-

 

 

 

 

 

 

United States Department of The Interior 

Office of Surface Mining Reclamation and Enforcement 

Columbian Sharp Tailed Grouse 

Trapper Mine Reclamation 

Trapper Mine 

Environmental Assessment 

Trapper Mine 

Moffat County, Colorado 

Federal Coal Leases C-07519 and C-079641 

Mining Plan Modification 

April 2016 

Prepared by: 

U.S. Department of the Interior
	

Office of Surface Mining Reclamation and Enforcement Program Support Division
	

1999 Broadway, Suite 3320
	

Denver, CO 80202
	

PH: 303-293-5000 / FAX: 303-293-5032
	

Prepared in cooperation with:
	

US Bureau of Land Management, Colorado Department of Natural Resources, 

Colorado Department of Public Health and Environment, and Moffat and Rio Blanco Counties (Colorado)
	

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Acronyms and Abbreviations 

Acronyms and Abbreviations 

2009 Approval Mining Plan Approval Document Signed by the Assistant Secretary for Land and 

Minerals Management for the Trapper Mine in 2009 

°F degrees Fahrenheit 

μg/g microgram per gram 

μg/L microgram per liter 

μg/m2 microgram per square meter 

μg/m3 microgram per cubic meter 

AADT Annual Average Daily Traffic 

AAI Agapito Associates, Inc. 

ACHP Advisory Council on Historic Preservation 

AMPD Air Markets Program Data 

amsl above mean sea level 

ANFO ammonium nitrate and fuel oil 

AP-42 Compilation of Air Pollutant Emission Factors 

APCD Air Pollution Control Division 

APE area of potential effect 

APEN Air Pollutant Emission Notice 

AQCR Air Quality Control Regions 

ASLM Assistant Secretary for Land and Minerals Management 

AVF alluvial valley floor 

BA Biological Assessment 

BART Best Available Retrofit Technology 

BGEPA Bald and Golden Eagle Protection Act 

BLM Bureau of Land Management (U.S.) 

BMP Best Management Practice 

BO Biological Opinion 

CAA Clean Air Act of 1970 

CARMMS Colorado Air Resource Management Modeling Study 

CCR Coal Combustion Residual 

CDOT Colorado Department of Transportation 

CDPHE Colorado Department of Public Health and Environment 

CDPS Colorado Discharge Permit System 

CDRMS Colorado Division of Reclamation, Mining and Safety 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

cfs cubic feet per second 

CH4 methane 

CHIA Cumulative Hydrologic Impact Assessment 

CIAA cumulative impact analysis area 

cm centimeter 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification AA-1 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Acronyms and Abbreviations 

CNHP Colorado Natural Heritage Program 

CO carbon monoxide 

CO2 carbon dioxide 

CO2e carbon dioxide equivalent 

COGCC Colorado Oil and Gas Conservation Commission 

CPW Colorado Parks and Wildlife 

CR County Road 

Craig Station Craig Generating Station 

CRS Colorado Revised Statutes 

CSCMRA Colorado Surface Coal Mining Reclamation Act of 1979 

CSLB Colorado State Land Board 

CWA Clean Water Act 

DAU Data Analysis Unit 

dB decibel 

dB(A) decibel on an A-weighted scale 

District Court U.S. District Court in the State of Colorado 

DNR Department of Natural Resources (Colorado) 

DOI Department of the Interior (U.S.) 

DOLA Department of Local Affairs (Colorado) 

dv deciview 

EA Environmental Assessment 

EDCC Economic Development Council of Colorado 

EGU electric generating unit 

EIS Environmental Impact Statement 

EO Executive Order 

EP Extraction Procedure 

ESA Endangered Species Act of 1973 

FCLAA Federal Coal Leasing Amendments Act of 1976 

FCPP Four Corners Power Plant 

Fe Iron 

FLPMA Federal Land Policy and Management Act of 1976 

FMU Fish Management Unit 

FR Federal Register 

GHG greenhouse gas 

GMU Game Management Unit 

gpm gallons per minute 

GWP global warming potential 

H:V Horizontal to Vertical 

HAP hazardous air pollutant 

Hayden Station Hayden Generating Station 

HCFC hydrochloroflourocarbons 

HFC hydrofluorocarbons 

Hg2+ oxidized mercury 

IF Isolated Find 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification AA-2 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Acronyms and Abbreviations 

IME IME Consulting 

km kilometer 

kV kilovolt 

lb/GWh pounds of pollutant per gigawatt – electric output 

lb/yr pounds per year 

LSFO Little Snake Field Office (BLM) 

MATS Mercury and Air Toxics Standards 

MBTA Migratory Bird Treaty Act 

MDN Mercury Deposition Network 

MFP Management Framework Plan 

mg/L milligrams per liter 

MLA Mineral Leasing Act of 1920 

MLRA Major Land Resource Area 

MMBtu Million British thermal unit 

MMPA Mining and Minerals Policy Act of 1970 

MMT million metric tons 

MPDD Mining Plan Decision Document 

MT metric tons 

mtpy million tons per year 

MW megawatt 

N2O nitrous oxide 

NAAQS National Ambient Air Quality Standards 

NEPA National Environmental Policy Act of 1969 

NHPA National Historic Preservation Act 

NMEP Navajo Mine Energy Project 

NO2 nitrogen dioxide 

NOX nitrogen oxide 

NRCS Natural Resources Conservation Service 

NRHP National Register of Historic Places 

NSPS New Source Performance Standards 

O3 ozone 

OSMRE Office of Surface Mining Reclamation and Enforcement 

P.M. Prime Meridian 

PAP Permit Application Package 

PFC perfluorocarbons 

PFYC Potential Fossil Yield Classification 

PM10 particulate matter 10 microns or less in diameter 

PM2.5 particulate matter 2.5 microns or less in diameter 

ppb parts per billion 

ppm parts per million 

PPV peak particle velocity 

PR Permit Revision 

PSD Prevention of Significant Deterioration 

R Range 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification AA-3 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Acronyms and Abbreviations 

R2P2 Resource Recovery and Protection Plan 

RCRA Resource Conservation and Recovery Act 

RIPRAP Recovery Implementation Program Recovery Action Plan 

RMP Resource Management Plan 

RN Permit Renewal 

ROD Record of Decision 

SCC social cost of carbon 

SCR Selective Catalytic Reduction 

SF6 sulfur hexafluoride 

SH State Highway 

SHPO State Historic Preservation Office(r) 

SIP State Implementation Plan 

SMCRA Surface Mining Control and Reclamation Act of 1977 

SNCR Selective Non-Catalytic Reduction 

SO2 sulfur dioxide 

SO4 sulfate 

SPCC Plan Spill Prevention, Control, and Countermeasure Plan 

T Township 

TDS total dissolved solids 

TMI Trapper Mining Inc. 

tpy tons per year 

TRI Toxic Release Inventory 

TSS total suspended sediment 

USACE U.S. Army Corps of Engineers 

U.S. United States 

USC United States Code 

USDA U.S. Department of Agriculture 

USEPA U.S. Environmental Protection Agency 

USFS U.S. Forest Service 

USFWS U.S. Fish and Wildlife Service 

USGS U.S. Geological Survey 

VER Valid Existing Rights 

VOC volatile organic compound 

VRI Visual Resource Inventory 

VRM Visual Resource Management 

WOTUS Waters of the U.S. 

TRI Toxic Release Inventory 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification AA-4 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 
Table of Contents 

Contents 

Acronyms and Abbreviations............................................................................................................... AA-1
 

1.0 Purpose and Need ............................................................................................................................ 1-1
 

1.1 Introduction ................................................................................................................................. 1-1
	

1.2 Background................................................................................................................................. 1-1
	

1.2.1 Site History.................................................................................................................... 1-1
	

1.2.2 Project Background ...................................................................................................... 1-2
	

1.2.3 Statutory and Regulatory Background......................................................................... 1-5
	

1.3 Purpose and Need...................................................................................................................... 1-6
	

1.3.1 Purpose......................................................................................................................... 1-6
	

1.3.2 Need.............................................................................................................................. 1-6
	

1.4 Relationship to Statutes, Regulations, and Other Agency Plans.............................................. 1-6
	

1.4.1 Statutes and Regulations ............................................................................................. 1-6
	

1.4.2 Other Agency Plans...................................................................................................... 1-9
	

1.5 Authorizing Actions................................................................................................................... 1-10
	

1.6 Outreach and Issues ................................................................................................................ 1-10
	

2.0 Proposed Action and Alternatives ................................................................................................. 2-1
 

2.1 Trapper Mine SMCRA Permit .................................................................................................... 2-1
	

2.2 Project Area ................................................................................................................................ 2-1
	

2.3 Description of Existing Mining and Reclamation Operations .................................................... 2-5
	

2.3.1 Trapper Mine Support Facilities ................................................................................. 2-10
	

2.4 Alternative A - Proposed Action ............................................................................................... 2-13
	

2.4.1 Proposed Mine Operation Components within the Project Area .............................. 2-13
	

2.4.2 Existing and Proposed Disturbance........................................................................... 2-13
	

2.4.3 Mining Operations....................................................................................................... 2-14
	

2.4.4 Project Environmental Protection and Mitigation Features ....................................... 2-15
	

2.5 Alternative B – Disapproval of Mining Plan by ASLM ............................................................. 2-17
	

2.6 Alternative C – No Action Alternative....................................................................................... 2-18
	

2.7 Alternatives Considered but Eliminated from Further Study................................................... 2-18
	

2.7.1 Underground Mining Alternative................................................................................. 2-18
	

2.7.2 Air Quality Mitigation Alternatives .............................................................................. 2-21
	

3.0 Affected Environment ...................................................................................................................... 3-1
 

3.1 General Setting........................................................................................................................... 3-2
	

3.2 Topography................................................................................................................................. 3-3
	

3.3 Air and Climate Resources......................................................................................................... 3-3
	

3.3.1 Airshed Boundary ......................................................................................................... 3-3
	

3.3.2 Regional Climate .......................................................................................................... 3-3
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification i 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 
3.3.5 Regional Air Quality.................................................................................................... 3-12
	

3.3.6 Industrial Source Emissions Inventory....................................................................... 3-14
	

3.3.7 Greenhouse Gas Emissions and Climate Change.................................................... 3-15
	

3.3.8 Black Carbon .............................................................................................................. 3-18
	

3.4 Geology and Minerals............................................................................................................... 3-19
	

3.4.1 Geology....................................................................................................................... 3-19
	

3.4.2 Mineral Resources...................................................................................................... 3-19
	

3.5 Water Resources...................................................................................................................... 3-20
	

3.5.1 Surface Water............................................................................................................. 3-20
	

3.5.2 Groundwater ............................................................................................................... 3-27
	

3.6 Soils........................................................................................................................................... 3-31
	

3.6.1 Moffat County Soil Mapping Units.............................................................................. 3-32
	

3.7 Vegetation................................................................................................................................. 3-40
	

3.7.1 Mountain Shrub Community....................................................................................... 3-43
	

3.7.2 Big Sagebrush-Grass Community ............................................................................. 3-43
	

3.7.3 Reclaimed Rangeland ................................................................................................ 3-43
	

3.7.4 Disturbed Area............................................................................................................ 3-43
	

3.7.5 Noxious Weeds........................................................................................................... 3-43
	

3.8 Wetlands and Riparian Zones.................................................................................................. 3-44
	

3.8.1 Wetlands ..................................................................................................................... 3-44
	

3.8.2 Riparian Areas ............................................................................................................ 3-45
	

3.9 Fish and Wildlife Resources..................................................................................................... 3-45
	

3.9.1 Regulatory Background.............................................................................................. 3-45
	

3.9.2 Analysis Areas ............................................................................................................ 3-45
	

3.9.3 Nongame Species ...................................................................................................... 3-46
	

3.9.4 Game Species ............................................................................................................ 3-49
	

3.9.5 Fish.............................................................................................................................. 3-56
	

3.10 Special Status Species............................................................................................................. 3-56
	

3.10.1 Federally Threatened, Endangered, and Candidate Species................................... 3-62
	

3.10.2 State Listed and BLM Sensitive Species ................................................................... 3-67
	

3.11 Cultural Resources ................................................................................................................... 3-73
	

3.11.1 Introduction ................................................................................................................. 3-73
	

3.11.2 Definition of the APE................................................................................................... 3-73
	

3.11.3 American Indian Concerns ......................................................................................... 3-73
	

3.11.4 Historic Properties ...................................................................................................... 3-74
	

3.11.5 Regional Culture History............................................................................................. 3-74
	

3.11.6 Previous Surveys........................................................................................................ 3-75
	

3.11.7 Known Cultural Resources......................................................................................... 3-75
	

3.12 Socioeconomics........................................................................................................................ 3-79
	

3.13 Environmental Justice .............................................................................................................. 3-82
	

3.14 Recreation................................................................................................................................. 3-83
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification ii 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

Table of Contents 

3.3.3 Local Climate and Meteorology.................................................................................... 3-3
	

3.3.4 Regulatory Requirements ............................................................................................ 3-4
	
Table of Contents 

3.15 Visual Resources...................................................................................................................... 3-83
	

3.15.1 BLM Visual Resources Management ........................................................................ 3-83
	

3.15.2 Lighting........................................................................................................................ 3-85
	

3.16 Paleontological Resources....................................................................................................... 3-85
	

3.17 Access and Transportation....................................................................................................... 3-85
	

3.18 Solid Waste............................................................................................................................... 3-86
	

3.19 Noise ......................................................................................................................................... 3-87
	

3.20 Livestock Grazing ..................................................................................................................... 3-89
	

3.21 Prime Farmlands ...................................................................................................................... 3-90
	

3.22 Alluvial Valley Floors ................................................................................................................ 3-90
	

4.0 Environmental Consequences........................................................................................................ 4-1
 

4.1 Introduction ................................................................................................................................. 4-1
	

4.1.1 Summary of Direct and Indirect Environmental Impacts............................................. 4-2
	

4.2 Topography................................................................................................................................. 4-9
	

4.2.1 Alternative A – Proposed Action .................................................................................. 4-9
	

4.2.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM ................ 4-9
	

4.2.3 Mitigation Measures...................................................................................................... 4-9
	

4.3 Air and Climate Resources......................................................................................................... 4-9
	

4.3.1 Alternative A – Proposed Action Alternative................................................................ 4-9
	

4.3.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM .............. 4-23
	

4.3.3 Mitigation Measures.................................................................................................... 4-24
	

4.4 Geology and Minerals............................................................................................................... 4-25
	

4.4.1 Alternative A – Proposed Action ................................................................................ 4-25
	

4.4.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM .............. 4-26
	

4.4.3 Mitigation Measures.................................................................................................... 4-26
	

4.5 Water Resources...................................................................................................................... 4-26
	

4.5.1 Alternative A – Proposed Action ................................................................................ 4-26
	

4.5.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM .............. 4-33
	

4.5.3 Mitigation Measures.................................................................................................... 4-34
	

4.6 Soils........................................................................................................................................... 4-35
	

4.6.1 Alternative A – Proposed Action ................................................................................ 4-35
	

4.6.2 Alternatives B – Disapproval of the Mining Plan Modification by the ASLM ............ 4-36
	

4.6.3 Mitigation Measures.................................................................................................... 4-36
	

4.7 Vegetation................................................................................................................................. 4-36
	

4.7.1 Alternative A – Proposed Action ................................................................................ 4-36
	

4.7.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM .............. 4-37
	

4.7.3 Mitigation Measures.................................................................................................... 4-37
	

4.8 Wetlands and Riparian Zones.................................................................................................. 4-37
	

4.8.1 Alternative A – Proposed Action ................................................................................ 4-37
	

4.8.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM .............. 4-38
	

4.8.3 Mitigation Measures.................................................................................................... 4-38
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification iii 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 
Table of Contents 

4.9 Fish and Wildlife Resources..................................................................................................... 4-38
	

4.9.1 Alternative A – Proposed Action ................................................................................ 4-38
	

4.9.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM .............. 4-41
	

4.9.3 Mitigation Measures.................................................................................................... 4-41
	

4.10 Special Status Species............................................................................................................. 4-41
	

4.10.1 Alternative A – Proposed Action ................................................................................ 4-41
	

4.10.2 Indirect Impacts........................................................................................................... 4-44
	

4.10.3 Alternative B – Disapproval of the Mining Plan Modification by the ASLM .............. 4-49
	

4.10.4 Mitigation Measures.................................................................................................... 4-49
	

4.11 Cultural Resources ................................................................................................................... 4-50
	

4.11.1 Alternative A – Proposed Action ................................................................................ 4-51
	

4.11.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM .............. 4-51
	

4.11.3 Mitigation Measures.................................................................................................... 4-52
	

4.11.4 American Indian Concerns ......................................................................................... 4-53
	

4.12 Socioeconomics........................................................................................................................ 4-53
	

4.12.1 Alternative A – Proposed Action ................................................................................ 4-53
	

4.12.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM .............. 4-53
	

4.12.3 Mitigation Measures.................................................................................................... 4-54
	

4.13 Visual Resources...................................................................................................................... 4-54
	

4.13.1 Alternative A – Proposed Action ................................................................................ 4-55
	

4.13.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM .............. 4-55
	

4.14 Paleontological Resources....................................................................................................... 4-55
	

4.14.1 Alternative A – Proposed Action ................................................................................ 4-55
	

4.14.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM .............. 4-56
	

4.14.3 Mitigation Measures.................................................................................................... 4-56
	

4.15 Access and Transportation....................................................................................................... 4-56
	

4.15.1 Alternative A – Proposed Action ................................................................................ 4-56
	

4.15.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM .............. 4-57
	

4.15.3 Mitigation Measures.................................................................................................... 4-57
	

4.16 Solid Waste............................................................................................................................... 4-57
	

4.16.1 Alternative A – Proposed Action ................................................................................ 4-57
	

4.16.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM .............. 4-58
	

4.16.3 Mitigation Measures.................................................................................................... 4-59
	

4.17 Noise ......................................................................................................................................... 4-59
	

4.17.1 Alternative A – Proposed Action ................................................................................ 4-59
	

4.17.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM .............. 4-59
	

4.17.3 Mitigation Measures.................................................................................................... 4-60
	

5.0 Cumulative Impacts.......................................................................................................................... 5-1
 

5.1 Introduction ................................................................................................................................. 5-1
	

5.2 Past and Present Actions ........................................................................................................... 5-2
	

5.3 Reasonably Foreseeable Future Actions .................................................................................. 5-4
	

5.4 Cumulative Impacts .................................................................................................................... 5-5
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification iv 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 
Table of Contents 

5.4.1 Topography................................................................................................................... 5-5
	

5.4.2 Air and Climate Resources........................................................................................... 5-5
	

5.4.3 Geology and Minerals................................................................................................... 5-9
	

5.4.4 Water Resources ........................................................................................................ 5-10
	

5.4.5 Soils............................................................................................................................. 5-12
	

5.4.6 Vegetation................................................................................................................... 5-13
	

5.4.7 Wetlands and Riparian Zones.................................................................................... 5-13
	

5.4.8 Fish and Wildlife Resources....................................................................................... 5-13
	

5.4.9 Special Status Species............................................................................................... 5-14
	

5.4.10 Cultural Resources ..................................................................................................... 5-15
	

5.4.11 Socioeconomics.......................................................................................................... 5-16
	

5.4.12 Visual Resources........................................................................................................ 5-17
	

5.4.13 Paleontological Resources......................................................................................... 5-17
	

5.4.14 Access and Transportation......................................................................................... 5-18
	

5.4.15 Solid Waste................................................................................................................. 5-18
	

5.4.16 Noise ........................................................................................................................... 5-19
	

6.0 Consultation and Coordination....................................................................................................... 6-1
 

6.1 Public Comment Process........................................................................................................... 6-1
	

6.2 U.S. Fish and Wildlife Service Section 7 Consultation.............................................................. 6-2
	

6.3 American Indian Consultation .................................................................................................... 6-3
	

6.4 Cooperating Agencies ................................................................................................................ 6-3
	

6.5 Preparers .................................................................................................................................... 6-4
	

7.0 References..........................................................................................................................................7-1
 

List of Appendices 

Appendix A Legal Notice and Outreach Letter 

Appendix B Air Technical Support Document 

Appendix C Biological Opinion 

Appendix D American Indian Consultation 

Appendix E Public Comments and Responses 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification v 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 
 

Table of Contents 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

vi 
List of Tables 

List of Tables
 

Table 1-1 Public Outreach Comments Categorized by Key Resource Category................................. 1-11
	

Table 2-1 Summary of Phased Bond Release Acreages in the Project Area ...................................... 2-10
	

Table 2-2 Summary of Disturbance in Project Area for Alternative A – Proposed Action.................... 2-14
	

Table 2-3 Proposed Project Area Mine Plan.......................................................................................... 2-15
	

Table 2-4 Summary of Environmental Commitments from Trapper Mining Inc. PAP.......................... 2-15
	

Table 3-1 Resources and Determination of Need for Further Analysis .................................................. 3-1
	

Table 3-2 Monthly Temperature and Precipitation Statistics: Craig, Colorado, and Vicinity................. 3-7
	

Table 3-3 National Ambient Air Quality Primary Standards .................................................................... 3-9
	

Table 3-4 Prevention of Significant Deterioration Increments ............................................................... 3-10
	

Table 3-5 MATS Emission Requirements.............................................................................................. 3-11
	

Table 3-6 Regional Air Quality................................................................................................................ 3-12
	

Table 3-7 Craig Station and Hayden Station: Reported Actual Emissions (2014) ............................... 3-15
	

Table 3-8 U.S. Greenhouse Gas Emissions Allocated to Economic Sectors....................................... 3-17
	

Table 3-9 U.S. Greenhouse Gas Emissions and Sinks......................................................................... 3-17
	

Table 3-10 U.S. Sulfur Dioxide (Indirect GHG) Emissions ...................................................................... 3-18
	

Table 3-11 Soil Classifications within the Project Area............................................................................ 3-35
	

Table 3-12 Vegetation Communities ........................................................................................................ 3-40
	

Table 3-13 Migratory Birds Known to Occur and with the Potential to Occur in the Vicinity of
	

the Project Area...................................................................................................................... 3-47
	

Table 3-14 Special Status Species in Moffat County............................................................................... 3-59
	

Table 3-15 Columbian Sharp-tailed Grouse Lek Counts in the Vicinity of the SMCRA Permit
	

Area Boundary........................................................................................................................ 3-68
	

Table 3-16 Summary of Previous Surveys within SMCRA Permit Boundary Plus 0.25-mile
	

Buffer....................................................................................................................................... 3-75
	

Table 3-17 Summary of Identified Sites within Project Area and SMCRA Permit Boundary
	

Plus 0.25-mile Buffer .............................................................................................................. 3-78
	

Table 3-18 Population Estimates.............................................................................................................. 3-80
	

Table 3-19 Per Capita Personal Income .................................................................................................. 3-80
	

Table 3-20 Mean Household Income ....................................................................................................... 3-80
	

Table 3-21 Housing Characteristics ......................................................................................................... 3-81
	

Table 3-22 Example Noise Sources and Sound Levels .......................................................................... 3-88
	

Table 3-23 Colorado Maximum Permissible Noise Levels...................................................................... 3-88
	

Table 3-24 Open Pit Mining Equipment Noise Levels ............................................................................. 3-88
	

Table 4-1 Comparison of Direct and Indirect Impacts ............................................................................. 4-2
	

Table 4-2 Projected Trapper Mine PM10 and PM 2.5 Emissions through 2025...................................... 4-11
	

Table 4-3 Worst-Case Year (2020) Trapper Mine PM10 and PM2.5 Direct Emissions .......................... 4-11
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification vii 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 
 

Table 4-4 Direct Mining Emissions for Worst-Case Year (2020) Fuel Combustion and 

Blasting ................................................................................................................................... 4-12
	

Table 4-5 Direct Mining HAPs Emissions for Worst-Case Year (2020) – Fuel Combustion 

(tpy) ......................................................................................................................................... 4-12
	

Table 4-6 Direct Mining GHG Emissions for Worst-Case Year (2020) (tons and MT per
	

year) ........................................................................................................................................ 4-13
	

Table 4-7 Direct Mining Related Emissions for Worst-Case Year (2020) – Black Carbon
	

(tpy) ......................................................................................................................................... 4-13
	

Table 4-8 Summary of Air Emission Controls – Craig Station............................................................... 4-14
	

Table 4-9 Indirect Coal Combustion Emissions (tpy)............................................................................. 4-15
	

Table 4-10 Actual 2014 Craig Station Mercury Emissions (lb/yr) as reported by Craig Station 

to CDPHE ............................................................................................................................... 4-16
	

Table 4-11 Estimated Craig Station Mercury Emissions from Trapper Mine Coal (lb/yr)....................... 4-16
	

Table 4-12 Indirect PM10 and PM2.5 Emissions from CCRs Placement at Trapper Mine....................... 4-17
	

Table 4-13 Indirect Emissions for Worst-Case Year (2020) Fuel Combustion: CCRs
	

Transfer by Truck to Trapper Mine ........................................................................................ 4-17
	

Table 4-14 Indirect GHG Emissions reported at CO2e for Coal Combustion and CCRs
	

Placement............................................................................................................................... 4-18
	

Table 4-15 AERMOD Modeling Results – Trapper Mine (all concentrations in μg/m3

).......................... 4-20
	

Table 4-16 Summary of Groundwater Quality Data for Selected Constituents ...................................... 4-32
	

Table 4-17 Disturbance to Soil Types, Proposed Action Alternative....................................................... 4-35
	

Table 4-18 Historic Properties Within Indirect APE ................................................................................. 4-50
	

Table 5-1 CIAA and CIAA Time Frame by Resource.............................................................................. 5-1
	

Table 6-1 Participants from Cooperating Agencies ................................................................................. 6-3
	

Table 6-2 Office of Surface Mining Reclamation and Enforcement ........................................................ 6-4
	

Table 6-3 Consultants............................................................................................................................... 6-4
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification viii 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

List of Tables 
List of Figures 

List of Figures
 

Figure 1-1 Project Location........................................................................................................................ 1-3
	

Figure 1-2 Mining Limits Under the Joint Proposed Remedy................................................................... 1-7
	

Figure 2-1 Project Area – Previous and Proposed Disturbance............................................................... 2-3
	

Figure 2-2 Proposed Mine Operation Components .................................................................................. 2-7
	

Figure 2-3 CDRMS Bond Release Areas................................................................................................ 2-11
	

Figure 2-4 Proposed Mining Outside the Project Area ........................................................................... 2-19
	

Figure 3-1 Airshed Boundary..................................................................................................................... 3-5
	

Figure 3-2 Trapper Mine Wind Rose 3/10/2015 – 12/10/2015 ................................................................. 3-8
	

Figure 3-3 Surface Water Resources ...................................................................................................... 3-21
	

Figure 3-4 Streamflow at No Name Gulch .............................................................................................. 3-25
	

Figure 3-5 Groundwater Resources ........................................................................................................ 3-29
	

Figure 3-6 NRCS Soil Mapping Units ...................................................................................................... 3-33
	

Figure 3-7 Vegetation............................................................................................................................... 3-41
	

Figure 3-8 Mule Deer Winter Ranges...................................................................................................... 3-51
	

Figure 3-9 Elk Ranges.............................................................................................................................. 3-52
	

Figure 3-10 Elk Population and Production Areas .................................................................................... 3-53
	

Figure 3-11 Moose Ranges ....................................................................................................................... 3-54
	

Figure 3-12 Black Bear Ranges................................................................................................................. 3-57
	

Figure 3-13 Colorado River Fish Critical Habitat....................................................................................... 3-63
	

Figure 3-14 Columbian Sharp-tailed Grouse Ranges............................................................................... 3-71
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification ix 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 
 

 

List of Figures 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

x 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 1.0 – Purpose and Need 

1.0 Purpose and Need1 

1.1 Introduction 

The Trapper Mine Federal Coal Leases, C-07519 and C-079641 Mining Plan Modification, 

Environmental Assessment (EA) has been prepared by the Office of Surface Mining Reclamation and 

Enforcement (OSMRE), Western Region, with assistance from cooperating agencies including: the 

Bureau of Land Management (BLM), Little Snake Field Office (LSFO); the State of Colorado, 

Department of Natural Resources (DNR) (including the Executive Director’s Office, Colorado Division of 

Reclamation, Mining and Safety [CDRMS], Colorado State Land Board [CSLB], and Colorado Parks and 

Wildlife [CPW]); Colorado Department of Public Health and Environment (CDPHE), Air Pollution Control 

Division (APCD); Moffat County Commissioners; and Rio Blanco County Natural Resources Department. 

The EA describes the environmental impacts that are anticipated to result from the current and future 

mining operations at the Trapper Mine from July 1, 2015, through the life of the mine within the portions 

of Federal Coal Leases C-07519 and C-079641 that lie within the approved Surface Mining Control and 

Reclamation Act of 1977 (SMCRA) permit area (the Project) (Figure 1-1). 

The EA review has been conducted in accordance with the National Environmental Policy Act of 1969 

(NEPA) and the Council on Environmental Quality (CEQ) regulations for implementing NEPA (40 Code 

of Federal Regulations [CFR] 1500-1508); the Department of the Interior’s (DOI’s) regulations for 

implementation of NEPA (43 CFR Part 46); the DOI’s Departmental Manual Part 516; and OSMRE’s 

Directive REG-1, Handbook on Procedures for Implementing the National Environmental Policy Act of 

1969 (OSMRE 1989). Information gathered from federal, state, and local agencies, Trapper Mining Inc. 

(TMI), and publicly available literature, as well as in-house OSMRE sources, such as the Trapper Mine 

Permit Application Package (PAP), were used in the preparation of this EA. 

NEPA requires federal agencies to disclose to the public the potential environmental impacts of projects 

they authorize and to make a determination as to whether the analyzed actions would “significantly” 

impact the environment. The term “significantly” is defined in 40 CFR 1508.27. If OSMRE determines 

that the Project would have significant impacts following the analysis in the EA, then an Environmental 

Impact Statement (EIS) would be prepared for the Project. If OSMRE determines that the potential 

impacts would not be “significant,” OSMRE would prepare a “Finding of No Significant Impact” to 

document this finding, and, accordingly, would not prepare an EIS. 

1.2 Background 

1.2.1 Site History 

The Trapper Mine is located approximately six miles (9.7 kilometers [km]) south of the City of Craig in 

Moffat County, Colorado, east of Colorado State Highway (SH) 13 (Figure 1-1). 

Utah International, Inc., a subsidiary of General Electric Company, began coal exploration in the Trapper 

Mine area in 1954. Once coal reserves were identified, Utah International, Inc. signed coal delivery 

contracts with four utility companies that owned the Craig Generating Station (Craig Station). At that 

time, Craig Station was owned by Colorado-Ute Electric Association, Inc., Salt River Project Agricultural 

Improvement and Power District, Tri-State Generation and Transmission Association, Inc., and Platte 

River Power Authority. Craig Station is a coal-powered, electricity generating facility capable of 

1 Italicized text denotes language inserted either in response to comments received on the EA (see Appendix E) or to clarify or 

update a topic based on new or additional information received. Each place where italicized text appears is denoted by a bar in 

the left hand margin. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

1-1 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 1.0 – Purpose and Need 

producing up to 1,264 megawatts (MW) of electricity. Construction began on the mine facilities in 1975. 

Mining operations began in 1977, with the first coal delivery occurring in 1978. 

In 1982, Utah International, Inc. formed a Colorado Corporation, called Trapper Mining Inc., to 

consolidate and hold the properties and rights to the Trapper Mine. In 1983, the four electric utility 

companies, mentioned above, purchased TMI from Utah International, Inc. In 1990, Colorado-Ute 

Electric Association, Inc. filed for bankruptcy, and, when the reorganization plan was finalized in 1992, 

Colorado-Ute Electric Association, Inc.’s interest in TMI was transferred to Tri-State Generation and 

Transmission Association, Inc. and PacifiCorp. 

Following the transfer of interests in TMI, the new owners formed a cooperative and incorporated the 

company as a Delaware Corporation on December 29, 1997. TMI is jointly owned by the cooperative 

members who include Salt River Project Agricultural Improvement and Power District, Platte River Power 

Authority, Tri-State Generation and Transmission Association, Inc., and PacifiCorp. 

TMI and its predecessors obtained rights to five tracts of federal coal from 1958 to 1980. Two of these 

tracts are covered by this EA. Federal Coal Lease C-07519 was issued by the BLM in June of 1958, and 

Federal Coal Lease C-079641 was issued by the BLM in October of 1962. Both leases were originally 

issued to General Electric Holdings, Inc. and subsequently assigned to TMI in 1990. 

In 1979, BLM completed the Final EIS for the Federal Coal Management Program and the Secretary of 

the Interior adopted this program for the management of coal resources on federal lands. The potential 

environmental impacts of leasing federal coal resources in Colorado and Wyoming were analyzed in the 

Final Green River - Hams Fork Regional Coal EIS (BLM 1980). The federal coal leases covered by this 

EA were issued prior to adoption of this program. As part of lease readjustments, Federal Coal leases 

C-07519 and C-079641 were subsequently evaluated through NEPA. A NEPA evaluation was released 

for readjustment of C-07519 on February 12, 1979, and for readjustment of C-079641 on September 28, 

1982 (BLM 1979 and BLM 1982, respectively). 

The Trapper Mine produces approximately 2.3 million tons per year (mtpy) and can produce a maximum 

of 2.6 mtpy based on permit limitations currently in place by the Clean Air Act of 1970 (CAA) permit 

issued by the CDPHE APCD. The Trapper Mine produces coal from the L Pit located on Federal Coal 

Lease C-079641. Future mining also is proposed in the N Pit, which is located partially within Federal 

Coal Lease C-07519. Coal is mined using dragline, truck and shovel, and highwall mining methods. 

Mining operations are described in detail in Chapter 2.0. The coal is transported by haul truck to the 

Craig Station located to the north of the mine. TMI currently has no provisions to transport coal to other 

locations. 

TMI operates the Trapper Mine under SMCRA Permit Number C-1981-010 issued by CDRMS in 

accordance with the approved Colorado State Coal Regulatory Program (30 CFR Part 906). Although 

SMCRA permits are issued based on the life-of-mine plans for the mining operation, under the Colorado 

Surface Coal Mining Reclamation Act of 1979 (CSCMRA) permits must be renewed every five years 

(34 33-101 et seq. Colorado Revised Statutes [CRS] 1973 as amended). 

1.2.2 Project Background 

On May 8, 2015, the United States (U.S.) District Court for the District of Colorado (the District Court) 

issued an Order related to NEPA compliance regarding the mining plan modification approval document 

signed by the Assistant Secretary for Land and Minerals Management (ASLM) for the Trapper Mine in 

2009 (2009 Approval). The Order in WildEarth Guardians v. U.S. Office of Surface Mining Reclamation 

and Enforcement et al., 104 F. Supp. 3d 1208 (D Colo. 2015) concluded: 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

1-2 
Chapter 1.0 – Purpose and Need 

Figure 1-1 Project Location 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

1-3 
 

Chapter 1.0 – Purpose and Need 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

1-4 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 1.0 – Purpose and Need 

“[OSMRE] violated NEPA by failing to notify the public of and involve the public in the 

preparation of the Colowyo and Trapper EAs and by failing to notify the public once the 

EAs had been completed and the [findings of no significant impacts] had been issued. 

[OSMRE] also violated NEPA by failing to take a hard look at the direct and indirect 

effects of the increased mining operations before determining that there would be no 

significant impact on the environment. The Secretary of the Interior violated NEPA by 

approving both of these mining plan modifications in spite of these defects.” 

In order to address the deficiencies identified by the District Court, this EA was completed pursuant to 

the Joint Proposed Remedy, proposed by OSMRE, TMI and WildEarth Guardians and approved by the 

District Court on September 14, 2015. As part of the District Court-approved remedy for the Project, 

OSMRE agreed to conduct a new, prospective NEPA analysis-this EA-that includes public participation 

components, on or before April 30, 2016. The EA discloses the potential for direct, indirect, and 

cumulative impacts to the environment from the Project. 

As part of the Joint Proposed Remedy, TMI agreed to on-the-ground restrictions for mining activities on 

Federal Coal Leases C-07519 and C-079641 during the preparation of this EA, including: 1) limiting 

mining activities to lands permitted by CDRMS as of July 1, 2015; 2) limiting disturbance to lands already 

classified as disturbed based on the current disturbance limit; and 3) limiting coal removal to areas west 

of a line designated as the Coal Removal Limit as shown on Figure 1-2. Mining up to the Coal Removal 

Limit allows TMI to mine an additional approximately four million tons after July 1, 2015. The District 

Court-approved remedy does not affect TMI’s mining or reclamation activities on state, county, or private 

lands or minerals, or other federal coal leases. The Intervenors appealed the District Court Order is on 

appeal to the U.S. Court of Appeals for the 10th Circuit (Case Nos. 15-1186 and 1236). 

1.2.3 Statutory and Regulatory Background 

For new mining plans, OSMRE prepares a mining plan decision document (MPDD) in support of its 

recommendation to the ASLM (30 CFR Chapter VII, Subchapter D). For existing approved mining plans 

that are proposed to be modified, as is the case with this Project, OSMRE prepares a MPDD for a mining 

plan modification. The ASLM reviews the MPDD and decides whether or not to approve the mining plan 

modification, and, if approved, what, if any, conditions may be needed. Pursuant to 30 CFR 746.13, 

OSMRE’s recommendation to the ASLM is based, at a minimum, upon: 

•	 The PAP; 

•	 Information prepared in compliance with NEPA, including this EA; 

•	 Documentation illustrating compliance with the applicable requirements of federal laws,
	

regulations and Executive Orders (EOs) other than NEPA;
	

•	 Comments and recommendations or concurrence from other federal agencies and the public; 

•	 Findings and recommendations of the BLM with respect to the Resource Recovery and 

Protection Plan (R2P2), federal lease requirements, and the Mineral Leasing Act of 1920 (MLA); 

•	 Findings and recommendations of the CDRMS with respect to the mine permit application 

C-1981-010 and the Colorado State program; and 

•	 The findings and recommendations of the OSMRE with respect to the additional requirements of 

30 CFR Chapter VII, Subchapter D. 

In compliance with other federal laws, regulations and EOs, OSMRE also conducts consultation with 

other agencies before it makes its recommendation to the ASLM. This consultation includes the U.S. 

Fish and Wildlife Service (USFWS) Section 7 consultation for threatened and endangered species 

potentially affected by the proposed mining plan under the Endangered Species Act of 1973 (ESA), and 

the Colorado State Historic Preservation Office (SHPO) under the National Historic Preservation Act of 

1966 (NHPA) Section 106 consultation for the affected area. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

1-5 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 1.0 – Purpose and Need 

1.3 Purpose and Need 

1.3.1 Purpose 

The purpose of this EA is to re-evaluate the environmental effects of coal mining on the portions of 

Federal Coal Leases C-07519 and C-079641 that lie within the approved SMCRA permit boundary to 

assist OSMRE in developing a new recommendation for the ASLM to make a new decision on a mining 

plan modification for the Project. 

1.3.2 Need 

Coal mining operators must have a mining plan approved by the ASLM to mine federal coal (30 CFR 

746.11). Mining of the coal within the two federal coal lease areas is required under the terms and 

conditions of the Federal Coal Leases C-07519 and C-079641, and under the terms and conditions of 

the TMI Logical Mining Unit Application and R2P2. TMI has contractual obligations to deliver 

approximately 2.3 mtpy plus/minus 200,000 tons to the Craig Station through the year 2020. 

OSMRE is the agency responsible for making a recommendation to the ASLM regarding a decision on 

proposed mining plan modifications (30 CFR 746.13). TMI is presently operating under the 2009 

Approval that allows it to mine federal coal from Federal Coal Leases C-07519 and C-079641 in 

accordance with the SMCRA permit issued by CDRMS. 

As a result of the District Court’s decision in WildEarth Guardians v. U.S. Office of Surface Mining 

Reclamation and Enforcement et al. 104 F. Supp. 3d 1208, (D. Colo. 2015), which determined there 

were deficiencies in the EA underlying the 2009 Approval, and, pursuant to the District Court-approved 

remedy, OSMRE has agreed to re-evaluate the environmental impacts of current and future mining 

activities on these federal leases, beginning July 1, 2015, and continuing through the life of mine within 

the SMCRA permit boundary. 

1.4 Relationship to Statutes, Regulations, and Other Agency Plans 

1.4.1 Statutes and Regulations 

The following key laws, as amended, relate to the primary authorities, responsibilities, and requirements 

for developing federal coal resources: 

• MLA 

• NHPA 

• NEPA 

• Mining and Minerals Policy Act of 1970 (MMPA) 

• CAA 

• Clean Water Act of 1972 (CWA) 

• ESA 

• CSCMRA 

• Federal Land Policy and Management Act of 1976 (FLPMA) 

• Federal Coal Leasing Amendments Act of 1976 (FCLAA) 

• SMCRA 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

1-6 
Chapter 1.0 – Purpose and Need 

Figure 1-2 Mining Limits Under the Joint Proposed Remedy 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

1-7 
 

Chapter 1.0 – Purpose and Need 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

1-8 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 1.0 – Purpose and Need 

The MLA and FCLAA provide the legal foundation for the leasing and development of federal coal 

resources. BLM is the federal agency delegated the authority to offer federal coal resources for leasing 

and to issue leases. The MMPA declares that it is the continuing policy of the federal government to 

foster and encourage the orderly and economic development of domestic mineral resources. In that 

context, BLM complies with FLPMA to plan for multiple uses of public lands and determine those lands 

suitable and available for coal leasing and development. Through preparation of land use plans and/or in 

response to coal industry proposals to lease federal coal, BLM complies with NEPA to disclose to the 

public the potential impacts from coal leasing and development, and also complies with the NHPA, CAA, 

CWA, ESA, and other applicable environmental laws to ensure appropriate protection of other resources. 

BLM then makes the federal coal that is determined suitable for coal development available for leasing. 

BLM also is responsible for ensuring that the public receives fair market value for the leasing of federal 

coal. Once a lease is issued, BLM ensures that the maximum economic recovery of coal is achieved 

during the mining of those federal leases and ensures that waste of federal coal resources is minimized 

through review and approval of a mine’s R2P2 as required under the MLA. BLM implements its 

responsibilities for leasing and oversight of coal exploration and development under its regulations at 

Public Lands, Subtitle B, Chapter II, BLM, DOI, Subchapter C – Minerals Management (43 CFR 

Parts 3400-3480). 

SMCRA provides the legal framework for the federal government to regulate coal mining by balancing 

the need for continued domestic coal production with protection of the environment and ensuring the 

mined land is returned to beneficial use when mining is finished. OSMRE was created in 1977 under 

SMCRA to carry out and oversee those federal responsibilities. OSMRE implements its MLA and 

SMCRA responsibilities under regulations at Mineral Resources, Chapter VII – OSMRE, DOI (30 CFR 

Parts 700-End). 

As provided for under SMCRA, OSMRE works with coal producing states and tribes to develop their own 

regulatory programs to permit coal mining. Once a regulatory program is approved for a state or tribe, 

OSMRE steps into an oversight role. OSMRE approved the State of Colorado’s coal regulatory program 

on December 15, 1980 (30 CFR 906.10). As a result, CDRMS manages its own program under the 

CSCMRA (34 33-101 et seq. CRS 1973, as amended). CDRMS has the authority and responsibility to 

make decisions to approve surface coal mining permits and regulate coal mining in Colorado under 

Regulations of the Colorado Mined Land Reclamation Board for Coal Mining with oversight from 

OSMRE. The Cooperative Agreement between OSMRE and CDRMS allows the CDRMS to regulate 

surface coal mining on federal lands or leases while OSMRE continues to carry out its obligations under 

the MLA, NEPA and other public laws (30 CFR 906.30) which includes the recommendations related to 

mining plans and mining plan modifications. 

1.4.2 Other Agency Plans 

The BLM LSFO in Craig, Colorado, manages approximately 1.3 million surface acres and 1.1 million 

acres of mineral estate in northwest Colorado, including BLM-managed mineral estate in the Project 

Area. As required by FLPMA, BLM periodically prepares and revises land use plans to determine those 

uses that are suitable and compatible on specific portions of public lands, and under what conditions 

those uses would be authorized to mitigate potential impacts on other resource values and protect 

human health and safety. 

In the late 1950s and early 1960s, when the TMI leases were issued, there were no existing BLM 

management plans. In the late 1960s and early 1970s, the BLM prepared Management Framework 

Plans (MFPs) as its land use plans. In 1989 the BLM approved the 1989 Resource Management Plan 

(RMP) for public lands administered by the BLM LSFO and associated Record of Decision (ROD) (1989 

LSFO RMP-ROD) (BLM 1989). In 2011, BLM issued the Little Snake Record of Decision and Approved 

Resource Management Plan (2011 LSFO RMP-ROD) (BLM 2011), which replaced the 1989 LSFO 

RMP-ROD. In September 2015 the BLM issued the ROD and Northwest Colorado Approved Greater 

Sage-Grouse Amendment (BLM 2015). 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

1-9 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 1.0 – Purpose and Need 

TMI’s leases were issued by the BLM prior to the existence of a RMP or MFP and, therefore, were 

established as valid existing rights (VER) prior to approval of the RMPs/MFPs. As is recognized and 

stated in the 2011 LSFO RMP-ROD, a valid existing lease conveys certain rights of development to the 

leaseholder and a stipulation cannot be added after the lease is issued without the consent of both the 

lessee and lessor. Conditions of Approval and/or Best Management Practices (BMPs) required by the 

BLM in accordance with the newer RMPs would need to be consistent with the VER granted in existing 

leases. In this context, BLM made subsequent and periodic decisions regarding readjustment of the 

lease terms for each lease as required under the MLA and FCLAA. For each readjustment decision, 

BLM determined whether the lease terms were in conformance with the land use plan in effect at the 

time. In several cases the BLM, with the concurrence of TMI, added stipulations to the lease adjustments 

to align the leases with the RMP in place at the time. Further, OSMRE consulted with the BLM LSFO as 

part of the 2009 Approval process. At that time, in a letter dated July 8, 2009, the BLM LSFO determined 

and documented that the R2P2, which BLM approved, was in conformance with the MLA; the 

regulations at 43 CFR 3480; the lease terms and conditions; and maximum economic recovery. In the 

context of this EA, BLM has again reviewed the Project and determined that it conforms to the MLA, 

43 CFR 3480 lease terms and conditions, and, considering VER, conforms with the 2011 LSFO RMP 

and the 2015 amendments to the RMP. 

1.5 Authorizing Actions 

Two separate approvals are needed for a coal mine operator to conduct mining operations on lands 

containing leased federal coal: 1) a SMCRA permit approved by the regulatory authority, in this case, 

CDRMS; and 2) a mining plan or mining plan modification approved by the ASLM in accordance with the 

MLA. 

1.6 Outreach and Issues 

Public comments in advance of preparation of this EA were solicited through several methods. OSMRE 

published legal notices in the Craig Daily Press on October 14 and 21, 2015, and the Rio Blanco Herald 

Times on October 22, 2015 (Appendix A). The legal notice described the Project in summary form, 

informed the public that a public outreach meeting for the EA was scheduled for October 29, 2015, at the 

Moffat County Fairgrounds, Pavilion Building, 640 Victory Way, Craig, Colorado 81625, and informed the 

public that public comments would be accepted until November 12, 2015. The legal notice was posted at 

various public locations in Craig and Meeker, Colorado. An outreach letter describing the Project, 

announcing the public outreach meeting, and soliciting comments was mailed on October 16, 2015, to a 

total of 15 recipients, including city governments, adjacent landowners, and other interested parties. On 

October 27, 2015, a total of six letters were sent to American Indian tribes. 

OSMRE developed a Project website, which provided additional Project notice, Project information, and 

comment opportunities: http://www.wrcc.osmre.gov/initiatives/trappermine.shtm. The website was 

activated on October 16, 2015, and continues to be updated periodically as additional information on the 

Project becomes available. 

The public outreach meeting was held on October 29, 2015, from 4:00 PM until 8:00 PM. Five hundred 

one individuals signed in at the public meeting, and 195 comment forms were submitted during the 

meeting. A total of 4,578 individuals or organizations submitted comments by the end of the comment 

period. Ninety-two comments were received after the comment period closed on November 12, 2015. 

Comments received during and after the comment period were evaluated for relevance in preparing this 

EA. 

Table 1-1 summarizes the comment topics by resource category. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

1-10 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 1.0 – Purpose and Need 

Table 1-1 Public Outreach Comments Categorized by Key 

Resource Category 

Comment Category 

Number of 

Comments 

% of Total 

Comments 

Air Quality/Climate Change 4,263 91.3 

Community Works 74 1.6 

Environmental Stewardship 53 1.1 

General Support without specific topic 26 0.5 

Mineral Resources 22 0.5 

Socioeconomic 232 5.0 

Total 4,670 100 

The majority of the comments received during the public outreach period were provided as a combined 

form letter prepared by WildEarth Guardians regarding the Trapper Mine, Spring Creek Mine, and 

Skyline Mine from the Wild Earth Guardians website. The Spring Creek Mine is located in Montana and 

operated by Cloud Peak Energy, while the Skyline Mine is located in Utah and operated by Bowie 

Resource Partners, LLC. These mines have no affiliation with TMI or the Trapper Mine. The WildEarth 

Guardians form letter was signed by 4,167 individuals before the public comment period ended and 

another 91 individuals after the comment period ended, comprising approximately 91 percent of the total 

comments. The primary focus of the WildEarth Guardians form letter concerned air quality and climate 

change impacts associated with burning coal to create energy. The form letter also mentioned the 

potential for impacts to wildlife and water from mining activities but did not provide any details on these 

impacts. Of the remaining 412 comments, one of which was received after the public comment period 

ended, five expressed concern for air quality and climate. The environmental concerns related to air 

quality and climate discussed alternative, clean energy sources in place of coal combustion. In addition, 

it was asserted that the Craig Station can be supplied with coal by other mines in the area. Concern also 

was expressed for overseas exportation of coal. 

Four hundred and seven were individual comments made in support of Trapper Mine focusing mainly on 

the economic ramifications of discontinuing the mining operations within the Project Area but also 

discussing community works, environmental stewardship, and mineral resources. Job and tax revenue 

loss were the largest concerns. Most individual commenters praised TMI for its involvement in the local 

community and its exemplary reclamation efforts in most individual comments. Many commenters in 

support focused on the awards TMI has received including the Gold Level Good Neighbor award given in 

2004 and the Bronze Award in 2002 by OSMRE for having one of the top three mining reclamation 

practices. Socioeconomic impacts were discussed in nearly every comment of support for TMI. 

Individuals who work directly for TMI and businesses in the area that rely on mining to sustain their 

enterprises expressed concerns for their jobs and family welfare. Other socioeconomic comments 

outlined that TMI is a major contributor to Moffatt County tax revenue as the fourth largest tax payer. 

Many comments also incorporated the role TMI plays in community involvement. TMI employees donate 

time to charitable organizations. TMI donates time, equipment, and materials to provide Craig and the 

surrounding community with parks, golf courses, and fitness facilities. Mineral resource comments were 

the smallest group and addressed coal quality and proximity to the Craig Station. Mineral resource 

comments consisted of observations of the proximity of Trapper Mine to the Craig Station, the high 

quality of the coal mined at the Trapper Mine, and the high percent used directly at the Craig Station. 

Additional comments were submitted supporting TMI without specific focus on any one subject. 

One commenter provided a range of alternatives that they would like to see evaluated in the EA. 

All substantive comments received have been considered and included as appropriate in the preparation 

of this document. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

1-11 
 

Chapter 1.0 – Purpose and Need 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

1-12 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 2.0 – Proposed Action and Alternatives 

2.0 Proposed Action and Alternatives1 

This chapter provides background information on TMI’s existing operations at the Trapper Mine, and 

describes Alternative A - the Proposed Action Alternative, Alternative B - disapproval of continued mining 

within the Project Area, and Alternative C - the No Action Alternative. Alternatives that were considered, 

but eliminated from detailed analysis also are discussed. A more complete description of TMI’s existing 

mining and reclamation methods can be found in the PAP. The PAP, including Permit Renewal (RN) 06 

(RN06) which was submitted by TMI to the CDRMS on June 20, 2012, and approved by the CDRMS on 

August 28, 2013, and Permit Revision (PR) 07 (PR07), which was submitted to the CDRMS May 21, 

2013, and approved by CDRMS on October 6, 2015, provides detailed information on the current 

five-year mining term from 2013 through 2017 (TMI 1981 et seq.). Readers desiring greater detail can 

review the additional descriptions, maps, and drawings contained in the PAP. The PAP is available at 

the Trapper Mine Administration Office at 25910 State Highway 13, Craig, Colorado, 81625; the CDRMS 

at 1313 Sherman Street, Room 215, Denver, Colorado, 80203; and the OSMRE Western Region Office 

located at 1999 Broadway, Suite 3320, Denver, Colorado, 80202. The PAP also is available online on 

the CDRMS website at http://mining.state.co.us. 

2.1 Trapper Mine SMCRA Permit 

TMI operates the Trapper Mine within the SMCRA permit boundary of CDRMS-issued Permit C-1981-

010. The SMCRA permit area includes a total of approximately 11,157 acres as shown in Figure 2-1. 

TMI owns or controls the surface and coal resources within the SMCRA permit boundary. The surface 

ownership includes private entities and the State of Colorado. Coal resources within the SMCRA permit 

boundary are owned by private entities, the State of Colorado, and the federal government. 

Environmental studies for the Trapper Mine began in 1972, with the construction of facilities commencing 

in 1975. The Colorado Mined Land Reclamation Board approved Permit No. 76-11 for the Trapper Mine 

on May 28, 1976, and mining operations began in 1977. On February 2, 1981, Utah International, Inc. 

submitted an application for a new permit under SMCRA. CDRMS issued the Trapper Mine SMCRA 

permit on December 31, 1982. Permit applications approved under the CDRMS regulations are for a 

five-year permit term and the permit must be renewed every five years, updating the application with new 

information and planned changes in the mining or reclamation activities. The Trapper Mine SMCRA 

permit has been approved for renewal six times since 1982. The current approved permit term for 

operations at the Trapper Mine, RN06, is from December 31, 2012, to December 31, 2017. 

If the mining plan changes during the five-year SMCRA permit term, the changes must be approved by 

CDRMS through a PR, technical revision, or minor revision. Each time a permit is revised or a RN is 

approved by the CDRMS, the appropriate changes are made to the PAP so that the PAP remains 

current with the mining and reclamation plans. 

2.2 Project Area 

The Project Area for this EA is limited by the Joint Proposed Remedy to lands within Federal Coal 

Leases C-07519 and C-079641 that lie within the SMCRA permit boundary as shown in Figure 2-1. The 

Project Area is approximately 2,423 acres. 

The EA addresses OSMRE’s review of a life-of-mine plan for mining in the Project Area from July 1, 

2015, through approximately 2025, or beyond depending upon the coal delivery schedule. Because the 

1 Italicized text denotes language inserted either in response to comments received on the EA (see Appendix E) or to clarify or 

update a topic based on new or additional information received. Each place where italicized text appears is denoted by a bar in 

the left hand margin. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-1 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 2.0 – Proposed Action and Alternatives 

CDRMS approval is only for the current five-year permit term, the current CDRMS mine plan approval 

does not extend for the life of mining nor does the current CDRMS approval include the full extent of 

disturbance contemplated in the life-of-mine plan presented in this EA. TMI would be required to obtain 

RN approval from CDRMS for the periods of December 31, 2017, through December 31, 2022, and 

December 31, 2022, through December 31, 2027, and obtain CDRMS approval for the mining 

operations as presented in this EA before fully implementing the life-of-mine plan for the Project Area. 

The surface and coal rights in the Project Area are owned or controlled by TMI. The surface is owned by 

TMI while the coal is owned by the federal government and leased to TMI. Coal rights are controlled by 

TMI through obtaining coal leases. As described in Chapter 1.0, Purpose and Need, the BLM is the 

agency with authority to lease federal coal and was the issuing agency for Federal Coal Leases C-07519 

and C-079641, the two leases covering the Project Area. The legal description for the two lease areas, 

which lie within the SMCRA permit boundary, is as follows: 

C-07519 

Township 5 North (T5N), Range 90 West (R90W), 6th Prime Meridian (P.M.)
	

Section 6, Lots 8 through 19 inclusive
	

T6N, R90W, 6th P.M.
	

Section 31, Lots 5 through 20 inclusive
	

A total of 1,194.2 acres in lease C-07519 lie within the SMCRA permit boundary. 

C-079641 

T5N, R90W, 6th P.M.
	

Section 5, Lots 5 through 20 inclusive
	

T6N, R90W, 6th P.M.
	

Section 32, Lots 4 through 16 inclusive
	

A total of 1,228.6 acres in lease C-079641 lie within the SMCRA permit boundary. 

The Trapper Mine is an open-pit sub-bituminous coal mine located approximately six miles (9.7 km) 

south of the City of Craig in Moffat County, Colorado. The mine is accessed via Colorado SH 13. 

Development of the Trapper Mine began in 1954 with exploration drilling and continued with acquisition 

of state and federal coal leases, water rights, and permits to operate. Construction of mine facilities 

began in 1975 and mining operations began in 1977. The first coal was delivered to the Craig Station in 

1978. The Craig Station is located adjacent to the SMCRA permit boundary to the northwest of the 

Project Area. Mining since 1977 generally has progressed from west to east within the SMCRA permit 

boundary. The Project Area is located on the eastern portion of the SMCRA permit area as shown in 

Figure 2-1. 

Coal mined at the Trapper Mine is delivered by truck to the Craig Station at an average rate of 

approximately 2.3 mtpy (with a maximum rate of 2.6 mtpy). The coal is mined from seven coal seams of 

the Upper Williams Fork Formation: the “H,” “I,” “K,” “L,” “M,” “Q,” and “R” seams. Within the Project 

Area, the “R” seam is too deep for surface mining. Draglines were the primary earthmoving equipment 

used until October 8, 2006, when a 250-acre landslide occurred within the Project Area. This event 

required a modification of the SMCRA mining plan and mining method which was approved on July 7, 

2008, by CDRMS under Technical Revision 103. Following the landslide, mining has been 

accomplished by a combination of dragline, dozer, and truck and loader operations, depending on the 

depth and material being mined. The mining process is described in Section 2.3 below. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-2 
Chapter 2.0 – Proposed Action and Alternatives 

Figure 2-1 Project Area – Previous and Proposed Disturbance 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-3 
 

Chapter 2.0 – Proposed Action and Alternatives 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-4 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2.3 

Chapter 2.0 – Proposed Action and Alternatives 

Some limited highwall mining has occurred and may occur in the future within the Project Area. 

Highwall mining consists of excavating horizontally along an exposed coal seam, such as in a highwall 

area, to recover the coal. 

The Horse Gulch Fill, shown in Figure 2-1, was created following the 2006 landslide to allow permanent 

placement of overburden materials removed during initial truck and loader mining operations because an 

adjacent open pit was not available for material placement due to the landslide event. Approximately 

24.6 million bank cubic yards of overburden material has been permanently placed in the Horse Gulch 

Fill. Subsequent to construction of the Horse Gulch Fill, TMI conducted additional evaluations and 

modified the SMCRA permit plan to allow for additional dragline mining and placement of overburden 

directly back in the mined pit as backfill. No additional fill placement is planned in Horse Gulch as part 

of the Project and the Horse Gulch Fill is currently undergoing reclamation. 

There are two dual powerlines and one single powerline that cross the Project Area (Figure 2-2). The 

largest dual powerline is a 345-kilovolt (kV) line owned by Tri-State Generation and Transmission 

Association, Inc., which links the Craig Station with the Hayden Generating Station (Hayden Station), 

located approximately 21 miles (33.8 km) to the east of the Craig Station. The second dual powerline is a 

230-kV line owned by Western Area Power Administration, which distributes power from the Craig 

Station. The single powerline is a 138-kV line owned by Tri-State Generation and Transmission 

Association Inc., which distributes power from the Hayden Station west toward the White River Electric 

Association. The two larger dual powerlines would not be affected by the planned mining operations 

within the Project Area. The smaller single powerline runs north to south through the proposed L Pit 

disturbance within the Project Area and would be moved to allow mining. That powerline is privately 

owned and located on private land and would be moved to private land adjacent to the planned mining 

areas. The current location and the realignment are shown in Figure 2-2. 

Description of Existing Mining and Reclamation Operations 

Operations at the Trapper Mine are conducted in accordance with applicable laws and regulations 

including SMCRA; the CSCMRA, most recently revised August 7, 2006; regulations of the Colorado 

Mined Land Reclamation Board, last revised September 14, 2005; and the CDRMS-approved PAP. The 

PAP, including the approved revisions provides the most complete descriptions of mining, environmental 

protection measures and reclamation activities within the Project Area for the current five-year permit 

term (2012 through 2017) and, as such, is used and referenced for the purpose of this EA. The general 

sequence of operations is described below. 

In new mine areas, the first action is to create drainage and sediment control for the area to be disturbed. 

Once drainage and sediment controls are in place, vegetation is cleared and topsoil is removed. 

Vegetation is removed using dozers. Vegetation is typically pushed into nearby disturbed areas for 

burial, but also can be used for erosion and sediment control purposes. Topsoil is removed using 

scrapers or other earthmoving equipment. 

Topsoil is hauled directly for placement on graded areas undergoing reclamation or placed in temporary 

stockpiles. Temporary topsoil stockpiles are graded so the out-slopes are 3 horizontal to 1 vertical 

(3H:1V) or less and stabilized through revegetation. Topsoil salvage depths and volumes are monitored 

and recorded for use in material balancing during reclamation. Topsoil removal typically occurs in May 

through October. As a result, topsoil salvage is typically one to five pit widths in advance of mining 

operations to allow mining to continue to advance through the winter months. 

After the topsoil has been salvaged, mining operations begin to recover the coal. Trapper Mine pits are 

mined using both a dip-line mining method and a strike-line mining method. Mining is completed in 

parallel strips. Each pit is adjacent and parallel to the previous pit. Cuts are initiated near the outcrop of 

the coal seam higher on the hillside and worked down the hill until the coal becomes too deep to recover, 

or initiated near the economic strip limit and worked up the hill until the coal outcrops. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-5 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 2.0 – Proposed Action and Alternatives 

The overburden, or rock that lies above the coal seams to be mined, is drilled and blasted to break up 

the rock to allow it to be moved using the mining equipment. Blasting is performed using an ammonium 

nitrate and fuel oil (ANFO) mixture. After overburden blasting is completed, the overburden removal 

begins. For the Project Area, overburden removal would occur primarily using trucks and loaders. The 

maximum coal depth for the Project Area would involve the initial use of trucks and loaders because the 

draglines cannot economically remove materials deeper than 200 feet. The overburden ranges in depth 

from 100 to 150 feet. 

Following removal of overburden by the trucks and loaders, dozers scrape the remaining thin layer of 

overburden material to expose the uppermost coal seam. Coal is either ripped with a dozer or drilled and 

blasted for removal using similar blasting material (ANFO) as is used for overburden. Depending on the 

depth of the uppermost coal seam within the pit, the uppermost coal seam is mined using draglines or 

front-end loaders. The coal is loaded into haul trucks for transfer to the Craig Station. 

After the uppermost coal seam is removed, interburden, or the non-coal rock material located between 

multiple coal seams to be mined, is removed using trucks, loaders and dozers, or using draglines and 

dozers, depending on the depth. Dozers prepare the lower coal seams for mining by clearing the thin 

layer of interburden above the lower coal seams. The coal is then loaded into haul trucks by loaders and 

dozers or the draglines and dozers. The draglines typically work one pass down and one pass up each 

cut removing the deeper interburden and coal. At the Craig Station, coal is end dumped into the primary 

crushing system or is stockpiled in the immediate vicinity of the crusher. Coal that is stockpiled is placed 

in the crusher at a later date using front end loaders operated by TMI employees. Once the coal is 

dumped into the crushing system, it transfers ownership to the Craig Station. Coal Combustion 

Residuals (CCRs) are utility wastes generated during the burning of coal and include fly ash, bottom ash, 

and scrubber sludge. CCRs not recycled for use in cement products, wallboard, and road base are 

hauled back to the Trapper Mine for placement as pit backfill in permitted areas. Approximately 

55 percent of the total CCRs produced at Craig Station, an estimated 501,000 tons annually, are placed 

at the Trapper Mine. CCRs are placed in areas located within the SMCRA permit boundary but outside 

of the Project Area. 

Overburden and interburden, collectively known as spoil, removed to access the coal seams in an active 

mine pit are used as backfill in the adjacent mine pit to begin the reclamation process. The dragline casts 

the spoil into the adjacent cut to backfill the pit. Dozers also are used to backfill spoil into the adjacent 

cut, while loaders and haul trucks are used to move material into backfill areas farther behind the active 

mining operation. 

Backfilling is completed contemporaneously at the Trapper Mine with backfilling beginning in the pit as 

soon as safely possible after the mining equipment has completed coal removal and moved to an 

adjacent pit. After the pit has been backfilled and mining has progressed away from the mined-out pit, 

the backfill material is rough graded, using dozers, graders, or draglines, in preparation for reclamation. 

