FINAL

Environmental Impact Statement for the 

Wright Area Coal Lease Applications

July 2010

BLM

Wyoming State Office – High Plains District

Volume 2 of 2

Chapters 5 - 8 and Appendices

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.
5.0 Consultation and Coordination 

Final EIS, Wright Area Coal Lease Applications 5-1 

5.0 CONSULTATION AND COORDINATION 

In addition to this Environmental Impact Statement (EIS)1, other factors and 

consultations are considered and play a major role in determining decisions on 

the proposed lease applications. These are included in the following. 

Regional Coal Team Consultation

The four coal lease applications included in this EIS were reviewed and discussed 

at Powder River Regional Coal Team (PRRCT) public meetings held on April 19, 

2006, in Casper, Wyoming (North Hilight Field, South Hilight Field, West Hilight 

Field, and West Jacobs Ranch tracts), and on January 18, 2007, in Casper, 

Wyoming (North and South Porcupine tracts). The North and South Hilight Field 

tracts were applied for in a single application, and the North and South Porcupine 

tracts were applied for in a single application. Each of the applicants presented 

information about their existing mines and pending lease application to the 

PRRCT at those meetings. Voting and nonvoting members of the PRRCT include 

the governors of Wyoming and Montana, the Northern Cheyenne Tribe, the Crow 

Tribal Council, the U.S. Department of Agriculture - Forest Service (USFS), Office 

of Surface Mining Reclamation and Enforcement, U.S. Fish and Wildlife Service, 

National Park Service, and U.S. Geological Survey. The PRRCT determined that 

the lands in the four applications met the qualifications for processing as 

production maintenance tracts. The PRRCT recommended that the Bureau of 

Land Management (BLM) continue to process all four lease applications. 

Governor's Consultation

The BLM Wyoming State Director notified the Governor of Wyoming on April 27, 

2006, that Ark Land Company had filed a lease application with BLM for the North 

and South Hilight Field Lease by Application (LBA) Tracts. The BLM Wyoming 

State Director notified the Governor of Wyoming on February 2, 2006, that Ark 

Land Company 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 Jacobs Ranch Coal Company 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 

Western Resources, Inc. had filed a lease application with BLM for the North and 

South Porcupine LBA Tracts. 

Public Notice

BLM published a Notice of Intent to prepare an EIS and Notice of Public Scoping 

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 

 

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

5-2 Final EIS, Wright Area Coal Lease Applications 

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. 

At the public scoping meeting, which was held July 24, 2007 in Gillette, Wyoming, 

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. 

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. The 

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

EIS in the Federal Register on July 8, 2009, in the Douglas Budget newspaper on 

July 8, 2009, and in the Gillette News-Record newspaper 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 formal public hearing was held on July 29 at 

7:00 p.m. at the Clarion Inn 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 17 individuals, agencies, 

businesses, and organizations, as well as over 500 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. 

Parties on the distribution have been sent copies of the completed Final EIS, and 

the EPA and BLM will publish Notices of Availability for the Final EIS in the 

Federal Register. After a 30-day availability period, BLM will make separate 

decisions to hold or not to hold a competitive lease sale for the federal coal in each 

of these six LBA tracts. A separate Record of Decision (ROD) will be prepared and 

signed for each of the tracts. Copies of each ROD will be mailed to parties on the 

mailing list and others who commented on this EIS during the National 

Environmental Policy Act (NEPA) process. There will be a 30-day appeal period 

after each ROD is signed before the ROD is implemented. If lands administered by 

the USFS are included in the tracts that are offered for lease, the USFS will 

prepare and sign a separate consent decision for each tract. Applicable USFS 

regulations for appeal will be followed. 

Department of Justice Consultation

After each competitive coal lease sale, but prior to issuance of a lease, BLM will 

solicit the opinion of the Department of Justice on whether the planned lease 
5.0 Consultation and Coordination 

Final EIS, Wright Area Coal Lease Applications 5-3 

issuance creates a situation inconsistent with federal anti-trust 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, BLM can 

proceed with issuance of the lease. 

Other Consultations

Other federal, state, local, and Native American governmental agencies that have 

been consulted in preparation of this EIS or will be consulted prior to making a 

decision to hold or not to hold a federal coal lease sale are listed in the following 

tables. 

Contributors, Reviewers, and Preparers

This EIS was prepared by WWC Engineering, a third-party contractor, under the 

direction of the BLM. Representatives from cooperating agencies reviewed and 

contributed to the EIS. Tables 5-1 and 5-2 provide listings of the BLM, 

cooperating agency, and third-party consultant personnel who prepared and 

reviewed this EIS. 

Distribution List

This EIS was distributed to Congressional offices, federal agencies, state 

governments, local governments, industry representatives, interest groups, and 

individuals for their review and comment (Table 5-3). 
5.0 Consultation and Coordination 

5-4 Final EIS, Wright Area Coal Lease Applications 

Table 5-1. List of Contributors and Reviewers.

Name Project Responsibility 

BLM High Plains District Office

Mike Karbs Coal Program Supervisor 

Sarah Bucklin Wright Area EIS Project Manager, Wildlife, T&E Species 

Teresa Johnson Environmental Protection Specialist 

Ginger Vickers Legal Assistant, Distribution List 

Mike Brogan Water Resources 

 

BLM Wyoming State Office

Brenda Neuman Coal Program Coordination 

Bob Janssen Coal Program Coordination 

Ken Peacock NEPA Coordination 

Janet Kurman NEPA Coordination 

Mavis Love Land Adjudication 

Larry Jensen Socioeconomics 

Steve Hageman Minerals Appraiser 

Bill Hill General Resources 

Dennis Saville Wildlife 

Dale Hansen Paleontology 

Melissa Hovey Air Quality 

John Zachariassen Air Quality and Climate 

Rick Schuler Water Resources 

Ranal Capron Cultural 

BLM Wyoming Reservoir Management Group 

Al Elser Petroleum Geology 

Dwain McGarry CBNG Geology 

Lee Almasy CBNG Reservoir Engineering 

Dave Chase Minerals 

BLM Buffalo Field Office

Tom Bills EIS Liaison 

Clint Crago Cultural, Paleontology 

Buck Damone Cultural 

Kay Medders Rangeland 

Jerry Queen Geology, Minerals, Mining Claims 

Chris Durham Wildlife, T&E Species, BLM Sensitive Species 

Don Brewer Wildlife 

USDA Forest Service 

Misty Hays Deputy District Ranger, Socioeconomics, Range 

Mike Fracasso EIS Liaison, Geology, Minerals, Paleontology 

Ian Ritchie Cultural 

Daneille Reboletti NEPA Coordination 

Charlie Bradshaw Vegetation, Range, Weeds 

Moriah Shadwick Vegetation, Range, Weeds 

Kathy Roche Botany, T&E Plants, USFS Sensitive Plant Species 

Tim Byer Wildlife, T&E Animals, Management Indicator Species 

Catherine Willard Fisheries, Amphibians, Reptiles 

Shawn Anderson Fisheries, Amphibians 

Dave Gloss Water Resources, Wetlands 

Greg Eaglin Air Quality 

Randy Tepler Soils 

Marcia Rose-Ritchie Land Use, Recreation 

Jeff Tupala Visual 

Amy Ormseth Hazardous Waste, Transportation 
5.0 Consultation and Coordination 

Final EIS, Wright Area Coal Lease Applications 5-5 

Table 5-1. List of Contributors and Reviewers (Continued). 

Name Project Responsibility 

BLM National Science and Technology Center 

(Powder River Basin Coal Review) 

Craig Nicholls Air Quality and Climate 

Paul Summers Water Resources 

Office of Surface Mining Reclamation and Enforcement 

Western Regional Coordinating Center

Foster Kirby Archaeologist, EIS Cooperating Agency Representative 

Board of Converse County Commissioners 

James H. Willox EIS Cooperating Agency Representative 

Wyoming Department of Transportation 

Larry Konetzki EIS Cooperating Agency Representative 

University of Wyoming 

Bonnie Heidel Wyoming Natural Diversity Database Botanist 

Ron Hartman Rocky Mountain Herbarium Curator 

B. Ernie Nelson Rocky Mountain Herbarium Manager 

ENSR International 

(Powder River Basin Coal Review) 

Valerie Randall Project Manager 

Dolora Koontz Assistant Project Manager and Task 2 Manager 

(Existing Development and Reasonably Foreseeable 

Development) 

Eldon Strid, Matt Reilly Existing and Projected Coal Development and Coal 

Transportation Scenarios 

Doree Dufresne Database Development 

Bruce MacDonald, PhD Air Quality 

Robert Berry, PhD Water Resources 

James Rumbaugh Ground Water Modeling 

Brad Anderson Surface Water 

Ron Dutton, George Blankenship Socioeconomics 

Bernhard Strom Land Use, Transportation, and Utilities 

William Berg Topography, Geology, and Minerals 

James Burrell, James Nyenhuis Soils and Alluvial Valley Floors 

Jon Alstad Vegetation, Wetlands, and Grazing 

Charles Johnson Wildlife 

Rollin Daggett Fisheries 

Kim Munson Native American Concerns and Paleontology 

Wyoming Department of Environmental Quality (WDEQ) 

Office of Outreach Services 

Dan Clark Ombudsman, EIS Liaison

WDEQ Land Quality Division 

Don McKenzie Administrator 

Kathy Muller Ogle CHIA Program Supervisor 

Mark Rogaczewski District Three Supervisor 

Anna Waitkus Senior Analyst 

Doug Emme Blasting Program Principal 

 

WDEQ Air Quality Division 

Kelly Bott Engineer/EIS Cooperating Agency Division Representative 
5.0 Consultation and Coordination 

5-6 Final EIS, Wright Area Coal Lease Applications 

Table 5-1. List of Contributors and Reviewers (Continued). 

Name Project Responsibility 

WDEQ Water Quality Division 

John Wagner Water Resources 

Wyoming Game and Fish Department 

John Emmerich Deputy Director – External Programs 

Wyoming State Planning Office

Steve Furtney Coal Issues Coordination/Cooperating Agency Representative 
5.0 Consultation and Coordination 

Final EIS, Wright Area Coal Lease Applications 5-7 

Table 5-2. List of Preparers.

Name Education/Experience Responsibility 

BLM High Plains District Office 

Mike Karbs M.S., B.S. Mineral Engineer, Public Policy, 

34 years professional experience 

Coal Program Supervisor 

Sarah Bucklin M.S. Candidate Zoology, B.S. Biology, 

Nationally Certified Wildlife Biologist, 

11 years professional experience 

EIS Project Manager 

WWC Engineering (Third-Party Contractor)

Ken Collier B.S. Geology, 

33 years professional experience 

Licensed Wyoming Geologist 

EIS Project Manager 

Report Preparation 

John Berry B.S. Wildlife Biology, 

33 years professional experience 

Report Preparation 

Heidi Robinson 18 years professional experience Document Production 

Mal McGill 12 years professional experience CADD/Figures Preparation 

Subcontractors 

Resource Responsibility 

For ALC: 

North, South and West Hilight Field Tracts 

Geology/Mineral Resources Habitat Management, Inc., Gillette, WY 

Air Quality Knight Technologies, Inc., Gillette, WY 

Water Resources WWC Engineering, Sheridan, WY 

Alluvial Valley Floors Habitat Management, Inc., Gillette, WY 

Wetlands Knight Technologies, Inc., Gillette, WY 

Soils BKS Environmental Associates, Inc., Gillette, WY 

Vegetation Habitat Management, Inc., Gillette, WY 

Wildlife Thunderbird-Jones and Stokes, Gillette, WY 

Land Use/Ownership Habitat Management, Inc., Gillette, WY 

Cultural GCM Services, Inc., Butte, MT 

Visual Knight Technologies, Inc., Gillette, WY 

Paleontology Arcadis U.S., Inc., Buffalo, WY 

Socioeconomics WWC Engineering, Laramie, WY 

Resource Responsibility 

For JRCC: 

West Jacobs Ranch Tract 

Geology/Mineral Resources Aqua Terra Consultants, Sheridan, WY 

Water Resources Aqua Terra Consultants, Sheridan, WY 

Alluvial Valley Floors Aqua Terra Consultants, Sheridan, WY 

Wetlands Aqua Terra Consultants, Sheridan, WY 

Soils Intermountain Resources, Laramie, WY 

Vegetation Intermountain Resources, Laramie, WY 

Wildlife Intermountain Resources, Laramie, WY 

Land Use/Ownership Aqua Terra Consultants, Sheridan, WY 

Cultural/Paleontology GCM Services, Inc., Butte, MT 

Socioeconomics WWC Engineering, Laramie, WY 

Resource Responsibility 

For BTU: 

North and South Porcupine Tracts 

Soils BKS Environmental Associates, Inc., Gillette, WY 

Vegetation BKS Environmental Associates, Inc., Gillette, WY 

Wildlife Thunderbird-Jones and Stokes, Gillette, WY 

Cultural GCM Services, Inc., Butte, MT 

Paleontology Arcadis U.S., Inc., Buffalo, WY 

Socioeconomics WWC Engineering, Laramie, WY 
5.0 Consultation and Coordination 

5-8 Final EIS, Wright Area Coal Lease Applications 

Table 5-3. BLM Distribution List for the Wright Area Final EIS.

US Government Printing Office, Washington, DC Federal and State Officials USDA – FS, Douglas Ranger District, Douglas, WY

Governor of Montana Brian Schweitzer USDA Forest Service, Douglas, WY 

Governor of Wyoming Dave Freudenthal USDA Forest Service, Golden, CO 

Representative Dave Edwards USGS Water Resources Division, Cheyenne, WY 

Representative Erin Mercer 

Representative Sue Wallis 

Representative Timothy Hallinan Wyoming State Agencies

Representative Thomas Lubnau Department of Agriculture 

Senator Jim Anderson Department of Education 

Senator John Hines Department of Employment, Research & Planning

Senator Michael Von Flatern Department of Transportation 

US Congresswoman Cynthia M. Lummis Economic Analysis Division 

US Senator John Barrasso Game & Fish Department, Cheyenne 

US Senator Mike Enzi Game & Fish Department, Lander 

 Game & Fish Department, Sheridan 

Office of the State Treasurer Federal Agencies Office of State Lands & Investments 

BLM Library, Denver, CO O & G Conservation Commission 

BLM, Buffalo, WY Parks & Cultural Resources Department 

BLM, Casper, WY Public Service Commission 

BLM, Cheyenne, WY State Engineer's Office 

BLM, Miles City, MT State Geological Survey 

BLM, Montana State Office, Billings, MT State Historic Preservation Office 

BLM, Washington, DC State Land Office 

Bureau of Indian Affairs, Washington, DC State Planning Office 

Department of Energy, Casper, WY Water Development Commission 

Department of Energy, Washington, DC WDEQ - Air Quality Division 

Department of Interior, Denver, CO WDEQ – Industrial Siting Division 

Devils Tower National Monument WDEQ - Land Quality Division, Cheyenne 

Medicine Bow National Forest, Laramie, WY WDEQ - Land Quality Division, Sheridan 

Mineral Management Bureau, Helena, MT WDEQ - Water Quality Division 

MMS, Denver, CO 

MMS, Herndon, VA 

National Park Service, Denver, CO Local Government and Agencies 

NPS - Air Resources Division, Denver, CO Big Horn County Commission, MT 

NPS, Washington, DC Campbell County Board of Commissioners, WY 

NRCS, Douglas, WY Campbell County Conservation District, WY 

OEPC, Denver, CO Campbell County Dept of Public Works, WY 

OSM Library, Denver, CO Campbell County School District 1, WY 

OSM, Casper, WY Carbon County, WY 

OSM, Denver, CO City of Douglas, WY 

OSM, Washington, DC City of Gillette, WY 

Rocky Mountain Regional Solicitor Converse County Commission, WY 

US Army Corps of Engineers, Cheyenne, WY Converse County Joint Powers Board, WY 

US EPA, Denver, CO Converse County School District, WY 

US EPA, Washington, DC Converse City Special Projects, WY 

US Fish & Wildlife Service, Arlington, VA Gillette Dept of Comm. Dev, WY 

US Fish & Wildlife Service, Cheyenne, WY Rosebud County Commission, MT 

US Geological Survey, Cheyenne, WY Town of Wright, WY 

US Geological Survey, Denver, CO Weston County Board of Comm., Newcastle, WY 

US Geological Survey, Reston, VA 
5.0 Consultation and Coordination 

Final EIS, Wright Area Coal Lease Applications 5-9 

Table 5-3. BLM Distribution List for the Wright Area Final EIS (Continued).

Tribal Organizations and Individuals Companies/Businesses

Apache Tribe of Oklahoma ABN Amro Mortgage Group, Inc. 

Arapahoe Business Council Aceite Energy Corp. 

Cheyenne River Sioux Tribe AE Investments, Inc. 

Cheyenne-Arapaho Tribes of Oklahoma AG Andrikopoulos Resources, Inc. 

Comanche Nation All American Equipment 

Crow Creek Sioux Tribe Amax Land Co. 

Crow Tribe Amerada Hess Corp. 

Eastern Shoshone Tribe American Colloid Co. 

Flandreau Santee Sioux Tribe Anadarko Exploration & Production 

Kiowa Business Committee Anadarko Petroleum Corp. 

Lower Brule Sioux Tribe Anderson Investments 

Northern Arapaho Business Council Anderson Oil Company 

Northern Arapaho Tribe Anderson Oil Ltd. 

Northern Cheyenne Cultural Commission Antelope Coal Company 

Northern Cheyenne Tribe APC Operation Partnership, LP 

Oglala Sioux Tribe Arch Western Resources, LLC 

Rosebud Sioux Tribe Ark Land Company 

Santee Sioux Tribe Bank of America, NA 

Shoshone Business Council Barret Resources Corp. 

Standing Rock Sioux Tribe Beard Oil Co. 

 Belle Fourche Pipeline Co. 

Berenergy Corp. Other Organizations and Groups Bill Barrett CBM LLC 

Advisory Council on Historic Preservation Bill Barrett Corp. 

Biodiversity Conservation Alliance Bjork Lindley Little PC 

Campbell City Economic Dev. Corp. BKS Environmental 

CANDO BNSF Railway Co. 

Center For Biological Diversity Boller-Mills Ranch 

Defenders of Wildlife Bridgeview Coal Co. 

Federation for North American Wild Sheep Bridle Bit Ranch Co. 

John P. Ellbogen Foundation Buckskin Mine 

National Mining Association Burlington Northern Santa Fe Railroad 

National Wildlife Federation Burns & McDonnell 

Natural Resources Defense Council C & H Oil & Gas, Inc. 

Petroleum Association of Wyoming Calvin Petroleum Corp. 

Powder River Basin Resource Council Carbon Recovery Technology 

Sierra Club Cargoil Oil and Gas LLC 

Theodore Roosevelt Cons. Partnership CH Snyder Company 

Thunder Basin Coalition Chaco Energy Co. 

Trout Unlimited Chaparral Royalty Co. 

WildEarth Guardians Chevron USA, Inc. 

WY Assoc. of Professional Archeologists Citation 1994 Investment LP 

WY Business Council/NE Region Citation 2002 Investment LP 

Wyoming Bankers Association Cloud Peak Energy 

Wyoming Business Alliance Coleman Oil & Gas, Inc. 

Wyoming Mining Association Colonial Royalties Limited Partnership 

Wyoming Outdoor Council Conoco-Phillips Petroleum Company 

Wyoming Stock Growers Association CONSOL Inc Exploration & Land 

Wyoming Wildlife Federation Cordero Rojo Mine 

Wyoming Wool Growers Association Cosner Minerals Limited Partnership 

 Cowry Enterprises, Ltd. 

 CTV O & G Multi-State LLC 

 Cucker, Montgomery, Aronstein & Bess, PC 

 Dakota - TX Oil Company 
5.0 Consultation and Coordination 

5-10 Final EIS, Wright Area Coal Lease Applications 

Table 5-3. BLM Distribution List for the Wright Area Final EIS (Continued).

Daven Corp. JP Morgan Chase Bank, NA 

Davis Oil Co. JPC, LLC 

Derby Energy LLC KAB Acquisitions LLP-VI 

Devon Energy Production Company LLP Kaiser-Francis Oil Co. 

DL Cook Estate Kastner Oil Properties, LLC 

DNR O & G Inc. Kenneth R. Paulsen Consultants 

Dry Fork Coal Co. Kerr McGee O & G Onshore LP 

Ducker Montgomery, et al. Kiewit Mining Group, Inc. 

Durham Ranches, Inc. Kirby Minerals, LLC 

Dymond Resources Limited Partnership Kirkwood Oil & Gas LLC 

EDE Consultants Klabzuba Oil & Gas Inc 

El Paso Production Co. KM Upstream, LLC 

Eland Energy, Inc. KN Gas Gathering, Inc. 

Ellbogen Property Management LTD Lasmo Oil & Gas, Inc. 

Energy Operating Company, Inc. LE Peabody & Associates 

ENSR Liberty Petroleum Corp 

Environmental Solutions, Inc. Louisiana Land & Exploration Co. 

EOG Resources, Inc. M & K Oil Co., Inc. 

Explorers Petro Corp. Malibu Presbyterian Church 

Exxon Mobil Oil Corp. Manitowac Mortgage Holding Co. 

Fayette Oil & Gas Corp. Manx Oil Corp. 

First Interstate Bank Marathon Oil Co. 

First State Bank of Newcastle Marshall & Winston, Inc. 

Five Star Energy LLC Marston & Marston 

Fleischaker Mineral Co., LLC McDun Limited Partnership 

Flocchini Investment McGraw-Hill 

Flying J Oil & Gas, Inc. McMoran Oil & Gas Co. 

Foundation Coal West, Inc. McVehil-Monnett Associates, Inc. 

Fulbright Tower, Guggenheim Corp. Meagher Oil & Gas Properties, Inc. 

Funding, LLC Medallion Exploration 

Future Realty, Inc. Media Maconi 

Geyer Brothers Equipment MEG Wyoming Gas Services, LLC 

GPM, Inc. Meineadair Consultants 

Great Points Energy Merit Energy Co. 

Greenbrair Energy LP IV Merit Energy Partners 

Guest Petroleum, Inc. Mills Brothers 

Hallador Petroleum, LLP Mine Engineers, Inc. 

Hardin & Associates Mining Associates of Wyoming 

Harvey E. Yates Co. Moon Royalty, LLC 

Headington Investments, Inc. Morse Acquisition, LLC 

Headington Minerals, Inc. Mourne Oil & Gas 

HEYCO Employees LTD Murjo Oil & Royalty Company 

Hilcorp Energy LLP Nance Petroleum Corp. 

HQ-USAF/CEVP National Leasing Corp. 

Hunt Petroleum Inc. Nationsbanc Leasing Corp 

Inexco Oil Co. Nerco Coal Company 

Intermountain Resources NM Doelger Consulting, LLC 

Interwest Mining Co. Norwest Corporation 

Isaacs Family Ltd Liability Ltd. Partnership NPC, Inc. 

Jacobs Ranch Coal Co. Oilfield Salvage and Service Co. 

Jerry J. Dilts Family Ltd. Partnership Olive Oil LLC 

Jetta Production Co., Inc. Ostlund Investments 

JIREH Exploration and Consulting, LLC OXY USA, Inc. 

John E. Jacobs Family Company, LLC P & M Coal Mining Co. 

Jolen Operating Co. Pacific Power & Light Co. 

Journey Properties, LLC Paribas North America 
5.0 Consultation and Coordination 

Final EIS, Wright Area Coal Lease Applications 5-11 

Table 5-3. BLM Distribution List for the Wright Area Final EIS (Continued).

Pathfinder Energy, Inc. Union Pacific Railroad 

Patina Oklahoma Corp. US Bank National Association 

Peabody Coal Co. US West Communications 

Peabody Energy Vintage Petroleum, Inc. 

Peabody Natural Gas LLC Wachovia Bank, National Association 

Perry R. Bass, Inc. Wells Fargo Bank, NA 

Petro-Canada Resources (USA), Inc. Wellstar Corp. 

Petro-Hunt, LLC West Roundup Resources, Inc. 

Phillips Petroleum Co. Western Energy Company 

Phoenix Resources Co. Western Fuels Association 

Plains Petroleum Operating Co. Western Gas Resources, Inc. 

Powder River Coal, LLC Westland Energy, Inc. 

Powder River Energy Corp. Whiting Petroleum Joint Venture 1983-84 

Powder River Oil & Gas Ventures, LLC Wilbanks Acquisitions I, LLC 

Prima Oil & Gas Co. Williams Field Service Co. 

Providence Energy Corporation Williams Production RMT Co. 

Quest Communications International, Inc. Wold Oil Properties, Inc. 

Questar Exploration and Production Co. WP Properties Corp. 

QWEST WWC Engineering 

RAM Energy Inc. Wyotex Oil Co. 

Raymond T. Duncan Oil Properties LTD Yates Petroleum Corp., et al. 

Resolute Wyoming Yates Petroleum Corp. 

RIM Offshore, Inc. ZAB, Inc. 

RL Zinn, et al, LTD Zalman Resources, Inc. 

Robert M. Bass Group 

Royalty Repository II, LLC 

Ryder Stilwell Oil Press 

Scorpio Resources, Inc. Associated Press 

Scot Holding Inc., dba Ture Blue Sky, Inc. Casper Star Tribune 

Shog Oil & Gas Co., LLC Douglas Budget 

Sid R. Bass, Inc. Gillette News-Record 

Sioux Ranch, Inc. Platts 

Sonorin III, LLC Wyoming-Tribune Eagle 

Spiral, Inc. 

Sport Resources, Inc. 

Star Investment Corp. Educational Institutions 

Steveco CSU Library 

Swift Energy Co. Northwestern University 

TC Craighead & Co. NWU Policy Research Institute 

Teton Capital Management, Inc. University of Wyoming Libraries 

Tetra Tech EC, Inc. URS Greiner Woodward Clyde Library 

The Bud & Mary Lou Flocchini Fam. Part. US Department of the Interior Library 

Thru Line, Inc. 

Thunder Basin Coal Co. 

Thunder Creek Gas Services, LLC Individuals

Thunderbird-Jones & Stokes Awve, Carl 

Titan Resources Corp. Awve, Delores 

Tonka Oil & Gas Production, Inc. Aylsworth, Gayle 

TRC Environmental Baalman, Lynne M. & Mark I. 

Triton Coal Co., LLC Barbero, Ralph 

Tucker Family Investments, LLP Bartolone, Carmen 

Two Rivers Ranch Belden, Scott 

Union Bank of California, NA Bennage, James 
5.0 Consultation and Coordination 

5-12 Final EIS, Wright Area Coal Lease Applications 

Table 5-3. BLM Distribution List for the Wright Area Final EIS (Continued).

Benson, Scott Huckins, Gary P. 

Bierman, Sheldon Isenberger, Mathew Lee 

Birdsall, Jennie Isenberger, Robert E. 

Boller, Verne Jester, Debra A. 

Bradley Jr., Jack Johnson-Head, Debra 

Buchanan et vir, Patricia Johnson-Hopson, DeMar 

Bunds, Carol Joslyn, Jerald D. 

Burroughs, Chap Kennedy, George 

Chapa, Nancy Kimoski, Stephen 

Chittenden, William M. & Lois R. Kinnaman, Dorothy 

Collins, Kristina Klabzuba, Robert 

Collums, James Klurfeld, Gregor 

Cottrell, Elizabeth Ann Kraning, James 

Couch, Marion Kruse, Douglas G. 

Couch, Tom Kruse, Gary 

Coulter, Betty Leadbetter, Cheryl 

Craft, Lecia Leadbetter, Linda 

Cupery, Karla Lee, Vivian E. 

DeGroot, John Lenhert, Amy L. 

Deizell, Larry Leutwyler, Scott 

Deputy et al., Robert Levorsen, Sandra 

Dilts et ux, John Lieberman, Erin 

Diltz III, Fred Litton, Mr. & Mrs. Gene E. 

Ditmore, Judy Long, Robert L. 

Dobbs, Kenna Masek, John 

Dorough Jr., Thomas Matejec, Hazel E. 

Dukam, Jennifer Springen Maxey, Shirley E. 

Dunlap, Katherin McAfee, Paul 

Dymond, Michael McKee, Gwyn 

Edwards, Dorothy McMahon Jr., Joe 

Edwards, Linda Meadows, Kelly 

Edwards, Thomas W. & Leah B. Merritt, Linda J. 

Fliginger, Mark Merritt, Ruth A. 

Flocchini Family, Richard & Patricia Migchelbrink, Margaret E. 

Forbes Jr., Jim Moore, Dr. Carl 

Forster, Jamie Moore, Larry W. 

Fraley Jr., Thomas Moore, Robert D. 

Glover, Dewey and Ruth Nash, Patsy Shubert 

Glustrom, Leslie Nelson, Christine M. 

Graham, John Nichols, Jeremy 

Greer, Virginia Lee Nyenhuis, Jim 

Greub, Twyla O'Connell, R.K. 

Gryneberg, Celeste Ogren, Harriet E. 

Gunnison, Lila Mae Olson, Kermit G. 

Hardy, Vern R. Papp, Alex 

Hays, James K. Paris, Jack W. 

Hays, Robert D. Pederson, Kathleen 

Heisner, Bill Penner II, Robert L. 

Hernandez, Beth Penner, Wibert H. 

Hewit, Betty R. Pippin, Robert L. 

Hines, Sandra Powers, Shirley 

Holland, J. Read Price et ux, William 

Holt, David T. Price, Bennett L. 

Huckins, Coey Pridgeon, William & Elaine 
5.0 Consultation and Coordination 

Final EIS, Wright Area Coal Lease Applications 5-13 

Table 5-3. BLM Distribution List for the Wright Area Final EIS (Continued).

Priewe, Doran E. 

Rock, Kim Trusts

Rockefeller, Mandra Amy Lynn Lenhert Trust/Gerald T. Tresner Trust 

Roderick, Jonathan S. Anna Louise Wright Carson, Trustee 

Roemer, Dr. Lamar B. Bennage Family Trust 

Rogers Jr., Richard J. Boller Trust 

Rogers, Geri Burton Keith Reno, Jr., Trustee 

Sauble, Dennis Mackey Callies Family Trust 

Saulcy, Bill Carole J. Pahl Irrevocable Trust 

Schmitt, Debbie S. Coramay Keeline Edelman Irrevocable Trust 

Schriner, Frances N. David L. Herbaly Revocable Trust 

Schwabauer et vir, Linda M. Donald L. Anderson, Trustee 

Semple, William Doris I. Mills Living Trust 

Smith, Peter F. Earl & Mildred Boller Living Trust 

Spangsberg, Shirley Fleischman Revocable Trust 

Springen, Phyllis Frank Ford, Trustee 

Stadelman, Joseph & Diana Gary P. Huckins, Trustee for Jeffery Thompson 

Stephens, Billie L. George F. Collins, Jr. Trust 

Storey, Bill George R. & Elaine Keeline Trust 

Stringer, Luella M. Guy W. Edwards Trust and Ruth A. Edwards 

Stroock, Thomas F. Harry W. Keeline II Trust 

Stuart, Larry D. Hazel K. Nisselius Trust 

Tanner, Sandy Henderson Living Trust U/A/D 

Taylor, Janet C. Irene Stuart Living Trust 

Terry, Evelyn M. Jack K. Nisselius, Revocable Trust 

Terry, Mark W. John & Shirley Long Revocable Trust 

Turner, Dr. Jenny Joseph S. Pollare Living Trust 

Turner, Dr. Wendy Keeline Oil & Gas Trust 

Turner, Dan Kenneth C. Revland Revocable Trust 

Turner, L.J. Larry & Kathryn Dunlap Family Trust 

Turner, Mike Larry L. Jourgenson, Trustee 

Ukeiley, Robert LaVern & Bill Stephens Revocable Trust 

Unruh, Dean D. Maurita A. & Patrick M. Meehan, Trustees 

Unruh, Florence E. Ms. Barbara H. Dilts Living Trust 

Van Dyke, Jeanne Northern Trust Bank of Florida 

Walker, Huntington Patsy Sue Shubert Trust 

Wallin, Julia Springen R. Reynared Mills Trust 

Wanger, Deena L. R. Wesley Savage, Trustee 

Ward Linda Reverend Burns Ind. & as Trustee 

West, Jennie M. Robert L. Haynie Revocable Trust 

Wilinson, John Allen Stuart Living Trust 

Wilkinson, Jerry & Rhonda TFS Trust 

Williams, John Thomas G. Dorough Trust Partnership 

Williams, Keith Willamas Family Trust (NE) 

Williams, Monica William E. Reno Revocable Trust 

Wilmot, Roger R. William L. Ferguson Trust 

Wilmot, William W. William R. & Dolores P. Wright II, Trustees 

Winland, Mark Willimas Family Trust (CA) 

Wood, Derryl W. WL Ferguson Testamentary Trust 

Wright Davis, Mary Ellen & Bobby Gale WTR Revocable Trust 

Wright, O. Dale 

Young, Dennis D. 
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Final EIS, Wright Area Coal Lease Applications 6-1 

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Antelope Rochelle mines if the North Hilight Field, South Hilight Field, 

West Jacobs Ranch, North Porcupine and South Porcupine LBA Tracts 

are added to the mines’ operations. Available on request from BLM 

Casper Field Office. Prepared March 2009. 

Zachariassen, J., 2010, Personal communication between J. Zachariassen, 

BLM Wyoming State Office, Cheyenne, Wyoming, and S. Bucklin, BLM 

High Plains District Office, Casper, Wyoming, May 10. 

Zachos, J.C., U. Rohl, S.A. Schellenberg, A. Sluijs, D.A. Hodell, D.C. Kelly, E. 

Thomas, M. Nicolo, I. Raffi, L.J. Lourens, H. McCarren, and D. Kroon, 

2005, Rapid acidification of the ocean during the Paleocene–Eocene 

thermal maximum; Science, Vol. 308, p. 1611–1615. 
7.0 Glossary 

Final EIS, Wright Area Coal Lease Applications 7-1

7.0 GLOSSARY 

aboriginal - Related to early or primitive cultures in a region. Being the first or 

earliest known of its kind in a specific region.

ad valorem tax - A tax paid as a percentage of the assessed value of property.

adverse impact - An apparent direct or indirect detrimental effect.

aliquot - An exact portion.

alkalinity - The degree to which the pH of a substance is greater than 7.

alluvial deposit - Deposits of clay, silt, sand, gravel, and/or other materials 

carried by moving surface water, such as streams, and deposited at points of 

weak water flow; alluvium. 

alluvial valley floor (AVF) - An area of unconsolidated stream-laid deposits 

holding streams with water availability sufficient for subirrigation or flood 

irrigation agricultural activities (see 30 CFR 701.5). 

alluvium - Sorted or semi-sorted sediment consisting of clay, silt, sand, gravel, 

or other unconsolidated rock material deposited in comparatively recent 

geologic time by a stream or other body of running water in the bed of that 

stream or on its flood plain or delta. 

alternative - In terms of the National Environmental Policy Act, one of several 

substitute or alternate proposals that a federal agency is considering in an 

environmental analysis. 

ambient - Surrounding conditions (or environment) in a given place and time. 

ANFO – An explosive blasting agent commonly used in open cut mining to aid 

in the removal of consolidated overburden, composed of ammonium nitrate and 

fuel oil. 

annual precipitation - The quantity of water that falls yearly in the form of 

rain, hail, sleet, and snow. 

anthropogenic - A direct result of human activities or are the result of natural 

processes that have been affected by human activities (IPCC/UNEP/OECD/IEA 

1997).

approximate original contour - Post-mining surface configuration achieved 

by backfilling and grading of mined-out areas so that the reclaimed land 

surface resembles the general surface configuration of the land prior to mining 

(see 30 CFR 701.5). 
7.0 Glossary 

7-2 Final EIS, Wright Area Coal Lease Applications

aquatic - Living or growing in or on the water. 

aquifer - A layer of permeable rock, sand, or gravel that stores and transmits 

water in sufficient quantities for a specific use. In hydrology, a rock layer or 

sequence that contains water and releases it in appreciable amounts. The 

rocks contain water-filled pores that, when connected, allow water to flow 

through their matrix. A confined aquifer is overlain by a rock layer that does 

not transmit water in any appreciable amount or that is impermeable. There 

probably are few truly confined aquifers. In an unconfined aquifer the upper 

surface (water table) is open to the atmosphere through permeable overlying 

material. An aquifer also may be called a water-bearing stratum, lens, or zone. 

aquitard - A confining bed that retards but does not totally prevent the flow of 

water to or from an adjacent aquifer; a leaky confining bed. 

area source – A plant site that does not emit any single HAP (Hazardous Air 

Pollutants) at a rate of 10 tons or greater per year, or any combination of HAPs 

at a rate of 25 tons or greater per year. 

ash - The residual non-combustible matter in coal that comes from included 

silt, clay, silica, or other substances. The lower the ash content, the better the 

quality of the coal. 

avian - Of, relating to, or derived from birds. 

backfill - The operation of refilling an excavation. Also, the material placed in 

an excavation when it is refilled. 

baseline - Conditions, including trends, existing in the human environment 

before a proposed action is begun; a benchmark state from which the 

environmental consequences of an action are forecast; the no-action 

alternative. 

beneficial impact - An apparent direct or indirect advantageous effect. 

bentonite – An absorptive and colloidal clay used especially as a sealing agent 

or suspending agent formed by the decomposition of volcanic ash which has 

the ability to absorb large amounts of water and to expand to several times its 

normal volume; used in adhesives, cements and ceramic fillers.

biogenic – Pertaining to a deposit resulting from the physiological activities of 

organisms. 

bonus - That value in excess of the rentals and royalties that is paid to the 

United States as part of the consideration for receiving a lease for publicly 

owned minerals [see 43 CFR 3400.0-5(c)].
7.0 Glossary 

Final EIS, Wright Area Coal Lease Applications 7-3

buffer zone - An area between two different land uses that is intended to 

resist, absorb, or otherwise preclude development or intrusion between the two 

use areas. 

bypass coal - An isolated part of a coal deposit that is not leased and that can 

only be economically mined in an environmentally sound manner as a part of 

continued mining by an existing adjacent operation [see 43 CFR 3400.0.5(d)]. 

carbon dioxide equivalent (CO2e) – Measures for describing how much global 

warming a given type and amount of greenhouse gas may cause, using the 

functionally equivalent amount or concentration of carbon dioxide as the 

reference. CO2e is expressed as parts per million by volume. 

carbon sink - A natural or manmade reservoir that accumulates and stores 

some carbon-containing chemical compound for an indefinite period. 

cast blasting – Commonly used in open cut mining to throw the overburden 

some distance in a controlled direction using a blasting agent (ANFO). 

climate change - A change in long-term weather patterns, i.e. warmer or 

colder temperatures or an increase or decrease in annual amounts of rainfall or 

snowfall.

clinker (scoria) - Baked and fused rock resulting from in-place burning of coal 

deposits. 

coal bed natural gas (CBNG) - Natural gas (methane) that is generated during 

the coal-forming process. 

colluvium - Rock fragments, sand, or soil material that accumulates at the 

base of slopes; slope wash. 

confluence - The point at which two or more streams meet. 

contiguous - Lands or legal subdivisions having a common boundary, lands 

having only a common corner are not contiguous. 

cooperating agency - An agency which has jurisdiction by law in an action 

being analyzed in an environmental document and who is requested to 

participate in the NEPA process by the agency that is responsible for preparing 

the environmental document [see 40 CFR 1501.6 and 1508.5]. 

crucial wildlife habitat - Parts of the habitat necessary to sustain a wildlife 

population during periods of their life cycle. It may be a limiting factor on the 

population, such as nesting habitat or winter habitat. 

cultural resources - The remains of human activity, occupation, or endeavor 

reflected in districts, sites, structures, buildings, objects, artifacts, ruins, 
7.0 Glossary 

7-4 Final EIS, Wright Area Coal Lease Applications

works of art, architecture, and natural features that reveal the nature of 

historic and prehistoric human events. These resources consist of (1) physical 

remains, (2) areas where significant human events occurred, and (3) the 

environment immediately surrounding the resource. 

cumulative impact - The impact on the environment which results from the 

incremental impact of the action when added to other past, present, and 

reasonably foreseeable future actions regardless of what agency (federal or nonfederal) or person undertakes such other actions. Cumulative impacts can 

result from individually minor but collectively significant actions taking place 

over a period of time (40 CFR 1508.7). 

decibel - A unit of sound measurement. In general, a sound doubles in 

loudness for every increase of 10 decibels. 

deciview - A general measure of view impairment (13 deciview equals a view of 

approximately 60 miles) caused by pollution. A 10 percent change in 

extinction corresponds to 1.0 dv. 

desorb – To remove by the reverse of adsorption or absorption. 

dip - The angle at which a rock layer is inclined from the horizontal. 

direct (or primary) impact - An impact caused by an action that occurs at the 

same time and place as the action (see 40 CFR 1508.8). 

discharge - Any of the ways that ground water comes out of the surface, 

including through springs, creeks, or being pumped from a well. 

dissected upland - An upland or high area in which a large part of the original 

surface has been deeply cut into by surface water flow. 

dragline - A type of excavating crane that casts a rope- or cable-hung bucket a 

considerable distance, collects the dug material by pulling the bucket toward 

itself on the ground with a second rope or cable, elevates the bucket, and 

dumps the material on a backfill bank or pile. 

eolian – Deposits which are due to the transporting action of the wind. 

ephemeral stream - A stream that flows occasionally because of surface 

runoff, and is not influenced by permanent ground water. 

erosion - The wearing away of the land surface by running water, wind, ice or 

other geologic agents. 

evapotranspiration - The sum total of water lost from the land by evaporation 

and plant transpiration. 
7.0 Glossary 

Final EIS, Wright Area Coal Lease Applications 7-5

excavation (archeological) - The scientifically controlled recovery of 

subsurface materials and information from a cultural site. Recovery 

techniques are relevant to research problems and are designed to produce 

maximum knowledge about the site's use, its relation to other sites and the 

natural environment, and its significance in the maintenance of the cultural 

system. 

fair market value - The amount in cash, or in terms reasonably equivalent to 

cash, for which in all probability a coal deposit would be sold or leased by a 

knowledgeable owner willing but not obligated to sell or lease to a 

knowledgeable purchaser who desires but is not obligated to buy or lease. 

floodplain - The relatively flat area or lowland adjoining a body of flowing 

water, such as a river or stream, that is covered with water when the river or 

stream overflows its banks. 

forage - Vegetation used for food by wildlife, particularly big game wildlife, and 

domestic livestock. 

formation (geologic) - A rock body distinguishable from other rock bodies and 

useful for mapping or description. Formations may be combined into groups or 

subdivided into members. 

fossil - The remains or traces of an organism or assemblage of organisms that 

have been preserved by natural processes in the earth's crust. Many minerals 

that may be of biologic origin are not considered to be fossils (e.g. oil, gas, 

asphalt, limestone). 

geometric mean - The nth root of the product of the values of n positive 

numbers. 

global warming - An average increase in the Earth's temperature, which in 

turn causes changes in climate.

greenhouse effect - A theory that certain gases (so-called greenhouse gases) in 

the atmosphere impede the release of radiation from the earth, trapping heat in 

the atmosphere like glass over a greenhouse. 

groundwater - Subsurface water that fills available openings in rock or soil 

materials to the extent that they are considered water saturated. 

habitat - A place where a plant or animal naturally or normally lives and 

grows. 

habituation - The process of becoming accustomed to, or used to, something; 

acclimation. 
7.0 Glossary 

7-6 Final EIS, Wright Area Coal Lease Applications

hazardous materials - Substance which, because of its potential for 

corrosivity, toxicity, ignitability, chemical reactivity, or explosiveness, may 

cause injury to persons or damage to property. 

hazardous waste - Those materials defined in Section 101 (14) of the 

Comprehensive Environmental Response, Compensation and Liability Act of 

1980, and listed in 40 CFR § 261. A used or discarded material that can 

damage the environment and be harmful to health. Hazardous wastes include 

heavy metals and toxic chemicals used in industrial products and processes as 

well as infectious medical wastes and radioactive materials such as spent 

nuclear fuel rods.

heterogenous - Made up of dissimilar constituents. 

human environment - The natural and physical environment in which 

humans preside or have an impact and the relationship of people with the 

surrounding environment (see 30 CFR 1508.14). 

hydraulic conductivity - The capacity of a medium to transmit water; 

permeability coefficient. Expressed as the volume of water at the prevailing 

temperature that will move in unit time under a unit hydraulic gradient 

through a unit area. Units include gallons per day per square foot, centimeters 

per second. 

hydraulic - Pertaining to fluid in motion, or to movement or action caused by 

water. 

hydric soil - A soil that is saturated, flooded, or ponded long enough during 

the growing season to develop anaerobic conditions that favor the growth and 

regeneration of hydrophytic (water-loving) vegetation. Hydric soils that occur in 

areas having positive indicators of hydrophytic vegetation and wetland 

hydrology are wetland soils. 

hydrocarbon - Any organic compound, gaseous, liquid, or solid, consisting 

solely of carbon and hydrogen. 

hydrology - The science dealing with the behavior of water as it occurs in the 

atmosphere, on the surface of the ground, and underground. 

hydrophytic vegetation - The plant life growing in water or on a substrate 

that is at least periodically deficient in oxygen as a result of excessive water 

content. When hydrophytic vegetation comprises a community where 

indicators of hydric soils and wetland hydrology also occur, the area has 

wetland vegetation. 

impermeable - Not capable of transmitting fluids or gasses in appreciable 

quantities. 
7.0 Glossary 

Final EIS, Wright Area Coal Lease Applications 7-7

incised - Having a margin that is deeply and sharply notched. 

indirect (or secondary) impact - A reasonably foreseeable impact resulting 

from an action but occurring later in time than or removed in distance from 

that action (see 40 CFR 1508.8). 

in-place coal reserves - The estimated volume of all of the coal reserves in a 

lease without considering economic or technological factors that might restrict 

mining. 

in-situ leach mining (ISL) - Removal of the valuable components of a mineral 

deposit through chemical leaching without physical extraction of the rock. 

(ISL), also called in-situ recovery (ISR) or solution mining, is a process of 

recovering minerals such as copper and uranium through boreholes drilled into 

the deposit. The process initially involves drilling of holes into the ore deposit. 

Explosive or hydraulic fracturing may be used to create open pathways in the 

deposit for solution to penetrate. Leaching solution is pumped into the deposit 

where it makes contact with the ore. The solution bearing the dissolved ore 

content is then pumped to the surface and processed. This process allows the 

extraction of metals and salts from an ore body without the need for 

conventional mining involving drill-and-blast, open-cut or underground

mining. 

interbedded - Layers of one type of rock, typically thin, that are laid between 

or that alternate with layers of another type of rock. 

interburden - A layer of sedimentary rock that separates two mineable coal 

beds. 

interdisciplinary - Characterized by participation or cooperation among two or 

more disciplines or fields of study. 

intermittent stream - A stream that does not flow year-round but has some 

association with ground water for surface or subsurface flow. 

laminated - Consolidated or unconsolidated sediment that is characterized by 

thin (less than 1 cm thick) layers. 

land and resource management plan (LRMP) - A land use plan that directs 

the use and allocation of U.S. Forest Service lands and resources. 

lead agency - The agency or agencies preparing or having taken primary 

responsibility for preparing an environmental document (see 40 CFR 1508.16). 

lease (mineral) - A legal document executed between a mineral owner or lessor 

and another party or lessee which grants the lessee the right to extract 

minerals from the tract of land for which the lease has been obtained [see 43 

CFR 3400.0-5(r)]. 
7.0 Glossary 

7-8 Final EIS, Wright Area Coal Lease Applications

lek - A traditional breeding area for grouse species where territorial males 

display and establish dominance. 

lenticular - Term describing a body of rock or earth that thins out in all 

directions from the center like a double convex optical lens. 

limb (geologic) - One side of a fold (syncline or anticline). 

limestone - A sedimentary rock consisting chiefly of calcium carbonate. 

lineament - A linear topographic feature of regional extent that is believed to 

reflect crustal structure. 

loadout facilities - The mine facilities used to load the mined coal for 

transport out of the mine. 

loam - A rich, permeable soil composed of a mixture of clay, silt, sand, and 

organic matter. 

maintenance tract - A federal coal tract that would continue or extend the life 

of an existing coal mine. 

major federal action - An action with effects that may be major and which is 

potentially subject to federal control and responsibility (see 40 CFR 1508.18). 

major sources – Those sources that emit more than 10 tons per year of any 

single hazardous air pollutant, or 25 tons of all hazardous air pollutants 

combined. The determination of major is based on all sources of hazardous air 

pollutants at the site, and not just the equipment affected by the MACT 

standard. 

maximum economic recovery - The requirement that, based on standard 

industry operating practices, all profitable portions of a leased federal coal 

deposit must be mined. MER determinations will consider existing proven 

technology; commercially available and economically feasible equipment; coal 

quality, quantity, and marketability; safety, exploration, operating, processing, 

and transportation costs; and compliance with applicable laws and regulations 

[see 43 CFR 3480.0-5(a)(24)]. 

meteorological - Related to the science dealing with the atmosphere and its 

phenomena, especially as relating to weather. 

methane - A colorless, odorless, and flammable gaseous hydrocarbon; the 

simplest hydrocarbon; chemical formula = CH4. It is the product of 

decomposition of organic matter and of the carbonization of coal, is used as a 

fuel and as a starting material in chemical synthesis, and is the simplest of the 

alkanes, constituent of natural gas and is also found associated with crude oil 

and coal. 
7.0 Glossary 

Final EIS, Wright Area Coal Lease Applications 7-9

mineable coal - Coal that can be economically mined using present day 

mining technology. 

mineral rights - The rights of one who owns the mineral estate (subsurface). 

mining permit - A permit to conduct surface coal mining and reclamation 

operations issued by the state regulatory authority pursuant to a state program 

or by the Secretary pursuant to a federal program (see 30 CFR 701.5). 

mitigation - An action to avoid, minimize, reduce, eliminate, replace, or rectify 

the impact of a management practice. 

mudstone - A hardened sedimentary rock consisting of clay. It is similar to 

shale but lacks distinct layers. 

National Register of Historic Places (NRHP) - A list of districts, sites, 

buildings, structures and objects significant in American history, architecture, 

archeology and culture maintained by the Secretary of the Interior. Expanded 

as authorized by Section 2(b) of the Historic Sites Act of 1935 (16 U.S.C. 462) 

and Section 101(a)(1) (A) of the National Historic Preservation Act. 

native species – Native species refer to wild animals and plants that have 

evolved in a particular region and environment. Native species are the most 

adapted to the area and are more disease and drought resistant than nonnative species. Native plants provide the greatest benefits to wildlife because 

the native wildlife evolved with native plants. Often the food provided by native 

plants is the most nutritious to our native wildlife. 

natural gas - Combustible gases (such as hydrocarbons) or mixtures of 

combustible gases and non-combustible gases (such as helium) that are in a 

gaseous phase at atmospheric conditions of temperature and pressure. 

NEPA process - All measures necessary for compliance with the National 

Environmental Policy Act of 1969 (see 40 CFR 1508.21). 

no action alternative - An alternative where no activity would occur. The 

development of a no action alternative is required by regulations implementing 

the National Environmental Policy Act (40 CFR 1502.14). The No Action 

Alternative provides a baseline for estimating the effects of other alternatives. 

outcrop - A rock formation that appears at or near the surface; the intersection 

of a rock formation with the surface. 

overburden - Overburden is the term used in mining to describe material that 

lies above (excluding topsoil) the area of economic interest, e.g., the rock and 

soil that lies above the coal seam. Also known as 'waste'. Overburden is distinct 

from tailings, the material that remains after economically valuable 

components have been extracted from the generally finely milled ore. 
7.0 Glossary 

7-10 Final EIS, Wright Area Coal Lease Applications

Overburden is removed during surface mining, but is typically not 

contaminated with toxic components and may be used to restore a mining site 

to a semblance of its appearance before mining began. Overburden may also be 

used as a term to describe all soil and ancillary material above the bedrock 

horizon in a given area. 

oxides of nitrogen (NOX) - The generic term for a group of highly reactive 

gases, all of which contain nitrogen and oxygen in varying amounts. 

ozone - A gas that is created by a chemical reaction between oxides of nitrogen 

(NOx) and volatile organic compounds (VOC) in the presence of sunlight. 

paleontological resource - A site containing evidence of plant or non-human 

animal life of past geological periods, usually in the form of fossil remains. 

peak discharge or flow - The highest discharge of water recorded over a 

specified period of time at a given stream location; also called maximum flow. 

Often thought of in terms of spring snowmelt, summer, fall or winter rainy 

season flows. 

perennial species (vegetation) - Vegetation that lives over from season to 

season. 

perennial stream - A stream or part of a stream that flows continuously 

during the calendar year as a result of groundwater discharge or surface 

runoff. 

permeability - The ability of rock or soil to transmit a fluid. 

permit application package - A proposal to conduct surface coal mining and 

reclamation operations on federal lands, including an application for a permit, 

permit revision, or permit renewal and all the information required by SMCRA, 

the applicable state program, any applicable cooperative agreement, and all 

other applicable laws and regulations including, with respect to federal leased 

coal, the Mineral Leasing Act and its implementing regulations. 

permit area - The area of land, indicated on the approved map submitted by 

the operator with his or her application, required to be covered by the 

operator’s performance bond under the regulations at 30 CFR Part 800 and 

which shall include the area of land upon which the operator proposes to 

conduct surface coal mining and reclamation operations under the permit, 

including all disturbed areas (see 30 CFR 701.5). 

physiography - Physical geography. 

playa - The sandy, salty, or mud-caked flat floor of a basin with interior 

drainage, usually occupied by a shallow ephemeral lake during or after rain or 

snow storms. 
7.0 Glossary 

Final EIS, Wright Area Coal Lease Applications 7-11

point source (pollution) - A point at which pollution is added to a system, 

either instantaneously or continuously. An example is a smokestack. 

pore volume - The amount of fluid necessary to fill the void space in an 

unsaturated porus medium (i.e., mine backfill). 

porosity - The percentage of the bulk volume of rock, sediment or soil that is 

not occupied by sediment or soil particles; the void space in rock or sediment. 

It may be isolated or connected. 

postmining topography - The relief and contour of the land that remains after 

mining has been completed. 

potentiometric surface - The surface that coincides with the static level of 

water in an aquifer. The surface is represented by the levels to which water 

from a given aquifer will rise under its full hydraulic head. 

predator - An animal that obtains food by killing and consuming other 

animals. 

prime or unique farmland - Those lands which are defined by the Secretary of 

Agriculture in 7 CFR part 657 (Federal Register Vol. 4 No. 21) and which have 

historically been used for cropland (see 30 CFR 701.5). 

proposed action - In terms of National Environmental Policy Act, the project, 

activity, or action that a federal agency proposes to implement or undertake 

and which is the subject of an environmental analysis. 

qualified surface owner - The natural person or persons (or corporation, the 

majority stock of which is held by a person or persons otherwise meeting the 

requirements of this section) who: 

 (1) hold legal or equitable title to the surface of split estate lands; 

 (2) have their principal place of residence on the land, or personally 

conduct farming or ranching operations upon a farm or ranch unit to 

be affected by surface mining operations; or received directly a 

significant portion of their income, if any, from such farming and 

ranching operations; and 

 (3) have met the conditions of (1) and (2) above for a period of at least 

three years, except for persons who gave written consent less than 

three years after they met the requirements of both (1) and (2) above 

[see 43 CFR 3400.0-5(gg)]. 

raptor - Bird of prey, such as an eagle, falcon, hawk, owl, or vulture. 

recharge - The processes by which groundwater is absorbed into a zone of 

saturation. 
7.0 Glossary 

7-12 Final EIS, Wright Area Coal Lease Applications

reclamation - Rehabilitation of a disturbed area to make it acceptable for 

designated uses. This normally involves regrading, replacement of topsoil, 

revegetation (with native plant life) and other work necessary to restore the 

disturbed area for post-mining use. In general where viable an attempt to put 

the terrain back to the pre-mining contours is also of paramount importance. 

record of decision - A document separate from, but associated with, an 

environmental impact statement that publicly and officially discloses the 

responsible official's decision on the proposed action (see 40 CFR 1505.2). 

recoverable coal - The amount of coal that (is economically feasible to recover) 

can actually be recovered for sale from the demonstrated coal reserve base. 

rental payment - Annual payment from a lessee to a lessor to maintain the 

lessee’s mineral lease rights. 

resource management plan - A land use plan, as prescribed by FLPMA, that 

directs the use and allocation of public lands and resources managed by BLM. 

Prior to selection of the RMP, different alternative management plans are 

compared and evaluated in an environmental impact statement (EIS) to 

determine which plan will best direct the management of the public lands and 

resources. 

revegetation - The reestablishment and development of self-sustaining plant 

cover following land disturbance. This may occur through natural processes, 

or the natural processes may be enhanced by human assistance through 

seedbed preparation, reseeding, and mulching. 

right of way - The right to pass over property owned by another. The strip of 

land over which facilities such as roadways, railroads, or power lines are built. 

riparian - The area adjacent to rivers and streams that lies between the stream 

channel and upland terrain and that supports specific vegetation influenced by 

perennial and/or intermittent water. 

royalty (mineral) - A share of production that is free of the expense of 

production. It is generally paid by a lessee to a lessor of a mineral lease as part 

of the terms of the lease. 

runoff - That portion of rainfall that is not absorbed; it may be used by 

vegetation, lost by evaporation, or it may find its way into streams as surface 

flow. 

salinity - Refers to the solids, such as sodium chloride (table salt) and alkali 

metals, that are dissolved in water. Often in non-saltwater areas, total 

dissolved solids is used as an equivalent term. 
7.0 Glossary 

Final EIS, Wright Area Coal Lease Applications 7-13

sandstone - A common sedimentary rock primarily composed of sand grains, 

mainly quartz, that are cemented together by other mineral material. 

scoping - A public informational process required by the National 

Environmental Policy Act to determine private and public concerns, scope of 

issues, and/or questions regarding a proposed action to be evaluated in an 

environmental impact analysis. 

scoria (clinker) - Baked and fused rock resulting from in-place burning of coal 

deposits. 

sedimentation pond - An impoundment used to remove solids from water in 

order to meet water quality standards or effluent limitations before the water 

leaves the permit area (see 30 CFR 701.5). 

semi-arid - A climate or region characterized by little yearly rainfall and by the 

growth of a number of short grasses and shrubs. 

severance tax - A tax on the removal of minerals from the ground. 

shale - A very fine-grained clastic rock or sediment consisting predominately of 

clay-sized particles that is laminated; lithified, layered mud. 

significant impact - A qualitative term used to describe the anticipated 

importance of impacts to the human and or the environment as a result of an 

action(s) either direct or indirect. 

siltstone - A fine-grained clastic rock consisting predominately of silt-sized 

particles. 

socioeconomics - The social and economic situation that might be affected by 

a proposed action. 

soil survey - The systematic examination, description, classification, and 

mapping of soils in an area, usually a county. Soil surveys are classified 

according to the level of detail of field examination. Order I is the most detailed 

and Order V is the least detailed. 

spontaneous combustion – The heating and slow combustion (self-ignition) of 

coal and coaly material initiated through chemical action (as oxidation 

(absorption of oxygen)). 

stipulations - Requirements that are part of the terms of a mineral lease. 

Some stipulations are standard on all Federal leases. Other stipulations may 

be applied to specific leases at the discretion of the surface management 

agency to protect valuable surface resources or uses existing on those leases. 
7.0 Glossary 

7-14 Final EIS, Wright Area Coal Lease Applications

storage coefficient - The volume of water that can be released from storage 

per unit surface area of a saturated confined aquifer, per unit decline in the 

component of hydraulic head normal to the surface. It is calculated by taking 

the product of the specific storage and the aquifer thickness. 

stratigraphic - Of, relating to, or determined by stratigraphy, which is the 

branch of geology dealing with the study of the nature, distribution, and 

relations of layered rocks in the earth’s crust. 

stripping ratio - The unit amount of overburden that must be removed to gain 

access to a similar unit amount of coal. 

subirrigation - In alluvial valley floors, the supplying of water to plants from 

underneath, or from a semi-saturated or saturated subsurface zone where 

water is available for use by vegetation (see 30 CFR 701.5). 

subbituminous - A lower rank of coal (35-45 percent carbon) with a heating 

value between that of bituminous and lignite, usually 8,300-11,500 Btu per 

pound. Sub bituminous coal contains a high percentage of volatile matter and 

moisture. 

surface disturbance - Any disturbance by direct or indirect actions that alters 

the soil surface. 

surface rights - Rights to the surface of the land, does not include rights to oil, 

gas, or other subsurface minerals or subsurface rights. 

suspended solids - The very fine soil particles that remain in suspension in 

water for a considerable period of time without contact with the stream or river 

channel bottom. 

tectonic fracture - Fractures caused by deformation of the earth’s crust. 

threatened and endangered species - These species of plants or animals 

classified as threatened or endangered pursuant to Section 4 of the 

Endangered Species Act. Any species which is in danger of extinction, or is 

likely to become so within the foreseeable future. 

Category 1 - Substantial biological information on file to support the 

appropriateness of proposing to list as endangered or threatened. 

Category 2 - Current information indicates that proposing to list as 

endangered or threatened is possibly appropriate, but substantial 

biological information is not on file to support an immediate ruling (U.S. 

Fish and Wildlife Service). 

topography - Physical shape of the ground surface; the configuration of land 

surface including its relief, elevation, and the position of its natural and 

manmade features. 
7.0 Glossary 

Final EIS, Wright Area Coal Lease Applications 7-15

topsoil - The upper portion of a soil, usually dark colored and rich in organic 

material. It is more or less equivalent to the upper portion of an A horizon in an 

ABC soil.

total dissolved solids (TDS) - The total quantity in milligrams per liter of 

dissolved materials in water. 

transmissivity - The rate at which water is transmitted through a unit width 

of an aquifer under a unit hydraulic gradient. Equals the hydraulic 

conductivity multiplied by the aquifer thickness. Values are given in units of 

gallons per day per foot. 

transpiration - The discharge of water vapor by plants. 

truck & shovel - A mining method used to remove overburden and coal in a 

strip mining operation. Truck and shovel operations use large bucketequipped digging and loading machines (shovels) and large dump trucks to 

remove overburden instead of using a dragline for overburden removal. 

unconfined aquifer - An aquifer where the water table is exposed to the 

atmosphere through openings in the overlying materials. 

unsuitability criteria - The 20 criteria described in 43 CFR 3461, the 

application of which results in an assessment of federal coal lands as suitable 

or unsuitable for surface coal mining. 

upland – Ground elevated above the lowlands located along drainage bottoms. 

uranium - A very hard, heavy, metallic element that is crucial to development 

of atomic energy. 

vegetation type - A kind of existing plant community with distinguishable 

characteristics described in terms of the present vegetation that dominates an 

area. 

vertebrate fossils - The fossilized remains of animals that possessed a 

backbone; examples are fish, amphibians, reptiles, dinosaurs, birds, and 

mammals. 

vesicular - Rock containing many small cavities that were formed by the 

expansion of a bubble of gas or steam during the solidification of the rock. 

visual resources - The physical features of a landscape that can be seen (e.g., 

land, water, vegetation, structures, and other features). 

visual resource management - Systematic means to identify visual values, 

establish objectives that provide the standards for managing those values, and 

evaluate visual impacts of proposed projects to ensure that objectives are met. 
7.0 Glossary 

7-16 Final EIS, Wright Area Coal Lease Applications

volatile matter - In coal, those substances, other than moisture, that are 

given off as gas or vapor during combustion. 

volatile organic compound - Organic chemical compounds that have high 

enough vapor pressures under normal conditions to significantly vaporize and 

enter the atmosphere. 

waterfowl - A bird that frequents water, especially a swimming bird such as a 

duck or swan. 

wetlands - Those areas that are inundated or saturated by surface or ground 

water at a frequency and duration sufficient, under normal circumstances, to 

support a prevalence of vegetative or aquatic life that requires saturated or 

seasonally saturated soil conditions for growth and reproduction. Wetlands 

include marshes, bogs, sloughs, potholes, river overflows, mud flats, wet 

meadows, seeps, and springs [see 33 CFR 328.3(a)(7)(b)]. 

wild and scenic river - Rivers or sections of rivers designated by 

Congressional actions under the 1968 Wild and Scenic Rivers Act as wild, 

scenic, or recreational by an act of the Legislature of the state or states through 

which they flow. Wild and scenic rivers may be classified and administered 

under one or more of the following categories: 

wild river areas - Rivers or sections of rivers that are free of 

impoundments and generally inaccessible except by trail, with 

watersheds or shorelines essentially primitive and waters unpolluted. 

These represent vestiges of primitive America. 

scenic river areas - Rivers or sections of rivers that are free of 

impoundments, with watersheds still largely primitive and shorelines 

largely undeveloped, but accessible in places by roads. 

recreational river areas - Rivers or sections of rivers that are readily 

accessible by road or railroad, that may have some development along 

their shorelines, and that may have undergone some impoundment or 

diversion in the past. 

wilderness - An area of undeveloped Federal land designated wilderness by 

Congress, retaining its primeval character and influence, without permanent 

improvements or human habitation, protected and managed to preserve its 

natural conditions and that (1) generally appears to have been affected 

primarily by the forces of nature with the imprint of man's work substantially 

unnoticeable, (2) has outstanding opportunities for solitude or primitive and 

unconfined recreation, (3) has at least 5,000 acres or is of sufficient size to 

make practical its preservation and use in an unimpaired condition, and (4) 

also may contain features that are of ecological, geological, scientific, 

educational, scenic, or historical value. These characteristics were identified 

by Congress in the Wilderness Act of 1964. 
8.0 Index 

Final EIS, Wright Area Coal Lease Applications 8-1 

8.0 INDEX 

agriculture bonus payment or bonus bid payment 

ES-11, ES-49 ES-15–26, ES-60 

1-5 2-78–89 

2-16, 2-72, 2-93, 2-100 3-300–304 

3-2, 3-35, 3-143, 3-158, 3-159, 

3-161, 3-165, 3-269 carbon dioxide or CO2

4-83, 4-85, 4-87, 4-99, 4-100, ES-60, ES-61, ES-68 

4-102, 4-141 3-26, 3-323, 3-325–327 

5-1, 5-8 4-20, 4-22, 4-25, 4-27, 4-130–132,

6-3, 6-8, 6-24 4-136–142, 4-144–148, 4-150, 

7-11 4-151 

Appendix D: D-7 6-3, 6-11, 6-36 

Appendix G: G-1, G-134 7-3 

Appendix H: H-1, H-86, H-122 

 coal bed natural gas or CBNG 

alluvial valley floor or AVF ES-27, ES-30, ES-31, ES-33, 

ES-28, ES-49, ES-61 ES-40, ES-48, ES-62, ES-65, 

1-7 ES-67 

2-72, 2-73, 2-93, 2-100 1-22, 1-24 

3-2, 3-115, 3-158, 3-159, 3-160, 2-8, 2-67–69, 2-91, 2-99, 2-100 

3-161–165, 3-174 3-26–34, 3-49, 3-77, 3-109, 3-110,

4-6, 4-83 3-112, 3-113, 3-115–118, 3-120, 

5-5, 5-7 3-122, 3-123, 3-125, 3-132, 

6-15 3-142, 3-127–129, 3-147–151, 

7-1, 7-14 3-153–156, 3-169–173, 3-184, 

Appendix B: B-3, B-6, B-9, B-12, 3-191, 3-193, 3-220, 3-225, 3-229,

B-15, B-18 3-231–233, 3-251–254, 3-256–258,

Appendix G: G-129 3-260, 3-262–264, 3-278, 3-281, 

 3-285, 3-321, 3-327 

blasting 4-1, 4-2, 4-18, 4-20–25, 4-27, 

ES-13, ES-33, ES-39, ES-58, 4-41–44, 4-48, 4-49, 4-54–58, 

ES-59 4-61, 4-62, 4-65–69, 4-72–85, 

1-11, 1-12, 1-14, 1-16, 1-25 4-87–89, 4-91–93, 4-95, 4-96, 

2-13, 2-40, 2-48, 2-51, 2-56, 4-98, 4-103, 4-108–112, 4-114, 

2-72, 2-92 4-123–126, 4-128, 4-141, 4-142 

3-49, 3-58, 3-59, 3-63, 3-70, 5-4 

3-77–80, 3-81–84, 3-86–89, 6-24 

3-90, 3-95, 3-98, 3-283–285, 7-3 

3-324, 3-327 Appendix E: E-4–16 

4-42, 4-70, 4-156 Appendix F: F-14, F-16 

5-5 Appendix G: G-53, G-55–62, 

6-11, 6-22 G-67, G-69, G-72, G-74, G-76, 

7-1, 7-3 G-77, G-81, G-82, G-98–102, 

Appendix F: F-8, F-17, F-18 G-110–114, G-120, G-121, G-128 

 Appendix H: H-45–49, H-52–56, 

 H-65, H-111, H-112 
8.0 Index 

8-2 Final EIS, Wright Area Coal Lease Applications

Environmental Protection Agency or grazing (cont’d) 

EPA G-78, G-81, G-98, G-99, G-100, 

ES-10, ES-34, ES-36, ES-39, G101, G-102, G-112, G-114, G-117

ES-63 Appendix H: H-66, H-86, H-110, 

1-25, 1-26 H-112 

2-71, 2-76 

3-48, 3-50, 3-51, 3-55, 3-58, 3-60, human health 

3-70, 3-76–82, 3-90, 3-91, 3-93, ES-39, ES-57 

3-96, 3-97, 3-166, 3-167, 3-283, 3-215, 3-259–262, 3-265, 3-267, 

3-322, 3-326 3-321 

4-45, 4-46, 4-48, 4-52, 4-130, 4-100, 4-102, 4-103 

4-131, 4-133, 4-135, 4-141, 4-144, 6-9, 6-12 

4-145, 4-151–157, Appendix H: H-103, H-107, H-108,

5-2, 5-8 H-112 

6-26, 6-27 

Appendix F: F-1, F-3–5, F-9, F-10, migratory birds 

F-12, F-15–18 ES-28 

 2-95 

fair market value 3-2, 3-217, 3-225, 3-226, 3-235 

ES-10, ES-11 Appendix G: G-39 

1-4, 1-26 

2-13, 2-19, 2-21, 2-26, 2-28, mitigation 

2-33, 2-37, 2-40, 2-46, 2-50, ES-11, ES-32, ES-33, ES-53, 

2-57, 2-60, 2-65, 2-68 ES-57, ES-61 

3-264 1-20 

5-2 2-14, 2-16, 2-23, 2-30, 2-33, 2-41,

7-5 2-43, 2-52, 2-54, 2-62, 2-69, 2-70,

 2-71–75 

fugitive dust 3-1, 3-16, 3-23, 3-33, 3-37, 

ES-33, ES-36 3-45–47, 3-58, 3-73, 3-77, 

2-15, 2-42 3-83, 3-87, 3-89, 3-96, 3-99, 

3-48, 3-49, 3-57, 3-58, 3-60, 3-132, 3-148, 3-157, 3-165, 

3-67, 3-73 3-167, 3-174, 3-175, 3-182, 

4-46, 4-107 3-188, 3-208, 3-211, 3-212, 

Appendix F: F-8, F-11, F-17 3-228, 3-230, 3-234, 3-236, 

 3-266, 3-271, 3-273, 3-274, 

grazing 3-276, 3-277, 3-280, 3-281, 

ES-56 3-286, 3-295, 3-298, 3-299, 

1-9, 1-11, 1-12, 1-14, 1-16, 1-25 3-319, 3-323, 3-326 

2-73, 2-74, 2-94, 2-95 4-44, 4-48, 4-54, 4-66, 4-87, 

3-15, 3-184, 3-185, 3-189, 3-196, 4-106, 4-132, 4-139, 4-143 

3-237, 3-244, 3-262, 3-263, 6-17 

3-264, 3-265, 3-266, 3-268, 7-9 

3-270, 3-320 Appendix D: D-1, D-2, D-7, D-8 

4-6, 4-99, 4-100, 4-101, 4-102 Appendix F: F-8–10 

5-5 Appendix G: G-36, G-38, G-112, 

6-23 G-114–116, G-118 

Appendix G: G-65, G-66, G-76, Appendix H: H-49, H-70, H-72, 
8.0 Index 

Final EIS, Wright Area Coal Lease Applications 8-3 

mitigation (cont’d) PM10

H-73, H-75, H-76, H-78, H-79, ES-33, ES-34, ES-36, ES-39, 

H-81–83, H-99, H-100, ES-64 

H-104, H-116, H-117 2-66, 2-71, 2-98, 2-99 

 3-49–51, 3-55, 3-57, 3-58, 

MLA Mining Plan 3-60–63, 3-67, 3-68, 3-70–73, 

1-17–19 3-76–78, 3-82–84, 3-86, 3-322, 

2-67 3-323 

3-33 4-45–50, 4-54 

Appendix A: A-1 6-27, 6-28 

Appendix G: G-35 Appendix F: F-3–5, F-7–10, 

 F-12, F-14–17 

monitoring plan 

2-70–75 power plant(s) 

3-23, 3-133 ES-34, ES-68 

 1-17, 1-18, 1-25 

nitrogen oxides or NOx 2-69, 2-92 

ES-33, ES-34, ES-39 3-49, 3-83, 3-84, 3-86, 3-111, 

1-25 3-296, 3-323 

2-95 4-9, 4-14–21, 4-32, 4-41, 4-44, 

3-49, 3-61, 3-62, 3-71, 3-72, 4-45, 4-54, 4-72, 4-85, 4-87, 4-88,

3-96, 3-98, 3-222 4-101, 4-107, 4-109, 4-111, 

4-151 4-118, 4-126–29, 4-135, 4-136, 

6-26, 6-28 4-141, 4-144, 4-146–148, 

7-10 4-150–156 

Appendix F: F-8–10, F-14, Appendix G: G-2, G-26 

F-16–18 Appendix F: F-8 

 Appendix H: H-112 

nitrogen dioxide or NO2 

ES-33, ES-34, ES-39, ES-64 reclamation 

2-72, 2-98 ES-11, ES-29, ES-48–54, 

3-49, 3-50, 3-78–81, 3-86, 3-88, ES-56–59, ES-61, ES-67, ES-68 

3-83, 3-84, 3-89, 3-90, 3-96, 1-5, 1-18, 1-19, 1-20 

3-323 2-11, 2-13, 2-14, 2-22, 2-27, 2-28,

4-45–50, 4-54 2-40, 2-41, 2-51, 2-52, 2-61, 2-66,

6-17, 6-26, 6-27 2-67, 2-70–75, 2-93–96, 2-98, 

Appendix F: F-3–5, F-8, 2-100, 2-101, 2-103 

F-9, F-14, F-17, F-18 3-2, 3-8–10, 3-13, 3-15, 3-16, 

 3-22, 3-23, 3-30–33, 3-47, 3-73, 

PM2.5 3-87, 3-95, 3-99, 3-111, 

ES-33, ES-34, ES-64 3-114–116, 3-121, 3-126, 3-127, 

2-98 3-132, 3-133, 3-144, 3-145, 3-147,

3-49–51, 3-91, 3-96 3-156, 3-158, 3-160–162, 3-165, 

4-45–48, 4-50, 4-54 3-173–178, 3-180–182, 3-185–189,

6-27 3-192, 3-193, 3-197, 3-206, 

Appendix F: F-3, F-4 3-211, 3-224, 3-225, 3-227, 

 3-228, 3-230, 3-231, 3-233, 

 3-235–237, 3-263, 3-265, 3-266, 
8.0 Index 

8-4 Final EIS, Wright Area Coal Lease Applications

reclamation (cont’d) royalty 

3-276, 3-280, 3-281, 3-286, ES-15–26, ES-60 

3-295, 3-298, 3-299, 3-301, 1-5, 1-17 

3-320, 3-321, 3-323, 3-327, 3-328 2-68, 2-69, 2-74, 2-78–89 

4-6, 4-9, 4-11, 4-12, 4-25, 4-33, 3-33, 3-301, 3-319 

4-38, 4-40, 4-41, 4-56, 4-57, 4-59, 4-124, 4-125 

4-61, 4-62, 4-65, 4-69, 4-70, 4-75, 5-9–11 

4-76, 4-83–85, 4-87, 4-88, 6-17 

4-93–95, 4-98, 4-99, 4-101, 4-103, 7-12 

4-104, 4-106, 4-107, 4-136, 4-154 Appendix D: D-4 

5-1, 5-5 

6-19, 6-21, 6-22 sage-grouse 

7-9, 7-10, 7-12 ES-52–57 

Appendix A: A-1 1-25 

Appendix B: B-2, B-3, B-5, B-6, 2-73, 2-95, 2-101 

B-8, B-9, B-11, B-12, B-14, B-15, 3-186, 3-190, 3-199–204, 

B-17, B-18 3-212–230, 3-234, 3-263, 3-265, 

Appendix D: D-2, D-3 3-285, 3-320, 3-321 

Appendix F: F-16, F-18 4-96–99, 4-102 

Appendix G: G-3, G-34–36, 6-3, 6-9, 6-10, 6-18, 6-19, 6-22, 

G-38, G-54, G-55, G-57, G-59, 6-24, 6-29, 6-31, 6-34 

G-61, G-62, G-97–112, G-116, Appendix B: B-3, B-6, B-9, B-12, 

G-118, G-126, G-128, G-129 B-15, B-18 

Appendix H: H-55–58, Appendix G: G-40, G-41, G-125, 

H-71, H-72, H-62, H-66, H-75–80, G-136 

H-85, H-94–98, H-103, H-108, Appendix H: H-4, H-6, H-8, H-10, 

H-109, H-111–113, H-115–117 H-12, H-14, H-21, H-23, H-25, 

 H-60, H-61, H-87–99, H-114, 

reclamation bond H-115, H-117–119, H-121 

ES-51, ES-57 

2-73, 2-103 T&E species 

3-10, 3-186, 3-189, 3-266 ES-61 

4-6 3-2, 3-207, 3-235, 3-237, 3-328 

 5-4 

recreation Appendix G: G-1, G-3, G-39, G-40,

ES-28, ES-56, ES-61 G-42–52, G-54, G-55, G-57, G-59, 

1-9, 1-12, 1-14, 1-16 G-61, G-62, G-97, G-112, 

2-95, 2-101 G-125–130, G-133 

3-2, 3-92, 3-143, 3-152, 3-237, 

3-244, 3-265–267, 3-321 total dissolved solids or TDS 

4-36, 4-73, 4-74, 4-99, 4-100, ES-48, ES-67 

4-102, 4-103 2-92 

5-4 3-17, 3-103, 3-105, 3-107, 

7-16 3-109–111, 3-114, 3-115, 3-121, 

Appendix B: B-1, B-4, B-7, B-10, 3-126, 3-131 

B-13, B-16 4-70, 4-71, 4-76, 4-77, 4-94 

Appendix F: F-6 7-12, 7-15 

Appendix G: G-98–102, G-114 
8.0 Index 

Final EIS, Wright Area Coal Lease Applications 8-5 

total suspended solids or TSS U.S. Fish & Wildlife Service or USFWS

3-142 (cont’d) 

 B-18 

U.S. Department of Agriculture-Forest Appendix G: G-35, G-36, G-38–42,

Service or U.S. Forest Service or USFS G-53–59, G-61–63, G-86, G-87, 

ES-11, ES-14, ES-32, ES-56, G-88, G-89, G-91, G-103, 

ES-57 G-104–107, G-113–115, 

1-5, 1-9, 1-12, 1-16, 1-19–21, G-119–122, G-132, G-133, G-135, 

1-26 G-136 

2-16, 2-20, 2-24, 2-26, 2-31, 2-35, Appendix H: H-51–53, 

2-47, 2-55, 2-58, 2-63 H-59, H-70, H-72, H-75, H-76, 

3-2, 3-35, 3-37, 3-40, 3-41, 3-97, H-78, H-79, H-81–83, H-100, 

3-143, 3-168, 3-175, 3-188, 3-197, H-104, H-117, H-122 

3-198, 3-205, 3-207, 3-210, 3-215, 

3-219, 3-222, 3-223, 3-227, 3-232, wetlands 

3-233, 3-237, 3-244, 3-259, 3-262, ES-28, ES-49, ES-50, ES-61 

3-264–266, 3-270, 3-279, 3-280 1-25 

4-85, 4-87, 4-95, 4-100, 4-102 2-72, 2-73, 2-93, 2-100 

5-1, 5-2, 5-4 3-2, 3-152, 3-165–176 3-187, 

6-8, 6-14, 6-19, 6-20, 6-22, 6-24 3-188, 3-231, 3-235 

7-7 4-84, 4-87, 4-88, 4-91, 4-99, 

Appendix B: B-3, B-6, B-9, B-12, 4-100 

B-15, B-18 5-4, 5-5, 5-7 

Appendix D: D-7, D-9 6-18, 6-23, 6-26–28 

Appendix G: G-1, G-9, G-10, G-13, 7-6, 7-16 

G-14, G-18, G-20, G-27, G-29, Appendix A: A-1 

G-32, G-34, G-36, G-39, G-40, Appendix G: G-39, G-53–62, 

G-41, G-42, G-69, G-71, G-74, G-64–76, G-78–83, G-113–115, 

G-77, G-81, G-82, G-84–88, G-125, G-126, G-128–130, 

G-97, G-113, G-117, G-126, G-136 

G-128, G-129, G-133–135 Appendix H: H-33, H-34, H-39, 

Appendix H: H-1–3, H-16–91, H-47–50, H-64–66, H-115, H-116 

H-93–102, H-105–119, H-122 

 Wyoming Department of Environmental

U.S. Fish & Wildlife Service or USFWS Quality or WDEQ 

ES-49, ES-51, ES-53–56 ES-11, ES-34, ES-36, ES-39, 

2-73, 2-74, 2-95 ES-48–51, ES-68 

3-168–171, 3-189, 3-192, 3-197, 1-5, 1-9, 1-11, 1-12, 1-14, 

3-198, 3-207, 3-210, 3-241, 1-17–20 

3-217, 3-225, 3-227, 3-228, 2-12, 2-14, 2-21, 2-27, 2-39, 2-41,

3-234, 3-236 2-50, 2-52, 2-59, 2-66, 2-67, 

4-95, 4-97 2-70–76, 2-93 

5-1 3-7–10, 3-13, 3-16, 3-33, 3-48, 

6-28, 6-29 3-50, 3-51, 3-55, 3-57–59, 3-63, 

7-14 3-67, 3-70, 3-73, 3-76–84, 3-86, 

Appendix B: B-2, B-5, B-8, B-9, 3-88, 3-90, 3-91, 3-95, 3-96, 3-99,

B-11, B-12, B-14, B-15, B-17, 3-104, 3-108, 3-109, 3-115, 3-116,
8.0 Index 

8-6 Final EIS, Wright Area Coal Lease Applications

Wyoming Department of Environmental 

Quality or WDEQ (cont’d) 

3-118, 3-120, 3-121, 3-123, 

3-125, 3-126, 3-129, 3-131–133, 

3-142–144, 3-148, 3-149, 3-151, 

3-157, 3-158, 3-189, 3-160–166, 

3-173, 3-175–177, 3-183, 

3-186–190, 3-192, 3-197, 3-208, 

3-210, 3-211, 3-216, 3-218, 3-221, 

3-226, 3-266, 3-298, 3-299, 3-222, 

3-323 

 

 

 

 
APPENDIX A

FEDERAL AND STATE PERMITTING 

REQUIREMENTS AND AGENCIES 
Appendix A 

Final EIS, Wright Area Coal Lease Applications A-1

APPENDIX A: 

FEDERAL AND STATE AGENCIES & PERMITTING REQUIREMENTS1

Agency Lease/Permit/Action

FEDERAL

Bureau of Land Management Coal Lease 

Resource Recovery & Protection Plan 

Scoria Sales Contract 

Exploration Drilling Permit 

Office of Surface Mining Reclamation and 

Enforcement 

Preparation of MLA Mining Plan Approval Document 

SMCRA Oversight 

Office of the Secretary of the Interior Approval of MLA Mining Plan 

Mine Safety and Health Administration Safety Permit and Legal ID 

Ground Control Plan 

Major Impoundments 

Explosives Use and Storage Permit 

Bureau of Alcohol, Tobacco, and Firearms Explosives Manufacturer’s License 

Explosives Use and Storage Permit 

Federal Communication Commission Radio Permit: Ambulance 

Mobile Relay System Radio License 

Nuclear Regulatory Commission Radioactive By-Products Material License 

Army Corps of Engineers Authorization of Impacts to Wetlands and Other Waters 

of the U.S. 

Department of Transportation Hazardous Waste Shipment Notification 

Federal Aviation Administration Radio Tower Facilities Construction Permits

STATE

State Land Commission Coal Lease 

Scoria Lease 

Department of Environmental Quality/Land 

Quality Division 

Permit and License to Mine 

Permit to Construct Sedimentation Pond 

Department of Environmental Quality/Air 

Quality Division 

Air Quality Permit to Operate 

Air Quality Permit to Construct 

Department of Environmental Quality/Water 

Quality Division 

NPDES Water Discharge Permit 

Authorization to Construct Septic Tank & Leach Field 

Authorization to Construct and Install a Public Water 

Supply and Sewage Treatment System 

Department of Environmental Quality/Solid 

Waste Management Program 

Solid Waste Disposal Permit - Permanent and 

Construction 

State Engineer’s Office Appropriation of Surface Water Permits 

Appropriation of Ground Water Permits 

Industrial Siting Council Industrial Siting Certificate of Non-Jurisdiction 

1 Individual Lease/Permit Actions listed may not be required at all mines. 
APPENDIX B 

UNSUITABILITY CRITERIA FOR THE 

 NORTH HIGHLIGHT FIELD, SOUTH HILIGHT FIELD, 

WEST HILIGHT FIELD, WEST JACOBS RANCH, 

NORTH PORCUPINE, AND SOUTH PORCUPINE 

LBA STUDY AREAS 
Appendix B 

Final EIS, Wright Area Coal Lease Applications B-1 

APPENDIX B. UNSUITABILITY CRITERIA FOR THE NORTH HIGHLIGHT 

FIELD LBA STUDY AREA

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR THE NORTH HILIGHT 

FIELD LBA STUDY AREA 

1. Federal Land Systems. With 

certain exceptions that do not 

apply to this tract, all federal lands 

included in the following systems 

are unsuitable for mining: 

National Parks, National Wildlife 

Refuges, National System of Trails, 

National Wilderness Preservation 

System, National Wild and Scenic 

Rivers, National Recreation Areas, 

Lands acquired through the Land 

and Water Conservation Fund, 

National Forests and Federal lands 

in incorporated cities, towns and 

villages.

There are Federal lands located around 

Gillette, Sheridan, and Wright that were 

determined to be unsuitable under this 

criterion. TBNG lands are included in 

the North Hilight Field LBA study area. 

The TBNG is not a proclaimed National 

Forest.

None of the federal lands determined to be 

unsuitable under Criterion 1 are present 

on the North Hilight Field LBA study area. 

Therefore, there are no unsuitable 

findings under this criterion.

2. Rights-Of-Way and Easements. 

Federal lands that are within 

ROWs or easements or within 

surface leases for residential, 

commercial, industrial or other 

public purposes, on federally 

owned surface, are unsuitable for 

mining.

Portions of the BNSF & UP railroad ROW, 

the Tri-County 230-Kv transmission line 

ROW, the Wyoming State Highway 450 

ROW, and the I-90 ROW were found to be 

unsuitable under this criterion within the 

general review area.

The portions of the Tri-County 230-Kv 

transmission line ROW, the Wyoming 

State Highway 450 ROW, the I-90 ROW, 

and the BNSF & UP railroad ROW that 

were determined to be unsuitable are not 

located on the North Hilight Field LBA 

study area. Therefore, there area no 

unsuitable findings under Criterion 2 for 

the North Hilight Field LBA study area.

3. Buffer Zones for Rights-Of-Way, 

Communities, and Buildings. 

Federal lands within 100 ft of a 

ROW of a public road or a 

cemetery; or within 300 ft of any 

public building, school, church, 

community or institutional 

building or public park; or within 

300 ft of an occupied dwelling are 

unsuitable for mining.

Portions of Wyoming State Highway 450, 

Interstate Highway I-90, and one 

cemetery were found to be unsuitable 

under this criterion. Decisions were 

deferred on other highways/roads, 

occupied dwellings, and one school until 

an application to lease is filed. 

Highway 450, I-90, and the cemetery are 

not located on the North Hilight Field LBA 

study area. No occupied dwellings or 

schools are located on the study area. 

Portions of the ROWs of the Shroyer, 

Hilight, Small, and Jacobs roads, all 

county roads, are located on the tract as 

applied for and/or under Alternative 2. 

The Small and Jacobs roads have been 

vacated by the Campbell County 

Commissioners. Therefore, the portions 

of the North Hilight Field LBA study area 

within the ROWs of the Shroyer and 

Hilight roads and the associated 100-ft 

buffer zones are designated unsuitable 

and the lease will be stipulated to exclude 

mining within these areas unless a permit 

to move the road is approved by Campbell 

County Board of Commissioners.

4. Wilderness Study Areas. Federal 

lands designated as wilderness 

study areas are unsuitable for 

mining while under review for 

possible wilderness designation.

No lands in the general review area are 

within a wilderness study area.

There are no unsuitable findings under 

Criterion 4 for the North Hilight Field LBA 

study area.

5. Scenic Areas. Scenic federal 

lands designated by visual 

resource management analysis as 

Class I (outstanding visual quality 

or high visual sensitivity) but not 

currently on National Register of 

Natural Landmarks are unsuitable.

No lands in the general review area meet 

the scenic criteria as outlined.

There are no unsuitable findings under 

Criterion 5 for the North Hilight Field LBA 

study area.

6. Land Used for Scientific Study. 

Federal lands under permit by the 

surface management agency and 

being used for scientific studies 

involving food or fiber production, 

natural resources, or technology 

demonstrations and experiments 

are unsuitable for the duration of 

the study except where mining 

would not jeopardize the purpose 

of the study.

Two vegetation monitoring study sites on 

the TBNG (NE1⁄4 of Sec. 1, T.41N., R.71W. 

and NW1⁄4 NW1⁄4 of Sec. 30, T.41N., 

R.69W.), and the Hoe Creek Site (Sec. 7, 

T.47N., R.72W.) were found to be 

unsuitable under this criterion.

The vegetation monitoring sites and the 

Hoe Creek site are not located on the 

North Hilight Field LBA study area. There 

are no unsuitable findings under Criterion 

6 for the North Hilight Field LBA study 

area.
Appendix B 

B-2 Final EIS, Wright Area Coal Lease Applications

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR THE NORTH HILIGHT 

FIELD LBA STUDY AREA

7. Cultural Resources. All publicly 

or privately owned places which 

are included in or are eligible for 

inclusion in the NRHP and an 

appropriate buffer zone are 

unsuitable.

On the basis of the consultation with 

SHPO, there were no unsuitable findings 

under this criterion in the general review 

area. Continue using the “Standard 

Archeological Stipulation” to new leases.

There are no unsuitable findings under 

Criterion 7 for the North Hilight Field LBA 

study area. The “Standard Archeological 

Stipulation” should be applied if this tract 

is leased.

8. Natural Areas. Federal lands 

designated as natural areas or 

National Natural Landmarks are 

unsuitable.

No lands in the general review area are 

designated as natural areas or as 

National Natural Landmarks.

There are no unsuitable findings under 

Criterion 8 for the North Hilight Field LBA 

study area.

9. Critical Habitat for Threatened 

or Endangered Plant and Animal 

Species. Federally designated 

critical habitat for threatened or 

endangered plant and animal 

species, and scientifically 

documented essential habitat for 

threatened or endangered species 

are unsuitable.

There is no federally designated critical 

habitat for threatened or endangered 

plant or animal species within the 

general review area.

There are no unsuitable findings under 

Criterion 9 for the North Hilight Field LBA 

study area.

10. State Listed Threatened or 

Endangered Species. Federal 

lands containing habitat 

determined to be critical or 

essential for plant or animal 

species listed by a state pursuant 

to state law as threatened or 

endangered shall be considered 

unsuitable.

Wyoming does not maintain a state list of 

threatened or endangered species of 

plants or animals. Therefore, this 

criterion does not apply.

There are no unsuitable findings under 

Criterion 10 for the North Hilight Field 

LBA study area.

11. Bald or Golden Eagle Nests. An 

active bald or golden eagle nest 

and appropriate buffer zone are 

unsuitable unless the lease can be 

conditioned so that eagles will not 

be disturbed during breeding 

season or unless golden eagle 

nests will be moved.

Defer suitability decisions and evaluate 

bald and golden eagle nests on a case by 

case basis at the time of leasing. 

Establish buffer zones around nests 

during mining and reclamation planning 

after consultation with USFWS.

There are currently no bald or golden 

eagle nests (active or inactive) on the 

North Hilight Field LBA study area. 

Evaluate suitability prior to lease 

issuance during consultation with 

USFWS.

12. Bald and Golden Eagle Roost and 

Concentration Areas. Bald and 

golden eagle roost and 

concentration areas on federal 

lands used during migration and 

wintering are unsuitable unless 

mining can be conducted in such a 

way as to ensure that eagles shall 

not be adversely disturbed.

Defer suitability decisions and evaluate 

bald and golden eagle roost areas on a 

case by case basis prior to lease 

issuance. Establish buffer zones after 

consultation with USFWS.

There are no identified roost sites on the 

North Hilight Field LBA study area. 

Evaluate suitability prior to lease 

issuance during consultation with 

USFWS. 

13. Falcon Nesting Sites and Buffer 

Zones. Federal lands containing 

active falcon (excluding kestrel) 

cliff nesting sites and a suitable 

buffer zone shall be considered 

unsuitable unless mining can be 

conducted in such a way as to 

ensure the falcons will not be 

adversely affected.

Defer suitability decisions on falcon 

nesting sites and evaluate on a case by 

case basis prior to lease issuance. 

Establish buffer zones around nesting 

sites after consultation with USFWS.

No falcon nesting sites have been 

identified on the North Hilight Field LBA 

study area. There are no unsuitable 

findings under Criterion 13 for the North 

Hilight Field LBA study area.

14. Habitat for Migratory Bird 

Species. Federal lands which are 

high priority habitat for migratory 

bird species of management 

concern in Wyoming shall be 

considered unsuitable unless 

mining can be conducted in such a 

way as to ensure that migratory 

bird habitat will not be adversely 

affected during the period it is in 

use.

Defer suitability decisions on high 

priority habitat for migratory bird species 

of management concern in Wyoming and 

evaluate on a case by case basis prior to 

lease issuance. Establish buffer zones 

for nesting areas during mining and 

reclamation planning after consultation 

with USFWS.

Evaluate suitability during consultation 

with USFWS.
Appendix B 

Final EIS, Wright Area Coal Lease Applications B-3 

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR THE NORTH HILIGHT 

FIELD LBA STUDY AREA

15. Fish and Wildlife Habitat for 

Resident Species. Federal lands 

which the surface management 

agency and state jointly agree are 

fish, wildlife and plant habitat of 

resident species of high interest to 

the state, and which are essential 

for maintaining these priority 

wildlife species, shall be considered 

unsuitable unless mining can be 

conducted in such a way as to 

ensure no long-term impact on the 

species being provided will occur.

Defer suitability decisions on grouse leks 

and evaluate on a case by case basis 

prior to lease issuance. Establish buffer 

zones after consultation with WGFD.

There is currently one occupied and one 

unoccupied/abandoned (no activity for 10 

consecutive years) sage-grouse lek 

identified on lands within the North 

Hilight Field LBA study area. There are 

currently no other occupied or 

unoccupied sage-grouse leks within 2 

miles of the North Hilight Field LBA study 

area. Evaluate this criterion prior to lease 

issuance. Establish buffer zones during 

mining and reclamation planning after 

consultation with WGFD.

16. Floodplains. Federal lands in 

riverine, coastal, and special 

floodplains shall be considered 

unsuitable where it is determined 

that mining could not be 

undertaken without substantial 

threat of loss of life or property.

The BLM and USFS have determined that 

the identified floodplains in the general 

review area could potentially be mined. 

Therefore, all lands within the general 

review area are considered suitable.

Site-specific stipulations and resource 

protection safeguards will be applied if 

necessary during mining and reclamation 

planning. There are no unsuitable 

findings under Criterion 16 for the North 

Hilight Field LBA study area.

17. Municipal Watersheds. Federal 

lands which have been committed 

by the surface management agency 

to use as municipal watersheds 

shall be considered unsuitable.

There are no designated municipal 

watersheds in the general review area.

There are no unsuitable findings under 

Criterion 17 for the North Hilight Field 

LBA study area

18. National Resource Waters. 

Federal lands with national 

resource waters, as identified by 

states in their water quality 

management plans, and 1⁄4-mile 

buffer zones shall be unsuitable.

There are no designated national 

resource waters within the general review 

area.

There are no unsuitable findings under 

Criterion 18 for the North Hilight Field 

LBA study area.

19. Alluvial Valley Floors. Federal 

lands identified by the surface 

management agency, in 

consultation with the state, as 

AVFs where mining would 

interrupt, discontinue or preclude 

farming, are unsuitable. 

Additionally, when mining federal 

lands outside an AVF would 

materially damage the quality or 

quantity of water in surface or 

underground water systems that 

would supply AVFs, the land shall 

be considered unsuitable.

Consider areas determined to contain 

AVFs significant to farming as 

unsuitable. Defer decisions on other 

AVFs and analyze on a case-by-case 

basis prior to lease issuance.

No AVFs or potential AVFs have been 

identified on the North Hilight Field LBA 

study area with characteristics indicating 

potential significance to farming. There 

are no unsuitable findings under Criterion 

19 for the North Hilight Field LBA study 

area.

20. State or Indian Tribe Criteria. 

Federal lands to which is 

applicable a criterion proposed by 

the state or Indian tribe located in 

the planning area and adopted by 

rulemaking by the Secretary are 

unsuitable.

There are no criterion proposed by state 

or Indian tribes that have been approved 

by the Secretary of the Interior. No tribal 

lands are located in or near the general 

review area.

There are no unsuitability findings for this 

criterion on the North Hilight Field LBA 

study area.
Appendix B 

B-4 Final EIS, Wright Area Coal Lease Applications

APPENDIX B. UNSUITABILITY CRITERIA FOR THE SOUTH HIGHLIGHT 

FIELD LBA STUDY AREA

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR THE SOUTH HILIGHT 

FIELD LBA STUDY AREA

1. Federal Land Systems. With 

certain exceptions that do not 

apply to this tract, all federal lands 

included in the following systems 

are unsuitable for mining: 

National Parks, National Wildlife 

Refuges, National System of Trails, 

National Wilderness Preservation 

System, National Wild and Scenic 

Rivers, National Recreation Areas, 

Lands acquired through the Land 

and Water Conservation Fund, 

National Forests and Federal lands 

in incorporated cities, towns and 

villages.

There are Federal lands located around 

Gillette, Sheridan, and Wright that were 

determined to be unsuitable under this 

criterion. TBNG lands are included in 

the South Hilight Field LBA study area. 

The TBNG is not a proclaimed National 

Forest.

None of the federal lands determined to be 

unsuitable under Criterion 1 are present 

on the South Hilight Field LBA study 

area. Therefore, there are no unsuitable 

findings under this criterion.

2. Rights-Of-Way and Easements. 

Federal lands that are within 

ROWs or easements or within 

surface leases for residential, 

commercial, industrial or other 

public purposes, on federally 

owned surface, are unsuitable for 

mining.

Portions of the BNSF & UP railroad ROW, 

the Tri-County 230-Kv transmission line 

ROW, the Wyoming State Highway 450 

ROW, and the I-90 ROW were found to be 

unsuitable under this criterion within the 

general review area.

The portions of the Tri-County 230-Kv 

transmission line ROW, the Wyoming 

State Highway 450 ROW, and the I-90 

ROW that were determined to be 

unsuitable are not located on the South 

Hilight Field LBA study area. A portion of 

the north-south BNSF & UP railroad ROW 

that was found to be unsuitable for 

mining is located on the western 

boundary of tract as applied for and 

under Alternative 2. Therefore, this 

portion of the BNSF & UP railroad ROW 

was designated unsuitable and the lease 

will be stipulated to exclude mining within 

the ROW.

3. Buffer Zones for Rights-Of-Way, 

Communities, and Buildings. 

Federal lands within 100 ft of a 

ROW of a public road or a 

cemetery; or within 300 ft of any 

public building, school, church, 

community or institutional 

building or public park; or within 

300 ft of an occupied dwelling are 

unsuitable for mining.

Portions of Wyoming State Highway 450, 

Interstate Highway I-90, and one 

cemetery were found to be unsuitable 

under this criterion. Decisions were 

deferred on other highways/roads, 

occupied dwellings, and one school until 

an application to lease is filed. 

Highway 450, I-90, and the cemetery are 

not located on the South Hilight Field LBA 

study area. No occupied dwellings or 

schools are located on the study area. 

Portions of the ROWs of the Hilight and 

Reno roads, both county roads, are 

located on the tract as applied for and/or 

under Alternative 2. Therefore, the 

portions of the South Hilight Field LBA 

study area within the ROWs of the Hilight 

and Reno roads and the associated 100-ft 

buffer zones are designated unsuitable 

and the lease will be stipulated to exclude 

mining within these areas unless a permit 

to move the road is approved by Campbell 

County Board of Commissioners.

4. Wilderness Study Areas. Federal 

lands designated as wilderness 

study areas are unsuitable for 

mining while under review for 

possible wilderness designation.

No lands in the general review area are 

within a wilderness study area.

There are no unsuitable findings under 

Criterion 4 for the South Hilight Field LBA 

study area.

5. Scenic Areas. Scenic federal 

lands designated by visual 

resource management analysis as 

Class I (outstanding visual quality 

or high visual sensitivity) but not 

currently on National Register of 

Natural Landmarks are unsuitable.

No lands in the general review area meet 

the scenic criteria as outlined.

There are no unsuitable findings under 

Criterion 5 for the South Hilight Field LBA 

study area.

6. Land Used for Scientific Study. 

Federal lands under permit by the 

surface management agency and 

being used for scientific studies 

involving food or fiber production, 

natural resources, or technology 

demonstrations and experiments 

are unsuitable for the duration of 

the study except where mining 

would not jeopardize the purpose 

of the study.

Two vegetation monitoring study sites on 

the TBNG (NE1⁄4 of Sec. 1, T.41N., R.71W. 

and NW1⁄4 NW1⁄4 of Sec. 30, T.41N., 

R.69W.), and the Hoe Creek Site (Sec. 7, 

T.47N., R.72W.) were found to be 

unsuitable under this criterion.

The vegetation monitoring sites and the 

Hoe Creek site are not located on the 

South Hilight Field LBA study area. There 

are no unsuitable findings under Criterion 

6 for the South Hilight Field LBA study 

area.
Appendix B 

Final EIS, Wright Area Coal Lease Applications B-5 

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR SOUTH HILIGHT FIELD 

LBA STUDY AREA

7. Cultural Resources. All publicly 

or privately owned places which 

are included in or are eligible for 

inclusion in the NRHP and an 

appropriate buffer zone are 

unsuitable.

On the basis of the consultation with 

SHPO, there were no unsuitable findings 

under this criterion in the general review 

area. Continue using the “Standard 

Archeological Stipulation” to new leases.

There are no unsuitable findings under 

Criterion 7 for the South Hilight Field LBA 

study area. The “Standard Archeological 

Stipulation” should be applied if this tract 

is leased.

8. Natural Areas. Federal lands 

designated as natural areas or 

National Natural Landmarks are 

unsuitable.

No lands in the general review area are 

designated as natural areas or as 

National Natural Landmarks.

There are no unsuitable findings under 

Criterion 8 for the South Hilight Field LBA 

study area.

9. Critical Habitat for Threatened 

or Endangered Plant and Animal 

Species. Federally designated 

critical habitat for threatened or 

endangered plant and animal 

species, and scientifically 

documented essential habitat for 

threatened or endangered species 

are unsuitable.

There is no federally designated critical 

habitat for threatened or endangered 

plant or animal species within the 

general review area.

There are no unsuitable findings under 

Criterion 9 for the South Hilight Field LBA 

study area.

10. State Listed Threatened or 

Endangered Species. Federal 

lands containing habitat 

determined to be critical or 

essential for plant or animal 

species listed by a state pursuant 

to state law as threatened or 

endangered shall be considered 

unsuitable.

Wyoming does not maintain a state list of 

threatened or endangered species of 

plants or animals. Therefore, this 

criterion does not apply.

There are no unsuitable findings under 

Criterion 10 for the South Hilight Field 

LBA study area.

11. Bald or Golden Eagle Nests. An 

active bald or golden eagle nest 

and appropriate buffer zone are 

unsuitable unless the lease can be 

conditioned so that eagles will not 

be disturbed during breeding 

season or unless golden eagle 

nests will be moved.

Defer suitability decisions and evaluate 

bald and golden eagle nests on a case by 

case basis at the time of leasing. 

Establish buffer zones around nests 

during mining and reclamation planning 

after consultation with USFWS.

There are currently no bald or golden 

eagle nests (active or inactive) on the 

South Hilight Field LBA study area. 

Evaluate suitability prior to lease 

issuance during consultation with 

USFWS.

12. Bald and Golden Eagle Roost and 

Concentration Areas. Bald and 

golden eagle roost and 

concentration areas on federal 

lands used during migration and 

wintering are unsuitable unless 

mining can be conducted in such a 

way as to ensure that eagles shall 

not be adversely disturbed.

Defer suitability decisions and evaluate 

bald and golden eagle roost areas on a 

case by case basis prior to lease 

issuance. Establish buffer zones after 

consultation with USFWS.

There are no identified roost sites on the 

South Hilight Field LBA study area. 

Evaluate suitability prior to lease 

issuance during consultation with 

USFWS.

13. Falcon Nesting Sites and Buffer 

Zones. Federal lands containing 

active falcon (excluding kestrel) 

cliff nesting sites and a suitable 

buffer zone shall be considered 

unsuitable unless mining can be 

conducted in such a way as to 

ensure the falcons will not be 

adversely affected.

Defer suitability decisions on falcon 

nesting sites and evaluate on a case by 

case basis prior to lease issuance. 

Establish buffer zones around nesting 

sites after consultation with USFWS.

No falcon nesting sites have been 

identified on the South Hilight Field LBA 

study area. There are no unsuitable 

findings under Criterion 13 for the South 

Hilight Field LBA study area.

14. Habitat for Migratory Bird 

Species. Federal lands which are 

high priority habitat for migratory 

bird species of management 

concern in Wyoming shall be 

considered unsuitable unless 

mining can be conducted in such a 

way as to ensure that migratory 

bird habitat will not be adversely 

affected during the period it is in 

use.

Defer suitability decisions on high 

priority habitat for migratory bird species 

of management concern in Wyoming and 

evaluate on a case by case basis prior to 

lease issuance. Establish buffer zones 

for nesting areas during mining and 

reclamation planning after consultation 

with USFWS.

Evaluate suitability during consultation 

with USFWS.
Appendix B 

B-6 Final EIS, Wright Area Coal Lease Applications

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR SOUTH HILIGHT FIELD 

STUDY AREA

15. Fish and Wildlife Habitat for 

Resident Species. Federal lands 

which the surface management 

agency and state jointly agree are 

fish, wildlife and plant habitat of 

resident species of high interest to 

the state, and which are essential 

for maintaining these priority 

wildlife species, shall be considered 

unsuitable unless mining can be 

conducted in such a way as to 

ensure no long-term impact on the 

species being provided will occur.

Defer suitability decisions on grouse leks 

and evaluate on a case by case basis 

prior to lease issuance. Establish buffer 

zones after consultation with WGFD.

There are currently are no occupied 

(active within the last 10 years) or 

unoccupied (destroyed or abandoned) 

sage-grouse leks indentified on lands 

within the South Hilight Field LBA study 

area. There is currently one unoccupied 

(destroyed) sage-grouse lek located on an 

existing Black Thunder Mine lease within 

2 miles of the South Hilight Field LBA 

study area. Evaluate this criterion prior 

to lease issuance. Establish buffer zones 

during mining and reclamation planning 

after consultation with WGFD.

16. Floodplains. Federal lands in 

riverine, coastal, and special 

floodplains shall be considered 

unsuitable where it is determined 

that mining could not be 

undertaken without substantial 

threat of loss of life or property.

The BLM and USFS have determined that 

the identified floodplains in the general 

review area could potentially be mined. 

Therefore, all lands within the general 

review area are considered suitable.

Site-specific stipulations and resource 

protection safeguards will be applied if 

necessary during mining and reclamation 

planning. There are no unsuitable 

findings under Criterion 16 for the South 

Hilight Field LBA study area.

17. Municipal Watersheds. Federal 

lands which have been committed 

by the surface management agency 

to use as municipal watersheds 

shall be considered unsuitable.

There are no designated municipal 

watersheds in the general review area.

There are no unsuitable findings under 

Criterion 17 for the South Hilight Field 

LBA study area.

18. National Resource Waters. 

Federal lands with national 

resource waters, as identified by 

states in their water quality 

management plans, and 1⁄4-mile 

buffer zones shall be unsuitable.

There are no designated national 

resource waters within the general review 

area.

There are no unsuitable findings under 

Criterion 18 for the South Hilight Field 

LBA study area.

19. Alluvial Valley Floors. Federal 

lands identified by the surface 

management agency, in 

consultation with the state, as 

AVFs where mining would 

interrupt, discontinue or preclude 

farming, are unsuitable. 

Additionally, when mining federal 

lands outside an AVF would 

materially damage the quality or 

quantity of water in surface or 

underground water systems that 

would supply AVFs, the land shall 

be considered unsuitable.

Consider areas determined to contain 

AVFs significant to farming as 

unsuitable. Defer decisions on other 

AVFs and analyze on a case-by-case 

basis prior to lease issuance.

No AVFs or potential AVFs have been 

identified on the South Hilight Field LBA 

study area with characteristics indicating 

potential significance to farming. There 

are no unsuitable findings under Criterion 

19 for the South Hilight Field LBA study 

area.

20. State or Indian Tribe Criteria. 

Federal lands to which is 

applicable a criterion proposed by 

the state or Indian tribe located in 

the planning area and adopted by 

rulemaking by the Secretary are 

unsuitable.

There are no criterion proposed by state 

or Indian tribes that have been approved 

by the Secretary of the Interior. No tribal 

lands are located in or near the general 

review area.

There are no unsuitability findings for this 

criterion on the South Hilight Field LBA 

study area.
Appendix B 

Final EIS, Wright Area Coal Lease Applications B-7 

APPENDIX B. UNSUITABILITY CRITERIA FOR THE WEST HILIGHT FIELD 

LBA STUDY AREA

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR WEST HILIGHT FIELD 

LBA STUDY AREA

1. Federal Land Systems. With 

certain exceptions that do not 

apply to this tract, all federal lands 

included in the following systems 

are unsuitable for mining: 

National Parks, National Wildlife 

Refuges, National System of Trails, 

National Wilderness Preservation 

System, National Wild and Scenic 

Rivers, National Recreation Areas, 

Lands acquired through the Land 

and Water Conservation Fund, 

National Forests and Federal lands 

in incorporated cities, towns and 

villages.

There are Federal lands located around 

Gillette, Sheridan, and Wright that were 

determined to be unsuitable under this 

criterion. TBNG lands are included in 

the West Hilight Field LBA study area. 

The TBNG is not a proclaimed National 

Forest.

None of the federal lands determined to be 

unsuitable under Criterion 1 are present 

on the West Hilight Field LBA study area. 

Therefore, there are no unsuitable 

findings under this criterion.

2. Rights-Of-Way and Easements. 

Federal lands that are within 

ROWs or easements or within 

surface leases for residential, 

commercial, industrial or other 

public purposes, on federally 

owned surface, are unsuitable for 

mining.

Portions of the BNSF & UP railroad 

ROWs, the Tri-County 230-Kv 

transmission line ROW, the Wyoming 

State Highway 450 ROW, and the I-90 

ROW were found to be unsuitable under 

this criterion within the general review 

area.

The portions of the Tri-County 230-Kv 

transmission line ROW, the Wyoming 

State Highway 450 ROW, and the I-90 

ROW that were determined to be 

unsuitable are not located on the West 

Hilight Field LBA study area. A portion of 

the north-south BNSF & UP railroad ROW 

that was found to be unsuitable for 

mining is located on the eastern boundary 

of the tract configured under Alternative 

2. Therefore, this portion of the BNSF & 

UP railroad ROW was designated 

unsuitable and the lease will be stipulated 

to exclude mining within the ROW.

3. Buffer Zones for Rights-Of-Way, 

Communities, and Buildings. 

Federal lands within 100 ft of a 

ROW of a public road or a 

cemetery; or within 300 ft of any 

public building, school, church, 

community or institutional 

building or public park; or within 

300 ft of an occupied dwelling are 

unsuitable for mining.

Portions of Wyoming State Highway 450, 

Interstate Highway I-90, and one 

cemetery were found to be unsuitable 

under this criterion. Decisions were 

deferred on other highways/roads, 

occupied dwellings, and one school until 

an application to lease is filed.

I-90 and the cemetery are not located on 

the West Hilight Field LBA study area. No 

occupied dwellings or schools are located 

on the study area. The West Hilight Field 

LBA study area includes a portion of 

Highway 450 west of the intersection with 

the north-south main BNSF & UP railroad 

trunk line, which was not designated 

unsuitable for mining under Criterion 2. 

However, a portion of the Highway 450 

ROW is located on the tract as applied for 

and under Alternatives 2 and 3. A portion 

of the ROW of the Hilight Road, a county 

road, is also located on the tract 

configured under Alternatives 2 and 3. 

Therefore, the portions of the West Hilight 

Field LBA study area within the ROWs of 

Highway 450 and Hilight Road and the 

associated 100-ft buffer zones are 

designated unsuitable and the lease will 

be stipulated to exclude mining within 

these areas unless permits to move the 

highway and road are approved by 

Wyoming Department of Transportation 

and Campbell County Commissioners, 

respectively. 

4. Wilderness Study Areas. Federal 

lands designated as wilderness 

study areas are unsuitable for 

mining while under review for 

possible wilderness designation.

No lands in the general review area are 

within a wilderness study area.

There are no unsuitable findings under 

Criterion 4 for the West Hilight Field LBA 

study area.

5. Scenic Areas. Scenic federal 

lands designated by visual 

resource management analysis as 

Class I (outstanding visual quality 

or high visual sensitivity) but not 

currently on National Register of 

Natural Landmarks are unsuitable.

No lands in the general review area meet 

the scenic criteria as outlined.

There are no unsuitable findings under 

Criterion 5 for the West Hilight Field LBA 

study area.
Appendix B 

B-8 Final EIS, Wright Area Coal Lease Applications

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR WEST HILIGHT FIELD 

LBA STUDY AREA

6. Land Used for Scientific Study. 

Federal lands under permit by the 

surface management agency and 

being used for scientific studies 

involving food or fiber production, 

natural resources, or technology 

demonstrations and experiments 

are unsuitable for the duration of 

the study except where mining 

would not jeopardize the purpose 

of the study.

Two vegetation monitoring study sites on 

the TBNG (NE1⁄4 of Sec. 1, T.41N., R.71W. 

and NW1⁄4 NW1⁄4 of Sec. 30, T.41N., 

R.69W.), and the Hoe Creek Site (Sec. 7, 

T.47N., R.72W.) were found to be 

unsuitable under this criterion.

The vegetation monitoring sites and the 

Hoe Creek site are not located on the West 

Hilight Field LBA study area. There are 

no unsuitable findings under Criterion 6 

for the West Hilight Field LBA study area.

7. Cultural Resources. All publicly 

or privately owned places which 

are included in or are eligible for 

inclusion in the NRHP and an 

appropriate buffer zone are 

unsuitable.

On the basis of the consultation with 

SHPO, there were no unsuitable findings 

under this criterion in the general review 

area. Continue using the “Standard 

Archeological Stipulation” to new leases.

There are no unsuitable findings under 

Criterion 7 for the West Hilight Field LBA 

study area. The “Standard Archeological 

Stipulation” should be applied if this tract 

is leased.

8. Natural Areas. Federal lands 

designated as natural areas or 

National Natural Landmarks are 

unsuitable.

No lands in the general review area are 

designated as natural areas or as 

National Natural Landmarks.

There are no unsuitable findings under 

Criterion 8 for the West Hilight Field LBA 

study area.

9. Critical Habitat for Threatened 

or Endangered Plant and Animal 

Species. Federally designated 

critical habitat for threatened or 

endangered plant and animal 

species, and scientifically 

documented essential habitat for 

threatened or endangered species 

are unsuitable.

There is no federally designated critical 

habitat for threatened or endangered 

plant or animal species within the 

general review area.

There are no unsuitable findings under 

Criterion 9 for the West Hilight Field LBA 

study area.

10. State Listed Threatened or 

Endangered Species. Federal 

lands containing habitat 

determined to be critical or 

essential for plant or animal 

species listed by a state pursuant 

to state law as threatened or 

endangered shall be considered 

unsuitable.

Wyoming does not maintain a state list of 

threatened or endangered species of 

plants or animals. Therefore, this 

criterion does not apply.

There are no unsuitable findings under 

Criterion 10 for the West Hilight Field LBA 

study area.

11. Bald or Golden Eagle Nests. An 

active bald or golden eagle nest 

and appropriate buffer zone are 

unsuitable unless the lease can be 

conditioned so that eagles will not 

be disturbed during breeding 

season or unless golden eagle 

nests will be moved.

Defer suitability decisions and evaluate 

bald and golden eagle nests on a case by 

case basis at the time of leasing. 

