020 would be limited to the production water from 

CBNG development. 

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. As discussed above, 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. 

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

are and will continue to contribute to a reduction in hunting opportunities for 

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

The PRB Coal Review used the Regional Economic Models Inc. 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-15 presents the 

recent and projected population levels for the counties included in the PRB 

Coal Review socioeconomic analysis. 
Executive Summary 

ES-68 Final EIS, Wright Area Coal Lease Applications

Table ES-15. Recent and Projected PRB Population. 

Year 

Campbell 

County 

Converse 

County 

Crook 

County 

Johnson 

County 

Sheridan 

County 

Weston 

County 

Six 

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 (2006a) and PRB Coal Review Task 3C Report 

The cumulative 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 not determined at the time of leasing or 

mining; the use is determined by the purchaser and end user. However, 

almost all of the coal mined in the PRB is utilized and burned by coal-fired 

power plants located throughout the U.S. to generate electricity. When coal is 

burned, it results in the release of CO2, a GHG, as well as mercury and other 

compounds and elements. GHGs, climate change, the potential impacts of 

worldwide GHG emissions, and coal combustion by-products are discussed at 

length in Section 4.2.14. The U.S. Department of Energy’s recent reports that 

project the nation’s current and future energy needs and power generation 

sources are also cited in the discussion. 

This EIS presents BLM’s analysis of environmental impacts under authority of 

the NEPA and associated rules and guidelines. 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 mining and 

reclamation plans, to the WDEQ/LQD. 
Table of Contents 

Final EIS, Wright Area Coal Lease Applications i 

TABLE OF CONTENTS

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

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

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

1.1.1 North and South Hilight Field LBA Tracts ........................ 1-5 

1.1.2 West Hilight Field LBA Tract.......................................... 1-11 

1.1.3 West Jacobs Ranch LBA Tract ....................................... 1-12 

1.1.4 North and South Porcupine LBA Tracts ......................... 1-14 

1.2 Purpose and Need for Action.................................................... 1-16 

1.3 Regulatory Authority and Responsibility.................................. 1-18 

1.4 Relationship to BLM Policies, Plans, and Programs.................. 1-20 

1.5 Conformance with Existing Land Use Plans............................. 1-20 

1.6 Consultation and Coordination................................................ 1-23 

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

2.1 North Hilight Field LBA Tract .................................................. 2-10 

2.1.1 North Hilight Field LBA Tract Proposed Action ............... 2-10 

2.1.2 North Hilight Field LBA Tract Alternative 1 .................... 2-15 

2.1.3 North Hilight Field LBA Tract Alternative 2 – Preferred 

Alternative ..................................................................... 2-16 

2.2 South Hilight Field LBA Tract.................................................. 2-19 

2.2.1 South Hilight Field LBA Tract Proposed Action............... 2-19 

2.2.2 South Hilight Field LBA Tract Alternative 1.................... 2-22 

2.2.3 South Hilight Field LBA Tract Alternative 2 – Preferred 

Alternative ..................................................................... 2-23 

2.3 West Hilight Field LBA Tract.................................................... 2-26 

2.3.1 West Hilight Field LBA Tract Proposed Action................. 2-26 

2.3.2 West Hilight Field LBA Tract Alternative 1...................... 2-29 

2.3.3 West Hilight Field LBA Tract Alternative 2 – Preferred 

Alternative ..................................................................... 2-30 

2.3.4 West Hilight Field LBA Tract Alternative 3...................... 2-33 

2.4 West Jacobs Ranch LBA Tract................................................. 2-37 

2.4.1 West Jacobs Ranch LBA Tract Proposed Action.............. 2-37 

2.4.2 West Jacobs Ranch LBA Tract Alternative 1................... 2-42 

2.4.3 West Jacobs Ranch LBA Tract Alternative 2 – Preferred 

Alternative ..................................................................... 2-43 

2.5 North Porcupine LBA Tract...................................................... 2-47 

2.5.1 North Porcupine LBA Tract Proposed Action................... 2-47 

2.5.2 North Porcupine LBA Tract Alternative 1........................ 2-53 

2.5.3 North Porcupine LBA Tract Alternative 2 – Preferred 

Alternative ..................................................................... 2-54 

2.6 South Porcupine LBA Tract ..................................................... 2-57 

 2.6.1 South Porcupine LBA Tract Proposed Action .................. 2-57 

 2.6.2 South Porcupine LBA Tract Alternative 1 ....................... 2-61 

 2.6.3 South Porcupine LBA Tract Alternative 2 – Preferred 

Alternative ..................................................................... 2-62 
Table of Contents 

TABLE OF CONTENTS (Continued) 

ii Final EIS, Wright Area Coal Lease Applications

2.7 Alternatives Considered but not Analyzed in Detail.................. 2-65 

 2.7.1 Alternative 4: New Mine Start......................................... 2-65 

 2.7.2 Alternative 5: Delaying the Sale...................................... 2-67 

2.8 Regulatory Compliance, Mitigation and Monitoring.................. 2-69 

2.9 Hazardous and Solid Waste..................................................... 2-70 

2.10 Summary of Alternatives and Environmental Consequences.... 2-77 

 2.10.1 Background................................................................. 2-77 

 2.10.2 Summary of Alternatives.............................................. 2-77 

3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL 

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

3.1 General Setting ....................................................................... 3-10 

3.1.1 Climate and Meteorology................................................ 3-10 

3.2 Topography and Physiography................................................. 3-11 

3.2.1 Affected Environment..................................................... 3-11 

3.2.2 Environmental Consequences ........................................ 3-13 

3.2.2.1 Proposed Action and Alternatives 2 and 3.... 3-13 

3.2.2.2 No Action Alternative................................... 3-15 

3.2.3 Regulatory Compliance, Mitigation and Monitoring ........ 3-16 

3.2.4 Residual Impacts ........................................................... 3-16 

3.3 Geology, Mineral Resources and Paleontology.......................... 3-16 

3.3.1 General Geology and Coal Resources.......................... 3-16 

3.3.1.1 Affected Environment.................................. 3-16 

3.3.1.2 Environmental Consequences ..................... 3-19 

3.3.1.2.1 Proposed Action and 

 Alternatives 2 and 3..................... 3-19 

3.3.1.2.1.1 North Hilight Field 

 LBA Tract ..................... 3-20 

3.3.1.2.1.2 South Hilight Field 

 LBA Tract ..................... 3-20 

3.3.1.2.1.3 West Hilight Field 

 LBA Tract ..................... 3-20 

3.3.1.2.1.4 West Jacobs Ranch 

 LBA Tract ..................... 3-21 

3.3.1.2.1.5 North Porcupine 

 LBA Tract ..................... 3-21 

3.3.1.2.1.6 South Porcupine 

 LBA Tract ..................... 3-22 

3.3.1.2.2 No Action Alternative ................... 3-22 

3.3.1.3 Regulatory Compliance, Mitigation and 

 Monitoring .................................................. 3-23 

3.3.1.4 Residual Impacts........................................... 3-23 

3.3.2 Other Mineral Resources................................................ 3-23 

3.3.2.1 Affected Environment .................................... 3-23 

3.3.2.1.1 Conventional Oil and Gas ............ 3-23 

3.3.2.1.2 Unconventional Oil and Gas ........ 3-26 
Table of Contents 

TABLE OF CONTENTS (Continued) 

Final EIS, Wright Area Coal Lease Applications iii 

 3.3.2.1.2.1 Coal Bed Natural 

 Gas (CBNG) .................. 3-27 

3.3.2.1.3 Other Minerals ............................ 3-30 

3.3.2.2 Environmental Consequences ..................... 3-30 

3.3.2.2.1 Proposed Action and 

 Alternatives 2 and 3..................... 3-30 

3.3.2.2.2 No Action Alternative ................... 3-32 

3.3.2.3 Regulatory Compliance, Mitigation and 

Monitoring .................................................. 3-33 

3.3.2.4 Residual Impacts......................................... 3-34 

3.3.3 Paleontology .................................................................. 3-34 

3.3.3.1 Affected Environment.................................. 3-34 

 3.3.3.1.1 Paleontological Resource 

 Survey ........................................................ 3-37 

 3.3.3.1.2 North Hilight Field LBA Tract ...... 3-38 

 3.3.3.1.3 South Hilight Field LBA Tract...... 3-38 

 3.3.3.1.4 West Hilight Field LBA Tract ....... 3-39 

 3.3.3.1.5 West Jacobs Ranch LBA Tract..... 3-40 

 3.3.3.1.6 North Porcupine LBA Tract ......... 3-40 

 3.3.3.1.7 South Porcupine LBA Tract......... 3-41 

3.3.3.2 Environmental Consequences ..................... 3-45 

3.3.3.2.1 Proposed Action and 

 Alternatives 2 and 3..................... 3-45 

 3.3.3.2.1.1 North Hilight Field 

 LBA Tract ..................... 3-45 

 3.3.3.2.1.2 South Hilight Field 

 LBA Tract ..................... 3-45 

 3.3.3.2.1.3 West Hilight Field 

 LBA Tract ..................... 3-45 

 3.3.3.2.1.4 West Jacobs Ranch 

 LBA Tract ..................... 3-46 

 3.3.3.2.1.5 North Porcupine 

 LBA Tract ..................... 3-46 

 3.3.3.2.1.6 South Porcupine 

 LBA Tract ..................... 3-46 

3.3.3.2.2 No Action Alternative ................... 3-46 

3.3.3.3 Regulatory Compliance, Mitigation and 

Monitoring .................................................. 3-47 

3.3.3.4 Residual Impacts......................................... 3-47 

3.4 Air Quality .............................................................................. 3-47 

3.4.1 Background ............................................................... 3-48 

3.4.1.1 Emission Sources........................................ 3-48 

3.4.2 Particulate Emissions................................................. 3-51 

3.4.2.1 Affected Environment for Particulate 

 Emissions ................................................... 3-51 
Table of Contents 

TABLE OF CONTENTS (Continued) 

iv Final EIS, Wright Area Coal Lease Applications

3.4.2.2 Environmental Consequences Related to 

Particulate Emissions.................................. 3-55 

3.4.2.2.1 Proposed Action and 

 Alternatives 2 and 3..................... 3-57 

3.4.2.2.1.1 North, South, and 

 West Hilight Field 

 LBA Tracts.................... 3-59 

3.4.2.2.1.2 West Jacobs Ranch 

 LBA Tract ..................... 3-63 

3.4.2.2.1.3 North and South LBA 

 Porcupine Tracts........... 3-67 

3.4.2.2.2 No Action Alternative................. 3-73 

3.4.2.3 Regulatory Compliance, Mitigation, and 

Monitoring for Particulate Emissions........... 3-73 

3.4.3 Emissions of Nitrogen Oxides (NOx) and Ozone (O3) .... 3-78 

3.4.3.1 Affected Environment for NOx and O3

 Emissions ................................................... 3-78 

3.4.3.1.1 Site Specific NOx and O3

 Emissions.................................... 3-79 

3.4.3.2 Environmental Consequences Related to 

 Short-Term NOx Emissions.......................... 3-80 

3.4.3.2.1 Proposed Action and 

 Alternatives 2 and 3..................... 3-82 

3.4.3.2.1.1 North, South, and 

 West Hilight Field 

 LBA Tracts.................... 3-83 

3.4.3.2.1.2 West Jacobs Ranch 

 LBA Tract ..................... 3-84 

3.4.3.2.1.3 North and South 

 Porcupine LBA Tracts ... 3-86 

3.4.3.2.2 No Action Alternative ................... 3-87 

3.4.3.3 Regulatory Compliance, Mitigation, and 

Monitoring for NOx Emissions...................... 3-87 

3.4.4 Air Quality Related Values (AQRVs)............................ 3-90 

3.4.4.1 Visibility...................................................... 3-91 

3.4.4.1.1 Affected Environment for 

 Visibility ...................................... 3-91 

3.4.4.1.2 Environmental Consequences 

 for Visibility................................. 3-93 

3.4.4.1.2.1 Proposed Action and 

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

3.4.4.1.2.2 No Action Alternative .... 3-95 

3.4.4.1.3 Regulatory Compliance, 

 Mitigation, and Monitoring for 

 Visibility Impacts......................... 3-96 

 3.4.4.2 Acidification of Lakes .................................. 3-96 
Table of Contents 

TABLE OF CONTENTS (Continued) 

Final EIS, Wright Area Coal Lease Applications v 

3.4.4.2.1 Affected Environment.................. 3-97 

3.4.4.2.2 Environmental Consequences ..... 3-97 

3.4.4.2.2.1 Proposed Action and 

 Alternatives 2 and 3...... 3-97 

3.4.4.2.2.2 No Action Alternative .... 3-98 

3.4.4.2.3 Regulatory Compliance, 

 Mitigation, and Monitoring.......... 3-99 

3.4.5 Residual Impacts to Air Quality.................................. 3-99 

3.5 Water Resources ..................................................................... 3-99 

3.5.1 Groundwater.............................................................. 3-99 

3.5.1.1 Affected Environment.................................. 3-99 

3.5.1.1.1 Recent Alluvium ........................ 3-103 

3.5.1.1.2 Wasatch Formation ................... 3-106 

3.5.1.1.3 Wyodak/Wyodak-Anderson 

 Coal........................................... 3-108 

3.5.1.1.4 Subcoal Fort Union Formation... 3-110 

3.5.1.1.5 Lance Formation-Fox Hills 

 Sandstone ................................. 3-111 

3.5.1.2 Environmental Consequences ................... 3-111 

3.5.1.2.1 Proposed Action and 

 Alternatives 2 and 3 ................ 3-111 

3.5.1.2.1.1 North, South, and 

 West Hilight Field 

 LBA Tracts.................. 3-116 

3.5.1.2.1.2 West Jacobs Ranch 

 LBA Tract ................... 3-121 

3.5.1.2.1.3 North and South 

 Porcupine LBA 

 Tracts ......................... 3-126 

3.5.1.2.2 No Action Alternative............... 3-131 

3.5.1.3 Regulatory Compliance, Mitigation, and 

Monitoring ................................................ 3-132 

3.5.2 Surface Water .......................................................... 3-133 

3.5.2.1 Affected Environment................................ 3-133 

3.5.2.2 Environmental Consequences ................... 3-143 

3.5.2.2.1 Proposed Action and 

 Alternatives 2 and 3................... 3-143 

3.5.2.2.1.1 North, South, and 

 West Hilight Field 

 LBA Tracts.................. 3-145 

3.5.2.2.1.2 West Jacobs Ranch 

 LBA Tract ................... 3-146 

3.5.2.2.1.3 North and South 

 Porcupine LBA 

 Tracts ......................... 3-147 

3.5.2.2.2 No Action Alternative ................. 3-147 
Table of Contents 

TABLE OF CONTENTS (Continued) 

vi Final EIS, Wright Area Coal Lease Applications

3.5.2.3 Regulatory Compliance, Mitigation, and 

Monitoring ................................................ 3-148 

3.5.3 Water Rights ............................................................ 3-148 

3.5.3.1 Affected Environment................................ 3-148 

3.5.3.2 Environmental Consequences ................... 3-153 

3.5.3.2.1 Proposed Action and 

 Alternatives 2 and 3 ................ 3-153 

3.5.3.2.1.1 North Hilight Field 

 LBA Tract ................... 3-153 

3.5.3.2.1.2 South Hilight Field 

 LBA Tract ................... 3-154 

3.5.3.2.1.3 West Hilight Field 

 LBA Tract ................... 3-154 

3.5.3.2.1.4 West Jacobs Ranch 

 LBA Tract ................... 3-155 

3.5.3.2.1.5 North Porcupine 

 LBA Tract ................... 3-155 

3.5.3.2.1.6 South Porcupine 

 LBA Tract ................... 3-156 

3.5.3.2.2 No Action Alternative............... 3-156 

3.5.3.3 Regulatory Compliance, Mitigation and 

Monitoring ................................................ 3-157 

3.5.4 Residual Impacts ..................................................... 3-157 

3.6 Alluvial Valley Floors............................................................. 3-158 

3.6.1 Affected Environment............................................... 3-158 

3.6.1.1 North Hilight Field LBA Tract .................... 3-159 

3.6.1.2 South Hilight Field LBA Tract.................... 3-160 

3.6.1.3 West Hilight Field LBA Tract...................... 3-160 

3.6.1.4 West Jacobs Ranch LBA Tract................... 3-161 

3.6.1.5 North Porcupine LBA Tract........................ 3-161 

3.6.1.6 South Porcupine LBA Tract ....................... 3-162 

3.6.2 Environmental Consequences .................................. 3-162 

3.6.2.1 Proposed Action and Alternatives 2 

 and 3 ........................................................ 3-162 

3.6.2.2 No Action Alternative................................. 3-164 

3.6.3 Regulatory Compliance, Mitigation and 

 Monitoring ............................................................... 3-165 

3.6.4 Residual Impacts ..................................................... 3-165 

3.7 Wetlands............................................................................... 3-165 

3.7.1 Affected Environment............................................... 3-165 

3.7.1.1 North Hilight Field LBA Tract .................... 3-169 

3.7.1.2 South Hilight Field LBA Tract.................... 3-169 

3.7.1.3 West Hilight Field LBA Tract...................... 3-170 

3.7.1.4 West Jacobs Ranch LBA Tract................... 3-171 

3.7.1.5 North Porcupine LBA Tract........................ 3-172 

3.7.1.6 South Porcupine LBA Tract ....................... 3-172 
Table of Contents 

TABLE OF CONTENTS (Continued) 

Final EIS, Wright Area Coal Lease Applications vii 

3.7.2 Environmental Consequences .................................. 3-173 

3.7.2.1 Proposed Action and Alternatives 2 

 and 3 ........................................................ 3-173 

3.7.2.2 No Action Alternative................................. 3-174 

3.7.3 Regulatory Compliance, Mitigation and 

 Monitoring ............................................................... 3-174 

3.7.4 Residual Impacts ..................................................... 3-175 

3.8 Soils...................................................................................... 3-175 

3.8.1 Affected Environment............................................... 3-175 

3.8.1.1 North Hilight Field, South Hilight Field 

 and West Hilight Field LBA Tracts ............. 3-176 

3.8.1.2 West Jacobs Ranch LBA Tract................... 3-177 

3.8.1.3 North and South Porcupine LBA Tracts ..... 3-177 

3.8.2 Environmental Consequences ................................... 3-177 

3.8.2.1 Proposed Action and Alternatives 2 

 and 3 ........................................................ 3-177 

3.8.2.1.1 North Hilight Field LBA Tract..... 3-178 

3.8.2.1.2 South Hilight Field LBA Tract .... 3-179 

3.8.2.1.3 West Hilight Field LBA Tract ...... 3-179 

3.8.2.1.4 West Jacobs Ranch LBA Tract ... 3-180 

3.8.2.1.5 North Porcupine LBA Tract ........ 3-180 

3.8.2.1.6 South Porcupine LBA Tract........ 3-181 

3.8.2.2 No Action Alternative................................. 3-181 

3.8.3 Regulatory Compliance, Mitigation and 

 Monitoring ............................................................... 3-182 

3.8.4 Residual Impacts ..................................................... 3-182 

3.9 Vegetation............................................................................. 3-183 

3.9.1 Affected Environment............................................... 3-183 

3.9.2 Environmental Consequences .................................. 3-185 

3.9.2.1 Proposed Action and Alternatives 2 

 and 3 ........................................................ 3-185 

3.9.2.2 No Action Alternative................................. 3-187 

3.9.3 Threatened, Endangered, Proposed, and 

 Candidate Plant Species, and BLM and USFS 

 Sensitive Plant Species............................................. 3-188 

3.9.4 Regulatory Compliance, Mitigation and Monitoring... 3-188 

3.9.5 Residual Impacts ..................................................... 3-189 

3.10 Wildlife.................................................................................. 3-189 

3.10.1 General Setting ........................................................ 3-189 

3.10.1.1 Affected Environment................................ 3-189 

3.10.1.2 Environmental Consequences ................... 3-192 

3.10.1.2.1 Proposed Action and 

 Alternatives 2 and 3 ................ 3-192 

3.10.1.2.2 No Action Alternative............... 3-193 

3.10.2 Big Game ................................................................. 3-194 

3.10.2.1 Affected Environment................................ 3-194 
Table of Contents 

TABLE OF CONTENTS (Continued) 

viii Final EIS, Wright Area Coal Lease Applications

3.10.2.2 Environmental Consequences ................... 3-196 

3.10.2.2.1 Proposed Action and 

 Alternatives 2 and 3 ................ 3-196 

3.10.2.2.2 No Action Alternative............... 3-197 

3.10.3 Other Mammals ....................................................... 3-197 

3.10.3.1 Affected Environment................................ 3-197 

3.10.3.1.1 North, South, and West 

 Hilight Field LBA Tracts........... 3-205 

3.10.3.1.2 West Jacobs Ranch LBA 

 Tract ....................................... 3-205 

3.10.3.1.3 North and South Porcupine 

 LBA Tracts .............................. 3-205 

3.10.3.2 Environmental Consequences ................... 3-206 

3.10.3.2.1 Proposed Action and 

 Alternatives 2 and 3 ................ 3-206 

3.10.3.2.2 No Action Alternative............... 3-207 

3.10.4 Raptors.................................................................... 3-207 

3.10.4.1 Affected Environment................................ 3-207 

3.10.4.1.1 North, South, and West 

 Hilight Field LBA Tracts........... 3-208 

3.10.4.1.2 West Jacobs Ranch LBA 

 Tract ....................................... 3-209 

3.10.4.1.3 North and South Porcupine 

 LBA Tracts .............................. 3-209 

3.10.4.2 Environmental Consequences ................... 3-210 

3.10.4.2.1 Proposed Action and 

 Alternatives 2 and 3 ................ 3-210 

3.10.4.2.1.1 North, South, and 

 West Hilight Field 

 LBA Tracts.................. 3-211 

3.10.4.2.1.2 West Jacobs Ranch 

 LBA Tract ................... 3-212 

3.10.4.2.1.3 North and South 

 Porcupine LBA 

 Tracts ......................... 3-212 

3.10.4.2.2 No Action Alternative............... 3-212 

3.10.5 Upland Game Birds.................................................. 3-212 

3.10.5.1 Affected Environment................................ 3-212 

3.10.5.1.1 Sage-Grouse Use Associated 

 With the North, South, and 

 West Hilight Field LBA Tracts .. 3-218 

3.10.5.1.2 Sage-Grouse Use Associated 

 With the West Jacobs Ranch 

 LBA Tract................................ 3-219 
Table of Contents 

TABLE OF CONTENTS (Continued) 

Final EIS, Wright Area Coal Lease Applications ix 

3.10.5.1.3 Sage-Grouse Use Associated 

 With the North and South 

 Porcupine LBA Tracts.............. 3-220 

3.10.5.2 Environmental Consequences ................... 3-221 

3.10.5.2.1 Proposed Action and 

 Alternatives 2 and 3 ................ 3-221 

3.10.5.3 No Action Alternative................................. 3-225 

3.10.6 Other Birds.............................................................. 3-225 

3.10.6.1 Affected Environment................................ 3-225 

3.10.6.2 Environmental Consequences ................... 3-229 

3.10.6.2.1 Proposed Action and 

 Alternatives 2 and 3 ................ 3-229 

3.10.6.2.2 No Action Alternative............... 3-231 

3.10.7 Amphibians, Reptiles, and Aquatic Species .............. 3-231 

3.10.7.1 Affected Environment................................ 3-231 

3.10.7.2 Environmental Consequences ................... 3-233 

3.10.7.2.1 Proposed Action and 

 Alternatives 2 and 3 ................ 3-233 

3.10.7.2.2 No Action Alternative............... 3-233 

3.10.8 Threatened, Endangered, Proposed, and 

 Candidate Species; BLM Sensitive Species; and 

 USFS Sensitive Species and Management 

 Indicator Species...................................................... 3-233 

3.10.9 Regulatory Compliance, Mitigation and 

 Monitoring ............................................................... 3-234 

3.10.10 Residual Impacts ..................................................... 3-236 

3.11 Land Use and Recreation....................................................... 3-237 

3.11.1 Affected Environment............................................... 3-237 

3.11.2 Environmental Consequences .................................. 3-263 

3.11.2.1 Proposed Action and Alternatives 2 

 and 3 ........................................................ 3-263 

3.11.2.2 No Action Alternative................................. 3-266 

3.11.3 Regulatory Compliance, Mitigation and 

 Monitoring............................................................... 3-266 

3.11.4 Residual Impacts..................................................... 3-267 

3.12 Cultural Resources................................................................ 3-267 

3.12.1 Affected Environment............................................... 3-267 

3.12.1.1 North, South, and West Hilight Field 

 LBA Tracts ............................................... 3-272 

3.12.1.2 West Jacobs Ranch LBA Tract .................. 3-273 

3.12.1.3 North and South Porcupine LBA Tracts .... 3-274 

3.12.2 Environmental Consequences .................................. 3-275 

3.12.2.1 Proposed Action and Alternatives 2 

 and 3........................................................ 3-275 

3.12.2.2 No Action Alternative................................ 3-276 

3.12.3 Native American Consultation ................................. 3-276 
Table of Contents 

TABLE OF CONTENTS (Continued) 

x Final EIS, Wright Area Coal Lease Applications

3.12.4 Regulatory Compliance, Mitigation and 

 Monitoring .............................................................. 3-277 

3.12.5 Residual Impacts..................................................... 3-277 

3.13 Visual Resources................................................................... 3-278 

3.13.1 Affected Environment .............................................. 3-278 

3.13.2 Environmental Consequences.................................. 3-279 

3.13.2.1 Proposed Action and Alternatives 2 

 and 3 ........................................................ 3-279 

3.13.2.2 No Action Alternative................................. 3-280 

3.13.3 Regulatory Compliance, Mitigation and 

 Monitoring .............................................................. 3-281 

3.13.4 Residual Impacts..................................................... 3-281 

3.14 Noise..................................................................................... 3-281 

3.14.1 Affected Environment .............................................. 3-281 

3.14.2 Environmental Consequences.................................. 3-283 

3.14.2.1 Proposed Action and Alternatives 2 

 and 3 ........................................................ 3-283 

3.14.2.2 No Action Alternative................................. 3-286 

3.14.3 Regulatory Compliance, Mitigation and 

 Monitoring .............................................................. 3-286 

3.14.4 Residual Impacts..................................................... 3-286 

3.15 Transportation ...................................................................... 3-286 

3.15.1 Affected Environment .............................................. 3-286 

3.15.2 Environmental Consequences.................................. 3-294 

3.15.2.1 Proposed Action and Alternatives 2 

 and 3 ........................................................ 3-294 

3.15.2.2 No Action Alternative................................. 3-295 

3.15.3 Regulatory Compliance, Mitigation and 

 Monitoring .............................................................. 3-295 

3.15.4 Residual Impacts..................................................... 3-295 

 3.15.4.1 Coal Loss During Rail Transport............... 3-296 

3.16 Hazardous and Solid Waste................................................... 3-298 

3.16.1 Affected Environment .............................................. 3-298 

3.16.2 Environmental Consequences.................................. 3-299 

3.16.2.1 Proposed Action and Alternatives 2 

 and 3 ........................................................ 3-299 

3.16.2.2 No Action Alternative................................. 3-299 

3.16.3 Regulatory Compliance, Mitigation and 

 Monitoring .............................................................. 3-299 

3.16.4 Residual Impacts..................................................... 3-299 

3.17 Socioeconomics..................................................................... 3-300 

3.17.1 Local Economy ........................................................ 3-300 

3.17.1.1 Affected Environment................................ 3-300 

3.17.1.2 Environmental Consequences ................... 3-302 

3.17.1.2.1 Proposed Action and 

 Alternatives 2 and 3 ................ 3-302 
Table of Contents 

TABLE OF CONTENTS (Continued) 

Final EIS, Wright Area Coal Lease Applications xi 

3.17.1.2.1.1 North Hilight Field 

 LBA Tract ................... 3-305 

3.17.1.2.1.2 South Hilight Field 

 LBA Tract ................... 3-305 

3.17.1.2.1.3 West Hilight Field 

 LBA Tract ................... 3-305 

3.17.1.2.1.4 West Jacobs Ranch 

 LBA Tract ................... 3-306 

3.17.1.2.1.5 North Porcupine 

 LBA Tract ................... 3-306 

3.17.1.2.1.6 South Porcupine 

 LBA Tract ................... 3-306 

3.17.1.2.2 No Action Alternative............... 3-307 

3.17.2 Population............................................................... 3-307 

3.17.2.1 Affected Environment................................ 3-307 

3.17.2.2 Environmental Consequences ................... 3-308 

3.17.2.2.1 Proposed Action and 

 Alternatives 2 and 3 ................ 3-308 

3.17.2.2.2 No Action Alternative............... 3-308 

3.17.3 Employment............................................................ 3-308 

3.17.3.1 Affected Environment................................ 3-308 

3.17.3.2 Environmental Consequences ................... 3-309 

3.17.3.2.1 Proposed Action and 

 Alternatives 2 and 3 ................ 3-309 

 3.17.3.2.1.1 North Hilight Field 

 LBA Tract ................... 3-309 

 3.17.3.2.1.2 South Hilight Field 

 LBA Tract ................... 3-310 

 3.17.3.2.1.3 West Hilight Field 

 LBA Tract ................... 3-310 

 3.17.3.2.1.4 West Jacobs Ranch 

 LBA Tract ................... 3-310 

 3.17.3.2.1.5 North Porcupine 

 LBA Tract ................... 3-310 

 3.17.3.2.1.6 South Porcupine 

 LBA Tract ................... 3-311 

3.17.3.2.2 No Action Alternative............... 3-311 

3.17.4 Housing .................................................................. 3-311 

3.17.4.1 Affected Environment................................ 3-311 

3.17.4.2 Environmental Consequences ................... 3-313 

3.17.4.2.1 Proposed Action and 

 Alternatives 2 and 3 ................ 3-313 

3.17.4.2.2 No Action Alternative............... 3-314 

3.17.5 Local Government Facilities and Services ................ 3-314 

3.17.5.1 Affected Environment................................ 3-314 
Table of Contents 

TABLE OF CONTENTS (Continued) 

xii Final EIS, Wright Area Coal Lease Applications

3.17.5.2 Environmental Consequences ................... 3-316 

3.17.5.2.1 Proposed Action and 

 Alternatives 2 and 3 ................ 3-316 

3.17.5.2.2 No Action Alternative............... 3-317 

3.17.6 Social Setting .......................................................... 3-317 

3.17.6.1 Affected Environment ............................... 3-317 

3.17.6.2 Environmental Consequences................... 3-317 

3.17.6.2.1 Proposed Action and 

 Alternatives 2 and 3................ 3-317 

3.17.6.2.2 No Action Alternative .............. 3-317 

3.17.7 Environmental Justice ............................................ 3-318 

3.17.7.1 Affected Environment................................ 3-318 

3.17.7.2 Environmental Consequences ................... 3-319 

3.17.7.2.1 Proposed Action and 

 Alternatives 2 and 3 ................ 3-319 

3.17.7.2.2 No Action Alternative............... 3-319 

3.17.8 Regulatory Compliance, Mitigation and 

 Monitoring .............................................................. 3-319 

3.17.9 Residual Impacts..................................................... 3-319 

3.18 Relationship Between Local Short-Term Uses of Man’s 

 Environment and the Maintenance and Enhancement of 

 Long-Term Productivity ......................................................... 3-320 

3.18.1 Local Area .............................................................. 3-320 

3.18.1.1 Human Health Impact Assessment............ 3-322 

3.18.2 Greenhouse Gas Emissions .................................... 3-323 

3.18.2.1 Regulatory Compliance, Mitigation and 

Monitoring ................................................ 3-326 

3.19 Irreversible and Irretrievable Commitments of Resources....... 3-327 

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

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

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

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

4.1.1.2 Coal-Related Development........................... 4-14 

4.1.1.2.1 Coal Transportation................... 4-15 

4.1.1.2.2 Electric Power Generation.......... 4-16 

4.1.1.2.3 Transmission Lines ................... 4-18 

4.1.1.2.4 Coal Conversion Technology ...... 4-18 

4.1.1.2.5 Carbon Sequestration................ 4-20 

4.1.2 Oil and Gas Development .......................................... 4-21 

4.1.2.1 Conventional Oil and Gas............................ 4-21 

4.1.2.2 CBNG Development..................................... 4-23 

4.1.2.3 Oil and Gas Related Development................ 4-25 

4.1.2.3.1 Pipelines.................................... 4-25 

4.1.2.3.2 Refineries .................................. 4-27 

4.1.3 Other Development Activity ....................................... 4-28 

4.1.3.1 Other Mining............................................... 4-28 
Table of Contents 

TABLE OF CONTENTS (Continued) 

Final EIS, Wright Area Coal Lease Applications xiii 

4.1.3.2 Industrial Manufacturing ............................ 4-31 

4.1.3.3 Wind Power................................................. 4-31 

4.1.3.4 Solar Power................................................. 4-33 

4.1.3.5 Reservoirs ................................................... 4-34 

4.1.3.6 Other Non-Energy Development .................. 4-34 

4.2 Cumulative Environmental Consequences............................... 4-37 

4.2.1 Topography and Physiography................................... 4-41 

4.2.2 Geology, Mineral Resources, and Paleontology........... 4-41 

4.2.2.1 Coal ............................................................ 4-42 

4.2.2.2 Oil and Gas................................................. 4-42 

4.2.2.3 Other Mineral Resources............................. 4-42 

4.2.2.4 Paleontology................................................ 4-43 

4.2.3 Air Quality ................................................................ 4-44 

4.2.4 Water Resources ....................................................... 4-55 

4.2.4.1 Groundwater .............................................. 4-55 

4.2.4.2 Surface Water............................................. 4-73 

4.2.5 Channel Stability....................................................... 4-81 

4.2.6 Alluvial Valley Floors ................................................. 4-83 

4.2.7 Soils.......................................................................... 4-83 

4.2.8 Vegetation, Wetlands and Riparian Areas .................. 4-84 

4.2.8.1 Vegetation .................................................. 4-85 

4.2.8.2 Special Status Plant Species....................... 4-85 

4.2.8.3 Noxious and Invasive Weed Species ............ 4-86 

4.2.8.4 Wetland and Riparian Species .................... 4-87 

4.2.9 Wildlife and Fisheries ................................................ 4-88 

4.2.9.1 Game Species............................................. 4-89 

4.2.9.2 Non-game Species ...................................... 4-91 

4.2.9.3 Fisheries .................................................... 4-92 

4.2.9.4 Special Status Species................................ 4-95 

4.2.10 Land Use and Recreation........................................... 4-99 

4.2.10.1 Grazing and Agriculture ........................... 4-100 

4.2.10.2 Urban Use................................................ 4-101 

4.2.10.3 Recreation................................................ 4-102 

4.2.11 Cultural Resources and Native American 

 Concerns................................................................. 4-103 

4.2.11.1 Prehistoric Sites ....................................... 4-104 

4.2.11.2 Historic Sites............................................ 4-106 

4.2.11.3 Native American Traditional Cultural 

 Places....................................................... 4-106 

4.2.11.4 Site Protection .......................................... 4-106 

4.2.12 Transportation and Utilities..................................... 4-106 

4.2.13 Socioeconomics ....................................................... 4-109 

4.2.13.1 Employment and the Economic Base........ 4-110 

4.2.13.2 Labor Market Conditions .......................... 4-112 

4.2.13.3 Personal Income ....................................... 4-113 

4.2.13.4 Population and Demographics .................. 4-114 
Table of Contents 

TABLE OF CONTENTS (Continued) 

xiv Final EIS, Wright Area Coal Lease Applications

4.2.13.5 Housing.................................................... 4-117 

4.2.13.6 Public Education ...................................... 4-120 

4.2.13.7 Facilities and Services .............................. 4-123 

4.2.13.8 Fiscal Conditions...................................... 4-124 

4.2.13.9 Social Setting ........................................... 4-126 

4.2.14 Coal Mining and Coal-Fired Power Plant Related 

 Emissions and By-Products..................................... 4-129 

4.2.14.1 Greenhouse Gas Emissions, Global 

 Warming and Climate Change ................. 4-130 

4.2.14.2 Cumulative Effects of Combustion of 

 PRB Coal by Power Plants......................... 4-135 

4.2.14.3 U.S. Actions and Strategies to Address 

Greenhouse Gas Emissions ...................... 4-143 

4.2.14.4 Current and Future Energy Sources 

 and Emissions of Greenhouse Gases in 

 the U.S..................................................... 4-145 

4.2.14.5 Mercury, Coal Combustion Residues, 

 and Other By-Products............................. 4-151 

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 North Hilight 

 Field LBA Tract and Black Thunder Mine – Shroyer Road 

 is Not Moved and the Underlying Coal is Not Recovered.......ES-15 

Table ES-2. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for North Hilight 

 Field LBA Tract and Black Thunder Mine – Shroyer Road 

 is Moved and the Underlying Coal is Recovered ...................ES-16 

Table ES-3. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for South Hilight 

 Field LBA Tract and Black Thunder Mine – Reno Road is 

 Not Moved and Underlying Coal is Not Recovered ................ES-17 

Table ES-4. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for South Hilight 

 Field LBA Tract and Black Thunder Mine – Reno Road is 

 Moved and the Underlying Coal is Recovered.......................ES-18 
Table of Contents 

TABLE OF CONTENTS (Continued) 

Final EIS, Wright Area Coal Lease Applications xv 

Table ES-5. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for West Hilight 

 Field LBA Tract and Black Thunder Mine – State Highway 

 450 and Hilight Road are Not Moved and the Underlying 

 Coal is Not Recovered..........................................................ES-19 

Table ES-6. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for West Hilight 

 Field LBA Tract and Black Thunder Mine – State Highway 

 450 and Hilight Road are Moved and the Underlying 

 Coal is Recovered ................................................................ES-20 

Table ES-7. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for West Jacobs 

 Ranch LBA Tract and Jacobs Ranch Mine – State Highway 

 450 and Hilight Road are Not Moved and the Underlying 

 Coal is Not Recovered..........................................................ES-21 

Table ES-8. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for West Jacobs 

 Ranch LBA Tract and Jacobs Ranch Mine – State Highway 

 450 and Hilight Road are Moved and the Underlying Coal 

 is Recovered........................................................................ES-22 

Table ES-9. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for North Porcupine 

 LBA Tract and North Antelope Rochelle Mine – Mackey 

 Road is Not Moved and the Underlying Coal is Not 

 Recovered............................................................................ES-23 

Table ES-10. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for North Porcupine 

 LBA Tract and North Antelope Rochelle Mine – Mackey 

 Road is Moved and the Underlying Coal is Recovered...........ES-24 

Table ES-11. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for South Porcupine 

 LBA Tract and North Antelope Rochelle Mine – 2.25-Mile 

 Section of Antelope Road is Not Moved and the 

 Underlying Coal is Not Recovered ........................................ES-25 

Table ES-12. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for South Porcupine 

 LBA Tract and North Antelope Rochelle Mine – 2.25-Mile 

 Section of Antelope Road is Moved and the Underlying 

 Coal is Recovered ................................................................ES-26 

Table ES-13. Projected Maximum Potential Near-field Impacts .................ES-64 

Table ES-14. Modeled Change in Visibility Impacts at Class I and 

 Sensitive Class II Areas .......................................................ES-66 

Table ES-15. Recent and Projected PRB Population..................................ES-68 
Table of Contents 

TABLE OF CONTENTS (Continued) 

xvi Final EIS, Wright Area Coal Lease Applications

Table 1-1. Leases Issued and Exchanges Completed Since 

 Decertification, Powder River Basin, Wyoming .........................1-6 

Table 1-2. Pending LBAs, Powder River Basin, Wyoming .......................... 1-8 

Table 2-1. Regulatory Compliance, Mitigation and Monitoring 

 Measures for Surface Coal Mining Operations Required by 

 SMCRA and State Law for all Alternatives.............................. 2-71 

Table 2-2. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for North Hilight 

 Field LBA Tract and Black Thunder Mine – Shroyer Road 

 is Not Moved and the Underlying Coal is Not Recovered......... 2-78 

Table 2-3. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for North Hilight 

 Field LBA Tract and Black Thunder Mine – Shroyer Road 

 is Moved and Underlying Coal is Recovered ........................... 2-79 

Table 2-4. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for South Hilight 

 Field LBA Tract and Black Thunder Mine – Reno Road is 

 Not Moved and the Underlying Coal is Not Recovered ............ 2-80 

Table 2-5. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for South Hilight 

 Field LBA Tract and Black Thunder Mine – Reno Road is 

 Moved and the Underlying Coal is Recovered......................... 2-81 

Table 2-6. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for West Hilight 

 Field LBA Tract and Black Thunder Mine – State Highway 

 450 and Hilight Road are Not Moved and the Underlying 

 Coal is Not Recovered............................................................ 2-82 

Table 2-7. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for West Hilight 

 Field LBA Tract and Black Thunder Mine – State Highway 

 450 and Hilight Road are Moved and the Underlying 

 Coal is Recovered .................................................................. 2-83 

Table 2-8. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for West Jacobs 

 Ranch LBA Tract and Jacobs Ranch Mine – State Highway 

 450 and Hilight Road are Not Moved and the Underlying 

 Coal is Not Recovered............................................................ 2-84 

Table 2-9. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for West Jacobs 

 Ranch LBA Tract and Jacobs Ranch Mine – State Highway 

 450 and Hilight Road are Moved and the Underlying 

 Coal is Recovered .................................................................. 2-85 
Table of Contents 

TABLE OF CONTENTS (Continued) 

Final EIS, Wright Area Coal Lease Applications xvii 

Table 2-10. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for North Porcupine 

 LBA Tract and North Antelope Rochelle Mine – Mackey Road 

 is Not Moved and the Underlying Coal is Not Recovered......... 2-86 

Table 2-11. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for North Porcupine 

 LBA Tract and North Antelope Rochelle Mine – Mackey Road 

 is Moved and the Underlying Coal is Recovered ..................... 2-87 

Table 2-12. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for South Porcupine 

 LBA Tract and North Antelope Rochelle Mine – 2.25-Mile 

 Section of Antelope Road is Not Moved and the Underlying 

 Coal is Not Recovered............................................................ 2-88 

Table 2-13. Summary Comparison of Coal Production, Surface 

 Disturbance, Mine Life, and Revenues for South Porcupine 

 LBA Tract and North Antelope Rochelle Mine – 2.25-Mile 

 Section of Antelope Road is Moved and the Underlying 

 Coal is Recovered .................................................................. 2-89 

Table 2-14. Summary Comparison of Magnitude and Duration of Direct 

 and Indirect Impacts for Alternative 1 (No Action), the 

 Proposed Action, Alternative 2, and Alternative 3 for the 

 North Hilight Field, South Hilight Field, West Hilight Field, 

 West Jacobs Ranch, North Porcupine, and South Porcupine 

 LBA Tracts ............................................................................ 2-91 

Table 2-15. Summary Comparison of Magnitude and Duration of 

 Cumulative Impacts .............................................................. 2-98 

Table 3-1. Comparison of Existing and Proposed Black Thunder Mine 

 Disturbance Area and Mining Operations for the North 

 Hilight Field LBA Tract ............................................................ 3-4 

Table 3-2. Comparison of Existing and Proposed Black Thunder Mine 

 Disturbance Area and Mining Operations for the South 

 Hilight Field LBA Tract ............................................................ 3-4 

Table 3-3. Comparison of Existing and Proposed Black Thunder Mine 

 Disturbance Area and Mining Operations for the West 

 Hilight Field LBA Tract ............................................................ 3-5 

Table 3-4. Comparison of Existing and Proposed Jacobs Ranch Mine 

 Disturbance Area and Mining Operations for the West 

 Jacobs Ranch LBA Tract ......................................................... 3-5 

Table 3-5. Comparison of Existing and Proposed North Antelope 

 Rochelle Mine Disturbance Area and Mining Operations for 

 the North Porcupine LBA Tract................................................ 3-6 

Table 3-6. Comparison of Existing and Proposed North Antelope 

 Rochelle Mine Disturbance Area and Mining Operations for 

 the South Porcupine LBA Tract ............................................... 3-6 
Table of Contents 

TABLE OF CONTENTS (Continued) 

xviii Final EIS, Wright Area Coal Lease Applications

Table 3-7. Average Overburden, Interburden, and Coal Thicknesses 

 and Approximate Postmining Surface Elevation Changes 

 of the Six WAC LBA Tracts .................................................... 3-14 

Table 3-8. Assumed Background Air Pollutant Concentrations, 

 Applicable AAQS, and PSD Increment Values ........................ 3-50 

Table 3-9. 2001 Through 2008 Annual 4th Max, 8-Hour Average 

 Ozone Values ........................................................................ 3-80 

Table 3-10. Annual Ambient NO2 Concentration Data.............................. 3-89 

Table 3-11. 2002 Through 2008 Annual Mean NO2 Concentration 

 Data...................................................................................... 3-90 

Table 3-12. Approximate Distances and Directions from the General 

 Wright Analysis Area to Mandatory Federal PSD Class I, 

 Tribal Federal PSD Class I, and Federal PSD Class II Areas ... 3-92 

Table 3-13. Existing Acid Neutralizing Capacity in Sensitive Lakes........... 3-98 

Table 3-14. Vegetation Types Identified and Mapped Within the 

 Combined Vegetation Analysis Areas ................................... 3-184 

Table 3-15. Distribution of Surface Ownership Within Each LBA Tract 

Configured Under Alternative 2, BLM’s Preferred 

 Alternative .......................................................................... 3-237 

Table 3-16. North Hilight Field LBA Tract Federal Oil and Gas 

 Lessees of Record ................................................................ 3-251 

Table 3-17. South Hilight Field LBA Tract Federal Oil and Gas 

 Lessees of Record ................................................................ 3-252 

Table 3-18. West Hilight Field LBA Tract Federal Oil and Gas 

 Lessees of Record ................................................................ 3-252 

Table 3-19. West Jacobs Ranch LBA Tract Federal Oil and Gas 

 Lessees of Record ................................................................ 3-253 

Table 3-20. North Porcupine LBA Tract Federal Oil and Gas 

 Lessees of Record ................................................................ 3-254 

Table 3-21. South Porcupine LBA Tract Federal Oil and Gas 

 Lessees of Record ................................................................ 3-256 

Table 3-22. Noise Impacts Associated with Mine Blasting on the 

 Wright Area LBA Tracts....................................................... 3-284 

Table 3-23. Projected Socioeconomic Impacts from Leasing the 

 Wright Area LBA Tracts Under the Proposed Action and 

 Alternatives 2 and 3 ............................................................ 3-304 

Table 3-24. Estimated Annual Equivalent CO2 Emissions at the Black 

Thunder, Jacobs Ranch, and North Antelope Rochelle 

 Mines.................................................................................. 3-325 

Table 4-1. Status and Ownership of Wyoming PRB Coal Mines for 

 2003, the PRB Coal Review Baseline Year, and for 2007 .......... 4-7 

Table 4-2. Actual and Projected Wyoming PRB Coal Mine 

 Development, Lower Coal Production Scenario ...................... 4-11 
Table of Contents 

TABLE OF CONTENTS (Continued) 

Final EIS, Wright Area Coal Lease Applications xix 

Table 4-3. Actual and Projected Wyoming PRB Coal Mine 

 Development, Upper Coal Production Scenario ...................... 4-12 

Table 4-4. Actual and Projected Wyoming PRB Coal-Related 

 Development Scenario........................................................... 4-15 

Table 4-5. Past, Present, and Projected Wyoming PRB Coal Mine 

 and Coal-Related Development Scenario................................ 4-21 

Table 4-6. Actual and Projected Wyoming PRB Conventional 

 Oil and Gas Development Scenario........................................ 4-23 

Table 4-7. Actual and Projected Wyoming PRB CBNG Development 

 Scenario................................................................................ 4-24 

Table 4-8. Wyoming PRB Conventional Oil and Gas, CBNG, and 

 Related Development Disturbance and Water Production ...... 4-25 

Table 4-9. In-Situ Recovery Uranium Projects Currently Proposed 

 in the Wyoming PRB Study Area............................................ 4-30 

Table 4-10. Actual and Projected Wyoming PRB Total Development 

 Scenario, Task 3 Study Area.................................................. 4-40 

Table 4-11. Projected Maximum Potential Near-field Impacts ................... 4-47 

Table 4-12. Maximum Predicted PSD Class I and Sensitive Class 

 II Area Impacts...................................................................... 4-50 

Table 4-13. Modeled Change in Visibility Impacts at Class I and 

 Sensitive Class II Areas ......................................................... 4-51 

Table 4-14. Predicted Total Cumulative Change in Acid Neutralizing 

 Capacity of Sensitive Lakes ................................................... 4-53 

Table 4-15. Recoverable Groundwater in the Fort Union/Wasatch 

 Aquifer System in the PRB .................................................... 4-56 

Table 4-16. Water Use as of 2002 in the Powder/Tongue River 

 Basins................................................................................... 4-73 

Table 4-17. Surface Water Availability in the Powder/Tongue River 

 Basins................................................................................... 4-74 

Table 4-18. Water Use as of 2002 in the Northeast Wyoming River 

 Basins................................................................................... 4-74 

Table 4-19. Surface Water Availability in the Northeast Wyoming River 

 Basins................................................................................... 4-75 

Table 4-20. Summary of Proposed Limits for SAR and EC........................ 4-78 

Table 4-21. Projected Impact of CBNG Production Water Discharge on 

Perennial Streams................................................................. 4-82 

Table 4-22. Potential Cumulative Disturbance to Pronghorn Ranges 

 from Development Activities—Lower and Upper Coal 

 Production Scenarios ............................................................ 4-89 

Table 4-23. Potential Cumulative Disturbance to White-tailed Deer 

 Ranges from Development Activities—Lower and Upper 

 Coal Production Scenarios..................................................... 4-90 

Table 4-24. Potential Cumulative Disturbance to Mule Deer Ranges 

 from Development Activities—Lower and Upper Coal 

 Production Scenarios ............................................................ 4-90 
Table of Contents 

TABLE OF CONTENTS (Continued) 

xx Final EIS, Wright Area Coal Lease Applications

Table 4-25. Potential Cumulative Disturbance to Elk Ranges from 

 Development Activities – Lower and Upper Coal 

 Production Scenarios ............................................................ 4-90 

Table 4-26. Potential Cumulative Impacts to Greater Sage-grouse Leks 

 from Coal Mine Development – Upper and Lower Coal 

 Production Scenarios ............................................................ 4-99 

Table 4-27. Land Use by Surface Ownership.......................................... 4-100 

Table 4-28. AUMs and Acres of Cropland Estimated Unavailable on 

 Lands Disturbed and Not Yet Reclaimed as a Result of 

Development Activities ........................................................ 4-101 

Table 4-29. 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 ........................................ 4-105 

Table 4-30. PRB Rail Lines Coal Hauling Capacity and Projected Use..... 4-108 

Table 4-31. Recent and Projected PRB Population.................................. 4-115 

Table 4-32. Rental Housing Vacancy Rates, 2004 4Q and 2006 4Q........ 4-117 

Table 4-33. Total Housing Stock in 2000 and 2005................................ 4-117 

Table 4-34. Monthly Housing Rents in 2006 in the PRB Study Area 

 and Percent Change from 2004 ........................................... 4-118 

Table 4-35. Summary of Mineral Development Tax Revenues 

 Associated with Energy Resource Production Under the 

 Lower Coal Production Scenario .......................................... 4-125 

Table 4-36. Summary of Mineral Development Tax Revenues 

 Associated with Energy Resource Production Under the 

 Upper Coal Production Scenario.......................................... 4-126 

Table 4-37. Estimated Annual CO2 Emissions from Projected PRB 

 Coal Production Levels According to Task 2 or the PRB 

 Coal Review......................................................................... 4-138 

Table 4-38. Estimated Annual CO2 Equivalent Emissions from Coal 

Production at PRB Mine With Pending LBAs........................ 4-139 

Table 4-39. Estimated Annual CO2 Emissions Produced from 

 Combustion of Coal Produced from WAC LBA Tracts ........... 4-140 

Table 4-40. 2004 Percent Contribution to Worldwide Anthropogenic 

 Mercury Emissions.............................................................. 4-152 

Table 5-1. List of Contributors and Reviewers ............................................ 5-4 

Table 5-2. List of Preparers........................................................................ 5-7 

Table 5-3. BLM Distribution List for the Wright Area Final EIS .................. 5-8 

LIST OF FIGURES 

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

 LBA Tracts .........................................................................ES-2 

Figure ES-2. North Hilight Field LBA Tract Alternatives...........................ES-3 

Figure ES-3. South Hilight Field LBA Tract Alternatives ..........................ES-4 
Table of Contents 

TABLE OF CONTENTS (Continued) 

Final EIS, Wright Area Coal Lease Applications xxi 

Figure ES-4. West Hilight Field LBA Tract Alternatives............................ES-5 

Figure ES-5. West Jacobs Ranch LBA Tract Alternatives .........................ES-7 

Figure ES-6. North Porcupine LBA Tract Alternatives..............................ES-8 

Figure ES-7. South Porcupine LBA Tract Alternatives .............................ES-9 

Figure ES-8. Maximum Modeled PM10 and NOx Concentrations at 

 the Black Thunder Mine Ambient Air Boundary for 

 the Year 2017...................................................................ES-35 

Figure ES-9. Maximum Modeled PM10 Concentrations at the Jacobs 

 Ranch Mine Ambient Air Boundary for the Years 2013 

 and 2015..........................................................................ES-37 

Figure ES-10. Maximum Modeled PM10 and NOx Concentrations at 

 the North Antelope Rochelle Mine Ambient Air 

 Boundary for the Year 2017..............................................ES-38 

Figure ES-11. Residences, School Bus Stops, Public Roads, and 

 Other Publicly Accessible Facilities Within 3 Miles of 

 the North Hilight Field LBA Tract Under Alternative 2.......ES-41 

Figure ES-12. Residences, School Bus Stops, Public Roads, and 

 Other Publicly Accessible Facilities Within 3 Miles of 

 the South Hilight Field LBA Tract Under Alternative 2 ......ES-42 

Figure ES-13. Residences, School Bus Stops, Public Roads, and 

 Other Publicly Accessible Facilities Within 3 Miles of 

 the West Hilight Field LBA Tract Under Alternative 2 ........ES-43 

Figure ES-14. Residences, School Bus Stops, Public Roads, and 

 Other Publicly Accessible Facilities Within 3 Miles of 

 the West Jacobs Ranch LBA Tract Under Alternative 2 .....ES-44 

Figure ES-15 Residences, School Bus Stops, Public Roads, and 

 Other Publicly Accessible Facilities Within 3 Miles of 

 the North Porcupine LBA Tract Under Alternative 2 ..........ES-45 

Figure ES-16 Residences, School Bus Stops, Public Roads, and 

 Other Publicly Accessible Facilities Within 3 Miles of 

 the South Porcupine LBA Tract Under Alternative 2..........ES-46 

Figure ES-17 Extrapolated Extent of Life of Mine Cumulative 

 Drawdown Within the Wyodak Coal Aquifer With the 

 Addition of Wright Area Coal LBA Tracts...........................ES-47 

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

 Tracts ..................................................................................... 1-2 

Figure 1-2. Black Thunder Mine’s Federal Coal Leases and North 

 Hilight Field, South Hilight Field, and West Hilight Field 

 LBA Tracts as Applied for ...................................................... 1-10 

Figure 1-3. Jacobs Ranch Mine’s Federal Coal Leases and West 

 Jacobs Ranch LBA Tract as Applied for ................................. 1-13 

Figure 1-4. North Antelope Rochelle Mine’s Federal Coal Leases and 

 North Porcupine and South Porcupine LBA Tracts as 

 Applied for ............................................................................ 1-15 
Table of Contents 

TABLE OF CONTENTS (Continued) 

xxii Final EIS, Wright Area Coal Lease Applications

Figure 2-1. North Hilight Field LBA Tract Alternatives ............................... 2-2 

Figure 2-2. South Hilight Field LBA Tract Alternatives............................... 2-3 

Figure 2-3. West Hilight Field LBA Tract Alternatives ................................ 2-4 

Figure 2-4. West Jacobs Ranch LBA Tract Alternatives.............................. 2-5 

Figure 2-5. North Porcupine LBA Tract Alternatives................................... 2-6 

Figure 2-6. South Porcupine LBA Tract Alternatives .................................. 2-7 

Figure 3-1. General Wright Analysis Area ..................................................3-3 

Figure 3-2. Stratigraphic Relationship and Hydrologic Characteristics 

 of Upper Cretaceous, Lower Tertiary, and Recent Geologic 

 Units of the Powder River Basin, Wyoming ............................ 3-17 

Figure 3-3. Wind Rose, Air Quality and Meteorological Stations at the 

 Black Thunder Mine.............................................................. 3-52 

Figure 3-4. Wind Rose, Air Quality and Meteorological Stations at the 

 Jacobs Ranch Mine ............................................................... 3-53 

Figure 3-5. Wind Rose, Air Quality and Meteorological Stations at the 

 North Antelope Rochelle Mine................................................ 3-54 

Figure 3-6. Annual Coal Production and Overburden Removal vs. 

 Ambient Particulates for the General Wright Analysis 

 Area (1998 through 2008) ..................................................... 3-56 

Figure 3-7. Maximum Modeled PM10 and NOx Concentrations at the 

 Black Thunder Mine Ambient Air Boundary for the Year 

 2015 ..................................................................................... 3-61 

Figure 3-8. Maximum Modeled PM10 and NOx Concentrations at the 

 Black Thunder Mine Ambient Air Boundary for the Year 

 2017 ..................................................................................... 3-62 

Figure 3-9. Residences, School Bus Stops, Public Roads, and Other 

 Publicly Accessible Facilities in the Vicinity of the North 

 Hilight Field LBA Tract Under Alternative 2 ........................... 3-64 

Figure 3-10. Residences, School Bus Stops, Public Roads, and Other 

 Publicly Accessible Facilities in the Vicinity of the South 

 Hilight Field LBA Tract Under Alternative 2 ........................... 3-65 

Figure 3-11. Residences, School Bus Stops, Public Roads, and Other 

 Publicly Accessible Facilities in the Vicinity of the West 

 Hilight Field LBA Tract Under Alternative 2 ........................... 3-66 

Figure 3-12. Maximum Modeled PM10 Concentrations at the Jacobs 

 Ranch Mine Ambient Air Boundary for the Years 2013 

 and 2015 .............................................................................. 3-68 

Figure 3-13. Residences, School Bus Stops, Public Roads, and Other 

 Publicly Accessible Facilities in the Vicinity of the West 

 Jacobs Ranch LBA Tract Under Alternative 2 ........................ 3-69 

Figure 3-14. Maximum Modeled PM10 and NOx Concentrations at the 

 North Antelope Rochelle Mine Ambient Air Boundary for 

 the Year 2012........................................................................ 3-71 
Table of Contents 

TABLE OF CONTENTS (Continued) 

Final EIS, Wright Area Coal Lease Applications xxiii 

Figure 3-15. Maximum Modeled PM10 and NOx Concentrations at the 

 North Antelope Rochelle Mine Ambient Air Boundary for 

 the Year 2017........................................................................ 3-72 

Figure 3-16. Residences, School Bus Stops, Public Roads, and Other 

 Publicly Accessible Facilities in the Vicinity of the 

 North Porcupine LBA Tract Under Alternative 2..................... 3-74 

Figure 3-17. Residences, School Bus Stops, Public Roads, and Other 

 Publicly Accessible Facilities in the Vicinity of the 

 South Porcupine LBA Tract Under Alternative 2 .................... 3-75 

Figure 3-18. Maximum Modeled NOx Concentrations at the Jacobs 

 Ranch Mine Ambient Air Boundary for the Years 2006 

 and 2013 .............................................................................. 3-85 

Figure 3-19. Visibility in the Badlands and Windcave National Parks 

 and the Bridger/Fitzpatrick and Cloud Peak Wilderness 

 Areas .................................................................................... 3-94 

Figure 3-20. Locations of Currently Active Groundwater Monitoring 

 and Water Supply Wells at the Black Thunder Mine ............ 3-100 

Figure 3-21. Locations of Currently Active Groundwater Monitoring 

 and Water Supply Wells at the Jacobs Ranch Mine.............. 3-101 

Figure 3-22. Locations of Currently Active Groundwater Monitoring 

 and Water Supply Wells at the North Antelope Rochelle 

 Mine ................................................................................... 3-102 

Figure 3-23. Black Thunder Mine Life of Mine Drawdown, Resulting 

 from Currently Approved Mining with the Addition of the 

 North, South, and West Hilight Field LBA Tracts ................. 3-119 

Figure 3-24. Jacobs Ranch Mine Life of Mine Drawdown, Resulting 

 from Currently Approved Mining with the Addition of the 

 West Jacobs Ranch LBA Tract............................................. 3-124 

Figure 3-25. North Antelope Rochelle Mine Life of Mine Drawdown, 

 Resulting from Currently Approved Mining with the 

 Addition of the North and South Porcupine LBA Tracts........ 3-130 

Figure 3-26. Surface Drainage in the General Wright Analysis Area......... 3-134 

Figure 3-27. Surface Water Features Within and Adjacent to the 

 North Hilight Field LBA Tract Alternatives ........................... 3-136 

Figure 3-28. Surface Water Features Within and Adjacent to the 

 South Hilight Field LBA Tract Alternatives........................... 3-137 

Figure 3-29. Surface Water Features Within and Adjacent to the 

 West Hilight Field LBA Tract Alternatives ............................ 3-138 

Figure 3-30. Surface Water Features Within and Adjacent to the 

 West Jacobs Ranch LBA Tract Alternatives.......................... 3-140 

Figure 3-31. Surface Water Features Within and Adjacent to the 

 North and South Porcupine LBA Tract Alternatives.............. 3-141 

Figure 3-32. Raptor Nest Sites, Sage-Grouse Leks, and Prairie Dog 

 Colonies Within and Adjacent to the North Hilight Field 

 LBA Tract............................................................................ 3-199 
Table of Contents 

TABLE OF CONTENTS (Continued) 

xxiv Final EIS, Wright Area Coal Lease Applications

Figure 3-33. Raptor Nest Sites, Sage-Grouse Leks, and Prairie Dog 

 Colonies Within and Adjacent to the South Hilight Field 

 LBA Tract............................................................................ 3-200 

Figure 3-34. Raptor Nest Sites, Sage-Grouse Leks, and Prairie Dog 

 Colonies Within and Adjacent to the West Hilight Field 

 LBA Tract............................................................................ 3-201 

Figure 3-35. Raptor Nest Sites, Sage-Grouse Leks, and Prairie Dog 

 Colonies Within and Adjacent to the West Jacobs Ranch 

 LBA Tract............................................................................ 3-202 

Figure 3-36. Raptor Nest Sites, Sage-Grouse Leks, and Prairie Dog 

 Colonies Within and Adjacent to the North Porcupine 

 LBA Tract............................................................................ 3-203 

Figure 3-37. Raptor Nest Sites, Sage-Grouse Leks, and Prairie Dog 

 Colonies Within and Adjacent to the South Porcupine 

 LBA Tract............................................................................ 3-204 

Figure 3-38. Average Male Sage-grouse Lek Attendance Within the 

 Northeast Wyoming Local Working Group Area.................... 3-222 

Figure 3-39. Average Male Sage-grouse Lek Attendance Statewide 

 and Within the Northeast Wyoming Local Sage-grouse 

 Working Group Area and the Thunder Basin National 

 Grasslands.......................................................................... 3-223 

Figure 3-40. Surface Ownership Within the North Hilight Field LBA 

 Tract Alternatives................................................................ 3-238 

Figure 3-41. Surface Ownership Within the South Hilight Field LBA 

 Tract Alternatives................................................................ 3-239 

Figure 3-42. Surface Ownership Within the West Hilight Field LBA 

 Tract Alternatives................................................................ 3-240 

Figure 3-43. Surface Ownership Within the West Jacobs Ranch LBA 

 Tract Alternatives................................................................ 3-241 

Figure 3-44. Surface Ownership Within the North Porcupine LBA 

 Tract Alternatives................................................................ 3-242 

Figure 3-45. Surface Ownership Within the South Porcupine LBA 

 Tract Alternatives................................................................ 3-243 

Figure 3-46. Oil and Gas Wells and Oil and Gas Ownership Within 

 the North Hilight Field LBA Tract Alternatives ..................... 3-245 

Figure 3-47. Oil and Gas Wells and Oil and Gas Ownership Within 

 the South Hilight Field LBA Tract Alternatives..................... 3-246 

Figure 3-48. Oil and Gas Wells and Oil and Gas Ownership Within 

 the West Hilight Field LBA Tract Alternatives....................... 3-247 

Figure 3-49. Oil and Gas Wells and Oil and Gas Ownership Within 

 the West Jacobs Ranch LBA Tract Alternatives.................... 3-248 

Figure 3-50. Oil and Gas Wells and Oil and Gas Ownership Within 

 the North Porcupine LBA Tract Alternatives......................... 3-249 

Figure 3-51. Oil and Gas Wells and Oil and Gas Ownership Within 

 the South Porcupine LBA Tract Alternatives ........................ 3-250 
Table of Contents 

TABLE OF CONTENTS (Continued) 

Final EIS, Wright Area Coal Lease Applications xxv 

Figure 3-52. Relationship Between A-Scale Decibel Readings and 

 Sounds of Daily Life ............................................................ 3-282 

Figure 3-53. Transportation Facilities Within and Adjacent to the 

 North, South, and West Hilight Field LBA Tracts ................. 3-287 

Figure 3-54. Transportation Facilities Within and Adjacent to the 

 West Jacobs Ranch LBA Tract............................................. 3-288 

Figure 3-55. Transportation Facilities Within and Adjacent to the 

 North and South Porcupine LBA Tracts ............................... 3-289 

Figure 3-56. Pipelines Within and Adjacent to the North, South, 

 and West Hilight Field LBA Tracts ....................................... 3-290 

Figure 3-57. Pipelines Within and Adjacent to the West Jacobs Ranch 

 LBA Tract............................................................................ 3-291 

Figure 3-58. Pipelines Within and Adjacent to the North and South 

 Porcupine LBA Tracts.......................................................... 3-292 

Figure 3-59. Estimated Wyoming and Federal Revenues from 2007 

 Coal Production in Campbell County................................... 3-303 

Figure 4-1. Wyoming Study Area for PRB Coal Review Evaluating 

 Current and Projected Levels of Development ..........................4-3 

Figure 4-2. Tons of Federal Coal Leased Versus Tons of Federal Coal 

 Mined Since 1990 ...................................................................4-5 

Figure 4-3. Projected and Actual Total Coal Production from Campbell 

 and Converse Counties Under the Lower and Upper 

 Production Scenarios ............................................................ 4-10 

Figure 4-4. Wyoming Task 3 Study Area for PRB Coal Review Studies 

Evaluating Projected Environmental Consequences ............... 4-39 

Figure 4-5. Extrapolated Extent of Life of Mine Cumulative Drawdown 

 Within the Wyodak Coal Aquifer With the Addition of 

 Wright Area Coal LBA Tracts ................................................. 4-60 

Figure 4-6. Coal Mine Groundwater Model, Upper Fort Union 

 Formation, 1990-2010 Coal Mine-related Groundwater 

 Level Drawdown.................................................................... 4-63 

Figure 4-7. Coal Mine Groundwater Model, Upper Fort Union 

 Formation, 1990-2020 Coal Mine-related Groundwater 

 Level Drawdown.................................................................... 4-64 

Figure 4-8. Coal Mine Groundwater Model, Upper Fort Union 

 Formation 1990-2010 Coal Bed Natural Gas-related 

 Groundwater Level Drawdown............................................... 4-67 

Figure 4-9. Coal Mine Groundwater Model, Upper Fort Union 

 Formation, 1990-2020 Coal Bed Natural Gas-related 

 Groundwater Level Drawdown............................................... 4-68 

Figure 4-10. Projected Campbell County Population and Employment 

 to 2020 ............................................................................... 4-116 

Figure 4-11. Projected Housing Demand in the PRB Study Area Under 

 the Lower Coal Production Scenario .................................... 4-119 
Table of Contents 

TABLE OF CONTENTS (Continued) 

xxvi Final EIS, Wright Area Coal Lease Applications

Figure 4-12. Projected School Enrollment Trends to 2020 Under the 

 Lower Coal Production Scenario .......................................... 4-122 

Figure 4-13. Current and Forecast Mix of Electric Generation Sources .... 4-149 

LIST OF APPENDICES 

Appendix A. Federal and State Permitting Requirements and Agencies 

Appendix B. Unsuitability Criteria for the North Hilight Field, South Hilight 

Field, West Hilight Field, West Jacobs Ranch, North Porcupine, 

and South Porcupine LBA Study Areas 

Appendix C. Coal Lease-By-Application Flow Chart 

Appendix D. Bureau of Land Management Special Coal Lease Stipulations, 

U.S. Forest Service Special Stipulations, and Form 3400-12 

Coal Lease 

Appendix E. Conventional Oil and Gas and Coal Bed Natural Gas Wells 

Capable of Production Located Within the BLM Study Areas for 

the North Hilight Field LBA Tract, South Hilight Field LBA Tract, 

West Hilight Field LBA Tract, West Jacobs Ranch LBA Tract, 

North Porcupine LBA Tract and South Porcupine LBA Tract 

Appendix F. Supplemental Air Quality Information 

Appendix G. Biological Assessment for the Wright Area Coal Lease 

Applications EIS for the North Hilight Field LBA Tract, South 

Hilight Field LBA Tract, West Hilight Field LBA Tract, West 

Jacobs Ranch LBA Tract, North Porcupine LBA Tract and South 

Porcupine LBA Tract 

Appendix H. BLM Sensitive Species and USFS Region 2 Sensitive Species and 

Management Indicator Species Evaluations for the Wright Area 

Coal Lease Applications EIS 

Appendix I. Draft EIS Comment Letters, BLM Responses, and Hearing 

Summary 
Abbreviations and Acronyms 

Final EIS, Wright Area Coal Lease Applications xxvii

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 

AIRS Aerometric Information and Retrieval System 

ALC Ark Land Company 

AML Abandoned Mine Land 

ANC acidification neutralization capacity 

ANFO ammonium nitrate fuel oil 

APD Application for Permit to Drill 

APLIC Avian Power Line Interaction Committee 

AQD Air Quality Division 

AQRV air quality related values 

ARCO Atlantic Richfield Company 

ARS Air Resource Specialists, Inc. 

ASCM alternative sediment control measure 

AUM animal unit month 

AVF alluvial valley floor 

A&C Allen and Crouch Petroleum Engineers, Inc. 

BACM best available control method 

BACT best available control technology 

bcf billion cubic feet 

bcy bank cubic yards 

BLM Bureau of Land Management 

BMP best management practice 

BNSF Burlington Northern Santa Fe 

BNSF-UP, BNSF&UP Burlington Northern Santa Fe and Union Pacific 

BN-UP, BN&UP Burlington Northern-Union Pacific 

boe barrels of oil equivalent 

B.P. before present 

BTU BTU Western Resources, Inc. 

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 

CANAC CANAC Railway Service, Inc. 

CANDO Converse Area New Development Organization 

CBNG coal bed natural gas 

CCBC Campbell County Board of Commissioners 

CCC Caballo Coal Company 

CCEDC Campbell County Economic Development Corporation 

CCP coal combustion product 

CCS carbon capture and storage 

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 

 
Abbreviations and Acronyms 

xxviii Final EIS, Wright Area Coal Lease Applications 

Abbreviations and Acronyms Used in this Report 

CH4 methane 

CMC Cordero Mining Company 

CMGC Coal Mine Groundwater Model 

CO carbon monoxide 

CO2 carbon dioxide 

CO2e CO2 equivalents 

COE U.S. Army Corps of Engineers 

CP Canadian Pacific Railway Ltd. 

CREG Consensus Revenue Estimating Group 

CRI Caballo Rojo, Inc. 

CSI Community Strategies Institute 

CWA Clean Water Act 

cy cubic yards 

dBA A-weighted decibels 

DEIS Draft Environmental Impact Statement 

DM&E Dakota, Minnesota & Eastern Railroad Corporation 

DOE Department of Energy 

DNRC Department of Natural Resources and Conservation 

DOI Department of the Interior 

dv deciview, a measure of view impairment 

EA Environmental Assessment 

EC elemental carbon particles (re: air quality) 

EIA Energy Information Administration 

EIS Environmental Impact Statement 

ENCOAL Encoal Corporation 

EO Executive Order 

EOR enhanced oil recovery 

EPA U.S. Environmental Protection Agency 

EPRI Electric Power Research Institute 

EQC Environmental Quality Council 

ESA Endangered Species Act 

EUR estimated ultimate recovery 

EVG Erathem-Vanir Geological, PLLC 

F Fahrenheit 

FAA Federal Aviation Administration 

FCLAA Federal Coal Leasing Act Amendments of 1976 

FCW Foundation Coal West, Inc. 

FDM Fugitive Dust Model 

FEA Final Environmental Assessment 

FEIS Final Environmental Impact Statement 

FERC Federal Energy Regulatory Commission 

FGD Flue Gas Desulfurization 

FLM Federal Land Management 

FLPMA Federal Land Policy Management Act of 1976 

FOIA Freedom of Information Act 

FR Federal Register 

FRA Federal Railroad Administration 

ft feet, foot 

ft/day feet per day 

ft/mile feet per mile 

ft3 cubic feet 

 
Abbreviations and Acronyms 

Final EIS, Wright Area Coal Lease Applications xxix

Abbreviations and Acronyms Used in this Report 

FY fiscal year 

FYPC Fossil Yield Potential Classification 

g gram 

GAO General Accounting Office 

GAGMO Gillette Area Ground Water Monitoring Organization 

GDP Gross Domestic Product 

GHG greenhouse gas 

GIS Geographic Information Systems 

gpm gallons per minute 

GPS Global Positioning System 

GSP Gross State Product 

HAP Hazardous Air Pollutant 

HFC hydrofluorocarbon 

HIP Health Impact Assessment 

hp horsepower 

hr hour 

HUC Hydrologic Unit Code 

IBLA Interior Board of Land Appeals 

IGCC Integrated Gasification Combined Cycle 

IMPROVE Interagency Monitoring of Protected Visual Environments 

IR Intermountain Resources 

JRCC Jacobs Ranch Coal Company 

JRM Jacobs Ranch Mine 

J&S Thunderbird - Jones & Stokes 

km kilometers 

kV kilovolts 

LAC limits of acceptable change (re: air quality) 

LBA lease by application 

lbs/mmBtu pounds per million British thermal units 

LFC liquids from coal 

LNCM Lands Necessary to Conduct Mining 

LOP life of project 

LRMP Land and Resource Management Plan 

LW Lower Wyodak coal seam 

MACT Maximum Achievable Control Technology 

MBHFI migratory birds of high federal interest 

MBTA Migratory Bird Treaty Act 

μeq/L microequivalents per liter 

μg/m3 micrograms per cubic meter 

μmhos/cm micromhos per centimeter 

mcf thousand cubic feet 

MDEQ Montana Department of Environmental Quality 

MDEQ/AWM Montana Department of Environmental Quality/Air and Waste 

Management Bureau 

MEI maximally exposed individual 

mg/L milligrams per liter 

MLA Mineral Leasing Act of 1920 

MLE most likely exposure 

mm million 

mmbcy million bank cubic yards 

mmbo million barrels of oil 

 
Abbreviations and Acronyms 

xxx Final EIS, Wright Area Coal Lease Applications 

Abbreviations and Acronyms Used in this Report 

mmcf million cubic feet 

mmcfpd million cubic feet of gas per day 

mmgpy million gallons per year 

mmt million tons 

mmtpy million tons per year 

mph miles per hour 

MSA Metropolitan Statistical Area 

MSDS material safety data sheet 

MW megawatts 

NAAQS National Ambient Air Quality Standards 

NADP National Atmospheric Deposition Program 

NALMA North American Land Mammal Age 

NAPG North American Power Group 

NARM North Antelope Rochelle Mine 

NCTA National Coal Transportation Association 

NEAP Natural Events Action Plan 

NEPA National Environmental Policy Act of 1969 

NERC North American Electric Reliability Council 

NIOSH National Institute of Occupational Safety and Health 

NO nitrogen oxide 

NOA notice of availability 

NOAA National Oceanic and Atmospheric Administration 

NOI notice of intent 

N2O nitrous oxide 

NO2 nitrogen dioxide 

NOX nitrogen oxides 

NPDES National Pollution Discharge Elimination System 

NPS National Park Service 

NRCS Natural Resources Conservation Service 

NRHP National Register of Historic Places 

NSPS National Source Performance Standards 

NSR New Source Review 

NWI National Wetlands Inventory 

NWLSWG Northeast Wyoming Local Sage-Grouse Working Group 

O3 ozone (photochemical oxidants) 

OC organic carbon particles 

OHWM ordinary high water mark 

OFE Office of Fossil Energy 

ORV off road vehicle 

OSHA Occupational Safety and Health Administration 

OSM Office of Surface Mining Reclamation & Enforcement 

OWUS other waters of the U.S. 

PEC Peabody Energy Corporation 

PECs passive enclosure control systems 

PETM Paleocene-Eocene Thermal Maxim 

PFYC Probable Fossil Yield Classification 

P.M. Prime Meridian 

P&M Pittsburg and Midway Coal Mining Company 

PM2.5 particulates finer than 2.5 microns in effective diameter 

PM10 particulates finer than 10 microns in effective diameter 

PMT postmining topography 

 
Abbreviations and Acronyms 

Final EIS, Wright Area Coal Lease Applications xxxi

Abbreviations and Acronyms Used in this Report 

POD Plan of Development 

ppm parts per million 

PRB Powder River Basin 

PRBRC Powder River Basin Resource Council 

PRC Powder River Coal, LLC 

PRCC Powder River Coal Company 

PRPA Paleontological Resource Preservation Act 

PRRCT Powder River Regional Coal Team 

PSD Prevention of Significant Deterioration 

R2P2 Resource Recovery and Protection Plan 

RAG RAG Coal West, Inc. 

RFD reasonably foreseeable development 

RH relative humidity 

RMEF Rocky Mountain Elk Foundation 

RMP Resource Management Plan 

ROD Record of Decision 

ROW right-of-way 

RTEA Rio Tinto Energy America 

RV recreational vehicle 

SAR Sodium-adsorption ratio 

SARA Superfund Amendment & Reauthorization Act of 1986 

scf/ton standard cubic feet per ton 

SCSD Sheridan County School District 

SEIS Supplemental Environmental Impact Statement 

SEO State Engineer’s Office 

SGAC South Gillette Area Coal 

SHPO State Historic Preservation Office 

SIP State Implementation Plan 

SMCRA Surface Mining Control and Reclamation Act of 1977 

SO2 sulfur dioxide 

SPL Sound Pressure Level 

SPRB South Powder River Basin 

STB Surface Transportation Board 

T&E Threatened and Endangered 

TBCC Thunder Basin Coal Company, LLC 

TBGA Thunder Basin Grazing Association 

TBNG Thunder Basin National Grassland 

TBNG-DRD Thunder Basin National Grassland – Douglas Ranger District 

TCO temporary cessation of operations 

TDS total dissolved solids 

TJS Thunderbird, Jones & Stokes 

TPY tons per year 

TSP total suspended particulates 

TSS total suspended solids 

UPRR Union Pacific Rail Road 

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 

USDOE U.S. Department of Energy 

 
Abbreviations and Acronyms 

xxxii Final EIS, Wright Area Coal Lease Applications 

Abbreviations and Acronyms Used in this Report 

USGS U.S. Geological Survey 

USFS U.S. Department of Agriculture - Forest Service 

USFWS U.S. Fish and Wildlife Service 

UW University of Wyoming 

VMT vehicle miles traveled 

VOCs volatile organic compounds 

VRM visual resource management 

WA Wilderness Area 

WAC Wright Area Coal 

WAAQS Wyoming Ambient Air Quality Standards 

WAQSR Wyoming Air Quality Standards and Regulations 

WARMS Wyoming Air Resources Monitoring System 

WCDA Wyoming Community Development Authority 

WCIC Wyoming Coal Information Committee 

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 

WEQC Wyoming Environmental Quality Council 

WFA Western Fuels Association 

WGFD Wyoming Game and Fish Department 

WMA Wyoming Mining Association 

WOC Wyoming Outdoor Council 

WOGCC Wyoming Oil and Gas Conservation Commission 

WOUS Waters of the U.S. 

WRCC Western Regional Climate Center 

WRRI Water Resources Research Institute 

WSBLC Wyoming State Board of Land Commissioners 

WSFC Wyoming School Facilities Commission 

WSGS Wyoming State Geological Survey 

WSO-RMG Wyoming State Office Reservoir Management Group (BLM) 

WYDOT Wyoming Department of Transportation 

WYPDES Wyoming Pollution Discharge Elimination System 

WYNDD Wyoming Natural Diversity Database 

WWC WWC Engineering 
1.0 Introduction 

Final EIS, Wright Area Coal Lease Applications 1-1 

1.0 INTRODUCTION

This Environmental Impact Statement (EIS)1 analyzes the environmental 

impacts of leasing six tracts of federal coal reserves adjacent to the Black 

Thunder, Jacobs Ranch, and North Antelope Rochelle mines. All are operating 

surface coal mines in the southern Powder River Basin (PRB) of Wyoming, near 

the town of Wright. The operators of the Black Thunder, Jacobs Ranch, and 

North Antelope Rochelle mines filed four applications to lease the six tracts of 

federal coal included in maintenance coal tracts under the regulations at 43 

CFR 3425, Leasing On Application. The Division of Minerals and Lands at the 

Bureau of Land Management (BLM) Wyoming State Office reviewed all four 

applications and determined that the lease applications met the regulatory 

requirements for Lease by Applications (LBAs). These maintenance coal tracts, 

which would continue or extend the life of the applicant mines, are referred to 

as the North Hilight Field LBA Tract, the South Hilight Field LBA Tract, the 

West Hilight Field LBA Tract, the West Jacobs Ranch LBA Tract, the North 

Porcupine LBA Tract, and the South Porcupine LBA Tract. Figure 1-1 shows 

the six LBA tracts as applied for, other currently pending LBA tracts, and the 

existing federal leases including previously leased LBA tracts in the Wyoming 

PRB. 

In addition to this EIS, a separate document entitled Supplementary 

Information on the Affected Environment in the General Analysis Areas for the 

Wright Area Coal Lease Applications EIS has been prepared. The 

supplementary document provides detailed site-specific information on the 

existing environment associated with the North Hilight Field, South Hilight 

Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South 

Porcupine LBA Tracts. These six tracts of federal coal reserves are located 

adjacent to operating mines in the southern Powder River Basin near Wright, 

Wyoming. Copies of the supplementary information document are available 

upon request and can be viewed at the BLM offices in Casper and Cheyenne. 

1.1 Background 

On October 7, 2005, Ark Land Company (ALC) filed an application with the 

BLM for federal coal reserves in two separate tracts located north and 

southwest of and immediately adjacent to the Black Thunder Mine in Campbell 

County, Wyoming. The tracts are referred to as the North Hilight Field and 

South Hilight Field LBA Tracts. The North Hilight Field tract is located 

approximately 5.5 miles east of Wright, Wyoming and the South Hilight Field 

tract is located approximately 7 miles southeast of Wright (Figure 1-1). The 

federal coal reserves were applied for as maintenance tracts for the Black 

Thunder Mine. BLM determined that the two tracts in the application would be 

processed separately and, if the decision is made to conduct a lease sale, would 

be offered for sale separately. ALC is a wholly owned subsidiary of Arch Coal,

 

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

Niobrara County

To Douglas 46 Miles

 LEGEND

GILLETTE

ROZET

MOORCROFT

To Buffalo 38 Miles

To Newcastle 29 Miles

North Antelope Rochelle Mine

Belle Ayr North

Belle Ayr Mine

Dry Fork Mine

Wyodak Mine

Rawhide Mine

Caballo Mine

Cordero Rojo Mine

Coal Creek Mine

Buckskin Mine

Eagle Butte Mine

Antelope Mine

Black Thunder Mine

Jacobs Ranch Mine

West Antelope II

Caballo West

Coal-Fired Power Plant

(Proposed or Under Construction)

SCALE: 1"= 10 MILES

West Coal Creek

WEST JACOBS RANCH

Hay Creek II

Maysdorf II

WEST HILIGHT FIELD

SOUTH HILIGHT FIELD

NORTH PORCUPINE

59

LBA Tracts As Applied For (This EIS)

LBA's Pending

LBA's Issued

Existing Leases (Prior to Decertification)

RENO

JUNCTION

Converse County

Johnson County

Campbell County

Campbell County

Crook County Weston County

Campbell County Weston County

Converse County

116

450

387

50

90

90

90 16

16

14

14

50

387

59

59

NORTH HILIGHT FIELD

SOUTH PORCUPINE

School Creek Mine

(Proposed)

North Rochelle Mine

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

1.0 Introduction

1-2 Final EIS, Wright Area Coal Lease Applications
1.0 Introduction 

Final EIS, Wright Area Coal Lease Applications 1-3 

Inc. The Black Thunder Mine is operated by Thunder Basin Coal Company 

(TBCC), a subsidiary of Arch Western Resources, LLC. In this EIS, ALC is 

referred to as the applicant and TBCC is referred to in discussions of mine 

operations. ALC’s coal lease application was assigned case file numbers 

WYW164812 (North Hilight Field) and WYW174596 (South Hilight Field). 

On January 17, 2006, ALC filed an application with the BLM for federal coal 

reserves in a tract located west of and immediately adjacent to the Black 

Thunder Mine in Campbell County, Wyoming, approximately 4 miles southeast 

of Wright, Wyoming (Figure 1-1). The tract, which is referred to as the West 

Hilight Field LBA Tract, was assigned case file number WYW172388. The 

federal coal reserves were applied for as a maintenance tract for the Black 

Thunder Mine. 

On March 24, 2006, Jacobs Ranch Coal Company (JRCC) filed an application 

with the BLM for federal coal reserves in a tract located approximately 0.75 

mile west of the Jacobs Ranch Mine in Campbell County, Wyoming. The tract, 

which is referred to as the West Jacobs Ranch LBA Tract, is located 

approximately 2.5 miles east of Wright, Wyoming (Figure 1-1). JRCC’s coal 

lease application was assigned case file number WYW172685. The federal coal 

reserves were applied for as a maintenance tract for the Jacobs Ranch Mine. 

On October 1, 2009, the Jacobs Ranch Mine was acquired by Arch Coal, Inc. 

ALC intends to consolidate the permits for the Jacobs Ranch Mine and the 

Black Thunder Mine in order to integrate the two separate mining operations. 

In this EIS, the applicant for the West Jacobs Ranch LBA Tract will be referred 

to as ALC. It is assumed that ALC would be the successful bidder, and that 

the West Jacobs Ranch tract would be mined as a maintenance lease for the 

existing Jacobs Ranch Mine. 

On September 29, 2006, BTU Western Resources, Inc. (BTU) filed an 

application with the BLM for federal coal reserves in three separate tracts 

located west, northwest, and north of and immediately adjacent to the North 

Antelope Rochelle Mine in Campbell County, Wyoming. The two tracts on the 

north side of the mine are referred to as the North Porcupine LBA Tract, and 

the tract on the west side of the mine is referred to as the South Porcupine LBA 

Tract. 

On October 12, 2007, BTU filed a request with the BLM to modify the 

Porcupine LBA Tract configuration to increase the lease area and coal volume. 

The North Porcupine LBA Tract, which is located approximately 12 miles 

southeast of Wright, Wyoming, was combined into one tract and its size was 

increased with additional lands. The South Porcupine LBA Tract, which is 

located approximately 14 miles southeast of Wright, was also increased in size 

with additional lands (Figure 1-1). BLM reviewed the modified tract 

configuration and notified the company that their application had been 

modified. The federal coal reserves were applied for as maintenance tracts for 

the North Antelope Rochelle Mine. BLM determined that the two tracts in the 

application would be processed separately and, if the decision is made to 
1.0 Introduction 

1-4 Final EIS, Wright Area Coal Lease Applications 

conduct a lease sale, would be offered for sale separately. The North Antelope 

Rochelle Mine is operated by Powder River Coal, LLC (PRC), a subsidiary of 

Peabody Energy Corporation (PEC). BTU is also a subsidiary of PEC, and in 

this EIS, BTU is referred to as the applicant and PRC is referred to in 

discussions of mine operations. BTU’s coal lease application was assigned case 

file numbers WYW173408 (North Porcupine) and WYW176095 (South 

Porcupine). 

These federal coal lands are located within the Powder River Federal Coal 

Region, which was decertified in January, 1990. Although the Powder River 

Federal Coal Region is decertified, the Powder River Regional Coal Team 

(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 the ALC and JRCC maintenance coal lease 

applications (case file numbers WYW164812, WYW174596, WYW172388, and 

WYW172685) at a public meeting held on April 19, 2006 in Casper, Wyoming. 

The PRRCT reviewed the BTU maintenance coal lease application (case file 

numbers WYW173408 and WYW176095) at a public meeting held on January 

18, 2007 in Casper, Wyoming. The PRRCT recommended that the BLM process 

the coal lease applications at those respective meetings. 

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 National Environmental Policy Act of 1969 

(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. 

The BLM determined that one EIS would be prepared to evaluate the 

environmental impacts that would be expected to occur if leases are issued for 

the North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs 

Ranch, North Porcupine, and South Porcupine LBA Tracts. This EIS has been 

prepared to evaluate the site-specific and cumulative environmental impacts of 

leasing and developing the federal coal included in these application areas. For 

each of the six LBA tracts, 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 the modified tract, or reject the 

lease application and not offer the tract for sale at this time. A separate Record 

of Decision (ROD) will be issued for each LBA tract. If the decision is made to 

offer the tract for lease, then a separate sale would be held for each tract. The 

bidding at the sale would be open to any qualified bidder; it would not be 

limited to the applicant. 

If a lease sale is held, each 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. 
1.0 Introduction 

Final EIS, Wright Area Coal Lease Applications 1-5 

Also, before the lease could be issued to the high bidder, the United States 

Department of Justice would need to determine that there would be no 

antitrust violations. 

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. Prior to 2008, federal bonus, rental, and royalty 

payments were equally divided with the state in which the lease was located. 

However, in fiscal year 2008, Congress decreased the state’s royalty share to 48 

percent, and increased the federal government’s share to 52 percent. The 

percentage of federal bonus, rental, and royalty payments distribution reverted 

back to 50 percent/50 percent at the end of the 2008 fiscal year. 

Other agencies may use this analysis to make decisions related to leasing and 

mining the federal coal in these tracts. Cooperating agencies on this EIS 

include: Office of Surface Mining Reclamation and Enforcement (OSM), U.S. 

Department of Agriculture-Forest Service (USFS), Wyoming Department of 

Transportation (WYDOT), Wyoming Department of Environmental Quality 

(WDEQ) Air Quality Division (AQD) and WDEQ Land Quality Division (LQD), 

and the Converse County Board of Commissioners. 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 Mineral Leasing Act of 1920 (MLA) mining plan if the tracts are leased. If 

USFS lands are included in a tract, USFS must consent to lease the federal 

coal that is located on USFS-administered lands before BLM can make a 

decision to hold a federal coal lease sale. WYDOT’s responsibilities include 

planning and supervising road improvement work, maintaining roads, and 

supporting airports and aviation in the state. 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. 

Since decertification of the Powder River Federal Coal Region in 1990, 20 

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 (BLM 2009a). Each mine with an application 

being considered in this EIS has previously been issued a maintenance coal 

lease since decertification (Table 1-1 and Figure 1-1). 

Table 1-2 summarizes the 12 LBAs that are currently pending (BLM 2009a). 

1.1.1 North and South Hilight Field LBA Tracts

As applied for, the Hilight Field LBA Tract, adjacent to the Black Thunder Mine, 

consisted of two separate blocks of federal coal and included a total of 

approximately 4,590.19 acres with an estimated 477.0 million tons of 
1.0 Introduction 

1-6 Final EIS, Wright Area Coal Lease Applications 

Table 1-1. Leases Issued and Exchanges Completed Since Decertification, 

Powder River Basin, Wyoming. 

Leases Issued

LBA Name (Lease Number) 

Applicant Mine 

Current Lessee 

Effective Date 

Acres 

Leased1

Mineable Tons 

of Coal1

Successful 

Bid 

Jacobs Ranch (WYW117924) 

Jacobs Ranch Mine 

Thunder Basin Coal Co. 

10/1/1992 

1,708.620 147,423,560 $20,114,930.00 

West Black Thunder (WYW118907) 

Black Thunder Mine 

Thunder Basin Coal Co. 

10/1/1992 

3,492.495 429,048,216 $71,909,282.69 

North Antelope/Rochelle (WYW119554) 

North Antelope Rochelle Mine 

Powder River Coal Co., LLC 

10/1/1992 

3,064.040 403,500,000 $86,987,765.00 

West Rocky Butte (WYW122586) 

No Existing Mine2

Caballo Coal Co. 

1/1/1993 

463.205 56,700,000 $16,500,000.00 

Eagle Butte (WYW124783)

Eagle Butte Mine 

Alpha Coal West, Inc. 

8/1/1995 

1,059.180 166,400,000 $18,470,400.00 

Antelope (WYW128322) 

Antelope Mine 

Antelope Coal Co. 

2/1/1997 

617.200 60,364,000 $9,054,600.00 

North Rochelle (WYW127221) 

North Rochelle Mine 

Ark Land Co. 

1/1/1998 

1,481.930 157,610,000 $30,576,340.00 

Powder River (WYW136142) 

North Antelope Rochelle Mine 

Powder River Coal Co., LLC 

9/1/1998 

4,224.225 532,000,000 $109,596,500.00 

Thundercloud (WYW136458) 

Jacobs Ranch Mine 

Thunder Basin Coal Co. 

1/1/1999 

3,545.503 412,000,000 $158,000,008.50 

Horse Creek (WYW141435) 

Antelope Mine 

Antelope Coal Co. 

12/1/2000 

2,818.695 275,577,000 $91,220,120.70 

North Jacobs Ranch (WYW146744) 

Jacobs Ranch Mine 

Thunder Basin Coal Co. 

5/1/2002 

4,982.240 537,542,000 $379,504,652.00 

NARO South (WYW154001)

North Antelope Rochelle Mine 

BTU Western Resources, Inc. 

9/1/2004

2,956.725 297,469,000 $274,117,684.00 

West Hay Creek (WYW151634) 

Buckskin Mine 

Kiewit Mining Properties, Inc. 

1/1/2005

921.158 142,698,000 $42,809,400.00
1.0 Introduction 

Final EIS, Wright Area Coal Lease Applications 1-7 

Table 1-1. Leases Issued and Exchanges Completed Since Decertification, 

Powder River Basin, Wyoming (Continued). 

Leases Issued

LBA Name (Lease Number) 

Applicant Mine 

Current Lessee 

Effective Date 

Acres 

Leased1

Mineable Tons 

of Coal1

Successful 

Bid 

Little Thunder (WYW150318) 

Black Thunder Mine 

Ark Land Co. 

3/1/2005

5,083.500 718,719,000 $610,999,949.80

West Antelope (WYW151643) 

Antelope Mine 

Antelope Coal Co. 

3/1/2005

2,809.130 194,961,000 $146,311,000.00 

NARO North (WYW150210) 

North Antelope Rochelle Mine 

BTU Western Resources, Inc. 

3/1/2005 

2,369.380 324,627,000 $299,143,785.00 

West Roundup (WYW151134) 

North Rochelle Mine 

West Roundup Resources, Inc. 

5/1/2005

2,812.510 327,186,000 $317,697,610.00 

Eagle Butte West (WYW155132) 

Eagle Butte Mine 

Alpha Coal West, Inc. 

5/1/2008

1,427.770 255,000,000 $180,540,000.00 

South Maysdorf (WYW174407) 

Cordero Rojo Mine 

Cordero Mining Co. 

8/1/2008

2,900.240 288,082,000 $250,800,000.00 

North Maysdorf (WYW154432) 

Cordero Rojo Mine 

Cordero Mining Co. 

1/29/2009

445.890 54,657,000 $48,098,424.00 

TOTALS 49,183.640 5,781,563,776 $3,162,452,451.69 

Exchanges Completed

Exchange Name 

Case File Number 

Exchange Proponent 

Exchange Type 

Effective Date

Acres 

Exchanged

Mineable Tons of 

Coal

Federal Coal 

Exchanged for: 

EOG (Belco) I-90 Lease Exchange

WYW150152 

EOG Resources (formerly Belco)3 

I-90 Lease Exchanged for New Lease 

4/1/2000 

599.170 106,000,000 Lease Rights to Belco 

I-90 Lease 

(WYW0322794). 

Pittsburg & Midway Coal Exchange

WYW148816 

Pittsburg and Midway Coal Mining Co. 

Private Land Exchanged for Federal Coal 

1/27/2005 

2,045.530 84,200,000 6,065.77 acres of 

land and some 

minerals in Lincoln, 

Carbon, and Sheridan 

Counties, Wyoming. 

Gold Mine Draw Lease Exchange 

WYW0321779, WYW154001 

Powder River Coal Co., LLC 

AVF Lease Exchanged for New Lease 

6/25/2006

623.000 47,700,000 Lease rights to 

921.60 acres of 

leased federal coal 

underlying an AVF. 

TOTALS 3,267.700 237,900,000 

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.
1.0 Introduction 

1-8 Final EIS, Wright Area Coal Lease Applications 

Table 1-2. Pending LBAs, Powder River Basin, Wyoming. 

LBA Name 

Lease Number 

Applicant Mine 

Application 

Date 

Acres as 

Applied for 

Estimated as 

Applied for Coal 

(mmt) Status 

Belle Ayr North 

WYW161248 

Belle Ayr Mine

7/6/2004 1,578.74 191.90 3 FEIS available 8/14/2009 

ROD in preparation 

West Antelope II 

WYW163340 

Antelope Mine

4/6/2005 4,108.60 429.70 1 FEIS available 12/19/2008 

ROD available 4/1/2010 

North Hilight Field 

WYW164812 

Black Thunder Mine

10/7/2005 2,613.50 263.40 3 FEIS in preparation 

South Hilight Field 

WYW174596 

Black Thunder Mine

10/7/2005 1,976.69 213.60 3 FEIS in preparation 

West Hilight Field 

WYW172388 

Black Thunder Mine 

1/17/2006 2,370.52 377.90 3 FEIS in preparation 

West Coal Creek 

WYW172585 

Coal Creek Mine 

2/10/2006 1,151.26 57.00 3 FEIS available 8/14/2009 

ROD in preparation 

Caballo West 

WYW172657 

Caballo Mine 

3/15/2006 777.49 81.80 3 FEIS available 8/14/2009 

ROD in preparation 

West Jacobs Ranch 

WYW172685 

Jacobs Ranch Mine 

3/24/2006 5,944.37 669.60 3 FEIS in preparation 

Hay Creek II 

WYW172684 

Buckskin Mine 

3/24/2006 

Modified 

5/19/2008 

Modified 

1/23/2009 

415.00 51.90 2 DEIS available 3/12/2010 

Hearing 4/22/2010 

FEIS in preparation 

Maysdorf II

WYW173360 

Cordero Rojo Mine 

9/1/2006 4,653.84 474.50 3 FEIS available 8/14/2009 

ROD in preparation 

North Porcupine

WYW173408 

North Antelope Rochelle Mine 

9/29/2006 

Modified 

10/12/2007 

5,795.78 601.20 3 FEIS in preparation 

South Porcupine

WYW176095 

North Antelope Rochelle Mine 

9/29/2006 

Modified 

10/12/2007 

3,185.96 309.70 3 FEIS in preparation 

TOTALS 34,571.75 3,722.20 

1 Estimated tons of in-place coal as reported in the lease application. 2 Estimated tons of mineable coal as reported in the lease application. 3 Estimated tons of recoverable coal as reported by the applicant.
1.0 Introduction 

Final EIS, Wright Area Coal Lease Applications 1-9 

recoverable coal reserves. The BLM split this LBA into two separate tracts, the 

North and South Hilight Field Tracts, as shown in Figure 1-2, and the two 

tracts will be processed separately. The North Hilight Field LBA Tract as 

applied for includes approximately 2,613.50 acres and an estimated 263.4 

million tons of recoverable coal reserves. The South Hilight Field LBA Tract as 

applied for includes approximately 1,976.69 acres and an estimated 213.6 

million tons of recoverable coal reserves. 

As of January 1, 2009, TBCC estimates the in-place reserves at the existing 

Black Thunder Mine to be 1,271.1 million tons, of which approximately 1,169.4 

million tons of those remaining reserves would be recoverable. Black Thunder 

Mine’s currently approved by WDEQ/AQD air quality permits (Permit Numbers 

MD-417A, MD-877, MD-1178, MD-1555, MD-6824, and MD-3851, which were 

approved on July 1, 1999, June 23, 2003, July 12, 2005, May 13, 2007, 

January 22, 2008, and August 18, 2008, respectively) allow up to 135 million 

tons of coal per year to be mined. The Black Thunder Mine produced 

approximately 67.4 million tons of coal in 2008, 65.3 million tons of coal in 

2007, 67.3 million tons of coal in 2006, 62.7 million tons of coal in 2005, and 

66.8 million tons of coal in 2004. 

The North Hilight Field tract is contiguous with both the Black Thunder Mine 

and the Jacobs Ranch Mine federal coal leases. The South Hilight Field tract is 

contiguous with only the Black Thunder Mine federal coal leases. A portion of 

the North Hilight Field tract lies within Jacobs Ranch Mine’s current permit 

area. A portion of the South Hilight Field tract lies within Black Thunder 

Mine’s current permit area. None of the North Hilight Field tract lies within 

Black Thunder Mine’s current permit area, although it does border the mine’s 

permit boundary (Figure 1-2). The area applied for is similar to the adjacent 

mines for which detailed site-specific environmental data have been collected. 

Additionally, environmental analyses have previously been prepared for 

existing leases and mining permits. As previously stated, the Jacobs Ranch 

Mine was acquired by Arch Coal, Inc. on October 1, 2009, and ALC intends to 

consolidate the permits of the Jacobs Ranch Mine and the Black Thunder Mine 

in order to integrate the two separate mining operations. ALC proposes to mine 

the North and South Hilight Field LBA Tracts as applied for as maintenance 

tracts for the consolidated Black Thunder Mine. 

The surface of the North Hilight Field LBA Tract as applied for is owned by 

TBCC, ALC, Mills Brothers Partnership, and Western Railroad Properties, Inc. 

& Burlington Northern Railroad. The surface of the South Hilight Field LBA 

Tract as applied for is owned by TBCC, Western Railroad Properties, Inc. & 

Burlington Northern Railroad, and the United States of America. The federally 

owned surface comprises roughly 82 percent (approximately 1,625.9 acres) of 

the South Hilight Field tract as applied for and is part of the Thunder Basin 

National Grassland (TBNG), administered by the USFS. Current land uses of 

the tracts include grazing by domestic livestock and wildlife, oil and gas 

production, recreation, and transportation (i.e., rail lines and public road).
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T.

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T.

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R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

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T.

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T.

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T.

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Reno Road

Road Jacobs

State

Edwards

Matheson Road

Reno Road

Hilight Road Hilight Road

Keeline Road

Road

Highway 450

State

450 Highway

Road

BNSF & UP

RR

BNSF & UP RR

Antelope Road

NORTH HILIGHT FIELD

SOUTH HILIGHT FIELD

Shroyer

WEST HILIGHT FIELD

Small Road

0 5000 10000 20000

GRAPHIC SCALE (FEET)

LEGEND

North Hilight Field LBA Tract

as Applied for (WYW-164812)

Black Thunder Mine

Lease WYW-2313

Black Thunder Mine

Lease WYW-118907

Black Thunder Mine

Lease WYW-71692

Black Thunder Mine

Lease WYW-127221

Black Thunder Mine

Permit Boundary

Black Thunder Mine

Lease WYW-136458

Black Thunder Mine

Lease WYW-150318

West Hilight Field LBA Tract as

Applied for (WYW-172388)

Black Thunder Mine

Lease WYW-172692

South Hilight Field LBA Tract as

Applied for (WYW-174596)

Figure 1-2. Black Thunder Mine's Federal Coal Leases and North Hilight Field, South Hilight Field, and West

Hilight Field LBA Tracts as Applied for.

1.0 Introduction

1-10 Final EIS, Wright Area Coal Lease Applications
1.0 Introduction 

Final EIS, Wright Area Coal Lease Applications 1-11 

The mining methods would likely be a truck and shovel pre-benching operation 

in advance of a dragline, while cast blasting may be employed to supplement 

dragline productivity, which are the mining methods currently in use at the 

mine. The coal would be used primarily for electric power generation. 

After mining, the land would be reclaimed for livestock grazing and wildlife use 

as is the current practice at the Black Thunder Mine. Industrial postmining 

land uses, which include but are not limited to oil and gas wells, pipelines, 

roads, rail lines, and utility easements, also would be reestablished as 

required. 

1.1.2 West Hilight Field LBA Tract

The West Hilight Field LBA Tract as applied for and the existing federal coal 

leases in the adjacent Black Thunder Mine are shown in Figure 1-2. As applied 

for, the West Hilight Field LBA Tract consists of a single block of federal coal 

and includes approximately 2,370.52 acres and an estimated 377.9 million 

tons of recoverable coal reserves. 

As of January 1, 2009, TBCC estimates the in-place reserves at the existing 

Black Thunder Mine to be 1,271.1 million tons, of which approximately 1,169.4 

million tons of those remaining reserves would be recoverable. Black Thunder 

Mine’s currently approved by WDEQ/AQD air quality permits (Permit Numbers 

MD-417A, MD-877, MD-1178, MD-1555, MD-6824, and MD-3851, which were 

approved on July 1, 1999, June 23, 2003, July 12, 2005, May 13, 2007, 

January 22, 2008, and August 18, 2008, respectively) allow up to 135 million 

tons of coal per year to be mined. The Black Thunder Mine produced 

approximately 67.4 million tons of coal in 2008, 65.3 million tons of coal in 

2007, 67.3 million tons of coal in 2006, 62.7 million tons of coal in 2005, and 

66.8 million tons of coal in 2004. 

As discussed above, the West Hilight Field LBA Tract as applied for consists of 

a single block west of the Black Thunder Mine’s existing federal coal leases, 

and a portion of the tract lies within Black Thunder Mine’s current permit area 

(Figure 1-2). The area applied for is similar to the adjacent mines for which 

detailed site-specific environmental data have been collected. Additionally, 

environmental analyses have previously been prepared for existing leases and 

mining permits. As previously stated, the Jacobs Ranch Mine was acquired by 

Arch Coal, Inc. on October 1, 2009, and ALC intends to consolidate the permits 

of the Jacobs Ranch Mine and the Black Thunder Mine in order to integrate the 

two separate mining operations. ALC proposes to mine the West Hilight Field 

LBA Tracts as applied for as a maintenance tract for the consolidated Black 

Thunder Mine. 

The surface of the West Hilight Field LBA Tract as applied for is owned by 

TBCC, James R. & Irene Stuart Trusts, and the United States of America. The 

federally owned surface comprises roughly 29 percent (approximately 695.9 

acres) of the tract as applied for and is part of the TBNG, administered by the 
1.0 Introduction 

1-12 Final EIS, Wright Area Coal Lease Applications 

USFS. Current land uses of the tract include grazing by domestic livestock and 

wildlife, oil and gas production, recreation, and transportation (i.e., public 

road). 

The mining methods would likely be a truck and shovel pre-benching operation 

in advance of a dragline, while cast blasting may be employed to supplement 

dragline productivity, which are the mining methods currently in use at the 

mine. The coal would be used primarily for electric power generation. 

After mining, the land would be reclaimed for livestock grazing and wildlife use 

as is the current practice at the Black Thunder Mine. Industrial postmining 

land uses, which include but are not limited to oil and gas wells, pipelines, 

roads, and utility easements, also would be reestablished as required. 

1.1.3 West Jacobs Ranch LBA Tract

The West Jacobs Ranch LBA Tract as applied for and the existing federal coal 

leases in the adjacent Jacobs Ranch Mine are shown in Figure 1-3. The 

existing federal coal leases in the adjacent Black Thunder Mine are shown in 

Figure 1-2. As applied for, the West Jacobs Ranch LBA Tract consists of a 

single block of federal coal and includes approximately 5,944.37 acres and an 

estimated 669.6 million tons of recoverable coal reserves. 

As of January 1, 2009, ALC estimates the in-place reserves at the existing 

Jacobs Ranch Mine to be 403.6 million tons, of which approximately 379.4

million tons of those remaining reserves would be recoverable. The Jacobs 

Ranch Mine’s current WDEQ/AQD air quality permit (Permit Number MD1005A2, approved on January 22, 2007) allows up to 55 million tons of coal 

per year to be mined. The Jacobs Ranch Mine produced approximately 42.1 

million tons of coal in 2008, 38.1 million tons of coal in 2007, 40.0 million tons 

of coal in 2006, 37.3 million tons of coal in 2005, and 38.6 million tons of coal 

in 2004. 

As discussed above, the West Jacobs Ranch LBA Tract as applied for consists 

of a single block located approximately 0.75 mile west of Jacobs Ranch Mine’s 

current mining permit boundary and 1.0 mile west of the mine’s current federal 

coal leases (Figure 1-3). The West Jacobs Ranch tract is contiguous with only 

the Black Thunder Mine, and a portion of the tract is within Black Thunder 

Mine’s current permit area (Figure 1-2). The area applied for is similar to the 

adjacent mines for which detailed site-specific environmental data have been 

collected. Additionally, environmental analyses have previously been prepared 

for existing leases and mining permits. As previously stated, the Jacobs Ranch 

Mine was acquired by Arch Coal, Inc. on October 1, 2009, and ALC intends to 

consolidate the permits of the Jacobs Ranch Mine and the Black Thunder Mine 

in order to integrate the two separate mining operations. ALC proposes to mine 

the West Jacobs Ranch LBA Tract as applied for as maintenance tract for the 

consolidated Black Thunder Mine. 
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R. 71 W. R. 70 W. R.70W. R.69W.

T.

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

Keeline

Road Jacobs

State

Small BNSF & UP RR

Hilight Road Hilight Road

Road

Keeline Road

Road

Highway 450

State

450 Highway

BNSF & UP RR

Shroyer

Road

LEGEND

Jacobs Ranch Mine Lease WYW-23928

Jacobs Ranch Mine Lease WYW-117924

Jacobs Ranch Mine Lease WYW-87582

Jacobs Ranch Mine Lease WYW-146744

Jacobs Ranch Mine Permit Boundary

Jacobs Ranch Mine Lease WYW-148123

Jacobs Ranch Mine Lease WYW-149516

West Jacobs Ranch LBA Tract as Applied for (WYW-172685)

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Figure 1-3. Jacobs Ranch Mine's Federal Coal Leases and West Jacobs Ranch LBA Tract as Applied for.

1.0 Introduction

Final EIS, Wright Area Coal Lease Applications 1-13
1.0 Introduction 

1-14 Final EIS, Wright Area Coal Lease Applications 

The surface of the West Jacobs Ranch LBA Tract as applied for is owned by 

ALC, Boller-Mills Ranch LP, and William M. & Lois R. Chittenden. Current 

land uses of the tract include grazing by domestic livestock and wildlife, oil and 

gas production, recreation, and transportation (i.e., public roads and railroad). 

The mining methods would likely be a truck and shovel pre-benching operation 

in advance of a dragline, while cast blasting may be employed to supplement 

dragline productivity, which are the mining methods currently in use at the 

Black Thunder Mine. The coal would be used primarily for electric power 

generation.

After mining, the land would be reclaimed for livestock grazing and wildlife use 

as is the current practice at the Jacobs Ranch Mine. Industrial postmining 

land uses, which include but are not limited to oil and gas wells, pipelines, 

roads, and utility easements, also would be reestablished as required. 

1.1.4 North and South Porcupine LBA Tracts

As applied for, the Porcupine LBA Tract, adjacent to the North Antelope 

Rochelle Mine, consisted of two separate blocks of federal coal and included a 

total of approximately 8,981.74 acres with an estimated 910.9 million tons of 

recoverable coal reserves. The BLM split this LBA into two separate tracts, the 

North and South Porcupine Tracts, as shown in Figure 1-4, and will process 

the two tracts separately. The North Porcupine LBA Tract as applied for 

includes approximately 5,795.78 acres and an estimated 601.2 million tons of 

recoverable coal reserves. The South Porcupine LBA Tract as applied for 

includes approximately 3,185.96 acres and an estimated 309.7 million tons of 

recoverable coal reserves. 

As of January 1, 2009, PRC estimates the in-place reserves at the existing 

North Antelope Rochelle Mine to be 1,049.9 million tons, of which 

approximately 933.8 million tons of those remaining reserves would be 

recoverable. North Antelope Rochelle Mine’s current WDEQ/AQD air quality 

permits (MD-1172, MD-1309, MD-1331, and MD-6375 approved in June 2005, 

January 2006, March 2006, and November 2008, respectively) allow up to 140 

million tons of coal per year to be mined. The North Antelope Rochelle Mine 

produced approximately 97.6 million tons of coal in 2008, 91.5 million tons of 

coal in 2007, 88.5 million tons of coal in 2006, 82.7 million tons of coal in 

2005, and 82.5 million tons of coal in 2004. 

The North Porcupine tract is contiguous with the North Antelope Rochelle 

Mine’s existing federal coal leases; the South Porcupine tract is contiguous 

with both the North Antelope Rochelle Mine’s and the Antelope Mine’s existing 

federal coal leases. Both tracts lie completely within the North Antelope 

Rochelle Mine’s current permit area (Figure 1-4). The area applied for is 

similar to the adjacent mines for which detailed site-specific environmental 
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R. 71 W. R. 70 W. R. 70 W. R. 69 W.

Converse County

Campbell County

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

T.

41

N.

T.

40

N.

Matheson

Reno Road

Mackey

Edwards Reno Road School Creek

Hilight Road

Road

Road

Antelope Road

Road

Road

BNSF & UP RR

Antelope Road

SOUTH PORCUPINE

NORTH PORCUPINE

T.

42

N.

T.

41

N.

Mackey Road

0 5000 10000 20000

GRAPHIC SCALE (FEET)

LEGEND

North Antelope Rochelle

Mine Lease WYW-150210

North Antelope Rochelle

Mine Permit Boundary

North Porcupine LBA Tract

as Applied for (WYW-173408)

North Antelope Rochelle

Mine Lease WYW-0321779

North Antelope Rochelle

Mine Lease WYW-60231

North Antelope Rochelle

Mine Lease WYW-125794

North Antelope Rochelle

Mine Lease WYW-151896

North Antelope Rochelle

Mine Lease WYW-119554

North Antelope Rochelle

Mine Lease WYW-154001

North Antelope Rochelle

Mine Lease WYW-136142

North Antelope Rochelle

Mine Lease WYW-87364

North Antelope Rochelle

Mine Lease WYW-155534

South Porcupine LBA Tract

as Applied for (WYW-176095)

Figure 1-4. North Antelope Rochelle Mine's Federal Coal Leases and North Porcupine and South Porcupine

LBA Tracts as Applied for.

1.0 Introduction

Final EIS, Wright Area Coal Lease Applications 1-15
1.0 Introduction 

1-16 Final EIS, Wright Area Coal Lease Applications 

data have been collected. Additionally, environmental analyses have previously 

been prepared for existing leases and mining permits. 

The surface of the North Porcupine LBA Tract as applied for is owned by PRC, 

LLC., Jerry N. & Rhonda Wilkinson, the state of Wyoming, Western Railroad 

Properties, Inc., and the United States of America. The federally owned surface 

comprises roughly 72 percent (approximately 4,186.0 acres) of the tract as 

applied for and is part of the TBNG, administered by the USFS. The surface of 

the South Porcupine LBA Tract as applied for is owned by PRC, LLC., Jerry J. 

Dilts Living Trust, Jerry J. Dilts Family LP 1, Bridle Bit Ranch Company, Jerry 

J. Dilts Family LP II and Bridle Bit Ranch Company, and the United States of 

America. The federally owned surface comprises roughly 51 percent 

(approximately 1,637.2 acres) of the tract as applied for and is part of the 

TBNG, administered by the USFS. Current land uses of the tracts include 

grazing by domestic livestock and wildlife, oil and gas production, recreation, 

and transportation (i.e., rail lines and public roads). 

The mining methods would be a truck and shovel pre-benching operation in 

advance of a dragline, while cast blasting may be employed to supplement 

dragline productivity, which are the methods currently in use at the North 

Antelope Rochelle Mine. The coal would be used primarily for electric power 

generation. 

After mining, the land would be reclaimed for livestock grazing and wildlife use 

as is the current practice at the North Antelope Rochelle Mine. Industrial 

postmining land uses, which include but are not limited to oil and gas wells, 

pipelines, roads, rail lines, and utility easements, also would be reestablished 

as required. 

1.2 Purpose and Need for Action 

Approximately 92 percent of the total coal that is mined in the U.S. is used for 

generating reasonably priced electricity (USDOE 2009a). Coal is mined in 25 

states (USDOE 2009a); the low cost and abundance of coal resources within 

the country is one of the primary reasons why consumers in the U.S. currently 

benefit from some of the lowest electricity rates of any free-market economy 

(USDOE 2009b). 

Electricity is important to the country’s security and economy and is 

structured on a market-based supply and demand system. Currently, coalfired electric generating plants are the cornerstone of the nation’s central power 

configuration (USDOE 2009b). Approximately half of the electricity currently 

generated in the United States comes from coal (USDOE 2009b). Wyoming coal 

is used to generate electricity in 36 other states (WMA 2009). 

The Federal Land Policy and Management Act of 1976 (FLPMA) mandated BLM 

to manage public lands for multiple use so that the lands are utilized in the 

combination that will best meet the present and future needs of the American 
1.0 Introduction 

Final EIS, Wright Area Coal Lease Applications 1-17 

people. FLPMA authorized BLM to manage the use, occupancy, and 

development of public lands through leases and permits (BLM 2007). 

The Energy Policy Act of 2005 directs federal agencies to undertake efforts to 

ensure energy efficiency and the production of secure, affordable, and reliable 

domestic energy. 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 in order to meet the nation’s energy needs. As a result, 

private development of federal coal reserves is integral to the BLM coal leasing 

program under the authority of the Mineral Leasing Act of 1920 (MLA), as well 

as FLPMA and Federal Coal Leasing Act Amendments of 1976 (FCLAA). 

The United States has the world’s largest known coal reserves (BP 2009). The 

BLM’s coal leasing program encourages the development of domestic coal 

reserves and the reduction of U.S. dependence on foreign sources of energy. As 

a result of the leasing, mining, and sale of federal coal resources in the PRB, 

the public has a reliable supply of low sulfur coal for generating affordable 

electric power. The public also receives extensive revenue from lease bonuses, 

rentals, and royalty payments. 

As this EIS describes, the Black Thunder Mine, Jacobs Ranch Mine, and North 

Antelope Rochelle Mine have applied for a total of six maintenance tracts of 

federal coal reserves. The mines applied for these reserves in order to continue 

to supply and sell low sulfur compliance coal to power plants for the purpose of 

generating electric power for the public. 

This EIS is being prepared in response to the four coal lease applications that 

BLM received from the three mines mentioned above. In response to each of 

the applications, BLM must decide whether to: 1) hold a competitive, sealed-bid 

lease sale for the tract as applied for, 2) hold a competitive, sealed-bid lease 

sale for a modified tract, or 3) reject the current lease application and not offer 

the tract for sale at this time. 

If a decision is made to lease a tract of federal coal and if the tract is sold and a 

lease is issued, the federal coal lease would grant the lessee the exclusive right 

to apply for a WDEQ mining permit. The WDEQ approved mining permit is 

what allows coal mining to take place on a lease. It authorizes surface 

disturbance and mining operations subject to the terms of the lease, the 

mining permit, and applicable state and federal laws. Before mining operations 

can be conducted on a new lease, the lessee must obtain approval of a detailed 

mining permit. Additionally, for federal coal lessees, the lessee may not 

conduct surface coal mining operations on federal coal land prior to obtaining 

approval of the MLA mining plan, through OSM and by the Assistant Secretary 

of the Interior, Land and Minerals Management. 

If an LBA tract is leased to the applicant as a maintenance tract, the permit to 

conduct mining operations for the adjacent mine would have to be amended to 
1.0 Introduction 

1-18 Final EIS, Wright Area Coal Lease Applications 

include the new lease area before it could be disturbed. This process takes 

several years to complete. ALC and BTU are applying for federal coal reserves 

now so that they can secure coal resources to market, enter into new contracts, 

and complete the permitting processes in time to mine the new federal reserves 

in a logical progression. 

If a tract is leased, a WDEQ mining permit is obtained and Assistant 

Secretarial approval through OSM is obtained. The coal would then be mined 

and sold to power plants for the purpose of generating electricity for the United 

States. Continued leasing of low sulfur PRB coal would assist coal-fired power 

plants in meeting the Clean Air Act (CAA) requirements without constructing 

new plants or revamping existing ones. This helps to provide a stable supply of 

power to meet increasing electrical demands without a potentially significant 

increase in power costs for the public. 

This EIS analyzes the environmental impacts of issuing federal coal leases and 

mining the federal coal in the North Hilight Field, South Hilight Field, West 

Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

maintenance coal lease applications as required by NEPA and associated rules 

and guidelines. A decision to hold a competitive sale and issue a lease for the 

lands in any of these applications is a prerequisite for mining but it is not the 

enabling action that would authorize mining. 

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 Land Quality Division (LQD) of the WDEQ 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 four Wright Area coal lease applications analyzed in this EIS were 

submitted to BLM 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 development of federal coal reserves is integral to the BLM coal leasing 

program under the authority of the Mineral Leasing Act of 1920 (MLA), as well 

as the Federal Land Policy Management Act of 1976 (FLPMA) and the Federal 

Coal Leasing Act Amendments of 1976 (FCLAA). BLM is the lead agency 
1.0 Introduction 

Final EIS, Wright Area Coal Lease Applications 1-19 

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, 

the Surface Mining Control and Reclamation Act of 1977 (SMCRA) gives OSM 

primary responsibility to administer programs that regulate surface coal 

mining operations and the surface effects of underground coal mining 

operations. USFS is also a cooperating agency on this EIS. If any USFSadministered lands are included in a tract that is proposed for leasing, USFS 

must consent to leasing the federal coal before BLM can make a decision to 

hold a federal coal lease sale. 

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, USFS 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 federal laws and their attendant regulations. If the 

permit application package complies, 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 
1.0 Introduction 

1-20 Final EIS, Wright Area Coal Lease Applications 

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, and 

USFS for USFS-administered lands, have authority in emergency situations if 

WDEQ or OSM cannot act before environmental harm and damage occurs. 

Appendix A presents other federal and state permitting requirements that must 

be satisfied to mine these LBA tracts. 

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 ALC and BTU applications, 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 2008a) has been followed in 

developing this EIS. 

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 1985), governs and addresses the leasing of federal coal in Campbell 

County. The Land and Resource Management Plan for the Thunder Basin 

National Grassland, Medicine Bow-Routt National Forest, Rocky Mountain Region

(USFS 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; 
1.0 Introduction 

Final EIS, Wright Area Coal Lease Applications 1-21 

• 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 Wyoming 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 was 

adopted in the 2001 BLM Buffalo Field Office Resource Management Plan 

(RMP) update (BLM 2001a). The results of this analysis were included as 

Appendix D of the 2001 RMP update, which can be viewed in the 2001 NEPA 

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 USFS, Douglas Ranger District for lands within the 

TBNG. 

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 

lands in these four coal lease applications are within the area identified as 

having coal development potential by the BLM and the USFS in the coal 

screening analyses published in the 2001 BLM and USFS planning documents. 

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 

through moderate coal development potential lands in the Wyoming PRB, 

including the six LBA tracts and surrounding lands in these four coal lease 

applications, 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 North Hilight 

Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, North 

Porcupine, and South Porcupine LBA Tracts. 

Unsuitability Criterion Number 2 addresses lands within rights-of-way (ROWs) 

on federal lands. Under this criterion, portions of the Burlington Northern 

Santa Fe & Union Pacific (BNSF & UP) railroad ROW shall be considered 

unsuitable for surface coal mining. As shown in Figures 1-2 and 1-4, the 

BNSF & UP railroad borders the west sides of the North and South Hilight Field 

LBA Tracts as applied for, crosses the North Porcupine LBA Tract as applied 

for, and lies west of and adjacent to the South Porcupine LBA Tract as applied 

for. 
1.0 Introduction 

1-22 Final EIS, Wright Area Coal Lease Applications 

Unsuitability Criterion Number 3 addresses lands used for public roads and 

other public purposes. Wyoming State Highway 450 east of the BNSF & UP 

railroad shall be considered unsuitable for surface coal mining. The 2001 BLM 

Buffalo RMP update deferred a decision on the unsuitability of the public road 

ROWs and associated buffer zones (with the exclusion of Wyoming State 

Highway 450 east of the BNSF & UP railroad and Interstate Highway I-90 

ROWs) until a leasing action occurred. 

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 North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs 

Ranch, North Porcupine, and South Porcupine LBA Tracts do not lie within or 

in proximity to an identified buffer zone surrounding an existing community. 

Therefore, no federal coal lands within these six LBA tracts 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 

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 RMP 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-bycase basis. 

Both conventional oil and gas and coal bed natural gas (CBNG) wells have been 

drilled within or around the North Hilight Field, South Hilight Field, West 

Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA 

Tracts. BLM’s evaluation of the potential for conflict with the development of 

oil and gas resources within the six LBA tracts is included in the Mineral 

Resources discussion in Section 3.3 and in the Land Use discussion in Section 

3.11 of this EIS. BLM’s policy and guidance on conflicts between surface coal 

mine and conventional oil and gas and CBNG development is to optimize the 

recovery of both resources and ensure that the public receives a reasonable 
1.0 Introduction 

Final EIS, Wright Area Coal Lease Applications 1-23 

return, as explained in BLM Instruction Memorandum No. 2006-153 (BLM 

2006a). 

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 the 2001 Buffalo RMP update. 

Private surface owners in the Gillette coal development potential area 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 update 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 North Hilight 

Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, North 

Porcupine, and South Porcupine LBA Tracts have been eliminated from further 

consideration for leasing due to qualified surface owner conflicts at this time. 

The current surface ownership of the LBA tracts is discussed in Section 1.1 of 

this chapter and in Section 3.11. Private surface owners who are found to be 

qualified must consent to leasing before BLM can offer the underlying federal 

coal for lease. BLM will review the current surface ownership in the tracts that 

will be considered for leasing prior to holding a lease sale for each tract. Prior 

to holding a lease sale, surface owner consultation must be completed with any 

private surface owners who are determined to be qualified. 

In summary, the lands in the ALC and BTU coal lease applications have been 

subjected to the four coal planning screens. The results are detailed in 

Appendix B and detailed in the description of the Proposed Action and 

alternatives for each LBA tract contained in Chapter 2 of this EIS. Thus, a 

decision to lease the federal coal lands in these applications, conditioned 

consistent with RMP decisions, would be in conformance with the current BLM 

Buffalo RMP and the TBNG RMP. 

1.6 Consultation and Coordination 

Initial Involvement

BLM received the Hilight Field coal lease application on October 7, 2005, the 

West Hilight Field coal lease application on January 17, 2006, the West Jacobs 

Ranch coal lease application on March 24, 2006, and the Porcupine coal lease 

application on September 29, 2006. The applications were initially reviewed by 

the BLM Wyoming State Office-Division of Minerals and Lands. BLM ruled that 

these four applications and the 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 on April 

27, 2006, that ALC had filed a lease application with BLM for the North Hilight 
1.0 Introduction 

1-24 Final EIS, Wright Area Coal Lease Applications 

Field and South Hilight Field LBA Tracts. The BLM Wyoming State Director 

notified the Governor of Wyoming on February 2, 2006, that ALC had filed a 

lease application with BLM for the West Hilight Field LBA Tract. The BLM 

Wyoming State Director notified the Governor of Wyoming on September 18, 

2006, that JRCC had filed a lease application with BLM for the West Jacobs 

Ranch LBA Tract. The BLM Wyoming State Director notified the Governor of 

Wyoming on March 14, 2007, that BTU had filed a lease application with BLM 

for the North Porcupine and South Porcupine LBA Tracts. 

The PRRCT reviewed the Hilight Field, West Hilight Field, and West Jacobs 

Ranch maintenance coal lease applications at a public meeting held on April 

19, 2006 in Casper, Wyoming. The PRRCT reviewed the Porcupine 

maintenance coal lease application at a public meeting held on January 18, 

2007 in Casper, Wyoming. Each of the applicants presented information about 

their existing mine and pending lease application to the PRRCT at those 

meetings. The PRRCT recommended that the BLM continue to process all four 

lease applications at those respective meetings. The major steps in processing 

an LBA are shown in Appendix C. 

BLM published a Notice of Intent (NOI) to prepare an EIS and Notice of Public 

Meeting in the Federal Register on July 3, 2007, in the Gillette News-Record on 

July 6, 2007, and in the Douglas Budget on July 11, 2007. The publications 

served as public notice that the Hilight Field, West Hilight Field, West Jacobs 

Ranch, and Porcupine coal lease applications had been received, announced 

the time and location of a public scoping meeting, and requested public 

comment on the four applications. Letters requesting public comment and 

announcing the time and location of the public scoping meeting were mailed to 

all parties on the distribution list on July 11, 2007. 

A public scoping meeting was held July 24, 2007 in Gillette, Wyoming. At the 

public meeting, the applicants orally presented information about their mines 

and their need for the coal. The presentations were followed with a question 

and answer period, during which three oral comments were made. The scoping 

period extended from July 3 through September 3, 2007, during which time 

BLM received nine comment letters. 

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 that have been identified through scoping and other recently expressed 

concerns related to the potential impacts of leasing the Wright Area 

maintenance tracts and other federal coal in the Wyoming PRB include: 

• potential conflicts between coal mining and existing and proposed 

conventional oil and gas and CBNG development; 
1.0 Introduction 

Final EIS, Wright Area Coal Lease Applications 1-25 

• potential cumulative impacts of coal leasing decisions combined with 

other existing and proposed development in the Wyoming PRB; 

• potential impacts to Highway 450 and other transportation routes; 

• potential impacts to people living in the area; 

• socioeconomic concerns; 

• potential impacts to ranching operations associated with the loss of 

grazing leases and permits; 

• noxious weed concerns; 

• potential impacts to visual resources; 

• potential impacts to cultural and paleontological resources; 

• potential impacts to Greater sage-grouse and other wildlife; 

• potential impacts to threatened and endangered species and other 

species of concern; 

• potential impacts to wetland resources; 

• potential impacts related to coal loss during rail transport; 

• potential air quality impacts and cumulative impacts to visibility; 

• potential surface and groundwater quality and quantity impacts; 

• potential impacts associated with nitrogen oxide emissions resulting from 

the blasting of coal and overburden; 

• human health impacts; 

• the need to address reasonably foreseeable actions, including the 

construction and operation of the DM&E railroad and power plants, in 

the cumulative analysis; 

• the need to address mercury, coal combustion residues, and other byproducts from coal-fired power plants; 

• the need to address increasing PRB coal production in the cumulative 

analysis; 

• the need to address site-specific greenhouse gas emissions; 

• ozone; and 

• climate change. 

Draft EIS

Parties on the distribution list were sent copies of the Draft EIS, and copies 

were made available for review at the BLM offices in Casper and Cheyenne, 

Wyoming. The document was also available for review on the BLM Wyoming 

website at: http://www.blm.gov/wy/st/en/info/NEPA/HighPlains/WrightCoal.html. 

The U.S. Environmental Protection Agency (EPA) published a notice 

announcing the availability of the Draft EIS in the Federal Register on June 26, 

2009. A 60-day comment period on the Draft EIS commenced with publication 

of the EPA’s Notice of Availability (NOA) and ended on August 25, 2009. BLM 

published a NOA/Notice of Public Hearing for the Draft EIS in the Federal 

Register on July 8, 2009. The BLM’s Federal Register notice announced the 

date and time of a public hearing, which was held during the 60-day comment 

period on July 29, 2009 at 7:00 p.m. at the Clarion Inn in Gillette, Wyoming. 

The purpose of the public hearing was to solicit public comments on the Draft 
1.0 Introduction 

1-26 Final EIS, Wright Area Coal Lease Applications 

EIS and on the fair market value, the maximum economic recovery, and the 

proposed competitive sale of federal coal from the LBA tracts. BLM also 

published a notice of public hearing in both the Douglas Budget and Gillette 

News-Record newspapers on July 8, 2009. Two individuals representing 

organizations presented statements on the Draft EIS during the hearing. A 

summary of the statements that were presented at the public hearing are 

included in Appendix I of this Final EIS. An official transcript of the public 

hearing is available for review at the BLM High Plains District Office in Casper. 

Final EIS and Future Involvement

BLM received written comments from 17 individuals, agencies, businesses, and 

organizations, as well as over 500 e-mails from interested individuals and 

entities regarding the Draft EIS. These comments are included, with agency 

responses, in Appendix I of this Final EIS. Availability of the Final EIS will be 

published in the Federal Register by BLM and EPA. After a 30-day availability 

period commencing from the date of the EPA’s notice, BLM will make separate 

decisions to hold or not to hold a competitive lease sale for the federal coal in 

the North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs 

Ranch, North Porcupine, and South Porcupine LBA Tracts. 

The USFS must consent to leasing the federal coal underlying lands that they 

administer before BLM can include those lands in a decision to hold a federal 

coal lease sale. If any lands administered by the USFS are included in the tract 

that BLM considers for leasing, the USFS will issue a separate record of 

decision (ROD) consenting to leasing those lands. The decision to consent to 

leasing the USFS land can be appealed within 45 days from the date that the 

Notice of Publication of the USFS ROD is published in the Laramie Boomerang 

newspaper. 

A public ROD for each of the tracts 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 any of the six tracts. The BLM decision 

must be appealed within 30 days from the date the NOA for the ROD is 

published in the Federal Register. The decision can be implemented at that 

time if no appeal is received. If competitive lease sales are held, the lease sales 

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 each competitive coal lease sale, but prior to issuance of the lease, 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. 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-1 

2.0 PROPOSED ACTION AND ALTERNATIVES 

This chapter describes the Proposed Action and alternatives to this action for 

each of the six Lease by Application (LBA1) tracts being evaluated in this EIS. 

The six LBA tracts are the North Hilight Field, South Hilight Field, West Hilight 

Field, and West Jacobs Ranch LBA Tracts as applied for by Ark Land Company 

(ALC), and the North Porcupine and South Porcupine LBA Tracts as applied for 

by BTU Western Resources, Inc. (BTU). 

For each tract, the Proposed Action is to hold a separate competitive lease sale 

and issue a separate lease for the federal coal lands included in the tract as 

applied for by the applicant. Under each Proposed Action, the tract as applied 

for would be offered for lease at one competitive sealed bid lease sale, subject to 

standard and special lease stipulations developed for the Powder River Basin 

(PRB) and that tract. The boundaries of each tract would be consistent with 

the tract configuration proposed by each applicant. Figures 2-1 through 2-6 

show the North Hilight Field, South Hilight Field, West Hilight Field, West 

Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts, respectively, 

under each Proposed Action. In each case, the Proposed Action assumes that 

the applicant would be the successful bidder on each tract, and that the tract 

would be mined as a maintenance lease for an existing mine. 

The National Environmental Policy Act of 1969 (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. 

The No Action Alternative (Alternative 1) for each tract considered in this 

Environmental Impact Statement (EIS) is to reject the lease application. Under 

the No Action Alternative, a tract would not be offered for competitive sale, and 

the coal contained within the tract would not be mined as proposed. Rejection 

of an application would not affect currently permitted mining activities on 

existing leases at any of the applicant mines, and selection of the No Action 

Alternative would not preclude an application to lease any rejected tract in the 

future. Portions of the surface of each LBA tract would probably be disturbed 

due to overstripping to allow coal to be removed from the adjacent existing 

leases. 

The Bureau of Land Management (BLM) Competitive Coal Leasing Manual 

(BLM Manual 3420-1) requires BLM to evaluate modifying the configuration of 

 

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

North Hilight Field LBA Tract as Applied for

Existing Black Thunder Mine Federal Coal Leases

Black Thunder Mine Permit Boundary

Additional Area Evaluated Under Alternative 2,

BLM's Preferred Alternative

Existing Jacobs Ranch Mine Federal Coal Leases

Jacobs Ranch Mine Permit Boundary

BLM's Study Area for the

North Hilight Field LBA Tract

Figure 2-1. North Hilight Field LBA Tract Alternatives.

2.0 Proposed Action and Alternatives

2-2 Final EIS, Wright Area Coal Lease Applications
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Additional Area Evaluated Under Alternative 2,

BLM's Preferred Alternative

Existing Jacobs Ranch Mine Federal Coal Leases

Jacobs Ranch Mine Permit Boundary

BLM's Study Area for the

South Hilight Field LBA Tract

Figure 2-2. South Hilight Field LBA Tract Alternatives.

2.0 Proposed Action and Alternatives

Final EIS, Wright Area Coal Lease Applications 2-3
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T.

43

N.

T.

42

N.

State

Edwards

Small

Matheson Road

Hilight Road

Road

Highway 450

Road

BNSF & UP RR

Shroyer Road

HilightRoad

R. 71 W.

Black Thunder Mine's

Northwest Rail Loop

Amendment Area

T.

44

N.

T.

43

N.

T.

44

N.

T.

43

N.

0 3000 6000 12000

GRAPHIC SCALE (FEET)

LEGEND

Existing Black Thunder Mine

Federal Coal Leases

Black Thunder Mine

Permit Boundary

West Hilight Field LBA

Tract as Applied for

Additional Area Evaluated

Under Alternative 2,

BLM's Preferred Alternative

Additional Area Evaluated

Under Alternative 3

BLM's Study Area for the

West Hilight Field LBA Tract

Figure 2-3. West Hilight Field LBA Tract Alternatives.

2.0 Proposed Action and Alternatives

2-4 Final EIS, Wright Area Coal Lease Applications
31

30

19

18

7

31

30

19

18

7

32

29

20

17

8

33

28

21

16

9

34

27

22

15

10

35

26

23

14

11

36

25

24

13

12

18

7

6

17

8

5

16

9

4

15

10

3

14

11

2

13

12

1

18

7

6

36

25

24

13

12

13

12

1

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

Small

BNSF & UP RR

Hilight Road Hilight Road

Road

Road

State

450 Highway

BNSF & UP RR

State Highway 450

Shroyer

R. 72 W. R. 71 W.

R. 72 W. R. 71 W.

LEGEND

Existing Jacobs Ranch Mine Federal Coal Leases

Jacobs Ranch Mine Permit Boundary

West Jacobs Ranch LBA Tract as Applied for

0 3000 6000 12000

GRAPHIC SCALE (FEET)

Additional Area Evaluated Under Alternative 2,

BLM's Preferred Alternative

ALC's Northwest Rail Loop Amendment Area

Black Thunder Mine Permit Boundary

Existing Black Thunder Mine Federal Coal Leases

BLM's Study Area for the

West Jacobs Ranch LBA Tract

Figure 2-4. West Jacobs Ranch LBA Tract Alternatives.

2.0 Proposed Action and Alternatives

Final EIS, Wright Area Coal Lease Applications 2-5
21

2833

16 15

22

2734

26

35

1423

13

2425

36

18

19

30

31

17

20

29

32

16

21

2833

2734

22

15

35

26

14

23

13242536

6 5 4 3 2 1 4 3 2 1

T.

42

N.

T.

41

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

42

N.

T.

41

N.

Reno Road

Mackey

Antelope Road

Road

BNSF & UP RR

Matheson Road

Mackey Road

Matheson Road

BNSF & UP RR

Antelope Road

3000 12000 0

GRAPHIC SCALE (FEET)

LEGEND

6000

North Antelope Rochelle Mine Permit BoundaryExisting North Antelope Rochelle Mine Federal Coal LeasesNorth Porcupine LBA Tract as Applied for

Additional Area Evaluated Under Alternative 2,

BLM's Preferred AlternativeBLM's Study Area for theNorth Porcupine LBA Tract

Figure 2-5. North Porcupine LBA Tract Alternatives.

2.0 Proposed Action and Alternatives

2-6 Final EIS, Wright Area Coal Lease Applications
33

28

34

27

35

26

36

25

31

30

32

29

33

28

34

27

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

T.

42

N.

T.

41

N.

R. 71 W. R. 70 W.

Converse County

Campbell County

R. 71 W. R. 70 W.

T.

42

N.

T.

41

N.

Antelope

Matheson Road

BNSF & UP RR

Road

Antelope Road

Matheson Road

0 3000 6000 12000

GRAPHIC SCALE (FEET)

LEGEND

Existing North Antelope Rochelle Mine Federal Coal Leases

North Antelope Rochelle Mine Permit Boundary

South Porcupine LBA Tract as Applied for

Additional Area Evaluated Under Alternative 2,

BLM's Preferred Alternative

BLM's Study Area for the

South Porcupine LBA Tract

Figure 2-6. South Porcupine LBA Tract Alternatives.

2.0 Proposed Action and Alternatives

Final EIS, Wright Area Coal Lease Applications 2-7
2.0 Proposed Action and Alternatives 

2-8 Final EIS, Wright Area Coal Lease Applications

federal coal tracts based on 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 

identifies alternate tract configurations and evaluates them as alternatives to 

the Proposed Action. BLM has identified a study area for each LBA tract that 

includes each tract as applied for and adjacent unleased federal coal. Figures 

2-1 through 2-6 show these study areas for the North Hilight Field, South 

Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and 

South Porcupine LBA Tracts, respectively. BLM is evaluating these study areas 

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. 

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 alternate tract configurations, BLM could either 

increase or decrease the size of each tract as applied for. 

The potential tract configurations, and therefore the potential number of 

alternatives evaluated for NEPA purposes, can vary for each tract. In this EIS, 

one alternative, Alternative 2, is evaluated in addition to the Proposed Action 

and Alternative 1 (the No Action Alternative) for all of the tracts considered in 

this EIS. Under Alternative 2 for each tract, BLM is evaluating adding all or 

part of the BLM study area to the tract as applied for and/or reducing the size 

of the tract as applied for. For only the West Hilight Field LBA Tract, another 

alternative, Alternative 3, is evaluated in detail in this EIS in addition to the 

Proposed Action, Alternative 1, and Alternative 2. Under Alternative 3 for the 

West Hilight Field tract, BLM is evaluating adding all or part of the BLM study 

area and all or part of Thunder Basin Coal Company’s (TBCC’s) permitted 

Northwest Rail Loop Amendment Area (Figure 2-3). One competitive sealed bid 

sale would be held for each tract as configured by BLM. 

Two alternatives were considered but not analyzed in detail. They are: 

• holding a competitive lease sale and issuing a lease for federal coal lands 

included in one or more of the LBA tracts (as applied for or as modified 

by BLM), with the assumption that one or more of the tracts would be 

developed as a new mine (see Section 2.7.1), and 

• delaying the sale of one or more of the LBA tracts as applied for in order 

to take advantage of higher coal prices and/or to allow recovery of the 

potential coal bed natural gas (CBNG) resources in the tract prior to 

mining. Under this alternative, it is assumed that one or more of the 

tracts could be developed later as a maintenance tract or a new mine 

start, depending on how long the sale was delayed (see Section 2.7.2). 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-9 

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. For each tract, the Proposed Action and Alternative 2 or 

Alternative 3 considered in this EIS assume that the applicant that applied for 

the tract would be the successful bidder if the federal coal included in the tract 

is offered for lease, and that each tract would be mined as a maintenance tract 

for an existing permitted 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 Chapter 1, 

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 for each tract could potentially differ from the more general mining 

plan used in this EIS to analyze the impacts of the Proposed Action and 

Alternative 2 or Alternative 3 for each tract, 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 each 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, etc., would not be 

substantially different from the plans used in this analysis. 

If any of the tracts are leased under the Proposed Action or Alternative 2 or 3 

for each tract, it is assumed that an area larger than the tract would have to be 

disturbed in order to recover all of the coal in the 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. This is referred to as the “general analysis area” 

for that tract. The Proposed Action and Alternative 2 or Alternative 3 for each 

LBA tract will be referred to collectively as the Action Alternatives. 

For the Action Alternatives, future coal production rates are difficult to predict 

since mines must vary rates in response to the demand and competition for 

coal sales. BLM estimated future production rates for the purpose of 

estimating cumulative impacts. This was done as part of the Powder River 

Basin Coal Review - Task 2 Report - Past and Present and Reasonably 

Foreseeable Development Activities (BLM 2005a). The production estimates 

were based on forecasted coal demand for Wyoming PRB coal through the year 

2020, and production rates were allocated to the three mine groups in the 

basin (Wright Area, South Gillette Area, and North Gillette Area) as constrained 

by production capacity. The Wright Area mines include the Antelope Mine as 

well as the three mines with the six LBA tracts addressed in this EIS (Figure 1-

1). For this mine group, production was forecasted to reach somewhere 

between 291 million tons (lower range) to 307 million tons (upper range) per 

year by 2020. Mining company estimates from this EIS, as well as the West 

Antelope II EIS (BLM 2008d), total 306 million tons per year (mmtpy) by 2020. 
2.0 Proposed Action and Alternatives 

2-10 Final EIS, Wright Area Coal Lease Applications

The sum of the company projections is near the upper range of the forecasted 

Wright Area production rate. In addition, a fifth mine has been proposed in the 

Wright Area mine group. The proposed School Creek Mine has not been 

permitted at this time; however, if School Creek Mine opens, it will compete for 

a portion of the coal expected to be produced from this mine group, in response 

to demand and competition with other mines. 

2.1 North Hilight Field LBA Tract 

2.1.1 North Hilight Field LBA Tract Proposed Action

Ark Land Company (ALC) has filed an application for two separate LBA tracts 

(North Hilight Field and South Hilight Field). Each tract will be evaluated 

separately and if a decision is made to lease both of these tracts, a separate 

competitive lease sale will be held for each tract. 

Under the Proposed Action for the North Hilight Field LBA Tract, the tract as 

applied for by ALC 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 North Hilight Field lease application (Figure 2-1). 

The Proposed Action assumes that ALC would be the successful bidder on the 

North Hilight Field LBA Tract, if it is offered for sale. 

The legal description of the proposed North Hilight Field LBA Tract coal lease 

lands as applied for by ALC under the Proposed Action is as follows: 

T.44N., R.70W., 6th PM, Campbell County, Wyoming

Section 19: Lots 5 through 20; 656.88 acres 

T.44N., R.71W., 6th PM, Campbell County, Wyoming

Section 23: Lots 1 through 16; 653.11 acres 

Section 24: Lots 1 through 16; 653.44 acres 

Section 26: Lots 1 through 16; 650.07 acres 

Total: 2,613.50 acres

Land descriptions and acreage are based on the BLM Status of Public Domain 

Land and Mineral Titles approved Master Title Plats as of August 30, 2005 and 

September 7, 2007 and Coal Plats as of September 7, 2007. 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. 

Some of the coal in the above-described lands in the North Hilight Field LBA 

Tract is not currently considered by TBCC, operator of the Black Thunder 

Mine, to be mineable due to the presence of the Burlington Northern Santa Fe 

& Union Pacific (BNSF & UP) rail line, which borders the western side of the 

tract (Figure 2-1). The coal underlying the BNSF & UP railroad right-of-way 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-11 

(ROW) and an associated 100-foot buffer zone is not considered by TBCC to be 

mineable at this time because the cost that would be associated with moving 

the railroad tracks would make it economically unfeasible to recover the 

underlying coal. Although the federal coal underlying the railroad ROW and 

associated buffer zone would not be mined, it is included in the tract because it 

would allow maximum recovery of the mineable coal adjacent to but outside of 

the railroad ROW and its associated buffer zone and comply with the coal 

leasing regulations that do not allow leasing of less than 10-acre aliquot parts. 

Also, some of the coal in the above-described lands in the North Hilight Field 

LBA Tract is overlain by the Shroyer Road (County Road 116), which borders 

the North Hilight Field LBA Tract (Figure 2-1). The Surface Mining Control and 

Reclamation Act of 1977 (SMCRA) prohibits surface mining operations on lands 

within 100 feet of the outside line of the ROW for a public road (SMCRA Section 

522(e)(4) and 30 CFR 761.11(d)). Some of the coal in the above-described lands 

in the North Hilight Field LBA Tract is also within 100 feet of the Hilight Road 

(Campbell County Road 52) ROW. However, because the Hilight Road lies 

parallel and adjacent to the BNSF & UP rail line (Figure 2-1), the 100-foot 

buffer zone associated with the railroad ROW actually extends farther east and 

overlies more coal within the North Hilight Field LBA Tract than the 100-foot 

buffer zone associated with the Hilight Road ROW. The coal that is underlying 

the Shroyer Road, its ROW, and associated 100-foot buffer zone, and the coal 

that is within 100 feet of the Hilight Road ROW has been determined to be 

unsuitable for mining in accordance with SMCRA and as specified under 

Unsuitability Criterion 3 (43 CFR 3461). 

There is an exception to this prohibition in the regulations at SMCRA Section 

522(e)(4) and 30 CFR 761.11(d)(2), which can be applied if the appropriate road 

authority (Campbell County Board of Commissioners) allows the public roads 

to be relocated or closed after public notice, an opportunity for a public 

hearing, and a finding that the interests of the affected public and landowners 

will be protected. The Small Road (Campbell County Road 89) also overlies the 

North Hilight Field LBA Tract (Figure 2-1); however, it has been vacated by the 

Campbell County Commissioners. If TBCC obtains approval from the Campbell 

County Board of Commissioners to move the Shroyer Road, the exception to 

the prohibition on mining within the public road ROW and buffer zone could be 

applied and the unsuitability determination could be reconsidered. In that 

case, TBCC would be able to recover the coal underlying the county road ROW 

and its associated buffer zone. TBCC would not need to consider moving the 

Hilight Road for the reason explained above. If TBCC does not obtain approval 

to move or close the Shroyer Road, the coal underlying its ROW and associated 

buffer zone would remain unsuitable for mining and would not be recovered. 

The federal coal underlying the Shroyer Road, its ROW and associated 100-foot 

buffer zone is included in the tract because it would allow maximum recovery 

of all the mineable coal adjacent to but outside of the road ROW and associated 

buffer zone if the road is not moved; it would also allow recovery of the coal 

under the road if it is moved or closed. If a lease is issued for this tract, a 
2.0 Proposed Action and Alternatives 

2-12 Final EIS, Wright Area Coal Lease Applications

stipulation will be attached to the lease stating that no mining activity may be 

conducted in the portions of the lease within the ROW and buffer zone for the 

Shroyer Road and Hilight Road unless approval is obtained from the 

appropriate authority to move or close the road. 

TBCC estimates that the North Hilight Field LBA Tract as applied for includes 

approximately 319.7 million tons of in-place coal. If the Shroyer Road is not 

moved or closed, and considering the coal underlying the BNSF & UP railroad 

ROW and buffer zone, TBCC estimates that the North Hilight Field LBA Tract 

as applied for contains approximately 286.3 million tons of mineable coal 

reserves. Based on historical recovery practices, TBCC assumes that about 92 

percent of that coal, or approximately 263.4 million tons of coal, would be 

recovered from the North Hilight Field LBA Tract as applied for. If they acquire 

the tract and if the county road is not moved or closed, a total of 1,499.8 

million tons of coal would be mined after January 1, 2008, with an estimated 

263.4 million tons coming from the LBA tract. Based upon this estimate of 

recoverable reserves, about 17.6 percent of the in-place coal reserves included 

within the LBA tract would not be recovered under normal mining practices 

and due to the presence of the unmineable reserves within the railroad and 

public road ROWs and associated buffer zones. If the Shroyer Road is moved 

or closed, TBCC estimates that an additional 9.5 million tons of coal would be 

mineable in the North Hilight Field LBA Tract as applied for. 

The North Hilight Field LBA Tract would be mined as an integral part of the 

Black Thunder Mine under the Proposed Action. Since the North Hilight Field 

LBA Tract would be an extension of the existing Black Thunder Mine, the 

facilities and infrastructure would be the same as those identified in the 

Wyoming Department of Environmental Quality/Land Quality Division 

(WDEQ/LQD) Mine Permit 233 Term T7, approved November 1, 2005 and the 

BLM Resource Recovery and Protection Plan (R2P2), which was approved 

December 12, 2006. 

Black Thunder Mine’s currently approved air quality permits (Permit Numbers 

MD-417A, MD-877, MD-1178, MD-1555, MD-6824, and MD-3851) from the 

Wyoming Department of Environmental Quality/Air Quality Division 

(WDEQ/AQD) allow up to 135 million tons of coal per year to be mined. The 

Black Thunder Mine produced: 

• 62.6 million tons of coal in 2003, 

• 66.8 million tons of coal in 2004, 

• 62.7 million tons of coal in 2005, 

• 67.3 million tons of coal in 2006, 

• 65.3 million tons of coal in 2007, and 

• 67.4 million tons of coal in 2008 

(Wyoming Department of Employment 2003, Shamley 2008a and 2010). 

As of December 31, 2008, a total of approximately 1,087.9 million tons of coal 

had been mined from within the current permitted area of the mine. 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-13 

TBCC estimates an average annual coal production rate of 100 mmtpy after 

2008 for the Black Thunder Mine, increasing to an average of 135 mmtpy by 

2015. If ALC acquires the North Hilight Field LBA Tract as applied for, a total 

of approximately 1,432.8 million tons of coal would be recovered from the 

existing leases and the North Hilight Field LBA Tract after January 1, 2009, 

with an estimated 263.4 million tons coming from the LBA tract, as discussed 

above. With the North Hilight Field LBA Tract, coal production at the Black 

Thunder Mine would continue for approximately 11.3 years beyond 2008. The 

LBA tract accounts for approximately 2 years of the mine life extension. 

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 

and average quality of the coal 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 and average 

quality of the coal included in the tract will be published in the sale notice if 

the tract is offered for sale. 

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, and any public utility lines and oil and gas pipelines 

would be relocated as necessary. 

The first step of the mining process is soil salvage with suitable heavy 

equipment, such as rubber-tired scrapers. During initial pit development, soil 

is placed in temporary stockpiles for later use in final pit closure and 

reclamation. Whenever possible, direct haulage of soil from salvage areas 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 redistribute the stockpiled topsoil on regraded 

areas. 

The Black Thunder Mine is one of several mines currently operating in the PRB 

where the coal seams are notably thick and the overburden is relatively thin. 

Mining would be conducted in three separate pits identified as the North Pit, 

West Pit, and South Pit. After soil salvage operations are complete, blast holes 

are drilled down through the overburden to the top of the upper-most mineable 

coal seam. The drill holes are then loaded with explosives (a mixture of 

ammonium nitrate and fuel oil, or ANFO) and detonated to fragment the 

overburden to facilitate efficient excavation. Overburden removal has been and 

would continue to be conducted primarily with draglines, trucks and shovels, 

and/or direct cast blasting. Other equipment used during overburden removal 

and backfilling includes dozers, scrapers, excavators, front-end loaders, 

graders, and water trucks. Exposed coal seams have been and would continue 

to be cleaned with a dozer, drilled and blasted to facilitate efficient excavation, 

and then loaded into haul trucks for transport to the coal crushing and storage 

facilities. 
2.0 Proposed Action and Alternatives 

2-14 Final EIS, Wright Area Coal Lease Applications

The design of the Black Thunder Mine seeks to confine disturbance to the 

active mine blocks. As overburden is removed, most would be directly placed 

into the previous empty pit where coal has been removed. 

Chapter 4, Section 2(b)(i) of the WDEQ/LQD Coal Rules requires that rough 

backfilling and grading follow coal removal as closely as possible based on the 

mining conditions (WDEQ/LQD 2009). Replaced (backfilled) overburden is 

graded to approximate the original land surface contour, as required by WDEQ 

and the Office of Surface Mining Reclamation and Enforcement (OSM) rules. 

Elevations consistent with the approved post-mining topography (PMT) plan are 

established as quickly as possible to reconstruct a stable landscape and restore 

drainage. 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. Backfilled and recontoured overburden is sampled and 

analyzed to verify suitability as subsoil. Should unsuitable backfill materials 

be encountered (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), mitigation by 

additional soil depth, excavation and burial, or other special handling to 

remove them from the root zone would occur. Prior to soil distribution, 

regraded backfill is scarified to relieve compaction. Soil is redistributed on 

recontoured backfill using rubber-tired scrapers or haul trucks, dozers and 

blades. Once a seedbed has been formed, the reclaimed areas are revegetated 

using native grasses, forbs, and shrubs that are consistent with the postmining 

land use. According to the most recent OSM evaluation of the Wyoming coal 

mining industry, the reclamation to disturbance ratio in 2008 was 

approximately 86 percent (4,703 acres reclaimed vs. 5,497 acres disturbed) 

(OSM 2009). 

Coal would be produced from two mineable seams within the North Hilight 

Field LBA Tract. TBCC refers to these seams as the Upper Wyodak 

(upper/rider seam) and the Middle Wyodak (main seam), which are separated 

by a shale parting that has an average thickness of approximately 1 foot. The 

Upper Wyodak seam averages 13 feet thick and the Middle Wyodak seam 

averages 48 feet thick. A third seam, the Lower Wyodak (basal seam), is not 

present over the entire tract. Coal would be mined at several working pit faces 

to enable blending of the 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. 

Mining efficiency and air quality protection are and would continue to be 

facilitated by extensive use of near-pit crushers and overland conveyors. 

Coal would be loaded with electric-powered shovels or hydraulic excavators 

into off-highway haul trucks for transport to crushing facilities. Coal haul 

roads would be temporary structures built within the mine areas. All coal 

transfer location points and crushing operations are controlled by baghouse-
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-15 

type dust collectors, dry foggers, or passive enclosure control systems (PECs). 

The truck dumping operations use stilling sheds to control fugitive dust and 

the overland conveyor is covered by a dust hood. 

There are currently four existing crushing facilities, four existing silos, and a 

slot storage facility within the permit area that provide capacity to produce at 

the permitted level. New coal processing facilities and a new train loadout have 

been constructed within TBCC’s Northwest Rail Loop Amendment Area (refer to 

Section 2.3.4 for a description of this area), will improve operating efficiency 

and air quality protection. The new Thundercloud near-pit crusher/conveyor 

systems would be used if ALC acquires the North Hilight Field LBA Tract. 

Full-time employment at the Black Thunder Mine is currently 1,080. If the 

mine increases production as estimated, employment would grow to 1,324 by 

2013. If ALC acquires the North Hilight Field LBA Tract under the Proposed 

Action, they anticipate that Black Thunder Mine’s employment would remain at 

1,324 for the additional 2 years that it would take to mine the coal included in 

the tract. 

As discussed in Chapter 1, the North Hilight Field LBA Tract is adjacent to 

existing leases at both the Black Thunder and Jacobs Ranch mines, but is not 

adjacent to any of the other mines in this area, (Figure 1-1). If a company 

other than ALC was to acquire the tract, the rate of coal production, mining 

sequence, equipment, and facilities could be different than if ALC acquired the 

tract as a maintenance lease, as described above. However, the area of 

disturbance and the impacts of removing the coal would not be substantially 

different from the area of disturbance and the impacts of ALC mining the tract. 

2.1.2 North Hilight Field LBA Tract Alternative 1

Under the North Hilight Field LBA Tract Alternative 1, the No Action 

Alternative, ALC’s application to lease the coal included in the North Hilight 

Field 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 nor 

employment on the existing leases at the Black Thunder Mine. The Black 

Thunder Mine currently leases approximately 19,581.3 acres of federal coal, 

41.9 acres of private coal, and 2,792.9 acres of state coal, all of which are 

within the existing Black Thunder Mine permit boundary. A total of 

approximately 26,490.2 acres will eventually be affected in mining the current 

leases. If the North Hilight Field LBA Tract is not leased, TBCC estimates that 

the average annual coal production at the Black Thunder Mine after 2008 

would be 100 mmtpy, increasing to an average of 135 mmtpy by 2015, and the 

average full-time employment level by 2013 is expected to be 1,324 persons. 

Mining would continue at Black Thunder for approximately 9.3 years. Portions 

of the surface of the LBA tract would probably be disturbed by both the Black 
2.0 Proposed Action and Alternatives 

2-16 Final EIS, Wright Area Coal Lease Applications

Thunder and Jacobs Ranch mines 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 the North Hilight Field 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 North Hilight Field 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. This tract 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 north, east 

and/or west to create a larger tract, which could be mined by a new operation 

in the future. 

2.1.3 North Hilight Field LBA Tract Alternative 2--Preferred Alternative

Under Alternative 2 for the North Hilight Field LBA Tract, BLM would 

reconfigure the tract, 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 (Appendix D). Alternative 2, 

holding a competitive coal sale for a modified tract, is BLM’s Preferred 

Alternative. 

Alternative 2 for the North Hilight Field LBA Tract assumes that ALC 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 Black Thunder 

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 North Hilight Field LBA Tract consists of a single block of 

federal coal. In order to evaluate the potential that an alternate configuration 

of the tract would provide for more efficient recovery of the federal coal, 

increase competitive interest in the North Hilight Field 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 northern and eastern edges of the tract as applied for (Figure 2-1). The 

BLM study area includes lands (approximately 80.9 acres, or 1.1 percent of the 

study area) on the Thunder Basin National Grassland (TBNG), which is 

administered by the U.S. Department of Agriculture – Forest Service (USFS). 

Under Alternative 2, 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. 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-17 

Under Alternative 2, the area BLM is evaluating adding to the tract as applied 

for includes the following lands: 

T.44N., R.70W., 6th PM, Campbell County, Wyoming

Section 17: Lots 1 through 16; 654.17 acres 

Section 18: Lots 5 through 20; 655.14 acres 

Section 20: Lots 1 through 16; 651.07 acres 

Section 21: Lots 1 through 16; 658.37 acres 

Section 22: Lots 1 through 15; 606.85 acres 

T.44N., R.71W., 6th PM, Campbell County, Wyoming

Section 13: Lots 1 through 16; 655.53 acres 

Section 14: Lots 1 through 16; 644.74 acres 

Total: 4,525.87 acres

The legal description of the Alternative 2 BLM reconfiguration (Figure 2-1) for 

the North Hilight Field LBA Tract is as follows: 

T.44N., R.70W., 6th PM, Campbell County, Wyoming

Section 17: Lots 1 through 16; 654.17 acres 

Section 18: Lots 5 through 20; 655.14 acres 

Section 19: Lots 5 through 20; 656.88 acres 

Section 20: Lots 1 through 16; 651.07 acres 

Section 21: Lots 1 through 16; 658.37 acres 

Section 22: Lots 1 through 15; 606.85 acres 

T.44N., R.71W., 6th PM, Campbell County, Wyoming

Section 13: Lots 1 through 16; 655.53 acres 

Section 14: Lots 1 through 16; 644.74 acres 

Section 23: Lots 1 through 16; 653.11 acres 

Section 24: Lots 1 through 16; 653.44 acres 

Section 26: Lots 1 through 16; 650.07 acres 

Total: 7,139.37 acres

Land descriptions and acreage are based on the BLM Status of Public Domain 

Land and Mineral Titles approved Master Title Plats as of August 30, 2005 and 

September 7, 2007 and Coal Plats as of September 7, 2007. 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. 

TBCC estimates that the LBA tract reconfigured under Alternative 2 (the BLM 

study area) includes approximately 756.9 million tons of in-place coal reserves. 

As discussed in Section 2.1.1, some of the coal included in the above-described 

alternative tract configuration is not currently considered by TBCC to be 

mineable due to the presence of the BNSF & UP rail line ROW and associated 

100-foot buffer zone, which borders the entire western side of the BLM study 
2.0 Proposed Action and Alternatives 

2-18 Final EIS, Wright Area Coal Lease Applications

area (Figure 2-1). TBCC estimates that approximately 29.4 million tons of coal 

would not be mineable because of the railroad ROW and associated buffer 

zone. 

As discussed in Sections 1.5 and 2.1.1 and shown in Figure 2-1, some of the 

coal in the above-described alternative tract configuration is overlain by the 

Shroyer Road. Some of the coal in the above-described alternative tract 

configuration is also within 100 feet of the Hilight Road ROW. The coal that is 

underlying the public road ROWs and associated 100-foot buffer zones 

extending on either side of the ROWs has been determined to be unsuitable for 

mining in accordance with SMCRA and as specified in coal leasing 

Unsuitability Criterion Number 3 (43 CFR 3461) and would not be recoverable. 

The Hilight Road runs parallel and adjacent to the west side of the BNSF & UP 

railroad ROW (Figure 2-1); therefore, the 100-foot buffer zone associated with 

the railroad ROW actually extends farther east and overlies more coal within 

the BLM study area than the 100-foot buffer zone associated with the Hilight 

Road ROW. 

As discussed in Section 2.1.1, there is an exception to this prohibition to mine 

the coal underlying the public road ROWs and associated buffer zones that can 

be applied if the appropriate public road authority allows the road to be 

relocated or closed (SMCRA Section 522(e)(4) and 30 CFR 761.11(d)(2)). The 

Jacobs Road (Campbell County Road 59) and Small Road are two other county 

roads that overlie the Alternative 2 reconfiguration of the North Hilight Field 

LBA Tract (Figure 2-1), although they have been vacated by the Campbell 

County Commissioners. If TBCC obtains approval from the Campbell County 

Board of Commissioners to move or close the Shroyer Road, the exception to 

the prohibition on mining within the public road ROW and its associated 100-

foot buffer zone could be applied and the unsuitability determination could be 

reconsidered. In that case, TBCC would be able to recover the coal underlying 

the road ROW and associated buffer zone. TBCC would not need to consider 

moving the Hilight Road for the reason explained above. If TBCC does not 

obtain approval to move or close Shroyer Road, the coal underlying its ROWs 

and associated buffer zone would remain unsuitable for mining and would not 

be recovered. 

If the Shroyer Road is not moved or closed, TBCC estimates that the BLM study 

area under Alternative 2 (Figure 2-1) includes approximately 709.6 million tons 

of mineable coal reserves. Using TBCC’s projected recovery factor of 92 percent 

of the mineable coal reserves, about 652.8 million tons of the mineable coal 

would be recoverable. TBCC estimates that approximately 47.3 million tons of 

coal would not be mineable because of the railroad and public road ROWs and 

associated buffer zones. Although these lands would not be mined, they are 

included in the BLM study area tract configuration to allow maximum recovery 

of all 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, a stipulation will be attached to the lease stating that no mining activity 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-19 

may be conducted in the portions of the leased tract within the Hilight and 

Shroyer county road ROWs and associated buffer zones unless approval is 

obtained from the appropriate public road authority to relocate or close the 

roads. If the Shroyer Road is moved or closed, TBCC estimates that an added 

17.9 million tons of coal would be mineable in the BLM study area tract. 

TBCC estimates an average annual coal production rate of 100 mmtpy after 

2008 for the Black Thunder Mine, increasing to 135 mmtpy by 2015. With the 

BLM study area tract, coal production at the Black Thunder Mine would 

continue for approximately 14.1 years beyond 2008. The study area tract 

accounts for approximately 4.8 years of the mine life extension. 

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 may not be in agreement with the 

estimate provided by the applicant. Under the Preferred Alternative 

(Alternative 2), BLM’s estimate will be published in the sale notice for the tract, 

if it is offered for sale. 

2.2 South Hilight Field LBA Tract 

2.2.1 South Hilight Field LBA Tract Proposed Action

ALC has filed an application for two separate LBA tracts (North Hilight Field 

and South Hilight Field). Each tract will be evaluated separately and if a 

decision is made to lease both of these tracts, a separate competitive lease sale 

will be held for each tract. 

Under the Proposed Action for the South Hilight Field LBA Tract, the tract as 

applied for by ALC 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 South Hilight Field lease application (Figure 2-2). 

The Proposed Action assumes that ALC would be the successful bidder on the 

South Hilight Field LBA Tract, if it is offered for sale. 

The legal description of the proposed South Hilight Filed LBA Tract coal lease 

lands as applied for by ALC under the Proposed Action is as follows: 

T.43N., R.71W., 6th PM, Campbell County, Wyoming

Section 23: Lots 1 through 16; 649.36 acres 

Section 26: Lots 1 through 16; 667.69 acres 

Section 35: Lots 1 through 16; 659.64 acres 

Total: 1,976.69 acres

Land descriptions and acreage are based on the BLM Status of Public Domain 

Land and Mineral Titles approved Master Title Plat as of September 7, 2007 
2.0 Proposed Action and Alternatives 

2-20 Final EIS, Wright Area Coal Lease Applications

and Coal Plat as of September 7, 2007. The coal estate included in the tract 

described above is federally owned. Much of the surface (approximately 82 

percent, or 1,625.9 acres) of the tract as applied for includes lands on the 

TBNG, which is administered by the USFS. The ownership of the surface and 

oil and gas estates is discussed in Section 3.11. 

As discussed in Section 1.5, some of the coal in the above-described lands in 

the South Hilight Field LBA Tract has been determined to be unsuitable for 

mining in accordance with SMCRA and as specified under Unsuitability 

Criterion 2 (43 CFR 3461) due to the presence of the BNSF & UP railroad line, 

which borders the western side of the LBA tract (Figure 2-2). The coal 

underlying the railroad ROW and an associated 100-foot buffer zone is also not 

considered by TBCC to be mineable at this time because the cost that would be 

associated with moving the railroad tracks would make it economically 

unsuitable to recover the underlying coal. Although the federal coal underlying 

the railroad ROW and its associated buffer zone would not be mined, the coal is 

included in the tract because it would allow maximum recovery of the mineable 

coal adjacent to but outside of the railroad ROW and its associated buffer zone 

and comply with the coal leasing regulations that do not allow leasing of less 

than 10-acre aliquot parts. 

As indicated in Section 1.5, some of the coal in the above-described lands in 

the South Hilight Field LBA Tract is within 100 feet of the Hilight Road 

(Campbell County Road 52) ROW (Figure 2-2). SMCRA prohibits surface 

mining operations on lands within 100 feet of the outside line of the ROW for a 

public road (SMCRA Section 522(e)(4) and 30 CFR 761.11(d)). The coal that is 

within 100 feet of the Hilight Road ROW has been determined to be unsuitable 

for mining in accordance with SMCRA and as specified under Unsuitability 

Criterion 3 (43 CFR 3461). There is an exception to this prohibition in the 

regulations at SMCRA Section 522(e)(4) and 30 CFR 761.11(d)(2), which can be 

applied if the appropriate road authority (Campbell County Board of 

Commissioners) allows the public road to be relocated or closed. However, 

because the Hilight Road lies parallel and adjacent to the BNSF & UP rail line 

(Figure 2-2), the 100-foot buffer zone associated with the railroad ROW actually 

extends farther east and overlies more coal within the South Hilight Field LBA 

Tract than the 100-foot buffer zone associated with the Hilight Road ROW. 

TBCC would therefore not need to obtain approval from the Campbell County 

Board of Commissioners to close or move the Hilight Road in order to recover 

the coal underlying the 100-foot buffer zone along the east side of the Hilight 

Road ROW. 

If a lease is issued for this alternative tract configuration, a stipulation will be 

attached to the lease stating that no mining activity may be conducted in the 

portions of the lease within 100 feet of either the BNSF & UP rail line or Hilight 

Road ROWs. The stipulation would allow recovery of the coal under Hilight 

Road if approval is obtained from the appropriate authority to move or close the 

road. 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-21 

TBCC estimates that the South Hilight Field LBA Tract as applied for includes 

approximately 273.3 million tons of in-place coal, that approximately 232.2 

million tons of those in-place coal reserves are mineable, and that about 213.6 

million tons of coal would be recoverable. TBCC’s estimate that approximately 

78 percent of the estimated in-place reserves would be recoverable from the 

tract is based on assumptions about the currently unrecoverable reserves that 

lie within the railroad ROW and its associated buffer zone. 

The South Hilight Field LBA Tract would be mined as an integral part of the 

Black Thunder Mine under the Proposed Action. Since the South Hilight Field 

LBA Tract would be an extension of the existing Black Thunder Mine, the 

facilities and infrastructure would be the same as those identified in the 

WDEQ/LQD Mine Permit 233 Term T7, approved November 1, 2005 and the 

BLM R2P2, which was approved December 12. 2006. 

Black Thunder Mine’s currently approved air quality permits from the 

WDEQ/AQD allow up to 135 million tons of coal per year to be mined. The 

Black Thunder Mine produced: 

• 62.6 million tons of coal in 2003, 

• 66.8 million tons of coal in 2004, 

• 62.7 million tons of coal in 2005, 

• 67.3 million tons of coal in 2006, 

• 65.3 million tons of coal in 2007, and 

• 67.4 million tons of coal in 2008 

(Wyoming Department of Employment 2003, Shamley 2008a and 2010). 

As of December 31, 2008, a total of approximately 1,087.9 million tons of coal 

had been mined from within the current permitted area of the mine. 

TBCC estimates an average annual coal production rate of 100 mmtpy after 

2008 for the Black Thunder Mine, increasing to an average of 135 mmtpy by 

2015. If ALC acquires the South Hilight Field LBA Tract as applied for, a total 

of approximately 1,383.0 million tons of coal would be recovered from the 

existing leases and the South Hilight Field LBA Tract after January 1, 2009, 

with an estimated 213.6 million tons coming from the LBA tract, as discussed 

above. With the South Hilight Field LBA Tract, coal production at the Black 

Thunder Mine would continue for approximately 10.9 years beyond 2008. The 

LBA tract accounts for approximately 1.6 years of the mine life extension. 

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 

and average quality of the coal 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 and average 

quality of the coal included in the tract will be published in the sale notice if 

the tract is offered for sale. 
2.0 Proposed Action and Alternatives 

2-22 Final EIS, Wright Area Coal Lease Applications

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, and any public utility lines and oil and gas pipelines 

would be relocated as necessary. 

A brief description of TBCC’s mining operation at the Black Thunder Mine, 

emphasizing the methods and equipment that are used to remove, handle, and 

reclaim overburden and soil, is included in Section 2.1.1. The methods and 

equipment used to mine the coal, and the facilities used to process and store 

coal are also described in Section 2.1.1. Coal would be produced from two 

mineable seams within the South Hilight Field LBA Tract. TBCC refers to these 

seams as the Upper Wyodak (upper/rider seam) and the Middle Wyodak 

(lower/main seam), which are separated by a shale parting that has an average 

thickness of approximately 94 feet. The Upper Wyodak seam averages 5 feet 

thick and the Middle Wyodak seam averages 76 feet thick. The mining and 

reclamation methods, coal processing and storage facilities, and associated air 

quality protection measures would allow the Black Thunder Mine to produce at 

the currently permitted level. While sufficient capacity exists, future changes 

in facilities may be constructed to improve operating efficiency and air quality 

protection. 

Full-time employment at the Black Thunder Mine is currently 1,080. If the 

mine increases production as estimated, employment would grow to 1,324 by 

2013. If ALC acquires the South Hilight Field LBA Tract under the Proposed 

Action, they anticipate that the full-time employment level at the mine would 

remain at 1,324 for the additional 1.6 years that it would take to mine the coal 

included in the tract. 

As discussed in Chapter 1, the South Hilight Field LBA Tract is adjacent to 

existing leases at the Black Thunder Mine, but is not adjacent to any of the 

other existing mines in this area (Figure 1-1). If a company other than ALC 

was to acquire the tract, the rate of coal production, mining sequence, 

equipment, and facilities would be different than if ALC acquired the tract as a 

maintenance lease, as described above. However, the area of disturbance and 

the impacts of removing the coal would not be substantially different from the 

area of disturbance and the impacts of ALC mining the tract. 

2.2.2 South Hilight Field LBA Tract Alternative 1

Under the South Hilight Field LBA Tract Alternative 1, the No Action 

Alternative, ALC’s application to lease the coal included in the South Hilight 

Field 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 nor 

employment on the existing leases at the Black Thunder Mine. The Black 

Thunder Mine currently leases approximately 19,581.3 acres of federal coal, 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-23 

41.9 acres of private coal, and 2,792.9 acres of state coal, all of which are 

within the existing Black Thunder Mine permit boundary. A total of 

approximately 26,490.2 acres will eventually be affected in mining the current 

leases. If the South Hilight Field LBA Tract is not leased, TBCC estimates that 

the average annual production at the Black Thunder Mine would be 100 

mmtpy after 2008, increasing to an average of 135 mmtpy by 2015, and the 

average full-time employment level is expected to increase to 1,324 persons by 

2013. Mining would continue at the Black Thunder Mine for approximately 9.3 

years. Portions of the surface of the LBA tract would probably be disturbed by 

the Black Thunder Mine 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 the South Hilight Field 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 South Hilight Field 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. This tract 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 south and/or 

west to create a larger tract, which could be mined by a new operation in the 

future. 

2.2.3 South Hilight Field LBA Tract Alternative 2--Preferred Alternative

Under Alternative 2 for the South Hilight Field LBA Tract, BLM would 

reconfigure the tract, 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 (Appendix D). Alternative 2, 

holding a competitive coal sale for a modified tract, is BLM’s preferred 

alternative. 

Alternative 2 for the South Hilight Field LBA Tract assumes that ALC 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 Black Thunder 

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 South Hilight Field LBA Tract consists of a single block of 

federal coal. In order to evaluate the potential that an alternate configuration 

of the tract would provide for more efficient recovery of the federal coal, 

increase competitive interest in the South Hilight Field LBA Tract, and/or 
2.0 Proposed Action and Alternatives 

2-24 Final EIS, Wright Area Coal Lease Applications

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 southern edge of the tract as applied for (Figure 2-2). Under Alternative 

2, 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. 

Under Alternative 2, the area BLM is evaluating adding to the tract as applied 

for includes the following lands: 

T.42N., R.71W., 6th PM, Campbell County, Wyoming

Section 1: Lots 7 through 10 and 15 through 18; 316.43 acres 

Section 2: Lots 5 through 20; 629.26 acres 

Total: 945.69 acres

The legal description of the Alternative 2 BLM reconfiguration (Figure 2-2) for 

the South Hilight Field LBA Tract is as follows: 

T.42N., R.71W., 6th PM, Campbell County, Wyoming

Section 1: Lots 7 through 10 and 15 through 18; 316.43 acres 

Section 2: Lots 5 through 20; 629.26 acres 

T.43N., R.71W., 6th PM, Campbell County, Wyoming

Section 23: Lots 1 through 16; 649.36 acres 

Section 26: Lots 1 through 16; 667.69 acres 

Section 35: Lots 1 through 16; 659.64 acres 

Total: 2,922.38 acres

Land descriptions and acreage are based on the BLM Status of Public Domain 

Land and Mineral Titles approved Master Title Plats as of September 7, 2007 

and Coal Plats as of September 7, 2007. The coal estate included in the tract 

described above is federally owned. Much of the surface (approximately 88 

percent, or 2,572.6 acres) of the BLM study area includes lands on the TBNG, 

which is administered by the USFS. The ownership of the surface and oil and 

gas estates is discussed in Section 3.11. 