In most cases rough grading of the backfill begins within 30 days of placement, with a maximum of one 

pile of overburden and interburden material (referred to as a spoil pile) behind the active working area of 

the pit. The power to the dragline is typically supplied to the machine from the spoil pile side of the pit 

with power cables positioned on the ground behind the draglines. The rough grading of the piles is 

completed quickly to allow for ease of movement of the power cables supplying the dragline. Rough 

grading also reduces the potential for ponding of surface water on the steeply dipping slopes and 

promotes runoff to avoid the potential for water to promote landslides or inhibit operations. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-6 
Chapter 2.0 – Proposed Action and Alternatives 

Figure 2-2 Proposed Mine Operation Components 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-7 
 

Chapter 2.0 – Proposed Action and Alternatives 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-8 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 2.0 – Proposed Action and Alternatives 

After rough grading, final grading is conducted to blend the backfilled areas with the surrounding 

topography, create a reclaimed area in accordance with the CDRMS approved post-mining topography, 

and construct drainage patterns. The area is then prepared for topsoil placement and seeding. 

The Trapper Mine’s overall reclamation objectives are to restore the disturbed areas to the pre-mining 

uses of cropland or rangeland and wildlife habitat. To date, mining at the Trapper Mine has disturbed 

approximately 593 acres of cropland, and all of these areas have been reclaimed as cropland. No 

additional cropland disturbance or reclamation is planned within the SMCRA permit boundary. 

Approximately 3,925 acres of rangeland and wildlife habitat have been reclaimed since the start of 

mining. Reclamation of the remaining disturbed areas would be conducted to achieve the post-mining 

land uses of rangeland and wildlife habitat. For rangeland and wildlife habitat reclamation, the topsoil is 

placed on the graded overburden/interburden to a depth of 12 inches. Topsoil placement occurs in the 

summer and fall. Fertilizer is not used for rangeland/wildlife habitat reclamation as past experience has 

shown that the use of fertilizers promotes growth of more aggressive grasses and forbs while decreasing 

the overall plant community diversity. The prepared areas are then seeded with one of three rangeland 

seed mixes as approved by CDRMS (TMI 1981 et seq.). Mature shrub transplanting also can occur 

within the reclamation areas. Mature shrubs are transplanted using a front end loader or similar 

equipment. Revegetation is monitored until the vegetation establishment meets the approved standards 

in the PAP. 

TMI is required to post a bond covering land within the SMCRA permit area where mining and 

reclamation operations occur. The bond is made payable to the State of Colorado and OSMRE and 

covers performance of all requirements contained in regulations, the PAP, and the reclamation plan. A 

bond must remain in place until reclamation is completed in accordance with the regulatory requirements 

and permit documents, and to the satisfaction of the regulatory authorities. The bond is based on the 

cost of having a third-party contractor complete the required reclamation work if for some reason TMI is 

unable to do so. Reclamation liabilities at the Trapper Mine, as calculated by CDRMS as part of the 

PR07 approval, are $23,016,528.92. CDRMS holds a corporate surety bond in the amount of 

$23,400,000.00 to cover all reclamation liabilities at the Trapper Mine. 

There are three phases of bond release based on completion of certain portions of the reclamation plan. 

TMI can apply for Phase I bond release after completion of backfilling, regrading, and drainage 

establishment. Phase I bond release allows for release of approximately 60 percent of the reclamation 

bond for the area. TMI can apply for Phase II bond release once topsoil has been placed and vegetative 

cover has been established in accordance with the reclamation plan and associated regulatory 

standards. Phase II bond release also evaluates control of sediment in runoff outside of the reclaimed 

area to ensure compliance with the requirements. Phase II bond release allows for the release of up to 

an additional 25 percent of the reclamation bond, and in combination with the Phase I bond release 

allows for 85 percent of the bond to be released for that area. Phase III bond release occurs once all 

surface coal mining and reclamation activities have been completed in accordance with the requirements 

of the SMCRA, the Colorado regulations, and the PAP, and no fewer than 10 years have passed since 

the need for irrigation, fertilization, or significant revegetation. Revegetation success is determined by 

evaluating plant cover, plant production, woody plant density, and plant species diversity. After Phase III 

bond release, the area is 100 percent released from any bond liability. TMI has received approval for 

Phase I, Phase II, and Phase III bond releases for areas within the SMCRA permit boundary and the 

Project Area. Figure 2-3 shows the areas of bond release within the Project Area and Table 2-1 

provides acreages for each phase of bond release within the Project Area. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-9 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 2.0 – Proposed Action and Alternatives 

Table 2-1 Summary of Phased Bond Release Acreages in the 

Project Area 

Land Status 

Approximate 

Acreage 

Total Areas Reclaimed Within the Project Area 494 

Areas Which Have Achieved Phase I Bond Release 494 

Areas Which Have Achieved Phase II Bond Release 267 

Areas Which Have Achieved Phase III Bond Release 178 

Note that bond release is successive. Reclaimed land must achieve Phase I bond release 

before being eligible for Phase II and must achieve Phase II bond release before being 

eligible for Phase III. Each successive phase of bond release is a subset of the previous 

phase. 

Equipment used at the Trapper Mine for mining, reclamation, and support of these activities includes the 

following: 

Draglines Water Trucks 

Overburden/Parting Drills Fuel and Lube Trucks 

Track Dozers 35-ton Crane 

Rubber-tired Dozers Backhoes 

Motor Graders Cable Reel 

Scrapers Service Trucks 

Hydraulic Excavators Pickups/Sport Utility Vehicles 

Front-end Loaders Farm Tractors 

Coal Drills Tractor and 200-ton Lowboy Trailer 

Haul Trucks (240-ton, 95-ton, 55-ton) Compactor 

The Trapper Mine operates 24 hours a day, seven days per week. The mine employs approximately 

191 individuals (based on 2015 employee count) and operates on various schedules of 8-, 10-, or 

12-hour shifts per day (TMI 2016). 

2.3.1 Trapper Mine Support Facilities 

Mining activities are supported by existing, permitted facilities located within the SMCRA permit 

boundary but outside the Project Area. The mine office, shop, and warehouse complex is located 

adjacent to the mine entrance approximately 2.5 miles from the Project Area. The mine office, shop, and 

warehouse complex includes most of the buildings and facilities needed to operate the mine, including 

the mine offices, truck shop, warehouse, storage yards, storage buildings, truck wash, electric shop, 

dragline repair shop, and fuel storage and refueling area for diesel and gasoline vehicles and other 

equipment. Other facilities outside of the Project Area and not located within the mine office, shop, and 

warehouse complex include the water pump house and water storage tanks. All of these facilities would 

be used to support the Proposed Action. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-10 
Chapter 2.0 – Proposed Action and Alternatives 

Figure 2-3 CDRMS Bond Release Areas 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-11 
 

Chapter 2.0 – Proposed Action and Alternatives 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-12 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 2.0 – Proposed Action and Alternatives 

2.4 Alternative A - Proposed Action 

Under Alternative A, the Proposed Action, OSMRE would recommend and the ASLM would sign a new 

MPDD for coal mining and reclamation operations at the Trapper Mine within the Project Area through 

the life-of-mine, estimated to be approximately 2025 or later depending on coal delivery requirements. 

TMI would mine the coal at the current mining rates, which average approximately 2.3 mtpy with a 

maximum production rate of 2.6 mtpy and would use similar mining and reclamation methods as 

described in Section 2.3. The operations within the Project Area would disturb an additional 257 acres of 

undisturbed land and re-disturb approximately 11 acres of reclaimed land. 

2.4.1 Proposed Mine Operation Components within the Project Area 

The Proposed Action would consist of the following mine components and facilities located within the 

Project Area. Major facilities are shown on Figure 2-2: 

•	 L Pit – Currently active open pit on Lease No. C-079641, projected to be mined 2015 through 

2025. 

•	 N Pit – Open pit partially located on Lease No. C-07519, projected to be mined near the end of 

the life-of-mine for the Project (currently estimated at 2023). This pit has not been approved by 

CDRMS at this time. 

•	 TMI powerlines would provide power to facilities within the Project Area and to the draglines. 

•	 East Panel Readyline and Fuel Storage Tanks area would provide plug-ins to warm dieselpowered equipment engines and fuel for the refueling of equipment. 

•	 Support facilities necessary to conduct mining operations within the Project Area would include: 

− Haul roads used by haul trucks to transport coal to the Craig Station or move overburden 

and connect with in-pit roads and ramps; 

− Temporary light use ancillary roads; 

− Temporary in-pit ramps and roads; 

− Powder magazine used to store high explosives; 

− Emulsion and ammonium nitrate storage tanks for materials used in blasting; 

− Blasting equipment storage for keeping blasting equipment from freezing; 

− Temporary stockpile areas to store topsoil removed from disturbed areas for use in 

reclamation;
	

− Temporary berms for control of water, material placement, or traffic;
	

− Dewatering wells and associated waterlines;
	

− Temporary construction staging areas;
	

− Environmental monitoring stations for air and water monitoring; and 

− Sediment ponds and diversion ditches.
	

2.4.2 Existing and Proposed Disturbance 

The Proposed Action would include mining from July 1, 2015, through the estimated life-of-mine for the 

Project Area (2025). Although mining operations are ongoing within the Project Area, all acreages for 

disturbance and reclamation used in this EA are based on the disturbance and reclamation status as of 

July 1, 2015. Table 2-2 summarizes the total Project Area, approximate acres of previously disturbed 

area, approximate acreage of previously reclaimed areas, approximate acreage of new disturbance, and 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-13 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 2.0 – Proposed Action and Alternatives 

approximate acreage of areas currently reclaimed but planned for re-disturbance. The overall disturbed 

areas for the Proposed Action are shown in Figure 2-1. 

Table 2-2 Summary of Disturbance in Project Area for Alternative A – Proposed Action 

Land Status Approximate Acreage 

Current Disturbed Area as of July 1, 2015 1,053 

Previously Disturbed and Reclaimed Area as of July 1, 2015 494 

Proposed New Disturbance After July 1, 2015 257 1 

Not Proposed for Disturbance 619 

Total Project Area 2,423 

1 In addition, 11 acres of reclaimed area is planned for re-disturbance as part of the Project. 

2.4.3 Mining Operations 

Mining operations associated with the Proposed Action would continue to be conducted in a similar 

manner as described for existing operations in Section 2.3. Vegetation would be removed in new 

disturbance areas followed by topsoil removal, blasting of the overburden, overburden/interburden and 

coal removal, pit backfilling, and reclamation. 

As part of the Proposed Action, coal would continue to be mined in the L Pit within the Project Area from 

July 1, 2015, to approximately the year 2025 and in the portion of the N Pit located partially within the 

Project Area beginning in approximately the year 2023 (Figure 2-2). TMI proposes to continue mining in 

the Project Area using a combination of dragline, dozer, and truck and loader operations to remove 

overburden and recover coal. Some limited highwall mining also could occur. 

The L Pit is where current mining operations are occurring. Ongoing mining in the L Pit, through 

completion of the EA, is being conducted in accordance with the Joint Proposed Remedy, which is 

described in Section 1.2.2. 

The L Pit is designed and operated as both a strike-line truck and loader pit and a dip-line dragline pit, 

depending on field conditions. The L Pit currently is and would be mined using a combination of truck 

and loader, dozer, and dragline stripping as described in Section 2.3. Coal is currently and would 

continue to be removed using a combination of loaders and trucks. Highwall mining also could be used 

in the endwalls or highwalls of the L Pit if further geologic and geotechnical studies demonstrate 

feasibility, and the timing of the stripping operations allows access (TMI 1981 et seq.). 

TMI also proposes to mine the N Pit located partially within the Project Area over the life of the mine. 

Mining in the N Pit within the Project Area would not begin until near the end of the life-of-mine plan 

estimated to be in 2023, although mining of private coal within the N Pit outside of the Project Area could 

begin earlier. Mining previously has occurred in the N Pit area and some of that previous disturbance 

has been reclaimed. However, mining only recovered the coal seams closer to the surface; the “H” and 

“I” seams. The Proposed Action would initiate re-mining in this area to recover the coal from the deeper 

coal seams in the N Pit, specifically the “L,” “M,” and “Q” seams. Mining of these coal seams is not 

currently approved by CDRMS. Approval would be required by CDRMS prior to initiating any disturbance 

in the N Pit area. 

The N Pit area has steep grades, weak formations, wet ground, historical spoils, and a high stripping 

ratio. Due to these conditions it is possible that highwall mining could be the preferred mining method in 

some areas. However, all or portions of the N Pit also would be mined using the standard combination of 

dragline, dozer, and truck and loader equipment as described for the L Pit in Section 2.3. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-14 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 2.0 – Proposed Action and Alternatives 

Table 2-3 provides additional information on the L and N Pit mine pit areas and total tonnage. 

Table 2-3 Proposed Project Area Mine Plan 

Mine Pit 

Total Pit Area* 

in Acres 

Estimated Federal 

Coal Tons** 

Estimated Mining 

Years 

L Pit 517 19,003,900 2015-2025 

N Pit 17 130,800 2023 

Total 534 19,134,700 2015-2025 

* From July 1, 2015, through life-of-mine (estimated 2025).
	

** TMI 2015.
	

2.4.4 Project Environmental Protection and Mitigation Features 

The surface mining permitting process under the CDRMS coal regulatory program requires applicants to 

incorporate design features into their mining proposals to protect or minimize impacts to environmental 

resources (CDRMS 1980). Each PAP submitted to CDRMS for a new or revised mining permit is 

required to contain resource-specific protection and mitigation plans. The resource-specific plans 

describe the design features for reducing or eliminating the potential impacts to various resources or how 

those resources would be restored to approved post-mining conditions after mining is complete. CDRMS 

reviews the PAP, which includes the required resource-specific plans, design features, and associated 

performance standards. CDRMS approval commits the applicant to implementing the design features 

contained in the PAP. It is important to note that the design features of the original permit also apply to 

the newly revised permit, unless CDRMS approves any changes to the revised permit that would replace 

older design features. 

Section 4 of the PAP describes the design, operation, and reclamation features to reduce or eliminate 

potential impacts to environmental resources. Table 2-4 contains a summary of those features with a 

more detailed description included in the PAP (TMI 1981 et seq.). 

Table 2-4 Summary of Environmental Commitments from Trapper Mining Inc. PAP 

Resource Area Measure 

Topography Restore the area to approved post-mining topography. 

Grade backfilled mining areas to establish a stable post-mine topography that blends 

into the undisturbed areas outside the mining limits. 

Air Quality Water roads and apply chemical dust suppressants as necessary to control fugitive 

dust emissions. 

Operate in compliance with the CDPHE APCD Construction Permit (11MF253-1). 

Seed long-term topsoil stockpiles. 

Water Resources Route all runoff from disturbed areas through one or more sediment ponds. 

Construct new sedimentation structures and diversion ditches prior to topsoil removal 

to control runoff, avoid erosion and an increased contribution of sediment load to 

runoff, and protect surface water and groundwater quality. 

Maintain temporary sediment ponds until vegetative establishment is complete and 

acceptable runoff water quality is achieved. 

Monitor performance of diversion ditches and sediment control structures and 

maintain or upgrade as needed. 

Control and monitor the quantity and quality of any discharges from the permit area 

in compliance with the Colorado Discharge Permit System (CDPS) Permit Number 

CO-0032115 issued by the CDPHE under the National Pollutant Discharge 

Elimination System Program. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-15 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 2.0 – Proposed Action and Alternatives 

Table 2-4 Summary of Environmental Commitments from Trapper Mining Inc. PAP 

Resource Area Measure 

Revegetate permanent drainage ditches unless CDRMS approves rip rap as a 

channel lining. 

Seed disturbance related to sediment pond construction, including embankments 

and surrounding areas, after the pond construction is completed. 

Design sediment ponds to contain the water and settleable sediment load from a 

10-year, 24-hour storm event. 

Construct secondary sediment controls in the form of dozer basins to provide 

secondary sediment controls for precipitation and snowmelt events in disturbed 

areas of the mine site. 

Size haul road culverts to maintain proper drainage during high snowmelt or other 

exceptional runoff events. 

Vegetation Live transplant shrubs in accordance with approved permit commitments. 

Revegetate to achieve the approved post-mining land uses. 

Eliminate livestock grazing during vegetation establishment. 

Once vegetation is established, manage livestock usage to protect the established 

vegetative cover. 

Evaluate revegetation success in accordance with the standards approved by the 

CDRMS. 

Fish and Wildlife Re-establish appropriate and suitable forage and cover on reclaimed areas. 

Construct permanent stock and wildlife watering ponds. 

Keep soil disturbance to a minimum to reduce destruction of vegetation and food 

species used by wildlife. 

Take administrative actions for any employee found harassing wildlife. 

Manage livestock grazing to ensure that adequate forage is left for wildlife use and 

that the range is not over used. 

Control pesticide and herbicide use to protect livestock and wildlife. 

Construct powerlines to Rural Electric Association Bulletin 6140, Powerline Contacts 

by Eagles and Other Large Birds, standards. 

Limit vehicle speeds in the mine area to reduce the likelihood of collisions with 

wildlife. 

Provide topographic relief for wildlife habitat. 

Threatened and 

Endangered Species 

Continue to implement measures required as part of the Endangered Fish Recovery 

Agreement with USFWS. 

Cultural Resources Perform pre-disturbance field surveys. 

If an unidentified cultural or historical resource is discovered within or adjacent to the 

Project Area, halt activities that may damage the resource and report the findings to 

the responsible regulatory agency. 

Complete required mitigation for cultural and historic resources. 

Visual Resources Restore disturbed areas to the approved post-mining topography. 

Soils Manage topsoil resources to minimize the negative effects of salvaging, stockpiling, 

and replacing soils to the extent practicable. 

Live-handle topsoil where possible. 

Salvage the A and upper B horizon soils, where practical, for use in reclamation. 

Restrict topsoil salvage to dry conditions where possible. 

Restrict topsoil salvage to the months of May through October. 

Locate topsoil stockpiles to avoid erosion from wind and water and additional 

compaction or contamination. 

Regrade topsoil stockpiles with outside slopes no steeper than 3H:1V and protect 

topsoil stockpiles by revegetating as soon as conditions allow. 

Clearly label topsoil stockpiles. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-16 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2.5 

Chapter 2.0 – Proposed Action and Alternatives 

Table 2-4 Summary of Environmental Commitments from Trapper Mining Inc. PAP 

Resource Area Measure 

Control weeds on topsoil stockpiles by monitoring and treating with an herbicide as 

needed. 

If soil compaction occurs after topsoil replacement, rip the soil with a dozer to 

minimize compaction, promote stability and assist in revegetation. 

Leave reapplied topsoil in a rough condition to help control wind and water erosion 

prior to seeding. 

Monitor topsoil removal and maintain replacement balances to ensure adequate 

topsoil is available for reclamation. 

Post-mining Land Use Reclaim affected areas to land uses as high as or higher than those in effect prior to 

mining. 

Establish vegetation to support livestock grazing. 

Establish adequate forage and cover to support year-round wildlife usage. 

Establish permanent stock and wildlife watering ponds. 

Establish the post-mining hydrologic conditions in accordance with the approved 

hydrologic reclamation plan. 

Alternative B – Disapproval of Mining Plan by ASLM 

Under this alternative, OSMRE would recommend, and the ASLM would sign a MPDD that disapproves 

of continued mining operations at the Trapper Mine. Once the ASLM decision is issued, TMI would 

immediately terminate the current mining operations in the Project Area and begin final reclamation. 

Under this alternative, OSMRE has assumed that mining operations at the Trapper Mine would cease by 

April 30, 2016. As of that date, an additional 1.75 million tons of coal would be mined within the Project 

Area but 17.35 million tons would not be mined. Mining could occur in other areas within the SMCRA 

permit boundary, but subject to judicial review of the ASLM’s decision, no further mining would occur in 

the areas covered by the Project Area, and no additional coal removal would occur from Federal Coal 

Leases C-07519 and 

C-079641. 

Once operations have ceased, TMI would start reclamation of the existing disturbed areas within the 

Project Area. Reclamation would proceed in accordance with the approved reclamation plan contained 

within the SMCRA Permit as generally described in Section 2.3. Reclamation would be expected to take 

approximately three to five years to complete backfilling, grading, and drainage reestablishment; topsoil 

replacement; and seeding. Vegetation establishment and Phase III bond release for the Project Area 

could take an additional 10 to 15 years. 

Coal reserves identified in areas outside the Project Area in the N Pit and I Pit are shown on Figure 2-4. 

The N Pit has been previously mined for recovery of the “H” and “I” coal seams, and future mining would 

recover the deeper coal seams (the “L,” “M,” and “Q” seams). The 11-acre portion of the N Pit within 

Federal Coal Lease C-07519 would not be mined, but the area of the N Pit outside of the lease would be 

mined. The I Pit has not been previously disturbed. The N Pit west of Federal Coal Lease C-07519 and 

the I Pit are located on private and state lands with state coal. The coal expected to be mined from these 

pits would be approximately 4.5 million tons. The mining rate for these pits would potentially be reduced 

from the current average mining rate of 2.3 mtpy, due to equipment congestion in these smaller mine 

areas. Although detailed plans have not been developed for mining these areas, for the purposes of this 

analysis a mining rate of approximately 1.5 mtpy is used. The current identified reserves would be mined 

within three to four years of the decision by the ASLM to not recommend approval of the mining within 

Federal Coal Leases C-07519 and C-079641. This would not preclude the possibility that additional coal 

reserves could be identified within the SMCRA permit boundary. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-17 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 2.0 – Proposed Action and Alternatives 

2.6 Alternative C – No Action Alternative 

Under this alternative, OSMRE would not develop a MPDD and the ASLM would not issue a decision 

based on the revised EA document. TMI would continue to operate under the 2009 Approval signed 

November 27, 2009, by the ASLM. Because of the deficiencies raised in the prior NEPA process by the 

District Court in WildEarth Guardians v. U.S. Office of Surface Mining Reclamation and Enforcement et al. 

104 F. Supp. 3d 1208, (D. Colo. 2015), it is reasonably possible that, under this alternative, the existing 

MPDD would be vacated based upon a future court order. The District Court’s decision is the subject of 

an appeal by the Intervenors to the U.S. Court of Appeals for the 10th Circuit (Case Nos. 15-1186 and 

1136) and may be reversed. If the prior EA analysis and the existing MPDD are vacated, operations at 

Trapper Mine would cease immediately and the effects would be equivalent to Alternative B outlined 

above, although TMI could continue to mine until the 2009 Approval is vacated by a court. The coal 

tonnage removed and the timing for the cessation of mining could vary from that outlined for 

Alternative B. 

If the 2009 EA and the associated 2009 Approval are not vacated by a court, TMI would continue to mine 

as outlined in Section 2.1 under Alternative A, the Proposed Action, for the life of mining within the 

Project Area. 

2.7 Alternatives Considered but Eliminated from Further Study 

NEPA requires that alternatives to the Proposed Action be rigorously explored and objectively evaluated 

and that the NEPA document provide a discussion of alternatives eliminated along with the reasons for 

their elimination (40 CFR 1502.14). Alternatives to the Proposed Action must meet the Purpose and 

Need for the Project, and offer significantly lower or fewer impacts to the environment than the Proposed 

Action. An alternative may be eliminated from detailed study for a number of reasons, including: 

•	 It does not meet the Project Purpose and Need; 

•	 It is technically or economically infeasible; 

•	 It is inconsistent with the basic policy objectives for the management of the area (such as, not in 

conformance with land use plans); 

•	 Its implementation is remote or speculative; 

•	 It is substantially similar in design to an alternative that is analyzed; or 

•	 It would have substantially similar effects to an alternative that is analyzed. 

2.7.1 Underground Mining Alternative 

An alternative to mine the federal coal within the Project Area using underground mining methods was 

suggested during the public outreach and was evaluated and eliminated from detailed study for several 

reasons, including: 1) CDRMS has approved a surface mining permit for this project using surface 

mining techniques; and underground mining is inconsistent with the approved permit; 2) underground 

mining is not consistent with the Purpose and Need for this EA; and 3) the percentage of coal recovered 

through underground mining methods would be less than the maximum economic recovery using 

surface mining methods and inconsistent with the Federal Coal Lease terms and the R2P2. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-18 
 

Chapter 2.0 – Proposed Action and Alternatives 

Figure 2-4 Proposed Mining Outside the Project Area 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-19 
 

Chapter 2.0 – Proposed Action and Alternatives 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-20 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 2.0 – Proposed Action and Alternatives 

This alternative also would be economically infeasible. The facilities and equipment needed for 

underground mining are different from surface mining. Because the infrastructure for underground 

mining is not in place at the Trapper Mine, new infrastructure for underground mining would need to be 

constructed. The capital expenditure to develop an underground mine would be prohibitive. In addition, 

all new surface facilities would need to be constructed, including, but not limited to, conveyors, coal 

stockpiles, a wash plant, one or more processing waste piles, and maintenance and support facilities. In 

addition, all new underground mining equipment would need to be purchased, such as, but not limited to, 

a long wall mining system, conveyor systems, drives and power stations, vehicles for transporting 

workers and supplies, several continuous miners, shuttle cars, large and small ventilation fans, and roof 

bolters. 

The coal seams currently mined by surface methods would not all be appropriate for recovery using 

underground mining. Many of the seams split or have partings making them uneconomic for 

underground mining. Recovery using underground mining methods is estimated by TMI to be 

approximately 35 percent of the 19.1 million tons proposed for recovery through surface mining in this 

EA (Hinkemeyer 2015). 

In addition, approval by CDRMS of an application for a PR or for a new mining permit would be required 

to authorize underground mining. The process for TMI to design and engineer a new underground mine 

and for CDRMS to process a permit application or revision would take a number of years. The extended 

time for permitting and design add to the underground mining alternative as an economically 

unreasonable alternative to consider. 

In summary, this alternative was not brought forward for analysis because underground mining would not 

respond to the Purpose and Need for this action, is not in conformance with the maximum economic 

recovery requirements of the federal coal leases and the R2P2, and, the economic burden to shift to 

underground mining would be prohibitive. 

2.7.2 Air Quality Mitigation Alternatives 

Two alternatives were evaluated to reduce greenhouse gas (GHG) emissions related to mining at the 

Trapper Mine. These two alternatives were suggested as part of the public outreach and are described 

below. 

The first alternative considered a reduction in coal production from the Trapper Mine, which would 

reduce Trapper Mine’s contribution of related emissions at the Craig Station from the burning of Trapper 

Mine coal. At the maximum permitted production rate of 2.6 mtpy as described in the Proposed Action, 

Trapper Mine would provide approximately 54 percent of the total coal needed to run the Craig Station. If 

mining operations at the Trapper Mine were reduced, it is likely the Craig Station would need to seek 

coal from other sources to meet the requirements to operate. Other sources would be more distant than 

the Trapper Mine and indirect emissions as a result of transport of that coal by truck or train to the Craig 

Station would increase while actual Craig Station emissions from burning of the coal would remain 

similar to current emissions. In addition, while the emissions from mining at the Trapper Mine would be 

reduced, it is expected that emissions from mining at the alternate coal source would increase if their 

production increased in order to meet the Craig Station demand. While the coal coming from the Trapper 

Mine is crushed at the Craig Station, it is likely that any coal transported from more distant sources would 

require crushing prior to transport, potentially resulting in increased emissions at that mine and during 

transport. Under this alternative, the Craig Station also might maintain a larger coal stockpile to ensure 

coal supply into the plant in the event of a delay in shipment, which also could increase air emissions at 

that location. 

Moreover, the effects of a reduced mining rate at the Trapper Mine would extend the environmental 

effects of the mining operation and the air emissions from mining equipment over a longer period of time 

to recover the coal within the Project Area. As currently estimated, the emissions from mining operations 

will cease from the Project Area in 2025. If a reduced mining rate at the Trapper Mine is implemented, 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-21 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 2.0 – Proposed Action and Alternatives 

the emissions from active mining within the Project Area could be extended for several years depending 

on the rate of reduction. The reduced mining rate would change Project economics by decreasing both 

costs and revenues and would require a smaller workforce resulting in layoffs and associated negative 

economic impacts for the region. In addition, TMI would not be in compliance with the terms of their 

existing contracts with the owners of the Craig Station to supply the required amount of coal. 

OSMRE has determined that a reduced mining rate alternative would not meet the Project purpose and 

need. 

The second alternative evaluated the potential for reduced air emissions at the mine by changing or 

modifying mining related equipment to equipment which would produce lower air emissions. This 

equipment replacement would reduce the emissions related to fuel combustion but would not change the 

emissions related to particulate matter. Trapper Mine is a relatively small contributor of the emissions 

related to engine combustion (primarily carbon dioxide [CO2] and nitrogen oxides [NOX]) in the region. 

The Craig Station, Hayden Station, and oil and gas operations contribute the majority of these pollutants 

to the regional air quality. 

The cost to make the switch to equipment powered by a different fuel (such as natural gas or solar 

powered equipment) for the remaining 10-year life of the mine in the Project Area would be prohibitive for 

the minimal benefit to the regional air quality. To replace every piece of equipment in TMI’s current fleet 

with newer model equipment is estimated to cost approximately $84 million. This $84 million does not 

take into account upgraded equipment that would use a different fuel. As a fuel alternative, natural gas 

engines are more expensive, and the storage and transportation of natural gas is more complex than 

diesel. In addition, the use of natural gas powered engines in mining equipment is relatively new and 

some types of equipment would not be available for replacement with natural gas powered engines. The 

use of solar power to run large equipment has not been tested and is not considered technologically 

feasible at this time. Similarly, retrofitting existing equipment with additional emissions control devices 

would be expensive with limited effect on regional air emissions. In addition, there is an environmental 

impact associated with manufacturing new equipment including, the potential environmental impacts and 

associated emissions created by mining operations to obtain the required metals and then the emissions 

that result from the manufacturing processes. It also is likely that the current equipment would be sold to 

a third party and may or may not continue to be used and generate emissions. 

OSMRE has not brought forward this alternative for full analysis because natural gas and solar powered 

engine technology and retrofitting of existing equipment is not economically or technically feasible for all 

equipment at the Trapper Mine. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

2-22 
 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

3.0 Affected Environment1 

The CEQ regulations state that NEPA documents “must concentrate on the issues that are truly 

significant to the action in question, rather than amassing needless detail” (40 CFR 1500.1(b)). While 

many issues may arise during scoping, not all of the issues raised warrant analysis in an EA. Issues are 

analyzed if: 1) an analysis of the issue is necessary to make a reasoned choice between alternatives, or 

2) if the issue is associated with significant direct, indirect, or cumulative impact, or where analysis is 

necessary to determine the significance of the impacts. Table 3-1 lists the resources considered for this 

EA and the determination as to whether the resource required additional analysis. 

Table 3-1 Resources and Determination of Need for Further Analysis 

Determination* Resource Rationale for Determination 

PI Topography See discussion below. 

PI Air Quality See discussion below. 

PI Climate Change See discussion below. 

PI Geology and Minerals See discussion below. 

PI Surface Water and Groundwater Resources See discussion below. 

PI Soils See discussion below. 

PI Vegetation See discussion below. 

PI Wetlands and Riparian Zones See discussion below. 

PI Fish and Wildlife Resources See discussion below. 

PI Special Status Species See discussion below. 

PI Cultural and Historic Resources See discussion below. 

PI American Indian Concerns See discussion below. 

PI Socioeconomics See discussion below. 

NI Environmental Justice See discussion below. 

PI Visual Resources See discussion below. 

NI Recreation See discussion below. 

PI Paleontology See discussion below. 

PI Access and Transportation See discussion below. 

PI Solid Waste See discussion below. 

PI Noise See discussion below. 

NI Livestock Grazing See discussion below. 

NP Prime Farmlands See discussion below. 

NP Alluvial Valley Floors See discussion below. 

NP Floodplains No Federal Emergency Management 

Agency-designated floodplains are located 

within the Project Area. 

Italicized text denotes language inserted either in response to comments received on the EA (see Appendix E) or to clarify or 

update a topic based on new or additional information received. Each place where italicized text appears is denoted by a bar in 

the left hand margin. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

1 

3-1 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

3.1 

Chapter 3.0 – Affected Environment 

Table 3-1 Resources and Determination of Need for Further Analysis 

Determination* Resource Rationale for Determination 

NP Wild Horses No Herd Management Areas are located 

within or near the Project Area. 

NP Wildfire Management No public lands are located within or adjacent 

to the Project Area. 

NP Forest Management No public lands managed for commercial 

timber are located within or adjacent to the 

Project Area. 

NP Areas of Critical Environmental Concern No designated Areas of Critical 

Environmental Concern are located within or 

near the Project Area. 

NP Wild and Scenic Rivers No Wild or Scenic Rivers are located within or 

near the Project Area. 

NP Inventoried Roadless Areas No inventoried roadless areas are located 

within or near the Project Area. 

NP Wilderness Areas No Wilderness Areas or lands that meet the 

criteria for wilderness characteristics are 

located within or near the Project Area. 

NP Scenic Byways No scenic byways are located within or near 

the Project Area. 

NP Realty Authorizations No public lands that could have realty 

authorizations are located within or adjacent 

to the Project Area. 

NP Special use Authorizations No public lands that could have special-use 

authorizations are located within or adjacent 

to the Project Area. 

*		 NP = not present in the Project Area; NI = present but not affected to a degree that detailed analysis is required; and PI = 

present with the potential for impact; and analyzed in this EA.
	

General Setting 

The Project Area is located approximately six miles (9.7 km) south of the City of Craig, Colorado, in 

Moffat County (Figure 1-1). The site lies along the north slope of the Williams Fork Mountains. Nearby 

communities include the cities of Craig and Hamilton. 

The climate is semi-arid shrub steppe with strong seasonal variations. The mean annual precipitation 

is approximately 17.25 inches (43.8 centimeters [cm]) as measured at the weather station adjacent to 

the Trapper Mine office west of the Project Area. Between 33 and 50 percent of the precipitation is in 

the form of snowfall. Snowmelt runoff is the principal source of water for stream flows in northwest 

Colorado. The growing season is approximately 77 days. 

Figure 2-1 depicts the Project Area and the SMCRA permit boundary. The existing disturbance as of 

July 1, 2015, and the future disturbance from July 1, 2015, through the life of mine within the Project 

Area also are shown on Figure 2-1. The Project Area is the focus of the Affected Environment for this 

EA. However, several resource discussions include a larger area, such as the SMCRA permit boundary 

or the region, in order to provide context for the resource. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-2 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

3.2 Topography 

The Trapper Mine is located along the northern slope of the Williams Fork Mountains, a 25-mile-long 

(40-km-long) west-northwest trending range that forms a long ridge with elevations ranging between 

7,400 and 7,800 feet above mean sea level (amsl) (2,255 to 2,377 meters amsl). The Williams Fork 

Mountains form the drainage divide between the Williams Fork and Yampa rivers. The Yampa River 

flows generally east to west approximately 4.5 miles (7.2 km) north of the Project Area. The Williams 

Fork River flows into the Yampa River several miles west of the Project Area. 

Elevations in the Project Area range from approximately 6,500 to 7,800 feet amsl (1,981 to 2,377 meters 

amsl). See Map M3 of the PAP for the pre-mining topography. The north slope of the Williams Fork 

Mountains drops at grades up to 15 percent near the crest and flattens out to an approximate 2 percent 

grade closer to the Yampa River. 

3.3 Air and Climate Resources 

3.3.1 Airshed Boundary 

The airshed boundary was defined using a topographic/airshed approach. An assessment was 

conducted to determine the reasonable airshed where regional air quality impacts could occur. 

Boundaries were defined by topographic features and resulted in an area covering approximately 

4,000 square miles (12,360 square km) (Figure 3-1). 

The study area is identical to the study area defined for the Colowyo South Taylor/Lower Wilson Permit 

Expansion Area EA (OSMRE 2015). The airshed boundary covers southeastern sections of Moffat 

County, southwestern sections of Routt County, portions of northeastern Rio Blanco County, and a 

small section in extreme northern Garfield County. The Trapper Mine lies almost in the center of the 

airshed boundary. 

The airshed boundary is presently designated as attainment or unclassified for all criteria air pollutants. 

Information on the measured air pollutant concentrations representative of the study area is included 

later in this section. As of October 2015, the only designated non-attainment area in Colorado is on the 

Colorado Front range for ozone (O3). 

3.3.2 Regional Climate 

The climate of the area is typical of a semi-arid, continental, mid-latitude region: warm summers and 

cold winters are prevalent with strong diurnal and seasonal temperature variations. The flow of 

Pacific air dominates the climate and descends into the area as a warming and drying mass after 

depositing most of its moisture over the western slopes of the Sierra Nevada and Cascade mountains. 

This creates a large rain shadow effect over Nevada, Utah, and western Colorado. 

The predominant air mass over the Rocky Mountain region during the winter season is continental 

polar with cold, dry air during storm-free periods. Storm systems that result in fine, light, powdery 

snow may become established during winter as the region lies within the mean winter storm track. 

During the summer, the air masses are generally maritime polar. The region is usually south of the 

main storm track in the summer; however, localized thundershowers and thunderstorms occur 

primarily during the afternoon if a moisture supply is available either locally or in the air mass 

(BLM 2006). Summertime thunderstorms have the potential for heavy rains that may cause flash 

flooding during extreme events. 

3.3.3 Local Climate and Meteorology 

An on-site meteorological monitoring station has existed at Trapper Mine since March 2015 

(Station ID #5022). This monitoring station is equipped with a 10-meter (32.8-foot) tower that 

measures temperature, wind speed and direction, relative humidity, and solar radiation. The 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-3 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

temperature and humidity measurements are collected at the 2-meter (6.6-foot) level. The Trapper 

Mine tower also collects data for barometric pressure, peak wind speed, temperature differences 

between the 10- and 2-meter levels (“delta temperature”), and standard deviation of wind direction 

(sigma-theta), which is computed with the on-site data logger. The monitoring site location is within the 

Trapper Mine at latitude/longitude coordinates of 40.4309°N (north) and -107.5322°W (west). 

Additional data have been collected near the Trapper Mine at two locations. Trapper Mine personnel 

operate a National Weather Service Cooperative Station near the mine’s administrative office (Station 

Craig 4SW, ID #051932) where temperature and precipitation data are collected. The latitude/longitude 

coordinates for Craig 4SW are 40.4505°N and -107.5894°W. Additional temperature data are collected 

at the Craig-Moffat County Airport (Station ID 24046), located at latitude/longitude coordinates of 

40.4930°N, -107.5239°W. The Craig-Moffat County Airport elevation is approximately 6,191 feet amsl 

(1,887 meters amsl). Table 3-2 summarizes the temperature and precipitation data collected from all 

three monitoring stations referenced above. A wind rose for the Trapper Mine on-site monitoring program 

for the period March 11 through December 10, 2015, is provided as Figure 3-2. 

The warmest temperatures occur in July, with the mean temperature from the Craig-Moffat County 

Airport measuring 68.6 degrees Fahrenheit (°F). The coldest temperatures occur in January, with the 

mean temperature at the Craig-Moffat County Airport measuring 13.9°F. 

Annual precipitation amounts averaged over the reporting period (2005 to 2014) ranged from 

13.8 inches (35.1 cm) at the Craig-Moffat County Airport to 17.25 inches (43.8 cm) at the Craig 4SW, 

located at the Trapper Mine administrative office. The Craig 4SW monitoring station is located at a higher 

elevation, which explains the difference in the measured precipitation totals. September is the wettest 

month on average and February is the driest month on average. 

The wind rose at the Trapper Mine shows a large dominance of winds from the south through southwest. 

Winds are from the south through southwest nearly 50 percent of the observed hours for the monitoring 

period (March 10, 2015, through December 10, 2015). Winds from the northeast quadrant occur with the 

lowest frequency. The majority of measured wind velocities are less than seven meters per second 

(roughly 15 miles per hour). 

3.3.4 Regulatory Requirements 

3.3.4.1 National Ambient Air Quality Standards 

The regulatory framework for air quality includes both federal and state rules, regulations, and standards 

promulgated by the U.S. Environmental Protection Agency (USEPA) and implemented by the CDPHE. 

The CAA established the National Ambient Air Quality Standards (NAAQS) for seven criteria pollutants. 

The criteria pollutants are listed in Table 3-3 and include carbon monoxide (CO), lead (Pb), nitrogen 

dioxide (NO2), ozone (O3), particulate matter 10 microns or less in diameter (PM10), particulate matter 

2.5 microns or less in diameter (PM2.5), and sulfur dioxide (SO2). The USEPA Administrator recently 

lowered the O3 NAAQS from 75 to 70 parts per billion (ppb), as published in the Federal Register (FR) 

on October 26, 2015. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-4 
Chapter 3.0 – Affected Environment 

Figure 3-1 Airshed Boundary 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-5 
 

Chapter 3.0 – Affected Environment 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-6 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-2	 Monthly Temperature and Precipitation Statistics: Craig, Colorado, and Vicinity 

Period of Record: 2005-2014, except where noted 

Temperature (o

F) 

Station 

Station 

Number Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 

Trapper 

Mine1 

5022 Maximum ND ND 65.5 66.4 74.0 87.0 84.4 85.1 78.4 76.8 61.5 ND 

Minimum ND ND 24.3 19.2 25.7 45.5 49.8 42.1 40.5 28.2 5.0 ND 

Average ND ND 45.0 42.3 47.0 66.2 65.3 66.7 61.3 50.9 30.6 ND 

Craig 

4SW2 

51932 Maximum 30.1 34.4 46.6 55.3 65.8 77.9 86.4 83.2 74.4 59.6 46.7 31.1 

Minimum 6.1 11.0 20.0 26.7 36.1 43.7 51.6 49.3 40.3 30.2 19.7 9.1 

Average 18.1 22.7 33.3 41.0 51.0 60.8 69.0 66.3 57.4 44.9 33.2 20.1 

CraigMoffat 

County 

Airport2 

24046 Maximum 29.1 34.3 46.8 57.0 67.8 80.5 88.6 88.6 76.2 60.6 47.1 30.6 

Minimum 1.2 7.8 19.1 26.4 33.9 40.1 47.8 47.8 37.2 27.7 17.1 5.6 

Average 15.2 21.0 32.9 41.7 50.9 60.4 68.2 68.2 56.7 44.1 32.1 18.0 

Precipitation (inches) 

Station 

Station 

Number Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Total 

Craig 

4SW2 

51932 Rainfall 1.23 0.97 1.44 1.80 1.71 1.10 0.91 1.36 2.02 1.85 1.03 1.83 17.25 

Snowfall 11.03 8.68 8.58 6.54 1.10 0.02 0.00 0.00 0.00 2.52 6.20 15.99 60.66 

CraigMoffat 

County 

Airport2 

24046 Rainfall 0.84 0.61 0.99 1.40 1.47 1.13 0.97 0.97 1.91 1.49 0.92 1.19 13.89 

Snowfall ND ND ND ND ND ND ND ND ND ND ND ND ND 

1		 Data was gathered on-site from the Trapper Mine. The Trapper Mine on-site data collection started in March 2015 and a complete one-year data set was not available at the time the EA was 

prepared. 

2		 Data were gathered from the National Climate Data Center from January 2005 through December 2014, www.ncdc.noaa.gov/cdo-wed/datasets, except for Craig 4SW precipitation data 

which were taken from Trapper Mine records. The Craig 4SW Station is located adjacent to the Trapper Mine administrative office building and is operated by Trapper Mine personnel. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-7 
 

Chapter 3.0 – Affected Environment 

Figure 3-2 Trapper Mine Wind Rose 3/10/2015 - 12/10/2015 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 3-8 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-3 National Ambient Air Quality Primary Standards 

Pollutant Average Time 

National 

Standard 

Primary or Secondary 

Standard Form 

CO 

8-hour 9 ppm Primary Not to be exceeded more than 

once per year 1-hour 35 ppm Primary 

Lead Rolling 3-month 

average 

0.15 μg/m3 Primary & Secondary Not to be exceeded 

NO2 

1-hour 100 ppb Primary 98th percentile of the 1-hour 

daily maximum concentration, 

averaged over three years 

Annual 53 ppb Primary & Secondary Annual mean 

O3 

8-hour 70 ppb Primary & Secondary Annual fourth-highest daily 

maximum 8-hour 

concentration, averaged over 

three years. USEPA 

announced a revised O3 

standard on October 26, 2015 

Particle 

Pollution 

PM2.5 Annual 12 μg/m3 Primary Annual mean, averaged over 

three years 

Annual 15 μg/m3 Secondary Annual mean averaged over 

three years 

24-hour 35 μg/m3 Primary & Secondary 98th percentile, averaged over 

three years 

PM10 24-hour 150 μg/m3 Primary & Secondary Not to be exceeded more than 

once per year on average over 

three years 

SO2 1-hour 75 ppb Primary 99th percentile of 1-hour daily 

maximum concentrations, 

averaged over three years 

3-hour 0.5ppm Secondary Not to be exceeded more than 

once per year 3

μg/m = micrograms per cubic meter of air.
	

ppm = parts per million.
	

Pursuant to the CAA, the USEPA has developed classifications for distinct geographical regions known 

as Air Quality Control Regions (AQCR). In Colorado, the state has been divided into eight multi-county 

areas that are generally based on topography and have similar airshed characteristics. The airshed 

boundary (Figure 3-1) lies in the Western Slope Air Pollution Control Region as designated by the State 

of Colorado. USEPA designates whole or partial counties as attainment, unclassifiable, non-attainment, 

or maintenance for each criteria air pollutant. AQCRs classified as in attainment, are areas in which no 

pollutant has exceeded the NAAQS. Regions may be designated as unclassifiable if there is not 

sufficient ambient monitoring data from which to formally classify the area. However, in such cases, the 

unclassifiable region is still treated as being in attainment. A non-attainment classification represents an 

area in which one or more pollutants have exceeded the NAAQS. The maintenance designation is used 

when an area was formerly designated as non-attainment, but monitored pollutant levels have been 

reduced such that the area now attains the NAAQS. Moffat County and surrounding areas have been 

designated as attainment or unclassifiable for all criteria pollutants based on monitoring results that were 

below the applicable NAAQS. 

Colorado state air quality standards are identical to the NAAQS, except that Colorado has a state-only 

standard for SO2 equal to 0.267 ppm on a 3-hour average not to be exceeded more than once in any 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-9 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

12-month period. However, the 1-hour average SO2 NAAQS (75 ppb or 0.075 ppm) is the more 

restrictive standard. Compliance with the 1-hour SO2 NAAQS assures compliance with the State of 

Colorado 3-hour SO2 standard. 

3.3.4.2 Prevention of Significant Deterioration 

The CAA also divides areas where air quality is already cleaner than required by federal standards into 

three classes, and specifies the increments of SO2, NO2, and particulate pollution allowed in each 

class as regulated by the Prevention of Significant Deterioration (PSD) regulations (40 CFR 52.21). 

Designated Class I PSD areas include national parks and wilderness areas in existence as of 1977 

and exceeding a certain size. Allowable increments of increased pollution in these Class I areas are 

very small. Class II areas include all attainment and not classifiable areas not otherwise designated as 

Class I. Allowable increments of increased pollution in Class II areas are modest. Class III areas may 

be designated by states where industrial development is anticipated, but at the time of this writing, no 

Class III areas are designated in Colorado or elsewhere. 

The region surrounding the Trapper Mine is listed as a Class II area. Nearby Class I areas are the 

Flat Top Wilderness (approximately 25 linear miles [40 km] from the Project Area) and the Mount 

Zirkel Wilderness (approximately 35 linear miles [56 km] from the Project Area). Dinosaur National 

Monument (approximately 70 linear miles [113 km] from the Project Area), is officially designated as 

Class II, but Colorado’s state regulations treat this area as equivalent to a Class I area with regard to 

SO2 concentrations. The designated PSD increment for each class is listed in Table 3-4. 

Table 3-4 Prevention of Significant Deterioration Increments 

Pollutant Averaging Time 

Maximum Allowable Increase1 (μg/m3) 

Class I Area Class II Area Class III Area 

PM2.5 Annual 1 4 8 

24-hour 2 9 18 

PM10 Annual 4 1 

7 

34 

24-hour 8 3 

0 

60 

SO2 Annual 2 2 

0 

40 

24-hour 5 9 

1 

182 

3-hour 25 51 

2 

700 

NO2 Annual 2. 

5 

25 50 

Increment represents the maximum allowable increase in concentration above the baseline concentration established by 

40 CFR 52.21. 

3.3.4.3 Title V Operating Permits 

The CAA Amendments of 1990 introduced a new facility-wide Federal Operating Permit program, also 

known as Title V permits. Title V permits are required for facilities with the potential to emit more than 

100 tons per year (tpy) of a regulated pollutant, 10 tpy of any single hazardous air pollutant (HAP), or 

25 tpy of any combination of HAPs. Fugitive emissions count toward the major source applicability under 

Title V only for specifically listed emission source categories. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

1 

3-10 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

At Trapper Mine, the potential to emit (not counting fugitive emissions) is below the emissions threshold 

requiring a Title V Operating Permit. However, Title V operating permit requirements are typically 

applicable for the locations of final coal combustion and the Craig Station has been issued a Title V 

permit (Permit Number 960PMF155, issued May 1, 2005). 

3.3.4.4 Emission Standards at Coal Combustion Sources 

The CAA enacted the New Source Performance Standards (NSPS) and National Emissions Standards 

for Hazardous Air Pollutants for specific types of equipment located at new or modified stationary 

pollutant sources. NSPS regulations limit emissions from new, modified, or reconstructed emission units 

under the regulated source categories. Stationary sources typically meet the NSPS limits by installing 

modern equipment and/or adding air pollution control equipment. Specific to this EA, NSPS emissions 

standards apply to combustion of coal at the Craig Station. Other NSPS standards also may apply at the 

Craig Station related to coal processing (i.e., crushing and screening). 

Beginning in 2011, the Craig Station and other electricity generating facilities became subject to new 

emission standards to reduce mercury and other toxic air pollution from coal and oil combustion at 

electric generating units (EGUs). These rules set technology-based emissions limitation standards for 

mercury and other toxic air pollutants, reflecting levels achieved by the best-performing sources currently 

in operation. The final rule established HAP standards for new and existing coal- and oil-fired EGUs with 

a capacity of 25 MW or greater. All regulated EGUs are considered major sources under the final rule. 

While new sources must meet the standards at start-up of operations, existing sources generally have 

up to four years to comply with the Mercury and Air Toxics Standards (MATS). The emissions limits 

associated with the MATS rule are presented in Table 3-5. The Craig Station has already attained 

compliance with MATS for Units 1 and 2 and Unit 3 is scheduled to attain compliance by the end of 

2015. 

Table 3-5 MATS Emission Requirements1 Coal- and Oil-Fired Units 

EGU Subcategory 

Mercury Emission Limit 

(lb/GWh) 

Existing Regular Coal 0.013 

Designed for Low Rank Coal2 0.12 or 0.040 

IGCC (Gasified Coal) 0.03 

Solid-oil Derived & Continental Liquid Oil 0.002 

Non-continental Liquid Oil 0.004 

New Regular Coal 0.0002 

Designed for Low Rank Coal 0.04 

IGCC (Gasified Coal) 0.003 

Solid-oil Derived 0.002 

Continental Liquid Oil 0.0001 

Non-continental Liquid Oil 0.0004 

1 The Supreme Court recently held that the USEPA did not properly consider the costs of the MATS rule. See Michigan 

v. USEPA, 192 L. Ed. 2d 674 (June 29, 2015). The consequences of this decision are still being assessed by USEPA 

and the lower courts. For purposes of the Trapper Mine EA, the analysis includes the 2011 MATS rule because the Craig 

Station has already complied with those standards. 

2 Most of these units burn lignite coal.
	

lb/GWh = pounds of pollutant per gigawatt hour – electric output.
	

Source: USEPA February 16, 2012.
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-11 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

3.3.4.5 Visibility and Regional Haze 

Visibility impacts are managed under a State Implementation Plan (SIP) for the reduction of Regional 

Haze (CDPHE 2014a). This regulation is intended to reduce the visibility impacts from existing facilities. 

The national visibility goal under the regional haze program is to return visibility to “natural conditions” 

(i.e., conditions present in the absence of anthropogenic air pollution) by 2064. The initial step in 

reducing visibility impairing emissions at EGUs is known as Best Available Retrofit Technology (BART). 

The Craig Station has two units that are eligible for BART: Units 1 and 2. Under the Colorado Regional 

Haze SIP, Units 1 and 2 are required to meet emissions limits for NOX that are based on the installation 

of a Selective Catalytic Reduction (SCR) to reduce NOX emissions. The Craig Station is having SCR 

installed on Unit 1 by August 31, 2021, and on Unit 2 by January 31, 2018. These are the deadlines for 

BART controls per Colorado and USEPA regulations. The existing wet limestone scrubbers on Units 1 

and 2 already meet the SO2 emission limits in the Regional Haze SIP. According to modeling conducted 

as part of the BART analysis, the SCR NOX emission controls will improve visibility in nearby Class 1 

areas by 1.01 deciview (dv) at Unit 1 and by 0.98 dv at Unit 2. A deciview is a unit of measure for 

visibility and generally represents the change in light extinction that would be minimally perceptible to a 

normal human observer. Unit 3 at the Craig Station will have a Selective Non-Catalytic Reduction 

(SNCR) emission controls installed to reduce NOX emissions. Modeling predicts these emission 

reductions will improve visibility in nearby Class I areas by 0.32 dv. The SNCR technology is new and 

must be installed on Unit 3 by December 31, 2017, per Colorado and USEPA regulations. Unit 3 already 

employs a spray dryer absorber to control SO2 emissions, which meets the applicable emission limits in 

the Regional Haze SIP. 

3.3.5 Regional Air Quality 

The airshed boundary is currently classified as attainment or unclassified for all criteria pollutants. 

Monitoring of criteria pollutants in the region is generally performed near population centers or other 

locations of specific interest. Per USEPA guidelines, ambient monitoring is not required where 

pollutant concentrations are less than 60 percent of the NAAQS. As a result, the data described in this 

section are regionally representative, but are often from monitoring performed at some distance from 

the Project Area. 

Table 3-6 summarizes the regional air quality data for northwestern Colorado as provided by CDPHE 

for Calendar Year 2014. For this EA, data are reported where the site is regionally representative of air 

quality conditions and located within the airshed boundary (Figure 3-1). If no monitoring data have been 

collected for a particular pollutant within the airshed boundary, a representative monitoring suite or sites 

from outside the study area were selected. Monitoring data collected where measurements are 

influenced by local industrial emission sources were omitted as such measurements are specific to the 

monitoring location and would not be generally representative of current conditions within the airshed 

boundary. Based on the reported data, all measured pollutant concentrations are below the applicable 

NAAQS. The measured O3 concentrations listed in Table 3-6 also are below the new 70 ppb NAAQS 

standard adopted by the USEPA in October 2015. 

Table 3-6 Regional Air Quality 

Monitor Location 

Active 

Since 

Monitoring 

Agency 

Annual 

Samples 

Elevation 

(feet) 

Highest Measured 

Concentration During 2014 

1-hour 8-hour 24-hour 

PM10 (μg/m3) 

Rifle 2005 CDPHE 120 5,340 NA NA 47 

Parachute High 

School 

2001 CDPHE 119 5,100 NA NA 39 

Steamboat Springs 1987 CDPHE 346 6,740 NA NA 84 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-12 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-6 Regional Air Quality 

Monitor Location 

Active 

Since 

Monitoring 

Agency 

Annual 

Samples 

Elevation 

(feet) 

Highest Measured 

Concentration During 2014 

1-hour 8-hour 24-hour 

PM2.5 (ppb) 

Rangely 2011 BLM 325 5,430 NA NA 17.8 

NO2 (ppb) 

Rangely 2011 BLM 8,592 5,430 19.6 NA NA 

Meeker 2011 BLM 8,584 6,540 6.1 NA NA 

SO2 (ppb) 

Walden- Colorado 

Chandler Ranch 

2012 USFS 4,452 7,930 1 NA 0.5 

Williams Willow 

Creek 

2012 Private Hourly 6,400 1 (2012) NA 1 (2012) 

CO (ppm) 

Walden – Colorado, 

Chandler Ranch 

2013 USFS 4,330 7,930 0.3 0.3 NA 

O3 

Rifle 2009 CDPHE 192 days 5,380 NA 0.062 NA 

Meeker 2010 BLM 206 days 6,540 NA 0.063 NA 

Rangely 2011 BLM 203 days 5,430 NA 0.066 NA 

Lay Peak 2012 CDPHE 212 days 6,240 NA 0.067 NA 

NA = not applicable; no air quality standard exists for the pollutant and averaging time.
	

USFS – U.S. Forest Service
	

3.3.5.1 Particulate Matter (PM10/PM2.5) 

Representative PM10 measurements have been collected at three monitoring locations in northwest 

Colorado; one in Rifle, one in Steamboat Springs, and one in Parachute. Data from 2014 also are 

available for Grand Junction but are not included here as the other data are more representative of the 

EA airshed boundary. The highest 24-hour concentration for Parachute measured during 2014 was 

39 μg/m3

, the highest 24-hour concentration for Rifle was 47 μg/m3, and the highest 24-hour 

concentration for Steamboat Springs was 84 μg/m3

. 

Representative PM2.5 measurements were collected during 2014 at Rangely, Colorado. The maximum 

24-hour average PM2.5 concentration from this site was 17.8 μg/m3

. 

All measured values are currently below the NAAQS (PM10 = 150 μg/m3

, PM2.5 = 35 μg/m3). The 

reported concentrations in Table 3-6 are conservative with respect to the NAAQS. The table lists the 

maximum measured concentration during 2014, and NAAQS compliance is assessed using the 

second-highest 24-hour average concentration for PM10 and the three-year average of the 98th percentile 

24-hour average concentration for PM2.5. In a complete one-year data set (365 samples), the 98th 

percentile concentration is the 8th highest daily value. 

3.3.5.2 Nitrogen Dioxide (NO2) 

The nearest representative NO2 data for the airshed boundary were collected at the U.S. Department of 

Agriculture (USDA) Upper Colorado Environmental Plant Center in Meeker Colorado. The maximum 

hourly NO2 measured at the site during 2014 was 6.1 ppb. NO2 data are also reported for Rangely, 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-13 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

where the measured concentration was 19.6 ppb; however, the Rangely monitoring site lies outside the 

defined Trapper EA airshed boundary. For comparison, the 1-hour NO2 NAAQS of 100 ppb is 

calculated as the three-year average of the 98th percentile maximum daily 1-hour concentration. In a 

complete one-year data set (365 samples), the 98th percentile concentration is the 8th highest daily 

value. 

Near the Trapper Mine, local NO2 concentrations are most likely linked to emissions from the Craig 

Station. NOX emissions at Craig Station occur from coal combustion at the power plant boilers. As 

referenced in Section 3.3.4.5, improved NOX emission controls are being installed at the Craig Station 

per the Colorado Regional Haze SIP. As a result, a future reduction in NOX emission levels from the 

Craig Station is anticipated. 

3.3.5.3 Sulfur Dioxide (SO2) 

The nearest representative SO2 data for the airshed boundary were collected at Chandler Ranch, 

near Walden, Colorado and also at a private monitoring site near the Williams Willow Creek Plant in 

Rio Blanco County, Colorado. The maximum hourly SO2 measured at Chandler Ranch during 2014 

was at or below 1 ppb. Williams Willow Creek also recorded a maximum 1-hour SO2 concentration at 

or below 1 ppb, but this monitor only operated during 2012. For comparison, the 1-hour SO2 NAAQS is 

75 ppb, calculated as the three-year average of the 99th percentile maximum daily 1-hour concentration. 

In a complete one-year data set (365 samples), the 99th percentile concentration is the 4th highest daily 

value. 

Near the Trapper Mine, local SO2 concentrations are most likely linked to emissions from the Craig 

Station. SO2 emissions at Craig Station occur from coal combustion at the power plant boilers. As 

referenced in Section 3.3.4.5, the Craig Station already controls SO2 emissions using either a wet 

scrubber (Units 1 and 2) or a spray dryer absorber (Unit 3). 

3.3.5.4 Carbon Monoxide (CO) 

The nearest representative CO monitoring data for the airshed boundary were collected at Chandler 

Ranch, near Walden. CO is predominantly an urban air pollutant, generally associated with combustion 

emissions from motor vehicles. 

The measured concentrations were very low, which is characteristic of a remote location located 

away from urban emission sources. The maximum CO measured at Chandler Ranch during 2014 

was 0.3 ppm for both the maximum 1-hour and 8-hour concentrations. For comparison, the CO 

NAAQS is 35 ppm for the 1-hour average and 9 ppm for the 8-hour average. 

3.3.5.5 Ozone (O3) 

Representative O3 measurements in northwest Colorado are collected at several locations: Rifle, 

Rangely, Meeker, and Lay Peak (west of Craig near Maybell). The monitoring at Rifle, Rangely, and 

Meeker are seasonal monitors, where the Lay Peak monitor has operated continuously since 2012. 

All of the monitors show similar annual O3 levels, with the peak 8-hour average concentrations during 

2014 in the range of 62 to 67 ppb. By comparison, the O3 NAAQS is 70 ppb, measured as the 

three-year average of the 4th highest daily maximum 8-hour average concentration. The measured O3 

are currently under the new O3 NAAQS based on the 2014 monitoring data provided above. However, a 

formal determination of compliance with the new O3 NAAQS requires at least three years of data. 

3.3.6 Industrial Source Emissions Inventory 

The airshed boundary is generally rural with anthropogenic emission sources dominated by mining, 

power generation, oil and gas production, and aggregate (sand and gravel) processing. The CDPHE 

requires permits for all new and/or modified sources of air quality emissions. The air quality permit 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-14 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

program dates back to about 1970. Only non-major sources in existence prior to the initial adoption of 

the Colorado Air Quality Control Commission Regulation 3, Stationary Source Permitting and Air 

Pollutant Emission Notice (APEN) Requirements, would be exempt from the permit requirements. 

Trapper Mine operates pursuant to an air quality permit issued by CDPHE. Regulated emissions in 

Trapper Mine’s permit include particulate matter associated with mining operations (i.e., drilling, 

blasting, coal and overburden excavation and handling, etc.), coal hauling to the Craig Station, and 

emissions associated with placement of CCRs within the mine site. Gaseous emissions associated with 

blasting also are regulated. Trapper Mine’s air quality permit was most recently issued in 2009 and has 

no set expiration date. This permit would be modified as needed to address future changes in mining 

operations and/or changes in air pollution regulatory requirements. 

Certain activities are exempt from CDPHE stationary source permit requirements. Emission source, 

such as dust from most paved and unpaved public roads, most agricultural operations, recreational 

activities, and emissions from mobile sources (e.g., automobiles, trucks, etc.,) do not require 

stationary source permits. However, these sources may still be regulated by CDPHE as they have the 

capacity to impact regional air quality. Any impact associated with emissions from these sources would 

be reflected in the regional air quality data described in the previous section. 

Two existing coal-fired EGUs are currently operating in the airshed boundary. The Craig Station is 

located adjacent to the Trapper Mine and is operated by Tri-State Generation and Transmission 

Association Inc. The Craig Station consists of three coal-fired steam driven EGUs (Units 1, 2, and 3) 

with a net electric generating capacity of 1,264 MW. 

The other local EGU is the Hayden Station owned and operated by the Public Service Company of 

Colorado, located approximately 16 miles (25.7 km) from Craig and four miles (6.4 km) east of Hayden 

(21 miles [33.8 km] from the Craig Station). It consists of two coal-fired steam-driven EGUs (Units 1 

and 2). Hayden Station Units 1 and 2 have a combined rating of 446 MW. 

Actual emissions data for both the Craig Station and Hayden Station are listed in Table 3-7. 

Table 3-7 Craig Station and Hayden Station: Reported Actual Emissions (2014) 

EGU 

2014 APENs Annual Actual Pollutant Emissions (tpy) 

PM10 PM2.5 CO NO2 SO2 VOC HAPs 

Craig 134.6 84.1 1669.3 13379.3 3763.3 58.0 52.26 

Hayden 148.3 67.5 385.1 6483.6 2330.7 49.2 15.08 

VOC = volatile organic compound. 

3.3.7 Greenhouse Gas Emissions and Climate Change 

The primary natural and synthetic GHGs in the Earth's atmosphere are water vapor, CO2, methane 

(CH4), nitrous oxide (N2O), and fluorinated gases. GHGs allow heat from the sun to pass though the 

upper atmosphere and warm the earth by blocking some of the heat that is radiated from the earth back 

into space. 

CO2 emissions occur from the combustion of fossil fuels (i.e., oil, natural gas, and coal) by industry and 

in the transportation sector, and as a result of other chemical reactions (e.g., the manufacture of 

cement). CH4 emissions occur from livestock and other agricultural practices and also from the decay of 

organic waste placed in municipal solid waste landfills. CH4 also is emitted during the production and 

transport of coal, natural gas, and oil. The largest natural source of CH4 is wetlands where bacteria 

decompose organic matter in the absence of oxygen. Other natural CH4 sources include termites, 

oceans, sediment, volcanoes, and wildfires. N2O is emitted during agricultural and industrial activities, as 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-15 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

well as during combustion of fossil fuels and solid waste. Fluorinated gases, while not abundant in the 

atmosphere, are powerful GHGs that are emitted from a variety of industrial processes and are often 

used as substitutes for O3-depleting substances (e.g., chlorofluorocarbons, hydrochlorofluorocarbons, 

and halons). 