Establish buffer zones around nests 

during mining and reclamation planning 

after consultation with USFWS.

There are currently no bald eagle nests 

(active or inactive) on the West Hilight 

Field LBA study area. There is currently 

one active golden eagle nest within 1⁄4 mile 

of the West Hilight Field LBA study area. 

Evaluate suitability prior to lease 

issuance during consultation with 

USFWS.

12. Bald and Golden Eagle Roost and 

Concentration Areas. Bald and 

golden eagle roost and 

concentration areas on federal 

lands used during migration and 

wintering are unsuitable unless 

mining can be conducted in such a 

way as to ensure that eagles shall 

not be adversely disturbed.

Defer suitability decisions and evaluate 

bald and golden eagle roost areas on a 

case by case basis prior to lease 

issuance. Establish buffer zones after 

consultation with USFWS.

There are no identified roost sites on the 

West Hilight Field LBA study area. 

Evaluate suitability prior to lease 

issuance during consultation with 

USFWS.

13. Falcon Nesting Sites and Buffer 

Zones. Federal lands containing 

active falcon (excluding kestrel) 

cliff nesting sites and a suitable 

buffer zone shall be considered 

unsuitable unless mining can be 

conducted in such a way as to 

ensure the falcons will not be 

adversely affected.

Defer suitability decisions on falcon 

nesting sites and evaluate on a case by 

case basis prior to lease issuance. 

Establish buffer zones around nesting 

sites after consultation with USFWS.

No falcon nesting sites have been 

identified on the West Hilight Field LBA 

study area. There are no unsuitable 

findings under Criterion 13 for the West 

Hilight Field LBA study area.
Appendix B 

Final EIS, Wright Area Coal Lease Applications B-9 

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR WEST HILIGHT FIELD 

LBA STUDY AREA

14. Habitat for Migratory Bird 

Species. Federal lands which are 

high priority habitat for migratory 

bird species of management 

concern in Wyoming shall be 

considered unsuitable unless 

mining can be conducted in such a 

way as to ensure that migratory 

bird habitat will not be adversely 

affected during the period it is in 

use.

Defer suitability decisions on high 

priority habitat for migratory bird species 

of management concern in Wyoming and 

evaluate on a case by case basis prior to 

lease issuance. Establish buffer zones 

for nesting areas during mining and 

reclamation planning after consultation 

with USFWS.

Evaluate suitability during consultation 

with USFWS.

15. Fish and Wildlife Habitat for 

Resident Species. Federal lands 

which the surface management 

agency and state jointly agree are 

fish, wildlife and plant habitat of 

resident species of high interest to 

the state, and which are essential 

for maintaining these priority 

wildlife species, shall be considered 

unsuitable unless mining can be 

conducted in such a way as to 

ensure no long-term impact on the 

species being provided will occur.

Defer suitability decisions on grouse leks 

and evaluate on a case by case basis 

prior to lease issuance. Establish buffer 

zones after consultation with WGFD.

There is currently one undetermined (no 

documented activity for the last 10 years, 

but insufficient information to designate 

occupied) sage-grouse lek identified on 

lands within the West Hilight Field LBA 

study area, and one undetermined sagegrouse lek located within 2 miles of the 

West Hilight Field LBA study area. 

Evaluate this criterion prior to lease 

issuance. Establish buffer zones during 

mining and reclamation planning after 

consultation with WGFD.

16. Floodplains. Federal lands in 

riverine, coastal, and special 

floodplains shall be considered 

unsuitable where it is determined 

that mining could not be 

undertaken without substantial 

threat of loss of life or property.

The BLM and USFS have determined that 

the identified floodplains in the general 

review area could potentially be mined. 

Therefore, all lands within the general 

review area are considered suitable.

Site-specific stipulations and resource 

protection safeguards will be applied if 

necessary during mining and reclamation 

planning. There are no unsuitable 

findings under Criterion 16 for the West 

Hilight Field LBA study area.

17. Municipal Watersheds. Federal 

lands which have been committed 

by the surface management agency 

to use as municipal watersheds 

shall be considered unsuitable.

There are no designated municipal 

watersheds in the general review area.

There are no unsuitable findings under 

Criterion 17 for the West Hilight Field LBA 

study area.

18. National Resource Waters. 

Federal lands with national 

resource waters, as identified by 

states in their water quality 

management plans, and 1⁄4-mile 

buffer zones shall be unsuitable.

There are no designated national 

resource waters within the general review 

area.

There are no unsuitable findings under 

Criterion 18 for the West Hilight Field LBA 

study area.

19. Alluvial Valley Floors. Federal 

lands identified by the surface 

management agency, in 

consultation with the state, as 

AVFs where mining would 

interrupt, discontinue or preclude 

farming, are unsuitable. 

Additionally, when mining federal 

lands outside an AVF would 

materially damage the quality or 

quantity of water in surface or 

underground water systems that 

would supply AVFs, the land shall 

be considered unsuitable.

Consider areas determined to contain 

AVFs significant to farming as 

unsuitable. Defer decisions on other 

AVFs and analyze on a case-by-case 

basis prior to lease issuance.

No AVFs or potential AVFs have been 

identified on the West Hilight Field LBA 

study area with characteristics indicating 

potential significance to farming. There 

are no unsuitable findings under Criterion 

19 for the West Hilight Field LBA study 

area.

20. State or Indian Tribe Criteria. 

Federal lands to which is 

applicable a criterion proposed by 

the state or Indian tribe located in 

the planning area and adopted by 

rulemaking by the Secretary are 

unsuitable.

There are no criterion proposed by state 

or Indian tribes that have been approved 

by the Secretary of the Interior. No tribal 

lands are located in or near the general 

review area.

There are no unsuitability findings for this 

criterion on the West Hilight Field LBA 

study area.
Appendix B 

B-10 Final EIS, Wright Area Coal Lease Applications

APPENDIX B. UNSUITABILITY CRITERIA FOR THE WEST JACOBS 

RANCH LBA STUDY AREA

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR THE WEST JACOBS 

RANCH LBA STUDY AREA

1. Federal Land Systems. With 

certain exceptions that do not 

apply to this tract, all federal lands 

included in the following systems 

are unsuitable for mining: 

National Parks, National Wildlife 

Refuges, National System of Trails, 

National Wilderness Preservation 

System, National Wild and Scenic 

Rivers, National Recreation Areas, 

Lands acquired through the Land 

and Water Conservation Fund, 

National Forests and Federal lands 

in incorporated cities, towns and 

villages.

There are Federal lands located around 

Gillette, Sheridan, and Wright that were 

determined to be unsuitable under this 

criterion. No TBNG lands are included in 

the West Jacobs Ranch LBA study area. 

The TBNG is not a proclaimed National 

Forest.

None of the federal lands determined to be 

unsuitable under Criterion 1 are present 

on the West Jacobs Ranch LBA study 

area. Therefore, there are no unsuitable 

findings under this criterion.

2. Rights-Of-Way and Easements. 

Federal lands that are within 

ROWs or easements or within 

surface leases for residential, 

commercial, industrial or other 

public purposes, on federally 

owned surface, are unsuitable for 

mining.

Portions of the BNSF & UP railroad 

ROWs, the Tri-County 230-Kv 

transmission line ROW, the Wyoming 

State Highway 450 ROW, and the I-90 

ROW were found to be unsuitable under 

this criterion within the general review 

area.

The portions of the Tri-County 230-Kv 

transmission line ROW, the Wyoming 

State Highway 450 ROW, and the I-90 

ROW that were determined to be 

unsuitable are not located on the West 

Jacobs Ranch LBA study area. A portion 

of the north-south BNSF & UP railroad 

ROW that was found to be unsuitable for 

mining is located on the eastern boundary 

of the tract as applied for and under 

Alternative 2. Therefore, this portion of 

the BNSF & UP railroad ROW was 

designated unsuitable and the lease will 

be stipulated to exclude mining within the 

ROW. 

3. Buffer Zones for Rights-Of-Way, 

Communities, and Buildings. 

Federal lands within 100 ft of a 

ROW of a public road or a 

cemetery; or within 300 ft of any 

public building, school, church, 

community or institutional 

building or public park; or within 

300 ft of an occupied dwelling are 

unsuitable for mining.

Portions of Wyoming State Highway 450, 

Interstate Highway I-90, and one 

cemetery were found to be unsuitable 

under this criterion. Decisions were 

deferred on other highways/roads, 

occupied dwellings, and one school until 

an application to lease is filed.

I-90 and the cemetery are not located on 

the West Jacobs Ranch LBA study area. 

No occupied dwellings or schools are 

located on the study area. The West 

Jacobs Ranch LBA study area includes a 

portion of Highway 450 west of the 

intersection with the north-south main 

BNSF & UP railroad trunk line, which was 

not designated unsuitable for mining 

under Criterion 2. However, a portion of 

the Highway 450 ROW is located on the 

tract as applied for and under Alternative 

2. A portion of the ROW of the Hilight 

Road, a county road, is also located on 

the tract as applied for and under 

Alternative 2. Therefore, the portions of 

the West Jacobs Ranch LBA study area 

within the ROWs of Highway 450 and 

Hilight Road and the associated 100-ft 

buffer zones are designated unsuitable 

and the lease will be stipulated to exclude 

mining within these areas unless permits 

to move the highway and road are 

approved by Wyoming Department of 

Transportation and Campbell County 

Commissioners, respectively. 

4. Wilderness Study Areas. Federal 

lands designated as wilderness 

study areas are unsuitable for 

mining while under review for 

possible wilderness designation.

No lands in the general review area are 

within a wilderness study area.

There are no unsuitable findings under 

Criterion 4 for the West Jacobs Ranch 

LBA study area.

5. Scenic Areas. Scenic federal 

lands designated by visual 

resource management analysis as 

Class I (outstanding visual quality 

or high visual sensitivity) but not 

currently on National Register of 

Natural Landmarks are unsuitable.

No lands in the general review area meet 

the scenic criteria as outlined.

There are no unsuitable findings under 

Criterion 5 for the West Jacobs Ranch 

LBA study area.
Appendix B 

Final EIS, Wright Area Coal Lease Applications B-11 

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR THE WEST JACOBS 

RANCH LBA STUDY AREA

6. Land Used for Scientific Study. 

Federal lands under permit by the 

surface management agency and 

being used for scientific studies 

involving food or fiber production, 

natural resources, or technology 

demonstrations and experiments 

are unsuitable for the duration of 

the study except where mining 

would not jeopardize the purpose 

of the study.

Two vegetation monitoring study sites on 

the TBNG (NE1⁄4 of Sec. 1, T.41N., R.71W. 

and NW1⁄4 NW1⁄4 of Sec. 30, T.41N., 

R.69W.), and the Hoe Creek Site (Sec. 7, 

T.47N., R.72W.) were found to be 

unsuitable under this criterion.

The vegetation monitoring sites and the 

Hoe Creek site are not located on the West 

Jacobs Ranch LBA study area. There are 

no unsuitable findings under Criterion 6 

for the West Jacobs Ranch LBA study 

area.

7. Cultural Resources. All publicly 

or privately owned places which 

are included in or are eligible for 

inclusion in the NRHP and an 

appropriate buffer zone are 

unsuitable.

On the basis of the consultation with 

SHPO, there were no unsuitable findings 

under this criterion in the general review 

area. Continue using the “Standard 

Archeological Stipulation” to new leases.

There are no unsuitable findings under 

Criterion 7 for the West Jacobs Ranch 

LBA study area. The “Standard 

Archeological Stipulation” should be 

applied if this tract is leased.

8. Natural Areas. Federal lands 

designated as natural areas or 

National Natural Landmarks are 

unsuitable.

No lands in the general review area are 

designated as natural areas or as 

National Natural Landmarks.

There are no unsuitable findings under 

Criterion 8 for the West Jacobs Ranch 

LBA study area.

9. Critical Habitat for Threatened 

or Endangered Plant and Animal 

Species. Federally designated 

critical habitat for threatened or 

endangered plant and animal 

species, and scientifically 

documented essential habitat for 

threatened or endangered species 

are unsuitable.

There is no federally designated critical 

habitat for threatened or endangered 

plant or animal species within the 

general review area.

There are no unsuitable findings under 

Criterion 9 for the West Jacobs Ranch 

LBA study area.

10. State Listed Threatened or 

Endangered Species. Federal 

lands containing habitat 

determined to be critical or 

essential for plant or animal 

species listed by a state pursuant 

to state law as threatened or 

endangered shall be considered 

unsuitable.

Wyoming does not maintain a state list of 

threatened or endangered species of 

plants or animals. Therefore, this 

criterion does not apply.

There are no unsuitable findings under 

Criterion 10 for the West Jacobs Ranch 

LBA study area.

11. Bald or Golden Eagle Nests. An 

active bald or golden eagle nest 

and appropriate buffer zone are 

unsuitable unless the lease can be 

conditioned so that eagles will not 

be disturbed during breeding 

season or unless golden eagle 

nests will be moved.

Defer suitability decisions and evaluate 

bald and golden eagle nests on a case by 

case basis at the time of leasing. 

Establish buffer zones around nests 

during mining and reclamation planning 

after consultation with USFWS.

There are currently no bald eagle nests 

(active or inactive) on the West Jacobs 

Ranch LBA study area. There is currently 

one active golden eagle nest on lands 

within the West Jacobs Ranch LBA study 

area. Evaluate suitability prior to lease 

issuance during consultation with 

USFWS.

12. Bald and Golden Eagle Roost and 

Concentration Areas. Bald and 

golden eagle roost and 

concentration areas on federal 

lands used during migration and 

wintering are unsuitable unless 

mining can be conducted in such a 

way as to ensure that eagles shall 

not be adversely disturbed.

Defer suitability decisions and evaluate 

bald and golden eagle roost areas on a 

case by case basis prior to lease 

issuance. Establish buffer zones after 

consultation with USFWS.

There are no identified roost sites on the 

West Jacobs Ranch LBA study area. 

Evaluate suitability prior to lease 

issuance during consultation with 

USFWS. 

13. Falcon Nesting Sites and Buffer 

Zones. Federal lands containing 

active falcon (excluding kestrel) 

cliff nesting sites and a suitable 

buffer zone shall be considered 

unsuitable unless mining can be 

conducted in such a way as to 

ensure the falcons will not be 

adversely affected.

Defer suitability decisions on falcon 

nesting sites and evaluate on a case by 

case basis prior to lease issuance. 

Establish buffer zones around nesting 

sites after consultation with USFWS.

No falcon nesting sites have been 

identified on the West Jacobs Ranch LBA 

study area. There are no unsuitable 

findings under Criterion 13 for the West 

Jacobs Ranch LBA study area.
Appendix B 

B-12 Final EIS, Wright Area Coal Lease Applications

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR THE WEST JACOBS 

RANCH LBA STUDY AREA

14. Habitat for Migratory Bird 

Species. Federal lands which are 

high priority habitat for migratory 

bird species of management 

concern in Wyoming shall be 

considered unsuitable unless 

mining can be conducted in such a 

way as to ensure that migratory 

bird habitat will not be adversely 

affected during the period it is in 

use.

Defer suitability decisions on high 

priority habitat for migratory bird species 

of management concern in Wyoming and 

evaluate on a case by case basis prior to 

lease issuance. Establish buffer zones 

for nesting areas during mining and 

reclamation planning after consultation 

with USFWS.

Evaluate suitability during consultation 

with USFWS.

15. Fish and Wildlife Habitat for 

Resident Species. Federal lands 

which the surface management 

agency and state jointly agree are 

fish, wildlife and plant habitat of 

resident species of high interest to 

the state, and which are essential 

for maintaining these priority 

wildlife species, shall be considered 

unsuitable unless mining can be 

conducted in such a way as to 

ensure no long-term impact on the 

species being provided will occur.

Defer suitability decisions on grouse leks 

and evaluate on a case by case basis 

prior to lease issuance. Establish buffer 

zones after consultation with WGFD.

There are currently are no occupied 

(active within the last 10 years) or 

unoccupied (destroyed or abandoned) 

sage-grouse leks identified on lands 

within the West Jacobs Ranch LBA study 

area. There are currently two 

undetermined (no documented activity for 

the last 10 years, but insufficient 

information to designate occupied) sagegrouse leks identified on lands adjacent to 

the LBA tract: one approximately 1 mile 

south-southwest and one approximately 

1.3 miles south-southwest of the West 

Jacobs Ranch LBA study area. Evaluate 

this criterion prior to lease issuance. 

Establish buffer zones during mining and 

reclamation planning after consultation 

with WGFD.

16. Floodplains. Federal lands in 

riverine, coastal, and special 

floodplains shall be considered 

unsuitable where it is determined 

that mining could not be 

undertaken without substantial 

threat of loss of life or property.

The BLM and USFS have determined that 

the identified floodplains in the general 

review area could potentially be mined. 

Therefore, all lands within the general 

review area are considered suitable.

Site-specific stipulations and resource 

protection safeguards will be applied if 

necessary during mining and reclamation 

planning. There are no unsuitable 

findings under Criterion 16 for the West 

Jacobs Ranch LBA study area.

17. Municipal Watersheds. Federal 

lands which have been committed 

by the surface management agency 

to use as municipal watersheds 

shall be considered unsuitable.

There are no designated municipal 

watersheds in the general review area.

There are no unsuitable findings under 

Criterion 17 for the West Jacobs Ranch 

LBA study area.

18. National Resource Waters. 

Federal lands with national 

resource waters, as identified by 

states in their water quality 

management plans, and 1⁄4-mile 

buffer zones shall be unsuitable.

There are no designated national 

resource waters within the general review 

area.

There are no unsuitable findings under 

Criterion 18 for the West Jacobs Ranch 

LBA study area.

19. Alluvial Valley Floors. Federal 

lands identified by the surface 

management agency, in 

consultation with the state, as 

AVFs where mining would 

interrupt, discontinue or preclude 

farming, are unsuitable. 

Additionally, when mining federal 

lands outside an AVF would 

materially damage the quality or 

quantity of water in surface or 

underground water systems that 

would supply AVFs, the land shall 

be considered unsuitable.

Consider areas determined to contain 

AVFs significant to farming as 

unsuitable. Defer decisions on other 

AVFs and analyze on a case-by-case 

basis prior to lease issuance.

No AVFs or potential AVFs have been 

identified on the West Jacobs Ranch LBA 

study area with characteristics indicating 

potential significance to farming. There 

are no unsuitable findings under Criterion 

19 for the West Jacobs Ranch LBA study 

area.

20. State or Indian Tribe Criteria. 

Federal lands to which is 

applicable a criterion proposed by 

the state or Indian tribe located in 

the planning area and adopted by 

rulemaking by the Secretary are 

unsuitable.

There are no criterion proposed by state 

or Indian tribes that have been approved 

by the Secretary of the Interior. No tribal 

lands are located in or near the general 

review area.

There are no unsuitability findings for this 

criterion on the West Jacobs Ranch LBA 

study area.
Appendix B 

Final EIS, Wright Area Coal Lease Applications B-13 

APPENDIX B. UNSUITABILITY CRITERIA FOR THE NORTH PORCUPINE 

LBA STUDY AREA

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR THE NORTH PORCUPINE 

LBA STUDY AREA

1. Federal Land Systems. With 

certain exceptions that do not 

apply to this tract, all federal lands 

included in the following systems 

are unsuitable for mining: 

National Parks, National Wildlife 

Refuges, National System of Trails, 

National Wilderness Preservation 

System, National Wild and Scenic 

Rivers, National Recreation Areas, 

Lands acquired through the Land 

and Water Conservation Fund, 

National Forests and Federal lands 

in incorporated cities, towns and 

villages.

There are Federal lands located around 

Gillette, Sheridan, and Wright that were 

determined to be unsuitable under this 

criterion. TBNG lands are included in 

the North Porcupine LBA study area. The 

TBNG is not a proclaimed National 

Forest.

None of the federal lands determined to be 

unsuitable under Criterion 1 are present 

on the North Porcupine LBA study area. 

Therefore, there are no unsuitable 

findings under this criterion.

2. Rights-Of-Way and Easements. 

Federal lands that are within 

ROWs or easements or within 

surface leases for residential, 

commercial, industrial or other 

public purposes, on federally 

owned surface, are unsuitable for 

mining. 

Portions of the BNSF & UP railroad 

ROWs, the Tri-County 230-Kv 

transmission line ROW, the Wyoming 

State Highway 450 ROW, and the I-90 

ROW were found to be unsuitable under 

this criterion within the general review 

area.

The portions of the Tri-County 230-Kv 

transmission line ROW, the Wyoming 

State Highway 450 ROW, and the I-90 

ROW that were determined to be 

unsuitable are not located on the North 

Porcupine LBA study area. A portion of 

the BNSF & UP railroad ROW that was 

found to be unsuitable for mining crosses 

the tract as applied for and under 

Alternative 2. Therefore, this portion of 

the BNSF & UP railroad ROW was 

designated unsuitable and the lease will 

be stipulated to exclude mining within the 

ROW. 

3. Buffer Zones for Rights-Of-Way, 

Communities, and Buildings. 

Federal lands within 100 ft of a 

ROW of a public road or a 

cemetery; or within 300 ft of any 

public building, school, church, 

community or institutional 

building or public park; or within 

300 ft of an occupied dwelling are 

unsuitable for mining.

Portions of Wyoming State Highway 450, 

Interstate Highway I-90, and one 

cemetery were found to be unsuitable 

under this criterion. Decisions were 

deferred on other highways/roads, 

occupied dwellings, and one school until 

an application to lease is filed.

Highway 450, I-90, and the cemetery are 

not located on the North Porcupine LBA 

study area. No occupied dwellings or 

schools are located on the study area. 

Portions of the ROWs of the Antelope, 

Matheson, and Mackey roads, all county 

roads, are located on the tract as applied 

for and under Alternative 2. The 

relocation of the Antelope Road and a 

portion of the Matheson Road within the 

LBA study area have been approved by 

the Campbell County Commissioners. 

Therefore, the portions of the North 

Porcupine LBA study area within the 

ROWs of the Mackey Road and a portion 

of the Matheson Road and the associated 

100-ft buffer zones are designated 

unsuitable for mining and the lease will 

be stipulated to exclude mining within 

these areas unless permits to move the 

roads are approved by Campbell County 

Board of Commissioners.

4. Wilderness Study Areas. Federal 

lands designated as wilderness 

study areas are unsuitable for 

mining while under review for 

possible wilderness designation.

No lands in the general review area are 

within a wilderness study area.

There are no unsuitable findings under 

Criterion 4 for the North Porcupine LBA 

study area.

5. Scenic Areas. Scenic federal 

lands designated by visual 

resource management analysis as 

Class I (outstanding visual quality 

or high visual sensitivity) but not 

currently on National Register of 

Natural Landmarks are unsuitable.

No lands in the general review area meet 

the scenic criteria as outlined.

There are no unsuitable findings under 

Criterion 5 for the North Porcupine LBA 

study area. 
Appendix B 

B-14 Final EIS, Wright Area Coal Lease Applications

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR THE NORTH PORCUPINE 

LBA STUDY AREA

6. Land Used for Scientific Study. 

Federal lands under permit by the 

surface management agency and 

being used for scientific studies 

involving food or fiber production, 

natural resources, or technology 

demonstrations and experiments 

are unsuitable for the duration of 

the study except where mining 

would not jeopardize the purpose 

of the study.

Two vegetation monitoring study sites on 

the TBNG (NE1⁄4 of Sec. 1, T.41N., R.71W. 

and NW1⁄4 NW1⁄4 of Sec. 30, T.41N., 

R.69W.), and the Hoe Creek Site (Sec. 7, 

T.47N., R.72W.) were found to be 

unsuitable under this criterion.

The vegetation monitoring sites and the 

Hoe Creek site are not located on the 

North Porcupine LBA study area. There 

are no unsuitable findings under Criterion 

6 for the North Porcupine LBA study area.

7. Cultural Resources. All publicly 

or privately owned places which 

are included in or are eligible for 

inclusion in the NRHP and an 

appropriate buffer zone are 

unsuitable.

On the basis of the consultation with 

SHPO, there were no unsuitable findings 

under this criterion in the general review 

area. Continue using the “Standard 

Archeological Stipulation” to new leases.

There are no unsuitable findings under 

Criterion 7 for the North Porcupine LBA 

study area. The “Standard Archeological 

Stipulation” should be applied if this tract 

is leased.

8. Natural Areas. Federal lands 

designated as natural areas or 

National Natural Landmarks are 

unsuitable.

No lands in the general review area are 

designated as natural areas or as 

National Natural Landmarks.

There are no unsuitable findings under 

Criterion 8 for the North Porcupine LBA 

study area.

9. Critical Habitat for Threatened 

or Endangered Plant and Animal 

Species. Federally designated 

critical habitat for threatened or 

endangered plant and animal 

species, and scientifically 

documented essential habitat for 

threatened or endangered species 

are unsuitable.

There is no federally designated critical 

habitat for threatened or endangered 

plant or animal species within the 

general review area.

There are no unsuitable findings under 

Criterion 9 for the North Porcupine LBA 

study area.

10. State Listed Threatened or 

Endangered Species. Federal 

lands containing habitat 

determined to be critical or 

essential for plant or animal 

species listed by a state pursuant 

to state law as threatened or 

endangered shall be considered 

unsuitable.

Wyoming does not maintain a state list of 

threatened or endangered species of 

plants or animals. Therefore, this 

criterion does not apply.

There are no unsuitable findings under 

Criterion 10 for the North Porcupine LBA 

study area.

11. Bald or Golden Eagle Nests. An 

active bald or golden eagle nest 

and appropriate buffer zone are 

unsuitable unless the lease can be 

conditioned so that eagles will not 

be disturbed during breeding 

season or unless golden eagle 

nests will be moved.

Defer suitability decisions and evaluate 

bald and golden eagle nests on a case by 

case basis at the time of leasing. 

Establish buffer zones around nests 

during mining and reclamation planning 

after consultation with USFWS.

There are currently no bald eagle nests 

(active or inactive) on the North Porcupine 

LBA study area. There are currently two 

active golden eagle nests on lands within 

the North Porcupine LBA study area. 

Evaluate suitability prior to lease 

issuance during consultation with 

USFWS.

12. Bald and Golden Eagle Roost and 

Concentration Areas. Bald and 

golden eagle roost and 

concentration areas on federal 

lands used during migration and 

wintering are unsuitable unless 

mining can be conducted in such a 

way as to ensure that eagles shall 

not be adversely disturbed.

Defer suitability decisions and evaluate 

bald and golden eagle roost areas on a 

case by case basis prior to lease 

issuance. Establish buffer zones after 

consultation with USFWS.

There are no identified roost sites on the 

North Porcupine LBA study area. 

Evaluate suitability prior to lease 

issuance during consultation with 

USFWS. 

13. Falcon Nesting Sites and Buffer 

Zones. Federal lands containing 

active falcon (excluding kestrel) 

cliff nesting sites and a suitable 

buffer zone shall be considered 

unsuitable unless mining can be 

conducted in such a way as to 

ensure the falcons will not be 

adversely affected.

Defer suitability decisions on falcon 

nesting sites and evaluate on a case by 

case basis prior to lease issuance. 

Establish buffer zones around nesting 

sites after consultation with USFWS.

No falcon nesting sites have been 

identified on the North Porcupine LBA 

study area. There are no unsuitable 

findings under Criterion 13 for the North 

Porcupine LBA study area.
Appendix B 

Final EIS, Wright Area Coal Lease Applications B-15 

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR THE NORTH PORCUPINE 

LBA STUDY AREA

14. Habitat for Migratory Bird 

Species. Federal lands which are 

high priority habitat for migratory 

bird species of management 

concern in Wyoming shall be 

considered unsuitable unless 

mining can be conducted in such a 

way as to ensure that migratory 

bird habitat will not be adversely 

affected during the period it is in 

use.

Defer suitability decisions on high 

priority habitat for migratory bird species 

of management concern in Wyoming and 

evaluate on a case by case basis prior to 

lease issuance. Establish buffer zones 

for nesting areas during mining and 

reclamation planning after consultation 

with USFWS.

Evaluate suitability during consultation 

with USFWS.

15. Fish and Wildlife Habitat for 

Resident Species. Federal lands 

which the surface management 

agency and state jointly agree are 

fish, wildlife and plant habitat of 

resident species of high interest to 

the state, and which are essential 

for maintaining these priority 

wildlife species, shall be considered 

unsuitable unless mining can be 

conducted in such a way as to 

ensure no long-term impact on the 

species being provided will occur.

Defer suitability decisions on grouse leks 

and evaluate on a case by case basis 

prior to lease issuance. Establish buffer 

zones after consultation with WGFD.

There is currently one occupied (active 

within the last 10 years) sage-grouse lek 

and no unoccupied (destroyed or 

abandoned) sage-grouse leks identified on 

lands within the North Porcupine LBA 

study area. There are currently two 

occupied sage-grouse leks identified on 

lands adjacent to the LBA tract: both are 

approximately 1.5 miles southeast of the 

LBA study area. There is also one 

unoccupied/abandoned (no activity for 10 

consecutive years) sage-grouse lek 

identified on lands adjacent to the LBA 

tract: approximately 0.5 mile southeast of 

the LBA study area. Evaluate this 

criterion prior to lease issuance. 

Establish buffer zones during mining and 

reclamation planning after consultation 

with WGFD.

16. Floodplains. Federal lands in 

riverine, coastal, and special 

floodplains shall be considered 

unsuitable where it is determined 

that mining could not be 

undertaken without substantial 

threat of loss of life or property.

The BLM and USFS have determined that 

the identified floodplains in the general 

review area could potentially be mined. 

Therefore, all lands within the general 

review area are considered suitable.

Site-specific stipulations and resource 

protection safeguards will be applied if 

necessary during mining and reclamation 

planning. There are no unsuitable 

findings under Criterion 16 for the North 

Porcupine LBA study area.

17. Municipal Watersheds. Federal 

lands which have been committed 

by the surface management agency 

to use as municipal watersheds 

shall be considered unsuitable.

There are no designated municipal 

watersheds in the general review area.

There are no unsuitable findings under 

Criterion 17 for the North Porcupine LBA 

study area.

18. National Resource Waters. 

Federal lands with national 

resource waters, as identified by 

states in their water quality 

management plans, and 1⁄4-mile 

buffer zones shall be unsuitable.

There are no designated national 

resource waters within the general review 

area.

There are no unsuitable findings under 

Criterion 18 for the North Porcupine LBA 

study area.

19. Alluvial Valley Floors. Federal 

lands identified by the surface 

management agency, in 

consultation with the state, as 

AVFs where mining would 

interrupt, discontinue or preclude 

farming, are unsuitable. 

Additionally, when mining federal 

lands outside an AVF would 

materially damage the quality or 

quantity of water in surface or 

underground water systems that 

would supply AVFs, the land shall 

be considered unsuitable.

Consider areas determined to contain 

AVFs significant to farming as 

unsuitable. Defer decisions on other 

AVFs and analyze on a case-by-case 

basis prior to lease issuance.

No AVFs or potential AVFs have been 

identified on the North Porcupine LBA 

study area with characteristics indicating 

potential significance to farming. There 

are no unsuitable findings under Criterion 

19 for the North Porcupine LBA study 

area.

20. State or Indian Tribe Criteria. 

Federal lands to which is 

applicable a criterion proposed by 

the state or Indian tribe located in 

the planning area and adopted by 

rulemaking by the Secretary are 

unsuitable.

There are no criterion proposed by state 

or Indian tribes that have been approved 

by the Secretary of the Interior. No tribal 

lands are located in or near the general 

review area.

There are no unsuitability findings for this 

criterion on the North Porcupine LBA 

study area.
Appendix B 

B-16 Final EIS, Wright Area Coal Lease Applications

APPENDIX B. UNSUITABILITY CRITERIA FOR THE SOUTH PORCUPINE 

LBA STUDY AREA

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR THE SOUTH PORCUPINE 

LBA STUDY AREA

1. Federal Land Systems. With 

certain exceptions that do not 

apply to this tract, all federal lands 

included in the following systems 

are unsuitable for mining: 

National Parks, National Wildlife 

Refuges, National System of Trails, 

National Wilderness Preservation 

System, National Wild and Scenic 

Rivers, National Recreation Areas, 

Lands acquired through the Land 

and Water Conservation Fund, 

National Forests and Federal lands 

in incorporated cities, towns and 

villages.

There are Federal lands located around 

Gillette, Sheridan, and Wright that were 

determined to be unsuitable under this 

criterion. TBNG lands are included in 

the South Porcupine LBA study area. 

The TBNG is not a proclaimed National 

Forest.

None of the federal lands determined to be 

unsuitable under Criterion 1 are present 

on the South Porcupine LBA study area. 

Therefore, there are no unsuitable 

findings under this criterion.

2. Rights-Of-Way and Easements. 

Federal lands that are within 

ROWs or easements or within 

surface leases for residential, 

commercial, industrial or other 

public purposes, on federally 

owned surface, are unsuitable for 

mining. 

Portions of the BNSF & UP railroad 

ROWs, the Tri-County 230-Kv 

transmission line ROW, the Wyoming 

State Highway 450 ROW, and the I-90 

ROW were found to be unsuitable under 

this criterion within the general review 

area. 

The portions of the Tri-County 230-Kv 

transmission line ROW, the Wyoming 

State Highway 450 ROW, and the I-90 

ROW that were determined to be 

unsuitable are not located on the South 

Porcupine LBA study area. A portion of 

the BNSF & UP railroad ROW that was 

found to be unsuitable for mining crosses 

the tract configured under Alternative 2. 

Therefore, this portion of the BNSF & UP 

railroad ROW was designated unsuitable 

and the lease will be stipulated unsuitable 

to exclude mining within the ROW. 

3. Buffer Zones for Rights-Of-Way, 

Communities, and Buildings. 

Federal lands within 100 ft of a 

ROW of a public road or a 

cemetery; or within 300 ft of any 

public building, school, church, 

community or institutional 

building or public park; or within 

300 ft of an occupied dwelling are 

unsuitable for mining.

Portions of Wyoming State Highway 450, 

Interstate Highway I-90, and one 

cemetery were found to be unsuitable 

under this criterion. Decisions were 

deferred on other highways/roads, 

occupied dwellings, and one school until 

an application to lease is filed.

Highway 450, I-90, and the cemetery are 

not located on the South Porcupine LBA 

study area. No occupied dwellings or 

schools are located on the study area. 

Portions of the ROW of the Antelope Road, 

a county road, are located on the tract as 

applied for and under Alternative 2. The 

relocation of a portion of the Antelope 

Road within the LBA study area has been 

approved by the Campbell County 

Commissioners. Therefore, the portions 

of the South Porcupine LBA study area 

within the ROW of a portion of the 

Antelope Road and the associated 100-ft 

buffer zone are designated unsuitable for 

mining and the lease will be stipulated to 

exclude mining within these areas unless 

a permit to move the road is approved by 

Campbell Co. Board of Commissioners. 

4. Wilderness Study Areas. Federal 

lands designated as wilderness 

study areas are unsuitable for 

mining while under review for 

possible wilderness designation.

No lands in the general review area are 

within a wilderness study area.

There are no unsuitable findings under 

Criterion 4 for the South Porcupine LBA 

study area.

5. Scenic Areas. Scenic federal 

lands designated by visual 

resource management analysis as 

Class I (outstanding visual quality 

or high visual sensitivity) but not 

currently on National Register of 

Natural Landmarks are unsuitable.

No lands in the general review area meet 

the scenic criteria as outlined.

There are no unsuitable findings under 

Criterion 5 for the South Porcupine LBA 

study area.
Appendix B 

Final EIS, Wright Area Coal Lease Applications B-17 

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR THE SOUTH PORCUPINE 

LBA STUDY AREA

6. Land Used for Scientific Study. 

Federal lands under permit by the 

surface management agency and 

being used for scientific studies 

involving food or fiber production, 

natural resources, or technology 

demonstrations and experiments 

are unsuitable for the duration of 

the study except where mining 

would not jeopardize the purpose 

of the study.

Two vegetation monitoring study sites on 

the TBNG (NE1⁄4 of Sec. 1, T.41N., R.71W. 

and NW1⁄4 NW1⁄4 of Sec. 30, T.41N., 

R.69W.), and the Hoe Creek Site (Sec. 7, 

T.47N., R.72W.) were found to be 

unsuitable under this criterion.

The vegetation monitoring sites and the 

Hoe Creek site are not located on the 

South Porcupine LBA study area. There 

are no unsuitable findings under Criterion 

6 for the South Porcupine LBA study area.

7. Cultural Resources. All publicly 

or privately owned places which 

are included in or are eligible for 

inclusion in the NRHP and an 

appropriate buffer zone are 

unsuitable.

On the basis of the consultation with 

SHPO, there were no unsuitable findings 

under this criterion in the general review 

area. Continue using the “Standard 

Archeological Stipulation” to new leases.

There are no unsuitable findings under 

Criterion 7 for the South Porcupine LBA 

study area. The “Standard Archeological 

Stipulation” should be applied if this tract 

is leased.

8. Natural Areas. Federal lands 

designated as natural areas or 

National Natural Landmarks are 

unsuitable.

No lands in the general review area are 

designated as natural areas or as 

National Natural Landmarks.

There are no unsuitable findings under 

Criterion 8 for the South Porcupine LBA 

study area.

9. Critical Habitat for Threatened 

or Endangered Plant and Animal 

Species. Federally designated 

critical habitat for threatened or 

endangered plant and animal 

species, and scientifically 

documented essential habitat for 

threatened or endangered species 

are unsuitable.

There is no federally designated critical 

habitat for threatened or endangered 

plant or animal species within the 

general review area.

There are no unsuitable findings under 

Criterion 9 for the South Porcupine LBA 

study area.

10. State Listed Threatened or 

Endangered Species. Federal 

lands containing habitat 

determined to be critical or 

essential for plant or animal 

species listed by a state pursuant 

to state law as threatened or 

endangered shall be considered 

unsuitable.

Wyoming does not maintain a state list of 

threatened or endangered species of 

plants or animals. Therefore, this 

criterion does not apply.

There are no unsuitable findings under 

Criterion 10 for the South Porcupine LBA 

study area.

11. Bald or Golden Eagle Nests. An 

active bald or golden eagle nest 

and appropriate buffer zone are 

unsuitable unless the lease can be 

conditioned so that eagles will not 

be disturbed during breeding 

season or unless golden eagle 

nests will be moved.

Defer suitability decisions and evaluate 

bald and golden eagle nests on a case by 

case basis at the time of leasing. 

Establish buffer zones around nests 

during mining and reclamation planning 

after consultation with USFWS.

There are currently no bald or golden 

eagle nests (active or inactive) on the 

South Porcupine LBA study area. 

Evaluate suitability prior to lease 

issuance during consultation with 

USFWS.

12. Bald and Golden Eagle Roost and 

Concentration Areas. Bald and 

golden eagle roost and 

concentration areas on federal 

lands used during migration and 

wintering are unsuitable unless 

mining can be conducted in such a 

way as to ensure that eagles shall 

not be adversely disturbed.

Defer suitability decisions and evaluate 

bald and golden eagle roost areas on a 

case by case basis prior to lease 

issuance. Establish buffer zones after 

consultation with USFWS.

There are no identified roost sites on the 

South Porcupine LBA study area. 

Evaluate suitability prior to lease 

issuance during consultation with 

USFWS. 

13. Falcon Nesting Sites and Buffer 

Zones. Federal lands containing 

active falcon (excluding kestrel) 

cliff nesting sites and a suitable 

buffer zone shall be considered 

unsuitable unless mining can be 

conducted in such a way as to 

ensure the falcons will not be 

adversely affected.

Defer suitability decisions on falcon 

nesting sites and evaluate on a case by 

case basis prior to lease issuance. 

Establish buffer zones around nesting 

sites after consultation with USFWS.

No falcon nesting sites have been 

identified on the South Porcupine LBA 

study area. There are no unsuitable 

findings under Criterion 13 for the South 

Porcupine LBA study area.
Appendix B 

B-18 Final EIS, Wright Area Coal Lease Applications

UNSUITABILITY CRITERIA

GENERAL RECOMMENDATIONS FOR 

BUFFALO RESOURCE AREA (BLM 1985, 

2001a)

FINDINGS FOR THE SOUTH PORCUPINE 

LBA STUDY AREA

14. Habitat for Migratory Bird 

Species. Federal lands which are 

high priority habitat for migratory 

bird species of management 

concern in Wyoming shall be 

considered unsuitable unless 

mining can be conducted in such a 

way as to ensure that migratory 

bird habitat will not be adversely 

affected during the period it is in 

use.

Defer suitability decisions on high 

priority habitat for migratory bird species 

of management concern in Wyoming and 

evaluate on a case by case basis prior to 

lease issuance. Establish buffer zones 

for nesting areas during mining and 

reclamation planning after consultation 

with USFWS.

Evaluate suitability during consultation 

with USFWS.

15. Fish and Wildlife Habitat for 

Resident Species. Federal lands 

which the surface management 

agency and state jointly agree are 

fish, wildlife and plant habitat of 

resident species of high interest to 

the state, and which are essential 

for maintaining these priority 

wildlife species, shall be considered 

unsuitable unless mining can be 

conducted in such a way as to 

ensure no long-term impact on the 

species being provided will occur.

Defer suitability decisions on grouse leks 

and evaluate on a case by case basis 

prior to lease issuance. Establish buffer 

zones after consultation with WGFD.

There are currently are no occupied 

(active within the last 10 years) or 

unoccupied (destroyed or abandoned) 

sage-grouse leks identified on lands 

within the South Porcupine LBA study 

area or on lands within 2 miles of the LBA 

study area. Evaluate this criterion prior 

to lease issuance. Establish buffer zones 

during mining and reclamation planning 

after consultation with WGFD.

16. Floodplains. Federal lands in 

riverine, coastal, and special 

floodplains shall be considered 

unsuitable where it is determined 

that mining could not be 

undertaken without substantial 

threat of loss of life or property.

The BLM and USFS have determined that 

the identified floodplains in the general 

review area could potentially be mined. 

Therefore, all lands within the general 

review area are considered suitable.

Site-specific stipulations and resource 

protection safeguards will be applied if 

necessary during mining and reclamation 

planning. There are no unsuitable 

findings under Criterion 16 for the South 

Porcupine LBA study area.

17. Municipal Watersheds. Federal 

lands which have been committed 

by the surface management agency 

to use as municipal watersheds 

shall be considered unsuitable.

There are no designated municipal 

watersheds in the general review area.

There are no unsuitable findings under 

Criterion 17 for the South Porcupine LBA 

study area.

18. National Resource Waters. 

Federal lands with national 

resource waters, as identified by 

states in their water quality 

management plans, and 1/4-mile 

buffer zones shall be unsuitable.

There are no designated national 

resource waters within the general review 

area.

There are no unsuitable findings under 

Criterion 18 for the South Porcupine LBA 

study area.

19. Alluvial Valley Floors. Federal 

lands identified by the surface 

management agency, in 

consultation with the state, as 

AVFs where mining would 

interrupt, discontinue or preclude 

farming, are unsuitable. 

Additionally, when mining federal 

lands outside an AVF would 

materially damage the quality or 

quantity of water in surface or 

underground water systems that 

would supply AVFs, the land shall 

be considered unsuitable.

Consider areas determined to contain 

AVFs significant to farming as 

unsuitable. Defer decisions on other 

AVFs and analyze on a case-by-case 

basis prior to lease issuance.

No AVFs or potential AVFs have been 

identified on the South Porcupine LBA 

study area with characteristics indicating 

potential significance to farming. There 

are no unsuitable findings under Criterion 

19 for the South Porcupine LBA study 

area.

20. State or Indian Tribe Criteria. 

Federal lands to which is 

applicable a criterion proposed by 

the state or Indian tribe located in 

the planning area and adopted by 

rulemaking by the Secretary are 

unsuitable.

There are no criterion proposed by state 

or Indian tribes that have been approved 

by the Secretary of the Interior. No tribal 

lands are located in or near the general 

review area.

There are no unsuitability findings for this 

criterion on the South Porcupine LBA 

study area.
APPENDIX C 

COAL LEASE-BY-APPLICATION 

FLOW CHART 
Appendix C 

Final EIS, Wright Area Coal Lease Applications C-1 

COAL LEASE-BY-APPLICATION

State Director (SD) notifies

Governor and Regional Coal Team

of application

Field Office Manager (FM) ensures 

that application is in conformance

with Land Use Plan (LUP)

Minerals Staff receives application

and prepares report on maximum

economic recovery

BLM STATE OFFICE

RECEIVES APPLICATION

Conformance with LUP:

FM prepares site-specific 

Environmental

Analysis

Non-Conformance with LUP:

FM recommends amendment

of LUP and/or modification of

application area

FM prepares Environmental

Analysis of LUP amendment

and application

Adjudicator evaluates

applicant’s qualifications

FM HOLDS PUBLIC

HEARING

Applicant submits/

Adjudicator reviews surface owner

consent agreement(s) (if necessary) 

SD

DECISION

HOLD

SALE

REJECT

APPLICATION

SD consults with 

Surface Management Agency, Governor,

Attorney General, and Indian Tribes 
APPENDIX D

BUREAU OF LAND MANAGEMENT 

SPECIAL COAL LEASE STIPULATIONS, 

U.S. FOREST SERVICE SPECIAL STIPULATIONS, 

AND FORM 3400-12 COAL LEASE 
Appendix D 

Final EIS, Wright Area Coal Lease Applications D-1 

BLM will attach the following special stipulations to each Wright LBA tract that is 

leased: 

SPECIAL STIPULATIONS 

In addition to observing the general obligations and standards of performance set 

out in the current regulations, the lessee shall comply with and be bound by the 

following special stipulations. 

These stipulations are also imposed upon the lessee’s agents and employees. The 

failure or refusal of any of these persons to comply with these stipulations shall be 

deemed a failure of the lessee to comply with the terms of the lease. The lessee 

shall require his agents, contractors and subcontractors involved in activities 

concerning this lease to include these stipulations in the contracts between and 

among them. These stipulations may be revised or amended, in writing, by the 

mutual consent of the lessor and the lessee at any time to adjust to changed 

conditions or to correct an oversight. 

(a) CULTURAL RESOURCES

(1) Before undertaking any activities that may disturb the surface of the leased 

lands, the lessee shall conduct a cultural resource intensive field inventory in a 

manner specified by the Authorized Officer of the BLM or of the surface 

managing agency, if different, on portions of the mine plan area and adjacent 

areas, or exploration plan area, that may be adversely affected by lease-related 

activities and which were not previously inventoried at such a level of intensity. 

The inventory shall be conducted by a qualified professional cultural resource 

specialist (i.e., archeologist, historian, historical architect, as appropriate), 

approved by the Authorized Officer of the surface managing agency (BLM, if the 

surface is privately owned), and a report of the inventory and recommendations 

for protecting any cultural resources identified shall be submitted to the 

Regional Director of the Western Region of the Office of Surface Mining (the 

Western Regional Director), the Authorized Officer of the BLM, if activities are 

associated with coal exploration outside an approved mining permit area 

(hereinafter called Authorized Officer), and the Authorized Officer of the surface 

managing agency, if different. The lessee shall undertake measures, in 

accordance with instructions from the Western Regional Director, or 

Authorized Officer, to protect cultural resources on the leased lands. The 

lessee shall not commence the surface disturbing activities until permission to 

proceed is given by the Western Regional Director or Authorized Officer. 

(2) The lessee shall protect all cultural resource properties that have been 

determined eligible to the National Register of Historic Places within the lease 

area from lease-related activities until the cultural resource mitigation 

measures can be implemented as part of an approved mining and reclamation 
Appendix D 

D-2 Final EIS, Wright Area Coal Lease Applications

or exploration plan unless modified by mutual agreement in consultation with 

the State Historic Preservation Officer. 

(3) The cost of conducting the inventory, preparing reports, and carrying out 

mitigation measures shall be borne by the lessee. 

(4) If cultural resources are discovered during operations under this lease, the 

lessee shall immediately bring them to the attention of the Western Regional 

Director or Authorized Officer, or the Authorized Officer of the surface 

managing agency, if the Western Regional Director is not available. The lessee 

shall not disturb such resources except as may be subsequently authorized by 

the Western Regional Director or Authorized Officer. 

Within two (2) working days of notification, the Western Regional Director or 

Authorized Officer will evaluate or have evaluated any cultural resources 

discovered and will determine if any action may be required to protect or 

preserve such discoveries. The cost of data recovery for cultural resources 

discovered during lease operations shall be borne by the lessee unless 

otherwise specified by the Authorized Officer of the BLM or of the surface 

managing agency, if different. 

(5) All cultural resources shall remain under the jurisdiction of the United 

States until ownership is determined under applicable law. 

(b) PALEONTOLOGICAL RESOURCES

If paleontological resources, either large and conspicuous, and/or of significant 

scientific value are discovered during mining operations, the find will be reported 

to the Authorized Officer immediately. Mining operations will be suspended within 

250 feet of said find. An evaluation of the paleontological discovery will be made 

by a BLM-approved professional paleontologist within five (5) working days, 

weather permitting, to determine the appropriate action(s) to prevent the potential 

loss of any significant paleontological value. Operations within 250 feet of such 

discovery will not be resumed until written authorization to proceed is issued by 

the Authorized Officer. The lessee will bear the cost of any required 

paleontological appraisals, surface collection of fossils, or salvage of any large 

conspicuous fossils of significant scientific interest discovered during the 

operations. 

(c) THREATENED, ENDANGERED, CANDIDATE, or OTHER SPECIAL STATUS 

PLANT and ANIMAL SPECIES 

(1) The lease area may now or hereafter contain plants, animals, or their 

habitats determined to be threatened or endangered under the Endangered 

Species Act of 1973, as amended, 16 U.S.C. 1531 et seq., or that have other 

special status. The Authorized Officer may recommend modifications to 

exploration and development proposals to further conservation and 
Appendix D 

Final EIS, Wright Area Coal Lease Applications D-3

management objectives or to avoid activity that will contribute to a need to list 

such species or their habitat or to comply with any biological opinion issued by 

the Fish and Wildlife Service for the Proposed Action. The Authorized Officer 

will not approve any ground-disturbing activity that may affect any such 

species or critical habitat until it completes its obligations under applicable 

requirements of the Endangered Species Act. The Authorized Officer may 

require modifications to, or disapprove a proposed activity that is likely to 

result in jeopardy to the continued existence of a proposed or listed threatened 

or endangered species, or result in the destruction or adverse modification of 

designated or proposed critical habitat. 

(2) The lessee shall comply with instructions from the Authorized Officer of the 

surface managing agency (BLM, if the surface is private) for ground disturbing 

activities associated with coal exploration on federal coal leases prior to 

approval of a mining and reclamation permit or outside an approved mining 

and reclamation permit area. The lessee shall comply with instructions from 

the Authorized Officer of the Office of Surface Mining Reclamation and 

Enforcement, or his designated representative, for all ground disturbing 

activities taking place within an approved mining and reclamation permit area 

or associated with such a permit. 

(3) Any potential habitat that has not already been surveyed for Ute ladies’-

tresses within the project area shall be identified and surveyed prior to surface 

mining activities. 

(d) MULTIPLE MINERAL DEVELOPMENT

Operations will not be approved which, in the opinion of the Authorized Officer, 

would unreasonably interfere with the orderly development and/or production 

from a valid existing mineral lease issued prior to this one for the same lands. 

(e) OIL AND GAS/COAL RESOURCES

The BLM realizes that coal mining operations conducted on Federal coal leases 

issued within producing oil and gas fields may interfere with the economic 

recovery of oil and gas; just as Federal oil and gas leases issued in a Federal coal 

lease area may inhibit coal recovery. BLM retains the authority to alter and/or 

modify the resource recovery and protection plans for coal operations and/or oil 

and gas operations on those lands covered by Federal mineral leases so as to 

obtain maximum resource recovery. 

(f) RESOURCE RECOVERY AND PROTECTION

Notwithstanding the approval of a resource recovery and protection plan (R2P2) by 

the BLM, lessor reserves the right to seek damages against the operator/lessee in 
Appendix D 

D-4 Final EIS, Wright Area Coal Lease Applications

the event (i) the operator/lessee fails to achieve maximum economic recovery 

(MER) (as defined at 43 CFR 3480.0-5(21)) of the recoverable coal reserves or (ii) 

the operator/lessee is determined to have caused a wasting of recoverable coal 

reserves. Damages shall be measured on the basis of the royalty that would have 

been payable on the wasted or unrecovered coal. 

The parties recognize that under an approved R2P2, conditions may require a 

modification by the operator/lessee of that plan. In the event a coal bed or portion 

thereof is not to be mined or is rendered unmineable by the operation, the 

operator/lessee shall submit appropriate justification to obtain approval by the 

Authorized Officer to leave such reserves unmined. Upon approval by the 

Authorized Officer, such coal beds or portions thereof shall not be subject to 

damages as described above. Further, nothing in this section shall prevent the 

operator/lessee from exercising its right to relinquish all or portion of the lease as 

authorized by statute and regulation. 

In the event the Authorized Officer determines that the R2P2, as approved, will not 

attain MER as the result of changed conditions, the Authorized Officer will give 

proper notice to the operator/lessee as required under applicable regulations. The 

Authorized Officer will order a modification if necessary, identifying additional 

reserves to be mined in order to attain MER. Upon a final administrative or 

judicial ruling upholding such an ordered modification, any reserves left unmined 

(wasted) under that plan will be subject to damages as described in the first 

paragraph under this section. 

Subject to the right to appeal hereinafter set forth, payment of the value of the 

royalty on such unmined recoverable coal reserves shall become due and payable 

upon determination by the Authorized Officer that the coal reserves have been 

rendered unmineable or at such time that the operator/lessee has demonstrated 

an unwillingness to extract the coal. 

The BLM may enforce this provision either by issuing a written decision requiring 

payment of the Mineral Management Service demand for such royalties, or by 

issuing a notice of non-compliance. A decision or notice of non-compliance issued 

by the lessor that payment is due under this stipulation is appealable as allowed 

by law. 

(g) PUBLIC LAND SURVEY PROTECTION

The lessee will protect all survey monuments, witness corners, reference 

monuments, and bearing trees against destruction, obliteration, or damage during 

operations on the lease areas. If any monuments, corners or accessories are 

destroyed, obliterated, or damaged by this operation, the lessee will hire an 

appropriate county surveyor or registered land surveyor to reestablish or restore 

the monuments, corners, or accessories at the same location, using surveying 

procedures in accordance with the "Manual of Surveying Instructions for the 
Appendix D 

Final EIS, Wright Area Coal Lease Applications D-5

Survey of the Public Lands of the United States." The survey will be recorded in 

the appropriate county records, with a copy sent to the Authorized Officer. 

(h) BUFFER ZONES FOR RIGHTS-OF-WAY OF PUBLIC ROADS

The following special stipulation (h)(1) will be added to the West Hilight Field and 

West Jacobs Ranch LBA Tracts: 

(1) No mining activity of any kind may be conducted within Wyoming State 

Highway 450 right-of-way and associated 100-feet buffer zone while that public 

road remains in its current (2009) location. The lessee shall recover all legally 

and economically recoverable coal from all leased lands not within the 

foregoing right-of-way and associated buffer zone. Provided a permit to move 

this public highway is approved by the appropriate authority (Wyoming 

Department of Transportation), the lessee shall recover all legally and 

economically recoverable coal from all leased lands within the foregoing rightof-way and associated buffer zone. The lessee shall pay all royalties on any 

legally and economically recoverable coal that it fails to mine without the 

written permission of the Authorized Officer. 

The following special stipulation (h)(2) will be added to each Wright area LBA tract: 

(2) No mining activity of any kind may be conducted within Campbell County 

Road [Shroyer (CR 116), Reno (CR 83), Hilight (CR 52), Mackey (CR 69), 

Matheson, or Antelope (CR4)] rights-of-way and associated 100-feet buffer 

zones while those public roads remain in their current (2009) locations. The 

lessee shall recover all legally and economically recoverable coal from all leased 

lands not within the foregoing rights-of-way and associated buffer zones. 

Provided a permit to move the respective road(s) is approved by the appropriate 

authority (Campbell County Board of Commissioners), the lessee shall recover 

all legally and economically recoverable coal from all leased lands within the 

foregoing rights-of-way and associated buffer zones. The lessee shall pay all 

royalties on any legally and economically recoverable coal that it fails to mine 

without the written permission of the Authorized Officer. 

(i) RAILROAD RIGHT-OF-WAY

The following special stipulation will be added to the South Hilight Field, West Hilight 

Field, West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts: 

No mining activity of any kind may be conducted on those portions of the 

Burlington Northern/Santa Fe and Union Pacific Railroad right-of-way that cross 

federally administered lands. The lessee shall recover all legally and economically 

recoverable coal from all leased lands not within the foregoing right-of-way. 

Lessee shall pay all royalties on any legally and economically recoverable coal that 

it fails to mine without the written permission of the Authorized Officer. 
Appendix D 

Final EIS, Wright Area Coal Lease Applications D-6 

The North Hilight Field, South Hilight Field, West Hilight Field, North Porcupine, and 

South Porcupine LBA Tracts reconfigured under Alternative 2 (the BLM study area, 

which is BLM’s preferred alternative) include National Forest System Lands. U.S. 

Forest Service will attach the following special stipulations to each Wright LBA tract 

that is leased:

NOTICE FOR LANDS OF THE NATIONAL FOREST SYSTEM UNDER 

JURISDICTION OF THE DEPARTMENT OF AGRICULTURE 

The permittee must comply with all the rules and regulations of the Secretary of 

Agriculture set forth in Title 36, Chapter II, of the Code of Federal Regulations 

governing the use and management of the National Forest System (NFS) when not 

inconsistent with the rights granted by the Secretary of the Interior in the permit. 

The Secretary of Agriculture’s rules and regulations must be complied with for (1) 

all use and occupancy of the NFS prior to approval of an exploration plan by the 

Secretary of the Interior, (2) uses of all existing improvements, such as forest 

development roads, within and outside the area permitted by the Secretary of the 

Interior, and (3) use and occupancy of the NFS not authorized by an exploration 

plan approved by the Secretary of the Interior. 

All matters related to this stipulation are to be addressed to: 

 District Ranger 

 2250 East Richards 

 Douglas, WY 82633 

 Telephone: 307-358-4690 

who is the authorized representative of the Secretary of Agriculture. 

NOTICE 

CULTURAL AND PALEONTOLOGICAL RESOURCES – The U.S. Department of 

Agriculture-Forest Service (USFS) is responsible for assuring that the leased lands 

are examined to determine if cultural and paleontological resources are present 

and to specify mitigation measures. Prior to undertaking the surface-disturbing 

activities on the lands covered by the lease, the lessee or operator, unless notified 

to the contrary by the USFS, shall: 

1. Contact the USFS to determine if a site specific cultural or paleontological 

resource inventory is required. If a survey is required, then: 

2. Engage the services of a cultural resource specialist and/or paleontologist 

acceptable to the USFS to conduct a cultural and/or paleontological 

resource inventory of the area of proposed surface disturbance. The 

operator may elect to inventory an area larger than the area of proposed 

disturbance to cover possible site relocation which may result from 

environmental or other considerations. An acceptable inventory report is to 
Appendix D 

Final EIS, Wright Area Coal Lease Applications D-7

be submitted to the USFS for review and approval at the time a surface 

disturbing plan of operation is submitted. 

3. A cultural and/or paleontological resource assessment and mitigation 

proposal is required for any scientifically significant locality discovered and 

known to exist in the area of proposed surface disturbance. Implement 

measures required by the USFS and BLM to preserve or avoid destruction of 

cultural and paleontological resource or values. Mitigation may include 

relocation of proposed facilities, testing, salvage, recordation, or other 

protective measures. All costs of the inventory and mitigation will be borne 

by the lessee or operator, and all data and materials salvaged will remain 

under the jurisdiction of the U.S. Government as appropriate. 

The discovery of any antiquities or other objects of historic or scientific interest, 

including but not limited to, historic or prehistoric ruins, fossils, or artifacts as 

the result of any operation conducted within the lease boundaries on Forest 

System Land shall immediately be brought to the attention of the District 

Ranger. The permittee will cease operations in that area until authorized to 

proceed by the District Ranger. 

FOREST SERVICE REGION 2 SENSITIVE SPECIES – The USFS is responsible 

for assuring that the leased land is examined prior to undertaking any surfacedisturbing activities to determine effects upon any plant or animal species 

listed as sensitive by the Regional Forester. The findings of this examination 

may result in some restrictions to the operator’s plan or even disallow use and 

occupancy. 

ENDANGERED OR THREATENED SPECIES – The USFS is responsible for 

assuring that the leased land is examined prior to undertaking any surfacedisturbing activities to determine effects upon any plant or animal species 

listed or proposed for listing as endangered or threatened, or their habitats. 

The findings of this examination may result in some restriction to the 

operator’s plans or even disallow use and occupancy that would be in violation 

of the Endangered Species Act of 1973 by detrimentally affecting endangered or 

threatened species or their habitats. 

The lessee/operator may, unless notified by the USFS that the examination is 

not necessary, conduct the examination of leased lands at this discretion and 

cost. This examination must be done by or under the supervision of a qualified 

resource specialist approved by the USFS. An acceptable report must be 

provided to the USFS identifying the anticipated effects of a proposed action on 

endangered or threatened species or their habitats, and the anticipated effects 

and impacts to USFS Regions 2 Sensitive Species that may occur or have 

habitat in the area. 
Appendix D 

Final EIS, Wright Area Coal Lease Applications D-8 
Appendix D 

D-9 Final EIS, Wright Area Coal Lease Applications
Appendix D 

Final EIS, Wright Area Coal Lease Applications D-10 
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 

SOUTH PORCUPINE LBA TRACT 
Final EIS, Wright Area Coal Lease Applications E-1

CONVENTIONAL OIL AND GAS WELLS CAPABLE OF PRODUCTION WITHIN THE 

NORTH HILIGHT FIELD LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUD

API 

Number 

(Short) Company Well Name/No. TWP RNG Location 

WOGCC 

Status 

Cumu

Produ

Ga

(MC

521991 M & K Oil Company, Inc. So Hilight Unit No. 1-41 44N 70W NWNW Sec. 17 PR 237,521992 M & K Oil Company, Inc. So Hilight Unit No. 4-41 44N 70W NWSW Sec. 17 PR 18,4522016 Primary Natural Resources, Inc. Central Hilight Unit No. 227 44N 70W NWSW Sec 18 PR 221,522106 M & K Oil Company, Inc. So Hilight Unit No. 11-53 44N 70W NWNE Sec 19 GL 75,4522107 M & K Oil Company, Inc. So Hilight Unit No. 19-53 44N 70W NWSE Sec 19 GL 71,0522283 M & K Oil Company, Inc. So Hilight Unit No. 18-20 44N 70W NWSW Sec 19 GL 458,522148 M & K Oil Company, Inc. So Hilight Unit No. 12-40 44N 70W NWNW Sec 20 GL 989,522224 M & K Oil Company, Inc. So Hilight Unit No. 20-40 44N 70W NWSW Sec 20 GL 20,9522245 M & K Oil Company, Inc. So Hilight Unit No. 14-25 44N 70W NWNE Sec 21 GL 330,522502 M & K Oil Company, Inc. So Hilight Unit No. 23-12 44N 70W NWSE Sec 21 GL 443,522160 M & K Oil Company, Inc. So Hilight Unit No. 22-39 44N 70W NWSW Sec 21 GL 174,522031 M & K Oil Company, Inc. So Hilight Unit No. 13-39 44N 70W NWNW Sec 21 GL 265,523523 M & K Oil Company, Inc. Royar Fed No. 1 44N 70W NWSW Sec 22 GL 114,521956 M & K Oil Company, Inc. Pamela No. 1 44N 71W NWSW Sec 13 GL 304,521959 Primary Natural Resources, Inc. Central Hilight Unit No. 226 44N 71W NWSE Sec 13 PR 232,522568 M & K Oil Company, Inc. Pamela No. 1-A 44N 71W NWSW Sec 13 GL 839,521925 M & K Oil Company, Inc Mills No. 17 44N 71W NWSE Sec 23 PR 115,525086 C & H Well Service Springen No. 1 44N 71W SENW Sec 23 GL 337,521845 M & K Oil Company, Inc So Hilight Unit No. 8-43 44N 71W NWNW Sec 24 GL 484,522082 M & K Oil Company, Inc So Hilight Unit No. 9-17 44N 71W NWNE Sec 24 GL 81,4

Status Codes: PR = Pumping Rods, GL = Gas Lift Conventional oil and gas 
Appendix E 

 E-2 Final EIS, Wright Area Co

CONVENTIONAL OIL AND GAS WELLS CAPABLE OF PRODUCTION WITHIN THE 

SOUTH HILIGHT FIELD LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUD

API 

Number 

(Short) Company Well Name/No. TWP RNG Location 

WOGCC 

Status 

Cumu

Produ

Ga

(MC

525150 M & K Oil Company, Inc Porcupine Fed W30501 No. 1 42N 71W NWSW Sec. 2 GL 318,

CONVENTIONAL OIL AND GAS WELLS CAPABLE OF PRODUCTION WITHIN THE 

WEST HILIGHT FIELD LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUDY 

API 

Number 

(Short) Company Well Name/No. TWP RNG Location 

WOGCC 

Status 

Cumu

Produ

Ga

(MC

527612 M & K Oil Company, Inc Burton Reno No. 1 43N 71W NESW Sec. 15 PR 0 

CONVENTIONAL OIL AND GAS WELLS CAPABLE OF PRODUCTION WITHIN THE 

WEST JACOBS RANCH LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUDY 

API 

Number 

(Short) Company Well Name/No. TWP RNG Location 

WOGCC 

Status 

Cumu

Produ

Ga

(MC

521868 M & K Oil Company, Inc South Hilight Unit No. 34-50 44N 71W NWSE Sec. 27 GL 70,6

CONVENTIONAL OIL AND GAS WELLS CAPABLE OF PRODUCTION WITHIN THE 

SOUTH PORCUPINE LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUDY 

API 

Number 

(Short) Company Well Name/No. TWP RNG Location 

WOGCC 

Status 

Cumu

Produ

Ga

(MC

526100 Abraxas Petroleum Corporation Frazier No. 11-12 41N 71W NWNW Sec. 12 PR 307,

Status Codes: PR = Pumping Rods, GL = Gas Lift Conventional oil and gas 
Final EIS, Wright Area Coal Lease Applications E-3 

CONVENTIONAL OIL AND GAS WELLS CAPABLE OF PRODUCTION WITHIN THE 

NORTH PORCUPINE LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUDY 

API 

Number 

(Short) Company Well Name/No. TWP RNG Location 

WOGCC 

Status 

Cumu

Produ

Ga

(MC

527391 DNR Oil and Gas, Inc. Fed. W-093721C No. 19-16 42N 70W SESE Sec. 19 FL 1,161524326 DNR Oil and Gas, Inc. Gamberg No. 1 42N 70W SWNW Sec. 26 PR 58,4527941 Berenergy Janzen Fed 04315 No. 34-26 42N 70W SWSE Sec. 26 PR 56,1521995 Peabody Natural Gas LLC WYO A 050890 No. 1 42N 70W SWNE Sec. 27 GL 1,2526728 Peabody Natural Gas LLC Federal No. 29-2 42N 70W NWNW Sec. 29 FL 791,522962 Peabody Natural Gas LLC Federal No. 1-29 42N 70W NWNW Sec. 29 FL 2,802522996 Chaco Energy Company Federal No. 1-23 42N 71W NWSE Sec. 23 FL 726,526471 Chaco Energy Company Exxon W-67034 No. 1-27 42N 71W SENW Sec. 23 FL 155,525697 Adair Company LLC Quillback W-67220 No. 1-34 42N 71W SWNW Sec. 34 FL 160,

Status Codes: FL = Flowing, PR = Pumping Rods, GL = Gas Lift Conventional oil and gas 
Appendix E 

 E-4 Final EIS, Wright Area Co

CBNG WELLS CAPABLE OF PRODUCTION WITHIN THE 

NORTH HILIGHT FIELD LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUD

API 

Number 

(Short) Company Well Number TWP RNG Location 

WOGCC 

Status 

Cumul

Produc

Ga

(MC

537396 PRIMARY NATURAL RESOURCES INC No. 22-19 44 70 SE NW Sec. 19 SI 2,08537399 PRIMARY NATURAL RESOURCES INC No. 11-19 44 70 NW NW Sec. 19 FL 16,8537400 PRIMARY NATURAL RESOURCES INC No. 24-19 44 70 SE SW Sec. 19 PS 58,9537861 PRIMARY NATURAL RESOURCES INC No. 31-19 44 70 NW NE Sec. 19 PS 70,8537909 PRIMARY NATURAL RESOURCES INC No. 13-19 44 70 NW SW Sec. 19 PS 63,7537854 PRIMARY NATURAL RESOURCES INC No. 33-19 44 70 NW SE Sec. 19 FL 36,3542731 PRIMARY NATURAL RESOURCES INC No. 11-20 44 70 NW NW Sec. 20 PS 112,4542732 PRIMARY NATURAL RESOURCES INC No. 13-20 44 70 NW SW Sec. 20 PS 104,8532169 PRIMARY NATURAL RESOURCES INC No. 22-13 44 71 SE NW Sec. 13 PS 43,3532170 PRIMARY NATURAL RESOURCES INC No. 31-13 44 71 NW NE Sec. 13 SI 26,2532171 PRIMARY NATURAL RESOURCES INC No. 42-13 44 71 SE NE Sec. 13 SI 1,17532172 PRIMARY NATURAL RESOURCES INC No. 33-13 44 71 NW SE Sec. 13 SI 15,3532174 PRIMARY NATURAL RESOURCES INC No. 11-13 44 71 NW NW Sec. 13 PS 98,2537397 PRIMARY NATURAL RESOURCES INC No. 24-13 44 71 SE SW Sec. 13 PS 105,8537398 PRIMARY NATURAL RESOURCES INC No. 13-13 44 71 NW SW Sec. 13 PS 72,2540283 PRIMARY NATURAL RESOURCES INC No. 44-13 44 71 SE SE Sec. 13 PS 68,5540273 PRIMARY NATURAL RESOURCES INC No. 31-14 44 71 NW NE Sec. 14 SI 75,3542582 PRIMARY NATURAL RESOURCES INC No. 42-14 C 44 71 SE NE Sec. 14 PS 102,546007 PRIMARY NATURAL RESOURCES INC No. 21-14 44 71 NE NW Sec. 14 PS 81,4548075 C & H WELL SERVICING INC No. 14-11 44 71 NE SW Sec. 14 FL 108,2548082 C & H WELL SERVICING INC No. 14-13 44 71 SW SW Sec. 14 FL 108,2549757 PRIMARY NATURAL RESOURCES INC No. 33-14 44 71 NW SE Sec. 14 FL 129,6
Final EIS, Wright Area Coal Lease Applications E-5 

CBNG WELLS CAPABLE OF PRODUCTION WITHIN THE 

NORTH HILIGHT FIELD LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUDY ARE

API 

Number 

(Short) Company Well Number TWP RNG Location 

WOGCC 

Status 

Cumul

Produc

Ga

(MC

549758 PRIMARY NATURAL RESOURCES INC No. 12-14 44 71 SW NW Sec. 14 PS 60,9549759 PRIMARY NATURAL RESOURCES INC No. 44-14 44 71 SE SE Sec. 14 PS 101,9537863 PRIMARY NATURAL RESOURCES INC No. 42-23 44 71 SE NE Sec. 23 PS 118,8537864 PRIMARY NATURAL RESOURCES INC No. 44-23 44 71 SE SE Sec. 23 PS 209,0537913 PRIMARY NATURAL RESOURCES INC No. 31-23 44 71 NW NE Sec. 23 PR 281,4537914 PRIMARY NATURAL RESOURCES INC No. 33-23 44 71 NW SE Sec. 23 FL 327,4548079 C & H WELL SERVICING INC No. 23-3 44 71 NE NW Sec. 23 FL 108,2548080 C & H WELL SERVICING INC No. 23-5 44 71 SW NW Sec. 23 FL 108,2537432 PRIMARY NATURAL RESOURCES INC No. 31-24 44 71 NW NE Sec. 24 PS 103,0537433 PRIMARY NATURAL RESOURCES INC No. 42-24 44 71 SE NE Sec. 24 PS 67,1537865 PRIMARY NATURAL RESOURCES INC No. 11-24 44 71 NW NW Sec. 24 PS 163,6537866 PRIMARY NATURAL RESOURCES INC No. 22-24 44 71 SE NW Sec. 24 PS 115,2537867 PRIMARY NATURAL RESOURCES INC No. 33-24 44 71 NW SE Sec. 24 PS 129,537868 PRIMARY NATURAL RESOURCES INC No. 44-24 44 71 SE SE Sec. 24 PS 93,2540188 PRIMARY NATURAL RESOURCES INC No. 24-24 44 71 SE SW Sec. 24 PS 580,2539749 PRIMARY NATURAL RESOURCES INC No. 13-24 44 71 NW SW Sec. 24 PS 176,2543700 PRIMARY NATURAL RESOURCES INC No. 23-24 44 71 NE SW Sec. 24 SI 0 540280 PRIMARY NATURAL RESOURCES INC No. 44-26 44 71 SE SE Sec. 26 FL 313,7

Status Codes: FL = Flowing, PR = Pumping Rods, PS = Pumping Submersible, SI = Shut in CBNG well status from WOGCC database 5/14/08 Cumulative production from WOGCC database 9/25/08
Appendix E 

 E-6 Final EIS, Wright Area Co

CBNG WELLS CAPABLE OF PRODUCTION WITHIN THE 

SOUTH HILIGHT FIELD LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUD

API 

Number 

(Short) Company Well Number TWP RNG Location 

WOGCC 

Status 

Cumul

Produc

Ga

(MC

549558 LANCE OIL & GAS COMPANY INC No. 21-2-4271 42 71 NE NW Sec. 2 SI 0 549559 LANCE OIL & GAS COMPANY INC No. 23-2-4271 42 71 NE SW Sec. 2 SI 0 549560 LANCE OIL & GAS COMPANY INC No. 12-2-4271 42 71 SW NW Sec. 2 SI 0 549561 LANCE OIL & GAS COMPANY INC No. 14-2-4271 42 71 SW SW Sec. 2 SI 0 531964 LANCE OIL & GAS COMPANY INC No. 14-23 43 71 SW SW Sec. 23 SI 3,24532513 LANCE OIL & GAS COMPANY INC No. 14-26 43 71 SW SW Sec. 26 PS 616,0532517 LANCE OIL & GAS COMPANY INC No. 22-26 43 71 SE NW Sec. 26 PS 176,7532598 LANCE OIL & GAS COMPANY INC No. 44-26 43 71 SE SE Sec. 26 PS 218,3533456 LANCE OIL & GAS COMPANY INC No. 32-26 43 71 SW NE Sec. 26 PS 221,3533363 LANCE OIL & GAS COMPANY INC No. 41-35 43 71 NE NE Sec. 35 PS 447,6533368 LANCE OIL & GAS COMPANY INC No. 32-35 43 71 SW NE Sec. 35 PS 340,3532593 LANCE OIL & GAS COMPANY INC No. 31-35 43 71 NW NE Sec. 35 PS 199,7532594 LANCE OIL & GAS COMPANY INC No. 22-35 43 71 SE NW Sec. 35 PS 303,5532596 LANCE OIL & GAS COMPANY INC No. 12-35 43 71 SW NW Sec. 35 PS 357,5532597 LANCE OIL & GAS COMPANY INC No. 11-35 43 71 NW NW Sec. 35 SI 303,7532605 LANCE OIL & GAS COMPANY INC No. 43-35 43 71 NE SE Sec. 35 SI 268,0532606 LANCE OIL & GAS COMPANY INC No. 42-35 43 71 SE NE Sec. 35 PS 236,8

Status Codes: PS = Pumping Submersible, SI = Shut in CBNG well status from WOGCC database 5/14/08 Cumulative production from WOGCC database 9/25/08
Final EIS, Wright Area Coal Lease Applications E-7

CBNG WELLS CAPABLE OF PRODUCTION WITHIN THE 

WEST HILIGHT FIELD LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUDY 

API 

Number 

(Short) Company Well Number TWP RNG Location 

WOGCC 

Status 

Cumul

Produc

Ga

(MC

544726 LANCE OIL & GAS COMPANY INC No. 41-8-4371 43 71 NE NE Sec. 8 SI 139,4531544 LANCE OIL & GAS COMPANY INC No. 1-41-9 43 71 NE NE Sec. 9 PS 382,0544720 LANCE OIL & GAS COMPANY INC No. 43-9-4371 43 71 NE SE Sec. 9 PS 263,5544721 LANCE OIL & GAS COMPANY INC No. 34-9-4371 43 71 SW SE Sec. 9 FL 194,2544723 LANCE OIL & GAS COMPANY INC No. 23-9-4371 43 71 NE SW Sec. 9 FL 301,8544724 LANCE OIL & GAS COMPANY INC No. 21-9-4371 43 71 NE NW Sec. 9 FL 327,6544725 LANCE OIL & GAS COMPANY INC No. 12-9-4371 43 71 SW NW Sec. 9 FL 215,6531545 LANCE OIL & GAS COMPANY INC No. 1-21-10 43 71 NE NW Sec. 10 FL 361,6534488 LANCE OIL & GAS COMPANY INC No. 23-10 43 71 NE SW Sec. 10 SI 284,5544719 LANCE OIL & GAS COMPANY INC No. 12-10-4371 43 71 SW NW Sec. 10 FL 247,8547010 COLEMAN OIL & GAS INC No. 15-23 43 71 NE SW Sec. 15 PS 363,5547011 COLEMAN OIL & GAS INC No. 15-21 43 71 NE NW Sec. 15 PS 628,0547012 COLEMAN OIL & GAS INC No. 15-14 43 71 SW SW Sec. 15 PS 385,3547013 COLEMAN OIL & GAS INC No. 15-12 43 71 SW NW Sec. 15 PS 524,9549585 COLEMAN OIL & GAS INC No. 15-43 43 71 NE SE 1 Sec. 5 PS 200,2549586 COLEMAN OIL & GAS INC No. 15-41 43 71 NE NE Sec. 15 PS 202,7549587 COLEMAN OIL & GAS INC No. 15-34 43 71 SW SE Sec. 15 SI 82,4537926 LANCE OIL & GAS COMPANY INC No. 43-17-4371 43 71 NE SE Sec. 17 PS 482,0537927 LANCE OIL & GAS COMPANY INC No. 34-17-4371 43 71 SW SE Sec. 17 PS 676,5537929 LANCE OIL & GAS COMPANY INC No. 21-17-4371 43 71 NE NW Sec. 17 PS 148,3544755 LANCE OIL & GAS COMPANY INC No. 14-17-4371 43 71 SW SW Sec. 17 PS 241,4544756 LANCE OIL & GAS COMPANY INC No. 12-17-4371 43 71 SW NW Sec. 17 SI 412,2
Appendix E 

 E-8 Final EIS, Wright Area Co

CBNG WELLS CAPABLE OF PRODUCTION WITHIN THE 

WEST HILIGHT FIELD LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUDY AREA 

API 

Number 

(Short) Company Well Number TWP RNG Location 

WOGCC 

Status 

Cumul

Produc

Ga

(MC

539634 LANCE OIL & GAS COMPANY INC No. 11-20-4371 43 71 NW NW Sec. 20 PS 320,7540744 LANCE OIL & GAS COMPANY INC No. 34-21 43 71 SW SE Sec. 21 PS 517,5540745 LANCE OIL & GAS COMPANY INC No. 43-21 43 71 NE SE Sec. 21 PS 657,9532638 LANCE OIL & GAS COMPANY INC No. 34-22 43 71 SW SE Sec. 22 FL 175,3534873 LANCE OIL & GAS COMPANY INC No. 32-22 43 71 SW NE Sec. 22 SI 90,2534874 LANCE OIL & GAS COMPANY INC No. 41-22 43 71 NE NE Sec. 22 SI 184,4540747 LANCE OIL & GAS COMPANY INC No. 23-22 43 71 NE SW Sec. 22 SI 189,0532267 LANCE OIL & GAS COMPANY INC No. 21-27 43 71 NE NW Sec. 27 PS 265,9532630 LANCE OIL & GAS COMPANY INC No. 32-27 43 71 SW NE Sec. 27 PS 285,532632 LANCE OIL & GAS COMPANY INC No. 34-27 43 71 SW SE Sec. 27 PS 417,532633 LANCE OIL & GAS COMPANY INC No. 42-27 43 71 SE NE Sec. 27 PS 460,2532634 LANCE OIL & GAS COMPANY INC No. 43-27 43 71 NE SE Sec. 27 PS 637,540324 LANCE OIL & GAS COMPANY INC No. 14-28-4371 43 71 SW SW Sec. 28 PS 403,6549926 LANCE OIL & GAS COMPANY INC No. 12-28-4371 43 71 SW NW Sec. 28 SI 53,9549934 LANCE OIL & GAS COMPANY INC No. 21-28-4371 43 71 NE NW Sec. 28 FL 148,0549935 LANCE OIL & GAS COMPANY INC No. 23-28-4371 43 71 NE SW Sec. 28 FL 114,0549936 LANCE OIL & GAS COMPANY INC No. 32-28-4371 43 71 SW NE Sec. 28 FL 77,9549937 LANCE OIL & GAS COMPANY INC No. 34-28-4371 43 71 SW SE Sec. 28 FL 96,5549938 LANCE OIL & GAS COMPANY INC No. 41-28-4371 43 71 NE NE Sec. 28 FL 133,5549939 LANCE OIL & GAS COMPANY INC No. 43-28-4371 43 71 NE SE Sec. 28 FL 104,0532526 LANCE OIL & GAS COMPANY INC No. 41-34 43 71 NE NE Sec. 34 PS 452,533644 LANCE OIL & GAS COMPANY INC No. 13-34 43 71 NW SW Sec. 34 SI 157,5
Final EIS, Wright Area Coal Lease Applications E-9

CBNG WELLS CAPABLE OF PRODUCTION WITHIN THE 

WEST HILIGHT FIELD LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUDY AREA 

API 

Number 

(Short) Company Well Number TWP RNG Location 

WOGCC 

Status 

Cumul

Produc

Ga

(MC

533645 LANCE OIL & GAS COMPANY INC No. 23-34 43 71 NE SW Sec. 34 FL 591,2533165 LANCE OIL & GAS COMPANY INC No. 11-34 43 71 NW NW Sec. 34 PS 757,0533166 LANCE OIL & GAS COMPANY INC No. 21-34 43 71 NE NW Sec. 34 FL 153,6

Status Codes: FL = Flowing, PS = Pumping Submersible, SI = Shut in CBNG well status from WOGCC database 5/14/08 Cumulative production from WOGCC database 9/25/08
Appendix E 

 E-10 Final EIS, Wright Area Co

CBNG WELLS CAPABLE OF PRODUCTION WITHIN THE 

WEST JACOBS RANCH LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUDY 

API 

Number 

(Short) Company Well Number TWP RNG Location 

WOGCC 

Status 

Cumul

Produc

Ga

(MC

544732 LANCE OIL & GAS COMPANY INC No. 41-3-4371 43 71 NE NE Sec. 3 FL 69,0544734 LANCE OIL & GAS COMPANY INC No. 32-3-4371 43 71 SW NE Sec. 3 FL 88,4544735 LANCE OIL & GAS COMPANY INC No. 23-3-4371 43 71 NE SW Sec. 3 FL 305,0544736 LANCE OIL & GAS COMPANY INC No. 21-3-4371 43 71 NE NW Sec. 3 FL 85,5544737 LANCE OIL & GAS COMPANY INC No. 14-3-4371 43 71 SW SW Sec. 3 FL 130,9544738 LANCE OIL & GAS COMPANY INC No. 12-3-4371 43 71 SW NW Sec. 3 FL 107,8534479 LANCE OIL & GAS COMPANY INC No. 13-4 43 71 NW SW Sec. 4 PS 276,4534480 LANCE OIL & GAS COMPANY INC No. 24-4 43 71 SE SW Sec. 4 PS 244,534481 LANCE OIL & GAS COMPANY INC No. 33-4 43 71 NW SE Sec. 4 PS 272,4534482 LANCE OIL & GAS COMPANY INC No. 44-4 43 71 SE SE Sec. 4 PS 389,5544727 LANCE OIL & GAS COMPANY INC No. 41-4-4371 43 71 NE NE Sec. 4 FL 91,3544728 LANCE OIL & GAS COMPANY INC No. 32-4-4371 43 71 SW NE Sec. 4 FL 150,2544729 LANCE OIL & GAS COMPANY INC No. 21-4-4371 43 71 NE NW Sec. 4 FL 144,0544730 LANCE OIL & GAS COMPANY INC No. 12-4-4371 43 71 SW NW Sec. 4 FL 178,534483 LANCE OIL & GAS COMPANY INC No. 22-5 43 71 SE NW Sec. 5 PS 160,7534484 LANCE OIL & GAS COMPANY INC No. 24-5 43 71 SE SW Sec. 5 PS 342,9534485 LANCE OIL & GAS COMPANY INC No. 33-5 43 71 NW SE Sec. 5 SI 105,8534486 LANCE OIL & GAS COMPANY INC No. 42-5 43 71 SE NE Sec. 5 PS 236,0534487 LANCE OIL & GAS COMPANY INC No. 44-5 43 71 SE SE Sec. 5 FL 103,9536461 LANCE OIL & GAS COMPANY INC No. 11-5-4371 43 71 NW NW Sec. 5 PS 134,8536462 LANCE OIL & GAS COMPANY INC No. 13-5-4371 43 71 NW SW Sec. 5 PS 207,5536463 LANCE OIL & GAS COMPANY INC No. 31-5-4371 43 71 NW NE Sec. 5 PS 121,3536468 LANCE OIL & GAS COMPANY INC No. 42-6-4371 43 71 SE NE Sec. 6 PS 140,7
Final EIS, Wright Area Coal Lease Applications E-11 

CBNG WELLS CAPABLE OF PRODUCTION WITHIN THE 

WEST JACOBS RANCH LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUDY AREA 

API 

Number 

(Short) Company Well Number TWP RNG Location 

WOGCC 

Status 

Cumul

Produc

Ga

(MC

536469 LANCE OIL & GAS COMPANY INC No. 44-6-4371 43 71 SE SE Sec. 6 PS 210,5546005 LANCE OIL & GAS COMPANY INC No. 23-15-4471 44 71 NE SW Sec. 15 PS 201,546006 LANCE OIL & GAS COMPANY INC No. 14-15-4471 44 71 SW SW Sec. 15 FL 129,548076 C & H WELL SERVICING INC No. 15-15 44 71 SW SE Sec. 15 SI 13,5548081 C & H WELL SERVICING INC No. 15-9 44 71 NE SE Sec. 15 FL 120,5535949 LANCE OIL & GAS COMPANY INC No. 34-20-4471 44 71 SW SE Sec. 20 PS 387,6535950 LANCE OIL & GAS COMPANY INC No. 43-20-4471 44 71 NE SE Sec. 20 PS 494,6535951 LANCE OIL & GAS COMPANY INC No. 12-21-4471 44 71 SW NW Sec. 21 PS 379,4535952 LANCE OIL & GAS COMPANY INC No. 14-21-4471 44 71 SW SW Sec. 21 PS 426,4535953 LANCE OIL & GAS COMPANY INC No. 21-21-4471 44 71 NE NW Sec. 21 PS 354,535954 LANCE OIL & GAS COMPANY INC No. 23-21-4471 44 71 NE SW Sec. 21 PS 567,6535955 LANCE OIL & GAS COMPANY INC No. 32-21-4471 44 71 SW NE Sec. 21 PS 364,535957 LANCE OIL & GAS COMPANY INC No. 41-21-4471 44 71 NE NE Sec. 21 PS 124,4535958 LANCE OIL & GAS COMPANY INC No. 43-21-4471 44 71 NE SE Sec. 21 PS 157,9546021 LANCE OIL & GAS COMPANY INC No. 21-22-4471 44 71 NE NW Sec. 22 PS 151,3548077 C & H WELL SERVICING INC No. 22-1 44 71 NE NE Sec. 22 FL 120,5548078 C & H WELL SERVICING INC No. 22-7 44 71 SW NE Sec. 22 FL 120,5549578 COLEMAN OIL & GAS INC No. 14-22 44 71 SW SW Sec. 22 PS 367,6549579 COLEMAN OIL & GAS INC No. 23-22 44 71 NE SW Sec. 22 PS 274,7549580 COLEMAN OIL & GAS INC No. 34-22 44 71 SW SE Sec. 22 PS 255,9542192 WILLIAMS PRODUCTION RMT COMPANY No. 43-27-4471 44 71 NE SE Sec. 27 PS 93,5542193 WILLIAMS PRODUCTION RMT COMPANY No. 34-27-4471 44 71 SW SE Sec. 27 PS 89,9543423 COLEMAN OIL & GAS INC No. 12-27 44 71 SW NW Sec. 27 PS 834,4
Appendix E 

 E-12 Final EIS, Wright Area Co

CBNG WELLS CAPABLE OF PRODUCTION WITHIN THE 

WEST JACOBS RANCH LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUDY AREA 

API 

Number 

(Short) Company Well Number TWP RNG Location 

WOGCC 

Status 

Cumul

Produc

Ga

(MC

543424 COLEMAN OIL & GAS INC No. 21-27 44 71 NE NW Sec. 27 PS 364,2534527 LANCE OIL & GAS COMPANY INC No. 23-27 44 71 NE SW Sec. 27 SI 212,549581 COLEMAN OIL & GAS INC No. 32-27 44 71 SW NE Sec. 27 PS 123,9549582 COLEMAN OIL & GAS INC No. 41-27 44 71 NE NE Sec. 27 PS 187,7534528 LANCE OIL & GAS COMPANY INC No. 23-28 44 71 NE SW Sec. 28 SI 704,5534529 LANCE OIL & GAS COMPANY INC No. 34-28 44 71 SW SE Sec. 28 PS 463,8534521 LANCE OIL & GAS COMPANY INC No. 43-28 44 71 NE SE Sec. 28 PS 342,0534525 LANCE OIL & GAS COMPANY INC No. 14-28 44 71 SW SW Sec. 28 PS 378,9535959 LANCE OIL & GAS COMPANY INC No. 12-28-4471 44 71 SW NW Sec. 28 SI 372,2535960 LANCE OIL & GAS COMPANY INC No. 21-28-4471 44 71 NE NW Sec. 28 PS 372,9535961 LANCE OIL & GAS COMPANY INC No. 32-28-4471 44 71 SW NE Sec. 28 PS 532,8535963 LANCE OIL & GAS COMPANY INC No. 12-29-4471 44 71 SW NW Sec. 29 PS 261,535964 LANCE OIL & GAS COMPANY INC No. 14-29-4471 44 71 SW SW Sec. 29 PS 306,8535965 LANCE OIL & GAS COMPANY INC No. 21-29-4471 44 71 NE NW Sec. 29 PS 355,8535966 LANCE OIL & GAS COMPANY INC No. 23-29-4471 44 71 NE SW Sec. 29 PS 297,8535967 LANCE OIL & GAS COMPANY INC No. 32-29-4471 44 71 SW NE Sec. 29 PS 619,7535968 LANCE OIL & GAS COMPANY INC No. 41-29-4471 44 71 NE NE Sec. 29 PS 219,534522 LANCE OIL & GAS COMPANY INC No. 34-29 44 71 SW SE Sec. 29 PS 201,3534523 LANCE OIL & GAS COMPANY INC No. 43-29 44 71 NE SE Sec. 29 PS 295,8546026 LANCE OIL & GAS COMPANY INC No. 43-30-4471 44 71 NE SE Sec. 30 FL 167,9546027 LANCE OIL & GAS COMPANY INC No. 41-30-4471 44 71 NE NE Sec. 30 SI 106,8546033 LANCE OIL & GAS COMPANY INC No. 42-31-4471 44 71 SE NE Sec. 31 PS 181,8
Final EIS, Wright Area Coal Lease Applications E-13 

CBNG WELLS CAPABLE OF PRODUCTION WITHIN THE 

WEST JACOBS RANCH LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUDY AREA 

API 

Number 

(Short) Company Well Number TWP RNG Location 

WOGCC 

Status 

Cumul

Produc

Ga

(MC

534535 LANCE OIL & GAS COMPANY INC No. 23-32 44 71 NE SW Sec. 32 SI 290,4534536 LANCE OIL & GAS COMPANY INC No. 32-32 44 71 SW NE Sec. 32 PS 621,9534537 LANCE OIL & GAS COMPANY INC No. 34-32 44 71 SW SE Sec. 32 PS 310,2534538 LANCE OIL & GAS COMPANY INC No. 41-32 44 71 NE NE Sec. 32 PS 287,5534539 LANCE OIL & GAS COMPANY INC No. 43-32 44 71 NE SE Sec. 32 PS 388,3534875 LANCE OIL & GAS COMPANY INC No. 14-33 44 71 SW SW Sec. 33 PS 430,3534876 LANCE OIL & GAS COMPANY INC No. 21-33 44 71 NE NW Sec. 33 FL 303,9534877 LANCE OIL & GAS COMPANY INC No. 23-33 44 71 NE SW Sec. 33 SI 593,8534878 LANCE OIL & GAS COMPANY INC No. 32-33 44 71 SW NE Sec. 33 PS 215,3534879 LANCE OIL & GAS COMPANY INC No. 34-33 44 71 SW SE Sec. 33 PS 418,9534880 LANCE OIL & GAS COMPANY INC No. 41-33 44 71 NE NE Sec. 33 PS 200,9534881 LANCE OIL & GAS COMPANY INC No. 43-33 44 71 NE SE Sec. 33 PS 436,2534524 LANCE OIL & GAS COMPANY INC No. 12-33 44 71 SW NW Sec. 33 PS 206,6549583 COLEMAN OIL & GAS INC No. 32-34 44 71 SW NE Sec. 34 PS 536,0549584 COLEMAN OIL & GAS INC No. 41-34 44 71 NE NE Sec. 34 PS 387,544712 LANCE OIL & GAS COMPANY INC No. 43-34-4471 44 71 NE SE Sec. 34 FL 349,2544713 LANCE OIL & GAS COMPANY INC No. 34-34-4471 44 71 SW SE Sec. 34 SI 59,2544714 LANCE OIL & GAS COMPANY INC No. 23-34-4471 44 71 NE SW Sec. 34 SI 59,6544715 LANCE OIL & GAS COMPANY INC No. 21-34-4471 44 71 NE NW Sec. 34 PS 332,4544716 LANCE OIL & GAS COMPANY INC No. 14-34-4471 44 71 SW SW Sec. 34 PS 77,8544717 LANCE OIL & GAS COMPANY INC No. 12-34-4471 44 71 SW NW Sec. 34 SI 48,8

Status Codes: FL = Flowing, PS = Pumping Submersible, SI = Shut in CBNG well status from WOGCC database 5/14/08 Cumulative production from WOGCC database 9/25/08
Appendix E 

 E-14 Final EIS, Wright Area Co

CBNG WELLS CAPABLE OF PRODUCTION WITHIN THE 

NORTH PORCUPINE LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUDY 

API 

Number 

(Short) Company Well Number TWP RNG Location 

WOGCC 

Status 

Cumul

Produc

Ga

(MC

553824 BILL BARRETT CORPORATION No. 14-19-4270 42 70 SW SW Sec. 19 FL 158,8553826 BILL BARRETT CORPORATION No. 43-19-4270 42 70 NE SE Sec. 19 FL 162,6553069 BILL BARRETT CORPORATION No. 23-19-4270 42 70 NE SW Sec. 19 FL 150,3553070 BILL BARRETT CORPORATION No. 32-19-4270 42 70 SW NE Sec. 19 FL 107,0553827 BILL BARRETT CORPORATION No. 12-20-4270 42 70 SW NW Sec. 20 FL 109,3553828 BILL BARRETT CORPORATION No. 14-20-4270 42 70 SW SW Sec. 20 FL 150,4553830 BILL BARRETT CORPORATION No. 23-20-4270 42 70 NE SW Sec. 20 FL 131,3553831 BILL BARRETT CORPORATION No. 34-20-4270 42 70 SW SE Sec. 20 FL 168,7554339 BILL BARRETT CORPORATION No. 12-21-4270 42 70 SW NW Sec. 21 FL 89,2554340 BILL BARRETT CORPORATION No. 14-21-4270 42 70 SW SW Sec. 21 FL 159,2554341 BILL BARRETT CORPORATION No. 23-21-4270 42 70 NE SW Sec. 21 FL 99,6546208 PEABODY NATURAL GAS LLC No. 21-30 42 70 NE NW Sec. 30 FL 98,1546595 PEABODY NATURAL GAS LLC No. 11-30 42 70 NW NW Sec. 30 FL 165,5554333 PEABODY NATURAL GAS LLC No. 41-30-42-70 42 70 NE NE Sec. 30 FL 44,0551233 BILL BARRETT CORPORATION No. 43-22-42-71 42 71 NE SE Sec. 22 FL 126,8551256 BILL BARRETT CORPORATION No. 32-22-42-71 42 71 SW NE Sec. 22 FL 119,3551257 BILL BARRETT CORPORATION No. 34-22-42-71 42 71 SW SE Sec. 22 FL 132,553799 BILL BARRETT CORPORATION No. 12-23-4271 42 71 SW NW Sec. 23 FL 91,0553800 BILL BARRETT CORPORATION No. 14-23-4271 42 71 SW SW Sec. 23 FL 106,553802 BILL BARRETT CORPORATION No. 23-23-4271 42 71 NE SW Sec. 23 FL 102,7553803 BILL BARRETT CORPORATION No. 32-23-4271 42 71 SW NE Sec. 23 FL 92,0553804 BILL BARRETT CORPORATION No. 34-23-4271 42 71 SW SE Sec. 23 FL 171,4
Final EIS, Wright Area Coal Lease Applications E-15 

CBNG WELLS CAPABLE OF PRODUCTION WITHIN THE 

NORTH PORCUPINE LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUDY AREA 

API 

Number 

(Short) Company Well Number TWP RNG Location 

WOGCC 

Status 

Cumul

Produ

Ga

(MC

553806 BILL BARRETT CORPORATION No. 43-23-4271 42 71 NE SE Sec. 23 FL 119,553066 BILL BARRETT CORPORATION No. 12-24-4271 42 71 SW NW Sec. 24 FL 89,0554344 BILL BARRETT CORPORATION No. 34-24-4271 42 71 SW SE Sec. 24 FL 203,554302 PEABODY NATURAL GAS LLC No. 41-25-42-71 42 71 NE NE Sec. 25 FL 36,3549603 PEABODY NATURAL GAS LLC No. 23-26 42 71 NE SW Sec. 26 FL 192,549605 PEABODY NATURAL GAS LLC No. 12-26 42 71 SW NW Sec. 26 FL 347,549606 PEABODY NATURAL GAS LLC No. 14-26 42 71 SW SW Sec. 26 FL 301,554299 PEABODY NATURAL GAS LLC No. 41-26-42-71 42 71 NE NE Sec. 26 FL 103,554301 PEABODY NATURAL GAS LLC No. 21-26-42-71 42 71 NE NW Sec. 26 SI 94,8551234 BILL BARRETT CORPORATION No. 12-27-42-71 42 71 SW NW Sec. 27 FL 100,551235 BILL BARRETT CORPORATION No. 14-27-42-71 42 71 SW SW Sec. 27 FL 128,551236 BILL BARRETT CORPORATION No. 21-27-42-71 42 71 NE NW Sec. 27 FL 129,551237 BILL BARRETT CORPORATION No. 23-27-42-71 42 71 NE SW Sec. 27 FL 120,552018 BILL BARRETT CORPORATION No. 12-34-42-71 42 71 SW NW Sec. 34 FL 90,1552019 BILL BARRETT CORPORATION No. 21-34-42-71 42 71 NE NW Sec. 34 FL 112,552020 BILL BARRETT CORPORATION No. 32-34-42-71 42 71 SW NE Sec. 34 FL 104,552021 BILL BARRETT CORPORATION No. 41-34-42-71 42 71 NE NE Sec. 34 FL 119,554295 PEABODY NATURAL GAS LLC No. 23-35-42-71 42 71 NE SW Sec. 35 FL 71,1554296 PEABODY NATURAL GAS LLC No. 21-35-42-71 42 71 NE NW Sec. 35 FL 84,0554297 PEABODY NATURAL GAS LLC No. 14-35-42-71 42 71 SW SW Sec. 35 FL 65,3554298 PEABODY NATURAL GAS LLC No. 12-35-42-71 42 71 SW NW Sec. 35 FL 94,3

Status Codes: FL = Flowing, SI = Shut in CBNG well status from WOGCC database 5/14/08 Cumulative production from WOGCC database 9/25/08
Appendix E 

E-16 Final EIS, Wright Area Co

CBNG WELLS CAPABLE OF PRODUCTION WITHIN THE 

SOUTH PORCUPINE LBA TRACT AS APPLIED FOR AND LANDS ADDED BY BLM’S STUDY AREA 

API 

Number 

(Short) Company Well Number TWP RNG Location 

WOGCC 

Status 

Cumul

Produc

Ga

(MC

554303 PEABODY NATURAL GAS LLC No. 23-1-41-71 41 71 NE SW Sec. 1 FL 92,7554304 PEABODY NATURAL GAS LLC No. 21-1-41-71 41 71 NE NW Sec. 1 SI 14,0554305 PEABODY NATURAL GAS LLC No. 14-1-41-71 41 71 SW SW Sec. 1 FL 72,6554306 PEABODY NATURAL GAS LLC No. 12-1-41-71 41 71 SW NW Sec. 1 FL 54,4554226 YATES PETROLEUM CORPORATION No. 8 41 71 NE SE Sec. 10 FL 62,2554212 YATES PETROLEUM CORPORATION No. 2 41 71 NE SW Sec. 11 SI 61,2551248 BILL BARRETT CORPORATION No. 34-11-41-71 41 71 SW SE Sec. 11 FL 114,0551249 BILL BARRETT CORPORATION No. 43-11-41-71 41 71 NE SE Sec. 11 FL 148,7553817 BILL BARRETT CORPORATION No. 12-12-4171 41 71 SW NW Sec. 12 FL 74,9553818 BILL BARRETT CORPORATION No. 14-12-4171 41 71 SW SW Sec. 12 FL 96,9553819 BILL BARRETT CORPORATION No. 23-12-4171 41 71 NE SW Sec. 12 FL 93,4554210 YATES PETROLEUM CORPORATION No. 1 41 71 SW SW Sec. 13 FL 74,7

Status Code: FL = Flowing, SI = Shut-InCBNG well status from WOGCC 5/14/08 Cumulative production data from WOGCC 9/25/08 
APPENDIX F 

SUPPLEMENTAL AIR QUALITY INFORMATION 
Appendix F 

Final EIS, Wright Area Coal Lease Applications F-1

F-1.0 INTRODUCTION 

The purpose of this appendix is to provide background information on air 

quality issues, including the regulatory framework, regional air quality 

conditions, dispersion model methodologies, and the Best Available Control 

Technology (BACT) process. 

The air quality discussion in Chapter 3 of this EIS focuses on potential air 

quality impacts specific to the Black Thunder, Jacobs Ranch, and North 

Antelope Rochelle mines and the North Hilight Field, South Hilight Field, West 

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

Tracts (Figure F-1). Cumulative air quality-related impacts associated with 

coal leasing in the Powder River Basin (PRB) of Wyoming are addressed in 

Section 4.2.3 of this EIS, which summarizes the results the Task 1A (Current 

Air Quality Conditions), Task 3A (Cumulative Air Quality Effects), and Task 3A 

Supplemental (Cumulative Air Quality Effects for 2015) Reports of the Powder 

River Basin Coal Review, prepared by the ENSR Corporation for the BLM 

Wyoming State Office, BLM Wyoming High Plains District Office, and BLM 

Montana Miles City Field Office, September 2005 (Tasks 1A and 3A) and 

October 2008 (Task 3A Supplemental). 

F-2.0 REGULATORY FRAMEWORK 

Ambient air quality and air pollution emissions are regulated under federal and 

state laws and regulations. In Wyoming, the Wyoming Department of 

Environmental Quality/Air Quality Division (WDEQ/AQD) is responsible for 

managing air quality through state regulations promulgated in the Wyoming 

Air Quality Standards and Regulations (WAQSR) and through the Wyoming 

State Implementation Plan (SIP). WDEQ/AQD has also been delegated 

authority by the U.S. Environmental Protection Agency (EPA) to implement 

federal programs of the Clean Air Act Amendment of 1990 (CAAA). 

The WDEQ/AQD implements WAQSR and CAAA requirements through various 

air permitting programs. A proponent initiating a project must undergo new 

source review and obtain a pre-construction permit or a permit waiver 

authorizing construction of the project. This process ensures that the project 

will comply with the air quality requirements at the time of construction. To 

ensure on-going compliance, WDEQ/AQD also implements an operating permit 

program that can require on-going monitoring of emissions sources and/or 

source control systems. 

F-2.1 National Ambient Air Quality Standards 

The Clean Air Act (CAA) requires EPA to establish National Ambient Air Quality 

Standards (NAAQS) to protect public health and welfare. These standards 

define the maximum level of air pollution allowed in the ambient air. The CAA 

established NAAQS for six pollutants, known as “criteria” pollutants, which 

“...cause or contribute to air pollution which may be reasonably anticipated to
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 F-1. General Location Map with Federal Coal Leases and LBA Tracts.

Appendix F

F-2 Final EIS, Wright Area Coal Lease Applications
Appendix F 

Final EIS, Wright Area Coal Lease Applications F-3

endanger public health or welfare and the presence of which in the ambient air 

results from numerous or diverse mobile or stationary sources.” The six, 

present-day criteria pollutants are lead, nitrogen dioxide (NO2), sulfur dioxide 

(SO2), carbon monoxide (CO), ozone (O3) and particulate matter (PM10 and 

PM2.5), where PM10 is coarse particulate with mean aerodynamic diameter of 10 

microns or less and PM2.5 is fine particulate with a diameter of 2.5 microns or 

less. 

The CAA and CAAA allow states to promulgate additional ambient air 

standards that are at least as stringent, or more stringent, than the NAAQS. A 

list of the criteria pollutants regulated by the CAA, and the currently applicable 

NAAQS set by the EPA for each, is presented in Table F-1. The Wyoming 

Ambient Air Quality Standards, or WAAQS, set by the WDEQ/AQD are also 

listed in this table. In some instances, the Wyoming standards are more 

stringent than the NAAQS. 

During the new source review process, applicants must demonstrate that the 

facility will not cause or significantly contribute to exceedance of these 

standards. These demonstrations are made via atmospheric dispersion 

modeling or other means, including monitoring data approved by the 

WDEQ/AQD administrator. 

F-2.2 Attainment/Non-Attainment Area Designations 

Pursuant to the CAA, EPA has developed a method for classifying existing air 

quality in distinct geographic regions known as air basins, or air quality control 

regions, and/or Metropolitan Statistical Areas (MSAs). For each federal criteria 

pollutant, each air basin (or portion of a basin or MSA) is classified as in 

“attainment” if the area has “attained” compliance with (that is, not exceeded) 

the adopted NAAQS for that pollutant, or is classified as in “non-attainment” if 

the levels of ambient air pollution exceed the NAAQS for that pollutant. Areas 

for which sufficient ambient monitoring data are not available to define 

attainment status are designated as “unclassified” for those particular 

pollutants. 

States use the EPA method to designate areas within their borders as being in 

“attainment” or “non-attainment” with the NAAQS. Existing air quality 

throughout most of the PRB in Wyoming, including the general Wright analysis 

area, is designated an attainment area for all pollutants. However, the town of 

Sheridan, Wyoming, located in Sheridan County about 150 miles northwest of 

the general Wright analysis area, is a moderate non-attainment area for PM10

due to localized sources and activity within the town. There are no other nonattainment areas within 150 miles of the project area. 
Appendix F 

 F-4 Final EIS, Wright Area 

Table F-1. Assumed Background Air Pollutant Concentrations, Applicable AAQS, and PSD I

μg/m3). 

Criteria Pollutant 

Averaging 

Time1

Background 

Concentration 

Primary 

NAAQS2

Secondary 

NAAQS2 WAAQS 

PSD Cla

Increme

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 r

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, th

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 val

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 Decemb

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 valu

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 an

24-hr = average of 98th percentile values in 2005-2008.) 

Source: BLM 2005b, EPA 2009a, and WDEQ/AQD 
Appendix F 

 Final EIS, Wright Area Coal Lease Applications F-5

F-2.3 Prevention of Significant Deterioration 

Under requirements of the CAA, EPA has established Prevention of Significant 

Deterioration (PSD) rules, intended to prevent deterioration of air quality in 

attainment (and unclassifiable) areas. Increases in ambient concentrations of 

NO2, SO2, and PM10 are limited to modest increments above the existing or 

“baseline” air quality in most attainment areas of the country (Class II areas 

discussed below), and to very small incremental increases in pristine 

attainment areas (Class I areas discussed below). 

For the purposes of PSD, EPA has categorized each attainment area within the 

United States into one of three PSD area classifications. PSD Class I is the 

most restrictive air quality category, and was created by Congress to prevent 

further deterioration of air quality in national and international parks, national 

memorial parks and national wilderness areas of a given size threshold which 

were in existence prior to 1977, or those additional areas which have since 

been designated Class I under federal regulations (40 CFR 52.21). All 

remaining areas outside of the designated Class I boundaries were designated 

Class II areas, which allow a relatively greater deterioration of air quality over 

that in existence in 1977, although still within the NAAQS. No Class III areas, 

which would allow further degradation, have been designated. 

The federal land managers have also identified certain federal assets with Class 

II status as “sensitive” Class II areas for which air quality and/or visibility are 

valued resources. 

Table F-2 is a list of mandatory federal Class I areas, tribal Class I areas, and 

federal Class II areas that are of special interest in the region and their 

distance from the general Wright analysis area. The closest Class I area to the 

general Wright analysis area is Wind Cave National Park in South Dakota, 

located about 91 miles to the east. The next closest Class I area is the 

Northern Cheyenne Indian Reservation (tribal federal Class I area), located 

about 132 miles to the north-northwest. The closest sensitive Class II areas 

are the Devils Tower National Monument and the Jewel Cave National 

Monument, which are approximately 70 miles north-northeast and 74 miles 

east of the general Wright analysis area, respectively. 

PSD regulations limit the maximum allowable increase (increment) in ambient 

PM10 in a Class I airshed resulting from major stationary sources or major 

modifications to 4 μg/m3 (annual geometric mean) and 8 μg/m3 (24-hour 

average). Increases in other criteria pollutants are similarly limited. Specific 

types of facilities listed in the PSD rules which emit, or have the potential to 

emit, 100 tons per year or more of PM10 or other criteria air pollutants, or any 

other facility which emits, or has the potential to emit, 250 tons per year or 

more of PM10 or other criteria air pollutants, are considered major stationary 

sources and must therefore demonstrate compliance with those incremental 

standards during the new source permitting process. However, fugitive 

emissions are not counted against the PSD major source applicability threshold
Appendix F 

F-6 Final EIS, Wright Area Coal Lease Applications

Table F-2. 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. 
Appendix F 

 Final EIS, Wright Area Coal Lease Applications F-7

unless the source is so designated by federal rule (40 CFR 52.21). As a result, 

the surface coal mines in the PRB have not been subject to permitting under 

the PSD regulations because the mine emissions that are subject to PSD 

applicability levels fall below these thresholds. 

F-2.4 Best Available Control Technology 

All sources being permitted within Wyoming must meet state-specific best 

available control technology (BACT) requirements, regardless of whether the 

source is subject to state/federal PSD review. During new source review, a 

BACT analysis is developed for the proposed project. The BACT analysis must 

evaluate all control options on the basis of technical, economic and 

environmental feasibility. BACT for mining operations in the PRB is largely 

dictated by categorical control requirements defined in the WAQSR. BACT 

decisions are mandated through the new source review pre-construction 

permit. 

F-2.5 New Source Performance Standards 

The new source performance standards (NSPS) are a program of “end-of-stack” 

technology-based controls/ approaches required by the CAA and adopted by 

reference into the WAQSR. These standards, which apply to specific types of 

new, modified or re-constructed stationary sources, require the sources to 

achieve some base level of emissions control. For surface coal mining in the 

PRB, this includes certain activities at coal preparation plants. Specifically, the 

applicable requirements can be found at 40 CFR Part 60, Subpart Y (Standards 

of Performance for Coal Preparation Plants), and in the WAQSR. However, in 

Wyoming these standards are typically less stringent than state-level BACT 

limits. 

F-2.6 Federal Operating Permit Program 

The CAAA required the establishment of a facility-wide permitting program for 

larger sources of pollution. This program, known as the Federal Operating 

Permit Program, or “Title V” (codified at Title V of the 1990 CAAA), requires that 

“major sources” of air pollutants obtain a federal operating permit. Under this 

program, a “major source” is a facility that has the potential to emit more than 

100 tons per year (tpy) of any regulated pollutant, 10 tpy of any single 

hazardous air pollutant (HAP), or 25 tpy or more of any combination of HAPs, 

from applicable sources. The operating permit is a compilation of all applicable 

air quality requirements for a facility and requires an ongoing demonstration of 

compliance through testing, monitoring, reporting and recordkeeping 

requirements. The potential to emit (PTE) for PM10 under the existing air 

quality permits for the Black Thunder, Jacobs Ranch, and North Antelope 

Rochelle mines were well below the 100 tpy applicability threshold. 
Appendix F 

F-8 Final EIS, Wright Area Coal Lease Applications

F-2.7 Summary of Pre-Construction Permitting Procedures 

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. A new coal mine, or a modification to an existing 

mine, must be permitted by WDEQ/AQD, pursuant to the provisions of 

WAQSR Chapter 6, Section 2. Under these provisions, a successful permittee 

must demonstrate that it will comply with all applicable aspects of the WAQSR 

including state and federal ambient air standards. 

When a permittee decides to construct a new surface coal mine or modify 

operations at an existing surface coal mine that will cause an increase in 

pollutant emissions, they must submit an application, which is reviewed by 

WDEQ/AQD new source review staff and the applicable WDEQ/AQD field 

office. Typically, a company will meet with the WDEQ/AQD prior to submitting 

an application to determine issues and details that need to be included in the 

application. A surface coal mining application will include the standard 

application, BACT measures that will be implemented, an inventory of point 

and fugitive sources for the mine in question as well as neighboring mines and 

other sources, and air quality modeling analyses addressing cumulative 

impacts in the mining region. 

BACT must be employed at all sources permitted/exempted in Wyoming. Per 

WAQSR Chapter 6, Section 2, BACT at large mining operations typically 

include but may not be limited to: paving of access roads, treating of haul 

routes with chemical dust suppressant (and water) and storage of large 

amounts of materials/coal awaiting shipment in enclosures such as silos, 

troughs or barns. These (and other) mitigation measures are considered in the 

development of emission inventories used for modeling/permitting. 

For the modeling analyses, an applicant must compile an emission inventory of 

PM10 from their mining operation, neighboring mines and other surrounding 

sources. For PM10 from the applicant mine, both point source and fugitive dust 

emissions are quantified. The emissions are based on the facility’s potential to 

emit in each year of the life of mine (LOM). The applicant also examines the 

surrounding coal mining operations and their previous air quality permits to 

determine their emissions throughout the LOM. Two or more worst-case years 

(generally with the highest potential emissions) are then modeled in detail. 

Other surrounding emission sources, such as power plants, compressor 

stations, paved highways, long-haul railroad lines and municipalities are also 

considered in the modeling analysis. 

Coal mines in the PRB are also required to quantify nitrogen oxides (NOx) 

emissions from their operations. Dispersion modeling is required to 

demonstrate compliance with the ambient NO2 standard. Potential emissions 

from diesel powered mining equipment, blasting and locomotive emissions (on 
Appendix F 

 Final EIS, Wright Area Coal Lease Applications F-9

mine property) are considered in the modeling analyses. In a fashion similar to 

the PM10 analysis, neighboring mining operations and other surrounding 

sources are also included in the NOx/NO2 analysis. 

Long-term PM10 modeling is conducted for the permit application to 

demonstrate compliance with the annual PM10 standard. For both point and 

area sources, the Industrial Source Complex Long Term model, version 3 

(ISCLT3) is typically used. 

The WDEQ/AQD has recently required all mines in the PRB to “submit and 

justify a background PM10 concentration with each permit application” 

(WDEQ/AQD 2006). A site specific PM10 background concentration of 14.91 

μg/m3 was developed in the modeling analysis for the Black Thunder and 

Jacobs Ranch mines, while a background concentration of 15.0 μg/m3 was 

developed for the North Antelope Rochelle Mine. The modeling results are 

added to the background and compared to the annual standard. Likewise, 

compliance with the annual NO2 standard is verified using ISCLT3 and an NO2

background concentration of 14.0 μg/m3 for the Black Thunder and Jacobs 

Ranch mines and a NO2 background concentration of 20.0 μg/m3 for the North 

Antelope Rochelle Mine. 

Short-term PM10 modeling is not required by WDEQ/AQD, nor does 

WDEQ/AQD consider it to be an accurate representation of short-term 

impacts. Section 234 of the 1990 CAAA mandated the administrator of the 

EPA to analyze the accuracy of short-term modeling of fugitive particulate 

emissions from surface coal mines. A June 26, 1996 letter from EPA Region 

VIII to Wyoming State Representative, Ms. Barbara Cubin, detailed the results 

of an EPA study wherein the short-term model failed to meet evaluation criteria 

and tended to significantly overpredict 24-hour impacts of surface coal mines. 