TBCC estimates that the LBA tract reconfigured under Alternative 2 (the BLM 

study area) includes approximately 406.5 million tons of in-place coal reserves. 

As discussed in Sections 1.5 and 2.2.1, some of the coal included in the abovedescribed alternative tract configuration has been determined unsuitable for 

mining due to the presence of the BNSF & UP rail line, which borders the entire 

western side of the BLM study area (Figure 2-2). TBCC estimates that 

approximately 58.7 million tons of coal would not be mineable because of the 

railroad ROW and associated 100-foot buffer zone. 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-25 

As shown in Figure 2-2, Reno Road (Campbell County Road 83) borders the 

southern edge of the BLM study area for the South Hilight Field LBA Tract. 

The coal that is underlying this public road ROW and associated 100-foot 

buffer zone has been determined to be unsuitable for mining in accordance 

with SMCRA and as specified under Unsuitability Criterion 3 (43 CFR 3461). 

Some of the coal in the above-described alternative tract configuration is also 

within 100 feet of the Hilight Road ROW; however, the 100-foot buffer zone 

associate with the railroad ROW extends farther east and overlies more coal 

within the BLM study area than the 100-foot buffer zone associated with the 

Hilight Road ROW. 

As discussed in Section 2.2.1, there is an exception to this prohibition in the 

regulations at SMCRA Section 522(e)(4) and 30 CFR 761.11(d)(2), which can be 

applied if the appropriate road authority (Campbell County Board of 

Commissioners) allows the road to be relocated or closed. If TBCC obtains 

approval from the Campbell County Board of Commissioners to move or close 

Reno Road, the exception to the prohibition on mining within the public road 

ROW and its associated buffer zone could be applied and the unsuitability 

determination could be reconsidered. In that case, TBCC would be able to 

recover the coal underlying the county road ROW and buffer zone. TBCC 

would not need to consider closing or moving the Hilight Road for the reason 

explained above. If TBCC does not obtain approval to move or close Reno 

Road, the coal underlying its ROW and associated buffer zone would remain 

unsuitable for mining and would not be recovered. 

If a lease is issued for this alternative tract configuration, a stipulation will be 

attached to the lease stating that no mining activity may be conducted in the 

portions of the lease within 100 feet of either the BNSF & UP railroad ROW, 

Hilight Road ROW, or Reno Road ROW. The stipulation would allow recovery of 

the coal under Reno or Hilight Road if approval is obtained from the 

appropriate authority to move or close the respective road. 

If the Reno Road is not moved or closed, TBCC estimates that the BLM study 

area under Alternative 2 (Figure 2-2) includes approximately 330.8 million tons 

of mineable coal reserves. Using TBCC’s projected recovery factor of 92 percent 

of the mineable coal reserves, about 304.3 million tons of the mineable coal 

would be recoverable. TBCC estimates that approximately 75.7 million tons of 

coal would not be mineable because of the railroad and public road ROWs and 

associated buffer zones. Although these lands would not be mined, they are 

included in the alternative tract configuration to allow maximum recovery of all 

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, a 

stipulation will be attached to the lease stating that no mining activity may be 

conducted in the portions of the leased tract within the Reno Road ROW and 

associated buffer zone unless approval is obtained from the appropriate public 

road authority to relocate or close the road. If the Reno Road is moved or 
2.0 Proposed Action and Alternatives 

2-26 Final EIS, Wright Area Coal Lease Applications

closed, TBCC estimates that an added 17.0 million tons of coal would be 

mineable in the BLM study area tract. 

TBCC estimates an average annual coal production rate of 100 mmtpy after 

2008 for the Black Thunder Mine, increasing to an average of 135 mmtpy by 

2015. With the BLM study area tract, coal production at the Black Thunder 

Mine would continue for approximately 11.6 years beyond 2008. The study 

area tract accounts for approximately 2.3 years of the mine life extension. 

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 may not be in agreement with the 

mineable coal reserve and coal quality estimates provided by the applicant. 

Under the Preferred Alternative (Alternative 2), BLM’s estimate will be 

published in the sale notice for the tract, if it is offered for sale. 

2.3 West Hilight Field LBA Tract 

2.3.1 West Hilight Field LBA Tract Proposed Action

Under the Proposed Action for the West Hilight Field LBA Tract, the tract as 

applied for by ALC 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 Hilight Field lease application (Figure 2-3). 

The Proposed Action assumes that ALC would be the successful bidder on the 

West Hilight Field LBA Tract, if it is offered for sale. 

The legal description of the proposed West Hilight Field LBA Tract coal lease 

lands as applied for by ALC under the Proposed Action is as follows: 

T.43N., R.71W., 6th PM, Campbell County, Wyoming

Section 8: Lots 1, 2, and 7 through 16; 493.00 acres 

Section 9: Lots 1 through 16; 655.31 acres 

Section 10: Lots 3 through 6, and 11 through 14; 327.85 acres 

Section 17: Lots 1 through 16; 650.17 acres 

Section 20: Lots 1 through 4; 162.54 acres 

Section 21: Lots 3 and 4 81.65 acres 

Total: 2,370.52 acres

Land descriptions and acreage are based on the BLM Status of Public Domain 

Land and Mineral Titles approved Master Title Plat as of September 7, 2007 

and Coal Plat as of September 7, 2007. The coal estate included in the tract 

described above is federally owned. A portion of the surface of the tract as 

applied for (approximately 29 percent, or 695.9 acres) includes lands on the 

TBNG, which is administered by the USFS. The ownership of the surface and 

oil and gas estates is discussed in Section 3.11. 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-27 

As discussed in Section1.5, Wyoming State Highway 450 borders the northern 

edge of the West Hilight LBA Tract (Figure 2-3). The Surface Mining Control 

and Reclamation Act of 1977 (SMCRA) prohibits mining within 100 feet on 

either side of the ROW of any public road unless the appropriate public road 

authority allows the road to be relocated or closed after public notice, an 

opportunity for a public hearing, and a finding that the interests of the affected 

public and landowners will be protected (30 CFR 761.11(d)). For State 

Highway 450 west of the BNSF & UP railroad ROW, an unsuitability decision 

(43 CFR 3461) is deferred subject to a finding by the Wyoming Department of 

Transportation (WYDOT) under this process (BLM 2001a). As a result, some of 

the coal in the above described lands is not currently considered to be 

recoverable. Although the federal coal underlying these lands may not be 

mined, it is included in the tract to allow maximum recovery of the mineable 

coal adjacent to but outside of the highway 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. 

If a lease is issued for this tract configuration, a stipulation will be attached to 

the lease stating that no mining activity may be conducted in the portions of 

the lease within 100 feet of the State Highway 450 ROW. The stipulation would 

allow recovery of the coal under State Highway 450 if approval is obtained from 

the appropriate authority to move the road. 

As applied for, the West Hilight Field LBA Tract includes an estimated 440.4 

million tons of in-place coal reserves. TBCC estimates that 29.6 million tons of 

the in-place coal would not be mineable because of the Highway 450 ROW and 

associated buffer zone. Of the 410.8 million tons of mineable reserves, using 

TBCC’s projected recovery factor of 92 percent of the mineable coal reserves, 

approximately 377.9 million tons would be recoverable from the West Hilight 

LBA Tract as applied for. 

The West Hilight Field LBA Tract would be mined as an integral part of the 

Black Thunder Mine under the Proposed Action. Since the West Hilight Field 

LBA Tract would be an extension of the existing Black Thunder Mine, the 

facilities and infrastructure would be the same as those identified in the 

WDEQ/LQD Mine Permit 233 Term T7, approved November 1, 2005 and the 

BLM R2P2, which was approved December 12, 2006. 

Black Thunder Mine’s currently approved air quality permits from the 

WDEQ/AQD allow up to 135 million tons of coal per year to be mined. The 

Black Thunder Mine produced: 

• 62.6 million tons of coal in 2003, 

• 66.8 million tons of coal in 2004, 

• 62.7 million tons of coal in 2005, 

• 67.3 million tons of coal in 2006, 

• 65.3 million tons of coal in 2007, and 

• 67.4 million tons of coal in 2008 
2.0 Proposed Action and Alternatives 

2-28 Final EIS, Wright Area Coal Lease Applications

(Wyoming Department of Employment 2003, Shamley 2008a and 2010). 

As of December 31, 2008, a total of approximately 1,087.9 million tons of coal 

had been mined from within the current permitted area of the mine. 

TBCC estimates an average annual coal production rate of 100 mmtpy after 

2008 for the Black Thunder Mine, increasing to an average of 135 mmtpy by 

2015. If ALC acquires the West Hilight Field LBA Tract as applied for, a total of 

approximately 1,547.3 million tons of coal would be recovered from the existing 

leases and the West Hilight Field LBA Tract after January 1, 2009, with an 

estimated 377.9 million tons coming from the LBA tract, as discussed above. 

About 14 percent of the in-place coal within the West Hilight Field LBA Tract 

would be lost under normal mining practices and would not be recovered due 

to the presence of the Highway 450 ROW and associated buffer zone. With the 

West Hilight Field LBA Tract, coal production at the Black Thunder Mine would 

continue for approximately 12.1 years beyond 2008. The LBA tract accounts 

for approximately 2.8 years of the mine life extension. If State Highway 450 is 

moved, TBCC estimates that an added 29.6 million tons of coal would be 

mineable in the West Hilight Field LBA Tract as applied for. 

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 

and average quality of the coal included in the tract may not be in agreement 

with the mineable coal reserves and coal quality estimates provided by the 

applicant. BLM’s estimate of the mineable federal coal reserves and average 

quality of the coal included in the tract will be published in the sale notice if 

the tract is offered for sale. 

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, and any public utility lines and oil and gas pipelines 

would be relocated as necessary. 

A brief description of TBCC’s mining operation at the Black Thunder Mine, 

emphasizing the methods and equipment that are used to remove, handle, and 

reclaim overburden and soil, is included in Section 2.1.1. The methods and 

equipment used to mine the coal, and the facilities used to process and store 

coal are also described in Section 2.1.1. Coal would be produced from two 

mineable seams within the West Hilight Field LBA Tract. TBCC refers to these 

seams as the Upper Wyodak (upper/rider seam) and the Middle Wyodak 

(lower/main seam), which are separated by a shale parting that has an average 

thickness of approximately 32 feet. The Upper Wyodak seam averages 6 feet 

thick and the Middle Wyodak seam averages 87 feet thick. The mining and 

reclamation methods, coal processing and storage facilities, and associated air 

quality protection measures would allow the Black Thunder Mine to produce at 

the currently permitted level. While sufficient capacity exists, future changes 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-29 

in facilities may be constructed to improve operating efficiency and air quality 

protection. 

Full-time employment at the Black Thunder Mine is currently 1,080. If the 

mine increases production as estimated, employment would grow to 1,324 by 

2013. If ALC acquires the West Hilight Field LBA Tract under the Proposed 

Action, they anticipate that the mine’s full-time employment level would remain 

at 1,324 for the additional 2.8 years that it would take to mine the coal 

included in the tract. 

As discussed in Chapter 1, the West Hilight Field LBA Tract is not adjacent to 

any existing leases at the Black Thunder Mine, although a portion of the tract 

lies within the mine’s current mining permit boundary (Figure 2-3). The West 

Hilight Field LBA Tract is not adjacent to any of the other existing leases or 

mines in this area (Figure 1-1). If a company other than ALC was to acquire 

the tract, the rate of coal production, mining sequence, equipment, and 

facilities would be different than if ALC acquired the tract as a maintenance 

lease, as described above. However, the area of disturbance and the impacts of 

removing the coal would not be substantially different from the area of 

disturbance and the impacts of ALC mining the tract. 

2.3.2 West Hilight Field LBA Tract Alternative 1

Under the West Hilight Field LBA Tract Alternative 1, the No Action Alternative, 

ALC’s application to lease the coal included in the West Hilight Field 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 nor 

employment on the existing leases at the Black Thunder Mine. The Black 

Thunder Mine currently leases approximately 19,581.3 acres of federal coal, 

41.9 acres of private coal, and 2,792.9 acres of state coal, all of which are 

within the existing Black Thunder Mine permit boundary. A total of 

approximately 26,490.2 acres will eventually be affected in mining the current 

leases. If the West Hilight Field LBA Tract is not leased, TBCC estimates that 

the average annual coal production at the Black Thunder Mine would be 100 

mmtpy after 2008, increasing to an average of 135 mmtpy by 2015, and the 

average full-time employment level is expected to increase to 1,324 persons by 

2013. Mining would continue at the Black Thunder Mine for approximately 9.3 

years. The surface of the LBA tract as applied for does not lie within any 

mine’s current permit area and would therefore not likely be disturbed by 

mining activities. 

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 the West Hilight Field 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 
2.0 Proposed Action and Alternatives 

2-30 Final EIS, Wright Area Coal Lease Applications

the future. If the decision is made to reject the West Hilight Field 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. This tract 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 that surrounds it to 

create a larger tract, which could be mined by a new operation in the future. 

2.3.3 West Hilight Field LBA Tract Alternative 2--Preferred Alternative

Under Alternative 2 for the West Hilight Field LBA Tract, BLM would 

reconfigure the tract, 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 (Appendix D). Alternative 2, 

holding a competitive coal sale for a modified tract, is BLM’s preferred 

alternative. 

Alternative 2 for the West Hilight Field LBA Tract assumes that ALC 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 Black Thunder 

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 Hilight Field LBA Tract consists of a single block of 

federal coal. In order to evaluate the potential that an alternate configuration 

of the tract would provide for more efficient recovery of the federal coal, 

increase competitive interest in the West Hilight Field 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 eastern, southern, northeastern, and northwestern edges of the tract as 

applied for (Figure 2-3). Under Alternative 2, 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. 

Under Alternative 2, the area BLM is evaluating adding to the tract as applied 

for includes the following lands: 

T.43N., R.71W., 6th PM, Campbell County, Wyoming

Section 8: Lots 3 through 6; 164.33 acres 

Section 10: Lots 1, 2, 7 through 10, 15, and 16; 326.18 acres 

Section 15: Lots 1 through 16; 659.26 acres 

Section 20: Lots 5 through 16; 488.50 acres 

Section 21: Lots 1, 2, and 5 through 16; 569.73 acres 

Section 22: Lots 1 through 16; 657.89 acres 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-31 

Section 27: Lots 1 through 16; 656.87 acres 

Section 28: Lots 1 through 16; 648.02 acres 

Section 34: Lots 1 through 16; 649.98 acres 

Total: 4,820.76 acres

The legal description of the Alternative 2 BLM reconfiguration (Figure 2-3) for 

the West Hilight Field LBA Tract is as follows: 

T.43N., R.71W., 6th PM, Campbell County, Wyoming

Section 8: Lots 1 through 16; 654.33 acres 

Section 9: Lots 1 through 16; 655.31 acres 

Section 10: Lots 1 through 16; 654.03 acres 

Section 15: Lots 1 through 16; 659.26 acres 

Section 17: Lots 1 through 16; 650.17 acres 

Section 20: Lots 1 through 16; 651.04 acres 

Section 21: Lots 1 through 16; 651.38 acres 

Section 22: Lots 1 through 16; 657.89 acres 

Section 27: Lots 1 through 16; 656.87 acres 

Section 28: Lots 1 through 16; 648.02 acres 

Section 34: Lots 1 through 16; 649.98 acres 

Total: 7,191.28 acres

Land descriptions and acreage are based on the BLM Status of Public Domain 

Land and Mineral Titles approved Master Title Plat as of September 7, 2007 

and Coal Plat as of September 7, 2007. The coal estate included in the tract 

described above is federally owned. Approximately 40 percent (or about 2,900 

acres) of the West Hilight Field LBA Tract under Alternative 2 includes lands on 

the TBNG, which is administered by the USFS. The ownership of the surface 

and oil and gas estates is discussed in Section 3.11. 

TBCC estimates that the West Hilight Field LBA Tract reconfigured under 

Alternative 2 (the BLM study area) includes approximately 1,147.9 million tons 

of in-place coal reserves. As discussed in Section 2.3.1 and shown in Figure 2-

3, a portion of Wyoming State Highway 450 borders the entire northern edge of 

the above-described alternate tract configuration. Therefore, some of the coal 

included in the West Hilight Field LBA Tract under this alternative is overlain 

by Highway 450 and SMCRA prohibits surface mining operations on lands 

within 100 feet of the outside line of the ROW for a public road (SMCRA Section 

522(e)(4) and 30 CFR 761.11(d)). If TBCC obtains approval from the WYDOT to 

move State Highway 450, the exception to the prohibition on mining within the 

road ROW and buffer zone could be applied and the unsuitability 

determination could be reconsidered. In that case, TBCC would be able to 

recover the coal underlying Wyoming State Highway 450, its ROW, and 

associated buffer zone. 
2.0 Proposed Action and Alternatives 

2-32 Final EIS, Wright Area Coal Lease Applications

As discussed in Section 1.5, some of the coal included in the above-described 

alternative tract configuration has been determined unsuitable for mining due 

to the presence of the BNSF & UP rail line, which borders the entire eastern 

side of the BLM study area (Figure 2-3). 

As shown in Figure 2-3, a portion of Hilight Road (Campbell County Road 52) 

lies west of and adjacent to the BNSF & UP rail line ROW, and also borders the 

entire eastern edge of the above described BLM study area. Therefore, some of 

the coal included in the West Hilight Field LBA Tract under this alternative is 

overlain by the Hilight Road and SMCRA prohibits surface mining operations 

on lands within 100 feet of the outside line of the ROW for a public road. The 

coal underlying this county road, its ROW, and associated 100-foot buffer zone 

has been determined to be unsuitable for mining in accordance with SMCRA 

and as specified under Unsuitability Criterion 3. There is an exception to this 

prohibition in the regulations at 30 CFR 761.11(d)(2), which can be applied if 

the appropriate road authority (Campbell County Board of Commissioners) 

allows the road to be relocated or closed. If TBCC obtains approval from the 

Campbell County Board of Commissioners to move this county road, the 

exception to the prohibition on mining within the road ROW and buffer zone 

could be applied and the unsuitability determination could be reconsidered. In 

that case, TBCC would be able to recover the coal underlying Hilight Road, its 

ROW, and associated buffer zone. If TBCC does not obtain approval to move or 

close the county road, the coal underlying the road, its ROW, and associated 

buffer zone would remain unsuitable for mining and would not be recovered. 

If Wyoming State Highway 450 and the Hilight Road are not moved or closed, 

TBCC estimates that the West Hilight Field LBA Tract under Alternative 2 

(Figure 2-3) includes approximately 1,049.1 million tons of mineable coal 

reserves. Using TBCC’s projected recovery factor of 92 percent of the mineable 

coal reserves, about 965.2 million tons of the mineable coal would be 

recoverable. TBCC estimates that approximately 98.8 million tons of coal 

would not be mineable because of the public road ROWs and associated buffer 

zones. Although these lands would not be mined, they are included in the 

alternative tract configuration to allow maximum recovery of all 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, a stipulation will 

be attached to the lease stating that no mining activity may be conducted in 

the portions of the leased tract within the Wyoming State Highway 450 and 

Hilight Road ROWs and associated buffer zones unless approval is obtained 

from the appropriate public road authority to relocate or close the roads. 

TBCC estimates an average annual coal production rate of 100 mmtpy after 

2008 for the Black Thunder Mine, increasing to an average of 135 mmtpy by 

2015. With the BLM study area tract, coal production at the Black Thunder 

Mine would continue for approximately 16.4 years beyond 2008. The study 

area tract accounts for approximately 7.1 years of the mine life extension. 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-33 

If Hilight Road is moved or closed, TBCC estimates that an added 52.6 million 

tons of coal would be mineable in the BLM study area tract. If relocation of 

Wyoming State Highway 450 were approved, TBCC estimates that an additional 

46.2 million tons of coal would be mineable in the BLM study area tract. 

Full-time employment at the Black Thunder Mine is currently 1,080. If the 

mine increases production as estimated, employment would grow to 1,324 by 

2013. If ALC acquires the BLM study area tract, they anticipate that the 

mine’s full-time employment level would remain at 1,324 for the additional 7.1 

years that it would take to mine the coal included in the tract. 

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 may not be in agreement with the 

mineable coal reserve and coal quality estimates provided by the applicant. 

Under the Preferred Alternative (Alternative 2), BLM’s estimate will be 

published in the sale notice for the tract, if it is offered for sale. 

2.3.4 West Hilight Field LBA Tract Alternative 3

Under Alternative 3 for the West Hilight Field LBA Tract, BLM is considering 

adding some or all of the BLM study area, as discussed under Alternative 2 

(Section 2.3.3), and some or all of TBCC’s Northwest Rail Loop Amendment 

Area (Figure 2-3). Under Alternative 3, BLM would reconfigure the tract, 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 (Appendix D). 

Alternative 3 for the West Hilight Field LBA Tract assumes that ALC 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 Black Thunder 

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 Hilight Field LBA Tract consists of a single block of 

federal coal. As discussed under Alternative 2, BLM identified a study area in 

order to evaluate the potential that an alternate configuration of the tract 

would provide for more efficient recovery of the federal coal, increase 

competitive interest in the West Hilight Field LBA Tract, and/or reduce the 

potential that some of the remaining unleased federal coal in this area would 

be bypassed in the future. The BLM study area, shown in Figure 2-3, includes 

the tract as applied for and unleased federal coal adjacent to the eastern, 

southern, and northwestern edges of the tract as applied for, and additionally 

under Alternative 3, BLM is considering adding some or all of Black Thunder 

Mine’s Northwest Rail Loop Amendment Area. 
2.0 Proposed Action and Alternatives 

2-34 Final EIS, Wright Area Coal Lease Applications

TBCC’s Northwest Rail Loop Amendment Area, which lies north of Wyoming 

State Highway 450 and west of the Hilight Road, is entirely within Black 

Thunder Mine’s current permit area (Figure 2-3). In 2008, Black Thunder Mine 

completed the construction of a new train loadout facility, including a railroad 

spur and two storage silos within their Northwest Rail Loop Amendment Area. 

This area is also entirely within the West Jacobs Ranch LBA Tract; therefore, 

BLM has not included it within the study area for the West Hilight Field LBA 

Tract. However, this alternative tract configuration will preserve the option of 

delineating some or all of TBCC’s Northwest Rail Loop Amendment Area into 

the West Hilight Field, the West Jacobs Ranch, or both LBA tracts. 

It may not be economically feasible to move the railroad spur, train loadout and 

silos to recover all the coal at this time. However, BLM is considering including 

this area in the tract because it may be possible to recover portions of the coal 

reserves in this area when the rest of the tract is mined, if it is leased at this 

time. It may also be economically feasible at some point in the future to move 

the train loadout facilities and recover the coal if it is leased. 

Under Alternative 3, the lands within TBCC’s Northwest Rail Loop Amendment 

Area that BLM is evaluating adding to the Alternative 2 reconfiguration of the 

West Hilight Field LBA Tract are as follows: 

T.43N., R.71W., 6th PM, Campbell County, Wyoming

Section 3: Lots 2, 5, and 8 through 19; 557.99 acres 

T.44N., R.71W., 6th PM, Campbell County, Wyoming

Section 22: Lots 9, 10, 15, and 16; 164.25 acres 

Section 27: Lots 1, 2, 7 through 10, 15, and 16; 327.88 acres 

Section 34: Lots 1, 2, 7 through 10, 15, and 16; 328.73 acres 

Total: 1,378.85 acres

The legal description of the Alternative 3 reconfiguration of the West Hilight 

Field LBA Tract is as follows: 

T.43N., R.71W., 6th PM, Campbell County, Wyoming

Section 3: Lots 2, 5, and 8 through 19; 557.99 acres 

Section 8: Lots 1 through 16; 654.33 acres 

Section 9: Lots 1 through 16; 655.31 acres 

Section 10: Lots 1 through 16; 654.03 acres 

Section 15: Lots 1 through 16; 659.26 acres 

Section 17: Lots 1 through 16; 650.17 acres 

Section 20: Lots 1 through 16; 651.04 acres 

Section 21: Lots 1 through 16; 651.38 acres 

Section 22: Lots 1 through 16; 657.89 acres 

Section 27: Lots 1 through 16; 656.87 acres 

Section 28: Lots 1 through 16; 648.02 acres 

Section 34: Lots 1 through 16; 649.98 acres 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-35 

T.44N., R.71W., 6th PM, Campbell County, Wyoming

Section 22: Lots 9, 10, 15, and 16; 164.25 acres 

Section 27: Lots 1, 2, 7 through 10, 15, and 16; 327.88 acres 

Section 34: Lots 1, 2, 7 through 10, 15, and 16; 328.73 acres 

Total: 8,570.13 acres

Land descriptions and acreage are based on the BLM Status of Public Domain 

Land and Mineral Titles approved Master Title Plats as of August 30, 2005 and 

September 7, 2007 and Coal Plats as of September 7, 2007. The coal estate 

included in the tract described above is federally owned. Approximately 35 

percent (roughly 2,900 acres) of the West Hilight Field LBA Tract under 

Alternative 3 includes lands on the TBNG, which is administered by the USFS. 

The ownership of the surface and oil and gas estates is discussed in Section 

3.11. 

TBCC estimates that the West Hilight Field LBA Tract under this alternative 

includes approximately 1,373.4 million tons of in-place coal reserves. As 

discussed in Sections 2.3.1 and 2.3.2, and shown in Figure 2-3, a portion of 

Wyoming State Highway 450 borders the northern edge and lies across a 

portion of the above-described alternate tract configuration. Therefore, some of 

the coal included in the West Hilight Field LBA Tract under this alternative is 

overlain by State Highway 450 and SMCRA prohibits surface mining operations 

on lands within 100 feet of the outside line of the ROW for a public road 

(SMCRA Section 522(e)(4) and 30 CFR 761.11(d)). If TBCC obtains approval 

from the WYDOT to relocate State Highway 450, the exception to the 

prohibition on mining within the road ROW and buffer zone could be applied 

and the unsuitability determination could be reconsidered. In that case, TBCC 

would be able to recover the coal underlying Wyoming State Highway 450, its 

ROW, and associated buffer zone. 

As discussed in Section 1.5, some of the coal included in the above-described 

alternative tract configuration has been determined unsuitable for mining due 

to the presence of the BNSF & UP rail line, which borders the entire eastern 

side of the Alternative 3 reconfiguration of the West Hilight Field LBA Tract 

(Figure 2-3). 

As shown in Figure 2-3, a portion of Hilight Road (Campbell County Road 52) 

lies west of and adjacent to the BNSF & UP rail line ROW, and also borders the 

entire eastern edge of the above described Alternative 3 tract reconfiguration. 

Therefore, some of the coal included in the West Hilight Field LBA Tract under 

this alternative is overlain by the Hilight Road and SMCRA prohibits surface 

mining operations on lands within 100 feet of the outside line of the ROW for a 

public road. The coal underlying this county road, its ROW, and associated 

100-foot buffer zone has been determined to be unsuitable for mining in 

accordance with SMCRA and as specified under Unsuitability Criterion 3. 

There is an exception to this prohibition in the regulations at 30 CFR 

761.11(d)(2), which can be applied if the appropriate road authority (Campbell 
2.0 Proposed Action and Alternatives 

2-36 Final EIS, Wright Area Coal Lease Applications

County Board of Commissioners) allows the road to be relocated or closed. If 

TBCC obtains approval from the Campbell County Board of Commissioners to 

move this county road, the exception to the prohibition on mining within the 

road ROW and buffer zone could be applied and the unsuitability 

determination could be reconsidered. In that case, TBCC would be able to 

recover the coal underlying Hilight Road, its ROW, and associated buffer zone. 

If TBCC does not obtain approval to move or close the county road, the coal 

underlying the road, its ROW, and associated buffer zone would remain 

unsuitable for mining and would not be recovered. 

If a lease is issued for this tract, a stipulation will be attached to the lease 

stating that no mining activity may be conducted in the portions of the leased 

tract within the Wyoming State Highway 450 and Hilight Road ROWs and 

associated buffer zones unless approval is obtained from the appropriate public 

road authority to relocate or close the roads. 

If Wyoming State Highway 450 and the Hilight Road are not moved or closed, 

TBCC estimates that the West Hilight Field LBA Tract under Alternative 3 

(Figure 2-3) includes approximately 1,049.1 million tons of mineable coal 

reserves. Using TBCC’s projected recovery factor of 92 percent of the mineable 

coal reserves, about 965.2 million tons of the mineable coal would be 

recoverable. TBCC estimates that approximately 324.3 million tons of coal 

would not be mineable because of the presence of the mine’s new railroad spur, 

train loadout and two storage silos, plus the public road ROWs and associated 

buffer zones. Although these lands would not be mined, they are included in 

the alternative tract configuration to allow maximum recovery of all the 

mineable coal that is adjacent to but outside of the Northwest Rail Loop 

facilities, road 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, a stipulation will be attached to the lease 

stating that no mining activity may be conducted in the portions of the leased 

tract within the Wyoming State Highway 450 and Hilight Road ROWs and 

associated buffer zones unless approval is obtained from the appropriate public 

road authority to relocate or close the roads. 

TBCC estimates an average annual coal production rate of 100 mmtpy after 

2008 for the Black Thunder Mine, increasing to an average of 135 mmtpy by 

2015. With the West Hilight Field LBA Tract under Alternative 3, coal 

production at the Black Thunder Mine would continue for approximately 16.4 

years beyond 2008. The Alternative 3 Tract configuration accounts for 

approximately 7.1 years of the mine life extension. 

If Hilight Road is moved or closed, and if relocation of Wyoming State Highway 

450 were approved, TBCC estimates that an added 98.8 million tons of coal 

would be mineable in the Alternative 3 tract. TBCC estimates that about 207.5 

million tons could be recovered assuming coal under the Northwest Rail Loop 

Amendment Area were mineable at some time in the future. 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-37 

Full-time employment at the Black Thunder Mine is currently 1,080. If the 

mine increases production as estimated, employment would grow to 1,324 by 

2013. If ALC acquires the West Hilight Field LBA as configured under 

Alternative 3, they anticipate that the mine’s full-time employment level would 

remain at 1,324 for the additional 7.1 years that it would take to mine the coal 

included in the tract. 

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 may not be in agreement with the 

mineable coal reserve and coal quality estimates provided by the applicant. 

Under Alternative 3, BLM’s estimate will be published in the sale notice for the 

tract, if it is offered for sale. 

2.4 West Jacobs Ranch LBA Tract 

2.4.1 West Jacobs Ranch LBA Tract Proposed Action

Under the Proposed Action for the West Jacobs Ranch LBA Tract, the tract as 

applied for by ALC 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 Jacobs Ranch lease application (Figure 2-

4). The Proposed Action assumes that ALC would be the successful bidder on 

the West Jacobs Ranch LBA Tract, if it is offered for sale. 

The legal description of the proposed West Jacobs Ranch LBA Tract coal lease 

lands as applied for by ALC under the Proposed Action is as follows: 

T.43N., R.71W., 6th PM, Campbell County, Wyoming

Section 3: Lots 2 and 5 through 19; 638.38 acres 

Section 4: Lots 5 through 20; 639.50 acres 

Section 5: Lots 5 through 20; 636.67 acres 

T.44N., R.71W., 6th PM, Campbell County, Wyoming

Section 22: Lots 9 through 16; 326.99 acres 

Section 27: Lots 1 through 16; 658.21 acres 

Section 28: Lots 1 through 3 and 5 through 16; 608.43 acres 

Section 29: Lots 5 through 15 and SE1⁄4SE1⁄4; 478.10 acres 

Section 32: Lots 1 through 15 and SW1⁄4SE1⁄4; 643.83 acres 

Section 33: Lots 1 through 15 and NE1⁄4SE1⁄4 ; 653.02 acres 

Section 34: Lots 1 through 16; 661.24 acres 

Total: 5,944.37 acres

Land descriptions and acreage are based on the BLM Status of Public Domain 

Land and Mineral Titles approved Master Title Plats as of August 30, 2005 and 

September 7, 2007 and Coal Plats as of September 7, 2007. The coal estate 
2.0 Proposed Action and Alternatives 

2-38 Final EIS, Wright Area Coal Lease Applications

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, Wyoming State Highway 450 borders the entire 

southern edge of the West Jacobs Ranch LBA Tract (Figure 2-4). SMCRA 

prohibits mining within 100 feet on either side of the ROW of any public road 

unless the appropriate public road authority allows the road to be relocated or 

closed after public notice, an opportunity for a public hearing, and a finding 

that the interests of the affected public and landowners will be protected (30 

CFR 761.11(d)). For State Highway 450 west of the BNSF & UP railroad ROW, 

an unsuitability decision (43 CFR 3461) is deferred subject to a finding by 

WYDOT under this process (BLM 2001a). As a result, some of the coal in the 

above described lands is not currently considered to be recoverable. 

TBCC’s Northwest Rail Loop Amendment Area, which lies north of Wyoming 

State Highway 450 and west of the Hilight Road, is entirely within Black 

Thunder Mine’s current permit area (Figure 2-3). Black Thunder Mine 

completed the construction of a new train loadout facility, including a railroad 

spur and two storage silos, within their Northwest Rail Loop Amendment Area 

in 2008. TBCC’s new railroad spur, train loadout facility, and two storage silos 

are located entirely within the West Jacobs Ranch LBA Tract. It may not be 

economically feasible to move the railroad spur and the coal processing and 

storage facilities to recover all the coal at this time, but may be economically 

feasible at some point in the future, if the coal is leased. 

As discussed in Section 1.5, some of the coal included in the above-described 

alternative tract configuration has been determined unsuitable for mining due 

to the presence of the BNSF & UP rail line ROW, which borders the entire 

eastern side of the LBA tract. As shown in Figure 2-4, a portion of Hilight Road 

(Campbell County Road 52) lies west of and adjacent to the BNSF & UP rail line 

ROW, and also borders the entire eastern edge of the above described lands. 

Therefore, some of the coal included in the West Jacobs Ranch LBA Tract as 

applied for is overlain by the Hilight Road and SMCRA prohibits surface mining 

operations on lands within 100 feet of the outside line of the ROW for a public 

road. The coal that is underlying this county road, its ROW, and associated 

100-foot buffer zone has been determined to be unsuitable for mining in 

accordance with SMCRA and as specified under Unsuitability Criterion 3. 

There is an exception to this prohibition in the regulations at SMCRA Section 

522(e)(4) and 30 CFR 761.11(d)(2), which can be applied if the appropriate road 

authority (Campbell County Board of Commissioners) allows the road to be 

relocated or closed. If ALC obtains approval from the Campbell County Board 

of Commissioners to move this county road, the exception to the prohibition on 

mining within the road ROW and buffer zone could be applied and the 

unsuitability determination could be reconsidered. In that case, ALC would be 

able to recover the coal underlying Hilight Road, its ROW, and associated 

buffer zone. 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-39 

ALC estimates that the West Jacobs Ranch LBA Tract as applied for includes 

approximately 957.0 million tons of in-place coal reserves. If Wyoming State 

Highway 450 and the Hilight Road are not closed or relocated, ALC estimates 

that the West Jacobs Ranch LBA Tract as applied for (Figure 2-4) includes 

approximately 744.0 million tons of mineable coal reserves. Using ALC’s 

projected recovery factor of 90 percent of the mineable coal reserves, about 

669.6 million tons of the mineable coal would be recoverable. ALC estimates 

that approximately 213.0 million tons of coal would not be mineable because of 

the public road ROWs and associated buffer zones. Although these lands 

would not be mined, they are included in the as applied for tract configuration 

to allow maximum recovery of all the mineable coal that is adjacent to but 

outside of the public road 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, a stipulation will be attached to 

the lease stating that no mining activity may be conducted in the portions of 

the leased tract within the State Highway 450 and Hilight Road ROWs and 

associated buffer zones unless approval is obtained from the appropriate public 

road authority to relocate or close the roads. 

The West Jacobs Ranch LBA Tract would be mined as an integral part of the 

Jacobs Ranch Mine under the Proposed Action. Since the West Jacobs Ranch 

LBA Tract would be an extension of the existing Jacobs Ranch Mine, the 

facilities and infrastructure would be the same as those identified in the 

WDEQ/LQD Mine Permit 271 Term T5, approved November 23, 2004 and the 

BLM R2P2, which was approved October 19, 2005. 

Jacobs Ranch Mine’s currently approved air quality permit (Permit Number 

MD-1005A2) from the WDEQ/AQD allows up to 55 million tons of coal per year 

to be mined. The Jacobs Ranch Mine produced: 

• 36.0 million tons of coal in 2003, 

• 38.6 million tons of coal in 2004, 

• 37.3 million tons of coal in 2005, 

• 40.0 million tons of coal in 2006, 

• 38.1 million tons of coal in 2007, and 

• 42.1 million tons of coal in 2008 

(Wyoming Department of Employment 2003, Shamley 2008a and 2010). 

As of December 31, 2008, a total of approximately 671.1 million tons of coal 

had been mined from within the current permitted area of the mine. 

ALC estimates an average annual coal production rate of 40 mmtpy for the 

Jacobs Ranch Mine for the years beyond 2008. If ALC acquires the West 

Jacobs Ranch LBA Tract as applied for, a total of approximately 1,049.0 million 

tons of coal would be recovered from the existing leases and the West Jacobs 

Ranch LBA Tract after January 1, 2009, with an estimated 669.6 million tons 

coming from the LBA tract, as discussed above. About 30 percent of the inplace coal within the West Jacobs Ranch LBA Tract would be lost under 
2.0 Proposed Action and Alternatives 

2-40 Final EIS, Wright Area Coal Lease Applications

normal mining practices and would not be recovered due to the presence of the 

Highway 450 and Hilight Road ROWs and associated buffer zones. With the 

West Jacobs Ranch LBA Tract as applied for, coal production at the Jacobs 

Ranch Mine would continue for approximately 26.3 years beyond 2008. The 

LBA tract accounts for approximately 16.7 years of the mine life extension. 

If the Hilight Road is moved or closed, and if relocation of Wyoming State 

Highway 450 were approved, ALC estimates that an added 213.0 million tons of 

coal would be mineable in the West Jacobs Ranch LBA Tract as applied for. 

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 

and average quality of the coal 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 and average 

quality of the coal included in the tract will be published in the sale notice if 

the tract is offered for sale. 

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, and any public utility lines and oil and gas pipelines 

would be relocated as necessary. 

The first step of the mining process is soil salvage with suitable heavy 

equipment, such as rubber-tired scrapers. During initial pit development, soil 

is placed in temporary stockpiles for later use in final pit closure and 

reclamation. Whenever possible, direct haulage of soil from salvage areas 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 redistribute the stockpiled topsoil on regraded 

areas. 

The Jacobs Ranch Mine is one of several mines currently operating in the PRB 

where the coal seams are notably thick and the overburden is relatively thin. 

Mining has historically been conducted in two pits in order to facilitate 

blending of the coal to meet customers’ coal quality requirements. Mining may 

be conducted in three separate pits; two located within the current permit area 

and one located within the proposed lease area. The locations of the specific 

pits may change as a result of further geologic and mining evaluations. After 

soil salvage operations are complete, blast holes are drilled down through the 

overburden to the top of the upper-most mineable coal seam. The drill holes 

are then loaded with explosives (ANFO) and detonated to fragment the 

overburden to facilitate efficient excavation. Overburden removal has been and 

would continue to be conducted primarily with a dragline and/or trucks and 

shovels. Cast blasting is employed to supplement dragline productivity. Other 

equipment used during overburden removal and backfilling includes dozers, 

scrapers, excavators, front-end loaders, graders, and water trucks. Exposed 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-41 

coal seams have been and would continue to be cleaned with a dozer, drilled 

and blasted to facilitate efficient excavation, and then loaded into haul trucks 

for transport to the coal crushing and storage facilities. Coal is also 

transported by overland conveyor to the final preparation plant and storage 

facilities. 

The design of the Jacobs Ranch Mine seeks to confine disturbance to the active 

mine blocks. As overburden is removed, most would be directly placed into the 

previous empty pit where coal has been removed. 

Chapter 4, Section 2(b)(i) of the WDEQ/LQD Coal Rules requires that rough 

backfilling and grading follow coal removal as closely as possible based on the 

mining conditions (WDEQ/LQD 2009). Replaced (backfilled) overburden is 

graded to approximate the original land surface contour, as required by WDEQ 

and OSM rules. Elevations consistent with the approved PMT plan are 

established as quickly as possible to reconstruct a stable landscape and restore 

drainage. 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. Backfilled and recontoured overburden is sampled and 

analyzed to verify suitability as subsoil. Should unsuitable backfill materials 

be encountered (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), mitigation by 

additional soil depth, excavation and burial, or other special handling to 

remove them from the root zone would occur. Prior to soil distribution, 

regraded backfill is scarified to relieve compaction. Soil is redistributed on 

recontoured backfill using rubber-tired scrapers. Once a seedbed has been 

formed the reclaimed areas are revegetation using native grasses, forbs, and 

shrubs that are consistent with the postmining land use. According to the 

most recent OSM evaluation of the Wyoming coal mining industry, the 

reclamation to disturbance ratio in 2008 was approximately 86 percent (4,703 

acres reclaimed vs. 5,497 acres disturbed) (OSM 2009). 

The Jacobs Ranch Mine mines up to three coal seams that the operator (TBCC) 

refers to as the Upper, Middle, and Lower Wyodak seams. Coal would be 

produced from one mineable seam within the West Jacobs Ranch LBA Tract. 

TBCC refers to this single coal seam as the Wyodak and it has an average 

thickness of about 102 feet in the LBA tract area. Coal would be mined at 

several working pit faces to enable blending of the 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. Mining efficiency and air quality protection are and 

would continue to be facilitated by the use of a near-pit crusher and overland 

conveyor. Coal would be loaded with electric-powered shovels or hydraulic 

excavators into off-highway haul trucks for transport to the near-pit crusher or 

the coal preparation plant. Coal haul roads would be temporary structures 
2.0 Proposed Action and Alternatives 

2-42 Final EIS, Wright Area Coal Lease Applications

built within the mine areas. All coal transfer location points and crushing 

operations are controlled by baghouse-type dust collectors, dry fog systems, or 

PECs. The truck dumping operations use stilling sheds to control fugitive dust 

and the overland conveyor system is entirely enclosed. There are two existing 

crushing facilities, the near-pit primary crusher and the coal preparation plant, 

and seven coal storage silos within the permit area that provide capacity to 

produce at the permitted level. While sufficient capacity exists, future changes 

in facilities may be constructed to improve operating efficiency and air quality 

protection. Future possibilities for processing and loadout of coal include 

overland conveying to existing facilities. Alternately, if ALC acquires the West 

Jacobs Ranch LBA Tract, TBCC’s new coal processing and train loadout 

facilities that are located within Black Thunder Mine’s Northwest Rail Loop 

Amendment Area (Figures 2-3 and 2-4) may be utilized once the Jacobs Ranch 

and Black Thunder Mine permits are consolidated. 

Full-time employment at the Jacobs Ranch Mine is currently 630. If ALC 

acquires the West Jacobs Ranch LBA Tract under the Proposed Action, they 

anticipate that, at the expected average annual post-2008 coal production of 40 

million tons, the average employment level would increase to from 630 to 785 

for the additional 16.7 years that it would take to mine the coal included in the 

tract. 

As discussed in Chapter 1, the West Jacobs Ranch LBA Tract is adjacent to 

existing leases at the Black Thunder Mine and a portion of the tract is within 

the mine’s current permit area. The West Jacobs Ranch LBA Tract is not 

adjacent to any of the other existing leases or mines in this area (Figure 1-1). If 

a company other than ALC was to acquire the tract, the rate of coal production, 

mining sequence, equipment, and facilities would be different than if ALC 

acquired the tract as a maintenance lease, as described above. However, the 

area of disturbance and the impacts of removing the coal would not be 

substantially different from the area of disturbance and the impacts of TBCC 

mining the tract. 

2.4.2 West Jacobs Ranch LBA Tract Alternative 1

Under the West Jacobs Ranch LBA Tract Alternative 1, the No Action 

Alternative, ALC’s application to lease the coal included in the West Jacobs 

Ranch 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 nor 

employment on the existing leases at the Jacobs Ranch Mine. The Jacobs 

Ranch Mine currently leases approximately 7,381.0 acres of federal coal, 720 

acres of private coal, and 503.8 acres of state coal, all of which are within the 

existing Jacobs Ranch Mine permit boundary. A total of approximately 

15,261.5 acres will eventually be affected in mining the current leases. If the 

West Jacobs Ranch LBA Tract is not leased, TBCC estimates that the annual 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-43 

production at the Jacobs Ranch Mine after 2008 would average 40 million 

tons, and the average full-time employment level is expected to be 630 persons. 

Mining would continue at the Jacobs Ranch Mine for approximately 9.6 years. 

No portion of the West Jacobs Ranch LBA Tract will be disturbed under the 

Jacobs Ranch and Black Thunder mines’ existing mining plans in order to 

recover the coal in the existing contiguous coal leases. However, the 

construction of a new train loadout facility for the Black Thunder Mine within 

TBCC’s permitted Northwest Rail Loop Amendment Area, which is located 

within the eastern portion of the LBA tract (Figures 2-3 and 2-4), was 

completed in 2008. 

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 the West Jacobs Ranch 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 Jacobs Ranch 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. This tract includes enough coal reserves to economically justify mining 

by a new operation, and the coal reserves included in the tract could 

potentially be combined with unleased federal coal to the north, east and/or 

west to create a larger tract that could be mined by a new operation in the 

future. 

2.4.3 West Jacobs Ranch LBA Tract Alternative 2--Preferred Alternative

Under Alternative 2 for the West Jacobs Ranch LBA Tract, BLM would 

reconfigure the tract, 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 (Appendix D). Alternative 2, 

holding a competitive coal sale for a modified tract, is BLM’s preferred 

alternative. 

Alternative 2 for the West Jacobs Ranch LBA Tract assumes that ALC 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 Jacobs Ranch 

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 Jacobs Ranch LBA Tract consists of a single block of 

federal coal. In order to evaluate the potential that an alternate configuration 

of the tract would provide for more efficient recovery of the federal coal, 

increase competitive interest in the West Jacobs Ranch LBA Tract, and/or 

reduce the potential that some of the remaining unleased federal coal in this 
2.0 Proposed Action and Alternatives 

2-44 Final EIS, Wright Area Coal Lease Applications

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 northern and western edges of the tract as applied for (Figure 2-4). 

Under Alternative 2, 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. 

Under Alternative 2, the area BLM is evaluating adding to the tract as applied 

for includes the following lands: 

T.43N., R.71W., 6th PM, Campbell County, Wyoming

Section 6: Lots 8, 15, 16, and 23; 163.05 acres 

T.44N., R.71W., 6th PM, Campbell County, Wyoming

Section 15: Lots 9 through 16; 326.83 acres 

Section 20: Lots 9, 10, 14, and 15; 161.38 acres 

Section 21: Lots 1 through 16; 639.69 acres 

Section 22: Lots 1 through 8; 320.85 acres 

Section 28: Lot 4; 41.00 acres 

Section 29: Lots 1 through 4; 159.36 acres 

Section 30: Lots 5, 12, 13, and 20; 157.29 acres 

Section 31: Lots 5, 12, 13, and 20; 162.40 acres 

Total: 2,131.85 acres

The legal description of the Alternative 2 BLM reconfiguration (Figure 2-4) for 

the West Jacobs Ranch LBA Tract is as follows: 

T.43N., R.71W., 6th PM, Campbell County, Wyoming

Section 3: Lots 2 and 5 through 19; 638.38 acres 

Section 4: Lots 5 through 20; 639.50 acres 

Section 5: Lots 5 through 20; 636.67 acres 

Section 6: Lots 8, 15, 16, and 23; 163.05 acres 

T.44N., R.71W., 6th PM, Campbell County, Wyoming

Section 15: Lots 9 through 16; 326.83 acres 

Section 20: Lots 9, 10, 14, and 15; 161.38 acres 

Section 21: Lots 1 through 16; 639.69 acres 

Section 22: Lots 1 through 16; 647.84 acres 

Section 27: Lots 1 through 16; 658.21 acres 

Section 28: Lots 1 through 16; 649.43 acres 

Section 29: Lots 1 through 15 and SE1⁄4SE1⁄4; 637.46 acres 

Section 30: Lots 5, 12, 13, and 20; 157.29 acres 

Section 31: Lots 5, 12, 13, and 20; 162.40 acres 

Section 32: Lots 1 through 15 and SW1⁄4SE1⁄4; 643.83 acres 

Section 33: Lots 1 through 15 and NE1⁄4SE1⁄4 ; 653.02 acres 

Section 34: Lots 1 through 16; 661.24 acres 

Total: 8,076.22 acres
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-45 

Land descriptions and acreage are based on the BLM Status of Public Domain 

Land and Mineral Titles approved Master Title Plats as of August 30, 2005 and 

September 7, 2007 and Coal Plats as of September 7, 2007. 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. 

ALC estimates that the LBA tract reconfigured under Alternative 2 (the BLM 

study area) includes approximately 1,269.0 million tons of in-place coal 

reserves. As discussed in Sections 1.1, 1.5, and 2.4.1 and shown in Figure 2-

4, a portion of Wyoming State Highway 450 borders the entire southern edge of 

the above-described alternate tract configuration. Therefore, some of the coal 

included in the West Jacobs Ranch LBA Tract under this alternative is overlain 

by Highway 450 and SMCRA prohibits surface mining operations on lands 

within 100 feet of the outside line of the ROW for a public road (SMCRA Section 

522(e)(4) and 30 CFR 761.11(d)). If ALC obtains approval from the WYDOT to 

move this state highway, the exception to the prohibition on mining within the 

road ROW and buffer zone could be applied and the unsuitability 

determination could be reconsidered. In that case, ALC would be able to 

recover the coal underlying Wyoming State Highway 450, its ROW and 

associated buffer zone. If ALC does not obtain approval to relocate the 

highway, the coal underlying the road, its ROW, and associated buffer zone 

would remain unsuitable for mining and would not be recovered. 

TBCC’s Northwest Rail Loop Amendment Area, which lies north of Wyoming 

State Highway 450 and west of the Hilight Road, is entirely within Black 

Thunder Mine’s current permit area (Figures 2-3 and 2-4). Black Thunder 

Mine completed the construction of a new train loadout facility, including a 

railroad spur and two storage silos, within their Northwest Rail Loop 

Amendment Area in 2008. TBCC’s new railroad spur, train loadout facility, 

and two storage silos are located entirely within the West Jacobs Ranch LBA 

Tract. It may not be economically feasible to move the railroad spur and the 

coal processing and storage facilities to recover all the coal at this time, but 

may be economically feasible at some point in the future, if the coal is leased. 

As discussed in Section 1.5, some of the coal included in the above-described 

alternative tract configuration has been determined unsuitable for mining due 

to the presence of the BNSF & UP rail line, which borders the entire eastern 

side of the LBA study area (Figure 2-4). 

As shown in Figure 2-4, a portion of Hilight Road (Campbell County Road 52) 

lies west of and adjacent to the BNSF & UP rail line ROW, and also borders the 

entire eastern edge of the above described lands. Therefore, some of the coal 

included in the West Jacobs Ranch LBA Tract under this alternative is overlain 

by the Hilight Road and SMCRA prohibits surface mining operations on lands 

within 100 feet of the outside line of the ROW for a public road. The coal 

underlying this county road, its ROW, and associated 100-foot buffer zone has 

been determined to be unsuitable for mining in accordance with SMCRA and as 

specified under Unsuitability Criterion 3. There is an exception to this 
2.0 Proposed Action and Alternatives 

2-46 Final EIS, Wright Area Coal Lease Applications

prohibition in the regulations at 30 CFR 761.11(d)(2), which can be applied if 

the appropriate road authority (Campbell County Board of Commissioners) 

allows the road to be relocated or closed. If ALC obtains approval from the 

Campbell County Board of Commissioners to close or move this county road, 

the exception to the prohibition on mining within the road ROW and buffer 

zone could be applied and the unsuitability determination could be 

reconsidered. In that case, ALC would be able to recover the coal underlying 

Hilight Road, its ROW, and associated buffer zone. If ALC does not obtain 

approval to move or close the county road, the coal underlying the road, its 

ROW, and associated buffer zone would remain unsuitable for mining and 

would not be recovered. 

If State Highway 450 and Hilight Road are not moved or closed, ALC estimates 

that the BLM study area tract (Figure 2-4) includes approximately 1,014.0 

million tons of mineable coal reserves. Using ALC’s projected recovery factor of 

90 percent of the mineable coal reserves, about 912.6 million tons of the 

mineable coal would be recoverable. Although these lands would not be mined, 

they are included in the alternative tract configuration to allow maximum 

recovery of all the mineable coal that is adjacent to but outside of the public 

road 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, a stipulation will be attached to the lease stating 

that no mining activity may be conducted in the portions of the leased tract 

within the Wyoming State Highway 450 and Hilight Road ROWs and associated 

buffer zones unless approval is obtained from the appropriate public road 

authority to relocate or close the roads. 

ALC estimates an average annual coal production rate of 40 mmtpy for the 

Jacobs Ranch Mine after 2008. With the West Jacobs Ranch LBA Tract 

reconfigured under Alternative 2, coal production at the Jacobs Ranch Mine 

would continue for approximately 32.4 years beyond 2008. The study area 

tract accounts for approximately 22.8 years of the mine life extension. 

If the Hilight Road is moved or closed, and if relocation of Wyoming State 

Highway 450 were approved, ALC estimates that an added 255.0 million tons of 

coal would be mineable in the BLM study area tract. 

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 may not be in agreement with the 

mineable coal reserve and coal quality estimates provided by the applicant. 

Under the Preferred Alternative (Alternative 2), BLM’s estimate will be 

published in the sale notice for the tract, if it is offered for sale. 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-47 

2.5 North Porcupine LBA Tract 

2.5.1 North Porcupine LBA Tract Proposed Action

Under the Proposed Action for the North Porcupine LBA Tract, the tract as 

applied for by BTU Western Resources, Inc. (BTU) 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 North 

Porcupine lease application (Figure 2-5). The Proposed Action assumes that 

BTU would be the successful bidder on the North Porcupine LBA Tract, if it is 

offered for sale. 

The legal description of the proposed North Porcupine LBA Tract coal lease 

lands as applied for by BTU under the Proposed Action is as follows: 

T.42N., R.70W., 6th PM, Campbell County, Wyoming

Section 19: Lots 13 through 20; 296.94 acres 

Section 20: Lots 9 through 16; 328.00 acres 

Section 21: Lots 9 through 16; 329.54 acres 

Section 22: Lots 9 through 16; 327.74 acres 

Section 26: Lots 3 through 6 and 9 through 16; 496.64 acres 

Section 27: Lots 1 through 16; 664.48 acres 

Section 28: Lots 1 through 4; 165.98 acres 

Section 29 Lots 1 through 4; 164.30 acres 

Section 30: Lots 5 through 8; 147.79 acres 

T.42N., R.71W., 6th PM, Campbell County, Wyoming

Section 22: Lots 10 through 15 and 21 through 24; 323.49 acres 

Section 23: Lots 9 through 16; 324.94 acres 

Section 24: Lots 9 through 16; 325.82 acres 

Section 25: Lots 1 through 4; 162.96 acres 

Section 26: Lots 1 through 6 and 11 through 14; 404.09 acres 

Section 27: Lots 2 through 6, 9, 12, and 15 through 30; 649.42 acres 

Section 34: Lots 1 through 3 and 6 through 11; 360.46 acres 

Section 35: Lots 3 through 6 and 11 through 14; 323.19 acres 

Total: 5,795.78 acres

Land descriptions and acreage are based on the BLM Status of Public Domain 

Land and Mineral Titles approved Master Title Plats as of September 7, 2007 

and September 20, 2007 and Coal Plats as of September 7, 2007 and 

September 20, 2007. The coal estate included in the tract described above is 

federally owned. Much of the surface (approximately 72 percent, or 4,186 

acres) of the tract as applied for includes lands on the TBNG, which is 

administered by the USFS. The ownership of the surface and oil and gas 

estates is discussed in Section 3.11. 
2.0 Proposed Action and Alternatives 

2-48 Final EIS, Wright Area Coal Lease Applications

As discussed in Section 1.5, and as shown in Figure 2-5, some of the coal 

included in the above-described lands in the North Porcupine LBA Tract has 

been determined to be unsuitable for mining in accordance with SMCRA and as 

specified under Unsuitability Criterion 2 (43 CFR 3461) due to the presence of 

the BNSF & UP railroad line, which crosses the western side of the LBA tract. 

The coal underlying the railroad ROW and an associated 100-foot buffer zone is 

also not considered by Powder River Coal (PRC), operator of the North Antelope 

Rochelle Mine, to be mineable at this time because the cost that would be 

associated with moving the railroad tracks would make it economically 

unfeasible to recover the underlying coal. Although the federal coal underlying 

the railroad ROW and associated buffer zone would not be mined, it is 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. PRC estimates that approximately 65.8 million 

tons of mineable coal included in the North Porcupine LBA Tract as applied for 

is located within a layback buffer zone that PRC has determined extends 1,000 

feet on either side of the railroad centerline. 

Some of the coal included in the above-described lands is not currently 

considered by PRC to be mineable due to the presence of the Teckla Electric 

Power Substation, which is located adjacent to the North Porcupine tract in the 

NE1⁄4NE1⁄4 of Section 3, T.41N., R.71W. Due to the requirement that no 

blasting operations be conducted within 500 feet of the substation, the coal 

underlying the southwestern diagonal half of Lot 13, Section 35, T.42N., 

R.71W., is not considered mineable at this time by PRC because the cost that 

would be associated with moving the substation would make it economically 

unfeasible to recover. PRC estimates that approximately 2.7 million tons of 

mineable coal included in the North Porcupine LBA Tract is located within the 

Teckla Substation layback buffer zone. Although the federal coal underlying 

the substation buffer zone would not be mined, it is included in the tract to 

allow maximum recovery of all of the mineable coal that is adjacent to but 

outside of the substation buffer zone and to comply with the coal leasing 

regulations that do not allow leasing of less than 10-acre aliquot parts. 

As indicated in Section 1.5 and as shown in Figure 2-5, some of the coal 

included in the above-described lands in the North Porcupine LBA Tract is 

overlain by the Antelope Road (Campbell County Road 4), which crosses a 

portion of the LBA tract, the Matheson Road (Campbell County Road 70), 

which borders a portion of the LBA tract, and the Mackey Road (Campbell 

County Road 69), which borders and crosses a portion of the LBA tract. 

SMCRA prohibits surface mining operations on lands within 100 feet of the 

outside line of the ROW for a public road (SMCRA Section 522(e)(4) and 30 CFR 

761.11(d)). The coal that is underlying these public road ROWs and associated 

100-foot buffer zones has been determined to be unsuitable for mining in 

accordance with SMCRA and as specified under Unsuitability Criterion 3 (43 

CFR 3461). There is an exception to this prohibition in the regulations at 

SMCRA Section 522(e)(4) and 30 CFR 761.11(d)(2), which can be applied if the 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-49 

appropriate road authority (Campbell County Board of Commissioners) allows 

the roads to be relocated or closed. 

As discussed in Section 1.1, PRC has obtained approval from the Campbell 

County Board of Commissioners to close and relocate the portions of Antelope 

and Matheson roads that cross and border the North Porcupine LBA Tract as 

applied for. The exception to Unsuitability Criterion 3 is therefore applicable 

and the coal underlying those two county road ROWs and associated buffer 

zones would be recoverable if a lease is issued for the North Porcupine LBA 

Tract. If PRC obtains approval from the Campbell County Board of 

Commissioners to close and relocate the Mackey Road, which crosses and 

borders the North Porcupine tract, the exception to the prohibition on mining 

within that road’s ROW and buffer zone could be applied and the unsuitability 

determination could be reconsidered. In that case, PRC would be able to 

recover the coal underlying the Mackey Road ROW and associated buffer zone. 

If PRC does not obtain approval to close and relocate the Mackey Road, the coal 

underlying its ROW and buffer zone would remain unsuitable for mining and 

would not be recovered. If the Mackey Road is moved or closed, PRC estimates 

that an added 34.9 million tons of coal would be mineable in the North 

Porcupine LBA Tract. 

The federal coal underlying the Mackey Road, its ROW, and adjacent 100-foot 

buffer zone is included in the as applied for tract configuration because it 

would allow maximum recovery of all the mineable coal adjacent to but outside 

of the road ROW and associated buffer zone, and to comply with the coal 

leasing regulations that do not allow leasing of less than 10-acre aliquot parts 

if the road is not moved; it would also allow recovery of the coal under the road 

if it is closed or relocated. If a lease is issued for this tract, a stipulation will be 

attached to the lease stating that no mining activity may be conducted in the 

portions of the lease within 100 feet of either the BNSF & UP rail line ROW or 

Mackey Road ROW. The stipulation would allow recovery of the coal under 

Mackey Road if approval is obtained from the appropriate authority to move or 

close the road. 

PRC estimates that the North Porcupine LBA Tract as applied for includes 

approximately 756.9 million tons of in-place coal reserves. If the Mackey Road 

is not closed or relocated, PRC estimates that the North Porcupine LBA Tract 

as applied for contains approximately 653.5 million tons of mineable coal 

reserves. Based on historical recovery practices, PRC assumes that about 92 

percent of that coal, or approximately 601.2 million tons of coal, would be 

recovered from the North Porcupine LBA Tract as applied for. PRC estimates 

that approximately 103.4 million tons of coal (which is about 14 percent of the 

in-place coal within the North Porcupine LBA Tract as applied for) would not be 

mineable because of the public road ROW and the layback buffers for the 

substation and rail line. 

The North Porcupine LBA Tract would be mined as an integral part of the North 

Antelope Rochelle Mine under the Proposed Action. Since the North Porcupine 
2.0 Proposed Action and Alternatives 

2-50 Final EIS, Wright Area Coal Lease Applications

LBA Tract would be an extension of the existing North Antelope Rochelle Mine, 

the facilities and infrastructure would be the same as those identified in the 

WDEQ/LQD Mine Permit 569 Term T7, approved July 28, 2009 and the BLM 

R2P2, which was approved February 28, 2007. 

North Antelope Rochelle Mine’s currently approved air quality permits (Permit 

Numbers MD-1172, MD-1309, MD-1331, and MD-6375) from the WDEQ/AQD 

allow up to 140 million tons of coal per year to be mined. The North Antelope 

Rochelle Mine produced: 

• 80.1 million tons of coal in 2003, 

• 82.5 million tons of coal in 2004, 

• 82.7 million tons of coal in 2005, 

• 88.5 million tons of coal in 2006, 

• 91.5 million tons of coal in 2007, and 

• 97.6 million tons of coal in 2008 

(Wyoming Department of Employment 2003, Shamley 2008a and 2010). 

As of December 31, 2008, a total of approximately 1,230.8 million tons of coal 

had been mined from within the current permitted area of the mine. 

PRC estimates an average annual coal production rate of 95 mmtpy for the 

North Antelope Rochelle Mine for the years beyond 2008. If BTU acquires the 

North Porcupine LBA Tract as applied for, a total of approximately 1,535.0 

million tons of coal would be recovered from the existing leases and the North 

Porcupine LBA Tract after January 1, 2009, with an estimated 601.2 million 

tons coming from the LBA tract, as discussed above. With the North Porcupine 

LBA Tract as applied for, coal production at the North Antelope Rochelle Mine 

would continue for approximately 16.2 years beyond 2008, and PRC 

anticipates that the current work force of 1,150 persons would remain the 

same. The LBA tract accounts for approximately 6.3 years of the mine life 

extension. 

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 

and average quality of the coal 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 and average 

quality of the coal included in the tract will be published in the sale notice if 

the tract is offered for sale. 

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, and any public utility lines and oil and gas pipelines 

would be relocated as necessary. 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-51 

The first step of the mining process is soil salvage with suitable heavy 

equipment, such as rubber-tired scrapers. During initial pit development, soil 

is placed in temporary stockpiles for later use in final pit closure and 

reclamation. Whenever possible, direct haulage of soil from salvage areas 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 

would again be used to haul and redistribute the stockpiled topsoil on regraded 

areas. 

The North Antelope Rochelle Mine is one of several mines currently operating in 

the PRB where the coal seams are notably thick and the overburden is 

relatively thin. Mining has been and would continue to be conducted in three 

semi-independent pits (West, North, and East Pits). The design of the North 

Antelope Rochelle Mine seeks to confine disturbance to the active mine blocks. 

After soil salvage operations are complete, blast holes are drilled down through 

the overburden to the top of the upper-most mineable coal seam. The drill 

holes are then loaded with explosives (ANFO) and detonated to fragment the 

overburden to facilitate efficient excavation. As overburden is removed, most 

would be directly placed into the previous empty pit where coal has been 

removed. The mine’s current method of overburden removal employs a truck 

and shovel pre-benching operation in advance of a dragline. Cast blasting is 

also employed to supplement dragline productivity. Other equipment used 

during overburden removal and backfilling includes dozers, scrapers, 

excavators, front-end loaders, graders, and water trucks. While increasing 

overburden depths in the North Porcupine tract would require an increasing 

percentage of overburden material to be moved by the truck and shovel prebenching operation, overburden removal methods would remain essentially the 

same as the current operation. However, once operations have moved west of 

the BNSF & UP rail line, the mine may utilize an alternative method of 

overburden removal and handling for the box cut and pre-benching operations. 

In combination with the conventional truck/shovel and dragline system, in-pit 

overburden crushing and overland conveying methods may be employed to 

move and emplace overburden materials to open pits areas east of the rail line 

and/or stockpile locations off of the coal lease area. 

Exposed coal seams have been and would continue to be cleaned with a dozer, 

drilled and blasted to facilitate efficient excavation. Coal removal is currently 

accomplished with the conventional truck and shovel method and then 

transported to one of four truck dump/crusher locations. Two of these truck 

dumps are remotely located from the final coal preparation plant and unit train 

loadout facilities. Coal haul roads would be temporary structures built within 

the mine areas. Coal is also transported from the near-pit crushers by 

overland conveyor to the final preparation plant and storage facilities. Some 

changes to the coal handling system infrastructure may be implemented in the 

future. For example, an additional remote coal truck dump/near-pit crusher 

and overland conveyor may be constructed west of the BNSF & UP railroad 

line. 
2.0 Proposed Action and Alternatives 

2-52 Final EIS, Wright Area Coal Lease Applications

Chapter 4, Section 2(b)(i) of the WDEQ/LQD Coal Rules requires that rough 

backfilling and grading follow coal removal as closely as possible based on the 

mining conditions (WDEQ/LQD 2009). Replaced (backfilled) overburden is 

graded to approximate the original land surface contour, as required by WDEQ 

and OSM rules. Elevations consistent with the approved PMT plan are 

established as quickly as possible to reconstruct a stable landscape and restore 

drainage. 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. Backfilled and recontoured overburden is sampled and 

analyzed to verify suitability as subsoil. Should unsuitable backfill materials 

be encountered (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), mitigation by 

additional soil depth, excavation and burial, or other special handling to 

remove them from the root zone would occur. Prior to soil distribution, 

regraded backfill is scarified to relieve compaction. Soil is redistributed on 

recontoured backfill using rubber-tired scrapers. Once a seedbed has been 

formed the reclaimed areas are revegetated using native grasses, forbs, and 

shrubs that are consistent with the postmining land use. According to the 

most recent OSM evaluation of the Wyoming coal mining industry, the 

reclamation to disturbance ratio in 2008 was approximately 86 percent (4,703 

acres reclaimed vs. 5,497 acres disturbed) (OSM 2009). 

Coal would be produced from two mineable seams within the North Porcupine 

LBA Tract. PRC refers to these seams as the Wyodak-Anderson 1 and the 

Wyodak-Anderson 2. These two coal seams are separated by a shale parting 

that averages approximately 17 feet thick within North Antelope Rochelle 

Mine’s existing lease areas. However, there is no shale parting in the LBA tract 

as applied for, and the combined Wyodak-Anderson 1 and 2 seam averages 

approximately 75 thick. Coal would be mined at several working pit faces to 

enable blending of the 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. 

Mining efficiency and air quality protection are and would continue to be 

facilitated by extensive use of near-pit crushers and overland conveyors. There 

are four existing crushing facilities within the existing permit area. The 

overland conveyors are covered by dust hoods and all coal transfer points on 

conveyor belts and the truck dump hoppers are controlled by PECs, 

fogger/spray systems, or stilling sheds. There are five existing storage silos 

and one covered storage slot. While sufficient capacity exists to produce at the 

permitted level, future changes in coal handling and processing facilities may 

be constructed to improve operating efficiency and air quality protection. 

The North Antelope Rochelle Mine has a current full-time work force of 1,150 

persons. If BTU acquires the North Porcupine LBA Tract under the Proposed 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-53 

Action, they anticipate that employment levels would remain the same for the 

additional 6.3 years that it would take to mine the coal included in the tract. 

As discussed in Chapter 1, the North Porcupine LBA Tract is adjacent to 

existing leases at the North Antelope Rochelle Mine, but is not adjacent to any 

of the other existing mines in this area (Figure 1-1). If a company other than 

BTU was to acquire the tract, the rate of coal production, mining sequence, 

equipment, and facilities would be different than if BTU acquired the tract as a 

maintenance lease, as described above. However, the area of disturbance and 

the impacts of removing the coal would not be substantially different from the 

area of disturbance and the impacts of PRC mining the tract. 

2.5.2 North Porcupine LBA Tract Alternative 1

Under the North Porcupine LBA Tract Alternative 1, the No Action Alternative, 

BTU’s application to lease the coal included in the North Porcupine 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 nor 

employment on the existing leases at the North Antelope Rochelle Mine. The 

North Antelope Rochelle Mine currently leases approximately 16,666 acres of 

federal coal and 1,400 acres of state coal, all of which are within the existing 

North Antelope Rochelle Mine permit boundary. A total of approximately 

27,443 acres will eventually be affected in mining the current leases. If the 

North Porcupine LBA Tract is not leased, PRC estimates that the annual 

production at the North Antelope Rochelle Mine after 2008 would average 95 

million tons, and the average full-time employment level is expected to remain 

at 1,150 persons. Mining would continue at the North Antelope Rochelle Mine 

for approximately 9.9 years. Portions of the surface of the LBA tract will be 

disturbed by the North Antelope Rochelle Mine 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 the North Porcupine 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 North Porcupine 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. This tract includes enough coal reserves to economically justify mining 

by a new operation, and the coal reserves included in the tract could 

potentially be combined with unleased federal coal to the north, south and/or 

west to create a larger tract that could be mined by a new operation in the 

future. 
2.0 Proposed Action and Alternatives 

2-54 Final EIS, Wright Area Coal Lease Applications

2.5.3 North Porcupine LBA Tract Alternative 2--Preferred Alternative

Under Alternative 2 for the North Porcupine LBA Tract, BLM would reconfigure 

the tract, 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 (Appendix D). Alternative 2, 

holding a competitive coal sale for a modified tract, is BLM’s preferred 

alternative. 

Alternative 2 for the North Porcupine LBA Tract assumes that BTU 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 North Antelope 

Rochelle 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 North Porcupine LBA Tract consists of a single block of 

federal coal. In order to evaluate the potential that an alternate configuration 

of the tract would provide for more efficient recovery of the federal coal, 

increase competitive interest in the North Porcupine 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 

northern and southwestern edges of the tract as applied for (Figure 2-5). 

Under Alternative 2, 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. 

Under Alternative 2, the area BLM is evaluating adding to the tract as applied 

for includes the following lands: 

T.42N., R.70W., 6th PM, Campbell County, Wyoming

Section 19: Lots 9 through 12; 149.02 acres 

Section 20: Lots 5 through 8; 162.93 acres 

Section 21: Lots l through 8; 330.71 acres 

Section 22: Lots 3 through 6; 163.80 acres 

T.42N., R.71W., 6th PM, Campbell County, Wyoming

Section 22: Lots 5 through 7, 19, and 20; 162.70 acres 

Section 23: Lots 5 through 8; 162.51 acres 

Section 24: Lots 5 through 8; 163.30 acres 

Section 34: Lots 4, 5, and 12 through 16; 276.04 acres 

Total: 1,572.01 acres

The legal description of the Alternative 2 BLM reconfiguration (Figure 2-5) for 

the North Porcupine LBA Tract is as follows: 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-55 

T.42N., R.70W., 6th PM, Campbell County, Wyoming

Section 19: Lots 9 through 20; 445.96 acres 

Section 20: Lots 5 through 16; 490.93 acres 

Section 21: Lots 1 through 16; 660.25 acres 

Section 22: Lots 3 through 6 and 9 through 16; 491.54 acres 

Section 26: Lots 3 through 6 and 9 through 16; 496.64 acres 

Section 27: Lots 1 through 16; 664.48 acres 

Section 28: Lots 1 through 4; 165.98 acres 

Section 29 Lots 1 through 4; 164.30 acres 

Section 30: Lots 5 through 8; 147.79 acres 

T.42N., R.71W., 6th PM, Campbell County, Wyoming

Section 22: Lots 5 through 7, 10 through 15, and 

 19 through 24; 486.19 acres 

Section 23: Lots 5 through 16; 487.45 acres 

Section 24: Lots 5 through 16; 489.12 acres 

Section 25: Lots 1 through 4; 162.96 acres 

Section 26: Lots 1 through 6 and 11 through 14; 404.09 acres 

Section 27: Lots 2 through 6, 9, 12, and 15 through 30; 649.42 acres 

Section 34: Lots 1 through 16; 636.50 acres 

Section 35: Lots 3 through 6 and 11 through 14; 323.19 acres 

Total: 7,366.79 acres

Land descriptions and acreage are based on the BLM Status of Public Domain 

Land and Mineral Titles approved Master Title Plats as of September 7, 2007 

and September 20, 2007 and Coal Plats as of September 7, 2007 and 

September 20, 2007. The coal estate included in the tract described above is 

federally owned. Much of the surface (approximately 72 percent, or 5,289.6 

acres) of the BLM study area includes lands on the TBNG, which is 

administered by the USFS. The ownership of the surface and oil and gas 

estates is discussed in Section 3.11. 

PRC estimates that the LBA tract reconfigured under Alternative 2 (the BLM 

study area) includes approximately 955.8 million tons of in-place coal reserves. 

As discussed in Sections 1.5, and 2.5.1, some of the coal included in the 

above-described alternative tract configuration is not currently considered by 

PRC to be mineable due to the presence of the BNSF & UP rail line ROW and 

associated 100-foot buffer zone, which crosses the BLM study area (Figure 2-

5). The coal that is located within the BNSF & UP railroad ROW and associated 

buffer zone has been determined to be unsuitable for mining under Coal 

Unsuitability Criterion Number 2 and would not be recoverable. Within the 

BLM study area, PRC estimates that approximately 95.2 million tons of 

mineable coal is located within a layback buffer zone that extends 1,000 feet on 

either side of the railroad centerline. 

As discussed in Section 2.5.1, some of the coal included in the above-described 

lands is not currently considered by PRC to be mineable due to the 
2.0 Proposed Action and Alternatives 

2-56 Final EIS, Wright Area Coal Lease Applications

requirement that no blasting operations be conducted within 500 feet of the 

Teckla Electric Power Substation, which is located in the NE1⁄4NE1⁄4 of Section 

3, T.41N., R.71W. Therefore, the coal underlying the substation buffer zone is 

not considered mineable at this time by PRC because the cost that would be 

associated with moving the substation would make it economically unfeasible 

to recover. 

As discussed in Sections 1.5 and 2.5.1 and shown in Figure 2-5, some of the 

coal in the above-described alternative tract configuration is overlain by the 

Antelope, Matheson, and Mackey roads (Campbell County roads 4, 70, and 69, 

respectively). The coal that is underlying these public road ROWs and 

associated 100-foot buffer zones extending on either side of the ROWs has been 

determined to be unsuitable for mining in accordance with SMCRA and as 

specified in coal leasing Unsuitability Criterion Number 3 (43 CFR 3461) and 

would not be recoverable. There is an exception to this prohibition to mine the 

coal underlying the public road ROWs and associated buffer zones that can be 

applied if the appropriate public road authority allows the road to be relocated 

or closed (SMCRA Section 522(e)(4) and 30 CFR 761.11(d)(2)). PRC has 

currently obtained approval from the Campbell County Board of 

Commissioners to close and relocate the portion of Antelope Road that crosses 

the BLM study area and Matheson Road that crosses and borders the North 

Porcupine LBA Tract as applied for. However, PRC has not obtained approval 

from the County Commissioners to close and relocate the portion of Matheson 

Road that borders lands added by the BLM study area and would not seek 

approval because this portion of the road lies within the BNSF & UP railroad 

buffer zone, and because it provides access to the Teckla Electric Power 

Substation. PRC has not yet obtained approval from the County 

Commissioners to close and relocate the portion of Mackey Road that crosses 

the BLM study area. If PRC obtains approval from the Campbell County Board 

of Commissioners to close and relocate Mackey Road, which crosses and 

borders the BLM study area, the exception to the prohibition on mining within 

the road’s ROW and buffer zone could be applied and the unsuitability 

determination could be reconsidered. In that case, PRC would be able to 

recover the coal underlying the Mackey Road ROW and associated buffer zone. 

If PRC does not obtain approval to close and relocate the Mackey Road, the coal 

underlying its ROW and buffer zone would remain unsuitable for mining and 

would not be recovered. 

If the above-described portions of the Matheson and Mackey roads are not 

closed or relocated, PRC estimates that the BLM study area tract (Figure 2-5) 

includes approximately 810.2 million tons of mineable coal reserves. Using 

PRC’s projected recovery factor of 92 percent of the mineable coal reserves, 

about 745.4 million tons of the mineable coal would be recoverable. At the 

average annual production rate of 95 mmtpy, mining this coal would extend 

the life of the mine by about 7.8 additional years. PRC estimates that 

approximately 145.6 million tons of coal would not be mineable within the BLM 

study area due to the presence of the railroad and public road ROWs and 

associated buffer zones and the Teckla Substation buffer zone. Although these 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-57 

lands would not be mined, they are included in BLM’s study area (the preferred 

alternative tract configuration) to allow maximum recovery of all the mineable 

coal that is adjacent to but outside of the railroad and public road ROWs and 

associated buffer zones and the electric substation buffer zone 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 tract within the BNSF & UP railroad and pubic road ROWs and 

associated buffer zones. The stipulations would also state that mining within 

the public road ROWs and buffer zones may be conducted if approval is 

obtained from the appropriate public road authority to relocate or close the 

roads. 

If the Mackey Road is moved or closed, PRC estimates that an added 47.7 

million tons of coal would be mineable in the BLM study area tract under 

Alternative 2. 

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 may not be in agreement with the 

mineable coal reserve and coal quality estimates provided by the applicant. 

Under the Preferred Alternative (Alternative 2), BLM’s estimate will be 

published in the sale notice for the tract, if it is offered for sale. 

2.6 South Porcupine LBA Tract 

2.6.1 South Porcupine LBA Tract Proposed Action

Under the Proposed Action for the South Porcupine LBA Tract, the tract as 

applied for by BTU 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 South Porcupine lease application (Figure 2-6). 

The Proposed Action assumes that BTU would be the successful bidder on the 

South Porcupine LBA Tract, if it is offered for sale. 

The legal description of the proposed South Porcupine LBA Tract coal lease 

lands as applied for by BTU under the Proposed Action is as follows: 

T.41N., R.70W., 6th PM, Campbell County, Wyoming

Section 7: Lots 7 through 10 and 15 through 18; 320.94 acres 

Section 18: Lots 6 through 11 and 14 through 19; 479.71 acres 

T.41N., R.71W., 6th PM, Campbell County, Wyoming

Section 1: Lots 5 through 20; 638.15 acres 

Section 12: Lots 1 through 16; 678.52 acres 

Section 13: Lots 1 through 16; 668.93 acres 

Section 14: Lots 1, 8, 9, and 16; 154.62 acres 
2.0 Proposed Action and Alternatives 

2-58 Final EIS, Wright Area Coal Lease Applications

Section 23: Lot 1 and N1⁄2 of Lot 8; 59.81 acres 

Section 24: Lots 2 through 4 and N1⁄2 of Lots 5, 6 and 7; 185.28 acres 

Total: 3,185.96 acres

Land descriptions and acreage are based on the BLM Status of Public Domain 

Land and Mineral Titles approved Master Title Plats as of September 6, 2007 

and Coal Plats as of September 6, 2007. The coal estate included in the tract 

described above is federally owned. Roughly half of the surface (approximately 

51 percent or 1,637.2 acres) of the tract as applied for includes lands on the 

TBNG, which is administered by the USFS. The ownership of the surface and 

oil and gas estates is discussed in Section 3.11. 

As discussed in Section 1.5 and as shown in Figure 2-6, some of the coal in the 

above-described lands in the South Porcupine LBA Tract is not mineable due to 

the presence of the BNSF & UP railroad ROW and associated 100-foot nodisturbance buffer zone. The rail line lies west of and adjacent to the South 

Porcupine tract, and like the North Porcupine tract, the coal underlying 

portions of the railroad ROW and associated 100-foot buffer zone in this area 

has been determined by the BLM to be unsuitable for mining according to the 

coal leasing Unsuitability Criterion 2 (43 CFR 3461). Although the federal coal 

underlying the railroad ROW and associated buffer zone has been determined 

to be unsuitable for mining and would therefore not be recovered, it is included 

in the LBA 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. PRC estimates that approximately 13.8 million 

tons of mineable coal included in the South Porcupine LBA Tract as applied for 

is located within a layback buffer zone that extends 1,000 feet east of the 

railroad centerline. If a lease is issued for this tract, a stipulation will be 

attached to the lease stating that no mining activity may be conducted within 

the BNSF & UP railroad ROW. 

As indicated in Section 1.5 and as shown in Figure 2-6, some of the coal 

included in the above-described lands in the South Porcupine LBA Tract is 

overlain by the Antelope Road (Campbell County Road 4), which crosses the 

LBA tract. SMCRA prohibits surface mining operations on lands within 100 

feet of the outside line of the ROW for a public road (SMCRA Section 522(e)(4) 

and 30 CFR 761.11(d)). The coal that is underlying this public road ROW and 

associated 100-foot buffer zone on both sides of the ROW has been determined 

to be unsuitable for mining in accordance with SMCRA and as specified under 

Unsuitability Criterion 3 (43 CFR 3461). There is an exception to this 

prohibition in the regulations at SMCRA Section 522(e)(4) and 30 CFR 

761.11(d)(2), which can be applied if the appropriate road authority (Campbell 

County Board of Commissioners) allows the road to be relocated or closed. As 

discussed in Section 1.1, PRC has obtained approval from the Campbell 

County Board of Commissioners to close and relocate a portion (approximately 

1.25 miles) of the Antelope Road that crosses the South Porcupine LBA Tract. 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-59 

PRC plans to apply for the approval of the County Commissioners to close or 

relocate the remaining length (approximately 2.25 miles) of Antelope Road that 

crosses the South Porcupine tract. If PRC obtains approval from the County 

Commissioners to close or relocate this section of the county road, the 

exception to the prohibition on mining within the road ROW and associated 

buffer zone could be applied and the unsuitability determination could be 

reconsidered. In that case, PRC would be able to recover the coal underlying 

the county road ROW and buffer zone. If PRC does not obtain approval to 

move or close the 2.25-mile section of Antelope Road, the coal underlying its 

ROW and buffer zone would remain unsuitable for mining and would not be 

recovered. 

The federal coal underlying the above-described 2.25-mile section of Antelope 

Road, its ROW, and adjacent buffer zone is included in the tract because it 

would allow maximum recovery of all the mineable coal adjacent to but outside 

of the road ROW and associated buffer zone if this length of road is not moved; 

it would also allow recovery of the coal under the road if it is moved or closed. 

If a lease is issued for this tract, a stipulation will be attached to the lease 

stating that no mining activity may be conducted within the Antelope Road 

ROW and 100-foot buffer zone for this 2.25-mile section unless approval is 

obtained from the appropriate authority to close or relocate the road. 

PRC estimates that the South Porcupine LBA Tract as applied for includes 

approximately 422.2 million tons of in-place coal. If the remaining 2.25-mile 

section of Antelope Road is not closed or relocated, PRC estimates that the 

South Porcupine LBA Tract as applied for contains approximately 336.6 million 

tons of mineable coal reserves. Based on historical recovery practices, PRC 

assumes that about 92 percent of that coal, or approximately 309.7 million 

tons of coal, would be recovered from the South Porcupine LBA Tract as 

applied for. 

The South Porcupine LBA Tract would be mined as an integral part of the 

North Antelope Rochelle Mine under the Proposed Action. Since the South 

Porcupine LBA Tract would be an extension of the existing North Antelope 

Rochelle Mine, the facilities and infrastructure would be the same as those 

identified in the WDEQ/LQD Mine Permit 569 Term T7, approved July 28, 

2009 and the BLM R2P2, which was approved February 28, 2007. 

North Antelope Rochelle Mine’s currently approved air quality permits from the 

WDEQ/AQD allow up to 140 million tons of coal per year to be mined. The 

North Antelope Rochelle Mine produced: 

• 80.1 million tons of coal in 2003, 

• 82.5 million tons of coal in 2004, 

• 82.7 million tons of coal in 2005, 

• 88.5 million tons of coal in 2006, 

• 91.5 million tons of coal in 2007, and 
2.0 Proposed Action and Alternatives 

2-60 Final EIS, Wright Area Coal Lease Applications

• 97.6 million tons of coal in 2008 

(Wyoming Department of Employment 2003, Shamley 2008a). 

As of December 31, 2008, a total of approximately 1,230.8 million tons of coal 

had been mined from within the current permitted area of the mine. 

PRC estimates an average annual coal production rate of 95 mmtpy for the 

North Antelope Rochelle Mine for the years beyond 2008. If BTU acquires the 

South Porcupine LBA Tract as applied for, a total of approximately 1,243.5 

million tons of coal would be recovered from the existing leases and the South 

Porcupine LBA Tract after January 1, 2009, with an estimated 309.7 million 

tons coming from the LBA tract, as discussed above. Based upon this estimate 

of recoverable reserves, about 27 percent of the in-place coal reserves included 

within the LBA tract would not be recovered under normal mining practices 

and due to the presence of the unmineable reserves within the railroad ROW 

and associated buffer zone and the 2.25-mile section of the Antelope Road 

ROW and associated buffer zone. With the South Porcupine LBA Tract, coal 

production at the North Antelope Rochelle Mine would continue for 

approximately 13.2 years beyond 2008. The LBA tract accounts for 

approximately 3.3 years of the mine life extension. 

If the remaining 2.25-mile section of Antelope Road is closed or relocated, PRC 

estimates that that an added 71.8 million tons of coal would be mineable in the 

South Porcupine LBA Tract. Based upon this estimate of recoverable reserves, 

about 11 percent of the in-place coal reserves included within the LBA tract 

would not be recovered under normal mining practices and due to the presence 

of the unmineable reserves within the railroad ROW and associated buffer 

zone. 

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 

and average quality of the coal 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 and average 

quality of the coal included in the tract will be published in the sale notice if 

the tract is offered for sale. 

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, and any public utility lines and oil and gas pipelines 

would be relocated as necessary. 

A brief description of PRC’s mining operation at the North Antelope Rochelle 

Mine, emphasizing the methods and equipment that are used to remove, 

handle, and reclaim overburden and soil, is included in Section 2.5.1. The 

methods and equipment used to mine the coal, and the facilities used to 

process and store coal are also described in Section 2.5.1. Coal would be 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-61 

produced from two mineable seams within the South Porcupine LBA Tract. 

PRC refers to these seams as the Wyodak-Anderson 1 and the WyodakAnderson 2, which have a combined average thickness of approximately 76 feet 

in the LBA tract. These two coal seams are separated by a shale parting that 

averages approximately 17 feet thick within the mine’s existing leases and 

approximately 10 feet thick within the South Porcupine LBA Tract. The mining 

and reclamation methods, coal handling, processing and storage facilities, and 

associated air quality protection measures would allow the North Antelope 

Rochelle Mine to produce at the currently permitted level. While sufficient 

capacity exists, future changes in facilities may be constructed to improve 

operating efficiency and air quality protection. 

The North Antelope Rochelle Mine has a current full-time work force of 1,150 

persons. If BTU acquires the South Porcupine LBA Tract under the Proposed 

Action, they anticipate that employment levels would remain the same for the 

additional 3.3 years that it would take to mine the coal included in the tract. 

As discussed in Chapter 1, BTU applied for the South Porcupine LBA Tract, 

but the tract is also adjacent to the Antelope Mine, operated by Antelope Coal 

Company (Figure 1-1). As a result, Antelope Coal Company is potentially in a 

position to mine the South Porcupine LBA Tract. If a company other than BTU 

was to acquire the tract, the rate of coal production, mining sequence, 

equipment, and facilities would be different than if BTU acquired the tract as a 

maintenance lease, as described above. However, the area of disturbance and 

the impacts of removing the coal would not be substantially different from the 

area of disturbance and the impacts of PRC mining the tract. 

2.6.2 South Porcupine LBA Tract Alternative 1

Under the South Porcupine LBA Tract Alternative 1, the No Action Alternative, 

BTU’s application to lease the coal included in the South Porcupine 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 nor 

employment on the existing leases at the North Antelope Rochelle Mine. The 

North Antelope Rochelle Mine currently leases approximately 16,666 acres of 

federal coal and 1,400 acres of state coal, all of which are within the existing 

North Antelope Rochelle Mine permit boundary. A total of approximately 

27,443 acres will eventually be affected in mining the current leases. If the 

South Porcupine LBA Tract is not leased, PRC estimates that the annual 

production at the North Antelope Rochelle Mine after 2008 would average 95 

million tons, and the average full-time employment level is expected to remain 

at 1,150 persons. Mining would continue at the North Antelope Rochelle Mine 

for approximately 9.9 years. Portions of the surface of the LBA tract would 

probably be disturbed by the North Antelope Rochelle Mine due to 

overstripping to allow coal to be removed from existing contiguous leases. 
2.0 Proposed Action and Alternatives 

2-62 Final EIS, Wright Area Coal Lease Applications

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 the South Porcupine 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 South Porcupine 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. This tract 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 to create a 

larger tract that could be mined by a new operation in the future. 

2.6.3 South Porcupine LBA Tract Alternative 2--Preferred Alternative

Under Alternative 2 for the South Porcupine LBA Tract, BLM would reconfigure 

the tract, 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 (Appendix D). Alternative 2, 

holding a competitive coal sale for a modified tract, is BLM’s preferred 

alternative. 

Alternative 2 for the South Porcupine LBA Tract assumes that BTU 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 North Antelope 

Rochelle 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 South Porcupine LBA Tract consists of a single block of 

federal coal. In order to evaluate the potential that an alternate configuration 

of the tract would provide for more efficient recovery of the federal coal, 

increase competitive interest in the South Porcupine 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 

western edge of the tract as applied for (Figure 2-6). Under Alternative 2, 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. 

Under Alternative 2, the area BLM is evaluating adding to the tract as applied 

for includes the following lands: 

T.41N., R.71W., 6th PM, Campbell County, Wyoming

Section 10: Lot 9; 41.20 acres 

Section 11: Lots 9 through 12 and 14 through 16; 283.80 acres 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-63 

Section 14: Lot 2 and E1⁄2 of Lot 7; 57.07 acres 

Total: 382.07 acres

The legal description of the Alternative 2 BLM reconfiguration (Figure 2-6) for 

the South Porcupine LBA Tract is as follows: 

T.41N., R.70W., 6th PM, Campbell County, Wyoming

Section 7: Lots 7 through 10 and 15 through 18; 320.94 acres 

Section 18: Lots 6 through 11 and 14 through 19; 479.71 acres 

T.41N., R.71W., 6th PM, Campbell County, Wyoming

Section 1: Lots 5 through 20; 638.15 acres 

Section 10: Lot 9; 41.20 acres 

Section 11: Lots 9 through 12 and 14 through 16; 283.80 acres 

Section 12: Lots 1 through 16; 678.52 acres 

Section 13: Lots 1 through 16; 668.93 acres 

Section 14: Lots 1, 2, E1⁄2 of 7, 8, 9, and 16; 211.69 acres 

Section 23: Lot 1 and N1⁄2 of Lot 8; 59.81 acres 

Section 24: Lots 2 through 4 and N1⁄2 of Lots 5, 6 and 7; 185.28 acres 

Total: 3,568.03 acres

Land descriptions and acreage are based on the BLM Status of Public Domain 

Land and Mineral Titles approved Master Title Plats as of September 6, 2007 

and Coal Plats as of September 6, 2007. The coal estate included in the tract 

described above is federally owned. A portion of the surface (approximately 46 

percent, or 1,637.6 acres) of the BLM study area includes lands on the TBNG, 

which is administered by the USFS. The ownership of the surface and oil and 

gas estates is discussed in Section 3.11. 

PRC estimates that the LBA tract reconfigured under Alternative 2 (the BLM 

study area) includes approximately 470.9 million tons of in-place coal reserves. 

As discussed in Sections 1.5, and 2.6.1, some of the coal included in the 

above-described alternative tract configuration is not currently considered by 

PRC to be mineable due to the presence of the BNSF & UP rail line ROW and 

associated 100-foot buffer zone, which crosses the BLM study area (Figure 2-

6). The coal that is located within the BNSF & UP railroad ROW and associated 

buffer zone has been determined to be unsuitable for mining under Coal 

Unsuitability Criterion Number 2 and would not be recoverable. Within the 

BLM study area, PRC estimates that approximately 30.3 million tons of 

mineable coal included in the South Porcupine LBA Tract configured under 

Alternative 2 is located within a layback buffer zone that extends 1,000 feet on 

either side of the railroad centerline. 

As discussed in Sections 1.5 and 2.6.1 and shown in Figure 2-6, some of the 

coal included in the above-described alternative tract configuration is overlain 

by the Antelope Road. The coal that is underlying this public road ROW and 
2.0 Proposed Action and Alternatives 

2-64 Final EIS, Wright Area Coal Lease Applications

associated 100-foot buffer zone extending on either side of the ROW has been 

determined to be unsuitable for mining in accordance with SMCRA and as 

specified in coal leasing Unsuitability Criterion Number 3 (43 CFR 3461) and 

would therefore not be recoverable. 

As discussed in Section 2.6.1, there is an exception to this prohibition to mine 

the coal underlying the public road ROW and associated buffer zone that can 

be applied if the appropriate public road authority allows the road to be 

relocated or closed (SMCRA Section 522(e)(4) and 30 CFR 761.11(d)(2)). As 

discussed in Section 1.1, PRC has obtained approval from the Campbell 

County Board of Commissioners to close and relocate a portion (approximately 

1.25 miles) of the Antelope Road that crosses the South Porcupine LBA Tract 

under the alternative tract configuration. PRC plans to apply for the approval 

of the County Commissioners to close or relocate the remaining length 

(approximately 2.25 miles) of the Antelope Road that crosses the BLM study 

area for the South Porcupine tract. If PRC obtains approval from the County 

Commissioners to close or relocate this section of the county road, the 

exception to the prohibition on mining within the road ROW and associated 

buffer zone could be applied and the unsuitability determination could be 

reconsidered. In that case, PRC would be able to recover the coal underlying 

the county road ROW and buffer zone. If PRC does not obtain approval to 

move or close the 2.25-mile section of Antelope Road, the coal underlying its 

ROW and buffer zone would remain unsuitable for mining and would not be 

recovered. 

Although these lands would not be mined, they are included in the alternative 

tract configuration to allow maximum recovery of all the mineable coal that is 

adjacent to but outside of the railroad and public road 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 tract within the BNSF & UP railroad 

and public road ROWs and associated buffer zones. The stipulations would 

also state that mining within the public road ROW and buffer zone may be 

conducted if approval is obtained from the appropriate public road authority to 

relocate or close the remaining 2.25-mile portion of the Antelope Road. 

If the remaining 2.25-mile section of Antelope Road is not closed or relocated, 

PRC estimates that the South Porcupine LBA Tract configured under 

Alternative 2 (BLM’s study area) includes approximately 368.8 million tons of 

mineable coal reserves. Using PRC’s projected recovery factor of 92 percent of 

the mineable coal reserves, about 339.3 million tons of the mineable coal would 

be recoverable. At the average annual production rate of 95 mmtpy, mining 

this coal would extend the life of the mine by about 3.6 additional years. PRC 

estimates that approximately 102.1 million tons of coal would not be mineable 

because of the railroad and public road ROWs and associated buffer zones. 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-65 

If the remaining 2.25-mile section of Antelope Road is closed or relocated, PRC 

estimates that an added 71.8 million tons of coal would be mineable in the 

BLM study area tract (BLM’s preferred tract configuration). 

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 may not be in agreement with the 

mineable coal reserve and coal quality estimates provided by the applicant. 

Under the Preferred Alternative (Alternative 2), BLM’s estimate will be 

published in the sale notice for the tract, if it is offered for sale. 

2.7 Alternatives Considered but not Analyzed in Detail

2.7.1 Alternative 4: New Mine Start

Under this alternative, as under the Proposed Actions and Alternatives 2 and 3, 

BLM would hold a separate, competitive, sealed-bid sale for the lands included 

in each LBA tract. Under this alternative, it is assumed, however, that the 

successful qualified bidder for a tract would be someone other than the 

applicant and that this bidder would plan to open a new mine to develop the 

coal resources in one or more of the LBA tracts (North Hilight Field, South 

Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and 

South Porcupine). 

BLM currently estimates that a tract would potentially need to include as much 

as 500 to 600 million tons of in-place 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 need to construct 

facilities capable of producing 30 mmtpy in order to take advantage of the 

economies of scale offered by the coal deposits in the PRB. Secondly, it is 

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, 

the West Jacobs Ranch and North Porcupine LBA Tracts as applied for include 

sufficient coal reserves to consider opening a new mine, while the three Hilight 

Field LBA Tracts as applied for and the South Porcupine LBA Tract as applied 

for do not. The North Hilight Field, West Hilight Field, West Jacobs Ranch, and 

North Porcupine LBA Tracts reconfigured under Alternative 2 (and Alternative 3 

for the West Hilight Field tract), each include sufficient coal reserves to support 

a new mine, while the South Hilight Field and South Porcupine tracts do not. 

Therefore, it is unlikely that a company or companies would lease the South 

Hilight Field or South Porcupine tracts in order to open a new mine. However, 

the other four LBA Tracts that are included in this EIS analysis do include 

sufficient coal reserves to support a new mine. 

A company or companies acquiring this coal for one or more new stand-alone 

mines 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 spurs), mining equipment, 
2.0 Proposed Action and Alternatives 

2-66 Final EIS, Wright Area Coal Lease Applications

extensive baseline data collection, and development of new mining and 

reclamation plans. A new start mine would also require a large number of new 

employees, which may not be available from the mining sector workforce 

(which includes the oil and gas industry), considering the current strong 

demand for labor and low unemployment in Campbell County and surrounding 

counties in the PRB. 

In addition, a company or companies acquiring this coal for one or more new 

start mines would have to compete for customers with established mines in a 

competitive market. Based on demand forecasting for the Wyoming PRB 

mines, there is sufficient existing mine capacity to provide for expected coal 

demand through the year 2020 (BLM 2005a). While this does not mean that 

no new operations would open, it becomes difficult for a new operation with the 

capital costs of new facilities and mine start up costs to produce coal at a price 

competitive with the existing operations. 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 WDEQ/AQD website at 

http://deq.state.wy.us/aqd/standards.asp. There were no exceedances of the 

24-hour PM10 standard anywhere in the PRB through year 2000. From 2001 

through 2006, there were 29 monitored exceedances of the 24-hour PM10

standard at seven operating mines in the Wyoming PRB. Nineteen of these 

exceedances occurred in 2001 and 2002, while two, three, five, and zero 

exceedances occurred in 2003, 2004, 2005, and 2006 respectively. In 2007, 

there were a total of 11 exceedances of the 24-hour PM10 standard reported at 

six PRB surface coal mines. Seven of those 11 exceedances in 2007 occurred 

at the mines that are located in the general Wright analysis area (one at the 

Black Thunder Mine, two at the North Antelope Rochelle Mine, and four at the 

North Rochelle Mine, which was acquired by Arch Coal, Inc. in 2004 and is 

located between and adjacent to the Black Thunder and North Antelope 

Rochelle mines). A total of two exceedances of the 24-hour PM10 standard were 

reported at the PRB mines in 2008, one each at the Black Thunder and North 

Rochelle mines. WDEQ/AQD subsequently issued notices of violation for the 

two exceedances that occurred in 2008 (Shamley 2010). Although many of 

these exceedances have been attributed to high winds, concerns about future 

potential exceedances of the federal and state ambient air quality standards 

may make it more 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 the standards. 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-67 

In view of the issues discussed above, development of a new mine on one or 

more of the six LBA tracts that are included in this EIS is considered unlikely 

and this alternative is not analyzed in detail in this EIS. 

The environmental impacts of developing one or more new mines to recover the 

coal resources in one or more of these six LBA tracts would be greater than 

under the Proposed Action, the No Action Alternative, or Alternatives 2 or 3 

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 one or 

more lease sales are held and the applicants are not the successful bidder(s), 

the successful bidder(s) would be required to submit detailed mining and 

reclamation plans for approval before any of the tract(s) could be mined, and 

this NEPA analysis would be reviewed and supplemented as necessary prior to 

approval of those mining and reclamation plans. 

2.7.2 Alternative 5: Delaying the Sale

Under this alternative, BLM would delay the sale of one or more of the LBA 

tracts as applied for. This alternative assumes that a tract could be developed 

later as either a maintenance tract or a new start mine, depending on how long 

the sale was delayed. 

Coal bed natural gas (CBNG) resources are currently being recovered from oil 

and gas leases on all six LBA tracts. Delaying the sale of one or more of the 

tracts would allow CBNG resources to be more completely recovered prior to 

mining. There are several mechanisms in place that would allow continuing 

recovery of the CBNG resources prior to mining if the federal coal reserves in 

the tracts are leased now. These include: 

• BLM can attach a Multiple Mineral Development stipulation to each 

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. 

• BLM has a policy in place on CBNG-coal conflicts (BLM Instruction 

Memorandum No. 2006-153) that directs BLM decision makers to 

optimize the recovery of both resources and ensure that the public 

receives a reasonable return (BLM 2006a). 

• Mining of each LBA tract cannot occur until the coal lessee has a permit 

to mine the tract approved by the WDEQ/LQD and a Mineral Leasing Act 

(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. 
2.0 Proposed Action and Alternatives 

2-68 Final EIS, Wright Area Coal Lease Applications

• The mine permit approval process generally takes the coal lessee several 

years to complete. This would allow time for the CBNG resources to be 

recovered from each tract. 

However, delaying the sale of one or more of the tracts would not necessarily 

result in the recovery of more CBNG because the recovery is likely to continue 

post-sale, and most (or all) of the CBNG has either been, or will be by the time 

coal mining operations commence, produced from the oil and gas leases on the 

tract. 

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. Delaying the sale of one or more of the tracts may result 

in a higher coal price and/or higher bonus bid. If coal prices do increase, the 

fair market value of the coal resources in the LBA tracts 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 and 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 a existing mine runs out of coal 

reserves before prices rise, it would potentially have to 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. 

The average price received for PRB coal in 2000 was just under $5.00 per ton. 

Prices increased to between $6.00 and $7.00 per ton from 2001 to 2004, and in 

2005 the average price peaked at more than $20.00 per ton. During much of 

2005, coal shipments from the PRB were limited due to damage to railroad 

lines in Wyoming and other states. These shipping constraints combined with 

increasing world energy demands and natural disasters in other parts of the 

country led to anomalously large increases in coal prices in 2005. Rail 

capacity increased in 2006, which effectively helped to moderate coal prices 

throughout 2006. Average prices received for PRB coal remained fairly stable 

at around $10.00 per ton in 2007, increased to around $14.50 in 2008, and 

then decreased to under $10.00 per ton throughout most of 2009. 

The recent history of price volatility and the lengthy lease and permitting 

process underscores the difficulty in predicting the price of coal, and therefore, 

the bonus and royalty payments to the government. However, the global 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-69 

demand for coal has increased largely due to the rise of developing foreign 

markets like China and India. Fueled by recent overseas demand, Appalachian 

coal prices have increased dramatically. PRB coal may help to fill the gap left 

by the Appalachian coal exports, which could lead to greater demand and 

prices for PRB coal. If so, the bonus and royalty payments to the government 

might be higher if one or more of the tracts is offered for sale at a later date. 

There is no assurance however at this time that delaying the sale of one or 

more of the LBA tracts would result in a higher coal price or a higher bonus 

bid. 

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 continue meeting the 

nation’s energy needs while also meeting the existing Clean Air Act 

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 2 and 3. 

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 each proposed lease provide for the U.S. to 

benefit if coal prices increase by the time of mining. Moreover, recovery of a 

large portion of the economically-recoverable CBNG resources on the tracts 

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 Alternatives 2 and 3 for each LBA tract. If a new mine is 

required to mine the coal, the environmental impacts would be expected to be 

greater than if each tract were mined as an extension of an existing mine. 

2.8 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 permits to conduct mining 

operations for the Black Thunder, Jacobs Ranch, and North Antelope Rochelle 

mines include 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 

North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, 

North Porcupine, and South Porcupine LBA Tracts. These data collection 
2.0 Proposed Action and Alternatives 

2-70 Final EIS, Wright Area Coal Lease Applications

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 Black Thunder, Jacobs Ranch, and North Antelope 

Rochelle mines. These data collection requirements, mitigation plans, and 

monitoring commitments would be extended to include mining operations on 

the North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs 

Ranch, North Porcupine, and South Porcupine LBA Tracts if they are leased 

and permitted for mining. A mining and reclamation plan would have to be 

approved for each tract before any mining operations could be conducted, 

regardless of who acquires the tract. 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 Black Thunder, Jacobs Ranch, 

and North Antelope Rochelle mines are described in Chapter 3. 

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. 

2.9 Hazardous and Solid Waste 

Wastes produced by current mining activities at the Black Thunder, Jacobs 

Ranch, and North Antelope Rochelle mines are handled according to the 

procedures described in the approved mine permits (TBCC 2005, JRCC 2009, 

and PRC 2009, respectively). Under the Proposed Action and Action 

Alternatives for each of the six LBA tracts, the procedures and requirements for 

handling of hazardous and solid wastes would be the same as the procedures 

and requirements for the existing mining operations and in accordance with 

the mines’ approved waste disposal plans. 

Solid waste that is produced at the existing Black Thunder, Jacobs Ranch, and 

North Antelope Rochelle mines consists of floor sweepings, shop rags, empty 

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 Black Thunder, Jacobs Ranch, and North Antelope Rochelle 

mines is disposed of within the mines’ permit boundaries in accordance with 

WDEQ-approved solid waste disposal plans. Non-hazardous solid waste from 

the mines is also disposed of at the regulated Campbell County landfill near 

Gillette. 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 each of the three mines. 

Major lubrication, oil changes, etc. of most equipment are performed inside the 

service building lubrication bays at the Black Thunder, Jacobs Ranch, and
2.0 Proposed A

Final EIS, Wright Area Coal Lease Applications 2-71 

Table 2-1. Regulatory Compliance, Mitigation and Monitoring Measures for Surface Coa

Required by SMCRA and State Law for all Alternatives. 

Resource

Regulatory Compliance or Mitigation Required by 

Stipulations, State or Federal Law1 Monitorin

Topography & Physiography

▪ Restoring to approximate original contour or other approved topographic 

configuration.

▪ WDEQ/L

approved annual re

Geology & Minerals ▪ Identifying & selectively placing or mixing chemically or physically unsuitable 

overburden materials to minimize adverse effects to vegetation or groundwater.

▪ WDEQ/L

advance unsuitab

Soil ▪ Salvaging soil suitable to support plant growth for use in reclamation; 

▪ Protecting soil stockpiles from disturbance and erosional influences; ▪ Selectively placing at least 4 feet of suitable overburden on the graded backfill surface 

below replaced topsoil to meet guidelines for vegetation root zones.

▪ Monitorin

reclaimed for soil am

▪ Sampling 

complian

Air Quality ▪ 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. 

▪ On-site a

PM10 and

▪ Off-site a

and/or T

▪ On-site c

1 These requirements, mitigation plans, and monitoring plans are required by SMCRA and Wyoming state law, and are already in place f

Jacobs Ranch, and North Antelope Rochelle mines in their current approved WDEQ/LQD mining and reclamation plans (the No Action AlField, South Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts were leased, these rand monitoring plans would be part of the mining plan revisions covering each of the LBA tracts that must be approved before mining can Proposed Actions or Action Alternatives. 
2.0 Proposed Action and Alternatives 

 2-72 Final EIS, Wright Area C

Table 2-1. Regulatory Compliance, Mitigation and Monitoring Measures for Surface Coa

Required by SMCRA and State Law for all Alternatives (Continued). 

Resource 

Regulatory Compliance or Mitigation Required by 

Stipulations, State or Federal Law1 Monitori

Air Quality (continued) ▪ 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.

▪ Monitor

sedimen

▪ Monitor▪ Monitor

quality.

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.

▪ Monitori

in overbuunderbu

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.

▪ Monitori

in overbuunderbu

Alluvial Valley Floors

▪ Identifying all AVFs that would be affected by mining; ▪ WDEQ/LQD determination of significance to agriculture of all identified AVFs affected 

by mining; 

▪ Protecting downstream AVFs during mining; ▪ Restoring essential hydrologic function of all AVFs affected by mining.

▪ Monitori

of essentany decl

Wetlands ▪ Identifying all wetlands that would be affected by mining; 

▪ COE identification of jurisdictional wetlands; ▪ Replacing all jurisdictional wetlands that would be disturbed by mining; ▪ Replacing functional wetlands as required by surface managing agency, surface 

landowner, or WDEQ/LQD.

▪ Monitori

using saidentify pwetlands

1 These requirements, mitigation plans, and monitoring plans are required by SMCRA and Wyoming state law, and are already in place f

Jacobs Ranch, and North Antelope Rochelle mines in their current approved WDEQ/LQD mining and reclamation plans (the No Action AlField, South Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts were leased, these rand monitoring plans would be part of the mining plan revisions covering each of the LBA tracts that must be approved before mining can Proposed Actions or Action Alternatives. 
2.0 Proposed A

Final EIS, Wright Area Coal Lease Applications 2-73 

Table 2-1. Regulatory Compliance, Mitigation and Monitoring Measures for Surface Coa

Required by SMCRA and State Law for all Alternatives (Continued). 

Resource 

Regulatory Compliance or Mitigation Required by 

Stipulations, State or Federal Law1 Monitori

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.

▪ Monitori

diversity reclamatyears); 

▪ Monitori

need for establish

▪ Use of co

revegetadeterminmining l

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; ▪ 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 USFWS-approved raptor mitigation plans; 

▪ Avoiding bald eagle disturbance; 

▪ Restoring bald eagle perching and foraging areas disturbed by mining; ▪ Creating raptor nesting habitat through enhancement efforts; 

▪ Development of a Migratory Bird Species of Management Concern (including the 

Greater sage-grouse) Monitoring and Mitigation Plan; 

▪ Restoring sage-grouse and mountain plover habitat disturbed by mining; ▪ Surveying for sage-grouse, mountain plover and black-tailed prairie dogs. 

▪ Baseline 

monitori

▪ Monitori

migratormanagem

1 These requirements, mitigation plans, and monitoring plans are required by SMCRA and Wyoming state law, and are already in place f

Jacobs Ranch, and North Antelope Rochelle mines in their current approved WDEQ/LQD mining and reclamation plans (the No Action AlField, South Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts were leased, these rand monitoring plans would be part of the mining plan revisions covering each of the LBA tracts that must be approved before mining can Proposed Actions or Action Alternatives. 
2.0 Proposed Action and Alternatives 

 2-74 Final EIS, Wright Area C

Table 2-1. Regulatory Compliance, Mitigation and Monitoring Measures for Surface Coal 

Required by SMCRA and State Law for all Alternatives (Continued). 

Resource

Regulatory Compliance or Mitigation Required by 

Stipulations, State or Federal Law1 Monitori

Threatened, Endangered, Proposed, and Candidate Species (Vegetation and Animals) 

▪ Surveying for Ute ladies'-tresses and blowout penstemon; 

▪ USFWS block clearance from black-footed ferret surveys in project area; 

▪ Same as Wildlife and Sensitive Species above. 

▪ Baseline 

monitor

Land Use ▪ Suitably restoring reclaimed area for historic uses (grazing and wildlife); ▪ Monitor

prior to 

Cultural Resources 

▪ Conducting Class I & III surveys to identify cultural properties on all state and 

federal lands and on private lands affected by federal undertakings; 

▪ Consulting with SHPO to evaluate eligibility of cultural properties for the NRHP; 

▪ Avoiding or recovering data from significant cultural properties identified by surveys, 

according to an approved plan; 

▪ Notifying 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. 

▪ Monitor

during t

▪ Cessatio

notificatunidentduring t

Native American Concerns

▪ Notifying Native American tribes with known interest in this area of leasing action 

and request for help in identifying potentially significant religious or cultural sites.

▪ No speci

Paleontological Resources

▪ Notifying appropriate federal personnel if potentially significant paleontological sites 

are discovered during mining.

▪ No speci

Visual Resources

▪ Restoring landscape character during reclamation through return to approximate 

original contour and revegetation with native species.

▪ No speci

Noise ▪ Protecting employees from hearing loss. ▪ MSHA inTransportation Facilities

▪ Relocating existing pipelines, if necessary, in accordance with specific agreement 

between pipeline owner and coal lessee.

▪ No speci

Socioeconomics ▪ Paying royalty and taxes as required by federal, state, and local regulations. 

▪ No mitigation measures are proposed.

▪ Surveyin

docume

1 These requirements, mitigation plans, and monitoring plans are required by SMCRA and Wyoming state law, and are already in place fo

Jacobs Ranch, and North Antelope Rochelle mines in their current approved WDEQ/LQD mining and reclamation plans (the No Action Alte

Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts were leased, these reand monitoring plans would be part of the mining plan revisions covering each of the LBA tracts that must be approved before mining can Proposed Actions or Action Alternatives. 
2.0 Proposed A

Final EIS, Wright Area Coal Lease Applications 2-75 

Table 2-1. Regulatory Compliance, Mitigation and Monitoring Measures for Surface Coa

Required by SMCRA and State Law for all Alternatives (Continued). 

Resource

Regulatory Compliance or Mitigation Required by 

Stipulations, State or Federal Law1 Monitorin

Hazardous & Solid Waste 

▪ Disposing of solid waste and sewage within permit boundaries according to approved 

plans; 

▪ Storing and recycling waste oil; ▪ Maintaining 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. 

▪ No specif

required and respo

1 These requirements, mitigation plans, and monitoring plans are required by SMCRA and Wyoming state law, and are already in place f

Jacobs Ranch, and North Antelope Rochelle mines in their current approved WDEQ/LQD mining and reclamation plans (the No Action AlField, South Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts were leased, these rand monitoring plans would be part of the mining plan revisions covering each of the LBA tracts that must be approved before mining can Proposed Actions or Action Alternatives. 
2.0 Proposed Action and Alternatives 

2-76 Final EIS, Wright Area Coal Lease Applications

North Antelope Rochelle mines, 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, 

including, at some of the PRB mines, blending with diesel fuel oil for use as 

equipment fuel. These practices would not change if the applicants acquire 

these LBA tracts. 

TBCC and PRC have reviewed 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. 

TBCC and PRC maintain files containing Material Safety Data Sheets (MSDS) 

for all chemicals, compounds, and/or substances that are or would be used 

during the course of mining. 

TBCC and PRC are 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. 

TBCC and PRC must comply with emergency reporting requirements for release 

of hazardous materials. Any release of hazardous or extremely hazardous 

substances in excess of the reportable quantity, as established in 40 CFR 117, 

is reported as required by Comprehensive Environmental Response, 

Compensation, and Liability Act of 1980 (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. 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-77 

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 Black Thunder, 

Jacobs Ranch, and North Antelope Rochelle mines. Acquisition of the LBA 

tracts by the applicants would not change these current practices nor the type 

of any wastes generated and disposed of by the mines; however, the quantities 

of some wastes (e.g., lubricants and solid wastes produced in the shops and 

offices) would likely increase in proportion to increases in coal production. 

2.10 Summary of Alternatives and Environmental Consequences 

2.10.1 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 final EIS analyzes in detail different alternatives for the North Hilight 

Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, North 

Porcupine, and South Porcupine LBA Tracts described in the discussion above. 

2.10.2 Summary of Alternatives

The North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs 

Ranch, North Porcupine, and South Porcupine LBA Tracts under the Action 

Alternatives are shown on Figures 2-1 through 2-6, respectively. A summary 

comparison of projected coal production, surface disturbance, mine life, and 

federal and state revenues for the Proposed Action and Alternatives 1, 2, and 3 

(if applicable) for the North Hilight Field, South Hilight Field, West Hilight Field, 

West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts LBA 

Tracts are presented in Tables 2-2 through 2-13, respectively. 

Table 2-2 presents the comparisons assuming that Shroyer Road is not moved 

and the underlying coal is not recovered from the North Hilight Field tract. 

Table 2-3 presents the comparisons assuming that Shroyer Road is moved and 

the underlying coal is recovered from the North Hilight Field tract. 

Table 2-4 presents the comparisons assuming that Reno Road is not moved 

and the underlying coal is not recovered from the South Hilight Field tract.
2.0 Proposed Action and Alternatives 

 2-78 Final EIS, Wright Area C

Table 2-2. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Hilight Field LBA Tract and Black Thunder Mine – Shroyer Road is Not Moved and tNot Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing Black Thunder Mine) 

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 1,271.1 mmt 319.7 mmt Mineable Coal (as of 1/1/09)1 1,271.1 mmt 286.3 mmt Recoverable Coal (as of 1/1/09)2 1,169.4 mmt 263.4 mmt Coal Mined Through 2008 1,087.9 mmt -- Lease Area3 19,581.3 ac 2,613.5 ac Total Area To Be Disturbed3 26,490.2 ac 5,053.0 ac Permit Area3 29,212.0 ac 5,053.0 ac Average Annual Coal Production (by 2015)4 135 mmt 0 mmt Remaining Life of Mine (post-2008) 9.3 yrs 2.0 yrs Projected Number of Employees (by 2013)4 1,324 0 

Total Projected State Revenues (post-2008)5 $1,977.9 mm $488.5 – $584.4 mm 

Total Projected Federal Revenues (post-2008)6 $1,541.1 mm $390.1 – $486.0 mm 

1 Under the Proposed Action and Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath the BNSF & UP 

buffer zone and Shroyer Road ROW and associated buffer zone. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state and private coal within the permit boundary. The distur

leased area (total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the 

area is larger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defin

4 The mine projects to increase production rate from 100 mmtpy after 2008 to 135 mmtpy by 2015. The mine projects to increase emplo

projected production increases. 

5 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

6 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thr

mineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
2.0 Proposed A

Final EIS, Wright Area Coal Lease Applications 2-79 

Table 2-3. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Hilight Field LBA Tract and Black Thunder Mine – Shroyer Road is Moved and the Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing Black Thunder Mine) 

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 1,271.1 mmt 319.7 mmt Mineable Coal (as of 1/1/09)1 1,271.1 mmt 295.8 mmt Recoverable Coal (as of 1/1/09)2 1,169.4 mmt 272.1 mmt Coal Mined Through 2008 1,087.9 mmt -- Lease Area3 19,581.3 ac 2,613.5 ac Total Area To Be Disturbed3 26,490.2 ac 5,053.0 ac Permit Area3 29,212.0 ac 5,053.0 ac Average Annual Coal Production (by 2015)4 135 mmt 0 mmt Remaining Life of Mine (post-2008) 9.3 yrs 2.0 yrs Projected Number of Employees (by 2013)4 1,324 0 

Total Projected State Revenues (post-2008)5 $1,977.9 mm $504.6 – $603.7 mm 

Total Projected Federal Revenues (post-2008)6 $1,541.1 mm $403.0 – $502.1 mm 

1 Under the Proposed Action and Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railro

zone. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state and private coal within the permit boundary. The distur

leased area (total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the 

area is larger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defin

4 The mine projects to increase production rate from 100 mmtpy after 2008 to 135 mmtpy by 2015. The mine projects to increase emplo

projected production increases. 

5 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

6 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thromineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
2.0 Proposed Action and Alternatives 

 2-80 Final EIS, Wright Area C

Table 2-4. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Hilight Field LBA Tract and Black Thunder Mine – Reno Road is Not Moved and thNot Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing Black Thunder Mine) 

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 1,271.1 mmt 273.3 mmt Mineable Coal (as of 1/1/09)1 1,271.1 mmt 232.2 mmt Recoverable Coal (as of 1/1/09)2 1,169.4 mmt 213.6 mmt Coal Mined Through 2008 1,087.9 mmt -- Lease Area3 19,581.3 ac 1,976.7 ac Total Area To Be Disturbed3 26,490.2 ac 1,126.0 ac Permit Area3 29,212.0 ac 1,126.0 ac Average Annual Coal Production (by 2015)4 135 mmt 0 mmt Remaining Life of Mine (post-2008) 9.3 yrs 1.6 yrs Projected Number of Employees (by 2013)4 1,324 0 

Total Projected State Revenues (post-2008)5 $1,977.9 mm $396.1 – $473.9 mm 

Total Projected Federal Revenues (post-2008)6 $1,541.1 mm $316.3 – $394.1 mm 

1 Under the Proposed Action and Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railro

zone. Under Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath Reno Road ROW and associated buffe

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state and private coal within the permit boundary. The distur

leased area (total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the 

area is larger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defin

4 The mine projects to increase production rate from 100 mmtpy after 2008 to 135 mmtpy by 2015. The mine projects to increase emplo

projected production increases. 

5 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

6 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thrmineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
2.0 Proposed A

Final EIS, Wright Area Coal Lease Applications 2-81 

Table 2-5. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Hilight Field LBA Tract and Black Thunder Mine – Reno Road is Moved and thRecovered.

Item 

Alternative 1 - No Action Alternative 

(Existing Black Thunder Mine) 

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 1,271.1 mmt 273.3 mmt Mineable Coal (as of 1/1/09)1 1,271.1 mmt 232.2 mmt Recoverable Coal (as of 1/1/09)2 1,169.4 mmt 213.6 mmt Coal Mined Through 2008 1,087.9 mmt -- Lease Area3 19,581.3 ac 1,976.7 ac Total Area To Be Disturbed3 26,490.2 ac 1,126.0 ac Permit Area3 29,212.0 ac 1,126.0 ac Average Annual Coal Production (by 2015)4 135 mmt 0 mmt Remaining Life of Mine (post-2008) 9.3 yrs 1.6 yrs Projected Number of Employees (by 2013)4 1,324 0 

Total Projected State Revenues (post-2008)5 $1,977.9 mm $396.1 – $473.9 mm 

Total Projected Federal Revenues (post-2008)6 $1,541.1 mm $316.3 – $394.1 mm 

1 Under the Proposed Action and Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railro

zone. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state and private coal within the permit boundary. The distur

leased area (total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the 

area is larger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defin

4 The mine projects to increase production rate from 100 mmtpy after 2008 to 135 mmtpy by 2015. The mine projects to increase emplo

projected production increases. 

5 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

6 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thr

mineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
2.0 Proposed Action and Alternatives 

 2-82 Final EIS, Wright Area Co

Table 2-6. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and Rev

Field LBA Tract and Black Thunder Mine – State Highway 450 and Hilight Road aUnderlying Coal is Not Recovered. 

Item 

Alternative 1 – 

No Action Alternative 

(Existing Black Thunder Mine)

Added by 

Proposed Action 

Added by 

Alternative 2 

In-Place Coal (as of 1/1/09) 1,271.1 mmt 440.4 mmt 1,147.9 mmt Mineable Coal (as of 1/1/09)1 1,271.1 mmt 410.8 mmt 1,049.1 mmt 

Recoverable Coal (as of 1/1/09)2 1,169.4 mmt 377.9 mmt 965.2 mmt 

Coal Mined Through 2008 1,087.9 mmt -- -- Lease Area3 19,581.3 ac 2,370.5 ac 7,191.3 ac 

Total Area To Be Disturbed3 26,490.2 ac 6,351.4 ac 10,250.8 ac 

Permit Area3 29,212.0 ac 6,351.4 ac 10,250.8 ac 

Average Annual Coal Production (by 2015)4 135 mmt 0 mmt 0 mmt 

Remaining Life of Mine (post-2008) 9.3 yrs 2.8 yrs 7.1 yrs 

Projected Number of Employees (by 2013)4 1,324 0 0 

Total Projected State Revenues (post-2008)5 $1,977.9 mm $700.8 – $838.4 mm $1,789.9 – $2,141.3 mTotal Projected Federal Revenues (post-2008)6 $1,541.1 mm $559.7 – $697.3 mm $1,429.4 – $1,780.8 m1 Under the Proposed Action, the mineable coal figure excludes all coal that would not be mined beneath State Highway 450 ROW and a

Alternatives 2 and 3, the mineable coal figure excludes all coal that would not be mined beneath State Highway 450 and Hilight Road ROWUnder Alternative 3, the mineable coal figure excludes all coal that would not be mined beneath the Northwest Rail Loop Amendment Area. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state and private coal within the permit boundary. The distur

leased area (total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the 

area is larger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defin

4 The mine projects to increase production rate from 100 mmtpy after 2008 to 135 mmtpy by 2015. The mine projects to increase emplo

projected production increases. 

5 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bisold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

6 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thrmineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
2.0 Proposed A

Final EIS, Wright Area Coal Lease Applications 2-83 

Table 2-7. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Hilight Field LBA Tract and Black Thunder Mine – State Highway 450 and Hilight the Underlying Coal is Recovered. 

Item 

Alternative 1 – 

No Action Alternative 

(Existing Black Thunder Mine)

Added by 

Proposed Action 

Added by 

Alternative 2 

In-Place Coal (as of 1/1/09) 1,271.1 mmt 440.4 mmt 1,147.9 mmt Mineable Coal (as of 1/1/09)1 1,271.1 mmt 440.4 mmt 1,147.9 mmt 

Recoverable Coal (as of 1/1/09)2 1,169.4 mmt 405.2 mmt 1,056.1 mmt 

Coal Mined Through 2008 1,087.9 mmt -- -- 

Lease Area3 19,581.3 ac 2,370.5 ac 7,191.3 ac 

Total Area To Be Disturbed3 26,490.2 ac 6,351.4 ac 11,629.5 ac 

Permit Area3 29,212.0 ac 6,351.4 ac 11,629.5 ac 

Average Annual Coal Production (by 2015)4 135 mmt 0 mmt 0 mmt 

Remaining Life of Mine (post-2008) 9.3 yrs 3.0 yrs 7.8 yrs 

Projected Number of Employees (by 2013)4 1,324 0 0 

Total Projected State Revenues (post-2008)5 $1,977.9 mm $751.4 – $898.9 mm $1,958.4 – $2,343.0 mm Total Projected Federal Revenues (post-2008)6 $1,541.1 mm $600.1 – $747.6 mm $1,564.0 – $1,948.6 mm 1 Under the Proposed Action, the mineable coal figure excludes all coal that would not be mined beneath State Highway 450 ROW and a

Alternatives 2 and 3, the mineable coal figure excludes all coal that would not be mined beneath State Highway 450 and Hilight Road ROWUnder Alternative 3, the mineable coal figure excludes all coal that would not be mined beneath the Northwest Rail Loop Amendment Area. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state and private coal within the permit boundary. The distur

leased area (total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the 

area is larger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defin

4 The mine projects to increase production rate from 100 mmtpy after 2008 to 135 mmtpy by 2015. The mine projects to increase emplo

projected production increases. 

5 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bisold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

6 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thr

mineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
2.0 Proposed Action and Alternatives 

 2-84 Final EIS, Wright Area C

Table 2-8. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Jacobs Ranch LBA Tract and Jacobs Ranch Mine – State Highway 450 and Hilight and the Underlying Coal is Not Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing Jacobs Ranch Mine) 

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 403.6 mmt 957.0 mmt Mineable Coal (as of 1/1/09)1 403.6 mmt 744.0 mmt Recoverable Coal (as of 1/1/09)2 379.4 mmt 669.6 mmt Coal Mined Through 2008 671.1 mmt -- Lease Area3 7,381.0 ac 5,944.4 ac Total Area To Be Disturbed3 15,261.5 ac 7,023.0 ac Permit Area3 15,625.0 ac 8,066.0 ac Average Annual Coal Production (post-2008) 40 mmt 0 mmt Remaining Life of Mine (post-2008) 9.6 yrs 16.7 yrs Projected Number of Employees 630 155 

Total Projected State Revenues (post-2008)4 $641.7 mm $1,244.1 – $1,493.4 mm 

Total Projected Federal Revenues (post-2008)5 $500.0 mm $994.1 – $1,243.3 mm 

1 Under the Proposed Action and Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath State Highway 45

associated buffer zones. 

2 Assumes 94 percent recovery of mineable coal that occurs during normal mining operation under Alternative 1, and 90 percent recovery 

during normal mining operation under the Proposed Action and Alternative 2. 

3 The lease area figure includes federal coal leases only and does not include state and private coal within the permit boundary. The distur

leased area (total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the 

area is larger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defin

4 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

5 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.0 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thrmineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
2.0 Proposed A

Final EIS, Wright Area Coal Lease Applications 2-85 

Table 2-9. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Jacobs Ranch LBA Tract and Jacobs Ranch Mine – State Highway 450 and Hilight the Underlying Coal is Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing Jacobs Ranch Mine) 

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 403.6 mmt 957.0 mmt Mineable Coal (as of 1/1/09)1 403.6 mmt 957.0 mmt Recoverable Coal (as of 1/1/09)2 379.4 mmt 861.3 mmt Coal Mined Through 2008 671.1 mmt -- Lease Area3 7,381.0 ac 5,944.4 ac Total Area To Be Disturbed3 15,261.5 ac 7,023.0 ac Permit Area3 15,625.0 ac 8,066.0 ac Average Annual Coal Production (post-2008) 40 mmt 0 mmt Remaining Life of Mine (post-2008) 9.6 yrs 21.5 yrs Projected Number of Employees 630 155 

Total Projected State Revenues (post-2008)4 $641.7 mm $1,600.3 – $1,920.9 mm 

Total Projected Federal Revenues (post-2008)5 $500.0 mm $1,278.6 – $1,599.2 mm 

1 Under the Proposed Action and Alternative 2, the mineable coal figure includes all coal that would be mined beneath State Highway 450 

associated buffer zones. 

2 Assumes 94 percent recovery of mineable coal that occurs during normal mining operation under Alternative 1, and 90 percent recovery 

during normal mining operation under the Proposed Action and Alternative 2. 

3 The lease area figure includes federal coal leases only and does not include state and private coal within the permit boundary. The distur

leased area (total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the 

area is larger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defin

4 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

5 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thr

mineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
2.0 Proposed Action and Alternatives 

 2-86 Final EIS, Wright Area C

Table 2-10. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Porcupine LBA Tract and North Antelope Rochelle Mine – Mackey Road is Not MoveCoal is Not Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing North Antelope Rochelle Mine)

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 1,049.9 mmt 756.9 mmt Mineable Coal (as of 1/1/09)1 1,015.0 mmt 653.5 mmt Recoverable Coal (as of 1/1/09)2 933.8 mmt 601.2 mmt Coal Mined Through 2008 1,230.8 mmt -- Lease Area3 16,666.1 ac 5,795.8 ac Total Area To Be Disturbed3 27,443.0 ac 9,864.0 ac Permit Area3 45,975.0 ac 1,760.0 ac Average Annual Coal Production (post-2008) 95 mmt 0 mmt Remaining Life of Mine (post-2008) 9.9 yrs 6.3 yrs Projected Number of Employees 1,150 0 Total Projected State Revenues (post-2008)4 $1,579.4 mm $1,114.9 – $1,333.8 mm $Total Projected Federal Revenues (post-2008)5 $1,230.6 mm $890.3 – $1,109.3 mm $1 Under the Proposed Action, the mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railroad ROW and 

Substation buffer zone, and Mackey Road ROW and associated buffer zone. Under Alternative 2, the mineable coal figure excludes all 

beneath BNSF & UP railroad ROW and associated buffer zone, Teckla Substation buffer zone, a portion of Matheson Road ROW and assocRoad ROW and associated buffer zone. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state coal within the permit boundary. The disturbed area ty

(total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the lease blarger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defined lega

4 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

5 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amouroyalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thrmineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
2.0 Proposed A

Final EIS, Wright Area Coal Lease Applications 2-87 

Table 2-11. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Porcupine LBA Tract and North Antelope Rochelle Mine – Mackey Road is Moved Coal is Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing North Antelope Rochelle Mine) 

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 1,049.9 mmt 756.9 mmt Mineable Coal (as of 1/1/09)1 1,015.0 mmt 688.3 mmt Recoverable Coal (as of 1/1/09)2 933.8 mmt 633.3 mmt Coal Mined Through 2008 1,230.8 mmt -- Lease Area3 16,666.1 ac 5,795.8 ac Total Area To Be Disturbed3 27,443.0 ac 10,167.0 ac Permit Area3 45,975.0 ac 1,760.0 ac Average Annual Coal Production (post-2008) 95 mmt 0 mmt Remaining Life of Mine (post-2008) 9.9 yrs 6.7 yrs Projected Number of Employees 1,150 0 Total Projected State Revenues (post-2008)4 $1,579.4 mm $1,174.4 – $1,405.0 mm Total Projected Federal Revenues (post-2008)5 $1,230.6 mm $937.9 – $1,168.4 mm 

1 Under the Proposed Action, the mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railroad ROW and ass

Substation buffer zone. Under Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railrozone, Teckla Substation buffer zone, and a portion of Matheson Road ROW and associated buffer zone. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state coal within the permit boundary. The disturbed area ty

(total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the lease blarger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defined lega

4 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

5 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.35 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thrmineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
2.0 Proposed Action and Alternatives 

 2-88 Final EIS, Wright Area C

Table 2-12. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Porcupine LBA Tract and North Antelope Rochelle Mine – 2.25-Mile Section of AMoved and the Underlying Coal is Not Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing North Antelope Rochelle Mine)

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 1,049.9 mmt 422.2 mmt Mineable Coal (as of 1/1/09)1 1,015.0 mmt 336.6 mmt Recoverable Coal (as of 1/1/09)2 933.8 mmt 309.7 mmt Coal Mined Through 2008 1,230.8 mmt -- Lease Area3 16,666.1 ac 3,186.0 ac Total Area To Be Disturbed3 27,443.0 ac 3,366.0 ac Permit Area3 45,975.0 ac 200.0 ac Average Annual Coal Production (post-2008) 95 mmt 0 mmt Remaining Life of Mine (post-2008) 9.9 yrs 3.3 yrs Projected Number of Employees 1,150 0 

Total Projected State Revenues (post-2008)4 $1,579.4 mm $574.3 – $687.1 mm 

Total Projected Federal Revenues (post-2008)5 $1,230.6 mm $458.6 – $571.4 mm 

1 Under the Proposed Action and Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railro

zone and 2.25-mile section of Antelope Road and associated buffer zone. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state coal within the permit boundary. The disturbed area ty

(total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the lease b

larger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defined lega

4 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bisold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

5 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amouroyalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thr

mineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
2.0 Proposed A

Final EIS, Wright Area Coal Lease Applications 2-89 

Table 2-13. Summary Comparison of Coal Production, Surface Disturbance, Mine Life, and 

Porcupine LBA Tract and North Antelope Rochelle Mine – 2.25-Mile Section of Antand the Underlying Coal is Recovered.

Item 

Alternative 1 - No Action Alternative 

(Existing North Antelope Rochelle Mine) 

Added by 

Proposed Action 

In-Place Coal (as of 1/1/09) 1,049.9 mmt 422.2 mmt Mineable Coal (as of 1/1/09)1 1,015.0 mmt 408.4 mmt Recoverable Coal (as of 1/1/09)2 933.8 mmt 375.7 mmt Coal Mined Through 2008 1,230.8 mmt -- Lease Area3 16,666.1 ac 3,186.0 ac Total Area To Be Disturbed3 27,443.0 ac 3,908.0 ac Permit Area3 45,975.0 ac 200.0 ac Average Annual Coal Production (post-2008) 95 mmt 0 mmt Remaining Life of Mine (post-2008) 9.9 yrs 4.0 yrs Projected Number of Employees 1,150 0 

Total Projected State Revenues (post-2008)4 $1,579.4 mm $696.7 – $833.5 mm 

Total Projected Federal Revenues (post-2008)5 $1,230.6 mm $556.4 – $693.2 mm 

1 Under the Proposed Action and Alternative 2, the mineable coal figure excludes all coal that would not be mined beneath BNSF & UP railro

zone. 

2 Assumes 92 percent recovery of mineable coal that occurs during normal mining operation. 3 The lease area figure includes federal coal leases only and does not include state coal within the permit boundary. The disturbed area ty

(total federal and state) because of the need for highwall reduction, topsoil removal, and other mine support activities outside the lease blarger than the leased or disturbed area to assure that all disturbed lands are within the permit boundary and to allow an easily defined lega

4 Revenues to the State of Wyoming include severance taxes, property and production taxes (ad valorem), sales and use taxes, and Wyom

payments, AML fees and bonus bid payments. State revenues are based on $0.4312 per ton estimate for severance taxes × amount of recoveestimate for ad valorem taxes × amount of recoverable coal, plus $0.0569 per ton estimate for sales and use taxes × amount of recoverable c

of $11.06 per ton × amount of recoverable coal × federal royalty of 12.5 percent minus federal’s 50 percent share, plus $0.28 per ton for AM

coal minus federal’s 50 percent share, plus bonus bid payment on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus bi

sold from 2004 through early 2009) × amount of mineable coal minus federal’s 50 percent share. These figures could change based on th

that changed the percent of distribution to states. 

5 Federal revenues include black lung taxes and the federal government’s share of federal royalty payments, AML fees, and bonus bid paymen

on a projected coal price of $11.06 per ton × amount of recoverable coal × black lung tax of 4.4 percent, plus $11.06 per ton price × amou

royalty of 12.5 percent minus state’s 50 percent share, plus $0.28 per ton for AML fees × amount of recoverable coal minus state’s 50 

payments on LBA leased coal of $0.30 to $0.97 per ton (based on the range of bonus payments for the last 9 LBAs sold from 2004 thrmineable coal minus state’s 50 percent share. These figures could change based on the outcome of recent legislation that changed the perce
2.0 Proposed Action and Alternatives 

2-90 Final EIS, Wright Area Coal Lease Applications

Table 2-5 presents the comparisons assuming that Reno Road is moved and 

the underlying coal is recovered from the South Hilight Field tract. 

Table 2-6 presents the comparisons assuming that State Highway 450 and 

Hilight Road are not moved and the underlying coal is not recovered from the 

West Hilight Field tract. Table 2-7 presents the comparisons assuming that 

State Highway 450 and Hilight Road are moved and the underlying coal is 

recovered from the West Hilight Field tract. 

Table 2-8 presents the comparisons assuming that State Highway 450 and 

Hilight Road are not moved and the underlying coal is not recovered from the 

West Jacobs Ranch tract. Table 2-9 presents the comparisons assuming that 

State Highway 450 and Hilight Road are moved and the underlying coal is 

recovered from the West Jacobs Ranch tract. 

Table 2-10 presents the comparisons assuming that Mackey Road is not moved 

and the underlying coal is not recovered from the North Porcupine tract. Table 

2-11 presents the comparisons assuming that Mackey Road is moved and the 

underlying coal is recovered from the North Porcupine tract. 

Table 2-12 presents the comparisons assuming that the remaining 2.25-mile 

section of Antelope Road is not moved and the underlying coal is not recovered 

from the South Porcupine tract. Table 2-13 presents the comparisons 

assuming that the remaining 2.25-mile section of Antelope Road is moved and 

the underlying coal is recovered from the South Porcupine tract. 

Table 2-14 presents a comparative summary for all six LBA tracts of the direct 

and indirect environmental impacts of implementing each alternative as 

compared to the No Action Alternative. Each No Action Alternative assumes 

completion of currently permitted mining at the applicant mine for comparison 

to anticipated mining if the associated LBA tract is leased. Table 2-15 presents 

a comparative summary for the six LBA tracts regarding the cumulative 

environmental impacts of implementing each alternative for each tract. The 

environmental consequences of the Proposed Action and alternatives for each 

of the six LBA tracts are analyzed in Chapters 3 and 4. These summary impact 

tables are derived from the following explanation of impacts and magnitude. 

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 
2.0 Proposed 

Final EIS, Wright Area Coal Lease Applications 2-91 

Table 2-14. Summary Comparison of Magnitude1 and Duration of Direct and Indirect Impacts 

Action), the Proposed Action, Alternative 2, and Alternative 3 for the North Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

DESCRIPTION OF POTENTIAL IMPACT 

BY RESOURCE MAGNITUDE AND DURATION OF IMPAC

RESOURCE NAME ALTERNATIVE 1 

PROPOSED ACALTERNATIVE 

TOPOGRAPHY & PHYSIOGRAPHY (Applicable to all six tracts) Lower surface elevation Permanent topographic moderation, which could result in:  Microhabitat reduction  Habitat diversity reduction  Big game carrying capacity reduction  Reduction in water runoff and peak flows  Increased precipitation infiltration  Reduction in erosion  Potential enhanced vegetative productivity  Potential acceleration of groundwater recharge 

Moderate, permanent on existing mine areas Moderate, long term on existing mine areas Moderate, long term on existing mine areas Moderate, long term on existing mine areas Moderate, beneficial, long term on existing mine areas Moderate, beneficial, long term on existing mine areas Moderate, beneficial, long term on existing mine areas Moderate, beneficial, long term on existing mine areas Moderate, beneficial, long term on existing mine areas 

Same as AlternatSame as AlternatSame as AlternatSame as AlternatSame as AlternatSame as AlternatSame as AlternatSame as AlternatSame as Alternat

GEOLOGY AND MINERALS (Applicable to all six tracts) Removal of coal Removal and replacement of topsoil and overburden Physical characteristic alterations in replaced overburden Loss of unrecovered CBNG through venting and/or depletion of hydrostatic pressure Loss of access for development of sub-coal oil and gas resources and other minerals Destruction of paleontological resources that are not exposed on the surface 

Moderate, permanent on existing mine areas Moderate, permanent on existing mine areas Moderate, permanent on existing mine areas Moderate to substantial, permanent on existing mine areas Moderate, short term on existing mine areas Moderate, permanent on the existing mine areas 

Same as AlternatSame as AlternatSame as AlternatSame as AlternatSame as AlternatSame as Alternat

AIR QUALITY (Applicable to all six tracts) Particulate Emissions:  Elevated concentrations associated with projected 

average production of 270 mmtpy in compliance with ambient standards 

 Potential for public exposure to particulate emissions 

along State Highway 450, various county roads, and 

occupied dwellings in area 

 Potential for human health impacts as a result of 

exposure to particulate emissions 

Moderate, short term on existing mines and surrounding areas Minor to moderate, short term on existing mines and surrounding areas Minor to moderate, short term on existing mines and surrounding areas 

Same as Alternatsurrounding areayears Same as Alternatsurrounding areayears Same as Alternatsurrounding areayears 

1 Refer to Chapter 3 for a discussion on magnitude of impacts. 2 All impacts are assumed to be adverse unless noted otherwise. 
2.0 Proposed Action and Alternatives 

 2-92 Final EIS, Wright Area Table 2-14. Summary Comparison of Magnitude1 and Duration of Direct and Indirect Impacts 

Action), the Proposed Action, Alternative 2, and Alternative 3 for the North Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South Por

(Continued).

DESCRIPTION OF POTENTIAL IMPACT 

BY RESOURCE MAGNITUDE AND DURATION OF IMPAC

RESOURCE NAME ALTERNATIVE 1 

PROPOSED ACALTERNATIVE 

AIR QUALITY (Continued) (Applicable to all six tracts) NOx Emissions from Machinery: 

 Elevated concentrations associated with average 

production of 270 mmtpy in compliance with ambient standards 

 Potential for public exposure to NOx emissions from 

machinery along State Highway 450, various county roads, and occupied dwellings in area 

 Potential for human health impacts as a result of 

exposure to NOx emissions 

NOx Emissions from Blasting (in compliance with Black 

Thunder, Jacobs Ranch, and North Antelope Rochelle Mine Permit Blasting Conditions):  Potential for public exposure 

 Potential for human health impacts as a result of 

exposure to NOx emissions 

Visibility:  Elevated concentrations of fine particulate matter 

associated with average production of 270 mmtpy 

Acidification of Lakes: 

SO2 emissions derived from burning Black Thunder, 

Jacobs Ranch, and North Antelope Rochelle mines’ coal to produce power 

Moderate, short term on existing mines and surrounding areas Moderate, short term on existing mines and surrounding areas Moderate, short term on existing mines and surrounding areas No projected events No projected events Moderate, short term on existing mines and surrounding areas Moderate, short term in vicinity of power plants 

Same as Alternatsurrounding areayears Same as Alternatsurrounding areayears Same as Alternatsurrounding areayears No events projectNo events projectSame as Alternatsurrounding areayears Same as Alternat

WATER RESOURCES (Applicable to all six tracts) GROUNDWATER

Removal of coal and overburden aquifers Replacement of existing coal and overburden with unconsolidated backfill material Depressed water levels in overburden and coal aquifers adjacent to mines Change in hydraulic properties in backfilled areas Increase in TDS concentrations in backfilled areas Use of subcoal aquifers for water supply 

Moderate, short term on existing mine areas Moderate, permanent on existing mine areas Moderate, short to long term on existing mines and surrounding areas Negligible, long term on existing mine areas Moderate, long term on existing mine areas Negligible, short term on existing mines and surrounding areas 

Same as AlternatSame as AlternatSame as Alternatsurrounding areaSame as AlternatSame as AlternatSame as Alternatsurrounding area

1 Refer to Chapter 3 for a discussion on magnitude of impacts. 2 All impacts are assumed to be adverse unless noted otherwise. 
2.0 Proposed 

Final EIS, Wright Area Coal Lease Applications 2-93 

Table 2-14. Summary Comparison of Magnitude1 and Duration of Direct and Indirect Impacts 

Action), the Proposed Action, Alternative 2, and Alternative 3 for the North Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South Por

(Continued).

DESCRIPTION OF POTENTIAL IMPACT 

BY RESOURCE MAGNITUDE AND DURATION OF IMPAC

RESOURCE NAME ALTERNATIVE 1 

PROPOSED ACALTERNATIVE 

WATER RESOURCES (Continued)(Applicable to all six tracts)GROUNDWATER (Continued)

Decrease in water supply for groundwater-right holders having wells completed in the coal or overburden aquifers within the 5-foot drawdown areas for each mine SURFACE WATER

Diversion and disruption of surface drainage systems Reconstruction of surface drainage systems Increased runoff and erosion rates on disturbed lands due to vegetation removal Increased infiltration on reclaimed lands due to topographic moderation Increased runoff on reclaimed lands due to loss of soil structure Potential for adverse downstream effects as a result of sediment produced by large storms 

Moderate, long term on existing mines and surrounding areas Moderate, short term on existing mine areas Permanent on existing mine areas Moderate, short term on existing mine areas Moderate, beneficial, long term on existing mine areas Moderate, long term on existing mine areas Moderate, long term for existing mining operations 

Same as Alternatsurrounding areaSame as AlternatSame as AlternatSame as AlternatSame as AlternatSame as AlternatSame as Alternatoperations 

ALLUVIAL VALLEY FLOORS (Applicable to all six tracts) 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 tracts Removal and restoration of AVFs determined not to be significant to agriculture Disruptions to streamflows supplying downstream AVFs 

Moderate, short term for existing mining operations Negligible, short term on existing leases 

Same as AlternatSame as Alternat

WETLANDS (Applicable to all six tracts) Removal of jurisdictional wetlands and loss of wetland function until reclamation occursRemoval of non-jurisdictional wetlands and loss of wetland function until reclamation occurs

Moderate, short term on existing mining operations; jurisdictional wetlands would be replaced as required under Section 404 of the Clean Water Act Moderate, short term to long term on existing mining operations; non-jurisdictional wetlands would be replaced as required by the surface land owner or WDEQ/LQD 

Same as AlternatSame as Alternat

1 Refer to Chapter 3 for a discussion on magnitude of impacts. 2 All impacts are assumed to be adverse unless noted otherwise. 
2.0 Proposed Action and Alternatives 

 2-94 Final EIS, Wright Area CTable 2-14. Summary Comparison of Magnitude1 and Duration of Direct and Indirect Impacts 

Action), the Proposed Action, Alternative 2, and Alternative 3 for the North Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South Por

(Continued).

DESCRIPTION OF POTENTIAL IMPACT 

BY RESOURCE MAGNITUDE AND DURATION OF IMPAC

RESOURCE NAME ALTERNATIVE 1 

PROPOSED ACALTERNATIVE 

SOILS (Applicable to all six tracts) Changes in physical properties after reclamation would include: 

Increased near-surface bulk density and decreased soil infiltration rate resulting in increased potential for soil 

erosion More uniformity in soil type, thickness, and texture Decreased runoff due to topographic modification 

Changes in biological properties in soils that are stockpiled before reclamation would include: 

Reduction in organic matter Reduction in microorganism population Reduction in seeds, bulbs, rhizomes, and live plant parts 

Changes in chemical properties would include: 

More uniform soil nutrient distribution

Moderate, long term on existing mine areas Moderate, beneficial, long term on existing mine areas Moderate, beneficial, long term on existing mine areas Moderate, short to long term on existing mine areas Moderate, short to long term on existing mine areas Moderate, short to long term on existing mine areas Moderate, beneficial, long term on existing mine areas 

Same as AlternatSame as AlternatSame as AlternatSame as AlternatSame as AlternatSame as AlternatSame as Alternat

VEGETATION (Applicable to all six tracts) During mining: 

Progressive removal of existing vegetation Increased erosion Wildlife habitat and livestock grazing loss 

After revegetation: 

Changes in vegetation patterns Reduction in vegetation diversity Reduction in shrub density Decreased big game habitat carrying capacity Decreased habitat for shrub dependent species Potential invasion of non-native plant species 

Moderate, short term on existing mine areas Moderate, short term on existing mine areas Moderate, short term on existing mine areas Negligible, long term on existing mine areas Negligible, long term on existing mine areas Moderate, long term on existing mine areas Moderate, long term on existing mine areas Moderate, long term on existing mine areas Moderate, short term on existing mine areas 

Same as AlternatSame as AlternatSame as AlternatSame as AlternatSame as AlternatSame as AlternatSame as AlternatSame as AlternatSame as Alternat

1 Refer to Chapter 3 for a discussion on magnitude of impacts. 2 All impacts are assumed to be adverse unless noted otherwise. 
2.0 Proposed 

Final EIS, Wright Area Coal Lease Applications 2-95 

Table 2-14. Summary Comparison of Magnitude1 and Duration of Direct and Indirect Impacts 

Action), the Proposed Action, Alternative 2, and Alternative 3 for the North HilighField, West Hilight Field, West Jacobs Ranch, North Porcupine, and South Po(Continued).

DESCRIPTION OF POTENTIAL IMPACT 

BY RESOURCE MAGNITUDE AND DURATION OF IMPAC

RESOURCE NAME ALTERNATIVE 1 

PROPOSED ACALTERNATIVE 

WILDLIFE (Applicable to all six tracts)Big game displacement from active mining areas Increased competition on adjacent undisturbed or reclaimed lands, especially big game Restriction of wildlife movement, especially big game Increased mortality of small mammals Displacement of small and medium-sized mammals Surface and noise disturbance of active sage grouse leks Disturbance of sage grouse nesting habitat during mining Loss of sage grouse nesting habitat after reclamation Alteration of plant and animal communities after reclamation Abandonment of raptor nests Loss of foraging habitat for raptors Loss of nesting and foraging habitat for Migratory Birds of Management Concern (including sage-grouse) Reduction in waterfowl resting and feeding habitat Loss of habitat for aquatic species, amphibians and reptiles Road kills by mine-related traffic Reduction in habitat carrying capacity and habitat diversity on reclaimed lands Potential reduction in microhabitats on reclaimed lands 

Moderate, short term on existing mine areas Moderate, short term on adjacent areas Moderate, short term on existing mine areas Moderate, short term on existing mine areas Moderate, short term on existing mine areas Moderate, short to long term on existing mine areas Moderate, short term on existing mine areas Moderate, long term on existing mine areas Negligible, short term on existing mine areas Negligible, short term on existing mine areas Negligible, short to long term on existing mine areas Negligible, short to long term on existing mine areas Negligible, short term on existing mine areas Negligible, short term on existing mine areas Moderate, long term on existing mine areas Moderate, long term on existing mine areas Moderate, long term on existing mine areas 

Same as AlternatiSame as AlternatiSame as AlternatiSame as AlternatiSame as AlternatiSame as AlternatiSame as AlternatiSame as AlternatiSame as AlternatiSame as AlternatiSame as AlternatiSame as AlternatiSame as AlternatiSame as AlternatiSame as AlternatiSame as AlternatiSame as Alternati

THREATENED, ENDANGERED, PROPOSED, AND CANDIDATE SPECIES (Refer to Appendix G in this EIS) (Applicable to all six tracts) Ute ladies’-tresses (Threatened) Blowout penstemon (Endangered) Greater sage-grouse (Candidate) 

As determined by previous consultation with USFWS for all listed species at the time 

No effect No effect 

LAND USE AND RECREATION (Applicable to all six tracts) 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 

Moderate, long term on existing mine areas Moderate, long term on existing mine areas Moderate, short term on existing mine areas Moderate, short term on existing mine areas Moderate, short term on existing mine areas 

Same as AlternatiSame as AlternatiSame as AlternatiSame as AlternatiSame as Alternati

1 Refer to Chapter 3 for a discussion on magnitude of impacts. 2 All impacts are assumed to be adverse unless noted otherwise. 
2.0 Proposed Action and Alternatives 

 2-96 Final EIS, Wright Area Table 2-14. Summary Comparison of Magnitude1 and Duration of Direct and Indirect Impacts 

Action), the Proposed Action, Alternative 2 and Alternative 3 for the North Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South Po(Continued).

DESCRIPTION OF POTENTIAL IMPACT 

BY RESOURCE MAGNITUDE AND DURATION OF IMPAC

RESOURCE NAME ALTERNATIVE 1 

PROPOSED ACALTERNATIVE 

CULTURAL RESOURCES (Applicable to all six tracts)Sites that are not eligible for NRHP Sites that are eligible for NRHP Sites that are unevaluated for eligibility 

Ineligible sites may be destroyed without further work on existing mine areas 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 on existing mine areas Impacts to unevaluated sites are not permitted; unevaluated sites would be evaluated prior to mining on existing mine areas 

Same as AlternatiSame as AlternatiSame as Alternati

NATIVE AMERICAN CONCERNS (Applicable to all six tracts) No impact identified on existing mine areas Same as AlternatiVISUAL RESOURCES (Applicable to all six tracts) 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 

Moderate, short term on existing mine areas Moderate, short term on existing mine areas Negligible, long term on existing mine areas Moderate, short to long term on existing mine areas 

Same as AlternatiSame as AlternatiSame as AlternatiSame as Alternati

NOISE (Applicable to all six tracts) Increased noise levels Moderate to substantial, short term on existing mines, 

surrounding areas (including occupied dwellings and businesses) within 2,500 feet of mining activities 

Same as Alternatiand surrounding 

TRANSPORTATION FACILITIES (Applicable to all six tracts) Use of railroads and existing Black Thunder, Jacobs Ranch, and North Antelope Rochelle mine infrastructure to ship coal Employee and service contractor use of highways to and from mine sites

Moderate, for duration of existing approved mining operations Moderate, for duration of existing approved mining operations 

Same as Alternatiyears Same as Alternatiyears 

1 Refer to Chapter 3 for a discussion on magnitude of impacts. 2 All impacts are assumed to be adverse unless noted otherwise. 
2.0 Proposed 

Final EIS, Wright Area Coal Lease Applications 2-97 

Table 2-14. Summary Comparison of Magnitude1 and Duration of Direct and Indirect Impacts 

Action), the Proposed Action, Alternative 2, and Alternative 3 for the North HilighField, West Hilight Field, West Jacobs Ranch, North Porcupine, and South Po(Continued).

DESCRIPTION OF POTENTIAL IMPACT 

BY RESOURCE MAGNITUDE AND DURATION OF IMPAC

RESOURCE NAME ALTERNATIVE 1 

PROPOSED ACALTERNATIVE 

TRANSPORTATION FACILITIES (Continued) (Applicable to all six tracts) Relocation of pipelines Relocation of utility lines Relocation of county roads, if approved by Campbell County Commissioners, to allow recovery of coal under lease Mining operations near State Highway 450 

Negligible, short to long term on existing mine areas Negligible, short to long term on existing mine areas No impact on existing mine areas Moderate, for duration of existing approved mining operations (Black Thunder Mine only) 

Same as AlternatiSame as AlternatiModerate, long termine areas Same as Alternatiyears (Black Thunonly) 

HAZARDOUS AND SOLID WASTE (Applicable to all six tracts) Waste generated by mining operations Negligible, for duration of existing approved mining 

operations 

Same as Alternatiyears 

SOCIOECONOMICS (Applicable to all six tracts) 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 

Substantial benefit, short term for existing approved mining operations Substantial benefit, short term for existing approved mining operations Substantial benefit, 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 Alternatiyears Same as Alternatiyears Same as Alternatiyears Same as Alternatiyears Same as Alternatiyears 

1 Refer to Chapter 3 for a discussion on magnitude of impacts.2 All impacts are assumed to be adverse unless noted otherwise. 
2.0 Proposed Action and Alternatives 

 2-98 Final EIS, Wright Area 

Table 2-15. Summary Comparison of Magnitude and Duration of Cumulative Impacts1, 2.

DESCRIPTION OF POTENTIAL IMPACT 

BY RESOURCE MAGNITUDE, TYPE, AND DURATION OF IM

RESOURCE NAME ALTERNATIVE 1 

PROPOSED and ALTERN

TOPOGRAPHY & PHYSIOGRAPHY▪ Alteration of topography following reclamation of coal 

disturbance areas 

▪ Alteration of topography to accommodate coal-related, oil and 

gas, and oil- and gas-related facilities 

▪ Permanent topographic moderation following reclamation ▪ Long term to permanent limited changes in discrete, 

scattered areas 

▪ Same as Alt▪ Same as Alt

GEOLOGY AND MINERALS▪ Recovery of coal resulting in reduction in coal resources and 

disturbance and replacement of overburden and topsoil 

▪ Surficial disturbance and reclamation on oil and gas well sites 

and associated facilities 

▪ Moderate, long term to permanent ▪ Moderate, long term to permanent 

▪ Same as Alt▪ Same as Alt

PALEONTOLOGY▪ Coal, coal-related, oil and gas, and oil- and gas-related 

development disturbance of PFYC Class 5 Wasatch and Class 3 Fort Union formations 

▪ Permanent potential adverse effects to scientifically 

significant fossils that are present but not visible prior to disturbance 

▪ Same as Alt

AIR QUALITYImpacts to Wyoming near-field receptors: 

▪ 24-hour PM10 and PM2.5▪ Annual PM10▪ Annual PM2.5▪ All other parameters 

Impacts to Montana near-field receptors: 

▪ All parameters 

▪ Maximum modeled impacts occurring at isolated receptors 

show localized exceedances of the WAAQS and NAAQS for the base year (2004) as well as for both coal production scenarios for 2015 and 2020 

▪ Maximum modeled impacts at peak receptors show 20% 

increase from base year (2004) but in compliance with WAAQS for both coal production scenarios for 2020, but exceed the WAAQS for both coal production scenarios for 2015 

▪ Maximum modeled impacts at peak receptors show 20% 

increase from base year (2004) and localized exceedances of the WAAQS and NAAQS for both coal production scenarios for 2015 and 2020 

▪ Modeled impacts in compliance with WAAQS and NAAQS for 

both coal production scenarios for 2015 and 2020 

▪ Impacts at all Montana receptors would be in compliance 

with NAAQS and Montana AAQS for all pollutants and averaging periods. Impacts are predicted to decrease for annual NO2, PM10 and PM2.5 relative to the base year (2004) 

▪ Same as Alt▪ Same as Alt▪ Same as Alt▪ Same as Alt▪ Same as Alt

1 Cumulative impact discussion in this table and in Chapter 4 is based on the PRB Coal Review analyses (BLM 2005a-f, 2006b-d, 2008h-i, 2009b2 All impacts are assumed to be adverse unless noted otherwise. 
2.0 Proposed 

Final EIS, Wright Area Coal Lease Applications 2-99 

Table 2-15. Summary Comparison of Magnitude and Duration of Cumulative Impacts1, 2 (Continu

DESCRIPTION OF POTENTIAL IMPACT 

BY RESOURCE MAGNITUDE, TYPE, AND DURATION OF IM

RESOURCE NAME ALTERNATIVE 1 

PROPOSED and ALTERN

AIR QUALITY (Continued) Non-regulatory PSD Impacts at Class I and Sensitive Class II Areas: 

▪ Class I Northern Cheyenne Indian Reservation▪ Class I Badlands National Park ▪ Class I Wind Cave National Park ▪ All Sensitive Class II Areas (including Cloud Peak 

Wilderness Area and Crow Indian Reservation) 

Visibility Impacts: 

▪ Class I Areas ▪ Sensitive Class II Areas 

Acid Deposition Impacts: 

▪ Florence Lake ▪ Upper Frozen Lake ▪ All other modeled sensitive lakes 

▪ Modeled impacts above Class I increment levels for 24-hour 

PM10 for base year (2004) and both coal production 

scenarios for 2020; for 24-hour SO2 for both coal 

production scenarios for 2020; for 3-hour SO2 for upper 

coal production scenario for 2020 

▪ Modeled impacts above Class I increment levels for 24-hour 

PM10 for both coal production scenarios for 2020 

▪ Modeled impacts above Class I increment levels for 24-hour 

PM10 for base year (2004) and both coal production 

scenarios for 2020 

▪ Modeled impacts below Class II increments for all Sensitive 

Class II areas for base year (2004) and both coal production scenarios for 2020 

▪ Modeled impacts show 200 or more days a year during the 

base year (2004) with a change of 1.0 dv or greater at the Northern Cheyenne Indian Reservation, Badlands National Park, and Wild Cave National Park.; the same three Class I areas have the highest predicted visibility change in 2020 

▪ All but four areas have more than 100 days a year during 

the base year (2004) with a change of 1.0 dv or greater 

▪ All modeled impacts below the deposition threshold values 

for nitrogen and sulfur compounds 

▪ Modeled impact above 10 percent ANC threshold for both 

coal production scenarios for 2015 and 2020 

▪ Modeled impact above 1 μeq/L ANC for both coal 

production scenarios for 2015 and 2020 

▪ Modeled impact below 10 percent ANC threshold values for 

both coal production scenarios for 2015 and 2020 

▪ Same as Alt▪ Same as Alt▪ Same as Alt▪ Same as Alt▪ Same as Alt▪ Same as Alt▪ Same as Alt▪ Same as Alt▪ Same as Alt▪ Same as Alt

GROUNDWATER RESOURCES▪ Removal of coal aquifer and replacement with backfill material ▪ Lowering of water levels in aquifers around the mines ▪ Water level decline in sub-coal aquifers as a result of all 

development 

▪ Change in groundwater quality as a result of all development ▪ Overlapping drawdown in the coal aquifer caused by surface 

mining and CBNG development 

▪ Moderate, permanent for mining areas ▪ Moderate, long term in area immediately west of mines ▪ No cumulative impacts anticipated ▪ No cumulative impacts anticipated ▪ Additive, long term in area immediately west of surface coal 

mines 

▪ Same as Alt▪ Same as Alt▪ Same as Alt▪ Same as Alt▪ Same as Alt

1 Cumulative impact discussion in this table and in Chapter 4 is based on the PRB Coal Review analyses (BLM 2005a-f, 2006b-d, 2008h-i, 2009b2 All impacts are assumed to be adverse unless noted otherwise. 
2.0 Proposed Action and Alternatives 

 2-100 Final EIS, Wright Area C

Table 2-15. Summary Comparison of Magnitude and Duration of Cumulative Impacts1, 2 (Continu

DESCRIPTION OF POTENTIAL IMPACT 

BY RESOURCE MAGNITUDE, TYPE, AND DURATION OF IM

RESOURCE NAME ALTERNATIVE 1 

PROPOSED and ALTERN

SURFACE WATER RESOURCES▪ Surface disturbance of intermittent and ephemeral streams and 

scattered ponds and reservoirs as a result of coal mining, coalrelated, 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, coalrelated, oil and gas, and oil- and gas-related development 

▪ Moderate, short term ▪ Moderate, short term ▪ Moderate, short term 

▪ Same as Alt▪ Same as Alt▪ Same as Alt

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 

▪ Not permitted by regulation ▪ AVFs disturbed by mining must be restored to essential 

hydrologic function; no cumulative impacts anticipated 

▪ Same as Alt▪ Same as Alt

SOILS▪ Coal mining, coal-related, oil and gas, and oil- and gas-related 

disturbance and replacement of soil resources 

▪ CBNG water disposal impacts to soil resources 

▪ 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 Alt▪ Same as Alt

VEGETATION ▪ Coal mining, coal-related, oil and gas, and oil- and gas-related 

removal and replacement of native vegetation 

▪ Coal mining, coal-related, oil and gas, and oil- and gas-related 

impacts to Special Status Plant Species 

▪ Coal mining, coal related, oil and gas, and oil- and gas-related 

dispersal of noxious and invasive species

▪ Moderate, short to long term impacts due to potential 

differences in species composition and presence and size of woody species on reclaimed lands 

▪ Potential incremental loss of alteration of potential or known 

habitat 

▪ Potential displacement of native species and changes in 

species composition 

▪ Same as Alt▪ Same as Alt▪ Same as Alt

WETLAND AND RIPARIAN VEGETATION ▪ CBNG-related discharge of produced water ▪ Moderate, short to long term creation of wetlands in areas 

that previously supported upland vegetation 

▪ Same as Alt

WILDLIFE▪ Direct and indirect coal mining, coal-related, oil and gas, and oiland 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-related 

disturbance of game and nongame species habitat during project development and operation 

▪ Coal mining, coal related, oil and gas, and oil- and gas-related 

habitat changes after reclamation 

▪ Moderate, short term ▪ Moderate, short term loss of all types of habitat present in 

disturbed areas 

▪ Moderate, long term change in habitat with potential 

changes in associated wildlife populations 

▪ Same as Alt▪ Same as Alt▪ Same as Alt

1 Cumulative impact discussion in this table and in Chapter 4 is based on the PRB Coal Review analyses (BLM 2005a-f, 2006b-d, 2008h-i, 2009b2 All impacts are assumed to be adverse unless noted otherwise. 
2.0 Proposed 

Final EIS, Wright Area Coal Lease Applications 2-101 

Table 2-15. Summary Comparison of Magnitude and Duration of Cumulative Impacts1, 2 (Continu

DESCRIPTION OF POTENTIAL IMPACT 

BY RESOURCE MAGNITUDE, TYPE, AND DURATION OF IM

RESOURCE NAME ALTERNATIVE 1 

PROPOSED and ALTERN

FISHERIES▪ Alteration or loss of habitat due to coal mining, coal-related, oil 

and gas, and oil- and gas-related development 

▪ Changes in water quality as a result of surface disturbance or 

introduction of contaminants into drainages caused by coal mining, coal-related, oil and gas, and oil- and gas-related development 

▪ Changes in available habitat as a result of water withdrawals or 

discharges related to coal mining, coal-related, oil and gas, and oil- and gas-related development 

▪ Moderate, short to long term ▪ Moderate, short to long term ▪ Moderate, short term 

▪ Same as Alt▪ Same as Alt▪ Same as Alt

SPECIAL STATUS SPECIES▪ Direct and indirect coal mining, coal-related, oil and gas, and oiland gas-related development impacts, including direct mortality, 

breeding area, nest or burrow abandonment, sage-grouse lek abandonment, noise and increased human presence 

▪ Coal mining, coal-related, oil and gas, and oil- and gas-related 

disturbance of habitat (breading and nesting) during project development and operation 

▪ Coal mining, coal related, oil and gas, and oil- and gas-related 

habitat changes after reclamation 

▪ Moderate, short term ▪ Moderate, short term loss of all types of special status 

species habitat present in disturbed areas 

▪ Moderate, long term change in habitat with potential 

changes in associated populations of special status species 

▪ Same as Alt▪ Same as Alt▪ Same as Alt

LAND USE AND RECREATION▪ Loss of forage and range improvements and restriction of 

livestock movement due to coal mining, coal-related, oil and gas, and oil- and gas-related development 

▪ Disturbance of developed recreation sites by coal mining, coalrelated, oil and gas, and oil- and gas-related development ▪ Reduction or degradation of opportunities for dispersed 

recreation activities related to coal mining, coal-related, oil and gas, and oil- and gas-related development 

▪ Moderate, short term ▪ Negligible, short term ▪ Moderate, short term on existing mine areas 

▪ Same as Alt▪ Same as Alt▪ Same as Alt

CULTURAL RESOURCES▪ Disturbance of cultural resource sites ▪ Moderate, permanent ▪ Same as AltTRANSPORTATION AND UTILITIES▪ Movement of segments of existing public roads, pipelines, 

transmission lines, or railroads to accommodate coal mining development 

▪ Increased vehicular traffic on roads and highways due to 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 pipeline 

facilities and transmission lines to transport coal, oil and gas, and electricity 

▪ Moderate, long term to permanent, disruptive effects would 

be minimized 

▪ Moderate, short term ▪ Moderate, short to long term 

▪ Same as Alt▪ Same as Alt▪ Same as Alt

1 Cumulative impact discussion in this table and in Chapter 4 is based on the PRB Coal Review analyses (BLM 2005a-f, 2006b-d, 2008h-i, 2009b2 All impacts are assumed to be adverse unless noted otherwise. 
2.0 Proposed Action and Alternatives 

 2-102 Final EIS, Wright Area C

Table 2-15. Summary Comparison of Magnitude and Duration of Cumulative Impacts1, 2 (Continu

DESCRIPTION OF POTENTIAL IMPACT 

BY RESOURCE MAGNITUDE, TYPE, AND DURATION OF IM

RESOURCE NAME ALTERNATIVE 1 

PROPOSED and ALTERN

SOCIOECONOMICS▪ Increases in employment related to coal mining, coal-related, oil 

and gas, and oil- and gas-related development 

▪ Increases in personal income due to employment increases 

related to coal mining, coal-related, oil and gas, and oil- and gasrelated development 

▪ Increase in population due to employment increases related to 

coal mining, coal-related, oil and gas, and oil- and gas-related development 

▪ Expansion of housing supply due to employment increases 

related to coal mining, coal-related, oil and gas, and oil- and gasrelated development 

▪ Increases in school enrollment due to employment increases 

related to coal mining, coal-related, oil and gas, and oil- and gasrelated development 

▪ Need for additional local government facilities and services due to 

employment increases related to coal mining, coal-related, oil and gas, and oil- and gas-related development 

▪ Increased federal, state, and local revenues related to coal 

mining, coal-related, oil and gas, and oil-and gas-related development 

▪ Significant, short to long term ▪ Significant, beneficial, short to long term ▪ Significant, short to long term ▪ Significant, short to long term ▪ Moderate, short term ▪ Moderate, short to long term ▪ Significant, beneficial, short to long term 

▪ Same as Alt▪ Same as Alt▪ Same as Alt▪ Same as Alt▪ Same as Alt▪ Same as Alt▪ Same as Alt

1 Cumulative impact discussion in this table and in Chapter 4 is based on the PRB Coal Review analyses (BLM 2005a-f, 2006b-d, 2008h-i, 2009b2 All impacts are assumed to be adverse unless noted otherwise. 
2.0 Proposed Action and Alternatives 

Final EIS, Wright Area Coal Lease Applications 2-103 

(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 insignificant following completion of reclamation. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-1 

3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

This chapter describes the existing conditions of the physical, biological, 

cultural, and socioeconomic resources in the general Wright analysis area 

which includes all six of the Lease by Application (LBA1) tracts (the affected 

environment). This chapter also analyzes the direct and indirect impacts (the 

environmental consequences) to those resources if the tracts are leased and 

mined under the Proposed Action or Alternative 2 or 3. The potential 

environmental consequences of the No Action Alternative (Alternative 1, 

rejecting the application for the tract) are also considered in this chapter. 

In addition to this EIS, a separate document entitled Supplementary 

Information on the Affected Environment in the General Analysis Areas for the 

Wright Area Coal Lease Applications EIS has been prepared. The supplemental 

document provides detailed site-specific information on the existing 

environment associated with the North Hilight Field, South Hilight Field, West 

Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA 

tracts. Copies of the supplemental information document are available upon 

request and can be viewed at the BLM offices in Casper and Cheyenne. 

Furthermore, 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 Alternative 2 or 3 for each tract. 

As discussed in Chapter 2, regulatory compliance and mitigation and 

monitoring measures that are required by federal and/or state law are 

considered to be part of the Proposed Action and Alternative 2 or 3 for each 

tract. 

Under the Proposed Action for each tract, the tract as applied for would be 

offered for lease at one sale. As discussed in Chapter 2, Bureau of Land 

Management (BLM) has identified a study area for each LBA tract that consists 

of the tract as applied for and adjacent lands that BLM is considering adding to 

the tract. BLM is evaluating these study areas 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. 

Alternative 2 for each tract evaluates holding one sale for a tract modified by 

adding some or all of BLM’s study area to the tract. Alternative 3 for the West 

Hilight Field tract evaluates holding one sale for the tract modified by adding 

some or all of BLM’s study area and or some or all of Ark Land Company’s 

(ALC’s) permitted Northwest Rail Loop Amendment Area to the tract. The 

Proposed Action and Alternative 2 or Alternative 3 for each LBA tract will be 

referred to collectively as the Action Alternatives. 

 

1 Refer to page xxvii for a list of abbreviations and acronyms used in this document. 
3.0 Affected Environment and Environmental Consequences 

3-2 Final EIS, Wright Area Coal Lease Applications

If any of the tracts are leased under the Proposed Action or Alternative 2 or 3, it 

is assumed that an area larger than the tract would have to be disturbed in 

order to recover all of the coal in the tract. The disturbances outside the coal 

removal area would be due to activities like overstripping, highwall backsloping 

(including catch benches), highwall reduction after mining to match 

undisturbed topography, and construction of flood control and sediment 

control structures. For analysis purposes, this disturbance buffer is assumed 

to extend 1⁄4 mile outside the BLM study area boundary, where future mining 

disturbance can occur. In this environmental impact statement (EIS), the 

general analysis area for each tract is defined as the BLM study area (the LBA 

tract as applied for and the additional area evaluated under Alternative 2) plus 

the 1⁄4-mile disturbance buffer. 

Figure 3-1 shows the general Wright analysis area for most environmental 

resources. The general Wright analysis area does not have a defined boundary 

but includes the combined general analysis areas for the North Hilight Field, 

South Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, 

and South Porcupine LBA Tracts. 

The resources that are addressed here were identified during the scoping 

process or interdisciplinary team review as having the potential to be affected. 

Critical elements of the human environment (BLM 2008a) that could potentially 

be affected by the Proposed Action or Alternative 2 or 3 for each tract include 

air quality, cultural resources, Native American religious concerns, T&E 

species, U.S. Department of Agriculture-Forest Service Region 2 Sensitive 

Species and Thunder Basin National Grassland plant species of local concern, 

migratory birds, 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, floodplains, wild and scenic rivers, and wilderness) are not present 

in the general Wright analysis area and are not addressed further. In addition 

to the critical elements that are potentially present in the general Wright 

analysis area, this EIS discusses the status and potential effects of mining 

each 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. 

Tables 3-1 through 3-6 show the total leased and disturbance areas for the 

existing Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines 

(which represent the No Action Alternatives), and how the total leased areas 

and estimated total mine disturbance areas would change under the Proposed 

Action, Alternative 2 or Alternative 3. 

As indicated in Tables 3-1 through 3-3, Black Thunder Mine’s current coal 

leases include approximately 22,416 acres. Under the mine’s currently 

approved mining and reclamation plan, a total of approximately 26,490 acres 
Converse County

Campbell County

T.

44

N.

R. 71 W.

T.

43

N.

T.

42

N.

T.

41

N.

T.

40

N.

R. 70 W. R. 69 W.

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

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

T.

40

N.

WEST JACOBS

RANCH LBA

TRACT

NORTH

PORCUPINE

LBA TRACT

Jacobs Ranch Mine

Black

Thunder

Mine

North Antelope

Rochelle Mine

Antelope

Mine

WEST HILIGHT

FIELD LBA TRACT

SOUTH HILIGHT

FIELD LBA TRACT

Reno Road

Road Jacobs

Mackey

Antelope

Edwards

Matheson Road

Reno Road School Creek

State

 59 Highway

Hilight Road

Keeline Road

Road

State

450 Highway

Road

Road

Road

Antelope

Road

Road

BNSF &

BNSF & UP RR

Matheson RoadUP RR

BNSF & UP RR

NORTH HILIGHT

FIELD LBA TRACT

SOUTH

PORCUPINE

LBA TRACT

Shroyer

Small

Road

South Hilight Field LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA

Tract as Applied for

West Hilight Field LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

LEGEND

South Hilight Field LBA

Tract as Applied for

West Jacobs Ranch LBA

Tract as Applied for

West Jacobs Ranch LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

South Porcupine LBA

Tract as Applied for

South Porcupine LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

SCALE: 1"=3 MILES

North Hilight Field LBA

Tract as Applied for

Existing Lease Boundaries

North Porcupine LBA

Tract as Applied for

North Porcupine LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA

Tract Under Alternative 3

North Hilight Field LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-1. General Wright Analysis Area.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-3
3.0 Affected Environment and Environmental Consequences 

3-4 Final EIS, Wright Area Coal Lease Applications

Table 3-1. Comparison of Existing and Proposed Black Thunder Mine 

Disturbance Area and Mining Operations for the North Hilight 

Field LBA Tract. 