NAAQS do not exist for GHGs. In its Endangerment and Cause or Contribute Findings for Greenhouse 

Gases under CAA Section 202(a) (FR EPA-HQ-OAR-2009-0171), USEPA determined that GHGs are air 

pollutants subject to regulation under the CAA. USEPA acted on its understanding that GHG pollutants 

have long-term impacts on the climate because of their increasing concentrations in the earth’s 

atmosphere, which has been tied to industrialization and the burning of fossil fuels. GHGs can be 

produced from the direct process of coal mining and from the combustion of mined coal. The amount of 

GHG emissions associated with these processes varies depending on the mining technique used 

(i.e., surface versus underground mining) and combustion technologies employed. 

USEPA has regulated six key GHGs: CO2, CH4, N2O, hydrofluorocarbons (HFC), perfluorocarbons 

(PFC), and sulfur hexafluoride (SF6). Because CO2 is the most prevalent of the regulated GHGs, the 

USEPA references the impact of GHG emissions in terms of their equivalence to CO2 or carbon dioxide 

equivalent (CO2e). In addition to the USEPA estimates, the International Energy Agency estimated global 

emissions to be 29,000 million metric tons (MMT) CO2e in 2008. On a regional scale, CDPHE (2014) 

estimated the total 2010 (Calendar Year) GHG emissions to be 130 MMT CO2e for the State of Colorado. 

The USEPA has promulgated rules to regulate GHG emissions and the industries responsible under the 

Mandatory Reporting Rule (74 FR 56260, 40 CFR 98) and the Tailoring Rule (70 FR 31514, 40 CFR 51, 

52, 70, and 71). Under the USEPA’s GHG Mandatory Reporting Rule, coal mines subject to the rule are 

required to report emissions in accordance with the requirements of Subpart FF. Subpart FF is applicable 

only to underground coal mines and is not applicable to surface coal mines such as the Trapper Mine. 

The USEPA Tailoring Rule was, in part, struck down by a 2014 Supreme Court decision. Based on the 

Supreme Court decision, a facility would be subject to PSD permitting for GHGs only if it has the potential 

to emit GHGs in excess of 100,000 tpy of CO2e and also if the facility exceeded the PSD major source 

threshold for one or more criteria pollutants. For existing facilities this review would take place during any 

subsequent modifications to the facility that would trigger PSD review. Based on emission estimates for 

the Trapper Mine, no GHG reporting or permitting would currently apply to the mine given that the mine is 

not a major source for non-GHG pollutants. However, GHG emissions reporting does apply to the Craig 

Station and future GHG permitting could apply for future modifications (if any). The USEPA also has 

recently adopted regulations for GHG emissions from new and existing fossil fuel-fired EGUs (the USEPA 

Clean Power Plan), although the new USEPA regulations have been challenged in court. 

The USEPA tracks GHG emissions in the U.S. by source sector (e.g., industrial, land use, electricity 

generation, etc.); fuel source (e.g., coal, natural gas, geothermal, petroleum, etc.); and economic sector 

(e.g., residential, transportation, commercial, agriculture, etc.). With so many GHG emission sources, 

from cattle to vehicles to electric power generators, no single source represents a significant percentage 

of national emissions. 

Table 3-8 shows GHG emissions by economic sector as reported during 1995, 2000, and 2007 in units of 

CO2e (USEPA 2015). Compared to 2000, the 2007 U.S. GHG emissions decreased slightly. The 

contribution of each major economic sector to the GHG emissions total also is shown. Note that for CO2, 

“Land Use, Land-Use Change, and Forestry” represents a sink rather than a source, and is therefore 

presented in parentheses. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-16 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-8 U.S. Greenhouse Gas Emissions Allocated to Economic Sectors 

Implied Sectors 

1995 

(MMT CO2e) 

2000 

(MMT CO2e) 

2007 

(MMT CO2e) 

Electric Power Industry 1,989.0 2,329.3 2,445.1 

Transportation 1,685.2 1,919.7 1,995.2 

Industry 1,524.5 1,467.5 1,386.3 

Agriculture 453.7 470.2 502.8 

Commercial 401.0 388.2 407.6 

Residential 368.8 386.0 355.3 

U.S. Territories 41.1 47.3 57.7 

Total Emissions 6,463.3 7,008.2 7,150.1 

Land Use, Land-Use Change, and 

Forestry (Sink) 

(851.0) (717.5) (1,062.6) 

Net Emissions (Sources and Sinks) 5,612.3 6,290.7 6,087.5 

Table 3-9 (USEPA 2015) shows total U.S. GHG emissions reported for 1995, 2000, and 2007 for each 

major GHG contributor (CO2, CH4, N2O, etc.). This table also shows the largest emissions/sinks for each 

gas/source. 

Table 3-9 U.S. Greenhouse Gas Emissions and Sinks 

Gas/Source 

1995 

(MMT CO2e) 

2000 

(MMT CO2e) 

2007 

(MMT CO2e) 

CO2 5,407.9 5,955.2 6,103.4 

Fossil Fuel Combustion 5,013.9 5,561.5 5,735.8 

Non-Energy Use of Fuels 137.5 144.5 133.9 

Iron and Steel Production and Metallurgical 

Coke Production 

103.1 95.1 77.4 

Cement Manufacture 36.8 41.2 44.5 

Natural Gas Systems 33.8 29.4 28.7 

Land Use, Land-Use Change, and Forestry 

(Sink) 

(851.0) (717.5) (1,062.6) 

CH4 615.8 591.1 585.3 

Enteric Fermentation 143.6 134.4 139.0 

Landfills 144.3 122.3 132.9 

Natural Gas Systems 132.6 130.8 104.7 

Coal Mining 67.1 60.5 57.6 

Manure Management 34.5 37.9 44.0 

N2O 334.1 329.2 311.9 

Agricultural Soil Management 202.3 204.5 207.9 

Mobile Combustion 53.7 52.8 30.1 

Nitric Acid Production 22.3 21.9 21.7 

Stationary Combustion 13.3 14.5 14.7 

Manure Management 12.9 14.0 14.7 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-17 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-9 U.S. Greenhouse Gas Emissions and Sinks 

Gas/Source 

1995 

(MMT CO2e) 

2000 

(MMT CO2e) 

2007 

(MMT CO2e) 

HFCs, PFCs, and SF6 105.5 132.8 149.5 

Substitution of Ozone Depleting Substances 28.5 71.2 108.3 

HCFC-22 Production 33.0 28.6 17.0 

Electrical Transmission and Distribution 21.6 15.1 12.7 

Total Emissions 6,463.3 7.008.2 7,150.1 

Net Emissions (Sources and Sinks) 5,612.3 6,290.7 6,087.5 

Secondary GHGs do not have a direct atmospheric warming effect, but indirectly affect terrestrial 

radiation absorption by influencing the formation and destruction of tropospheric and stratospheric O3, or 

in the case of SO2, the absorptive characteristics of the atmosphere. 

Additionally, some of these gases may react with other chemical compounds in the atmosphere to form 

compounds that are GHGs. For example, the roasting of molybdenite in ore processing is among the 

sources of indirect GHG emissions to the atmosphere, specifically SO2. 

National SO2 emissions across the U.S. are listed in Table 3-10. SO2 emission levels have decreased 

since 1995, primarily due to increased emission controls for SO2, including the increased use of low 

sulfur coal from mines in the western states. 

Table 3-10 U.S. Sulfur Dioxide (Indirect GHG) Emissions 

Gas/Source 

GHG 1995 

(MMT) 

GHG 2000 

(MMT) 

GHG 2007 

(MMT) 

SO2 16.89 14.83 11.73 

Energy (combustion, etc.) 15.77 13.80 10.89 

Industrial Processes 1.12 1.03 0.84 

Chemical manufacturing 0.26 0.31 0.23 

Metals processing 0.48 0.28 0.19 

Other 0.37 0.37 0.29 

3.3.8 Black Carbon 

Black carbon is a by-product of incomplete combustion of fossil fuels, biofuels, and biomass. It can be 

emitted when coal is burned, as well as through tailpipe emissions from engines that use diesel fuel 

(e.g., diesel trucks and locomotives). Black carbon is a likely by-product that would be emitted 

from haul trucks and other diesel-powered equipment used during coal mining operations. Black 

carbon is an unregulated pollutant; however, the USEPA does regulate diesel fuel quality, such that in 

recent years diesel fuel quality has been improved by placing maximum limits on fuel sulfur content. 

Black carbon emissions also can be associated with coal combustion. Black carbon from coal 

combustion is linked with visibility impairment and regional haze because black carbon is the most 

strongly light-absorbing component of particulate matter. However, measurements for visibility 

impairment typically show other atmospheric pollutants such as sulfate, nitrates, and organics are larger 

contributors to visibility impairment compared to black carbon. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-18 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

3.4 Geology and Minerals 

3.4.1 Geology 

The Trapper Mine is located in the Yampa coal field that is composed of coal-bearing rocks that are 

Upper Cretaceous in age. The coal-bearing rocks mainly outcrop south of the Yampa River in northwest 

Colorado. The Yampa coal field extends east to west about 50 miles (80.5 km) and is about 40 miles 

(64.4 km) north to south. 

The surface bedrock in the Trapper Mine Project Area is mainly the Upper Cretaceous Williams Fork 

Formation, which is part of the Mesaverde Group, a regional unit that contains a large coal resource in 

northwest Colorado (Brownfield and Johnson 2008). The Williams Fork Formation consists of 

interbedded sandstones, siltstones, shale, and coals and crops out along a six-mile-wide (9.7-km) belt 

that extends along the entire length of the Williams Fork Mountains (Tweto 1976). The Williams Fork 

Formation is underlain by the Illes Formation, also part of the Mesaverde Group. The Illes Formation is 

lithologically similar to the Williams Fork Formation consisting of sandstones, mudstones, carbonaceous 

shale, and coal (Brownfield and Johnson 2008). The Lewis Shale, which is stratigraphically higher than 

the Mesaverde Group, outcrops in the northern extremity of the SMCRA permit area. The Lewis Shale 

also is Upper Cretaceous in age and is composed of uniform dark-gray marine shale, but also contains 

thin sandstones (Johnson 1987; Tweto 1976). Surficial deposits consist of alluvium, residuum derived 

from the Williams Fork Formation and the Lewis Shale, and landslide deposits (Madole 1989). 

Quaternary alluvial deposits composed of sand, silt, clay, and gravel are present in the stream drainages 

in the permit area and surrounding areas, but alluvium is thickest in the Yampa River and Williams Fork 

River valleys (CDRMS 2013). Residuum is composed of sand, silt, clay, gravel, and boulders derived 

from the underlying bedrock. 

The landslide deposits that are part of the surficial deposits are either rotational slides or earthflows and 

involve the Williams Fork Formation (Madole 1989). A major landslide occurred at the mine in October 

2006 (CDRMS 2013). Prior to the slide, there was heavy precipitation that facilitated the movement of an 

estimated 35 million cubic yards of material with original in-place dimensions of 250 acres and 100 feet 

(30.5 meters) deep (Buchsbaum 2011). The material was largely contained in an active pit, but the slide 

made it necessary for the mine to alter its mine plan. 

Structurally, the mine is bounded on the west, north, and northeast by three major folds. From west to 

east, the Williams Fork Anticline, Big Bottom Syncline, and Breeze Mountain or Buck Peak Anticline 

(Brownfield and Johnson 2008). At the mine, the beds of the Williams Fork Formation dip generally to 

the north at an altitude of 14 to 16 degrees. The Project Area lies on the south flank of the Sand Wash 

Basin, a structural basin which is the southeast extension of the Greater Green River Basin (Horn and 

Richardson 1959; TMI 1981 et seq.). 

The region is not very seismically active. From 1979 to 2014, there were 48 earthquake events greater 

than 1.0 magnitude within a 60-mile (96.6-km) radius of the mine, with no events with a magnitude 

greater than 4.3 (U.S. Geological Survey [USGS] 2015). No major faults have been found in the permit 

area (CDRMS 2013). A large unnamed down-to-the-north normal fault lies about two miles (3.2 km) 

south of the SMCRA permit area in T9N, R90W (Brownfield and Johnson 2008; Tweto 1976). The fault 

as mapped by Tweto (1976) is about four miles (6.4 km) long and is not classified as active. No active 

faults have been identified in the area (USGS and Colorado Geological Survey 2006). There is a low 

probability of strong ground motion if a maximum credible earthquake were to occur in the vicinity. 

Horizontal ground motions are expected to be 18 to 20 percent of the acceleration gravity with a 

2 percent probability of exceedance in 50 years (Petersen et al. 2015). 

3.4.2 Mineral Resources 

Coal has been mined in the Yampa coal field since 1864, and 192 surface and underground mines have 

been identified (Johnson et al. 2000). The cumulative production from the Yampa coal field to 2014 is 

estimated to be almost 600 million tons (Carroll 2004; CDRMS 2015). In the Project Area, the Williams 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-19 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Fork Formation consists of three members: the lower Williams Fork, Twentymile Sandstone, and upper 

Williams Fork (CDRMS 2013). The upper Williams Fork member contains the coals that are mined at the 

Trapper Mine and are designated (from lowest to highest): R, Q, M, L, K, I, and H. Historical 

development began in 1954, and modern coal production began in 1977. Annual production has varied 

from 1.5 to about 2.5 mtpy (Colorado Mining Association 2015; TMI 2015). Total cumulative production 

over the entire life of the mine is expected to be 74 million tons (CDRMS 2013). The coal seams that are 

mined at the Trapper Mine have consisted of a mixture of subbituminous A, B, and C, and high-volatile 

bituminous C coals. Average, as-received, values of ash yield are 7.05 percent and sulfur content is 

0.40 percent, with a heat value of 9,931 British thermal units per pound (Johnson et al. 2000). 

Other important mineral resources in the vicinity of the Trapper Mine Project Area are oil and gas. To the 

north of the mine are the Craig and Buck Peak fields and to south are the Williams Fork and Horse 

Gulch fields (Colorado Oil and Gas Conservation Commission [COGCC] 2015). The oil and gas 

production comes from mostly upper and lower Cretaceous units, but the Williams Fork field also 

produces from Jurassic, Triassic, and Permian formations. In 2011, oil and gas production was 

established just outside of the mine permit boundary in the east half of Section 30, T6N, R90W. Two 

wells have cumulatively produced approximately 43,000 barrels of oil, 92 million cubic feet of gas, and 

420 barrels of water from a nominal depth interval of 6,700 to 8,100 feet (2,042 to 2,469 meters) (true 

vertical depth) in the Niobrara Formation. 

There are numerous gravel pits located in the alluvium of the Yampa River and other local drainages 

(Guilinger and Keller 2002). Stone also is quarried in the area. No other important mineral resources 

were identified in the vicinity of the Project Area. 

3.5 Water Resources 

3.5.1 Surface Water 

The Project Area is located in the Upper Yampa River watershed, which is part of the Upper Colorado 

River Basin (USGS 2015). The Yampa River is the principal drainage within the watershed. It flows north 

from its headwaters in the Gore Range before making a westerly turn at Steamboat Springs, Colorado. 

Downstream of Craig, the Yampa River is joined by the Williams Fork River, one of its major tributaries. 

The Williams Fork Mountains form the drainage divide between the Yampa River to the north and the 

Williams Fork River to the south. 

TMI has extensive monitoring data for surface water quantity and quality within and adjacent to the 

SMCRA permit boundary. The following discussion provides a general understanding of surface water 

resources in the vicinity of the Project Area and within and adjacent to the broader SMCRA permit 

boundary. 

Because the SMCRA permit boundary is located primarily on the north side of the Williams Fork 

Mountains, most of the smaller drainages within the boundary flow north and west to the Yampa River. 

These drainages include Buzzard Gulch, Coyote Gulch, No Name Gulch, Johnson Gulch, Pyeatt Gulch, 

Grouse Gulch, Sage Gulch, Oak Gulch, Flume Gulch, and Deacon Gulch. A small portion of the SMCRA 

permit area is located south of the Yampa-Williams Fork drainage divide and drains to the Williams Fork 

River. Tributaries to the Williams Fork within the SMCRA permit boundary include Ute Gulch, Castor 

Gulch, Horse Gulch, and Deal Gulch. Of these drainages, only Pyeatt, Sage, Oak, Flume, Deacon, 

Horse, and Deal Gulches cross the Project Area (Figure 3-3). 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-20 
Chapter 3.0 – Affected Environment 

Figure 3-3 Surface Water Resources 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-21 
 

Chapter 3.0 – Affected Environment 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-22 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Surface water morphology in the area is influenced by the lithology and orientation of the underlying 

bedrock. The mine is located on the south limb of the Big Bottom syncline. Geologic formations within 

the syncline are dipping to the north at approximately the same angle as the topographic gradient. As a 

result, the Williams Fork Formation is present near the ground surface for long stretches, and surface 

water drainages continuously flow across the same geologic material. The resulting drainage pattern is 

dendritic, with broad swales in the upland areas that transition to broad valleys 50 to 100 feet (15.2 to 

30.5 meters) deep (TMI 1981 et seq.). On the south side of the Williams Fork Mountains, the overall 

slope of the land surface is much steeper, with outcrops of resistant sandstone forming cliff faces in 

some areas. The steep slopes and bedrock control of channels produce a trellis drainage pattern. 

The drainages north of the Williams Fork Mountains typically exhibit stream gradients ranging from 

0.088 to 0.11 feet/foot (TMI 1981 et seq.). Profile views of the stream channels reveal that the stream 

gradient is typically higher in the upstream reaches and flattens out in the downstream direction. This 

geometry is a sign of the relative youth of the drainage system. The streams have continuously lowering 

gradients through incision in their upper reaches. This is occurring in both alluvial and non-alluvial 

geologic material. The stream incisions likely progress upstream during the annual spring runoff, which 

may initiate some natural gullying on the side slopes adjacent to the channels as the base level of the 

slopes is lowered. Erosion scars created by this head-cutting are naturally re-vegetated throughout the 

year (TMI 1981 et seq.). 

The Project Area drainages are uniformly classified as ephemeral streams. Stream flow occurs mainly in 

response to spring snowmelt, summer thunderstorms, seeps originating in the upper bedrock aquifers, 

and groundwater discharge during periods of high precipitation. Annual runoff from the Trapper Mine has 

been estimated at approximately 1 inch per unit area (TMI 1981 et seq.). Based on this estimate, the 

Trapper Mine SMCRA permit area contributes approximately 730 acre-feet of runoff to the Yampa River 

and 200 acre-feet of runoff to the Williams Fork River each year (AECOM 2015). 

Surface water flow is highly seasonal in the area, even for perennial drainages like the Yampa River and 

Williams Fork River. Previous investigations have documented that approximately 65 percent of annual 

flow in the Yampa Valley occurs in May and June, with up to 85 percent occurring from April to July 

(Steele et al. 1979). Baseflow throughout the remainder of the year is supplied mainly from groundwater 

discharge. 

Stream flows in the ephemeral drainages within the SMCRA permit area also are highly variable. TMI 

collected baseline flow data for the SMCRA permit area in the late 1970s and early 1980s. The most 

complete baseline dataset available is for CDPS Site 002 on No Name Gulch located west of the Project 

Area. The flow data for this site, plotted on Figure 3-4 below, shows that No Name Gulch is dry for the 

majority of the year. Brief pulses of sustained flow occurred in March 1979, August 1979, February 1980, 

and April 1980. These data reinforce the notion that flow in Project Area drainages mainly occurs in 

response to spring snowmelt and occasional summer thunderstorms. 

Mine records indicate that from approximately 1981 to 1986, perennial flow occurred in East Pyeatt 

Gulch outside of the Project Area but within the SMCRA permit boundary and in Middle Flume Gulch 

(referred to as the East Middle Flume Gulch in the baseline water quality discussion in the TMI PAP) 

which drains the Project Area. This period of sustained flow was attributed to groundwater discharge 

from alluvium and seep flow originating from bedrock aquifers (TMI 1981 et seq.). TMI used streamflow 

hydrographs collected during this time frame to estimate the baseflow and runoff contributions in each 

stream. The average flow rate at East Pyeatt Gulch was approximately 0.36 cubic feet per second (cfs), 

with about 75 percent of the flow originating from groundwater discharge and 25 percent derived from 

runoff. At Middle Flume Gulch, contributions from baseflow and runoff were found to be approximately 

equal, and amounted to an average total flow rate of 0.16 cfs (TMI 1981 et seq.). 

Local seeps and springs resulting from groundwater discharge also may contribute to surface water 

flows in the Project Area. TMI initiated a detailed survey of spring locations within the SMCRA permit 

boundary in 1997. This survey identified a number of natural springs that existed prior to mining, 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-23 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

including Coyote Spring, East Pyeatt Spring, Fox Den Spring, Ute Gulch Spring, and North Horse Gulch 

Spring (Figure 3-3). The 1997 survey also identified several spoil springs within or adjacent to mined 

and backfilled areas. These spoil springs are not naturally occurring but likely formed as a result of 

mining activity. East Pyeatt South Spring is the only spoil spring that is currently monitored at the mine 

(Figure 3-3). Other spoil springs that were monitored historically were removed from the monitoring 

program when the area where the springs are located was included as part of the Phase III bond release 

(TMI 1981 et seq.). Bond release has resulted in discontinuing monitoring at some CDPS outfall 

locations, including sites 003 (East Buzzard Gulch), 006 (West Buzzard Gulch), and 010 (Elk Gulch). 

These outfalls were removed from the Trapper Mine’s CDPS permit following Phase III bond releases. 

Flow measurements for the natural springs are available dating back to the 1990s. The spring flows vary 

depending on the time of year and the amount of precipitation that has fallen compared to historical 

averages. Coyote Spring is the only natural spring that appears to be perennial. Based on records dating 

back to 1992, flow rates at this spring have ranged from a low of 0.02 gallons per minute (gpm) in May 

2003 to a high of 16 gpm in May 1999. Flow rates at the other natural springs have ranged from a low of 

0 to highs of 130 gpm, 10 gpm, 25 gpm, and 11 gpm for East Pyeatt, Fox Den, North Horse Gulch, and 

Ute Gulch springs, respectively. At the spoil spring known as East Pyeatt South, flow rates have been 

measured semi-annually since 2005. During that time the lowest recorded flow was approximately 2 gpm 

in September 2006, and the highest recorded flow was 75 gpm in June 2011 (Hydro-Engineering 2015). 

From 1974 to 1977, baseline water quality samples were collected from surface water monitoring 

locations in the Project Area vicinity. Since most streams within the SMCRA permit boundary were not 

disturbed at the onset of mining, much of the water quality data from the late 1970s and early 1980s also 

reflects baseline conditions (TMI 1981 et seq.). Several of the baseline sampling locations were later 

converted to sampling points under TMI’s CDPS permit, including S1 (CDPS Site 020), S3 (CDPS 

Site 011), S5 (CDPS Site 002), and S11 (CDPS Site 005). The CDPS sampling locations are shown on 

Figure 3-3. 

Water quality data from TMI’s baseline monitoring program indicate that ephemeral streams in the 

SMCRA permit area generally have poorer water quality than the perennial streams they flow into. For 

example, at the USGS station on the Yampa River below Craig, the average total dissolved solids (TDS) 

concentration during the early 1980s was 202 milligrams per liter (mg/L). The average TDS 

concentration at the mouth of the Williams Fork was 261 mg/L during the same timeframe (Maura 1982). 

In contrast, baseline data from drainages within the mine permit boundary had average TDS values 

ranging from 1,180 mg/L at Middle Flume Gulch (CDPS Site 020) to 2,070 mg/L at East Pyeatt Gulch 

(CDPS Site 011). The TDS concentration was even higher at a downstream location on Flume Gulch, 

with an average value of 3,540 mg/L (TMI 1981 et seq.). These measurements are comparable to an 

independent water quality study conducted by the USGS, which found an average TDS downstream in 

Flume Gulch of 3,790 mg/L (Maura 1982). The difference in water quality between large perennial 

streams like the Yampa River and smaller ephemeral drainages is due to differences in flow volume and 

input sources for each type of stream. The perennial streams receive a much larger volume of low-TDS 

snowmelt runoff that effectively dilutes higher TDS inflows derived from smaller tributaries and 

groundwater discharge. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-24 
Chapter 3.0 – Affected Environment 

Figure 3-4 Streamflow at No Name Gulch 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-25 
 

Chapter 3.0 – Affected Environment 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-26 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

The segment of the Yampa River from Elkhead Creek to the Green River is listed on Colorado’s 

Section 303(d) list for iron impairment and on the State’s monitoring and evaluation list for sediment 

(CDPHE 2012). Ephemeral streams within the SMCRA permit boundary could contribute iron and 

sediment to this impaired segment. Baseline water quality monitoring performed between 1975 and 1977 

indicated that average iron concentrations in Flume Gulch, East Pyeatt Gulch, Johnson Gulch, and No 

Name Gulch were generally below the 1 mg/L water quality standard for the Yampa River (CDPHE 

2015). However, in several instances, individual sample results were greater than the standard. For 

example, an upstream sampling location on Flume Gulch (CDPS Site 020) had an average baseline iron 

concentration of 0.69 mg/L, but a maximum recorded concentration of 2.3 mg/L. Baseline iron 

concentrations were even higher downstream in Flume Gulch, with an average iron concentration of 

1.2 mg/L and a maximum value of 3.6 mg/L. Iron content was generally lower in East Pyeatt Gulch,
	

Johnson Gulch, and No Name Gulch, with average concentrations typically less than 0.25 mg/L 

(TMI 1981 et seq.). These data illustrate that the SMCRA permit area drainages were contributing 

relatively high iron concentrations to the Yampa River in their natural state before mining was initiated.
	

However, the iron loading from the area would still have been low given the small flow volumes
	

associated with these ephemeral streams.
	

Sediment is another constituent of interest for the SMCRA permit area based on Colorado’s monitoring 

and evaluation list (CDPHE 2012). Baseline monitoring data indicate that total suspended sediment 

(TSS) concentrations are highly variable for ephemeral drainages in the mine area. TSS results depend 

on the timing of sample collection relative to spring snowmelt and major rainfall events. Maximum TSS 

concentrations recorded during baseline monitoring ranged from 81 mg/L at No Name Gulch to 

230 mg/L at Flume Gulch (TMI 1981 et seq.). Water quality data collected from the Yampa River below 

Craig (USGS Station 09247600) around the same time as the baseline program exhibited TSS 

concentrations up to 418 mg/L (USGS 2015). 

Selenium also is a constituent of interest in the SMCRA permit area in part due to high selenium 

concentrations in the Mancos Shale (Environmental Sciences Laboratory 2011). During baseline 

monitoring, selenium was reported above the laboratory detection limit in Flume Gulch, East Pyeatt 

Gulch, Johnson Gulch, No Name Gulch, and Coyote Gulch. Reported concentrations ranged from 

0.005 to 0.02 mg/L (TMI 1981 et seq.). Water quality data collected from the Yampa River below Craig 

(USGS Station 09247600) between 1975 and 1980, with a total of 14 samples, showed that over half the 

selenium values were reported at less than the laboratory detection limit, with a maximum reported value 

of 0.002 mg/L (USGS 2015). The chronic aquatic life standard for selenium is 0.0046 mg/L 

(CDPHE 2015). 

In 2014, Trapper Mine began sampling for mercury at several of the mine CDPS outfall locations. 

Although the results have consistently been below detection limits, the sampling to date has not 

achieved a detection limit below the 0.01 microgram per liter (μg/L) mercury standard for the Yampa 

River (Hydro-Engineering 2015). 

3.5.2 Groundwater 

The Project Area is located in the Sand Wash Basin, a large east-west trending structural depression 

that underlies much of northwestern Colorado. The basin outline generally follows the outcrop of 

Cretaceous rocks. Locally, Cretaceous strata have been folded into a series of anticlines and synclines 

that influence groundwater occurrence, flow directions, and recharge and discharge areas. The Trapper 

Mine lies on the south limb of one of these features known as the Big Bottom syncline. Cretaceous strata 

in the Project Area dip to the north in the direction of the syncline axis. This means that geologic 

formations are younger immediately north of the mine, and increase in age to the south along the flanks 

of the Williams Fork Mountains. 

The principal bedrock formations in the Project Area are the Upper Cretaceous Lewis Shale and 

Williams Fork formations (Figure 3-5). The Lewis Shale consists of dark gray marine shale that ranges 

in thickness from 1,500 to 1,900 feet (457 to 579 meters) (Tweto 1976). The formation has low 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-27 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

permeability that restricts groundwater flow and, thus, is considered an aquitard. However, in the 

SMCRA permit area, the Lewis Shale has been known to produce some water, with well yields reported 

up to 5 gpm (TMI 1981 et seq.). The mine has one on-site monitoring well (P-3) installed in the Lewis 

Shale. Monitoring well locations at Trapper Mine are depicted on Figure 3-5. 

Beneath the Lewis Shale lies the Williams Fork Formation. The Williams Fork Formation has been 

hydrologically subdivided into four members: the upper member, Twentymile Sandstone member, middle 

member, and lower member (Robson and Stewart 1990). The upper member is transitional with the 

Lewis Shale and consists primarily of dark gray mudstones, siltstones, and shale interbedded with coal 

seams and sandstone units. It is underlain by the Twentymile Sandstone member, a white to light gray, 

moderately well sorted, fine- to very fine-grained quartz arenite. Beneath the Twentymile Sandstone, the 

middle and lower members of the Williams Fork Formation are composed of gray to black siltstone, silty 

fine-grained sandstone, and shale interbedded with coal seams. At Trapper Mine, the upper Williams 

Fork member and Twentymile Sandstone member are the primary bedrock aquifers monitored. The 

lower two members are not part of the monitoring program since they lie well below the depth of mining. 

The upper member of the Williams Fork Formation is approximately 500 feet (152.4 meters) thick in the 

Project Area (TMI 1981 et seq.). As a whole, the upper Williams Fork Formation acts as an aquitard; 

however, individual sandstones and coal seams within the unit have been shown to produce water. 

Trapper Mine has developed a detailed conceptual model to name and characterize these minor 

aquifers. From youngest to oldest, the minor aquifers include the Second White sandstone, Third White 

sandstone, “HI” aquifer, “KLM” aquifer, “QR” aquifer, and “U” aquifer. The hydraulic conductivity of these 

aquifers varies widely due to the lenticular geometry of the sandstones and the presence of intervening 

shale beds. In some areas, joints in the sandstone and coal strata provide a small amount of secondary 

porosity that increases the aquifer hydraulic conductivity. Average hydraulic conductivity values span 

orders of magnitude from about 10 feet per day in the Third White sandstone to less than 0.1 feet per 

day in the “QR” aquifer (TMI 1981 et seq.). Groundwater conditions are monitored within each of the 

minor aquifers as part of mine operations. 

The Twentymile Sandstone is a regional sandstone aquifer that was deposited in a beach and barrier bar 

environment. It extends from the base of the upper Williams Fork member to a depth of over 1,100 feet 

(335 meters) in the Project Area (TMI 1981 et seq.). The aquifer is likely in hydraulic connection with the 

upper Williams Fork, but is separated from lower units by a regional confining layer formed by the middle 

Williams Fork member (Robson and Stewart 1990). Trapper Mine has installed two production wells in 

the Twentymile Sandstone. The first of these wells produced a sustained yield of 75 gpm. Near the axis 

of the Big Bottom syncline, wells in the aquifer may produce as much as 500 gpm. A hydraulic 

conductivity value of 20 feet per day was derived for the Twentymile Sandstone based on an aquifer test 

conducted on monitoring well GF-1 in 1986 (TMI 1981 et seq.). 

Hydraulic heads and groundwater flow directions in the bedrock aquifers are strongly influenced by the 

structure of the Big Bottom syncline. Because of the orientation of the syncline, older strata crop out 

successively higher on the Williams Fork Mountains and receive recharge at higher elevations, allowing 

hydraulic potential to build up within the formations. As a result, the bedrock aquifers in the Project Area 

are typically confined except near the formation outcrops. Some deeper wells within the SMCRA permit 

area are even under artesian pressure with water levels rising above ground surface. The hydraulic 

potential created by the southerly recharge area results in a groundwater flow direction that is 

predominantly to the north (Hydro-Engineering 2015). Hydraulic gradients for the bedrock aquifers at the 

site range from approximately 0.07 to 0.14 feet/foot (TMI 1981 et seq.). 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-28 
Chapter 3.0 – Affected Environment 

Figure 3-5 Groundwater Resources 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-29 
 

Chapter 3.0 – Affected Environment 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-30 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Quaternary alluvium in the SMCRA permit area also is known to contain and transmit groundwater. 

Figure 3-5 shows the extent of alluvium associated with the Yampa River. In the mine area, the 

hydraulic conductivity of the Yampa River alluvium has been estimated at 160 feet per day, and well 

yields may range as high as 900 gpm (TMI 1981 et seq.). Johnson, Pyeatt, and Flume gulches also 

contain relatively extensive alluvial sediments, especially north of the mine permit area where the 

drainages approach the Yampa River. Hydraulic conductivity values for these smaller alluvial aquifers 

have been estimated to range from approximately two to 40 feet per day (TMI 1981 et seq.). 

Groundwater has been monitored in or near the SMCRA permit area since 1974. These early 

investigations were focused on establishing pre-mining baseline conditions for the western portion of the 

Project Area included in the SMCRA permit area. In 1985, baseline sampling was extended to 

encompass areas east of Pyeatt Gulch to obtain data for a mine expansion proposed in the 1987 permit 

renewal (RN01). The baseline program included measuring water levels and collecting groundwater 

samples from the Lewis Shale, upper Williams Fork member, Twentymile Sandstone member, and 

Quaternary alluvium. Some of the monitoring wells used during the baseline program continue to be 

sampled as part of the ongoing groundwater monitoring program in place at the site. The current mine 

groundwater monitoring network is depicted on Figure 3-5. 

Groundwater chemistry varies by geologic source, though most wells sampled during the initial baseline 

program exhibited a calcium-bicarbonate signature (TMI 1981 et seq.). TDS concentrations are generally 

higher in the Lewis Shale than in other water-bearing zones at the site because the formation contains 

more salt available for dissolution. The average baseline TDS concentration for the Lewis Shale was 

3,240 mg/L. Groundwater TDS concentrations above 1,000 mg/L are common in the Pyeatt Gulch and 

Flume Gulch alluvial aquifers, and contribute to the relatively high TDS associated with those streams. 

Within the upper Williams Fork member, TDS is highly variable depending on the aquifer interval being 

sampled; however, for the unit as a whole, the average baseline TDS was around 840 mg/L. Average 

TDS for the Twentymile Sandstone during the baseline program was approximately 570 mg/L (TMI 1981 

et seq.), making it one of the better drinking water aquifers in the area. 

The Trapper Mine PAP contains an inventory of water wells within one mile (1.6 km) of the SMCRA 

permit boundary (TMI 1981 et seq.). The inventory shows that the majority of wells are completed in the 

upper Williams Fork, the Twentymile Sandstone, or in deeper units. Most of the wells are used for 

domestic supply, but permits have been issued for irrigation, livestock, commercial, industrial, municipal, 

and monitoring purposes. According to state records, static water levels within these wells range from 0 

feet (artesian) to approximately 700 feet (213.4 meters) below ground surface (Colorado Division of 

Water Resources 2015). The permitted well locations are shown on Figure 3-5. 

3.6 Soils 

The geographical extent of the Project Area for soils includes the portions of Federal Coal Leases 

C-07519 and C-079641 that lie within the SMCRA permit boundary. Information on Major Land 

Resource Areas (MLRAs) and soil types was obtained from Natural Resources Conservation Service 

(NRCS) literature and databases, including the Land Resource Regions and Major Land Resource 

Areas of the U.S., the Caribbean, and the Pacific Basin, USDA Handbook 296 (USDA 2006) and the Soil 

Survey Geographic database (USDA 2015). 

A soil survey specific to the Project Area was completed for Moffat County by the USDA NRCS in 2005 

(USDA, NRCS 2005). The Order 3 soil survey data for this county forms the basis for the soils 

information presented in this section. Although the Moffat County soil survey is listed as an Order 3 in the 

vicinity of the coal producing areas, the soils were mapped as a high intensity Order 2 survey (Crofts 

2015). 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-31 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

The Project Area lies within three MLRAs: 

• MLRA 34A – Cool Central Desertic Basins and Plateaus 

• MLRA 34B – Warm Central Desertic Basins and Plateaus 

• MLRA 48A – Southern Rocky Mountains 

Soils in MLRA 34A are generally calcareous and shallow or moderately deep to sedimentary bedrock. 

The average annual precipitation is 7 to 12 inches (17.8 to 30.5 cm) and the freeze-free period ranges 

from 45 to 160 days. The dominant soil orders in this MLRA are Aridisols and Entisols. Elevations range 

from 5,200 to 7,500 feet (1,585 to 2,286 meters) amsl. 

Soils in MLRA 34B are generally calcareous and shallow or moderately deep to shale or sandstone 

bedrock. Soils at lower elevations likely have significant amounts of calcium carbonate, salts, and 

gypsum. The average annual precipitation is 13 to 15 inches (33 to 38 cm) and the freeze-free period 

ranges from 45 to 160 days. The dominant soil orders are Aridisols and Entisols with Mollisols at higher 

elevations. Elevations range from 4,100 to 7,500 feet (1,250 to 2,286 meters) amsl. 

Soils in MLRA 48A are deep soils that are well drained and generally form on mountain slopes. The 

average annual precipitation is 16 to 20 inches (40.6 to 50.8 cm) and the freeze-free period ranges from 

50 to 95 days. The dominant soil orders are Mollisols, Alfisols, Inceptisols, and Entisols. Elevations range 

from 6,500 to 14,400 feet (1,981 to 4,389 meters) amsl. 

Various soil types occur within the Project Area. The soil variability stems primarily from a variety of 

parent materials as influenced by topography, aspect, elevation, vegetation, and differential rates of 

mineral weathering. The soils formed from alluvium, colluvium, residuum, and eolian parent materials are 

primarily derived from sedimentary rocks. Shallow to moderately deep soils are common within the 

Project Area. Soil depths range from shallow on ridges and hillslopes to very deep in valley bottoms. 

The NRCS database identified 17 soil mapping units within the Project Area (Figure 3-6). These 17 soil 

types are listed in Table 3-11 with the associated acres and percent of this mapping unit within the 

Project Area. 

3.6.1 Moffat County Soil Mapping Units 

The Moffat County soil survey mapped the soils within Moffat County, Colorado. Moffat County mapping 

units are classified by the dominant soil type in the unit. The purpose of the Moffat County survey was to 

separate landscapes into landforms with similar use and management requirements (USDA, NRCS 

1989). Descriptions of the general characteristics for each soil mapping unit, the taxonomic classes, 

associated landforms, and typical vegetation found within the soil mapping units in Moffat County are 

described below. The detailed soil descriptions are typical descriptions for all of Moffat County and actual 

Project Area soils may show variation from the typical descriptions. 

3.6.1.1 Adderton Series 

Adderton soils are very deep, well drained soils formed in alluvium. These soils occur on alluvial fans 

and drainageways with an elevation range from 7,000 to 8,500 feet (2,134 to 2,591 meters) amsl. The 

mean temperature for these soil types ranges from 37 to 40°F, with 50 to 75 frost-free days. Annual 

precipitation ranges between 16 to 20 inches (40.6 to 50.8 cm). 

Adderton loam, 1 to 10 percent slopes occurs in approximately 4.5 percent of the Project Area. The soil 

profile is mainly loam with 0 to 22 inches loam, 22 to 39 inches loam, and 39 to 60 inches fine sandy 

loam. The soil composition is 90 percent Adderton and similar soils and 10 percent moderately well and 

somewhat poorly drained soils. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-32 
Chapter 3.0 – Affected Environment 

Figure 3-6 NRCS Soil Mapping Units 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-33 
 

Chapter 3.0 – Affected Environment 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-34 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-11 Soil Classifications within the Project Area 

Dominant Soil 

Type 

Mapping 

Unit No. Type Description 

Acres of 

Project 

Area 

Percent 

of 

Project 

Area 

Adderton 3 Adderton loam, 1 to 10% slopes 108.9 4.5 

Bulkley 22 Bulkley silty clay, 3 to 12% slopes 38.7 1.6 

Clayburn 33 Clayburn loam, warm, 3 to 25% slopes 205 8.5 

35 Clayburn-Youga moist complex, 15 to 45% slopes 12.50 0.5 

Cochetopa 37 Cochetopa loam, 12 to 25% slopes 110.8 4.6 

39 Cochetopa loam, warm, 3 to 12% slopes 30.2 1.2 

Foidel 72 Foidel loam, cool, 3 to 25% slopes 433 17.9 

73 Foidel loam, 25 to 65% slopes 103.5 4.3 

Hesperus 99 Hesperus fine sandy loam, dry, 2 to 15% slopes 7.2 0.3 

Lamphier 114 Lamphier fine sandy loam, 3 to 25% slopes 364.7 15.1 

115 Lamphier fine sandy loam, 25 to 65% slopes 114.5 4.7 

Rock Outcrops 160 Rock outcrop-Torriorthents complex, 50 to 75% slopes 15.3 0.6 

Rock River 163 Rock River sandy loam, 12 to 25% slopes 17.7 0.7 

Routt 166 Routt loam, 3 to 25% slopes 418.8 17.3 

Torriorthents 197 Torriorthents-Rock outcrop, sandstone complex, 25 to 

75% slopes 

0.6 <0.1 

Ustorthents 206 Ustorthents, frigid-Borolls complex, 25 to 75% slopes 260.1 10.7 

Winevada 213 Winevada-Splitro complex, 3 to 25% slopes 181.2 7.5 

Total 2,422.7 100.0 

This soil type is generally dominated by grasses with some shrubs. In Moffat County, potential native 

vegetation for this soil mapping unit and the typical rangeland composition include: basin wildrye 

(Leymus cinereus) at 35 percent, slender wheatgrass (Elymus trachycaulus) at 10 percent, western 

wheatgrass (Pascopyrum smithii) at 10 percent, Letterman’s needlegrass (Stipa lettermanii) at 5 percent, 

mountain big sagebrush (Artemisia tridentate vaseyana) at 5 percent, mountain brome (Bromus 

marginatus) at 5 percent, and mountain snowberry (Symphoricarpos oreophilus) at 5 percent. 

3.6.1.2 Bulkley Series 

Bulkley soils are very deep and well drained with fine texture formed from calcareous alluvium derived 

from shale. This soil series occurs on alluvial fans and clayey foothills within an elevation range of 

6,200 to 7,000 feet (1,890 to 2,134 meters) amsl. Mean annual temperature is between 42 and 45°F, 

with an average frost-free period of 75 to 95 days a year. Annual precipitation ranges between 13 to 

15 inches (33 to 38 cm). This soil type is best for livestock grazing and wildlife habitat. 

Bulkley silty clay, 3 to 12 percent slopes occurs in a small portion of the Project Area, approximately 

1.6 percent. This soil profile is 0 to 4 inches silty clay, 4 to 36 inches clay, and 36 to 60 inches silty clay. 

The soil composition is 80 percent Bulkley and similar soils, 10 percent Pricecreek type soils, and 

10 percent Abor soils. 

The vegetation cover is typically native grasses and sagebrush. In Moffat County, potential native 

vegetation for this soil mapping unit and the typical rangeland composition include: western wheatgrass 

at 40 percent, Wyoming big sagebrush (Artemisia tridentate wyomingensis) at 15 percent, bottlebrush 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-35 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

squirreltail (Elymus elymoides) at 5 percent, prairie Junegrass (Koeleria macrantha) at 5 percent, other 

perennial forbs at 5 percent, and other perennial grasses at 5 percent. 

3.6.1.3 Clayburn Series 

Clayburn soils are very deep, well drained mountain loam soils and consist of glacial drift, colluvium, and 

slope alluvium derived from sandstone and shale. Most soils in this series occur on plateaus, hills, and 

mountain slopes between elevations of 7,000 to 8,600 feet (2,134 to 2,621 meters) amsl. Mean 

temperature ranges from 37 to 40°F, with 50 to 75 frost-free days and annual precipitation between 18 to 

20 inches (45.7 to 50.8 cm) a year. This soil type generally supports livestock grazing and wildlife 

habitat. 

Clayburn loam, warm, 3 to 25 percent slope soils occur in approximately 8.5 percent of the Project Area. 

This soil profile is 0 to 11 inches loam, 11 to 46 inches clay loam, and 46 to 60 inches loam. Minor soil 

components are about 8 percent Routt type soils and 7 percent Jerry soil types. 

Native vegetation for this soil type includes grasses and sagebrush. In Moffat County, potential native 

vegetation for this soil mapping unit and the typical rangeland composition include: Letterman’s 

needlegrass at 15 percent, slender wheatgrass at 15 percent, mountain big sagebrush at 10 percent, 

Saskatoon serviceberry (Amelanchier alnfolia) at 5 percent, elk sedge (Carex geyeri) at 5 percent, 

mountain brome at 5 percent, mountain snowberry at 5 percent, nodding brome (Bromus anomalus) at 

5 percent, other perennial forbs at 5 percent, other perennial grasses at 5 percent, and other shrubs at 

5 percent. 

Clayburn-Youga, moist complex soils are composed of 45 percent Clayburn soils, 35 percent Youga 

soils, and small percentages of various other soil types. Clayburn-Youga soils occur in approximately 

0.5 percent of the Project Area. The Clayburn soil profile is typically 0 to 17 inches loam, 7 to 50 inches 

clay loam, and 50 to 60 inches sandy clay loam. The profile for Youga soils varies slightly from the 

Clayburn with 0 to 1 inch slightly decomposed plant material, 1 to 14 inches loam, 14 to 40 inches clay 

loam, and 40 to 60 inches sandy clay loam. Other soils include Cochetopa at 7 percent, Foidel at 

6 percent, and moderately deep soils over sandstone bedrock at 7 percent. 

Native vegetation for this soil type includes grasses and sagebrush. In Moffat County, potential native 

vegetation for this soil mapping unit and the typical rangeland composition include: Gambel’s oak at 

10 to 15 percent, Saskatoon serviceberry at 10 percent, mountain brome at 10 percent, Letterman’s 

needlegrass at 5 percent, elk sedge at 5 to 10 percent, mountain snowberry at 5 percent, nodding brome 

at 5 percent, slender wheatgrass at 5 percent, other perennial forbs at 5 percent, other perennial grasses 

at 5 percent, and other shrubs at 5 percent. 

3.6.1.4 Cochetopa Series 

Cochetopa soils are very deep, well drained mountain loam soils that are formed in colluvium and 

alluvium derived from sandstone and shale. These soils occur on mountain slopes, hills, and valley sides 

with an elevation range from 7,000 to 8,300 feet (2,134 to 2,530 meters) amsl. The mean temperature 

for these soil types ranges from 37 to 40°F, with 50 to 75 frost-free days. Annual precipitation ranges 

between 18 to 20 inches (45.7 to 50.8 cm). Cochetopa loam, 12 to 25 percent slopes and Cochetopa 

loam, warm, 3 to 12 percent slopes occur within the Project Area. Cochetopa loam, 12 to 25 percent 

slopes covers almost 5.8 percent of the Project Area. Both soil classes have a similar clay loam soil 

profile with 0 to 11 inches of loam, with the 11 to 19 inches, 19 to 48 inches, and 48 to 60 inches profiles 

all characterized as clay loam. The soil compositions are 85 percent Cochetopa and similar soils, 

approximately 8 percent Jerry soils, and 7 percent Routt type soils. 

This soil type supports livestock grazing and wildlife habitat, with big sagebrush, snowberry, and grasses 

dominating the vegetation type. In Moffat County, potential native vegetation for this soil mapping unit 

and the typical rangeland composition includes: slender wheatgrass at 15 percent, Letterman’s 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-36 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

neddlegrass at 10 percent, mountain big sagebrush at 10 percent, elk sedge at 5 percent, mountain 

brome at 5 percent, mountain snowberry at 5 percent, nodding brome at 5 percent, other perennial forbs 

at 5 percent, other perennial grasses at 5 percent, and other shrubs at 5 percent. 

3.6.1.5 Foidel Series 

The Foidel soils are very deep, well drained soils formed in loess and alluvium, colluvium, and residuum 

derived from sandstone and shale. These soils occur on mountain slopes, hills, and plateaus at 

elevations ranging from 7,000 to 8,400 feet (2,134 to 2,560 meters) amsl. The mean temperature for this 

soil type falls between 37 to 40°F, with 50 to 75 frost-free days. Annual precipitation ranges between 

18 to 20 inches (45.7 to 50.8). This soil type largely accommodates livestock grazing and wildlife habitat. 

Foidel soils support vegetation that is a mix of small shrubs and native grasses. 

Foidel loam, cool, 3 to 25 percent slopes and Foidel loam, 25 to 65 percent slopes cover approximately 

22.2 percent of the Project Area. These soil mapping units have a similar soil profile of 0 to 2 inches 

slightly decomposed plant material, 2 to 28 inches loam, 28 to 39 inches clay loam, and 39 to 60 inches 

clay loam. The soil composition for Foidel loam soils with slopes of 3 to 25 percent is 85 percent Foidel 

soils with the remaining 15 percent split between Winevada, Routt, Cochetopa, Clayburn, and coarse 

texture soils. Foidel, 25 to 65 percent slopes are 85 percent Foidel soils; 4 percent Skyway, Routt, and 

Clayburn soils; and 3 percent Lamphier soils. 

These soils support vegetation that is a mix of small shrubs and native grasses. In Moffat County, 

potential native vegetation for this soil mapping unit and the typical rangeland composition include: 

Gambel’s oak at 20 percent, Saskatoon serviceberry at 10 percent, mountain brome at 10 percent, 

Letterman’s needlegrass at 5 percent, common chokecherry (Prunus virginiana) at 5 percent, elk sedge 

at 5 percent, mountain snowberry at 5 percent, slender wheatgrass at 5 percent, other perennial forbs at 

5 percent, other perennial grasses at 5 percent, and other shrubs at 5 percent. 

3.6.1.6 Hesperus Series 

Hesperus soils are very deep, well to moderately well drained mountain loam soils and are formed from 

loess and alluvium derived from sandstone and shale. Most soils in this series occur in hills and plateaus 

between elevations of 6,500 to 7,000 feet (1,981 to 2,134 meters) amsl. Mean temperature ranges from 

40 to 43°F, with 65 to 85 frost-free days per year. Annual precipitation falls between 16 to 18 inches 

(40.6 to 45.7 cm). Hesperus fine sandy loam, dry, 2 to 15 percent slopes cover approximately 0.3 

percent of the Project Area with a soil profile of 0 to 5 inches fine sandy loam, 5 to 20 inches loam, 20 to 

52 inches clay loam, and 52 to 60 inches clay loam. Minor inclusions consist of approximately 8 percent 

Weed soil types and similar soils and 7 percent Pagoda soil types. 

This soil type generally supports grazing and wildlife habitat. Vegetation is likely to be grasses and 

sagebrush. In Moffat County, potential native vegetation for this soil mapping unit and the typical 

rangeland composition include: Letterman’s needlegrass at 15 percent, mountain big sagebrush at 

15 percent, slender wheatgrass at 10 percent, western wheatgrass at 10 percent, elk sedge at 5 percent, 

mountain brome at 5 percent, mountain snowberry at 5 percent, nodding brome at 5 percent, other 

perennial forbs at 5 percent, and other perennial grasses at 5 percent. 

3.6.1.7 Lamphier Series 

Lamphier soils are very deep, well-drained mountain loam soils formed in alluvium and colluvium from 

sandstone. These soils occur mostly on mountainsides. Elevations range between 7,000 to 8,600 feet 

(2,134 to 2,621 meters) amsl. Mean temperature ranges from 37 to 40°F, with 50 to 75 frost-free days 

and annual precipitation between 18 to 20 inches (45.7 to 50.8 cm) a year. 

Lamphier fine sandy loam, 3 to 25 percent slopes and Lamphier fine sandy loam, 25 to 65 percent 

slopes comprise approximately 19.8 percent of the Project Area. Lamphier soils have a profile 0 to 

2 inches moderately decomposed plant material, 2 to 24 inches fine sandy loam, and 24 to 60 inches 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-37 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

sandy clay loam. Minor soil components for 3 to 25 percent slopes include Foidel at 8 percent and 

Clayburn at 7 percent. Additional soil inclusions within the 25 to 65 percent slopes include Foidel, 

Clayburn, and Skyway at approximately 5 percent each. 

This soil type generally supports rangeland, and native grasses dominate the vegetation cover. In Moffat 

County, potential native vegetation for this soil mapping unit and the typical rangeland composition 

include: Gambel’s oak at 20 percent, Saskatoon serviceberry at 10 percent, elk sedge at 10 percent, 

mountain snowberry at 10 percent, Letterman’s needlegrass at 5 percent, mountain brome at 5 percent, 

nodding brome at 5 percent, slender wheatgrass at 5 percent, other perennial forbs at 5 percent, other 

perennial grasses at 5 percent, and other shrubs at 5 percent. 

3.6.1.8 Rock Outcrop-Torriorthents Series 

Rock outcrop-Torriorthents soils occur between 5,900 to 8,000 feet (1,798 to 2,438 meters) amsl, 

receiving annual precipitation between 9 to 16 inches (22.9 to 40.6 cm). Mean temperature falls between 

42 to 48°F, with 75 to 105 frost-free days. 

Rock outcrop-Torriorthents complex, 50 to 75 percent slopes occur over approximately 0.6 percent of the 

Project Area and are composed of 70 percent rock outcrop, 25 percent Torriorthents, and 5 percent deep 

soil types. The rock outcrops occur on hills and cliffs. Torriorthents soils are shallow and form on 

colluvium and residuum derived from sandstone and shale. This well drained soil type is found on 

mountainsides and hillslopes. Vegetation consists of grasses and small shrubs with a profile of 0 to 

2 inches channery sandy loam, 2 to 14 inches very channery sandy loam, and 14 to 18 inches 

unweathered bedrock. 

In Moffat County, potential native vegetation for this soil mapping unit and the typical rangeland 

composition include: Wyoming big sagebrush at 15 percent; Indian ricegrass (Achnatherum 

hymenoides) at 10 percent, Bottlebrush squirreltail at 10 percent, saltbush (Atriplex canescens) at 

10 percent, needle-and-thread grass (Hesperostipa comata) at 5 percent, and shadscale (Atriplex 

confertifolia) at 5 percent. 

3.6.1.9 Rock River Series 

Rock River soils are very deep and well drained soils formed in residuum derived from sandstone. This 

soil series occurs on shallow slopes within an elevation range of 6,500 to 6,800 feet (1,981 to 

2,073 meters) amsl. Mean annual temperature is between 42 and 45°F, with an average frost-free period 

of 75 to 95 days a year. Annual precipitation ranges between 11 to 13 inches (27.9 to 33 cm). Rock 

River sandy loam, 12 to 25 percent slopes, is found in approximately 0.7 percent of the Project Area. 

This soil profile is 0 to 3 inches sandy loam, 3 to 22 inches sandy clay loam, 22 to 32 inches sandy clay 

loam, and 32 to 60 inches sandy loam. The soil composition is 85 percent Rock River and similar soils, 

8 percent Forelle type soils, and 7 percent Berlake soils. 

The vegetation cover is typically native grasses and small shrubs. In Moffat County, potential native 

vegetation for this soil mapping unit and the typical rangeland composition include: Wyoming big 

sagebrush at 15 percent, needle and thread grass at 15 percent, Indian ricegrass at 10 percent, western 

wheatgrass at 10 percent, Nevada bluegrass (Poa secunda) at 5 percent, bottlebrush squirreltail at 

5 percent, and prairie junegrass at 5 percent. 

3.6.1.10 Routt Series 

Routt soils are very deep, well drained soils formed in loess and in residuum derived from shale. Most 

soils in this series occur on mountainsides and plateaus. Elevations range between 7,000 to 8,000 feet 

(2,134 to 2,438 meters) amsl. Mean temperature ranges from 37 to 40°F, with 50 to 70 frost-free days 

and annual precipitation between 18 to 20 inches (45.7 to 50.8 cm) a year. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-38 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Routt loam, 3 to 25 percent slopes comprises approximately 17.3 percent of the Project Area. Routt loam 

soils have a profile 0 to 2 inches slightly decomposed plant material, 2 to 27 inches loam, 27 to 33 inches 

clay loam, and 33 to 60 inches clay. Minor soil components consist of Foidel, Clayburn, Binco, and 

Cochetopa at 5 percent each. 

This soil type generally supports rangeland and wildlife habitat. Native grasses dominate the vegetation 

cover with large shrubs. In Moffat County, potential native vegetation for this soil mapping unit and the 

typical rangeland composition include: Gambel’s oak at 10 percent, Saskatoon serviceberry at 

10 percent, mountain brome at 10 percent, Letterman’s needlegrass at 5 percent, elk sedge at 5 percent, 

mountain snowberry at 5 percent, nodding brome at 5 percent, and slender wheatgrass at 5 percent. 

3.6.1.11 Torriorthents-Rock Outcrop Series 

Torriorthents-Rock outcrop soils occur at elevations between 6,000 and 11,280 feet (1,829 to 

3,438 meters) amsl. Mean annual precipitation is 9 to 16 inches (22.9 to 40.6 cm) and temperature is 

42 to 48°F, with approximately 75 to 105 frost-free days each year. 

Torriorthents-Rock outcrop, sandstone complex, 25 to 75 percent slopes occur over less than 

0.1 percent of the Project Area and are composed of 60 percent Torriorthents, 30 percent Rock outcrop, 

and 10 percent deep loamy soil types. For this series, Rock outcrop consists of sandstone and limestone 

ledges and exposed soft shale. The typical soil profiles for this soil mapping unit are described in Section 

3.6.1.8. 

The vegetation cover is typically native grasses and shrubs. In Moffat County, potential native vegetation 

for this soil mapping unit and the typical rangeland composition include: Indian ricegrass at 10 percent; 

Wyoming big sagebrush at 10 percent, bluebunch wheatgrass (Pseudoroegneria spicata) at 10 percent, 

western wheatgrass at 10 percent, antelope bitterbrush ( Purshia tridentate) at 5 percent, needle and 

thread grass at 5 percent, and mountain mahogany (Cercocarpus montanus) at 5 percent. 

3.6.1.12 Ustorthents, Frigid Borolls Series 

Ustorthents, frigid Borolls complex soils are shallow to moderately deep and well drained soils that are 

found on mountainsides and are formed from residuum and colluvium primarily derived from sedimentary 

rocks. Soils in this series occur mainly on mountainsides between 7,000 to 8,500 feet (2,134 to 

2,591 meters) amsl. Mean temperature ranges from 37 to 45°F, with 50 to 85 frost-free days and annual 

precipitation between 16 to 20 inches (40.6 to 50.8 cm) each year. 

Ustorthents, frigid-Borolls complex, 25 to 75 percent slopes cover approximately 10.7 percent of the 

Project Area. The soils within this complex consist of 55 percent Ustorthents, 35 percent Borolls, 

5 percent Abor, and 5 percent Rencot soils. The soil profile for Ustorthents is 0 to 3 inches very channery 

sandy loam, 3 to 28 inches extremely channery sandy loam, and 28 to 32 inches unweathered bedrock. 

Borolls soils have a profile of 0 to 19 inches loam, 19 to 30 inches cobbly sandy clay loam, and 30 to 

34 inches unweathered bedrock. 

This soil type generally supports rangeland where vegetation cover is a mixture of native grasses, 

shrubs, and small trees. In Moffat County, potential native vegetation for this soil mapping unit and the 

typical rangeland composition include: wheatgrass varieties at 10 to 20 percent, Indian ricegrass at 0 to 

10 percent, mountain big sagebrush at 10 percent, antelope bitterbrush at 0 to 5 percent, Nevada 

bluegrass at 0 to 5 percent, needle and thread grass at 0 to 5 percent, Saskatoon serviceberry at 5 to 

10 percent, Mountain mahogany at 0 to 5 percent, Columbia needlegrass (Achnatherum nelsonii) at 0 to 

10 percent, Gambel’s oak at 0 to 10 percent, elk sedge at 0 to 10 percent, Letterman’s needlegrass at 

0 to 10 percent, mountain brome at 0 to 10 percent, and mountain snowberry at 0 to 10 percent. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-39 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

3.6.1.13 Winevada-Splitro Series 

Winevada-Splitro complex soils are well drained, occur between 7,000 to 8,500 feet (2,134 to 

2,591 meters) amsl, and are generally found on mountainsides. Mean annual precipitation is between 

18 to 20 inches (45.7 to 50.8 cm). Mean temperature falls between 37 and 40°F, with 50 to 75 frost-free 

days. 

The Winevada-Splitro complex, 3 to 25 percent slopes occur in approximately 7.5 percent of the Project 

Area. The main soil compositions for this series are 60 percent Winevada soil types and 30 percent 

Splitro soils. Minor soils components include Skyway, Foidel, Lamphier, and Clayburn. Winevada soils 

are moderately deep and formed from residuum and colluvium derived from sandstone. These soils 

generally support livestock grazing and wildlife habitat. Vegetation for this series includes grasses and 

medium and large shrubs. The Winevada soil profile for the 3 to 25 percent slopes series is 0 to 

10 inches loam, 10 to 25 inches loam, and 26 to 29 inches unweathered bedrock. 

Splitro soils are shallow and formed in medium textured alluvium, residuum, and eolian material mainly 

from sandstone. Soils may be derived from basalt in some areas of Colorado. This soil type can support 

native pastureland and recreation, with vegetation dominated by grasses but can include ponderosa pine 

and quaking aspen. The Splitro soil profile has 0 to 1 inch slightly decomposed plant material, 1 to 

12 inches fine sandy loam, 12 to 14 inches fine sandy loam, and 14 to 17 inches unweathered bedrock. 

In Moffat County, potential native vegetation for this soil mapping unit and the typical rangeland 

composition include: Saskatoon serviceberry at 0 to 10 percent, mountain big sagebrush at 10 percent, 

mountain brome at 5 to 10 percent, nodding brome at 10 percent, slender wheatgrass at 10 percent, elk 

sedge at 5 percent, mountain snowberry at 5 percent, Letterman’s needlegrass at 0 to 5 percent, other 

perennial grasses at 10 to 15 percent, other perennial forbs at 5 percent, and other shrubs at 0 to 

5 percent. 

3.7 Vegetation 

Quantitative vegetation inventories at the Trapper Mine commenced in the early 1970s prior to the 

enactment of SMCRA. The studies detailed vegetation mapping using aerial photography, plant 

community descriptions, and intensive preparation of plant species lists. Intensive baseline sampling of 

the pre-disturbance plant communities commenced in 1979 and continued through 1985. Additional 

surveys have been conducted since then, including a sensitive species survey completed in 2013. 

Information on vegetation cover, forage production, and shrub density was taken from the results of 

vegetation surveys conducted by TMI and available in the TMI PAP. The plant communities with 

mappable acreages that occur in the Project Area are summarized in Table 3-12 and are depicted in 

Figure 3-7. In addition to the plant communities, the Project Area also includes disturbed areas and 

reclaimed lands as listed in Table 3-12. A discussion of each vegetation community follows. 

Table 3-12 Vegetation Communities 

Vegetation Community Type Acres Percent of Project Area 

Mountain Shrub 853 35.2 

Big Sagebrush Grass 23 0.9 

Reclaimed Rangeland 494 20.4 

Disturbed Area 1,053 43.5 

Totals 2,423 100.0 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-40 
Chapter 3.0 – Affected Environment 

Figure 3-7 Vegetation 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-41 
 

Chapter 3.0 – Affected Environment 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-42 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

3.7.1 Mountain Shrub Community 

The mountain shrub community is the predominant plant community in the Project Area, covering 

approximately 853 acres (35.2 percent of the Project Area). This is a common plant community in the 

Colorado Plateau ecoregion that is typically found along dry foothills and lower mountain slopes from 

5,000 to 9,000 feet (1,524 to 2,743 meters) amsl. In the Project Area, shrubs are the major lifeform, with 

grasses growing as a secondary component. Perennial forbs are less common. The most common 

shrubs in the Project Area include mountain snowberry, Gambel’s oak, and Saskatoon serviceberry, with 

black chokecherry representing a lesser component. Kentucky bluegrass (Poa pratensis) and smooth 

brome (Bromus inermis) are the most common grasses within the mountain shrub community in the 

Project Area. Overall, the mountain shrub community provides dense cover and provides palatable 

forage for domestic livestock and wildlife. 

3.7.2 Big Sagebrush-Grass Community 

The big sagebrush-grass community covers approximately 23 acres (0.9 percent of the Project Area). 

This plant community usually grows along flat rolling hills in well drained soils at elevations between 

7,000 to 10,000 feet (2,134 to 3,048 meters) amsl. In the Project Area, grasses are the major species in 

the big sagebrush-grass community, with shrubs forming a secondary component. Mountain big 

sagebrush is the most common species and typically forms about 25 percent of the plant cover within the 

big sagebrush-grass community in the Project Area. Other shrubs found in minor amounts in the Project 

Area include mountain snowberry, Saskatoon serviceberry, and black chokecherry. The dominant 

grasses within the big sagebrush-grass community in the Project Area include smooth brome, Kentucky 

bluegrass, western wheatgrass, and intermediate wheatgrass (Thinopyrum intermedium). The big 

sagebrush plant community provides forage and cover for a wide variety of wildlife and could support 

grazing for livestock. 

3.7.3 Reclaimed Rangeland 

Reclaimed rangeland occurs on areas previously disturbed by mining activities that have undergone final 

reclamation. Reclaimed rangeland occupies approximately 494 acres (20.4 percent) of the Project Area. 