The memorandum of agreement of January 24, 1994 between EPA Region VIII 

and the State of Wyoming allows WDEQ/AQD to conduct monitoring in lieu of 

short-term modeling for assessing coal mining-related impacts in the PRB. 

This agreement remains in effect and ambient particulate monitoring is 

required of each coal mine through conditions of their respective permits. The 

1994 Memorandum of Agreement also required WDEQ/AQD to implement 

“Best Available Work Practice” mitigation measures at any mine where an 

exceedance of the PM10 air quality standard has occurred. 

The permit application is reviewed by WDEQ/AQD to determine compliance 

with all applicable air quality standards and regulations. This includes review 

of compliance with emission limitations established by NSPS, review of 

compliance with ambient standards through modeling analyses, and 

establishment of control measures to meet BACT requirements. The 

WDEQ/AQD proposed permit conditions are sent to public notice for a 30-day 

review period after which a final decision on the permit is made (or a public 

hearing is held prior to a final permit decision). 
Appendix F 

F-10 Final EIS, Wright Area Coal Lease Applications

The Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines have 

prepared permit applications and conducted air quality modeling analyses 

when mine plan changes have dictated and as required by WDEQ/AQD. These 

applications and analyses demonstrate that mining operations have complied, 

and will continue to comply, with all applicable aspects of the WAQSR and the 

federal CAAA. 

In conducting an analysis of air quality impacts in the PRB for the Wyoming 

and Montana BLM, the Task 1A Report for the Powder River Basin Coal Review 

reports a background concentration of 5 μg/m3 for NOx for the entire PRB. The 

air permit actions for the Black Thunder and Jacobs Ranch mines used a 

background concentration of 14.0 μg/m3 for PM10 and the North Antelope 

Rochelle Mine used a background concentration of 20.0 μg/m3. These 

concentrations are based on recently monitored values in Gillette, Wyoming 

and at the Black Thunder, Jacobs Ranch, and North Antelope Rochelle mines, 

and include all sources operating at the time the value was measured, 

including existing coal mine operations located around Gillette. 

F-2.8 Natural Events Action Plan 

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 

has 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. The plan was submitted to and approved by 

EPA. A report describing the plan can be accessed on the WDEQ/AQD’s 

website at http://deq.state.wy.us/AQD/NEAP%20Files/1-23-07NEAP.pdf. 

The NEAP recognizes that certain NAAQS exceedances due to natural events 

are uncontrollable. While all practical mitigation measures need to be 

implemented during those events, the exceedances should not be considered 

against the NAAQS attainment designation for the region. Specific NEAP goals 

include: 

• Provide for the protection of public health, 

• Develop public information program, 

• Provide a mechanism for “flagging” exceedances due to uncontrollable 

natural events, 

• Implement Best Available Control Measures (BACM) and Reactionary 

Control Measures (RACM) based on the severity of the event, and 

• Provide mechanism for excluding flagged data when they meet specific 

wind speed criteria and BACM and RACM are in place. 

The NEAP identifies, in addition to the BACT measures generally included in 

individual mine air quality permits, two other categories of control measures 

designed to prevent exceedances during high wind events (WDEQ/AQD 2007). 

One of these is an additional list of control measures that the mines can 

implement continuously so that they are in place before a high wind event 
Appendix F 

 Final EIS, Wright Area Coal Lease Applications F-11

occurs. These measures are not current requirements in all of the mines’ air 

quality permits. They primarily address the principal mine-controlled sources 

of fugitive dust, which are large contiguous disturbed areas. These measures 

include: 

1. Stabilizing topsoiled area as soon as practicable following topsoil 

replacement. 

2. Ripping, windrowing, mulching, temporarily seeding or chemically 

treating areas greater than 300 contiguous acres in size that have been 

stripped of topsoil but will not be mined in the near future. 

3. Ripping, windrowing, temporarily seeding or chemically treating graded 

backfill areas greater than 300 contiguous acres in size. 

4. Ripping, mulching, temporarily seeding or chemically treating long-term 

out-of-pit overburden and topsoil stockpiles that have been graded. 

5. Applying non-vegetative barriers such as gravel or other large-diameter 

particles to erodible surfaces to reduce surface erosion where 

appropriate. 

6. Cleaning, treating, and maintaining pads in front of truck dumps to 

prevent accumulations of spilled materials from getting pulverized. 

7. Scheduling topsoil removal, backfill grading and topsoil replacements 

concurrently to minimize open areas when possible. 

8. Requiring contractors to apply water and/or chemical dust suppressants 

in their haulage areas. 

The second additional category of control measures discussed in the NEAP 

includes measures that are not currently required by all individual air quality 

permits but are actions that can be taken during a high wind event, depending 

on site specific conditions (WDEQ/AQD 2007). These include: 

1. The mine operator will consider relevant information, including National 

Weather Service forecasts and local meteorological information, to 

confirm that a high wind event is occurring. 

2. The mine operator will visually determine areas of mining activity that 

are generating excessive visible dust and direct water trucks to those 

areas. 

3. The mine operator should direct overburden operations to the shortest 

haul distance available during a high wind event. 

4. The mine operator will evaluate the practicality of dumping the 

overburden as low as possible. 

5. Mine employees will inspect for and extinguish coal fires. 

6. The mine operator will evaluate shutting down scoria crushing 

operations that appear to be generating excess dust. 

7. The mine operator will evaluate shutting down road maintenance 

activities that are generating dust. 

8. The mine operator will evaluate ordering contractors to increase water, 

reduce operating equipment or shut down haulage. 

9. The mine operator will evaluate the need to shut down and/or reduce 

earthmoving activities as the mine schedule and conditions will allow. 
Appendix F 

F-12 Final EIS, Wright Area Coal Lease Applications

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 exeedances are 

demonstrated to be the result of natural events. Based on the EPA’s Natural 

Events Policy, PM10 concentrations due to dust raised by unusually high winds 

will be treated as uncontrollable 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. 

The WDEQ/AQD NEAP includes a public education plan, a public notification 

and health advisory program, and a plan to abate or minimize appropriate 

contributing controllable sources of PM10, which includes three categories of 

control measures. The NEAP approved by EPA only includes measures for 

control of coal mine sources since it is the ambient monitoring systems around 

the large surface coal mines that have recorded the exceedances of the 24-hour 

PM10 NAAQS. If it is demonstrated that there are non-coal sources 

contributing to elevated measurements in an area of concern, WDEQ/AQD may 

address these additional sources separately from the approved NEAP or as a 

future update of the plan. 

F-3.0 EXISTING AIR QUALITY 

WDEQ monitors air quality through an extensive network of air quality 

monitors throughout the state. Particulate matter is generally measured as 

PM10. The eastern portion of the PRB has an extensive network of PM10 

monitors operated by the mining industry due to the density of coal mines in 

the region (Figure F-2). There are also monitors in Sheridan, Gillette, Arvada 

and Wright, Wyoming. 

This network is sited to measure ambient air quality and to infer impacts from 

specific sources. Source-specific monitors may also be used for developing 

trends in PM10 concentrations. WDEQ uses data from this monitoring network 

to identify potential air quality problems and to anticipate issues related to air 

quality. With this information, the WDEQ can stop or reverse trends that 

negatively affect the ambient air. Part of that effort has resulted in the 

formation of a coalition involving the counties, coal companies and coal bed 

methane operators to focus on minimizing dust from roads. The WDEQ may 

also take enforcement action to remedy a situation where monitoring shows a 

violation of any standard. If a monitored standard is exceeded at a specific 

source, the state agency may initiate enforcement against that source. In those 

instances, the state agency may use a negotiated settlement agreement to seek 

corrective action. 

WDEQ operates two visibility monitoring stations in the PRB, both of which are 

IMPROVE sites. One of these sites is located north of Gillette. This site 

includes a nephelometer, a transmissometer, an aerosol monitor (IMPROVE 

protocol), and meteorological instruments to measure wind speed, direction, 

temperature, and relative humidity. The site is also equipped with a digital
CROOK

COUNTY

WESTON

COUNTY

NIOBRARA

COUNTY

SHERIDAN

COUNTY

JOHNSON

COUNTY

NATRONA

COUNTY

CAMPBELL

COUNTY

CONVERSE

COUNTY

CASPER DOUGLAS

GILLETTE BUFFALO

SHERIDAN

MONTANA

SOUTH DAKOTA

WRIGHT

LEGEND

PM10 Monitoring Station, Active in 2008

0 12.5 25 50

GRAPHIC SCALE (MILES)

Source: EPA (2009h)

PM2.5 Monitoring Station, Active in 2008

Figure F-2. Active Particulate Monitoring Stations in Northeastern Wyoming.

Appendix F

Final EIS, Wright Area Coal Lease Applications F-13
Appendix F 

F-14 Final EIS, Wright Area Coal Lease Applications

camera and analyzers for ozone and nitrogen oxides (NO, NO2, NOx). The 

second visibility monitoring station is located west of Buffalo and includes a 

nephelometer, a transmissometer, an aerosol monitor (IMPROVE), 

meteorological instruments to measure wind speed, direction, temperature, 

and relative humidity, plus a digital camera. 

Air quality monitoring equipment for NO2 within the PRB includes a Wyoming 

Air Resources Monitoring System (WARMS) operated by BLM to detect sulfur 

and nitrogen concentrations near Buffalo, Sheridan, and Newcastle and a 

National Atmospheric Deposition Program (NADP) monitoring system for 

precipitation chemistry in Newcastle. 

F-3.1 Regional Particulate Emissions 

The federal and state standards for particulate matter pollutant are discussed 

in Chapter 3, Section 3.4.2.1 of this EIS. 

WDEQ/AQD requires monitoring data to document the air quality at all of the 

PRB mines. Each mine monitored PM10 for a 24-hour period every 6 days at 

multiple monitoring sites through the end of 2001. This frequency was 

increased by the WDEQ/AQD to a 24-hour period every 3 days beginning in 

2002. Available monitoring data for total suspended particles (TSP) began in 

1980 and data for PM10 began in 1989. Through 2004 approximately 57,000 

TSP samples had been collected, and approximately 48,950 PM10 samples had 

been collected through 2008, making the eastern PRB one of the most intensely 

monitored areas for particulates in the county. Table F-3 summarizes the 

annual arithmetic average of data from 1980 through 2008 for sites located at 

the mining operations in Campbell and Converse counties. 

As indicated in Table F-3, the long-term trend in particulate emissions 

remained relatively flat through 1998. The overall average annual TSP 

concentration was 37.7 μg/m3 from 1980 through 2003, with annual averages 

ranging between 27.8 μg/m3 and 57.5 μg/m3. There were increases in 1988 

and 1996, which may have been the result of fires in the region during those 

years. Increases from 1999 to 2003 may be related to drought conditions as 

well as increases in coal and overburden production and increases in other 

natural resource development activities, including coal bed natural gas (CBNG), 

during that period. Annual average PM10 concentrations from 1989 through 

1998 were relatively flat, ranging from 12.9 μg/m3 to 16.5 μg/m3, with an 

overall average of 15.4 μg/m3. Annual average PM10 concentrations from 1999 

through 2008 were increased slightly, but were similarly relatively flat, ranging 

from 20.3 μg/m3 to 27.2 μg/m3, with an overall average of 23.0 μg/m3. 

The 1980-1998 time period was associated with significant growth in the 

surface coal mining industry in the eastern PRB. Coal production increased 

from about 59 million tons per year (mmtpy) to over 293 mmtpy (an increase of 

almost 400 percent), and associated overburden production increased from 105 

million bank cubic yards (mmbcy) to 669 mmbcy per year (an increase of over 
Appendix F 

 Final EIS, Wright Area Coal Lease Applications F-15

Table F-3. Summary of WDEQ/AQD Reports on Air Quality Monitoring for 

Surface Coal Mines1 in Wyoming's PRB, 1980-2007. 

Year 

Coal 

Produced 

(mmtpy) 

Overburden 

Moved 

(mmbcy) 

Number of Mines 

Operating/ 

Monitoring TSP/ 

Monitoring PM101

Number of 

TSP/PM10

Monitoring

Sites2

TSP 

Average 

(μg/m3) 

PM10

Average 

(μg/m3) 

1980 58.7 105.3 10/14/0 34/0 35.5 na3

1981 71.0 133.4 11/13/0 35/0 39.4 na 

1982 76.1 141.1 11/14/0 40/0 31.2 na 

1983 84.9 150.9 13/14/1 41/1 32.6 11.2 

1984 105.3 169.5 14/16/1 42/1 33.9 11.1 

1985 113.0 203.4 16/17/0 49/0 32.3 na 

1986 111.2 165.7 16/17/0 45/0 29.3 na 

1987 120.7 174.6 16/17/0 43/0 31.7 na 

1988 138.8 209.7 16/17/0 43/0 37.7 na 

1989 147.5 215.6 15/17/3 40/3 32.1 15.9 

1990 160.7 220.1 17/17/5 47/5 34.3 14.8 

1991 171.4 242.3 17/17/5 46/6 32.7 16.5 

1992 166.1 296.0 17/17/7 41/7 31.7 15.9 

1993 188.8 389.5 17/17/8 40/11 27.8 14.5 

1994 213.6 483.9 17/18/8 44/11 31.7 15.5 

1995 242.6 512.7 16/18/8 41/12 29.6 12.9 

1996 257.0 605.4 17/18/8 41/12 35.4 16.0 

1997 259.7 622.0 16/17/10 39/15 33.3 15.9 

1998 293.5 669.0 16/17/12 36/17 33.9 15.9 

1999 317.1 762.9 15/17/12 36/18 55.3 21.6 

2000 322.6 868.9 15/15/12 31/17 56.1 23.4 

2001 354.1 927.7 12/11/12 29/29 57.5 27.2 

2002 359.7 1,032.1 13/11/13 23/38 56.0 23.3 

2003 363.6 1,044.2 13/10/13 16/34 51.9 20.8 

2004 381.6 1,184.4 13/6/13 7/33 --4 20.3 

2005 390.3 1,147.6 12/6/12 7/33 --4 21.5 

2006 431.9 1,256.7 13/5/13 6/33 --4 24.2 

2007 436.5 1,268.5 14/4/14 4/33 --4 25.2 

2008 451.7 1,432.2 13/0/13 0/37 --4 22.8 

1 Mines include Buckskin, Rawhide, Eagle Butte, Dry Fork, Fort Union (acquired by Dry 

Fork), Wyodak, Clovis Point (acquired by Wyodak), Caballo, Belle Ayr, Cordero Rojo 

(Caballo Rojo combined with Cordero), Coal Creek, Jacobs Ranch, Black Thunder, 

North Antelope Rochelle (North Antelope combined with Rochelle), and Antelope. (North 

Rochelle Mine was acquired by Black Thunder and North Antelope Rochelle mines.) 

2 Some sites include more than one sampler, so the number of samplers is greater than 

the number of sites. 

3 Not applicable (no monitoring for PM10 was done). 4 Data no longer pertinent due to paucity of monitoring sites. 

Sources: 1980 through 1996 emissions and production data from April 1997 report 

prepared by Wyoming Mining Association for WDEQ/AQD. 1997 through 2008 

PM10 emissions data from EPA AirData database (EPA 2009a). 1997 through 2003 

TSP emissions data from WDEQ/AQD (available upon request). 1997 through 

2008 production data from WDEQ/AQD (Shamley 2008a, 2010) and Wyoming 

Department of Employment/State Inspector of Mines (1997-2007a, 2008c). 
Appendix F 

F-16 Final EIS, Wright Area Coal Lease Applications

537 percent). From 1990 through 2007, the average annual increase in coal 

production was 6.3 percent, while annual overburden production increased an 

average of 11.3 percent over the same time period. The proportionately larger 

annual increase in overburden production is due to the fact that the mines are 

gradually moving into areas of higher stripping ratios as the shallower reserves 

are mined out. 

The relatively flat trend in particulate emissions from 1980 through 1998 is 

due in large part to the Wyoming Air Quality Program that requires BACT at all 

permitted facilities. BACT control measures, which include watering and 

chemical treatment of roads, limiting the amount of area disturbed, temporary 

revegetation of disturbed areas to reduce wind erosion, and timely final 

reclamation, are discussed in Section 3.4.2.3 of this EIS. 

The average annual TSP concentration increased from 33.9 μg/m3 in 1998 to 

55.3 μg/m3 in 1999, and remained greater than 50.0 μg/m3 through 2003. 

The average annual PM10 concentration increased from 15.9 μg/m3 in 1998 to 

21.6 μg/m3 in 1999 and peaked in 2001 at 27.2 μg/m3. The monitored 

concentrations have decreased since 2001; in 2004, the average annual 

concentration was 20.3 μg/ m3 and in 2008 it was 22.8 μg/ m3. The average 

annual increase in coal production from 2001 through 2008 (3.4 percent per 

year, or 12.2 mmtpy over the 8-year period) and associated overburden 

production (6.8 percent per year and 63.1 mmbcy over the 8-year period) were 

less than a majority of the previous twenty 5-year running average periods, but 

the particulate concentrations remained relatively constant. There were no 

major fires in the region between 1998 and 2005 but major fires were 

experienced in the region in 2006 and 2007. There was an increase in CBNG 

development in the PRB between 1998 and 2005 and northeastern Wyoming 

has experienced extreme drought conditions as well as a dramatic increase in 

surface disturbance activities associated with CBNG development since 1999. 

All of these factors have exacerbated particulate emissions. 

There were no monitored exceedances of the 24-hour PM10 standards anywhere 

in the Wyoming PRB through year 2000. From 2001 through 2006 there were 

29 monitored exceedances of the 24-hour PM10 standard at seven operating 

mines, and in 2007 a total of 11 exceedances were reported at six mines. A 

majority of the 29 exceedances reported between 2001 and 2006 were 

associated with elevated winds exceeding 20 miles per hour, each of which 

could have qualified as a high wind event under the NEAP. Of the 11 

exceedances reported within the PRB in 2007, nine have been flagged as 

exceptional events by EPA under the NEAP and will be treated as 

uncontrollable natural events (not considered when determining the region’s 

air quality designation). Of the two other reported exceedances in 2007, one is 

still under review by EPA and may be flagged as an exceptional event under the 

NEAP, and one was determined by EPA to be a valid exceedance (not 

considered an exceptional event under the NEAP) and a notice of violation was 

subsequently issued (Shamley 2010). In 2008, a total of two exceedances of 

the 24-hour PM10 standard were reported in the PRB, one each at the Black 
Appendix F 

 Final EIS, Wright Area Coal Lease Applications F-17

Thunder Mine and North Rochelle Mine. WDEQ/AQD subsequently issued 

notices of violation for both exceedances that occurred in 2008 (Shamley 2010). 

There were no exceedances of the 24-hour PM10 particulate standard reported 

in the PRB in 2009 (Shamley 2010). In summary, 29 of the 33 valid 

exceedances (those not considered exceptional events under the NEAP) of the 

24-hour PM10 standard that have occurred in the PRB through 2009 have been 

recorded by the group of mines located south and east of the town of Wright; 

the remaining four valid exceedances occurred in the group of mines located 

north of Gillette (Figure F-1). 

Emissions control measures that are used to control particulate emissions at 

the PRB mines, including the three applicant mines in the Wright area (Black 

Thunder, Jacobs Ranch and North Antelope Rochelle), are discussed in 

Chapter 3, Section 3.4.2.3 of this EIS. 

County roads are also responsible for some portion of the fugitive dust related 

to transportation. To help address this problem, the Campbell County 

Commissioners, oil and gas production companies, and coal mine operators 

have formed a coalition to implement the most effective dust control measures 

on a number of county roads. Measures taken have ranged from the 

implementation of speed limits to paving of heavily traveled roads. The 

coalition has utilized chemical treatments to control dust as well as closing 

roads where appropriate or necessary and rebuilding existing roads to higher 

specifications. The coalition requested money from the Wyoming State 

Legislature to fund acquisition of Rotomill (ground up asphalt) to be mixed with 

gravel for use in treating some of the roads in the PRB. The Rotomill/gravel 

mixture has been demonstrated to be effective in reducing dust; the life of the 

mixture on treated roads is estimated to be from 5 to 6 years (Bott 2006). 

F-3.2 Regional NO2 Concentrations 

The federal and state standards for NO2 are discussed in Chapter 3, Section 

3.4.3.1 of this EIS. 

Nitrogen oxides (NOx) 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 the EPA, motor vehicles produce about 55 percent of the 

manmade NOx emissions, utilities and industrial/commercial/residential 

activities each produce about 22 percent of the manmade NOx emissions, and 

other sources account for the remaining 1 percent of the manmade emissions 

(EPA 2009b). The primary direct source of emissions of NOx during coal mining 

operations is tailpipe emissions from large mining equipment and other vehicle 

traffic inside the mine permit area. 

Blasting that is done to remove the material overlying the coal (the overburden) 

can result in emissions of several products, including NO2, as a result of the 

incomplete combustion of nitrogen-based explosives used in the blasting 
Appendix F 

F-18 Final EIS, Wright Area Coal Lease Applications

process. When this occurs, gaseous, orange-colored clouds may be formed and 

they can drift or be blown off mine permit areas. 

NO2 is a product of incomplete combustion of sources such as gasoline- and 

diesel-burning engines or from mine blasting activities. Incomplete combustion 

during blasting may be caused by wet conditions in the overburden, 

incompetent or fractured geological formations, deformation of bore holes, and 

blasting agent factors. Generally, blasting-related NOx emissions are more 

prevalent at operations that use the blasting technique referred to as cast 

blasting (Chancellor 2003). Cast blasting refers to a type of direct blasting in 

which the blast is designed to cast the overburden from on top of the coal into 

the previously mined area. 

In the mid-to late-1990s, the Office of Surface Mining Reclamation and 

Enforcement (OSM) received complaints from several citizens about blasting 

clouds from several mines in the PRB. EPA expressed concerns that NO2 levels 

in some of those blasting clouds may have been sufficiently high at times to 

cause human health effects. In response to those concerns, several studies 

have been conducted, the mines have modified their blasting techniques, and 

the WDEQ has imposed blasting restrictions on several mines. More 

information about these studies and restrictions is presented in the following 

discussion. 

On the order of the Director of the WDEQ, members of the mining industry in 

the PRB conducted a comprehensive, multi-year monitoring and modeling 

study of NO2 exposures from blast clouds. Results of the study (TBCC 2002), 

conducted pursuant to protocols reviewed and approved by the WDEQ, were 

provided to the WDEQ and the public in July 2002. 

Using a combination of NO2 measurements collected near 91 blast sites (78 

valid runs) and a conservative modeling/extrapolation approach, the authors 

developed a series of “safe” setback curves for coal, overburden and cast shots 

for various wind speed classes. The curves were derived from the sampled 

data, conservative projections of concentrations at greater/lesser distances 

than measured and an assumed safe level (based on a comprehensive review of 

available health effects data) of 5.0 ppm for 10 minutes. 

Subsequently, the data in the 2002 report (collected at the Black Thunder 

Mine) were augmented with monitored data/analyses from an additional 45 

validated blast events at the Eagle Butte, North Antelope Rochelle, Buckskin 

and Cordero Rojo mines. New curves, based on the entire basin-wide data set 

encompassing 123 valid tests, were developed but differed only slightly from 

the original Black Thunder curves. 

Measures that are used by the mines to control NO2 emissions related to 

blasting by the PRB mines are discussed in Chapter 3, Section 3.4.3.3 of the 

EIS.
Appendix F 

 Final EIS, Wright Area Coal Lease Applications F-19

F-4.0 REFERENCES CITED 

All references cited within this appendix are included within Section 6.0 of this 

EIS. 
APPENDIX G 

BIOLOGICAL ASSESSMENT 

FOR THE WRIGHT AREA COAL 

LEASE APPLICATIONS EIS 

NORTH HILIGHT FIELD LBA TRACT 

SOUTH HILIGHT FIELD LBA TRACT 

WEST HILIGHT FIELD LBA TRACT 

WEST JACOBS RANCH LBA TRACT 

NORTH PORCUPINE LBA TRACT 

SOUTH PORCUPINE LBA TRACT
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-i 

TABLE OF CONTENTS

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

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

G-1.2 Description of the North Hilight Field Tract Proposed Action and 

Alternatives.............................................................................. G-5

G-1.2.1 Proposed Action.............................................................. G-5

G-1.2.2 Alternatives to the Proposed Action ................................. G-7

G-1.2.2.1 Alternative 1.......................................................... G-7

G-1.2.2.2 Alternative 2 (BLM’s Preferred Alternative) ............. G-7

G-1.3 Description of the South Hilight Field Tract Proposed Action and 

Alternatives.............................................................................. G-9

G-1.3.1 Proposed Action............................................................ G-10

G-1.3.2 Alternatives to the Proposed Action ............................... G-10

G-1.3.2.1 Alternative 1........................................................ G-10

G-1.3.2.2 Alternative 2 (BLM’s Preferred Alternative) ........... G-10

G-1.4 Description of the West Hilight Field Tract Proposed Action and 

Alternatives............................................................................ G-14

G-1.4.1 Proposed Action............................................................ G-14

G-1.4.2 Alternatives to the Proposed Action ............................... G-14

G-1.4.2.1 Alternative 1........................................................ G-14

G-1.4.2.2 Alternative 2 (BLM’s Preferred Alternative) ........... G-17

G-1.4.2.3 Alternative 3........................................................ G-18

G-1.5 Description of the West Jacobs Ranch Tract Proposed Action and 

Alternatives............................................................................ G-20

G-1.5.1 Proposed Action............................................................ G-20

G-1.5.2 Alternatives to the Proposed Action ............................... G-22

G-1.5.2.1 Alternative 1........................................................ G-22

G-1.5.2.2 Alternative 2 (BLM’s Preferred Alternative) ........... G-22

G-1.6 Description of the North Porcupine Tract Proposed Action and 

Alternatives............................................................................ G-24

G-1.6.1 Proposed Action............................................................ G-25

G-1.6.2 Alternatives to the Proposed Action ............................... G-27

G-1.6.2.1 Alternative 1........................................................ G-27

G-1.6.2.2 Alternative 2 (BLM’s Preferred Alternative) ........... G-27

G-1.7 Description of the South Porcupine Tract Proposed Action and 

Alternatives............................................................................ G-30

G-1.7.1 Proposed Action............................................................ G-30

G-1.7.2 Alternatives to the Proposed Action ............................... G-32

G-1.7.2.1 Alternative 1........................................................ G-32

G-1.7.2.2 Alternative 2 (BLM’s Preferred Alternative) ........... G-32

G-2.0 REGULATORY FRAMEWORK ...................................................... G-34

G-3.0 CONSULTATIONS WITH U.S. FISH AND WILDLIFE SERVICE TO 

DATE.......................................................................................... G-36
Appendix G 

TABLE OF CONTENTS (Continued) 

G-ii Final EIS, Wright Area Coal Lease Applications

G-4.0 CURRENT STATUS OF SPECIES................................................. G-39

G-5.0 METHODS .................................................................................. G-41

G-5.1 Published Literature............................................................... G-42

G-5.2 Unpublished Documents........................................................ G-42

G-5.3 Personal Communications...................................................... G-42

G-5.4 Field Surveys ......................................................................... G-42

G-5.4.1 North Hilight Field Tract ............................................... G-43

G-5.4.2 South Hilight Field Tract............................................... G-43

G-5.4.3 West Hilight Field Tract................................................. G-46

G-5.4.4 West Jacobs Ranch Tract.............................................. G-46

G-5.4.5 North Porcupine Tract................................................... G-46

G-5.4.6 South Porcupine Tract .................................................. G-49

G-6.0 CURRENT HABITAT DESCRIPTIONS........................................... G-51

G-6.1 North Hilight Field Tract......................................................... G-53

G-6.2 South Hilight Field Tract ........................................................ G-54

G-6.3 West Hilight Field Tract.......................................................... G-56

G-6.4 West Jacobs Ranch Tract ....................................................... G-57

G-6.5 North Porcupine Tract ............................................................ G-59

G-6.6 South Porcupine Tract............................................................ G-61

G-7.0 CURRENT STATUS AND HABITAT REQUIREMENTS OF 

SPECIES..................................................................................... G-63

G-7.1 Ute Ladies’-tresses (Spiranthes diluvialis)................................ G-63

G-7.1.1 Biology and Habitat Requirements ................................ G-63

G-7.1.2 LBA Tracts Existing Environments................................ G-66

G-7.1.2.1 North Hilight Field............................................... G-66

G-7.1.2.2 South Hilight Field .............................................. G-69

G-7.1.2.3 West Hilight Field ................................................ G-71

G-7.1.2.4 West Jacobs Ranch ............................................. G-74

G-7.1.2.5 North Porcupine .................................................. G-77

G-7.1.2.6 South Porcupine.................................................. G-81

G-7.2 Black-footed Ferret (Mustela nigripes) ..................................... G-84

G-7.2.1 Biology and Habitat Requirements ................................ G-84

G-7.2.2 LBA Tracts Existing Environments................................ G-85

G-7.2.2.1 North Hilight Field............................................... G-86

G-7.2.2.2 South Hilight Field .............................................. G-86

G-7.2.2.3 West Hilight Field ................................................ G-87

G-7.2.2.4 West Jacobs Ranch ............................................. G-87

G-7.2.2.5 North Porcupine .................................................. G-88

G-7.2.2.6 South Porcupine.................................................. G-88

G-7.3 Blowout Penstemon (Penstemon haydenii) .............................. G-89

G-7.3.1 Biology and Habitat Requirements ................................ G-90

G-7.3.2 LBA Tracts Existing Environments................................ G-91

G-7.3.2.1 North Hilight Field............................................... G-92
Appendix G 

TABLE OF CONTENTS (Continued) 

Final EIS, Wright Area Coal Lease Application G-iii 

G-7.3.2.2 South Hilight Field .............................................. G-92

G-7.3.2.3 West Hilight Field ................................................ G-94

G-7.3.2.4 West Jacobs Ranch ............................................. G-94

G-7.3.2.5 North Porcupine .................................................. G-95

G-7.3.2.6 South Porcupine.................................................. G-95

G-8.0 DIRECT AND INDIRECT IMPACTS OF THE PROPOSED 

ACTIONS AND ALTERNATIVES ................................................... G-97

G-8.1 Ute Ladies’-tresses ................................................................. G-97

G-8.1.1 North Hilight Field ........................................................ G-97

G-8.1.2 South Hilight Field........................................................ G-98

G-8.1.3 West Hilight Field.......................................................... G-99

G-8.1.4 West Jacobs Ranch..................................................... G-100

G-8.1.5 North Porcupine.......................................................... G-101

G-8.1.6 South Porcupine ......................................................... G-102

G-8.2 Black-footed Ferret............................................................... G-103

G-8.2.1 North Hilight Field ...................................................... G-103

G-8.2.2 South Hilight Field...................................................... G-103

G-8.2.3 West Hilight Field........................................................ G-104

G-8.2.4 West Jacobs Ranch..................................................... G-105

G-8.2.5 North Porcupine.......................................................... G-105

G-8.2.6 South Porcupine ......................................................... G-106

G-8.3 Blowout Penstemon.............................................................. G-107

G-8.3.1 North Hilight Field ...................................................... G-107

G-8.3.2 South Hilight Field...................................................... G-107

G-8.3.3 West Hilight Field........................................................ G-108

G-8.3.4 West Jacobs Ranch..................................................... G-108

G-8.3.5 North Porcupine.......................................................... G-109

G-8.3.6 South Porcupine ......................................................... G-109

G-9.0 CUMULATIVE IMPACTS............................................................ G-109

G-9.1 Ute Ladies’-tresses ............................................................... G-112

G-9.2 Black-footed Ferret............................................................... G-113

G-9.3 Blowout Penstemon.............................................................. G-114

G-10.0 THREATS AND CONSERVATION MEASURES TO AVOID OR 

REDUCE ADVERSE IMPACTS................................................... G-114

G-10.1 Ute Ladies’-tresses ............................................................... G-114

G-10.2 Black-footed Ferret............................................................... G-115

G-10.3 Blowout Penstemon.............................................................. G-116

G-11.0 EFFECTS OF THE PROPOSED ACTIONS AND ALTERNATIVES 

ON THE EXPECTED STATUS OF SPECIES IN THE FUTURE ..... G-118

G-12.0 DETERMINATION OF EFFECTS FOR LISTED SPECIES............. G-118

G-12.1 Ute Ladies’-tresses ............................................................... G-118
Appendix G 

TABLE OF CONTENTS (Continued) 

G-iv Final EIS, Wright Area Coal Lease Applications

G-12.1.1 North Hilight Field ...................................................... G-118

G-12.1.2 South Hilight Field...................................................... G-119

G-12.1.3 West Hilight Field........................................................ G-120

G-12.1.4 West Jacobs Ranch..................................................... G-120

G-12.1.5 North Porcupine.......................................................... G-121

G-12.1.6 South Porcupine ......................................................... G-121

G-12.2 Black-footed Ferret............................................................... G-122

G-12.2.1 North Hilight Field ...................................................... G-122

G-12.2.2 South Hilight Field...................................................... G-122

G-12.2.3 West Hilight Field........................................................ G-122

G-12.2.4 West Jacobs Ranch..................................................... G-123

G-12.2.5 North Porcupine.......................................................... G-123

G-12.2.6 South Porcupine ......................................................... G-123

G-12.3 Blowout Penstemon.............................................................. G-123

G-12.3.1 North Hilight Field ...................................................... G-123

G-12.3.2 South Hilight Field...................................................... G-123

G-12.3.3 West Hilight Field........................................................ G-124

G-12.3.4 West Jacobs Ranch..................................................... G-124

G-12.3.5 North Porcupine.......................................................... G-124

G-12.3.6 South Porcupine ......................................................... G-124

G-13.0 CREDENTIALS OF SURVEY PERSONNEL ................................. G-125

G-13.1 North, South and West Hilight Field LBA Tracts ................... G-125

G-13.1.1 T&E Animal Species.................................................... G-125

G-13.1.2 T&E Vegetation Species .............................................. G-125

G-13.2 West Jacobs Ranch LBA Tract.............................................. G-126

G-13.2.1 T&E Animal Species.................................................... G-126

G-13.2.2 T&E Vegetation Species .............................................. G-126

G-13.3 North and South Porcupine LBA Tracts ................................ G-127

G-13.3.1 T&E Animal Species.................................................... G-127

G-13.3.2 T&E Vegetation Species .............................................. G-127

G-14.0 REFERENCES AND LITERATURE CITED .................................. G-131

LIST OF FIGURES 

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

Tracts................................................................................... G-2

Figure G-2. North Hilight Field LBA Tract Alternatives............................. G-6

Figure G-3. Surface Ownership Within the North Hilight Field LBA 

Tract Alternatives ................................................................. G-8

Figure G-4. South Hilight Field LBA Tract Alternatives.......................... G-11

Figure G-5. Surface Ownership Within the South Hilight Field LBA 

Tract Alternatives ............................................................... G-12
Appendix G 

TABLE OF CONTENTS (Continued) 

Final EIS, Wright Area Coal Lease Application G-v 

Figure G-6. West Hilight Field LBA Tract Alternatives............................ G-15

Figure G-7. Surface Ownership Within the West Hilight Field LBA 

Tract Alternatives ............................................................... G-16

Figure G-8. West Jacobs Ranch LBA Tract Alternatives......................... G-21

Figure G-9. Surface Ownership Within the West Jacobs Ranch LBA 

Tract Alternatives ............................................................... G-23

Figure G-10. North Porcupine LBA Tract Alternatives.............................. G-26

Figure G-11. Surface Ownership Within the North Porcupine LBA Tract 

Alternatives ........................................................................ G-28

Figure G-12. South Porcupine LBA Tract Alternatives ............................. G-31

Figure G-13. Surface Ownership Within the South Porcupine LBA Tract 

Alternatives ........................................................................ G-33

Figure G-14. Black Thunder, Jacobs Ranch, and North Antelope 

Rochelle Mines’ Existing Federal Coal Leases and Permit 

Boundaries, and the Six WAC LBA Tracts as Applied for..... G-37

Figure G-15. T&E Species Survey Area for the North Hilight Field LBA 

Tract .................................................................................. G-44

Figure G-16. T&E Species Survey Area for the South Hilight Field LBA 

Tract .................................................................................. G-45

Figure G-17. T&E Species Survey Area for the West Hilight Field LBA 

Tract .................................................................................. G-47

Figure G-18. T&E Species Survey Area for the West Jacobs Ranch LBA 

Tract .................................................................................. G-48

Figure G-19. T&E Species Survey Area for the North Porcupine LBA 

Tract .................................................................................. G-50

Figure G-20. T&E Species Survey Area for the South Porcupine LBA 

Tract .................................................................................. G-52

Figure G-21. Wetlands Within the General Analysis Area for the North 

Hilight Field LBA Tract ....................................................... G-68

Figure G-22. Wetlands Within the General Analysis Area for the South 

Hilight Field LBA Tract ....................................................... G-70

Figure G-23. Wetlands Within the General Analysis Area for the West 

Hilight Field LBA Tract ....................................................... G-73

Figure G-24. Wetlands Within the General Analysis Area for the West 

Jacobs Ranch LBA Tract..................................................... G-75

Figure G-25. Wetlands Within the General Analysis Area for the North 

Porcupine LBA Tract........................................................... G-79
Appendix G 

TABLE OF CONTENTS (Continued) 

G-vi Final EIS, Wright Area Coal Lease Applications

Figure G-26. Wetlands Within the General Analysis Area for the South 

Porcupine LBA Tract........................................................... G-83

Figure G-27. Windblown Sand Deposits Within and Near the General 

Analysis Area for the North Hilight Field, South Hilight 

Field, West Hilight Field, and West Jacobs Ranch LBA 

Tracts................................................................................. G-93

Figure G-28. Windblown Sand Deposits Within and Near the General 

Analysis Area for the North Porcupine and South 

Porcupine LBA Tracts......................................................... G-96
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-1 

G-1.0 INTRODUCTION 

This Biological Assessment (BA) discusses the potential effects of leasing six 

tracts of federal coal reserves located adjacent to operating surface coal mines 

in the southern Powder River Basin (PRB) of Wyoming on threatened, 

endangered, and proposed species pursuant to Section 7 of the Endangered 

Species Act (ESA) of 1973 (PL 93-205, as amended). The environmental 

impacts of leasing all six lease by application (LBA) tracts are being evaluated 

in this environmental impact statement (EIS), the Wright Area Coal (WAC) 

Lease Applications EIS. For federal actions that are major construction 

activities, the ESA requires that a BA be prepared to evaluate the potential 

effects of the action on federally listed threatened and endangered (T&E) and 

proposed species and designated and proposed critical habitat that may be 

present in the action area, consistent with regulations at 50 CFR 402.12. This 

BA was prepared under the direction of the Bureau of Land Management (BLM) 

and the U.S. Department of Agriculture-Forest Service (USFS) (a cooperating 

agency on this EIS). USFS has established direction to guide habitat 

management for T&E species in Forest Service Manual 2670. 

The objectives of this BA are: 

1. To comply with the provisions of the ESA, which requires federal 

agencies to use their authorities to carry out programs to conserve T&E 

species, and to ensure that actions authorized, funded, or carried out by 

them are not likely to jeopardize the continued existence of listed or 

proposed species, nor result in the destruction or adverse modification of 

their critical habitats. 

2. To provide a process and standard by which to ensure that T&E species 

receive full consideration in the decision making process. 

G-1.1 Background 

Between October 2005 and September 2006, operators of three existing coal 

mines in Campbell County, Wyoming filed applications with the BLM for federal 

coal reserves in six separate tracts as maintenance leases under the Leasing on 

Application regulations at 43 CFD 3425. The six LBA tracts, which are shown 

on Figure G-1, and the respective applicant mines are: 

• North Hilight Field LBA Tract adjacent to the Black Thunder Mine; 

• South Hilight Field LBA Tract adjacent to the Black Thunder Mine; 

• West Hilight Field LBA Tract west of the Black Thunder Mine; 

• West Jacobs Ranch LBA Tract west of the Jacobs Ranch Mine; 

• North Porcupine LBA Tract adjacent to the North Antelope Rochelle Mine; 

and 

• South Porcupine LBA Tract adjacent to the North Antelope Rochelle 

Mine. 
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 G-1. General Location Map with Federal Coal Leases and LBA Tracts.

Appendix G

G-2 Final EIS, Wright Area Coal Lease Applications
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-3 

If a decision is made to hold separate competitive lease sales for the North 

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

Porcupine, or South Porcupine LBA Tracts, and if there is a successful bidder 

at a sale, a lease would be issued for the tract of federal coal that is offered for 

sale. The tracts offered for lease would be subject to standard and special 

lease stipulations developed for the Wyoming PRB. The stipulations that would 

be attached to a lease for each of the six WAC LBA tracts are listed in Appendix 

D of this EIS. The following stipulation relating to T&E species is one of the 

special stipulations developed for the Wyoming PRB: 

THREATENED, ENDANGERED, CANDIDATE, or OTHER SPECIAL STATUS 

PLANT and ANIMAL SPECIES – The lease area may now or hereafter 

contain plants, animals, or their habitats determined to be threatened or 

endangered under the Endangered Species Act of 1973, as amended, 16 

U.S.C. 1531 et seq., or that have other special status. The Authorized Officer 

may recommend modifications to exploration and development proposals to 

further conservation and management objectives or to avoid activity that will 

contribute to a need to list such species or their habitat or to comply with any 

biological opinion issued by the Fish and Wildlife Service for the Proposed 

Action. The Authorized Officer will not approve any ground-disturbing activity 

that may affect any such species or critical habitat until it completes its 

obligations under applicable requirements of the Endangered Species Act. 

The Authorized Officer may require modifications to, or disapprove a proposed 

activity that is likely to result in jeopardy to the continued existence of a 

proposed or listed threatened or endangered species, or result in the 

destruction or adverse modification of designated or proposed critical habitat. 

The lessee shall comply with instructions from the Authorized Officer of the 

surface managing agency (BLM, if the surface is private) for ground disturbing 

activities associated with coal exploration on federal coal leases prior to 

approval of a mining and reclamation permit or outside an approved mining 

and reclamation permit area. The lessee shall comply with instructions from 

the Authorized Officer of the Office of Surface Mining Reclamation and 

Enforcement, or his designated representative, for all ground disturbing 

activities taking place within an approved mining and reclamation permit area 

or associated with such a permit. 

The coal mining unsuitability criteria listed in the federal coal management 

regulations at 43 CFR 3461.5 were applied to high to moderate coal 

development potential lands in the Wyoming PRB. As indicated in Sections 1.1 

and 1.5 of this EIS, some of the coal in the six tracts is overlain by rights-ofway (ROWs) for a state highway or county roads, or portions of the Burlington 

Northern Santa Fe and Union Pacific (BNSF & UP) Railroad ROW and has been 

determined to be unsuitable for mining under Unsuitability Criterion 2 and/or 

Unsuitability Criterion 3 (43 CFR 3461.5). 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)). There is an exception to this prohibition in 
Appendix G 

G-4 Final EIS, Wright Area Coal Lease Applications

the regulations at SMCRA Section 522(e)(4) and 30 CFR 761.11(d)(2), which 

can be applied if the appropriate road authority (Wyoming Department of 

Transportation for state highways and Campbell County Board of 

Commissioners for county roads) allows a public 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. Although the 

federal coal underlying the railroad and road ROWs and associated buffer 

zones may not be mined, it is included in a tract because it would allow 

maximum recovery of the mineable coal adjacent to but outside of the railroad 

and road ROWs and associated buffer zones and comply with the coal leasing 

regulations that do not allow leasing of less than 10-acre aliquot parts. 

BLM does not authorize mining by issuing a lease for federal coal, but the 

impacts of mining the coal are considered at the leasing stage because they are 

a logical consequence of issuing a lease. 

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. The boundaries of each tract would be consistent 

with the tract configuration proposed by each applicant. The Proposed Action 

assumes that each LBA tract would be developed as maintenance lease to 

extend the life of the adjacent existing applicant mine and that the applicant 

would be the successful bidder on the tract. As a result, under the Proposed 

Action, the coal included in the tract would be mined by existing employees 

using existing facilities and roads. 

The BLM Competitive Coal Leasing Manual (BLM Manual 3420-1) requires BLM 

to evaluate modifying the configuration of 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. BLM therefore 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. 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. 

It is assumed that an area larger than an LBA tract would have to be disturbed 

in order to recover all of the coal in the tract. The disturbances outside of a 

tract would be due to activities like overstripping, matching undisturbed 

topography, and construction of flood control and sediment control structures. 

The BLM study area for each of these six LBA tracts is defined as the original 

tract as applied for, plus all lands that BLM is considering adding to the tract. 

The general analysis area for each of these six LBA tracts 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. The general analysis area for the North Hilight Field 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-5 

LBA Tract includes some lands within both Black Thunder and Jacobs Ranch 

Mines’ existing mine permit boundaries. The general analysis area for the 

South Hilight Field LBA Tract includes some lands within Black Thunder 

Mine’s current mine permit area. The general analysis area for the West 

Hilight Field LBA Tract does not include lands within a current mine permit 

area. The general analysis area for the West Jacobs Ranch LBA Tract includes 

some lands within the Black Thunder Mine’s current mine permit area. The 

general analysis areas for both the North and South Porcupine LBA Tracts are 

almost entirely within North Antelope Rochelle Mine’s current mine permit 

area. The general Wright analysis area is defined as the area encompassing all 

six of these LBA tract general analysis areas. 

G-1.2 Description of the North Hilight Field Tract Proposed Action and 

Alternatives 

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 (Figure G-1). The tracts, which are referred to as the North 

Hilight Field and South Hilight Field LBA Tracts, were assigned case file 

numbers WYW164812 and WYW174596, respectively. 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. ALC is referred to as the applicant 

and TBCC is referred to as the mine operator. 

G-1.2.1 Proposed Action 

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 of this EIS). The boundaries of the tract would be consistent with 

the tract configuration proposed in the North Hilight Field lease application 

(Figure G-2). The Proposed Action assumes that ALC would be the successful 

bidder on the North Hilight Field LBA Tract if it is offered for sale, and the tract 

would be mined as a maintenance lease for an existing mine. 

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
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.

R. 71 W. R. 70 W.

T.

44

N.

T.

43

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 G-2. North Hilight Field LBA Tract Alternatives.

Appendix G

G-6 Final EIS, Wright Area Coal Lease Applications
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-7 

Section 24: Lots 1 through 16; 653.44 acres 

Section 26: Lots 1 through 16; 650.07 acres 

Total: 2,613.50 acres

The coal estate included in the tract described above is federally owned and 

administered by the BLM. The ownership of the surface and oil and gas estates 

is discussed in Section 3.11 of this EIS. Surface ownership is shown in Figure 

G-3. 

G-1.2.2 Alternatives to the Proposed Action 

G-1.2.2.1 Alternative 1 

Under 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 or employment on the existing leases at the Black 

Thunder Mine. Portions of the surface of the LBA tract would probably be 

disturbed by both the Black Thunder and Jacobs Ranch mines due to 

overstripping to allow coal to be removed from existing contiguous leases. 

G-1.2.2.2 Alternative 2 (BLM’s 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 Powder River Basin (PRB) and for this tract if it is offered for sale (Appendix 

D of this EIS). 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 to extend the life of the adjacent 

existing Black Thunder Mine. Other assumptions are the same as for the 

Proposed Action. 

In evaluating the North Hilight Field coal lease application, BLM identified a 

study area that includes unleased federal coal adjacent to the northern and 

eastern edges of the tract as applied for (Figure G-2). BLM is evaluating the 

potential that some or all of these lands could be added to the area to be 

offered for lease to 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 potentially mineable federal coal in this area 

would be bypassed if it is not included in the North Hilight Field LBA Tract. 
StateHilight Road

Keeline Road

Highway 450 BNSF & UP RR

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.

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 G-3. Surface Ownership Within the North Hilight Field LBA Tract Alternatives.

Appendix G

G-8 Final EIS, Wright Area Coal Lease Applications
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-9 

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 BLM’s preferred configuration of the North Hilight Field 

LBA Tract under Alternative 2 (Figure G-2) 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

The BLM study area includes lands (approximately 80.8 acres) on the Thunder 

Basin National Grassland (TBNG), which is administered by the USFS. 

G-1.3 Description of the South Hilight Field Tract Proposed Action and 

Alternatives 

On October 7, 2005, 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 (Figure G1). The tracts, which are referred to as the North Hilight Field and South 

Hilight Field LBA Tracts, were assigned case file numbers WYW164812 and 

WYW174596, respectively. The federal coal reserves were applied for as 
Appendix G 

G-10 Final EIS, Wright Area Coal Lease Applications

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. 

G-1.3.1 Proposed Action 

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 of this EIS). The boundaries of the tract would be consistent with 

the tract configuration proposed in the South Hilight Field lease application 

(Figure G-4). The Proposed Action assumes that ALC would be the successful 

bidder on the South Hilight Field LBA Tract if it is offered for sale, and the tract 

would be mined as a maintenance lease for an existing mine. 

The legal description of the proposed South 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 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

The coal estate included in the tract described above is federally owned and 

administered by the BLM. Much of the surface (approximately 83 percent) 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 of this EIS. Surface ownership is shown in Figure G-5. 

G-1.3.2 Alternatives to the Proposed Action 

G-1.3.2.1 Alternative 1 

Under 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 or employment on the existing leases at the Black 

Thunder Mine. 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. 

G-1.3.2.2 Alternative 2 (BLM’s 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 
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.

R. 71 W. R. 70 W.

T.

43

N.

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 G-4. South Hilight Field LBA Tract Alternatives.

Appendix G

Final EIS, Wright Area Coal Lease Applications G-11
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

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.

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 G-5. Surface Ownership Within the South Hilight Field LBA Tract Alternatives.

Appendix G

G-12 Final EIS, Wright Area Coal Lease Applications
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-13 

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 of this EIS). 

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 to extend the life of the adjacent 

existing Black Thunder Mine. Other assumptions are the same as for the 

Proposed Action. 

In evaluating the South Hilight Field coal lease application, BLM identified a 

study area that includes unleased federal coal adjacent to the southern edge of 

the tract as applied for (Figure G-4). BLM is evaluating the potential that some 

or all of these lands could be added to the area to be offered for lease to provide 

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

the South Hilight Field LBA Tract, and/or reduce the potential that some 

potentially mineable federal coal in this area would be bypassed if it is not 

included in the South Hilight Field LBA Tract. 

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 BLM’s preferred configuration of the South Hilight Field 

LBA Tract under Alternative 2 (Figure G-4) 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

Much of the surface (approximately 89 percent) of the BLM study area includes 

lands on the TBNG, which is administered by the USFS. 
Appendix G 

G-14 Final EIS, Wright Area Coal Lease Applications

G-1.4 Description of the West Hilight Field Tract Proposed Action and 

Alternatives 

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

reserves in a tract located west of the Black Thunder Mine in Campbell County, 

Wyoming (Figure G-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. 

G-1.4.1 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 of this EIS). The boundaries of the tract would be consistent with 

the tract configuration proposed in the West Hilight Field lease application 

(Figure G-6). The Proposed Action assumes that ALC would be the successful 

bidder on the West Hilight Field LBA Tract if it is offered for sale, and the tract 

would be mined as a maintenance lease for an existing mine. 

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

The coal estate included in the tract described above is federally owned and 

administered by the BLM. A portion of the surface of the tract as applied for 

(approximately 30 percent) 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 of this EIS. Surface ownership is shown in Figure G7. 

G-1.4.2 Alternatives to the Proposed Action 

G-1.4.2.1 Alternative 1 

Under 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 
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.

R. 71 W.

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 G-6. West Hilight Field LBA Tract Alternatives.

Appendix G

Final EIS, Wright Area Coal Lease Applications G-15
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 G-7. Surface Ownership Within the West Hilight Field LBA Tract Alternatives.

Appendix G

G-16 Final EIS, Wright Area Coal Lease Applications
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-17 

permitted mining activities or employment on the existing leases at the Black 

Thunder Mine. 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. 

G-1.4.2.2 Alternative 2 (BLM’s 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 of this EIS). 

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 to extend the life of the existing 

Black Thunder Mine. Other assumptions are the same as for the Proposed 

Action. 

In evaluating the West Hilight Field coal lease application, BLM identified a 

study area that includes unleased federal coal adjacent to the eastern, 

southern, northeastern, and northwestern edges of the tract as applied for 

(Figure G-6). BLM is evaluating the potential that some or all of these lands 

could be added to the area to be offered for lease to 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 potentially mineable 

federal coal in this area would be bypassed if it is not included in the West 

Hilight Field LBA Tract. 

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 

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
Appendix G 

G-18 Final EIS, Wright Area Coal Lease Applications

The legal description of BLM’s preferred configuration of the West Hilight Field 

LBA Tract under Alternative 2 (Figure G-6) 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

Approximately 40 percent of the West Hilight Field LBA Tract under Alternative 

2 includes lands on the TBNG, which is administered by the USFS. 

G-1.4.2.3 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 and 

some or all of TBCC’s Northwest Rail Loop Amendment Area (Figure G-6). 

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 of this EIS). 

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. Other assumptions are the same as for the Proposed Action. 

In evaluating the West Hilight Field coal lease application, BLM identified a 

study area that includes unleased federal coal adjacent to the eastern, 

southern, northeastern, and northwestern edges of the tract as applied for 

(Figure G-6). BLM is evaluating the potential that some or all of these lands 

could be added to the area to be offered for lease to 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 potentially mineable 

federal coal in this area would be bypassed if it is not included in the West 

Hilight Field LBA Tract. 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-19 

Under Alternative 3, BLM is considering adding some or all of Black Thunder 

Mine’s Northwest Rail Loop Amendment Area, which is entirely within Black 

Thunder Mine’s current permit area. Black Thunder Mine completed the 

construction of a new train loadout facility within their Northwest Rail Loop 

Amendment Area in 2008. 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 alternate tract configuration 

will preserve the option of delineating some or all of TBCC’s Northwest Rail 

Loop Amendment Area into the West Hilight Field, and West Jacobs Ranch, or 

both LBA tracts. 

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 

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
Appendix G 

G-20 Final EIS, Wright Area Coal Lease Applications

Approximately 35 percent of the West Hilight Field LBA Tract under Alternative 

3 includes lands on the TBNG, which is administered by the USFS. 

G-1.5 Description of the West Jacobs Ranch Tract Proposed Action and 

Alternatives 

On March 22, 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 G-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. 

Ark Land Company (ALC), a wholly owned subsidiary of Arch Coal, Inc., 

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 

BA, the applicant for the West Jacobs Ranch LBA Tract will be referred to as 

ALC. 

G-1.5.1 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 of this EIS). The boundaries of the tract would be consistent with 

the tract configuration proposed in the West Jacobs Ranch LBA Tract lease 

application (Figure G-8). The Proposed Action assumes that ALC would be the 

successful bidder on the West Jacobs Ranch LBA Tract if it is offered for sale, 

and the tract would be mined as a maintenance lease for an existing mine. 

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
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 G-8. West Jacobs Ranch LBA Tract Alternatives.

Appendix G

Final EIS, Wright Area Coal Lease Applications G-21
Appendix G 

G-22 Final EIS, Wright Area Coal Lease Applications

Total: 5,944.37 acres

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 of 

this EIS. Surface ownership is shown in Figure G-9. 

G-1.5.2 Alternatives to the Proposed Action 

G-1.5.2.1 Alternative 1 

Under 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, and the coal included in the tract 

would not be mined. Rejection of the application would not affect permitted 

mining activities and employment on the existing leases at Jacobs Ranch Mine. 

No portion of the West Jacobs Ranch LBA Tract will be disturbed under Jacobs 

Ranch Mine’s current mining plans in order to recover the coal in the mine’s 

existing coal leases. However, a portion of the LBA tract’s surface was recently 

disturbed during the construction of a new train loadout facility for the Black 

Thunder Mine within TBCC’s Northwest Rail Loop Amendment Area, which is 

located along the eastern side of the tract. Construction of the new coal 

loadout facilities was completed in 2008 (Figure G-8). 

G-1.5.2.2 Alternative 2 (BLM’s Preferred Alternative) 

Under Alternative 2 for the West Jacobs Ranch LBA Tract, BLM would 

reconfigure the tract, hold a 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 of this EIS). 

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 to extend the life of the existing 

Jacobs Ranch Mine. Other assumptions are the same as for the Proposed 

Action. 

In evaluating the West Jacobs Ranch coal lease application, BLM identified a 

study area that includes unleased federal coal adjacent to the northern and 

western edges of the tract as applied for (Figure G-8). BLM is evaluating the 

potential that some or all of these lands could be added to area to be offered for 

lease to 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 potentially mineable federal coal in this area would 

be bypassed if it is not included in the West Jacobs Ranch LBA Tract. 
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 G-9. Surface Ownership Within the West Jacobs Ranch LBA Tract Alternatives.

Appendix G

Final EIS, Wright Area Coal Lease Applications G-23
Appendix G 

G-24 Final EIS, Wright Area Coal Lease Applications

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 BLM’s preferred configuration of the West Jacobs 

Ranch LBA Tract under Alternative 2 (Figure G-8) 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

G-1.6 Description of the North Porcupine Tract Proposed Action and 

Alternatives 

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

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

Final EIS, Wright Area Coal Lease Applications G-25 

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

Antelope Rochelle Mine in Campbell County, Wyoming (Figure G-1). 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. The South Porcupine 

LBA Tract, which is located approximately 14 miles southeast of Wright, was 

also increased in size with additional lands. BTU’s coal lease application was 

assigned case file numbers WYW173408 (North Porcupine) and WYW176095 

(South Porcupine). 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. 

G-1.6.1 Proposed Action 

Under the Proposed Action for the North 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 of this EIS). The boundaries of the tract would be consistent with 

the tract configuration proposed in the North Porcupine LBA Tract lease 

application (Figure G-10). The Proposed Action assumes that BTU would be 

the successful bidder on the North Porcupine LBA Tract if it is offered for sale, 

and the tract would be mined as a maintenance lease for an existing mine. 

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
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 G-10. North Porcupine LBA Tract Alternatives.

Appendix G

G-26 Final EIS, Wright Area Coal Lease Applications
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-27 

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

The coal estate included in the tract described above is federally owned. Much 

of the surface (approximately 85 percent) 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 of this EIS. 

Surface ownership is shown in Figure G-11. 

G-1.6.2 Alternatives to the Proposed Action 

G-1.6.2.1 Alternative 1 

Under 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 or employment on the existing leases at the North 

Antelope Rochelle Mine. Portions of the surface of the LBA tract will be 

disturbed due to overstripping to allow coal to be removed from existing 

contiguous leases. 

G-1.6.2.2 Alternative 2 (BLM’s 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 of this EIS). 

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 to extend the life of the existing 

North Antelope Rochelle Mine. Other assumptions are the same as for the 

Proposed Action. 

In evaluating the North Porcupine coal lease application, BLM identified a 

study area that includes unleased federal coal adjacent the northern and 

southwestern edges of the tract as applied for (Figure G-10). BLM is evaluating 

the potential that some or all of these lands could be added to the area offered 

for lease to 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 potentially mineable federal coal in this area would 

be bypassed if it is not included in the North Porcupine LBA Tract. 
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 G-11. Surface Ownership Within the North Porcupine LBA Tract Alternatives.

Appendix G

G-28 Final EIS, Wright Area Coal Lease Applications
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-29 

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 BLM’s preferred configuration of the North Porcupine 

LBA Tract under Alternative 2 (Figure G-10) is as follows: 

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

Much of the surface (approximately 83 percent) of the BLM study area includes 

lands on the TBNG, which is administered by the USFS. 
Appendix G 

G-30 Final EIS, Wright Area Coal Lease Applications

G-1.7 Description of the South Porcupine Tract Proposed Action and 

Alternatives 

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 (Figure G-1). 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. The South Porcupine 

LBA Tract, which is located approximately 14 miles southeast of Wright, was 

also increased in size with additional lands. BTU’s coal lease application was 

assigned case file numbers WYW173408 (North Porcupine) and WYW176095 

(South Porcupine). 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. 

G-1.7.1 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 of this EIS). The boundaries of the tract would be consistent with 

the tract configuration proposed in the South Porcupine LBA Tract lease 

application (Figure G-12). The Proposed Action assumes that BTU would be 

the successful bidder on the South Porcupine LBA Tract if it is offered for sale, 

and the tract would be mined as a maintenance lease for an existing mine. 

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 

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
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 G-12. South Porcupine LBA Tract Alternatives.

Appendix G

Final EIS, Wright Area Coal Lease Applications G-31
Appendix G 

G-32 Final EIS, Wright Area Coal Lease Applications

The coal estate included in the tract described above is federally owned. Much 

of the surface (approximately 78 percent) 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 of this EIS. 

Surface ownership is shown in Figure G-13. 

G-1.7.2 Alternatives to the Proposed Action 

G-1.7.2.1 Alternative 1 

Under 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 or employment on the existing leases at the North 

Antelope Rochelle Mine. Portions of the surface of the LBA tract will probably 

be disturbed due to overstripping to allow coal to be removed from existing 

contiguous leases. 

G-1.7.2.2 Alternative 2 (BLM’s 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 of this EIS). 

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 to extend the life of the existing 

North Antelope Rochelle Mine. Other assumptions are the same as for the 

Proposed Action. 

In evaluating the South Porcupine coal lease application, BLM identified a 

study area that includes unleased federal coal adjacent the western edge of the 

tract as applied for (Figure G-12). BLM is evaluating the potential that some or 

all of these lands could be added to the area offered for lease to 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 

potentially mineable federal coal in this area would be bypassed if it is not 

included in the South Porcupine LBA Tract. 

Under Alternative 2, the area BLM is evaluating adding to the tract as applied 

for includes the following lands: 
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 G-13. Surface Ownership Within the South Porcupine LBA Tract Alternatives.

Appendix G

Final EIS, Wright Area Coal Lease Applications G-33
Appendix G 

G-34 Final EIS, Wright Area Coal Lease Applications

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 

Section 14: Lot 2 and E1⁄2 of Lot 7; 57.07 acres 

Total: 382.07 acres

The legal description of BLM’s preferred configuration of the South Porcupine 

LBA Tract under Alternative 2 (Figure G-12) 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

Much of the surface (approximately 70 percent) of the BLM study area includes 

lands on the TBNG, which is administered by the USFS. 

G-2.0 REGULATORY FRAMEWORK 

The issuance of a federal coal lease grants the lessee the exclusive rights to 

mine the coal, subject to the terms and conditions of the lease. Lease 

ownership is necessary for mining federal coal, but lease ownership does not 

authorize mining operations. Surface coal mining operations are regulated in 

accordance with the requirements of the Surface Mining Control and 

Reclamation Act of 1977 (SMCRA) and Wyoming state regulations. SMCRA 

gives the Office of Surface Mining Reclamation and Enforcement (OSM) primary 

responsibility to administer programs that regulate surface coal mining 

operations and the surface effects of underground coal mining operations. 

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 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-35 

mining on federal lands within the state. In order to get approval of this 

cooperative agreement, the state had to demonstrate that the state laws and 

regulations are no less stringent than, meet the minimum requirements of, and 

include all applicable provisions of SMCRA. 

If the North Hilight Field, South Hilight Field, West Hilight Field, West Jacobs 

Ranch, North Porcupine, or South Porcupine LBA Tracts are leased, they would 

each be a maintenance lease for the existing applicant mines, which currently 

have both approved Mineral Leasing Act of 1920 (MLA) mining plans and 

approved state mining and reclamation permits. In the case of maintenance 

leases for existing mines, such as the six WAC LBA tracts, the existing MLA 

mining plans and state mining and reclamation plans must be amended to 

include any newly leased area before that area can be mined. 

In order to amend the existing MLA mining plans and state mining and 

reclamation permits, the mining companies would be required to submit 

detailed permit application packages to WDEQ before starting surface coal 

mining operations on any newly acquired lease(s). WDEQ/Land Quality 

Division (LQD) would review the respective 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. If the permit application package does comply, WDEQ 

would issue the applicant an amended permit that would allow the permittee to 

extend coal mining operations onto the newly acquired lease(s). 

Protection of fish, wildlife, and related environmental values is required under 

SMCRA regulations at 30 CFR 816.97, which state: 

“No surface mining activity shall be conducted which is likely to jeopardize 

the continued existence of endangered or threatened species listed by the 

Secretary of which is likely to result in the destruction or adverse 

modification of designated critical habitats of such species in violation of the 

Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.).” 

In addition to requiring the operator to minimize disturbances and adverse 

impacts on fish, wildlife, and related environmental values, the regulations at 

30 CFR 816.97 disallow any surface mining activity which is likely to 

jeopardize the continued existence of endangered or threatened species and 

require that the operator use the best technology currently available to: 1) 

minimize electrocution hazards to raptors; 2) locate and operate haul and 

access roads to avoid or minimize impacts on important fish and wildlife 

species; and 3) design fences, conveyors, and other potential barriers to permit 

passage of large mammals. 

U.S. Fish and Wildlife Service (USFWS) Section 7 consultation would be 

required prior to approval of the mining and reclamation plan modification. 

Additional measures to ensure compliance with the ESA and SMCRA can be 

developed when the detailed mining plan, which identifies the actual location of 
Appendix G 

G-36 Final EIS, Wright Area Coal Lease Applications

the disturbance areas, how and when they would be disturbed, and how they 

would be reclaimed, is developed and reviewed for approval. At the leasing 

stage, a detailed mining and reclamation plan is not available for evaluation or 

development of appropriate mitigation measures specific to an actual proposal 

to mine. 

The following is a partial list of measures related to federally-protected species 

that are required as part of the mining and reclamation permits: 

• avoiding bald eagle disturbance per the Bald and Golden Eagle Protection 

Act of 1940 and the Migratory Bird Treaty Act; 

• restoring bald eagle foraging areas disturbed by mining; 

• using raptor safe power lines; and 

• surveying for Ute ladies’-tresses if habitat is present. 

G-3.0 CONSULTATIONS WITH U.S. FISH AND WILDLIFE SERVICE TO 

DATE 

The locations of the existing Black Thunder, Jacobs Ranch, and North Antelope 

Rochelle mines’ coal leases, the existing approved mine permit areas, and the 

six WAC LBA tracts are shown in Figure G-14. These three applicant mines 

and six proposed LBA tracts are included in the area determined to be 

“acceptable for further consideration for leasing” as part of the coal screening 

process. The coal screening process is a four-part process that includes 

application of the coal unsuitability criteria, which are defined in 43 CFR 

3461.5 and listed in Appendix B of this EIS. BLM and USFS have applied 

these coal screens to federal coal lands in Campbell County several times, 

starting in the early 1980s. The six WAC LBA tracts are located in the area 

covered by the USFS screening analysis published as Appendix F of the 1985 

Thunder Basin National Grassland Land and Resource Management Plan. Most 

recently, in 1993, BLM, USFS and the USFWS began the process of reapplying 

these screens to federal coal lands in Campbell, Converse, and Sheridan 

counties. The results of this analysis were included as Appendix D of the 2001 

Approved Resource Management Plan for Public Lands Administered by the BLM 

Buffalo Field Office (BLM 2001a), which can be viewed on the Wyoming BLM 

website at http://www.wy.blm.gov in the NEPA documents section. This 

analysis is referenced in the Final Environmental Impact Statement (FEIS) for the 

Northern Great Plains Management Plans Revision (USFS 2001a) and adopted in 

the Land and Resource Management Plan (LRMP) for the Thunder Basin National 

Grassland (USFS 2001b). The Record of Decision for the Thunder Basin 

National Grassland Final Environmental Impact Statement and Land and 

Resource Management Plan Revision was signed on July 31, 2002 (USFS 

2002a). The six WAC LBA tracts fall within Management Area 8.4, as identified 

in the Thunder Basin National Grassland LRMP, which is to be managed for 

mineral production and development. Consultation with USFWS was 

conducted as part of the Thunder Basin National Grassland LRMP. 

Consultation with USFWS occurred in conjunction with the unsuitability 

findings under Criterion 9 (Critical Habitat for Threatened or Endangered Plant 
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

Mackey

Edwards

Matheson Road

Reno Road

Hilight Road Hilight Road

Keeline

Road

State

450 Highway

Road

Antelope

Road

Road

BNSF & UP RR

Antelope Road

30

19

18

31

30

19

18

32

29

20

17

33

28

21

16

34

27

22

15

35

26

23

14

36

25

24

13

1

0

19

8

32

29

20

17

33

28

21

16

34

27

22

15

35

26

23

14

36

25

24

13

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

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

6 5 4 3 2 6 1 6 5

4

3 2 1

T.

42

N.

T.

41

N.

R70WR69W

R. 70 W. R. 69 W

T.

42

N.

T.

41

N.

31

6

School Creek

Road

32

29

33

28

34

27

35

26

36

25

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

5 4 3 2 1

T.

42

N.

T.

41

N.

T.

42

N.

T.

41

W. N.

SCALE: 1"=14,000'

West Hilight Field LBA

Tract as Applied for

South Hilight Field LBA

Tract as Applied for

West Jacobs Ranch LBA

Tract as Applied for

South Porcupine LBA

Tract as Applied for

North Hilight Field LBA

Tract as Applied for

North Porcupine LBA

Tract as Applied for

Black Thunder Mine

Permit Boundary

Jacobs Ranch Mine

Permit Boundary

North Antelope Rochelle

Mine Permit Boundary

Existing Black Thunder Mine

Federal Coal Leases

Existing Jacobs Ranch

Mine Federal Coal Leases

Existing North Antelope

Rochelle Mine Federal

Coal Leases

LEGEND

Figure G-14. Black Thunder, Jacobs Ranch, and North Antelope Rochelle Mines' Existing Federal Coal

Leases and Permit Boundaries, and the Six WAC LBA Tracts as Applied for.

Appendix G

Final EIS, Wright Area Coal Lease Applications G-37
Appendix G 

G-38 Final EIS, Wright Area Coal Lease Applications

and Animal Species), Criterion 11 (Bald or Golden Eagle Nests), Criterion 12 

(Bald and Golden Eagle Roost and Concentration Areas), Criterion 13 (Falcon 

Nesting Site(s) and Buffer Zone(s)), and Criterion 14 (Habitat for Migratory Bird 

Species). 

Appendix B of this EIS summarizes the unsuitability criteria, describes the 

general findings for the screening analyses discussed above, and presents a 

validation of these findings for the six WAC LBA tracts based on the current 

information. 

When the Record of Decision for the Thunder Basin National Grassland Final 

Environmental Impact Statement and Land and Resource Management Plan 

Revision was signed in 2002, there was no identified habitat for Ute ladies’-

tresses and blowout penstemon was not yet listed for the TBNG. 

Consultation with USFWS has previously been completed for the areas 

included within the Black Thunder, Jacobs Ranch and North Antelope Rochelle 

mines’ existing approved mine permit areas, as part of the mine and 

reclamation plan approval processes. The most recent Migratory Bird Species 

of Management Concern and Raptor Monitoring and Mitigation Plan for the 

Black Thunder Mine was approved by the USFWS in 2007. The most recent 

Migratory Bird Species of Management Concern and Raptor Monitoring and 

Mitigation Plan for the Jacobs Ranch Mine was approved by the USFWS on 

July 25, 2002, which covered 2002 through 2009. Jacobs Ranch Mine 

resubmitted its plan to the USFWS on January 18, 2010, as part of the 

WDEQ/LQD mine permit renewal process, but it had not yet been approved at 

the time of this writing. North Antelope Rochelle Mine’s most recent Migratory 

Bird Species of Management Concern and Raptor Monitoring and Mitigation 

Plan, which was included as part of mine’s most recent mine permit 

amendment, was approved by USFWS January 4, 2006. USFWS approved 

subsequent revisions and amendments to North Antelope Rochelle Mine’s plan, 

the most recent of which is dated December 5, 2007. 

Under 50 CFR 402.12, USFWS will use the BA in determining if there are listed 

or proposed species or critical habitat present that are likely to be adversely 

affected by the action. If the BA indicates that there are no listed or proposed 

species or critical habitat present that are likely to be adversely affected by the 

action, then formal consultation is not required. 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 2009). Each mine with an application being considered in this EIS has 

previously been issued a maintenance coal lease since decertification (as listed 

in Table 1-1 of Chapter 1). None of those previous actions, which required the 

preparation of a BA for each separate LBA tract, prompted USFWS to enter into 

formal consultation with BLM. 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-39 

An informal, 2-day conference between botanists and biologists from the USFS, 

USFWS, and BLM was hosted by ALC at the Black Thunder Mine in August 

2009 to discuss the biology and habitat requirements of the blowout 

penstemon. The interagency meeting was followed by a field tour, led by ALC, 

of the area within and around the Hilight Field tracts in an effort to located 

potentially suitable habitat for the endangered plant. No individuals or 

suitable habitat were found at that time. The group agreed that a field guide 

for the blowout penstemon would be prepared by a botanist with the USFSDouglas Ranger District, and it would be made available for vegetation 

specialists who are tasked with conducting surveys for the plant. 

G-4.0 CURRENT STATUS OF SPECIES 

USFWS maintains a list of T&E and candidate species and designated critical 

habitat on their official website; the website includes those species found in 

Wyoming. USFWS updates the species list annually or sooner if any listing 

changes occur. The species list on the USFWS website fulfills the obligation of 

the USFWS, under Section 7(c) of the ESA, to provide a list of T&E species 

upon request for federal actions and the National Environmental Policy Act of 

1969 (NEPA) compliance. 

USFWS provided BLM a listing of the T&E species that may be present in the 

Buffalo Field Office area (northeastern Wyoming) in a memorandum letter 

dated August 8, 2007 (USFWS 2007), which included only the black-footed 

ferret (Mustela nigripes) and Ute ladies’-tresses (Spiranthes diluvialis). The 

memorandum stated that the USFWS focuses on three broad categories of 

trust resources: 1) T&E and candidate species, 2) migratory birds, and 3) 

wetlands and riparian areas. The memorandum stated that the Service would 

work with the BLM to ensure that species-specific protective measures and 

programs for the conservation and recovery of listed species as required by 

under the ESA are satisfied and carried out. Protective measures for migratory 

birds are provided pursuant to the Migratory Bird Treaty Act and the Bald and 

Golden Eagle Protection Act, and the protection of wetlands is pursuant to 

Section 404 of the Clean Water Act, Executive Order 11990, and Executive 

Order 11988. The memorandum also provided recommendations for biological 

assessments in compliance with NEPA, the protection of migratory birds, 

wetlands, and for other fish and wildlife resources (under the Fish and Wildlife 

Coordination Act and the Fish and Wildlife Act of 1956). No proposed or 

candidate species were included. The bald eagle (Haliaetus leucocephalus) was 

removed from listing as a threatened species in August 2007. Discussion on 

the bald eagle is included in Appendix H of this EIS as a sensitive species. 

As described in Section G-1.1, applications for the six WAC LBA tracts were 

filed with the BLM between October 2005 and September 2006. The three 

applicant mines initiated baseline investigations expressly for the six WAC LBA 

tracts beginning in 2006 and 2007 based on the USFWS’s listings at that time 

for the T&E species that could potentially occur in the general Wright analysis 

area (black-footed ferret and Ute ladies’-tresses). In 2008 the USFWS began to 
Appendix G 

G-40 Final EIS, Wright Area Coal Lease Applications

post listings of T&E and candidate species for all counties in Wyoming on their 

website (http://www.fws.gov/mountain-prairie/endspp/CountyLists/Wyoming 

.pdf). The February 2008 USFWS listing for Campbell County included the 

black-footed ferret, Ute ladies’-tresses, and an additional species, the blowout 

penstemon (Penstemon haydenii) (USFWS 2008). The USFWS supplies a 

specific list of T&E and candidate species to the USFS Thunder Basin National 

Grassland (TBNG) each year for use in project planning. The TBNG list 

provided to USFS in 2008 (Kelly 2008) concurred with the February 2008 

listing for Campbell County. The BA included in the WAC Lease Applications 

Draft EIS, which was made available for public inspection in June 2009, as 

prepared according to these 2008 USFWS listings of three federally listed 

species that could potentially occur in the general Wright analysis area: 

• Ute ladies’-tresses orchid (Spiranthes diluvialis): Threatened 

• Black-footed ferret (Mustela nigripes): Endangered 

• Blowout penstemon (Penstemon haydenii): Endangered 

In a memorandum letter to BLM dated May 22, 2009 (USFWS 2009a), USFWS 

provided an updated listing of the T&E species that may be present in the 

Buffalo Field Office area, which included the Ute ladies’-tresses and blowout 

penstemon, but did not include the black-footed ferret. In a similar letter from 

the USFWS to the USFS Douglas Ranger District dated May 22, 2009, which 

listed the T&E species that may occur within the TBNG, only the Ute ladies’-

tresses and blowout penstemon were included (USFWS 2009b). In addition, 

the USFWS’s website listing of T&E species that may be present in Campbell 

County was updated August, 2009 (USFWS 2009c), and it concurs with the 

May 22, 2009 letters from the USFWS to the BLM Buffalo Field Office and the 

USFS Douglas Ranger District listing the T&E species that could potentially 

occur in the general Wright analysis area. Therefore, according to the current 

USFWS information (USFWS 2009a, 2009b, and 2009c), two federally listed 

species could potentially occur in the general Wright analysis area: 

• Ute ladies’-tresses orchid (Spiranthes diluvialis): Threatened 

• Blowout penstemon (Penstemon haydenii): Endangered 

As stated above, the BA included in the WAC Lease Applications Draft EIS 

addressed the Ute ladies’-tresses, blowout penstemon, and black-footed ferret. 

Rather than remove those sections that describe the biology and habitat 

requirements and potential impacts of the Proposed Actions and alternatives 

on the black-footed ferret because the animal is no longer listed by the USFWS 

as potentially occurring in the general Wright analysis area, BLM has elected to 

keep those sections intact and address all three species in the Final EIS (this 

document). 

Since 1999, the USFWS has received eight petitions requesting that the greater 

sage-grouse (Centrocercus urophasianus) be listed under the 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-
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-41 

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 USFWS 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 the need to address higher priority species first. 

Candidate species are plants and animals for which the USFWS 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 other 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 

species’ range. While it is not required that BLM consult or confer with USFWS 

on Candidate species, the BLM may seek technical assistance from the USFWS 

when it is determined to be advantageous to a species’ conservation or BLM 

management options. The greater sage-grouse is currently listed as a BLM 

Sensitive Species and a USFS Region 2 Sensitive Species and Management 

Indicator Species, and as such, is included in the Biological Evaluation for this 

EIS (Appendix H). 

The Wyoming Game and Fish Department (WGFD) provided BLM with scoping 

comments for the six WAC LBA tracts in a letter dated July 5, 2007 (WGFD 

2007). WGFD recommended consideration be given to possible impacts to big 

game species and their habitat, sage-grouse, other sagebrush obligates, and 

nongame species that occur within the general Wright analysis area. 

G-5.0 METHODS 

All available information pertaining to the species included in this analysis 

were reviewed and incorporated by reference. The assessments and 

recommendations contained within this BA are based upon information 

obtained from several sources including published literature, unpublished 

documents, personal communications with state and federal agency wildlife 

specialists, and field surveys. 
Appendix G 

G-42 Final EIS, Wright Area Coal Lease Applications

G-5.1 Published Literature 

Published scientific documents that pertain directly to the species included in 

this analysis were reviewed and incorporated into this BA. Background 

information on the wildlife, vegetation and T&E species in the vicinity of the 

general Wright analysis area was also obtained from other PRB coal leasing EIS 

documents (e.g., the 2003 South Powder River Basin Coal FEIS and the 2008 

West Antelope II Coal Lease Application FEIS). All published literature used in 

the preparation of this BA is appropriately cited. 

G-5.2 Unpublished Documents 

Unpublished documents and records from the Wyoming Game and Fish 

Department (WGFD), BLM, USFWS, and USFS were reviewed, as were survey 

guidelines for the T&E species that are included in this analysis. The Wyoming 

Natural Diversity Database (WYNDD) was queried for reports of these species 

within the general Wright analysis area. WDEQ/LQD mine permit 

applications, which include the baseline surveys and inventories, and annual 

wildlife monitoring reports for the applicant and the neighboring (i.e., Antelope 

Mine) mines, which are all on file with the WDEQ/LQD in Cheyenne and 

Sheridan, Wyoming, were also reviewed. 

G-5.3 Personal Communications 

Professional wildlife biologists, botanists and rangeland management 

specialists contracted to conduct baseline surveys and annual monitoring by 

the applicant mines, as well as the neighboring mines, have been in personal 

contact with their counterparts and other personnel from the WGFD, BLM, 

USFWS, USFS, and the WYNDD since the mines were initially permitted. 

G-5.4 Field Surveys 

Wildlife baseline inventories and annual monitoring surveys have been 

conducted for the Black Thunder Mine since 1983, the Jacobs Ranch Mine 

since 1980, and the North Antelope Rochelle Mine since 1984. These wildlife 

monitoring programs were designed to meet the WDEQ/LQD, WGFD, and 

federal (USFWS) requirements for annual monitoring and reporting of wildlife 

activity on coal mining areas. Detailed procedures and site-specific 

requirements have been carried out as approved by WGFD and USFWS. The 

annual wildlife monitoring program have been consistent and in accordance 

with Appendix B of WDEQ/LQD Coal Rules and Regulations. Areas covered by 

the wildlife surveys have included the mine’s permit area and a large perimeter 

around the permit boundary. Vegetation and soils baseline surveys covering 

the mine permit areas have also been conducted for the three applicant mines 

since they were initially permitted. 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-43 

G-5.4.1 North Hilight Field Tract 

The North Hilight Field LBA Tract has received extensive coverage during 

baseline and annual wildlife monitoring surveys for both the Black Thunder 

and Jacobs Ranch mines for over 25 years. All but the northern quarter of the 

tract as applied for has been included in Black Thunder Mine’s annual surveys 

since 2002. 

The Black Thunder Mine initiated baseline wildlife investigations expressly for 

the North Hilight Field LBA Tract in 2006, with annual monitoring continued in 

subsequent years. All or portions of the tract’s associated general analysis 

area (described in Section G-1.1), plus the additional “wildlife survey area” 

(described as a 2-mile perimeter beyond the LBA tract’s general analysis area) 

was included in these wildlife monitoring areas at the Black Thunder Mine 

and/or the neighboring Jacobs Ranch Mine. Black Thunder Mine initiated 

targeted surveys specifically for the West Hilight Field LBA Tract and its wildlife 

survey area in 2006 and 2007. Additional survey areas focusing on the North 

and South Hilight Field LBA Tracts were added in 2007 and 2008. Figure G-15 

depicts the North Hilight Field LBA Tract, the tract’s general analysis area, and 

the T&E animal species survey area. 

Details concerning the field surveys that were conducted for the T&E plant 

species (Ute ladies’-tresses and blowout penstemon), which covered the LBA 

tract’s general analysis area, are discussed below in Section 7.0. 

G-5.4.2 South Hilight Field Tract 

The South Hilight Field LBA Tract has received extensive coverage during 

baseline and annual wildlife monitoring surveys for the Black Thunder Mine for 

over 25 years. All but approximately 160 acres located in the southwestern 

corner of BLM’s study area for the South Hilight Field tract has been included 

in baseline inventories and annual wildlife surveys conducted for the mine 

since 1983. 

Black Thunder Mine initiated targeted surveys specifically for the West Hilight 

Field LBA Tract and its wildlife survey area in 2006 and 2007. Additional 

surveys focusing on the wildlife survey areas for the North and South Hilight 

Field LBA Tracts were added in 2007 and 2008. Figure G-16 depicts the South 

Hilight Field LBA Tract, the tract’s general analysis area, and the T&E animal 

species survey area. 

Details concerning the field surveys that were conducted for the T&E plant 

species (Ute ladies’-tresses and blowout penstemon), which covered the LBA 

tract’s general analysis area, are discussed below in Section 7.0. 
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.

PRAIRIE DOG COLONIES

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

Prairie Dog Colony

Jacobs Ranch Mine

Permit Boundary

Figure G-15. T&E Species Survey Area for the North Hilight Field LBA Tract.

Appendix G

G-44 Final EIS, Wright Area Coal Lease Applications
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.

PRAIRIE DOG

COLONIES

PRAIRIE DOG

COLONIES

South Hilight Field LBA

Tract as Applied for

0 5000 10000 20000

GRAPHIC SCALE (FEET)

LEGEND

Prairie Dog Colony

South Hilight Field LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

2-Mile Wildlife Study Area Boundary

General Analysis Area Black Thunder Mine

Permit Boundary

Jacobs Ranch Mine

Permit Boundary

Figure G-16. T&E Species Survey Area for the South Hilight Field LBA Tract.

Appendix G

Final EIS, Wright Area Coal Lease Applications G-45
Appendix G 

G-46 Final EIS, Wright Area Coal Lease Applications

G-5.4.3 West Hilight Field Tract 

The West Hilight Field LBA Tract has received extensive coverage during 

baseline and annual wildlife monitoring surveys for the Black Thunder Mine for 

over 25 years. The eastern half of BLM’s study area for the West Hilight Field 

tract has been included in baseline inventories and annual wildlife surveys 

conducted for the Black Thunder Mine since 1983. The balance of the BLM 

study area and the lands included under Alternative 3 were included in 

monitoring efforts beginning in 2002, and targeted surveys specifically for this 

LBA Tract and its wildlife survey area were conducted in 2006 and 2007. 

Figure G-17 depicts the West Hilight Field LBA Tract, the tract’s general 

analysis area, and the T&E animal species survey area. 

Details concerning the field surveys that were conducted for the T&E plant 

species (Ute ladies’-tresses and blowout penstemon), which covered the LBA 

tract’s general analysis area, are discussed below in Section 7.0. 

G-5.4.4 West Jacobs Ranch Tract 

The West Jacobs Ranch LBA Tract has been surveyed for several years because 

it is part of the survey area for the Jacobs Ranch and/or Black Thunder mines. 

Field surveys were conducted expressly for the West Jacobs Ranch LBA Tract 

and its wildlife survey area beginning in February of 2007 and continuing 

through August of 2008. Figure G-18 depicts the West Jacobs Ranch LBA 

Tract, the tract’s general analysis area, and the T&E animal species survey 

area. 

Details concerning the field surveys that were conducted for the T&E plant 

species (Ute ladies’-tresses and blowout penstemon), which covered the LBA 

tract’s general analysis area, are discussed below in Section 7.0. 

G-5.4.5 North Porcupine Tract 

The annual monitoring areas for the North Antelope Rochelle, Antelope, and 

Black Thunder mines encompass large survey perimeters around each permit 

boundary; therefore, the North Porcupine LBA Tract and surrounding lands 

have been included in annual wildlife monitoring for many years. The North 

Porcupine tract lies within the North Antelope Rochelle Mine’s existing mine 

permit area. Surveys with respect to the North Porcupine tract are 

summarized as follows: 

• Since the early 1980s: 

° approximately 1,480 acres (16 percent) in the eastern portion of the 

North Porcupine tract general analysis area; and 

° the eastern two-thirds of the North Porcupine tract 2-mile wildlife 

survey area. 
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.

Little

Thunder Creek

PRAIRIE DOG

COLONIES

PRAIRIE DOG

COLONIES

LEGEND

0 5000 10000 20000

GRAPHIC SCALE (FEET)

West Hilight Field LBA

Tract as Applied for

Prairie Dog Colony

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

Black Thunder Mine

Permit Boundary

Jacobs Ranch Mine

Permit Boundary

Figure G-17. T&E Species Survey Area for the West Hilight Field LBA Tract.

Appendix G

Final EIS, Wright Area Coal Lease Applications G-47
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.

PRAIRIE DOG

COLONIES

PRAIRIE DOG

COLONIES

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

Prairie Dog Colony

West Jacobs Ranch LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

Black Thunder Mine

Permit Boundary

Jacobs Ranch Mine

Permit Boundary

Figure G-18. T&E Species Survey Area for the West Jacobs Ranch LBA Tract.

Appendix G

G-48 Final EIS, Wright Area Coal Lease Applications
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-49 

• Since 1992: 

° approximately 4,480 acres (about 50 percent) of the North Porcupine 

tract general analysis area and the 2-mile wildlife survey area 

(excluding the northern- and western-most tiers) (since 1992). 

• Since 2000: 

° the entire North Porcupine tract general analysis area; and 

° all but the northern- and western-most 6,770 acres (14 percent) of the 

North Porcupine tract 2-mile wildlife survey area. 

• Since 2002: 

° all lands in the general analysis area and wildlife survey area the 

North Porcupine tract, including targeted baseline wildlife surveys 

conducted for the tract from 2006 through 2008. 

To summarize, the entire general analysis area for the North Porcupine LBA 

Tract has been included in annual wildlife monitoring for at least the last 8 

years (2000 through 2007). Baseline wildlife studies conducted expressly for 

the North Porcupine LBA Tract from 2006 through early 2008 added to those 

existing data. Figure G-19 depicts the North Porcupine LBA Tract, the tract’s 

general analysis area, and the T&E animal species survey area. Long-term 

information is also available for the 2-mile wildlife survey area associated with 

the tract. 

Details concerning the field surveys that were conducted for the T&E plant 

species (Ute ladies’-tresses and blowout penstemon), which covered the LBA 

tract’s general analysis area, are discussed below in Section 7.0. 

G-5.4.6 South Porcupine Tract 

The annual monitoring areas for the North Antelope Rochelle and Antelope 

mines encompass large survey perimeters around each permit boundary; 

therefore, the South Porcupine LBA Tract and surrounding lands have been 

included in annual wildlife monitoring for many years. The South Porcupine 

tract lies within the North Antelope Rochelle Mine’s existing mine permit area. 

Surveys with respect to the South Porcupine tract are summarized as follows: 

• Since the early 1980s: 

° all but the western-most extension and southwestern corner of the 

South Porcupine tract general analysis area; and 

° the eastern two-thirds of the South Porcupine tract 2-mile wildlife 

survey area. 

• Since 1994: 

° all but the western-most 114 acres (3 percent) of the South Porcupine 

tract general analysis area; and; 

° the eastern 70 percent of the South Porcupine tract wildlife survey 

area. 

• Since 2000: 

° the entire South Porcupine tract general analysis area; and 
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

17

20

5

8

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

R. 72 W. R. 71 W.

R. 72 W. R. 71 W.

PRAIRIE DOG

COLONIES

PRAIRIE DOG

COLONIES

PRAIRIE DOG

COLONIES

North Antelope RochelleMine Permit BoundaryNorth Porcupine LBA

Tract as Applied for

LEGEND

Prairie Dog Colony

5000 10000 20000 0

GRAPHIC SCALE (FEET)

General Analysis Area2-Mile Wildlife Study Area Boundary

North Porcupine LBA

Tract Under Alternative 2,

BLM's Preferred Alternative

Figure G-19. T&E Species Survey Area for the North Porcupine LBA Tract.

Appendix G

G-50 Final EIS, Wright Area Coal Lease Applications
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-51 

° all but 2,216 acres (8 percent) at the west-central edge of the South 

Porcupine tract wildlife survey area. 

• Since 2002: 

° all lands in the general analysis area and wildlife survey area the 

South Porcupine tract, including targeted baseline wildlife surveys 

conducted for the tract from 2006 through 2008. 

To summarize, the entire general analysis area for the South Porcupine LBA 

Tract has been included in annual wildlife monitoring for at least the last eight 

years (2000 through 2007), and 97 percent of the tract’s general analysis area 

was monitored annually from 1994 through 2000. Baseline wildlife studies 

conducted expressly for the South Porcupine LBA Tract from 2006 through 

early 2008 added to those existing data. Figure G-20 depicts the South 

Porcupine LBA Tract, the tract’s general analysis area, and the T&E animal 

species survey area. Long-term information is also available for the 2-mile 

wildlife survey area associated with the tract. 

Details concerning the field surveys that were conducted for the T&E plant 

species (Ute ladies’-tresses and blowout penstemon), which covered the LBA 

tract’s general analysis area, are discussed below in Section 7.0. 

G-6.0 CURRENT HABITAT DESCRIPTIONS 

Predominant wildlife habitat types classified in the general Wright analysis area 

generally correspond with the major vegetation communities defined during the 

vegetation baseline survey. In terms of relative acres of occurrence, the 

predominant vegetation types are the Big Sage Shrubland (approximately 42 

percent), Upland/Mixed Prairie Grassland (approximately 28 percent), and 

Crested Wheatgrass/Agricultural Pastureland (approximately 15 percent). 

Minor vegetation types, including saline grassland, rough breaks, disturbed 

lands and bottomlands account for approximately 10 percent of the six 

combined general analysis areas. Disturbed lands include road and utility 

rights-of-way, areas surrounding active construction sites and mining facilities, 

oil and gas facilities, and occupied and abandoned homesteads. Few trees 

occur in the general Wright analysis area due to the lack of water and suitable 

habitats; most trees are found primarily in windbreaks planted adjacent to 

ranching facilities. Reclaimed lands include areas that were recently disturbed 

for road construction, installation of oil and gas development-related facilities, 

and mining-associated activities. 

Numerous in-channel stock reservoirs are scattered throughout the general 

Wright analysis area. Most of these stock ponds are many decades old and are 

constructed with earthen berms or dams. There are also a number of playas 

within the area. Those water bodies provide short-term habitat of variable 

quality for migrating waterfowl, shorebirds, and other aquatic species (birds, 

fish, herptiles) during spring but are less reliable, and often dry, during other 

seasons. 
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

Draw

Mike's

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.

T.

41

N.

T.

40

N.

T.

41

N.

T.

40

N.

PRAIRIE DOG

COLONIES

PRAIRIE DOG

COLONIES

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

Prairie Dog Colony

2-Mile Wildlife Study Area Boundary

General Analysis Area

Figure G-20. T&E Species Survey Area for the South Porcupine LBA Tract.

Appendix G

G-52 Final EIS, Wright Area Coal Lease Applications
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-53 

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 does not contribute runoff to 

any stream, and playas have formed in the lowest portion of these noncontributing 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 

(ground elevated above the lowlands that lie along the banks of drainages) 

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 along the drainages, 

where channel incision has created some gullying. 

G-6.1 North Hilight Field Tract 

The North Hilight Field Tract LBA Tract and adjacent areas consist primarily of 

uplands. The topography of the tract’s general analysis area, like the areas 

within the adjacent mines’ existing permit areas, is relatively subdued. The 

average land surface slope over the entire general analysis area for the North 

Hilight Field tract is approximately 3.4 percent. Surface mine lands, both 

disturbed and reclaimed, dominate the landscape south and east of the North 

Hilight Field tract. 

The North Hilight Field tract’s 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. Black Thunder Mine’s approved WDEQ/LQD mine permit 

allows disturbance of Little Thunder Creek and several of its tributaries, 

including North Prong Little Thunder Creek. Approximately 43 percent (3,031 

acres) of the 7,139-acre BLM study area for the North Hilight Field tract drains 

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. 

A preliminary wetland inventory of the general analysis area for the North 

Hilight Field LBA Tract, based on USFWS National Wetland Inventory (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 coal 

bed natural gas (CBNG)-related water production within and upstream of the 

tract’s 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 natural 

surface water features and CBNG dewatering activities, the boundaries, areas, 
Appendix G 

G-54 Final EIS, Wright Area Coal Lease Applications

and types of wetlands are likewise ephemeral. A formal jurisdictional wetland 

delineation survey for the North Hilight Field LBA Tract would be conducted 

and submitted to the U.S. Army Corps of Engineers (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 other waters of the U.S. (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 mine permitting process. In 

Wyoming, once the delineation has been verified, it is made a part of the mine 

permit document. The reclamation plan is then revised to incorporate the 

replacement of at least equal types and numbers of jurisdictional wetland 

acreages. 

Within the general analysis area for the North Hilight Field LBA Tract, no 

designated critical, crucial, or unique habitats designated by USFWS for T&E 

species are present. 

G-6.2 South Hilight Field Tract 

The South Hilight Field Tract LBA Tract and adjacent areas consist primarily of 

uplands (i.e., ground elevated above the lowlands that lie along the banks of 

drainages). The topography of the tract’s general analysis area, like the areas 

within the adjacent mines’ existing permit areas, is relatively subdued. The 

average land surface slope over the entire general analysis area for the South 

Hilight Field tract is approximately 2.5 percent. Surface mine lands, both 

disturbed and reclaimed, dominate the landscape northeast, east, and 

southeast of the South Hilight Field tract. 

The South Hilight Field tract’s 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. Little Thunder Creek flows easterly through and drains 

the northern portion of the BLM study area for the South Hilight Field LBA 

Tract. Approximately 47 percent (1,364 acres) of the 2,922-acre BLM study 

area for the South Hilight Field tract drains toward playas that are formed by 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-55 

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. Black Thunder Mine’s approved WDEQ/LQD mine 

permit allows disturbance of Little Thunder Creek and several of its tributaries. 

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 tract’s 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 natural surface water features and CBNG dewatering 

activities, the boundaries, areas, and types of wetlands 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 mine permitting process. In 

Wyoming, once the delineation has been verified, it is made a part of the mine 

permit document. The reclamation plan is then revised to incorporate the 

replacement of at least equal types and numbers of jurisdictional wetland 

acreages. 

Within the general analysis area for the South Hilight Field LBA Tract, no 

designated critical, crucial, or unique habitats designated by USFWS for T&E 

species are present. 
Appendix G 

G-56 Final EIS, Wright Area Coal Lease Applications

G-6.3 West Hilight Field Tract 

The West Hilight Field Tract LBA Tract and adjacent areas consist primarily of 

uplands (i.e., ground elevated above the lowlands that lie along the banks of 

drainages). The topography of the tract’s general analysis area, like the areas 

within the adjacent mines’ existing permit areas, is relatively subdued. The 

average land surface slope over the entire general analysis area for the West 

Hilight Field tract is approximately 2.2 percent. Surface mine lands, both 

disturbed and reclaimed, dominate the landscape northeast, east and 

southeast of the West Hilight Field tract. 

The West Hilight Field tract’s 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. Black Thunder Mine’s approved WDEQ/LQD mine permit 

allows disturbance of Little Thunder Creek and several of its tributaries. 

Approximately 24 percent (1,708 acres) of the 9,189-acre BLM study area for 

the West Hilight Field tract drains toward 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. 

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 tract’s 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 natural surface water features and CBNG dewatering 

activities, the boundaries, areas, and types of wetlands 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, 

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 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-57 

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 mine permitting process. In 

Wyoming, once the delineation has been verified, it is made a part of the mine 

permit document. The reclamation plan is then revised to incorporate the 

replacement of at least equal types and numbers of jurisdictional wetland 

acreages. 

Within the general analysis area for the West Hilight Field LBA Tract, no 

designated critical, crucial, or unique habitats designated by USFWS for T&E 

species are present. 

G-6.4 West Jacobs Ranch Tract 

The West Jacobs Ranch LBA Tract and adjacent areas consist primarily of 

uplands (i.e., ground elevated above the lowlands that lie along the banks of 

drainages). The topography of the tract’s general analysis area, like the areas 

within the adjacent mines’ existing permit areas, is relatively subdued. The 

average land surface slope over the entire general analysis area for the West 

Jacobs Ranch tract is approximately 4.1 percent. Surface mine lands, both 

disturbed and reclaimed, dominate the landscape east of the West Jacobs 

Ranch tract. 

Predominant wildlife habitat types classified in the general Wright analysis area 

generally correspond with the major vegetation communities defined during the 

vegetation baseline survey. In terms of relative acres of occurrence, the 

predominant vegetation types are the Big Sage Shrubland (approximately 42 

percent), Upland/Mixed Prairie Grassland (approximately 28 percent), and 

Crested Wheatgrass/Agricultural Pastureland (approximately 15 percent). 

Other habitats present within and around the West Jacobs Ranch LBA Tract 

include bottomland grassland, rough breaks, playas, reservoirs/stockponds, 

and disturbed lands. Disturbance areas associated with oil and gas 

development (i.e., networks of road and utility rights-of-way, tank batteries and 

well pads) overlay much of the tract’s general analysis area and make up the 

majority of disturbed lands. Few trees are present due to the lack of water and 

suitable habitats, most of which are found primarily in shelterbelts planted 

adjacent to ranching facilities. Reclaimed lands include areas that were 

disturbed for road construction and the installation of oil and gas developmentrelated facilities. 
Appendix G 

G-58 Final EIS, Wright Area Coal Lease Applications

The existing Jacobs Ranch Mine permit area and the general analysis area for 

the West Jacobs Ranch LBA Tract 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. 

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. Typical of this semi-arid area, Little Thunder Creek and its 

tributaries are all ephemeral streams. The current mine plan for the adjacent 

Black Thunder Mine allows disturbance of Little Thunder Creek and several of 

its tributaries, including North Prong Little Thunder Creek. 

Essentially all water courses in the tract’s general analysis area are receiving, 

or have received, discharge water from CBNG development and, as a result, the 

frequency and duration of streamflow events have increased and periods of no 

flow are less common. At least 33 distinct diked impoundments are located 

within the West Jacobs Ranch tract’s general analysis area. The shallow 

impoundments along Dry Fork Little Thunder Creek have seldom been 

completely dry in recent years. There are also a number of playas within the 

area that provide seasonal habitat for waterbirds and other aquatic species. 

A preliminary wetland inventory of the general analysis area for the West 

Jacobs Ranch LBA Tract, based on USFWS NWI mapping and reconnaissance 

in the field, was conducted in 2007 and 2008. Some wetland areas previously 

mapped by the USFWS NWI have been recently altered due to CBNG-related 

water production within and upstream of the tract’s 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 natural surface water features and CBNG dewatering 

activities, the boundaries, areas, and types of wetlands 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/reservoirs, ephemeral streams, playas, and 

isolated depressions. Of these 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 51.7 acres are pond or channel other waters (i.e., open water in 

reservoirs/stockponds, along ephemeral streams, and in playas). All of these 

wetlands and OWUS are classified as palustrine. Most of the wetlands have 

emergent vegetation, while most of the ponds and playas have aquatic beds 

and are seasonally or temporarily flooded. The vegetated wetlands are located 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-59 

primarily along the stream channels associated with Dry Fork and North Prong 

Little Thunder Creek. 

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 mine permitting process. In 

Wyoming, once the delineation has been verified, it is made a part of the mine 

permit document. The reclamation plan is then revised to incorporate the 

replacement of at least equal types and numbers of jurisdictional wetland 

acreages. 

Within the general analysis area for the West Jacobs Ranch LBA Tract, no 

designated critical, crucial, or unique habitats designated by USFWS for T&E 

species are present. 

G-6.5 North Porcupine Tract 

The North Porcupine LBA Tract and adjacent areas consist primarily of 

uplands (i.e., ground elevated above the lowlands that lie along the banks of 

drainages). The topography of the North Porcupine tract is influenced by 

Porcupine Creek and its tributaries. Land surface elevations in the tract’s 

general analysis area range from 4,707 to 5,000 feet and approximately 81 

percent of the land surface area has a slope of less than 5 percent. The 

average land surface slope over the entire general analysis area for the tract is 

approximately 3.2 percent. Surface mine lands, both active and reclaimed, 

dominate the landscape south and east of the North Porcupine LBA Tract. 

Based on total acreages, the predominant vegetation types in the general 

analysis area for the North Porcupine tract are Big Sagebrush Grassland (53.85 

percent) and Upland Grassland (31.78 percent), both of which occur primarily 

on the rolling upland terrain. Other habitat types common to North Porcupine 

include Breaks Grassland, Salt Grassland, Meadow Undeveloped Pastureland, 

Disturbed, Playa Grassland, Hayland, and Water areas. Disturbed areas are 

characterized primarily by a network of major roads and well pads that are 

stabilized with gravel or reclaimed. There are also small tank batteries and 

numerous miles of pipeline disturbance that, to varying degrees, are recovering 

vegetation cover. Those disturbances are associated with both CBNG and 

traditional oil and gas development in the area, though similar existing 

disturbance has occurred from ongoing surface mining activities. 

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. The North Antelope Rochelle Mine 

disturbs Porcupine Creek and several of its tributaries, and is currently 

permitted to disturb approximately 25 percent of Porcupine Creek’s watershed. 

Approximately 6,221 acres, or about 84 percent of the 7,367-acre BLM study 
Appendix G 

G-60 Final EIS, Wright Area Coal Lease Applications

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 tract’s general analysis area. The northeastern portion of the 

tract’s 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. 

Formal jurisdictional wetland delineation surveys covering North Antelope 

Rochelle Mine’s current permit area and some additional adjacent lands were 

completed by Powder River Coal, LLC (PRC) and submitted to the COE for 

verification in 1996, 1997, 1998, 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 nonjurisdictional 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 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-61 

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. 

Only the COE has the authorization to determine whether or not wetlands are 

jurisdictional or non-jurisdictional, following the submittal and review of a 

formal wetland delineation as part of the mine permitting process. In 

Wyoming, once the delineation has been verified, it is made a part of the mine 

permit document. The reclamation plan is then revised to incorporate the 

replacement of at least equal types and numbers of jurisdictional wetland 

acreages. 

Within the general analysis area for the North Porcupine LBA Tract, no 

designated critical, crucial, or unique habitats designated by USFWS for T&E 

species are present. 

G-6.6 South Porcupine Tract 

Of the six LBA tracts included in this analysis, the topography of the South 

Porcupine tract is somewhat unique due to the presence of more pronounced 

gullies and deeper tributary draws that are formed by the headwaters of 

Antelope, Horse, and Porcupine creeks. Land surface elevations in the tract’s 

general analysis area range from 4,675 to 4,950 feet, and approximately 51 

percent of the land surface area has a slope of less than 5 percent. The 

average land surface slope over the entire general analysis area for the tract is 

approximately 6.2 percent. Surface mine lands, both disturbed and reclaimed, 

dominate the landscape north, south and east of the South Porcupine LBA 

Tract. 

Based on total acreages, the predominant vegetation types in the general 

analysis area for the South Porcupine tract are Upland Grassland (55.7 

percent) and Breaks Grassland (23.5 percent), both of which occur primarily on 

the rolling upland terrain. Other habitat types common to South Porcupine 

include Salt Grassland, Playa Grassland, Disturbed, and Water areas. 

Disturbed areas are characterized primarily by a network of major roads and 

well pads that are stabilized with gravel or reclaimed. There are also small 

tank batteries and numerous miles of pipeline disturbance that, to varying 

degrees, are recovering vegetation cover. Those disturbances are associated 

with both CBNG and traditional oil and gas development in the area, though 

similar existing disturbance has occurred from ongoing surface mining 

activities. 

As stated above, the South Porcupine LBA Tract is located at the headwaters of 

tributaries to Antelope, Horse, and Porcupine creeks. Surface water drainage 

in the tract is divided, in that the northern and eastern portions of the tract 

drain north and east to Porcupine Creek via several of its ephemeral 

tributaries, the southern portion of the tract drains south to Antelope Creek via 

several of its ephemeral tributaries, and the western portion of the tract drains 
Appendix G 

G-62 Final EIS, Wright Area Coal Lease Applications

west to Horse Creek via several of its ephemeral tributaries. With the exception 

of about 60 acres, the entire BLM study area for the South Porcupine LBA 

Tract is within the existing North Antelope Rochelle Mine’s permit area. The 

North Antelope Rochelle Mine disturbs Porcupine Creek and several of its 

tributaries as well as several of Antelope Creek’s unnamed ephemeral 

tributaries. The mine is currently permitted to disturb approximately 25 

percent of Porcupine Creek’s watershed. 

All but about 140 acres of the general analysis area for the South Porcupine 

LBA Tract lies within North Antelope Rochelle Mine’s current mine permit area. 

Therefore, the mine’s 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 tract’s 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 12.3 acres of jurisdictional wetlands and OWUS. 

Of those 12.3 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. 

Only the COE has the authorization to determine whether or not wetlands are 

jurisdictional or non-jurisdictional, following the submittal and review of a 

formal wetland delineation as part of the mine permitting process. In 

Wyoming, once the delineation has been verified, it is made a part of the mine 

permit document. The reclamation plan is then revised to incorporate the 

replacement of at least equal types and numbers of jurisdictional wetland 

acreages. 

Within the general analysis area for the South Porcupine LBA Tract, no 

designated critical, crucial, or unique habitats designated by USFWS for T&E 

species are present. 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-63 

G-7.0 CURRENT STATUS AND HABITAT REQUIREMENTS OF SPECIES 

The following subsections describe the current status and habitat requirements 

of the Ute ladies’-tresses orchid (Spiranthes diluvialis), black-footed ferret 

(Mustela nigripes), and blowout penstemon (Penstemon haydenii). 

G-7.1 Ute Ladies’-tresses (Spiranthes diluvialis) 

Ute ladies’-tresses, a member of the orchid family, was listed under the ESA by 

the USFWS as threatened on January 17, 1992. At the time of listing, Ute 

ladies’-tresses was only known from Colorado, Utah, and extreme eastern 

Nevada. Ute ladies’-tresses orchids were discovered in Goshen County 

Wyoming in 1993. It is currently known from western Nebraska, east-central 

and southeastern Wyoming, north-central and northwestern Colorado, 

northeastern, south-central and western Utah, southeastern Idaho, 

southwestern Montana, southeastern Nevada, central Washington, and most 

recently in British Columbia, Canada (Brown 2008). Within Wyoming, Ute 

ladies’-tresses, the state’s rarest orchid, is known from Converse, Goshen, 

Laramie, and Niobrara counties in the Antelope Creek, Horse Creek, and 

Niobrara River watersheds (Fertig 2000, Heidel 2007). There is no designated 

critical habitat for the species in either Campbell or Converse counties, 

Wyoming (USFWS 2008). 

The ESA defines a threatened species as any species which is likely to become 

in danger of extinction within the foreseeable future throughout all or a 

significant portion of its range. The Ute ladies’-tresses was listed as threatened 

due to a variety of factors including geographic rarity, small population size, 

low reproductive rate, and habitat loss and modification (USFWS 1992a). 

G-7.1.1 Biology and Habitat Requirements 

Ute ladies’-tresses is a perennial, terrestrial orchid with 7- to 32-inch stems 

arising from tuberously thickened roots. The flowering stalk consists of a few 

to many small white or ivory-colored flowers that are arranged in a loose spiral 

at the top of the stem (USFWS 2009d). Flowers are needed for positive plant 

identification, and the plant can be reliably located only when it is flowering 

(Heidel 2001). 

In Wyoming, this species typically blooms from late July through early 

September (Heidel 2007). Flowering, which occurs mainly in August and takes 

about 2 weeks for any one plant, starts from the bottom upward on the 

flowering spike (Heidel et al. 2008). Leaves, which are separate from one 

another or joined only at the very base of the plant, persist during flowering 

(Moseley 1998). Plants do not flower every year and may remain dormant 

below ground during adverse (i.e., drought) conditions. In general, the species’ 

best flowering years seem to correspond with extreme heat during flowering. 

Preliminary review of climate data also indicates that growing seasons that 
Appendix G 

G-64 Final EIS, Wright Area Coal Lease Applications

start out as relatively cold and wet correspond with low flowering levels (Heidel 

2001). 

Flowers must be pollinated to produce seeds. No direct observations of 

pollination have been made in Wyoming. Sipes and Tepedino (1995) indicated 

that large, long-tongued bumblebees in the genus Bombus are the primary 

pollinators in Utah and Colorado. Smaller bees may also visit these flowers, 

but have the incorrect body shape or mass to properly accommodate the 

orchid’s large, sticky anther/pollen clusters (Fertig 2000). 

Sipes and Tepedino (1995) estimate that individual seed pods may contain 

several hundred to several thousand seeds apiece and an entire plant may 

produce as many as 100,000 seeds in a year. As with other orchid species, Ute 

ladies’-tresses’ seeds are microscopic dust-like, and are readily dispersed by 

wind or water (Fertig et al. 2005). Orchids with microscopic seeds are most 

commonly distributed by the wind and therefore may be widely dispersed for 

great distances (Arditti and Ghani 2000). 

After its microscopic seeds germinate, the roots form an interdependent 

relationship with a fungus, which are called mycorrhizae. In any given year, 

individual Ute ladies’-tresses plants may flower, remain in an inconspicuous 

vegetative stage with narrow leaves, or remain entirely below ground with the 

help of its mycorrhizae symbiont (Fertig 2000, Heidel et al. 2008). The absence 

or rarity of appropriate symbionts in the soil may be a major factor limiting the 

establishment of the Spiranthes diluvialis populations. Surviving seedlings 

probably develop slowly into larger dormant mycorrhizal roots or grow directly 

into aboveground vegetative shoots, but apparently neither has been confirmed 

in the wild (Fertig et al. 2005). No data are available on the number of years 

required for subterranean Ute ladies’-tresses roots to reach sufficient size to 

develop aboveground leafy shoot, although related species may remain 

dormant for 8-11 years (Wells 1981). Long-term demographic monitoring 

studies indicate that the plant can revert to belowground existence for one to 

four or more growing seasons before re-emerging with new shoots (Arft 1995, 

Heidel 2001). Although considered dormant, belowground plants remain 

metabolically active and derive nourishment from their mycorrhizal partners or 

food stores laid down when photosynthetic shoots were present (Fertig et al. 

2005). 

The Ute ladies’-tresses preferred habitat typically occurs in moist valley 

bottoms where perennial rivers and streams are fed by groundwater (Heidel et 

al. 2008). The species occurs primarily on low, flat floodplain terraces or 

abandoned oxbows within 2-150 feet of small perennial streams or rivers. 

These terraces are subirrigated, often seasonally flooded, and remain moist 

throughout most of the growing season. It typically occurs in stable wetland 

and seepy areas within historical floodplains of major rivers, as well as in 

wetlands and seeps near freshwater lakes or springs. Nearly all occupied sites 

have a high water table (usually within 5 to 18 inches of the surface) 

augmented by seasonal flooding, snowmelt, runoff and irrigation (USFWS 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-65 

2009d). Ute ladies’-tresses seem to require “permanent sub-irrigation,” 

indicating a close affinity with floodplain areas where the water table is near 

the surface throughout the growing season and into the late summer and early 

autumn (USFWS 1995). The species seems to prefer well drained, sandy to 

silty loam soils derived from alluvial deposits with a slightly basic pH 

(University of Wyoming 2008). It is not found in heavy or tight clay soils or in 

extremely saline or alkaline (pH > 8) soils (USFWS 2009d). 

Surveys conducted since 1992 have expanded the number of vegetation and 

hydrology types occupied by Ute ladies’-tresses to include subirrigated or 

spring-fed abandoned stream channels and valleys, and lakeshores. 

Populations have also been discovered along irrigation canals, berms, irrigated 

meadows, excavated gravel pits, roadside borrow pits, and other humanmodified wetlands. The orchid is well adapted to disturbances from stream 

movement within floodplains over time and is tolerant of other disturbances 

such as grazing that are common to grassland riparian habitats (USFWS 1995). 

Populations are often dynamic and “move” within a watershed as disturbances 

create new habitat or succession eliminates old habitat (Fertig and Beauvais 

1999). The orchid has been known to establish in heavily disturbed sites, such 

as revegetated gravel pits, heavily grazed riparian edges, and along welltraveled foot trails on old berms (USFWS 1995). The elevation range in which 

the species is known to occur is from 720 feet in Washington to 7,000 feet in 

Utah (USFWS 2009d). 

The grassy vegetation of Ute ladies’-tresses habitat is relatively short (usually 

less than 18 inches) but dense, usually in full sun but sometimes partial 

shade. The wet meadow communities preferred by the plant are dominated by 

redtop (Agrostis stolonifera), common quackgrass (Elytrigia repens), foxtail 

barley (Hordeum jubatum), switchgrass (Panicum virgatum), and occasionally 

Baltic rush (Juncus balticus) or few-flowered spikerush (Eleocharis quinqueflora) 

within a narrow vegetative band between emergent aquatic vegetation and 

adjacent dry upland prairie (Fertig 2000, Heidel 2007). Other associated 

species include horsetail (Equisetum laevigatum), milkweed (Asclepias L.), 

goldenrod (Solidago L.), arrowgrass (Triglochin L.), blue-eyed grasses 

(Sisyrinchium angustifolium and S. montanum), three-square (Schoenoplectus 

pungens), and white prairie aster (Symphyotrichum falcatum) (Fertig et al. 2005, 

Heidel et al. 2008). Vegetation cover is typically 75-90 percent and the Ute 

ladies’-tresses usually occur as small scattered groups and occupy relatively 

small areas within the riparian system (Fertig 2000). The orchid persists in 

those areas where the hydrology provides continual dampness in the rooting 

zone throughout the growing season, but is not tolerant of long term standing 

water, and does not compete with emergent plant species (e.g., cattails) or 

aggressive species that form dense monocultures such as Canada thistle 

(USFWS 1995). 
Appendix G 

G-66 Final EIS, Wright Area Coal Lease Applications

G-7.1.2 LBA Tracts Existing Environments 

Prior to 2005, four Ute ladies’-tresses populations had been documented within 

Wyoming, all discovered between 1993 and 1997 (Fertig and Beauvais 1999). 

Four additional sites were located in 2005 and one additional site was found in 

2006 (Heidel 2007). The new locations were in the same drainages or 

tributaries as the original four populations. Drainages with documented orchid 

populations include Antelope Creek and its tributaries in northern Converse 

County, Bear Creek in northern Laramie and southern Goshen counties, Horse 

Creek in Laramie County, and Niobrara River in Niobrara County. The nearest 

population to the general Wright analysis area is located on an unnamed 

tributary of Antelope Creek in northern Converse County. No occurrences have 

been recorded in Campbell County, and there is no designated critical habitat 

for Ute ladies’-tresses within the general Wright analysis area. 