No Action Alternative 

(Existing Permit Area) 

Proposed 

Action Alternative 2 

Additional Lease Area (Acres) --- 2,613.5 7,139.4 

Total Lease Area (Acres)1 22,416.2 25,029.7 29,555.6 

Increase in Lease Area (Percent) --- 11.7 31.8 

Estimated Additional Mine 

Disturbance Area (Acres)2 --- 5,053.0 12,908.8 

Estimated Total Mine Disturbance 

Area (Acres) 26,490.2 31,543.2 39,399.0 

Increase in Estimated Disturbance 

Area (Percent) --- 19.1 48.7 

Estimated Additional Recoverable Coal 

(Million Tons)3 --- 263.4 652.8 

Estimated Recoverable Coal for Mine 

as of 1/09 (Million Tons) 1,169.4 1,432.8 1,822.2 

Increase in Estimated Recoverable 

Coal as of 1/09 (Percent) --- 22.5 55.8 

1 Includes federal, state, and private 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 (92 percent). 

Table 3-2. Comparison of Existing and Proposed Black Thunder Mine 

Disturbance Area and Mining Operations for the South Hilight 

Field LBA Tract. 

No Action Alternative 

(Existing Permit Area) 

Proposed 

Action Alternative 2 

Additional Lease Area (Acres) --- 1,976.7 2,922.4 

Total Lease Area (Acres)1 22,416.2 24,392.9 25,338.6 

Increase in Lease Area (Percent) --- 8.8 13.0 

Estimated Additional Mine Disturbance 

Area (Acres)2 --- 1,126.0 2,731.4 

Estimated Total Mine Disturbance Area 

(Acres) 26,490.2 27,616.2 29,221.6 

Increase in Estimated Disturbance 

Area (Percent) --- 4.3 10.3 

Estimated Additional Recoverable Coal 

(Million Tons)3 --- 213.6 304.3 

Estimated Recoverable Coal for Mine as 

of 1/09 (Million Tons) 1,169.4 1,383.0 1,473.7 

Increase in Estimated Recoverable Coal 

as of 1/09 (Percent) --- 18.2 26.0 

1 Includes federal, state, and private 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 (92 percent). 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-5 

Table 3-3. Comparison of Existing and Proposed Black Thunder Mine 

Disturbance Area and Mining Operations for the West Hilight 

Field LBA Tract. 

No Action 

Alternative

(Existing 

Permit Area)

Proposed 

Action Alternative 2 Alternative 3

Additional Lease Area (Acres) --- 2,370.5 7,191.3 8,570.1 

Total Lease Area (Acres)1 22,416.2 24,786.7 29,607.5 30,986.3 

Increase in Lease Area (Percent) --- 10.6 32.1 38.2 

Estimated Additional Mine Disturbance 

Area (Acres)2 --- 6,351.4 10,250.8 10,250.8 

Estimated Total Mine Disturbance Area 

(Acres) 26,490.2 32,841.6 36,741.0 36741.0 

Increase in Estimated Disturbance Area 

(Percent) --- 24.0 38.7 38.7 

Estimated Additional 

Recoverable Coal (Million Tons)3 --- 377.9 965.2 965.2 

Estimated Recoverable Coal for Mine as of 

1/09 (Million Tons) 1,169.4 1,547.3 2,125.6 2,125.6 

Increase in Estimated Recoverable Coal as 

of 1/09 (Percent) --- 32.3 82.5 82.5 

1 Includes federal, state, and private 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 (92 percent). 

Table 3-4. Comparison of Existing and Proposed Jacobs Ranch Mine 

Disturbance Area and Mining Operations for the West Jacobs 

Ranch LBA Tract. 

No Action Alternative 

(Existing Permit Area) 

Proposed 

Action Alternative 2 

Additional Lease Area (Acres) --- 5,944.4 8,076.2 

Total Lease Area (Acres)1 8,604.7 14,549.1 16,680.9 

Increase in Lease Area (Percent) --- 69.1 93.9 

Estimated Additional Mine Disturbance 

Area (Acres)2 --- 7,023.0 9,370.0 

Estimated Total Mine Disturbance Area 

(Acres) 15,261.5 22,284.5 24,631.5 

Increase in Estimated Disturbance 

Area (Percent) --- 46.0 61.4 

Estimated Additional Recoverable Coal 

(Million Tons)3 --- 669.6 912.6 

Estimated Recoverable Coal for Mine as 

of 1/09 (Million Tons) 379.4 1,049.0 1,292.0 

Increase in Estimated Recoverable Coal 

as of 1/09 (Percent) --- 176.5 240.5 

1 Includes federal, state, and private 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 (90 percent). 
3.0 Affected Environment and Environmental Consequences 

3-6 Final EIS, Wright Area Coal Lease Applications

Table 3-5. Comparison of Existing and Proposed North Antelope Rochelle 

Mine Disturbance Area and Mining Operations for the North 

Porcupine LBA Tract. 

No Action Alternative 

(Existing Permit Area) 

Proposed 

Action Alternative 2 

Additional Lease Area (Acres) --- 5,795.8 7,366.8 

Total Lease Area (Acres)1 18,066.0 23,861.8 25,432.8 

Increase in Lease Area (Percent) --- 32.1 40.8 

Estimated Additional Mine Disturbance 

Area (Acres)2 --- 9,864.0 11,444.0 

Estimated Total Mine Disturbance Area 

(Acres) 27,443.0 37,307.0 38,887.0 

Increase in Estimated Disturbance 

Area (Percent) --- 35.9 41.7 

Estimated Additional Recoverable Coal 

(Million Tons)3 --- 601.2 745.4 

Estimated Recoverable Coal for Mine as 

of 1/09 (Million Tons) 933.8 1,535.0 1,679.2 

Increase in Estimated Recoverable Coal 

as of 1/09 (Percent) --- 64.4 79.8 

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 (92 percent). 

Table 3-6. Comparison of Existing and Proposed North Antelope Rochelle 

Mine Disturbance Area and Mining Operations for the South 

Porcupine LBA Tract. 

No Action Alternative 

(Existing Permit Area) 

Proposed 

Action Alternative 2 

Additional Lease Area (Acres) --- 3,186.0 3,568.0 

Total Lease Area (Acres)1 18,066.0 21,252.0 21,634.0 

Increase in Lease Area (Percent) --- 17.6 19.7 

Estimated Additional Mine Disturbance 

Area (Acres)2 --- 3,366.0 4,068.0 

Estimated Total Mine Disturbance Area 

(Acres) 27,443.0 30,809.0 31,511.0 

Increase in Estimated Disturbance 

Area (Percent) --- 12.3 14.8 

Estimated Additional Recoverable Coal 

(Million Tons)3 --- 309.7 339.3 

Estimated Recoverable Coal for Mine as 

of 1/09 (Million Tons) 933.8 1,243.5 1,273.1 

Increase in Estimated Recoverable Coal 

as of 1/09 (Percent) --- 33.2 36.3 

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 (92 percent). 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-7 

will be disturbed in order to recover that coal. According to Black Thunder 

Mine’s 2008 Annual Report submitted to the Wyoming Department of 

Environmental Quality/Land Quality Division (WDEQ/LQD), the mine had 

disturbed a total of approximately 13,874.0 acres as of October 1, 2008. Of 

that total area of disturbance, approximately 4,769.9 acres (34.4 percent) were 

occupied by permanent or temporary facilities (stockpiles, hydrologic control 

structures, mine buildings and coal loading facilities, railroad loop, 

environmental monitoring areas, etc.), 2,628.2 acres (18.9 percent) were 

occupied by areas being actively mined, and 6,476.0 acres (46.7 percent) were 

occupied by areas that had been mined and reclaimed or were in the process of 

being reclaimed (TBCC 2008). 

If the North Hilight Field, South Hilight Field, and West Hilight Field LBA 

Tracts are leased to the applicant as maintenance tracts under the Proposed 

Action or Alternative 2 or 3, the permit area for the adjacent Black Thunder 

Mine would have to be amended to include the new lease areas before they 

could be disturbed by mining activities. Tables 3-1 through 3-3 also show how 

the leased area and disturbance area would change, for each of the tracts as 

applied for and under Alternatives 2 and 3, if all the federal coal in the BLM 

study area discussed in Chapter 2 is included in the tract that is offered for 

sale. The estimates of recoverable coal, associated disturbance, and mine life 

shown in Tables 3-1 through 3-3 and elsewhere in this chapter assume that 

coal currently unsuitable for mining due to the presence of public roads is not 

mined. If the Campbell County Board of Commissioners determine that the 

county roads that border or cross the tracts can be closed and/or moved, the 

estimated tons of recoverable coal, associated disturbance, and Black Thunder 

Mine life would increase as discussed in Sections 2.1, 2.2, and 2.3 and as 

indicated in Tables 2-2, 2-4, and 2-6 for the North Hilight Field, South Hilight 

Field, and West Hilight Field LBA Tracts, respectively. A portion of the South 

Hilight Field LBA Tract as applied for lies inside the current mine permit area 

(Figure 2-2), a portion of the West Hilight Field LBA Tract under Alternative 3 

lies inside the current mine permit area (Figure 2-3), and the North Hilight 

Field LBA Tract under both the Proposed Action and Alternative 2 borders, but 

lies entirely outside of, the current mine permit area (Figure 2-1). If a tract is 

leased, the area that would have to be added to the existing mine permit area 

would be that portion of the LBA tract that lies outside 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 tracts as applied for or as configured under Alternative 2 or 

Alternative 3 that are contiguous to existing coal leases (Figure 3-1) and within 

approved mine permit areas will be disturbed by the current mining operations. 

The environmental consequences of leasing the North Hilight Field, South 

Hilight Field and West Hilight Field LBA Tracts under any one of the Action 

Alternatives would be similar in nature, but selection of the Proposed Action 

would disturb less area of land surface.
3.0 Affected Environment and Environmental Consequences 

3-8 Final EIS, Wright Area Coal Lease Applications

As indicated in Table 3-4, Jacobs Ranch Mine’s current coal leases include 

approximately 8,604.7 acres. Under the mine’s currently approved mining and 

reclamation plan, a total of approximately 15,262 acres will be disturbed in 

order to recover that coal. According to Jacobs Ranch Mine’s 2008 Annual 

Report submitted to WDEQ/LQD, the mine had disturbed a total of 

approximately 9,681 acres as of December 31, 2008. Of that total area of 

disturbance, approximately 1,191 acres (12.3 percent) were occupied by 

permanent or temporary facilities (stockpiles, hydrologic control structures, 

mine buildings and coal loading facilities, railroad loop, environmental 

monitoring areas, etc.), 2,508 acres (25.9 percent) were occupied by areas 

being actively mined, and 5,982 acres (61.8 percent) were occupied by areas 

that had been mined and reclaimed or were in the process of being reclaimed 

(JRCC 2008). 

If the West Jacobs Ranch LBA Tract is leased to the applicant as a 

maintenance tract under the Proposed Action or Alternative 2, the permit area 

for the Jacobs Ranch Mine would have to be amended to include the new lease 

area before it could be disturbed by mining activities. Table 3-4 also shows 

how the leased area and disturbance area would change, for the tract as 

applied for and under Alternative 2, if all the federal coal in the BLM study area 

discussed in Chapter 2 is included in the tract that is offered for sale. The 

estimates of recoverable coal, associated disturbance, and mine life shown in 

Table 3-4 and elsewhere in this chapter assume that coal currently unsuitable 

for mining due to the presence of public roads is not mined. If the Campbell 

County Board of Commissioners determines that the portion of Hilight Road 

bordering the east side of the tract can be closed and/or moved, the estimated 

tons of recoverable coal, associated disturbance, and Jacobs Ranch Mine life 

would increase as discussed in Section 2.4 and as indicated in Table 2-8 for 

the West Jacobs Ranch LBA Tract. As shown in Figure 2-4, no portion of the 

West Jacobs Ranch LBA Tract under the Proposed Action or Alternative 2 lies 

inside Jacobs Ranch Mine’s current permit area; however, the eastern portion 

of the LBA Tract as applied for does lie within Black Thunder Mine’s current 

permit area, which is referred to as ALC’s or Black Thunder Mine’s Northwest 

Rail Loop Amendment Area. Consequently, no portion of the tract has been 

disturbed by the Jacobs Ranch Mine, but as discussed in Sections 2.1, 2.3, 

and 2.4, surface disturbances related to the construction of a new rail spur, 

rail loops, storage silos, and coal loadout facilities for the Black Thunder Mine 

are presently occurring within ALC’s Northwest Rail Loop Amendment Area 

(Figures 2-3 and 2-4). No portion of the West Jacobs Ranch LBA Tract will be 

disturbed under the current mining plans in order to recover coal in the 

existing adjacent coal leases due to the presence of the Burlington Northern 

Santa Fe & Union Pacific (BNSF & UP) railroad, which borders the eastern side 

of the tract and effectively separates mining operations on either side of the rail 

line. If the tract is leased to the applicant, the area that would have to be 

added to the existing mine permit area would be the entire LBA tract 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. The environmental 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-9 

consequences of leasing the West Jacobs Ranch LBA Tract under the Proposed 

Action or Alternative 2 would be similar in nature, but selection of the 

Proposed Action would disturb a smaller area of land surface. 

On October 1, 2009, the Jacobs Ranch Mine was acquired by Arch Coal, Inc. 

ALC intends to consolidate the permits for the Jacobs Ranch Mine and the 

Black Thunder Mine in order to integrate the two separate mining operations. 

In this EIS, the applicant for the West Jacobs Ranch LBA Tract will be referred 

to as ALC, and the operator of the Jacobs Ranch Mine will be referred to as 

Thunder Basin Coal Company (TBCC). It is assumed that ALC would be the 

successful bidder, and that the West Jacobs Ranch tract would be mined as a 

maintenance lease for the existing Jacobs Ranch Mine. 

As indicated in Tables 3-5 through 3-6, North Antelope Rochelle Mine’s current 

coal leases include approximately 18,066 acres. Under the mine’s currently 

approved mining and reclamation plan, a total of approximately 27,443 acres 

will be disturbed in order to recover that coal. According to North Antelope 

Rochelle Mine’s 2008 Annual Report submitted to the WDEQ/LQD, the mine 

had disturbed a total of approximately 15,311 acres as of September 30, 2008. 

Of that total area of disturbance, approximately 3,415 acres (22 percent) were 

occupied by permanent or temporary facilities (stockpiles, hydrologic control 

structures, mine buildings and coal loading facilities, railroad loop, 

environmental monitoring areas, etc.), 6,488 acres (43 percent) were occupied 

by areas being actively mined, and 5,409 acres (35 percent) were occupied by 

areas that had been mined and reclaimed or were in the process of being 

reclaimed (PRC 2008b). 

If the North Porcupine and South Porcupine LBA Tracts are leased to the 

applicant as maintenance tracts under the Proposed Action or Alternative 2, 

the permit area for the adjacent North Antelope Rochelle Mine would have to be 

amended before the entire new lease areas could be disturbed by mining 

activities. Tables 3-5 and 3-6 also show how the leased area and disturbance 

area would change, for each of the tracts as applied for and under Alternative 

2, if all the federal coal in the BLM study area discussed in Chapter 2 is 

included in the tract that is offered for sale. The estimates of recoverable coal, 

associated disturbance, and mine lives shown in Tables 3-5 and 3-6 and 

elsewhere in this chapter assume that coal currently unsuitable for mining due 

to the presence of public roads is not mined. If the Campbell County Board of 

Commissioners determine that the county roads that border or cross the tracts 

can be closed and/or moved, the estimated tons of recoverable coal, associated 

disturbance, and North Antelope Rochelle Mine life would increase as 

discussed in Sections 2.5 and 2.6 and as indicated in Tables 2-10 and 2-12 for 

the North Porcupine and South Porcupine LBA Tracts, respectively. The North 

Porcupine LBA Tract as applied for and under Alternative 2 lies entirely within 

the current mine permit boundary (Figure 2-5). The South Porcupine LBA 

Tract as applied for lies entirely within the current mine permit area, as does 

all but approximately 60 acres of the tract configured under Alternative 2 

(Figure 2-6). If a tract is leased however, additional area would have to be 
3.0 Affected Environment and Environmental Consequences 

3-10 Final EIS, Wright Area Coal Lease Applications

added to the existing mine permit area 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 tracts as applied for or as configured under Alternative 2 

that are contiguous to existing coal leases (Figure 3-1) will be disturbed by the 

current mining operations. The environmental consequences of leasing the 

North Porcupine and South Porcupine LBA Tracts under the Proposed Action 

or Alternative 2 would be similar in nature, but selection of the Proposed 

Action would disturb less area of land surface.

Surface mining and reclamation have been ongoing in the eastern Powder River 

Basin (PRB) for nearly 3 decades. During this time, effective mining and 

reclamation technologies have been developed and continue to be refined. 

Mining and reclamation operations are regulated under the Surface Mining 

Control and Reclamation Act of 1977 (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 Department of the Interior (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, 

long-term (persisting beyond the end of mine life and reclamation), or shortterm (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. 

3.1 General Setting

The general Wright 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 Wright 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 Western Regional Climate Center/National Oceanic and 

Atmospheric Administration (WRCC/NOAA) meteorological station (Wright 12 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-11 

W), located between 3 and 18 miles west to northwest of the general Wright 

analysis area, is 13.45 inches (WRCC 2008). May (2.06 inches) and June (2.03 

inches) are the wettest months, whereas December (0.33 inch) and January 

(0.36 inch) are the driest. Snowfall averages 54.8 inches per year, with most 

occurring in March and April (9.3 inches each). Potential evapotranspiration 

has been estimated at 31 inches (NOAA 1969), which exceeds annual 

precipitation. Summers are relatively short and warm, while winters are longer 

and cold. The annual mean temperature for the WRCC/NOAA meteorological 

station at Wright for the period of record (1991 through 2007) is 44.7 degrees 

Fahrenheit (F). The highest recorded temperature was 103 degrees F and the 

lowest was minus 39 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 and Grimes 2004). 

In the general Wright analysis area, surface wind speeds range from more than 

30 miles per hour (mph) during the winter and spring to 10 to 12 mph during 

the summer. The area also experiences extreme wind gusts, especially during 

thunderstorm activity that occurs in June, July, and August. Distinct diurnal 

changes occur, with average wind velocities increasing during the day and 

decreasing during the night. Local variations in wind speed and direction are 

primarily due to differences in topography. Wind speeds are highest in the 

winter and spring (October through April) and are predominantly from the 

western and northern sectors. During the warmer months (May through 

September), wind directions are more random, although winds from the 

northern or southeastern sectors are slightly more predominant. 

During periods of strong wind, dust may impact air quality across the region. 

An average of 15 air-stagnation events occurs annually in the PRB with an 

average duration of 2 days each (BLM 1974). 

3.2 Topography and Physiography

3.2.1 Affected Environment

The general Wright analysis area is a high plains area within the unglaciated 

Missouri Plateau subregion of the Great Plains Province, near the eastern 

portion of the Powder River Basin (PRB) in the state of Wyoming. The PRB is 

both a topographic drainage and geologic structural basin. The structural 

basin is an elongated, asymmetrical syncline approximately 120 miles east to 

west and 200 miles north to south. It is bounded in Wyoming by the Black 

Hills on the east; the Big Horn Mountains on the west; and the Hartville Uplift, 

Casper Arch, and Laramie Mountains on the south. The northern extent of the 

structural basin is the Miles City Arch and the Yellowstone River in Montana. 

The axis of the structural basin trends from the southeast to the northwest 

near the western margin of the syncline. The general Wright analysis area is 

located on the gently dipping eastern limb of the structural basin. In general, 
3.0 Affected Environment and Environmental Consequences 

3-12 Final EIS, Wright Area Coal Lease Applications

geologic strata along the eastern limb of the structural PRB dip to the west at 1 

to 2 degrees toward the axis of the basin. 

The Powder River Basin is so named because it is drained by the Powder River, 

although it is also drained in part by other major rivers, including the Big 

Horn, Tongue, Little Missouri, Belle Fourche, and Cheyenne rivers. The 

general Wright analysis area is within the Cheyenne River drainage basin. 

Little Thunder Creek, North Prong Little Thunder Creek, Porcupine Creek and 

Antelope Creek, tributaries of the Cheyenne River, are the most prominent 

natural topographic features in the general Wright analysis area. 

Broad plains, rolling hills, and tablelands dominate the PRB landscape. 

Internally-drained playas are common in the basin, as are buttes and plateaus 

capped by sandstone or clinker. Elevations throughout the PRB range from 

less than 2,500 feet to more than 6,000 feet above sea level. The major river 

valleys have wide, flat floors and broad floodplains. The drainages dissecting 

the basin are incised, typically are ephemeral or intermittent, and do not 

provide year-round water sources. 

The topography of the general Wright analysis area, like the areas within the 

adjacent mines’ existing permit areas, is relatively subdued. The landscape of 

the general Wright analysis area consists primarily of gently rolling terrain 

broken by minor drainages and internally-drained playa areas. Drainage 

densities are quite low, and the playas are common topographic and hydrologic 

features. Much of the land surface covered by the LBA tracts as applied for 

and the lands added by the BLM study areas do not contribute runoff to any 

stream, and playas have formed in the lowest portion of these non-contributing 

drainage areas. 

Land surface elevations range from about 4,690 to 5,170 feet above sea level 

and slopes range from essentially flat to over 50 percent within the general 

Wright analysis area. Gently rolling uplands comprise most of the general 

Wright analysis area; most of the land surface (between 75 and 90 percent, 

depending on the particular LBA tract) seldom exceeds a 5 percent slope. The 

steepest slopes typically occur near the highest elevations along the ridge lines 

and drainage divides and at the breaks or transitions between uplands and 

bottomlands that are dissected by small ravines and gullies. Of the six LBA 

tracts included in the general Wright analysis area, the topography of the 

South Porcupine tract is somewhat unique due to the presence of a number of 

steep draws and gullies that are formed by the headwaters of Antelope, Horse, 

and Porcupine creeks. However, gently rolling uplands comprise approximately 

51 percent of the general analysis area for the South Porcupine tract, and the 

steepest slopes within the erosionally dissected areas are slightly over 30 

percent. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-13 

3.2.2 Environmental Consequences

3.2.2.1 Proposed Action and Alternatives 2 and 3

Surface mined lands, both active and reclaimed, dominate the landscape east 

of Wyoming State Highway 59 in the vicinity of the general Wright analysis 

area. Surface coal mining would permanently alter the topography of each LBA 

tract if it is leased and mined. Topsoil would be removed and stockpiled or 

placed directly on recontoured areas. Overburden would be blasted and 

stockpiled or directly placed into already mined pits, and coal would be 

removed. Highwalls with vertical heights equal to overburden (and 

interburden, if present) plus coal thickness would exist in the active pits. If 

necessary, streams would be diverted into temporary channels around active 

mining areas or would be contained within temporary reservoirs to prevent pits 

from being flooded. 

Typically, a direct permanent impact of coal mining and reclamation is 

topographic moderation. After reclamation, the postmining topography would 

be similar to the premining topography, but would be somewhat gentler and 

more uniform. The original topography in North Hilight Field, South Hilight 

Field, West Hilight Field, West Jacobs Ranch, North Porcupine and South 

Porcupine LBA Tracts ranges from essentially flat playa areas to gently rolling 

hills to relatively rugged draws and gullies. 

As discussed above, slopes on the LBA tracts as applied for range from around 

zero to over 50 percent, and the average slopes range from about 2.2 percent 

(for the West Hilight Field LBA Tract) to 6.2 percent (for the South Porcupine 

LBA Tract). Following reclamation, the average surface elevation on each LBA 

tract would be lower due to coal removal (see Table 3-7). The removal of the 

coal would be partially offset by the swelling that occurs when the overburden 

(and interburden, if present) is blasted, excavated, and backfilled. 

Table 3-7 presents the approximate postmining surface elevation change for 

each LBA tract as applied for under the Proposed Action and Alternative 2. 

West Hilight’s Alternative 3 is also included in the table. These figures 

represent the estimated average change in surface elevation over the entire 

area of coal removal. After the coal is removed, highwalls would be eliminated 

and the land surface would be restored to its 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, if the tract is 

leased. 

Direct adverse impacts resulting from topographic moderation include a 

reduction in microhabitats (e.g., cutbank slopes and steep bedrock bluffs and 

escarpments) for some wildlife species and a reduction in habitat diversity, 

particularly in slope-dependent shrub communities and associated habitat. 

These impacts, which would be greater in those areas characterized as rough 
3.0 Affected Environment and Environmental Consequences 

 3-14 Final EIS, Wright Area Co

Table 3-7. Average Overburden, Interburden, and Coal Thicknesses and Approximate 

Elevation Changes of the Six WAC LBA Tracts. 

LBA Tract and Configuration 

Overburden 

Thickness 

(ft) 

Interburden 

Thickness 

(ft) 

Total Coal 

Thickness 

(ft) 

Swell 

Factor 

(percent) 

Coal 

F

(p

North Hilight Field 

Proposed Action 246 1 61 16 

Alternative 2 246 1 61 16 

South Hilight Field 

Proposed Action 292 94 81 16 

Alternative 2 292 94 81 16 

West Hilight Field 

Proposed Action 428 32 93 16 

Alternative 2 428 32 93 16 Alternative 3 428 32 93 16 

Existing Black Thunder Mine Leases 

No Action Alternative for North, South and West Hilight Field LBA Tracts 282 

Included with 

overburden 78 16 

West Jacobs Ranch 

Proposed Action 475 0 102 18 

Alternative 2 486 0 104 18 

Existing Jacobs Ranch Mine Leases 

No Action Alternative for West Jacobs Ranch LBA Tract 168 9 57 18 

North Porcupine 

Proposed Action 343 0 75 15.5 

Alternative 2 354 0 75 15.5 

South Porcupine 

Proposed Action 346 11 76 15.5 Alternative 2 347 10 76 15.5 

Existing North Antelope Rochelle Mine Leases 

No Action Alternative for North and South Porcupine LBA Tracts 211 17 71 15.5 

1 Reclaimed (postmining) surface elevation change calculated as: ((overburden thickness + interburden thickness) × swell 

coal recovery factor). 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-15 

breaks, may result in a long-term reduction in the carrying capacity for some 

species. 

The applicant mines’ existing reclamation plans include measures, to the 

extent possible, to establish wildlife enhancement features. 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 

and potentially accelerate recharge of groundwater. This may help counteract 

the potential for increased erosion that could occur as a result of higher nearsurface bulk density of the reclaimed soils (Section 3.8). It may also increase 

vegetative productivity, which would result in a benefit to livestock grazing. 

The approximate original drainage pattern of all streams within each LBA tract 

would be restored (Section 3.5). In-channel stockponds and playas (shallow 

topographic depressions) 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 Black Thunder, Jacobs Ranch, and 

North Antelope Rochelle mines’ coal leases as coal is mined and mined-out 

areas are reclaimed. Under the Proposed Action or Alternative 2 or 3, the areas 

that would be permanently topographically changed would increase as shown 

in Tables 3-1 through 3-6. 

3.2.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and coal removal and the associated 

disturbance and impacts to topography and physiography would not occur on 

the portions of the LBA tracts as applied for or the LBA tracts configured under 

Alternative 2 that will not be disturbed under currently approved surface coal 

mining permits. Coal removal and the associated impacts to topography and 

physiography would continue as currently permitted on the existing Black 

Thunder, Jacobs Ranch, and North Antelope Rochelle Mine coal leases. Table 

3-7 presents the approximate postmining surface elevation change for the 

existing Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines. 

Impacts to topography and physiography related to mining operations at these 

three applicant mines would not be extended onto portions of the LBA tracts 

that will not be affected under the current mining and reclamation plans. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective tract in the future. 
3.0 Affected Environment and Environmental Consequences 

3-16 Final EIS, Wright Area Coal Lease Applications

3.2.3 Regulatory Compliance, Mitigation and Monitoring

The mined-out areas must be restored to approximate original contour or other 

topographic configuration approved by WDEQ/LQD. Topographic 

configurations would be developed and approved as part of the required mining 

and reclamation plans within the surface mining permits for the Black 

Thunder, Jacobs Ranch, and North Antelope Rochelle mines. WDEQ/LQD 

monitors topographic restoration by regularly checking the as-built topography 

in the annual reports filed by the mines to see if it conforms to the approved 

topography. 

3.2.4 Residual Impacts

Topographic moderation is a permanent consequence of mining. Reclaimed 

landforms are expected to mimic premining topography, but be more subdued 

in topographic variation and slightly lower in elevation (Table 3-7). 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

Geologic units in the general Wright analysis area that would be impacted if 

the LBA tracts under consideration for leasing are 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 seams). Variations between 

the LBA tracts occur primarily in the thickness of the mineable coal seams, the 

thickness of overburden, the parting thickness(es) between the various seams 

comprising the Wyodak coal, and the surface topography. Figure 3-2 shows 

the stratigraphic relationships of the geologic units in the general Wright 

analysis area that are typical for the eastern part of the PRB in Wyoming. 

Additional information about these units is included in Section 3.5 of this EIS. 

The majority of the recent Quaternary Holocene age surface deposits in the 

general Wright analysis area are reworked Wasatch Formation residuum or 

deposits that are of mixed alluvial and eolian nature. The lithologies of these 

unconsolidated deposits represent materials eroded locally from the Wasatch 

Formation and reflect relatively near-source deposition. The alluvial deposits 

are comprised of fine sands and silts interbedded with clays and fine gravels. 

Thin (ranging from nearly absent to less than 20 feet thick) alluvial and eolian 

deposits occur along the larger ephemeral stream channels such as Little 

Thunder Creek. The valley floor of Porcupine Creek contains appreciable 

amounts of alluvium, both in width and depth, and the alluvial deposits of 

Porcupine Creek are comprised of coarser-grained material than the other 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-17 

Geologic Unit Hydrologic Characteristics 

RECENT ALLUVIUM 

HOLOCENE 

Typically fine grained and poorly sorted sands interbedded with silts and 

clays in ephemeral drainages. Occasional very thin, clean interbedded 

sand lenses. More laterally extensive, thicker, and coarse-grained along 

the larger stream courses. Excessive dissolved solids generally make this 

aquifer unsuitable for domestic and agricultural use and marginal for 

livestock (Class III) use standards. Low infiltration capacity in ephemeral 

draws unless covered by sandy eolian blanket. Low to moderate infiltration 

along Little Rawhide Creek. 

CLINKER 

HOLOCENE TO 

PLEISTOCENE 

Baked and fused bedrock resulting from burning coal seams which ignite 

on the outcrop from lightning, manmade fires or spontaneous combustion. 

The reddish clinker (locally called scoria, red dog, etc.) formed by melting 

and partial fusing of overburden above the burning coal. The baked rock 

varies greatly in the degree of alteration; some is dense and glassy while 

some is vesicular and porous. It is commonly used as a road construction 

material and is an aquifer wherever saturated. Considered to be part of the 

Wasatch Formation. 

WASATCH FORMATION 

EOCENE 

Lenticular fine sands interbedded in predominantly very fine grained 

siltstone and claystone may yield low to moderate quantities of poor to good 

quality water. The discontinuous nature and irregular geometry of these 

sand bodies result in low overall permeabilities and very slow groundwater 

movement in the overburden on a regional scale. Water quality in the 

Wasatch Formation generally does not meet Wyoming Class I (domestic 

use) standards due to the dissolved mineral content. Some wells do, 

however, produce water of considerably better quality that does meet the 

Class I standard.

TONGUE 

RIVER 

MEMBER 

The coal beds serve as regional groundwater aquifers and exhibit highly 

variable aquifer properties. Permeability and porosity associated with the 

coal arise almost entirely from fractures. Coal water typically does not meet 

Wyoming Class I or Class II (irrigation use) standards. In most cases, water 

from coal wells is suitable for livestock use. The coal water is used 

throughout the region as a source of stock water and occasionally for 

domestic use. USGS (Flores et al. 1999) refers to the thick mineable coals 

in the Gillette coal field as the Wyodak-Anderson coal zone of the Tongue 

River Member of the Fort Union Formation.

LEBO MEMBER 

The Lebo member, also referred to as the “Lebo Confining Layer” or “Lebo 

Shale.” Has a mean thickness of 711 ft in the PRB, although ranges 

between 400 to 1,000 ft in the Gillette area and 400 to 800 ft in the general 

Wright analysis area. The Lebo typically yields small quantities of poor 

quality groundwater. Where sand content is locally large, caused by 

channel or deltaic deposits, the Lebo may yield as much as 10 gpm. 

FORT UNION FORMATION 

PALEOCENE 

TULLOCK 

MEMBER 

The Tullock member has a mean thickness of 785 ft in the PRB and a mean 

sand content of 53 percent which indicates that the unit generally 

functions well as a regional aquifer. Yields of 15 gpm are common but vary 

locally and may be as much as 40 gpm. Records from the SEO indicate 

that maximum yields of approximately 300 gpm have been achieved from 

this aquifer. Water quality in the Tullock Member often meets Class I 

standards. The extensive sandstone units in the Tullock Member are 

commonly developed regionally for domestic and industrial uses. The city 

of Gillette is currently using eight wells completed in this zone to meet part 

of its municipal water requirements, and the town of Wright is currently 

utilizing four wells completed in the Tullock for its municipal water supply. 

LANCE FORMATION/HELL 

CREEK FORMATION 

Silty, calcareous sandstones and interbedded sandy shales, claystones, and 

coals. Provides yields generally less than 20 gpm. Higher yields can occur 

where sand thicknesses are greatest. Water quality is typically fair to good. 

Also referred to as the “Upper Lance Confining Layer.” 

FOX HILLS 

SANDSTONE 

Marine sandstones and sandy shales. Has a mean thickness of 818 ft and 

a mean sand content over 50 percent in the PRB. Yields up to 200 gpm are 

common; however, yields can be significantly less. Water quality is good, 

with TDS concentrations commonly less than 1,000 mg/L. The city of 

Gillette is currently using five wells completed in this aquifer to meet part 

of its municipal water requirements. 

UPPER CRETACEOUS 

PIERRE SHALE 

This unit is comprised predominantly of dark marine shales with only 

occasional local thin sandstone lenses. Maximum yields are minor and 

overall the unit is not water bearing. Water obtained from this unit is poor 

with high concentrations of sodium and sulfate as the predominant ions in 

solution. 

Sources: Stratigraphy from Stratigraphic Nomenclature Committee, Wyoming Geological Association, 1969. Hydrogeology from Lewis 

and Hotchkiss, 1981. 

Figure 3-2. Stratigraphic Relationship and Hydrologic Characteristics of Upper 

Cretaceous, Lower Tertiary, and Recent Geologic Units of the 

Powder River Basin, Wyoming. 
3.0 Affected Environment and Environmental Consequences 

3-18 Final EIS, Wright Area Coal Lease Applications

ephemeral streams that drain the general Wright analysis area. Eolian 

deposits occur throughout the general Wright analysis area, although are more 

common in the southern portion where these fine-grained sand, silt and clay 

deposits can blanket the terrain up to 15 feet thick (Reheis and Coates 1987). 

Eolian processes have reworked some of the surficial deposits, resulting in 

isolated deflation basins having no natural drainage. These internally-drained 

surface features (playas) commonly contain fine-grained sediments recently 

deposited from seasonal rainfall or snowmelt runoff events. 

The Eocene Wasatch Formation forms most of the overburden in the general 

Wright analysis area. The Wasatch overburden consists of interbedded 

lenticular sands/sandstones, silts/siltstones, clays and shales with thin 

discontinuous coal seams. Wasatch rocks are exposed in some localities, 

particularly along steep bluffs and hills formed by the more erosionally 

resistant sandstone strata and in the eroded gullies and ravines that separate 

upland and bottomland areas. Wasatch coals, where present, are typically of 

no economic significance. Clinker (also referred to as burn or scoria) is 

sedimentary rocks that were baked, fused or melted in place when an 

underlying coal seam burned in-situ. Clinker is often exposed on the surface 

as predominantly red-colored, resistant rock outcrops. The occurrence of 

clinker is site-specific, typically occurring in areas where coal seams crop out 

at the surface. 

Underlying the Wasatch Formation is the Paleocene Fort Union Formation. 

The boundary between the Wasatch Formation and the Fort Union Formation 

is not distinct. From a practical standpoint, however, the top of the mineable 

coal zone is considered as the contact between the two formations. Table 3-7 

indicates the overburden thicknesses in the North Hilight Field, South Hilight 

Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South 

Porcupine LBA Tracts as applied for and under Alternative 2. As discussed in 

Section 3.2.1, the regional dip in this area is to the west; as a result, the 

overburden thickness generally increases from east to west. The overburden is 

also generally thinner in the vicinity of the major drainage channels and 

increases in thickness away from the channel bottoms. There are no known 

local, major geologic structures in the general Wright analysis area. 

The Fort Union Formation consists primarily of siltstones, mudstones, 

claystones, shales, lenticular sands/sandstones, and coal seams. As shown in 

Figure 3-2, the Fort Union Formation is divided into three members: the 

Tongue River (which contains the mineable coal seams), the Lebo, and the 

Tullock, in descending order. The Tongue River Member consists of 

interbedded siltstone, claystone, silty shale, carbonaceous shale, and coal, with 

lesser amounts of fine-grained sands and sandstones. 

The U.S. Geological Survey (Flores et al. 1999) refers to the thick mineable 

coals in the Gillette coal field as the Wyodak-Anderson coal zone of the Tongue 

River Member of the Fort Union Formation. The nomenclature of the mineable 

coal seams in the Tongue River Member varies from mine operator to mine 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-19 

operator in the eastern PRB and are locally referred to as the Anderson and 

Canyon, Roland and Smith, Wyodak-Anderson, and Wyodak. Operators of the 

mines in the general Wright analysis area refer to the mineable coal zone as 

either the Wyodak (Upper Wyodak, Middle Wyodak and Lower Wyodak) or the 

Wyodak-Anderson. The number of coal seams varies from tract to tract. 

There are two coal seams (referred to as Upper and Middle Wyodak) in the 

North Hilight Field LBA Tract as applied for and three coal seams (referred to 

as Upper, Middle, and Lower Wyodak) in the North Hilight Field LBA Tract 

configured under Alternative 2; however, due to quality issues, the Upper 

Wyodak may not be recovered. There are two coal seams (referred to as Upper 

and Middle Wyodak) in the South Hilight Field LBA Tract as applied for and 

three coal seams (referred to as Upper, Middle, and Lower Wyodak) in the 

South Hilight Field LBA Tract configured under Alternative 2; however, due to 

quality issues, the Upper Wyodak may not be recovered. There are two coal 

seams (referred to as Upper and Middle Wyodak) in the West Hilight Field LBA 

Tract as applied for and as configured under Alternative 2; however, due to 

quality issues, the Upper Wyodak may not be recovered. There is one mineable 

seam (referred to as the Wyodak) in the West Jacobs Ranch LBA Tract as 

applied for and as configured under Alternative 2. There are two mineable coal 

seams (referred to as the Wyodak-Anderson 1 and Wyodak-Anderson 2) in both 

the Porcupine North and Porcupine South LBA Tracts as applied for and under 

Alternative 2. The combined average thicknesses of the mineable coal seams 

within each LBA tract as applied for and the additional area evaluated under 

Alternative 2 (and Alternative 3 for the West Hilight Field tract) are shown in 

Table 3-7. The combined average thicknesses of interburden between coal 

seams are also given in Table 3-7. 

The Fort Union coal seams are subbituminous and are generally low-sulfur, 

low-ash coals. Typically, the coal being mined south of Gillette has a higher 

heating value and lower sulfur content than the coal being mined north of 

Gillette. In these six tracts that are under consideration for leasing, the 

heating value of the coal seams is expected to range from around 8,500 to 

9,200 Btu/lb; the ash content is expected to vary from about 3.5 to 6.5 

percent; the sulfur content is expected to vary from about 0.1 to 0.7 percent; 

the fixed carbon is expected to vary from 30 to 55 percent, and the moisture 

content is expected to vary from around 22 to 30 percent. 

3.3.1.2 Environmental Consequences

3.3.1.2.1 Proposed Action and Alternatives 2 and 3

The stratigraphic units from the base of the lowest coal seam mined to the land 

surface would be subject to permanent change after the coal is removed on the 

LBA tracts under the respective Proposed Action or Alternative 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, claystone, 
3.0 Affected Environment and Environmental Consequences 

3-20 Final EIS, Wright Area Coal Lease Applications

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 stratigraphy. 

3.3.1.2.1.1 North Hilight Field LBA Tract

Mining would remove an average of 246 feet of overburden, 1 foot of 

interburden, and 61 feet of coal from about 2,349 acres up to about 6,738 

acres for the BLM’s preferred tract configuration under Alternative 2. These 

figures represent the estimated area of actual coal removal, assuming that 

Shroyer Road is not moved. Table 3-7 presents the average overburden, 

interburden, and coal thicknesses for the North Hilight Field LBA Tract as 

applied for and for the BLM’s preferred tract configuration under Alternative 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 291 feet in thickness under both the 

Proposed Action and Alternative 2. Approximately 263.4 million tons of coal 

would be recovered from the tract as applied for, and an estimated 652.8 

million tons would be recovered from BLM’s preferred tract configuration under 

Alternative 2. 

3.3.1.2.1.2 South Hilight Field LBA Tract

Mining would remove an average of 292 feet of overburden, 94 foot of 

interburden, and 81 feet of coal from about 1,675 acres for the tract as applied 

for up to about 2,373 acres for the BLM’s preferred tract configuration under 

Alternative 2. These figures represent the estimated area of actual coal 

removal, assuming that Reno Road is not moved. Table 3-7 presents the 

average overburden, interburden, and coal thicknesses for the South Hilight 

Field LBA Tract as applied for and for the BLM’s preferred tract configuration 

under Alternative 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 454 feet in thickness under both the 

Proposed Action and Alternative 2. Approximately 213.6 million tons of coal 

would be recovered from the tract as applied for, and an estimated 304.3 

million tons would be recovered from BLM’s preferred tract configuration under 

Alternative 2. 

3.3.1.2.1.3 West Hilight Field LBA Tract

Mining would remove an average of 428 feet of overburden, 32 foot of 

interburden, and 93 feet of coal from about 2,211 acres for the tract as applied 

for up to about 6,577 acres for the tract as it would be configured under 

Alternatives 2 and 3; Alternative 2 being BLM’s preferred tract configuration. 

These figures represent the estimated area of actual coal removal, assuming 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-21 

that Wyoming State Highway 450 and Hilight Road are not moved. Table 3-7 

presents the average overburden, interburden, and coal thicknesses for the 

West Hilight Field LBA Tract as applied for and for the tract configured under 

Alternatives 2 and 3. 

The replaced overburden and interburden would be a relatively homogeneous 

(compared to the premining layered overburden and interburden) and partly 

recompacted mixture averaging about 541 feet in thickness under both the 

Proposed Action and Alternatives 2 and 3. Approximately 377.9 million tons of 

coal would be recovered from the tract as applied for, compared to an 

estimated 965.2 million additional tons that would be recovered from the tract 

configured under Alternatives 2 and 3. 

3.3.1.2.1.4 West Jacobs Ranch LBA Tract

Mining would remove an average of 475 feet of overburden, no interburden, 

and 102 feet of coal from about 4,798 acres for the tract as applied for. Under 

Alternative 2, which is BLM’s preferred alternative, mining would remove an 

average of 486 feet of overburden, 0.5 foot of interburden (where it exists), and 

104 feet of coal from about 6,691 acres. These figures represent the estimated 

area of actual coal removal, assuming that Wyoming State Highway 450 and 

Hilight Road are not moved. Table 3-7 presents the average overburden, 

interburden, and mineable coal thicknesses for the West Jacobs Ranch LBA 

Tract as applied for and for the BLM’s preferred tract configuration under 

Alternative 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 571 feet in thickness under the Proposed 

Action and about 584 feet in thickness under Alternative 2, BLM’s preferred 

alternative. Approximately 669.6 million tons of coal would be recovered from 

the tract as applied for, and an estimated 912.6 million tons would be 

recovered from BLM’s preferred tract configuration under Alternative 2. 

3.3.1.2.1.5 North Porcupine LBA Tract

Mining would remove an average of 343 feet of overburden, no interburden, 

and 75 feet of coal from about 5,024 acres for the tract as applied for. Under 

Alternative 2, which is BLM’s preferred alternative, mining would remove an 

average of 353.7 feet of overburden, no interburden, and 74.7 feet of coal from 

about 6,258 acres. These figures represent the estimated area of actual coal 

removal, assuming that Mackey Road is not moved. Table 3-7 presents the 

average overburden, interburden, and mineable coal thicknesses for the North 

Porcupine LBA Tract as applied for and for the BLM’s preferred tract 

configuration under Alternative 2. 

The replaced overburden and interburden would be a relatively homogeneous 

(compared to the premining layered overburden and interburden) and partly 
3.0 Affected Environment and Environmental Consequences 

3-22 Final EIS, Wright Area Coal Lease Applications

recompacted mixture averaging about 402 feet in thickness under the Proposed 

Action and about 415 feet in thickness under Alternative 2, BLM’s preferred 

alternative. Approximately 601.2 million tons of coal would be recovered from 

the tract as applied for, and an estimated 745.4 million tons would be 

recovered from BLM’s preferred tract configuration under Alternative 2. 

3.3.1.2.1.6 South Porcupine LBA Tract

Mining would remove an average of 345.7 feet of overburden, 10.9 feet of 

interburden, and 76.1 feet of coal from about 2,531 acres for the tract as 

applied for. Under Alternative 2, which is BLM’s preferred alternative, mining 

would remove an average of 348.6 feet of overburden, 10.2 feet of interburden, 

and 76.4 feet of coal from about 2,783 acres. These figures represent the 

estimated area of actual coal removal, assuming that a portion of Antelope 

Road approximately 2.25 miles in length is not moved. Table 3-7 presents the 

average overburden, interburden, and mineable coal thicknesses for the South 

Porcupine LBA Tract as applied for and for the BLM’s preferred tract 

configuration under Alternative 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 418 feet in thickness under the Proposed 

Action and about 421 feet in thickness under Alternative 2, BLM’s preferred 

alternative. Approximately 309.7 million tons of coal would be recovered from 

the tract as applied for, and an estimated 339.3 million tons would be 

recovered from BLM’s preferred tract configuration under Alternative 2. 

3.3.1.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected. Coal removal and the associated 

disturbance to the stratigraphic units from the base of the lowest coal seam 

that would be mined to the land surface would not occur on the LBA tracts as 

applied for or configured under Alternative 2. Coal removal and associated 

impacts described above would continue as currently permitted on the existing 

Black Thunder, Jacobs Ranch, and North Antelope Rochelle Mine coal leases. 

Table 3-7 presents the average overburden, interburden, and coal thicknesses 

for the existing Black Thunder, Jacobs Ranch, and North Antelope Rochelle 

Mine permit areas. Impacts to the stratigraphic units from the base of the 

lowest coal seam mined to the land surface related to mining operations at 

these three applicant mines would not be extended onto portions of the LBA 

tracts that will not be affected under the current mining and reclamation 

plans. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective tract in the future. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-23 

3.3.1.3 Regulatory Compliance, Mitigation and Monitoring

State and federal regulations require that drilling and sampling programs be 

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 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 Black Thunder, Jacobs Ranch, and 

North Antelope Rochelle mines and would be developed for the North Hilight 

Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, North 

Porcupine, and South Porcupine LBA Tracts if they are leased. 

The waste coal from both the mined and unmined seams remains in the pit to 

be mixed with and covered by backfilled overburden and interburden materials. 

The portions of Wyodak coal seams that may not be recovered (e.g., the Upper 

Wyodak seam may not be mined in the three Hilight Field tracts) due to quality 

issues are similar with respect to low sulfur content; therefore, the potential for 

acid formation is minimal. Any acid that is formed by the coal would be 

diluted or neutralized by contact with groundwater that becomes alkaline as 

the minerals from the backfilled overburden materials are dissolved. Any 

unsuitable materials in the backfill would be buried under adequate fill so as 

to be below the replaced soil to meet regulatory guidelines for vegetation root 

zones. Regraded overburden would be sampled to verify suitability as subsoil. 

3.3.1.4 Residual Impacts

Geology from the base of the coal to the land surface would permanently 

change from layered stratigraphy to a mixture of unconsolidated backfill 

material. 

3.3.2 Other Mineral Resources

3.3.2.1 Affected Environment

The PRB contains large reserves of fossil fuels including oil, natural gas, and 

coal, all of which are currently being produced. In addition, uranium, 

bentonite, and clinker (scoria) are mined in the PRB (WSGS 2003). 

3.3.2.1.1 Conventional Oil and Gas

Conventional hydrocarbon resource accumulations are described in terms of 

discrete fields or pools localized in structural or stratigraphic traps by the 

buoyancy of oil or gas in water. In contrast, unconventional (or “continuous”) 
3.0 Affected Environment and Environmental Consequences 

3-24 Final EIS, Wright Area Coal Lease Applications

accumulations (oil or gas) have large special dimensions regional in extent, 

have diffuse, indistinctly defined boundaries, do not have obvious seals and 

traps, and exist more or less independently of the water column (Schmoker 

1995). Unconventional oil and gas resources are discussed in the following 

subsection (3.3.2.1.2). 

The following is based on information from BLM’s Task 2 Report of the PRB 

Coal Review (BLM 2005a and 2009b), the Wyoming State Geological Survey’s 

oil and gas map of the PRB (WSGS 2007), a May 2008 review of Wyoming Oil 

and Gas Conservation Commission (WOGCC) database, and a January 2008 

reserve estimate prepared by Allen & Crouch Petroleum Engineers, Inc. (A&C) 

of Casper, Wyoming, of conventional oil and gas resources in the general 

Wright analysis area. 

The U.S. Geological Survey (USGS) estimated means of undiscovered 

conventional oil and natural gas resources in the PRB of Wyoming and 

Montana, as of December 2006, are 215 million barrels of oil, 1.16 trillion 

cubic feet of natural gas, and 105 million barrels of natural gas liquids (USGS 

2006). Depths to conventional gas and oil-bearing strata generally range from 

4,000 to 13,500 feet. 

The Powder River structural basin is one of the richest petroleum provinces in 

the Rocky Mountain area. Conventional oil and gas resources in the eastern 

PRB occur in reservoirs ranging from Pennsylvanian to Late (Upper) Cretaceous 

age rocks, in both structural and stratigraphic traps. Oil was first produced 

from the PRB in 1887 from the Lower Cretaceous Newcastle Sandstone on the 

east flank of the basin near Moorcroft, Wyoming. In the 1960s and 1970s, 

drilling moved into deeper parts of the basin that resulted in the discovery of 

prolific oil fields in stratigraphic traps in Upper and Lower Cretaceous age 

rocks. The discovery of oil from the Lower Cretaceous Muddy Sandstone on 

the Montana side of the basin set off a flurry of exploration that resulted in a 

number of discoveries in Wyoming in the Muddy Sandstone. Muddy Sandstone 

production fields in the vicinity of the general Wright analysis area include 

portions of the Hilight, Porcupine, Payne, and Rocky Hill fields (De Bruin 

2002). Drilling continued for deeper targets and resulted in the recovery of oil 

and gas in deeper reserves in the Permian-Pennsylvanian Minnelusa Formation 

in the Hilight Field and other fields. Through 2005, there had been a 15-year 

period of very little conventional oil and gas development activity in the PRB 

(BLM 2005a). 

There are several conventional oil and gas fields that produce in the vicinity of 

the general Wright analysis area, including the Hilight, Rocky Hill, Porcupine, 

and Payne Oil and Gas Fields. The Hilight Field is overlain by portions of the 

North Hilight Field, West Hilight Field, and West Jacobs Ranch LBA Tracts. 

The Rocky Hill Field is overlain by portions of the North Hilight Field and West 

Jacobs Ranch LBA Tracts; the Porcupine Field is overlain by portions of the 

North Porcupine, South Porcupine and South Hilight Field LBA Tracts; and the 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-25 

Payne Field is overlain by a portion of the North Porcupine LBA Tract (De Bruin 

2002). 

The Hilight Field is producing from or has produced primarily oil from the 

Lower Cretaceous Muddy-Newcastle Sandstone, which is the main zone of 

production within that oil and gas field. The Muddy Sandstone play covers 

much of the PRB and consists of stratigraphic traps, including marine bar, 

strandline, alluvial, and delta plain sandstone bodies. Depths to productive 

traps range from 3,000 to 14,000 feet, with most ranging from roughly 9,000 to 

10,000 feet below the surface in the general Wright analysis area. Most of the 

Muddy Sandstone wells in this field were completed in the 1960s and 1970s, 

and development within the Hilight Field has tended to occur on a 160-acre 

well spacing. The Rocky Hill Field, which is a minor oil and gas field adjacent 

to the Hilight Field, is producing or has produced oil and natural gas from the 

Muddy Sandstone, as well as the Upper Cretaceous Teckla Sandstone Member 

of the Mesaverde Group, the Upper Cretaceous Niobrara Formation, the Lower 

Cretaceous Fuson and Lakota Formations and Skull Creek Shale, and the 

Pennsylvanian Minnelusa Formation. Depths to these Upper and Lower 

Cretaceous production zones in this field are generally around 9,000 to 10,000 

feet below land surface, while depths to the older Minnelusa Formation are 

around 12,000 feet (WOGCC 2008a). 

In the general Wright analysis area, the Porcupine Field and the adjacent 

Payne Field are producing or have produced oil and gas from the Upper 

Cretaceous Sussex Sandstone Member of the Cody Shale and the Turner 

Sandy Member of the Carlile Shale. Production of oil and gas from these two 

fields has also been from or is currently from the Lower Cretaceous Muddy 

Sandstone, Skull Creek Shale, Dakota Sandstone, and Morrison Formation. 

Depths to these Upper and Lower Cretaceous production zones in these two 

fields generally range from 8,000 to 11,000 feet below land surface (WOGCC 

2008a). 

According to the WOGCC database as of May 2008, a total of 74 conventional 

oil and natural gas wells have been drilled within the six LBA tracts as applied 

for and the lands added by the respective BLM study areas included in this 

analysis. A total of 37 oil wells have been drilled within the North Hilight Field 

LBA Tract under Alternative 2: 20 of which were still producing; seven were 

shut in; and 10 were plugged and abandoned. A total of two oil wells have 

been drilled within the South Hilight Field LBA Tract under Alternative 2: one 

of which was still producing and one was plugged and abandoned. A total of 

six oil and gas wells have been drilled within the West Hilight Field LBA Tract 

under Alternative 2: one gas well of which was still producing; one gas well was 

shut in; and four oil wells were plugged and abandoned. A total of 12 oil and 

gas wells have been drilled within the West Jacobs Ranch LBA Tract under 

Alternative 2: one oil well of which was still producing; one oil well was shut in; 

and nine oil wells and one gas well were plugged and abandoned. A total of 14 

oil and gas wells have been drilled within the North Porcupine LBA Tract under 

Alternative 2: six gas wells and three oil wells of which were still producing; 
3.0 Affected Environment and Environmental Consequences 

3-26 Final EIS, Wright Area Coal Lease Applications

four oil wells were plugged and abandoned; and one gas well was plugged and 

abandoned. A total of three oil and gas wells have been drilled within the 

South Porcupine LBA Tract under Alternative 2: one gas well of which was still 

producing and two oil wells were plugged and abandoned. As of May 2008, no 

conventional oil or natural gas wells have been drilled within these six LBA 

tract study areas since 1990. 

According to the January 2008 reserve estimate of conventional oil and gas 

resources that was prepared by A&C, of the 33 wells capable of producing oil or 

conventional gas that are located within these six LBA tracts, each configured 

under Alternative 2, 16 wells are considered to have recoverable reserves using 

in-place recovery methods. Estimated remaining recoverable reserves from 

these 16 wells are approximately 43,308 barrels of oil and 1.654 million cubic 

feet (mmcf) of natural gas (A&C 2008). 

Higher oil prices experienced recently have helped prevent the abandonment of 

low-producing wells and could potentially increase conventional oil and gas 

exploration as well as secondary recovery in the PRB. Since 1990, most 

reserve additions in the U.S.-89 percent of oil reserve additions and 92 percent 

of gas reserve additions-have come from finding new reserves in old fields (OFE 

1999). Most recent reserve additions in the PRB have come from old fields 

(BLM 2005g). Secondary recovery uses methods like gas reinjection and water 

flooding to boost primary production and displace hydrocarbons not produced 

in the primary recovery phase. Enhanced oil recovery involves the injection of 

liquids or gases (such as carbon dioxide) to stimulate hydrocarbon flow 

bypassed in earlier recovery phases (BLM 2005g). Sources of fresh or treatable 

water is needed for water flooding and accessibility to cheap natural gas is 

needed for gas injection projects; however, sources of abundant fresh water 

and cheap natural gas are not currently available in the general Wright 

analysis area. Enhanced oil recovery using carbon dioxide (CO2) flooding also 

has the potential to increase oil recovery in the general Wright analysis area, 

but the infrastructure (e.g., CO2 pipelines, etc.) is not currently in place (BLM 

2005a). 

Section 3.11 includes a discussion of the ownership of the oil and gas 

resources in each of the BLM study areas for the six LBA tracts included in this 

analysis. The 33 conventional oil and gas wells located in the BLM study areas 

for the six LBA tracts that are capable of production are listed in Appendix E. 

3.3.2.1.2 Unconventional Oil and Gas

Continuous hydrocarbon accumulations form a geologically diverse group that 

includes CBNG, tight-sand gas, shale gas, basin-center gas, gas hydrates, and 

shallow biogenic gas. These various petroleum deposits are linked together as 

continuous accumulations by two key geologic characteristics: 1) they consist 

of large volumes of rock pervasively charged with oil or gas, and 2) they do not 

depend upon the buoyancy of oil or gas in water for their existence (Schmoker 

2005). 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-27 

The USGS estimated means of undiscovered continuous oil and natural gas 

resources in the PRB of Wyoming and Montana, as of December 2006, are 424 

million barrels of oil, 15.5 trillion cubic feet of natural gas, and 26 million 

barrels of natural gas liquids (USGS 2006). Continuous oil and gas resources 

in the PRB occur in reservoirs ranging from Pennsylvanian to Late (Upper) 

Cretaceous age rocks, 

Natural gas from hydrocarbon rich shale formations, known as shale gas is one 

of the most rapidly expanding trends in onshore domestic oil and gas 

exploration and production today (OFE 2009). Analysts have estimated that by 

2011 most new reserves growth in the U.S. will come from continuous natural 

gas accumulations in highly organic shales and tight sands (OFE 2009). In 

their 2009 analysis of modern shale gas development in the United States, the 

U.S. Department of Energy, Office of Fossil Energy (OFE 2009) identified the 

locations of the nation’s current producing gas shales and prospective shales, 

of which the PRB was not included. 

The USGS (2006) reported that the potential for undiscovered continuous oil 

and gas resources in the PRB of Wyoming and Montana are most likely to 

occur in the Early (Lower) Cretaceous Mowry Continuous Oil Assessment Unit, 

the Upper Cretaceous Niobrara Continuous Oil Assessment Unit, the Lower 

Fort Union Lance Formation CBNG Assessment Unit, the Upper Fort Union 

Formation CBNG Assessment Unit, the Wasatch Formation CBNG Assessment 

Unit, and an unnamed “Shallow Continuous Biogenic” Gas Assessment Unit. 

Shale gas investigations by the Wyoming State Geological Survey are currently 

focused on the Lower Cretaceous Mowry Shale, which is one of the major 

source rocks in the northern Rocky Mountain region. The Mowry Shale is 

extensively distributed throughout Wyoming’s Laramide basins and has 

considerable potential for shale gas production (WSGS 2010). Depths to the 

Mowry Shale in the general Wright analysis area are generally 8,000 to 10,000 

feet. Drilling for these resources is currently occurring in the Keeline and Wild 

West Oil and Gas Units (Elser 2010), which are located just east of the Black 

Thunder and Jacobs Ranch mines in T.43N., R.69W. and T.44N., R.69W., 

respectively. 

Continued advances in technology will be key to providing the most effective 

means of reducing costs and minimizing adverse environmental impacts when 

trying to recover unconventional hydrocarbon resources (OFE 2003). 

3.3.2.1.2.1 Coal Bed Natural Gas (CBNG)

CBNG has been commercially produced in the PRB since 1989 when 

production began at the Rawhide Butte Field located northwest of the Gillette, 

Wyoming (De Bruin and Lyman 1999). Extensive CBNG development has 

occurred on lands immediately west of the surface coal mines, including the 

North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, 

North Porcupine, and South Porcupine LBA Tracts. The predominant CBNG 
3.0 Affected Environment and Environmental Consequences 

3-28 Final EIS, Wright Area Coal Lease Applications

production to date in this area has occurred from the upper Fort Union 

Formation Wyodak-Anderson coal zone, which are the same coal beds (or 

equivalent to the coal beds) being mined by the surface coal mines. The 

Wyodak-Anderson 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 also being produced from other, deeper coal seams locally throughout the 

PRB. 

In order for CBNG to be produced, the hydrostatic pressure in the coal must be 

reduced to a level that can vary from coal to coal, which allows the gas to 

desorb from the coal. This is accomplished by removing water from the coal 

bed. CBNG reservoirs can be affected by any nearby activities, including coal 

mining, that reduce the hydrostatic pressure in the coal bed. 

The Wyoming BLM State Office-Reservoir Management Group (WSO-RMG) has 

recently prepared a variety of detailed analyses of CBNG resources in the lands 

near (meaning those townships within and adjacent to) the existing surface 

coal mines in the Wyoming PRB for coal leasing and other actions. The WSORMG completed a report in 2006 that describes the existing/affected 

environment of the coal mining areas and adjacent lands, with respect to 

CBNG resources, and documents the observed and inferred resource depletion 

that has and will continue to occur (WSO-RMG 2006). 

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 Wyodak-Anderson coal 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 standard cubic feet per ton (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. Analyses by WSO-RMG, USGS, CBNG 

operators, and others have shown that dewatering of the coal beds, by both 

CBNG production and mine dewatering, reduces the hydrostatic pressure in 

the coals and allows the CBNG to desorb and escape from the coal. These 

effects have been ongoing and it is likely that desorption has continued since 

2000; as a result, coal gas content and the gas-in-place adjacent to the existing 

mines would currently be expected to be less than in 2000. 

WOGCC well data from the areas adjacent to the PRB surface coal mines 

generally show that operator interest peaked prior to 2000 and 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 

(WSO-RMG 2006). 

CBNG wells were initially drilled on 40-acre spacing in the Wyoming PRB. 

Production/reservoir analyses that have been submitted to the WOGCC in 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-29 

various public hearings have indicated that CBNG wells in the PRB will 

produce reserves from larger areas than 40 acres. As a result, the WOGCC 

established an 80-acre spacing pattern as the default spacing for CBNG wells 

completed in the PRB within the Fort Union and Wasatch Formations. Most 

CBNG wells on and near the general Wright analysis area were drilled on an 

80-acre pattern, although some were drilled on a 40-acre pattern because they 

were drilled before the spacing was changed to 80 acres. Certain townships in 

the PRB are exempt from the 80-acre spacing pattern rule; however, those 

townships are north of the general Wright analysis area (WOGCC 2008b). 

Although CBNG has been produced in this area for about 10 years, there are 

still some undrilled 80-acre spacing units in and around the general Wright 

analysis area. However, there has been little recent interest in drilling 

additional wells for completion in the Wyodak-Anderson coal zone in this area. 

CBNG is also being produced locally from other deeper seams in the PRB (e.g., 

Cook, Wall, and Pawnee coal seams of the Tongue River Member of the Fort 

Union Formation)., although no wells have been completed in the deeper seams 

on and immediately west of the North Hilight Field, South Hilight Field, West 

Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA 

Tracts (WOGCC 2008a). 

According to the WOGCC database as of May 2008, a total of 287 wells have 

been drilled for CBNG production within the six LBA tracts as applied for and 

the lands added by the respective BLM study areas included in this analysis. A 

total of 40 wells have been drilled within the North Hilight Field LBA Tract 

under Alternative 2: 34 of which were still producing and six were shut in. A 

total of 32 wells have been drilled within the South Hilight Field LBA Tract 

under Alternative 2: 10 of which were still producing; nine were plugged and 

abandoned, seven were shut it; and six were dry holes. A total of 61 wells have 

been drilled within the West Hilight Field LBA Tract under Alternative 2: 38 of 

which were still producing; 13 were plugged and abandoned, nine were shut it; 

and one was a dry hole. A total of 99 wells have been drilled within the West 

Jacobs Ranch LBA Tract under Alternative 2: 78 of which were still producing; 

11 were shut in; and 10 were plugged and abandoned. A total of 43 wells have 

been drilled within the North Porcupine LBA Tract under Alternative 2: 42 of 

which were still producing and one was shut in. A total of 12 wells have been 

drilled within the South Porcupine LBA Tract under Alternative 2: 10 of which 

were still producing and two were shut in. 

The ownership of oil and gas resources in the North Hilight Field, South Hilight 

Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South 

Porcupine LBA Tracts, which includes the CBNG resources, is discussed in 

Section 3.11. The 248 CBNG wells located in the BLM study areas for the six 

LBA tracts that are capable of production (including those that are currently 

shut in) are listed in Appendix E. 
3.0 Affected Environment and Environmental Consequences 

3-30 Final EIS, Wright Area Coal Lease Applications

3.3.2.1.3 Other Minerals

Bentonite, uranium, and clinker 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 drilling mud. No mineable 

bentonite reserves have been identified on any of the LBA tracts under the 

Proposed Action or Alternative 2 or 3. 

There are substantial uranium resources in southwestern Campbell and 

western Converse Counties. There is currently one producing uranium mining 

operation in Wyoming, the Smith Ranch-Highland in-situ recovery operation, 

which is located in west-central Converse County (WSGS 2009). No known 

uranium reserves exist within the general Wright analysis area. 

Clinker, which is also sometimes referred to as scoria, burn, or porcelanite, has 

been and continues to be a major source of aggregate for road construction in 

the area due to the shortage of more competent materials. Clinker consists of 

sediments that were baked, fused, or melted in place when an underlying coal 

seam burned. Clinker is present within the existing Black Thunder, Jacobs 

Ranch, and North Antelope Rochelle mine permit areas, predominantly east of 

the mineable coal limit. Clinker does occur on the eastern-most portion of the 

North Hilight Field LBA Tract configured under Alternative 2, but does not 

occur on the other five LBA tracts as applied for under the Proposed Actions or 

within the additional areas evaluated under Alternative 2 or 3. 

A search of the BLM Land and Mineral Use Records revealed that no active 

mining claims are presently located on the LBA tracts as applied for under the 

Proposed Actions or within the additional areas evaluated under Alternatives 2 

or 3 (BLM 2008b). 

3.3.2.2 Environmental Consequences

3.3.2.2.1 Proposed Action and Alternatives 2 and 3

With the exception of developing continuous oil and gas resources from source 

rocks below the mineable Wyodak-Anderson coal beds, other minerals present 

on the LBA tracts could not be developed during mining. Some of these other 

minerals could, however, be developed after coal mining and reclamation are 

completed. 

The conventional oil and gas reservoirs below the mineable Wyodak-Anderson 

coal beds would not be directly disturbed by removal of the mineable coal. The 

existing conventional oil and gas wells on the North Hilight Field, South Hilight 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-31 

Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South 

Porcupine LBA Tracts under the Proposed Actions or Alternatives 2 or 3, as 

discussed above, would have to be plugged and abandoned, and all production 

equipment would have to be removed before mining operations could begin. 

Following mining and reclamation, the oil and gas lessees could 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 drilling the wells and rebuilding the production 

infrastructure. As discussed above, conventional oil and gas resources in the 

general Wright analysis area have been extensively developed. According to the 

A&C’s 2008 evaluation, the actively producing wells, as presently completed, 

located within the BLM study areas for the six WAC LBA tracts appear to have 

exhausted most of their recoverable reserves, with approximately 5 percent of 

the recoverable oil and 11 percent of the recoverable gas remaining in these 

wells (A&C 2008). No conventional oil and gas wells have been drilled in the 

general Wright analysis area over the last 18 years, so the area generally 

appears to be unfavorable for additional production from known conventional 

reservoirs. 

Currently, the drilling and completion of shale gas wells includes both vertical 

and horizontal wells. Horizontal wells provide more exposure to a formation 

than a vertical well does; six to eight horizontal wells drilled from one well pad 

can access the same volume of source rock as sixteen vertical wells (OFE 

2009). As stated in Section 3.3.2.1.2, there is active interest in Mowry 

continuous shale gas near the general Wright analysis area, and it is 

anticipated that horizontal wells would be used almost exclusively to develop 

this continuous gas play (Elser 2010). It is possible that horizontal wells could 

be drilled from surface locations outside of the LBA tracts and deviated to run 

horizontally beneath the tracts within source rocks that are many thousands of 

feet deeper than the mineable Wyodak-Anderson coal beds. Continuous oil 

and gas resources could be developed in this manner on the LBA tracts during 

mining. 

Before mining operations could begin, all active CBNG wells would have to be 

plugged and abandoned, and all gas production equipment would have to be 

removed. CBNG resources that have not been recovered from the WyodakAnderson zone prior to mining would be lost when the coal is removed. 

CBNG production requires withdrawal of water from the coal seams to reduce 

hydrostatic pressure and enable methane desorption from the coals. WSORMG’s analyses indicate that depletion of the hydrostatic pressures and 

methane resources starts to occur adjacent to mining areas a short time after 

mining begins, and 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). Groundwater level data 

compiled by the Gillette Area Groundwater Monitoring Organization (GAGMO) 

in 2000 and earlier indicated that widespread hydrostatic pressure depletion in 

the affected coal seam aquifers had occurred since mining began in the late 
3.0 Affected Environment and Environmental Consequences 

3-32 Final EIS, Wright Area Coal Lease Applications

1970s and early 1980s. Hydrostatic pressures had declined by as much as 60 

percent in the southern group of mines, and coal gas in place can be inferred to 

have been depleted by similar proportions. The ongoing reduction of 

hydrostatic pressure in the coal beds due to mining has been accelerated by 

extensive CBNG production from surrounding lands. 

WSO-RMG’s analyses of the production and reservoirs indicate that the CBNG 

resource within the Wyodak-Anderson seam has been substantially depleted, 

either by mining or by recovery from producing wells. It seems likely that the 

wells presently capable of production that are located within the BLM study 

areas for the six LBA tracts included in this EIS (Appendix E) will have 

exhausted their economic reserves prior to initiation of mining in the LBA 

tracts. It is also likely that any undrilled spacing units in the BLM study areas 

will have been drained and dewatered by production from the existing wells 

and nearby mining activity prior to initiation of mining in the LBA tracts. 

Mining operations within the LBA tracts could not begin until permitting is 

completed, which generally requires several years after a lease is acquired. By 

that time, it is likely that most of the economically recoverable CBNG resource 

would have been produced. CBNG production from the coal zones underlying 

the Wyodak-Anderson coal zone would not be directly disturbed by surface 

mining operations and could be delayed as the parcel is mined. If production 

from these lower seams is established on the LBA tracts in the future, 

additional measures would be required to accommodate both mining and 

CBNG production (see Section 3.3.2.3). 

Section 3.11.1 includes a discussion on the current ownership of the oil and 

gas resources on the LBA tracts and the oil and gas facilities in the area of the 

tracts. 

3.3.2.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and coal removal and the associated 

disturbance would not occur on the portions of the LBA tracts as applied for or 

the LBA tracts configured under Alternative 2 that will not be disturbed under 

the currently approved surface coal mining permits. Mining operations would 

continue to limit the development of other mineral resources described above 

on the existing adjacent Black Thunder, Jacobs Ranch and North Antelope 

Rochelle Mine coal leases. Mineral development limitations related to mining 

operations at these three applicant mines would not be extended onto portions 

of the LBA tracts that will not be affected under the current mining and 

reclamation plans. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective tract in the future. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-33 

3.3.2.3 Regulatory Compliance, Mitigation and Monitoring

The reservoir analyses conducted by A&C (2008) indicate that most of the 

recoverable conventional oil and gas resources on the North Hilight Field, 

South Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, 

and South Porcupine LBA Tracts have been extracted by the existing wells. 

Reservoir analyses conducted by the BLM WSO-RMG indicate that most of the 

recoverable CBNG resources in the Wyodak-Anderson coal zone on these six 

LBA tracts have probably been produced by the existing wells. Potential does 

exist for conflicts between coal operations and CBNG and conventional oil and 

gas wells completed in formations and coal zones below the Wyodak-Anderson 

seam. 

If the federal coal in the tracts is leased and conflicts do develop between the 

operators of the oil and gas wells and the surface coal mine operators, there are 

several mechanisms that can be used to facilitate recovery of the conventional 

oil and gas and CBNG resources prior to mining. These include: 

• 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 2006a). This memorandum offers 

royalty incentives to CBNG operators to accelerate production in order 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 these LBA tracts 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 tracts 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. 
3.0 Affected Environment and Environmental Consequences 

3-34 Final EIS, Wright Area Coal Lease Applications

• 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

WSO-RMG’s 2006 analyses of the CBNG production and reservoirs within the 

Wyodak-Anderson seam in the areas within and adjacent to the existing PRB 

coal mines indicated that the resource has been substantially depleted, either 

by mining or by recovery from producing wells. It therefore seems likely that 

the CBNG wells capable of production that are located within the BLM study 

areas for the six LBA tracts (Appendix E) will have exhausted the reserves prior 

to initiation of mining in the LBA tracts. In the improbable event that any 

CBNG remains in the Wyodak-Anderson coal when it is exposed by mining, the 

gas would be vented to the atmosphere and permanently lost. 

3.3.3 Paleontology

3.3.3.1 Affected Environment

The region of the PRB, where the general Wright analysis area is located, is 

exclusively comprised of sedimentary rocks from the Lower Tertiary Period, 

including exposures of the Eocene age Wasatch Formation at the surface with a 

few minor exposures of the underlying Paleocene age Fort Union Formation 

(Green and Drouillard 1994, Love and Christiansen 1985). The Wasatch 

Formation, the geologic formation exposed on the surface of the North Hilight 

Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, North 

Porcupine, and South Porcupine LBA Tracts, has been interpreted to represent 

a fluvial system dominated by meandering channel belts (Pocknall 1987). This 

formation consists of buff tan to gray, non-marine, arkosic sandstone, drab 

siltstone, varicolored mudstone, lenticular pebble conglomerate, and 

carbonaceous shale. The formation also contains numerous relatively thin, 

discontinuous coal seams near the base. Most lithologies are poorly cemented 

with the exception of some calcite-cemented sandstone beds. Clinker deposits 

are also present in the area with this formation. Formation thickness can be 

up to 2,000 feet (Love and Christiansen 1985). 

The Paleontological Resource Preservation Act (PRPA) was passed as part of the 

Omnibus Public Land Management Act of 2009 and is referenced as Public Law 

111-011 Subtitle D. Land managing agencies are currently in the process of 

developing guidelines and procedures to implement PRPA. Several key features 

of PRPA include the definition of paleontological resources, a mandate to 

manage paleontological resources on federal lands using scientific principles 

and expertise, criteria for issuing permits to collect paleontological resources, 

definitions of specifically prohibited acts, specific penalties for violations, and 

an exemption of specific paleontological locality data from Freedom of 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-35 

Information Act (FOIA) requests. Overall, PRPA gives land managing agencies 

the authority to specifically protect and manage paleontological resources on 

federal lands. 

BLM ranks geologic formations according to their potential to contain 

vertebrate fossils or noteworthy occurrences of invertebrate or plant fossils. 

The Wasatch Formation is ranked as fulfilling BLM Paleontology Condition No. 

1, which is described in the Paleontological Resource Management Handbook 

8270-I as “areas that are known to contain vertebrate fossils or noteworthy 

occurrences of invertebrate or plant fossils.” According to the handbook, 

“consideration of paleontological resources will be necessary if the Field Office 

review of available information indicates that such fossils are present in the 

area.” 

The BLM in Wyoming currently uses an additional planning tool, called the 

Potential Fossil Yield Classification (PFYC) system (Instructional Memorandum 

No. 2008-009), which was developed by the U.S. Department of AgricultureForest Service (USFS). This system uses a Class 1-5 ranking scale where Class 

1 represents the lowest potential and Class 5 the highest potential for 

paleontological resources. The PFYC 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. 

The PFYC was used by the USFS in their 2001 revised Land and Resource 

Management Plan (LRMP) for the Thunder Basin National Grassland (TBNG). 

The USFS has designated the Wasatch Formation in the PRB as a Class 5 

under the PFYC system, which is described as follows: 

Class 5: Highly fossiliferous geologic units that consistently and predictably 

produce vertebrate fossils or scientifically significant invertebrate or plant 

fossils, and that are at risk of natural degradation and/or human-caused 

adverse impacts. 

The BLM considers the Wasatch Formation to fulfill the PFYC Class 5 in other 

parts of Wyoming; however, the BLM considers the Wasatch Formation in the 

PRB to fulfill the PFYC Class 3a. Class 3a formations in the PFYC system are 

described as follows: 

Class 3a: Fossiliferous sedimentary geologic units known to contain 

vertebrate fossils or scientifically significant fossils, but occurrences are 

widely scattered. Common invertebrate or plant fossils may be found in the 

area, and opportunities may exist for hobby collecting. The potential for a 

project to be sited on or impact a significant fossil locality is low, but is 

somewhat higher for common fossils. 
3.0 Affected Environment and Environmental Consequences 

3-36 Final EIS, Wright Area Coal Lease Applications

The Eocene Wasatch Formation has been known to produce abundant and 

significant paleontological resources in several basins throughout Wyoming 

(Delson 1971, Winterfeld 1978, EVG 2001). Occurrences of significant fossils 

in this formation within the PRB have been more sporadic and less common 

than in other basins. This formation is best known for its diverse mammalian 

fauna that define the Wasatchian North American Land Mammal Age (NALMA). 

Several groups of mammals have been discovered from this formation over the 

past 150 years. PRB mammalian taxa include multituberculates, marsupials, 

insectivores, deltatherians, primates, condylarths, carnivores, rodents, 

pantodonts, perissodactyls, and artiodactyls (Delson 1971). Non-mammalian 

taxa known to occur in this formation includes champsosaurs, squamates, 

fish, turtles, crocodilians and birds. Non-vertebrate fossils include a wide 

variety of mollusks and numerous paleofloral biotas (fossil plants). The fossil 

plants inventoried are primarily leaves and fossilized wood. The leaves usually 

occur as lignitic impressions in sandstone and siltstone and as compact 

masses in shale. Leaves are the most abundant fossils found in the Wasatch 

Formation in the PRB 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. 

Distinguishing between the Eocene Wasatch and Paleocene Fort Union 

formations in the PRB is complicated. The distinction is paleontologically 

significant because the Paleocene-Eocene transition was marked by a major 

climatic shift that influenced floral and faunal communities. The base of the 

Wasatch Formation represents the Paleocene-Eocene Thermal Maximum 

(PETM), a brief period (10-20,000 years) of intense global warming that also 

marks the onset of the Eocene (Wing et al. 2003). The cause of warming has 

been attributed to a rapid, massive addition of greenhouse gases to the 

atmosphere (Dickens et al. 1995). Although the amount of warming has been 

well-documented (Kennet and Stott 1991, Zachos et al. 2005), changes of other 

climate factors such as precipitation are less resolved. Changes to faunal and 

floral community compositions during the PETM have been documented in 

Wyoming (Gingerich 2003, Smith et al. 2007). The PETM is represented in 

terrestrial and marine sediments by a negative carbon isotope excursion. 

Evidence for the carbon isotope excursion (CIE) in the PRB comes from paleosol 

carbonate nodules, mammal teeth, and bulk organic matter. These data place 

the onset of the PETM approximately 5 to 13 meters above the uppermost 

carbonaceous shale unit that exists within the base of the Wasatch Formation 

and indicate that approximately 50 meters of sediments are within the PETM 

interval (Wing et al. 2003). Similar studies place the Paleocene-Eocene 

boundary at the base of the Willwood Formation in the southern Bighorn Basin 

of Wyoming and indicate that the main PETM interval is approximately 37 

meters thick (Wing et al. 2005, Smith et al. 2007). 

Although the Wasatch Formation is known to produce fossil vertebrates of 

scientific significance in Wyoming, outcrops of the Wasatch Formation in the 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-37 

PRB are not generally well-exposed and the conditions of deposition of the 

formation have contributed to a low preservation potential for fossils. Surficial 

geologic mapping of the general Wright analysis area by the USGS (Reheis and 

Coates 1987) indicate that unconsolidated surficial deposits (i.e., colluvial and 

eolian deposits) occur widespread over the area and actual outcrops of the 

Wasatch Formation that could be prospected for fossils occur infrequently. 

The landscape of the LBA tracts’ general analysis areas is not particularly well 

suited to bedrock and paleontological exposure. 

The upper-most member of the Fort Union Formation, the Lebo Member, is less 

significant in regards to paleontological resources. Fossils occur sporadically 

and significant vertebrate specimens have rarely been reported from the PRB. 

The most common fossils from this member include various paleofloral and 

invertebrate specimens. 

Surficial materials in the general Wright analysis area are derived primarily 

from the underlying bedrock, which consists mainly of soft shale, sandstone 

and coal beds, and most of these rocks weather to fine-grained material. The 

physical properties of the weathered materials depend largely on the mode of 

transportation and deposition, whether by water, gravity, or wind that account 

for the position of the weathered materials. Actual outcrops of the Wasatch 

and underlying Fort Union formations that could be prospected for fossils 

occur infrequently and are found most commonly in areas having the steepest 

slopes (i.e., rough breaks between upland areas and drainage channels). 

3.3.3.1.1 Paleontological Resource Survey

The entire general analysis areas for the North Hilight Field, South Hilight 

Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South 

Porcupine LBA Tracts were examined for the presence of fossils, focusing 

attention on bedrock exposures and planar surfaces lacking vegetative cover. 

Anthills were also investigated. Three distinct types of paleontological localities 

could potentially exist in the general Wright analysis area. The first consists of 

in-situ (in its natural position) specimens weathering out from the point of 

original bedrock deposition. The second consists of identifiable specimens for 

which the exact source location (and contextual information) cannot be 

determined. The third consists of unidentifiable specimens (e.g., bone 

fragments) for which the source could not be determined and no contextual 

data could be recovered. 

The USFS requires that the paleontological survey of the federally-owned 

surface lands within the LBA tracts’ general analysis areas be undertaken to 

locate, identify, and document paleontological resources that might be affected, 

and to provide recommendations of management/mitigation for identified 

paleontological resources. Surveys on the federal lands (TBNG) in the general 

Wright analysis area were conducted in 2009 by qualified paleontologists with 

USFS approval to conduct paleontological resource surveys on the TBNG. 

Survey results are included in the following subsections. 
3.0 Affected Environment and Environmental Consequences 

3-38 Final EIS, Wright Area Coal Lease Applications

Each newly discovered locality was recorded on a field data sheet and marked 

on a master project field map. Site recording involved a detailed contextual 

description of the geology, stratigraphy, and lithology of each locality. 

Specimens were identified in the field to the extent possible. Global positioning 

system (GPS) coordinates were recorded as point features from each locality, 

and a detailed photographic log of the fossils and outcrops was also completed 

for each locality. Potentially significant specimens exposed on the surface were 

collected to prevent any potential loss of data. 

3.3.3.1.2 North Hilight Field LBA Tract

All lands managed by the TBNG–Douglas Ranger District (TBNG-DRD) within 

the general analysis area for the North Hilight Field LBA Tract were surveyed in 

July 2009 by ARCADIS U.S., Inc. under Paleontological Resource Special Use 

Permit DGL275. The entire project area was block surveyed. No new 

paleontological localities were discovered and no specimens were found to 

collect as a result of the survey. A report documenting the findings of the 

survey was prepared and submitted to the TBNG-DRD for review. 

3.3.3.1.3 South Hilight Field LBA Tract

All lands managed by the TBNG-DRD within the general analysis area for the 

South Hilight Field LBA Tract were surveyed in July 2009 by ARCADIS U.S., 

Inc. under Paleontological Resource Special Use Permit DGL275. The entire 

project area was block surveyed. A report documenting the findings of the 

survey was prepared and submitted to the TBNG-DRD for review. 

Two new paleontological localities were discovered in the South Hilight Field 

LBA Tract. The first locality contained abundant multi-specific leaf 

impressions in a buff to tan, very thinly-bedded sandy siltstone within the 

Wasatch Formation. The fossil-bearing unit was approximately 0.3 meters 

thick and overlaid a carbonaceous shale. Exposed bedrock from this locality 

weathered buff to light brown and tended to break along bedding planes. Leaf 

impressions were oriented parallel to bedding planes and the preservation of 

leaf morphology was excellent. Occasional woody debris up to 5 centimeters in 

diameter was also present. The leaf impressions were identified as 

Glyptostrobus sp. from the Cupressaceae family and an unknown genus of the 

family Betulaceae. The type of fossil material at this locality was considered 

relatively common, and although the locality may have scientific interest, it was 

considered to have low scientific significance. No specimens were collected or 

reposited for curation from this locality. 

The second locality covered an area of approximately 50 square meters and 

consisted of a dark brown, carbonaceous shale with extremely abundant, 

multispecific paleofloral remains. The carbonaceous shale was overlain by a 

thin (1 meter) buff, fine-grained, poorly consolidated sandstone. The sandstone 

was overlain by another carbonaceous shale, which weathers to a 

comparatively reddish horizon. The carbonaceous shale overlying the 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-39 

sandstone horizon also contained leaves, but the fossils were less abundant 

and exhibited poorer preservation. The upper horizon was exposed throughout 

the outcrop, whereas the lower, more productive horizon was only exposed 

along the eastern half because the beds dip to the west at approximately 10 

degrees. Within the lower carbonaceous shale, clastic material and 

preservation quality of individual leaves both increased upwards. The lower 

portions of the horizon were composed almost entirely of leaf remnants, many 

of which have preserved organic material. The abundance of leaves in the 

lower shale made identification of individual specimens (i.e., leaf margins) 

difficult. All of the leaf impressions were representative of angiosperm 

(broadleaf) species. Specimens representing Betulaceae, Nyssa sp. and 

Archeampelos sp. were tentatively identified. Occasional seed pods and 

possible fruit structures are occasionally present. No large pieces of petrified 

wood were identified at this locality. The type of fossil material at this locality 

is considered relatively common. Because the locality contains such abundant 

material, it may be representative of the local paleofloral community and useful 

in paleoecologic and paleoclimatic reconstructions. Furthermore, because its 

stratigraphic location near the base of the Wasatch Formation places it near 

the Paleocene-Eocene boundary, this location may represent a paleoflora from 

the PETM, a brief warm period marked by floral and faunal migrations which 

has been intensively studied over the past decade (Wing et al. 2005). 

Paleobotanists with potential interest in the locality (Scott Wing – Smithsonian 

Institution and Kirk Johnson – Denver Museum of Nature and Science) were 

informed of its location and potential significance. No specimens were collected 

or reposited for curation from this locality. 

3.3.3.1.4 West Hilight Field LBA Tract

All lands managed by the TBNG-DRD within the general analysis area for the 

West Hilight Field LBA Tract were surveyed in July 2009 by ARCADIS U.S., Inc. 

under Paleontological Resource Special Use Permit DGL275. The entire project 

area was block surveyed. A report documenting the findings of the survey was 

prepared and submitted to the TBNG-DRD for review. 

Only one new locality was discovered as a result of the field survey. This 

locality contained scattered bone and petrified wood fragments. Bone 

fragments have weathered to a dull yellow or brown color. All fragments except 

one were smaller than one square inch. The fossils were found weathering 

from Wasatch Formation regolith. Due to the flat topography, no contextual 

geologic data could be collected. The fragments were not identifiable in terms 

of animal type or anatomy. Examination of anthills in the vicinity of the 

locality produced no teeth or other bone fragments. Although the fragments 

were broken and weathered beyond the point of usefulness, they were well 

preserved and hard, indicating that identifiable fragments may exist. However, 

discovery of identifiable fossils was considered unlikely due to the low density 

of bones at the ground surface and overall limited ground visibility. Thus, the 

locality was considered to have low scientific significance, and no specimens 

were collected or reposited for curation from this locality. 
3.0 Affected Environment and Environmental Consequences 

3-40 Final EIS, Wright Area Coal Lease Applications

3.3.3.1.5 West Jacobs Ranch LBA Tract

No lands are managed by the TBNG-DRD within the general analysis area for 

the West Jacobs Ranch LBA Tract. Therefore, paleontological surveys in the 

project area were not conducted by a paleontologist with USFS approval. 

However, professional archeologists, in effort to locate unique localities of 

fossilized bone, closely examined Wasatch outcrops in conjunction with their 

intensive pedestrian surveys for cultural resources. Such concentrations of 

fossilized bone were not found. The only observed fossils were of small petrified 

wood fragments. No significant or unique paleontological resource localities 

have been recorded in the West Jacobs Ranch tract’s general analysis area. 

3.3.3.1.6 North Porcupine LBA Tract

All lands managed by the TBNG-DRD within the general analysis area for the 

North Porcupine LBA Tract were surveyed in November 2009 by ARCADIS U.S., 

Inc. under Paleontological Resource Special Use Permit DGL275. The entire 

project area was block surveyed. A report documenting the findings of the 

survey was prepared and submitted to the TBNG-DRD for review. 

A background investigation was conducted to identify any publications, 

reports, collections records or previous field surveys that detailed any 

paleontological discoveries in or near the general analysis area for the North 

Porcupine LBA Tract. USFS and BLM were also consulted by ARCADIS to 

identify any known paleontological resources in the vicinity of the project area. 

The northern portion of the tract’s general analysis area was previously block 

surveyed by Uinta Paleontological Associates (UPA 2008). No previously 

discovered localities were identified. 

Overall, two new paleontological localities were discovered in the project area 

by the paleontologists. Localities consisted of moderately well-preserved 

specimens discovered as float (not in-situ). Both localities discovered in the 

LBA tract’s general analysis area are from the Wasatch Formation. 

The first locality contained associated scattered vertebrate bone and petrified 

wood fragments. Despite the heavy weathering due to exposure, the fragments 

exhibited relatively good preservation of bone structure. A long bone or rib 

fragments, a jaw fragment from a small crocodilian, and the distal end of a 

small tibia were recognizable, although none were complete enough to identify 

taxonomically. The locality was in an area of lightly rolling topography and no 

bedrock was visible at or in the vicinity of the locality. Because vertebrate 

fossils from this portion of the PRB are relatively rare, these fossils were 

collected for curation, and pending taxonomic identification may be considered 

scientifically significant. 

The second locality contained isolated, scattered, unidentifiable vertebrate bone 

fragments as well as abundant petrified wood fragments. Based on the highly 

porous bone structure, the fragments are possibly crocodilian. This locality 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-41 

was discovered in an area that was previously inventoried by Uinta 

Paleontological Associates, Inc. as the result of spot checking areas of exposed 

bedrock. This locality is within a bedrock exposure of the Wasatch Formation, 

consisting of poorly cemented, fine-grained, gray sandstone. Silicified wood 

fragments were often found as float downslope from the bedrock outcrops, and 

one large (8-inch diameter) petrified log was identified in-situ; however, these 

resources are common and not considered to be scientifically significant. 

Because the vertebrate fossils were unidentifiable with no contextual data, they 

are not considered to be scientifically significant and were not collected. 

In summary, two new paleontological localities were discovered during this 

2009 survey. Both of the localities contained vertebrate fossil material and 

were discovered in the Wasatch Formation. Specimens discovered on the 

surface at one of the localities were collected and will be reposited with the 

Denver Museum of Nature and Science. Because no in-situ sources for the 

discovered fossil fragments were identified, further efforts to recover additional 

fossil material are considered unlikely to be successful. Fragments of fossilized 

wood were intermittently identified throughout the North Porcupine general 

analysis area, but were not considered scientifically significant. 

3.3.3.1.7 South Porcupine LBA Tract

All lands managed by the TBNG-DRD within the general analysis area for the 

South Porcupine LBA Tract were surveyed in November 2009 by ARCADIS 

U.S., Inc. under Paleontological Resource Special Use Permit DGL275. The 

entire project area was block surveyed. A report documenting the findings of 

the survey was prepared and submitted to the TBNG-DRD for review. 

A background investigation was conducted to identify any publications, 

reports, collections records or previous field surveys that detailed any 

paleontological discoveries in or near the general analysis area for the South 

Porcupine LBA Tract. USFS and BLM were also consulted by ARCADIS to 

identify any known paleontological resources in the vicinity of the project area. 

No previously discovered paleontological localities were identified within the 

project area. 

As described in Section 3.2.1, the terrain in the northern portion of the South 

Porcupine tract is comprised of gently rolling hills with subdued draws, but the 

southern portion of the tract contains steep-sided gullies that have formed as a 

result of deep incision by the headwaters of tributaries to Horse, Antelope, and 

Porcupine creeks. 

Overall, 10 new paleontological localities were discovered in the project area by 

the paleontologists. Localities discovered in the LBA tract’s general analysis 

area are from both the Wasatch and Fort Union formations. 

The first locality contains the terminal ends of two possible limb bones, 

abundant crocodilian scutes (skin armor), a crocodilian jaw fragment, a heavily 
3.0 Affected Environment and Environmental Consequences 

3-42 Final EIS, Wright Area Coal Lease Applications

abraded rib fragment and numerous unidentifiable bone fragments. The fossils 

at this locality were discovered at the surface of a fine- to medium-grained, 

poorly cemented, gray-tan sandstone near the base of the Wasatch Formation. 

It is highly likely that additional fossil material may be buried at this locality, 

and because of their potential scientific significance, all fossil material 

discovered on the surface was collected from this locality. 

The second locality contains one unidentified in-situ vertebrate bone. The 

specimen is extremely fragile and preserved within a very poorly-cemented 

sandstone block in the lower Wasatch Formation. The significance of this fossil 

cannot be assessed without identification, which cannot be determined without 

careful excavation and preparation. The specimen was not collected due to its 

fragile condition. 

The third locality contains abundant freshwater unionid mollusk shells. The 

shells are very fragile and often crumble or flake apart when handled. Due to 

the fragile nature of the specimens, it was very difficult to identify them to a 

taxon, although several specimens appear to be from the genus Plesielliptio. 

These fossils were discovered in-situ within a poorly cemented fine- to very 

fine-grained, very well sorted sandstone interbedded with mudstone. The 

outcrop is capped by a well-cemented, very fine-grained sandstone that 

contains occasional woody debris. This locality occurs in the Lebo Member of 

the Fort Union Formation. The type of invertebrate fossil materials at this 

locality is considered relatively common, and although the locality may have 

scientific interest in terms of taphonomy or paleogeography, it is considered to 

have low scientific significance. No specimens were collected from this locality. 

The fourth locality contains abundant unionid mollusk shells similar to those 

found at the third locality, but the shells at this locality are somewhat better 

preserved, less fragile, and more complete. At least one genus, Plesielliptio, was 

recognized. These shells were discovered in-situ within a very fine-grained 

sandstone overlying a carbonaceous shale within the Lebo Member of the Fort 

Union Formation. These invertebrate fossils are considered relatively common, 

and although the locality may have scientific interest in terms of taphonomy or 

paleocommunity structure, it is considered to have low scientific significance. 

These specimens occur in both Paleocene and Eocene and therefore do not 

serve as good biostratigraphic markers in that respect. Due to the poor 

preservation of fossil material and common occurrence, no specimens were 

collected from this locality. 

The fifth locality contains abundant associated vertebrate bones identified as 

Champsosaurus sp. Skeletal elements present include distal tibia, two dorsal 

vertebrae, and other bone fragments, including a partial illium. The bones are 

relatively well preserved and exhibit moderate weathering. Although found as 

surface float within the Lebo Member of the Fort Union Formation, the fossils 

were constrained to a small area, and the lack of dispersal suggests minimal 

transport resulting from modern erosion processes. It is highly likely that 

additional in-situ resources are present at this location. The paleontological 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-43 

resources at this locality are considered to be scientifically significant given the 

abundance of associated vertebrate fossil material that appears to represent a 

single individual and the high potential for additional buried material to be 

located in-situ. All fossil material on the surface was collected. Excavation of 

this locality may likely yield additional significant paleontological resources. 

The sixth locality contains abundant vertebrate fossils, including five 

Champsosaurus dorsal vertebrae, crocodilian scutes, and other associated 

unidentifiable bone fragments. The Champsosaurus vertebrae are identified on 

the basis of amphicoelous centra and an hourglass-shaped neural spine when 

viewed dorsally. The vertebrae and larger bone fragments were all found on the 

surface in close association and are interpreted to have weathered from the 

same horizon. Abundant crocodilian scutes and unidentified bone fragments 

were scattered amongst colluvium throughout the locality. These fossils were 

located within colluvium and residuum formed in the uppermost Lebo Member 

of the Fort Union Formation. Fossil material from this locality appears to be in 

the same stratigraphic position as the fossils discovered at the fifth locality. 

The paleontological resources at this locality are considered to be scientifically 

significant given the abundance of associated vertebrate fossil material that 

appears to represent a single individual and the high potential for additional 

buried material to be located in-situ. All fossil material on the surface was 

collected. Excavation of this locality may likely yield additional significant 

paleontological resources. Additionally, samples of paleofloral fossils from 

underlying carbonaceous shale at this locality could provide additional 

contextual paleoecological data. 

The seventh locality contains numerous heavily abraded crocodilian scutes, a 

possible crocodilian ungal phalanx (toe claw), and unidentifiable bone 

fragments. All fossils at this locality have good preservation despite heavy 

weathering. Fossils were discovered as surface float along a flat, heavily 

vegetated surface. The regolith at the surface has weathered from the 

underlying Lebo Member of the Fort Union Formation. The specimens were not 

discovered in-situ and therefore no contextual depositional data was available. 

The abundance of fossil material at this locality spread across the surface may 

indicate the presence of additional buried paleontological resources. All 

specimens discovered on the surface were collected. With no exact source 

identified, it is difficult to predict if excavation would yield additional 

paleontological resources. 

The eighth locality contains abundant paleofloral impressions in a very wellcemented siltstone. Most specimens were observed to be broadleaf, but 

occasional Glyptostrobus (a narrow-leaf cypress) specimens were observed. The 

partially silicified siltstone containing these leaf fossils is in the Lebo Member 

of the Fort Union Formation. This locality is very similar lithologically and 

stratigraphically to the sixth locality and was probably preserved during the 

same depositional sequence. The type of fossil material at this locality is 

considered relatively common, and although the locality may have scientific 
3.0 Affected Environment and Environmental Consequences 

3-44 Final EIS, Wright Area Coal Lease Applications

interest, it is considered to have low scientific significance. No specimens were 

collected from this locality. 

The ninth locality contains abundant gastropod fossils. The specific taxon 

represented by these gastropods has not been determined, but only one 

morphology was observed. The shells are well preserve with distinct 

morphology, including pronounced horizontal varices on each whorl with less 

pronounced vertical varices. The fossils were abundant and could be found 

along the entire exposure of the fossil-bearing horizon, which is a single 

mudstone in the Lebo Member of the Fort Union Formation. The type of 

invertebrate fossil material at this locality is considered relatively common, and 

although the locality may have scientific interest in terms of taphonomy or 

paleocommunity structure, it is considered to have low scientific significance. 

No specimens were collected from this locality. 

The tenth locality contained an in-situ single small robust humerus, possibly 

from a medium-sized reptile. The lack of epiphyseal sutures excludes the 

possibility of the bone representing any mammal species, and the dense, 

robust, non-hollow character excludes birds. The bone is well preserved, even 

though both termini are highly abraded, indicating transport prior to 

fossilization. The fossil was discovered in-situ within a medium-grained, poorly 

cemented quartzitic sandstone in the lowermost Wasatch Formation. The 

outcrop containing this locality forms the headwall of a steep headcut in an 

ephemeral stream channel. No other bone material, including fragments, was 

discovered at this locality. This specimen is considered to be scientifically 

significant as it is well preserved, identifiable and was discovered in-situ, 

allowing for the collection of important contextual data. Even though no 

additional fossil bones were discovered on the surface, it is highly likely that 

additional buried fossil material may be present at this locality. Excavation 

efforts at this locality may potentially yield additional significant paleontological 

resources. The humerus discovered at this locality was removed from the 

bedrock and collected to prevent any future adverse impacts to the specimen. 

In summary, 10 new paleontological localities were discovered during this 

survey. Six of the localities contained fossil vertebrate material, three localities 

contained fossil invertebrate material, and one locality contained fossil plant 

impressions. Three vertebrate localities were discovered in the Wasatch 

Formation, while the remaining seven localities were discovered in the Lebo 

Member of the Fort Union Formation. Vertebrate specimens exposed on the 

surface that did not require excavation were collected from five localities. All 

collected specimens will be reposited with the Denver Museum of Nature and 

Science. None of the invertebrate or plant localities discovered during this 

2009 survey were considered rare of scientifically significant, and therefore no 

specimens were collected from them. Fragments of fossil wood were 

intermittently identified throughout the general analysis area for the South 

Porcupine LBA Tract, but were not considered scientifically significant. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-45 

3.3.3.2 Environmental Consequences

3.3.3.2.1 Proposed Action and Alternatives 2 and 3

Fossils with scientific significance could be present on the tracts but not 

exposed at the surface. If the tracts are leased under the Proposed Actions or 

Alternatives 2 or 3, paleontological resources located on the tract that are not 

exposed on the surface would be destroyed when the overburden is removed. 

Paleontological resources adjacent to the mine areas may be impacted as a 

result of increased access to the areas. There may be increased unauthorized 

collecting of fossils associated with recreational activity and other pursuits 

outside adjacent to mine permit areas. Unintended or uninformed impacts 

related to increased off-road traffic outside of but adjacent to mine permit areas 

during mine related activities are the most frequent impacts to paleontological 

resources. 

The sections that follow describe the potential impacts to paleontological 

resources on each LBA tract under the Action Alternatives. 

3.3.3.2.1.1 North Hilight Field LBA Tract

No fossils, scientifically significant or otherwise, were identified or collected 

during the July 2009 survey. No additional paleontological mitigation 

measures prior to mining-related disturbances are recommended by the 

qualified paleontologist who conducted the survey. 

3.3.3.2.1.2 South Hilight Field LBA Tract

All localities would likely be affected by mining activities if the LBA tract is 

leased under the Proposed Action or Alternative 2, BLM’s preferred alternative. 

No scientifically significant fossils were identified or collected during the July 

2009 survey. The type of fossil material at one locality was considered 

relatively common, and although the locality may have scientific interest, it was 

considered to have low scientific significance. Because the locality contains 

such abundant material, it may be representative of the local paleofloral 

community and useful in paleoecologic and paleoclimatic reconstructions. 

Furthermore, because its stratigraphic location near the base of the Wasatch 

Formation places it near the Paleocene-Eocene boundary, this location may 

represent a paleoflora from the PETM. No additional specific mitigation 

measures, aside from the notification of potentially interested researchers, are 

recommended for this locality by the qualified paleontologist who conducted 

the survey. 

3.3.3.2.1.3 West Hilight Field LBA Tract

All localities would likely be affected by mining activities if the LBA tract is 

leased under the Proposed Action or Alternative 2, BLM’s preferred alternative. 
3.0 Affected Environment and Environmental Consequences 

3-46 Final EIS, Wright Area Coal Lease Applications

No scientifically significant fossils were identified or collected during the July 

2009 survey. No additional paleontological mitigation measures prior to 

mining-related disturbances are recommended by the qualified paleontologist 

who conducted the survey. 

3.3.3.2.1.4 West Jacobs Ranch LBA Tract

All localities would likely be affected by mining activities if the LBA tract is 

leased under the Proposed Action or Alternative 2, BLM’s preferred alternative. 

No significant or unique paleontological resource localities have been recorded 

in the West Jacobs Ranch tract’s general analysis area. No additional 

paleontological mitigation measures prior to mining-related disturbances would 

be necessary. 

3.3.3.2.1.5 North Porcupine LBA Tract

All localities would likely be affected by mining activities if the LBA tract is 

leased under the Proposed Action or Alternative 2, BLM’s preferred alternative. 

Scientifically significant vertebrate fossil materials were identified and 

specimens discovered on the surface at one of the localities were collected and 

will be reposited with the Denver Museum of Nature and Science. Because no 

in-situ sources for the discovered vertebrate fossil fragments were identified, 

further efforts to recover additional fossil material are considered to likely be 

unsuccessful. No additional paleontological mitigation measures prior to 

mining-related disturbances are recommended by the qualified paleontologist 

who conducted the survey. 

3.3.3.2.1.6 South Porcupine LBA Tract

All localities would likely be affected by mining activities if the LBA tract is 

leased under the Proposed Action or Alternative 2, BLM’s preferred alternative. 

No additional mitigation measures are recommended by the qualified 

paleontologist who conducted the survey for any of the invertebrate or plant 

fossil localities. Scientifically significant vertebrate specimens exposed on the 

surface that did not require excavation were collected from five localities. 

Based on the field survey, it is highly likely that additional buried fossil 

material may be present at several vertebrate fossil localities. In order to avoid 

future impacts to potentially scientifically significant paleontological resources 

at these localities, it is recommended by the qualified paleontologist who 

conducted the survey that mitigation efforts be conducted to determine if 

additional buried material is present, and to then collect any scientifically 

significant specimens. These mitigation efforts would ensure that mining 

operations would have no adverse effect on these localities. 

3.3.3.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-47 

coal lease applications would be rejected and coal removal and the potential 

associated impacts to paleontological resources would not occur on the 

portions of the LBA tracts as applied for or the LBA tracts configured under 

Alternative 2 that will not be disturbed under the currently approved surface 

coal mining permits. Mining operations would continue as permitted on the 

existing Black Thunder, Jacobs Ranch, and North Antelope Rochelle Mine coal 

leases. Impacts to paleontological resources related to mining operations at 

these three applicant mines would not be extended onto portions of the LBA 

tracts that will not be affected under the current mining and reclamation 

plans. 

As discussed in Section 2.2, a decision to reject one or more of these six Wright 

area coal (WAC) lease applications at this time would not preclude an 

application to lease that respective tract in the future. 

3.3.3.3 Regulatory Compliance, Mitigation and Monitoring

Although potentially buried paleontological resources may exist within the 

general analysis areas for each of the WAC LBA tracts, long term monitoring is 

neither a safe nor practical mitigation measure due to the size and complexity 

of surface mining operations. 

If the North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs 

Ranch, North Porcupine, and South Porcupine LBA Tracts are leased, BLM will 

attach a stipulation to each 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). No such incidents have occurred on the 

applicants’ existing leases. 

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 Appendix F (Supplemental Air Quality 

Information) is based on the air quality information provided by the Black 

Thunder, Jacobs Ranch, and North Antelope Rochelle mines and from various 

state and federal sources. This section summarizes the affected environment 

in the general Wright analysis area and the potential air quality impacts if the 

North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, 

North Porcupine, and South Porcupine LBA Tracts are leased and mined. 

Appendix F provides background information on the air quality regulatory 

framework, regional conditions, dispersion model methodology, the best 

available control technology (BACT) process, etc. Existing and projected 

cumulative air quality impacts are discussed in Section 4.2.3. 
3.0 Affected Environment and Environmental Consequences 

3-48 Final EIS, Wright Area Coal Lease Applications

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 is strongly affected by local topography. 

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. In general, local effects are 

superimposed on the general weather regime and are most important when the 

large-scale wind flow is weak. 

The general Wright analysis area, shown in Figure 3-1, is located in the eastcentral 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 4,690 feet to 5,170 feet above 

sea level. The climate in the general Wright analysis area 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 Wright analysis area. 

Air Quality regulations applicable to surface coal mining include the National 

Ambient Air Quality Standards/Wyoming Ambient Air Quality Standards 

(NAAQS/WAAQS), Prevention of Significant Deterioration (PSD), New Source 

Performance Standards (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 Clean Air Act (CAA) and the Clean Air Act Amendment of 1990 (CAAA). 

In Wyoming, air pollution impacts are managed by the Wyoming Department of 

Environmental Quality/Air Quality Division (WDEQ/AQD) under the Wyoming 

Air Quality Standards and Regulations (WAQSR) and the U.S. Environmental 

Protection Agency (EPA)-approved State Implementation Plan (SIP). 

3.4.1.1 Emission Sources

Air quality conditions in rural areas are typically 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 farms and ranches) and favorable 

atmospheric dispersion conditions which can result in relatively low air 

pollutant concentrations. For these reasons, air quality conditions in the rural 

areas of the PRB are likely to be very good. However, the potential exists for 

localized pockets of higher concentrations of fugitive dust particles and gaseous 

emissions related to oil and gas development in the basin (BLM 2005b). 

Occasional high concentrations of carbon monoxide (CO) and particulate 

matter may also occur in more urbanized areas (e.g., cities of Gillette, 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-49 

Sheridan, and Buffalo) and around industrial facilities (e.g., surface coal mines 

and coal-fired power plants), especially under stable atmospheric conditions 

that occur occasionally during winter. 

Surface coal mining activities generate fugitive dust particulates 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 for particulate matter associated with surface coal mining and 

preparation. The primary direct source of gaseous emissions from surface coal 

mining operations is tailpipe exhaust from large mining equipment and other 

vehicle traffic inside the mine permit area. Small amounts of gaseous 

pollutants are also emitted from small stationary boilers and off-road diesel 

engines. The federal and Wyoming state ambient air quality standards for the 

six criteria pollutants are shown in Table 3-8. 

Overburden and coal blasting sometimes produces gaseous, orange-colored 

clouds that contain nitrogen dioxide (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. The federal and Wyoming state ambient air standards for NO2 are 

shown in Table 3-8. 

Other existing air pollutant emission sources within the region include: 

• CO and nitrogen oxides (NOX) from internal combustion engines used at 

natural gas and CBNG pipeline compressor stations; 

• CO, NOX, particulates (PM10 and PM2.5), sulfur dioxide (SO2), and volatile 

organic compounds (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; 

• 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 40-60 miles south-southwest of 

these six LBA tracts, and the Wyodak, Wygen, and Neil Simpson plants, 

located about 35-55 miles north of these six LBA tracts; 

• Air pollutants transported from emission sources located outside the 

PRB; and 

• Ground level ozone (O3) is not emitted directly into the air, but is created 

by chemical reactions between NOX and VOCs in the presence of 

sunlight. 
3.0 Affected Environment and Environmental Consequences 

 3-50 Final EIS, Wright Area Co

Table 3-8. Assumed Background Air Pollutant Concentrations, Applicable AAQS, and PSD In

μg/m3). 

Criteria Pollutant 

Averaging 

Time1

Background 

Concentration 

Primary 

NAAQS2

Secondary 

NAAQS2 WAAQS 

PSD Clas

Incremen

Carbon monoxide 

1-hour 8-hour 

3,3364 

1,381 

40,000 10,000 

40,000 10,000 

40,000 10,000 

--- --- 

Nitrogen dioxide 

1-hour5

Annual 

--- 

256 

188.1 100 

--- 

100 

--- 

100 

--- 

2.5 

Ozone 8-hour 1336 147 147 157 --- 

Sulfur dioxide 

3-hour 

24-hour 

Annual 

1577

687

97

--- 

365 

80 

1,300 

--- --- 

1,300 

260 

60 

25 

5 2 

PM10 8 24-hour 

Annual 

1039

269

150 

--- 

150 

--- 

150 

50 

8 4 

PM2.5 8 24-hour 

Annual 

18.910

6.410

35 15 

35 15 

65 15 

--- --- 

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 welfare. 3 All NEPA analysis comparisons to the PSD increments are intended to evaluate a threshold of concern and do not re

Increment Consumption Analysis. 4 Data collected by Amoco at Ryckman Creek for an eight-month period during 1978-1979, summarized in Riley Ridge EIS 

5 EPA set a new 1-hour NO2 standard at 0.100 ppm (188.1 μg/m3) effective January 22, 2010. To attain this standard, the 

percentile of the daily maximum 1-hour average at each monitor within an area must not exceed 0.100 ppm. 6 Data collected at WDEQ/AQD site located 15 miles SSW of Gillette, Wyoming. (Annual = average of mean annual valu

average of four highest 8-hr values in 2005-2008). 7 Data collected at Wyodak Site 4, Campbell County, Wyoming. (Annual = average of mean annual values in 2005-2008. 2

two highest 24-hr and 3-hr values in 2005-2008.) 8 On October 17, 2006, EPA published final revisions to the NAAQS for particulate matter that took effect on Decembe

strengthens the 24-hour PM2.5 standard from 65 to 35 μg/m3 and revokes the annual PM10 standard of 50 μg/m3. The S

into rulemaking to revise the WAAQS. 9 Data collected at the Jacobs Ranch Mine, Site 5, Campbell County, Wyoming. (Annual = average of mean annual value

average of four highest 24-hr values in 2005-2008.) 

10 Data collected at the Black Thunder Mine, Site BTM-26-2, Campbell County, Wyoming. (Annual = average of mean ann

24-hr = average of 98th percentile values in 2005-2008.) 

Source: BLM 2005b, EPA 2009a, and WDEQ/AQD 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-51 

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 (TSP) 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 

(particulate matter with a mean aerodynamic diameter of 2.5 microns or less, 

or 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 micrograms per cubic meter 

(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 3-8. 

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. As a result, the eastern PRB is one of the most intensely 

monitored areas in the world. According to EPA AirData, in 2007 there were 

six TSP monitors, five PM2.5 monitors and 36 PM10 monitors in the Wyoming 

portion of the PRB. TSP and PM10 data have been collected since 1980 and 

1989, respectively. Through 2004 approximately 57,000 TSP samples had 

been collected, and approximately 48,950 PM10 samples had been collected 

through 2008. Information about the regulatory framework, the monitoring 

network, and PM10 concentration trends since monitoring began are included 

in Appendix F. Existing site specific air quality information is included in the 

Supplementary Information Document. 

Historical particulate matter ambient air quality data for the general Wright 

analysis area air quality monitoring sites generally show the same results as 

described above for the PRB as a whole. The locations of PM10, PM2.5, and TSP 

(if monitored) particulate emission monitoring samplers at the applicant mines 

(Black Thunder, Jacobs Ranch, and North Antelope Rochelle) are shown on 

Figures 3-3 through 3-5, respectively. The progression of mining operations 

requires that the location and number of particulate monitors be adjusted in 
31

30

19

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T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

44

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T.

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N.

T.

43

N.

T.

42

N.

R. 70 W. R. 69 W.

R. 70 W. R. 69 W.

Road Jacobs

Antelope

Edwards

Matheson Road

Reno Road

School Creek

Hilight Road

Hilight

Road

Keeline Road

State

450 Highway

Road

Road

Road

BNSF & UP RR

State Highway 450

Shroyer

Road

Small Road

Black Thunder Mine

Plant Facilities Area

Official BT Meteorological Station

BTM-31

(discontinued

October 2006)

BTM-26

(relocated to BTM-25

February 2008)

BTM-36 Tracy Ranch

Site

BTM-9

(new February 2008)

BTM-25

30 6 10 16 21

m.p.h.

KEY

Windrose

>24 Period: 2000-2004

Black Thunder Mine Permit Boundary

LEGEND

0 6000 12000 24000

GRAPHIC SCALE (FEET)

TSP and/or PM10 Air Quality Sampling Locations

Meteorological Station

N

E

S

W

North Hilight Field LBA Tract as Applied for

North Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA Tract as Applied for

South Hilight Field LBA Tract as Applied for

South Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA Tract Under Alternative 3

West Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Tracy Ranch NO2 Monitoring Site

Figure 3-3. Wind Rose, Air Quality and Meteorological Stations at the Black Thunder Mine.

3.0 Affected Environment and Environmental Consequences

3-52 Final EIS, Wright Area Coal Lease Applications
31

30

19

18

7

6

31

30

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18

7

6

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29

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8

5

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28

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4

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22

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10

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11

2

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25

24

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1

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30

19

18

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6

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17

8

5

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28

21

16

9

4

34

27

22

15

10

3

35

26

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14

11

2

36

25

24

13

12

1

30

19

18

7

6

29

20

17

8

5

28

21

16

9

4

27

22

15

10

3

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

29

20

17

8

5

28

21

16

9

4

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10

3

26

23

14

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2

25

24

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12

1

30

19

18

7

6

T.

44

N.

T.

43

N.

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

Road Jacobs

Small BNSF & UP RR

Hilight Road Hilight Road

Keeline Road

Road

Road

State

450 Highway

BNSF & UP RR

State Highway 450

R. 71 W. R. 70 W.

Shroyer

Site 5 (to July 2003)

Site 5 (July 2003 to Present)

Meteorological Station

(August 2005 to Present)

Meteorological Station

(to August 2005)

Site 4

Site 3

Jacobs Ranch Mine

Plant Facilities Area

Jacobs Ranch Mine Permit Boundary

West Jacobs Ranch LBA Tract as Applied for

West Jacobs Ranch LBA Tract Under Alternative 2,

BLM's Preferred Alternative

LEGEND

10000 20000

4.00 7.4 12.1 19.0 25.8

m.p.h.

KEY

Windrose

Period: 1998-2007

N

E

S

W 0%

>25.8

TSP and/or PM10 Air Quality Sampling Locations

Meteorological Station

(temperature, wind, and precipitation)

0 5000

GRAPHIC SCALE (FEET)

Figure 3-4. Wind Rose, Air Quality and Meteorological Stations at the Jacobs Ranch Mine.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-53
36

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25

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13

12

1

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

Converse County

Campbell County

R. 70 W. R. 69 W.

T.

42

N.

T.

41

N.

Mackey

Antelope

Road

Road

PRCC-1

RO-1

NA-5

(May 2008 to present)

North Antelope Rochelle Mine

Plant Facilities Area

33

28

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16

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27

22

15

35

26

23

14

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24

13

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18

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29

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17

33

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21

16

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27

22

15

35

26

23

14

T.

42

N.

T.

41

N.

R. 71 W. R. 70 W.

Reno Road

Antelope

BNSF & UP RR

Road

Matheson Road

Mackey Road

NA-7

(new in 2008)

NA-6 or NA/RC

(mid-2000 to mid-2008)

NA-6

(through mid-2000)

NA-5

(through May 2008)

LEGEND

0 5000 10000 20000

GRAPHIC SCALE (FEET)

North Antelope Rochelle Mine Permit Boundary

North Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

North Porcupine LBA Tract as Applied for

South Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

South Porcupine LBA Tract as Applied for

TSP and/or PM10 Air Quality Sampling Locations

Meteorological Station

30 6 10 16 21

m.p.h.

KEY

Windrose

>24 Period: 2000-2004

N

E

S

W

Figure 3-5. Wind Rose, Air Quality and Meteorological Stations at the North Antelope Rochelle Mine.

3.0 Affected Environment and Environmental Consequences

3-54 Final EIS, Wright Area Coal Lease Applications
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-55 

order to provide the best documentation of the ambient air quality. Figure 3-6 

presents the average annual particulate emissions, as PM10, measured by the 

three applicant Wright area coal (WAC) mines’ particulate monitoring samplers 

from 1998 through 2008. Annual coal and overburden production for the 

three WAC mines for these same years are also shown on Figure 3-6. 

There were no monitored exceedances of the PM10 standard in the PRB through 

2000. No exceedances of the annual PM10 particulate standards were 

documented by the three applicant mines through 2007. From 2001 through 

2006 there were a total of nine exceedances of the 24-hour PM10 particulate 

standard associated with the Black Thunder, Jacobs Ranch, and North 

Antelope Rochelle mines. Prior to 2007, there was no mechanism in place to 

account for exceedances demonstrated to be the result of natural events. The 

WDEQ/AQD collaborated with the Wyoming Mining Association (WMA) to 

develop a Natural Events Action Plan (NEAP) for the coal mines of the PRB, 

based on EPA Natural Event Policy guidance. Under certain conditions, 

excessive PM10 concentrations resulting from dust raised by exceptionally high 

winds or other natural events will be treated as uncontrollable natural events. 

The NEAP is discussed in more detail in Appendix F. All of the nine 

exceedances that occurred at the Black Thunder, Jacobs Ranch, and North 

Antelope Rochelle mines between 2001 and 2006 were associated with elevated 

wind speeds exceeding 20 miles per hour (mph), which could have qualified as 

a high wind event under the NEAP. 

In 2007, a total of three 24-hour PM10 exceedances were reported at the three 

WAC mines (two at North Antelope Rochelle, one at Black Thunder, and none 

at Jacobs Ranch). These three exceedances reported in 2007 have been flagged 

by EPA as exceptional events under the NEAP and will not be considered when 

determining the region’s air quality designation. 

One 24-hour PM10 particulate standard exceedance was reported by the Black 

Thunder Mine and no 24-hour PM10 exceedances were reported by the Jacobs 

Ranch and North Antelope Rochelle mines in 2008 (Shamley 2010). The single 

exceedance reported in 2008 at the Black Thunder mine was determined to be 

a valid exceedance (not considered to be an exceptional event under the NEAP) 

and a notice of violation was subsequently issued to the mine (Shamley 2010). 

No exceedances of the 24-hour PM10 particulate standard were reported by the 

three WAC mines, or any of the other surface coal mines in the PRB in 2009 

(Shamley 2010). 

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 (2.5 micrometers in diameter and 

smaller), 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 impairment in many parts of 
Coal Production (million tons) and

Overburden Removal (million cubic yards)

WAC Applicant MinesAverage Annual

PM10 Concentration

Production Year

ANNUAL AVERAGE PM10 vs. PRODUCTION

Coal ProductionOverburden Removal

1999 2000 1998 2004 2003 2002 2001 2005

Annual Average

PM10 Concentration (μg/m3)

0

720600480360240120

302520151050

2006 2007

840 35

2008

Figure 3-6. Annual Coal Production and Overburden Removal vs. Ambient Particulates for the General

Wright Analysis Area (1998 through 2008).

3.0 Affected Environment and Environmental Consequences

3-56 Final EIS, Wright Area Coal Lease Applications
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-57 

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 2 and 3

Potential particulate emissions related to mining operations at the existing 

Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines are 

described below. As part of the applicant mines’ mining permit applications, 

air quality impact analyses were prepared using air quality dispersion modeling 

to predict the effects of the existing mine operations on nearby air quality. 

Modeling for the three existing mine sites is discussed below and in Appendix 

F. Due to the similarities in mining rates and mining operations, the potential 

impacts of mining the LBA tracts have been inferred from the projected impacts 

of mining the existing coal leases as currently permitted. 

To model potential ambient impacts in the area surrounding the mine 

operations, receptor locations were placed at approximately 500-meter intervals 

along the Lands Necessary to Conduct Mining (LNCM) boundary, which is also 

referred to as the ambient air quality boundary, for each mine. As discussed in 

Appendix F, a PM10 concentration of 14.91 μg/m3 was added to the Black 

Thunder Mine and the Jacobs Ranch Mine modeled emissions to account for 

background fugitive dust. The North Antelope Rochelle Mine used a 13.50 

μg/m3 concentration value for PM10 modeling. Predicted PM10 emissions from 

the other regional mining operations were inventoried using those mines’ most 

recent WDEQ/AQD air quality permit applications. Impacts on ambient air 

from the Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines 

and other regional mines vary by year due to annual changes in emission 

strength, emission density, pit proximity to defined ambient air boundaries, 

and pit configuration. Emissions for each year are ranked and candidate 

worst-case years are further evaluated regarding proximity to neighboring 

mining operations and emissions. The total PM10 concentration at each 

receptor was determined by summing the concentration due to each active 

mine in the general area and adding the appropriate background 

concentration. The resulting particulate levels were then compared to the 

average annual PM10 standard of 50 μg/m3 to determine compliance with the 

annual WAAQS. This constitutes a demonstration of compliance with the 

“long-term” or annual WAAQS. 

As discussed in Appendix F, surface coal mines in the Wyoming PRB have not 

been subject to PSD requirements. 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. 

The Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines’ point 

source emissions inventories include all coal preparation and processing 

facilities (i.e., crushers, material transfer points, silos, and loadouts). All point 
3.0 Affected Environment and Environmental Consequences 

3-58 Final EIS, Wright Area Coal Lease Applications 

source parameters for the regional mining operations, which were obtained 

from WDEQ/AQD files, were also considered in the modeling analysis. As 

discussed in Appendix F, a proposed new point source that has the potential to 

emit more than 250 tons per year (tpy) of any criteria pollutant (the primary 

pollutant being particulate matter) must undergo a regulatory PSD increment 

consumption analysis as well as a BACT review. 

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 

the EPA and the state of Wyoming. That agreement recognizes that appropriate 

models do not exist to accurately predict 24-hour impacts. Twenty-four-hour 

impacts have been estimated from recent monitoring and emission control 

activities. From 2001 through 2006, there were a total of nine exceedances of 

the 24-hour PM10 particulate standards associated with the three applicant 

mines. These nine exceedances were all associated with elevated wind speeds 

exceeding 20 mph, which could have qualified as exceptional events under the 

NEAP. In 2007, a total of 11 exceedances of the 24-hour PM10 particulate 

standards were reported by six mines in the PRB; three of which were reported 

by the WAC mines (two at North Antelope Rochelle, one at Black Thunder, and 

none at Jacobs Ranch). These three exceedances reported in 2007 have been 

flagged by EPA as exceptional events under the NEAP. One exceedance of the 

24-hour PM10 particulate standard was reported by the Black Thunder Mine 

and no 24-hour PM10 exceedances were reported by the Jacobs Ranch and 

North Antelope Rochelle mines in 2008 (Shamley 2010). The single exceedance 

reported in 2008 at the Black Thunder mine was determined to be a valid 

exceedance (not considered to be an exceptional event under the NEAP) and a 

notice of violation was subsequently issued to the mine (Shamley 2010). No 

exceedances of the 24-hour PM10 particulate standard were reported by the 

three WAC mines, or any of the other surface coal mines in the PRB in 2009 

(Shamley 2010). 

The estimated average overburden thickness is generally greater in each of the 

LBA tracts than within the current leases, but the thickness of the coal in the 

LBA tracts is about the same as in the existing mine areas (see Table 3-7). The 

acquisition and mining of the LBA tracts by the applicant mines could result in 

an increase in fugitive emissions per ton of coal mined above current levels due 

to the increased volume of overburden that would have to be removed to 

recover the coal. The increase in fugitive dust emissions could potentially be 

moderated somewhat if removal of the larger volume of overburden material 

results in a slower rate of mining advancement through the LBA tracts. This 

would potentially decrease the number of acres disturbed annually and cause 

haul distances to increase more slowly. 

Current mining and emission mitigation methods to recover the coal in the LBA 

tracts would be expected to continue for a longer period of time than is shown 

in the mines’ currently approved air quality permits. The mines would 

continue to utilize direct cast blasting, draglines, and/or truck and shovel 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-59 

fleets to remove and replace overburden and truck and shovel fleets and 

overland conveyors to remove and transport coal. Truck haul distances to 

transport the coal to the processing and rail loadout facilities are not expected 

to increase, because overland conveyors are likely to be extended onto the 

tracts. The facilities shown in the current air quality permits would not change 

as a result of proposed mining of the LBA tracts. There are no plans to change 

blasting procedures or blast sizes associated with the mining of the LBA tracts. 

In addition, current BACT measures for particulates would continue to be 

employed. If the Black Thunder, Jacobs Ranch, and North Antelope Rochelle 

mines acquire the LBA tracts, they will have to amend their current air quality 

permits to include the new leases before mining activities can proceed into the 

new lease areas. New air quality modeling would need to be conducted in 

support of that permit application demonstrating on-going compliance with all 

applicable ambient standards. 

3.4.2.2.1.1 North, South, and West Hilight Field LBA Tracts

The North, South, and West Hilight Field LBA Tracts would be mined as 

integral parts of the Black Thunder Mine under the Proposed Actions and 

Alternatives 2 and 3. 

TBCC projects that the mine’s annual coal production rate will be 135 million 

tons by 2015, with or without the North, South, or West Hilight Field LBA 

Tracts. Black Thunder Mine’s currently approved air quality permit from the 

WDEQ/AQD limits annual coal production to 135 million tons of coal. 

According to TBCC, if they acquire the additional coal in the LBA tracts, 

production would continue at an average rate of 135 million tons per year 

(mmtpy) for approximately 6.4 more years under the Proposed Action, or for 

about 14.2 additional years under Alternative 2, BLM’s preferred configuration 

for all three tracts. As discussed in Section 3.0, the estimates of recoverable 

coal, associated disturbance, and mine life shown in Tables 3-1 through 3-3 

assume that Shroyer, Reno and Hilight Roads and State Highway 450 are not 

moved. As indicated in Tables 2-3, 2-5, and 2-7, approximately 132.1 million 

additional tons of coal could be recovered if these public roads are moved, 

which would extend operations at the mine for a total of about one additional 

year under Alternative 2 for all three tracts. 

WDEQ/AQD issued air quality permit MD-417A for the Black Thunder Mine on 

July 1, 1999. This air quality permit was issued based on an analysis using 

emission factors, estimation methods, and model selection consistent with 

WDEQ/AQD policy. WDEQ/AQD issued air quality permit MD-6824 on 

January 22, 2008, which reclassified the Black Thunder Mine as below the 

minor source threshold (BTM 2008a). Air quality permit MD-3851 was issued 

on August 18, 2008, combining the Black Thunder Mine and North Rochelle 

Mine air quality permits and increasing the permitted production from 100 to 

135 mmtpy (BTM 2008b). Material movement currently utilizes direct cast 

blasting, draglines, and/or truck and shovel fleets for overburden and truck 

and shovel fleets and overland conveyors for coal removal and transport. 
3.0 Affected Environment and Environmental Consequences 

3-60 Final EIS, Wright Area Coal Lease Applications 

Particulate emission inventories for the mining activities at Black Thunder 

Mine were prepared for all years in the currently anticipated life of the mine. 

Two years were then selected for worst-case dispersion modeling of PM10 based 

on mine plan parameters and emission inventories. Fugitive emission sources 

and point sources were modeled using the ISCLT3 Model to estimate average 

annual PM10 concentrations. 

Long-term modeling for air quality permit MD-3851 indicates the currently 

projected mine activities will be in compliance with the annual PM10 ambient 

air standard for the life of the Black Thunder Mine. Based on mine plan 

parameters and highest emissions inventories, the years 2015 and 2017 were 

selected as the worst-case years. The dispersion model showed a maximum 

concentration on the Black Thunder Mine LNCM boundary of 41.9 μg/m3 in 

2015 and 49.96 μg/m3 (very close to the standard) in 2017. Coal production in 

both years was modeled at the maximum permitted annual production level of 

135 million tons (BTM 2008b). The locations of the maximum-modeled PM10

concentrations for 2015 and 2017 are shown on Figures 3-7 and 3-8, 

respectively. 

An initial inventory of all point sources, controls, and emissions for the Black 

Thunder Mine air quality permit showed a maximum potential to emit 110.4 

tpy. A reevaluation of point sources emissions (air quality permit MD-6824) 

estimated the maximum potential to emit 32.2 tpy. Therefore, a PSD 

increment consumption analysis was not necessary, and because this value is 

now below the 100 tpy major source threshold limit specified in Chapter 6, 

Section 3 of the WAQSR, Black Thunder Mine will not be subject to the Title V 

Operating Permit program (BTM 2008a). 

Modeling conducted for air quality permit MD-3851 to revise air quality permit 

MD-6824 predicted no exceedances of the annual PM10 NAAQS at a 135-mmtpy 

production rate. There were six exceedances of the 24-hour PM10 particulate 

standards at the Black Thunder Mine from 2001 through 2006. All six 

exceedances were associated with elevated wind speeds exceeding 20 mph, 

which could have qualified as a high wind event under the NEAP. There was 

one exceedance reported in 2007, which was designated by EPA as an 

exceptional event (due to a high wind event) under the NEAP. There was one 

exceedance of the 24-hour PM10 particulate standards at the Black Thunder 

Mine in 2008, and EPA determined that it was not an exceptional event under 

the NEAP and a notice of violation was subsequently issued to the mine 

(Shamley 2010). There were no exceedances of the 24-hour PM10 particulate 

standards reported by the mine in 2009. There have been no exceedances of 

the annual PM10 NAAQS. TBCC estimates that the Black Thunder Mine would 

produce at an average annual rate of 135 mmtpy if it acquires and mines the 

North, South, and/or West Hilight Field LBA Tracts, but fugitive dust 

emissions are projected to remain within daily and annual AAQS limits. 

Public exposure to particulate emissions from surface mining operations is 

most likely to occur along publicly accessible roads and highways that pass
31

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13

12

1

18

7

6

17

8

5

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4

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3

14

11

2

13

12

1

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

Reno Road

Road Jacobs

State

Antelope

Edwards

Matheson Road

Reno Road

Hilight Road Hilight Road

Keeline Road

Highway 450

State

450 Highway

Road

Road

BNSF & UP RR

Shroyer

Road

Small Road

PM10=41.9 μg/m3

NOx=46.3 μg/m3

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Receptor Location

Area Source

Ambient Air Boundary

Haul Roads

Black Thunder Mine Permit Boundary

Existing Black Thunder

Mine Federal Coal Leases

LEGEND

North Hilight Field LBA Tract as Applied for

North Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA Tract as Applied for

South Hilight Field LBA Tract as Applied for

South Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA Tract Under Alternative 3

West Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-7. Maximum Modeled PM10 and NOX

 Concentrations at the Black Thunder Mine Ambient Air

Boundary for the Year 2015.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-61
31

30

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29

20

17

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1

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

Reno Road

Road Jacobs

State

Antelope

Edwards

Matheson Road

Reno Road

Hilight Road Hilight Road

Keeline Road

Highway 450

State

450 Highway

Road

Road

BNSF & UP RR

Shroyer

Road

Small Road

PM10=49.96 μg/m3

NOx=52.5 μg/m3

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Receptor Location

Area Source

Ambient Air Boundary

Haul Roads

Black Thunder Mine Permit Boundary

Existing Black Thunder

Mine Federal Coal Leases

LEGEND

North Hilight Field LBA Tract as Applied for

North Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA Tract as Applied for

South Hilight Field LBA Tract as Applied for

South Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA Tract Under Alternative 3

West Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-8. Maximum Modeled PM10 and NOX

 Concentrations at the Black Thunder Mine Ambient Air

Boundary for the Year 2017.

3.0 Affected Environment and Environmental Consequences

3-62 Final EIS, Wright Area Coal Lease Applications
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-63 

near and through the areas of mining operations. Occupants of dwellings in 

the area could also be affected. Roads, highways, currently occupied dwellings, 

businesses, and school bus stops in the vicinity of the North, South, and West 

Hilight Field LBA Tracts are shown in Figures 3-9 through 3-11, respectively. 

3.4.2.2.1.2 West Jacobs Ranch LBA Tract

The West Jacobs Ranch LBA Tract would be mined as an integral part of the 

Jacobs Ranch Mine under the Proposed Action and Alternative 2. 

TBCC projects that the mine’s annual coal production is expected to average 40 

million tons, with or without the West Jacobs Ranch LBA Tract. Jacobs Ranch 

Mine’s currently approved air quality permit from the WDEQ/AQD limits 

annual coal production to 55 million tons of coal. According to TBCC, if they 

acquire the additional coal in the LBA tract as applied for, production would 

continue at the present average rate of 40 mmtpy for approximately 16.7 

additional years under the Proposed Action, or for about 22.8 more years under 

Alternative 2, BLM’s preferred configuration for the tract. As discussed in 

Section 3.0, the estimates of recoverable coal, associated disturbance, and 

mine life shown in Table 3-4 assume that Hilight Road and State Highway 450 

are not moved. As indicated in Table 2-9, approximately 229.5 million 

additional tons of coal could be recovered if these public roads are moved, 

which would extend operations at the mine for a total of about 5.8 additional 

years under Alternative 2. 

WDEQ/AQD issued air quality permit MD-1005 for the Jacobs Ranch Mine on 

August 6, 2004. This air quality permit was issued based on an analysis using 

emission factors, estimation methods, and model selection consistent with 

WDEQ/AQD policy. WDEQ/AQD issued air quality permit MD-1005A on 

December 1, 2004 to modify operations at the Jacobs Ranch Mine to add a 

dragline for overburden removal. WDEQ/AQD issued air quality permit MD1005A2 on January 22, 2007 to revise the LNCM boundary. Material 

movement currently utilizes direct cast blasting, draglines, and/or truck and 

shovel fleets for overburden and truck and shovel fleets and overland conveyors 

for coal (JRM 2007). 

Particulate emission inventories for the mining activities at Jacobs Ranch Mine 

were prepared for all years in the currently anticipated life of the mine. Two 

years were then selected for worst-case dispersion modeling of PM10 based on 

mine plan parameters and emission inventories. Fugitive emission sources 

and point sources were modeled using the ISCLT3 Model to estimate average 

annual PM10 concentrations. 

Long-term modeling indicates the currently projected mine activities will be in 

compliance with the annual PM10 ambient air standard for the life of the Jacobs 

Ranch Mine. Based on mine plan parameters and highest emissions 

inventories, the years 2013 and 2015 were selected as the worst-case years. 

The dispersion model showed a maximum concentration on the Jacobs Ranch
Breen

Keeline

Road Jacobs

State

BNSF & UP RR

Hilight Road

Hilight Road

Road Lawver Road

Road

Highway 450

Small

Road

31

30

19

18

7

6

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

20

17

8

5

21

16

9

4

22

15

10

3

23

14

11

2

24

13

12

1

19

18

7

6

20

17

8

5

21

16

9

4

22

15

10

3

23

14

11

2

24

13

12

1

19

18

7

6

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

32

29

20

33

28

21

34

27

22

35

26

23

36

25

24

31

30

19

32

29

20

33

28

21

34

27

22

35

26

23

36

25

24

31

30

19

R. 70 W. R. 69 W.

R. 70 W. R. 69 W.

T.

45

N.

T.

44

N.

T.

45

N.

T.

44

N.

JACOBS RANCH

MINE OFFICE

BLACK THUNDER MINE OFFICE

B

B

B

Shroyer

Road

Black Thunder Mine Permit Boundary

Existing Black Thunder

Mine Federal Coal Leases

LEGEND

Single Occupied Residence

B School Bus Stop

Multiple Occupied Residences

Exist Within this Area

(Boundaries are Approximate)

North Hilight Field LBA Tract as Applied for

0 5000 10000 20000

GRAPHIC SCALE (FEET)

North Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-9. Residences, School Bus Stops, Public Roads, and Other Publicly Accessible Facilities in the

Vicinity of the North Hilight Field LBA Tract Under Alternative 2.

3.0 Affected Environment and Environmental Consequences

3-64 Final EIS, Wright Area Coal Lease Applications
Reno Road

State

Antelope

Edwards

Matheson Road

Reno Road

Hilight Road

Highway 450

Road

Road

BNSF & UP RR

Small Road

Mackey Road

31

30

32

29

33

28

34

27

35

26 25

31

30

32

29

33

28

34

27

35

26

36

25

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

25

24

13

12

36

25

36

25

24

13

12

1

25

24

13

12

1

30

19

18

7

6

29

20

17

8

5

28

21

16

9

4

27

22

15

10

3

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

29

20

17

8

5

28

21

16

9

4

27

22

15

10

3

26

23

14

11

2

25

24

13

12

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

R. 72 W. R. 71 W.

R. 72 W. R. 71 W.

BLACK THUNDER

MINE OFFICE JACOBS RANCH

MINE OFFICE

Hilight Road

South Hilight Field LBA Tract as Applied for

Black Thunder Mine Permit Boundary

Existing Black Thunder

Mine Federal Coal Leases

LEGEND

Single Occupied Residence

0 5000 10000 20000

GRAPHIC SCALE (FEET)

South Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

No school bus stops exist in the vicinity of the BLM

study area for the South Hilight Field LBA Tract.

Figure 3-10. Residences, School Bus Stops, Public Roads, and Other Publicly Accessible Facilities in the

Vicinity of the South Hilight Field LBA Tract Under Alternative 2.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-65
Cosner County

Road Jacobs

State

Antelope

Edwards

State Highway 387

Matheson Road

Reno Road

State 59 Highway

State

 59 Highway

Hilight Road Hilight Road

Highway 450

Road

Road

BNSF & UP RR

Small Road

31

30

19

18

32

29

20

17

33

28

21

16

31

30

19

18

32

29

20

17

33

28

21

16

34

27

22

15

35

26

23

14

36

25

24

13

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

33

28

21

16

34

22

15

35

26

23

14

36

25

24

13

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

16

9

4

15

10

3

14

11

2

13

12

1

18

7

6

17

8

5

16

9

4

15

10

3

14

11

2

13

12

1

18

7

6

17

8

5

16

9

4

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

R. 72 W. R. 71 W.

R. 72 W. R. 71 W.

BLACK THUNDER

MINE OFFICE

BUSINESS

BUSINESS

Road

Shroyer

Road

B

B

B

Wright, Wyoming

Town Site

Black Thunder Mine Permit Boundary

Existing Black Thunder

Mine Federal Coal Leases

LEGEND

Single Occupied Residence

B School Bus Stop

Multiple Occupied Residences

Exist Within this Area

(Boundaries are Approximate)

West Hilight Field LBA Tract as Applied for

0 5000 10000 20000

GRAPHIC SCALE (FEET)

West Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA Tract Under Alternative 3

Figure 3-11. Residences, School Bus Stops, Public Roads, and Other Publicly Accessible Facilities in the

Vicinity of the West Hilight Field LBA Tract Under Alternative 2.

3.0 Affected Environment and Environmental Consequences

3-66 Final EIS, Wright Area Coal Lease Applications
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-67 

Mine LNCM boundary of 44.70 μg/m3 in 2013 and 49.61 μg/m3 in 2015. Coal 

production in both years was modeled at the maximum permitted production 

level of 55 million tons (JRM 2007). The locations of the maximum-modeled 

PM10 concentrations for 2013 and 2015 are shown on Figure 3-12. 

An inventory of all point sources, controls, and emissions for air quality permit 

MD-1005A2 showed a potential to emit of 21.9 tpy; therefore, a PSD increment 

consumption analysis was not necessary, and because this value is below the 

100 tpy major source threshold limit specified in Chapter 6, Section 3 of the 

WAQSR, Jacobs Ranch Mine will not be subject to the Title V Operating Permit 

program (JRM 2007). 

Modeling conducted for the current Jacobs Ranch Mine air quality permit 

predicted no exceedances of the annual PM10 NAAQS at a 55-mmtpy 

production rate. There has been one exceedance of the 24-hour PM10 NAAQS 

since PM10 monitoring began at the mine and no exceedances of the annual 

PM10 NAAQS. TBCC estimates that the Jacobs Ranch Mine would continue to 

produce at an average annual rate of 40 mmtpy if it acquires and mines the 

West Jacobs Ranch LBA Tract, but fugitive dust emissions are projected to 

remain within daily and annual AAQS limits. 

Public exposure to particulate emissions from surface mining operations is 

most likely to occur along publicly accessible roads and highways that pass 

near and through the areas of mining operations. Occupants of dwellings in 

the area could also be affected. Roads, highways, currently occupied dwellings, 

businesses, and school bus stops in the vicinity of the West Jacobs Ranch LBA 

Tract are shown in Figure 3-13. 

3.4.2.2.1.3 North and South Porcupine LBA Tracts

The North and South Porcupine LBA Tracts would be mined as integral parts of 

the North Antelope Rochelle Mine under the Proposed Action and Alternative 2. 

PRC projects that the annual coal production is expected to average 95 million 

tons, with or without the North or South Porcupine LBA Tracts. North 

Antelope Rochelle Mine’s currently approved air quality permits from the 

WDEQ/AQD limit annual coal production to 140 million tons of coal. 

According to PRC, if they acquire the additional coal in the LBA tracts, 

production would continue at an average rate of 95 mmtpy for approximately 

9.9 more years under the Proposed Action, or for about 11.4 additional years 

under Alternative 2, BLM’s preferred configuration for both tracts. As 

discussed in Section 3.0, the estimates of recoverable coal, associated 

disturbance, and mine life shown in Tables 3-5 and 3-6 assume that Mackey 

Road and the remaining 2.25-mile section of Antelope Road are not moved. As 

indicated in Tables 2-11 and 2-13, approximately 98.1 million additional tons 

of coal could be recovered if these public roads are moved, which would extend 

operations at the mine for a total of about one additional year under Alternative 

2 for both tracts. 
30

32

29

33

28

34

27

35

26

36 31 32

29

33

28

34

27

35

26

36 31

31

30

19

18

7

6

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

T.

45

N.

T.

44

N.

T.

44

N.

T.

43

N.

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

T.

45

N.

T.

44

N.

T.

44

N.

T.

43

N.

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

Keeline

Road Jacobs

BNSF & UP RR

Hilight Road Hilight Road

Road

Keeline Road

Road

State

450 Highway

BNSF & UP RR

State Highway 450

Shroyer

Small Road

PM10=44.70 μg/m3 (2013)

PM10=49.61 μg/m3 (2015)

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Receptor Location

Area Source (2013)

Ambient Air Boundary

Haul Roads

LEGEND

Existing Jacobs Ranch Mine

Federal Coal Leases

Jacobs Ranch Mine Permit Boundary

West Jacobs Ranch LBA Tract as Applied for

West Jacobs Ranch LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Area Source (2015)

Figure 3-12. Maximum Modeled PM10 Concentrations at the Jacobs Ranch Mine Ambient Air Boundary for

the Years 2013 and 2015.

3.0 Affected Environment and Environmental Consequences

3-68 Final EIS, Wright Area Coal Lease Applications
33 34 35 32 33 34 35 R. 71 W. R. 70 W. 32 33 59 Hilight

R. 72 W. R. 71 W.

33

28

34

27

35

26

36 31 32

29

33

28

34

27

35

26

36 31 32

29 28

31

30

19

18

7

6

32

29

20

17

8

5

28

21

16

9

19

18

7

6

20

17

8

5

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

30

19

29

20

28

21

27

22

15

10

3

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

29

20

17

8

5

28

21

9

21

16

9

4

22

15

10

3

23

14

11

2

24

13

12

1

28

21

27

22

26

23

25

24

T.

45

N.

T.

44

N.

R. 71 W. R. 70 W.

Cosner County Road

Keeline

Road Jacobs

Small BNSF & UP RR

State

 59 Highway State Highway

Hilight Road Road

Road

Road

Road BNSF & UP RR

Shroyer

R. 72 W. R. 71 W.

T.

44

N.

T.

43

N.

T.

44

N.

T.

43

N.

T.

45

N.

T.

44

N.

BLACK THUNDER MINE OFFICE

State

450 Highway

BUSINESS

B

Wright, Wyoming

Town Site

31

30

32

29

33

28

18

7

6

17

8

5

16

9

4

33

28

34

27

35 36

25

16

9

4

15

10

3

14

11

2

13

12

1

State

State Highway 450

387 Highway

BUSINESS

BUSINESS

26

B

B

LEGEND

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Single Occupied Residence

B School Bus Stop

Multiple Occupied Residences,

Businesses, and Roads Exist Within this

Area (Boundaries are Approximate)

Existing Jacobs Ranch Mine

Federal Coal Leases

Jacobs Ranch Mine Permit Boundary

West Jacobs Ranch LBA Tract as Applied for

West Jacobs Ranch LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-13. Residences, School Bus Stops, Public Roads, and Other Publicly Accessible Facilities in the

Vicinity of the West Jacobs Ranch LBA Tract Under Alternative 2.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-69
3.0 Affected Environment and Environmental Consequences 

3-70 Final EIS, Wright Area Coal Lease Applications 

WDEQ/AQD issued air quality permit MD-1309 for the North Antelope Rochelle 

Mine on January 24, 2006. This air quality permit was issued based on an 

analysis using emission factors, estimation methods, and model selection 

consistent with WDEQ/AQD policy. WDEQ/AQD issued air quality permit MD1331 on March 7, 2006 to modify operations at the North Antelope Rochelle 

Mine. Material movement utilizes direct cast blasting, draglines, and/or truck 

and shovel fleets for overburden and truck and shovel fleets and overland 

conveyors for coal. WDEQ/AQD issued air quality permit MD-6375 on 

November 10, 2008 to modify operations and increase the permitted coal 

production at the North Antelope Rochelle Mine from 99 mmtpy to 140 mmtpy 

(PRC 2008a). 

Particulate emission inventories for the mining activities at North Antelope 

Rochelle Mine were prepared for all years in the currently anticipated life of the 

mine. Two years were then selected for worst-case dispersion modeling of PM10

based on mine plan parameters and emission inventories. Fugitive emission 

sources and point sources were modeled using the ISCLT3 Model to estimate 

average annual PM10 concentrations. 

Long-term modeling for North Antelope Rochelle Mine’s air quality permit MD6375 indicates the currently projected mine activities will be in compliance 

with the annual PM10 ambient air standard for the life of the mine. Based on 

mine plan parameters and highest emissions inventories, the years 2012 and 

2017 were selected as the worst-case years. The dispersion model showed a 

maximum concentration on the North Antelope Rochelle LNCM boundary of 

33.10 μg/m3 in 2012 and 39.24 μg/m3 in 2017. Coal production in both years 

was modeled at a maximum production level of 140 million tons (PRC 2008a). 

The locations of the maximum-modeled PM10 concentrations for 2012 and 2017 

are shown on Figures 3-14 and 3-15, respectively. 

An initial inventory of all point sources, controls, and emissions for the North 

Antelope Rochelle Mine air quality permit showed a maximum potential to emit 

40.2 tpy. Therefore, a PSD increment consumption analysis was not necessary 

and because this value is below the 100 tpy major source threshold limit 

specified in Chapter 6, Section 3 of the WAQSR, North Antelope Rochelle Mine 

will not be subject to the Title V Operating Permit program (PRC 2008a). 

Modeling conducted for the current air quality permit predicted no exceedances 

of the annual PM10 NAAQS at a 140-mmtpy production rate. There were two 

exceedances of the 24-hour PM10 particulate standards at the North Antelope 

Rochelle Mine from 2001 through 2006. Both exceedances were associated 

with elevated wind speeds exceeding 20 mph, which could have qualified as a 

high wind event under the NEAP. There were two exceedances reported in 

2007, both of which have been designated by EPA as exceptional events under 

the NEAP and will not be considered when determining the region’s air quality 

designation. There were no exceedances of the 24-hour PM10 particulate 

standards reported by the North Antelope Rochelle Mine in 2008 and 2009 

(Shamley 2010). There have been no exceedances of the annual PM10 NAAQS.
33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

31

30

19

18

7

6

32

29

20

17

8

5

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

6

8

5

8 9

4

10

3

11

2 1

6

8

5

9

4

10

3

11

2 1

T.

42

N.

T.

41

N.

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

Converse County

Campbell County

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

T.

42

N.

T.

41

N.

Reno Road

Mackey

Antelope

Edwards Reno Road

School Creek

Hilight

Road

Road Road Road

Antelope Road

Road

BNSF & UP RR

Matheson Road

Mackey Road

MathesonRoad

T.

41

N.

T.

40

N.

T.

41

N.

T.

40

N.

PM10=33.1 μg/m3

EAST PIT

NORTH PIT

MIDDLE

PIT

WEST

PIT

NOx=50.6 μg/m3

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Receptor Location

Area Source

Ambient Air Boundary

Haul Roads

LEGEND

Existing North Antelope Rochelle

Mine Federal Coal Leases

North Antelope Rochelle Mine Permit Boundary

North Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

North Porcupine LBA Tract as Applied for

South Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

South Porcupine LBA Tract as Applied for

Figure 3-14. Maximum Modeled PM10 and NOX

 Concentrations at the North Antelope Rochelle Mine

Ambient Air Boundary for the Year 2012.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-71
33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

31

30

19

18

7

6

32

29

20

17

8

5

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

6

8

5

8 9

4

10

3

11

2 1

6

8

5

9

4

10

3

11

2 1

T.

42

N.

T.

41

N.

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

Converse County

Campbell County

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

T.

42

N.

T.

41

N.

Reno Road

Mackey

Antelope

Edwards Reno Road

School Creek

Hilight

Road

Road Road Road

Antelope Road

Road

BNSF & UP RR

Matheson Road

Mackey Road

MathesonRoad

T.

41

N.

T.

40

N.

T.

41

N.

T.

40

N.

PM10=39.2 μg/m3

NOx=55.2 μg/m3

EAST

PIT

MIDDLE

PIT

WEST

PIT

0 5000 10000 20000

GRAPHIC SCALE (FEET)

LEGEND

Existing North Antelope Rochelle

Mine Federal Coal Leases

North Antelope Rochelle Mine Permit Boundary

North Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

North Porcupine LBA Tract as Applied for

South Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

South Porcupine LBA Tract as Applied for

Receptor Location

Area Source

Ambient Air Boundary

Haul Roads

Figure 3-15. Maximum Modeled PM10 and NOX

 Concentrations at the North Antelope Rochelle Mine

Ambient Air Boundary for the Year 2017.

3.0 Affected Environment and Environmental Consequences

3-72 Final EIS, Wright Area Coal Lease Applications
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-73 

PRC estimates that the mine would produce at an average annual rate of 95 

mmtpy if it acquires and mines the North and/or South Porcupine LBA Tracts, 

but fugitive dust emissions are projected to remain within daily and annual 

AAQS limits. 

Public exposure to particulate emissions from surface mining operations is 

most likely to occur along publicly accessible roads and highways that pass 

near and through the areas of mining operations. Occupants of dwellings in 

the area could also be affected. Roads, highways, businesses, and currently 

occupied dwellings in the vicinity of the North and South Porcupine LBA Tracts 

are shown in Figures 3-16 and 3-17, respectively. 

3.4.2.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and coal removal and projected 

impacts related to PM10 emissions discussed above would not occur on the 

portions of the LBA tracts as applied for or the LBA tracts configured under 

Alternative 2 that will not be disturbed under the currently approved mining 

and air quality permits. Mining operations would continue as currently 

permitted on the existing Black Thunder, Jacobs Ranch, and North Antelope 

Rochelle Mine coal leases. Projected impacts related to PM10 emissions would 

not be extended onto those portions of the LBA tracts that will not be affected 

under the mines’ current mining and reclamation plans. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective 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 PRB require the following dust control measures, which are considered 

to be Best Available Control Methods (BACMs): 

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 

that 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. 
31

30

19

32

29

20

33

28

21

34

27

22

35

26

23

36

25

31

30

32

29

20

33

28

21

34

27

22

35

26

23

36

25

31

30

32

29

20

28

21

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

28

21

16

9

31

30

19

18

7

6

32

29

20

17

8

5

28

21

16

9

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

6

8

5

7

6

8

5

9

4

10

3

11

2

1 6

8

5

9

4

10

3

11

2 1

T.

42

N.

T.

41

N.

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

Converse County

Campbell County

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

T.

42

N.

T.

41

N.

Reno Road

Mackey

Antelope

Edwards

Matheson Road

Reno Road School

Creek

BNSF & UP RR

Hilight Road

State

Highway 450

Road

Road

Road

Antelope Road

Road

Matheson Road

Mackey Road

T.

41

N.

T.

40

N.

T.

41

N.

T.

40

N.

25

24

25

24

13

12

13

12

T.

43

N.

T.

42

N.

T.

43

N.

T.

42

N.

NORTH ANTELOPE ROCHELLE

MINE OFFICE

BUSINESS

0 6000 12000 24000

GRAPHIC SCALE (FEET)

LEGEND

No occupied residences, school bus stops, or other

publicly accessible facilities exist in the vicinity of the

BLM study area for the North Porcupine LBA Tract.

Existing North Antelope Rochelle

Mine Federal Coal Leases

North Antelope Rochelle Mine Permit Boundary

North Porcupine LBA Tract as Applied for

North Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-16. Residences, School Bus Stops, Public Roads, and Other Publicly Accessible Facilities in the

Vicinity of the North Porcupine LBA Tract Under Alternative 2.

3.0 Affected Environment and Environmental Consequences

3-74 Final EIS, Wright Area Coal Lease Applications
31

30

19

18

7

6

32

29

20

17

8

5

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28

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16

9

4

34

27

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15

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26

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14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

7

6

8

5

9

4

10

3

11

2 1

6

8

5

9

4

10

3

11

2

12

1

T.

42

N.

T.

41

N.

R. 71 W. R. 70 W.

Converse County

Campbell County

R. 71 W. R. 70 W.

T.

42

N.

T.

41

N.

Reno Road

Mackey

Antelope

Edwards

Matheson Road

Reno Road

School

Creek

Hilight

Road

Road Road Road

Antelope Road

Road

BNSF & UP RR

Matheson Road

Mackey Road

T.

41

N.

T.

40

N.

T.

41

N.

T.

40

N.

NORTH ANTELOPE ROCHELLE

MINE OFFICE

ANTELOPE MINE OFFICE

BUSINESS

0 5000 10000 20000

GRAPHIC SCALE (FEET)

LEGEND

Existing North Antelope Rochelle

Mine Federal Coal Leases

North Antelope Rochelle Mine Permit Boundary

South Porcupine LBA Tract as Applied for

South Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

No occupied residences or school bus stops

exist in the vicinity of the BLM study area for

the South Porcupine LBA Tract.

Figure 3-17. Residences, School Bus Stops, Public Roads, and Other Publicly Accessible Facilities in the

Vicinity of the South Porcupine LBA Tract Under Alternative 2.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-75
3.0 Affected Environment and Environmental Consequences 

3-76 Final EIS, Wright Area Coal Lease Applications 

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 2007). 

Additional site-specific requirements related to mine-specific layout and mining 

practices may be included in individual mine and air quality permits. 

Fugitive emissions are also controlled with a variety of other measures that the 

WDEQ/AQD considers BACT. Haul truck speed limits are voluntarily set to 

further help to reduce fugitive emissions from roads. Material drop heights for 

shovels and draglines (bucket to truck bed or backfill) are voluntarily limited to 

the minimum necessary to conduct the mining operations. Timely temporary 

and permanent revegetation of disturbed areas is utilized to minimize wind 

erosion. All of these control measures are employed at the Black Thunder, 

Jacobs Ranch, and North Antelope Rochelle mines. 

In response to the measured exceedances of the PM10 NAAQS in certain areas 

of the PRB and in anticipation of possible future exceedances, the WDEQ/AQD 

in a joint effort with PRB mining stakeholders, developed a Natural Events 

Action Plan, or NEAP, for the coal mines of the PRB in April 2006 (revised 

January 2007). The NEAP was developed under the framework afforded by 

EPA’s Natural Events Policy of May 30, 1996. EPA Region VIII approved the 

WDEQ NEAP on March 13, 2007, and the PRB mining operators have 

implemented these measures and are presently complying with the NEAP. A 

report describing the plan in detail can be accessed on the WDEQ/AQD’s 

website on the Internet (WDEQ/AQD 2007), and the NEAP is discussed in 

Appendix F. 

If a NEAP is designed and implemented to minimize PM10 concentrations, EPA 

will exercise its discretion, under Section 107(d)(3) of the CAA, not to 

redesignate areas as nonattainment, provided that the exceedances are 

demonstrated to be the result of natural events under the following conditions: 

1) the dust originated from non-anthropogenic sources, or 2) the dust 

originated from anthropogenic sources controlled with the required BACMs. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-77 

EPA’s Exceptional Event Rule of March 22, 2007 no longer requires a NEAP. 

However, according to the preamble to the Exceptional Event Rule (signed 

March 22, 2007, effective May 21, 2007), “The EPA believes that it is 

advantageous for states to keep NEAPs in place that are currently being 

implemented in order to address the public health impacts associated with 

recurring natural events such as high wind events. “However, following the 

promulgation of this rule, states will no longer be required to keep NEAPs in 

place that were not approved as a part of a SIP for an area.” WDEQ will retain 

the NEAP because it provides the flexibility to control other emission sources, 

like fugitive emission sources, that otherwise might not be controlled with 

BACT. The BACM specified in the NEAP contains an appropriate and 

reasonable minimum level of control as required under the Exceptional Event 

Rule for the PRB coal mines. 

WDEQ/AQD may require implementation of the control steps outlined in the 

NEAP and may require 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 North 

Antelope 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 

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 to be used as a means 

of better evaluating dust problems. For example, where elevated emissions 

have occurred, WDEQ/AQD has increased monitoring frequency requirements 

including installation of continuous PM10 monitors, or TEOMs, which allow 

monitoring of emissions on a real-time basis. Other regulatory options may 

include enforcement actions such as Notices of Violation resulting in a consent 

decree and/or modified permit conditions. 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. 

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 
3.0 Affected Environment and Environmental Consequences 

3-78 Final EIS, Wright Area Coal Lease Applications 

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, monitoring requirements, the data that have been 

collected, and PM10 concentration trends since monitoring began are included 

in Appendix F. 

WDEQ/AQD’s Ambient Air Monitoring Annual Network Plan provides an 

overview of the number and types of air quality monitors AQD runs or oversees 

within the state of Wyoming, and is available for review on its website at: 

http://deq.state.wy.us/aqd/downloads/AirMonitor/Network%20Plan_2008.pdf

3.4.3 Emissions of Nitrogen Oxides (NOX) and Ozone (O3)

3.4.3.1 Affected Environment for NOX and O3 Emissions

Gases that contain nitrogen and oxygen in varying amounts are referred to as 

nitrogen oxides (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. O3 has been included in discussions on emissions of NOX

since NOX is one of the main ingredients involved in the formation of ground 

level O3. Ground-level O3 is not emitted directly into the air, but is created by 

chemical reactions between NOX and VOCs in the presence of sunlight. 

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 to NO2 may cause death by damaging the pulmonary 

system. 

• 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, in 2002, all motor vehicles (including non-road equipment) produced 

about 60 percent of the manmade NOX emissions, utilities produced 

approximately 22 percent of the emissions, industrial/commercial/residential 

activities produced about 17 percent of the manmade NOX emissions, and 

other sources accounted for the remaining 1 percent of the manmade 

emissions (EPA 2009b). 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-79 

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 assist in the 

removal of 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, orange-colored clouds may be formed and they can drift or be blown 

off mine permit areas. 

Incomplete combustion during blasting may be caused by wet conditions in the 

overburden, incompetent or fractured geological formations, deformation of 

boreholes, and blasting agent factors. The rate of release is not well known but 

is believed to be dependent on a wide number of factors that 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. Generally, blasting-related NOX emissions are more prevalent at 

operations that use the blasting technique referred to as cast blasting. Cast 

blasting refers to a type of blasting in which the blast is designed to directly 

cast the overburden from on top of the coal into the previously mined area. All 

three of the applicant mines employ cast blasting. 

O3 has the same chemical structure whether it occurs miles above the earth or 

at ground level and can be “good” or “bad”, depending on its location in the 

atmosphere. In the earth’s lower atmosphere, ground-level O3 is considered 

“bad.” Motor vehicle exhaust and emissions from industrial sources contain 

NOX and in the presence of VOCs react to form ground-level O3. Ground-level 

O3 is the primary constituent of smog. Many urban areas tend to have high 

levels of “bad” O3, but even rural areas are also subject to increased O3 levels 

because wind carries O3 and pollutants that form it hundreds of miles away 

from their original sources. 

Under the Clean Air Act, EPA has set protective health-based standards for O3

in the air we breathe. Prior to May 27, 2008, the NAAQS 8-hour standard for 

O3 was 0.080 parts per million (ppm) (157 μg/m3). Effective May 27, 2008, the 

8-hour standard was revised by EPA to 0.075 ppm (147 μg/m3). Ozone 

monitoring is not required by WDEQ/AQD at the PRB coal mines, but levels 

have been monitored by WDEQ/AQD at its ambient air quality monitoring sites 

in the PRB since 2001 (Table 3-9). An exceedance of the O3 8-hour standard 

occurs if the 4th-highest daily maximum value is above the level of the 

standard. 

3.4.3.1.1 Site Specific NOX and O3 Emissions

Sources of fugitive NOX emissions at the Black Thunder, Jacobs Ranch, and 

North Antelope Rochelle mines include overburden and coal blasting events, 

tailpipe emissions from the mining equipment, and emissions from the trains 

used to transport the coal away from the mines. NOX point sources at the 
3.0 Affected Environment and Environmental Consequences 

3-80 Final EIS, Wright Area Coal Lease Applications 

Table 3-9. 2001 Through 2008 Annual 4th Max, 8-Hour Average Ozone 

Values (ppm). 

Site Address 2001 2002 2003 2004 2005 2006 2007 2008 

TBNG 0.069 0.071 0.074 0.065 0.063 0.072 0.072 0.074 

Campbell County -- -- 0.077 0.061 0.063 0.065 0.072 0.064 

Monitor values from EPA (2009a) 

Pre-May 27, 2008, 8-Hour O3 NAAQS = 0.080 ppm 

Post-May 27, 2008, 8-Hour O3 NAAQS = 0.075 ppm

mines could include stationary engines, coal-fired hot water generators, and 

natural-gas fired heaters. 

To date, there have been no reported events of public exposure to NO2 from 

blasting activities at the Jacobs Ranch and North Antelope Rochelle mines. 

The WDEQ has not required the mines to implement any specific measures to 

control or limit public exposure to NO2 from blasting, although the mines have 

instituted voluntary blasting restrictions to avoid NOX impact to the public, 

which are discussed in more detail in Section 3.4.3.3. Black Thunder Mine 

received several reports of public exposure to NO2 from blasting prior to 2001. 

Measures to control or limit future such incidences, which are part of Black 

Thunder Mine’s settlement agreement, have been instituted when large 

overburden blasts are planned at that mine, and those measures are discussed 

in Section 3.4.3.3. 

Table 3-9 shows that no exceedances of the O3 standard have occurred at 

either of the two monitoring sites if evaluated under the standard in place at 

the time the values were recorded. If the strengthened 2008 standard was 

applied retroactively, one exceedance would have occurred (in 2003 at the 

Campbell County site). BLM expects a stricter O3 standard of between 0.06 

and 0.07 ppm to be announced in August 2010 (Zachariassen 2010). 

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 

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 reactants 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 that cause visibility impairment, 

most noticeably in national parks; 

• it reacts to form toxic chemicals; 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-81 

• 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 2009b). 

Potential health risks associated with inhalation of ground level ozone and NOX

related 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 2007b). 

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). WDEQ has yet not 

established a WAAQS for NO2 for averaging times shorter than one year. EPA 

recently set a 1-hour NO2 NAAQS at 100 parts per billion (ppb) effective 

January 22, 2010. 

While extensive expert testimony was provided to the Wyoming Environmental 

Quality Council (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 

overburden cast blasting when wind direction or atmospheric conditions are 

unfavorable. Such approaches are employed at the Black Thunder, Jacobs 

Ranch, and North Antelope Rochelle Mines and will continue 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 emissions. The National Institute of Occupational Safety 

and Health (NIOSH), Occupational Safety and Health Administration (OSHA), 

and EPA have identified the following short-term exposure criteria for NO2: 

• NIOSH’s recommended Immediately Dangerous to Life and Health level is 

20.0 ppm (37,600 μg/m3); 

• EPA’s Significant Harm Level, a 1-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; 
3.0 Affected Environment and Environmental Consequences 

3-82 Final EIS, Wright Area Coal Lease Applications 

• 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 

2003a). 

The Black Thunder Mine also conducted a study designed to provide 

information on safe setback distances for blasting activities at that mine (TBCC 

2002). Monitors for that study were located close to blasts in order to collect 

data for a modeling project; they were located within the mine permit boundary 

in areas that are not and would not be accessible to the public during mining 

operations and these areas are also cleared of employees during blasting. The 

measured NOX levels ranged from non-detectable to 21.4 ppm. The highest 

value was measured 361 feet from the blast. 

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 2 and 3

Potential NOX emissions related to mining operations at the existing Black 

Thunder, Jacobs Ranch, and North Antelope Rochelle mines are described 

below. Due to the similarities in mining rates and mining operations, the 

potential impacts of mining the LBA tracts have been inferred from the 

projected impacts of mining the existing coal leases as currently permitted. 

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, the 

applicant mines conducted modeling analyses for PM10 and NOX for a 

maximum projected coal production rate as part of their air quality permit 

applications. Receptor locations were placed at approximately 500-meter 

intervals along the mines’ LNCM boundaries. The regional background NOX

annual concentration used for the Black Thunder and Jacobs Ranch Mines 

was 14.0 μg/m3, while the North Antelope Rochelle Mine used a regional 

background concentration of 20.0 μg/m3. Pursuant to WDEQ/AQD 

requirements, emissions from all stationary engines, coal-fired hot water 

generators, and natural-gas fired heaters, which are considered to be NOX

point sources at the mine, were considered in the inventory. Additional mobile 

sources were added to describe the railroad locomotives and large mining 

equipment on each mine site. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-83 

The estimated average overburden thickness is generally greater in each of the 

LBA tracts than within the current leases, but the thickness of the coal is 

about the same as in the existing mine areas (Table 3-7). If the Black Thunder, 

Jacobs Ranch, and North Antelope Rochelle mines acquire the LBA tracts, 

there are no plans to change blasting procedures or blast sizes associated with 

the mining of the North Hilight Field, South Hilight Field, West Hilight Field, 

West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts. 

However, if the average annual rates of production are maintained, there would 

potentially be an increase in the frequency of blasting in order to remove the 

additional volume of overburden overlying the coal. 

If the Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines 

acquire the LBA tracts, they will have to amend their current air quality 

permits to include the new leases before mining activities can proceed into the 

new lease areas. Current mining and mitigation methods to recover the coal in 

the LBA tracts would be expected to continue for a longer period of time than is 

shown in the mines’ current air quality permits. The mines would continue to 

use cast blasting, and there are currently no plans to change blasting 

procedures or blast sizes associated with mining of the LBA tracts. According 

to WDEQ, permit conditions designed to control or limit public exposure to NO2

and flyrock from blasting operations would be no less stringent for mining 

operations on the LBA tracts than the permit conditions that are in place for 

blasting operations on the existing Black Thunder, Jacobs Ranch, and North 

Antelope Rochelle Mine leases (Emme 2007). 

3.4.3.2.1.1 North, South, and West Hilight Field LBA Tracts

The North, South, and West Hilight Field LBA Tracts would be mined as 

integral parts of the Black Thunder Mine under the Proposed Action and 

Alternatives 2 and 3. 

As discussed in Section 3.4.2.2, WDEQ/AQD issued the most recent air quality 

permit, MD-3851, for the Black Thunder Mine on August 18, 2008, and the 

mine was required to conduct NO2 dispersion modeling similar in scope to the 

PM10 analysis. Emission rates were determined for the same worst-case years 

used in the PM10 modeling. The amount of NO2 emissions from blasting is 

related to the amount of ANFO utilized. NO2 emission rates for 2015 and 2017 

are expected to be 4,507 tpy and 4,743 tpy, respectively. NOX modeling closely 

followed many of the same procedures used in the PM10 analysis. Emissions 

were apportioned in a similar manner and the same meteorological data set 

was used. Area source, haul road, and point source information for the Black 

Thunder, Jacobs Ranch, and North Antelope Rochelle mines and information 

for railroads, roads, power plants, and regional sources provided by 

WDEQ/AQD were included in the model. Long-term modeling indicated the 

currently projected mine activities will be in compliance with the annual NOX

AAQS for the life of the Black Thunder Mine. For year 2015, the maximum 

annual NOX concentration along the Black Thunder Mine LNCM boundary was 

46.3 μg/m3 and for year 2017, the maximum annual NOX concentration along 
3.0 Affected Environment and Environmental Consequences 

3-84 Final EIS, Wright Area Coal Lease Applications 

the Black Thunder Mine LNCM boundary was 52.5 μg/m3 (BTM 2008b). Coal 

production in both years was assumed to be the maximum permitted 

production level of 135 million tons. The locations of the maximum-modeled 

NOX concentrations along the Black Thunder Mine LNCM boundary for 2015 

and 2017 are shown on Figures 3-7 and 3-8, respectively. 

Modeling conducted for the current Black Thunder Mine air quality permit 

projected no exceedances of the annual NO2 NAAQS at the permitted 

production rate. TBCC estimates that the Black Thunder Mine would produce 

at an average rate of 135 mmtpy if it acquires and mines the North, South, 

and/or West Hilight Field LBA Tracts; therefore, air quality impacts that result 

from mining the LBA tracts should also be within annual NAAQS limits. 

Public exposure to NOX emissions caused by surface mining operations is most 

likely to occur along publicly accessible roads and highways that pass near and 

through the areas of mining operations. Occupants of dwellings in the area 

could also be affected. Roads, highways, currently occupied dwellings, 

businesses, and school bus stops in the vicinity of the North, South, and West 

Hilight Field LBA Tracts are shown in Figures 3-9 through 3-11, respectively. 

3.4.3.2.1.2 West Jacobs Ranch LBA Tract

The West Jacobs Ranch LBA Tract would be mined as an integral part of the 

Jacobs Ranch Mine under the Proposed Action and Alternative 2. 

As discussed in Section 3.4.2.2, WDEQ/AQD issued the most recent air quality 

permit, MD-1005A2, for the Jacobs Ranch Mine on January 22, 2007; 

however, NO2 dispersion modeling for the mine is included in air quality permit 

MD-1005, issued August 6, 2004. Based on mine plan parameters and highest 

emissions inventories, the worst-case years of 2006 and 2013 were selected. 

The amount of NOX emissions from blasting is related to the amount of ANFO 

utilized. NOX emission rates for 2006 and 2013 were expected to be 1,447 tpy 

and 1,450 tpy, respectively. NOX modeling closely followed many of the same 

procedures used in the PM10 analysis except for selecting different modeling 

years and different source areas. Area source, haul road, and point source 

information for the Black Thunder, Jacobs Ranch, and North Antelope Rochelle 

mines and information for railroads, roads, power plants, and regional sources 

provided by WDEQ/AQD were included in the model. Long-term modeling 

indicated the currently projected mine activities will be in compliance with the 

annual NOX AAQS for the life of the Jacobs Ranch Mine. For year 2006, the 

maximum annual NOX concentration along the Jacobs Ranch Mine LNCM 

boundary was 50.0 μg/m3 and for year 2013, the maximum annual NOX

concentration along the Jacobs Ranch Mine LNCM boundary was 55.0 μg/m3

(JRM 2007). Coal production in both years was assumed to be the maximum 

permitted production level of 55 million tons. The locations of the maximummodeled NOX concentrations along the Jacobs Ranch Mine LNCM boundary for 

2006 and 2013 are shown on Figure 3-18. 
T.

45

N.

T.

44

N.

T.

44

N.

T.

43

N.

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

T.

45

N.

T.

44

N.

T.

44

N.

T.

43

N.

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

Keeline

Road Jacobs

BNSF & UP RR

Hilight Road Hilight Road

Road

Keeline Road

Road

State

450 Highway

BNSF & UP RR

State Highway 450

Shroyer

Small

Road

30

32

29

33

28

34

27

35

26

36 31 32

29

33

28

34

27

35

26

36 31

31

30

19

18

7

6

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

NOx=55.0 μg/m3 (2013)

NOx=50.0 μg/m3 (2006)

0 5000 10000 20000

GRAPHIC SCALE (FEET)

LEGEND

Existing Jacobs Ranch Mine

Federal Coal Leases

Jacobs Ranch Mine Permit Boundary

West Jacobs Ranch LBA Tract as Applied for

West Jacobs Ranch LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Receptor Location

Area Source (2006)

Ambient Air Boundary

Haul Roads

Area Source (2013)

Figure 3-18. Maximum Modeled NO X

 Concentrations at the Jacobs Ranch Mine Ambient Air Boundary for

the Years 2006 and 2013.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-85
3.0 Affected Environment and Environmental Consequences 

3-86 Final EIS, Wright Area Coal Lease Applications 

Modeling conducted for the current Jacobs Ranch Mine air quality permit 

projected no exceedances of the annual NOX NAAQS at the permitted 

production rate. TBCC estimates that the Jacobs Ranch Mine would produce 

at the current average rate of 40 mmtpy if it acquires and mines the West 

Jacobs Ranch LBA Tract; therefore, air quality impacts that result from mining 

the LBA tract should also be within annual NAAQS limits. 

Public exposure to NOX emissions caused by surface mining operations is most 

likely to occur along publicly accessible roads and highways that pass near and 

through the areas of mining operations. Occupants of dwellings in the area 

could also be affected. Roads, highways, currently occupied dwellings, 

businesses, and school bus stops in the vicinity of the West Jacobs Ranch LBA 

Tract are shown in Figure 3-13. 

3.4.3.2.1.3 North and South Porcupine LBA Tracts

The North and South Porcupine LBA Tracts would be mined as integral parts of 

the North Antelope Rochelle Mine under the Proposed Action and Alternative 2. 

As discussed in Section 3.4.2.2, WDEQ/AQD issued the most recent air quality 

permit, MD-6375, for the North Antelope Rochelle Mine on February 10, 2008, 

which modified air quality permit MD-1331 that was issued on March 7, 2006. 

The mine was required to conduct NO2 dispersion modeling similar in scope to 

the PM10 analysis. Emission rates were determined for the same worst-case 

years used in the PM10 modeling. The amount of NOX emissions from blasting 

is related to the amount of ANFO utilized. NOX emission rates for 2012 and 

2017 are expected to be 3,323 tpy and 3,856 tpy, respectively. NOX modeling 

closely followed many of the same procedures used in the PM10 analysis. 

Emissions were apportioned in a similar manner and the same meteorological 

data set was used. Area source, haul road, and point source information for 

the North Antelope Rochelle, Black Thunder, Jacobs Ranch, North Rochelle 

(now part of the North Antelope Rochelle and Black Thunder mines), and 

Antelope mines and information for railroads, roads, power plants, and 

regional sources provided by WDEQ/AQD were included in the model. Longterm modeling indicated the currently projected mine activities will be in 

compliance with the annual NOX AAQS for the life of the North Antelope 

Rochelle Mine. For year 2012, the maximum annual NOX concentration along 

the North Antelope Rochelle Mine LNCM boundary was 50.6 μg/m3 and for 

year 2017, the maximum annual NOX concentration along the North Antelope 

Rochelle Mine LNCM boundary was 55.2 μg/m3 (PRC 2008a). Coal production 

in both years was assumed to be the maximum permitted production level of 

140 million tons. The locations of the maximum-modeled NOX concentrations 

for 2012 and 2017 are shown on Figures 3-14 and 3-15, respectively. The 

potential NOX impacts from mining the North and South Porcupine LBA Tracts 

have been inferred to be similar to the currently permitted impacts of mining 

the existing coal leases at the North Antelope Rochelle Mine because of the 

similarities in mining rates and mining operations. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-87 

Modeling conducted for the current North Antelope Rochelle Mine air quality 

permit projected no exceedances of the annual NOX NAAQS at the permitted 

production rate. PRC estimates that the North Antelope Rochelle Mine would 

continue to produce at the an average rate of 95 mmtpy if it acquires and 

mines the North and/or South Porcupine LBA Tracts; therefore, air quality 

impacts that result from mining the LBA tract should also be within annual 

NAAQS limits. 

Public exposure to NOX emissions caused by surface mining operations is most 

likely to occur along publicly accessible roads and highways that pass near and 

through the areas of mining operations. Occupants of dwellings in the area 

could also be affected. Roads, highways, currently occupied dwellings, and 

businesses in the vicinity of the North and South Porcupine LBA Tract are 

shown in Figures 3-16 and 3-17, respectively. 