These lands support a mixture of mostly native grasses, forbs, and shrubs planted from a seed mixture 

approved by the CDRMS. Reclaimed rangeland undergoes several years of revegetation monitoring to 

ensure that reclaimed areas are progressing toward the approved revegetation success standards. 

Some of these reclaimed areas have already met the Phase III reclamation standards and have been 

released from bonding. Reclaimed rangeland provides productive forage and cover for wildlife and 

domestic livestock. 

3.7.4 Disturbed Area 

Disturbed areas are not vegetation communities in the classical sense because these areas are typically 

void of plant cover. Disturbed areas are the active mine disturbance areas that are being used to support 

current mining operations and are not ready for final reclamation. Disturbed areas cover approximately 

1,053 acres (43.5 percent) of the Project Area. 

3.7.5 Noxious Weeds 

Noxious weeds are those plants that have been designated by the Colorado Noxious Weed Act as 

species that have been included on state or county lists and which, according to the CDRMS regulations 

and policies, must be controlled in all mining and reclamation areas. Section 35-5.5-103 (16), of the 

Colorado Noxious Weed Act defines a noxious weed as “an alien plant or parts of an alien plant that 

have been designated by rule as being noxious or has been declared a noxious weed by a local advisory 

board.” Under the Colorado Noxious Weed Act, the State maintains a “list of plant species that are 

designated as noxious weeds” that are included on one of three lists of regulated species: List A, List B, 

or List C. Plants in List A are designated for eradication in the state. Plants in List B are to be prevented 

from spreading by implementing weed management plans that have been developed in consultation with 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-43 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

the state, local governments, and other interested parties. List C plants are widespread and wellestablished noxious weed species for which weed control is recommended but not required by the state, 

although local governing bodies may require management. Moffat County does not maintain its own list 

of noxious weeds but has developed an Undesirable Plant Management Plan that is part of the County’s 

Land Use Plan of 2001 (Moffat County 2001). This plan outlines recommended steps to support federal, 

state, and local weed control activities but does not cite additional noxious weeds outside of the state list. 

The predominant noxious weeds relevant to Trapper Mine are those appearing in List C. 

Weed control measures are ongoing within the Project Area and are focused on reclaimed land and 

areas with known noxious weeds. Noxious weeds actively controlled within the Project Area include 

hoary cress (Cardaria draba), dalmatian toadflax (Linaria dalmatica), houndstongue (Cynoglossum 

officinale), Scotch thistle (Onopordum acanthium), musk thistle (Carduus nutans), Canada thistle 

(Cirsium arvense), and Russian knapweed (Acroptilon repens) (TMI 2015). Control measures include 

application of selective and non-selective broadleaf herbicides where noxious weeds are found. Noxious 

weeds often consist of small localized patches or are interspersed with other plants to such a degree that 

it is extremely difficult to map these areas as a separate vegetation type. 

Not all noxious weeds are List A and List B species that are required to be actively controlled within the 

Project Area. List C noxious weeds such as cheatgrass (Bromus tectorum) are prevalent throughout the 

region and are managed at Trapper Mine through management of revegetation efforts rather than 

through control with herbicides. Noxious weeds typically represent a very small part of the total plant 

cover in the Project Area. As recommended in the CDRMS’s Bond Release Guidance, the cover and 

production contribution for all state listed noxious weeds is deleted prior to the calculation of the final 

plant cover and forage production amounts on all reclaimed lands (CDRMS 1995). 

3.8 Wetlands and Riparian Zones 

Wetlands and riparian environments play an important role in the general health of various ecosystems, 

supporting diverse biota, filtering pollutants, and storing flood waters. Wetland delineation surveys and 

surveys to identify any waters of the U.S. (WOTUS) within the SMCRA permit boundary were conducted 

by IME Consulting (IME) in 1998 and 2008. 

Pursuant to CWA regulations, the U.S. Army Corps of Engineers (USACE) has regulatory authority over 

disturbances to all jurisdictional WOTUS (which include wetlands). 

WOTUS include all interstate waters (traditional navigable waters) and wetlands. Other WOTUS include 

channels and wetlands that connect directly, or through a significant nexus, to traditional navigable 

waters. Any water connected through a significant nexus is evaluated and approved by the USACE. 

These waters are evaluated to ensure that impacts to wetlands and streams connected to traditional 

navigable waters do not have downstream impact on the general health of the permitted waters. 

Possible impacts include reduction in flow, pollutant runoff, and impacts to biota. Not all interstate 

wetlands are WOTUS. Wetlands within the Project Area are all jurisdictional and considered WOTUS. 

3.8.1 Wetlands 

Wetlands are evaluated based on the presence of three main criteria: hydrophytic vegetation, hydric 

soils, and hydrology. When all three indicators are present, the USACE categorizes a wetland as 

jurisdictional. Wetlands within the Project Area were evaluated in accordance with the USACE Wetlands 

Delineation Manual (USACE 1987), and the Regional Supplement to the Corps of Engineers Wetland 

Delineation Manual: Western Mountains, Valleys, and Coast Region (USACE 2010). 

In 1998, IME performed field surveys within the Project Area. Most of the wetlands identified within the 

Project Area occur along incised channels and are determined jurisdictional based on presence of the 

three defining criteria (i.e., hydrophytic vegetation, hydric soils, and hydrology). These ephemeral stream 

channels are seasonally inundated and supported by runoff from surrounding topography and 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-44 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

considered isolated where they occur. Additionally, isolated spring-fed wetlands occur within the Project 

Area, with most of those identified being less than 0.10 acre in size. These isolated wetlands met all 

three criteria from the USACE. A total of 1.55 acres of jurisdictional wetlands and 0.33 acre of ponds 

were delineated within the Project Area in the 1998 survey; 0.399 acre of those were approved to be 

affected by mining activities (IME 1998). Dominant wetland vegetation includes: spreading bentgrass 

(Agrostis stolonifera), Nebraska sedge (Carex nebrascensis), clustered field sedge (C. praegracilis), and 

curly dock (Rumex crispus). 

Flume Gulch has been identified as the only drainage with incised channels within the Project Area. This 

series of drainages includes several smaller drainages that flow into the main Flume Gulch channel, lie 

on the northeastern portion of the Project Area, and flow north out of the Project Area along County 

Road (CR) 35 toward the Yampa River. Portions of Deacon Gulch occur on the eastern edge of the 

Project Area and will not be impacted by mining activities. The National Wetlands Inventory shows 

wetlands within the Project Area but most are outside of the disturbance area (National Wetland 

Inventory 2015). On October 2, 1998, the USACE issued Trapper Mine a Nationwide Permit 21, Surface 

Coal Mining Activities, which encompassed the Project Area and the associated mining activities. 

3.8.2 Riparian Areas 

Riparian areas are generally defined as the vegetated transitional zones that lie between aquatic and 

terrestrial (upland) environments. Riparian areas usually occur as belts along streams, rivers, lakes, 

marshes, bogs, and other waterbodies. As a transitional zone between aquatic and upland 

environments, riparian systems often exhibit characteristics of both. Generally, only perennial and 

intermittent streams can support riparian areas that serve the entire suite of riparian ecological functions. 

The Project Area lies mostly above 7,000 feet (2,134 meters) amsl with no perennial or intermittent 

streams. Ephemeral streams rarely possess the hydrologic conditions that allow true riparian vegetation 

to grow. There are no riparian areas mapped within the Project Area. 

3.9 Fish and Wildlife Resources 

3.9.1 Regulatory Background 

Laws, regulations, and policies that directly influence wildlife management decisions made as part of the 

EA for the Trapper Mine are primarily implemented by the USFWS and CPW. Prominent laws, 

regulations, directives, and agreements relevant to the fish and wildlife resources within the Project Area 

include: 

• CRS 33-1-101, 33-2-104; 

• ESA; 

• Migratory Bird Treaty Act (MBTA) (16 United States Code [USC] 703 et seq.); 

• EO 13186 (66 FR 3853); 

• CRS 33-2-105; and 

• Bald and Golden Eagle Protection Act (BGEPA) (16 USC, 668 et seq.). 

Information regarding wildlife species and their habitats within the Project Area was obtained from a 

review of the Trapper Mine PAP, published sources, public database information, BLM RMPs, CPW 

resource information, and USFWS data and documents. 

3.9.2 Analysis Areas 

Analysis areas for terrestrial and wildlife species were chosen to represent the combination of 

geographic areas containing contiguous habitat that would be impacted by the Proposed Action, as well 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-45 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

as the management regimes to which this habitat is subject. The analysis areas for terrestrial wildlife 

species are defined as follows: 

•	 Big Game Analysis Area: The big game analysis area consists of the Data Analysis Units 

(DAUs) and Game Management Units (GMUs) that are crossed by the Project Area. The Project 

Area boundary is within GMU 13. Sensitive habitat is typically considered a limiting factor for big 

game populations; therefore, the analysis focuses on these areas (e.g., winter range, migratory 

corridors, production areas, and summer range) within the DAUs for each species and GMU 13. 

DAU plans provide specific information including herd dynamics and population trends, habitat 

utilized by the herd, and current land use within the DAU. 

•	 Nongame and Small Game Terrestrial Wildlife Analysis Area: The terrestrial wildlife analysis 

area for small game species and nongame species, including raptors and other migratory birds, 

includes suitable habitat within the Project Area. 

The wildlife habitat located within the Project Area is predominately composed of the mountain shrub 

vegetation community and reclaimed rangelands. Other habitat types include sagebrush shrubland and 

grasslands. 

The region supports a diverse terrestrial wildlife community of large and small mammals, migratory birds, 

and reptiles. Occurrence and density of wildlife species within the region are dependent upon a variety of 

factors including the size and mobility of the animal, food habits, water, existing and ongoing 

development, and overall habitat carrying capacities (Prior Magee et al. 2007). All wildlife species 

present in the analysis areas are important members of a functioning ecosystem and wildlife community, 

but most are common and have wide distributions in the region. 

3.9.3 Nongame Species 

The Nongame and Small Game Terrestrial Wildlife Analysis Area supports many types of nongame 

species (e.g., small mammals, raptors, passerines, and reptiles) occupying the habitat types within the 

Project Area. Nongame species serve as predators, prey, and scavengers in ecosystems. 

3.9.3.1 Small Mammals 

Within the Project Area, bat species could use trees, caves, and rock crevices as day and maternal roost 

sites, as well as hibernacula. No bat surveys have been conducted within the Project Area. However, bat 

species with the potential to occur within the wildlife analysis area include the little brown bat (Myotis 

lucifugus), long-eared myotis (Myotis evotis), western small-footed myotis (Myotis ciliolabrum), silverhaired bat (Lasionycteris noctivagans), big brown bat (Eptesicus fuscus), hoary bat (Lasiurus cinereus), 

and pallid bat (Antrozous pallidus) (TMI 1981 et seq.). 

Other common small mammals occurring within the terrestrial wildlife analysis area include voles, 

shrews, chipmunks, pocket gophers, raccoons, woodrats, ground squirrels, mice, and other species that 

provide a substantial prey base for predators within the Project Area including larger mammals and 

raptors (TMI 1981 et seq.). Common small mammals that are known to occur within the Project Area 

include the masked shrew (Sorex cinereus), vagrant shrew (Sorex vagrans), Nuttall’s cottontail 

(Sylvilagus nuttallii), white-tailed jackrabbit (Lepus townsendii), least chipmunk (Tamias minimus), 

yellow-bellied marmot (Marmota flaviventris), Richardson’s ground squirrel (Urocitellus richardsonii), 

golden-mantled ground squirrel (Callospermophilus lateralis), northern pocket gopher (Thomomys 

talpoides), deer mouse (Peromyscus maniculatus), bushy-tailed wood rat (Neotoma cinerea), redbacked vole (Myodes gapperi), long-tailed vole (Microtus longicaudus), porcupine (Erethizon dorsatum), 

coyote (Canis latrans), red fox (Vulpes vulpes), raccoon (Procyon lotor), long-tailed weasel (Mustela 

frenata), American badger (Taxidea taxus), striped skunk (Mephitis mephitis), and bobcat (Lynx rufus) 

(TMI 1981 et seq.). 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-46 
 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

3.9.3.2 Migratory Birds 

The MBTA provides federal legal protection from human depredation for more than 1,000 bird species 

(16 USC 703-712). In addition to the MBTA, bald and golden eagles are protected under the BGEPA 

(16 USC 668 et seq.). The majority of birds found within the Project Area and vicinity are considered 

migratory under the MBTA. These birds are primarily summer residents in the region. Many of the 

summer residents are neotropical migrants that winter in Central and South America. Many bird species 

are more vulnerable to disturbance during the breeding season when human disturbances can 

compromise successful reproduction. The timing and duration of the breeding season is species-specific 

and may vary according to latitude, elevation, and climatic conditions. Table 3-13 provides a list of 

migratory birds known to occur or with the potential to occur within the Project Area and surrounding 

region. 

Table 3-13	 Migratory Birds Known to Occur and with the Potential to Occur in the Vicinity 

of the Project Area 

Red-winged blackbird (Agelaius 

phoeniceus) 

Brewer’s blackbird (Euphagus 

cyanocephalus) 

Mountain bluebird (Sialia 

currucoides) 

Lazuli bunting (Passerina amoena) Bushtit (Psaltriparus minimus) Black-capped chickadee (Poecile 

atricapillus) 

Gray catbird (Dumetella 

carolinensis) 

Brown-headed cowbird (Molothrus 

ater) 

Sandhill crane (Grus canadensis) 

American crow (Corvus 

brachyrhynchos) 

Mourning dove (Zenaida macroura) Gadwall (Anas strepera) 

Mallard (Anas platyrhynchos) Pintail (Anas acuta) Blue-winged teal (Anas discors) 

Cinnamon teal (Anas cyanoptera) Green-winged teal (Anas crecca) Northern shoveler (Anas clypeata) 

American wigeon (Anas 

americana) 

Bald eagle (Haliaeetus 

leucocephalus) 

Golden eagle (Aquila chrysaetos) 

American kestrel (Falco sparverius) Prairie falcon (Falco mexicanus) House finch (Haemorhous 

mexicanus) 

Northern flicker (Colaptes auratus) Dusky flycatcher (Empidonax 

oberholseri) 

Blue-gray gnatcatcher (Polioptila 

caerulea) 

American goldfinch (Spinus tristis) Lesser goldfinch (Spinus psaltria) Canada goose (Branta canadensis) 

Black-headed grosbeak 

(Pheucticus melanocephalus) 

Cooper’s hawk (Accipter cooperii) Ferruginous hawk (Buteo regalis) 

Red-tailed hawk (Buteo 

jamaicensis) 

Rough-legged hawk (Buteo lagopus) Sharp-shinned hawk (Accipter 

striatus) 

Swainson’s hawk (Buteo 

swainsoni) 

Great blue heron (Ardea herodias) Black-chinned hummingbird 

(Archilochus alexandri) 

Broad-tailed hummingbird 

(Selasphorus platycercus) 

Western scrub- jay (Aphelocoma 

californica) 

Steller’s jay (Cyanocitta stelleri) 

Dark-eyed junco (Junco hyemalis) Killdeer (Charadrius vociferous) Western kingbird (Tyrannus 

verticalis) 

Ruby-crowned kinglet (Regulus 

calendula) 

Horned lark (Eremophila alpestris) Black-billed magpie (Pica 

hudsonia) 

Western meadowlark (Sturnella 

neglecta) 

Common nighthawk (Chordeiles 

minor) 

Bullock’s oriole (Iceterus bullockii) 

Great-horned owl (Bubo 

virginianus) 

Long-eared owl (Asio otus) Say’s phoebe (Sayornis saya) 

American pipit (Anthus rubescens) Common poor-will (Phalaenoptilus 

nuttallii) 

Common raven (Corvus corax) 

American robin (Turdus 

migratorius) 

Red-naped sapsucker (Sphyrapicus 

nuchalis) 

Loggerhead shrike (Lanius 

ludovicianus) 

Northern shrike (Lanius excubitor) Pine siskin (Spinus pinus) Wilson’s snipe (Gallinago delicata) 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-47 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-13 Migratory Birds Known to Occur and with the Potential to Occur in the Vicinity 

of the Project Area 

Brewer’s sparrow (Spizella breweri) Barn swallow (Hirundo rustica) Chipping sparrow (Spizella 

passerina) 

Lark sparrow (Chondestes 

grammacus) 

Song sparrow (Melospiza melodia) Vesper sparrow (Pooecetes 

gramineus) 

White-crowned sparrow 

(Zonotrichia leucophrys) 

Cliff swallow (Petrochelidon 

pyrrhonota) 

Tree swallow (Tachycineta bicolor) 

Violet-green swallow (Tachycineta 

thalassina) 

White-throated swift (Aeronautes 

saxatalis) 

Western tanager (Piranga 

ludoviciana) 

Sage thrasher (Oreoscoptes 

montanus) 

Green-tailed towhee (Pipilo 

chlorurus) 

Spotted towhee (Pipilo maculatus) 

Plumbeous vireo (Vireo plumbeus) Warbling vireo (Vireo gilvus) MacGillivray’s warbler (Geothlypis 

tolmiei) 

Orange-crowned warbler 

(Oreothlypis celata) 

Virginia’s warbler (Vermivora 

virginiae) 

Wilson’s warbler (Cardelina pusilla) 

Yellow warbler (Setophaga 

petechia) 

Yellow-rumped warbler (Setophaga 

coronata) 

Cedar waxwing (Bombycilla 

cedrorum) 

Downy woodpecker (Picoides 

pubescens) 

Hairy woodpecker (Picoides villosus) Western wood-pewee (Contopus 

sordidulus) 

House wren (Troglodytes aedon) Rock wren (Salpinctes obsoletus) 

Raptors 

Raptors are protected under state and federal laws including the MBTA, and bald and golden eagle are 

protected under the BGEPA. A variety of raptor habitats are found within and adjacent to the Project 

Area, from lower elevation grassland and shrublands to montane shrublands and forests. As a result, 

there are a variety of raptor species likely to hunt or breed in the area including: red-tailed hawk, longeared owl, great-horned owl, turkey vulture (Cathartes aura), golden eagle, bald eagle, ferruginous 

hawk, prairie falcon, Cooper's hawk, rough-legged hawk, American kestrel, sharp-shinned hawk, and 

Swainson's hawk (TMI 1981 et seq.). 

Surveys were conducted between 2001 and 2015 to identify the status of a historic prairie falcon nest 

site at the southeast corner of Trapper Mine’s SMCRA permit boundary near the Hamill property. The 

surveys did observe active prairie falcon and golden eagle nests within the vicinity of the Project Area 

(TMI 1981 et seq.). 

3.9.3.3 Reptiles and Amphibians 

Most reptiles occur in lower elevations and in drier habitats such as sagebrush, greasewood, and 

pinyon-juniper vegetation communities. Common reptile species that have been noted in the Project 

Area include the greater short-horned lizard (Phrynosoma hernandesi), Great Basin gopher snake 

(Pituophis melanoleucus deserticola), wandering garter snake (Thamnophis elegans vagrans), and 

prairie rattlesnake (Crotalus viridis viridis) (TMI 1981 et seq.). 

Native amphibians that could potentially occur in the Project Area include the chorus frog (Pseudacris 

triseriata), tiger salamander (Ambystoma tigrinum), and northern leopard frog (Lithobates pipiens).The 

chorus frog and tiger salamander are not managed by CPW. The northern leopard frog is a species 

receiving more interest by CPW as a species in need of conservation. Northern leopard frogs are the 

only potentially occurring species known to inhabit ponds and other suitable habitats within the SMCRA 

permit boundary, but the species has not been documented in the Project Area (TMI 2015). 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-48 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

3.9.4 Game Species 

3.9.4.1 Big Game 

As described above, the analysis area for big game species includes CPW-designated big game ranges 

(e.g., overall range, severe winter range, production range, etc.) within the GMU 13 that overlaps with 

the Project Area. In Colorado, big game is managed by CPW within specific geographic areas within 

herd areas, or GMUs, based on objectives set within a herd management plan, also known as a DAU. 

Herds are capable of using multiple or single GMUs (CPW 2015-2016). The DAU represents the yearround range of a big game herd and includes all of the seasonal ranges of a specific herd. The purpose 

of a DAU plan is to integrate the plans and intentions of CPW with the concerns and ideas of land 

management agencies and the interested public to determine how a big game herd in a DAU should be 

managed (CPW 2015a). This analysis area provides the context for Project impacts and cumulative 

impacts involving the habitat specifically managed for big game populations. This is further referred to as 

the big game analysis area through the remainder of this section. 

The big game species whose overall range overlap with the Project Area include mule deer (Odocoileus 

hemionus), elk (Cervus canadensis), moose (Alces alces), black bear (Ursus americanus), and mountain 

lion (Puma concolor). The Project Area does not overlap with the overall range for pronghorn 

(Antilocapra americana) (CPW 2014a). The Project Area does occur within DAU A-9 for pronghorn and 

pronghorns are known to occur within the Project Area. In 2014, this DAU had an estimated population 

of 12,370 individuals, and in 2004 there was an estimated population of 16,200. This is approximately 

17 percent of the statewide population (CPW 2015b). 

Mule Deer 

Within the region, mule deer use a variety of vegetation communities that provide year-round suitable 

habitat. These vegetation communities include aspen forests and woodlands, conifer forests, 

shrublands, and pinyon-juniper woodlands. The White River deer herd is the largest mule deer herd in 

Colorado. The total herd population was estimated to be 71,380 in 2007 and 37,530 in 2014. The herd 

population exhibited an increasing trend from 2001 to 2005. The decrease between 2007 and 2014 may 

be due to a series of severe winters and droughts, which affected the area (CPW 2015b). 

The entire Project Area is within the overall winter and summer range of the White River deer herd 

(DAU D-7) (Figure 3-8). CPW (2012a) defines summer range as that part of the overall range where 

90 percent of the individuals are located between spring green-up and the first heavy snowfall. The 

northern two-thirds of the Project Area falls within winter range for mule deer. Winter range is that part of 

the range where 90 percent of the animals are located during average winters. Winter habitat for mule 

deer occurs in areas of relatively high amounts of sagebrush and bitterbrush and overall low snow 

accumulation – typically on south- and west-facing slopes. 

Elk 

In Colorado, elk are distributed across the western two-thirds of the state, generally at elevations above 

6,000 feet (1,829 meters) amsl (Armstrong et al. 2011). Elk are typically found in forested habitats, 

although in northwestern Colorado elk are found in large herds during the winter months in open 

sagebrush shrublands and grasslands (CPW 2012b). Winter habitat for elk typically consists of low 

elevation rolling hills, meadows, and agricultural fields. However, unlike mule deer, elk are not as 

susceptible to harsh winter conditions due to their nutritional requirements and large body size, and often 

remain at higher elevations longer. Spring and fall migrations are facultative and are tied to weather and 

forage quality. Upland meadow and mountain shrub habitats provide the highest-quality forage areas for 

elk within the big game analysis area. 

Elk within the Project Area are part of the White River herd (DAU E-6) as defined by CPW. The 

population of the White River elk herd has grown steadily since the early 1980s, and CPW has been 

attempting to reduce the herd size to maintain it within the management goal of 32,000 to 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-49 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

39,000 animals (CPW 2015b). In 2007, the herd was estimated to be 43,870 animals. In 2014, the total 

herd population was estimated at 39,900, and represents the largest elk herd in Colorado (CPW 2015b). 

Elk seasonal ranges that overlap with the Project Area are shown on Figure 3-9. Figure 3-10 shows elk 

resident population and production areas that overlap with the Project Area. CPW data indicate that the 

entire Project Area is located within designated winter and summer ranges, as well as a production area 

for elk. Portions of the Project Area are located within migration corridors, a resident population area, 

severe winter range, and a winter concentration area. 

The CPW defines these ranges and production areas as follows: 

•	 Migration corridors are a specific site through which large numbers of animals migrate; loss of 

which would change migration routes. 

•	 Production areas are that part of the overall range occupied by the females from May 15 to 

June 15 for calving. 

•	 A resident population area is an area used year-round by a population of elk. Individuals could 

be found in any part of the area at any time of the year; the area cannot be subdivided into 

seasonal ranges. It is most likely included within the overall range of the larger population. 

•	 Summer range is that part of the range of a species where 90 percent of the individuals are 

located between spring green-up and the first heavy snowfall, or during a site specific period of 

summer as defined for each DAU. Summer range is not necessarily exclusive of winter range; in 

some areas winter range and summer range may overlap. 

•	 Winter range is that part of the overall range of elk where 90 percent of the individuals are 

located during the average five winters out of 10 from the first heavy snowfall to spring green-up, 

or during a site-specific period of winter as defined for each DAU. 

•	 Winter concentration areas include that part of the winter range where densities are at least 

200 percent greater than the surrounding winter range density during the average five winters 

out of six from the first heavy snowfall to spring green-up, or during a site-specific period of 

winter as defined for each DAU. 

•	 Severe winter range represents that part of the overall range of elk where 90 percent of the 

individuals are located when the annual snowpack is at its maximum and/or temperatures are at 

a minimum in the two worst winters out of 10. 

Moose 

Moose are not common within the big game analysis area. Until 1978 when moose were reintroduced to 

North Park from Utah and Wyoming, moose were not breeding in Colorado and were only considered 

infrequent migrants into the state (CPW 2014b). From 2005 to 2007, moose were reintroduced to the 

Grand Mesa (CPW 2014c). Typically, this species is found in forested areas, primarily along riparian 

areas with abundant willow habitat. Typically, moose are not as susceptible to severe winter conditions 

as other big game animals due to their large body size and adaptions that allow them to forage in deep 

snow and survive in colder climates. 

The Project Area boundary does not occur within any moose DAUs, but moose overall range and 

summer range are within the Project Area. According to CPW, moose summer range is defined as that 

part of the overall range where 90 percent of the individuals are located during the summer months. This 

summer time frame will be delineated with specific start/end dates for each moose population within the 

state (e.g., May 1 to September 15). Summer range is not necessarily exclusive of winter range. Moose 

ranges in and near the Project Area are shown in Figure 3-11. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-50 
 

Chapter 3.0 – Affected Environment 

Figure 3-8 Mule Deer Winter Ranges 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-51 
Chapter 3.0 – Affected Environment 

Figure 3-9 Elk Ranges 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-52 
Chapter 3.0 – Affected Environment 

Figure 3-10 Elk Population and Production Areas 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-53 
Chapter 3.0 – Affected Environment 

Figure 3-11 Moose Ranges 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-54 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Black Bear and Mountain Lion 

Black bear are fairly common within the big game analysis area. The species is especially common in 

forested, woody riparian, and wetland areas along perennial waterbodies (Armstrong et al. 2011). Black 

bears usually occur at low densities in similar habitats within the region, and their presence or absence is 

highly dependent on existing disturbance and available food sources. The Project Area falls within 

DAU B-10. Fall concentration areas and summer concentration areas overlap with the Project Area 

(Figure 3-12). Fall concentration areas are that portion of the overall range occupied from August 15 

until September 30 for the purpose of ingesting large quantities of mast and berries to establish fat 

reserves for the winter hibernation period. Summer concentration areas are that portion of the overall 

range of the species where activity is greater than the surrounding overall range from June 15 to 

August 15 (CPW 2012b). 

Similar to black bear, mountain lions are fairly common in the region. Mountain lions generally occur at 

low densities in a variety of habitats found within the big game analysis area and their distribution is 

dependent on available food sources, primarily mule deer. The Project Area falls within the range of 

DAU-L7 for mountain lion. 

3.9.4.1 Small Game Species 

Small game species that occur within the region include furbearers, upland game birds, and waterfowl. 

Potential habitat for small game species (except waterfowl) within the Project Area includes all of the 

plant communities that occur there. Potential habitat for waterfowl within the wildlife analysis area is 

limited to sediment ponds within the Project Area. 

Furbearers 

Furbearers likely to occur within the wildlife analysis area include cottontail (Sylvilagus spp.), black-tailed 

jackrabbit (Lepus californicus), Richardson’s ground squirrel, ring-tail (Bassariscus astutus), raccoon 

(Procyon lotor), striped skunk , long-tailed weasel , American badger , bobcat , coyote , and red fox 

(CPW 2012b). These species have wide distributions and are found within a variety of habitat types in 

the greater region (e.g., sagebrush shrubland, desert shrub, pinyon-juniper, montane shrubland, 

grassland, etc.). The distribution of furbearers within the wildlife analysis area is typically determined by 

available food sources and suitable cover sites for burrows or dens. 

Upland Game Birds 

Upland game bird species that occur within the wildlife analysis area include Columbian sharp-tailed 

grouse (Tympanuchus phasianellus columbianus), dusky grouse (Dendragapus obscurus), and 

mourning dove. The Columbian sharp-tailed grouse is discussed under Special Status Species, 

Section 3.10. Mourning doves occur in habitats ranging from deciduous forests to shrubland and 

grassland communities, often nesting in trees or shrubs near riparian areas or water sources (Stokes 

and Stokes 1996). Most upland game bird species feed on a wide variety of plant and insect species 

depending on the time of year (i.e., insects during the spring and summer and leaves and seeds during 

the fall and winter). Many of the species described above exhibit annual population fluctuations 

depending on habitat conditions and weather patterns. 

Waterfowl 

The Project Area is located within the Pacific Flyway. Common waterfowl species that have been 

reported to occur in the region or that may occur in the Project Area include Canada goose, mallard, 

green-winged teal, pintail, gadwall, American wigeon, and common goldeneye (Bucephala clangula). 

Other common summer residents include blue-winged teal, northern shoveler, redhead (Aythya 

americana), and lesser scaup (Anas affinis) (Cerovski et al. 2004; Kingery 1998; Stokes and Stokes 

1996). 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-55 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

These species distributions are limited to the rivers, streams, lakes, reservoirs, ponds, and wetlands 

found within the greater region. These habitats are absent from the Project Area with the exception of 

water impounded at sediment ponds. Population numbers for these species vary annually based on 

available food and weather patterns. While waterfowl species are considered game birds, they also are 

protected under the MBTA. 

3.9.5 Fish 

The Project Area for aquatic biological resources includes streams located within the mine boundary 

(Figure 2-1). In addition, a downstream section of the Yampa River is considered part of the regional 

effects area and deposition effects and water use are analyzed for that area. The affected environment 

description for aquatic biological resources focuses on perennial streams, which support fish species. 

Aquatic habitat within the mine boundary of the Project Area consists of only ephemeral streams. There 

are no intermittent or perennial streams within the mine boundary area. Ephemeral (short-lived or 

transitory flow) streams provide temporary habitat during the year. Water availability would be limited to 

periods when water is present as a result of spring snowmelt or storm events. None of the streams are 

managed for recreational sports fisheries by CPW. The Yampa River is located approximately 4.5 miles 

(7.2 km) north of the mine boundary, and it contains a mixture of runs, riffles, and deep pools but lies 

outside the Project Area. 

The aquatic communities in the ephemeral streams would mainly support macroinvertebrates when 

water is present. Macroinvertebrate groups would be represented by species that are indicative of 

seasonal availability of water. Fish would not occur in the streams due to a lack of water on a consistent 

basis throughout the year. It is possible that a few scattered pools could provide fish habitat on an 

infrequent basis, but there are no upgradient perennial streams that would be a source of fish during flow 

events. 

The Yampa River, 4.5 miles (7.2 km) north of the Project Area, is part of the CPW’s Middle Yampa 

Fish Management Unit (FMU) (CPW 2010). This section of the river contains a mixture of coldwater 

and warmwater fish species. The upper portion of the Middle Yampa FMU is utilized as a recreational 

trout fishery, while the lower portion (from Hayden downstream to the confluence with the Williams 

Fork River) is managed for the recovery of federally endangered fishes of the Upper Colorado River 

Basin and other native fish species. Special status aquatic species are discussed in Section 3.10. The 

typical recreational sport fish species along the Yampa River include: rainbow trout (Oncorhynchus 

mykiss), brown trout (Salmo trutta), channel catfish (Ictalurus punctatus), northern pike (Esox lucius), 

and smallmouth bass (Micropterus dolomieu) (Johnson et al. 2008). Colorado River cutthroat trout 

(Oncorhynchus clarkii pleuriticus) and mountain whitefish (Prosopium williamsoni) are found in lakes 

and ponds in the area. 

3.10 Special Status Species 

Special status species are those species for which state or federal agencies afford an additional level of 

protection by law, regulation, or policy. Included in this category are federally listed species that are 

protected under the ESA; BLM sensitive species; and species that CPW has designated as threatened, 

endangered, or species of concern in Colorado. The analysis area for state listed and BLM sensitive 

species is the Project Area within suitable, historic, or occupied habitat and is coincident with the 

analysis area described for vegetation in Section 3.7. 

The analysis area for federally listed species is larger and equivalent to the areas analyzed in a separate 

Biological Assessment (BA) submitted to the USFWS for Section 7 consultation under the ESA 

(OSMRE 2015). The analysis area for the yellow billed-cuckoo includes the airshed analysis boundary 

for mercury deposition from mining and coal combustion. The analysis area for federally listed fish 

species includes this same airshed analysis boundary and an adjoining area to the west between the 

Yampa and White rivers to their confluences with the Green River. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-56 
Chapter 3.0 – Affected Environment 

Figure 3-12 Black Bear Ranges 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-57 
 

Chapter 3.0 – Affected Environment 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-58 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Special status species known to occur within Moffat County are shown in Table 3-14, which also 

describes those species that were carried forward for analysis in the EA and those that were not. Several 

sources of information were reviewed to identify sensitive species that have the potential to occur in the 

Project Area: the USFWS Information for Planning and Conservation (USFWS 2015a) for federally listed 

species, Colorado Natural Heritage Program's (CNHP) Species Tracking Lists (CNHP 2015), BLM 

sensitive species list for the LSFO (BLM 2015), published books and journal articles, and other sources 

of publicly available information. 

Table 3-14 Special Status Species in Moffat County 

Common Name 

(Scientific Name) 

Federal 

Status 

State 

Status Carried Forward for Further Analysis 

Amphibians Boreal toad 

(Anaxyrus boreas) 

BLM LSFO 

Sensitive 

No – suitable habitat is not found within 

the Project Area. 

Northern leopard frog 

(Lithobates pipiens) 

BLM LSFO 

Sensitive 

SC Yes – suitable habitat is not found 

within the Project Area. However, the 

species occurs in the SMCRA permit 

area and could disperse into Project 

Area in the future. 

Birds Northern goshawk 

(Accipter gentilis) 

BLM LSFO 

Sensitive 

NL No – suitable habitat is not found within 

the Project Area. 

Golden eagle 

(Aquila chrysaetos) 

BLM LSFO 

Sensitive 

NL Yes – suitable foraging habitat occurs 

in the Project Area. The species nests 

east of the Project Area. 

Burrowing owl 

(Athene cunicularia) 

BLM LSFO 

Sensitive 

NL Yes – suitable habitat is not found 

within the Project Area. However, the 

species is found on reclaimed lands 

west of the Project Area. 

Ferruginous hawk 

(Buteo regalis) 

BLM LSFO 

Sensitive 

SC Yes – species is rare in the region, with 

limited potential to occur in the Project 

Area. 

Greater sage-grouse 

(Centrocercus urophasianus) 

BLM LSFO 

Sensitive 

SC No – suitable habitat for the species is 

not present in the Project Area. 

Mountain plover 

(Charadrius montanus) 

BLM LSFO 

Sensitive 

SC No – rare in the region with unsuitable 

habitat in the Project Area. 

Yellow-billed cuckoo 

(Coccyzus americanus) 

Threatened NL Yes – suitable habitat is not found 

within the Project Area but occurs in a 

wider analysis area for this species. 

American peregrine falcon 

(Falco peregrinus anatum) 

BLM LSFO 

Sensitive 

SC Yes – rare spring and fall migrant in the 

wider analysis area with limited 

potential to occur in the Project Area. 

Sandhill crane 

(Grus canadensis) 

NL SC No – suitable habitat is not found within 

the Project Area although this species 

does nest in wetlands near the western 

SMCRA permit boundary. 

Bald eagle 

(Haliaeetus leucocephalus) 

BLM LSFO 

Sensitive 

SC No – suitable habitat is not found within 

the Project Area. 

Long-billed curlew 

(Numenius americanus) 

NL SC No – rare in the region with no suitable 

habitat in the Project Area. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-59 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-14 Special Status Species in Moffat County 

Common Name 

(Scientific Name) 

Federal 

Status 

State 

Status Carried Forward for Further Analysis 

Brewer’s sparrow 

(Spizella berweri) 

BLM LSFO 

Sensitive 

NL Yes – suitable habitat occurs in the 

Project Area where there is adequate 

shrub cover. 

Mexican spotted owl 

(Strix occidentalis) 

Threatened NL No – suitable habitat is not found within 

the Project Area. 

Columbian sharp-tailed grouse 

(Tympanuchus phasianellus 

columbianus) 

BLM LSFO 

Sensitive 

SC Yes – found within reclaimed areas. 

Fish Bluehead sucker 

(Catostomus discobolus) 

BLM LSFO 

Sensitive 

NL No – no suitable habitat in the Project 

Area. 

Flannelmouth sucker 

(Catostomas latipinnis) 

BLM LSFO 

Sensitive 

NL No – no suitable habitat in the Project 

Area. 

Mountain sucker 

(Catostomas platyrhynchus) 

BLM LSFO 

Sensitive 

SC No – no suitable habitat in the Project 

Area. 

Bonytail chub 

(Gila elegans) 

Endangered SE Yes – suitable habitat is not found 

within the Project Area but occurs in 

the wider analysis area for this species. 

Humpback chub 

(Gila cypha) 

Endangered ST Yes – suitable habitat is not found 

within the Project Area but occurs in 

the wider analysis area for this species. 

Roundtail chub 

(Gila robusta) 

BLM LSFO 

Sensitive 

SC No – occurs outside Project Area in the 

Yampa and White rivers. 

Colorado River cutthroat trout 

(Oncorhynchus clarkii pleuriticus) 

BLM LSFO 

Sensitive 

SC No – occurs outside Project Area in the 

Yampa and White rivers. 

Colorado pikeminnow 

(Ptychocheilus lucius) 

Endangered ST Yes – suitable habitat is not found 

within the Project Area but occurs in 

the wider analysis area for this species. 

Razorback sucker 

(Xyrauchen texanus) 

Endangered SE Yes – suitable habitat is not found 

within the Project Area but occurs in 

the wider analysis area for this species. 

Mammals Townsend’s big-eared bat 

(Corynorhinus townsendii) 

NL SC No – suitable habitat is not found within 

the Project Area. 

White-tailed prairie dog 

(Cynomys ludovicianus) 

BLM LSFO 

Sensitive 

NL No – the species is not present in the 

Project Area, but potential habitat 

occurs on reclaimed land and in native 

range land. 

Spotted bat 

(Euderma maculatum) 

BLM LSFO 

Sensitive 

NL No – suitable habitat is not found within 

the Project Area. 

Canada lynx 

(Lynx canadensis) 

Threatened SE No – suitable habitat is not found within 

the Project Area. 

Black-footed ferret 

(Mustela nigripes) 

Endangered SE No – the geographic range of reintroduced populations of the species 

is outside the Project Area. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-60 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-14 Special Status Species in Moffat County 

Common Name 

(Scientific Name) 

Federal 

Status 

State 

Status Carried Forward for Further Analysis 

Kit fox 

(Vulpes macrotis) 

NL SE No – Project Area is outside the 

geographic range of the species. 

Reptiles Midget faded rattlesnake 

(Crotalus oreganus concolor) 

BLM LSFO 

Sensitive 

SC No – suitable habitat is not found within 

the Project Area; the species is 

restricted to outcrops of the Green 

River Formation in the region. 

Plants Ute ladies’-tresses 

(Spiranthes diluvalis) 

Threatened NL No – suitable habitatis not found within 

the Project Area. 

Dudley bluffs twinpod 

(Physaria obcordata) 

Threatened NL No – suitable habitat is not found within 

the Project Area. 

Duchesne milkvetch 

(Astragalus duchesnensis) 

BLM LSFO 

Sensitive 

NL No – the Project Area is outside the 

geographic range of the species. 

Tufted cryptantha 

(Cryptantha caespitosa) 

BLM LSFO 

Sensitive 

NL No – the Project Area is outside the 

geographic range of the species. 

Uinta Basin spring-parsley 

(Cymopterus duchesnensis) 

BLM LSFO 

Sensitive 

NL No – the Project Area is outside the 

geographic range of the species. 

Singlestem buckwheat 

(Eriogonum acaule) 

BLM LSFO 

Sensitive 

NL No – the Project Area is outside the 

geographic range of the species. 

Woodside buckwheat 

(Eriogonum tumulosum) 

BLM LSFO 

Sensitive 

NL No – the Project Area is outside the 

geographic range of the species. 

Clay Hill buckwheat 

(Eriogonum viridulum) 

BLM LSFO 

Sensitive 

NL No – the Project Area is outside the 

geographic range of the species. 

Flaming Gorge evening primrose 

(Oenothera acutissima) 

BLM LSFO 

Sensitive 

NL No – the Project Area is outside the 

geographic range of the species. 

Colorado feverfew 

(Parthenium ligulatum) 

BLM LSFO 

Sensitive 

NL No – the Project Area is outside the 

geographic range of the species. 

Gibbens’ beardtongue 

(Penstemon gibbensii) 

BLM LSFO 

Sensitive 

NL No – the Project Area is outside the 

geographic range of the species. 

Yampa beardtongue 

(Penstemon yampaensis) 

BLM LSFO 

Sensitive 

NL No – the Project Area is outside the 

geographic range of the species. 

Rock tansy 

(Sphaeromeria capitata) 

BLM LSFO 

Sensitive 

NL No – the Project Area is outside the 

geographic range of the species. 

Hairy Townsend daisy 

(Townsendia strigosa) 

BLM LSFO 

Sensitive 

NL No – the Project Area is outside the 

geographic range of the species. 

Note: SE – State endangered; ST - State threatened; SC - State species of concern; NL – Not Listed. 

Sources: BLM 2015; CNHP 2015; OSMRE 2015; USFWS 2015a. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-61 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

3.10.1 Federally Threatened, Endangered, and Candidate Species 

3.10.1.1 Colorado River Federally Endangered Fish 

Bonytail Chub (Endangered with Critical Habitat) 

Currently, no self-sustaining populations of bonytail chub are known to exist in the wild, with very few 

individuals being reported throughout the Colorado River Basin (USFWS 2002a). The last known riverine 

area where bonytail chub were common was the Green River in Dinosaur National Monument, where 

Vanicek (1967) and Holden and Stalnaker (1970) collected 91 specimens from 1962 to 1966. From 1977 

to 1983, no bonytail chub were collected from the Colorado or Gunnison rivers in Colorado or Utah. 

However, in 1984, a single bonytail chub was collected from Black Rocks on the Colorado River. Several 

suspected bonytail chub were captured in Cataract Canyon from 1985 to 1987. Current stocking plans 

for bonytail chub identify the middle Green River and the Yampa River in Dinosaur National Monument 

as the highest priority for stocking in Colorado (USFWS 2008). 

The typical types of habitat used by bonytail chub consist of mainstem riverine areas and impoundments 

in the Colorado River system. Deep pools and eddies with slow to fast currents and muddy to rocky 

bottoms are characteristic of the riverine habitat (Kaeding et al. 1986). Based on five specimens 

captured in the Upper Colorado River Basin, four were captured in deep, swift, rocky canyon areas 

(i.e., Yampa Canyon, Black Rocks, Cataract Canyon, and Coal Creek Rapid) (USFWS 2002a). Critical 

habitat for the bonytail chub in the analysis area is present along the Yampa River and its 100-year 

floodplain within Dinosaur National Monument, which is roughly 60 miles (96.6 km) downstream from 

Craig, Colorado (Figure 3-13). 

The bonytail chub is an omnivorous feeder with a diet consisting of a wide variety of aquatic and 

terrestrial insects, small fish, worms, algae, plankton, and plant matter (Lower Colorado Multi-Species 

Conservation Program 2014). 

Colorado Pikeminnow (Endangered with Critical Habitat) 

Wild populations of Colorado pikeminnow are now found only in the upper basin of the Colorado River 

above Lake Powell. Three wild populations of Colorado pikeminnow exist in 1,090 miles (1,754 km) of 

riverine habitat in the Green River, upper Colorado River, and San Juan River sub-basins. The 

occurrence of Colorado pikeminnow in the Yampa River extends from the confluence with the Green 

River upstream to the Craig area. The most recent population estimates are still being analyzed, but the 

results seem to indicate a population decline throughout the entire Green River sub-basin which includes 

the Yampa and White rivers. The decline is likely due to introduced non-native predatory fish 

(USFWS 2014a). 

Habitat requirements of Colorado pikeminnow vary depending on the life stage and time of year. 

Young-of-the-year and juveniles prefer shallow backwaters, while adults use pools, eddies, and deep 

runs that are maintained by high spring flows (USFWS 2002b). Habitat, that was the focus of sampling 

efforts for Colorado pikeminnow in the Green River during low flow periods, includes small eddies and 

pools in nearshore areas and mid-channel sites near sand and gravel bars (Bestgen et al. 2010). 

Colorado pikeminnow is a long-distance migrator, with adults moving hundreds of miles to and from 

spawning areas. During peak runoff in the spring and early summer, fish usually move into backwater 

areas of flooded riparian zones to avoid swift velocities, feed, and prepare for the upcoming spawning 

period. Spawning occurs over riffle areas with gravel or cobble substrate between late June and early 

September. Spawning has been observed for Colorado pikeminnow in the lower 20 miles (32.2 km) of 

the Yampa River above the Green River confluence. This species primarily feeds on other fish, but 

smaller individuals also eat insects and other invertebrates. 

Critical habitat is present in the Yampa River and its 100-year floodplain within Dinosaur National 

Monument and continues upstream to Craig, Colorado. Critical habitat continues beyond the analysis 

area downstream below the Yampa’s confluence with the Green River (Figure 3-13). 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-62 
 

Chapter 3.0 – Affected Environment 

Figure 3-13 Colorado River Fish Critical Habitat 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-63 
 

Chapter 3.0 – Affected Environment 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-64 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Humpback Chub (Endangered with Critical Habitat) 

Currently, six populations of humpback chub are known to exist: 1) Black Rocks, Colorado River, 

Colorado; 2) Westwater Canyon, Colorado River, Utah; 3) Yampa Canyon, Colorado; 4) Desolation/Gray 

Canyons, Green River, Utah; 5) Cataract Canyon, Colorado River, Colorado; and 6) mainstem Colorado 

River in Marble and Grand canyons, Colorado. Populations in the Yampa River and Cataract Canyon 

are too small to monitor through mark-recapture analysis. The Yampa Canyon population is the closest 

occurrence to Trapper Mine, roughly 60 miles (96.6 km) west of Craig, Colorado. Critical habitat for the 

humpback chub is present in the analysis area along the Yampa River and its 100-year floodplain within 

Dinosaur National Monument (Figure 3-13), which is roughly 60 miles (96.6 km) downstream from Craig, 

Colorado. 

Humpback chub mainly occur in river canyons where they utilize a variety of habitats including deep 

pools, eddies, upwells near boulders, and areas near steep cliff faces. Humpback chub exhibit minimal 

movement from the canyon reaches, as indicated by a one-mile (1.6-km) movement distance in the 

Black Rocks area (Kaeding et al. 1990). As young humpback chub mature, they shift toward deeper and 

swifter offshore habitats (USFWS 2002c). In the Yampa and Green rivers, juveniles and adults use 

habitats consisting of rocky shoreline runs and small shoreline eddies. Humpback chub are opportunistic 

feeders that consume aquatic and terrestrial arthropods, small fishes, diatoms, planktonic crustaceans, 

and algae (USFWS 2015b). 

Razorback Sucker (Endangered with Critical Habitat) 

The largest population of the razorback sucker in the Upper Colorado River Basin exists in the middle 

Green River between the Duchesne and Yampa rivers, and is considered a single reproducing 

population (USFWS 2002d). The estimated numbers range from approximately 500 to 950 fish. 

Relatively low numbers are present in the Yampa, White, and Upper Colorado rivers. There are no 

current population estimates of razorback sucker in the Yampa River due to low numbers captured in 

recent years. Razorback suckers mainly occur in the lower four miles (6.4 km) of the Yampa River and 

occasionally utilize the river up to the confluence with the Little Snake River. 

Razorback suckers are permanent residents of the Green River below the confluence with the Yampa 

River and depend on in-channel habitat for spawning and flooded off-channel habitats for several phases 

of their development. The razorback sucker is found in deep clear to turbid waters of large rivers and 

some reservoirs over mud, sand, or gravel substrates. Habitat types used by razorback suckers vary 

depending on the life stage and time of year. Adults use eddies, pools, and backwaters during the 

nonbreeding period from July through March (Maddux et al. 1993). Seasonal habitat use includes pools 

and eddies from November through April, runs and pools from July through October, runs and 

backwaters in May, and backwaters and flooded gravel pits during June. Juveniles prefer shallow water 

with minimal flow in backwaters, tributary mouths, off-channel impoundments, and lateral canals 

(Maddux et al. 1993). In the upper basin, bottomlands, low-lying wetlands, and oxbow channels that are 

perennially flooded or ephemerally connected to the main channel by high spring flows are important 

habitats for all life stages of razorback sucker. Razorback suckers in riverine environments consume a 

mixture of benthic invertebrates, algae, detritus, and inorganic materials, with little evidence of 

zooplankton consumption. 

Critical habitat for the species is present in the Yampa River and its 100-year floodplain from about the 

east service road within Dinosaur National Monument and continuing downstream beyond the 

confluence with the Green River (BLM 2012) (Figure 3-13). Designated critical habitat also occurs along 

the White River upstream for approximately 15 miles (24 km) from its confluence with the Green River 

(Figure 3-13). 

3.10.1.2 Yellow-billed Cuckoo (Threatened with Proposed Critical Habitat) 

The yellow-billed cuckoo declined substantially in western Colorado during the 20th Century but was 

never very common. The most recent records show only sparse occurrences in western Colorado. The 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-65 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Colorado Breeding Bird Atlas II (2007-2011) shows two confirmed occurrences on the Western Slope 

(Wickersham 2015). One is along the North Fork of the Gunnison River near Paonia and Hotchkiss in 

Delta County (Wickersham 2015). The second is along the Gunnison River in Gunnison County. The 

previous Colorado Breeding Bird Atlas (1987-1994) had a confirmed record along the Yampa River, west 

of Steamboat Springs in Routt County (Kingery 1998). 

Other recent records also indicate that the species is rare and breeding is not well documented on the 

Western Slope. Reports of single yellow-billed cuckoos have come primarily from the Grand Junction 

area and Mesa County in 2001, 2002, 2005, and 2008, with a report of more than one cuckoo at Orchard 

Mesa Wildlife Area in 2006 (USFWS 2011). More recently, cuckoos have been observed or heard by 

USFWS staff and include one along the Gunnison River in Grand Junction in 2013, one along the 

Colorado River in 2014, and one along the North Fork of the Gunnison River in 2015. It is unknown if 

these birds were nesting (USFWS 2015c). Additional reports include a cuckoo south of Montrose in 

Montrose County near the Uncompahgre River in 2009, a cuckoo along the Gunnison River near 

Gunnison in 2007 (USFWS 2011), and detections by the Rocky Mountain Bird Observatory along the 

Yampa River near Craig in 2007 and 2008, and in far western Colorado near Nucla in 2005 and 2008 

(Beason 2012; Dexter 1998; USFWS 2011). The detections near Craig and Nucla in 2008 resulted from 

surveys completed by the Rocky Mountain Bird Observatory in five western counties. However, surveys 

repeated in two of the counties in 2009 failed to detect these birds. Surveys by the Rocky Mountain Bird 

Observatory in 2010 were conducted near historical detections and at sites with suitable habitat in 

Archuleta, Conejos, Montezuma, and Rio Grande counties in southcentral and southwest Colorado; no 

cuckoos were detected (Beason 2012). Survey results to date are insufficient to determine population 

size or trend. 

Yellow-billed cuckoos winter in South America and typically arrive on the Western Slope of Colorado in 

late May and leave by late August (Andrews and Righter 1992), with outlying records as late as midSeptember and mid-October. The species typically breeds at elevations below 6,000 feet (1,829 meters) 

amsl but occasionally breeds at elevations as high as 8,500 feet (2,591 meters) amsl (Andrews and 

Righter 1992). 

The yellow-billed cuckoo nests in large, contiguous blocks of riparian habitat (greater than 50 acres), 

particularly woodlands with cottonwoods (Populus fremontii) and willows (Salix sp.). A dense multilayered canopy of understory foliage appears to be an important factor in nest site selection. The 

multilayered canopy provides shade and traps moisture to create the relatively cooler and more humid 

streamside conditions that are believed to be important for nesting success. At the landscape level, the 

amount of cottonwood-willow-dominated vegetation in the landscape and the width of riparian habitat 

appear to influence yellow-billed cuckoo distribution and abundance (USFWS 2014b). Cuckoos appear 

to avoid nesting in isolated patches of about one to two acres in size or in narrow, linear riparian habitats 

that are less than 33 to 66 feet (10 to 20 meters) wide (Halterman et al. 2015). 

Overall, migration and wintering habitats appear to be less restrictive to this species (USFWS 2014b). 

Single birds have been detected in isolated habitat patches or linear riparian corridors during migration or 

the early breeding season (mid to late June). Migrating yellow-billed cuckoos also have been found in 

coastal scrub, second-growth forests and woodlands, hedgerows, forest edges, and in smaller riparian 

patches than those used for breeding (USFWS 2014b). 

The Project Area does not contain riparian habitat for the cuckoo. However, the species has been 

described as an occasional, localized breeder along the Yampa River near Craig, Colorado 

(USFWS 2014c). Proposed critical habitat for the species occurs along the Yampa River from 

approximately five miles (8 km) west of Craig to about eight miles (13 km) east of Hayden, which is 

within the wider analysis area for the cuckoo. The last known sighting of the cuckoo along the Yampa 

River occurred in 2008 and was within the proposed critical habitat. No information is available to 

indicate if the birds observed were nesting in the area or in the process of migration. 

Yellow-billed cuckoos usually forage within riparian habitats that are similar to breeding habitats, but they 

may undertake short flights from riparian habitats into surrounding low vegetation to capture prey 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-66 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

(Halterman et al. 2015). Cuckoos primarily eat large insects such as caterpillars, cicadas, and 

grasshoppers. They will consume frogs and small lizards and have been known to take eggs and young 

of other birds. Yellow-billed cuckoos will eat small fruits and seeds on wintering grounds and 

occasionally during the breeding season (Bennett and Keinath 2003). 

3.10.2 State Listed and BLM Sensitive Species 

3.10.2.1 Northern Leopard Frog 

The northern leopard frog is a species of concern in Colorado, as well as a BLM sensitive species. It 

inhabits the banks and shallows of marshes, ponds, lakes, reservoirs, beaver ponds, streams, and other 

habitats with permanent surface water (Hammerson 1986). This species is absent from otherwise 

suitable habitats where predatory fish, bullfrogs, or crayfish are abundant. Northern leopard frogs inhabit 

ponds and other suitable habitats within the SMRCA permit boundary, but the species has not been 

documented in the Project Area. 

3.10.2.2 Golden Eagle 

The golden eagle is a BLM sensitive species that is resident throughout Colorado but is more common in 

winter. The species is found in a wide array of habitats with open landscapes within Colorado (Andrews 

and Righter 1992). Nests are located on cliffs and trees in rugged areas. Golden eagle presence in an 

area is largely dictated by the availability of its preferred prey, rabbits and hares. Golden eagles are 

relatively common in Moffat County, and individuals occur regularly within the Project Area. There is a 

known golden eagle nest to the east of the Project Area. 

3.10.2.3 Burrowing Owl 

The burrowing owl is a BLM sensitive species. It is a summer resident in Colorado that occurs in 

grasslands and occasionally in semi-desert shrublands (Andrews and Righter 1992). Burrowing owls 

usually nest in prairie dog towns but will nest in burrows dug by other mammals. The species is 

uncommon on the Western Slope. Burrowing owls have been documented on reclaimed lands west of 

the Project Area but not within the Project Area itself. 

3.10.2.4 Ferruginous Hawk 

The ferruginous hawk is a species of concern in Colorado, as well as a BLM sensitive species. The 

species breeds in grasslands, semi-desert shrublands, and the ecotone between shrublands and pinyonjuniper woodlands. Nests are found on elevated sites, such as rock outcrops, power poles, or isolated 

trees. Winter concentrations are found around prairie dog towns (Travsky and Beauvais 2005). Although 

this species is rare in Moffat County, suitable habitat for ferruginous hawks is present within the Project 

Area. There is a historic breeding record near Craig, Colorado (Andrews and Righter 1992). 

3.10.2.5 American Peregrine Falcon 

The American peregrine falcon is a state species of concern and a BLM sensitive species that is found in 

open spaces associated with cliffs and bluffs that overlook rivers and open bodies of water. Habitat does 

exist, but is limited in the Project Area. There have been no reported sightings in the Project Area. 

3.10.2.6 Brewer’s Sparrow 

Brewer’s sparrow is a BLM sensitive species that is locally common in Moffat County throughout the 

year. It primarily inhabits and breeds in sagebrush shrublands. It also occurs in other shrublands 

dominated by mountain mahogany or rabbitbrush (Andrews and Righter 1994). Habitat exists for this 

species within the Project Area in older reclaimed lands and shrublands on unmined land. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-67 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

3.10.2.7 Columbian Sharp-tailed Grouse 

The Columbian sharp-tailed grouse is a species of concern in Colorado and a BLM sensitive species. It 

is found where deciduous shrubs (gamble oak and serviceberry) are interspersed with bunch grasses, 

sagebrush, aspen, irrigated meadows, wheat fields, and/or alfalfa fields. Display grounds are on knolls or 

ridges (Marks 2007). The entire Project Area is within Columbian sharp-tailed grouse overall range and 

winter range (CPW 2014). Approximately 410 acres of designated production areas for this species are 

located within the northwest corner of the Project Area (17 percent of the analysis area) (Figure 3-14). 

This species is known to occur within the Project Area although no leks are known to occur within the 

Project Area. Reclaimed areas at Trapper Mine have shown an increased presence of Columbian sharptailed grouse. TMI has worked cooperatively with CPW to develop reclaimed areas to promote 

Columbian sharp-tailed grouse habitat and evaluate the presence of the species. Lek count data from 

reclaimed areas west of the Project Area are provided in Table 3-15. 

Table 3-15	 Columbian Sharp-tailed Grouse Lek Counts in the Vicinity of the SMCRA
 

Permit Area Boundary
 

Lek 

Description 

Year 

Found 2006 20071 20082 2009 2010 2011 2012 2013 20143 

Above Cottonwood 

Spring (D-B-84) 

1998 40 30 

(4/5) 

18 

(4/22) 

20 

(4/21) 

27 

(4/27) 

27 

(4/29) 

32 

(4/9) 

31 

(4/30) 

26 

(4/9) 

D Pit Haulroad 

by LSWT JW3 

1998 10 7 

(4/16) 

6 

(4/30) 

3 

(4/23) 

5 

(4/27) 

2 

(5/3) 

1 

(4/10) 

0 

(5/1) 

0 

(4/22) 

C Pit Reclamation 

West Edge (C-C-92) 

2001 3 2 

(4/5) 

5 

(5/12) 

5 

(4/22) 

3 

(4/27) 

0 

(5/3) 

0 

(4/4) 

0 

(4/30) 

0 

(4/22) 

D Pit Reclamation by 

LSWT NNM5 (D-B-90) 

2002 17 15 

(5/9) 

13 

(4/22) 

12 

(4/22) 

7 

(4/27) 

0 

(5/3) 

0 

(4/5) 

0 

(4/30) 

2 

(4/9) 

D Pit Reclamation at 

top of Elk Drainage 

2010 ND ND ND ND 16 

(5/7) 

12 

(5/2) 

11 

(4/4) 

8 

(4/30) 

7 

(4/9) 

A Pit Reclamation S of 

Ash Pit (A-A-93) 

2003 18 13 

(5/3) 

26 

(4/29) 

9 

(4/21) 

11 

(4/27) 

0 

(4/29) 

0 

(4/5) 

ND 0 

(4/10) 

Johnson Gulch 

(rock pile ridge) 

2011 ND ND ND ND ND 7 

(5/9) 

14 

(4/10) 

8 

(5/2) 

6 

(4/10) 

Empire Reclamation 

Area 

2006 16 16 19 

(4/29) 

13 

(4/21) 

19 

(4/27) 

11 

(5/2) 

24 

(4/4) 

10 

(4/30) 

12 

(4/9) 

D Pit Reclamation by 

LSWT CE6 (D-B-90) 

2006 12 19 15 

(4/30) 

22 

(4/21) 

23 

(4/27) 

31 

(5/23) 

34 

(4/4) 

34 

(4/30) 

45 

(4/22) 

A Pit Reclamation east 

of Ash Pit (A-B-94) 

2006 9 8 

(5/3) 

8 

(5/3) 

4 

(4/21) 

0 

(4/20) 

0 

(5/16) 

0 

(4/5) 

-- 0 

(4/10) 

A East Reclamation 

(A-B-97) 

2008 ND ND 14 

(4/29) 

13 

(4/22) 

17 

(4/20) 

17 

(4/29) 

24 

(4/5) 

18 

(4/26) 

18 

(4/25) 

H Pit (top of ridge) 2009 ND ND ND 5 

(4/30) 

8 

(4/20) 

11 

(5/3) 

14 

(4/11) 

13 

(4/30) 

11 

(4/21) 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-68 
 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-15 Columbian Sharp-tailed Grouse Lek Counts in the Vicinity of the SMCRA 

Permit Area Boundary 

Lek 

Description 

Year 

Found 2006 20071 20082 2009 2010 2011 2012 2013 20143 

F Pit 

(SW corner of reclaim) 

2014 ND ND ND ND ND ND ND ND 7 

(4/11) 

Satellite Leks -- 2 6 3 14 11 19 18 12 17 

Annual Total 127 116 127 120 147 137 172 134 151 

1 Thirteen females were trapped on Lek 1 and taken to Middle Park by CPW.
	

2 Nine females were trapped on leks 1, 6, and 7 and taken to Middle Park by CPW.
	

3 Ten and eight males were trapped on leks 1 and 7, respectively, in September 2014 by CPW and relocated to
	

Middle Park. 

ND – No data. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-69 
 

Chapter 3.0 – Affected Environment 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-70 
Chapter 3.0 – Affected Environment 

Figure 3-14 Columbian Sharp-tailed Grouse Ranges 

11 x 17
	

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-71 
 

Chapter 3.0 – Affected Environment 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-72 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

3.11 Cultural Resources 

3.11.1 Introduction 

Cultural resources can be defined as “those parts of the physical environment – natural and built – that 

have cultural value of some kind to some sociocultural group” (King 1998). In broader terms, the concept 

of “cultural resources” embraces an “intricate mosaic of things and institutions and values, beliefs and 

perceptions, customs and traditions, symbols and social structures” (King 1998). This broader 

perspective forms the context in which the direct, as well as the indirect, effects of any undertaking are 

assessed. 

The mining plan modification of the Trapper Mine under review is considered a federal undertaking, 

which is subject to compliance with Section 106 of the NHPA, as amended through 2014 (54 USC 

300101 et seq.). The NHPA, as amended, requires that federal agencies take into account the effects of 

their undertakings on historic properties and afford the Advisory Council on Historic Preservation (ACHP) 

a reasonable opportunity to comment. The historic preservation review process mandated by Section 

106 is outlined in regulations issued by the ACHP, found at 36 CFR 800, Protection of Historic 

Properties, which became effective in 2004. Historic properties are defined at 36 CFR 800.16(l)(1) as 

any resource determined eligible for listing in the National Register of Historic Places (NRHP). 

NEPA also considers effects to cultural and historic resources. The term “cultural resources” covers a 

wider range of resources than “historic properties,” such as sacred sites, archaeological sites not eligible 

for the NRHP, and archaeological collections. The ACHP and the CEQ encourage integration of the 

NEPA process with Section 106 of NHPA and other planning and environmental reviews. 

The following sections define the area of potential effects (APE), identify tribal concerns, define historic 

properties, describe the regional culture history, and identify previous surveys and known cultural 

resources. This information provides the context in which the environmental consequences and 

cumulative impacts of this Project on historic properties in the APE can be assessed and interpreted. 

3.11.2 Definition of the APE 

The APE for direct project effects is defined as all associated mine-related disturbance and facilities with 

the Project Area. In addition to the APE, a number of cultural resource surveys have been conducted 

within the broader Project Area, SMCRA permit boundary, and extending 0.25 mile (0.4 km) beyond the 

SMCRA permit boundary. 

3.11.3 American Indian Concerns 

OSMRE has notified the Colorado SHPO and has corresponded with the following American Indian 

tribes that consider the Project Area to be located within their traditional territory. 

• Eastern Shoshone Tribe 

• Southern Ute Indian Tribe 

• Ute Mountain Ute Tribe 

• Ute Indian Tribe 

• Navajo Nation 

• Hopi Tribe 

OSMRE has consulted with the Hopi Tribe and the Southern Ute Indian Tribe on a site identified as 

eligible for listing as described in Section 3.11.7 below. Section 6.3 provides additional details on the 

consultation. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-73 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

3.11.4 Historic Properties 

Historic properties are defined at 36 CFR 800.16(l)(1) as any prehistoric or historic district, site, building, 

structure, or object included in, or eligible for inclusion in, the NRHP. Historic properties can be identified 

through historical documentation, field survey, and/or oral evidence. The significance of the known 

resources is evaluated within a regional cultural context. Historic properties and other cultural resources 

within the APE are discussed in Section 3.11.7. 