In order to adequately determine the presence of the species, areas of 

potentially suitable habitat within the general analysis area for each of the 

WAC LBA tracts were surveyed during the period that the orchids in Converse 

County are known to flower. Dormant plants can typically persist belowground 

for one to many years and can only be reliably documented after several years 

of repeated surveys (Lesica and Steel 1994). The USFWS Interim Survey 

Requirements for Ute ladies’-tresses therefore recommends that all suitable 

habitat be surveyed annually for three consecutive years (USFWS 1992b). For 

each LBA tract’s general analysis area, topographical and wetland delineation 

maps were reviewed to identify all areas that may contain the species. Other 

potentially suitable habitat factors included less steep stream banks, light soil 

texture and well drained soils, close lateral or vertical distance to perennial 

water source during the flowering period, lack of plant competition, lack of 

general soil alkalinity/salinity, and current or historical land management 

practices that did not promote overgrazing and extensive use of riparian areas. 

USFWS requires a statement of surveyor qualifications as part of a field survey. 

Field surveys were conducted by qualified personnel, whose botanical 

experience and training in conducting rare plant surveys, including Spiranthes 

diluvialis, are included below in Section G-13.0. The results of the field 

surveys for each LBA tract are included within the following subsections. 

G-7.1.2.1 North Hilight Field 

The nearest known population of Ute ladies’-tresses to the North Hilight Field 

LBA Tract is located on a tributary of Antelope Creek in northern Converse 

County, roughly 35 miles southwest of the tract. The North Hilight Field tract 

is not located within the Antelope Creek drainage basin. 

Topographical and wetland delineation maps of the North Hilight Field tract 

were reviewed to identify potentially suitable habitat for Ute ladies’-tresses 

prior to conducting the field surveys. Refer to Section G-6.1 for a description of 

the landscape and potential wetland areas identified within the general 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-67 

analysis area for the North Hilight Field tract. The preliminary wetland 

inventory that was conducted in 2007 identified a total of 177.5 acres of 

wetlands and OWUS, which were all vegetated wetlands, and no areas of open 

water (pond or channel OWUS) were observed. Figure G-21 depicts the USFWS 

NWI mapping within the North Hilight Field tract’s general analysis area. Most 

of the potentially suitable habitat within the general analysis area and adjacent 

areas is found along the ephemeral stream channels that drain south toward 

North Prong Little Thunder Creek, north toward Black Thunder Creek, or 

toward internally drained playas. Limited portions of these drainages may 

receive recharge from bank storage making them locally intermittent. In 

response to surface discharge of groundwater associated with CBNG 

development on or upstream of the North Hilight Field LBA Tract, which was a 

relatively recent phenomenon, streamflow was more persistent in the 

ephemeral channels and the duration of time that some playas and in-channel 

reservoirs held water was extended before going dry. In 2009, surveyors 

observed that groundwater discharges from local CBNG production declined, 

reducing the amount of potentially suitable habitat for Ute ladies’-tresses. 

Areas of potentially suitable habitat within the general analysis area for the 

North Hilight Field LBA Tract were surveyed by Habitat Management, Inc. on 

August 11-15, 2008 and on August 12, 2009. Pedestrian surveys were 

conducted during the time of flowering of the known population in Converse 

County and involved walking entirely around all areas that have been identified 

as potential wetlands, including the entire lengths of the ephemeral drainage 

channels (Figure G-21), documenting locations of potentially suitable habitat 

and searching for this species. Outside of these areas, favorable habitat 

conditions do not exist within the tract’s general analysis area. No Ute ladies’-

tresses were found during the 2008 and 2009 surveys. In order to adequately 

determine the presence of the species, an additional survey by Habitat 

Management, Inc. is scheduled during the flowering period, from mid-August to 

early September, in 2010. 

Previous surveys for Ute ladies’-tresses have been conducted within the 

adjacent Jacobs Ranch and Black Thunder mines’ existing permit areas in 

order to evaluate the potential effects of leasing federal coal reserves within 

those areas on the federally listed species. For example, the North Hilight Field 

tract is contiguous to two federal coal leases that were recently issued to these 

two mines: the North Jacobs Ranch LBA Tract, which is within the Jacobs 

Ranch Mine permit area, and the Little Thunder LBA Tract, which is within the 

Black Thunder Mine permit area. The results of those surveys are included 

within the Final EIS for the North Jacobs Ranch Coal Lease Application (BLM 

2001b) and the Final South Powder River Basin Coal EIS (BLM 2003). (Note: 

Table 1-1 of this EIS lists the LBA tract names, the respective applicant mines, 

and the dates that each maintenance coal lease was issued in the Powder River 

Basin since 1992.) The potential suitable habitat within the study area for the 

North Jacobs Ranch LBA Tract was surveyed by Intermountain Resources 

during the flowering period in July and August 1999 and no Ute ladies’-tresses 

were found (BLM 2001b). The potential suitable habitat within the study area 
30

31

18

19

7

1720

29

32

8

16

21

2833

9

15

2227

34

10 11

14

23

26

35

10152227

34 35

26

23

14

11 12

13

24

2536

T.

44

N.

R. 71 W. R. 70 W.

R. 71 W. R. 70 W.

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMAh

PEMC

PEMCx

PEMAh

PABFh

PEMAh

PEMB

PEMAh

PEMC

PEMCh

PEMAh

PEMAh

PEMAh PEMAh

PEMAh

PABFh

PEMC

PEMCh

PEMCh PABFh

PEMCh

PABFh

PEMA

PEMA

PEMA

PUBFx

PEMAh

PEMAh

PABFh

PEMC

PABFh

PEMAh

PEMAh

PABFh

PEMAh

PABFh PEMAh

PEMCh

PEMAh

PEMCh

PEMAh

PEMAh

PUBFx

PUSCh

PABFh

PABFh

PEMAh

PEMC

PEMA

PEMA

PEMAh

PEMAh

T.

44

N.

Coal

Creek

Creek

Thunder

Black

Draw

Keeline

Springen Draw

Mills

Draw

LEGEND

2500 5000 10000 0

GRAPHIC SCALE (FEET)

Wetlands Areas

(i.e., broad depressions, stock pond areas)Linear Wetlands(i.e., narrow ephemeral drainage channels)

PEMC

PEMA Palustrine, Emergent, Temporarily Flooded

PEMAh

Palustrine, Emergent, Seasonally Flooded

Palustrine, Emergent, TemporarilyFlooded, Diked/Impounded

PEMCh Palustrine, Emergent, Seasonally Flooded, Diked/Impounded

USFWS NWI

Map Classification Codes North Hilight Field LBA Tract Wetlands Analysis Area Boundary

PABFh Palustrine, Aquatic Bed, Semipermanently Flooded, Diked/Impounded

PEMB Palustrine, Emergent, Saturated

PUBFx Palustrine, Unconsolidated Bottom, Semipermanently Flooded, Excavated

PUSCh Palustrine, Unconsolidated Shore, Seasonally Flooded, Diked/Impounded

PEMA

PEMA

Source: USFWS NWI Mapping (1980)

Black Thunder Mine Permit BoundaryEphemeral Stream Channel

Figure G-21. Wetlands Within the General Analysis Area for the North Hilight Field LBA Tract.

Appendix G

G-68 Final EIS, Wright Area Coal Lease Applications
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-69 

for the Little Thunder LBA Tract was surveyed by Intermountain Resources 

during the flowering period in August 2001 and no Ute ladies’-tresses were 

found (BLM 2003). 

In addition to the BAs that have been prepared to evaluate the potential effects 

of leasing federal coal tracts to the adjacent mines, BAs have also been 

prepared to address the potential effects to federally listed species by 

disturbing federal surface lands that are located inside the mines’ existing 

permit areas but are outside the mines’ federal coal lease boundaries. Those 

BAs, which have been submitted to the appropriate land management agency 

(i.e., USFS), document the results of field surveys in those areas, and to date, 

all surveys for Ute ladies’-tresses in the general Wright analysis area have 

resulted in negative findings. 

G-7.1.2.2 South Hilight Field 

The nearest known population of Ute ladies’-tresses to the South Hilight Field 

LBA Tract is located on a tributary of Antelope Creek in northern Converse 

County, roughly 30 miles southwest of the tract. The South Hilight Field tract 

is not located within the Antelope Creek drainage basin. 

Topographical and wetland delineation maps of the South Hilight Field tract 

were reviewed to identify potentially suitable habitat for Ute ladies’-tresses 

prior to conducting the field surveys. Refer to Section G-6.2 for a description of 

the landscape and potential wetland areas identified within the general 

analysis area for the South Hilight Field tract. The preliminary wetland 

inventory that was conducted in 2007 identified a total of 55.1 acres of 

wetlands and OWUS, which were predominantly vegetated wetlands and 

roughly 1 acre of aquatic beds and 2.8 acres of open water within the channel 

of Little Thunder Creek were observed. Figure G-22 depicts the USFWS NWI 

mapping within the South Hilight Field tract’s general analysis area. Most of 

the potentially suitable habitat within the general analysis area and adjacent 

areas is found along Little Thunder Creek, which flows from west to east 

through the northern portion of the tract. Nearly half of the study area drains 

toward playas that are formed by natural topographic depressions. All 

drainages within and around this area, including Little Thunder Creek, are 

ephemeral. Limited portions of these drainages may receive recharge from 

bank storage making them locally intermittent. In response to surface 

discharge of groundwater associated with CBNG development on or upstream 

of the South Hilight Field LBA Tract, which was a relatively recent 

phenomenon, streamflow was more persistent in the ephemeral channels and 

the duration of time that some playas and in-channel reservoirs held water was 

extended before going dry. In 2009, surveyors observed that groundwater 

discharges from local CBNG production declined, reducing the amount of 

potentially suitable habitat for Ute ladies’-tresses. 

Areas of potentially suitable habitat within the general analysis area for the 

South Hilight Field LBA Tract were surveyed by Habitat Management, Inc. on 
33

28

21

16

34

27

22

15

35

26

23

14

36

25

24

13

31

30

19

18

32

29

20

17

9

4

10

3

11

2

12

1

7

6

8

5

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

T.

43

N.

T.

42

N.

R. 71 W. R. 70 W.

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMAh

PEMAh

PEMC

Creek

Little

Thunder

Olson

Draw

Briggs

Draw

Grey

Draw

LEGEND

0 2000 4000 8000

GRAPHIC SCALE (FEET)

PEMA PEMC

PEMA Palustrine, Emergent, Temporarily

Flooded

PEMAh

Palustrine, Emergent, Seasonally

Flooded

Palustrine, Emergent, Temporarily

Flooded, Diked/Impounded

USFWS NWI

South Hilight Field LBA Tract Map Classification Codes

Wetlands Analysis Area Boundary

Wetlands Areas

(i.e., broad depressions, stock pond areas)

Linear Wetlands

(i.e., narrow ephemeral drainage channels) PEMA

Source: USFWS NWI Mapping (1980)

Ephemeral Stream Channel

Black Thunder Mine Permit Boundary

Figure G-22. Wetlands Within the General Analysis Area for the South Hilight Field LBA Tract.

Appendix G

G-70 Final EIS, Wright Area Coal Lease Applications
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-71 

August 11-15, 2008 and on August 12, 2009. Pedestrian surveys were 

conducted during the time of flowering of the known population in Converse 

County and involved walking entirely around all areas that have been identified 

as potential wetlands, including the entire lengths of the ephemeral drainage 

channels (Figure G-22), documenting locations of potentially suitable habitat 

and searching for this species. Outside of these areas, favorable habitat 

conditions do not exist within the tract’s general analysis area. No Ute ladies’-

tresses were found during the 2008 and 2009 surveys. In order to adequately 

determine the presence of the species, an additional survey by Habitat 

Management, Inc. is scheduled during the flowering period, from mid-August to 

early September, in 2010. 

Previous surveys for Ute ladies’-tresses have been conducted within the 

adjacent Black Thunder Mine’s existing permit area and the proposed School 

Creek Mine’s permit area in order to evaluate the potential effects of leasing 

federal coal reserves within those areas on the federally listed species. For 

example, the South Hilight Field tract is contiguous to two federal coal leases 

that were recently issued to these two mines: the Little Thunder LBA Tract, 

which is within the Black Thunder Mine permit area, and the West Roundup 

LBA Tract, which is within the proposed School Creek Mine permit area. The 

results of those surveys are included within the Final South Powder River 

Basin Coal EIS (BLM 2003). (Note: Table 1-1 of this EIS lists the LBA tract 

names, the respective applicant mines, and the dates that each maintenance 

coal lease was issued in the Powder River Basin since 1992.) The potential 

suitable habitat within the study area for the Little Thunder LBA Tract was 

surveyed by Intermountain Resources during the flowering period in August 

2001 and no Ute ladies’-tresses were found (BLM 2003). The potential suitable 

habitat within the study area for the West Roundup LBA Tract was surveyed by 

Intermountain Resources during the flowering period in July and August 2001 

and no Ute ladies’-tresses were found (BLM 2003). 

In addition to the BAs that have been prepared to evaluate the potential effects 

of leasing federal coal tracts to the adjacent mines, BAs have also been 

prepared to address the potential effects to federally listed species by 

disturbing federal surface lands that are located inside the mines’ existing 

permit areas but are outside the mines’ federal coal lease boundaries. Those 

BAs, which have been submitted to the appropriate land management agency 

(i.e., USFS), document the results of field surveys in those areas, and to date, 

all surveys for Ute ladies’-tresses in the general Wright analysis area have 

resulted in negative findings. 

G-7.1.2.3 West Hilight Field 

The nearest known population of Ute ladies’-tresses to the West Hilight Field 

LBA Tract is located on a tributary of Antelope Creek in northern Converse 

County, roughly 30 miles southwest of the tract. The West Hilight Field tract is 

not located within the Antelope Creek drainage basin. 
Appendix G 

G-72 Final EIS, Wright Area Coal Lease Applications

Topographical and wetland delineation maps of the West Hilight Field tract 

were reviewed to identify potentially suitable habitat for Ute ladies’-tresses 

prior to conducting the field surveys. Refer to Section G-6.3 for a description of 

the landscape and potential wetland areas identified within the general 

analysis area for the West Hilight Field tract. The preliminary wetland 

inventory that was conducted in 2007 identified a total of 262.7 acres of 

wetlands and OWUS, which were predominantly vegetated wetlands and 

roughly 12 acres of aquatic beds and 10 acres of open water held within the 

channel of Little Thunder Creek and the Little Thunder Reservoir. Figure G-23 

depicts the USFWS NWI mapping within the West Hilight Field tract’s general 

analysis area. Most of the potentially suitable habitat within the general 

analysis area and adjacent areas is found along Little Thunder Creek, which 

flows from west to east through the central portion of the tract, and its 

ephemeral tributaries, Briggs Draw and Black Butte Draw, which drain the 

southern portion of the general analysis area. Nearly a quarter of the study 

area drains toward playas that are formed by natural topographic depressions; 

the largest of which is called Rochelle Lake. All drainages within and around 

this area, including Little Thunder Creek, are ephemeral. Limited portions of 

these drainages may receive recharge from bank storage making them locally 

intermittent. In response to surface discharge of groundwater associated with 

CBNG development on or upstream of the South Hilight Field LBA Tract, which 

was a relatively recent phenomenon, streamflow was more persistent in the 

ephemeral channels and the duration of time that some playas and in-channel 

reservoirs held water was extended before going dry. In 2009, surveyors 

observed that groundwater discharges from local CBNG production declined, 

reducing the amount of potentially suitable habitat for Ute ladies’-tresses. 

Areas of potentially suitable habitat within the general analysis area for the 

West Hilight Field LBA Tract were surveyed by Habitat Management, Inc. on 

August 11-15, 2008 and on August 12, 2009. Pedestrian surveys were 

conducted during the time of flowering of the known population in Converse 

County and involved walking entirely around all areas that have been identified 

as potential wetlands, including the entire lengths of the ephemeral drainage 

channels (Figure G-23), documenting locations of potentially suitable habitat 

and searching for this species. Outside of these areas, favorable habitat 

conditions do not exist within the tract’s general analysis area. No Ute ladies’-

tresses were found during the 2008 and 2009 surveys. In order to adequately 

determine the presence of the species, an additional survey by Habitat 

Management, Inc. is scheduled during the flowering period, from mid-August to 

early September, in 2010. 

Previous surveys for Ute ladies’-tresses have been conducted within the 

adjacent Black Thunder Mine’s existing permit area in order to evaluate the 

potential effects of leasing federal coal reserves within that area on the federally 

listed species. For example, the West Hilight Field tract is contiguous to the 

Little Thunder LBA Tract, which was recently issued as a maintenance lease to 

the Black Thunder Mine. The results of those surveys are included within the 

Final South Powder River Basin Coal EIS (BLM 2003). (Note: Table 1-1 of this 
31 32 33 34 35

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

7

6

8

5

9

4

10

3

11

2

T.

44

N.

T.

43

N.

T.

43

N.

T.

42

N.

T.

44

N.

T.

43

N.

R. 71 W.

R. 71 W.

T.

43

N.

T.

42

N.

PEMAh

PEMAh

PEMAh

PEMC

PEMC

PABF

PABF PABF

PABF

PABF

PEMC

PABFh

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PEMAh

PEMA

PEMAh

PEMAx

PEMA

PEMA

PEMAh

PEMAh

PABFh

PABFh

PEMC

PABF

PEMAh

PABFh

PUSCh

PEMA

PEMA

PEMA

PEMA

PEMA

PEMA

PUBFx

PUBFx PEMA

PEMAh

PEMAh

PABFh

PEMCh

PABFh

PEMA

PEMA

PEMA

PEMB

PEMAh

PABFh

PEMA

PEMA

PEMAh

PABFh

PABFh

PEMAh

PEMA

PABFh

PEMA

PEMA

PEMA

PEMA

PUBFx

Thunder

Little

Creek

Prong

North

Little Thunder

Creek

Dry Fork

Draw

Creek

Thunder

Little

Thunder Butte

Black

Briggs

Draw

Grey Draw

Brater

Draw

Draw

Manor

Palustrine, Aquatic Bed,

Semipermanently Flooded

Palustrine, Emergent, Temporarily

Flooded

Palustrine, Emergent, Seasonally

Flooded

Palustrine, Emergent, Temporarily

Flooded, Diked/Impounded

Palustrine, Emergent, Seasonally

Flooded, Diked/Impounded

USFWS NWI

Map Classification Codes

West Hilight Field LBA Tract

Wetlands Analysis Area Boundary

Palustrine, Aquatic Bed,

Semipermanently Flooded,

Diked/Impounded

Palustrine, Emergent, Saturated

Palustrine, Unconsolidated Bottom,

Semipermanently Flooded, Excavated

LEGEND

0 2500 5000 10000

GRAPHIC SCALE (FEET)

Wetlands Areas

(i.e., broad depressions,

stock pond areas)

Linear Wetlands

(i.e., narrow ephemeral

drainage channels)

PEMA

PEMA

PUBFx

PEMB

PABFh

PEMCh

PEMAh

PEMC

PABF

PEMAx

PUSCh

PEMA

Palustrine, Emergent, Temporarily

Flooded, Excavated

Palustrine, Unconsolidated Shore,

Seasonally Flooded, Diked/Impounded

Source: USFWS NWI Mapping (1980)

Ephemeral Stream Channel

Black Thunder Mine Permit Boundary

Figure G-23. Wetlands Within the General Analysis Area for the West Hilight Field LBA Tract.

Appendix G

Final EIS, Wright Area Coal Lease Applications G-73
Appendix G 

G-74 Final EIS, Wright Area Coal Lease Applications

EIS lists the LBA tract names, the respective applicant mines, and the dates 

that each maintenance coal lease was issued in the Powder River Basin since 

1992.) The potential suitable habitat within the study area for the Little 

Thunder LBA Tract was surveyed by Intermountain Resources during the 

flowering period in August 2001 and no Ute ladies’-tresses were found (BLM 

2003). 

In addition to the BAs that have been prepared to evaluate the potential effects 

of leasing federal coal tracts to the adjacent mines, BAs have also been 

prepared to address the potential effects to federally listed species by 

disturbing federal surface lands that are located inside the mines’ existing 

permit areas but are outside the mines’ federal coal lease boundaries. Those 

BAs, which have been submitted to the appropriate land management agency 

(i.e., USFS), document the results of field surveys in those areas, and to date, 

all surveys for Ute ladies’-tresses in the general Wright analysis area have 

resulted in negative findings. 

G-7.1.2.4 West Jacobs Ranch 

The nearest known population of Ute ladies’-tresses to the West Jacobs Ranch 

LBA Tract is located on a tributary of Antelope Creek in northern Converse 

County, roughly 30 miles southwest of the tract. The West Jacobs Ranch tract 

is not located within the Antelope Creek drainage basin. 

Topographical and wetland delineation maps of the West Jacobs Ranch tract 

were reviewed to identify potentially suitable habitat for Ute ladies’-tresses 

prior to conducting the field surveys. Refer to Section G-6.4 for a description of 

the landscape and potential wetland areas identified within the general 

analysis area for the West Jacobs Ranch tract. The preliminary wetland 

inventory that was conducted in 2007 and 2008 by Intermountain Resources 

identified a total of 68.4 acres of wetlands and OWUS, which were comprised of 

approximately 16.7 acres of vegetated wetlands and 51.7 acres of open water 

held in reservoirs/stockponds, ephemeral streams and playas. The vegetated 

wetlands were located primarily along the Dry Fork and North Prong Little 

Thunder Creek stream channels. Figure G-24 depicts Intermountain 

Resources’ preliminary wetland mapping within the West Jacobs Ranch tract’s 

general analysis area. Most of the potentially suitable habitat within the West 

Jacobs Ranch tract’s general analysis area and adjacent areas is very limited 

and found mostly along the CBNG-impacted bottomlands of North Prong Little 

Thunder Creek, Dry Fork Little Thunder Creek, and their tributaries. The 

quality of potential habitat in this area is poor for a number of key reasons: 

• The soils tend to be heavy and trend from moderately to very 

saline/sodic. The saline/sodic areas typically have monocultural stands 

of inland saltgrass (Distichlis spicata stricta), foxtail barley (Hordeum 

jubatum) or alkali bulrush (Scirpus maritimus). 
P

P

P

P P

P

P

P

P

P

P P

P

P

P

P

P

P

P

P

P

P

P

P

P

P

P

P

P

P

D

D

D

D

D

D

D

D

D

D

D

D

D

T.

44

N.

T.

43

N.

T.

44

N.

T.

43

N.

R. 71 W.

R. 71 W.

19

18

20

17

21

16

22

15

23

14

36

25

24

13

12

1

31

30

32

29

33

28

34

27

35

26

7

6

8

5

9

4

10

3

11

2

P

P

Draw

Thunder

Little

Creek

Prong

North

Section

School

Little Thunder

Creek

Dry Fork

Springen

Draw

Brater Draw

P

D Playa or Depression

Pond

Ephemeral Stream Wetland

or Other Waters of the U.S.

LEGEND

Jacobs Ranch Mine Permit Boundary

0 2000 4000 8000

GRAPHIC SCALE (FEET)

West Jacobs Ranch LBA Tract

General Analysis Area Boundary

Preliminary Wetland Mapping by

Intermountain Resources (2008)

Ephemeral Stream Channel

Figure G-24. Wetlands Within the General Analysis Area for the West Jacobs Ranch LBA Tract.

Appendix G

Final EIS, Wright Area Coal Lease Applications G-75
Appendix G 

G-76 Final EIS, Wright Area Coal Lease Applications

• Wet meadow habitat types are heavily colonized by aggressive 

rhizomatous graminoid plant species, including common spikerush 

(Eleocharis palustris), alkali cordgrass (Spartina gracilis), and western 

wheatgrass (Pascopyron smithii). These narrow riparian strips located 

between emergent aquatic vegetation and dry upland prairie may be too 

dense and too shaded by tall vegetation to provide suitable habitat. 

• Surface discharge of groundwater associated with CBNG development 

within and upstream of the study area, which is a relatively recent 

phenomenon, has altered historic shallow groundwater and soil moisture 

conditions along all water courses, causing major shifts in plant 

community distributions. 

• Livestock grazing, particularly during the wetter times of the year, has 

impacted the quality of riparian areas. 

In 2007 and 2008, field surveyors observed that streamflow was more 

persistent in the ephemeral channels and the duration of time that some 

playas and in-channel reservoirs held water was extended before going dry. 

This phenomenon was due to the surface discharge of groundwater associated 

with local CBNG production, thus increasing the overall area of potentially 

suitable habitat for Ute ladies’-tresses. However, in 2009 the surveyors noted 

that groundwater discharges from CBNG production in the area had declined 

relative to the conditions in 2007 and 2008, thus reducing the amount of 

potentially suitable habitat for the orchids. 

Areas of potentially suitable habitat within the general analysis area for the 

West Jacobs Ranch LBA Tract were surveyed for Ute ladies’-tresses by 

Intermountain Resources in early and mid-August of 2007, in early and midAugust of 2008, and again in early and mid-August of 2009. Pedestrian 

surveys of the limited potential habitat for this species, which occurs only 

within the potential wetland areas and narrow riparian strips located along the 

CBNG-impacted bottomlands of the North Prong Little Thunder Creek and its 

tributaries (Figure G-24), were conducted during the flowering period of the 

known population in Converse County, and no orchids were found. 

Previous surveys for Ute ladies’-tresses have been conducted within the 

adjacent Jacobs Ranch and Black Thunder mines’ existing permit areas in 

order to evaluate the potential effects of leasing federal coal reserves within 

those areas on the federally listed species. For example, the West Jacobs 

Ranch tract is contiguous to the Little Thunder LBA Tract, which was recently 

issued as a maintenance lease to the Black Thunder Mine. In addition, the 

West Jacobs Ranch tract is located just 1 mile west of the North Jacobs Ranch 

LBA Tract, which was recently issued as a maintenance lease to the Jacobs 

Ranch Mine. The results of those surveys are included within the Final South 

Powder River Basin Coal EIS (BLM 2003) and the Final EIS for the North 

Jacobs Ranch Coal Lease Application (BLM 2001b). (Note: Table 1-1 of this EIS 

lists the LBA tract names, the respective applicant mines, and the dates that 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-77 

each maintenance coal lease was issued in the Powder River Basin since 1992.) 

The potential suitable habitat within the study area for the Little Thunder LBA 

Tract was surveyed by Intermountain Resources during the flowering period in 

August 2001 and no Ute ladies’-tresses were found (BLM 2003). The potential 

suitable habitat within the study area for the North Jacobs Ranch LBA Tract 

was surveyed by Intermountain Resources during the flowering period in July 

and August 1999 and no Ute ladies’-tresses were found (BLM 2001b). 

In addition to the BAs that have been prepared to evaluate the potential effects 

of leasing federal coal tracts to the adjacent mines, BAs have also been 

prepared to address the potential effects to federally listed species by 

disturbing federal surface lands that are located inside the mines’ existing 

permit areas but are outside the mines’ federal coal lease boundaries. Those 

BAs, which have been submitted to the appropriate land management agency 

(i.e., USFS), document the results of field surveys in those areas, and to date, 

all surveys for Ute ladies’-tresses in the general Wright analysis area have 

resulted in negative findings. 

G-7.1.2.5 North Porcupine 

The nearest known population of Ute ladies’-tresses to the North Porcupine 

LBA Tract is located on an unnamed tributary of Antelope Creek in northern 

Converse County, roughly 28 miles west-southwest of the tract. A large portion 

(about 84 percent) of the North Porcupine tract is located within the Porcupine 

Creek watershed, which is a major tributary of Antelope Creek. Trussler and 

Holmes Creek watersheds drain the remainder of the tract, but they are not 

within the Antelope Creek watershed. No occurrences have been recorded in 

Campbell County, including the lands within the North Porcupine tract’s 

general analysis area. 

The potentially suitable habitat within North Porcupine tract’s general analysis 

area and adjacent areas is found primarily along Porcupine Creek. Porcupine 

Creek is classified as an ephemeral stream, although surface discharge of 

groundwater associated with local CBNG development, which is a relatively 

recent phenomenon, has resulted in more persistent streamflow and generally 

wetter conditions within and adjacent to the stream channel throughout the 

year. The alluvial soils along Porcupine Creek in this area provides very little 

suitable habitat for Ute ladies’-tresses due to excessive saline/sodic soil 

properties (PRC 2009). There are several stock reservoirs within the tract’s 

general analysis area as well, and a few playas have formed in the lowest 

portion of areas that do not contribute runoff to any stream. Most of the 

reservoirs and playas contain water only in early spring. However, if the 

presence of water is more persistent in some areas, potential Ute ladies’-tresses 

habitat may exist within the narrow riparian strips located adjacent to these 

features, as they furnish the appropriate vegetation such as that found along 

Porcupine Creek. 
Appendix G 

G-78 Final EIS, Wright Area Coal Lease Applications

Prior to conducting field surveys, topographical and wetland delineation maps 

were reviewed to identify all areas of potentially suitable habitat where the 

species may occur. Suitable habitat factors included less steep stream banks, 

light soil texture and well drained soils, close lateral or vertical distance to a 

perennial water source during the flowering period, lack of plant competition, 

lack of general soil alkalinity/salinity, and current or historical management 

practices that did not promote overgrazing and extensive use of riparian areas. 

The 2009 surveys used past survey data and current aerial photography to 

refine the search areas. Pedestrian and vehicular reconnaissance was also 

used to search for suitable habitat. Potentially suitable habitat areas were 

documented using the global positioning system (GPS) and notes describing the 

habitat were taken during these reconnaissance surveys. 

Refer to Section G-6.5 for a description of the landscape and wetland areas 

identified within the general analysis area for the North Porcupine tract. 

Within the tract’s entire general analysis area, which is contained within the 

North Antelope Rochelle Mine’s existing permit area, there are approximately 

19.7 acres of jurisdictional wetlands and OWUS, including 10.2 acres of 

vegetated wetlands and 9.5 acres of pond and channel OWUS. 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 ephemeral stream channels and open water. Figure G-25, which was 

taken from North Antelope Rochelle Mine’s permit (PRC 2009), depicts the 

wetland areas mapped within the LBA tract’s general analysis area. 

The entire general analysis area for the North Porcupine tract has undergone 

one or more vegetation baseline studies conducted for amendments to the 

North Antelope Rochelle Mine permit. Vegetation studies were reported in 

1991, 1998, and 2001. No occurrence of the species was recorded in the 1991 

vegetation study. 

BKS Environmental Associates, Inc. (BKS) surveyed all areas of potentially 

suitable habitat on the federally owned lands (TBNG) within North Porcupine 

tract’s general analysis area along Porcupine Creek and its tributaries on 

September 1 and 6, 2005 and on August 11, 2009. On the TBNG, BKS 

surveyed all areas of potentially suitable habitat within the tract’s general 

analysis area along Holmes Creek on August 16, 2006 and on August 11, 

2009. On the TBNG, BKS surveyed all areas of potentially suitable habitat 

within the tract’s general analysis area along Trussler Creek on August 24, 

2006, August 26, 2007, and on August 11 and 13, 2009. The species was not 

observed during any of these surveys that were conducted on the TBNG. 

Special reconnaissance surveys for Ute ladies’-tresses were conducted by BKS 

in 1999, 2000, and 2009. The earlier surveys covered more than 73 percent of 

the North Porcupine tract’s general analysis area and included the entire reach 

of Porcupine Creek located within the tract’s general analysis area. As stated 

previously, the 2009 survey used information from past surveys and aerial 
28

33

21

16 15

22

27

34

14

23

26

35

13

2425

36

1819

30

31

17

2029

32

16

212833

15

22

2734

14

23

2635

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.

Gray

Creek

Draw

Butte

Creek

Creek

Porcupine

Boss

Creek

Corder

Creek

Porcupine

Black

Trussler

Creek

Creek

Holmes

Mouse Draw

Draw

Chipmunk

Draw

Rat

Draw Mike's

Draw

Payne

LEGEND

3000 6000 12000 0

GRAPHIC SCALE (FEET)

North Porcupine LBA Tract Wetlands

Analysis Area Boundary

Ephemeral Stream Channel

"Other Waters of U.S."Continuous/Nearly Continuous

Ephemeral Stream WetlandDiscontinuous Ephemeral Stream

Wetlands Intermingled With Upland Channel

"Other Waters of U.S."

Wetland or "Other Waters of U.S." at Stockpond,

Reservoir, Playa or Depression Wetland Mapping from North Antelope Rochelle Mine Permit,

Appendix D-10, Exhibit 1 (PRC 2004)

North Antelope Rochelle MinePermit BoundaryEphemeral Stream Channel

Figure G-25. Wetlands Within the General Analysis Area for the North Porcupine LBA Tract.

Appendix G

Final EIS, Wright Area Coal Lease Applications G-79
Appendix G 

G-80 Final EIS, Wright Area Coal Lease Applications

photography to best identify areas of potentially suitable habitat, and covered 

Porcupine Creek, Trussler Creek and Holmes Creek within the tract’s general 

analysis area. The surveyors noted during the 2009 survey that Porcupine 

Creek provided very little suitable habitat due to excessive saline/sodic soil 

conditions, few associated species were present, and the stream banks were 

quite abrupt. They also noted that various reaches of the stream do not have 

suitable habitat due to a lack of late season streamflow. No potential habitat 

for the species exists along Rat Draw (refer to Figure G-25) as the vegetation 

types found along that drainage are characteristic of uplands. No occurrences 

of the species were observed during any of these surveys. 

Several wetland surveys were conducted throughout the adjacent proposed 

School Creek Mine permit area in 2006, and the northeastern portion of the 

North Porcupine tract’s general analysis area was included in those surveys. 

No Ute ladies’-tresses were identified during any of those wetland delineations. 

Baseline studies for the proposed School Creek Mine also included special 

reconnaissance for Ute ladies’-tresses along the upper reaches of Trussler and 

Holmes creeks (refer to Figure G-25). Surveys were conducted by BKS along 

Trussler Creek in 2006, 2007, and 2009 and no areas of potentially suitable 

habitat or orchids were observed. Surveys were conducted by BKS along 

Holmes Creek in 2006 and 2009 and no areas of potentially suitable habitat 

and no occurrence of the species were observed. Both of these ephemeral 

drainages within the North Porcupine tract’s general analysis area are typically 

dry during the orchid’s flowering period. 

Surveys for Ute ladies’-tresses have also been conducted within North Antelope 

Rochelle Mine’s existing permit area in order to evaluate the potential effects of 

leasing federal coal reserves within that area on the federally listed species. 

For example, the North Porcupine tract is contiguous to the NARO North LBA 

Tract, which was recently issued (2005) as a maintenance lease to the mine. 

The North Porcupine tract is also contiguous to the Powder River LBA Tract, 

which was issued as a maintenance lease to the North Antelope Rochelle Mine 

in 1998. The results of those surveys are included within the Final South 

Powder River Basin Coal EIS (BLM 2003) and the Final EIS for the Powder 

River Coal Lease Application (WYW136142) and Thundercloud Coal Lease 

Application (WYW`136458) (BLM 1998). (Note: Table 1-1 of this EIS lists the 

LBA tract names, the respective applicant mines, and the dates that each 

maintenance coal lease was issued in the Powder River Basin since 1992.) The 

potential suitable habitat within the study area for the NARO North LBA Tract 

was surveyed by BKS during the flowering period in August and September 

1997, in August 1999, and again in August 2000. No Ute ladies’-tresses were 

found during any of those surveys (BLM 1998 and 2003). 

In addition to the BAs that have been prepared to evaluate the potential effects 

of leasing federal coal tracts, BAs have also been prepared to address the 

potential effects to federally listed species by disturbing federal surface lands 

that are located inside the mine’s existing permit area but are outside the 

existing federal coal lease boundaries. Those BAs, which have been submitted 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-81 

to the appropriate land management agency (i.e., USFS), document the results 

of field surveys in those areas. No Ute ladies’-tresses were found during the 

2005-2007 Ute ladies’-tresses and BA surveys conducted by BKS in potentially 

suitable habitats on USFS lands within the North Porcupine tract’s general 

analysis area. 

In conclusion, all areas of potentially suitable habitat for Ute ladies’-tresses 

that exist along Porcupine Creek within the entire general analysis area for the 

North Porcupine tract have not yet been surveyed over three consecutive years, 

as recommended by the USFWS. As such, surveys covering the potentially 

suitable habitat areas within the tract’s entire general analysis area are 

scheduled during the species’ flowering period (mid-August to early September) 

in 2010 and 2011. 

G-7.1.2.6 South Porcupine 

The nearest known population of Ute ladies’-tresses to the South Porcupine 

LBA Tract is located on an unnamed tributary of Antelope Creek in northern 

Converse County, roughly 29 miles west of the tract. The South Porcupine 

tract is located entirely within the Horse Creek and Porcupine Creek 

watersheds, both of which are tributaries of Antelope Creek. No occurrences 

have been recorded in Campbell County, including the lands within the South 

Porcupine tract’s general analysis area. 

The potentially suitable habitat within South Porcupine tract’s general analysis 

area is found along Mike’s Draw, a tributary of Porcupine Creek. Mike’s Draw 

is classified as an ephemeral stream, although surface discharge of 

groundwater associated with local CBNG development, which is a relatively 

recent phenomenon, has resulted in more persistent streamflow and generally 

wetter conditions within and immediately adjacent to the stream channel 

throughout the year. Increased bank storage and subsurface lateral water flow 

has improved the potential for suitable Ute ladies’-tresses habitat along 

portions of the drainage. 

Prior to conducting field surveys, topographical and wetland delineation maps 

were reviewed to identify all areas of potentially suitable habitat where the 

species may occur. Suitable habitat factors included less steep stream banks, 

light soil texture and well drained soils, close lateral or vertical distance to a 

perennial water source during the flowering period, lack of plant competition, 

lack of general soil alkalinity/salinity, and current or historical management 

practices that did not promote overgrazing and extensive use of riparian areas. 

The 2009 surveys used past survey data and current aerial photography to 

refine the search areas. Pedestrian and vehicular reconnaissance was also 

used to search for suitable habitat. Potentially suitable habitat areas were 

documented using GPS and notes describing the habitat were taken during 

these reconnaissance surveys. 
Appendix G 

G-82 Final EIS, Wright Area Coal Lease Applications

Refer to Section G-6.6 for a description of the landscape and wetland areas 

identified within the general analysis area for the South Porcupine tract. 

Within the tract’s entire general analysis area there are an estimated 12.3 

acres of jurisdictional wetlands and OWUS, including 7.2 acres of vegetated 

wetlands and 5.1 acres of pond and channel OWUS. There are also 

approximately 0.2 wetland acres of non-jurisdictional playa/depressional 

features. The vegetated wetland areas consist primarily of palustrine emergent 

herbaceous wet meadow or marsh along ephemeral stream channels. Figure 

G-26, which was taken from North Antelope Rochelle Mine’s permit (PRC 

2009), depicts the wetlands mapped within the LBA tract’s general analysis 

area. 

The entire general analysis area for the South Porcupine tract has undergone 

one or more vegetation baseline studies conducted for amendments to the 

North Antelope Rochelle Mine permit. Vegetation studies were reported in 

1991, 1998, and 2001. No occurrence of the species was recorded in the 1991 

vegetation study. 

BKS surveyed all areas of potentially suitable habitat along Mike’s Draw on 

September 1 and 6, 2005 and on August 12, 2009. Potentially suitable habitat 

areas were documented using the global positioning system (GPS) and notes 

describing the habitat were taken during these pedestrian surveys. Past 

survey data and aerial photography were used to refine the search areas for the 

2009 survey. Correspondence with USFS personnel confirmed that the 

hydrology of Mike’s Draw has been affected by water discharged by local CBNG 

production. The habitat along Mike’s Draw was considered to be marginally 

suitable for Ute ladies’-tresses in 2005; however, during the 2009 survey of the 

drainage no surface water was present, the saturation level was greater than 

18 inches below ground level, and the habitat was found to be poor to nonexistent. A CBNG discharge outfall point was noted along the drainage but it 

appeared to no longer be discharging. No orchids were observed during any of 

these surveys. 

Surveys for Ute ladies’-tresses have also been conducted within North Antelope 

Rochelle Mine’s existing permit area in order to evaluate the potential effects of 

leasing federal coal reserves within that area on the federally listed species. 

For example, the South Porcupine tract is contiguous to the NARO North and 

NARO South LBA Tracts, which were recently issued (2005 and 2004, 

respectively) as maintenance leases to the mine. The South Porcupine tract is 

also contiguous to the Powder River LBA Tract, which was issued as a 

maintenance lease to the North Antelope Rochelle Mine in 1998. The results of 

those surveys are included within the Final South Powder River Basin Coal EIS 

(BLM 2003) and the Final EIS for the Powder River Coal Lease Application 

(WYW136142) and Thundercloud Coal Lease Application (WYW`136458) (BLM 

1998). (Note: Table 1-1 of this EIS lists the LBA tract names, the respective 

applicant mines, and the dates that each maintenance coal lease was issued in 

the Powder River Basin since 1992.) The potential suitable habitat within the 

study area for the NARO North and NARO South LBA Tracts was surveyed by 
33

28

21

34

27

22

35

26

23

36

25

24

31

30

19

32

29

20

33

28

21

31

30

19

18

7

6

32

29

20

17

8

5

33

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

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.

Draw

Creek

Porcupine

Boss

Creek

Corder

Creek

Antelope

Creek

Horse

Porcupine

Creek

Draw

Mike's

Draw Roger's

Draw

Eagle

Draw

Redtail

Draw

Chyr

0 3000 6000 12000

GRAPHIC SCALE (FEET)

LEGEND

South Porcupine LBA Tract

Wetlands Analysis Area Boundary

Wetland or "Other Waters of U.S."

at Stockpond or Reservoir

Continuous/Nearly Continuous

Ephemeral Stream Wetland

Ephemeral Stream Channel

"Other Waters of U.S."

Wetland Mapping from

North Antelope Rochelle Mine Permit,

Appendix D-10, Exhibit 1 (PRC 2004)

North Antelope Rochelle Mine

Permit Boundary

Ephemeral Stream Channel

Figure G-26. Wetlands Within the General Analysis Area for the South Porcupine LBA Tract.

Appendix G

Final EIS, Wright Area Coal Lease Applications G-83
Appendix G 

G-84 Final EIS, Wright Area Coal Lease Applications

BKS during the flowering period in August and September 1997, in August 

1999, and again in August 2000. No Ute ladies’-tresses were found during any 

of those surveys (BLM 1998 and 2003). 

In addition to the BAs that have been prepared to evaluate the potential effects 

of leasing federal coal tracts, BAs have also been prepared to address the 

potential effects to federally listed species by disturbing federal surface lands 

that are located inside the mine’s existing permit area but are outside the 

existing federal coal lease boundaries. Those BAs, which have been submitted 

to the appropriate land management agency (i.e., USFS), document the results 

of field surveys in those areas. No Ute ladies’-tresses were found during the 

2005-2007 Ute ladies’-tresses and BA surveys conducted by BKS in potentially 

suitable habitats on USFS lands within the South Porcupine tract’s general 

analysis area. 

In conclusion, all areas of potentially suitable habitat for Ute ladies’-tresses 

that exist along Mike’s Draw within the tract’s general analysis area have not 

yet been surveyed over three consecutive years, as recommended by the 

USFWS. As such, surveys covering the potentially suitable habitat areas 

within the tract’s entire general analysis area are scheduled during the species’ 

flowering period (mid-August to early September) in 2010 and 2011. 

G-7.2 Black-footed Ferret (Mustela nigripes) 

This species of ferret is currently one of the most endangered mammals in 

North America and was thought to be extinct until a small population was 

discovered near Meeteetse, Wyoming in September, 1981. Since then, 

successful captive breeding and reintroduction programs have released blackfooted ferrets back into the wild in several western and Great Plains states 

including Wyoming, Montana, South Dakota, Colorado, Utah, Arizona, Kansas 

and New Mexico. They have also been reintroduced at one site in Mexico and 

there are plans for the first reintroduction in Canada in the fall of 2009 

(BFFRIT 2009). 

The ESA defines an endangered species as any species which is in danger of 

extinction throughout all or a significant portion of its range. The black footed 

ferret was placed on the endangered species list in March, 1967 (USFWS 

2009e). 

G-7.2.1 Biology and Habitat Requirements 

Black-footed ferrets are a member of a large group of mammals known as 

mustelids, or musk-producing animals. There are three ferret species 

worldwide but the black-footed ferret is the only one indigenous to North 

America. Black-footed ferrets are primarily nocturnal, making direct 

observation difficult. Black-footed ferrets are highly specialized, obligate 

carnivores of the prairie dog (Cynomys spp.). They depend almost exclusively 

on prairie dogs for food and they also use prairie dog burrows for shelter, 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-85 

parturition, and raising young (Hillman and Clark 1980). Few ferrets have 

historically been recorded in locations away from prairie dog colonies. Ferrets 

produce one litter per year, typically giving birth to four or five kits. 

This species is thought to have historically inhabited a nearly contiguous 

matrix of prairie dog colonies spanning the short-grass prairies of the eastern 

and southern Rockies and the Great Plains of North America (Forrest et al. 

1985). Originally, the prairie dog ecosystem occupied 20 percent of the entire 

western rangeland, allowing ferrets to cover a large geographic range (BFFRIT 

2009). Since the early 1930s, numerous factors have led to substantial 

declines in prairie dog colonies in that region. Reductions in some states are 

estimated as high as 90 percent from formerly occupied colonies (Rose 1973, 

Tyler 1968). Conversion of grasslands to agricultural landscapes, eradication 

of prairie dogs, and diseases such as the plague and canine distemper have all 

combined to result in severe reductions in prairie dog colonies across the west, 

colonies which provided food, shelter, and habitat for black-footed ferrets. 

Today, less than 2 percent of their original geographic distribution remains. 

The black-footed ferret’s current status is a sign of its exclusive dependence on 

the dramatically impacted prairie dog ecosystem (BFFRIT 2009). 

Since 1991, federal and state agencies, in cooperation with private landowners, 

conservation groups, Native Americans, and the North American Zoo 

community have been actively reintroducing ferrets back into the wild from 

captive breeding facilities. There are currently 18 reintroduction sites located 

in eight states and one site in Mexico (BFFRIT 2009). Reintroduction efforts 

have successfully established one black-footed ferret population in Wyoming, 

which is located in the Shirley Basin area in the south-central portion of the 

state. Today, from the 18 individual ferrets that were captured from the last 

known wild population near Meeteetse between 1985 to 1987 to begin the 

captive breeding program, approximately 800 to 1,000 individuals now live in 

the wild. Between 150 to 240 young ferrets are being reintroduced into the 

wild each year (BFFRIT 2009). 

G-7.2.2 LBA Tracts Existing Environments 

Despite extensive ferret surveys throughout Wyoming, the last known wild 

black-footed ferret population was discovered near Meeteetse in 1981 (Miller et 

al. 1996). Those surveys included numerous USFWS-approved clearances for 

coal mining and other development in Wyoming’s PRB, as well as USFS surveys 

for ferrets on the neighboring TBNG. On February 2, 2004, the USFWS 

declared that surveys for black-footed ferrets were no longer required in blacktailed prairie dog colonies throughout Wyoming (USFWS 2004). There is no 

designated critical habitat for black-footed ferrets in either Campbell or 

Converse counties, Wyoming (USFWS 2008). 
Appendix G 

G-86 Final EIS, Wright Area Coal Lease Applications

G-7.2.2.1 North Hilight Field 

The Black Thunder Mine and North Hilight Field LBA Tract’s general analysis 

area are beyond the focus area for ferret reintroduction efforts on the TBNG 

and elsewhere in the general region (USFS 2002b, Grenier 2003). 

While the general analysis area for the North Hilight Field LBA Tract and its 2-

mile wildlife study area (Figure G-15) harbor some small prairie dog colonies, 

black-footed ferrets have never been documented at the mine, nor the 

surrounding region, during surveys conducted over the last 30 plus years 

(1976 to present) by a variety of private, state, and federal entities. No blackfooted ferret observations or scat have ever been documented in this LBA 

tract’s wildlife study area. 

Currently, four black-tailed prairie dog colonies encompassing a total of 

approximately 53.8 non-contiguous acres are located within 2 miles of the 

North Hilight Field tract (Figure G-15). Of which, two colonies occur within the 

general analysis area itself and are approximately 3.4 and 19.5 acres in size. 

The other two colonies located in the surrounding 2-mile survey area are 

approximately 3.7 and 27.2 acres in size. All of these colonies were occupied 

during 2007. None of these four colonies within the 2-mile wildlife study area 

meet the 120-acre minimum threshold for supporting a breeding female ferret 

and her litter (Forrest et al. 1985) and none meet the 80-acre minimum 

requirement for black-footed ferret habitat (USFWS 1989). 

G-7.2.2.2 South Hilight Field 

The Black Thunder Mine and South Hilight Field LBA Tract’s general analysis 

area are beyond the focus area for ferret reintroduction efforts on the TBNG 

and elsewhere in the general region (USFS 2002b, Grenier 2003). 

While the general analysis area for the South Hilight Field LBA Tract and its 2-

mile wildlife study area (Figure G-16) harbor some small prairie dog colonies, 

black-footed ferrets have never been documented at the mine, nor the 

surrounding region, during surveys conducted over the last 30 plus years 

(1976 to present) by a variety of private, state, and federal entities. No blackfooted ferret observations or scat have ever been documented in this LBA 

tract’s wildlife study area. 

Currently, seven black-tailed prairie dog colonies encompassing a total of 

approximately 177.2 non-contiguous acres are located within 2 miles of the 

South Hilight Field tract (Figure G-16). Of which, just one colony occurs within 

the general analysis area itself and it is less than 1 acre in size. The other six 

colonies are located within or partially within the surrounding 2-mile survey 

area and range in size from approximately 2.0 to 89.1 acres. All of these 

colonies were occupied during 2007. None of these seven colonies within the 

2-mile wildlife study area meet the 120-acre minimum threshold for supporting 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-87 

a breeding female ferret and her litter (Forrest et al. 1985), and one colony does 

meet the 80-acre minimum requirement for black-footed ferret habitat (USFWS 

1989). 

G-7.2.2.3 West Hilight Field 

The Black Thunder Mine and West Hilight Field LBA Tract’s general analysis 

area are beyond the focus area for ferret reintroduction efforts on the TBNG 

and elsewhere in the general region (USFS 2002b, Grenier 2003). 

While the general analysis area for the West Hilight Field LBA Tract and its 2-

mile wildlife study area (Figure G-17) harbor some small prairie dog colonies, 

black-footed ferrets have never been documented at the mine, nor the 

surrounding region, during surveys conducted over the last 30 plus years 

(1976 to present) by a variety of private, state, and federal entities. No blackfooted ferret observations or scat have ever been documented in this LBA 

tract’s wildlife study area. 

Currently, eight black-tailed prairie dog colonies encompassing a total of 

approximately 167.5 non-contiguous acres are located within 2 miles of the 

West Hilight Field tract (Figure G-17). Of which, one colony occurs within the 

general analysis area itself and it is approximately 89.1 acres in size. The 

other seven colonies are located within the surrounding 2-mile survey area and 

range in size from approximately 0.1 to 27.2 acres. All of these colonies were 

occupied during 2007. None of these eight colonies within the 2-mile wildlife 

study area meet the 120-acre minimum threshold for supporting a breeding 

female ferret and her litter (Forrest et al. 1985). One colony does meet the 80-

acre minimum requirement for black-footed ferret habitat (USFWS 1989). 

G-7.2.2.4 West Jacobs Ranch 

The Jacobs Ranch Mine and West Jacobs Ranch LBA Tract’s general analysis 

area are beyond the focus area for ferret reintroduction efforts on the TBNG 

and elsewhere in the general region (USFS 2002b, Grenier 2003). 

While the general analysis area for the West Jacobs Ranch LBA Tract and its 2-

mile wildlife study area (Figure G-18) harbor some small prairie dog colonies, 

black-footed ferrets have never been documented at the mine, nor the 

surrounding region, during surveys conducted over the last 30 plus years 

(1976 to present) by a variety of private, state, and federal entities. No blackfooted ferret observations or scat have ever been documented in this LBA 

tract’s wildlife study area. 

Currently, six black-tailed prairie dog colonies encompassing a total of 

approximately 78.3 non-contiguous acres are located within 2 miles of the 

West Jacobs Ranch tract (Figure G-18). Of these, only one colony occurs 

within the general analysis area itself and is approximately 17.9 acres in size. 
Appendix G 

G-88 Final EIS, Wright Area Coal Lease Applications

The other five colonies located in the surrounding 2-mile survey area range in 

size from approximately 2.6 to 27.2 acres in size. All of these colonies were 

occupied during 2007. None of these six colonies within the 2-mile wildlife 

study area meet the 120-acre minimum threshold for supporting a breeding 

female ferret and her litter (Forrest et al. 1985) and none meet the 80-acre 

minimum requirement for black-footed ferret habitat (USFWS 1989). 

G-7.2.2.5 North Porcupine 

The North Antelope Rochelle Mine and North Porcupine LBA Tract’s general 

analysis area are beyond the focus area for ferret reintroduction efforts on the 

TBNG and elsewhere in the general region (USFS 2002b, Grenier 2003). 

While the general analysis area for the North Porcupine LBA Tract and its 2-

mile wildlife study area (Figure G-19) harbor some small prairie dog colonies, 

black-footed ferrets have never been documented at the mine, nor the 

surrounding region, during surveys conducted over the last 30 plus years 

(1976 to present) by a variety of private, state, and federal entities. No blackfooted ferret observations or scat have ever been documented in this LBA 

tract’s wildlife study area. 

Currently, 17 black-tailed prairie dog colonies encompassing a total of 

approximately 1,211.4 non-contiguous acres are located within 2 miles of the 

North Porcupine tract (Figure G-19). Of which, only one colony occurs within 

the general analysis area itself and it is approximately 18.6 acres in size. The 

other 16 colonies located in the surrounding 2-mile survey area range in size 

from approximately 1.5 to 345.3 acres in size. All of these colonies were 

occupied during 2007. Of these 17 colonies, the three largest in size meet the 

120-acre minimum threshold for supporting a breeding female ferret and her 

litter (Forrest et al. 1985) and the 80-acre minimum requirement for blackfooted ferret habitat (USFWS 1989). These three colonies are 228.9 acres, 

338.1 acres, and 345.3 acres in size. 

G-7.2.2.6 South Porcupine 

The North Antelope Rochelle Mine and South Porcupine LBA Tract’s general 

analysis area are beyond the focus area for ferret reintroduction efforts on the 

TBNG and elsewhere in the general region (USFS 2002b, Grenier 2003). 

While the general analysis area for the South Porcupine LBA Tract and its 2-

mile wildlife study area (Figure G-20) harbor some small prairie dog colonies, 

black-footed ferrets have never been documented at the mine, nor the 

surrounding region, during surveys conducted over the last 30 plus years 

(1976 to present) by a variety of private, state, and federal entities. No blackfooted ferret observations or scat have ever been documented in this LBA 

tract’s wildlife study area. 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-89 

Currently, 10 black-tailed prairie dog colonies encompassing a total of 

approximately 476.3 non-contiguous acres are located within 2 miles of the 

South Porcupine tract (Figure G-20). Of which, no colonies occur within the 

general analysis area itself. These 10 colonies are all located in the 

surrounding 2-mile survey area and range in size from approximately 1 acre to 

345.3 acres. All of these colonies were occupied during 2007. The largest 

colony is located within the wildlife survey area for both the North and South 

Porcupine tracts (Figures G-19 and G-20), and only this colony meets the 120-

acre minimum threshold for supporting a breeding female ferret and her litter 

(Forrest et al. 1985) and the 80-acre minimum requirement for black-footed 

ferret habitat (USFWS 1989). 

G-7.3 Blowout Penstemon (Penstemon haydenii) 

Blowout penstemon, a member of the Scrophulariaceae (Figwort) family, was 

listed under the ESA by the USFWS as endangered on October 1, 1987 and is 

one of Wyoming’s rarest native plants. The blowout penstemon was first 

discovered in the Nebraska Sandhills, where it was known in large numbers 

through 1914, but by the 1940s they had decreased dramatically (Heidel et al. 

2007). The plant was actually considered extinct by 1940 but was rediscovered 

in 1968 (Stubbendieck and Kottas 2007). This perennial herb was first 

discovered in Wyoming in 1877 in an area of prominent sand dunes located 

between Casper and Rawlins, and then rediscovered in the same general area 

by a BLM botanist in 1996 (Heidel et al. 2007). 

The blowout penstemon is a regional endemic species of the Sandhills of westcentral 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 near the Ferris and 

Seminoe Mountains located in the northwestern part of Carbon County (BLM 

2005). The three known populations are subdivided into at least eight 

subpopulations that occupy about 80 acres within five square miles (Fertig 

2001). Currently, several thousand individual plants make up the three 

Wyoming populations (Heidel et al. 2007). 

The ESA defines an endangered species as any species which is in danger of 

becoming extinct throughout all or a significant portion of its range. The 

blowout penstemon was listed as endangered due to a variety of factors 

including the small geographic range of existing plants, the possibility of 

localized droughts to severely impact entire populations, and habitat loss and 

modification (Stubbendieck and Kottas 2007). 

There is no designated critical habitat for blowout penstemon in Wyoming 

(USFWS 2008); however, USFWS approved a recovery plan in 1992 (Fritz et al. 

1992). At the time of the recovery plan’s publication, there were no known 

occurrences of the species in Wyoming. Therefore, the recovery plan focuses 

on habitat protection in Nebraska (BLM 2005). 
Appendix G 

G-90 Final EIS, Wright Area Coal Lease Applications

G-7.3.1 Biology and Habitat Requirements 

Blowout penstemon is a perennial herb that grows 1-2 feet high. Vegetative 

stems are usually less than 30 centimeters (12 inches) tall and have greenishglue, waxy, linear leaves. Flowering stems have narrow, linear leaves at the 

base, and broad, waxy leaves that taper to a narrow tip. The inflorescence is 6-

16 centimeters (2-6 inches) long and has six to ten compact leafy whorls of 

milky-blue to pale lavender flowers. The flowers are 1-11⁄2-inch long, arranged 

in clusters around a tall flowering stem and produce a faint, vanilla-like scent. 

Blowout penstemon begins spring growth in late March or early April from 

buds on the lower stems formed the previous year. Plants will typically bloom 

from late May through early July and set fruit in July and August. Individual 

plants are typically in bloom for 3-4 weeks (Stubbendieck and Kottas 2007). 

When in bloom in Wyoming in June and July, its blue or lavender flowers 

stand out against other sparse vegetation found in and around sandy 

blowouts. The flowers are typically cross-pollinated by many different insects, 

in including twenty-six species of solitary bees and one bee-like wasp, as well 

as beetles, ants, and butterflies (Stubbendieck and Kottas 2007 and Heidel et 

al. 2007). Once pollinated, the flowers ripen into 1⁄2-inch long capsule-like 

fruits, each containing twenty to thirty light-brown, disc-shaped seeds 

(Stubbendieck and Kottas 2007, BLM 2005, and University of Wyoming 2008). 

Mature fruits dry and split open by late August to September and seeds fall to 

the ground throughout the fall and winter. While some insects, birds and 

small mammals feed on the seeds, the rest are blown along the ground surface 

until they are covered with sand. Buried seeds remain viable and for natural 

seed germination to occur and for seedling roots to reach a depth where 

moisture is constantly available, blowout sand must remain damp for at least 

two weeks, conditions that do not occur every year (Stubbendieck and Kottas 

2007). Once a plant germinates, it can live for several years, but may not 

flower every year (Heidel et al. 2007). 

Blowout penstemon is a pioneer species, one of the first plants to establish 

itself, on sand dunes and sandy aprons (Heidel et al. 2007). The blowout 

penstemon’s habitat consists of sparsely vegetated, early successional, shifting 

sand dunes and blowout depressions created by wind erosion (Fertig 2001). 

The species is most common in the open, sandy habitats or wind-excavated 

depressions (crater-like blowouts) in dune tops. The plant is a primary invader 

that does not persist when a blowout becomes completely vegetated (BLM 

2005). Wind erosion is important in maintaining the open habitat required by 

blowout penstemon. The blowout community contains plants especially 

tolerant of disturbance caused by wind erosion as blowout sand is excavated 

and wind-driven (Stubbendieck and Kottas 2007). In Wyoming, blowout 

penstemon is found in sparsely vegetated sandy blowouts in the early stages of 

plant community development. On unstable, windward slopes, blowout 

penstemon is typically found with communities of blowout grass (Redfieldia 

flexuosa), lemon scurfpea (Psoralidium lanceolatum), and thickspike wheatgrass 

(Elymus lanceolatus) or Indian ricegrass (Achnatherum hymenoides) with less 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-91 

than 5 percent cover. Populations on more stable, lee slopes occur in similar 

communities with vegetative cover between 15 and 40 percent (BLM 2005). 

Shifting sand dunes are prevented from becoming fully stabilized and 

overgrown because of wind and gravity. The dunes may be 60 to 120 feet high 

on typically steep slopes at elevations between 5,800 and 7,500 feet. The 

absence of blowout penstemon from other active blowouts and gently 

undulating sand dune fields found in central and eastern Wyoming is likely 

due to a lack of soil moisture during the growing season and the stage in 

development of local plant communities (Heidel et al. 2007). 

G-7.3.2 LBA Tracts Existing Environments 

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. 

Fertig (2001) identified areas of potential habitat for blowout penstemon in 

Wyoming in the Killpecker Sand Dunes of north-central Sweetwater County, 

the Green Mountains in southeast Fremont County, the Sandhills in 

southwestern Carbon County, and the Ferris Mountain/Seminoe Mountain 

area in northern Carbon County (BLM 2005). There have been some extensive 

surveys in potential habitat recently that have not turned up any new 

populations (BLM 2005). No occurrences have been recorded in Campbell 

County, and there is no designated critical habitat for blowout penstemon in 

Wyoming (USFWS 2008). 

In order to determine if and where areas of suitable habitat for the species exist 

within each WAC LBA tract’s general analysis area, references were made to 

the published geologic maps and soil surveys that cover the general Wright 

analysis area. 

The Powder River Basin is underlain by the sedimentary deposits of the Eocene 

age Wasatch Formation, which consists mainly of soft shale, sandstone and 

coal beds, and most of these rocks weather to fine-grained, unconsolidated 

surficial material. The surface of the basin is largely covered by the residual, 

colluvial, and eolian (arranged by the wind) deposits derived from the Wasatch. 

The mode of transportation and deposition accounts for the position of these 

weathered materials. Wind, being the most prevalent mode of transportation in 

this area, accounts for the transport and deposition of most of the 

unconsolidated deposits, which are depicted on the U.S. Geological Survey’s 

Surficial Geologic Map of the Reno Junction 30’ × 60’ Quadrangle, Campbell and 

Weston Counties, Wyoming (Reheis and Coates 1987) as “eolian mix.” However, 

these areally extensive “eolian mix” deposits are predominantly very finegrained, silt- and clay-sized particles and are largely stabilized with vegetation. 

The Wyoming State Geological Survey’s Preliminary Geologic Map of the Reno 

Junction 30’ × 60’ Quadrangle, Campbell and Weston Counties, Wyoming (Ver 

Ploeg and Boyd 2003) is more specific and depicts “windblown sand” deposits, 

which are described as “loose particles of quartz, mainly from poorly lithified 
Appendix G 

G-92 Final EIS, Wright Area Coal Lease Applications

outcrops of Wasatch Formation, and silt deposited in dunes and sheets 

downwind from sources areas.” 

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 in the general Wright analysis area were noted: 1) those soils developing 

predominantly in thin residuum from sandstone or shale on upland ridges, 2) 

those soils developing predominantly in slopewash, colluvium, or alluvial fan 

deposits from mixed sources on gently sloping uplands, 3) those soils 

developing predominantly in coarse-textured alluvium or sandy eolian deposits 

on rolling uplands, and 4) drainage soils developing in mixed stream laid 

alluvium on terraces and channels and in fine-textured playa deposits in 

depressions and closed basins. The major soils series encountered during the 

soils surveys were grouped according to these four primary soil formation 

processes. Refer to Section 3.8 in this EIS for a description of the soils surveys 

covering the six WAC LBA tracts’ general analysis areas. 

The results of the suitable habitat evaluations for each WAC LBA tract are 

included within the following subsections. 

G-7.3.2.1 North Hilight Field 

Geologic mapping by Ver Ploeg and Boyd (2003) indicates that two separate 

areas of windblown sand deposits totaling less than 100 acres in size are 

present at the north-central and northeastern edge of the tract’s general 

analysis area (Figure G-27). Of the 17 soil series that were mapped within the 

coarse-textured alluvium or sandy eolian deposits on rolling uplands, one (the 

“Keeline-Tullock loamy sands”) is associated with soil textures that are 

predominantly sand. No active, shifting sand dune features were mapped 

during the soils surveys. The windblown sand deposits and sandy soils that 

are present are stabilized with vegetation. No areas of potentially suitable 

habitat for the blowout penstemon (sparsely vegetated, early successional, 

shifting sand dunes and blowout depressions) have been identified within the 

tract’s general analysis area. 

No blowout penstemon or plants commonly associated with the species 

(blowout grass, lemon scurfpea and thickspike wheatgrass) were found during 

the vegetation survey that was conducted in 2007 by Habitat Management, Inc. 

G-7.3.2.2 South Hilight Field 

Geologic mapping by Ver Ploeg and Boyd (2003) indicates that there are no 

areas of windblown sand deposits present within the tract’s general analysis 

area (Figure G-27). Of the eight soil series that were mapped within the coarsetextured alluvium or sandy eolian deposits on rolling uplands, none are 

associated with soil textures that are predominantly sand, but rather, they are 

described as sandy loams. No active, shifting sand dune features were mapped 
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.

Road Jacobs

Edwards

Matheson Road

Reno Road

Hilight Road

Keeline Road

Keeline

Road

State

450 Highway

Road

BNSF & UP RR

Antelope

Road

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

31

30

19

18

7

32

29

20

17

8

33

28

21

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9

34

27

22

15

10

35

26

23

14

11

36

25

24

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12

31

30

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18

7

6

32

29

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17

8

5

33

28

21

16

9

4

34

27

22

15

10

3

35

26

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14

11

2

36

25

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12

1

31

30

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18

7

6

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29

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8

5

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4

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30

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4

10

3

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7

6

8

5

9

4

10

3

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12

1

7

6

R70WR69W

R70W R69W

31

6

School Creek

Road

WINDBLOWN

SAND DEPOSITS

SCALE: 1"=10,000'

West Hilight Field LBA

Tract as Applied for

South Hilight Field LBA

Tract as Applied for

West Jacobs Ranch LBA

Tract as Applied for

North Hilight Field LBA

Tract as Applied for

West Hilight Field LBA Tract

General Analysis Area

South Hilight Field LBA

Tract General Analysis Area

West Jacobs Ranch LBA Tract

General Analysis Area

North Hilight Field LBA Tract

General Analysis Area

Windblown Sand

LEGEND

Black Thunder Mine

Permit Boundary

Jacobs Ranch Mine

Permit Boundary

Figure G-27. Windblown Sand Deposits Within and Near the General Analysis Area for the North Hilight

Field, South Hilight Field, West Hilight Field, and West Jacobs Ranch LBA Tracts.

Appendix G

Final EIS, Wright Area Coal Lease Applications G-93
Appendix G 

G-94 Final EIS, Wright Area Coal Lease Applications

during the soils surveys. No areas of potentially suitable habitat for the 

blowout penstemon (sparsely vegetated, early successional, shifting sand 

dunes and blowout depressions) have been identified within the tract’s general 

analysis area. 

No blowout penstemon or plants commonly associated with the species 

(blowout grass, lemon scurfpea and thickspike wheatgrass) were found during 

the baseline vegetation survey that was conducted in 2007 by Habitat 

Management, Inc. 

G-7.3.2.3 West Hilight Field 

Geologic mapping by Ver Ploeg and Boyd (2003) indicates that there are no 

areas of windblown sand deposits present within the tract’s general analysis 

area (Figure G-27). Of the 10 soil series that were mapped within the coarsetextured alluvium or sandy eolian deposits on rolling uplands, one (the 

“Keeline-Tullock-Niobrara dry complex”) is associated with soil textures that 

are predominantly sand. No active, shifting sand dune features were mapped 

during the soils surveys. The sandy soils that are present are stabilized with 

vegetation. No areas of potentially suitable habitat for the blowout penstemon 

(sparsely vegetated, early successional, shifting sand dunes and blowout 

depressions) have been identified within the tract’s general analysis area. 

No blowout penstemon or plants commonly associated with the species 

(blowout grass, lemon scurfpea and thickspike wheatgrass) were found during 

the vegetation survey that was conducted in 2007 by Habitat Management, Inc. 

G-7.3.2.4 West Jacobs Ranch 

Geologic mapping by Ver Ploeg and Boyd (2003) indicates that there are no 

areas of windblown sand deposits present within the tract’s general analysis 

area (Figure G-27). Of the eight soil series that were mapped within the coarsetextured alluvium or sandy eolian deposits on rolling uplands, three (the 

“Keeline-Tullock loamy sands,” the “Keeline-Tullock-Niobrara dry complex,” 

and the “Orpha-Tullock loamy sands”) are associated with soil textures that are 

predominantly sand. No active, shifting sand dune features were mapped 

during the soils surveys. The sandy soils that are present are stabilized with 

vegetation. No areas of potentially suitable habitat for the blowout penstemon 

(sparsely vegetated, early successional, shifting sand dunes and blowout 

depressions) have been identified within the tract’s general analysis area. 

No blowout penstemon or plants commonly associated with the species 

(blowout grass, lemon scurfpea and thickspike wheatgrass) were found during 

the vegetation surveys that were conducted in 2007 and 2008 by 

Intermountain Resources. 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-95 

G-7.3.2.5 North Porcupine 

Geologic mapping by Ver Ploeg and Boyd (2003) indicates that there are no 

areas of windblown sand deposits present within the tract’s general analysis 

area (Figure G-28). Of the 19 soil series that were mapped within the coarsetextured alluvium or sandy eolian deposits on rolling uplands, three (the 

“Keeline-Tullock-Niobrara complex,” the “Keeline loamy sands,” and the 

“Tullock loamy sands”) are associated with soil textures that are predominantly 

sand. No active, shifting sand dune features were mapped during the soils 

surveys. The sandy soils that are present are stabilized with vegetation. No 

areas of potentially suitable habitat for the blowout penstemon (sparsely 

vegetated, early successional, shifting sand dunes and blowout depressions) 

have been identified within the tract’s general analysis area. 

No blowout penstemon or plants commonly associated with the species 

(blowout grass, lemon scurfpea and thickspike wheatgrass) were found during 

the vegetation surveys that were conducted in 2008 by BKS Environmental 

Associates, Inc., or the previous vegetation mapping done in accordance with 

the WDEQ/LQD mine permitting requirements on the portion of the tract’s 

general analysis area that lies within the North Antelope Rochelle Mine’s 

current mine permit area. 

G-7.3.2.6 South Porcupine 

Geologic mapping by Ver Ploeg and Boyd (2003) indicates that there are no 

areas of windblown sand deposits present within the tract’s general analysis 

area (Figure G-28). Of the 19 soil series that were mapped within the coarsetextured alluvium or sandy eolian deposits on rolling uplands, three (the 

“Keeline-Tullock-Niobrara complex,” the “Keeline loamy sands,” and the 

“Tullock loamy sands”) are associated with soil textures that are predominantly 

sand. No active, shifting sand dune features were mapped during the soils 

surveys. The sandy soils that are present are stabilized with vegetation. No 

areas of potentially suitable habitat for the blowout penstemon (sparsely 

vegetated, early successional, shifting sand dunes and blowout depressions) 

have been identified within the tract’s general analysis area. 

No blowout penstemon or plants commonly associated with the species 

(blowout grass, lemon scurfpea and thickspike wheatgrass) were found during 

the vegetation surveys that were conducted in 2008 by BKS Environmental 

Associates, Inc., or the previous vegetation mapping done in accordance with 

the WDEQ/LQD mine permitting requirements on the portion of the tract’s 

general analysis area that lies within the North Antelope Rochelle Mine’s 

current mine permit area. 
T.

42

N.

T.

41

N.

R. 71 W. R. 70 W.

Reno Road

Mackey

Antelope Road

Road

BNSF & UP RR

Antelope Road

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

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26

23

14

11

36

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24

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12

31

30

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18

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29

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17

8

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30

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18

7

6

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29

20

17

8

5

31

30

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18

7

6

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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

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12

1

33

28

21

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9

4

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27

22

15

10

3

35

26

23

14

11

2

36

25

24

13

12

1

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7

6

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8

5

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9

4

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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

R. 70 W. R. 69 W.

WINDBLOWN

SAND DEPOSITS

T.

41

N.

T.

40

N.

T.

42

N.

T.

41

N.

T.

41

N.

T.

40

N.

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

BNSF & UP RR

SCALE: 1"=10,000'

North Porcupine LBA

Tract as Applied for

North Antelope

Rochelle Mine Permit

Boundary

South Porcupine LBA Tract

General Analysis Area

North Porcupine LBA Tract

Windblown Sand General Analysis Area

LEGEND

South Porcupine LBA

Tract as Applied for

Figure G-28. Windblown Sand Deposits Within and Near the General Analysis Area for the North Porcupine

and South Porcupine LBA Tracts.

Appendix G

G-96 Final EIS, Wright Area Coal Lease Applications
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-97 

G-8.0 DIRECT AND INDIRECT IMPACTS OF THE PROPOSED ACTIONS 

AND ALTERNATIVES 

The following subsections evaluate the direct and indirect impacts of BLM’s 

Proposed Action and Preferred Alternative with respect to each WAC LBA tract 

on the Ute ladies’-tresses, the black-footed ferret, and the blowout penstemon. 

As stated in Section G-1.1 above, the LBA tracts that are offered for lease 

would be subject to standard and special lease stipulations (which are listed in 

Appendix D of this EIS) that would be attached by BLM to the lease. As stated 

in the special stipulation developed for T&E, candidate, or other special status 

plant and animal species: “... the Authorized Officer may require modifications 

to, or disapprove a proposed activity that is likely to result in jeopardy to the 

continued existence of a proposed or listed T&E species, or result in the 

destruction or adverse modification of designated or proposed critical habitat.” 

Furthermore, “... the lessee shall comply with instructions from the Authorized 

Officer of the Office of Surface Mining Reclamation and Enforcement, or his 

designated representative, for all ground disturbing activities taking place within 

an approved mining and reclamation permit area or associated with such a 

permit.”

For the WAC LBA tracts that include National Forest System Lands, USFS will 

also attach special stipulations to the leases (which are listed in Appendix D of 

this EIS). With respect to T&E species, USFS is responsible for assuring that 

the leased land is examined prior to surface disturbance activities to determine 

effects upon any T&E plant or animal species or their habitats. “The findings of 

this examination may result in some restriction to the operator’s plan or even 

disallow use and occupancy that would be in violation to the ESA by 

detrimentally affecting T&E species or their habitats.”

G-8.1 Ute Ladies’-tresses 

Potentially suitable habitats for this species are very limited in the general 

Wright analysis area. This species has never been documented to occur in this 

area and the likelihood of it occurring is low due to the following reasons: 1) 

this area is typical of the semi-arid high plains and there are no perennial 

streams present, 2) very few moist riparian meadow areas are present, and 3) 

the transition between the narrow riparian strips along stream, reservoir and 

playa margins and the upland vegetation is abrupt. 

G-8.1.1 North Hilight Field 

Under the Proposed Action for the North Hilight Field LBA Tract, up to 5,053.0 

acres would be disturbed by surface coal mining operations over a period of 2.0 

years. Under Alternative 2, BLM’s Preferred Alternative, for the North Hilight 

Field LBA Tract, up to 12,908.8 acres would be disturbed by surface coal 

mining operations over a period of 4.8 years. Although the total disturbance 
Appendix G 

G-98 Final EIS, Wright Area Coal Lease Applications

acreage is known, the distribution of this disturbance will not be known until 

site-specific mine and reclamation plans have been determined. 

Direct effects of mining would be the removal of any potentially suitable habitat 

areas that are located within the mine’s disturbance limits. Indirect effects of 

mining would be associated primarily with hydrological changes resulting from 

the alteration of natural stream flows and dynamics that could affect other 

nearby favorable orchid habitat conditions and/or unknown populations. If 

there are any unknown occurrences within and near the general Wright 

analysis area that would not be directly impacted by surface disturbance, dust 

from mining activities could affect those plants by reducing their vigor and 

reproduction capability. General habitat fragmentation would occur, which 

may result in effects to pollinators and disruption of seed dispersal. 

Livestock grazing is currently the primary land use, while oil and gas 

production and recreation are secondary land uses. As such, roughly 3 

percent of the LBA tract’s general analysis area is presently disturbed by roads, 

areas surrounding active construction sites, ranching-related facilities, oil and 

gas well sites, and oil and gas production-related facilities. Several reservoirs 

recently constructed for containment of CBNG discharge water are also 

present. 

No Ute ladies’-tresses have been recorded within the LBA tract’s general 

analysis area or the adjacent mine permit areas to date. It is unlikely that 

orchid populations would remain undetected during multiple surveys over 

multiple consecutive years, if they are present in the area. Nonetheless, if 

undetected populations are present on the potentially suitable habitat in the 

general analysis area, they would be lost due to surface disturbing activities. 

Given the presence of potentially suitable habitat within the tract’s general 

analysis area, there is a slight chance of impacts due to the low likelihood of it 

occurring. 

G-8.1.2 South Hilight Field 

Under the Proposed Action for the South Hilight Field LBA Tract, up to 1,126.0 

acres would be disturbed by surface coal mining operations over a period of 1.6 

years. Under Alternative 2, BLM’s Preferred Alternative, for the South Hilight 

Field LBA Tract, up to 2,731.4 acres would be disturbed by surface coal mining 

operations over a period of 2.3 years. Although the total disturbance acreage is 

known, the distribution of this disturbance will not be known until site-specific 

mine and reclamation plans have been determined. 

Direct effects of mining would be the removal of any potentially suitable habitat 

areas that are located within the mine’s disturbance limits. Indirect effects of 

mining would be associated primarily with hydrological changes resulting from 

the alteration of natural stream flows and dynamics that could affect other 

nearby favorable orchid habitat conditions and/or unknown populations. If 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-99 

there are any unknown occurrences within and near the general Wright 

analysis area that would not be directly impacted by surface disturbance, dust 

from mining activities could affect those plants by reducing their vigor and 

reproduction capability. General habitat fragmentation would occur, which 

may result in effects to pollinators and disruption of seed dispersal. 

Livestock grazing is currently the primary land use, while oil and gas 

production and recreation are secondary land uses. As such, roughly 7.5 

percent of the LBA tract’s general analysis area is presently disturbed by roads, 

areas surrounding active construction sites, ranching-related facilities, oil and 

gas well sites, and oil and gas production-related facilities. Several reservoirs 

recently constructed for containment of CBNG discharge water are also 

present. 

No Ute ladies’-tresses have been recorded within the LBA tract’s general 

analysis area or the adjacent mine permit areas to date. It is unlikely that 

orchid populations would remain undetected during multiple surveys over 

multiple consecutive years, if they are present in the area. Nonetheless, if 

undetected populations are present on the potentially suitable habitat in the 

general analysis area, they would be lost due to surface disturbing activities. 

Given the presence of potentially suitable habitat within the tract’s general 

analysis area, there is a slight chance of impacts due to the low likelihood of it 

occurring. 

G-8.1.3 West Hilight Field 

Under the Proposed Action for the West Hilight Field LBA Tract, up to 6,351.4 

acres would be disturbed by surface coal mining operations over a period of 2.8 

years. Under Alternatives 2 and 3 (Alternative 2 is BLM’s Preferred Alternative) 

for the West Hilight Field LBA Tract, up to 10,250.8 acres would be disturbed 

by surface coal mining operations over a period of 7.1 years. Although the total 

disturbance acreage is known, the distribution of this disturbance will not be 

known until site-specific mine and reclamation plans have been determined. 

Direct effects of mining would be the removal of any potentially suitable habitat 

areas that are located within the mine’s disturbance limits. Indirect effects of 

mining would be associated primarily with hydrological changes resulting from 

the alteration of natural stream flows and dynamics that could affect other 

nearby favorable orchid habitat conditions and/or unknown populations. If 

there are any unknown occurrences within and near the general Wright 

analysis area that would not be directly impacted by surface disturbance, dust 

from mining activities could affect those plants by reducing their vigor and 

reproduction capability. General habitat fragmentation would occur, which 

may result in effects to pollinators and disruption of seed dispersal. 

Livestock grazing is currently the primary land use, while oil and gas 

production and recreation are secondary land uses. As such, roughly 2.0 
Appendix G 

G-100 Final EIS, Wright Area Coal Lease Applications

percent of the LBA tract’s general analysis area is presently disturbed by roads, 

areas surrounding active construction sites, ranching-related facilities, oil and 

gas well sites, and oil and gas production-related facilities. Several reservoirs 

recently constructed for containment of CBNG discharge water are also 

present. 

No Ute ladies’-tresses have been recorded within the LBA tract’s general 

analysis area or the adjacent mine permit areas to date. It is unlikely that 

orchid populations would remain undetected during multiple surveys over 

multiple consecutive years, if they are present in the area. Nonetheless, if 

undetected populations are present on the potentially suitable habitat in the 

general analysis area, they would be lost due to surface disturbing activities. 

Given the presence of potentially suitable habitat within the tract’s general 

analysis area, there is a slight chance of impacts due to the low likelihood of it 

occurring. 

G-8.1.4 West Jacobs Ranch 

Under the Proposed Action for the West Jacobs Ranch LBA Tract, up to 7,023.0 

acres would be disturbed by surface coal mining operations over a period of 

16.7 years. Under Alternative 2, BLM’s Preferred Alternative, for the West 

Jacobs Ranch LBA Tract, up to 9,370.0 acres would be disturbed by surface 

coal mining operations over a period of 22.8 years. Although the total 

disturbance acreage is known, the distribution of this disturbance will not be 

known until site-specific mine and reclamation plans have been determined. 

Direct effects of mining would be the removal of any potentially suitable habitat 

areas that are located within the mine’s disturbance limits. Indirect effects of 

mining would be associated primarily with hydrological changes resulting from 

the alteration of natural stream flows and dynamics that could affect other 

nearby favorable orchid habitat conditions and/or unknown populations. If 

there are any unknown occurrences within and near the general Wright 

analysis area that would not be directly impacted by surface disturbance, dust 

from mining activities could affect those plants by reducing their vigor and 

reproduction capability. General habitat fragmentation would occur, which 

may result in effects to pollinators and disruption of seed dispersal. 

Livestock grazing is currently the primary land use, while oil and gas 

production and recreation are secondary land uses. As such, roughly 1.6 

percent of the LBA tract’s general analysis area is presently disturbed by roads, 

areas surrounding active construction sites, ranching-related facilities, oil and 

gas well sites, and oil and gas production-related facilities. Several reservoirs 

recently constructed for containment of CBNG discharge water are also 

present. 

No Ute ladies’-tresses have been recorded within the LBA tract’s general 

analysis area or the adjacent mine permit areas to date. It is unlikely that 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-101 

orchid populations would remain undetected during multiple surveys over 

multiple consecutive years, if they are present in the area. Nonetheless, if 

undetected populations are present on the potentially suitable habitat in the 

general analysis area, they would be lost due to surface disturbing activities. 

Given the presence of potentially suitable habitat within the tract’s general 

analysis area, there is a slight chance of impacts due to the low likelihood of it 

occurring. 

G-8.1.5 North Porcupine 

Under the Proposed Action for the North Porcupine LBA Tract, up to 9,864.0 

acres would be disturbed by surface coal mining operations over a period of 6.3 

years. Under Alternative 2, BLM’s Preferred Alternative, for the North 

Porcupine LBA Tract, up to 11,444.0 acres would be disturbed by surface coal 

mining operations over a period of 7.8 years. Although the total disturbance 

acreage is known, the distribution of this disturbance will not be known until 

site-specific mine and reclamation plans have been determined. 

Direct effects of mining would be the removal of any potentially suitable habitat 

areas that are located within the mine’s disturbance limits. Indirect effects of 

mining would be associated primarily with hydrological changes resulting from 

the alteration of natural stream flows and dynamics that could affect other 

nearby favorable orchid habitat conditions and/or unknown populations. If 

there are any unknown occurrences within and near the general Wright 

analysis area that would not be directly impacted by surface disturbance, dust 

from mining activities could affect those plants by reducing their vigor and 

reproduction capability. General habitat fragmentation would occur, which 

may result in effects to pollinators and disruption of seed dispersal. 

Livestock grazing is currently the primary land use, while oil and gas 

production and recreation are secondary land uses. As such, roughly 0.8 

percent of the LBA tract’s general analysis area is presently disturbed by roads, 

areas surrounding active construction sites, ranching-related facilities, oil and 

gas well sites, and oil and gas production-related facilities. Several reservoirs 

recently constructed for containment of CBNG discharge water are also 

present. 

No Ute ladies’-tresses have been recorded within the LBA tract’s general 

analysis area or the adjacent mine permit areas to date. It is unlikely that 

orchid populations would remain undetected during multiple surveys over 

multiple consecutive years, if they are present in the area. Potentially suitable 

habitat for the species within the tract’s general analysis area is present only 

along portions of Porcupine Creek, which would be directly disturbed by 

mining. If undetected populations are present on the potentially suitable 

habitat in the general analysis area, they would be lost due to surface 

disturbing activities. 
Appendix G 

G-102 Final EIS, Wright Area Coal Lease Applications

Given the presence of potentially suitable habitat within the tract’s general 

analysis area, there is a slight chance of impacts due to the low likelihood of it 

occurring. 

G-8.1.6 South Porcupine 

Under the Proposed Action for the South Porcupine LBA Tract, up to 3,366.0 

acres would be disturbed by surface coal mining operations over a period of 3.3 

years. Under Alternative 2, BLM’s Preferred Alternative, for the South 

Porcupine LBA Tract, up to 4,068.0 acres would be disturbed by surface coal 

mining operations over a period of 3.6 years. Although the total disturbance 

acreage is known, the distribution of this disturbance will not be known until 

site-specific mine and reclamation plans have been determined. 

Direct effects of mining would be the removal of any potentially suitable habitat 

areas that are located within the mine’s disturbance limits. Indirect effects of 

mining would be associated primarily with hydrological changes resulting from 

the alteration of natural stream flows and dynamics that could affect other 

nearby favorable orchid habitat conditions and/or unknown populations. If 

there are any unknown occurrences within and near the general Wright 

analysis area that would not be directly impacted by surface disturbance, dust 

from mining activities could affect those plants by reducing their vigor and 

reproduction capability. General habitat fragmentation would occur, which 

may result in effects to pollinators and disruption of seed dispersal. 

Livestock grazing is currently the primary land use, while oil and gas 

production and recreation are secondary land uses. As such, roughly 0.6 

percent of the LBA tract’s general analysis area is presently disturbed by roads, 

areas surrounding active construction sites, ranching-related facilities, oil and 

gas well sites, and oil and gas production-related facilities. Several reservoirs 

recently constructed for containment of CBNG discharge water are also 

present. 

No Ute ladies’-tresses have been recorded within the LBA tract’s general 

analysis area or the adjacent mine permit areas to date. It is unlikely that 

orchid populations would remain undetected during multiple surveys over 

multiple consecutive years, if they are present in the area. Nonetheless, if 

undetected populations are present on the potentially suitable habitat in the 

general analysis area, they would be lost due to surface disturbing activities. 

There is limited potential habitat for this species on the tract, and it occurs 

only along portions of Mike’s Draw, an ephemeral tributary of Porcupine Creek. 

If the South Porcupine tract is leased by BTU and proposed for mining, the 

North Antelope Rochelle Mine does not presently intend to mine through Mike’s 

Draw and the areas of potential habitat would therefore not be disturbed under 

the Proposed Action or Alternative 2. Outside of the narrow strip of riparian 

habitat located along this drainage, potential habitat throughout the balance of 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-103 

the LBA tract’s general analysis area is rare or non-existent so there is a very 

low likelihood of any impacts to potentially suitable habitat. 

G-8.2 Black-footed Ferret 

Potentially suitable habitat for this species is limited in the general Wright 

analysis area. Based on more than 30 years of prairie dog colony surveys and 

numerous surveys specifically for black-footed ferrets conducted according to 

USFWS guidelines (USFWS 1989), this species has never been documented to 

occur in this area and the likelihood of them occurring is extremely low. 

G-8.2.1 North Hilight Field 

Under the Proposed Action for the North Hilight Field LBA Tract, up to 5,053.0 

acres would be disturbed by surface coal mining operations over a period of 2.0 

years. Under Alternative 2, BLM’s Preferred Alternative, for the North Hilight 

Field LBA Tract, up to 12,908.8 acres would be disturbed by surface coal 

mining operations over a period of 4.8 years. Although the total disturbance 

acreage is known, the distribution of this disturbance will not be known until 

site-specific mine and reclamation plans have been determined. Mine activities 

include, but are not limited to, large-scale topsoil stripping, the intense 

presence of heavy machinery, extended human presence, loud noise and 

various linear disturbances such as roads, power lines and fences. 

Two separate black-tailed prairie dog colonies of 3.4 and 19.5 acres in size, 

which were within the tract’s general analysis area and occupied in 2007, 

would be directly affected by mining activities. Two other separate black-tailed 

prairie dog colonies of 3.7 and 27.2 acres in size, which were within the 

surrounding 2-mile survey area and occupied in 2007, would likely be 

indirectly affected by mining activities. 

Based on more than 30 years of historic and recent survey efforts and other 

general analysis area data and information, it is unlikely that ferrets exist in 

the North Hilight Field tract general analysis area or surrounding wildlife 

survey area. Given the documented absence of black-footed ferrets in the 

region, including the North Hilight Field LBA Tract, the lack of sizeable, 

contiguous prairie dog colonies within the LBA tract and surrounding areas, 

the block clearance issued by USFWS for black-tailed prairie dog colonies 

throughout the entire state, and the distance of the LBA area from future 

reintroduction sites, mining the general analysis area for the North Hilight 

Field LBA Tract would not result in any direct or indirect effects on blackfooted ferrets. 

G-8.2.2 South Hilight Field 

Under the Proposed Action for the South Hilight Field LBA Tract, up to 1,126.0 

acres would be disturbed by surface coal mining operations over a period of 1.6 

years. Under Alternative 2, BLM’s Preferred Alternative, for the South Hilight 
Appendix G 

G-104 Final EIS, Wright Area Coal Lease Applications

Field LBA Tract, up to 2,731.4 acres would be disturbed by surface coal mining 

operations over a period of 2.3 years. Although the total disturbance acreage is 

known, the distribution of this disturbance will not be known until site-specific 

mine and reclamation plans have been determined. Mine activities include, 

but are not limited to, large-scale topsoil stripping, the intense presence of 

heavy machinery, extended human presence, loud noise and various linear 

disturbances such as roads, power lines and fences. 

Just one black-tailed prairie dog colony of less than 1.0 acre in size, which was 

within the tract’s general analysis area and occupied in 2007, would be directly 

affected by mining activities. Six other separate black-tailed prairie dog 

colonies of approximately 2.0 to 89.1 acres in size, which were within the 

surrounding 2-mile survey area and occupied in 2007, would likely be 

indirectly affected by mining activities. 

Based on more than 30 years of historic and recent survey efforts and other 

general analysis area data and information, it is unlikely that ferrets exist in 

the South Hilight Field tract’s general analysis area or surrounding wildlife 

survey area. Given the documented absence of black-footed ferrets in the 

region, including the South Hilight Field LBA Tract, the lack of sizeable, 

contiguous prairie dog colonies within the LBA tract and surrounding areas, 

the block clearance issued by USFWS for black-tailed prairie dog colonies 

throughout the entire state, and the distance of the LBA area from future 

reintroduction sites, mining the general analysis area for the South Hilight 

Field LBA Tract would not result in any direct or indirect effects on blackfooted ferrets. 

G-8.2.3 West Hilight Field 

Under the Proposed Action for the West Hilight Field LBA Tract, up to 6,351.4 

acres would be disturbed by surface coal mining operations over a period of 2.8 

years. Under Alternatives 2 and 3 (Alternative 2 is BLM’s Preferred Alternative) 

for the West Hilight Field LBA Tract, up to 10,250.8 acres would be disturbed 

by surface coal mining operations over a period of 7.1 years. Although the total 

disturbance acreage is known, the distribution of this disturbance will not be 

known until site-specific mine and reclamation plans have been determined. 

Mine activities include, but are not limited to, large-scale topsoil stripping, the 

intense presence of heavy machinery, extended human presence, loud noise 

and various linear disturbances such as roads, power lines and fences. 

Just one black-tailed prairie dog colony of approximately 89.1 acres in size, 

which was within the tract’s general analysis area and occupied in 2007, would 

be directly affected by mining activities. Seven other separate black-tailed 

prairie dog colonies of approximately 0.1 to 27.2 acres in size, which were 

within the surrounding 2-mile survey area and occupied in 2007, would likely 

be indirectly affected by mining activities. 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-105 

Based on more than 30 years of historic and recent survey efforts and other 

general analysis area data and information, it is unlikely that ferrets exist in 

the West Hilight Field tract general analysis area or surrounding wildlife survey 

area. Given the documented absence of black-footed ferrets in the region, 

including the West Hilight Field LBA Tract, the lack of sizeable, contiguous 

prairie dog colonies within the LBA tract and surrounding areas, the block 

clearance issued by USFWS for black-tailed prairie dog colonies throughout the 

entire state, and the distance of the LBA area from future reintroduction sites, 

mining the general analysis area for the West Hilight Field LBA Tract would 

have no effect on black-footed ferrets. 

G-8.2.4 West Jacobs Ranch 

Under the Proposed Action for the West Jacobs Ranch LBA Tract, up to 7,023.0 

acres would be disturbed by surface coal mining operations over a period of 

16.7 years. Under Alternative 2, BLM’s Preferred Alternative, for the West 

Jacobs Ranch LBA Tract, up to 9,370.0 acres would be disturbed by surface 

coal mining operations over a period of 22.8 years. Although the total 

disturbance acreage is known, the distribution of this disturbance will not be 

known until site-specific mine and reclamation plans have been determined. 

Mine activities include, but are not limited to, large-scale topsoil stripping, the 

intense presence of heavy machinery, extended human presence, loud noise 

and various linear disturbances such as roads, power lines and fences. 

Just one black-tailed prairie dog colony of approximately 17.9 acres in size, 

which was within the tract’s general analysis area and occupied in 2007, would 

be directly affected by mining activities. Five other separate black-tailed prairie 

dog colonies of approximately 2.6 to 27.2 acres in size, which were within the 

surrounding 2-mile survey area and occupied in 2007, would likely be 

indirectly affected by mining activities. 

Based on more than 30 years of historic and recent survey efforts and other 

general analysis area data and information, it is unlikely that ferrets exist in 

the West Jacobs Ranch tract general analysis area or surrounding wildlife 

survey area. Given the documented absence of black-footed ferrets in the 

region, including the West Jacobs Ranch LBA Tract, the lack of sizeable, 

contiguous prairie dog colonies within the LBA tract and surrounding areas, 

the block clearance issued by USFWS for black-tailed prairie dog colonies 

throughout the entire state, and the distance of the LBA area from future 

reintroduction sites, mining the general analysis area for the West Jacobs 

Ranch LBA Tract would not effect the black-footed ferret. 

G-8.2.5 North Porcupine 

Under the Proposed Action for the North Porcupine LBA Tract, up to 9,864.0 

acres would be disturbed by surface coal mining operations over a period of 6.3 

years. Under Alternative 2, BLM’s Preferred Alternative, for the North 

Porcupine LBA Tract, up to 11,444.0 acres would be disturbed by surface coal 
Appendix G 

G-106 Final EIS, Wright Area Coal Lease Applications

mining operations over a period of 7.8 years. Although the total disturbance 

acreage is known, the distribution of this disturbance will not be known until 

site-specific mine and reclamation plans have been determined. Mine activities 

include, but are not limited to, large-scale topsoil stripping, the intense 

presence of heavy machinery, extended human presence, loud noise and 

various linear disturbances such as roads, power lines and fences. 

Just one black-tailed prairie dog colony of approximately 18.6 acres in size, 

which was within the tract’s general analysis area and occupied in 2007, would 

be directly affected by mining activities. Sixteen other separate black-tailed 

prairie dog colonies of approximately 1.5 to 345.3 acres in size, which were 

within the surrounding 2-mile survey area and occupied in 2007, would likely 

be indirectly affected by mining activities. 

Based on more than 30 years of historic and recent survey efforts and other 

general analysis area data and information, it is unlikely that ferrets exist in 

the North Porcupine tract general analysis area or surrounding wildlife survey 

area. Given the documented absence of black-footed ferrets in the region, 

including the North Porcupine LBA Tract, the lack of sizeable, contiguous 

prairie dog colonies within the LBA tract and surrounding areas, the block 

clearance issued by USFWS for black-tailed prairie dog colonies throughout the 

entire state, and the distance of the LBA area from future reintroduction sites, 

mining the general analysis area for the North Porcupine LBA Tract would not 

result in any direct or indirect effects on black-footed ferrets. 

G-8.2.6 South Porcupine 

Under the Proposed Action for the South Porcupine LBA Tract, up to 3,366.0 

acres would be disturbed by surface coal mining operations over a period of 3.3 

years. Under Alternative 2, BLM’s Preferred Alternative, for the South 

Porcupine LBA Tract, up to 4,068.0 acres would be disturbed by surface coal 

mining operations over a period of 3.6 years. Although the total disturbance 

acreage is known, the distribution of this disturbance will not be known until 

site-specific mine and reclamation plans have been determined. Mine activities 

include, but are not limited to, large-scale topsoil stripping, the intense 

presence of heavy machinery, extended human presence, loud noise and 

various linear disturbances such as roads, power lines and fences. 

There were no occupied black-tailed prairie dog colonies within the tract’s 

general analysis area in 2007; therefore, no colonies would be directly affected 

by mining activities. Ten other separate black-tailed prairie dog colonies of 

approximately 1.0 to 345.3 acres in size, which were within the surrounding 2-

mile survey area and occupied in 2007, would likely be indirectly affected by 

mining activities. 

Based on more than 30 years of historic and recent survey efforts and other 

general analysis area data and information, it is unlikely that ferrets exist in 

the South Porcupine tract general analysis area or surrounding wildlife survey 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-107 

area. Given the documented absence of black-footed ferrets in the region, 

including the South Porcupine LBA Tract, the lack of sizeable, contiguous 

prairie dog colonies within the LBA tract and surrounding areas, the block 

clearance issued by USFWS for black-tailed prairie dog colonies throughout the 

entire state, and the distance of the LBA area from future reintroduction sites, 

mining the general analysis area for the South Porcupine LBA Tract would not 

result in any direct or indirect effects on black-footed ferrets. 

G-8.3 Blowout Penstemon 

In Wyoming, blowout penstemon is only known to occur in certain habitats 

south of the Ferris Mountains in the northern part of Carbon County. The 

suitable habitat evaluations for each of the WAC LBA tracts (section G-7.3.2) 

did not identify any areas of potentially suitable habitat for blowout 

penstemon. This species has never been documented to occur in this area and 

the likelihood of the plant occurring is extremely low. 

G-8.3.1 North Hilight Field 

Under the Proposed Action for the North Hilight Field LBA Tract, up to 5,053.0 

acres would be disturbed by surface coal mining operations over a period of 2.0 

years. Under Alternative 2, BLM’s Preferred Alternative, for the North Hilight 

Field LBA Tract, up to 12,908.8 acres would be disturbed by surface coal 

mining operations over a period of 4.8 years. Although the total disturbance 

acreage is known, the distribution of this disturbance will not be known until 

site-specific mine and reclamation plans have been determined. Mine activities 

include, but are not limited to, large-scale topsoil stripping, the intense 

presence of heavy machinery, extended human presence, loud noise and 

various linear disturbances such as roads, power lines and fences. 

No blowout penstemon have been recorded within the LBA tract’s general 

analysis area or the adjacent mine permit areas to date. Given the lack of any 

potentially suitable habitat within the LBA tract and surrounding areas and 

the documented absence of the species in the region, mining the general 

analysis area for the North Hilight Field LBA Tract would not result in any 

direct or indirect effects on blowout penstemon. 

G-8.3.2 South Hilight Field 

Under the Proposed Action for the South Hilight Field LBA Tract, up to 1,126.0 

acres would be disturbed by surface coal mining operations over a period of 1.6 

years. Under Alternative 2, BLM’s Preferred Alternative, for the South Hilight 

Field LBA Tract, up to 2,731.4 acres would be disturbed by surface coal mining 

operations over a period of 2.3 years. Although the total disturbance acreage is 

known, the distribution of this disturbance will not be known until site-specific 

mine and reclamation plans have been determined. Mine activities include, 

but are not limited to, large-scale topsoil stripping, the intense presence of 
Appendix G 

G-108 Final EIS, Wright Area Coal Lease Applications

heavy machinery, extended human presence, loud noise and various linear 

disturbances such as roads, power lines and fences. 

No blowout penstemon have been recorded within the LBA tract’s general 

analysis area or the adjacent mine permit areas to date. Given the lack of any 

potentially suitable habitat within the LBA tract and surrounding areas and 

the documented absence of the species in the region, mining the general 

analysis area for the South Hilight Field LBA Tract would not result in any 

direct or indirect effects on blowout penstemon. 

G-8.3.3 West Hilight Field 

Under the Proposed Action for the West Hilight Field LBA Tract, up to 6,351.4 

acres would be disturbed by surface coal mining operations over a period of 2.8 

years. Under Alternatives 2 and 3 (Alternative 2 is BLM’s Preferred Alternative) 

for the West Hilight Field LBA Tract, up to 10,250.8 acres would be disturbed 

by surface coal mining operations over a period of 7.1 years. Although the total 

disturbance acreage is known, the distribution of this disturbance will not be 

known until site-specific mine and reclamation plans have been determined. 

Mine activities include, but are not limited to, large-scale topsoil stripping, the 

intense presence of heavy machinery, extended human presence, loud noise 

and various linear disturbances such as roads, power lines and fences. 

No blowout penstemon have been recorded within the LBA tract’s general 

analysis area or the adjacent mine permit areas to date. Given the lack of any 

potentially suitable habitat within the LBA tract and surrounding areas and 

the documented absence of the species in the region, mining the general 

analysis area for the West Hilight Field LBA Tract would not result in any direct 

or indirect effects on blowout penstemon. 

G-8.3.4 West Jacobs Ranch 

Under the Proposed Action for the West Jacobs Ranch LBA Tract, up to 7,023.0 

acres would be disturbed by surface coal mining operations over a period of 

16.7 years. Under Alternative 2, BLM’s Preferred Alternative, for the West 

Jacobs Ranch LBA Tract, up to 9,370.0 acres would be disturbed by surface 

coal mining operations over a period of 22.8 years. Although the total 

disturbance acreage is known, the distribution of this disturbance will not be 

known until site-specific mine and reclamation plans have been determined. 

Mine activities include, but are not limited to, large-scale topsoil stripping, the 

intense presence of heavy machinery, extended human presence, loud noise 

and various linear disturbances such as roads, power lines and fences. 

No blowout penstemon have been recorded within the LBA tract’s general 

analysis area or the adjacent mine permit areas to date. Given the lack of any 

potentially suitable habitat within the LBA tract and surrounding areas and 

the documented absence of the species in the region, mining the general 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-109 

analysis area for the West Jacobs Ranch LBA Tract would not result in any 

direct or indirect effects on blowout penstemon. 

G-8.3.5 North Porcupine 

Under the Proposed Action for the North Porcupine LBA Tract, up to 9,864.0 

acres would be disturbed by surface coal mining operations over a period of 6.3 

years. Under Alternative 2, BLM’s Preferred Alternative, for the North 

Porcupine LBA Tract, up to 11,444.0 acres would be disturbed by surface coal 

mining operations over a period of 7.8 years. Although the total disturbance 

acreage is known, the distribution of this disturbance will not be known until 

site-specific mine and reclamation plans have been determined. Mine activities 

include, but are not limited to, large-scale topsoil stripping, the intense 

presence of heavy machinery, extended human presence, loud noise and 

various linear disturbances such as roads, power lines and fences. 

No blowout penstemon have been recorded within the LBA tract’s general 

analysis area or the adjacent mine permit areas to date. Given the lack of any 

potentially suitable habitat within the LBA tract and surrounding areas and 

the documented absence of the species in the region, mining the general 

analysis area for the North Porcupine LBA Tract would not result in any direct 

or indirect effects on blowout penstemon. 

G-8.3.6 South Porcupine 

Under the Proposed Action for the South Porcupine LBA Tract, up to 3,366.0 

acres would be disturbed by surface coal mining operations over a period of 3.3 

years. Under Alternative 2, BLM’s Preferred Alternative, for the South 

Porcupine LBA Tract, up to 4,068.0 acres would be disturbed by surface coal 

mining operations over a period of 3.6 years. Although the total disturbance 

acreage is known, the distribution of this disturbance will not be known until 

site-specific mine and reclamation plans have been determined. Mine activities 

include, but are not limited to, large-scale topsoil stripping, the intense 

presence of heavy machinery, extended human presence, loud noise and 

various linear disturbances such as roads, power lines and fences. 

No blowout penstemon have been recorded within the LBA tract’s general 

analysis area or the adjacent mine permit areas to date. Given the lack of any 

potentially suitable habitat within the LBA tract and surrounding areas and 

the documented absence of the species in the region, mining the general 

analysis area for the South Porcupine LBA Tract would not result in any direct 

or indirect effects on blowout penstemon. 

G-9.0 CUMULATIVE IMPACTS 

Cumulative effects are those effects of future state or private activities, not 

involving federal activities, that are reasonably certain to occur within the 

action area of the federal action subject to consultation (50 CFR 402.2). A 
Appendix G 

G-110 Final EIS, Wright Area Coal Lease Applications

cumulative impact analysis is used to evaluate the influences of past, present, 

and reasonably foreseeable future human developments, and examines 

impacts on a broader scale. 

The BLM recently 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 LBA tracts in the general Wright 

analysis area, are approved. These 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. Chapter 4 of this EIS summarizes the information presented in 

the PRB Coal Review task studies and Table 4-10 in that section summarizes 

the total actual disturbance and reclamation acreages for 2003 (the baseline 

year) and 2007 and the total projected disturbance and reclamation acreages 

for 2010, 2015, and 2020. 

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 River, Antelope Creek, and Dry Fork Cheyenne River 

subwatersheds that lie within Sheridan, Johnson, Campbell and northern 

Converse counties. The six WAC LBA tracts are included within the Upper 

Cheyenne River and Antelope Creek subwatersheds, which are depicted on 

Figure 4-4 in Chapter 4 of this EIS. The total Task 3 cumulative effects study 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-111 

area includes over 4 million acres. A total of approximately 210,096 acres of 

this land area had been disturbed by development activities (e.g., ranchingrelated, coal mining-related, and oil and gas-related) as of 2003, which 

represents about 5.2 percent of the total Task 3 study area. As of the end of 

2007, a total of approximately 222,568 acres (about 5.6 percent) of land area 

had been disturbed by development activities in the cumulative effects study 

area. Of the 222,568 acres of total habitat disturbance, approximately 113,382 

acres (51 percent) have been reclaimed. The remaining 132,645 acres of 

habitat 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 habitat disturbance directly associated with 

coal mine development, approximately 25,884 acres (31 percent) have been 

reclaimed (as 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 (i.e., roads, buildings coal handling 

facilities) that are needed to conduct mining operations. These areas would be 

reclaimed near the end of mine 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. 

According to the PRB Coal Review, the 2007 total of 222,568 acres of 

cumulative disturbance is projected to increase to as much as 434,374 acres 

by 2020 under the upper coal production scenario, which would represent 

approximately 10.9 percent of the cumulative study area. Of that total, 

approximately 296,670 acres (68 percent) would be reclaimed by 2020. The 

remaining 137,702 acres of habitat 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 (34 

percent of the total cumulative disturbance) that are projected to be associated 

with coal mine development, it is projected that approximately 86,196 acres (58 

percent) would be reclaimed by 2020. 

BLM estimates that the existing federal coal leases in the Wyoming PRB 

include approximately 125,180 acres. The currently pending federal coal LBA 

tracts (including the North Hilight Field, South Hilight Field, West Hilight Field, 

West Jacobs Ranch, North Porcupine, and South Porcupine LBA Tracts) 

include approximately 34,571.75 additional acres. The majority of the coal in 

the areas permitted for surface coal mining is federal, but some state and 

private leases are included within some of the existing mine permit areas. All 

of the current and proposed federal coal leases are concentrated near the 

outcrop of the Wyodak coal bed, which is located in eastern Campbell County 

and the extreme northeastern edge of Converse County. 

Oil and gas exploration and production have been ongoing in the PRB for more 

than 100 years. Conventional (non-CBNG) oil and gas fields are, for the most 

part, concentrated in the central and southern parts of the structural basin. 

Development of the CBNG resources from the coal beds is a more recent 
Appendix G 

G-112 Final EIS, Wright Area Coal Lease Applications

occurrence, with CBNG production in the Wyoming PRB starting in the late 

1980s. As of 2003, an estimated 177,140 acres had been disturbed in the coal 

review project area as a result of oil and gas development activities, but 

approximately 114,777 acres of that disturbance has been reclaimed. This 

includes conventional oil and gas and CBNG wells and associated facilities and 

major transportation pipelines. 

The existing habitat disturbing activities within the general Wright analysis 

area, aside from coal mining, are conventional oil and gas and CBNG 

development, agricultural (ranching) activities, recreational activities, roads, 

and railroads. Mining developments tend to have more intense impacts on 

fairly localized areas, while ranching (livestock grazing) activities, recreational 

activities, and oil and gas development can be less intensive locally but tend to 

spread over larger areas. Mining activities and oil and gas development have 

requirements for reclamation of disturbed areas as resources are depleted. The 

net area of energy disturbance in the general Wright analysis area has been 

increasing. This means that in the short term, the potential direct impacts to 

T&E species is a reduction in the available habitat. In the long term, habitat is 

being and will continue to be restored as reclamation proceeds. Indirect 

threats to T&E species would include the potential import and spread of 

noxious weeds, which have the ability to displace native vegetation and hinder 

reclamation efforts. Control of noxious weeds is addressed in surface coal 

mining and oil and gas reclamation plans. Provided weed mitigation and 

preventative procedures are applied to all construction and reclamation 

practices, impact of noxious weeds on T&E species would be minimized. 

Indirect loss of habitat due to habitat fragmentation is also a potential adverse 

effect to federally protected species. 

The existing mines have developed mitigation procedures, as required by 

SMCRA (at 30 CFR 816.97) and Wyoming state regulations, to protect T&E 

species. These procedural requirements 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 as proposed, and after required detailed plans to mine the coal and 

reclaim the mined-out areas are developed and approved. Species-specific 

cumulative impacts are discussed below.

G-9.1 Ute Ladies’-tresses 

Potential direct impacts to this plant species as a result of development 

activities in the PRB Coal Review Task 3 study area could include incremental 

loss or alteration of potentially suitable habitat, associated with past and 

projected activities. Indirect impacts could occur due to the increased 

dispersal and establishment of noxious weeds, which may result in the 

displacement of the species in the long term. 

Operations associated with development activities in the Task 3 study area 

would result in the use of groundwater. Annually, during 2010-2020, from 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-113 

30,000-35,000 million gallons per year of CBNG-produced water would be 

discharged to impoundments or intermittent and ephemeral streams or reinjected. The surface discharge of large quantities of produced water could 

alter stream morphology and hydrology and result in the creation of wetlands 

in containment ponds, landscape depressions, and riparian areas along 

drainages that previously supported upland vegetation. Existing wetlands and 

riparian areas that would receive additional water would become more 

extensive and potentially support a greater diversity of wetland species in the 

long term. 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. 

Implementation of the Proposed Action and Alternative 2, BLM’s Preferred 

Alternative, for each of the six WAC LBA tracts is not expected to contribute to 

cumulative impacts upon Ute ladies’-tresses due to a lack of confirmed 

occurrences of the species within the general Wright analysis area. Should 

future surveys identify populations of Ute ladies’-tresses, such populations and 

associated habitats would be avoided. 

G-9.2 Black-footed Ferret 

Implementation of Alternative 2, BLM’s Preferred Alternative, for each of the six 

WAC LBA tracts would directly affect a total of six prairie dog colonies by 

surface disturbance (topsoil salvage operations) and 27 would be indirectly 

affected by increased activity (noise levels and human presence) in the 

immediate area, resulting in the overall reduction in prairie dog habitat 

suitability. Additionally, ongoing disturbances from sources unrelated to 

mining (ranching and oil and gas production activities) would likely continue, 

with some activities occurring within prairie dog colonies in the area. These 

activities would result in less habitat disturbance than surface mining, but 

physical disturbance would occur. 

Intensive coal mining and natural gas development have occurred in the 

general Wright analysis area for more than 30 years, with activities expected to 

increase in the immediate future. Leasing and mining lands in the six WAC 

LBA tracts’ general analysis areas is not expected to contribute to cumulative 

impacts upon black-footed ferrets within either the general Wright analysis 

area or this region of Wyoming. No black-footed ferret populations exist within 

northeastern Wyoming or the TBNG. The USFWS issued a block clearance for 

this species in black-tailed prairie dog colonies throughout Wyoming. The 

focus area for ferret reintroduction efforts is outside the coal mine region of the 

PRB of northeast Wyoming (USFS 2002b, Grenier 2003). Furthermore, the 

Proposed Action and Alternatives 1 and 2 for any or all six of the WAC LBA 

tracts would not conflict with any future objectives to manage the area for, or 

reintroduce black-footed ferrets into, the TBNG. 
Appendix G 

G-114 Final EIS, Wright Area Coal Lease Applications

G-9.3 Blowout Penstemon 

Implementation of the Proposed Action and Alternative 2, BLM’s Preferred 

Alternative, for each of the six WAC LBA tracts is not expected to contribute to 

cumulative impacts upon blowout penstemon due to the absence of suitable 

habitat and a lack of confirmed occurrences of the species within the general 

Wright analysis area. 

G-10.0 THREATS AND CONSERVATION MEASURES TO AVOID OR 

REDUCE ADVERSE IMPACTS 

G-10.1 Ute Ladies’-tresses 

Rangewide, current and potential threats to the species include: urbanization, 

road and infrastructure construction, hydrologic development, agricultural 

conversion of wetlands, non-native plant invasion, pesticide application, 

pollinator loss, over collection, livestock and native herbivore grazing, 

recreation, drought, vegetation succession, fire suppression, and intrinsic 

rarity of Ute ladies’-tresses and associated mycorrhizal fungi (USFWS 1992b, 

Fertig et al. 2005). Threats observed locally upon potentially suitable habitat 

for the species are primarily hydrological changes resulting from the alteration 

of the surface water flows by CBNG development and coal mining activities. 

Other threats may be off-road vehicle use, invasion by non-native and/or 

noxious plants, control of weeds with herbicides, and overgrazing. 

LBA tracts that are offered for lease would be subject to lease stipulations that 

will protect populations of Ute ladies’-tresses, should they be found to occur 

within the LBA tract. Any potential habitat that has not already been surveyed 

for Ute ladies’-tresses within the project area shall be identified and surveyed 

prior to surface mining activities. If this species is found within an LBA tract 

that is offered for lease, either a no-surface-disturbance buffer could be placed 

around the population to prevent any potential impacts, the plants could be 

salvaged for study to contribute to the science on the species, or the plants 

could be transplanted to another suitable habitat outside of the disturbance 

area. 

Jurisdictional wetlands located in the six WAC LBA tracts that are destroyed by 

mining operations would be replaced in accordance with the requirements of 

Section 404 of the Clean Water Act (CWA), as determined by the COE. The 

replaced wetlands may not duplicate the exact function and landscape features 

of the pre-mine wetlands. COE considers the type and function of each 

jurisdictional wetland that will be impacted and may require restoration of 

additional acres if the type and function of the restored wetlands will not 

completely replace the type and function of the original wetland. Replacement 

of non-jurisdictional and functional wetlands may be required by the surface 

land owner and/or WDEQ/LQD. WDEQ/LQD allows, and sometimes requires, 

mitigation of non-jurisdictional wetlands affected by mining, depending on the 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-115 

values associated with the wetland features. WDEQ/LQD also requires 

replacement of playas with hydrologic significance. 

All appropriate sedimentation, erosion control, and produced water control 

measures will be implemented to avoid changes in surface water quality or 

quantity in the area. 

The approved Black Thunder Mine Permit 233-T7 (TBCC 2005), Jacobs Ranch 

Mine Permit 271-T6 (JRCC 2009), and North Antelope Rochelle Mine Permit 

569-T7 (PRC 2009) include monitoring and mitigation measures that are 

required by and Wyoming state law. If one or more of the WAC LBA tracts are 

acquired by ALC and/or BTU, these required measures would be extended to 

cover operations on the LBA tract(s) when the respective mining permit is 

amended to include the tract. This amended permit would have to be approved 

before mining operations could take place on the tract. Continued site-specific 

surveys for the lease area and appropriate perimeter would be part of the mine 

permitting process if a tract is leased and proposed for mining. All of these 

monitoring, mitigation and conservation measures are considered to be part of 

the Proposed Action and alternatives during the leasing process because they 

are regulatory requirements. 

According to the USFWS 2005 Rangewide Status Review of Ute Ladies’-tresses 

(Fertig et al. 2005), the number of populations, geographic ranges, acreages, 

and estimated population sizes of this species has increased significantly since 

it was listed in 1992. Much of this can be attributed to increased survey and 

project analysis work over much of the western United States and heightened 

awareness of the plant due to its protected status. When the orchid was listed 

as threatened in 1992, it had an estimated population size of 6,000 individuals. 