3.4.3.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and coal removal and projected 

impacts related to NOX emissions discussed above would not occur on the 

portions of the LBA tracts as applied for or the LBA tracts configured under 

Alternative 2 that will not be disturbed under the currently approved mining 

and air quality permits. Mining operations would continue as currently 

permitted on the existing Black Thunder, Jacobs Ranch, and North Antelope 

Rochelle Mine coal leases. Projected impacts related to NOX emissions would 

not be extended onto those portions of the LBA tracts that will not be affected 

under the mines’ current mining and reclamation plans. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective tract in the future. 

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 emissions impact to the public. Voluntary 

measures that have been instituted, particularly when large blasts are planned 

include: 

• telephone notification of neighbors (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; 
3.0 Affected Environment and Environmental Consequences 

3-88 Final EIS, Wright Area Coal Lease Applications 

• 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. 

To date, there have been no reported events of public exposure to NO2 from 

blasting activities at the Jacobs Ranch and North Antelope Rochelle mines. 

The WDEQ has not required those mines to implement any specific measures 

to control or limit public exposure to NO2 from blasting, although the mines 

have instituted voluntary blasting restrictions to avoid NOX impact to the 

public. WDEQ received reports of public exposure to NO2 from blasting 

operations at some of the PRB mines prior to 2001, including the Black 

Thunder Mine. Measures to control or limit future such incidences when large 

overburden blasts are planned, have been instituted at the Black Thunder 

Mine. There have been no incidents in the southern PRB reported by the 

public to the WDEQ for the past 4 years. Measures to avoid impacts to the 

public are requirements for the Black Thunder Mine as part of a settlement 

agreement reached in 2000. Many of the other mines have voluntarily 

implemented similar administrative controls to avoid impacts to the public, as 

discussed above. Measures that have been implemented include: 

• notification of neighbors and workers in the general area of the mine 

prior to a blast; 

• 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; and 

• closing public roads when appropriate to protect the public. 

The Wyoming EQC has issued orders that address procedures and notification 

protocols related to providing protections from overburden blasting within PRB 

mine areas. The conditions state that specific procedures would be used when 

overburden blasting occurs within a certain distance of residences and 

businesses adjacent to the mines. Orders have also placed limits on the size of 

the blasting that can be conducted within the mine areas and restricted 

blasting under certain atmospheric conditions. 

WDEQ has required several PRB surface coal 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.” During blasting operations, public access to some of the 

roads in the area, including the Antelope Road and State Highway 450, are 

currently blocked and will continue to be blocked when wind directions or 

proximity to the road warrant such closure. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-89 

Significant research has been conducted at the mines to reduce NOX emissions 

from blasting activities. Efforts to eliminate NOX production have included 

working with blasting agent manufacturers to reduce NOX emissions by the 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 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). 

Mitigation measures implemented to reduce mine-related NOX emissions 

should also reduce the potential for the formation of ground-level O3 in the 

PRB. 

Annual mean NO2 concentrations have been periodically measured in the PRB 

since 1975. NO2 was monitored from 1975 through 1983 in Gillette and from 

March 1996 through April 1997 at four locations in the PRB, including Gillette. 

Table 3-10 summarizes the results of that monitoring. 

Table 3-10. Annual Ambient NO2 Concentration Data. 

Site Gillette, WY 

Black 

Thunder 

Mine 

Belle Ayr 

Mine Bill, WY 

Year 

Percent of 

Standard1

Percent of 

Standard1

Percent of 

Standard1

Percent of 

Standard1

1975 6* 

1976 4* 1* 

1977 4* 5* 

1978 11* 

1979 11 

1980 12 

1981 14 

1982 11 

19832 17 

1996-973 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)
3.0 Affected Environment and Environmental Consequences 

3-90 Final EIS, Wright Area Coal Lease Applications 

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 

due to development of all types in the eastern PRB, the coal mining industry 

instituted a monitoring network in cooperation with WDEQ/AQD to gather data 

on NO2 beginning in 2001. Through a cooperative agreement between AQD and 

the Wyoming Mining Association, the PRB NOX network began operation in 

January 2001 (WDEQ/AQD 2008). Industry funded and operated the network 

for approximately 3 years. Ownership of some of the monitoring equipment 

was transferred to WDEQ by the mines and WDEQ now funds and operates 

that NO2 monitoring equipment. The mines have been given ongoing access to 

all of the monitoring sites and provide electrical power for the instrumentation. 

WDEQ/AQD and the mines now share maintenance of these monitoring 

stations, and the AQD is relying on the ongoing monitoring data and emission 

inventories in the mines’ air quality permit applications to demonstrate 

compliance with the annual NO2 ambient air standard (Table 3-8). The 2002 

through 2007 data from this regional network are summarized in Table 3-11. 

With respect to the general Wright analysis area, the Tracy Ranch Site is 

located roughly in the geographic center of the area (TBCC owns and operates 

that site), the Thunder Basin National Grassland Site is approximately 67 miles 

north, and the Campbell County Site is approximately 33 miles northwest. As 

noted in Tables 3-9 and 3-10, the mean annual NO2 concentrations for all 

monitoring sites have historically been significantly below the WAAQS and 

NAAQS annual standard (100 μg/m3). 

Table 3-11. 2002 Through 2008 Annual Mean NO2 Concentration Data

(μg/m3). 

Site Address 2002 2003 2004 2005 2006 2007 2008 

TBNG1 5.7 5.7 3.8 3.8 3.8 3.8 3.8 

Belle Ayr Mine1 -- 13.2 13.2 15.1 17.0 -- -- 

Antelope Mine1 -- 7.5 7.5 9.4 7.5 -- -- 

Campbell County1 -- 13.2 9.4 7.5 5.7 7.5 5.6 

Tracy Ranch2 6.2 5.6 5.8 7.7 11.8 8.2 6.1 

Average 5.95 9.04 7.94 8.70 9.16 6.50 5.17 

1 Monitor values from EPA (2009a) 

2 Monitor values from TBCC (2009) 

The WDEQ/AQD’s Ambient Air Monitoring Annual Network Plan provides an 

overview of the number and types of air quality monitors AQD runs or oversees 

within the state of Wyoming, and is available for review on its website at: 

http://deq.state.wy.us/aqd/downloads/AirMonitor/Network%20Plan_2008.pdf

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 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-91 

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 is also 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 

3-12 shows the distances from 31 PSD Class I and Class II areas in the vicinity 

of the PRB to the general Wright 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 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 to review and revise, if appropriate, the Long Term Strategy every 

3 years. The 2003 Review Report is available on the WDEQ/AQD visibility 

program website at http://deq.state.wy.us/aqd/visibility.asp (WDEQ/AQD 

2009). 
3.0 Affected Environment and Environmental Consequences 

3-92 Final EIS, Wright Area Coal Lease Applications 

Table 3-12. Approximate Distances and Directions from the General Wright 

Analysis Area to Mandatory Federal PSD Class I, Tribal Federal 

PSD Class I, and Federal PSD Class II Areas. 

Receptor Area 

Distance 

(miles) 

Direction to

Receptor 

Mandatory Federal PSD Class I Area 

Badlands Wilderness Area1 143 E 

Bridger Wilderness Area 199 WSW 

Fitzpatrick Wilderness Area 207 W 

Gates of the Mountain Wilderness Area 382 NW 

Grand Teton National Park 254 W 

North Absaroka Wilderness Area 213 WNW 

Red Rocks Lake Wilderness Area 320 WNW 

Scapegoat Wilderness Area 426 NW 

Teton Wilderness Area 221 W 

Theodore Roosevelt National Park (North Unit) 290 NNE 

Theodore Roosevelt National Park (South Unit) 242 NNE 

U.L. Bend Wilderness Area 290 NNW 

Washakie Wilderness Area 187 W 

Wind Cave National Park 91 E 

Yellowstone National Park 235 WNW 

Tribal Federal PSD Class I 

Fort Peck Indian Reservation 301 N 

Northern Cheyenne Indian Reservation 132 NNW 

Federal PSD Class II 

Absaroka-Beartooth Wilderness Area 224 WNW 

Agate Fossil Beds National Monument 114 SE 

Badlands National Park 121 E 

Bighorn Canyon National Recreation Area 166 NW 

Black Elk Wilderness Area 88 E 

Cloud Peak Wilderness Area 93 WNW 

Crow Indian Reservation 124 NW 

Devils Tower National Monument 70 NNE 

Fort Belknap Indian Reservation 327 NNW 

Fort Laramie National Historic Site 108 SSE 

Jewel Cave National Monument 74 E 

Mount Rushmore National Memorial 94 E 

Popo Agie Wilderness Area 194 WSW 

Soldier Creek Wilderness Area 106 SE 

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. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-93 

The Regional Haze Rule calls for improved visibility on the most-impaired days 

and no additional improvement on the least-impaired days. EPA participates 

in the Interagency Management of Protected Visual Environments (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. On December 20, 2005, the IMPROVE Steering Committee approved a 

new algorithm for calculating current and natural background visibility. 

Figure 3-19 shows annual averages, based on the new algorithm, for the 20 

percent best (clearest), average, and worst (haziest) visibility days at the four 

IMPROVE visibility monitoring sites located within approximately 200 miles of 

the general Wright analysis area (IMPROVE 2010). These historical visibility 

data, in deciview, for the Badlands and Wind Cave National Parks in South 

Dakota, and the Bridger/Fitzpatrick and Cloud Peak Wilderness Areas in 

Wyoming, are depicted on Figure 3-19. Visibility data for all IMPROVE 

visibility monitoring sites in the U.S. are available on the Visibility Information 

Exchange Web System (VIEWS) website at http://views.cira.colostate.edu/

web/Trends/. Visibility data for Badlands National Park have statistically 

shown a trend toward improved visibility on the least-, average-, and mostimpaired days. The visibility data for the Bridger/Fitzpatrick Wilderness Areas 

have statistically shown a trend toward improved visibility on the average- and 

least-impaired days and a trend toward greater perceived visibility impairment 

on the most-impaired days. The visibility data for Wind Cave National Park 

have statistically shown a trend toward improved visibility on the least- and 

most-impaired days and a trend toward greater perceived visibility impairment 

on the average-impaired days. The Cloud Peak Wilderness Area site was 

established in 2003; therefore, the data set is not yet large enough to 

statistically determine accurate trends in the best, average and worst visibility 

days. However, Figure 3-19 illustrates that there may be a slight trend toward 

increasing visibility impairment on the average- and least-impaired days at the 

Cloud Peak site. 

3.4.4.1.2 Environmental Consequences for Visibility

3.4.4.1.2.1 Proposed Action and Alternatives 2 and 3

The impacts to visibility from mining the North, South, and West Hilight Field 

LBA Tracts have been inferred from the currently permitted impacts of mining 

the existing coal leases at the Black Thunder Mine. The impacts to visibility 

from mining the West Jacobs Ranch LBA Tract have been inferred from the 

currently permitted impacts of mining the existing coal leases at the Jacobs 

Ranch Mine. The impacts to visibility from mining the North and South 

Porcupine LBA Tracts have been inferred from the currently permitted impacts 

of mining the existing coal leases at the North Antelope Rochelle Mine. If the 

mines acquire the additional coal in the LBA tracts, the LBA tracts would be 

mined as an integral part of the applicant mines. The average annual coal 

production for each applicant mine is anticipated to remain at the projected 

post-2008 rates, with or without the LBA tracts. Therefore, impacts to visibility 

under the Proposed Action and Alternative 2, BLM’s preferred alternative for 
20

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6

4

2

0

1989

Visibility in Badlands National Park, South Dakota (IMPROVE Station: BADL1)

8

Visibility (dv)

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999

20% Clearest

Average

20% Haziest

Visibility in Bridger / Fitzpatrick Wilderness Areas, Wyoming (IMPROVE Station: BRID1)

2000 2001 2002 2003 2004 2005

14

12

10

6

0

1989

8

Visibility (dv)

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005

2006 2007 2008

2005 2006 2007 2008

Visibility in Windcave National Park, South Dakota (IMPROVE Station: WICA1)

Source: VIEWS (2010)

18

16

14

12

10

6

4

2

0

8

Visibility (dv)

2000 2001 2002 2003 2004 2005 2006 2007 2008

4

2

Visibility in the Cloud Peak Wilderness Area, Wyoming (IMPROVE Station: CLPE1)

16

14

12

10

6

4

2

0

8

Visibility (dv)

2003 2004 2005 2006 2007 2008

Figure 3-19. Visibility in the Badlands and Windcave National Parks and the Bridger / Fitzpatrick and Cloud

Peak Wilderness Areas.

3.0 Affected Environment and Environmental Consequences

3-94 Final EIS, Wright Area Coal Lease Applications
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-95 

each tract, would be similar to the impacts under the No Action Alternative, 

except they would be extended by 1.6 years (for the South Hilight Field LBA 

Tract as applied for) up to as many as 22.8 years (for the West Jacobs Ranch 

LBA Tract under Alternative 2). 

Current techniques for blasting, coal removal, and coal processing would be 

expected to continue for a longer period of time than is shown in the applicant 

mines’ currently approved air quality permits. Material movement would 

continue to utilize direct cast blasting, draglines, and/or truck and shovel 

fleets for overburden and truck and shovel fleets and overland conveyors for 

coal. The applicant mines would not propose significant changes to the 

facilities shown in the current air quality permits or the blasting procedures or 

blast sizes if they acquire the tracts. However, when the mining permits are 

amended to include the new lease areas, the techniques proposed for coal and 

overburden removal, coal processing, and blasting processes would be reviewed 

and modified if necessary to incorporate the BACT protection measures that 

are in effect at that time. Overburden is generally thicker in the LBA tracts 

than the current lease areas; therefore, state of the art methods to minimize 

any increases in blast sizes and/or blasting agents will be employed. Thus, 

emissions from blasting are not expected to increase significantly, 

notwithstanding the increased thicknesses of overburden that would be 

excavated in these LBA tracts. 

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 North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and coal removal and related visibility 

impacts would not occur on the portions of the LBA tracts as applied for or the 

LBA tracts configured under Alternative 2 that will not be disturbed under the 

currently approve surface coal mining permits. Mining operations would 

continue as permitted on the existing Black Thunder, Jacobs Ranch, and North 

Antelope Rochelle Mine coal leases. Visibility impacts related to mining 

operations at these three applicant mines would not be extended onto portions 

of the LBA tracts that will not be affected under the mines’ current mining and 

reclamation plans. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective tract in the future. 
3.0 Affected Environment and Environmental Consequences 

3-96 Final EIS, Wright Area Coal Lease Applications 

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 Thunder Basin National Grasslands 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 impacts. The IMPROVE 

Steering Committee approved the incorporation of the TBNG 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 Network was recently 

supplemented with the development of a website on the Internet at 

http://www.wyvisnet.com/all.html to allow public access to real-time 

monitored visibility and air quality conditions (WDEQ/AQD 2009). 

3.4.4.2 Acidification of Lakes

The acidification of freshwater lakes and streams is caused by atmospheric 

deposition of acid pollutants (acid rain). According to EPA, SO2 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 

below a value of 7 on a scale of 1 to 14) when the water itself and its 

surrounding soil cannot buffer the acid rain enough to neutralize it. Lakes and 

streams that are generally regarded as acidified are typically very nutrient poor 

waters draining unreactive geology such as granitic mountainous areas. In 

areas where buffering capacity is low, acid rain also releases toxic metals such 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-97 

as aluminum from soils into lakes and streams. Both the lower pH and higher 

aluminum concentrations in surface water can cause damage to fish and many 

other species of aquatic organisms. The plants and animals living within an 

ecosystem are highly interdependent, and because of the connections between 

the organisms living in an aquatic ecosystem, changes in pH or aluminum 

levels affect biodiversity as well. Thus, as lakes and streams become more 

acidic, the numbers and types of fish and other aquatic plants and animals 

that live in these waters decrease. 

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 the state of New York, the midAppalachian 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 2005a). The USFS 

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 (EPA 2007b). 

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 an 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 

acid neutralizing capacity (ANC), measured in microequivalents per liter 

(μeq/L); the lake’s capacity to resist acidification from acid rain. The USFS 

considers lakes with ANC values between 25 and 100 μeq/L to be very sensitive 

to atmospheric deposition and lakes with ANC values less than or equal to 25 

μeq/L to be extremely sensitive to atmospheric deposition. Table 3-13 shows 

the existing ANC monitored in some mountain lakes and their distance from 

the general Wright analysis area. 

3.4.4.2.2 Environmental Consequences

3.4.4.2.2.1 Proposed Action and Alternatives 2 and 3

The North Hilight Field, South Hilight Field, and West Hilight Field LBA Tracts 

would be mined as integral parts of the Black Thunder Mine. The West Jacobs 

Ranch LBA Tract would be mined as an integral part of the Jacobs Ranch 

Mine. The North Porcupine and South Porcupine LBA Tracts would be mined 

as integrals part of the North Antelope Rochelle Mine. Therefore, the impacts
3.0 Affected Environment and Environmental Consequences 

3-98 Final EIS, Wright Area Coal Lease Applications 

Table 3-13. Existing Acid Neutralizing Capacity in Sensitive Lakes. 

Wilderness Area Lake 

Background ANC 

(μeq/L) 

Distance from 

General Wright 

Analysis Area 

(miles) 

Bridger Black Joe 69.0 203 

 Deep 61.0 204 

 Hobbs 68.0 222 

 Upper Frozen 5.81 204 

Cloud Peak Emerald 55.3 113 

 Florence 32.7 104 

Fitzpatrick Ross 61.4 218 

Popo Agie Lower Saddlebag 55.5 198 1 The background ANC is based on only six samples taken between 1997 and 2001. 

Source: Argonne (2002) 

to air quality from mining the LBA tracts have been inferred from the impacts 

at the currently permitted mining operations. 

The applicant mines anticipate that coal production would remain unchanged 

from the projected post-2008 levels if the LBA tracts are acquired. Impacts to 

air quality related to lake acidification under the Proposed Action or Alternative 

2, BLM’s preferred alternatives for each tract, would therefore be similar to the 

impacts under the No Action Alternative, except they would be extended by 1.6 

years (for the South Hilight Field LBA Tract as applied for) up to as many as 

22.8 years (for the West Jacobs Ranch LBA Tract under Alternative 2). 

The Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines would 

employ the best measures available to mitigate any potential emission 

increases associated with mining the LBA tracts. These would include, but 

would not necessarily be limited to, extension of overland conveyors to 

minimize haul distances and associated particulate and gaseous (i.e., nitrogen 

oxides, carbon oxides and sulfur dioxides) 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 North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and coal removal and the associated 

disturbance would not occur on the portions of the LBA tracts as applied for or 

the LBA tracts configured under Alternative 2 that will not be disturbed under 

the currently approved surface coal mining permits. Mining operations would 

continue as currently permitted on the existing Black Thunder, Jacobs Ranch, 

and North Antelope Rochelle Mine coal leases. Mining operations and 

associated emissions that contribute to the acidification of lakes would not be 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-99 

extended onto those portions of the LBA tracts that will not be affected under 

the mines’ current mining and reclamation plans. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective 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 contribute to the acidification of lakes, are discussed in Sections 3.4.2.3, 

3.4.3.3, and 3.4.4.1.3. Other air quality monitoring programs that are in place 

in the PRB include Wyoming Air Resources Monitoring System (WARMS) 

monitoring of sulfur and nitrogen concentrations near Buffalo, Sheridan, and 

Newcastle, and the National Atmospheric Deposition Program (NADP) 

monitoring of precipitation chemistry in Newcastle. The WDEQ/AQD’s 

Ambient Air Monitoring Annual Network Plan provides an overview of the 

number and types of air quality monitors AQD runs or oversees within the 

state of Wyoming, and is available for review on its website at: 

http://deq.state.wy.us/aqd/downloads/AirMonitor/Network%20Plan_2008.pdf

3.4.5 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

The general Wright analysis area contains three water-bearing geologic units 

that have been directly affected by existing mining activities and would be 

directly affected by mining the six LBA tracts. In descending order, these units 

are the recent alluvial deposits, the Wasatch Formation overburden, and the 

mineable coal seam(s) in the Tongue River Member of the Fort Union 

Formation, which is referred to as the Wyodak or Wyodak-Anderson. The 

underlying, sub-coal Fort Union Formation and the Lance-Fox Hills aquifer are 

utilized for water supply at the existing coal mines within the general Wright 

analysis area, but these units are not physically disturbed by mining activities. 

Both regional and site-specific baseline hydrogeologic environments within and 

around the general Wright analysis area are extensively characterized in the 

WDEQ/LQD mine permits for the three applicant mines included in this 

analysis (TBCC 2005, JRCC 2009, and PRC 2009). Figures 3-20, 3-21, and 3-

22 depict the locations of the groundwater monitoring wells that are actively 

being monitored by TBCC and PRC at the Black Thunder, Jacobs Ranch, and 

North Antelope Rochelle mines. Figure 3-2 presents the stratigraphic 
31

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1

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

Reno Road

Road Jacobs

State

Antelope

Edwards

Matheson Road

Reno Road

Hilight Road Hilight Road

Keeline Road

Highway 450

State

450 Highway

Road

Road

BNSF & UP RR

BNSF & UP RR

Shroyer

Road

Small Road

BMW-4-17

BMW-5-17

BMW-6-17

BMW-3-16

BTW-16

BTFU-20-1

BTA-26

17-1-LFH

BTW-26

BTA-28

BTA-25

BTA-27

BTA-22 BTA-12e

BTA-12f

BTB-27

BTB-28

BTA-24e

BTA-22A

BTB-6

BTB-5

BTFU-27-1

BTFU-17-2

BTB-3

BTB-22

BTB-23 BTB-24

BTW-1

BTW-29

BTR-28

BTW-17

BTR-160

BTW-19

BTR-158

BTR-159

BTR-1

BTFU-16-2

Water Supply Well

Monitoring Well

Completion Aquifer

Alluvium

Coal

Backfill

Overburden

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Black Thunder Mine Permit Boundary

Existing Black Thunder

Mine Federal Coal Leases

LEGEND

North Hilight Field LBA Tract as Applied for

North Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA Tract as Applied for

South Hilight Field LBA Tract as Applied for

South Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA Tract Under Alternative 3

West Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-20. Locations of Currently Active Groundwater Monitoring and Water Supply Wells at the Black

Thunder Mine.

3.0 Affected Environment and Environmental Consequences

3-100 Final EIS, Wright Area Coal Lease Applications
30

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28

34

27

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26

36 31 32

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27

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36 31

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26

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T.

45

N.

T.

44

N.

T.

44

N.

T.

43

N.

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

T.

45

N.

T.

44

N.

T.

44

N.

T.

43

N.

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

Keeline

Road Jacobs

Small BNSF & UP RR

Hilight Road Hilight Road

Road

Keeline Road

Road

Road

State

450 Highway

BNSF & UP RR

State Highway 450

Shroyer

JRM #18

JRM #19

JRM-29-2W40

JRM-26-2W41

JRM-19-2W40

JRM-21-2W40 JRM-21-1C40

JRM-7-1R

JRM-12-1R

JRM-7-2K

JRM-10-1R JRM-12-3K

JRM-11-1R

JRM-8

JRM-15-2R

JRM-11-2K

JRM #3

JRM #16

JRM #17

0 5000 10000 20000

GRAPHIC SCALE (FEET)

LEGEND

Existing Jacobs Ranch Mine

Federal Coal Leases

Jacobs Ranch Mine Permit Boundary

West Jacobs Ranch LBA Tract as Applied for

West Jacobs Ranch LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Water Supply Well

Monitoring Well

Completion Aquifer

Coal

Overburden Backfill

Clinker

Coal/Underburden

Figure 3-21. Locations of Currently Active Groundwater Monitoring and Water Supply Wells at the Jacobs

Ranch Mine.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-101
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8

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8 9

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10

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2 1

T.

42

N.

T.

41

N.

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

Converse County

Campbell County

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

T.

42

N.

T.

41

N.

Reno Road

Mackey

Antelope

Edwards Reno Road

School Creek

Hilight

Road

Road Road Road

Antelope Road

Road

BNSF & UP RR

Matheson Road

Mackey Road

MathesonRoad

T.

41

N.

T.

40

N.

T.

41

N.

T.

40

N.

PRCC-21B

PRCC-6B

PRCC-7C

PRCC-20B

PRCC-8E

PRCC-22B

PRCC-5B

NA-60A

NA-61B

NA-62A

SP-15-NA

DOW-108

SOW-107

DOW-110

SOW-109

PRCC-29B

PRCC-29A

PRCC-29C NA-65A

DOW-3B

NA-63B

PRCC-30 PRCC-31

SOW-3B

AW-31

AW-62

NA-33

DOW-118 SOW-117

SP-5-NA

SP-11-NA

SP-6-NA

AW-59 SP-10-NA

SP-1-NA

SP-3-NA

SP-4-NA SP-17-NA

SP-12-NA SP-16-NA

SP-14-NA

SP-13-NA

SP-18-NA SP-6-R

SP-3-R

R-9

R-23

R-3P

R-22

SP-8-R R-2U R-21

SP-7-R

R-41

R-4

R-35

R-32

R-1A

R-36

R-17

R-20

R-12A

R-14

R-40

R-11

R-37 R-38

R-10A

PRCC-3

SOW-7A

SOW-8A

SOW-5A

SOW-6A

PRCC-4B

PRCC-1F

SP-25-NA

SP-23-NA

SP-22-NA

SP-24-NA

SP-21-NA

SP-20-NA

SP-12-U

SP-9-R

SP-10-R

SP-19-NA

PRCC-5C

PRCC-6C

PRCC-8D

R-11A

R-12

R-10C

R-10U

R-3

SP-2-NA

NA-61A

NA-62B

NA-65B

NARC#4

201

RCC#1

RCC#2

NARC#22

NARC#24

NARC#5

0 5000 10000 20000

GRAPHIC SCALE (FEET)

LEGEND

Water Supply Well

Monitoring Well

Completion Aquifer

Alluvium

Coal

Backfill

Underburden

Overburden

Clinker

Existing North Antelope Rochelle

Mine Federal Coal Leases

North Antelope Rochelle Mine Permit Boundary

North Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

North Porcupine LBA Tract as Applied for

South Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

South Porcupine LBA Tract as Applied for

Figure 3-22. Locations of Currently Active Groundwater Monitoring and Water Supply Wells at the North

Antelope Rochelle Mine.

3.0 Affected Environment and Environmental Consequences

3-102 Final EIS, Wright Area Coal Lease Applications
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-103 

relationships and hydrologic characteristics of the units underlying the general 

Wright analysis area. 

3.5.1.1.1 Recent Alluvium

Alluvial (unconsolidated stream laid) deposits will form localized aquifers where 

they are extensive enough and provided they receive recharge from 

precipitation infiltration, surface water flows, or in some cases, discharge from 

the adjacent overburden. Alluvial groundwater flow is typically in the same 

direction as the surface drainage. Discharge is typically to the surface, to the 

adjacent overburden sediments, or to evapotranspiration (Ogle and Calle 2006). 

Within the general Wright analysis area, alluvial deposits are present and 

primarily occupy the valleys of the larger drainages, namely Little Thunder 

Creek, North Prong Little Thunder Creek, and Porcupine Creek. Less extensive 

alluvial deposits are also found along the lower reaches of the tributaries to 

these larger streams. The alluvial, colluvial, sheetwash and playa deposits 

associated with minor surface drainages are typically very thin and not 

laterally extensive enough to be considered aquifers. In addition, these less 

extensive unconsolidated stream laid deposits are generally very fine-grained 

and have very limited permeabilities, precluding any significant storage and 

movement of groundwater. Alluvial groundwater quality in this area is highly 

variable spatially and generally poor but suitable for livestock and wildlife use. 

However, the concentrations of individual constituents may exceed livestock 

use standards at some locations. Based on the analyses of 793 alluvial 

groundwater samples collected in the southern PRB, the median concentration 

of total dissolved solids (TDS) was 2,110 milligrams per liter (mg/L) and the 

predominant chemical constituents were calcium and sulfate, although 

significant quantities of sodium, magnesium and bicarbonate were also present 

(Ogle and Calle 2006). 

Within the BLM study area for the North Hilight Field LBA Tract, alluvial 

deposits are associated primarily with Springen Draw, a relatively large closed 

basin (over 8,000 acres in size) into which several ephemeral draws drain. 

These unconsolidated stream laid deposits have been mapped by the U.S. 

Geological Survey (USGS) as overbank, fan, apron and sheetwash deposits, and 

consist of intermixed silt and sand locally interbedded with thin clay or gravel 

lenses ranging from about 1.0 to 10.0 feet thick (Reheis and Coates 1987, 

Moore and Coates 1978, Coates 1977). No aquifer tests have been conducted 

in the alluvial deposits that occur within the BLM study area for the North 

Hilight Field LBA Tract due to the minimal saturated thickness and low 

transmissivity of the deposits. Based on the comparison of soil texture and 

type with permeability values presented in the literature (Cedergren 1977), the 

average hydraulic conductivity for the valley fill stream laid deposits and 

colluvium is estimated to range from 0.2 to 20 feet per day (ft/day). Hydraulic 

conductivity values compiled from all alluvial aquifer tests conducted by the 

Black Thunder, North Antelope Rochelle, and Antelope mines range from 0.035 

ft/day to 136.5 ft/day, with the median value of 3.8 ft/day, which is 
3.0 Affected Environment and Environmental Consequences 

3-104 Final EIS, Wright Area Coal Lease Applications 

comparable to that of silty sand (Ogle and Calle 2006). Available water quality 

data from the Black Thunder Mine’s alluvial monitoring wells (Figure 3-20) 

indicate that groundwater from the valley fill deposits of North Prong Little 

Thunder Creek and Mills Draw is generally of poor quality and does not meet 

all of the WDEQ Water Quality Division (WQD) standards (WDEQ/WQD 2009) 

for domestic and agricultural uses and is marginal for livestock and wildlife use 

(TBCC 2005). 

Within the BLM study area for the South Hilight Field LBA Tract, alluvial 

deposits are associated with only Little Thunder Creek, an ephemeral tributary 

of Black Thunder Creek. These unconsolidated stream laid deposits have been 

mapped by the USGS as stream-channel and overbank deposits, and they 

consist of intermixed silt and sand locally interbedded with thin clay or gravel 

lenses and range from about 1.0 to 10.0 feet thick (Reheis and Coates 1987, 

Moore and Coates 1978, Coates 1977, Coates 1978a). No aquifer tests have 

been conducted in the valley fill deposits that occur within the BLM study area 

for the South Hilight Field LBA Tract due to the minimal saturated thickness 

and low transmissivity of the deposits. Available water quality data indicate 

that groundwater from the valley fill deposits of Little Thunder Creek and North 

Prong Little Thunder Creek does not meet the WDEQ/WQD standards for 

domestic and agricultural uses and is marginal or fails to meet the standards 

for livestock and wildlife use , depending on the location (TBCC 2005). 

Within the BLM study area for the West Hilight Field LBA Tract, alluvial 

deposits are primarily associated with Little Thunder Creek. These 

unconsolidated stream laid deposits have been mapped by the USGS as 

stream-channel and overbank deposits, and they consist of intermixed silt and 

sand locally interbedded with thin clay or gravel lenses and range from about 

1.0 to 10.0 feet thick (Reheis and Coates 1987, Moore and Coates 1978, Coates 

1978a). Lesser quantities of alluvial, colluvial, sheetwash, and playa deposits 

are also associated with tributaries to Little Thunder Creek (e.g., Black Butte 

Draw and Briggs Draw), Dry Fork Little Thunder Creek, and numerous 

internally-drained playas (e.g., Rochelle Lake) that occur in the area. No 

aquifer tests have been conducted in the alluvial deposits that occur within the 

BLM study area for the West Hilight Field LBA Tract due to the minimal 

saturated thickness and low transmissivity of the deposits. Likewise, alluvial 

groundwater quality data are not available for this area, although a general 

description of Little Thunder Creek’s alluvial groundwater quality is given 

above. 

Within the BLM study area for the West Jacobs Ranch LBA Tract, the recent 

alluvium exhibiting any potential of yielding groundwater is limited to those 

unconsolidated stream laid deposits associated with the larger streams (all of 

which are ephemeral) that drain this area. Surficial geology mapping by JRCC 

(1994) and the USGS (Reheis and Coates 1987, Coates 1978a and 1978b) 

shows that the only alluvial deposits within the LBA tract’s general analysis 

area occur along the channels of Dry Fork Little Thunder Creek and its 

tributary, Brater Draw. These alluvial deposits consist of intermixed silt and 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-105 

sand locally interbedded with thin clay or gravel lenses and range from about 

1.0 to 10.0 feet thick. Groundwater occurrence in the alluvium is generally 

unknown in this area, but some limited occurrence may be expected as bank 

storage from ephemeral stream flows. No aquifer tests have been conducted in 

the alluvial deposits that occur within the BLM study area for the West Jacobs 

Ranch LBA Tract, but tests conducted by TBCC on North Prong Little Thunder 

Creek alluvial monitoring wells located downstream of the LBA tract revealed 

hydraulic conductivity values ranging from 0.52 to 6.42 ft/day (TBCC 2005). 

Water quality samples collected from North Prong Little Thunder Creek alluvial 

monitoring wells located in the existing Black Thunder Mine permit area 

exhibit an average TDS concentration of 1,600 mg/L, which is suitable for 

agricultural and livestock use. 

The BLM study area for the North Porcupine LBA Tract is drained by Porcupine 

Creek and its tributaries, all of which are ephemeral streams. The most 

significant alluvial aquifer in the general Wright analysis area is that associated 

with Porcupine Creek. The valley floor of Porcupine Creek contains appreciable 

amounts of alluvium both in width and depth, and the alluvial deposits contain 

more coarse material than the other smaller ephemeral streams that drain 

most of the general Wright analysis area. Downstream of the North Porcupine 

tract, where the stream has been disturbed by the North Antelope Rochelle 

Mine, the alluvium was up to 1,000 feet wide, up to 12 feet thick, and 

composed primarily of coarse-grained sand (BLM 1998). Mapping of the 

surficial geology within the LBA tract’s general analysis area shows that 

alluvial deposits occur along the channels of Porcupine Creek and its 

tributaries, Gray Creek and Rat Draw (Reheis and Coates 1987, PRC 2009). 

These materials are comprised of stream-channel and overbank deposits of 

sand and silt interbedded with gravel lenses. Isolated, thin deposits of 

sheetwash alluvium consisting of sands, silts, and clays also occur in areas of 

unchanneled flow on hillslopes and in depressions. Studies conducted by PRC 

on the alluvium of Porcupine and Corder creeks downstream of the North 

Porcupine tract indicate that the hydraulic conductivity of Porcupine Creek 

alluvium is variable, ranging from 1.1 to 13.0 ft/day (BLM 1998). The 

Porcupine Creek alluvial aquifer receives recharge from the infiltration of 

precipitation, from the lateral movement of groundwater that discharges from 

the adjacent Wasatch Formation overburden, and from the infiltration of 

surface flow within the stream channel. Lesser quantities of colluvial, 

sheetwash, and playa deposits associated with other smaller drainages and 

internally-drained basins in the area also occur, but these materials are 

generally thin, fine grained, and not laterally extensive enough to store or yield 

groundwater. The quality of Porcupine Creek alluvial groundwater is generally 

suitable for livestock and wildlife use, but the concentration of sulfate typically 

exceeds the agricultural use standard. The TDS concentrations of water 

quality samples collected by the North Antelope Rochelle Mine downstream of 

the LBA tract range from about 1,000 mg/L to 37,000 mg/L with an average of 

approximately 5,350 mg/L (Ogle and Calle 2006). 
3.0 Affected Environment and Environmental Consequences 

3-106 Final EIS, Wright Area Coal Lease Applications 

The South Porcupine LBA Tract’s general analysis area is drained by minor 

tributaries of Porcupine Creek, Horse Creek, and Antelope Creek. Mapping of 

the surficial geology within the tract’s general analysis area (Reheis and Coates 

1987, PRC 2009) shows that some alluvial deposits occur only along Mike’s 

Draw, a north-flowing, third order ephemeral tributary of Porcupine Creek. 

These recent alluvial deposits are comprised of stream-channel and overbank 

deposits of sand and silt. Because the thickness and areal extent of these 

materials are very limited, and they infrequently receive recharge from the 

infiltration of precipitation and surface flow within the stream channel, they do 

not yield groundwater. 

3.5.1.1.2 Wasatch Formation

Within the PRB, the Wasatch Formation (the strata lying above the mineable 

coal, also called the overburden) consists of various non-marine, fluvial and 

eolian deposits of interbedded sands, silts, and clays with occasional 

discontinuous deposits of coal and carbonaceous material. The Wasatch strata 

range in cohesion from unconsolidated (i.e., loose sands and silts) to lithified 

(i.e., sandstones, siltstones, shales, and coal stringers). Any of the deposits 

may be water bearing, although the sands and sandstones possess a greater, 

but laterally limited, potential for groundwater yield. These sands are generally 

discontinuous and separated laterally and vertically by finer-grained silts and 

clays. Perched groundwater can occur locally within the surficial deposits of 

Wasatch residuum and Wasatch-derived eolian deposits that overlie an 

impermeable stratum. This basic description generally holds true for all of the 

general Wright analysis area. 

The discontinuous nature of the sediments produces considerable variability in 

the occurrence of groundwater in the overburden both laterally and vertically. 

The hydraulic connection between water-bearing units is tenuous due to 

intervening shale aquitards; thus, groundwater movement through the 

Wasatch Formation overburden is limited. Due to the discontinuous nature of 

the permeable overburden sediments, premine overburden groundwater 

movement generally follows the topography. Because the water-bearing units 

within the Wasatch Formation are not continuous, the Wasatch is not 

considered to be a regional aquifer. However, Wasatch sands and sandstones 

do provide limited amounts of groundwater for livestock and domestic uses on 

a local scale, provided the water quality is suitable. Channel deposits of 

unconsolidated sand (paleochannel sands) with up to about 60 feet of 

saturation occasionally occur in the Wasatch overburden, and wells developed 

in these sands may individually yield up to 50 gallons per minute (gpm). 

Paleochannels are typically less than 500 feet wide and are isolated laterally 

and vertically by silt and clay deposits of very low permeabilities. 

Another geologic unit that may be considered a part of the Wasatch Formation 

is clinker, also called scoria or burn. It consists of sediments that were baked, 

fused, and melted in place when the underlying coal burned (via range fire, 

lightening or spontaneous combustion). These baked sediments collapsed into 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-107 

the void left by the burned coal. Clinker deposits can be a very permeable 

aquifer and can extend laterally for miles in the eastern PRB. The occurrence 

of clinker is site specific, typically occurring in areas where coal seams crop out 

at the surface. The hydrologic function of clinker includes providing infiltration 

of precipitation and recharge to laterally contiguous overburden and coal beds. 

The West Jacobs Ranch LBA Tract is the only tract included in this analysis 

that contains clinker deposits; however, the outcrops in Sections 21 and 31 of 

T.44N., R.71W. are erosionally isolated, small in areal extent, and not 

documented as aquifers or a significant source of recharge. 

Recharge to the Wasatch Formation is from the infiltration of precipitation, 

infiltration of surface water stored in playas and in-channel reservoirs, 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 drainage into mine excavations, and by 

seepage into the alluvium along stream courses. Overburden groundwater is 

not generally connected to the underlying Wyodak coal seam due to a lowpermeability stratum at the base of the overburden, which is fairly widespread 

in the general Wright analysis area. However, there is some leakage between 

the aquifers that provides vertical recharge to the coal aquifer. 

For the Wasatch Formation as a whole in the PRB, the discontinuous nature of 

the water bearing units results in low overall hydraulic conductivity and low 

groundwater flow rates. Groundwater encountered in the Wasatch overburden 

is usually unconfined or perched, and water levels generally vary from 10 to 

over 100 feet below the ground surface (Ogle and Calle 2006). The 

overburden’s hydraulic properties are variable due to the varied nature of the 

stratigraphic units, although the hydraulic conductivity is relatively low. 

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 conducted near the PRB coal mines was 0.2 

ft/day. Fifty-nine overburden monitoring wells located in the permit areas of 

the mines in the general Wright analysis area have been aquifer tested and the 

hydraulic conductivity values ranged from 0.001 ft/day to 27.0 ft/day with a 

the median of 0.11 ft/day. 

The quality of groundwater in the Wasatch Formation is extremely variable and 

generally poor. In the general Wright analysis area, TDS concentrations range 

from 500 mg/L to 6,157 mg/L and the water type is typically a sodium-sulfate. 

Based on the analyses of over 1,000 water quality samples collected by the 

southern PRB coal mines, including the three applicant mines, the median TDS 

concentration was 2,000 mg/L and the predominant constituents were sodium 

and sulfate (Ogle and Calle 2006). Overburden groundwater is considered to 

be unsuitable for domestic and irrigation uses, but is generally suitable for 

livestock and wildlife use although, at some locations, concentrations of 

individual constituents may exceed livestock standards. 
3.0 Affected Environment and Environmental Consequences 

3-108 Final EIS, Wright Area Coal Lease Applications 

3.5.1.1.3 Wyodak/Wyodak-Anderson Coal

The Tongue River Member of the Fort Union Formation contains the mineable 

coal zone, which is often divided by partings that separate it into two or more 

units. Operators of the mines in the general Wright analysis area refer to the 

mineable coal zone as either the Wyodak (Upper Wyodak, Middle Wyodak and 

Lower Wyodak) or the Wyodak-Anderson. A general discussion of the coal 

seam aquifer is presented as follows. 

The Wyodak coal seam is considered to be a regional aquifer because of its 

water bearing properties and it is laterally continuous throughout the area. 

Historically, the Fort Union coal seams have been a source of groundwater for 

domestic and livestock uses in the eastern PRB. However, due to the westnorthwest dip of the coal beds, the coal generally becomes too deep to be an 

economical source of water within a couple of miles west of the PRB surface 

coal mines. 

Hydraulic conductivity within the Wyodak coal seam is highly variable and 

reflective of the amount of fracturing the coal has undergone, as non-fractured 

coal is virtually impermeable. Field aquifer tests indicate that the coal has a 

low to moderate transmissivity with a range of roughly three orders of 

magnitude. The yield of groundwater to wells and mine pits is smallest where 

the permeability of the coal is derived primarily from localized unloading 

fractures. These fractures, which are the most common, are created by the 

expansion of the coal as the weight of overlying sediments is slowly removed by 

erosion. Localized zones of moderately high transmissivity occur due to 

increased fracturing, and the highest permeability is imparted to the coal by 

tectonic fractures. These are through-going fractures of areal importance 

created during deformation of the 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. For example, aquifer testing conducted by PRC 

within North Antelope Rochelle Mine’s permit area indicates that the coal 

possesses higher permeability in a northwest-southeast direction. 

Field aquifer tests conducted by the southern group of PRB mines (Jacobs 

Ranch, Black Thunder, North Rochelle, North Antelope Rochelle, and Antelope) 

were examined by WDEQ/LQD (Ogle and Calle 2006) and the hydraulic 

conductivities of the coal ranged from 0.005 ft/day to 1,167 ft/day; the 

variability most likely due to the fractured nature of the coal. The median 

hydraulic conductivity of the coal aquifer based on 101 aquifer tests is 1.8 

ft/day, and the median storage coefficient is 5.8×10–4, indicative of a confined 

aquifer. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-109 

Recharge to the coal occurs principally by infiltration of precipitation in the 

clinker outcrop areas along the flank of the eastern Powder River structural 

basin. Vertical recharge from the overburden also occurs, but is highly 

variable. Prior to mining, the direction of groundwater flow within the areally 

continuous coal aquifer was generally from recharge areas at the coal seam’s 

outcrop westward into the PRB, following the dip of the coal. Groundwater 

conditions varied from unconfined to confined, depending on the coal elevation 

and proximity to the outcrop area. Water levels were generally above the top of 

the coal away from the outcrop. 

Site-specific water-level data collected from coal monitoring wells by mining 

companies and the BLM in the general Wright analysis area and presented in 

the Gillette Area Groundwater Monitoring Organization (GAGMO) 25-year 

report (Hydro-Engineering 2007) indicate that the groundwater flow directions 

in the Wyodak coal have been greatly influenced by surface mine dewatering 

and groundwater discharge associated with CBNG development. Groundwater 

levels observed near active mining areas prior to 1997 were likely due to mine 

dewatering alone and the groundwater flow direction within the coal aquifer 

was typically toward the mine pits. By year 2000, groundwater level decline 

rates had dramatically increased because drawdown caused by widespread 

CBNG development west of the mines was overlapping with drawdown caused 

by mining operations. A continuous cone of depression currently exists around 

the Jacobs Ranch, Black Thunder, North Antelope Rochelle and Antelope 

mines due to their proximity to each other and the cumulative drawdown 

effects from pit dewatering and nearby CBNG development. The extent of 

drawdown west of the mines that is specifically attributable to mine dewatering 

alone can no longer be directly defined due to much greater and areally 

extensive drawdown caused by CBNG development. Roughly 30 years of 

surface mining and the more recent CBNG development have resulted in 

complete dewatering of the coal aquifer in localized areas, particularly near the 

mines’ pits and where the coal seams are structurally highest. 

In general, the water in the Wyodak coal aquifer is suitable only for livestock 

and wildlife use (WDEQ/WQD Class III). Certain constituent concentrations, 

such as TDS, sulfate, iron and manganese, commonly exceed the domestic use 

(Class I) standards, while the sodium-adsorption ratio (SAR) and TDS and 

sulfate concentrations commonly exceed the agricultural use (Class II) 

standards (WDEQ/WQD 2009). Within the general Wright analysis area, 

Wyodak coal groundwater quality is generally poor, but exhibits lower TDS 

concentrations than alluvial or overburden groundwater. The composition of 

groundwater in the coal is fairly uniform and there are no seasonal or longterm trends in composition. The composition of groundwater in the coal 

aquifer is generally characterized as a calcium/magnesium-sulfate type near 

the clinker outcrop recharge areas and transitions to a sodium-bicarbonate 

type as the groundwater moves downgradient. A median TDS concentration of 

952 mg/L was calculated by the WDEQ/LQD for the coal aquifer, based on 832 

samples collected from the southern group of PRB mines (Ogle and Calle 2006). 
3.0 Affected Environment and Environmental Consequences 

3-110 Final EIS, Wright Area Coal Lease Applications 

3.5.1.1.4 Subcoal Fort Union Formation

The Fort Union Formation is divided into three members, which are, in 

descending order: the Tongue River Member, the Lebo Member, and the Tullock 

Member. The mineable coal seams occur within the Tongue River Member. 

The subcoal Fort Union Formation consists primarily of lithified sands and 

shales, and is divided into three hydrogeologic units: the upper Tongue River 

aquifer, the Lebo confining layer, and the Tullock aquifer (Law 1976). Of the 

three units, the Tullock is the most prolific in terms of groundwater yield. 

Mining does not directly disturb the hydrogeologic units below the mineable 

coal, but many PRB mines use them for industrial water supply wells. In a few 

cases there have been drawdowns in the subcoal aquifer due to leakage into 

mine pits, dewatering, and CBNG development (BLM 2001). The upper Tongue 

River aquifer consists of lenticular, fine-grained sandstone interbedded with 

mudstone. The Lebo confining layer is typically more fine-grained than the 

other two members and generally retards the movement of water (Lewis and 

Hotchkiss 1981). The Lebo confining layer typically separates the Tongue River 

and Tullock aquifers hydraulically. The Tullock aquifer consists of 

discontinuous lenses of sandstone separated by interbedded shale and 

siltstone. 

Transmissivity is equal to an aquifer’s hydraulic conductivity, or permeability, 

times the aquifer’s saturated thickness, and is commonly used when 

discussing the hydraulic properties of the subcoal Fort Union Formation where 

wells are completed by exposing many discrete sand lenses to the well bore. 

Transmissivities are generally higher in the deeper Tullock aquifer than in the 

shallower Tongue River aquifer, and many mines in the PRB have water-supply 

wells completed in this interval (Martin et al. 1988). The city of Gillette and the 

town of Wright also utilize the Tullock aquifer to meet part of their municipal 

water requirements. The average transmissivity for the Tullock, as reported by 

OSM (1984), is 290 ft2/day. The three applicant mines located within the 

general Wright analysis area use a total of 15 wells completed in the subcoal 

Fort Union Formation for water supply, and they range in depth from 

approximately 250 feet to 3,200 feet. 

The water quality of the subcoal Fort Union Formation is generally good. TDS 

concentrations measured in various subcoal Fort Union Formation water 

supply wells in the eastern PRB range from 230 mg/L to 520 mg/L. Water 

from the subcoal Fort Union Formation is typically of the sodium-bicarbonate 

type. This water is generally suitable for livestock and wildlife watering and 

may be suitable for domestic use. Depending upon site-specific TDS 

concentrations and SAR values, groundwater from Fort Union Formation 

supply wells may also be suitable for irrigation. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-111 

3.5.1.1.5 Lance Formation-Fox Hills Sandstone

Underlying the Fort Union Formation is the Lance Formation of Cretaceous 

age. The Lance Formation is comprised of an upper confining layer and a lower 

aquifer. Individual sandstone beds of the lower aquifer sequence are up to 

about 100 feet thick, are fine-grained, and contain variable amounts of 

interbedded clay and silt. The Fox Hills Sandstone underlies the Lance 

Formation and is usually difficult to distinguish from the Lance. The Fox Hills 

is described as well-developed, fine- to medium-grained, marine sandstone that 

contains thin beds of sandy shale and probably averages around 250 feet thick 

beneath the general Wright analysis area. 

The lower Lance Formation and Fox Hills sandstone, which is called the LanceFox Hills aquifer in the eastern PRB, is used for an industrial water supply at 

the North Antelope Rochelle and Black Thunder mines. North Antelope 

Rochelle Mine’s two Lance-Fox Hills wells are approximately 5,400 feet deep 

and Black Thunder Mine’s well is 4,850 feet deep. The city of Gillette also 

utilizes the Lance-Fox Hills aquifer to meet part of its municipal water 

requirements, as do the Wyodak Power Plant and various other eastern PRB 

surface coal mines. The quality of groundwater from the Lance-Fox Hills 

aquifer is generally good enough to meet the standards for domestic use, 

depending upon the concentrations of TDS and various constituents such as 

fluoride. Sodium and bicarbonate are typically the predominant ionic 

constituents. 

3.5.1.2 Environmental Consequences

3.5.1.2.1 Proposed Action and Alternatives 2 and 3

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 North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs 

Ranch, North Porcupine, and South Porcupine LBA Tracts are leased under the 

Proposed Actions or Alternatives 2 or 3 and mined, the overall regional extent 

of coal removal and reclamation would increase, which would result in an 

increase in the area of impacts to groundwater quantity. As mining expands, 

additional water-bearing bedrock strata would be exposed and groundwater 

would drain by gravity into the active pits. The overburden and coal aquifers 

within the leased tracts would be completely dewatered and removed, and the 

area of drawdown caused by overburden and coal removal would be extended 

further to the northwest, west and southwest of the active mine areas. The 

extent that drawdown would propagate away from the mine pits is primarily a 

function of the affected aquifer’s hydraulic properties (i.e., hydraulic 
3.0 Affected Environment and Environmental Consequences 

3-112 Final EIS, Wright Area Coal Lease Applications 

conductivity, storativity, and current saturated thickness). While there are 

variations in the affected aquifers’ hydraulic properties, duration of time that 

the pits would be open, distance from the open pits, and CBNG development 

(intensity and duration) in the vicinity of mining, the area subject to lower 

groundwater levels would be extended roughly in proportion to the increase in 

areas affected by mining. The amount and extent of additional drawdown may 

not be significant however, as current drawdown associated with mining the 

existing leases combined with drawdown associated with CBNG development 

has nearly dewatered the coal aquifer within and immediately west of the 

general Wright analysis area. 

Currently approved mining will continue to remove the overburden, 

interburden (where present), and coal on the existing leases at the Black 

Thunder, Jacobs Ranch, and North Antelope Rochelle mines and replace these 

separate units with backfill material composed of an unlayered, relatively 

homogeneous mixture of the shale, siltstone, and sandstone that makes up the 

existing Wasatch Formation overburden and Fort Union Formation interburden 

(if present). The applicant mines’ existing leases currently include 

approximately 49,086.9 acres. Mining each of the LBA tracts as maintenance 

leases would extend the area of overburden and coal removal by about 21,887 

acres under the Proposed Actions up to about 36,264 acres under BLM’s 

preferred tract configurations for Alternative 2. 

The 25-year GAGMO Report (Hydro-Engineering 2007) presents drawdowns 

that have developed in the last 25 years as a result of coal mining activity or 

other stresses to the groundwater system. The 25-year drawdown map for the 

general Wright analysis area is included within the 25-year GAGMO Report, 

and it shows a continuous cone of depression exists around the southern 

group of mines (Black Thunder, Jacobs Ranch, North Antelope Rochelle, and 

Antelope) due to their proximity to each other and due to the large drawdowns 

caused to the west by CBNG development. The cumulative coal mine 

dewatering drawdown caused by the southern group of mines overlaps west of 

the mines with drawdown caused by CBNG development. Hydro-Engineering 

(2007) states that the extent of drawdown west of the mines caused by mining 

alone can no longer be directly defined due to the much greater drawdown 

caused by CBNG development. The present drawdown of the Wyodak coal 

potentiometric surface has made the comparison between the 25-year 

drawdowns and the modeled groundwater drawdown predictions using the 

conservative, worst-case scenario for each mine to be unrealistic. Drawdowns 

in all areas have greatly increased in the last few years due to water production 

from the coal aquifer by CBNG production. Overlapping impacts of the existing 

mining activities with other existing and proposed activities are addressed 

further in Chapter 4 of this EIS. 

Due to the inconsistent lithologic makeup of the Wasatch Formation 

overburden (discontinuous sandstone and sand lenses in a matrix of siltstone 

and shale), drawdowns in the overburden are variable and do not extend great 

distances (generally less than 1⁄2 mile) from the active mine pits. Due to the 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-113 

varied nature of the water-bearing units within the Wasatch Formation 

overburden, the extent of water level drawdowns are variable as well. Water 

level drawdowns propagate much farther and in a more consistent manner in 

the coal seam aquifers than in the overburden due to the regional continuity 

and higher transmissivity of the coal seam. Prior to CBNG development, 

drawdown in the coal aquifer was primarily a function of distance from the 

mine’s open pit, although geologic and hydrologic barriers and boundaries 

such as crop lines, fracture zones, and recharge sources can also influence 

drawdowns. As discussed below, each mine evaluated groundwater level 

drawdowns resulting from their existing operations based on site-specific 

characteristics such as hydraulic conductivity, mining sequence, and local 

geology. Mines usually model groundwater level drawdown using the 

conservative, worst-case scenario. Therefore, it is unlikely that the actual 

drawdown will extend as far from the mine pits as predicted. It is also difficult 

to predict the time for groundwater recovery since each mine uses different 

predictive modeling techniques and assumptions, and reports different 

recovery time periods. In general, and excluding the dewatering and drawdown 

effects associated with CBNG development, drawdown in groundwater levels in 

both the coal and overburden that are associated with mining alone are 

greatest immediately adjacent to the mine pits and decrease with distance from 

the pits (Ogle and Calle 2006). 

The subcoal aquifers (i.e., Tullock Member of the Fort Union Formation and 

Lance-Fox Hills aquifer) are not removed or disturbed by mining, so they are 

not directly impacted by coal mining activity. All three of the applicant mines 

located within the general Wright analysis area utilize water supply wells 

completed in aquifers stratigraphically below the Wyodak coal. If these six LBA 

tracts are leased and mined by the applicants, water would be produced from 

these wells for a longer period of time but the mines do not anticipate requiring 

additional sub-coal wells for industrial water supply to continue mining and 

reclaiming, including the LBA tracts. 

As noted above, the existing layers of sediment and rock in the area of coal 

removal would be replaced by generally homogeneous, unconsolidated backfill 

material, which would recover as a single hydrostratigraphic unit. The backfill 

unit created in the LBA tract areas would be in hydraulic communication with 

contiguous undisturbed coal, overburden, and the existing backfill aquifer 

units. Mining would not disturb premining recharge areas. 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 swelling of the mined strata attendant with excavating the 

strata, and due to generally flatter postmining topography resulting in less 

surface runoff. Water levels in the affected aquifers would remain depressed 

below premining levels for a long period of time, since groundwater discharge 

rates from the affected aquifers into the proposed mine pits are expected to be 

low. Groundwater levels are projected to recover to near pre-mining and preCBNG development levels once these industrial uses of groundwater have 

ceased. Backfill material would gradually resaturate and eventually discharge 
3.0 Affected Environment and Environmental Consequences 

3-114 Final EIS, Wright Area Coal Lease Applications 

downgradient to hydrostratigraphic units contiguous to the backfilled pit; at 

which time, groundwater levels and flow patterns are expected to be similar to 

premining conditions. Groundwater flow through the backfill and undisturbed 

bedrock near the pits would be interrupted until saturation levels in the 

backfilled pits have increased, and the rates of recharge to and discharge from 

the backfill have equilibrated. Backfill in the PRB can take anywhere from 50 

to 200 years to resaturate (Hydro-Engineering 2001). The rate at which the 

mine backfill resaturates and the postmining potentiometric surfaces reach 

equilibrium is dependent upon the hydraulic conductivity of the backfill, 

sources of recharge water, and groundwater flow rates in the adjacent aquifers. 

The hydraulic properties of the backfill aquifer based on the results of aquifer 

testing at mines in the PRB are quite variable, although generally equal to or 

greater than the undisturbed overburden and coal aquifers (Van Voast et al. 

1978 and Rahn 1976). It is early in the process of full reclamation and to date, 

not all of the backfilled materials have reached an adequate saturated 

thickness to be aquifer tested at the three applicant mines in the general 

Wright analysis area. The composition of the backfilled overburden materials 

at these three adjacent mines is quite similar; therefore, the hydraulic 

characteristics of the backfill at these three mines are also expected to be 

similar. Hydraulic conductivity values measured in existing monitoring wells 

completed in the saturated backfill at the Black Thunder, Jacobs Ranch, and 

North Antelope Rochelle mines range from 0.12 ft/day to 90.0 ft/day (TBCC 

2005, JRC 2009, PRC 2009, and Ogle and Calle 2006), which is comparable to 

the reported hydraulic conductivity values determined for the Wasatch 

overburden and Wyodak coal seam. These data therefore provide an indication 

that the backfill would readily resaturate as postmining potentiometric 

elevations recover in the surrounding undisturbed aquifers, and that wells 

completed in the backfill (including in these six LBA tracts) would be capable of 

supplying sufficient yields to wells constructed for livestock watering uses. 

Mining and reclamation also impacts groundwater quality; the TDS 

concentration in the water resaturating the backfill is generally higher than the 

TDS concentration in groundwater from the overburden and coal seam aquifers 

prior to mining. This is due to the increased porosity and exposure of fresh 

mineral surfaces to groundwater that moves through the backfill and increased 

oxidation. Scientific tests in the laboratory and in the field show the 

predominant cause for high dissolved-solids contents in mine backfill is the 

availability of highly soluble salts in the overburden sediments. The soluble 

salts that are exposed to groundwater are readily mobilized; therefore, 

groundwater quality in recently backfilled mine pits is highly diverse due to the 

variable distribution of soluble salts and the variable permeability of the 

backfill. As the backfill is resaturated and groundwater flow patterns are 

reestablished, the soluble salts are leached by groundwater flow. Groundwater 

quality in the backfill then depends on a balance between the introduction of 

new salts by groundwater that recharges the backfill and the flushing of the 

newly exposed soluble salts by groundwater flow. Studies of backfill 

groundwater quality are not yet conclusive due to a relatively short period of 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-115 

monitoring available in the PRB. A general observation is that the content of 

TDS, calcium, magnesium, and sodium sulfates, when compared to the 

undisturbed aquifers, is roughly two to three times as high at present. 

However, these elevated levels should decline as flushing and leaching of 

soluble salts reaches equilibrium. Even at a two to three fold increase in TDS 

concentration, the water in the backfill will, in most cases, be suitable for its 

predominant premining use, stock watering (Straskraba 1986). 

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. Van Voast and Reiten 

(1988) reached the same conclusions after analyzing data from the Decker and 

Colstrip mines located in the northern PRB. Their research indicates that 

upon initial saturation, mine backfill is generally high in TDS concentration 

and contains soluble salts of calcium, magnesium and sodium sulfates. TDS 

concentrations tend to decrease with time, indicating that the long-term 

groundwater quality in mined and off-site lands would return to approximate 

pre-mine conditions (Van Voast and Reiten 1988). Clark (1995) conducted a 

study to determine if the decreases predicted by laboratory studies actually 

occurred onsite. In the area of the West Decker Mine near Decker, Montana, 

Clark’s 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 flow path from a backfill aquifer to a downgradient 

coal aquifer. WDEQ/LQD calculated a median TDS concentration of 3,670 

mg/L based on 869 samples collected from monitoring wells with at least 15 

years of data that are completed in the backfill at the three applicant mines 

included in this analysis, and concluded that the recovered concentrations will 

be suitable for post-mining land use (Ogle and Calle 2006). 

Changes to the premining hydraulic characteristics of the alluvial aquifer and 

the quality of alluvial groundwater are expected to be minor after final 

reclamation, because the applicant mines would be required to maintain the 

essential hydrologic functions of the alluvial valley floors (AVFs) declared in the 

general Wright analysis area and their alluvial aquifer systems (as is currently 

required for the already-approved mining operations). See additional 

discussion in Sections 3.5.1.3 and 3.6. 

Direct and indirect impacts to the groundwater system resulting from mining 

the LBA tracts included in this analysis would add to the cumulative impacts 

that will occur due to mining existing leases. As discussed above, there have 

been drawdowns in the coal and overlying aquifers as a result of this existing 

approved mining and the existing CBNG development in the vicinity of the LBA 

tracts. The probable groundwater impacts from the leasing and subsequent 

mining of each of the LBA tracts under the Proposed Actions or Alternatives 2 

and 3 are described in the following paragraphs. Some or all of the impacts to 

the groundwater levels in the coal aquifer described below may occur prior to 

the mining of the LBA tracts, if they are leased, as a result of currently 
3.0 Affected Environment and Environmental Consequences 

3-116 Final EIS, Wright Area Coal Lease Applications 

approved surface coal mining adjacent to the LBA tracts and development of 

CBNG resources on and adjacent to the LBA tracts. 

3.5.1.2.1.1 North, South, and West Hilight Field LBA Tracts

The existing leases at the Black Thunder Mine currently include approximately 

22,416 acres. Mining the North Hilight Field LBA Tract as a maintenance lease 

would extend the area of overburden and coal removal by about 2,613.5 acres 

under the Proposed Action up to about 7,139.4 acres under Alternative 2, 

BLM’s preferred tract configuration. Mining the South Hilight Field LBA Tract 

as a maintenance lease would extend the area of overburden and coal removal 

by about 1,976.7 acres under the Proposed Action up to about 2,922.4 acres 

under Alternative 2, BLM’s preferred tract configuration. Mining the West 

Hilight Field LBA Tract as a maintenance lease would extend the area of 

overburden and coal removal by about 2,370.5 acres under the Proposed 

Action up to about 7,191.3 acres under Alternative 2, BLM’s preferred tract 

configuration. 

Mining has affected alluvial groundwater level elevations only where the alluvial 

aquifer has been mined out. If the North, South, and West Hilight Field tracts 

were leased, mining would dewater (if saturated) and physically remove the 

shallow alluvial materials within the tracts. Black Thunder Mine is required to 

maintain the essential hydrologic functions of affected alluvial aquifer systems. 

Unless it is determined that the recent alluvial deposits provide essential 

hydrologic functions, it is unlikely that WDEQ/LQD would require TBCC to 

selectively remove and replace the alluvial deposits within these three tracts. 

Should WDEQ/LQD require alluvial aquifer reclamation, changes to the 

premining hydraulic characteristics of the aquifer and the quality of the alluvial 

groundwater are expected to be minor after final reclamation. See additional 

discussions in Sections 3.5.1.3 and 3.6. 

Overburden thickness in the North Hilight Field LBA Tract averages around 

246 feet and the interburden thickness averages about 1 foot. Overburden 

thickness in the South Hilight Field LBA Tract averages around 292 feet and 

the interburden thickness averages about 94 feet. Overburden thickness in the 

West Hilight Field LBA Tract averages around 428 feet and the interburden 

thickness averages about 32 feet. Most of these materials are composed of 

massive silty and clayey shales of very low permeability, and the interbedded 

sandstone units are typically thin and discontinuous. Discontinuous, 

lenticular-shaped sand bodies also occur locally in the general Wright analysis 

area. Some of these isolated sandstone units and sand bodies in the 

overburden are saturated, but groundwater yields from them are generally low. 

Due to the discontinuous nature of the permeable overburden sediments, 

premining overburden groundwater movement generally followed the 

topography, and before mining, overburden groundwater flow in the vicinity of 

the Black Thunder Mine was generally toward, and discharged to Little 

Thunder and North Prong Little Thunder Creek valleys. Groundwater flow has 

since been affected by the removal of overburden by mining in the area. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-117 

Monitor well data indicate that overburden groundwater, where present, in the 

general Wright analysis area now flows toward the Black Thunder Mine and 

neighboring mines’ open pits. Mining has and will continue to depress water 

levels in the overburden, although the historical monitoring data do not 

indicate a direct correlation between water level drawdown in the overburden to 

distance and direction from the open pits. In general, overburden groundwater 

levels will begin to show steady decline in areas that are within about one-half 

mile of the mine pits as mining progresses. Future drawdown in the 

overburden is expected to be similar to that measured to date, and would be 

expected to continue to have a limited impact outside of the mined area. 

Water level drawdowns have propagated much farther and in a more consistent 

manner in the Wyodak coal seam aquifer than in the overburden. 

Groundwater level monitoring data collected by the Black Thunder Mine and 

the other mines located in the general Wright analysis area and presented in 

the GAGMO 25-year report (Hydro-Engineering 2007) indicate that the 

groundwater flow directions in the Wyodak coal have been greatly influenced 

by surface mine dewatering and groundwater discharge associated with CBNG 

development. Groundwater levels observed near active mining areas prior to 

1997 were likely due to mine dewatering alone and the groundwater flow 

direction within the coal aquifer was typically toward the mine where it would 

drain by gravity into the open pits. By year 2000, groundwater level decline 

rates had dramatically increased because drawdown caused by widespread 

CBNG development west of the mines was overlapping with drawdown caused 

by mining operations. A continuous cone of depression currently exists around 

the Black Thunder, Jacobs Ranch, North Antelope Rochelle, and Antelope 

mines due to their proximity to each other and the cumulative drawdown 

effects from pit dewatering and nearby CBNG development. 

BLM’s PRB Coal Review Task 3B Report, Cumulative Water Resources Effects 

(BLM 2009e), summarizes the modeled cumulative changes in groundwater 

levels projected for 2010, 2015, and 2020 in the eastern PRB within 

approximately 25 miles of the coal mines. The Task 3B report describes the 

modeled cumulative groundwater impacts associated with ongoing coal minerelated groundwater withdrawal in the eastern PRB for the time periods of 

2010, 2015, and 2020, and the base years used for comparison of groundwater 

impacts were 2002 (the year used for calibration of the groundwater model) 

and 1990 (a time period prior to CBNG pumpage and when the coal mines were 

beginning to increase dewatering as mining of the coal seams progressed to 

deeper levels). The eastern PRB cumulative effects study area for water 

resources comprises the Coal Mine Groundwater Model (CMGM) domain as 

shown in Figure 4-4. The CMGM was developed specifically for the PRB Coal 

Review study. The GAGMO databases for 1990 to 2002 were used to calibrate 

the groundwater model to best reflect conditions in the basin. The Task 3B 

report evaluated the potential groundwater impacts due only to coal mine 

dewatering. The projected locations of coal mine pits from 2002 to 2020 were 

used for placement of drain cells in the CMGM that represent pumpage of 

groundwater by the mines. The amount of water removed by the drain cells 
3.0 Affected Environment and Environmental Consequences 

3-118 Final EIS, Wright Area Coal Lease Applications 

reflects calibration to GAGMO monitoring wells surrounding each mine, rather 

than estimated or recorded discharge rates (BLM 2009e). The cumulative 

groundwater effects in the eastern PRB, including a discussion on the results 

of the PRB Task 3B report CMGM results, is included in Section 4.2.4.1 of this 

EIS. 

It is therefore possible to estimate the extent of drawdown in the Wyodak coal 

aquifer west of each mine that is specifically attributable to mine dewatering. 

The accuracy of those estimates however cannot be tested or observed in the 

real world because drawdown related only to mining is a relatively small impact 

that is masked by the much larger drawdown that is due to CBNG development 

in the area. Wyodak coal groundwater level data for year 2005, presented in 

the 25-year GAGMO report, illustrate that approximately 160 feet of drawdown 

has occurred near the western edge of the North Hilight Field LBA Tract, and 

approximately 40 feet of drawdown has occurred near the tract’s eastern edge. 

The 2005 data show that approximately 210 feet of drawdown has occurred 

near the western edge of the South Hilight Field LBA Tract, and approximately 

180 feet of drawdown has occurred near the tract’s eastern edge. The 2005 

data show that approximately 350 feet of drawdown has occurred near the 

western edge of the West Hilight Field LBA Tract as applied for, and 

approximately 220 feet of drawdown has occurred near the tract’s eastern edge. 

The 2005 coal seam water level contours in the area of the Black Thunder, 

Jacobs Ranch, North Antelope Rochelle, and Antelope mines depict the 

groundwater flow direction to be entirely to the west, away from the open pits 

(Hydro-Engineering 2007). Roughly 30 years of surface mining and CBNG 

development has resulted in nearly complete dewatering of the coal seams in 

localized areas, particularly near the mines’ pits and where the coal seams are 

structurally highest. 

In 2006, the extent of water level drawdown in the Wyodak coal aquifer 

attributable to mining the existing leases at the Black Thunder Mine was 

estimated using the analytical line slot (or sink) method. The results of the line 

sink analysis are reported in Addendum MP-3.3.5 of the WDEQ/LQD Black 

Thunder Mine Permit 233-T7 (TBCC 2005). For the purpose of this analysis, 

the extent of coal-mining related drawdown (5-foot contour) in the Wyodak 

seam over the life of the Black Thunder Mine if the North, South, and West 

Hilight Field LBA Tracts are mined was extrapolated by extending TBCC’s 

predicted life of mine, line sink drawdown contour to the north, south and west 

by the dimensions of the North, South, and West Hilight Field LBA Tracts, each 

configured under BLM’s preferred tract configuration (Figure 3-23). The area 

subject to lower water levels would increase roughly in proportion to the 

increase in area mined. This extrapolation serves as a general approximation 

of the potential impacts, based on experience, but it does not take variations in 

hydrologic properties, the time the pits are open, and the distance from 

previous mining and CBNG development into account. 

The rate and extent of the actual drawdown in the coal is currently much 

greater than the predicted life-of-mine drawdown. This has occurred as 
Clarkelen Road

Cosner

Breen

Reno Road

Road Jacobs

Mackey

State

Antelope

Edwards

State Highway 387

Matheson Road

Reno Road

BNSF & UP RR

State 59 Highway

Hilight Road

Road Lawver Road

Keeline Road

Highway 450

Road

Road

Road

Matheson

Road

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

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

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

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

Road County

WRIGHT

LEGEND

Existing Black Thunder Mine Federal Coal Lease

Boundaries

0 10000 20000 40000

GRAPHIC SCALE (FEET)

Extent of Worst-Case Modeled and Extrapolated Life

of Mine Drawdown (5 ft) with North, South, and West

Hilight Field LBA Tracts Under Alternative 2

Clinker

Approximate Wyodak Coal Outcrop

Clinker and coal outcrop information modified from

Plate 1 in Heffern and Coates (2000).

South Hilight Field LBA Tract as Applied for

West Hilight Field LBA Tract as Applied for

North Hilight Field LBA Tract as Applied for

South Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

North Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-23. Black Thunder Mine Life of Mine Drawdown, Resulting from Currently Approved Mining with the

Addition of the North, South, and West Hilight Field LBA Tracts.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-119
3.0 Affected Environment and Environmental Consequences 

3-120 Final EIS, Wright Area Coal Lease Applications 

drawdown caused by extensive CBNG development west of the current Black 

Thunder Mine permit area has overlapped with drawdown caused by mining 

operations. Continued drawdown effects from CBNG withdrawals are probable; 

therefore, future drawdown to the Wyodak coal aquifer from mining the 

approved leases and the North, South and West Hilight Field LBA Tracts would 

be expected to be negligible due to the fact that the coal seam has essentially 

been dewatered in the general Wright analysis area. Groundwater elevation 

data collected by the Black Thunder Mine since 1973 have formed the basis for 

quantifying groundwater level drawdowns since mining began and provide a 

reasonable and reliable means to predict trends in groundwater elevations 

associated with dewatering due to future mining. These data will continue to 

be recorded according to the mine’s WDEQ-approved groundwater monitoring 

program and included in the annual progress report that the Black Thunder 

Mine submits to the WDEQ/LQD, as well as the GAGMO Annual Reports. If 

ALC acquires the North, South and West Hilight Field LBA Tracts, WDEQ/LQD 

would require that future drawdown impacts due to mining alone be predicted 

in order to amend the tracts into the Black Thunder Mine permit area (Section 

3.5.1.3). 

The subcoal aquifers (i.e., Tullock Member of the Fort Union Formation and 

Lance-Fox Hills aquifer) are not removed or disturbed by mining, so they are 

not directly impacted by coal mining activity. Figure 3-20 depicts the locations 

of Black Thunder Mine’s five water supply wells, all of which are completed in 

aquifers below the Wyodak coal. If the applicant leases the North, South and 

West Hilight Field LBA Tracts, water would be produced from these wells for a 

longer period of time, but TBCC does not anticipate requiring additional subcoal wells to mine the LBA tracts. 

To date, 17 wells have been installed to monitor water levels and water quality 

in the backfill at Black Thunder Mine. Six of these wells were constructed 

between 1987 and 1991, eight wells were constructed in 1994, one was 

installed in 1995, and the remaining two were installed in 2008. Eight of these 

backfill wells were included in the mine’s current (2008) groundwater 

monitoring network, which is depicted in Figure 3-20. The groundwater level 

hydrographs recorded by these wells over the period of record indicate that the 

level of saturation in the backfill has fluctuated considerably and is largely 

dependant upon the well’s location with respect to the thickness of backfill, the 

physical characteristics of the backfill materials, and the source of 

groundwater recharge. At the present time, groundwater levels have increased 

by 1 to 23 feet at four well locations, remained stable at two locations, and 

declined 4 to 5 feet at the remaining well locations (Hydro-Engineering 2007). 

Aquifer tests performed to date on backfill well BTB-1 (Figure 3-20) at the 

Black Thunder Mine indicate the hydraulic conductivity ranges from 0.12-

ft/day to 0.86-ft/day. The values of hydraulic conductivity for well BTB-1 

appear to be reasonable for a recently dumped backfill. The reported values 

should be considered the highest that will exist in the backfill at the well 

location. The hydraulic conductivity values will decrease as the backfill 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-121 

undergoes further compaction and densification. It is estimated that after 

saturation and re-densification, the final hydraulic conductivity of the backfill 

will be in the range of 0.00003 ft/day to 0.003 ft/day (TBCC 2005). These data 

therefore provide an indication that the backfill will readily resaturate as 

postmining potentiometric elevations recover in the surrounding undisturbed 

aquifers (including the North, South and West Hilight Field LBA Tracts). The 

exact configuration and hydraulic gradient of the postmining potentiometric 

surface may vary from premine conditions; however, postmining equilibrium 

groundwater movement should exhibit a hydraulic gradient similar to that 

which existed prior to mining (TBCC 2005). 

TDS concentrations observed in the Black Thunder Mine backfill monitoring 

wells to date are similar to those found in the undisturbed alluvial and 

overburden aquifers, but greater than those found in the Wyodak coal aquifer. 

Postmining groundwater quality is expected to improve after one pore volume of 

water moves through the backfill. In general, the mine’s backfill groundwater 

quality can be expected to be similar to the premining overburden aquifer and 

meet Wyoming Class III standards (livestock and wildlife use); however, there 

could be localized areas in the backfill that yield groundwater that does not 

meet Wyoming Class III standards. Groundwater quality within the backfill at 

the North, South and West Hilight Field LBA Tracts would be expected to be 

similar to groundwater quality measured in existing wells completed in the 

Black Thunder Mine backfill. 

3.5.1.2.1.2 West Jacobs Ranch LBA Tract

The existing leases at the Jacobs Ranch Mine currently include approximately 

8,605 acres. Mining the West Jacobs Ranch LBA Tract as a maintenance lease 

would extend the area of overburden and coal removal by about 5,944.4 acres 

under the Proposed Action up to about 8,076.2 acres under Alternative 2, BLM 

preferred tract configuration. 

Mining has affected alluvial groundwater level elevations only where the alluvial 

aquifer has been mined out. If the West Jacobs Ranch LBA Tract were leased, 

mining would dewater (if saturated) and physically remove the shallow alluvial 

materials within the tract. Jacobs Ranch Mine is required to maintain the 

essential hydrologic functions of affected alluvial aquifer systems. Unless it is 

determined that the recent alluvial deposits provide essential hydrologic 

functions, it is unlikely that WDEQ/LQD would require TBCC to selectively 

remove and replace the alluvial deposits within this tract. Should WDEQ/LQD 

require alluvial aquifer reclamation, changes to the premining hydraulic 

characteristics of the aquifer and the quality of the alluvial groundwater are 

expected to be minor after final reclamation. See additional discussions in 

Sections 3.5.1.3 and 3.6. 

Overburden thickness in the West Jacobs Ranch LBA Tract averages around 

475 feet and there is no interburden present. Most of the overburden is 

composed of massive silty and clayey shales of very low permeability, and the 
3.0 Affected Environment and Environmental Consequences 

3-122 Final EIS, Wright Area Coal Lease Applications 

interbedded sandstone units are typically thin and discontinuous. 

Discontinuous, lenticular-shaped sand bodies also occur locally in the general 

Wright analysis area. Some of these isolated sandstone units and sand bodies 

in the overburden are saturated, but groundwater yields from them are 

generally low. Due to the discontinuous nature of the permeable overburden 

sediments, premining overburden groundwater movement generally followed 

the topography, and before mining, overburden groundwater flow in the vicinity 

of the Jacobs Ranch Mine was generally toward, and discharged to North Prong 

Little Thunder Creek. Groundwater flow has since been affected by the 

removal of overburden by mining in the area. Monitor well data indicate that 

overburden groundwater, where present, in the general Wright analysis area 

now flows toward the Jacobs Ranch Mine and neighboring mines’ open pits. 

Mining has and will continue to depress water levels in the overburden, 

although the historical monitoring data do not indicate a direct correlation 

between water level drawdown in the overburden to distance and direction from 

the open pits. In general, overburden groundwater levels will begin to show 

steady decline in areas that are within about one-half mile of the mine pits as 

mining progresses. Future drawdown in the overburden is expected to be 

similar to that measured to date, and would be expected to continue to have a 

limited impact outside of the mined area. 

Water level drawdowns have propagated much farther and in a more consistent 

manner in the Wyodak coal seam aquifer than in the overburden. 

Groundwater level monitoring data collected by the Jacobs Ranch Mine and the 

other mines located in the general Wright analysis area and presented in the 

GAGMO 25-year report (Hydro-Engineering 2007) indicate that the 

groundwater flow directions in the Wyodak coal have been greatly influenced 

by surface mine dewatering and groundwater discharge associated with CBNG 

development. Groundwater levels observed near active mining areas prior to 

1997 were likely due to mine dewatering alone and the groundwater flow 

direction within the coal aquifer was typically toward the mine where it would 

drain by gravity into the open pits. By year 2000, groundwater level decline 

rates had dramatically increased because drawdown caused by widespread 

CBNG development west of the mines was overlapping with drawdown caused 

by mining operations. A continuous cone of depression currently exists around 

the Black Thunder, Jacobs Ranch, North Antelope Rochelle, and Antelope 

mines due to their proximity to each other and the cumulative drawdown 

effects from pit dewatering and nearby CBNG development. 

BLM’s PRB Coal Review Task 3B Report, Cumulative Water Resources Effects 

(BLM 2009e), summarizes the modeled cumulative changes in groundwater 

levels projected for 2010, 2015, and 2020 in the eastern PRB within 

approximately 25 miles of the coal mines. The Task 3B report describes the 

modeled cumulative groundwater impacts associated with ongoing coal minerelated groundwater withdrawal in the eastern PRB for the time periods of 

2010, 2015, and 2020, and the base years used for comparison of groundwater 

impacts were 2002 (the year used for calibration of the groundwater model) 

and 1990 (a time period prior to CBNG pumpage and when the coal mines were 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-123 

beginning to increase dewatering as mining of the coal seams progressed to 

deeper levels). The eastern PRB cumulative effects study area for water 

resources comprises the Coal Mine Groundwater Model (CMGM) domain as 

shown in Figure 4-4. The CMGM was developed specifically for the PRB Coal 

Review study. The GAGMO databases for 1990 to 2002 were used to calibrate 

the groundwater model to best reflect conditions in the basin. The Task 3B 

report evaluated the potential groundwater impacts due only to coal mine 

dewatering. The projected locations of coal mine pits from 2002 to 2020 were 

used for placement of drain cells in the CMGM that represent pumpage of 

groundwater by the mines. The amount of water removed by the drain cells 

reflects calibration to GAGMO monitoring wells surrounding each mine, rather 

than estimated or recorded discharge rates (BLM 2009e). The cumulative 

groundwater effects in the eastern PRB, including a discussion on the results 

of the PRB Task 3B report CMGM results, is included in Section 4.2.4.1 of this 

EIS. 

It is therefore possible to estimate the extent of drawdown in the Wyodak coal 

aquifer west of each mine that is specifically attributable to mine dewatering. 

The accuracy of those estimates however cannot be tested or observed in the 

real world because drawdown related only to mining is a relatively small impact 

that is masked by the much larger drawdown that is due to CBNG development 

in the area. Wyodak coal groundwater level data for year 2005, presented in 

the 25-year GAGMO report, illustrate that approximately 350 feet of drawdown 

has occurred near the western edge of the West Jacobs Ranch LBA Tract, and 

approximately 220 feet of drawdown has occurred near the tract’s eastern edge. 

The 2005 coal seam water level contours in the area of the Black Thunder, 

Jacobs Ranch, North Antelope Rochelle, and Antelope mines depict the 

groundwater flow direction to be entirely to the west, away from the open pits 

(Hydro-Engineering 2007). Roughly 30 years of surface mining and CBNG 

development has resulted in nearly complete dewatering of the coal seams in 

localized areas, particularly near the mines’ pits and where the coal seams are 

structurally highest. 

In 2003, the extent of water level drawdown in the coal aquifer attributable to 

mining the existing leases at the Jacobs Ranch Mine was estimated using the 

analytical line slot (or sink) method. The results of the line sink analysis are 

reported in Addendum MP-E of the WDEQ/LQD Jacobs Ranch Mine Permit 

271-T6 (JRCC 2009). For the purpose of this analysis, the extent of coalmining related drawdown (5-foot contour) in the Wyodak seam over the life of 

the Jacobs Ranch Mine if the West Jacobs Ranch LBA Tract is mined was 

extrapolated by extending TBCC’s predicted life of mine, line sink drawdown 

contour to the north, south, and west by the dimensions of the West Jacobs 

Ranch LBA Tract under Alternative 2, BLM preferred tract configuration (Figure 

3-24). The area subject to lower water levels would increase roughly in 

proportion to the increase in area mined. This extrapolation serves as a 

general approximation of the potential impacts, based on experience, but it 

does not take variations in hydrologic properties, the time the pits are open, 

and the distance from previous mining and CBNG development into account.
Clarkelen Road

Cosner

Breen

Reno Road

Road Jacobs

Mackey

State

Antelope

Edwards

State Highway 387

Matheson Road

Reno Road

BNSF & UP RR

State 59 Highway

Hilight Road Hilight Road

Road Lawver Road

Keeline Road

Highway 450

Road

Road

Road

Matheson

Road

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

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

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

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

Road County

WRIGHT

Existing Jacobs Ranch Mine Federal

Coal Lease Boundaries

West Jacobs Ranch LBA Tract as Applied for

LEGEND

0 10000 20000 40000

GRAPHIC SCALE (FEET)

Clinker

Approximate Wyodak Coal Outcrop

Clinker and coal outcrop information modified from

Plate 1 in Heffern and Coates (2000).

Extent of Worst-Case Modeled and Extrapolated

Life of Mine Drawdown (5 ft) with West Jacobs

Ranch LBA Tract Under Alternative 2

West Jacobs Ranch LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-24. Jacobs Ranch Mine Life of Mine Drawdown, Resulting from Currently Approved Mining with the

Addition of the West Jacobs Ranch LBA Tract.

3.0 Affected Environment and Environmental Consequences

3-124 Final EIS, Wright Area Coal Lease Applications
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-125 

The rate and extent of the actual drawdown in the Wyodak coal is currently 

much greater than the predicted life-of-mine drawdown. This has occurred as 

drawdown caused by extensive CBNG development west of the current Jacobs 

Ranch Mine permit area has overlapped with drawdown caused by mining 

operations. Continued drawdown effects from CBNG withdrawals are probable; 

therefore, future drawdown to the Wyodak coal aquifer from mining the 

approved leases and the West Jacobs Ranch LBA Tract would be expected to be 

negligible due to the fact that the coal seam has essentially been dewatered in 

the general Wright analysis area. Groundwater elevation data collected by the 

Jacobs Ranch Mine since 1980 have formed the basis for quantifying 

groundwater level drawdowns since mining began and provide a reasonable 

and reliable means to predict trends in groundwater elevations associated with 

dewatering due to future mining. These data will continue to be recorded 

according to the mine’s WDEQ-approved groundwater monitoring program and 

included in the annual progress report that the Jacobs Ranch Mine submits to 

the WDEQ/LQD, as well as the GAGMO Annual Reports. If TBCC acquires the 

West Jacobs Ranch LBA Tract, WDEQ/LQD would require that future 

drawdown impacts due to mining alone be predicted in order to amend the 

tract into the Jacobs Ranch Mine permit area (Section 3.5.1.3). 

The subcoal aquifers (i.e., Tullock Member of the Fort Union Formation and 

Lance-Fox Hills aquifer) are not removed or disturbed by mining, so they are 

not directly impacted by coal mining activity. Figure 3-21 depicts the locations 

of Jacobs Ranch Mine’s five water supply wells, all of which are completed in 

aquifers below the Wyodak coal. If the applicant leases the West Jacobs Ranch 

LBA Tract, water would be produced from these wells for a longer period of 

time, but TBCC does not anticipate requiring additional sub-coal wells to mine 

the LBA tract. 

To date, five wells have been installed to monitor water levels and water quality 

in the backfill at Jacobs Ranch Mine. Two of these wells were constructed in 

1981 and 1984, one well was constructed in 1994, and the remaining two wells 

were constructed in 2001. All of these backfill wells were included in the 

mine’s current (2008) groundwater monitoring network, which is depicted in 

Figure 3-21. The groundwater level hydrographs recorded by these wells over 

the period of record indicate that the level of saturation in the backfill has 

either increased steadily or has remained unchanged. Jacobs Ranch Mine’s 

backfill monitoring wells are located near the eastern extent of mining, and the 

relatively rapid groundwater level recovery suggests that the backfill is 

receiving recharge from the undisturbed clinker areas located adjacent to the 

eastern and southern edges of the mine (JRCC 2008). 

To date, no aquifer tests have been conducted on the backfill monitoring wells 

at the Jacobs Ranch Mine. Therefore, no site-specific data are available for the 

hydraulic properties of the applicant mine’s backfill. The composition of 

backfill materials at the adjacent Black Thunder Mine is quite similar to that of 

the Jacobs Ranch Mine, and the hydraulic properties of the backfill at both 

mines, as well as the West Jacobs Ranch LBA Tract, are also expected to be 
3.0 Affected Environment and Environmental Consequences 

3-126 Final EIS, Wright Area Coal Lease Applications 

quite similar. Refer to Section 3.5.1.2.1.1 for a discussion on the hydraulic 

conductivity of the backfill measured at Black Thunder Mine. These data 

provide an indication that the Jacobs Ranch Mine backfill will readily 

resaturate as postmining potentiometric elevations recover in the surrounding 

undisturbed aquifers, and that wells completed in the backfill (including in the 

West Jacobs Ranch LBA Tract) would be capable of supplying sufficient yields 

to wells constructed for livestock watering uses. 

TDS concentrations observed in the Jacobs Ranch Mine backfill monitoring 

wells to date are similar to those found in the undisturbed alluvial and 

overburden aquifers, but greater than those found in the Wyodak coal aquifer. 

The TDS concentrations in all of the mine’s backfill wells have steadily 

increased from the first samples taken, likely due to an increase in water levels 

toward equilibrium conditions and a corresponding increased contact with the 

recently backfilled overburden materials (JRCC 2008). Postmining 

groundwater quality is expected to improve after one pore volume of water 

moves through the backfill. In general, the mine’s backfill groundwater quality 

can be expected to be similar to the premining overburden aquifer and meet 

Wyoming Class III standards (livestock and wildlife use); however, there could 

be localized areas in the backfill that yield groundwater that does not meet 

Wyoming Class III standards. Groundwater quality within the backfill at the 

West Jacobs Ranch LBA Tract would be expected to be similar to groundwater 

quality measured in existing wells completed in the Jacobs Ranch Mine 

backfill. 

3.5.1.2.1.3 North and South Porcupine LBA Tracts

The existing leases at the North Antelope Rochelle Mine currently include 

approximately 18,066 acres. Mining the North Porcupine LBA Tract as a 

maintenance lease would extend the area of overburden and coal removal by 

about 5,795.8 acres under the Proposed Action up to about 7,366.8 acres 

under Alternative 2, BLM’s preferred tract configuration. Mining the South 

Porcupine LBA Tract as a maintenance lease would extend the area of 

overburden and coal removal by about 3,186.0 acres under the Proposed 

Action up to about 3,568.0 acres under Alternative 2, BLM’s preferred tract 

configuration. 

Mining has affected alluvial groundwater level elevations only where the alluvial 

aquifer has been mined out. If the North Porcupine tract were leased, mining 

would dewater (if saturated) and physically remove the generally thin, finegrained shallow alluvial materials within the tract. No alluvial deposits occur 

within the South Porcupine tract. North Antelope Rochelle Mine is required to 

maintain the essential hydrologic functions of affected alluvial aquifer systems. 

Unless it is determined that the recent alluvial deposits present within the 

North Porcupine tract provide essential hydrologic functions, it is unlikely that 

WDEQ/LQD would require PRC to selectively remove and replace those alluvial 

deposits. Should WDEQ/LQD require alluvial aquifer reclamation, changes to 

the premining hydraulic characteristics of the alluvial materials and the quality 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-127 

of the alluvial groundwater are expected to be minor after final reclamation. 

See additional discussions in Sections 3.5.1.3 and 3.6. 

Overburden thickness in the North Porcupine LBA Tract averages around 343 

feet and there is no interburden present. Overburden thickness in the South 

Porcupine LBA Tract averages around 346 feet and the interburden thickness 

averages about 11 feet. Most of these materials are composed of massive silty 

and clayey shales of very low permeability, and the interbedded sandstone 

units are typically thin and discontinuous. Discontinuous, lenticular-shaped 

sand bodies also occur locally in the general Wright analysis area. Some of 

these isolated sandstone units and sand bodies in the overburden are 

saturated, but groundwater yields from them are generally low. Due to the 

discontinuous nature of the permeable overburden sediments, premining 

overburden groundwater movement generally followed the topography, and 

before mining, overburden groundwater flow in the vicinity of the North 

Antelope Rochelle Mine was generally toward, and discharged to Porcupine 

Creek valley. Groundwater flow has since been affected by the removal of 

overburden by mining in the area. Monitor well data indicate that overburden 

groundwater, where present, in the general Wright analysis area now flows 

toward the North Antelope Rochelle Mine and neighboring mines’ open pits. 

Mining has and will continue to depress water levels in the overburden, 

although the historical monitoring data do not indicate a direct correlation 

between water level drawdown in the overburden to distance and direction from 

the open pits. In general, overburden groundwater levels will begin to show 

steady decline in areas that are within about one-half mile of the mine pits as 

mining progresses. Future drawdown in the overburden is expected to be 

similar to that measured to date, and would be expected to continue to have a 

limited impact outside of the mined area. 

Water level drawdowns have propagated much farther and in a more consistent 

manner in the Wyodak coal seam aquifer than in the overburden. 

Groundwater level monitoring data collected by the North Antelope Rochelle 

Mine and other mines located in the general Wright analysis area and 

presented in the GAGMO 25-year report (Hydro-Engineering 2007) indicate 

that the groundwater flow directions in the Wyodak-Anderson coal have been 

greatly influenced by surface mine dewatering and groundwater discharge 

associated with CBNG development. Groundwater levels observed near active 

mining areas prior to 1997 were likely due to mine dewatering alone and the 

groundwater flow direction within the coal aquifer was typically toward the 

mine where it would drain by gravity into the open pits. By year 2000, 

groundwater level decline rates had dramatically increased because drawdown 

caused by widespread CBNG development west of the mines was overlapping 

with drawdown caused by mining operations. A continuous cone of depression 

currently exists around the Black Thunder, Jacobs Ranch, North Antelope 

Rochelle, and Antelope mines due to their proximity to each other and the 

cumulative drawdown effects from pit dewatering and nearby CBNG 

development. 
3.0 Affected Environment and Environmental Consequences 

3-128 Final EIS, Wright Area Coal Lease Applications 

BLM’s PRB Coal Review Task 3B Report, Cumulative Water Resources Effects 

(BLM 2009e), summarizes the modeled cumulative changes in groundwater 

levels projected for 2010, 2015, and 2020 in the eastern PRB within 

approximately 25 miles of the coal mines. The Task 3B report describes the 

modeled cumulative groundwater impacts associated with ongoing coal minerelated groundwater withdrawal in the eastern PRB for the time periods of 

2010, 2015, and 2020, and the base years used for comparison of groundwater 

impacts were 2002 (the year used for calibration of the groundwater model) 

and 1990 (a time period prior to CBNG pumpage and when the coal mines were 

beginning to increase dewatering as mining of the coal seams progressed to 

deeper levels). The eastern PRB cumulative effects study area for water 

resources comprises the Coal Mine Groundwater Model (CMGM) domain as 

shown in Figure 4-4. The CMGM was developed specifically for the PRB Coal 

Review study. The GAGMO databases for 1990 to 2002 were used to calibrate 

the groundwater model to best reflect conditions in the basin. The Task 3B 

report evaluated the potential groundwater impacts due only to coal mine 

dewatering. The projected locations of coal mine pits from 2002 to 2020 were 

used for placement of drain cells in the CMGM that represent pumpage of 

groundwater by the mines. The amount of water removed by the drain cells 

reflects calibration to GAGMO monitoring wells surrounding each mine, rather 

than estimated or recorded discharge rates (BLM 2009e). The cumulative 

groundwater effects in the eastern PRB, including a discussion on the results 

of the PRB Task 3B report CMGM results, is included in Section 4.2.4.1 of this 

EIS. 

It is therefore possible to estimate the extent of drawdown in the Wyodak coal 

aquifer west of each mine that is specifically attributable to mine dewatering. 

The accuracy of those estimates however cannot be tested or observed in the 

real world because drawdown related only to mining is a relatively small impact 

that is masked by the much larger drawdown that is due to CBNG development 

in the area. Wyodak-Anderson coal groundwater level data for year 2005, 

presented in the 25-year GAGMO report, illustrate that approximately 240 feet 

of drawdown has occurred near the western edge of the North Porcupine LBA 

Tract, and approximately 5 feet of drawdown has occurred near the tract’s 

eastern edge. The 2005 data show that approximately 100 feet of drawdown 

has occurred near the western edge of the South Porcupine LBA Tract, and 

approximately 160 feet of drawdown has occurred near the tract’s eastern edge. 

The 2005 coal seam water level contours in the area of the Black Thunder, 

Jacobs Ranch, North Antelope Rochelle, and Antelope mines depict the 

groundwater flow direction to be entirely to the west, away from the open pits 

(Hydro-Engineering 2007). Roughly 30 years of surface mining and CBNG 

development has resulted in nearly complete dewatering of the coal seams in 

localized areas, particularly near the mines’ pits and where the coal seams are 

structurally highest. 

In 2006, the extent of water level drawdown in the coal aquifer attributable to 

mining the existing leases at the North Antelope Rochelle Mine was estimated 

using the analytical line slot (or sink) method. The results of the line sink 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-129 

analysis are reported in Addendum D6-G2 of the WDEQ/LQD North Antelope 

Rochelle Mine Permit 569-T7 (PRC 2009). For the purpose of this analysis, the 

extent of coal-mining related drawdown (5-foot contour) in the WyodakAnderson seam over the life of the North Antelope Rochelle Mine if the North 

and South Porcupine LBA Tracts are mined was extrapolated by extending 

PRC’s predicted life of mine, line sink drawdown contour to the north, south, 

and west by the dimensions of the North and South Porcupine LBA Tracts 

under Alternative 2, BLM’s preferred tract configuration (Figure 3-25). The 

area subject to lower water levels would increase roughly in proportion to the 

increase in area mined. This extrapolation serves as a general approximation 

of the potential impacts, based on experience, but it does not take variations in 

hydrologic properties, the time the pits are open, and the distance from 

previous mining and CBNG development into account. 

The rate and extent of the actual drawdown in the coal is currently much 

greater than the predicted life-of-mine drawdown. This has occurred as 

drawdown caused by extensive CBNG development west of the North Antelope 

Rochelle Mine permit area has overlapped with drawdown caused by mining 

operations. Continued drawdown effects from CBNG withdrawals are probable; 

therefore, future drawdown to the Wyodak-Anderson coal aquifer from mining 

the approved leases and the North and South Porcupine tracts would be 

expected to be negligible due to the fact that the coal seam has essentially been 

dewatered in the general Wright analysis area. Groundwater elevation data 

collected by the North Antelope Rochelle Mine since 1973 have formed the 

basis for quantifying groundwater level drawdowns since mining began and 

provide a reasonable and reliable means to predict trends in groundwater 

elevations associated with dewatering due to future mining. These data will 

continue to be recorded according to the mine’s WDEQ-approved groundwater 

monitoring program and included in the annual progress report that the North 

Antelope Rochelle Mine submits to the WDEQ/LQD, as well as the GAGMO 

Annual Reports. If PRC acquires the North and South Porcupine LBA Tracts, 

WDEQ/LQD would require that future drawdown impacts due to mining alone 

be predicted in order to amend the tracts into the North Antelope Rochelle Mine 

permit area (Section 3.5.1.3). 

The subcoal aquifers (i.e., Tullock Member of the Fort Union Formation and 

Lance-Fox Hills aquifer) are not removed or disturbed by mining, so they are 

not directly impacted by coal mining activity. Figure 3-22 depicts the locations 

of North Antelope Rochelle Mine’s seven water supply wells, all of which are 

completed in aquifers below the Wyodak coal. If the applicant leases the North 

and South Porcupine LBA Tracts, water would be produced from these wells for 

a longer period of time, but PRC does not anticipate requiring additional subcoal wells to mine the LBA tract. 

To date, 28 wells have been installed to monitor water levels and water quality 

in the backfill at North Antelope Rochelle Mine. As depicted in Figure 3-22, all 

28 wells were included in the mine’s current (2008) groundwater monitoring 

network. The groundwater level hydrographs recorded by these wells over the
Cosner

Reno Road

State

Antelope

Edwards

State Highway 387

Matheson Road

Reno Road School

Creek

BNSF & UP RR

State 59 Highway

State

 59

Highway

Hilight Road

Highway 450

Road

Road

Road

Campbell County

Converse County

T.

43

N.

T.

42

N.

T.

41

N.

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

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

T.

43

N.

T.

42

N.

T.

41

N.

Road County

T.

40

N.

T.

40

N. Antelope Road

WRIGHT

LEGEND

Existing North Antelope Rochelle Mine Federal

Coal Lease Boundaries

0 10000 20000 40000

GRAPHIC SCALE (FEET)

Extent of Worst-Case Modeled and Extrapolated

Life of Mine Drawdown (5 ft) with North and South

Porcupine LBA Tracts Under Alternative 2

Clinker

Approximate Wyodak Coal Outcrop

Clinker and coal outcrop information modified from

Plate 1 in Heffern and Coates (2000).

North Porcupine LBA Tract as Applied for

South Porcupine LBA Tract as Applied for

South Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

North Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-25. North Antelope Rochelle Mine Life of Mine Drawdown, Resulting from Currently Approved

Mining with the Addition of the North and South Porcupine LBA Tracts.

3.0 Affected Environment and Environmental Consequences

3-130 Final EIS, Wright Area Coal Lease Applications
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-131 

period of record indicate that the level of saturation in the backfill is largely 

dependant upon the well’s location with respect to the thickness of backfill, the 

physical characteristics of the backfill materials, and the source of 

groundwater recharge. For example, those monitoring wells completed in 

reclaimed alluvial materials emplaced beneath the reclaimed Porcupine Creek 

stream channel recorded relatively rapid resaturation followed by seasonal 

water level fluctuations similar to the stream’s undisturbed alluvial aquifer. 

Most of the other wells completed in the mine’s backfill have recorded either 

steadily increasing or relatively constant water levels, while some have shown 

that the backfill remains essentially dry in some areas (PRC 2008b). 

The hydraulic properties of the backfill aquifer at the North and South 

Porcupine LBA Tracts would be expected to be similar to the hydraulic 

properties measured in existing wells completed in the backfill at the North 

Antelope Rochelle Mine. The backfill aquifer has been tested at four wells, and 

the average hydraulic conductivity of 36 ft/day exceeds the median hydraulic 

conductivity (1.8 ft/day) reported by WDEQ/LQD (Ogle and Calle 2006) for the 

Wyodak-Anderson coal aquifer in the vicinity of the general Wright analysis 

area. This data therefore provide an indication that the backfill will readily 

resaturate as postmining potentiometric elevations recover in the surrounding 

undisturbed aquifers (including the North and South Porcupine LBA Tracts). 

The exact configuration and hydraulic gradient of the postmining 

potentiometric surface may vary from premine conditions; however, postmining 

equilibrium groundwater movement should exhibit a hydraulic gradient similar 

to that which existed prior to mining (PRC 2009). 

TDS concentrations observed in the North Antelope Rochelle Mine backfill to 

date are similar to those found in the undisturbed alluvial and Wasatch 

Formation overburden aquifers, but greater than those found in the Wyodak 

coal aquifer. TDS concentrations in the most recent samples collected from 14 

of the mine’s backfill monitoring wells that were reported in the GAGMO 25-

year report (Hydro-Engineering 2007) ranged from 817 mg/L to 12,819 mg/L, 

with a geometric mean of 3,173 mg/L and an average of 4,455 mg/L. In 

general, the mine’s backfill groundwater quality can be expected to be similar 

to the premining overburden aquifer and meet Wyoming Class III standards; 

however, there could be localized areas in the backfill that yield groundwater 

that does not meet Wyoming Class III standards, particularly where the poorer 

quality alluvial materials happen to be concentrated. Groundwater quality 

within the backfill at the North and South Porcupine LBA Tracts would be 

expected to be similar to groundwater quality measured in existing wells 

completed in the North Antelope Rochelle Mine backfill. 

3.5.1.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and coal removal and the associated 

impacts to groundwater resources would not occur on the portions of the LBA 
3.0 Affected Environment and Environmental Consequences 

3-132 Final EIS, Wright Area Coal Lease Applications 

tracts as applied for or the LBA tracts configured under Alternative 2 that will 

not be disturbed under the currently approved surface coal mining permits. 

Coal removal and associated impacts to groundwater resources related to 

existing approved mining (as well as CBNG development, as described above) 

would continue as currently permitted within the existing Black Thunder, 

Jacobs Ranch, and North Antelope Rochelle Mine permit areas. Impacts to 

groundwater resources related to mining operations at these three applicant 

mines would not be extended onto portions of the LBA tracts that will not be 

affected under the currently approved mining and reclamation plans. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective tract in the future. 

3.5.1.3 Regulatory Compliance, Mitigation, and Monitoring

In order to obtain a surface coal mining permit, the Surface Mine Control and 

Reclamation Act (SMCRA) and state law require surface coal mine operators to 

evaluate regional and site-specific baseline hydrogeologic environments within 

and around their mines. Prior to the cumulative drawdown effects of CBNG 

development and mining on the Wyodak/Wyodak-Anderson coal seam aquifer, 

WDEQ required each mine to use a numerical groundwater flow model (i.e., 

MODFLOW) to predict the extent of water level drawdown that would occur as 

a result of mining its existing leases. Current mine permit requirements 

require that future drawdown impacts due to mining alone be addressed, 

although less rigorous methods such as historical groundwater level trend 

analyses and simple analytical models (i.e., line-sink analysis) can and are 

being used rather than complex numerical groundwater flow models. Results 

of these studies are included in the WDEQ/LQD mine permits for the existing 

Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines (TBCC 

2005, JRCC 2009, and PRC 2009). These studies would be revised accordingly 

and included in the mine permit amendment that would be required for each 

respective LBA tract that is leased. Permit revisions must be approved before 

mining could occur on each tract that is leased, regardless of who acquires the 

tract. 

As discussed in Section 3.5.3.3, 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. 

Operational groundwater monitoring programs are dynamic and modified 

through time as wells are removed by mining, discontinued from monitoring to 

eliminate redundancy, or added to replace those removed by mining and to 

facilitate monitoring of future mine expansion areas as mining has progressed. 

Through the years, some of the monitoring wells have become gaseous and 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-133 

were removed from the monitoring plan for safety reasons. Additional wells 

have also been installed in the reclaimed backfill to monitor recovering, 

postmine groundwater conditions. Many groundwater monitoring wells 

installed by Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines 

within and around their current permit areas have been used to evaluate 

groundwater conditions in the general Wright analysis area since the early 

1970s and continue to be monitored to reveal a long-term record of 

groundwater conditions. Wells for which monitoring has been discontinued are 

still in place and may be reincorporated into the monitoring network in the 

future. The data gathered from the actively monitored wells are included in the 

annual reports prepared by the mines and submitted to the WDEQ/LQD. The 

locations of the current groundwater monitoring networks at the Black 

Thunder, Jacobs Ranch, and North Antelope Rochelle mines are depicted in 

Figures 3-20, 3-21, and 3-22, respectively. 

SMCRA and state regulations require surface coal mines to maintain the 

essential hydrologic functions of the streams and their alluvial groundwater 

systems that are disturbed by mining. In order to meet this requirement, the 

mines are typically required to salvage and stockpile the stream laid alluvial 

materials during mining and replace them upon final reclamation. 

3.5.2 Surface Water

3.5.2.1 Affected Environment

The Cheyenne River and its tributaries drain the general Wright analysis area. 

For the purpose of this analysis, the general Wright analysis area encompasses 

the three applicant mines, the BLM study areas for the six LBA tracts that are 

proposed for leasing, and the adjacent lands that would be disturbed by mining 

the BLM study areas. From north to south, the general Wright analysis area is 

drained by Black Thunder Creek, North Prong Little Thunder Creek, Little 

Thunder Creek, Porcupine Creek, Horse Creek, and Antelope Creek (Figure 3-

26). North Prong Little Thunder Creek is a tributary of Little Thunder Creek, 

which is a tributary of Black Thunder Creek. Porcupine Creek and Horse 

Creek are tributaries of the Antelope Creek. Black Thunder Creek and 

Antelope Creek are both major tributaries of the Cheyenne River. 

The general Wright analysis area lies within the southeastern part of the 

Powder River Structural Basin and within the Cheyenne River drainage basin 

(Hydrologic Unit Code [HUC] 101201). 

The North Hilight Field general analysis area and the existing Black Thunder 

Mine permit area are located in the Little Thunder Creek watershed. Typical of 

this semi-arid area, Little Thunder Creek and its tributaries are all ephemeral 

streams. The Black Thunder Mine disturbs Little Thunder Creek and several of 

its tributaries, including North Prong Little Thunder Creek, and is currently 

permitted to disturb approximately 4 percent of the Little Thunder Creek 

watershed. The mine’s existing permit area is located entirely within the Little 
NORTH

HILIGHT

FIELD LBA

TRACT

NORTH

PORCUPINE

LBA

TRACT

Jacobs

Ranch

Mine

Black

Thunder

Mine

North

AntelopeRochelle

Mine

WEST

HILIGHT

FIELD LBA

TRACT

WEST JACOBS

RANCH LBA

TRACT

Little

Thunder

Creek

North Prong

Creek

Porcupine

Creek

Spring

Creek Antelope

Antelope

Creek

Creek

Thunder

Black

Little

Thunder

Creek

Hay Creek

Belle

Fourche

River

T.

46

N.

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

T.

40

N.

T.

39

N.

R. 65 W. R. 66 W. R. 67 W. R. 68 W. R. 73 W. R. 72 W. R. 71 W. R. 70 W. R. 69 W. R. 64 W.

R. 65 W. R. 66 W. R. 67 W. R. 68 W. R. 73 W. R. 72 W. R. 71 W. R. 70 W. R. 69 W. R. 64 W. T.

46

N.

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

T.

40

N.

T.

39

N.

WRIGHT

Niobrara County

Converse County

Weston County

Campbell County

Weston County

Campbell CountyConverse County Niobrara County

Cheyenne

River

Cheyenne

River

Lodgepole

Creek

Cheyenne

River

116

450

387

59

59

SCALE: 1"=7 MILES

SOUTH

HILIGHT

FIELD LBA

TRACT

SOUTH

PORCUPINE

LBA

TRACT

Creek

Horse

Creek

School

Little

Thunder

Creek

Creek

Thunder

Black

Figure 3-26. Surface Drainage in the General Wright Analysis Area.

3.0 Affected Environment and Environmental Consequences

3-134 Final EIS, Wright Area Coal Lease Applications
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-135 

Thunder Creek drainage. The northeastern portion of the BLM study area for 

the North Hilight Field LBA Tract (the tract as applied for and the additional 

area evaluated under Alternative 2) is drained by Keeline Draw, a northerlyflowing ephemeral tributary of Black Thunder Creek. Mills Draw, a southerlyflowing ephemeral tributary of North Prong Little Thunder Creek, drains a 

small portion of the North Hilight Field general analysis area. Approximately 

3,031 acres (or about 43 percent) of the 7,139-acre BLM study area for the 

North Hilight Field tract drain toward playas that are formed by natural 

topographic depressions; the largest of which are the Hansen Lakes; and 

Springen Draw, an internally drained closed basin, drains the entire western 

portion of the tract’s general analysis area. Figure 3-27 depicts the surface 

water features within and adjacent to the North Hilight Field LBA Tract. 

The South Hilight Field general analysis area and the existing Black Thunder 

Mine permit area are located in the Little Thunder Creek watershed. Little 

Thunder Creek flows easterly through and drains the northern portion of the 

BLM study area for the South Hilight Field LBA Tract (the tract as applied for 

and the additional area evaluated under Alternative 2). Approximately 1,364 

acres (or about 47 percent) of the 2,922-acre BLM study area for the South 

Hilight Field tract drain toward playas that are formed by natural topographic 

depressions. The southwestern corner of the tract’s general analysis area is 

drained by Briggs Draw, an ephemeral tributary of Little Thunder Creek. 

Figure 3-28 depicts the surface water features within and adjacent to the 

South Hilight Field LBA Tract. 

The West Hilight Field general analysis area and the existing Black Thunder 

Mine permit area are located in the Little Thunder Creek watershed. 

Ephemeral tributaries of Dry Fork Little Thunder Creek (e.g., Brater Draw) 

drain a small northern portion of the BLM study area for the West Hilight Field 

LBA Tract (the tract as applied for and the additional area evaluated under 

Alternative 2). Approximately 1,708 acres (or about 24 percent) of the 9,189-

acre BLM study area for the West Hilight Field LBA Tract drain to playas that 

are formed by natural topographic depressions, the largest of which is called 

Rochelle Lake. Most of the internally-drained areas located within the West 

Hilight Field general analysis area occur north of Little Thunder Creek. Little 

Thunder Creek flows easterly through the central portion of the West Hilight 

Field general analysis area, and its ephemeral tributaries, Briggs Draw and 

Black Butte Draw, drain the southern portion of the general analysis area. 

Figure 3-29 depicts the surface water features within and adjacent to the West 

Hilight Field LBA Tract. 

The existing Jacobs Ranch Mine permit area and the West Jacobs Ranch 

general analysis area are located in the North Prong Little Thunder Creek 

watershed. North Prong Little Thunder Creek and its tributaries, Dry Fork 

Little Thunder Creek and School Section Draw, drain the general analysis area 

for the West Jacobs Ranch LBA Tract. North Prong Little Thunder Creek flows 

from the northwest to the southeast across the LBA tract. All of the West 

Jacobs Ranch LBA Tract is outside of the mine’s existing permit area. 
Breen

Keeline

Road Jacobs

State

Hilight Road

Road Lawver Road

Road

Highway 450

BNSF & UP RR

31

30

19

18

7

6

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

20

17

8

5

21

16

9

4

22

15

10

23

14

11

2

24

13

12

1

19

18

7

6

20

17

8

5

21

16

9

4

22

15

10

3

23

14

11

2

24

13

12

1

19

18

7

6

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

32

29

20

33

28

21

34

27

22

35

26

23

36

25

24

31

30

19

32

29

20

33

28

21

34

27

22

35

26

23

36

25

24

31

30

19

R. 70 W. R. 69 W.

R. 70 W. R. 69 W.

T.

45

N.

T.

44

N.

T.

45

N.

T.

44

N.

Draw

Thunder

Little

Creek

Prong

North

Section

School

West

Coal

Fork

Creek

Little

Thunder

Creek

Dry Fork

Draw

Creek

Little Thunder

North Prong

Little

Creek

Thunder

Black

Creek

Thunder

Black

Creek

Draw

Thunder

Creek

Shipley

Burning

Draw

Coal

Little

Cottonwood

Draw

Keeline

Hansen

Lakes

Springen

Draw

Mills

Draw

Brater Draw

Little

Thunder

Reservoir

Rochelle

Lake

Draw

Manor

Stuart

Reservoir

NP-1

LT-6

NP-5

DIVERSION

CHANNELS

10000 20000

Black Thunder Mine Permit Boundary

North Hilight Field LBA Tract as Applied for

5000

GRAPHIC SCALE (FEET)

0

North Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

LEGEND

Stream Channel (Pre-Mining)

Pond or Reservoir

Playa

TBCC Surface Water NP-1 Monitoring Site

Existing Mine Flood

Control Structure

Figure 3-27. Surface Water Features Within and Adjacent to the North Hilight Field LBA Tract Alternatives.

3.0 Affected Environment and Environmental Consequences

3-136 Final EIS, Wright Area Coal Lease Applications
Reno Road

Road Jacobs

State

Antelope

Edwards

Matheson Road

Reno Road

State 59 Highway

Hilight Road

Highway 450

Road

Road

BNSF & UP RR

31

30

19

18

32

29

20

17

33

28

21

16

34

27

22

15

26

23

14

31

30

19

18

32

29

20

17

33

28

21

16

34

27

22

15

35

26

23

14

36

25

24

13

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

35

26

23

14

36

25

24

13

26

23

14

11

2

36

25

24

13

12

1

14

11

2

13

12

1

18

7

6

17

8

5

16

9

4

15

10

3

14

11

2

13

12

1

18

7

6

17

8

5

16

9

4

15

10

3

14

11

2

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

Draw

Thunder

Little

Creek

Prong

North

Section

School

West

Little

Thunder

Creek

Dry Fork

Little

Nicholson

Draw

Thunder

Creek

Draw

North

Prong

Butte

Black

Cripple

Creek

Olson

Draw

Creek

Porcupine

Little

Draw

Thunder

Creek

Shipley

Burning

Draw

Coal

R. 72 W. R. 71 W.

R. 72 W. R. 71 W.

Keeline

Hansen

Lakes

Springen

Draw

Mills

Draw

Briggs

Draw

Grey Draw

Brater Draw

Little

Thunder

Reservoir

Rochelle

Lake

Draw

Manor

Stuart

Reservoir

NP-1

LT-6

NP-5

FLOOD CONTROL

RESERVOIRS

DIVERSION

CHANNEL

DIVERSION

CHANNELS

PRONGHORN LAKE

(POSTMINE PERMANENT

IMPOUNDMENT) Trussler

Creek

Little Thunder

Creek

10000 20000

Black Thunder Mine Permit Boundary

South Hilight Field LBA Tract as Applied for

South Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

LEGEND

Stream Channel (Pre-Mining)

Pond or Reservoir

Playa

TBCC Surface Water

0 5000 NP-1 Monitoring Site

GRAPHIC SCALE (FEET)

Existing Mine Flood

Control Structure

Figure 3-28. Surface Water Features Within and Adjacent to the South Hilight Field LBA Tract Alternatives.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-137
Reno Road

Road Jacobs

State

Antelope

Edwards

Matheson Road

Reno Road

State 59 Highway

Hilight Road

Highway 450

Road

Road

BNSF & UP RR

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

Draw

Thunder

Little

Creek

Prong

North

Section

School

West

Little

Thunder

Creek

Dry Fork

Little

Nicholson

Draw

Creek

Thunder

Creek

Little Thunder

Draw

NorthProng

Butte

Black

Cripple

Creek

Olson

Draw

Creek

Porcupine

Little

Draw

Thunder

Creek

Shipley Trussler

Creek

Burning

Draw

Coal

Little Thunder

Creek

R. 72 W. R. 71 W.

R. 72 W. R. 71 W.

Hansen

Lakes

Springen

Draw

Mills

Draw

Briggs

Draw

Grey Draw

Brater Draw

Little

Thunder

Reservoir

Rochelle

Lake

Draw

Manor

Stuart

Reservoir

31

30

19

18

32

29

20

17

33

28

21

16

34

27

22

15

3

2

2

1

31

30

19

18

32

29

20

17

33

28

21

16

34

27

22

15

35

26

23

14

36

25

24

13

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

35

26

23

14

36

25

24

13

35

26

23

14

11

2

36

25

24

13

12

1

14

11

2

13

12

1

18

7

6

17

8

5

16

9

4

15

10

3

14

11

2

13

12

1

18

7

6

17

8

5

16

9

4

15

10

3

14

11

2

NP-1

LT-6

NP-5

FLOOD CONTROL

RESERVOIRS

DIVERSION

CHANNELS

PRONGHORN LAKE

(POSTMINE PERMANENT

IMPOUNDMENT)

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Black Thunder Mine Permit Boundary

LEGEND

West Hilight Field LBA Tract as Applied for

West Hilight Field LBA Tract Under Alternative 3

West Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Stream Channel (Pre-Mining)

Pond or Reservoir

Playa

TBCC Surface Water NP-1 Monitoring Site

Existing Mine Flood

Control Structure

Figure 3-29. Surface Water Features Within and Adjacent to the West Hilight Field LBA Tract Alternatives.

3.0 Affected Environment and Environmental Consequences

3-138 Final EIS, Wright Area Coal Lease Applications
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-139 

Springen Draw, an ephemeral tributary to an internally-drained playa, drains a 

small area in the northeastern corner of the West Jacobs Ranch general 

analysis area. Figure 3-30 depicts the surface water features within and 

adjacent to the West Jacobs Ranch LBA Tract. 

The North Porcupine general analysis area and the majority of the existing 

North Antelope Rochelle Mine’s permit area are located in the Porcupine Creek 

watershed. Porcupine Creek is an ephemeral stream in its upper reaches and 

an intermittent stream in its lower reaches. Porcupine Creek is a major 

tributary to Antelope Creek, which is an intermittent stream that, prior to 

mining, received a small degree of baseflow from subcropping coal seams. The 

North Antelope Rochelle Mine disturbs Porcupine Creek and several of its 

tributaries. Only the extreme southern and southwestern portions of the 

mine’s permit area drain directly to Antelope Creek and Horse Creek. The 

North Antelope Rochelle Mine is currently permitted to disturb approximately 

25 percent of the Porcupine Creek watershed. The entire BLM study area for 

the North Porcupine LBA Tract (the tract as applied for and the additional area 

evaluated under Alternative 2) is within the mine’s existing permit area. 

Approximately 6,221 acres, or about 84 percent of the 7,367-acre BLM study 

area for the North Porcupine LBA Tract, drain to Porcupine Creek. A short 

reach of Porcupine Creek, which is a meandering ephemeral stream in this 

area, flows southeastward across the western portion of the North Porcupine 

LBA Tract. Several ephemeral tributaries of Porcupine Creek (e.g., Corder 

Creek, Boss Draw, Rat Draw, Gray Creek, and Chipmunk Draw) also cross the 

North Porcupine general analysis area. The northeastern portion of the North 

Porcupine general analysis area is drained by Trussler and School creeks, 

ephemeral tributaries of Little Thunder Creek. There are also some areas in 

the eastern portion of the general analysis area that do not contribute runoff to 

any stream and playas have formed in the lowest portions of these noncontributing drainage areas. Figure 3-31 depicts the surface water features 

within and adjacent to the North Porcupine LBA Tract. 

Surface water drainage in the South Porcupine LBA Tract is divided, in that the 

northern and eastern portions of the tract drain north and east to Porcupine 

Creek via several ephemeral tributaries, the southern portion of the tract 

drains south to Antelope Creek via several ephemeral tributaries, and the 

western portion of the tract drains west to Horse Creek via several ephemeral 

tributaries. With the exception of about 60 acres, the entire BLM study area 

for the South Porcupine LBA Tract (the tract as applied for and the additional 

area evaluated under Alternative 2) is within the existing mine permit area. 

Figure 3-31 depicts the surface water features within and adjacent to the 

South Porcupine LBA Tract. 

As mentioned above, streams in the general Wright analysis area are 

ephemeral, receiving flow contributions primarily from convective 

thunderstorm runoff and, to a lesser extent, from snowmelt runoff in the spring 

(Ogle and Calle 2006). Black Thunder Creek and Antelope Creek demonstrate 

characteristics of both ephemeral and intermittent streams. Streamflow
Keeline

Road Jacobs

BNSF & UP RR

State 59 Highway

Hilight Road Hilight Road oad

Road

BNSF & UP RR UP RR

State Highway 450

T.

45

N.

T.

44

N.

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

T.

45

N.

T.

44

N.

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

Draw

Thunder

Little

Creek

Prong

North

Creek Hay

Section

School

West

Fork West

Creek

Hay

Hay

Creek

Coal

Fork

Creek

Little

Thunder Creek

Dry Fork

Little

Nicholson

Draw

Creek

Thunder

Creek

Little Thunder

Draw

NorthProng

Butte

Black

Little

Draw

Thunder

Creek

Shipley

Trussler

Creek

Little Thunder

Creek

R. 72 W. R. 71 W.

R. 72 W. R. 71 W.

Draw

Keeline

Hansen

Lakes

Springen

Draw

Mills

Draw

Briggs

Draw

Grey Draw

Brater Draw

Little

Thunder

Reservoir

Rochelle

Lake

Draw

Manor

Stuart

Reservoir

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

34

35 36 31 32 33 34 35 36 31 32 33

DIVERSION

CHANNELS

Jacobs Ranch Mine Permit Boundary

West Jacobs Ranch LBA

Tract as Applied for

0 5000 10000 20000

GRAPHIC SCALE (FEET)

LEGEND

West Jacobs Ranch LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

Stream Channel (Pre-Mining)

Pond or Reservoir

Playa

Existing Mine Flood

Control Structure

Figure 3-30. Surface Water Features Within and Adjacent to the West Jacobs Ranch LBA Tract Alternatives.

3.0 Affected Environment and Environmental Consequences

3-140 Final EIS, Wright Area Coal Lease Applications
Road

Road

Reno Road

Mackey

Antelope

Edwards

Matheson Road

Reno Road

School

Creek

Hilight

Road

Road

Antelope

Road

Road

BNSF & UP RR

Matheson

Road

Mackey Road

32 33 34 35 36 31 32 33 34 35 36 31

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

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

31

30

19

18

7

6

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

T.

43

N.

T.

42

N.

T.

42

N.

T.

41

N.

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

Converse County

Campbell County

T.

43

N.

T.

42

N.

T.

42

N.

T.

41

N.

Olson

Draw

Creek

Gray

Draw

Butte Creek

Creek

Porcupine

Boss

Creek

Corder

Black

Creek

Antelope

Creek

Horse

Creek

Horse

Antelope

Trussler

Creek

Creek

Holmes

School

Creek

Creek

Porcupine

Creek

Creek

Porcupine

GS-1

7656

RS-1 GS-5

RS-5

GS-7

Rat Draw

Mouse

Draw

Chipmunk

Draw

Eagle

Draw

Ed-1

Draw

Redtail

Draw

Payne

Draw

Draw Roger's

Draw

Mike's

Chyr

Draw

FLOOD CONTROL

RESERVOIRS

5000 10000 20000

GRAPHIC SCALE (FEET)

North Antelope Rochelle Mine Permit Boundary

North Porcupine LBA Tract as Applied for

South Porcupine LBA Tract as Applied for

LEGEND

Stream Channel (Pre-Mining)

Pond or Reservoir

Playa

NARM Surface Water

Monitoring Site RS-1

0

North Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

South Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Existing Mine Flood

Control Structure

Figure 3-31. Surface Water Features Within and Adjacent to the North and South Porcupine LBA Tract

Alternatives.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-141
3.0 Affected Environment and Environmental Consequences 

3-142 Final EIS, Wright Area Coal Lease Applications 

monitoring stations have been operated by the U.S. Geological Survey (USGS) 

and the applicant mines on streams in the general Wright analysis area since 

the mid-1970s. Figures 3-27 through 3-31 show the locations of the three 

applicant mines’ current surface water monitoring stations. Currently, and for 

some indefinite time into the future, CBNG discharge water is adding flow to 

surface drainages in the Cheyenne River watershed. Streamflow is still very 

much a function of the amount and timing of precipitation and snowmelt 

runoff; however, since 1999, the PRB of northeastern Wyoming has 

experienced extreme drought conditions. Therefore, the mean annual 

streamflow rate and annual discharge volume has not significantly increased in 

these streams as a result of the discharge of CBNG-produced waters into 

surface drainages west of and generally upstream of the applicant mines, 

although extended periods of no flow are less common (Clark and Mason 2007). 

Water quality in each of these streams is highly dependent on flow. Dissolved 

solids concentrations and specific conductance generally have an inverse 

relationship with streamflow; thus, the highest concentrations occur during 

low flows and lowest concentrations occur during high flows. Total suspended 

solids (TSS) show a direct relationship with streamflow; TSS concentrations are 

typically high during high flow and low during low flows. Due to the sparse 

vegetative cover and the infrequent occurrence of surface water runoff in this 

semi-arid environment, high TSS concentrations can be expected, especially 

from floods caused by thunderstorms. 

Surface water monitoring programs required by WDEQ/LQD are included in 

the three applicant mines’ WDEQ/LQD permits and annual reports, which 

ensures that streamflows are measured and water quality samples are collected 

on a regular basis from Little Thunder Creek, North Prong Little Thunder 

Creek, Porcupine Creek, and Antelope Creek at sites located upstream and 

downstream of the respective mine operation. As a result, comprehensive flow 

and water quality records are submitted to the WDEQ/LQD in the mines’ 

existing permits and annual reports that are on file and available for public 

review at WDEQ’s offices in Cheyenne and Sheridan, Wyoming. 

A study by the USGS within an area of CBNG development in the PRB was 

conducted from 2000 to 2005 to characterize the water quality of streams and 

assess change through time. That study concluded that annual runoff in all 

major drainage basins was less than average during 2001-2005 due to drought 

conditions, and that water-quality characteristics were highly variable generally 

because of streamflow variability, geologic controls, and potential land-use 

effects. No significant trends in water quality were determined for sites in the 

Cheyenne River drainage basin; however, drought conditions during the study 

period may not represent long-term water quality conditions for all sites 

studied (Clark and Mason 2007). 

In the Surface Water Classification List, the WDEQ/WQD has classified Little 

Thunder Creek upstream of its confluence with the North Prong Little Thunder 

Creek as Class 3B water (WDEQ/WQD 2009). The North Prong Little Thunder 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-143 

Creek is also listed as a Class 3B stream that is not known to support fish 

populations or drinking water supplies and where those uses are not 

attainable. As defined by WDEQ/WQD, Class 3B waters are intermittent or 

ephemeral streams with sufficient water present to normally support other 

aquatic life (i.e., invertebrates and amphibians) at some life stage and are 

protected for other aquatic life, recreation, wildlife, agriculture, and other uses. 

Downstream of the North Prong Little Thunder Creek confluence, Little 

Thunder Creek is listed as a 2ABww stream that is protected for drinking 

water, aquatic life (a “ww” notation indicates a warm water fishery), recreation, 

wildlife, agriculture, industry and scenic value. Class 2AB waters are those 

known to support game fish populations at least seasonally and unless shown 

otherwise, are presumed to have sufficient water quantity and quality to 

support drinking water supplies and are protected for that use. 

The WDEQ/WQD has classified Antelope Creek, Porcupine Creek, and Horse 

Creek as Class 3B waters. The Cheyenne River is listed in the WDEQ/WQD 

Surface Water Classification List as a Class 2ABww stream. All other 

ephemeral streams draining the general Wright analysis area are listed as 

Class 4 streams (where it has been determined that aquatic life uses are not 

attainable) (WDEQ/WQD 2009). 

Springs are uncommon and none have been identified within the general 

analysis areas of these six LBA tracts. 

A number of small in-channel reservoirs used for livestock water are located in 

the six LBA tracts’ general analysis areas. Most of these stock ponds are many 

decades old and have not been permitted with the Wyoming State Engineer’s 

Office (SEO). The SEO records have been searched for surface water rights 

within a three-mile radius of the six LBA tracts and listed in Section 3.5.3 and 

the supplementary information document for this EIS. Little Thunder 

Reservoir, a large in-channel reservoir on Little Thunder Creek that is located 

within the BLM study area for the West Hilight Field tract, was constructed by 

the USFS for recreational uses (i.e., fishing) prior to development of the PRB 

surface coal mines. Little Thunder Reservoir is located within the Thunder 

Basin National Grassland (TBNG) and currently accessible for public recreation 

uses. 

3.5.2.2 Environmental Consequences

3.5.2.2.1 Proposed Action and Alternatives 2 and 3

Changes in surface runoff characteristics and sediment discharges would occur 

during mining of each of the LBA tracts as a result of the destruction and 

reconstruction of drainage channels and the use of sediment control structures 

to manage discharges of surface water from the mine permit areas. Since the 

LBA tracts would be mined as extensions of the existing mines under the 

Proposed Actions or Alternatives 2 or 3, 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 
3.0 Affected Environment and Environmental Consequences 

3-144 Final EIS, Wright Area Coal Lease Applications 

result of leasing these tracts. Impacts would be similar for both the Proposed 

Actions and Alternatives 2 and 3 to the expected impacts for the currently 

permitted mining operations. Reclamation would be ongoing and concurrent 

with mining. 

Erosion rates could be high on the disturbed areas due to lack of vegetation. 

However, both state and federal regulations require treatment of surface runoff 

from mined lands to meet Wyoming Pollutant Discharge Elimination System 

(WYPDES) and/or National Pollutant Discharge Elimination System (NPDES) 

effluent standards before it is released downstream. Generally, the surface 

runoff sediment is deposited in ponds or alternative sediment control measures 

(ASCMs) constructed inside the mine’s permit area before the surface runoff 

water is allowed to leave the permit area. While mining is in progress, surface 

water quality would continue to be protected by directing surface runoff from 

affected areas to various sediment control structures, including sediment 

ponds, traps, ditches, sumps, and/or mine pits. Surface runoff water from the 

mine permit area would be detained until testing has shown that effluent 

limitations would be met for water to be discharged. Discharge limitations are 

contained in the mine’s discharge permit. Under normal conditions, 

exceedances of effluent limitations are not expected in the future as mining 

extends into new drainages and additional sediment control facilities are 

added. 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 operations. This 

potential for adverse downstream impacts would be extended if the LBA tracts 

were leased and mined. 

The temporary diversion and impoundment of runoff water for sediment control 

may reduce stream flow volumes and peak flows downstream of the mined 

lands. Impounded water may be used on the mine site for dust control or lost 

due to infiltration and evaporation and therefore may not be released 

downstream. However, in order to maintain adequate available storage volume 

in sedimentation ponds, the impounded water is discharged when it meets 

effluent limitations that are contained in the mine’s discharge permit. The 

WDEQ/LQD encourages the use of ASCMs to trap sediment and allow runoff to 

continue downstream (Ogle and Calle 2006). 

Immediately following reclamation, the loss of soil structure would act to 

increase runoff rates on the LBA tracts. However, the general decrease in 

average slope in reclaimed areas, as discussed in Section 3.2.2, and drainage 

densities common in reclamation would tend to outweigh the potential for an 

increase in runoff due to a loss of soil structure. Soil structure would 

gradually recover over time, and vegetation (after successful reclamation) would 

provide erosion protection from raindrop impact, retard surface flows, and 

control runoff at approximately premining levels. All surface drainage from 

reclaimed areas would be controlled using best management practices (BMPs), 

such as contour furrows, ponds or small depressions for sediment traps, and 

vegetation buffers, until the area is sufficiently stable that drainage control is 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-145 

no longer required. Sedimentation rates are expected to be similar to 

premining conditions. Surface water monitoring would continue to be 

conducted to evaluate and identify anomalous variations in surface water 

quantity and quality and ensure that runoff leaving the site meets specific 

water quality criteria. 

Once mining is completed the pits would be backfilled and drainage would be 

reestablished. Surface water drainages would be designed and reconstructed 

to approximate the premining drainage basin and channel characteristics. The 

reclaimed drainageways would be constructed to approximate the premine 

condition and blend with the existing drainage system above and below the 

area disturbed by the mining operation, providing a complete drainage system 

with hydrologic functions similar to premining conditions. After mining and 

reclamation are complete, surface water flow and quality would approximate 

premining conditions. The impacts described above would be similar to the 

expected impacts for currently permitted mining operations. 

The impacts described above would be similar for both the Proposed Actions 

and BLM’s preferred tract configurations under Alternative 2, and they are 

similar to the expected impacts for the currently permitted mining operations. 

Direct and indirect impacts to the surface water system resulting from mining 

the six LBA tracts would add to the cumulative impacts that would occur due 

to mining existing leases. These cumulative impacts are discussed in Chapter 

4 of this EIS. Following is a description of surface water impacts from the 

leasing and subsequent mining of each of the LBA tracts under the Proposed 

Action or Alternative 2, BLM’s preferred alternative. 

3.5.2.2.1.1 North, South, and West Hilight Field LBA Tracts

Due to the North Hilight Field tract’s location at the headwater areas of two 

ephemeral tributaries to Black Thunder Creek and North Prong Little Thunder 

Creek (Keeline Draw and Mills Draw, respectively), and due to the fact that the 

balance of the general analysis area for the North Hilight Field tract drains to 

playas with no nexus (continuous surface connection) to tributaries of either 

Black Thunder Creek or North Prong Little Thunder Creek, runoff within the 

tract would not be expected to be significant. During mining, hydrologic 

control would most likely consist of allowing runoff to accrue to the open mine 

pits where it would be evacuated by pumping to sedimentation ponds, then 

used for dust abatement or treated and discharged outside the mine’s permit 

area if the water meets effluent limitations. A need for large flood control 

reservoirs is not anticipated for the North Hilight Field LBA Tract. 

There may periodically be substantial streamflow in Little Thunder Creek 

within the South Hilight Field LBA Tract. Little Thunder Creek has been 

diverted around active pits within the existing Black Thunder Mine permit 

area. A large flood control reservoir is located on Little Thunder Creek 

upstream of the current mining activities, and overflow from the reservoir is 

then diverted north around the open pits to a blocking dike that diverts water 
3.0 Affected Environment and Environmental Consequences 

3-146 Final EIS, Wright Area Coal Lease Applications 

into the diversion system constructed on North Prong Little Thunder Creek 

(Figure 3-28). Diverted flows from Little Thunder Creek, being native water and 

not treated, are routed through the diversion system and discharged outside 

and downstream of the mine’s permit area. During mining of the South Hilight 

Field tract, hydrologic control would most likely consist of building another 

flood control reservoir and diversion channel for the main stream around the 

open pit areas. These structures would be located west of the tract to provide 

adequate flood protection of the downstream mining activities. In addition to 

diverting Little Thunder Creek flows, hydrologic control during mining would 

most likely consist of allowing surface runoff to accrue to the mine pits where it 

would be evacuated by pumping to sedimentation ponds, then used for dust 

abatement or treated and discharged outside the mine’s permit area if the 

water meets effluent limitations. Nearly half of the BLM study area for the 

South Hilight Field LBA Tract is internally drained and runoff has no nexus (or 

continuous surface connection) to Little Thunder Creek; therefore, it would not 

be necessary for additional flood control structures to be constructed. 

The West Hilight Field LBA Tract is located near the headwaters of Little 

Thunder Creek, and because much of the general analysis area for West Hilight 

Field tract is drained by Little Thunder Creek and its tributaries (e.g., Briggs 

Draw), which are all ephemeral streams, runoff within the tract would not be 

expected to be substantial. As discussed above, most of the surface of the LBA 

tract north of Little Thunder Creek is internally drained and runoff has no 

nexus to Little Thunder Creek. Playas, such as Rochelle Lake, occur in the 

lowest portions of these non-contributing drainages. Therefore, a need for 

large flood control reservoirs during mining is not anticipated for the LBA tract. 

Hydrologic control during mining would most likely consist of allowing runoff to 

accrue to the mine pits where it would evacuated by pumping to sedimentation 

ponds and then used for dust control or treated and discharged outside the 

mine’s permit area if the water meets effluent limitations. 

3.5.2.2.1.2 West Jacobs Ranch LBA Tract

North Prong Little Thunder Creek and its tributaries, Dry Fork Little Thunder 

Creek and School Section Draw, drain essentially all of the general analysis 

area for the West Jacobs Ranch LBA Tract. The balance of the general analysis 

area is drained by non-contributing, internal drainage basins containing playas 

(Figure 3-30). The West Jacobs Ranch LBA Tract is located near the 

headwaters of these ephemeral streams; therefore, runoff within the tract 

would not be expected to be substantial and a need for large flood control 

reservoirs is not anticipated for the LBA tract. Hydrologic control during 

mining would most likely consist of containing flows from these ephemeral 

streams in small flood control reservoirs, routing flows in small channel 

diversions around active pits, or allowing runoff to accrue to the mine pits 

where it would evacuated by pumping to sedimentation ponds and then used 

for dust control or treated and discharged outside the mine’s permit area if the 

water meets effluent limitations. The exact plan for hydrologic control would 

depend on the mining sequence. 
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Final EIS, Wright Area Coal Lease Applications 3-147 

3.5.2.2.1.3 North and South Porcupine LBA Tracts

There may periodically be substantial streamflow in Porcupine Creek in the 

vicinity of the North Porcupine LBA Tract. Flood control reservoirs are 

presently located on Porcupine Creek and its larger tributaries, Boss Draw and 

Corder Creek, upstream of the current mining activities (Figure 3-31). 

Overflow from these reservoirs is allowed to accrue to the open mine pits where 

it is evacuated by pumping to sedimentation ponds and then used for dust 

abatement or discharged outside the mine’s permit area if the water meets 

effluent limitations. During mining of the North Porcupine LBA Tract, 

hydrologic control would most likely consist of building another flood control 

reservoir on Porcupine Creek. The remainder of the general analysis area is 

located near the headwaters of ephemeral tributaries to Porcupine Creek and is 

also drained by non-contributing, internal drainage basins; therefore, runoff 

within the tract would not be expected to be substantial. Hydrologic control 

during mining would most likely consist of containing flows from these 

ephemeral tributary streams in small flood control reservoirs, routing flows in 

small channel diversions around active pits, and/or allowing runoff to accrue 

to the mine pits where it would be evacuated by pumping to sedimentation 

ponds and then used for dust control or treated and discharged outside the 

mine’s permit area if the water meets effluent limitations. The exact plan for 

hydrologic control would depend on the mining sequence. 

As discussed above, the entire South Porcupine LBA Tract is drained by 

ephemeral tributaries of Porcupine Creek, Horse Creek, and Antelope Creek 

(Figure 3-31). Due to its location at the headwaters of these drainages, runoff 

would not be expected to be significant. During mining, hydrologic control 

would most likely consist of allowing runoff to accrue to the mine pits where it 

would be evacuated by pumping to sedimentation ponds and then used for 

dust control or treated and discharged outside the mine’s permit area if the 

water meets effluent limitations. 

3.5.2.2.2 No Action Alternative

Under the No Action Alternatives, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and coal removal and the associated 

impacts to surface water resources would not occur on the portions of the LBA 

tracts as applied for or the LBA tracts configured under Alternative 2 that will 

not be disturbed under the currently approved surface coal mining permits. 

Coal removal and the associated impacts to surface water resources related to 

currently approved mining (and CBNG development, described above) would 

continue as currently permitted within the existing Black Thunder, Jacobs 

Ranch, and North Antelope Rochelle Mine permit areas. Impacts to surface 

water resources related to mining operations at these three applicant mines 

would not be extended onto portions of the LBA tracts that will not be affected 

under the current mining and reclamation plans. 
3.0 Affected Environment and Environmental Consequences 

3-148 Final EIS, Wright Area Coal Lease Applications 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective tract in the future. 

3.5.2.3 Regulatory Compliance, Mitigation, and Monitoring

In accordance with SMCRA and Wyoming State Statutes, major stream 

channels that are disturbed by surface coal mining operations on these six LBA 

tracts would be restored. Surface water flow, quality, and sediment discharge 

would approximate premining conditions. The drainages that are disturbed 

when the coal is recovered 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 would be restored. (See additional discussion in 

Section 3.5.1.3.) 

Other WDEQ/LQD permit requirements for the existing Black Thunder, Jacobs 

Ranch, and North Antelope Rochelle mines include constructing sediment 

control structures to manage discharges of surface water from the current 

mine permit areas; treatment of all surface runoff from mined lands as 

necessary to meet effluent standards; and restoration of stock ponds, playas, 

and in-channel impoundments disturbed during mining. These requirements 

would be extended to include the North Hilight Field, South Hilight Field, West 

Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA 

Tracts during the permitting process, if the tracts are leased. 

Monitoring requirements for each of the existing applicant mines include a 

program to assure that sediment ponds always have adequate space reserved 

for sediment accumulation and for collection of streamflow and water quality 

data from North Prong Little Thunder Creek, Little Thunder Creek, and 

Porcupine Creek (Figures 3-27 through 3-31). These requirements would be 

extended accordingly and included in the mine permit amendment that would 

be required for each respective LBA tract that is leased. Mine permit revisions 

must be approved before mining could occur on each tract that is leased, 

regardless of who acquires the tract. 

3.5.3 Water Rights

3.5.3.1 Affected Environment

The Wyoming State Engineer’s Office (SEO) administers water rights in 

Wyoming. Water rights are granted for both groundwater and surface water. 

Prior to development of water resources associated with energy development, 

water appropriations (either groundwater or surface water) in the PRB were 

typically for livestock use. Currently, mining companies and CBNG 

development companies hold the majority of the water rights in the general 

Wright analysis area. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-149 

Records of the SEO were searched for groundwater rights within a 3-mile 

radius of the BLM study area for each of these six LBA tracts. This information 

is required by the WDEQ/LQD for surface coal mine permitting. Summaries of 

the most recent search for each tract are provided below. A more detailed 

listing of the non-coal mine related groundwater rights within a 3-mile radius 

of each LBA tract is presented in the supplementary information document for 

this EIS, which is available on request. 

For the North Hilight Field LBA Tract, SEO data indicate that, as of October 9, 

2007, there were 609 permitted water wells within 3 miles of the BLM study 

area for the tract, of which, 191 wells are owned by coal mining companies. 

The other 418 non-coal mine related, permitted water wells, which include 314 

wells permitted for uses related to CBNG development, are permitted for the 

following uses: 

• 314 CBNG 

• 61 livestock 

• 16 domestic 

• 14 monitoring 

• 5 industrial 

• 8 miscellaneous 

For the South Hilight Field LBA Tract, SEO data indicate that, as of October 8, 

2007, there were 694 permitted water wells within 3 miles of the BLM study 

area for the tract, of which, 211 wells are owned by coal mining companies. 

The other 483 non-coal mine related, permitted water wells, which include 425 

wells permitted for uses related to CBNG development, are permitted for the 

following uses: 

• 425 CBNG 

• 39 livestock 

• 2 domestic 

• 17 monitoring 

For the West Hilight Field LBA Tract, SEO data indicate that, as of October 8, 

2007, there were 1,011 permitted water wells within 3 miles of the BLM study 

area for the tract, of which, 149 wells are owned by coal mining companies. 

The other 862 non-coal mine related, permitted water wells, which include 750 

wells permitted for uses related to CBNG development, are permitted for the 

following uses: 

• 750 CBNG 

• 69 livestock 

• 20 domestic 

• 19 monitoring 

• 1 miscellaneous 

• 3 municipal 
3.0 Affected Environment and Environmental Consequences 

3-150 Final EIS, Wright Area Coal Lease Applications 

For the West Jacobs Ranch LBA Tract, SEO data indicate that, as of September 

30, 2007, there were 1,171 permitted water wells within 3 miles of the BLM 

study area for the tract, of which, 231 wells are owned by coal mining 

companies. The remaining 940 non-coal mine related, permitted water wells, 

which include 645 wells permitted for uses related to CBNG development, are 

permitted for the following uses: 

• 440 CBNG only 

• 181 livestock and CBNG 

• 117 monitoring only 

• 76 livestock only 

• 34 miscellaneous 

• 17 domestic and livestock 

• 14 domestic only 

• 9 livestock, CBNG, and reservoir supply 

• 8 livestock, CBNG, and miscellaneous 

• 7 miscellaneous and CBNG 

• 7 municipal only 

• 6 industrial only 

• 6 miscellaneous and reservoir supply 

• 6 livestock, miscellaneous, dewatering, and reservoir supply 

• 3 irrigation only 

• 3 miscellaneous and municipal 

• 1 dewatering 

• 1 miscellaneous, industrial and temporary 

• 1 livestock, industrial and miscellaneous 

• 1 livestock, miscellaneous and monitoring 

• 1 industrial and miscellaneous 

• 1 testing 

For the North Porcupine LBA Tract, SEO data indicate that, as of August 1, 

2008, there were 982 permitted water wells within 3 miles of the BLM study 

area for the tract, of which, 354 wells are owned by coal mining companies. 

The other 628 non-coal mine related, permitted water wells, which include 547 

wells permitted for uses related to CBNG development, are permitted for the 

following uses: 

• 260 CBNG only 

• 173 livestock and CBNG 

• 84 CBNG and miscellaneous 

• 48 livestock only 

• 23 monitoring only 

• 20 CBNG and reservoir supply 

• 5 domestic and livestock 

• 4 livestock, CBNG, and miscellaneous 

• 3 dewatering and CBNG 

• 2 industrial only 

• 1 CBNG, reservoir supply and livestock 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-151 

• 1 domestic only 

• 1 miscellaneous 

• 1 livestock, CBNG, and reservoir supply 

• 1 livestock and miscellaneous 

• 1 livestock, miscellaneous and CBNG 

For the South Porcupine LBA Tract, SEO data indicate that, as of August 1, 

2008, there were 779 permitted water wells within 3 miles of the tract, of 

which, 388 wells are owned by coal mining companies. The other 391 non-coal 

mine related, permitted water wells, which include 324 wells permitted for uses 

related to CBNG development, are permitted for the following uses: 

• 173 CBNG only 

• 70 CBNG and miscellaneous 

• 57 livestock and CBNG 

• 37 livestock only 

• 20 CBNG and reservoir supply 

• 18 monitoring 

• 6 domestic and livestock 

• 3 dewatering and CBNG 

• 3 industrial only 

• 2 miscellaneous 

• 1 livestock and miscellaneous 

• 1 livestock, miscellaneous and CBNG 

SEO records have been searched for surface water rights within a 3-mile radius 

of the BLM study area for each of the six LBA tracts. Like the groundwater 

rights, this information is also required for WDEQ permitting. The results of 

the most recent searches are provided below for each tract. A more detailed 

listing of the non-coal mine related surface water rights is presented in the 

supplementary information document for this EIS, which is available on 

request. 

For the North Hilight Field LBA Tract, SEO records indicate that as of October 

10, 2007, there were 104 permitted surface water rights within the search area, 

of which 46 are owned by coal mining companies. The other 58 non-coal mine 

related permitted surface water rights are permitted for the following uses: 

• 3 livestock 

• 1 irrigation and domestic 

• 54 not designated 

For the South Hilight Field LBA Tract, SEO records indicate that as of October 

10, 2007, there were 143 permitted surface water rights within the search area, 

of which 70 are owned by coal mining companies. The other 73 non-coal mine 

related permitted surface water rights are permitted for the following uses: 

• 21 livestock 
3.0 Affected Environment and Environmental Consequences 

3-152 Final EIS, Wright Area Coal Lease Applications 

• 2 irrigation 

• 50 not designated 

For the West Hilight Field LBA Tract, SEO records indicate that as of October 

9, 2007, there were 141 permitted surface water rights within the search area, 

of which 36 are owned by coal mining companies. The other 105 non-coal 

mine related permitted surface water rights are permitted for the following 

uses: 

• 19 livestock 

• 3 irrigation 

• 83 not designated 

For the West Jacobs Ranch LBA Tract, SEO records indicate that as of 

September 30, 2007, there were 150 permitted surface water rights within the 

search area, of which 33 are owned by coal mining companies. The remaining 

117 surface water rights were permitted for the following uses: 

• 73 livestock 

• 3 livestock and irrigation 

• 2 industrial and temporary 

• 1 fish propagation 

• 1 reservoir supply 

• 37 not designated 

For the North Porcupine LBA Tract, SEO records indicate that as of August 1, 

2008, there were 335 non-coal mine related, permitted surface water rights 

within the search area. These surface water rights were permitted for the 

following uses: 

• 260 livestock 

• 33 irrigation 

• 3 irrigation and domestic 

• 16 livestock, irrigation and domestic 

• 5 undefined 

• 4 temporary, industrial and miscellaneous 

• 3 fish propagation and recreation 

• 3 recreation, livestock, and fish propagation 

• 2 industrial and pollution control 

• 2 livestock and irrigation 

• 2 wetlands 

• 1 industrial 

• 1 industrial and temporary 

For the South Porcupine LBA Tract, SEO records indicate that as of August 1, 

2008, there were 223 non-coal mine related, permitted surface water rights 

within the search area. These surface water rights are permitted for the 

following uses: 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-153 

• 157 livestock 

• 37 irrigation 

• 7 undefined 

• 4 industrial and flood control 

• 4 temporary and industrial 

• 4 temporary, industrial and miscellaneous 

• 3 irrigation and livestock 

• 3 livestock and irrigation 

• 2 industrial and pollution control 

• 1 industrial 

• 1 industrial and temporary 

3.5.3.2 Environmental Consequences

3.5.3.2.1 Proposed Action and Alternatives 2 and 3

As discussed above, there have already been significant drawdowns in the 

Wyodak coal and overlying aquifers (where present) as a result of the past and 

existing mining activities and CBNG development in the general Wright 

analysis area. As a result, private water supply wells that are completed in the 

Wyodak coal seam listed in Section 3.5.3.1 have already been impacted. 

Continued effects from groundwater withdrawals associated with CBNG 

development activities are probable, and future drawdown to the Wyodak coal 

aquifer resulting from mining the approved coal leases by the three applicant 

mines is expected to be negligible due to the fact that the coal seam has 

essentially been dewatered in proximity to the mines. Therefore, it is unlikely 

that any of these privately permitted water wells would be indirectly impacted 

by water level drawdown to a greater extent than current conditions; however, 

private wells may be physically removed by activities associated with mining 

the proposed LBA tracts. 

Only a slight reduction in streamflow downstream of the applicant mines 

during mining is expected due to the containment of runoff from the disturbed 

areas by mine pits and other runoff control structures. Downstream surface 

water rights would be protected by minimizing detention of surface runoff for 

sediment control in North Prong Little Thunder Creek, Little Thunder Creek 

and Porcupine Creek. Changes to the overall flow and water quality of these 

streams and their receiving streams, Black Thunder Creek, Antelope Creek, 

and Cheyenne River) during mining are expected to be negligible. Any surface 

water rights listed in Section 3.5.3.1 that are located within the proposed 

mining disturbance areas would be interrupted until the disturbance area is 

reclaimed. 

3.5.3.2.1.1 North Hilight Field LBA Tract

In October 2007, Wyoming SEO records indicated that a total of 609 permitted 

water wells were located within 3 miles of the BLM study area for the North 

Hilight Field LBA Tract. As discussed above, 191, or approximately 31 percent 
3.0 Affected Environment and Environmental Consequences 

3-154 Final EIS, Wright Area Coal Lease Applications 

of these wells are owned by coal mining companies and are used for 

groundwater monitoring and water supply. Approximately 75 percent of the 

remaining 418 non-coal mine related wells are permitted for uses related to 

CBNG development; 15 percent are permitted for livestock use; 4 percent are 

permitted for domestic use; 3 percent are permitted for monitoring uses; 1 

percent are permitted for industrial uses; and about 2 percent are permitted for 

miscellaneous uses. 

As discussed above, some of these privately permitted water wells have been or 

will likely be impacted (either directly by removal of the well or indirectly by 

water level drawdown) by approved mining at the Black Thunder and adjacent 

mines and CBNG development. Future drawdowns to the Wyodak coal aquifer 

are expected to be negligible due to the fact that the coal seam has essentially 

been dewatered. Therefore, it is unlikely that any of these privately permitted 

water wells would be impacted by water level drawdown to a greater extent 

than they currently are if the North Hilight LBA Field Tract is leased and 

mined. 

3.5.3.2.1.2 South Hilight Field LBA Tract

In October 2007, Wyoming SEO records indicated that a total of 694 permitted 

water wells were located within 3 miles of the BLM study area for the South 

Hilight Field LBA Tract. As discussed above, 211, or approximately 30 percent 

of these wells are owned by coal mining companies and are used for 

groundwater monitoring and water supply. Approximately 88 percent of the 

remaining 483 non-coal mine related wells are permitted for uses related to 

CBNG development; 8 percent are permitted for livestock use; 0.5 percent are 

permitted for domestic use; and 3.5 percent are permitted for monitoring uses. 

As discussed above, some of these privately permitted water wells have been or 

will likely be impacted (either directly by removal of the well or indirectly by 

water level drawdown) by approved mining at the Black Thunder and adjacent 

mines and CBNG development. Future drawdowns to the Wyodak coal aquifer 

are expected to be negligible due to the fact that the coal seam has essentially 

been dewatered. Therefore, it is unlikely that any of these privately permitted 

water wells would be impacted by water level drawdown to a greater extent 

than they currently are if the South Hilight Field LBA Tract is leased and 

mined. 

3.5.3.2.1.3 West Hilight Field LBA Tract

In October 2007, Wyoming SEO records indicated that a total of 1,011 

permitted water wells were located within 3 miles of the BLM study area for the 

West Hilight Field LBA Tract. As discussed above, 149, or approximately 15 

percent of these wells are owned by coal mining companies and are used for 

groundwater monitoring and water supply. Approximately 87 percent of the 

remaining 862 non-coal mine related wells are permitted for uses related to 

CBNG development; 8 percent are permitted for livestock use; 2.3 percent are 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-155 

permitted for domestic use; 2.2 percent are permitted for monitoring; and 

about 0.5 percent are permitted for miscellaneous and municipal uses. 

As discussed above, some of these privately permitted water wells have been or 

will likely be impacted (either directly by removal of the well or indirectly by 

water level drawdown) by approved mining at the Black Thunder and adjacent 

mines and CBNG development. Future drawdowns to the Wyodak coal aquifer 

are expected to be negligible due to the fact that the coal seam has essentially 

been dewatered. Therefore, it is unlikely that any of these privately permitted 

water wells would be impacted by water level drawdown to a greater extent 

than they currently are if the West Hilight Field LBA Tract is leased and mined. 

3.5.3.2.1.4 West Jacobs Ranch LBA Tract

In September 2007, Wyoming SEO records indicated that a total of 1,171 

permitted water wells were located within 3 miles of the BLM study area for the 

West Jacobs Ranch LBA Tract. As discussed above, 231, or approximately 20 

percent of these wells are owned by coal mining companies and are used for 

groundwater monitoring and water supply. Approximately 69 percent of the 

remaining 940 non-coal mine related wells are permitted for uses related to 

CBNG development; 11 percent are permitted either for livestock use only or for 

livestock and other uses; 12 percent are permitted for monitoring; 5 percent 

are permitted for miscellaneous uses; about 1.5 percent are permitted for 

domestic use; and about 1.5 percent are permitted for municipal, industrial, 

irrigation, dewatering and testing. 

As discussed above, some of these privately permitted water wells have been or 

will likely be impacted (either directly by removal of the well or indirectly by 

water level drawdown) by approved mining at the Jacobs Ranch and adjacent 

mines and CBNG development. Future drawdowns to the Wyodak coal aquifer 

are expected to be negligible due to the fact that the coal seam has essentially 

been dewatered. Therefore, it is unlikely that any of these privately permitted 

water wells would be impacted by water level drawdown to a greater extent 

than they currently are if the West Jacobs Ranch LBA Tract is leased and 

mined. 

3.5.3.2.1.5 North Porcupine LBA Tract

In August 2008, Wyoming SEO records indicated that a total of 982 permitted 

water wells were located within 3 miles of the BLM study area for the North 

Porcupine LBA Tract. As discussed above, 354, or approximately 36 percent of 

these wells are owned by coal mining companies and are used for groundwater 

monitoring and water supply. Approximately 87 percent of the remaining 628 

non-coal mine related wells are permitted for uses related to CBNG 

development; about 8 percent are permitted for livestock use only; about 4 

percent are permitted for monitoring; and about 1 percent are permitted for 

domestic, livestock, industrial and miscellaneous uses. 
3.0 Affected Environment and Environmental Consequences 

3-156 Final EIS, Wright Area Coal Lease Applications 

As discussed above, some of these privately permitted water wells have been or 

will likely be impacted (either directly by removal of the well or indirectly by 

water level drawdown) by approved mining at the North Antelope Rochelle and 

adjacent mines and CBNG development. Future drawdowns to the Wyodak 

coal aquifer are expected to be negligible due to the fact that the coal seam has 

essentially been dewatered. Therefore, it is unlikely that any of these privately 

permitted water wells would be impacted by water level drawdown to a greater 

extent than they currently are if the North Porcupine LBA Tract is leased and 

mined. 

3.5.3.2.1.6 South Porcupine LBA Tract

In August 2008, Wyoming SEO records indicated that a total of 779 permitted 

water wells were located within 3 miles of the BLM study area for the South 

Porcupine LBA Tract. As discussed above, 388, or approximately 50 percent of 

these wells are owned by coal mining companies and are used for groundwater 

monitoring and water supply. Approximately 83 percent of the remaining 391 

non-coal mine related wells are permitted for uses related to CBNG 

development; about 9.5 percent are permitted for livestock use only; about 4.5 

percent are permitted for monitoring; and about 3 percent are permitted for 

domestic, livestock, industrial and miscellaneous uses. 

As discussed above, some of these privately permitted water wells have been or 

will likely be impacted (either directly by removal of the well or indirectly by 

water level drawdown) by approved mining at the North Antelope Rochelle and 

adjacent mines and CBNG development. Future drawdowns to the Wyodak 

coal aquifer are expected to be negligible due to the fact that the coal seam has 

essentially been dewatered. Therefore, it is unlikely that any of these privately 

permitted water wells would be impacted by water level drawdown to a greater 

extent than they currently are if the South Porcupine LBA Tract is leased and 

mined. 

3.5.3.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and coal removal and associated 

disturbance and impacts to water rights would not occur on the portions of the 

LBA tracts as applied for or the LBA tracts configured under Alternative 2 that 

will not be disturbed under the currently approved surface coal mining 

permits. Coal removal and the impacts to water rights associated with existing 

approved mining and CBNG development as described above would continue to 

occur. Impacts to water rights related to mining operations at these three 

applicant mines would not be extended onto portions of the LBA tracts that will 

not be affected under the current mining and reclamation plans. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-157 

As discussed in Section 2.2, a decision to reject one or more of these six lease 

applications at this time would not preclude an application to lease that 

respective tract in the future. 

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 2 and 3. The most probable source of replacement water would be 

one of the aquifers underlying the mineable coal (Wyodak or WyodakAnderson). For example, the subcoal Fort Union Formation aquifers are not 

removed or disturbed by coal mining, and would therefore be a potential source 

of replacement water. 

If the North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs 

Ranch, North Porcupine, and South Porcupine LBA Tracts are 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 5-foot 

drawdown contour as part of the WDEQ/LQD mine permitting process. The 

operator would be required to commit to replacing those water supplies with 

water of equivalent quality and quantity if they are predicted to be affected by 

mining 

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 2 and 3 compared with the area of coal and overburden 

removal and overburden replacement and associated groundwater drawdowns 

for each of the three existing applicant mines. The postmining backfill may 

take in excess of 100 years to fully resaturate and reach equilibrium water 

levels and water quality. Less time would be required near the mining 

boundaries. Monitoring data from wells completed in existing backfilled areas 

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 livestock and wildlife use, which was the primary premining use 

of water from the coal seams. The hydraulic properties and water quality 

characteristics of the backfill may be somewhat different than that of the 

undisturbed overburden and Wyodak coal, although groundwater at 

comparable depth, yield, and quality would be available for the same premining 

uses within the general analysis areas of these six LBA tracts. 
3.0 Affected Environment and Environmental Consequences 

3-158 Final EIS, Wright Area Coal Lease Applications 

3.6 Alluvial Valley Floors 

3.6.1 Affected Environment

WDEQ regulations define alluvial valley floors (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. Following these studies, areas passing the limiting criteria that are 

identified as AVFs are evaluated for their significance to farming by 

WDEQ/LQD. 

SMCRA prohibits surface coal mining 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. However, 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, these 

prohibitions would not apply and mining would be allowed. The prohibitions 

also apply if AVFs that are downstream of the area proposed for mining would 

be affected by disruptions in streamflow. Provided WDEQ determines that an 

AVF is not significant to agriculture, it can be disturbed by mining but must be 

restored as part of the reclamation process. For any designated AVF, 

regardless of its significance to agriculture, it must be demonstrated that the 

essential hydrologic functions of the AVF, both within and outside the mine 

area, will be protected. 

In a decision by the U.S. District Court for the District of Columbia, Civil Action 

Number 69-1144 (1980) (known as the Flannery Decision), the court noted that 

an AVF must satisfy both geologic criteria (unconsolidated stream laid deposits) 

and hydrologic criteria (water sufficient to sustain agriculture). Therefore, the 

court emphasized that the key to the existence of an AVF is the presence of 

both geologic and water availability characteristics, which together sustain 

agricultural activities. 

Investigations have been conducted by TBCC, JRCC, and PRC to determine the 

presence of AVFs within and surrounding the Black Thunder, Jacobs Ranch, 

and North Antelope Rochelle mines, respectively. AVF investigations conducted 

within and near the general Wright analysis area have identified AVFs that 

occur along Little Thunder Creek, North Prong Little Thunder Creek, and 

Porcupine Creek; however, those lands are located at considerable distances 

downstream of the six LBA tracts included in this analysis. Refer to Figure 3-

26 for the location of the major streams with respect to the applicant mines 

and LBA tracts in the general Wright analysis area. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-159 

The investigations concluded, and WDEQ concurred, that an AVF that is 

significant to agriculture exists at the confluence of North Prong Little Thunder 

Creek and Little Thunder Creek. WDEQ/LQD declared 194 acres along the 

lower reach of North Prong Little Thunder Creek and 143 acres along Little 

Thunder Creek, and the declared AVF extends from near the eastern edge of 

the Black Thunder Mine permit boundary downstream (eastward) to the 

streams’ confluence. 

AVF investigations concluded, and WDEQ concurred, that an AVF exists along 

the lower reach of Porcupine Creek. WDEQ/LQD declared that a narrow area 

adjacent to the Porcupine Creek channel, totaling 39 acres, is an AVF not 

significant to agriculture. North Antelope Rochelle Mine was allowed to mine 

this area after WDEQ approved the mine’s plan to preserve the essential 

hydrologic functions of the AVF along Porcupine Creek. Sections of Porcupine 

Creek have been mined and reclaimed in this area since 1984. In addition, a 

250-acre flood-irrigated hay meadow that exists near the confluence of 

Porcupine Creek and Antelope Creek has been determined by WDEQ/LQD to 

be an AVF significant to agriculture. This hay meadow, which is irrigated by 

surface water diverted from Antelope Creek and stored in a nearby reservoir 

(Porcupine Reservoir), is the only flood-irrigated land that has been identified in 

and near the general Wright analysis area. Special measures have been 

designated to ensure that the North Antelope Rochelle Mine will not interrupt 

or preclude farming on the flood-irrigated lands, and Porcupine Creek 

downstream from the mine’s facilities will not be affected by mining. No other 

AVFs identified in this area have been determined by WDEQ/LQD to be 

significant to agriculture. 

3.6.1.1 North Hilight Field LBA Tract

Numerous ephemeral drainages occur within the general analysis area for the 

North Hilight Field LBA Tract, although the stream laid deposits associated 

with these drainages are very limited in areal extent and not capable of 

supporting subirrigation or flood irrigation agricultural activities. Surface 

water quantity is insufficient to support natural or artificial flood irrigation 

practices, and historic flood irrigation attempts have not been identified along 

Mills Draw, Keeline Draw, or Springen Draw. Due to its limited areal extent, 

limited saturated thickness, and low hydraulic conductivity, alluvial deposits 

associated with these streams do not consistently produce enough water to be 

put to beneficial use. Furthermore, the alluvial groundwater is generally of 

such poor quality that it does not meet WDEQ/WQD standards for agricultural 

use (refer to Section 3.5.1.1.1). The soils that dominate the drainage bottoms 

within the general analysis area for the tract are classified by the Natural 

Resource Conservation Service (NRCS) as unsuitable for irrigation. 

If the North Hilight Field LBA Tract is leased and proposed for mining, an AVF 

assessment would be part of the mine permitting process, and formal 

declarations of the presence or absence of an AVF, its significance to 

agriculture, and the appropriate perimeter (areal extent) would be made by the 
3.0 Affected Environment and Environmental Consequences 

3-160 Final EIS, Wright Area Coal Lease Applications 

WDEQ/LQD as part of the permitting process. Based on previous non-AVF 

declarations made on Mills Draw and Springen Draw within and adjacent to 

the existing Jacobs Ranch Mine permit area, which includes a portion of the 

BLM study area for the North Hilight Field LBA Tract, it is unlikely that 

WDEQ/LQD would declare that any AVFs exist in the general analysis area for 

the North Hilight Field tract. 

3.6.1.2 South Hilight Field LBA Tract

As discussed in Section 3.5.1.1.1, within the BLM study area for the South 

Hilight Field LBA Tract, alluvial deposits are primarily associated with Little 

Thunder Creek. Little Thunder Creek and its tributaries within and extending 

a half mile beyond Black Thunder Mine’s existing permit boundary have been 

formally investigated for the presence of AVFs by TBCC. Therefore, the entire 

length of Little Thunder Creek within the South Hilight Field LBA Tract has 

been investigated, and the reports of these studies are contained in Black 

Thunder Mine’s WDEQ/LQD mine permit (TBCC 2005). These investigations 

concluded, and WDEQ has concurred, that no AVFs exist along Little Thunder 

Creek within the South Hilight Field LBA Tract. The declared AVF at the North 

Prong Little Thunder Creek and Little Thunder Creek confluence is located 

several miles downstream from the LBA tract and would not be affected by 

mining and reclamation within the tract. 

Other drainages on the South Hilight Field tract are much smaller and AVF 

characteristics are negligible. Few stream laid deposits are present, the 

streams do not consistently produce enough runoff to be put to beneficial use, 

and the soils that dominate the drainage bottoms within the general analysis 

area are classified by the NRCS as unsuitable for irrigation. In addition, there 

are no present or historical records of agricultural use, other than undeveloped 

range land, of the stream channels and associated stream laid deposits within 

the general analysis area for the tract. If the South Hilight Field LBA Tract is 

leased and proposed for mining, an AVF assessment would be part of the mine 

permitting process. Based on previous non-AVF declarations made on Little 

Thunder Creek within and adjacent to the South Hilight Field LBA Tract, it is 

unlikely that the WDEQ/LQD would declare that an AVF is present within the 

general analysis area for the tract. 

3.6.1.3 West Hilight Field LBA Tract

Alluvial deposits within the BLM study area for the West Hilight Field LBA 

Tract are, like the adjacent South Hilight Field tract, primarily associated with 

Little Thunder Creek. As discussed above, Little Thunder Creek and its 

tributaries within and extending a half mile beyond Black Thunder Mine’s 

existing permit boundary have been investigated for the presence of AVFs by 

TBCC. Therefore, Little Thunder Creek has not been formally investigated for 

the presence of AVFs within the general analysis area for the West Hilight Field 

LBA Tract. Based on previous non-AVF declarations made on Little Thunder 

Creek downstream of the West Hilight Field LBA Tract, it is unlikely that the 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-161 

stream would be declared an AVF in this area where the stream is smaller and 

AVF characteristics (i.e., extent of alluvial deposits, water availability, and 

water quality) are negligible. The declared AVF at the North Prong Little 

Thunder Creek and Little Thunder Creek confluence is located several miles 

downstream from the West Hilight Field LBA Tract and would not be affected 

by mining and reclamation within the tract. 

Other drainages on the West Hilight Field tract are tributaries of Little Thunder 

Creek and AVF characteristics are negligible. Few stream laid deposits are 

present, the streams do not consistently produce enough runoff to be put to 

beneficial use, and the soils that dominate the drainage bottoms within the 

general analysis area are classified by the NRCS as unsuitable for irrigation. In 

addition, there are no present or historical records of agricultural use, other 

than undeveloped range land, of the stream channels and associated stream 

laid deposits within the general analysis area for the tract. If the West Hilight 

Field LBA Tract is leased and proposed for mining, an AVF assessment would 

be part of the mine permitting process, although it is unlikely that the 

WDEQ/LQD would declare that an AVF is present. 

3.6.1.4 West Jacobs Ranch LBA Tract

As discussed in Section 3.5.1.1.1, in the general analysis area for the West 

Jacobs Ranch LBA Tract, alluvial deposits have been mapped only along Dry 

Fork Little Thunder Creek and one of its unnamed tributaries; no stream laid 

deposits have been mapped within any other drainage in the area. If the West 

Jacobs Ranch LBA Tract is leased and proposed for mining, an AVF 

assessment would be part of the mine permitting process, and formal 

declarations of the presence or absence of an AVF, its significance to 

agriculture, and the appropriate perimeter (areal extent) would be made by the 

WDEQ/LQD as part of the permitting process. Based on previous non-AVF 

declarations made on North Prong Little Thunder Creek and Dry Fork Little 

Thunder Creek downstream within the existing Black Thunder Mine permit 

area, which includes a portion of the West Jacobs Ranch LBA Tract, it is 

unlikely that WDEQ/LQD would declare that any AVF characteristics exist in 

the general analysis area for the West Jacobs Ranch tract. The declared AVF 

at the North Prong Little Thunder Creek and Little Thunder Creek confluence is 

located several miles downstream from the West Jacobs Ranch LBA Tract and 

would not be affected by mining and reclamation within the tract. 

3.6.1.5 North Porcupine LBA Tract

As discussed in Section 3.5.1.1.1, alluvial deposits are primarily associated 

with Porcupine Creek within the BLM study area for the North Porcupine LBA 

Tract. The BLM study area for the North Porcupine tract is completely within 

North Antelope Rochelle Mine’s existing mine permit area; therefore, the entire 

lengths of Porcupine Creek and its tributaries (e.g., Payne Draw, Corder Creek, 

Boss Draw, Rat Draw, Chipmunk Draw, and Gray Creek) that cross the North 

Porcupine LBA Tract have been formally investigated for the presence of AVFs, 
3.0 Affected Environment and Environmental Consequences 

3-162 Final EIS, Wright Area Coal Lease Applications 

and the reports of these studies are contained in North Antelope Rochelle 

Mine’s WDEQ/LQD mine permit (PRC 2009). These investigations concluded, 

and WDEQ has concurred, that no AVFs exist along Porcupine Creek or its 

tributaries within the general analysis area for the North Porcupine LBA Tract. 

The declared AVF areas on Porcupine Creek are located several miles 

downstream from the LBA tract and would not be affected by mining and 

reclamation within the tract. 

3.6.1.6 South Porcupine LBA Tract

As discussed in Section 3.5.1.1.1, no unconsolidated stream laid deposits have 

been mapped within the BLM study area for the South Porcupine LBA Tract. 

The South Porcupine tract is completely within North Antelope Rochelle Mine’s 

existing mine permit area, although the streams draining the tract’s general 

analysis area have not all been formally evaluated for the presence of AVFs. If 

the South Porcupine LBA Tract is leased and proposed for mining, it is unlikely 

that WDEQ would require that an AVF assessment be part of the mine 

permitting process in consideration of the absence of any alluvial deposits on 

the tract. 

3.6.2 Environmental Consequences

3.6.2.1 Proposed Action and Alternatives 2 and 3

AVF investigations conducted within and near the general Wright analysis area 

have identified AVFs that occur along Little Thunder Creek, North Prong Little 

Thunder Creek, and Porcupine Creek; however, those lands are located at 

considerable distances downstream of the six LBA tracts included in this 

analysis. 

As indicated above, the entire general analysis area for the North Hilight Field 

LBA Tract has not yet been formally evaluated for the presence of AVFs. AVF 

investigations conducted within and adjacent to the existing Black Thunder 

and Jacobs Ranch Mine permit areas have determined that the AVF 

characteristics of Mills Draw and Springen Draw are negligible and do not meet 

the regulatory definition of an AVF. The paucity of alluvial deposits, 

insufficient surface water runoff to support natural or artificial flood irrigation, 

insufficient or poor quality alluvial groundwater, and unsuitable soils for 

irrigation all indicate it is unlikely that mining the North Hilight Field tract as 

applied for or BLM’s preferred tract configuration under Alternative 2 by the 

applicant as an extension of the existing Black Thunder Mine would directly or 

indirectly affect any AVFs in those areas. 

As indicated above, TBCC has investigated for the presence of AVFs on Little 

Thunder Creek within and a half mile outside of Black Thunder Mine’s existing 

permit area, which included the entire length of the stream within the South 

Hilight Field LBA Tract. Based on the non-AVF declarations that have been 

made on Little Thunder Creek within and adjacent to the LBA tract, and 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-163 

because there are essentially no other alluvial deposits in the tract’s general 

analysis area outside of Little Thunder Creek’s valley, it is unlikely that mining 

the South Hilight Field tract as applied for or BLM’s preferred tract 

configuration under Alternative 2 by the applicant as an extension of the 

existing Black Thunder Mine would have any direct or indirect impacts on 

AVFs in those areas. 

Based on previous non-AVF declarations made on Little Thunder Creek 

downstream of and adjacent to the West Hilight Field LBA Tract, it is unlikely 

that this stream would receive an AVF declaration upstream on this LBA tract 

where the drainage is smaller and AVF characteristics are negligible. As 

indicated above, few stream laid deposits are present in the tract’s general 

analysis area outside the valley of Little Thunder Creek, the streams do not 

consistently produce enough runoff to be put to beneficial use, and the soils 

that dominate the drainage bottoms within the general analysis area are 

classified by the NRCS as unsuitable for irrigation. In addition, there are no 

present or historical records of agricultural use, other than undeveloped range 

land, of the stream channels and associated stream laid deposits within the 

general analysis area for the tract. It is therefore unlikely that mining the West 

Hilight Field tract as applied for or BLM’s preferred tract configuration under 

Alternative 2 by the applicant as an extension of the existing Black Thunder 

Mine would have any direct or indirect impacts on AVFs in those areas. 

If the West Jacobs Ranch LBA Tract is mined by the applicant as an extension 

of the existing Jacobs Ranch Mine operations under the Proposed Action or 

Alternative 2, BLM’s preferred tract configuration, the mining operations would 

remove stream laid deposits from an area totaling about 35 acres along Dry 

Fork Little Thunder Creek and one of its unnamed tributaries. Although the 

published geologic mapping of the remainder of the general analysis area for 

the West Jacobs Ranch LBA Tract indicates that there are no other areas where 

stream laid deposits occur, detailed AVF investigations, including mapping of 

alluvial deposits, would be completed as part of the permitting process. Based 

on previous non-AVF declarations made on North Prong Little Thunder Creek 

and Dry Fork Little Thunder Creek downstream within the existing Black 

Thunder Mine permit area, which includes a portion of the West Jacobs Ranch 

LBA Tract, it is unlikely that mining the West Jacobs Ranch tract as applied for 

or BLM’s preferred tract configuration under Alternative 2 by the applicant as 

an extension of the existing Jacobs Ranch Mine would have any direct or 

indirect impacts on AVFs in those areas. 

Porcupine Creek and its tributaries within the existing North Antelope Mine 

permit area has been evaluated and declared non-AVF by WDEQ/LQD. The 

BLM study area for the North Porcupine LBA Tract is entirely within the mine’s 

existing permit area; therefore, no AVFs would be directly or indirectly 

impacted by mining the North Porcupine tract as applied for or BLM’s preferred 

tract configuration under Alternative 2 by the applicant as an extension of the 

existing North Antelope Rochelle Mine. 
3.0 Affected Environment and Environmental Consequences 

3-164 Final EIS, Wright Area Coal Lease Applications 

No unconsolidated stream laid deposits are found within the South Porcupine 

LBA Tract. The entire general analysis area for the South Porcupine tract has 

not been formally evaluated for the presence of AVFs; however, it is unlikely an 

AVF declaration would be made. It is unlikely that mining the South Porcupine 

LBA Tract as applied for or BLM’s preferred tract configuration under 

Alternative 2 by the applicant as an extension of the existing North Antelope 

Rochelle Mine would have any direct or indirect impacts on AVFs in those 

areas. 

It is reasonable to assume that if the WDEQ/LQD would determine that no 

AVFs are present within any of the LBA tracts that are leased. Should 

declarations be made within any LBA tracts that are leased, it is reasonable to 

assume that mining would be permitted because all of the proposed lease areas 

consist entirely of undeveloped rangeland. If the LBA tracts that are leased are 

mined as an extension of existing operations, the mining would generally 

extend upstream on streams already in active mine areas. 