3.11.5 Regional Culture History 

Several recent studies have established a cultural history of northwestern Colorado. The most current 

and comprehensive study is the Northern Colorado River Basin cultural context, prepared by Reed and 

Metcalf (1999). Other pertinent studies, although somewhat dated, are the prehistory of northwestern 

Colorado (Grady 1984) and history of northwestern Colorado (Athearn 1982). 

The prehistory of northwestern Colorado extends back more than 12,000 years, when current evidence 

suggests that native peoples first arrived in this area (Reed and Metcalf 1999). These early inhabitants, 

collectively grouped as Paleoindians, are described generally as hunters of big game animals, many of 

which (e.g., mammoth, mastodon, and large bison) are now extinct. The succeeding Archaic era, which 

lasted from approximately 8,400 years ago until the Christian era, is characterized by a broad-based 

subsistence strategy focused on hunting and gathering (Reed and Metcalf 1999). The Formative era is 

distinguished from the preceding Archaic era by a major subsistence focus on horticulture, especially 

corn growing (Reed and Metcalf 1999). This period overlaps with the Archaic focus, approximately 

2,500 years ago and continues approximately 700 years when climatic changes upset this carefully 

honed pattern of subsistence. Not all of the early inhabitants of western Colorado pursued a Formative 

lifestyle; some places were simply unsuitable for horticulture, and those groups continued to hunt and 

gather. In some places, horticultural and non-horticultural groups lived side by side. Besides cultigens, 

Formative sites are marked by small arrow points, grinding stones, pottery, and living structures. The 

concluding Protohistoric era refers to aboriginal occupation of western Colorado between the end of the 

Formative era and the expulsion of the Ute tribes to reservations in 1881 (Reed and Metcalf 1999). 

The distribution of prehistoric sites varies depending on the age of the materials and the consequences 

of natural and cultural disturbances. Paleoindian artifacts are scarce near the Project Area (Reed and 

Metcalf 1999), an observation that is probably more attributable to natural (erosion and deposition) and 

cultural (modern disturbance) factors than true absence. Fremont tradition sites are located well to the 

west of the Project Area (Reed and Metcalf 1999). The Formative-era Gateway and Anasazi tradition 

sites are located farther to the south (Reed and Metcalf 1999). The non-horticultural cultural systems 

scattered throughout the area are included under the Aspen tradition. A greater frequency of Aspen 

tradition sites are found near the Project Area (Reed and Metcalf 1999). Evidence for Protohistoric sites 

is scarce and located south of the Project Area (Reed and Metcalf 1999). 

Athearn (1982) has succinctly summarized the non-aboriginal history of northwestern Colorado. Visits by 

Euroamericans and other non-natives prior to the mid-19th Century were infrequent. The discovery of 

gold, in 1859, near Denver, precipitated a major rush to Colorado. Mining eventually spread beyond the 

Front Range into other parts of Colorado, but it did not significantly develop in northwestern Colorado 

until the late 19th Century and early 20th Century. The development of transportation networks, 

especially the railroad, had a dramatic effect and spurred settlement and development throughout the 

region. Athearn (1982) describes the modern (1890-1980) development of northwestern Colorado as 

follows: 

towns were founded, natural resources developed, and vast areas of the public domain 

were withdrawn from use by homesteaders and cattlemen. The period was one of 

consolidation and reorganization; the old frontier rule of “he who got there first” was no 

longer in effect. Now settlers had to deal with large corporations, governmental 

agencies, and the law. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-74 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

3.11.6 Previous Surveys 

Between 1970 and 2013, 22 cultural resources surveys have been conducted within the broader 

SMCRA permit boundary of the Trapper Mine, including the APE (Table 3-16) and extending 0.25 mile 

beyond. The earliest surveys in the 1970s were completed by the University of Colorado at Boulder and 

Colorado State University’s Laboratory of Public Archaeology. Since the early 1980s, however, the 

surveys have been conducted by consulting firms. During these 43 years, the surveys were completed at 

a somewhat regular pace (approximately one survey every other year), except for 1981 when four 

surveys were completed. The areas surveyed ranged from 1 to 281,600 acres, and a total of 591 sites 

were recorded. Many of those surveys (e.g., Arthur et al. 1981; Lischka 1975; Mehls and Mehls 1991; 

Sherman et al. 1999; Treat and Newkirk 1981) included acres outside the SMCRA permit boundary, and 

the total sites recorded do not reflect the site density within the SMCRA permit boundary or APE. These 

surveys also resulted in the recording of 126 Isolated Finds (IFs). IFs are generally defined as 

“transportable artifacts representing a single activity” and a single feature may be treated as an IF 

(Colorado SHPO 2015). 

3.11.7 Known Cultural Resources 

Five cultural resources have been recorded within the direct APE. A Protohistoric rock art site (5MF.948) 

was documented in Federal Coal Lease C-079641 and determined eligible for listing in the NRHP. The 

other four resources were evaluated as not eligible for listing in the NRHP: a prehistoric sheltered camp 

with rock art (5MF.290) in Federal Coal Lease C-07519, and a prehistoric open camp/historic homestead 

(5MF.950) and two IFs (5MF.1145 and 5MF.1146) in Federal Coal Lease C-079641. These five 

resources are listed at the beginning of Table 3-17. 

Thirty-two cultural resources have been recorded outside the direct APE, but within the SMCRA permit 

boundary including 0.25 mile (0.4 km) beyond the boundary. Of these, 14 are sites and 18 are IFs. 

Table 3-17 summarizes these sites and IFs. Of the total number of resources, 24 are prehistoric in age 

and cultural affiliation, one site dates to the Protohistoric era, nine sites are historic, one site has both 

prehistoric and historic components, and the age of one site is unknown. Prehistoric site types include 

open camp, open lithic, sheltered camp, and rock art. The historic site types include homestead, 

shepherd’s camp, temporary shelter, and linear routes (highway, road, and wagon road). Most of the IFs 

are prehistoric lithic artifacts. 

Additional sites have been located outside the direct APE, but within the SMCRA permit boundary 

including 0.25 mile (0.4 km) beyond the boundary. A historic highway (5MF.5138) has been 

recommended as eligible for listing in the NRHP. Additional data are needed for two prehistoric open 

camps (5MF.288 and 5MF.945) before their eligibility for listing in the NRHP can be evaluated. 

Table 3-16	 Summary of Previous Surveys within SMCRA Permit Boundary Plus 0.25-mile 

Buffer 

Survey ID 

Completion 

Date Author(s) Institution Description* 

Results 

Acres Sites IFs 

MF.LM.R1036 7/30/2013 C.E. Conner Grand River 

Institute 

Survey of Lease 

Modification 

Area 

860 3 0 

MC.LM.R652 5/15/2012 C.E. Conner, 

C. Martin, and 

B. Davenport 

Grand River 

Institute 

Survey of 

Williams Fork 

Mountain’s 

Exploration 

Project 

Phase IV 

139 4 1 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-75 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-16 Summary of Previous Surveys within SMCRA Permit Boundary Plus 0.25-mile 

Buffer 

Survey ID 

Completion 

Date Author(s) Institution Description* 

Results 

Acres Sites IFs 

MF.LM.R898 6/9/2011 P. O’Brien BLM LSFO Survey for TMI’s 

Proposed 

Williams Fork 

Mountain’s 

Exploration 

Phase 2 

121 1 0 

MF.LM.R890 5/26/2011 P. O’Brien BLM LSFO Survey for TMI’s 

Proposed 

Williams Fork 

Mountain’s 

Exploration 

Phase 1 

57 1 0 

MF.LM.R704 7/19/2006 T. Bott Metcalf 

Archaeological 

Consultants 

Empire Mine 

Seismic Line #2 

44 0 2 

MC.CH.R98 5/4/2000 M.W. Painter 

and 

R.D. Vickers 

Centennial 

Archaeology 

Survey of 12-

Region Wide 

Fencing 

Upgrade 

Locations 

320 7 4 

MC.CH.R96 6/7/1999 S.A. 

Sherman, 

T.R. Metcalf, 

M.W. Painter, 

D.C. Jones, 

and C.J. Zier 

Centennial 

Archaeology 

Survey of 

Interstates 25, 

70, 225, and 

270, U.S. 

Highway 34 and 

160; and SH 13 

and 470 

16,570 255 22 

MC.CM.R1 9/1/1991 S. Mehls, and 

C. Mehls 

Western Historical 

Studies 

Coal Mining 

Survey 

281,600 81 0 

MC. LM. 

NR135 

6/28/1983 C.J. Zier Metcalf-Zier 

Archaeologists 

Survey of Drill 

Hole Locations 

for Williams 

Fork 

29 0 0 

MF.LM.R619 8/1/1981 C.S. Arthur, 

J.L. Brower, 

S.M. Collins, 

J.E. 

Ingmanson, 

C.J. Jennings, 

L.M. Viola, 

and 

G.J. Krause 

CSU Laboratory of 

Public Archaeology 

Archaeological 

Investigations 

Along Colowyo 

Coal Company 

Railroad Spur 

220 21 0 

MC.E.R58 7/24/1981 P. Treat and 

J.A. Newkirk 

Gilbert/ 

Commonwealth 

Survey of CraigRifle 230- to 

345-kV 

Transmission 

Line 

1,498 5 10 

MF.LM.R531 7/2/1981 M. Loscheider Archaeological 

Services 

Addendum to 

Trapper Mine 

Survey 

1 8 0 

MC.LM.R294 5/22/1981 G.E. Williams, 

and M. Emery 

Powers Elevation Phases I and II 

Survey of MobilPagoda Pipeline 

835 7 4 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-76 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-16 Summary of Previous Surveys within SMCRA Permit Boundary Plus 0.25-mile 

Buffer 

Survey ID 

Completion 

Date Author(s) Institution Description* 

Results 

Acres Sites IFs 

MR.LM.R524 11/1/1980 C.F. Caraveo 

and 

J.W. Greer 

Archaeological 

Services 

Survey of 

Trapper Mine 

5,583 7 18 

MC.LM.R2 5/1/1977 C. Arthur and 

C.H. Jennings 

CSU Laboratory of 

Public Archaeology 

Reconnaissance 

Survey of 

Proposal Coal 

Lease Areas 

14,280 53 0 

MF.LM.R616 3/1/1977 P.R. Williams 

and 

C.H. Jennings 

CSU Laboratory of 

Public Archaeology 

Archaeological 

Reconnaissance 

of Utah 

International 

Craig 

Underground 

1,120 1 0 

MC.LM.R50 9/1/1975 C.S. Arthur CSU Laboratory of 

Public Archaeology 

Interim Report 

on 

Reconnaissance 

Survey of 

Proposed Coal 

Lease Areas 

23,000 54 0 

MF.LM.R287 6/1975 J.J. Lischka CU Boulder W.R. Grace & 

Company 

Railroad 

Corridors & 

Colowyo Mine 

Site 

10,152 72 65 

MF.CU.R7 8/7/1973 J.J. Hester 

and 

B. Williams 

CU Boulder Archaeological 

Survey of 

Proposed 

Railroad 

Construction 

Unknown 4 0 

MF.CU.R8 11/19/1972 J.E. Smith CU Boulder Archaeological 

Appraisal of 

Proposed Plant 

Site 

Unknown 1 0 

MF.CU.R3 5/5/1972 D.A. 

Breternitz 

CU Boulder Survey of 

Archaeological 

Resources 

Within Coal 

Stripping Area, 

Williams Fork 

Mountains 

Unknown 3 0 

MF.CU.R4 10/20/1970 D.A. 

Breternitz 

CU Boulder Archaeological 

Appraisal of 

Proposed 

Hayden and 

Yampa-Williams 

Fork Power 

Plant Sites 

320 3 0 

CSU = Colorado State University. 

CU = Colorado University. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-77 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-17	 Summary of Identified Sites within Project Area and SMCRA Permit Boundary 

Plus 0.25-mile Buffer 

Site No. Recording Lease NRHP 

(5MF.___) Date Description Age Date Areas? Eligibility 

948 8/21/2013 Rock Art Protohistoric UD- Yes Determined 

Eligible 

950 5/12/1987 Open Prehistoric/Historic 1910­ Yes Determined 

Camp/Homestead 1969 Not Eligible 

290 7/29/1980 Shelter Unknown UD Yes Determined 

Camp/Rock Art Not Eligible 

1145 7/3/1980 Isolated Find (P) Prehistoric UD Yes Recommended 

Not Eligible 

1146 7/3/1980 Isolated Find (P) Prehistoric UD Yes Recommended 

Not Eligible 

7402.1 5/5/2014 Road Historic UD No Determined 

Not Eligible 

7566.1 5/5/2014 Wagon Road Historic UD No Does Not 

Support 

Eligibility of 

Linear 

Resource 

5138 2/6/2002 Highway Historic 1916 No Recommended 

Eligible 

445 4/11/1999 Open Camp Prehistoric UD No Recommended 

Needs Data 

2427 5/13/1987 Homestead Historic 1920 No Determined 

Not Eligible 

2253 10/2/1985 Temporary Shelter Historic UD No Determined 

Not Eligible 

1960 8/15/1984 Homestead Historic 1920 No Determined 

Not Eligible 

1399 7/1/1981 Shepherd’s Camp Historic 1900- No Determined 

1930 Not Eligible 

1202 5/27/1981 Isolated Find Prehistoric UD No Determined 

(flake) Not Eligible 

947 7/8/1980 Open Camp Late Plains Archaic UD No Determined 

Not Eligible 

945 7/7/1980 Open Camp Prehistoric UD No Determined 

Not Eligible 

946 7/7/1980 Open Lithic Late Plains Archaic UD No Determined 

Not Eligible 

1130 7/3/1980 Isolated Find (P) Prehistoric UD No Recommended 

Not Eligible 

1131 7/3/1980 Isolated Find (P) Prehistoric UD No Recommended 

Not Eligible 

1132 7/3/1980 Isolated Find (P) Prehistoric UD No Recommended 

Not Eligible 

1133 7/3/1980 Isolated Find (P) Prehistoric UD No Recommended 

Not Eligible 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-78 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-17 Summary of Identified Sites within Project Area and SMCRA Permit Boundary 

Plus 0.25-mile Buffer 

Site No. 

(5MF.___) 

Recording 

Date Description Age Date 

Lease 

Areas? 

NRHP 

Eligibility 

1134 7/3/1980 Isolated Find (P) Prehistoric UD No Recommended 

Not Eligible 

1135 7/3/1980 Isolated Find (H) Historic UD No Recommended 

Not Eligible 

1136 7/3/1980 Isolated Find (P) Prehistoric UD No Recommended 

Not Eligible 

1137 7/3/1980 Isolated Find (P) Prehistoric UD No Recommended 

Not Eligible 

1138 7/3/1980 Isolated Find (P) Prehistoric UD No Recommended 

Not Eligible 

1139 7/3/1980 Isolated Find (P) Prehistoric UD No Recommended 

Not Eligible 

1140 7/3/1980 Isolated Find (P) Prehistoric UD No Recommended 

Not Eligible 

1141 7/3/1980 Isolated Find (P) Prehistoric UD No Recommended 

Not Eligible 

1142 7/3/1980 Isolated Find (P) Prehistoric UD No Recommended 

Not Eligible 

1143 7/3/1980 Isolated Find (P) Prehistoric UD No Recommended 

Not Eligible 

1144 7/3/1980 Isolated Find (P) Prehistoric UD No Recommended 

Not Eligible 

1147 7/3/1980 Isolated Find (P) Prehistoric UD No Recommended 

Not Eligible 

903 10/13/1976 Isolated Find (P) Prehistoric UD No Recommended 

Not Eligible 

348 8/1/1975 Homestead Historic 1920 No Determined 

Not Eligible 

288 6/10/1972 Open Camp Prehistoric UD No Recommended 

Needs Data 

Sites in bold are found within the Project Area.
	

Sites highlighted in gray are eligible for listing in the NRHP; sites highlighted in blue require additional data for evaluation.
	

P = Prehistoric; H = Historic.
	

UD – Undated.
	

3.12 Socioeconomics 

The Trapper Mine is located approximately six miles (9.7 km) southwest of the City of Craig and 

approximately 16 miles (25.7 km) west of the Town of Hayden. The mine is to the east of SH 13 in Moffat 

County. The Town of Hayden is within Routt County. Table 3-18 details the populations of these 

communities. Ethnic demographics are further discussed in Section 3.13. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-79 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-18 Population Estimates 

Community 2000 Census 2010 Census 2014 Estimate 

Craig 9,189 9,464 8,846 

Hayden 1,634 1,810 1,837 

Source: U.S. Census Bureau 2013, 2015. 

In general, the populations of Craig and Hayden have increased since 2000, with 3 percent total growth 

from 2000 to 2010 for Craig, and 11 percent growth from 2000 to 2010 for Hayden. Growth for Hayden is 

expected to turn static, while it is estimated that Craig has experienced negative growth since the 2010 

census. 

Per capita personal income has grown in both Craig and Hayden between 2000 and 2014, with Craig 

and Hayden recording 26 and 39 percent growth, respectively. The growth rate for Craig was less than 

the State of Colorado average. Per capita personal income is shown in Table 3-19. Mean household 

income grew for each municipality during the 2000 to 2014 timeframe with the City of Craig recording 

higher mean household income growth than the Town of Hayden, but less than the State of Colorado. 

Mean household income growth for the Town of Hayden also was lower than the average for the State of 

Colorado. Mean household income is portrayed in Table 3-20. 

Table 3-19 Per Capita Personal Income 

Community 2000 2014 Estimate % Change 

Craig $18,140 $22,936 26 

Hayden $18,574 $25,795 39 

State of Colorado $24,049 $31,674 32 

Source: U.S. Census Bureau 2015. 

Table 3-20 Mean Household Income 

Community 2000 Estimate 2014 Estimate % Change 

Craig $45,836 $59,186 29 

Hayden $47,317 $59,718 26 

State of Colorado $59,313 $79,990 35 

Source: U.S. Census Bureau 2015. 

The three largest employment sectors in Craig in terms of employment are educational services and 

health care, retail trade, and arts and entertainment. The agriculture, forestry, fishing and hunting, and 

mining sector is Craig’s fourth largest employment sector. The three largest employment sectors in 

Hayden are education and health care, retail trade, and construction. The agriculture, forestry, fishing 

and hunting, and mining sector is Hayden’s fourth largest employment sector. The top three employment 

industries for the State of Colorado roughly mirror those of Craig and Hayden (U.S. Census Bureau 

2013). 

Both Moffat and Routt counties have recorded declining unemployment rates over the past several years 

as local and national economic conditions improved. The preliminary July 2015 unemployment rates for 

Moffat and Routt counties were 4.4 percent and 3.2 percent, respectively. The July 2015 preliminary 

unemployment for the State of Colorado was 3.8 percent (U.S. Bureau of Labor Statistics 2015). The 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-80 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

unemployment scenario for mining is less optimistic as Bureau of Economic Analysis data indicates a 

decrease of 10 percent in total full- and part-time employment within the mining sector from 2010 to 2014 

(Bureau of Economic Analysis 2015). Routt County also recorded a decrease in employment of 

2 percent during the same timeframe. Moffat County experienced a decline in employment related to 

workers in the oil and gas and residential and commercial construction industries as workers have left 

Moffat County to seek jobs elsewhere as a result of declines in these industries. Such worker relocations 

are not typically reflected in employment statistics as workers leave the area for work elsewhere instead 

of filing for unemployment in the area 

Craig and Hayden median home price growth rates have exceeded that of the State of Colorado, as has 

the growth rate for median rent (Table 3-21); however, more recent data suggests a downturn in home 

prices, as the Craig Chamber of Commerce reports its fourth quarter median price of home sales in 

Moffat County at approximately $130,000 (Craig Chamber of Commerce 2014). Recent data on real 

estate website Zillow (Zillow.com) also reflects a potential softening of local home prices (Zillow 2015). 

Table 3-21 Housing Characteristics 

Community 

2000 

Median Home 

Price 

2010 

Median Home 

Price 

Percent 

Change 

2000 

Median Rent 

2010 

Median Rent 

Percent 

Change 

Craig $101,900 $160,100 57 $450 $719 60 

Hayden $132,100 $216,800 64 $662 $882 33 

State of Colorado $166,600 $236,600 42 $671 $852 27 

Source: U.S. Census Bureau 2013. 

The mining industry in Moffat County is the largest industry in the county in terms of employee 

compensation, consisting of 19 percent of total county private nonfarm compensation (Bureau of 

Economic Analysis 2014). The Trapper Mine directly employed 191 workers as of the end of 2015. 

These workers were mostly from the municipalities of Craig and Hayden, in Moffat and Routt counties, 

respectively. In 2014, TMI expended approximately $19.7 million in gross wages, including benefits 

(TMI 2015). This amount rose to $20.3 million in 2015 (TMI 2016a). 

Trapper Mine supports many businesses both directly and indirectly. A number of industries directly 

provide services to the daily operation of the mine, while a number of industries, such as retail and the 

accommodation industry, are indirectly supported by the mine. The local expenditures on goods and 

services within the City of Craig in 2015 totaled $6.0 million. Total 2015 expenditures on goods and 

services in neighboring Routt and Rio Blanco counties totaled $5.2 million and $83,000, respectively 

(TMI 2016a). The Economic Development Council of Colorado (EDCC) prepared a report detailing the 

economic activity within the Yampa-White River Region of Northwest Colorado (EDCC 2015). The most 

recent data available at the time of the report was for 2012. Moffat County’s coal mining sector 

contributed about $229 million, or 31 percent of the county Gross Regional Product of $742 million 

(EDCC 2015). Coal mining in Moffat County also directly employed 776 workers for a total of 1,144 direct 

and indirect workers supported by the mining industry, providing direct labor income of $61.1 million and 

total income of $75.3 million. Routt County’s coal mining sector contributed about $191 million, or 

12 percent of the county gross regional product of $1,618 million (EDCC 2015). Coal mining in Routt 

County directly employed 586 workers for a total of 1,152 direct and indirect workers supported by the 

mining industry, providing direct labor income of $62.4 million and total income of $93.3 million 

(EDCC 2015). Coal mining in Rio Blanco also contributes revenue and employment to the local 

economy. These contributions are detailed in the Colowyo Coal Mine South Taylor/Lower Wilson Permit 

Expansion Area Project, Federal Mining Plan Modification EA (OSMRE 2015). 

Coal production in Moffat County has been declining over the past several years. Production declined by 

89,000 tons, or 21 percent, in September 2015 compared to September 2010 (CDRMS 2015). Total coal 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-81 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

production for the full year 2014 was approximately 4.4 million tons, down 8 percent from 4.8 million tons 

in 2010. This represents an average monthly decline in production of 34,000 tons, from 400,000 average 

monthly tons in 2010 to 366,000 average monthly tons in 2014 (CDRMS 2015). 

A national program, established by SMCRA, is in place that includes an inventory of high priority 

abandoned mine sites, a reclamation fee paid by the coal mining industry, and a funding mechanism 

comprised largely of grants to states and Indian tribes with approved OSMRE programs to provide cleanup of these abandoned mines. This fee is known as the Abandoned Mine Land fee (DOI 2015). During 

the 2010 to 2015 timeframe, Trapper Mine paid a total of $3.9 million in federal Abandoned Mine Land 

fees (TMI 2015, 2016b). A federal coal lease royalty tax rate of 12.5 percent is applied to mined federal 

coal per 43 CFR 3473. Of the revenue collected through federal mineral lease royalties, 49 percent is 

distributed to the state and 51 percent to the federal government. The federal government disperses 

approximately 78 percent of its share to the Reclamation Fund for western water projects, and 22 

percent to the General Fund of the U.S. Treasury. The state distributes its portion to the State Public 

School Fund (48.3 percent), Colorado Water Conservation Board (10 percent), and school districts (1.7 

percent). Approximately 40 percent of the state’s portion is directed to the Local Impact Program through 

the Department of Local Affairs (DOLA). Trapper Mine paid a total of $36.9 million in federal mineral 

lease royalties during the 2010 to 2015 timeframe, 49 percent ($18.1 million) of which was distributed to 

Colorado. In addition, from 2010 to 2015, Trapper Mine paid approximately $1.5 million to the CSLB for 

state-leased coal with the money used to support public schools. 

Colorado severance tax on surface-mined coal is 36 cents per ton produced, with the first 300,000 tons 

produced per quarter exempt (Section 39-29-106, CRS). Of the state severance tax received, half is 

distributed to the DNR and the remaining half to the DOLA. DOLA then distributes funds to local impact 

grants and counties based on the number of production employees living in the energy-impacted 

communities, as well as permits, production, population and highway user miles (Colorado 2010; 

Colorado DOLA 2015). Trapper Mine paid a total of $4.8 million from 2010 through 2015 in severance 

tax, averaging $796,500 a year, of which a portion was distributed to local governments and impact grant 

funds. Trapper Mine also paid $8.0 million in property tax during the 2010 to 2015 timeframe (TMI 2015). 

It also is estimated that TMI paid Moffat County over $1.36 million in tax revenue for the 2015 tax year 

(TMI 2016a). 

TMI is socially involved in the community in a number of ways. Local community participation has 

included reclamation of a gravel pit resulting in a waterfowl sanctuary which will become a part of the 

South Beach State Park, construction of the Trapper Fitness Center for the benefit of local residents, 

donation of labor and equipment for Loudy-Simpson Park soccer field construction, construction of the 

“back nine” at the Yampa Valley golf course, construction and maintenance of local athletic facilities, and 

educational mine tours. Further discussion of TMI community involvement is included in Section 4.12.1. 

3.13 Environmental Justice 

Environmental justice is defined as the fair treatment and meaningful involvement of all people 

regardless of race, color, national origin, or income with respect to the development, implementation, and 

enforcement of environmental laws, regulations, and policies (USEPA1998). EO 12898, Federal Actions 

to Address Environmental Justice in Minority Populations and Low-Income Populations, tasks “each 

Federal agency [to] make achieving environmental justice part of its mission by identifying and 

addressing, as appropriate, disproportionately high adverse human health and environmental effects of 

its programs, policies, and activities on minority populations and low-income populations.” 

According to the CEQ and USEPA guidelines established to assist federal and state agencies, a minority 

population is present in a Project Area if: 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-82 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

•	 The minority population of the affected area exceeds 50 percent; or 

•	 The percentage of the minority population in the affected area is meaningfully greater than the 

percentage in the general population. 

Of the total estimated 2014 population of Moffat County, the large majority classify themselves as White 

(82.2 percent). The second largest ethnic/racial group is Hispanic or Latino (14.3 percent), followed by 

those who classify themselves as American Indian or Alaska Native (1.5 percent) and Asian 

(0.8 percent) (U.S. Census Bureau 2015). All of the minority populations within Moffat County are below 

the Colorado average. 

The guidance recommends that low-income populations in an affected area be identified using the 

annual statistical poverty thresholds from the Bureau of Census. In identifying low-income populations, 

agencies may consider a community as either a group of individuals living in geographic proximity to one 

another, or a set of individuals (such as migrant workers or Native Americans), where either type of 

group experiences common conditions of environmental exposure. In 2014 the U.S. Census Bureau 

annual income poverty threshold for a family of three was $18,850 (U.S. Census Bureau 2014). The 

percent of the population living below the poverty level in Moffat County is 11.5 percent. The state 

average is 13.2 percent (U.S. Census Bureau 2015). The number of people living below the poverty level 

in Moffat County is well below the state average. Additionally, all of the minority populations within Moffat 

County are below the Colorado average. These factors indicate the lack of an environmental justice 

population in the study area. The analysis of environmental justice populations was not carried forward 

into Chapter 4.0 because of the lack of an environmental justice population in the study area. 

3.14 Recreation 

Popular forms of recreation on public lands in the region include boating and river based recreation, 

camping, hiking, horseback riding, hunting, mountain biking, off-highway vehicle use, and wildlife viewing 

on public lands managed by the BLM. Most of these activities occur west of the Town of Craig where 

public lands are more prevalent; however, the Yampa River does flow immediately to the west of the 

Craig Station approximately 4.5 miles (7.2 km) north of the Project Area. Recreation on the Yampa River 

has been managed by CPW (previously the Colorado Division of Wildlife) since 1999 under an 

agreement with the BLM (BLM 2010). Boating activities on the Yampa River are typically limited to late 

spring and early summer when spring runoff occurs and there is peak water flow. By July, the irrigation 

water demand decreases the water levels and boating becomes less feasible. 

The land within the Project Area is private and state-owned and, therefore, not open to public recreation 

except when landowners agree to lease portions of their land for specific activities such as for hunting or 

fishing. Recreational activities are not allowed within the Project Area while active mining operations are 

in process due to public safety concerns. All routes that provide access to the Project Area are gated and 

require keys or access codes to open. Because public land recreational opportunities do not exist within 

the Project Area or vicinity, recreation was not carried forward for further analysis in this EA. 

3.15 Visual Resources 

OSMRE does not have its own visual standards and uses the BLM visual management standards to 

assess visual impacts of projects. The BLM manages visual resources using an inventory system to 

identify visual values and minimize visual impacts to the overall landscape character of federally 

managed lands. 

3.15.1 BLM Visual Resources Management 

3.15.1.1 Visual Resource Inventory 

The Visual Resource Inventory (VRI) process consists of scenic quality evaluations, analysis of scenic 

sensitivity, and delineation of distance zones. The combination of these three factors result in 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-83 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

BLM-administered lands being placed in one of four VRI classes to inform the RMP decision makers in 

assigning the Visual Resource Management (VRM) class. VRI Class I is assigned to lands where 

previous management decisions have determined that a natural landscape is to be maintained, such as 

for national wilderness areas and national scenic and wild rivers. Classes II through IV are assigned 

through a combined assessment of scenic quality, sensitivity levels, and distance zones (BLM 1986). 

3.15.1.2 Visual Resource Management 

For BLM-managed lands, VRM classes are assigned through RMPs with consideration of the actions 

proposed during the RMP process. All actions that would result in surface disturbance must consider 

VRM objectives to assess the level of allowable change to the viewshed. Per the BLM Manual H-8410-1 

(BLM 1986), the VRM Class objectives are defined as follows: 

•	 Class I: Preserve the existing character of the landscape. This class provides for natural 

ecological changes; however, it does not preclude very limited management activity. The level of 

change to the characteristic landscape should be very low and must not attract attention. 

•	 Class II: Retain the existing character of the landscape. The level of change to the characteristic 

landscape should be low. Management activities may be seen, but should not attract the 

attention of the casual observer. Any changes must repeat the basic elements of form, line, 

color, and texture found in the predominant natural features of the characteristic landscape. 

•	 Class III: Partially retain the existing character of the landscape. The level of change to the 

characteristic landscape should be moderate. Management activities may attract attention but 

should not dominate the view of the casual observer. Changes should repeat the basic elements 

found in the predominant natural features of the characteristic landscape. 

•	 Class IV: Provide for management activities which require major modifications of the existing 

character of the landscape. The level of change to the characteristic landscape can be high. 

These management activities may dominate the view and be the major focus of viewer attention. 

However, every attempt should be made to minimize the impact of these activities through 

careful location, minimal disturbance, and repeating the basic elements. 

The BLM LSFO RMP states that areas suitable for coal mining are generally classified as VRM Class IV 

(BLM 2011). 

3.15.1.3 Visual Resources Surrounding the Project Area 

Trapper Mine is located in the Intermountain Semidesert Province Ecoregion on the northern slope of the 

Williams Fork Mountains with the Yampa River to the west and north. The Williams Fork River runs 

south of the SMCRA permit area. The mine area ranges from approximately 6,500 to 7,800 feet 

(1,981 to 2,377 km) amsl and is dominated by a mountain shrub community to the east that transitions 

into a sagebrush steppe community in the western portion. 

3.15.1.4 View Points 

Viewers of the Trapper Mine Project Area would be travelers on U.S. Highway 40, SHs 13 and 394, and 

CRs 35, 93, and 107 (see Section 3.17) in the vicinity of the Project Area where roads are traversing 

comparatively higher or more open ground. 

Some recreationists may experience views of Trapper Mine while engaging in disbursed recreation on 

public lands. This would require an individual to be on relatively high or open ground. The draglines 

would be visible from portions of the Yampa River for approximately five miles (8 km) east of Craig, 

intermittent areas of the Yampa River for eight miles (13 km) west of Craig, and intermittent areas north 

of Craig. Trapper Mine would not be visible from the Williams Fork River because mining occurs on the 

north side of the Williams Fork Mountains. The dragline booms would be visible but would likely blend 

with the exposed soils in a manner that would limit the ability to distinguish the booms. However, as 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-84 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

mining activities move up the hillside, the dragline house, which is painted white, would become more 

visible because the color would contrast with the exposed soils. 

3.15.2 Lighting 

Trapper Mine lies in the light shadow of the Craig Station. The Craig Station is the dominant nighttime 

light source in the vicinity of the City of Craig. Lighting within the Trapper Mine is limited to active mining 

areas. All mining equipment has lights that are used at nighttime. Portable light plants also are used 

within the active mining areas and are moved as needed to ensure working areas are well lit. Lighting for 

nighttime activities is required for worker safety. All lighting is directed downward to provide the 

maximum amount of light for work areas and least visual disturbance outside the work area. 

There are no lights on the haul roads. The main office complex located west of the Project Area does 

have nighttime lighting that is typical of an office complex. 

3.16 Paleontological Resources 

OSMRE does not have its own paleontological resource standards and uses the BLM and USFS 

Potential Fossil Yield Classification (PFYC) to provide an assessment method to determine the potential 

for fossils in geologic units (BLM 2007). The PFYC system includes the following classifications: 

•	 Class 1: Igneous and metamorphic geologic units (excluding tuffs) that are not likely to contain 

recognizable fossil remains. 

•	 Class 2: Sedimentary geologic units that are not likely to contain vertebrate fossils or
	

scientifically significant non-vertebrate fossils.
	

•	 Class 3: Fossiliferous sedimentary geologic units where fossil content varies in significance, 

abundance, and predictable occurrence. A Class 3 formation may have unknown potential. 

•	 Class 4: Class 4 geologic units are Class 5 units that have lowered risks of human-caused 

adverse impacts or lowered risk of natural degradation. Proposed ground-disturbing activities 

would require assessment to determine whether significant paleontological resources occur in 

the area of a Proposed Action and whether the action would impact the resources. 

•	 Class 5: Highly fossiliferous geologic units that regularly and predictably produce vertebrate 

fossils or scientifically significant non-vertebrate fossils and that are at high risk of natural 

degradation or human-caused adverse impacts. 

The higher the PFYC number, the higher the fossil yield potential and greater sensitivity to adverse 

impacts. The Williams Fork Formation in northwestern Colorado has yielded valuable fossils including 

dinosaurs, other vertebrates, fossil tracks, and plants (Sullivan and Lucas 2006). Fossils that have been 

observed at the Trapper Mine include mollusks, evidence of burrowing animals in soft sediment 

(bioturbation), angiosperm leaf impressions, in situ tree stumps, and root casts (Massoth 1982). Because 

of the high-potential for important fossils in the Williams Fork Formation, the BLM has assigned a PFYC 

system rating of 5 (BLM 2010). The Lewis Shale that outcrops within the mine permit area has a PFYC 

rating of 3. TMI reports minimal fossil finds (Hinkemeyer 2015). No pre-blasting paleontological surveys 

have been performed so information on actual fossil yield is limited. 

3.17 Access and Transportation 

Trapper Mine is located approximately six miles (9.7 km) south of the City of Craig. The primary access 

to the mine is from U.S. Highway 40 (east-to-west route) to SH 13 (north-to-south route). SH 394 (eastto-west route) runs from Craig eastward and is located east of the Trapper Mine. The 2014 Annual 

Average Daily Traffic (AADT) count (Colorado Department of Transportation [CDOT] 2015) for U.S. 

Highway 40 varies depending on which side of the intersection with SH 394 counts are taken. West of 

the intersection, the AADT is 5,200 vehicles of which 8.7 percent are commercial-size trucks. East of the 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-85 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

intersection the AADT increases to 7,200, with 5.3 percent commercial-size trucks. The 2014 AADT for 

SHs 13 and 394 were recorded at 5,000 and 4,400 vehicles, respectively, with 8.6 and 3.6 percent, 

respectively, commercial-size trucks. Trapper Mine is accessed from CR 107 (off SH 13), which 

becomes a private road shortly after turning off SH 13. Other county roads that terminate at the mine 

permit boundary include CRs 35, 93, and 107, which terminate at locked gates. CR 33 runs adjacent to 

the eastern edge of the SMCRA permit boundary. CR 177 once led all the way to the Trapper Mine 

SMCRA permit boundary but has since been abandoned. 

Trapper Mine-related traffic outside of the SMCRA permit boundary typically consists of passenger 

vehicles for commuting to work and trucks delivering supplies to the mine. Coal is delivered from the 

Trapper Mine to the Craig Station via a private road. Trucks haul CCRs back to the mine for placement 

in areas outside of the Project Area via the same private road. That road is located partially within the 

SMCRA permit boundary and partially within the boundary of the Craig Station. The transport of coal 

from the mine to the power plant requires 27,368 truck trips per year. Deliveries of CCRs (fly ash) from 

the power plant to the mine require 9,858 truck trips per year (Air Resource Specialists 2015). The mine 

employs approximately 191 employees and operates seven days per week on 8-, 10-, and 12-hour shifts 

(TMI 2016). When shift changes occur, traffic necessary to transport employees to and from work occur 

over a condensed period of time. 

3.18 Solid Waste 

Solid waste is defined by the Resource Conservation and Recovery Act (RCRA) as a broad range of 

materials that include garbage, refuse, wastewater treatment plant sludge, non-hazardous industrial 

waste, hazardous waste, and other materials (solid, liquid, or contained gaseous substances) resulting 

from industrial, commercial, mining, agricultural, and community activities (USEPA 2011). Solid waste 

includes hazardous waste and non-hazardous waste and is regulated under different subtitles of RCRA. 

Non-hazardous waste is regulated under RCRA Subtitle D and hazardous waste is regulated under 

Subtitle C. 

The Trapper Mine generates mostly non-hazardous solid waste (TMI 1981 et seq.). The mine also 

generates small amounts of hazardous waste and is registered as a Conditionally Exempt Small 

Quantity Generator (USEPA 2015a). Under the generator requirements for a Conditionally Exempt Small 

Quantity Generator, no more than 2,200 pounds (1,000 kilograms) of hazardous waste can be stored 

onsite at any given time. The hazardous waste is disposed at permitted offsite facilities. 

Non-hazardous waste consists of lumber, concrete, tires, office waste, empty barrels, oil filters, and rags. 

Most of these materials can be disposed in pits under the SMCRA permit and under a landfill permit (or 

Certificate of Designation) that was granted by Moffat County in 1980 and 1981 and remains active. 

Scrap iron is recycled if it is recoverable. If it cannot be recovered, scrap iron is disposed as solid waste. 

Solid waste is hauled off site for disposal or placed in the on-site landfill. Petroleum wastes including 

waste oil and lubricants are recycled or blended into the mine’s petroleum supply. Shop wash that may 

contain small amounts of petroleum is directed through drains into a retention pond where oil is 

separated from the water and the water is allowed to be discharged (TMI 1981 et seq.). 

Another major waste stream is utility waste that is comprised of flyash, bottom ash, and scrubber sludge 

from the Craig Station. These utility wastes are generated from the burning of coal and are collectively 

referred to as CCRs. CCRs are placed into pits during backfilling or placed and encapsulated into spoil 

piles. The CCRs placement pits are located outside of the Project Area but represent a potential indirect 

effect as a result of the mining operation. An annual average of 507,000 tons of CCRs has been 

disposed at the mine since 1999 . The placement of CCRs into mine pits is regulated by rules of various 

agencies including the CDRMS, CDPHE, Moffat County, and the CSLB (TMI 1981 et seq.). The CDPHE 

has primacy from the USEPA for implementation of the RCRA rules. In order to conduct mine-filling, the 

CDRMS requires that applicants conduct a baseline groundwater study to describe the hydrologic 

setting, define the chemical and physical characteristics of the CCRs and overburden, and assess the 

leaching potential of the CCRs. The CCRs at Trapper Mine were subjected to leach testing and 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-86 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

determined to present a low potential for toxic metals to be leached from the materials (TMI 1981 et 

seq.). An assessment of the percolation rate of the groundwater also was conducted to determine the 

potential for the movement of contaminants if leaching of the material were to occur. The percolation 

analysis indicated that movement of any leached contaminants to groundwater would be very slow. In 

addition, the material would be less likely to leach because of relatively low permeability of the CCRs. 

Regulations require that the CCRs be isolated from surface and groundwater. The CCRs must be placed 

above the expected post-mining groundwater level and no less than 50 feet (15 meters) horizontally from 

surface drainages. The CCRs must be covered with a minimum of 6 feet (2 meters) of cover. 

Groundwater monitoring is required before and after CCRs are placed into pits. 

The USEPA revised disposal regulations for CCRs in 2015 and determined that CCRs would be 

regulated as non-hazardous waste under Subtitle D versus a hazardous waste under Subtitle C. 

Although CCRs will not be regulated as a hazardous waste, the USEPA has issued new requirements 

for existing CCRs landfills regarding certification, operating criteria, groundwater monitoring and 

corrective action, and closure and post-closure care. However, according to the USEPA, “the final rule 

does not apply to CCRs placed in active or abandoned underground or surface coal mines, consistent 

with the approach in the proposed rule” (USEPA 2015b). Management of the placement of CCRs in 

surface coal mines will be handled through separate regulatory actions by the DOI and USEPA, but the 

agencies are expected to work cooperatively to develop regulations that are protective of public health 

and the environment. 

TMI submits Toxic Release Inventory (TRI) reports to the USEPA each year mainly because of power 

plant CCRs that are disposed within the SMCRA permit boundary. The TRI reporting is required under 

Section 313 of the Emergency Planning and Community Right-to-Know Act Toxic Chemical Release 

Inventory. CCRs contain constituents that exceed, on an annual basis, the threshold reporting values for 

metallic compounds (USEPA 2015a). TMI falls under the “otherwise use” category of TRI reporting that 

includes on-site landfilling of CCRs and must report any TRI compound or chemical that is present in 

quantities that exceed 10,000 pounds, with the exception of mercury (which has a threshold reporting 

limit of 100 pounds) (USEPA 2000). Land disposal, even in a permitted landfill, is considered a release to 

the environment and therefore reportable under TRI. Other minor contributors to releases at the mine are 

particulate emissions to the air from the CCR hauling and placement which are discussed in Section 3.3. 

3.19 Noise 

The USEPA defines environmental noise as the amplitude, duration, and the character of sounds from 

all sources. Noise can be considered objectionable based on intermittence, beat frequency, shrillness, 

and level. Noise is measured in a logarithmic unit called the decibel (dB), and is most often measured in 

A-weighted decibels dB(A). A-weighted decibels are most closely related to human perception of noise 

due to the removal of low frequency sound that is less perceivable to human auditory senses. 

Many factors affect outdoor noise propagation and reception including manmade features, environments, 

and terrain. Vegetation can play a noticeable role in how efficiently sound travels in open environments. 

Dense trees and large shrubs can reduce noise levels substantially, while lakes and ponds can enhance 

acoustical propagation over long distances. Terrain that is flat with hard groundcover allows sound to 

travel relatively unobstructed. Hilly terrain and soft ground cover can reduce sound levels over distance. 

Barriers and berms can be constructed to reduce noise associated with highways and some types of 

industrial, mining, and power generating activities. 

Ambient noise is the noise present in any given environment and is often unnoticed. Noticeable noise 

levels can be considered a nuisance, such as traffic or loud music, especially if the noise interferes with 

or disrupts noise-sensitive activities, such as sleep, learning, entertainment, or enjoyment of outdoor 

activities. Noise can become damaging at levels exceeding 85 dB(A). At this level, noise can cause a 

loss of hearing if exposure occurs over extended periods. If noise levels reach 150 dB(A), eardrums can 

rupture. Example noise levels are outlined in 10 dB(A) intervals in Table 3-22 (CDOT 2015). 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-87 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-22 Example Noise Sources and Sound Levels 

Noise Source 

Sound 

Level dB(A) Noise Source 

Sound 

Level dB(A) 

Threshold of Hearing 0 Freeway Traffic at 50 feet 70-80 

Remote Outdoor Location (no wind) 20-30 Heavy Truck/Motorcycle at 25 feet 85-95 

Living Room 35-45 Shouting at 5 feet 95-105 

Quiet Neighborhood 45-55 Commercial Jet 110-120 

Conversational Speech at 5 feet 55-65 

The State of Colorado has a noise statute that outlines the maximum permissible noise levels for land 

use zoning as shown in Table 3-23. In addition to these levels, noise can exceed the maximum sound 

levels by 10 dB(A) for up to 15 minutes in a 1-hour period. Periodic, impulsive, or shrill noises are 

considered a nuisance when the dB(A) level is 5 dB lower than the levels in Table 3-23 

(CRS 25-12-103). 

Table 3-23 Colorado Maximum Permissible Noise Levels 

Zone 

Maximum Sound Level dB(A) 

7:00 AM to 7:00 PM 7:00 PM to 7:00 AM 

Residential 55 50 

Commercial 60 55 

Light Industrial 70 65 

Industrial 80 75 

Ambient noise for the Project Area includes environmental natural sources such as wind and wildlife as 

well as manmade noise sources such as existing mining activity, nearby roads, rail lines, and aircraft 

overflights. In addition, the Project Area is used for oil and gas production activities which contribute to 

ambient levels. Current mining activities that contribute noise include pit and surface types of mining, 

haul road traffic, and reclamation activities. The nearest sensitive noise receptor is an individual home 

that is 0.46 mile (0.74 km) from the major haul road and 0.86 mile (1.4 km) from the L Pit and most 

recent reclamation areas. The next closest sensitive receptor is more than one mile (1.6 km) from the 

Project Area. 

Major noise emissions from the Project would be equipment associated with surface mining and 

reclamation activities. Such equipment is listed in Table 3-24 with the associated noise levels. 

Equipment noise includes scraping and dumping of materials, backup alarms, blast warning sirens, and 

large engines. Not all equipment operates in tandem and additional noise sources are present including 

impulsive noise from blasting within the mine pit. 

Table 3-24 Open Pit Mining Equipment Noise Levels 

Noise Source 

Noise Level 

dB(A)1 Noise Source 

Noise 

Level 

dB(A)1 

Draglines 92 Water Trucks 68 

Overburden/Parting Drills 84 Fuel and Lube Trucks 68 

Track Dozers 99 35-ton Crane 97 

Rubber Tired Dozers 85 Backhoe 80 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-88 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

Table 3-24 Open Pit Mining Equipment Noise Levels 

Noise Source 

Noise Level 

dB(A)1 Noise Source 

Noise 

Level 

dB(A)1 

Motor Graders 85 Service Truck 65 

Scrapers 85 Pickups/SUVs 55 

Hydraulic Excavators 84 Farm Tractors 84 

Front-end Loaders 79 Tractor and 200-ton Lowboy Trailer 91 

Coal Drills 98 Compactor 80 

Haul Trucks (240-, 95-, and 55-ton) 84 

1 Federal Highway Administration 2015; Sensogut 2007; Suter 2002. 

Trapper Mine and the Project Area are located in a nonresidential, undeveloped area. This area has hilly 

terrain with small valleys becoming flat to the north. To the south and east, large hills and valleys occur 

for miles, and the Yampa River is approximately 4.5 miles (7.2 km) south. Directly west of the Project 

Area, reclamation exists from past mining and occurs on slopes. Reclamation vegetation consists 

mainly of grasses and small shrubs. 

Noise levels within the Project Area would increase with proximity to active mining areas. The degree of 

increase at any one location would depend on the distance from the source, ambient noise levels, and 

factors influencing acoustical propagation, such as obstructions or acoustically absorptive ground cover. 

The various stages of the mining process require different equipment to be in use. The type and number 

of equipment used at any one time would produce varying noise levels. Mining noise transmission also 

would be limited by the mining activities. The depth of mining within the pit creates a barrier for noise as 

mining activities go deeper creating a natural wall between active mining and the environment. 

Reclamation is being performed on the western side of the mine as extraction opportunities move 

eastward. These activities include contouring the land surface, replacing topsoil, grading, and reseeding. 

Reclamation occurs at grade and contributes to mining noise. Traffic from haul roads also contribute to 

noise production in the area. 

3.20 Livestock Grazing 

There is minimal active livestock grazing within the Project Area or within the active mining areas of the 

SMCRA permit boundary. Private livestock grazing does occur on TMI-owned lands which have had 

Phase 3 bond release within the SMCRA permit boundary and on TMI-owned lands outside and 

adjacent to the SMCRA permit boundary. 

The BLM is responsible for managing portions of public lands for livestock grazing by permitting animal 

unit months in designated grazing allotments. One of the primary land uses within the LSFO is livestock 

grazing. Sheep and cattle have historically grazed along north-facing slopes where the vegetation is 

more plentiful due to greater soil moisture relative to soil on south-facing slopes. There are no BLM 

administered grazing allotments within the Project Area; however, three allotments are immediately 

adjacent to the permitted boundary. They are the South Big Bottom, East Ute Gulch, and the Upper 

Castor Gulch allotments. The South Big Bottom Allotment supports four cattle during the month of May 

on 80 acres, the East Ute Gulch Allotment supports 19 cattle from late May through October 31 on 

1,462 acres, and the Upper Castor Gulch Allotment supports 12 cattle from early June to mid-November 

on 468 acres (GeoCommunicator 2015). 

Surface disturbance would not affect any of the adjacent BLM allotments or their animal unit month 

production as mining activities would not occur within the allotments. The prevailing wind direction is 

from the southwest; therefore, fugitive dust emissions would be blown away from the allotments to the 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-89 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

northeast the majority of the time. Because of the lack of public grazing lands within or adjacent to the 

Project Area, grazing was not carried forward for further analysis in this EA. 

3.21 Prime Farmlands 

The CSCMRA (CRS 34-33-101 et seq.) requires surface coal mining and reclamation applicants to 

conduct a reconnaissance inspection within the SMCRA permit area for the existence of prime farmland 

historically used for cropland and submit the results to the U.S. Soil Conservation Service. Prime 

farmland is defined by the USDA as land that has the most beneficial combination of physical and 

chemical characteristics for the production of food, feed, fiber, and oilseed crops and is available for use 

(USDA 2015). The physical and chemical characteristics typically include acidity/alkalinity, sodium 

content, soil moisture and permeability, erosion potential, slope, and length of the growing season 

(USDA 2015). 

In the Proposed Decision and Finding of Compliance for the Trapper Mine PR07 (CDRMS 2015) the 

CDRMS determined that no areas of prime farmland currently exist within the SMCRA permit area 

including within the Project Area. Therefore prime farmlands were not carried forward in this EA. 

3.22 Alluvial Valley Floors 

The CSCMRA (CRS 34-33-101 et seq.) defines alluvial valley floors (AVFs) as unconsolidated streamlaid deposits holding streams where water availability is sufficient for subirrigation or flood irrigation 

agricultural activities. This does not include upland areas overlain by colluvial deposits composed chiefly 

of debris from sheet erosion, deposits by unconcentrated runoff or slope wash, together with talus, other 

mass movement accumulation, and wind-blown deposits. The CSCMRA prohibits surface coal mining 

operations from interrupting, discontinuing, or precluding farming on alluvial valley floors that are irrigated 

or naturally subirrigated, excluding undeveloped range lands which are not significant to farming on said 

alluvial valley floors and those lands upon which the Colorado Mined Land Reclamation Board finds that 

the farming which would be interrupted, discontinued, or precluded is of such small acreage as to be of 

negligible impact on said land’s agricultural production. The CSCMRA further prohibits surface coal 

mining operations from materially damaging the quantity and quality of surface water and groundwater 

systems that supply alluvial valley floors. These prohibitions do not apply to those surface coal mining 

operations which in the year preceding August 3, 1977, either produced coal in commercial quantities 

and were located within or adjacent to alluvial valley floors or had obtained permit approval to conduct 

surface coal mining operations within said alluvial valley floors. The CSCMRA further requires that 

surface coal mining and reclamation operations preserve throughout the mining and reclamation 

processes the essential hydrologic functions of alluvial valley floors. The CSCMRA allows surface coal 

mining and reclamation permit applicants that propose to operate in or adjacent to a valley holding a 

stream or any streams to request the regulatory authority to submit a written alluvial floor determination 

with respect to the valley floor. The determination is based on available data, field studies, or a 

combination of available data and field studies. 

In the Proposed Decision and Finding of Compliance for the Trapper Mine PR07 (CDRMS 2015) the 

CDRMS determined that there are two alluvial valleys that meet the AVF criteria: the Yampa River in the 

Big Bottom area and the Williams Fork River near its confluence with the Yampa River. Due to a lack of 

adequate available water for crop production, the Flume, Johnson, No Name, and Pyeatt gulches have 

been determined to not have AVFs. This also applies to a 20-acre portion of the upper Flume Gulch that 

was previously determined to contain an AVF. 

Impacts to the Yampa River AVF were determined to be negligible by the CDRMS. Drainages that flow 

from the SMCRA permit area to the Yampa River AVF contribute very little surface water to the Yampa 

River (approximately 0.07 cfs per square mile) and the groundwater contribution is so minor that it is 

undetectable (CDRMS 2015). The greatest contributor of water to the Yampa River AVF is the Yampa 

River, which loses water to the AVF as it flows past the Trapper Mine. Additionally, surface disturbing 

activities associated with the Trapper Mine occur at least one mile (1.6 km) from the southern boundary 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-90 
 

 

 

 

 

 

 

 

 

 

Chapter 3.0 – Affected Environment 

of the AVF. For these reasons the CDRMS determined that no activities within the Trapper Mine permit 

boundary would impact farming on the Yampa River AVF. 

Impacts to the Williams Fork River also were determined to be negligible by the CDRMS. The Williams 

Fork River is located to the south of the proposed permit area. Surface water that flows from the Trapper 

Mine is limited almost exclusively to spring snowmelt. Any discharge from sediment ponds would flow 

down the drainages and infiltrate the permeable Twentymile Sandstone outcrop, which dips northward 

away from Williams Fork River and underneath Trapper Mine leaving almost no chance for surface or 

subsurface flow to reach the Williams Fork River (CDRMS 2015). Additionally, water in the sediment 

ponds is typically evaporated. Therefore, the CDRMS determined that no activities within the Trapper 

Mine SMCRA permit boundary would impact farming on the Williams Fork River AVF. Because neither 

AVF would be affected by the Trapper Mine, AVFs were not carried forward in this EA. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-91 
 

Chapter 3.0 – Affected Environment 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

3-92 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

4.0 Environmental Consequences1 

4.1 Introduction 

This chapter discusses the potential direct and indirect effects of Alternative A - the Proposed Action, 

and Alternative B - Disapproval of the Mining Plan Modification by the ASLM. Alternative C - the No 

Action Alternative, is not evaluated in detail because the environmental consequences of Alternative C 

would fall within the range of impacts described for Alternative A and Alternative B, depending on when 

Alternative C is implemented. Each of these alternatives is described in Chapter 2.0. The information 

about the existing condition of the environment from Chapter 3.0 was used as a baseline to measure and 

identify potential impacts from the project. Mitigation measures also were considered and incorporated, 

including current mitigation measures being practiced by TMI, as well as potential future mitigation 

measures, as appropriate. 

Direct impacts are defined as those impacts that are caused by the action and occur at the same time 

and place (40 CFR 1508.8(a)). Indirect impacts are those that are caused by the action and occur later in 

time or are farther removed in distance, but are still reasonably foreseeable (40 CFR 1508.8(b)). 

An impact, or effect, is defined as a modification to the environment brought about by an outside action. 

Impacts vary in significance from no change, or only slightly discernible change, to a full modification or 

elimination of the resource. Impacts can be beneficial (positive) or adverse (negative). Impacts are 

described by their level of significance (i.e., major, moderate, minor, negligible, or no impact). For 

purposes of discussion and to enable use of a common scale for all resources, resource specialists 

considered the following impact levels in qualitative terms. 

•	 Major Impact: Impacts that potentially could cause irretrievable loss of a resource; significant 

depletion, change, or stress to resources; or stress within the social, cultural, and economic 

realm. 

•	 Moderate Impact: Impacts that potentially could cause some change or stress to an
	

environmental resource but the impact levels are not considered significant.
	

•	 Minor Impact: Impacts that potentially could be detectable but slight. 

•	 Negligible Impact: Impacts in the lower limit of detection of an effect, that potentially could cause 

an insignificant change or stress to an environmental resource or use. 

•	 No Impact: No discernible or measurable impacts. 

Impacts can be short-term meaning these impacts generally occur over a short period during a specific 

point in the mining process and these changes generally revert to pre-disturbance conditions at or within 

a few years after the ground disturbance has taken place. Long-term impacts are defined as those that 

substantially would remain beyond short-term ground-disturbing activities. Long-term impacts would 

generally last the life of the Project and beyond. 

The impact analysis applies quantitative thresholds when available, to determine the level of 

significance. Some resource areas are more conducive to quantification than others. For example, 

impacts on vegetation can be characterized partly using acreage, and air quality can be measured 

against air quality standards. Evaluations of some resources are inherently difficult to quantify with 

1 Italicized text denotes language inserted either in response to comments received on the EA (see Appendix E) or to clarify or 

update a topic based on new or additional information received. Each place where italicized text appears is denoted by a bar in 

the left hand margin. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-1 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

exactitude. In these cases, levels of impact are based on best available information and professional 

judgment. 

Several resource topics that were discussed in Chapter 3.0 are not discussed in this chapter because 

these resources do not occur in the study area or are not affected by the alternatives. These resource 

topics include Environmental Justice, Recreation, Livestock Grazing, Prime Farmlands and Alluvial 

Valley Floors. For additional information on these resources refer to Table 3-1 and the resource-specific 

discussions in Chapter 3.0. Cumulative effects of the alternatives are discussed in Chapter 5.0. 

4.1.1 Summary of Direct and Indirect Environmental Impacts 

Table 4-1 summarizes and compares the potential direct and indirect environmental impacts associated 

with Alternative A, the Proposed Action and Alternative B, Disapproval of the Mining Plan Modification by 

the ASLM. Alternative C, the No Action Alternative is also shown on the table with the range of potential 

impacts. 

Table 4-1 Comparison of Direct and Indirect Impacts 

Resource 

Alternative A – Proposed 

Action 

Alternative B – 

Disapproval of the 

Mining Plan 

Modification by the 

ASLM 

Alternative C – No 

Action 

Topography After reclamation, direct 

impacts to topography 

would be negligible in the 

long term. 

There would be no indirect 

impacts to topography. 

Same as Alternative A. Same as Alternative A. 

Air and Climate Resources 

Direct mining criteria 

emissions 

In the worse-case mining 

year (Year 2020) direct 

mining emissions are 

below NAAQS standards 

for PM10/PM2.5 and 

combustion emissions 

(NOX, SO2, CO, and VOCs) 

and impacts to air quality 

would be short-term during 

the life of mining and 

negligible. 

Direct mining emissions 

would be reduced by 

approximately 40 percent 

based on the expected 

reduced mining rate and 

would continue to be 

below the standards. 

Impacts to air quality 

would be short-term 

during the life of mining 

and negligible. 

Direct mining emissions 

would range from those 

outlined for Alternative A 

to a reduction of 

approximately 40 percent 

based on the reduced 

mining rate of 

Alternative B. These 

impacts would be shortterm during the life of 

mining and negligible. 

Direct GHG emissions GHG emissions from 

mining would be 

approximately 482,014 

metric tons CO2e in the 

worst-case year (2020). 

When compared to state 

and national GHG 

emissions, the direct GHG 

emissions would represent 

less than 0.4% of the 2010 

Colorado GHG emissions 

and less than 0.007% of 

the 2007 nationwide GHG 

emissions. GHG impacts 

would be negligible and 

long-term but additional 

Direct GHG emissions 

would be reduced by an 

estimated 40 percent 

based on the expected 

reduced mining rate. 

GHG impacts would be 

negligible and long-term 

but additional 

contributions would cease 

after mining ceases. 

GHG emissions would 

range from a maximum of 

482,014 metric tons CO2e 

to approximately 

40 percent less than that 

number based on a 

reduced mining rate of 

Alternative B. These 

impacts would be 

negligible and long-term 

but additional 

contributions would cease 

after mining ceases. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-2 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Table 4-1 Comparison of Direct and Indirect Impacts 

Resource 

Alternative A – Proposed 

Action 

Alternative B – 

Disapproval of the 

Mining Plan 

Modification by the 

ASLM 

Alternative C – No 

Action 

contributions would cease 

after mining ceases. 

Indirect coal combustion 

criteria emissions 

Emissions from Craig 

Station attributable to 

Trapper Mine coal would 

be 97.8 tpy PM10, 60.9 tpy 

PM2.5, 1,567 tpy SO2, 7,445 

tpy NOX, 650 tpy CO, and 

78 tpy VOCs. Following 

installation of improved 

emissions controls for NOX 

expected emissions 

attributable to Trapper 

Mine would be 1,145 tpy. 

Craig Station is currently in 

compliance with all 

applicable emission 

standards. The emissions 

attributable to Trapper 

Mine would be short term 

occurring over the life of 

the mine and would be 

negligible. 

Emissions from Craig 

Station attributable to 

Trapper Mine coal would 

be reduced by an 

estimated 40 percent 

based on the expected 

reduced mining rate; 

however, overall 

emissions from the Craig 

Station would remain 

unchanged. The 

emissions attributable to 

Trapper Mine would be 

short term occurring over 

the life of the mine and 

would be negligible. 

Indirect coal combustion 

emissions attributable to 

Trapper Mine coal would 

range from those outlined 

in Alternative A to an 

estimated 40 percent 

reduction based on the 

reduced mining rate of 

Alternative B. The 

emissions attributable to 

Trapper Mine would be 

short term occurring over 

the life of the mine and 

would be negligible. 

Indirect combustion 

emissions from transport 

and placement of CCRs 

Emissions from transport 

and placement of CCRs 

from Craig Station at 

Trapper Mine would be 

12.80 tpy PM10, 2.30 tpy 

PM2.5, 12.1 tpy NOX, 1.5 

tpy SO2, 5.15 tpy CO, and 

0.7 tpy VOCs. The 

emissions attributable to 

Trapper Mine would be 

short term occurring over 

the life of the mine and 

would be negligible. 

Combustion emissions 

attributable to the 

transport of CCRs from 

Trapper Mine coal would 

be reduced by an 

estimated 40 percent 

based on the reduced 

coal delivery rate; 

however, overall 

combustion emissions 

from CCRs transport 

would remain unchanged. 

The emissions 

attributable to Trapper 

Mine would be short term 

occurring over the life of 

the mine and would be 

negligible. 

Indirect coal combustion 

emissions from the 

transport and placement 

of CCRs attributable to 

Trapper Mine coal would 

range from those outlined 

in Alternative A to an 

estimated 40 percent 

reduction based on the 

reduced mining rate of 

Alternative B. The 

emissions attributable to 

Trapper Mine would be 

short term occurring over 

the life of the mine and 

would be negligible. 

Indirect combustion GHG 

emissions 

Indirect GHG emissions 

from coal combustion and 

transport of CCRs to 

placement location would 

be 5,342,951 tpy which 

represents approximately 

4.1 percent of total 

Colorado GHG emissions 

based on 2010 data and 

0.07 percent of national 

Indirect GHG emissions 

attributable to combustion 

of Trapper Mine coal and 

transport of CCRs would 

be reduced by an 

estimated 40 percent 

based on the reduced 

mining rate, but overall 

GHG emissions from 

Craig Station would 

Indirect GHG emissions 

from the combustion of 

Trapper Mine coal and 

transport and placement 

of CCRs would range 

from those outlined in 

Alternative A to an 

estimated 40 percent 

reduction based on the 

reduced mining rate of 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-3 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Table 4-1 Comparison of Direct and Indirect Impacts 

Resource 

Alternative A – Proposed 

Action 

Alternative B – 

Disapproval of the 

Mining Plan 

Modification by the 

ASLM 

Alternative C – No 

Action 

emissions based on 2007 

data. GHG impacts would 

be negligible and long-term 

but additional contributions 

would cease after mining 

ceases. 

continue at the same rate. 

GHG impacts would be 

negligible and long-term 

but additional 

contributions would cease 

after mining ceases. 

Alternative B. The 

emissions attributable to 

Trapper Mine would be 

negligible and long-term 

but additional 

contributions would cease 

after mining ceases. 

Indirect coal combustion 

mercury emissions 

Indirect mercury emissions 

from coal combustion at 

the Craig Station 

attributable to Trapper 

Mine coal would be 8.23 

pounds per year (lb/yr) at 

the maximum mining rate 

of 2.6 mtpy. Impacts as a 

result of these mercury 

emissions are discussed 

below under indirect 

impacts to the yellow-billed 

cuckoo and Colorado River 

fish. 

Indirect mercury 

emissions from 

combustion of Trapper 

Mine coal would be 

reduced by an estimated 

40 percent due to the 

reduced mining rate but 

overall mercury emissions 

from coal combustion at 

the Craig Station would 

remain unchanged. 