In 2005, additional survey work estimated the number of plants to be over 

83,300. USFWS determined that a petition to remove the orchid from federal 

protection under the ESA provided substantial biological information, which 

indicated that removal may be warranted. As of December 2005, the Service 

was moving forward with the proposal to delist the Ute ladies’-tresses, but a 

final decision has not yet been made. A 5-year study is needed before such 

action could occur. 

G-10.2 Black-footed Ferret 

Loss of habitat is the primary reason black-footed ferrets remain near the brink 

of extinction. Major threats contributing to the slow decline in black-tailed 

prairie dog populations and reduced ferret habitat include conversion of native 

grasslands to intensive agricultural uses, urbanization, widespread prairie dog 

eradication programs (including recreational shooting), and fatal non-native 

disease (sylvatic plague) (BFFRIT 2009). Mineral development within blacktailed prairie dog colonies is a leading cause of potential ferret habitat loss in 

the PRB. Surface coal mining tends to have more intense impacts on fairly 

localized areas, while oil and gas development tends to be less intensive but 

spread over larger areas. Oil and gas development and mining activities have 
Appendix G 

G-116 Final EIS, Wright Area Coal Lease Applications

requirements for reclamation of disturbed areas as resources are depleted. In 

reclaimed areas, vegetation cover may differ from undisturbed areas. In the 

case of surface coal mines, re-established vegetation would be dominated by 

species mandated in the reclamation seed mixtures (to be approved by WDEQ). 

The majority of the approved plant species are native to the area; however, 

reclaimed areas may not serve ecosystem functions presently served by 

undisturbed vegetation communities and habitats, particularly in the shortterm, when species composition, shrub cover, and other environmental factors 

are likely to be different. Shifts in habitat composition or distribution following 

reclamation could increase or decrease potential habitat for prairie dogs and 

associated habitat for black-footed ferrets. However, black-tailed prairie dogs 

have been recorded in colonies on reclaimed coal mined lands in northeastern 

Wyoming in recent years, whether by natural expansion or purposeful 

relocations (J&S 2008, IR 2007). 

The approved Black Thunder Mine Permit 233-T7 (TBCC 2005), Jacobs Ranch 

Mine Permit 271-T6 (JRCC 2009), and North Antelope Rochelle Mine Permit 

569-T7 (PRC 2009) include monitoring and mitigation measures that are 

required by and Wyoming state law. If one or more of the WAC LBA tracts are 

acquired by ALC and/or BTU, these required measures would be extended to 

cover operations on the LBA tract(s) when the respective mining permit is 

amended to include the tract. This amended permit would have to be approved 

before mining operations could take place on the tract. Continued site-specific 

surveys for the lease area and appropriate perimeter would be part of the mine 

permitting process if a tract is leased and proposed for mining. These 

monitoring and mitigation measures are considered to be part of the Proposed 

Action and alternatives during the leasing process because they are regulatory 

requirements. 

G-10.3 Blowout Penstemon 

No one reason has been determined for the blowout penstemon decline from 

being a relatively common plant in the early 1900s to an endangered plant at 

present. Blowout penstemon is adapted to a dynamic habitat that moves 

continually, but is an early successional species. The blowout community 

contains plants especially tolerant of disturbance caused by wind erosion as 

blowout sand is excavated and wind-driven. Wind erosion is important in 

maintaining the open habitat required by blowout penstemon. If other plants 

invade the open habitat, the blowout penstemon declines. Improved range 

management practices and active fire suppression programs have led to 

increases in prairie vegetation cover with decreases in sandy areas. The greatly 

reduced surface area of shifting sand dunes and the number of blowouts have 

been beneficial to the ranching community but has proven detrimental to 

blowout penstemon (Stubbendieke and Kottas 2007). Blowouts represent a 

significant loss of forage production, but they provide ideal habitat for plants 

such as the blowout penstemon (Weedon et al. 1982, Flessner 1988). 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-117 

The species requires abundant soil moisture for germination and moisture may 

not be adequate in some years for germination or survival. The primary 

limiting factor in seedling establishment is moisture availability. For the seeds 

to germinate and for the roots to reach a depth where moisture is available and 

constant, blowout sand must remain damp for at least 2 weeks during the 

growing season. In the arid environment of sandy blowouts, these conditions 

usually only occur in one out of every 8 to 10 years. The drought of the 1930s 

is the most conspicuous stressful event and may have contributed to a severe 

reduction in the species. The low natural seedling survival rates combined 

with a relatively short life span of about 6 to 8 years explains part of the reason 

for the small size of the present natural population (Stubbendieke and Kottas 

2007). 

Most populations are physically isolated in a few sites and the probability of 

seeds migrating to other blowouts is small. These populations are also 

genetically isolated so the prospect for introduction of genetic material from 

one population to another is unlikely. The small geographic range of existing 

plants is of concern since the possibility of localized droughts could severely 

impact entire populations (Stubbendieke and Kottas 2007). 

This species is potentially vulnerable to habitat loss and degradation resulting 

from sand mining, water development, energy development, off-road vehicle 

use, and the spread of non-native species (University of Wyoming 2008). 

The Wyoming BLM is developing a blowout penstemon conservation strategy in 

coordination with local, state, and federal agencies, as well as private land 

owners, to apply federal statutes and agency policy in a way that addresses the 

conservation needs of this plant. The goal is to foster long term viability of the 

blowout penstemon and avert potential threats that include oil, gas, powerline, 

wind farm, and water development, sand mining, off-road vehicle use, livestock 

grazing, and plant collection. BLM continues to work with the Wyoming 

Natural Diversity Database and the Rocky Mountain Herbarium at the 

University of Wyoming to survey, monitor, and research native plant species in 

order to maintain Wyoming’s native plants and their habitats (Heidel et al. 

2007). 

According to Heidel et al. (2007), monitoring of Wyoming blowout penstemon 

populations during dry years (2003-2006) suggests that this plant can survive 

drought. While this plant’s habitat is continually being eroded by wind or 

buried by shifting sand, new habitat is developing. Additionally, long-lived 

seeds may provide important buffer from the uncertainties of unstable habitat 

and unsuitable climatic conditions. Research and monitoring are helping to 

ensure the long-term viability of blowout penstemon populations in Wyoming 

(Heidel et al.2007). 

Blowout penstemon plants are now being propagated in University of Nebraska 

greenhouses and successfully transplanted to suitable habitat in the Nebraska 

Sandhills (USFS 2009). 
Appendix G 

G-118 Final EIS, Wright Area Coal Lease Applications

The approved Black Thunder Mine Permit 233-T7 (TBCC 2005), Jacobs Ranch 

Mine Permit 271-T6 (JRCC 2009), and North Antelope Rochelle Mine Permit 

569-T7 (PRC 2009) include monitoring and mitigation measures that are 

required by and Wyoming state law. If one or more of the WAC LBA tracts are 

acquired by ALC and/or BTU, these required measures would be extended to 

cover operations on the LBA tract(s) when the respective mining permit is 

amended to include the tract. This amended permit would have to be approved 

before mining operations could take place on the tract. Continued site-specific 

surveys for the lease area and appropriate perimeter would be part of the mine 

permitting process if a tract is leased and proposed for mining. Habitat for the 

blowout penstemon will be identified prior to any surface disturbing activities. 

If suitable habitat (e.g., sparsely vegetated active sand dunes or sand dune 

blowouts) is determined to be present on the site, surveys will be conducted for 

the presence of this species. If the species is found, a no-surface-disturbance 

buffer would be placed around the population consistent with the Bureau’s 

Statewide Programmatic Biological Assessment (BLM 2005). These monitoring 

and mitigation measures are considered to be part of the Proposed Action and 

alternatives during the leasing process because they are regulatory 

requirements. 

G-11.0 EFFECTS OF THE PROPOSED ACTIONS AND ALTERNATIVES ON 

THE EXPECTED STATUS OF SPECIES IN THE FUTURE 

Provided the conservation measures described above are implemented, the 

Proposed Action and Preferred Alternative with respect to each WAC LBA tract 

is not expected to alter the current status of, or result in any decreased 

survival of, the Ute ladies’-tresses, the black-footed ferret, and the blowout 

penstemon during the duration of mining and reclamation of each LBA tract. 

G-12.0 DETERMINATION OF EFFECTS FOR LISTED SPECIES 

The following subsections present the conclusions made concerning the direct 

and indirect effects of the Proposed Actions and alternatives on the Ute ladies’-

tresses, the black-footed ferret, and the blowout penstemon, together with the 

effects of other activities that are interrelated or interdependent with those 

actions. These effects are considered along with the environmental baseline 

and predicted cumulative effects to determine the overall effects to the listed 

species. 

G-12.1 Ute Ladies’-tresses 

G-12.1.1 North Hilight Field 

Based upon the impact analyses of the alternatives, the current status of this 

species, other land use activities in the area, and incorporation of the 

conservation measures recommended in this BA, it is concluded that mining 

the federal coal included in the North Hilight Field LBA Tract, if the tract is 

leased under the Proposed Action or Alternative 2 (BLM’s Preferred Alternative), 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-119 

may affect, but is not likely to adversely affect Ute ladies’-tresses. It is 

expected that the effects on the species would be discountable, or extremely 

unlikely to occur. 

The general analysis area for this tract is not located within the same drainage 

basin as the nearest known population of Ute ladies’-tresses. Previous surveys 

for Ute ladies’-tresses have been conducted within the adjacent mine permit 

areas and BAs have been prepared to evaluate the potential effects to the 

species by leasing federal coal tracts and disturbing federal surface lands 

located inside the mines’ existing permit areas, but no plants were ever found. 

No Ute ladies’-tresses were found during the 2008 and 2009 surveys of all 

areas of potentially suitable habitat within the general analysis area for the 

North Hilight Field tract. The USFWS Interim Survey Requirements for Ute 

ladies’-tresses recommends all suitable habitat areas be surveyed annually for 

three consecutive years (USFWS 1992b); therefore, another survey is scheduled 

to be conducted during the species’ flowering period in 2010. Despite the 

uncertainty, it does not affect this determination because it is extremely 

unlikely that any orchids will be found in the future within this area. 

G-12.1.2 South Hilight Field 

Based upon the impact analyses of the alternatives, the current status of this 

species, other land use activities in the area, and incorporation of the 

conservation measures recommended in this BA, it is concluded that mining 

the federal coal included in the South Hilight Field LBA Tract, if the tract is 

leased under the Proposed Action or Alternative 2 (BLM’s Preferred Alternative), 

may affect, but is not likely to adversely affect Ute ladies’-tresses. It is 

expected that the effects on the species would be discountable, or extremely 

unlikely to occur. 

The general analysis area for this tract is not located within the same drainage 

basin as the nearest known population of Ute ladies’-tresses. Previous surveys 

for Ute ladies’-tresses have been conducted within the adjacent mine permit 

areas and BAs have been prepared to evaluate the potential effects to the 

species by leasing federal coal tracts and disturbing federal surface lands 

located inside the mines’ existing permit areas, but no plants were ever found. 

No Ute ladies’-tresses were found during the 2008 and 2009 surveys of all 

areas of potentially suitable habitat within the general analysis area for the 

South Hilight Field tract. The USFWS Interim Survey Requirements for Ute 

ladies’-tresses recommends all suitable habitat areas be surveyed annually for 

three consecutive years (USFWS 1992b); therefore, another survey is scheduled 

to be conducted during the species’ flowering period in 2010. Despite the 

uncertainty, it does not affect this determination because it is extremely 

unlikely that any orchids will be found in the future within this area. 
Appendix G 

G-120 Final EIS, Wright Area Coal Lease Applications

G-12.1.3 West Hilight Field 

Based upon the impact analyses of the alternatives, the current status of this 

species, other land use activities in the area, and incorporation of the 

conservation measures recommended in this BA, it is concluded that mining 

the federal coal included in the West Hilight Field LBA Tract, if the tract is 

leased under the Proposed Action or Alternative 2 (BLM’s Preferred Alternative), 

may affect, but is not likely to adversely affect Ute ladies’-tresses. It is 

expected that the effects on the species would be discountable, or extremely 

unlikely to occur. 

The general analysis area for this tract is not located within the same drainage 

basin as the nearest known population of Ute ladies’-tresses. Previous surveys 

for Ute ladies’-tresses have been conducted within the adjacent mine permit 

areas and BAs have been prepared to evaluate the potential effects to the 

species by leasing federal coal tracts and disturbing federal surface lands 

located inside the mines’ existing permit areas, but no plants were ever found. 

No Ute ladies’-tresses were found during the 2008 and 2009 surveys of all 

areas of potentially suitable habitat within the general analysis area for the 

West Hilight Field tract. The USFWS Interim Survey Requirements for Ute 

ladies’-tresses recommends all suitable habitat areas be surveyed annually for 

three consecutive years (USFWS 1992b); therefore, another survey is scheduled 

to be conducted during the species’ flowering period in 2010. Despite the 

uncertainty, it does not affect this determination because it is extremely 

unlikely that any orchids will be found in the future within this area. 

G-12.1.4 West Jacobs Ranch 

Based upon the impact analyses of the alternatives, the current status of this 

species, other land use activities in the area, and incorporation of the 

conservation measures recommended in this BA, it is concluded that mining 

the federal coal included in the West Jacobs Ranch LBA Tract, if the tract is 

leased under the Proposed Action or Alternative 2 (BLM’s Preferred Alternative), 

may affect, but is not likely to adversely affect Ute ladies’-tresses. It is 

expected that the effects on the species would be discountable, or extremely 

unlikely to occur. 

The general analysis area for this tract is not located within the same drainage 

basin as the nearest known population of Ute ladies’-tresses. Previous surveys 

for Ute ladies’-tresses have been conducted within the adjacent mine permit 

areas and BAs have been prepared to evaluate the potential effects to the 

species by leasing federal coal tracts and disturbing federal surface lands 

located inside the mines’ existing permit areas, but no plants were ever found. 

No Ute ladies’-tresses were found during the 2007, 2008, and 2009 surveys of 

all areas of potentially suitable habitat within the general analysis area for the 

West Jacobs Ranch tract. The surface discharge of groundwater associated 

with CBNG development in the area has caused soil moisture conditions along 

water courses to change and the distribution of plant communities have 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-121 

therefore been altered to some degree. Nevertheless, the quality of potential 

habitat remains poor for a number of key reasons, which are discussed in 

Section G-7.1.2.4 of this BA. In addition, survey personnel noticed that the 

surface discharges from CBNG production in 2009 had declined relative to 

conditions observed in 2007 and 2008. Despite the uncertainty of future 

surficial hydrologic conditions, it does not affect this determination because it 

is extremely unlikely that any orchids will be found in the future within this 

area. 

G-12.1.5 North Porcupine 

Based upon the impact analyses of the alternatives, the current status of this 

species, other land use activities in the area, and incorporation of the 

conservation measures recommended in this BA, it is concluded that mining 

the federal coal included in the North Porcupine LBA Tract, if the tract is leased 

under the Proposed Action or Alternative 2 (BLM’s Preferred Alternative), may 

affect, but is not likely to adversely affect Ute ladies’-tresses. It is expected 

that the effects on the species would be discountable, or extremely unlikely to 

occur. 

Most of the general analysis area for this tract is located within the Antelope 

Creek drainage basin and the nearest known population of Ute ladies’-tresses 

is located within the same watershed roughly 28 miles west-southwest of the 

tract. The LBA tract’s entire general analysis area is located within the North 

Antelope Rochelle Mine’s existing mine permit area, and as such, a number of 

Ute ladies’-tresses surveys covering various portions of the potentially suitable 

habitat within the tract’s general analysis area have been conducted. Surveys 

for the species have also been conducted and BAs have been prepared to 

evaluate the potential effects to the species by leasing adjacent federal coal 

tracts. No occurrence of the orchid has been recorded by any of those previous 

surveys. Two additional surveys of the potentially suitable habitat within the 

general analysis area for this tract are scheduled to be conducted during the 

species’ flowering period in 2010 and 2011, in order to fulfill the USFWS 

Interim Survey Requirements (USFWS 1992b) for Ute ladies’-tresses. Despite 

the uncertainty, it does not affect this determination because it is extremely 

unlikely that any orchids will be found in the future within this area. 

G-12.1.6 South Porcupine 

Based upon the impact analyses of the alternatives, the current status of this 

species, other land use activities in the area, and incorporation of the 

conservation measures recommended in this BA, it is concluded that mining 

the federal coal included in the South Porcupine LBA Tract, if the tract is 

leased under the Proposed Action or Alternative 2 (BLM’s Preferred Alternative), 

may affect, but is not likely to adversely affect Ute ladies’-tresses. It is 

expected that the effects on the species would be discountable, or extremely 

unlikely to occur. 
Appendix G 

G-122 Final EIS, Wright Area Coal Lease Applications

The general analysis area for this tract is located within the Antelope Creek 

drainage basin and the nearest known population of Ute ladies’-tresses is 

located within the same watershed roughly 29 miles west of the tract. The LBA 

tract’s entire general analysis area is located within the North Antelope 

Rochelle Mine’s existing mine permit area, and as such, a number of Ute 

ladies’-tresses surveys covering the potentially suitable habitat within the tract 

have been conducted. Surveys for the species have also been conducted and 

BAs have been prepared to evaluate the potential effects to the species by 

leasing adjacent federal coal tracts. No occurrence of the orchid was been 

recorded by any of those previous surveys. Two additional surveys of the 

potentially suitable habitat within the general analysis area for this tract are 

scheduled to be conducted during the species’ flowering period in 2010 and 

2011, in order to fulfill the USFWS Interim Survey Requirements (USFWS 

1992b) for Ute ladies’-tresses. Despite the uncertainty, it does not affect this 

determination because it is extremely unlikely that any orchids will be found in 

the future within this area. 

G-12.2 Black-footed Ferret 

G-12.2.1 North Hilight Field 

Based upon the impact analyses of the alternatives, the current status of this 

species, other land use activities in the area, and incorporation of the 

conservation measures recommended in this BA, it is concluded that mining 

the federal coal included in the North Hilight Field LBA Tract, if the tract is 

leased under the Proposed Action or Alternative 2 (BLM’s Preferred Alternative), 

would have no affect on black-footed ferrets. 

G-12.2.2 South Hilight Field 

Based upon the impact analyses of the alternatives, the current status of this 

species, other land use activities in the area, and incorporation of the 

conservation measures recommended in this BA, it is concluded that mining 

the federal coal included in the South Hilight Field LBA Tract, if the tract is 

leased under the Proposed Action or Alternative 2 (BLM’s Preferred Alternative), 

would have no affect on black-footed ferrets. 

G-12.2.3 West Hilight Field 

Based upon the impact analyses of the alternatives, the current status of this 

species, other land use activities in the area, and incorporation of the 

conservation measures recommended in this BA, it is concluded that mining 

the federal coal included in the West Hilight Field LBA Tract, if the tract is 

leased under the Proposed Action or Alternative 2 (BLM’s Preferred Alternative), 

would have no affect on black-footed ferrets. 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-123 

G-12.2.4 West Jacobs Ranch 

Based upon the impact analyses of the alternatives, the current status of this 

species, other land use activities in the area, and incorporation of the 

conservation measures recommended in this BA, it is concluded that mining 

the federal coal included in the West Jacobs Ranch LBA Tract, if the tract is 

leased under the Proposed Action or Alternative 2 (BLM’s Preferred Alternative), 

would have no affect on black-footed ferrets. 

G-12.2.5 North Porcupine 

Based upon the impact analyses of the alternatives, the current status of this 

species, other land use activities in the area, and incorporation of the 

conservation measures recommended in this BA, it is concluded that mining 

the federal coal included in the North Porcupine LBA Tract, if the tract is leased 

under the Proposed Action or Alternative 2 (BLM’s Preferred Alternative), would 

have no affect on black-footed ferrets. 

G-12.2.6 South Porcupine 

Based upon the impact analyses of the alternatives, the current status of this 

species, other land use activities in the area, and incorporation of the 

conservation measures recommended in this BA, it is concluded that mining 

the federal coal included in the South Porcupine LBA Tract, if the tract is 

leased under the Proposed Action or Alternative 2 (BLM’s Preferred Alternative), 

would have no affect on black-footed ferrets. 

G-12.3 Blowout Penstemon 

G-12.3.1 North Hilight Field 

Based on the lack of suitable habitat in the tract’s general analysis area and 

the known distribution of this species in the state of Wyoming, it is extremely 

unlikely that the blowout penstemon would occur in the tract’s general 

analysis area. Therefore, it is concluded that mining the federal coal included 

in the North Hilight Field LBA Tract, if the tract is leased under the Proposed 

Action or Alternative 2 (BLM’s Preferred Alternative), would have no affect on 

blowout penstemon. 

G-12.3.2 South Hilight Field 

Based on the lack of suitable habitat in the tract’s general analysis area and 

the known distribution of this species in the state of Wyoming, it is extremely 

unlikely that the blowout penstemon would occur in the tract’s general 

analysis area. Therefore, it is concluded that mining the federal coal included 

in the South Hilight Field LBA Tract, if the tract is leased under the Proposed 

Action or Alternative 2 (BLM’s Preferred Alternative), would have no affect on 

blowout penstemon. 
Appendix G 

G-124 Final EIS, Wright Area Coal Lease Applications

G-12.3.3 West Hilight Field 

Based on the lack of suitable habitat in the tract’s general analysis area and 

the known distribution of this species in the state of Wyoming, it is extremely 

unlikely that the blowout penstemon would occur in the tract’s general 

analysis area. Therefore, it is concluded that mining the federal coal included 

in the West Hilight Field LBA Tract, if the tract is leased under the Proposed 

Action or Alternative 2 (BLM’s Preferred Alternative), would have no affect on 

blowout penstemon. 

G-12.3.4 West Jacobs Ranch 

Based on the lack of suitable habitat in the tract’s general analysis area and 

the known distribution of this species in the state of Wyoming, it is extremely 

unlikely that the blowout penstemon would occur in the tract’s general 

analysis area. Therefore, it is concluded that mining the federal coal included 

in the West Jacobs Ranch LBA Tract, if the tract is leased under the Proposed 

Action or Alternative 2 (BLM’s Preferred Alternative), would have no affect on 

blowout penstemon. 

G-12.3.5 North Porcupine 

Based on the lack of suitable habitat in the tract’s general analysis area and 

the known distribution of this species in the state of Wyoming, it is extremely 

unlikely that the blowout penstemon would occur in the tract’s general 

analysis area. Therefore, it is concluded that mining the federal coal included 

in the North Porcupine LBA Tract, if the tract is leased under the Proposed 

Action or Alternative 2 (BLM’s Preferred Alternative), would have no affect on 

blowout penstemon. 

G-12.3.6 South Porcupine 

Based on the lack of suitable habitat in the tract’s general analysis area and 

the known distribution of this species in the state of Wyoming, it is extremely 

unlikely that the blowout penstemon would occur in the tract’s general 

analysis area. Therefore, it is concluded that mining the federal coal included 

in the South Porcupine LBA Tract, if the tract is leased under the Proposed 

Action or Alternative 2 (BLM’s Preferred Alternative), would have no affect on 

blowout penstemon. 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-125 

G-13.0 CREDENTIALS OF SURVEY PERSONNEL 

G-13.1 North, South and West Hilight Field LBA Tracts 

G-13.1.1 T&E Animal Species 

Consulting Firm: Thunderbird/Jones & Stokes of Gillette, Wyoming 

Gwyn McKee: Ms. McKee obtained a Master of Science degree in Wildlife 

Ecology/Management from the University of Missouri-Columbia. She has 

accumulated nearly 20 years of professional experience, with the last 14 spent 

working with the energy industry in Wyoming, Montana, and South Dakota. 

Ms. McKee has conducted the wildlife surveys and impact analyses for most of 

the surface coal mines in the PRB during her tenure in Wyoming, including two 

of the three applicant mines included this EIS. She has also provided and/or 

reviewed the pertinent text related to impact assessments for vertebrate species 

of concern for most of the coal EISs that have been prepared in the PRB since 

2000. 

Jennifer Ottinger: Ms. Ottinger received a B.S. in Zoology from Colorado State 

University in 1993, with a minor in Microbiology. She has 12 years of 

professional experience with a variety of vertebrate species, including surveys 

for sage-grouse and mountain plovers, though her work has focused on raptors 

during that period. Ms. Ottinger has worked throughout the U.S. and abroad. 

She joined Jones & Stokes as a Wildlife Biologist in 2004. She has strong 

raptor identification and handling skills, research experience, proven abilities 

in data analysis and technical writing, and has presented and/or published 

several articles in a variety of professional meetings and publications, 

respectively. 

G-13.1.2 T&E Vegetation Species 

Consulting Firm: Habitat Management Inc. of Gillette, Wyoming 

Richard Bonine Jr.: Mr. Bonine has a Bachelor of Science degree in Agronomy 

from Kansas State University with significant study concentration in range, 

plant, and soil science. Mr. Bonine has 20 years of experience conducting 

vegetation and T&E surveys in Wyoming, New Mexico, Montana, Kansas, and 

Missouri. These surveys include baseline characterizations, T&E surveys, 

wetland delineations, and soil mapping delineations. Mr. Bonine has taken 

significant action to gain familiarly with Ute ladies’-tresses. These actions 

include consulting several taxonomic texts to gain an understanding of the 

distinguishing botanical characteristics and habitats of this species; visiting a 

know population of Ute ladies’-tresses located on Clear creek near Golden, 

Colorado where he evaluated the site for understory and canopy vegetation, 

associated soil series, and hydrology; discussed with several Wyoming wildlife 

biologists the known Ute ladies’-tresses habitat on Antelope Creek. 
Appendix G 

G-126 Final EIS, Wright Area Coal Lease Applications

Scott Benson: Mr. Benson has conducted numerous research studies to 

quantify vegetation using line transect, point transect, quadrat and plotless 

techniques. These studies have been conducted to obtain quantitative baseline 

data for use in future comparisons, to monitor success of reclamation, and to 

monitor success of created wetlands. Scott has also prepared numerous 

vegetation maps in a variety of habitats, along with both quantitative and 

qualitative descriptions of habitat types. Scott has conducted numerous 

searches for federally-listed plant species, including blowout penstemon, Ute's 

ladies'-tresses, and Colorado butterfly plant, as well as searches for USFS, 

BLM, and state-listed rare plants. Mr. Benson has also conducted qualitative 

plant surveys for NEPA projects and prepared extensive plant lists to describe a 

variety of habitats.

G-13.2 West Jacobs Ranch LBA Tract 

G-13.2.1 T&E Animal Species 

Consulting Firm: Intermountain Resources of Laramie, Wyoming 

Jim Orpet: Mr. Orpet obtained a M.S degree in Range Management and a B.S. 

degree in Wildlife Management, both from the University of Wyoming. He has 

over 30 years experience in vegetation and wildlife surveys in Wyoming and 

adjacent states, primarily with baseline field inventories for mining and other 

energy development projects including T&E, candidate and sensitive species 

surveys for both plants and animals. Mr. Orpet has been involved in T&E 

surveys and research since 1976. Experience includes research and 

monitoring of bald eagle nests and roosts, grizzly bear research, black-footed 

ferret surveys and survey certification and Ute Ladies’-tresses surveys. Mr. 

Orpet and his staff discovered one of the nine currently known occurrences of 

the Ute ladies’-tresses in Wyoming. 

Russell Tait: Mr. Tait earned a B.S degree in Wildlife Management with a minor 

in Range Management from the University of Wyoming. He has over 14 years 

experience in vegetation and wildlife surveys in Wyoming, Colorado and South 

Dakota. These surveys were primarily baseline field inventories and final bond 

release studies for energy and non-energy development projects including T&E, 

candidate and sensitive species surveys for both plants and animals. Mr. Tait’s 

T&E survey experience includes bald eagle roost monitoring, bald eagle nest 

searches, Ute ladies’-tresses surveys and black-footed ferret surveys. Mr. Tait 

was part of a survey crew that discovered one of the nine known occurrences of 

the Ute ladies’-tresses in Wyoming, finding many of the individual plants 

himself. 

G-13.2.2 T&E Vegetation Species 

Consulting Firm: Intermountain Resources (see same personnel above). 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-127 

G-13.3 North and South Porcupine LBA Tracts 

G-13.3.1 T&E Animal Species 

Consulting Firm: Thunderbird/Jones & Stokes (see same personnel above). 

G-13.3.2 T&E Vegetation Species 

Consulting Firm: BKS Environmental Associates, Inc of Gillette, Wyoming 

Dr. Brenda K. Schladweiler: Dr. Schladweiler obtained her Ph.D. in Soil 

Science from the University of Wyoming in 2003, her M.S. in Soil Science from 

the University of Wyoming in 1995, and her B.S. in Range Management (Land 

Rehabilitation) from Colorado State University in 1980. 

Dr. Schladweiler has extensive experience over the last 24 years in conducting 

rare plant surveys. The following is a list of recent T&E plant studies she has 

conducted: 

Location Date Plants Surveyed 

Wharf Mine, Lawrence Co., SD 1992 Various, State of SD 

Heritage Plants 

Ferris Haggerty Mine, Carbon Co., WY 1998 Various, State of WY 

Crow AML, Big Horn Co., MT 1999 Various, State of MT 

Caballo Mine, Campbell Co., WY 1999 Spiranthes diluvialis 

Wright Clinic AML, Campbell Co., WY 1999 Spiranthes diluvialis 

Kane Environmental, Campbell Co., WY 1999 Spiranthes diluvialis 

Atlantic City Mine, Knight Piesold, 

Fremont Co., WY 

2000 Spiranthes diluvialis 

Eagle Butte Mine, Campbell Co., WY Spiranthes diluvialis 

West Antelope Mine, Converse Co., WY 2001 Spiranthes diluvialis 

BRS, Bighorn Basin Water Project, 

Washakie Co., WY 

2001 Various, State of 

Wyoming Plant 

URS, Transmission Line, Campbell Co., 

WY 

2001 Spiranthes diluvialis 

Wright, (bike path) Campbell Co., WY 2001 Spiranthes diluvialis 

Gillette, PCA sewer line, Campbell Co., WY 2002-

2004 

Spiranthes diluvialis 

Gillette, PCA trunk line, Campbell Co., WY 2002-

2004 

Spiranthes diluvialis 

Pinehaven (Wester-Wetstein), Crook Co., 

WY 

2003 Spiranthes diluvialis 

Spotted Horse, (CBMA CH4), Campbell 

Co., WY 

2003 Spiranthes diluvialis 

Bowers Oil (Antelope Creek)Campbell/ 

Converse Co., WY 

2003 Spiranthes diluvialis 
Appendix G 

G-128 Final EIS, Wright Area Coal Lease Applications

Gillette, PCA Swanson Rd., Campbell Co., 

WY 

2003 Spiranthes diluvialis 

North Rochelle Mine USFS Survey, 

Campbell Co., WY 

2004 Various USFS Sensitive 

Species for TBNG 

Westport Oil & Gas, Nicholson POD, 

Campbell Co., WY 

2004 Spiranthes diluvialis 

Devon Energy, Mustang POD, Campbell 

Co., WY 

2004 Spiranthes diluvialis 

NARM, Beckwith Rd., Campbell Co., WY 2004 Spiranthes diluvialis 

Yates Petroleum, Campbell Co., WY 2004 Spiranthes diluvialis; 

various USFS Sensitive 

Species for TBNG 

PRCC, Ridgeroad USFS, Campbell Co., WY 2004 Spiranthes diluvialis 

Lance, Black Thunder POD, Campbell Co., 

WY 

2004 Spiranthes diluvialis 

Devon Energy, Mulie POD, Campbell Co., 

WY 

2004 Spiranthes diluvialis 

Devon Energy Whitetail POD, Campbell 

Co., WY 

2004 Spiranthes diluvialis 

Devon Energy, Bighorn POD, Campbell 

Co., WY 

2004 Spiranthes diluvialis 

Numerous actions have been taken by Dr. Schladweiler to become acquainted 

with the known locations and the appearance of Spiranthes diluvialis. 

Research has been conducted through the Wyoming Natural Diversity 

Database and the Internet for sensitive plants. In addition, she has actually 

visited the population on the unnamed tributary to Antelope Creek numerous 

times over the last 10 years. This known population verification was completed 

as part of a field survey conducted for Yates Petroleum Company in the 

Rochelle Hills POD, Campbell County, Wyoming on August 29, 2004. She has 

also visited the known population near Chugwater, Wyoming. 

Dr. Schladweiler, on numerous occasions, has been in contact with Mr. Ernie 

Nelson, University of Wyoming, Rocky Mountain Herbarium, and George Jones, 

Wyoming Natural Diversity Database. In addition, she has consulted with Mr. 

Walt Fertig, previously from the University of Wyoming. 

Katie Wilson: Ms. Wilson holds a B.S. in Environmental Studies with a minor 

in Biology from Bemidji State University, Bemidji, Minnesota (2005). Ms. 

Wilson has been employed by BKS since the spring of 2005. She has been 

conducting mineland reclamation monitoring for various coal mines in 

Campbell and Converse counties since her employment. She has also 

performed vegetation sampling for numerous CBNG projects and baseline 

vegetation surveys in the PRB. In addition, she has conducted rare plant 

species surveys, wetland delineations, and environmental compliance 

assessments. T&E plant survey experience includes: 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-129 

• Visited an unnamed tributary of Antelope Creek and observed a Ute 

ladies’-tresses (Spiranthes diluvialis) population, 2005. 

• Powder River Coal Company, Gold Mine Draw AVF Exchange. Ute 

ladies’-tresses orchid survey in Campbell County, Wyoming, 2005. 

• West Roundup Resources, Inc., School Creek Mine. Ute ladies’-tresses 

orchid survey in Campbell County, Wyoming, 2005 and 2006. 

• Devon Energy Corporation, Juniper Draw Unit. Ute ladies’-tresses 

orchid survey in Johnson County, Wyoming, 2005. 

• Devon Energy Corporation, Crossroads Unit. Ute ladies’-tresses orchid 

survey in Johnson County, Wyoming, 2005. 

Cindy Adams: Ms. Robinson holds a Masters of Business Administration (MBA) 

and a B.S. in Environmental Science from the University of Denver, Denver, 

Colorado (2005). Ms. Adams has been employed by BKS since April of 2006 

conducting mineland reclamation monitoring for various coal mines in 

Campbell County, Wyoming. In addition, she has conducted rare plant species 

surveys, wetland delineations, and environmental compliance assessments. 

Ms. Adams has also visited a Barr’s milkvetch (Astragalus barrii) site on USFS 

lands at the proposed School Creek Mine area when the species was blooming. 

She has also visited a Ute ladies’-tresses (Spiranthes diluvialis) population in 

bloom on an unnamed tributary of Antelope Creek. T&E and sensitive plant 

survey experience includes: 

• West Roundup Resources, Inc., School Creek Mine. Barr's Milkvetch 

survey in Campbell County, Wyoming, May 2006. 

• West Roundup Resources, Inc., School Creek Mine. Ute ladies’-tresses 

survey in Campbell County, Wyoming, August 2006. 

• Thunder Basin Coal Company, Black Thunder Mine, West Hilight Field 

LBA Tract. Barr's milkvetch survey in Campbell County, Wyoming, 

August 2006. 

• Wellstar Corporation (Jones and Stokes), Ute ladies’-tresses survey, 

March 2007. 

• Composing amendment updates for North Antelope Rochelle Mine’s 

Biological Assessment/Biological Evaluation. 

Jamie Eberly: Jamie Eberly holds a B.S. in Rangeland Management (Rangeland 

Livestock Production) from Chadron State College, Chadron, Nebraska (2005). 

Ms. Eberly has been employed by BKS Environmental since the fall of 2006. 

She has been conducting mineland reclamation monitoring for various coal 

mines in Campbell and Converse counties, Wyoming since her employment. 

She has also conducted baseline vegetation monitoring for both small mine 

permits as well as coal and uranium operations in the PRB. In addition, she 

has conducted rare plant species surveys, wetland delineations, and 

environmental compliance assessments. T&E and sensitive plant survey 

experience includes: 

• Williams Production Company (Jones and Stokes), West Cripple Creek 

POD, Campbell County, Wyoming. Barr’s milkvetch survey, May 2007. 
Appendix G 

G-130 Final EIS, Wright Area Coal Lease Applications

• Williams Production Company (Jones and Stokes). Rosy Palofaxia 

survey, May 2007. 

• Powertech Corporation, Dewey-Burdock Project. T&E species and 

habitat survey, June 2007. 

• Antelope Road Relocation Project, Campbell County, Wyoming. 

Biological Assessment /Biological Evaluation, April 2008. 

Melody S. Smith: Ms. Smith obtained a B.S. in Rangeland Ecology and 

Watershed Management from the University of Wyoming in 1996. Ms. Smith 

was employed by BKS from 2000 to September 2006 and is experienced in 

vegetation monitoring, vegetation community mapping, soils sampling, soils 

mapping, rare plant species surveys, wetland delineations, and environmental 

compliance assessments. Rare plant (including species of special concern) 

monitoring and survey experience includes: 

• Mimbres figwort (Scrophularia macrantha) survey, Hurley, New Mexico, 

1997. 

• Sneed pincushion cactus (Coryphantha sneedii) monitoring, Fort Bliss, 

Texas, 1998. 

• Alamo beardtongue (Penstemon alamosensis) monitoring, Fort Bliss, 

Texas, 1998. 

• Hueco rock daisy (Perityle huecoensis) monitoring, Fort Bliss, Texas, 

1998. 

• Desert night-blooming cereus (Peniocereus greggii var. greggii) 

monitoring, Fort Bliss, Texas, 1998. 

• Organ mountains evening primrose (Oenothera organensis) monitoring, 

Fort Bliss, Texas, 1998. 

• Ute Ladies' Tresses (Spiranthes diluvialis) surveys, Campbell and 

Sheridan counties, Wyoming, 2002-2005. Nine individuals of nearest 

known population on unnamed tributary of Antelope Creek identified 

and observed in August 2003, expert contacts at various times by BKS 

include Ernie Nelson and Walt Fertig (University of Wyoming) as well as 

Bonnie Heidel and George Jones (Wyoming Natural Diversity Database). 

• Barr’s milkvetch (Astragalus barrii) surveys, various locations, Campbell 

County, Wyoming, 2004 and 2005. New populations identified in 2005. 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-131 

G-14.0 REFERENCES AND LITERATURE CITED 

Arditti, J. and A.K.A. Ghani, 2000, Tansley review No. 110-Numerical and 

physical properties of orchid seeds and their biological implications. 

New Phytol 145: 367-421. 

Arft, A.M., 1995, The genetics, demography, and conservation management of 

rare orchid Spiranthes diluvialis. PhD dissertation. University of 

Colorado, Boulder, CO. 

Black-footed Ferret Recovery Implementation Team (BFFRIT), 2009, Blackfooted Ferret Recovery Program website: 

<http://www.blackfootedferret.org/index.htm>. 

Brown, P.M., 2008, Spiranthes diluvialis new to Canada. North American 

Native Orchid Journal. Vol. 14(2): 69. 

Bureau of Land Management (BLM), 1998, Final EIS for the Powder River Coal 

Lease Application (WYW136142) and Thundercloud Coal Lease 

Application (WYW136458), Casper District Office. 

, 2001a, Approved Resource Management Plan for Public Lands 

Administered by the Bureau of Land Management Buffalo Field Office. 

U.S. Department of the Interior, Bureau of Land Management, Buffalo 

Field Office, Buffalo, Wyoming. Available from website: 

<http://www.blm.gov/wy/st/en/info/NEPA/documents.html>. 

, 2001b, Final Environmental Impact Statement for the North Jacobs 

Ranch Coal Lease Application (WYW146744). U.S. Department of 

Interior, Bureau of Land Management, Casper Field Office, Casper, 

Wyoming. 

, 2003, Final South Powder River Basin Coal Environmental Impact 

Statement, December 2003, Casper Field Office, Casper, Wyoming. 

, 2005, Statewide Programmatic Biological Assessment: Blowout 

Penstemon (Penstemon haydenii). Final report prepared by Greystone, 

submitted to BLM Wyoming State Office, Cheyenne, Wyoming, August 

2005. Available from website: 

<http://www.blm.gov/pgdata/etc/medialib/blm/wy/programs/botany/

bio-assessmnts.Par.62741.File.dat/blowout-penst.pdf>. 

, 2008, Final Environmental Impact Statement for the West Antelope II 

Coal Lease Application. U.S. Department of the Interior, Bureau of Land 

Management, Casper Field Office, Casper, Wyoming, December 2008. 
Appendix G 

G-132 Final EIS, Wright Area Coal Lease Applications

, 2009, Powder River Basin coal leases by application data sheets. 

Available from website: <http://www.blm.gov/wy/st/en/programs/

energy/Coal_Resources/PRBCoal/lba_title.html>. 

Fertig, W., 2000, Survey for Ute ladies’-tresses (Spiranthes diluvialis) along the 

Sweetwater River in Pathfinder National Wildlife Refuge. Wyoming 

Natural Diversity Database, University of Wyoming, Laramie. 15 pp. 

, 2001, 2000 Survey for Blowout Penstemon (Penstemon haydenii) in 

Wyoming. A report prepared for the Bureau of Land Management 

Wyoming State Office. Wyoming Natural Diversity Database, University 

of Wyoming, Laramie. 

Fertig, W., and G. Beauvais, 1999, Wyoming Plant and Animal Species of 

Special Concern. Unpublished report. Wyoming Natural Diversity 

Database, Laramie, Wyoming. 

Fertig, W., R. Black, and P. Wolken, 2005, Rangewide status review of Ute 

ladies’-tresses (Spiranthes diluvialis). Report prepared for the U.S. Fish 

and Wildlife Service and Central Utah Water Conservancy District, 

September 30, 2005. 

Flessner, T.R., 1988, Propagation, establishment, and ecological characteristics 

of Penstemon haydenii S. Wats. Master of Science Thesis. University of 

Nebraska, Lincoln. 

Forrest, S.C., T.W. Clark, L. Richardson, and T.M. Campbell III, 1985, Blackfooted Ferret Habitat: Some Management and Reintroduction 

Considerations, Wyoming BLM Wildlife Technical Bulletin #2, 49 pp. 

Fritz, M., J. Stubbendieck, and W. Jobman, 1992, Blowout penstemon 

(Penstemon haydenii S. Wats.) recovery plan. Prepared for Region 6 U.S. 

Fish and Wildlife Service, Denver, Colorado. Available from website: 

<http://ecos.fws.gov/docs/recovery_plans/1992/920717.pdf>. 

Grenier, M., 2003, An Evaluation of Black-footed Ferret Block Clearances in 

Wyoming: Completion Report, Wyoming Game and Fish Department, 

Lander, Wyoming, 16pp. 

Heidel, B., 2001, Monitoring Ute ladies’-tresses (Spiranthes diluvialis) in 

Jefferson County, Montana, 1996-2000. Report to Bureau of Land 

Management. Montana Natural Heritage Program. Helena, Montana. 

, 2007, Survey of Spiranthes diluvialis (Ute ladies’-tresses) in eastern 

Wyoming (Campbell, Converse, Goshen, Laramie, Niobrara, and Platte 

counties), 2005-2006. Prepared for BLM and TBNG. Wyoming Natural 

Diversity Database, University of Wyoming, Laramie. 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-133 

Heidel, B., W. Fertig, F. Bloomquist, and T. Abbott, 2007, Wyoming’s 

Threatened and Endangered Plant Species: Blowout Penstemon. 

Wyoming BLM in collaboration with Wyoming Natural Diversity 

Database. 

, 2008, Wyoming’s Threatened and Endangered Species: Ute Ladies’-

tresses Orchid. Wyoming Bureau of Land Management in collaboration 

with Wyoming Natural Diversity Database. 

Hillman, C.N. and T.W. Clark, 1980, Mustela nigripes, Mammalian Species No. 

126. 

Intermountain Resources (IR), 2007, Personal communication with Russell 

Tait, October 2007. 

Jacobs Ranch Coal Company (JRCC), 2009, Jacobs Ranch Mine Permit 

Application, WDEQ/LQD Surface Mine Permit 271-T6, approved 

November 19, 2004. On file at WDEQ/LQD offices in Cheyenne and 

Sheridan, Wyoming. 

Jones & Stokes (J&S), 2008, Personal communication with Gwyn McKee, 

December 2008. 

Kelly, B.T., 2008, Memorandum from Brian Kelly, Field Supervisor, USFWS 

Wyoming State Office, Cheyenne, Wyoming to Mary Peterson, USFS 

Supervisor’s Office regarding current list of T&E species, Medicine Bow 

and Routt National Forests and Thunder Basin National Grassland, 

Laramie, Wyoming. 

Lesica, P. and B. Steele, 1994, Prolonged dormancy in vascular plants and 

implications for monitoring studies. Natural Areas Journal 14: 209-212. 

Miller, B., R.P. Reading, and S. Forrest, 1996, Prairie night: Black-footed 

ferrets and the recovery of endangered species, Smithsonian Institution 

Press, Washington, D.C. 

Moseley, R., 1998, Ute ladies’-tresses (Spiranthes diluvialis) in Idaho: 1997 and 

1998 Status Reports. Idaho Bureau of Land Management, Technical 

Bulletin No. 98-16. 23 pp. 

Powder River Coal, LLC (PRC), 2009, North Antelope Rochelle Mine Permit 

Application, WDEQ/LQD Surface Mine Permit 569-T7, approved July 28, 

2009. On file at WDEQ/LQD offices in Cheyenne and Sheridan, 

Wyoming. 

Reheis, M.A., and D.A. Coates, 1987, Surficial Geologic Map of the Reno 

Junction 30’ × 60’ Quadrangle, Campbell and Weston Counties, 

Wyoming. U.S. Geological Survey Coal Investigations Map C-106. 
Appendix G 

G-134 Final EIS, Wright Area Coal Lease Applications

Rose, B.J., 1973, History of prairie dogs in South Dakota. In: Black-footed 

Ferret-Prairie Dog Workshop Proceedings, September 4-6, 1973. South 

Dakota State University, Brookings, pp. 76-77. 

Sipes, S.D., and V.J. Tepedino, 1995, Reproductive biology of the rare orchid 

Spiranthes diluvialis: breeding system, pollination and implications for 

conservation. Conservation Biology 9(4): 929-938. 

Stubbendieke, J. and K. Kottas, 2007, Blowout Penstemon (Penstemon 

haydenii) Endangered Species, Report No. SPR-P1 (07) P583. 

Department of Agronomy and Horticulture, University of Nebraska – 

Lincoln., sponsored by Nebraska Department of Roads 

Thunder Basin Coal Company (TBCC), 2005, Black Thunder Mine Permit 

Application, WDEQ/LQD Surface Mine Permit 233-T7, approved 

November 1, 2005. On file at WDEQ/LQD offices in Cheyenne and 

Sheridan, Wyoming. 

Tyler, J.D., 1968, Distribution and vertebrate associates of the black-tailed 

prairie dog in Oklahoma. PhD Dissertation, University of Oklahoma, 

Norman, 85 pp. 

University of Wyoming, 2008, Wyoming Natural Diversity Database - State 

Species Abstract (Penstemon haydenii) Blowout Penstemon. By Walter 

Fertig, updated by Bonnie Heidel, September 17, 2008. Available from 

website: 

<http://www.uwyo.edu/wynddsupport/docs/Reports/SpeciesAbstracts/

Penstemon_haydenii.pdf>. 

U.S. Department of Agriculture-Forest Service (USFS), 2001a, Final 

Environmental Impact Statement for the Northern Great Plains 

Management Plans Revision for Thunder Basin National Grassland. May 

2001. Available from website: 

<http://www.fs.fed.us/ngp/plan/feis-chpts-appx.htm>. 

, 2001b, Land and Resource Management Plan for the Thunder Basin 

National Grassland, Medicine Bow-Routt National Forest, Rocky 

Mountain Region. 

, 2002a, Final Environmental Impact Statement and Land and Resource 

Management Plan Revision Record of Decision for the Thunder Basin 

National Grassland, July 31, 2002. Available from website: 

<http://www.fs.fed.us/r2/mbr/projects/forestplans/thunderbasin/pdfd

oc/rod/tbng_rod_07212002.pdf>. 

, 2002b, Supplemental Information Report disclosing changes to blacktailed prairie dog habitat within proposed management area 3.63 of the 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-135 

Thunder Basin National Grassland Plan resulting from the 2001 Sylvatic 

plague outbreak. January 14, 2002. 

, 2009, Restoring Blowout Penstemon (Penstemon haydenii) in Nebraska, 

by Tim Griffin, Bessey Ranger District, USFS. Available from website: 

<http://www.fs.fed.us/wildflowers/rareplants/conservation/success/pe

nstemon_haydenii_restoration.shtml>. 

U.S. Fish and Wildlife Service (USFWS), 1989, Black-footed Ferret Survey 

Guidelines for Compliance with the Endangered Species Act. U.S. Fish 

and Wildlife Service, Denver, Colorado and Albuquerque, New Mexico. 

, 1992a, Endangered and threatened wildlife and plants; final rule to list 

the plant Spiranthes diluvialis (Ute ladies’-tresses) as a threatened 

species. Federal Register 57(12): 2048-2054. 

, 1992b, Interim Survey Requirement for Ute Ladies’-tresses Orchid 

(Spiranthes diluvialis), November 23, 1992. Available from website: 

<http://www.fws.gov/mountainprairie/endspp/protocols/UteLadiesTresses1992.pdf.> 

, 1995, Ute ladies’-tresses (Spiranthes diluvialis) recovery plan. U.S. Fish 

and Wildlife Service, Denver, Colorado, 46 pp. 

, 2002, Biological and Conference Opinion for the Powder River Basin Oil 

and Gas Project, Campbell, Converse, Johnson, and Sheridan Counties, 

Wyoming, Cheyenne, 51 pp. 

, 2004, File letter ES-1411/BFF/WY7746 issuing block clearance for 

black-footed ferrets in all black-tailed prairie dog colonies throughout 

Wyoming, and select white-tailed prairie dog colonies, Wyoming Field 

Office of the U.S. Fish and Wildlife Service, Cheyenne. 

, 2005, Memorandum from Brian Kelly, Field Supervisor, USFWS 

Wyoming State Office, Cheyenne, Wyoming, to James Murkin, BLM, Field 

Office Manager, Casper Field Office, Casper, Wyoming, dated February 

15, 2005. 

, 2007, Memorandum letter from Brian Kelly, Field Supervisor, USFWS 

Wyoming State Office, Cheyenne, Wyoming, to Chris Hanson, BLM Field 

Manager, Buffalo Field Office, Buffalo, Wyoming, dated August 8, 2007. 

, 2008, Endangered, Threatened, and Candidate Species and Designated 

Critical Habitat for Wyoming Counties, February 2008. Available from 

website: <http://www.fws.gov/mountainprairie/endspp/CountyLists/

Wyoming.pdf>. 
Appendix G 

G-136 Final EIS, Wright Area Coal Lease Applications

, 2009a, Memorandum letter from the Field Supervisor, USFWS Wyoming 

Field Office, Cheyenne, Wyoming, to the Field Manager, BLM Buffalo 

Field Office, Buffalo, Wyoming, dated May 22, 2009. Subject: Species 

List for Buffalo Field Office 

, 2009b, Letter from Brian Kelly, Field Supervisor, USFWS Wyoming Field 

Office, Cheyenne, Wyoming, to Robert Sprentall, District Ranger, Douglas 

Ranger District, Medicine Bow-Routt National Forest, Douglas, Wyoming, 

dated May 22, 2009. Subject: Species List for Thunder Basin National 

Grassland. 

, 2009c, Federal Endangered and Threatened Species that Occur in or 

may be Affected by Projects in CAMPBELL County, Wyoming. Last 

updated August 2009. Available from website: 

<http://www.fws.gov/wyominges/PDFs/CountySpeciesLists/Campbellsp.pdf>. 

, 2009d, Ute ladies’-tresses (Spiranthes diluvialis), Species Profile, 

Environmental Conservation Online System. Available from website: 

<http://ecos.fws.gov/speciesProvile/profile/speciesProvile.action?spcode

=Q2WA#lifeHistory>. 

, 2009e, Black-footed ferret (Mustela nigripes), Species Profile, 

Environmental Conservation Online System. Available from website: 

<http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=

A004>. 

, 2010, “Questions and Answers for the Greater Sage-Grouse Status 

Review,” U.S. Fish and Wildlife Service Website on Endangered Species. 

Available from website as of March 2010: 

<http://www.fws.gov/mountain-prairie/species/birds/sagegrouse/

03052010Q&A.pdf>. 

U.S. Fish and Wildlife Service, National Wetlands Inventory (USFWS NWI), 

1980, National Wetlands Inventory data for portions of Wyoming: Spatial 

Data and Visualization Center, Laramie, Wyoming. Available from 

website: <http://sdvc.uwyo.edu/24K/nwi.html>. 

Ver Ploeg, A.J., and C.S. Boyd, 2003, Preliminary Geologic Map of the Reno 

Junction 30’ × 60’ Quadrangle, Campbell and Weston Counties, 

Wyoming. Wyoming State Geological Survey, Map Series 62. 

Weedon, R.R., D.J. Norton, and J. Stubbendiecke, 1982, Blowout penstemon 

(P. haydenii S. Wats.): A rare Sandhills endemic (Nebraska). Restoration 

and Management Notes 1:213. 
Appendix G 

Final EIS, Wright Area Coal Lease Applications G-137 

Wells, T.C.E., 1981, Population ecology of terrestrial orchids. Pp. 281-295. In: 

H. Synge, ed. The Biological Aspects of Rare Plant Conservation. John 

Wiley and Sons, Ltd., London, G.B. 

Wyoming Game and Fish Department (WGFD), 2007, Letter from John 

Emmerich, Deputy Director, WGFD, Cheyenne, Wyoming, to Sarah 

Bucklin, BLM, Casper Field Office, Casper, Wyoming, dated July 5, 2007. 

Wyoming GIS Coordinate Structure (WGCS), 2002, 2002 Color Infrared Aerial 

Photography - Digital Orthophoto Quads, Wyoming Geographic 

Information Advisory Council (WGIAC), Wyoming Spatial Data 

Clearinghouse. Available from website: 

<http://wgiac2.state.wy.us/html/doqq752002/43105.asp>. 
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 H 

Final EIS, Wright Area Coal Lease Applications H-i 

TABLE OF CONTENTS 

H-1.0 PROJECT AREA DESCRIPTIONS.................................................. H-1

H-1.1 North Hilight Field, South Hilight Field, and West Hilight 

Field LBA Tracts................................................................... H-1

H-1.2 West Jacobs Ranch LBA Tract .............................................. H-1

H-1.3 North and South Porcupine LBA Tracts ................................ H-2

H-1.4 Description of General Analysis Areas................................... H-2

H-2.0 BLM SENSITIVE SPECIES EVALUATION...................................... H-3

H-2.1 Introduction ......................................................................... H-3

H-2.2 Species Habitat and Occurrence ........................................... H-3

H-3.0 USFS REGION 2 SENSITIVE SPECIES EVALUATION ................. H-16

H-3.1 Introduction ........................................................................H-16

H-3.2 Species Habitat and Occurrence on USFS Lands Within 

the General Wright Analysis Area, and the Direct and 

Indirect Direct Effects on Those Species...............................H-24

H-3.2.1 Prairie moonwort................................................. H-31

H-3.2.2 Narrowleaf moonwort........................................... H-32

H-3.2.3 Leathery grapefern............................................... H-33

H-3.2.4 Foxtail sedge ....................................................... H-33

H-3.2.5 Elliptic spikerush ................................................ H-34

H-3.2.6 Hall’s fescue ........................................................ H-35

H-3.2.7 Wood lily ............................................................. H-35

H-3.2.8 Largeflower triteleia ............................................. H-36

H-3.2.9 Barr’s milkvetch .................................................. H-37

H-3.2.10 Smooth goosefoot ................................................ H-38

H-3.2.11 Flat-top goldentop ............................................... H-38

H-3.2.12 Rosy palafox........................................................ H-39

H-3.2.13 Lemonscent......................................................... H-40

H-3.2.14 Larchleaf beardtongue......................................... H-41

H-3.2.15 Wooly twinpod..................................................... H-41

H-3.2.16 Visher’s buckwheat ............................................. H-42

H-3.2.17 Highbush-cranberry ............................................ H-43

H-3.2.18 Northern leopard frog .......................................... H-43

H-3.2.19 Black-tailed prairie dog........................................ H-51

H-3.2.20 Swift Fox ............................................................. H-59

H-3.2.21 Long-billed curlew ............................................... H-64

H-3.2.22 Ferruginous hawk ............................................... H-66

H-3.2.23 Burrowing owl ..................................................... H-72

H-3.2.24 Chestnut-collared longspur ................................. H-83

H-3.2.25 McCown’s Longspur ............................................ H-85

H-3.2.26 Greater sage-grouse............................................. H-87

H-3.2.27 Bald eagle.......................................................... H-100

H-3.2.28 Mountain plover ................................................ H-104

H-3.2.29 Loggerhead shrike ............................................. H-107

H-3.2.30 Brewer’s sparrow............................................... H-110
Appendix H 

TABLE OF CONTENTS (Continued) 

H-ii Final EIS, Wright Area Coal Lease Applications

H-4.0 CUMULATIVE EFFECTS REGARDING SENSITIVE SPECIES..... H-112

H-4.1 Species Associated Primarily With Short Grasses or Prairie 

Dog Colonies .....................................................................H-113

H-4.2 Mixed Sagebrush and/or Mid-grass Species ......................H-114

H-4.3 Sagebrush Obligates..........................................................H-114

H-4.4 Tree or Wetland/Aquatic Species .......................................H-115

H-5.0 TBNG PLAN COMPLIANCE....................................................... H-116

H-6.0 REQUIRED MITIGATION AND RECOMMENDED MONITORING.H-116

H-7.0 USFS MANAGEMENT INDICATOR SPECIES EVALUATION....... H-117

H-7.1 Introduction ......................................................................H-117

H-7.2 Species Evaluated and Rationale .......................................H-117

H-8.0 REFERENCES AND LITERATURE CITED ................................. H-119

LIST OF TABLES 

Table H-1. BLM Sensitive Species for the Buffalo Field Office, Habitat 

Requirements, and Observations within the General Analysis 

Area for the North Hilight Field LBA Tract ................................ H-4

Table H-2. BLM Sensitive Species for the Buffalo Field Office, Habitat 

Requirements, and Observations within the General Analysis 

Area for the South Hilight Field LBA Tract................................ H-6

Table H-3. BLM Sensitive Species for the Buffalo Field Office, Habitat 

Requirements, and Observations within the General Analysis 

Area for the West Hilight Field LBA Tract.................................. H-8

Table H-4. BLM Sensitive Species for the Buffalo Field Office, Habitat 

Requirements, and Observations within the General Analysis 

Area for the West Jacobs Ranch LBA Tract..............................H-10

Table H-5. BLM Sensitive Species for the Buffalo Field Office and 

Habitat Requirements and Observations within the General 

Analysis Area for the North Porcupine LBA Tract.....................H-12

Table H-6. BLM Sensitive Species for the Buffalo Field Office and 

Habitat Requirements and Observations within the General 

Analysis Area for the South Porcupine LBA Tract ....................H-14

Table H-7. USFS Region 2 Sensitive Species List and Status for the 

Entire Thunder Basin National Grassland (USFS 2007) ...........H-17
Appendix H 

TABLE OF CONTENTS (Continued) 

Final EIS, Wright Area Coal Lease Applications H-iii

Table H-8. USFS Region 2 Sensitive Species Status on TBNG and on 

USFS Lands Within the General Wright Analysis Area, and 

Habitat Suitability on USFS Lands Within the General 

Wright Analysis Area (Provided by USFS Douglas Ranger 

District, July 2007) .................................................................H-21

Table H-9. USFS Region 2 Species of Local Concern Status on TBNG 

and on USFS Lands Within the General Wright Analysis 

Area, and Habitat Suitability on USFS Lands Within the 

General Wright Analysis Area (provided by Roche 2009) ..........H-23

LIST OF FIGURES 

Figure H-1. USFS Region 2 Sensitive Wildlife Species Survey Area for the 

North Hilight Field LBA Tract ..................................................H-26

Figure H-2. USFS Region 2 Sensitive Wildlife Species Survey Area for the 

South Hilight Field LBA Tract..................................................H-27

Figure H-3. USFS Region 2 Sensitive Wildlife Species Survey Area for the 

West Hilight Field LBA Tract....................................................H-28

Figure H-4. USFS Region 2 Sensitive Wildlife Species Survey Area for the 

North Porcupine LBA Tract......................................................H-29

Figure H-5. USFS Region 2 Sensitive Wildlife Species Survey Area for the 

South Porcupine LBA Tract .....................................................H-30
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-1 

H-1.0 PROJECT AREA DESCRIPTIONS 

H-1.1 North Hilight Field, South Hilight Field, and West Hilight Field 

LBA Tracts 

Under the Proposed Actions for the North Hilight Field, South Hilight Field, and 

West Hilight Field LBA Tracts, Bureau of Land Management (BLM) would hold 

a separate competitive lease sale and issue a separate lease for the federal coal 

lands included in each tract as applied for by the applicant, Ark Land 

Company (ALC), or under other Alternatives (see Figures 2-1, 2-2, and 2-3, 

respectively, and land descriptions in Sections 2.1, 2.2, and 2.3, respectively, of 

this EIS). In each case, it is assumed that the applicant for the tracts, ALC, 

would be the successful bidder on each tract, and that the tract would be 

mined as a maintenance lease for the existing Black Thunder Mine. 

The surface estate on the North Hilight Field LBA Tract as applied for is 

composed of privately owned lands. Under Alternative 2, additional lands, 

including federal lands managed by U.S. Department of Agriculture-Forest 

Service (USFS), were added by BLM to be analyzed for possible inclusion in 

that tract. The surface estate on the South Hilight Field LBA Tract as applied 

for is composed of privately owned and federally owned lands managed by 

USFS. Under Alternative 2, additional lands, including federal lands managed 

by USFS, were added by BLM to be analyzed for possible inclusion in that 

tract. The surface estate on the West Hilight Field LBA Tract as applied for is 

composed of privately owned and federally owned lands managed by USFS. 

Under Alternatives 2 and 3, additional lands, including federal lands managed 

by USFS, were added by BLM to be analyzed for possible inclusion in that 

tract. Additional information on surface ownership and current land uses can 

be found in Section 3.11 of this EIS. All of these federally owned lands 

administered by the USFS are within the Thunder Basin National Grasslands 

(TBNG). 

H-1.2 West Jacobs Ranch LBA Tract 

Under the Proposed Action for the West Jacobs Ranch LBA Tract, BLM would 

hold a competitive lease sale and issue a lease for the federal coal lands 

included in the tract as applied for by the applicant, Jacobs Ranch Coal 

Company (JRCC), or under another Alternative (see Figure 2-4 and land 

descriptions in Section 2.4 of this EIS). 

The Jacobs Ranch Mine was acquired by Arch Coal, Inc. on October 1, 2009. 

ALC, a wholly-owned subsidiary of Arch Coal, Inc., will integrate the mining 

operations of the Jacobs Ranch Mine with the mining operations of the Black 

Thunder Mine. ALC’s intention is to consolidate the permits for the Jacobs 

Ranch Mine and the Black Thunder Mine. In this Biological Evaluation (BE), 

the applicant for the West Jacobs Ranch LBA Tract will henceforth be referred 

to as ALC. It is assumed that the applicant for the tract, ALC, would be the 
Appendix H 

H-2 Final EIS, Wright Area Coal Lease Applications

successful bidder, and that the tract would be mined as a maintenance lease 

for the existing Jacobs Ranch Mine. 

The surface estate on the West Jacobs Ranch LBA Tract as applied for is 

composed entirely of privately owned lands. Under Alternative 2, additional 

lands, all privately owned, were added by BLM to be analyzed for possible 

inclusion in that tract. Additional information on surface ownership and 

current land uses can be found in Section 3.11 of this EIS. 

H-1.3 North and South Porcupine LBA Tracts 

Under the Proposed Actions for the North Porcupine and South Porcupine LBA 

Tracts, BLM would hold a separate competitive lease sale and issue a separate 

lease for the federal coal lands included in each tract as applied for by the 

applicant, BTU Western Resources, Inc. (BTU), or under other Alternatives (see 

Figures 2-5 and 2-6, respectively, and land descriptions in Sections 2.5 and 

2.6, respectively, of this EIS). In each case, it is assumed that the applicant for 

the tracts, BTU, would be the successful bidder on each tract, and that the 

tract would be mined as a maintenance lease for the existing North Antelope 

Rochelle Mine. 

The surface estate on the North Porcupine LBA Tract as applied for is 

composed of privately owned and federally owned lands managed by USFS. 

Under Alternative 2, additional lands, including federal lands managed by 

USFS, were added by BLM to be analyzed for possible inclusion in that tract. 

The surface estate on the South Porcupine LBA Tract as applied for is 

composed of privately owned and federally owned lands managed by USFS. 

Under Alternative 2, additional lands, including federal lands managed by 

USFS, were added by BLM to be analyzed for possible inclusion in that tract. 

Additional information on surface ownership and current land uses can be 

found in Section 3.11 of this EIS. All of these federally owned lands 

administered by the USFS are within the TBNG. 

H-1.4 Description of General Analysis Areas 

The BLM study area for each of these six LBA tracts is defined as the original 

tract as applied for, plus all lands that BLM is considering adding to the tract. 

The general analysis area for each of these six LBA tracts 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. The general analysis area for the North Hilight Field 

LBA Tract does not include lands within Black Thunder Mine’s current permit 

area. The general analysis area for the South Hilight Field LBA Tract includes 

some lands within Black Thunder Mine’s current permit area. The general 

analysis area for the West Hilight Field LBA Tract does not include lands within 

Black Thunder Mine’s current permit area. The general analysis area for the 

West Jacobs Ranch LBA Tract does not include lands within Jacobs Ranch 

Mine’s current permit area. The general analysis area for the North Porcupine 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-3

LBA Tract is almost entirely within North Antelope Rochelle Mine’s current 

permit area. The general analysis area for the South Porcupine LBA Tract is 

almost entirely within North Antelope Rochelle Mine’s current permit area. For 

the purpose of this sensitive species evaluation, the general Wright analysis 

area is defined as the area encompassing all six of these LBA tracts’ general 

analysis areas. 

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

are managed by BLM, and the federally owned surface within these general 

analysis areas are administered by the USFS; therefore, both BLM and USFS 

sensitive species evaluations must be completed as part of this EIS. 

H-2.0 BLM SENSITIVE SPECIES EVALUATION 

H-2.1 Introduction 

BLM Wyoming has prepared a list of sensitive species to focus species 

management efforts towards maintaining habitats under a multiple use 

mandate. The authority for this policy and guidance comes from the 

Endangered Species Act (ESA), as amended; Title II of the Sikes Act, as 

amended; the Federal Land Policy Management Act of 1976 (FLPMA) (43 U.S.C. 

1716); Department Manual 235.1.1A; and BLM Manual 6840.06 E. Sensitive 

Species. 

The goals of BLM’s sensitive species policy are to: 

• Maintain vulnerable species and habitat components in functional BLM 

ecosystems. 

• Ensure sensitive species are considered in land management decisions. 

• Prevent a need for species listing under the ESA. 

• Prioritize needed conservation work with an emphasis on habitat. 

H-2.2 Species Habitat and Occurrence 

BLM sensitive species were listed for their ranges within the BLM Buffalo Field 

Office (24 species total). Some sensitive species could or do occur within one or 

more of the general analysis areas for these six LBA tracts. Specialized habitat 

requirements (i.e., caves, cliffs, coniferous forests, calcareous rock outcrops) 

make occupation for other sensitive species unlikely. 

Tables H-1 through H-6 list BLM sensitive species, summarize their habitat 

requirements, and indicate if they have been observed on or around the general 

analysis areas for the LBA tracts. These tables represent the most current 

sensitive species lists (BLM 2002), and observations were based on field 

surveys and file searches completed in 2007 and 2008. Additional information 

on occurrences of these species on the tracts and surrounding wildlife survey 

areas can be found in Section 3.10 of this EIS. 
Appendix H 

 H-4 Final EIS, Wright Area 

Table H-1. BLM Sensitive Species for the Buffalo Field Office, Habitat Requirements, and O

General Analysis Area for the North Hilight Field LBA Tract. 

Common Name (scientific name) Habitat Field Observations Amphibians Northern leopard frog (Rana pipiens) Beaver ponds, permanent water in plains and foothills No1Spotted frog (Ranus pretiosa) Ponds, sloughs, small streams No1 BirdsBaird’s sparrow (Ammodramus bairdii) Grasslands, weedy fields No Brewer’s sparrow (Spizella breweri) Basin-prairie shrub Yes, Common Breeder Burrowing owl (Athene cunicularia) Grasslands, basin-prairie shrub Yes, Uncommon BreedeFerruginous hawk (Buteo regalis) Basin-prairie shrub, grasslands, rock outcrops Yes, Common Breeder Greater sage-grouse (Centrocercus urophasianus) Basin-prairie shrub, mountain-foothill shrub Yes, Historic Common 

Breeder 

Loggerhead shrike (Lanius ludovicianus) Basin-prairie shrub, mountain-foothill shrub Yes, Uncommon ForageLong-billed curlew (Numenius americanus) Grasslands, plains, foothills, wet meadows Yes, Infrequent Migrant Northern goshawk (Accipiter gentilis) Conifer and deciduous forests No1 Peregrine falcon (Falco peregrinus) Cliffs usually along waterways No1Sage sparrow (Amphispiza billneata) Basin-prairie shrub, mountain-foothill shrub No1Sage thrasher (Oreoscoptes montanus) Basin-prairie shrub, mountain-foothill shrub Yes, Uncommon BreedeTrumpeter swan (Cygnus buccinator) Lakes, ponds, rivers No1 White-faced ibis (Plegadis chihi) Marshes, wet meadows No1 Yellow-billed cuckoo (Coccyzus americanus) Open woodlands, streamside willow and alder groves No1
Final EIS, Wright Area Coal Lease Applications H-5 

Table H-1. BLM Sensitive Species for the Buffalo Field Office, Habitat Requirements, and O

General Analysis Area for the North Hilight Field LBA Tract (Continued). 

Common Name (scientific name) Habitat Field Observations FishYellowstone cutthroat trout (Oncoryhynchus clarki) Cold water streams and lakes No1 MammalsFringed myotis (Myotis thysanodes) Conifer forests, woodland chaparral, caves and mines No1 Long-eared myotis (Myotis evotis) Conifer and deciduous forest, caves and mines No1 Spotted bat (Euderma maculatum) Cliffs over perennial water, basin-prairie shrub No1 Swift fox (Vulpes velox) Grasslands No Townsend’s big-eared bat (Corynorhinus townsendii) Forests, basin-prairie shrub, caves and mines NoPlants Porter’s sagebrush (Artemisia porteri) 

Sparsely vegetated badlands of ashy or tufaceous mudstone and clay slopes; 5,300-6,500 ft. elev. No 

William’s wafer parsnip (Cymopterus williamsii) 

Open ridgetops and upper slopes with exposed limestone outcrops or rockslides; 6,000-8,300 ft. elev. No1

1 Habitat generally lacking or very limited 2 Former listed or candidate species under the ESA automatically revert to BLM Sensitive Species upon delisting or removal from the ESA listing p
Appendix H 

 H-6 Final EIS, Wright Area 

Table H-2. BLM Sensitive Species for the Buffalo Field Office, Habitat Requirements, and O

General Analysis Area for the South Hilight Field LBA Tract. 

Common Name (scientific name) Habitat Field Observations Amphibians Northern leopard frog (Rana pipiens) Beaver ponds, permanent water in plains and foothills No1Spotted frog (Ranus pretiosa) Ponds, sloughs, small streams No1 BirdsBaird’s sparrow (Ammodramus bairdii) Grasslands, weedy fields No1Brewer’s sparrow (Spizella breweri) Basin-prairie shrub Yes, Common Breeder Burrowing owl (Athene cunicularia) Grasslands, basin-prairie shrub No Ferruginous hawk (Buteo regalis) Basin-prairie shrub, grasslands, rock outcrops Yes, Common Breeder Greater sage-grouse (Centrocercus urophasianus) Basin-prairie shrub, mountain-foothill shrub No Loggerhead shrike (Lanius ludovicianus) Basin-prairie shrub, mountain-foothill shrub Yes, Potential Breeder Long-billed curlew (Numenius americanus) Grasslands, plains, foothills, wet meadows Yes, Infrequent Migrant Northern goshawk (Accipiter gentilis) Conifer and deciduous forests No1 Peregrine falcon (Falco peregrinus) Cliffs usually along waterways No1Sage sparrow (Amphispiza billneata) Basin-prairie shrub, mountain-foothill shrub No1 Sage thrasher (Oreoscoptes montanus) Basin-prairie shrub, mountain-foothill shrub Yes, Uncommon BreedeTrumpeter swan (Cygnus buccinator) Lakes, ponds, rivers No1 White-faced ibis (Plegadis chihi) Marshes, wet meadows No1 Yellow-billed cuckoo (Coccyzus americanus) Open woodlands, streamside willow and alder groves No1
Final EIS, Wright Area Coal Lease Applications H-7 

Table H-2. BLM Sensitive Species for the Buffalo Field Office, Habitat Requirements, and O

General Analysis Area for the South Hilight Field LBA Tract (Continued). 

Common Name (scientific name) Habitat Field Observations FishYellowstone cutthroat trout (Oncoryhynchus clarki) Cold water streams and lakes No1 MammalsFringed myotis (Myotis thysanodes) Conifer forests, woodland chaparral, caves and mines No1 Long-eared myotis (Myotis evotis) Conifer and deciduous forest, caves and mines No1 Spotted bat (Euderma maculatum) Cliffs over perennial water, basin-prairie shrub No1 Swift fox (Vulpes velox) Grasslands No1 (one sighting in 24 yTownsend’s big-eared bat (Corynorhinus townsendii) Forests, basin-prairie shrub, caves and mines NoPlants Porter’s sagebrush (Artemisia porteri) 

Sparsely vegetated badlands of ashy or tufaceous mudstone and clay slopes; 5,300-6,500 ft. elev. No 

William’s wafer parsnip (Cymopterus williamsii) 

Open ridgetops and upper slopes with exposed limestone outcrops or rockslides; 6,000-8,300 ft. elev. No1

1 Habitat generally lacking or very limited 2 Former listed or candidate species under the ESA automatically revert to BLM Sensitive Species upon delisting or removal from the ESA listing p
Appendix H 

 H-8 Final EIS, Wright Area 

Table H-3. BLM Sensitive Species for the Buffalo Field Office, Habitat Requirements, and O

General Analysis Area for the West Hilight Field LBA Tract. 

Common Name (scientific name) Habitat Field Observations Amphibians Northern leopard frog (Rana pipiens) Beaver ponds, permanent water in plains and foothills No Spotted frog (Ranus pretiosa) Ponds, sloughs, small streams No1 BirdsBaird’s sparrow (Ammodramus bairdii) Grasslands, weedy fields No Brewer’s sparrow (Spizella breweri) Basin-prairie shrub Yes, Common Breeder Burrowing owl (Athene cunicularia) Grasslands, basin-prairie shrub No (one nest burrow jusFerruginous hawk (Buteo regalis) Basin-prairie shrub, grasslands, rock outcrops Yes, Common Breeder Greater sage-grouse (Centrocercus urophasianus) Basin-prairie shrub, mountain-foothill shrub No, Infrequent Breeder Loggerhead shrike (Lanius ludovicianus) Basin-prairie shrub, mountain-foothill shrub Yes, Potential Breeder Long-billed curlew (Numenius americanus) Grasslands, plains, foothills, wet meadows Yes, Infrequent Migrant Northern goshawk (Accipiter gentilis) Conifer and deciduous forests No1 Peregrine falcon (Falco peregrinus) Cliffs usually along waterways No1Sage sparrow (Amphispiza billneata) Basin-prairie shrub, mountain-foothill shrub No1Sage thrasher (Oreoscoptes montanus) Basin-prairie shrub, mountain-foothill shrub Yes, Uncommon BreedeTrumpeter swan (Cygnus buccinator) Lakes, ponds, rivers No1 White-faced ibis (Plegadis chihi) Marshes, wet meadows NoYellow-billed cuckoo (Coccyzus americanus) Open woodlands, streamside willow and alder groves No1
Final EIS, Wright Area Coal Lease Applications H-9 

Table H-3. BLM Sensitive Species for the Buffalo Field Office, Habitat Requirements, and O

General Analysis Area for the West Hilight Field LBA Tract (Continued). 

Common Name (scientific name) Habitat Field Observations FishYellowstone cutthroat trout (Oncoryhynchus clarki) Cold water streams and lakes No1 MammalsFringed myotis (Myotis thysanodes) Conifer forests, woodland chaparral, caves and mines No1 Long-eared myotis (Myotis evotis) Conifer and deciduous forest, caves and mines No1 Spotted bat (Euderma maculatum) Cliffs over perennial water, basin-prairie shrub No1 Swift fox (Vulpes velox) Grasslands No1Townsend’s big-eared bat (Corynorhinus townsendii) Forests, basin-prairie shrub, caves and mines NoPlants Porter’s sagebrush (Artemisia porteri) 

Sparsely vegetated badlands of ashy or tufaceous mudstone and clay slopes; 5,300-6,500 ft. elev. No 

William’s wafer parsnip (Cymopterus williamsii) 

Open ridgetops and upper slopes with exposed limestone outcrops or rockslides; 6,000-8,300 ft. elev. No1

1 Habitat generally lacking or very limited 2 Former listed or candidate species under the ESA automatically revert to BLM Sensitive Species upon delisting or removal from the ESA listing p
Appendix H 

 H-10 Final EIS, Wright Area 

Table H-4. BLM Sensitive Species for the Buffalo Field Office, Habitat Requirements, and O

General Analysis Area for the West Jacobs Ranch LBA Tract. 

Common Name (scientific name) Habitat Field Observations Amphibians Northern leopard frog (Rana pipiens) Beaver ponds, permanent water in plains and foothills Yes, Breeder Spotted frog (Ranus pretiosa) Ponds, sloughs, small streams No1 BirdsBaird’s sparrow (Ammodramus bairdii) Grasslands, weedy fields No Brewer’s sparrow (Spizella breweri) Basin-prairie shrub Yes, Common Breeder Burrowing owl (Athene cunicularia) Grasslands, basin-prairie shrub Yes, Breeder Ferruginous hawk (Buteo regalis) Basin-prairie shrub, grasslands, rock outcrops Yes, Common Breeder Greater sage-grouse (Centrocercus urophasianus) Basin-prairie shrub, mountain-foothill shrub Yes, Historic Breeder Loggerhead shrike (Lanius ludovicianus) Basin-prairie shrub, mountain-foothill shrub Yes, Uncommon BreedeLong-billed curlew (Numenius americanus) Grasslands, plains, foothills, wet meadows Yes, Rare Spring M

Breeder 

Northern goshawk (Accipiter gentilis) Conifer and deciduous forests No1 Peregrine falcon (Falco peregrinus) Cliffs usually along waterways No, Limited Habitat, MigSage sparrow (Amphispiza billneata) Basin-prairie shrub, mountain-foothill shrub No Sage thrasher (Oreoscoptes montanus) Basin-prairie shrub, mountain-foothill shrub Yes, Uncommon BreedeTrumpeter swan (Cygnus buccinator) Lakes, ponds, rivers No1 White-faced ibis (Plegadis chihi) Marshes, wet meadows No1 Yellow-billed cuckoo (Coccyzus americanus) Open woodlands, streamside willow and alder groves No1
Final EIS, Wright Area Coal Lease Applications H-11 

Table H-4. BLM Sensitive Species for the Buffalo Field Office, Habitat Requirements, and O

General Analysis Area for the West Jacobs Ranch LBA Tract (Continued). 

Common Name (scientific name) Habitat Field Observations FishYellowstone cutthroat trout (Oncoryhynchus clarki) Cold water streams and lakes No1 MammalsFringed myotis (Myotis thysanodes) Conifer forests, woodland chaparral, caves and mines No1 Long-eared myotis (Myotis evotis) Conifer and deciduous forest, caves and mines No1 Spotted bat (Euderma maculatum) Cliffs over perennial water, basin-prairie shrub No1 Swift fox (Vulpes velox) Grasslands Yes, Opportunistic SighTownsend’s big-eared bat (Corynorhinus townsendii) Forests, basin-prairie shrub, caves and mines No1 Plants Porter’s sagebrush (Artemisia porteri) 

Sparsely vegetated badlands of ashy or tufaceous mudstone and clay slopes; 5,300-6,500 ft. elev. No 

William’s wafer parsnip (Cymopterus williamsii) 

Open ridgetops and upper slopes with exposed limestone outcrops or rockslides; 6,000-8,300 ft. elev. No1

1 Habitat generally lacking or very limited 2 Former listed or candidate species under the ESA automatically revert to BLM Sensitive Species upon delisting or removal from the ESA listing p
Appendix H 

 H-12 Final EIS, Wright Area 

Table H-5. BLM Sensitive Species for the Buffalo Field Office and Habitat Requirements and O

General Analysis Area for the North Porcupine LBA Tract. 

Common Name (scientific name) Habitat Field Observations Amphibians Northern leopard frog (Rana pipiens) Beaver ponds, permanent water in plains and foothills No1Spotted frog (Ranus pretiosa) Ponds, sloughs, small streams No1 BirdsBaird’s sparrow (Ammodramus bairdii) Grasslands, weedy fields No Brewer’s sparrow (Spizella breweri) Basin-prairie shrub Yes, Common Breeder Burrowing owl (Athene cunicularia) Grasslands, basin-prairie shrub Yes, Uncommon BreedeFerruginous hawk (Buteo regalis) Basin-prairie shrub, grasslands, rock outcrops Yes, Breeder Greater sage-grouse (Centrocercus urophasianus) Basin-prairie shrub, mountain-foothill shrub Yes, Common Breeder Loggerhead shrike (Lanius ludovicianus) Basin-prairie shrub, mountain-foothill shrub Yes, Uncommon BreedeLong-billed curlew (Numenius americanus) Grasslands, plains, foothills, wet meadows Yes, Infrequent Migrant Northern goshawk (Accipiter gentilis) Conifer and deciduous forests No1 Peregrine falcon (Falco peregrinus) Cliffs usually along waterways No1Sage sparrow (Amphispiza billneata) Basin-prairie shrub, mountain-foothill shrub No1 Sage thrasher (Oreoscoptes montanus) Basin-prairie shrub, mountain-foothill shrub Yes, Uncommon BreedeTrumpeter swan (Cygnus buccinator) Lakes, ponds, rivers No1 White-faced ibis (Plegadis chihi) Marshes, wet meadows No1 Yellow-billed cuckoo (Coccyzus americanus) Open woodlands, streamside willow and alder groves No1
Final EIS, Wright Area Coal Lease Applications H-13 

Table H-5. BLM Sensitive Species for the Buffalo Field Office and Habitat Requirements and O

General Analysis Area for the North Porcupine LBA Tract (Continued). 

Common Name (scientific name) Habitat Field Observations FishYellowstone cutthroat trout (Oncoryhynchus clarki) Cold water streams and lakes No1 MammalsFringed myotis (Myotis thysanodes) Conifer forests, woodland chaparral, caves and mines No1 Long-eared myotis (Myotis evotis) Conifer and deciduous forest, caves and mines No1 Spotted bat (Euderma maculatum) Cliffs over perennial water, basin-prairie shrub No1 Swift fox (Vulpes velox) Grasslands No1Townsend’s big-eared bat (Corynorhinus townsendii) Forests, basin-prairie shrub, caves and mines No Plants Porter’s sagebrush (Artemisia porteri) 

Sparsely vegetated badlands of ashy or tufaceous mudstone and clay slopes; 5,300-6,500 ft. elev. No 

William’s wafer parsnip (Cymopterus williamsii) 

Open ridgetops and upper slopes with exposed limestone outcrops or rockslides; 6,000-8,300 ft. elev. No1

1 Habitat generally lacking or very limited 2 Former listed or candidate species under the ESA automatically revert to BLM Sensitive Species upon delisting or removal from the ESA listing p
Appendix H 

 H-14 Final EIS, Wright Area 

Table H-6. BLM Sensitive Species for the Buffalo Field Office and Habitat Requirements and O

General Analysis Area for the South Porcupine LBA Tract. 

Common Name (scientific name) Habitat Field Observations Amphibians Northern leopard frog (Rana pipiens) Beaver ponds, permanent water in plains and foothills No1Spotted frog (Ranus pretiosa) Ponds, sloughs, small streams No1 BirdsBaird’s sparrow (Ammodramus bairdii) Grasslands, weedy fields No1Brewer’s sparrow (Spizella breweri) Basin-prairie shrub Yes, Common Breeder Burrowing owl (Athene cunicularia) Grasslands, basin-prairie shrub No Ferruginous hawk (Buteo regalis) Basin-prairie shrub, grasslands, rock outcrops Yes, Historic Breeder Greater sage-grouse (Centrocercus urophasianus) Basin-prairie shrub, mountain-foothill shrub No Loggerhead shrike (Lanius ludovicianus) Basin-prairie shrub, mountain-foothill shrub Yes, Uncommon BreedeLong-billed curlew (Numenius americanus) Grasslands, plains, foothills, wet meadows Yes, Infrequent Migrant Northern goshawk (Accipiter gentilis) Conifer and deciduous forests No1 Peregrine falcon (Falco peregrinus) Cliffs usually along waterways No1Sage sparrow (Amphispiza billneata) Basin-prairie shrub, mountain-foothill shrub No1 Sage thrasher (Oreoscoptes montanus) Basin-prairie shrub, mountain-foothill shrub Yes, Uncommon BreedeTrumpeter swan (Cygnus buccinator) Lakes, ponds, rivers No1 White-faced ibis (Plegadis chihi) Marshes, wet meadows No1 Yellow-billed cuckoo (Coccyzus americanus) Open woodlands, streamside willow and alder groves No1
Final EIS, Wright Area Coal Lease Applications H-15 

Table H-6. BLM Sensitive Species for the Buffalo Field Office and Habitat Requirements and O

General Analysis Area for the South Porcupine LBA Tract (Continued). 

Common Name (scientific name) Habitat Field Observations FishYellowstone cutthroat trout (Oncoryhynchus clarki) Cold water streams and lakes No1 MammalsFringed myotis (Myotis thysanodes) Conifer forests, woodland chaparral, caves and mines No1 Long-eared myotis (Myotis evotis) Conifer and deciduous forest, caves and mines No1 Spotted bat (Euderma maculatum) Cliffs over perennial water, basin-prairie shrub No1 Swift fox (Vulpes velox) Grasslands No Townsend’s big-eared bat (Corynorhinus townsendii) Forests, basin-prairie shrub, caves and mines No Plants Porter’s sagebrush (Artemisia porteri) 

Sparsely vegetated badlands of ashy or tufaceous mudstone and clay slopes; 5,300-6,500 ft. elev. No 

William’s wafer parsnip (Cymopterus williamsii) 

Open ridgetops and upper slopes with exposed limestone outcrops or rockslides; 6,000-8,300 ft. elev. No1

1 Habitat generally lacking or very limited 2 Former listed or candidate species under the ESA automatically revert to BLM Sensitive Species upon delisting or removal from the ESA listing p
Appendix H 

H-16 Final EIS, Wright Area Coal Lease Applications

H-3.0 USFS REGION 2 SENSITIVE SPECIES EVALUATION 

H-3.1 Introduction 

Species that have been identified by the Regional Forester as sensitive species 

must be considered for the Wright Area Coal Lease Applications because the 

general analysis areas for North Hilight Field, South Hilight Field, West Hilight 

Field, North Porcupine, and South Porcupine LBA Tracts include federal lands 

administered by the USFS. There is no USFS administered surface within the 

general analysis area for the West Jacobs Ranch LBA Tract. The purpose of 

this section of this Appendix is to provide information about the potential 

environmental effects that leasing the USFS administered lands would have on 

USFS Region 2 Sensitive wildlife and vegetative species (terrestrial and 

aquatic). 

USFS classifies species as “sensitive” when they meet one or more of the 

following three criteria: 1) the species is declining in numbers or occurrences, 

and evidence indicates it could be proposed for federal listing as threatened or 

endangered if action is not taken to reverse or stop the downward trend; 2) the 

species’ habitat is declining and continued loss could result in population 

declines that lead to federal listing as threatened or endangered if action is not 

taken to reverse or stop the decline; and 3) the species’ population or habitat is 

stable but limited. In addition to these criteria, a ranking system is used to 

identify species for sensitive status, which is outlined in USFS Manual 2670-

2671. Table H-7 lists species that have been identified as “sensitive” for USFS 

Region 2, TBNG (USFS 2007). This table also provides information about the 

status of the species on the TBNG as a whole (not exclusive to USFS lands 

within the general analysis areas for the North Hilight Field, South Hilight 

Field, West Hilight Field, North Porcupine, and South Porcupine LBA Tracts). 

The USFS Douglas Ranger District has reviewed the entire list of animal and 

plant sensitive species for USFS Region 2 and eliminated from further review 

those species that occur on the TBNG but are geographically or biologically 

outside of any effects of the Wright Area Coal Lease Applications. Tables H-8 

and H-9 list the current status of USFS Region 2 sensitive species and species 

of local concern on TBNG and on USFS lands in the general Wright analysis 

area. These tables also indicate suitability of habitat for each species specific 

only to the USFS lands in the general Wright analysis area. The seven plant 

species that are listed in Table H-9 were moved off the Region 2 sensitive 

species list and are now species that are of local concern (Roche 2009). The 

species listed in Tables H-8 and H-9 have been identified as definitely or 

potentially inhabiting the USFS lands within the general Wright analysis area, 

either seasonally or year-round, and therefore may be potentially affected by 

one or more of the Proposed Actions or Alternatives. 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-17 

Table H-7. USFS Region 2 Sensitive Species List and Status for the Entire 

Thunder Basin National Grassland (USFS 2007). 

Status Code: 

K = Known occurrence in vicinity. Date of last observation indicates that species still 

occur in area. 

N = No recent observations; surveys recently completed; may be historic records; potential 

habitat possible. 

S = Suspected occurrence. May be historic records but no recent observations. Suitable 

habitat likely. 

U = Unknown occurrence, more surveys may be needed, may be historic records, potential 

habitat possible. 

D = Dismissed from further analysis. The proposed project area is located outside of the 

species current and historic distribution. 

Scientific Name Common Name 

Status 

on 

TBNG 

Plants: Ferns and Allies 

Botrychium ascendens Trianglelobe moonwort U 

Botrychium campestre Prairie moonwort S 

Botrychium furcatum Forkleaved moonwort U 

Botrychium lineare Narrowleaf moonwort S 

Botrychium paradoxum Peculiar moonwort U 

Lycopodium complanatum Crowfoot clubmoss U 

Selaginella selaginoides Northern spike-moss U 

Plants: Monocots 

Amerorchis rotundifolia Round leaved orchid U 

Calochortus flexuosus Weakstem mariposalily U 

Carex alopecoidea Foxtail sedge S 

Carex diandra Lesserpanicled sedge U 

Carex livida Livid sedge U 

Cypripedium montanum Mountain lady’s slipper U 

Cypripedium parvijlorum Smallyellow ladyslipper U 

Eleocharis elliptica Elliptic spikerush S 

Epipactis gigantea Giant helle borine U 

Eriophorum altaicum var. neogaeum Altai cottongrass U 

Eriophorum chamissonis Chamisso cottonsedge U 

Eriophorum gracile Slender cottonsedge U 

Festuca hallii Hall’s Fescue S 

Kobresia simpliciuscula Simple Kobresia U 

Liparis loeselii Loesel’s twayblade U 

Malaxis brachypoda Adder’s-mouth U 

Platanthera orbiculata Large roundleafed orchid U 

Ptilagrostis porteri Colorado Falseneedlegrass U 

Schoenoplectus hallii Hall’s bulrush U 

Triteleia grandiflora Largeflower triteleia S 
Appendix H 

H-18 Final EIS, Wright Area Coal Lease Applications 

Table H-7. USFS Region 2 Sensitive Species List and Status for the Entire 

Thunder Basin National Grassland (Continued). 

Scientific Name Common Name 

Status 

on 

TBNG 

Plants: Dicots 

Aquilegia chrysantha var. rydbergii Golden Columbine U 

Aquilegia laramiensis Laramie Columbine U 

Armeria maritima var. siberica Sea pink U 

Asclepias uncialis Dwarf milkweed U 

Astragalus barrii Barr’s milkvetch K 

Astragalus leptaleus Park milkvetch U 

Astragalus missouriensis var.

humistratus 

Missouri milkvetch U 

Astragalus proximus Aztec milkvetch U 

Astragalus ripleyi Ripleys milkvetch U 

Astragalus wetherillii Wetherill milkvetch U 

Braya glabella Smooth rockcress U 

Chenopodium cycloides Sandhill goosefoot U 

Cirsium perplexans Rocky Mountain thistle U 

Descurainia torulosa Wind River tansymustard U 

Draba exunguiculata Grays Peak whitlowgrass U 

Draba grayana Hitchcock Gray's Peak 

whitlow-grass 

U 

Draba smithii Smiths whitlow-grass U 

Drosera anglica English sundew U 

Drosera rotundifolia Roundleaf sundew U 

Eriogonum brandegeei Brandegee wildbuckwheat U 

Eriogonum exilifolium Drop-leaf wild buckwheat S 

Eriogonum visheri Visher’s buckwheat S 

Gilia sedifolia Purple false gily-flower U 

Ipomopsis aggregata ssp. weberi Weber’s scarlet gilia U 

Ipomopsis globularis Globe gilia U 

Ipomopsis polyantha Pagosa skyrocket U 

Lesquerella fremontii Fremont’s bladderpod U 

Lesquerella pruinosa Pagosa Springs bladderpod U 

Machaeranthera coloradoensis Colorado tansymustard U 

Mimulus gemmiparus Weber’s monkeyflower U 

Neoparrya lithophila Rock-loving aletes U 

Oenothera harringtonii Harrington’s oenothera U 

Oreoxis humilis Pikes Peak spring parsley U 

Parnassia kotzebuei Kotzebue’s grass-ofParnassus U 

Penstemon absarokensis Absaroka penstemon U 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-19 

Table H-7. USFS Region 2 Sensitive Species List and Status for the Entire 

Thunder Basin National Grassland (Continued). 

Scientific Name Common Name 

Status 

on 

TBNG 

Plants: Dicots (continued)

Penstemon caryi Cary beardtongue U 

Penstemon degeneri Degener’s penstemon U 

Penstemon harringtonii Harrington’s beardtongue S 

Phacelia scopulina var. submutica Debeque scorpionweed U 

Physaria didymocarpa var. lanata Woolly twinpod S 

Physaria pulvinata Cushion bladderpod U 

Potentilla rupincola Front Range cinquefoil U 

Primula egaliksensis Greenland primrose U 

Pyrrocoma carthamoides var.

subsquarrosa 

Absoroka goldenweed U 

Pyrrocoma clementis var. villosa Tranquil goldenweed U 

Pyrrocoma integrifolia Many-stemmed goldenweed U 

Ranunculus karelinii Frosty buttercup U 

Rubus arcticus ssp. acaulis Arctic bramble U 

Salix arizonica Arizona willow U 

Salix barrattiana Barrat willow U 

Salix candida Sage willow U 

Salix myrtillifolia Myrtleleaf willow U 

Salix serissima Autumn willow U 

Sanguinaria canadensis Bloodroot U 

Shoshonea pulvinata Shoshonia U 

Thalictrum heliophilum Sun-loving meadowrue U 

Townsendia condensata var.

anomala 

Cushion townsenddaisy U 

Utricularia minor Lesser bladderpod U 

Viburnum opulus var. americanum Highbush-cranberry S 

Viola selkirkii Great-spurred violet U 

Fish 

Nocomis biguttatus Hornyhead chub D 

Couesius plumbeus Lake chub U 

Gila pandora Rio Grande chub D 

Gila robusta Roundtail chub D 

Macrhybopsis gelida Sturgeon chub U 

Phoxinus neogaeus Finescale dace U 

Margariscus margarita Pearl dace U 
Appendix H 

H-20 Final EIS, Wright Area Coal Lease Applications

Table H-7. USFS Region 2 Sensitive Species List and Status for the Entire 

Thunder Basin National Grassland (Continued). 

Scientific Name Common Name 

Status 

on 

TBNG 

Fish (continued)

Phoxinus eos Northern redbelly dace D 

Phoxinus erythrogaster Southern redbelly dace D 

Platygobio gracilis Flathead chub K 

Hybognathus placitus Plains minnow K 

Catostomus discobulus Bluehead sucker D 

Catostomus latipinnis Flannelmouth sucker D 

Catostomus platyrynchus Mountain sucker D 

Catostomus plebeius Rio Grande sucker D 

Oncorhynchus clarki pleuriticus Colorado River cutthroat 

trout 

D 

Oncorhynchus clarki bouvieri Yellowstone cutthroat trout D 

Oncorhynchus clarki virginalis Rio Grande cutthroat trout D 

Invertebrates 

Somatochlora hudsonica Hudsonian emerald butterfly U 

Speyeria nokomis nokomis Great Basin silverspot 

butterfly 

U 

Hesperia ottoe Ottoe skipper butterfly U 

Speyeria idalia Regal fritillary S 

Reptiles and Amphibians 

Rana pipiens Northern leopard frog K 

Storeria occipitomaculata pahasapae Black Hills redbelly snake S 

Mammals 

Euderma maculatum Spotted bat K 

Corynorhinus townsendii Townsend’s big-eared bat K 

Myotis thysanodes Fringed myotis K 

Cynomys ludovicianus Black-tailed prairie dog K 

Vulpes velox Swift fox K 

Birds 

Cygnus buccinator Trumpeter swan U 

Botaurus lentiginosus American bittern U 

Coccyzus americanus Yellow-billed cuckoo K 

Numenius americanus Long-billed curlew K 

Buteo regalis Ferruginous hawk K 

Accipiter gentilis Northern goshawk K 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-21 

Table H-7. USFS Region 2 Sensitive Species List and Status for the Entire 

Thunder Basin National Grassland (Continued). 

Scientific Name Common Name 

Status 

on 

TBNG 

Birds (continued)

Circus cyaneus Northern harrier K 

Athene cunicularia Burrowing owl K 

Asio flammeus Short-eared owl K 

Calcarius ornatus Chestnut-collared longspur K 

Calcarius mccownii McCown’s longspur K 

Centrocercus urophasianus Greater sage-grouse K 

Haliaeetus leucocephalus Bald eagle K 

Charadrius montanus Mountain plover K 

Lanius ludovicianus Loggerhead shrike K 

Spizella breweri Brewer’s sparrow K 

Ammodramus savannarum Grasshopper sparrow K 

Amphispiza billneata Sage sparrow U 

Chlidonias niger Black tern K 

Melanerpes lewis Lewis’ Woodpecker K 

Table H-8. USFS Region 2 Sensitive Species Status on TBNG and on USFS 

Lands Within the General Wright Analysis Area, and Habitat 

Suitability on USFS Lands Within the General Wright Analysis 

Area (Provided by USFS Douglas Ranger District, July 2007). 

Common Name 

(Scientific Name)

Status on TBNG/Status on 

USFS Lands in General 

Wright Analysis Area 

Suitability of 

Habitat on USFS 

Lands in General 

Wright Analysis 

Area 

Plants: Ferns and Allies

Prairie moonwort 

(Botrychium campestre) Undocumented/Undocumented Very Poor to Unsuitable Habitat 

Narrowleaf moonwort 

(Botrychium lineare) Undocumented/Undocumented Unsuitable Habitat 

Leathery grapefern 

(Botrychium multifidum 

var. coulteri) 

Undocumented/Undocumented Unsuitable Habitat 

Plants: Monocots

Foxtail sedge 

(Carex alopecoidea) Undocumented/Undocumented Unsuitable Habitat 

Elliptic spikerush 

(Eleocharis elliptica) Undocumented/Undocumented Unsuitable Habitat 
Appendix H 

H-22 Final EIS, Wright Area Coal Lease Applications

Table H-8. USFS Region 2 Sensitive Species Status on TBNG and on USFS 

Lands Within the General Wright Analysis Area, and Habitat 

Suitability on USFS Lands Within the General Wright Analysis 

Area (Provided by USFS Douglas Ranger District, July 2007) 

(Continued).

Common Name 

(Scientific Name)

Status on TBNG/Status on 

USFS Lands in General 

Wright Analysis Area 

Suitability of 

Habitat on USFS 

Lands in General 

Wright Analysis 

Area 

Plants: Monocots (Continued)

Hall’s fescue 

(Festuca hallii) Undocumented/Undocumented Unsuitable Habitat 

Largeflower triteleia 

(Triteleia grandiflora) Undocumented/Undocumented Unsuitable Habitat 

Plants: Dicots

Barr’s milkvetch 

(Astragalus barrii) Documented/Undocumented Suitable Habitat 

Woolly twinpod 

(Physaria didymocarpa

var. lanata) 

Undocumented/Undocumented Marginal Habitat 

Visher’s buckwheat 

(Eriogonum visheri) 

Tentatively 

Documented/Undocumented Unsuitable Habitat 

Highbush-cranberry 

(Viburnum opulus var.

americanum) 

Undocumented/Undocumented Unsuitable Habitat 

Amphibians

Northern leopard frog 

(Rana pipiens) Documented/No Observations Poor to Unsuitable Habitat 

Fish 

Flathead Chub 

(Platygobio gracilis) Documented/Undocumented Unsuitable Habitat 

Plains minnow 

(Hybognathus placitus) Documented/Undocumented Unsuitable Habitat 

Mammals 

Black-tailed prairie dog 

(Cynomys ludovicianus) Documented/Documented Limited to Unsuitable Habitat 

Swift fox 

(Vulpes velox) Documented/No Observations Suitable to Unsuitable Habitat 

Birds 

Long-billed curlew 

(Numenius americanus) Documented/No Observations Foraging Habitat 

Ferruginous hawk 

(Buteo regalis) Documented/Documented Suitable Habitat 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-23 

Table H-8. USFS Region 2 Sensitive Species Status on TBNG and on USFS 

Lands Within the General Wright Analysis Area, and Habitat 

Suitability on USFS Lands Within the General Wright Analysis 

Area (Provided by USFS Douglas Ranger District, July 2007) 

(Continued).

Common Name 

(Scientific Name)

Status on TBNG/Status on 

USFS Lands in General 

Wright Analysis Area 

Suitability of 

Habitat on USFS 

Lands in General 

Wright Analysis 

Area 

Birds (Continued)

Burrowing owl 

(Athene cunicularia) Documented/Documented Limited Suitable Habitat 

Chestnut-collared 

longspur 

(Calcarius ornatus) 

Documented/Documented Limited Suitable 

Habitat 

McCown’s longspur 

(Calcarius mccownii) Documented/Documented Poor to Marginal Habitat 

Greater sage-grouse 

(Centrocercus 

urophasianus) 

Documented/Documented Suitable to Unsuitable 

Habitat 

Bald eagle 

(Haliaeetus 

leucocephalus) 

Documented/Documented Suitable Rangeland 

Foraging Habitat 

Mountain Plover 

(Charadrius montanus) Documented/No Observations Suitable to Unsuitable 

Habitat 

Loggerhead shrike 

(Lanius ludovicianus) Documented/Documented Marginal Habitat 

Brewer’s sparrow 

(Spizella breweri) Documented/Documented Suitable to Unsuitable Habitat 

Table H-9. USFS Region 2 Species of Local Concern Status on TBNG and on 

USFS Lands Within the General Wright Analysis Area, and 

Habitat Suitability on USFS Lands Within the General Wright 

Analysis Area (provided by Roche 2009). 

Common Name 

(Scientific Name)

Status on TBNG/Status on 

USFS Lands in General 

Wright Analysis Area 

Suitability of 

Habitat on USFS 

Lands in General 

Wright Analysis 

Area 

Plants: Monocots

Wood (wild) lily 

(Lilium philadelphicum) Undocumented/Undocumented Unsuitable Habitat 
Appendix H 

H-24 Final EIS, Wright Area Coal Lease Applications

Table H-9. USFS Region 2 Species of Local Concern Status on TBNG and on 

USFS Lands Within the General Wright Analysis Area, and 

Habitat Suitability on USFS Lands Within the General Wright 

Analysis Area (provided by Roche 2009) (Continued).

Common Name 

(Scientific Name)

Status on TBNG/Status on 

USFS Lands in General 

Wright Analysis Area 

Suitability of 

Habitat on USFS 

Lands in General 

Wright Analysis 

Area 

Plants: Dicots

Smooth goosefoot 

(Chenopodium 

subglabrum) 

Undocumented/Undocumented Unsuitable Habitat 

Flat-top (fragrant) 

goldentop (goldenrod) 

(Euthamia graminifolia) 

Undocumented/Undocumented Unsuitable Habitat 

Rosy palafox 

(Palafoxia rosea var. 

macrolepis) 

Documented/Undocumented Suitable Habitat 

Lemonscent (crownseed fetid-marigold) 

(Pectis angustifolia) 

Documented/Undocumented Suitable Habitat 

Larchleaf beardtongue 

(Penstemon laricifolius

ssp. exifolius) 

Undocumented/Undocumented Marginal Habitat 

H-3.2 Species Habitat and Occurrence on USFS Lands Within the 

General Wright Analysis Area, and the Direct and Indirect Direct 

Effects on Those Species 

Site-specific data on the occurrence of USFS Region 2 Sensitive Species on 

USFS lands within the general Wright analysis area were obtained from the 

Wyoming Department of Environmental Quality/Land Quality Division 

(WDEQ/LQD) permit applications and annual reports for the Black Thunder, 

Jacobs Ranch, and North Antelope Rochelle mines, the Rocky Mountain 

Herbarium, the Wyoming Natural Diversity Database, and the USFS. 

Baseline and annual wildlife surveys have been conducted for the three 

applicant mines (Black Thunder, Jacobs Ranch and North Antelope Rochelle) 

since the early 1980s. WDEQ/LQD guidelines and regulations specify different 

wildlife survey areas for different species and for different survey purposes 

(baseline studies or annual monitoring). Those surveys included the mine 

permit area and surrounding perimeter ranging from 0.5 to 2.0 miles 

(depending on the purpose of the surveys). The larger survey perimeters for the 

mines’ annual monitoring programs coincidentally encompassed all USFS 

administered lands within the general analysis areas for the North and South 

Porcupine tracts and the North Hilight Field tract, all but the southwestern-
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-25 

most corner (roughly 15 percent) of the general analysis area for the South 

Hilight Field tract, and all but the southwestern quarter (roughly 25 percent) of 

the general analysis area for West Hilight Field tract. 

Regular surveys conducted in and near USFS lands over the years included 

raptors, mountain plovers (Charadrius montanus), upland game birds, 

migratory bird species of management concern, lagomorphs (rabbits), and big 

game. Supplemental specific surveys for bald eagles, herptiles, waterfowl, fish, 

and other species were conducted periodically during baseline studies for the 

applicant mines and adjacent mines (i.e., Antelope Mine). Efforts included a 

variety of approved survey methods, such as fixed-wing aerial, remote 

observation via spotting scopes and binoculars, pedestrian, nocturnal 

spotlighting, belt transects, point counts, and trapping. All incidental sightings 

of those species were also recorded during each site visit, including notes on 

species, number of individuals, sex/age (when possible), habitat, and location. 

Specific details regarding survey methods and results from annual monitoring 

and baseline inventories for the Black Thunder, Jacobs Ranch and North 

Antelope Rochelle mines, dating back to the early 1980s, are provided in 

reports on file with the WDEQ-LQD and/or USFS, and thus are not provided in 

this document. 

USFS typically assesses impacts to resources on its managed lands and, when 

applicable, adjacent lands that could also be impacted by the Proposed Action. 

For wildlife, the USFS is interested in knowing what resources and potential 

impacts occur within a 1- or 2-mile perimeter surrounding their lands, 

depending on the species. As discussed in Section 3.10 of this EIS, the wildlife 

survey areas for this analysis includes the LBA tracts’ general analysis areas 

plus a surrounding perimeter that varies in extent depending on the species. 

Thunder Basin Coal Company (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; Jacobs Ranch Coal Company (JRCC) conducted baseline 

investigations in 2007 and 2008 expressly for the West Jacobs Ranch LBA 

Tract; and Powder River Coal, Inc. (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, Greater sagegrouse lek, and prairie dog colony locations covered the respective wildlife 

survey areas (2-mile perimeter surrounding the general analysis areas). 

Figures H-1 through H-5 depict the wildlife survey area and the USFS lands 

within the general analysis area for the North Hilight Field, South Hilight Field, 

West Hilight Field, North Porcupine, and South Porcupine LBA Tracts, 

respectively. 

The entire list of Region 2 Sensitive Species was reviewed and every vertebrate 

species was considered for full evaluation. However, only those species that 

might potentially be affected directly or indirectly by implementation of the
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

FH

FH

FH

FH

SH/FH

SH/RTH/FH

FH

FH

FH

FH

FH

FH

FH

SH/FH

FH

FH

FH

FH

FH

FH

FH

FH

BO

BO

BO

BO

FH

Butch

Lek

Stuart II

Lek

Hansen

Lakes

Lek

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)

Two-Mile Wildlife Study

Area Boundary

General Analysis Area

LEGEND

BO

FH

Burrowing Owl

Ferruginous Hawk

Thunder Basin National Grassland

(USFS)

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

SH

RTH

Swainson's Hawk

Red-tailed Hawk

Figure H-1. USFS Region 2 Sensitive Wildlife Species Survey Area for the North Hilight Field LBA Tract.

Appendix H

H-26 Final EIS, Wright Area Coal Lease Applications
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

FH

FH

FH

FH

FH

FH FH

FH

FH/RTH

FH

FH

SH/FH

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

Thunder Basin National Grassland

(USFS)

South Hilight Field LBA

Tract as Applied for

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Black Thunder Mine Permit Boundary LEGEND

SH

RTH

FH

Swainson's Hawk

Red-tailed Hawk

Ferruginous Hawk

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 H-2. USFS Region 2 Sensitive Wildlife Species Survey Area for the South Hilight Field LBA Tract.

Appendix H

Final EIS, Wright Area Coal Lease Applications H-27
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.

Little

Thunder Creek

FH/SH

BO

BO

FH

FH

FH FH

FH

FH

FH

FH FH

FH

FH

FH

FH

FH

FH

FH

FH

SH/FH

FH

SH/RTH/FH

FH

FH

FH

FH

FH

FH/RTH

BO

FH

FH

FH

SH/FH

FH

FH

FH

FH

FH

FH

FH FH

FH

FH/RTH

SH/FH

FH

FH

FH

FH

FH

FH

FH FH

FH

FH

FH

Stuart I

Lek

Stuart II

Lek

Black

Thunder

Lek

FH

Thunder Basin National Grassland

(USFS)

LEGEND

0 5000 10000 20000

GRAPHIC SCALE (FEET)

Black Thunder Mine

Permit Boundary

West Hilight Field LBA

Tract as Applied for

BO

SH

RTH

FH

Burrowing Owl

Swainson's Hawk

Red-tailed Hawk

Ferruginous Hawk

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 H-3. USFS Region 2 Sensitive Wildlife Species Survey Area for the West Hilight Field LBA Tract.

Appendix H

H-28 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

R. 72 W. R. 71 W.

R. 72 W. R. 71 W.

Rochelle

Lek

Kort

II Lek

Kort I

Lek

Wilson

Lek

Payne Lek

GE

SH/FH

SH/FH

BO

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/GHO/FH

FH

FH

FH

FH

BO

H

H FH

SH/FH

FH

FH

FH

SH/FH

FH

SH/FH

SH/FH

FH

FH

BO

BO

FH

FH

FH

FH

FH

GE

BO

FH

FH

FH

FH

FH FH

SEO

FH

BO

BO

FH FH

SH

BO

FH FH

FH

FH

FH

FH

FH

FH

FH

FH

FH

FH

BO

FH

FH/GHO/RTH

FH

FH

RTH/FH

BO

FH

FH

FH

FH

FH

FH

FH FH FH

FH

FH

FH

FH

FH

FH

FH FH

North Antelope RochelleMine Permit BoundaryNorth Porcupine LBA

Tract as Applied for

5000 10000 20000 0

GRAPHIC SCALE (FEET)

North Porcupine LBA Tract Under Alternative 2,BLM's Preferred AlternativeGeneral Analysis Area

2-Mile Wildlife Study Area Boundary

United States Department of Agriculture

LEGEND

H

BO

GHO

FH

RTH

SH

Ferruginous HawkRed-tailed Hawk

Swainson's HawkGreat Horned Owl

Burrowing OwlNorthern Harrier

Prairie Dog Colony

SEO Short-eared Owl

Existing Raptor NestFormer Raptor NestExisting Platform 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)

Unoccupied (Destroyed) Sage-Grouse Lek

(Destroyed and No Longer Suitable for Breeding)

Figure H-4. USFS Region 2 Sensitive Wildlife Species Survey Area for the North Porcupine LBA Tract.

Appendix H

Final EIS, Wright Area Coal Lease Applications H-29
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

Converse County

Campbell County

Payne

Lek

FH

BO

FH

FH

FH

FH

FH

FH

FH

FH

FH

FH FH

BO

FH

FH

FH

FH FH

FH

BO BO

BO

BO

FH

FH

FH FH

BO SH/FH

SH/FH

FH

FH

FH

FH

SH/FH

FH

FH

FH

SH/GHO/FH

SH/FH

SH

BO

BO BO

FH

SH

FH

BO

FH

Rochelle

Lek

Kort II

Lek

Kort I

Lek

Wilson

Lek

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.

R. 71 W. R. 70 W.

T.

42

N.

T.

41

N.

T.

41

N.

T.

40

N.

T.

41

N.

T.

40

N.

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

FH

Burrowing Owl

Great Horned Owl

Swainson's Hawk

Ferruginous Hawk

Two-Mile Wildlife Study

Area Boundary

General Analysis Area

United States Department

of Agriculture

Prairie Dog Colony

Existing Platform Nest

Former Raptor Nest

Occupied Sage-Grouse Lek Existing Raptor Nest

(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 H-5. USFS Region 2 Sensitive Wildlife Species Survey Area for the South Porcupine LBA Tract.

Appendix H

H-30 Final EIS, Wright Area Coal Lease Applications
Appendix H 

Final EIS, Wright Area Coal Lease Application H-31 

Proposed Actions or Alternatives on USFS lands were selected for evaluation 

(Table H-8). For example, if a vertebrate species was known to occur on or 

near USFS lands, or suitable but unoccupied habitat was present in that area 

and would be disturbed, then potential effects were evaluated. If suitable 

habitat was not present in the area, no further analysis was conducted. 

Thirteen vertebrate species were identified that could potentially be affected by 

implementation of the Proposed Actions or Alternatives (Table H-8). Many 

other sensitive vertebrates and one invertebrate that had been documented 

elsewhere on the TBNG were not evaluated further because of a lack of suitable 

habitat on or near USFS lands, or because no such habitat would be physically 

disturbed or otherwise affected by implementation of the Proposed Actions or 

Alternatives. 

Vegetation baseline inventories have been completed on each mine’s current 

permit area in accordance with the current WDEQ/LQD mine permitting 

requirements. As a result, all or portions of the LBA tracts’ general analysis 

areas were covered during various vegetation baseline inventories, as well as 

for prior EIS analyses. Vegetation assessments were completed for the balance 

of the tracts’ general analysis areas in 2007 and 2008. There is no suitable 

habitat on USFS lands within the general analysis areas for 12 of the 17 plant 

species listed in Tables H-8 and H-9. All of the 17 plant species will be 

discussed here because potential habitat may be present on other portions of 

the general analysis areas even if suitable habitat is not present on the USFS 

lands. 

The following discussions summarize the results of these surveys, including 

brief descriptions of the habitat and occurrence of each evaluated USFS Region 

2 sensitive species and species of local concern, which are identified in Tables 

H-8 and H-9 as inhabiting or potentially inhabiting USFS lands within the 

general analysis areas for the North Hilight Field, South Hilight Field, West 

Hilight Field, North Porcupine, and South Porcupine LBA Tracts. The general 

analysis area for the West Jacobs Ranch LBA Tract does not include any TBNG 

lands administered by the USFS. The potential direct and indirect 

environmental effects on the respective species as a result of leasing and 

mining the LBA tracts follow the habitat and occurrence descriptions. 

Cumulative impacts for all evaluated Region 2 Sensitive Species are discussed 

at the end of this biological evaluation. 

H-3.2.1 Prairie moonwort (Botrychium campestre)

The prairie moonwort, a sensitive plant species, has not been documented on 

USFS lands within the North Hilight Field, South Hilight Field, West Hilight 

Field, North Porcupine and South Porcupine general analysis areas or within 

the TBNG. This plant species is suspected of occurring on TBNG lands where 

suitable habitat is present. This species was only recorded in Wyoming in a 

semi-shady mixed deciduous and ponderosa pine forest on sandy soils in the 

Black Hills. Prairie moonworts are known to exist in a variety of other habitats 

such as those underlain by Pierre shale, the Laramie Formation, calcareous 
Appendix H 

H-32 Final EIS, Wright Area Coal Lease Applications 

sedimentary rocks, calcareous soils underlain by limestone, sandy soils and 

loess prairie. These habitats are generally limited on the North Hilight Field, 

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

general analysis areas, with only some areas dominated by sandy soils present. 

Existing Conditions

Prime habitats for the prairie moonwort are not present on the USFS lands 

within the general analysis areas for the North Hilight Field, South Hilight 

Field, West Hilight Field, North Porcupine and South Porcupine tracts. Sites 

with sandy soils are present on USFS lands and other portions of the general 

Wright analysis area, but these areas are rather sparsely vegetated and do not 

provide habitat preferred by this plant species. Prairie moonworts have not 

been recorded on the general Wright analysis area or adjacent areas. 