No direct, indirect, or cumulative impacts are anticipated to off-site AVFs 

through mining of the six LBA tracts included in this analysis. Streamflows in 

Little Thunder Creek, North Prong Little Thunder Creek, and Porcupine Creek 

and their tributaries would be diverted around the active mining areas in a 

temporary diversion ditches, captured in various flood control structures above 

the pits, or allowed to accrue to the mine pits. Therefore, during normal runoff 

events, a slight reduction in downstream flow rates would be expected. 

Following major runoff events, it would be necessary to evacuate the pit sumps 

and flood control structures to provide storage volume for the next runoff 

event. Runoff waters would then be discharged outside the mine permit area 

after sufficient time for settling of suspended solids has passed. Consequently, 

disruptions to streamflow that might supply downstream AVFs during mining 

are expected to be negligible. Groundwater and surface runoff intercepted by 

the mine pits would be routed through settling ponds to meet state and federal 

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. 

3.6.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and coal removal and associated 

disturbance and impacts to AVFs would not occur on the portions of the LBA 

tracts as applied for or the LBA tracts configured under Alternative 2 that will 

not be disturbed under the currently approved surface coal mining permits. 

Coal removal and associated impacts to AVFs would continue as currently 

permitted on the existing Black Thunder, Jacobs Ranch, and North Antelope 

Rochelle Mine permit areas. Impacts to AVFs related to mining operations at 

these three applicant mines would not be extended onto portions of the LBA 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-165 

tracts that will not be affected under the current mining and reclamation 

plans. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective tract in the future. 

3.6.3 Regulatory Compliance, Mitigation and Monitoring

As discussed above, AVFs must be identified because SMCRA restricts mining 

activities that would affect AVFs that are determined to be significant to 

agriculture. Impacts to lands that are declared an AVF 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. In the 

state of Wyoming, 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 stream valley will be protected. Mines are 

required to restore the essential hydrologic functions of any affected AVF and 

preserve the hydrologic functions of AVFs on adjacent lands. 

Downstream AVFs must also be protected during mining. The effects of mining 

on downstream AVFs are required by regulation by monitoring discharges of 

surface water from the current mine permit areas for quantity and quality 

during mining. These requirements would be extended to include the North 

Hilight Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, North 

Porcupine, and South Porcupine LBA Tracts during the permitting process, if 

the tracts are leased. These requirements would be extended accordingly and 

included in the mine permit amendment that would be required for each 

respective LBA tract that is leased. Mine permit revisions must be approved 

before mining could occur on each tract that is leased, regardless of who 

acquires the tract. 

3.6.4 Residual Impacts

No residual impacts to AVFs would occur following mining. 

3.7 Wetlands

3.7.1 Affected Environment

Wetlands are aquatic features defined as “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 
3.0 Affected Environment and Environmental Consequences 

3-166 Final EIS, Wright Area Coal Lease Applications 

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]). The prolonged presence of water creates conditions that favor 

the growth of specially adapted plants and promote the development of 

characteristic wetland (hydric) soils (EPA 2007c). Vegetation in wetland 

environments is highly productive and diverse and provides habitat for many 

wildlife species. These systems as a whole play important roles in controlling 

floodwaters, recharging groundwater, and filtering pollutants (Niering 1985). 

Wetlands must contain three components: hydric soils, a dominance of 

hydrophytic plants, and wetland hydrology. When the upper part of the soil is 

saturated with water at growing season temperatures, soil organisms consume 

the oxygen in the soil and cause conditions unsuitable for most plants. Such 

conditions also cause the development of soil characteristics (such as color and 

texture) of so-called “hydric soils.” The plants that can grow in such 

conditions, such as marsh grasses, are called “hydrophytes.” Together, hydric 

soils and hydrophytes give clues that a wetlands area is present. The presence 

of water by ponding, flooding, or soil saturation is not always a good indicator 

of wetlands. Except for wetlands flooded by ocean tides, the amount of water 

present in wetlands fluctuates as a result of rainfall patterns, snow melt, dry 

seasons and longer droughts (EPA 2007c, Niering 1985, COE 1987). 

Waters of the U.S. (WoUS) is a collective term for those water bodies subject to 

regulation pursuant to the Clean Water Act (CWA). The U.S. Army Corps of 

Engineers (COE) administers a regulatory program under Section 404 of the 

CWA, which requires a permit for the discharge of dredged or fill materials into 

WoUS, including jurisdictional wetlands. This regulatory program requires 

that an inventory of WoUS, including wetlands, be performed, permits be 

acquired prior to dredging or filling jurisdictional wetlands, and that impacts to 

jurisdictional wetlands and Other Waters of the U.S. (OWUS) be adequately 

mitigated. WDEQ/LQD regulations require that wetlands and other high value 

wildlife habitat that is to be disturbed by proposed mining activities be 

reclaimed following mining operations. 

WoUS include all areas subject to regulation by the COE pursuant to the CWA, 

to include special aquatic sites, of which wetlands is a subset. The definition of 

WoUS has been broadly interpreted to include most major water bodies, 

streams, intermittent drainages, mud flats, wetlands, sloughs, prairie potholes, 

wet meadows, playa lakes, and natural ponds. Special aquatic sites are 

defined as “geographic areas, large or small, possessing special ecological 

characteristics and productivity, habitat, wildlife protection, or other important 

and easily disrupted ecological values” (40 CFR 230.3[q-1]). Special aquatic 

sites include “sanctuaries and refuges, wetlands, mud flats, vegetated shallows, 

coral reefs, and riffle and pool complexes” (40 CFR 230, Subpart E). 

Wetlands subject to CWA jurisdiction are known as “jurisdictional wetlands,” 

while those wetlands not subject to CWA jurisdiction are known as “nonjurisdictional” wetlands. Compliance with Section 404 and its implementing 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-167 

regulations requires a sequence of avoidance, minimization of impact, and 

mitigation of wetlands. Precise definitions of WoUS or navigability are 

ultimately dependent on judicial interpretation and cannot be made 

conclusively by administrative agencies (33 CFR 329). Rules, regulations, 

policies, and procedures used in determining the extent of jurisdiction have 

changed and evolved with time. Many ephemeral channels and playas in the 

PRB have, in the past, been classified as WoUS. However, several changes 

have occurred to the COE regulatory program over the past several years that 

will have a bearing on the current status of numerous areas historically 

classified as jurisdictional. For example, in 2001 the U.S. Supreme Court 

ruled that isolated waters and playas are not WoUS. A U.S. Supreme Court 

decision (Rapanos v. United States and Carabell v. United States, collectively 

referred to as the “Rapanos” decision) in 2006 attempted to address federal 

jurisdiction over waters of the U.S. under the CWA (EPA 2007d). According to 

the Court’s decision, the EPA and COE must ensure that jurisdictional 

determinations, permitting actions, and other relevant actions are consistent 

with the Rapanos decision. The decision addressed where the federal 

government can apply the CWA, specifically by determining whether a wetland 

or tributary is a “Water of the U.S.”, being “relatively permanent, standing or 

continuously flowing bodies of water” connected to traditional navigable waters, 

and to “wetlands with a continuous surface connection (nexus) to” such 

relatively permanent waters. As a result of that decision, the COE has placed a 

moratorium on the issuance of approved jurisdictional determinations that will 

be in place until the COE headquarters, the EPA, and the Department of 

Justice determines how to proceed and issues appropriate legal guidance. 

Federal regulations limit jurisdiction to the Ordinary High Water Mark (OHWM) 

(33 CFR 328.4). Previous delineations used the very general criteria that stated 

“drainages must have an active channel that exhibits relatively stable 

fluviogeomorphic character (i.e., the channel has a well-defined bed and grade) 

to be classified as WoUS.” Regulatory Guidance Letter 05-05 now provides a 

specific list of the physical characteristics that are to be evaluated to identify 

the presence or location of an OHWM. Evaluation of these specific physical 

characteristics may now lead to a determination that many of the ephemeral 

drainages in the PRB are not jurisdictional. 

Briefly, the agencies will assert jurisdiction over the following waters: 

• Traditional navigable waters; 

• Wetlands adjacent to traditional navigable waters; 

• Non-navigable tributaries of traditional navigable waters that are 

relatively permanent where the tributaries typically flow year-round or 

have continuous flow at least seasonally (e.g., typically three months); 

and 

• Wetlands that directly abut such tributaries. 
3.0 Affected Environment and Environmental Consequences 

3-168 Final EIS, Wright Area Coal Lease Applications 

The agencies will decide jurisdiction over the following waters based on a factspecific analysis to determine whether they have a significant nexus with a 

traditional navigable water: 

• Non-navigable tributaries that are not relatively permanent; 

• Wetlands adjacent to non-navigable tributaries that are not relatively 

permanent; and 

• Wetlands adjacent to, but do not directly abut, a relatively permanent 

non-navigable tributary. 

The agencies will generally not assert jurisdiction over the following features: 

• Swales or erosional features (e.g., gullies, small washes characterized by 

low volume, infrequent, or short duration flow); and 

• Ditches (including roadside ditches) excavated wholly in and draining 

only uplands and that do not carry a relatively permanent flow of water. 

In describing wetlands, three very different types, from a permitting 

perspective, may be identified, those being jurisdictional, non-jurisdictional, 

and functional. Functional wetlands are areas that may contain only one or 

two of the three wetland criteria (presence of hydric soils, a dominance of 

hydrophytic plants, and wetland hydrology). The United States Fish and 

Wildlife Service (USFWS) uses this third categorization in producing National 

Wetland Inventory (NWI) maps, which are based on aerial photo interpretation 

with limited or no field verification. 

Wetlands can occur in a variety of forms and are somewhat limited in size 

within the general Wright analysis area; however, the vegetation in these 

environments is relatively productive and diverse, and provides habitat for a 

number of wildlife species. Riverine wetlands, typically defined by their close 

association with stream channels, occur sporadically along drainages. In this 

area, these wetlands are generally supported by periodic flooding events. 

Common vegetation species in these riverine settings can include willows (Salix

spp.), scouring rush (Equisetum spp.), sedges (Carex spp.), and rushes (Juncus

spp.). Palustrine wetlands, defined by their close association with emergent 

herbaceous marshes, swales, and wet meadows, support a variety of lush plant 

life and occur sporadically along major drainages and where topographic 

depression areas (playas) are naturally subirrigated and/or sporadically 

flooded. These wetlands are the most common and abundant in the general 

Wright analysis area. Common vegetation species in these palustrine settings 

can include sedges, rushes, cordgrass (Spartina spp.), mint (Mentha spp.), and 

buttercup (Ranunculus spp.). Naturally occurring depressions (playas) that 

flooded more frequently and/or hold deeper water may support lacustrine 

wetlands. Manmade structures such as stock ponds may also support 

lacustrine wetlands. The most common species in these lacustrine settings 

include cattails (Typha spp.) and bulrush (Scirpus spp.), although lady’s thumb 

(Polygonum spp.), verbena (Verbena spp.), and milkweed (Asclepias spp.) may 

also occur (USFS 1987). 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-169 

In addition to wetlands, the general Wright analysis area may include Other 

Waters of the U.S. (OWUS), as defined by 33 CFR 328.3. These OWUS are 

primarily ephemeral stream channels, open water, and other stream channels 

that carry water but do not meet the criteria for classification as wetlands. 

3.7.1.1 North Hilight Field LBA Tract

A preliminary wetland inventory of the general analysis area for the North 

Hilight Field LBA Tract, based on USFWS NWI mapping (1980), review of color 

infrared aerial photographs (WGCS 2002), and a field survey reconnaissance, 

was conducted in 2007. Some wetland areas previously mapped by the 

USFWS NWI have been recently altered due to CBNG-related water production 

within and upstream of the general analysis area. The NWI maps were 

consulted prior to the initiation of the preliminary wetland field survey; 

however, the boundaries of the existing potential wetlands vary to a greater or 

lesser extent from the boundaries shown on the NWI maps. Due to the 

ephemeral nature of CBNG dewatering activities, the boundaries, and therefore 

wetland areas, are likewise ephemeral. A formal jurisdictional wetland 

delineation survey for the North Hilight Field LBA Tract would be conducted 

and submitted to the COE for verification as part of the mine permitting 

process, if the LBA tract is leased. 

Within the entire general analysis area for the North Hilight Field LBA Tract 

(8,476.4 acres), the preliminary wetland inventory identified a total of 177.5 

acres of wetlands and OWUS. These wetlands and OWUS were found within 

five general land categories: ephemeral streams, playas, ponds/reservoirs, 

isolated depressions, and excavated upland areas. These 177.5 acres are 

vegetated wetlands that consist of approximately 172.0 acres of palustrine 

emergent herbaceous wet meadow or marsh and approximately 5.5 acres of 

palustrine aquatic beds located along ephemeral stream channels and around 

ponds, playas and depressions. No areas of open water (pond or channel 

OWUS) were observed during this preliminary wetland inventory. 

At this time, a distinction has not been made between jurisdictional and nonjurisdictional acreages of wetlands and OWUS since only the COE has the 

authorization to make such determination following the submittal and review of 

a formal wetland delineation as part of the permitting process. 

3.7.1.2 South Hilight Field LBA Tract

A preliminary wetland inventory of the general analysis area for the South 

Hilight Field LBA Tract, based on USFWS NWI mapping (1980), review of color 

infrared aerial photographs (WGCS 2002), and a field survey reconnaissance, 

was conducted in 2007. Some wetland areas previously mapped by the 

USFWS NWI have been recently altered due to CBNG-related water production 

within and upstream of the general analysis area. The NWI maps were 

consulted prior to the initiation of the preliminary wetland field survey; 

however, the boundaries of the existing potential wetlands vary to a greater or 
3.0 Affected Environment and Environmental Consequences 

3-170 Final EIS, Wright Area Coal Lease Applications 

lesser extent from the boundaries shown on the NWI maps. Due to the 

ephemeral nature of CBNG dewatering activities, the boundaries, and therefore 

wetland areas, are likewise ephemeral. A formal jurisdictional wetland 

delineation survey for the South Hilight Field LBA Tract would be conducted 

and submitted to the COE for verification as part of the mine permitting 

process, if the LBA tract is leased. 

Within the entire general analysis area for the South Hilight Field LBA Tract 

(3,367.9 acres), the preliminary wetland inventory identified a total of 55.1 

acres of wetlands and OWUS. These wetlands and OWUS were found within 

five general land categories: ephemeral streams, playas, ponds/reservoirs, 

isolated depressions, and excavated upland areas. Of these 55.1 acres, 

approximately 52.3 acres are vegetated wetlands that consist of approximately 

51.2 acres of palustrine emergent herbaceous wet meadow or marsh and 

approximately 1.1 acres of palustrine aquatic beds located along ephemeral 

stream channels and around ponds, playas and depressions. The remaining 

2.8 acres are channel OWUS (open water in Little Thunder Creek). Little 

Thunder Creek was initially classified as a palustrine wetland by NWI, but 

currently meets the classification of a riverine, streambed system and is heavily 

influenced by CBNG discharge water. 

At this time, a distinction has not been made between jurisdictional and nonjurisdictional acreages of wetlands and OWUS since only the COE has the 

authorization to make such determination following the submittal and review of 

a formal wetland delineation as part of the permitting process. 

3.7.1.3 West Hilight Field LBA Tract

A preliminary wetland inventory of the general analysis area for the West 

Hilight Field LBA Tract, based on USFWS NWI mapping (1980), review of color 

infrared aerial photographs (WGCS 2002), and a field survey reconnaissance, 

was conducted in 2007. Some wetland areas previously mapped by the 

USFWS NWI have been recently altered due to CBNG-related water production 

within and upstream of the general analysis area. The NWI maps were 

consulted prior to the initiation of the preliminary wetland field survey; 

however, the boundaries of the existing potential wetlands vary to a greater or 

lesser extent from the boundaries shown on the NWI maps. Due to the 

ephemeral nature of CBNG dewatering activities, the boundaries, and therefore 

wetland areas, are likewise ephemeral. A formal jurisdictional wetland 

delineation survey for the West Hilight Field LBA Tract would be conducted and 

submitted to the COE for verification as part of the mine permitting process, if 

the LBA tract is leased. 

Within the entire general analysis area for the West Hilight Field LBA Tract 

(9,188.6 acres), the preliminary wetland inventory identified a total of 262.7 

acres of wetlands and OWUS. These wetlands and OWUS were found within 

five general land categories: ephemeral streams, playas, ponds/reservoirs, 

isolated depressions, and excavated upland areas. Of these 262.7 acres, 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-171 

approximately 252.8 acres are vegetated wetlands that consist of approximately 

240.6 acres of palustrine emergent herbaceous wet meadow or marsh and 

approximately 12.2 acres of palustrine aquatic beds located along ephemeral 

stream channels and around ponds, playas and depressions. The remaining 

9.9 acres are channel and pond OWUS (open water in Little Thunder Creek and 

Little Thunder Reservoir). Little Thunder Creek was initially classified as a 

palustrine wetland by NWI, but currently meets the classification of a riverine, 

streambed system and is heavily influenced by CBNG discharge water. 

At this time, a distinction has not been made between jurisdictional and nonjurisdictional acreages of wetlands and OWUS since only the COE has the 

authorization to make such determination following the submittal and review of 

a formal wetland delineation as part of the permitting process. 

3.7.1.4 West Jacobs Ranch LBA Tract

A preliminary wetland inventory of the general analysis area for the West 

Jacobs Ranch LBA Tract, based on USFWS NWI mapping (1980) and a field 

survey reconnaissance, was conducted in 2007 and 2008. Information was 

also obtained from previous formal wetland inventories completed on the 

eastern portion of the general analysis area by TBCC (TBCC 2005). Some 

wetland areas previously mapped by the USFWS NWI and other inventories 

have been recently altered due to CBNG-related water production within and 

upstream of the general analysis area. The NWI maps were consulted prior to 

the initiation of the preliminary wetland field survey; however, the boundaries 

of the existing potential wetlands vary to a greater or lesser extent from the 

boundaries shown on the NWI maps. Due to the ephemeral nature of CBNG 

dewatering activities, the boundaries, and therefore wetland areas, are likewise 

ephemeral. A formal jurisdictional wetland delineation survey for the West 

Jacobs Ranch LBA Tract would be conducted and submitted to the COE for 

verification as part of the mine permitting process, if the LBA tract is leased. 

Within the entire general analysis area for the West Jacobs Ranch LBA Tract 

(9,370.4 acres), the preliminary wetland inventory identified a total of 68.4 

acres of wetlands and OWUS. These wetlands and OWUS were found within 

four general land categories: ponds, ephemeral streams, playas, and 

depressions. Of this 68.4 acres, approximately 16.7 acres are vegetated 

wetlands, which include 4.7 acres around ponds, 7.8 acres along ephemeral 

streams, 1.7 acres on playas, and 2.5 acres in other depressions. The 

remaining 50.7 acres are pond or channel other waters (i.e., open water in 

reservoirs/stockponds, along ephemeral streams, and in playas). The 

vegetated wetlands are located primarily along the stream channels associated 

with Dry Fork and North Prong Little Thunder Creek. All of these wetlands and 

OWUS are classified as palustrine. 

At this time, a distinction has not been made between jurisdictional and nonjurisdictional acreages of wetlands and OWUS since only the COE has the 
3.0 Affected Environment and Environmental Consequences 

3-172 Final EIS, Wright Area Coal Lease Applications 

authorization to make such determination following the submittal and review of 

a formal wetland delineation as part of the permitting process. 

3.7.1.5 North Porcupine LBA Tract

Formal jurisdictional wetland delineation surveys covering North Antelope 

Rochelle Mine’s current permit area and some additional adjacent lands were 

completed by PRC and submitted to the COE for verification in 1996, 1997, 

2000 and 2004. These wetland delineations and the COE’s respective letters of 

verification summarizing the acreage figures of approved jurisdictional 

determinations are included in Appendix D-10 of the mine’s permit (PRC 2009). 

According to the COE’s latest (October 12, 2004) jurisdictional determination, 

there is a total of 219.71 acres of jurisdictional wetlands and OWUS within the 

mine’s current permit area. Of those 219.71 acres, there are 77.84 acres of 

riverine wetlands, 26.99 acres of stockpond wetlands, 11.42 acres of riverine 

open water OWUS, 44.62 acres of stockpond open water OWUS, and 58.84 

acres of ephemeral stream channel OWUS. There are also 20.92 wetland acres 

and 1.33 open water acres of non-jurisdictional playa/depressional features. 

The general analysis area for the North Porcupine LBA Tract lies completely 

within North Antelope Rochelle Mine’s current mine permit area. Therefore, 

these previous wetland delineation surveys provide an estimate of the acreages 

of wetlands and OWUS that exist within the LBA tract’s general analysis area, 

with the caveat that some wetland areas previously mapped may have been 

altered by CBNG-related water production within and upstream of the general 

analysis area. In addition to the effects from CBNG-related water discharges, 

the PRB has experienced a moderate to severe drought cycle that has persisted 

since 2000, which may have also altered previously-mapped wetland and 

OWUS areas. The boundaries of some wetlands and OWUS could, therefore, 

vary to a greater or lesser extent from the boundaries that existed at the time 

that the formal wetland delineation surveys were conducted. 

Within the general analysis area for the North Porcupine LBA Tract (9,021.4 

acres), there are an estimated 19.7 acres of jurisdictional wetlands and OWUS. 

Of those 19.7 acres, there are approximately 9.3 acres of riverine wetlands, 

approximately 0.9 acres of stockpond wetlands, approximately 0.9 acres of 

stockpond open water OWUS, and approximately 8.6 acres of ephemeral 

stream channel OWUS. There are also approximately 4.9 wetland acres and 

1.2 open water acres of non-jurisdictional playa/depressional features. The 

vegetated wetland areas consist primarily of palustrine emergent herbaceous 

wet meadow or marsh and palustrine aquatic beds located along ephemeral 

stream channels and around ponds, playas and depressions, whereas the 

OWUS consist of dry ephemeral drainages and open water. 

3.7.1.6 South Porcupine LBA Tract

The general analysis area for the South Porcupine LBA Tract lies completely 

within North Antelope Rochelle Mine’s current mine permit area. Therefore, 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-173 

the mine’s wetland delineation surveys described above provide an estimate of 

the acreages of wetlands and OWUS that exist within the LBA tract’s general 

analysis area, with the caveat that some wetland areas previously mapped may 

have been altered by CBNG-related water production within and upstream of 

the general analysis area. In addition to the effects from CBNG-related water 

discharges, the PRB has experienced a moderate to severe drought cycle that 

has persisted since 2000, which may have also altered previously-mapped 

wetland and OWUS areas. The boundaries of some wetlands and OWUS could, 

therefore, vary to a greater or lesser extent from the boundaries that existed at 

the time that the formal wetland delineation surveys were conducted. 

Within the general analysis area for the South Porcupine LBA Tract (4,020.5 

acres), there are an estimated 12.5 acres of jurisdictional wetlands and OWUS. 

Of those 12.5 acres, there are approximately 6.8 acres of riverine wetlands, 

approximately 0.4 acres of stockpond wetlands, approximately 0.2 acres of 

stockpond open water OWUS, and approximately 4.9 acres of ephemeral 

stream channel OWUS. There are also approximately 0.2 wetland acres of nonjurisdictional playa/depressional features. The vegetated wetland areas consist 

primarily of palustrine emergent herbaceous wet meadow or marsh along 

ephemeral stream channels and around ponds, playas and depressions, 

whereas the OWUS consist of dry ephemeral drainages and open water. 

3.7.2 Environmental Consequences

3.7.2.1 Proposed Action and Alternatives 2 and 3

Formal wetland delineations have been confirmed by the COE for wetlands and 

OWUS included in the proposed LBA tracts that lie within the three applicant 

mines’ existing permit areas. Based on those previous wetland delineation 

surveys and the preliminary wetland inventories conducted in 2007 and 2008 

of the general analysis areas for the six LBA tracts included in this EIS, a 

maximum of approximately 602 acres of wetlands and OWUS would be 

disturbed if each of the six LBA tracts is leased and subsequently mined under 

Alternative 2, BLM’s preferred alternative for each of the six tracts. Formal 

wetland inventories covering the remainder of the general analysis areas for the 

LBA tracts that are leased would be conducted and 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 number of jurisdictional wetland 

acreages. 

Disturbed non-jurisdictional wetlands would be restored as required by the 

authorized federal or state agency or private surface land owner as specified in 

the mine permit, which would have to be approved by WDEQ/LQD before 

mining operations could be conducted on the LBA tracts that are leased. 
3.0 Affected Environment and Environmental Consequences 

3-174 Final EIS, Wright Area Coal Lease Applications 

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 CWA as determined 

by the COE. 

3.7.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and coal removal and associated 

disturbance and impacts to wetlands and OWUS would not occur on the 

portions of the LBA tracts as applied for or the LBA tracts configured under 

Alternative 2 that will not be disturbed under the currently approved surface 

coal mining permits. Coal removal and associated impacts to wetlands and 

OWUS would continue as currently permitted on the existing Black Thunder, 

Jacobs Ranch, and North Antelope Rochelle Mine permit areas. Impacts to 

AVFs and OWUS related to mining operations at these three applicant mines 

would not be extended onto portions of the LBA tracts that will not be affected 

under the current mining and reclamation plans. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective tract in the future. 

3.7.3 Regulatory Compliance, Mitigation and Monitoring

A formal wetland delineation survey must be conducted prior to mining 

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. Once the delineation has been verified, it is made part of the 

mine and reclamation permit. 

The presence of jurisdictional wetlands and OWUS on a mine property does not 

preclude mining. 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 CWA, and all wetland replacement plans have to be approved by the 

COE. As such, a formal jurisdictional wetland delineation survey would be 

conducted and submitted to the COE for verification as part of the mining and 

reclamation permit process for each of these six LBA tracts that are leased and 

proposed for mining. 

Section 404 of the CWA does not cover non-jurisdictional or functional 

wetlands; however, Executive Order (EO) No. 11990 – Protection of Wetlands 

(May 24, 1977) – requires that all federal agencies protect all wetlands. 

Mitigation for impacts to non-jurisdictional wetlands located on these six LBA 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-175 

tracts will be specified during the permitting process as required by the 

authorized state or federal agency (which may include the WDEQ, OSM, 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 general analysis 

areas for the Wright area LBA tracts is private and federal (see Section 3.11). 

The federal surface is administered by the USFS. 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. 

Finally, the surface mining regulatory authorities (WDEQ/LQD and OSM) 

typically require replacement of non-jurisdictional and functional wetlands as a 

measure to protect and enhance wildlife. 

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

Numerous baseline soil surveys associated with surface mining operations and 

oil and gas field development have been conducted in the eastern PRB. Soil 

surveys of Campbell County, Wyoming, including the general analysis areas for 

the North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs 

Ranch, North Porcupine, and South Porcupine LBA Tracts, have also recently 

been conducted by the National Resource Conservation Service (NRCS) (Prink 

et al. 2004). 

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 

general Wright analysis 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 coarsetextured alluvium or sandy eolian deposits on rolling uplands, and 4) drainage 
3.0 Affected Environment and Environmental Consequences 

3-176 Final EIS, Wright Area Coal Lease Applications 

soils developing in mixed stream laid alluvium on terraces and channels, and 

in fine-textured playa deposits in depressions and closed basins. 

The soil depths and types on the general analysis areas for these six LBA tracts 

are similar to soils currently being salvaged and utilized for reclamation at the 

adjacent Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines 

and other mines in the eastern PRB. Additional detailed information about the 

soil types on these six LBA tracts is included in the supplemental information 

document, which is available on request. The site-specific soil surveys have 

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 alkalinity, salinity, or clay content. 

As described in Section 3.0, the general analysis area for each tract is defined 

as the BLM study area (the LBA tract as applied for and the additional area 

evaluated under Alternative 2) plus the 1⁄4-mile disturbance buffer. Baseline 

soil surveys cover the general analysis areas for these six LBA tracts. 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 WDEQ Order 1-2 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 tracts’ general analysis areas were 

identified by series, which consist of soils that have similar horizons in their 

profile. Horizons are soil layers having similar color, texture, structure, 

reaction, consistency, mineral and chemical composition, and arrangement in 

the profile. 

3.8.1.1 North Hilight Field, South Hilight Field, and West Hilight Field LBA 

Tracts

The general analysis area for the North Hilight Field tract (8,476.4 total acres) 

has been covered by baseline soil surveys completed to an Order 1-2 resolution 

for the adjacent Jacobs Ranch Mine and the Little Thunder Amendment Area of 

the Black Thunder Mine, both of which are included in the approved 

WDEQ/LQD mine permits. In addition, the entire general analysis area has 

been covered by the NRCS Order 3 survey of southern Campbell County (Prink 

et al. 2004). 

A portion of the general analysis area for the South Hilight Field tract (3,367.9 

total acres) has been covered by baseline soil surveys completed to an Order 1-

2 resolution for the Little Thunder and West Black Thunder Amendment Areas 

of the Black Thunder Mine, and for the West Roundup Amendment of the 

North Rochelle Mine. All three of these soils surveys of permit amendment 

areas are included in the approved WDEQ/LQD mine permits. In addition, the 

entire general analysis area has been covered by the NRCS Order 3 survey of 

southern Campbell County (Prink et al. 2004). 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-177 

A portion of the general analysis area for the West Hilight Field tract (9,188.6 

total acres) has been covered by a baseline soil survey completed to an Order 1-

2 resolution for the Little Thunder Amendment Area of the Black Thunder 

Mine, which is included in the approved WDEQ/LQD mine permit. In addition, 

the entire general analysis area has been covered by the NRCS Order 3 survey 

of southern Campbell County (Prink et al. 2004). 

3.8.1.2 West Jacobs Ranch LBA Tract

A portion of the general analysis area for the West Jacobs Ranch tract (9,370.4 

total acres) has been covered by a baseline soil survey completed to an Order 1-

2 resolution for the Little Thunder Amendment Area of the Black Thunder 

Mine, which is included in the approved WDEQ/LQD mine permit. In addition, 

the entire general analysis area has been covered by the NRCS Order 3 survey 

of southern Campbell County (Prink et al. 2004). The baseline soils survey of 

the general analysis area for the West Jacobs Ranch tract was completed in 

2007 by Intermountain Resources of Laramie, Wyoming to an Order 2 

resolution. The inventory included a listing of all soil types within the general 

analysis area along with a brief description of those types. 

3.8.1.3 North and South Porcupine LBA Tracts

The general analysis area for the North Porcupine tract (9,021.4 total acres) 

has been covered by three separate baseline soil surveys completed to an Order 

1-2 resolution; two of which are for the North Antelope Rochelle Mine and are 

included in the approved WDEQ/LQD mine permit. The third Order 1-2 survey 

is included in the School Creek Baseline Soils Assessment (BKS 2005) that was 

submitted as part of the adjacent proposed School Creek Mine permit 

application, currently under review by the WDEQ/LQD. The entire general 

analysis area for the North Porcupine tract has also been covered by the NRCS 

Order 3 survey of southern Campbell County (Prink et al. 2004). 

The general analysis area for the South Porcupine tract (4,020.5 total acres) 

has been subjected to three separate Order 1-2 soil surveys completed for the 

North Antelope Rochelle Mine, which are part of its approved WDEQ/LQD mine 

permit. In addition, the entire general analysis area for the South Porcupine 

tract has been covered by the NRCS Order 3 survey of southern Campbell 

County (Prink et al. 2004). 

3.8.2 Environmental Consequences

3.8.2.1 Proposed Action and Alternatives 2 and 3

Salvage and redistribution 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 
3.0 Affected Environment and Environmental Consequences 

3-178 Final EIS, Wright Area Coal Lease Applications 

plant growth would not be salvaged for use in reclamation. This would result 

in more uniform vegetative productivity on the reclaimed land. 

The baseline soils analyses for these six LBA tracts indicate that the amount of 

suitable topsoil that would be available for redistribution on all disturbed acres 

within the six general analysis areas during reclamation would vary from an 

average depth of 2.0 feet to an average depth of 3.0 feet. The replaced topsoil 

should support a stable and productive vegetation community adequate in 

quality and quantity to support the planned postmining land uses of rangeland 

and wildlife habitat. 

There would most likely be an increase in the near-surface bulk density of the 

reclaimed soil resources on the reclaimed areas due to loss of soil aggregates. 

As a result, the average soil infiltration rates would generally decrease, which 

would increase the potential for runoff and soil erosion. Roughening the 

regraded backfill surface prior to soil redistribution, and soil preparation by 

disking or plowing prior to seeding would mitigate surface compaction. 

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. Ephemeral stream 

channels and floodplains would be designed and reclaimed to be erosionally 

stable, thereby conserving the soil resource. 

Direct biological impacts to soil resources would include short-term to longterm reduction in soil organic matter, microbial populations, seeds, bulbs, 

rhizomes, and live plant parts for soil resources that are stockpiled before 

placement. The sections that follow describe the potential impacts to soil 

resources on each LBA tract following reclamation under the Action 

Alternatives. 

3.8.2.1.1 North Hilight Field LBA Tract

Potential impacts to soil resources on the LBA tract after final reclamation 

under the Proposed Action or Alternative 2 are quantified as follows. Under the 

currently approved mining and reclamation plan, approximately 26,812.0 acres 

of soil resources will be disturbed in order to mine the coal in the existing 

leases at the Black Thunder Mine (Table 3-1). If the North Hilight Field LBA 

Tract is leased, TBCC estimates disturbance related to coal mining would 

directly affect from approximately 5,053.0 to 12,908.8 additional acres of soil 

resources on and adjacent to the LBA tract under the Proposed Action or under 

Alternative 2, BLM’s preferred alternative, respectively (Table 3-1). There are 

approximately 3,304.7 additional acres of soil resources within the North 

Hilight Field LBA Tract as applied for plus a 1⁄4-mile disturbance buffer and 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-179 

approximately 8,476.4 additional acres of soil resources within the BLM study 

area (the LBA tract as applied for and the additional area evaluated under 

Alternative 2) plus the 1⁄4-mile disturbance buffer. Preliminary estimates 

indicate the average redistributed soil thickness would be about 33 inches (2.7 

feet) across the entire reclaimed surface; however, soil redistribution depths 

would vary to mimic the premine conditions. The types of soils and the 

quantities of the soil resource included in the North Hilight Field LBA Tract as 

applied for and in Alternative 2, BLM’s preferred tract configuration, are similar 

to the soils on the existing leases at the adjacent Jacobs Ranch and Black 

Thunder mines. As discussed in Section 3.0, the estimates of recoverable coal, 

associated disturbance, and mine life shown in Table 3-1 assume that Shroyer 

Road is not moved. 

3.8.2.1.2 South Hilight Field LBA Tract

Potential impacts to soil resources on the LBA tract after final reclamation 

under the Proposed Action or Alternative 2 are quantified as follows. Under the 

currently approved mining and reclamation plan, approximately 26,812.0 acres 

of soil resources will be disturbed in order to mine the coal in the existing 

leases at the Black Thunder Mine (Table 3-2). If the South Hilight Field LBA 

Tract is leased, TBCC estimates disturbance related to coal mining would 

directly affect from approximately 1,126.0 to 2,731.4 additional acres of soil 

resources on and adjacent to the LBA tract under the Proposed Action or under 

Alternative 2, BLM’s preferred alternative, respectively (Table 3-2). There are 

approximately 2,332.4 additional acres of soil resources within the South 

Hilight Field LBA Tract as applied for plus a 1⁄4-mile disturbance buffer and 

approximately 3,367.9 additional acres of soil resources within the BLM study 

area (the LBA tract as applied for and the additional area evaluated under 

Alternative 2) plus the 1⁄4-mile disturbance buffer. Preliminary estimates 

indicate the average redistributed soil thickness would be about 35 inches (2.9 

feet) across the entire reclaimed surface; however, soil redistribution depths 

would vary to mimic the premine conditions. The types of soils and the 

quantities of the soil resource included in the South Hilight Field LBA Tract as 

applied for and in Alternative 2, BLM’s preferred tract configuration, are similar 

to the soils on the existing leases at the adjacent Black Thunder Mine. As 

discussed in Section 3.0, the estimates of recoverable coal, associated 

disturbance, and mine life shown in Table 3-2 assume that Reno Road is not 

moved. 

3.8.2.1.3 West Hilight Field LBA Tract

Potential impacts to soil resources on the LBA tract after final reclamation 

under the Proposed Action or Alternative 2 are quantified as follows. Under the 

currently approved mining and reclamation plan, approximately 26,812.0 acres 

of soil resources will be disturbed in order to mine the coal in the existing 

leases at the Black Thunder Mine (Table 3-3). If the West Hilight Field LBA 

Tract is leased, TBCC estimates disturbance related to coal mining would 

directly affect from approximately 6,351.4 to 10,250.8 additional acres of soil 
3.0 Affected Environment and Environmental Consequences 

3-180 Final EIS, Wright Area Coal Lease Applications 

resources on and adjacent to the LBA tract under the Proposed Action or under 

Alternative 2, BLM’s preferred alternative, respectively (Table 3-3). There are 

approximately 3,843.5 additional acres of soil resources within the West Hilight 

Field LBA Tract as applied for plus a 1⁄4-mile disturbance buffer and 

approximately 9,188.6 additional acres of soil resources within the BLM study 

area (the LBA tract as applied for and the additional area evaluated under 

Alternative 2) plus the 1⁄4-mile disturbance buffer. Preliminary estimates 

indicate the average redistributed soil thickness would be about 28 inches (2.3 

feet) across the entire reclaimed surface; however, soil redistribution depths 

would vary to mimic the premine conditions. The types of soils and the 

quantities of the soil resource included in the West Hilight Field LBA Tract as 

applied for and in Alternative 2, BLM’s preferred tract configuration, are similar 

to the soils on the existing leases at the adjacent Black Thunder Mine. As 

discussed in Section 3.0, the estimates of recoverable coal, associated 

disturbance, and mine life shown in Table 3-3 assume that State Highway 450 

and Hilight Road are not moved. 

3.8.2.1.4 West Jacobs Ranch LBA Tract

Potential impacts to soil resources on the LBA tract after final reclamation 

under the Proposed Action or Alternative 2 are quantified as follows. Under the 

currently approved mining and reclamation plan, approximately 14,853.0 acres 

of soil resources will be disturbed in order to mine the coal in the existing 

leases at the Jacobs Ranch Mine (Table 3-4). If the West Jacobs Ranch LBA 

Tract is leased, TBCC estimates disturbance related to coal mining would 

directly affect from approximately 7,023.0 to 9,370.0 additional acres of soil 

resources on and adjacent to the LBA tract under the Proposed Action or under 

Alternative 2, BLM’s preferred alternative, respectively (Table 3-4). Preliminary 

estimates indicate the redistributed soil thickness would average between 

about 26 inches (2.2 feet) and 36 inches (3.0 feet) across the entire reclaimed 

surface; varying redistribution depths to mimic the premine conditions. The 

types of soils and the quantities of the soil resource included in the West 

Jacobs Ranch LBA Tract as applied for and in Alternative 2, BLM’s preferred 

tract configuration, are similar to the soils on the existing leases at the 

adjacent Jacobs Ranch and Black Thunder mines. As discussed in Section 

3.0, the estimates of recoverable coal, associated disturbance, and mine life 

shown in Table 3-4 assume that State Highway 450 and Hilight Road are not 

moved. 

3.8.2.1.5 North Porcupine LBA Tract

Potential impacts to soil resources on the LBA tract after final reclamation 

under the Proposed Action or Alternative 2 are quantified as follows. Under the 

currently approved mining and reclamation plan, approximately 27,443.0 acres 

of soil resources will be disturbed in order to mine the coal in the existing 

leases at the North Antelope Rochelle Mine (Table 3-5). If the North Porcupine 

LBA Tract is leased, PRC estimates disturbance related to coal mining would 

directly affect from approximately 9,864.0 to 11,444.0 additional acres of soil 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-181 

resources on and adjacent to the LBA tract under the Proposed Action or under 

Alternative 2, BLM’s preferred alternative, respectively (Table 3-5). There are 

approximately 7,602.6 additional acres of soil resources within the North 

Porcupine LBA Tract as applied for plus a 1⁄4-mile disturbance buffer and 

approximately 9,021.4 additional acres of soil resources within the BLM study 

area (the LBA tract as applied for and the additional area evaluated under 

Alternative 2) plus the 1⁄4-mile disturbance buffer. Preliminary estimates 

indicate the average redistributed soil thickness would be about 35 inches (2.9 

feet) across the entire reclaimed surface; however, soil redistribution depths 

would vary to mimic the premine conditions. The types of soils and the 

quantities of the soil resource included in the North Porcupine LBA Tract as 

applied for and in Alternative 2, BLM’s preferred tract configuration, are similar 

to the soils on the existing leases at the adjacent North Antelope Rochelle Mine. 

As discussed in Section 3.0, the estimates of recoverable coal, associated 

disturbance, and mine life shown in Table 3-5 assume that Mackey Road is not 

moved. 

3.8.2.1.6 South Porcupine LBA Tract

Potential impacts to soil resources on the LBA tract after final reclamation 

under the Proposed Action or Alternative 2 are quantified as follows. Under the 

currently approved mining and reclamation plan, approximately 27,443.0 acres 

of soil resources will be disturbed in order to mine the coal in the existing 

leases at the North Antelope Rochelle Mine (Table 3-6). If the South Porcupine 

LBA Tract is leased, PRC estimates disturbance related to coal mining would 

directly affect from approximately 3,366.0 to 4,068.0 additional acres of soil 

resources on and adjacent to the LBA tract under the Proposed Action or under 

Alternative 2, BLM’s preferred alternative, respectively (Table 3-6). There are 

approximately 3,598.3 additional acres of soil resources within the South 

Porcupine LBA Tract as applied for plus a 1⁄4-mile disturbance buffer and 

approximately 4,020.5 additional acres of soil resources within the BLM study 

area (the LBA tract as applied for and the additional area evaluated under 

Alternative 2) plus the 1⁄4-mile disturbance buffer. Preliminary estimates 

indicate the average redistributed soil thickness would be about 24 inches (2.0 

feet) across the entire reclaimed surface; however, soil redistribution depths 

would vary to mimic the premine conditions. The types of soils and the 

quantities of the soil resource included in the South Porcupine LBA Tract as 

applied for and in Alternative 2, BLM’s preferred tract configuration, are similar 

to the soils on the existing leases at the adjacent North Antelope Rochelle Mine. 

As discussed in Section 3.0, the estimates of recoverable coal, associated 

disturbance, and mine life shown in Table 3-6 assume that the remaining 2.25-

mile section of Antelope Road is not moved. 

3.8.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and coal removal and the associated 
3.0 Affected Environment and Environmental Consequences 

3-182 Final EIS, Wright Area Coal Lease Applications 

disturbance and impacts to soils would not occur on the portions of the LBA 

tracts as applied for or the LBA tracts configured under Alternative 2 that will 

not be disturbed under the currently approved surface coal mining permits. 

Coal removal and associated soil removal and replacement would continue as 

currently permitted on the existing Black Thunder, Jacobs Ranch, and North 

Antelope Rochelle Mine coal leases. Impacts to soils related to mining 

operations at these three applicant mines would not be extended onto portions 

of the LBA tracts that will not be affected under the current mining and 

reclamation plans. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective 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. 

Unsuitable materials would be buried under adequate fill (at least 4 feet of 

suitable overburden) prior to soil redistribution to meet guidelines for 

vegetation root zones. After topsoil is redistributed on reclaimed surfaces, 

revegetation would reduce wind erosion. Sediment control structures would be 

constructed as needed to detain sediments. 

Regraded overburden would be sampled to verify suitability as subsoil for 

compliance with root zone criteria. Redistributed soil would be sampled to 

document redistribution depths. Vegetation growth would be monitored on 

reclaimed areas to confirm vegetation establishment and acceptability for bond 

release. Appropriate normal husbandry practices may be implemented to 

achieve specific reclamation goals. 

These measures are required by regulation and are therefore considered to be 

part of the Proposed Action and Alternative 2 for the North Hilight Field, South 

Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and 

South Porcupine LBA Tracts. 

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. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-183 

3.9 Vegetation

3.9.1 Affected Environment

The vegetation analysis area for each of the six LBA tracts included in this 

analysis is the respective tract’s general analysis area. As described in Section 

3.0, the general analysis area is defined as the LBA tract as applied for and the 

additional area evaluated under Alternative 2 (BLM’s study area) plus the 1⁄4-

mile buffer that would be disturbed in order to recover the coal in the BLM 

study area. The 1⁄4-mile buffer includes only those lands that are not already 

approved for disturbance under currently approved coal leases and mine plans. 

These vegetation analysis areas are either partially located within, contiguous 

to, or completely within current applicant mines’ permit boundaries. 

Consequently, portions or all of these vegetation analysis areas were previously 

mapped and sampled in accordance with the current WDEQ/LQD mine 

permitting requirements. The balance of the vegetation assessments were 

completed in 2007. The vegetation communities in these areas were appraised 

and mapped to provide a preliminary baseline assessment. 

The vegetation within the six vegetation analysis areas consists of species 

common to eastern Wyoming and consistent with vegetation that occurs within 

the adjacent mine permit areas. Water and disturbed areas were also mapped. 

The following vegetation types were identified in the combined vegetation 

analysis areas: 

• Crested Wheatgrass/Agricultural Pastureland 

• Pasture/Hayland 

• Undeveloped Pastureland 

• Upland/Mixed Prairie Grassland 

• Big Sage Shrubland 

• Bottomland/Streamside Grassland/Meadow 

• Disturbed Lands 

• Reclaimed Lands 

• Playa/Playa Grassland 

• Rough Breaks/Breaks Grassland 

• Reservoir/Water 

• Salt Grassland/Saline Bottomland/Alkali Bottomland 

Table 3-14 presents the acreage and percent of the combined vegetation 

analysis areas encompassed by each vegetation type. Additional information 

about the vegetation types within each of these six LBA tracts is included in 

the supplementary information document, which is available on request. 

In terms of total acres of occurrence within the combined vegetation analysis 

areas, the predominant vegetation types are the Big Sage Shrubland (42.2 

percent), Upland/Mixed Prairie Grassland (27.8 percent), and Crested 

Wheatgrass/Agricultural Pastureland (15.3 percent). The most common plant 

species on these types include Wyoming big sagebrush, western wheatgrass,
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3-184 Final EIS, Wright Area Coal Lease Applications 

Table 3-14. Vegetation Types Identified and Mapped Within the Combined 

Vegetation Analysis Areas. 

Vegetation Type Acres Percent of Area 

Big Sage Shrubland 18,329.1 42.2 

Upland/Mixed Prairie Grassland 12,079.5 27.8 

Crested Wheatgrass/ 

Agricultural Pastureland 

6,657.8 15.3 

Salt Grassland/Saline 1,730.1 4.0 

Rough Breaks/Breaks Grassland 1,533.8 3.5 

Disturbed Lands 940.5 2.2 

Bottomland/Streamside 699.1 1.6 

Playa/Playa Grassland 613.6 1.0 

Pasture/Hayland 317.5 0.7 

Reclaimed Lands 223.0 0.5 

Undeveloped Pastureland 192.6 0.4 

Reservoir/Water 105.6 0.2 

Total 43,422.2 100.0

needleandthread, blue grama, crested wheatgrass, red threeawn, Sandberg 

bluegrass, prairie junegrass, cheatgrass brome, sixweeksgrass, and upland 

sedges. Wyoming big sagebrush is the dominant shrub in the Big Sage 

Shrubland and Upland/Mixed Prairie Grassland vegetation communities. 

Annual grasses and forbs, lichens, and manyspine plains pricklypear cactus 

are frequently large components of the vegetation cover. 

The predominant vegetation type on approximately 15 percent of the combined 

vegetation analysis area is the crested wheatgrass pastureland. This vegetation 

type occurs on relatively flat areas to rolling plains with moderately deep to 

deep soils that have been converted (at least originally and intentionally) from 

native vegetation to crested wheatgrass that is being used for haying or grazing 

purposes. Through time, those areas that have not been actively managed are 

likely to experience invasion by native plant species from adjacent areas. This 

vegetation type therefore ranges from areas that are generally a crested 

wheatgrass monoculture to areas with a greater component of graminoid, 

shrub and subshrub species. Blue grama, purple and red threeawn, 

Junegrass, cheatgrass brome, and needleandthread are among the more 

commonly invading grasses. 

The various categories of disturbance (topsoil stockpiles, reclaimed areas, 

disturbed areas, pre-mining disturbance, and developed areas) account for 

approximately 2.7 percent of the combined vegetation analysis area. Areas 

mapped as disturbed are mostly associated with advancing excavation 

associated with the backslopes of mine pits, disturbance associated with CBNG 

development activity (roads to drill pads, wellpads, and pipeline and powerline 

construction), areas recently excavated and contoured as part of the 

construction of a flood control structure, and rights-of-way for public roads. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-185 

In addition to these major vegetation types identified in the combined 

vegetation analysis area, trees are found primarily in a few 

shelterbelts/windbreaks planted adjacent to ranching facilities. Very few other 

small trees are present due to the lack of water and suitable habitats. Prior to 

mining disturbance, detailed tree inventories would be conducted as required 

by state and federal agencies. 

There are few occurrences of noxious weeds within the three applicant mine 

areas; however, there are native areas (primarily drainage bottoms) adjacent to 

mine permit areas that are infested with noxious weeds, primarily Canada 

thistle. 

3.9.2 Environmental Consequences

3.9.2.1 Proposed Action and Alternatives 2 and 3

Under the currently approved mining and reclamation plans, approximately 

69,108.0 acres of vegetation will be disturbed in order to mine the coal in the 

existing leases at the Black Thunder, Jacobs Ranch, and North Antelope 

Rochelle mines. Surface disturbance would occur on the six LBA tracts under 

all of the alternatives. Under the Proposed Actions, mining of the six LBA 

tracts would progressively remove the existing vegetation on approximately 

32,783 additional acres on and near the LBA tracts. Under Alternative 2, 

BLM’s preferred alternative for each tract, mining of the six LBA tracts would 

progressively remove the existing vegetation on up to 50,773 additional acres. 

Vegetation removal at each LBA tract under the Action Alternatives is 

presented as the additional mine disturbance areas in Tables 3-1 through 3-6. 

Under Alternative 2, the combined vegetation analysis area of 43,422.2 acres 

(Table 3-14) would be disturbed, and potentially 7,350.8 additional acres, 

which would be included in additional baseline vegetation inventories as part of 

the mine permitting processes if the LBA tracts are leased and proposed for 

mining. 

Short-term impacts associated with the removal of vegetation from the LBA 

tracts would include increased erosion, interrupted livestock grazing, and 

habitat loss for wildlife. Potential long-term impacts include habitat 

modification or reduction of habitat carrying capacity for some wildlife species 

as a result of reduced plant species diversity or reduced plant density for some 

species, particularly big sagebrush, on reclaimed lands. However, grasslanddependent wildlife species and livestock would benefit from the increased grass 

cover and production. 

Grazing restrictions prior to mining and during reclamation would remove up 

to 100 percent of the areas proposed for mining 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. The applicant mines’ historical wildlife 
3.0 Affected Environment and Environmental Consequences 

3-186 Final EIS, Wright Area Coal Lease Applications 

monitoring indicates that there would not be a substantial restriction of wildlife 

use of the area throughout the operations (refer to Section 3.10). 

Reclamation, including revegetation of these lands, would occur 

contemporaneously with mining on adjacent lands, i.e., reclamation would 

begin once an area is mined. Estimates of the time elapsed from soil salvage 

through reseeding of any given area range from 2 to 4 years, longer for areas 

occupied by stockpiles, haulroads, sediment-control structures, and other 

mine facilities. No new life-of-mine facilities would be located on the LBA tracts 

under the Proposed Action or Alternatives 2 or 3 because the LBA tracts would 

be mined as an extension of an existing mine using existing facilities. Some 

roads and facilities would not be reclaimed until the end of mining. 

Reclamation of the final pits, certain roads, sediment control structures, and 

life-of-mine facilities would extend beyond the completion of coal removal. By 

the time mining ceases, over 75 percent of the disturbed lands would have 

been reseeded. The remaining 25 percent would be reseeded during the 

following 2 to 3 years as the life-of-mine facilities areas are reclaimed. 

In an effort to approximate premining conditions, the applicants would plan to 

reestablish vegetation types to reflect premine types and land uses 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 primarily a mixture of prairie grasslands with 

graminoid/forb-dominated areas. An overall reduction in species diversity, 

especially for the shrub component, would occur. At least 20 percent of the 

native vegetation area would be reclaimed to native shrubs at a density of one 

per square meter 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. As indicated previously, sagebrush is a 

component of the Big Sagebrush Shrubland and Upland/Mixed Prairie 

Grassland vegetation communities, which together occupy about 70 percent of 

the combined vegetation analysis area (Table 3-14). 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 the vegetation 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 tracts. 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. 

The reclamation plans for the existing mines include steps to control invasion 

by weedy (invasive nonnative) plant species because WDEQ/LQD rules and 

regulations require surface coal mine operators to control and minimize the 

introduction of noxious weeds until bond release, in accordance with federal 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-187 

and state regulatory requirements. Section 3.9.4 includes a discussion of the 

steps the mines use to control noxious weeds. As a result, there are few 

occurrences of noxious weeds in the mine areas. The reclamation plan for each 

LBA tract would also include steps to control invasion from such species. 

Wyoming, including the PRB, has experienced drought conditions since around 

2000. The climatic record of the western U.S. suggests that droughts could 

occur periodically during the life of the applicant mines. Such droughts would 

severely hamper revegetation efforts, since lack of sufficient moisture would 

reduce germination and could damage newly established plants. In such 

instances, reseeding may be necessary. Same-aged vegetation would be more 

susceptible to disease than would plants of various ages. Droughts could also 

result in stands of vegetation in which less gregarious plants like warm season 

grasses are better established. Severe thunderstorms could also adversely 

affect newly seeded areas. However, these events would have similar impacts 

as would occur on native vegetation once a stable vegetative cover is 

established. 

Changes expected in the surface water network on each 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 would be 20 percent, in accordance with WDEQ policy. The average 

reclaimed overland slope on each LBA tract would not be known until WDEQ’s 

technical review of each mine permit revision application is complete. No 

significant changes in the average overland slope are predicted. 

There would be no net loss of jurisdictional wetlands. They would be restored 

under the jurisdiction of the COE (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. 

The decrease in plant diversity would not seriously affect the potential 

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 species. Native vegetation from surrounding areas would gradually 

invade and eventually become established on the reclaimed land. 

3.9.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and coal removal and the associated 

disturbance and impacts to vegetation would not occur on the portions of the 

LBA tracts as applied for or the LBA tracts configured under Alternative 2 that 

will not be disturbed under the currently approved surface coal mining 

permits. Coal removal and the associated vegetation removal and replacement 
3.0 Affected Environment and Environmental Consequences 

3-188 Final EIS, Wright Area Coal Lease Applications 

would continue as currently permitted on the existing Black Thunder, Jacobs 

Ranch, and North Antelope Rochelle Mine coal leases. Impacts to vegetation 

related to mining operations at these three applicant mines would not be 

extended onto portions of the LBA tracts that will not be affected under the 

current mining and reclamation plans. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective tract in the future. 

3.9.3 Threatened, Endangered, Proposed, and Candidate Plant Species, and 

BLM and USFS Sensitive Plant Species

Refer to Appendices G and H. 

3.9.4 Regulatory Compliance, Mitigation and Monitoring

Reclaimed areas would be revegetated as specified in the approved mine plans 

using reclamation seed mixtures that would be approved by WDEQ. The 

majority of the species would be native to the LBA tracts. 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. Shrubs would be 

selectively planted in riparian areas and trees would be replaced in a one-toone 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)). 

In accordance with these requirements, the Black Thunder, Jacobs Ranch, and 

North Antelope Rochelle mines work with the Campbell County Weed and Pest 

Department and conduct active noxious weed control programs on their 

existing coal leases and mine permit areas. If these LBA tracts are leased and 

proposed for mining, the mines would be required to continue to utilize those 

practices on their new lease areas as part of the mine permitting processes. 

The COE would ensure no net loss of jurisdictional wetlands and their 

associated vegetation occurs within the total disturbance area. Detailed 

wetland mitigation plans would be developed and approved by the COE during 

the permitting stage. Non-jurisdictional and functional wetlands would be 

reestablished in accordance with the requirements of the surface landowner or 

as required by WDEQ/LQD (Section 3.7). 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-189 

Revegetation growth and diversity would be monitored until the final 

reclamation bond is released (a minimum of 10 years following seeding with the 

approved 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 following revegetation to manage the vegetation and 

determine the suitability and effectiveness of the reclaimed land for the postmining land uses. 

OSM evaluates the success of contemporaneous reclamation by evaluating the 

timeliness of reclamation bond release. According the OSM’s 2009 evaluation 

of the Wyoming regulatory program, with respect to achieving the purposes of 

SMCRA, a total of approximately 5,500 acres were disturbed within the state at 

all surface coal mines, 3,955 acres received Phase I bond release, 1,424 acres 

received Phase II bond release, and 341 acres received Phase III bond release 

(OSM 2009). Another measurement OSM uses for contemporaneous 

reclamation success at Wyoming surface coal mines is by comparison of the 

rate at which lands are being permanently reclaimed (seeded) to the rate of 

disturbance. OSM’s 2009 evaluation indicates that approximately 4,700 acres 

were seeded, which is a reclamation to disturbance ratio of approximately 86 

percent. OSM’s most recent evaluation of contemporaneous reclamation at 

Wyoming’s surface coal mines finds that reclamation is proceeding on schedule 

consistent with the requirements of the state’s regulatory program (OSM 2009). 

3.9.5 Residual Impacts

Reclaimed vegetative communities may never completely match the 

surrounding native plant community. 

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. 

3.10.1.1 Affected Environment

Background information on wildlife in the general Wright analysis area was 

drawn from several sources, including Wyoming Game and Fish Department 

(WGFD) and U.S. Fish and Wildlife Service (USFWS) records, the Wyoming 

Natural Diversity Database (WYNDD), recent PRB federal coal lease application 

EIS documents (available for public review on Wyoming BLM’s website at 

http://www.blm.gov/wy/st/en.html), and personal contacts with WGFD and 

USFWS biologists. Site-specific data for the North Hilight Field, South Hilight 

Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South 

Porcupine LBA Tracts were obtained from several sources, including baseline 

information contained in WDEQ/LQD mine permit applications and annual 
3.0 Affected Environment and Environmental Consequences 

3-190 Final EIS, Wright Area Coal Lease Applications 

wildlife monitoring reports for the applicant mines and nearby coal mines. In 

accordance with the current WDEQ/LQD mine permitting requirements, 

wildlife baseline surveys and annual monitoring surveys extend 1 to 2 miles 

beyond the mine permit area, depending on the mine and the species. 

The general analysis area for each of the six LBA tracts included in this 

analysis is defined as the respective tract’s BLM study area plus surrounding 

lands within a 1⁄4-mile perimeter that could be disturbed by mining the coal 

within the BLM study area. The wildlife survey area typically overlaps 

significant portions of the general analysis area for all of the LBA tracts, 

providing long-term wildlife data for those areas. The wildlife survey areas for 

this analysis includes the general analysis areas plus a surrounding perimeter 

that varies in extent depending on the species. The general Wright analysis 

area represents the entire area covered by all of the general analysis areas for 

these six LBA tracts. 

Due to the proximity of the proposed lease areas to the adjacent applicant mine 

permit areas, the general analysis areas for these six LBA tracts have received 

some level of coverage annually since the early 1980s. Increasing percentages 

of the general analysis areas were included in annual monitoring efforts as 

survey areas for the adjacent mines have been expanding due to previous coal 

lease acquisitions and subsequent permit area amendments. In addition, 

TBCC conducted baseline investigations during 2006 and early 2007 

specifically for the West Hilight Field LBA Tract with additional surveys 

targeting the North and South Hilight Field LBA Tracts in 2007 and 2008 (J&S 

2008); JRCC conducted baseline investigations in 2007 and 2008 expressly for 

the West Jacobs Ranch LBA Tract (IR 2008); and PRC conducted baseline 

investigations during 2007 and early 2008 specifically for the North and South 

Porcupine LBA Tracts (J&S 2009). These surveys covered the respective 

general analysis areas, and surveys for selected wildlife information such as 

raptor nest and greater sage-grouse lek locations included in a 2-mile 

perimeter surrounding the general analysis areas. Site-specific surveys for 

each lease area and appropriate perimeters would be part of the mine 

permitting process if the tracts are leased. 

The topography within the general Wright analysis area (discussed in Section 

3.2) is mainly of gently rolling upland terrain broken by minor drainages and 

internally-drained playa areas. Most of the land surface (between 75 and 90 

percent, depending on the particular LBA tract) seldom exceeds a 5 percent 

slope. The steepest slopes typically occur near the highest elevations along the 

ridge lines and drainage divides, at the breaks or the broken land dissected by 

small ravines and gullies, or at the transitions between uplands and bottom 

lands. Surface mine lands, both active and reclaimed, dominate the landscape 

generally east and south of the LBA tracts. Elevations range from 

approximately 4,690 to 5,170 feet above sea level. 

In an undisturbed condition, the major vegetation types in the general Wright 

analysis area (discussed in Section 3.9) provide high quality habitats for many 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-191 

species. Vegetation types tend to occur in a 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 tracts 

and adjacent areas generally correspond with the major vegetation 

communities defined during the vegetation baseline surveys; they consist 

primarily of Big Sage Shrubland, Upland/Mixed Prairie Grassland, and Crested 

Wheatgrass/Agricultural Pastureland. 

The predominant wildlife habitat type within the general Wright analysis area 

is shrubland (approximately 42 percent), which consists mostly of Wyoming big 

sagebrush. The native upland/mixed prairie grasslands is the next largest 

habitat type (approximately 28 percent) and it consists mostly of western 

wheatgrass, needleandthread, prairie junegrass, blue grama, Sandberg 

bluegrass, and cheatgrass brome. The seeded grassland/agricultural 

pastureland (approximately 15 percent) is dominated by crested wheatgrass, 

but older seedings have a mixture of less dominant native plant species 

including, needleandthread, prairie junegrass, red threeawn, sixweeksgrass, 

big sagebrush, and upland sedges. No designated critical, crucial, or unique 

habitats are present. 

Mesic (requiring a moderate amount of moisture) habitats are limited to narrow 

corridors along primary drainages (Porcupine Creek, Little Thunder Creek, 

North Prong Little Thunder Creek, and some of the larger tributaries of these 

streams). Several playas dominated by western wheatgrass are scattered 

throughout the general Wright analysis area. Very few trees are present, the 

majority of which were planted in shelterbelts/windbreaks around ranch 

buildings. A few other isolated trees exist along some drainages. An 

occasional rough breaks habitat occurs and is distinguished by the irregularity 

of vegetation, slopes, and soils. Vegetation on the rough breaks is typically 

sparse, although the diversity of vascular plant species is greater than in the 

Big Sage Shrubland and Upland/Mixed Prairie Grassland communities. As a 

result of oil and gas development, there are networks of road and well-pad 

disturbance areas overlaying much of the areas, as well as tank batteries and 

miles of pipeline disturbance with varying degrees of recovering vegetative 

cover. 

From north to south, the general Wright analysis area is drained by Black 

Thunder Creek, North Prong Little Thunder Creek, Little Thunder Creek, 

Porcupine Creek, Horse Creek, and Antelope Creek (discussed in Section 3.5). 

Under natural conditions, all water courses in the general Wright analysis area 

are ephemeral, receiving flow contributions primarily from convective 

thunderstorm runoff and, to a lesser extent, from snowmelt runoff in the spring 

(Ogle and Calle 2006). Limited portions of the streams may receive recharge 

from bank storage, making them locally intermittent. Historically, water was 

often present in the main stream channels only as small, shallow, isolated 

pools. Currently, and for an indefinite time into the future, some of the water 

courses and internally-drained playas are receiving discharge water from CBNG 

development; however, streamflow is still very much a function of the amount 
3.0 Affected Environment and Environmental Consequences 

3-192 Final EIS, Wright Area Coal Lease Applications 

and timing of precipitation and snowmelt runoff. Therefore, the mean annual 

streamflow rates and discharge volumes have not significantly increased, 

although extended periods of no flow are less common (Clark and Mason 2007). 

Despite the recent influx of water into the general Wright analysis area, many 

channels are still reduced to isolated, shallow pools in the summer. Seventeen 

stock reservoirs (over 1 acre in size) and 41 playa areas exist within the six 

wildlife general analysis areas. Those water bodies provide short-term habitat 

for migrating waterfowl, shorebirds, and other aquatic species 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 2 and 3

If the North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs 

Ranch, North Porcupine, and South Porcupine LBA Tracts are leased under the 

Proposed Action or Alternative 2 or 3, the areal extent of coal mining operations 

would increase. Estimated disturbance areas for each of these six LBA tracts 

under the respective Proposed Action and Alternative 2, BLM’s preferred 

alternative configuration for each tract, are presented in Tables 3-1 through 3-

6. At the Black Thunder Mine, mining operations would be extended by up to 

about 4.8 additional years for the North Hilight Field tract, 2.3 additional years 

for the South Hilight Field tract, and 7.1 additional years for the West Hilight 

Field tract under Alternative 2, BLM’s preferred alternative, for each LBA tract. 

At the Jacobs Ranch Mine, mining operations would be extended by up to 

about 22.8 additional years under Alternative 2, BLM’s preferred alternative, 

for the West Jacobs Ranch LBA Tract. At the North Antelope Rochelle Mine, 

mining operations would be extended by up to about 7.8 additional years for 

the North Porcupine tract and 3.6 additional years for the South Porcupine 

tract under Alternative 2, BLM’s preferred alternative for each LBA tract. 

Wildlife habitat outside of tracts’ general analysis areas may be removed by 

adjacent mining activities unrelated to the LBA tracts. Impacts to wildlife that 

would be caused by mining the LBA tracts would be addressed as part of the 

review of the mine permit applications by the WGFD, USFWS, and the 

WDEQ/LQD when the mining and reclamation permits are amended to include 

the LBA tracts. 

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 shortterm. They include injury and mortalities caused by collisions with minerelated traffic or mortalities due to loss of habitat (especially for species with 

limited mobility such as fish and some herptiles); restrictions on wildlife 

movement created by fences, spoil piles, and mine 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 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-193 

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 North Hilight Field, South Hilight Field, West 

Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA 

Tracts were leased and mined, the direct impacts related to mine traffic and 

mine operations would be extended within the general Wright analysis area by 

up to as many as 22.8 years (for the West Jacobs Ranch LBA Tract under 

Alternative 2). 

The indirect impacts are longer term than the direct impacts. Results from 

long-term surveys conducted in both native and reclaimed habitats at the three 

applicant mines, and from those completed 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 tracts are 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 tracts, 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. 

3.10.1.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and the impacts to wildlife and 

wildlife habitat associated with coal removal as described above would not 

occur on the portions of the LBA tracts as applied for or the LBA tracts 

configured under Alternative 2 that will not be disturbed under the currently 

approved surface coal mining permits. Mining operations and the associated 

impacts to wildlife and wildlife habitat would continue as currently permitted 

on the existing Black Thunder, Jacobs Ranch, and North Antelope Rochelle 

Mine coal leases, but would not be extended onto portions of the LBA tracts 

that will not be affected under the current mining and reclamation plans. 

Impacts to wildlife and wildlife habitat associated with CBNG development 
3.0 Affected Environment and Environmental Consequences 

3-194 Final EIS, Wright Area Coal Lease Applications 

would continue where those activities overlap with the six LBA tracts included 

in this analysis. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective tract in the future. 

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 Wright analysis area are pronghorn (Antilocapra americana) and mule 

deer (Odocoileus hemionus). Elk (Cervus elaphus) are frequent winter residents 

in the area, but spend most of the year in the Rochelle Hills east of the general 

Wright analysis area. White-tailed deer (Odocoileus virginianus) are seldom 

observed within the general Wright analysis area due to their preference for 

riparian woodlands and irrigated agricultural lands. No crucial big game 

habitat or migration corridors are recognized by the WGFD in this area. 

Pronghorn are by far the most common big game species in the general Wright 

analysis area. Pronghorn were observed using all habitat types, although this 

species is most abundant in the shrubland and native upland/mixed prairie 

grassland habitats. Reclaimed grassland constitutes only a small portion of 

the available habitat around the PRB mines, although pronghorn are observed 

during all seasonal surveys in these areas. Home range for pronghorn can vary 

between 400 acres to 5,600 acres, according to several factors including 

season, habitat quality, population characteristics, and local livestock 

occurrence. Typically, daily movements do not exceed 6 miles. Pronghorn may 

make seasonal migrations between summer and winter habitats, but 

migrations are often triggered by availability of preferred forage availability and 

not local weather conditions (Fitzgerald et al. 1994). The WGFD has classified 

the general Wright analysis area as primarily yearlong pronghorn range (a 

population or substantial portion of a population of animals makes general use 

of this habitat on a year-round basis, but may leave the area under severe 

conditions on occasion) and winter/yearlong pronghorn range (a population or 

a portion of a population of animals makes general use of this habitat on a 

year-round basis, with a significant influx of additional animals onto this 

habitat from other seasonal ranges in the winter). No crucial winter range for 

pronghorn is contained in the general Wright analysis area. The general 

Wright analysis area spans two pronghorn WGFD herd units: the Hilight Herd 

Unit (antelope Hunt Area 24) north of State Highway 450 and the Cheyenne 

River Herd Unit (antelope Hunt Area 27) south of the State Highway 450. In 

post-season 2007, the WGFD estimated the Hilight Herd Unit population to be 

12,397 animals, with an objective of 11,000; the Cheyenne River Herd Unit 

estimate was 55,287, which is 45 percent above the objective of 38,000 

animals (WGFD 2007a). 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-195 

Mule deer use nearly all habitats, but prefer sagebrush grassland, rough 

breaks, 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 frequently observed in 

native habitats and on mine reclaimed lands within existing mine permit areas. 

In certain areas of the state this species tends to be more migratory than whitetailed deer, traveling from higher elevations in the summer to winter ranges 

that provide more food and cover. However, monitoring has indicated that 

mule deer are not very migratory in the vicinity of the general Wright analysis 

area. The WGFD has classified a majority of the general Wright analysis area 

as being out of the normal mule deer use range, although areas that roughly 

follow the predominant stream channels are classified as being yearlong range, 

which means that a population or substantial portion of a population of 

animals makes general use of this habitat on a year-round basis, but may 

leave the area under severe conditions on occasion. The entire general Wright 

analysis area is located within the WGFD Thunder Basin Mule Deer Herd Unit 

(mule deer Hunt Areas 10 and 21). No crucial or critical mule deer ranges or 

migration corridors occur on or within several miles of the general Wright 

analysis area. Crucial range is defined as any particular seasonal range or 

habitat component that has been documented as the determining factor in a 

population’s ability to maintain and reproduce itself at a certain level. The 

WGFD estimated the 2007 post-season mule deer population in this herd unit 

at 20,980, which is about 5 percent above the current objective of 20,000 deer 

(WGFD 2007a). 

White-tailed deer are not managed separately by the WGFD, but are managed 

and hunted in conjunction with mule deer. White-tailed deer prefer riparian 

habitats and are therefore seldom observed in the general Wright analysis area 

due to the lack of that particular habitat. The WGFD classifies the entire 

general Wright analysis area, with the exception of a narrow corridor along 

Antelope Creek, as out of the normal white-tailed deer use range. The Antelope 

Creek corridor is classified as yearlong range. The entire general Wright 

analysis area is located within the WGFD Central White-tailed Deer Herd Unit 

(white-tailed deer Hunt Areas 10 and 21). The WGFD does not have population 

estimates for this herd unit due to the challenges of obtaining adequate 

classifications in many hunt areas within the herd unit given the 

preponderance of private land and the poor visibility of deer in riparian areas. 

Another factor preventing reasonable population estimates is that these whitetailed deer are highly mobile and their movements in central and northeastern 

Wyoming are not well understood (WGFD 2007a). 

A resident elk herd resides in the Rochelle Hills east of the general Wright 

analysis area. Elk do wander from the protection of the Rochelle Hills to forage 

in native and reclaimed grasslands in the vicinity of the general Wright analysis 

area. None of the general Wright analysis area is classified by the WGFD as 

within normal elk use range. As more lands are reclaimed from mining, elk are 

shifting their winter use to these areas. The WGFD has designated an 
3.0 Affected Environment and Environmental Consequences 

3-196 Final EIS, Wright Area Coal Lease Applications 

approximately 5 square mile area on reclaimed lands within the Jacobs Ranch 

Mine permit area as crucial winter habitat for the Rochelle Hills elk herd 

(Oedekoven 1994). Rio Tinto Energy America (RTEA) (the previous owner of 

Jacobs Ranch Mine) and the Rocky Mountain Elk Foundation (RMEF) finalized 

a formal agreement that created the Rochelle Hills Conservation Easement. 

The easement contains nearly 1,000 acres, with 75 percent of that total 

comprised of reclaimed mine lands within the Jacobs Ranch Mine permit area. 

The easement acreage was donated to RMEF by RTEA to ensure that the 

reclaimed land continues to be used as grazing land and wildlife habitat for the 

extended future (RMEF 2007). Elk have occasionally been observed within the 

general Wright analysis area in recent years, but they are typically restricted to 

the pine breaks of the Rochelle Hills, which are located immediately east of the 

three applicant mines. The WGFD estimated the 2007 post-season elk 

population for the Rochelle Hills Herd Unit at 600, which is 50 percent above 

the current objective of 400 animals (WGFD 2007a). 

3.10.2.2 Environmental Consequences

3.10.2.2.1 Proposed Action and Alternatives 2 and 3

Under the respective Proposed Action and Alternative 2, BLM’s preferred 

alternative configuration for each LBA tract, big game would be displaced from 

portions of the North Hilight Field, South Hilight Field, West Hilight Field, West 

Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts to adjacent 

ranges during mining. Pronghorn would be most affected due to their greater 

abundance in the area; however, no areas classified as crucial pronghorn 

habitat occur on or within 2 miles of these LBA tracts. Mule deer would not be 

substantially impacted, given their infrequent use of these lands and the 

availability of suitable habitat in adjacent areas. White-tailed deer are not 

usually found in the area but are occasionally observed to the south along 

Antelope Creek. None of the land within the general Wright analysis area is 

considered by WGFD to be an elk use area, although the Rochelle Hills Elk 

Herd are shifting their winter use to reclaimed lands within the general Wright 

analysis area. Removal of sagebrush and grassland habitat will reduce overall 

forage for all three of these big game species. 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 avoidance of foraging 

areas adjacent to mining activities. On the existing coal leases, however, big 

game have continued to occupy areas adjacent to and within active mining 

operations, suggesting that some animals may become habituated to such 

disturbances. 

Big game animals are highly mobile and can move to undisturbed areas. 

However, there would be more restrictions on big game movement on or 

through these six LBA tracts due to the construction of additional fences, spoil 

piles, and open pits related to mining. During winter storms, pronghorn may 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-197 

not be able to negotiate these barriers. WDEQ guidelines require fencing to be 

designed to permit passage pronghorn and other big game species, to the 

extent possible. 

Following reclamation, topographic moderation and changes in vegetation may 

result in a long-term reduction in big game carrying capacity, with effects 

varying by species. Eventual restoration of important shrub habitats would 

allow for the return of some animals to reclaimed mine lands over time. 

3.10.2.2.2 No Action Alternative

The impacts to big game under the No Action Alternative would be similar to 

the impacts 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 Wright analysis area, although not all have been observed on the 

LBA tracts themselves. These include predators and furbearers, such as the 

coyote (Canis latrans), red fox (Vulpes vulpes), bobcat (Lynx rufus), striped 

skunk (Mephitis mephitis), long-tailed weasel (Mustela frenata), badger (Taxidea 

taxus), muskrat (Ondatra zibethicus), raccoon (Procyon lotor), and beaver 

(Castor canadensis). Prey species include rodents [such as mice, rats, voles, 

gophers, ground squirrels, black-tailed prairie dogs (Cynomys ludovicianus), 

muskrats, and chipmunks] and lagomorphs (jackrabbits and cottontails). 

These prey species are cyclically common and widespread throughout the 

region. Porcupines (Erethizon dorsatum) and bats (such as hoary [Lasiurus 

cinereus] and big brown [Eptesicus fuscus]) also have habitat in the vicinity, 

primarily in forested habitats of the Rochelle Hills east of the general Wright 

analysis area. The prey species are important for raptors and other predators. 

The black-tailed prairie dog was added to the list of candidates for federal 

listing as a threatened or endangered species under the Endangered Species 

Act on February 4, 2000. The USFWS then removed the black-tailed prairie 

dog from the list of candidate species on August 12, 2004. On December 2, 

2008, the USFWS announced a 90-day finding on a petition seeking federal 

protection of the black-tailed prairie dog under the ESA. The USFWS 

subsequently announced that it will conduct a 12-month finding, which will 

end February 2, 2009, to determine if listing of the species is warranted 

(USFWS 2009). The USFWS 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 BLM 

Sensitive Species and a USFS Sensitive Species (see Appendix H). 

The black-tailed prairie dog is a highly social, diurnally active, burrowing 

mammal. Aggregations of individual burrows, known as colonies, form the 
3.0 Affected Environment and Environmental Consequences 

3-198 Final EIS, Wright Area Coal Lease Applications 

basic unit of prairie dog populations. Found throughout the Great Plains in 

short-grass and mixed-grass prairie areas (Fitzgerald et al. 1994), the blacktailed 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 through 

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 2000 and 2009). 

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). Prairie dogs construct extensive burrow 

systems in fine- to medium-textured upland soil types. The USFWS’s most 

recent estimate of occupied black-tailed prairie dog habitat in Wyoming, which 

was made in 2004, is approximately 125,000 acres (USFWS 2004b). Many 

other wildlife species, such as the black-footed ferret (Mustela nigripes), swift 

fox (Vulpes velox), mountain plover (Charadrius montanus), 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 2000 

and 2009). 

According to USFS observations on the Thunder Basin National Grassland 

(TBNG), which overlaps portions of the general Wright analysis area, the largest 

concentrations of prairie dog colonies in the vicinity of the eastern PRB surface 

coal mines are found east of the coal burnline, which is outside and east of the 

area of surface coal mining (Byer 2003). The large prairie dog complexes in 

this area east of the coal burnline have been drastically impacted by outbreaks 

of plague at irregular intervals over the years. The colonies west of the 

burnline, including those within the general Wright analysis area, are generally 

smaller and less densely concentrated. These colonies have not been affected 

by plague to the same degree as those located east of the burnline, likely due to 

their reduced size and density. 

Qualified wildlife biologists with Intermountain Resources (of Laramie, 

Wyoming) and Thunderbird-Jones & Stokes (of Gillette, Wyoming) have 

mapped the current acreage of prairie dog colonies on and within 2 miles of the 

general analysis areas for each of these six LBA tracts. Biologists walked the 

perimeters of colonies and delineated them using hand-held global positioning 

system receivers and/or visually mapped them on topographic maps. Figures 

3-32 through 3-37 depict the location and extent of prairie dog colonies that 

are completely and partially within the 2-mile perimeter that encompasses the 

general analysis area for the North Hilight Field, South Hilight Field, West 

Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA 

Tract, respectively. There are overlaps between the six prairie dog survey area 

boundaries, and as such, there are overlaps in the depiction of colonies on
Keeline

Road Jacobs

State

Hilight Road

Road

Keeline Road

Highway 450

State

450 Highway

BNSF & UP RR

Shroyer

Road

Small Road

31

30

19

18

7

6

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

29

20

17

8

5

28

21

16

9

4

27

22

15

10

3

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

29

20

17

8

5

28

21

16

9

4

27

22

15

10

3

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

32

29

33

28

34

27

35

26

36

25

31

30

32

29

33

28

34

27

35

26

36

25

31

30

Little

Thunder

Creek

North

Prong

Little

Thunder

Creek

Creek

Thunder

Black

Creek

Coal

Fork

West

T.

45

N.

T.

44

N.

T.

45

N.

T.

44

N.

R. 70 W. R. 69 W.

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

FH/SH

FH

FH

FH

FH

FH

FH

FH

FH

BO

BO

SH

FH

FH

FH

SH

GE

FH

SH/FH

SH/RTH/FH

FH

FH

GE

FH

FH

FH

FH

SH SH

FH

SH/FH

FH

FH

FH

FH

FH

FH

FH

FH

SH

SH

SH/GHO

BO

BO

BO

BO

SH

FH

Butch

Lek

Stuart II

Lek

Hansen

Lakes

Lek

SH SH

SH

FH

FH FH

Black Thunder Mine

Permit Boundary

North Hilight Field LBA

Tract as Applied for

North Hilight Field LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

0 5000 10000 20000

GRAPHIC SCALE (FEET)

2-Mile Wildlife Study Area Boundary

General Analysis Area

LEGEND

BO

GHO

SH

RTH

FH

GE

Burrowing Owl

Great Horned Owl

Swainson's Hawk

Red-tailed Hawk

Ferruginous Hawk

Golden Eagle

Prairie Dog Colony

Existing Platform Nest

Former Raptor Nest

Existing Raptor Nest

Occupied Sage-Grouse Lek

(Active at Least Once Within the Last 10 Years)

and 3-Mile Radius

Unoccupied (Abandoned) Sage-Grouse Lek

(No Activity for 10 Consecutive Years)

Undetermined Sage-Grouse Lek

(No Documented Activity for Last 10 Years but

Insufficient Information to Designate Unoccupied)

and 3-Mile Radius

Figure 3-32. Raptor Nest Sites, Sage-Grouse Leks, and Prairie Dog Colonies Within and Adjacent to the

North Hilight Field LBA Tract.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-199
Reno Road

State

Antelope

Edwards

Small

Matheson Road

Reno Road

Hilight Road

Road

Highway 450

Road

Road

BNSF & UP RR

Mackey Road

31

30

32

29

33

28

34

27

35

26

31

30

32

29

33

28

34

27

35

26

36

25

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

36

25

24

13

12

1

25

24

13

12

1

30

19

18

7

6

29

20

17

8

5

28

21

16

9

4

27

22

15

10

3

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

29

20

17

8

5

28

21

16

9

4

27

22

15

10

3

26

23

14

11

2

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

T.

43

N.

T.

42

N.

Little

Thunder

Creek

North

Prong

Creek

Porcupine

Little

Thunder

Creek

T.

44

N.

T.

43

N.

T.

44

N.

T.

43

N.

R. 72 W. R. 71 W.

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

FH FH FH

FH

FH

FH

FH/RTH

FH

FH FH FH

FH

FH

SH/FH

FH

GE

FH

FH

SH/GE GE

FH

FH

FH

FH FH

FH

GE

FH/RTH

GE

FH

FH

SH/FH

SH

FH/SH

SH/FH

SH/FH

FH

FH

FH

FH

FH FH

FH

FH

FH FH

FH

FH

FH

FH

FH

FH

Black

Thunder

Lek

Stuart II

Lek

Stuart I

Lek

Payne

Lek

South Hilight Field LBA

Tract as Applied for

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Black Thunder Mine Permit Boundary

LEGEND

SH

RTH

FH

GE

Swainson's Hawk

Red-tailed Hawk

Ferruginous Hawk

Golden Eagle

Prairie Dog Colony

Existing Platform Nest

Former Raptor Nest

Existing Raptor Nest

South Hilight Field LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

2-Mile Wildlife Study Area Boundary

General Analysis Area

Occupied Sage-Grouse Lek

(Active at Least Once Within the Last 10 Years)

and 3-Mile Radius

Unoccupied (Destroyed) Sage-Grouse Lek

(Destroyed and No Longer Suitable for Breeding)

Undetermined Sage-Grouse Lek

(No Documented Activity for Last 10 Years but

Insufficient Information to Designate Unoccupied)

and 3-Mile Radius

Figure 3-33. Raptor Nest Sites, Sage-Grouse Leks, and Prairie Dog Colonies Within and Adjacent to the

South Hilight Field LBA Tract.

3.0 Affected Environment and Environmental Consequences

3-200 Final EIS, Wright Area Coal Lease Applications
State

Antelope

Edwards

Small

Matheson Road

Reno Road

State 59 Highway

Hilight Road

Hilight Road

Road

Highway 450

Road

Road

BNSF & UP RR

BNSF & UP RR

30

19

18

7

6

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

30

19

18

7

35

26

23

14

11

2

36

25

24

13

12

1

35

26

23

14

11

2

36

25

24

13

12

1

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

29

20

17

8

5

28

21

16

9

4

27

22

15

10

3

26

23

14

11

2

25

24

13

12

1

30

19

18

7

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

North

Prong

Creek

Porcupine

Little

Thunder

Creek

R. 72 W. R. 71 W.

R. 72 W. R. 71 W.

FH/SH

BO

BO

SH

FH

FH

FH FH

SH

FH

GE

GE

FH

FH

FH FH

FH

FH

GE

FH

FH

FH

FH

FH

FH

SH/FH

FH

SH/RTH/FH

FH

FH

GE

GE

FH

FH

FH

FH/RTH

GE

BO

FH

FH

FH

SH/FH

FH

GE

FH

FH

SH/GE

GE

SH

SH

SH/GHO

FH

FH

FH

FH FH

FH

GE

FH/RTH

GE

SH/FH

SH

FH

FH

FH

FH

FH

FH

FH FH

FH

FH

FH

Stuart I

Lek

Stuart II

Lek

Black

Thunder

Lek

Little

Thunder Creek

SH

FH

GE

LEGEND

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Black Thunder Mine

Permit Boundary

West Hilight Field LBA

Tract as Applied for

BO

GHO

SH

RTH

FH

GE

Burrowing Owl

Great Horned Owl

Swainson's Hawk

Red-tailed Hawk

Ferruginous Hawk

Golden Eagle

Prairie Dog Colony

Existing Platform Nest

Former Raptor Nest

Existing Raptor Nest

West Hilight Field LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

2-Mile Wildlife

Study Area Boundary

General Analysis Area

West Hilight Field LBA

Tract Under Alternative 3

Unoccupied (Destroyed)

Sage-Grouse Lek

(Destroyed and No Longer

Suitable for Breeding)

Undetermined Sage-Grouse Lek

(No Documented Activity for Last

10 Years but Insufficient Information

to Designate Unoccupied)

and 3-Mile Radius

Figure 3-34. Raptor Nest Sites, Sage-Grouse Leks, and Prairie Dog Colonies Within and Adjacent to the

West Hilight Field LBA Tract.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-201
Cosner County

Keeline

Road Jacobs

State Highway

BNSF & UP RR

State 59

Highway

Hilight Road Hilight Road

Road

Road

BNSF & UP RR

State Highway 450

Shroyer

Small Road 387

Road

28

34

27

35

26

36

25

31

30

32

29

33

28

34

27

35

26

36

25

31

30

32

29

33

28

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

30

19

18

7

6

29

20

17

8

5

28

21

16

9

4

27

22

15

10

3

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

29

20

17

8

5

28

21

16

9

4

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

28

21

16

9

4

27

22

15

10

3

26

23

14

11

2

25

24

13

12

1

T.

45

N.

T.

44

N.

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

T.

45

N.

T.

44

N.

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

West

Creek

Hay

Coal

Fork

Creek

Little

Prong

North

Little

Thunder

Creek

Thunder

R. 72 W. R. 71 W.

R. 72 W. R. 71 W.

FH

FH

Stuart II

Lek

FH FH

FH

FH

SH/FH

FH

SH/GHO

SH

SH/FH

BO

BO

SH/RTH/FH

FH

FH

GE

FH FH

FH

FH FH

FH

FH

FH

FH

FH

FH

FH

FH

FH

FH

SH

FH FH

FH

FH

Stuart I

Lek

FH

FH

FH

FH

FH

FH

FH

FH

FH

FH FH

GE

GE

SH

GE

GE

FH

FH

FH

GE

GE

FH

FH

FH

FH

BO

SH

SH

FH

Butch

Lek

Jacobs Ranch Mine

Permit Boundary

0 5000 10000 20000

GRAPHIC SCALE (FEET)

West Jacobs Ranch LBA

Tract as Applied for

2-Mile Wildlife Study

Area Boundary

General Analysis Area

LEGEND

BO

GHO

SH

RTH

FH

GE

Burrowing Owl

Great Horned Owl

Swainson's Hawk

Red-tailed Hawk

Ferruginous Hawk

Golden Eagle

Prairie Dog Colony

West Jacobs Ranch LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

Former Raptor Nest

Existing Raptor Nest

Unoccupied (Abandoned) Sage-Grouse Lek

(No Activity for 10 Consecutive Years)

Undetermined Sage-Grouse Lek

(No Documented Activity for Last 10 Years but

Insufficient Information to Designate Unoccupied)

and 3-Mile Radius

Figure 3-35. Raptor Nest Sites, Sage-Grouse Leks, and Prairie Dog Colonies Within and Adjacent to the

West Jacobs Ranch LBA Tract.

3.0 Affected Environment and Environmental Consequences

3-202 Final EIS, Wright Area Coal Lease Applications
Reno Road

Mackey

Antelope

Edwards

Matheson Road Reno Road

School

Creek

State

 59 Highway

Hilight

Road

Road

Road

Road

Road

Mackey Road

Creek

Porcupine

Creek

Horse

Trussler

Creek

School Creek

Creek

Porcupine

1930

31

18

67

17

20

2932

8

5

2128

33

9

16

4

10

15

22

2734

3

26

35

11

14

23

2

12

13

24

25

36

1

30

31

19

18

7

6

1720

29

32

8

5

162128

33

9

4

2734

1522

3

10

35

26

23

14

2

11 12

13242536

1

7

18

193031

6

29

32

5

8

17

20

33

4

9

1621

28

18

6

7

17

5

8

16

4

9

18

6

7

17

5

8

16

4

9

3

10

15 14

2

11 12

13

1

18

6

7

17

5

8

16

4

9

15

3

10

14

2

11

13

12

1

T.

42

N.

T.

41

N.

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

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

T.

42

N.

T.

41

N.

26

35

14

23

11

2

12

13242536

1

11

14

2

13

12

1

Rochelle

Lek

Kort

II Lek

Kort I

Lek

Wilson

Lek

Payne Lek

SH

GE

SH/FH SH

SH/FH

BO

SH/GHO/RTH

GE

FH

FH

FH

SH/RTH/FH

FH

SH/FH

FH FH/SH

SH/FH

FH FH

FH

FH

FH

FH

FH

FH

FH

SH/FH/RTH SH

GE/B/RTH

RTH/GHO

SH/GHO/FH

FH

FH

FH

FH

BO

H

H FH

SH/FH

FH

SH

FH

FH

SH/FH

FH GE/RTH

SH/FH

SH/FH

SH FH

FH

SH

BO

BO

FH

FH

FH

FH

FH

GE/RTH

GE

BO SH

FH

FH

FH

FH

FH FH

SEO

FH

BO

BO

FH FH

SH

BO

FH FH

FH

FH

FH

FH

FH

FH

FH

FH

RTH

RTH

SH FH

GE

FH

SH SH

BO

SH

FH

FH/GHO/RTH

FH

FH

RTH/FH

BO

FH

FH

FH

FH

FH

FH

FH FH FH

FH

FH

B

GE

B

FH

FH

FH

FH

FH FH

R. 72 W. R. 71 W.

R. 72 W. R. 71 W.

North Antelope RochelleMine Permit BoundaryNorth Porcupine LBA

Tract as Applied for

LEGEND

H

BO

GHO

GE

FH

RTH

SH

Golden Eagle

Ferruginous HawkRed-tailed Hawk

Swainson's HawkGreat Horned Owl

Burrowing OwlNorthern Harrier

Prairie Dog Colony

SEO Short-eared Owl

5000 10000 20000 0

GRAPHIC SCALE (FEET)

Existing Raptor NestFormer Raptor NestExisting Platform Nest

B Buteo Species

General Analysis Area

2-Mile Wildlife Study Area Boundary

Occupied Sage-Grouse Lek

(Active at Least Once Within the Last 10 Years)

and 3-Mile Radius

Unoccupied (Abandoned) Sage-Grouse Lek

(No Activity for 10 Consecutive Years)

North Porcupine LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

Unoccupied (Destroyed) Sage-Grouse Lek

(Destroyed and No Longer Suitable for Breeding)

Figure 3-36. Raptor Nest Sites, Sage-Grouse Leks, and Prairie Dog Colonies Within and Adjacent to the

North Porcupine LBA Tract.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-203
Reno Road

Mackey

Antelope

Edwards

Matheson Road

Reno Road Road Road

Antelope

Road

Road

Matheson Road

Creek

Porcupine

Creek

Horse

Trussler

Creek

Creek

Antelope

Creek

Antelope

32

29

20

17

8

33

28

21

16

9

34

27

22

15

10

35

26

23

14

11

36

25

24

13

12

31

30

19

18

7

32

29

20

17

8

33

28

21

16

9

34

27

22

15

10

35

26

23

14

11

36

25

24

13

12

31

30

19

18

7

31

30

19

18

7

6

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

7

6

8

5

9

4

10

3

11

2

12

1

7

6

8

5

9

4

10

3

11

2

12

1

T.

42

N.

T.

41

N.

R. 71 W. R. 70 W.

Converse County

Campbell County

R. 71 W. R. 70 W.

T.

42

N.

T.

41

N.

Payne

Lek

FH

BO

FH

SH

RTH

RTH

FH

FH

FH

FH

FH

FH

FH

FH

FH FH

BO

SH

GE

RTH/GHO

GE

GHO

FH

GE FH

GE SH

FH

RTH

SH

FH

RTH/GE

FH

FH

RTH/GHO

GHO

BO GHO BO

BO

BO

RTH/GHO

RTH

FH

FH

FH

SH

FH

SH BO SH/FH

SH/FH

GE/RTH FH

FH

FH

FH

RTH/GHO

SH/FH

FH

FH

FH

SH/GHO/FH

GE/B/RTH

SH/FH

SH

BO

BO BO

GHO

FH

RTH

SH/RTH

SH

FH

RTH

BO

GHO

RTH

RTH/GHO

RTH/GHO

SH/GHO/RTH

FH

RTH

T.

41

N.

T.

40

N.

T.

41

N.

T.

40

N.

Rochelle

Lek

Kort II

Lek

Kort I

Lek

Wilson

Lek

South Porcupine LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

South Porcupine LBA

Tract as Applied for

LEGEND

0 5000 10000 20000

GRAPHIC SCALE (FEET)

North Antelope Rochelle

Mine Permit Boundary

BO

GHO

SH

RTH

FH

GE

Burrowing Owl

Great Horned Owl

Swainson's Hawk

Red-tailed Hawk

Ferruginous Hawk

Golden Eagle

Prairie Dog Colony

Existing Platform Nest

Former Raptor Nest

Existing Raptor Nest

B Buteo Species

2-Mile Wildlife Study Area Boundary

General Analysis Area

Occupied Sage-Grouse Lek

(Active at Least Once Within the Last 10 Years)

and 3-Mile Radius

Unoccupied (Abandoned) Sage-Grouse Lek

(No Activity for 10 Consecutive Years)

Unoccupied (Destroyed) Sage-Grouse Lek

(Destroyed and No Longer Suitable for Breeding)

Figure 3-37. Raptor Nest Sites, Sage-Grouse Leks, and Prairie Dog Colonies Within and Adjacent to the

South Porcupine LBA Tract.

3.0 Affected Environment and Environmental Consequences

3-204 Final EIS, Wright Area Coal Lease Applications
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-205 

these figures and in the individual tract discussions that follow below. A total 

of 33 occupied prairie dog colonies encompassing approximately 1,490.2 noncontiguous acres were present on and within 2 miles of the general analysis 

areas for these six LBA tracts in 2007. A total of six prairie dog colonies 

encompassing approximately 148.6 acres are located entirely within the six 

combined general analysis areas. 

The black-tailed prairie dog is recognized as a USFS and BLM Sensitive Species 

and is further discussed in the Sensitive Species Evaluation (Appendix H) of 

this EIS. 

3.10.3.1.1 North, South, and West Hilight Field LBA Tracts

Four prairie dog colonies (approximately 53.8 total acres) were found within 2 

miles of the general analysis area for the North Hilight Field tract (Figure 3-32). 

Two colonies of which are within the general analysis area for the tract (the 

area likely to be affected under Alternative 2, BLM’s preferred alternative) and 

are approximately 3.4 to 19.5 acres in size. The two other colonies are 

approximately 3.7 and 27.2 acres in size. 

Seven prairie dog colonies (approximately 177.2 total acres) were found within 

2 miles of the general analysis area for the South Hilight Field tract (Figure 3-

33). Only one colony (approximately 0.1 acre in size) is within the general 

analysis area for the tract (the area likely to be affected under Alternative 2, 

BLM’s preferred alternative). The other six colonies are approximately 2.0, 2.6, 

7.7, 21.8, 53.9, and 89.1 acres in size. 

Eight prairie dog colonies (approximately 159.0 total acres) were found within 2 

miles of the general analysis area for the West Hilight Field tract (Figure 3-34). 

One colony (approximately 89.1 acres in size) is within the general analysis 

area for the tract (the area likely to be affected under Alternative 2, BLM’s 

preferred alternative). The other seven colonies are approximately 0.1, 2.6, 3.4, 

7.7, 17.9, 19.5, and 27.2 acres in size. 

3.10.3.1.2 West Jacobs Ranch LBA Tract

Six prairie dog colonies (approximately 78.3 total acres) were found within 2 

miles of the general analysis area for the West Jacobs Ranch tract (Figure 3-

35). Only one colony (approximately 17.9 acre in size) of which is within the 

general analysis area for the tract (the area likely to be affected under 

Alternative 2, BLM’s preferred alternative). The other five colonies are 

approximately 2.6, 3.4, 7.7, 19.5, and 27.2 acres in size. 

3.10.3.1.3 North and South Porcupine LBA Tracts

Seventeen prairie dog colonies (approximately 1,317.0 total acres) were found 

within or overlapped the 2-mile perimeter around the general analysis area for 

the North Porcupine tract (Figure 3-36). Only one colony (approximately 18.6 
3.0 Affected Environment and Environmental Consequences 

3-206 Final EIS, Wright Area Coal Lease Applications 

acres in size) of which is within the general analysis area for the tract (the area 

likely to be affected under Alternative 2, BLM’s preferred alternative). The 

other 16 colonies range in size from approximately 1 to 345 acres; the largest of 

which occurs within both the North and South Porcupine wildlife survey areas. 

Ten prairie dog colonies (approximately 476.3 total acres) were found within or 

overlapped the 2-mile perimeter around the general analysis area for the South 

Porcupine tract (Figure 3-37). No colonies are within the general analysis area 

for the tract (the area likely to be affected under Alternative 2, BLM’s preferred 

alternative). The largest colony was approximately 345 acres; this colony is 

within both the North and South Porcupine wildlife survey areas. The 

remaining nine colonies were all less than 40 acres, with an average size of 

about 15 acres. 

3.10.3.2 Environmental Consequences

3.10.3.2.1 Proposed Action and Alternatives 2 and 3

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 will retreat into 

burrows when disturbed. Therefore, populations of such prey animals 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. Research projects 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. Black–tailed prairie dogs have recolonized reclaimed lands on the 

Jacobs Ranch Mine and are expanding their colonies east of that mine’s 

current permit area (IR 2007). 

Six prairie dog colonies encompassing approximately 148.6 non-contiguous 

acres in the combined general analysis areas for the North Hilight Field tract 

(two colonies totaling about 22.9 acres), South Hilight Field tract (one colony of 

roughly 0.1 acre), West Hilight Field tract (one colony of approximately 89.1 

acres), West Jacobs Ranch tract (one colony of about 17.9 acres), and North 

Porcupine tract (one colony of roughly 18.6 acres) would be affected by leasing 

and mining these six LBA tracts, each under Alternative 2, BLM’s preferred 

tract configuration. This represents approximately 10 percent of the total 

colony acreage (approximately 1,490.2 acres) that currently exists within the 

combined prairie dog survey areas. The other 90 percent (27 additional 

colonies) within the combined prairie dog survey areas may be affected by 

adjacent mining activities unrelated to the LBA tracts. Refer to the Biological 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-207 

Assessments (Appendix G) for each tract for further discussion of impacts to 

prairie dog colonies in the general analysis areas. 

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. 

3.10.4 Raptors

3.10.4.1 Affected Environment

The raptor species known or expected to occur in suitable habitats in the 

general Wright analysis area include the golden eagle (Aquila chrysaetos), 

ferruginous hawk, red-tailed hawk (Buteo jamaicensis), Swainson's hawk (Buteo 

swainsoni), rough-legged hawk (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). Some of these species are USFS and/or BLM Sensitive Species (see 

Appendix H). 

The bald eagle (Haliaeetus leucocephalus) is a migrant and common winter 

resident of the Wyoming PRB region. On July 9, 2007, the USFWS published a 

Federal Register notice (72 FR 37346) announcing that the bald eagle would be 

removed from the list of threatened and endangered (T&E) species under the 

Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.); delisting was effective as of 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 USFS Sensitive Species 

and BLM Sensitive Species and is further discussed in Appendix H of this EIS. 

Those species that commonly nest in the general Wright analysis area are the 

golden eagle, ferruginous hawk, red-tailed hawk, Swainson’s hawk, burrowing 

owl, and great horned owl. American kestrels, northern harriers, and shorteared owls intermittently nest in the area, as occasional sightings of recently 

fledged young indicate that such activities do occur within the general Wright 

analysis area for one or more of those species. Habitat is limited for those 

species that nest exclusively in trees or on cliffs, but several species have 

adapted to nesting on the ground, creek banks, buttes, mine highwalls, or rock 

outcrops. Rough-legged hawks are winter residents in northeast Wyoming, and 

breed in the arctic regions. 

The raptor monitoring areas for the Black Thunder, Jacobs Ranch, and North 

Antelope Rochelle mines include their respective permit areas and a 

surrounding 1- or 2-mile perimeter. Due to the proximity of the LBA tracts to 

those adjacent applicant mines, all or portions of the general analysis area and 

respective 2-mile perimeter for each of these six LBA tracts have been included 
3.0 Affected Environment and Environmental Consequences 

3-208 Final EIS, Wright Area Coal Lease Applications 

in the mines’ annual raptor monitoring surveys since the early 1980s. Specific 

details regarding those surveys are available in the mines’ annual wildlife 

monitoring reports, which are on file with the WDEQ/LQD. 

Figures 3-32 through 3-37 show the locations of raptor nests identified within 

the 2-mile perimeter that encompasses the general analysis area for each of the 

six Wright area coal (WAC) LBA tracts (North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

LBA Tract, respectively), in 2007 and 2008. There are overlaps between the six 

raptor survey area boundaries, and as such, there are overlaps in the depiction 

of raptor nests on these figures and in the individual tract discussions that 

follow below. Over time, raptors have built new nests, natural forces have 

destroyed many nests, and others have been relocated for mitigation or 

removed by mining activities. In some cases, nests have been created to 

mitigate other nest sites impacted by mining operations. A total of 143 intact 

raptor nests were documented on and within 2 miles of the general analysis 

areas for these six LBA tracts in 2007 and 2008. A total of 44 of these 143 

nests are located within the six general analysis areas (the areas likely to be 

affected under Alternative 2, BLM’s preferred alternative for each tract). 

3.10.4.1.1 North, South, and West Hilight Field LBA Tracts

During surveys completed in 2007 by Thunderbird-Jones & Stokes (J&S 2008), 

a total of 34 intact raptor nests (one golden eagle nest, 23 ferruginous hawk 

nests, four Swainson’s hawk nests, two burrowing owl nest sites, one platform 

nest erected for ferruginous hawks, and three nests that have been used by 

multiple raptor species) were present within 2 miles of the general analysis 

area for the North Hilight Field LBA Tract (Figure 3-32). Eight intact nests 

were within the general analysis area for the tract (the area likely to be affected 

under Alternative 2, BLM’s preferred alternative): four intact nests (two 

burrowing owl and two ferruginous hawk) were present within the tract as 

applied for, one intact nest (used by multiple species) was present on the 

additional lands evaluated by BLM under Alternative 2, and three more intact 

nests (all ferruginous hawk) were present on the 1⁄4-mile disturbance buffer. 

Only one of the eight intact nests within the general analysis area for the North 

Hilight Field tract was active (eggs laid) during 2007. The remaining 26 intact 

nests were within 2 miles of the tract’s general analysis area. 

Surveys completed in 2007 by J&S identified a total of 18 intact raptor nests 

(12 ferruginous hawk nests, two platform nests erected for 

ferruginous/Swainson’s hawks, and one platform nest erected for golden 

eagles, and three nests that have been used by multiple raptor species) within 

2 miles of the general analysis area for the South Hilight Field LBA Tract 

(Figure 3-33). Two intact nests were within the general analysis area for the 

tract (the area likely to be affected under Alternative 2, BLM’s preferred 

alternative): no intact nests were present within the tract as applied for, and 

two intact ferruginous hawk nests were present on the additional lands 

evaluated by BLM under Alternative 2. Both of those nests were in the same 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-209 

territory. No intact nests within the general analysis area for the South Hilight 

Field tract were active during 2007. The remaining 16 intact nests were within 

2 miles of the tract’s general analysis area. 

During surveys completed in 2007 by J&S, a total of 42 intact raptor nests (26 

ferruginous hawk nests, three Swainson’s hawk nests, three burrowing owl 

nest sites, two platform nests erected for ferruginous/red-tailed hawks, one 

platform nest erected for golden eagles, and four nests that have been used by 

multiple raptor species) were present within 2 miles of the general analysis 

area for the West Hilight Field LBA Tract (Figure 3-34). Eight intact nests were 

within the general analysis area for the tract (the area likely to be affected 

under Alternative 2, BLM’s preferred alternative): no intact nests were present 

within the tract as applied for, two intact nests (ferruginous hawk) were 

present on the additional lands evaluated by BLM under Alternative 2, and six 

more intact nests (four ferruginous hawk, one burrowing owl, and one golden 

eagle) were present within the 1⁄4-mile disturbance buffer. Three of the eight 

intact nests within the general analysis area for the West Hilight Field tract 

were active (eggs laid) during 2007. The remaining 34 intact nests were within 

2 miles of the tract’s general analysis area. 

3.10.4.1.2 West Jacobs Ranch LBA Tract

During raptor nest surveys completed in 2007 and 2008 by Intermountain 

Resources (IR 2008), a total of 44 intact raptor nests (33 ferruginous hawks 

nests, three Swainson’s hawk nests, three burrowing owl nest sites, two golden 

eagle nests, and three nests that have been used by multiple raptor species) 

were present within 2 miles of the general analysis area for the West Jacobs 

Ranch LBA Tract (Figure 3-35). Nine intact nests were within the general 

analysis area for the tract (the area likely to be affected under Alternative 2, 

BLM’s preferred alternative): one intact nest (Swainson’s hawk) was present 

within the tract as applied for, two intact nests (one golden eagle and one 

Swainson’s hawk) were present on the additional lands evaluated by BLM 

under Alternative 2, and six more intact nests (five ferruginous hawk and one 

golden eagle) were present within the 1⁄4-mile disturbance buffer. Three of the 

nine intact nests (one golden eagle, one Swainson’s hawk, and one ferruginous 

hawk) within the general analysis area for the West Jacobs Ranch tract were 

active during 2007 and 2008. The remaining 35 intact nests were within 2 

miles of the tract’s general analysis area. 

3.10.4.1.3 North and South Porcupine LBA Tracts

During raptor nest surveys completed in 2007 by Thunderbird-Jones & Stokes 

(J&S 2009), a total of 56 intact raptor nests (31 ferruginous hawk nests, five 

burrowing owl nest sites, five Swainson’s hawk nests, two golden eagle nests, 

one red-tailed hawk nest, 12 nests that have been used by multiple raptor 

species, which includes four platform nests erected for ferruginous hawks, one 

platform nest erected for golden eagles, and one platform nest erected for 

ferruginous/Swainson’s hawks) were present within 2 miles of the general 
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3-210 Final EIS, Wright Area Coal Lease Applications 

analysis area for the North Porcupine LBA Tract (Figure 3-36). Eleven intact 

nests were within the general analysis area for the tract (the area likely to be 

affected under Alternative 2, BLM’s preferred alternative): seven intact nests 

(one burrowing owl, three ferruginous hawk, two golden eagle, and one redtailed hawk) were present within the tract as applied for, three intact 

ferruginous nests were present on the additional lands evaluated by BLM 

under Alternative 2, and one additional intact ferruginous hawk nest was 

present on the 1⁄4-mile disturbance buffer. Nineteen of the 56 intact nests were 

active (eggs laid) during 2007, and five of the 11 nests within the general 

analysis area were active that year. 

Surveys completed in 2007 by J&S identified a total of 32 intact raptor nests 

(12 ferruginous hawk nests, four Swainson’s hawk nests, two red-tailed hawk 

nests, four burrowing owl nest sites, two great horned owl nests, and eight 

nests that have been used by multiple raptor species, including one platform 

nest erected for ferruginous/Swainson’s hawks, one platform nest erected for 

ferruginous hawks, and one platform nest erected for Swainson’s hawks) 

present within 2 miles of the general analysis area for the South Porcupine LBA 

Tract (Figure 3-37). Six intact nests were within the general analysis area for 

the tract (the area likely to be affected under Alternative 2, BLM’s preferred 

alternative), all six of which (three ferruginous hawk, one Swainson’s hawk, 

and two multiple species nests) were present within the LBA tract as applied 

for. No additional intact nests were present on the additional lands evaluated 

by BLM under Alternative 2 or the 1⁄4-mile disturbance buffer. Thirteen of the 

32 intact nests were active during 2007, three of which were within the general 

analysis area. 

3.10.4.2 Environmental Consequences

3.10.4.2.1 Proposed Action and Alternatives 2 and 3

Mining the LBA tracts 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 1-mile buffer around all active ferruginous hawk nests. Active 

nests (incubating/brooding adults, eggs, or young present) of most other raptor 

species are typically buffered by a 1⁄2-mile radius. Monitoring data collected 

since the early 1980s within the general Wright analysis area indicate that 

several of the raptor pairs that breed within this area have alternate nesting 

sites elsewhere within their territories that are beyond the boundaries of the 2-

mile perimeter that encompasses the general analysis areas for the West 

Hilight Field, South Hilight Field, West Jacobs Ranch, North Porcupine, and 

South Porcupine LBA Tracts. 

USFWS, WGFD, WDEQ/LQD, and/or USFS approval would be required before 

mining could occur within standard buffer zones for active raptor nests. The 

Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines annually 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-211 

monitor territorial occupancy and nest productivity on and around their 

existing leases. Several raptor pairs representing multiple species have 

successfully nested in close proximity to mining operations at surface coal 

mines in the PRB, including golden eagles (approximately 600 feet), Swainson’s 

hawks (approximately 400 feet), red-tailed hawks (approximately 200 feet), and 

great horned owls (on active coal processing facilities, such as crushers and 

silos). Those same raptor species have been documented within the general 

Wright analysis area. Those nesting efforts have succeeded due to a 

combination of raptors becoming acclimated to the gradual encroachment of 

mine operations and 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 Black Thunder, Jacobs Ranch, and North Antelope Rochelle 

mines’ Annual Wildlife Reports, as well as those for other regional PRB coal 

mines, on file with the WDEQ/LQD. 

Mining within or near raptor territories would impact availability of foraging 

habitat for nesting birds. However, increased acreage of reclamation within the 

permit areas would offset new habitat loss as mining progresses. Equipment 

enclosures associated with mining provide additional habitat for prey species 

such as cottontail rabbits, and several raptor pairs have voluntarily nested 

near those areas. As at other surface mines throughout the region, raptor 

nesting efforts at the Black Thunder, Jacobs Ranch, and North Antelope 

Rochelle mines 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. 

A total of 44 intact raptor nests were present in 2007 and 2008 within the 

general analysis areas for these six LBA tracts and could be impacted if the 

tracts were leased and mined under Alternative 2, BLM’s preferred alternative. 

3.10.4.2.1.1 North, South, and West Hilight Field LBA Tracts

Eighteen intact raptor nests that were present within the combined general 

analysis areas for the North Hilight Field (8 nests), South Hilight Field (2 nests), 

and West Hilight Field (8 nests) LBA Tracts in 2007 would be affected by 

leasing and mining these three tracts, each under Alternative 2, BLM’s 

preferred tract configuration. Thirteen of these 18 intact raptor nests were 

ferruginous hawk nests representing seven territories within the combined 

general analysis areas for the North Hilight Field (five nests), South Hilight 

Field (two nests), and West Hilight Field (six nests) LBA Tracts. However, 

ferruginous hawks have actively nested (laid eggs) at only two of those 13 nests 

in recent years. 
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3-212 Final EIS, Wright Area Coal Lease Applications 

3.10.4.2.1.2 West Jacobs Ranch LBA Tract

Nine intact raptor nests were present within the general analysis area for the 

West Jacobs Ranch LBA Tract in 2007 and 2008. Five of these nine intact 

raptor nests were ferruginous hawk nests. Ferruginous hawks actively nested 

(laid eggs) at only one of those five sites in recent years. Only two raptor 

species (Swainson’s hawk and golden eagle) have been recorded nesting on the 

BLM study area for the West Jacobs Ranch LBA Tract (the tract as applied for 

and the additional area evaluated by BLM under Alternative 2, BLM’s preferred 

alternative). 

3.10.4.2.1.3 North and South Porcupine LBA Tracts

Seventeen intact raptor nests that were present within the combined general 

analysis areas for the North Porcupine (11 nests) and South Porcupine (six 

nests) LBA Tracts in 2007 would be affected by leasing and mining these two 

tracts, each under Alternative 2, BLM’s preferred tract configuration. Ten of 

these 17 intact raptor nests were ferruginous hawk nests representing 3 

territories within the combined general analysis areas for the North Porcupine 

(7 nests) and South Porcupine (3 nests) LBA Tracts. 

All intact nests within the general analysis areas for both North and South 

Porcupine tracts are encompassed by the current permit area for the North 

Antelope Rochelle Mine (Figures 3-36 and 3-37) and could therefore be 

impacted by mine-related operations regardless of whether the LBA tracts are 

leased. Although individual birds or pairs could be impacted by those 

activities, the continued use of effective mitigation measures will minimize 

impacts to overall regional raptor populations. Mining activity could cause 

raptors to abandon nests proximate to disturbance, particularly if mining 

encroaches on active nests during a given breeding season. Monitoring data 

collected over the last 20 plus years, has indicated that some of the raptor 

pairs that breed within these two general analysis areas have alternate nesting 

sites elsewhere within their territories, but beyond the two-mile wildlife survey 

area. 

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. 

3.10.5 Upland Game Birds

3.10.5.1 Affected Environment

Four upland game bird species have historically been documented within the 

general Wright analysis area. These species are the mourning dove (Zenaida 

macroura), gray partridge (Perdix perdix), wild turkey (Meleagris gallopavo), and 

greater sage-grouse (Centrocercus urophasianus). The mourning dove, however, 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-213 

is the most prevalent upland game bird in this area, and the only species 

known to occur with any regularity. Based on annual lek searches since the 

late 1970’s, sharp-tailed grouse do not appear to inhabit the surface coal mine 

region of the southern PRB. The nearest sharp-tailed grouse lek is located over 

40 miles northwest of the general Wright analysis area. 

Mourning doves are a migrant and are relatively common in the area during 

spring and fall with fewer observations during the nesting season. This species 

is a relatively common breeding bird in Campbell County and may be found in 

a variety of habitat types. Doves are most often seen near sites with water 

sources and trees, though they are occasionally observed in sagebrush and 

greasewood stands. Mourning doves were observed within the general Wright 

analysis area in 2007 and 2008. 

The gray partridge (a.k.a. Hungarian partridge or Hun) is an introduced, nonmigratory game bird species that form flocks (or coveys) outside the breeding 

season. Gray partridge have been infrequently observed on reclaimed areas, 

sagebrush shrublands, upland grassland, and cultivated lands in the general 

Wright analysis area. In some years, this species is occasionally encountered, 

while in other years, partridge appear to be totally absent. Gray partridge were 

not observed in the general Wright analysis area in 2007 or 2008. 

Wild turkeys have been seen infrequently over time in the general Wright 

analysis area, with spans of several years between observations. All historical 

observations have occurred during spring, when males were gobbling. This 

species is most often observed along Antelope Creek, generally south of the 

North and South Porcupine LBA Tracts. Wild turkeys were not observed in the 

general Wright analysis area in 2007 or 2008. 

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, and exhibit seasonal 

movements to utilize discrete sagebrush habitats. 

Sage-grouse breeding occurs on strutting grounds (leks) during late March and 

April. Leks are generally established in open areas surrounded by Wyoming 

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, 

approximately two-thirds of sage-grouse hens nest within 3 miles of the lek 

where they were bred. New spring plant growth, residual cover, and 

understory are important habitat components for nesting sage-grouse hens. 

Areas near nests are used for several weeks by hens for brood rearing. The 

habitats used during the first few weeks after hatching must provide good 
3.0 Affected Environment and Environmental Consequences 

3-214 Final EIS, Wright Area Coal Lease Applications 

cover to conceal the chicks and must provide essential nutritional 

requirements during this period of rapid development. Brood-rearing habitats 

that have a healthy and wide diversity of plant species, particularly grasses and 

forbs, tend to provide a variety and abundance of insects that are an essential 

protein supply for the young. 

Summer habitat consists of sagebrush mixed with areas of wet meadows, 

riparian, or irrigated agricultural fields. As summer progresses and forbs 

mature and dry up, sage-grouse broods must move to more mesic, wet 

meadow-type habitats where succulent plants and insects are still available. 

This can be especially important in drier years and during long drought 

periods. As the fall season 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 the sagegrouse be listed under the Endangered Species Act (ESA) as threatened or 

endangered. Three of the petitions requested that sage-grouse be listed as 

endangered across its entire range. On January 12, 2005, following a 12-

month status review on the species, the USFWS concluded that listing was not 

warranted at that time. On December 4, 2007, U.S. District Court, District of 

Idaho, ruled that the USFWS 12-month petition finding on sage-grouse was in 

error and remanded the case back to the Service for further reconsideration. 

On February 26, 2008, the USFWS announced the initiation of another status 

review for the sage-grouse. The USFWS announced on March 5, 2010 its 

decision to classify the sage-grouse as a candidate species under the ESA. The 

USFWS found that listing the sage-grouse (rangewide) was warranted, but 

precluded by higher priority listing actions. 

Candidate species are plants and animals for which the Service has sufficient 

information on their biological status and threats to propose them for listing as 

endangered or threatened under the ESA, but for which development of a 

proposed listing regulation is precluded by higher priority listing actions to 

address species in greater need. Candidate species receive no statutory 

protection under the ESA, but the USFWS encourages voluntary cooperative 

conservation efforts for these species because they are, by definition, species 

that warrant future protection under the ESA (USFWS 2010). 

USFWS has indicated the need for continued efforts to conserve sage-grouse 

and sagebrush habitat on a long-term basis, and has encouraged continued 

development and implementation of conservation strategies throughout the 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-215 

species’ range. The sage-grouse is also a BLM Sensitive Species and a USFS 

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 WGFD’s September 11, 2003 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. Recent lek 

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 due to cooler temperatures that 

reduced mosquito populations. Sage-grouse hunting seasons were 

consequently reopened in 2004 (Christiansen 2004). 

In 2007, Wyoming Governor Dave Freudenthal commissioned a Statewide 

Sage-grouse Implementation Team, which emerged from the Governor’s 2007 

Sage-Grouse Summit. On March 17, 2008, the Implementation Team 

preliminarily identified and mapped recommended sage-grouse core breeding 

areas in Wyoming in an effort to better understand what types of habitat the 

grouse prefer and what areas should be protected. On August 1, 2008, 

Governor Freudenthal released an executive order regarding sage-grouse core 

area protection (Office of the Governor of Wyoming 2008). The sage-grouse 

focus area protection concept came about as a result of work by the Sagegrouse Implementation Team. The Implementation Team developed a Core 

Population Strategy for the State of Wyoming “to maintain habitats and viable 

populations of sage-grouse in areas where they are most abundant” and 

delineated approximately 40 areas around the state with a focus of 

maintenance and enhancement of grouse habitats and populations within the 

focus areas. The areas were delineated by evaluating habitats within a 4-mile 

radius of selected sage-grouse leks in high lek-density areas. The general 

Wright analysis area is not located within the mapped core breeding areas. 

The BLM Wyoming State Office is in the process of developing a state-wide 

sage-grouse management policy and has incorporated sage-grouse focus areas 

based on the core area concept in the draft management policy. BLM has 

indicated that the sage-grouse management strategy for management of future 

surface disturbance (including actions proposed in this EIS) will likely be based 

on the sage-grouse focus areas (BLM 2008c). 

WGFD has adopted definitions for the purposes of collecting and reporting 

sage-grouse data (WGFD 2007b). The definitions contain an assessment of the 

annual status and a management status of sage-grouse leks. The annual 

status is assessed annually based on the following definitions: 
3.0 Affected Environment and Environmental Consequences 

3-216 Final EIS, Wright Area Coal Lease Applications 

• Active – Any lek that has been attended by male sage-grouse during the 

strutting season. 

• Inactive – Any lek where sufficient data suggests that there was no 

strutting activity throughout a strutting season. 

• Unknown – Leks for which status as active or inactive has not been 

documented during the course of a strutting season. 

The management status is based on a lek’s annual status; a lek is assigned to 

one of the following categories for management purposes: 

• Occupied – A lek that has been active during at least one strutting 

season within the prior 10 years. Occupied leks are protected through 

prescribed management actions during surface disturbing activities. 

• Unoccupied (formerly “historical lek”) – There are two types of 

unoccupied leks, “destroyed” and “abandoned.” Unoccupied leks are not 

protected during surface disturbing activities. 

− destroyed – A formerly active lek site and surrounding sagebrush 

habitat that has been destroyed and is no longer suitable for sagegrouse breeding. 

− abandoned – A lek in otherwise suitable habitat that has not been 

active during a period of 10 consecutive years. To be designated 

abandoned, a lek must be “inactive” (see above criteria) in at least four 

non-consecutive strutting seasons spanning the 10 years. The Forest 

Service defines “abandoned” as leks that have been documented as 

inactive for five consecutive years. 

• Undetermined – Any lek that has not been documented active in the last 

10 years, but survey information is insufficient to designate the lek as 

unoccupied. Undetermined leks will be protected through prescribed 

management actions during surface disturbing activities until sufficient 

documentation is obtained to confirm the lek is unoccupied. 

The Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines have 

conducted surveys of known sage-grouse leks and searches for new leks as 

part of their wildlife baseline inventories and wildlife monitoring programs 

since the early 1980s. Baseline inventories, which have occurred prior to 

initial permitting and subsequent permit amendments, encompassed the 

respective mine’s permit area and a 2-mile perimeter. The mines continued 

annual surveys that included the respective mine permit area and a 1-mile 

perimeter and began when each mine was initially permitted. Those surveys 

became mandatory with the implementation of Appendix B of the WDEQ/LQD 

Coal Rules and Regulations in 1993. Each occupied and undetermined lek is 

generally surveyed three times within a given breeding season. As a result, 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-217 

most of the general analysis areas for the North Hilight Field, South Hilight 

Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South 

Porcupine LBA Tracts have been included in previous regular survey efforts. 

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 

sage-grouse is included on the updated list, giving further impetus to ongoing 

annual survey efforts. 

Figures 3-32 through 3-37 depict the locations of sage-grouse leks identified 

within the 2-mile perimeter that encompasses the general analysis area for the 

North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, 

North Porcupine, and South Porcupine LBA Tract, respectively, in 2007 and 

2008. There are overlaps between the six sage-grouse survey area boundaries, 

and as such, there are overlaps in the depiction of sage-grouse leks on these 

figures and in the tract discussions that follow below. A total of 10 sage-grouse 

leks have been documented on and within 2 miles of the general analysis areas 

for these six LBA tracts. Two leks, Kort I and Kort II, likely represent a shift in 

lekking activity rather than two distinct leks (Figures 3-36 and 3-37). Four of 

the leks have been active during recent survey years and are classified as 

occupied; two leks have not been attended by displaying grouse for at least the 

last 10 years and are classified as unoccupied/abandoned; two leks have been 

removed by mining activities and are classified as unoccupied/destroyed; there 

has been no documented activity for the last 10 years at two leks, but survey 

information is insufficient to designate them as unoccupied, so they are 

classified as undetermined. 

Sage-grouse populations are generally considered to be cyclic, with periodic 

intervals between peaks in region-wide male lek attendance. However, sagegrouse populations and their distribution in Wyoming have declined over the 

last five decades (WGFD long-term data, provided by L. Jahnke, 2008) despite 

higher counts in some years. 

No sage-grouse broods were recorded within the BLM study area for each LBA 

tract (the tract as applied for and the additional area evaluated by BLM under 

Alternative 2) during specific surveys or incidental to other wildlife surveys 

conducted in those areas annually since at least 1993. 

Although nesting and winter surveys for sage-grouse are not required as part of 

the annual wildlife monitoring programs for the three applicant mines, winter 

surveys have been conducted as part of the required baseline inventories for 

previously planned mine expansions. Additionally, winter surveys for other 

species (e.g., big game, bald eagle roosts, and other wintering raptors) have 

been conducted at the three mines in recent years. Due to their proximity to 

existing mine permit areas, the general analysis areas for these six LBA tracts 

have been included in a minimum of seven consecutive years of big game 

winter surveys (from 1993 through 1999) and no sage-grouse were ever 
3.0 Affected Environment and Environmental Consequences 

3-218 Final EIS, Wright Area Coal Lease Applications 

documented in or near the LBA tracts during those surveys. Radio-telemetry 

data gathered from grouse collared at the North Antelope Rochelle Mine during 

a voluntary, multi-year (2001 through 2007) study have, however, 

demonstrated that most birds in the North Porcupine wildlife survey area 

reside near the mine year-round. Few grouse were recorded within 2 miles of 

the South Porcupine LBA Tract during that telemetry monitoring. 

3.10.5.1.1 Sage-Grouse Use Associated With the North, South, and West 

Hilight Field LBA Tracts

The sage-grouse is a year-round resident throughout much of the PRB, but has 

declined dramatically on and within 2 miles of the general analysis areas for 

the North, South, and West Hilight Field LBA Tracts over the last 30 years. 

The lack of sage-grouse use in that region has been well documented in the 

adjacent mines’ Wildlife Annual Monitoring reports to the WDEQ/LQD from the 

late 1970s through 2008. Sage-grouse were last confirmed in these study 

areas in 2003 (Hansen Lakes lek located within the BLM study area for the 

North Hilight Field tract), though some leks in these areas were not checked 

annually by the WGFD prior to the 2007 and 2008 surveys associated with this 

EIS. 

Five sage-grouse leks are located on and within 2 miles of the North, South, 

and West Hilight Field general analysis areas: Stuart I, Stuart II, Black 

Thunder, Butch, and Hansen Lakes Leks (Figures 3-32 through 3-34). Three of 

the five leks (Butch, Hansen Lakes, and Stuart II) fall within one of the three 

general analysis areas, with the remaining two (Black Thunder and Stuart I) 

located in the 2-mile wildlife survey perimeter (Figures 3-32 through 3-34). 

The Black Thunder lek was eclipsed by mining activities in 2007 after 12 

consecutive years of inactivity. The remaining four leks have experienced 

lengthy periods of little or not activity over at least the last 16 years (1992-

2007). As described above, no lek activity has been documented in these three 

wildlife survey areas since 2003, though the Butch and Hansen Lakes leks 

were not checked every year. 

The wildlife study areas for the North, South, and West Hilight Field LBA Tracts 

are not within a sage-grouse focus area. 

Two sage-grouse leks have been documented within the general analysis area 

for the North Hilight Field LBA Tract: Hansen Lakes and Butch (Figure 3-32). 

The Butch lek was discovered in 1990, and was active every year through 

1993. That was the same year that the Hansen Lakes lek was discovered; it 

was active each year from 1993 through 2003 and is therefore considered 

active. The Hansen Lakes lek is located approximately 1.5 miles east of Butch 

lek, and could potentially represent a shift in the lek’s location. The Butch lek 

was checked annually from 1994 through 2001, with no records of grouse 

during that period. The lek was not checked again until 2007; it was also 

inactive that year and is therefore now classified unoccupied/abandoned. The 

Hansen Lakes lek was checked in 3 of the last 4 four years and no grouse were 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-219 

present. No other leks have been documented within the wildlife study area for 

the North Hilight Field LBA Tract. 

One sage-grouse lek has been documented approximately 1 mile east of the 

general analysis area for the South Hilight Field LBA Tract: Black Thunder 

(Figure 3-33). In 2005, the Black Thunder lek was classified as historical after 

12 consecutive years of inactivity. Surveys were no longer required at that lek 

after that year, and it was eclipsed by mining in 2007. The Black Thunder lek 

is now classified unoccupied/destroyed. No other leks have been documented 

within the wildlife study area for the South Hilight Field LBA Tract. 

Two sage-grouse leks have been documented on and within 2 miles of the West 

Hilight Field general analysis area: Stuart I and Stuart II (Figure 3-34). The 

Stuart II lek is located within the LBA tract as applied for, and the Stuart I lek 

is located approximately 1.3 miles west of the general analysis area for the 

West Hilight Field LBA Tract. The Stuart II lek was monitored by the WGFD 

and/or USFS at approximately three-year increments from 1979 through 2004. 

The highest number of grouse ever recorded during that period was seven in 

1991. That was also the last year when grouse were confirmed at the lek. The 

Stuart II lek has been monitored by private consultants in each of the last four 

years (2005 through 2008) and no grouse were observed. The Stuart I lek was 

discovered in 1977. The lek was monitored in three of the following four years, 

and was active in each survey year. Monitoring efforts were reduced to every 

third year (WGFD standard timing) from 1982 through 2003; annual 

monitoring began in 2004. Grouse were observed in only one of the monitoring 

years from 1982 through 2007. Two males were recorded at the Stuart I lek in 

1991 and that was the last year when grouse or sign were confirmed at the lek. 

No sage-grouse have been recorded at the Stuart I and II leks for over 10 years; 

however, not enough consistent data have been collected to classify either as 

abandoned. Both Stuart I and Stuart II leks are now classified undetermined 

(insufficient information to designate the leks as unoccupied). No other leks 

have been documented within the wildlife study area for the West Hilight Field 

LBA Tract. 

3.10.5.1.2 Sage-Grouse Use Associated With the West Jacobs Ranch LBA 

Tract

Two sage-grouse leks have been documented within 2 miles of the West Jacobs 

Ranch general analysis area: Stuart I and Stuart II (Figure 3-35). The Stuart II 

lek is located approximately 1 mile south of the LBA tract as applied for, and 

the Stuart I lek is located approximately 1.3 miles southwest of the general 

analysis area for the West Jacobs Ranch LBA Tract. 

While displaying males have not been recorded at either of these two leks for 

over 10 years (not since 1991 at both sites), there is insufficient data to 

indicate that they are abandoned; therefore, both leks are presently classified 

undetermined. The Stuart I lek would probably not be re-occupied in the near 
3.0 Affected Environment and Environmental Consequences 

3-220 Final EIS, Wright Area Coal Lease Applications 

future due to the presence of a CBNG compression station and other CBNG 

development facilities within 1⁄4 mile of the lek site. The Stuart II lek would 

probably not be re-occupied in the near future due to the presence of CBNG 

access roads and other CBNG facilities within 1⁄4 mile of the lek site (IR 2008). 

No other leks have been documented within the wildlife study area for the West 

Jacobs Ranch LBA Tract, and this area is not within a sage-grouse focus area. 

3.10.5.1.3 Sage-Grouse Use Associated With the North and South Porcupine 

LBA Tracts

Five sage-grouse leks have been documented within 2 miles of the North 

Porcupine general analysis area: Payne, Wilson, Kort I, Kort II, and Rochelle 

(Figure 3-36). Payne lek is located on the LBA tract as applied for and is close 

to the tract’s eastern edge. The Wilson, Kort I, and Kort II lek sites are within 2 

miles of the LBA tract’s general analysis area and are all southeast of the 

tract’s southeastern corner. The Rochelle lek site is also located southeast of 

the tract’s general analysis area, although it is just outside of the 2-mile 

wildlife study area boundary. 

The Rochelle lek was discovered in 1990 but experienced reduced attendance 

after 1992, with birds present in only 3 of the subsequent 11 years. The site 

may have been a satellite to the Wilson lek; used only when the local grouse 

population was relatively high or increasing. The Rochelle lek was mined 

through in 2004, and is now classified as unoccupied/destroyed. The Kort I 

lek was first identified in spring 1998 when, for unknown reasons, grouse 

apparently shifted their breeding activities from the Wilson lek. Male 

attendance at the Kort I lek gradually declined through 2004 (low of three 

males), and the birds shifted their display location to the Kort II lek site in 

2005. The Kort I and Kort II leks are currently classified as occupied. The 

Wilson Lek is classified as unoccupied/abandoned. The Payne lek was first 

discovered in spring 2001. The peak male count (21) recorded that year was 

higher than that of any subsequent year. Grouse counts at the Payne lek have 

fluctuated over the last seven years, with numbers increasing each year from 

2005 through 2007 (peak of 14 males in 2007). The management status of the 

Payne lek is currently listed as occupied. No other leks have been documented 

within the wildlife study areas for the North Porcupine LBA Tract. 

No leks have been documented within the wildlife study area for the South 

Porcupine LBA Tract (Figure 3-37). The Payne lek, which is nearly 5 miles to 

the northeast, is the closest sage-grouse lek to the South Porcupine LBA Tract. 

The wildlife study areas for the North and South Porcupine LBA Tracts are not 

within a sage-grouse focus area. 

Peak male counts at leks located within 2 miles of the general analysis areas 

for the North and South Porcupine tracts have been well documented from the 

mid-1980s through 2007. Annual grouse counts fluctuated during that period, 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-221 

with new leks discovered in some years and declining counts recorded in 

others. Although sage-grouse numbers have generally been low in these areas 

over the years, known or potential grouse habitat is present. However, the 

most suitable sage-grouse habitat exists in the North Porcupine area, as 

suggested by the distribution of grouse leks between the two areas and 

confirmed through the information gleaned from the last 7 years of radiotelemetry data collected in the general vicinity. Results from that project have 

demonstrated that grouse are most commonly recorded in the eastern quarter 

of the 2-mile wildlife survey area for the North Porcupine tract, east of the 

Payne County Road. Detailed reports and long-term maps documenting grouse 

locations in the area have been submitted to WDEQ/LQD and other agencies in 

each study year. 

Annual surveys for sage-grouse broods were conducted in native and reclaimed 

stream channels at the North Antelope Rochelle Mine and adjacent mines from 

1994 through 1999; such surveys were no longer required by WGFD and 

WDEQ/LQD after that year due to the consistent lack of grouse broods 

observed at coal mines throughout the PRB. Likewise, no sage-grouse broods 

were seen during recent baseline inventories conducted for the two Porcupine 

tracts. All grouse broods that have been recorded over the years occurred as 

incidental sightings during other wildlife surveys. 

3.10.5.2 Environmental Consequences

3.10.5.2.1 Proposed Action and Alternatives 2 and 3

Leasing and mining the North Hilight Field, South Hilight Field, West Hilight 

Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts 

would affect some potential habitat for mourning doves, wild turkeys, and gray 

partridge. While woody corridors are not abundant in the general Wright 

analysis area, they also are not unique to the LBA tracts. Similar habitat is 

present in other areas near the tracts, 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 wooded 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 greater 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 (0.51 percent per year), 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).
3.0 Affected Environment and Environmental Consequences 

3-222 Final EIS, Wright Area Coal Lease Applications 

The North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs 

Ranch, North Porcupine, and South Porcupine LBA Tracts are within the 

Northeast Wyoming Local Sage-Grouse Working Group (NWLSWG) area. It 

includes portions of the WGFD Sheridan and Casper regions and the USFS 

Thunder Basin National Grassland (TBNG). Sage-grouse monitoring has 

occurred within the NWLSWG since 1967. Within this area, sage-grouse 

population trends have exhibited a cyclical pattern, although the overall trend 

indicates declining numbers since at least 1967 (Figure 3-38). 

0

10

20

30

40

50

196819701972197419761978198019821984198619881990199219941996199820002002200420062008

Year

No. Males per Lek

Figure 3-38. Average Male Sage-grouse Lek Attendance Within the Northeast 

Wyoming Local Working Group Area (1968-2008). 

Source: USFS (2006), Thiele (2009) 

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 TBNG, has typically been lower than those 

observed statewide (Figure 3-39). 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 2006. 

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 

(Wisdom et al. 2002, Naugle et al. 2004). 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-223 

Year

0

5

10

15

20

25

30

35

40

45

19951996199719981999200020012002200320042005200620072008

No. Males per Lek

Statewide NWLSWG TBNG

Figure 3-39. Average Male Sage-grouse Lek Attendance Statewide and Within 

the Northeast Wyoming Local Sage-grouse Working Group Area 

and the Thunder Basin National Grasslands (1995-2008). 

Source: USFS (2006), Thiele (2009), Painter (2009) 

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 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). In the case of sage-grouse lek attendance near the Black 

Thunder, Jacobs Ranch, and North Antelope Rochelle mines, the decline in 

attendance preceded physical mining disturbance and thus may not be 

attributable to mine-related activities (Orpet 2007, J&S 2007). 

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 
3.0 Affected Environment and Environmental Consequences 

3-224 Final EIS, Wright Area Coal Lease Applications

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 is present before mining. Should these six BLM 

study areas (the six LBA tracts as applied for and the additional areas 

evaluated by BLM under Alternative 2, BLM preferred alternative for each tract) 

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 

BLM study areas, 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 the habitat in the general Wright analysis area. However, given the 

limited presence of sage stands in the 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. 

As discussed in Section 3.10.5.1, 10 sage-grouse leks have been documented 

within the six combined sage-grouse survey areas. Four of the leks have been 

active during recent survey years and are classified as occupied (Hansen Lakes, 

Payne, and Kort I and Kort II, which likely represent a shift in lekking activity 

rather than two distinct leks). Two of the leks have not been attended by 

displaying grouse for at least the last 10 years and are classified as 

unoccupied/abandoned (Butch and Wilson). There is insufficient data on two 

leks, therefore they have been classified as undetermined (Stuart I and Stuart 

II). Two leks have been eclipsed by mining activities at the adjacent Black 

Thunder and North Antelope Rochelle mines (Black Thunder and Rochelle, 

respectively). 

The occupied leks, Hansen Lakes and Payne, are within the BLM study areas 

for the North Hilight Field and North Porcupine LBA Tracts, respectively, and 

are therefore likely to be directly impacted if these two tracts are leased and 

mined under the Proposed Action and/or Alternative 2, BLM’s preferred 

alternative. The 3-mile radii of concern for the two other occupied leks (Kort I 

and Kort II, which are likely only one strutting ground that has been relocated 

slightly), overlap the North Porcupine LBA Tract. If the North Porcupine LBA 

Tracts as applied for and/or the additional areas evaluated by BLM under 

Alternative 2, the BLM’s preferred alternative, is leased and mined, potential 

nesting habitat for grouse that were bred at the Kort I and II leks would likely 

be affected by mining activity in those areas. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-225 

Stuart II, one of the two undetermined leks, is within the West Hilight Field 

LBA Tract as applied for, and the 3-mile radii of both undetermined leks 

(Stuart I and Stuart II) overlap both the West Hilight Field and West Jacobs 

Ranch LBA Tracts as applied for. The 3-mile radius is the area in which twothirds of the hens that were bred at those leks would be expected to nest. As 

previously discussed, the Stuart I and Stuart II leks are classified 

undetermined, but they are likely unoccupied/abandoned and will probably 

not be re-occupied in the near future due to the presence of nearby CBNG 

development activities and facilities. Therefore, if the West Hilight Field and 

West Jacobs Ranch LBA Tracts as applied for and the additional areas 

evaluated by BLM under Alternative 2 are leased and mined, it is unlikely that 

those two undetermined leks would be affected. However, as also previously 

discussed, few sage-grouse nests and no broods have been recorded on any of 

the six LBA tracts as applied for or on lands added under Alternative 2, BLM’s 

preferred alternative for each tract, during specific surveys or incidental to 

other wildlife surveys conducted in those areas annually since at least 1994. 

The noise associated with mining operations may disrupt sage-grouse breeding 

and nesting activities that might occur in those areas. 

There is some limited evidence that sage-grouse do repopulate areas after 

reclamation for the species. However, there is no evidence that populations 

attain their previous levels, and reestablishment in reclaimed areas may take 

20 to 30 years or longer (Braun 1998). Estimates for the time it would take to 

restore shrubs, including sagebrush, to pre-mine density levels range from 20 

to 100 years, which may delay sage-grouse repopulation in the reclaimed 

areas. 

3.10.5.3 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. 

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 2002). 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 Black Thunder, Jacobs Ranch, and 

North Antelope Rochelle mines have conducted specific surveys for migratory 

birds of concern annually since at least 1993, incorporating new lists and 

survey protocols as they were issued. The surveys, which are conducted in the 

spring and summer, include the existing permit area and a surrounding 1⁄2-
3.0 Affected Environment and Environmental Consequences 

3-226 Final EIS, Wright Area Coal Lease Applications

mile perimeter for most species. Species of added concern such as the sagegrouse and bald eagle may require expanded survey perimeters. 

Due to the proximity of the North Hilight Field, South Hilight Field, West 

Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and 

South Porcupine LBA Tracts to the existing mine permit areas, significant 

portions of the general analysis areas for these six LBA tracts have been 

included in annual surveys for avian species of concern since at least 1993. 

Results from surveys for migratory birds at the three applicant mines are 

available in baseline and annual wildlife reports, on file with WDEQ/LQD. 

Those reports include a tabulation of the regional status, expected 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. 

The Wildlife Section of the supplemental information document to this EIS, 

which is available on request, includes a tabulation of the regional status and 

expected occurrence, historical observations, and breeding records for each of 

the species on the Coal Mine List of 40 Migratory Bird Species of Management 

Concern in Wyoming, based on a compilation of the results of the annual 

surveys conducted on and near the respective LBA tract’s general analysis 

area. 

Non-raptor avian species that have been documented within the PRB and are 

included on both the Coal Mine List of 40 Migratory Bird Species of Management 

Concern in Wyoming 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 sage-grouse. Of those species, the long-billed 

curlew, sage thrasher, loggerhead shrike, sage sparrow, Brewer’s sparrow, and 

sage-grouse have been recorded within the combined general analysis areas for 

these six LBA tracts; only the sage thrasher, loggerhead shrike, Brewer’s 

sparrow, and sage-grouse are known or suspected to nest in those vicinities. 

Raptor species that have been documented in the PRB and are on the Coal 

Mine List of 40 Migratory Bird Species of Management Concern in Wyoming 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 combined general analysis areas for these six LBA 

tracts, 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, 23 of the 40 listed species have historically been observed within the 

combined general analysis areas for these six LBA tracts. Species that 

historically have been recorded nesting in these areas or are suspected of 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-227 

nesting, based on their presence and behavior during the breeding season, 

include the burrowing owl, Brewer’s sparrow, Swainson’s hawk, short-eared 

owl, ferruginous hawk, lark bunting (Calamospiza melanocorys), grasshopper 

sparrow (Ammodramus savannarum), upland sandpiper (Bartramia longicauda), 

loggerhead shrike, lark sparrow (Chondestes grammacus), sage thrasher, 

chestnut-collared longspur (Calcarius ornatus), McCown’s longspur (Calcarius 

mccownii), sage-grouse, and the vesper sparrow (Pooecetes gramineus). Other 

species observed in the areas less often include the peregrine falcon (Falcon 

peregrinus), bald eagle, bobolink (Dolichonyx oryzivorus), common loon (Gavia 

immer), long-billed curlew, red-headed woodpecker (Melanerpes 

erthrocephalus), sage sparrow, and merlin (Falco coumbarius). The bald eagle is 

only observed in the winter or as a migrant. The other non-nesting species 

have been observed infrequently as migrants. 

The mountain plover is included on the list of Migratory Bird Species of 

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 in mine reclamation plans that 

would provide protection for this species, as it continues to be protected under 

the Migratory Bird Treaty Act, and as a USFS Region 2 Sensitive Species and 

as a Sensitive Species under BLM policy (Bureau Manual 6840.06 E., Sensitive 

Species). 

Wildlife surveys conducted at the Black Thunder, Jacobs Ranch, and North 

Antelope Rochelle mines since the late 1970s have detected the presence of 

very few mountain plovers with only one confirmed nesting attempt, which was 

an active nest discovered inside the current mine permit area for the North 

Antelope Rochelle Mine in 2004, fledging two young. The survey areas, which 

include the mines’ permit areas and a 1⁄2-mile perimeter around each, are 

inventoried for suitable mountain plover habitat annually. No other mountain 

plovers have been documented in the general Wright analysis area before or 

after that year. 

The bald eagle, a USFS Region 2 Sensitive Species and a BLM Sensitive 

Species, is seasonally common and most frequently observed during the winter 

months. Bald eagles are relatively common winter residents and migrants in 

northeastern Wyoming’s PRB, but only rarely nest in that region. No bald eagle 

nests or winter roosts have been documented on and within 1 mile of the 

general analysis areas for these six LBA tracts during either baseline or annual 

monitoring studies since they began in the late 1970s. Aside from a few 

isolated and small (fewer than five trees) stands of cottonwoods that occur 

along major drainages, little potential bald eagle nesting and winter roosting 

habitat is present in the general Wright analysis area. In addition, the area 

does not generally 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 infrequently seen in 
3.0 Affected Environment and Environmental Consequences 

3-228 Final EIS, Wright Area Coal Lease Applications

the general Wright analysis area, perched or foraging only during winter. 

Additional information about the observed occurrence of the bald eagle on 

these six LBA tracts can be found in the Sensitive Species Evaluation 

(Appendix H) of this EIS document. 

Swainson’s hawks have nested in the general Wright analysis area for the last 

few years. However, because of the restricted 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, the potential 

for increased numbers of nesting Swainson’s hawks may be limited. 

The burrowing owl is uncommon and is observed as an occasional or 

uncommon breeder in the general Wright analysis area. 

Sage-grouse, recently added to the Level I list of avian species of concern at 

coal mines, have declined in the general Wright analysis area but are still 

classified as a common breeder on and within 3 miles of the general analysis 

areas for the North Hilight Field, West Hilight Field, West Jacobs Ranch, and 

North Porcupine LBA Tracts (see Section 3.10.5). The USFWS considers Level I 

species as in need of conservation action, which includes having a monitoring 

and mitigation plan for those birds. 

Lark buntings and vesper sparrows have been recorded in the general Wright 

analysis area during each of the last 15 years (1994-2008). 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 Wright analysis area throughout spring and summer, 

and are presumed to nest in the vicinity. 

Lark sparrows have been recorded periodically in the general Wright 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 those areas having relatively rugged breaks, thus the higher 

number of sightings there. Grasshopper sparrows have occasionally been 

recorded in the general Wright analysis area, but most sightings have been in 

the relatively mature stands of reclaimed grassland associated with the nearby 

existing mines. 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 Wright analysis area. Most observations of these species consisted 

of migrants and non-breeding adults. Although potential nesting habitat is 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-229 

present, neither species has been known to nest in the general Wright analysis 

area. 

The remaining 17 migratory bird species of management concern have never 

been recorded in the general Wright 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 Wright analysis area. 

Under natural conditions, the general analysis areas for the North Hilight Field, 

South Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, 

and South Porcupine LBA Tracts provide limited and marginal habitat for 

waterfowl and shorebirds. The natural aquatic habitat, prior to CBNG 

development within and adjacent to the general Wright analysis area, was 

mainly available during spring migration as ponds (primarily stock reservoirs 

and playa areas) and intermittent and ephemeral streams. Many of these 

water features generally were reduced to small, isolated pools or were 

completely dry during the remainder of the year. However, the relatively recent 

development of CBNG within and upstream of the general Wright analysis area 

has enhanced the available water resources, 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 Wright 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 2 and 3

Of the 23 Migratory Bird Species of Management Concern in Wyoming that have 

historically been observed in the general Wright analysis area at least once, 12 

species are classified as Level I (those identified as needing conservation 

action). Eight of those 12 species are known or presumed to nest in and near 

the general Wright analysis area: ferruginous hawk, burrowing owl, sagegrouse, Brewer’s sparrow, Swainson’s hawk, McCown’s longspur, short-eared 

owl, and upland sandpiper. The raptors and sparrow have nested with some 

regularity in the area over the last two decades of annual monitoring. In 

contrast, the other three species are presumed to have nested less frequently, 

in part due to dwindling populations (sage-grouse) and more limited nesting 

habitat (McCown’s longspur and upland sandpiper). The other four Level I 

species historically observed in the general Wright analysis area include the 

long-billed curlew, peregrine falcon, sage sparrow, and bald eagle. 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 
3.0 Affected Environment and Environmental Consequences 

3-230 Final EIS, Wright Area Coal Lease Applications

within several miles of the general Wright analysis area, and none of the other 

three species have ever been documented to display breeding behaviors or nest 

in the general Wright analysis area. 

Leasing and subsequently mining these six BLM study areas (the LBA tracts as 

applied for and the additional areas evaluated by BLM under Alternative 2, the 

BLM’s preferred alternative for each LBA tract) would fragment, impair, or 

destroy current existing habitat within the general analysis areas for these 12 

Level I species. 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 

plans and practices for the Black Thunder, Jacobs Ranch, and North Antelope 

Rochelle mines 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. Only a few native trees are present within the general 

Wright analysis area and limited primarily to reaches along Little Thunder 

Creek, North Prong Little Thunder Creek, and Porcupine Creek. Some 

domestic trees were planted in shelterbelts adjacent to ranch buildings located 

within the West Jacobs Ranch LBA Tract. Any naturally-occurring trees that 

are removed by mining would be inventoried and replaced with the same 

number of new trees on the postmine landscape, as required by state and 

federal law. 

Specific impacts to and mitigation measures for avian species of management 

concern such as 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 Wright 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. No impacts to mountain plovers are 

anticipated because they have not been observed in the vicinity of the general 

analysis areas for these six LBA tracts during wildlife surveys conducted for the 

adjacent applicant mines that began in the 1970s, and the typical suitable 

habitat for this species is not currently present in these areas. 

Mining the North Hilight Field, South Hilight Field, West Hilight Field, West 

Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts as applied 

for and the additional areas evaluated by BLM under Alternative 2, the BLM’s 

preferred alternative for each 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. Any 

diverted stream channels (i.e., Little Thunder Creek, North Prong Little 

Thunder Creek, and Porcupine Creek) would provide similar, but not identical, 

habitat compared to the natural stream channels, though natural stream flow 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-231 

and the presence of CBNG discharge water in some areas would not be 

affected. Active mining adjacent to those drainages could inhibit use by 

aquatic avian species. 

The current reclamation plans for the three applicant mines require that any 

portion of a stream channel affected by currently permitted mining be 

reclaimed to restore its pre-mining hydrologic functions. If these six LBA tracts 

are leased and mined, these reclamation efforts would be extended into the 

portion of the streams affected by mining the new tracts. 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 tracts 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. 

3.10.7 Amphibians, Reptiles, and Aquatic Species

3.10.7.1 Affected Environment

Monitoring of amphibians, reptiles, and aquatic species is not required at the 

Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines. Likewise, 

fish surveys were not required or conducted specifically for the associated 

proposed lease areas included in this analysis. Nevertheless, wildlife surveys 

completed specifically for the applicant mines and other mines in the PRB, 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 Wright analysis area is 

limited by the ephemeral nature of surface waters. The lack of deepwater 

habitat, extensive and persistent water sources, and mesic habitat in general 

limits the presence and diversity of fish, amphibians, and other aquatic or 

semi-aquatic species within most of the general Wright analysis area. As 

discussed above, all water courses are ephemeral, receiving flow contributions 

primarily from convective thunderstorm runoff and, to a lesser extent, from 

snowmelt runoff in the spring (Ogle and Calle 2006). Limited portions of the 

streams may receive recharge from bank storage, making them locally 

intermittent. Historically, water was often present in the main stream 

channels only as small, shallow, isolated pools. Currently, and for an 

indefinite time into the future, some of the water courses and internally-
3.0 Affected Environment and Environmental Consequences 

3-232 Final EIS, Wright Area Coal Lease Applications

drained playas are receiving discharge water from CBNG development; 

however, streamflow is still very much a function of the amount and timing of 

precipitation and snowmelt runoff. Therefore, the mean annual streamflow 

rates and discharge volumes have not significantly increased, although 

extended periods of no flow are less common (Clark and Mason 2007). Despite 

the recent influx of water into the general Wright analysis area, many channels 

are still reduced to isolated, shallow pools in the summer. Little Thunder 

Creek, North Prong Little Thunder Creek, and Porcupine Creek have not 

become perennial, even with the addition of CBNG discharge water. Seventeen 

in-channel stock reservoirs (over 1 acre in size) and 41 playa areas exist within 

the six combined general analysis areas. Water discharged from CBNG wells 

has enhanced the water supply within some of those water bodies, resulting in 

improved habitat for amphibian and aquatic species. However, those enhanced 

areas are still relatively limited and/or isolated in nature. The upland areas 

provide habitat for reptile species. 

Numerous amphibian and reptile species have been recorded during the 

various wildlife surveys conducted on the Black Thunder, Jacobs Ranch, and 

North Antelope Rochelle mine areas and adjacent lands, including the LBA 

tracts. These species include the tiger salamander (Ambystoma tigrinum), 

plains spadefoot (Scaohiopus bombifrons), great plains toad (Bufo cognatus), 

boreal chorus frog (Pseudacris triseriata maculata), northern leopard frog (Rana 

pipiens), short-horned lizard (Phrynosoma douglassi), northern sagebrush 

lizard (Sceloporus graciosus graciosus), plains hognose snake (Heterondon 

nasicus nasicus), wandering garter snake (Thamnophis elegans vagrans), redsided garter snake (Thamnophis sirtalis parietalis), prairie rattlesnake (Crotalus 

viridis viridis), bullsnake (Pituophis melanoleucas sayi), western plains garter 

snake (Thamnophis radix haydeni), and eastern yellowbelly racer (Coluber 

constrictor flaviventris). 

The relatively low quantity and quality of aquatic habitat in the general Wright 

analysis area reduces its potential to attract these species, particularly 

amphibians and turtles. The boreal chorus frog has been the most common 

herptile observed in the area over the last two decades. These frogs have been 

heard in creeks and ponds throughout the area during spring. Other less 

common species observed on or near the general analysis areas for these six 

LBA tracts over time include the northern leopard frog, tiger salamander, and 

wandering garter snake. Prairie rattlesnakes, short-horned lizards, and 

sagebrush lizards have been observed infrequently in sagebrush stands 

throughout the area. Other dryland species, such as the bullsnake, are likely 

to occur but are seldom observed. The northern leopard frog is listed as a 

USFS and BLM Sensitive Species (see Appendix H). 

Fish sampling was conducted on the TBNG in the Cheyenne River, Little 

Thunder River, Black Thunder Creek, and Antelope Creek in 2003 and 2004 by 

USFS personnel. Species observations included the following: black bullhead 

(Ameiurus melas), plains killifish (Fundulus zebrinus), carp (Cyprinus spp.), 

brassy minnow (Hybognathus hankinsoni), plains minnow (Hybognathus 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-233 

placitus), green sunfish (Lepomis cyanellus), bluegill (Lepomis macrochirus), 

fathead minnow (Pimephales promelas), sand shiner (Notropis stramineus), 

sucker spp. (Catostomus spp.), plains top minnow (Fundulus sciadicus), and 

flathead chub (Platygobio gracilis). The flathead chub and plains minnow are 

considered a USFS Region 2 sensitive species. Plains minnows were observed 

in Little Thunder Creek and the Cheyenne River. Flathead chubs were 

observed in the Cheyenne River. 

Based on WGFD gill net sampling conducted in 2000 and 2004, black 

bullhead, largemouth bass (Micropterus salmoides), and rainbow trout 

(Onchorhynchus mykiss) were present in the Little Thunder Reservoir, which is 

located on the West Hilight Field tract. There are no historical monitoring 

records of Little Thunder Reservoir’s water levels. Anecdotally, local residents 

and mine personnel recall this reservoir held only a fraction of its volume 

capacity prior to groundwater discharges from CBNG development in the Little 

Thunder Creek drainage above the impoundment, which began in the mid- to 

late-1990s. Anecdotal evidence also indicates that the reservoir was rarely 

used for recreational fishing prior to CBNG development in the area. The 

stocking of catchable rainbow trout began at the Little Thunder Reservoir in 

2004, and WGFD has not restocked the reservoir since 2006. 

3.10.7.2 Environmental Consequences

3.10.7.2.1 Proposed Action and Alternatives 2 and 3

Mining activities in the general analysis areas for the North Hilight Field, South 

Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and 

South Porcupine LBA Tracts would remove habitat for amphibians, reptiles and 

aquatic species, particularly in portions of the ephemeral drainages (Little 

Thunder Creek, North Prong Little Thunder Creek, and/or Porcupine Creek) 

during active mining. Under natural conditions, habitat for amphibians and 

aquatic species is limited on these six LBA tracts as applied for and the 

additional area evaluated by BLM under Alternative 2, BLM’s preferred 

alternative, for each tract. Additionally, reclamation of the primary stream 

channels and restoration of surface water flow quantity and quality after 

mining to approximate pre-mining conditions would restore the naturallyoccurring mesic and aquatic habitats of those water courses. 

3.10.7.2.2 No Action Alternative

Impacts to amphibians, reptiles, and aquatic species under the No Action 

Alternative would be similar to the impacts described in Section 3.10.1.2.2. 

3.10.8 Threatened, Endangered, Proposed, and Candidate Species; BLM

Sensitive Species; and USFS Sensitive Species and Management 

Indicator Species

Refer to Appendices G and H. 
3.0 Affected Environment and Environmental Consequences 

3-234 Final EIS, Wright Area Coal Lease Applications

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 passage of pronghorn and other big game 

species 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: 

− creation of raptor nests and nesting habitat through enhancement 

efforts (nest platforms, tree plantings) to mitigate other nest sites 

impacted by mining operations; 

− relocation of raptor nests that would be impacted by mining in 

accordance with the approved raptor monitoring and mitigation plan; 

− obtaining a permit for removal and mitigation of golden eagle nests 

and those of other raptor species; 

− 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; 

− reestablishment of the ground cover necessary for the return of a 

suitable raptor prey base after mining; 

− 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 and native forbs on reclaimed lands and 

grading of reclaimed lands to create swales and depressions suitable for 

sagebrush obligates and their young; 

• restoration of diverse landforms, direct topsoil replacement, and the 

construction of brush piles, snags, and rock piles to enhance habitat for 

wildlife; 

• restoration of short-grass habitat for species that nest and forage in 

those habitat types; 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-235 

• restoration of habitat provided by jurisdictional and functional wetlands; 

and 

• reclamation of the stream channels and restoration of surface water flow 

quantity and quality after mining to approximate pre-mining conditions. 

The current mine permits for the Black Thunder, Jacobs Ranch, and North 

Antelope Rochelle mines require reconstruction of bed form features, such as 

pools and runs, in major stream channels. Those efforts should help restore 

the channels’ natural form and function, as well as provide habitat. Future 

restoration will continue to be achieved by salvaging sufficient material from 

original channel and terrace alluvium, or other materials having the same 

physical characteristics, to reconstruct naturally-occurring channel features. 

These measures are included in the existing mining and reclamation permits 

and would be included in any amended mining and reclamation plans, if one or 

more of the LBA tracts are leased and proposed for mining. 

Baseline wildlife surveys were conducted for all three applicant mines before 

mining operations began. Annual wildlife monitoring has been ongoing since 

the late 1970s or 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 

respective general analysis area for each of these six LBA tracts have been 

encompassed during the required monitoring efforts for the neighboring three 

mines. 

The required annual wildlife monitoring programs 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; 

• raptor territorial occupancy and nest productivity is surveyed annually 

on and within a 1- or 2-mile perimeter surrounding the existing permit 

areas, depending on the mine; and 

• winter surveys for bald eagle winter roosts on and within 1 mile of the 

permit area (conducted as needed base on proximity of disturbance to 

potential roosting habitat). 
3.0 Affected Environment and Environmental Consequences 

3-236 Final EIS, Wright Area Coal Lease Applications

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 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 general Wright analysis area. 

Although big game surveys are no longer required, the Black Thunder and 

North Antelope Rochelle mines (as well as the neighboring 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 these mines. 

All three applicant mines operate under a current USFWS approved Monitoring 

and Mitigation Plan for raptors and other migratory bird species of 

management concern. Their respective plans would be amended to include the 

associated LBA tracts if they are leased and permitted for mining. The 

amended plans would be subject to review and approval by the USFWS before 

the amended mine plans are approved. 

If the current Coal Mine List of 40 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 

Plans for each mine would be amended to incorporate and protect those birds 

and their habitats. 

3.10.10 Residual Impacts

Although the North Hilight Field, South Hilight Field, West Hilight Field, West 

Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts 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 that occupy somewhat specialized, low-growth form habitats. Those 

species may repopulate reclaimed areas, but populations may not attain premining levels without special variances to accommodate those specific needs. 

For example, every effort would be made to preserve source populations of 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-237 

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 habitat is present in the general Wright 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. Until pre-mining habitats have been fully reestablished, such 

habitat transformations would likely result in a change in wildlife species 

composition. Minimal residual impacts to T&E, candidate, or proposed plant 

and animal species are expected to occur, because state and federal 

regulations require reclamation of specific habitats. 

3.11 Land Use and Recreation

3.11.1 Affected Environment

Surface ownership within the general Wright analysis area consists primarily of 

private lands with intermingled federal lands. Table 3-15 summarizes the 

distribution of surface ownership for each LBA tract configured under 

Alternative 2, BLM’s preferred alternative. Federally owned lands included in 

the general Wright analysis area include portions of the Thunder Basin 

National Grasslands (TBNG) administered by the USFS. As indicated in Table 

3-15, approximately 162 acres of state owned land is included in the North 

Porcupine LBA Tract configured under Alternative 2, and no federally owned 

land is included in the West Jacobs Ranch LBA Tract configured under 

Alternative 2. Surface ownership within the BLM study area (the Alternative 2 

configuration) for the North Hilight Field, South Hilight Field, West Hilight 

Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts, 

is shown in Figures 3-40 through 3-45, respectively. 

Table 3-15. Distribution of Surface Ownership Within Each LBA Tract 

Configured Under Alternative 2, BLM’s Preferred Alternative. 

Federal Ownership State Ownership Private Ownership 

LBA Tract (Acres) (Percent) (Acres) (Percent) (Acres) (Percent)

North Hilight Field 80.9 1.1 0.0 0.0 7,058.5 98.9 

South Hilight Field 2,572.6 88.0 0.0 0.0 349.8 12.0 

West Hilight Field 2,900.0 40.3 0.0 0.0 4,291.4 59.7 

West Jacobs Ranch 0.0 0.0 0.0 0.0 8,076.2 100.0 

North Porcupine 5,289.6 71.8 162.1 2.2 1,915.1 26.0 

South Porcupine 1,637.6 45.9 0.0 0.0 1,930.4 54.1 

Total 12,480.7 34.4 162.1 0.5 23,621.4 65.1 

Livestock grazing on native rangeland is the primary land use, while oil and gas 

production, wildlife habitat, communication and power lines, transportation, 
StateHilight Road

Keeline Road

Highway 450 BNSF & UP RR

31

30

19

18

7

6

32

29

20

17

8

5

33

28

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9

4

34

27

22

15

10

3

35

26

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14

11

2

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10

3

35

26

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2

36

25

24

13

12

1

10

3

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2

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1

7

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9

4

10

3

11

2

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

North

Prong

Little

Thunder

Creek

Creek

Thunder

Black

R. 71 W. R. 70 W.

Hilight Road

BNSF & UP RR

LEGEND

0 3000 6000 12000

GRAPHIC SCALE (FEET)

Foundation Coal West, Inc.

North Hilight Field LBA Tract as Applied for

Black Thunder Mine Permit Boundary Ark Land Co.

Guy W. Edwards Trust

Mills Brothers Partnership

Thunder Basin Coal Company LLC Western RR Properties Inc. & BNRR

Thunder Basin National Grassland

North Hilight Field LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-40. Surface Ownership Within the North Hilight Field LBA Tract Alternatives.

3.0 Affected Environment and Environmental Consequences

3-238 Final EIS, Wright Area Coal Lease Applications
Antelope

Edwards Reno Road Hilight RoadRoad

Road

BNSF & UP RR

32

29

20

17

8

33

28

21

16

9

34

27

22

15

10

35

26

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14

11

36

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12

31

30

19

18

7

32

29

20

17

8

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9

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8

5

16

9

4

15

10

3

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7

6

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4

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

T.

43

N.

T.

42

N.

Little

Thunder

Creek

North

Prong Little

Thunder

Creek

R. 71 W. R. 70 W.

South Hilight Field LBA Tract as Applied for

LEGEND

0 3000 6000 12000

GRAPHIC SCALE (FEET)

Thunder Basin National Grassland

Black Thunder Mine Permit Boundary

Thunder Basin Coal Company LLC

Western RR Properties Inc. & BNRR

South Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-41. Surface Ownership Within the South Hilight Field LBA Tract Alternatives.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-239
State

Edwards

Small

Matheson Road

Hilight Road

Road

Highway 450

Road

BNSF & UP RR

31

30

19

32

29

20

33

28

21

34

27

22

35

26

23

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

6

5 4 3 2

T.

43

N.

T.

42

N.

T.

43

N.

T.

42

N.

Little Thunder

Creek

North

Prong

Little

Thunder

Creek

R. 71 W.

R. 71 W.

T.

44

N.

T.

43

N.

T.

44

N.

T.

43

N.

LEGEND

0 3000 6000 12000

GRAPHIC SCALE (FEET)

James R. & Irene Stuart Trusts

West Hilight Field LBA

Tract as Applied for

Black Thunder Mine Permit Boundary

Ark Land Co.

Thomas W. & Leah B. Edwards

Bridle Bit Ranch Co.

Thunder Basin Coal Company LLC

Thunder Basin National Grassland

Area Added Under Alternative 3

(See Figure 3-43 for Surface Ownership)

West Hilight Field LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-42. Surface Ownership Within the West Hilight Field LBA Tract Alternatives.

3.0 Affected Environment and Environmental Consequences

3-240 Final EIS, Wright Area Coal Lease Applications
31

30

19

18

7

32

29

20

17

8

33

28

21

16

9

34

27

22

15

10

35

26

23

14

11

36

25

24

13

12

18

7

6

17

8

5

16

9

4

15

10

3

14

11

2

13

12

1

36

25

24

13

12

13

12

1

T.

44

N.

T.

43

N.

T.

44

N.

T.

43

N.

Small

Hilight Road

Road

BNSF & UP RR

State Highway 450

West

Coal

Fork

Creek

Little

Prong

North

Little

Thunder

Creek

Thunder

R. 72 W. R. 71 W.

R. 72 W. R. 71 W.

Shroyer Road

Hilight

BNSF & UP RR

Road

Jacobs Ranch Mine Permit Boundary

West Jacobs Ranch LBA Tract as Applied for

LEGEND

0 3000 6000 12000

GRAPHIC SCALE (FEET)

Boller-Mills Ranch L P

William M. & Lois R. Chittenden

Ark Land Co.

West Jacobs Ranch LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-43. Surface Ownership Within the West Jacobs Ranch LBA Tract Alternatives.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-241
Reno Road

Mackey

Antelope

BNSF & UP RR

Road

Road

Matheson Road

21

28

33

16 15

22

27

34

26

35

23

14 13

2425

36

18

19

30

31

17

2029

32

16

212833

27

34

22

15

35

26

14

23

1324

25

36

6 5 4 3 2 1 4 3 2 1

T.

42

N.

T.

41

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

42

N.

T.

41

N.

Creek

Porcupine

Road Antelope

Matheson Road

Mackey Road

North Antelope Rochelle Mine Permit BoundaryNorth Porcupine LBA Tract as Applied for

LEGEND

3000 6000 12000 0

GRAPHIC SCALE (FEET)

Thunder Basin National Grassland

State of Wyoming

Jerry N. & Rhonda Wilkinson

School Creek Coal Resources

North Porcupine LBA Tract Under Alternative 2,BLM's Preferred Alternative

Powder River Coal, LLC

Western Railroad Properties, Inc.

Figure 3-44. Surface Ownership Within the North Porcupine LBA Tract Alternatives.

3.0 Affected Environment and Environmental Consequences

3-242 Final EIS, Wright Area Coal Lease Applications
Antelope

BNSF & UP RR

Matheson Road

Road

34 35 36 31 32

19

18

7

6

20

17

8

5

22

15

10

3

23

14

11

2

24

13

12

1

T.

42

N.

T.

41

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W. T.

42

N.

T.

41

N. Creek

Porcupine

Creek

Horse

South Porcupine LBA Tract as Applied for

North Antelope Rochelle Mine Permit Boundary

LEGEND

0 1500 3000 6000

GRAPHIC SCALE (FEET)

Powder River Coal, LLC

Jerry J. Dilts Living Trust

Barbara H. Dilts Living Trust

Bridle Bit Ranch Company

Jerry J. Dilts Family LP II

and Bridle Bit Ranch Co.

South Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Thunder Basin National Grassland

Western Railroad Properties, Inc.

Jerry J. Dilts Family LP I

Figure 3-45. Surface Ownership Within the South Porcupine LBA Tract Alternatives.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-243
3.0 Affected Environment and Environmental Consequences 

3-244 Final EIS, Wright Area Coal Lease Applications

and recreation are secondary land uses for both public and private lands. As 

indicated in Table 3-15, approximately 12,481 acres of federal surface 

administered by the USFS is included in the North, South and West Hilight 

Field tracts and the North and South Porcupine tracts under Alternative 2, 

BLM’s preferred alternative. This federal land is within Grazing Allotments 

#270 (located in the North Hilight Field tract), #256 (located in the South and 

West Hilight Field tracts), #266 (located in the West Hilight Field tract), #280, 

#223, #240, #298, #264, #282 (located in the North Porcupine tract), and #278 

and #281 (located in the South Porcupine tract), all of which are currently held 

by Thunder Basin Grazing Association (TBGA 2008). This agreement annually 

permits the Thunder Basin Grazing Association (TBGA) for 71,500 animal unit 

months (AUMs) on approximately 351,192 TBNG acres for a period of 10 years. 

In turn, TBGA permits these allotments to its individual members. These 

allotments within the proposed lease tracts are currently permitted to six 

members for a total 2,976 AUMs. 

Areas of disturbance within and near the six proposed lease areas include 

roads, oil and gas wells and associated production facilities, surface minerelated facilities and activities, and activities associated with ranching 

operations. State Highway 59, which runs north-south, is located west of all 

six LBA tracts, and State Highway 450, which runs east-west, borders the 

southern edge of the West Jacobs Ranch tract and the northern edge of the 

West Hilight Field tract (Figure 1-1). County roads that border or traverse the 

LBA tracts and provide public and private access within and near the general 

Wright analysis area include Shroyer Road (County Road 116), Hilight Road 

(County Road 52), Reno Road (County Road 83), Mackey Road (County Road 

69), Antelope Road (County Road 4), and Matheson Road (County Road 70). 

Several unnamed two-track roads also traverse and provide private access 

within and near the proposed lease areas. The Burlington Northern Santa Fe & 

Union Pacific (BNSF & UP) railroad right-of-way (ROW) crosses portions of, or is 

adjacent to all six of the LBA tracts configured under Alternative 2 (Figures 3-

40 through 3-45). 

The oil and gas estate within the general Wright analysis area is federally and 

privately owned, with the majority (approximately 67 percent) being federally 

owned. Most, although not entirely all, of the federally owned oil and gas 

estate is currently leased. The ownership of the oil and gas estate for each LBA 

tract is shown on Figures 3-46 through 3-51. Lists of the current federal oil 

and gas lessees within the North Hilight Field, South Hilight Field, West Hilight 

Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts 

are listed in Tables 3-16 through 3-21, respectively. 

According to the Wyoming Oil and Gas Conservation Commission (WOGCC) 

records as of May 14, 2008, there were 74 permitted conventional oil and gas 

wells on lands included within the BLM study areas (the tracts as applied for 

and the additional areas evaluated by BLM under Alternative 2) for these six 

LBA tracts (Figures 3-46 through 3-51). Of these 74 wells, 28 were 

permanently abandoned, 33 were still producing, nine were shut in, three were 
31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

10

3

11

2

12

1

7

6

8

5

9

4

10

3

11

2

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

PRIVATE

WYW144475

WYW091135 WYW3063

WYW0103392

PRIVATE WYW7750

WYW14503

WYW5305

WYW0249938A

WYW0103392

WYW5305

WYW5306 WYW5305

WYW32195

WYW32195

COMPT OG

PRIVATE

PRIVATE

PRIVATE

PRIVATE

0 3000 6000 12000

GRAPHIC SCALE (FEET)

Oil & Gas Ownership Boundaries

WYW00000 Federal Oil & Gas Lease Numbers

LEGEND

Existing Black Thunder Mine Federal Coal Leases

Black Thunder Mine Permit Boundary

North Hilight Field LBA Tract as Applied for

North Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

CBNG - Shut-In

CBNG - Producing

Oil - Plugged & Abandoned

Injector, Plugged and Abandoned

Oil - Producing

Oil - Shut-In

Monitor - Shut-in

Note: Well locations and status were derived from a download from

the WOGCC website on 5/14/08. (Located by 1/4 1/4 for clarity)

OIL & GAS WELL TYPES

Figure 3-46. Oil and Gas Wells and Oil and Gas Ownership Within the North Hilight Field LBA Tract

Alternatives.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-245
32

29

20

17

8

33

28

21

16

9

34

27

22

15

10

35

26

23

14

11

36

25

24

13

12

31

30

19

18

7

32

29

20

17

8

33

28

21

16

9

17

8

5

16

9

4

15

10

3

14

11

2

13

12

1

18

7

6

17

8

5

16

9

4

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

WYW30501

RESTRICTED MINERALS

WYW143686

PRIVATE

WYW145841

RESTRICTED MINERALS

WYW140940

UNLEASED

WYW143940

WYW147833

South Hilight Field LBA Tract as Applied for

LEGEND

Black Thunder Mine Permit Boundary

0 3000 6000 12000

GRAPHIC SCALE (FEET)

Oil & Gas Ownership Boundaries

WYW00000 Federal Oil & Gas Lease Numbers

Existing Black Thunder Mine Federal Coal Leases

South Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

CBNG - Plugged and Abandoned

CBNG - Shut-In

CBNG - Producing

Oil - Plugged & Abandoned

CBNG - Dry Hole

Oil - Producing

Note: Well locations and status were derived from a download from

the WOGCC website on 5/14/08. (Located by 1/4 1/4 for clarity)

OIL & GAS WELL TYPES

Figure 3-47. Oil and Gas Wells and Oil and Gas Ownership Within the South Hilight Field LBA Tract

Alternatives.

3.0 Affected Environment and Environmental Consequences

3-246 Final EIS, Wright Area Coal Lease Applications
PRIVATE

WYW124456

WYW96875

WYW124456

PRIVATE

WYW140939

WYW140773

WYW95702

PRIVATE

WYW36006

WYW143062

WYW95702

WYW143686

WYW36006

WYW29941

WYW150372

WYW142058

WYW135567

WYW132212

WYW95702

PRIVATE

WYW140773

WYW96875

WYW95702

T.

43

N.

T.

42

N.

T.

43

N.

T.

42

N.

R. 71 W.

R. 71 W.

31

30

19

32

29

20

33

28

21

34

27

22

35

26

23

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

6

5 4 3 2

UNLEASED

PRIVATE

RESTRICTED

MINERALS

T.

44

N.

T.

43

N.

T.

44

N.

T.

43

N.

LEGEND

Oil & Gas Ownership

Boundaries

WYW00000 Federal Oil & Gas

Lease Numbers

0 3000 6000 12000

GRAPHIC SCALE (FEET)

Existing Black Thunder Mine

Federal Coal Leases

Black Thunder Mine

Permit Boundary

West Hilight Field LBA

Tract as Applied for

West Hilight Field LBA Tract

Under Alternative 2,

BLM's Preferred Alternative

CBNG - Plugged and Abandoned

CBNG - Shut-In

CBNG - Producing

Oil - Dry Hole

Oil - Plugged & Abandoned

CBNG - Dry Hole

Conventional Gas - Shut-In

Conventional Gas - Producing

Oil - Producing

Note: Well locations and status were derived

from a download from the WOGCC website

on 5/14/08. (Located by 1/4 1/4 for clarity)

OIL & GAS WELL TYPES

West Hilight Field LBA Tract

Under Alternative 3

Figure 3-48. Oil and Gas Wells and Oil and Gas Ownership Within the West Hilight Field LBA Tract

Alternatives.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-247
31

30

19

18

7

32

29

20

17

8

33

28

21

16

9

34

27

22

15

10

35

26

23

14

11

36

25

24

13

12

18

7

6

17

8

5

16

9

4

15

10

3

14

11

2

13

12

1

36

25

24

13

12

13

12

1

T.

44

N.

T.

43

N.

T.

44

N.

T.

43

N.

R. 72 W. R. 71 W.

R. 72 W. R. 71 W.

PRIVATE

WYW143510

WYW118520

NOT POSTED

WYW150372

WYW139066

WYW133562

WYW150372

WYW142057

WYW132214

WYW95702

WYW132214

WYW143510

WYW132214

LEGEND

0 3000 6000 12000

GRAPHIC SCALE (FEET)

Oil & Gas Ownership Boundaries

WYW00000 Federal Oil & Gas Lease Numbers

Existing Jacobs Ranch Mine Federal Coal Leases

Jacobs Ranch Mine Permit Boundary

Conventional Gas - Plugged and Abandoned West Jacobs Ranch LBA Tract as Applied for

CBNG - Plugged and Abandoned

CBNG - Shut-In

CBNG - Producing

Oil - Dry Hole

Oil - Plugged & Abandoned

Oil - Producing

Oil - Shut-In

Note: Well locations and status were derived from a download from

the WOGCC website on 5/14/08. (Located by 1/4 1/4 for clarity)

OIL & GAS WELL TYPES

West Jacobs Ranch LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-49. Oil and Gas Wells and Oil and Gas Ownership Within the West Jacobs Ranch LBA Tract

Alternatives.

3.0 Affected Environment and Environmental Consequences

3-248 Final EIS, Wright Area Coal Lease Applications
21

2833

16

34

27

22

15

23

26

35

14

25

36

24

13

30

31

19

18

29

32

20

17

2833

21

16

27

34

22

15

35

26

14

23

1324

25

36

6 5 4 3 2 1

4 3 2 1

T.