Impacts as a result of 

these mercury emissions 

are discussed below 

under indirect impacts to 

the yellow-billed cuckoo 

and Colorado River fish. 

Indirect mercury 

emissions from the 

combustion of Trapper 

Mine coal would range 

from those outlined in 

Alternative A to an 

estimated 40 percent 

reduction based on the 

reduced mining rate of 

Alternative B. Impacts as 

a result of these mercury 

emissions are discussed 

below under indirect 

impacts to the yellowbilled cuckoo and 

Colorado River fish. 

Geology and Minerals Negligible to minor longterm impact to the overall 

geologic column by 

eliminating the column in 

the pit areas; no impact to 

mining of other minerals. 

Same as Alternative A. Same as Alternative A. 

Water Resources 

Direct Surface Water 

Impacts 

Negligible short- and longterm potential for direct 

impacts to surface water 

from changes in mine 

drainage patterns, 

sediment releases, spills, 

release of iron, selenium, 

and TDS. 

Same as Alternative A. Same as Alternative A. 

Indirect Surface Water 

Impacts 

Indirect impacts to the 

Yampa River from mercury 

releases from the Project 

Area and from coal 

combustion emissions 

cannot be determined 

based on existing 

information. Water 

diversion for use at Craig 

Station would have a 

negligible to minor longSame as Alternative A. Same as Alternative A. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-4 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Table 4-1 Comparison of Direct and Indirect Impacts 

Resource 

Alternative A – Proposed 

Action 

Alternative B – 

Disapproval of the 

Mining Plan 

Modification by the 

ASLM 

Alternative C – No 

Action 

term impact on instream 

flows in the Yampa River. 

Direct Groundwater 

Impacts 

Negligible short- and longterm impacts to 

groundwater aquifers as a 

result of disruption during 

mining; negligible long-term 

impacts to water quality or 

quantity of springs in the 

Project Area vicinity; 

avoidance of impacts to 

senior water users through 

implementation of a water 

augmentation plan for 

water uses within the 

Project Area. 

Same as Alternative A. Same as Alternative A. 

Indirect Groundwater 

Impacts 

Negligible long-term 

impacts to groundwater as 

a result of placement of 

coal combustion residuals 

within the SMCRA Permit 

Boundary. Negligible 

indirect impacts to the 

Yampa River from 

discharges of sediment or 

iron from the Project Area. 

Same as Alternative A. Same as Alternative A. 

Soils Negligible long-term 

impacts to soil resources 

upon completion of 

reclamation activities. 

Same as Alternative A. Same as Alternative A. 

Vegetation Impacts to vegetation 

would be minor and longterm until reclamation is 

complete. 

Same as Alternative A. Same as Alternative A. 

Wetlands No additional wetlands 

disturbance would occur. 

The N Pit has been 

previously disturbed so 

there would be no new 

wetlands disturbance 

from re-mining in that pit. 

Detailed wetlands 

mapping has not occurred 

within the I Pit area so 

impacts to wetlands are 

unknown. 

There would be no 

impacts from ongoing 

activities in the Project 

Area. If the approval is 

vacated, impacts from 

mining outside the Project 

Area in the I Pit are not 

known as detailed 

wetlands mapping has 

not occurred for this area. 

Fisheries and Wildlife 

Direct Wildlife Impacts Impacts to wildlife would be 

mitigated by 

contemporaneous 

reclamation, enforcement 

Same as Alternative A. Same as Alternative A. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-5 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Table 4-1 Comparison of Direct and Indirect Impacts 

Resource 

Alternative A – Proposed 

Action 

Alternative B – 

Disapproval of the 

Mining Plan 

Modification by the 

ASLM 

Alternative C – No 

Action 

of posted speed limits, and 

in the case of some 

species, the limited habitat 

available within the Project 

Area. Short-term negligible 

impacts to big game and 

migratory birds; short-term, 

minor impacts to raptors, 

small mammals, and 

reptiles 

Direct Fisheries Impacts No direct impact to 

fisheries since there are no 

fish present in Project Area 

streams. 

Same as Alternative A. Same as Alternative A. 

Indirect Fisheries Impacts 

due to mining 

Indirect impacts to fisheries 

from water quality 

discharges from the 

Trapper Mine would be 

short- and long-term and 

negligible based on the 

existing sediment control 

system and spill prevention 

and mitigation measures. 

Indirect impacts to 

Colorado River fishes as a 

result of mercury and 

selenium emissions cannot 

be quantified based on the 

available data. 

Same as Alternative A. Same as Alternative A. 

Special Status Species 

Direct Impacts No or negligible short-term 

impacts to state and BLM 

listed special status 

species including northern 

leopard frog, golden eagle, 

burrowing owl, ferruginous 

hawk, Brewer’s sparrow. 

Minor short-term impacts to 

Columbian sharp-tailed 

grouse due to loss of 

production area within the 

Project Area. In the longterm reclamation will 

improve Columbian sharptailed grouse habitat over 

the pre-mining conditions. 

Same as Alternative A. Same as Alternative A. 

Indirect Impacts to 

Colorado River Fishes 

It is not possible to quantify 

the amount of mercury 

which endangered fish 

would be exposed to or the 

Although the emissions 

attributable to Trapper 

Mine coal would be 

reduced based on the 

The mercury emissions 

attributable to Trapper 

Mine coal would range 

from current levels to 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-6 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Table 4-1 Comparison of Direct and Indirect Impacts 

Resource 

Alternative A – Proposed 

Action 

Alternative B – 

Disapproval of the 

Mining Plan 

Modification by the 

ASLM 

Alternative C – No 

Action 

impact as a result of that 

mercury exposure. 

reduced mining rate, it is 

assumed that Craig 

Station would continue to 

operate at current levels, 

obtaining coal from 

another source. It is not 

possible to quantify the 

amount of mercury which 

endangered fish would be 

exposed to or the impact 

as a result of that mercury 

exposure. 

levels based on a 

reduced mining rate of 

Alternative B. It is not 

possible to quantify the 

amount of mercury which 

endangered fish would be 

exposed to or the impact 

as a result of that mercury 

exposure. 

Indirect Impacts to Yellowbilled cuckoo It is not possible to 

determine the severity of 

impacts to yellow-billed 

cuckoos from either 

mercury or selenium 

emissions from coal 

combustion due to lack of 

information. 

Coal combustion 

emissions would continue 

under Alternative B but 

the amount attributable to 

Trapper mine would be 

reduced based on the 

reduced mining rate. The 

impacts cannot be 

quantified at this time due 

to lack of information. 

Emissions from coal 

combustion would range 

from current emissions 

attributable to Trapper 

Mine coal to a reduced 

emissions based on the 

reduced mining rate of 

Alternative B. The 

impacts cannot be 

quantified at this time due 

to lack of information. 

Cultural Resources As long as TMI complies 

with recommendations for 

the Rock Art Site 

mitigation, no impacts are 

anticipated to cultural 

resources. 

The area of the N Pit has 

been previously disturbed 

so there would be no new 

impacts. Due to the lack 

of detailed mining plans 

for the I Pit, impacts 

cannot be fully quantified, 

There would be no 

impacts from continued 

mining within the Project 

Area as in Alternative A. 

For mining in areas 

outside of the Project 

Area as in Alternative B, 

there would be no new 

impacts from mining in 

the N Pit but the area of 

impact for the N Pit has 

not been fully defined and 

impacts cannot be 

quantified. 

Socioeconomics There are beneficial 

socioeconomic impacts 

locally, regionally and 

state-wide from continued 

mining at the Trapper Mine 

over the 10-year life-ofmine. 

Mining would continue in 

areas outside of the 

Project Area so 

socioeconomic benefits 

also would continue until 

mining ceases but would 

be reduced due to the 

reduced mining rates and 

reduced timing for 

completion of mining 

(three to four years). 

The beneficial 

socioeconomic impacts 

would continue over the 

life-of-mine for the Project 

Area, estimated at 10 

years. If mining does not 

continue within the 

Project Area, under 

Alternative B mining 

would continue to provide 

socioeconomic benefits 

but these benefits would 

be reduced by six to 

seven years due to the 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-7 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Table 4-1 Comparison of Direct and Indirect Impacts 

Resource 

Alternative A – Proposed 

Action 

Alternative B – 

Disapproval of the 

Mining Plan 

Modification by the 

ASLM 

Alternative C – No 

Action 

reduced mining rate and 

reduced timing for 

completion of mining. 

Visual Resources Negligible to minor shortterm visual impacts over 

the life of the mine. 

Lighting from mining 

activities creates a minor 

short-term impact over the 

life of the mining operation. 

Same as Alternative A. Same as Alternative A. 

Paleontology Negligible, long-term 

impacts due to loss of 

paleontological resources 

There could be beneficial 

impacts from exposing 

paleontological resources 

for discovery. 

Same as Alternative A. Same as Alternative A. 

Access and 

Transportation 

No changes to current 

access and transportation. 

Access and transportation 

numbers could be 

somewhat reduced due to 

the reduced mining rate. 

The reduction would be 

short-term and minor 

during mining operations. 

Impacts could range from 

no change if the existing 

mining operations 

continue as in 

Alternative A, to shortterm minor impacts if 

mining ceases in the 

Project Area and mining 

outside the Project Area 

as in Alternative B results 

in a reduced mining rate 

with associated reduction 

in employees and 

deliveries. 

Solid Waste 

Direct Impacts from Solid 

Waste Generation and 

Disposal 

No direct impacts from 

solid waste disposal. 

Same as Alternative A. Same as Alternative A. 

Indirect Impacts from 

Placement of CCRs 

Negligible long-term 

impacts with placement in 

accordance with approved 

plans and reclamation 

upon completion of 

placement in an area. 

Same as Alternative A as 

CCRs placement would 

continue at the Trapper 

Mine. 

Same as Alternative A. 

Noise Depending on the location 

of the mine pit, the closest 

residence ranges from 

0.46 to 0.7 mile (0.7 km to 

1.1 km) from mining 

activities. Short-term, 

negligible impacts, until 

reclamation is complete 

Closest residence to the 

proposed I Pit is 

approximately 0.66 mile 

(1 km). Impacts would be 

the same as 

Alternative A, until 

reclamation is complete 

and heavy equipment is 

The closest residence 

would vary depending on 

when mining ceases, 

however, impacts would 

be the same as 

Alternative A. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-8 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Table 4-1 Comparison of Direct and Indirect Impacts 

Resource 

Alternative A – Proposed 

Action 

Alternative B – 

Disapproval of the 

Mining Plan 

Modification by the 

ASLM 

Alternative C – No 

Action 

and heavy equipment is no 

longer operating in the 

area. 

no longer operating in the 

area. 

4.2 Topography 

4.2.1 Alternative A – Proposed Action 

4.2.1.1 Direct Impacts 

Approximately 257 acres of previously undisturbed lands would be disturbed within the Project Area, and 

11 acres of previously disturbed and reclaimed land would be re-disturbed within the Project Area, 

disrupting the existing topography during mining. In addition, there are 1,053 acres of currently disturbed 

land within the Project Area. All areas previously disturbed and to be disturbed in the future would be 

contemporaneously reclaimed through backfilling and grading to the approved post-mining topography 

and establishment of surface drainage patterns per the approved reclamation plan. After reclamation has 

been completed, the long-term impacts to topography would be negligible. 

4.2.1.2 Indirect Impacts 

There would be no indirect impacts to topography under Alternative A. 

4.2.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM 

4.2.2.1 Direct Impacts 

Under Alternative B, mining in the Project Area would cease and closure and reclamation would be 

initiated. The additional 257 acres of new disturbance and 11 acres of re-disturbance would not occur. 

The existing 1,053 acres of disturbance would be reclaimed to the approved post-mining topography. It 

is anticipated that mining would occur in areas outside of the Project Area in the N and I pits. This mining 

would occur over a time period of three to four years which is shorter than the proposed Project life-ofmine of approximately 10 years. The short-term impacts to topography would occur in a different area 

within the SMCRA permit boundary but would be similar to those under Alternative A. Under 

Alternative B mining would cease and final reclamation would occur earlier. After reclamation has been 

completed, the long term impacts to topography would be negligible. 

4.2.2.2 Indirect Impacts 

There would be no indirect impacts to topography under Alternative B. 

4.2.3 Mitigation Measures 

No mitigation measures would be necessary for topography. 

4.3 Air and Climate Resources 

4.3.1 Alternative A – Proposed Action Alternative 

The Trapper Mine EA addresses emissions associated with mining activities that are ongoing. As such, 

ongoing air quality and climate impacts are reflected in the baseline data described in the Affected 

Environment (Chapter 3.0). 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-9 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

4.3.1.1 Direct Emissions from Surface Coal Mining 

This section covers the direct air emissions associated with the proposed surface mining activities at the 

Trapper Mine within the Project Area. Direct emissions include the following: 

•	 PM10 and PM2.5 emissions associated with the Trapper Mine operations, including but not limited 

to, emissions from drilling, blasting, coal excavation and removal, overburden excavation and 

removal, and emissions from coal/overburden hauling on unpaved roads within the Project Area. 

•	 NOX, SO2, CO, and VOC emissions associated with fuel combustion in mining equipment and 

haul trucks. 

•	 Combustion emissions associated with blasting (i.e., NOX). 

•	 GHG emissions, including but not limited to fugitive CH4 releases from the coal mining seams 

and GHGs associated with fuel combustion in mining equipment and haul trucks. 

•	 Black carbon emissions associated with fuel combustion in mining equipment and haul trucks. 

O3 emissions and impacts are discussed in the Cumulative Impacts section (Chapter 5.0) as the 

contribution of individual source emissions to regional O3 levels cannot be accurately quantified. 

However, emissions of O3 precursors (NOX and VOCs) are quantified in this section. 

All calculated emissions used in the modeling of direct air quality impacts were quantified using the 

maximum allowable mining rate at the Trapper Mine based on TMI’s air quality permit (i.e., 2.6 mtpy). 

For PM10 and PM2.5, emissions were quantified for each year up to 2025 (when the coal reserves in the 

Project Area would be exhausted based on TMI’s proposed mining plans). CDRMS has only approved 

detailed mining plans through 2017, and additional regulatory review and approval by CDRMS would be 

required prior to mining through 2025. Based on the calculated PM10/PM2.5 emissions, a worst-case year 

was selected and the emissions from other pollutants were then evaluated for the selected worst-case 

year. As documented below, the worst-case emissions year was determined to be 2020. The Air and 

Climate Resources Technical Support Document (TSD) (Air Resource Specialists 2016) provides 

detailed information on the emissions inventory and modeling and is included as Appendix B. The TSD 

information is summarized below. 

Particulate Matter 

Particulate matter emissions (PM10 and PM2.5) occur from mining activities, as well as emissions 

associated with diesel fuel combustion in the mining equipment and trucks. Mining activities include 

drilling, blasting, coal and overburden removal and handling, and coal hauling by truck from the Trapper 

Mine to the adjacent Craig Station. 

PM10 and PM2.5 emission controls are imposed through the fugitive dust control plan contained in the 

Trapper Mine air emissions permit issued by the CDPHE on May 8, 2009 – Permit 11MF253-1, 

Modification 2 (CDPHE 2009). These emissions controls are summarized in the TSD (Appendix B). 

Table 4-2 summarizes the PM10 and PM2.5 emissions for each year through 2025 when the Trapper 

Mine coal reserves within the Project Area would be exhausted, based on the proposed mining plans 

and a peak production rate of 2.6 mtpy. Once the worst-case year was determined, the appropriate fuel 

combustion emissions were then added to the PM10/PM2.5 emission totals. 

The emissions calculations used standard USEPA factors for western surface coal mines from USEPA’s 

Compilation of Air Pollutant Emission Factors, or AP-42 (USEPA 2015a), combined with year-by-year 

projections of mine operations provided by TMI, to calculate the total PM10 and PM2.5 emissions. Details 

about the calculations are presented in the TSD (Appendix B). 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-10 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Table 4-2 Projected Trapper Mine PM10 and PM 2.5 Emissions through 

2025 

Mining Year 

PM10 Emissions 

(tpy) 

PM2.5 Emissions 

(tpy) 

2016 533.88 79.75 

2017 537.06 82.08 

2018 526.23 80.25 

2019 534.62 84.50 

2020 603.51 93.25 

2021 615.89 96.83 

2022 569.46 88.21 

2023 525.76 80.76 

2024 450.35 69.22 

2025 335.46 48.00 

Table 4-2 includes indirect emissions from CCRs disposal. The total PM10 and PM2.5 emissions
	

including CCRs disposal were evaluated to select the worst-case year.
	

Source: Air Resource Specialists 2016. 

Based on Table 4-2, the peak PM10/PM2.5 emissions would occur in Calendar Years 2020 and 2021. In 

the TMI proposed mining plans, both 2020 and 2021 would be years with higher than average stripping 

ratios, so the overburden volumes to be handled and transported within the mine pit and the associated 

air emissions are greater. However, the magnitude of the emissions between 2020 and 2021 would be 

virtually the same. 

The selection of the worst-case year also considered the relative location of the PM10/PM2.5 emissions 

based on TMI’s anticipated mining plans. Beginning in 2019, TMI’s anticipated mining plans would 

include mining in the N Pit. Only a fraction of the N Pit lies inside the Project Area. For worst-case year 

(2020), TMI’s anticipated mine plan would include mining in the N Pit outside of the Project Area and the 

associated N Pit emissions would primarily occur outside of the Project Area. However, in 2020, there 

would be a higher concentration of emissions in the L Pit, which is the current active Trapper Mine pit. 

The L Pit also would be closer to the eastern SMCRA permit boundary in 2020 and the separation 

distance between the emissions location and ambient air would be less. For these reasons, 2020 was 

selected as the worst-case year for the air quality analysis as it would be likely to produce higher air 

quality impacts to nearby ambient air. 

A more detailed PM10/PM2.5 inventory for the worst-case year (2020) is summarized in Table 4-3 based 

on emissions calculated in the TSD (Appendix B). 

Table 4-3	 Worst-Case Year (2020) Trapper Mine PM10 and PM2.5 Direct
 

Emissions
 

Mining Operation PM10 (tpy) PM2.5 (tpy) 

Drilling: Coal & Overburden 0.98 0.98 

Blasting: Coal & Overburden 0.06 0.003 

Truck Loading: Coal 8.48 0.88 

Bulldozing: Coal 30.93 2.53 

Bulldozing: Overburden 35.70 19.62 

Overburden Replacement 78.58 11.79 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-11 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Table 4-3 Worst-Case Year (2020) Trapper Mine PM10 and PM2.5 Direct 

Emissions 

Mining Operation PM10 (tpy) PM2.5 (tpy) 

Dragline 111.55 9.60 

Topsoil Removal: Scraper 2.15 2.15 

Topsoil: Scraper Travel Mode 27.93 2.79 

Topsoil Unloading: Scraper 1.48 1.48 

Grading: Haul Roads 6.03 0.60 

Coal/Overburden Truck Hauling 87.95 8.79 

Light Duty Vehicle Traffic 2.05 0.20 

Wind Erosion 196.84 29.53 

TOTAL 590.71 90.94 

Source: Air Resource Specialists 2016. 

Combustion Emissions 

Combustion emissions include NOX, SO2, CO, and VOCs from combustion of diesel fuel in mining 

equipment and trucks along with emissions associated with blasting. 

The combustion emissions calculations are included in Appendix B with the results documented in 

Table 4-4. Calculations for HAP emissions associated with fuel combustion in the mining equipment and 

trucks are reported in Table 4-5. 

Table 4-4	 Direct Mining Emissions for Worst-Case Year (2020) Fuel Combustion and
 

Blasting
 

Emissions Source 

Fuel Combustion: Mining 

Equipment & Trucks 

Blasting 

TOTAL 

NOX (tpy) 

987 

74 

1,061 

SO2 (tpy) 

52 

9 

61 

CO (tpy) 

378 

291 

669 

VOCs (tpy) 

72 

No Data 

72 

Source: Air Resource Specialists 2016. 

Table 4-5	 Direct Mining HAPs Emissions for Worst-Case Year (2020) – Fuel Combustion 

(tpy) 

Benzene Toluene Xylene 1,3-Butadiene Formaldehyde Acetaldehyde Acrolein Napthalene 

0.41 0.15 0.11 0.02 0.13 0.07 0.01 0.06 

Source: Air Resource Specialists 2016. 

Ozone 

The contributions to O3 emissions from direct mining activities and associated impacts are discussed in 

Section 5.4.2 of the Cumulative Impacts section (Chapter 5.0) as the contribution of individual source 

emissions to regional O3 levels cannot be accurately quantified. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-12 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

1 

Chapter 4.0 – Environmental Consequences 

Mining-Related GHG Emissions 

GHG emissions include CO2, CH4, and N2O. The direct Trapper Mine GHG emissions are associated 

with the fuel combustion in mining equipment and trucks, and blasting. In addition, fugitive CH4 

emissions are released at surface mines from the coal seams. Technical details about the calculation of 

GHG emissions are listed in the TSD (Appendix B). 

GHG emissions are reported on the basis of CO2e. This accounts for the differences in the global 

warming potential (GWP) of the individual constituents. Table 4-6 lists the estimated direct GHG 

emissions and the GWP for the individual GHG gasses. GHG emissions are shown in metric tons (MT) 

for consistency with international standards (1 MT = 1,000 kg = 1.1 tons US). For the N2O estimates, if 

specific N2O emissions data were not available, all NOX emissions were assumed to be in the form of 

N2O in order to provide for a worst-case assessment. 

Table 4-6	 Direct Mining GHG Emissions for Worst-Case Year (2020) (tons and MT
 

per year)
 

CO2 CH4 N2O CO2e 

Global Warming Potential 1 36 1 298 

Fuel Combustion (tons) 86,711 -- 987 380,973 

Blasting (tons) 291 3 74 22,364 

Coal Seams (tons) -- 3,524 -- 126,878 

TOTAL (tons) 87,002 3,527 1,061 530,215 

TOTAL (MT) 79,093 3,206 965 482,014 

USEPA lists the CH4 GWP as a range of 28 to 36. The GWP of 36 was used for CH4 in order to provide an upper 

bound on the GHG emissions estimate, see www3.epa.gov/climatechange/ghgemissions/gases/ch4.html. 

Source: Air Resource Specialists 2016. 

Black Carbon 

Black carbon is a subset of the PM10/PM2.5 emissions associated with diesel fuel combustion. Black 

carbon is effective at absorbing light and has a disproportionally larger impact on visibility degradation 

compared to other forms of particulate matter. Some researchers also link black carbon emissions to 

climate-related air quality impacts. 

Black carbon has been calculated as a percentage of the PM2.5 emissions associated with diesel fuel 

combustion based on Cai and Wang (2014). The calculated black carbon emissions based on diesel fuel 

consumption from the worst-case year (2020) is provided in Table 4-7. 

Table 4-7	 Direct Mining Related Emissions for Worst-Case Year
 

(2020) – Black Carbon (tpy)
 

PM2.5 Black Carbon Ratio Black Carbon Emissions 

64 tpy 0.813 52 tpy 

Source: Air Resource Specialists 2016. 

4.3.1.2 Indirect Emissions Associated with Coal Combustion 

Indirect emissions associated with coal combustion include combustion of coal at the Craig Station to 

generate electricity. Based on the CDPHE-issued Title V operating permit (Permit 96OPMF155, Issued 

May 1, 2005), the Craig Station includes three coal-fired EGUs, with a combined net electric generating 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-13 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

capacity of 1,264 MW. Unit 1 was placed in service in 1980, Unit 2 in 1979, and Unit 3 in 1984. Coal 

from the Trapper Mine is used almost exclusively at Units 1 and 2 and coal from other sources is fired in 

Unit 3. Where supported by available data, the indirect emissions discussed in this section are based on 

the emissions from combustion of TMI coal at Units 1 and 2. The emission controls at the Craig Station 

are summarized in Table 4-8. 

In addition, some of the Craig Station CCRs (e.g., fly ash and bottom ash) are used as backfill at the 

Trapper Mine. The remaining CCRs are recycled for beneficial uses. The emissions associated with the 

CCRs’ transport and placement at Trapper Mine are included in the indirect emissions. This would 

include fugitive dust emissions (PM10 and PM2.5) associated with the hauling of CCRs by truck to the 

placement site, and associated diesel fuel combustion emissions from the trucks, including GHG 

emissions. 

Table 4-8 Summary of Air Emission Controls – Craig Station 

Unit 1 Unit 2 Unit 3 

Capacity (Net) 428 MW 428 MW 408 MW 

In-service Date 1980 1979 1984 

Particulate Matter Fabric Filter Baghouse Fabric Filter Baghouse Fabric Filter Baghouse 

SO2 Wet Limestone Scrubber Wet Limestone Scrubber Spray Dryer Absorber (Dry 

Scrubber) 

NOX Low NOX Burners with 

Overfire Air 

Low NOX Burners with 

Overfire Air 

Low NOX Burners with 

Overfire Air 

Add SCR by 2021 to meet 

emission limits of the 

Colorado Regional Haze 

SIP 

Add SCR by 2018 to meet 

emission limits of the 

Colorado Regional Haze 

SIP 

Add SNCR by 2018 to 

meet emission limits of the 

Colorado Regional Haze 

SIP 

Mercury Ancillary control provided 

by existing systems for 

other pollutants 

Ancillary control provided 

by existing systems for 

other pollutants 

Ancillary control provided 

by existing systems for 

other pollutants 

Source: Air Resource Specialists 2016. 

Criteria Pollutant Indirect Emissions from Electricity Generation (SO2, NOX, CO,VOCs, and PM10/PM2.5) 

Coal combustion for generation of electricity produces air emissions. These emissions were estimated 

based on coal combustion at Craig Station Units 1 and 2 for the maximum coal production rate under 

TMI’s air permit, or 2.6 mtpy. 

As described previously, coal from the Trapper Mine is used almost exclusively at Craig Station Units 1 

and 2. Where supported by reliable technical information, emissions data unique to Units 1 and 2 were 

used to estimate the Trapper Mine-related indirect emissions. 

A summary of calculated emissions for the Craig Station is provided in Table 4-9. For SO2 and NOX 

calculations, unit-specific emissions data for 2014 were obtained for the Craig Station from the USEPA 

Air Markets Program Data (AMPD). As explained in the TSD (Appendix B), the AMPD SO2 and NOX 

emissions data for Units 1 and 2 were then adjusted to reflect the contribution to these emissions from 

TMI coal at the maximum allowable coal production rate of 2.6 mtpy. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-14 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Table 4-9 Indirect Coal Combustion Emissions (tpy) 

SO2 Emissions NOX Emissions 

Unit 1 Unit 2 Unit 3 Unit 1 Unit 2 Unit 3 CO VOCs PM10 PM2.5 

Craig Station 

Emissions Total 

(2014) 

799.02 963.36 2,000.90 3,768.07 4,603.28 5,367.91 -- -- 119.0 68.5 

Trapper Mine 

Coal 

Combustion 

Contribution 

(78.67%) 

628.59 757.88 -- 2,964.34 3,621.40 -- -- -- 86.5 53.9 

Trapper Mine 

Coal 

Combustion 

Contribution 

Adjusted to 2.6 

mtpy 

710.58 856.73 -- 3,350.99 4,093.76 -- 650.0 78.0 97.8 60.9 

Note: PM10 and PM2.5 emissions are the total from Units 1 and 2 as reported for Calendar Year 2014 on APENs filed with CDPHE. 

Source: Air Resource Specialists 2016. 

The USEPA AMPD database lists SO2 and NOX emissions; but not emissions for CO, VOCs, and 

PM10/PM2.5. 

For CO and VOC, Craig Station emissions were based on AP-42 Section 1.1.1 (Coal Combustion). Also, 

for CO and VOC, the AP-42 factors (pounds per ton) were applied to the 2.6 mtpy maximum mining rate 

for Trapper Mine coal to derive the indirect emissions information. PM10 and PM2.5 emissions at Units 1 

and 2 were taken from APENs filed with CDPHE by Tri-State Generation and Transmission Association, 

Inc. and adjusted to reflect the TMI coal contribution at the maximum mining rate of 2.6 mtpy. For all 

pollutants, the indirect emissions are based on the maximum coal combustion of 2.6 mtpy and do not 

represent a specific future year. 

Based on the above data, the Craig Station emissions associated with Trapper Mine coal at a 2.6 mtpy 

mining rate would be: SO2 – 1,567 tpy, NOX – 7,445 tpy, CO – 650 tpy, VOCs – 78 tpy, PM10 – 97.8 tpy, 

and PM2,5 – 60.9 tpy. 

The NOX emissions estimates shown above do not include the expected future benefits of improved 

emissions controls at Craig Station. Both Unit 1 and Unit 2 are planning to install SCR for NOX emissions 

control (see Table 4-8) to meet the emissions limits contained in the Regional Haze SIP (CDPHE 

2014a). The SIP specifies the required NOX emissions limits and the owner/operator (Tri-State 

Generation and Transmission) then selects the appropriate emissions control technology to achieve the 

required limits. The Unit 2 SCR is scheduled to be operational by 2018 and the Unit 1 SCR is scheduled 

to be operational by 2021. Based on the NOX emissions limits contained in the Colorado Visibility and 

Regional Haze SIP (CDPHE 2014a), the projected NOX reduction would be on the order of 80 percent at 

each unit, for a total reduction of about 8,000 tpy. The reductions attributable to Trapper Mine coal would 

be a portion of the total Unit 1 and 2 reductions, or about 6,300 tpy, leaving post-control indirect NOX 

emissions attributable to Trapper Mine coal of 1,145 tpy. 

The contribution of indirect emissions to regional O3 is discussed in the Cumulative Impacts section 

(Chapter 5.0) as the contribution of individual source emissions to O3 levels cannot be accurately 

quantified. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 4-15 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Mercury Emissions from Electricity Generation 

The CDPHE has provided mercury emissions data for Craig Station for the 2014 reporting year (Tri-State 

Generation and Transmission Association, Inc. 2015). These Craig Station mercury emissions data are 

based on continuous emissions monitoring system equipment installed at each Craig Station unit. 

The Craig Station is generally recognized to have one of the lower mercury emission rates for electric 

generating units in the United States. Based on 2009 mercury emissions data compiled by 

Environmental Integrity Project (2011), Craig Station was at the time ranked second-lowest among coalfired power plants in the U.S. in terms of mercury emissions per unit of electricity generation, expressed 

as lb/GWh. 

The 2014 mercury emissions data for Craig Station are summarized in Table 4-10. Table 4-11 

summarizes the mercury emissions attributable to the Trapper Mine coal and reflects the contribution to 

the total mercury emissions from coal combustion at Craig Station Units 1 and 2 adjusted to the 

maximum TMI mining rate of 2.6 mtpy. Mercury released at Craig Unit 3 is not tied to combustion of TMI 

coal but instead comes from coal supplied by other mines. The calculations for the mercury emissions 

are documented in the TSD (Appendix B). The total mercury emissions derived here are consistent with 

the Craig Station mercury emissions listed in the 2014 USEPA TRI (USEPA 2014b). 

Table 4-10	 Actual 2014 Craig Station Mercury Emissions 

(lb/yr) as reported by Craig Station to CDPHE
 

Unit 1 4.41 

Unit 2 4.85 

Unit 3 33.69 

Total 42.95 

lb/yr = pounds per year. 

Table 4-11	 Estimated Craig Station Mercury Emissions from 

Trapper Mine Coal (lb/yr) 

Mercury Emissions for 

Trapper Mine 

2014 Combustion Rates 

(2.3 mtpy) 

Mercury Emissions at 

Maximum Trapper Coal 

Combustion Rates 

(2.6 mtpy) 

Unit 1 3.47 3.92 

Unit 2 3.82 4.31 

TOTAL 7.29 8.23 

Source: Air Resource Specialists 2016. 

CCRs Placement at Trapper Mine 

The delivery and placement of CCRs at Trapper Mine is characterized as an indirect emission because 

placement is in areas outside of the Project Area. Trapper Mine receives a portion of the CCRs from 

Craig Station for placement, with the remainder recycled for beneficial uses. The emission calculations 

address the CCRs returned to Trapper Mine for placement, regardless of the origin of the coal. The 

CCRs volume returned to the Trapper Mine for placement is estimated at approximately 501,000 tpy. 

The calculated indirect emissions associated with placement of CCRs at Trapper Mine is based on the 

projected volume and does not represent a specific year of operation. The technical details of the 

emissions calculations are documented in the TSD (Appendix B). 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-16 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

PM10 and PM2.5 emissions are principally fugitive dust from truck traffic carrying the CCRs from Craig 

Station to the placement site at Trapper Mine. Other sources of emissions include bulldozing and wind 

erosion at the placement site, and exhaust emissions associated with the diesel fuel combusted by the 

haul trucks. Table 4-12 summarizes the indirect PM10/ PM2.5 emissions associated with the CCRs 

placement. 

Table 4-12	 Indirect PM10 and PM2.5 Emissions from CCRs Placement at Trapper Mine 

Emission Source PM10 (tpy) PM2.5 (tpy) 

CCRs Hauling: Truck Traffic 7.85 1.38 

CCRs Bulldozing 1.16 0.35 

Wind Erosion 3.80 0.57 

TOTALS 12.81 2.30 

Source: Air Resource Specialists 2016. 

The fuel combustion for haul trucks that transport the CCRs to the Trapper Mine placement site also 

releases pollutants such as NOX, SO2, CO, and VOCs. These emissions were calculated using the 

USEPA MOVES2014 model (USEPA 2014a) and estimated operating time for the trucks (Appendix B). 

The relevant emissions are summarized in Table 4-13. 

Table 4-13	 Indirect Emissions for Worst-Case Year (2020) Fuel Combustion: CCRs
 

Transfer by Truck to Trapper Mine
 

NOX (tpy) SO2 (tpy) CO (tpy) VOCs (tpy) 

Fuel Combustion: CCRs Haul Trucks 12.1 1.5 5.15 0.7 

Source: Air Resource Specialists 2016. 

Indirect GHG Emissions 

Indirect GHG emissions are associated with combustion of the coal provided to Craig Station by the 

Trapper Mine. Indirect emissions also are associated with diesel fuel combustion from the haul trucks, 

which carry the CCRs material back to Trapper Mine for final placement. 

At the Craig Station, CO2 emissions associated with coal combustion are listed in the AMPD database, 

so the CO2 emissions estimates were handled in a manner similar to the SO2 and NOX emissions 

described previously. The total 2014 Craig Station CO2 emissions were obtained from the AMPD and the 

portion derived from Trapper Mine coal at Units 1 and 2 was calculated. This value was then adjusted to 

the permitted maximum coal production rate of 2.6 mtpy. 

Because the AMPD reports only CO2 emissions, the total GHG emissions as CO2e needed to be 

determined by including emissions of other GHG pollutants, specifically CH4 and N2O. Using the AP-42 

emission factors (Section 1.1, Coal Combustion) and the GWP of each pollutant, a CO2e factor was 

determined and compared to the CO2-only emissions factor from AP-42. This ratio was then used to 

adjust the CO2-only emissions reported in the AMPD for Craig Station Units 1 and 2. Because CO2 

dominates the GHG emissions for coal combustion compared to CH4 and N2O, the calculated 

adjustment factor was very small (0.5 percent) (Appendix B). 

GHG emissions associated with the diesel fuel combustion in the trucks hauling CCRs to the placement 

site were calculated using the USEPA MOVES2014 emissions model (USEPA 2014a). MOVES2014 

only lists data on CO2 emissions; so other GHG emissions were not calculated for the CCRs placement. 

However, like coal combustion, GHGs from diesel fuel combustion are dominated by the CO2 emissions 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-17 
 

 

 

Chapter 4.0 – Environmental Consequences 

and omitting the other GHG pollutants from the calculation does not introduce a significant error in the 

overall estimate. Also, the CCRs placement is a very small fraction of the overall indirect GHG 

emissions. 

The indirect GHG emissions are shown in Table 4-14. GHG emissions are shown in MT for consistency 

with international standards (1 MT = 1,000 kg = 1.1 tons US). 

Table 4-14 Indirect GHG Emissions reported at CO2e for Coal Combustion and CCRs 

Placement
 

GHG Emissions as CO2e 

(MT per yr) 

Indirect Project Emissions as 

compared to State/National Totals 

Craig Station Units 1 and 2 Coal 

Combustion adjusted to maximum 

TMI Mining Rate( 2.6 mtpy) 

5,341,966 NA 

CCRs Placement (transportation) 985 NA 

Total Indirect GHG Emissions 5,342,951 NA 

Colorado GHG Emissions (2010) 129.95 million 4.1% 

Nationwide GHG Emissions (2007) 7,150.1 million 0.07% 

Source: Air Resource Specialists 2016. 

The indirect GHG emissions are shown in comparison to the state and national GHG inventories. The 

Colorado inventory is taken from CDPHE (2014b) and represents the statewide GHG inventory for 

Calendar Year 2010. The indirect emissions associated with combustion of 2.6 mtpy of coal at Craig 

Station Units 1 and 2 is about 4.1 percent of the statewide GHG inventory. The nationwide GHG 

inventory is described under the Section 3.3, Existing Environment and represents the nationwide GHG 

inventory for Calendar Year 2007. The project-related indirect emissions are 0.07 percent of the national 

GHG emissions. 

Although it is impossible to connect a single emitter of GHGs to the degree of impact that emitter may 

have on the global climate change, EPA has predicted that Colorado will experience the following 

general trends related to climate change (USEPA 2015c). 

	 The region may experience warmer temperatures with less snowfall. 

	 Temperature are expected to increase more in the winter than in the summer, more at night 

than in the day, and more in the mountains than at lower elevations. 

	 Earlier snowmelt will result in earlier peak stream flows, weeks before the peak needs of 

ranchers, farmers, recreationalists and others. In late summer, rivers, lakes, and reservoirs will 

be drier. 

	 More frequent, more severe, and possibly longer-lasting droughts will occur. 

	 Crop and livestock production patterns could shift northward; less soil moisture due to increased 

evaporation may increase irrigation needs. 

 Drier conditions will reduce the range and health of ponderosa and lodgepole pine forests, and 

increase the susceptibility to fire. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-18 
 

 

 

Chapter 4.0 – Environmental Consequences 

 Grasslands and rangeland could expand into previously forested areas. 

 Ecosystems will be stressed and wildlife such as s mountain lion, black bear, long-nose sucker, 

pine marten, and bald eagle could be further stressed. 

The climate impacts described above would potentially be long-term, but any contribution to climate 

change associated with direct/indirect emissions from Trapper Mine would be negligible and additional 

contributions would cease after the life of the mine. 

Another approach to address climate change impacts is to calculate the “social cost of carbon” (SCC). 

The SCC protocol was developed for use in cost-benefit analyses for proposed regulations that could 

impact cumulative global GHG emissions (USEPA 2013). The SCC estimates economic damages 

associated with increases in carbon emissions and includes, but is not limited to changes in net 

agricultural productivity, human health, and property damages associated with increased flood risks. 

The SCC is typically expressed as the cost in dollars per MT of emissions and there is a wide range of 

costs, with the greatest influence on costs caused by the discount rate. The discount rate is a measure to 

estimate the present value for costs/damages that may occur far out into the future. For 2020 emissions, 

the range in SCC presented by the USEPA is $13/MT to $137/MT, represented as 2011 dollars 

(USEPA 2013). 

OSMRE has elected not to specifically quantify the SCC. First, there is no certainty that GHG emissions 

at Craig Station would actually be reduced if Trapper Mine coal from the Project Area was not mined 

given that Craig Station has alternative sources for coal, and the Trapper Mine also has non-federal coal 

reserves that could be mined (see Section 2.5). Also, in order to provide any meaningful insight, the 

projected SCC would need to be viewed in context with other Project costs and benefits associated with 

the Proposed Action. Given the uncertainties associated with assigning a specific and accurate SCC to 

the Project, and the uncertainties that indirect GHG emissions would actually be reduced under any 

reasonable Project alternatives, OSMRE has elected to quantify direct and indirect GHG emissions and 

evaluated these emissions in the context of state and national GHG emission inventories (Table 4-14). 

4.3.1.3 Air Dispersion Modeling Analysis 

An air dispersion modeling analysis was conducted by Air Resource Specialists (2016) to assess the air 

quality impacts associated with Alternative A against the NAAQS. The modeling analysis was based on 

the emissions calculated for Alternative A for the worst-case year, 2020. The modeling analysis is 

discussed in detail in Appendix B and summarized below. 

Modeling Overview 

The air quality modeling analysis was conducted with the USEPA AERMOD dispersion model – 

Version 15181 (USEPA 2004). AERMOD is the standard air dispersion model recommended by the 

USEPA for use in regulatory actions such as permitting. The AERMOD modeling generally followed the 

recommendations in USEPA’s Guideline for Air Quality Models (USEPA 2005a) and USEPA’s current 

AERMOD Implementation Guidance (USEPA 2015b). Recommended USEPA regulatory defaults were 

used for all AERMOD model inputs unless noted otherwise in the discussion below. 

One of the basic inputs to AERMOD is meteorological information (wind speed, wind direction, 

temperature, etc.). In the modeling analysis, the AERMOD modeling was performed using two different 

meteorological data sets. One data set was the on-site monitoring data collected at Trapper Mine for the 

period March through September 2015. However, as the Trapper Mine on-site data do not span a full 

12-month period, a second more complete dataset also was used. The CDPHE was solicited to 

recommend the alternate meteorological data, and CDPHE provided data collected at the Colowyo Mine 

Gossard monitoring site during 2012 (CDPHE 2015a). The Gossard monitoring site is located at 

Latitude 40.313 North and Longitude -107.799 West at an elevation of 6,325 feet (1,928 meters) amsl. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-19 
 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Once the modeling was conducted, it was observed that the Gossard meteorological data consistently 

returned higher model predictions compared to the on-site Trapper Mine data. 

AERMOD Modeling Results 

The AERMOD modeling results for Trapper Mine emissions are summarized below and compare the 

predicted concentrations to the applicable NAAQS. Where the NAAQS is expressed in units of ppb or 

ppm, the NAAQS concentration value has been converted to μg/m3 to allow for direct comparison 

against the AERMOD modeling results. The AERMOD modeling addresses the following regulated 

pollutants: CO, SO2, NO2, PM10, and PM2.5. O3 emissions and impacts are discussed in the Cumulative 

Impacts section (Chapter 5.0) as the contribution of individual source emissions to regional O3 levels 

cannot be accurately quantified. 

The AERMOD modeling results are discussed in detail in Appendix B and summarized in Table 4-15. 

Only the worst-case modeling result from the two meteorological data sets (Trapper Mine On-Site versus 

Gossard) is shown in the results table. As noted above, for all pollutants and averaging times, the 

Gossard data provided the worst-case modeling result. 

As demonstrated by Table 4-15, the predicted AERMOD concentration for each pollutant and averaging 

time, plus an appropriate background level to account for impact from emission sources not explicitly 

included in the modeling, demonstrates compliance with all applicable NAAQS. Because the modeling 

demonstrates that the impacts are below the NAAQS, these impacts are defined as negligible. These 

impacts are short-term and would occur for the duration of mining under this alternative. 

Table 4-15 AERMOD Modeling Results – Trapper Mine (all concentrations in μg/m3

) 

Pollutant 

Averaging 

Time 

Form1

 – AERMOD 

Modeled 

Concentration2 

Background 

Concentration 

Cumulative 

Impact 

(AERMOD plus 

Background) NAAQS 

CO 

1-hour 2nd High – 3,791.54 1,145 4,936.54 10,000 

8-hour 2nd High – 907.4 1,145 2,052.4 40,000 

SO2 1-hour 4th High – 49.413

 2.62 52.03 195.6 

NO2 

1-hour 8th High – 159.27 13.16 172.43 188 

Annual 1st High – 24.67 1.88 26.55 100 

PM10 24-hour 2nd High – 62.12 23 85.12 150 

PM2.5 

24-hour 8th High – 12.78 14 26.78 35 

Annual 1st High – 3.94 3 6.94 12 

1	 The AERMOD concentration shown is the concentration expressed in the form of the NAAQS. For example, because the SO2 

NAAQS is based on the 99th percentile daily maximum concentration, the 4th highest concentration value from AERMOD is 

reported (i.e., over 365 days, the highest three days are excluded to reach the 99th percentile concentration). Other pollutants 

are addressed similarly based on the form of the NAAQS. 

2	 The Modeled Concentration was chosen as the higher value of the Gossard and On-Site Trapper modeling results for each 

pollutant and averaging period. The Gossard meteorological data provided higher results for every scenario. 

3 For SO2, only the 1-hour concentrations were reported in the dispersion modeling. There are 3-hour state and federal air 

quality standards for SO2; however, the 1-hour standard is more stringent and compliance with the 1-hour average SO2 

NAAQS also assures compliance with the 3-hour state/federal SO2 standards. The 3-hour average SO2 concentrations are 

listed in the TSD (Appendix B). 

Source: Air Resource Specialists 2016. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-20 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Maximum Impact Locations 

The location of the maximum modeled concentration described in Table 4-15 varies between pollutants 

and averaging periods and depends largely on the emission distribution and the nature of the 

meteorology data. The dominant wind direction (south through southwest) resulted in all maximum 

modeled concentrations along either the north or east Trapper Mine SMCRA permit boundary. 

For PM10 and PM2.5, the emissions were dominated by mining activities in and near the mine pits. As 

such, the maximum modeled PM10 24-hour concentration occurred along the Trapper Mine permit 

boundary to the northeast of the N Pit. This impact was believed to be dominated by mining-related 

emissions associated with the N Pit and also from emissions associated with the L Pit coal hauling 

where the haul road bypasses the N Pit on the north side. Even though N Pit had fewer emissions 

compared to the L Pit, the shorter transport distance from the N Pit to the SMCRA permit boundary plus 

the contribution from the coal hauling emissions contribute to the increase in the PM10 impacts in this 

area. 

The maximum modeled PM2.5 concentrations both occurred along the eastern SMCRA permit boundary. 

The maximum modeled PM2.5 concentration occurred to the northeast of the L Pit. The worst-case PM2.5 

impact locations were the result of the relatively high concentration of emissions within the L Pit and the 

direction of the prevailing winds. 

The maximum modeled NO2 concentration occurred along the northeastern section of the SMCRA 

permit boundary to the north of the L Pit. These impacts were influenced by the high concentration of 

NOX emissions from the truck and mining equipment in the L Pit. 

For pollutants such as CO, annual mean NO2, and SO2 haul road truck traffic is the dominant source of 

emissions. For these pollutants, the maximum modeled impacts occur near where the coal haul road 

leading to the Craig Station passes through the SMCRA permit boundary of the mine. The impacts occur 

at this particular location because the transport distance to potential receptors is minimized at this 

location. The CO 1-hour and 8-hour, NO2 annual, and SO2 1-hour maximum modeled impacts were all 

located within a few hundred meters of where the coal haul road passes through the Trapper Mine 

SMCRA permit boundary. 

4.3.1.4 Air Quality and Climate Impacts for Alternative A 

The Trapper Mine EA addresses emissions associated with mining activities that are ongoing. As such, 

ongoing air quality and climate impacts are reflected in the baseline data described in the Affected 

Environment (Chapter 3.0). 

O3 emissions and impacts are discussed in the Cumulative Impacts section (Chapter 5.0) as the 

contribution of individual source emissions to regional O3 levels cannot be accurately quantified. 

Direct Impacts 

Direct mining-related air quality impacts would include emissions associated with coal/overburden/ 

interburden handling and transfer and emissions from combustion of diesel fuel in trucks and mining 

equipment. Although air emissions would be released into the environment from mining activities, air 

quality dispersion modeling demonstrated that NAAQS for PM10, PM2.5, NOX, SO2, and CO would not be 

exceeded in the worst-case year (2020). Impacts during other years would be less and would comply 

with the NAAQS. As such, the direct air quality impacts would be negligible. Direct air quality impacts 

would be short-term and would occur throughout the life of Alternative A. 

Direct GHG emissions include fugitive releases of CH4 from the coal seams and GHG emissions from 

combustion of diesel fuel in the truck fleet and mining equipment. Direct GHG emissions from mining are 

expected to be approximately 482,014 metric tons CO2e in the worst-case year (2020) and less than that 

number for other mining years. The direct GHG emissions from the mining operations would be less than 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-21 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

10 percent of the indirect emissions from coal combustion as described below. In addition, when 

compared to state and national GHG emissions, the direct GHG emissions would represent less than 

0.4 percent of the 2010 Colorado GHG emissions and less than 0.007 percent of the 2007 nationwide 

GHG emissions. Climate impacts would potentially be long-term, but any contribution to climate change 

associated with direct emissions from Trapper Mine would be negligible and would diminish after the life 

of the mine when additional contributions to GHG are no longer occurring. 

Indirect Impacts 

Indirect air quality impacts would occur from combustion of Trapper Mine coal at Craig Station Units 1 

and 2 and placement of CCRs at the Trapper Mine outside the Project Area. The coal combustion 

releases air emissions, most notably SO2 and NOX. Craig Station employs pollution abatement 

equipment to reduce these emissions and has plans to further reduce NOX emissions in the 2018-2021 

timeframe. Emissions attributable to combustion of Trapper Mine coal would be 97.8 tpy PM10, 60.9 tpy 

PM2.5, 1,567 tpy SO2, 7.445 tpy NOX, 650 tpy CO, and 78 tpy VOCs based on the current emission 

controls for Units 1 and 2 at the Craig Station, Following installation of additional NOX emission controls, 

the NOX emissions from combustion of Trapper Mine coal are estimated to be 1,145 tpy. There would be 

no changes to the Craig Station operations as a result of Alternative A. 

Craig Stations currently is in compliance with all applicable emission standards. The indirect emissions 

associated with the transport and placement of CCRs at the Trapper Mine include dust from hauling of 

the CCRs, dust generated by equipment spreading the CCRs, wind erosion and fuel combustion for the 

haul trucks and spreading equipment. The indirect emissions from CCR hauling and placement would be 

12.80 tpy PM10, 2.30 tpy PM2.5, 12.1 tpy NOX, 1.5 tpy SO2, 5.15. tpy CO, and 0.7 tpy VOCs. These 

emissions are included in the air quality modeling of direct impacts which showed compliance with the 

NAAQS. 

The coal combustion is ongoing and there would be no changes that would result in exceedance of the 

current NAAQS. The indirect air quality impacts attributable to combustion of Trapper Mine coal would 

be short-term and negligible, and would cease after Trapper Mine ceases to provide coal to the Craig 

Station. 

Given that coal to operate Craig Station would be available from sources other than the Trapper Mine, 

Craig Station emissions related to coal combustion would likely continue if Trapper Mine coal was 

unavailable. Craig Station emissions would continue in the long term. 

The indirect air quality impacts associated with mercury emissions released during coal combustion are 

based on mercury emissions attributable to Trapper Mine coal combusted in Units 1 and 2 of the Craig 

Station. Mercury emissions would be 8.23 lb/yr at the maximum mining rate of 2.6 mtpy. These 

emissions would result in potential impacts to Colorado River fish and the Yellow-billed cuckoo. Impacts 

to these species as a result of the mercury emissions are discussed in detail Section 4.10, Special 

Status Species. 

Indirect GHG emissions occur from coal combustion at Craig Station and from CCR transport and 

placement. Indirect GHG emissions would be 5,342,951 tpy which represents approximately 4.1 percent 

of the total 2010 Colorado emissions and 0.07 percent of the 2007 national emissions. There is concern 

that GHG emissions are a contributor to climate change, but the nature and magnitude of any such 

climate impact is uncertain and cannot be accurately quantified at present. Any climate impacts that may 

occur are difficult to assign to an individual emission source of GHGs such as Trapper Mine and Craig 

Station. Climate impacts would potentially be long-term, but any contribution to climate change 

associated with indirect emissions from Trapper Mine would be negligible and additional contributions 

would cease after the life of the mine when indirect emissions attributable to the Trapper Mine coal 

combustion would no longer be occurring. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-22 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

4.3.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM 

Under Alternative B, TMI would not mine any future coal within the Project Area. If Alternative B were 

selected, the most likely outcome would be that TMI would instead transfer its mining operations to other 

coal reserves within the SMCRA permit boundary that are located outside the Project Area. Under 

Alternative B, the maximum coal production rate is expected to decrease to an estimated 1.5 mtpy and 

these coal reserves would likely be exhausted within about three to four years. 

O3 emissions and impacts for Alternative B are discussed in the Cumulative Impacts section 

(Chapter 5.0) as the contribution of individual source emissions to regional O3 levels cannot be 

accurately quantified. 

4.3.2.1 Direct Mining Emissions 

If mining were to be transferred to other coal reserves within the SMCRA permit boundary, the expected 

direct air emissions from the mining activities would be reduced based on the anticipated reduced mining 

rate of 1.5 mtpy. At the reduced mining rate, direct air quality impacts would be expected to be about 

40 percent less than those described under Alternative A and these impacts would cease once mining 

for the other reserves was completed within about three to four years. However, some year-to-year 

variation in direct emissions would be expected depending on the specifics of the mine plan for these 

other reserves. For example, direct mining emissions might be higher or lower in any given year 

depending on the year-to-year variation in overburden stripping ratios. Also, because these other coal 

reserves are generally to the west of the Project Area, mining of these reserves would likely occur closer 

to the Craig Station, and the reduced coal hauling distances would be expected to result in lower 

emissions from this activity. 

An increase in air emissions impacts, tied to cessation of mining activities in the Project Area, would 

result from reclamation activities that would need to commence at TMI’s existing L Pit. Over the nearterm, reclamation activities would be extensive as TMI worked to backfill the current mine pit and 

recontour/reclaim the existing land disturbance in the L Pit. Although reclamation plans have not been 

fully developed by TMI, it is expected that the necessary backfill material would need to come from the 

new pit operations outside of the Project Area, which would substantially increase overburden hauling 

distances in the near-term. As such, the extensive activities for reclamation at L Pit would be expected to 

cause additional air emissions over and above the Trapper Mine direct mining emissions for a period of a 

few years. Once the L Pit reclamation activities were completed, the direct mining emissions would only 

be related to mining activity in the areas outside the Project Area. 

Under Alternative B, it also is expected that a short-term disruption in mining might occur as TMI 

transferred mining equipment from the current mine pit to the new coal reserves. Any disruption in coal 

supply from Trapper Mine might require Craig Station to seek alternative sources for coal until Trapper 

Mine’s coal production started at the new mining pit. The reduced mining rate of 1.5 mtpy also would 

require Craig Station to seek coal from other sources in order to make up the deficit. Any alternative coal 

supply would need to come from a more distant mine and there would be an increase in air quality 

emissions associated with transport of any substitute coal from the more distant coal source. 

4.3.2.2 Indirect Emissions Associated with Coal Combustion 

Under Alternative B, Craig Station would receive coal mined at the Trapper Mine from reserves outside 

the Project Area. Any deficit in coal production at Trapper Mine under Alternative B would likely be 

replaced by coal from a more distant alternative coal supplier. As such, it is expected that there would be 

no change in the Craig Station operation and no change in the associated Craig Station air 

quality/climate emissions. The emissions associated with coal transport to Craig Station could be 

different depending on the location of the alternative source for coal. Otherwise, the indirect air quality 

impacts under Alternative B would be unchanged from those described for Alternative A. However, the 

TMI contribution to the indirect impacts from Craig Station emissions would decrease by approximately 

40 percent. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-23 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

4.3.2.3 Air Quality and Climate Impacts for Alternative B 

Direct Impacts 

Direct mining-related air quality impacts would include emissions associated with coal/overburden/ 

interburden handling and transfer and emissions from combustion of diesel fuel in trucks and mining 

equipment. Under Alternative B, emissions would be anticipated to be below the levels described under 

Alternative A by about 40 percent, based on the reduced mining rate for this alternative, and NAAQS 

would not be exceeded. As such, the direct air quality impacts under Alternative B would be negligible. 

Direct air quality impacts would be short-term and occur for the life of mining activities outside the Project 

Area, or three to four years, which is a shorter duration than the projected 10-year life-of-mine for 

Alternative A. 

Direct GHG emissions include fugitive releases of CH4 from the coal seams and GHG emissions from 

combustion of diesel fuel in the truck fleet and mining equipment. Direct GHG emissions from mining are 

expected to be approximately 40 percent below the levels described for Alternative A based on the 

reduced mining rate for Alternative B. As such, the direct GHG impacts would be negligible and could be 

long-term but would diminish after mining ceases and additional direct GHG emissions are no longer 

occurring. 

Indirect Impacts 

Indirect air quality impacts occur from combustion of coal mined by TMI at Craig Station Units 1 and 2 

and placement of CCRs at the Trapper Mine as described for Alternative A. The emissions from 

placement of CCRs within the Trapper Mine would remain unchanged from that described for Alternative 

A. The coal combustion releases air emissions, most notably SO2 and NOX. Craig Station employs 

pollution abatement equipment to reduce these emissions and plans to further reduce NOX emissions in 

the 2018-2021 timeframe. Overall Craig Station emissions would be unchanged; however, indirect 

emissions attributable to the Trapper Mine coal would be approximately 40 percent below the indirect 

emissions of Alternative A. However, there would be additional impacts from emissions for coal transport 

from more distant sources to make up for the reduced Trapper Mine mining rate, should the Craig 

Station continue to operate at current levels. The indirect air quality emissions attributable to Trapper 

Mine coal would be short-term, occurring for the life of mining activities, and would be negligible. Indirect 

emissions from Craig Station would continue for the long term. 

The indirect air quality impacts associated with mercury emissions released during coal combustion are 

based on mercury emissions attributable to Trapper Mine coal combusted in Units 1 and 2 of the Craig 

Station. Mercury emissions attributable to Trapper Mine coal could be reduced by 40 percent from the 

mercury emissions outlined in Alternative A. These emissions would result in potential impacts to 

Colorado River fish and the Yellow-billed cuckoo. Impacts to these species as a result of the mercury 

emissions are discussed in detail Section 4.10, Special Status Species. 

Emissions of GHGs attributable to combustion of Trapper Mine coal would be reduced by 40 percent as 

a result of the reduced mining rate of Alternative B. There is concern that GHG emissions are a 

contributor to climate change, but the nature and magnitude of any such climate impact is uncertain and 

cannot be accurately quantified at present. Also, any climate impacts that may occur are difficult to 

assign to an individual emission source of GHGs such as Trapper Mine and Craig Station. Climate 

impacts would be potentially long-term, but any contribution to climate change associated with indirect 

emissions from Trapper Mine would be negligible and would diminish after the life of the mine when 

Trapper Mine coal is no longer being combusted. 

4.3.3 Mitigation Measures 

No mitigation measures beyond those required by the Trapper Mine air quality permit would be required 

for air quality. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-24 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

4.4 Geology and Minerals 

4.4.1 Alternative A – Proposed Action 

4.4.1.1 Direct Impacts 

Alternative A would result in the removal of the recoverable coal seams in the N and L pits. At this time, 

CDRMS has neither received nor approved an application that includes detailed plans for mining the 

N Pit. The CDRMS would need to approve mining in the N Pit prior to initiating mining in this pit. The coal 

would be mined according to the methods described in Section 2.4.3. 19.1 million tons of coal would be 

mined through approximately 2025 (as indicated in Section 2.4). In addition to the coal, over the life of 

mining for the Project Area, mining would remove an estimated 150 million cubic yards of geological 

strata (overburden and interburden) above and between coals assuming a stripping ratio of 10:1 (10 

cubic yards per ton of coal (Stubblefield and Fish 1991). The original character of the overburden and 

interburden would be permanently altered and the geological column would be permanently altered 

within the pit area. However, the Project Area represents a small portion of the overall geologic column 

and coal reserves associated with the Yampa coal field. Therefore, the effect would be negligible to 

minor, but would be permanent. At the end of mine life, the pit would be backfilled as part of closure and 

reclamation. 

Coal mining was a contributing factor to the massive G Pit (now L Pit) landslide that took place in 

October 2006. There are many areas of naturally occurring landslides on the slopes of the Williams Fork 

Mountains indicating an inherent instability, which could be aggravated by mining. Several smaller mass 

wasting events occurred in the G Pit area in the years leading up to the October 2006 event (Agapito 

Associates, Inc. [AAI] 2008). Potential impacts due to mass movements include endangerment of 

personnel, loss of recoverable coal resources, and loss of equipment. In the case of the October 2006 

incident, monitoring of ground conditions enabled areas to be evacuated prior to the catastrophic failure. 

PR06 was submitted to address the adverse conditions presented by the slide and enable safe recovery 

of much of the coal that could have been lost (CDRMS 2009). In addition, geotechnical monitoring of the 

slide area was implemented through revisions of PR05 and through implementation of Minor 

Revisions 212 and 213 and Technical Revision 99. The purpose of the monitoring was to measure the 

movement of the slide mass. The geotechnical monitoring was initiated in March 2008 and was 

accomplished by use of inclinometers in boreholes, piezometers (wells to measure groundwater levels), 

and benchmarks initially at 16 sites in and near the slide mass (TMI 2008). The most recent monitoring 

report indicated that there is a “minimal amount of movement” and that a new ground control plan would 

be submitted to CDRMS after approval of the PR07 (TMI 2015). 

There is a potential that mining operations would preclude access to other mineral resources such as oil 

and gas within the Project Area. In areas leased and designated for coal mining, it may not be possible 

to extract other minerals during the mining operations. Such impacts would be relatively short-term 

because loss of access would be temporary and after mining is conducted, it would be possible to 

conduct oil and gas exploration and production. Additionally, because horizontal drilling may be the 

preferred method of recovery,mining operations would not necessarily prevent access to the deeper oil 

and gas resources. 

Coal mining would not interfere with the mining of sand and gravel deposits located in major alluvial 

drainages like the Yampa River outside the Project Area. In addition, the mine has its own aggregate 

resources to partially supply aggregate needs at the mine lessening the burden on local aggregate 

supplies. 

4.4.1.2 Indirect Impacts 

After active coal mining has ceased, some material would be disturbed as a result of the reclamation 

activities. Natural processes of erosion and occurrence of landslides would continue in unmined areas. 

The potential for landslides would continue and would represent a long-term but moderate risk based on 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-25 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

historic evidence of slope instability. It is expected that reclaimed areas would have a lesser risk of 

landslides due to reclamation design which would reduce slope instability. 

4.4.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM 

4.4.2.1 Direct Impacts 

Under Alternative B, mining would cease within the Project Area and impacts to geological resources in 

the Project Area also would end. An estimated 1.75 million tons of coal would be mined from July 1, 

2015, to the assumed cessation date of April 30, 2016 (see Section 2.5). Alternative B would result in not 

mining an estimated 17.35 million tons of coal reserves and a shortened mine life. Although the amount 

of coal involved is small compared to the overall coal resource in the Yampa coal field, the loss of the 

coal reserve would be long-term. Some mining of coal would continue within the SMCRA permit 

boundary outside of the Project Area. Therefore, the effect would be negligible to minor but would be 

permanent. 

Alternative B would have similar impacts to Alternative A on the access and extraction of other mineral 

resources during mining activities outside of the Project Area. 

4.4.2.2 Indirect Impacts 

After active coal mining has ceased, some material would be disturbed as a result of the reclamation 

activities within the Project Area and for mining outside the Project Area. Natural processes of erosion 

and occurrence of landslides would continue in unmined areas. These natural processes represent a 

long-term but moderate risk for slope instability. It is expected that reclaimed areas would have a lesser 

risk of landslides due to reclamation which would be designed to reduce slope instability. 

4.4.3 Mitigation Measures 

No mitigation measures are recommended for geological resources or hazards. TMI would continue to 

monitor ground conditions as directed by CDRMS and provisions of the existing and future ground 

control plans. A new ground control plan would be amended by technical revisions or minor permit 

revisions as appropriate for changing ground conditions. 

4.5 Water Resources 

4.5.1 Alternative A – Proposed Action 

4.5.1.1 Surface Water 

Under Alternative A, the currently active L Pit on Lease No. C-079641 would continue to be mined from 

2015 through 2025. Coal also would be mined from the N Pit, an open pit partially located on Lease 

No. C-07519, near the end of the life-of-mine for the Project Area (estimated at 2023). At this time, 

CDRMS has neither received nor approved an application from TMI to revise the Trapper Mine PAP to 

add the N Pit. However, for this analysis, it was assumed that the N Pit would be added to the PAP and 

the portion of the N Pit within the Project Area would be mined prior to the end of the life-of-mine for the 

Project Area in 2025. 

Direct Impacts 

Surface mining of the L and N pits would disturb a total of 148 acres in the Breeze Basin-Yampa River 

subwatershed, 94 acres in the Jeffway Gulch-Williams Fork subwatershed, and 16 acres in the Johnson 

Gulch-Yampa River subwatershed (Figure 3-3). In addition, approximately 11 acres of land previously 

disturbed and reclaimed in the Johnson Gulch-Yampa River subwatershed would be redisturbed for 

mining activities. The planned mining disturbance would physically alter the drainage characteristics of 

the landscape, and would remove some channel segments altogether. For example, eastward 

expansion of the L Pit would physically disrupt the uppermost channel reaches of Deacon Gulch and its 

headwater tributaries in the Breeze Basin-Yampa River subwatershed. The disturbed channels would 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-26 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

cease to function for eight to 10 years until the L Pit was backfilled and re-contoured during reclamation. 