Indirect and Direct Impacts

If present on areas to be disturbed by mining, individuals of this species would 

be lost when topsoil is removed or during disturbances caused by other mining 

activities. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract may 

impact individuals but is not likely to cause a trend to federal listing or loss of 

viability within the planning area. As indicated, the general analysis areas for 

the North Hilight Field, South Hilight Field, West Hilight Field, North Porcupine 

and South Porcupine tracts do not provide suitable habitat for this plant 

species. The potential for loss of individuals or preferred habitats is very low. 

H-3.2.2 Narrowleaf moonwort (Botrychium lineare)

The narrowleaf moonwort, a sensitive plant species, has not been documented 

on USFS lands within the North Hilight Field, South Hilight Field, West Hilight 

Field, North Porcupine and South Porcupine general analysis areas or within 

the TBNG. This plant species is suspected of occurring on TBNG lands where 

suitable habitat is present. This species has an affinity for riparian areas and 

is associated with spruce/fir forests, lodgepole pine forests, and forest 

meadows. 

Existing Conditions

Habitats for the narrowleaf moonwort are not present on the USFS lands 

within the general Wright analysis area. Suitable riparian habitats or forest 

habitats are not present on these USFS lands within the general Wright 

analysis area. Few riparian sites associated with various ephemeral drainages 

are present on portions of the general Wright analysis area, and these sites do 

not appear to provide optimum habitat for this species. The narrowleaf 

moonwort has not been recorded on the general Wright analysis area or 

adjacent areas. 
Appendix H 

Final EIS, Wright Area Coal Lease Application H-33 

Indirect and Direct Impacts

If present on areas to be disturbed by mining, individuals of this species would 

be lost when topsoil is removed or during disturbances caused by other mining 

activities. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract may 

impact individuals but is not likely to cause a trend to federal listing or loss of 

viability within the planning area. As indicated, the general analysis areas for 

the North Hilight Field, South Hilight Field, West Hilight Field, North Porcupine 

and South Porcupine tracts do not provide suitable habitat for this plant 

species. The potential loss of individuals or preferred habitats is very low. 

H-3.2.3 Leathery grapefern (Botrychium multifidum var. coulteri)

The leathery grapefern, a plant species of local concern, has not been 

documented on USFS lands within the North Hilight Field, South Hilight Field, 

West Hilight Field, North Porcupine and South Porcupine general analysis 

areas or within the TBNG. This plant species is suspected of occurring on 

TBNG lands where suitable habitat is present. This species generally has an 

affinity for meadows, wetlands, floodplains and other wet areas in open to 

forested habitats within forests. 

Existing Conditions

Habitats for the leathery grapefern are not present on the USFS lands within 

the general Wright analysis area. Suitable riparian habitats or forest habitats 

are not present on these USFS lands within the general Wright analysis area. 

Few riparian sites associated with various ephemeral drainages are present on 

other portions of the general Wright analysis area, and these sites do not 

appear to provide optimum habitat for this species. The leathery grapefern has 

not been recorded on the general Wright analysis area or adjacent areas. 

Indirect and Direct Impacts

If present on areas to be disturbed by mining, individuals of this species would 

be lost when topsoil is removed or during disturbances caused by other mining 

activities. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract 

would have no impact on the leathery grapefern. As indicated, the general 

analysis areas for the North Hilight Field, South Hilight Field, West Hilight 

Field, North Porcupine and South Porcupine tracts do not provide suitable 

habitat for this plant species so the potential loss of individuals or preferred 

habitats is not expected. 

H-3.2.4 Foxtail sedge (Carex alopecoidea)

The foxtail sedge, a sensitive plant species, is a perennial plant species and has 

not been documented on USFS lands within the North Hilight Field, South 

Hilight Field, West Hilight Field, North Porcupine and South Porcupine general 
Appendix H 

H-34 Final EIS, Wright Area Coal Lease Applications 

analysis areas or within the TBNG. This plant species is suspected of 

occurring on TBNG lands where suitable habitat is present. The foxtail sedge 

generally has an affinity for wet meadows and willow-sedge communities along 

wet, shady creek bottoms and springs. 

Existing Conditions

Habitats for the foxtail sedge are not present on the USFS lands within the 

general Wright analysis area. Suitable wet meadows or willow-sedge 

communities are not present on these USFS lands. Few riparian sites 

associated with various ephemeral drainages are present on other portions of 

the general Wright analysis area, and these sites do not appear to provide 

optimum habitat for this species. The foxtail sedge has not been recorded on 

the general Wright analysis area or adjacent areas. 

Indirect and Direct Impacts

If present on areas to be disturbed by mining, individuals of this species would 

be lost when topsoil is removed or during disturbances caused by other mining 

activities. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract 

should have no impact on the foxtail sedge. As indicated, the general analysis 

areas for the North Hilight Field, South Hilight Field, West Hilight Field, North 

Porcupine and South Porcupine tracts do not provide suitable habitat for this 

plant species. The potential for loss of individuals or preferred habitats is not 

expected. 

H-3.2.5 Elliptic spikerush (Eleocharis elliptica)

The elliptic spikerush, a sensitive plant species, is a perennial and has not 

been documented on USFS lands within the North Hilight Field, South Hilight 

Field, West Hilight Field, North Porcupine and South Porcupine general 

analysis areas or within the TBNG. This plant species is suspected of 

occurring on TBNG lands where suitable habitat is present. This species 

generally has an affinity for wetland areas created by seeps or springs but may 

also be found in temporarily flooded areas. 

Existing Conditions

Habitats for the elliptic spikerush are not present on the USFS lands within the 

general Wright analysis area. Suitable wetland habitats are not present on 

these USFS lands. Few wetland sites associated with various ephemeral 

drainages and playas are present on portions of the general Wright analysis 

area, but these sites do not appear to provide optimum habitat for this species. 

The elliptic spikerush has not been recorded on the general Wright analysis 

area or adjacent areas. 

Indirect and Direct Impacts

If present on areas to be disturbed by mining, individuals of this species would 

be lost when topsoil is removed or during disturbances caused by other mining 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-35 

activities. However, due to lack of abundant suitable habitat the impacts to 

this species overall would be minimal. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract may 

impact individuals but is not likely to cause a trend to federal listing or loss of 

viability within the planning area. As indicated, the general analysis areas for 

the North Hilight Field, South Hilight Field, West Hilight Field, North Porcupine 

and South Porcupine tracts do not provide abundant habitat for this plant 

species so the potential loss of individuals or preferred habitats is low. 

H-3.2.6 Hall’s fescue (Festuca hallii)

The Hall’s fescue, a sensitive plant species, is a tufted perennial grass and has 

not been documented on USFS lands within the North Hilight Field, South 

Hilight Field, West Hilight Field, North Porcupine and South Porcupine general 

analysis areas or within the TBNG. This plant species is suspected of 

occurring on TBNG lands where suitable habitat is present. This species 

generally has an affinity for montane meadows, slopes and edges of open 

coniferous woods and meadows above 6,000 feet in Wyoming. 

Existing Conditions

Habitats for the Hall’s fescue are not present on the USFS lands within the 

general Wright analysis area. Suitable montane habitats above 6,000 feet are 

not present on these USFS lands within the general Wright analysis area, and 

the Hall’s fescue has not been recorded on the general Wright analysis area or 

adjacent areas. 

Indirect and Direct Impacts

If present on areas to be disturbed by mining, individuals of this species would 

be lost when topsoil is removed or during disturbances caused by other mining 

activities. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract 

should have no impact on the Hall’s fescue. As indicated, the general analysis 

areas for the North Hilight Field, South Hilight Field, West Hilight Field, North 

Porcupine and South Porcupine tracts do not provide suitable habitat for this 

plant species. The potential loss of individuals or preferred habitats is not 

expected. 

H-3.2.7 Wood lily (Lilium philadelphicum)

The wood lily, a plant species of local concern, is a perennial herb and has not 

been documented on USFS lands within the North Hilight Field, South Hilight 

Field, West Hilight Field, North Porcupine and South Porcupine general 

analysis areas or within the TBNG. This plant species is suspected of 

occurring on TBNG lands where suitable habitat is present. This species 

generally has an affinity for woodland meadows and woodland grasslands. 
Appendix H 

H-36 Final EIS, Wright Area Coal Lease Applications 

Existing Conditions

Habitats for the wood lily are not present on the USFS lands within the general 

Wright analysis area. Suitable woodland meadow or grassland habitats are not 

present on these USFS lands within the general Wright analysis area, and the 

wood lily has not been recorded on the general Wright analysis area or adjacent 

areas. 

Indirect and Direct Impacts

If present on areas to be disturbed by mining, individuals of this species would 

be lost when topsoil is removed or during disturbances caused by other mining 

activities. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract 

should have no impact on the wood lily. As indicated, the general analysis 

areas for the North Hilight Field, South Hilight Field, West Hilight Field, North 

Porcupine and South Porcupine tracts do not provide suitable habitat for this 

plant species so the potential loss of individuals or preferred habitats is not 

expected. 

H-3.2.8 Largeflower triteleia (Triteleia grandiflora)

The largeflower triteleia, a sensitive plant species, is a perennial herb and has 

not been documented on USFS lands within the North Hilight Field, South 

Hilight Field, West Hilight Field, North Porcupine and South Porcupine general 

analysis areas or within the TBNG. This plant species is suspected of 

occurring on TBNG lands where suitable habitat is present. This species 

generally has an affinity for grassy areas in sagebrush at the edge of aspen and 

lodgepole pine forests and in pinon-juniper woodlands to pine forests and hills. 

Existing Conditions

Habitats for the largeflower triteleia are not present on the USFS lands within 

the general Wright analysis area. Suitable grassy areas in sagebrush at the 

edge of aspen and lodgepole pine forests and pinon-juniper woodlands or pine 

forests and hills are not present on these USFS lands within the general Wright 

analysis area, and the largeflower triteleia has not been recorded on the general 

Wright analysis area or adjacent areas. 

Indirect and Direct Impacts

If present on areas to be disturbed by mining, individuals of this species would 

be lost when topsoil is removed or during disturbances caused by other mining 

activities. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract 

should have no impact on the largeflower triteleia. As indicated, the general 

analysis areas for the North Hilight Field, South Hilight Field, West Hilight 

Field, North Porcupine and South Porcupine tracts do not provide suitable 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-37 

habitat for this plant species so the potential loss of individuals or preferred 

habitats is not expected. 

H-3.2.9 Barr’s milkvetch (Astragalus barrii)

The Barr’s milkvetch, a sensitive plant species, is a matt-forming perennial forb 

that is known from numerous occurrences on the USFS lands within the 

TBNG. As more surveys are completed, new occurrences are reported. The 

Barr’s milkvetch is found primarily on dry, sparsely-vegetated rocky prairie 

breaks, knolls, hillsides and ridges. Parent material is calcareous soft shale, 

siltstone or silty sandstone. Most populations appear to be stable, although 

populations may decline under drought conditions. 

Existing Conditions

Astragalus barrii is a regional endemic plant of the plains in southwestern 

South Dakota, eastern Wyoming, southeastern Montana, and northwestern 

Nebraska. According to USFS, this plant species is known to occur in six 

counties in Wyoming, and there are eleven known occurrences of A. barrii in 

the USFS TBNG. 

Suitable habitat for the Barr’s milkvetch is present on the USFS lands within 

the general analysis areas for the North Hilight Field, South Hilight Field, West 

Hilight Field, North Porcupine and South Porcupine LBA Tracts as well as other 

lands within the general Wright analysis area. Populations and individuals 

have not been documented in the general analysis areas for the North, South 

and West Hilight Field tracts, but have been identified in surrounding areas. A 

pedestrian survey of the North, South and West Hilight Field tracts’ general 

analysis areas was conducted in April 2008, when the Barr’s milkvetch is in 

bloom, and no individuals of this species were found. Surveys in 2005 within 

the general analysis areas for the North and South Porcupine tracts identified 

Barr’s milkvetch populations, but no individuals were found on USFS lands. 

Barr’s milkvetch has been collected and positively identified approximately 6 

miles south of the general Wright analysis area, in Section 21 of T.40N., 

R.71W., based on specimens on file with the Rocky Mountain Herbarium in 

Laramie, Wyoming. 

Indirect and Direct Impacts

If lands within the general analysis areas for the North Hilight Field, South 

Hilight Field and West Hilight Field LBA Tracts are leased and mined, potential 

habitat, individuals, and A. barrii populations could be lost due to surface 

disturbances caused by mining activities. If lands within the general analysis 

areas for the North Porcupine and South Porcupine LBA Tracts are leased and 

mined, potential habitat, individuals, and A. barrii populations would be lost 

due to surface disturbances caused by mining activities. These losses would 

most likely be permanent unless disturbed lands are reclaimed to habitats that 

would support this plant species. 
Appendix H 

H-38 Final EIS, Wright Area Coal Lease Applications 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract may 

impact individuals but is not likely to cause a trend to federal listing because 

there are Astragalus barrii occurrences outside of the areas that would be 

affected by the Proposed Action or Alternative 2. The Rocky Mountain 

Herbarium records reveal this plant species is widespread in northeastern 

Wyoming, so the loss of individuals or populations from mining activities 

related to the Proposed Action or Alternative 2 would not result in the 

extirpation of this species. 

H-3.2.10 Smooth goosefoot (Chenopodium subglabrum)

The smooth goosefoot, a plant species of local concern, is an annual forb and 

has not been documented on USFS lands within the North Hilight Field, South 

Hilight Field, West Hilight Field, North Porcupine and South Porcupine general 

analysis areas or within the TBNG. This plant species is suspected of 

occurring on TBNG lands where suitable habitat is present. This species 

generally has an affinity for sand bars and sandy blowouts in riparian areas. 

Existing Conditions

Habitats for the smooth goosefoot are not present on the USFS lands within the 

general Wright analysis area. Suitable riparian areas are not present on the 

USFS lands within the general Wright analysis area. A few riparian areas 

associated with various ephemeral drainages are present on portions of the 

general Wright analysis area, but these areas do not contain the required sand 

bar or sandy blowout habitats required for this plant species. The smooth 

goosefoot has not been recorded on the general Wright analysis area or 

adjacent areas. 

Indirect and Direct Impacts

If present on areas to be disturbed by mining, individuals of this species would 

be lost when topsoil is removed or during disturbances caused by other mining 

activities. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract 

should have no impact on the smooth goosefoot. As indicated, the general 

analysis areas for the North Hilight Field, South Hilight Field, West Hilight 

Field, North Porcupine and South Porcupine tracts do not provide suitable 

habitat for this plant species so the potential loss of individuals or preferred 

habitats is not expected. 

H-3.2.11 Flat-top goldentop (Euthamia graminifolia)

The flat-top goldentop, a plant species of local concern, is a rhizomatous 

perennial forb and has not been documented on USFS lands within the North 

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

South Porcupine general analysis areas or within the TBNG. This plant species 

is suspected of occurring on TBNG lands where suitable habitat is present. In 

Wyoming, this species generally has an affinity for stony sandbars and 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-39 

streambanks but may also be found on moist or drying sites along open 

streambanks or roadside ditches. 

Existing Conditions

Habitats for the flat-top goldentop are not present on the USFS lands within 

the general Wright analysis area. Suitable wetland or streambank areas are 

not present on the USFS lands within the general Wright analysis area. 

Streambanks and a few wetland areas in association with various ephemeral 

drainages are present within portions of the general Wright analysis area, but 

these areas generally do not contain the typical habitats required for this plant 

species, but marginal habitats are present. The flat-top goldentop has not 

been recorded on the general Wright analysis areas or adjacent areas. 

Indirect and Direct Impacts

If present on areas to be disturbed by mining, individuals of this species would 

be lost when topsoil is removed or during disturbances caused by other mining 

activities. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract may 

impact individuals but is not likely to cause a trend to federal listing or loss of 

viability within the planning area. As indicated, the general analysis areas for 

the North Hilight Field, South Hilight Field, West Hilight Field, North Porcupine 

and South Porcupine tracts do not provide suitable habitat for this plant 

species so the potential loss of individuals or preferred habitats is low. 

H-3.2.12 Rosy palafox (Palafoxia rosea var. macrolepis)

The rosy palafox, a plant species of local concern, is an annual forb that has 

not been documented on USFS lands within the North Hilight Field, South 

Hilight Field, West Hilight Field, North Porcupine and South Porcupine general 

analysis areas but has been recorded on other lands within the TBNG. This 

plant species is suspected of occurring on other TBNG lands where suitable 

habitat is present. In Wyoming, this species generally has an affinity for 

sagebrush and mixed-grass prairie habitats on sandy soils. 

Existing Conditions

Habitats utilized by the rosy palafox are present on the USFS lands within the 

general Wright analysis area and on other surrounding lands. Sagebrush and 

mixed-grass prairie plant communities are present on sandy soils in the 

general Wright analysis area. However, rosy palafox has not been recorded on 

these lands but is potentially present. This plant species has been documented 

southeast of the general Wright analysis area. 

Indirect and Direct Impacts

If present on areas to be disturbed by mining, individuals of this species would 

be lost when topsoil is removed or during disturbances caused by other mining 

activities. However, due to the presence of abundant habitat outside of the 

general analysis areas for the North Hilight Field, South Hilight Field, West 
Appendix H 

H-40 Final EIS, Wright Area Coal Lease Applications 

Hilight Field, North Porcupine and South Porcupine tracts, and the fact that 

this plant is abundant in other areas, the impacts to this species overall would 

be minimal. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract may 

impact individuals but is not likely to cause a trend to federal listing or loss of 

viability within the planning area. As indicated, the general analysis areas for 

the North Hilight Field, South Hilight Field, West Hilight Field, North Porcupine 

and South Porcupine tracts do contain some suitable habitat for this plant 

species but the rosy palafox has not been documented. This species has been 

documented southeast of the general Wright analysis area and abundant 

habitat is present on other sites that would not be affected. 

H-3.2.13 Lemonscent (Pectis angustifolia)

The lemonscent, a plant species of local concern, is an annual forb and has not 

been documented on USFS lands within the North Hilight Field, South Hilight 

Field, West Hilight Field, North Porcupine and South Porcupine general 

analysis areas but has been recorded on other lands within the TBNG. This 

plant species is suspected of occurring on other TBNG lands where suitable 

habitat is present. In Wyoming, this species generally has an affinity for gravel 

hills and scoria slopes. Lemonscent is also known to occur in low areas in 

sandy ravines and on sandbars. 

Existing Conditions

Habitats utilized by lemonscent are present on the USFS lands within the 

general Wright analysis area and on other surrounding lands. However, 

lemonscent has not been recorded in the general Wright analysis area but 

could potentially be present. This plant species has been documented south of 

the general Wright analysis area. 

Indirect and Direct Impacts

If present on areas to be disturbed by mining, individuals of this species would 

be lost when topsoil is removed or during disturbances caused by other mining 

activities. However, due to the presence of abundant habitat outside of the 

general analysis areas for the North Hilight Field, South Hilight Field, West 

Hilight Field, North Porcupine and South Porcupine tracts, and the fact that 

this plant is abundant in other areas, the impacts to this species overall would 

be minimal. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract may 

impact individuals but is not likely to cause a trend to federal listing or loss of 

viability within the planning area. As indicated, the general analysis areas for 

the North Hilight Field, South Hilight Field, West Hilight Field, North Porcupine 

and South Porcupine tracts do contain some suitable habitat for this plant 

species but the lemonscent has not been documented. This species has been 

documented south of the general Wright analysis area and abundant habitat is 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-41 

present on other sites outside of the areas that would be affected by the 

Proposed Action or Alternative 2 for each LBA tract. 

H-3.2.14 Larchleaf beardtongue (Penstemon laricifolius spp. exifolius)

The larchleaf beardtongue (penstemon), a plant species of local concern, is a 

perennial forb and has not been documented on USFS lands within the North 

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

South Porcupine general analysis areas or within the TBNG. This plant species 

is suspected of occurring on TBNG lands where suitable habitat is present. In 

Wyoming, this species generally has an affinity for dry, rocky, gravelly or sandy 

slopes, ridgetops and upland flats with shallow soils. Most populations in 

Wyoming are found at elevations above 6,000 feet, but this species has been 

documented at lower elevations in the state. 

Existing Conditions

Habitats utilized by larchleaf beardtongue are marginally present on the USFS 

lands within the general Wright analysis area. A few rocky, gravelly hill slopes 

and rough breaks provide potential habitat, but the larchleaf beardtongue has 

not been recorded on these lands. This plant species has not been documented 

near the general Wright analysis area but is potentially present. 

Indirect and Direct Impacts

If present on areas to be disturbed by mining, individuals of this species would 

be lost when topsoil is removed or during disturbances caused by other mining 

activities. However, due to the presence of abundant habitat outside of the 

general Wright analysis area and the fact that this plant is abundant in other 

areas, the impacts to this species overall would be minimal. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract may 

impact individuals but is not likely to cause a trend to federal listing or loss of 

viability within the planning area. As indicated, the general analysis areas for 

the North Hilight Field, South Hilight Field, West Hilight Field, North Porcupine 

and South Porcupine tracts do contain marginal habitat for this plant species 

but the larchleaf beardtongue has not been documented. This species has 

been documented and is common in southern Wyoming and abundant habitat 

is present on other sites outside of the areas that would be affected by the 

Proposed Action or Alternative 2 for each LBA tract. 

H-3.2.15 Wooly twinpod (Physaria didymocarpa var. lanata)

The wooly twinpod, a sensitive plant species, is a perennial forb and has not 

been documented on USFS lands within the North Hilight Field, South Hilight 

Field, West Hilight Field, North Porcupine and South Porcupine general 

analysis areas or within the TBNG. This plant species is suspected of 

occurring on other TBNG lands where suitable habitat is present. In Wyoming, 

this species generally has an affinity for dry redbed clay-shale slopes, limeysandstone outcrops, roadcuts and other exposed rock-cliff substrates. Most 
Appendix H 

H-42 Final EIS, Wright Area Coal Lease Applications 

populations in Wyoming have been documented in the foothills of the Big Horn 

Mountains. 

Existing Conditions

Habitats utilized by the wooly twinpod are marginally present on the USFS 

lands within the general Wright analysis area. A few sandstone outcrops and 

exposed rock-cliff substrates provide potential habitat, but the wooly twinpod 

has not been recorded on these lands. This plant species has not been 

documented near the general Wright analysis area but is potentially present. 

Indirect and Direct Impacts

If present on areas to be disturbed by mining, individuals of this species would 

be lost when topsoil is removed or during disturbances caused by other mining 

activities. However, due to the presence of abundant habitat outside of the 

general Wright analysis area and the fact that this plant is abundant in other 

areas, the impacts to this species overall would be minimal. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract may 

impact individuals but is not likely to cause a trend to federal listing or loss of 

viability within the planning area. As indicated, the general analysis areas for 

the North Hilight Field, South Hilight Field, West Hilight Field, North Porcupine 

and South Porcupine tracts do contain marginal habitat for this plant species 

but the wooly twinpod has not been documented. This species has been 

documented and is common in north-central Wyoming and abundant habitat is 

present on other sites outside of the areas that would be affected by the 

Proposed Action or Alternative 2 for each LBA tract. 

H-3.2.16 Visher’s buckwheat (Eriogonum visheri)

The Visher’s buckwheat, a sensitive plant species, is an annual forb and has 

not been documented on USFS lands within the North Hilight Field, South 

Hilight Field, West Hilight Field, North Porcupine and South Porcupine general 

analysis areas but has been tentatively identified elsewhere within the TBNG. 

This plant species is suspected of occurring on TBNG lands where suitable 

habitat is present. This species generally has an affinity for gullied ridges and 

eroded badland hills. These sites generally consist of barren shale and clay 

outcrops with at least 50 percent bare soil, high salt content and shrink/swell 

clay soils. Typical habitat includes badland islands in grasslands.

Existing Conditions

Habitats for the Visher’s buckwheat are not present on the USFS lands within 

the general Wright analysis area. A few areas of highly eroded gullies 

consisting of barren shale or clay outcrops may be found in portions of the 

general Wright analysis area, but these sites generally provided a greater 

vegetation cover than is needed to provide optimum habitat for this species. 

The Visher’s buckwheat has not been recorded on the general Wright analysis 

area or adjacent areas. 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-43 

Indirect and Direct Impacts

If present on areas to be disturbed by mining, individuals of this species would 

be lost when topsoil is removed or during disturbances caused by other mining 

activities. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract 

would have no impact on the Visher’s buckwheat. As indicated, the general 

analysis areas for the North Hilight Field, South Hilight Field, West Hilight 

Field, North Porcupine and South Porcupine tracts do not provide optimum 

suitable habitat for this plant species so the potential loss of individuals or 

preferred habitats is not expected. 

H-3.2.17 Highbush-cranberry (Viburnum opulus var. americanum)

The highbush-cranberry, a sensitive plant species, is a perennial forb and has 

not been documented on USFS lands within the North Hilight Field, South 

Hilight Field, West Hilight Field, North Porcupine and South Porcupine general 

analysis areas or within the TBNG. In Wyoming, this plant species is found 

within Crook County and is suspected of occurring on TBNG lands where 

suitable habitat is present. This species generally has an affinity for moist 

sites including wooded hillsides, thickets or low woodlands. The highbushcranberry is found all across northern North America.

Existing Conditions

Habitats for the highbush-cranberry are not present on the USFS lands within 

the general Wright analysis area. Suitable moist, wooded habitats are not 

present on these USFS lands within the general Wright analysis area. The 

highbush-cranberry has not been recorded within the general Wright analysis 

area or adjacent areas. 

Indirect and Direct Impacts

If present on areas to be disturbed by mining, individuals of this species would 

be lost when topsoil is removed or during disturbances caused by other mining 

activities. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract 

would have no impact on the highbush-cranberry. As indicated, this species 

has not been documented in the general Wright analysis area and the general 

analysis areas for the North Hilight Field, South Hilight Field, West Hilight 

Field, North Porcupine and South Porcupine tracts do not provide suitable 

habitat for this plant species so the potential loss of individuals or preferred 

habitats is not expected. 

H-3.2.18 Northern leopard frog (Rana pipiens)

Northern leopard frogs range from the Great Slave Lake and Hudson Bay, 

south to Kentucky and New Mexico (NatureServe 2007). This species is 

considered relatively common within Wyoming (Baxter and Stone 1980, 
Appendix H 

H-44 Final EIS, Wright Area Coal Lease Applications 

Cerovski et al. 2004). Northern leopard frogs require shallow, permanent, or 

semi-permanent standing water with at least some emergent vegetation for 

breeding (Wagner 1997). Conversely, they use deeper lakes or ponds with welloxygenated water that does not freeze to the bottom as overwintering habitat 

(Wagner 1997). Leopard frogs must have good quality water to successfully 

reproduce, as degraded or turbid water has the potential to negatively affect 

development of eggs and tadpoles. Overcrowding and changes in water 

temperature and pH (5.5 or lower) can increase the incidence of disease and 

mortality (NatureServe 2007) in this species. Adult frogs feed upon a variety of 

insects and other invertebrates, tadpoles, snakes, and fish (Cerovski et al. 

2004), while tadpoles feed primarily upon small invertebrates, plant tissue, and 

organic debris. Adults also forage within aquatic and upland habitats, whereas 

tadpoles are restricted to aquatic habitats. Although their overall range 

remains essentially undiminished in size, many populations are declining. 

Major factors affecting leopard frog populations are habitat loss in some 

portions of their range, habitat degradation, overexploitation, interactions with 

non-native species, climate change, disease, and other unknown causes 

(Wagner 1997).

Existing Conditions − North Hilight Field LBA Tract

The northern leopard frog has been observed in southern Campbell County, 

but has not officially been recognized as breeding there (Cerovski et al. 2004). 

Although formal anuran surveys were not required or conducted at the 

adjacent Black Thunder, Jacobs Ranch, or North Antelope Rochelle mines, 

annual monitoring efforts for other species conducted in overlapping survey 

areas from 1983 through 2007 have not revealed the presence of northern 

leopard frogs or anuran egg masses on USFS lands or elsewhere within the 

general analysis area for the North Hilight Field LBA Tract. Those surveys 

occurred during all seasons, with biologists watching and listening for northern 

leopard frogs and other herptiles while conducting all other surveys throughout 

the area. It is unlikely that northern leopard frogs would have remained 

undetected during multiple surveys conducted during that long-term period if 

they were present in the area. Results from annual wildlife monitoring and 

baseline studies for the three mines are on file with, and available from, the 

WDEQ/LQD in Sheridan or Cheyenne, Wyoming and USFS Douglas Ranger 

District; those reports also include detailed descriptions of survey areas 

(including maps), methods, and dates for each year. 

Habitat conditions on USFS and non-USFS lands within the tract’s general 

analysis area are classified as unsuitable, as there are no available permanent 

or semi-permanent water sources. Water levels in drainages are typically too 

temporary and/or shallow to support tadpoles until metamorphosis, or allow 

frogs to successfully overwinter, respectively. All drainages throughout the 

tract’s general analysis area are ephemeral in nature and only carry water 

during or immediately following high intensity precipitation events, resulting in 

low quality or unsuitable habitat conditions for this frog species. The general 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-45 

lack of emergent vegetation near temporary water bodies limits their value to 

northern leopard frogs. 

Existing Conditions − South Hilight Field LBA Tract

The northern leopard frog has been observed in southern Campbell County, 

but has not officially been recognized as breeding there (Cerovski et al. 2004). 

Although formal anuran surveys were not required or conducted at the 

adjacent Black Thunder, Jacobs Ranch, or North Antelope Rochelle mines, 

annual monitoring efforts for other species conducted in overlapping survey 

areas from 1983 through 2007 have not revealed the presence of northern 

leopard frogs or anuran egg masses on USFS lands or elsewhere within the 

general analysis area for the South Hilight Field LBA Tract. Those surveys 

occurred during all seasons, with biologists watching and listening for northern 

leopard frogs and other herptiles while conducting all other surveys throughout 

the area. It is unlikely that northern leopard frogs would have remained 

undetected during multiple surveys conducted during that long-term period if 

they were present in the area. Results from annual wildlife monitoring and 

baseline studies for the three mines are on file with, and available from, the 

WDEQ/LQD in Sheridan or Cheyenne, Wyoming and USFS Douglas Ranger 

District; those reports also include detailed descriptions of survey areas 

(including maps), methods, and dates for each year. 

Habitat conditions on USFS and non-USFS lands within the tract’s general 

analysis area are classified as poor potential to unsuitable, as there are only 

limited seasonal water sources available. No permanent or semi-permanent 

waters are present anywhere on those USFS lands. Little Thunder Creek 

passes through USFS lands within the South Hilight Field tract. In its natural 

state, this ephemeral stream is typically dry by mid to late summer, and 

without flow to maintain open water, any pools persisting until winter freeze 

solid, thus limiting overwintering habitat for this species. Like Little Thunder 

Creek, all other drainages throughout the tract’s general analysis area are 

ephemeral in nature and only carry water during or immediately following high 

intensity precipitation events, resulting in low quality or unsuitable habitat 

conditions for this frog species. Water discharged from CBNG wells has 

enhanced the water supply within some portions of Little Thunder Creek and 

its tributaries, which has increased potential habitat for some aquatic and 

semi-aquatic species. However, those enhanced areas are still relatively limited 

and/or isolated in nature. Water levels in drainages are typically too 

temporary and/or shallow to support tadpoles until metamorphosis, or allow 

frogs to successfully overwinter, respectively. The general lack of emergent 

vegetation near temporary water bodies limits their value to northern leopard 

frogs. 

Existing Conditions − West Hilight Field LBA Tract

The northern leopard frog has been observed in southern Campbell County, 

but has not officially been recognized as breeding there (Cerovski et al. 2004). 

Although formal anuran surveys were not required or conducted at the 
Appendix H 

H-46 Final EIS, Wright Area Coal Lease Applications 

adjacent Black Thunder, Jacobs Ranch, or North Antelope Rochelle mines, 

annual monitoring efforts for other species conducted in overlapping survey 

areas from 1983 through 2007 have not revealed the presence of northern 

leopard frogs or anuran egg masses on USFS lands or elsewhere within the 

general analysis area for the West Hilight Field LBA Tract. Those surveys 

occurred during all seasons, with biologists watching and listening for northern 

leopard frogs and other herptiles while conducting all other surveys throughout 

the area. It is unlikely that northern leopard frogs would have remained 

undetected during multiple surveys conducted during that long-term period if 

they were present in the area. Results from annual wildlife monitoring and 

baseline studies for the three mines are on file with, and available from, the 

WDEQ/LQD in Sheridan or Cheyenne, Wyoming and USFS Douglas Ranger 

District; those reports also include detailed descriptions of survey areas 

(including maps), methods, and dates for each year. 

Habitat conditions on USFS and non-USFS lands within the tract’s general 

analysis area are classified as poor potential to unsuitable, as there are only 

limited seasonal water sources available. No permanent or semi-permanent 

waters are present anywhere on those USFS lands. Little Thunder Creek 

passes through USFS lands within the West Hilight Field tract. In its natural 

state, this ephemeral stream is typically dry by mid to late summer, and 

without flow to maintain open water, any pools persisting until winter freeze 

solid, thus limiting overwintering habitat for this species. Like Little Thunder 

Creek, all other drainages throughout the tract’s general analysis area are 

ephemeral in nature and only carry water during or immediately following high 

intensity precipitation events, resulting in low quality or unsuitable habitat 

conditions for this frog species. Water discharged from CBNG wells has 

enhanced the water supply within some portions of Little Thunder Creek and 

its tributaries, which has increased potential habitat for some aquatic and 

semi-aquatic species. However, those enhanced areas are still relatively limited 

and/or isolated in nature. A portion of Little Thunder Creek on USFS lands in 

the W1⁄2 Section 22, T.43N., R.71W. (Little Thunder Reservoir) has been 

dammed to retain water for at least part of each year. Despite that occasional 

increased water supply, the reservoir often lacks the emergent vegetation that 

is important for breeding and foraging leopard frogs. Water levels in drainages 

are typically too temporary and/or shallow to support tadpoles until 

metamorphosis, or allow frogs to successfully overwinter, respectively. The 

general lack of emergent vegetation near temporary water bodies limits their 

value to northern leopard frogs. 

Existing Conditions − North Porcupine LBA Tract

The northern leopard frog has been observed in southern Campbell County, 

but has not officially been recognized as breeding there (Cerovski et al. 2004). 

No suitable habitat is present on USFS lands within the general analysis area 

for the North Porcupine LBA Tract. Porcupine Creek crosses a narrow band 

(approximately 1,500 feet) of USFS lands in the western portion of the tract’s 

general analysis area (Figure H-4), but that small portion of the creek does not 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-47 

provide sufficient, persistent water quantities or quality to support northern 

leopard frogs; the same is true of the stream channel immediately upstream 

and downstream of USFS lands in that area. No other persistently flowing 

streams or persistent reservoirs are present on USFS lands within the North 

Porcupine tract’s general analysis area. 

Habitat conditions for northern leopard frogs vary considerably between the 

overall general analysis area for the North Porcupine LBA Tract and the USFS 

lands within that larger area. The tract’s general analysis area includes 

portions of Porcupine Creek and some of its ephemeral tributaries that 

occasionally retain small pools of water during spring and early summer. 

Within the general analysis area for the North Porcupine LBA Tract there are 

an estimated 19.7 acres of jurisdictional wetlands and other waters of the U.S. 

(OWUS). Of those 25.8 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 in-channel stock reservoirs. Without 

surface discharge of groundwater associated with CBNG development in the 

area, no water would be present in these ephemeral streams except in response 

to precipitation events and snow melt. Flows to maintain open water are 

therefore inconsistent and these streams are often dry by mid- to late summer; 

without flow to maintain open water, any pools persisting until winter freeze 

solid, which limits overwintering habitat for this species. Therefore, none of 

the physical characteristics considered as optimum for the various life stages of 

this species are present on the USFS lands throughout this tract’s general 

analysis area, and no leopard frogs or anuran egg masses have been 

documented on those lands during more than 25 years of annual monitoring 

efforts. No northern leopard frogs were ever recorded in the general analysis 

area during overlapping annual monitoring efforts for other species conducted 

from 1984 through 2007. Results from annual wildlife monitoring and baseline 

studies for all adjacent mines are on file with, and available from, the 

WDEQ/LQD in Sheridan or Cheyenne, Wyoming and the USFS Douglas Ranger 

District Office in Douglas, Wyoming. Those reports also include detailed 

descriptions of survey areas (including maps), methods, and dates for each 

year. 

Existing Conditions − South Porcupine LBA Tract

The northern leopard frog has been observed in southern Campbell County, 

but has not officially been recognized as breeding there (Cerovski et al. 2004). 

No suitable habitat is present on USFS lands within the general analysis area 

for the South Porcupine LBA Tract. Prior to CBNG development in this area, 

no persistent standing water was present within the South Porcupine tract’s 

general analysis area, including all USFS surface lands in that area (Figure H-
Appendix H 

H-48 Final EIS, Wright Area Coal Lease Applications 

5). Water sources on those lands are limited to an ephemeral tributary of 

Porcupine Creek (Mike’s Draw), which flows in response to precipitation events 

such as rain storms and excessive snow melt. However, surface discharge of 

groundwater associated with CBNG development within the tract’s general 

analysis area, which is a relatively recent phenomenon, has resulted in 

generally wetter conditions within the stream’s channel throughout the year. 

Within the tract’s entire general analysis area, there are an estimated 12.3 

acres of jurisdictional wetlands and other waters of the U.S. (OWUS). Of those 

12.3 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, all of which are present along Mike’s Draw.. The 

vegetated wetland areas consist primarily of palustrine emergent herbaceous 

wet meadow or marsh along the ephemeral stream channel. Without surface 

discharge of groundwater associated with CBNG development in the area, no 

water would be present in Mike’s Draw except in response to precipitation 

events and snow melt. Flows to maintain open water are therefore considered 

inconsistent, which limits overwintering habitat for this species. Therefore, 

none of the physical characteristics considered as optimum for the various life 

stages of this species are present on the USFS lands throughout this tract’s 

general analysis area, and no leopard frogs or anuran egg masses have been 

documented on those lands during more than 25 years of annual monitoring 

efforts. No northern leopard frogs were ever recorded in the general analysis 

area during overlapping annual monitoring efforts for other species conducted 

from 1984 through 2007. Results from annual wildlife monitoring and baseline 

studies for all adjacent mines are on file with, and available from, the 

WDEQ/LQD in Sheridan or Cheyenne, Wyoming and the USFS Douglas Ranger 

District Office in Douglas, Wyoming. Those reports also include detailed 

descriptions of survey areas (including maps), methods, and dates for each 

year. 

Direct and Indirect Effects − North, South and West Hilight Field LBA Tracts

Wetland and aquatic habitats for northern leopard frogs are considered very 

poor to unsuitable on USFS lands and elsewhere in the general analysis areas 

for the North Hilight Field, South Hilight Field and West Hilight Field LBA 

Tracts, as described above. Furthermore, no frog sightings have been recorded 

on USFS lands during baseline surveys or annual monitoring completed 

between 1983 and 2007. Consequently, northern leopard frogs and their 

aquatic and terrestrial habitats are not expected to be impacted if the USFS 

lands in these LBA tracts were leased. In the unlikely event that this species is 

present in the future, direct loss of, or injury to, foraging and dispersing frogs 

could result from encounters with mine vehicles or heavy equipment during 

topsoil stripping or other surface disturbance, although such risks are minimal 

due to the lack of frog sightings to date. 

It is possible that existing reservoirs and ponds (natural and those enhanced 

by CBNG discharge water), and those created for flood control, sedimentation, 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-49 

water storage purposes, or wetland mitigation measures could provide suitable 

foraging or breeding habitat for northern leopard frogs in the future. However, 

most artificial water structures would still be limited to relatively shallow, 

seasonal waters with little emergent vegetation that would not provide for the 

year-round habitat needs of this frog species. Should those efforts result in 

improved aquatic habitats, adult frogs, tadpoles, and/or egg masses present in 

the area could be injured or killed during activities associated with additional 

construction of diversion dikes or associated channels, or the dewatering of 

potential habitats downstream of a dike. Under those limited circumstances, 

potential impacts could include loss of individuals and foraging habitat, 

increased predation, and changes in stream morphology and hydrology. 

Standard mining procedures such as the use of silt barriers across affected 

stream channels and other similar efforts would minimize any negative impacts 

that might result from mine-related operations. Likewise, adherence to the 

Thunder Basin National Grassland Plan Standards and Guidelines (USFS 

2002) pertaining to water and wetlands would ensure that leopard frogs and 

other aquatic organisms present on USFS lands would not be negatively 

affected by increased sedimentation, degraded water chemistry, or otherwise 

damaged aquatic habitats. 

Direct and Indirect Effects − North and South Porcupine LBA Tracts

Wetland and aquatic habitats for northern leopard frogs are considered 

unsuitable to poor on USFS lands and elsewhere in the North and South 

Porcupine tracts’ general analysis areas, as described above. Furthermore, no 

frog sightings have been recorded on USFS lands during baseline surveys or 

annual monitoring completed between 1984 and 2007. Consequently, 

northern leopard frogs and their aquatic and terrestrial habitats are not 

expected to be impacted if the USFS lands in the North and South Porcupine 

LBA Tracts are leased and mined. 

In the unlikely event that this species is present in the North and South 

Porcupine tracts’ general analysis areas in the future, direct loss of, or injury 

to, foraging and dispersing frogs could result from encounters with mine 

vehicles or heavy equipment near Porcupine Creek during topsoil stripping or 

other surface disturbance. If the South Porcupine tract is leased and proposed 

for mining by PRC, the North Antelope Rochelle Mine does not presently intend 

to mine through Mike’s Draw and the potential habitat for this species would 

not be disturbed under the Proposed Action or Alternative 2. 

It is possible that existing reservoirs and ponds (natural and those enhanced 

by CBNG discharge waters), and those created for flood control, sedimentation, 

water storage purposes, or wetland mitigation measures could provide suitable 

foraging or breeding habitat for northern leopard frogs in the future. However, 

most artificial water structures would still be limited to relatively shallow, 

seasonal waters with little emergent vegetation that would not provide for the 

year-round habitat needs of this frog species. Should those efforts result in 

improved aquatic habitats, adult frogs, tadpoles, and/or egg masses present in 
Appendix H 

H-50 Final EIS, Wright Area Coal Lease Applications 

the area could be injured or killed during activities associated with additional 

construction of diversion dikes or associated channels, or the dewatering of 

potential habitats downstream of a dike. Under those limited circumstances, 

potential impacts could include loss of individuals and foraging habitat, 

increased predation, and changes in stream morphology and hydrology. 

Standard mining procedures, such as the use of silt barriers across affected 

stream channels and other similar efforts, would minimize any negative 

impacts that might result from mine-related operations. Likewise, adherence 

to the TBNG Plan Standards and Guidelines (USFS 2002) pertaining to water 

and wetlands would ensure that leopard frogs and other aquatic organisms 

present on USFS lands would not be negatively affected by increased 

sedimentation, degraded water chemistry, or otherwise damaged aquatic 

habitats. 

Determination of Effect and Rationale − North, South and West Hilight Field 

LBA Tracts

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. As indicated, USFS lands and adjacent non-federal lands 

within the North, South and West Hilight Field general analysis areas do not 

contain suitable habitat for northern leopard frogs. Water sources in the 

drainages in those areas are too temporary and shallow to support tadpoles 

until metamorphosis, or to allow frogs to successfully overwinter. If present, 

individual adult leopard frogs may be incidentally killed by vehicles or 

equipment. Habitat may be enhanced or created during certain mine 

operations, but water flow and depth associated with existing structures at the 

adjacent mines have not resulted in adequate conditions to support the life 

cycle needs of this species, and they are not expected to create those conditions 

anywhere in these three LBA tracts. As no northern leopard frogs have ever 

been documented on USFS lands within the overall general analysis areas for 

the North Hilight Field, South Hilight Field and West Hilight Field LBA Tracts, 

potential effects are expected to be negligible, if they occur at all. Furthermore, 

northern leopard frogs have been documented at other sites outside of the 

tracts’ general analysis areas that will not be affected by coal leasing actions. 

Determination of Effect and Rationale − North and South Porcupine LBA Tracts

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. As indicated, USFS lands and adjacent non-federal lands 

within the North and South Porcupine tracts’ general analysis areas do not 

currently contain suitable habitat for northern leopard frogs. Water sources in 

the drainages in those areas are too temporary and shallow to support tadpoles 

until metamorphosis, or to allow frogs to successfully overwinter. If present, 

individual adult leopard frogs may be incidentally killed by vehicles or 

equipment. Habitat may be enhanced or created during certain mine 

operations, but water flow and depth associated with existing structures at the 

adjacent North Antelope Rochelle Mine has not resulted in adequate conditions 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-51 

to support the life cycle needs of this species, and they are not expected to 

create those conditions anywhere in these two LBA tracts. As no northern 

leopard frogs have ever been documented on USFS lands within the overall 

general analysis areas for the North Porcupine and South Porcupine LBA 

Tracts, potential effects are expected to be negligible, if they occur at all. 

Furthermore, northern leopard frogs have been documented at other sites 

outside of the tract’s general analysis area that will not be affected by coal 

leasing actions. 

H-3.2.19 Black-tailed prairie dog (Cynomys ludovicianus)

The black-tailed prairie dog was removed from the USFWS federal listing 

process in 2004. The agency ruled that listing this species may be warranted, 

but was precluded by higher priority considerations. Consequently, the blacktailed prairie dog is no longer considered a candidate species under the 

Endangered Species Act (ESA). 

Black-tailed prairie dogs historically ranged throughout the Great Plains in 

short-grass and mixed-grass prairies. This species is also a common resident 

in the short- and mid-grass habitats of eastern Wyoming (Cerovski et al. 2004). 

The TBNG, which includes USFS lands in the general analysis areas for the 

North Hilight Field, South Hilight Field, West Hilight Field, North Porcupine 

and South Porcupine LBA Tracts, harbors one of the seven major colony 

complexes remaining in North America. Black-tailed prairie dogs are highly 

social, diurnal burrowing rodents that typically feed on grasses and forbs. 

Prairie dogs form colonies that are the main unit of a prairie dog population. 

This species has the ability to rapidly expand its distribution and population if 

not limited by pest control practices or disease, and will readily spread into 

recently disturbed areas. Many species such as the black-footed ferret, 

mountain plover, burrowing owl, and swift fox are dependent on prairie dogs 

during a portion of their life cycle. Black-tailed prairie dog occupied range and 

abundance has declined dramatically, and continues to exhibit a slow decline 

(NatureServe 2007). Major factors contributing to the decline include disease 

(sylvatic plague), urbanization, habitat conversion, and control efforts. 

Existing Conditions − North Hilight Field LBA Tract

No prairie dog colonies were present on USFS lands within the North Hilight 

Field LBA Tract general analysis area or its 2-mile perimeter in 2007. Four 

prairie dog colonies (approximately 53.8 total acres) were found on non-federal 

surface in the wildlife survey area for the North Hilight Field tract (Figure H-1). 

Of which, two colonies occurred within the general analysis area for the tract 

and are approximately 3.4 and 19.5 acres in size. The other two colonies were 

in the surrounding 2-mile perimeter, and are about 3.7 and 27.2 acres in size. 

None of these four colonies meet the 80-acre minimum for black-footed ferret 

habitat (USFWS 1989). However, the focus area for ferret reintroduction efforts 

is outside the coal mine region of the PRB of northeast Wyoming (refer to 

Management Area 3.63) (USFS 2002, Grenier 2003). That coal region includes 
Appendix H 

H-52 Final EIS, Wright Area Coal Lease Applications 

all USFS and surrounding lands within the general analysis area for the North 

Hilight Field LBA Tract. Additionally, some prairie dog colonies in that coal 

region were recently infested with the plague, while others are currently 

exposed to year-round disturbance associated with conventional oil and gas, 

CBNG, and coal (including open pits) resources, as well as seasonal 

recreational shooting and vehicular travel. 

Existing Conditions − South Hilight Field LBA Tract

A total of seven prairie dog colonies (approximately 177.2 total acres) were 

found within 2 miles of the general analysis area for the South Hilight Field 

LBA Tract in 2007, four of which were present on USFS lands. One colony 

(approximately 0.1 acre in size) on USFS lands was in the general analysis area 

itself, while the other three colonies on USFS lands were in the surrounding 2-

mile perimeter, and ranged in size from 7.7 to 89.1 acres, for a total of 

approximately 118 acres. Three additional prairie dog colonies were recorded 

on non-federal surface within or overlapping the 2-mile wildlife survey area 

(Figure H-2) in 2007, all three of which were outside of the tract’s general 

analysis area. The total area for those three colonies was approximately 59 

non-contiguous acres, and the sizes range from about 2 to 54 acres. 

Only the 89.1-acre colony meets the 80-acre minimum for black-footed ferret 

habitat (USFWS 1989). As noted above, that colony is not on USFS lands nor 

is it within the general analysis area for the South Hilight Field LBA Tract. 

However, the focus area for ferret reintroduction efforts is outside the coal mine 

region of the PRB of northeast Wyoming (refer to Management Area 3.63) (USFS 

2002, Grenier 2003). That coal region includes all USFS and surrounding 

lands within the general analysis area for the South Hilight Field LBA Tract. 

Additionally, some prairie dog colonies in that coal region were recently infested 

with the plague, while others are currently exposed to year-round disturbance 

associated with conventional oil and gas, CBNG, and coal (including open pits) 

resources, as well as seasonal recreational shooting and vehicular travel. 

Existing Conditions − West Hilight Field LBA Tract

A total of eight prairie dog colonies (approximately 167.5 total acres) were 

found within the wildlife survey area for the West Hilight Field LBA Tract in 

2007, three of which were present on USFS lands. The West Hilight Field 

wildlife survey area for this tract includes lands added by the BLM under 

Alternative 3 and the surrounding 2-mile perimeter. One colony 

(approximately 89.1 acres in size) on USFS lands was in the general analysis 

area itself, while the other two colonies on USFS lands were in the surrounding 

2-mile perimeter, and ranged from less than 1 acre to about 7 acres in size, for 

a total of approximately 96 acres. Five additional prairie dog colonies were 

recorded on non-federal surface within or overlapping the 2-mile wildlife survey 

area (Figure H-3) in 2007, all five of which were outside of the tract’s general 

analysis area. No colonies were present on adjacent lands within Alternative 3. 

The total area for those five colonies was approximately 63 non-contiguous 

acres, and the sizes range from about 2.6 to 27.2 acres. 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-53 

Only the 89.1-acre colony meets the 80-acre minimum for black-footed ferret 

habitat (USFWS 1989). As noted above, that colony is on USFS lands and is 

also within the general analysis area for the West Hilight Field LBA Tract. 

However, the focus area for ferret reintroduction efforts is outside the coal mine 

region of the PRB of northeast Wyoming (refer to Management Area 3.63) (USFS 

2002, Grenier 2003). That coal region includes all USFS and surrounding 

lands within the general analysis area for the West Hilight Field LBA Tract. 

Additionally, some prairie dog colonies in that coal region were recently infested 

with the plague, while others are currently exposed to year-round disturbance 

associated with conventional oil and gas, CBNG, and coal (including open pits) 

resources, as well as seasonal recreational shooting and vehicular travel. 

Existing Conditions − North Porcupine LBA Tract

Surveys have been conducted to locate prairie dog colonies within the 2-mile 

wildlife survey area surrounding the general analysis area for North Porcupine 

LBA Tract (Figure H-4). No prairie dog colonies were present on USFS lands 

within the North Porcupine tract’s general analysis area in 2007. Seventeen 

prairie dog colonies totaling approximately 1,211.4 non-contiguous acres were 

present within or overlapped the 2-mile wildlife survey area surrounding the 

North Porcupine tract’s general analysis area in 2007 (Figure H-4). Only one 

colony (approximately 18.6 acres in size) was within the general analysis area 

itself. The remaining 16 colonies ranged from 1.5 to 345.3 acres in size. 

The entire coal mine region of the PRB of northeast Wyoming, including all 

USFS and surrounding lands within the general analysis area for the South 

Porcupine LBA Tract, is beyond the focus area for ferret reintroduction efforts 

on the TBNG and in the general region (refer to Management Area 3.63-USFS 

2002, Grenier 2003). Additionally, some prairie dog colonies in that region are 

currently experiencing development associated with conventional oil and gas, 

CBNG, and coal (including open pits) resources. Year-round human activity 

and disturbance are already present in a few locations. 

Existing Conditions − South Porcupine LBA Tract

Surveys have been conducted to locate prairie dog colonies within the 2-mile 

wildlife survey area surrounding the general analysis area for South Porcupine 

LBA Tract (Figure H-5). No prairie dog colonies were present within the general 

analysis area for the tract in 2007. Ten prairie dog colonies totaling 

approximately 476.3 non-contiguous acres were present within or overlapped 

the 2-mile wildlife survey area surrounding the South Porcupine tract’s general 

analysis area in 2007 (Figure H-5). The largest colony was approximately 

345.3 acres in size; this colony is within both North and South Porcupine 

tracts’ wildlife survey areas. The remaining nine colonies were all less than 40 

acres in size. 

The entire coal mine region of the PRB of northeast Wyoming, including all 

USFS and surrounding lands within the general analysis area for the South 

Porcupine LBA Tract, is beyond the focus area for ferret reintroduction efforts 
Appendix H 

H-54 Final EIS, Wright Area Coal Lease Applications 

on the TBNG and in the general region (refer to Management Area 3.63-USFS 

2002, Grenier 2003). Additionally, some prairie dog colonies in that region are 

currently experiencing development associated with conventional oil and gas, 

CBNG, and coal (including open pits) resources. Year-round human activity 

and disturbance are already present in a few locations. 

Direct and Indirect Effects − North, South and West Hilight Field LBA Tracts

The current mining plans for the Black Thunder and Jacobs Ranch mines do 

not project any new surface disturbance in the two prairie dog colonies located 

within the general analysis area for the North Hilight Field LBA Tract. 

Nevertheless, those two colonies would be affected by the proposed leasing 

action at some point in time. As stated above, neither colony is located on 

USFS lands. Such impacts could have immediate results on prairie dogs if an 

occupied colony is suddenly subjected to the effects of a soil salvage operation, 

or is otherwise impacted in a short timeframe that precludes the dispersal of 

individuals prior to surface disturbance. However, as those activities typically 

occur incrementally across various portions of future mining areas, some 

individuals could disperse to undisturbed portions of the affected colony, or 

create one or more new colonies within the area. 

The current mining plans for the Black Thunder Mine do not project any new 

surface disturbance in the one prairie dog colony that is located within the 

general analysis area for the South Hilight Field LBA Tract. Nevertheless, that 

colony would be affected by the proposed leasing action at some point in time. 

As stated above, that very small colony (approximately 0.1 acre in size) is 

located on USFS lands. Such impacts could have immediate results on prairie 

dogs if an occupied colony is suddenly subjected to the effects of a soil salvage 

operation, or is otherwise impacted in a short timeframe that precludes the 

dispersal of individuals prior to surface disturbance. However, as those 

activities typically occur incrementally across various portions of future mining 

areas, some individuals could disperse to undisturbed portions of the affected 

colony, or create one or more new colonies within the area. 

The current mining plans for the Black Thunder Mine do not project any new 

surface disturbance in the one prairie dog colony that is located within the 

general analysis area for the West Hilight Field LBA Tract. Nevertheless, that 

colony would be affected by the proposed leasing action at some point in time. 

As stated above, that colony (89.1 acres in size) is located on USFS lands. 

Such impacts could have immediate results on prairie dogs if an occupied 

colony is suddenly subjected to the effects of a soil salvage operation, or is 

otherwise impacted in a short timeframe that precludes the dispersal of 

individuals prior to surface disturbance. However, as those activities typically 

occur incrementally across various portions of future mining areas, some 

individuals could disperse to undisturbed portions of the affected colony, or 

create one or more new colonies within the area. 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-55 

Smaller-scale disturbances associated with both the mining and CBNG 

industries can also impact prairie dog colonies and surrounding vegetation 

through fragmentation or loss of foraging and burrowing habitat. Linear 

disturbances associated with mining infrastructure, such as roads, power 

lines, fences, and pipelines will occur within narrow corridors over relatively 

short distances, and would be completed within shorter timeframes than the 

advancement of a surface mine pit. However, such disturbances would still 

pose some level of risks due to vehicular collisions or by enhancing habitat for 

mammalian and avian species that prey on prairie dogs. 

Some linear impacts could be minimized or mitigated through the consolidation 

of roads and electric utilities within common corridors, applying perch 

deterrents on overhead power poles, and reseeding pipeline disturbances 

quickly with appropriate seed mixes for the region. Minor surface disturbance 

near existing colonies would provide recently upturned soils that could 

facilitate the expansion of the existing colonies or the establishment of new 

ones, as prairie dogs will readily move into recently disturbed areas. Postmining reclamation could have similar potential benefits; prairie dogs have 

already demonstrated their ability to inhabit reclaimed lands at the nearby 

Antelope Mine (BLM 2008). 

All USFS Standards and Guidelines applicable to black-tailed prairie dogs 

outlined in the TBNG Plan (USFS 2002, page 1-20) would be implemented. To 

reduce risks and habitat loss for prairie dogs and other wildlife species closely 

associated with prairie dog colonies, new roads will be aligned outside colony 

boundaries where possible. If it is necessary to place a new road within a 

prairie dog colony, the amount of road in the colony will be minimized to the 

extent that soil, drainage, topographical and other physical factors will allow. 

Direct and Indirect Effects − North and South Porcupine LBA Tracts

The North Porcupine LBA tract and its general analysis area are almost entirely 

encompassed by the existing North Antelope Rochelle Mine permit area; 

therefore, it is possible that surface disturbance associated with coal removal 

from the mine’s current leases could occur on the tract regardless of whether 

or not additional leasing occurs in that area. As stated above, one colony 

(approximately 18.6 acres in size) was within the general analysis area for the 

North Porcupine LBA Tract in 2007; however, that colony is not located on 

USFS lands. That one colony would be affected by the proposed leasing action 

at some point in time. Mining disturbance associated with the adjacent North 

Antelope Rochelle Mine could impact those prairie dog colonies that exist 

elsewhere within the larger wildlife survey area surrounding this LBA tract 

(Figure H-4). Such impacts could have immediate results on prairie dogs if an 

occupied colony is abruptly subjected to a soil salvaging operation, or is 

otherwise impacted in a short timeframe that precludes dispersal prior to 

disturbance. However, as those activities typically occur incrementally across 

various portions of a mine permit area, some individuals could disperse to 
Appendix H 

H-56 Final EIS, Wright Area Coal Lease Applications 

undisturbed portions of the affected colony, or create one or more new colonies 

within the general area. 

The South Porcupine LBA tract and its general analysis area are almost 

entirely encompassed by the existing North Antelope Rochelle Mine permit 

area; therefore, it is possible that surface disturbance associated with coal 

removal from the mine’s current leases could occur on the tract, regardless of 

whether or not additional leasing occurs in that area. As no colonies are 

present in the South Porcupine tract’s general analysis area, leasing and 

mining this LBA tract under either the Proposed Action or Alternative 2 would 

not disturb any existing prairie dog colonies. However, mining disturbance 

associated with the adjacent North Antelope Rochelle Mine could impact those 

prairie dog colonies that exist elsewhere within the larger wildlife survey area 

surrounding the tract (Figure H-5). Such impacts could have immediate 

results on prairie dogs if an occupied colony is abruptly subjected to a soil 

salvaging operation, or is otherwise impacted in a short timeframe that 

precludes dispersal prior to disturbance. However, as those activities typically 

occur incrementally across various portions of a mine permit area, some 

individuals could disperse to undisturbed portions of the affected colony, or 

create one or more new colonies within the general area. 

Smaller-scale disturbances associated with both the mining and CBNG 

industries can also impact prairie dog colonies and surrounding vegetation 

through fragmentation or loss of foraging and burrowing habitat. Linear 

disturbances associated with mining infrastructure, such as roads, power 

lines, fences, and pipelines will occur within narrow corridors over relatively 

short distances, and would be completed within shorter timeframes than the 

advancement of a surface mine pit. However, such disturbances would still 

pose some level of risks due to vehicular collisions or by enhancing habitat for 

mammalian and avian species that prey on prairie dogs. 

Some linear impacts could be minimized or mitigated through the consolidation 

of roads and electric utilities within common corridors, applying perch 

deterrents on overhead power poles, and reseeding pipeline disturbances 

quickly with appropriate seed mixes for the region. Minor surface disturbance 

near existing colonies would provide recently upturned soils that could 

facilitate the expansion of the existing colonies or the establishment of new 

ones, as prairie dogs will readily move into recently disturbed areas. Postmining reclamation could have similar potential benefits; prairie dogs have 

already demonstrated their ability to inhabit reclaimed lands at the nearby 

Antelope Mine (BLM 2008). 

As no prairie dog colonies are present on USFS lands within the North and 

South Porcupine tracts’ general analysis areas, no USFS Standards and 

Guidelines applicable to black-tailed prairie dogs would be implemented. 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-57 

Determination of Effect and Rationale − North Hilight Field LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. Only two of the four black-tailed prairie dog colonies within the 

wildlife survey areas for the North Hilight Field LBA Tract would be physically 

disturbed by mining activities within the tract’s general analysis area, if the 

lease is issued. Those two colonies encompassed less than 23 acres, and 

neither of which were on USFS lands in 2007. Given the fact that two of the 

four colonies within the wildlife survey areas for the North Hilight Field LBA 

Tract were outside of the general analysis area (area of potential surface 

disturbance) associated with this proposed lease, the tendency of prairie dogs 

to disperse and expand their boundaries, and the incremental nature of 

surface coal mining relative to some other disturbance activities, the potential 

impacts to prairie dog colonies on and near USFS lands in the North Hilight 

Field LBA Tract would not have adverse consequences for the viability of the 

local or regional population. Disturbance and reclamation efforts will occur 

incrementally in varying locations throughout the permit area as mining 

progresses through the approved lease. 

Determination of Effect and Rationale − South Hilight Field LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. Only one of the seven black-tailed prairie dog colonies within 

the wildlife survey area for the South Hilight Field LBA Tract would be 

physically disturbed by mining activities within the tract’s general analysis 

area, if the lease is issued. That colony encompassed less than 1 acre in 2007, 

and it was on USFS lands. Given the fact that six of the seven colonies within 

the wildlife survey area for the South Hilight Field LBA Tract were outside of 

the general analysis area (area of potential surface disturbance) associated with 

this proposed lease, the tendency of prairie dogs to disperse and expand their 

boundaries, and the incremental nature of surface coal mining relative to some 

other disturbance activities, the potential impacts to prairie dog colonies on 

and near USFS lands in the South Hilight Field LBA Tract would not have 

adverse consequences for the viability of the local or regional population. 

Disturbance and reclamation efforts will occur incrementally in varying 

locations throughout the permit area as mining progresses through the 

approved lease. 

Determination of Effect and Rationale − West Hilight Field LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. Only one of the eight black-tailed prairie dog colonies within 

the wildlife survey area for the West Hilight Field LBA Tract would be physically 

disturbed by mining activities within the tract’s general analysis area, if the 

lease is issued. That colony encompassed 89.1 acres in 2007, and it was on 

USFS lands. Given the fact that seven of the eight colonies within the wildlife 

survey area for the West Hilight Field LBA Tract were outside of the general 
Appendix H 

H-58 Final EIS, Wright Area Coal Lease Applications 

analysis area (area of potential surface disturbance) associated with this 

proposed lease, the tendency of prairie dogs to disperse and expand their 

boundaries, and the incremental nature of surface coal mining relative to some 

other disturbance activities, the potential impacts to prairie dog colonies on 

and near USFS lands in the West Hilight Field LBA Tract would not have 

adverse consequences for the viability of the local or regional population. 

Disturbance and reclamation efforts will occur incrementally in varying 

locations throughout the permit area as mining progresses through the 

approved lease. 

Determination of Effect and Rationale − North Porcupine LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. No black-tailed prairie dog colonies would be physically 

disturbed by mining activities on USFS lands within the tract’s general analysis 

area, if the lease is issued. Only one colony (approximately 18.6 acres in size) 

is present on non-federal lands in the North Porcupine tract general analysis 

area. Prairie dog colonies located within the existing North Antelope Rochelle 

Mine permit area could be impacted by mining operations regardless of 

whether the North Porcupine LBA Tract is leased. Given the limited additional 

impacts to prairie dog colonies within the North Porcupine tract’s general 

analysis area, the tendency of prairie dogs to disperse and expand their 

boundaries, and the incremental nature of surface coal mining relative to some 

other disturbance activities, the potential impacts to prairie dog colonies on 

and near USFS lands in the North Porcupine tract’s wildlife survey area would 

not have adverse consequences for the viability of the local or regional 

population. Disturbance and reclamation efforts will occur incrementally in 

varying locations throughout the permit area as mining progresses through the 

approved lease. 

Determination of Effect and Rationale − South Porcupine LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. No black-tailed prairie dog colonies would be physically 

disturbed by mining activities on USFS lands within the tract’s general analysis 

area, if the lease is issued. No colonies are present on either federal or nonfederal lands in the South Porcupine tract’s general analysis area. Prairie dog 

colonies located within the existing North Antelope Rochelle Mine permit area 

could be impacted by mining operations regardless of whether the South 

Porcupine LBA Tract is leased. Given the tendency of prairie dogs to disperse 

and expand their boundaries, and the incremental nature of surface coal 

mining relative to some other disturbance activities, the potential impacts to 

prairie dog colonies on and near USFS lands in the South Porcupine tract’s 

wildlife survey area would not have adverse consequences for the viability of 

the local or regional population. Disturbance and reclamation efforts will occur 

incrementally in varying locations throughout the permit area as mining 

progresses through the approved lease. 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-59 

H-3.2.20 Swift Fox (Vulpes velox)

The swift fox was removed from the USFWS federal listing process in 1995, 

after extensive field surveys demonstrated that the population was greater than 

expected. This species is considered to be common within the eastern Great 

Plains grasslands of Wyoming (Cerovski et al. 2004), though it typically occurs 

at very low densities. The exact status of the population is unknown but 

believed to be increasing, especially in the Northern Plains. Swift foxes are 

largely nocturnal and typically prefer flat to gently rolling, short- or mixedgrass prairies, generally lacking in shrubs or woody vegetation (Cotterill 1997). 

This species uses multiple den sites year-round for shelter, protection from 

predators, and rearing young. Burrows of other mammals such as badgers 

(Taxidea taxus), red foxes (Vulpes vulpes), and prairie dogs are often used or 

modified for those purposes. Small to mid-sized mammals constitute the bulk 

of their diet. Swift foxes have little fear of humans and may den in proximity to 

human disturbances (residences and busy roadways). This tolerance also 

makes them susceptible to trapping, vehicle collisions, and attacks by dogs. 

Major threats faced by the swift fox include habitat loss and degradation, 

interspecific competition with red fox and coyote (Canis latrans), and vehicle 

collisions.

Existing Conditions − North, South and West Hilight Field LBA Tracts

Swift fox have been observed in large grassland blocks in southern Campbell 

County with more frequency in recent years, and are presumed to breed there. 

This species has also been documented within the overall TBNG. However, 

sagebrush communities dominate the general analysis areas for the North 

Hilight Field, South Hilight Field, and West Hilight Field LBA Tracts, as well as 

USFS lands in that area. The prevalence of sagebrush throughout this area 

largely explains the extremely limited sightings of this grassland fox over the 

last 25 years, as described below. Burrows within the existing black-tailed 

prairie dog colonies and scattered badger or red fox burrows could be used by 

swift foxes as den or shelter sites, and swift fox could forage in the area. 

No specific surveys for swift fox were conducted for this analysis. However, 

such efforts were completed in 2002 using USFS survey protocols for other 

unrelated projects. Those surveys occurred within 13.5 miles of USFS lands in 

the North Hilight Field Tract’s general analysis area; within 2.0 miles of USFS 

lands in the South Hilight Field Tract’s general analysis area; and within 6.0 

miles of USFS lands in the West Hilight Field Tract’s general analysis area. 

Nocturnal spotlight surveys for rabbits and hares were conducted as part of 

annual wildlife monitoring at adjacent existing mines every year since at least 

1994, with diurnal surveys for a variety of vertebrate species occurring across 

all seasons annually since the early 1980s. All of those survey efforts 

overlapped significant portions of the North Hilight Field, South Hilight Field, 

and West Hilight Field tract’s wildlife survey areas. 

As a result of those combined efforts, one swift fox sighting was made 

approximately 5 miles south of the North Hilight Field tract, on USFS lands in 

the South Hilight Field tract, along Little Thunder Creek between 1995 and 
Appendix H 

H-60 Final EIS, Wright Area Coal Lease Applications 

1997, in T.43N., R.71W., SE1⁄4 Section 23 (USFS 2003). A lone fox was also 

observed on adjacent lands in T.43N., R.71W., SW1⁄4 Section 14 during that 

period. No swift foxes have ever been recorded on USFS or other lands within 

the general analysis areas for the North and West Hilight Field LBA Tracts. No 

swift foxes have been recorded elsewhere in the overall Black Thunder Mine 

annual monitoring area since surveys began in 1983. 

Few other swift fox sightings have been recorded elsewhere within the 

surrounding region during specific surveys or incidental to other searches at 

local mines over the last 25 years. Those efforts were conducted as part of 

annual wildlife monitoring by contract and USFS biologists on private and 

federal lands in the area. One swift fox was documented approximately 4 to 6 

miles south of USFS lands within the general analysis area for the South 

Hilight Field tract, in T.42N., R.70W., SE1⁄4 Section 15, during spotlight 

trapping efforts for sage-grouse at the nearby North Antelope Rochelle Mine in 

March 2002. The nearest other sighting occurred in T.43N., R.72W., SE1⁄4 

Section 20 between 1995 and 1997. Reports from all annual monitoring and 

special studies are on file at the USFS Douglas Ranger District Office in 

Douglas and/or with WDEQ/LQD in Cheyenne. 

Existing Conditions − North and South Porcupine LBA Tracts

Swift fox have been observed in large grassland blocks in southern Campbell 

County with more frequency in recent years, and are presumed to breed there. 

This species has also been documented within the overall TBNG. 

Sagebrush communities generally dominate the wildlife survey area for the 

North Porcupine LBA Tract, though grasslands are more prevalent in the 

southwestern portion of the tract’s general analysis area. Potential swift fox 

habitat in that area is largely restricted to the western extent, west of the 

Antelope Road (Figure H-4). The South Porcupine tract’s general analysis area 

is dominated by various native and introduced grassland species considered 

suitable habit for this species. However, the prevalence of sagebrush 

throughout these two tracts’ wildlife survey areas largely explains the extremely 

limited sightings of this grassland fox over the last 25 years of monitoring 

efforts. Burrows within the existing black-tailed prairie dog colonies and 

scattered badger or red fox burrows could be used by swift foxes as den or 

shelter sites, and swift fox could forage in the area. 

No specific surveys for swift fox were conducted for this analysis. However, 

such efforts were completed in 2002 using USFS survey protocols for other 

unrelated projects. Those surveys included USFS lands within and 

immediately adjacent to the North and South Porcupine tracts’ general analysis 

areas, as well as additional lands in the surrounding area. Nocturnal spotlight 

surveys for rabbits and hares were conducted as part of annual wildlife 

monitoring at adjacent existing mines every year since at least 1994, with 

diurnal surveys for a variety of vertebrate species occurring across all seasons 

annually since the early 1980s. All of those survey efforts overlapped all or 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-61 

significant portions of the North and South Porcupine tracts’ wildlife survey 

areas. Despite those combined survey efforts, no swift fox have ever been 

recorded on USFS or other lands within the North and South Porcupine tracts’ 

general analysis areas. 

Few other swift fox sightings have been recorded elsewhere within the North 

Porcupine tract’s wildlife survey area or surrounding region during specific 

surveys or incidental to other searches at local mines over the last 25 years. 

Those efforts were conducted as part of annual wildlife monitoring by USFS 

and contract biologists on private and federal lands in the area. One swift fox 

was documented on USFS lands approximately 0.5 mile northeast of the North 

Porcupine tract’s general analysis area in March 2002. The fox was observed 

in T.42N., R.70W., SE1⁄4 Section 15 during spotlight trapping efforts for sagegrouse at the nearby North Antelope Rochelle Mine. Swift fox have been 

observed on private surface in the southwestern portion of the two-mile wildlife 

survey area for the South Porcupine tract in recent years. Two individuals (an 

adult and juvenile) were observed during spotlight lagomorph surveys 

conducted for the adjacent Antelope Mine on private surface (in T.41N., 

R.71W., NW1⁄4 SW1⁄4 Section 22 and NE1⁄4 SW1⁄4 Section 22, respectively) 

approximately 4 miles south of the North Porcupine tract’s general analysis 

area in October 2005. A pair of swift foxes was observed in the adjacent 

sections to the west and south during similar spotlight surveys conducted in 

both 2006 and 2007. 

Direct and Indirect Effects − North, South and West Hilight Field LBA Tracts

Due to the overall poor quality habitat conditions on USFS and adjacent lands 

in the North Hilight Field, South Hilight Field and West Hilight Field LBA 

Tracts’ general analysis areas, and the sightings of very few swift fox in that 

general area over the last 25 years of annual monitoring (including spotlight 

searches for other species), no direct or indirect impacts are anticipated for this 

species. Given these circumstances, species-specific Standards and Guidelines 

outlined in the TBNG Plan (USFS 2002, page 1-20) would not apply. 

Direct and Indirect Effects − North and South Porcupine LBA Tracts

Due to absence of swift fox observations in the general analysis area for the 

North Porcupine tract, the limited presence of suitable habitats on USFS and 

adjacent lands in that area and the surrounding wildlife survey area, and the 

lone sighting of a single swift fox in that area over the last 25 years of annual 

monitoring (including spotlight searches for other species), no direct or indirect 

impacts are anticipated for this species within the North Porcupine tract’s 

general analysis area. Given these circumstances, species-specific Standards 

and Guidelines outlined in the TBNG Plan (USFS 2002, page 1-20) would not 

apply. 

Suitable but unoccupied swift fox habitat is present on and near USFS lands 

and adjacent lands within the general analysis area for the South Porcupine 

LBA Tract, though individuals have been observed in recent years 
Appendix H 

H-62 Final EIS, Wright Area Coal Lease Applications 

approximately 1.25 miles to the southwest, within the surrounding wildlife 

survey area for this LBA tract. Should this species be present on those lands 

in the future, direct loss of or injury to individuals foraging or denning within, 

or passing through that area could result from vehicle collisions or encounters 

with equipment associated with mine-related activities. Swift fox are relatively 

tolerant of human activities, but may avoid areas directly affected by mine 

operations as human presence and noise escalate with active mining. As the 

population size and residency status of the individuals in the area are largely 

unknown, some swift fox may remain within undisturbed habitats in the 

vicinity of mining encroachment. 

For the South Porcupine LBA Tract, the Proposed Action or Alternatives could 

also disturb potential swift fox foraging, denning, or shelter habitat on USFS 

and adjacent lands within the tract’s general analysis area. Those habitats 

could be removed, altered, or fragmented to varying degrees by one or more 

mine- or non-mine-related activities such as topsoil removal and a variety of 

linear disturbances (e.g., roads, fences, power lines, and pipelines). However, 

the latter disturbances will occur within narrow corridors over relatively short 

distances, and will typically be completed within a few days. Linear 

disturbances and habitat alterations could also provide convenient travel 

corridors and habitat for larger mammalian predators that could compete with 

swift foxes for prey species. The type, timing, location, and extent of habitat 

disturbance will vary throughout the general analysis area and on USFS lands 

as mining operations progress. Reclamation of disturbed areas will occur 

incrementally as mining is completed in a given portion of the area, and will 

eventually provide additional foraging and potential denning habitat for the 

swift fox. Surface disturbing activities may result in a short-term, localized 

decrease in prey base (small rodents and voles), but due to their high 

reproductive potential and tendencies to re-establish and adapt to disturbed 

and reclaimed areas, prey numbers should increase quickly after the 

disturbance. Should swift fox be documented on or adjacent to USFS lands in 

the tract’s general analysis area, that agency would determine whether speciesspecific Standards and Guidelines outlined in the TBNG Plan (USFS 2002, page 

1-20) would apply. 

Determination of Effect and Rationale − North Hilight Field LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. Habitat conditions in the North Hilight Field tract’s general 

analysis area are considered poor quality due to the prevalence of sagebrush 

shrublands and limited presence of grassland expanses. Only two observations 

of swift fox have been recorded in the general region despite annual monitoring 

surveys in all or most of those areas over the last 25 years, and both were 4 to 

5 miles south of this LBA tract. Furthermore, sufficient suitable habitat 

(grasslands) is present elsewhere within the general vicinity that could sustain 

swift foxes as project activities disturb the general analysis area for the North 

Hilight Field LBA tract. Existing and future reclaimed grasslands will create or 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-63 

enhance potential swift fox habitat once mining has been completed in the 

tracts. 

Determination of Effect and Rationale − South Hilight Field LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. Habitat conditions in the South Hilight Field tract’s general 

analysis area are considered poor quality due to the prevalence of sagebrush 

shrublands and limited presence of grassland expanses. The only swift fox 

observation ever recorded on USFS lands in the South Hilight Field Tract 

occurred along Little Thunder Creek 11 to 13 years ago, despite annual 

monitoring surveys in all or most of those areas during and subsequent to that 

time. Only one other observation of a swift fox has been recorded in the tract’s 

wildlife survey area during that period, although it was outside of the tract’s 

general analysis area. Furthermore, sufficient suitable habitat (grasslands) is 

present elsewhere within the general vicinity that could sustain swift foxes as 

project activities disturb the general analysis area for this LBA tract. Existing 

and future reclaimed grasslands will create or enhance potential swift fox 

habitat once mining has been completed in the tract. 

Determination of Effect and Rationale − West Hilight Field LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. Habitat conditions in the West Hilight Field tract’s general 

analysis area are considered poor quality due to the prevalence of sagebrush 

shrublands and limited presence of grassland expanses. Only two swift fox 

observations have ever been recorded near this tract, both of which occurred 

approximately 13 years ago on adjacent lands roughly one mile east of the 

tract’s general analysis area. Furthermore, sufficient suitable habitat 

(grasslands) is present elsewhere within the general vicinity that could sustain 

swift foxes as project activities disturb the general analysis area for this LBA 

tract. Existing and future reclaimed grasslands will create or enhance 

potential swift fox habitat once mining has been completed in the tract. 

Determination of Effect and Rationale − North Porcupine LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. Habitat for this species on USFS lands within the western 

portion of the general analysis area for the North Porcupine LBA Tract is 

currently considered as suitable but unoccupied. No fox sightings have been 

documented on those USFS lands during specific and incidental surveys 

conducted over the last 25 years (1984-2007). Only four sightings have been 

recorded within or near the tract’s two-mile wildlife survey area during that 

period: one in 2002, and three since 2005. The three most recent sightings 

were at least 3 miles to the south, and on the far side of a railroad and county 

road between the sightings and the nearest USFS lands. 
Appendix H 

H-64 Final EIS, Wright Area Coal Lease Applications 

Determination of Effect and Rationale − South Porcupine LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. Habitat for this species on USFS lands within the general 

analysis area for the South Porcupine LBA Tract is currently considered as 

suitable but unoccupied. No fox sightings have been documented on those 

USFS lands during specific and incidental surveys conducted over the last 25 

years (1984-2007). Only four sightings have been recorded within or near the 

South Porcupine tract’s two-mile wildlife survey area during that period: one in 

2002, and three since 2005. The three most recent sightings were at least 1.75 

miles to the southwest, and on the far side of a railroad and county road 

between the sightings and the nearest USFS lands. 

H-3.2.21 Long-billed curlew (Numenius americanus)

Long-billed curlews breed from interior British Columbia and southern Alberta 

through southern Manitoba, south to central California, and east to western 

North Dakota, central South Dakota, central Nebraska, western Kansas, 

northeastern New Mexico, and northern Texas (Dechant et al. 2003a). The 

long-billed curlew is a relatively uncommon summer resident of grasslands and 

sagebrush-grasslands in Wyoming (Cerovski et al. 2004). Curlews are ground 

nesters, and require large open expanses of grassland, with relatively low 

vegetation and few shrubs in which to nest (Hill 1998). The nest is typically a 

shallow scrape or depression, thinly lined with grass, weeds or cow dung, 

typically near water or moist areas. 

Curlews use historically occupied sites each year, and some individual birds 

may reuse the same territories from year to year (Dechant et al. 2003a). 

Curlews primarily feed upon insects but also eat other invertebrates, small 

crustaceans, toads, and eggs and nestlings of other birds. This species forages 

in grasslands, wet meadows, prairie dog colonies, and occasionally along the 

margins of wetlands. Lakeshores and river valleys are often used during fall as 

migration staging areas (Hill 1998). Although some populations may be 

declining, overall population trends suggest long-billed curlew numbers are 

stable or increasing slightly. The major factor affecting curlew populations is 

habitat destruction and fragmentation. 

Existing Conditions − North, South and West Hilight Field LBA Tracts

Long-billed curlews are uncommon summer residents within the TBNG. The 

areas evaluated for this analysis include USFS and adjacent lands within the 

general analysis areas for the North, South and West Hilight Field LBA Tracts. 

As described above for the northern leopard frog and swift fox, those areas are 

dominated by sagebrush habitats with scattered stands of upland grasslands 

and few surface water features. No significant wetlands (i.e., large lakes) or 

other persistent water conditions that might attract large numbers of curlews 

during migration exist within the North, South and West Hilight Field tracts’ 

wildlife survey areas. Consequently, habitat conditions in the tracts’ general 

analysis areas and surrounding lands would be suitable for foraging migrants, 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-65 

but they do not provide large expanses of grassland areas for nesting activities. 

No long-billed curlews have ever been documented on USFS lands or adjacent 

lands in the general analysis areas or larger wildlife survey areas for the North, 

South and West Hilight Field LBA Tracts. Likewise, few curlews have been 

observed in the surrounding region during annual wildlife monitoring in the 

area over the last 24 or more years. Most of those sightings occurred during 

spring months and beyond USFS lands, and were likely individual migrants or 

non-breeding adults. 

No nesting occurrences have been documented for long-billed curlews in 

southern Campbell County (Cerovski et al. 2004), including USFS lands in the 

North, South and West Hilight Field tracts’ general analysis areas and adjacent 

lands. Potential foraging habitat is present on USFS and adjacent lands in 

those areas and elsewhere within the 2-mile wildlife survey perimeters, but 

nesting habitat conditions are poor to unsuitable. CBNG development 

activities occur throughout the region, with active mining (including open pits) 

also occurring in the near vicinity. Therefore, potential foraging habitats would 

be disturbed by the Proposed Action and Alternatives for these three LBA 

tracts. 

Existing Conditions − North and South Porcupine LBA Tracts

Long-billed curlews are uncommon summer residents within the TBNG. 

However, no nesting occurrences have been documented for long-billed curlews 

in southern Campbell County (Cerovski et al. 2004), including USFS lands in 

the North and South Porcupine tracts’ general analysis areas and adjacent 

lands. As described above, the general analysis area for the North Porcupine 

tract is dominated by sagebrush habitats and the general analysis area for the 

South Porcupine tract is dominated by upland grassland habitats. No 

significant wetlands (i.e., large lakes) or other persistent water conditions that 

might attract large numbers of curlews during migration exist within either the 

North or South Porcupine tracts’ wildlife survey areas. Consequently, habitat 

conditions in these two LBA tracts’ general analysis areas and surrounding 

lands would be suitable for foraging migrants, and they do not provide large 

expanses of grassland areas for nesting activities. 

No long-billed curlews have ever been documented on USFS lands in the 

general analysis areas or larger wildlife survey areas for the North and South 

Porcupine LBA Tracts. Likewise, few curlews have been observed in the 

surrounding region during annual wildlife monitoring conducted in the general 

area over the last 25 years. Those general surveys occurred repeatedly 

throughout the breeding season each year. All curlew sightings that have 

occurred in the general region over time were recorded during spring months 

and were beyond USFS lands; those individuals were likely migrants or nonbreeding adults. 
Appendix H 

H-66 Final EIS, Wright Area Coal Lease Applications 

Direct and Indirect Effects

Given the lack of sightings of long-billed curlews in the general analysis areas 

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

Porcupine, and South Porcupine LBA Tracts and surrounding areas over the 

last 25 years, and the fact that habitat conditions in those areas are only 

suitable for foraging migrants or non-breeding adults, the Proposed Action and 

Alternatives for each of the LBA tracts are unlikely to cause any direct injury or 

mortality to this species. However, if migrants were present, future mining 

activities could result in injuries or mortalities to foraging individuals. 

Foraging individuals may also be displaced by human activities and noise 

associated with mining. Potential foraging habitats may be disturbed, 

removed, or fragmented by mining activities. The type, timing, location, and 

extent of habitat disturbance will vary throughout the tracts’ general analysis 

areas as operations progress. Reclamation of disturbed areas will occur 

incrementally as mining is completed in given portions of the three applicant 

mines, and will eventually mitigate impacts to some degree. The Jacobs 

Ranch, Black Thunder, and North Antelope Rochelle mine’s reclamation plans 

would incorporate the replacement of jurisdictional wetland acreages existing 

prior to mining with at least equal types and numbers of wetland acreages. 

The creation of wetland habitats, especially where adjacent to native or 

reclaimed grassland habitats, could provide additional (although limited) 

foraging areas for curlews. 

As no long-billed curlews have been documented within USFS lands or other 

lands in or near the North Hilight Field, South Hilight Field, West Hilight Field, 

North Porcupine, and South Porcupine LBA Tracts’ general analysis areas, and 

habitat conditions do not provide quality nesting areas, species-specific 

Standards and Guidelines outlined in the Grassland Plan (USFS 2002) would 

not apply. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract may 

impact individuals but is not likely to cause a trend to federal listing or loss of 

viability within the planning area. As this species appears to be an infrequent 

visitor to the six WAC LBA tracts’ general analysis areas, and good quality 

foraging and nesting habitat is not present within the general Wright analysis 

area, impacts to this species are likely to be minimal. Loss, degradation, or 

fragmentation of potential foraging habitat and potential collisions with 

vehicles may occur. Enhanced water features and grasslands created by 

reclamation may provide some limited foraging or nesting habitats. 

H-3.2.22 Ferruginous hawk (Buteo regalis)

Ferruginous hawks breed throughout much of the western United States and 

portions of three Canadian provinces (Johnsgard 1990). This species nests 

throughout Wyoming (Cerovski et al. 2004) and occupies portions of the state 

during winter. Large expanses of grassland and shrubland, where livestock 

grazing (vs. cultivation) is the predominant land use, provide the most suitable 

habitat (Schmutz 1989, Johnsgard 1990). Most ferruginous hawks in the PRB 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-67 

nest on the ground (usually elevated sites, though some pairs nest in small 

trees). Typical nest sites include hilltops, rock outcrops, eroded creek banks, 

small trees, and even relatively level ground. The ferruginous hawk relies 

primarily on two mammalian families for the majority of its prey: Leporidae

(rabbits and hares) and Sciuridae (ground squirrels and prairie dogs). 

Numerous nests can occur within the territory of a single pair, and ferruginous 

hawks often reuse nests for many years. 

This species may be sensitive to human disturbance, especially during the 

nesting period (White and Thurow 1985). This sensitivity can be heightened in 

years of low prey abundance. Accurate information regarding the trend for the 

ferruginous hawk is limited and mixed. Some populations may be declining 

(Bechard and Schmutz 1995); however, overall population trends suggest 

numbers are stable or increasing (NatureServe 2007). Major factors affecting 

ferruginous hawk populations include habitat destruction and fragmentation, 

and human disturbance. 

Existing Conditions − North Hilight Field LBA Tract

Annual monitoring has documented that ferruginous hawks nested in the 

vicinity of the Black Thunder Mine during each of the last 25 years, and fledged 

young in all but one of those years. Similar long-term nesting has occurred at 

the neighboring Jacobs Ranch and North Antelope Rochelle mines. Many of 

those nests were located on USFS lands. Details describing the number of 

intact and active nests within the mine monitoring survey areas in a given year 

are available in annual monitoring and baseline wildlife reports on file at the 

USFS Douglas Ranger District Office in Douglas and/or with WDEQ/LQD in 

Cheyenne. 

The presence or absence of nest material does not determine whether the USFS 

considers a site as “active” (occupied during at least 1 of the last 7 years). No 

ferruginous hawk nest sites have been documented on USFS lands within the 

North Hilight Field tract’s general analysis area or surrounding 2-mile wildlife 

survey area during annual wildlife monitoring surveys conducted through 

2007. Seven nest sites in two territories have been recorded on non-federal 

surface within the general analysis area through 2007; five of the seven sites 

still had nest material present that year (Figure H-1). Through 2007, 24 

individual ferruginous hawk nests plus 3 multi-species sites used by 

ferruginous hawks and at least one other raptor species over the years have 

been identified within the tract’s 2-mile wildlife survey area. The 27 nests 

represented at least 10 different territories. All but 9 of the 27 sites still had 

nest material present in 2007. 

Existing Conditions − South Hilight Field LBA Tract

Annual monitoring has documented that ferruginous hawks nested in the 

vicinity of the Black Thunder Mine during each of the last 25 years, and fledged 

young in all but one of those years. Similar long-term nesting has occurred at 

the neighboring Jacobs Ranch and North Antelope Rochelle mines. Many of 
Appendix H 

H-68 Final EIS, Wright Area Coal Lease Applications 

those nests were located on USFS lands. Details describing the number of 

intact and active nests within the mine monitoring survey areas in a given year 

are available in annual monitoring and baseline wildlife reports on file at the 

USFS Douglas Ranger District Office in Douglas and/or with WDEQ/LQD in 

Cheyenne. 

The presence or absence of nest material does not determine whether the USFS 

considers a site as “active” (occupied during at least 1 of the last 7 years). 

Seven ferruginous hawk nest sites in two territories have been documented on 

USFS lands within the South Hilight Field tract’s general analysis area during 

annual wildlife monitoring surveys conducted through 2007 (Figure H-2). Two 

of the seven sites still had nest material present that year. No nest sites were 

present on non-federal lands within the general analysis area during any 

monitoring year. 

Nine additional ferruginous hawk nest sites in five territories have been 

recorded on USFS surface within the tract’s 2-mile wildlife survey area through 

2007; two of the nine sites had been used by ferruginous hawks and at least 

one other raptor species over the years. Five nest sites were still physically 

present in 2007. The remaining 30 nest sites (25 individual nests plus 5 multispecies sites) are located on non-federal lands within the 2-mile wildlife survey 

area; none of those nests are within the tract’s general analysis area itself. The 

30 nests were in at least 10 different territories. Only 10 of the 30 sites still 

had nest material present in 2007. 

Existing Conditions − West Hilight Field LBA Tract

Annual monitoring has documented that ferruginous hawks nested in the 

vicinity of the Black Thunder Mine during each of the last 25 years, and fledged 

young in all but one of those years. Similar long-term nesting has occurred at 

the neighboring Jacobs Ranch and North Antelope Rochelle mines. Many of 

those nests were located on USFS lands. Details describing the number of 

intact and active nests within the mine monitoring survey areas in a given year 

are available in annual monitoring and baseline wildlife reports on file at the 

USFS Douglas Ranger District Office in Douglas and/or with WDEQ/LQD in 

Cheyenne. 

The presence or absence of nest material does not determine whether the USFS 

considers a site as “active” (occupied during at least 1 of the last 7 years). 

Three ferruginous hawk nest sites in two territories have been documented on 

USFS lands within the West Hilight Field tract’s general analysis area during 

annual wildlife monitoring surveys conducted through 2007. Two sites still 

had nest material present that year (Figure H-3). 

Only one additional nest site has been recorded on USFS surface within the 2-

mile wildlife survey area through 2007. No material was present at the nest 

site in 2007. Nine additional nest sites in three territories were present on 

non-federal lands within the tract’s general analysis area during the 2007 

survey. Nest material was present at four of the nine sites that year. 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-69 

An additional 40 nest sites (24 individual nests plus 6 multi-species sites) were 

located on non-federal lands within the tract’s 2-mile wildlife survey area 

through 2007. The 40 nests were in at least 16 different territories. Only 23 of 

the 40 sites still had nest material present in 2007. 

Existing Conditions − North Porcupine LBA Tract

Annual monitoring has documented that ferruginous hawks nested in the 

vicinity of the North Antelope Rochelle Mine every year since at least 1990, and 

fledged young in 17 of those 19 years. Similar long-term nesting has occurred 

at the neighboring Black Thunder and Antelope mines. Ferruginous hawks 

have nested on USFS lands in the North Porcupine tract’s general analysis 

area. Details describing the number of intact and active nests within the mine 

monitoring survey areas in a given year are available in annual monitoring and 

baseline wildlife reports on file at the USFS Douglas Ranger District Office in 

Douglas and/or with WDEQ/LQD in Cheyenne. 

The presence or absence of nest material does not determine whether the USFS 

considers a site as “active” (occupied during at least 1 of the last 7 years). In 

2007, 73 individual ferruginous hawk nests (21 territories) were present within 

the North Porcupine tract wildlife survey area, plus 14 other nest sites that 

have been used by ferruginous hawks and at least one other raptor species 

over the years (Figure H-4). 

Four nest sites were on USFS surface within the general analysis area itself in 

2007, three of which still had nest material present. Three additional 

individual ferruginous hawk nest sites and two multi-species nests were on 

non-federal lands within the general analysis area in 2007. 

Existing Conditions − South Porcupine LBA Tract

Annual monitoring has documented that ferruginous hawks nested in the 

vicinity of the North Antelope Rochelle Mine every year since at least 1990, and 

fledged young in 17 of those 19 years. Similar long-term nesting has occurred 

at the neighboring Black Thunder and Antelope mines. Ferruginous hawks 

have nested on USFS lands in the South Porcupine tract’s general analysis 

area. Details describing the number of intact and active nests within the mine 

monitoring survey areas in a given year are available in annual monitoring and 

baseline wildlife reports on file at the USFS Douglas Ranger District Office in 

Douglas and/or with WDEQ/LQD in Cheyenne. 

The presence or absence of nest material does not determine whether the USFS 

considers a site as “active” (occupied during at least 1 of the last 7 years). In 

2007, 33 individual ferruginous hawk nests (11 territories) were present within 

the South Porcupine wildlife survey area, plus 5 other nest sites that have been 

used by ferruginous hawks and at least one other raptor species over the years 

(Figure H-5). 
Appendix H 

H-70 Final EIS, Wright Area Coal Lease Applications 

Five individual ferruginous hawk nest sites were on USFS lands within the 

general analysis area itself in 2007, one of which still had nest material 

present. Five additional individual nest sites were on non-federal lands in that 

area in 2007. 

Direct and Indirect Effects

Over time, the Black Thunder Mine has avoided, where possible, or mitigated 

mining impacts on raptor nests through a variety of means. The mine has 

voluntarily monitored nesting raptor populations in a perimeter larger than 

required annually since 1983, maintained and implemented current USFWS 

approved Raptor Mitigation Plans, adjusted operations to provide temporal and 

spatial buffers around raptor nests, and ensured that new power lines at the 

mine conform to current Avian Power Line Interaction Commission (APLIC) 

guidelines. 

As indicated previously, only a few acres in the North and South Porcupine 

tracts’ general analysis areas are not already encompassed by the existing 

North Antelope Rochelle Mine’s existing permit area. Surface disturbance is 

therefore likely to occur in those areas, regardless of the proposed leasing 

decision. However, the North Antelope Rochelle Mine has avoided, where 

possible, or mitigated mining impacts on raptor nests through a variety of 

means. The mine has also maintained and implemented current USFWS 

approved Raptor Mitigation Plans, adjusted operations to provide temporal and 

spatial buffers around raptor nests, and ensured that new power lines at the 

mine conform to current Avian Power Line Interaction Commission (APLIC) 

guidelines. 

Provided those practices are continued, direct impacts on ferruginous hawks 

and their active nest sites will be minimized, both on and near USFS lands. 

Due to restrictions on disturbance near active nest sites, the most probable 

source of potential impact to ferruginous hawks themselves would be an 

increase in injuries and fatalities of individuals foraging within the WAC LBA 

tracts’ general analysis areas due to vehicle collisions associated with ongoing 

or future mining and other activities. The use of existing roads in the area, 

when possible, would help to minimize this risk. 

Habitat loss, degradation, and fragmentation would result from a variety of 

large- and small-scale mining operations such as soil salvaging and 

reservoir/flood construction, among others. Potential nesting and foraging 

habitat might also be fragmented by linear disturbances such as the 

construction, maintenance, and removal of roads, fences, power lines, and 

pipelines. Those disturbances could also create new travel corridors for 

mammalian predators that reside in or pass through the area. However, many 

such disturbances would occur within narrow corridors over relatively short 

distances, typically over a period of days. Additionally, those structures are 

often constructed immediately prior to the removal of similar features 

elsewhere in the area, often resulting in minimal or no net gain of new linear 

disturbances. All mine-related habitat disturbances would shift throughout 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-71 

the expanded permit area as operations progress. Reclamation of disturbed 

areas would occur incrementally as resource recovery is completed in a given 

portion of the mine, and would mitigate impacts to some degree. Surface 

disturbing activities could also result in a short-term, localized decrease in the 

prey base (lagomorphs and rodents) for ferruginous hawks. However, due to 

their high reproductive potential and tendencies to re-populate and adapt to 

disturbed and reclaimed areas, prey numbers should increase quickly after the 

disturbance. 

USFS Standards and Guidelines would be implemented and offer additional 

protections for active nests; they would apply only to activities outside of the 

lease area. These protocols should help ensure that the Proposed Action and 

Alternatives do not significantly degrade the quality of existing ferruginous 

hawk territories and nest sites. Standards and Guidelines specific to 

ferruginous hawks outlined in the TBNG Plan (USFS 2002, page 1-20-21) are 

as follows: 

73. To help prevent abandonment, reproductive failure or nest 

destruction, prohibit development of new facilities within 0.25 mile 

(or line of sight) of active ferruginous hawk nests. For the 

ferruginous hawk, a nest is no longer considered active if it is 

known to have been unoccupied for the last seven years. This does 

not apply to pipelines, fences and underground utilities. 

74. To help reduce disturbances to nesting ferruginous hawks, prohibit 

the following activities within 0.5 mile (or line of sight) of active 

ferruginous hawk nests from 1 March through 31 July: 

construction (e.g., roads, water impoundments, oil and gas 

facilities), reclamation, gravel mining operations, drilling of water 

wells, and oil and gas drilling. 

75. To help reduce disturbances to nesting ferruginous hawks, do not 

authorize the following activities within 0.5 mile (line of sight) of 

active ferruginous hawk nests from 1 March through 31 July: 

construction (e.g., pipelines, utilities, fencing), seismic exploration, 

and workover operations for maintenance of oil and gas wells. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract may 

impact individuals but is not likely to cause a trend to federal listing or loss of 

viability within the planning area. 

Mine-related activities will not physically disturb any ferruginous hawk nest 

sites on USFS lands in the North Hilight Field tract’s general analysis area. All 

ferruginous hawk nests located within the South Hilight Field tract’s general 

analysis area are located on federal surface. Most ferruginous hawk nests 

located within the West Hilight Field tract’s general analysis area are located on 

non-federal surface. Mine-related activities will likely disturb ferruginous hawk 
Appendix H 

H-72 Final EIS, Wright Area Coal Lease Applications 

nest sites on USFS lands in the North Porcupine tract’s wildlife survey area. 

Mine-related activities will likely disturb ferruginous hawk nest sites on USFS 

lands in the South Porcupine tract’s wildlife survey area. Some individuals or 

pairs may experience disturbance, destruction, or fragmentation of nesting and 

foraging habitat. However, ferruginous hawks typically have alternate nest 

sites within the same territories, and therefore many alternative nests occur 

beyond the tracts’ general analysis areas and thus are less likely to be 

impacted by future mining disturbance associated with the proposed leasing 

actions. 

Increased disturbance to individuals due to human activity may also occur. 

However, several factors should minimize the potential mining-related impacts 

on this species, including the availability of alternate nest sites located further 

away from pending disturbance in each affected territory, implementation of 

USFWS and USFS approved mitigation measures, reclaiming habitats as soon 

as feasible, encouraging nesting within mine reclamation lands through 

artificial nest structures and habitat features such as rock piles and tree 

plantings that attract prey species, and continued monitoring of this species to 

ensure that mitigation methods are applied when necessary. 

H-3.2.23 Burrowing owl (Athene cunicularia)

Burrowing owls breed from southern Alberta to southwestern Saskatchewan, 

south through east-central Washington, central Oregon, and southern 

California, and east to eastern North Dakota, west-central Kansas, and Texas 

(Klute et al. 2003, pg 7). The burrowing owl is a summer resident of open 

rangeland habitats throughout Wyoming (Cerovski et al. 2004). This species 

requires burrows of fossorial mammals, primarily badgers and prairie dogs, for 

nesting and roosting (Klute et al. 2003, pg 12).

Most burrowing owl nests within the TBNG are located within prairie dog 

colonies (USFS 2003). Burrowing owls typically reuse traditional nesting areas. 

Burrow mounds, shrubs, fence posts or boulders may be used as observation 

perches. This species is usually tolerant of human activity but is vulnerable to 

predation by pets (cats, dogs). Burrowing owls forage within a variety of 

habitats, including cropland, pasture, prairie dog colonies, fallow fields, and 

sparsely vegetated areas. This species is often active during daylight hours. 

Insects and small mammals (mice and voles) are the owls’ primary prey items. 

Burrowing owl populations have been declining throughout its range, primarily 

due to habitat loss. 

Existing Conditions − North, South and West Hilight Field LBA Tracts

Burrowing owls are common summer residents within the TBNG (Cerovski et 

al. 2004). This species was first recorded nesting in the Black Thunder Mine 

annual monitoring 2-mile perimeter in 1988. Despite the presence of potential 

nesting habitat (prairie dog and badger burrows) in the monitoring area, this 

species nested in only 5 of the subsequent 19 years. All known burrowing owl 

nest sites in the mine monitoring area have been in prairie dog burrows. Four 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-73 

artificial nest boxes have been constructed in the mine’s 2-mile perimeter 

wildlife survey area for mitigation purposes over the years, but no owls have 

ever been observed at or near them. 

No burrowing owl nest sites have been documented on USFS lands within the 

North Hilight Field tract’s general analysis area or the tract’s surrounding 

wildlife survey area through 2007. Two nest sites in one territory have been 

identified in a small (18 acres) prairie dog colony on non-federal lands located 

within the tract’s general analysis area (Figure H-1). The colony is 

approximately 4 miles west of the nearest USFS lands within the tract’s general 

analysis area, and 3 miles northwest of the nearest USFS lands in the 

surrounding 2-mile perimeter. The USFS buffer for this species is 0.25 mile. 

A smaller (3 acres) colony is also present in the general analysis area, but no 

burrowing owls have been recorded there. One artificial nest box (BO5) was 

created in the LBA tract’s 2-mile wildlife survey area, but it has never been 

used by burrowing owls. 

No burrowing owl nest sites had been documented within the entire South 

Hilight Field tract’s general analysis area or the tract’s surrounding wildlife 

survey area through 2007, including all USFS lands in that area. Only one 

small (less than 1 acre) prairie dog colony (potential burrowing owl nesting 

habitat) is present within the tract’s general analysis area, though larger 

colonies do occur in the surrounding 2-mile wildlife survey area (Figure H-2). 

Badger burrows undoubtedly occur in the area, but are not typically recorded. 

No burrowing owl nest sites had been documented within the general analysis 

area for the West Hilight Field LBA Tract through 2007, including USFS lands 

within that area. One burrowing owl nest site has been recorded on nonfederal lands in the northwestern corner of the general analysis area and 

approximately 0.25 mile from the nearest USFS lands (Figure H-3). The 

disturbance-free buffer for active nests of this species is 0.25 mile. This nest 

site was active in 2007, but no young fledged. Two additional burrowing owl 

nest sites (one territory) have been documented in the northeastern portion of 

the two-mile wildlife survey area. Those nests are located within the North 

Hilight Field LBA Tract as applied for (refer to Section H-3.3.23). Potential 

nesting habitat for burrowing owls is present in a prairie dog colony 

(approximately 89 acres in size) within the West Hilight Field tract’s general 

analysis area, which is located on USFS lands. Another prairie dog colony 

(about 7 acres in size) is located about 0.25 mile east of the West Hilight Field 

tract’s general analysis area (Figure H-3), and in any badger burrows that 

might be present in the area would also provide potential nesting habitat for 

burrowing owls. 

Existing Conditions − North and South Porcupine LBA Tracts

Burrowing owls are common summer residents within the TBNG (Cerovski et 

al. 2004). This species was observed nested in the North Antelope Rochelle 

Mine’s monitoring area in 1985 and 1989. Despite the presence of potential 
Appendix H 

H-74 Final EIS, Wright Area Coal Lease Applications 

nesting habitat (prairie dog and badger burrows) in the monitoring area, 

nesting owls were not found again until 1997. Burrowing owls have nested in 

the mine’s monitoring area in most years since then, especially within a prairie 

dog colony located in T.41N., R.70W., Section 17, just east of the southeastern 

corner of the South Porcupine LBA Tract (Figure H-5). 

One burrowing owl nest site has been identified in a small (19 acres in size) 

prairie dog colony within the North Porcupine tract’s general analysis area. 

This colony and nest site are located immediately adjacent to USFS lands 

(Figure H-4). The USFS buffer for this species is 0.25 mile. No burrowing owl 

nest sites have been documented on USFS lands within the North Porcupine 

tract’s general analysis area. A total of seven nest sites have been recorded on 

USFS lands in the surrounding wildlife survey area through 2007; one of which 

is in a prairie dog colony located approximately 0.25 mile east of the general 

analysis area, in T.42N., R.70W., Section 25. 

No burrowing owl nest sites had been documented within the South Porcupine 

tract’s general analysis area through 2007, including USFS lands in that area. 

Eleven nest sites have been recorded in the surrounding 2-mile wildlife survey 

area: one on USFS lands and 10 on non-federal surface. Seven of those 11 

nest sites were in a single prairie dog colony located approximately 0.4 mile 

east of the southeastern corner of this general analysis area in T.41N., R.70W., 

Section 17 (Figure H-5). 

Direct and Indirect Effects − North Hilight Field LBA Tract

No known burrowing owl nest sites are present on USFS lands in the general 

analysis area for the North Hilight Field LBA Tract, or within 0.25 mile of those 

lands (the USFS buffer for that species). Potential nesting habitat in the 

vicinity of this LBA tract is largely limited to the two relatively small prairie dog 

colonies located in the tract’s general analysis area. Therefore, leasing the 

North Hilight Field LBA Tract would not result in any direct or indirect effects 

to nesting burrowing owls. Both USFS Standards and Guidelines (USFS 2002) 

and Black Thunder Mine’s mine permit (TBCC 2005) stipulate that clearance 

surveys will be conducted and approved by the appropriate agencies before any 

colony is disturbed during the breeding season. That process will preclude 

most direct impacts to new nesting burrowing owls in that area. 

Due to the strong (but not exclusive) relationship between burrowing owls and 

prairie dog colonies, many of the indirect effects described above for the blacktailed prairie dog, would also apply to burrowing owls and, thus, will not be 

repeated in full detail here. Because burrowing owls are active during daylight 

hours, the most probable source of direct impacts would be the death of, or 

injury to, individuals fleeing heavy equipment, or being killed or injured by 

equipment while feeding or moving through the mine area. Burrowing owls are 

generally tolerant of human activities, but increased presence and noise, 

especially during the nest initiation period, may displace individuals or inhibit 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-75 

nesting proximate to mine operations. Foraging could also be hindered within 

these areas, especially where mining activities occur near prairie dog colonies. 

As described previously, mining could eventually disturb or eliminate prairie 

dog colonies (potential nesting habitat) in the general analysis area for the 

North Hilight Field LBA Tract (21 total acres). However, the limited presence or 

long-term absence of nesting burrowing owls in those colonies, in combination 

with the presence of other non-disturbed colonies in the area and the ability for 

prairie dogs to recolonize reclamation, would mitigate those losses to a large 

extent. Surface disturbing activities could also result in a short-term, localized 

decrease in the prey base (rodents, non-flying insects) for burrowing owls. 

However, due to their high reproductive potential and tendencies to re-populate 

and adapt to disturbed and reclaimed areas, prey numbers should increase 

quickly after the disturbance. 

Additionally, the tendency of prairie dogs to quickly colonize nearby areas when 

their colonies are disturbed would create new nesting habitat for burrowing 

owls. Overall, nesting and foraging habitats will be incrementally affected by a 

variety of large-and small-scale operations. The type, timing, location, and 

extent of habitat disturbance will vary throughout the general analysis area as 

mining operations progress, thus providing opportunities for burrowing owls to 

relocate to other suitable habitat within the immediate area. 

Reclamation will proceed incrementally as areas are mined and activities move 

to new locations within the mine area. Both activities will create loose soil that 

should be attractive to dispersing prairie dogs (potential habitat source), at 

least in the short term. Reclamation of disturbed areas will occur 

incrementally as resources are extracted in a given portion of the mine, and 

will eventually mitigate habitat impacts to some degree. However, to date, 

burrowing owls have rarely been documented nesting within reclaimed habitats 

at surface mines in the PRB of northeast Wyoming. 

If nesting burrowing owls are documented on or near USFS lands in the North 

Hilight Field LBA Tract, USFS Standards and Guidelines applicable to this 

species would be implemented on applicable lands to offer additional 

protections beyond those outlined in the USFWS approved Raptor Mitigation 

Plan for the Black Thunder Mine. Annual monitoring of known burrowing owl 

nest sites within the 2-mile wildlife survey area for the mine, including USFS 

and adjacent lands, and other nearby colonies will continue through the life of 

the mine to document their histories of occupancy and production. 

Direct and Indirect Effects − South Hilight Field LBA Tract

No known burrowing owl nest sites are present on USFS lands in the general 

analysis area for the South Hilight Field LBA Tract, or within 0.25 mile of those 

lands (the USFS buffer for that species). Potential nesting habitat is largely 

limited to a lone, very small prairie dog colony in the tract’s general analysis 

area. Therefore, leasing the South Hilight Field LBA Tract would not result in 

any direct or indirect effects to nesting burrowing owls. Both USFS Standards 
Appendix H 

H-76 Final EIS, Wright Area Coal Lease Applications 

and Guidelines (USFS 2002) and the Black Thunder Mine’s mine permit (TBCC 

2005) stipulate that clearance surveys will be conducted and approved by the 

appropriate agencies before any colony is disturbed during the breeding 

season. That process will preclude most direct impacts to new nesting 

burrowing owls in that area. 

Because burrowing owls are active during daylight hours, the most probable 

source of direct impacts would be the death of, or injury to, individuals fleeing 

heavy equipment, or being killed or injured by equipment while feeding or 

moving through the mine area. Burrowing owls are generally tolerant of 

human activities, but increased presence and noise, especially during the nest 

initiation period, may displace individuals or inhibit nesting proximate to mine 

operations. Foraging could also be hindered within these areas, especially 

where mining activities occur near prairie dog colonies. 

As described previously, mining could eventually disturb or eliminate prairie 

dog colonies (potential nesting habitat) in the general analysis area for the 

South Hilight Field LBA Tract (1 acre). However, the limited presence or longterm absence of nesting burrowing owls in that colony, in combination with the 

presence of other non-disturbed colonies in the area and the ability for prairie 

dogs to recolonize reclamation, would mitigate those losses to a large extent. 

Surface disturbing activities could also result in a short-term, localized 

decrease in the prey base (rodents, non-flying insects) for burrowing owls. 

However, due to their high reproductive potential and tendencies to re-populate 

and adapt to disturbed and reclaimed areas, prey numbers should increase 

quickly after the disturbance. 

Additionally, the tendency of prairie dogs to quickly colonize nearby areas when 

their colonies are disturbed would create new nesting habitat for burrowing 

owls. Overall, nesting and foraging habitats will be incrementally affected by a 

variety of large-and small-scale operations. The type, timing, location, and 

extent of habitat disturbance will vary throughout the general analysis area as 

mining operations progress, thus providing opportunities for burrowing owls to 

relocate to other suitable habitat within the immediate area. 

Reclamation will proceed incrementally as areas are mined and activities move 

to new locations within the mine area. Both activities will create loose soil that 

should be attractive to dispersing prairie dogs (potential habitat source), at 

least in the short term. Reclamation of disturbed areas will occur 

incrementally as resources are extracted in a given portion of the mine, and 

will eventually mitigate habitat impacts to some degree. However, to date, 

burrowing owls have rarely been documented nesting within reclaimed habitats 

at surface mines in the PRB of northeast Wyoming. 

If nesting burrowing owls are documented on or near USFS lands in the South 

Hilight Field LBA Tract, USFS Standards and Guidelines applicable to this 

species would be implemented on applicable lands to offer additional 

protections beyond those outlined in the USFWS approved Raptor Mitigation 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-77 

Plan for the Black Thunder Mine. Annual monitoring of known burrowing owl 

nest sites within the 2-mile wildlife survey area for the mine, including USFS 

and adjacent lands, and other nearby colonies will continue through the life of 

the mine to document their histories of occupancy and production. 

Direct and Indirect Effects − West Hilight Field LBA Tract

No known burrowing owl nest sites are present on USFS lands in the general 

analysis area for the West Hilight Field LBA Tract. One existing nest site is 

approximately 0.25 mile of those lands (the USFS buffer for that species is 0.25 

mile). Potential nesting habitat in the vicinity of this LBA tract is largely 

limited to the large prairie dog colony located along Little Thunder Creek within 

the tract’s general analysis area. Therefore, leasing the West Hilight Field LBA 

Tract would not result in any direct or indirect effects to nesting burrowing 

owls. Both USFS Standards and Guidelines (USFS 2002) and the Black 

Thunder Mine’s mine permit (TBCC 2005) stipulate that clearance surveys will 

be conducted and approved by the appropriate agencies before any colony is 

disturbed during the breeding season. That process will preclude most direct 

impacts to new nesting burrowing owls in that area. 

Because burrowing owls are active during daylight hours, the most probable 

source of direct impacts would be the death of, or injury to, individuals fleeing 

heavy equipment, or being killed or injured by equipment while feeding or 

moving through the mine area. Burrowing owls are generally tolerant of 

human activities, but increased presence and noise, especially during the nest 

initiation period, may displace individuals or inhibit nesting proximate to mine 

operations. Foraging could also be hindered within these areas, especially 

where mining activities occur near prairie dog colonies. 

As described previously, mining could eventually disturb or eliminate prairie 

dog colonies (potential nesting habitat) on USFS lands in the West Hilight Field 

tract’s general analysis area (approximately 89 acres). However, the limited 

presence or long-term absence of nesting burrowing owls in that colony, in 

combination with the presence of other non-disturbed colonies in the area and 

the ability for prairie dogs to recolonize reclamation, would mitigate those 

losses to a large extent. Surface disturbing activities could also result in a 

short-term, localized decrease in the prey base (rodents, non-flying insects) for 

burrowing owls. However, due to their high reproductive potential and 

tendencies to re-populate and adapt to disturbed and reclaimed areas, prey 

numbers should increase quickly after the disturbance. 

Additionally, the tendency of prairie dogs to quickly colonize nearby areas when 

their colonies are disturbed would create new nesting habitat for burrowing 

owls. Overall, nesting and foraging habitats will be incrementally affected by a 

variety of large-and small-scale operations. The type, timing, location, and 

extent of habitat disturbance will vary throughout the general analysis area as 

mining operations progress, thus providing opportunities for burrowing owls to 

relocate to other suitable habitat within the immediate area. 
Appendix H 

H-78 Final EIS, Wright Area Coal Lease Applications 

Reclamation will proceed incrementally as areas are mined and activities move 

to new locations within the mine area. Both activities will create loose soil that 

should be attractive to dispersing prairie dogs (potential habitat source), at 

least in the short term. Reclamation of disturbed areas will occur 

incrementally as resources are extracted in a given portion of the mine, and 

will eventually mitigate habitat impacts to some degree. However, to date, 

burrowing owls have rarely been documented nesting within reclaimed habitats 

at surface mines in the PRB of northeast Wyoming. 

If nesting burrowing owls are documented on or near USFS lands in the West 

Hilight Field LBA Tract, USFS Standards and Guidelines applicable to this 

species would be implemented on applicable lands to offer additional 

protections beyond those outlined in the USFWS approved Raptor Mitigation 

Plan for the Black Thunder Mine. Annual monitoring of known burrowing owl 

nest sites within the 2-mile wildlife survey area for the mine, including USFS 

and adjacent lands, and other nearby colonies will continue through the life of 

the mine to document their histories of occupancy and production. 

Direct and Indirect Effects − North Porcupine LBA Tract

No known burrowing owl nest sites are present on USFS lands in the general 

analysis area for the North Porcupine LBA Tract. However, leasing the North 

Porcupine LBA Tract could result in direct or indirect effects on two nest sites 

located within 0.25 mile of USFS lands in that tract; one of which is within the 

tract’s general analysis area itself, while the other is located immediately east 

of the tract’s general analysis area (Figure H-4). That distance represents the 

USFS buffer for this species. Most nesting has occurred in prairie dog colonies 

in or near the tract’s general analysis area, though badger burrows have also 

been used. Both USFS Standards and Guidelines (USFS 2002) and the North 

Antelope Rochelle Mine’s mine permit (PRC 2004) stipulate that clearance 

surveys will be conducted and approved by the appropriate agencies before any 

colony is disturbed during the breeding season. That process will preclude 

most direct impacts to new nesting burrowing owls in that area. 