42

N.

T.

41

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

T.

42

N.

T.

41

N.

WYW67220C

WYW140937

WYW67034

WYW140938

WYW147135

WYW46352

WYW0258354A

WYW156685

WYW67220C

PRIVATEWYW0185974B

WYW67220C

WYW0185974B

NOT POSTED

WYW43652

WYW0100872A

WYW75680

WYW0100872A

WYW0100872

WYW151157

WYW4315

WYW45702A

WYW50066

WYW050890

NOT POSTED

WYW096554

WYW151157

WYW27703

WYW042736C

WYW151156

WYW163611

WYW042736B

WYW042736

WYW093721

WYW163611

WYW093721

WYW042736

WYW042736B

WYW093721C

WYW093721

WYW163611

WYW093721

WYW093721A

WYW095594

WYW095594B

PRIVATE

WYW093721

WYW147135

WYW095594A

PRIVATE

PRIVATE

North Antelope Rochelle Mine Permit BoundaryNorth Porcupine LBA Tract as Applied for

LEGEND

3000 6000 12000 0

GRAPHIC SCALE (FEET)

Oil & Gas Ownership Boundaries

WYW00000

Existing North Antelope Rochelle Mine Federal Coal Leases

North Porcupine LBA Tract Under Alternative 2,BLM's Preferred AlternativeFederal Oil & Gas Lease Numbers

CBNG - ProducingCBNG - Shut-InConventional Gas - Plugged and AbandonedConventional Gas - ProducingOil - ProducingOil - Plugged & Abandoned

Note: Well locations and status were derived

from a download from the WOGCC website

on 5/14/08. (Located by 1/4 1/4 for clarity)

OIL & GAS WELL TYPES

Figure 3-50. Oil and Gas Wells and Oil and Gas Ownership Within the North Porcupine LBA Tract

Alternatives.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-249
33

28

34

27

35

26

36

25

31

30

32

29

33

28

30

19

18

7

6

29

20

17

8

5

28

21

16

9

4

28

21

16

9

4

27

22

15

10

3

26

23

14

11

2

25

24

13

12

1

T.

42

N.

T.

41

N.

R. 71 W. R. 70 W.

Converse County

Campbell County

R. 71 W. R. 70 W.

T.

42

N.

T.

41

N.

WYW136875

WYW136941

WYW141205

WYW67219

NOT POSTED

WYW141205

WYW144681

WYW143931

WYW48385

WYW128995

PRIVATE

WYW141205

WYW138118

WYW143508

WYW141205

WYW141206

WYW140769

WYW130033

South Porcupine LBA Tract as Applied for

North Antelope Rochelle Mine Permit Boundary

LEGEND

0 3000 6000 12000

GRAPHIC SCALE (FEET)

Oil & Gas Ownership Boundaries

WYW00000 Federal Oil & Gas Lease Numbers

OIL & GAS WELL TYPES

South Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Existing North Antelope Rochelle Mine Federal Coal Leases CBNG - Shut-In

CBNG - Producing

Oil - Plugged & Abandoned

Conventional Gas - Producing

Note: Well locations and status were derived

from a download from the WOGCC website

on 5/14/08. (Located by 1/4 1/4 for clarity)

Figure 3-51. Oil and Gas Wells and Oil and Gas Ownership Within the South Porcupine LBA Tract

Alternatives.

3.0 Affected Environment and Environmental Consequences

3-250 Final EIS, Wright Area Coal Lease Applications
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-251 

Table 3-16. North Hilight Field LBA Tract Federal Oil and Gas Lessees of 

Record. 

Location Lease Number Lessees of Record 

T.44N., R.70W.

Section 17; Lots 9, 10, 15, 16 

Section 19; Lots 7, 8, 10, 15, 18 

Section 20; Lots 1, 2, 7-10, 15 

Section 21; Lots 1, 8-10, 15, 16 

WYW005305 Citation 2002 Investment LP 

Key Production Co., Inc. 

M&K Oil Co., Inc. 

Section 18; Lots 7-10, 15-17 WYW007750 ExxonMobil Oil Corp. 

Kerr McGee O&G Onshore LP 

Marathon Oil Co. 

Section 18; Lot 18 WYW014503 Patina Oklahoma Corp. 

Primary Natural Resources, Inc. 

Section 20; Lot 16 WYW005306 Citation 2002 Investment LP 

Key Production Co., Inc. 

M&K Oil Co., Inc. 

Section 22; Lots 4, 11, 13 WYW032195 APD Energy Co., LP 

Citation 2002 Investment LP 

Derby Energy LLC 

Kennedy, George C. 

Key Production Co., Inc. 

Langham Petrol Expl 

Meagher O&G Properties, Inc. 

Oilfield Salvage & Service Co. 

Pip Energy IV-80 

Unruh, Dean 

Section 22; Lots 8, 9, 14, 15 Compt. OG --- 

T.44N., R.71W.

Section 13; Lots 3-6 

Section 14; Lot 1 

WYW003063 Inexco Oil Co. 

Merit Energy Partners III 

Merit MGMT Partners I LP 

Section 13; Lots 11-14 

Section 24; Lots 1, 2 

WYW103392 CTV O&G Multi-State, LLC 

Inexco Oil Co. 

Key Production Co., Inc. 

M&K Oil Co., Inc. 

Questar Expl and Prod Co. 

Section 14; Lot 2 WYW091135 Primary Natural Resources, Inc. 

Section 14; Lots 3, 4 WYW144475 Bill Barrett CBM, LLC 

Section 24; Lots 7, 8 WYW0249938A CTV O&G Multi-State, LLC 

M&K Oil Co., Inc. 

Questar Expl and Prod Co. 

Note: From BLM Oil and Gas Plats (dated 09/07/07 & 12/17/07). The oil and gas rights 

(including CBNG) and coal rights for the above locations are owned by the federal 

government. For the rest of the LBA tract, the oil and gas rights (including CBNG) are 

privately owned, and the coal rights are federally owned. 
3.0 Affected Environment and Environmental Consequences 

3-252 Final EIS, Wright Area Coal Lease Applications

Table 3-17. South Hilight Field LBA Tract Federal Oil and Gas Lessees of 

Record. 

Location Lease Number Lessees of Record 

T.42N., R.71W.

Section 1; Lots 7-10 WYW143940 Lance O&G Co., Inc. 

Williams Prod RMT Co. 

Section 1; Lots 15-18 WYW147833 Five Star Energy, LLC 

Lance O&G Co., Inc. 

Williams Prod RMT Co. 

Section 2; Lots 5, 6, 11-14, 19, 20 WYW145841 Petro Canada Res (USA) Inc. 

Section 2; Lots 7-10, 15-18 WYW030501 Coleman Oil & Gas, Inc. 

T.43N., R.71W.

Section 23; Lots 10-15 

Section 26; Lots 1, 2, 7-10, 15, 16 

Section 35; Lots 1, 2, 7-9, 16 

WYW140940 Western Gas Resources, Inc. 

Section 23; Lots 1-9, 16 

Section 35; Lots 11-14 

Restricted 

Minerals 

--- 

Section 35; Lots 10, 15 Unleased Oil & 

Gas 

--- 

Section 35; Lots 3-6 WYW143686 Jolen Operating Co. 

Lance O&G Co., Inc. 

Williams Prod RMT Co. 

Note: From BLM Oil and Gas Plats (dated 09/07/07 & 12/14/07). The oil and gas rights 

(including CBNG) and coal rights for the above locations are owned by the federal 

government. For the rest of the LBA tract, the oil and gas rights (including CBNG) are 

privately owned, and the coal rights are federally owned. 

Table 3-18. West Hilight Field LBA Tract Federal Oil and Gas Lessees of 

Record. 

Location Lease Number Lessees of Record 

T.43N., R.71W. 

Section 8; Lots 2, 7-10, 15, 16 WYW143686 Jolen Operating Co. 

Lance O&G Co., Inc. 

Williams Prod RMT Co. 

Section 8; Lots 1 

Section 9; Lots 1-12, 14-16 

Section 10; Lot 1 

Section 17; Lots 1, 2, 4, 5, 7, 8, 

12, 13 

WYW095702 Explorers Petro Corp. 

Harvey E. Yates Co. 

Heyco Employees LTD. 

Spiral, Inc. 

Section 8; Lots 3-6, 11-14 

Section 20; Lots 1, 2, 7-10, 15, 16 

WYW036006 CTV O&G Multi-State, LLC 

Deputy Robert W. 

Devon Energy Prod Co. 

Farley, Thomas H. Jr. 

GF Collins Jr. Trust 

Key Production Co., Inc. 

Questar Expl and Prod Co. 

RBC Expl & Product Co. 

Ryder Stilwell Oil 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-253 

Table 3-18. West Hilight Field LBA Tract Federal Oil and Gas Lessees of 

Record (Continued).

Location Lease Number Lessees of Record 

T.43N., R.71W.

Section 8; Lots 3-6, 11-14 

Section 20; Lots 1, 2, 7-10, 15, 16 

(Continued) 

WYW036006 

(Continued) 

St Mary Land & Exploration Co. 

Stadelman, Diana L. 

Stadelman, Joseph R. 

WP Properties Corp. 

Section 9; Lot 13 WYW029941 Hilcorp Energy, LP 

Section 10; Lots 2, 7-10, 15, 16 Unleased Oil & 

Gas

--- 

Section 10; Lots 3, 4 WYW150372 Lance O&G Co., Inc. 

Williams Prod RMT Co. 

Section 10; Lots 5, 6 WYW142058 Bill Barrett CBM, LLC 

Section 10; Lot 12 WYW135567 Western Gas Resources, Inc. 

Section 10; Lot 13 WYW132212 EOG Resources, Inc. 

Section 20; Lots 3, 6, 11-14 Restricted 

Minerals

--- 

Section 20; Lot 5 

Section 22; Lots 11, 14 

WYW140773 Western Gas Resources, Inc. 

Section 21; Lots 11, 14 

Section 27; Lots 3-6, 11-14 

Section 28; Lots 2-7, 10-12, 14, 

15 

WYW124456 Explorers Petro Corp. 

Harvey E. Yates Co. 

Heyco Employees LTD 

Spiral, Inc. 

Section 21; Lots 9, 10, 15, 16 WYW140939 Western Gas Resources, Inc. 

Section 21; Lots 4, 5, 12, 13 WYW143062 CH4 Energy, LLC 

Western Gas Resources, Inc. 

Williams Prod RMT Co. 

Section 28; Lots 1, 8, 9, 16 

Section 34; Lots 1, 2, 7-10, 15, 16 

WYW096875 Lance O&G Co. Inc. 

Note: From BLM Oil and Gas Plat (dated 12/14/07). The oil and gas rights (including 

CBNG) and coal rights for the above locations are owned by the federal government. 

For the rest of the LBA tract, the oil and gas rights (including CBNG) are privately 

owned, and the coal rights are federally owned. 

Table 3-19. West Jacobs Ranch LBA Tract Federal Oil and Gas Lessees of 

Record. 

Location Lease Number Lessees of Record 

T.43N., R.71W.

Section 3; Lots 2, 5-14, 18, 19 WYW095702 Explorers Petro Corp. 

Harvey E. Yates Co. 

Heyco Employees LTD 

Spiral, Inc. 

Section 3; Lots 16, 17 WYW142057 Bill Barrett CBM, LLC 

Section 3; Lot 15 

Section 4; Lots 7, 8 

WYW150372 Lance O&G Co., Inc. 

Williams Prod RMT Co. 

Section 4; Lots 5, 6, 11, 12 WYW133562 EOG Resources, Inc. 

Section 4; Lots 9, 10 WYW139066 Western Gas Resources, Inc. 

Williams Prod RMT Co. 
3.0 Affected Environment and Environmental Consequences 

3-254 Final EIS, Wright Area Coal Lease Applications

Table 3-19. West Jacobs Ranch LBA Tract Federal Oil and Gas Lessees of 

Record (Continued).

Location Lease Number Lessees of Record 

T.44N., R.71W.

Section 15; Lots 11-14 

Section 22; Lots 3-6 

Section 34; Lots 3-6, 9, 10, 15, 16 

WYW132214 Western Gas Resources, Inc. 

Section 30; Lots 5, 12, 13, 20 

Section 34; Lots 11-14 

WYW143510 Jolen Operating Co. 

Lance O&G Co., Inc. 

Williams Prod RMT Co. 

Section 31; Lots 5, 12 WYW118520 Sawyer, Paul F. 

Section 31; Lots 13, 20 Not Posted 

Note: From BLM Oil and Gas Plats (dated 09/07/07 & 12/14/07). The oil and gas rights 

(including CBNG) and coal rights for the above locations are owned by the federal 

government. For the rest of the LBA tract, the oil and gas rights (including CBNG) are 

privately owned, and the coal rights are federally owned. 

Table 3-20. North Porcupine LBA Tract Federal Oil and Gas Lessees of 

Record. 

Location Lease Number Lessees of Record 

T.42N., R.70W.

Section 19; Lots 13, 20 WYW093721C Bill Barrett Corp. 

Darius Oil Properties, LLC 

Powder River Coal, LLC 

Section 19; Lots 9, 12, 14, 19 

Section 20; Lots 9, 16 

WYW093721 Bill Barrett Corp. 

El Paso E&P Co., LP 

Kaiser-Francis Oil 

Kerr McGee O&G Onshore LP 

Merit Energy Partners III 

Merit Partners LP 

Section 19; Lots 16, 17 

Section 20; Lots 8, 10, 15 

WYW163611 Bill Barrett Corp. 

Section 20; Lots 5, 11, 14 WYW042736 Bill Barrett Corp. 

Darius Oil Properties, LLC 

Powder River Coal, LLC 

Section 20; Lots 6, 12, 13 WYW042736B El Paso E&P Co., LP 

Mach Petro, Inc. 

Powder River Coal, LLC 

Section 20; Lot 7 WYW151156 ABO Petro Corp. 

Myco Industries, Inc. 

Sharbro Oil LTD Co. 

Yates Drilling Co. 

Yates Petroleum Corp. 

Section 21; Lots 3-6, 11-14 WYW042736C Bill Barrett Corp. 

Section 21; Lots 1, 2 

Section 22; Lots 3-6 

WYW027703 Bill Barrett Corp. 

Conrad, Clayton 

Jouflas, George P. 

Section 22; Lots 9, 10, 15, 16 WYW096554 Mobil Expl & Prod 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-255 

Table 3-20. North Porcupine LBA Tract Federal Oil and Gas Lessees of 

Record (Continued).

Location Lease Number Lessees of Record 

T.42N., R.70W.

Section 21; Lots 7-10, 15, 16 

Section 22; Lots 11-14 

Section 27;Lots 9-16 

WYW151157 ABO Petro Corp. 

Myco Industries, Inc. 

Sharbro Oil LTD Co. 

Yates Drilling Co. 

Yates Petroleum Corp. 

Section 26; Lots 13, 14 WYW045702A Brazos LTD Partnership 

Petroleum, Inc. 

Whiting Oil & Gas 

Section 26; Lots 3-6, 11, 12 WYW050066 DNR O&G, Inc. 

Section 26; Lots 9, 10, 15, 16 WYW004315 Berenergy Corp. 

Daven Corp. 

Sport Resources, Inc. 

Zab, Inc. 

Zalman Res, Inc. 

Section 27; Lot 4 Not Posted --- 

Section 27; Lots 1-3, 5-8 WYW050890 Mobil Expl & Prod 

Section 29; Lots 1-3 WYW0100872 Powder River Coal, LLC 

Section 29; Lot 4 

Section 30; Lot 6 

WYW0100872A Damson Oil Corp. 

Powder River Coal, LLC 

Stalls, Clark F. 

Section 30; Lot 5 WYW075680 Powder River Coal, LLC 

T.42N., R.71W.

Section 22; Lots 5, 6, 11-14 WYW140938 Bill Barrett Corp. 

Section 22; Lots 7-10, 15, 16 

Section 27; Lots 9, 10, 15, 16 

WYW147135 Bill Barrett Corp. 

Section 23; Lots 7, 8 WYW095594B Bill Barrett Corp. 

Klabzuba Oil and Gas 

Section 23; Lots 9, 10, 16 

Section 24; Lots 11-14 

WYW095594 Devon Energy Prod Co. LP 

F&H Schultz Trst 

Klabzuba, Robert 

Schultz Mgmt LTD 

Section 23; Lots 11-14 WYW0258354A Bill Barrett Corp. 

Section 23; Lot 15 WYW095594A Bill Barrett Corp. 

Section 23; Lots 5, 6 

Section 25; Lots 1, 2 

WYW043652 Citadel Energy, Inc. 

Key Production Co., Inc. 

Powder River Coal, LLC 

St Mary Land & Exploration, Co. 

Section 24; Lots 10, 15 WYW093721A Independent Prod Co. 

Section 24; Lots 11-14 WYW095594 Devon Energy Prod Co. LP 

F&H Schultz Trst 

Klabzuba, Robert 

Schultz Mgmt LTD 
3.0 Affected Environment and Environmental Consequences 

3-256 Final EIS, Wright Area Coal Lease Applications

Table 3-20. North Porcupine LBA Tract Federal Oil and Gas Lessees of 

Record (Continued).

Location Lease Number Lessees of Record 

T.42N., R.71W.

Section 24; Lots 9, 16 WYW093721 Bill Barrett Corp. 

El Paso E&P Co., LP 

Kaiser-Francis Oil 

Kerr McGee O&G Onshore LP 

Merit Energy Partners III 

Merit Partners LP 

Section 25; Lots 3, 4 Not Posted --- 

Section 26; Lots 1, 2 

Section 35; Lots 3-6 

WYW185974B Devon Energy Prod Co. LP 

Powder River Coal, LLC 

Reunion Energy Co. 

Section 26; Lots 3, 4 WYW156685 Powder River Coal, LLC 

Section 27; Lots 3-6, 11-14 WYW067034 ExxonMobil Oil Corp. 

Section 27; Lots 1, 2, 7, 8 

Section 34; Lots 1-8 

Section 35; Lots 11-14 

WYW67220C Axel Johnson Expl. 

Black Hills Expl & Prod Inc. 

DeLoyd Cook Estate 

Ladd, Jerry D. 

Meyer Oil Co Inc. 

Whiting Oil & Gas Corp. 

Wright, Dale O. 

Section 34; Lots 9-16 WYW140937 Bill Barrett Corp. 

Note: From BLM Oil and Gas Plats (dated 09/07/07 & 09/20/07). The oil and gas rights 

(including CBNG) and coal rights for the above locations are owned by the federal 

government. For the rest of the LBA tract, the oil and gas rights (including CBNG) are 

state or privately owned, and the coal rights are federally owned. 

Table 3-21. South Porcupine LBA Tract Federal Oil and Gas Lessees of 

Record. 

Location Lease Number Lessees of Record 

T.41N., R.70W.

Section 7; Lots 7-10, 15-18 Not Posted --- 

Section 18; Lots 6, 11, 14, 19 WYW143931 Powder River Coal, LLC 

Section 18; Lots 7-10, 15-18 WYW144681 Powder River Coal, LLC 

T.41N., R.71W.

Section 1; Lots 7-10, 15-18 WYW136875 Rubenstein, Kathleen A. 

Section 1; Lots 5, 6, 11, 12 WYW136941 Powder River Coal, LLC 

Section 10; Lot 9 WYW130033 ABO Petro Corp. 

Lance O&G Co., Inc. 

Myco Industries, Inc. 

Sharbro Oil LTD Co. 

Williams Prod RMT Co. 

Yates Drilling Co. 

Yates Petroleum Corp. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-257 

Table 3-21. South Porcupine LBA Tract Federal Oil and Gas Lessees of 

Record (Continued).

Location Lease Number Lessees of Record 

T.41N., R.71W.

Section 11; Lots 11, 12, 14 WYW128995 ABO Petro Corp. 

Lance O&G Co., Inc. 

Myco Industries, Inc. 

Williams Prod RMT Co. 

Yates Drilling Co. 

Yates Petroleum Corp. 

Section 11; Lots 9, 10, 15, 16 

Section 12; Lots 1, 2, 4-8, 11-14 

Section 13; Lots 1-10, 15, 16 

WYW048385 Key Production Co., Inc. 

St. Mary Land & Exploration Co. 

Section 12; Lot 3 WYW067219 Liberty Petroleum Corp. 

Universal Fuels Co. 

West Trend Res Corp. 

Section 13; Lots 12-14 WYW138118 Yates Petroleum Corp. 

Section 14; Lots 9, 16 WYW140769 Lance O&G Co., Inc. 

Williams Production RMT Co. 

Section 1; Lots 13, 14, 19, 20 

Section 12; Lots 9, 10, 15, 16 

Section 13; Lot 11 

Section 23; N1⁄2 Lot 8 

WYW141205 Williams Production RMT Co. 

Section 23; Lot 1 WYW141206 Williams Production RMT Co. 

Section 24; Lots 2-4, N1⁄2 Lots 5-7 WYW143508 Five Star Energy, LLC 

Williams Production RMT Co. 

Note: From BLM Oil and Gas Plats (dated 09/06/07 & 02/27/08). The oil and gas rights 

(including CBNG) and coal rights for the above locations are owned by the federal 

government. For the rest of the LBA tract, the oil and gas rights (including CBNG) are 

privately owned, and the coal rights are federally owned. 

permanently abandoned injector holes, and one was a dry hole. Of the 42 wells 

capable of producing (inclusive of the nine shut-in wells), 16 have economically 

recoverable reserves. Seven of these 16 wells are located on private leases. 

Within these six LBA tract study areas, approximately 79 percent of the 74 

permitted conventional oil and gas wells were drilled between 1967 and 1980, 

and no conventional oil or gas wells have been drilled since 1990. The 

conventional oil and gas wells located in the BLM study areas for these six LBA 

tracts that are capable of production are listed in Appendix E. 

The Supreme Court has ruled that the coal bed natural gas (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 

tracts. According to the WOGCC records as of May 14, 2008, there were 287 

permitted CBNG wells on lands included within the BLM study areas for these 

six LBA tracts (Figures 3-46 through 3-51). Of these 287 CBNG wells, 212 

were producing, 36 were shut-in, 32 were permanently abandoned, and seven 

were dry holes. Extensive CBNG development has also occurred on lands 
3.0 Affected Environment and Environmental Consequences 

3-258 Final EIS, Wright Area Coal Lease Applications

surrounding the LBA tracts, especially to the west. CBNG wells capable of 

production on or in sections adjacent to the LBA tracts are listed in 

Appendix E. 

Additional information on the conventional oil and gas and CBNG development 

in the general Wright analysis area 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, there are some oil and 

gas production facilities, primarily oil and gas pipelines, on the LBA tracts, as 

discussed in Section 3.15 of this EIS. Additional support facilities might not be 

constructed on the LBA tracts because conventional oil and gas and CBNG well 

development has likely reached a peak due to exhausted reserves and 

diminished production. 

Coal mining is the predominant land use in the general Wright analysis area. 

The applicant mines (Black Thunder, Jacobs Ranch, and North Antelope 

Rochelle) are part of a group of contiguous surface coal mines located in 

Campbell County (Figure 1-1). Coal production from the three applicant mines 

increased by 58 percent between 1998 and 2007 (from approximately 136.4 

million tons in 1998 to 215.8 million tons in 2007). Of the 19 federal coal 

leases issued in the PRB since decertification of the federal coal region, nine 

(Jacobs Ranch, West Black Thunder, North Antelope/Rochelle, Powder River, 

Thundercloud, North Jacobs Ranch, NARO South, Little Thunder, and NARO 

North) have been issued within this group of three mines. The currently 

pending North Hilight Field, South Hilight Field, West Hilight Field, West 

Jacobs Ranch, North Porcupine, and South Porcupine lease applications 

evaluated in this EIS are in this group of mines (Tables 1-1 and 1-2). 

The City of Gillette/Campbell County Comprehensive Planning Program (City of 

Gillette 1978) was finalized by the city of Gillette and Campbell County in June 

1978. The 1978 plan was updated in March 1994 and both plans provide 

general land use goals and polices for state and federal coal leases in the 

county. These documents emphasized local government involvement in state 

and federal government decisions and plans. On August 21, 2007, the 

Campbell County Natural Resource and Land Use Plan (the Plan) was adopted. 

The Plan was developed by a diverse cross section of county residents 

appointed by the Board of Campbell County Commissioners and it focuses on 

planning for growth and development in the county (Campbell County 2007). 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-259 

The Plan describes the local environment, natural resources, and industries 

within the county. It defines the social and economic conditions, and the 

Plan’s intent is for Campbell County’s values to be taken into consideration in 

any state or federal agency action which falls under NEPA requirements. There 

are no provisions for zoning in the Plan, and the proposed lease areas do not 

have designated zoning classifications. 

Big game hunting is the principal recreational land use within the general 

Wright analysis area, and pronghorn, mule deer, and white-tailed deer are 

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 2 to 3 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 2007a). 

In general, publicly owned lands (i.e., USFS 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 approximately 12,642.8 acres of public surface lands within the BLM 

study areas for the North Hilight Field, South Hilight Field, West Hilight Field, 

West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts 

(Figures 3-40 through 3-45 and Table 3-14). A majority of the public surface 

lands (12,480.7 acres) are associated with the TBNG, which is administered by 

the USFS. Approximately 7,288 acres of the public surface lands within the 

BLM study areas for these six LBA tracts are within the current mine permit 

boundaries or are surrounded by private lands and thus may be inaccessible to 

the public. 

Specific details regarding big game herd management objectives within and 

near the general Wright analysis area are contained in Wyoming Game and 

Fish Department’s (WGFD’s) 2007 Big Game Herd Unit Job Completion Reports 

for the Casper and Sheridan Regions (WGFD 2007a). The WGFD classifies the 

entire general Wright analysis area as yearlong and winter/yearlong habitat for 

antelope. No crucial or critical pronghorn habitat is recognized by the WGFD 

in this area. WGFD definitions of big game ranges are included in Section 

3.10.2.1. The proposed lease areas are within pronghorn Hunt Area 24 (north 

of Highway 450), which is contained in the Hilight Herd Unit, and pronghorn 

Hunt Area 27 (south of Highway 450), which is contained in the Cheyenne 

River Herd Unit. In post-season 2007, the population of the Hilight Herd Unit 

was estimated to be approximately 12,397 animals, which is above the WGFD 

objective of 11,000, and the population of the Cheyenne River Herd Unit was 
3.0 Affected Environment and Environmental Consequences 

3-260 Final EIS, Wright Area Coal Lease Applications

estimated to be 55,287, which is above 45 percent above the WGFD objective of 

38,000 animals (WFGD 2007a). 

Historical problems associated with the management of the Hilight Herd Unit 

include hunter access, over harvest on limited public lands, and quantifying 

landowner preferences and desires. Prior to 1997, the herd population was 

fairly stable and near the objective of 11,000 antelope. Losses from severe 

winters, poor production rates, and disease subsequently decreased the 

population; however, the herd has recently recovered and since 2005 it has 

been slightly above the objective level. Hunt Area 24 contains mostly privately 

owned surface lands with poor hunter access to limited publicly owned lands; 

therefore, the number of antelope 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 area. Nearly all landowners 

charge access fees for hunting and private land access is based on the desires 

and perceptions of the landowners. Some portions of the herd unit are leased 

to outfitters, which makes areas more expensive and restrictive with regards to 

access. Increased harvest may also be difficult to achieve because of the 

increased CBNG development, which is limiting rifle hunting on associated 

lands. Assuming most licenses are sold and given the predicted harvest, the 

2008 post-season population was expected to be 12,129 antelope (WGFD 

2007a). 

Between 1995 and 2001, 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 herd objective 

was surpassed in 2005 and continues to grow. Hunt Area 27 contains mostly 

privately owned surface lands (roughly 77 percent of the herd unit is private 

land) with poor hunter access to limited publicly owned lands. Given 

inadequate access to private lands, WGFD’s inability to sell all issued licenses, 

and the uneven distribution of animals throughout the area, managing this 

herd is difficult and the number of pronghorn is expected to steadily increase. 

Nearly all landowners either charge access fees for hunting or lease their land 

to outfitters. In addition, an increased harvest may be difficult to achieve 

because of the increased CBNG development, which is limiting rifle hunting on 

associated lands. The 2007 post-season population estimate was 45 percent 

above the objective. While WGFD significantly increased license issuance in 

2008, the estimated harvest assumes many remain unsold and the 2008 postseason population was expected to be 53,142 antelope (WGFD 2007a). 

The WGFD has classified the general Wright analysis area as yearlong and 

“OUT” mule deer use range (the OUT designated areas do no 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 Wright analysis area. The general Wright analysis 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-261 

area is located within WGFD mule deer Hunt Areas 10 and 21, part of the 

Thunder Basin Mule Deer Herd Unit, which also includes mule deer Hunt 

Areas 7, 8, 9, and 11. 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 and decreasing hunting 

opportunity on private lands. Reducing the number of licenses issued and 

length of hunting season in Hunt Area 10 has reduced hunter pressure on 

public lands within this herd unit. The population of this herd reached 

objective in 2000 and since 2002 it has grown on average 9 percent per year. 

The 2007 post-season objective for this mule deer herd was 20,000 and the 

population was estimated at 20,980. WGFD believes the herd should be 

reduced to or below the objective population because of drought-related forage 

conditions; however, limited sales and use of certain types of licenses and 

insufficient harvest of deer from private land may hamper the ability to reduce 

the population through hunting. Given average herd productivity and climatic 

conditions, the 2008 post-season population is expected to increase to 22,265 

animals (WGFD 2007a). 

White-tailed deer are not managed separately by WGFD, but are managed and 

hunted in conjunction with mule deer. The population occupying Hunt Areas 

10 and 21 is part of the Central White-tailed Deer Herd Unit. White-tailed deer 

are seldom observed within the general Wright analysis area due to their 

preference for riparian woodlands and irrigated agricultural lands. WGFD 

classifies the entire general Wright analysis area, with the exception of a 

narrow corridor along Antelope Creek, as OUT white-tailed deer use range. The 

narrow corridor along the Antelope Creek is classified as yearlong range. There 

is no population model for this herd. 

The general Wright analysis area is within Elk Hunt Areas 113 and 123 of the 

Rochelle Hills Herd Unit. The Rochelle Hills Elk Herd resides in the Rochelle 

Hills, which are located immediately east of the three applicant mines. The 

herd favors the ponderosa pine/juniper woodlands, savanna, and steeper 

terrain habitat offered by the Rochelle Hills. As more lands are reclaimed from 

coal mining adjacent to the Rochelle Hills, elk are shifting their winter use to 

these areas. Such lands typically offer excellent winter grass supplies, 

especially during more severe winters when other sites are less accessible. Elk 

are presently using the reclaimed mine lands of the Jacobs Ranch, Black 

Thunder, and North Antelope Rochelle mines. The WGFD has designated an 

approximately five square mile area on reclaimed lands within the Jacobs 

Ranch Mine permit area as crucial winter habitat for the Rochelle Hills elk herd 

(Odekoven 1994). Rio Tinto Energy America (RTEA), the previous owner of the 

Jacobs Ranch Mine, and the Rocky Mountain Elk Foundation (RMEF) finalized 

a formal agreement that created the Rochelle Hills Conservation Easement. 

The easement contains nearly 1,000 acres, with 75 percent of that area 

comprised of reclaimed mining lands on the Jacobs Ranch Mine. The 

easement acreage was donated to RMEF by RTEA to ensure that the reclaimed 
3.0 Affected Environment and Environmental Consequences 

3-262 Final EIS, Wright Area Coal Lease Applications

land continues to be used as grazing land and wildlife habitat for the extended 

future (RMEF 2007). 

Much of the occupied range of the Rochelle Hills Elk Herd is located on the 

TBNG, which is administered by the USFS. Elk Hunt Areas 113 and 123 

contain crucial winter, parturition, winter-yearlong, yearlong, OUT, and 

undecided/unknown use ranges. Hunting in Areas 113 and 123 has been 

permitted every two or three years, allowing very good bull quality for this herd; 

many of which have scored in the official record books. Some landowners 

within Hunt Areas 113 and 123 had, in previous years, allowed free public 

access for much of the season, although in more recent years, trespass or 

outfitting fees have become more common, particularly for antlered elk. The 

current postseason population objective for this herd is 400 elk. For postseason 2007, the estimated herd size was approximately 600, with a probable 

range of between 600 and 800 animals. Elk have been observed dispersing 

from the designated herd boundary, due to behavioral or habitat limitations. 

Habitat conditions in recent years have been poor throughout this herd unit 

and elk appear to have moved out of the rougher hills habitats and into the 

lowlands habitat in search of adequate forage. As a result, the majority of the 

elk in Hunt Area 123 are found in the northeastern portions of the area and 

almost entirely on private land (WGFD 2007a). No elk have been observed 

recently within any of the LBA tracts, but have been reported near the Hilight 

Road by area landowners. The public enjoy observing these elk along Highway 

450 and within accessible USFS lands; thus they also provide for nonconsumptive recreational use opportunities. 

Under natural conditions, aquatic habitat is very limited by the ephemeral 

nature of surface waters in the general Wright analysis area; therefore, public 

fishing opportunities are likewise 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. There are currently no fisheries on the asapplied-for LBA tracts. However, Little Thunder Reservoir, an in-channel 

impoundment on Little Thunder Creek, is located within the BLM’s West 

Hilight Field study area (Figure 3-29). The reservoir is located on TBNG 

surface and is managed as a warm water sport fishery by the USFS. Local 

residents use the reservoir year-round for fishing, camping, and recreational 

shooting. WGFD stocked the reservoir with catchable rainbow trout from 2004 

through 2006. Upon an evaluation, they found that is was well-stocked with 

bullheads and small mouth bass that could maintain themselves. They plan 

another evaluation in the summer of 2009 with the idea of maintaining active 

management of the fishery. Access to the reservoir is across private surface 

owned by TBCC (Figures 3-29 and 3-42); however, USFS has an easement over 

this land that allows legal public access to the reservoir. 

Water discharged from CBNG wells from within and upstream of the general 

Wright analysis area has temporarily enhanced the water supply within some 

drainages, particularly Little Thunder Creek, North Prong Little Thunder Creek, 

and Porcupine Creek, and increased potential habitat for some aquatic species. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-263 

For example, there are no historical monitoring records of Little Thunder 

Reservoir’s water levels. Anecdotally, local residents and mine personnel recall 

this reservoir held only a fraction of its volume capacity prior to groundwater 

discharges from CBNG development in the Little Thunder Creek drainage above 

the impoundment, which began in the mid- to late-1990s. Anecdotal evidence 

also indicates that the reservoir was rarely used for recreational fishing prior to 

CBNG development in the area. CBNG production and the related surface 

discharge of groundwater are expected to decrease over time. As a result, 

regular inflow of water to the Little Thunder Reservoir will diminish over time, 

the naturally-occurring low water volume stored in the reservoir will resume, 

and the impoundment may not function as it currently does as a fishery. 

Sage-grouse, mourning dove, waterfowl, rabbit, and coyote are hunted in the 

general vicinity, and some coyote and red fox trapping may occur. 

3.11.2 Environmental Consequences

3.11.2.1 Proposed Action and Alternatives 2 and 3

The major adverse environmental consequences of leasing and mining the West 

Hilight Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, North 

Porcupine, and South Porcupine LBA Tracts with respect to land use would be 

the temporary reduction of livestock grazing, incremental loss of wildlife habitat 

(particularly big game), and curtailment of oil and gas development while the 

areas are being mined and reclaimed. This would include removal of all 

existing oil and gas surface and downhole production and transportation 

equipment and facilities. Livestock grazing, and to a lesser extent wildlife use, 

would be displaced while the tracts are being mined and reclaimed. Access for 

recreational and other activities (i.e., ranching, oil and gas development) would 

be restricted during mining operations. The loss of accessibility to lands 

successfully leased and proposed for mining is long term (during mining and 

reclamation), but not permanent. 

Approximately 12,481 acres of TBNG surface that are currently permitted for 

federal grazing by the TBGA would be suspended during mining and 

reclamation operations. This suspension would result in an additional seven 

allotments that would no longer be available for grazing, one allotment that 

would be reduced by approximately 50 percent, and three allotments that 

would have small reductions in grazing for a total of approximately 2,890 

AUMs lost from TBGA, or 4 percent of the total grazing agreement. Estimated 

disturbance areas for the North Hilight Field, South Hilight Field, West Hilight 

Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts 

under the Proposed Action and Alternative 2, BLM’s preferred alternative 

configuration for each tract, are presented in Tables 3-1 through 3-6, 

respectively. These reductions in combination with past impacts from mining 

would result in an additional three grazing members that would no longer have 

allotments to graze, one member that would have grazing allotments reduced 

by 65 percent, one member that would have grazing allotments reduced by 50 
3.0 Affected Environment and Environmental Consequences 

3-264 Final EIS, Wright Area Coal Lease Applications

percent, and one member that is minimally impacted. While the TBGA could 

potentially provide relief to some of its members impacted by mining through 

the possible allocation of other vacant allotments if they are available, TBGA 

cannot totally recover these losses, especially in combination with past losses. 

Often, lost AUMs ultimately result in a net loss to the member and the TBGA 

and negatively impact the ranchers that were allocated those AUMs for their 

livestock operations. 

Since the onset of mining in this portion of the PRB, approximately 44,000 

acres of federal surface administered by the USFS within 20 allotments have 

been impacted by mining through mining of leases, overstripping for mining, or 

ancillary facilities. This has resulted in a loss of approximately 10,200 AUMs 

from the TBGA. Combined with grazing losses from the current mining 

operations, the loss of grazing the lands successfully leased and proposed for 

mining would result in a total reduction of approximately 13,090 AUMs, or 18 

percent of the TBGA grazing agreement. While these suspensions are 

considered temporary, they are nevertheless long term. Since the beginning of 

mining in this area in approximately 1980, none of the lands permitted for 

grazing to the TBGA have reached final bond release and been returned for use 

under the TBGA grazing agreement. Thirty years equates to three terms of the 

grazing agreement and at least one generation of ranchers that are unable to 

graze their livestock on these lands. As previously described, for five TBGA 

members, the loss of TBNG grazing use due to the leasing and subsequent 

mining of the WAC LBA tracts could cause serious impacts to their livestock 

operations and family ranches. 

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 in the BLM study areas for these six LBA tracts. Well location 

information, federal oil and gas ownership, and federal oil and gas lessee 

information are presented in Figures 3-46 through 3-51 and Tables 3-15 

through 3-20. 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 allow development of both resources on portions of the LBA 

tract. Producing conventional oil and gas and CBNG wells are present on all 

six of these LBA tracts. In the PRB, royalties have been and would be lost to 

both the state and federal governments if conventional oil and gas wells are 

abandoned prematurely, if the federal CBNG is not recovered prior to mining, 

or if federal coal is not recovered due to conflicts. State and federal 

governments can also lose bonus money when the costs of the agreements 

between the lessees are factored into the fair market value determinations. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-265 

As discussed above, the North Hilight Field, South Hilight Field, West Hilight 

Field, North Porcupine, and South Porcupine LBA Tracts configured under 

Alternative 2, BLM’s preferred alternative, include approximately 12,481 acres 

of TBNG surface, which is administered by the USFS; approximately 7,288 

acres of which are currently accessible to the public. According to the USFS 

Douglas Ranger District, each mine can close access in areas that are actively 

mined for human health and safety reasons (Homuth 2003). The loss of access 

to federal lands is long term (during mining and reclamation), but is not 

permanent. If the USFS-administered lands are leased for coal mining, loss of 

public access could potentially extend for 20 years or more depending on 

individual mine plans, mine variation in coal production rates, permitting 

requirements, and reclamation sequence and succession. Public access to 

federal lands would be restored after mining and reclamation are complete. 

Hunting on the LBA tracts, including the federal surface discussed above, 

would be eliminated during mining and reclamation. Pronghorn and mule deer 

have been observed on and adjacent to the LBA tracts, as have sage-grouse, 

mourning doves, waterfowl, rabbits, and coyotes. 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. 

None of the lands included in the West Jacobs Ranch LBA Tract under 

Alternative 2 are managed by the USFS; thus, no federal lands would be 

removed from public access if this LBA tract were leased. 

Public access to Little Thunder Reservoir, which is located on federal surface, 

would be eliminated during mining and reclamation of the West Hilight Field 

LBA Tract configured under Alternative 2. Hunting, fishing, camping and 

recreational activities afforded by the impoundment would be suspended 

during mining and reclamation operations. 

TBCC permitted and constructed Pronghorn Lake, located in T.43N., R.70W., 

Section 27 (Figure 3-29), as a postmining public recreational facility. This 

permanent postmining impoundment, which is located on land owned by USFS 

and TBCC, currently functions as storage for dust suppression water used on 

the Black Thunder Mine site. Pronghorn Lake is located within an active 

portion of the mine’s permit area, and as such, safety concerns for the general 

public preclude access to the reservoir for the current time and the foreseeable 

future. Plans are for Pronghorn Lake to become available as a public 

recreation area for fishing and other activities once it no longer serves a 

function for the mining operation. The recreational activities provided by Little 

Thunder Reservoir could be replaced by those provided by Pronghorn Lake; 

however, the time at which Pronghorn Lake becomes accessible to the general 

public may not coincide with the time at which Little Thunder Reservoir 

becomes inaccessible. 

Following reclamation, the land would be suitable for grazing by domestic 

livestock and wildlife uses, which are the historic land uses. The reclamation 

standards required by the federal Surface Mining Control and Reclamation Act 
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3-266 Final EIS, Wright Area Coal Lease Applications

of 1977 (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 

(USFS). 

3.11.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and coal removal and associated 

disturbance and impacts to land use and recreation would not occur on the 

portions of the LBA tracts as applied for or the LBA tracts configured under 

Alternative 2 that will not be disturbed under the currently approved surface 

coal mining permits. Coal removal and associated surface disturbance and 

impacts to land use and recreation would continue as currently permitted on 

the existing Black Thunder, Jacobs Ranch and North Antelope Rochelle Mine 

permit areas. Impacts to land use related to mining operations at these three 

applicant mines would not be extended onto portions of the LBA tracts that will 

not be affected under the current mining and reclamation plans. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective tract in the future. 

3.11.3 Regulatory Compliance, Mitigation and Monitoring

Mined areas would be reclaimed as specified in the approved mine and 

reclamation plan to support the anticipated post-mining land uses of rangeland 

and wildlife habitat, which are premining land uses. The reclamation 

procedures would include stockpiling and redistributing soil, using reclamation 

seed mixtures approved by WDEQ, and replacing recreational and livestock 

reservoirs. 

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 

approved 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. 

For those ranching operations that would be seriously impacted by the loss of 

grazing allotments through the TBGA on federal surface administered by the 

USFS, a potential exists for the grazing association, affected TBGA members, 

USFS, and mine operators to partner and collaborate in addressing the issue. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-267 

As a consolidated stakeholder group, potential solutions to help mitigate the 

adverse affects could be developed. 

Section 3.3.2.3 includes the 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, which are protected under the National Historic 

Preservation Act of 1966, are nonrenewable remains of past human activity. 

The PRB, including the general Wright 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. 

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. These periods are defined by the years before the present time (B.P.). 

Frison’s chronology is listed below. The Plains designation within the Early, 

Middle, and Late Archaic periods has been omitted from the list. 

• 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 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 
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3-268 Final EIS, Wright Area Coal Lease Applications

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 cornernotched dart points characteristic of the Late Archaic period are replaced by 

smaller corner- and side-notched points for use with the bow and arrow. 

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 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. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-269 

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 their 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). Early ranches established in the 

region surrounding the general Wright analysis area as of 1883 include the 

Ritchie Ranch, the McCray Ranch, and the 6 Ranch. Later arrivals to the area 

(as of 1908) include the Grant Ranch on Hay Creek, the Rooney Ranch on 

Rawhide Creek, and the Gardner and Wilson Ranches on the Little Powder 

River. The specific project area of Site 48CA3378 was homesteaded by George 

Oedekoven in 1917, and his family still maintains the property today. Site 

48CA1918 was homesteaded by Bert Herrod in 1919. This homestead has 

been abandoned since at least 1983. 

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 well-organized 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 
3.0 Affected Environment and Environmental Consequences 

3-270 Final EIS, Wright Area Coal Lease Applications

decreased, indicating the shift to livestock raising (LeCompte and Anderson 

1982). 

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. In 1934, the Agricultural 

Adjustment Administration began studying portions of Converse, Campbell, 

Weston, Niobrara, and Crook counties. In all, 2 million acres, including about 

560,000 acres of federal owned lands, 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 (USFS 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 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-271 

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 National 

Register of Historic Places (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 consultation with the State Historic Preservation 

Office (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, site-specific 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 that 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 

an LBA tract is leased, full consultation with the SHPO will 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 literature and records reviews 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 Wright analysis area. 

The general analysis areas of the North Hilight Field, South Hilight Field, West 

Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA 

Tracts (defined as the LBA tract as applied for, the additional area evaluated 

under Alternative 2, plus a 1⁄4-mile disturbance buffer) have been mostly 

surveyed for cultural resources at a Class III level. These areas include all 

anticipated areas of disturbance assuming the coal is mined by the existing 

adjacent mines. Currently, Class III inventory is needed on 160 acres within 

the general analysis area for the South Hilight Field tract, 480 acres within the 

general analysis area for the West Jacobs Ranch tract, and 58 acres within the 

general analysis area for the South Porcupine tract. The inventories must be 

completed, along with agency review and SHPO consultation, prior to the 

signing of a record of decision to hold a competitive lease sale for the LBA tract 

in question. 
3.0 Affected Environment and Environmental Consequences 

3-272 Final EIS, Wright Area Coal Lease Applications

3.12.1.1 North, South, and West Hilight Field LBA Tracts

Cultural resource inventories in this area began in the early 1980s and 

continued with numerous projects associated with oil and gas field 

development as well as surface mining operations throughout the 1990s and 

2000s. TBCC contracted with GCM Services, Inc. of Butte, Montana to perform 

literature and records reviews and Class III surveys of the North, South, and 

West Hilight Field LBA Tracts and surrounding areas in the summer of 2007, 

which completed the Class III level inventory of the entire general analysis 

areas for the North, South, and West Hilight Field LBA Tracts. At this time, the 

only portion that does not meet current Class III standards is 160 acres within 

Section 2, T.42N., R.71W. within the South Hilight Field tract. That area was 

surveyed in 1980; however, BLM does not recognize surveys prior to 1985 as 

adequate, nor was the report ever reviewed by a federal agency or by SHPO. No 

federal decisions can be made based on such an old survey or report. 

A total of 59 cultural sites have been documented in the North Hilight Field 

general analysis area. Of these, 41 are prehistoric, 16 are historic, and two are 

multi-component sites consisting of both prehistoric and historic elements. 

Prehistoric sites consist primarily of lithic scatters, cairns, stone circles, and 

campsites. Historic sites consist primarily of homesteads and trash dumps. 

Twenty-three of the previously recorded sites have been determined not eligible

for the NRHP by the agency with SHPO concurrence. Eight of the prehistoric 

sites have been determined to be eligible for the NRHP by the agency with 

SHPO concurrence. Twenty-eight of the previously recorded sites are 

considered unevaluated for eligibility by the agency, and all will require further 

work including historic documentation, updated site recording, and additional 

subsurface testing in order for the agency to make an eligibility determination 

and consult with SHPO. 

A total of 36 cultural sites have been documented in the South Hilight Field 

general analysis area. Of these, 18 are prehistoric, 12 are historic, and six are 

multi-component sites. Prehistoric sites consist primarily of lithic scatters and 

campsites. Historic sites consist primarily homesteads and trash dumps. 

Twenty-three of the previously recorded sites have been determined not eligible

for the NRHP by the agency with SHPO concurrence. Thirteen of the previously 

recorded sites are considered unevaluated by the agency and all will require 

further work including historic documentation, updated site recording, and 

additional subsurface testing in order for the agency to make an eligibility 

determination and consult with SHPO. There are no NRHP-eligible sites 

documented in the general analysis area for the South Hilight Field LBA Tract 

at this time. 

A total of 79 cultural sites have been documented in the West Hilight Field 

general analysis area. Of these, 56 are prehistoric, 17 are historic, and six are 

multi-component. Prehistoric sites consist primarily of lithic scatters and 

campsites. Historic sites consist primarily of homesteads and trash dumps. 

Forty-nine of the previously recorded sites have been determined not eligible for 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-273 

the NRHP by the agency with SHPO concurrence. One of the prehistoric sites 

has been determined to be eligible for the NRHP by the agency with SHPO 

concurrence. Twenty-nine of the previously recorded sites are considered 

unevaluated for eligibility by the agency, and all will require further work 

including historic documentation, updated site recording, and additional 

subsurface testing in order for the agency to make an eligibility determination 

and consult with SHPO. 

In summary, a total of 174 cultural sites have been documented in the general 

analysis areas for the North, South, and West Hilight Field LBA Tracts. Of 

these, 138 sites were previously recorded and identified during record 

searches. An additional 36 sites were located during the 2007 inventories of 

the remaining unsurveyed lands in the entire general analysis areas for the 

North, South, and West Hilight Field LBA Tracts. Of the 174 total cultural 

sites, nine sites have been determined to be eligible for the NRHP by the agency 

with SHPO concurrence. Those nine sites must be avoided or a mitigation plan 

approved and implemented prior to any disturbance. There are a total of 70 

sites currently considered unevaluated for the NRHP, which will require 

additional documentation, formal testing, or evaluation in order for the agency 

to make an eligibility determination and consult with SHPO. Unevaluated sites 

are given the same protections as eligible sites and are to be avoided until a 

determination of eligibility has been made. There are 95 sites that have been 

determined not eligible for the NRHP and no further work is required at these 

sites. 

3.12.1.2 West Jacobs Ranch LBA Tract

Cultural resource inventories in this area began in 1975 and continued with 

numerous projects associated with oil and gas field development as well as 

surface mining operations throughout the 1990s and 2000s. JRCC contracted 

with GCM Services, Inc. of Butte, Montana to perform literature and records 

reviews and Class III surveys of the West Jacobs Ranch LBA Tract and 

surrounding areas in 2006 and 2007. At this time, the only portion of the tract 

that does not meet current Class III standards is 480 acres within Section 16, 

T.44N., R.71W. That area was surveyed in 1980; however, BLM does not 

recognize surveys prior to 1985 as adequate, nor was the report ever reviewed 

by a federal agency or by SHPO. No federal decisions can be made based on 

such an old survey or report. 

The literature and records review of the general analysis area for the West 

Jacobs Ranch LBA Tract identified 24 previously recorded, documented 

cultural sites, while 23 new cultural properties were identified during the Class 

III surveys. Of these 47 total sites, 22 are historic, 14 are prehistoric, one 

contains both historic and prehistoric components, and 10 sites are rock 

cairns of indeterminate age and cultural affiliation. The historic sites consist 

primarily of homesteads and include a ranch complex and a stock herder’s 

camp. The prehistoric sites consist of lithic scatters, stone circles or tipi ring 

sites, and rock cairns. The multi-component site consists of an historic corral 
3.0 Affected Environment and Environmental Consequences 

3-274 Final EIS, Wright Area Coal Lease Applications

complex and a prehistoric rock alignment. Newly recorded sites include 11 

historic sites, three prehistoric sites, and nine rock cairns of indeterminate age 

and cultural affiliation. 

Eight of these 24 previously recorded cultural properties have not been 

reviewed and evaluated by the lead agency or SHPO in terms of their NRHP 

eligibility. All 24 of these unevaluated properties require further 

documentation or subsurface testing. Of the 24 previously recorded sites, 15 

have been reviewed and determined not eligible for the NRHP by the agency 

with SHPO concurrence. There is one site within the tract’s 1⁄4-mile 

disturbance buffer zone considered eligible for the NRHP. Significance 

determinations for the newly recorded sites, all of which have been 

recommended not eligible by the contractor, will have to be made by the lead 

agency and SHPO consulted. All unevaluated sites and sites that have not 

received lead agency and SHPO review will be treated as if they are eligible for 

the NRHP. 

3.12.1.3 North and South Porcupine LBA Tracts

Cultural resource inventories in this area began in the early 1980s and 

continued with numerous projects associated primarily with surface mining 

operations, as well as with oil and gas field development, through 2005. The 

entire general analysis area for the North Porcupine LBA Tract has been 

previously surveyed for cultural resources at a Class III level. Approximately 

58 acres of Class III inventory is still needed in the South Porcupine LBA Tract 

in Section 7, T.41N., R.70W., and Section 14, T.41N., R.71W. 

A total of 66 cultural sites have been documented in the North Porcupine tract 

general analysis area. Of these, 36 are prehistoric, 20 are historic, and 10 are 

multi-component sites. Prehistoric sites consist primarily of lithic scatters, 

cairns, stone circles, and campsites. Historic sites consist primarily of 

homesteads and associated remains. All inventory results have been reviewed 

by either BLM or OSM and submitted to SHPO, who concurred with the 

recommendations on site eligibility for the NRHP. Test excavations were 

carried out at some sites and will need to be carried out at others. A total of 

four prehistoric sites (campsites) and two of the multi-component sites have 

been determined eligible for the NRHP by SHPO. Two sites remain unevaluated 

for the NRHP including one prehistoric site that needs to be recorded to current 

standards. The other 58 sites have been determined not eligible for the NRHP 

and no further work is required at these sites. 

A total of 46 cultural sites have been documented in the South Porcupine 

general analysis area. Of these, 30 are prehistoric, 14 are historic, and two are 

multi-component. Prehistoric sites consist primarily of lithic scatters and 

campsites. Historic sites consist primarily of homesteads and associated 

remains. Three sites have been determined to be eligible for the NRHP by the 

agency with SHPO concurrence. Those three sites must be avoided or a 

mitigation plan approved and implemented prior to any disturbance. Only one 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-275 

site is currently considered unevaluated for the NRHP, which will require 

additional documentation, formal testing, or evaluation in order for the agency 

to make an eligibility determination and consult with SHPO. The other 42 sites 

have been determined not eligible for the NRHP and no further work is required 

at these sites. 

In summary, a total of 112 cultural sites have been documented in the general 

analysis areas for the North and South Porcupine LBA Tracts. All 112 sites 

were previously recorded and were identified during record searches that were 

conducted by PRC in 2008. However, approximately 58 acres of the South 

Porcupine LBA Tract still requires Class III inventory. Of the 112 cultural sites 

documented in the entire general analysis areas for the North and South 

Porcupine LBA Tracts, 66 are prehistoric, 34 are historic, and 12 are multicomponent sites. A total of 17 homestead sites, all dating back to the early 

1900s, are located within the general analysis areas for the North and South 

Porcupine LBA Tracts. Of the homestead sites, 12 are located within the 

general analysis area for the North Porcupine tract, four are located within the 

general analysis area for the South Porcupine tract, and portions of one 

homestead are located on both general analysis areas. Either BLM or OSM 

have reviewed the cultural resource inventories covering most of the general 

analysis areas for the North and South Porcupine LBA Tracts and have 

submitted the results to SHPO. SHPO has concurred with the 

recommendations finding nine sites (six in the North Porcupine tract general 

analysis area and three in the South Porcupine tract general analysis area) 

eligible for the NRHP. Three of the previously recorded sites are considered 

unevaluated for eligibility by the agency and those sites will require further 

work including historic documentation, updated site recording, and additional 

subsurface testing in order for the agency to make an eligibility determination 

and consult with SHPO. There are 100 sites that have been determined not 

eligible for the NRHP and no further work is required at these sites. 

3.12.2 Environmental Consequences

3.12.2.1 Proposed Action and Alternatives 2 and 3

Data recovery plans are required for all sites recommended eligible to the 

National Register following testing and consultation with the SHPO. Until full 

consultation with the SHPO has been completed and agreement regarding 

NRHP eligibility has been reached, all sites shall be protected from disturbance. 

Consultation with the 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 shall not 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. 
3.0 Affected Environment and Environmental Consequences 

3-276 Final EIS, Wright Area Coal Lease Applications

Any eligible sites on the North Hilight Field, South Hilight Field, West Hilight 

Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts 

that cannot be avoided or that have not already been subjected to data recovery 

action would be carried forward in the mining and reclamation plans 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 outside of but adjacent to mine 

permit areas during mine related activities are the most frequent impacts to 

cultural resources. 

3.12.2.2 No Action Alternative

Under the No Action Alternative for each of the LBA tracts, the coal lease 

application would be rejected and coal removal and the associated disturbance 

and impacts would not occur on the portions of the LBA tract as applied for or 

the LBA tract configured under Alternative 2 that will not be disturbed under 

the currently approved surface coal mining permits. Coal removal and 

associated surface disturbances would continue as currently permitted on the 

existing Black Thunder, Jacobs Ranch, and North Antelope Rochelle Mine 

permit areas. Potential impacts to cultural resources related to mining 

operations at these three applicant mines would not be extended onto portions 

of the LBA tracts that will not be affected as a result of recovering the 

remaining coal in the existing leases under the current mining and reclamation 

plans. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective 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 Wright analysis 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-277 

area. However, the geographic position of the general Wright 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 tracts in 

this analysis. Their help has been requested in identifying potentially 

significant religious or cultural sites in the general analysis areas for the North 

Hilight Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, North 

Porcupine, and South Porcupine LBA Tracts before a leasing decision is made 

on any 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. 

3.12.4 Regulatory Compliance, Mitigation and Monitoring

Literature and records reviews and Class III surveys are conducted to identify 

cultural properties on all lands affected by federal undertakings. Prior to 

mining, the 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 are avoided or, if avoidance is not possible, a data 

recovery plan is implemented prior to disturbance. 

Mining activities are monitored during topsoil stripping operations. If a lease is 

issued for the North Hilight Field, South Hilight Field, West Hilight Field, West 

Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts, BLM would 

attach a stipulation to each 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 are destroyed by surface coal mining operations but, as a result 

of the intensive pedestrian inventories, site evaluations, and excavation and 

analysis of cultural resources discussed above, there is a more informed 
3.0 Affected Environment and Environmental Consequences 

3-278 Final EIS, Wright Area Coal Lease Applications

understanding of what types of past human activity exist in the region and a 

better understanding of local prehistory. 

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 do not receive any further work after recordation is completed. 

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 and around 

the general Wright analysis area are characterized by a gently rolling 

topography and large, open expanses of sagebrush and short-grass prairie, 

which are common throughout the PRB. There are also areas of altered 

landscape, such as oil and gas fields and surface coal mines. The existing 

active surface mines that are located on the eastern side of the PRB form three 

geographic groups that are separated by areas with no mining operations 

(Figure 1-1). Two of the groups of surface mines are located east of Highway 59 

from south of Gillette to south of Wright, a distance of about 50 miles; the third 

mine group is located on the east side of U.S. Highway 14-16 from Gillette 

north for about 13 miles. Other man-made intrusions on the natural 

landscape in the general Wright analysis area include oil and gas development 

(oil well pumpjacks, pipeline and utility ROWs, water storage reservoirs, access 

roads, CBNG well shelters, and natural gas compressor stations), 

transportation facilities (public and private roads, road signage, power and 

utility transmission lines, and railroads), ranching activities (fences, ranch 

buildings, livestock, and abandoned homesteads), and environmental 

monitoring installations. The natural scenic quality in and near the general 

Wright analysis area is fairly low because of the industrial nature of the 

adjacent existing mining operations and oil and gas field development. 

The Visual Resource Management (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 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. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-279 

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 Resource Management Plan (RMP) revision (BLM 2001) 

covers the general Wright analysis area. It retained and carried forward the 

VRM inventory from the 1985 Buffalo RMP (BLM 1985). At this time, the lands 

included in the general Wright analysis area continue to be managed in 

accordance with the VRM classes established in 1981, and the predominant 

VRM class is Class IV. 

Approximately 12,481 acres (or 34 percent) of the surface of these LBA tracts 

configured under Alternative 2, BLM’s preferred alternative for each tract, is 

part of the TBNG, which is administered by the USFS. The USFS has 

established scenic integrity objectives for the TBNG. In the general Wright 

analysis area, the scenic integrity objective is low. A low scenic integrity 

objective refers to landscapes where the value landscape character appears 

moderately altered. In this area, facilities and landscape modifications may be 

visible but should be reasonably mitigated to blend and harmonize with 

natural features according to USFS’s revised Land and Resource Management 

Plan (LRMP) for the TBNG (USFS 2001). 

Currently, mine facilities and mining activities at the Jacobs Ranch, Black 

Thunder, North Antelope Rochelle, and Antelope mines are visible from various 

public-use roads in the general Wright analysis area, including State Highway 

450, Jacobs Road, Shroyer Road, Keeline Road, Hilight Road, Edwards Road, 

Reno Road, Antelope Road, Mackey Road, and Matheson Road. 

3.13.2 Environmental Consequences

3.13.2.1 Proposed Action and Alternatives 2 and 3

Some mining activities on the North, South and West Hilight Field LBA Tracts 

would be visible from State Highway 450, a major travel route that borders the 

West Hilight Field tract. Some of the existing mining operations at the Black 

Thunder and Jacobs Ranch mines are currently visible from this highway. 

Some mining activities on the West Jacobs Ranch LBA Tract would be visible 

from State Highway 450, which borders the tract. Portions of the West Hilight 

Field and West Jacobs Ranch tracts may also be visible from State Highway 59, 
3.0 Affected Environment and Environmental Consequences 

3-280 Final EIS, Wright Area Coal Lease Applications

which is from about 2 to 5 miles east of the tracts. Not all of the mining 

activities on these four LBA tracts would be visible from these major highways 

because of the rolling terrain. Portions of these four LBA tracts would also be 

visible from Keeline Road, Jacobs Road, Shroyer Road, Hilight Road, Edwards 

Road, Reno Road, and Matheson Road. 

Some mining activities on both the North and South Porcupine LBA Tracts 

would be visible from Antelope Road and Matheson Road. Some mining 

activities on the North Porcupine tract would also be visible from the Edwards 

Road, Reno Road, and Mackey Road. Some of the existing mining operations at 

the North Antelope Rochelle Mine are currently visible from these public roads. 

Due to the existing mining activities in the general Wright analysis area, the 

predominant BLM VRM class is Class IV. This classification would not be 

altered by the leasing and subsequent mining of the six LBA tracts under any 

of the Action Alternatives. After reclamation of the LBA tracts and adjoining 

mines, the VRM Class IV conditions would be improved and the reclaimed land 

would resemble the surrounding undisturbed terrain. The USFS scenic 

integrity objectives for the general Wright analysis area allow facilities and 

landscape modifications to be visible, but call for reasonable mitigation to 

blend and harmonize with natural features. No visual resources that are 

unique to this area have been identified on or near the North Hilight Field, 

South Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, 

and South Porcupine LBA Tracts. 

Reclaimed terrain would be almost indistinguishable from the surrounding 

undisturbed terrain. Slopes might appear smoother (less intricately dissected) 

and gentler (less steep) 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 North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and coal removal and associated 

disturbance and impacts to visual resources would not occur on potions of the 

LBA tracts as applied for or the LBA tracts configured under Alternatives 2 or 3 

that will not be disturbed under the currently approved surface coal mining 

permits. The additional acres that would be disturbed under the Proposed 

Action or Alternative 2, BLM’s preferred alternative for each tract, would not 

change the current VRM Class IV designation for those lands. Currently 

approved mining operations would continue on the existing Black Thunder, 

Jacobs Ranch, and North Antelope Rochelle Mine leases. Impacts to visual 

resources related to mining operations at these mines would not be extended 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-281 

onto portions of the LBA tracts that will not be affected under the current 

mining and reclamation plan. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective tract in the future. 

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 Sections 3.2 and 3.9 for additional discussion of the regulatory 

requirements, mitigation, and monitoring for topography and vegetation, 

respectively. 

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 Wright analysis area include coal mining 

activities, rail traffic, traffic on nearby state highways, county roads and access 

roads, natural gas compressor stations, and wind. 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 (A-weighted decibel). 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 3-52 presents noise levels 

associated with some commonly heard sounds. 

In 2004, Matheson Mining Consultants, Inc. conducted a noise survey at the 

two occupied locations closest to the existing Antelope Mine operations. The 

Antelope Mine is located adjacent to the South Porcupine LBA Tract (Figure 1-

1). Measurements were taken at a residence located directly west of the 

Antelope Mine on State Highway 59 and at the Dyno Nobel West Region office
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 3-52. Relationship Between A-Scale Decibel Readings and Sounds of Daily Life.

3.0 Affected Environment and Environmental Consequences

3-282 Final EIS, Wright Area Coal Lease Applications
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-283 

located northeast of the Antelope Mine on Campbell County Road 4 (Antelope 

Road). The Dyno Nobel office is located within the southern portion of the 

South Porcupine LBA Tract (Figure 3-18). The maximum daily time weighted 

(Leq) noise reading at the residence was 51 dBA, which is comparable to that of 

a normal office, 50 feet in the distance. The maximum measured Leq at the 

Dyno Nobel office was 52.6 dBA, which is equivalent to the noise level of an 

average office environment (BLM 2008d). 

No site-specific noise level data are available for the other proposed coal lease 

areas included in this analysis; therefore, the current median noise level is 

estimated to be 40-60 dBA for day and night, with the noise level increasing 

with proximity to the currently active mining operations. Mining activities are 

characterized by noise levels of 85-95 dBA at 50 feet from actual mining 

operations and activities (BLM 1992). 

OSM prepared a noise impact report for the Caballo Rojo Mine (OSM 1980) that 

determined that the noise level from crushers and a conveyor would not exceed 

45 dBA at a distance of 1,500 feet. The air overpressure created by blasting is 

estimated to be 123 dBA at the location of the blast. At a distance of 

approximately 2,500 feet (0.47 mile), the intensity of this blast would be 

reduced to 55 dBA. Under the authority of the Noise Control Act of 1972, EPA 

designates 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 (EPA 1974). 

Figures 3-9 through 3-11 depict the occupied residences and active businesses 

located within 3 miles of the North, South, and West Hilight Field LBA Tracts, 

respectively. Figure 3-14 depicts the occupied residences and active 

businesses within 3 miles of the West Jacobs Ranch LBA Tract. Figures 3-17 

and 3-18 depict the locations of active businesses (no occupied residences 

exist) within 3 miles of the North Porcupine and South Porcupine LBA Tracts, 

respectively. The distances from each LBA tract to the nearest occupied 

dwelling are given in Table 3-22. 

3.14.2 Environmental Consequences

3.14.2.1 Proposed Action and Alternatives 2 and 3

Noise levels on the LBA tracts would be increased considerably by mining 

activities such as blasting, loading, hauling, and possibly in-pit crushing. The 

BNSF & UP rail line currently borders and/or traverses all six LBA tracts; 

therefore, rail traffic noise on the tracts would continue to be proportionate to 

the rate of coal production from the PRB mines in the future. Due to the 

remoteness of the LBA tracts and because mining is already ongoing in the 

area, noise would have few off-site impacts. 

A noise level below 55 dBA does not constitute an adverse impact (EPA 1974). 

Any occupied dwelling within 2,500 feet of active mining (particularly blasting) 
3.0 Affected Environment and Environmental Consequences 

 3-284 Final EIS, Wright Area Co

Table 3-22. Noise Impacts Associated with Mine Blasting on the Wright Area LBA Tracts. 

Number of Dwellings 

Within 3 Miles 

Number of Dwellings Within 

2,500 Feet 

LBA Tract1

Single 

Family 

Multiple 

Residences2

Single 

Family 

Multiple 

Residences2

Distance to 

Closest 

Dwelling 

(feet) 

Max

Noise L

Clo

Dwe

(d

North Hilight Field 20 2 

45 0 0 12

South Hilight Field 1 0 0 0 15,840 3

West Hilight Field 8 

24 0 0 5,280 4

West Jacobs Ranch 29 24 36 0 0 12

North Porcupine 0 0 0 0 -- South Porcupine 0 0 0 0 -- 

1 Configured under Alternative 2, BLM’s preferred alternative. 2 Multiple occupied residences and/or businesses exist closely together. 3 I: Impacts anticipated. 

 N: No impact anticipated (24-hour equivalent level of less than 55 dBA). 4 Includes the developed area around the town of Wright. 

5 Two residences are located within the LBA tract and two are located adjacent to the LBA tract. 6 All three residences are located within the LBA tract. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-285 

would experience adverse noise impacts. If the tracts are leased under 

Alternative 2, BLM’s preferred alternative for each tract, the potential blasting 

related noise impacts associated with mining are presented in Table 3-21. The 

five occupied dwellings that are located within the tracts (two within the North 

Hilight Field LBA Tract and three within the West Jacobs Ranch tract) would be 

vacated prior to advancing mining activities. No occupied dwellings would 

experience adverse noise impacts from mining activities if the South Hilight 

Field, West Hilight Field, North Porcupine, and South Porcupine LBA Tracts are 

leased as applied for or under Alternative 2. The two occupied dwellings that 

are located immediately adjacent to the North Hilight Field tract (Figure 3-9), 

would experience adverse noise impacts if mining activities (particularly 

blasting) occur within 2,500 feet of them. 

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. 

Guidelines were developed by the FS to prevent or limit noise impacts to 

wildlife on the TBNG, which include the following: 

• To help prevent reproductive failure, limit noise on sage-grouse display 

grounds from nearby facilities and activities to 49 dBA (10 dBA above 

background noise) from March 1 to June 15. 

• Prohibit development or operations of facilities within 2 miles of a sagegrouse display ground if these activities would exceed a noise level of 

more than 10 dBA above the background noise level (39 dBA), at 800 feet 

from the source, from March 1 to June 15. 

The occurrence of sage-grouse within the 2-mile wildlife study areas for each of 

the Wright area LBA tracts, and the effects of mining the proposed lease areas 

are discussed in Section 3.10.5 and Appendix H of this EIS. Two of the 

currently occupied sage-grouse leks that have been documented within the six 

combined wildlife survey areas are located on the BLM study areas for the 

North Hilight Field and North Porcupine LBA Tracts and are therefore likely to 

be directly impacted if these two tracts are leased and mined under the 

Proposed Action and/or Alternative 2, BLM’s preferred alternative. Noise 

impacts to those two leks (Hansen Lakes and Payne) would occur prior to 

surface disturbance of the display grounds by mining operations (topsoil 

salvage). The only other currently occupied leks in the general Wright analysis 

area (Kort I and Kort II) are located roughly 1.5 miles southeast of the North 

Porcupine LBA Tract and would therefore likely experience noise impacts from 

blasting if the tract is leased and mined. However, active mining operations at 

the North Antelope Rochelle Mine are presently closer to these two active leks 

than the boundary of the North Porcupine LBA Tract. All other leks that have 

been documented in the general Wright analysis area are currently classified as 

either unoccupied or undetermined and will probably not be re-occupied due to 

the presence of nearby CBNG development and/or mining activities. 
3.0 Affected Environment and Environmental Consequences 

3-286 Final EIS, Wright Area Coal Lease Applications

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 North Hilight Field, South Hilight Field, 

West Jacobs Ranch, North Porcupine, and South Porcupine coal lease 

applications would be rejected and coal removal and associated noise would 

not occur on the portions of the LBA tracts as applied for or the LBA tracts 

configured under Alternative 2 that will not be disturbed under the currently 

approved surface coal mining permits. Coal removal and the associated noise 

would continue on the existing Black Thunder, Jacobs Ranch, and North 

Antelope Rochelle Mine coal leases. Noise impacts related to mining operations 

at these mines would not be extended onto portions of the LBA tracts that will 

not be affected under the current mining and reclamation plans. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective tract in the future. 

3.14.3 Regulatory Compliance, Mitigation and Monitoring

Mine operators are required to comply with Mine Safety and Health 

Administration (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. 

3.15 Transportation

3.15.1 Affected Environment

Transportation resources within the general Wright analysis area include State 

Highways 450 and 59, numerous improved two-lane county roads, several 

improved and unimproved local roads and accesses, numerous two-track trails, 

the Gillette-Douglas rail line used jointly by BNSF & UP Railroads, mine 

railroad spurs, oil and gas pipelines, utility/power lines, telephone lines, and 

associated ROWs. Figures 3-53 through 3-55 depict the current transportation 

facilities, excluding pipelines, within and near the North, South, and, West 

Hilight Field LBA Tracts, the West Jacobs Ranch LBA Tract, and the North and 

South Porcupine LBA Tracts, respectively. Figure 3-56 through 3-58 depict the 

existing pipelines (oil, gas and water) within and near the North, South, and, 

West Hilight Field LBA Tracts, the West Jacobs Ranch LBA Tract, and the 

North and South Porcupine LBA Tracts, respectively. 
19

18

7

19

18

7

20

17

8

21

16

9

22

15

10

23

14

11

24

13

12

19

18

7

20

17

8

21

16

9

22

15

10

23

14

11

24

13

12

R. 71 W. R. 70 W.

Road Jacobs

Hilight Road

Keeline Road

Shroyer

Road

30

31

30

32

29

33

28

34

27

35

26

36

25

31

30

32

29

33

28

34

27

35

26

36

25

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

30

19

18

7

7

6

8

5

9

4

10

3

11

2

12

1

7

6

8

5

9

4

10

3

11

2

12

1

7

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

State

Antelope

Edwards

Matheson Road

Reno Road

Hilight

Road

Highway 450

State

450 Highway

Road

Road

Small Road

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Black Thunder Mine Permit Boundary

Existing Black Thunder

Mine Federal Coal Leases

LEGEND

Overhead Electric

Telephone Tower

North Hilight Field LBA Tract as Applied for

West Hilight Field LBA Tract as Applied for

South Hilight Field LBA Tract as Applied for

BNSF & UP Rail Line

DM & E Proposed Rail Line

North Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

South Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA Tract Under Alternative 3

West Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-53. Transportation Facilities Within and Adjacent to the North, South, and West Hilight Field LBA

Tracts.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-287
Keeline

Road Jacobs

Hilight Road Hilight Road

Road

Keeline Road

Road

State

450

Highway

State Highway 450

Shroyer

Small

Road

31

30

32

29

33

28

34

27

35

26

36 31 32

29

33

28

34

27

35

26

36

25

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

25

24

13

12

36

25

24

13

12

T.

45

N.

T.

44

N.

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

T.

45

N.

T.

44

N.

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

LEGEND

Existing Jacobs Ranch Mine Federal Coal Leases

Jacobs Ranch Mine Permit Boundary

West Jacobs Ranch LBA Tract as Applied for

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Electric Corridor

BNSF & UP Rail Line

DM & E Proposed Rail Line

West Jacobs Ranch LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-54. Transportation Facilities Within and Adjacent to the West Jacobs Ranch LBA Tract.

3.0 Affected Environment and Environmental Consequences

3-288 Final EIS, Wright Area Coal Lease Applications
28

21

16

9

4

27

22

15

10

3

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

31

30

19

18

7

6

32

29

20

17

8

5

31

30

19

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

33

28

21

34

27

22

35

26

23

36

25

24

6

8

5

8 9

4

10

3

11

2 1

6

8

5

9

4

10

3

11

2 1

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

Converse County

Campbell County

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

T.

42

N.

T.

41

N.

Reno Road

Mackey

Antelope

Edwards Reno Road

School Creek

Hilight

Road

Road

Road

Road

Antelope Road

Road

Mackey Road

MathesonRoad

T.

41

N.

T.

40

N.

T.

41

N.

T.

40

N.

33 34 35 36 31

18

7

6

16

9

4

15

10

3

14

11

2

13

12

1

T.

42

N.

T.

41

N.

Matheson Road

0 5000 10000 20000

GRAPHIC SCALE (FEET)

LEGEND

Existing North Antelope Rochelle

Mine Federal Coal Leases

North Antelope Rochelle Mine Permit Boundary

North Porcupine LBA Tract as Applied for

South Porcupine LBA Tract as Applied for

Overhead Electric

Telephone Corridor

DM & E Proposed Rail Line

BNSF & UP Rail Line

North Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

South Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Figure 3-55. Transportation Facilities Within and Adjacent to the North and South Porcupine LBA Tracts.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-289
BNSF & UP

RR

Road Jacobs

Hilight Road

Keeline Road

State

Antelope

Edwards

Matheson Road

Reno Road

Hilight

Road

Highway 450

State

450 Highway

Road

Road

19

18

7

19

18

7

20

17

8

21

16

9

22

15

10

23

14

11

24

13

12

19

18

7

20

17

8

21

16

9

22

15

10

23

14

11

24

13

12

R. 71 W. R. 70 W.

30

31

30

32

29

33

28

34

27

35

26

36

25

31

30

32

29

33

28

34

27

35

26

36

25

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

30

19

18

7

7

6

8

5

9

4

10

3

11

2

12

1

7

6

8

5

9

4

10

3

11

2

12

1

7

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Black Thunder Mine Permit Boundary

Existing Black Thunder

Mine Federal Coal Leases

LEGEND

North Hilight Field LBA Tract as Applied for

West Hilight Field LBA Tract as Applied for

South Hilight Field LBA Tract as Applied for

North Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

South Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative

West Hilight Field LBA Tract Under Alternative 3

West Hilight Field LBA Tract Under Alternative 2,

BLM's Preferred Alternative Pipeline (Oil, Gas, and/or Water)

Figure 3-56. Pipelines Within and Adjacent to the North, South, and West Hilight Field LBA Tracts.

3.0 Affected Environment and Environmental Consequences

3-290 Final EIS, Wright Area Coal Lease Applications
Keeline

Road Jacobs

BNSF & UP RR

Hilight Road Hilight Road

Road

Keeline Road

Road

State

450

Highway

BNSF & UP RR

State Highway 450

Shroyer

31

30

32

29

33

28

34

27

35

26

36 31 32

29

33

28

34

27

35

26

36

25

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

25

24

13

12

1

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

25

24

13

12

36

25

24

13

12

T.

45

N.

T.

44

N.

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

T.

45

N.

T.

44

N.

T.

44

N.

T.

43

N.

R. 71 W. R. 70 W.

LEGEND

Existing Jacobs Ranch Mine Federal Coal Leases

Jacobs Ranch Mine Permit Boundary

West Jacobs Ranch LBA Tract as Applied for

0 5000 10000 20000

GRAPHIC SCALE (FEET)

BLM's Study Area (Alternative 2)

Pipeline (Oil, Gas, and/or Water)

Figure 3-57. Pipelines Within and Adjacent to the West Jacobs Ranch LBA Tract.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-291
33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

31

30

19

18

7

6

32

29

20

17

8

5

31

30

19

18

7

6

32

29

20

17

8

5

31

30

19

18

7

6

32

29

20

17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

33

28

21

16

9

4

34

27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

6

8

5

8 9

4

10

3

11

2 1 6

8

5

9

4

10

3

11

2 1

T.

42

N.

T.

41

N.

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

Converse County

Campbell County

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

T.

42

N.

T.

41

N.

Reno Road

Mackey

Antelope

Edwards Reno Road

School Creek

Road

Road

Road

Antelope Road

Road

BNSF & UP RR

Matheson Road

Mackey Road

MathesonRoad

T.

41

N.

T.

40

N.

T.

41

N.

T.

40

N.

0 5000 10000 20000

GRAPHIC SCALE (FEET)

LEGEND Existing North Antelope Rochelle

Mine Federal Coal Leases

North Antelope Rochelle Mine Permit Boundary

North Porcupine LBA Tract as Applied for

South Porcupine LBA Tract as Applied for

North Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

South Porcupine LBA Tract Under Alternative 2,

BLM's Preferred Alternative

Pipeline

(Oil, Gas, and/or Water)

Figure 3-58. Pipelines Within and Adjacent to the North and South Porcupine LBA Tracts.

3.0 Affected Environment and Environmental Consequences

3-292 Final EIS, Wright Area Coal Lease Applications
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-293 

The highways and improved county roads provide public and private access 

within the general Wright analysis area. State Highway 59, a paved two-lane 

highway located west of all six LBA tracts, is the major north-south 

transportation corridor, while State Highway 450, also a paved two-lane 

highway, is the principal east-west transportation corridor. Other paved 

county roads, including Hilight Road (Campbell County Road 52), Edwards 

Road (Campbell County Road 30), Reno Road (Campbell County Road 83), and 

Antelope Road (Campbell County Road 4), are also major public transportation 

routes. There are numerous other improved county roads, including Shroyer 

Road (Campbell County Road 116), Matheson Road (Campbell County Road 

70), Mackey Road (Campbell County Road 69), and Keeline Road (Campbell 

County Road 62). Access to the Black Thunder, Jacobs Ranch, and North 

Antelope Rochelle mines, as well as the LBA tracts included in this analysis, is 

primarily from the west (from Highway 59) via State Highway 450 or the 

Edwards/Reno Road. Hilight Road and Antelope Road are the major northsouth public transportation corridors closest to the applicant mines. Some 

improved county roads within active mine permit areas have been vacated by 

the Campbell County Commissioners (i.e., Jacobs Road and Small Road) and 

are therefore no longer accessible to the general public. Unimproved local 

roads and accesses in the area are primarily for private use or public access to 

federal lands. 

The general Wright analysis area presently has one major railroad. The BNSF 

& UP Gillette-Douglas rail line runs north-south along the eastern edge of the 

PRB, roughly parallel to and east of State Highway 59. The coal mines located 

north of Gillette ship most of their coal via the east-west BNSF rail line that 

runs through Gillette for destinations in the Midwest. The coal mines located 

south of Gillette and Wright ship most of their coal via the Gillette-Douglas 

BNSF & UP joint trackage that runs south through Campbell and Converse 

counties and then east over separate BNSF and UP mainlines for destinations 

in the Midwest. Individual spur lines connect each mine to the BNSF track or 

the joint BNSF & UP track. 

The Dakota, Minnesota and Eastern (DM&E) Railroad has proposed an 

expansion into the PRB of Wyoming. If constructed, the DM&E Expansion 

Project would be the largest railroad construction project in the United States 

in the last 100 years (Sheridan Press 2006). If constructed as proposed, the 

DM&E railroad would provide additional rail capacity for those mines located 

south of Gillette. The Surface Transportation Board (STB) completed an EIS 

and gave final approval to the project in 2002. However, in response to a 

successful appeal, the 8th Circuit Court of Appeals directed the STB to give 

further consideration to four environmental issues that were raised. The STB 

issued a Final Supplemental EIS (SEIS) on the expansion project December 30, 

2005, which addressed the four issues that were remanded back to the STB 

with input from various federal agencies, Tribes, organizations, environmental 

groups, businesses, and members of the general public (STB 2006). The issuedriven alignment has been determined and the DM&E rail line would 

potentially be in a position to haul coal produced by the Black Thunder, Jacobs 
3.0 Affected Environment and Environmental Consequences 

3-294 Final EIS, Wright Area Coal Lease Applications

Ranch, and North Antelope Rochelle mines. The STB granted final approval to 

construct the rail line on February 15, 2006. The Final SEIS was also 

appealed, but was upheld by the U.S. Court of Appeals for the Eighth Circuit in 

December 2006. In early September 2007, Canadian Pacific Railway Ltd 

announced the acquisition of DM&E and its subsidiaries (MSNBC 2007). The 

transaction was approved by STB on September 29, 2008. 

3.15.2 Environmental Consequences

3.15.2.1 Proposed Action and Alternatives 2 and 3

Essentially all of the coal mined on the LBA tracts would be transported by rail 

system. Since the North Hilight Field, South Hilight Field, West Hilight Field, 

West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts would 

be an extension of the operating applicant mines, the existing rail facilities and 

infrastructure would be used during mining of the proposed lease areas. 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 North Hilight Field, South Hilight Field, West Hilight Field, West 

Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts. The 

construction of the proposed DM&E Railroad expansion into this area is not 

dependent on leasing one or more of the six LBA tracts. 

As discussed in Chapters 1 and 2, some of the coal included in each of the six 

LBA tracts under both the Proposed Action and Alternative 2, BLM’s preferred 

tract configuration, is overlain by portions of various public roads. SMCRA 

prohibits mining within 100 feet of the outside ROW line of any public road 

unless the appropriate public road authority allows the road to be relocated or 

closed after public notice, an opportunity for a public hearing, and a finding 

that the interests of the affected public and landowners will be protected [30 

CFR 761.11(d)]. As a result, the coal underlying the public road ROWs and 

adjacent buffer zones has been determined to be unsuitable for mining 

according to coal leasing Unsuitability Criterion Number 3 [43 CFR 3461(c)]. 

The coal underlying portions of State Highway 450, Antelope Road, Hilight 

Road, Reno Road, Shroyer Road, Mackey Road, and Matheson Road is included 

in the LBA tracts being considered for leasing because the coal under the roads 

could be mined if the authorized public road authorities determine that the 

roads could be abandoned or relocated [see 43 CFR 3461.5(c)(2)(iii) and 

discussions in Section 2.1]. If the roads are not moved, including the coal 

underlying the public roads in the leases would allow maximum recovery of all 

the mineable coal adjacent to the road ROWs and buffer zones (100 feet on 

either side of the road ROW). 

Stipulations stating that no mining activity may be conducted in the portion(s) 

of the lease within the public road ROW(s) and buffer zone(s) unless the 

authorized public road authorities determine that the road(s) could be 

abandoned or relocated will be attached if a lease is issued for an LBA tract. 

The exclusion from mining by lease stipulation honors the finding of 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-295 

unsuitability under Unsuitability Criterion Number 3. All mining related road 

abandonment and relocation option plans would be reviewed and approved by 

the Campbell County Board of Commissioners (for the Campbell County roads) 

and/or the Wyoming Department of Transportation (for State Highway 450) 

prior to road abandonment and relocation 

Vehicular traffic to and from the mines would continue at existing or slightly 

higher levels for an extended period of time, depending on which LBA tracts are 

leased and which alternatives are selected. 

Pipelines and utility/power transmission lines currently cross the LBA tracts. 

If the tracts are leased and proposed for mining, these pipelines and 

utility/power lines 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. There would be additional surface 

disturbance associated with construction when pipeline is relocated. 

3.15.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Jacobs Ranch, North Porcupine, and South Porcupine coal lease 

applications would be rejected and coal removal and associated effects to 

transportation resources would not occur on the portions of the LBA tracts as 

applied for or the LBA tracts configured under Alternative 2 that will not be 

disturbed under the currently approved surface coal mining permits. Coal 

removal and any associated impacts to transportation resources would 

continue on the existing Black Thunder, Jacobs Ranch, and North Antelope 

Rochelle Mine coal leases. Impacts to transportation resources related to 

mining operations at these mines would not be extended onto portions of the 

LBA tracts that will not be affected under the current mining and reclamation 

plans. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective tract in the future. 

3.15.3 Regulatory Compliance, Mitigation and Monitoring

The regulatory requirements regarding transportation facilities require that no 

public road be relocated unless the appropriate public road authority allows 

the road to be relocated or closed, and 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. 
3.0 Affected Environment and Environmental Consequences 

3-296 Final EIS, Wright Area Coal Lease Applications

3.15.4.1 Coal Loss During Rail Transport

There are potential impacts from sifting and blowing coal dust and fines 

coming off freshly loaded, moving rail cars, which can accumulate along rail 

beds, railroad ROWs, and on adjacent lands. Coal dust can be washed into 

adjacent drainages where it accumulates. Accumulated coal dust has been 

linked to train derailments and can also spontaneously combust and cause 

rangeland wildfires. 

With the opening of the PRB coal field in Wyoming in the late 1970s, U.S. coal 

shipments have grown dramatically from 4.8 million carloads back then to 8.4 

million carloads in 2006 as the railroads deliver low sulfur coal to help electric 

utilities achieve Clean Air Standards (FRA 2008). The largest rail coal 

movements are from the PRB to generating power plants in Illinois, Missouri, 

and Texas (FRA 2008). 

According to the 2001 Final EIS for the DM&E PRB Expansion Project, a 1996 

study conducted in Virginia on metallurgical coal (which is finely crushed and 

has a low moisture content) indicated that 400 to 800 pounds of coal dust and 

fines are typically lost per rail car over a 500-mile trip (STB 2001). Although 

PRB coal is generally transported with larger particles sizes and is higher in 

moisture content, which reduces the amount of coal dust blowing off of moving 

rail cars (STB 2001), it is generally accepted that coal dust is accumulating 

along the rail lines, especially in the first portion of the journey as the loaded 

coal trains leave the mines (UPRR 2005). 

Coal can be lost from rail cars through dust and fines sifting from the rail car 

discharge doors, spillage over the rail car sides, and by being blown from rail 

car tops during transit. In testing conducted by BNSF & UP Railroad and the 

National Coal Transportation Association (NCTA), the average loss of coal from 

an individual rail car’s rapid discharge doors was about 19 pounds per 216 

miles, or 0.09 pounds per mile (NCTA 2007). The same testing indicated that 

an average of 225 pounds of coal was lost from the top of a coal car through 

either top spillage or being blown off during a 567 mile test trip, which equated 

to about 0.40 pounds per mile (NCTA 2007). 

The derailment of two trains in the PRB in 2005 resulted from track instability 

problems caused by a buildup of coal dust and other particles on the rail bed 

in combination with high concentrations of moisture (UPRR 2005). BNSF 

railway officials toured the PRB rail infrastructure in June, 2007. According to 

a BNSF official, when coal dust is blown off rail cars, it gets lodged in the rail 

bed, allowing moisture to intrude. The moisture then degrades the structural 

stability of the rail bed and leaves the rail more vulnerable to buckling under 

stress (Gillette News-Record 2007a). NCTA testing results suggested that rail 

car bottom spillage may have more of a negative impact on rail ballast stability 

than loss from the top of rail cars since the leakage is directly above and near 

the ballast. NCTA testing also showed that after the rapid discharge doors 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-297 

were adjusted, there was a 32 percent decrease in bottom spillage of coal 

(NCTA 2007). 

Accumulating coal dust and deposition has become a concern in Converse 

County, Wyoming. The majority of coal mined in the PBR travels through 

Converse County on railroads. Coal dust blows off and sifts from the freshly 

loaded coal cars on their way from the PRB mine load-outs to Bill, Wyoming 

and through Converse County (Casper Star Tribune 2007a). The Converse 

County Board of Commissioners is concerned with the coal dust piles that have 

accumulated in the county from coal being transported by rail. 

Spontaneous combustion of accumulated coal dust can cause rangeland fires. 

Smoldering coal dust within a railroad right-of-way can ignite a wildfire and 

quickly spread to surrounding private lands if the fire is not immediately 

controlled. The Douglas, Wyoming Volunteer Fire Department Chief, Rick 

Andrews, estimates that coal fires account for at least 50 percent of the 

department’s average summer call volume (Casper Star Tribune 2007a). Water 

often only temporarily extinguishes the flames and some fires repeatedly ignite 

over the course of several hours or days. While the county’s rural fire district 

is compensated for some of the costs involved in putting out fires caused by 

coal dust accumulation, the compensation doesn’t come close to the actual 

costs, according to the Douglas Volunteer Fire Department Chief. Coal fires 

along the railroad tracks are an ongoing problem for the Douglas Volunteer 

Fire Department (Casper Star Tribune 2007a). 

BLM was invited by a Converse County private land owner to examine and 

survey the coal deposition that has occurred from coal trains traveling through 

his land. On July 7, 2008, BLM personnel met with the private landowner and 

toured his rangeland adjacent to the railroad ROW between Bill and Douglas, 

Wyoming. It was observed that water runoff had washed lost coal from the rail 

bed into adjacent drainages and the amount of deposition varied along the 

railroad ROW. BLM surveyed coal accumulations in Box Creek, and one area 

was found to have an accumulation 1.8 feet thick (BLM 2008e). 

In an effort to reduce the amount of small particles that are created in the coal 

crushing process, BNSF is encouraging the utility companies and the mines to 

not crush as finely (i.e., crushing to 3-inch diameter rather than 2-inch 

diameter) (Gillette News-Record 2007a). Another possibility that may help 

lessen blowing coal dust from trains is the use of a surfactant applied to the 

tops of loaded coal cars. When applied to coal, surfactant can stabilize and 

adhere fines and dust to larger pieces. Some tests have shown that coal dust 

on railroad tracks can be reduced by up to 95 percent with surfactant use 

(Gillette News-Record 2007a). In order for a surfactant to be used, it would 

need to meet utility companies’ burning specifications. 

A collaborative effort between the NCTA, PRB mines, and BNSF and UP 

railroads has resulted in an improved design for a coal loading chute that 

distributes coal more evenly and produces a lower profile load (UPRR 2006). 
3.0 Affected Environment and Environmental Consequences 

3-298 Final EIS, Wright Area Coal Lease Applications

Preliminary results have demonstrated that this new design may result in a 30 

to 60 percent reduction in coal dust blowing off the top of cars during the early 

portion of the route (UPRR 2006). The collaborative team is also analyzing the 

value of crushing the coal to a 3-inch diameter rather than 2-inch diameter to 

reduce dust and fines sifting through the bottom gates of rail cars, and using a 

surfactant applied to the top of the load to reduce coal dust emissions (UPRR 

2006). 

Converse County Commissioners have formally expressed concerns to BLM in 

regard to fire, health, and safety issues associated with blowing coal dust from 

trains. The Commissioners have stated that the health and well-being of 

Converse County citizens downwind of the railroad tracks continue to be 

jeopardized due to lack of coal dust mitigation in the coal mining permit 

process (BLM 2008f). The Converse County Commissioners have urged that 

coal dust mitigation be applied as a standard condition of approval upfront in 

the mining permit (BLM 2008f). 

BLM does not authorize mining permits nor regulate mining operations with 

the issuance of a BLM coal lease. WDEQ is the agency that permits mining 

operations and has authority to enforce mining regulations. In Wyoming, 

WDEQ has entered into a cooperative agreement with the Secretary of the 

Interior to regulate surface coal mining operations. Mitigation and other 

requirements are developed as part of the mining and reclamation permit. 

These must be approved by WDEQ before mining operations can occur on 

leased federal coal lands. 

Other agencies that may be stakeholders in this issue include the Federal 

Railroad Administration, which implements U.S. Department of Transportation 

environmental policies related to U.S. railroads, and the NCTA whose mission 

includes facilitating the resolution of coal transportation issues in order to 

serve the needs of the general public and industry (NCTA 2008). 

The leasing and mining of these six LBA tracts would not increase the rate of 

buildup of coal dust and fines but would prolong the issue. 

3.16 Hazardous and Solid Waste

3.16.1 Affected Environment

Potential sources of hazardous or solid waste on the North Hilight Field, South 

Hilight Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and 

South Porcupine LBA Tracts 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 any of the six LBA 

tracts. Wastes produced by current mining activities at the Black Thunder, 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-299 

Jacobs Ranch, and North Antelope Rochelle mines are handled according to 

the procedures described in Section 2.9. 

3.16.2 Environmental Consequences

3.16.2.1 Proposed Action and Alternatives 2 and 3

If the applicant mines acquire the six LBA tracts, the wastes that would be 

generated in the course of mining the tracts would be similar to those currently 

being generated by the existing mining operations. The procedures that are 

used for handling hazardous and solid wastes at the existing mines are 

described in Chapter 2, Section 2.9. Wastes generated by mining the LBA 

tracts 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 Black Thunder, Jacobs Ranch, and North Antelope 

Rochelle mines. 

3.16.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Jacobs Ranch, North Porcupine, and South Porcupine coal lease 

applications would be rejected and coal removal and associated disturbance 

and impacts would not occur on the portions of the LBA tracts as applied for or 

the LBA tracts configured under Alternative 2, BLM’s preferred alternative, that 

will not be disturbed under the currently approved surface coal mining 

permits. Coal removal and any associated waste production would continue on 

the existing Black Thunder, Jacobs Ranch, and North Antelope Rochelle Mine 

coal leases. Impacts from mining operations at these mines would not be 

extended onto portions of the LBA tracts that will not be affected under the 

current mining and reclamation plans, and no waste materials would be 

generated as a result of coal removal on the tracts. 

As discussed in Section 2.2, a decision to reject one or more of these six coal 

lease applications at this time would not preclude an application to lease that 

respective 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. 
3.0 Affected Environment and Environmental Consequences 

3-300 Final EIS, Wright Area Coal Lease Applications

3.17 Socioeconomics

The social and economic study area for the proposed project includes Campbell 

County and the communities of Wright and Gillette, Wyoming. These two 

communities are home to a majority of the three applicant mines’ current 

workforce, as well as most of the mining services, retail and business and 

consumer service establishments in the area. Gillette, the county seat, would 

most likely attract the majority of any new residents due to its current 

population levels and the availability of services, shopping amenities, and 

educational institutions. 

3.17.1 Local Economy

3.17.1.1 Affected Environment

Wyoming’s coal mines produced 449.1 million tons in 2007, a new annual 

production record, according to the Wyoming State Inspector of Mines. This 

was an increase of more than 9 percent over the 444.9 million tons produced in 

2006; itself a record. PRB coal production (from Campbell and Converse 

counties, 13 active mines) was over 436.5 million tons in 2007, which 

represented over 97 percent of the statewide coal production (Wyoming 

Department of Employment 2006 and 2007a). 

Approximately 27 percent of the November 2007 total employment in Campbell 

County and 40 percent of the second quarter 2007 total payroll was attributed 

to the natural resources and mining sector, which includes oil and gas 

employment (Wyoming Department of Employment 2007a and 2008a). In 

2007, Campbell County employment grew at a similar rate compared to the 

statewide average (3.7 percent versus 3.6 percent change, respectively). Job 

growth occurred in construction, trade, manufacturing, transportation and 

utilities, and local government, but the most dramatic increase was in the 

manufacturing sector (Wyoming Department of Employment 2008b). 

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. Lease bonus bids are paid to the federal government for the right to 

enter into lease agreements for federal coal. Bonus bids are paid in five annual 

installments; the state receives half of each installment. In 2004 and 2005, 

BLM held competitive sealed-bid lease sales for six federal coal tracts in the 

PRB (NARO South, West Antelope, West Hay Creek, Little Thunder, West 

Roundup, and NARO North). No coal lease sales were held for federal coal 

tracts in the PRB in 2006 or 2007. Three lease sales (Eagle Butte West, South 

Maysdorf, and North Maysdorf) were held in 2008. 

The successful bonus bids for the six lease sales held in 2004 and 2005 ranged 

from 30 cents per ton to 97 cents per ton and totaled $1.69 billion (BLM 

2009a). Annual bonus bid payments from the six lease sales totaled $338.2 

million in 2007 (BLM 2008g). Combined with remaining bonus bid payments 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-301 

from lease sales held in previous years of $90.1 million, the annual bonus bid 

payment total for 2004 was $428.3 million, derived directly from federal coal in 

Campbell and Converse counties. The Wyoming Consensus Revenue 

Estimating Group (CREG) is projecting that coal lease bonus bid revenues to 

the state from federal coal in the PRB will be $169.8 million for fiscal years 

2007, 2008, and 2009. Presently, the bonus bid revenues received by the state 

are allocated to fund capital construction for cities and towns, the state’s 

highway fund, community colleges, and school capital construction (Wyoming 

CREG 2007). 

Wyoming, Campbell County, and the communities in the county receive 

revenue from a variety of taxes and royalties on the production of federal coal 

in addition to the bonus bids. These include ad valorem taxes, severance 

taxes, royalty payments, sales and use taxes on equipment and other taxable 

purchases, and portions of the required contributions to the federal Abandoned 

Mine Land (AML) program and the Black Lung Disability Trust Fund. 

Federal mineral royalties are collected by the federal government at the time 

the produced coal is sold, with a royalty rate of 12.5 percent of the sale price. 

In the past, federal royalties and bonus bids had been divided equally with the 

state of Wyoming. A modification of the percentage distribution of federal 

royalties to 52 percent federal/48 percent state for fiscal year 2008 was 

attached to the federal budget bill. The percentage of mineral royalty 

distribution will revert back to 50 percent/50 percent at the end of the 2008 

fiscal year unless legislation is passed in the future to maintain or further 

modify the current percentage of distribution of royalties. Coal mines pay 28 

cents per ton of surface coal produced to fund AML reclamation programs. 

Annual appropriations returned to the states vary depending on Congressional 

authorizations and AML program priorities. Additional sources of revenue 

include federal income tax and annual rentals that are paid to the government. 

Sales and use taxes, which are levied by the state and local governments, are 

distributed to cities and towns within the county and to the county’s general 

fund. 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, the 

Campbell County government imposes a 1.0 percent general purpose local 

option tax and a 0.25 percent specific county option tax. Sales and tax 

revenues are vital for local governments. According to the Excise Tax Division 

of the Wyoming Department of Revenue (2004), the sales and use taxes 

collected from coal mines and coal mining-related services in Campbell County 

in fiscal year (FY) 2004 was $8.2 million. 

Ad valorem taxes comprise production and property taxes, with production 

taxes being far greater than property taxes for surface coal mines. Ad valorem 

taxes are collected by the county and disbursed to local governments and 

school districts that rely heavily on ad valorem taxes. Rising production and 

market values for oil and gas, and the increases in coal production tonnages 
3.0 Affected Environment and Environmental Consequences 

3-302 Final EIS, Wright Area Coal Lease Applications

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. The coal 

mining industry accounted for 59 percent of Campbell County’s 2005 total 

assessed value (Wyoming Department of Revenue 2006, Wyoming State Board 

of Equalization 2007). 

In 1994, the University of Wyoming estimated that the total fiscal benefit to the 

state of Wyoming for coal produced in the PRB was $1.10 per ton (Borden et al. 

1994). This study did not include AML fees or bonus bid payments in the 

calculation for fiscal benefits to the state of Wyoming. 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 2005 

results in an estimated $661 million, or $1.62 per ton. Figure 3-59 depicts the 

estimated total revenues to state and federal governments from 2007 coal 

production in Campbell County. 

Recent (2004) Gross State Product (GSP) calculations for Wyoming indicate 

that the minerals industry (mining and oil and gas) accounted for about 21 

percent of the state’s total GSP of $24.1 billion, which made it the largest 

sector of the Wyoming economy. 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. Mining 

alone accounted for 8.3 percent of the Wyoming GSP (Wyoming Department of 

Administration and Information 2007). 

3.17.1.2 Environmental Consequences

3.17.1.2.1 Proposed Action and Alternatives 2 and 3

The federal and state revenues that would be generated by the leasing and 

mining of these six LBA tracts would depend on which alternative for each tract 

is selected and the sale price of the coal. The Wyoming CREG forecasts all 

mineral revenues to the state, and is forecasting that the average gross sales 

prices for Wyoming coal production will range from $11.06 per ton in 2008 

increasing to $12.50 per ton by 2011 (Wyoming CREG 2008). PRB coal prices 

are generally lower than prices for coal produced in other areas of Wyoming; 

however, most of the coal produced in Wyoming is from the PRB. For the 

purposes of this analysis, a conservative average sales price of $11.06 per ton 

is assumed for the coal included in the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

LBA Tracts. 

The projected federal and state revenues for each of the six Wright Area LBA 

Tracts presented in Table 3-23 are based on coal production tonnages shown
Total Wyoming Revenue = $847.9 Million

Total Federal Revenue = $620.7 Million

Bonus Bid Payments

$169.1 million

(27.2%)

Ad Valorem Taxes

$171.6 million

(20.2%)

Sales and Use Taxes

$23.1 million

(2.7%)

Federal Mineral Royalties

$215.1 million

(25.4%)

Severence Tax

$199.7 million

(23.6%)

AML Fund

$69.3 million

(8.2%)

Bonus Bid Payments

$169.1 million

(19.9%)

AML Fund

$69.3 million

(11.2%)

Black Lung Fund

$158.4 million

(25.5%)

Federal Mineral Royalties

$223.9 million

(36.1%)

Figure 3-59. Estimated Wyoming and Federal Revenues from 2007 Coal Production in Campbell County.

3.0 Affected Environment and Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 3-303
3.0 Affected Environment and Environmental Consequences 

3-304 Final EIS, Wright Area Coal Lease Applications

Table 3-23. Projected Socioeconomic Impacts from Leasing the Wright Area

LBA Tracts Under the Proposed Action and Alternatives 2 and 3.

LBA Tract and Item 

No Action 

Alternative/ 

Existing Mine 

Proposed 

Action 

Alternatives 2 

and 3 

North Hilight Field 

 State Revenues (mm) $2,091.2 $488.5 to $584.4 $1,210.5 to $1,448.3 

 Federal Revenues (mm) $1,629.4 $390.1 to $486.0 $966.8 to $1,204.5 

 Increased Mine Life (yrs) 0 2.0 4.8 

 Additional Employees 0 0 0 

 

South Hilight Field 

 State Revenues (mm) $2,091.2 $396.1 to $473.9 $564.3 to $675.1 

 Federal Revenues (mm) $1,629.4 $316.3 to $394.1 $450.7 to $561.5 

 Increased Mine Life (yrs) 0 1.6 2.3 

 Additional Employees 0 0 0 

 

West Hilight Field 

 State Revenues (mm) $2,091.2 $700.8 to $838.4 $1,789.9 to $2,141.3 

 Federal Revenues (mm) $1,629.4 $559.7 to $697.3 $1,429.4 to $1,780.8 

 Increased Mine Life (yrs) 0 2.8 7.1 

 Additional Employees 0 0 0 

 

West Jacobs Ranch 

 State Revenues (mm) $715.4 $1,244.1 to $1,493.4 $1,695.6 to $2,035.3 

 Federal Revenues (mm) $557.5 $994.1 to $1,243.3 $1,354.8 to $1,694.5 

 Increased Mine Life (yrs) 0 16.7 22.8 

 Additional Employees 0 155 155 

 

North Porcupine 

 State Revenues (mm) $1,744.5 $1,114.9 to $1,333.8 $1,382.3 to $1,653.7 

 Federal Revenues (mm) $1,359.3 $890.3 to $1,109.3 $1,103.9 to $1,375.3 

 Increased Mine Life (yrs) 0 6.3 7.8 

 Additional Employees 0 0 0 

 

South Porcupine 

 State Revenues (mm) $1,744.5 $574.3 to $687.1 $629.2 to $752.7 

 Federal Revenues (mm) $1,359.3 $458.6 to $571.4 $502.5 to $626.0 

 Increased Mine Life (yrs) 0 3.3 3.6 

 Additional Employees 0 0 0 

in Tables 3-1 through 3-6, assuming an average coal price of $11.06 per ton 

and a potential range of bonus bid payments on the leased (mineable) coal of 

30 to 97 cents per ton. As discussed in Section 3.0, the estimates of 

recoverable coal, associated mine life and employment assume that the public 

roads bordering or crossing the LBA tracts are not moved. 

If the North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs 

Ranch, North Porcupine, and South Porcupine LBA Tracts are leased and 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-305 

mined under the Proposed Actions or other action alternatives, potential state 

and federal revenues would vary by LBA tract as indicated below. 

3.17.1.2.1.1 North Hilight Field LBA Tract

If this LBA tract is leased and mined under the Proposed Action, the potential 

additional federal revenues would range from approximately $390 million to 

$486 million. For the BLM’s preferred alternative configuration under 

Alternatives 2, the potential additional federal revenues would range from 

approximately $967 million to $1,205 million. 

If the LBA tract is leased and mined under the Proposed Action, the potential 

additional state revenues would range from about $489 million to $585 million. 

For Alternative 2, BLM’s preferred alternative, the potential additional state 

revenues would range from about $1,211 million to $1,448 million. 

The base of economic activity provided by wages and local purchases would 

continue for up to about 4.8 additional years, depending on which alternative 

is selected. 

3.17.1.2.1.2 South Hilight Field LBA Tract

If this LBA tract is leased and mined under the Proposed Action, the potential 

additional federal revenues would range from approximately $316 million to 

$394 million. For the BLM’s preferred alternative configuration under 

Alternatives 2, the potential additional federal revenues would range from 

approximately $451 million to $562 million. 

If the LBA tract is leased and mined under the Proposed Action, the potential 

additional state revenues would range from about $396 million to $474 million. 

For Alternative 2, BLM’s preferred alternative, the potential additional state 

revenues would range from about $564 million to $675 million. 

The base of economic activity provided by wages and local purchases would 

continue for up to about 2.3 additional years, depending on which alternative 

is selected. 

3.17.1.2.1.3 West Hilight Field LBA Tract

If this LBA tract is leased and mined under the Proposed Action, the potential 

additional federal revenues would range from approximately $560 million to 

$697 million. For the BLM’s preferred alternative configuration under 

Alternatives 2, the potential additional federal revenues would range from 

approximately $1,429 million to $1,781 million. 

If the LBA tract is leased and mined under the Proposed Action, the potential 

additional state revenues would range from about $701 million to $838 million. 
3.0 Affected Environment and Environmental Consequences 

3-306 Final EIS, Wright Area Coal Lease Applications

For Alternative 2, BLM’s preferred alternative, the potential additional state 

revenues would range from about $1,790 million to $2,141 million. 

The base of economic activity provided by wages and local purchases would 

continue for up to about 7.1 additional years, depending on which alternative 

is selected. 

3.17.1.2.1.4 West Jacobs Ranch LBA Tract

If this LBA tract is leased and mined under the Proposed Action, the potential 

additional federal revenues would range from approximately $994 million to 

$1,243 million. For the BLM’s preferred alternative configuration under 

Alternatives 2, the potential additional federal revenues would range from 

approximately $1,355 million to $1,695 million. 

If the LBA tract is leased and mined under the Proposed Action, the potential 

additional state revenues would range from about $1,244 million to $1,493 

million. For Alternative 2, BLM’s preferred alternative, the potential additional 

state revenues would range from about $1,696 million to $2,035 million. 

The base of economic activity provided by wages and local purchases would 

continue for up to about 22.8 additional years, depending on which alternative 

is selected. 

3.17.1.2.1.5 North Porcupine LBA Tract

If this LBA tract is leased and mined under the Proposed Action, the potential 

additional federal revenues would range from approximately $890 million to 

$1,109 million. For the BLM’s preferred alternative configuration under 

Alternatives 2, the potential additional federal revenues would range from 

approximately $1,104 million to $1,375 million. 

If the LBA tract is leased and mined under the Proposed Action, the potential 

additional state revenues would range from about $1,115 million to $1,334 

million. For Alternative 2, BLM’s preferred alternative, the potential additional 

state revenues would range from about $1,382 million to $1,654 million. 

The base of economic activity provided by wages and local purchases would 

continue for up to about 7.8 additional years, depending on which alternative 

is selected. 

3.17.1.2.1.6 South Porcupine LBA Tract

If this LBA tract is leased and mined under the Proposed Action, the potential 

additional federal revenues would range from approximately $459 million to 

$571 million. For the BLM’s preferred alternative configuration under 

Alternatives 2, the potential additional federal revenues would range from 

approximately $503 million to $626 million. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-307 

If the LBA tract is leased and mined under the Proposed Action, the potential 

additional state revenues would range from about $574 million to $687 million. 

For Alternative 2, BLM’s preferred alternative, the potential additional state 

revenues would range from about $629 million to $753 million. 

The base of economic activity provided by wages and local purchases would 

continue for up to about 3.6 additional years, depending on which alternative 

is selected. 

3.17.1.2.2 No Action Alternative

Under the No Action Alternatives, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and the potentially recoverable coal 

included in an LBA tract under the Proposed Action or Alternative 2, BLM’s 

preferred alternative, would not be recovered and the economic 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 Black Thunder Mine leases, but would 

cease between 1.6 and 7.1 years earlier than under the Proposed Actions or 

Alternative 2 for the North, South, and West Hilight Field LBA Tracts. 

Currently approved mining operations and associated economic benefits would 

continue on the existing Jacobs Ranch Mine leases, but would cease between 

16.7 and 22.8 years earlier than under the Proposed Action or Alternative 2 for 

the West Jacobs Ranch LBA Tract. Currently approved mining operations and 

associated economic benefits would continue on the existing North Antelope 

Rochelle Mine leases, but would cease between 3.3 and 7.8 years earlier than 

under the Proposed Actions or Alternative 2 for the North and South Porcupine 

LBA Tracts. Job losses, both those directly associated with the mines, as well 

as those secondary jobs supported by the mines, would occur following the 

cessation of operations. 

As discussed in Section 2.2, a decision to reject the LBA lease applications at 

this time would not preclude an application to lease the tracts in the future. 

3.17.2 Population

3.17.2.1 Affected Environment

Campbell County’s population rose from 33,698 in 2000 to an estimated 

40,473 in July 2008. This represents a 23 percent growth since 2000 and 

makes Campbell County the second fastest growing county in the state 

(following only Sublette County, which ranked fifth in growth in the nation 

between July 2006 and July 2007). Campbell County’s population ranks it as 

the third most populous of Wyoming’s 23 counties (U.S. Census Bureau 2008). 

The majority of the three applicant mines’ employees and support services 

reside in Gillette and Wright. It is estimated that the total population in the 
3.0 Affected Environment and Environmental Consequences 

3-308 Final EIS, Wright Area Coal Lease Applications

Gillette city limits increased from 24,235 at the beginning of 2003 to 30,636 at 

the end of 2007; an increase of 26.4 percent over five years. Gillette accounts 

for roughly 62 percent of the county’s residents (City of Gillette 2008a). 

Wright’s population rose from 1,355 in July 2000 to an estimated 1,529 in July 

2007, accounting for about 4 percent of the county’s residents (U.S. Census 

Bureau 2007). Gillette is currently the fourth largest city in the state, following 

Cheyenne, Casper, and Laramie. 

3.17.2.2 Environmental Consequences

3.17.2.2.1 Proposed Action and Alternatives 2 and 3

As indicated by Table 3-22, leasing and subsequently mining the six Wright 

Area LBA Tracts would extend the life of the three existing applicant mines and 

current employment at those mines by up to nearly 23 additional years (Jacobs 

Ranch Mine - Table 3-22) at the projected rates of production, under 

Alternative 2, BLM’s preferred alternative for each tract. Average yearly 

employment at the mines would increase by up to 155 positions under the 

Proposed Action and Alternative 2 (Jacobs Ranch Mine - Table 3-22). It is 

likely that the additional employees would be available from the existing 

workforce in Campbell County and no influx of new residents would occur as a 

result of filling these new positions. 

3.17.2.2.2 No Action Alternative

Under the No Action Alternative, North Hilight Field, South Hilight Field, West 

Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine coal 

lease applications would be rejected and the potentially recoverable coal 

included in an LBA tract under the Proposed Action or Alternative 2, BLM’s 

preferred alternative, would not be mined. Population levels would not be 

affected by any additional employment at the existing mines. Currently 

approved mining operations and associated employment levels would continue 

on the existing mines leases for about 10.2 years at the Black Thunder Mine, 

about 10.6 years at the Jacobs Ranch Mine, and approximately 10.9 years at 

the North Antelope Rochelle Mine. 

As discussed in Section 2.2, a decision to reject the LBA lease applications at 

this time would not preclude an application to lease the tracts in the future. 

3.17.3 Employment

3.17.3.1 Affected Environment

The statewide total employment increased by more than 10 percent from 2003 

to 2006, and nearly one-of-three of the new jobs created during that 3-year 

period was in the mining industry. During the same period, statewide coal 

mining employment increased by 762 jobs, a 16 percent increase. From 2003 

to 2006, total employment in Campbell County grew by 3,384 jobs, a 16 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-309 

percent increase. From 2000 through November 2007, the number of 

employees in Campbell County grew by about 33 percent (19,299 to 25,762) 

(City of Gillette 2008a). The average unemployment rate in Campbell County 

for 2006 was 2.1 percent and less than 2.0 percent for 2007 (City of Gillette 

2008a), even as the local labor force has grown due to immigration and 

attraction of additional residents into the labor force (U.S. Bureau of Labor 

Statistics 2008). 

Surface coal mining has changed substantially in recent times, largely as a 

result of new technologies and higher capacity equipment. The local coal 

mining labor force grew rapidly during the 1970s as more mines opened and 

production increased. 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 the PRB coal mines climbed as total 

annual production increased by more than 45 percent (Wyoming Department of 

Employment 1998 and 2007b). 

The mining sector, which includes oil and gas workers, accounts for nearly 28 

percent of all employment in Campbell County, nearly four times the statewide 

percentage. In the fourth quarter of 2007, around 7,267 people were directly 

employed by surface coal mines or coal contractors in Campbell County, 

representing about 26 percent of the Campbell County employed labor force 

(Wyoming Department of Employment 2008a). Campbell County also has 

slightly higher percentages of construction and wholesale trade employment, 

which is keeping with the development demands of continuing growth and the 

county’s position as a commercial center for northeast Wyoming. 

3.17.3.2 Environmental Consequences

In January 2008, the unemployment rate in Campbell County was 2.5 percent 

(664 unemployed persons out of a total labor force of 26,295) (Wyoming 

Department of Employment 2008b). It is likely that additional employees 

would be available from the existing labor force in Campbell County, depending 

on the timing of the hiring at the mines as compared to the timing of hiring for 

other ongoing and proposed projects in the county, which are discussed in 

Section 4.1. 

3.17.3.2.1 Proposed Action and Alternatives 2 and 3

3.17.3.2.1.1 North Hilight Field LBA Tract

Leasing and subsequently mining the North Hilight Field LBA Tract would 

extend the life of the Black Thunder Mine by up to about 2 years under the 

Proposed Action or 4.8 years under Alternative 2, BLM’s preferred alternative, 

depending on which alternative is selected. As discussed above, TBCC is not 

projecting an increase in average yearly employment at the mine under either 
3.0 Affected Environment and Environmental Consequences 

3-310 Final EIS, Wright Area Coal Lease Applications

alternative (Table 3-22). The economic stability of the communities of Gillette 

and Wright would benefit by having the current Black Thunder Mine workforce 

living in the community and employed at the mine for up to about 4.8 

additional years. 

3.17.3.2.1.2 South Hilight Field LBA Tract

Leasing and subsequently mining the South Hilight Field LBA Tract would 

extend the life of the Black Thunder Mine by about 1.6 years under the 

Proposed Action or 2.3 additional years under Alternative 2, BLM’s preferred 

alternative, depending on which alternative is selected. As discussed above, 

TBCC is not projecting an increase in average yearly employment at the mine 

under either alternative (Table 3-22). The economic stability of the 

communities of Gillette and Wright would benefit by having the current Black 

Thunder Mine workforce living in the community and employed at the mine for 

up to about 2.3 additional years. 

3.17.3.2.1.3 West Hilight Field LBA Tract

Leasing and subsequently mining the West Hilight Field LBA Tract would 

extend the life of the Black Thunder Mine by about 2.8 years under the 

Proposed Action or 7.1 additional years under both Alternative 2 (BLM’s 

preferred alternative) and Alternative 3, depending on which alternative is 

selected. As discussed above, TBCC is not projecting an increase in average 

yearly employment at the mine under any of the Action Alternatives (Table 3-

22). The economic stability of the communities of Gillette and Wright would 

benefit by having the current Black Thunder Mine workforce living in the 

community and employed at the mine for up to about 7.1 additional years. 

3.17.3.2.1.4 West Jacobs Ranch LBA Tract

Leasing and subsequently mining the West Jacobs Ranch LBA Tract would 

extend the life of the Jacobs Ranch Mine by up to about 16.7 years under the 

Proposed Action or 22.8 additional years under Alternative 2, BLM’s preferred 

alternative, depending on which alternative is selected. As discussed above, 

TBCC is projecting that the average yearly employment at the mine would 

increase by up to 155 positions under both the Proposed Action and Alternative 

2 (Table 3-22). The economic stability of the communities of Gillette and 

Wright would benefit by having the current Jacobs Ranch Mine workforce living 

in the community and employed at the mine for up to about 22.8 additional 

years. 

3.17.3.2.1.5 North Porcupine LBA Tract

Leasing and subsequently mining the North Porcupine LBA Tract would extend 

the life of the North Antelope Rochelle Mine by about 6.3 additional years 

under the Proposed Action or 7.8 additional years under Alternative 2, BLM’s 

preferred alternative, depending on which alternative is selected. As discussed 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-311 

above, PRC is not projecting an increase in average yearly employment at the 

mine under either alternative (Table 3-22). The economic stability of the 

communities of Gillette and Wright would benefit by having the current North 

Antelope Rochelle Mine workforce living in the community and employed at the 

mine for up to about 7.8 additional years. 

3.17.3.2.1.6 South Porcupine LBA Tract

Leasing and subsequently mining the South Porcupine LBA Tract would extend 

the life of the North Antelope Rochelle Mine by about 3.3 additional years 

under the Proposed Action or 3.6 additional years under Alternative 2, BLM’s 

preferred alternative, depending on which alternative is selected. As discussed 

above, PRC is not projecting an increase in average yearly employment at the 

mine under either alternative (Table 3-22). The economic stability of the 

communities of Gillette and Wright would benefit by having the current North 

Antelope Rochelle Mine workforce living in the community and employed at the 

mine for up to about 3.6 additional years. 

3.17.3.2.2 No Action Alternative

Under the No Action Alternative, North Hilight Field, South Hilight Field, West 

Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine coal 

lease applications would be rejected and the potentially recoverable coal 

included in an LBA tract under the Proposed Action or Alternative 2, BLM’s 

preferred alternative, would not be mined. Mine life and existing employment 

levels would not be extended by up to nearly 23 additional years, though 

currently approved mining operations and associated employment would 

continue on the existing mines leases for about 10.2 years at the Black 

Thunder Mine, 10.6 years at the Jacobs Ranch Mine, and 10.9 years at the 

North Antelope Rochelle Mine. Direct jobs provided by the mines and those 

supported indirectly by those operations and the consumer expenditures of the 

mines’ workforces would be lost sooner than if leasing were to occur. 

As discussed in Section 2.2, a decision to reject the LBA lease applications at 

this time would not preclude an application to lease the tracts in the future. 

3.17.4 Housing

3.17.4.1 Affected Environment

According to a 2001 report on housing needs in Campbell County, roughly 61 

percent of PRB surface coal mining employees live in Gillette and surrounding 

areas, 14 percent live in Wright, and 25 percent live outside of Campbell 

County (Pederson Planning Consultants 2001). 

There were 11,538 housing units in Campbell County reported in the 1990 

census. The 2000 census counted 13,288 housing units in Campbell County, 

of which 12,207 (92 percent) were occupied; 74 percent by the owners. Of the 
3.0 Affected Environment and Environmental Consequences 

3-312 Final EIS, Wright Area Coal Lease Applications

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). 

The number of housing units in Gillette increased from 7,078 in 1990 to 7,931 

in 2000, an increase of 12 percent. The number of housing units increased in 

Wright from 528 in 1990 to 544 in 2000, an increase of slightly over 3 percent. 

The types of housing units counted in 2000 included 6,698 single-family 

detached units, 794 single-family attached units, 2,276 multi-family units, 

3,432 mobile homes, and 88 RVs, vans, or similar types of units. Subsequent 

construction added 561 single-family detached, 61 single-family attached, 498 

manufactured homes, and 352 multi-family units in Gillette and Wright, plus 

an unknown number of single-family and manufactured units in rural areas. 

The resulting totals are estimated at 7,259 single-family detached units (49.2 

percent), 855 single-family attached units (5.8 percent), 2,628 multi-family 

units (17.8 percent), 3,930 mobile/manufactured units (26.6 percent), and 88 

RV/vans (0.6 percent) (CSI 2005). 

Population growth since 2000 has prompted new housing construction in the 

region. In Campbell County, net additions to the number of housing units 

from 2000 through 2005 total 797. 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 (WCDA 2007). During 2006, 

there were 631 housing units permitted; a new record. During 2007, another 

new record was established at 1,112 housing units permitted. The housing 

inventory in Gillette increased from 10,194 units to 11,347 units over the 2007 

calendar year; an increase of 11.3 percent (City of Gillette 2008a). The number 

of units added in unincorporated, rural areas of Campbell County is not known 

because the county does not require building permits or certificates of 

occupancy for residential development in unincorporated areas (Braunlin 

2004). 

A survey conducted in October 2004 estimated the vacancy rate of rental units 

to be 7.0 percent, based on a sample of approximately 40 percent of all rental 

units, mostly in larger complexes (CSI 2005). According to a 2006 housing 

survey, there was a 0.10 percent vacancy rate for rental property in 2007, while 

the average annual vacancy rate for manufactured home/mobile home rentals 

within the city limits was 5.2 percent (City of Gillette 2008a). Many 

apartments had long waiting lists. 

In the second quarter of 2007, average housing rental costs in Campbell 

County were $691 for a two-bedroom, unfurnished apartment, $292 for a 

single-wide mobile home lot, and $1,127 for a two or three-bedroom single 

family home. In the second quarter of 2008, average housing rental costs in 

Campbell County were $717 (a 3.8 percent increase) for a two-bedroom, 

unfurnished apartment, $318 (a 9.1 percent increase) for a single-wide mobile 

home lot, and $1,314 (a 16.7 percent increase) for a two- or three-bedroom 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-313 

single family home (Wyoming Department of Administration and Information 

2008). 

The average selling price of homes in Campbell County, based on 528 sales, in 

2007 was $247,150. That average represents a 23.6 percent increase over that 

in 2006 and sixth highest among Wyoming counties (WCDA 2008). 

In addition to permanent housing, temporary or transient housing is a 

consideration for any project that might have a construction component. 

Temporary housing can include 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). Campbell County has a multi-event facility, the CAM-PLEX, located in 

Gillette. It has 1,821 RV sites, which vary from 688 full service sites with rest 

rooms and shower facilities to electric only sites. The CAM-PLEX facilities are 

generally available only for scheduled special events, not for public camping 

(CAM-PLEX 2005). 

Gillette also has approximately 1,595 mobile home park spaces. Mobile home 

parks are generally considered permanent housing resources, but they 

sometimes provide temporary spaces for RVs as well if there are vacant spaces 

available. As of early October 2004, the average vacancy rate in Gillette’s 

mobile home parks was 35 percent, or 558 spaces (CSI 2005). 

3.17.4.2 Environmental Consequences

3.17.4.2.1 Proposed Action and Alternatives 2 and 3

As discussed above, TBCC is not projecting an increase in average yearly 

employment at the Black Thunder Mine under any of the Action Alternatives 

for the North, South, and West Hilight Field LBA Tracts. The current 

employment level at the Black Thunder Mine would be extended by up to about 

4.8 additional years for the North Hilight Field tract, 2.3 years for the South 

Hilight Field tract, and 7.1 additional years for the West Hilight Field tract 

under Alternative 2, BLM’s preferred alternative, for each LBA tract. 

As discussed above, TBCC is projecting an increase in average yearly 

employment by up to 155 positions and employment at the Jacobs Ranch Mine 

would be extended by up to 16.7 additional years under the Proposed Action 

and 22.8 years under Alternative 2, BLM’s preferred alternative, for the West 

Jacobs Ranch LBA Tract. 
3.0 Affected Environment and Environmental Consequences 

3-314 Final EIS, Wright Area Coal Lease Applications

As discussed above, PRC is not projecting an increase in average yearly 

employment at the North Antelope Rochelle Mine under the Action Alternatives 

for the North and South Porcupine LBA Tracts. The current employment level 

at the North Antelope Rochelle Mine would be extended by up to about 7.8 

additional years for the North Porcupine tract and 3.6 additional years for the 

South Porcupine tract under Alternative 2, BLM’s preferred alternative for each 

LBA tract. 

No additional demands on the existing infrastructure or services in the 

community would be expected because little or no influx of new residents 

would be needed to fill new jobs. Although housing is tight in Gillette, it is 

likely that housing for the additional employees would be available from the 

existing and proposed units in Campbell County. 

3.17.4.2.2 No Action Alternative

Under the No Action Alternative, the North Hilight Field, South Hilight Field, 

West Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine 

coal lease applications would be rejected and the coal included in an LBA tract 

under the Proposed Action or Alternative 2, BLM’s preferred alternative, would 

not be mined. Housing occupancy would not be affected by any additional 

employment at the three applicant mines. Currently approved mining 

operations and associated employment levels would continue on the existing 

coal leases for about 10.2 years at the Black Thunder Mine, 10.6 years at the 

Jacobs Ranch Mine, and for approximately 10.9 years at the North Antelope 

Rochelle Mine. 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 LBA lease applications at 

this time would not preclude an application to lease the tracts 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 keep pace with growth. Current facilities 

and services are generally adequate for the current population, although 

several service providers are engaged in expansion plans to accommodate 

future growth. 

Campbell County School District No. 1’s enrollment as of December 2007 is 

listed as stable at 7,569 students, making it the third largest school district in 

Wyoming. The district facilities include: one high school (with two campuses) 

and two junior high schools in Gillette, a junior-senior high school in Wright 

and 15 elementary schools (including one in Wright and three in rural areas). 

The district also operates an alternative high school and aquatic center in 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-315 

Gillette (CCSD 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 School District initiated a 

Capital Facilities Plan during 2007, and there are three new elementary 

schools under review at this time (City of Gillette 2008a). 

Law enforcement services throughout the county are provided by the Campbell 

County Sheriff’s Office, while the Gillette Police Department provides police 

protection within the city of Gillette. In addition to general law enforcement, 

the Sheriff’s staff and city police officers provide court security, detention 

facilities, and animal control. The Campbell County Detention Center is a 24-

hour supervised, 128-bed facility that includes separate modules for women 

and juveniles (BLM 2005c). 

Fire suppression throughout Campbell County is provided by the Campbell 

County Fire Department, which is governed by a city-county joint powers 

board. The department maintains four stations in Gillette and six dispersed 

throughout the county. The department has 17 full-time staff and 150 trained 

volunteers. In addition, there are 30 to 40 volunteers in outlying areas who are 

trained and equipped primarily to fight wildland fires. Campbell County coal 

mines generally provide equipment and trained staff to fight fires on mine 

property, and if called upon, the County Fire Department provides backup 

assistance with personnel and equipment (Vonsik 2005). 

The primary medical care facility in Campbell County is Campbell County 

Memorial Hospital, a 90-bed acute care hospital, located in Gillette. The 

hospital has a medical staff of over 50 affiliated physicians in 20 specialties 

and a total staff of 800 (CCMH 2005). The hospital also operates the Wright 

Clinic, a satellite clinic 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. 

Water and wastewater treatment systems are provided by the city of Gillette. 

Gillette’s water supply, which is a system of groundwater wells, has the 

capacity to serve approximately 30,600 people within the city limits and some 

nearby urbanized areas. Water use approaches capacity during the peak 

demand months in the summer when parks and private lawns are being 

irrigated (Morovits 2005). The city of Gillette and Campbell County have 

developed a long term water supply plan called the Gillette Regional Water 

Supply Project that includes an additional Madison Formation well field and 

pipeline with a capacity to serve approximately 50,000 people (City of Gillette 

2008b). Projected completion is about 6 years. In the interim, the city has 

other wells it can pump if necessary, but high natural fluoride levels require 

careful monitoring if they are used (Morovits 2005). 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 
3.0 Affected Environment and Environmental Consequences 

3-316 Final EIS, Wright Area Coal Lease Applications

capacity to accommodate a projected population of 41,000. Currently, the 

system serves an estimated 25,000 people in the city and surrounding areas. 

Water and wastewater treatment systems are provided to the community of 

Wright by the Wright Water and Sewer District. The Wright district’s water and 

sewage treatment facilities were designed to serve a population of 

approximately 3,000, albeit with an additional sewage lagoon required when 

the service population reached about 2,500 people. The district is planning an 

additional well to increase its water supply capacity by about 30 percent. The 

district’s facilities in Wright currently serve a population of approximately 

1,400 people; essentially the entire town is served by the water system, and 

most lots are on the sewer system, although there are some private septic 

systems. 

3.17.5.2 Environmental Consequences

3.17.5.2.1 Proposed Action and Alternatives 2 and 3

As discussed above, TBCC is not projecting an increase in average yearly 

employment at the Black Thunder Mine under the Proposed Action or 

Alternative 2, BLM’s preferred tract configuration, for the North, South and 

West Hilight Field LBA Tracts. Current employment levels would continue for 

about 4.8 additional years under Alternative 2 for the North Hilight Field tract, 

2.3 additional years under Alternative 2 for the South Hilight Field tract, and 

7.1 additional years under Alternative 2 for the West Hilight Field tract. 

As discussed above, TBCC is projecting that the average yearly employment at 

the Jacobs Ranch Mine would increase by up to 155 positions under both the 

Proposed Action and Alternative 2, BLM’s preferred tract configuration, and 

mine life would be extended by up to 22.8 additional years under Alternative 2 

for the West Jacobs Ranch tract. 

As discussed above, PRC is not projecting an increase in average yearly 

employment at the North Antelope Rochelle Mine under the Proposed Action or 

Alternative 2, BLM’s preferred tract configuration, for the North and South 

Porcupine LBA Tracts. Current employment levels would continue for about 

7.8 additional years under Alternative 2 for the North Porcupine tract and 3.6 

additional years under Alternative 2 for the South Porcupine tract. 

No additional demands on 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 will be satisfied by the existing facilities and services currently in place 

in Campbell County. 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-317 

3.17.5.2.2 No Action Alternative

Under the No Action Alternative, North Hilight Field, South Hilight Field, West 

Hilight Field, West Jacobs Ranch, North Porcupine, and South Porcupine coal 

lease applications would be rejected and the potentially recoverable coal 

included in an LBA tract under the Proposed Action or Alternative 2, BLM’s 

preferred alternative, would not be mined. Local government facilities and 

services would not be affected by any additional employment at the Black 

Thunder, Jacobs Ranch or North Antelope Rochelle mines. Currently approved 

mining operations and associated employment levels would continue on the 

existing mine leases for about 10.2 years at the Black Thunder Mine, 10.6 

years at the Jacobs Ranch Mine, and 10.9 years at the North Antelope Rochelle 

Mine. 

As discussed in Section 2.2, a decision to reject the LBA lease applications at 

this time would not preclude an application to lease the tracts 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 

2005c). That report emphasizes Campbell County and its communities as the 

nucleus for coal development in the PRB. The three applicant mines included 

in this EIS went into production between 1977 and 1983. These mines and 

their employees contribute to the social and economic stability of Campbell 

County, the city of Gillette and the town of Wright. 

3.17.6.2 Environmental Consequences

3.17.6.2.1 Proposed Action and Alternatives 2 and 3

As discussed above, employment at the mines is not anticipated to increase 

substantially under the Proposed Action or Alternatives 2 and 3. 

Consequently, little or no change in the social setting of Campbell County or 

the communities of Gillette and Wright would be anticipated under these 

alternatives. 

3.17.6.2.2 No Action Alternative

Implementation of the No Action Alternative would result in the eventual loss of 

approximately 3,104 relatively high paying mining jobs in the PRB, along with 

numerous support services and other jobs that depend on the mining industry. 

A majority of those losses would occur in Campbell County and the city of 

Gillette. Loss of the 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 Campbell County and the city 
3.0 Affected Environment and Environmental Consequences 

3-318 Final EIS, Wright Area Coal Lease Applications

of Gillette and some population relocation, unless mine employees were able to 

find comparable employment within commuting distance of Gillette. Social 

effects of the No Action Alternative on 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 County, 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 adverse impacts on minority and/or low-income groups, 

including Native Americans. 

Campbell County’s population in 2007 was comprised of 94.1 percent white 

non-Hispanic, 3.5 percent Hispanic, 1.7 percent Native American, 1.3 percent 

two or more races, and 1.1 percent other races (the total exceeds 100 percent 

because Hispanics could be counted in other races). In 2007, approximately 

7.6 percent of Campbell County’s residents had income below the poverty level 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-319 

and 3.0 percent of the county’s residents had income below 50 percent of the 

poverty level (City-Data 2009). 

3.17.7.2 Environmental Consequences

3.17.7.2.1 Proposed Action and Alternatives 2 and 3

Economic and demographic data indicate that neither minority populations nor 

people living at or below the poverty level make up a “meaningfully greater 

increment” of the total population in Gillette, Wright or Campbell County than 

they do in the state as a whole, or that they would be unequally impacted if 

North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, 

North Porcupine, and South Porcupine LBA Tracts are leased under the 

Proposed Actions or Alternatives 2 or 3. 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 BLM study areas for the proposed LBA 

tracts. Consequently, implementation of the Proposed Actions or Alternatives 2 

or 3 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 a “meaningfully greater 

increment” of the total population in Gillette, Wright or Campbell County than 

they do in the state as a whole, or that they would be unequally impacted if the 

North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs Ranch, 

North Porcupine, and South Porcupine LBA Tracks are leased under the 

Proposed Actions or Alternatives 2 or 3. 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 three existing applicant mines. 

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. BLM compares the amount of 

coal reported as produced with the estimated amount of unmined, in-place coal 

to verify that the federal coal is efficiently mined and that royalties are paid on 

all of the coal that is mined. 

3.17.9 Residual Impacts

No socioeconomic residual impacts are expected. 
3.0 Affected Environment and Environmental Consequences 

3-320 Final EIS, Wright Area Coal Lease Applications

3.18 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) (BLM 2008). 

3.18.1 Local Area

If the North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs 

Ranch, North Porcupine, and South Porcupine LBA Tracts are leased, almost 

all components of the present ecological system that have developed over a long 

period of time would be modified as the coal is mined. In the long term, the 

reclaimed land surface contours would resemble the original topography, 

although it would be slightly lower in elevation and lack some of the original 

diversity of geomorphic form. 

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. 

The forage and associated grazing and wildlife habitat that these six LBA tracts 

currently provide would be temporarily and incrementally disturbed during 

mining and reclamation. If the LBA tracts are mined, there would be a loss of 

native vegetation on a total of 32,783.4 acres (total of all Proposed Actions) up 

to a maximum of 53,773.0 acres (total of all Alternatives 2 and 3) with an 

accompanying disturbance of grazing land and wildlife habitat. 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). Plant communities may never return to their original 

compositions, although the reclaimed lands would be returned to equivalent or 

better forage production capacity for domestic livestock before the performance 

bond is released. Long-term productivity would depend largely on postmining 

range management practices, which to a large extent would be controlled by 

private landowners and the Forest Service. 

Mining would disturb pronghorn and mule deer habitat. As discussed in 

Section 3.10.5, potential sage-grouse habitat is scarce throughout the general 

Wright analysis area. There would be loss and displacement of wildlife in the 

short term during mining, but based on monitoring of previously reclaimed 

lands, it is anticipated that the reclaimed habitat would support a diversity of 

wildlife species similar to premining conditions over the long term. The 

diversity of species found in undisturbed lands would not be completely 

restored on the mined lands for an estimated 50 years after the initiation of 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-321 

disturbance. Reestablishment of mature sagebrush habitat, which is crucial 

for pronghorn and sage-grouse, would be expected to take even longer. 

If the North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs 

Ranch, North Porcupine, and South Porcupine LBA Tracts are leased and 

mined, depths to groundwater in the overburden and coal would increase in an 

area extending further to the west and south of the existing mine areas in the 

short term. Groundwater flow through the undisturbed aquifers near the 

backfilled mine pits would be interrupted until saturation levels in the backfill 

have risen and the rates of recharge to and discharge from the backfill 

equilibrate. The water levels in the coal aquifer should return to premining 

levels at some time after mining and CBNG development in the vicinity have 

ceased because recharge areas would not be disturbed when recovering the 

coal in the LBA tracts. Groundwater quality in and near the backfilled mine 

pits would be different from pre-mining conditions after reclamation, although 

it would remain adequate for livestock and wildlife use. 

CBNG is currently being recovered from within and near these six LBA tracts, 

and BLM’s analysis suggests that a large portion of the CBNG resources on the 

tracts has been recovered or would be recovered prior to mining. CBNG that is 

not recovered prior to mining would be vented to the atmosphere during the 

mining process. CBNG is composed primarily of methane, which is a 

greenhouse gas. A discussion of methane emissions from coal mining 

operations in the U.S. is included in Chapter 4, Section 4.2.14. Total U.S. 

methane emissions attributable to coal mining would not be likely to decrease 

if these six LBA tracts are not leased at this time. Likewise, it would not be 

likely that total U.S. methane emissions in the long term would measurably 

increase if these six LBA tracts are leased at this time. 

Short-term impacts to recreation values may occur from a reduction in big 

game populations due to habitat disturbance and reduction in access to some 

public lands. These changes would primarily impact hunting in the lease 

areas. 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 

hunting opportunities. Another minor short-term impact to recreation values 

may occur due to the loss of public access to the Little Thunder Reservoir as a 

result of leasing and mining the West Hilight Field LBA Tract. Public access to 

Pronghorn Lake, a postmining final impoundment that is located within an 

active portion of Black Thunder Mine’s current permit area, will occur once it 

no longer serves a function (storage for dust suppression water) for the mining 

operation. The recreational activities provided by Little Thunder Reservoir 

could be replaced by those provided by Pronghorn Lake; however, the time at 

which Pronghorn Lake becomes accessible to the general public may not 

coincide with the time at which Little Thunder Reservoir becomes inaccessible, 

but there should be no long-term adverse impacts on fishing opportunities. 
3.0 Affected Environment and Environmental Consequences 

3-322 Final EIS, Wright Area Coal Lease Applications

The short- and long-term economy of the region would be enhanced as a result 

of the Action Alternatives. Leasing and subsequently mining the North, South, 

and West Hilight Field LBA Tracts under Alternative 2, BLM’s preferred 

alternative for each tract, would extend the life of the existing Black Thunder 

Mine by up to a total of 14.2 additional years (Tables 2-2, 2-4, and 2-6). 

Leasing and subsequently mining the West Jacobs Ranch LBA Tract under 

Alternative 2, BLM’s preferred alternative, would extend the life of the existing 

Jacobs Ranch Mine by up to 22.8 additional years (Table 2-8). Leasing and 

subsequently mining the North and South Porcupine LBA Tracts under 

Alternative 2, BLM’s preferred alternative for each tract, would extend the life of 

the existing North Antelope Rochelle Mine by up to a total of 11.4 additional 

years (Tables 2-10 and 2-12). 

3.18.1.1 Human Health Impact Assessment

In 2008, public concerns were brought to BLM’s attention in regard to 

conducting human health impact assessments in the PRB where coal mining 

activities occur. A health impact assessment (HIA) is a method used in 

assessing potential impacts of a proposed project on human health. HIAs 

examine health on a broad scale, including social, emotional, and cultural 

impacts as well as physical impacts. HIAs rely on available scientific data, 

public testimony, and modeling to predict potential health impacts. 

Public concerns included emissions from coal mining activities like particulate 

matter and nitrogen oxide exposure and their potential impact on the health of 

people living in the vicinity of surface coal mines located in the eastern PRB. 

BLM does not have jurisdiction in regard to conducting human health 

assessments. However, BLM has invited the Wyoming Department of 

Health/Environmental Health Section and the U.S. Center for Disease Control 

and Prevention to review and provide comment on the Wright Area Coal Lease 

Applications EIS. 

Air pollution is controlled by state and federal air quality regulations and 

standards established under the federal Clean Air Act Amendments. State 

implementation plans are in place to ensure proposed actions like coal mining 

comply with all associated air quality regulations and criteria. The Wyoming 

Ambient Air Quality Standards (WAAQS) are stricter than the National Ambient 

Air Quality Standards (NAAQS) and are enforced by WDEQ. 

As described in Section 3.4.2.3 of this EIS, the WDEQ/AQD developed a 

Natural Events Action Plan for the coal mines of the PRB. The plan, based on 

EPA Natural Event Policy guidance, identifies potential control measures for 

protecting public health and minimizing exceedences of the PM10 NAAQS. 

All mines are required to conduct air quality modeling to show that their 

proposed operations will comply with the WAAQS and NAAQS, and they are 

required to monitor to demonstrate that their actual air emissions do not 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-323 

exceed the standards. The WDEQ/AQD coal mining permit process requires 

air quality modeling of the primary air pollutants PM10 and NO2. Sections 

3.4.2.3 and 3.4.3.3 in this EIS addresses air quality mitigation measures that 

WDEQ/AQD implemented in order to prevent exceedences of the WAAQS and 

NAAQS by PRB surface coal mines. 

As stated above and as discussed in Section 3.4, mining operations and 

associated activities would effectively degrade the air quality in the vicinity on a 

short-term basis. Following coal removal, removal of all surface facilities, and 

completion of reclamation, there would be no long-term impact on air quality. 

3.18.2 Greenhouse Gas Emissions

There has been, and continues to be, considerable scientific investigation and 

discussion as to the causes of recently increasing global mean temperatures 

and whether a warming trend will continue. This section will address 

greenhouse gas (GHG) emissions as specifically related to the Black Thunder, 

Jacobs Ranch, and North Antelope Rochelle mines, the applicant mines 

adjacent to the North Hilight Field, South Hilight Field, West Hilight Field, West 

Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts. 

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. WDEQ, with oversight from OSM, has regulatory authority in 

issuing permits to mine coal in Wyoming. 

GHGs are an issue because of global warming and climate change. Global 

warming is a theory that certain gases in the atmosphere impede the radiation 

of heat from the earth back into space, trapping heat like the glass in a 

greenhouse. This raises the average temperature of the surface of the earth 

and the lower atmosphere, which contributes to climate change. Among these 

GHGs are carbon dioxide (CO2), methane (CH4), water vapor, ozone (O3), 

nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and 

sulfur hexafluoride (SF6). GHGs are not currently regulated, but there is a 

consensus in the international community that the global climate change is 

occurring and that it should be addressed in governmental decision making. If 

the coal in the North Hilight Field, South Hilight Field, West Hilight Field, West 

Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts is leased and 

mined, so-called GHG emissions from the mining operations would be released 

into the atmosphere. A discussion of emissions and by-products that are 

generated by burning coal to produce electricity, and a more complete 

discussion of the global warming and climate change phenomena is included in 

Section 4.2.14 of this EIS. 

The use of the coal after it is mined is 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 
3.0 Affected Environment and Environmental Consequences 

3-324 Final EIS, Wright Area Coal Lease Applications

discussed in Chapter 2, under Black Thunder Mine’s currently approved 

mining plan, which represents the No Action Alternative, TBCC anticipates that 

the mine would produce its remaining estimated 1,169.4 million tons of 

recoverable coal reserves in 9.3 years at an average annual production rate 

(post-2008) of approximately 135 million tons. Leasing and subsequently 

mining the North, South, and West Hilight Field LBA Tracts, each under the 

Proposed Action at an average annual production rate of 135 million tons, 

TBCC estimates that the life of the mine would be extended by about 2.0, 1.6, 

and 2.8 additional years, respectively. Leasing and subsequently mining the 

North, South, and West Hilight Field LBA Tracts at the same average annual 

production rate under Alternative 2, BLM’s preferred alternative for each tract, 

TBCC estimates the life of the mine would be extended by 4.8, 2.3, and 7.1 

years, respectively. 

As discussed in Chapter 2, under Jacobs Ranch Mine’s currently approved 

mining plan, which represents the No Action Alternative, TBCC anticipates that 

the mine would produce its remaining estimated 379.4 million tons of 

recoverable coal reserves in 9.6 years at an average annual production rate 

(post-2008) of approximately 40 million tons. Leasing and subsequently 

mining the West Jacobs Ranch LBA Tract under the Proposed Action, TBCC 

estimates that the life of the mine would be extended by about 16.7 additional 

years at an average annual production rate of 40 million tons. Leasing and 

subsequently mining the West Jacobs Ranch LBA Tract under Alternative 2, 

BLM’s preferred alternative, TBCC estimates the life of the mine would be 

extended by 22.8 years at the same average annual production rate. 

As discussed in Chapter 2, under North Antelope Rochelle Mine’s currently 

approved mining plan, which represents the No Action Alternative, PRC 

anticipates that the mine would produce its remaining estimated 933.8 million 

tons of recoverable coal reserves in 9.9 years at an average annual production 

rate (post-2008) of approximately 95 million tons. Leasing and subsequently 

mining the North and South Porcupine LBA Tracts, each under the Proposed 

Action at an average annual production rate of 95 million tons, PRC estimates 

that the life of the mine would be extended by about 6.3 and 3.3 additional 

years, respectively. Leasing and subsequently mining the North and South 

Porcupine LBA Tracts at the same average annual production rate under 

Alternative 2, BLM’s preferred alternative for each tract, PRC estimates the life 

of the mine would be extended by 7.8 and 3.6 years, respectively. 

Some PRB surface coal mines have completed GHG emissions inventories. Not 

all three applicant mines have completed a GHG emissions inventory, although 

mines both within and outside the general Wright analysis area conducted 

inventories of expected GHG emissions that occurred in 2007. These mines 

also projected emissions for a typical year of operations if additional lands are 

leased and mined. Emissions inventories included from all sources, including 

all types of carbon fuels used in the mining operations, electricity used on site 

(i.e., lighting for facilities, roads, and operations and electrically powered 

equipment and conveyors) and mining processes (i.e., blasting, coal fires 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-325 

caused by spontaneous combustion and methane released from exposed coal 

seams). An additional category, which was not included in the emissions 

estimates for the three applicant mines due to a lack of information, is rail 

transport, both on-site and in moving coal to the buyers. Emissions are 

measured as metric tons (tonnes) of carbon dioxide equivalents (CO2e). CO2e is 

a unit of measure that takes into account the global warming potential of each 

emitted GHG in terms of equivalent CO2 emissions. Using the functionally 

equivalent amount or concentration of CO2 as the reference, a conversion is 

made to put any of the various gases emitted (i.e., CH4 and N2O) into the 

equivalent greenhouse effect. 

The expected CO2e emissions that occurred in 2007 for the mines that have not 

completed emissions inventories were estimated by assuming the CO2e 

emission ratios (CO2e/million tons of coal produced, CO2e/million bank cubic 

yards of overburden moved, and CO2e/acres of disturbance) for the mines that 

completed emissions inventories would be equivalent to those mines that have 

not. The correlations were based on the 2007 coal production, overburden 

production, and disturbance acres (facilities plus active pit acres) for three 

source types (fuel, electricity, and mining process) at the Black Thunder, 

Jacobs Ranch, and North Antelope Rochelle mines (WWC 2009). Since the 

combined CO2e emission estimates for the three applicant mines are based on 

limited information, the estimated values are tentative. For the purpose of this 

analysis, these combined total values are only included here as a means of 

obtaining a representation of potential CO2e emissions, should the six LBA 

tracts be leased and mined. 

CO2e emissions are projected to increase at the Black Thunder, Jacobs Ranch 

and North Antelope Rochelle mines if the North Hilight Field, South Hilight 

Field, West Hilight Field, West Jacobs Ranch, North Porcupine, and South 

Porcupine LBA Tracts are added to the mining operations (Table 3-24). The 

increases in CO2e emissions are expected to result from the additional fuels 

(especially diesel) that would be used in consideration of the increased coal and 

overburden haul distances, as well as increased use of electricity and 

explosives related to increasing overburden thicknesses. The incremental 

changes with the addition of these six LBA tracts to the applicant mines’ 

operations represent the estimated CO2e emissions for the Proposed Actions as 

well as Alternative 2, BLM’s preferred alternative for each tract. Estimates 

assume that the combined annual production rate from these three mines is 

270 million tons. 

Table 3-24. Estimated Annual Equivalent CO2 Emissions1 at the Black 

Thunder, Jacobs Ranch, and North Antelope Rochelle Mines.

Source 2007 With LBA Tracts 

Fuel 577,463 1,429,582 

Electricity 465,908 777,141 

Mining Process 201,871 296,166 

Total of Three Sources 1,245,241 2,502,889 

1 CO2e in tonnes 

Source: WWC 2009 
3.0 Affected Environment and Environmental Consequences 

3-326 Final EIS, Wright Area Coal Lease Applications

The Center for Climate Strategies estimates that activities in Wyoming will 

account for approximately 60.3 million tonnes of gross CO2e emissions in 2010 

and 69.4 million tonnes in 2020 (Center for Climate Strategies 2007). Using 

those projections, the 2007 emissions from the three applicant mines total 

(Table 3-24) represents 2.22 percent of the 2010 state-wide CO2e emissions. 

With the addition of the North Hilight Field, South Hilight Field, West Hilight 

Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts, 

the estimated total CO2e emissions at the three applicant mines would 

represent 3.61 percent of the projected 2020 state-wide emissions. 

As mentioned above, the CO2e estimates for the WAC LBA tracts in Table 3-24 

include projected methane emissions vented from exposed, unmined coal, given 

the applicant mines’ anticipated annual production rates. Using the gas 

content data obtained by the USGS and WSO-RMG (2006) from coal cores that 

the agencies collected in the vicinity of the applicant mines, the amount of 

methane vented annually, expressed as CO2e, was calculated to be 

approximately 761.57 tonnes per million tons of coal. Based on the 2007 

combined coal production from the three applicant mines, the estimated 

annual methane emissions vented from exposed unmined coal at these mines 

was 164,347 tonnes (WWC 2009). The total methane emissions from all 

anthropogenic sources in the U.S. in 2007 was 722.7 million tonnes (USDOE 

2009a); therefore, about 0.02 percent of that total was from exposed coal at 

these three mines. Based on the applicant mines’ projected maximum future 

mining rates, the estimated contribution of CO2e emissions from vented coal 

bed methane would be approximately 205,624 tonnes per year during the 

mining of the WAC LBA tracts, or about 8.2 percent of the estimated total 

annual CO2e emissions that are expected to result from mining the LBA tracts. 

Section 4.2.14 includes an assessment of cumulative impacts related to GHGs, 

and how the Action Alternatives considered in this EIS contribute. 

3.18.2.1 Regulatory Compliance, Mitigation and Monitoring

In 2009, EPA issued the Mandatory Reporting of Greenhouse Gases Rule, 

which requires reporting of GHG emissions from large sources and suppliers in 

the U.S. The rule was signed by the Administrator on September 22, 2009, 

and it became effective December 29, 2009 (EPA 2010a). Under the rule, 

suppliers of fossil fuels or industrial greenhouse gases, manufacturers of 

vehicles and engines, and facilities that emit 25,000 tonnes or more per year of 

GHG emissions are required to submit annual reports to the EPA. EPA 

believes that the new reporting system will provide a better understanding of 

where GHGs are coming from and will guide development of the best possible 

policies and programs to reduce emissions. 

The PRB mines are suppliers of fossil fuel and each emits more than 25,000 

tonnes of GHGs per year. However, EPA did not finalize reporting requirements 

for coal suppliers with other source categories in the Final Rule, Subpart KK 

(EPA 2010b). The agency anticipates making these reporting requirements 
3.0 Affected Environment and Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 3-327 

known by January 1, 2011 so that record keeping can begin and the first 

annual GHG emissions reports can be submitted in 2012. If a coal mine has 

general stationary fuel combustion units and the facility emits more than 

25,000 tonnes CO2e per year from stationary combustion, then the mine must 

report stationary combustion source emissions for calendar year 2010. The 

three applicant mines, with or without the WAC LBA tracts, do not approach 

this stationary source threshold. Therefore, it is anticipated that formal 

recording and reporting of GHG emissions for the PRB mines, including the 

three applicant mines, will commence in January 2011. 

Control of GHG emissions is not required by permit at the PRB coal mines. 

However, the reduction of GHG emissions and management of carbon footprint 

at the mines is being implemented through the following measures: 

• using new mining technologies and striving to continually improve the 

efficiency of each phase of the operation, from haul road design to seed 

planting at final reclamation; 

• implementing new blasting technology to achieve the greatest efficiency 

in moving overburden and the highest degree of reducing emissions from 

the blasting agent; 

• minimizing blast size to the extent possible and using the appropriate 

blend of blasting agents (i.e., ANFO slurries and gels) to match the 

overburden properties; 

• reducing fuel consumption to the greatest extent possible by improving 

fuel efficiency, use of highly efficient engines, and restricting idling times; 

and 

• suppressing in-pit coal fires promptly. 

3.19 Irreversible and Irretrievable Commitments of Resources 

The major commitment of resources would be the mining and consumption of 

2,435.4 million tons (Proposed Action for all six LBA tracts) up to a maximum 

of 3,910.6 million tons (Alternative 2, BLM’s preferred alternative, for all six 

LBA tracts) 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 

Sections 3.18 and 4.2.14). It is estimated that 1 to 2 percent of the energy 

produced would be required to mine the coal, and this energy would also be 

irretrievably lost. 

The characteristics of topsoil on approximately 32,783 acres (total for all six 

LBA tracts, each under the Proposed Action) up to a maximum of 

approximately 50,773 acres (total for all six LBA tracts, each under Alternative 

2, BLM’s preferred alternative) would be irreversibly changed. Soil formation 
3.0 Affected Environment and Environmental Consequences 

3-328 Final EIS, Wright Area Coal Lease Applications

processes, although continuing, would be irreversibly altered during miningrelated activities. Newly formed soil material would be similar but not identical 

to that in the natural landscape. 

Direct and indirect wildlife deaths caused by mining operations or associated 

activity would be an irreversible loss. No T&E species (animal or plant) that are 

listed for Campbell County are known to occur on the BLM study area for each 

of the six LBA tracts, therefore none would be lost as a result of the Proposed 

Actions or alternatives. The black-tailed prairie dog is the most common 

sensitive species in the area and it therefore has the most potential to be 

affected (killed or injured) by activities in or near their colonies, and habitat 

would be lost until reclamation takes place. Any activities that jeopardize 

prairie dogs and their habitat would also affect those sensitive species that are 

strongly associated with them, namely the mountain plover, burrowing owl, 

chestnut-collared longspur, and McCown’s longspur. Despite their strong 

association with prairie dogs, these avian species can all utilize short-grass 

habitats other than prairie dog colonies; however, they would benefit from the 

presence of undisturbed prairie dog colonies. Direct and indirect deaths of 

other sensitive species that occur on the LBA tracts (refer to Appendix H) 

caused by mining operations or associated activity would be an irreversible 

loss. 

Loss of human 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 the Mine Safety and Health Administration (MSHA) 

(1997) for the 10-year period 1987-1996, fatal accidents (excluding contractors) 

occur at the rate of 0.003 per 200,000 man-hours worked. Disabling (losttime) injuries occur 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 cultural sites eligible for the 

NRHP on the mine areas would be mitigated to the maximum extent possible. 

However, accidental destruction of presently unknown archeological or 

paleontological values would be irreversible. 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-1 

4.0 CUMULATIVE ENVIRONMENTAL CONSEQUENCES 

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. 

This section summarizes the cumulative impacts that are occurring as a result 

of existing development in the Powder River Basin (PRB1) and considers how 

those impacts would change if other projected development in the area occurs 

and if the six lease by application (LBA) tracts in the general Wright analysis 

area are leased and mined. 

BLM completed three regional Environmental Impact Statements (EISs) 

evaluating the potential cumulative impacts of surface coal development in the 

1970s and early 1980s (BLM 1974, 1979, and 1981). A draft document for a 

fourth regional EIS was prepared and released in 1984 (BLM 1984). Since 

those regional EISs were prepared, BLM has prepared a number of NEPA 

(National Environmental Policy Act of 1969) analyses evaluating coal leasing 

actions and oil and gas development in the PRB. Each of these NEPA analyses 

includes an analysis of cumulative impacts in the Wyoming PRB. 

Recently, the BLM completed 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 PRB Coal Review consists of three tasks: 

• Task 1 identifies existing resource conditions in the PRB for the baseline 

year (2003) and, for applicable resources, updates the BLM's 1996 status 

check for coal development in the PRB. 

• Task 2 defines the past and present development activities in the PRB 

and their associated development levels as of 2003 and develops a 

forecast of reasonably foreseeable development in the PRB through 2020. 

The reasonably foreseeable activities fall into three broad categories: coal 

development (coal mine and coal-related), oil and gas development 

(conventional oil and gas, coal bed natural gas, and major transportation 

pipelines), and other development, which includes development that is 

not energy-related as well as other energy-related development. 

• Task 3 predicts the cumulative impacts that could be expected to occur 

to air, water, socioeconomic, and other resources if the development 

occurs as projected in the forecast developed under Task 2. 

A series of reports have been prepared to present the results of the PRB Coal 

Review task studies. The Task 1, 2, and 3 reports represent components of a 

technical study of cumulative development in the PRB; they do not evaluate 

 

1 Refer to page xxvii for a list of abbreviations and acronyms used in this document. 
4.0 Cumulative Environmental Consequences 

4-2 Final EIS, Wright Area Coal Lease Applications 

specific proposed projects, but they provide information that BLM is using to 

evaluate the cumulative impacts that would be expected to occur if specific 

projects or applications, such as the six LBA tracts in the general Wright 

analysis area, are approved. The Task 1 reports, which include air quality 

conditions, water resources conditions, social/economic conditions, and other 

environmental resource conditions, and the Task 2 Report have been 

completed. An update of the Task 2 Report is reflected in this document. The 

Task 3 reports for air quality conditions, social/economic conditions, and other 

resource conditions have been completed. The Task 3A Cumulative Air Quality 

Effects were included in the draft of this EIS to project air quality effects for 

2015. After the draft of this EIS was issued, modeling of Cumulative Air 

Quality Effects for 2020 was completed (the Task 3A Supplemental Report) and 

the new data and analysis is reflected in this Final EIS. The groundwater 

impacts modeling portion of the Cumulative Water Effects (the Task 3B Report) 

was recently completed and is also reflected in this document along with the 

cumulative surface water effects. The information in these reports is 

summarized later in this chapter, and the completed reports are available for 

viewing at the BLM offices in Casper and Cheyenne and on the Wyoming BLM 

website at http://www.blm.gov/wy/st/en/programs/energy/Coal_Resources/

PRB_Coal/prbdocs.html. 

The PRB includes portions of northeastern Wyoming and southeastern 

Montana. The Wyoming portion of the PRB is the primary focus of the PRB 

Coal Review reports. The Montana portion of the PRB is included in the Task 2 

Report and in the Task 1 and 3 air resources studies. For the majority of 

resources in the Task 1 reports and for the Task 2 Report, the Wyoming portion 

of the PRB Coal Review study area encompasses all of Campbell County, all of 

Sheridan and Johnson counties outside of the Bighorn National Forest, and the 

northern portion of Converse County (Figure 4-1). For some components of the 

Task 2 Report and for the Task 1 and 3 air resource studies, the Montana PRB 

Coal Review study area includes portions of Big Horn, Custer, Powder River, 

Rosebud, and Treasure counties. For several resources, the Task 1 and Task 3 

study areas include only potentially affected portions of the Wyoming PRB Coal 

Review study area; for other resources, the study area extends outside of 

Wyoming and Montana because the impacts would extend beyond the PRB. 

For example, the groundwater drawdown is evaluated in the area surrounding 

and extending west of the mines, because that is the area where surface coal 

mining operations and coal bed natural gas (CBNG) production operations 

would impact groundwater resources; but air quality impacts are evaluated 

over a multi-state area because they would be expected to extend beyond the 

PRB. 

Section 4.1 summarizes the information presented in the PRB Coal Review 

Task 1 and Task 2 reports. Section 4.2 summarizes the predicted cumulative 

impacts to air, water, socioeconomic, and other resources presented in the PRB 

Coal Review Task 3 reports. 
CAMPBELL

COUNTY

SHERIDAN

COUNTY

JOHNSON

COUNTY

CONVERSE

COUNTY

SHERIDAN

BUFFALO

GILLETTE

WRIGHT

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

1

2

3

B.N.S.F. RR

Buckskin, Dry Fork, Eagle Butte,

Rawhide, and Wyodak Mines 1 Subregion 1 -

2

3

Belle Ayr, Caballo, Coal Creek, and

Cordero-Rojo Mines Subregion 2 -

Jacobs Ranch, Black Thunder,

North Antelope Rochelle,

and Antelope Mines

Subregion 3 -

SCALE: 1"= 20 MILES

COAL MINE SUBREGIONS

LEGEND

Federal Coal Lease Areas

Railroads

Former Surface Coal Mine Sites

PSO Ash

Creek Mine

Big

Horn

Mine

Dave

Johnston

Mine

B.N.S.F. RR

Task 1 and 2 Study Boundary

Existing and Proposed Power Plants

Two Elk

Unit 1

Hartzog

Barber

Creek

Arvada

Dave

Johnston

Dry Fork Station

Wygen I

Wygen II

Wyodak

Neil Simpson 1

Neil Simpson 2

Figure 4-1. Wyoming Study Area for PRB Coal Review Evaluating Current and Projected Levels of Development.

4.0 Cumulative Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 4-3
4.0 Cumulative Environmental Consequences 

4-4 Final EIS, Wright Area Coal Lease Applications 

4.1 Past, Present, and Reasonably Foreseeable Development 

Past, present, and reasonably foreseeable development in the Wyoming PRB are 

considered in the Task 1 and Task 2 reports for the PRB Coal Review. The 

Task 1 reports describe the existing situation as of the end of 2003, which 

reflects the past and present levels of development. The Task 2 Report defines 

the past and present development activities in the PRB as of the end of 2003 

and projects reasonably foreseeable development in the Wyoming PRB through 

2020. Task 2 was updated based on actual levels of development through 

2007, and current development estimates available through year 2009 (BLM 

2009b). 

4.1.1 Coal Development

4.1.1.1 Coal Mine Development

The Powder River Federal Coal Region was decertified as a federal coal 

production region by the Powder River Regional Coal Team (PRRCT) in 1990. 

Decertification of the region allows leasing to take place on an application 

basis, as discussed in the regulations at 43 CFR 3425.1-5. Between 1990 and 

January 2009, the BLM’s Wyoming State Office held 25 competitive coal lease 

sales and issued 20 new federal coal leases containing almost 5.8 billion tons 

of coal using the LBA process. The lease sales are listed in Table 1-1, and the 

leased tracts are shown in Figure 1-1. This leasing process has undergone the 

scrutiny of two appeals to the Interior Board of Land Appeals (IBLA) and one 

audit by the General Accounting Office (GAO). As can be seen in Figure 4-2, 

leasing activity has generally paralleled production since decertification. This 

is consistent with the PRRCT’s objective at the time of decertification, which 

was to use the LBA process to lease tracts of federal coal to maintain 

production at existing mines. 

The pending applications in the Wyoming PRB are shown in Table 1-2. 

BLM has also completed three exchanges involving federal coal resources in the 

Wyoming PRB since decertification: 

• Belco Exchange – an exchange of lease rights for a portion of the former 

Hay Creek federal coal tract for lease rights to coal near Buffalo, 

Wyoming, which became unmineable when Interstate 90 was 

constructed. This exchange was authorized by Public Law 95-554 and 

completed in 2000. 

• Pittsburg and Midway Coal Mining Company (P&M) Exchange – an 

exchange of federal coal in Sheridan County, Wyoming, for land and 

mineral rights in Lincoln, Carbon, and Sheridan counties, Wyoming, 

completed in 2004. 
Cumulative Tons Federal Coal Leased by Year

Cumulative Tons Federal Coal Mined by Year

Powder River Basin

Campbell and Converse Counties, Wyoming

6,000,000,0005,000,000,0004,000,000,0003,000,000,0002,000,000,0001,000,000,000

0

Tons

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000

Year

2001 2002 2003 2004 2005 2006 2007 2008 2009

7,000,000,000

Figure 4-2. Tons of Federal Coal Leased Versus Tons of Federal Coal Mined Since 1990.

4.0 Cumulative Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 4-5
4.0 Cumulative Environmental Consequences 

4-6 Final EIS, Wright Area Coal Lease Applications 

• Powder River Coal Company AVF Exchange – an exchange of lease rights 

underlying an AVF at the Caballo Mine, which cannot be mined, for lease 

rights of equal value adjacent to existing federal leases at Powder River 

Coal Company’s North Antelope Rochelle Mine, completed in 2006. 

Table 4-1 provides information about the status, ownership and production 

levels for the existing surface coal mines in the Wyoming PRB in 2003 and their 

status as of 2007. In 2003, which was the baseline year for the PRB Coal 

Review Task 1 and Task 2 studies, there were 12 active surface coal mines and 

one inactive mine. Since 2003, the inactive mine (Coal Creek) has resumed 

operations and the North Rochelle Mine has been incorporated into the Black 

Thunder Mine following its purchase by the operator of the Black Thunder 

Mine. The North Rochelle Mine leases were divided between Black Thunder 

and North Antelope Rochelle Mine in 2006. Peabody has deferred startup of 

their new mine, the School Creek Mine, which is located between the Black 

Thunder and North Antelope Rochelle mines, until at least late 2010, or later. 

These mines are all located in Campbell and Converse counties, just west of 

the outcrop of the Wyodak coal, where the coal is at the shallowest depth 

(Figure 1-1). As indicated in Table 4-1, there have been numerous changes in 

mine ownership since decertification, which have resulted in mine 

consolidations and mine closings within the PRB. 

Two recently active surface coal mines (the Big Horn Coal Mine in northern 

Sheridan County and the Dave Johnston Mine in southern Converse County) 

in the PRB have ended mining operations, relinquished their federal coal 

leases, and reclaimed areas of disturbance. The lands within the Dave 

Johnston Mine permit boundary are owned by PacifiCorp. PacifiCorp 

requested a change in post mining land use from livestock/wildlife grazing to 

industrial for the areas that would be affected by a wind energy project right-ofway. Some of the area was on full reclamation bond release and some area 

included was on pre-law lands. Wyoming Department of Environmental 

Quality/Land Quality Division (WDEQ/LQD) approved this change of land use 

in three stages between September of 2007 and May of 2008. The Glenrock 

Wind Energy Project is sited at the reclaimed surface coal mine and it began 

operations in late 2008 and early 2009. 

There are existing permits for other surface coal mining-related operations in 

the PRB. These include the Ash Creek and Welch Mine permits in Sheridan 

County and the Izita Mine permit in Campbell County. Operations at these 

sites are completed and the disturbed areas have been reclaimed, but 

monitoring of the reclaimed areas is no longer ongoing. The KFx Mine, located 

north of Gillette on privately owned coal, has stopped mining coal for 

processing at the KFx coal enhancement plant, which is discussed in Section 

4.1.1.2.4. The Fort Union plant was idled down in March 2008, until further 

notice. 

The active mines in the Wyoming PRB are geographically grouped into three 

subregions (Figure 4-1). For purposes of this cumulative impact discussion,
4.0 Cumulative Env

Final EIS, Wright Area Coal Lease Applications 4-7 

Table 4-1. Status and Ownership of Wyoming PRB Coal Mines for 2003, the PRB Coal Review Base2003 Mine

1994 

Mine Owner

2007 

Mine Owner

2007 

Coal 

Production

(mm Tons)1 

Permitted 

Production 

Level 

(mm Tons)2 Status and A

SUBREGION 1 (North Gillette) 

Buckskin SMC (Zeigler) Kiewit Mining Properties 25.3 42.0 Active Dry Fork Phillips/WFA & Fort Union Ltd WFA 5.3 15.0 Active (includes form

Eagle Butte Cyprus-Amax Foundation Coal West 25.0 35.0 Active Rawhide Carter (Exxon) Peabody Holding Co. 17.1 24.0 Active Wyodak Wyodak Resources Wyodak Resources 5.0 12.0 Active (includes form

Total 77.7 128.0

SUBREGION 2 (South Gillette) 

Belle Ayr Cyprus-Amax Foundation Coal West 26.6 45.0 Active Caballo Carter (Exxon) & Western Energy Peabody Holding Co. 31.2 50.0 Active (includes Roc

Butte leases) 

Cordero Rojo Kennecott & Drummond Rio Tinto Energy America3 40.5 65.0 Active (consolidatio

Caballo Rojo Mines

Coal Creek ARCO Arch Coal Inc. 10.2 25.0 Inactive in 2003, opTotal 108.5 185.0

SUBREGION 3 (Wright)

Antelope Kennecott Rio Tinto Energy America3 34.5 36.0 Active Black Thunder ARCO Arch Coal Inc. 65.3 100.0 Active Jacobs Ranch Kerr-McGee Rio Tinto Energy America3 38.1 55.0 Active 

North Antelope Rochelle Peabody Peabody Holding Co. 91.5 99.0 Active (consolidatio

and Rochelle Mines

North Rochelle SMC (Zeigler) Arch Coal Inc. 20.9 35.0 Inactive since 2005

Thunder and North 

Total 250.3 325.0

TOTAL FOR 3 MINE GROUPS 436.5 638.0

1 Wyoming State Inspector of Mines (2007a) and Shamley (2008) 2 WDEQ 2007 permitting levels (Shamley 2008) 3 Kennecott Energy Company changed its name to Rio Tinto Energy America in 2006. 
4.0 Cumulative Environmental Consequences 

4-8 Final EIS, Wright Area Coal Lease Applications 

these subregions are called the North Gillette, South Gillette, and Wright 

subregions. Table 4-1 lists the mines included in each subregion. 

A fourth subregion includes former and proposed mines in Sheridan County 

and existing mines just north of Sheridan County, in Montana. There are 

currently no active mines in the Wyoming portion of the fourth subregion. 

However, the PRB Coal Review Task 2 Report projected that a new mine would 

be developed near Sheridan by 2010. In April, 2007, P&M and CONSOL 

Energy Inc. announced that they have formed a new company, Youngs Creek 

Mining Company, LLC, and entered into a joint agreement to develop a new 

mine in Wyoming north of Sheridan (Reuters 2007). According to the 

announcement, engineering, environmental and permitting work are in 

progress, but actual mine construction will not start until the joint venture has 

enough coal sales under contract to justify the investment. The coal reserves 

included in this project are all privately owned. 

The surface coal mines listed in Table 4-1 currently produce over 96 percent of 

the coal produced in Wyoming each year. Since 1989, coal production in the 

PRB has increased by an average of 6 percent per year. The increasing 

production is primarily due to increasing sales of low-sulfur, low-cost PRB coal 

to electric utilities who must comply with the Phase I requirements of Title III of 

the 1990 Clean Air Act Amendments. Electric utilities account for 97 percent 

of Wyoming’s coal sales. In 2009, production from the Wyoming PRB coal 

mines dropped by about 7 percent from the 2008 levels, the first drop since the 

early 1900s. This drop coincided with a national coal production decline due 

to reduced industrial electric demand in 2009. 

In 2003 (the baseline year for the PRB Coal Review), more than 35 percent of 

the coal mined in the United States came from the Wyoming PRB. By 2007, 

about 38 percent of the coal mined in the United States came from the 

Wyoming PRB (USDOE 2009a), and according to the U.S. Department of 

Energy (USDOE), over 38 percent of the coal mined in the United States came 

from the Wyoming PRB by 2009. 

BLM estimates that the surface coal mines listed in Table 4-1 currently have 

about 125,180 acres of federal coal leased in Campbell and Converse counties. 

This represents approximately 4.1 percent of Campbell County, where the 

majority of the leases are located. 

Task 2 of the PRB Coal Review projected coal development into the future for 

the years 2010, 2015, and 2020. Due to the variables associated with future 

coal production, two projected coal production scenarios (representing an 

upper and a lower production level) were developed to bracket the most likely 

foreseeable regional coal production level. The basis for the projected 

production levels included: 

1) an analysis of historic PRB production levels in comparison to the gross 

domestic product and national coal demand; 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-9 

2) an analysis of PRB coal market forecasts that model the impact of gross 

domestic product growth, potential regulatory changes affecting coalfired power plants, and mining and transportation costs on PRB coal 

demand; 

3) the availability, projected production cost, and quality of future minespecific coal reserves within the PRB region; and 

4) the availability of adequate infrastructure for coal transportation. 

The projected upper and lower production levels subsequently were allocated to 

the Wyoming PRB subregions, discussed above, and to individual mines based 

on past market shares. Individual mine production levels were reviewed 

relative to potential future production constraints (e.g., loadout capacities), 

permitted production levels, mining costs, and coal quality. Then the projected 

future production was aggregated on a subregion basis. The actual 2003 and 

2005 production levels and the two projected coal production scenarios for 

those years are shown on Figure 4-3. The two projected production levels for 

2010, 2015, and 2020 are shown on Figure 4-3 and in Tables 4-2 and 4-3. 

The actual 2007 and 2008 production levels are also shown on Figure 4-3 as a 

reference. 

Tables 4-2 and 4-3 show the cumulative coal mining disturbance as of the 

baseline year and the cumulative coal mine disturbance projected for the 

future years for the upper and lower coal production scenarios. In these 

tables, the baseline year (2003), actual values as of 2007, and cumulative 

projected disturbance areas for 2010, 2015 and 2020 are broken down into 

three categories: 

• areas which are or projected to be permanently reclaimed; 

• areas which are or projected to be undergoing active mining or which 

have been mined but are not yet reclaimed; and, 

• areas which are or projected to be occupied by mine facilities, haul 

roads, stockpiles, and other long-term structures, and which are 

therefore unavailable for reclamation until mining operations are 

completed. 

Tables 4-2 and 4-3 also include estimates of baseline year and projected future 

coal mining employment, water consumption, and water production. 

The six LBA tracts in the general Wright analysis area are associated with three 

of the four currently operating mines (Jacobs Ranch, Black Thunder, North 

Antelope Rochelle, and Antelope) in the southern-most group of mines in the 

eastern PRB (Figure 1-1). This group of mines is referred to as the Wright 

Subregion or Subregion 3 in the PRB Coal Review. Each of these four 

operating mines has a least one LBA pending (Table 1-2). The analysis 
Lower Production Scenerio

0

100,000,000

Upper Production Scenario

Tons/

Year

600,000,000500,000,000400,000,000300,000,000200,000,000

Year

2003 2005 2010 2015 2020 2007

Actual Production

2008

Figure 4-3. Projected and Actual Total Coal Production from Campbell and Converse Counties Under the

Lower and Upper Production Scenarios.