Other drainages in the Project Area that could be impacted by mining include the main channels and 

tributaries of Sage Gulch (N Pit), Oak Gulch (N Pit), Middle Flume Gulch (L Pit), East Flume Gulch 

(L Pit), and Deal Gulch (L Pit). 

During mining, diversion ditches would be constructed to capture runoff from disturbed areas and route 

the water into sediment ponds. These sediment ponds would help maintain downstream water quality by 

controlling the sediment load in water discharged from the Project Area and the SMCRA permit area. In 

the short term, the system of diversion ditches and sediment ponds required for mining could alter the 

volume or timing of peak flows in Sage Gulch, Oak Gulch, Middle Flume Gulch, East Flume Gulch, 

Deacon Gulch, and Deal Gulch by impounding water that would have otherwise flowed downstream. 

This impact would be negligible because flow would only be impounded within a small upstream portion 

of the affected watersheds. The impacted drainages also are ephemeral streams that contribute 

relatively small amounts of flow to the Yampa River. Overall, impacts from altering the mine drainage 

patterns would be short term. Once mining is completed, the open pits would be backfilled and graded to 

approximate pre-mine drainage conditions. 

Stream flow monitoring performed by TMI also supports the conclusion that peak flow impacts from the 

altered drainage patterns would be negligible. Downstream flow in the ephemeral gulches is maintained 

to some degree through permitted discharges at Trapper Mine’s CDPS outfalls. Flumes installed at the 

outfalls also provide a relatively continuous record of flow measurements in the receiving drainages. At 

East Middle Flume Gulch, flow rates recorded at CDPS site 021 averaged approximately 0.15 cfs 

between January 2005 and December 2014 (Hydro-Engineering 2015). By comparison, the average 

baseline flow rate for this stream (recorded between 1981 and 1986) was 0.16 cfs, indicating that the 

flow rate has not discernibly changed during the period of active mining. 

Surface mining operations represent a source of coal fines and sediment that is easily eroded by wind 

and flowing water. Without proper drainage protections, these eroded materials can impact surface water 

quality as they are transported downgradient and deposited in stream channels. The system of diversion 

ditches and sediment ponds implemented by TMI helps to prevent these types of water quality impacts. 

TMI’s sediment ponds are designed to treat the runoff and settleable sediment load from a 10-year, 

24-hour storm event (TMI 1981 et seq.). The mine also uses secondary sediment control structures 

called dozer basins to augment the function of designed sediment ponds. The dozer basins are 

constructed in disturbed areas, upstream of the sediment ponds, as excavations with a minimal 

embankment and a notched spillway. They are intended to be temporary structures that are either 

cleaned out periodically, or abandoned in place once they fill up with sediment. Overall, the combination 

of diversion ditches and primary and secondary sediment control structures would reduce potential water 

quality impacts from eroded sediment to negligible levels during the life of mine. 

Other pollutants present in the mine area, such as fuel, oil, hydraulic fluid, and explosives, could impact 

surface water quality through accidental leaks or spills. Slow leaks that remain undetected for a long 

period of time could infiltrate to groundwater, creating localized contamination issues that may eventually 

discharge to surface water. Left untreated, accidental spills also could impact water quality if the 

chemicals are flushed into nearby streams. TMI reduces the potential for these types of impacts through 

implementation of a Spill Prevention, Control, and Countermeasures (SPCC) Plan. BMPs required under 

the SPCC Plan include berms and secondary containment structures around chemical storage areas, 

spill response training for workers, and stocking spill cleanup kits close to the work site. If any inadvertent 

leaks or spills occurred, they would be properly contained and cleaned up, with reporting to appropriate 

agencies as required. Furthermore, operational water quality sampling at the CDPS outfalls shown on 

Figure 3-3 also would enable tracking of water quality to identify and address any unforeseen issues. 

With implementation of these BMPs, potential water quality impacts from accidental spills and leaks 

would be reduced to negligible levels during the life of mine. 

Monitoring records from CDPS site 020 (Figure 3-3) indicate that TDS may have increased in Middle 

Flume Gulch compared to data from the 1970s. As discussed in Section 3.5, the average baseline TDS 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-27 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

concentration in this stream was 1,180 mg/L from 1974 to 1977 (TMI 1981 et seq.). Recent data 

collected between 2005 and 2014 exhibit an average TDS concentration of 1,360 mg/L (HydroEngineering 2015). No analysis was made of whether this increase is statistically significant. However, 

the TDS concentration trend graph for CDPS site 020 shows a distinct jump in TDS concentrations after 

April 2008. 

Increasing surface water TDS would be an expected consequence of mining mostly due to groundwater 

discharge from backfill material. The backfill contains the mineral pyrite, which oxidizes to produce 

sulfate ions in the presence of meteoric water. Increasing sulfate is a major contributor to higher TDS. 

Post-mining, groundwater and surface water TDS would be expected to increase to varying degrees 

across the site depending on the pyritic sulfur content of the backfill material, which typically ranges from 

0.1 to 0.3 percent. These sulfur contents, while generally low for a coal mine, may result in elevated TDS 

and sulfate concentrations which could last for 300 years or more if the entire mass of pyrite in the 

backfill is oxidized (TMI 1981 et seq.). However, calculations presented in the PAP indicate that higher 

surface water TDS derived from the mine would have a negligible impact on the Yampa River over the 

long term, increasing the average TDS of the river by no more than one tenth of 1 percent (TMI 1981 et 

seq.). 

The sulfur content of the coal mined by TMI also is relatively low at less than 0.5 percent (TMI 1981 et 

seq.). At the Trapper Mine, the sedimentary rock-dominated mine spoil material typically contains 

enough carbonate available for dissolution to effectively buffer acidic water generated by pyrite oxidation. 

This buffering capacity helps minimize acid drainage effects and also helps prevent trace metals from 

being mobilized into solution (TMI 1981 et seq.). As such, surface water quality impacts from acid mine 

drainage and trace metals are not expected to occur. 

It also is unlikely that Alternative A would affect the iron impairment in the Yampa River in the short- or 

long-term. As discussed in Section 3.5, baseline surface water quality monitoring at the mine indicated 

that average iron concentrations were generally below the 1 mg/L water quality standard for the Yampa 

River. However, in some cases, individual sample results exceeded the standard even before mining 

was initiated. Discharges from the mine area are currently regulated under CDPS Permit CO-0032115. 

Permitted outfalls directly downstream of the proposed Project Area mine pits include CDPS site 016 on 

Sage Gulch, CDPS sites 020, 021, and 023 on tributaries of Flume Gulch, and CDPS site 022 on Deal 

Gulch (Figure 3-3). No flow has been recorded at CDPS site 016 since 1997, which suggests that the 

eastern portion of the N Pit is unlikely to produce measurable flow in Sage Gulch. The other four outfalls 

are permitted for a maximum 30-day average total recoverable iron concentration of 3 mg/L, and a daily 

maximum total recoverable iron concentration of 6 mg/L (TMI 2012). Over the past 10 years, average 

total iron concentrations recorded at these outfalls have typically been below the 3 mg/L standard, 

ranging from 0.32 to 0.80 mg/L (Hydro-Engineering 2015). These values also are below the water quality 

standard for the Yampa River. 

The primary effluent limitation for total recoverable iron was exceeded at CDPS sites 020 and 021 on 

March 6, 2012, when the reported iron concentrations reached 4.03 and 10.6 mg/L, respectively 

(Hydro-Engineering 2015). These iron values were associated with higher than average flow rates and 

similarly elevated TSS concentrations. The reported iron concentrations were likely influenced by 

suspended sediment in the samples. It also should be noted that under TMI’s CDPS permit, no specific 

effluent limit applies to iron in cases of large discharge volumes caused by precipitation or snowmelt 

events (TMI 2012). Overall, mining operations under Alternative A would be unlikely to affect the Yampa 

River’s iron impairment. Total iron concentrations at permitted outfalls near the Project Area have 

remained similar to baseline conditions and have rarely exceeded primary effluent limitations except 

during large precipitation or snowmelt events. 

Runoff from actively mined areas and groundwater discharge from backfill material could contribute 

elevated selenium concentrations to surface water drainages. TMI’s CDPS permit does not include an 

effluent limit for selenium (TMI 2012). While the future potential for selenium impacts is difficult to 

quantify, baseline and recent water quality samples collected at the mine suggest that there is limited risk 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-28 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

of selenium contamination. Baseline selenium concentrations reported for Flume Gulch and other mine 

drainages generally ranged from about 0.005 to 0.02 mg/L (TMI 1981 et seq.). TMI collected additional 

selenium data from its permitted outfalls after active mining began. From 2005 to 2014, average 

detected selenium concentrations at CDPS sites 020, 021, 022, and 023 were 0.005 mg/L, 0.002 mg/L, 

0.001 mg/L, and 0.01 mg/L, respectively (Hydro-Engineering 2015). These averages were calculated 

using detected concentrations only (i.e., non-detect sample results were excluded), and are consistent 

with baseline values. As long as TMI’s water quality compliance efforts continue to be effective, mining 

operations under Alternative A would pose negligible risk of increasing selenium concentrations in 

Project Area drainages during and after mining. 

Mercury contamination would be another potential water quality issue associated with coal mining. TMI’s 

CDPS permit does not include an effluent limit for mercury (TMI 2012). However, in 2014, TMI began 

sampling for mercury at several of the mine CDPS outfall locations. Although the results have 

consistently indicated mercury is below the detection limit, the analyses to date has not achieved a 

detection limit below the 0.01 microgram per liter mercury standard for the Yampa River (TMI 2015). 

Thus, it is not possible to determine the degree to which (if any) the mine has in the past or would in the 

future contribute mercury to the Yampa River. 

Continued compliance with reclamation requirements and TMI’s CDPS permit would help ensure that 

water quality is maintained throughout the reclamation phase and is suitable for designated uses prior to 

the release of the reclamation bond. Over the long term, final reclamation would further reduce the 

potential for water quality impacts. Mine pits that have been backfilled after mining would result in 

surfaces that would be consistent with the approved post-mining topography and that would be covered 

with topsoil and revegetated. During reclamation, drainage patterns would be re-established per the 

approved reclamation plan and the potential for water quality impacts would be further reduced in part 

because there would be less potential for erosion and spills. 

Overall direct impacts to surface water would be negligible in both the short term and long term. 

Indirect Impacts 

Indirect surface water impacts from the mining of coal would be related to water usage at the Craig 

Station. The Craig Station adjacent to the Trapper Mine diverts surface water in much greater quantities 

than the mine, which would be considered an indirect impact because the mine supplies coal to the 

power plant. The water diverted by the Craig Station comes from the Yampa River, Elkhead Reservoir, 

Yamcolo Reservoir, and other sources as needed. The plant-related diversions averaged about 

12,000 acre-feet per year between 1980 and 2014 (OSMRE 2015). During that same time period, the 

average annual flow of the Yampa River near Maybell, Colorado (USGS Station 09251000, downstream 

of the Craig Station and Trapper Mine) was approximately 1.1 million acre-feet per year (USGS 2015). 

Thus, the Craig Station appropriates about 1 percent of the total Yampa River flow upstream of Maybell. 

The Craig Station has valid water rights for its diversions and could continue using water from the 

Yampa River into the future even if Alternative A is not approved. The impact of these continued 

diversions would be mitigated to some degree by an instream water right (6-02CW106) on the Yampa 

River from Elkhead Creek to the confluence with the Green River (Colorado Water Conservation Board 

2015). The instream water right is designed to maintain minimum flows in the Yampa to support fish 

populations and recreation (Colorado Water Court, Water Division 6 2005). The impact of water 

withdrawals from the Yampa River for use at the Craig Station would be long term and negligible to 

minor. 

Another potential indirect impact from Alternative A would be atmospheric mercury deposition resulting 

from coal combustion, as the mine continues to supply coal to the Craig Station. Atmospheric mercury 

can affect surface water quality as it settles into streams and lakes through precipitation or dry 

deposition. The potential for mercury contamination through atmospheric deposition is extremely 

complex because atmospheric mercury can be derived from any number of local, regional, or global 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-29 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

sources. Thus, it is not possible to determine how much mercury could be deposited in the Yampa River 

or Project Area drainages from continued operation of the Craig Station. 

4.5.1.2 Groundwater 

Direct Impacts 

Under Alternative A, mining in the L and N pits would remove coal from the upper Williams Fork 

Formation. Although, as a whole, the upper Williams Fork Formation acts as an aquitard, individual 

sandstones and coal seams within the unit have been shown to produce water. These discrete water 

bearing zones would be permanently impacted where they are part of either the overburden, interburden, 

or coal removed during mining. Individual units that would be permanently impacted by mining in the 

L Pit include the Second White Sandstone Aquifer, the Third White Sandstone Aquifer, the HI Aquifer, 

and deeper coal units. Intervals planned for mining in the N Pit include the “L,” “M,” and “Q” coal seams. 

Consequently, future mining in the N Pit would permanently impact the KLM and QR aquifers. 

The aquifers would be impacted as the geologic material that transmits groundwater is removed and 

replaced with backfill or mine spoils. TMI refers to these backfilled zones as “spoil aquifers.” The spoil 

aquifers would continue to store and transmit groundwater into the future, and would likely act as a single 

aquifer system, replacing the pre-mine condition of interbedded aquifers and confining units within the 

mine areas. Experience at the mine has shown that some surface water infiltration and re-saturation of 

the spoil aquifers would be expected to occur as evidenced by increasing water levels in backfill 

monitoring wells. Hydraulic conductivity values measured at monitoring wells completed in the spoil 

aquifer range from approximately 0.5 to 5 feet per day (15 to 152 cm per day). This range is comparable 

to native geologic material at the mine (TMI 1981 et seq.). Overall, it appears that TMI’s practice of 

backfilling former mine pits would create a more continuous permanent aquifer system with fewer 

confining layers. The hydraulic conductivity of the spoil aquifers may be similar to pre-mine conditions. 

Alternative A would not disrupt the regional Twentymile Sandstone Aquifer or deeper aquifer units. The 

Twentymile Sandstone is approximately 500 feet (152 meters) deep beneath the SMCRA permit area, 

well below the base of the planned mine pits. Even in areas where mining extends to the deeper “Q” coal 

seam, there would still be another aquitard and aquifer zone (i.e., the “U” Aquifer) that would provide a 

buffer between mining and the top of the Twentymile Sandstone. 

Alternative A could directly impact the Flume Gulch Alluvial Aquifer by removing upstream channel 

segments and alluvial sediments associated with the Flume Gulch drainage. Alluvial sediments that are 

removed to facilitate mining would not be restored during reclamation. Impacts to the Flume Gulch 

alluvium would be expected to be permanent but negligible because only a relatively short tributary 

segment of Flume Gulch would be removed during mining. The alluvium also tends to be thin or absent 

in upstream reaches of the Project Area drainages. 

Spatial data provided by TMI shows that there are two springs in the Project Area: North Horse Gulch 

Spring and Fox Den Spring (Figure 3-3). No impacts would be expected to North Horse Gulch Spring 

because it is located outside of the previously disturbed area and over a mile from both the L and N pits. 

Conversely, the potential for impacts to Fox Den Spring would be higher because the spring is on the 

edge of the previously disturbed mine area, and only about 1,600 feet (488 meters) northeast of the N Pit 

(Figure 3-6). Fox Den Spring exists near the southern limits of the Third White Sandstone (a part of the 

upper Williams Fork member) and is thought to emanate from this unit. To date, mining in the area has 

had no obvious effects on flows from Fox Den Spring, and the spring flow is not expected to be impacted 

during post-mine conditions (TMI 1981 et seq.). Sulfate and TDS concentrations measured at Fox Den 

Spring are similar to levels documented in monitoring wells completed in the Third White Sandstone. 

Long term, the static water level of the spoil aquifer in this vicinity would be expected to be below the 

base of the Third White Sandstone, meaning there would be limited potential for groundwater in the spoil 

aquifer to mix with groundwater discharging from Fox Den Spring. Thus, the water quality of the spring 

likely would not be affected during post-mine conditions (TMI 1981 et seq.). 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-30 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Post-mining, the spoil aquifer also might cause new springs to form as new preferential flow paths would 

be created. The flow regime through backfilled areas would likely be too complex to accurately predict 

where and how many spoil springs could form. However, TMI does not anticipate that spoil springs 

would develop in the Flume Gulch drainage, primarily because groundwater within the spoil aquifer in the 

eastern half of the Project Area would be able to drain into underlying permeable sandstone beds 

(TMI 1981 et seq.). If any spoil springs are identified post-mining, TMI would monitor the spring flows and 

water quality in accordance with the mine’s approved monitoring plan and CDPS discharge permit. 

Under Alternative A, groundwater would continue to be used for dust suppression and potable purposes. 

During water year 2014, TMI dewatered approximately 131 acre-feet of groundwater from its mine 

operations (Cummins 2015). The entire dewatering volume was pumped to an inactive mine pit and 

stored for later use as dust suppression water on the mine’s haul roads and topsoil stockpiles. In addition 

to the dewatering water, TMI used another 195 acre-feet for dust suppression supplied from other inputs 

flowing into the inactive pit. These inflows included direct precipitation, runoff into the pit, groundwater 

discharge, and approximately 20 acre-feet of return flow from the Craig Station (Cummins 2015). 

Overall, dust suppression at the mine consumed 326 acre-feet during water year 2014. During that 

timeframe, TMI also pumped approximately 32 acre-feet of groundwater for potable use from its 

permitted water supply well in the Twentymile Sandstone (Cummins 2015). Water used for dust 

suppression and potable purposes represents a minor depletion of potentially non-renewable 

groundwater within the upper Williams Fork and Twentymile Sandstone aquifers. These depletions are 

conducted in accordance with Colorado water law under a court-approved augmentation plan decreed in 

Case No. W1178-77. By complying with this plan, groundwater and surface water depletions caused by 

mine operations would be effectively managed during mining to avoid impacts to senior water rights and 

downstream users. 

Domestic wells within one mile of the Project Area are generally completed in the Third White Sandstone 

or deeper water-bearing units (TMI 1981 et seq.). Groundwater level drawdown resulting from mine 

dewatering could lower the static water levels in these wells. The potential for this impact was evaluated 

by reviewing groundwater hydrographs from monitoring wells installed in the vicinity of the L Pit. The 

monitoring wells in this area, shown on Figure 3-5, include GC-2 and GP-9 in the Third White 

Sandstone, GC-1 and GP-7 in the HI Aquifer, and GP-2 and GP-8 in the KLM Aquifer. The PAP 

suggests that mining would not significantly affect groundwater levels in the Third White Sandstone 

because the nearest Third White Sandstone well is approximately 6,000 feet (1,829 meters) north of the 

surface mine area (TMI 1981 et seq.). This statement is supported by hydrographs from wells GC-2 and 

GC-9, which reveal that water levels have actually increased in the Third White Sandstone over the past 

15 years. In the HI Aquifer, water level trends have been inconsistent. A sharp increase in water levels 

has occurred in GC-1 since 2009, while water levels have gradually fallen in GP-7 since 2001, 

registering a total decrease of 14 feet (four meters). In contrast, large declines in the KLM Aquifer 

potentiometric surface began in the late 1990s to early 2000s. The total decreases observed in wells 

GP-2 and GP-8 were around 31 feet and 37 feet (nine to 11 meters), respectively (Hydro-Engineering 

2015). The water levels in these wells have since rebounded to some degree and are approaching their 

static levels. 

Groundwater drawdown typically diminishes with distance from a pumping or dewatering source. Most of 

TMI’s monitoring wells are closer to the mining area than the nearest domestic water wells (Figure 3-5), 

so actual drawdown in the domestic wells is expected to be less than the changes observed in on-site 

monitoring wells. As such, based on recent water level trends, groundwater declines in the nearby 

domestic wells should be no more than about 30 feet (nine meters) in the KLM Aquifer, and no more 

than 14 feet (four meters) in the HI Aquifer. These impacts would be negligible because the private wells 

within one mile of the Project Area had on average 250 feet (76 meters) of available head at the time of 

installation (Colorado Division of Water Resources 2015). Any water level declines from mine-induced 

drawdown would be short term and minor and would not impact the long-term viability of these wells. 

Accidental leaks or spills of chemicals used in the mining process would have the potential to impact 

groundwater quality without prompt action to clean up the spill and contaminated soil material. TMI would 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-31 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

reduce the potential for these types of impacts through implementation of their SPCC Plan. Any 

inadvertent leaks or spills would be properly contained and cleaned up, with reporting to appropriate 

agencies as required. Furthermore, operational water quality sampling at monitoring wells shown on 

Figure 3-5 would enable tracking of water quality to identify and address any unforeseen issues. With 

implementation of these BMPs, potential water quality impacts from accidental spills and leaks would be 

reduced to negligible levels. 

Groundwater quality also would have the potential to be impacted by leachate from mine spoils and by 

infiltration of mine runoff. In areas where mine spoils contain pyritic sulfur, impacts from leachate would 

be discernible through changes in groundwater TDS and sulfate concentrations. Table 4-16 presents 

baseline and recent TDS and sulfate concentrations for several monitoring wells near the Project Area. 

The well locations are shown on Figure 3-5. The table illustrates that as expected, average TDS values 

during the period of active mining (assumed to be the last 10 years) increased relative to baseline 

concentrations by as much as 40 percent. The trend of increasing TDS concentrations holds true for 

aquifers in both the upper Williams Fork member (i.e., the Third White Sandstone and HI interval) and 

the alluvial aquifer. Sulfate concentrations also increased over baseline values in three of the four 

monitoring wells, suggesting an influence from pyritic sulfur. Higher groundwater TDS and sulfate 

concentrations in mined and reclaimed areas would be expected and would likely persist for many years 

as pyritic sulfur in spoil material is slowly oxidized. These groundwater quality impacts are considered 

minor because they would be confined to localized areas around the mine spoils. To the extent that 

impacted groundwater from the mine discharges to surface water, it still would not contain enough 

dissolved solids to increase the TDS concentration of the Yampa River above predetermined material 

damage levels (CDRMS 2010). 

Table 4-16 Summary of Groundwater Quality Data for Selected Constituents 

Site ID1 

Aquifer 

Interval Sampling Period 

Total Dissolved 

Solids 

(TDS) 

Sulfate 

(SO4) 

Iron (Fe) 

(total recoverable) 

n mg/L n mg/L N mg/L 

GC-1 HI 1974-1985 for TDS and 

SO4, 1981-1985 for Fe 

20 893.8 13 312.1 13 7.6 

2005-2014 20 1,027.4 10 359.0 10 0.8 

GC-2 Third 

White 

Sandstone 

1974-1985 for TDS and 

SO4, 1981-1985 for Fe 

15 728.0 9 419.0 1 11.2 

2005-2014 20 1,036.4 10 364.0 10 2.0 

GC-3 Alluvium 1974-1985 for TDS, 

1981-1985 for Fe, 

1974-1985 for SO4 

19 1,077.3 12 347.2 15 50.5 

2005-2014 46 1,402.3 10 552.0 34 1.7 

COY Alluvium 1974-1985 for TDS, 

1981-1985 for Fe, 

1974-1985 for SO4 

3 1,690.0 3 815.7 7 13.8 

2005-2014 20 1,920.0 10 1,002.0 10 0.5 

See Figure 3-5 for well locations. 

n = Number of observations. 

Grey highlighting represent the more recent sampling data. 

Source: Hydro-Engineering 2015. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

1 

4-32 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Indirect Impacts 

Table 4-16 shows total recoverable iron concentration results for baseline and recent time periods. The 

iron data are important because they provide a measure of potential indirect impacts from iron mass 

loading as groundwater from the spoil aquifer discharges into Project Area drainages. In the small subset 

of wells presented in the table, total iron concentrations decreased markedly compared to average 

baseline values. It is difficult to pinpoint an exact reason for this decrease. However, the data suggest 

that native groundwater in the Project Area had high iron content prior to mining, and that mining would 

be unlikely to worsen this condition. Based on this information and discussion presented in 

Section 4.5.1.1, Alternative A would be unlikely to affect the iron impairment in the Yampa River. 

CCRs produced at the Craig Station as part of the coal combustion process are hauled for CCRs 

placement at the Trapper Mine, outside of the Project Area. CCRs placement would be an indirect effect 

of Alternative A. The placement site is under the jurisdiction of the SMCRA permit and is approved to 

receive CCRs under a Certificate of Designation from Moffat County, with regulatory oversight from 

CDPHE. The placement site, CCRs placement requirements, design features, operating criteria, 

monitoring requirements, closure and post-closure monitoring standards, and record-keeping and 

reporting requirements are regulated under the SMCRA permit and through CDHPE. Further, 

groundwater monitoring at the site indicates that metals of potential concern in the CCRs material are 

present at low levels in site groundwater; however, limited permeability and infiltration has kept these 

concentrations within background ranges observed elsewhere at the mine. Therefore, the potential 

indirect impact to groundwater as a result of CCRs placement at the Trapper Mine would be long-term 

and negligible. 

Overall, potential direct and indirect impacts to surface water and groundwater resources under 

Alternative A are expected to be negligible to minor and short- to long-term. 

4.5.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM 

4.5.2.1 Direct Impacts 

Under Alternative B, mining in the Project Area would cease. There would be no further disruption of 

Project Area stream channels, and no further effects to downstream flows or water quality. Similarly, 

there would be no additional effects to groundwater springs or interception of groundwater within the 

Project Area. Alternative B would not, however, preclude mining in other portions of the SMCRA permit 

boundary outside of the Project Area. Mining would likely continue in the N Pit outside of the Project Area 

and in the I Pit in the western SMCRA permit area (Figure 2-4). Surface water and groundwater impacts 

from mining in these areas would be similar in nature to impacts from Alternative A. 

The area of the anticipated N Pit has previously been mined to remove the “H” and “I” seams, and has 

been partially reclaimed. This area would be reopened under Alternative B to recover deeper coal 

intervals. This would essentially undo reclamation efforts at the N Pit and would alter the drainage 

characteristics of East Pyeatt Gulch. Runoff from the N Pit would be captured in diversion ditches and 

routed to a sediment pond associated with CDPS outfall 011. Flow rates in East Pyeatt Gulch could be 

impacted as runoff is captured in this pond, but a comparison of baseline and recent flow data from the 

gulch suggests that the impact would be negligible. The average flow rate in East Pyeatt Gulch was 

0.36 cfs during the baseline monitoring period (1981 to 1986) and increased to 0.45 cfs during the 

previous 10 years of mining and reclamation (Hydro-Engineering 2015; TMI 1981 et seq.). No 

assessment was made of whether this change is statistically significant; the increase appears mainly to 

be driven by a period of high flows that occurred during the spring and summer of 2009. TMI also has a 

long period of water quality data available for East Pyeatt Gulch dating back to the mid-1970s. The data 

indicate that TDS concentrations in the gulch have not appreciably changed since the baseline period. 

The average baseline TDS concentration was 2,070 mg/L compared to recent TDS concentrations that 

averaged 1,910 mg/L over the past 10 years (Hydro-Engineering 2015; TMI 1981 et seq.). These data 

suggest that short and long term flow and water quality impacts to East Pyeatt Gulch would likely be 

negligible under Alternative B. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-33 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Construction of the anticipated I Pit would directly alter the drainage characteristics and watersheds of 

Coyote Gulch and No Name Gulch. The area of the I Pit in the western SMCRA permit boundary has not 

been previously mined, but areas of No Name Gulch and Coyote Gulch upstream of the I Pit have been 

mined, and post-mining drainage flows into the No Name and Coyote Gulch ponds. Samples collected 

from the pond outfalls indicate that TDS concentrations associated with No Name Gulch and Coyote 

Gulch initially increased relative to baseline but are gradually decreasing post-mining as reclamation 

takes effect. For example, at No Name Gulch (CDPS outfall 002), the average TDS concentration has 

changed from 1,580 mg/L during the 1970s baseline monitoring period, to 1,930 mg/L between 1995 and 

2004, and then to 1,850 mg/L between 2005 and 2014. TDS concentrations have trended similarly at 

Coyote Gulch (CDPS outfall 005), from an average of 340 mg/L during baseline, to 730 mg/L between 

1995 and 2004, and back to 340 mg/L between 2005 and 2014 (Hydro-Engineering 2015). Hydrologic 

data collected from the No Name Gulch pond and the Coyote Gulch pond as well as near the L and 

N Pits suggest that implementation of TMI’s CDPS Permit and drainage control measures would help 

limit surface water quality and quantity impacts to negligible levels in the short term and long term. 

Mining of the N and I pits under Alternative B would directly impact groundwater in the upper Williams 

Fork Formation by removing native water-bearing strata and replacing the strata with backfill or mine 

spoils. In the N Pit, this would affect the KLM and QR aquifers; water-bearing intervals above the “H” and 

“I” coal seam were already removed during the previous phase of mining. As the pits are backfilled, the 

footprint of the spoil aquifer would increase. This could have implications for development of spoil 

springs as new preferential flow paths develop through the spoil material. There is already a well-defined 

spoil spring on the western edge of the N Pit known as the East Pyeatt South Spring. In the 10 years 

since this spring has been monitored, TDS and sulfate concentrations have ranged from 2,200 to 

3,300 mg/L and 980 to 1,630 mg/L, respectively (Hydro-Engineering 2015). These concentrations could 

increase through time as pyritic sulfur in the spoil material is slowly oxidized. 

An important difference between Alternative A and Alternative B is the rate and duration of mining. Coal 

reserves in the N and I pits are smaller and would be depleted by 2020 after only three to four years of 

mining (available coal reserves are projected to last until 2025 under Alternative A). In the absence of 

additional reserves, final reclamation would be implemented across the mine after completion of mining 

in the N and I pits by backfilling open mine pits, grading the backfill to achieve the approved post-mining 

topography, removing buildings and structures, replacing topsoil, and reseeding the reclaimed areas. By 

re-establishing vegetation, reclamation would gradually reduce erosion from the Project Area, reduce 

sediment loads in runoff, and eliminate the need for runoff to be captured in sediment ponds. Final 

reclamation would occur five to six years earlier than Alternative A based on the currently identified coal 

reserves available under Alternative B. 

Indirect Effects 

Under Alternative B, the mine would continue to supply coal to the Craig Station until approximately 

2020, albeit at an estimated reduced rate of 1.5 mtpy from reserves outside of the Project Area. There is 

currently no evidence that a diminishing coal supply from Trapper Mine would affect the Craig Station; if 

the mine stopped operating or reduced coal production, the plant would presumably obtain coal from 

another source. As long as the Craig Station continues to burn coal, it would continue to divert water for 

cooling, generate emissions, and produce CCRs. Indirect water resource impacts from these activities 

would be the same as Alternative A. 

Overall, potential direct and indirect impacts to water resources under Alternative B are expected to be 

negligible to minor and short-term to long-term. 

4.5.3 Mitigation Measures 

No mitigation measures would be necessary for water resources. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-34 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

4.6 Soils 

4.6.1 Alternative A – Proposed Action 

4.6.1.1 Direct Impacts 

The proposed disturbance from July 2015, to the life-of-mine for the Project Area would affect 

approximately 257 acres (Table 4-17). As part of the mining process, topsoil would be removed using 

scrapers or similar equipment typically between May and October. The soil would typically be hauled 

directly to reclamation areas for immediate use or placed in stockpiles. If placed in temporary stockpiles, 

the stockpiles would be graded with 3H:1V outslopes and would be temporarily revegetated for 

stabilization. Topsoil would be salvaged during development of the pit, and during development of 

overburden stockpiles, temporary stockpiles, access roads and sediment ponds. A and upper B horizon 

soils would be removed for re-use, unless the soils are clayey or stony. 

Table 4-17 Disturbance to Soil Types, Proposed Action Alternative 

Soil Unit 

Approximate 

Disturbed Acres 

Adderton loam, 1 to 10% slopes 1.2 

Bulkley silty clay, 3 to 12% slopes 20.4 

Cochetopa loam, 12 to 25% slopes 52.8 

Foidel loam, cool, 3 to 35% slopes 36.0 

Foidel loam, 25 to 65% slopes 28.4 

Hesperus fine sandy loam, dry, 2 to 15% slopes 1.4 

Lamphier fine sandy loam, 3 to 25% slopes 70.5 

Lamphier fine sandy loam, 25 to 65% slopes 10.1 

Ustorthents, frigid-Borollis complex, 25 to 75% slopes 7.3 

Winevada-Splitro complex, 3 to 25% slopes 29.3 

Total 257 

A horizon soils are generally high in organic matter but structurally weak, while upper B horizons have a 

moderately stable structure, but tend to be higher in clay near the C horizon interface. TMI would salvage 

the A and upper B horizon soils together where they become mixed. This mixing can serve to increase 

fertility of more sterile clay soils and help soils heavy in organic matter become more stable and resistant 

to erosion. The lower B and C horizons would not be salvaged due to their clayey nature that makes 

them infertile with weak soil structure. In areas where there is rocky ground or terrain, topsoil salvage is 

not always practiced. Where the terrain varies and topsoil salvage would be practicable, or where the 

horizon depths change, soils would be salvaged at varying depths within the profile. This can provide for 

a more loamy mixture or a slightly heavier mix with more clay. 

Within the Trapper Mine Project Area soils would be used for reclamation to achieve a post-mining land 

use of rangeland and wildlife habitat. Rangeland and wildlife habitat dedicated reclamation areas would 

receive approximately 12 inches of topsoil. Where possible, soils would be moved from salvaging in new 

areas directly to reclamation sites to minimize impacts to the chemical, physical, and biological 

properties of the soil. Direct haul of soils would be the preferred method for reclamation practices due to 

the less disruptive, direct placement, and preservation of the natural components of the soil. Direct 

hauling prevents compaction and chemical changes that would otherwise occur during long periods in a 

stockpile. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-35 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Stockpiled soils would be vegetated with fast growing native species prior to winter months. These soils 

can lose fertility, organic matter content, and microbial activity during stockpiling or become compacted 

or lose their capacity to retain water. Should compaction occur, TMI would use methods to break up the 

soil (e.g., discing) once placed in reclamation areas to fluff the soil and aid with the seeding process. 

Impacts to soil resources in the Project Area would be minor in the short term and negligible in the long 

term following reclamation. The process of salvaging the A and upper B horizons together mixes the soil 

horizons. The net environmental effects of mixing horizons can be difficult to predict because it can make 

poor soils more productive and stable in areas that were unproductive before mining but also may have 

the effect of making previously productive areas less productive, leading to difficulty with revegetation of 

some species. TMI’s record of reclamation and bond release shows that the reclamation techniques 

practiced at the Trapper Mine are successful. 

4.6.1.2 Indirect Impacts 

There are no indirect impacts to soils under Alternative A. 

4.6.2 Alternatives B – Disapproval of the Mining Plan Modification by the ASLM 

4.6.2.1 Direct Impacts 

Under Alternative B mining would cease and no new ground disturbance would occur within the Project 

Area. Reclamation activities would occur in the Project Area through backfilling and grading the existing 

disturbed area to the approved post-mining topography, topsoil replacement, and revegetation within the 

Project Area. Structures and equipment would be broken down and moved to new mining areas outside 

of the Project Area. These activities would last three to five years and proceed through the Phase III 

bond release, expected to be completed within an additional 10 to 15 years. Additional mining within the 

SMCRA permit boundary would cause disturbance to the soils within the N and I pit areas outside of the 

Project Area. The area of the N Pit has been previously disturbed and soils have been salvaged for 

reclamation. The I Pit soils have not been previously disturbed. Similar techniques for topsoil salvage 

and replacement would be practiced for areas outside of the Project Area. 

Impacts to soil resources would be minor in the short term and negligible in the long term after 

reclamation activities. 

4.6.2.2 Indirect Impacts 

There are no indirect impacts to soils under Alternative B. 

4.6.3 Mitigation Measures 

No mitigation measures would be necessary for soils. 

4.7 Vegetation 

4.7.1 Alternative A – Proposed Action 

4.7.1.1 Direct Impacts 

Alternative A would remove approximately 257 acres of mountain shrubland through new disturbance 

over the next 10 years. Current disturbance of 1,053 acres exists in the Project Area. This previous 

disturbance also was mountain shrublands. Under the approved reclamation plan for the SMCRA permit, 

approximately 494 acres of previously disturbed mountain shrubland have been reclaimed to 

rangeland/wildlife habitat within the Project Area and approximately 178 acres of the reclaimed area has 

achieved Phase III bond release. The remainder of the current disturbance and future disturbance also 

would be reclaimed to rangeland and wildlife habitat, dominated by native perennial grasses and a 

mixture of native shrubs and forbs. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-36 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Mountain shrubland may not regenerate; previous reclamation areas have trended to establishment of a 

big sagebrush-grass community as it matures. The total time through Phase III bond release would be 

approximately 23 to 30 years. The total amount of impacted mountain shrubland vegetation (257 acres) 

would be small in comparison to that available in the region. 

The potential for acid generating mine spoil underlying replaced topsoil and inhibiting plant growth has 

been evaluated by TMI on graded spoil throughout the SMCRA permit boundary. The test results have 

demonstrated that the Trapper Mine spoil is inert and will not inhibit plant growth. Based on past testing 

results, CDRMS no longer requires TMI to test spoil prior to topsoil placement and revegetation. 

The direct impact to vegetation would be minor and long-term until reclamation is complete and 

vegetation has become established. 

The additional disturbance increases the potential for the establishment and spread of noxious weeds. 

However, with implementation of established protocols to identify noxious weeds and TMI’s current weed 

control practices, according to State regulations and CDRMS guidelines, the overall impact in the Project 

Area would be negligible. 

4.7.1.2 Indirect Impacts 

There are no indirect impacts to vegetation. 

4.7.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM 

4.7.2.1 Direct Impacts 

Under Alternative B, all mining related activities in the Project Area would cease and closure and 

reclamation of the 1,053 acres of currently disturbed land would be initiated. The existing disturbance 

would be reclaimed to rangeland/wildlife habitat. There would be no further impacts related to future 

disturbance and conversion of plant communities from mountain shrubland to reclaimed rangeland 

habitat. The reclamation of previously disturbed lands would be conducted using native grasses, forbs, 

and shrubs planted with prescribed seed mixes. Additional vegetation disturbance would occur in the 

N and I pits outside the Project Area. The N Pit has been previously disturbed and reclaimed. The I Pit 

would be new disturbance. The mining activities outside of the Project Area would occur over three to 

four years, followed by reclamation. Overall the reclamation within the Project Area and mining and 

reclamation in other areas would take from 17 to 25 years, slightly less time than Alternative A. The 

impacts would be the same as described for Alternative A; minor and long-term until reclamation is 

complete and vegetation has become established. 

4.7.2.2 Indirect Impacts 

There are no indirect impacts to vegetation from Alternative B. 

4.7.3 Mitigation Measures 

No mitigation measures would be necessary for vegetation. 

4.8 Wetlands and Riparian Zones 

4.8.1 Alternative A – Proposed Action 

4.8.1.1 Direct Impacts 

Mining operations within the Project Area have resulted in the disturbance of 0.399 acre of wetlands. No 

additional wetlands disturbances would occur as part of Alternative A. The existing impacts to the 

disturbed wetlands have occurred from January 21, 1998, and would continue through the final mine 

closure. The wetlands disturbance was permitted under USACE Nationwide Permit 21, permit 

number 199875575. Nationwide Permit 21 covers the dredge and fill activities associated with wetland 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-37 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

loss due to surface coal mining activities. The USACE determined that dredged and fill material released 

in waters of the U.S. would not impact threatened or endangered species. Wetlands mitigation would be 

conducted in accordance with TMI’s reclamation plan. TMI would reestablish the approved post-mining 

topography contour within the Project Area. This contouring would replace the drainage bottoms 

approximately to their previous character, resulting in new fringe wetlands in accordance with SMCRA 

Permit C-1981-010. In addition, TMI has volunteered to take steps to protect 1.46 acres of wetlands 

created from past reclamation activities outside of the Project Area on CSLB-managed lands. 

There would be no new impacts to wetlands under Alternative A. 

4.8.1.2 Indirect Impacts 

Indirect impacts to wetlands could occur from water quality impacts associated with Alternative A. As 

discussed in Section 4.5, impacts to water quality are expected to be negligible to minor and short-term 

to long-term. 

4.8.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM 

4.8.2.1 Direct Impacts 

Under Alternative B no additional impacts would occur to wetlands, waters of the U.S., and riparian 

areas within the Project Area. Reclamation of the existing impacts to 0.399 wetlands within the Project 

Area would be the same as described for Alternative A. The reclamation measures currently in place 

would continue through the Phase III bond release ensuring the Project Area under Alternative B would 

be reclaimed in the same manner as under the life of mine plan of Alternative A. Reclamation includes 

re-contouring of land, revegetation, and erosion and sediment control. 

New disturbance would occur outside of the Project Area within the SMCRA permit boundary. The N Pit 

area has been previously disturbed and new mining activities would result in no new wetlands 

disturbance. Prior to disturbance associated with mining in the I Pit, a new wetlands inventory would 

occur and, if wetlands are determined to be present, mitigation measures would be implemented. These 

mitigation measures would be designed to reduce wetlands impacts to minor to negligible. Overall 

impacts from Alternative B are expected to be negligible to minor and short- to long-term until completion 

of any needed wetlands mitigation and re-establishment of drainage patterns upon completion of mining 

and reclamation. 

4.8.2.2 Indirect Impacts 

Indirect impacts to wetlands could occur from water quality impacts associated with Alternative B. The 

indirect impacts under Alternative B would be the same as discussed for indirect impacts under the 

Alternative A. 

4.8.3 Mitigation Measures 

The proposed disturbance from July 1, 2015, to the life-of-mine within the Project Area would not affect 

additional wetlands. The existing 0.399 acre of impacts to wetlands was disturbed under current mining. 

Mitigation measures for these wetlands would occur during the reclamation process by restoring the area 

to the approximate original topography. No additional mitigation measures are necessary for wetlands. 

4.9 Fish and Wildlife Resources 

4.9.1 Alternative A – Proposed Action 

4.9.1.1 Direct Impacts 

Short-term impacts to wildlife, lasting a few minutes to less than five years, would occur primarily through 

gradual loss of habitat and disturbance by mining and human presence. These impacts, as described 

below, would be minor. Areas of habitat that are lost due to mining (257 acres) are less than 1 percent of 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-38 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

available habitats in the region and the related activities within the Project Area would be reclaimed 

contemporaneously, as soon as mining has progressed beyond to the next mine pit and it is safe to 

begin reclamation. At the end of the Project, all disturbed mine land and support infrastructure would be 

reclaimed in accordance with the approved reclamation plan, which includes goals to replace or improve 

wildlife habitat. At the end of the Project, disturbance to wildlife as a result of noise (Section 4.17) and 

human activity would cease (10 years to completion of mining and an additional three to five years to 

complete reclamation activities). Full Phase III bond release would likely occur in the following 10 to 

15 years. The time required for development of a mature big sagebrush community is difficult to predict 

given the many factors which could affect the development of this community. 

Big Game 

Within the Project Area, Alternative A would remove land that is coincident with big game ranges. 

Alternative A would remove 257 acres of mule deer summer range, and a smaller portion of winter 

range. Likewise, Alternative A would remove 257 acres of elk summer and winter range, with a small 

portion of that also being classified as winter concentration area. The disturbance also would remove 

257 acres that are categorized as overall and summer range for moose, overall range and fall 

concentration area for black bear, production area for elk, and a small amount of habitat designated for 

the resident elk population. General habitat for mountain lions and pronghorn also would be impacted. 

The impact would be short-term, until contemporaneous reclamation is successful in reestablishing these 

habitats within the Project Area. With contemporaneous reclamation, impacts to these habitats would be 

negligible, primarily due to the focus on reclamation and revegetation for wildlife habitat. 

Big game would tend to displace from areas being disturbed to areas outside of the Project Area and 

would avoid active mining sites and infrastructure. Based on observations at the existing mining 

operations, within the SMCRA permit boundary, both elk and mule deer have acclimated to the 

disturbance from mining operations and exist in proximity to the disturbance associated with mining. 

Herds are commonly found on previously and newly reclaimed areas that are adjacent to active mining 

operations. With foraging opportunities available, mountain lions and black bears could use the Project 

Area but may reduce use due to noise and mine activities. The overall impact due to displacement would 

be minor and short-term, lasting only during the active mining years and until contemporaneous 

reclamation activities are complete in any area within the Project Area. 

Migratory Birds 

Direct impacts to migratory birds within the Project Area could include mortalities and injuries to birds 

and eggs in unidentified nests. Disturbance to 257 acres of suitable habitat in mountain shrub vegetation 

could reduce nesting opportunities for species adapted to habitats in those areas. Migratory birds also 

would tend to be displaced from active mining areas; however, with contemporaneous reclamation, 

habitat would become available to birds adapted to grassland and early successional shrubland habitats 

within three to five years. Mountain shrubland habitats are more widely available outside the Project 

Area. 

Noise produced by mining operations also may affect migratory birds. Noise can interfere with 

establishment of breeding territories for songbirds that vocalize during breeding, or interfere with alarm 

calls of birds and mammals (Larkin 1996; U.S. Department of the Interior 2003). These impacts would be 

localized and short-term in any active mining areas. The overall impact would be negligible due to the 

limited acres of disturbance at any one time, availability of habitat outside of the Project Area and 

contemporaneous reclamation. 

Raptors 

Direct impacts to raptors could result from vehicle strikes. However the possibility would be negligible 

due to implemented design features and speed control. Therefore, the primary impacts that may result to 

raptors under this alternative would be from loss of 257 acres of potential foraging habitat and 

disturbance to individuals perching within the Project Area. Foraging opportunities could return on 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-39 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

contemporaneously reclaimed land in three to 15 years. Noise and human presence could disturb 

individuals that forage or perch in the area. Potential disturbance from mining and reclamation activities 

would end within three to 15 years, depending on the mining and reclamation schedule for each area. 

Nesting habitat is limited in the Project Area and vegetation removal could reduce nesting opportunities 

to a minor extent. Nesting raptors are often sensitive to disturbance from human related activities, 

particularly prior to eggs being laid. Raptors may abandon nests with eggs or become less attentive to 

hatchlings, thus increasing the potential for mortality from predation or exposure. The amount of 

disturbance that an individual raptor will tolerate varies among species and individuals (CPW 2003) and 

the degree to which an individual has acclimatized to human activity. Impacts to nesting raptors could 

extend beyond the actual disturbance area up to 0.5 mile (0.8 km) away (CPW 2003). Only two known 

nest sites are within this disturbance range, and none are known from the proposed disturbance area 

within the Project Area. The known nests near the Project Area include a golden eagle nest and a prairie 

falcon nest; there are no nests that would be impacted directly by the Project. The direct impact to 

raptors would be minor and short-term due to the limited habitat lost relative to that available in the 

region, the limited duration of mining activities and contemporaneous reclamation allowing foraging 

opportunities to be regained. 

Small Mammals and Reptiles 

In addition to the loss of habitat for small mammals and reptiles, some mortality could occur from 

construction, mining activities, and vehicle operation. The loss of approximately 257 acres of mountain 

shrubland with possible habitat would be negligible compared to the existing available habitat in the 

region outside the Project Area. Habitat would develop on disturbed lands within three to 15 years for 

most species with contemporaneous reclamation. The direct impact would be short-term and minor. 

Fisheries 

Direct disturbance to aquatic habitat and species within the Project Area would be limited to ephemeral 

streams, which support macroinvertebrates when water is present. Some of these may be disturbed by 

mining over the next 10 years. Contemporaneous reclamation would return functional channels to the 

post mining landscape within a short period of time of completion of mining in any given area. Fish are 

not present in these streams due to the lack of water on a consistent basis. Direct impacts to fisheries 

would be short-term and negligible. 

4.9.1.2 Indirect Impacts 

Potential indirect impacts could occur in the Yampa River, located approximately 4.5 miles (7.2 km) 

north of the Project Area, as a result of potential discharges from the Project Area to the Yampa 

River or as a result of emissions from coal combustion at the Craig Station. 

Surface disturbance increases the potential for localized sediment input to ephemeral streams. However, 

sediment control structures, sediment ponds, and diversion ditches would be used as part of project 

design features, which would reduce the amount of sediment that could potentially be carried 

downstream. In addition, mining activities near streams would pose a risk of petroleum product or 

hazardous material spills. As part of the project design features, a SPCC Plan would be implemented to 

reduce risk of a spill and the potential to affect aquatic habitat and macroinvertebrates. The potential 

impacts to water quality are discussed in Section 4.5. The potential effects of mine dewatering and water 

use and emissions from the Craig Station on fish species in the Yampa River are discussed in 

Section 4.10, Special Status Species. The indirect impacts to fisheries could be short-term and long-term 

and would be negligible due to the controls implemented to prevent impacts to off-site water quality and 

habitat degradation. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-40 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

4.9.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM 

4.9.2.1 Direct Impacts 

Under Alternative B, all mining-related activities in the Project Area would cease and closure and 

reclamation would be initiated on the existing disturbance within the Project Area. There would be no 

further impacts as a result of habitat loss related to the proposed 257 acres of additional disturbance. 

The reclamation of wildlife habitat and the cessation of noise and human disturbance would occur earlier 

in the Project Area than under Alternative A, but would have the same overall short-term, negligible to 

minor impacts as Alternative A until reclamation activities cease and reclamation is successfully 

established. 

However, mining would continue in areas outside of the Project Area. As a result, direct impacts would 

continue until reclamation activities have ceased and reclamation has been successfully established in 

areas within and outside of the Project Area. Impacts similar to those described for Alternative A would 

continue to occur in areas outside the Project Area until mining ceases at Trapper Mine. 

4.9.2.2 Indirect Impacts 

Reclamation activities would continue for three to five years, during which a lower-level of impacts 

(described above) would continue to affect big game, raptors, migratory birds, small mammals and 

reptiles. There would be no additional indirect impacts to fisheries. Impacts would diminish appreciably 

upon completion of reclamation. Big game would eventually lose improvements to habitat in the 

disturbed areas, as reclaimed rangelands mature and develop a uniform structure, similar to the big 

sagebrush rangelands in the region. 

4.9.3 Mitigation Measures 

No mitigation measures would be necessary for wildlife. 

4.10 Special Status Species 

4.10.1 Alternative A – Proposed Action 

4.10.1.1 Direct Impacts 

Several special status species are known in the vicinity of the Project Area or have habitat within or in 

the vicinity of the Project Area. These species include BLM sensitive species and Colorado species of 

concern. Federally listed species do not occur within or near the Project Area but do occur in a wider 

analysis area and are discussed for potential direct and indirect impacts. 

Northern Leopard Frog 

The northern leopard frog has not been observed within the Project Area but is known to occur in the 

vicinity. Alternative A would have negligible direct impact on the northern leopard frog since it does not 

occur in the Project Area. 

Golden Eagle 

Golden eagles are known to use the Project Area for foraging, and there is a known golden eagle nest 

within 0.5 mile of the Project Area. Golden eagles could be impacted by noise and mine activity under 

Alternative A. This could result in individuals avoiding or flushing from foraging areas or perch sites in the 

Project Area. A total of about 257 acres of vegetation removed through mine activities would impact 

habitat for rabbits, hares, and ground squirrels – the staples of the golden eagle diet. This would directly 

result in lower foraging opportunities for golden eagles in the Project Area when vegetation is cleared, 

but the area is small compared to the total foraging habitat surrounding the Project Area. There is a small 

possibility for golden eagles to collide with vehicles operating in the Project Area, but the potential is 

small due to the limited occurrence of golden eagles in the Project Area and enforcement of speed limits 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-41 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

within the Project Area. Direct impacts to this species would be negligible due to the limited amount of 

foraging habitat that would be affected (less than 1 percent) compared to that available in the region and 

the limited possibility of direct mortality. 

Burrowing Owl 

Burrowing owls have not been documented within the Project Area but have been documented on 

reclaimed lands to the west of the Project Area. Alternative A would have little direct impact on the 

burrowing owl. No potential habitat would be removed for mining operations. There is a small possibility 

that burrowing owls could be struck by moving vehicles during the course of normal operations. Overall, 

direct impacts to this species would be negligible due to no disturbance of suitable habitat, lack of a 

documented presence of the species within the Project Area and the unlikelihood of direct mortality due 

to enforcement of speed limits. 

Ferruginous Hawk 

Ferruginous hawk habitat exists within the Project Area, but this species has not been documented in the 

Project Area. Alternative A would have little direct impact on the ferruginous hawk because of its lack of 

documented presence. Foraging habitat for the species exists in reclaimed rangeland and the big 

sagebrush-grass community. No big sagebrush-grass vegetation and only a small amount (11 acres) of 

reclaimed rangeland may be re-disturbed. Potential foraging opportunities for ground squirrels and 

rabbits in the Project Area would remain intact. Noise and mine activity under Alternative A could result 

in individuals avoiding or flushing from foraging areas or perch sites in the Project Area if these were 

used in the future. There is little to no possibility that ferruginous hawks could be struck by moving 

vehicles during the course of normal operations due to the lack of their documented presence within the 

Project Area and the enforcement of speed limits. Overall, the direct impacts to this species would be 

negligible due to the limited amount of habitat for the species in the Project Area and the unlikelihood of 

individuals using the Project Area in the next nine to 10 years. 

Peregrine Falcon 

American peregrine falcon habitat is limited within the Project Area, and this species has not been 

documented within the Project Area. Alternative A would have little direct impact on the peregrine falcon. 

Foraging habitat for the species exists in native habitats and on reclaimed rangeland. Vegetation cleared 

for mine activities would remove about 257 acres of mountain shrubland and habitat for small birds; thus, 

reducing potential foraging opportunities for peregrine falcons. There is little to no possibility that 

peregrine falcons could be struck by moving vehicles during the course of normal operations due to the 

lack of their documented presence within the Project Area and the enforcement of speed limits. Overall, 

the direct impacts to this species would be negligible due to the limited amount of habitat for the species 

in the Project Area and the unlikelihood of individuals using the Project Area in the next nine to 10 years 

Brewer’s Sparrow 

Brewer’s sparrow is unlikely to experience direct impacts from Alternative A. It is unlikely to occur in the 

257 acres of mountain shrubland vegetation that will be disturbed in the next nine to 10 years. It has the 

greatest potential to occur in reclaimed rangeland vegetation and native sagebrush shrublands in and 

near the Project Area (22 acres of big sagebrush-grass vegetation; 494 acres of reclaimed rangeland). It 

is anticipated that a very small amount of reclaimed rangeland (11 acres) would be re-disturbed by 

re-mining in the N Pit. As a result, there would be short-term, negligible direct impacts to this species 

during mining activities that re-disturb reclaimed rangeland. 

Columbian Sharp-tailed Grouse 

Columbian sharp-tailed grouse habitat has been created on reclaimed lands to the west of the Project 

Area and the use of these reclaimed lands by the grouse is well-documented and increasing. The entire 

Project Area is within Columbian sharp-tailed grouse overall range and winter range. Approximately 

410 acres of designated production areas for this species are located within the northwest corner of the 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-42 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Project Area. This species is known to occur within the Project Area, although no leks are known to 

occur. Alternative A has the potential to directly affect the Columbian sharp-tailed grouse by removing 

257 acres of native mountain shrubland vegetation. There is a potential for individual mortality due to 

vehicle collisions related to normal mine operations; however, the likelihood is small with the 

enforcement of speed limits within the Project Area. The overall direct impacts to the Columbian sharptailed grouse would be short-term and minor due to the small amount of habitat affected by Alternative A 

relative to the availability of habitat in the region, the lack of documented leks in the proposed 

disturbance area, and the small potential for direct mortality to individual grouse due to enforcement of 

speed limits. Completion of the reclamation and revegetation will provide improved habitat for the 

Columbian sharp-tailed grouse compared to the pre-mining conditions. 

Colorado River Watershed Fish 

The closest habitat for the Colorado River endangered fish species is the Yampa River located 

approximately 4.5 miles (7 km) north of the Project Area (Figure 3-13). There is no habitat or designated 

critical habitat for the Colorado River fish in or adjacent to the Project Area. Direct impacts to the 

Colorado River fish are related to water depletions from Trapper Mine water usage. In the BA issued for 

RN06, the net annual water depletion was estimated at 94.8 acre-feet (OSMRE 2013). The USFWS 

determined in the subsequent Biological Opinion (BO) that the Trapper Mine’s net water depletions fit 

under the Programmatic Biological Opinion on the Management Plan for Endangered Fishes in the 

Yampa River Basin (Yampa River Programmatic Biological Opinion). The Yampa River Programmatic 

Biological Opinion states that in order for actions to fall under the umbrella of the document and rely on a 

Recovery Implementation Program Recovery Action Plan (RIPRAP) to offset depletions, the following 

criteria must be met: 

1.		 A Recovery Agreement must be offered and signed prior to conclusion of Section 7 

consultation.
	

2.		 A fee to fund recovery actions will be submitted for new depletion projects greater than 

100 acre-feet per year. 

3.		 Re-initiation stipulations will be included in all individual consultations under the umbrella of 

this program. 

4.		 The USFWS and project proponent will request that discretionary federal control be retained 

for all consultations under this program. 

TMI and the USFWS signed a RIPRAP that identifies actions believed to be required to recover the 

endangered fish in the most expeditious manner (USFWS 2013). TMI agreed to a one-time contribution 

based on its share of the costs of the Recovery Implementation Program to fund recovery actions 

(USFWS 2013). No additional depletions would occur under Alternative A and no further actions are 

needed for depletions. 

Colorado River watershed habitat for endangered fish also could be affected by sediment loading, and 

releases of mercury and selenium. The Trapper Mine lies approximately 4.5 miles south of the Yampa 

River. Mining activities under Alternative A could increase sediment loading in streams being carried 

offsite and eventually reaching the Yampa River in the short term as indicated in Section 4.5. However 

mitigation measures would greatly decrease the likelihood of sediment reaching the Yampa River. The 

impact of selenium discharges from the mine reaching the Yampa River are considered to be long-term 

and negligible based on the analysis in Section 4.5.1.1. Based on available water monitoring data, it is 

unknown if mining activities are contributing to mercury levels in the Yampa River. 

Yellow Billed Cuckoo 

The yellow-billed cuckoo is described as an occasional, localized breeder along the Yampa River near 

Craig (USFWS 2014). The species was last documented in that area in 2008 but breeding was not 

confirmed. Proposed critical habitat for the species occurs along the Yampa River from approximately 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-43 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

8 miles (13 km) east of Hayden to approximately 5 miles (8 km) west of Craig. As discussed above for 

the Colorado River Watershed Fish, the impact of selenium discharges and sediment loading is 

expected to be long-term and negligible. Based on available water monitoring data, it is unknown if 

mining activities are contributing to mercury levels in the Yampa River. 

4.10.2 Indirect Impacts 

Indirect impacts from Alternative A to the Colorado River endangered fishes (Colorado pikeminnow, 

humpback chub, bonytail chub, and razorback sucker) are related to coal combustion at the Craig 

Station. Combustion of coal releases mercury into the atmosphere which may be deposited directly into 

habitat for the endangered fish in the Colorado River watershed or may wash into the Colorado River or 

its tributaries after being deposited on land. The indirect effects area for the Colorado River watershed 

fish is the airshed boundary and the area between the Yampa and White rivers to their confluences with 

the Green River to the east (Figure 3-1). 

Aquatic systems receive mercury by direct deposition from the atmosphere and from overland transport 

from within the watershed (U.S. Environmental Protection Agency [USEPA] 1997). Mercury primarily 

enters aquatic systems in an inorganic form where it can adsorb to suspended solids and settle to the 

bottom (USEPA 1997). It also can be photo-reduced in the upper few centimeters of the water’s surface 

and escape into the atmosphere. Reactive gaseous mercury at the sediment water boundary can be 

transformed into methylmercury by sulfate-reducing bacteria; however, this is a reversible reaction that 

can transform methylmercury back to reactive gaseous mercury, depending on site-specific conditions. 

The most important areas for methylation are anoxic areas of the aquatic environment, such as wetlands 

or surface waters that remain stratified. 

Most mercury that bio-accumulates in fish tissue is in the form of methylmercury (USEPA 1997). Rates 

of methylation processes and bioaccumulation typically vary and depend on many factors. The effects of 

mercury on fish are numerous. Lusk (2010) describes the potential affects as: 

1.		 Potent neurotoxin: 

a.		 Affects the central nervous systems (reacts with brain enzymes, then lesions) 

b.		 Affects the hypothalamus and pituitary, affects gonadotropin-secreting cells 

c.		 Altered behaviors: Reduced predator avoidance, reproduction timing failure 

d.		 Reduced ability to feed (emaciation and growth effects) 

2.		 Endocrine disruptor: 

a.		 Suppressed reproduction hormones in male and female fish 

b.		 Reduced gonad size and function, reduced gamete production 

c.		 Altered ovarian morphology, delayed oocyte development 

d.		 Reduced reproductive success 

e.		 Transfer of dietary mercury of the maternal adult during oogenesis and into the developing 

embryo 

3.		 Inability to grow new brain cells or significantly reduce brain mercury. 

The specific impacts to the Colorado River fish from mercury in the Yampa and White rivers is highly 

uncertain. It is not known to what extent the level of mercury in these systems may be impacting these 

species at a population level. Additionally, given the longer life of the Colorado pikeminnow and its 

position higher in the food chain as a top predator, mercury would likely affect this species to a greater 

degree than the razorback sucker, bonytail chub, or humpback chub. This is due to the fact that the 

pikeminnow would have a greater chance to bio-accumulate higher concentrations of mercury during its 

lifespan. In contrast, the bonytail chub and humpback chub are middle feeders and the razorback sucker 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-44 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

is a bottom feeder that feed on organisms lower in the food chain with potentially lower concentrations of 

mercury. 

Mercury emissions have been previously described in Section 4.3.1.2 with the amount of mercury 

emissions attributable to combustion of Trapper Mine coal at the Craig Station estimated to be 7.29 lb/yr 

(3.31 kilograms per year) for the average mining rate of 2.3 mtpy, and 8.23 lb/year (3.73 kilograms per 

year) for the maximum mining rate of 2.6 mtpy. These rates represent approximately 17 percent and 

19 percent, respectively, of the total mercury emissions from Craig Station. 

No current data or modeling is available to indicate how much of the mercury that is emitted by the Craig 

Station is deposited annually within the airshed used in this assessment. However, a recent BA 

conducted for the Four Corners Power Plant and Navajo Mine Energy Project (FCPP & NMEP) 

(OSMRE 2014) included detailed modeling of the emissions and deposition of mercury produced at the 

FCPP. In those models, it was determined that approximately 95 percent of all mercury emitted by the 

FCPP rises high enough into the atmosphere to be carried by prevailing wind currents out of the area 

analyzed in that BA. It is important to note that it is unknown if this modeling accurately reflects the 

conditions at the Craig Station, because environmental conditions in the Four Corners region are 

different from those in Craig, Colorado. 

The Mercury Deposition Network (MDN) has a system of receptors that monitor levels of mercury. The 

nearest receptor to the Trapper Mine is the Buffalo Pass-Summit Lake site east of Steamboat Springs, 

which is approximately 45 miles (72 km) east of the Trapper Mine and the Craig Station. These 

monitoring stations measure the levels of mercury that are deposited in precipitation events (i.e., wet 

deposition). Data from this station in 2013 indicated that there was an annual deposition of 

9.757 micrograms per square meter (μg/m2

) of mercury at that location (National Atmospheric Deposition 

Program 2015). There are no other monitoring sites within the airshed; consequently, it would be 

speculative to accurately determine how much mercury is being deposited throughout the airshed due to 

the spatial variability of the deposition on an annual basis. It should be noted that the MDN clearly 

indicates that deposition can vary spatially across regional airsheds. 

Using the results of the emission and deposition modeling conducted at FCPP as a possible scenario, 

and assuming that the average annual deposition of 9.757 μg/m2 of mercury is equally distributed 

throughout Yampa and White river watersheds (a combined total of 13,267 square miles [21,351 square 

km]); an annual deposition of 739.14 pounds of mercury is calculated. The entirety of the Colorado River 

Fish indirect effects evaluation area is within these two watersheds and is 4,059 square miles 

(6,532 square km). Therefore, assuming an even distribution of mercury deposition, there would be a 

total of 226.17 pounds of mercury dropped annually over the entire indirect effects area. However, if the 

results of the FCPP & NMEP model are used, then only 5 percent of the mercury deposited would be 

emitted from local sources; and the other 95 percent would come from global or other distant sources. 

This would indicate that the proportional amount of mercury deposited annually that comes from the 

Craig Station and the Hayden Station, the two local generating stations, is 11.3 pounds (5 percent from 

local sources) across the entire indirect effects evaluation area. 

The proportion of local mercury attributable to the Craig Station can be estimated by comparing the ratio 

of coal that is combusted between the Craig Station and the Hayden Station, both located within the 

indirect effects evaluation area. The Craig Station consumes coal at a rate of 4.8 mtpy, and the Hayden 

Station uses coal at a rate of 1.75 mtpy. Using these numbers, the Craig Station would contribute 

8.3 pounds annually (0.733 x 11.31 pounds) of local mercury to mercury deposition within the evaluation 

area; and the Hayden Station would contribute 3.02 pounds of local mercury (0.267 x 11.31 pounds). 