Due to the strong (but not exclusive) relationship between burrowing owls and 

prairie dog colonies, many of the indirect effects described above for the blacktailed prairie dog would also apply to burrowing owls and, thus, will not be 

repeated in full detail here. Because burrowing owls are active during daylight 

hours, the most probable source of direct impacts would be the death of, or 

injury to, individuals fleeing heavy equipment, or being killed or injured by 

equipment while feeding or moving through the mine area. Burrowing owls are 

generally tolerant of human activities, but increased presence and noise, 

especially during the nest initiation period, may displace individuals or inhibit 

nesting proximate to mine operations. Foraging could also be hindered within 

these areas, especially where mining activities occur near prairie dog colonies. 

As described previously, only one prairie dog colony (approximately 18.6 acres 

in size) is present on non-federal lands in the North Porcupine tract general 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-79 

analysis area. Prairie dog colonies located within the existing North Antelope 

Rochelle Mine permit area could be impacted by mining operations regardless 

of whether the North Porcupine LBA Tract is leased. If the North Porcupine 

tract is leased, mining could eventually disturb or eliminate the prairie dog 

colony (potential nesting habitat) in the tract’s general analysis area. Mining 

could eventually disturb or eliminate prairie dog colonies on adjacent lands in 

or within 0.25 mile of the North Porcupine tract’s general analysis area. 

However, the generally limited presence of active burrowing owl nests, in 

combination with the presence of other non-disturbed colonies in the general 

vicinity and the ability for prairie dogs to recolonize reclamation, would 

mitigate those losses to a large extent. Surface disturbing activities could also 

result in a short-term, localized decrease in the prey base (rodents, non-flying 

insects) for burrowing owls. However, due to their high reproductive potential 

and tendencies to re-populate and adapt to disturbed and reclaimed areas, 

prey numbers should increase quickly after the disturbance. 

Additionally, the tendency of prairie dogs to quickly colonize nearby areas when 

their colonies are disturbed would create new nesting habitat for burrowing 

owls. Overall, nesting and foraging habitats will be incrementally affected by a 

variety of large-and small-scale operations. The type, timing, location, and 

extent of habitat disturbance will vary throughout the general analysis area as 

mining operations progress, thus providing opportunities for burrowing owls to 

relocate to other suitable habitat within the immediate area. 

Reclamation will proceed incrementally as areas are mined and activities move 

to new locations within the mine area. Both activities will create loose soil that 

should be attractive to dispersing prairie dogs (potential habitat source), at 

least in the short term. Reclamation of disturbed areas will occur 

incrementally as resources are extracted in a given portion of the mine, and 

will eventually mitigate habitat impacts to some degree. However, to date, 

burrowing owls have rarely been documented nesting within reclaimed habitats 

at surface mines in the PRB of northeast Wyoming. 

If nesting burrowing owls are documented on or near USFS lands in the North 

Porcupine LBA Tract, USFS Standards and Guidelines applicable to this 

species would be implemented on applicable lands to offer additional 

protections beyond those outlined in the USFWS approved Raptor Mitigation 

Plan for the North Antelope Rochelle Mine. Annual monitoring of known 

burrowing owl nest sites within the 2-mile wildlife survey area for the mine, 

including USFS and adjacent lands, and other nearby colonies will continue 

through the life of the mine to document their histories of occupancy and 

production. 

Direct and Indirect Effects − South Porcupine LBA Tract

No known burrowing owl nest sites are present on USFS lands in the general 

analysis area for the South Porcupine LBA Tract. Most nesting has occurred in 

prairie dog colonies near each general analysis area, though badger burrows 
Appendix H 

H-80 Final EIS, Wright Area Coal Lease Applications 

have also been used. Both USFS Standards and Guidelines (USFS 2002) and 

the North Antelope Rochelle Mine’s mine permit (PRC 2004) stipulate that 

clearance surveys will be conducted and approved by the appropriate agencies 

before any colony is disturbed during the breeding season. That process will 

preclude most direct impacts to new nesting burrowing owls in that area. 

Due to the strong (but not exclusive) relationship between burrowing owls and 

prairie dog colonies, many of the indirect effects described above for the blacktailed prairie dog would also apply to burrowing owls and, thus, will not be 

repeated in full detail here. Because burrowing owls are active during daylight 

hours, the most probable source of direct impacts would be the death of, or 

injury to, individuals fleeing heavy equipment, or being killed or injured by 

equipment while feeding or moving through the mine area. Burrowing owls are 

generally tolerant of human activities, but increased presence and noise, 

especially during the nest initiation period, may displace individuals or inhibit 

nesting proximate to mine operations. Foraging could also be hindered within 

these areas, especially where mining activities occur near prairie dog colonies. 

As described previously, no prairie dog colonies (potential burrowing owl 

nesting habitat) are present in the general analysis area for the South 

Porcupine LBA Tract. Two colonies are however located within approximately 

0.25 mile of the South Porcupine tract’s general analysis area, both of which 

are within North Antelope Rochelle Mine’s existing permit area, and mining 

could eventually disturb or eliminate those colonies regardless of whether the 

South Porcupine LBA Tract is leased. However, the generally limited presence 

of active nests, in combination with the presence of other non-disturbed 

colonies in the area and the ability for prairie dogs to recolonize reclamation, 

would mitigate those losses to a large extent. Surface disturbing activities 

could also result in a short-term, localized decrease in the prey base (rodents, 

non-flying insects) for burrowing owls. However, due to their high reproductive 

potential and tendencies to re-populate and adapt to disturbed and reclaimed 

areas, prey numbers should increase quickly after the disturbance. 

Additionally, the tendency of prairie dogs to quickly colonize nearby areas when 

their colonies are disturbed would create new nesting habitat for burrowing 

owls. Overall, nesting and foraging habitats will be incrementally affected by a 

variety of large-and small-scale operations. The type, timing, location, and 

extent of habitat disturbance will vary throughout the general analysis area as 

mining operations progress, thus providing opportunities for burrowing owls to 

relocate to other suitable habitat within the immediate area. 

Reclamation will proceed incrementally as areas are mined and activities move 

to new locations within the mine area. Both activities will create loose soil that 

should be attractive to dispersing prairie dogs (potential habitat source), at 

least in the short term. Reclamation of disturbed areas will occur 

incrementally as resources are extracted in a given portion of the mine, and 

will eventually mitigate habitat impacts to some degree. However, to date, 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-81 

burrowing owls have rarely been documented nesting within reclaimed habitats 

at surface mines in the PRB of northeast Wyoming. 

If nesting burrowing owls are documented on or near USFS lands in the South 

Porcupine LBA Tract, USFS Standards and Guidelines applicable to this 

species would be implemented on applicable lands to offer additional 

protections beyond those outlined in the USFWS approved Raptor Mitigation 

Plan for the North Antelope Rochelle Mine. Annual monitoring of known 

burrowing owl nest sites within the 2-mile wildlife survey area for the mine, 

including USFS and adjacent lands, and other nearby colonies will continue 

through the life of the mine to document their histories of occupancy and 

production. 

Determination of Effect and Rationale − North Hilight Field LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. No burrowing owl nests have been documented on or near 

USFS lands in the North Hilight Field tract’s general analysis area during many 

years of annual monitoring; only two nests in a single territory are located 

within the tract’s general analysis area. Disturbance, fragmentation, and 

alteration of foraging and nesting habitats would occur if this tract is leased 

and mined. However, few prairie dog colonies occur in the general vicinity of 

this LBA tract, and most are located outside of the tract’s general analysis area 

where future surface disturbance would occur. 

The Black Thunder Mine has avoided, where possible, and mitigated such 

impacts in the past through intensive monitoring of both populations and 

specific nest sites, implementation of USFWS approved mitigation measures, 

and adjusting operations to provide temporal and spatial buffers around raptor 

nests (including burrowing owl nests). Mining activities and noise may disturb 

individuals inhabiting the lease area, thus inhibiting potential nesting or 

foraging in proximity to lands with ongoing development. Potential collisions 

with vehicles might also occur, though none have been recorded in the area to 

date. 

Determination of Effect and Rationale − South Hilight Field LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. No burrowing owl nests have been documented on or near 

USFS lands in the South Hilight Field tract’s general analysis area during 

many years of annual monitoring, nor have any nests been located within the 

tract’s general analysis area itself. Few prairie dog colonies occur in the 

general vicinity of this LBA tract, and most are located outside of the tract’s 

general analysis area where future surface disturbance would occur. 

The Black Thunder Mine has avoided, where possible, and mitigated such 

impacts in the past through intensive monitoring of both populations and 
Appendix H 

H-82 Final EIS, Wright Area Coal Lease Applications 

specific nest sites, implementation of USFWS approved mitigation measures, 

and adjusting operations to provide temporal and spatial buffers around raptor 

nests (including burrowing owl nests). Mining activities and noise may disturb 

individuals inhabiting the lease area, thus inhibiting potential nesting or 

foraging in proximity to lands with ongoing development. Potential collisions 

with vehicles might also occur, though none have been recorded in the area to 

date. 

Determination of Effect and Rationale − West Hilight Field LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. No burrowing owl nests have been documented on USFS lands 

in the West Hilight Field tract’s general analysis area during many years of 

annual monitoring, and only a single nest site is located approximately 0.25 

mile from the nearest USFS lands in the tract’s general analysis area. 

Disturbance, fragmentation, and alteration of foraging and nesting habitats 

would occur if this tract is leased and mined. However, excluding the single 

large colony that is located in the tract’s general analysis area, few prairie dog 

colonies occur in the general vicinity of this LBA tract, and most are located 

outside of the tract’s general analysis area. 

The Black Thunder Mine has avoided, where possible, and mitigated such 

impacts in the past through intensive monitoring of both populations and 

specific nest sites, implementation of USFWS approved mitigation measures, 

and adjusting operations to provide temporal and spatial buffers around raptor 

nests (including burrowing owl nests). Mining activities and noise may disturb 

individuals inhabiting the lease area, thus inhibiting potential nesting or 

foraging in proximity to lands with ongoing development. Potential collisions 

with vehicles might also occur, though none have been recorded in the area to 

date. 

Determination of Effect and Rationale − North Porcupine LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. No burrowing owl nests have been documented on USFS lands 

in the North Porcupine tract’s general analysis area during many years of 

annual monitoring. A single nest site is located in the only prairie dog colony 

that is within the tract’s general analysis area, and that nest site is 

immediately adjacent to USFS lands. Disturbance, fragmentation, and 

alteration of foraging and nesting habitats would occur if this tract is leased 

and mined. However, most of the prairie dog colonies in the general vicinity are 

located outside of the tract’s general analysis area where future surface 

disturbance associated with this leasing action would occur. 

The North Antelope Rochelle Mine has avoided, where possible, and mitigated 

such impacts in the past through intensive monitoring of both populations and 

specific nest sites, implementation of USFWS approved mitigation measures, 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-83 

and adjusting operations to provide temporal and spatial buffers around raptor 

nests (including burrowing owl nests). Mining activities and noise may disturb 

individuals inhabiting the lease area, thus inhibiting potential nesting or 

foraging in proximity to lands with ongoing development. Potential collisions 

with vehicles might also occur, though none have been recorded in the area to 

date. 

Determination of Effect and Rationale − South Porcupine LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. No burrowing owl nests have been documented on or within 

0.25 mile of USFS lands in the general analysis area for the South Porcupine 

LBA Tract during many years of annual monitoring. Most prairie dog colonies 

in the general vicinity are located outside of the tract’s general analysis area 

where future surface disturbance associated with this leasing action would 

occur. 

The North Antelope Rochelle Mine has avoided, where possible, and mitigated 

impacts in the past through intensive monitoring of both populations and 

specific nest sites, implementation of USFWS approved mitigation measures, 

and adjusting operations to provide temporal and spatial buffers around raptor 

nests (including burrowing owl nests). Mining activities and noise may disturb 

individuals inhabiting the lease area, thus inhibiting potential nesting or 

foraging in proximity to lands with ongoing development. Potential collisions 

with vehicles might also occur, though none have been recorded in the area to 

date. 

H-3.2.24 Chestnut-collared longspur (Calcarius ornatus)

The breeding range of the chestnut-collared longspur extends from southern 

Alberta to southern Manitoba, south to west-central Colorado, and east 

through North Dakota and South Dakota to western Minnesota (Dechant et al. 

2003b). The chestnut-collared longspur is a common summer resident of the 

eastern plains of Wyoming (Cerovski et al. 2004). This species prefers native 

grasslands as breeding sites, inhabiting open prairie and avoiding excessively 

shrubby areas. Grasslands with dense litter accumulations are also avoided 

(Dechant et al. 2003b). Scattered shrubs are often used as singing perches. 

Nests are typically placed in areas of sparse vegetation (less than 50-75 inches 

or 20-30 centimeters), but usually with a taller grass component than sites 

preferred by McCown’s longspurs. Nests are on the ground in depressions and 

often placed beside cattle dung, small shrubs, or under a clump of grass (Hill 

and Gould 1997). Male fidelity to breeding areas has been observed. 

Chestnut-collared longspurs feed primarily on seeds (especially grasses), 

insects, and spiders. This species is generally tolerant of short-term intrusion 

at the nest site but may desert if disturbed during nest building or egg-laying 

(Hill and Gould 1997). High rates of predation on eggs and nestlings have been 

reported and pesticides have been shown to reduce hatching success. The 

chestnut-collared longspur breeding range has contracted and long-term data 
Appendix H 

H-84 Final EIS, Wright Area Coal Lease Applications 

suggests population declines (Hill and Gould 1997). These declines have been 

attributed to loss of native prairie habitat, and conversion to cropland and 

urban development. 

Existing Conditions − North, South and West Hilight Field LBA Tracts

Chestnut-collared longspurs are common summer residents within the TBNG. 

This species has not been recorded on USFS lands or other lands in the North 

or South Hilight Field tracts’ general analysis areas during annual monitoring 

in recent years. Individuals of this species were recorded infrequently on nonfederal lands in the West Hilight Field tract’s general analysis area during 

annual monitoring in recent years. As described previously, sagebrush 

habitats dominate USFS and adjacent lands in the general analysis areas for 

the North Hilight Field, South Hilight Field and West Hilight Field LBA Tracts. 

Grassland areas are present in the form of upland grasslands, agricultural 

pasture grasslands, and within prairie dog colonies, but they occur in isolated 

parcels scattered throughout the area rather than in contiguous and/or 

sizeable blocks that would be attractive to nesting chestnut-collared longspurs. 

Consequently, only limited suitable habitat conditions exist for this species on 

USFS lands in the North Hilight Field, South Hilight Field and West Hilight 

Field LBA Tracts’ general analysis areas and adjacent lands. 

Existing Conditions − North and South Porcupine LBA Tracts

Chestnut-collared longspurs are common summer residents within the TBNG. 

This species has not been recorded on USFS or adjacent lands in the North 

and South Porcupine tract’s general analysis area during annual monitoring 

conducted in recent years. 

The North Porcupine tract’s general analysis area is dominated by sagebrush 

communities. Potential habitat in that area is largely restricted to the western 

extent, west of the Antelope Road (Figure H-4). The South Porcupine tract’s 

general analysis area is dominated by various native and introduced grassland 

species. Therefore, the general analysis area for the South Porcupine LBA 

Tract is considered suitable habitat for this species. 

Direct and Indirect Effects

Due to the similarity of potential impacts from future mining on chestnutcollared longspurs and other grassland species previously discussed (e.g., 

prairie dog and swift fox), detailed descriptions of those impacts are not 

repeated here. Chestnut-collared longspurs have not been documented as 

nesting in the North Hilight Field, South Hilight Field, West Hilight Field, North 

Porcupine and South Porcupine tracts’ general analysis areas. Individuals of 

this species have been documented on non-federal surface in the larger South 

Porcupine 2-mile wildlife survey area (Figure H-5); which was presumed due to 

observations of breeding displays. Equipment operations associated with 

future mining operations could result in fatalities or injury to individuals, nests 

and eggs, and/or young. Increased human activity and noise could inhibit 

foraging or nesting within suitable habitats on USFS lands or displace 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-85 

individuals during periods of intense activities. Over the life of the mine, 

potential nesting and foraging habitats in the general analysis areas could be 

disturbed, destroyed, altered, or fragmented, though the type, timing, location, 

and extent of habitat disturbance will vary throughout the general analysis 

areas as mining operations progress. Reclamation of disturbed areas will occur 

incrementally as resources are extracted in a given portion of the mine. Within 

1 to 2 years, newly reclaimed areas may create good quality, short-duration 

nesting habitat for chestnut-collared longspurs. However, as these sites 

mature, they would become less suitable as nesting habitat for this species. 

Determination of Effect and Rationale − North, South and West Hilight Field 

LBA Tracts

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. USFS lands in the North Hilight Field, South Hilight Field and 

West Hilight Field tracts’ general analysis areas are dominated by sagebrush 

communities that are not as attractive to grassland species such as the 

longspur. No individuals have been documented in the general analysis areas 

for the North Hilight Field and South Hilight Field tracts, and only limited 

observations of individuals have occurred in the West Hilight Field tract’s 

general analysis area. Potential and documented alternative habitats for 

chestnut-collared longspurs are present elsewhere in the vicinity in areas not 

currently scheduled for mining disturbance. 

Determination of Effect and Rationale − North and South Porcupine LBA Tracts

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. Sagebrush dominated areas such as those on USFS and 

adjacent lands within the North Porcupine tract’s general analysis area are not 

as attractive to grassland species such as longspurs. The grasslands in the 

South Porcupine tract’s general analysis area are more likely to attract these 

birds than the sagebrush-dominated areas that typically occur in the general 

Wright analysis area. No individuals have been documented in the North and 

South Porcupine tracts’ general analysis areas or surrounding wildlife survey 

areas. Potential and documented alternative habitats for chestnut-collared 

longspurs are present elsewhere in the vicinity in areas not currently 

scheduled for mining disturbance. 

H-3.2.25 McCown’s Longspur (Calcarius mccownii)

McCown’s longspurs breed from southern Alberta and southern Saskatchewan, 

south through Montana, eastern and central Wyoming, and north-central 

Colorado, and east to western Nebraska, north-central South Dakota, and 

southwestern North Dakota (Dechant et al. 2003c). This species is a common 

summer resident of the eastern plains and great basin-foothills grasslands, 

basin-prairie shrublands, and agricultural areas throughout most of Wyoming 

(Cerovski et al. 2004). Specifically, this species requires open habitats such as 

sparsely vegetated, low structured grasslands, and heavily grazed pastures 
Appendix H 

H-86 Final EIS, Wright Area Coal Lease Applications 

containing a moderate bare ground component for nesting and foraging. Nest 

sites are typically a natural or shallow scraped depression on the ground 

placed in the open or beside vegetation such as bunch grasses, cacti, or 

shrubs. McCown’s longspurs feed on seeds of grasses and forbs, insects, and 

other arthropods. No strong data suggests breeding site fidelity although some 

individuals may return to the general nesting area in subsequent years. 

Individuals vary in response to human intrusion at nest sites, but appear to be 

relatively more tolerant than most grassland songbird species. High rates of 

predation on eggs and nestlings occur especially where nests are associated 

with vegetative structure. Nestlings may also be directly poisoned where 

insecticides are sprayed in nest areas (With 1994). Populations are declining, 

especially within the northern portion of the range. Factors directly affecting 

the McCown’s longspur include the reduction of breeding habitat due to 

overgrazing, control of prairie fires, plowing, development, and excessive use of 

pesticides. Conversion of short-grass prairie to agriculture and urban 

development is the most important factor (With 1994). 

Existing Conditions − North, South and West Hilight Field LBA Tracts

McCown’s longspurs are also common summer residents within the TBNG. 

Observations of the McCown’s longspur mirror those of the chestnut-collared 

longspur. Neither species has been documented in either the North or South 

Hilight Field tracts’ general analysis areas, and limited sightings of individual 

birds have been recorded in the West Hilight Field tract’s general analysis area 

in recent years, although no confirmed observations of this species were made 

on USFS lands in that area. The nearest observation to this general area 

occurred on non-federal lands in NE1⁄4SW1⁄4 Section 13, T.43N., R.71W. in May 

2000. The height and composition of vegetation (i.e., sagebrush) on most USFS 

lands in the North, South and West Hilight Field tracts’ general analysis areas 

is generally too tall and dense to provide suitable habitat for McCown’s 

longspurs. 

Existing Conditions − North and South Porcupine LBA Tracts

This species has not been observed on USFS or adjacent lands in the 

sagebrush dominated North Porcupine tract’s general analysis area or its 

wildlife survey area. McCown’s longspurs were not recorded on USFS lands in 

the grassland dominated South Porcupine tract’s general analysis area, but 

individuals have been seen occasionally on non-federal lands in and near that 

area. This species is regularly observed in prairie dog colonies at the 

neighboring Antelope Mine. 

Direct and Indirect Effects

The direct and indirect effects to McCown’s longspurs would be the same as 

those described above for the chestnut-collared longspur. 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-87 

Determination of Effect and Rationale − North, South and West Hilight Field 

LBA Tracts

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. USFS lands in the North Hilight Field, South Hilight Field and 

West Hilight Field tracts’ general analysis areas are dominated by sagebrush 

communities that are not as attractive to grassland species such as the 

longspur. No individuals have been documented in the general analysis areas 

for the North Hilight Field and South Hilight Field tracts, and only limited 

observations of individuals have been recorded in the West Hilight Field tract’s 

general analysis area. Potential and documented alternative habitats for 

McCown’s longspurs are present nearby in more appropriate habitats not 

currently scheduled for mining disturbance. 

Determination of Effect and Rationale − North and South Porcupine LBA Tracts

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. Potential impacts to McCown’s longspurs would be the same as 

those described above for the chestnut-collared longspur in the North and 

South Porcupine tracts’ general analysis areas. However, as reclaimed 

grasslands mature, they would become less suitable as nesting habitat for this 

short-grass species. 

H-3.2.26 Greater sage-grouse (Centrocercus urophasianus)

The Greater sage-grouse occurs year-round throughout non-forested regions of 

Wyoming (Cerovski et al. 2004). Sage-grouse rely on a variety of habitats 

within sagebrush dominated landscapes to reproduce and survive throughout 

the year. Early in the spring, grouse gather at breeding display sites called 

leks. Leks are usually in open areas (playas, ridge tops, sparse sagebrush, or 

burned areas) that are surrounded by dense sagebrush and escape cover. The 

surrounding area also typically represents nesting, loafing, and foraging 

habitat.

After being bred, hens typically scratch out a nest under sagebrush (Connelly 

et al. 1991) within three kilometers of the lek (Schroeder et al. 1999). Nests in 

some portions of sage-grouse range are typically placed under sagebrush with 

average height of 36-79 centimeters (Schroeder et al. 1999). However, research 

conducted within the Southern PRB (Brown and Clayton 2004) indicated that, 

although shorter sagebrush was present at nest sites, grouse selected shrubs 

ranging from 55-61 centimeters in height under which to place nests. Renesting may occur if the nest is destroyed early during the laying or incubation 

period. Nest success is enhanced where both sagebrush and residual grass 

cover are taller and denser (Gregg et al. 1994). Sage-grouse exhibit high fidelity 

to seasonal ranges, and may return to the same area to nest in subsequent 

years. 
Appendix H 

H-88 Final EIS, Wright Area Coal Lease Applications 

For the first month after hatching, the young depend on relatively open 

sagebrush stands with an abundance of forbs and insects, especially ants and 

beetles (Drut et al. 1994, Schroeder et al. 1999). Late-season brood rearing 

habitats, such as wet meadows and bottomlands, are more mesic and support 

greater forb cover (Drut et al. 1994). Sage-grouse use a variety of habitats 

during fall, and the incidence of sagebrush in their diet increases as forbs 

become less available. During winter, grouse feed upon sagebrush leaves 

almost exclusively. Winter range is characterized by large expanses of dense, 

exposed sagebrush. Where snow accumulations are significant, gentle southand west-facing slopes or windblown ridges are preferred. 

Breeding populations of this species have declined by at least 17 to 47 percent 

throughout much of its range (Connelly et al. 2004). Within Wyoming, sagegrouse populations have generally declined over the past 4 decades. However, 

sage-grouse population estimates specifically pertaining to the TBNG suggest 

an overall increase in individuals since 1995. This same general trend was 

observed both statewide and within the Northeast Wyoming Sage-Grouse Local 

Working Group (NWSGWG) area. 

The NWSGWG identified habitat fragmentation and degradation, disturbance 

and direct mortality as major influences affecting sage-grouse (NWSGWG 

2006). The group identified oil and gas development, vegetation management, 

invasive plants, and weather as those factors with the most influence on the 

northeast Wyoming sage-grouse populations and those that may most 

effectively be addressed to provide the greatest benefit for sage-grouse 

conservation in northeast Wyoming (NWSGWG 2006). 

Existing Conditions − North, South and West Hilight Field LBA Tracts

As described above, USFS lands on and adjacent to the general analysis areas 

for the North, South, and West Hilight Field LBA Tracts are dominated by a 

sagebrush-grassland community, primarily big sagebrush, with shrub cover 

ranging from 55 to 60 percent. Those areas provide potential year-round 

habitat for sage-grouse, though habitat quality varies. Sagebrush stands range 

from sparse to moderately dense throughout the areas, with only a marginal 

grassy understory in many areas. 

Despite the prevalence of sagebrush in the combined wildlife survey areas for 

the North, South and West Hilight Field LBA Tracts, sage-grouse numbers were 

never especially high in the area. Five sage-grouse leks are located on and 

within 2 miles of the North, South, and West Hilight Field tracts’ general 

analysis areas: Stuart I, Stuart II, Black Thunder, Butch, and Hansen Lakes 

(Figures H-1, H-2 and H-3). 

No sage-grouse leks are present on USFS lands in the North Hilight Field 

tract’s general analysis area. Two leks are present on non-federal surface in 

the tract’s general analysis area: Butch and Hansen Lakes. The Hansen Lakes 

lek is immediately south of USFS surface in that area (Figure H-1). The 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-89 

Hansen Lakes lek is classified as “occupied” by the WGFD (active in at least 1 

of the last 10 years). The Butch lek was first recorded in 1990. The peak male 

count (15) occurred in 1991, after which numbers declined dramatically. No 

grouse were recorded at the Butch lek during annual checks conducted over 

the last 14 years (1994 through 2007). The Butch lek is classified as 

“unoccupied/abandoned” by the WGFD (no activity for 10 consecutive years). 

The Butch lek was discovered in 1990, and was active every year through 

1993. The Hansen Lakes lek was discovered in 1993, coincidently at the same 

time peak male counts were dramatically declining at the Butch lek; the leks 

are approximately 1.5 miles apart. Peak male counts at the Hansen Lakes lek 

ranged from 14 to 24 birds from 1993 through 2000, but dropped markedly to 

only 3 birds in 2001. Grouse were present at the lek for the next 2 years, but 

no birds were observed there after 2003. No other grouse leks are present 

within 3 miles of the North Hilight Field tract’s general analysis area. The next 

nearest lek is the Stuart II lek, approximately 4.1 miles southwest of the North 

Hilight Field tract’s general analysis area (Figure H-1). 

No sage-grouse leks are present on USFS lands in the general analysis area for 

the South Hilight Field LBA Tract or within that tract’s 2-mile wildlife survey 

area (Figure H-2). Likewise, no lek sites have been documented on non-federal 

surface in South Hilight Field tract’s general analysis area. The former Black 

Thunder lek was located on non-federal surface approximately 1 mile east of 

the South Hilight Field tract’s general analysis area. The Black Thunder lek 

was first documented in 1984, when a peak male count of 21 was recorded. 

Grouse numbers gradually declined over the next several years of annual 

monitoring, with only one bird observed at the lek in 1993. No grouse were 

recorded at the Black Thunder lek during annual checks conducted over the 

subsequent 12 years (1994 through 2005), prior to any mine-related 

disturbance occurring within several miles. Due to the consistently low 

counts, WGFD authorized the mine to reduce searches for grouse leks in the 

permit area and 1-mile perimeter to every third year beginning in 2004 (i.e., 

2004, 2007, etc.). That lek was classified as “unoccupied/abandoned” after 10 

consecutive years of inactivity, and it was then impacted by topsoil stripping in 

2007 and is now officially classified as “unoccupied/destroyed” by WGFD. The 

Stuart II lek is located on USFS lands approximately 3 miles northwest of the 

tract’s general analysis area (Figure H-2). 

The Stuart II lek lies within the general analysis area for the West Hilight Field 

LBA Tract (Figure H-3), and is the only lek on USFS lands in the combined 

wildlife survey areas for the three Hilight Field LBA Tracts. Two leks are 

present on non-federal surface in the vicinity of the West Hilight Field area. 

The Stuart I lek is approximately 1.25 miles west of the tract’s general analysis 

area, and the next nearest lek is the former Black Thunder site, approximately 

2.25 miles east of the tract’s general analysis area (Figure H-3). 

The Stuart I lek was first recorded in 1977. The peak male count (29) occurred 

in 1979, with reduced numbers in the subsequent 2 years. The lek was 
Appendix H 

H-90 Final EIS, Wright Area Coal Lease Applications 

monitored by the WGFD at approximately 3-year intervals from 1982 through 

2003; annual monitoring was conducted by private consultants for unrelated 

projects each year from 2004 through 2007. Grouse were observed at the lek 

during only 1 of the 11 survey years from 1982 through 2007. The last 

sighting occurred in 1991, when two males were recorded at the Stuart I lek. 

The Stuart II lek was discovered in 1979. Few grouse were seen at the lek over 

the next 28 years, with a maximum of seven males observed in any survey 

year. The Stuart II lek was also surveyed primarily at 3-year intervals since its 

discovery, with annual checks conducted from 2005 through 2007. Because 

the two Stuart leks were not monitored annually, their management status is 

“undetermined,” despite consistently low counts when surveys did occur. 

Grouse counts at these five leks in the combined wildlife survey areas for the 

North, South and West Hilight Field LBA Tracts were consistently low since 

their respective discoveries, with few birds observed at any location in the last 

7 to 20 years, depending on the lek site. Additionally, records from the WGFD 

(obtained from D. Thiele, Regional Biologist, WGFD, Buffalo, Wyoming), and 

USFS have not documented any new sage-grouse leks within the approximately 

131 square mile area that encompasses the combined wildlife survey areas for 

the three Hilight Field LBA Tracts. Telemetry data collected on radio-collared 

grouse at the nearby North Antelope Rochelle Mine throughout the last 7 years 

(2001-2007) shows no sage-grouse locations within several miles of the three 

Hilight Field LBA Tracts during that period (Brown and Clayton 2004, North 

Antelope Rochelle Mine Annual Wildlife Report 2006, 2007). It is important to 

note that the reduction in grouse attendance at these five leks, and most others 

in the PRB, preceded physical mining disturbance and, thus, cannot be directly 

attributable to mine-related activities (Orpet 2007, McKee 2007). Annual 

counts for each lek are available in annual monitoring and baseline wildlife 

reports on file at the USFS Douglas Ranger District Office in Douglas and/or 

with WDEQ/LQD in Cheyenne. 

Annual surveys for sage-grouse broods were conducted in native and reclaimed 

stream channels at and around the Black Thunder Mine 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 at coal mines throughout 

the PRB. No new leks or broods were seen during recent baseline inventories 

conducted for the three Hilight Field LBA Tracts. All grouse broods that have 

been recorded over the years occurred as incidental sightings during other 

wildlife surveys. 

Areas of suitable habitat for nesting and strutting grounds are widely known as 

necessary to sustain sage-grouse populations. One recent study suggests that 

availability of winter habitat may also affect sage-grouse populations (Naugle et 

al. 2006). Nesting and winter surveys for sage-grouse are not required as part 

of the annual wildlife programs for the Black Thunder Mine or other applicant 

mines discussed in this EIS, though winter surveys have been conducted as 

part of baseline inventories for previous mine expansions. Additionally, 

periodic winter surveys for other species (i.e., big game, bald eagle roosts) have 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-91 

occurred at all three applicant mines in recent years. Due to their proximity to 

existing mine permit areas, most USFS lands in the North and South Hilight 

Field tracts’ general analysis areas, and those in the eastern half of the West 

Hilight Field tract’s general analysis area, have been included in a minimum of 

seven consecutive years (big game surveys 1993-1999) of some level of winter 

surveys, with additional surveys conducted in some subsequent years. No 

sage-grouse were ever documented in or near those LBA tracts during those 

winter surveys. 

Existing Conditions − North Porcupine LBA Tract

As described above, USFS lands on and adjacent to the general analysis area 

for the North Porcupine LBA Tract are dominated by a sagebrush-grassland 

community, primarily big sagebrush, with shrub cover averaging 54 percent in 

that area. The North Antelope Rochelle Mine, as part of its wildlife monitoring 

program from 1984 through 1992, conducted voluntary searches for and 

annual monitoring of sage-grouse leks throughout the mine’s original permit 

area and a 1-mile perimeter. Those surveys became mandatory with the 

implementation of Appendix B of the WDEQ/LQD Coal Rules and Regulations 

in 1993, and continued each year through 2007. Radio-telemetry data 

gathered from grouse collared at the North Antelope Rochelle Mine during a 

voluntary, multi-year (2001 through 2007) study have demonstrated that most 

birds in the North and South Porcupine LBA Tracts’ 2-mile wildlife survey 

areas (Figures H-4 and H-5) reside near the mine year-round. Additional 

details describing the survey and monitoring efforts for sage-grouse at the 

North Antelope Rochelle Mine are available in annual wildlife monitoring and 

baseline wildlife reports on file at the USFS Douglas Ranger District Office in 

Douglas and/or with WDEQ/LQD in Cheyenne. 

Five sage-grouse leks are located within 2 miles of the North Porcupine tract’s 

general analysis area: Payne, Wilson, Rochelle, Kort I, and Kort II (Figure H-4). 

The Payne and Kort 1 leks are on USFS lands, but only the Payne lek is 

actually within the LBA tract’s general analysis area itself. These five leks are 

collectively referred to as the Rochelle Complex. The birds in that complex 

comprise approximately 4 percent of the grouse population in the entire TBNG, 

and approximately 17 percent of the population in the Hilight Bill Geographic 

Area. 

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 7 years, with numbers 

increasing each year from 2005 through 2007. The average annual peak count 

for males at the Payne lek since its discovery was 10.5. The Payne lek is 

currently classified as “occupied.” 

The Wilson lek has been unoccupied for the last 10 consecutive years, and is 

therefore considered “unoccupied/abandoned.” 
Appendix H 

H-92 Final EIS, Wright Area Coal Lease Applications 

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 average peak male count for the Kort leks since their discovery was 

5.2 males per year. The Kort I and Kort II leks are currently classified as 

“occupied.” 

Although sage-grouse numbers have generally been low in the combined North 

and South Porcupine tracts’ wildlife survey areas over the years, known or 

potential grouse habitat is present in both areas. 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 radio-telemetry 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 LBA 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 North and 

South Porcupine LBA Tracts. All grouse broods that have been recorded over 

the years occurred as incidental sightings during other wildlife surveys. 

Nesting and winter surveys for sage-grouse are not required as part of the 

annual wildlife programs for the North Antelope Rochelle or the other applicant 

mines included in this EIS (Black Thunder and Jacobs Ranch), though winter 

surveys have been conducted as part of baseline inventories for previous mine 

expansions. Additionally, winter surveys for other species (big game and bald 

eagle roosts) have occurred at all three of these mines in recent years. Due to 

their proximity to existing mine permit areas, nearly all of the combined North 

and South Porcupine tracts’ general analysis areas have been included in some 

level of regular (but not always annual) winter surveys since 1987. No sagegrouse were ever documented in or near these two LBA tracts during those 

surveys. However, grouse have been confirmed as year-round residents in the 

vicinity of the North Porcupine tract general analysis area during year-round 

telemetry studies conducted from 2001 through 2005, with less frequent 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-93 

monitoring during the subsequent two winters. Only isolated grouse sightings 

occurred within 3 miles of the South Porcupine tract general analysis area 

during that telemetry monitoring period, with each sighting limited to a single 

observation per bird. 

Existing Conditions − South Porcupine LBA Tract

As described previously, USFS lands on the general analysis area for the South 

Porcupine LBA Tract are dominated by various native and introduced 

grassland species. The North Antelope Rochelle Mine, as part of its wildlife 

monitoring program from 1984 through 1992, conducted voluntary searches 

for and annual monitoring of sage-grouse leks throughout the mine’s original 

permit area and a 1-mile perimeter. Those surveys became mandatory with the 

implementation of Appendix B of the WDEQ/LQD Coal Rules and Regulations 

in 1993, and continued each year through 2007. Radio-telemetry data 

gathered from grouse collared at the North Antelope Rochelle Mine during a 

voluntary, multi-year (2001 through 2007) study have demonstrated that most 

birds in the North and South Porcupine LBA Tracts’ 2-mile wildlife survey 

areas (Figures H-4 and H-5) reside near the mine year-round. Additional 

details describing the survey and monitoring efforts for sage-grouse at the 

North Antelope Rochelle Mine are available in annual wildlife monitoring and 

baseline wildlife reports on file at the USFS Douglas Ranger District Office in 

Douglas and/or with WDEQ/LQD in Cheyenne. 

No sage-grouse leks have been documented on or within 3 miles of the South 

Porcupine tract’s general analysis area (Figure H-5). The Payne lek, which is 

nearly 5 miles to the northeast, is the closest sage-grouse lek to the South 

Porcupine tract’s general analysis area. 

Although sage-grouse numbers have generally been low in the combined North 

and South Porcupine tracts’ wildlife survey areas over the years, known or 

potential grouse habitat is present in both areas. 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 radio-telemetry 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 LBA 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 North and 
Appendix H 

H-94 Final EIS, Wright Area Coal Lease Applications 

South Porcupine LBA Tracts. All grouse broods that have been recorded over 

the years occurred as incidental sightings during other wildlife surveys. 

Nesting and winter surveys for sage-grouse are not required as part of the 

annual wildlife programs for the North Antelope Rochelle or the other applicant 

mines included in this EIS (Black Thunder and Jacobs Ranch), though winter 

surveys have been conducted as part of baseline inventories for previous mine 

expansions. Additionally, winter surveys for other species (big game and bald 

eagle roosts) have occurred at all three of these mines in recent years. Due to 

their proximity to existing mine permit areas, nearly all of the combined North 

and South Porcupine tracts’ general analysis areas have been included in some 

level of regular (but not always annual) winter surveys since 1987. No sagegrouse were ever documented in or near these two LBA tracts during those 

surveys. However, grouse have been confirmed as year-round residents in the 

vicinity of the North Porcupine general analysis area during year-round 

telemetry studies conducted from 2001 through 2005, with less frequent 

monitoring during the subsequent two winters. Only isolated grouse sightings 

occurred within 3 miles of the South Porcupine general analysis area during 

that telemetry monitoring period, with each sighting limited to a single 

observation per bird. 

Direct and Indirect Effects − North, South and West Hilight Field LBA Tracts

Three of the five sage-grouse leks located in the combined wildlife survey areas 

for the three Hilight Field LBA Tracts occur in an area likely to be disturbed by 

future mining, if the three proposed leasing actions are approved. One lek 

(Stuart II in the West Hilight Field tract’s general analysis area) is on USFS 

lands and the other two (Hansen Lakes and Butch) are on non-federal surface 

in the North Hilight Field tract’s general analysis area. 

Due to the consistently low number of sage-grouse documented in these LBA 

tracts’ wildlife survey areas over the last 3 decades, despite the presence of 

apparently suitable habitat, leasing and mining USFS lands and adjacent lands 

within the general analysis areas for the North, South, and West Hilight Field 

LBA Tracts would have limited effects on individual birds. Some potential 

impacts of mineral development (including coal mining and oil and gas 

development) on sage-grouse that might inhabit the area, as well as on known 

and potential sage-grouse habitat include: alteration of plant and animal 

communities; loss or degradation of important seasonal habitats; increased 

human activity and noise which could cause animals to avoid the area and/or 

reduce their breeding efficiency; increased road traffic and related injuries or 

mortalities; increased risk of predation from raptors perched on existing or 

future power poles and/or grouse avoidance of areas with overhead power 

lines; potential illegal harvest; and reduced water tables resulting in the loss of 

herbaceous vegetation. 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. 

Sagebrush is a component of both the Sagebrush/Grassland and Big 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-95 

Sagebrush vegetation communities, which occupy approximately 55 to 60 

percent of the combined vegetation analysis areas for the three Hilight Field 

LBA Tracts. WDEQ/LQD reclamation standards call for restoration of 

sagebrush on at least 20 percent of the reclaimed area. Estimates for the time 

it would take to restore shrubs, including sagebrush, to pre-mining density 

levels range from 20 to 100 years. Until sagebrush returns to its pre-mining 

density levels, a reduction in potential sage-grouse nesting habitat and winter 

habitat on the three Hilight Field LBA Tracts would persist. 

Due to the documented long-term lack of sage-grouse use on USFS lands and 

adjacent lands in the North, South, and West Hilight Field tracts’ general 

analysis areas and surrounding wildlife survey areas, USFS Standards and 

Guidelines (USFS 2002, page 1-18; Appendix D) would have limited 

applications toward controlling the type, timing, and location of disturbance 

activities within the three Hilight Field LBA Tract areas. The use of existing 

roads, when possible, could minimize additional impacts related to traffic 

hazards and the use of new travel corridors by mammalian predators. Raptor 

predation does not seem to be a primary source of mortality for the local sagegrouse population (Brown and Clayton 2004). Nevertheless, new overhead 

power lines could be fitted with perch deterrents to limit opportunities for avian 

predators to target any grouse that might be in the area. The use of 

underground power lines to the extent possible would also reduce this risk, 

and would minimize new vertical structures that could affect grouse use or 

movements in the area. If precautions are taken to avoid direct mortalities and 

disturbances to nests and leks during the breeding season, grouse might have 

the opportunity to disperse away from mine activities. 

Mine operations and oil and gas development have requirements for 

reclamation of disturbed areas as recovery of energy resources is completed. 

Those reclamation efforts can work in concert with Standards and Guidelines 

toward mitigating impacts to wildlife species and habitats, though reclamation 

standards are widely variable among industries. New areas disturbed by 

mining in the general analysis areas for the three Hilight Field LBA Tracts will 

be reclaimed incrementally, but they may not be attractive to sage-grouse for 

many years due to slow establishment and growth rates of important 

sagebrush species. Information gleaned from the multi-year telemetry study at 

a neighboring coal mine could also be helpful in reclamation efforts for the 

three Hilight Field LBA Tracts. In the meantime, the presence of known and 

apparently suitable sage-grouse habitat elsewhere within the immediate area 

could provide alternate areas for dispersing grouse to use until reclaimed 

sagebrush stands have matured adequately to support a local population. 

In keeping with the Direction Objectives for the Hilight Bill Geographic Area 

(USFS 2002, page 1-25), impacts to sage-grouse habitat in the general analysis 

areas for the three Hilight Field LBA Tracts could be further mitigated off-site 

by efforts to preserve and enhance habitat on adjoining and nearby private 

lands, such as those currently under way through the Thunder Basin 

Grasslands Prairie Ecosystem Association. Management planning and 
Appendix H 

H-96 Final EIS, Wright Area Coal Lease Applications 

processes that are developed through this combined effort among landowners 

and federal representatives will presumably provide suitable habitat for sagegrouse that disperse from the three Hilight Field LBA Tracts general analysis 

areas during the interim between habitat disturbance and completed 

reclamation. 

Should sage-grouse move onto USFS lands analyzed in this EIS in the future, 

agency Standards and Guidelines would offer appropriate protections for the 

species and its important habitats. However, under the current conditions, 

and the documented absence or consistently low presence of this species in the 

area, mining USFS lands within the North, South, and West Hilight Field LBA 

Tracts would not adversely impact sage-grouse populations in the region, nor 

would it conflict with the current TBNG Plan or any future objectives to 

manage the area for this species. 

Direct and Indirect Effects − North Porcupine LBA Tract

Because of their location within the existing permit area for the North Antelope 

Rochelle Mine, all five sage-grouse leks in the North Porcupine tract’s wildlife 

survey area occur in an area likely to be disturbed by future mining, regardless 

of whether the proposed leasing action is approved. 

Some potential impacts of mineral development (including coal mining and oil 

and gas development) on sage-grouse that might inhabit the general analysis 

area for the North Porcupine tract, as well as on known and potential sagegrouse habitat include: alteration of plant and animal communities; loss or 

degradation of important seasonal habitats; increased human activity and 

noise, which could cause animals to avoid the area and/or reduce their 

breeding efficiency; increased road traffic and related injuries or mortalities; 

increased risk of predation from raptors perched on existing or future power 

poles and/or grouse avoidance of areas with overhead power lines; potential 

illegal harvest; and reduced water tables resulting in the loss of herbaceous 

vegetation. 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. 

Sagebrush communities occupy approximately 54 percent of the vegetation 

analysis areas in the North Porcupine LBA Tract. Mine operations and oil and 

gas development have requirements for reclamation of disturbed areas as 

recovery of energy resources is completed. WDEQ/LQD reclamation standards 

for surface coal mines call for restoration of sagebrush on at least 20 percent of 

the reclaimed area. Those reclamation efforts can work in concert with USFS 

Standards and Guidelines toward mitigating impacts to wildlife species and 

habitats. New areas disturbed by mining in the general analysis area for the 

North Porcupine LBA Tract would be reclaimed incrementally, but they may 

not be attractive to sage-grouse for many years due to slow establishment and 

growth rates of important sagebrush species. Information gleaned from the 

multi-year telemetry study at the North Antelope Rochelle Mine would be 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-97 

incorporated into reclamation efforts for the LBA tract to maximize successful 

reclamation of sage-grouse habitat. Estimates for the time it would take to 

restore shrubs, including sagebrush, to pre-mining density levels range from 

20 to 100 years. Until sagebrush returns to its pre-mining density levels, a 

reduction in potential year-round sage-grouse habitat within the North 

Porcupine tract’s general analysis area would persist. In the meantime, the 

presence of known and apparently suitable sage-grouse habitat elsewhere 

within the immediate area could provide alternate areas for dispersing grouse 

to use until reclaimed sagebrush stands have matured adequately to support a 

local population. 

In keeping with the Direction Objectives for the Hilight Bill Geographic Area 

(USFS 2002, page 1-25), impacts to sage-grouse habitat in the general analysis 

area for the North Porcupine LBA Tract could be further mitigated off-site by 

efforts to preserve and enhance habitat on adjoining and nearby private lands, 

such as those currently under way through the Thunder Basin Grasslands 

Prairie Ecosystem Association. Management planning and processes that are 

developed through this combined effort among landowners and federal 

representatives will presumably provide suitable habitat for sage-grouse that 

disperse from the North Porcupine tract and adjacent North Antelope Rochelle 

Mine areas during the interim between habitat disturbance and completed 

reclamation. Should sage-grouse move onto new USFS lands proposed for 

mining in the future, agency Standards and Guidelines would offer appropriate 

protections for the species and its important habitats. 

Despite the impacts to the Rochelle lek complex, the proposed leasing action 

would not contribute to significant reductions in the regional sage-grouse 

population overall, nor would it conflict with the current TBNG Plan or any 

future objectives to manage the area for this species. 

Direct and Indirect Effects − South Porcupine LBA Tract

No impacts to sage-grouse are expected for the South Porcupine area due to 

the documented lack of sage-grouse and suitable sage-grouse habitat in that 

area. 

Some potential impacts of mineral development (including coal mining and oil 

and gas development) on sage-grouse that might inhabit the general analysis 

area for the South Porcupine tract, as well as on known and potential sagegrouse habitat include: alteration of plant and animal communities; loss or 

degradation of important seasonal habitats; increased human activity and 

noise which could cause animals to avoid the area and/or reduce their 

breeding efficiency; increased road traffic and related injuries or mortalities; 

increased risk of predation from raptors perched on existing or future power 

poles and/or grouse avoidance of areas with overhead power lines; potential 

illegal harvest; and reduced water tables resulting in the loss of herbaceous 

vegetation. Following reclamation, there may be a long-term loss of nesting 
Appendix H 

H-98 Final EIS, Wright Area Coal Lease Applications 

and winter habitat, depending on the amount of sagebrush that is restored 

relative to the amount of sagebrush that is present before mining. 

Mine operations and oil and gas development have requirements for 

reclamation of disturbed areas as recovery of energy resources is completed. 

WDEQ/LQD reclamation standards for surface coal mines call for restoration 

of sagebrush on at least 20 percent of the reclaimed area. Those reclamation 

efforts can work in concert with USFS Standards and Guidelines toward 

mitigating impacts to wildlife species and habitats. New areas disturbed by 

mining in the South Porcupine tract’s general analysis area would be reclaimed 

incrementally, but they may not be attractive to sage-grouse for many years 

due to slow establishment and growth rates of important sagebrush species. 

Information gleaned from the multi-year telemetry study at the North Antelope 

Rochelle Mine will be incorporated into reclamation efforts for the LBA tract to 

maximize successful reclamation of sage-grouse habitat. Estimates for the 

time it would take to restore shrubs, including sagebrush, to pre-mining 

density levels range from 20 to 100 years. Until sagebrush returns to its premining density levels, a reduction in potential year-round sage-grouse habitat 

within the South Porcupine tract’s general analysis area would persist. In the 

meantime, the presence of known and apparently suitable sage-grouse habitat 

elsewhere within the immediate area could provide alternate areas for 

dispersing grouse to use until reclaimed sagebrush stands have matured 

adequately to support a local population. 

In keeping with the Direction Objectives for the Hilight Bill Geographic Area 

(USFS 2002, page 1-25), impacts to sage-grouse habitat in the North Antelope 

Rochelle Mine’s permit area could be further mitigated off-site by efforts to 

preserve and enhance habitat on adjoining and nearby private lands, such as 

those currently under way through the Thunder Basin Grasslands Prairie 

Ecosystem Association. Management planning and processes that are 

developed through this combined effort among landowners and federal 

representatives will presumably provide suitable habitat for sage-grouse that 

disperse from the North Antelope Rochelle Mine area during the interim 

between habitat disturbance and completed reclamation. Should sage-grouse 

move onto new USFS lands proposed for mining in the future, agency 

Standards and Guidelines would offer appropriate protections for the species 

and its important habitats. 

Despite the impacts to the Rochelle lek complex, the proposed leasing action 

would not contribute to significant reductions in the regional sage-grouse 

population overall, nor would it conflict with the current TBNG Plan or any 

future objectives to manage the area for this species. 

Determination of Effect and Rationale − North, South and West Hilight Field 

LBA Tracts

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-99 

planning area. The sage-grouse is a common year-round resident throughout 

much of the PRB and TBNG, but has declined 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. Three decades of regular monitoring have documented 

that sage-grouse have not consistently inhabited the USFS lands analyzed for 

the North or South Hilight Field LBA Tracts, nor have they been confirmed as 

occupying USFS lands analyzed for the West Hilight Field LBA Tract since 

1991. Currently, the nearest lek (Payne lek) with regular activity is more than 

5.0 miles to the southeast of the USFS lands in the South and West Hilight 

Field LBA Tracts. Consequently, if the North, South and West Hilight Field 

LBA Tracts are leased, anticipated mining-related disturbances would not 

affect any identified and actively used seasonal sage-grouse habitats on or near 

USFS lands in the combined general analysis areas for these three tracts. 

Annual monitoring will continue for the life of the Black Thunder Mine, and 

would include new permit expansions and a one-mile perimeter. Should sagegrouse be observed on USFS lands in any of the three Hilight Field LBA Tracts’ 

wildlife survey areas, appropriate monitoring and mitigation measures would 

be implemented to minimize impacts to birds, habitats, and populations.

Determination of Effect and Rationale − North Porcupine LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. More than 20 years of regular monitoring have documented 

that sage-grouse do inhabit USFS lands analyzed for the North Porcupine LBA 

Tract general analysis area. Currently, the Payne and Kort leks are the only 

sites with regular activity in recent years, with most birds seen at the Payne 

lek. Those leks have been used by an average peak count of 10.5 and 5.2 

males per year, respectively, since they were discovered. Although impacts to 

the leks within the Rochelle complex will be detrimental to individual birds, 

that group represents only a small (4 to 17 percent) proportion of the sagegrouse population in the TBNG and Hilight Bill Geographic Area, respectively. 

Annual monitoring will continue for the life of the North Antelope Rochelle 

Mine, and will include new permit expansions and a 1-mile perimeter. Should 

additional sage-grouse leks or use areas be observed on USFS lands in the 

North Porcupine tract’s wildlife survey area, appropriate monitoring and 

mitigation measures will be implemented to minimize impacts to birds, 

habitats, and populations.

Determination of Effect and Rationale − South Porcupine LBA Tract

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. More than 20 years of regular monitoring have documented 

that sage-grouse do not inhabit the grassland dominated South Porcupine LBA 

Tract general analysis area. Annual monitoring will continue for the life of the 

North Antelope Rochelle Mine, and will include new permit expansions and a 

one-mile perimeter. Should additional sage-grouse leks or use areas be 

observed on USFS lands in the South Porcupine tract’s wildlife survey area, 
Appendix H 

H-100 Final EIS, Wright Area Coal Lease Applications 

appropriate monitoring and mitigation measures will be implemented to 

minimize impacts to birds, habitats, and populations.

H-3.2.27 Bald eagle (Haliaeetus leucocephalus)

Bald eagles occur throughout North America, from Alaska and Canada south to 

Florida, the Gulf Coast, and northern Mexico. The northwest coast of North 

America serves as the stronghold for this species, with approximately one-half 

of the population inhabiting Alaska. 

The USFWS officially listed the bald eagle as an endangered species in 43 of the 

lower 48 states on July 4, 1976. The listing was due to a combination of 

several factors, including widespread habitat loss, negative effects of pesticide 

use on reproductive success, indiscriminant shooting, and others. The status 

of the bald eagle was downgraded to threatened throughout the lower 48 states 

in 1995. Bald eagle population trends began increasing throughout most of 

the species’ range in the early 1990’s, and it was proposed for de-listing in 

1999. 

On July 9, 2007, USFWS published a Federal Register notice (72 FR 37346) 

announcing that the bald eagle would be removed from the list of threatened 

and endangered species under the Endangered Species Act of 1973, as 

amended (16 U.S.C 1531 et seq.) on August 8, 2007. However, the protections 

provided to the bald eagle under the Bald and Golden Eagle Protection Act 

(BGEPA), 16 U.S.C. 668, and the Migratory Bird Treaty Act (MBTA), 16 U.S.C. 

703, will remain in place. The bald eagle is now recognized as a BLM and 

USFS Sensitive Species. 

Bald eagles typically nest in large trees within a stand of mature, similarly 

sized trees either beside or in proximity (within 0.7 mile) to rivers, lakes, or 

reservoirs that harbor adequate fish populations. Those areas tend to be 

remote and experience little disturbance (Johnsgard 1990). Typically, the nest 

is placed in the crown of a large cottonwood or pine, but if the topography 

allows, eagles will nest on cliff edges or escarpments. Open-canopied trees and 

snags provide required perches in nesting and foraging areas. 

All verified bald eagle nests in northeastern Wyoming (BLM Buffalo Field Office 

GIS database) are situated in significant, mature cottonwood stands along 

larger streams or rivers (i.e., Tongue River, Powder River, Clear Creek, and 

Little Thunder Creek). Nesting attempts are rare on the TBNG (Beske 1994). 

Fish and waterfowl are the primary source of food for nesting bald eagles. 

Where available, large to mid-size carrion and large rodents (e.g., prairie dogs) 

can also be an important dietary component. 

Bald eagles nest and winter throughout Wyoming, though typically are not 

locally abundant in the northeastern portion of the state. The species regularly 

migrates through and winters in Campbell County (Cerovski et al. 2004), and 

has often been documented during winter and early spring at nearby coal 

mines (various coal mine annual reports are on file at the USFS Douglas 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-101 

Ranger District Office in Douglas and/or with WDEQ/LQD in Cheyenne). Most 

eagles that migrate through or winter in Campbell County roost communally in 

stands of large ponderosa pine, along wooded cottonwood-riparian corridors, or 

in isolated stands of large trees. As water is scarce in that region, especially 

during winter, those birds likely forage widely for lagomorphs or carrion. 

Existing Conditions − North, South and West Hilight Field LBA Tracts

The bald eagle is seasonally common and most frequently observed during the 

winter months. Bald eagles are relatively common winter residents and 

migrants in the PRB, but only rarely nest in that region. Potential bald eagle 

nesting and winter roosting habitat, being primarily scattered stands of mature 

cottonwood trees, are present on USFS and adjacent lands along Little Thunder 

Creek, which flows through the general analysis areas for the South and West 

Hilight Field LBA Tracts; no streams flow through the North Hilight Field tract’s 

general analysis area. 

In general, the combined wildlife survey areas for the three Hilight Field LBA 

Tracts do not contain unique or sizeable concentrated prey sources (e.g., 

fisheries, waterfowl wintering areas) that would be expected to attract bald 

eagles. As described in the North, South, and West Hilight Field LBA Tracts’ 

black-tailed prairie dog analyses that are included within this appendix and in 

Section 3.10 of this EIS, two prairie dog colonies encompassing a total of 

approximately 89.2 acres were present on USFS lands within the three Hilight 

Field tracts’ general analysis areas in 2007. A total of four prairie dog colonies 

encompassing approximately 112.1 acres were present in the three combined 

general analysis areas, and a total of 12 prairie dog colonies encompassing 

approximately 248.9 acres were present in the combined wildlife study areas 

for the three Hilight Field LBA Tracts in 2007 (Figures H-1, H-2 and H-3). 

Sheep and their lambs are present in this area in the spring, when bald eagles 

have typically left the region, and flocks are pastured there infrequently in the 

winter. The area does not support a large big game herd, though some groups 

do winter in the area. 

Ground surveys for bald eagle winter roost sites were most recently conducted 

within the combined wildlife survey areas for the three Hilight Field tracts 

during baseline surveys beginning in 2006. Previous winter roost surveys also 

encompassed all or most potential habitat within that overall survey area. All 

winter roost surveys were conducted between 1⁄2 hour before and 1 hour after 

sunrise or between 1 hour before and 1⁄2 hour after sunset, per current BLM 

guidelines for survey timing and frequency. Biologists also watched for nesting 

bald eagles within the survey area while conducting surveys for other nesting 

raptors. 

No bald eagle nests or winter roosts have been documented within 1 mile of 

USFS lands located within the North Hilight Field tract’s general analysis area 

during any baseline or annual monitoring studies since they began in the late 

1970s and early 1980s, respectively. Similarly, no bald eagle nests or winter 
Appendix H 

H-102 Final EIS, Wright Area Coal Lease Applications 

roosts have been documented within 1 mile of USFS lands located within the 

South Hilight Field tract’s general analysis area during any baseline or annual 

monitoring studies since they began during those same timeframes. 

The BLM and USFS wildlife databases indicate that the nearest potential bald 

eagle nest was identified in 2003 in T.43N., R.71W., NE1⁄4NW1⁄4 Section 29, 

which is in the southwestern corner of the West Hilight Field tract’s general 

analysis area (Figure H-3). Although the nest has been labeled as a bald eagle 

site for that year, the circumstances of the sighting were less than definitive. 

The lone observation of the nest was made from approximately 1 mile away late 

in the nesting season, when young golden eagles are fully feathered except for 

their heads. It is possible that an inexperienced observer could have mistaken 

a young golden eagle for an adult bald eagle under those circumstances. 

Additionally, golden eagles were confirmed nesters at the same site location in 

both 2002 and 2004. Nevertheless, the site could be treated as a potential bald 

eagle nest for management purposes. 

Existing Conditions − North and South Porcupine LBA Tracts

The bald eagle is seasonally common and most frequently observed during the 

winter months. Bald eagles are relatively common winter residents and 

migrants in the PRB, but only rarely nest in that region. 

No bald eagle nests or winter roosts have been documented within 1 mile of 

USFS lands located within the general analysis areas for the North or South 

Porcupine LBA Tracts during any baseline or annual monitoring studies since 

they began in the late 1970s and early 1980s, respectively. Scattered stands of 

potential bald eagle nesting and winter roosting habitat (mature cottonwood 

corridors) are present on USFS and adjacent lands along Porcupine Creek as it 

flows through the general analysis area for the North Porcupine LBA Tract. No 

streams flow through the South Porcupine tract’s general analysis area and few 

trees are present there. 

In general, the combined wildlife survey areas for the two Porcupine LBA Tracts 

do not contain unique or sizeable, concentrated prey sources (e.g., fisheries, 

waterfowl wintering areas) that would be expected to attract bald eagles. As 

described in the North and South Porcupine LBA Tracts’ black-tailed prairie 

dog analyses that are included within this appendix and in Section 3.10 of this 

EIS, no prairie dog colonies were present on USFS lands within either tract’s 

general analysis area in 2007. Only one colony encompassing approximately 

18.6 acres was present within the North Porcupine tract’s general analysis 

area, and no colonies were present within the South Porcupine tract’s general 

analysis area, in 2007. A total of 23 prairie dog colonies encompassing 

approximately 1,317 acres were present in the combined wildlife study areas 

for the two Porcupine LBA Tracts in 2007 (Figures H-4 and H-5). Sheep and 

their lambs are present in this area in the spring, when bald eagles have 

typically left the region, and flocks are pastured there infrequently in the 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-103 

winter. The area does not support a large big game herd, though some groups 

do winter in the area. 

Ground surveys for bald eagle winter roost sites were most recently conducted 

within the combined wildlife survey areas for the two Porcupine tracts during 

baseline surveys beginning in 2006. Previous winter roost surveys also 

encompassed all or most potential habitat within that overall survey area. All 

winter roost surveys were conducted between 1⁄2 hour before and 1 hour after 

sunrise or between 1 hour before and 1⁄2 hour after sunset, per current BLM 

guidelines for survey timing and frequency. Biologists also watched for nesting 

bald eagles within the survey area while conducting surveys for other nesting 

raptors. 

Direct and Indirect Effects

As no winter roost sites or large groups of bald eagles have been documented in 

the general analysis area for any of the WAC LBA Tracts, potential impacts 

would be limited to occasional foraging individuals rather than a large segment 

of the population. The increased human presence and noise associated with 

construction activities, if conducted while eagles are wintering within the area, 

could harass or displace individual eagles during that period. Nesting eagles 

could also be distressed to the point of abandoning eggs or young, or their 

hunting efforts and success impacted. If necessary, the majority of direct 

effects could be mitigated by controlling the timing and location of disturbance 

activities, and/or through approved nest relocation efforts. 

Indirect effects include additional disturbance and fragmentation of already 

limited foraging habitat within the geographic area. These impacts could result 

from a variety of large- and small-scale activities described previously for other 

species, including, but not limited to: topsoil stripping; overburden and coal 

removal; reclamation activities; and construction of roads, reservoirs, power 

lines (above ground and buried), fences, and pipelines. The locations of 

operations would shift throughout the expanded permit area as mining 

occurred, with habitats disturbed and reclaimed incrementally. Conversely, 

the addition of fences and raptor-safe power poles could possibly benefit 

foraging bald eagles by providing additional perch sites. Due to the limited 

presence of potential nesting or roosting sites, and lack of concentrated sources 

of prey, the direct and indirect effects of the Proposed Action and Alternative 2 

for each LBA tract to bald eagles are expected to be minimal. 

Determination of Effect and Rationale − North, South and West Hilight Field 

LBA Tracts

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. No bald eagle nests have been documented on or within 1 mile 

of the North or South Hilight Field LBA Tracts’ general analysis areas, and only 

one dubious nesting event was recorded in the West Hilight Field LBA Tract’s 

general analysis area over time. Bald eagle winter roost sites are absent from 
Appendix H 

H-104 Final EIS, Wright Area Coal Lease Applications 

all three Hilight Field LBA Tracts’ wildlife survey areas, and little potential 

nesting or roosting habitat is present. Therefore, potential hazards for this 

species would be limited to foraging individuals during winter. Disturbance, 

fragmentation, and alteration of potential foraging habitat would occur. 

However, the Black Thunder Mine has avoided, where possible, and mitigated 

raptor impacts in the past through intensive raptor monitoring, 

implementation of USFWS approved mitigation measures, and adjusting 

operations to provide temporal and spatial buffers around raptor nests. 

Determination of Effect and Rationale − North and South Porcupine LBA Tracts

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. No bald eagle nests have been documented on or within 1 mile 

of the North or South Porcupine LBA Tract’s general analysis area since annual 

monitoring began in the early 1980s. Potential bald eagle winter roost and 

nesting sites are limited in both LBA tract’s wildlife survey area, and no reliable 

prey sources are present to support nesting or roosting bald eagles. Therefore, 

potential hazards for this species would be limited to foraging individuals 

during winter. Disturbance, fragmentation, and alteration of potential foraging 

habitat would occur. However, the North Antelope Rochelle Mine has avoided, 

where possible, and mitigated raptor impacts in the past through intensive 

raptor monitoring, implementation of USFWS approved mitigation measures, 

and adjusting operations to provide temporal and spatial buffers around raptor 

nests. 

H-3.2.28 Mountain plover (Charadrius montanus)

The mountain plover breeds from southeastern Alberta and southwestern 

Saskatchewan through central Montana, south to south-central Wyoming, 

east-central Colorado and northeastern New Mexico, and east to northern 

Texas and western Kansas. In Wyoming, this species is a common summer 

resident (Cerovski et al. 2004). Mountain plovers require flat grasslands with 

short and sparse vegetation, and a large bare ground component (Knopf 1996) 

for nesting, foraging, or staging. Within the PRB, heavily grazed prairie dog 

colonies generally provide the most suitable mountain plover habitat. 

Mountain plovers are monogamous and possibly polyandrous ground nesters, 

and typically produce at least two clutches. The nest is a shallow depression 

occasionally thinly lined with grass. Plovers may utilize the same nesting area 

in subsequent years (Dechant et al. 2003d). Adults and fledged chicks leave 

the breeding grounds by early August, and may stage within appropriate 

habitats before migrating. Plovers feed primarily upon insects. Beetles, 

grasshoppers, crickets, and ants are the most important prey items (Knopf 

1996). This species is highly approachable and does not flee far. Mountain 

plover populations have historically declined and recent data suggests that this 

species is continuing to decline in numbers. Causes of population declines 

have been primarily attributed to regional changes in agricultural practices 

(Knopf 1996). 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-105 

Existing Conditions − North, South and West Hilight Field LBA Tracts

Mountain plovers are summer residents within portions of the TBNG. Most 

observations of mountain plovers in northeast Wyoming have been associated 

with prairie dog colonies. Approximately 86 percent of recently (since 1993) 

occupied mountain plover habitat in that region occurred within prairie dog 

colonies (Byer 2001). As described in the North, South, and West Hilight Field 

LBA Tracts’ black-tailed prairie dog analyses that are included within this 

appendix and in Section 3.10 of this EIS, two prairie dog colonies 

encompassing a total of approximately 89.2 acres were present on USFS lands 

within the three Hilight Field tracts’ general analysis areas in 2007. A total of 

four prairie dog colonies encompassing approximately 112.1 acres were present 

in the three combined general analysis areas, and a total of 12 prairie dog 

colonies encompassing approximately 248.9 acres were present in the 

combined wildlife study areas for the three Hilight Field LBA Tracts in 2007 

(Figures H-1, H-2 and H-3). 

As previously described for other short-grass species, the dominance of 

sagebrush in the North, South, and West Hilight Field LBA Tract’s general 

analysis and wildlife survey areas provides only poor to marginal or unsuitable 

habitat for mountain plovers. The height and composition of vegetation on 

most USFS lands in the three Hilight Field tracts’ general analysis areas is 

generally too tall and dense to provide suitable habitat for mountain plovers. 

The lack of occurrence of this species at the Black Thunder Mine and 

surrounding area, including all USFS lands in the analysis areas, is well 

documented. The nearest known population of nesting mountain plovers 

occurs at the Antelope Mine, approximately 9 miles south of the South Hilight 

Field tract’s general analysis area, and even farther from the other two Hilight 

Field LBA Tracts. 

Existing Conditions − North and South Porcupine LBA Tracts

Mountain plovers are summer residents within portions of the TBNG. Most 

observations of mountain plovers in northeast Wyoming have been associated 

with prairie dog colonies. Approximately 86 percent of recently (since 1993) 

occupied mountain plover habitat in that region occurred within prairie dog 

colonies (Byer 2001). Because of the similarity in habitat requirements 

between the mountain plover and McCown’s longspur, similar existing 

conditions and impacts would apply for both species. The nearest known 

breeding population of mountain plovers occurs in a large prairie dog colony 

located at the Antelope Mine, approximately 4 miles southwest of the South 

Porcupine LBA Tract’s general analysis area, and even farther from the North 

Porcupine LBA Tract. 

As described above, sagebrush communities dominate the North Porcupine 

tract’s general analysis area. Only one small (approximately 18.6 acres) prairie 

dog colony is present in that area, and it is located on non-federal lands. 

Generally, the vegetation in the North Porcupine tract’s general analysis area 

and surrounding wildlife survey area is too tall and dense to attract mountain 
Appendix H 

H-106 Final EIS, Wright Area Coal Lease Applications 

plovers. The best potential habitat for this species occurs in a large (about 

345.3 acres) occupied prairie dog colony immediately south of the North 

Porcupine tract’s general analysis area (Figure H-4). Despite the presence of 

suitable habitat and the occurrence of annual monitoring in that area, 

mountain plovers have never been documented on USFS or adjacent lands 

within the North Porcupine tract’s general analysis area. 

Some portions of the grassland-dominated South Porcupine tract’s general 

analysis area and surrounding area would be considered suitable mountain 

plover habitat, including both USFS and non-federal surface. The best 

potential habitat for this species occurs in the large (about 345.3 acres) 

occupied prairie dog colony that overlaps the wildlife monitoring area for both 

the North and South Porcupine LBA Tracts (Figures H-4 and H-5). Despite the 

presence of suitable habitat and the occurrence of annual monitoring in that 

area, mountain plovers have never been documented on USFS or adjacent 

lands within the South Porcupine tract’s general analysis area. 

Mountain plovers have been recorded in the combined North and South 

Porcupine tracts’ wildlife survey areas only three times over the last 2 decades 

of annual monitoring. In mid-June 2004, single individuals were seen in shortgrass areas on two separate days. One adult was observed on non-federal 

surface in the western portion of the South Porcupine tract’s general analysis 

area. The second individual was recorded in the southwestern portion of the 

South Porcupine tract’s wildlife survey area. Neither adult exhibited any 

defensive behavior, so both were presumed to be non-breeding birds. In early 

August 2005, a group of 15 to 20 mountain plovers was observed in the large 

(345.3 acres in size) prairie dog colony that overlaps both the North and South 

Porcupine tracts’ wildlife survey areas. That group was presumed to be staging 

briefly during the fall migration. No other plover sightings have ever been 

recorded in that colony, despite survey efforts targeting that location. 

Direct and Indirect Effects

Due to the similarit in their habitat associations, the direct and indirect effects 

to mountain plover in the general analysis areas for the North Hilight Field, 

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

LBA Tracts would be the same as those described above for the McCown’s 

longspur. 

Determination of Effect and Rationale – North, South and West Hilight Field 

LBA Tracts

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. USFS lands in the North, South, and West Hilight Field tracts’ 

general analysis areas are dominated by sagebrush communities that are not 

attractive to short-grass species such as the mountain plover. No individuals 

of this species have been documented in any of the three Hilight Field tracts’ 

general analysis areas, though limited potential habitat is present there. 

Documented alternative habitats for mountain plovers are present in portions 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-107 

of the general area that are more appropriate for this species and are not 

currently scheduled for mining disturbance. 

Determination of Effect and Rationale – North and South Porcupine LBA Tracts

Implementation of the Proposed Action or Alternative 2 may impact individuals 

but is not likely to cause a trend to federal listing or loss of viability within the 

planning area. Suitable plover habitat on USFS lands is limited primarily to a 

large prairie dog colony that overlaps the wildlife survey areas for both the 

North and South Porcupine LBA Tracts; no prairie dog colonies are present on 

USFS lands in either tract’s general analysis area. Only one mountain plover 

has been documented in the general analysis area for either Porcupine LBA 

tract in more than 20 years of annual monitoring. Documented alternative 

habitats for mountain plovers are present elsewhere in the region that is not 

currently scheduled for mining disturbance. 

H-3.2.29 Loggerhead shrike (Lanius ludovicianus)

Loggerhead shrikes breed from Washington, northern Alberta, central 

Saskatchewan, and southern Manitoba, south to California and Florida, and 

east to southwestern Minnesota, southern Wisconsin, southern Michigan, and 

Maryland. This species is a common summer resident throughout Wyoming 

(Cerovski et al. 2004). Shrikes prefer relatively open, heterogeneous habitats 

characterized by grasses and forbs of low stature interspersed with bare 

ground and shrubs or low trees with perches for hunting. This species will use 

a wide variety of trees and shrubs, particularly thick or thorny species, as 

nesting substrates and hunting perches (Prescott and Bjorge 1999). 

Although some shrike nests are used in subsequent years, fidelity to a nest site 

is limited. This species forages over relatively open habitats, feeding primarily 

upon arthropods, amphibians, small to medium-sized reptiles, small mammals, 

and birds (Yosef 1996). Shrikes may also feed upon road kill and carrion. This 

species is generally tolerant of human activity near a nest, although they will 

abandon if disturbed during egg-laying or early in incubation. The loggerhead 

shrike is declining in both number and overall range. Declines have been 

attributed to habitat loss and conversion, urbanization, pesticide 

contamination, and loss of insect prey as a result of pesticide use (Yosef 1996). 

Existing Conditions − North, South and West Hilight Field LBA Tracts

Loggerhead shrikes are common summer residents within the TBNG, though 

they are not often observed on or adjacent to USFS lands within the North, 

South and West Hilight Field LBA Tracts. Shrikes have occasionally been seen 

in the 1-mile perimeter wildlife survey area for the adjacent Black Thunder 

Mine, which overlaps significant portions of USFS lands in the South Hilight 

Field tract’s general analysis area. No actual shrike nests or recently fledged 

young have been documented on or near USFS lands in the general analysis 

areas for the North, South and West Hilight Field LBA Tracts, but this species 

could potentially nest in the general vicinity. Over time, most sightings have 

occurred in cottonwood-riparian corridors along primary streams in the general 
Appendix H 

H-108 Final EIS, Wright Area Coal Lease Applications 

Wright analysis area, or in taller greasewood stands. Neither habitat type is 

common in the general analysis areas for the North, South and West Hilight 

Field LBA Tracts. Shrikes have also been infrequently recorded perched on 

various fences or on overhead power lines at other nearby mines. Shrike 

foraging habitat is present throughout the North, South and West Hilight Field 

tracts’ general analysis areas, including USFS lands. As indicated, existing 

utility and fence lines currently provide good quality hunting perches. 

Existing Conditions − North and South Porcupine LBA Tracts

Loggerhead shrikes are common summer residents within the TBNG. This 

species has occasionally been observed in a small tree windbreak at an old 

homestead site located adjacent to the general analysis areas for the North and 

South Porcupine tracts on USFS lands in T.42N., R.71W., SW1⁄4SE1⁄4 Section 35 

(Figures H-4 and H-5). The presence of young indicates that shrikes have 

nested in that windbreak at least once. Few other trees or other nesting 

habitats are present elsewhere in the North and South Porcupine tracts’ 

wildlife survey areas, as described previously for the bald eagle. Shrikes have 

also been infrequently recorded perched on various fences or on overhead 

power lines elsewhere in the tracts’ wildlife survey areas. Shrike foraging 

habitat is present throughout the North and South Porcupine LBA Tracts’ 

general analysis areas, including USFS lands. As indicated, existing utility and 

fence lines currently provide good quality hunting perches. 

Direct and Indirect Effects − North, South and West Hilight Field LBA Tracts

Implementation of the Proposed Action or Alternatives could result in direct 

and indirect impacts to loggerhead shrikes, though such impacts would likely 

be uncommon. No known nest sites have been documented on or adjacent to 

USFS lands in the North, South and West Hilight Field tracts’ general analysis 

areas or elsewhere in the wildlife monitoring area for the adjacent Black 

Thunder Mine. The most probable direct impact would be the mortality of, or 

injury to, individuals foraging within or passing through the USFS lands due to 

collisions with future mine-related vehicles, or dispersal of foraging individuals 

due to active mining. 

The relatively slow movement of mining equipment and the noise associated 

with the activity would decrease direct impacts associated with vehicle 

collisions. As loggerhead shrikes are not especially common in the North, 

South and West Hilight Field tracts’ general analysis areas, indirect impacts 

would be limited despite the fragmentation, degradation, or loss of habitat in 

the short and mid-term. Any birds that would be displaced would be forced to 

travel to other locations with acceptable habitat. This could result in stress to 

individual birds, as well as potential decreased nesting effort and success. 

Prey numbers reduced by mining would be expected to rebound following 

reclamation due to generally high reproductive potential and prey tendencies to 

re-establish and adapt to disturbed and reclaimed areas. The locations of 

mine-related habitat disturbances and reclamation efforts would proceed 

incrementally throughout the expanded mining area as operations progressed. 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-109 

Additionally, this mining activity would not conflict with the current TBNG 

Plan, or any future objectives to manage the TBNG for this species. USFS 

Standards and Guidelines would offer additional protections for any active nest 

sites that may be present in the area. 

Direct and Indirect Effects − North and South Porcupine LBA Tracts

Implementation of the Proposed Action or Alternatives could result in direct 

and indirect impacts to loggerhead shrikes, though such impacts would likely 

be uncommon. Only one presumed nest site has been documented on or 

adjacent to USFS lands or elsewhere in the wildlife survey areas for the North 

and South Porcupine LBA Tracts; that site is just outside of the tracts’ general 

analysis areas, but is within the existing mine permit area for the North 

Antelope Rochelle Mine. The most probable direct impact would be the 

mortality of, or injury to, individuals foraging within or passing through the 

USFS lands due to collisions with future mine-related vehicles, or dispersal of 

foraging individuals due to active mining. 

The relatively slow movement of mining equipment and the noise associated 

with the activity would decrease direct impacts associated with vehicle 

collisions. As loggerhead shrikes are not especially common in the North and 

South Porcupine tracts’ general analysis areas, indirect impacts would be 

limited despite the fragmentation, degradation, or loss of habitat in the short 

and mid-term. Any birds that would be displaced would be forced to travel to 

other locations with acceptable habitat. This could result in stress to 

individual birds, as well as potential decreased nesting effort and success. 

Prey numbers reduced by mining would be expected to rebound following 

reclamation due to generally high reproductive potential and prey tendencies to 

re-establish and adapt to disturbed and reclaimed areas. The locations of 

mine-related habitat disturbances and reclamation efforts would proceed 

incrementally throughout the expanded mining area as operations progressed. 

Additionally, this mining activity would not conflict with the current TBNG 

Plan, or any future objectives to manage the TBNG for this species. USFS 

Standards and Guidelines would offer additional protections for any active nest 

sites that may be present in the area. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract may 

impact individuals but is not likely to cause a trend to federal listing or loss of 

viability within the planning area. Such impacts would be minimized by the 

lack of regular sightings and known nesting attempts, as well as the relative 

paucity of suitable nesting habitat on or adjacent to the USFS lands analyzed 

in this EIS and their surrounding region. Degradation, fragmentation, or loss 

of potential foraging habitat, reduction in prey populations, and potential 

collisions with vehicles may occur. Given the lack of birds recorded in the 

area, and the composition of the shrike’s prey base (insects, small mammals, 

etc.), impacts to shrikes would be minimal. USFS Standards and Guidelines 

would apply for active nests during the breeding season. Additionally, mining 
Appendix H 

H-110 Final EIS, Wright Area Coal Lease Applications 

the USFS lands would not conflict with the current TBNG Plan, or any future 

objectives to manage the TBNG for loggerhead shrikes.

H-3.2.30 Brewer’s sparrow (Spizella breweri)

The breeding range of the Brewer’s sparrow extends from southwestern Yukon, 

southern Alberta, and southwestern Saskatchewan, south (east of the 

Cascades and Sierras) to southern California, central Arizona, and northern 

New Mexico (Rotenberry et al. 1999). The Brewer’s sparrow is a common 

summer resident of the basin-prairie and mountain-foothills throughout 

Wyoming (Cerovski et al. 2004). Brewer’s sparrow is a sagebrush obligate 

species (Rotenberry et al. 1999). 

This species is an uncommon cowbird (Molothrus ater) host and typically builds 

a small cup nest low in sagebrush shrubs. Brewer’s sparrows prefer to nest in 

medium-sized (48-90 centimeters, or 19-35 inches) live sagebrush within 

relatively dense (26-42 percent canopy cover) stands (Walker 2004). Grass 

height and density are important factors for nest concealment. Although 

tolerant of human visitation, this species may abandon a nest if disturbed 

during the construction process. 

Brewer’s sparrows feed primarily on small insects and, to a lesser extent, seeds 

from grasses and forbs. Throughout areas where they have been surveyed, the 

species appears to have undergone and continues to undergo statistically 

significant declines (Rotenberry et al. 1999). Major threats to Brewer's sparrow 

populations are similar to those faced by other declining sagebrush-obligate 

species and include habitat conversion and fragmentation, invasion by nonnative plants, altered fire regimes, livestock overgrazing, conifer encroachment, 

energy development, and conversion to urban or residential housing (Walker 

2004). 

Existing Conditions − North, South and West Hilight Field LBA Tracts

Brewer’s sparrows are common summer residents within the TBNG and 

southern Campbell County (Cerovski et al. 2004). Breeding bird survey data 

from annual monitoring and baseline studies conducted for the Black Thunder 

Mine, as well as incidental observations over time, have shown that the 

Brewer’s sparrow is a common but limited breeder in the area. This species is 

commonly observed and has been recorded in sagebrush habitats in the 

general Wright analysis area during many years of surveys. Although no nests 

have been encountered in the general analysis areas for the North, South and 

West Hilight Field LBA Tracts, the presence and behavior (singing) of birds 

throughout spring and summer suggest that Brewer’s sparrows nest in the 

sagebrush stands common to those areas. 

Existing Conditions − North and South Porcupine LBA Tracts

Brewer’s sparrows are common summer residents within the TBNG and 

southern Campbell County (Cerovski et al. 2004). Breeding bird survey data 

from annual monitoring and baseline studies conducted for the North Antelope 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-111 

Rochelle Mine, and incidental observations over time, have shown that the 

Brewer’s sparrow is a common but limited breeder in the area. This species 

has been recorded during many years of surveys in sagebrush habitats within 

and near the North Porcupine LBA Tract, but no Brewer’s sparrows have been 

recorded in the grassland-dominated general analysis area for the South 

Porcupine LBA Tract. Although no nests have been encountered, the presence 

and behavior (singing) of birds throughout spring and summer suggest that 

Brewer’s sparrows nest in the sagebrush stands common to the tract’s general 

analysis area. 

Direct and Indirect Effects

Habitat loss, degradation, and fragmentation of sagebrush communities in the 

general analysis areas for the North Hilight Field, South Hilight Field, West 

Hilight Field and North Porcupine LBA Tracts would result from a variety of 

mining operations such as topsoil stripping, drilling, and reservoir 

construction, among others. Potential nesting and foraging habitat would also 

be fragmented by linear disturbances such as the construction, maintenance, 

and removal of roads, fences, power lines, and pipelines. Those disturbances 

could also create new travel corridors for mammalian predators that reside in 

or pass through the area. However, many such disturbances would occur 

within narrow corridors over relatively short distances, typically over a period 

of days. Additionally, those structures are often constructed immediately prior 

to the removal of similar features elsewhere in the area, often resulting in 

minimal or no net gain of new linear disturbances. All habitat disturbances 

and reclamation efforts would shift throughout the expanded area of mining 

operations. 

The use of existing roads, when possible, could minimize impacts related to 

traffic hazards and predator travel corridors. Increased activity and noise, 

especially during the nest initiation period, could inhibit nesting proximate to 

mining activities. Foraging could also be hindered within these areas, 

especially where active mining occurs. Additional infrastructure and activity 

associated with the expansion of the mine, in combination with other ongoing 

disturbances (e.g., CBNG operations), could displace Brewer’s sparrows from 

any historical use areas that might occur in the area. Those birds could 

potentially move into other sagebrush stands in the general vicinity, assuming 

they are not already occupied. 

Reclamation of disturbed areas will occur incrementally as mining is completed 

in a given portion of the mine and will eventually mitigate impacts to sagebrush 

habitats to some degree, though such efforts could take decades to benefit 

sagebrush obligates such as the Brewer’s sparrow. Impacts to sagebrush 

habitat on USFS lands could be further mitigated off-site by efforts to preserve 

and enhance such habitat on adjacent and nearby private lands, as described 

above. Standards and Guidelines for sagebrush habitats outlined in the TBNG 

Plan (USFS 2002, pages 1-18; Appendix D) would be implemented as 

necessary, and could serve to sustain regional populations of this sparrow. 

Those management guidelines would apply only to activities beyond the North 
Appendix H 

H-112 Final EIS, Wright Area Coal Lease Applications 

Hilight Field, South Hilight Field, West Hilight Field, and North Porcupine LBA 

Tracts. 

No impacts to Brewer’s sparrows are expected in the genral analysis area for 

the South Porcupine tract due to the documented lack of sparrows and 

suitable sparrow habitat in that area. 

Determination of Effect and Rationale

Implementation of the Proposed Action or Alternative 2 for each LBA tract may 

impact individuals but is not likely to cause a trend to federal listing or loss of 

viability within the planning area. Some habitat loss, degradation, and 

fragmentation would occur on and near USFS lands in the general analysis 

areas for the North Hilight Field, South Hilight Field, West Hilight Field, North 

Porcupine and South Porcupine LBA Tracts, along with potential impacts to 

individuals. However, the presence of large stands of sagebrush elsewhere in 

the general vicinity suggests that Brewer’s sparrows would remain viable within 

the TBNG for at least the short-term. Additionally, the Proposed Action or 

Alternative 2 for each LBA tract would not conflict with the current TBNG Plan 

(USFS 2002) or future objectives to manage the area for this species. 

Application of appropriate USFS Standards and Guidelines, successful 

reclamation efforts, and proper land management on adjoining lands could 

mitigate potential impacts, to some degree.

H-4.0 CUMULATIVE EFFECTS REGARDING SENSITIVE SPECIES 

Cumulative effects are defined under the National Environmental Policy Act of 

1969 (NEPA) process as the incremental impacts of past, present, and 

reasonably foreseeable future actions conducted by any entity (federal, state, 

private, and others). 

Cumulative short- and long-term disturbances to the species considered in this 

analysis arise from multiple sources that occur on federal and non-federal 

lands within the general Wright analysis area, including USFS lands within 

that area and neighboring lands. Those sources include direct and indirect 

impacts of mining (with an anticipated life of at least 20 more years), extraction 

of conventional oil and gas and CBNG reserves, road development and 

relocation, construction and removal of power lines and pipelines, grazing 

(livestock and wildlife), drought, occupied residences, and hunting and 

trapping. Those activities have occurred in the vicinity of the general Wright 

analysis area in the past and most are expected to continue at similar levels, at 

least for the near future. 

Coal mining and CBNG development are expected to occur at an increased rate 

in the future. Other reasonable and foreseeable developments within the area 

could potentially include the construction of a coal-fired power plant and new 

rail lines for transporting coal. Both mining and oil and gas development 

activities have requirements for reclamation of disturbed areas as resources are 

depleted. However, those standards are dramatically different in both 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-113 

implementation and monitoring. As new areas of disturbance related to energy 

extraction activities are added, areas that have been mined out will be restored 

and reclaimed. Similarly, oil and gas well sites will be reclaimed once they are 

depleted and abandoned. 

No critical habitat for any USFS Sensitive Species has been delineated in the 

general Wright analysis area (including the USFS lands). Any habitat losses 

that do occur will eventually be mitigated for most species by reclamation with 

native seed mixes, which may improve habitat quality by reducing the presence 

of non-native plants (e.g., crested wheatgrass) within the area. Leasing lands 

within the general Wright analysis area will not conflict with the current TBNG 

Plan, or any future objectives to manage USFS lands and provide habitat for 

sensitive species. Because effects of disturbance on sensitive species 

inhabiting the same habitat types would be the same, cumulative impacts are 

analyzed according to species’ main habitat associations. 

H-4.1 Species Associated Primarily With Short Grasses or Prairie Dog 

Colonies 

Five evaluated species are strongly associated with prairie dog colonies or other 

areas with short, sparse vegetation: the black-tailed prairie dog, mountain 

plover, burrowing owl, chestnut-collared longspur, and McCown’s longspur. 

Cumulative impacts to these habitats and associated species will largely result 

from activities that would decrease occupied black-tailed prairie dog colonies 

within the area. As the prairie dog is the most common sensitive species in the 

area, it has the most potential to be affected by cumulative impacts from the 

Proposed Actions and Alternatives. Specifically, individuals could be killed or 

injured by activities in or near prairie dog colonies, and habitat would be lost 

until reclamation takes place. Incremental habitat disturbance and freshly 

turned soil in stripped and reclaimed areas would allow escaping or dispersing 

animals to create new burrows, and thus maintain a presence in the area. 

Burrowing owls and mountain plovers rely heavily on prairie dogs to provide 

and maintain suitable nesting habitat. Longspurs are also often found in 

prairie dog colonies in the overall general Wright analysis area. Therefore, any 

activities that jeopardize prairie dogs will also affect those species to some 

degree. Although impacts would occur on approximately 148.6 acres of prairie 

dog colonies that are currently located within 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 (108.1 acres 

of which occur on or within one-quarter-mile of USFS lands), the presence of 

approximately 1,490.6 total acres of colonies that currently exist on and within 

2 miles of the six combined general analysis areas would minimize negative 

impacts to those three species. Despite their strong association with prairie 

dogs, species such as burrowing owls, mountain plovers, and longspurs can all 

utilize short-grass habitats other than prairie dog colonies. However, all of 

those avian species would benefit from the presence of undisturbed prairie dog 
Appendix H 

H-114 Final EIS, Wright Area Coal Lease Applications 

colonies surrounding the six combined general analysis areas, including USFS 

lands, as well as other short-form vegetative communities. 

Despite the presence of additional habitat outside the six combined general 

analysis areas, cumulative effects expected for these five species would include 

habitat destruction, alteration, and fragmentation. As indicated, some 

individuals may be killed or injured by vehicles or equipment, collisions with 

fences, and poisoning or shooting. Predation rates on some species may 

increase due to the creation of favorable habitats, perches, or travel corridors 

for avian or mammalian predators. Nests of avian species will likely be 

destroyed or compromised by human disturbances or activities, and 

individuals (especially avian species) will likely be displaced from existing 

territories. Such occurrences would increase competition for available adjacent 

territories. If those areas have already reached carrying capacity, the result 

would be intra-specific competition followed by nutritional stress, decreased 

fecundity, and/or mortality. 

H-4.2 Mixed Sagebrush and/or Mid-grass Species 

Mid-grass parcels interspersed with sagebrush commonly occur in the general 

Wright analysis area, including USFS lands. Mining in the area would impact 

the sagebrush shrubland/mixed prairie grassland habitats that are present. 

Evaluated species for mixed grassland habitats included the swift fox, longbilled curlew, and ferruginous hawk. Cumulative impacts to those species 

would be the similar to those described above. However, as all of these species 

have the capacity of utilizing a variety of habitats, including prairie dog 

colonies and short-grass areas, beyond the overall general Wright analysis 

area, the cumulative effects would be somewhat lessened. 

Regarding the swift fox and ferruginous hawk, the fragmentation, alteration, or 

destruction of suitable habitats would also destroy denning and shelter sites or 

nest sites, respectively, and would potentially facilitate inter-specific 

competition for available prey bases. Both the swift fox and hawks using these 

habitats would also be negatively affected by activities that reduce prey 

availability. The impacts would be partially mitigated by the existing presence 

of alternate denning and nesting sites in the area that would not be disturbed 

by the Proposed Actions or Alternatives. The greatest threat to mixed 

sagebrush and/or mid-grass species would arise from the creation of habitat 

patches that are too small to attract individuals or sustain viable breeding 

pairs or populations. 

H-4.3 Sagebrush Obligates 

Species associated with sagebrush habitats that could occur in or near the 

general Wright analysis area and associated USFS lands include the Greater 

sage-grouse and Brewer’s sparrow. However, more than 25 consecutive years 

of monitoring have demonstrated that the sagebrush stands within most of this 

area are insufficient in size and structure to provide optimum sage-grouse 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-115 

habitat. However, due to the total combined acreage of big sagebrush 

shrubland that would be disturbed by mining the six combined general 

analysis areas (approximately 18,330 total acres), sage-grouse would likely 

experience cumulative impacts by the Proposed Actions or Alternatives. 

Similarly, the relatively small and somewhat sparse shrub stands within the 

general analysis areas for these six LBA tracts provide limited, marginal 

nesting habitat for Brewer’s sparrows. 

Given the widespread occurrence of sagebrush habitat within the overall 

general Wright analysis area (including USFS lands), cumulative impacts to 

sagebrush habitats and their associated species would occur as a result of 

leasing and mining these six LBA tracts under the Proposed Actions or 

Alternatives. Direct impacts would likely be limited to the injury or mortality of 

individual sage-grouse and Brewer’s sparrows, or their nests or young. 

Indirect impacts to the sagebrush-dependant species could entail changes in 

their presence or distribution as the quantity and quality of existing sagebrush 

stands in the area are diminished due to habitat fragmentation, alteration, 

degradation, and conversion of shrubland communities during ongoing and 

new mining operations. 

Any displaced individuals would have to compete for the limited availability of 

adjacent territories, and if those areas have reached carrying capacity, intraspecific competition may result in nutritional stress, decrease in fecundity, or 

mortality to affected individuals. Sagebrush habitats lost to mining would be 

mitigated, as required. However, those efforts would not likely be able to keep 

pace with, or compensate for, the on-going loss or alteration of sagebrush 

habitat within the area, as sagebrush stands can take two or three decades to 

re-establish. 

H-4.4 Tree or Wetland/Aquatic Species 

Within the general Wright analysis area, trees are found primarily in a few 

shelterbelts/windbreaks planted adjacent to widely scattered ranching 

facilities. Very few other trees are present due to the lack of water and suitable 

habitats. Approximately 602 acres of wetlands and other waters of the U.S. 

have been identified within the combined general analysis areas for these six 

LBA tracts, which provide wetland/aquatic habitats on and near USFS lands. 

Species associated with treed or aquatic habitats that could occur in or near 

those areas include the loggerhead shrike and northern leopard frog, though 

the latter is less likely to be present. Cumulative effects to shrikes would be 

similar, but slightly greater than, those for non-raptor avian species within 

mixed mid-grass and shrub habitats. The increased intensity of effects would 

be due to the overall lack of trees (potential nest sites), and thus the limited 

alternate habitats as trees are lost to mining. Mitigating that impact is the fact 

that detailed tree inventories would be conducted prior to all mining 

disturbances, as required by state and federal agencies, so that every tree that 

is lost to mining would be replaced during final reclamation. High intensity 

activity and noise when mining is most proximate along stream corridors where 
Appendix H 

H-116 Final EIS, Wright Area Coal Lease Applications 

native trees occur could deter shrikes from nesting in the area, at least until 

they acclimated to the disturbance. All trees destroyed by mining will be 

replaced during reclamation, but it will take decades for them to mature to 

their current stature. 

Northern leopard frogs are not prevalent within either the general Wright 

analysis area or associated USFS lands, and therefore have little potential to be 

affected by cumulative impacts from the Proposed Actions and Alternatives. 

Wetland and aquatic habitats for northern leopard frogs are considered very 

poor to unsuitable on USFS lands within the combined general analysis areas 

for these six LBA tracts, and no frog sightings have been recorded on USFS 

lands within these areas. If this species is present in the future, individuals 

could be killed or injured by activities in proximity to aquatic habitats. 

Dewatering or degradation of breeding habitats could kill eggs, tadpoles, or 

over-wintering adults, as well as increase predation rates on adults and eggs. 

Conversely, the creation and augmentation of aquatic habitats for 

sedimentation ponds and other purposes could maintain and possibly increase 

local northern leopard frog populations. There would be no net loss of 

jurisdictional wetlands, as they would be restored under the jurisdiction of the 

U.S. Corps of Engineers (refer to Section 3.7 of this EIS). Non-jurisdictional 

and functional wetlands would be restored in accordance with the 

requirements of the surface landowner or as required by WDEQ/LQD. 

Overall, despite the death, injury, and displacement of some animals, the 

cumulative impacts associated with the Proposed Actions or Alternatives are 

not expected to significantly reduce the size or viability of populations of any of 

the USFS Region 2 Sensitive Species. Many of these species have not been 

documented within the general Wright analysis area or associated USFS lands 

over the last 25 years, have already been displaced from those areas, or have 

remained present despite the ongoing mine and non-mine activities in and near 

those areas. 

H-5.0 TBNG PLAN COMPLIANCE 

The Proposed Actions and Alternatives are considered to be in compliance with 

Grassland-wide, Geographic Area, and Management Area Standards and 

Guidelines for wildlife (including regionally sensitive species, and Management 

Indicator Species) detailed in the Grassland Plan (USFS 2002). 

H-6.0 REQUIRED MITIGATION AND RECOMMENDED MONITORING 

To help protect USFS Region 2 Sensitive Species, the mine operator will notify 

the USFS District Ranger, Douglas, Wyoming, if sensitive species nests or dens, 

in addition to those identified in the Biological Assessment (Appendix G of this 

EIS), are located during mining. Future surveys for any USFS Region 2 

Sensitive Species could be conducted in response to requests from the USFS 

Douglas District Ranger. This would allow assessments of how, and if, 

implementation of the TBNG Plan is benefiting these species. 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-117 

Mitigation measures designed to reduce impacts to wildlife that are required by 

the Surface Mining Control and Reclamation Act (SMCRA) and state law 

include: 

• Using raptor-safe power lines; 

• Designing fences to permit wildlife passage; 

• Creating artificial raptor nest sites; 

• Relocating raptor nests and taking other action to maintain active 

nesting pairs; 

• Restoring pre-mining topography to the maximum extent possible; 

• Planting a diverse mixture of grasses, forbs, and shrubs in configurations 

beneficial to wildlife; and 

• Building and maintaining sediment control ponds or other sediment 

control devices during mining. 

To further minimize negative impacts to faunal species of concern, the USFWS 

requires additional species-specific protective measures, as well as targeted 

monitoring and mitigation plans for certain Region 2 Sensitive Species. 

H-7.0 USFS MANAGEMENT INDICATOR SPECIES EVALUATION 

H-7.1 Introduction 

Species that have been identified by the Regional Forester as Management 

Indicator Species (MIS) must be considered for the Wright Area Coal Lease 

Applications because the general analysis areas for North Hilight Field, South 

Hilight Field, West Hilight Field, North Porcupine, and South Porcupine LBA 

Tracts include federal lands administered by the USFS. There is no USFS 

administered surface within the general analysis area for the West Jacobs 

Ranch LBA Tract. The purpose of this section of this Appendix is to provide 

information about the potential environmental effects that leasing the USFS 

administered lands would have on USFS TBNG Forest Plan MIS. 

H-7.2 Species Evaluated and Rationale 

A Management Indicator Species is defined as a “plant or animal species or 

habitat components selected in a planning process used to monitor the effects 

of planned management activities on populations of wildlife and fish, including 

those that are socially or economically important” (USFS 2002). MIS are 

selected to serve as barometers for species diversity and viability. These 

species are monitored over time to assess the effects of management activities 

on their populations and habitat, and the populations of other species with 

similar habitat needs. MIS for the TBNG are identified by Geographic Area. In 

accordance with the TBNG Plan (USFS 2002), the greater sage-grouse was 

selected as the MIS to be evaluated for this project (as defined for the Hilight 

Bill Geographic Area). 
Appendix H 

H-118 Final EIS, Wright Area Coal Lease Applications 

For detailed sage-grouse habitat and population information, please see 

Section 3.10.5 in this EIS. This MIS evaluation and the Biological Assessment 

(Appendix G) of this EIS analyzes and discloses potential effects to wildlife if 

lands within the general Wright analysis area are leased and mined. The USFS 

Douglas Ranger District biologists have reviewed Section 3.10 and the BA in 

this EIS. 

In addition to the information provided in this analysis, a full Biological 

Assessment and Biological Evaluation (BABE) document is being prepared for 

review by USFS Douglas Ranger District biologists as part of future permitting 

actions. Among other things, that document will provide supplemental 

information regarding local and regional population trends for the MIS (greater 

sage-grouse). The approved BABE will be available for public view at the 

Douglas Ranger District office. 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-119 

H-8.0 REFERENCES AND LITERATURE CITED 

Baxter, G.T. and M.D. Stone, 1980, Amphibians and reptiles of Wyoming. 

Wyoming Game and Fish Department, Lander, Wyoming. 

Bechard, M.J. and J.K. Schmutz, 1995, Ferruginous hawk (Buteo regalis). In

The Birds of North America, No. 172 (A. Poole and F. Gill, Eds.), The 

Academy of Natural Sciences, Philadelphia, PA, and The American 

Ornithologists’ Union, Washington, D.C. 

Beske, A.E., 1994, 1994 raptor nest survey on the Thunder Basin National 

Grassland. USFS, Douglas Ranger District, Medicine Bow National 

Forest. Unpublished report. 

Brown, K.G. and K.M. Clayton, 2004, Ecology of the Greater sage-grouse 

(Centrocercus urophasianus) in the coal mining landscape of Wyoming’s 

Powder River Basin. Final Technical Report prepared by Thunderbird 

Wildlife Consulting, Gillette, Wyoming. 

Bureau of Land Management (BLM), 2002, BLM Wyoming Sensitive Species 

Policy and List September 20, 2002, available on the Internet as of July 

2008: 

<http://www.blm.gov/pgdata/etc/medialib/blm/wy/wildlife.Par.9226.

File.dat/02species.pdf>. 

, 2008, West Antelope II Coal Lease Application Final Environmental 

Impact Statement. U.S. Department of the Interior, Bureau of Land 

Management, Casper Field Office, Casper, Wyoming, December 2008. 

Byer, T., 2001, Biological assessment and biological evaluation report for 

Devon Energy Production Company. USFS, Douglas Ranger District. 

Cerovski, A.O., M. Grenier, B. Oakleaf, L. Van Fleet, and S. Patla, 2004, Atlas 

of Birds, Mammals, Amphibians, and Reptiles in Wyoming. Wyoming 

Game and Fish Department Nongame Program, Lander. 

Connelly, J.W., W.L. Wakkinen, A.D. Apa, and K.P. Reese, 1991, Sage grouse 

use of nest sites in southeastern Idaho. J. Wildl. Manage. 55:521-524. 

Connelly, J.W., S.T. Knick, M.A. Schroeder, and S.J. Stiver, 2004, 

Conservation Assessment of Greater Sage-grouse and Sagebrush 

Habitats. Western Association of Fish and Wildlife Agencies. 

Unpublished Report, Cheyenne, Wyoming. 

Cotterill, S.E., 1997, Status of the swift fox (Vulpes velox) in Alberta. Alberta 

Environmental Protection, Wildlife Status Report No. 7, Edmonton, AB., 

Canada. 
Appendix H 

H-120 Final EIS, Wright Area Coal Lease Applications 

Dechant, J.A., M.L. Sondreal, D.H. Johnson, L.D. Igl, C.M. Goldade, P.A. Rabie, 

and B.R. Euliss, 2003a, Effects of management practices on grassland 

birds: Long-billed Curlew (Version 12 Dec 2003). Northern Prairie 

Wildlife Research Center, Jamestown, ND. Available from website on the 

Internet: <http://www.npwrc.usgs.gov/resource/literatr/grasbird/lbcu/

lbcu.htm>. 

______, 2003b, Effects of management practices on grassland birds: Chestnutcollared Longspur (Version 28 May 2004). Northern Prairie Wildlife 

Research Center, Jamestown, ND. Available from website on the 

Internet: <http://www.npwrc.usgs.gov/resource/literatr/grasbird/cclo/

cclo.htm>. 

______, 2003c, Effects of management practices on grassland birds: McCown’s 

Longspur (Version 12 Aug 2004). Northern Prairie Wildlife Research 

Center, Jamestown, ND. Available from website on the Internet: 

<http://www.npwrc.usgs.gov/resource/literatr/grasbird/mclo/

mclo.htm>. 

______, 2003d, Effects of management practices on grassland birds: Mountain 

Plover (Version 12 Dec 2003). Northern Prairie Wildlife Research Center, 

Jamestown, ND. Available from website on the Internet: 

<http://www.npwrc.usgs.gov/resource/literatr/grasbird/mopl/

mopl.htm>. 

Drut, M.S., J.A. Crawford, and M.A. Gregg, 1994, Brood habitat use by sage 

grouse in Oregon. Great Basin Naturalist 54:170-176. 

Gregg, M.A., J.A. Crawford, M.S. Drut, and A.K. DeLong, 1994, Vegetational 

cover and predation of sage grouse nests in Oregon. J. Wildl. Manage. 

58:162-166. 

Grenier, Martin, 2003, An Evaluation of Black-footed Ferret Block Clearances 

in Wyoming: Completion Report. Wyoming Game and Fish Department. 

Lander, Wyoming. 16pp. 

Hill, D.P., 1998, Status of the long-billed curlew (Numenius americanus) in 

Alberta. Alberta Environmental Protection, Wildlife Status Report No. 16, 

Edmonton, AB. 

Hill, D.P. and L.K. Gould, 1997, Chestnut-collared longspur (Calcarius 

ornatus). In The Birds of North America, No. 288 (A. Poole and F. Gill, 

Eds.), The Academy of Natural Sciences, Philadelphia, PA, and The 

American Ornithologists’ Union, Washington, D.C. 

Johnsgard, P.A., 1990, Hawks, eagles, and falcons of North America. 

Smithsonian Institution Press, Washington, D.C. 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-121 

Klute, D.S., L.W. Ayers, M.T. Green, W.H. Howe, S.L. Jones, J.A. Schaffer, S.R. 

Sheffield, and T.S. Zimmerman, 2003, Status Assessment and 

Conservation Plan for the Western Burrowing Owl in the United States. 

U.S. Department of Interior, Fish and Wildlife Service, Biological 

Technical Publication FWS/BTP-R6001-2003, Washington, D.C. 

Knopf, F.L., 1996, Mountain plover (Charadrius montanus). In The Birds of 

North America, No. 211 (A. Poole and F. Gill, Eds.), The Academy of 

Natural Sciences, Philadelphia, PA, and The American Ornithologists’ 

Union, Washington, D.C. 

McKee, Gwyn, 2006, Nest Success and Survival of the Greater Sage-grouse 

(Centrocercus urophasianus) at the North Antelope Rochelle Surface Coal 

Mine in 2006. 2006 Summary Report. 

______, 2007, Personal communication with Gwyn McKee, wildlife biologist with 

Thunderbird-Jones & Stokes. 

NatureServe, 2007, NatureServe Explorer: An online encyclopedia of life [web 

application]. Version 4.0. NatureServe, Arlington, Virginia. Available 

from website on the Internet as of January 2007: 

<http://www.natureserve.org/explorer>. 

Naugle, D.E., K.E. Doherty, and B.L. Walker, 2006, Sage-grouse winter habitat 

selection and energy development in the Powder River Basin: Completion 

Report. Available from website on the Internet as of March 2009: 

<http://www.voiceforthewild.org/SageGrouseStudies/

Winter_habitat_report.pdf>. 

North Antelope Rochelle Mine, 2007, 2006 Annual Wildlife Monitoring Report, 

submitted to WDEQ/LQD. Prepared by Thunderbird-Jones & Stokes. 

On file with WDEQ/LQD in Cheyenne, Wyoming. 

Northeast Wyoming Sage-grouse Working Group (NWSGWC), 2006, Northeast 

Wyoming Sage-grouse Conservation Plan. August 15. Available from 

website on the Internet as of December 2007: 

<http://gf.state.wy.us/wildlife/wildlife_management/sagegrouse/

Northeast/NEConsvPlan.pdf>. 

Orpet, J., 2007, Personal communication with Jim Orpet, wildlife biologist with 

Intermountain Resources. 

Powder River Coal, LLC (PRC), 2009, North Antelope Rochelle Mine Permit 

Application, WDEQ/LQD Surface Mine Permit 569-T7, approved July 28, 

2009. On file at WDEQ/LQD office in Cheyenne, Wyoming. 
Appendix H 

H-122 Final EIS, Wright Area Coal Lease Applications 

Prescott, D.R.C, and R.R. Bjorge, 1999, Status of the loggerhead shrike (Lanius 

ludovicianus) in Alberta. Alberta Environment, Wildlife Status Report No. 

24, Edmonton, AB, Canada. 

Roche, Kathy, 2009, Personal communication between K. Roche, Forest 

Ecologist and North Zone Botanist, Medicine Bow Routt National Forest 

and Thunder Basin National Grassland, Laramie Ranger District, 

Laramie, Wyoming, and S. Bucklin, BLM Environmental Specialist, BLM 

High Plains District Office, Casper, Wyoming, January 28. 

Rotenberry, J.T., M.A. Patten, and K.L. Preston, 1999, Brewer’s sparrow 

(Spizella breweri). In The Birds of North America, No. 390 (A. Poole and F. 

Gill, Eds.), The Academy of Natural Sciences, Philadelphia, PA, and The 

American Ornithologists’ Union, Washington, D.C. 

Schmutz, J.K., 1989, Hawk occupancy of disturbed grasslands in relation to 

models of habitat selection. Condor 91:362-371. 

Schroeder, M.A, J.R. Young, and C.E. Braun, 1999, Sage grouse (Centrocercus 

urophasianus). In The Birds of North America, No. 425 (A. Poole and F. 

Gill, Eds.) The Birds of North America, Inc., Philadelphia, PA. 

Thunder Basin Coal Company (TBCC), 2005, Black Thunder Mine Permit 

Application, WDEQ/LQD Surface Mine Permit 233-T7, approved 

November 1, 2005. On file at WDEQ/LQD offices in Cheyenne and 

Sheridan, Wyoming. 

U.S. Department of Agriculture-Forest Service (USFS), 2002, Updated Land and 

Resource Management Plan for the Thunder Basin National Grassland, 

Medicine Bow-Routt National Forest, Rocky Mountain Region. USDA 

Forest Service, Medicine Bow-Routt National Forest, Rocky Mountain 

Regional Office, Denver, Colorado. 

______, 2003, Thunder Basin National Grassland Wildlife GIS Data and Map. 

Unpubl. 

______, 2007, Species Conservation Project: Region 2 Regional Forester’s 

Sensitive Species – Rocky Mountain Region. Available from website on 

the Internet as of January 2009: <http://www.fs.fed.us/r2/projects/

scp/sensitivespecies/index.shtml>. 

U.S. Department of Interior-Fish and Wildlife Service (USFWS), 1989, Blackfooted ferret survey guidelines for compliance with the endangered 

species act. USFWS, Denver, Colorado, and Albuquerque, New Mexico. 

April 1989. 
Appendix H 

Final EIS, Wright Area Coal Lease Applications H-123 

Wagner, G., 1997, Status of the northern leopard frog (Rana pipiens) in Alberta. 

Alberta Environmental Protection, Wildlife Status Report No. 9, 

Edmonton, AB, Canada. 

Walker, B., 2004, Effects of management practices on grassland birds: Brewer's 

Sparrow. Northern Prairie Wildlife Research Center, Jamestown, ND. 

Jamestown, ND: Northern Prairie Wildlife Research Center Online. 

Available from website on the Internet: 

<http://www.npwrc.usgs.gov/resource/literatr/grasbird/brsp/brsp.htm

(Version 12 Aug 2004)>. 

White, C.M. and T.L. Thurow, 1985, Reproduction of ferruginous hawks 

exposed to controlled disturbance. The Condor 87:14-22. 

With, K.A., 1994, McCown’s longspur (Calcarius mccownii). In The Birds of 

North America, No. 96 (A. Poole and F. Gill, Eds.), The Academy of 

Natural Sciences, Philadelphia, PA, and The American Ornithologists’ 

Union, Washington, D.C. 

Yosef, R., 1996, Loggerhead shrike (Lanius ludovicianus). In The Birds of North 

America, No. 231 (A. Poole and F. Gill, Eds.), The Academy of Natural 

Sciences, Philadelphia, PA, and The American Ornithologists’ Union, 

Washington, D.C. 
APPENDIX I 

DRAFT EIS COMMENT LETTERS, BLM RESPONSES, 

AND HEARING SUMMARY 

































































































































































1 

BLM Responses to Comment Letters Received 

Regarding the Wright Area Draft EIS 

Comment Response 1: Please review Section 1.2; we have clearly stated the purpose and need 

of the EIS and the proposed action. Approximately 92 percent of the total coal that is mined in 

the U.S. is used for generating electricity. Currently, coal-fired electric generating plants are the 

cornerstone of the nation’s central power configuration. Electricity is important to the country’s 

security and economy. Many other states rely on Wyoming for coal reserves in view of the fact 

that Wyoming coal is used to generate electricity in 36 states. 

We revised the Final EIS to include additional information regarding the projected electric 

generation portfolio of the United States. Please see Section 4.2.14.4. Studies have indicated 

that 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 until at least 

2035. 

As described in Section 4.2.14.4 of the EIS, the key determinant of energy consumption is 

population. The population in the U.S. has increased by about 20 percent and energy 

consumption by a comparable 18 percent since 1990, with variations in energy use per capita 

depending on factors such as weather and the economy. As human population and activities 

have increased, carbon-based fuels have been used to provide for these additional energy needs. 

To meet the nationwide consumer demand and requirement for energy, coal is burned in power 

plants to produce electricity. Many countries are even more reliant on coal for their energy 

needs than is the United States. As stated in the EIS, more than 70 percent of the electricity 

generated in China and India comes from coal. 

As described throughout Chapter 1, the purpose of this EIS is to analyze and disclose the 

potential effects to the natural and human environment from the proposed leasing of six 

maintenance tracts of federal coal in the Wright Area of the Wyoming Powder River Basin. 

Although leasing these tracts would not authorize mining operations on those lands, the EIS 

evaluates the potential impacts of mining the tracts because mining is a logical consequence of 

issuing a lease for a maintenance tract of federal coal. The EIS presents BLM’s analysis of 

environmental impacts under the authority of NEPA and associated rule and guidelines. 

The BLM is a multiple use land management agency that also manages federal minerals, 

including federal coal reserves. BLM administers public lands and minerals under the policy and 

practice of multiple use management. The Bureau's responsibility for multiple use involves 

balancing an extensive diversity of resources and the potential use or development of those 

resources and lands as administered by BLM. Managing vast and varied resources under this 

mandate is a complex undertaking, particularly since the priorities set for one management 

activity may conflict with the priorities of another. For both BLM and FS administered public 

lands, the management, constraints, limitations, and prescriptions for those lands are developed 

through the land use planning process. The public is encouraged and invited to participate 

throughout those processes. The EIS identifies and explains that the proposed actions and 

alternatives are consistent with the BLM Buffalo Field Office and USFS land use plans. 
2 

Comment Response 2: Please review the BLM National Environmental Policy Act (NEPA) 

Handbook H-1790-1. As described in the handbook, proposed federal projects that are 

externally generated actions, like coal lease applications filed by a proponent, include the 

formulation of a range of alternatives encompassing denial of the request (No Action), approval 

of the request as proposed by the proponent, and approval of the request with modifications as 

made by BLM to the proponent’s proposal. As exemplified in H-1790-1, the Wright Area EIS 

range of alternatives carry out the intent and spirit of NEPA. 

For the alternatives and their descriptions, please see Chapter 2 in the EIS. This chapter contains 

the full range of alternatives in response to the coal lease applications there were submitted by 

the lease applicants. Chapter 2 describes the proposed action and a number of alternatives for 

each of the six lease by application (LBA) tracts being evaluated in this EIS. 

Please review Section 2.7.1 for the new mine start alternative. As stated in the EIS, this 

alternative was not analyzed in detail because a new mine start is highly unlikely at this point in 

time for a number of reasons including initial capital expenses, mine startup costs, obtaining new 

permits, etc. Please review the EIS, all of these are clearly discussed and explained. 

As explained in Section 2.7.2, the delaying the sale alternative was not analyzed in detail because 

it would not produce substantially different impacts from other alternatives already analyzed in 

detail. 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. 

The EIS is not intended to be an environmental analysis of the numerous technologies that are 

capable of producing electricity. As stated throughout the Wright Area EIS, the EIS was 

prepared pursuant to the NEPA and other applicable regulations and statutes to address possible 

environmental and socioeconomic impacts that could result from the Wright Area coal lease 

applications. 

As stated in Chapter 4, ongoing scientific research is working to identify the potential impacts of 

greenhouse gases (GHG) on global climate. Our analysis recognizes that the addition of noncarbon fueled electric generation sources could reduce future GHG emissions. Further, the 

addition of alternate sources of electric generation would potentially help to conserve carbonbased fuels and provide a broader portfolio of electric sources. However, the environmental 

effects and impacts associated with the wide variety of renewable electric generation 

technologies are well beyond the scope of this EIS. Individual projects associated with 

alternative electric generation technologies would be evaluated separately under their own NEPA 

process as each project is proposed and would be analyzed on their own merit. In order for an 

alternative energy project to come to fruition, there must first be a valid proponent to propose, 

support, and fund the project. 

Comment Response 3: The BLM does not permit, nor authorize, mining operations and does 

not have the authority to regulate mining activities nor mitigate air quality impacts. As discussed 

in detail in Section 1.3 of the EIS, WDEQ is authorized by the Secretary of the Interior to 
3 

regulate surface coal mining operations and surface effects of mining on federal and non-federal 

lands within Wyoming. 