4.0 Cumulative Environmental Consequences

4-10 Final EIS, Wright Area Coal Lease Applications
4.0 Cumulative Env

Final EIS, Wright Area Coal Lease Applications 4-11 

Table 4-2. Actual and Projected Wyoming PRB Coal Mine Development, Lower Coal Production SceSubregion 

Annual 

Production 

(million tons) 

Cumulative 

Disturbed 

Area 

(acres) 

Cumulative 

Permanently 

Reclaimed 

Area 

(acres) 

Cumulative 

Active Mining 

Area and 

Unreclaimed 

Mined Area 

(acres) 

Cumulative 

Area 

Disturbed and 

Unavailable 

for 

Reclamation1 

(acres) 

Total Mine 

Employment 

Original Baseline Year (2003) 

North Gillette Subregion 55 12,047 3,054 3,360 5,633 746 South Gillette Subregion 77 21,249 6,783 6,107 8,359 861 Wright Subregion 232 35,498 11,401 13,992 10,105 3,090 Total for 2003 364 68,794 21,238 23,459 24,097 4,697 

Actual 2007 

North Gillette Subregion 78 14,421 3,658 8,342 5,781 1,032 South Gillette Subregion 100 23,630 6,441 12,353 9,273 1,424 Wright Subregion 250 45,542 15,785 31,577 11,941 3,077 Total for 2007 428 83,593 25,884 52,272 24,338 5,533 

Reasonably Foreseeable Development for 2010 

North Gillette Subregion 62 15,231 5,004 3,968 6,260 787 South Gillette Subregion 95 28,021 12,183 6,830 9,008 1,323 Wright Subregion 254 55,410 27,751 16,588 11,070 3,153 Total for 2010 411 98,662 44,938 27,386 26,338 5,263 

Reasonably Foreseeable Development for 2015 

North Gillette Subregion 74 17,457 6,654 4,202 6,601 830 South Gillette Subregion 112 32,356 15,683 7,314 9,359 1,369 Wright Subregion 281 67,423 38,851 16,983 11,589 3,186 Total for 2015 467 117,236 61,188 28,499 27,549 5,405 

Reasonably Foreseeable Development for 2020 

North Gillette Subregion 78 19,729 8,429 4,350 6,950 840 South Gillette Subregion 126 36,994 19,683 7,589 9,723 1,476 Wright Subregion 291 80,720 51,351 17,243 12,124 3,215 Total for 2020 495 137,443 79,463 29,182 28,797 5,531 1 Area unavailable for reclamation includes disturbed areas occupied by permanent or long-term facilities such as buildings, roads, topsoil stockpSource: PRB Coal Review Task 2 Update Report (BLM 2009b)
4.0 Cumulative Environmental Consequences 

 4-12 Final EIS, Wright Area Table 4-3. Actual and Projected Wyoming PRB Coal Mine Development, Upper Coal Production SceSubregion 

Annual 

Production 

(million tons) 

Cumulative 

Disturbed 

Area 

(acres) 

Cumulative 

Permanently 

Reclaimed 

Area 

(acres) 

Cumulative 

Active Mining 

Area and 

Unreclaimed 

Mined Area 

(acres) 

Cumulative 

Area 

Disturbed and 

Unavailable 

for 

Reclamation1 

(acres) 

Total Mine 

Employment 

Original Baseline Year (2003) 

North Gillette Subregion 55 12,047 3,054 3,360 5,633 746 South Gillette Subregion 77 21,249 6,783 6,107 8,359 861 Wright Subregion 232 35,498 11,401 13,992 10,105 3,090 Total for 2003 364 68,794 21,238 23,459 24,097 4,697 

Actual 2007 

North Gillette Subregion 78 14,421 3,658 8,342 5,781 1,032 South Gillette Subregion 100 23,630 6,441 12,353 9,273 1,424 Wright Subregion 250 45,542 15,785 31,577 11,941 3,077 Total for 2007 428 83,593 25,884 52,272 24,338 5,533 

Reasonably Foreseeable Development for 2010 

North Gillette Subregion 78 15,911 5,404 4,217 6,290 811 South Gillette Subregion 117 29,279 13,416 7,536 8,328 1,375 Wright Subregion 284 57,258 27,951 18,236 11,070 3,153 Total for 2010 479 102,448 46,771 29,989 25,688 5,339 

Reasonably Foreseeable Development for 2015 

North Gillette Subregion 104 18,490 7,329 4,500 6,660 905 South Gillette Subregion 138 35,624 18,616 8,248 8,760 1,431 Wright Subregion 301 70,431 39,451 19,391 11,589 3,186 Total for 2015 543 124,545 65,396 32,139 27,009 5,522 

Reasonably Foreseeable Development for 2020 

North Gillette Subregion 121 21,311 9,529 4,766 7,013 1,019 South Gillette Subregion 148 42,981 25,016 8,758 9,206 1,444 Wright Subregion 307 84,797 51,651 21,021 12,124 3,215 Total for 2020 576 149,089 86,196 34,545 28,345 5,678 1 Area unavailable for reclamation includes disturbed areas occupied by permanent or long-term facilities such as buildings, roads, topsoil stockpSource: PRB Coal Review Task 2 Update Report (BLM 2009b)
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-13 

assumes that if the LBAs are offered and if the applicant becomes the lessee, 

each mine will increase current production to a level where the four mines 

collectively will produce at an aggregate production level midway between the 

low and high projected coal production scenarios for 2015 and 2020 shown on 

Figure 4-3 and in Tables 4-2 and 4-3. The coal development levels and 

associated disturbance shown in Tables 4-2 and 4-3 include production at the 

four Wright area mines during the baseline year (2003) and projected 

production at the mines for 2010, 2015, and 2020. 

As discussed above, the projected development levels shown in Tables 4-2 and 

4-3 are based on projected demand and coal market forecasts, which are not 

affected by a decision to lease or not to lease the six LBA tracts in the general 

Wright analysis area. The reserves in these six LBA tracts, if offered, and if the 

applicants become the lessees, would add to the mine life of each of the three 

Wright Area Coal (WAC) mines. 

As discussed in Sections 1.1 and 2.1, Ark Land Company (ALC) estimates that 

there were 1,169.4 million tons of recoverable coal reserves on the existing 

Black Thunder Mine at the end of 2008. In 2008, the mine produced 

approximately 67.4 million tons and the currently approved (by Wyoming 

Department of Environmental Quality/Air Quality Division) air quality permit 

allows mining of up to 135 million tons of coal per year (mmtpy). If the mine 

produces at the estimated average of 135 mmtpy, the remaining recoverable 

reserves would be depleted in about 9 years (by 2017). ALC estimates that the 

North Hilight Field LBA Tract includes approximately 263.4 million tons of 

recoverable coal as applied for. Based on that estimate, acquisition of the 

North Hilight Field LBA Tract would increase the recoverable reserves at the 

Black Thunder Mine by about 23 percent. At the estimated future production 

level (135 mmtpy), mine life would be extended by about 2 years. However, if 

the Wyoming Department of Environmental Quality/Air Quality Division 

(WDEQ/AQD) approves a higher annual rate of production, the coal would be 

recovered more quickly. ALC estimates that the South Hilight Field LBA Tract 

includes approximately 213.6 million tons of recoverable coal as applied for. 

Based on that estimate, acquisition of the South Hilight Field LBA Tract would 

increase the recoverable reserves at the Black Thunder Mine by about 18 

percent. At the estimated future production level (135 mmtpy), mine life would 

be extended by about 1.6 years. However, if WDEQ/AQD approves a higher 

annual rate of production, the coal would be recovered more quickly. ALC 

estimates that the West Hilight Field LBA Tract includes approximately 377.9 

million tons of recoverable coal as applied for. Based on that estimate, 

acquisition of the West Hilight Field LBA Tract would increase the recoverable 

reserves at the Black Thunder Mine by nearly 32 percent. At the estimated 

future production level (135 mmtpy), mine life would be extended by about 2.8 

years. However, if WDEQ/AQD approves a higher annual rate of production, 

the coal would be recovered more quickly. 

As discussed in Sections 1.1 and 2.1, Jacobs Ranch Coal Company (JRCC) 

estimates that there were 379.4 million tons of recoverable coal reserves on the 
4.0 Cumulative Environmental Consequences 

4-14 Final EIS, Wright Area Coal Lease Applications 

existing Jacobs Ranch Mine at the end of 2008. In 2008, the mine produced 

approximately 42.1 million tons and the currently approved (by WDEQ/AQD) 

air quality permit allows mining of up to 55 mmtpy. If the mine produces at 

the estimated average of 40 mmtpy, the remaining recoverable reserves would 

be depleted in about 9.6 years (by 2018). JRCC estimates that the West 

Jacobs Ranch LBA Tract includes approximately 669.6 million tons of 

recoverable coal as applied for. Based on that estimate, acquisition of the West 

Jacobs Ranch LBA Tract would increase the recoverable reserves at the Jacobs 

Ranch Mine by about 177 percent. At the estimated future production level (40 

mmtpy), mine life would be extended by about 16.7 years. However, if 

production levels increase to the currently permitted level (55 mmtpy) or if 

WDEQ/AQD approves a higher annual rate of production, the coal would be 

recovered more quickly. 

As discussed in Sections 1.1 and 2.1, BTU Western Resources, Inc. (BTU) 

estimates that there were 933.8 million tons of recoverable coal reserves on the 

existing North Antelope Rochelle Mine at the end of 2008. In 2008, the mine 

produced approximately 97.6 of coal million tons and the currently approved 

(by WDEQ/AQD) air quality permit allows mining of up to 140 mmtpy. If the 

mine produces at the estimated average of 95 mmtpy, the remaining 

recoverable reserves would be depleted in about 9.9 years (by 2018). BTU 

estimates that the North Porcupine LBA Tract includes approximately 601.2 

million tons of recoverable coal as applied for. Based on that estimate, 

acquisition of the North Porcupine LBA Tract would increase the recoverable 

reserves at the North Antelope Rochelle Mine by about 64 percent. At the 

estimated future production level (95 mmtpy), mine life would be extended by 

about 6.3 years. However, if production levels increase to the currently 

permitted level (140 mmtpy) or if WDEQ/AQD approves a higher annual rate of 

production, the coal would be recovered more quickly. BTU estimates that the 

South Porcupine LBA Tract includes approximately 309.7 million tons of 

recoverable coal as applied for. Based on that estimate, acquisition of the 

South Porcupine LBA Tract would increase the recoverable reserves at the 

North Antelope Rochelle Mine by about 33 percent. At the estimated future 

production level (95 mmtpy), mine life would be extended by about 3.3 years. 

However, if production levels increase to the currently permitted level (140 

mmtpy) or if WDEQ/AQD approves a higher annual rate of production, the coal 

would be recovered more quickly. 

4.1.1.2 Coal-Related Development

Coal-related development as defined for this analysis includes railroads, coalfired power plants, major (230-kV) transmission lines, and coal technology 

projects. Table 4-4 summarizes the estimated disturbance associated with 

coal-related development activities for the baseline year and the projected 

disturbance through 2020. The subsequent paragraphs summarize the 

existing coal-related development in the Wyoming PRB and the reasonably 

foreseeable development considered in the PRB Coal Review. 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-15 

Table 4-4. Actual and Projected Wyoming PRB Coal-Related Development 

Scenario. 

2003 2007 2010 2015 2020

Coal-Related Disturbance (Acres) 4,892 5,802 5,963 6,915 6,914 

Source: PRB Coal Review Task 2 Update Report (BLM 2009b) 

4.1.1.2.1 Coal Transportation

As discussed above, electric utilities account for about 97 percent of Wyoming’s 

coal sales. Most of the coal sold to electric utilities is transported to power 

plants by rail. A small part, about 2 percent in 2007, of national coal 

production is exported abroad, but data are not published as to where this 

export coal is produced. The coal mines in the South Gillette and Wright 

subregions are served by a joint Burlington Northern Santa Fe and Union 

Pacific (BNSF & UP) rail line. For the baseline year of 2003, the existing 

capacity of the line was estimated at approximately 350 mmtpy. For that same 

year, the existing capacity of the BNSF line, which services the North Gillette 

subregion, was estimated at 250 mmtpy. 

The PRB Coal Review projected that two coal transportation projects would be 

developed prior to 2020 in Wyoming: expansion of the BNSF & UP rail facilities 

south of Gillette, and the construction of the Dakota, Minnesota & Eastern 

Railroad Corporation (DM&E) rail line in Wyoming and South Dakota. A third 

project proposed by the Tongue River Rail Company would be built between 

Decker and Miles City, Montana. 

BNSF & UP completed work to improve sections of the existing joint rail line 

and had increased capacity from 350 mmtpy to 450 mmtpy by 2008 with plans 

to improve additional sections of the existing joint rail line and to further 

increase capacity to 500 mmtpy by 2012 (BNSF 2008, CANAC 2007). This 

work includes construction of third and fourth main line track segments where 

needed. The increased capacity would accommodate the projected upper and 

lower production rates at the southern mines, which are projected to produce 

439 mmtpy and 455 mmtpy by 2020. The remaining planned expansion 

projects are considered highly likely to occur. 

The proposed DM&E rail line would include new rail construction in South 

Dakota and Wyoming (approximately 15 and 265 miles, respectively) and 600 

miles of rail line rehabilitation in South Dakota and Minnesota. Approximately 

78 miles of the new rail line construction would provide new rail services to the 

coal mines in the South Gillette and Wright subregions. The Surface 

Transportation Board (STB) released a Final Supplemental EIS for the DM&E 

project on December 30, 2005 and granted final approval to construct the rail 

line on February 15, 2006. The Supplemental EIS, which addressed issues 

that were successfully appealed after an EIS was completed in 2001, was also 

appealed. The Supplemental EIS was upheld by the U.S. Court of Appeals for 

the Eighth Circuit in December 2006. In 2007, Canadian Pacific Railway Ltd. 
4.0 Cumulative Environmental Consequences 

4-16 Final EIS, Wright Area Coal Lease Applications 

(CP) acquired DM&E and the STB approved CP’s acquisition of DM&E on 

September 30, 2008 (All Business 2008). The railroad’s expansion into the 

PRB would require a substantial financial commitment and CP is concentrating 

on the integration of DM&E’s operation before making a decision on the 

expansion project. No decision has been made on whether or not CP will build 

the PRB extension. This decision is contingent on several conditions: (1) 

acquire the necessary right-of-way to build the line, (2) execute agreements 

with PRB mines on terms for operations by DM&E over their loading tracks and 

facilities, (3) secure sufficient contractual commitments from prospective coal 

shippers to route their traffic over the PRB line to justify the investment 

required to build the line, (4) arrange financing for the project, and (5) an 

economic and regulatory environment that would support a long-term 

investment of this magnitude must be present (DM&E 2009). 

The STB announced approval of the final stretch of the rail line proposed by 

the Tongue River Railroad Company in October 2007. The company must 

acquire necessary federal and state permits and rights-of-way (ROWs) through 

private and public property before constructing the line. If it is constructed, it 

would provide a shorter route for some of the mines in the North Gillette 

subregion, which ship coal on the existing BNSF rail line (Billings Gazette 

2007). 

For the purposes of the PRB Coal Review, it was projected that the DM&E line 

would be constructed when the total rail haulage requirement from the eastern 

Wyoming PRB reaches 450 to 500 mmtpy and would potentially be operational 

by 2015. The construction of this rail line is considered moderately likely to 

occur. The PRB Coal Review assigned a low likelihood of development by 2010 

under the upper coal production scenario, and projected the construction of 

the Tongue River Railroad Company line would not occur unless the Otter 

Creek Mine is developed. Development of the Otter Creek tracts–more than a 

billion tons of state and private coal–could initiate expansion of the region’s 

coal industry and facilitate construction of the Tongue River Railroad. 

Appraisals of the Otter Creek lease tracts were completed in April 2009 

(Billings Gazette 2009a) and the Montana Land Board voted to lease the 572 

million tons of state-owned coal in December 2009 (Billings Gazette 2009b). 

The Montana Board of Land Commissioners voted to approve the lease of the 

Otter Creek tracts to Ark Land Company on March 18, 2010 (MDNRC 2010). 

4.1.1.2.2 Electric Power Generation

Currently, there are five existing coal-fired power plants in the Wyoming study 

area for the PRB Coal Review Tasks 1 and 2 (Figure 4-1). Black Hills Power 

Corporation owns and operates the Neal Simpson Units 1 and 2 (21.7-

megawatts [MW] and 80-MW, respectively), Wygen I and II (80-MW and 95-MW, 

respectively), and Wyodak (330-MW) power plants, all of which are located 

approximately five miles east of Gillette, Wyoming. Pacific Power and Light’s 

Dave Johnston Power Plant is located near Glenrock, Wyoming, outside of but 

adjacent to the study area. 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-17 

There are also three separate interconnected gas-fired power plants (Hartzog, 

Arvada, and Barber Creek) located near Gillette, Wyoming (Figure 4-1). Each 

contains three separate 5-MW-rated turbines that provide electric power to 

Basin Electric and its customers. In winter, the maximum capacity can reach 

22.6-MW from each site. All units are in operating condition, although they do 

not operate at maximum capacity. 

Several additional power plants are projected to be built prior to 2020. The 

PRB Coal Review assumed that proposed coal-fired power plants that plan to 

initiate operation by 2010 would have to have been undergoing air permit 

review by 2003 in order to obtain the required construction permits and 

complete construction by 2010. The study identified the following four projects 

as likely for 2015 development: 

• Black Hills Power and Light has received an air permit for the start of 

construction of WYGEN III; issues related to that permit currently are 

being resolved. WYGEN III would be a 100-MW facility located adjacent 

to WYGEN II. The plant is in construction and nearing completion. 

Operation of this facility by 2015 is considered highly likely. 

• Basin Electric Power Cooperative has obtained an air construction permit 

for a 385-MW coal-fired power plant (Dry Fork Station) near Gillette, 

Wyoming. The estimated startup date is 2011. It is estimated that 1.2 

million tons of coal per year would be required to fuel the facility. The 

cooling technology includes a dry scrubber, since that type of operation 

commonly is installed for PRB coal-fired units. Operation of this facility 

by 2015 is considered highly likely. 

• North American Power Group (NAPG) has permitted a 280-MW coal-fired 

power plant (Two Elk Unit #1) at a 40-acre site located approximately 15 

miles southeast of Wright, Wyoming. As originally permitted, the project 

also would include installation of a 45-MW gas-fired turbine. The air 

permit originally was issued in August 2002; construction has been 

initiated, with actual startup expected in 2011. This unit would be drycooled, requiring very little water. Campbell County approved more than 

$123 million in industrial revenue bonds for application to the Two-Elk 

financing. Operation of this facility by 2015 is considered moderately 

likely. 

• Wyoming Power Company (a subsidiary of NAPG) has submitted a permit 

application for Two-Elk Unit #2. This unit would be a 750-MW 

supercritical pulverized coal-fired electric generating unit that would 

burn coal from the nearby mines. The unit would be located on an 

approximately 60-acre site adjacent to Two-Elk Unit #1. The permit was 

expected to be issued in 2008, and operation of this unit is considered 

moderately likely in 2015. 
4.0 Cumulative Environmental Consequences 

4-18 Final EIS, Wright Area Coal Lease Applications 

The PRB Coal Review assumes that all existing power plants in the PRB region 

would remain operational through 2020. 

4.1.1.2.3 Transmission Lines

Major transmission lines in the Wyoming PRB study area that support the 

regional distribution system are associated with the Dave Johnston power 

plant located near Glenrock, Wyoming, and the power plants operated by Black 

Hills Power Corporation, which are located east of Gillette. These 230-kV 

transmission lines have been in place for several years, and their associated 

permanent disturbance is minimal. Distribution power lines associated with 

conventional oil and gas and coal bed natural gas (CBNG) development also 

occur within the study area. For the PRB Coal Review, these lines were 

included by factoring them in proportionally on a per well basis. 

The PRB Coal Review estimated that by 2020, four major transmission lines 

would be constructed. Markets would dictate the size and location of such 

facilities, and these are not known as of this time. Because transmission lines 

are a necessary supporting infrastructure for power generating facilities to 

provide connection to the grid, the PRB Coal Review assumes they would be 

required as part of the overall system development for the proposed power 

plants discussed in the previous section. Six specific proposals for these 

transmission lines have been identified by the PRB Coal Review analysis 

update. There is currently insufficient information to analyze or assign 

likelihood of development by 2020. 

The governors of California, Nevada, Utah, and Wyoming entered into a 

Memorandum of Understanding to encourage development of a high voltage 

power transmission line, the Frontier Line, connecting those states in April, 

2005. Since that time, no specific plans have been announced as to the 

location or timing of the Frontier Line. The 345-kV Wyoming-Colorado Intertie, 

as well as the Trans West and Gateway West and South projects, have been 

proposed in Wyoming in order to move power from Wyoming to growing Idaho 

and Nevada and other western U.S. load demand areas (Casper Star Tribune 

2007b). The TransWestern Express proposes to move electric power from 

Wyoming to Arizona through Colorado or Utah. The High Plains Express is 

proposed to move power from Wyoming to New Mexico and Arizona. 

4.1.1.2.4 Coal Conversion Technology

With rising energy prices, there has been considerable interest in either 

enhancing the quality of PRB coal and/or converting the coal to other fuels. 

Test facilities were previously constructed by AMAX (predecessor to Foundation 

Coal West, Inc. and Alpha Coal West, Inc.) at the Belle Ayr Mine, and by 

ENCOAL at the Buckskin Mine, but no commercial production occurred and 

these facilities have either been dismantled or are no longer in use. Evergreen 

Energy (formerly operating as KFx) previously built a prototype commercialscale coal upgrading plant near the old Fort Union Mine (now part of the Dry 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-19 

Fork Mine). The facility did achieve commercial production levels of K-Fuel® 

(the company’s enhanced coal product) for a short period (2006 through early 

2008); it was used for testing and demonstration purposes. Approximately 60 

people were employed at the plant. Evergreen Energy decided to idle the plant 

in May 2008, laying off all but a caretaker staff. 

The following coal conversion projects have been proposed, and are described 

in some detail in the PRB Coal Review. These projects were not included in the 

PRB Coal Review analysis because the likelihood of their occurrence was not 

known when the analysis was conducted: 

• Evergreen Energy Coal Beneficiation Project. Long-term plans for 

Evergreen Energy’s coal upgrading plant near the Dry Fork Mine have 

not been announced, although re-opening and dismantling the currently 

idle plant and redeploying some of the equipment to another location 

have surfaced as possibilities. 

• Rentech Inc. Coal Liquefaction Project. In 2004, Rentech completed a 

feasibility study for a coal liquefaction facility, based on the historic 

Fischer-Tropsch process, to produce low-sulfur diesel fuel from 

sub-bituminous coal. Thereafter, Rentech continued to consider the 

potential of developing a commercial-scale facility in the PRB, while 

simultaneously investing in a product demonstration facility near 

Denver, Colorado. 

• White Energy Company, NRG Energy, and Buckskin Mining Company. 

In March 2008, the three companies entered into a joint development 

agreement to complete a feasibility study of building and operating a 

plant having a capacity to produce at least 1 million tons of binderless 

coal briquettes annually at the Buckskin Mine. 

• GreatPoint Energy and Peabody Coal. These two companies entered into 

an agreement in January 2008, under which Peabody Coal would 

become the preferred provider of coal to GreatPoint Energy for use in a 

commercial-scale coal-to-gas conversion plant in the PRB. 

• Wyoming Infrastructure Authority. The Wyoming Infrastructure 

Authority (WIA) was created in 2004 by the Wyoming State Legislature. 

It was tasked with promoting the state’s economic development by 

assisting in the development of interstate electric transmission 

infrastructure. In 2006, WIA’s role was expanded to also promote 

advanced coal technologies related to electric generation (WIA 2008a). In 

2007, WIA selected PacifiCorp from a list of 17 candidate firms and 

entered into a public-private partnership to assess the feasibility of 

developing an integrated gasification combined cycle power plant. The 

initial study focused on a site in southwestern Wyoming, but may open 

the way for similar projects elsewhere in the state (WIA 2008a), including 

the PRB. 
4.0 Cumulative Environmental Consequences 

4-20 Final EIS, Wright Area Coal Lease Applications 

• Additionally, there currently is a developing technology that would use 

existing oil and gas wells to generate biologically-formed methane by 

enhancing the methane production from naturally occurring microbes in 

the coal. This process is proposed for commercial testing. It is a hybrid 

between conventional in-situ coal gasification and conventional CBNG 

development. A policy to authorize and regulate this activity currently is 

being developed. 

4.1.1.2.5 Carbon Sequestration

Carbon sequestration, the process of carbon capture, separation, and storage 

or reuse, is being researched as a means to stabilize and reduce concentrations 

of carbon dioxide (a greenhouse gas). Direct options for carbon sequestration 

would involve means to capture carbon dioxide (CO2) at the source (e.g., power 

plant) before it enters the atmosphere coupled with “value-added” 

sequestration (e.g., use of captured CO2 in enhanced oil recovery [EOR] 

operations). Indirect sequestration would involve means of integrating fossil 

fuel production and use with terrestrial sequestration and enhanced ocean 

storage of carbon. 

No carbon sequestration projects currently exist in the Wyoming PRB study 

area. However, there is CO2 being injected underground for the purpose of 

EOR near the study area in the Salt Creek area. 

The 59th Session of the Wyoming State Legislature passed, and Governor 

Freudenthal signed into law, legislation that could affect long-term energyrelated development in the PRB (House Bills 0089 and 0090) (Wyoming 

Legislative Services 2008). The former (now part of Wyoming Statute 34-1) 

specified the ownership of subsurface “pore” space, established the rights to 

use such space for the purpose of carbon sequestration, and maintained the 

primacy of the mineral estate and the owners of such estate to reasonable use 

of the surface for the purpose of mineral exploration and production. 

Legal provisions enacted as a result of House Bill 0090 vested regulatory 

control over carbon sequestration with WDEQ and directed the department to 

promulgate rules, regulations (including permitting processes), and standards 

for such use. The legislation also specifies that applications for a carbon 

sequestration project must describe the geology of the area, aquifers above and 

below the intended injection zone, drill holes and operating wells in the area, 

potential impacts to other fluid resources, and identify a program for detecting 

migration or excursion of the CO2. Finally, the enacted legislation (Wyoming 

Statute 35-11-103) specifically states that the act is not intended to impede or 

impair the rights of oil and gas operators to inject CO2 through an approved 

EOR project and establish, verify, register, and sell emissions reduction credits. 

Based on the coal- and oil and gas-related development in the PRB study area, 

the potential exists for future development of carbon sequestration in the area. 

However, no commercial projects specifically targeted at capturing and 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-21 

sequestering carbon have been identified at this time. Sequestration was not 

included in the PRB Coal Review analysis because the likelihood of projects 

occurring was not known when the analysis was conducted. 

A summary of past, present, and reasonably foreseeable coal mines, coalrelated facilities, coal production, coal mine employment, and coal and coalrelated disturbance in the Wyoming PRB is presented in Table 4-5. 

Table 4-5. Past, Present, and Projected Wyoming PRB Coal Mine and CoalRelated Development Scenario. 

Year 

Coal 

Production 

(mmtpy)

Number 

of Active 

Coal 

Mines1

Number 

of Active 

Power 

Plants

Number of 

Active Coal 

Conversion 

Facilities2

Direct Coal 

Mine 

Employment

Total Coal 

Disturbance 

(acres)3 

Past and Present

1990 163 18 3 1 2,862 na 

1995 247 19 4 1 3,177 na 

2000 323 12 4 2 3,335 na 

2003 364 12 4 0 4,697 68,794 

2007 428 13 5 0 5,533 83,593 

Projected Development - Lower Coal Production Scenario 

2010 411 131 7 12 5,433 98,662 

2015 467 131 7 12 5,705 117,236 

2020 495 131 7 12 5,731 137,443 

Projected Development - Upper Coal Production Scenario 

2010 479 131 7 12 5,509 102,448 

2015 543 131 7 12 5,722 124,545 

2020 576 131 8 12 5,998 149,089 

1 Mines have consolidated and may continue to do so in the future. Also, new mines may be 

permitted to better access the coal reserves projected for mining by 2020. 2 Several coal conversion facilities currently are being evaluated; however, there is only one for which 

the likelihood of future development currently can be assessed. 3 Disturbance area includes coal mine and coal-related disturbance areas. 

Source: Annual Report of the Wyoming State Mine Inspector (Wyoming Department of Employment 

1990, 1995, 2000, 2003, and 2007a) and PRB Coal Review Task 2 Update Report (BLM 

2009b) 

4.1.2 Oil and Gas Development

The following information on existing conventional and CBNG development is 

summarized from the PRB Coal Review Task 2 Report (BLM 2009b). The 

information reported is for 2003, which was the baseline year for the coal 

review. 

4.1.2.1 Conventional Oil and Gas

Conventional oil and gas development includes all non-CBNG development 

activity. Approximately 1,500 conventional oil and gas wells, including 

producing, non-producing and injection wells, were drilled between 1990 and 

2003 (IHS 2004) in the PRB Coal Review Task 2 Study Area. Of those, 60 
4.0 Cumulative Environmental Consequences 

4-22 Final EIS, Wright Area Coal Lease Applications 

percent were development wells, drilled in established producing areas. The 

remaining 40 percent were classified as wildcat wells, which are wells that are 

drilled in non-producing areas or drilled to evaluate untested prospective zones 

in producing areas. Approximately 75 percent of the wildcat wells were 

plugged and abandoned. By 2003, the successful new field wildcat wells had 

resulted in the discovery of 61 new fields that produced 719,000 barrels of oil 

and 1.45 billion cubic feet (bcf) of non-CBNG (WOGCC 2004). 

As of the end of 2003, there were approximately 3,500 producing conventional 

oil and gas wells in the Wyoming PRB study area plus 1,386 seasonally active 

wells (IHS 2004). The Wyoming Oil and Gas Conservation Commission 

(WOGCC) reported that these wells produced approximately 13 million barrels 

of oil (mmbo) and 41 bcf of conventional gas in 2003 (WOGCC 2004). The U.S. 

Geological Survey (USGS) estimated that the mean undiscovered non-coal bed 

hydrocarbon resource in the PRB (including Montana) is 1.8 billion barrels of 

oil equivalent (boe) (USGS 2002a). 

By the end of 2007, there were approximately 3,857 producing conventional oil 

and gas wells in the Wyoming PRB study area plus an estimated 1,500 

seasonally active wells (IHS 2008). WOGCC reported that these wells produced 

approximately 11.4 mmbo and 22 bcf of conventional gas in 2007 (WOGCC 

2008c). 

Most of Wyoming’s current oil production is from old oil fields with declining 

production and the level of exploration drilling to discover new fields has been 

low (WSGS 2002). This situation is reflected in the PRB where, over the 10-

year period from 1992 through 2002, oil production from conventional oil and 

gas wells in Campbell and Converse counties decreased approximately 60.4 

percent (from 32.8 million barrels in 1992 to 13.0 million barrels in 2002). Oil 

prices have been increasing, which is reversing projections of a continuing 

decline in oil and gas production; production is now expected to increase in the 

PRB, with a peak around 2010 of approximately 15.7 million barrels (WSORMG 2005). Oil production in the short term may also be bolstered by some 

planned CO2 flood projects in the PRB (WSGS 2003). This projected temporary 

upward trend in conventional oil and gas development is reflected in the PRB 

Coal Review projections (Table 4-6). 

The active wells identified in Table 4-6 include wells that produce year-round, 

seasonally producing wells, and service wells (mainly injection wells). It is 

estimated that there are approximately 2,000 idle conventional oil and gas 

wells in the PRB study area (WOGCC 2008a); however, the number of idle wells 

gradually would be reduced in the future through plugging programs, and the 

idle well locations (once the wells are abandoned) would be reclaimed and no 

longer represent a disturbance. 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-23 

Table 4-6. Actual and Projected Wyoming PRB Conventional Oil and Gas 

Development Scenario. 

Actual Projected 

Production and Wells 2003 2007 2010 2015 2020 

Annual Gas 

Production (bcf) 39.9 22.0 42.7 39.0 35.1 

Annual Oil 

Production (mmbo) 12.9 11.4 15.7 14.3 12.9 

Active Wells 5,0671 3,8572 5,603 5,115 4,625 

Inactive Wells 1,994 03 954 563 332 

1 Total includes approximately 1,500 seasonally active wells. 2 Total includes approximately 1,500 seasonally active wells and an unknown number of inactive 

wells. 3 Unknown. 

Source: PRB Coal Review Task 2 Update Report (BLM 2009b) 

4.1.2.2 CBNG Development

Natural gas production has been increasing in Wyoming. In the PRB, this is 

due to the development of shallow CBNG resources. Commercial development 

of these resources began in limited areas west of and adjacent to the 

northernmost surface coal mines in the late 1980s. Since that time, CBNG 

development has spread south and west into other parts of the PRB Coal 

Review Task 1 and Task 2 study area (Figure 4-1). 

On private and state oil and gas leases, the WOGCC and the Wyoming State 

Engineers Office (SEO) authorize CBNG drilling. On federal oil and gas leases, 

BLM must analyze the individual and cumulative environmental impacts of all 

drilling (federal, state, and private), as required by NEPA, before CBNG drilling 

can be authorized. BLM does not authorize drilling on state or private leases 

but must consider the impacts from those wells in their NEPA analyses. In 

many areas of the PRB, the coal estate is federally owned, but the oil and gas 

estate is privately owned. A June 7, 1999 Supreme Court decision (98-830) 

assigned the rights to develop CBNG on a piece of land to the owner of the oil 

and gas estate. 

Annual CBNG production increased rapidly in the PRB between 1999 and 2003 

but has leveled off somewhat since then. At the end of 2003, there were 

14,758 producing CBNG wells in the study area (IHS 2004), and total 

production for that year was 346 bcf, or 88 percent of the total gas production 

from the basin (WOGCC 2004). Total CBNG production in the PRB was 377 

bcf for 2006, 432 bcf for 2007, and 536 bcf for 2008 (WOGCC 2009). Average 

daily CBNG production was about 947 million cubic feet per day (mmcfpd) in 

2003 (Holcomb 2003), 1,033 mmcfpd in 2006, 1,177 mmcfpd in 2007, and 

1,469 mmcfpd in 2008. From 1987 to 2003, the total cumulative gas 

production from PRB coals was over 1.2 trillion cubic feet. The total water 
4.0 Cumulative Environmental Consequences 

4-24 Final EIS, Wright Area Coal Lease Applications 

production for the same time period was approximately 2.3 billion barrels 

(96,600 million gallons). According to the WOGCC database (WOGCC 2009), 

water production in the PRB associated with CBNG production has ranged 

between 567 million barrels (23,814 million gallons), or about 1.6 million 

barrels per day in 2003 to 679 million barrels, or about 1.9 million barrels per 

day in 2008. 

Since the early 1990s, the Wyoming BLM has completed numerous 

Environmental Assessments (EAs) and two EISs analyzing CBNG projects. The 

most recent of these is the Final EIS and Proposed Plan Amendment for the 

PRB Oil and Gas Project, which was completed in January 2003 (BLM 2003). 

The level of CBNG development since 2003 appears to be lower than was 

forecast in that document. New CBNG well numbers fell from a high of slightly 

more than 4,600 in 2001 to approximately 2,000 in 2004. The PRB Coal 

Review Task 2 Report discusses the uncertain trends for future CBNG activity 

in recent years. The methodology used to project future activity is detailed in 

Appendix E of that report. Table 4-7 shows the 2003 baseline, actual values 

for 2007, and projected 2010, 2015, and 2020 levels of CBNG development 

levels used to evaluate projected cumulative environmental impacts in the PRB 

Coal Review. 

Table 4-7. Actual and Projected Wyoming PRB CBNG Development Scenario. 

Actual Projected 

Production and Wells 2003 2007 2010 2015 2020 

Annual 

Production (bcf) 338 432 708 1,005 1,026 

Active Wells 14,758 20,408 31,943 42,980 42,108 

Source: PRB Coal Review Task 2 Update Report (BLM 2009b) 

The amount of CBNG activity appears to be at a lower rate than was forecast by 

earlier projections in the Final EIS and Proposed Plan Amendment for the PRB 

Oil and Gas Project (BLM 2003), as well as in the 2005 version of the Task 2 

report (BLM 2005a). New CBNG well numbers fell from a high of slightly more 

than 4,600 in 2001 to approximately 2,000 in 2004. It is anticipated that the 

number of new wells would increase so that between 2010 and 2020 the 

number of new wells drilled per year, basin-wide, would range between 2,892 

to 3,943. As shown in Table 4-7, there would be 31,943 CBNG wells basinwide by 2010, considerably lower than the over 40,000 wells predicted for the 

same time period in the Final EIS and Proposed Plan Amendment for the PRB 

Oil and Gas Project (BLM 2003). It is anticipated that production in the 

cumulative effects study area would increase from the 432 bcf per year 

observed in 2007 to approximately 1,026 bcf per year in 2020. These estimates 

are relatively aggressive related to actual activity from 2003 to 2007 (BLM 

2009b), and it is likely that the Buffalo RMP revision, currently underway, will 

further refine these estimates. 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-25 

4.1.2.3 Oil and Gas Related Development

Oil and gas related development activities considered in the PRB Coal Review 

include major transportation pipelines and refineries. Table 4-8 summarizes 

the net disturbance, reclamation, and water production associated with oil and 

gas activity (conventional oil and gas, CBNG, and major transportation 

pipelines) for 2003 (baseline year) and projects disturbance, reclamation, and 

water production for future years. 

Table 4-8. Wyoming PRB Conventional Oil and Gas, CBNG, and Related 

Development Disturbance and Water Production.

Actual Projected 

Category 2003 2007 2010 2015 2020 

Cumulative 

Disturbed Area 

(acres)1 

177,140 178,023 248,086 344,713 427,557 

Cumulative 

Permanently 

Reclaimed Area 

(acres) 

114,777 111,926 157,803 226,775 310,959 

Cumulative 

Unreclaimed 

Area (acres) 

62,363 66,097 90,283 117,959 116,598 

Annual Water 

Production 

(mmgpy) 

26,405 31,738 50,865 71,166 72,047 

1 Inclusive of conventional oil and gas and CBNG activities and major transportation pipelines. 

Disturbance associated with ancillary facilities (including gathering lines and distribution power 

lines) has been factored in a per well basis. 

Source: PRB Coal Review Task 2 Update Report (BLM 2009b) 

4.1.2.3.1 Pipelines

Major transportation pipelines for the transport of product to outside markets 

are a key factor in the development of CBNG and conventional oil and gas 

resources in the Wyoming PRB study area. Major transportation pipelines also 

provide for transport of CO2 to crude oil well fields, which depend somewhat on 

the availability of CO2 for EOR. Currently, there are over 13 major 

transportation pipeline systems in the PRB that transport gas resources to 

markets outside of the basin (Flores et al. 2001, Wyoming Pipeline Authority 

2008). The current capacity of these pipeline systems is approximately 2.1 bcf 

per day. Currently, the combined natural gas production (CBNG and 

conventional gas) in the Wyoming PRB study area is approximately 1.22 bcf per 

day. 

Gathering lines and power lines associated with conventional oil and gas and 

CBNG development also occur within the study area; disturbance from these 

ancillary facilities were factored into the PRB Coal Review analysis on a per well 

basis. 
4.0 Cumulative Environmental Consequences 

4-26 Final EIS, Wright Area Coal Lease Applications 

Currently, there are two proposed natural gas transportation pipeline projects 

that would cross the PRB study area: 

• Bison Pipeline LLC (Bison), wholly owned by a subsidiary of 

TransCanada Corporation, is proposing to construct the Bison Pipeline 

Project, an interstate natural gas pipeline designed to transport gas from 

the PRB to the Midwest market. The Bison project will consist of 

approximately 302 miles of 30-inch diameter natural gas pipeline and 

related facilities that will extend from near Gillette through southeastern 

Montana and southwestern North Dakota where it will interconnect with 

the Northern Border Pipeline system in North Dakota. Approximately 53 

miles of the proposed route is within the Wyoming PRB Coal Review 

study area. If constructed, the Bison project would have a 470 mmcfpd 

capacity with potential to expand to approximately 1,000 mmcfpd. Bison 

filed an application with the Federal Energy Regulatory Commission 

(FERC) for a certificate of public convenience and necessity to construct, 

own and operate the pipeline in April 2009 with an in-service estimate of 

2010 (Bison Pipeline 2009). 

• The proposed Pathfinder Pipeline Project, a 42-inch diameter, 500-mile 

long natural gas pipeline, would cross the Wyoming PRB study area; 

however, its main supply of gas would come from the Green River Basin, 

where it would originate. It is possible that an interconnect at Dead 

Horse Creek might provide an outlet for PRB-produced gas into 

Pathfinder. If constructed, the Pathfinder project would have a 1.2 to 2.0 

bcf per day capacity. Submittal of an application with FERC is pending, 

with an in-service estimate of 2010. 

Beyond the Wyoming PRB study area, these projects essentially would parallel 

one another to the interconnect with Northern Border’s main pipeline in North 

Dakota. Since these projects would be interstate gas transportation pipelines, 

they would be regulated by the FERC. Although FERC lists these projects as 

“on the horizon” (FERC 2008), no formal applications have been filed with the 

regulatory agencies (FERC 2008, WDEQ/ISD 2008). Both of these projects are 

dependent upon acquisition of sufficient support in the open season process. 

Based on the lack of formal applications, their likelihood currently is 

considered low (BLM 2009b). 

There currently are proposed and construction-in-progress natural gas 

transportation pipeline projects that would not cross the Wyoming PRB study 

area; however, they would influence the ability of PRB gas producers to access 

outside markets. These projects are the Alliance Pipeline (a 42-inch-diameter 

natural gas pipeline proposed from Wamsutter, Wyoming, to Emerson, 

Manitoba) and the Rockies Express (from Rio Blanco County, Colorado, to 

Monroe County, Ohio) (Rockies Express Pipeline LLC 2008, Wyoming Pipeline 

Authority 2008). The Alliance Pipeline is expected to commence construction 

in 2012, with a proposed in-service date sometime in 2013. Rockies Express 

Pipeline (western segment from western Colorado to Missouri) was in-service in 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-27 

January 2008. The expected in-service date for the eastern segment (Missouri 

to Ohio) is October 2011. Although important to PRB gas producers, because 

these projects would not cross the Wyoming PRB study area, they are not 

considered further in this analysis. 

The amount of available pipeline capacity could limit the amount of future 

CBNG development. In the original Task 2 Report (BLM 2003a), it was 

estimated that growth of Wyoming PRB CBNG production could rise from the 

2003 level of 947 mmcf per day up to 3 to 4 bcf per day around 2007 and 

remain at or above those levels until 2015 (Holcomb 2003). However, 

production rates of 3 to 4 bcf per day were not realized by 2007, and the 

average daily production for all gas (conventional and CBNG) was 

approximately 1.22 bcf per day (WOGCC 2008). Average CBNG production in 

2007 was approximately 1.24 bcf per day. The addition of the Bison Pipeline 

Project would increase the take-away capacity of the PRB by approximately 0.5 

bcf per day, resulting in total take-away capacity for the PRB of approximately 

2.55 bcf per day. The addition of the Pathfinder Pipeline Project would increase 

the take-away capacity by approximately an additional 1.6 bcf per day, for a 

total of approximately 4.15 bcf per day. Based on the assumptions in the Task 

2 report, the projected total gas production (conventional and CBNG) would 

increase to 2.06 bcf per day in 2010, 2.86 bcf per day in 2015, and 2.91 bcf per 

day in 2020. Therefore, likelihood for additional new pipeline construction for 

2010 is low, with a higher likelihood in subsequent years (BLM 2009b). 

In the original Task 2 report (BLM 2005a), it was indicated that Anadarko 

Petroleum Corporation was planning to extend its CO2 pipeline that runs 

between Bairoil, Wyoming, and Salt Creek, Wyoming, to the Sussex Field 

located in the southern Johnson County portion of the Wyoming PRB study 

area. However, more recent information indicates that this has not occurred 

(Anadarko Petroleum Corporation 2008). According to the Wyoming Enhanced 

Oil Recovery Institute, fields in the Wyoming PRB study area that would be 

good candidates for EOR using CO2 include Hartzog Draw, Hilight, and House 

Creek (Boyles and vant Veld 2006). Since no CO2 projects have been proposed 

for construction in the Wyoming PRB study area, they are not considered 

further in this analysis. 

4.1.2.3.2 Refineries

Construction of a new refinery was completed in the Wyoming PRB study area 

in 2008. The NorthCut Refinery, owned and operated by Interline Resources, is 

located in Converse County, approximately 20 miles north of the town of 

Douglas. Construction of the refinery, which was a conversion of the 

previously existing Well Draw Gas Plant, included installation of a crude oil 

pipeline between the company’s existing crude gathering system and the 

refinery. 

The NorthCut Refinery is a crude oil topping plant, specifically engineered to 

process 4,000 barrels per day of sweet crude produced in the PRB. Output 
4.0 Cumulative Environmental Consequences 

4-28 Final EIS, Wright Area Coal Lease Applications 

from the refinery will include naptha, off-road diesel, and reduced crude oil. 

The markets for the products include ethanol manufacturers, mines, and other 

refineries. The company-owned crude oil pipeline and third-party tanker 

trucks will be used for delivery of crude stocks. Tanker trucks also will be 

used to transport finished products from the facility (Interline Resources 2008). 

The refinery is adjacent to and east of State Highway 59, with the joint 

BNSF&UP rail line located just to the west of the highway. The site previously 

had been the location of the Well Draw Gas Plant (approximately 20 acres), 

which shut down in 2002 following a fire. Interline has acquired an additional 

12 acres bordering the original site for administrative, maintenance, and 

transportation-related uses (Interline Resources 2008). 

The level and composition of outputs from the existing NorthCut Refinery 

would respond to various markets, potentially resulting in the construction of 

additional infrastructure and/or facilities in the future. Any future changes 

and associated disturbances would occur within the property currently owned 

by Interline Resources at the NorthCut site (Williams 2008). No specific plans 

for expansion currently have been identified. As a result, the likelihood for 

project expansion currently is considered speculative. Therefore, it has been 

eliminated from further analysis in this study. 

No other reasonably foreseeable plans for construction and operation of new 

petroleum refineries in the Wyoming portion of the PRB have been identified. 

4.1.3 Other Development Activity

4.1.3.1 Other Mining

Uranium, sand, gravel, bentonite, and clinker (or scoria) have been and are 

being mined in the Wyoming PRB study area. 

Wyoming has been the nation’s leading producer of uranium ore since 1995, 

and also hosts the nation’s largest uranium reserves (WSGS 2009). There are 

three primary uranium mining districts in the PRB: Pumpkin Buttes, Southern 

Powder River, and Kaycee (BLM 2003). Numerous uranium mining sites, both 

potential and existing, are present in these districts. Wyoming’s only currently 

producing uranium mine, the Smith Ranch-Highland operation, is located in 

Converse County in the Southern Powder River District. The Smith RanchHighland operation is owned by Power Resources, Inc. (dba Cameco) and uses 

the in-situ recovery (or in-situ leach) method of mining. Aside from the Smith 

Ranch-Highland operation, the only other uranium mining operation in the 

PRB that is currently licensed by the U.S. Nuclear Regulatory Commission 

(USNRC) is the Christensen Ranch/Irigaray operation (owned by COGEMA 

Mining, Inc.) located in Johnson and Campbell counties (USNRC 2009). In-situ 

operations are expected to restart at the Christensen Ranch mine in the near 

future. 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-29 

In the PRB Coal Review Task 2 report (BLM 2005a), reasonably foreseeable 

uranium development was eliminated from further consideration because: 1) 

there were no specific projects with pending applications and 2) no 

development was anticipated, based on market conditions. Based on 

commodity forecasts and uranium activity as of June 2004, the likelihood and 

potential timing of new uranium mining operations in the PRB was not known, 

and additional development was not projected in the PRB Coal Review analysis. 

Due to increased overall demand for energy in recent years, uranium prices 

have increased from a low of $7 a pound in 2001 to over $138 a pound in 2007 

(Barry 2008). The price fell to $62 in 2008 and is currently in a range of $40-

$50 per pound, which is expected to hold through 2010 because of stable 

demand and a growing supply. The recent upsurge in yellowcake spot prices 

has increased exploration and claim-staking activity in the PRB and is 

generating considerable interest in new development (WSGS 2009). 

In response to the increased price of uranium, a number of uranium mine 

developments currently are proposed in the Wyoming PRB study area. The 

USNRC is currently reviewing applications for two new uranium recover 

facilities in the PRB: the Moore Ranch and the Nichols Ranch-Hank Unit 

(USNRC 2009). The Moore Ranch, owned by Energy Minerals Corporation (dba 

Uranium One), is located in Converse County, and the Nichols Ranch-Hank 

Unit, owned by Uranerz Energy Corporation, is located in Campbell and 

Johnson counties. Both of these projects submitted license applications in 

2007, they are located in the Pumpkin Buttes District, and would use the insitu recovery method of mining. 

Over the next three years, the USNRC expects to receive additional applications 

for new uranium recovery facilities, as well as requests for restarts and 

expansions of existing facilities. Table 4-9 provides information on the three 

new projects and four expansion projects currently proposed in the PRB, all of 

which would use in-situ recovery. With the exception of the Ross Project, 

which is located in western Crook County, the proposed developments are all 

in the Pumpkin Buttes District in southwestern Campbell and northwestern 

Converse counties. The actual number of the proposed developments that 

would become operational would depend on several factors including uranium 

prices and approval of permits. 

Bentonite is weathered volcanic ash that is used in a variety of products, 

including drilling mud and kitty litter, because of its absorbent properties. 

There are three major bentonite producing districts in and around the PRB: the 

Colony District in the Northern Black Hills, the Clay Spur District in the 

Southern Black Hills, and the Kaycee District west of Kaycee, Wyoming. 

Within the PRB Coal Review study area, bentonite is mined at Kaycee (WMA 

2006). The PRB Coal Review assumed that bentonite mining would continue 

throughout the study period and that production would continue at existing 

active mines, with no new mines developed through 2020. 
4.0 Cumulative Environmental Consequences 

4-30 Final EIS, Wright Area Coal Lease Applications 

Table 4-9. In-Situ Recovery Uranium Projects Currently Proposed in the 

Wyoming PRB Study Area.

Project/ 

Company County 

Application 

Type 

Watershed/ 

Mining District 

Likelihood/ 

Rationale 

Ludeman Satellite 

Project/ 

Energy Metals Corp 

(dba Uranium One) 

Converse Expansion/ 

Amendment 

to Moore 

Ranch 

Antelope Creek/ 

Pumpkin Buttes 

District 

Moderate for 2012/ 

Letter of intent to 

USNRC February 

2009, application 

expected 2009. 

Allemand-Ross 

Satellite Project/ 

Energy Metals Corp 

(dba Uranium One) 

Converse Expansion/ 

Amendment 

to Moore 

Ranch 

Antelope Creek/ 

Pumpkin Buttes 

District 

Moderate for 2012/ 

Letter of intent to 

USNRC February 

2009, application 

expected 2009. 

Ross Project/ 

Peninsula Minerals, 

Ltd. 

Crook New Little Missouri River/ 

Not in one of the three 

districts 

Moderate for 2012/ 

Letter of intent to 

USNRC October 2009, 

application expected 

2010. 

Collins Draw 

Project/ 

Uranerz Energy 

Corporation 

Campbell New Powder River/ 

Pumpkin Buttes 

District 

Moderate for 2012/ 

Letter of intent to 

USNRC March 2008, 

application expected 

2009. 

North Butte-Ruth 

Project/ 

Power Resources, 

Inc. (dba Cameco) 

Campbell and 

Johnson 

Expansion/ 

Satellite to 

Smith Ranch

Powder River/ 

Pumpkin Buttes 

District 

High probability for 

2012/ 

Application for 

commercial operation 

filed March 2006. 

Reno Creek Project/ 

Bayswater Uranium 

Corporation 

Campbell New Belle Fourche River 

and Antelope Creek/ 

Pumpkin Buttes 

District 

Moderate for 2015/ 

Letter of intent to 

USNRC March 2009, 

application expected 

2010. 

Ruby Ranch 

Project/ 

Power Resources, 

Inc. (dba Cameco) 

Campbell Expansion/ 

Satellite to 

Smith Ranch

Powder River and Belle 

Fourche River/ 

Pumpkin Buttes 

District 

Moderate for 2015/ 

Letter of intent to 

USNRC March 2008, 

application expected 

2009. 

Sources: USNRC (2009), World Information Service on Energy (2009) 

Aggregate, which is sand, gravel, and stone, is used for construction purposes. 

In the PRB, the more important aggregate mining localities are in Johnson and 

Sheridan counties (WSGS 2004). The largest identified aggregate operation is 

located in northern Converse County. It has an associated total disturbance 

area of approximately 67 acres, of which 4 acres have been reclaimed. 

Clinker (which is formed when coal beds burn and the adjacent rocks become 

baked) is used as aggregate where alluvial terrace gravel or in-place 

granite/igneous rock is not available. Clinker generally is mined in the 

Converse and Campbell counties portion of the Wyoming PRB study area. 

Increased sand, gravel, and clinker production and associated surface 

disturbance are anticipated in the Wyoming PRB study area in the future 

because aggregate would be required for road maintenance and new 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-31 

construction activities as other primary resources, such as coal and oil and 

gas, continue to be developed. New operations and increased production from 

existing operations can be expected. These operations would vary in size based 

on the immediate need from the primary industries, but there is no specific 

information about these projected operations. As a result, new sand, gravel, or 

clinker operations were not analyzed in detail in the PRB Coal Review. 

4.1.3.2 Industrial Manufacturing

There are a number of existing industrial manufacturing establishments 

located in the Wyoming PRB Coal Review study area. Most are relatively small 

with fewer than 25 employees; they predominately serve regional and local 

markets, and most are directly or indirectly related to energy resource 

development and production. Over the years, some of these firms have 

expanded such that they now support activities and serve markets outside of 

the region, but those operations remain dependent upon the local and regional 

markets to sustain their existing operations. 

The PRB Coal Review anticipates that increased coal production would result 

in an increased demand for fuels and explosives. This increased demand could 

result in the need for the development of new off-site chemical feedstock plants 

in the study area. Project-specific information is not available, however, and 

the potential development of new chemical feedstock plants was not considered 

in the PRB Coal Review. 

Local economic development organizations, including CCEDC and CANDO, are 

continually engaged in efforts to recruit or assist new business formation in the 

PRB study area. For example, CANDO has pursued development of long-term 

potential projects; however, the outcomes of those projects are uncertain and 

little information and detail are available. As a result, they were not considered 

in the PRB Coal Review. 

4.1.3.3 Wind Power

Due to increasing concerns over global climate change, there is strong interest 

from consumers, investor-owned utilities, and environmental and economic 

sustainability interests in wind energy generating projects and other forms of 

renewable energy projects. The current development interest in wind energy 

generation is driven in part by mandates for many utilities to increase the use 

of renewables in their overall energy portfolio, decisions by environmentally 

conscious firms to use renewable energy sources, and also due to the 

development of wind energy manufacturing infrastructure in the region. 

Wind power facilities have been proposed, are being constructed, and are 

providing energy at various sites in Wyoming, including the PRB region. There 

is good potential for wind power, and these facilities can contribute to meeting 

forecasted electric power demands; however, they are dependent on available 

transmission capacity to send power to users. Compared to the lower 48 
4.0 Cumulative Environmental Consequences 

4-32 Final EIS, Wright Area Coal Lease Applications 

states, Wyoming currently ranks in eleventh place in terms of existing wind 

power capacity from projects currently in operation with 986 MW and 299 MW 

under construction. Texas ranks in first place with 8,797 MW in operation and 

660 MW under construction. In terms of annual wind energy potential, 

Wyoming ranks seventh with 747 billion kilowatt-hours per year. North 

Dakota ranks first with 1,210 billion kilowatt-hours per year (AWEA 2010). 

Although many Wyoming locations having the highest potential are in the 

southern portion of the state, areas in both Converse and Campbell counties 

offer sufficient potential to support commercial-scale wind generation projects. 

• One such project, the Glenrock Wind Farm, is currently providing power 

in the Wyoming PRB study area. PacifiCorp completed construction of 

this three-phase project in Converse County in 2009. The Glenrock 

Wind Farm is located approximately 15 miles north of the existing Dave 

Johnston Power Plant, on and near the site of the former Dave Johnston 

Coal Mine. This is the first wind energy project in the nation to be 

located at a reclaimed coal mine. The first phase, known as the Glenrock 

Wind Energy Project, went online in 2008. The second and third phases, 

the Rolling Hills Wind Energy Project and the Glenrock III Wind Energy 

Project, respectively, went online in 2009. The Glenrock and Rolling Hills 

phases each consist of 66 wind turbine generators (each rated at 1.5-MW 

[99-MW total]). The Glenrock III phase consists of 26, 1.5-MW wind 

turbines (39-MW total) (PacifiCorp 2009). 

• Duke Energy (dba Three Buttes Windpower, LLC) completed the 

Campbell Hill Windpower Project and began commercial operations in 

December 2009. The Campbell Hill Windpower Project is located 

approximately 15 miles northeast of Casper in Converse County and 

consists of 66 wind turbines generating 99-MW. PacifiCorp will buy all of 

the output generated by the project. 

• Duke Energy plans to build the Top of the World Wind Energy Project, a 

200-MW wind farm located northeast of Glenrock in Converse County. 

Construction is expected to begin in early 2010 upon receipt of all 

necessary permits from the state. PacifiCorp will buy the power 

generated by the project (Duke Energy 2009). 

• Third Planet Windpower is in the initial development phase of a wind 

energy project (Reno Junction Windfarm) in the Pumpkin Buttes area of 

southwestern Campbell County. Third Planet Windpower has acquired 

approximately 13,000 acres of land leases for the project, installed 

meteorological monitoring sites, and is currently doing environmental 

and feasibility studies. The company plans to install up to 133, 1.5-MW 

towers, yielding a total capacity of 200-MW, if fully constructed. The site 

for the Reno Junction Wind Farm is close to the Black Hills Power 

Pumpkin Buttes substation and the companies are seeking an agreement 

for interconnection. Third Planet Windpower plans to start construction 

in mid-2010 with an online date expected for the end of 2010 (Gillette 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-33 

News-Record 2008c). This project is considered moderately likely to 

occur (BLM 2009b). 

Land use disturbance for wind energy projects is associated with development 

of access roads, a turbine assembly pad, and foundation pad for each wind 

turbine tower. Additional land disturbance results from installation of 

transformers and substations, underground electric and fiber optic 

communications cables, one or more operations and maintenance facilities, 

meteorological towers, and a transmission line connecting the project to the 

regional grid. Much of the disturbance area is reclaimed immediately following 

construction, with long-term disturbance associated with permanent facilities 

(i.e., access roads, support facilities, and tower foundations). 

Wind generating projects have an expected life of approximately 25 years, 

which could be extended based on market conditions and the overall condition 

of the infrastructure. Some redisturbance would occur at the time of 

decommissioning, followed by final reclamation. 

According to the American Wind Energy Association (2010), transmission will 

be a key issue for the wind industry’s future development over the next two 

decades. 

4.1.3.4 Solar Power

Although Wyoming has been given a rating of very good for Annual Solar 

Potential for Flat Plate Collectors, there currently are no utility-scale solar 

power collection facilities on federal, state, or private lands in Wyoming. 

Furthermore, no applications for the development of utility-scale solar energy 

projects have been filed as of January 1, 2010. 

The BLM, the Office of Energy Efficiency and Renewable Energy (EERE), and 

the USDOE are jointly preparing a solar energy Programmatic Environmental 

Impact Statement (PEIS) which could facilitate future solar energy development 

application processes. Wyoming is not covered in the PEIS but still may be 

affected by it. Information on the PEIS can be found at: 

http://solareis.anl.gov. The BLM currently evaluates solar energy project 

proposals on a case by case basis. 

Solar energy utilization in Wyoming is, as of January 1, 2010, limited to private 

residences and private commercial establishments. Current Wyoming solar 

energy incentives include a sales tax rebate on industrial or commercial solar 

energy generation equipment, a one-time grant of up to $3,000 offered through 

lottery from the Wyoming Business Council, and the utility buy back of unused 

electricity at the wholesale price. Solar energy production equipment and 

installation at residential, commercial, and utility sites is expensive. Currently, 

the electric utility costs in Wyoming are such that the cost of installation does 

not favor solar energy development over existing forms of energy development. 
4.0 Cumulative Environmental Consequences 

4-34 Final EIS, Wright Area Coal Lease Applications 

4.1.3.5 Reservoirs

Currently, there are five key water storage reservoirs in the Wyoming PRB Coal 

Review study area (Healy, Lake DeSmet, Muddy Guard No. 2, Gillette, and 

Betty No. 1) (HKM Engineering et al. 2002a and 2002b). The total disturbance 

associated with these five key water storage areas is 3,263 acres. 

Based on the applicable water plans prepared for the Wyoming Water 

Development Commission for its Basin Planning Program (HKM Engineering et 

al. 2002a and 2002b), there are long range projections for development of 

additional reservoirs in the Wyoming PRB study area. However, none of these 

reservoirs have reached the planning stage; therefore, there was not enough 

information to analyze them in the PRB Coal Review. 

4.1.3.6 Other Non-Energy Development

In addition to the specific projects and developments described above, a 

network of public and private physical infrastructure, private enterprises, and 

public activities has been developed in the PRB over time. Examples of 

infrastructure include the highway and road networks, airports, government 

offices, hospitals, public schools, municipal water systems, and extensive 

residential and commercial real estate development. Private enterprises 

include local retail and service establishments, newspaper publishing, and 

transportation and distribution firms. 

There are a number of existing industrial manufacturing and service 

establishments located in the Wyoming PRB study area. Most are relatively 

small with fewer than 50 employees, and most serve local and regional 

markets, the majority of which are directly or indirectly related to energy 

resource development and production. Hettinger Welding and L&H Welding 

and Machine, both based in Gillette, are the largest industrial manufacturing 

firms in the region specializing in repairs, rebuilding, and manufacturing for 

the mining industry. Though classified as wholesalers and repair 

establishments, rather than as manufactures, firms such as Wyoming 

Machinery and P&H Mining Equipment also serve the mining and oil and gas 

industries. Other industrial manufacturing and service establishments in the 

region provide metal fabrication, metal plating, custom and precast concrete 

products, and specialized chemical products and services. Over the years, 

some of these firms have expanded such that they now support activities and 

serve markets outside the PRB region. However, they remain dependent upon 

the local and regional markets to sustain their existing operations (BLM 

2009b). 

Local economic development organizations, including Campbell County 

Economic Development Corporation (CCEDC) and Converse Area New 

Development Organization (CANDO) are continually engaged in efforts to 

recruit or assist new business formation in the PRB study area. For example, 

CANDO is pursuing development of an ammonium nitrate plant (using 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-35 

methane as a feedstock) in the Bill, Wyoming, area, as well as location of an 

aluminum mill in the same general location. These and similar prospects are 

long-term potential whose outcomes are uncertain and for which little 

information and detail are available. As a result, they were eliminated from 

analysis in the PRB Coal Review (BLM 2009b). 

Local governments, school districts, and other special service districts and 

public entities continually engage in long-term planning. Examples of some of 

the recently completed projects and developments, as well as anticipated plans 

or proposals for development in public, private, and commercial infrastructure 

within the city of Gillette and Campbell County, are included in the current city 

of Gillette development summary (City of Gillette 2009) and summarized below: 

• The city of Gillette’s Wastewater Treatment Plant was upgraded in 2007. 

• An expansion and renovation of the county courthouse were completed 

in 2006, and a new public health building was completed in 2007. 

• The Wyoming Center, a conference and multi-event facility expansion of 

the Gillette CAM-PLEX, was completed in 2008. The expansion includes 

more exhibit space, conference and indoor athletic facilities with seating 

for up to 9,000, an indoor ice rink, and various concession and support 

spaces. 

• A new $10 million headquarters for the Campbell County Fire 

Department providing administrative, training, storage space, and 

additional parking bays for firefighting equipment and vehicles was 

completed in 2008. 

• A new Hospice Center, the Cummins Diesel Service Center, and the 

Hillcrest School were completed in 2008. 

• Construction of the new Health Sciences Center at Gillette College was 

competed in 2008. The facility houses the school’s nursing program, 

providing classrooms, labs, faculty offices, and other spaces. The 

nursing program functions in conjunction with the Campbell County 

Memorial Hospital 

• Major infrastructure projects within and adjacent to the city limits in 

2008 and 2009 included highway and roadway improvements, drainage 

system improvements, library renovations, subdivision developments, 

and expansion of the county landfill. 

• Expansion of the Campbell County Detention Center and remodeling of 

the Sheriff’s Office were completed in 2009. 

• Construction of various commercial and residential housing 

developments is ongoing. 
4.0 Cumulative Environmental Consequences 

4-36 Final EIS, Wright Area Coal Lease Applications 

• The new $55 million Campbell County Recreation Center is currently 

under construction and scheduled for completion in 2010. 

• The county, city, and Gillette College are partnering on a Campus 

Housing Complex and the Industrial Technical Education Center. 

Construction of these facilities is ongoing and part of a long-range master 

plan for the college that is designed to provide a broad college-level 

curriculum and provide more focused education and training to support 

local business and industry. 

• Campbell County Memorial Hospital is undergoing a major expansion 

and renovation project that began in 2009. 

• The city of Gillette is seeking state and local funding to construct an 

additional municipal water supply. Construction of a second Madison 

Formation well field in Crook County near the Keyhole Reservoir and a 

second water supply line from the well field to Gillette is expected to 

begin in 2011 or 2012. 

• The Wyoming School Facilities Commission (WSFC) oversees all aspects 

of construction and maintenance of school facilities and physical plant. 

School districts submit 5-year plans for facilities spending, which are 

subject to approval and funding by the WSFC. Currently approved 

master plans for the seven school districts serving some portion of the 

Wyoming PRB study area include defined needs for more than $115 

million in capital construction, some of which have already been funded 

(WSFC 2008). The total includes approximately $51 million for the 

Campbell County School District, the bulk of which would fund three 

new elementary schools and one new high school (WSFC 2008). 

Additional private sector industrial and commercial development is expected to 

occur within the context of normal community and economic development. 

The strong economic base provided by the coal mines, oil and gas companies, 

and relatively high income of residents draws regional and national retailers 

(e.g., The Home Depot) to the area. Gillette’s location on I-90 and the strong 

demand for lodging by energy workers, travelers, and visitors associated with 

events at the CAM-PLEX also have spurred construction of several new motels 

(CCEDC 2008, City of Gillette 2008a). 

The 2010 Wyoming Department of Transportation (WYDOT) State 

Transportation Improvement Program (STIP) includes planned construction for 

the 2010 fiscal year and preliminary engineering estimates for projects with 

anticipated construction dates through 2015. In general, Wyoming 

transportation projects scheduled over the next 6 years include maintenance, 

reconstruction, and improvement projects. Airport improvement plans consist 

primarily of pavement rehabilitation and overlays, with some minor expansion 

of taxiways, aprons, and parking. Costs anticipated for 2010 through 2015 for 

highway and airport maintenance, reconstruction, and improvement projects in 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-37 

the PRB Coal Review study area (Sheridan, Johnson and Campbell counties) 

are approximately $190 million. No construction of new highways is scheduled 

and no new airports are proposed (WYDOT 2010). 

In addition to highway projects included in WYDOT’s 2008-2013 plan, the 

Eagle Butte Mine received approval from WYDOT to relocate a portion of U.S. 

Highway 14-16 in the vicinity of the Gillette-Campbell County Airport, north of 

the city of Gillette. The relocation will facilitate the recovery of approximately 

40 million tons of additional coal recently acquired by the mine through the 

West Eagle Butte LBA Tract coal sale. Three alternative alignments, involving 

the construction of up to 6.8 centerline miles of new roadway, were identified 

and a preferred alternative was subsequently chosen and approved by WYDOT. 

Construction of the new highway segment is anticipated in 2011/2012 

(WYDOT and Foundation Coal Company 2008). 

There are numerous current and anticipated plans for future investment in 

public and private infrastructure in the PRB. Such investments would include 

state and local investment in transportation, administrative, and educational 

facilities. Given the timing, scale, year-to-year variability, relatively short 

construction timetables associated with such investments, the existence of a 

relatively large and diversified construction industry in the region and nearby 

areas, and the limited potential for these projects to alter long-term conditions 

in the PRB, they are not included in the PRB Coal Review analysis. However, 

one or more of these and similar projects could warrant consideration in a 

cumulative analysis for a site-specific project due to proximity or coincidental 

project schedules and timetables (BLM 2009b). 

4.2 Cumulative Environmental Consequences

Section 4.1 of this chapter discusses existing and projected levels of 

development in the Wyoming PRB, and includes summaries of the results of 

PRB Coal Review Task 2 studies. Task 2 was updated based on actual levels of 

development through 2007, and current development estimates available 

through year 2009. This section summarizes the existing conditions resulting 

from baseline year (2003) development and the cumulative environmental 

consequences of the projected development for 2010, 2015, and 2020 based on 

the results of the analyses conducted for PRB Coal Review Task 1 and 3 

reports, respectively. 

As discussed in Section 4.1, the Wyoming portion of the PRB is the primary 

focus of the PRB Coal Review analyses. For the majority of resources in the 

Task 1 analysis, the Wyoming PRB Coal Review study area encompasses all of 

Campbell County, all of Sheridan and Johnson counties outside of the Bighorn 

National Forest, and the northern portion of Converse County (Figure 4-1). The 

study areas for the Task 3 analyses are different. For the majority of the 

resources considered in the PRB Coal Review, the Task 3 study area is based 

on watershed boundaries in the PRB and includes the portions of the Upper 

Powder River, Little Powder River, Upper Belle Fourche River, Upper Cheyenne 
4.0 Cumulative Environmental Consequences 

4-38 Final EIS, Wright Area Coal Lease Applications 

River, Antelope Creek, and Dry Fork Cheyenne River subwatersheds that lie 

within Sheridan, Johnson, Campbell and northern Converse counties (Figure 

4-4). This study area includes over 4 million acres and is referred to below as 

the cumulative study area. Table 4-10 summarizes the total disturbance and 

reclamation acreages for the baseline year of 2003 and actual data for 2007, as 

well as the total projected disturbance and reclamation acreages for 2010, 

2015, and 2020 within the cumulative study area described above. 

A total of approximately 210,096 acres of this land area had been disturbed by 

development activities as of 2003. Based on the information in Appendices A 

and D of the Task 2 Update Report for the PRB Coal Review − Past, Present and 

Reasonably Foreseeable Development Activities (BLM 2009b), a total of 

approximately 222,568 acres (5 percent) of land area have been disturbed by 

development activities in the cumulative effects study area as of end of 2007. 

Of the 222,568 acres of total cumulative disturbance, approximately 83,593 

acres of disturbance (37 percent) were associated with coal mine development. 

Of the 222,568 acres of total cumulative disturbance, approximately 113,382 

acres (51 percent) have been reclaimed. The remaining 132,645 acres of 

disturbance would be reclaimed incrementally or following a project’s 

completion, depending on the type of development activity and permit 

requirements. Of the 83,593 total cumulative acres of disturbance directly 

associated with coal mine development, approximately 25,884 acres (31 

percent) have been reclaimed (as of end of 2007). Of the remaining 57,709 

acres of disturbance, approximately 24,338 acres currently are not available for 

reclamation, as they are occupied by long-term facilities that are needed to 

conduct mining operations. These areas would be reclaimed near the end of 

each mine’s life. Reclamation of the remaining 33,371 acres, which represent 

areas of active mining and areas where coal has been recovered but 

reclamation has not been completed, would proceed concurrently with coal 

mining. 

The total cumulative disturbance is projected to increase to as much as 

434,374 acres in 2020 under the upper coal production scenario, which would 

represent approximately 9.7 percent of the cumulative study area. This 

projected disturbance includes coal mining, coal-related development, and oil 

and gas and related development disturbance in the study area. Of the 

434,374 acres, it is projected that 149,089 acres (34 percent) would be 

associated with coal mining activities. Areas reclaimed during each future time 

period shown in Table 4-10 reflect how much of the disturbed acreage is 

projected to be permanently reclaimed by that point in time. 

Under the upper coal production scenario for 2020, of the 434,374 acres of 

total cumulative disturbance, approximately 296,670 (68 percent) would be 

reclaimed by 2020. The remaining 137,702 acres of disturbance would be 

reclaimed incrementally or following a project’s completion, depending on the 

type of development activity and permit requirements. Of the 149,089 acres of 

disturbance associated with coal mining, it is projected that approximately 
CAMPBELL

COUNTY

SHERIDAN

COUNTY

JOHNSON

COUNTY

CONVERSE

COUNTY

SHERIDAN

BUFFALO

GILLETTE

WRIGHT

1

2

3

Buckskin, Dry Fork, Eagle Butte,

Rawhide, and Wyodak Mines 1 Subregion 1 -

2

3

Belle Ayr, Caballo, Coal Creek, and

Cordero-Rojo Mines Subregion 2 -

Jacobs Ranch, Black Thunder,

North Antelope Rochelle,

and Antelope Mines

Subregion 3 -

SCALE: 1"= 20 MILES

LEGEND

Federal Coal Lease Areas

Railroads

Former Surface Coal Mine Sites

PSO ASH

CREEK MINE

BIG HORN

MINE

DAVE

JOHNSTON

MINE

Subwatersheds in the Environmental

Consequence Study Area

Coal Mine Groundwater Model

(CMGM) Domain

COAL MINE SUBREGIONS

Dry Fork

Cheyenne River

Tongue River

Big

Creek

Goose

Little Goose

Creek

Prairie

Dog

Creek

Sage Creek

Dry Creek Dry Fork Cheyenne

River

Antelope Creek

Porcupine Creek

Little Thunder Creek

Black Thunder Creek

Belle

Fourche River

Four

Horse Creek

Caballo Creek

Cottonwood Creek

Little Powder

River

Wild

Cat

Creek

Salt

Creek

South

Fork Powder

River

BuffaloMiddle

Creek

Fork Powder River

Bear Trap Creek

Red Fork Powder

River

North

Fork

Powder

River

South

Fork Crazy Woman

Creek

Trabing

Dry

Creek

Crazy

Woman

Creek

Rock Creek

Piney Creek

Clear Creek

Powder River

Spotted Horse Creek

Middle Prong

Horse

Wild

Creek

Antelope

Creek

Timber

Creek

Little

Powder River

North ForkCrazy

Woman

Creek

Powder

River

Wild Horse Creek

Bitter

Creek

Fourmile Creek

Pumpkin Creek

Dry Fork Powder

River

Upper

Belle

Fourche

River

Upper

Powder

River

Little

Powder

River

North Fork Bear

Creek

Upper

River

Figure 4-4. Wyoming Task 3 Study Area for PRB Coal Review Studies Evaluating Projected Environmental

Consequences.

4.0 Cumulative Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 4-39
4.0 Cumulative Environmental Consequences 

4-40 Final EIS, Wright Area Coal Lease Applications 

Table 4-10. Actual and Projected Wyoming PRB Total Development Scenario, 

Task 3 Study Area. 

Year 

Total Acres 

Disturbed 

Acres 

Reclaimed 

Acres 

Unreclaimed 

Acres 

Unavailable 

for 

Reclamation1 

Acres Affected 

by Coal 

Development1

Actual 

2003 210,096 111,879 98,217 24,097 68,794 

2007 222,568 113,382 132,645 24,338 83,593 

Projected Development - Lower Coal Production Scenario 

2010 278,209 159,291 118,919 26,338 98,662 

2015 354,148 219,816 134,334 27,549 117,236 

2020 422,727 289,937 132,789 28,797 137,443 

Projected Development - Upper Coal Production Scenario 

2010 281,996 161,124 120,872 25,688 102,448 

2015 361,456 224,024 137,432 27,099 124,545 

2020 434,374 296,670 137,702 28,345 149,089 

1 Includes coal mine and coal-related disturbance. 

Source: PRB Coal Review Task 2 Update Report (BLM 2009b)

86,196 (58 percent) would be reclaimed by 2020. Of the remaining 62,893 

acres of coal mining-related disturbance, it is estimated that approximately 

28,345 acres would be unavailable for concurrent reclamation due to the 

presence of long-term facilities, which would be reclaimed near the end of each 

mine’s life. Reclamation of the remaining 34,548 acres of disturbance would 

proceed concurrently with mining operations. 

The acres of unreclaimed disturbance would be reclaimed incrementally or 

following a project’s completion, depending on the type of development activity 

and permit requirements. The acres currently not available for reclamation are 

occupied by long-term facilities that are needed to conduct mining operations 

or coal-related activities. These areas would be reclaimed near the end of each 

mine or facility’s life. 

Adjustments were made to the study area described above and shown in Figure 

4-4 for several resources as described below: 

• The potential air quality impacts were evaluated over a multi-state area 

(including most of Wyoming, southeastern Montana, southwestern North 

Dakota, western South Dakota, and northwestern Nebraska) because 

they would be expected to extend beyond the Wyoming and Montana PRB 

study area that was used to identify emissions sources for the air quality 

analysis. 

• The socioeconomic impact analysis focused on Campbell County, but 

also considered Converse, Crook, Johnson, Sheridan, and Weston 

counties as directly affected and Niobrara and Natrona counties as 

indirectly affected. 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-41 

The groundwater drawdown was evaluated in the area surrounding and 

extending west of the surface coal mines, shown in Figure 4-4, because that is 

the area where groundwater drawdown related to surface coal mining 

operations and CBNG production operations would overlap. 

4.2.1 Topography and Physiography

The PRB is located within the Upper Missouri Basin Broken Lands 

physiographic subprovince that includes northeastern Wyoming and eastern 

Montana to the Canadian border. The topography generally is of low to 

moderate relief with occasional buttes and mesas. The general topographic 

gradient slopes down gently from southwest to northeast with elevations 

ranging from 5,000 to 6,000 feet above sea level on the southern and western 

portions of the basin to less than 4,000 feet above sea level on the north and 

northeast along the Montana state line. The major drainages in the basin are 

the Tongue, Powder, Belle Fourche, and Cheyenne rivers. Most of the 

drainages in the area are intermittent and have flows during high precipitation 

events or during periods of snowmelt. The drainages are part of the upper 

Missouri River Valley drainage basin. 

The disturbance associated with the majority of the past, present, and 

projected activities have resulted in or would result in the alteration of the 

surface topography. Surface coal mining, which is projected to continue in the 

area of the existing coal mines shown in Figure 4-4, permanently alters the 

topography by removing the overburden and coal and then replacing the 

overburden. 

Recontouring during reclamation to match approximate original contours, as 

required by regulation, reduces the long-term impact to topography. After 

mined-out areas are reclaimed, the restored land surfaces are typically gentler, 

with more uniform slopes and restored basic drainage networks. Oil and gas 

exploration and development has occurred and is projected to continue 

throughout most of the Task 3 study area. It also results in the alteration of 

topography to accommodate facilities (e.g., well pads, power plants, etc.) and 

roads, but the disturbance tends to occur in smaller, more discrete areas than 

coal mining and the development is spread out over a larger area. 

The disturbance and reclamation acreages associated with all existing and 

projected development in the Task 3 study area for the years 2003, 2007, 

2010, 2015, and 2020 are given in Table 4-10. 

4.2.2 Geology, Mineral Resources, and Paleontology

The cumulative effects study area for geology, mineral resources, and 

paleontology is the PRB Coal Review Task 3 study area (Figure 4-4). 

The PRB is one of a number of structural basins in Wyoming and the Rocky 

Mountain area that were formed during the Laramide Orogeny. The basin is 
4.0 Cumulative Environmental Consequences 

4-42 Final EIS, Wright Area Coal Lease Applications 

asymmetric with a structural axis that generally trends northwest to southeast 

along the western side of the basin (Flores et al. 1999). Natural earthquakes, 

landsides, and subsidence do not present a hazard in the PRB based on the 

lack of active faults in the study area (USGS 2004); the low risk of ground 

shaking in the region if a maximum credible earthquake were to occur (Frankel 

et al. 1997); and the absence of evidence of subsidence, landslides, or other 

geologic hazards in association with CBNG production. USGS monitors the 

magnitude of blasting activity in the PRB under the Routine Mining Seismicity 

Earthquake Hazards Program (USGS 2008). Coal mine blasting operations 

induced seismic activity does occur throughout the PRB and has reached a 

USGS local magnitude rating of 3.6 (USGS 2004). 

4.2.2.1 Coal

Most of the coal resources of the basin are found in the Fort Union and 

Wasatch Formations. Although coals are present in the Wasatch, they are 

thinner and less continuous than the coals in the Fort Union and, therefore, 

they are not as economically important as the coals in the Fort Union for either 

coal mining or CBNG development. Projected levels of coal production and 

disturbance under the lower and upper coal production scenarios are shown in 

Tables 4-2 and 4-3. 

In the coal mine areas, the overburden and coal would be removed and the 

overburden replaced, resulting in a permanent change in the geology of the 

area and a permanent reduction of coal resources. 

4.2.2.2 Oil and Gas

Drilling for conventional oil and gas in the Wyoming PRB has declined 

considerably in the last 15 years. However, as discussed above, increasing 

prices have led to increased interest in drilling and there remains potential for 

finding and developing these resources in the deeper formations of the basin. 

Conversely, CBNG production increased rapidly from 1999 through 2002 but 

began to level off in 2003. Actual production rates for conventional oil and gas 

and CBNG in 2007 and projected rates for 2010, 2015, and 2020 are shown in 

Tables 4-6 and 4-7. 

Oil and gas and related development accounts for most of the projected mineral 

disturbance outside of the coal mining areas. It generally would result in only 

shallow, discrete areas of surface disturbance, as discussed above. The 

acreages over which these impacts were occurring (as of 2003 and 2007) and 

are projected to occur in the years 2010, 2015, and 2020 are included in the 

totals shown in Table 4-10. 

4.2.2.3 Other Mineral Resources

As discussed in Section 4.1.3.1, other mineral resources that are being mined 

in the Wyoming PRB include uranium, bentonite, clinker, and aggregate. 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-43 

Production of uranium and bentonite is not likely to be affected by development 

of coal or CBNG in the PRB. Aggregate and clinker production levels are more 

likely to be affected by other mineral development levels because these 

resources would be used in construction projects related to other mineral 

development. 

4.2.2.4 Paleontology

Scientifically significant paleontological resources, including vertebrate, 

invertebrate, plant, and trace fossils, are known to occur in many of the 

geologic formations within the Wyoming PRB. These fossils are documented in 

the scientific literature, in museum records, and are known by paleontologists 

and land managers familiar with the area. 

The Wasatch Formation is the most geographically widespread unit exposed on 

the surface over most of the cumulative study area. It is underlain by the Fort 

Union Formation. The fossiliferous Morrison and Lance Formations crop out in 

the western portion of the basin but occur at depth in the vicinity of the coal 

mines and CBNG activity in the eastern portion of the basin. Within the 

cumulative study area, the highly fossiliferous White River Formation occurs 

only on Pumpkin Buttes in southwestern Campbell County. 

As of 2007, no significant or unique paleontological localities had been 

recorded on federal lands in the PRB. However, the lack of localities in the PRB 

does not mean that scientifically significant fossils are not present, as much of 

the area within and surrounding the PRB has not been adequately explored for 

paleontological resources. As a result, development activities in the cumulative 

study area have the potential to adversely affect scientifically significant fossils, 

if they are present in or adjacent to disturbance areas. 

The potential for impacts to scientifically significant fossils would be greatest in 

areas where Class 4 or 5 formations are present (see Section 3.3.3.1). The 

Wasatch Formation is classified as a Class 5 formation. The Fort Union 

Formation is classified as a Class 3 formation, which means that fossil content 

varies in significance, abundance, and predictable occurrence. The greatest 

potential impact to surface and subsurface fossils would result from 

disturbance of surface sediments and shallow bedrock during construction 

and/or operations, depending on the type of project. Potential subsurface 

disturbance of paleontological resources (e.g., during drilling operations) would 

not be visible or verifiable. The areas over which these impacts occurred as of 

2003 and 2007, and are projected to occur as a result of all projected 

development in the years 2010, 2015, and 2020 are shown in Table 4-10. As 

only portions of the cumulative study area have been evaluated for the 

occurrence of paleontological resources, and discrete locations for development 

activities cannot be determined at this time, no accurate estimate can be made 

as to the number of paleontological sites that may be affected by cumulative 

development activities. 
4.0 Cumulative Environmental Consequences 

4-44 Final EIS, Wright Area Coal Lease Applications 

Development activities which involve federally owned surface and/or minerals 

are subject to federal guidelines and regulations protecting paleontological 

resources. Protection measures, permit conditions of approval, and/or 

mitigation measures would be determined on a project-specific basis at the 

time of permitting to minimize potential impacts to paleontological resources as 

a result of these activities. 

4.2.3 Air Quality

There is substantial scientific evidence that increased atmospheric 

concentrations of greenhouse gases (GHG) and land use changes are 

contributing to an increase in average global temperature (IPCC 2007). 

However, since these gases are not regulated pollutants, a discussion of this 

subject has been included in Section 4.2.14. 

The Task 1A Report for the PRB Coal Review (BLM 2005b) documents the 

modeled air quality impacts of operations during a baseline year, 2002, using 

actual emissions and operations for that year. Emissions from permitted 

minor sources were estimated, due to unavailability of actual emissions data. 

The baseline year analysis evaluated impacts both within the PRB itself and at 

selected sensitive areas surrounding the region. The analysis specifically 

looked at impacts of coal mines, power plants, CBNG development, and other 

development activities. Results were provided for both Wyoming and Montana 

at the individual receptor areas. The Task 2 Report for the PRB Coal Review 

(BLM 2005a) identifies reasonably foreseeable development activities for the 

years 2010, 2015, and 2020. 

The Task 3A Report for the PRB Coal Review (BLM 2006b) evaluates the 

impacts on air quality and air quality-related values for the year 2010 using 

the development levels projected for 2010 and the same model and 

meteorological data that were used for the baseline year study in the Task 1A 

Report. BLM updated the model and conducted impact analysis for the year 

2015 (BLM 2008h) The updated Task 3A report for the PRB Coal Review 

Cumulative Air Quality Effects for 2015 uses a revised baseline year of 2004 

with revised projected 2015 scenarios. BLM subsequently updated the model 

and conducted impact analysis for the year 2020 (BLM 2009c). The updated 

Task 3A report for the PRB Coal Review Cumulative Air Quality Effects for 2020 

uses the same baseline year of 2004 with revised projected 2020 scenarios. 

The revised baseline year emissions inventory was developed using 2004 actual 

emissions data or emissions estimates and has incorporated the recent 

analyses of emissions in Wyoming and Montana, which were not available 

when the 2010 modeling study was done. 

Existing and projected emissions sources for the baseline year (2004) and 2015 

and 2020 analyses were identified within a study area comprised of the 

following counties in the PRB in Wyoming and Montana: 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-45 

• Campbell County, all of Sheridan and Johnson counties except the 

Bighorn National Forest lands to the west of the PRB, and the northern 

portion of Converse County, Wyoming. 

• Rosebud, Custer, Powder River, Big Horn, and Treasure counties, 

Montana. 

A state-of-the-art, guideline dispersion model was used to evaluate impacts of 

the existing and projected source emissions on several source groups, as 

follows: 

• Near-field receptors in Wyoming and Montana covering the PRB Coal 

Review Task 1A and 3A study area in each state. Overall, the near-field 

receptor grid points were spaced at one kilometer intervals over the study 

area; 

• Receptors in nearby federally designated pristine or “Class I” areas; and 

• Receptors at other sensitive areas (Class II sensitive areas). 

The EPA guideline CALPUFF model system version 5.8 (Scire et al. 1999a) was 

used for this study, which differs from the version used in the Task 1A and 

original Task 3A studies. The impacts for the baseline year (2004) and for 

2015 and 2020 lower and upper coal production scenarios were directly 

modeled, and the criteria pollutants modeled were particulates (PM10 and 

PM2.5), NO2 and SO2. As discussed above, the modeling domain extends over 

most of Wyoming, southeastern Montana, southwestern North Dakota, western 

South Dakota, and western Nebraska. An interagency group participated in 

developing the modeling protocol and related domain that were used for this 

analysis. 

The modeling approach for the updated Task 3A Report used actual emissions 

from existing sources representative of 2004 operations and projected those 

emissions for the expected level of development in 2015 and in 2020. Year 

2004 emission inventory data were previously developed for the Montana 

Statewide Oil and Gas Supplemental Environmental Impact Statement. No 

specific emissions data were available for the projected levels of development. 

The baseline year emissions data were gathered from a variety of sources, but 

mainly relied on data collected by the WDEQ/AQD and the Montana 

Department of Environmental Quality (MDEQ). Only actual emission sources 

inside the study area described above were included in the modeling. Key 

major sources were included, such as the coal-fired power plants, gas-fired 

power plants, and sources that were included in the Title V (operating permit) 

program. The Dave Johnston power plant, which is located outside of but 

adjacent to the study area in Converse County, was included in the baseline 

year study and in the projected emissions. Some operational adjustments were 

made to accommodate small sources with air permits that were presumed to be 

operating at less than full capacity. Emissions from other sources, including 
4.0 Cumulative Environmental Consequences 

4-46 Final EIS, Wright Area Coal Lease Applications 

estimated construction-related fugitive dust emissions, were computed based 

on EPA emission factors and on input data from WDEQ/AQD. 

The existing regional air quality conditions generally are very good in the PRB 

Coal Review Task 1A and Task 3A study area. There are limited air pollution 

emissions sources (few industrial facilities, including the surface coal mines, 

and few residential emissions in relatively small communities and isolated 

ranches) and good atmospheric dispersion conditions. The available data show 

that the region is in compliance with the ambient air quality standards for 

nitrogen dioxide (NO2) and sulfur dioxide (SO2). There have been no monitored 

exceedances of the annual particulates (PM10) standard in the Wyoming PRB. 

Air quality modeling indicates the projected mine activities at the three Wright 

area applicant mines will be in compliance with the PM10 and PM2.5 near-field 

and short-term NO2 air standards for the 2015 and 2020 modeled air quality 

impacts at their currently permitted mining rates. All applicants have 

indicated that they propose to mine the respective LBA tracts at a rate equal to 

or below the mines’ current air quality permit levels. Visibility data collected 

around the region indicate that, although there are some days with notable 

impacts at Class I areas, the general trend in the region shows little change in 

visibility impacts at the Badlands and Wind Cave National Parks and the 

Bridger/Fitzpatrick and Cloud Peak Wilderness Areas over the period from 

1989 to 2008 (Figure 3-19). 

Predicted impacts from baseline year (2004) and projected 2015 and 2020 

emissions were modeled for four air quality criteria pollutants (NO2, SO2, PM2.5,

and PM10), along with changes in air quality-related values at Class I areas and 

at identified sensitive areas. For regulatory purposes, the Class I PSD 

(Prevention of Significant Deterioration) evaluations are not directly comparable 

to the air quality permitting requirements, because the modeling effort does not 

identify or separately evaluate increment consuming sources that would need 

to be evaluated under the PSD program. The cumulative impact analysis 

focuses on changes in cumulative impacts, but not on a comparison to PSDrelated evaluations, which would apply to specific sources. 

Table 4-11 presents the modeled impacts on ambient air quality at the nearfield receptors in Montana and Wyoming. Results indicate the maximum 

impacts at any point in each receptor group, and data are provided for the 

baseline year (2004) analysis and for both coal production scenarios for 2015 

and 2020. Peak impacts occur at isolated receptors and are likely due to 

unique source-receptor relationships. The model results should not be 

construed as predicting an actual exceedance of any standard, but are at best 

indicators of potential impacts. 

The results of the modeling depict the anticipated changes under both 

development scenarios. For the Wyoming near-field receptors, the predicted 

impact of the 24-hour PM10 and PM2.5 concentrations show localized 

exceedances of the National Ambient Air Quality Standard (NAAQS) for the 
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Final EIS, Wright Area Coal Lease Applications 4-47 

Table 4-11. Projected Maximum Potential Near-field Impacts (μg/m3).

Pollutant 

Averaging 

Time 

Base 

Year 

(2004) 

Impacts 

2020 Lower 

Coal 

Development 

Scenario 

Impacts 

2020 Upper 

Coal 

Development 

Scenario 

Impacts NAAQS 

Wyoming 

AAQS 

Mo

A

Wyoming Near-field

NO2 Annual 31.3 30.5 30.6 100 100 

SO2 Annual 15.3 16.4 16.5 80 60 

 24-hour 112.3 143.3 143.3 365 260  3-hour 462.0 936.7 936.7 1,300 1,300 

PM2.5 Annual 13.4 16.3 16.3 15 15 

 24-hour 87.6 218.4 218.4 35 35 

PM10 Annual 38.4 46.6 46.6 --- 50 

 24-hour 250.4 624.1 624.3 150 150 

Montana Near-field

NO2 Annual 3.3 2.5 2.6 100 --- 

 1-hour 409.0 440.1 442.7 188.1 --- 

SO2 Annual 1.6 3.0 3.1 80 --- 

 24-hour 16.1 24.7 27.1 365 --- 

 3-hour 65.0 138.9 138.9 1,300 --- 1

 1-hour 162.9 237.0 259.1 --- --- 1

PM2.5 Annual 1.0 0.9 0.9 15 --- 

 24-hour 10.2 10.2 10.2 35 --- 

PM10 Annual 2.8 2.5 2.6 --- --- 

 24-hour 29.1 29.3 29.3 150 --- 

1 Indicates no value, standard, or increment 

Value units are microgram per cubic meter (μg/m3) Bold values indicate projected exceedance of AAQS Source: PRB Coal Review Task 3A Update Report (BLM 2009c) 
4.0 Cumulative Environmental Consequences 

4-48 Final EIS, Wright Area Coal Lease Applications 

baseline year (2004), as well as for both development scenarios for 2015 and 

2020. The 2020 development scenarios show the concentration increases by a 

factor of 2.5 relative to the base year for these parameters. Additionally, while 

down about 10 percent from 2015, 2020 development scenarios show a 20 

percent increase of annual PM10 and PM2.5 concentrations at peak Wyoming 

near-field receptors. This level of increase indicated modeled exceedances of 

annual standards for PM2.5. Impacts of NO2 and SO2 emissions are predicted 

to be below the NAAQS and Wyoming State Ambient Air Quality Standard 

(SAAQS) at the Wyoming near-field receptors. 

Based on the modeling results, impacts at Montana near-field receptors would 

be in compliance with the Montana SAAQS for all pollutants and averaging 

periods. Importantly, the 1-hour NO2 concentrations at Montana near-field 

receptors for 2015 were predicted to exceed the SAAQS at isolated locations 

due to CBNG development in Wyoming; however, with the anticipated 

southward progression of the CBNG wells, the 1-hour NO2 concentrations in 

2020 are predicted to remain below the SAAQS. However, the modeling results 

indicate that the 1-hour NO2 concentrations at Montana near-field receptors 

for 2020 would exceed EPA’s new 1-hour NAAQS (0.001 ppm or 188.1 μg/m3). 

The southward progression of the CBNG wells also contributes to a predicted 

decrease in impacts for annual NO2, PM10 and PM2.5 relative to the baseline 

year. Although large percentage increases were predicted in SO2 impacts, the 

levels would be below the ambient standards for all pollutants in the Montana 

near-field. 

As discussed in Section 3.4.2.2.1, modeling tends to over-predict the 24-hour 

impacts of surface coal mining and, as a result, WDEQ/AQD does not consider 

short-term PM10 modeling to be an accurate representation of short-term 

impacts. In view of this, a Memorandum of Agreement between WDEQ/AQD 

and EPA Region VIII, dated January 24, 1994, allows WDEQ/AQD to conduct 

monitoring in lieu of short-term modeling for assessing coal mining-related 

impacts in the PRB. This agreement also requires “Best Available Work 

Practice” mitigation measures in all coal mine permits. The monitored 

exceedances at surface coal mines in the Wyoming PRB and the measures that 

WDEQ/AQD has implemented or is proposing to implement to prevent future 

exceedances of the PM10 NAAQS are discussed in Chapter 3, Sections 3.4.2.1 

and 3.4.2.3. 

The maximum modeled impacts on the annual PM2.5 level is projected to be 

above the standard (15 μg/m3) at near-field receptors in Wyoming for the 2015 

and 2020 lower and upper coal production scenarios. Annual PM10 levels are 

projected to be above the standard (50 μg/m3) at near-field receptors in 

Wyoming for 2015, and then to fall back below the standard for the 2020 lower 

and upper coal production scenarios. EPA has revoked the NAAQS annual 

PM10 standard of 50 μg/m3, but until Wyoming enters into rule making to 

revise the WAAQS, that standard is still effective. WDEQ/AQD issues air 

quality permits for coal mining. AQD cannot issue any permit that violates 

Ambient Air Quality Standards. Impacts of NO2 and SO2 emissions are 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-49 

predicted to be below the NAAQS and Wyoming AAQS at all Wyoming near-field 

receptors. A large portion of the impacts for all scenarios would be associated 

with coal-related sources, although non-coal sources would contribute a 

notable portion of the impact. 

Table 4-12 lists the three Class I areas and two Class II areas where the 

modeled impacts are the greatest. Table 4-12 includes a comparison to 

ambient air quality standards and PSD increments; however, it must be noted 

that this modeling analysis did not separate PSD increment-consuming 

sources from those that do not consume increment. The PSD-increment 

comparison is provided for informational purposes only and cannot be directly 

related to a regulatory interpretation of PSD increment consumption. 

None of the modeled Class I areas currently have, or are predicted to have, 

NAAQS or SAAQS exceedances. Table 4-12 compares the modeled impacts to 

the PSD Class I and sensitive Class II increment levels. At the Northern 

Cheyenne Indian Reservation (IR), Badlands National Park (NP) and Wind Cave 

NP base year impacts are slightly above the Class I comparative levels for 24-

hour PM10 in 2020. Additionally, the SO2 impacts at the Northern Cheyenne IR 

for the 3-hour and 24-hour averaging period exceed the Class I PSD increment 

levels. In the other Class I areas, only the modeled 24-hour SO2 impacts at 

Theodore Roosevelt NP and Fort Peck IR, and 3-hour SO2 impacts at Theodore 

Roosevelt NP, are above the PSD increment levels for the 2020 development 

scenarios; the predicted exceedances for these areas are due to sources outside 

the PRB study area. In the sensitive Class II areas, there are no modeled 

exceedances of the Class II PSD Increments. The modeled annual NO2 impacts 

at the Cloud Peak Wilderness Area (WA) and Crow IR are projected to increase 

by a factor of 2 to 4, respectively, in 2020 as a result of projected CBNG and 

coal hauling activities. For comparison purposes, modeling results for all 

sensitive Class II areas are below PSD increment levels for both 2020 

development scenarios. 

The projected modeled visibility impacts for the baseline year (2004) and for the 

lower and upper coal production scenarios for 2020 for all analyzed Class I and 

sensitive Class II areas are listed in Table 4-13. For the baseline year, the 

maximum visibility impacts at Class I areas were determined to be at the 

Northern Cheyenne Indian Reservation in Montana and at Wind Cave and 

Badlands National Parks in South Dakota. For these locations, modeling 

showed more than 200 days of impacts with a change of 10 percent or more in 

extinction. A 10 percent change in extinction corresponds to 1.0 deciview (dv). 

Table 4-13 provides a detailed listing of visibility impacts for all analyzed Class 

I and sensitive Class II areas. As with the 2015 modeling results, 2020 

modeled visibility impacts at the identified Class I areas continue to show a 

similar pattern as exhibited for the base year (2004), with a high number of 

days with a greater than 10 percent change in visibility at the most impacted 

Class I areas. Visibility impacts at Badlands NP, Northern Cheyenne IR, and 

Wind Cave NP all have greater than 10 percent change for more than 200 days 
4.0 Cumulative Environmental Consequences 

 4-50 Final EIS, Wright Area 

Table 4-12. Maximum Predicted PSD Class I and Sensitive Class II Area Impacts (μg/m3). 

Location Pollutant Averaging Period 

Base Year (2004) 

Impacts 

2020 Lower Coal 

Development 

Scenario 

2020 Upper 

Developm

Scenari

Class I Areas 

NO2 Annual 0.4 0.8 1.1 

Annual 0.5 1.1 1.3 

SO2 24-hour 3.1 7.1 12.8 

3-hour 9.4 23.6 39.7 

Annual 0.3 0.4 0.5 

PM2.5 24-hour 3.4 4.5 4.6 

Annual 0.9 1.2 1.5 

Northern Cheyenne 

Indian Reservation 

PM10 24-hour 9.6 12.9 13.2 

NO2 Annual 0.1 0.2 0.2 

Annual 0.5 0.6 0.2 

SO2 24-hour 3.6 4.0 4.0 

3-hour 8.1 8.2 8.2 

Annual 0.2 0.3 0.3 

PM2.5 24-hour 2.1 3.0 3.1 

Annual 0.7 0.9 1.0 

Badlands 

National Park 

PM10 24-hour 5.9 8.5 8.8 

NO2 Annual 0.2 0.3 0.3 

Annual 0.7 0.8 0.8 

SO2 24-hour 3.7 4.6 4.7 

3-hour 7.0 7.5 7.7 

Annual 0.4 0.5 0.5 

PM2.5 24-hour 3.8 4.6 4.7 

Annual 1.0 1.4 1.4 

Wind Cave 

National Park 

PM10 24-hour 10.9 13.0 13.3 

Sensitive Class II Areas

NO2 Annual 0.06 0.12 0.12 

Annual 0.2 0.3 0.3 

SO2 24-hour 2.0 2.5 2.5 

3-hour 8.0 8.9 9.0 

Annual 0.2 0.2 0.2 

PM2.5 24-hour 2.6 3.2 3.39 

Annual 0.5 0.7 0.7 

Cloud Peak 

Wilderness Area 

PM10 24-hour 7.4 9.1 9.3 

NO2 Annual 0.9 3.6 4.2 

Annual 2.3 2.4 2.7 

SO2 24-hour 14.4 14.8 14.8 

3-hour 76.8 77.0 77.0 

Annual 0.8 0.8 0.8 

PM2.5 24-hour 7.2 7.2 7.2 

Annual 2.2 2.3 2.4 

Crow 

Indian Reservation 

PM10 24-hour 20.5 20.6 20.6 

1 Indicates no increment 

Value units are micrograms per cubic meter (μg/m3) 

Bold values indicate exceedance of PSD increment Source: PRB Coal Review Task 3A Update Report (BLM 2009c) 
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Final EIS, Wright Area Coal Lease Applications 4-51 

Table 4-13. Modeled Change in Visibility Impacts at Class I and Sensitive 

Class II Areas. 

Base Year 

(2004) 

2020 Lower 

Coal 

Development 

Scenario 

2020 Upper 

Coal 

Development 

Scenario 

Location 

No. of Days 

>10% 

Change in 

No. of Days 

>10% 

Change in 

No. of Days 

>10% 

Class I Areas

Badlands National Park 218 44 44 

Bob Marshall WA 8 0 0 

Bridger WA 144 5 5 

Fitzpatrick WA 91 6 6 

Fort Peck Indian Reservation 105 20 21 

Gates of the Mountain WA 55 4 4 

Grand Teton National Park 70 6 6 

North Absaroka WA 61 8 8 

North Cheyenne Indian Reservation 243 59 60 

Red Rock Lakes 42 3 3 

Scapegoat WA 27 2 2 

Teton WA 57 8 8 

Theodore Roosevelt National Park 178 24 24 

UL Bend WA 77 18 18 

Washakie WA 83 8 8 

Wind Cave National Park 262 28 31 

Yellowstone National Park 84 5 5 

Sensitive Class II Areas 

Absaroka Beartooth WA 101 10 10 

Agate Fossil Beds National Monument 251 26 26 

Big Horn Canyon National Rec. Area 331 1 1 

Black Elk WA 236 47 47 

Cloud Peak WA 126 29 30 

Crow Indian Reservation 360 3 3 

Devils Tower National Monument 274 31 32 

Fort Belknap Indian Reservation 66 14 15 

Fort Laramie National Historic Site 260 15 16 

Jedediah Smith WA 79 3 5 

Jewel Cave National Monument 261 36 37 

Lee Metcalf WA 97 2 2 

Mount Naomi WA 51 1 1 

Mount Rushmore National Monument 222 49 52 

Popo Agie WA 139 6 6 

Soldier Creek WA 268 19 19 

Wellsville Mountain WA 130 17 17 

Wind River Indian Reservation 217 9 10 

Source: PRB Coal Review Task 3A Update Report (BLM 2009c)
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4-52 Final EIS, Wright Area Coal Lease Applications 

a year during the base year. These Class I areas are the top three Class I areas 

with the highest predicted change in light extinction in 2020. All but four of 

the sensitive Class II areas have more than 100 days per year with greater than 

a 10 percent change during the base year. The most significant visibility 

change to sensitive Class II areas in 2020 is predicted for Black Elk WA and 

Mount Rushmore National Monument. Class II areas do not have any visibility 

protection under federal or state law. To provide a basis for discussing the 

modeled visibility impacts resulting from the projected increased production 

under the lower and upper coal production scenarios for 2020, the modeled 

visibility impacts for 2004 were subtracted from the model results for 2020. 

Table 4-13 shows the number of additional days that the projected impacts 

were greater than 1.0 dv (10 percent in extinction) for each site for the upper 

and lower coal production scenarios. Using Badlands Park as an example, the 

modeling analysis showed 218 days with impacts greater than 1.0 dv in 2004. 

Under the 2020 lower coal production scenario, the modeling analysis projects 

an additional 44 days with impacts greater than 1.0 dv, or a total of 262 days 

with impacts greater than 1.0 dv. 

For acid deposition, all predicted impacts are below the deposition threshold 

values for both nitrogen and sulfur compounds. There are substantial 

percentage increases in deposition under the lower and upper coal production 

scenarios for 2015; however, impacts remain well below the nitrogen and sulfur 

levels of concern (1.5 and 5.0 kilograms per hectare per year, respectively). 

The acid neutralizing capacity (ANC) of sensitive lakes also was analyzed, and 

results are summarized in Table 4-14. The base year study indicated that 

none of the lakes had predicted significant impacts except Upper Frozen Lake; 

however, the lower and upper development scenarios for 2020 show an 

increased impact at Florence Lake, leading to an impact above the 10 percent 

change in acid neutralizing capacity. Impacts also are predicted to be above 1 

microequivalent per liter (μeq/L) for Upper Frozen Lake. 

The study also modeled impacts of selected hazardous air pollutant emissions 

(benzene, ethyl benzene, formaldehyde, n-hexane, toluene, and xylene) on the 

receptors with the highest ambient impacts. The near-field receptors in 

Wyoming and Montana were analyzed for annual (chronic) and 1-hour (acute) 

impacts. Model results for the base year (2004) and 2020 development 

scenarios show that impacts are predicted to be well below the acute Reference 

Exposure Levels, non-carcinogenic Reference Concentrations for Chronic 

Inhalation, and carcinogenic risk threshold for all hazardous air pollutants. 

The maximally exposed individual’s carcinogenic risk factor due to benzene 

exposure is predicted to increase 50 percent as a result of projected 

development in the PRB, however, even with this substantial increase, the 

predicted risk is well below U.S. Environmental Protection Agency (EPA) 

carcinogenic risk thresholds. 

Comparing the PRB Coal Review updated Task 3A Report for 2020 (BLM 2009c) 

to the earlier update for 2015 shows a similar general increase in air quality 
4.0 Cumulative Env

Final EIS, Wright Area Coal Lease Applications 4-53 

Table 4-14. Predicted Total Cumulative Change in Acid Neutralizing Capacity of Sensitive Lakes

Location Lake 

Background 

ANC 

(μeq/L) 

Area 

(hectares) 

Base Year 

2004 Change 

(percent) 

2020 Lower Coal 

Development 

Scenario Change 

(percent) 

2020 Uppe

Developm

Scenario C

(percen

Black Joe 67.0 890 4.00 4.26 4.27 

Deep 60.0 205 4.70 4.98 4.99 

Hobbs 70.0 293 3.95 4.14 4.15 

Bridger Wilderness Area 

Upper Frozen 5.0 64.8 2.42 2.55 2.56 

Cloud Peak Emerald 55.3 293 5.24 6.69 6.30 Wilderness Area Florence 32.7 417 9.09 11.79 11.99 

Fitzpatrick Wilderness Area 

Ross 53.5 4,455 2.72 2.89 2.90 

Popo Agie Wilderness Area 

Lower 

Saddlebag 55.5 155 6.28 6.65 6.67 

1 Data for Upper Frozen Lake presented in changes in μeq/L rather than percent change. (For lakes with less than 25 μeq/L bacSource: PRB Coal Review Task 3A Update Report (BLM 2009c)
4.0 Cumulative Environmental Consequences 

4-54 Final EIS, Wright Area Coal Lease Applications 

effects over time compared to the base year. The production from conventional 

oil and gas activities is projected to peak at 2010, with slight declines predicted 

over the following decade. The production from CBNG activities was projected 

to peak at 2015, with slight declines predicted over the following decade; 

however the actual development has been slower than predicted and therefore 

the peak year has been shifted later. Therefore, from these sources, expected 

impacts have increased slightly from 2015 to 2020. The coal mining and 

CBNG sources would be the major contributors to PM10 and PM2.5 impacts in 

the near-field between 2015 and 2020, and these impacts would result from 

the proximity of the receptors to the coal mining operations. As noted above, 

the general south and westward trend of CBNG activity has lowered NO2 and 

particulate air quality effects projected in Montana by 2020. 

Power plants currently are the major contributors to all SO2 impacts in the 

near-field in both states. However, the projected impacts are well below any 

ambient standard or PSD increment. According to the PRB Coal Review Air 

Quality modeling analysis, predicted future expansion modeled to the year 

2020 should not jeopardize the attainment of those standards. Impacts on NO2

concentrations are the result of emissions from all the source groups. No one 

source group dominates the NO2 impacts in the near-field. 

A pattern that is similar to the near-field receptors holds true for the Class I 

and sensitive Class II receptor groups. Essentially, the mine operations would 

continue to dominate the PM10 and PM2.5 impacts, the power plants would 

continue to dominate the SO2 impacts (although they would continue to be 

below the standards), and the overall source groups would continue to 

contribute to NO2 impacts. Impacts should remain below the annual NO2

standard for 2015 and 2020 in Wyoming and Montana. 

Based on modeling results, one of the lakes (Florence) in the Cloud Peak Class 

I area and one lake (Upper Frozen Lake) in the Bridger Class I area exceeded 

the acid deposition thresholds for both the lower and upper coal production 

scenarios for 2015. With the exception of Florence and Upper Frozen lakes, the 

projected increases in coal development (and power plants) are not expected to 

raise the deposition levels above the thresholds extended into 2020. The model 

results showed that the increased deposition, largely from SO2 emissions from 

power plants, exceeded the thresholds of significance for the ANC at sensitive 

(high alpine) lakes. The results indicate that with increased growth in power 

plant operations, the reduced ANC of the sensitive lakes would need to be 

addressed carefully for each proposed major development project. 

WDEQ/AQD and WDEQ/LQD mitigation and monitoring requirements for coal 

mine emissions are discussed in Sections 3.4.2.3 and 3.4.3.3. The discussion 

in these sections includes the operational control measures that are currently 

in place and would be required for mining operations on LBAs that are issued 

in the future, as well as measures that may be required to avoid future 

exceedances of the WAAQS and NAAQS and/or future mine-related impacts to 

the public. 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-55 

4.2.4 Water Resources

Surface and groundwater are used extensively throughout the PRB for 

agricultural water supply, municipal water supply, and both domestic and 

industrial water supply. Surface water use is limited to major perennial 

drainages and agricultural areas within the basin are found mainly along these 

drainages. Reservoirs are also used throughout the basin for agricultural 

water supply. Municipal water supply comes from a combination of surface 

and groundwater. Domestic and industrial water supply primarily is from 

groundwater. 

The PRB Coal Review Task 1B Report (BLM 2009d) describes the base year 

(2002) water resource conditions in the PRB study area, which comprises all of 

Campbell County, all of Sheridan and Johnson counties less the Bighorn 

National Forest lands to the west of the PRB, and the northern portion of 

Converse County (Figure 4-4). The Task 3B Report for the PRB Coal Review 

(BLM 2009e) presents potential future cumulative groundwater impacts in the 

area of CBNG development and coal mine expansion in the eastern PRB (Figure 

4-4), and provides a cumulative impact assessment of surface water quality 

and channel stability from surface discharge of groundwater from CBNG 

development. 

4.2.4.1 Groundwater

There are five main aquifers in the PRB Coal Review Task 1 and 3 study area 

(Figure 4-4) that can be used for water supply: 

• Madison Aquifer System; 

• Dakota Aquifer System; 

• Fox Hills/Lance Aquifer System; 

• Fort Union/Wasatch Aquifer System; and 

• Quaternary Alluvial Aquifer System. 

The Fort Union/Wasatch Aquifer System includes the coal and overburden 

aquifers that are directly affected by surface coal mining and CBNG 

development. It is also a major source of local water supply for domestic and 

stock water use. Table 4-15 shows the recoverable groundwater in the 

components of the Fort Union/Wasatch Aquifer System. The Wasatch 

Formation is more of a local aquifer, while the Fort Union Formation is a 

regional aquifer. The volumes of recoverable groundwater from the sandstones 

within the Wasatch/Tongue River Aquifer, the Lebo Confining Layer, and the 

Tullock Aquifer were determined from the volume of sandstone in each of these 

units multiplied by the 13 percent specific yield value for sandstone. Similarly, 

the volume of recoverable groundwater from the coals within the 

Wasatch/Tongue River was calculated from the volume of coal multiplied by 

the 0.4 percent specific yield value for coal. 
4.0 Cumulative Environmental Consequences 

4-56 Final EIS, Wright Area Coal Lease Applications 

Table 4-15. Recoverable Groundwater in the Fort Union/Wasatch Aquifer 

System in the PRB.

Hydrogeologic 

Unit 

Surface Area (acres) Average Formation Thickness (ft) Percentage of Sand/Coal Average Sand/Coal Thickness (ft) Specific Yield (percent) Recoverable Groundwater (acre-feet)1 

Wasatch-Tongue 

River Aquifer 

Sandstones 

5,615,609 2,035 50.0 1,018 13.0 743,121,790 

Wasatch-Tongue 

River Aquifer Coals 4,988,873 2,035 6.2 126 0.4 2,516,519 

Lebo Confining 

Layer Sandstones 6,992,929 1,009 33.0 250 13.0 227,137,339 

Tullock Aquifer 

Sandstones 7,999,682 1,110 52.0 430 13.0 447,246,784 

1 Calculated by multiplying Surface Area × Average Sand/Coal Thickness × Specific Yield. These 

numbers vary slightly from the numbers presented in Table 3-5 of the Final Environmental Impact 

Statement and Proposed Plan Amendment for the PRB Oil and Gas Project. 

Source: BLM 2003 

As a result of statutory requirements and concerns, several studies and a 

number of modeling analyses have been conducted to help predict the impacts 

of surface coal mining on groundwater resources in the Wyoming portion of the 

PRB. Some of these studies and modeling analyses are discussed below. 

In 1987, the U.S. Geological Survey (USGS), in cooperation with the WDEQ and 

Office of Surface Mining Reclamation and Enforcement (OSM), conducted a 

study of the hydrology of the eastern PRB. The resulting description of the 

cumulative hydrologic effects of all current and anticipated surface coal mining 

(as of 1987) was published in 1988 in the USGS Water-Resources Investigation 

Report entitled “Cumulative Potential Hydrologic Impacts of Surface Coal Mining 

in the Eastern Powder River Structural Basin, Northeastern Wyoming,” also 

known as the “USGS CHIA” (Martin et al. 1988). This report evaluates the 

potential cumulative groundwater impacts of surface coal mining in the area 

and is incorporated by reference into this EIS. The USGS CHIA analysis 

considered the proposed mining at the three applicant mines in the Wright 

area. It did not, however, evaluate potential groundwater impacts related to 

additional coal leasing in this area and it did not consider the potential for 

overlapping groundwater impacts from coal mining and CBNG development. 

Each mine must assess the probable hydrologic consequences of mining as 

part of the mine permitting process. The WDEQ/LQD must evaluate the 

cumulative hydrologic impacts associated with each proposed mining operation 

before approving the mining and reclamation plan for each mine, and they 

must find that the cumulative hydrologic impacts of all anticipated mining 

would not cause material damage to the hydrologic balance outside of the 

permit area for each mine. As a result of these requirements, each existing 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-57 

approved mining permit includes an analysis of the hydrologic impacts of the 

surface coal mining proposed at that mine. If major amendments to mining 

and reclamation permits are proposed, then the potential cumulative impacts 

of the revisions must also be evaluated. If the six WAC LBA tracts are leased to 

the respective applicants, the existing mining and reclamation permits for each 

current mine must be revised and approved to include the new lease before it 

can be mined. 

The PRB Oil and Gas Project FEIS (BLM 2003) includes a modeling analysis of 

the groundwater impacts if an additional 39,000 new CBNG wells are drilled in 

the PRB by the end of 2011. The project area for this EIS, which covers all of 

Campbell, Sheridan, and Johnson counties, as well as the northern portion of 

Converse County, is similar to the study area for the PRB Coal Review Task 1 

and Task 2 study area (Figure 4-4). 

The coal mine groundwater monitoring data are published each year by the 

Gillette Area Groundwater Monitoring Organization (GAGMO), a voluntary 

group formed in 1980. Members of GAGMO include most of the companies 

with operating or proposed mines in the Wyoming PRB, WDEQ, Wyoming State 

Engineer’s Office (SEO), BLM, USGS, and OSM. GAGMO contracts with an 

independent firm each year to publish the annual monitoring results. GAGMO 

also periodically publishes reports summarizing the water monitoring data 

collected since 1980 in the Wyoming PRB (e.g., Hydro-Engineering 1991, 1996, 

2001, and 2007). 

Another source of data on the impacts of surface coal mining on groundwater 

is the monitoring that is required by WDEQ/LQD and administered by the 

mining operators. Each mine is required to monitor groundwater levels and 

quality in the affected coal aquifers, in the shallower aquifers (overburden and 

alluvium), and in the subcoal aquifers in the area surrounding their 

operations. Monitoring wells are also required to record water levels and water 

quality in reclaimed areas. Hydrologic monitoring data and analyses are 

submitted to the WDEQ/LQD annually. 

The cumulative impacts to groundwater resources associated with large scale 

surface coal mining in the eastern PRB have been identified as five major 

issues: 

1. The extent of the temporary lowering of static water levels in the aquifers 

around the mines due to dewatering associated with removal of aquifers 

within the mine boundaries. 

2. Potential overlapping drawdown due to proximity of coal mining and 

CBNG development. 

3. The effect of the removal of the coal aquifer and any overburden aquifers 

within the mine area and replacement of these aquifers with backfill 

material. 
4.0 Cumulative Environmental Consequences 

4-58 Final EIS, Wright Area Coal Lease Applications 

4. Changes in groundwater quality as a result of mining. 

5. The effects of the use of water from the subcoal Fort Union Formation by 

the mines. 

The first major issue is the extent of water level drawdown in the coal and 

shallower aquifers in the area surrounding the mines. In general, the 

saturated sand aquifers in the Wasatch Formation overburden have limited 

extent and, as a result, the drawdowns in the Wasatch Formation are much 

smaller and cover much less area than the coal drawdowns. 

The GAGMO 25-year report provides actual groundwater drawdown 

information after 25 years of mining (Hydro-Engineering 2007). Of the 530 

monitoring wells included in the GAGMO 25-year report, 195 are completed in 

the Upper Fort Union (or Wyodak) coal beds and 193 are completed in the 

overlying sediments or interburden between the coal beds located within and 

near the mine sites in the eastern PRB. The balance of the monitoring wells 

are completed in local alluvial aquifers or in strata below the lowest coal seam 

mined. Since 1996, some BLM monitor wells have been included in the 

GAGMO reports. 

The USGS CHIA predicted the approximate area of 5 feet or more water level 

decline in the Wyodak coal aquifer which would result from “all anticipated 

coal mining.” “All anticipated coal mining” included 16 surface coal mines 

operating at the time the report was prepared and six additional mines 

proposed at that time. All of the currently producing mines, including the 

three applicant mines in the Wright area, were considered in the USGS CHIA 

analysis (Martin et al. 1988). The study predicted that water supply wells 

completed in the coal may be affected as far away as 8 miles from mine pits, 

although the effects at that distance were predicted to be minimal. 

As drawdown propagates to the west, available drawdown in the coal aquifer 

increases. Available drawdown is defined as the elevation difference between 

the potentiometric surface (elevation to which water will rise in a well bore) and 

the bottom of the aquifer. Proceeding west, the coal depth increases faster 

than the potentiometric surface declines, so available drawdown in the coal 

increases. Since the depth to coal increases, most stock and domestic wells 

are completed in units above the coal. Consequently, with the exception of 

CBNG wells, few wells are completed in the coal in the areas west of the mines. 

Those wells completed in the coal have considerable available drawdown, so it 

is unlikely that surface coal mining would cause adverse impacts to wells 

outside the immediate mine area. 

Wells in the Wasatch Formation were predicted to be impacted by drawdown 

only if they were within 2,000 feet of a mine pit (Martin et al. 1988). Drawdown 

occurs farther from the mine pits in the coal than in the shallower aquifers 

because the coal is a confined aquifer that is areally extensive. The area in 

which the shallower aquifers (Wasatch Formation, alluvium, and clinker) 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-59 

experience a 5-feet drawdown would be much smaller than the area of 

drawdown in the coal because the shallower aquifers are generally 

discontinuous, of limited areal extent, and often unconfined. 

When the USGS CHIA was prepared in 1988 there were about 1,200 water 

supply wells within the maximum impact area defined in that study. Of those 

wells, about 580 were completed in Wasatch aquifers, about 100 in the Upper 

Fort Union (or Wyodak coal) aquifer, and about 280 in strata below the coal. 

There were no completion data available for the remainder of the wells (about 

240) at that time. 

The WDEQ/LQD Cumulative Hydrologic Impact Assessment of Coal Mining in 

the Southern Powder River Basin (WDEQ-CHIA-19) (Ogle and Calle 2006) 

examined the cumulative hydrologic impact of coal mining in the Wright 

subregion to determine the potential for material damage to the hydrologic 

system. Analysis of the cumulative impacts as a result of mining was 

performed by qualitatively assessing the additive impacts of these mines. Each 

mine is required by WDEQ/LQD to evaluate the impacts to the hydrologic 

resources and will typically model groundwater level drawdown using the most 

conservative, worst-case scenario. The extent of the 5-feet drawdown contour 

is used by WDEQ/LQD to assess the extent of the impact to the groundwater 

system caused by mining operations. The predicted maximum 5-foot 

drawdown contour for the Wyodak coal aquifer from all four Wright area coal 

mines (Jacobs Ranch, Black Thunder, North Antelope Rochelle, and Antelope) 

was superimposed by Ogle and Calle (2006) to generate the 5-foot cumulative 

estimate. The areal extent of cumulative drawdown within the Wyodak coal 

aquifer with the addition of the six WAC LBA tracts to the Jacobs Ranch, Black 

Thunder and North Antelope Rochelle mines, as defined by the 5-foot 

drawdown contour, was extrapolated using the WDEQ-CHIA-19 prediction and 

is depicted in Figure 4-5. 

If the six WAC LBA tracts are leased and mined, the groundwater drawdown 

would be extended into the area surrounding the proposed new leases. When a 

lease is issued to an existing mine for a maintenance tract, the mine must 

revise its existing mining permit to include the new tract in its mine and 

reclamation plans. In order to do that, the lessee would be required to conduct 

a detailed groundwater analysis to predict the extent of drawdown in the coal 

and overburden aquifers caused by mining the new lease. WDEQ/LQD would 

use the revised drawdown predictions to update their cumulative hydrologic 

impact analysis (WDEQ-CHIA) for this portion of the PRB. The applicants have 

installed monitoring wells that would be used to confirm or refute drawdown 

predicted by analysis. These analyses would be required as part of the WDEQ 

mine permitting procedure, which is discussed in Chapter 1 of this EIS. 

The PRB Coal Review Task 2 Report (BLM 2009b) defines the past and present 

development actions in the PRB study area, which comprises all of Campbell 

County, all of Sheridan and Johnson counties less the Bighorn National Forest 

lands, and the northern portion of Converse County (Figure 4-4). The Task 2 
Savageton Road

Moore Road

Todd Road

Mills Road

Clarkelen Road

Cosner

Breen

Hoadley

Lawver Road Jacobs

Mackey

Antelope

Edwards

State Highway 50

State Highway 387

Matheson Road

Reno Road

BNSF & UP RR

State 59 Highway

State

 59

Highway

Hilight Road

Road

Road

Road Lawver Road

Keeline

Road

State 450 Highway

Road

Road

Antelope

Road

Road

Wagensen

Road

Matheson

Road

T.

46

N.

 R. 75 W.

Weston County

Campbell County

Converse County

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

T.

40

N.

T.

39

N.

 R. 74 W. R. 73 W. R. 72 W. R. 71 W. R. 70 W. R. 69 W.

 R. 75 W. R. 74 W. R. 73 W. R. 72 W. R. 71 W. R. 70 W. R. 69 W.

T.

46

N.

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

T.

40

N.

T.

39

N.

Campbell County

County Road

State Highway 387

5'

5'

5'

TOWN OF

WRIGHT

LEGEND

Existing Lease Boundary

0 18000 36000 72000

GRAPHIC SCALE (FEET)

Extent of WDEQ's Cumulative and Extrapolated

Life of Mine Drawdown (5 feet) with

Wright Area Coal LBA Tracts

Clinker

Approximate Wyodak Coal Outcrop

Clinker and coal outcrop information modified from

Plate 1 in Heffern and Coates (2000).

Groundwater cumulative impact area information taken

from Plate 1 in WDEQ-CHIA-19 (Ogle and Calle 2006).

West Jacobs Ranch LBA Tract as Applied for

South Hilight Field LBA Tract as Applied for

West Hilight Field LBA Tract as Applied for

North Porcupine LBA Tract as Applied for

North Hilight Field LBA Tract as Applied for

South Porcupine LBA Tract as Applied for

5'

Figure 4-5. Extrapolated Extent of Life of Mine Cumulative Drawdown Within the Wyodak Coal Aquifer With

the Addition of Wright Area Coal LBA Tracts.

4.0 Cumulative Environmental Consequences

4-60 Final EIS, Wright Area Coal Lease Applications
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-61 

report also defines the projected reasonably foreseeable development (RFD) 

scenarios in the PRB for years 2010, 2015, and 2020, and provides the basis 

for the analysis of potential cumulative impacts in the Task 3 component of the 

study. 

The PRB Coal Review Task 3B Report (BLM 2009e) summarizes the modeled 

changes in groundwater levels projected for 2010, 2015, and 2020 in the 

eastern PRB within approximately 25 miles of the coal mines. The cumulative 

effects study area for water resources encompasses the groundwater model 

domain (Figure 4-4), with emphasis placed on the overlap in the coal mine- and 

CBNG-related groundwater drawdown area. Projected groundwater level 

changes primarily are due to CBNG groundwater withdrawal in the Upper Fort 

Union Formation and to both CBNG pumping and discharge along with coal 

mine pit dewatering in the Wasatch Formation. Near the coal mines, coal mine 

dewatering of the Upper Fort Union also has affected groundwater levels in that 

formation. Groundwater level recovery in the eastern PRB after the cessation 

of both CBNG development and coal mining, and the effect on groundwater 

flow paths associated with coal mine pit backfill and reclamation after the 

cessation of coal mining in the eastern PRB also were modeled and the results 

are included in the Task 3B report. For purposes of modeling groundwater 

recovery, it was assumed that CBNG development in the eastern PRB would 

cease by 2030 and surface coal mining would cease by 2050 (BLM 2009e). 

The Task 3B report describes the modeled cumulative groundwater impacts 

associated with ongoing coal mine-related groundwater withdrawal in the 

eastern PRB for the time periods of 2010, 2015, and 2020, and the base years 

used for comparison of groundwater impacts were 2002 (the year used for 

calibration of the groundwater model) and 1990 (a time period prior to CBNG 

pumpage and before major expansion by the eastern PRB coal mines). The 

eastern PRB cumulative effects study area for water resources comprises the 

Coal Mine Groundwater Model (CMGM) domain as shown in Figure 4-4 (BLM 

2009e). The CMGM was developed specifically for the PRB Coal Review study. 

The GAGMO databases for 1990 to 2002 were used to calibrate the 

groundwater model to best reflect conditions in the basin. 

The primary objective of the Task 3B report is to provide an estimate of 

potential future cumulative impacts to water resources in the eastern PRB of 

Wyoming due to CBNG development and coal mining for the target years 2010, 

2015, and 2020. To accomplish that objective, the Task 3B report evaluated 

the potential groundwater impacts due only to coal mine dewatering. The 

projected locations of coal mine pits from 2002 to 2020 were used for 

placement of drain cells in the groundwater model that represent pumpage of 

groundwater by the mines. The amount of water removed by the drain cells 

reflects calibration to GAGMO monitoring wells surrounding each mine, rather 

than estimated or recorded discharge rates (BLM 2009e). 

Projected groundwater level changes in the Wasatch generally are due to coal 

mine dewatering and CBNG pumping and discharge, which generally result in 
4.0 Cumulative Environmental Consequences 

4-62 Final EIS, Wright Area Coal Lease Applications 

local mounding of groundwater in the Wasatch near CBNG fields and 

drawdown near the coal mines (BLM 2009e). The Wasatch Formation is not a 

true aquifer in that it has only discontinuous water-bearing sand units not 

consistent and uniform groundwater level over the eastern PRB; therefore, 

groundwater level drawdowns due to mining are very localized and in close 

proximity to the mine operation. For the Upper Fort Union, groundwater level 

changes are due to CBNG pumpage and coal mine dewatering. Between 2002 

and 2020, the projected reduction in coal mine dewatering and the expected 

reduction in CBNG pumpage from Wright northward toward Gillette are 

projected to result in a rebound of groundwater levels both within the coal 

mine boundaries and especially within the basin west of the coal mines (BLM 

2009e). 

Based on the results of the CMGM, the effect of coal mine dewatering on the 

Upper Fort Union from 1990 to 2010 in Subregion 3 is a cumulative drawdown 

ranging from approximately 50 to 250 feet in the vicinity of the Antelope and 

North Antelope Rochelle mines, and from 50 to 150 feet in the vicinity of the 

Black Thunder and Jacobs Ranch mines. The 25-foot drawdown contour was 

projected to be less than 3 miles west of the four Wright area mines’ westernmost boundaries (Figure 4-6). The modeled drawdown in the Upper Fort Union 

due to coal mine dewatering from 1990 to 2020 in Subregion 3 indicated there 

is approximately 50 to 100 feet of groundwater rebound in area of the 

Subregion 3 mines due to a reduction in coal mine dewatering and ongoing 

reclamation. Drawdown in the Upper Fort Union attributable to mining only 

from 1990 to 2020 ranges from 25 to 125 feet in the active mine areas with up 

to 125 feet of rebound in the reclaimed areas. The location of the 25-foot 

drawdown contour was projected to be essentially the same as the 25-foot 

drawdown limit in 2010; 3 miles or less west of the Subregion 3 mines (Figure 

4-7) (BLM 2009e). 

The second issue of concern is the potential for cumulative impacts to 

groundwater resources due to the proximity of coal mining and CBNG 

development. The Upper Fort Union (Wyodak) coal is being developed by 

mining and CBNG production in the same general area. Dewatering activities 

associated with CBNG development have overlapped with and expanded the 

area of groundwater drawdown in the coal aquifer in the PRB over what would 

occur due to coal mining development alone, and this would be expected to 

continue. 

Numerical groundwater flow modeling was used to predict the impacts of the 

cumulative stresses imposed by mining and CBNG development on the Upper 

Fort Union Formation coal aquifer in the PRB Oil and Gas Project EIS (BLM 

2003). Modeling was necessary because of the large areal extent, variability, 

and cumulative stresses imposed by mining and CBNG development on the 

Fort Union coal aquifers. Information from earlier studies was incorporated 

into the modeling effort for this analysis. As expected, the modeling indicated 

that the groundwater impacts from CBNG development and surface coal 

mining would be additive in nature and that the addition of CBNG development 
Converse County

Campbell County

WRIGHT

Dry Fork Cheyenne River

Antelope Creek

Porcupine

Creek

Little

Thunder Creek

Black Thunder Creek

BaconCreek

Belle

Fourche

River

Horse

PumpkinCreek

North Fork

Bear

Creek

Antelope

Creek

59

59

387

T.

46

N.

 R. 75 W.

T.

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N.

T.

44

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T.

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N.

T.

41

N.

T.

40

N.

T.

39

N.

 R. 74 W. R. 73 W. R. 72 W. R. 71 W. R. 70 W. R. 69 W.

 R. 75 W. R. 74 W. R. 73 W. R. 72 W. R. 71 W. R. 70 W. R. 69 W.

T.

46

N.

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

T.

40

N.

T.

39

N.

 R. 76 W.

 R. 76 W.

150'

175'

150'

25'

25'

25'

25'

25'

100'

25'

25'

25'

100'

100'

100'

100'

100'

175'

175'

175'

100'

150'

150'

150'

25'

100'

Approximate Coal Mined-out Area

through 2006

Coal Mine Groundwater Model

(CMGM) Domain

0 20000 40000 80000

GRAPHIC SCALE (FEET)

LEGEND

Approximate Wyodak Coal Outcrop

Extent of CMGM Cumulative

Drawdown, in feet

Note: Includes effects of coal mine

groundwater pumping only. Source: BLM 2009e

Upper Fort Union Outcrop Area

Wasatch Outcrop Area

25'

Figure 4-6. Coal Mine Groundwater Model, Upper Fort Union Formation, 1990-2010 Coal Mine-related

Groundwater Level Drawdown.

4.0 Cumulative Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 4-63
Converse County

Campbell County

WRIGHT

Dry Fork Cheyenne River

Antelope Creek

Porcupine

Creek

Little

Thunder Creek

Black Thunder Creek

BaconCreek

Belle

Fourche

River

Horse

PumpkinCreek

North Fork

Bear

Creek

25'

25'

25'

25'

25'

25'

100'

100'

100'

100'

100'

100'

100'

100'

25'

25'

25'

Antelope

Creek

59

59

387

T.

46

N.

 R. 75 W.

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

T.

40

N.

T.

39

N.

 R. 74 W. R. 73 W. R. 72 W. R. 71 W. R. 70 W. R. 69 W.

 R. 75 W. R. 74 W. R. 73 W. R. 72 W. R. 71 W. R. 70 W. R. 69 W.

T.

46

N.

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

T.

40

N.

T.

39

N.

 R. 76 W.

 R. 76 W.

Approximate Coal Mined-out Area

through 2006

Coal Mine Groundwater Model

(CMGM) Domain

0 20000 40000 80000

GRAPHIC SCALE (FEET)

LEGEND

Approximate Wyodak Coal Outcrop

Extent of CMGM Cumulative

Drawdown, in feet

Note: Includes effects of coal mine

groundwater pumping only. Source: BLM 2009e

Upper Fort Union Outcrop Area

Wasatch Outcrop Area

25'

Figure 4-7. Coal Mine Groundwater Model, Upper Fort Union Formation, 1990-2020 Coal Mine-related

Groundwater Level Drawdown.

4.0 Cumulative Environmental Consequences

4-64 Final EIS, Wright Area Coal Lease Applications
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-65 

would extend the area experiencing a loss in hydraulic head to the west of the 

mining area. The GAGMO 25-year Report stated that drawdowns in all areas 

have greatly increased due to the water production from the Wyodak coal 

aquifer by CBNG producers (Hydro-Engineering 2007). 

As previously stated, the PRB Coal Review Task 2 Report (BLM 2009b) defines 

the projected RFD scenarios in the PRB for years 2010, 2015, and 2020, and 

provides the basis for the analysis of potential cumulative impacts in the Task 

3 component of the study. The Task 3B Report (BLM 2009e) summarizes the 

modeled changes in groundwater levels projected for 2010, 2015, and 2020 in 

the eastern PRB within approximately 25 miles of the coal mines. Projected 

groundwater level changes primarily are due to CBNG groundwater withdrawal 

in the Upper Fort Union Formation and to both CBNG pumping and discharge 

along with coal mine pit dewatering in the Wasatch Formation. Groundwater 

level recovery in the eastern PRB after the cessation of both CBNG development 

and coal mining, and the effect on groundwater flow paths associated with coal 

mine pit backfill and reclamation after the cessation of coal mining in the 

eastern PRB also were modeled and the results are included in the Task 3B 

report. For purposes of modeling groundwater recovery, it was assumed that 

CBNG development in the eastern PRB would cease by 2030 and surface coal 

mining would cease by 2050 (BLM 2009e). 

The Task 3B report describes the modeled cumulative groundwater impacts 

associated with ongoing CBNG-related groundwater withdrawal in the eastern 

PRB for the time periods of 2010, 2015, and 2020, and the base years used for 

comparison of groundwater impacts were 2002 (the year used for calibration of 

the groundwater model) and 1990 (a time period prior to CBNG pumpage and 

before major expansion by the eastern PRB coal mines). 

The primary objective of the Task 3B report is to provide an estimate of 

potential future cumulative impacts to water resources in the eastern PRB of 

Wyoming due to CBNG development and coal mining for the target years 2010, 

2015, and 2020. To accomplish that objective, the Task 3B report evaluated 

the potential groundwater impacts due only to CBNG development by 

estimating groundwater pumpage rates through analysis of past patterns in 

CBNG development and groundwater pumpage in the eastern PRB. The 

locations of surface discharge of groundwater (outfalls) were represented in the 

CMGM as recharge cells to allow for infiltration of discharge water into the 

Wasatch Formation (BLM 2009e). 

Projected groundwater level changes in the Wasatch generally are due to coal 

mine dewatering and CBNG pumping and discharge, which generally result in 

local mounding of groundwater in the Wasatch near CBNG fields and 

drawdown near the coal mines (BLM 2009e). For the Upper Fort Union, 

groundwater level changes are due to CBNG pumpage and coal mine 

dewatering. Between 2002 and 2020, the expected reduction in coal mine 

dewatering and CBNG pumpage from Wright northward toward Gillette are 

projected to result in a rebound of groundwater levels both within the coal 
4.0 Cumulative Environmental Consequences 

4-66 Final EIS, Wright Area Coal Lease Applications 

mine boundaries and especially within the basin west of the coal mines (BLM 

2009e). 

Based on the results of the CMGM, the effect of CBNG pumpage on the Upper 

Fort Union from 1990 to 2010 in Subregion 3 results in an extensive area of 

drawdown centered just southwest of Wright, covering nearly 15 townships and 

drawdowns range from 25 feet on the southern margin to 575 feet in the center 

of the depression (Figure 4-8). The modeled drawdown in the Upper Fort Union 

due to CBNG pumpage from 1990 to 2020 in Subregion 3 is projected to 

primarily be located southwest of Wright, producing a groundwater depression 

of between 25 to 425 feet that covers roughly eight to nine townships (Figure 4-

9) (BLM 2009e). 

There is a potential for conflicts to occur over who (coal mining or CBNG 

operators) is responsible for replacing or repairing private wells that are 

adversely affected by the drawdowns; however, the number of potentially 

affected wells completed in the coal is not large. As discussed previously, coal 

companies are required by state and federal law to mitigate any water rights 

that are interrupted, discontinued, or diminished by coal mining. In response 

to concerns about the potential impacts of CBNG development on water rights, 

a group of CBNG operators and local landowners developed a standard water 

well monitoring and mitigation agreement that can be used on a case-by-case 

basis as development proceeds. All CBNG operators on federal oil and gas 

leases are required to offer this water well agreement to the surface landowners 

(BLM 2003). 

The effect of replacing the coal and overburden with backfill is the third major 

groundwater issue of concern. The following discussion of recharge, 

movement, and discharge of water in the backfill aquifer is excerpted from the 

USGS CHIA (Martin et al. 1988): 

Postmining recharge, movement, and discharge of groundwater in the 

Wasatch aquifer and Wyodak coal aquifer will probably not be 

substantially different from premining conditions. Recharge rates and 

mechanisms will not change substantially. Hydraulic conductivity of 

the spoil aquifer will be approximately the same as in the Wyodak coal 

aquifer allowing groundwater to move from recharge areas where clinker 

is present east of mine areas through the spoil aquifer to the 

undisturbed Wasatch aquifer and Wyodak coal aquifer to the west. 

Monitoring data verify that recharge has occurred and is continuing in the 

backfill (Hydro-Engineering 1991, 1996, 2001, and 2007). The water 

monitoring summary reports prepared each year by GAGMO list current water 

levels in the monitoring wells completed in the backfill and compare them with 

the 1980 water levels, as estimated from the 1980 coal water-level contour 

maps. In the 1991 GAGMO 10-year report, some recharge had occurred in 88 

percent of the 51 backfill wells reported at that time (Hydro-Engineering 1991). 

In the GAGMO 20-year report, 79 percent of the 82 backfill wells measured
Converse County

Campbell County

WRIGHT

Dry Fork Cheyenne River

Antelope Creek

Porcupine

Creek

Little

Thunder Creek

Black Thunder Creek

BaconCreek

Belle

Fourche

River

Horse

PumpkinCreek

North Fork

Bear

Creek

25'

25'

25'

100'

100'

100'

100'

200'

200'

200'

200'

300'

300'

300'

500'

575'

Antelope

Creek

59

59

387

T.

46

N.

 R. 75 W.

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

T.

40

N.

T.

39

N.

 R. 74 W. R. 73 W. R. 72 W. R. 71 W. R. 70 W. R. 69 W.

 R. 75 W. R. 74 W. R. 73 W. R. 72 W. R. 71 W. R. 70 W. R. 69 W.

T.

46

N.

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

T.

40

N.

T.

39

N.

 R. 76 W.

 R. 76 W.

Approximate Coal Mined-out Area

through 2006

Coal Mine Groundwater Model

(CMGM) Domain

0 20000 40000 80000

GRAPHIC SCALE (FEET)

LEGEND

Approximate Wyodak Coal Outcrop

Extent of CMGM Cumulative

Drawdown, in feet

Note: Includes effects of CBNG

groundwater pumping only. Source: BLM 2009e

Upper Fort Union Outcrop Area

Wasatch Outcrop Area

25'

Figure 4-8. Coal Mine Groundwater Model, Upper Fort Union Formation, 1990-2010 Coal Bed Natural

Gas-related Groundwater Level Drawdown.

4.0 Cumulative Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 4-67
Converse County

Campbell County

WRIGHT

Dry Fork Cheyenne River

Antelope Creek

Porcupine

Creek

Little

Thunder Creek

Black Thunder Creek

BaconCreek

Belle

Fourche

River

Horse

PumpkinCreek

North Fork

Bear

Creek

425'

25'

25'

25'

25'

100'

100'

100'

200'

200'

300'

300'

Antelope

Creek

59

59

387

T.

46

N.

 R. 75 W.

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

T.

40

N.

T.

39

N.

 R. 74 W. R. 73 W. R. 72 W. R. 71 W. R. 70 W. R. 69 W.

 R. 75 W. R. 74 W. R. 73 W. R. 72 W. R. 71 W. R. 70 W. R. 69 W.

T.

46

N.

T.

45

N.

T.

44

N.

T.

43

N.

T.

42

N.

T.

41

N.

T.

40

N.

T.

39

N.

 R. 76 W.

 R. 76 W.

Approximate Coal Mined-out Area

through 2006

Coal Mine Groundwater Model

(CMGM) Domain

0 20000 40000 80000

GRAPHIC SCALE (FEET)

LEGEND

Approximate Wyodak Coal Outcrop

Extent of CMGM Cumulative

Drawdown, in feet

Note: Includes effects of CBNG

groundwater pumping only. Source: BLM 2009e

Upper Fort Union Outcrop Area

Wasatch Outcrop Area

25'

Figure 4-9. Coal Mine Groundwater Model, Upper Fort Union Formation, 1990-2020 Coal Bed Natural

Gas-related Groundwater Level Drawdown.

4.0 Cumulative Environmental Consequences

4-68 Final EIS, Wright Area Coal Lease Applications
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-69 

contained water (Hydro-Engineering 2001). In the GAGMO 25-year report, 8.6 

percent of the 101 backfill wells measured contained water (Hydro-Engineering 

2007). 

The outcrop areas of the Fort Union coal seams are zones of burned coal 

referred to as clinker (or scoria). These are zones of high secondary 

permeability and are the main recharge zones for the Fort Union Formation 

(BLM 2009d). Clinker occurs all along the coal outcrop at the eastern edge of 

the PRB study area, and is a major groundwater recharge source for the 

backfill just as it is for the coal aquifer. Some clinker is mined for roadsurfacing material, but saturated clinker is not generally mined since 

abundant clinker exists above the water table and does not present the mining 

problems that would result from mining saturated clinker. Therefore, the 

major recharge source for the backfill aquifer is not being disturbed by current 

mining. Clinker occurs in localized areas on only the North Hilight Field and 

North Porcupine LBA Tracts configured under Alternative 2, BLM’s preferred 

alternative. 

The cumulative size of the backfill area in the PRB and the duration of mining 

activity would be increased by mining the currently pending LBA tracts, 

including the six WAC LBA tracts. Because the mined-out areas are being 

backfilled and the monitoring data demonstrate that recharge of the backfill is 

occurring, substantial additional cumulative impacts are not anticipated as a 

result of the pending leasing actions. 

The PRB Coal Review Task 3B Report (BLM 2009e) summarizes the modeled 

recovery of groundwater levels once the CBNG development and coal mining 

operations have ceased. For CBNG development, it was assumed that 

groundwater pumping in the eastern PRB would end in 2030. For coal mining, 

it was assumed that open-pit dewatering in advance of mining, as well as mine 

reclamation, would end in 2050. Groundwater recovery related to the 

cessation of coal mining started in year 2050, with groundwater discharge 

rates remaining constant at the projected 2020 rate from year 2020 to 2050. 

The Upper Fort Union shows recovery after 50 to 100 years (2100 to 2150) and 

substantial recovery after 200 years (year 2250). Both the Wasatch and Upper 

Fort Union are projected to rebound and reach approximately 80 percent of 

steady-state after 300 to 500 years, or between years 2350 and 2550. When 

the Fort Union and Wasatch formations of the eastern PRB recover to near 

steady-state conditions, based on the resaturation modeling, groundwater will 

flow through the coal mine backfill aquifers and westward into the PRB (BLM 

2009e). 

The fourth issue of concern with respect to cumulative groundwater impacts is 

the effect of mining on water quality. Specifically, what effect does mining have 

on the water quality in the surrounding area, and what are the potential water 

quality problems in the backfill aquifer following mining? 
4.0 Cumulative Environmental Consequences 

4-70 Final EIS, Wright Area Coal Lease Applications 

In the Wyoming PRB, the backfill material gradually resaturates with water as 

groundwater from the Wasatch Aquifer and the Fort Union coal bed aquifers 

enters the backfill material. In a regional study of the cumulative impacts of 

coal mining, the median concentrations of dissolved solids and sulfates were 

found to be higher in water from backfill aquifers than in water from either the 

Wasatch Formation overburden or the Wyodak coal aquifer (Martin et al. 1988). 

This is expected because blasting and movement of the overburden materials 

exposes more surface area to water, increasing dissolution of soluble materials, 

particularly from the overburden materials that were situated above the 

saturated zone in the premining environment. 

One pore volume of water is the volume of water that would be required to 

saturate the backfill following reclamation. The time required for one pore 

volume of water to pass through the backfill aquifer is greater than the time 

required for the postmining groundwater system to reestablish equilibrium. 

According to the USGS CHIA, estimates of the time required to reestablish 

equilibrium range from tens to hundreds of years (Martin et al. 1988). 

The major current use of water from the aquifers being replaced by the backfill 

(the Wasatch Formation overburden and Fort Union coal aquifers) is for 

livestock because these aquifers are typically too high in dissolved solids for 

domestic use and well yields are typically too low for irrigation (Martin et al. 

1988). Chemical analyses of 336 samples collected between 1981 and 1986 

from 45 wells completed in backfill aquifers at 10 mines indicated that the 

quality of water in the backfill will, in general, meet the state standard for 

livestock use of 5,000 milligrams per liter (mg/L) for total dissolved solids (TDS) 

when recharge occurs (Martin et al. 1988). 

Water quality samples from coal mine backfill monitor wells in along the 

eastern PRB typically have a pH between 6.0 and 7.8, TDS in the range of 

1,000 to 4,000 mg/L, bicarbonate values ranging from 500 to 1,300 mg/L, 

sodium in the range of 200 to 800 mg/L, high sulfate values ranging from 

1,000 to 3,500 mg/L, and SAR values in the range of 2.0 to 7.0 (HydroEngineering 2001). The 2000 Annual GAGMO report (Hydro-Engineering 2001) 

evaluated samples from 48 backfill wells in 1999 and found that the TDS in 75 

percent were less than 5,000 mg/L, TDS in 23 percent were between 5,000 and 

10,000 mg/L, and TDS in one well was above 10,000 mg/L. An analysis of 

about 2,000 samples collected from 95 backfill monitoring wells between 1986 

and 2002 found that the water quality in 75 percent of the wells were within 

the acceptable range for the Wyoming livestock standard, with 25 percent 

exceeding that standard (Ogle 2004). 

WDEQ/LQD calculated a median TDS concentration of 3,293 mg/L for the 

backfill aquifer in the east-central area of the PRB, which includes the four 

mines located immediately south of Gillette, based on 1,384 samples (Ogle et 

al. 2005). These results suggest that the TDS in the backfill aquifer in the 

middle group of mines meets the requirements for livestock use and is similar 

to TDS found in the undisturbed Wasatch Formation overburden but typically 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-71 

larger than TDS found in the Wyodak coal aquifer. The 2005 Annual GAGMO 

report (Hydro-Engineering 2006) indicates that TDS concentrations in 2005 

ranged from 656 mg/L at well RW2804 (at the Belle Ayr Mine) to 12,409 mg/L 

at well SP-4-NA (at the North Antelope Rochelle Mine). The GAGMO 25-Year 

Report (Hydro-Engineering 2007) reported samples collected from 57 backfill 

monitoring wells, and of the last samples that were collected from those wells 

in 2005, the TDS concentrations ranged from a low of 656 mg/L to and high of 

12,409 mg/L, with an average of 3,800 mg/L and a median of 3,670 mg/L. 

WDEQ/LQD calculated a median TDS concentration of 3,670 mg/L based on 

869 samples collected from monitoring wells with at least 15 years of data that 

are completed in the backfill at the three applicant mines included in this 

analysis, and concluded that the recovered concentrations will be suitable for 

post-mining land use (Ogle and Calle 2006). The incremental effect on 

groundwater quality due to leasing and mining the six WAC LBA tracts would 

be to increase the total volume of backfill and, thus, the time for equilibrium to 

reestablish. 

The PRB Coal Review Task 3B Report (BLM 2009e) predicts that resaturation of 

coal mine pit backfill to form backfill aquifers may take approximately 100 

years after cessation of mining and is projected to result in the westward 

migration of groundwater with elevated TDS levels. Modeling of this westward 

migration indicates that TDS levels should be down to the average background 

value of 1,000 mg/L within 2,000 feet of the final westward extent of the coal 

mine boundaries. Thus, no impact to groundwater quality in either the 

Wasatch or Upper Fort Union aquifers is expected beyond approximately 2,000 

feet west of the final coal mine boundaries (BLM 2009e). 

Potential water-level decline in the subcoal Fort Union Formation is the fifth 

major groundwater issue. Water level declines in the Tullock Aquifer have been 

documented in the Gillette area. According to Crist (1991), these declines are 

most likely attributable to pumpage for municipal use by Gillette and for use at 

subdivisions and trailer parks in and near the city of Gillette. Most of the 

water-level declines in the subcoal Fort Union wells occur within one mile of 

the pumped wells (Crist 1991, Martin et al. 1988). Most of the mines have 

water supply wells completed in zones below the lowest coal seam mined (e.g., 

subcoal Fort Union Formation and the underlying Lance-Fox Hills aquifer), but 

the mine facilities in the PRB are separated by a distance of one mile or more, 

so little interference between mine supply wells would be expected (refer to 

Section 3.5.1.2). 

In response to concerns voiced by regulatory personnel, several mines have 

conducted impact studies of the subcoal Fort Union Formation. The OSM also 

commissioned a cumulative impact study of the subcoal Fort Union Formation 

to address the effects of mine facility wells on this aquifer (OSM 1984). 

Conclusions from these studies are similar and may be summarized as follows: 
4.0 Cumulative Environmental Consequences 

4-72 Final EIS, Wright Area Coal Lease Applications 

• Because of the discontinuous nature of the sands in this formation and 

because most large-yield wells are completed in several different sands, it 

is difficult to correlate completion intervals between wells. 

• In the Gillette area, water levels in this aquifer have probably declined 

because the city of Gillette and several subdivisions have utilized water 

from the formation (Crist 1991). (Note: Gillette is mixing Fort Union 

Formation water with water from wells completed in the Madison 

Formation. Also, because drawdown has occurred, some operators are 

able to dispose of CBNG water by injecting it into the subcoal Fort Union 

Formation near the city of Gillette.) 

• Because large saturated thicknesses are available (locally) in this aquifer 

unit, generally 500 feet or more, a drawdown of 100 to 200 feet in the 

vicinity of a pumped well would not dewater the aquifer. 

Most of the existing coal mines in the PRB have permits from the Wyoming 

SEO for subcoal Fort Union Formation water supply wells. Four industrial 

water supply wells are completed in the Fort Union Formation and one 

industrial supply well is completed in the underlying Lance-Fox Hills aquifer 

within Black Thunder Mine’s existing permit area. The Jacobs Ranch Mine 

uses five wells completed in the subcoal Fort Union Formation for industrial 

water supply. The North Antelope Rochelle Mine uses four wells completed in 

the subcoal Fort Union Formation and one well completed in the Lance-Fox 

Hills aquifer for industrial water supply. Locations of the three applicant 

mines’ water supply wells are shown on Figures 3-20, 3-21, and 3-22, 

respectively. Extending the life of the three WAC mines by issuing new leases 

would result in additional water being withdrawn from the subcoal Fort Union 

Formation and Lance-Fox Hills aquifer systems, but no new subcoal water 

supply wells would be required. The additional water withdrawal would not be 

expected to extend the area of water level drawdown over a substantially larger 

area due to the discontinuous nature of the sands in the Tullock Member and 

the fact that drawdown and yield reach equilibrium in a well due to recharge 

effects. Due to the distances separating subcoal Fort Union Formation and 

Lance-Fox Hills aquifer wells used for mine water supply, these wells have not 

experienced interference and are not likely to in the future. 

Water requirements and sources for proposed power plants are not currently 

known, however, there are no proposed power plants in the immediate vicinity 

of the three WAC mines. The Wyoming SEO is discouraging further 

development of the lower Fort Union Formation aquifers, so the most likely 

groundwater source for future power plants is the Lance-Fox Hills aquifer 

system. This would reduce the chances that the power plants would add to 

cumulative hydrologic impacts of mining and CBNG production. 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-73 

4.2.4.2 Surface Water

The Powder River structural basin of Wyoming, often referred to as the PRB, 

encompasses five major drainages. The drainages in the northern portion of 

the basin include the Powder River, Tongue River, and Little Powder River. In 

the central and southern parts of the basin, the major drainages are the Belle 

Fourche and Cheyenne rivers. Surface water flows to the north into Montana 

in the northern part of the basin and to the east-northeast into South Dakota 

in the southern and central parts of the basin. The discussion of water 

resources in the PRB focuses on two main issues: 1) current water use in the 

basin, and 2) industrial use of water resources by the coal mines and CBNG 

industries. The discussion of water use in Wyoming PRB study area is divided 

into two major water planning areas: the Powder/Tongue River Basin and the 

Northeast Wyoming River Basins (BLM 2009d). 

The main rivers in the Powder/Tongue River Basin are the Tongue River and 

the Powder River. The Powder/Tongue River Basin receives substantial surface 

water runoff from the Big Horn Mountains, leading to major agricultural 

development along drainages in the Tongue River and Powder River basins. 

Reservoirs are used throughout the basin for agricultural water supply and for 

municipal water supply in the Powder/Tongue River Basin. Water use in the 

Powder/Tongue River Basin as of 2002 is summarized in Table 4-16. 

Table 4-16. Water Use as of 2002 in the Powder/Tongue River Basins (acrefeet per year). 

Dry Year Normal Year Wet Year 

Water Use 

Categories 

Surface 

Water 

Groundwater Surface 

Water 

Groundwater Surface 

Water 

Groundwater 

Agricultural 178,000 200 184,000 200 194,000 300 

Municipal 2,700 500 2,700 500 2,700 500 

Domestic --- 4,400 --- 4,400 --- 4,400 

Industrial1 --- 68,000 --- 68,000 --- 68,000 

Recreation Non-consumptive 

Environmental Non-consumptive 

Evaporation 11,300 -- 11,300 -- 11,300 -- 

Total 192,000 73,100 198,000 73,100 208,000 73,200 

1 Includes conventional oil and gas production water and CBNG production water. Source: HKM Engineering et al. 2002a

The Little Bighorn River, Tongue River, Powder River, Crazy Woman Creek, and 

Piney Creek carry the largest natural flows in the Powder/Tongue River Basin. 

Many of the other major drainages are affected by irrigation practices to the 

extent that their flows are not natural (HKM Engineering et al. 2002a). Water 

availability in the major sub-basins of the Powder/Tongue River Basin is 

summarized in Table 4-17. This table presents the amount of surface water in 

acre-feet that is physically available above and beyond allocated surface water 

in these drainages. As a result of the Yellowstone River Compact, Wyoming
4.0 Cumulative Environmental Consequences 

4-74 Final EIS, Wright Area Coal Lease Applications 

Table 4-17. Surface Water Availability in the Powder/Tongue River Basins. 

Surface Water Availability 

(acre-feet per year) 

Sub-basin Wet Years Normal Years Dry Years 

Little Bighorn River 152,000 113,000 81,000 

Tongue River 473,000 326,000 218,000 

Clear Creek 213,000 124,000 80,000 

Crazy Woman Creek 69,000 32,000 16,000 

Powder River 547,000 324,000 16,000 

Little Powder River 48,000 12,000 3,000 

Total 1,502,000 931,000 414,000 

Source: HKM Engineering et al. 2002a 

must share some of the physically available surface water in the 

Powder/Tongue River Basin with Montana. 

The main rivers in the Northeast Wyoming River Basins are the Belle Fourche 

in Campbell and Crook counties and the Cheyenne River in Converse, Weston, 

and Niobrara counties. Water in these rivers and their tributaries comes from 

groundwater baseline flow and from precipitation, especially from heavy storms 

during the summer months. Most surface flow in Northeast Wyoming River 

Basins is intermittent to ephemeral and streamflows are typically dominated by 

irrigation practices to the extent that their flows are unnatural (HKM 

Engineering et al. 2002a). Water use in the Northeast Wyoming River Basins 

as of 2002 is summarized in Table 4-18. 

Table 4-18. Water Use as of 2002 in the Northeast Wyoming River Basins 

(acre-feet per year). 

Dry Year Normal Year Wet Year 

Water Use 

Categories 

Surface 

Water 

Groundwater Surface 

Water 

Groundwater Surface 

Water 

Groundwater 

Agricultural 65,000 11,000 69,000 17,000 71,000 17,000 

Municipal --- 9,100 --- 9,100 --- 9,100 

Domestic --- 3,600 --- 3,600 --- 3,600 

Industrial1 --- 46,000 --- 46,000 --- 46,000 

Industrial (Other) 2 --- 4,700 --- 4,700 --- 4,700 

Recreation Non-consumptive 

Environmental Non-consumptive 

Evaporation 

(Key Reservoirs) 14,000 --- 14,000 --- 14,000 --- 

Evaporation 

(Stock Ponds) 6,300 --- 6,300 --- 6,300 --- 

Total 85,300 74,400 89,300 80,400 91,300 80,400 

1 Includes conventional oil and gas production water and CBNG production water. 

2 Includes electricity generation, coal mining, and oil refining.

Source: HKM Engineering et al. 2002b

Stream flow in the major drainages of the Northeast Wyoming River Basins is 

much less than in the Powder/Tongue River Basin, due to the absence of a 

major mountain range to provide snow melt runoff. Water availability in the 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-75 

major sub-basins of the Northeast Wyoming Rivers Basin is summarized in 

Table 4-19. 

Table 4-19. Surface Water Availability in the Northeast Wyoming River 

Basins. 

Surface Water Availability 

(acre-feet per year) 

Sub-basin Wet Years Normal Years Dry Years 

Redwater Creek 34,000 26,000 17,000 

Beaver Creek 30,000 20,000 14,000 

Cheyenne River 103,000 31,000 5,000 

Belle Fourche River 151,000 71,000 13,000 

Total 318,000 148,000 49,000 

Source: HKM Engineering et al. 2002b 

The PRB Coal Review Task 3B Report (BLM 2009e) summarizes the modeled 

changes in surface water quality as a result of CBNG, conventional oil and gas, 

and surface coal mining development projected for 2010, 2015, and 2020 in 

the eastern PRB within approximately 25 miles of the coal mines. The base 

year used for comparison of surface water quality impacts was 2003. A stream 

channel stability analysis was also conducted to evaluate the potential effects 

to stream channels due to projected CBNG production water discharge. The 

surface water resources in the cumulative study area consist primarily of 

intermittent and ephemeral streams and scattered ponds and reservoirs. A 

major impact of the projected development activities would be direct surface 

disturbance of these surface water features. Projected cumulative surface 

water impacts primarily include the impacts of CBNG production water 

discharge to ephemeral drainages and the surface disturbance and subsequent 

reclamation of drainages that result from coal mine expansion. 

Surface water quality impacts for target years 2010, 2015, and 2020 were 

estimated using a linear model developed by ACE (2009) and the projected 

water discharge volumes presented in the PRB Coal Review Task 2 Report (BLM 

2009b). Projected changes in surface water quality are due to mixing of 

predicted CBNG production water discharge with natural flow in the modeled 

drainages. For CBNG discharge, the direct discharge to ephemeral drainages 

for each drainage basin was used as a guide for modeling water quality or 

estimating impacts to channel stability and channel properties. For the coal 

mines, most of the water produced was expected to be consumed, according to 

estimates provided by the mine operators and included in the Task 2 report. 

Where production exceeded estimated consumption for the coal mines in any 

given drainage basin, it was assumed that the discharged water would go first 

to holding ponds and then to nearby ephemeral drainages in accordance with 

Wyoming Pollution Discharge Elimination System (WYPDES) permits, thereby 

minimizing the potential for degradation of water quality and impacts to 

channel stability. 

Table 4-10 summarizes the cumulative baseline (2003), actual (2007), and 

projected (in 2010, 2015, and 2020) acres of surface disturbance and 
4.0 Cumulative Environmental Consequences 

4-76 Final EIS, Wright Area Coal Lease Applications 

reclamation. The projected activities would result in surface disturbance in 

each of the six subwatersheds in the cumulative study area (Figure 4-4). 

Discrete locations for development disturbance and reclamation areas cannot 

be determined based on existing information. However, the projected 

disturbance would primarily involve the construction of additional linear 

facilities, product gathering lines, and road systems associated with 

conventional oil and gas and CBNG activities, plus additional disturbance 

associated with extending coal mining operations onto lands adjacent to the 

existing mines. 

Surface disturbing activities can result in sediment input to water bodies, 

which affects water quality parameters such as turbidity and bottom substrate 

composition. Contaminants also can be introduced into water bodies through 

chemical characteristics of the sediment. Studies have shown that TDS levels 

in streams near reclaimed coal mine areas have increased from 1 to 7 percent 

(Martin et al. 1988). Typically, sedimentation effects are short-term in duration 

and localized in terms of the affected area. Suspended sediment 

concentrations would stabilize and return to typical background 

concentrations after construction or development activities have been 

completed. It is anticipated that sediment input associated with development 

disturbance areas would be minimized by implementation of appropriate 

erosion control measures, as would be determined during future permitting. 

Future coal mining could remove intermittent or ephemeral streams and stock 

ponds in the Little Powder River, Upper Belle Fourche River, Upper Cheyenne 

River, and Antelope Creek subwatersheds. As discussed in Section 3.5.2, the 

WAC mines are in the Cheyenne River subwatershed. Coal mine permits 

provide for removal of first- through fourth-order drainages. During 

reclamation, third- and fourth-order drainages must be restored; first- and 

second-order drainages often are not replaced (Martin et al. 1988). 

Coal mining-related surface water would be discharged into intermittent and 

ephemeral streams in four subwatersheds (Antelope Creek, Little Powder River, 

Upper Belle Fourche River, and Upper Cheyenne River). Based on current 

trends, it is assumed that most, if not all, of the coal mine-produced water 

would be consumed during operation. As discussed in Section 3.5.2.2, 

changes in surface runoff would occur as a result of the destruction and 

reconstruction of drainage channels as mining progresses. Sediment control 

structures would be used to manage discharges of surface water from the mine 

permit areas. State and federal regulations require treatment of surface runoff 

from mined lands to meet effluent standards. 

Of particular importance is the amount of production water that is directly 

conveyed to the receiving drainages. Based on information and data presented 

in the PRB Coal Review Task 1B and Task 2 reports (BLM 2009d and 2009b, 

respectively), it is assumed that the production water discharged directly to the 

receiving drainages would be limited to CBNG water discharge. The PRB Coal 

Review assumes that future permitting would allow a portion of CBNG-
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-77 

produced water to be discharged to intermittent and ephemeral drainages as is 

currently allowed in the six subwatersheds in the cumulative study area 

(Antelope Creek, Dry Fork Cheyenne River, Upper Cheyenne River, Upper Belle 

Fourche River, Upper Powder River, and Little Powder River) (Figure 4-4). 

The PRB Coal Review Task 3B Report utilizes the surface water model 

described in the Surface Water Quality Analysis Technical Report (Greystone 

and ALL Consulting 2003), which was prepared in support of the PRB Oil and 

Gas Project EIS (BLM 2003), to evaluate the cumulative impacts to surface 

water quality from surface discharge of CBNG development. The linear model 

used by ACE (2009) to predicted future cumulative surface water quality 

impacts combined stream flows and stream water quality with the predicted 

CBNG discharge water quantity and quality for each subwatershed for 2010, 

2015, and 2020, and the base year for comparison for surface water quality 

impacts was 2003. 

Based on past monitoring in receiving streams, most (70 to 90 percent) CBNG 

discharge water either infiltrates or evaporates within a few miles of the 

discharge points and generally is not recorded at USGS stream gaging stations. 

Impacts to surface water flow and quality are therefore generally limited to 

within a few miles of the discharge point. In view of this, the PRB Coal Review 

Task 3B water quality impact analysis assumes a conveyance loss of 70 

percent for the water quality assessment and modeling analysis. 

Key water quality parameters for predicting the potential effects of CBNG 

development in the surface water quality impact analysis focused on the 

suitability of surface water for agricultural irrigation. Consequently, the 

sodium adsorption ratio (SAR) and salinity, measured by electrical conductivity 

(EC), were utilized for the prediction. SAR is a measure of the amount of 

sodium in the water that can react with clays and, thus, reduce infiltration into 

soils and the ultimate use of the soil for growing crops. EC is a measure of the 

total dissolved solids. The most restrictive proposed limit (MRPL) and least 

restrictive proposed limit (LRPL) regulatory standards for EC and SAR are set 

for each subwatershed by the WDEQ in conjunction with neighboring states 

that receive flow across state boundaries from the specified stream in the 

watershed. These limits refer to the desired concentrations for SAR and EC 

and are used as guidelines for evaluating potential impacts to water quality. 

The limits presented in Table 4-20 were used during the comparison of EC and 

SAR values for resulting mixtures of existing streamflows and discharges from 

CBNG wells under various flow conditions and reasonably foreseeable 

development (RFD) projections for 2010, 2015, and 2020. 

The cumulative impacts to surface water quality focused on RFD scenarios for 

normal and dry year conditions to show the difference based on streamflow and 

climate. Wet years were not analyzed because increased runoff and stream 

flow would result in potential water quality impacts considerably less than 

normal and dry year RFD scenarios. The impact analysis, conducted using 

monthly flows, comparatively evaluated the water quality parameters (SAR and 
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4-78 Final EIS, Wright Area Coal Lease Applications 

Table 4-20. Summary of Proposed Limits for SAR and EC. 

Most Restrictive Proposed Limit 

(MRPL) 

Least Restrictive Proposed Limit 

(LRPL) 

Subwatershed SAR EC (μS/cm1) SAR EC (μS/cm1) 

Little Powder 5 2,000 9.75 2,500 

Upper Powder 2 2,000 9.75 2,500 

Belle Fourche 6 2,000 10 2,500 

Cheyenne River & 

Antelope Creek 10 2,000 10 2,500 

1 μS/cm = microsiemens per centimeter 

Source: Wyoming DEQ, Montana DEQ, and South Dakota Legislative Council 

EC) of the receiving drainage before and after mixing with discharge water 

generated by the CBNG wells within that drainage. In general, the water 

discharged from the CBNG wells reflected increased levels of SAR and reduced 

levels of EC compared to the water quality of the receiving drainages. Impacts 

to water quality are likely to be maximized during the low flow months; 

consequently, the comparative evaluation of water quality focused on the 

minimum monthly flow associated with the dry year and normal year 

conditions. 

The water quality impact analysis made several observations regarding the 

overall effects of mixing CBNG well production water with surface water in the 

cumulative study area. These general observations are summarized below. 

Normal Year Conditions

Antelope Creek: Before mixing, the SAR values are relatively low and do not 

exceed the MRPL. The EC values exceed the MRPL during the low-flow 

months, but are typically less than the LRPL all year. After mixing, from 2003 

to 2020, EC is projected to decline, and SAR values are projected to increase. 

The data indicate that the MRPL and LRPL would not be exceeded for either EC 

or SAR after mixing or CBNG production waters. Based on the data, surface 

water is projected to be suitable for irrigation use in all months. 

Dry Fork of the Cheyenne River: Before mixing, the SAR values are relatively 

low and do not exceed the MRPL. The EC values exceed the MRPL during the 

low-flow months, but are typically less than the LRPL all year. There is no 

projected discharge of CBNG production water to the drainage through 2020. 

Therefore, surface water quality conditions for 2010, 2015, and 2020 would be 

the same as for the base year (2003). 

Upper Cheyenne River: Before mixing, the SAR levels do not exceed the MRPL 

and the EC levels exceed the MRPL for 11 months of the year and the LRPL for 

9 months of the year. After mixing, from 2003 to 2010, EC is projected to 

decrease, and SAR values would not change. There is no projected discharge of 

CBNG production water to the drainage in 2015 and 2020. Based on the data, 

EC values would exceed the MRPL, except for August 2010, and exceed the 

LRPL, except for July through September 2010. SAR values would not exceed 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-79 

the MRPL and LRPL. Based on the data, surface water would remain suitable 

for irrigation from 2010 to 2020. 

Upper Belle Fourche: Before mixing, the SAR levels exceed the MRPL from 

November through January while meeting the LRPL throughout the year. The 

EC levels exceed the MRPL from September through January and exceed the 

LRPL from November through January. After mixing, from 2003 to 2015, EC is 

projected to decline and SAR is projected to increase slightly. There is no 

projected discharge of CBNG production water to the drainage in 2020; 

therefore, EC and SAR values for this time period would be the same as 

projected for the base year (2003). The data indicate that EC would not exceed 

the MRPL, except for October in 2010 and October through January in 2015, 

and would not exceed the LRPL. The projected SAR values would exceed the 

MRPL from August to January in 2010 and from September to January of 

2015, and would not exceed the LRPL for all months. Based on the data, 

surface water is projected to be suitable for irrigation to 2020. 

Upper Powder River: Before mixing, surface water in the Upper Powder River 

exceeds the MRPL for both EC and SAR throughout the majority of the year. 

Levels of SAR are less than the LRPL while EC values generally exceed the 

LRPL from July through December. After mixing, from 2003 to 2015, EC is 

projected to decrease slightly, and SAR values would increase slightly. There is 

no projected discharge of CBNG production water to the drainage in 2020; 

therefore, EC and SAR values for this time period would be the same as 

projected for the base year (2003). The data indicate that EC values would 

exceed the MRPL, except for May and June for 2010 and 2015, and would 

exceed the LRPL during July through December from 2010 to 2015. SAR 

values would exceed the MRPL, except for March in 2010 and 2015 and May in 

2015, and would not exceed the LRPL. Based on the data, surface water is 

projected to remain suitable for irrigation from 2010 to 2010. 

Little Powder River: Before mixing, the surface water in the Little Powder River 

exceeds the MRPL for EC and SAR throughout the majority of the year. SAR 

levels remain below the LRPL throughout the year, but EC levels exceed the 

LRPL during the low flow months. After mixing, from 2003 to 2020, EC is 

projected to increase slightly. The data indicate that EC values would exceed 

the MRPL except for March and May during 2010, and March during 2015 and 

2020; however, it would not exceed the LRPL except for January and August 

from 2010 to 2020, and also in September, November, and December from 

2015 to 2020. SAR values are projected to exceed the MRPL and not exceed 

the LRPL. Based on the data, surface water is projected to remain suitable for 

irrigation to 2020. 

Dry Year Conditions

Antelope Creek: After mixing, from 2003 to 2020, EC values would be reduced 

due to mixing with CBNG waters and SAR values would increase. The data 

indicate that the MRPL and LRPL would not be exceeded fro either EC or SAR 
4.0 Cumulative Environmental Consequences 

4-80 Final EIS, Wright Area Coal Lease Applications 

for all years. Based on the data, surface water would remain suitable for 

irrigation except for June and August from 2010 to 2020. 

Dry Fork of the Cheyenne River: There is no projected discharge of CBNG 

production water to the drainage through 2020. Therefore, surface water 

quality conditions would be the same as for the base year (2003), for all years 

to 2020. 

Upper Cheyenne River: After mixing, from 2003 to 2010, EC values would 

decline, and SAR values would increase slightly. There is no projected 

discharge of CBNG production water to the drainage in 2015 and 2020. EC 

values would exceed the MRPL except for August 2010; the LRPL would be 

exceeded except for July to September 2010. For SAR, neither the MRPL nor 

the LRPL would be exceeded. Based on the data, surface water would remain 

suitable for irrigation to 2020. 

Upper Belle Fourche: After mixing, from 2003 to 2015, EC values would 

decline, and SAR values would increase slightly. There is no projected 

discharge of CBNG production water to the drainage in 2020. EC values would 

not exceed the MRPL or LRPL from 2010 to 2015. SAR values would exceed 

the MRPL in 2010, except for March and July, and also would exceed the MRPL 

from August to January 2015. Based on the data, surface water would be 

unsuitable for irrigation from August to October during 2010 and in October 

2015. 

Upper Powder River: After mixing, from 2003 to 2015, EC vales would decrease 

slightly, and SAR values would increase slightly. There is no projected 

discharge of CBNG production water to the drainage in 2020. EC values would 

exceed the MRPL except for the months of May and June 2010 and 2015, and 

the LRPL would be exceeded July through December for 2010 and 2015. SAR 

values would exceed the MRPL, except for May and June 2015, and would not 

exceed the LRPL for all years. Based on the data, surface water would remain 

suitable for irrigation to 2020. 

Little Powder River: After mixing, from 2003 to 2020, the EC would be reduced 

and the SAR would increase. The MRPL would be exceeded for all years for EC 

during the months of February, April, June, and August in 2010; during 

November through February and during April, June, and August in 2015; and 

all months except March in 2020. EC values would exceed the LRPL in 

September 2010; August 2015; and January, August November, and December 

2020. SAR values would exceed the MRPL in all months and years except 

March 2015 and March and May 2020. The LRPL for SAR would be exceeded 

in September 2010. The water would remain suitable for irrigation from 2010 

to 2020 except for September and October 2010. 

In summary, the suitability of the mixed water for irrigation purposes is related 

to EC and SAR. In general, the water most suitable for irrigation has a 

relatively low SAR and a relatively high EC. Elevated SAR values may reduce 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-81 

permeability in clayey soils, which reduces the rate of water infiltration. As 

discussed above, the water discharged from the CBNG wells is generally 

characterized by higher levels of SAR and reduced levels of EC compared to the 

water quality of the receiving drainages. In those cases where mixing results in 

a significant increase in SAR and the EC is moderately low, the water was 

considered unsuitable. For these six drainages, the projected water quality 

after mixing demonstrated adequate suitability for irrigation in most months 

during normal year conditions. The MRPL and LRPL may be exceeded for EC 

and SAR in 1 or more years and in any given year for 1 or more months, but 

not for all months in the year. During dry year conditions, the suitability of 

surface waters in the six drainages for irrigation generally would be reduced 

due to the greater percentages of CBNG water in the drainage after mixing. 

Both the EC and SAR values would exceed the MRPL and LRPL more frequently 

compared to normal year flows. Even though the waters’ suitability for 

irrigation would be reduced (except for the Belle Fourche River) surface water 

generally would remain suitable for irrigation during the majority of months of 

the irrigation season. 

4.2.5 Channel Stability

In general, cumulative impacts to channel stability largely relate to changes in 

water quantity associated with discharges from existing and projected 

development activities as compared to the natural runoff characteristics of the 

receiving drainages. For this evaluation, ACE (2009) assumed that water 

discharged directly to the receiving drainages would be limited to CBNG 

activities, which are projected to be the primary source of discharge water in 

the PRB study area through 2020. 

To the extent possible, the impact to perennial drainages was addressed 

quantitatively at the subwatershed level using regression equations related to 

discharge and channel width. Geomorphic relationships between mean annual 

discharge, channel gradient and geometry, bed load, and median sediment size 

also were used to provide a qualitative assessment of potential impacts 

associated with the discharge of CBNG production water. 

To have an impact on channel stability that is manifested in active channel 

erosion, CBNG production water discharge likely would have to represent a 

substantial portion of the channel-forming discharge in watersheds where the 

channel slope is steep enough and the width, depth, and sinuosity low enough 

to impact channel morphology. Channel-forming discharge was estimated 

using the peak annual discharge recurrence interval and the common range for 

channel-forming discharge between the 1.5- to 2.0-year recurrence interval. 

Based on the magnitude of the projected CBNG production water discharges 

compared to the channel-forming discharge (1.5- to 2.0-year recurrence 

interval), the impact more likely would be evident in small ephemeral drainages 

that are characterized by steep channel gradients, lower sinuosity, and smaller 

widths and depths. Overall, as the drainage area increases, the channel slope 
4.0 Cumulative Environmental Consequences 

4-82 Final EIS, Wright Area Coal Lease Applications 

typically decreases along with an increase in sinuosity, thereby reducing the 

impact of CBNG production water discharge on channel stability. 

The channel-forming discharge for both the Little Powder River and Belle 

Fourche River is given in Table 4-21. The perennial stream evaluation 

calculated the change in channel width for the Little Powder River as less than 

0.3 percent. For the Belle Fourche River, it was calculated to be less than 0.2 

percent (Table 4-21) (ACE 2009). Given the low increase in mean annual 

discharge from introduced CBNG water, changes in channel geomorphology 

(width, depth, gradient, bed material transport and meander wavelength) are 

considered imperceptible. These results suggest that for the larger perennial 

streams the effect of CBNG production water discharge would be minimal. 

Table 4-21. Projected Impact of CBNG Production Water Discharge on 

Perennial Streams. 

CBNG 

Discharge Estimated Width 

Potential 

Impact 

[Increased 

Channel Width]

Location 

Channel 

Forming 

Discharge1

(cfs) (cfs) (%) 

Existing 

Conditions 

(ft) 

Combined 

Discharge 

(ft) (ft) (%) 

Little Powder River 

above Dry Creek near 

Weston, Wyoming 

(USGS Gage 06324970) 

270 to 420 2.2 

0.5 

to 

0.8 

47.3 to 

56.3 

47.4 to 

56.4 

0.15 to 

0.12 0.3 

Belle Fourche River 

below Moorcroft, 

Wyoming 

(USGS Gage 06426500) 

652 to 789 3.9 

0.5 

to 

0.6 

66.9 to 

72.1 

67.0 to 

72.2 

0.16 to 

0.14 0.2 

1 Discharge associated with the 1.5- to 2-year recurrence interval. 

Discharge of CBNG well production water into ephemeral drainages may start 

or exacerbate erosion in the ephemeral stream channel. Given the potentially 

greater increase in stream flow due to a lower natural flow, channel 

geomorphology is more likely to be perceptible. Smaller drainages may be more 

likely to exhibit channel erosion depending on the magnitude of the flow 

contribution from CBNG water production compared to the channel-forming 

discharge. However, field observations in these watersheds found an increase 

in vegetation diversity and density along the channel. 

According to the BLM Task 3B Report (BLM 2009e), a special study was done of 

the Caballo Creek drainage in the Belle Ayr Mine permit area, to see how 

reclaimed drainages were impacted by increased CBNG discharges. It was 

determined that CBNG discharge represented less than 1 percent of the 2-year 

peak discharge. No active erosion was noted in the natural or diverted portions 

of the Caballo Creek channel, while an increase in vegetative diversity and 

density was noted. Based on the relative magnitude of the flow contribution 

from CBNG production water discharge to the flow in Caballo Creek, the minor 

amount of flow increase would not likely result in increased erosion to its 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-83 

channel or in streams similar to Caballo Creek. While it is more likely that 

creeks with smaller drainage areas, like Duck Nest or Bone Pile Creeks may 

experience more erosion due to relatively larger flow increases due to CBNG 

discharge, such effects were not observed in the field (BLM 2009e). 

4.2.6 Alluvial Valley Floors

The identified AVFs for all coal mines in the PRB Coal Review study area are 

described in the PRB Coal Review Task 1D Report (BLM 2005d), based on 

individual mine State Decision Documents. Regulatory determinations of AVF 

occurrence and location are completed as part of the permitting process for 

coal mining operations, because their presence can restrict mining activities 

under SMCRA and Wyoming laws. The WDEQ/LQD administers the AVF 

regulations for coal mining activities in Wyoming. Coal mine-related impacts to 

designated AVFs generally are not permitted if the AVF is determined to be 

significant to agriculture. If an AVF is determined not to be significant to 

agriculture or if the permit to affect the AVF was approved prior to the effective 

date of SMCRA, the AVF can be disturbed during mining but must be restored 

to essential hydrologic function during reclamation. 

The formal AVF designation and related regulatory programs described above 

are specific to coal mining operations; however, other development-related 

activities in the study area would potentially impact AVF resources. The 

portions of the cumulative study area that lie outside of the mine permit areas 

have generally not been surveyed for the presence of AVFs; therefore, the 

locations and extent of the AVFs outside of the mine permit areas have not 

been determined. 

4.2.7 Soils

The PRB Coal Review Task 3D Report (BLM 2009f) discusses potential 

cumulative impacts to soils as a result of projected development activities in 

the PRB Coal Review Task 3 study area. The area of actual surface coal mining 

disturbance and reclamation for the years 2003 and 2007, and the projected 

cumulative areas of disturbance and reclamation for 2010, 2015, and 2020 are 

shown in Tables 4-2 and 4-3. The area of actual disturbance and reclamation 

for all development in 2003 and 2007, and the projected cumulative total areas 

of disturbance and reclamation for 2010, 2015, and 2020 are shown in Table 

4-10. 

Development activities such as increased vehicle traffic, vegetation removal, 

soil salvage and redistribution, discharge of CBNG produced groundwater, and 

construction and maintenance of project-specific components (e.g., roads, 

ROWs, well pads, industrial sites, and associated ancillary facilities) would 

result in cumulative impacts to soils in the study area. In general, soil 

disturbance and handling from these activities would generate both long-term 

and short-term impacts to soil resources through accelerated wind or water 
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4-84 Final EIS, Wright Area Coal Lease Applications 

erosion, declining soil quality factors, compaction, and the removal and 

replacement of soil resources at mining sites. 

Of the types of development projects in the study area, coal mining activities 

would create the most concentrated cumulative impacts to soils. This is due to 

the large acreages involved and the tendency of mining operations to occur in 

contiguous blocks. These factors would encourage widespread accelerated 

wind and water erosion. Extensive soil handling would cause compaction and 

a corresponding loss of permeability to water and air; a decline in microbial 

populations, fertility, and organic matter; and potential mixing of saline and/or 

alkaline soil zones into seedbeds, which would reduce soil quality. There 

would be a limited availability of suitable soil resources for reclamation uses in 

some areas. 

However, for surface coal mining operations, there are measures that are either 

routinely required or can be specifically required as necessary to reduce 

impacts to soil resources and to identify overburden material that may be 

unsuitable for use in reestablishing vegetation, as discussed in Sections 

3.3.1.3, 3.4.2.3, and 3.8.3. 

As described in Appendix E of the PRB Coal Review Task 2 Report (BLM 

2009b), a variety of CBNG water disposal methods may be employed in the 

cumulative study area. The potential impacts to soils would depend on the 

water treatment method, if any, and the nature of the disposal method. As 

discussed in the PRB Coal Review Task 3D Report (BLM 2005e), due to 

elevated SAR levels in water produced from the Wyodak-Anderson coal zone in 

the Upper Powder River and Little Powder River subwatersheds, land 

applications of CBNG-produced water in those areas could increase soil 

alkalinity. As discussed above in Section 4.2.4.2, the SAR values are generally 

low for the Upper Belle Fourche subwatershed and tend to exceed the MRPL 

after mixing with discharged CBNG water during six months of the year while 

meeting the LRPL throughout the year. Land application of CBNG-produced 

water is not anticipated in this area. The specific approaches to CBNG water 

discharges, the resource conditions and locations in which they occur, the 

timing of discharges, and the discharge permit stipulations from regulatory and 

land management agencies would determine the extent and degree of potential 

impacts to soils. 

4.2.8 Vegetation, Wetlands and Riparian Areas

The PRB Coal Review Task 3D Report (BLM 2009f) discusses potential 

cumulative impacts to vegetation, wetlands, and riparian areas as a result of 

projected development activities in the cumulative study area. The area of 

actual surface coal mining disturbance and reclamation for the years 2003 and 

2007, and the projected cumulative areas of disturbance and reclamation for 

2010, 2015, and 2020 are shown in Tables 4-2 and 4-3. The area of actual 

disturbance and reclamation for all development in 2003 and 2007, and the 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-85 

projected cumulative total areas of disturbance and reclamation for 2010, 

2015, and 2020 are shown in Table 4-10. 

4.2.8.1 Vegetation

The PRB is characterized as a mosaic of general vegetation types, which 

include prairie grasslands, shrublands, forested areas, and riparian areas. 

These broad categories often represent several vegetation types that are similar 

in terms of dominant species and ecological importance. Fourteen vegetation 

types were identified within the PRB Coal Review Task 1 study area, of which 

10 primarily consist of native vegetation and are collectively classified as 

rangeland. These vegetation types include short-grass prairie, mixed-grass 

prairie, sagebrush shrubland, other shrubland, coniferous forest, aspen, 

forested riparian, shrubby riparian, herbaceous riparian, and wet meadow. 

The remaining vegetation types support limited or non-native vegetation and 

include cropland, urban/disturbed, barren, and open water. The vegetation 

types are described in more detail in the Task 1D Report for the PRB Coal 

Review (BLM 2005d). 

Impacts to vegetation can be classified as short-term and long-term. Potential 

short-term impacts arise from the removal and disturbance of herbaceous 

species during a project’s development and operation (e.g., coal mining, CBNG 

drilling and production, etc.), which would cease upon project completion and 

successful reclamation in a given area. Reclaimed mine land is defined by 

WDEQ/LQD as affected land that has been backfilled, graded, topsoiled, and 

permanently seeded in accordance with the approved practices specified in the 

reclamation plan (Christensen 2002). Species composition on the reclaimed 

lands may be different than on the surrounding undisturbed lands. The 

removal of woody species would be considered a long-term impact since these 

species take approximately 25 years or longer to attain a size comparable to 

woody species present within proposed disturbance areas. Potential long-term 

impacts would also include permanent loss of vegetation and vegetative 

productivity in areas that would not be reclaimed in the near term (e.g., power 

plant sites, etc.). 

4.2.8.2 Special Status Plant Species

Special status plant species are those species for which state or federal 

agencies afford an additional level of protection by law, regulation, or policy. 

Included in this category are federally listed and federally proposed species 

(species that are protected under the ESA), BLM Sensitive Species, U.S. 

Department of Agriculture-Forest Service (USFS) Sensitive Species, and 

Wyoming Game and Fish Department (WGFD) Species of Special Concern in 

Wyoming. Further discussions of species that are protected under the ESA, 

BLM Sensitive Species, and USFS Sensitive Species are included in Appendix H 

of this EIS. Two federally listed species (Ute ladies’-tresses orchid and blowout 

penstemon) and three USFS sensitive species (Barr’s milkvetch, Rosy palafox, 

and Lemonscent) are known to occur or may have potentially suitable habitat 
4.0 Cumulative Environmental Consequences 

4-86 Final EIS, Wright Area Coal Lease Applications 

in the cumulative study area. Three BLM sensitive species (Nelson’s milkvetch 

and Laramie columbine [Casper Field Office] and William’s wafer-parsnip 

[Buffalo Field Office]) may occur in the cumulative study area. 

Potential direct impacts to special status plant species in the study area could 

include the incremental loss or alteration of potential or known habitat, 

associated with past and projected activities. Direct impacts also could include 

the direct loss of individual plants within the cumulative study area, depending 

on their location in relation to development activities. Indirect impacts could 

occur due to increased dispersal and establishment of noxious weeds, which 

may result in the displacement of special status plant species in the long term. 

4.2.8.3 Noxious and Invasive Weed Species

Once established, invasive and non-native plant species can out-compete and 

eventually replace native species, thereby reducing forage productivity and the 

overall vigor and diversity of existing native plant communities. The state of 

Wyoming has currently designated the following 25 plant species as noxious 

weeds: 

• Field bindweed (Convolvulus arvensis) 

• Canada thistle (Cirsium arvense) 

• Leafy spurge (Euphorbia esula) 

• Perennial sowthistle (Sonchus arvensis) 

• Quackgrass (Agropyron repens) 

• Hoary cress (Cardaria draba) 

• Perennial pepperweed (giant whitetop) (Lepidium latifolium) 

• Ox-eye daisy (Chrysanthemum leucanthemum) 

• Skeletonleaf bursage (Franseria discolor Nutt.) 

• Russian knapweed (Centaurea repens L.) 

• Yellow toadflax (Linaria vulgaris) 

• Dalmatian toadflax (Linaria dalmatica) 

• Scotch thistle (Onopordum acanthium) 

• Musk thistle (Carduus nutans) 

• Common burdock (Arctium minus) 

• Plumeless thistle (Carduus acanthoides) 

• Dyers woad (Isatis tinctoria) 

• Houndstongue (Cynoglossum officinale) 

• Spotted knapweed (Centaurea maculosa Lam.) 

• Diffuse knapweed (Centaurea diffusa Lam.) 

• Purple loosestrife (Lythrum salicaria L.) 

• Saltcedar (Tamarix spp.) 

• Common St. Johnswort (Hypericum perforatum) 

• Common Tansy (Tanacetum vulgare) 

• Russian olive (Elaeagnus angustifolia L.) 

Campbell County does not have a declared list of weeds.
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-87 

Development-related construction and operation activities would potentially 

result in the dispersal of noxious and invasive weed species within and beyond 

the surface disturbance boundaries, which would result in the displacement of 

native species and changes in species composition in the long term. The 

potential for these impacts would be higher in relation to the development of 

linear facilities (e.g., pipeline ROWs, oil- and gas-related road systems, etc.) 

than for site facilities (e.g., mines, power plants, etc.) due to the potential for 

dispersal of noxious weeds over a larger area. 

Chapter 4, Section 2(d)(xiv) of the WDEQ/LQD rules and regulations requires 

that surface coal mines address weed control on reclaimed areas as follows: 

The operator must control and minimize the introduction of noxious weeds 

in accordance with federal and state requirements until bond release. 

Accordingly, the reclamation plans for all surface coal mines in the Wyoming 

PRB include steps to control invasion by weedy (invasive nonnative) plant 

species. As discussed in Chapter 3, Section 3.9.4, the WAC mines work with 

the Campbell County Weed and Pest Department and conduct an active 

noxious weed control program on their existing coal leases. Similar measures 

to identify and control noxious weeds are used at all of the surface coal mines 

in the Wyoming PRB as a result of the WDEQ/LQD regulatory requirements. 

Mitigation to control invasion by noxious weeds for CBNG developers is 

determined on a site-specific basis and may include spraying herbicides before 

entering areas and washing vehicles before leaving infested areas. BLM reviews 

weed educational material during preconstruction on-site meetings with CBNG 

operators, subcontractors, and landowners. BLM also attaches this 

educational information to approved Applications for Permit to Drill (APDs) or 

Plans of Development (PODs) (BLM 2003). BLM also participates in a 

collaborative effort with the South Goshen Cooperative Extension Conservation 

District, the U.S. Department of Agriculture, Natural Resources Conservation 

Service (NRCS), private surface owners, WGFD, and the Weed and Pest District 

in a prevention program that includes a long-term integrated weed 

management plan, public awareness and prevention programs, and a common 

inventory (BLM 2003). 

4.2.8.4 Wetland and Riparian Species

Operations associated with development activities in the study area would 

result in the use of groundwater. Annually, during 2010-2020, from 30,000-

42,000 mmgpy of CBNG-produced water would be discharged to 

impoundments or intermittent and ephemeral streams or reinjected. The 

discharge of produced water could result in the creation of wetlands in 

containment ponds, landscape depressions, and riparian areas along segments 

of drainages that previously supported upland vegetation. In addition, existing 

wetlands and riparian areas that would receive additional water would become 

more extensive and potentially support a greater diversity of wetland species in 
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4-88 Final EIS, Wright Area Coal Lease Applications 

the long term. Alternately, the discharge of abnormally high flows or water 

with SARs of 13 or more could impact existing vegetation as discussed in the 

Task 1D Report for the PRB Coal Review (BLM 2005d). For agricultural uses, 

the current Wyoming water quality standard for SAR is 8.0 (WDEQ/WQD 

2009). SARs of 5 to 10 have been observed in discharge waters in the study 

area (BLM 2003). Once water discharges have peaked and subsequently 

decrease in the long term, the extent of wetlands and riparian areas and 

species diversity would decrease accordingly. After the complete cessation of 

water discharges, artificially-created wetland and riparian areas once again 

would support upland species and previously existing wetland and riparian 

areas would decrease in areal extent. 

4.2.9 Wildlife and Fisheries

The PRB Coal Review Task 3D Report (BLM 2009f) discusses potential 

cumulative impacts to wildlife as a result of projected development activities in 

the cumulative study area. The area of habitat disturbance and reclamation 

for the years 2003 and 2007, and the projected cumulative areas of 

disturbance and reclamation for 2010, 2015, and 2020 are shown in Tables 4-

2 and 4-3. The area of actual habitat disturbance and reclamation for all 

development in 2003 and 2007, and the projected cumulative total habitat 

disturbance and reclamation for 2010, 2015, and 2020 are shown in Table 4-

10. 

Impacts to wildlife can be classified as short-term and long-term. Potential 

short-term impacts arise from habitat disturbance associated with a project’s 

development and operation (e.g., coal mines, CBNG wells, etc.) and would cease 

upon project completion and successful reclamation in a given area. Potential 

long-term impacts consist of long-term or permanent changes to habitats and 

the wildlife populations that depend on those habitats, irrespective of 

reclamation success, and habitat disturbance related to longer term projects 

(e.g., power plant facilities, rail lines, etc.). Direct impacts to wildlife 

populations as a result of development activities in the study area could 

include direct mortalities, habitat loss or alteration, habitat fragmentation, or 

animal displacement. Indirect impacts could include increased noise, 

additional human presence, and the potential for increased vehicle-related 

mortalities. 

Habitat fragmentation from activities such as roads, well pads, mines, 

pipelines, and electrical power lines also can result in the direct loss of 

potential wildlife habitat. Other habitat fragmentation effects such as 

increased noise, elevated human presence, dispersal of noxious and invasive 

weed species, and dust deposition from unpaved road traffic can extend beyond 

the surface disturbance boundaries. These effects result in overall changes in 

habitat quality, habitat loss, increased animal displacement, reductions in 

local wildlife populations, and changes in species composition. However, the 

severity of these effects on terrestrial wildlife would depend on factors such as 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-89 

sensitivity of the species, seasonal use, type and timing of project activities, 

and physical parameters (e.g., topography, cover, forage, and climate). 

4.2.9.1 Game Species

Big game species that are present within the cumulative study area include 

pronghorn, white-tailed deer, mule deer, and elk. Potential direct impacts to 

these species would include the incremental loss or alteration of potential 

forage and ground cover associated with construction and operation of the 

past, present and reasonably foreseeable future development discussed in 

Section 4.1. Development associated with coal mining, drilling for CBNG, 

ancillary facilities, agricultural operations, urban areas, and transportation 

and utility corridors result in vegetation removal. Assuming that adjacent 

habitats would be at or near carrying capacity and considering the variabilities 

associated with drought conditions and human activities in the study area, the 

PRB Coal Review Task 3D study concluded that displacement of wildlife species 

(e.g., big game) as a result of development activities would create some 

unquantifiable reduction in wildlife populations. 

There are a number of big game habitat ranges within the cumulative study 

area. In Wyoming, the WGFD and the BLM have established habitat 

classifications based on seasonal use. Classification types include crucial 

winter, severe winter, winter yearlong, and yearlong. Crucial winter range 

areas are considered essential in determining a game population’s ability to 

maintain itself at a certain level over the long term. As discussed in the PRB 

Coal Review Task 2 Report, discrete locations for most of the disturbance 

related to the projected development could not be determined based on the 

available information. However, identified future coal reserves were used for 

the Task 3D Report to provide some level of quantification of potential future 

impacts to big game ranges. Tables 4-22 through 4-25 summarize the effects 

on pronghorn, deer, and elk game ranges as a result of the predicted lower and 

upper levels of coal production through 2020. 

Table 4-22. Potential Cumulative Disturbance to Pronghorn Ranges from 

Development Activities—Lower and Upper Coal Production 

Scenarios (acres/percent affected). 

 Pronghorn Ranges1

Time 

Period/Scenario Crucial Winter Severe Winter Winter Yearlong Yearlong 

2010/Lower N/A 1,472 / 3% 33,196 / 2% 32,099 / 1% 

2010/Upper N/A 1,472 / 3% 34,760 / 2% 33,172 / 1% 

2015/Lower N/A 1,460 / 3% 32,649 / 2% 34,828 / 1% 

2015 Upper N/A 1,460 / 3% 34,177 / 2% 36,999 / 1% 

2020/Lower N/A 1,422 / 3% 33,637 / 2% 35,714 / 1% 

2020/Upper N/A 1,422 / 3% 33,580 / 2% 37,437 / 2% 1 Potential coal mine related impacts to big game ranges were determined based on GIS information 

as follows: the total acres of a big game range (e.g., crucial winter, severe winter, winter yearlong, 

and yearlong) within the PRB Coal Review Task 3 study area was divided by the sum of the potential 

disturbance acreage for the time period (based on GIS mapping of coal reserves for the lower coal 

production scenario) and 2006 disturbance from coal mine development. 

Source: PRB Coal Review Task 3D Update Report (BLM 2009f) 
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4-90 Final EIS, Wright Area Coal Lease Applications 

Table 4-23. Potential Cumulative Disturbance to White-tailed Deer Ranges 

from Development Activities—Lower and Upper Coal Production 

Scenarios (acres/percent affected). 

White-tailed Deer Ranges1

Time 

Period/Scenario Crucial Winter Severe Winter Winter Yearlong Yearlong 

2010/Lower N/A N/A N/A 1,411 / 0.6% 

2010/Upper N/A N/A N/A 1,411 / 0.6% 

2015/Lower N/A N/A N/A 1,497 / 0.7% 

2015 Upper N/A N/A N/A 1,495 / 0.7% 

2020/Lower N/A N/A N/A 1,704 / 0.7% 

2020/Upper N/A N/A N/A 1,707 / 0.8% 

1 Potential coal mine-related impacts to big game ranges were determined based on GIS information 

as follows: the total acres of a big game range (e.g., crucial winter, severe winter, winter yearlong, 

and yearlong) within the PRB Coal Review Task 3 study area was divided by the sum of the potential 

disturbance acreage for the time period (based on GIS mapping of coal reserves for the lower coal 

production scenario) and 2006 disturbance from coal mine development. 

Source: PRB Coal Review Task 3D Update Report (BLM 2009f) 

Table 4-24. Potential Cumulative Disturbance to Mule Deer Ranges from 

Development Activities—Lower and Upper Coal Production 

Scenarios (acres/percent affected). 

 Mule Deer Ranges1

Time 

Period/Scenario Crucial Winter Severe Winter Winter Yearlong Yearlong 

2010/Lower N/A N/A 6,808 / 0.4% 25,390 / 1% 

2010/Upper N/A N/A 6,924 / 0.4% 26,641 / 1% 

2015/Lower N/A N/A 6,956 / 0.4% 26,420 / 1% 

2015 Upper N/A N/A 7,285 / 0.5% 27,205 / 1% 

2020/Lower N/A N/A 6,958 / 0.4% 27,004 / 1% 

2020/Upper N/A N/A 7,413 / 0.5% 27,990 / 1% 

1 Potential coal mine-related impacts to big game ranges were determined based on GIS information 

as follows: the total acres of a big game range (e.g., crucial winter, severe winter, winter yearlong, 

and yearlong) within the PRB Coal Review Task 3 study area was divided by the sum of the potential 

disturbance acreage for the time period (based on GIS mapping of coal reserves for the lower coal 

production scenario) and 2006 disturbance from coal mine development. 

Source: PRB Coal Review Task 3D Update Report (BLM 2009f) 

Table 4-25. Potential Cumulative Disturbance to Elk Ranges from 

Development Activities—Lower and Upper Coal Production 

Scenarios (acres/percent affected). 

 Elk Ranges1

Time 

Period/Scenario Crucial Winter Severe Winter Winter Yearlong Yearlong 

2010/Lower 24 / 0.4% N/A 375 / 1% 1,444 / 0.9% 

2010/Upper 24 / 0.4% N/A 375 / 1% 1,444 / 0.9% 

2015/Lower 24 / 0.4% N/A 351 / 1% 1,161 / 0.7% 

2015 Upper 24 / 0.4% N/A 351 / 1% 1,162 / 0.7% 

2020/Lower 24 / 0.4% N/A 351 / 1% 1,121 / 0.7% 

2020/Upper 24 / 0.4% N/A 351 / 1% 1,168 / 0.7% 

1 Potential coal mine-related impacts to big game ranges were determined based on GIS information 

as follows: the total acres of a big game range (e.g., crucial winter, severe winter, winter yearlong, 

and yearlong) within the PRB Coal Review Task 3 study area was divided by the sum of the potential 

disturbance acreage for the time period (based on GIS mapping of coal reserves for the lower coal 

production scenario) and 2006 disturbance from coal mine development. 

Source: PRB Coal Review Task 3D Update Report (BLM 2009f) 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-91 

Direct and indirect effects to small game species (i.e., upland game birds, 

waterfowl, small game mammals) within the cumulative study area as a result 

of development activities would be the same as discussed above for big game 

species. Impacts would result from the incremental surface disturbance of 

potential wildlife habitat, increased noise levels and human presence, dispersal 

of noxious and invasive weed species, and dust effects from unpaved road 

traffic. 

Operations associated with development activities in the cumulative study area 

would result in the use of groundwater. The PRB Coal Review assumes that 

most, if not all, of the coal mine-produced water would be consumed during 

operation and anticipates that up to approximately 31,000 mmgpy of water 

would be produced in association with oil and gas production in 2010, 

increasing to about 42,000 mmgpy by 2020. The portion of the water that is 

produced in association with the CBNG and discharged to impoundments or 

intermittent and ephemeral streams would be available for area wildlife (e.g., 

waterfowl). Although much of the water would evaporate or infiltrate into the 

ground, it is anticipated that substantial quantities of water would remain on 

the surface and would result in the expansion of wetlands, stock ponds, and 

reservoirs, potentially increasing waterfowl breeding and foraging habitats. The 

median sodium concentration of CBNG-produced water from the Fort Union 

Formation is 270 mg/L. If sodium concentrations are maintained below 

17,000 mg/L in the evaporation ponds, the potential adverse effects to 

waterfowl would be minimal. 

4.2.9.2 Non-game Species

Potential direct impacts to non-game species (e.g., small mammals, raptors, 

passerines, amphibians, and reptiles) would include the incremental loss or 

alteration of existing or potential foraging and breeding habitats from 

construction and operation of past, present and reasonably foreseeable future 

development activities (e.g., vegetation removal for coal mines and CBNG wells, 

ancillary facilities, and transportation and utility corridors). Impacts also could 

result in mortalities of less mobile species (e.g., small mammals, reptiles, 

amphibians, and invertebrates), nest or burrow abandonment, and loss of eggs 

or young in the path of vehicles and heavy equipment. Indirect impacts would 

include increased noise levels and human presence, dispersal and invasion of 

noxious weeds, and dust effects from unpaved road traffic. Assuming that 

adjacent habitats would be at or near carrying capacity, and considering 

variable factors such as drought conditions and human activities in the study 

area, the PRB Coal Review concluded that displacement of wildlife species from 

the cumulative study area would result in an unquantifiable reduction in 

wildlife populations. 

Numerous migratory bird species have been documented within the PRB over 

the last two to three decades of wildlife monitoring. Development activities that 

occur during the migratory bird breeding season (April 1 through July 31) 

could cause the abandonment of a nest site or territory or the loss of eggs or 
4.0 Cumulative Environmental Consequences 

4-92 Final EIS, Wright Area Coal Lease Applications 

young, resulting in the loss of productivity for the breeding season. Loss of an 

active nest site, incubating adults, eggs, or young would not comply with the 

intent of the Migratory Bird Treaty Act and could potentially affect populations 

of important migratory bird species that may occur in the PRB. 

Breeding raptor species that occur within the cumulative study area include 

the bald eagle, golden eagle, ferruginous hawk, red-tailed hawk, rough-legged 

hawk, Swainson’s hawk, American kestrel, prairie falcon, northern harrier, 

great horned owl, short-eared owl, burrowing owl, and long-eared owl (Asio 

otus). Bald eagles and long-eared owls are rare nesters in the area. 

One potential direct impact to raptors is habitat (nesting and foraging) loss due 

to additional surface disturbance within the cumulative study area. In the 

event that development activities were to occur during the breeding season 

(February 1 through July 31), these activities could result in nest or territory 

abandonment, or loss of eggs or young. Such losses would reduce productivity 

for the affected species during that breeding season. As discussed above, loss 

of an active nest site, incubating adults, eggs, or young would not comply with 

the intent of several laws, including the Migratory Bird Treaty Act and the Bald 

and Golden Eagle Protection Act. 

Additional direct impacts could result from construction of new overhead power 

lines in the region. New power line segments in the study area would 

incrementally increase the collision and/or electrocution potential for migrating 

and foraging bird species (e.g., raptors and waterfowl) (APLIC 1994). However, 

the potential for avian collisions with overhead power lines is typically 

dependent on variables such as the location of the structures relative to highuse areas (e.g., nesting, foraging, staging, and roosting habitats), the 

orientation of the power line to flight patterns and movement corridors, species 

composition, line visibility, and structure design. 

In addition, new power lines could pose an electrocution hazard for raptor 

species attempting to perch on the structure. Configurations greater than 69 

kV typically do not present an electrocution potential, based on conductor 

placement and orientation (APLIC 2006). It is assumed that future permitting 

for power lines would require the use of appropriate raptor-deterring designs, 

thereby minimizing potential impacts. For example, SMCRA requires that 

surface coal mine operators use the best technology available to ensure that 

electric power lines are designed and constructed to minimize electrocution 

hazards to raptors. Power line impacts to raptors can be reduced with the 

increased use of underground power lines wherever possible. Many of the 

power lines for CBNG development currently are being constructed 

underground. 

4.2.9.3 Fisheries

Potential cumulative effects on fisheries as a result of development activities in 

the cumulative study area would be closely related to impacts on ground and 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-93 

surface water resources. In general, development activities could affect fish 

species in the following ways: 1) alteration or loss of habitat as a result of 

surface disturbance; 2) changes in water quality as a result of surface 

disturbance or introduction of contaminants into drainages; and 3) changes in 

available habitat as a result of water withdrawals or discharge. The potential 

effects of development activities on aquatic communities are discussed below 

for each of these impact topics. 

The predominant aquatic habitat type in the cumulative study area consists of 

intermittent and ephemeral streams and scattered ponds and reservoirs. In 

general, perennial streams within the study area are limited to the Little 

Powder River and Belle Fourche River. Warm water game fish and non-game 

species are present in some perennial stream segments and numerous 

scattered reservoirs and ponds. However, the latter features are typically 

stocked artificially either following construction or annually, depending on the 

depth of the water body. Due to the lack of constant water in most of the 

potentially affected streams and static water bodies, existing aquatic 

communities are mainly limited to invertebrates and algae that can persist in 

these types of habitats. The removal of stock ponds would eliminate habitat for 

invertebrates and possibly fish species. This loss would be temporary if the 

stock ponds are replaced during reclamation. 

Development activities could result in the loss of aquatic habitat as a result of 

direct surface disturbance. Table 4-10 summarizes the cumulative acres of 

surface disturbance and reclamation as of 2003 and 2007, and projects 

cumulative acres of surface disturbance and reclamation in 2010, 2015, and 

2020. Discrete locations for development disturbance and reclamation areas 

cannot be determined based on existing information. However, projected 

development that could result in the loss of aquatic habitat would involve the 

construction of additional linear facilities, product gathering lines and road 

systems associated with conventional oil and gas and CBNG activities, as well 

as any additional disturbance that would be associated with extending coal 

mine operations onto lands adjacent to the existing mines. The removal of 

aquatic habitat eliminates existing and potential habitat for invertebrates and 

some fish species. This loss would be temporary if such ponds are 

reconstructed and recharged as part of the reclamation process. 

Projected activities would result in surface disturbance in each of the six 

cumulative study area sub-watersheds. Information relative to the stream 

crossing locations for the majority of the linear facilities is not available at this 

time. The initial phases of the proposed Bison Pipeline Project commenced in 

April 2008 and is projected to be completed by November 2010. If the project 

is constructed as planned, it would cross Cottonwood Creek, a tributary of the 

Little Powder River. Typically, the associated disturbance corridor would 

consist of a 100-foot-wide construction ROW; however, site-specific stream 

crossing methods and reclamation would be determined at the time of project 

permitting. 
4.0 Cumulative Environmental Consequences 

4-94 Final EIS, Wright Area Coal Lease Applications 

Future coal mining also could remove intermittent or ephemeral streams and 

stock ponds in the Antelope Creek, Upper Cheyenne River, Upper Belle 

Fourche River, and Little Powder River sub-watersheds. Coal mine permits 

provide for removal of first- through fourth-order drainages. During 

reclamation, third- and fourth-order drainages must be restored; first- and 

second-order drainages often are not replaced (Martin et al. 1988). As 

discussed in Section 3.5.2, the Cheyenne River and its tributaries drain the 

general Wright analysis area. All streams within the LBA tracts and adjacent 

applicant mine permit areas are typical for the region, in that flow events are 

ephemeral. Under natural conditions, aquatic habitat is limited by the 

ephemeral nature of surface waters in the general Wright analysis area. The 

results of fish surveys conducted in the Belle Fourche River, Caballo Creek, 

Antelope Creek, and various area stock ponds during baseline studies for the 

mines in the South Gillette and Wright subregions that started in the mid1970s were discussed in Section 3.10.7.1; no uncommon species were 

documented during those efforts. 

The PRB Coal Review assumes that surface disturbing activities would not be 

allowed in perennial stream segments or reservoirs on public lands that 

contain game fish species. It also assumes that other types of development 

operations would not occur within stream channels nor would they remove 

ponds or reservoirs as part of construction or operation and, therefore, would 

not result in the direct loss of habitat for these species. 

Water quality parameters such as turbidity and bottom substrate composition 

can be impacted by surface disturbing activities through erosion of sediment 

into water bodies. Contaminants can also be introduced into those systems 

through the chemical characteristics of the eroded sediment. Potential related 

effects on aquatic biota could include physiological stress, movement to avoid 

affected areas, or alterations of spawning or rearing areas (Waters 1995). 

Studies have shown that TDS levels in streams near reclaimed coal lands have 

increased from one percent to seven percent (Martin et al. 1988). Typically, 

sedimentation effects are short-term in duration and localized in terms of the 

affected area. TDS concentrations would stabilize and return to more typical 

concentrations after construction or development activities have been 

completed. The PRB Coal Review anticipated that the use of appropriate 

erosion and spill control measures during both development and reclamation 

activities, as determined during the permitting process, would minimize the 

introduction of additional sediments into the sub-watershed. 

The removal of streamside vegetation would impact both riparian vegetation 

and stream parameters in those locations. Loss of vegetation along stream 

channels would reduce the shade and increase bank erosion, both of which 

would degrade aquatic habitats. Effects on aquatic habitats from linear 

projects, such as ROWs, would be limited to a relatively small portion of the 

stream (generally no more than 100 feet in width), whereas mine-related 

disturbance could affect considerably larger stretches. Because perennial 

streams are protected from development by a buffer zone on either side of 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-95 

center, these types of impacts would presumably be limited to intermittent and 

ephemeral creeks. It is anticipated that reclamation practices to restore 

riparian vegetation would be required during future project permitting, thereby 

minimizing such impacts. 

CBNG and coal mining are the primary types of development activities that use 

or manage water as part of their operations. Based on current trends, the PRB 

Coal Review assumes that most, if not all, of the water produced during coal 

mining would be consumed during operation. As discussed in Section 3.5.2.2, 

changes in surface runoff characteristics and sediment discharges would occur 

during surface coal mining as a result of the destruction and reconstruction of 

drainage channels as mining progresses, and the use of sediment control 

structures to manage discharges of surface water from the mine permit area. 

State and federal regulations require treatment of surface runoff from mined 

lands to meet effluent standards. After treatment, coal mine-related surface 

water in the region would ultimately be discharged into intermittent and 

ephemeral streams in four sub-watersheds (Antelope Creek, Upper Cheyenne 

River, Belle Fourche River, and Little Powder River). The PRB Coal Review 

assumes that most, if not all, of the coal mine-produced water would be 

consumed during operation and anticipates that approximately 31,000 mmgpy 

of water would be produced in association with oil and gas production in 2010, 

increasing to about 42,000 mmgpy by 2020, and assumes that a portion of the 

water that is produced in association with the CBNG would be discharged to 

intermittent and ephemeral drainages in the general analysis area, much as is 

currently allowed in the six sub-watersheds in the study area. Based on past 

monitoring in receiving streams, no change in surface flows would be expected 

beyond approximately two miles from the discharge points (BLM 2003). Water 

discharged from CBNG wells has supplied some drainages and water bodies in 

the PRB nearly continuously for several years. Within the general analysis 

area, Spring Creek has experienced an influx of CBNG water in recent years, 

but has not become perennial. The same is true for other streams elsewhere in 

the PRB that receive CBNG discharge water. 

4.2.9.4 Special Status Species

Special status species are those species for which state or federal agencies 

afford an additional level of protection by law, regulation, or policy. Included in 

this category are federally listed and federally proposed species (species that 

are protected under the ESA), BLM Sensitive Species, USFS Sensitive Species, 

and WGFD Species of Special Concern in Wyoming. Further discussions of 

species that are protected under the Endangered Species Act (ESA), as well as 

BLM and USFS Sensitive Species, are included in Appendices G and H, 

respectively, of this EIS. The U.S. Fish and Wildlife Service (USFWS) also has a 

list of Migratory Bird Species of Management Concern in Wyoming, which is 

discussed in Section 3.10.6. Special status species potentially occurring in the 

Task 1 study area are identified in Section 2.4.3.5 of the PRB Coal Review Task 

1D Report (BLM 2005d). Additional information about the occurrence of these 

species in the general Wright analysis area can be found in the Annual Wildlife 
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4-96 Final EIS, Wright Area Coal Lease Applications 

Reports for the Black Thunder, Jacobs Ranch and North Antelope Rochelle 

mines, which are on file with the WDEQ/LQD in Cheyenne, Wyoming. 

Potential impacts to special status terrestrial species would be similar to those 

discussed above for non-game wildlife (e.g., small mammals, birds, 

amphibians, and reptiles). Potential direct impacts would include the 

incremental loss or alteration of potential habitat (native vegetation and 

previously disturbed vegetation) from construction and operation of 

development activities (e.g., vegetation removal for coal mines and CBNG wells, 

ancillary facilities, and transportation and utility corridors). Impacts could also 

result in mortalities of less mobile species (e.g., small mammals, reptiles, and 

amphibians), nest or burrow abandonment, and loss of eggs or young in the 

path of vehicles and heavy equipment. Indirect impacts would include 

increased noise levels and human presence, introduction and dispersal of 

noxious weeds, and dust effects from unpaved road traffic. 

In general, direct and indirect impacts to special status species would result in 

a reduction in habitat suitability and overall carrying capacity for species 

currently inhabiting the cumulative study area. Development within potential 

habitat for special status species likely would decrease its overall suitability, 

and potentially would reduce or preclude use by some species due to increased 

activity and noise. Future use by a special status species of habitats subject to 

development would be strongly influenced by the quality and composition of 

remaining habitat, with the degree of impact dependent on variables such as 

breeding phenology, nest and den site preferences, the species’ relative 

sensitivity to disturbance, and possibly the presence of visual barriers (e.g., 

topographic shielding) between nesting efforts and disturbance activities. 

Bird species that have been identified as occurring within the PRB and are on 

two or more of the special status species lists include common loon, American 

bittern, white-faced ibis, trumpeter swan, Greater sandhill crane, mountain 

plover, upland sandpiper, long-billed curlew, black tern, yellow-billed cuckoo, 

Lewis’ woodpecker, pygmy nuthatch, sage thrasher, loggerhead shrike, Baird’s 

sparrow, sage sparrow, Brewers sparrow, and Greater sage-grouse. Any 

development activities (oil and gas, coal mining, other operations and 

associated infrastructure) that occur during the breeding season (April 1 

through July 31) could result in the abandonment of a nest site or territory, or 

the loss of eggs or young. As discussed previously, loss of an active nest site, 

incubating adults, eggs, or young as a result of any of these development 

activities would not comply with the intent of the Migratory Bird Treaty Act and 

could potentially impact populations of important migratory bird species that 

are known to or may occur in the PRB. 

A number of raptor species have been documented in the PRB and are on two 

or more of the special status species lists including bald eagle, ferruginous 

hawk, northern goshawk, merlin, peregrine falcon, western burrowing owl, and 

short-eared owl. Those species that have been documented in the general 

Wright analysis area are discussed at length in Appendices G and H of this 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-97 

EIS. Potential direct impacts to raptors would result from the surface 

disturbance of nesting and foraging habitat, as well as injury or mortalities due 

to collisions with vehicles and equipment. Breeding raptors in or adjacent to 

development activities could abandon their nest sites or territories, or lose eggs 

or young. As previously described, such losses would constitute noncompliance with the intent of several laws including the Migratory Bird Treaty 

Act, and the Bald and Golden Eagle Protection Act, and could potentially affect 

populations of important migratory bird species that are known to or may 

occur within the region. Incremental construction of new overhead power lines 

in the area to support energy industries would increase risks of electrocution 

and collision for perching, migrating, and foraging bird species such as the 

larger raptors. Use of current APLIC guidelines for construction designs and 

retrofitting measures for new and existing utility structures would help mitigate 

these impacts. 

The USFWS announced on March 5, 2010 its decision to classify the Greater 

sage-grouse as a candidate species under the Endangered Species Act. 

Candidate species receive no statutory protection under the ESA, but the 

USFWS encourages voluntary cooperative conservation efforts for these species 

because they are, by definition, species that warrant future protection under 

the ESA (USFWS 2010). A total of 239 sage-grouse strutting grounds (leks) 

were identified in the six sub-watersheds in the cumulative study area as of 

2003, though that study did not evaluate the status (i.e., active or inactive) of 

those leks. As discussed in Section 3.10.5 and in the PRB Coal Review Task 

1D Report, the trend in the sage-grouse population for the Sheridan Region 

suggests about a 10-year cycle with periodic highs and lows. More recent 

population peaks have been lower than previous highs, suggesting a steadily 

declining sage-grouse population with the Sheridan Region (Oedekoven 2001). 

Direct and indirect impacts to sage-grouse as a result of development activities 

would result from the incremental surface disturbance of existing and potential 

habitat, increased levels of noise and human presence, introduction or 

dispersal of noxious and invasive weed species, and effects of dust from 

increased traffic on unpaved roads. In addition to disturbance-related impacts, 

sage-grouse are susceptible to infection with West Nile Virus, and the incidence 

of infection is much higher in northeastern Wyoming than the rest of the state. 

As discussed in Section 3.10.5.1, ten sage-grouse leks have been documented 

within the six combined general analysis areas for the six LBA tracts analyzed 

in this EIS. Four of the leks have been active during recent survey years and 

are classified as occupied (Hansen Lakes, Payne, and Kort I and Kort II leks; 

Kort leks likely represent a shift in lekking activity rather than two distinct 

leks). Two of the leks have not been attended by displaying grouse for at least 

the last 10 years and are classified as unoccupied/abandoned (Butch and 

Wilson leks). There is insufficient data on two leks, therefore they have been 

classified as undetermined (Stuart I and Stuart II). Two leks have been 

eclipsed by mining activities at the adjacent Black Thunder and North Antelope 

Rochelle mines (Black Thunder and Rochelle leks, respectively). 
4.0 Cumulative Environmental Consequences 

4-98 Final EIS, Wright Area Coal Lease Applications 

The occupied leks, Hansen Lakes and Payne, are within the BLM study areas 

for the North Hilight Field and North Porcupine LBA Tracts, respectively, and 

are therefore likely to be directly impacted if these two tracts are leased and 

mined under the Proposed Action and/or Alternative 2, BLM’s preferred 

alternative. The 3-mile radii of concern for the two other occupied leks (Kort I 

and Kort II leks, which are likely only one strutting ground that has been 

relocated slightly), overlap the North Porcupine LBA Tract. If the North 

Porcupine LBA Tracts as applied for and/or the additional areas evaluated by 

BLM under Alternative 2, the BLM’s preferred alternative, is leased and mined, 

potential nesting habitat for grouse that were bred at the Kort I and II leks 

would likely be affected by mining activity in those areas. 

Stuart II, one of the two undetermined leks, is within the West Hilight Field 

LBA Tract as applied for, and the 3-mile radii of both undetermined leks 

(Stuart I and Stuart II) overlap both the West Hilight Field and West Jacobs 

Ranch LBA Tracts as applied for. The 3-mile radius is the area in which twothirds of the hens that were bred at those leks would be expected to nest. As 

previously discussed, the Stuart I and Stuart II leks are classified 

undetermined, but they are likely unoccupied/abandoned and will probably 

not be re-occupied in the near future due to the presence of nearby CBNG 

development activities and facilities. Therefore, if the West Hilight Field and 

West Jacobs Ranch LBA Tracts as applied for and the additional areas 

evaluated by BLM under Alternative 2 are leased and mined, it is unlikely that 

those two undetermined leks would be affected. However, as also previously 

discussed, no sage-grouse nests or broods have been recorded on any of the six 

LBA tracts as applied for or on lands added under Alternative 2, BLM’s 

preferred alternative for each tract, during specific surveys or incidental to 

other wildlife surveys conducted in those areas annually since at least 1994. 

The noise associated with mining operations may disrupt sage-grouse breeding 

and nesting activities that might occur in those areas. Direct and indirect 

effects to Greater sage-grouse within the general Wright analysis area as a 

result of development activities are outlined in Appendix H. 

Based on existing information, the spatial relationship between projected 

future disturbance and reclamation areas for the coal production scenarios and 

the resource-specific information in the Geographic Information Systems (GIS) 

layers could not be determined for the PRB Coal Review. However, the analysis 

did use GIS layers for future coal reserves to provide some quantification of 

potential future coal mining-related impacts to Greater sage-grouse. The 

results of this analysis are summarized in Table 4-26. The difference in the 

number of lek sites that would occur within 2 miles of coal mining activities 

under the lower coal production scenario versus the upper coal production 

scenario is due to slight variations in the projected disturbance areas. An 

unquantifiable number of lek sites initially could be impacted by CBNG 

activity, which would occur in advance of coal mine development. Potential 

direct impacts to sage-grouse, if present, could include loss of foraging areas, 

abandonment of a lek site, or loss of eggs or young as a result of development 

activities. 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-99 

Table 4-26. Potential Cumulative Impacts to Greater Sage-grouse Leks from 

Coal Mine Development - Upper and Lower Coal Production 

Scenarios. 

Lek Categories 

2010/ 

Lower 

2010/ 

Upper 

2015/ 

Lower 

2015/ 

Upper 

2020/ 

Lower 

2020/ 

Upper 

Number of Directly 

Affected Leks 3 3 4 4 1 4 

Number of Leks within 2 

Miles of Coal Mining 

Activity 

30 30 31 35 28 27 

Source: PRB Coal Review Task 3D Update Report (BLM 2009f) 

Seven special status fish species potentially occur in the cumulative study area 

sub-watersheds: the flathead chub (Platygobio gracilis) (Antelope Creek, Upper 

Cheyenne River, and Little Powder River sub-watersheds), plains topminnow 

(Fundulus sciadicus) (Upper Cheyenne River), goldeye (Hiodon alosoides) (Little 

Powder River), lake chub (Couesius plumbeus) (Little Powder River), mountain 

sucker (Catostomus platyrhynchus) (Little Powder River), silvery minnow 

(Hybognathus argyritis) (Little Powder River), and plains minnow (Upper 

Cheyenne River, Upper Belle Fourche River, and Little Powder River). Potential 

impacts to special status fish species as a result of development activities 

would be similar to effects discussed above for fisheries. Surface disturbance 

in three sub-watersheds (Upper Cheyenne River, Upper Belle Fourche River, 

Little Powder River) could alter habitat or affect water quality conditions for 

special status fish species. Erosion control measures, as required by existing 

(2003) and future permits, and National Pollution Discharge Elimination 

System (NPDES) permit requirements would be implemented for each project. 

These efforts would help decrease disturbance-related sediment input into 

stream segments that may contain one or more of the special status fish 

species. Therefore, it is anticipated that impacts to special status fish species 

would be low. 

4.2.10 Land Use and Recreation

The PRB Coal Review Task 3D Report (BLM 2009f) discusses potential 

cumulative impacts to land use and recreation as a result of projected 

development activities in the PRB Coal Review Task 3 study area (Figure 4-4). 

The area of actual surface coal mining disturbance and reclamation for the 

years 2003 and 2007, and the projected cumulative areas of disturbance and 

reclamation for 2010, 2015, and 2020 are shown in Tables 4-2 and 4-3. The 

area of actual disturbance and reclamation for all development in 2003 and 

2007, and the projected cumulative total areas of disturbance and reclamation 

for 2010, 2015, and 2020 are shown in Table 4-10. 

The PRB is a predominantly rural, wide open landscape. With little rainfall and 

limited alternative sources of water, the primary land use is grazing. 

Nevertheless, there is a range of other land uses. The major categories include 

agriculture, forested, mixed rangeland, urban, water, wetlands, coal mines, 
4.0 Cumulative Environmental Consequences 

4-100 Final EIS, Wright Area Coal Lease Applications 

and barren land. The relative amounts of these lands in the PRB Coal Review 

Task 1 and Task 2 study area (Figure 4-1) is tabulated in Table 4-27. 

Table 4-27. Land Use by Surface Ownership. 

Surface Ownership (acres) Total 

Use Category BLM USFS State Private Acres Percent 

Agriculture 2,627 14,197 13,770 472,811 503,405 6.3 

Barren 165 205 187 9,396 9,953 0.1 

Forested 137,555 14,604 48,645 332,062 532,866 6.7 

Mixed Rangeland 732,014 218,156 561,363 5,271,644 6,783,177 86.0 

Urban 893 17 1,039 25,469 27,418 0.3 

Water 35 73 334 4,773 5,215 <0.1 

Wetlands 0 104 559 1,566 2,229 <0.1 

Coal Mines 149 7,236 2,805 40,917 51,107 0.6 

Total 873,438 254,592 628,702 6,158,638 7,915,370 100.0 

Source: PRB Coal Review Task 1D Report (BLM 2005d) 

A large part of the PRB consists of split estate lands (privately owned surface 

lands underlain by federally owned minerals). This results in conflicts between 

surface users, which are mainly ranching interests, and mineral developers. 

There also may be conflicts with some dispersed rural residences, although 

specific locations cannot be identified until development is proposed. 

Much of the study area is also used for dispersed recreational activities such as 

hunting. The study area includes surface lands that are federally, state, and 

privately owned. With nearly 80 percent of the area privately owned, public 

lands provide important open space and recreation resources including both 

developed recreation facilities and areas to pursue dispersed recreation 

activities. The private sector contributes the elements of commercial recreation 

opportunities and tourism services such as motels and restaurants. Some 

private land owners also allow hunting with specific permission, sometimes for 

a fee. 

4.2.10.1 Grazing and Agriculture

Potential impacts to grazing in the cumulative study area as a result of 

development activities can be classified as short-term and long- term. Potential 

short-term impacts arise from: 

• the temporary loss of forage as a result of vegetation removal/ 

disturbance; 

• temporary loss of AUMs; 

• temporary loss of water-related range improvements, such as improved 

springs, water pipelines, and stock ponds; 

• temporary loss of other range improvements, such as fences and cattle 

guards; and 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-101 

• restricted movement of livestock within an allotment due to the 

development and operation of projects like surface coal mines, which 

would cease after successful reclamation had been achieved and 

replacement of water-related and other range improvements had been 

completed. 

The discharge of produced water could increase the availability of water to 

livestock, which may offset the temporary loss of water-related range 

improvements. Potential long-term impacts consist of permanent loss of forage 

and forage productivity in areas, such as power plants, that would not be 

reclaimed in the near term. Indirect impacts may include dispersal of noxious 

and invasive weed species within and beyond the surface disturbance 

boundaries, which decreases the amount of desirable forage available for 

livestock grazing in the long term. 

Development activities could result in short- and long-term impacts to 

agricultural land, depending on their spatial relationship. Short-term impacts 

would include the loss of crop production during development and operational 

phases of the projects. Long-term impacts would result from the permanent 

loss of agricultural land due the development of permanent facilities such as 

power plants and railroads. 

Table 4-28 contains an estimate of the number of AUMs unavailable on lands 

disturbed and not yet reclaimed through 2020 for the high and low levels of 

predicted development activity, along with the acreage of cropland estimated to 

be affected. 

4.2.10.2 Urban Use

It is expected that there would be additional expansion of urban residential and 

commercial development as a result of the projected 48 percent growth in 

population (between 2003 and 2020) in Campbell County. Section 4.2.12 and 

the Task 3C Report of the PRB Coal Review (BLM 2005f) contain additional 

information on employment and population issues in the study area. A 

majority of the new urban development would be expected to occur adjacent to 

existing communities, primarily Gillette, which accounts for approximately 60 

Table 4-28. AUMs and Acres of Cropland Estimated Unavailable on Lands

Disturbed and Not Yet Reclaimed as a Result of Development

Activities. 

Category 

2003/ 

Baseline 

2007/ 

Actual 

2010/

Lower 

2010/

Upper 

2015/

Lower 

2015/ 

Upper 

2020/

Lower 

2020/

Upper

Unavailable 

AUMs1 18,150 22,108 19,820 20,145 22,389 22,905 22,131 22,950

Unavailable 

Crop Land (acres) 48 ---2 59 60 134 139 206 289 

1 Based on an average stocking rate of 6 acres per AUM. 

2 Not reported.

Source: PRB Coal Review Task 3D Update Report (BLM 2009f)
4.0 Cumulative Environmental Consequences 

4-102 Final EIS, Wright Area Coal Lease Applications 

percent of the Campbell County population and, to a lesser extent, Wright and 

other small communities. Most of this development would occur on land that 

is currently in use for grazing or agriculture. 

4.2.10.3 Recreation

Accessible public lands provide diverse opportunities for recreation, including 

hunting, fishing, off road vehicle (ORV) use, sightseeing, and wildlife 

observation. The National System of Public Lands generally provides dispersed 

recreational uses in the study area. Some developed recreational facilities 

occur in special management areas, including recreation areas. While 

opportunities are available on public lands throughout the PRB, the majority of 

dispersed recreational uses occur in the western part of the PRB Coal Review 

Task 1 and Task 2 study area, including the south Big Horn Mountains area 

and along the Powder River. Public lands elsewhere consist mainly of isolated 

tracts of land that are too small to provide a quality recreational experience. 

Larger parcels of public lands occur in the southwest part of Johnson County 

and along the Powder River (administered by BLM) and in the Thunder Basin 

National Grassland (administered by the USFS). Public lands are accessible via 

public roads or across private land with the landowner’s permission. 

Hunting is a major recreation use of state and federal lands in the study area. 

Various big game and upland game bird species are hunted in the region. 

Fishing is a popular year-round activity for residents of the study area. 

Mule deer and pronghorn hunting are by far the most popular hunting 

activities in the Task 1 study area, accounting for 35,529 and 21,304 hunter 

days, respectively, in 2003 (Stratham 2005). The next highest were cottontail 

rabbit (2,348 hunter days) and elk (2,055 hunter days), followed by wild turkey 

(1,019), sharp-tailed grouse (508), and sage-grouse (38). Consistent trends in 

hunter activity over the past decade are not discernible from the WGFD data 

considered in the PRB Coal Review. All of the most prominent species hunted 

in the study area have had high years and low years. Pronghorn hunting, for 

example, was greatest from 1993 to 1996, while elk hunting was at its peak in 

2001 and 2002. Mule deer hunting has been the most consistent, ranging from 

a low of 28,311 hunter days in 1996 to a high of 37,307 hunter days in 2002. 

ORV use in the Task 1 study area is available on most BLM-managed lands. 

Most of the public land in Johnson, Sheridan, and Campbell counties has been 

inventoried and designated as open, limited, or closed to ORV use. For the 

baseline year, approximately 20,386 acres were open to unlimited vehicle travel 

on and off roads. There were 4,680 acres in the area that were closed to all 

ORV use and approximately 867,534 acres were available for limited use. 

Limited use typically means ORVs are restricted to existing roads and vehicle 

routes. 

Recreational use of public lands in the Task 1 study area has increased 

substantially over the past two decades, and is expected to continue to increase 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-103 

by about five percent every 5 years for most recreational activities (BLM 2003). 

Total visitor use by residents and nonresident visitors in Campbell and 

Converse counties in 1980 was projected at 1,276,000 visitor days (BLM 1979). 

The total visitor days of 1,881,763 estimated for 1990 was approximately 47 

percent higher than the 1980 visitor days (BLM 2001a). Fewer than three 

percent of visitor days were estimated to occur on public lands. 

Few, if any, of the developed recreation sites in the PRB Coal Review Task 3 

study area would be affected by development related disturbance. As most of 

the projected disturbance area would occur on privately owned surface land, 

the extent of effects on dispersed recreation activities largely would depend on 

whether the disturbance areas had been open to public or private lease 

hunting. It is projected that cumulative development activities, especially the 

dispersed development of CBNG and, to a lesser extent, conventional oil and 

gas, would tend to exacerbate the trend toward a reduction in private land 

available for public hunting, which has been observed by WGFD in recent years 

(Shorma 2005). A reduction in available private land for dispersed recreation 

would contrast with the anticipated increase in demand for recreational 

opportunities and would tend to push more recreationists toward public lands 

where the BLM has projected a five percent increase in use every 5 years (BLM 

2001a). After coal- and oil and gas-related development activities have been 

completed and the disturbed areas have been reclaimed, many of the adverse 

effects on dispersed recreation activities would be reduced. 

It is expected that the development activities also would tend to expand and 

exacerbate the qualitative degradation of the dispersed recreation experience, 

in general, and of the hunting experience, in particular, as reported by the 

WGFD (Jahnke 2005). As noted in the Task 1D Report of the PRB Coal Review 

(BLM 2005d), reductions in land available for hunting also make herd 

management more difficult for the WGFD and reduce its hunting-derived 

revenues (Shorma 2005). 

No direct effects on wilderness or roadless areas would be expected from the 

projected development activities. There are no designated wilderness areas in 

the study area, and mineral development would not be permitted in the 

Fortification Creek Wilderness Study Area until and unless Congress acts to 

remove it from Wilderness consideration. 

There would be no effects on Wild and Scenic Rivers as the only river segment 

identified as both “eligible” and “suitable” in the Task 1D Report of the PRB 

Coal Review is not in the cumulative study area. 

4.2.11 Cultural Resources and Native American Concerns

The PRB Coal Review Task 3D Report (BLM 2009f) discusses potential 

cumulative impacts to cultural resources as a result of projected development 

activities in the cumulative study area. The area of actual surface coal mining 

disturbance and reclamation for the years 2003 and 2007, and the projected 
4.0 Cumulative Environmental Consequences 

4-104 Final EIS, Wright Area Coal Lease Applications 

cumulative areas of disturbance and reclamation for 2010, 2015, and 2020 are 

shown in Tables 4-2 and 4-3. The area of actual disturbance and reclamation 

for all development in 2003 and 2007, and the projected cumulative total areas 

of disturbance and reclamation for 2010, 2015, and 2020 are shown in Table 

4-10. 

Cultural sites occur throughout the cumulative study area. Surface disturbing 

activities can result in the loss or destruction of these sites. Table 4-29 

contains an estimate of the amount of projected disturbance through 2020 for 

the projected lower and upper levels of coal development activity, along with 

the number of cultural sites estimated to be affected. The sites fall into two 

categories; prehistoric sites and historic sites, as described below. Also below 

are description of Native American traditional cultural places and a summary 

of the program to protect sites in any of these categories. 

4.2.11.1 Prehistoric Sites

All recognized prehistoric cultural periods, from Clovis through Protohistoric 

(about 11,500 to 200 years ago), are represented in the cumulative study area 

(see Section 3.12 for additional discussion about the prehistoric cultural 

periods.) The earliest prehistoric cultural periods, Paleoindian through Early 

Plains Archaic, are represented by only a small number of sites. Archaic and 

later prehistoric period sites (Archaic to Protohistoric) are represented in 

increasing numbers as a result of higher populations through time and better 

preservation of more recent sites. Important prehistoric site types in the region 

include artifact scatters, campsites, stone circles, faunal kill and processing 

sites, rock alignments and cairns, and stone material procurement areas. 

Artifact scatters dominate prehistoric sites in the study area. When there is 

adequate information to evaluate these types of sites, most are not eligible to 

the NRHP. However, complex sites and sites with buried and dateable material 

can yield important information and are often field evaluated as eligible. The 

proportion of unevaluated sites is lower in the subwatersheds in which more 

studies and more follow-up studies have been conducted, such as Antelope 

Creek, Upper Cheyenne River, and Upper Belle Fourche River. Some portions 

of some of the subwatersheds which have more varied habitats or conditions 

more conducive to preservation are very rich in significant prehistoric sites. 

Within the cumulative study area, these areas include the lower Antelope 

Creek drainage and eastern portions of the Upper Belle Fourche River. While 

prehistoric sites do exist in the general Wright analysis area, it does not appear 

to be particularly plentiful in significant prehistoric sites. More detailed 

information on the known cultural sites that are present in the PRB based on 

the existing surveys is included in the Task 1D Report for the PRB Coal Review 

(BLM 2005d). 
4.0 Cumulative Env

Final EIS, Wright Area Coal Lease Applications 4-105 

Table 4-29. Square Miles of Projected Cumulative Disturbance and Number of Potentially Affe

Sites in the PRB Coal Review Task 3 Study Area – Lower and Upper Coal Production S

Lower Coal Production Scenario Upper Coal Pro

Year 2010 Year 2015 Year 2020 Year 2010 Year 

Sub-watershed 

Average 

Number of 

Sites per 

Square Mile1

Square

Miles2 Sites3 

Square

Miles2 Sites3 

Square

Miles2 Sites3 

Square

Miles2 Sites3 

Square

Miles2 

Antelope Creek 4.7 59 277 76 357 94 442 61 287 79 Dry Fork Cheyenne River 8.9 2.2 20 2.7 24 3.1 28 2.2 20 2.7 Little Powder River 4.6 76 350 85 391 89 409 77 354 86 Upper Belle Fourche River 4.3 135 580 148 636 156 671 137 589 154 Upper Cheyenne River 5.2 57 296 66 343 76 395 58 302 68 Upper Powder River 5.0 160 530 175 875 242 1,210 106 530 175 Total 435 2,053 553 2,626 660 3,155 441 2,082 565 1 Average number of sites per square mile based on previous surveys in the study area. 2 Calculated, based on database disturbance acreages prepared for the Task 2 Report for the PRB Coal Review, Past and Present 

Development Activities (Appendices A and D) (BLM 2009b). 

3 The number of sites was calculated by multiplying the average density of known cultural sites per square mile (based on previo

square miles of projected cumulative disturbance. 

Source: PRB Coal Review Task 3D Update Report (BLM 2009f) 
4.0 Cumulative Environmental Consequences 

4-106 Final EIS, Wright Area Coal Lease Applications 

4.2.11.2 Historic Sites

In the PRB region, sites are documented within the broad contexts of Rural 

Settlement, Urban Settlement, Mining, Transportation, Military, Exploration, 

and Communication. Each of these site categories and the types of sites they 

include are detailed in the Task 1D Report for the PRB Coal Review (BLM 

2005d). Evaluation of the importance of historic sites, districts, and landscapes 

must consider aspects of both theme and period in assessing the historic 

character and contributing attributes of the resources. 

4.2.11.3 Native American Traditional Cultural Places

General ethnographies of the tribes that may have had traditional ties to this 

region do not provide information on specific resources in the study area that 

are likely to be traditional cultural concerns because these resources are 

considered confidential by the tribes. Within this region, there are prominent 

and identifiable places such as the Medicine Wheel to the west in the Bighorn 

Mountains and Devils Tower to the east in the Black Hills area. These known 

sites offer some indication of the types of places valued by the Plains Indian 

horse cultures in the historic period. Any identification of sacred or traditional 

localities must be verified in consultation with authorized tribal 

representatives. 

4.2.11.4 Site Protection

At the time an individual project is permitted, the development activities 

considered in this study would be subject to the following regulations relative 

to cultural resources. Section 106 of the National Historic Preservation Act of 

1966 as amended, its implementing regulations (including but not limited to 36 

CFR 800, 36 CFR 61, and Executive Order 11593), and NEPA and its 

implementing regulations, including 40 CFR 1500 - 1508, provide the legal 

environment for documentation, evaluation, and protection of historic 

properties (i.e., cultural resources eligible for inclusion on the National Register 

of Historic Places) that may be affected by development activities. In cases of 

split estate (where surface ownership and mineral ownership differ), surface 

resources, such as cultural sites, belong to the surface owner. The surface 

owner must be consulted about investigation, mitigation, or monitoring. 

4.2.12 Transportation and Utilities

The PRB Coal Review Task 3D Report (BLM 2009f) discusses potential 

cumulative impacts to transportation and utilities systems as a result of 

projected development activities in the cumulative study area. The area of 

actual surface coal mining disturbance and reclamation for the years 2003 and 

2007, and the projected cumulative areas of disturbance and reclamation for 

2010, 2015, and 2020 are shown in Tables 4-2 and 4-3. The area of actual 

disturbance and reclamation for all development in 2003 and 2007, and the 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-107 

projected cumulative total areas of disturbance and reclamation for 2010, 

2015, and 2020 are shown in Table 4-10. 

Generally, transportation systems in the cumulative study area would not be 

directly affected by the disturbance associated with projected development. 

Site-specific instances of disturbance may require that segments of highways, 

pipelines, transmission lines, or railroads be moved to accommodate expansion 

of certain coal mines. In such cases, the agencies authorized to regulate such 

actions would have to approve any proposal to move any segments of any 

transportation systems and construction of alternative routing would be 

required prior to closing existing links so that any disruptive effects on 

transportation systems would be minimized. 

The coal mines in the North Gillette subregion currently ship most of their coal 

via the east-west BNSF rail line through Gillette. That subregion produced 55 

mmtpy in the baseline year (2003), which was just 22 percent of the estimated 

250 mmtpy capacity of the BNSF rail line (BLM 2005a). The coal mines in the 

South Gillette and Wright subregions produced approximately 308 mmtpy in 

2003, which was 88 percent of the estimated 350 mmtpy capacity of the joint 

BNSF & UP line serving those areas in the baseline year. 

Potential effects of development activities on transportation and utilities may be 

either short- or long-term in nature, varying with the type of development. A 

power plant or an urban community development would be considered longterm, and the demand for transmission line capacity would be virtually 

permanent, lasting for the economic life of the activity. The effects of coal 

production and the related demand for rail capacity would vary with market 

changes. In recent years, coal production has been increasing and the PRB 

Coal Review projects that the trend would continue, as shown in Tables 4-2 

and 4-3. Similarly, the demand for pipeline capacity would vary with market 

conditions as well as with the rate of depletion of the oil or gas resource. 

Potential direct effects of projected development on roads and highways would 

include increased vehicular traffic and risk of traffic accidents on existing 

roadways in the cumulative study area from daily travel by workers and their 

families. Indirect effects would include increased wear and tear on existing 

roads, additional air emissions from vehicles, additional fugitive dust from 

roads, noise, increased potential access to remote areas, and an increased risk 

of vehicle collisions with livestock and wildlife. Direct effects on railroads, 

pipelines, and transmission lines primarily would include increased demand 

for capacity to move coal, oil and gas, and electricity from production locations 

in the study area to markets outside the area. Indirect effects would include 

potential impacts of the accumulation of coal dust and fines blowing or sifting 

from moving, loaded rail cars. A collaborative effort between the National Coal 

Transportation Association, the mines, and the BNSF & UP Railroads is 

resulting in measures to reduce coal dust emissions from loaded, moving rail 

cars. 
4.0 Cumulative Environmental Consequences 

4-108 Final EIS, Wright Area Coal Lease Applications 

The socioeconomic analysis conducted as a part of Task 3C of the PRB Coal 

Review projects a population increase of approximately 48 percent between 

2003 and 2020 in Campbell County under the upper coal production scenario 

(BLM 2005f). Campbell County accounts for most of the population in the PRB 

Coal Review Task 3 study area. Based on traffic studies conducted 

independently of the PRB Coal Review, vehicle miles traveled tend to increase 

at or above the rate of population growth. Consequently, highway traffic would 

be expected to increase by at least 48 percent by 2020. Approximately 60 

percent of the population growth would occur in or near Gillette, which would 

indicate that the same proportion of traffic would originate in the Gillette area. 

The remainder of the traffic growth would be dispersed throughout the study 

area. Under this scenario, the greatest impact on traffic would occur in the 

Gillette area, where existing traffic volume to capacity ratios are highest. The 

increased traffic would be expected to cause delays in the Gillette area and 

might require widening of some streets and roads or other measures to 

increase traffic capacity. It is anticipated that there would be an increase in 

the risk of traffic accidents approximately proportional to the increase in traffic. 

 Highway capacity on major routes away from Gillette would be expected to be 

sufficient to accommodate the growth without substantial constraints. 

Existing rail lines, together with proposed upgrades on the joint BNSF & UP 

line, would be expected to accommodate the projected coal transportation 

traffic through 2015 (Table 4-30). The PRB Coal Review Task 2 Report (BLM 

2009b) projects that the proposed DM&E line would be built and operational 

by 2015 (pending completion of additional environmental analysis), which 

would add 100 mmtpy in additional shipping capacity for the South Gillette 

and Wright subregions. 

Table 4-30. PRB Rail Lines Coal Hauling Capacity and Projected Use. 

2010 Projected 2015 Projected 2020 Projected 

2010 

Capacity 

Rail Use 

Increase1

2015 

Capacity

Rail Use 

Increase1

2020 

Capacity 

Rail Use 

Rail Increase1

Line mmtpy mmtpy % mmtpy mmtpy % mmtpy mmtpy % 

North 

BNSF 250 62-78 25-31 250 74-104 30-42 250 78-121 31-48

South 

BNSF 

& UP 

450 349-398 79-88 600 381-4392 64-732 600 417-4552 70-762

DM&E 0 0 0 ---2 ---3 ---3 ---2 ---3 ---3 

1 The range of increase in use shown for each year reflects the increases that are projected for the Lower and Upper 

Coal Production Scenarios, respectively. 2 The DM&E is assumed to be built and operational by 2015, adding 100 mmtpy of capacity for the mines served by 

the BNSF & UP South line. 3 The BNSF & UP South line figures represent the projected combined traffic and percent capacity on the BNSF & 

UP South line and the projected DM&E line. 

Source: PRB Coal Review Task 3D Update Report (BLM 2009f) 

The Task 2 Report for the PRB Coal Review originally projected that basin-wide 

production of CBNG could potentially double by 2020, which would suggest 

that additional pipelines could be built. The recent update of the Task 2 report 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-109 

(BLM 2009b) revised the projections. As noted in Section 4.1, trends in CBNG 

development since 2007 indicate that this estimate may be lowered as new 

forecasting is done. Current gas pipeline capacity out of the PRB is 

approximately 2.05 bcf per day; average conventional natural gas and CBNG 

production in 2007 was approximately 1.24 bcf per day. Based on the 

information in the update of the Task 2 report, potential total gas production 

(conventional natural gas and CBNG) has been projected at 2.06 bcf per day by 

2010. This potential is pipeline capacity limited, suggesting additional 

pipelines could be built. There are no specific projects under way; however, 

two potential additional pipeline projects (Bison and Pathfinder) have been 

identified for potential completion in 2010 (see Section 4.1.2.3.1). These 

projects would increase the take-away capacity by 0.50 and 1.60 bcf, 

respectively, for a total of approximately 4.15 bcf per day. 

By 2010, an estimated 99 megawatts (MW) of additional power would be 

provided by a new wind energy project. An estimated 1,380 MW of new power 

plant production capacity and 250 MW of new wind energy production capacity 

are anticipated in the cumulative study area by 2015. One new 300-MW wind 

energy project and potentially up to 700 MW of additional power generation 

provided by coal-fired power plants is projected for 2020. This level of 

production would require construction of additional transmission line capacity. 

It is assumed that new transmission lines would be constructed to connect new 

power plants to the grid. It is projected that these transmission lines would be 

constructed by 2015 to connect to outside markets. However, specific 

location(s), capacities, and effects on the existing system cannot be determined 

at this time. 

4.2.13 Socioeconomics

The cumulative socioeconomic impact analysis focuses on Campbell County, 

but also considers Converse, Crook, Johnson, Sheridan, and Weston counties 

as directly affected and Niobrara and Natrona counties as indirectly affected. 

Recent and projected socioeconomic conditions are described in more detail in 

the Task 1C and 3C reports for the PRB Coal Review (BLM 2005c and 2005f). 

REMI Policy Insight (REMI), a professionally recognized regional economic 

model, was used to develop the cumulative employment and population 

projections presented below. The version of the REMI model for the Coal 

Review was comprised of two economic regions: one being Campbell County 

alone, the second composed of those Wyoming counties bordering Campbell 

County and linked to its economy by established industrial and consumer 

trade linkages and by work force commuting patterns. Results for the second 

region were analyzed to focus on the five counties, Converse, Crook, Johnson, 

Sheridan, and Weston, that are the most directly linked. Collectively, these five 

counties are referred to in the PRB Coal Review Task 3C Report (BLM 2005f) as 

the surrounding counties. Additional analysis was undertaken to translate the 

population and employment forecasts for each of the surrounding counties into 

housing needs and to project future school enrollment. 
4.0 Cumulative Environmental Consequences 

4-110 Final EIS, Wright Area Coal Lease Applications 

During the 1970s and early 1980s, the PRB emerged as a major coal producing 

region. Federal coal leasing has been a high profile activity because over 90 

percent of the coal resources in the PRB are federally owned. The surface coal 

mines that developed during the 1970s and early 1980s are now mature 

operations, providing a stable economic and social foundation for the region. 

While energy development has produced periodic surges in population, followed 

occasionally by population declines in some communities, the growth in 

domestic energy consumption, coupled with the PRB’s vast energy resource 

base, has resulted in a 50-year growth trend in the region without the severe 

economic dislocations that have characterized other western U.S. resource 

booms. 

This period of extended energy development has been accompanied by 

substantial economic changes and benefits, including economic growth, 

employment opportunity, tax revenue growth, and infrastructure development 

for local governments, both locally and across Wyoming, funded by tax 

revenues generated by production of coal and other energy resources. At the 

same time, periods of rapid growth have stressed communities and their social 

structures, housing resources, and public infrastructure and service systems. 

The emergence of the coal and other energy resource development industries in 

the PRB has had long-term cumulative affects on regional social and economic 

conditions. In general, Campbell County and the entire PRB region have 

developed an enhanced capacity to respond to and accommodate growth. The 

regional coal industry also provides a measure of insulation from dramatic 

economic and social dislocations. Key cumulative social and economic 

conditions identified in the PRB Coal Review are described below. 

4.2.13.1 Employment and the Economic Base

Energy resource development since 1970 has resulted in substantial economic 

expansion across the PRB. Total employment expanded by 163 percent as 

40,674 net new jobs were added between 1970 and 2004. The most rapid 

expansion occurred between 1975 and 1980. After modest growth and slight 

decline in the 1980s and early 1990s, employment growth resumed in the late 

1990s, led by increases in coal mine employment, including subcontractors, 

and CBNG development. Across the six-county area, total employment was 

65,597 in 2004. Nearly half of the net job gain occurred in Campbell County, 

where total employment increased from 6,026 jobs in 1970 to 25,921 jobs in 

2004. Strong gains also were posted in Sheridan County (9,821 jobs) and 

Converse County (4,421 jobs). 

The economic stimuli associated with the gains in mining and CBNG 

employment and the long-term population growth triggered secondary job gains 

in construction, trade, services, and government. In 2004, business and 

consumer services accounted for 51 percent of all jobs in the region, while 

mining and government accounted for 14 percent and 16 percent of all jobs, 

respectively. Farm employment in the region, as a share of total employment, 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-111 

declined from 14 percent in 1970 to 5.0 percent in 2004. However, that shift is 

primarily due to growth in non-farm employment rather than declines in 

farming, as total farm employment in the PRB recorded a net decline of only 

375 jobs, from 3,571 to 3,196 (U.S. Bureau of Economic Analysis 2006). 

The largest impetus to future growth over the PRB Coal Review study period 

(2003 to 2020) is expected to occur by 2010. Under the lower production 

scenario, employment in 2010 related to coal mining, oil and gas production, 

and oil field services is projected to increase by one-third, or more than 2,300 

jobs, as compared to 2003 levels. Many of the jobs gained would be the result 

of increased oil and gas development. While the number of coal mining jobs 

would increase, the projected coal mine-related productivity gains would limit 

increases in the number of mine employees required for operations. 

Beyond 2010, total mining industry employment would decline as major 

infrastructure development (e.g., additional CBNG compression capacity) is 

completed and the pace of conventional oil and gas drilling decreases. 

Increases in CBNG production and coal mining employment would occur 

thereafter, such that total mining employment would approach pre-2010 levels 

by the end of the forecast period (2020). Under the development scenarios, 

construction of three new power plants, having a combined capacity of 1,000 

MW and a peak work force of approximately 1,550 in 2007-2008, is assumed to 

occur concurrently with the increases in mining employment. Under the upper 

production scenario, a second temporary construction work force impact would 

occur between 2016 and 2020 in conjunction with the construction of an 

additional 700-MW power plant. 

The net effects of these activities, including secondary effects on suppliers, 

merchants, service firms, state agencies and local government in the region, 

would be the creation of more than 8,700 new jobs in the region between 2003 

and 2010. Of those, more than 5,600 jobs (a 22 percent increase over 2003) 

would be based in Campbell County. The pace of economic expansion, at least 

in terms of jobs, would moderate after 2010. Total employment growth of 

2,017 additional jobs is projected in Campbell County between 2010 and 2020, 

with 1,741 additional jobs projected in the surrounding counties. 

However, to achieve the projected levels of energy and mineral development 

activity through 2010 assumes that industry has access to the necessary 

equipment, materials, labor, and other vital inputs. Current oil and gas 

exploration and development across the Rocky Mountain region has absorbed 

the available inventory of drilling rigs and crews. A lack of access to resources 

could delay or limit the job gains below the levels projected, even though 

prospects for such growth remain. Furthermore, competition for equipment, 

combined with tight labor markets, could negate the productivity gains that 

underlie the projections, such that the employment and associated impacts do 

materialize, but are associated with lower levels of activity (e.g., a lengthier 

construction period for a power plant or fewer new wells drilled each year). 
4.0 Cumulative Environmental Consequences 

4-112 Final EIS, Wright Area Coal Lease Applications 

Employment effects associated with the upper coal production scenario, 

assuming productivity gains in coal mining equivalent to those in the lower 

coal production scenario, would result in total employment gains of 11,563 

jobs by 2010 in the six-county study area, with an additional 3,667 jobs by 

20202. As compared to the employment projections under the lower coal 

production scenario, those gains include 2,821 additional jobs in 2010 and 

3,214 additional jobs in 2020. Most of the incremental gains would be in 

Campbell County, further stressing labor markets, housing, and other 

community resources. Such pressures could delay or affect the development 

plans of individual firms and operators, such that the projected employment 

levels would not be realized in the time frames shown. Nonetheless, 

substantial growth in employment is expected to occur, and even if the 

projected total employment levels are not realized, substantial social and 

economic impacts still would be anticipated. 

The economic stimuli associated with the projected development also would 

stimulate increases in employment in other nearby counties beyond the five 

surrounding counties identified above. However, the potential effects in these 

areas are not addressed in the PRB Coal Review Task 3C Report because most 

of the effects would comprise indirect or induced growth that would be limited 

in scale relative to the size of the respective economies. Furthermore, the 

economic outlook for those areas is influenced by factors that are beyond the 

scope of this study, such as the role of the oil and gas support services 

industry based in Natrona County in supporting energy development in the 

south-central and southwestern portions of Wyoming. 

4.2.13.2 Labor Market Conditions

Labor market conditions in the PRB reflect a generally healthy economy, with 

average annual county unemployment rates between 2.1 percent (Campbell) 

and 3.5 percent (Weston) in 2006. Statewide and national unemployment rates 

for the period were 3.2 percent and 4.6 percent, respectively (U.S. Bureau of 

Labor Statistics 2007). 

Over time, local unemployment levels and rates have reflected the influences of 

the large, relatively stable employment baseline associated with the region’s 

coal mining industry and the more transitory and variable influences of natural 

gas development. Prior to the onset of CBNG development in 1989, 

unemployment in Campbell County fluctuated between 4.8 and 5.3 percent, 

slightly above the corresponding statewide averages. Labor demand associated 

with CBNG development contributed to a decline in unemployment to below 

3.0 percent in the 2001. As the pace of CBNG development stabilized, labor 

 

2 The number of jobs in the coal mining industry under the upper production scenario was estimated assuming future productivity

gains comparable to those used for the lower production scenario. This approach differs from that described for the upper production 

scenario in the Task 2 report of the coal study, whereby a 16 percent higher production would be achieved with a 2.5 percent increase 

in workforce. Although that assumption reflects a continuation of historic productivity gains, it may underestimate population and 

employment growth and related socioeconomic effects if the production levels are achieved but productivity lags. Using the productivity 

gains from the lower production scenario provides a more conservative perspective on potential long-term population growth for 

purposes of the cumulative analysis. 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-113 

demand eased and unemployment rates climbed to 3.7 percent in 2003, before 

again falling to current record lows. 

The employment effects identified above indicate substantial pressures on local 

labor markets. Strong demand for labor would maintain low unemployment, 

creating upward pressure on wages and salaries. Those influences would 

stimulate substantial economic migration into Campbell County, causing 

impacts to population, housing demand, and other economic and social 

conditions. Similar influences would occur in surrounding counties, although 

the implications are less severe because the scale of effects would be smaller 

and would be distributed over multiple communities and service providers. 

4.2.13.3 Personal Income

A benefit associated with energy resource development, whether it is mineral 

mining or oil and gas development, is local wages and salaries that are among 

the highest in the state. Personal income registered strong gains across the 

region, but especially in Campbell County, during the late 1970s and early 

1980s. In 1981, per capita personal income in Campbell County was $17,520, 

compared to the national average of $11,280 and the statewide average of 

$12,879. Personal income growth was tempered by several years of economic 

stagnation during the late 1980s. Renewed economic vitality since then 

resulted in per capita personal income in Campbell County reaching $33,388 

in 2004. Those gains notwithstanding, per capita income among Campbell 

County’s residents was below statewide and national norms, as well as that for 

Sheridan ($35,716) County. When measured on a median household or family 

income basis in the 2000 census, Campbell County led statewide, national, 

and other counties in the PRB by considerable margins. That pattern has been 

maintained due to the strong economic growth in the region; in 2006 the 

median household income in Campbell County was $60,800 compared to a 

statewide median of $43,785 and national median of $44,374. Median 

household incomes for the other five PRB counties ranged from $40,195 to 

$46,883 (U.S. Census Bureau 2006a). 

In terms of total personal income, Campbell County led the six-county region 

with $1.22 billion in 2004. Sheridan County residents recorded aggregate 

personal income of $972 million in 2004. Total personal income in the other 

counties was substantially lower, ranging from $193 million in Crook County 

to $389 million in Converse County. 

Personal incomes in the region would increase over the time period 2007-2020, 

both in aggregate and on a per capita basis, in conjunction with the economic 

outlooks foreshadowed by the projected development scenarios. In 2004, total 

personal income in the six-county area was $3.24 billion. Under the lower 

production scenario, total personal income would more than double to $7.57 

billion in 2020 (in nominal dollars). The upper production scenario would 

generate an additional $266 million per year in Campbell County and an 

additional $35 to $40 million per year in the surrounding counties by 2020. 
4.0 Cumulative Environmental Consequences 

4-114 Final EIS, Wright Area Coal Lease Applications 

Annual per capita incomes are projected to increase by approximately 27 

percent (in real terms) across the region between 2003 and 2020. Households 

with one or more workers employed directly in the energy industry, associated 

service firms, and the construction industry likely would realize larger shares 

of the gains (BLM 2005f). 

4.2.13.4 Population and Demographics

Population change over time is perhaps the single best indicator of cumulative 

social and economic change in the PRB. Campbell County was not among the 

original 13 counties when Wyoming was admitted to statehood, but was carved 

from Weston and Crook counties in 1911. Campbell County’s 1920 population 

of 5,233 ranked it seventeenth among Wyoming’s counties. Forty years later 

and prior to the onset of coal development in the region, Campbell County 

ranked eighteenth among Wyoming’s counties in terms of population, with a 

5,861 residents. Neighboring Converse, Sheridan, and Weston counties all had 

larger populations. 

By 1980, Campbell County’s population had increased by more than 300 

percent, to 24,367, seventh among Wyoming’s counties. Energy development 

contributed to population growth in Sheridan, Converse, Johnson, and Crook 

counties during that period. Weston County recorded a population decline 

during the period; however, the combined population of the PRB climbed from 

49,311 in 1960 to 82,598 in 1980. 

Annual coal production in the PRB has increased by nearly 560 percent since 

1980, accompanied by expanded mine service and rail transportation capacity, 

stimulating further growth. The impetus for growth in local employment was 

tempered by substantial productivity increases in the mining industry, coupled 

with declining production of other energy resources. Consequently, the 

region’s population gained a relatively modest 11 percent, 9,318 residents, 

between 1980 and 2000, reaching 91,916. Campbell County registered a net 

gain of 9,331 residents during that period, raising its total population to 

33,698 in 2000, fourth highest in the state. Across the PRB, the loss of about 

2,000 residents in Converse County was offset by modest gains in the other 

four counties (U.S. Census Bureau 2001). 

More recently, the PRB has seen renewed population growth, primarily linked 

to CBNG development. Population estimates for 2006 indicate a total regional 

population of 100,504, a 9.3 percent increase over the 2000 census population. 

Gains were reported for all six counties, ranging from 118 persons in Weston 

County to 5,236 persons in Campbell County (Table 4-31). 

The magnitude and timing of projected employment changes from 2003-2020 

under either coal production scenario would trigger corresponding effects to 

population across the PRB, particularly in Campbell County (Figure 4-10). 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-115 

Table 4-31. Recent and Projected PRB Population. 

Year 

Campbell 

County 

Converse 

County 

Crook 

County 

Johnson 

County 

Sheridan 

County 

Weston 

County 

Six 

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 (2006a) and PRB Coal Review Task 3C Report 

Under the lower coal production scenario, Campbell County’s population is 

projected to increase by more than 14,550 residents between 2003 and 2020, 

nearly 9,500 of which are anticipated by 2010. Growth over the next 3 years 

will maintain pressures on housing and other community resources. The 

projected energy and mineral development in the lower coal production 

scenario would also result in substantial population growth elsewhere in the 

PRB, with Sheridan, Johnson, and Converse counties all projected to gain 

substantial population. Population growth, like employment growth, would 

moderate after 2010. Projected population growth between 2003 and 2020 

ranges from 0.5percent compounded annual growth rate (CAGR) in Weston 

County to 2.0 percent CAGR in Campbell County. In absolute terms, the net 

change ranges from 537 additional residents in Weston County to a gain of 

14,557 residents in Campbell County. The total population of the six-county 

study area is projected to climb to 120,178 in 2020, a 1.3 percent CAGR. 

As with employment, changing development conditions could result in actual 

population growth varying from projected growth. If project schedules or levels 

of development vary from the projected levels, corresponding effects on 

population growth could result (e.g., lower growth). Population demographics 

could also change due to migration and commuting, with more immigrating 

construction workers being single-status, rather than accompanied by families. 

Another possibility is that the spatial distribution of population growth could 

shift as a result of housing or labor constraints, such that less growth would 

occur in Gillette and Campbell County, and more growth would occur 

elsewhere. 

Projected population growth through 2020 under the upper coal production 

scenario is approximately 19 percent higher than under the lower coal 

production scenario (28,625 compared to 24,100, with the six-county 

population reaching 124,703 by 2020). Much of the incremental population
2003 2005 2007 2009 2011 2013 2015 2017 2019

YEAR

2004 2006 2008 2010 2012 2014 2016 2018 2020

Population - Upper Coal ProductionPopulation - Lower Coal ProductionEmployment - Upper Coal ProductionEmployment - Lower Coal Production

60,00050,00040,00030,00020,000

10,000

0

Source : PRB Coal Review Task 3C Report (BLM 2005f)

Figure 4-10. Projected Campbell County Population and Employment to 2020.

4.0 Cumulative Environmental Consequences

4-116 Final EIS, Wright Area Coal Lease Applications
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-117 

growth would occur by 2010 in Campbell County, and in particular in and near 

Gillette. 

Community population growth under the upper coal production scenario 

generally would mirror growth under the lower coal production scenario but 

with higher growth in Wright, Douglas, and Newcastle due to the effects of 

higher coal production, coal transportation, and power generation concentrated 

in the southern portion of Campbell County. 

4.2.13.5 Housing

While the population grew by 55 percent in the 1970s, the housing stock in the 

study area grew by almost 78 percent. Housing growth was especially rapid 

during the 1970s in Campbell County, where population grew by 88 percent 

and the housing stock grew by 140 percent. The expansion in housing supply, 

combined with the slowdown in the rate of population growth, produced 

double-digit vacancy rates for rental housing in the late 1980s and early 

1990s. After growth resumed in the mid-1990s, most county-level vacancy 

rates for ownership units were at or below the state levels in 2000. Vacancy 

rates for rental units declined even more sharply. Vacancy rates have fallen 

even more as a result of recent growth, with current rates below 1.5 percent in 

five of the six-county study area, and that in Johnson County at only 2.8 

percent (Table 4-32). 

Table 4-32. Rental Housing Vacancy Rates, 2004 4Q and 2006 4Q. 

Year 

Campbell 

County 

Converse

County 

Crook 

County 

Johnson

County 

Sheridan

County 

Weston 

County Wyoming 

2004 4Q 2.8% 8.3% 10.4% 2.1% 4.5% 5.0% 4.8% 

2006 4Q 0.4% 1.4% 1.0% 2.8% 0.5% 0.0% 2.4% 

Source: Wyoming Housing Database Partnership (2007)

In 2000, the housing inventory in the six-county study area was 41,203 units 

(Table 4-33). Total housing inventory had expanded to 43,363 units in 2005, a 

net addition of 2,160 since 2000. However, new construction hasn’t kept pace 

with population growth, resulting in tighter market conditions in terms of 

availability, and higher prices. 

Table 4-33. Total Housing Stock in 2000 and 2005. 

Year 

Campbell 

County 

Converse 

County 

Crook 

County 

Johnson

County 

Sheridan

County 

Weston 

County 

Six-county 

PRB Region

2000 13,288 5,669 2,935 3,503 12,577 3,231 41,203 

2005 14,085 5,852 3,132 3,694 13,283 3,317 43,363 

Change 797 183 197 191 706 86 2,160 

Source: U.S. Census Bureau (2006b)

In 2005, the average sales price of homes in the study area varied from 

$80,303 in Weston County to $186,095 in Sheridan County. The average 

home price statewide in 2006 was $178,183 (Wyoming Housing Database 

Partnership 2007). In addition to Sheridan County, Campbell ($185,874) and 
4.0 Cumulative Environmental Consequences 

4-118 Final EIS, Wright Area Coal Lease Applications 

Johnson ($180,209) counties also had average home sale prices above the 

statewide average in 2006. The average sales price in Converse County was 

$149,096, 17 percent below the statewide average. 

Monthly costs for rental housing in the PRB, measured in the fourth quarter of 

2006, were highest in Campbell County (Table 4-34). 

Table 4-34. Monthly Housing Rents in 20061 in the PRB Study Area and 

Percent Change from 2004. 

County Apartments Mobile Home Lots Houses 

Mobile Homes 

on a Lot 

 Rent Change Rent Change Rent Change Rent Change 

Campbell $697 25.8% $283 22.0% $975 23.0% $758 20.5% 

Converse $515 31.4% $152 1.3% $545 2.8% $452 22.5% 

Crook $391 17.4% $125 5.9% NA NA NA NA 

Johnson $477 -5.4% $170 16.4% $700 15.3% $518 5.5% 

Sheridan $571 14.0% $285 4.4% $857 27.9% $650 26.7% 

Weston $459 47.1% $119 17.8% $567 36.3% $505 27.5% 

Wyoming $567 14.1% $225 15.4% $782 13.0% $561 15.2% 

1 Data are for the fourth quarter of 2006. Change is the percent change since fourth quarter of 2004. 

NA = information not available due to insufficient sample size. 

Source: Wyoming Department of Administration and Information (2006)

Temporary housing resources are available in the PRB in the form of hotelmotel rooms, private and public campgrounds, and vacant spaces in mobile 

home parks. In all, there are more than 70 lodging establishments with a total 

of more than 2,500 rooms. These temporary housing resources, supplemented 

by whatever apartments, townhouses, and mobile home spaces are available in 

Gillette, Wright and Douglas, have accommodated temporary housing needs 

associated with natural resource and energy projects in the past. 

Both projected coal production scenarios indicate a strong demand for housing 

across the six-county study area through 2020. Net housing requirements 

under the lower coal production scenario are for approximately 9,110 units 

through 2020, a 21 percent increase above the 2006 existing inventory (Figure 

4-11). New housing requirements under the upper coal production scenario 

are estimated at 10,900 units, a 25 percent increase compared to the 2006 

inventory and 1,790 units more than for the lower coal production scenario. 

Approximately 60 percent of the overall demand for new housing through 2010 

would be in Campbell County. 

A substantial portion of the near-term housing demand in Campbell County 

would be associated with the assumed concurrent construction of three power 

plants. If that occurs, one or more project sponsors may be required by the 

Wyoming Industrial Siting Administration to pro-actively provide housing (e.g., 

a construction camp for single-status workers). Such actions could temper the 

needs for more housing; however, the remaining needs would nonetheless be
YEAR

0

500

5,0004,5004,0003,5003,0002,5002,0001,5001,000

CampbellConverseCrook

Johnson

Sheridan

Weston

2003 - 2010 2011 - 2015 2016 - 2020

Source : PRB Coal Review Task 3C Report (BLM 2005f)

Figure 4-11. Projected Housing Demand in the PRB Study Area Under the Lower Coal Production Scenario.

4.0 Cumulative Environmental Consequences

Final EIS, Wright Area Coal Lease Applications 4-119
4.0 Cumulative Environmental Consequences 

4-120 Final EIS, Wright Area Coal Lease Applications 

substantial, straining public and private sector residential development 

capacity. 

Although smaller in scale than those in Campbell County, housing demands in 

the surrounding counties may also strain the capabilities of the residential 

construction sector to respond. Furthermore, residential contractors would be 

competing for available labor, contributing to the population growth and 

housing demand, and fueling increases in construction costs and housing 

prices. 

The relative scale of the housing needs can be evaluated in comparison to past 

growth in the study area. One benchmark for comparison is the rapid growth 

that occurred in the PRB in the 1970s. During that decade, the number of 

housing units in the six-county study area rose by approximately 14,900 units, 

approximately 1,500 units per year on average compared to the 850 to 975 new 

units per year projected under the upper and lower coal production scenarios 

through 2010. The rapid pace of development in the 1970s coincided with a 

period of economic expansion and strained the region’s construction trade and 

building supply industries. Although the underlying economies of the region 

are now larger, the projected needs would tax the ability of communities to 

respond Signs of strain are apparent in Gillette and could surface elsewhere as 

greater housing needs arise in the remaining counties of the six-county study 

area under the low coal production scenario. 

Projected housing demands under either coal production scenario, although 

lower than what Campbell County and the region experienced in the “boom” 

years of the 1970s, would exert substantial pressure on housing markets, 

prices, and the real estate development and construction industries, all at a 

time when demand for labor and other resources would be high overall. 

4.2.13.6 Public Education

There are 10 school districts in the six-county PRB study area, ranging in size 

from CCSD #1 with 7,337 students in the 2005 school year to Sheridan County 

School District # 3 (based in Clearmont, Wyoming) with fewer than 100 

students. CCSD #1, based in Gillette, and Converse #1 in Douglas, serve the 

primary energy and resource development region. 

Public school enrollment trends generally mirrored population trends during 

the period of rapid population growth. District-wide enrollment in Campbell 

County grew by more than 4,600 students (131 percent) between 1975 and 

1985. Enrollment increased in all districts in Converse and Sheridan counties 

as well. Enrollment in Campbell County School District (CCSD) #1 

subsequently peaked, but remained near record high levels for nearly a decade. 

Elsewhere in the region enrollments generally declined with a combined 

enrollment of 9,525 in the other study area districts in 2005, the lowest since 

1975 (Wyoming Department of Education 2006). Recent natural gas and 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-121 

mining development has tempered, but not reversed, the trend of declining 

school enrollments across the region. 

Communities across the PRB study area would see population growth due to 

economic migration from 2003 to 2020; however, the effects of such migration 

on public school enrollments would vary. As the demographics of the 

population change, school districts in the PRB would be affected by new 

trends. In some counties, the size of the school-age population (generally aged 

5 to 17 years) may even trend in the opposite direction of total population in 

the short-term due to underlying demographics of the established resident 

population. 

The demographic projections for the two coal production scenarios forecast 

growth in elementary school enrollments in Campbell County through 2010 

and after 2010 for most PRB school districts. Projected enrollments in CCSD 

#1 would be approximately 10 percent higher by 2020 under the upper coal 

production scenario, with those in the surrounding districts about one percent 

higher. However, several districts still may experience enrollment levels in 

2020 below current levels, as growth from 2010 to 2020 would not offset recent 

declines or those projected to occur before 2010. 

Under the lower coal production scenario, Campbell County would experience 

an increase of 1,587 students, or 22 percent above recent levels, in school 

enrollment through 2020. However, the net impact on CCSD #1 would be 

composed of two trends; a substantial increase in grades K-8 but only small 

increases in grades 9-12 (Figure 4-12). School districts in the surrounding 

counties are projected to experience declining elementary and middle school 

enrollments through 2010 and declining high school enrollments through 

2015. Thereafter, growth and the associated influences on demographics would 

generate renewed enrollment growth, particularly in the elementary grades in 

Johnson, Sheridan, and Converse counties. 

Under either scenario, projected enrollments may cause short-term school 

capacity shortages, depending on the specific grade levels and residential 

locations of the additional students. Under the Wyoming School Facilities 

Commission planning guidelines, impacted school districts generally need to 

accommodate minor capacity shortages through the use of temporary facilities, 

such as portable classrooms. For larger and more long-term increases, the 

Commission’s policy is to fund capital expansion where warranted by 

projections developed during updates of school districts’ 5-year plans. The 

approved 5-year plan for CCSD #1 has a $57.4 million budget covering 

construction of several new schools and numerous major maintenance and 

facility upgrade projects. The approved 5-year plans for the other school 

districts have combined cost of $163 million. Capital investment in public 

education facilities has been a statewide priority in Wyoming for the past 

decade, with taxes and royalties on mineral and energy resources the primary 

source of program funding (Wyoming School Facilities Commission 2007, 

Wyoming CREG 2007). 
2005

Source : PRB Coal Review Task 3C Report (BLM 2005f)

2010 2000 1995 1990 2015 2020 2025

9,0008,0007,0006,0005,0004,0003,0002,000

1,000

0

Other Districts, Grades K-8Campbell #1, Grades K-8Other Districts, Grades 9-12Campbell #1, Grades 9-12

YEAR

Figure 4-12. Projected School Enrollment Trends to 2020 Under the Lower Coal Production Scenario.

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4-122 Final EIS, Wright Area Coal Lease Applications
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Final EIS, Wright Area Coal Lease Applications 4-123 

4.2.13.7 Facilities and Services

The types and levels of facilities and services provided by local governments 

reflect service demand, revenue availability, and community values regarding 

appropriate services and service standards. As with most socioeconomic 

characteristics, the level and availability of local government facilities and 

services varies by county and community across the PRB. There are literally 

several hundred separate service providers in the region. Although virtually all 

local government facilities and services are affected by energy development and 

the demand related thereto, the critical facilities and services include municipal 

water and sewer systems, law enforcement at the county level, and hospitals. 

A comprehensive assessment of facilities and services is beyond the scope of 

the PRB Coal Review. However, an initial screening revealed no critical needs 

or shortfalls and indicated that most providers are engaged in an ongoing longterm process to maintain and improve facilities and services to meet 

community needs and to comply with various regulations and standards. 

The PRB Coal Review socioeconomic analysis focuses on water supply and 

wastewater systems (two essential services that are costly and have the longest 

lead times to develop) and law enforcement, emergency response, and road 

maintenance (three services that typically are most affected by energy 

development). 

Water supply and wastewater systems in most communities have the capacity 

to accommodate the cumulative population growth associated with either 

projected coal production scenario through 2020, assuming ongoing or 

planned improvements are completed. In Gillette, there may be a timing issue 

with planned water supply system expansions, as completion of planned 

improvements would occur when substantial growth is anticipated under both 

projected coal production scenarios. Consequently, Gillette may experience 

water shortages in the summer months for several years, particularly if growth 

follows that under the upper coal production scenario. Douglas is looking to 

add water treatment capacity to provide additional capacity and management 

flexibility to address needs during times of drought. 

The ability to provide desired levels of services to the projected energy-related 

population and development is less clear in Campbell County, Gillette, Wright, 

and outlying rural communities. Campbell County and its communities would 

experience a 25 percent increase in population between 2003 and 2010 under 

the lower coal production scenario and 30 percent under the upper coal 

production scenario. 

Growth rates and the resultant facility and service demand in other counties 

within the study area would be substantially less during the 2003 to 2010 

period under either scenario; all communities other than Johnson County and 

Buffalo would grow substantially less than 10 percent during the period. The 

populations of Johnson County and Buffalo would increase 10 percent by 

2010, driven primarily by CBNG development. 
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4-124 Final EIS, Wright Area Coal Lease Applications 

Growth rates and resultant increases in service demands would slow 

substantially during both the 2011 to 2015 and 2016 to 2020 periods under 

either projected coal production scenario. In most communities except 

Sheridan County and the city of Sheridan, there would be little difference in 

population growth and service demand between the two scenarios. 

4.2.13.8 Fiscal Conditions

Federal mineral royalties and state and local taxes levied on coal and other 

mineral production are vitally important sources of public revenue in Wyoming. 

Taxes, fees, and charges levied on real estate improvements, retail trade, and 

other economic activity supported by energy development provide additional 

revenues to support public facilities and services. These revenues benefit not 

only those jurisdictions within which the production or activity occurs, but also 

the federal treasury, state coffers, school districts, and local governments 

across the state through revenue-sharing and intergovernmental transfer 

mechanisms. 

Coal and other minerals produced in Wyoming, regardless of ownership, are 

subject to ad valorem taxation by local taxing entities and a statewide levy to 

support public education. Statewide ad valorem taxable valuation on coal 

production in 2005 was $2,280.1 million. Of that total, 88 percent was based 

on production in the PRB. 

The total assessed valuation of Campbell County, boosted by recent increases 

in CBNG production, was $4,264 million in 2006. Valuations on aggregate 

mineral production accounted for 87 percent of that total. Because Campbell 

County has been the primary beneficiary of mineral production gains over the 

past three decades and the recent gains tied to CBNG, the county’s assessed 

valuation in 2006 was nearly 38 times that of Weston County ($112.5 million) 

and 31 times that of Crook County ($137.2 million). The 2006 valuation of 

2005 coal production in Campbell County was $1,995.3 million (Wyoming 

Department of Revenue 2006). 

Wyoming levies a severance tax on coal and many other minerals produced in 

the state. The severance tax rate, levied on the value of production, has varied 

from 1.0 percent to 10.5 percent over time. The current rate of 7.0 percent was 

established in 1992. Cumulative statewide severance tax proceeds on coal 

production since 1970 exceed $2.8 billion. Cumulative severance tax revenues 

on coal produced in Campbell County total $1.89 billion. Cumulative 

severance tax revenues for the corresponding period total $96.5 million from 

Converse County, $60.5 million from Sheridan County, and $758.0 million 

from the remainder of the state (Wyoming CREG 2007 and Wyoming 

Department of Revenue 2006). 

Producers pay a 12.5 percent royalty to the federal treasury on the value of all 

surface coal production from federal leases. Total federal mineral royalties of 

nearly $3.3 billion have been paid on coal produced in Wyoming since 1970, 
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Final EIS, Wright Area Coal Lease Applications 4-125 

approximately half of which is returned to the state. Estimated 2005 mineral 

royalties of about $377 million were paid on federal coal produced in the PRB 

(Minerals Management Service 2006). 

At the foundation of the mineral development revenue projections for the period 

2003 to 2020 are projected levels of future energy and mineral resource 

production. The projected total value of annual mineral production under the 

lower coal production scenario will climb by $3.49 billion (2004 dollars) over 

2003 levels, reaching $8.54 billion by 2020, a 69 percent increase over the 

2003 value. The aggregate value of energy and mineral resource production 

under the upper coal production scenario would increase to $9.21 billion in 

2020. The incremental difference, compared to the value under the lower coal 

production scenario, would be $670 million per year, all of which represents 

the value of higher annual coal output. 

The overwhelming majority of future mineral production value is anticipated to 

be in Campbell County. Over time, the future value of production in Sheridan 

and Johnson counties would climb. Total annual mineral production value by 

2020 is projected to reach $6.37 billion in Campbell County and $2.17 billion 

in the surrounding counties. Between 2005 and 2020, total royalty and tax 

receipts derived from the key selected sources range between $21.1 and $22.6 

billion for the lower and upper coal production scenarios, respectively. 

Receipts derived from coal production would account for the majority of the 

totals under either scenario, with federal mineral royalties on coal at $4.9 to 

$5.7 billion being the single largest source. Severance taxes, ranging from $6.3 

to $6.7 billion, also would accrue to the state (Tables 4-35 and 4-36). 

Table 4-35. Summary of Mineral Development Tax Revenues Associated with 

Energy Resource Production Under the Lower Coal Production 

Scenario (million $). 

Industry and Taxes 2005-2010 2011-2015 2016-2020 Total 

Coal1 3,164.8 3,178.9 3,756.3 10,100.0 

CBNG 2,915.2 3,076.4 3,288.7 9,280.3 

Conventional Oil and Gas 568.5 576.4 614.0 1,759.0 

Totals 6,648.5 6,831.7 7,659.0 21,139.3 

Severance Tax 1,995.9 2,012.4 2,249.3 6,257.6 

Federal Mineral Royalties 2,754.1 2,839.4 3,166.3 8,759.8 

State Mineral Royalties 233.5 225.8 251.4 710.7 

Ad Valorem Tax 

(Counties) 

 417.6 443.0 502.8 1,363.3 

Ad Valorem Tax (Schools) 1,247.5 1,311.1 1,489.3 4,047.9 

Totals 6,648.6 6,831.7 7,659.1 21,139.3 1 Does not include coal lease bonus bids due to the uncertainty regarding timing. 

Source: PRB Coal Review Task 3C Report (BLM 2005f) 

The federal and state governments also benefit from coal lease bonus bids 

derived from future coal leasing. Bonus bids have risen over time, with 

successful bids for recent sales ranging from 30 cents per ton to 97 cents per 

ton. There is no guarantee of that trend continuing. Considerable uncertainty 

also exists with respect to the timing and scale of future leases, although BLM
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4-126 Final EIS, Wright Area Coal Lease Applications 

Table 4-36. Summary of Mineral Development Tax Revenues Associated with 

Energy Resource Production Under the Upper Coal Production 

Scenario (million $).

Industry and Taxes 2005-2010 2011-2015 2016-2020 Total1

Coal1 3,538.0 3,703.0 4,350.0 11,591.0 

CBNG 2,915.2 3,076.4 3,288.7 9,280.3 

Conventional Oil and Gas 568.5 576.4 614.0 1,759.0 

Totals 7,021.7 7,355.8 8,252.7 22,630.3 

Severance Tax 2,104.1 2,159.0 2,415.4 6,678.5 

Federal Mineral Royalties 2,946.3 3,099.9 3,461.4 9,507.6 

State Mineral Royalties 233.5 225.8 251.4 710.7 

Ad Valorem Tax (Counties) 435.8 472.0 535.0 1,442.8 

Ad Valorem Tax (Schools) 1,302.3 1,398.9 1,589.8 4,291.0 

Totals 7,022.0 7,355.6 8,253.0 22,630.6 

1 Does not include coal lease bonus bids due to the uncertainty regarding timing. 

Source: PRB Coal Review Task 3C Report (BLM 2005f) 

currently has pending applications for more than four billion tons of federal 

coal, including this application. The state receives 50 percent of the bonus bid 

revenue. 

Taxes and mineral royalties levied on energy and mineral resource production 

accruing to the state are disbursed to the Permanent Water Development Trust 

Fund, Wyoming School Foundation and Capital Facilities funds, capital 

construction fund for state and local government facilities, and other programs 

according to a legislatively-approved formula. Through these funds, the 

revenues derived from resource development benefit the entire state, not just 

agencies, businesses, and residents of the PRB. 

County governments and school districts would realize benefits from future 

energy and mineral resource development in the form of ad valorem taxes. 

Such taxes, estimated on the basis of future coal, oil, and natural gas 

production, are estimated to range between $5.4 billion and $5.7 billion 

through 2020. Those sums do not include future property taxes levied on the 

new power plants, expanded rail facilities, or new residential and commercial 

development associated with future growth, or sales and use taxes levied on 

consumer and some industrial purchases. These latter revenues are not 

estimated in this study, but would be substantially lower than those on 

resource production. 

Local governments would benefit from property taxes on new development, as 

well as from sales and use taxes on taxable sales within their boundaries. 

Such revenues are not estimated for this study due to the large number of 

jurisdictions and other analytical considerations. 

4.2.13.9 Social Setting

The past 30 years have seen sweeping social change in the U.S. and 

throughout much of the world. But in addition to the broad forces that have 
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Final EIS, Wright Area Coal Lease Applications 4-127 

driven social change in the U.S. as a whole, social conditions in some PRB 

communities have been substantially influenced by energy development. 

Factors that have affected social conditions in the PRB include industrial and 

natural resource development, economic and demographic change, housing 

and public infrastructure development, and institutional change at the local 

and state government levels. 

One of the key drivers of social change in the PRB has been energy-related 

population growth. When the first oil boom occurred in the late 1950s, 

Campbell County was a relatively stable, sparsely-populated rural county. Like 

many places in Wyoming and throughout the rural west, Campbell County was 

a small, relatively homogeneous ranching community (ROMCOE 1982). The oil 

booms of the 1950s and 1960s brought an influx of new people. Development 

of coal mines, continued oil and gas drilling, and power plant construction 

precipitated another round of growth. In all, Campbell County population grew 

by almost 600 percent between 1950 and 2000. 

On the one hand, this population growth, combined with a robust economy, 

generated a variety of positive social effects. Financial and technical resources 

poured into the community as it mobilized to accommodate the new 

population. Job opportunities were created in the construction industry, as 

the community responded to demands for housing, public facilities, and retail 

goods and services. The large and rapid influx of new residents, eager to take 

advantage of the employment opportunities, created energy, vitality, and a 

sense of economic optimism about the community. Where economic 

advancement had been limited before the boom, there was now opportunity 

(Gardiner 1985). 

On the other hand, it is likely that many residents had mixed feelings about 

these changes (Heinecke 1985). New residents brought new ideas, new ways of 

doing things, new preferences for goods and services, and new demands for 

government services. Some long-time residents, particularly those who were 

not directly participating in the economic benefits of energy development, 

viewed these changes as negative. 

Today, almost any organization, committee, or government body is made up of 

a cross-section of energy employees, ranchers, and other community members 

whose tenure in the community may be long or short (Bigelow 2004, Spencer 

2004). Moreover, because of the turnover in the energy companies, the 

community has become accustomed to newcomers. 

Cumulative energy development in the PRB through the year 2020 has the 

potential to generate both beneficial and adverse effects on community social 

conditions. Social effects of development activities in the PRB would vary from 

county to county and community to community under the coal production 

scenarios developed for this study, based on the existing social setting and the 

type of development that would occur. 
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4-128 Final EIS, Wright Area Coal Lease Applications 

Beneficial social effects would be associated with an expanding economy and 

employment opportunities associated with energy development and resulting 

improvements in living standards for those employed in energy-related 

industries. Adverse social effects could occur as a result of conflicts over land 

use and environmental values. Negative social effects also could occur if the 

pace of growth exceeds the abilities of affected communities to accommodate 

energy-related employees and their families with housing and community 

services. 

In the PRB, social conditions in Campbell County, the city of Gillette, and the 

town of Wright are most likely to be affected because the county would host 

much of the cumulative energy development workforce, and the county and its 

municipalities would receive the largest increments in population growth. 

Campbell County and its municipalities have a long history of energy 

development, and they have developed infrastructure and management 

systems to plan for and manage growth; consequently, major adverse social 

effects would not be anticipated. However, under either scenario, the county 

and the two municipalities may face challenges in providing adequate housing 

and expanding community services in anticipation of population growth 

through 2010, particularly if several power plant and coal mine construction 

projects occur simultaneously. As municipalities receive only sales and use tax 

revenues directly from development and purchases made within their 

boundaries, Gillette and Wright could face challenges in securing the necessary 

funding to improve municipal facilities and services. Housing shortages and 

limitations in public services could contribute to adverse community social 

effects in these communities. 

Many of the people who would immigrate to Campbell County for energyrelated jobs are likely to share characteristics with much of the current 

population; therefore, few barriers to social integration are anticipated. 

Social effects on other communities in the PRB are likely to be minimal to 

moderate. Energy-related population growth is anticipated to be moderate in 

other communities. Sheridan County, also familiar with coal mining, is the 

only other county anticipated to host a major construction project under the 

development assumptions used for either projected coal production scenario. 

Converse, Weston, and Crook counties could experience spillover growth from 

projects in Campbell County. 

Johnson, Sheridan, and Campbell counties could experience continued conflict 

over split estate and water issues associated with CBNG development, and the 

pace and scale of energy development across the PRB is likely to continue to 

generate social and political conflict over environmental issues under either 

coal production scenario. 
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Final EIS, Wright Area Coal Lease Applications 4-129 

4.2.14 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 or mining, the use is determined by the purchaser and the 

end user. 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 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 Alternative 1 (the No Action Alternative), from 2009 on, the Black 

Thunder Mine would be able to produce coal at an average production level of 

135.0 mmtpy for another 9.2 years, compared with an average of 135.0 mmtpy 

for 11.2 years under the Proposed Action, or an average of 135.0 mmtpy for 

another 14.0 years under Alternative 2 for the North Hilight Field LBA Tract 

(Table 2-2). The Black Thunder Mine would be able to produce coal at an 

average production level of 135.0 mmtpy for another 10.8 years under the 

Proposed Action, or an average of 135.0 mmtpy for another 11.5 years under 

Alternative 2 for the South Hilight Field LBA Tract (Table 2-4). The Black 

Thunder Mine would be able to produce coal at an average production level of 

135.0 mmtpy for another 12.0 years under the Proposed Action, or an average 

of 135.0 mmtpy for another 16.3 years under Alternative 2 for the West Hilight 

Field LBA Tract (Table 2-6). 

As discussed in Chapter 2, from 2009 on, the Jacobs Ranch Mine would be 

able to produce coal at an average production level of 40.0 mmtpy for another 

9.6 years under Alternative 1 (No Action Alternative), compared with an average 

of 40.0 mmtpy for 26.3 years under the Proposed Action, or an average of 40.0 

mmtpy for another 32.4 years under Alternative 2 for the West Jacobs Ranch 

LBA Tract (Table 2-8). 

As discussed in Chapter 2, under the currently approved mining plan, which 

represents Alternative 1 (No Action Alternative), from 2009 on, the North 

Antelope Rochelle Mine would be able to produce coal at an average production 

level of 95.0 mmtpy for another 9.9 years, compared with an average of 95.0 

mmtpy for 16.2 years under the Proposed Action, or an average of 95.0 mmtpy 

for another 17.7 years under Alternative 2 for the North Porcupine LBA Tract 

(Table 2-10). The North Antelope Rochelle Mine would be able to produce coal 

at an average production level of 95.0 mmtpy for another 13.2 years under the 

Proposed Action, or an average of 95.0 mmtpy for another 13.5 years under 

Alternative 2 for the South Porcupine LBA Tract (Table 2-12). 

Section 3.18.2 contains estimates of greenhouse gas emissions resulting from 

the specific mine operations at the three applicant mines (Black Thunder, 
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4-130 Final EIS, Wright Area Coal Lease Applications 

Jacobs Ranch, and North Antelope Rochelle) from projected operations under 

the Proposed Actions and alternatives over the life of the actions. 

4.2.14.1 Greenhouse Gas Emissions, Global Warming and Climate Change

Ongoing scientific research has identified the potential impacts of 

anthropogenic (man-made) greenhouse gas (GHG) emissions and changes in 

biological carbon sequestration due to land management activities on global 

climate. Although GHG levels have varied for millennia, recent 

industrialization and burning of fossil carbon sources have caused the carbon 

dioxide equivalent (CO2e) concentrations to increase in our lower atmosphere. 

As with any field of scientific study, there are uncertainties associated with the 

science of climate change. This does not imply that scientists do not have 

confidence in many aspects of climate change science. Some aspects of the 

science are known with virtual certainty, because they are based on wellknown physical laws and documented trends (EPA 2008a). However, the 

science is not settled and there is strong debate among the scientific 

community that natural variability is the overwhelming factor influencing 

climate rather than the accumulation of anthropogenic GHG emissions in the 

atmosphere. 

The National Assessment of the Potential Consequences of Climate Variability 

and Change, an interagency effort initiated by Congress under the Global 

Change Research Act of 1990, Public Law 101-606, has confirmed that climate 

changes, while impacts in and of themselves, can affect other aspects of the 

environment. The Synthesis Report, the final part of the Fourth Assessment 

Report of the Intergovernmental Panel on Climate Change (IPCC) (available 

online at http://www.ipcc.ch), was released in preliminary form on November 

17, 2007. The Synthesis Report (Bernstein et al. 2007) summarizes the results 

of the assessment carried out by the three working groups of the IPCC. 

Observations and projections addressed in the 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 show that 

many natural systems are being affected by regional climate changes, 

particularly temperature increases.” 

The term global warming is commonly used to refer to surface air temperature 

changes that are a response to increasing atmospheric GHG concentrations, 

along with other climate-influencing factors (NOAA 2007). From 1850 to 

present, historic trend data show an increase of 1° Centigrade (C) (1.8° 

Fahrenheit) in global mean temperature. However, the warming is not 

expected to be uniform over the globe, nor is it expected to be the same during 

all seasons of the year. There have been extended periods (decades) where 

temperature has dropped or stayed constant. This historic warming over that 
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Final EIS, Wright Area Coal Lease Applications 4-131 

same period has caused sea levels to rise by about 20 centimeters on average, 

and has also resulted in changes in climate patterns on land. In some areas 

near the equator, temperatures have cooled by about 5°C, while closer to the 

poles, temperatures have risen by equal amounts (Hansen and Lebedeff 1987). 

In northern latitudes (above 24° N), temperature increases of nearly 1.2°C (2.1° 

Fahrenheit) have been documented since 1900. The IPCC Fourth Assessment 

Report found that the “...projected warming in the 21st century shows scenarioindependent geographical patterns similar to those observed over the past 

several decades. “Warming is expected to be greatest over land and at most 

high northern latitudes, and least over the Southern Ocean and parts of North 

Atlantic Ocean.” Observations and computer models agree that arctic surface 

air temperatures are warming twice as fast as the global average, which is due 

partly to what is called the ice-albedo feedback (albedo is a term used to 

describe the fraction of sunlight reflected by an object) (NOAA 2007). Because 

temperature is a part of climate, the phenomenon of global warming is both an 

element of and a driving force behind climate change. 

There has been, and continues to be, considerable scientific investigation and 

discussion as to the causes of the recent historic rise in global mean 

temperatures, and whether the warming trend will continue. Several activities 

contribute to the phenomena of climate change, including emissions of GHGs 

(especially carbon dioxide and methane) from fossil fuel development, large 

wildfires and activities using combustion engines; changes to the natural 

carbon cycle; and changes to radiative forces and reflectivity (albedo). It is 

important to note that GHG emissions will have a sustained climatic impact 

over different temporal scales (EPA 2008a). 

Solar variability may play a role in global climate change, though the 

magnitude of the influence of increased sun activity is not well understood. 

Physical aspects of the sun, like sunspots and solar radiation output, are 

known to vary over time. The intensity of energy from the sun has varied 

through time and has resulted in global temperature variation. 

Human population doubled to two billion from the period 1780 to 1930, then 

doubled again by 1974. The atmospheric concentrations of GHGs have 

increased as human populations have increased. More land and resources 

were used to provide for the needs of these populations. As human activities 

have increased, carbon-based fuels have been used to provide for those 

additional energy needs. Forests and vegetation were cleared in order to 

provide for food production and human use. 

Carbon dioxide (CO2), methane (CH4), water vapor (H2O), ozone (O3), and 

nitrous oxide (N2O) are recognized as the major GHGs, although there are other 

gases that are considered GHGs. These are called “greenhouse gases” because, 

when released into the atmosphere, they prevent the escape of reflected solar 

radiation and heat from the Earth’s surface. Through complex interactions on 

a regional and global scale, these GHG emissions and net losses of biological 

carbon sinks (i.e., forests) cause a net warming effect of the atmosphere, 
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4-132 Final EIS, Wright Area Coal Lease Applications 

primarily by decreasing the amount of heat energy radiated by the earth back 

into space. In this way, the accumulation of GHGs in the atmosphere exerts a 

“greenhouse effect” on the earth’s temperature. Like glass in a greenhouse, 

these gases trap radiation from the sun and act as an insulator around the 

Earth, holding in the planet’s heat. The present CO2 concentration of about 

385 parts per million (ppm) is about 30 percent above its highest level over at 

least the last 800,000 years. U.S. average temperature has increased by about 

2° Fahrenheit over the last 50 years, which is more than the global average 

temperature increase (U.S. Global Change Research Program 2009). 

According to the IPCC’s Synthesis Report (Bernstein et al. 2007): 

• “Global atmospheric concentrations of carbon dioxide, methane, and 

nitrous oxide 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 

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 U.S., 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.” 
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Final EIS, Wright Area Coal Lease Applications 4-133 

• “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.” 

The National Academy of Sciences has confirmed these findings, but also has 

indicated there are uncertainties regarding how climate change may affect 

different regions. Computer model predictions indicate that increases in 

temperature will not be equally distributed, but are likely to be accentuated at 

higher latitudes. Warming during the winter months is expected to be greater 

than during the summer, and increases in daily minimum temperatures is 

more likely than increases in daily maximum temperatures. Increases in 

temperatures would increase water vapor in the atmosphere, and reduce soil 

moisture, increasing generalized drought conditions, while at the same time 

enhancing heavy storm events. Although large-scale spatial shifts in 

precipitation distribution may occur, these changes are more uncertain and 

difficult to predict (EPA 2008a). 

Relatively steep elevation gradients between valley floors and adjacent 

mountain ranges in the western U.S. produce considerable geographic climate 

variability. Warm, dry, semiarid conditions are typical on valley floors; moist 

and cool conditions are typical in higher parts of mountain ranges. Different 

plant communities occur within specific elevation zones. There also have been 

patterns of historic climatic variation in these areas for more than 10,000 

years, during which plant communities gradually shift to higher or lower 

elevations depending on the direction of temperature and precipitation changes 

(Tausch et. al. 2004). 

Temperature changes can result in shifts of weather patterns (rainfall and 

winds), which may then affect vegetation and habitat. If global warming trends 

continue into the foreseeable future, Chambers (2006) and the 2008 report by 

the U.S. Climate Change Science Program (U.S. Climate Change Science 

Program 2008a) indicate that the following changes may be expected to occur 

in the West: 

• The amount and seasonal variability of precipitation will increase over 

most areas. IPCC (2001) climate model scenarios indicate that by 2100, 

precipitation will increase about 10 percent in summer, about 30 percent 

in fall, and 40 percent in winter. Less snowfall will accumulate in higher 

elevations, more precipitation will occur as rain, and snowmelt will occur 

earlier in the spring because of higher temperatures. 

• Streamflow patterns will change in response to reduced snowpacks and 

increasing precipitation. Peak flows in spring are expected to occur 

earlier and be of lower magnitude because of snowpack changes. Runoff 

from greater amounts of winter rainfall will cause higher winter flows. 
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4-134 Final EIS, Wright Area Coal Lease Applications 

Summer flows will be lower, but with higher variability depending on the 

severity of storm events. 

• Some populations of native plants, invasive species, and pests will 

expand. Increasing amounts of atmospheric carbon dioxide and 

precipitation during the growing season will provide favorable growth 

conditions for native grasses, perennial forbs, woody species, and 

invasive annuals such as cheatgrass. Insect populations also will likely 

increase because milder winter temperatures will improve reproduction 

and survival rates. 

• Fire frequency, severity, and extent will increase because of the increased 

availability of fine fuels (grasses, forbs, and invasives) and accumulation 

of fuels from previous growing seasons. Higher temperatures will extend 

the length of fire seasons. Expansion of pinyon-juniper species and 

increasing tree densities could increase the number of high severity 

crown fires. Higher rates of insect damage and disease also may increase 

fuel accumulations. 

• Sensitive species and overall biodiversity will be reduced. High-elevation 

habitats will shrink in area or disappear as lower-elevation plant 

communities expand. It is probable that some mammalian, avian, and 

other species that currently inhabit these high-elevation habitats may 

become extinct. Higher rates of disease and insect damage also may 

pose threats to other sensitive plant and animal species. 

Global climate models exist that project/predict future temperature changes 

under various scenarios. For example, atmospheric CO2 concentration 

increasing by 1 percent per year would be an idealized scenario. The 

sensitivity of any climate model is generally calculated as the amount of 

temperature change the model produces for a doubling of atmospheric CO2

concentration. Most recent models have sensitivities of more than 2°C for a 

doubling of CO2 concentration (U.S. Climate Change Science Program 2008b). 

Scenarios however cannot include unknowable events such as volcanic 

eruptions and variations in solar activity. Perhaps the single largest 

uncertainty in determining the climate sensitivity to either natural or 

anthropogenic changes is clouds; their effects on radiation and their role in the 

hydrological cycle (IPCC 2007). The rate of heat uptake by the oceans is also 

an uncertainty when considering climate responses on time scales shorter than 

100 years (U.S. Climate Change Science Program 2008b). Despite such 

uncertainties, models are however consistent in their prediction of climate 

warming under GHG increases (IPCC 2007). 

Climate change models cannot be used to predict future climate changes at 

any particular scale less than globally. According to IPCC’s Fourth Assessment 

Report (2007), there is considerable confidence that climate models provide 

credible quantitative estimates of future climate change, particularly at 

continental scales and above, but the changes projected by global models 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-135 

decreases at smaller scales. Models are becoming more comprehensive and 

sophisticated in representing observed climate and past climate changes; 

however, models continue to have significant limitations that lead to 

uncertainties in magnitude and timing, as well as regional details of predicting 

climate change (IPCC 2007). By taking the average of all models, known as the 

ensemble approach, a more accurate representation of the climate emerges 

(U.S. Climate Change Science Program 2008b). Global climate models are at 

this time imperfect and due to their uncertainties should not be used as a 

basis for public policy. 

4.2.14.2 Cumulative Effects of Combustion of PRB Coal by Power Plants

Historically, the coal mined in the PRB has been used as one of the sources of 

fuel to generate electricity in power plants located throughout the U.S. 

Relatively little PRB coal, about 2 percent, is burned in Wyoming. Wyoming 

PRB coal is shipped primarily nationwide. In 2005, Wyoming coal went to 35 

states besides Wyoming, although it can also be shipped overseas. The mines 

in the PRB have sold, and are expected to sell coal into the open coal market. 

Each mine’s ability to sell coal in this market will determine annual production 

rates at that mine. Historically, the coal buyers have been domestic electric 

producers, although the coal could be used in other coal applications and it 

has been exported. 

Coal sales are made on short term contracts, generally to individual power 

generators, or coal is sold on a spot market. This market is very dynamic and 

competitive. During the coal leasing EIS process, it is uncertain and 

speculative to predict who might purchase future PRB coal, how it would be 

used, and where the coal might be transported to. In the Northern American 

Electric Reliability Council (NERC) power regions where PRB coal is sold, coal 

use ranges from 74.2 percent in the upper Midwest, to 15.6 percent in the 

northeast U.S. (EPA 2007e). 

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 NERC, peak 

demand for electricity in the U.S. is expected to double in the next 22 years 

(Associated Press 2007). Many developing countries, including China and 

India, are also relying heavily on coal to meet their rapidly increasing power 

demands as coal is more economical and more available than other sources of 

electrical generation. 

The regulatory mechanisms proposed under the Climate Security Act of 2008, 

as well as the past regulation of pollutants under the CAA, are imposed at the 

point when coal is burned and converted to electric energy. Over 95 percent of 

coal produced in the PRB is sold in an open market where coal is purchased on 

short term contracts or spot prices based on a coal feed stock that is suitable 

for each buyer’s power generating facility. Coal production at any one mine is 

not tied in any predictable way over a period of time to any one power plant. 
4.0 Cumulative Environmental Consequences 

4-136 Final EIS, Wright Area Coal Lease Applications 

Power plant buyers attempt to buy coal from suppliers at the most economical 

prices that meet their needs. PRB coal has competed well in this market due to 

its low sulfur content, providing a way for electric generators to achieve acid 

rain reduction requirements. This makes it valuable in lowering sulfur dioxide 

(SO2) pollution, as well as competitive mining costs when compared to delivered 

costs of coal from other coal producing areas. 

Wyoming coal production has increased at a more rapid rate than other 

domestic coal. Coal coming out of the Wyoming PRB is mined using surface 

mining methods which are generally safer and less labor intensive than 

underground mining. Rural rangelands are the areas that are mainly mined; 

they are reclaimed according to WDEQ/LQD’s standards (see Section 3.9.4). 

PRB coal reserves are in thick seams, resulting in more production from areas 

of similar land disturbance, and lower mining and reclamation costs. 

Coal-fired power plants have been identified as principal sources of 

anthropogenic GHG emissions. Assuming that all coal produced from all coal 

mines in the Wyoming PRB would be burned to generate electricity; the amount 

of GHG emissions that could be attributed to that coal production can be 

estimated. This is done by relating the portion of coal mined in the PRB to the 

total emission of GHG from all coal mined in the U.S. It is assumed that all 

PRB coal is used for coal-fired electric generation as part of the total U.S. use of 

coal for electric generation. This gives an upper estimate of the GHG emissions 

resulting from the use of the total PRB coal production to produce electricity. 

U.S. coal production increased from 1,029.1 million tons in 1990, when the 

Powder River Federal Coal Region was decertified, to 1,161.4 million tons in 

2006, an increase of 12.9 percent (USDOE 2007a). Wyoming coal production 

increased from 184.0 million tons in 1990 to 444.9 million tons in 2006, an 

increase of 242 percent (Wyoming Department of Employment 1990 and 2006). 

The share of electric power generated by burning coal was consistently around 

50 percent during that time frame. Also, the percentage of total U.S. CO2

emissions related to coal consumption was consistently around 36 percent 

during that same time frame. The percentage of U.S. CO2 emissions related to 

the coal electric power sector increased from about 30 percent in 1990 to about 

33 percent in 2006 (USDOE 2009c). 

In 2008, the Wyoming PRB coal mines produced approximately 451.7 million 

tons of coal. Using factors derived from laboratory analyses, it is estimated 

that approximately 749.6 million metric tons (tonnes) of CO2 would be 

generated from the combustion of all of this coal (before CO2 reduction 

technologies are applied). This number is based on an average Btu value of 

8,600 per pound of Wyoming coal and using a CO2 emission factor of 212.7 

pounds of CO2 per million Btu (USDOE 1994). The estimated 749.6 million 

tonnes of CO2 represents approximately 35.3 percent of the estimated 2,125.2 

million tonnes of U.S. CO2 emission from coal combustion in 2008 (USDOE 

2009c). In 2008, Wyoming PRB mines accounted for approximately 38.5 

percent of the coal produced in the U.S. (USDOE 2009a). 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-137 

According to the U.S. Department of Energy (USDOE), Energy Information 

Administration’s (EIA’s) 2008 Emissions of Greenhouse Gases in the U.S. 

report (USDOE 2009c) and EIA’s 2008 U.S. Coal Report (USDOE 2009a): 

• CO2 emissions represent about 83 percent of the total U.S. greenhouse 

gas emissions. 

• Estimated CO2 emissions in the U.S. totaled 5,839.3 million tonnes in 

2008, which was a 1.5 percent decrease from 2006 (which was 5,928.7 

million tonnes). 

• Estimated CO2 emissions from the electric power sector in 2008 totaled 

2,359.1 million tonnes, or about 40.6 percent of total U.S. energy-related 

CO2 emissions in 2008 (which was 5,814.4 million tonnes). 

• Estimated CO2 emissions from coal electric power generation in 2008 

totaled 1,945.9 million tonnes or about 33.5 percent of total energyrelated CO2 emissions and about 82.5 percent of CO2 emissions from the 

U.S. electric power sector in 2008. 

• Coal production from the Wyoming PRB represented approximately 43.4 

percent of the coal used for power generation in 2008, which means that 

combustion of Wyoming PRB coal to produce electric power was 

responsible for about 12.8 percent of the estimated U.S. CO2 emissions 

in 2008. 

As discussed earlier in this chapter, Task 2 of the PRB Coal Review projects 

coal development in the PRB into the future for the years 2010, 2015, and 

2020. Due to the variables associated with future coal production, two 

projected coal production scenarios (representing an upper and a lower 

production level) were developed to bracket the most likely foreseeable regional 

coal production level. In the low scenario, the percentage of coal use for 

electric generation would stay about the same, assuming that all forms of 

electric generation would grow at a proportional rate to meet forecast electric 

demand. In the high scenario, percentage of coal use would also remain about 

the same, but with PRB coal displacing coal from other domestic coal regions. 

Table 4-37 shows the estimated annual CO2 emissions that would be produced 

from the combustion of all of this coal (before CO2 reduction technologies are 

applied). 

In the following analysis, the contribution of the pending LBAs (Table 1-2) to 

cumulative effects on the environment by historic and projected development 

activity is evaluated. To do this, it is assumed that coal mining will proceed in 

accordance with existing permit conditions. It is further assumed that this 

coal will be sold to coal users in response to forecasts of demand for this coal. 

Historically these users have been electric utilities in the U.S., although there 

is potential for sales outside the U.S. This coal market is open and competitive 

and users can buy from the most cost effective suppliers that meet their needs. 
4.0 Cumulative Environmental Consequences 

4-138 Final EIS, Wright Area Coal Lease Applications 

Table 4-37. Estimated Annual CO2 Emissions from Projected PRB Coal 

Production Levels According to Task 2 or the PRB Coal Review1.

Projected Coal 

Production Scenario Year 

Coal Production Rate 

(million tons per year) 

CO2 Emissions 

(million tonnes per year)

2010 411 682 

Lower 2015 467 775 

2020 495 821 

2010 479 795 

Upper 2015 543 901 

2020 576 956 

1 BLM 2005a 

The BLM does not determine the destination of this coal, and the use of the 

coal is determined by the coal consumer. The electric utilities where this coal 

has historically been used are throughout the U.S., and have a variety of coal 

combustion technologies and emission control, but all are licensed by the 

appropriate regulatory authorities in their locale, and operate under necessary 

permit requirements, and in compliance with regulation. 

Table 4-38 shows the estimated cumulative annual CO2e emissions produced 

by all mines in the PRB that currently have LBAs pending (listed in Table 1-2). 

The cumulative emissions calculated are those associated with the actual 

mining operations and not from the combustion of the coal produced and sold 

on the open coal market. The LBA tracts are addressed individually in the 

following EISs: the South Gillette Area Coal (SGAC) Lease Applications FEIS 

(BLM 2009g), the Wright Area Coal (WAC) Lease Applications EIS (this 

document), the West Antelope II Coal Lease Application FEIS (BLM 2008d), and 

the Hay Creek II Coal Lease Application DEIS (BLM 2010). Under the Proposed 

Actions and Alternatives 2 and 3, the three applicant mines (Black Thunder, 

Jacobs Ranch, and North Antelope Rochelle) anticipate producing coal included 

in the North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs 

Ranch, North Porcupine, and South Porcupine LBA Tracts at or less than 

currently permitted levels using existing production and transportation 

facilities. Estimates of greenhouse gas emissions resulting from the specific 

mine operations at the Black Thunder, Jacobs Ranch, and North Antelope 

Rochelle mines from projected operations under the Proposed Actions and 

alternatives are also included in Section 3.18.2. 

The CO2 emissions related to burning coal that is produced from the three 

applicant mines to generate electricity would be extended as a result of leasing 

and mining the WAC LBA tracts. Table 4-39 shows the estimated annual coal 

production of each of the three applicant mines and the related annual CO2

emissions that would be produced from the combustion of the coal produced 

from each of the six WAC LBA tracts as applied for and as reconfigured under 

Alternative 2 (BLM’s preferred alternative), if this coal is burned to generate 

electric power. The total contribution of CO2 emissions that would be produced 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-139 

Table 4-38. Estimated Annual CO2 Equivalent Emissions* from Coal 

Production at PRB Mines With Pending LBAs.

Source 2007 With LBA Tracts 

Four SGAC Mines/Four LBA Tracts 0.716 1.182 

Three WAC Mines/Six LBA Tracts 1.245 2.503 

Antelope Mine/West Antelope II Tract 0.225 0.348 

Buckskin Mine/Hay Creek II Tract 0.197 0.197 

Total 2.535 4.229 

* CO2e in million metric tons (tonnes) 

Source: BLM 2008g, J&S 2009, WWC 2009

from the combustion of all the coal produced from each tract, if this coal is 

burned to generate electricity, are shown in Table 4-39. A scenario resulting in 

the maximum possible annual CO2 emissions from burning the coal produced 

from the WAC LBA tracts would occur assuming all six tracts were leased 

under Alternative 2, and that coal removal from all six tracts were to be 

sequenced to maintain each of the three applicant mines at full permitted 

production until the new reserves were fully depleted. Under this scenario, the 

Black Thunder Mine would be able to extend production for 14.2 years, the 

North Antelope Rochelle Mine for 11.4 years, and the Jacobs Ranch Mine for 

22.8 years. 

It is not possible to accurately project the level of CO2 emissions that burning 

the coal from the six WAC LBA tracts would produce due to the uncertainties 

about what emission limits would be in place at that time or where and how 

the coal in these LBA tracts would be used if they are leased and the coal is 

mined. Furthermore, the rate of mining and the timing of when coal removal 

from the tracts would actually begin are only the applicant mines’ best 

estimate. As shown in Tables 2-2 through 2-13, under the No Action 

alternatives the mines are projecting that after 2008 approximately 10 to 11 

years of currently permitted mine life remains. Therefore, coal removal from 

these six proposed maintenance lease tracts would not begin until 

approximately 2018 or 2019. More rapid improvements in technologies that 

provide for less CO2 emissions, new CO2 mitigation requirements, or an 

increased rate of voluntary CO2 emissions reduction programs could result in 

significantly lower CO2 emissions levels than are projected here. 

The three WAC applicant mines produced 228.3 million tons of coal in 2008, 

which represents about 50.5 percent of the coal produced in the Wyoming PRB 

in 2008. Combustion of those 228.3 million tons of coal to produce electricity 

produced approximately 378.7 million tonnes of CO2 emissions, or about 5.4 

percent of the total estimated anthropogenic CO2 emissions produced in the 

U.S. in 2008, which was approximately 7,052.6 million tonnes (USDOE 2009c). 

Under the No Action Alternative, CO2 emissions attributable to burning coal 

produced by the Black Thunder, Jacobs Ranch, and North Antelope Rochelle 

mines would be extended at about this level for up to approximately 10 years 
4.0 Cumulative Environmental Consequences 

 4-140 Final EIS, Wright Area C

Table 4-39. Estimated Annual CO2 Emissions Produced from Combustion of Coal Produced from 

CO2 Emissions 

Added by 

Proposed Action2

(million tonnes) 

Applicant Mine/ LBA Tract 

Anticipated 

Average 

Annual Coal 

Production by 

Applicant 

Mine1

(mmtpy) 

CO2 Emissions 

Related to 

Annual Coal 

Production2

(million 

tonnes) 

Recoverable 

Coal Added 

Under 

Proposed 

Action1

(mmt) 

Mine Life 

Added 

Under 

Proposed 

Action1

(years) 

Total 

per 

LBA 

Tract 

Average 

per 

Year 

Recoverable 

Coal Added 

Under 

Alternative 

21

(mmt) 

Mine 

Ad

Un

Altern

2

(ye

Black Thunder/ North Hilight Field 135 224.0 263.4 2.0 437.1 218.5 652.8 4Black Thunder/ South Hilight Field 135 224.0 213.6 1.6 354.4 221.5 304.3 2Black Thunder/ West Hilight Field 135 224.0 377.9 2.8 626.9 223.9 965.2 7Jacobs Ranch/ West Jacobs Ranch 40 66.4 669.6 16.7 1,110.9 66.5 912.6 22North Antelope Rochelle/ North Porcupine 95 157.6 601.2 6.3 997.4 158.3 745.4 7North Antelope Rochelle/ South Porcupine 95 157.6 309.7 3.3 513.8 155.7 339.3 31 Anticipated coal production rates at each applicant mine, coal tonnages within each LBA tract, and anticipated mine life 

addressed in Chapter 2. 

2 Determined using emission factor of 1.659 tonnes CO2/ton of coal burned (USDOE 1994). 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-141 

beyond 2008, while the mines recover their remaining estimated 2,483 million 

tons of currently leased coal reserves. 

It is not likely that selection of the No Action alternatives would result in a 

decrease of U.S. CO2 emissions attributable to coal mining and coal-burning 

power plants in the longer term, because there are multiple other sources of 

coal that, while not having the cost, environmental, or safety advantages, could 

supply the demand for coal beyond the time that the Black Thunder, Jacobs 

Ranch, and North Antelope Rochelle mines complete recovery of the coal in 

their existing leases. 

In 2006, transportation sources accounted for approximately 29 percent of 

total U.S. GHG emissions (EPA 2008b). Transportation is the fastest growing 

source of U.S. GHGs, accounting for 47 percent of the net increase in total U.S. 

emissions since 1990. Transportation is also the largest end-use source of 

CO2, which is the most prevalent GHG (EPA 2008b). Transportation is also the 

largest end-use source of CO2, which is the most prevalent anthropogenic GHG 

(EPA 2008b, NOAA 2007). 

Carbon dioxide is not the only GHG of concern. Another GHG, methane, in the 

form of coal bed natural gas (CBNG), is released into the atmosphere when coal 

is mined. The other major sources of U.S. methane emissions are from 

agriculture and waste management. According to the EIA (USDOE 2009a and 

2009c): 

• U.S. anthropogenic methane emissions totaled 722.7 million tonnes 

CO2e in 2007 and 737.4 million tonnes CO2e in 2008. 

• U.S. 2008 methane emissions from coal mining were estimated at 82.0 

million tonnes CO2e, which represents approximately 11.1 percent of the 

U.S. total anthropogenic methane emissions in 2008. 

• Surface coal mining operations in the U.S. were estimated to be 

responsible for methane emissions of about 15.7 million tonnes of CO2e 

in 2008, which represents about 2.1 percent of the estimated U.S. 

anthropogenic methane emissions in 2008, and about 19.1 percent of the 

estimated methane emissions attributed to coal mining of all types. 

• The Wyoming PRB produced approximately 55.5 percent of the coal 

mined in the U.S. in 2008 using surface mining techniques, which 

means that Wyoming PRB surface coal mines were responsible for 

approximately 1.17 percent of the estimated U.S. anthropomorphic 

methane emissions in 2008. The three applicant mines (Black Thunder, 

Jacobs Ranch, and North Antelope Rochelle) contributed about 50.5 

percent of the Wyoming PRB production in 2008, which is the equivalent 

of about 4.4 million tonnes CO2e vented methane emissions. It should 

be noted that the estimated amount of annual methane emissions vented 

from the applicant mines based on the gas content analyses of local coal 
4.0 Cumulative Environmental Consequences 

4-142 Final EIS, Wright Area Coal Lease Applications 

cores (Section 3.18.2) is more than 20 times less than this estimate that 

is based on EIA’s 2009 report (USDOE 2009c). 

Since 1990, when BLM began leasing using the lease by application (LBA) 

process, total U.S. anthropogenic methane emissions declined from 783.5 

million tonnes CO2e to 737.4 million tonnes CO2e in 2008. Total coal mining 

related emissions declined from 106.4 million tonnes CO2e to 82.0 million 

tonnes CO2e during the same time period. The EIA 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 (USDOE 2009c). 

CBNG is currently being commercially produced on a large scale by oil and gas 

operators from wells located within and near the WAC LBA tracts. CBNG that 

is not recovered prior to mining would be vented to the atmosphere during the 

mining process. Selection of the No Action alternatives would potentially allow 

more complete recovery of the CBNG from the six WAC LBA tracts in the short 

term (roughly 10 years), during the time that the three applicant mines’ 

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 2 or 3 (a complete discussion is included in Section 3.3.2.1.2.1). 

Selection of the No Action alternatives 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 Black Thunder, Jacobs Ranch, and North Antelope 

Rochelle mines recover the coal in their existing leases. 

Nitrous oxide (N2O) is the one other GHG of concern that is associated with 

coal mining; however, the largest source in the U.S. is agricultural (about 76 

percent comes from fertilization of soils and about 24 percent from 

management of animal waste) (USDOE 2009c). 

Specific levels of significance have not yet been established for GHG emissions, 

and given the current state of science, it is not yet possible to associate specific 

actions with the specific climate impacts. As a consequence, impact 

assessments of effects of specific anthropogenic activities cannot be performed. 

Tools necessary to quantify incremental climatic changes associated with these 

GHG emission estimates for the projected coal mine development activities in 

the PRB are presently unavailable. Technology to conduct such an analysis at 

this spatial and temporal scale simply does not exist; therefore, conclusions as 

to the magnitude or significance of the emissions on climate change cannot be 

reached. The impacts of climate change represent the cumulative aggregation 

of all worldwide GHG emissions, land use management practices, and the 

albedo effect. The analysis does provide a meaningful context and measure of 

the relative significance of coal use from the overall projected PRB coal 

production on total GHG emissions. Therefore, climate change analysis in this 

EIS is limited to accounting for and disclosing of factors that contribute to 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-143 

climate change. To the extent that emission data were available or could be 

inferred from representative type data, potential GHG emissions that could 

result from development of the pending LBA tracts in the PRB (Table 1-2) have 

been identified, as well as emissions that would result from selection of the No 

Action alternatives. 

Although the effects of GHG emissions and other contributions to climate 

change in the global aggregate are estimable, given the current state of science 

it is impossible to determine what effect any given amount of GHG emissions 

resulting from an activity might have on the phenomena of global warming, 

climate change, or the environmental effects stemming from it. It is therefore 

not currently possible to associate any particular action and its specific 

project-related emissions with the creation or mitigation of any specific climaterelated effects at any given time or place. However, it is known that certain 

actions may contribute in some way to the phenomenon (and therefore the 

effects of) climate change, even though specific climate-related environmental 

effects cannot be directly attributed to them. 

4.2.14.3 U.S. Actions and Strategies to Address Greenhouse Gas Emissions

Potential regulatory policies to address climate change are in various stages of 

development at the federal, state, and regional levels (USDOE 2009b). A 

number of bills have been introduced in the U.S. Congress related to global 

climate change. At this time, there is no national policy or law in place that 

regulates GHG emissions. 

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 within the United States. In short, the “cap” 

would set a legal limit on the quantity of greenhouse gases that a region can 

emit each year and “trade” would allow companies to exchange the permission 

– or permits – to emit greenhouse gases. The cap would get tighter over time, 

until by 2050, emissions would be reduced by 63 percent below 2005 levels. 

The bill was approved by the Senate Environment and Public Works Committee 

in December, 2007 (http://www.pewclimate.org, accessed 12/21/2007). The 

bill was introduced in the Senate and read the first time on May 20, 2008. The 

Boxer-Lieberman-Warner substitute amendment to the Climate Security Act of 

2008 was subsequently released by the Senate Environment and Public Works 

Committee on May 21, 2008. The bill was then read a second time and placed 

on the Senate Legislative Calendar under General Orders, Calendar No. 742. 

In June 2008 the U.S. Senate voted to invoke cloture on the Boxer amendment 

but did not pass the cap-and-trade legislation. 

On June 26, 2009, the U.S. House of Representatives passed The American 

Clean Energy and Security Act of 2009. The legislation includes a federal GHG 

emissions cap-and-trade program that would take effect in 2012. The declining 

emissions cap requires that total GHG emissions be 17 percent below 2005 

levels by 2020 and 83 percent below 2005 levels by 2050. In November 2009, 
4.0 Cumulative Environmental Consequences 

4-144 Final EIS, Wright Area Coal Lease Applications 

the Senate Environment and Public Works Committee passed a GHG cap-andtrade bill that borrows much from the House American Clean Energy and 

Security Act and tightens the GHG emissions cap to 20 percent below 2005 

levels by 2020. Several other committees are expected to weigh in before the 

final bill is crafted and brought before the Senate floor (USDOE 2009c). 

On April 2, 2007, in Massachusetts v. EPA, the U.S. Supreme Court found that 

GHGs are air pollutants covered by the Clean Air Act (CAA). The Court held 

that the Administrator of the EPA must determine whether or not emissions of 

GHGs from new motor vehicles cause or contribute to air pollution which may 

reasonably be anticipated to endanger public health or welfare, or whether the 

science is too uncertain to make a reasoned decision. At that time, the court 

directed EPA to review the latest science on climate change in order to make a 

determination. On April 17, 2009, the Administrator signed Proposed 

Endangerment and Cause or Contribute Findings for Greenhouse Gases under 

Section 202(a) of the CAA. On December 7, 2009, the Administrator signed two 

distinct findings regarding GHGs under Section 202(a) of the CAA. The 

Administrator finds that the current and projected concentrations of the six 

key well-mixed greenhouse gases—carbon dioxide (CO2), methane (CH4), 

nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and 

sulfur hexafluoride (SF6)—in the atmosphere threaten the public health and 

welfare of current and future generations and that the combined emissions of 

these well-mixed GHGs from new motor vehicles and new motor vehicle engines 

contribute to climate change. The findings do not in and of themselves impose 

any emission reduction requirements but rather allow EPA to finalize the GHG 

standards proposed earlier in 2009 (EPA 2009c). The agency is now poised to 

regulate CO2 as a pollutant, and the findings allow EPA to begin regulating 

GHG emissions from power plants, factories and major industrial polluters, 

although the precise details of that regulation have yet to be worked out. An 

endangerment finding under one provision of the CAA would not by itself 

automatically trigger regulation under the entire Act. 

As a result of the Supreme Court’s decision in 2007, the EPA drafted the 

Prevention of Significant Deterioration/Title V Greenhouse Gas Tailoring Rule. 

The draft rule, published in the Federal Register on October 27, 2009, limits 

the applicability of CO2 emissions standards to new and modified sources that 

emit more than 25,000 tonnes CO2e annually, rather than applying the 

threshold of 250 tons per sources for triggering the regulation of criteria 

pollutants specified in Title V of the CAA. At the 25,000 tonnes CO2e annual 

level, the EPA expects that 14,000 large industrial sources, which are 

responsible for 70 percent of the U.S. GHG emissions, will be required to obtain 

Title V operating permits. That threshold would cover large power plants, 

refineries, and other large industrial operations (USDOE 2009c). 

EPA has issued the Final Mandatory Reporting of Greenhouse Gases Rule (EPA 

2010). The rule requires reporting of GHG emissions from large sources and 

suppliers in the U.S., and is intended to collect accurate and timely emissions 

data to inform future policy decisions. Under the rule, suppliers of fossil fuels 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-145 

or industrial greenhouse gases, manufacturers of vehicles and engines, and 

facilities that emit 25,000 tonnes or more per year of GHG emissions are 

required to submit annual reports to EPA. The gases covered by the proposed 

rule are carbon dioxide, nitrous oxide, methane, hydrofluorocarbons, 

perfluorocarbons, sulfur hexafluoride, and other fluorinated gases including 

nitrogen trifluoride (NF3) and hydrofluorinated ethers (HFE). The final rule was 

signed by the Administrator on September 22, 2009. EPA’s new reporting 

system will provide a better understanding of where GHGs are coming from 

and will guide development of the best possible policies and programs to 

reduce emissions. Reporters must begin to monitor their emissions on 

January 1, 2010 and the first annual emissions reports will be due in 2011 

(EPA 2010). 

The American Recovery and Reinvestment Act of 2009 (“The Stimulus Bill”) was 

signed into law by President Obama on February 17, 2009, and under the Act, 

the U.S. DOE received $36.7 billion to fund renewable energy, carbon capture 

and storage, energy efficiency, and smart grid projects, among others. The 

projects are expected to provide reductions in both energy use and GHG 

emissions (USDOE 2009c). 

Federal, state, and local governments are also developing programs and 

initiatives aimed at reducing energy use and emissions. The 2002 Clear Skies 

and Global Climate Change Initiative is a voluntary national program to reduce 

greenhouse gas emissions. There are federal tax incentives for energy 

efficiency and conservation, and some states have renewable energy and energy 

efficiency policies. Regional initiatives have been started in the northeast 

(Northeast Regional Greenhouse Gas Initiative) as well as the Western Climate 

Initiative in the western states. At this time, it is not possible to predict how all 

of these programs would be melded into a national regulatory process if one 

were to be enacted. 

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 (NARUC 2007). There is uncertainty about 

anticipated CO2 emission limits and carbon capture/sequestration regulations. 

This has caused some proponents to cancel or delay their proposed projects 

that use existing and emerging technologies to produce electricity from coal 

(Casper Star Tribune 2007c). Capacity planning decisions for new generating 

plants and investment behavior in the electric power sector are being affected 

by the potential impacts of policy changes that could be made to limit or 

reduce GHG emissions (USDOE 2009b). 

4.2.14.4 Current and Future Energy Sources and Emissions of Greenhouse 

Gases in the U.S.

The key determinant of energy consumption is population. Population 

influences demand for goods, services, housing, and travel. In the U.S. the 

population has increased by about 20 percent and energy consumption by a 
4.0 Cumulative Environmental Consequences 

4-146 Final EIS, Wright Area Coal Lease Applications 

comparable 18 percent since 1990, with variations in energy use per capita 

depending on factors such as weather and the economy. To meet the 

nationwide consumer demand and requirement for energy, coal is burned in 

power plants to produce electricity. Coal is an important component of the 

U.S. energy supply partly because it is the most abundant domestically 

available fossil fuel (USGS 2002b). One-quarter of the world’s coal reserves are 

found within the U.S.; the energy content of U.S. coal resources exceeds that of 

all the world’s known recoverable oil; and coal resources supply more than half 

of the electricity consumed by Americans (USDOE 2008 and 2009d). Many 

countries are even more reliant on coal for their energy needs than is the 

United States. More than 70 percent of the electricity generated in China and 

India comes from coal (USGS 2000). The value of coal is partially offset by the 

environmental impacts of coal combustion (USGS 2000). 

In the USDOE 2007 Annual Energy Outlook, energy-related CO2 emissions 

were projected to grow by about 35 percent from 2006 to 2030 (USDOE 2007b). 

By comparison, the USDOE 2008 Annual Energy Outlook projected energyrelated CO2 emissions to grow by 16 percent, from 5,890 million tonnes in 

2006 to 6,851 million tonnes in 2030 (USDOE 2008). However, USDOE’s 2009 

Annual Energy Outlook projects energy-related CO2 emissions to grow by 7 

percent, from 5,991 million tonnes in 2007 to 6,414 million tonnes in 2030. 

The mix of sources for these generation projections include coal, natural gas, 

nuclear, liquids (petroleum), hydro-power, and non-hydro renewables (wind, 

solar, etc.). The most recent, lower projected emissions growth rate is due to a 

slower demand growth combined with increased use of renewables and a 

declining share of electricity generation that comes from fossil fuels (USDOE 

2009b). 

Total U.S. anthropogenic GHG emissions in 2008 were 2.2 percent below the 

2007 total. The decline in total emissions–from 7,209.8 million tonnes CO2e in 

2007 to 7,052.6 million tonnes in 2008–was largely the result of a 177.8 

million tonne CO2e drop in CO2 emissions. There were small percentage 

increases in emissions of other GHGs, but those increases were more than 

offset by the drop in CO2 emissions. The decrease in U.S. CO2 emissions in 

2008 resulted from higher energy prices, economic contraction, and lower 

demand for electricity (USDOE 2009c). 

Energy-related CO2 emissions dominate (about 81 percent in 2008) the total 

U.S. GHG emissions. Petroleum is the largest fossil fuel source for energyrelated CO2 emissions, contributing 41.9 percent of the total, whereas coal is 

the second-largest fossil fuel contributor, at 36.5 percent. Petroleum made up 

44.6 percent of total fossil fuel energy consumption in 2008, as compared with 

coal’s 26.8 percent. Natural gas accounted for 28.5 percent of the fossil fuel 

energy use in 2008, but only 21.4 percent of total energy-related CO2 

emissions. Energy-related CO2 emissions account for 98 percent of the total 

U.S. CO2 emissions (USDOE 2009c). 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-147 

The U.S. emits about 1,900 million tonnes annually from coal-fired power 

plants−33 percent of total energy-related CO2 emissions and 81 percent of CO2

emissions from the U.S. electric power sector (USDOE 2009c). If public 

sentiment results in changed electric demand, or if GHG emissions are 

ultimately regulated, the demand forecast for coal for electric generation could 

change. The potential impacts of policy changes that could be made to limit or 

reduce GHG emissions is affecting planning decisions for new power plants, 

particularly with respect to new coal-fired capacity. 

To assess the national electric generation portfolio and the mix of future 

electric generation technologies, BLM reviewed the Annual Energy Outlook 

2010 Report (USDOE 2009e). An independent study representing a forecast to 

the year 2035, it examined the ability of the domestic electric generation 

industry to alter the present electric generation portfolio (mix of electric 

generation technologies). This report compares the 2035 projection to the 

electric generation mix that existed in 2008. This most recent report 

incorporates the 2009 downturn in electric demand, which resulted from 

lowered electric demand for manufacturing in the depressed domestic economy 

of 2009. This forecast estimated the percentage of coal-fired electric generation 

in the domestic electric generation portfolio at 44 percent by 2035, based on a 

slowing in electric demand through 2035, and a doubling, to 17 percent, of 

renewable electric generation in the domestic electric generation portfolio by 

2035. Based on this study, even with a considerably more optimistic projection 

for renewable sources, coal use continues to be projected as the largest portion 

of the domestic electric fuel mix. 

Technologies for producing cleaner, more efficient and more reliable power from 

coal are currently available and are being improved. These include advanced 

pulverized coal, circulating fluidized bed, coal gasification or Integrated 

Gasification Combined Cycle (IGCC), and carbon sequestration or carbon 

capture and storage (CCS) technologies. Systems that utilize carbon capture 

technologies are being developed to capture at least 90 percent of emitted CO2, 

which would be stored within geological formations (i.e., oil and gas reservoirs, 

saline formations, unmineable coal seams). These technologies are not yet 

commercially established due to extremely high capital costs and low system 

reliability, which are the biggest obstacles to integration of these technologies 

into the power market. However, regulatory uncertainties are affecting 

planning decisions, for example, unless new coal-fired power plants are 

equipped with CCS equipment they could incur higher costs as a result of 

higher expenses for siting and permitting. However, costs would not be directly 

affected by regulatory uncertainty for nuclear and renewable power plants 

because they do not emit GHGs (USDOE 2009c). 

The Electric Power Research Institute (EPRI) has also attempted to identify a 

scenario of how the full portfolio of technologies to provide for electric energy 

would respond if national policy were to require that CO2 emissions be reduced 

to 1990 levels (James 2007). EPRI updated this research in an October 2009 
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4-148 Final EIS, Wright Area Coal Lease Applications 

report, The Power to Reduce CO2 Emissions: The Full Portfolio (EPRI 2009), 

which used the EIA’s Annual Energy Outlook 2009 Report for comparison. 

The EPRI study predicts that national policy that forces a reduction of CO2

emissions to 1990 levels would promote increased energy efficiency, and the 

growth of “non carbon” sources such as nuclear and renewable. Renewable 

sources include wind and solar, as well as emerging technologies like tidal 

power, river turbines and others reported in the media. Hydropower is limited 

because most opportunities for hydropower have been used or require large 

infrastructure. Use of carbon based sources such as natural gas and 

petroleum are less than forecasted by the USDOE EIA, while coal use remains 

about the same in the EPRI forecast, mostly due to forecasted improvement in 

GHG emission reduction in coal-fueled generation. Both EIA and EPRI forecast 

increases in electricity cost. 

Figure 4-13 shows the current (2008) electric generation mix, compared to the 

2035 EIA forecast (USDOE 2009e) as well as the older 2030 EPRI forecast 

(EPRI 2009). Both forecasts are consistent that the amount of electric 

generation fueled by coal is expected to drop from nearly fifty percent of the 

total presently to about 40 percent of the total in future years. Coal is forecast 

to remain as the major electric generation component until at least 2035. 

Renewable energy (other than hydroelectric) and nuclear are forecast to 

increase, while natural gas and other fossil fuels (i.e., oil) are forecast to remain 

stable or decrease to a degree. 

In 2003 the USDOE initiated the FutureGen project−a commercial-scale coalfired power plant incorporating IGCC with CCS−thus being the first facility of 

its kind to combine and test several cutting-edge technologies. FutureGen is a 

public-private partnership between the USDOE and the FutureGen Alliance, a 

non-profit organization that represents some of the world’s largest coal 

producers and electric utilities, to build a first-of-its-kind coal-fired near-zero 

emissions power plant. The FutureGen Alliance and the USDOE reached an 

agreement in June 2009 to proceed with the project, which will be located at 

Mattoon, Illinois. The project proposes to produce electricity by turning coal 

into gas, remove impurities, extract CO2 from the waste stream, and then 

sequester the CO2 underground. The Alliance is responsible for design, 

construction, and operation of the facility, and USDOE is responsible for 

independent oversight and coordinating participation of international 

governments. USDOE’s financial contribution will come from the American 

Recovery and Reinvestment Act. The USDOE issued a NEPA Record of 

Decision (ROD) on July 14, 2009 to move forward toward the first commercial 

scale, fully integrated, carbon capture and sequestration project in the country 

(USDOE 2009f). The ROD allows the Alliance to proceed with site-specific 

activities, and over the following 8 to 10 months the project design, costs and 

funding plan will be refined. The USDOE and the Alliance will then decide in 

early 2010 whether to continue the project through construction and 

operation. When fully operational the FutureGen facility will produce 275 MW 
Current (2008)

(USDOE 2008)

2030 Forecast

(EPRI 2009)

2035 Forecast

(USDOE 2009e)

Other Fossil

(1.5%)

Renewable

(9.1%)

Nuclear

(19.6%)

Natural Gas

(21.4%)

Coal

(48.5%)

Renewable

(21%)

Nuclear

(28%)

Natural Gas

(13%)

Coal

(38%)

Other Fossil

(1.4%)

Renewable

(17.0%)

Nuclear

(17.1%)

Natural Gas

(20.8%)

Coal

(43.8%)

Figure 4-13. Current and Forecast Mix of Electric Generation Sources.

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Final EIS, Wright Area Coal Lease Applications 4-149
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4-150 Final EIS, Wright Area Coal Lease Applications 

of power and capture 90 percent of the carbon emissions; however, it may be 

operated at a 60 percent capture rate in the first 3 years to validate plant 

integration and sequestration capability, as well as manage the startup risks 

and costs. This technology should sequester a million tons of CO2 annually 

(USDOE 2009f). 

Other methods of generating electricity that result in fewer GHG emissions 

than burning coal include natural gas, nuclear, hydroelectric, solar, wind, and 

geothermal resources. 

Natural gas plays a key role in meeting U.S. energy demands. Natural gas, coal 

and oil supply about 85 percent of the nation’s energy, with natural gas 

currently supplying about 22 percent of the total. The percent contribution of 

natural gas to the U.S. energy supply is expected to remain fairly constant for 

the next 20 years. According to EIA’s 2010 Annual Energy Outlook (USDOE 

2009e), concerns about GHG emissions have little effect on construction of new 

capacity fueled by natural gas. 

Unconventional natural gas resources are expected to play a larger role in the 

demand for natural gas for electricity generation (USDOE 2009b and 2009e). 

Natural gas production from hydrocarbon rich shale formations, known as 

“shale gas” is one of the most rapidly expanding trends in onshore domestic oil 

and gas exploration and production today. Analysts estimate that by 2011, 

most new natural gas reserves will come from unconventional shale gas 

reservoirs (NETL 2009). From 2007 to 2030, domestic production of natural 

gas is expected to increase by 22 percent (USDOE 2009b). 

The nuclear share of power generation is projected by EPRI (2009) to increase 

to about 28 percent by 2030 as the addition of new power plants and upgrades 

at existing units increases overall capacity and generation, and the nuclear 

power share of total electricity generation remains somewhat constant at 17-19 

percent by 2035 according to EIA (USDOE 2009e). 

The share the nation’s total electricity generation from renewables (i.e., 

biomass-based diesel, hydroelectricity, geothermal, solar, wind, ethanol), 

supported by federal tax incentives and state renewable programs, is expected 

to increase from 9 percent in 2008 to 17 percent in 2035 (USDOE 2009e). 

EPRI (2009) is more optimistic with renewable sources reaching 21 percent by 

2030. 

The estimated cumulative CO2 emissions that would be produced annually 

from the conventional combustion of the coal produced from the six WAC LBA 

tracts, if they are all leased under either the Proposed Action or Alternative 2 

(Section 4.2.14.2) are based on the applicant mines’ projected future mining 

rates. Those estimates present a scenario that assumes the demand for coal in 

the future would not differ from current demand, technologies for producing 

cleaner, more efficient and more reliable power from coal (i.e., advanced 

pulverized coal, circulating fluidized bed, IGCC, and CCS) would not yet be 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-151 

commercially established, and an explicit federal policy has not been enacted to 

limit or reduce U.S. GHG emissions. However, if there is a strong shift toward 

natural gas, nuclear, and renewable power generation, as well as fossil 

technologies with CCS equipment, those estimates of CO2 emissions from the 

combustion of coal produced from the PRB would be lower than estimated in 

the prior discussion (Section 4.2.14.2). 

4.2.14.5 Mercury, Coal Combustion Residues, and Other By-Products

One of the concerns associated with burning coal for the production of 

electricity is the release of elements from coal to the environment (USGS 2000). 

When coal is burned, GHGs as well as mercury and other compounds and 

elements, including lead and cadmium, that may have direct or indirect effects 

on human health are released (EPA 2009d). The principal pollutants generated 

by coal combustion that can cause health problems are particulates, sulfur 

and nitrogen oxides, trace elements (including arsenic, fluorine, selenium, and 

radioactive uranium and thorium), and organic compounds generated by 

incomplete coal combustion (USGS 2000). 

In coal combustion, concentrations of these elements and compounds vary 

depending on the chemistry of the coal deposits and on the type of air pollution 

controls in place when the coal is burned. Coal use in developing countries 

can potentially cause serious human health impacts (USGS 2000). Some coal 

mined in China is known to have caused severe health problems in several 

local populations because the coal was mined and burned with little regard to 

its chemical composition (USGS 2000). Chinese coals that contained high 

levels of arsenic, fluorine, selenium, and polycyclic aromatic hydrocarbons 

have caused severe, life-threatening health impacts to some residents that 

burned the coal in unvented stoves in their homes (USGS 2000). 

Coal that is burned in the U.S. generally contains low to modest concentrations 

of potentially toxic trace elements and sulfur (USGS 2000). Specifically, PRB 

coal is recognized as being a clean burning coal due to its low sulfur and low 

ash properties. In a 2002 analysis conducted by USGS (2002b), PRB coal was 

found to contain, on average, approximately eight times less sulfur than coals 

being utilized from the Appalachian and Illinois basins to supply U.S. power 

plants (feed coal). PRB feed coal was also found to contain nearly half as much 

uranium (8.9 ppm), seven times less arsenic (17 ppm), five times less lead (19 

ppm), and three times less cadmium (1.1 ppm) as compared to Appalachian 

and Illinois basin feed coals. When burned, PRB coal produced, on average, 38 

percent less fly ash than Appalachian and Illinois basin coals (USGS 2002b). 

The fly ash resulting from combusted PRB coal contained approximately 39 

times less mercury than fly ash that was generated from combusted 

Appalachian and Illinois basin coal (USGS 2002b). 

Additionally, many U.S. coal burning power plants use sophisticated pollutioncontrol systems that efficiently reduce the emission of hazardous elements 

(USGS 2000). The EPA conducted a detailed study of possible health impacts 
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4-152 Final EIS, Wright Area Coal Lease Applications 

from exposure to emissions of approximately 20 potentially toxic substances 

from U.S. coal-burning power plants (USGS 2000). The EPA concluded that, 

with the exception of possibly mercury, there is no compelling evidence to 

indicate that emissions from U.S. coal-burning power plants cause human 

health problems (USGS 2000). 

Mercury is a naturally occurring element and enters the environment as a 

result of natural sources, such as active volcanoes, and through human 

activities such as industrial combustion and mining (EPA 2006). Natural 

sources of mercury, such as volcanic eruptions and emissions from the ocean, 

have been estimated to contribute about 33 percent of the current worldwide 

mercury air emissions; anthropogenic (human-caused) mercury emissions 

account for the remaining 67 percent, though these estimates are highly 

uncertain (EPA 2009e). 

When fossil fuels burn, mercury vapor can be released into the atmosphere 

where it may drift for a year or more, spreading with air currents over vast 

regions of the globe (USDOE 2006). In 1995, an estimated 5,500 tons of 

mercury was emitted globally from both natural and human sources, and coalfired power plants in the U.S. contributed to less than one percent of that total 

(USDOE 2006). 

Mercury is a global problem that knows no national or continental boundaries. 

It can travel thousands of miles in the atmosphere before it is eventually 

deposited back to the earth in rainfall or in dry gaseous forms. EPA estimates 

that about one-third of the U.S. anthropogenic mercury emissions are 

deposited within the contiguous U.S. and the remainder enters the global cycle 

(EPA 2009e). 

Table 4-40 summarizes how the various continents contributed to the 

worldwide anthropogenic mercury emissions in 2004. The 2004 U.S. 

anthropogenic mercury emissions were estimated to account for about three 

percent of the global total (EPA 2009e). EPA estimates that 83 percent of the 

mercury deposited in the U.S. originates from international sources, with the 

remaining 17 percent coming from the U.S. and Canada. These figures include 

mercury from natural and anthropogenic sources (EPA 2006). 

Table 4-40. 2004 Percent Contribution to Worldwide Anthropogenic 

Mercury Emissions. 

Continent Percent 

Asia 53 

Africa 18 

Europe 11 

North America 9 

Australia 6 

South America 4 

Source: EPA 2009e 
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Final EIS, Wright Area Coal Lease Applications 4-153 

In 2006, EPA estimated that 50-70 percent of current global anthropogenic 

atmospheric emissions came from fuel combustion, and much of it came from 

China, India, and other Asian countries. Coal consumption in Asia is expected 

to grow significantly over the next 20 years. This international source of 

mercury emissions may grow substantially if left unaddressed (EPA 2006). 

Over the past decade, addressing environmental and human health mercury 

risks has been a focus for EPA. Overall U.S. mercury air emissions have been 

reduced by 45 percent since 1990. EPA is most concerned with methyl 

mercury, a potent form of mercury and the form to which humans are 

primarily exposed (EPA 2006). 

Atmospheric mercury can settle into water or onto land where it can be washed 

into the water. Certain microorganisms can transform mercury into methyl 

mercury, a highly toxic mercury compound that builds up in fish and shellfish 

when they feed. Methyl mercury is the only form of mercury that biomagnifies 

in the food web. Concentrations of methyl mercury in fish are generally on the 

order of a million times the methyl mercury concentration in the water. The 

primary pathway of human exposure to mercury is through eating fish 

containing methyl mercury (EPA 2006). 

There are adverse health effects to humans and other animals that consume 

these fish and shellfish. Birds and mammals that eat fish may be more 

exposed to mercury more than other animals in water ecosystems (EPA 2008c). 

At high levels of exposure, methyl mercury’s harmful effects may include death, 

reduced reproduction, slower growth and development, and abnormal behavior 

(EPA 2008c). 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). 

The USDOE’s Office of Fossil Energy has been sponsoring studies on mercury 

emissions from coal-based power generators to identify effective and 

economical control options for the past decade. The Office of Fossil Energy 

manages the largest funded program in the U.S. for developing an 

understanding of mercury emissions and developing emission control 

technologies for the coal-fired electric generating industry in the U.S. (USDOE 

2006). Research on advanced and improved mercury control technology is 

ongoing. 

In the U.S., coal-burning power plants are the largest human-caused source of 

mercury emissions being released into the air, accounting for about 40 percent 

of all domestic human-caused mercury emissions (EPA 2008c). 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 1 

percent of the global total (EPA 2009e). 
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4-154 Final EIS, Wright Area Coal Lease Applications 

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 anthropogenic mercury emissions. The three applicant 

mines (Black Thunder, Jacobs Ranch and North Antelope Rochelle) produced 

about 45.4 percent of the coal produced in the Wyoming PRB in 2006, which 

would represent about 0.2 percent of the global mercury emissions. Under the 

No Action alternatives, mercury emissions attributable to burning coal 

produced by the three applicant mines would be extended at about current 

levels of up to approximately 11 years beyond 2008, while the mines recover 

their remaining leased coal reserves. Under the Proposed Actions or 

Alternatives 2 or 3, the three applicant mines contribution to global mercury 

emissions would be extended from about 1.6 to 22.8 additional years, 

depending on the tract and alternatives selected. Uncertainties about future 

regulatory requirements and the use of the coal mined from the six WAC LBA 

tracts make it difficult to project the impacts of mercury emissions produced by 

burning coal produced from these tracts. 

Additionally, 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. As previously 

referenced, coal and coal combustion residues can contain a variety of 

compounds, metals, and other elements depending on the coal deposit and 

upon the site-specific characteristics of where the coal originated from. Coalfired boilers are required to have control devices to reduce the amount of 

emissions that are released into the atmosphere (EPA 2007f). The use of air 

pollution control equipment at power plants has resulted in fewer emissions 

but has also increased 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 as part of the reclamation process. There can 

potentially be 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 that is not to be cited or quoted. 

As discussed above, the WAC applicant mines produced about 45.4 percent of 

the coal produced in the Wyoming PRB in 2006. Under the No Action 

alternatives, production of coal combustion residue attributable to burning coal 

produced from the coal mines would be extended at about current levels for up 

to approximately 11 years beyond 2008, while the mines recover their 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-155 

remaining leased coal reserves. Under the Proposed Action or Alternatives 2 or 

3, coal combustion residue related to burning coal mined at the applicant 

mines would be extended from 1.6 to 22.8 additional years, depending on the 

tract and alternatives selected. Uncertainties about future regulatory 

requirements and the use of the coal mined from the six WAC LBA tracts make 

it difficult to project the impacts of disposing coal combustion residues 

produced by burning coal produced from these tracts. 

Depending on the size, shape, and chemical composition, some coal 

combustion residues can be recycled and beneficially reused as components of 

building materials or as replacement to raw materials that would ordinarily 

need to be mined such as sand, gravel, or gypsum (EPA 2007f). Coal 

combustion products (CCPs) are the materials produced primarily from the 

combustion of coal in coal-fired power plants and can include the following 

materials: fly ash, bottom ash, boiler slag, and flue gas desulfurization material 

(EPA 2007f). Studies and research conducted or supported by the EPA, 

Electric Power and Research Institute (EPRI), other government agencies, and 

universities have indicated that the beneficial uses of coal combustion products 

have not been shown to present significant risks to human health or the 

environment (EPA 2008d). 

Fly ash is a byproduct of burning finely ground coal in a boiler to produce 

electricity. Physically, fly ash is a fine, powdery material composed mostly of 

silica and nearly all particles are spherical in shape. Fly ash is a pozzolan—a 

siliceous material which, in the presence of water, will react with calcium 

hydroxide at ordinary temperatures to produce cementitious compounds. 

Because of its spherical shape and pozzolanic properties, fly ash can be useful 

in cement and concrete applications (EPA 2007g). 

Bottom Ash is agglomerated ash particles, formed in pulverized coal furnaces 

that are too large to be carried in the flue gases. Bottom ash is coarse with 

grain sizes spanning from fine sand to fine gravel. It can be used as a 

replacement for aggregate and is usually sufficiently well-graded in size to 

avoid the need for blending with other fine aggregates to meet gradation 

requirements (EPA 2007h). 

Boiler slag is the molten bottom ash collected at the base of slag tap and 

cyclone type furnaces. Boiler slag particles are uniform in size, hard, and 

durable with a resistance to surface wear. The permanent black color of this 

material is desirable for asphalt applications and aids in the melting of snow 

(EPA 2007i). 

Flue Gas Desulfurization (FGD) material is a product of a process typically 

used for reducing SO2 emissions from the exhaust gas system of a coal-fired 

boiler (EPA 2007j). These materials can be used as embankment and road 

base material, wallboard manufacturing, and in place of gypsum for the 

production of cement. Currently, the largest single market for FGD material is 

in wallboard manufacturing (EPA 2007j). 
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4-156 Final EIS, Wright Area Coal Lease Applications 

Utilizing CCPs can generate significant environmental and economic benefits 

(EPA 2009f). CCPs can be used for raw feed for cement, concrete, grout, 

flowable fill, structural fill, road base/sub-base, soil modification, mineral filler, 

snow and ice traction control, blasting grit and abrasives, roofing granules, 

mining applications, wallboard, waste stabilization/solidification, and soil 

amendment. Using CCPs can reduce energy consumption and GHG emissions 

and can help reduce the need for landfill space. Economic benefits include 

reduced costs associated with managing coal ash and slag disposal, potential 

revenue from the sale of CCPs, and savings from using CCPs in place of other 

more costly raw materials (EPA 2009f). 

CCPs offer product-performance benefits as well. Boiler slag is a sought-after 

replacement for sand in blasting grit because it is free of silica and eliminates 

the potential health risk of silicosis (EPA 2007i). High coal ash-content 

concrete is used for building long-lived pavements designed to last 50 years—

twice the lifetime of conventional pavements. Coal fly ash can create superior 

products because of its self-cementing properties. Using coal fly ash in 

concrete can also produce stronger and longer-lasting buildings (EPA 2007g). 

This not only reduces the costs of maintaining buildings, but provides the 

additional environmental benefit of reducing the need for new concrete to 

repair or replace aging buildings. This translates to a significant reduction in 

future energy consumption and GHG emissions (EPA 2007g). 

In 2005, demand had become so strong for coal ash that some power plants 

were selling all the ash they produced (EPA 2005b). EPA estimated that 

through the utilization of 15 million tons of coal fly ash, the U.S. reduced its 

GHG emissions equivalent to the annual emissions of nearly 2.5 million 

passenger vehicles (EPA 2008e). 

Because of the many potential uses of CCPs, EPA has sponsored the Coal 

Combustion Products Partnership (C2P2) Program to further the beneficial use 

of these coal combustion by-products (EPA 2003b). With more than 170 

private and public partners (EPA 2009g), the C2P2 Program is a cooperative 

effort between EPA and various organizations to help promote the beneficial 

use of CCPs and the environmental benefits that can result from the proper 

use of these potentially recyclable materials (EPA 2003b). The C2P2 Program 

will help meet the national waste reduction goals of the Resource Conservation 

Challenge—an EPA effort to find flexible yet more protective ways to conserve 

valuable natural resources through waste reduction, energy recovery, and 

recycling (EPA 2009g). 

In 2007, the U.S. used approximately 43 percent of its coal combustion 

products (EPA 2009f). The C2P2 Program aims to reduce adverse effects on air 

and land by increasing the use of coal combustion products to 50 percent in 

2011 from 32 percent in 2001 (EPA 2009g). The program also plans to 

increase the use of CCPs as a supplementary cementitious material in concrete 

by 50 percent, from 12.4 million tons in 2001 to 18.6 million tons in 2011; this 
4.0 Cumulative Environmental Consequences 

Final EIS, Wright Area Coal Lease Applications 4-157 

would decrease GHG emissions from avoided cement manufacturing by 

approximately 5 million tons (EPA 2009g).