Air pollution is controlled by state and federal air quality regulations and standards established 

under the federal Clean Air Act Amendments administered by EPA. The National Ambient Air 

Quality Standards (NAAQS) were established by EPA under the authority of the Clean Air Act 

(CAA). The Wyoming Ambient Air Quality Standard (WAAQS) for the PM10 annual, the SO2

annual, and 24-hour levels are more stringent than the National Ambient Air Quality Standard 

(NAAQS) and are enforced by WDEQ/AQD. State implementation plans are in place to ensure 

that proposed actions like coal mining comply with all associated air quality regulations and 

criteria. 

As disclosed in the EIS, large surface coal mines in the PRB have the potential to become 

particulate emission sources contributing to air quality degradation. As stated in Section 3.4.2.3 

of the EIS, the WDEQ/AQD requires the Wyoming Powder River Basin mines to collect air 

quality data. The eastern Powder River Basin is one of the most intensely monitored areas in the 

world for air quality. As explained throughout the EIS, WDEQ/AQD has, by statute, the 

authority and responsibility to require mitigation for air quality impacts. 

WDEQ/AQD issues permits to mine coal under the authority delegated to them by the EPA 

under the CAA. In Wyoming, mines in the PRB are permitted under the CAA as regulated 

emission sources. Permits issued by the WDEQ identify mitigation measures that the permittee 

must implement in order to comply with the permit. These measures, currently in place at the 

Wright Area mines and typically in place at other PRB mines, are described in Section 3.4.2 of 

the EIS. WDEQ/AQD is authorized to condition permits as necessary for mitigation. 

WDEQ/AQD will not permit activity that is out of compliance with the WAAQS. 

Ozone is included in the EIS discussion regarding NOX emissions since NOX is one of the main 

components involved in the formation of ground level ozone. As previously discussed, EPA is 

the agency chiefly responsible for national air quality regulations and authorities concerning 

ozone, CO2, and the development of national standards. BLM does not govern air quality 

standards and does not issue air quality permits. 

The EIS evaluates the Prevention of Significant Deterioration (PSD) and it is addressed in 

Chapter 3 and 4. Section 169 of the Clean Air Act addresses visibility protection. On June 15, 

2005, EPA issued final amendments to its July 1999 Regional Haze Rule. These amendments 

apply to the provisions of the rule and require emission controls known as Best Available 

Retrofit Technology, or BART, for industrial facilities emitting air pollutants that reduce 

visibility. As explained in the EIS, the nearest Class I PSD areas to the general analysis area for 

this EIS are Wind Cave National Park (about 100 miles east) and the Badlands Wilderness Area 

(about 150 miles east). 

The EIS has been revised to include additional information regarding air quality data and 

visibility monitoring. Please see Section 3.4.4.1.1, 3.4.4.1.2, 3.4.4.1.3, Table 3-12, Figure 3-19, 

and Section 4.2.3 for analyses regarding air quality, visibility, the Regional Haze Rule, and 

AQRVs. The EIS clarifies that the cumulative air quality modeling did not separate PSD 
4 

increment-consuming sources from those that did consume increment. The modeling was 

designed to include both known and predicted sources, regardless of regulatory status. Again, 

BLM has no jurisdiction over the air quality permitting process. 

For questions or concerns related to permitting procedures in Wyoming, please contact WDEQ, 

the governing agency of the coal mine permit process. 

Comment Response 4: Please refer to Section 3.3.2.1.2 in the EIS regarding methane, or 

CBNG. BLM recognizes that CBNG is a valuable energy resource and BLM policy encourages 

the development of this resource, where economically feasible, in advance of coal mining. The 

analysis in the EIS clarifies that CBNG has been commercially produced in the PRB since 1989. 

The EIS discloses the release of methane as a result of mining, and that coal seams were already 

substantially depleted of CBNG in the vicinity of the mines in 2000. By 2005, drilling activity in 

the areas adjacent to the coal mines declined significantly. There has been little recent interest in 

drilling CBNG in this area. 

The climate change and global warming analysis in Section 4.2.14.1 of the EIS identifies 

methane as a greenhouse gas (GHG) emission. The EIS describes the potential release of 

methane, both as a direct result of mining and the cumulative release of methane from activities 

in the PRB. Section 3.18.2 of the EIS contains estimates of GHG emissions resulting from 

specific mine operations at the three applicant mines as projected under the proposed actions and 

alternatives over the life of the actions. The estimates reflect mining and oil and gas activity 

based on national data scaled to activity in the PRB region. 

Surface mines release methane to the atmosphere as the coal is exposed and loaded in small 

diluted volumes. Flaring is not feasible with surface mining operations since flaring requires the 

gas to be concentrated in quantities sufficient to burn, as might be possible in an underground 

mine. We did recognize that large volumes of methane have been put to beneficial use as a 

result of CBNG (coalbed natural gas) recovery in advance of mining, and that by the time the 

coal is mined, methane in commercial quantities has been depleted.

Comment Response 5: The information provided in your comment has been considered in the 

preparation of the EIS. Please review our analyses and disclosure of impacts regarding 

greenhouse gas emissions, global warming, climate change, cumulative effects of combustion of 

PRB coal by power plants, and current and future energy sources and emissions of greenhouse 

gases in Section 4.2.14.1, 4.2.14.2, and 4.2.14.4.

Also, please see Section 4.2.14.3 in the EIS. It addresses U.S. actions and strategies regarding 

GHG emissions. Potential regulatory policies to address climate change are in various stages of 

development at the federal, state, and regional levels. EPA is the agency chiefly responsible for 

the Clean Air Act and its implementation including the governing of GHG emissions as air 

pollutants. EPA is the agency with the authority to regulate GHG emissions from power plants 

and factories, not BLM. BLM does not regulate GHG emissions, nor set national standards for 

carbon fuel use. 
5 

BLM does not govern air quality standards and pollutants. Further, BLM does not permit, nor 

authorize, mining operations and does not have the authority to regulate mining operations. As 

discussed in detail in Section 1.3 of the EIS, WDEQ is authorized by the Secretary of the Interior 

to regulate and permit surface coal mining operations. 

Your comment suggests that the EIS should examine a wide variety of “mitigation alternatives” 

with the only connection being that all the actions would, in theory, fall under the jurisdiction of 

an assortment of agencies within the Department of Interior. Your suggested approach fails to 

recognize that each project proposal is a federal action in its own right and must be evaluated in 

light of the effects of that action when added to other past, present, and reasonably foreseeable 

future actions regardless of what agency (federal or non-federal) or proponent undertakes such 

other actions. 

The EIS addresses the environmental effects of leasing coal and the logical result that coal would 

be mined by adjacent operating mines. The EIS further discloses indirect emissions with the 

assumption that the coal will be mined and burned to produce electricity. It is beyond the scope 

of this EIS to analyze potential national and international regulations regarding GHGs and 

carbon fuel use. 

Comment Response 6: Please review Section 4.2.14.1 in the EIS; it clearly describes and 

discusses GHGs and climate change at depth including the observed and projected effects of 

global warming, sea level changes, differential temperature changes, and changes to vegetation 

and habitat. We referenced the Intergovernmental Panel on Climate Change (IPCC) assessment 

throughout the cumulative impacts analysis. 

As disclosed throughout the EIS, when coal is burned and used as a primary source for 

generating electricity, it results in the release of CO2, a greenhouse gas (GHG). A large portion 

of our country’s existing domestic electric generating capacity is based upon carbon-based fuels, 

as described in the EIS. The potential impacts of climate change represent the cumulative 

aggregation of worldwide GHG emissions. As noted in the EIS, 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. Many foreign countries do not have an 

EPA to regulate air pollution or control emissions. 

The EIS provides a meaningful context and measure of the relative significance of coal use from 

the proposed LBAs and overall projected PRB coal production on total GHG emissions, and the 

EIS recognizes the effects of historic warming on the western U.S. Please see Chapter 4 to 

review the complete cumulative impacts analysis. BLM analyzed the cumulative impact on the 

environment that results from the incremental impact of the proposed LBAs when added to other 

past, present, and reasonably foreseeable future actions, including GHG emissions. 

Please see Section 4.2.14.2 of the EIS for our analysis regarding the cumulative effects of 

combustion of PRB coal by power plants. We included 1) annual CO2 emission estimates based 

on PRB coal production levels, 2) annual CO2 equivalents (CO2e) emission estimates from coal 

production at all PRB mines with pending LBAs, and 3) estimated CO2 emissions produced from 
6 

the combustion of coal produced from the Wright Area EIS coal tracts. As described in the EIS, 

we assumed that coal mining would proceed in accordance with permit conditions. We further 

assumed that this coal would be sold to consumers in response to forecasts of coal demand. 

Historically, the consumers have been the domestic electric utility companies although there is 

potential for sales outside the U.S. The coal market is open and competitive; consumers are free 

to choose and buy from the most cost effective suppliers in order to meet their needs. 

As previously noted, in Chapter 4, we estimated the amount of GHG emissions that could be 

attributed to coal production as a result of leasing the proposed LBAs, as well as from the 

forecast coal production from all coal mines in the Wyoming PRB. Again, we assumed that all 

PRB coal would be used for coal-fired electric power generation. This gives an upper estimate 

of GHG emissions resulting from use of the coal that would be produced from the proposed 

LBAs and for forecast total PRB coal production. The estimate was derived by relating the 

portion of coal produced in the Wyoming PRB to national steam coal totals, and then applying 

that ratio to the total emission of GHG estimated in the U.S. as a result of coal-fired electric 

generation. 

We have assumed that existing land and resource conditions within the analysis area have been 

and will continue to be affected by climate change under all alternatives including the No Action 

Alternative. Existing climate prediction models are not at a scale sufficient to estimate potential 

impacts of climate change within each analysis area. We have referenced national and regional 

data that is available including “The Effects of Climate Change on Agriculture, Land Resources, 

Water Resources and Biodiversity in the United States” (U.S. Climate Change Science Program, 

2008). 

An additional June 2009 report defined the relative degree of climate change effects that could 

potentially be experienced in the future in various regions of the United States (Global Climate 

Change Impacts in the United States, Thomas R. Karl, Jerry M. Melillo, and Thomas C. 

Peterson, (eds.), Cambridge University Press). The report uses two scenarios to bracket potential 

climate effects and separates the country into regions. The Wyoming Powder River Basin is 

included in the Great Plains region, which is characterized by strong seasonal climate variations. 

Historically, the area has been subject to prolonged drought followed by wetter conditions. 

Average temperature increases have been predicted in the region with the greatest changes being 

in the winter such that commonly very cold days would become less common and warmer wetter 

weather would be more common. 

Under the higher heat trapping emissions scenario, temperatures are projected to increase over 

the next 100 years more so than under the lower heat trapping emissions scenario. The milder 

winters and longer growing season would be expected to favor larger numbers of insects earlier 

and longer into the season. The change in climate is expected to cause a shift in wild plant and 

animal distributions favoring those species that are better suited for the warmer wetter climates 

that both the lower emission and higher emission scenarios predict for the Powder River Basin. 

With increasing precipitation, soil erosion in drainages and sheet flow across the land surface 

would be expected to increase, based on assumptions. 
7 

Please see Section 3.18.2 for our site-specific analysis regarding GHG emissions. It contains 

estimates of GHG emissions resulting from the combined mine operations. The site-specific 

impacts analyzed in this EIS are based on the assumption that if an LBA tract is offered for 

competitive lease, a lease would be issued and mining would be permitted. We further assume 

that the applicant would be the lessee, and the lease would be permitted as an extension of their 

current mining operations. As described in Chapter 3, we estimated the change to GHG 

emissions under each alternative LBA configuration, including the No Action Alternative. The 

EIS estimates direct emissions of GHGs as a result of continued operations of the applicant 

mines and the proposed leasing actions. The EIS also estimates potential GHG volumes resulting 

from the assumed use of this coal at dispersed electric generation facilities. 

As previously described, the EIS is addressing the environmental effects of leasing federal coal 

and the potential mining of that coal. The EIS further discloses the indirect emissions on the 

presumption that the coal will potentially be mined and burned to produce electricity. The EIS 

does not attempt to estimate the cost of GHG emissions from coal combustion at utility power 

plants. The EIS does not assert that the cost of GHG is zero or any particular value, as there is 

no known threshold or context for this value. In a regulatory structure where GHG control costs 

factor into electric generation costs, coal users would likely weigh these costs into capital and 

operating decisions. Electric generation activity is directly influenced by consumer demand. If 

electricity cannot be supplied to meet demand, power prices rise until the demand falls. 

Measures to reduce GHG emissions from coal burning are applicable at the place where the coal 

is consumed because the coal consumer must comply with regulatory and price constraints, and 

this will bear on fuel choices. Infrastructure, equipment availability, incentives, and cost also 

determine the potential for switching to non-carbon based electric generation. Mining the lease 

reserves and the continued operation of a Powder River Basin mine is not directly tied to any 

existing or proposed electric generation facility. Limiting one or even several points of fuel 

supply will not affect coal use because of the diverse group of national and international 

suppliers. 

Finally, please review Section 4.2.14.3, which describes U.S. actions and strategies to address 

GHG emissions. As stated in the EIS, national policies regulating specific levels of significance 

have not yet been established for GHG emissions. Given the state of the science, it is not 

possible to associate specific actions with specific global impacts such as potential climate 

effects. Since there are no tools available to quantify incremental climate changes associated 

with these GHG emissions, the analysis cannot reach conclusions as to the extent or significance 

of the emissions on global climate. 

As described throughout the EIS, BLM does not govern GHG emissions, air quality standards, 

nor pollutants. Further, BLM does not permit nor authorize mining operations and does not have 

the authority to regulate mining operations or the burning of coal at utility plants. The Clean Air 

Act requires the EPA to regulate air pollutants and develop regulations, rules, and standards for 

industries that emit one or more pollutants in significant quantities. 

BLM has considered and addressed climate change comments that we received in a timely 

manner pertaining to this EIS. They are also included in our administrative record. 
8 

Comment Response 7: We have revised Section 3.11 in the Final EIS to include additional 

information regarding the loss of access to public lands. In general, if the LBAs are leased, the 

loss of access to federally administered public lands in the LBAs may extend for 20 years or 

more after permitting depending on individual mine plans, mine variation in coal production 

rates, permitting requirements, and reclamation sequence and succession. Also, please see 

Chapter 2. It describes and discloses in detail the length of time that would be required to 

recover the federal coal from each LBA. Please see Comment Response #9 for additional 

information regarding reclamation. 

The BLM is a multiple use land management agency that also administers federal minerals, 

including federal coal reserves. BLM administers public lands and minerals under the policy and 

practice of multiple use management. The Bureau's responsibility for multiple use involves 

balancing an extensive diversity of resources and the potential use or development of those 

resources and lands as administered by BLM. Managing vast and varied resources under this 

mandate is a complex undertaking, particularly since the priorities set for one management 

activity may conflict with the priorities of another. For both BLM and FS administered public 

lands, the management, constraints, limitations, and prescriptions for those lands are developed 

through the land use planning process. The public is encouraged and invited to participate 

throughout the land use planning processes. The EIS identifies and explains that the proposed 

actions and alternatives are consistent with the BLM Buffalo Field Office and USFS land use 

plans. 

As described in the EIS, for the lands included in the Wright Area LBAs and affiliated study 

areas, there are, in fact, no BLM administered surface lands. BLM does not control nor manage 

private surface ownership lands. Those rights and authorizations belong to the private surface 

land owners. As shown in Table 3-15 in the EIS, private surface ownership makes up 65.1 

percent of the total acreage included in BLM’s preferred alternatives. BLM will not lease coal 

under private lands without the consent of the qualified surface owner (43 CFR 3400.0-5(gg)). 

As also indicated in Table 3-15, approximately 12,481 acres of federal surface administered by 

the USFS are included in the Wright Area LBA tracts under BLM’s preferred alternative. As 

described in Section 1.6, USFS is a cooperating agency on this EIS and 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. The USFS will issue their own separate record of 

decision (ROD) regarding their potential consent to lease those lands. A decision to consent to 

lease USFS lands can be appealed within 45 days from the date that the Notice of Publication of 

USFS ROD is published in the Laramie Boomerang. 

If USFS administered public lands are leased for coal, at the mine permit stage, USFS would 

include stipulations related to allowing access to TBNG lands included in existing federal coal 

leases. USFS does not necessarily allow the mines to close access to all public lands within the 

permit boundary. For human health and safety reasons, access can be closed in the areas that are 

currently being actively mined. The mines can officially only deny public access to National 

Forest System lands included in federal coal leases that are within the "active area fence" for 

each mine. If the mines remove publicly accessible roads from public access, they must provide 

alternate publicly accessible roads in that area. 
9 

The TBNG is a mixture of public and private surface lands. In some cases, USFS lands are 

isolated parcels surrounded by private lands that are not easily accessible to the public. Federal 

land exchanges can be used as a tool to help facilitate the creation of more contiguous blocks of 

National Forest System land, can make state land more accessible and usable to the general 

public, and can decrease conflicts related to crossing private land to reach public land. 

From 1993 through 2000, the USFS Douglas Ranger District completed 21 land exchanges 

involving more than 69,000 federal acres. In exchange for these federal lands, the USFS 

acquired more than 46,000 acres, eliminated 12 private inholdings within federal lands, 

eliminated 71 isolated parcels of public lands, and gained 426.8 acres of wetlands. 

From 2000 through 2010, the USFS Douglas Ranger District completed two land exchanges 

involving more than 5,199 federal acres. In exchange for these federal lands, the USFS acquired 

more than 4,918 acres, eliminated three private inholdings within federal lands, eliminated three 

isolated parcels of public lands, and gained 0.3 acres of wetlands. 

Comment Response 8: Please see Section 3.3.2, 3.11.1, and 3.15 of the EIS. Impacts to 

ancillary facilities that support oil and gas production in the area are addressed in detail in those 

sections. The EIS identifies and discloses that, in order for coal to be mined, oil and gas 

development must be curtailed and development facilities and equipment must be removed prior 

to mining operations. As stated in Section 3.15, the pipeline owner/operator and the coal mine 

operator must come to agreement before any disruption, relocation or abandonment of these 

pipelines would occur. 

For more information, please also see Section 4.1.12, 4.5.11, and Appendix D. Appendix D lists 

the stipulations that are included on coal leases in the Powder River Basin. These stipulations 

specifically address multiple mineral development and oil and gas/coal resources.

Comment Response 9: As described in the EIS, the Surface Mining Control and Reclamation 

Act of 1977 (SMCRA) is the federal law that regulates surface coal mining. BLM has no 

authority under SMCRA. BLM does not regulate or enforce reclamation of mined lands in 

Wyoming. The Wyoming Department of Environmental Quality/Land Quality Division 

(WDEQ/LQD) regulates and monitors reclamation. Reclamation laws for coal mining in 

Wyoming originate from the State of Wyoming’s Open Cut Reclamation Act of 1969 and the 

Wyoming State Environmental Quality Act of 1973, as well as from SMCRA, the federal act. 

These three acts together regulate coal mining. 

The State of Wyoming has the overall reclamation authority and enforces the federal and state 

acts through the WDEQ. Within the federal coal leasing program, BLM only has the authority to 

make decisions regarding the potential leasing of federal coal resources. BLM does not 

authorize surface disturbance or permit mining operations, nor administer reclamation activities. 

The Office of Surface Mining Reclamation and Enforcement (OSM) and the WDEQ/Land 

Quality Division (LQD) are the reclamation authorities. 
10 

Long term reclamation information is provided in Section 4.1.1.1 in the EIS and includes tables 

that provide detailed reviews and projections of actual and projected disturbance and reclamation 

in the Wright subregion. This review reflects the total disturbance, including active mining and 

mined but unreclaimed, as well as disturbed but unavailable for reclamation due to occupation by 

long term structures or facilities. Please note that permanently reclaimed areas are also included 

in the analysis. 

In particular, Table 4-2 and 4-3 in Chapter 4 of the Final EIS summarize a detailed review and 

projection of actual and projected disturbance and reclamation acreages through the year 2020. 

This review reflects the total disturbance area (including the active mining area, the unreclaimed 

mined area, and the area disturbed but unavailable for reclamation due to being occupied by 

long-term structures or facilities), as well as areas permanently reclaimed. The trend is that the 

acreage including active mining and mined but unreclaimed is expected to increase slowly, less 

than 1 percent per year, as is the acreage of land disturbed but unavailable for reclamation. The 

rate of permanent reclamation will be more rapid, about 4 percent per year. The ratio of total 

land reclamation to total land disturbance was around 30 percent in 2003, and is expected to be 

45 percent by 2010, and approaching 60 percent by 2020. As of 2008, the actual ratio of total 

land reclamation to total land disturbance was about 38 percent (15,800 acres permanently 

reclaimed out of a total mine disturbance area of 41,700 acres) for the Wyoming PRB mines. Of 

the total unreclaimed disturbance, about 12,000 acres were unavailable for reclamation and 

14,000 acres were in active mining operations. An accounting of acres disturbed to acres 

reclaimed for the three applicant mines in 2008 is also discussed in Chapter 3 of the EIS. 

During the permitting process, the mines submit reclamation plans to WDEQ for approval. 

These plans are based on the individual mining company’s mining progression. The WDEQ 

approves or rejects these plans based on the mining progression of the individual mine and the 

area needed for long-term facilities, sedimentation reservoirs, haul roads, diversions, and topsoil 

stockpiles. The reclamation plan is evaluated against the individual mine progression by the 

WDEQ to ensure reclamation is directly following the mining extraction process. 

WDEQ has strict parameters for coal mine reclamation procedures, species compositions, final 

land surface contour, and environmental sustainability. SMCRA requires sufficient bonding to 

cover anticipated reclamation costs. When mining is permitted, WDEQ/LQD sets the bond 

amount for reclamation of all disturbed lands and the operator posts an acceptable bonding 

instrument for this amount with the State of Wyoming. The reclamation bond is not released 

until a minimum of ten years have elapsed from the date of final seeding and the WDEQ/LQD 

has determined that all reclamation verifications have occurred. Regardless of their bond release 

status, reclaimed lands are frequently utilized, and are often preferred, by wildlife and are 

commonly used for livestock grazing. 

On a monthly basis, WDEQ/LQD monitors all lands within the mining permit boundary. These 

lands must pass requirements set by state law. Until the mines terminate their permit, the WDEQ 

does not require them to complete final bond release as long as contemporaneous reclamation is 

proceeding at the required rate and to the required standards as regulated by state and federal 

laws. Please note that there are several phases of bond release that mines may apply for that 

represents every task from replacing the backfill, to the approved contour, to placing topsoil and 
11 

permanent seeding. Therefore, a percentage assessment of lands that have been released from 

final bonding requirements is not an accurate assessment of “contemporaneous” reclamation. 

As previously mentioned, during the interim period between initial reclamation and final bond 

release, land condition and status is monitored by WDEQ/LQD, and that information is 

publically available at their Cheyenne office. Individual coal mine annual reports are also 

available to the public at WDEQ/LQD offices and include additional reclamation information. 

OSM also prepares reports describing reclamation activities in Wyoming. Please contact their 

offices for further information regarding reclamation. 

Comment Response 10: The EIS includes a thorough evaluation of water resources in Section 

3.5, 4.2.4, and 4.2.5. Please review these sections, and in particular, see Section 4.2.4 for the 

groundwater cumulative impact analysis, which includes coalbed methane/natural gas 

development. As noted throughout the EIS, SMCRA and Wyoming state law require that the 

surface coal mine operator provide the owner of the affected water right with water of equivalent 

quantity and quality. 

There are a number of specific studies under SMCRA and Wyoming law that would be done and 

would bear on the approval of a permit to mine any Wright Area LBA lands that might be leased. 

Once the mining plan has been developed, the mine would then submit a mine permit application 

to WDEQ. A Cumulative Hydrologic Impact Assessment (CHIA) would then be developed by 

the WDEQ/LQD to examine how the mining of the LBA, along with any other already approved 

mining, would affect groundwater. The CHIA considers recharge contribution and a system of 

wells to monitor groundwater would also be specified at that time. The management of surface 

water flows during mining, as well as the restoration of surface water flow systems post mining, 

is specified in each mining permit. CHIAs are available for the public to review at the 

WDEQ/LQD. 

The cumulative water modeling study, completed by BLM in December 2009 as part of the 

Powder River Basin Coal Review, provides additional information on surface and groundwater 

resources and effects by regional development activities. To review the report, please access the 

following link: 

http://www.blm.gov/wy/st/en/programs/energy/Coal_Resources/PRB_Coal/prbdocs.html 

For the purposes of identifying and disclosing potential impacts, the EIS assumes that: 1) each 

LBA is offered for lease, 2) that the successful lessee is the applicant mine, and 3) that the mine 

applies for, and is granted, a permit to mine the LBA in a manner similar to the mining that is 

already permitted on other lands at the applicant mine. 

Comment Response 11: If the decision is made to offer an LBA for lease and hold a coal sale, 

prior to proceeding with any lease offer as a result of processing the Wright Area LBAs, BLM 

will ensure that the provisions of the Mineral Leasing Act and the Federal Coal Leasing 

Amendments are complied with. A lease cannot be issued to any entity that would result in that 
12 

entity exceeding the acreage limitations. As described in Section 1.6 of the EIS, the Department 

of Justice will be consulted prior to the issuance of a lease. 

Comment Response 12: The Wright Area EIS wildlife surveys were carried out in accordance 

with established agency guidelines and protocols. BLM prepared and provided the Wright Area 

EIS, Biological Evaluation, and Biological Assessment to USFWS, USFS, and the Wyoming 

Game and Fish Department for their review. BLM has improved and revised the wildlife 

analyses in the FEIS based on comments received from the professional wildlife biologists at 

these agencies. 

Please see Section 3.10.5.1 in the EIS for the sage-grouse analysis. The sage-grouse is 

designated as a BLM Sensitive Species and as a USFS Region 2 Sensitive Species and 

Management Indicator Species, as additionally analyzed and described in detail in Appendix H. 

On March 5, 2010, the Service announced its decision to add the Greater sage-grouse to the list 

of Candidate species under the ESA. USFWS found that listing the Greater sage-grouse was 

warranted but precluded by higher priority listing actions. BLM identifies Greater sage-grouse 

as a Candidate species in the EIS. 

The U.S. Fish and Wildlife Service (USFWS) is responsible for the administration of the 

Endangered Species Act. USFWS is the lead agency that manages threatened and endangered 

species and, through the Section 7 process, consults with other agencies in how proposed 

projects may impact and affect listed species. All federal agencies have a responsibility under 

Section 7(a)(1) of the Endangered Species Act to conserve federally listed threatened and 

endangered species. BLM is partnered with USFWS in fulfilling our Section 7 consultation 

obligations and responsibilities. We continue to work with USFWS in order to address concerns 

and provide any additional information needs. Section 7 consultation will be completed before a 

decision is made on the Wright Area EIS proposed coal leases. 

As explained in the EIS, Wyoming has been exceptionally proactive in the management and 

conservation of its Greater sage-grouse. In 2007, Wyoming Governor Dave Freudenthal 

commissioned a Statewide Sage-grouse Implementation Team (SGIT), 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 Core Population Strategy for the state of Wyoming is designed to maintain 

habitats and viable populations of sage-grouse in areas where they are most abundant. SGIT 

delineated approximately 40 areas around the state with the objectives of maintenance and 

enhancement of sage-grouse habitats and populations within those focal areas. The polygons 

were delineated by evaluating habitats within a four mile radius of selected sage-grouse leks in 

high lek-density areas. The SGIT continues to refine the delineated core population areas based 

on updated information and consultation with state and federal agencies. 

On August 1, 2008, the Governor of Wyoming issued an executive order regarding sage-grouse 

core area protection. According to the executive order, state agencies are directed to work with 

federal agencies and landowners to maintain and enhance sage-grouse habitats and populations. 

The BLM Wyoming State Office is in the process of developing a statewide sage-grouse 
13 

management policy and has incorporated sage-grouse focus areas based on the core population 

area concept in the draft management policy. 

None of the lands analyzed in the Wright Area EIS are located within the designated sage-grouse 

core population areas as mapped and identified by Wyoming’s SGIT. Additionally, none of the 

lands evaluated in the EIS are within any of BLM’s sage-grouse management focus areas. 

Requirements to protect wildlife during mining operations are addressed as part of the existing 

mining and reclamation plan for each individual mine. BLM has no authority over these plans. 

If an LBA is leased and mined, the coal company, in concert with the USFWS, will develop a 

USFWS-approved mitigation plan to address and mitigate wildlife issues, including sage-grouse, 

before any surface disturbing activities can occur. Administered by WDEQ, requirements would 

be stipulated in the mining and reclamation plan amendments if the tract is leased, and before the 

tract would be mined. 

Finally, WDEQ has strict parameters for coal mine reclamation procedures, species 

compositions, final land surface contour, and environmental sustainability. SMCRA requires 

sufficient bonding to cover anticipated reclamation costs. When mining is permitted, 

WDEQ/LQD sets the bond amount for reclamation of all disturbed lands and the operator posts 

an acceptable bonding instrument for this amount with the State of Wyoming. The reclamation 

bond is not released until a minimum of ten years have elapsed from the date of final seeding and 

the WDEQ/LQD has determined that all reclamation verifications have occurred. Regardless of 

the bond release status, reclaimed lands are frequently utilized, and are often preferred, by 

wildlife. 

Comment Response 13: The USFWS is responsible for the administration of the Endangered 

Species Act. It is the mandate and responsibility of the Service to provide guidance to federal 

agencies in how to avoid adverse impacts to protected species and habitats. USFWS is currently 

monitoring trust resources to see how they are affected by changing climate. The USFWS 

Endangered Species Program is working to develop interim guidance regarding relevant aspects 

of ESA implementation involving climate change with a focus on how to evaluate and include 

the best available scientific information on climate change in the decision making process. 

BLM prepared and provided the Wright Area EIS wildlife analyses, Biological Evaluation, and 

Biological Assessment to USFWS, USFS, and the Wyoming Game and Fish Department for 

their review. BLM has improved and revised the wildlife analyses in the FEIS based on 

comments received from professional wildlife biologists at these agencies. 

Through the Section 7 process, the Service consults with agencies in how proposed projects may 

impact and affect listed species. All federal agencies have a responsibility under Section 7(a)(1) 

of the Endangered Species Act to conserve federally listed threatened and endangered species. 

BLM is partnered with USFWS in fulfilling our Section 7 consultation obligations and 

responsibilities. BLM will continue to coordinate and consult with USFWS on listed species and 

will work to ensure that our projects do not adversely affect nor jeopardize threatened and 

endangered species. Section 7 consultation will be completed before a decision is made on the 

Wright Area EIS proposed coal leases. 
14 

Section 4.2.14.1 in the EIS describes and discusses GHG and climate change at depth including 

the observed and projected effects of global warming. Section 4.2.14.3 in the EIS addresses U.S. 

actions and strategies regarding GHG emissions. Potential regulatory policies to address climate 

change are in various stages of development at the federal, state, and regional levels. EPA is the 

agency chiefly responsible for the Clean Air Act and its implementation including the governing 

of GHG emissions as air pollutants. EPA is the agency with the authority to regulate GHG 

emissions from power plants and factories, not BLM. BLM does not regulate GHG emissions, 

nor set national standards for carbon fuel use. It is very likely that various GHG emission limits 

will be established, enacted, and regulated by EPA in the future. As explained in the EIS, coalfired power plants would have to comply with any new EPA standards, rules, or regulations for 

emission controls. Regulatory limits on emissions by coal-fired power plants have been and will 

likely continue to be enacted by EPA in the future. 

Again, BLM does not govern GHG emissions, air quality standards, pollutants, nor air quality 

mitigation. Further, BLM does not permit, nor authorize, mining operations and does not have 

the authority to regulate mining operations nor the burning of coal. The Clean Air Act requires 

the EPA to regulate air pollutants, and they are required to develop regulations, rules, and 

standards for industries that emit one or more pollutants in significant quantities. 

Comment Response 14: As directly stated by Secretary Salazar, “The fact remains that oil and 

gas and coal are a very important part of our energy portfolio now and they will continue to be 

an important part of our energy portfolio in the future . . . Fossil fuels and clean technology coal 

will have to be part of the mix if the U.S. is able to have enough energy in the future.” Secretary 

Salazar also stated, “I don’t want you all here to be scared, those of you here who are supportive 

of coal and oil and natural gas. At the end of the day, if we are going to be an energy 

independent nation, it’s going to take all of us and all of you in coal and oil and those of us who 

want to harness the wind—all of us.” His speech is available at: 

http://www.farmandranchguide.com/articles/2009/11/18/ag_news/regional_news/news2.txt 

As stated in the EIS, approximately 92 percent of the total coal that is mined in the U.S. is used 

for generating electricity. Currently, coal-fired electric generating plants are the cornerstone of 

the nation’s central power configuration. Electricity is important to the country’s security and 

economy. Many other states rely on Wyoming for coal reserves in view of the fact that 

Wyoming coal is used to generate electricity in 36 states. 

As described in Section 4.2.14.4 of the EIS, the key determinant of energy consumption is 

population. The population in the U.S. has increased by about 20 percent and energy 

consumption by a comparable 18 percent since 1990, with variations in energy use per capita 

depending on factors such as weather and the economy. As human population and activities 

have increased, carbon-based fuels have been used to provide for these additional energy needs. 

To meet the nationwide consumer demand and ever-growing requirement for energy, coal is 

burned in power plants to produce electricity. 

We revised the Final EIS to include additional information regarding the projected electric 

generation portfolio of the United States. Please see Section 4.2.14.4. Studies have indicated 
15 

that 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 until at least 

2035. Other energy sources for electric power have been and continue to be developed, but not 

to the extent that they can instantaneously replace coal as a fuel for electrical generation. At this 

time, there is not enough alternative energy sources developed and in place to fill the gap that 

would be left if coal was removed as a fuel source for electrical generation in the U.S. 

 

America’s electrical power demand results from electric use decisions made by individuals and 

businesses. The coal market is open and competitive; consumers are free to choose and buy 

from the most cost effective suppliers in order to meet their needs. BLM leases federal coal to 

private coal companies that develop and supply coal primarily as a fuel for electric utility 

companies to generate electricity in response to the electric demand of the American people. 

BLM recognizes that coal leasing demand is a direct indication of electric generation activity, 

which in turn is directly influenced by consumer demand. If the demand for coal decreases 

nationwide, then coal production and coal mining would decrease. 

A Record of Decision (ROD) shall be issued for each LBA addressed in this EIS. In the ROD, 

BLM will reach a decision as to whether to reject the LBA or competitively offer a federal coal 

tract in response to the LBA. The ROD will address public interest considerations made in the 

decision. 

As described throughout Chapter 1, the purpose of this EIS is to analyze and disclose the 

potential environmental impacts and effects from the proposed leasing of six maintenance tracts 

of federal coal in the Wright Area of the Wyoming Powder River Basin. Although leasing these 

tracts would not authorize mining operations on those lands, the EIS evaluates the potential 

impacts of mining the tracts because mining is a logical consequence of issuing a lease for a 

maintenance tract of federal coal. Please see Section 3.19 in the EIS for the analysis regarding 

irreversible and irretrievable commitments of resources. 

The BLM is a multiple use land management agency that also administers federal coal leasing 

and the management of other federal minerals. BLM does not solicit, importune, nor seek out 

project proposals regarding coal, uranium, oil, gas, wind, solar, or any other energy-type 

resource. Rather, an applicant, lease holder, and/or company will propose a project or submit an 

application to BLM if their proposed action includes BLM-administered public lands and/or 

federal minerals. BLM manages these actions and proposals through leases and rights-of-way 

where public lands and/or minerals are concerned. Again, applicants, lease holders, and 

companies are the ones that propose development projects to BLM, not the other way around. 

Wind power and other alternative energy development projects potentially depend on available 

transmission capacity to link the project sites to the national grid. There are a number of high 

wind potential areas in Wyoming where the transmission infrastructure and powerline capacity is 

being enhanced and expanded in order to support wind power development. Of special note, 

BLM has an active renewable energy program and has recently created the Wyoming BLM 

Renewable Energy Coordination Office to facilitate the processing of renewable energy projects. 
16 

In order for an alternative energy project or any other project to come to fruition, as previously 

explained, there must first be a valid proponent to plan, develop, and propose the project to 

BLM, i.e. applicant, lessee, or company. As with any project, alternative energy projects would 

be evaluated separately under their own National Environmental Policy Act (NEPA) process. 

Each proposed project would be analyzed independently, on its own merit. 

BLM is a land management agency and, as such, does not have the means to develop “clean 

coal” technologies. However, the mission of the Department of Energy (DOE) is to promote 

America’s energy security through reliable, clean, and affordable energy. As noted by the 

DOE’s Office of Fossil Energy, fossil fuels supply 85 percent of the nation’s energy and, 

therefore, they are charged with researching and developing a number of high priority projects 

including pollution-free coal plants, carbon capture and sequestration, coal gasification, and new 

combustion turbine technology. For further information, please review their website at: 

http://fossil.energy.gov/programs/powersystems/index.html 

As described throughout the EIS, BLM does not govern GHG emissions, air quality standards, 

nor pollutants. Further, BLM does not permit, nor authorize, mining operations and does not 

have the authority to regulate mining operations or the burning of coal. The Clean Air Act 

requires the EPA to regulate air pollutants and develop regulations, rules, and standards for 

industries that emit one or more pollutants in significant quantities. 

Comment Response 15: Carbon sequestration is addressed in Section 4.1.1.2.5, 4.2.14.3, and 

4.2.14.4 of the EIS. 

Comment Response 16: Please see Section 4.2.14.5 in the EIS for the analysis regarding 

combustion by-products. Black carbon is a general term applied to various carbonaceous 

products that have not completely combusted. The WDEQ/AQD monitors and regulates coal 

combustion facilities in Wyoming. WDEQ enforces regulations on particulate emissions from 

coal combustion facilities at or above the standards set by the EPA. The Clean Air Act requires 

the EPA to regulate air pollutants and develop regulations, rules, and standards for industries that 

emit one or more pollutants in significant quantities. 

Comment Response 17: Please review Section 4.2.14.1 in the EIS; it clearly describes and 

discusses GHG and climate change at depth including the observed and projected effects of 

global warming, sea level changes, differential temperature changes, and changes to vegetation 

and habitat. 

Local human health impacts from mining in the PRB are described in Section 3.18.1.1 in the 

EIS. However, the tools necessary to effectively quantify the effects on global human health due 

to increased CO2 levels from a specific activity, like the mining of an LBA tract in Wyoming and 

the combustion of that particular source of coal, are not currently available. 
17 

Comment Response 18: Please review Section 4.2.14.1 in the EIS; it clearly describes and 

discusses GHG and climate change at depth including the observed and projected effects of 

global warming, sea level changes, differential temperature changes, and changes to vegetation 

and habitat. 

The tools necessary to quantify incremental effects on oceans due to increased CO2 levels for 

specific activities, like the mining of an LBA tract, are not available. Consequently, impact 

assessment of effects of specific anthropogenic activities cannot be performed. Additionally, 

specific levels of significance have not yet been established. Therefore, potential global analysis 

of ocean acidification in this EIS is limited to accounting and disclosing factors that contribute to 

GHG levels. To the extent that emission data were available or could be inferred from 

representative type data, we have identified potential GHG emissions that could result from the 

development of a proposed LBA, as well as emissions that could result from selection of the No 

Action Alternative. 

Comment Response 19: Ozone has been included in discussions on emissions of nitrogen 

oxide, NOX, since it is one of the main components involved in the formation of ground level 

ozone. Motor vehicle exhaust and industrial emissions, gasoline vapors, and chemical solvents 

as well as natural sources emit NOX and volatile organic compounds (VOC) that help to form 

ozone. Ground-level ozone is the primary constituent of smog. Sunlight and hot weather can 

cause ground level ozone to form in harmful concentrations in the air. As a result, it is known 

mainly as a summertime air pollutant. Many urban areas tend to have high levels of ozone; rural 

areas can also have increased ozone levels. 

Under the Clean Air Act (CAA), EPA has set protective health-based standards for ozone in the 

air we breathe. Prior to May 27, 2008, the National Ambient Air Quality 8-hour Standard for 

ozone was 0.080 ppm (157 micrograms per cubic meter--μg/m3

). In May of 2008, EPA revised 

the 8-hour standard to 0.075 ppm (147 μg/m3). The EPA proposed a new primary and secondary 

ozone standard in the Federal Register on Tuesday Jan. 19, 2010. The final standard is expected 

to be issued by August 31, 2010. The new primary standard was proposed as a daily maximum 

8-hour average in the range of 0.060 to 0.070 ppm. There are two ozone monitoring stations 

currently available in the PRB. According to the EPA AirData website, ozone levels have been 

monitored in the PRB since 2001. 

As explained throughout the EIS, the WDEQ/AQD requires the PRB mines to collect air quality 

data. The eastern PRB is one of the most intensely monitored areas in the world. According to 

EPA AirData, there are six total suspended particulate (TSP) monitors, five PM2.5 (particulates 

smaller than 2.5 microns in diameter) monitors and 36 PM10 (particulates smaller than 10 

microns in diameter) monitors in the Wyoming portion of the PRB. Data for TSP dates back to 

1980 and data for PM10 dates back to 1989. Approximately 57,000 TSP samples had been 

collected through 2004. Approximately 47,550 PM10 samples had been collected through 2007. 

Information about the regulatory framework, the monitoring network, and PM10 concentration 

trends since monitoring began are included in Appendix F of the EIS. 
18 

The federal standard for particulate matter was measured as TSP until 1987. This measurement 

included all suspendable dust (generally less than 100 microns in diameter). In 1987, EPA 

changed from a TSP-based standard to a PM10-based standard. In 2006, EPA again revised the 

air quality standards for particulate matter by changing the 24-hour fine particle standard from 

the previous level of 65 μg/m3 to 35 μg/m3 and revoked 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 Chapter 3 of the EIS. Wyoming added the PM10 standard in 1989. Even 

with the evolution of state and 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. 

The Task 1A Report for the PRB Coal Review documents the modeled air quality impacts of 

operations during the baseline year using actual emissions and operations for that year. 

Emissions from 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. 

As discussed in Chapter 3 of the EIS, 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 miningrelated impacts in the PRB. This agreement also requires Wyoming to implement “Best 

Available Work Practice” mitigation measures at any mine where an exceedance of the PM10 and 

PM2.5 NAAQS has occurred. 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 addressed in detail in Chapter 3 of the EIS. 

It should be noted that WDEQ/AQD issues the permits to mine coal in Wyoming under the 

authority delegated to them by the EPA under the Clean Air Act (CAA). Wyoming mines in the 

PRB are permitted under the CAA as regulated emission sources. WDEQ permits identify 

mitigation measures that the permittee must carry out in order to comply with the permit. These 

measures are currently in place at the Wright Area mines. The WDEQ/AQD conditions permits 

to provide necessary mitigation. The WDEQ/AQD has stated clearly that they cannot issue any 

permit that violates ambient air quality standards.

Comment Response 20: Please review Section 4.2.14.5 in the EIS for the analysis regarding 

mercury from coal combustion. We disclose adverse health effects caused by mercury, 

bioaccumulation in the food web, and other issues. An estimate of the percentage of global 

mercury emissions contributed by the three applicant mines is included. 

The estimated percentage of the annual total global anthropogenic mercury emissions from 

burning all of the coal produced from the Wyoming PRB, as well as from the three applicant 
19 

mines, is included in Section 4.2.14.5. Given the mines’ projected future levels of production 

under the considered alternatives, the additional years of mercury emissions attributable to 

burning the coal produced by the three applicant mines are also included with the caveat that the 

uncertainties about future regulatory requirements and the use of the coal mined from the Wright 

Area LBA tracts make it difficult to project the impacts of mercury emissions that would 

potentially be produced from burning the coal included in these tracts. 

Over the past decade, EPA has been focused on addressing environmental and human health 

mercury risks. EPA found that overall U.S. mercury air emissions have been reduced by 45 

percent since 1990. In 2009, EPA estimated that mercury emissions from domestic coal-fired 

power plants accounted for about one percent of the global total. Coal-fired boilers are required 

to have control devices to reduce the amount of emissions that are released into the atmosphere. 

The use of air pollution control equipment at power plants in the U.S. has resulted in fewer 

emissions but has also increased the amount of solid residues. 

Table 4-40 summarizes how the various continents contributed to the worldwide anthropogenic 

mercury emissions in 2004. As shown, the U.S. anthropogenic mercury emissions were 

estimated to account for about three percent of the global total. EPA estimates that 83 percent of 

the mercury deposited in the U.S. originates from international sources outside the country, with 

the remaining 17 percent coming from the U.S. and Canada. 

As described throughout the EIS, BLM does not govern coal-fired power plant emissions, air 

quality standards, nor pollutants. BLM does not permit, nor authorize, mining operations and 

does not have the authority to regulate mining operations or the burning of coal. The Clean Air 

Act requires the EPA to regulate air pollutants and to develop regulations, rules, and standards 

for industries that emit one or more pollutants in significant quantities. 

Comment Response 21: Please refer to Section 3.4.4.2 in the EIS for the lake acidification 

analysis. As noted in the EIS, 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. 

We also address acid rain in Section 3.4.3.2, 3.4.4.2.1, and 4.2.14.2 of the EIS. 

To help reduce acid rain, EPA implemented a program to reduce releases of SO2 and other 

pollutants from coal-fired power plants. The first phase began in 1995 for SO2 and targeted the 

largest and highest emitting power plants. The second phase, started in 2000, set tighter 

restrictions on smaller coal-, gas-, and oil-fired plants. Scientists predict that the decrease in SO2

emissions required by the Acid Rain Program will significantly reduce acidification. Regulatory 

limits on emissions by coal-fired power plants have been and will continue to be administered 

and implemented by EPA. 

In a 2002 USGS analysis (USGS Fact Sheet-038-02), Appalachian and Illinois Basin coals 

supplying a Kentucky power plant were found to contain 2.5 to 3.5 percent sulfur. In the same 

study, Powder River Basin coal supplying an Indiana power plant was found to contain 0.23 to 

0.47 percent sulfur. The study indicated that PRB coal contained approximately 8 times less 

sulfur than coals being used from the Appalachian and Illinois Basins. As explained in Chapter 
20 

4 of the EIS, one of the reasons that PRB coal competes well in the coal market is because of its 

low sulfur content and value in helping to lower SO2 pollution from coal-fired power plants. 

Comment Response 22: Please see Section 3.6 in the EIS for the alluvial valley floors (AVFs) 

analysis. It is BLM policy to not lease lands that could not be permitted for mining under 

Section 510 of the Surface Mining Control and Reclamation Act (SMCRA). For stream-laid 

deposits that could possibly be AVFs, we ask for comment from WDEQ/LQD as to whether 

these areas could be mined and reclaimed in accordance with WDEQ/LQD and SMCRA 

regulations. If WDEQ provides a preliminary finding that the AVF is significant to farming and 

that protection of the AVF precludes mining, BLM will not lease those lands. Neither the 

WDEQ nor OSM, both cooperating agencies on this EIS, identified additional areas as potential 

AVFs that would be unsuitable for mining. 

Comment Response 23: Please see Section 3.7 in the EIS for the wetlands analysis and to 

review site-specific wetlands and restoration information. As stated in the EIS, the U.S. Army 

Corps of Engineers (COE) requires mitigation of all impacted jurisdictional wetlands in 

accordance with Section 404 of the Clean Water Act. As described in the EIS, wetlands are 

restored under the jurisdiction of the COE. There are special required permitting procedures to 

assure that after mining, there would be no net loss of jurisdictional wetlands. 

If a lease is issued, a formal wetland inventory is completed and submitted to the COE for 

verification as part of the permitting process. COE reviews all surface coal mining and 

reclamation permits. For any LBA tract that is leased, restoration of jurisdictional wetlands 

would be required, and consultation with the U.S. Army Corps of Engineers (COE) would be 

completed during the permitting process. 

COE is the agency with the authority to approve plans for wetland restoration and the number of 

acres to be restored. COE considers the type and function of each jurisdictional wetland that will 

be impacted and may require restoration of additional acres if the type and function of the 

restored wetlands will not completely replace the type and function of the original wetland. The 

wetland mitigation plan, approved by COE, then becomes part of the WDEQ/LQD mining 

permit. WDEQ/LQD is the agency that permits mining operations and has authority to enforce 

mining regulations; they can require the restoration of some non-jurisdictional wetlands 

depending on the values associated with the wetland. WDEQ requires restoration of playas if 

they have hydrologic significance. Reclaimed wetlands are monitored using the same 

procedures used to identify pre-mining jurisdictional wetlands. 

Naturally occurring wetland areas within the general Wright analysis area and, generally 

speaking, in the overall Wyoming PRB, are typically associated with the presence of surface 

water and shallow groundwater that exists within alluvial deposits. They are generally thin, very 

limited in areal extent, and are closely associated with drainage channels. Riverine, palustrinetype wetlands are the most common type and are typically defined by their close association with 

drainage channels. These wetland areas occur sporadically along the channels and banks and are 

generally supported by periodic, seasonally-occurring flow events that recharge the alluvial 
21 

deposits. Wetland areas and other waters of the U.S. also occur within naturally-occurring 

playas and depressions, as well as stockponds built within the drainages; however, those features 

are also strongly associated with the presence of surface water rather than groundwater. Of 

particular note, as described in the EIS, all the streams in the general Wright analysis area are 

naturally ephemeral. 

Shallow groundwater tables in the general Wright analysis area are predominantly associated 

with alluvial deposits and are therefore extremely limited in both occurrence and areal extent, 

and typically exist only along the ephemeral drainages. Once the drainages that have been 

disturbed by mining are reclaimed in order to restore their pre-mining essential hydrologic 

functions, the shallow alluvial deposits that were replaced, as required by mine permit, will 

resaturate. Reestablishment of a shallow alluvial groundwater table and associated wetland areas 

will be dependent upon the occurrence of ephemeral streamflow events. 

As disclosed in the EIS, during the mining and reclamation period when the drainages and playa 

areas are disturbed, there is a temporary loss of wetlands. Monitoring efforts conducted by the 

mines have observed that surface runoff and sediment control structures (i.e. reservoirs and 

diversion channels) potentially act as seasonal wetland areas at times for wildlife. As previously 

mentioned, complete and timely reclamation of wetland areas that are disturbed by surface coal 

mining in the PRB is required by the U.S. Army Corps of Engineers and the WDEQ. 

Comment Response 24: The USFWS is responsible for the administration of the Endangered 

Species Act (ESA). It is the mandate and responsibility of the Service to provide guidance to 

federal agencies in how to avoid adverse impacts to protected species and habitats. Through the 

Section 7 process, the Service consults with agencies on how proposed projects may impact and 

affect listed species. All federal agencies have a responsibility under Section 7(a)(1) of the ESA 

to conserve federally listed threatened and endangered species. 

BLM recognizes that Ute Ladies’-tresses orchid (ULT) is listed under the ESA as a Threatened 

species. Please see the Biological Assessment in Appendix G of the EIS for the detailed 

analyses regarding ULT. The Wright Area mines have conducted multiple ULT surveys over 

multiple years according to the guidelines that were written and provided by USFWS. The 

Service developed these guidelines in concert with professional biologists, botanists, and 

ecologists that were knowledgeable about this species. BLM prepared and provided the Wright 

Area EIS, Biological Assessment (BA), and Biological Evaluation (BE) to USFWS and USFS 

for their review. BLM has improved and revised the EIS, BA, and BE based on their reviews. 

BLM is partnered with USFWS in fulfilling our Section 7 consultation obligations and 

responsibilities. BLM will continue to coordinate and consult with USFWS on listed species and 

will work to ensure that our projects do not adversely affect nor jeopardize threatened and 

endangered species. Section 7 consultation will be completed before any decision is made on the 

Wright Area EIS LBAs. 
22 

Comment Response 25: You state in your comment letter that Canada lynx and piping plover 

use lands in the PRB mining area. Unless you have direct species observation information to 

contribute, your comment is erroneous. If you are in possession of observation data or verified, 

legitimate distribution information regarding these species, please contact the USFWS 

Ecological Services in Cheyenne, Wyoming immediately as they would be highly interested in 

any valid data that you may have. 

The USFWS is responsible for the administration of the Endangered Species Act (ESA). It is the 

mandate and responsibility of the Service to provide guidance to federal agencies in how to 

avoid adverse impacts to protected species and habitats. Through the Section 7 process, the 

Service consults with agencies on how proposed projects may impact and affect listed species. 

All federal agencies have a responsibility under Section 7(a)(1) of the ESA to conserve federally 

listed threatened and endangered species. 

As described in the EIS, see Section G-4.0 of the Biological Assessment for the detailed analyses 

regarding the status of Threatened and Endangered species in Campbell County where the 

Wright Area mines are located. As explained in the EIS, USFWS biologists have used the best 

scientific information available to formulate a list of Threatened and Endangered (T&E) species 

that occur in or may be affected by proposed projects in Campbell County. Updated in March, 

2010, the list clearly shows one species that is currently recognized as Threatened (Ute Ladies’-

tresses), and one species that is recognized as Endangered (Blowout Penstemon). Please contact 

the USFWS Ecological Services regarding any issues that you may have with the T&E species 

list that the Service’s professional biologists prepared for Campbell County. 

BLM prepared and provided the Wright Area EIS, Biological Assessment (BA), and Biological 

Evaluation (BE) to USFWS and USFS for their review. BLM has improved and revised the EIS, 

BA, and BE based on their reviews. 

BLM is partnered with USFWS in fulfilling our Section 7 consultation obligations and 

responsibilities. BLM will continue to coordinate and consult with USFWS on listed species and 

will work to ensure that our projects do not adversely affect nor jeopardize threatened and 

endangered species. Section 7 consultation will be completed before any decision is made on the 

Wright Area EIS LBAs. 

Comment Response 26: Please refer to Section 3.3.2.1.2 in the EIS regarding methane, or 

CBNG. BLM recognizes that CBNG is a valuable energy resource and BLM policy encourages 

the development of this resource, where economically feasible, in advance of coal mining. The 

EIS acknowledges that much of the CBNG resources have already been recovered by existing oil 

and gas operators. CBNG has been commercially produced in the PRB since 1989. By 2005, 

drilling activity in the areas adjacent to the coal mines had declined significantly. The EIS points 

out that there has been little recent interest in drilling CBNG in the general Wright analysis area. 

Comment Response 27: Please see our extensive cumulative impacts analysis in Chapter 4 of 

the EIS. Over 100 pages in length, our analysis is rigorous and comprehensive. 
23 

The Powder River Basin (PRB) Coal Review began in 2003. The Review’s purpose was to 

evaluate the current condition of environmental and socioeconomic aspects in the PRB for a base 

year, to project reasonably foreseeable development in future years, and to develop models as 

well as other quantitative and qualitative tools to estimate future effects on environmental and 

socioeconomic aspects. The PRB Coal Review is not a NEPA document. It is a planning tool, a 

set of environmental impact analysis tools, and, when maintained through the years, is a method 

to calibrate development projections and related estimation of effects. 

The Coal Review products were delivered and posted for public access in 2005 and 2006. 

Several of the initial 2005 and 2006 reports have been updated. The 2010 air quality modeling 

report has been supplemented by adding 2015 modeling and, most recently, 2020 modeling. 

BLM has also tracked annual development activity and has updated that work through 2008; the 

2009 data will be added as it becomes available. With the 2009 completion of the groundwater 

model and the 2020 air quality modeling work, the reports have been issued and incorporated 

into the Wright Area Final EIS cumulative analysis. In addition, EPA specifically commented 

that the PRB Coal Review studies were used effectively in the Wright Area EIS discussion of the 

cumulative environmental consequences. 

The Coal Review is a dynamic, expanding body of information; new data is added continuously 

as it becomes available. The Review has been available to the public since 2006 and was the 

subject of an open house in May of that year to explain and demonstrate the modeling and report 

products. The Review is available online at: 

http://www.blm.gov/wy/st/en/programs/energy/Coal_Resources/PRB_Coal/ prbdocs.html 

Modeling and report updates and revisions are posted to the website as they are completed, and, 

when used as a tool for cumulative impact analysis or planning, the latest task report data and 

results are used. BLM recognizes that the PRB Coal Review is not the only source for 

cumulative impact analysis, which is why land use plans, WDEQ’s Cumulative Hydrologic 

Impact Assessments, and other sources and tools are used in addition to the Coal Review. 

Connected actions have also been addressed in Chapter 4. As previously discussed, this chapter 

addresses current or planned development in the Powder River Basin (PRB) and describes PRB 

cumulative development and the cumulative environmental consequences of that development. 

Both low and high production scenarios with projections to the year 2020 are discussed. Past, 

present, and reasonably foreseeable development and the cumulative environmental 

consequences of that development are also detailed. The years 2010, 2015, and 2020 were 

selected for the analysis of the direct, indirect, and cumulative impacts in Chapter 4. This is the 

duration of the expected production as related to the LBA coal reserves. 

Your comment suggests that the EIS should examine a wide variety of actions with the only 

connection being that all the actions are under the jurisdiction of the Department of the Interior 

(DOI). Your suggested approach fails to recognize that each of these proposals are federal 

actions in their own right, and must be evaluated in light of the effects of that action when added 

to other past, present, and reasonably foreseeable future actions regardless of what agency 

(federal or non-federal) or person undertakes such other actions. 
24 

The EIS addresses the environmental effects of leasing coal in the PRB and the logical result that 

the coal would potentially be mined by adjacent operating mines. The EIS further discloses 

indirect emissions with the assumption that coal would be mined and burned to produce 

electricity. It is beyond the scope of this EIS to analyze all the DOI-authorized projects and 

proposed activities that occur in the United States. 

Comment Response 28: To be clear, the Powder River Basin (PRB) Coal Production Region is 

a coal production region. Decertification of the region recognized that the PRB was expected to 

continue as a coal production region, but that the leasing would be primarily for maintenance of 

production at already existing mines. In 1990, the Powder River Regional Coal Team (RCT) and 

BLM recognized that the PRB had become a mature coal production region where the leasing 

interest would not reflect leasing for reserves to commence a new mining venture, but, rather, the 

coal resources would be sought to replace reserves depleted by production at existing mines. 

Coal leasing in the PRB had operated as a federal coal production region under the definition at 

43 CFR 3400.5, with leasing addressed under the regional leasing process as described under 43 

CFR 3420, through the 1980s. Many of the federal coal production regions were decertified in 

the later 1980s, in large part because of a decline of interest in leasing federal coal (64 FR 

52240). However, many of the Wyoming PRB mines had depleted their original leases during 

the 1980s, and there was a recognized need for replacement reserves in order to maintain 

production at these mines. 

In 1989, public comment was requested on partially or totally decertifying the PRB. While most 

comments were supportive, three parties expressed concern that decertification and the LBA 

process would lead to leasing abuse and restricted public involvement. In 1990, based on the 

advice of the RCT, BLM decertified the region. However, in light of concerns raised by the 

public, certain conditions of the decertification were established, in part, based on the RCT’s 

advice: 1) the region was decertified for production maintenance leasing, 2) the RCT would 

remain active to guide leasing, 3) new mine starts or expansions would be considered on a case 

by case basis, and 4) operating guidelines for LBAs would be adopted. 

In a region that is decertified, BLM is able to consider leasing by application (LBA) under the 

rules at 43 CFR 3425. The RCT has met about once each year since the decertification. BLM 

has presented all lease by applications to the RCT and has considered their advice on how to 

proceed with those applications. LBAs have been rejected by BLM since decertification, 

consistent with public comment at RCT meetings, and RCT advice. 

Decertifying the PRB recognized the need for a production maintenance leasing mechanism. 

Decertifying the PRB did not cause LBAs to occur, but recognized the need that existed at the 

time of decertification, and continues to exist as evidenced with the Wright Area LBAs and other 

coal lease applications. 

You are correct that production of PRB coal has increased steadily since decertification. Part of 

this growth is due to an increase in the demand for electric power and the related increase in 

demand for steam coal as a fuel for low cost electric generation. There are also cost (mining and 
25 

reclamation) advantages that have favored PRB coal over other domestic coal regions as well as 

the low sulfur content of PRB coal, which results in cost-effective air pollution control. 

The production increase has been made with no new mining operations opening since 

decertification, although several of the operations have consolidated. As shown in Figure 4-2 in 

the EIS, leasing under the LBA process has essentially been at the same rate as reserves existing 

before decertification have been being depleted. This level of leasing activity remains consistent 

with the 1990 decertification action. 

Production maintenance leasing does indeed define a leasing level. BLM has managed leasing to 

assure that the rate of new reserves being leased matches the rate of reserve depletion through 

production. This avoids reserves being offered at speculative value while balancing a reserve 

base to allow coal producers to maintain production capacity (equipment and employees). 

The lease application is submitted in order to identify those lands that the applicant has identified 

as needed to maintain production at an existing mine. BLM formulates alternatives (Alternatives 

1 and 2 in this EIS) that may include more or less lands than are included in the application. 

Under these alternatives, BLM is able to reconfigure the tract in the public interest to conserve 

coal resources, enhance competitive potential, and mitigate impacts. BLM has frequently (in 

almost every LBA offered) delineated a preferred alternative smaller or larger than the 

application, and containing some different lands than those applied for by the applicant. 

It is logical, prudent, and is generally in the public interest for the lease tracts to be adjacent to 

one or more existing mines. These are production maintenance tracts and, as such, are located so 

that existing operations could potentially pass onto these tracts without having to open a new pit, 

which would require significant additional disturbance and higher costs. 

BLM has offered coal tracts at several sales where multiple bids were received. There have been 

sales where the applicant was not the successful bidder. The sales are always competitive, even 

if there is only one bidder, because the BLM sets a fair market value and will not accept any bid 

that does not meet that value. These values are not disclosed, and bidders recognize that they 

need to bid a fair value or the bid will be rejected. BLM has rejected numerous bids that were 

the apparent high bid. 

BLM’s practices and administrative controls ensure that fair market values are received for the 

LBA tracts that are delineated by BLM. The tracts offered by BLM 1) allow coal production to 

be maintained at already operating mines, 2) avoid coal resource bypass and isolation, and 3) 

encourage competition. 

The BLM properly established the Powder River Coal Production Region as required by 43 CFR 

3400.5. The change to the region was published in the Federal Register on January 9, 1990 (55 

FR 784-785). BLM has, and continues to manage the LBA process in conformance with the 

criteria, conditions, and requirements of a decertified coal region. 

Processing the Wright Area lease by applications is consistent with the practice we follow in the 

decertified Powder River Coal Production Region. These are production maintenance tracts, 
26 

have been reviewed by the Powder River Regional Coal Team, and are being reviewed under the 

leasing by application process (43 CFR 3425). 

The Powder River RCT meetings are public and provide an opportunity for public comment and 

statements. Notices for upcoming Regional Coal Team meetings are published in the Federal 

Register and a press release is also posted on the BLM website. The public is always welcome 

and is encouraged to attend. 

The comment asks whether BLM has made a decision that the entire PRB is unacceptable for 

further consideration for coal leasing. This is not the case. This determination is based on 

findings from the resource management plans (RMPs) that encompass the Wright Area. 

Appendix B in the EIS summarizes the findings of the RMPs as well as a review completed as 

part of the EIS analyses to update and specify the acceptability for further consideration for coal 

leasing of lands within the general Wright analysis area. 

Like the regional leasing option under 43 CFR 3420, lease by application requires appropriate 

analysis and assessment of the environmental impacts of coal leasing. Lease by application also 

requires the opportunity for public participation. The NEPA process resulting in the Wright 

Area Coal EIS achieves these requirements. Alternative regional leasing levels are not addressed 

in the LBA process because, as previously discussed, production maintenance leasing is the 

defined leasing level appropriate to a decertified coal production region. Coal leasing decisions 

under the lease by application process consider coal economics, both direct and cumulative 

impact to the environment, and socioeconomic impacts. 

The Wright Area Coal EIS is not a regional EIS in the sense of the regulations at 43 CFR 3420. 

However, the EIS has been properly scoped to address direct, indirect, and cumulative impacts of 

the proposed leasing. BLM has chosen to address the currently pending LBAs in four separate 

EISs, some addressing groups of LBAs because of their geographical proximity, others as 

individual LBA EISs due to either no other LBAs in proximity or the fact that the EIS was 

already well underway prior to the nearby LBAs being filed. Each EIS is consistent in 

addressing the specific impacts of each LBA, in addressing the cumulative impacts of the 

specific LBA when added to other reasonably foreseeable activity, and in having complete public 

involvement at every step in the NEPA process. 

There are considerable undeveloped reserves in the U.S., about half the world’s reserves. The 

Energy Information Administration (EIA) estimates that there are over 250 billion tons of 

accessible demonstrated reserves in the nation, with about 20 billion committed to existing 

mining operations. Twenty billion tons represents 50 years of production from the PRB that are 

presently committed to production, some of which are held by existing PRB operators. At an 

annual domestic production of one billion tons per year, existing domestic coal mines can 

produce coal for twenty years, relying solely on already committed reserves. 

A Record of Decision (ROD) will be issued for each LBA addressed in this EIS. In the ROD, 

BLM will reach a decision as to whether to reject the LBA or competitively offer a coal tract in 

response to the LBA. The ROD will address the public interest considerations made in the 

decision.
27 

Comment Response 29: We acknowledge that the EIS can be challenging to read at times due 

to its complex nature, detailed resource information, and technical analyses. To improve the 

readability, we have prepared a comprehensive executive summary to condense and highlight the 

results of the analyses. We have also provided technical evaluation appendices in order to 

improve readability. Please use the Table of Contents to help guide and focus your examination 

of this document. 

Comment Response 30: We have summarized the discussion and have added information to 

the Executive Summary. 

Comment Response 31: The information provided in your comment letter has been considered 

in the preparation of the EIS. 

Comment Response 32: Blasting by surface coal mines is conducted in accordance with 

Chapter 6 of the WDEQ/LQD Coal Rules and Regulations. Specific control measures for 

blasting would be developed during the permitting process, when mining operations are 

authorized. 

Voluntary administrative controls are in place and are common components of the mines’ 

operating procedures to mitigate and reduce blasting-related NOx emissions. Several PRB mines 

have voluntarily elected to no longer employ cast blasting methods. As stated in Section 

3.4.3.1.1 of EIS, the primary control measure for mitigating exposures to offsite residents is to 

avoid cast blasting when wind directions or atmospheric conditions are unfavorable. As stated in 

Section 3.4.3.3, weather and atmospheric conditions are closely monitored prior to the decision 

to detonate a blast. If unfavorable conditions prevail, a decision will be made to postpone the 

blast until conditions have become favorable. EPA’s suggested mitigation methods are included 

in Section 3.4.3.3, which is comprehensive and has been reviewed by WDEQ/AQD. 

The BLM does not authorize mining operations by issuing a lease and does not regulate mining 

operations after a lease is issued. As discussed in Section 1.3 of the EIS, WDEQ is authorized 

by the Secretary of the Interior to regulate surface coal mining operations on federal and nonfederal lands within Wyoming. 

Comment Response 33: The annual NAAQS and WAAQS for NO2 is 0.053 ppm (53 ppb), 

which is equivalent to 100 μg/m3

. The new 1-hour primary NAAQS for NO2 is 100 ppb. The 

maximum annual average NOx prediction for the Jacobs Ranch Mine (year 2013) was 55 μg/m3, 

or 29.2 ppb, well below the federal and state standards. EPA’s error in stating that the NOx

prediction for the Jacobs Ranch Mine for 2013 exceeds the NAAQS by 2 ppb is due to a 

confusion of measurement units. Mitigation measures that are implemented to reduce minerelated NOx emissions at the three applicant mines are addressed in Section 3.4.3.3 of the Final 

EIS. 
28 

Section 3.4.2.2.1 states that the potential impacts from mining the LBA tracts have been inferred 

from the projected impacts of mining the existing coal leases as currently permitted. Modeling 

for each of the three applicant mines, as contained in the mine’s current air quality permit, 

indicates compliance with the PM10 annual WAAQS. No impact analyses or modeling for PM2.5

are included in the applicant mines’ existing air quality permits, which were approved in 2007 

(Jacobs Ranch Mine) and 2008 (Black Thunder and North Antelope Rochelle mines). The EPA 

Surrogate Policy allows states like Wyoming to use PM10 as a surrogate for PM2.5 in meeting 

New Source Review requirements under the Clean Air Act, including PSD permitting 

requirements. Since 1997, the WDEQ/AQD has followed and applied EPA’s Surrogate Policy. 

On May 16, 2008, EPA promulgated a rule that provides states with SIP-approved PSD 

programs (like Wyoming) that require amendments to incorporate PM2.5 into their state PSD 

rules time to accomplish these amendments to their State Implementation Plan (SIP), and these 

states have three years to incorporate PM2.5 into their state PSD rules. During that SIPamendment period, a state may continue to implement a PM10 program as a surrogate to meet the 

PSD program requirements for PM2.5 pursuant to EPA’s 1997 Surrogate Policy. 

Mining operations would continue on the existing mine leases as currently permitted, regardless 

of whether or not the six Wright Area coal lease applications are offered or rejected by BLM. As 

stated in Section 3.4.2.2.1, if the applicant mines acquire the LBA tracts, they will be required to 

amend their current air quality permits to include the new lease areas before mining activities can 

proceed into the new lease areas. New air quality modeling would include an adequate PM2.5

modeling analysis to demonstrate compliance with the PM2.5 WAAQS. 

Comment Response 34: Section 3.4.2.3 of the Final EIS (Regulatory Compliance, Mitigation 

and Monitoring for Particulate Emissions) covers BACMs for dust control for all surface coal 

mines in the PRB, and it is stated that additional site-specific layout and mining practices may be 

included in individual mine and air quality permits. 

Section 3.4.2.3 also states: “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. 

“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 
29 

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 truck-dumping 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.” 

Comment Response 35: Section 3.4.3.3 describes the voluntary measures that many of the 

PRB mines have implemented to avoid NOx emissions impacts to the public. Measures to avoid 

public exposure to NO2 from blasting activities are requirements for the Black Thunder Mine as 

part of a settlement agreement reached in 2000. Considerable discussion in Section 3.4.3.3 

addresses the mines’ efforts to reduce NOx emissions from blasting activities. As noted in Table 

3-9 and 3-10, the mean annual NO2 concentrations for all PRB monitoring sites have historically 

been significantly below the WAAQS and NAAQS annual standard. 

Comment Response 36: A summary of the GHG emissions projected with the addition of the 

six Wright Area LBA tracts was added to the Executive Summary. 

Comment Response 37: The annual NAAQS for NO2 (0.053 ppm or 100 μg/m3

) has been 

added to the text within the air quality section of the Executive Summary. 
30 

Comment Response 38: There is no scientific basis or regulatory requirement regarding the 3-

mile buffer line; it was an arbitrary selection. The EIS has been revised to exclude the 3-mile 

buffer. 

Comment Response 39: The projected modeled visibility impacts for all analyzed Class I and 

sensitive Class II areas were updated in Table 4-13 in the Final EIS using BLM’s updated Task 

3A report (Cumulative Air Quality Effects) for the PRB Coal Review. 

BLM’s PRB Coal Review is extensively referenced throughout Chapter 4 of the Wright Area 

Coal Lease Applications Final EIS in order to summarize the cumulative impacts occurring as a 

result of existing development in the PRB. The PRB Coal Review also describes how those 

impacts would change if other projected development, such as the leasing and mining of 

additional LBA tracts, were to occur in the area. Task 3 of the PRB Coal Review does not 

evaluate specific proposed projects within the PRB, but projects that would be expected to occur 

under the lower and upper coal production scenarios for 2010, 2015 and 2020. 

The updated Task 3A report for the PRB Coal Review (Cumulative Air Quality Effects) uses 

2004 as the baseline year with projected 2015 and 2020 lower and upper coal production 

scenarios. The baseline year emissions inventory was developed using 2004 actual emissions 

data and for the 2015 and 2020 analyses, the emission sources were projected for the assumed 

upper and lower coal production scenarios. Presenting the type and location(s) of the emissions 

contributing to the potential cumulative impacts throughout the PRB for 2015 and 2020 under 

the upper and lower coal production scenarios (as presented in Table 4-11 through 4-14) is 

considerably beyond the scope of the EIS for the Wright Area LBAs. 

As noted, BLM has recently contracted a second phase of the PRB coal review for modeling to 

update the 2020 analysis and extend the forecast of regional air quality to year 2030. This 

project will analyze additional pollutants (i.e. ozone) and include photochemical grid modeling. 

EPA is a key member in the interagency stakeholder group that will review the modeling 

protocols for the second phase effort. 

Comment Response 40: We have updated the data in Table 3-8 in the Final EIS and have 

revised the units to be consistent throughout (μg/m3

). 

Comment Response 41: Thank you for your comment. We revised the Final EIS to incorporate 

the information that you provided. 

Comment Response 42: The BLM does not permit, nor authorize, mining operations and does 

not have the authority to regulate mining activities nor mitigate air quality impacts. As discussed 

in detail in Section 1.3 of the EIS, WDEQ is authorized by the Secretary of the Interior to 

regulate surface coal mining operations and surface effects of mining on federal and non-federal 

lands within Wyoming. 
31 

As stated in Section 3.4.2.3 of the EIS, the WDEQ/AQD requires the Wyoming Powder River 

Basin mines to collect air quality data. As explained throughout the EIS, WDEQ/AQD has, by 

statute, the authority and responsibility to require mitigation for air quality impacts. 

Comment Response 43: We have revised, reorganized, and updated Section 4.2.14 in the Final 

EIS. 

Comment Response 44: The BLM’s PRB Coal Review is available online at: 

http://www.blm.gov/wy/st/en/programs/energy/Coal_Resources/PRB_Coal/prbdocs.html

The coal review reports and analyses are used and referenced in the cumulative impact analysis 

in NEPA documents prepared to evaluate coal leasing in the PRB like the Wright Area Coal 

Lease Applications EIS and other proposed projects. Since 2006, the coal review analysis has 

been reflected in each subsequent EIS as modified based on public comment on the analysis. 

The coal review has also been used to revise and update the BLM land use plans for the Casper, 

Miles City, and Buffalo Field Offices. 

The PRB is a major energy development area with diverse environmental values. BLM and 

other federal and state agencies need data and analysis tools to evaluate cumulative impacts as 

additional development is proposed in the basin. The coal review updates historic baseline data 

and projects the potential future cumulative effects of coal leasing and development based on 

reasonably foreseeable future development scenarios. 

The BLM Wyoming State Office has several pending applications to lease federal coal in the 

PRB. Each requires a NEPA analysis, and BLM plans to use the results of the PRB Coal Review 

in evaluating the cumulative impacts of leasing the federal coal included in these applications. 

The data and modeling tools are also relevant for the cumulative impact assessments for other 

project-specific impact assessments that BLM must prepare in order to comply with the 

requirements of NEPA by providing updated, readily available, and consistent information. 

Products of the study include databases containing future development activities, air quality, 

water, and socioeconomics information. These databases can be updated through time and used 

with the existing modeling programs to generate future projections of cumulative effects. As 

more data about actual development levels and actual associated impacts are collected and 

evaluated, conclusions based on projected development levels and projected associated impacts 

may need to be revised in the future to reflect the new information. 

The study primarily addresses coal and coal-related development within the PRB and focuses 

mainly on air quality, water resources, and socioeconomics. The PRB Coal Review is a BLM 

project, but BLM has invited federal and state agencies with relevant technical expertise to help 

define the technical approach and content of the project and task reports. Work on the project 

began in 2003. The Task 2 report on foreseeable development was updated in 2009 based on 

actual development that had occurred through 2008. The reports estimating effects of future 

developments to air quality (Task 3A) were done in three parts, primarily to have the reports 

based on up-to-date emission data. The Task 3A report on estimated effects on air quality by 
32 

2010 was completed in 2006, the 3A report for effects by 2015 was completed in 2008, and the 

3A report for effects by 2020 was completed in 2009. The reports estimating effects of future 

development to water (Task 3B) were done in two parts – surface and groundwater, which were 

completed in 2008 and 2009, respectively. 

Comment Response 45: The public has had ample opportunity to participate in the NEPA 

process in regard to the Wright Area LBAs. Please see Section 1.6 in the EIS, which documents 

past public participation activities and describes future public involvement and commenting 

opportunities. 

Comment Response 46: Please see the raptor nest site figures in Chapter 3 of the EIS. The 

raptor nests, including eagle, are clearly shown. 

Comment Response 47: Coal mine outbursts are a phenomenon characterized by the sudden 

and often violent ejection of coal and gas from the solid coal face in an underground mine. 

When outbursts occur, they can be very serious events and are among the major killers of miners 

in underground coal mines. Scientists have been investigating coal outbursts for more than 150 

years; the precise mechanism that causes the event is still largely unknown. Outbursts typically 

occur where the roof of the coal seam is well sealed and can generally be attributed to various 

anomalous geologic features such as structural faults. Studies have found that the gas storage 

capacity of coals increases with depth and coal rank. For example, subbituminous coals have 

much higher gas volume storage capacity than lignite coals. Outbursts happen only in deep 

underground mines where the coal bed is typically of a high rank (i.e., anthracite) and contains 

gas at high pressure. 

Catastrophic release of methane does not occur at the coal face in the open pit mines of the PRB. 

A comparison cannot be drawn between the nearly instantaneous outburst of methane gas from a 

deep, high-ranking coal seam in an underground mine and the slow desorption of methane gas 

from a shallow, low-ranking coal seam in a surface mine. In order for CBNG to be produced 

from a subbituminous coal, hydrostatic pressure within the coal must be reduced to a level that 

allows the gas to desorb. 

A study published by the U.S. Geological Survey in 2006 (Gas Desorption and Adsorption 

Isotherm Studies of Coals in the Powder River Basin, Wyoming and Adjacent Basins in Wyoming 

and North Dakota, USGS Open File Report 2006-1174) concluded that the subbituminous Fort 

Union coal beds having a greater gas volume storage capacity have greater hydrostatic pressures. 

Only the coal beds in the shallowest part of the basin are strip mined. Groundwater drains into 

the open mine pits, resulting in the dewatering of any saturated strata, including the coal seams, 

in the outlying areas. Dewatering of the coal seams mined in the eastern PRB has been ongoing 

since the mid-1970s. Coal bed methane development of the same seams that are mined began in 

the eastern PRB on a large scale in the early-1990s. The 2006 USGS study found that these 

shallow coal beds in the eastern PRB were essentially dewatered and drained of gas as a result. 
33 

A recent evaluation of CBNG reserves in the vicinity of the PRB mines by the BLM Wyoming 

State Office Reservoir Management Group (WSO-RMG, unpublished internal report, 2006) 

concludes that coal seam gas-in-place is dependent on a number of factors, including coal rank, 

coal lithology, and initial methane adsorption capacity of the coals, which is controlled by the 

hydrostatic pressure within the coal. CBNG reservoirs can, thus, be affected by depletion of 

hydrostatic pressure, such as from coal mining and the surrounding CBNG production. 

Reservoir analyses prepared by the WSO-RMG have shown that CBNG can generally no longer 

be economically produced from lands adjacent to the mining areas. Coal cores collected by the 

USGS and WSO-RMG in the vicinity of the mines generally show that coal seams were 

substantially depleted of water and natural gas. Therefore, coal seams exposed within open mine 

pits have typically been dewatered prior to removal of the overburden and are essentially 

depleted of all gas volume storage capacity. The ongoing reduction of hydrostatic pressure in the 

coal beds by the mine pits has been accelerated by extensive CBNG production from 

surrounding lands. The very small amount of residual methane and associated gases are vented 

to the atmosphere when the coal seam is actually mined; however, a small amount of venting can 

also occur naturally at the coal outcrop even in the absence of mining. 

The article by D.A. Kirchgessner, S.D. Piccot, and S.S. Masemore (Kirchgessner et al. 2000) that 

is cited by Dr. Kass states: “... methane is retained by the coal bed and surrounding strata as long 

as it remains under pressure and, assuming that no geologic processes breach the reservoir first, 

mining releases this pressure and the methane escapes,” and “... vertical wells can be drilled into 

the coal in advance of underground mining to drain methane from the coal.” Kirchgessner and 

others may have indeed developed a method for direct atmospheric measurement of methane 

emissions from surface coal mines. However, Dr. Kass’ statement that “using coal core samples 

to measure mine methane is fallacious” may stem from his unfamiliarity with the science of 

determining gas content from the desorption of gas (generally methane) from coal using methods 

described by Diamond and Schatzel (1998). The gas storage capacity of the PRB coal core 

samples were determined by the USGS (Open File Report 2006-1174) using those methods. 

As stated in Section 3.3.2.2.1, the CBNG resource within the Wyodak-Anderson coal seam has 

been substantially depleted, either by mining or by recovery from producing CBNG wells 

nearby. Furthermore, 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 

very likely that most, if not all, of any remaining recoverable CBNG resource will have been 

exhausted prior to the initiation of mining in the LBA tracts. 

As PRB mining operations continue to follow the coal seams downdip, the rate at which the open 

pits advance will decrease as more and more overburden must be removed to uncover the coal. 

Even though hundreds of feet of overburden must be removed, the coal will not become wetter 

or more pressurized due to the constant and continuous dewatering that is the inevitable 

consequence of open pit mining. 

The Final EIS does account for methane emissions from exposed unmined coal at the three 

applicant mines. The amount of methane vented annually, based on the mines’ projected 

maximum future mining rates and the gas content data obtained by the USGS and WSO-RMG 

from coal cores, is included in Section 3.18.2. The total amount of anthropomorphic methane 
34 

emissions attributed to surface coal mining is given in the DOE’s annual report on the emissions 

of GHGs in the U.S. Citing DOE’s most recent annual report, Section 4.2.14.2 in the Final EIS 

provides an estimate of the methane emissions contributed by the three applicant mines in 2008. 

Comment Response 48: PRB coals have a lower BTU per pound than higher ranked coals. 

This is due in large part to moistures in PRB coal. However, CO2 is created as a result of the 

oxidation of the carbon content in the coal. So with PRB coal, the same energy requires a greater 

weight of coal, but the same amount of carbon content, resulting in the same amount of CO2. 

As stated throughout the Wright Area EIS, the EIS was prepared pursuant to the NEPA and other 

applicable regulations and statutes to address possible environmental and socioeconomic impacts 

that could result from potentially leasing the Wright Area LBA tracts. We have assumed that if 

the tracts are leased, they would be mined. That assumption was used to develop the analysis in 

Chapter 3 regarding GHG emissions potentially resulting from the mining of the tracts. Chapter 

4 of the EIS estimates the cumulative effect of all reasonably foreseeable development activity in 

the PRB that would likely occur contemporaneously with the assumed mining of the LBA tracts. 

In this analysis, it is assumed that PRB coal would continue to be used as steam coal for electric 

generation at a rate similar to recent use. The analysis recognizes that future use of PRB coal, 

and coal in general, for electric generation is not entirely known, but, based on current electric 

generation portfolio forecasts, it is likely. 

We acknowledge that your method of estimating GHG emissions related to the mining, transport, 

and consumption of coal is reasonable if one were trying to show the impact of electric 

generation using coal. Decisions from this EIS will not determine if electric generation from 

coal continues, and if so, where the coal consumers will buy coal. These matters will be 

addressed in the marketplace and by law and policies that influence decisions of electricity 

producers and utility regulators. 

Comment Response 49: Coal fines fall from rail cars and accumulate along the rail line. The 

adverse effects of this accumulation, as well as potential mitigation are addressed in Section 

3.15.4.1 of the EIS. WDEQ has responded to complaints from landowners where coal fines are 

escaping the railroad’s right of way. 

Comment Response 50: Please refer to Section 3.3.2.1.2 in the EIS regarding methane, or 

CBNG. BLM recognizes that CBNG is a valuable energy resource and BLM policy encourages 

the development of this resource, where economically feasible, in advance of coal mining. The 

analysis in the EIS clarifies that CBNG has been commercially produced in the PRB since 1989. 

The EIS discloses the release of methane as a result of mining, and that coal seams were already 

substantially depleted of CBNG in the vicinity of the mines in 2000. By 2005, drilling activity in 

the areas adjacent to the coal mines declined significantly. There has been little recent interest in 

drilling CBNG in this area. 
35 

Your cited reference of Rice, Ellis, and Bullock (2000) is the U.S. Geological Survey Open-File 

Report 00-372, “Water co-produced with coalbed methane in the Powder River Basin, Wyoming: 

preliminary compositional data”. This report describes the water quality characteristics of only 

the Wyodak-Anderson coal seam. While it is true that groundwater produced from the Tongue 

River Member of the Fort Union Formation coals has relatively low sulfate concentrations, 

groundwaters from the overlying Wasatch Formation and recent alluvial deposits typically have 

high levels of sulfate, and, as a result, do not meet WDEQ’s standards for either domestic or 

agricultural uses due to the exceedingly high sulfate concentrations. Please see Section 3.5 in the 

EIS for descriptions of the quality of groundwater associated with each of the water-bearing 

geologic units that have been, and will continue to be, affected by surface coal mining and 

CBNG development in the PRB. 

There is a paucity of data on the occurrence of radium in the surface and groundwater systems of 

the PRB. WDEQ does not require coal mine operators to monitor radiochemical constituents in 

surface water or groundwater within and around their operations. BLM is aware of 

radiochemical data that is listed for 65 groundwater sites in the PRB and adjacent areas in 

northeastern Wyoming in a 1984 data report (Open-File Report 83-939). Those data, however, 

may not be completely representative of current conditions considering the level of development 

that has been ongoing in the basin over the past 26 years. No other published radiochemical data 

for naturally-occurring waters in the PRB are known to exist. 

The 2002 Powder/Tongue River Basin Water Plan, which was prepared by the Wyoming Water 

Development Office, stated that “radium-226 may be of concern near uranium ore deposits.” 

Wyoming has been the nation’s leading producer of uranium ore since 1995, and numerous 

uranium mining sites are present in the PRB. Pumpkin Buttes, the primary uranium mining 

district in the basin, is located more than 20 miles west of the general Wright analysis area. 

None of the uranium mining sites are located within the same watersheds that the three applicant 

mines and the six Wright Area LBA tracts are located in. Uranium mining in the PRB is 

conducted by the in-situ recovery method, which is highly monitored and regulated by the 

WDEQ and the Nuclear Regulatory Commission. Due to the great distances between the general 

Wright analysis area and the uranium mining districts in the PRB, cumulative impacts to water 

resources from these operations were not considered in this EIS. 

Radon gas is not known to be associated with either the Wasatch or Fort Union formations in the 

eastern portion of the PRB where the surface coal mining operations are located. 

Comment Response 51: BLM recognizes that CBNG is a valuable energy resource and BLM 

policy encourages the development of this resource, where economically feasible, in advance of 

coal mining. We acknowledge your comment of the importance in recognizing that the rights 

and lease obligations of federal oil and gas lessees be honored. 

If a decision is made to lease an LBA tract, mining operations within the tract would not begin 

until the permitting process is completed, which generally requires several years after a lease is 

issued. BLM’s special coal lease stipulations are identified in Appendix D of the Final EIS. 
36 

These stipulations specifically address multiple mineral development and oil and gas/coal 

resources. 

Additionally, BLM’s CBNG-coal policy provides the agency’s decision-makers with some 

latitude and tools to assist in working out reasonable accommodations among the lessees of coal 

and oil and gas in order to optimize the recovery of both of these resources and to ensure that the 

public receives a reasonable return. BLM recognizes that cooperation in recovering as much of 

the commercially available methane as possible prior to mining will help to reduce the 

atmospheric release of residual methane that results from mining and shipping coal. 

Another aspect of accommodation between oil and gas operators is the timing of well 

abandonment and mining and reclamation operations. It is reasonable to defer extensive 

reclamation on oil or gas sites, when mining and reclamation will follow in a short period of 

time. In these cases, it is possible to temporarily stabilize sites until mining and reclamation 

activities occur. 

Comment Response 52: 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 that actions like coal mining operations comply with all associated 

air quality regulations and criteria. The Wyoming Ambient Air Quality Standards for the PM10

annual and the NOx annual and 24-hour levels are more stringent than the National Ambient Air 

Quality Standards and are enforced by the WDEQ/AQD. 

Large surface coal mines have the potential to become particulate emission sources in the PRB 

contributing to air quality degradation. By statute and delegation, WDEQ/AQD has the authority 

and responsibility to require mitigation for air quality impacts. WDEQ has stated that they will 

not permit mining operations that don’t comply with the standards. 

Any LBA offered as a result of this EIS will have a condition placed on the lease requiring the 

lessee to comply with the air quality regulations. The LBA would be an additional lease mined 

in conjunction with other leases and state and private lands in order to maintain production at an 

existing mine. WDEQ air quality permits regulate and mitigate air pollution for an entire mining 

operation, where any specific mitigation on a single lease would apply only to that lease. 

The FEIS contains recently completed results of regional air quality modeling that was done in 

order to estimate the cumulative air quality effects of all reasonably foreseeable development in 

the PRB by year 2020. As noted in EPA’s letter, BLM has recently contracted for modeling to 

extend the forecast of regional air quality to year 2030. This modeling should be available for 

use by regulatory agencies when considering any future permitting related to adding LBA leases 

to mining operations. 

Comment Response 53: We have revised the Final EIS to include additional information 

regarding cultural resources. As described in Section 3.12 of the EIS, Class III site-specific 

cultural surveys have been completed for each of the six LBA tracts included in this EIS. 
37 

BLM initiated Native American consultation with the tribes on December 16, 2008 in regard to 

the Wright Area LBAs. We will continue to consult on site-specific culturally significant areas 

located within the general Wright analysis area. 

Regulatory compliance, mitigation, and monitoring requirements for cultural resources are 

described in Section 3.12.4. Native American consultation will continue throughout the 

permitting process and will be completed by the Office of Surface Mining Reclamation and 

Enforcement prior to any surface disturbing activities. The BLM’s and U.S. Forest Service’s 

coal lease stipulations with respect to cultural resources are included in Appendix D of the Final 

EIS. 

 

The effects on regional air quality (including the Class I and Sensitive Class II areas in and 

around the Black Hills) as a result of all development predicted in the PRB by 2015 were 

modeled. Those results are discussed in Chapter 4 of the Final EIS. We have also included 

recently completed modeling that projects the effects of all development through the year 2020. 

We did not identify measurable direct or indirect impacts from PRB development activity on 

water quality in the Black Hills. 

Comment Response 54: We appreciate your comment and readily acknowledge the importance 

of agriculture to the community and nation. Section 3.11.1 and 3.11.2.1 in the Final EIS has 

been revised and expanded to include additional information regarding the impacts and potential 

loss of grazing on the USFS Thunder Basin National Grasslands (TBNG) allotments contained 

within the Wright Area LBAs. 

During mining operations, lands are taken out of production for grazing and are not restored until 

the lands are capable of supporting grazing. As described throughout the EIS, reclamation is a 

long term process, and to achieve bond release, the mines must demonstrate to the Wyoming 

DEQ/LQD that the land is capable of withstanding grazing pressure comparable to pre-mining 

conditions. In general, if the LBAs are leased, the loss of access to federally administered public 

lands included in the tracts may extend for 20 years or more after permitting depending on 

individual mine plans, mine variation in coal production rates, permitting requirements, and 

reclamation sequence and succession. 

As described in the EIS, portions of the TBNG are included in five of the six LBA tracts and 

their study areas. Table 3-15 depicts the distribution of surface ownership for BLM’s preferred 

alternatives. As shown, approximately 12,481 acres of federal surface administered by the USFS 

is included in the North, South, and West Hilight Field tracts and in the North and South 

Porcupine tracts under Alternative 2, BLM’s preferred alternative. Section 3.11.1 in the EIS 

discloses that these federal lands are located within USFS 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 these 

allotments are currently held by the Thunder Basin Grazing Association (TBGA). If the federal 

lands are leased for coal, the livestock producers that depend upon these grazing allotments 
38 

would be negatively impacted. The EIS discloses that livestock grazing has been the primary use 

of these lands in the past. 

A number of livestock producers depend upon grazing USFS-administered lands within the 

Wright EIS general analysis area in order to maintain their ranch viability and sustainability. As 

stated above, much of the general Wright analysis area is currently permitted for grazing use 

through a grazing agreement between USFS and the TBGA. Overall, this agreement annually 

permits the TBGA for 71,500 Animal Unit Months (AUMs) on approximately 351,192 acres of 

TBNG for a period of ten years. In turn, TBGA permits these allotments to its individual 

members. 

If the Wright Area LBAs are leased, approximately 12,481 acres of TBNG surface that are 

currently permitted for federal grazing by the TBGA would be suspended during mining and 

reclamation activities. This suspension would result in an additional seven allotments that would 

no longer be available for grazing. One allotment would be reduced by approximately 50 

percent and three allotments would have small reductions in grazing. In total, approximately 

2,890 AUMs would be lost from the TBGA, or four percent of the total grazing agreement due to 

the potential leasing and mining of the Wright Area LBAs. In combination with past impacts, 

these additional AUM reductions from mining would result in three TBGA members that would 

no longer have allotments to graze, one member that would have grazing allotments reduced by 

65 percent, and one member that would be minimally impacted. 

The TBGA permits each of its members to graze in various allotments. When USFS lands are 

withdrawn from grazing use for any reason, including coal mining, the AUMs are removed from 

the member’s permit since they can no longer graze the area. While the TBGA could potentially 

provide relief to some of its members through the possible allocation of other vacant allotments 

if they are available, TBGA cannot totally recover these losses. Often, lost AUMs ultimately 

result in a net loss to the member and the TBGA and negatively impact the ranchers that were 

allotted those AUMs for their livestock operations. 

Since the onset of mining in this portion of the Powder River Basin, approximately 44,000 acres 

of federal surface administered by the USFS within 20 allotments have been impacted by coal 

mining operations. This has resulted in a loss of approximately 10,200 AUMs from the TBGA. 

Cumulatively, with losses from previous mining activities and these proposed leases, the TBGA 

grazing agreement could potentially be reduced by approximately 13,090 AUMs, or 18 percent. 

As previously described, for five TBGA members, the loss of TBNG grazing use due to the 

Wright Area LBAs could seriously impact their livestock operations and family ranches. 

A potential solution to help mitigate adverse effects would be for the TBGA, its affected 

members, USFS, and the mine operators to partner and collaborate in addressing this issue and 

begin to develop potential solutions as a consolidated stakeholder group. Also, it might be 

possible for the affected ranchers to work with one or more of the mines to arrange for grazing 

on reclaimed mine lands. 

As described in Section 1.6, USFS is a cooperating agency on this EIS and must consent to 

leasing the federal coal underlying lands that they administer before BLM can include those 
39 

lands in a decision to hold a federal coal lease sale. The USFS will issue their own separate 

record of decision (ROD) regarding their potential consent to lease those lands. A decision to 

consent to lease USFS lands can be appealed within 45 days from the date that the Notice of 

Publication of USFS ROD is published in the Laramie Boomerang. 

Comment Response 55: Please refer to Figure 1-1 or F-1 in the EIS. The mines south and east 

of Wright do indeed include the three applicant mines (Black Thunder, Jacobs Ranch, and North 

Antelope Rochelle); however, both the Antelope Mine and North Rochelle Mine (which no 

longer has an active air quality permit, and its federal coal leases are now owned by Ark Land 

Company and BTU Western Resources, Inc.) are also included. 

Section 3.4 and the Supplemental Air Quality Information appendix (Appendix F) have been 

updated and revised for the Final EIS. Appendix F in the Final EIS states “... 29 of the 33 valid 

exceedances (those not considered exceptional events under the NEAP) of the 24-hour PM10

standard that have occurred in the PRB through 2009 have been recorded by the group of mines 

located south and east of the town of Wright; the remaining four exceedances occurred in the 

group of mines located north of Gillette...” The 29 exceedances did not all occur at the three 

applicant mines. Please refer to Sections 3.4.2.1, 3.4.2.2.1, 3.4.2.2.1.1, 3.4.2.2.1.2, and 

3.4.2.2.1.3 in the Final EIS for an updated accounting of the exceedances that have occurred at 

each of the three applicant mines. The total number of 24-hour PM10 exceedances that have 

occurred at each of the three applicant mines are also disclosed in the Executive Summary. 

Through 2009 there have been no exceedances of the annual PM10 standards at all three applicant 

mines. Through 2009 there have been a total of eight 24-hour PM10 exceedances documented at 

the Black Thunder Mine (six of which occurred prior to 2007 and one was designated as a high 

wind event under the NEAP). Through 2009 there have been a total of four 24-hour PM10

exceedances documented at the North Antelope Rochelle mine (two of which occurred prior to 

2007 and two were designated as a high wind event under the NEAP). Through 2009 there has 

been one 24-hour PM10 exceedance documented at the Jacobs Ranch Mine (which occurred prior 

to 2007). 

In summary, since the three applicant mines have been in existence and monitoring the 

particulates and reporting the results to the WDEQ/AQD, a total of 13 24-hour PM10

exceedances are on record, three of which were designated as being caused by high wind events 

under the NEAP. Nine of the other 10 exceedances occurred prior to 2007 and DEQ 

acknowledges that most of those could have qualified as being the result of high wind events 

under the NEAP. 

Comment Response 56: Table F-1 and Table 3-8 have been updated and revised for the Final 

EIS. The background concentrations for particulates (PM10 and PM2.5) are based on data 

collected at the Jacobs Ranch and Black Thunder mines in 2005 through 2008. Please refer to 

the explanation of how those values were determined in the tables’ footnotes. 
40 

Please see Section 3.4.2.2.1 and Appendix F for the discussion on air quality modeling for the 

three existing applicant mine operations. 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. The applicant mines’ current 

air quality permit modeling results agree favorably with the historical monitoring data recorded 

by them. 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. 

Comment Response 57: WDEQ/AQD’s Natural Events Action Plan states that “all coal mines 

in the Wyoming PRB employ Best Available Control Technology (BACT). This Natural Events 

Action Plan for the Powder River Basin identifies BACT measures in place as the result of 

existing permit requirements, additional potential control measures identified as BACM, and 

reactionary control measures directed at transient problem sites that may be implemented during 

Natural Events. Implementation of BACT, BACM, and reactionary control measures will assure 

that anthropogenic dust emissions from the coal mines in the PRB are controlled to the greatest 

extent possible. The goal is to protect public health and to minimize exceedances of the PM10 

NAAQS through the continued implementation of BACT, and implementation of BACM and 

reactionary control measures.” 

WDEQ does conduct regularly scheduled mine inspections. The control measures identified as 

BACM that are employed at each of the mines are directed at transient problem areas or sites that 

are unique to the particular operation and are typically action measures rather than devices or 

installations. However, the actions employed by the mines during “natural events” can be 

observed and noted during the agency’s inspections. Included in Section F-2.8 of Appendix F, 

we describe Wyoming’s NEAP, including two lists of control measures designed to prevent 

exceedances during high wind events. Included are the measures that the mines can implement 

continuously so that they are in place before a high wind event occurs. These measures 

primarily address the principal mine-controlled sources of fugitive dust, which are large 

contiguous disturbed areas. The second list is an additional category of control measures that 

include actions that can be taken during a high wind event, depending on site specific conditions. 

The implementation of BACT, BACM, and reactionary control measures assure that 

anthropogenic dust emissions from the coal mines in the PRB are controlled to the greatest 

extent possible. 

Comment Response 58: The applicant mines’ current air quality permit modeling results agree 

with the historical recorded monitoring data. As such, the mines’ BACT requirements for 

particulates have been effective at protecting the NAAQS, and the EIS provides all of the 

information necessary to demonstrate compliance with BLM FLPMA obligations. In addition, 

the EIS states that 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 could proceed into the new lease areas. New air quality 
41 

modeling would need to be conducted in support of the permit application demonstrating ongoing compliance with all applicable ambient standards. 

Comment Response 59: Section 3.4.3 (Emissions of Nitrogen Oxides and Ozone) has been 

updated and revised in the Final EIS. The EIS discloses all possible sources for these gas 

emissions and the monitoring efforts of the WDEQ in the PRB. 

The EIS states that “ozone monitoring is not required by WDEQ 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.” An exceedance of the O3 8-hour standard occurs if the 4th-highest daily 

maximum value is above the level of the standard. Table 3-9 shows that 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. If the strengthened 2008 standard was 

applied retroactively, one exceedance would have occurred in 2003 at the Campbell County site. 

The EIS discloses that BLM expects a stricter O3 standard of between 0.06 and 0.07 ppm to be 

announced in August 2010. 

Your comment claims that ozone levels in the PRB are trending upward. BLM cannot make that 

assertion based on the limited data that are currently available, both temporarily and spatially, for 

the PRB. For example, sans the statistical trend analyses demonstrated by WildEarth’s 

comment, the highest recorded value occurred in 2003; seven years in the past. Additional data 

from these two sites and preferably a larger ozone air quality monitoring network that covers 

more of the basin are needed before any trends can be clearly defined. 

Comment Response 60: Based on data collected at WDEQ’s Campbell County ozone 

monitoring site from 2005 through 2008, we have updated the Final EIS to include the 

background ozone level as 133 μg/m3

 (0.057 ppm) in Table 3-8 and F-1. 

WDEQ does not currently require ozone monitoring or modeling by the PRB coal mines. 

Therefore, the applicant mines’ current air quality permits do not address impacts to the ozone 

standards, and as stated in the response to WildEarth’s prior comment (4a), ozone monitoring 

data for the eastern PRB are limited. BLM has disclosed the sources of ozone emissions from 

the mining operations and the environmental consequences related to it. 

Note that on January 6, 2010, EPA proposed to strengthen the NAAQS for ground-level ozone. 

EPA is proposing to strengthen the 8-hour “primary” ozone standard to a level within the range 

of 0.060-0.070 ppm. For the primary standard, ozone concentrations are averaged over 8-hour 

periods. The fourth highest 8-hour value at a particular monitor in the most recent year is 

averaged with the fourth-highest 8-hour values from the previous 2 years. This produces a 3-

year average. To meet the standard, the 3-year average must be less than or equal to the level of 

the standard. In light of EPA’s proposed ozone standard, additional ozone monitors would be 

needed in the PRB before a quantitative assessment of ozone impacts in the PRB could be made. 

EPA is considering comments received on the proposed monitoring requirements and plans to 

issue a final rule in coordination with the final ozone standards in August 2010. 
42 

The BLM as well as WDEQ recognize that ozone levels in the state are a serious concern. 

WDEQ operates and maintains a network of ambient air quality monitors to determine 

compliance with the NAAQS. When areas do not meet the NAAQS, WDEQ performs special 

monitoring studies, such as that which is ongoing in the Upper Green River Basin, to better 

understand ozone formation. 

Comment Response 61: Ground-level ozone is not emitted directly into the air, but is created 

by sources of NOX, which in the presence of volatile organic compounds (VOCs) reacts to form 

ground-level ozone. Therefore, the statement that is made in the EIS that measures to reduce 

mine-related NOX emissions should also reduce the potential for the formation of ground-level 

O3 in the PRB is entirely reasonable. 

Comment Response 62: The cumulative air quality effects analysis in Section 4.2.3 has been 

updated and revised in the Final EIS. 

BLM updated the air quality model and cumulative impact analysis for the year 2020 using 2004 

as the baseline year with revised 2020 coal production scenarios, based on the PRB Coal Review 

Task 3A Report update. The analysis specifically looked at impacts of coal mines, power plants, 

CBNG development, and other development activities. 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 that were not available 

when the previous modeling was done. 

Two of the reservations noted in your comment are located within the PRB: the Northern 

Cheyenne Indian Reservation, which is designated as a PSD Class I area, and the Crow Indian 

Reservation, which is designated as a PSD Class II area. The Northern Cheyenne Reservation is 

located 13 miles from the Colstrip Power Plant and the Rosebud surface coal mine, and 10 miles 

from the Absaloka surface coal mine. The Crow Reservation actually borders the Absaloka 

surface coal mine. These two reservations are approximately 130 miles north of the general 

Wright analysis area. The Wright EIS general analysis area is located about 330 miles away 

from the Fort Belknap Reservation and about 140 miles from the Wind River Reservation; both 

of these reservations are designated as PSD Class II areas. The modeled impacts to the visibility 

at these reservations, as shown in Table 4-13 in the EIS, are the cumulative result of all current 

and projected development activities within the PRB, not just the impacts that would result from 

the leasing and subsequent mining of the six Wright Area LBA tracts. 

Section 3.17.7 in the EIS addresses environmental justice and the impacts related to the proposed 

leasing of the six Wright Area LBA tracts, not the cumulative impacts from all development 

within the PRB. Therefore, the analysis in Section 3.17.7 is limited to Campbell County. The 

cumulative visibility impacts resulting from all projected development within the PRB would be 

no more acute for Native American populations than for the general public. 
43 

Comment Response 63: Thank you for your comment. We have revised the Final EIS to 

incorporate additional information regarding paleontological and cultural resources in the Wright 

EIS general analysis area. 

We have added the Rockpile Museum in Gillette to the BLM High Plains District coal EIS 

mailing list. The museum will receive all future BLM Wyoming PRB federal coal 

environmental impact statements. 

As is BLM policy, a survey of the lands being considered for federal coal leasing must be 

surveyed for historical and archeological sites and artifacts in advance of leasing. These surveys 

are typically completed by consulting firms approved and/or permitted by the Forest Service 

(USFS) or BLM. Agency approval allows them to conduct surveys on lands administered by 

either of these agencies, and sets professional and technical standards for their work. 

Based on the survey report findings, the BLM or USFS then consults with the Wyoming State 

Historic Preservation Office (SHPO) regarding the significance of sites discovered and the 

eligibility of those sites for the National Register of Historic Places. If the lands are leased, the 

WDEQ, the agency that permits coal mining, will require that a plan be developed to mitigate 

(generally by avoiding or excavating and recording) each eligible site. WDEQ will enforce this 

plan as a condition of the mining permit. 

The cultural survey reports include specific location and content information for each site found. 

This information is confidential under the National Historic Preservation Act. The consultant, 

federal agency, and SHPO are all prohibited from public release of this information. It might be 

possible for the Rockpile Museum to enter into a formal data sharing agreement with the 

agencies where specific information could potentially be shared. The Museum would be under 

the same public release prohibitions as the other agencies. 

Paleontological surveys of the lands being considered for federal coal leasing are undertaken to 

locate, identify, and document paleontological resources that might be affected, and to provide 

recommendations of management/mitigation for identified paleontological resources. Like the 

cultural resource surveys, these surveys are completed by qualified consulting firms that are 

approved to conduct surveys on public lands administered by the federal land management 

agency. 

Potentially significant fossil specimens exposed on the surface have been collected and reposited 

with the Denver Museum of Natural History to prevent data loss. The qualified paleontologists 

who conducted the field survey may recommend that mitigation efforts be conducted to 

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

specimens. 

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 a 

find until an approved paleontologist can evaluate the paleontological resource. 
44 

Comment Response 64: We have added your name to the BLM High Plains District coal EIS 

mailing list. You will receive all future BLM Wyoming PRB federal coal environmental impact 

statements. 

 

Figure 4-5 in the Final EIS does not represent current conditions, but rather, it depicts the areal 

extent of groundwater level drawdown within the Wyodak coal seam aquifer that would be 

expected to occur as a result of all mining activity in the Wright Area should all six of the Wright 

Area LBA tracts be leased and mined. The five-foot drawdown limit shown in Figure 4-5 

extends west beyond the Turner Ranch on Bates Creek. However, groundwater level drawdowns 

in the coal seam aquifer that are due to mine pit dewatering have been completely overshadowed 

by the dewatering effects on the coal seam aquifer as a result of coal bed natural gas (CBNG) 

development in this area. It is very unlikely that mine pit dewatering alone has had or will have 

any measurable effect on the Wyodak coal seam aquifer as far west as the Turner Ranch on 

Bates Creek. 

The statement in Section 3.5.2.1 that “springs are uncommon and none have been identified 

within the general analysis areas of these six LBA tracts” is factual. It is unclear but assumed the 

springs that you refer to in your comment are located within the Bates Creek watershed. Bates 

Creek is a major tributary of Antelope Creek, and the mouth of Bates Creek is located roughly 10 

miles southwest of the western edge of the South Porcupine LBA Tract, the closest of the six 

Wright Area LBA tracts to Bates Creek. 

The Final EIS has been updated to include the results of BLM’s regional groundwater flow 

model, which illustrates the areal extent and degree of drawdown that is associated with the 

mining operations and the CBNG development operations in the PRB. The groundwater flow 

model used in this NEPA analysis is included in BLM’s PRB Coal Review Task 3B Report. The 

PRB Coal Review is used by BLM to evaluate the cumulative impacts of leasing federal coal in 

the PRB. The groundwater model and its results are described in detail in the Task 3B Report 

and can be reviewed on the BLM High Plains District website. Figures depicting the effects of 

coal mine-related dewatering only and CBNG development-related dewatering only are included 

in the Final EIS; these data indicate that the effects of mine dewatering have not and will not in 

the future extend to the west far enough to effect groundwater resources in the Bates Creek 

watershed. 

The springs that you describe in your comment are much removed from the general Wright 

analysis area; therefore, the past and present hydrogeologic conditions responsible for these 

once-significant springs and their demise were not investigated in detail in this EIS. However, 

based on the general hydrologic characteristics of the geologic units that occur in the eastern part 

of the PRB, it is reasonable to assume that the springs were and are presently associated with a 

shallow groundwater source, such as recent alluvial deposits or possibly the Wasatch Formation, 

rather than a deep groundwater source, such as the Wyodak coal seam. 

Springs and seeps do not commonly occur within the PRB due to many factors, including the 

semi-arid climate and the lithologic characteristics of the shallow geologic units that crop out on 

the surface of the basin. In general, springs and seeps that occur within the drainages of the PRB 

are typically associated with shallow groundwater that is stored in the streams’ recent alluvial 
45 

deposits. Determining the cause of the changes to the “spring holes” on Bates Creek that you 

have witnessed is beyond the scope of this EIS. However, if these springs are indeed associated 

with shallow Bates Creek alluvial groundwater, those changes may be the result of changes that 

have occurred to the stream’s hydrologic flow regime, which could be the result of the extreme 

drought conditions that have prevailed in the PRB since 1999. 

We encourage you to advise the BLM High Plains District Office in Casper of the spring 

locations so that they can be included in the administrative record for this EIS. Those locations 

should be made available to the WDEQ as well. If nearby lands are leased for coal in the future, 

their locations should be made available to the coal lessee for study purposes. 

Twenty-eight wells have been installed in the backfill at the North Antelope Rochelle Mine to 

monitor water levels and water quality. As required by the WDEQ, the mine also monitors water 

levels and water quality in many wells that are completed in the water-bearing units that are 

affected by mining, including alluvial deposits, clinker deposits, Wasatch overburden strata, Fort 

Union coal beds, and underburden strata. The monitor well you cite (PRCC-21B) is a WDEQ 

required monitor well. Monitoring data and other required information, such as the well’s 

completion record, is reported to WDEQ by the mine operator. We understand that this data is 

made available to the public, and the WDEQ/LQD office, either in Sheridan or Cheyenne, should 

be able to assist you with locating all the information on this or any of the mine’s other 

monitoring wells. It should be noted that it is unlikely a well used for stock watering would also 

be used by a mine as a monitoring well due to the fact that its water level would be greatly 

affected by pumping, negating its usefulness to monitor the effects of mine-related dewatering 

and drawdown. 

Comment Response 65: Mining companies restrict access to their permitted lands as a safety 

precaution. There are dangers on mine sites; companies control visitors to protect the public’s 

safety and prevent accidents. However, the controlled mine areas should be well posted to 

prevent the public from accidently entering these areas. Please contact the mine company 

regarding your access to grazing areas and any affiliated problems that may have arisen 

regarding their employees’ conduct and customer service. It is our understanding that all of the 

PRB mines continue to welcome visitors and will gladly conduct tours of their operations 

provided that they are contacted in advance of your visit. 

Comment Response 66: Thank you for your comment. We have updated and revised Section 

3.5.1.2.1.1 (North, South, and West Hilight Field LBA Tracts), Section 3.5.1.2.1.2 (West Jacobs 

Ranch LBA Tract), and Section 3.5.1.2.1.3 (North and South Porcupine LBA Tracts) in the Final 

EIS. We revised the discussions on identifying and predicting the extent of drawdown in the 

Wyodak coal aquifer that is specifically attributable to mine dewatering. 

Comment Response 67: The Biological Assessment (Appendix G) has been revised extensively 

for the Final EIS. A discussion on the location and extent of the potential wetland areas was 

added for each LBA tract including separate maps to depict those areas within the respective 
46 

tract’s general analysis area. Also added were more detailed descriptions of each tract’s existing 

environments and the potentially suitable habitats for each listed species. Dates of all surveys 

conducted for ULTs are provided in the EIS. 

Comment Response 68: Previous surveys for ULT have been conducted within the adjacent 

mines’ existing permit areas in order to evaluate the potential effects of leasing federal coal 

reserves within those areas and are contained within the respective BLM EIS documents. 

References are made to those sources in Appendix G including the survey dates, surveyors’ 

names, and results. 

Comment Response 69: The Biological Assessment (Appendix G) has been revised extensively 

for the Final EIS. Appendix G states that all potentially suitable habitat within the general 

analysis area of each LBA tract will be surveyed for ULT three consecutive years during the 

plant’s flowering period in order to determine the presence of the species prior to any surface 

disturbing activities. 

BLM’s and USFS’s special coal lease stipulations are identified in Appendix D of the Final EIS 

and they include a threatened, endangered, candidate, or other special status plant and animal 

special stipulation. This stipulation was developed in concert with USFWS and specifically 

states, “Any potential habitat that has not already been surveyed for Ute ladies’-tresses within the 

project area shall be identified and surveyed prior to surface mining activities.” 

Comment Response 70: The Biological Assessment (Appendix G) has been revised extensively 

for the Final EIS. Further analysis determined that no suitable habitat for blowout penstemon is 

present within the general analysis areas of the six Wright Area LBA tracts; Appendix G has 

been revised to clarify that finding. BLM’s and USFS’s special coal lease stipulations are 

identified in Appendix D of the Final EIS. The threatened, endangered, candidate, or other 

special status plant and animal species coal lease stipulation that was developed in concert with 

the USFWS is included. With the guidance and support of USFWS, wildlife mitigation 

measures will also be prescribed at the permitting stage. 

Comment Response 71: Thank you for your comment. We revised Section 3.12 in the Final 

EIS to include additional information regarding cultural resources. BLM initiated Native 

American consultation with the tribes on December 16, 2008 in regard to the Wright Area EIS. 

Preliminary analysis of the Class III inventories associated with the six Wright Area LBA coal 

tracts indicates that there are likely archeological sites that may be of tribal significance. Once 

the Class III inventories are fully analyzed, BLM will consult the tribes in accordance with the 

National Historic Preservation Act regulations. Because there are numerous cultural resources in 

the Wright EIS general analysis area, BLM will conduct site-specific tribal consultation 

individually on each lease. BLM will consult with the Cheyenne River Sioux Tribe, and other 

tribes, in relation to the specific culturally significant areas that are located within the Wright EIS 

general analysis area beginning in the summer or fall of 2010. 
47 

Comment Response 72: We revised and updated Section 3.3.2.1 and 3.3.2.2 in the Final EIS to 

include additional information regarding the different forms of modern unconventional 

development of “continuous” hydrocarbon accumulations, including tight sand and shale gas. 

In the Final EIS, we added a new subsection to the unconventional oil and gas analysis (Section 

3.3.2.1.2) in order to address the potential for the development of continuous oil and gas 

resources in the PRB. Subsection 3.3.2.1.2.1 addresses CBNG production in the PRB and in the 

general Wright analysis area. 

In addition, the potential impacts of coal leasing upon both conventional and unconventional oil 

and gas development in the PRB and general Wright analysis area have been added to Section 

3.3.2.2 in the Final EIS. A discussion covering secondary recovery methods used to enhance 

production from old fields with declining production has also been included in the conventional 

oil and gas resources section (3.3.2.1.1), as was the potential for increased conventional oil and 

gas exploration due to increased prices. 

 

The development of natural gas from hydrocarbon rich shale and tight sand formations is a very 

recent phenomenon in the oil and gas industry. The industry’s ability to drill and complete wells 

that are capable of tapping these unconventional hydrocarbon resources is largely due to 

evolving state-of-the-art directional drilling and new formation fracturing technology. As 

discussed in the Final EIS, the oil and gas industry has only recently begun to explore the 

potential proficiency and feasibility of developing these continuous hydrocarbon resources in the 

PRB. 

Summary of the Wright Area Coal Lease Applications Draft EIS Public Hearing 

Two statements were given as testimony at the Wright Area Coal Lease Applications 

Draft EIS Public Hearing held on July 29, 2009 in Gillette, Wyoming. The complete transcript is 

available for public review at the BLM High Plains District Office in Casper. 

Shannon Anderson, speaking on behalf of the Powder River Basin Resource Council 

(PRBRC), described a number of the group’s concerns in regard to Powder River Basin coal 

mining including reclamation, groundwater impacts, and loss of wildlife habitat and livestock 

grazing areas. Ms. Anderson’s testimony highlighted the formal comment letter that was 

submitted to BLM by the PRBRC during the Draft EIS public comment period. Their letter is 

included in this appendix. 

Brad Mohrmann delivered testimony as a Sierra Club representative. Mr. Mohrmann 

asked the BLM to consider several issues including whether federal coal should currently be 

leased in light of the slow economy, decline in coal production, increased wind power electric 

generation, and the push to generate clean renewable energy. Concerns with reclamation, 

bonding, new climate change legislation, and the economics of leasing coal at this time were also 

presented.