Applying percentages to the sourced coal that is consumed in the three units at the Craig Station 

estimates TMI’s contribution to locally deposited mercury. Trapper Mine sourced coal that is combusted 

in Units1 and 2 contributes 19.16 percent of the mercury emitted from the Craig Station, and other coal 

that is consumed in Units 1, 2, and 3 contributes 80.84 percent of the mercury emissions. Applying these 

ratios to the local mercury deposition from the Craig Station (8.3 pounds) would indicate that Trapper 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-45 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Mine coal results in 1.6 pounds (0.1916 x 8.3 pounds) of locally deposited mercury; and other coal 

results in 6.7 pounds (0.8084 x 8.3 pounds) of locally deposited mercury. Therefore the mercury 

deposited over the study area attributable to Trapper Mine would be 1.6 pounds annually at the 

maximum mining rate of 2.6 mtpy. 

The assumption of an even deposition of mercury is impracticable because the prevailing winds from the 

southwest to the northeast likely result in higher amounts of deposition east of the Craig Station than 

other parts of the affected area. However, barring further detailed modeling into the analysis of mercury 

deposition, precise estimates of local deposition are unavailable at this time. 

The actual amount of mercury deposited annually would vary based on the chemical speciation of the 

mercury in the atmosphere, as well as the climatic conditions, and the amount of coal combusted to 

meet regional electricity needs. Therefore, the amount of mercury annually deposited in the affected 

area that may be attributable to the combustion of coal from Trapper Mine could vary yearly. 

It is important to note that the calculations above refer to wet deposition of mercury. Some research has 

shown that dry deposition can be equal to or greater than wet deposition. Dry deposition occurs when 

mercury settles out of the air, and wet deposition occurs when mercury is deposited in rain or other types 

of precipitation. Research has shown this rate to be anywhere from 0.8 to 4.8 times higher in the central 

and eastern U.S. (Zhang et al. 2012). The rate of dry deposition is highly dependent on the 

meteorological conditions and the chemical speciation of the mercury. Although most all of the sites 

analyzed in Zang et al. (2012) were in the eastern United States with more precipitation than that 

experienced in western Colorado, one site analyzed was in Salt Lake City, Utah. At that site, total 

mercury was 2.5 times that of the wet deposition of mercury (Zhang et al. 2012). The USFWS applied 

this ratio 2.5:1 in the BO for the Mining Plan Modification for the South Taylor/Lower Wilson Area at the 

Colowyo Coal Mine (USFWS 2015). Applying this factor to the Trapper Mine coal that is combusted at 

the Craig Station provides a total mercury deposition of 4 pounds annually over the entire indirect effects 

area from Alternative A. This translates to a depositional rate of 0.01575 ounces per square mile per 

year (0.1726 grams per square kilometer per year) in the study area. 

In addition to impacts to Colorado River fish alone, impacts also could occur to critical habitats of the four 

Colorado River fish species in the study area. Mercury from the combustion of Trapper Mine coal at the 

Craig Station that is deposited either directly or indirectly into the critical habitats for these species would 

have the potential to adversely impact critical habitats. This would occur primarily by increasing the 

amount of contaminants present in those areas. Bio-accumulation of methylmercury could degrade food 

resources for the species. 

It is difficult to quantify the level of these impacts to critical habitats as a result of Alternative A given the 

lack of information on the origin of mercury in the indirect effects area. However, if it is assumed that only 

5 percent of the mercury generated at the local generating stations is deposited into the area, the impact 

from Alternative A may be small. However, when added to the other regional and global sources of 

mercury deposited into the area, Alternative A may result in cumulatively adverse impacts (Chapter 5.0). 

Of the amount of mercury annually deposited in the indirect effects area (as well as the larger Yampa 

and White river basins), it is reasonable to assume that some portion would deposit directly or indirectly 

into the Yampa or White rivers or their tributaries. Some of this mercury would be converted into 

methylmercury and, thereby, has the potential to adversely affect the Colorado River fish. However, due 

to a lack of data on mercury transport within the study area, it is not possible to quantify the amount of 

mercury that would enter the Yampa and White rivers, or be converted to methylmercury. Therefore, at 

this time it is not possible to accurately predict the full impact to the Colorado River fish or their critical 

habitats. 

Due to the uncertainties in how mercury is potentially affecting the Colorado River fish species, it is 

difficult to draw a conclusion on the indirect impacts from Alternative A as some of the data appear to be 

contradictory. In a recent study, Colorado pikeminnow populations in the Yampa River were reported to 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-46 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

be declining but had low mercury concentrations compared to other river segments (Osmundson and 

Lusk 2012). Conversely, Colorado pikeminnow in the White River had high levels of mercury 

concentrations but the population has been increasing (Osmundson and Lusk 2012). The increase in the 

Colorado pikeminnow population in the White River was attributed to upstream movement of juvenile 

Colorado pikeminnow that originated in downstream Green River reaches during 2006 and 2007 and not 

from reproduction occurring in the White River itself (Bestgen et al. 2010). Further studies are required to 

determine how mercury is affecting the Colorado River fish species and critical habitats in the Yampa 

and White rivers before a specific conclusion can be drawn between Alternative A and impacts to the 

Colorado River fish and their critical habitats. 

The types of impacts from mercury accumulation in the Colorado River fish could include a number of 

factors. Mercury can affect an individual fish’s central nervous system, alter their behaviors (e.g., 

reduced predator avoidance), and disrupt the endocrine system resulting in reduced reproductive 

success (Lusk 2010). Given that the Colorado pikeminnow is a top predator in its ecosystem and is 

longer-lived, it would be expected that the impacts from mercury exposure would be more pronounced 

than in the bonytail chub, razorback sucker, or humpback chub. While the specific effects of mercury and 

other heavy metals on pikeminnow are known, the role these contaminants play on suppressing 

populations of the Colorado River fish are not well understood (USFWS 2011). For the Colorado River 

fish, Beckvar et al. (2005) determined that survival, growth, reproduction, and behavior begin to be 

affected by mercury at 0.2 micrograms per gram (μg/g) in the whole fish. In the 1960s, Colorado 

pikeminnow in the Yampa River Basin had a median level of mercury per fish weight of approximately 

0.6 μg/g. In 2010, that level had dropped to approximately 0.5 μg/g (Lusk 2010). The USFWS has 

hypothesized that this level of mercury exposure may be leading to reproductive impairment in a majority 

(64 percent) of Colorado pikeminnow (USFWS 2011). 

In addition to mercury, impacts to the Colorado River fish from increases in selenium from the 

combustion of coal at the Craig Station could occur. Selenium, a trace element, is a natural component 

of coal and soils in the area and can be released to the environment by the irrigation of selenium-rich 

soils and the burning of coal in power plants with subsequent emissions to air and deposition to land and 

surface water. Contributions from anthropogenic sources have increased with the increases of world 

population, energy demand, and expansion of irrigated agriculture. Selenium, abundant in western soils, 

enters surface waters through erosion, leaching, and runoff. While required in the diet of fish at very low 

concentrations (0.1 μg/g) (Sharma and Singh 1984), it is unknown if selenium is adversely affecting 

endangered fish in the Yampa Basin. Excess dietary selenium causes elevated selenium concentrations 

to be deposited into developing eggs, particularly the yolk (Buhl and Hamilton 2000). If concentrations in 

the eggs are sufficiently high, developing proteins and enzymes become dysfunctional or result in 

oxidative stress, conditions that may lead to embryo mortality, deformed embryos, or embryos that may 

be at higher risk for mortality. 

Of the four Colorado River fish species, selenium would disproportionately affect the razorback sucker 

more than the other three species. As with all sucker species, the razorback sucker is a bottom feeder 

and more likely to ingest selenium that has precipitated to the river bottoms. Hamilton et al (2005a) 

observed a significant positive correlation and possible causal linkage to elevated levels of selenium in 

adult razorback suckers and percent hatch, egg size, and embryo deformities in developing eggs. 

Hamilton et al. (2005b) also documented deformities and rapid mortality in razorback sucker larvae 

exposed to elevated dietary selenium. The results indicate an impact to the razorback sucker that lowers 

reproductive success at a population-level. 

Combustion of coal at the Craig Station could result in some amount of selenium being emitted and 

subsequently deposited. However, as it is not monitored as it is emitted, unlike mercury, there is no 

information as to how much is released. When selenium is present in flue gas, it tends to behave much 

like sulfur and is removed to some extent via SO2 air scrubbers in place or absorbs onto alkaline fly ash 

that is subsequently removed by a fabric filter baghouse (Electrical Power Research Institute 2008). 

Therefore, due to the lack of information available, it is unknown if selenium is impacting Colorado River 

fish species in the Yampa and White rivers. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-47 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Consultation on the potential effects of Alternative A has been conducted with the USFWS under Section 7 

of the ESA. The BO issued by the USFWS on March 22, 2016 found that the Project is not likely to 

jeopardize the four endangered fish, nor is it likely to destroy or adversely modify their critical habitat. 

The BO requires a number of conservation measures that would aid in improving the scientific 

knowledge and preservation of these species in the Yampa and White river basins. The mitigation 

measures approved as part of the BO are described in Section 4.10.4.1 and Appendix C. 

Yellow-Billed Cuckoo 

The yellow-billed cuckoo could be indirectly impacted by coal combustion and mercury in the 

environment. For the yellow-billed cuckoo, mercury bio-accumulates through the ingestion of aerial 

insects emerging from benthic life stages that develop in aquatic environments with mercury or from 

predatory spiders that eat these (Buckland-Nicks et al. 2014; Cristol et al. 2008; Edmonds et al. 2012; 

Evers et al. 2012; Gann et al. 2014). Dietary mercury concentrations associated with adverse effects to 

birds are normally greater than 0.1 mg/kg wet weight (DOI 1998). Once ingested, methylmercury rapidly 

moves into the bird’s central nervous system, resulting in behavioral and neuromotor disorders 

(Scheuhammer et al. 2012, 2007; Tan et al. 2009). The developing central nervous system in avian 

embryos is especially sensitive to this effect, and permanent brain lesions and spinal cord degeneration 

are common (Bryan et al. 2003; DOI 1998; Heinz et al. 2009; Scheuhammer et al. 2007; Young 1998). 

Therefore, adverse effects are described for the eggs, embryos, nestlings and fledglings due to elevated 

mercury burdens in the female parent. 

Uptake of mercury by birds usually has been shown to impact fish-eating birds more severely than 

insectivorous birds (Boening 2000; Zolfaghari et al. 2009). Additionally, Howie (2010) found that the 

lateral extent of elevated mercury levels in birds and invertebrate prey species varied from approximately 

250 to 650 meters (820 to 2,133 feet) from an affected water body. After this distance, mercury levels in 

the blood and feathers could not be distinguished from background levels, indicating that only those 

individuals that forage adjacent to affected water bodies show signs of bioaccumulation of mercury. 

No information is available on the levels of mercury found in invertebrates in the Yampa River or 

elsewhere within the indirect effects area. However, it could be assumed that given the levels of mercury 

that currently exist in the Yampa River, that the aquatic invertebrates may contain elevated levels of 

mercury. However, the amount of mercury that may be present would vary depending on the water 

temperature and its hardness (Boening 2000). 

Any yellow-billed cuckoos present in the area would be at risk for mercury contamination. However, that 

risk would be minor considering that the primary food sources for the cuckoo largely are not aquatic, but 

individual cuckoos could occasionally consume lizards that are higher in the food chain and that may 

have consumed insects of an aquatic origin. Under this scenario, the concentration of methylmercury 

would magnify from the environment as it bioaccumulates from insect to lizard and eventually a cuckoo 

that consumes the lizard. Therefore, it is not possible to entirely discount the potential for yellow-billed 

cuckoos to bio-accumulate mercury from Alternative A; however, given the infrequency of this species 

within the area historically, it is unknown how many individuals would have the potential to be affected. 

Furthermore, it is difficult to determine the level of impact given that there is no threshold information 

regarding mercury levels that adversely affect yellow-billed cuckoos or actual amounts of mercury in 

yellow-billed cuckoos that inhabit the area. Based on the low numbers of cuckoos that are thought to use 

the area, it would be difficult to obtain these data. 

Because the yellow-billed cuckoo may not return to the same breeding areas in successive years, it is 

possible that if any individuals were impacted by mercury in one year, individuals may travel to a new 

location in subsequent years that are not impacted by mercury generated from the Craig Station. Also, 

because cuckoos are migrants that are present for only a few months each year, the potential for 

mercury exposure in the area would be lower than if the species were a year-round resident. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-48 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

In addition to impacts to individual yellow-billed cuckoos, the proposed critical habitat for this species 

also may be impacted by Alternative A. The USFWS has proposed critical habitat for the western yellow 

billed cuckoo along the Yampa River. 

The indirect effects of Alternative A would result in some level of mercury deposition in the area. Some of 

this mercury may affect the invertebrates that make up the cuckoo’s prey base, thereby affecting the 

proposed critical habitat. Different orders of invertebrates often react to mercury differently, although the 

larval stages are usually most susceptible to mercury. Levels of 1 to 10 μg/L normally cause acute 

toxicity for the most sensitive developmental stage of many different species of aquatic invertebrates 

(Boening 2000). It should be noted, however, that aquatic insects are not the primary food source for 

cuckoos. It is unknown how much of the mercury deposited from Trapper Mine coal burned at the Craig 

Station would eventually enter into the bodies of yellow-billed cuckoos. Therefore, it is not possible to 

determine the severity of this impact. 

Combustion of coal at the Craig Station could result in some amount of selenium being emitted and 

subsequently deposited. Impacts from elevated selenium in birds can affect reproduction in developing 

embryos by acting as a teratogen, lower body weight, decrease immune function, or result in 

histopathological lesions (Hamilton 2004). However, as is described in the previous section, there is a 

lack of information on the amount of selenium emitted or absorbed at the Craig Station from 

Alternative A. Therefore, it is unknown if the indirect effects of selenium are impacting the yellow-billed 

cuckoo or proposed critical habitat. 

Consultation on the potential effects of Alternative A has been conducted with the USFWS under Section 7 

of the ESA. The BO issued by the USFWS on March 22, 2016 concurred with OSMRE’s findings in the 

BA that the Project is not likely to adversely affect the yellow-billed cuckoo and not likely to destroy or 

adversely modify the proposed critical habitat for the species. The BO requires actions to be taken to 

improve the scientific knowledge of the population of yellow-billed cuckoos that have been known to 

occur on the Yampa River. The mitigation measures approved as part of the BO are described in 

Section 4.10.4.2 and Appendix C. 

4.10.3 Alternative B – Disapproval of the Mining Plan Modification by the ASLM 

4.10.3.1 Direct Impacts 

Under Alternative B, activities within the Project Area would cease and reclamation would occur. 

However, mining would continue in areas outside of the Project Area. As a result direct impacts would 

continue in the Project Area until reclamation activities have ceased and reclamation has been 

successfully established but impacts, similar to those described for Alternative A, would continue to 

occur in areas outside the Project Area until mining ceases at the Trapper Mine. 

4.10.3.2 Indirect Impacts 

Indirect impacts to the Colorado River fish and yellow-billed cuckoo would continue in the long term due 

to the coal combustion and emissions of mercury and selenium. Although these impacts would continue 

for as long as the Craig Station is operational, the portion attributable to combustion of Trapper coal 

would decrease based on the expected decreased mining rate for the three- to four-year life of mining 

outside of the Project Area. For reasons previously described, the exact indirect impacts based on coal 

combustion cannot be determined. 

4.10.4 Mitigation Measures 

4.10.4.1 Colorado River Fish 

OSMRE has voluntarily developed a number of conservation measures in coordination with TMI and 

USFWS that would aid in improving the scientific knowledge and preservation of these species in the 

Yampa and White river basins. The objective of these conservation measures would be to help toward 

the recovery and ultimate goal of down listing or delisting these species in the future. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-49 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

TMI would contribute funding toward active research projects in the Yampa and White River Basins to 

study mercury deposition and the uptake in fish species in these areas. TMI would provide funding in the 

amount of $45,000 for upcoming mercury deposition studies being conducted in the Yampa and White 

rivers by the USGS Water Quality Division, and investigation of methylmercury uptake in fish tissues to 

be conducted jointly by BLM and USGS Fort Collins Office in cooperation with CPW in the same river 

systems. 

Additionally, TMI would contribute $10,000 of funding for recovery actions that are managed by the 

Upper Colorado River Endangered Fish Recovery Program. TMI would provide the funding to the 

National Fish and Wildlife Foundation to distribute to the Upper Colorado River Endangered Fish 

Recovery Program. The details of the specific activities that will be funded are described in the BO in 

Appendix C. 

4.10.4.2 Yellow-billed Cuckoo 

OSMRE has voluntarily developed a number of conservation measures in coordination with TMI and 

USFWS that would aid in improving the scientific knowledge about the population of yellow-billed 

cuckoos that have been known to occur on the Yampa River. TMI would provide $5,000 to fund a 

protocol survey during the breeding season in proposed critical habitat along the Yampa River. TMI 

would either conduct the survey itself or hire a permitted contractor to perform the survey. The results of 

the survey will be provided to USFWS. Further details of the specific activities that will be funded are 

described in the BO in Appendix C. 

4.11 Cultural Resources 

Surface-disturbing activities or construction of associated infrastructure may directly or indirectly affect 

cultural resources in the APE, including historic properties (i.e., NRHP-eligible sites), as well as those 

cultural resources that require additional information to determine eligibility (i.e., “needs data”). The sites 

categorized as needing additional data (the “needs data” sites) will be managed as if they are eligible for 

listing in the NRHP until further evaluation has been completed. 

The direct effects area includes all associated mine-related disturbances and facilities, including topsoil 

stockpiles, overburden stockpiles, access roads, power lines, water lines, sediment ponds, and diversion 

ditches. 

The indirect effects area, which encompasses those historic properties for which the setting is essential 

to their NRHP eligibility, is defined as the geographic area which is not planned for disturbance and lies 

within the Project Area. Indirect effects may include increased soil erosion and gullying, vibration from 

blasting, and dust from operations. In addition, enhanced access to now remote areas would increase 

the potential for illicit artifact collection and/or vandalism of cultural resources. Other indirect effects may 

include deterioration of the site setting, thereby diminishing those aspects for which nearby cultural 

resources are considered eligible for the NRHP. 

One cultural resource site is located within the indirect APE (Table 4-18). 

Table 4-18 Historic Properties Within Indirect APE 

Site Number Site Type 

Cultural 

Affiliation 

NRHP 

Evaluation 

Relationship To Proposed 

Disturbance 

5MF.948 Rock Art Protohistoric Eligible Indirect APE, located approximately 

700 feet south of L Pit disturbance limit 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-50 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

4.11.1 Alternative A – Proposed Action 

4.11.1.1 Direct Impacts 

No cultural resources sites eligible for listing on the NRHP are located within the direct effects area, so 

no direct effects to cultural resources would occur as a result of Alternative A. 

4.11.1.2 Indirect Impacts 

Alternative A includes the continued operation of the L Pit, which is located 700 feet north of site 

5MF.948, a rock art site that is dated to the Protohistoric era (A.D. 1300-1881). The site was recorded in 

July 1980 by Archaeological Services of Laramie, Wyoming. Features noted on the site include 

pictographs made with red and yellow ochre; petroglyphs of shield, spears, bison, mounted horseman, 

and standing warriors; and a charred bone fragment. The rock art adorns the vertical face of a sandstone 

cliff, on private lands within Federal Coal Lease C-079641. The site has been determined eligible for 

listing in the NRHP and avoidance is recommended, especially if construction activity is anticipated 

within 50 feet of the site. 

The site faces south and is found at least 200 feet below the lowest planned mining elevation, so direct 

mining activity would not disturb the site, and mining activities would not be visible from the site. In 

addition, given the aspect and position of the rock art panel, it would be protected from atmospheric and 

auditory effects such as fly rock and air blast. However, TMI plans to construct a sediment control pond 

directly below and within the viewshed of the site. 

Concern has been expressed that the site could be damaged by nearby blasting operations in existing 

and planned mining areas. TMI has acknowledged this risk and engaged AAI to complete analysis of the 

potential for vibration damage to the site. AAI calculated the blasting vibration levels (measured as peak 

particle velocity or PPV) sufficient to cause spalling or cracking of the rock forming the cliff on which the 

rock art is depicted and have recommended that vibration levels not exceed PPV of two inches per 

second. If sufficient protection from rock fall is implemented, a maximum PPV of five inches per second 

may be more appropriate. Charge weights for blasting range between 3,000 and 5,000 pounds. A 

charge weight of 3,000 pounds could be used at distances greater than 1,330 feet, while a 5,000-pound 

charge weight could be used at distances greater than 1,720 feet. When the blast area is nearer than 

these limits, the charge weight must be reduced to maintain a safe vibration level that would not harm 

the rock art at the site (AAI 2015). 

As part of the CDRMS mid-permit term review, TMI will be submitting the AAI report to the CDRMS and 

agreeing to abide by the recommendations of the report (Hinkemeyer 2015). If any mining or miningrelated activity occurs within 50 feet of any historic property, then the location would be fenced. This 

commitment would apply to the rock art site. If TMI complies with the AAI recommendations and the 

fencing commitments, the site would not be adversely affected by Alternative A. 

4.11.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM 

4.11.2.1 Direct Impacts 

Under this alternative, Alternative A would not be approved and the current mining operations in the 

Project Area would be terminated. No additional coal removal would occur within the Project Area. No 

additional disturbance beyond the existing disturbance footprint would occur and reclamation would be 

completed. Under these circumstances, no historic properties or “needs data” sites would be directly 

affected within the Project Area. The areas encompassed within the N and I pits were previously 

surveyed for cultural resources in the late 1970s and early 1980s and no cultural resources are known to 

exist in these areas. 

Under Alternative B TMI would move to coal recovery outside of the Project Area in the N Pit and the 

I Pit. The area of the N Pit has been previously disturbed and re-disturbance of this area would not result 

in direct impacts to cultural resources. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-51 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

TMI has indicated the pit boundary for the I Pit but has not yet completed design of the infrastructure that 

would be needed to mine that pit including the topsoil stockpiles, overburden stockpiles, roads, sediment 

ponds, power lines, water lines, so impacts to cultural resources as a result of construction of 

infrastructure to support mining in the N and I pits cannot be fully quantified. 

4.11.2.2 Indirect Impacts 

Any coal mined under Alternative B would be further away from site 5MF.948 and indirect impacts to that 

site would not occur. No additional known cultural resources would be indirectly affected by 

Alternative B. 

4.11.3 Mitigation Measures 

4.11.3.1 Unanticipated Discoveries 

If a previously unidentified cultural resource is discovered in the Project Area, TMI would take measures 

to protect the find locality and provide written notice to the CDRMS and the OSMRE within 48 hours of 

the discovery. A Colorado-permitted archaeologist meeting the Secretary of the Interior’s Professional 

Qualification Standards would, as soon as possible, evaluate the discovery, make a recommendation as 

to the NRHP eligibility of the resource, and provide written notice to the CDRMS and the OSMRE within 

48 hours. The CDRMS and OSMRE would then consult with the SHPO and the BLM (for federally 

managed sites) on the NRHP eligibility determination(s) and develop appropriate measures necessary to 

mitigate any adverse effects through the development of a treatment plan. 

Should the discovery involve a burial or a resource thought to have potential religious and cultural 

significance, the tribe(s) with an interest would be notified and consulted as appropriate. When 

agreement is reached among all of the involved parties, the appropriate mitigation, if necessary, would 

be implemented. The tribes, OSMRE, CDRMS, SHPO, and the surface landowner must agree to any 

proposed treatment measures. 

4.11.3.2 Human Remains 

If human remains are exposed during mining activities, mining activities would be halted immediately 

near the discovery. The remains would be appropriately covered and stabilized, and access to the 

immediate area would be blocked by flagging and/or temporary fencing. All mining operations would 

cease within a radius of 100 feet around the discovery site. 

Unmarked burials located on private or state land would be treated under CRS 24-80-411 and 

CRS 24-80 Part 13. TMI would contact the county sheriff, the county coroner, and the appropriate land 

managing agency official to notify them of the discovery. The coroner would conduct an on-site inquiry 

within 48 hours of notification and may enlist the assistance of specialists to determine if the remains are 

of forensic interest. If the remains are not of a forensic interest, the coroner would contact the State 

Archaeologist. Before further disturbance, the State Archaeologist would have a qualified archaeologist 

examine the human remains and determine whether or not they are more than 100 years old and to 

evaluate the integrity of their archaeological context. If the on-site inquiry discloses that the human 

remains are Native American, the State Archaeologist would notify the Colorado Commission of Indian 

Affairs to formulate a treatment plan within 10 days of the discovery. The State Archaeologist and 

Colorado Commission of Indian Affairs would coordinate Native American tribal notifications and 

subsequent consultations. If the remains are verifiably non-Native American, the county coroner would 

convey the remains to the Colorado State Anatomical Board for proper disposition. 

For unmarked Native American burials identified on federally managed lands, the requirements of the 

Native American Graves Protection and Repatriation Act would apply in accordance with 43 CFR 10, 

Subpart B. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-52 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

4.11.4 American Indian Concerns 

Several tribes were contacted in 2015 regarding Alternative A (Appendix D). The Hopi Tribe and the 

Southern Ute Indian Tribe were consulted related to the rock art at site 5MF.948 (Section 6.3). No other 

concerns have been raised regarding any religious or sacred sites near the mine. 

4.12 Socioeconomics 

4.12.1 Alternative A – Proposed Action 

Under Alternative A, mining operations at the Trapper Mine would continue within the Project Area from 

July 1, 2015, through the life-of-mine, estimated to be approximately 2025 or later depending on coal 

delivery requirements. The coal would be mined at the current mining rates which average approximately 

2.3 mtpy with a maximum production rate of 2.6 mtpy. 

4.12.1.1 Direct Impacts 

Trapper Mine currently employs approximately 191 workers. Employment levels would stay 

approximately the same under Alternative A until closure activities begin within the Project Area. In 2014, 

TMI spent approximately $19.7 million in gross wages including benefits. This amount rose to 

$20.3 million in 2015. This direct beneficial impact to TMI workers would continue until closure activities 

begin within the Project Area or potentially longer as TMI moves to other areas of coal within the SMCRA 

permit boundary. Direct support of industries that supply services to the Trapper Mine also would 

continue. This includes the Craig Station, which receives Trapper Mine coal and would continue to 

operate at or near its current level, assuming that its coal supply from multiple sources remains relatively 

constant. Additionally, industries such as welding, fabrication, and equipment rental would continue to 

directly benefit from the continuation of mining operations at the Trapper Mine until the completion of 

mining and reclamation. Payments of local, state, and federal taxes also would continue. Trapper Mine 

paid $3.9 million in federal Abandoned Mine Land fees; $4.8 million in severance tax ($1.2 million of 

which was distributed to local governments and impact grant funds); as well as $8.0 million in property 

tax and $36.9 million in royalties between 2010 and 2015. Local services would continue to benefit from 

the local distribution of 50 percent of the State of Colorado’s share of severance taxes. These payments 

would continue at approximately the same amount until mining is completed for the Project Area. 

TMI has been involved in the community in a number of ways. TMI community involvement has included, 

but is not limited to, construction and donation of a fitness center in Craig, donation of labor, equipment 

and funds to the construction and subsequent operation of local athletic facilities, construction of a 

portion of the Yampa Valley golf course at no cost to the community, and participation in hunting 

programs for disabled individuals. Local community participation and the resulting community benefit 

would continue to be associated with the Project Area until mine closure activities would begin in 2025. 

Overall socioeconomic benefits from Alternative A would be beneficial and last for the life of the mining 

and reclamation operations within the Project Area. 

4.12.1.2 Indirect Impacts 

Indirect beneficial impacts, such as support by TMI employees of the retail and accommodation 

industries, as well as local real estate, would continue from the continuation of mining operations at the 

Trapper Mine until closure. Indirect beneficial impacts also include local purchases, salaries and benefits 

to local workers at the Craig Station, which receives Trapper Mine coal. 

4.12.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM 

Under Alternative B, TMI would terminate the current mining operation in the Project Area. Coal reserves 

identified in areas outside of the Project Area include the N and I pits as shown on Figure 2-4. The 

expected coal to be mined from these pits would be approximately 4.5 million tons at an anticipated 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-53 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

reduced mining rate of 1.5 mtpy, resulting in the potential of three to four years of continued mining on a 

reduced level. 

4.12.2.1 Direct Impacts 

Under this alternative, direct employment of approximately 191 workers would be reduced, along with 

the subsequent payment of $20.3 million in gross wages and benefits as reported for 2015. A reduction 

in employment and subsequent gross wages and benefits would occur starting at cessation of mining 

within the Project Area, with further reductions after the three to four years of mining in areas outside of 

the Project Area and assuming no additional reserves are identified. Local, state, and federal tax 

payments would markedly decrease based on the reduced mining rate and would end at mine closure. It 

is estimated, based on 2010-2015 averages, approximately $174.5 million in gross wages and benefits, 

$5.9 million in Abandoned Mine Land fees, $7.2 million in severance tax, $55.4 million in royalties, and 

$12.0 million in property tax revenue from mining within the Project Area would be eliminated if mining 

did not continue. This reduction in revenue would be partially offset by the mining in other areas of the 

SMCRA permit boundary. The loss of direct employment income as well as local, state, and federal tax 

revenue would have substantial effects on a region that has strong economic ties with the mining sector. 

Although the effect to the State of Colorado from a reduction in severance tax collection would likely be 

minor, local areas would not receive the 50 percent disbursement of these funds, resulting in an adverse 

impact to the ability of local areas to provide services such as law enforcement and health care. 

Industries that directly contribute to the mine would potentially incur a large decline in business and 

associated revenue as well as employment. These industries include welding, fabrication, and 

equipment rental businesses. The housing industry also could potentially incur an adverse impact as 

those directly employed by Trapper Mine may leave the area. Local school enrollment also could be 

adversely affected as directly employed workers and their families leave the area. 

Under Alternative B, community involvement by TMI, which has ranged from funding of local sports fields 

and fitness centers to support of disabled hunter programs, would likely be reduced. 

Overall impacts from Alternative B would be beneficial during the shortened life of the mining operations 

outside the Project Area and adverse once mining operations cease. 

4.12.2.2 Indirect Impacts 

Industries to which the mine contributes indirectly would potentially incur a large decline in business and 

associated revenue as a result of the reduced mining operations and shortened mine life. Indirect 

employment levels also would likely be reduced. These industries include the retail and accommodation 

industries in Craig and vicinity. The real estate industry also could potentially incur an adverse impact as 

those indirectly supported by TMI may leave the area. Local school enrollment also could be affected as 

indirectly employed workers and their families leave the area. Indirect impacts also potentially include a 

reduction of availability of goods and services to local workers from the Craig Station, which receives 

Trapper Mine coal. 

4.12.3 Mitigation Measures 

No mitigation measures have been identified for socioeconomic resources. 

4.13 Visual Resources 

The mining of the Project Area would create a visual intrusion to the landscape from points where it is 

visible. It would create a noticeable change to the continuity of color, form, line and texture of the 

landscape. There also may be a certain amount of exhaust and dust emissions released into the air 

above the mine areas that may be visible; however, TMI has controls in place to limit these emissions in 

accordance with the air permit. Although the mine is not located on federally managed lands, OSMRE 

requires evaluation under the BLM visual resource management objectives and activities should conform 

to BLM Class IV (see Section 3.14). 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-54 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

4.13.1 Alternative A – Proposed Action 

4.13.1.1 Direct Impacts 

Under Alternative A, mining in the Project Area would continue and is visible from certain locations until 

reclamation allows the area to successfully blend with the natural surroundings which could take 20 to 

30 years. The Project Area is located at approximately 6,900 feet (2,103 meters) amsl and topography 

and vegetation block the view of the mine from many locations. The Project Area cannot be seen from 

the west or the south. Visibility from the south is blocked by the Williams Fork Mountain ridgeline. Views 

from a small amount of higher elevation areas (7,500 feet [2,286 meters] amsl) to the east in the Williams 

Fork Mountains look upon the Project Area. The majority of the mine viewshed is to the north and mostly 

in the eastern portion of Moffatt County. The mine is visible from the town of Craig but not from Hayden. 

Some portions of Highway 13 north of Craig (paralleling Fortification Creek) also are within the mine 

viewshed. Because mining within the SMCRA permit boundary has occurred since the 1970s, it is 

unlikely that the residents of Craig notice it as a visual intrusion, but visitors to the region might notice the 

visual intrusion. The mine is visible from portions of the Yampa River extending approximately 5 miles 

(8 km) east of Craig and intermittently 13 miles (21 km) west (most of the western visibility would only 

include the draglines). 

Overall, the visual impacts from the Project would be negligible to minor and short-term. These impacts 

would meet the BLM Class IV objectives. 

TMI does operate throughout the night and uses lighting systems that are visible from the City of Craig. 

Lighting at the Trapper Mine is minimal and is kept to only that lighting necessary for operator safety. 

The lighting is directed downward to minimize the light cast outward. The Craig Station lighting is far 

more visible and overshadows the Trapper Mine lights. As a result, the visibility of the mine lights is 

minor and would last for the duration of mining operations. 

4.13.1.2 Indirect Impacts 

There would be no indirect impacts to visual resources as a result of Alternative A. 

4.13.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM 

4.13.2.1 Direct Impacts 

Under Alternative B, OSMRE would not recommend approval of continued mining to the ASLM and the 

ASLM would not approve continued mining. TMI would cease mining activities in the Project Area and 

begin reclaiming the disturbed areas. Operational visibility and nighttime lighting would persist as mining 

continues in other areas of the SMCRA permit boundary. Final reclamation within the Project Area would 

be similar to Alternative A; however the reclamation would occur once mining operations cease. Visual 

intrusions as a result of mining would continue for areas outside the Project Area for an additional three 

to four years due to ongoing mining within the SMCRA permit boundary. Overall, the visual impacts from 

these continued mining activities would be negligible to minor and short-term. These impacts would meet 

the BLM Class IV objectives. 

4.13.2.2 Indirect Impacts 

There would be no indirect impacts to visual resources under Alternative B. 

4.14 Paleontological Resources 

4.14.1 Alternative A – Proposed Action 

4.14.1.1 Direct Impacts 

As the Project Area lies within a PFYC Class 5 zone, there is the potential that the ground disturbing 

activities would adversely affect fossils. If any such fossils of paleontological interest are located in the 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-55 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Project Area, ground disturbing and overburden removal activities could damage the fossils and the 

information that could have been gained from them would be lost. Activities under Alternative A also 

could pose a beneficial impact to paleontological resources by increasing the chances for discovery of 

scientifically important fossils within the Project Area. Surface coal mining and related activities could 

have a permanent adverse impact on paleontological resources. Paleontological resources not identified 

and transported prior to or during mining operations would be permanently lost. Because the Project 

Area disturbance is small compared to the overall Williams Fork Formation, impacts to paleontological 

resources are expected to be long-term and negligible. 

4.14.1.2 Indirect Impacts 

There would be no indirect impacts to paleontological resources from Alternative A. 

4.14.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM 

4.14.2.1 Direct Impacts 

Under Alternative B, mining would cease and closure and reclamation would be initiated. Additional 

disturbance would occur outside of the Project Area in the N and I pits. The N Pit has been previously 

disturbed so the discovery of paleontological resources would be unlikely, but the I Pit is new 

disturbance. Impacts to paleontological resources as a result of Alternative B would be similar to impacts 

from Alternative A. 

4.14.2.2 Indirect Impacts 

There would be no indirect impacts to paleontological resources as a result of Alternative B. 

4.14.3 Mitigation Measures 

The following protection measures for paleontological resources are taken from the BLM LSFO ROD 

and Approved RMP (BLM 2011): 

•	 Proposed surface disturbing actions will be evaluated to determine inventory needs and identify 

sites that could be potentially impacted by such activities. Surface disturbing activities in PFYC 

Class 4 and 5 paleontological areas that are devoid of thick soils and vegetation and with steep, 

unsafe cliffs will be inventoried by a qualified paleontologist with a valid Colorado BLM 

paleontology permit who is approved by the authorized officer. Mitigation measures for specific 

locations will be identified on a case-by-case basis. 

•	 If paleontological resources are discovered during mining operations on BLM managed lands, 

mine employees shall immediately notify the BLM and shall not disturb such discovered 

resources until the Field Office Manager issues specific instructions. Within five working days 

after notification, the Field Office Manager shall evaluate any paleontological resources 

discovered and shall determine whether any action may be required to protect or to preserve 

such discoveries. 

Should paleontological resources be encountered as a result of the Project, BLM and OSMRE would be 

consulted as appropriate. 

4.15 Access and Transportation 

4.15.1 Alternative A – Proposed Action 

4.15.1.1 Direct Impacts 

Under Alternative A Trapper Mine employee commuter traffic would continue to and from the mine when 

shift changes occur. The 37,226 annual truck trips required for the transportation of coal from the Project 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-56 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Area and CCRs from the Craig Station also would continue. AADT counts on U.S Highway 40 and SHs 

13 and 394 would not change as a result of the proposed project. 

Roads within the SMCRA permit boundary consist of haul roads and light use ancillary roads. In-pit 

routes of travel and ramps are not considered roads because they are temporary and frequently move to 

accommodate mining activities; however, they would continue to be constructed, used, modified, and 

moved until they are reclaimed. No new roads would be constructed under Alternative A. Roads and 

routes of travel would be watered to abate the effects of fugitive dust emissions as required by air quality 

standards. Overall there would be no changes to transportation and access as a result of Alternative A. 

4.15.1.2 Indirect Impacts 

There would be no indirect impacts to access and transportation as a result of Alternative A. 

4.15.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM 

4.15.2.1 Direct Impacts 

Under Alternative B mining within the Project Area would cease and reclamation activities would begin. 

Traffic related to mining within the Project Area would be reduced as reclamation is completed 

(approximately three to five years). Heavy equipment operating within the Project Area would cease with 

the exception of equipment engaged in reclamation activities. Mining activity may still occur in other 

areas within the SMCRA permit boundary resulting in continued internal traffic although the rate of 

mining would decrease from an average 2.3 mtpy to approximately 1.5 mtpy. The 37,226 truck trips 

would be reduced as a result of the reduced mining rate, but the hauling of CCRs waste would not 

change assuming the Craig Station continued to operate at current capacity. Changes to AADT counts 

for U.S Highway 40 and SHs 13 and 394 would be short-term and minor and occur mostly from fewer 

employees and reduced delivery of supplies as a result of the reduced mining rate. Over the long term, 

once mining is completed, traffic rates to and from the mine would be reduced. 

4.15.2.2 Indirect Impacts 

There would be no indirect impacts to access and transportation as a result of Alternative B. 

4.15.3 Mitigation Measures 

No mitigation measures would be necessary for access and transportation. 

4.16 Solid Waste 

4.16.1 Alternative A – Proposed Action 

4.16.1.1 Direct Impacts 

Direct impacts may occur through the mishandling or improper disposal of solid waste. Those impacts 

may include contamination of soil and water resources and could be long term if leaks or sources of 

contamination are not discovered in a timely manner. Under Alternative A, impacts to the environment 

from the potential release of hazardous or solid waste are not anticipated to occur. Solid waste that may 

be generated during coal mining would be mainly non-hazardous materials which would be hauled off 

site or disposed in mined out pits. Waste that can be disposed in mined out pits consists of inert 

materials such as trash, lumber, concrete, scrap iron, and unsalvageable tires (TMI 1981 et seq.). 

Construction sites and all facilities would be maintained in a sanitary condition at all times. Waste 

materials that cannot be disposed on-site would be disposed of promptly at appropriate off-site waste 

disposal facilities. All hazardous waste would be accumulated and disposed off-site according to 

applicable rules and regulations. Human waste from the mine facilities is transported through a flow line 

to the Craig Station sewage system. The sewage at work sites in portable toilets would be transported 

off-site for disposal. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-57 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

Assuming TMI follows the procedures outlined above for waste disposal, including hauling all materials 

that are not inert to an appropriate disposal facility, there would be no impacts from disposal of solid 

waste within the mined out pits. 

4.16.1.2 Indirect Impacts 

A waste stream deposited outside of the Project Area but which could result in indirect impacts is CCRs 

from the Craig Station. Indirect impacts may occur if buried CCRs material becomes leached and 

regulated constituents are released to the environment. 

The CCRs would continue to be placed into pits during backfilling or placed and encapsulated into spoil 

piles as long as the Trapper Mine is active. An annual average of 501,000 tons of CCRs have been 

placed at the mine since 1999 (TMI 2015). The placement of CCRs into mine pits is regulated by rules of 

various agencies including the CDRMS, CDPHE, Moffat County, and the CSLB (TMI 2015). In order to 

conduct mine-filling, the CDRMS requires that the applicant conduct a baseline groundwater study to 

describe the hydrologic setting, define the chemical and physical characteristics of the coal combustion 

residuals and overburden, and assess the leaching potential of the waste. 

The CCRs were subjected to leach testing and determined to present a low potential for toxic metals to 

be leached from the materials (TMI 1981 et seq.). The leaching potential of toxic metal constituents was 

tested in order to determine whether the CCRs could be considered characteristic hazardous waste. 

CCRs were subjected to the Extraction Procedure (EP) Toxicity test and the leachate was analyzed for a 

number of metal constituents (TMI 1981 et seq.). Of concern regarding hazardous waste determination 

are the eight RCRA metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver. 

Concentrations of the RCRA metals in the EP toxicity leachate were orders of magnitude below the 

toxicity limits. Given the EP toxicity results, the CCRs were shown to be a non-hazardous waste. The 

percolation rate of the groundwater was also evaluated to determine the potential for the movement of 

contaminants in the event leaching of the material were to occur. The percolation analysis indicated that 

movement of any leached contaminants to the groundwater table would be very slow, and the material 

would be less likely to leach because of relatively low permeability of the CCRs. 

The CDRMS also requires that the waste be isolated from surface and groundwater. The waste must be 

placed above the expected post-mining groundwater level and no less than 50 feet (15 meters) 

horizontally from surface drainages. Also, the coal combustion residuals must be covered with a 

minimum of six feet (two meters) of cover. Groundwater monitoring is required before, during, and after 

the waste is placed into pits. 

As discussed in Section 4.5.1.2 impacts to groundwater as a result of CCRs placement are expected to 

be negligible due to the groundwater monitoring and the limited permeability and infiltration of 

groundwater into buried CCRs. The CCRs placement locations will be reclaimed in accordance with the 

approved reclamation plan and long-term indirect impacts from CCRs placement are expected to be 

negligible. 

4.16.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM 

4.16.2.1 Direct Impacts 

Under Alternative B, mining operations would cease. As part of closure/reclamation, all materials or 

products not necessary for closure or reclamation activities would be removed from the Project Area. 

The removal of materials and products would considerably reduce the risks associated with spills and 

contamination of soil and groundwater. Solid waste would be hauled off-site or disposed on-site in 

accordance with the TMI solid waste permit issued by Moffat County and TMI’s SMCRA permit. Inert 

materials that can be disposed in mine pits would be placed into pits during backfilling. When active 

reclamation is complete, the potential impacts of waste generation and disposal would be negligible. 

Solid waste disposal could continue for mining-related solid waste as a result of mining in areas outside 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-58 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

of the Project Area using the same practices as currently employed. As a result the direct impacts of 

solid waste disposal under Alternative B would be the same as those outlined for Alternative A. 

Once all mining and reclamation activities are completed, no impacts from solid waste generation and 

disposal would be anticipated. 

4.16.2.2 Indirect Impacts 

CCRs placement and the associated indirect impacts would continue under Alternative B. As discussed 

in Section 4.5.1.2, impacts to groundwater as a result of CCRs placement are expected to be negligible 

due to the groundwater monitoring and the limited permeability and infiltration. As described above for 

Alternative A, the CCRs placement locations are subject to monitoring and operational requirements. As 

a result, the impacts from CCRs placement under Alternative B would be the same as described above 

for Alternative A. 

4.16.3 Mitigation Measures 

No mitigation measures would be necessary for solid waste since there are regulatory programs that 

govern the handling of waste materials. 

4.17 Noise 

4.17.1 Alternative A – Proposed Action 

Project noise under Alternative A would remain consistent with current mining activities. TMI currently 

mines at an average rate of 2.3 mtpy with a maximum production rate of 2.6 mtpy. These production 

rates would not increase under Alternative A. In addition, TMI would use the same equipment as 

described in Chapter 2.0. Reclamation activities would continue as before occurring as the mining 

process moves eastward. Production and disturbance rates would continue 24 hours a day, 7 days a 

week through the end of the life of mine in 2025. 

4.17.1.1 Direct Impacts 

Currently the closest sensitive receptor is an isolated residence located approximately 0.46 mile 

(0.74 km) to the north of the disturbance area. As mining activities continue eastward, the nearest 

sensitive receptor would shift to a residence located 0.70 mile (1.13 km) north of the Project Area and 

L Pit. Operational noise associated with reclamation, haul trucks and the mine pit have not elicited any 

complaints for noise at the Trapper Mine. Given the topography and vegetative cover, it is likely that 

most noise would be attenuated before reaching any residences or receptors and noise related impacts 

would be short-term, during the life of the mining and reclamation operations, and negligible. 

4.17.1.2 Indirect Impacts 

Indirect impacts include noise associated with haul trucks carrying coal to the Craig Station or CCRs 

back to the Trapper Mine for placement. In addition, the noise associated with the activities at the Craig 

Station would be an indirect noise impact. No information is available to quantify the noise associated 

with the Craig Station; however, there are no residences within close proximity to the Craig Station so 

noise related indirect impacts would be negligible but would occur long-term over the life of the Craig 

Station. 

4.17.2 Alternative B – Disapproval of the Mining Plan Modification by the ASLM 

4.17.2.1 Direct Impacts 

Under Alternative B, mining activities within the Project Area would be terminated. TMI would continue to 

mine within the SMCRA permit boundary outside of the Project Area. Reclamation within the Project 

Area would begin once mining ceased. Noise for this process would be directly related to tearing down 

and moving structures and equipment, backfilling and grading the land to the approved post-mining 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-59 
 

 

 

 

 

 

 

 

 

Chapter 4.0 – Environmental Consequences 

topography, topsoil replacement, and seeding activities. Reclamation activities within the Project Area 

are expected to be completed three to five years after closure with the impacts associated with these 

activities being similar to Alternative A. The closest residence to the activities in the N and I pits outside 

of the Project Area is located 0.66 mile (1 km) west of the I Pit. 

Within the I and N Pit mine areas outside of the Project Area, mining would occur at a slower rate than 

the mining presently being conducted, resulting in less noise production. Direct impacts of Alternative B 

would be short-term and negligible. 

4.17.2.2 Indirect Impacts 

Indirect impacts under Alternative B would be the same as described for Alternative A. 

4.17.3 Mitigation Measures 

No mitigation measures would be necessary for noise. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

4-60 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 5.0 – Cumulative Impacts 

5.0 Cumulative Impacts1 

5.1 Introduction 

This chapter discusses the potential contribution to cumulative impacts of Alternative A - the Proposed 

Action Alternative, and Alternative B - Disapproval of the Mining Plan Modification by the ASLM. 

Alternative C - the No Action Alternative is not evaluated in detail because the potential contribution to 

cumulative impacts of Alternative C would fall within the range described for Alternative A and 

Alternative B, depending on when Alternative C is implemented. Each of these alternatives is described 

in Chapter 2.0. 

Cumulative impacts are those impacts that result from incremental effects of an action when added to 

other past and present actions, and reasonably foreseeable future actions regardless of what agency or 

other entity undertakes such other actions. Cumulative impacts occur over a given time period. The time 

period for cumulative effects includes the time period when the impacts of past and present actions and 

reasonably foreseeable future actions overlap with the time period when project impacts would occur 

(including construction, operation, and reclamation phases). 

This section considers past and present actions and reasonably foreseeable future actions within a 

cumulative impact assessment area (CIAA) defined for each resource. The CIAA varies by resource and 

was determined based on the location, extent, and type of resource impacts as described in Chapter 4.0. 

The CIAA for each resource, and the time frame associated with each CIAA, are included on Table 5-1. 

Table 5-1 CIAA and CIAA Time Frame by Resource 

Resource CIAA CIAA Time Frame 

Topography SMCRA permit boundary Until approved post-mining 

topography is achieved 

Air Quality Airshed boundary Through the life-of-mine and 

completion of reclamation 

Climate Change State of Colorado Through the life-of-mine and 

completion of reclamation 

Geology and Minerals SMCRA permit boundary Through the life-of-mine and 

backfilling operations 

Surface Water and 

Groundwater Resources 

Yampa River and associated drainages 

from the confluence of Elkhead Creek 

to the confluence of the Williams Fork 

River, including the Williams Fork River 

and its tributaries from the confluence 

of its South and East Forks to the 

confluence with the Yampa River. 

Through the life-of-mine and Phase 

III bond release 

Soils SMCRA permit boundary Through the life-of-mine and 

completion of reclamation 

Vegetation SMCRA permit boundary Through the life-of-mine and Phase 

III bond release 

Wetlands and Riparian Zones SMCRA permit boundary Through the life-of-mine and Phase 

Italicized text denotes language inserted either in response to comments received on the EA (see Appendix E) or to clarify or 

update a topic based on new or additional information received. Each place where italicized text appears is denoted by a bar in 

the left hand margin. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

1 

5-1 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

5.2 

Chapter 5.0 – Cumulative Impacts 

Table 5-1 CIAA and CIAA Time Frame by Resource 

Resource CIAA CIAA Time Frame 

III bond release 

Small game and migratory 

birds, including raptors 

SMCRA permit boundary Through the life-of-mine and Phase 

III bond release 

Big Game Game Management Unit Through the life-of-mine and Phase 

III bond release 

BLM/State Sensitive species SMCRA permit boundary plus 1-mile 

(1.6-km) radius around disturbed areas 

Through the life-of-mine and Phase 

III bond release 

Yellow-billed cuckoo SMCRA permit boundary plus 2 miles 

(3.2 km) up and downstream of the 

Craig Station on the Yampa River 

Through the life-of-mine 

Colorado River Fish Airshed boundary Through the life-of-mine 

Cultural and Historic 

Resources 

SMCRA permit boundary plus 0.25-mile 

(0.4-km) buffer zone 

Through the life-of-mine 

Socioeconomics Moffat, Routt, and a portion of Rio 

Blanco counties 

Through the life-of-mine and 

completion of reclamation 

Visual Resources Viewshed for the Project Area Through the life-of-mine and 

completion of reclamation 

Paleontology SMCRA permit boundary Through the life-of-mine 

Access and Transportation Moffat, Routt, and a portion of Rio 

Blanco counties 

Through the life-of-mine and 

completion of reclamation 

Solid Waste SMCRA permit area plus the Moffat 

County landfill and the Hayden 

Generating Station CCRs placement 

area 

Through the life-of-mine and 

completion of reclamation 

Noise Project Area and 0.5-mile (0.8-km) 

buffer 

Through the life-of-mine and 

completion of reclamation 

For all resources, the CIAA for Alternatives A and B are the same because under Alternative B, mining at 

the Trapper Mine would continue in areas outside of the Project Area, and the other past and present 

actions and reasonably foreseeable future actions would remain the same. The timing for completion of 

mining activities under Alternative A would be approximately 10 years, while the timing for completion of 

mining activities under Alternative B would be three to four years. 

Past and Present Actions 

Past and present actions in Moffat, Routt, and the eastern third of Rio Blanco County, including the 

Colowyo Coal Mine and the town of Meeker, include coal mining, sand and gravel mining, power 

generation, livestock grazing, ranching, recreation, and oil and gas development. These activities have 

the potential to affect natural and human resources in the area. 

Coal mining has been present in these three counties for decades. A number of mines that were active 

as of August 3, 1977, when SMCRA was enacted became permitted by CDRMS. Some mine operators 

chose not to seek permits and several mines that obtained permits from CDRMS have since been 

reclaimed and their permits terminated. Past and present coal mining includes mines categorized by 

CDRMS as presently active, inactive, mines in temporary cessation, and mines in permanent cessation. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-2 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 5.0 – Cumulative Impacts 

Active coal sites include those that are producing, idled (not producing but not in temporary cessation), 

or are no longer producing and are in the process of conducting final reclamation. Active coal mining 

operations within the three counties include: 

•	 The Colowyo Mine, operated by Colowyo Coal Company, is a producing surface coal mine 

located approximately 30 miles (48 km) southwest of the Project Area in Moffat and Rio Blanco 

counties. 

•	 The Foidel Creek Mine, operated by the Twentymile Coal Company, is a producing underground 

mine located approximately 35 miles (56 km) southeast of the Project Area in Routt County. 

•	 The Peabody Sage Creek Mine, operated by Peabody Sage Creek Mining, LLC, is an idled 

underground mine located in Routt County adjacent to and immediately north of the Foidel 

Creek Mine. 

The Williams Fork Mine is a site located in Moffat County that is in temporary cessation (CDRMS 2015). 

Coal sites in temporary cessation have facilities on the ground but have temporarily stopped producing 

pending the possibility of obtaining new coal contracts. The Hayden Gulch Loadout, the Seneca II-West 

Mine and the Yoast Mine are coal sites in Routt County in permanent cessation (CDRMS 2015). 

Permanent cessation sites are those that are no longer producing and whose reclamation is a few years 

old, but whose reclamation has not progressed to the point that site-wide Phase III bond release has 

been achieved. Coal exploration has occurred in the past and continues in the region with approximately 

ten active coal exploration permits in the three counties described above (CDRMS 2015). 

Other active mining operations within Moffat, Routt, and the eastern third of Rio Blanco County include 

sand, gravel, and crushed stone material operations (aggregate mining). 

There are two power generating stations in the general vicinity of the Project Area: 

•	 Craig Station located northwest and adjacent to the Project Area is operated by Tri-State 

Generation and Transmission Association; approximately 300 people work at the 1,264-MW 

plant (Tri-State 2015). Plant construction began in 1974 with the first operating unit completed in 

1979. The plant site covers 1,120 acres. Its main water source is the Yampa River with 

supplemental allocations from nearby reservoirs. Craig Station receives its coal supply primarily 

from two sources: Trapper Mine and the Colowyo Mine sited about 30 miles (48 km) southwest 

of Craig Station. Trapper Mine delivers coal to the plant via 100-ton haul trucks from the mine 

site. Colowyo Mine delivers coal to the Craig Station daily by train. The station also augments 

these two sources of coal with spot coal purchases from other mines in northwestern Colorado 

(OSMRE 2015). 

•	 The Hayden Station, located approximately 21 miles (34 km) east of the Craig Station in Routt 

County, is a 446-MW plant operated by Xcel Energy. Construction began in 1962 with operation 

of Unit 1 in 1965 and a second unit in 1976. The Hayden Generating Station receives its coal 

from the Twentymile Coal Company’s Foidel Creek Mine and occasionally the Colowyo Mine. 

Coal is delivered to the station via train (OSMRE 2015). 

Historically, the Project Area and the vicinity have been used for ranching and livestock grazing, in 

particular cattle and sheep. In addition to livestock grazing, the area also supports wildlife including big 

game species. Hunting is the primary recreational activity in the area. Routt County includes a 

2,965-acre ski area with an annual average of 350,000 to 400,000 visitors. 

Other existing developments in the region include towns and connecting roads. U.S. Highway 40 is the 

major east-west highway located north of the Project Area connecting the towns of Hayden, Craig, and 

Maybell. SH 13 is located immediately west of the mine and runs from the northeast to the southwest of 

the western permit boundary and also runs north of the City of Craig. This is the main highway 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-3 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

5.3 

Chapter 5.0 – Cumulative Impacts 

connecting Craig with Meeker and Rifle to the south and Wyoming to the north. Various county 

maintained and unmaintained dirt roads and two tracks are located within the CIAA. 

Electric transmission lines of various capacities traverse the Project Area and vicinity. Wilson Reservoir 

is located approximately 30 miles (48 km) southwest of the Project Area, and Elk Head Reservoir is 

located approximately 17 miles (27 km) northeast of the Project Area. 

Oil and gas operations have been occurring in the vicinity of the Project Area since the 1920s. Numerous 

oil and gas wells have been drilled within Moffat, Routt, and Rio Blanco counties. The COGCC database 

lists a total of 137 wells as producing within a 20-mile (32-km) radius of the Project Area; 6 wells in the 

drilling stage, 4 wells used for injection, 2 wells awaiting completion, and 51 wells listed as shut-in or 

temporarily abandoned. Potential impacts from oil and gas development are more dispersed over a 

larger area than for mining operations (COGCC 2015a). 

Reasonably Foreseeable Future Actions 

Reasonably foreseeable future actions in the general vicinity of the Project Area include additional coal 

mining, continued livestock grazing, ranching and recreational activities, and ongoing oil and gas 

operations. 

It is reasonable to assume that coal mining will occur in the future. This may occur either as an extension 

of current mining operations or in new areas. Reasonably foreseeable future activities at the current 

mining operation within the CIAA include: 

•	 The Colowyo Coal Company’s Colowyo Mine is in the process of obtaining approval for the 

Collom Expansion through OSMRE, BLM, and CDRMS. The Collom Expansion would extend 

mining operations for approximately 20 to 40 years, depending on the mine production rate. A 

NEPA document is being prepared to address the Collom Expansion. Produced coal would 

likely be supplied to the Craig power plant as well as other customers throughout the country 

(OSMRE 2015). 

•	 The Twentymile Coal Company’s Foidel Creek Mine was recently issued a 310 acre lease 

modification by the BLM LSFO, effective April 1, 2016. The lease modification added 310 acres 

and about 340,000 tons of federal coal to the Foidel Creek Mine (BLM 2015). CDRMS is 

reviewing an application for a PR that would include the mining of these 310 acres of federal 

coal. 

Supplies of coal to the Craig and Hayden stations from the mines described above are not exclusive 

contracts. In the absence of any data to the contrary, it is assumed that the Craig and Hayden stations 

would continue operating at current levels even if Trapper Mine, Colowyo Mine, and Foidel Creek Mine 

stopped supplying coal because the stations would purchase coal from other suppliers. 

Ranching and livestock grazing operations in the area are expected to continue at current levels for the 

reasonably foreseeable future. Additionally, hunting and other recreational activities also are likely to 

continue at current levels into the reasonably foreseeable future. 

According to the COGCC database, there are 67 oil and gas wells which are permitted through COGCC 

but have not yet been drilled within a 20-mile (32-km) radius of the Project Area (COGCC 2015a). The 

BLM’s Colorado State Office conducts quarterly competitive lease sales to sell available oil and gas 

lease parcels. The act of leasing does not authorize any development or use of the surface of lease 

lands, without further application by the lessee and approval by the BLM. Oil and gas operations are 

anticipated to continue in the future in the vicinity of the Project Area. In 2014, 112 parcels comprising 

86,423.66 acres within the LSFO were nominated for the February 2015 Competitive Oil and Gas Lease 

Sale (OSMRE 2015). In support of this, the BLM LSFO completed an EA for this oil and gas lease sale 

that included parcels in the vicinity of the Project Area. Additional lease parcels were nominated in 2015 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-4 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 5.0 – Cumulative Impacts 

for the 2016 sale, and future lease parcels are expected to become available in subsequent years (BLM 

2015). Within the Project Area, oil and gas development may potentially occur after completion of coal 

mining and reclamation of the current and proposed mining areas is completed. 

5.4 Cumulative Impacts 

This section describes potential cumulative impacts to resources in the vicinity of the Project Area from 

the past and present actions and reasonably foreseeable future actions in conjunction with the 

alternatives. Cumulative impacts can result from individually minor but collectively significant actions 

taking place over a period of time (40 CFR 1508.7). For each resource, the contribution to cumulative 

impacts in the CIAA is described. The CIAAs vary by resource, as shown in Table 5-1, and range in 

geographic size from the Project Area with a buffer (for noise impacts) to a watershed (water) and all or 

portions of three counties (socioeconomics and transportation). For the analysis of cumulative impacts, it 

is assumed that all design features and any applicable mitigation measures for Alternative A would be 

implemented. 

5.4.1 Topography 

The CIAA for topography is the SMCRA permit boundary. Overall, mining of the Project Area under 

Alternative A or outside the Project Area under Alternative B would result in a short-term contribution to 

cumulative impacts on topography during mining operations. The contribution to cumulative impacts 

under both alternatives would cease, once the approved post-mining topography is achieved. 

5.4.2 Air and Climate Resources 

The CIAA for air quality encompasses the airshed boundary (Figure 3-1). For air quality, the direct and 

indirect emissions associated with the Trapper Mine are already occurring in the local environment 

(Section 4.3). As such, any cumulative air quality impacts are reflected in the air quality monitoring data 

collected in western Colorado, and the cumulative air quality impacts are represented by the baseline air 

quality conditions described in Section 3.3. 

5.4.2.1 Regional Air Emission Sources 

Table 5-2 summarizes the air emissions from industrial and commercial sources located within the 

airshed boundary (Figure 3-1). These data were compiled from APENs submitted to CDPHE by the 

regulated air emission sources and are reported in the Colowyo South Taylor EA (OSMRE 2015). The 

APEN emissions inventory is dominated by the two coal-fired electric generating stations in the region: 

Craig Station and Hayden Generating Station. 

Table 5-2	 Air Emissions Inventory for EA Air Quality Study Area 

Compiled from CDPHE APEN Data
 

Pollutant Emissions (tpy) 

PM2.5 837 

PM10 3,462 

SO2 5,609 

NOX 19,147 

CO 3,350 

VOCs 2,798 

Source: OSMRE 2015. 

Table 5-3 summarizes the county-by-county data for northwest Colorado as compiled by the 2011 

USEPA National Emissions Inventory (OSMRE 2015). These data include the industrial/commercial 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-5 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 5.0 – Cumulative Impacts 

emission sources listed in the previous table, plus non-industrial emissions sources such as mobile 

sources (automobiles and trucks). 

Table 5-3	 Air Emissions Inventory in tpy by County - 2011 National Emissions Inventory 

Data 

County CO NOx PM10 PM2.5 SO2 VOCs 

Garfield 25,325 16,123 4,170 1,210 187 91,075 

Moffat 8,188 15,308 5,243 1,351 3,978 5,618 

Rio Blanco 6,497 4,810 5,091 1,128 339 26,960 

Routt 17,218 7,732 7,856 2,126 2,243 3,758 

TOTAL 57,228 43,974 22,359 5,814 6,746 127,411 

Source: OSMRE 2015. 

5.4.2.2 Cumulative Direct and Indirect Air Emissions 

Table 5-4 provides a cumulative summary of the direct and indirect emissions that would be associated 

with Alternative A. The direct/indirect emissions data are reported for the worst-case year (2020). 

Table 5-4	 Summary of Trapper Mine Direct and Indirect Air Quality Emissions and
 

Contribution to Cumulative Total Emissions
 

CO 

tpy 

NOX 

tpy 

PM10 

tpy 

PM2.5 

tpy 

SO2 

tpy 

VOCs 

tpy 

CO2e 

MT/yr 

Fugitive Dust -- -- 591 91 -- -- --

Fuel Combustion 378 987 66 64 52 72 380,973 

Blasting 291 74 <1 <1 9 -- 22,364 

Coal Seams -- -- -- -- -- -- 126,678 

CCRs Disposal 5 12 13 2 2 1 985 

Craig Station 650 7,445 98 61 1,567 78 5,341,966 

Trapper Mine 

Direct and 

Indirect TOTAL 

1,324 8,518 768 218 1,630 151 5,872,966 

Contribution to 

Cumulative Total 2.3% 19.4% 3.0% 2.7% 22.7% 0.1% 4.1% 

Also shown in Table 5-4 is the relative contribution of the direct/indirect emissions to the cumulative 

county-wide emission totals described earlier, or in the case of the CO2e emissions, the comparison is to 

the statewide 2010 GHG emissions inventory (CDPHE 2014). Generally, the direct/indirect emissions for 

the Trapper Mine would contribute about 2 to 3 percent to the emissions total from the four-county area 

(Moffat, Routt, Rio Blanco, and Garfield) of the airshed boundary. The exceptions would be the SO2 and 

NOX emissions, which are dominated by the coal-fired electric generating station emissions (Craig 

Station and Hayden Station). For NOX and SO2, the Trapper Mine contribution would be about 

20 percent, primarily from the indirect emissions associated with combustion of coal from Trapper Mine 

at Craig Station. Overall, Alternative A’s direct contribution to cumulative air quality impacts would 

continue throughout the life of the mine and through completion of reclamation. The indirect contribution 

to cumulative air quality impacts would continue as long as Trapper Mine is contributing coal to the Craig 

Station. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-6 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 5.0 – Cumulative Impacts 

PM10, PM2.5, NO2, and SO2 Impacts 

Direct emissions at Trapper Mine are dominated by the PM10 and PM2.5 fugitive dust emissions. Fugitive 

dust emission impacts from surface mining operations tend to be localized. As a fugitive dust plume 

moves downwind, gravitation and other physical forces deplete the emissions plume and particle 

deposition occurs. The localized nature of fugitive dust emissions minimizes the potential for large-scale 

cumulative air quality impacts with other regional emission sources. 

In the dispersion modeling studies described in Appendix B, the cumulative impacts have already been 

addressed through the incorporation of a “background” concentration for the pollutants modeled. 

Background represents the contribution to ambient air quality impacts from sources not explicitly 

included in the modeled emissions source inventory. As such, the air quality impacts reported in 

Section 4.3.1 would be representative of the expected cumulative air quality impacts for the areas 

immediately surrounding the Trapper Mine. 

O3 Impacts 

Cumulative O3 impacts would be best represented by air quality monitoring data within the airshed 

boundary. These data are summarized in Table 5-5. For the monitoring stations reported in Table 5-5, 

only the Lay Peak and Meeker monitoring stations occur within the airshed boundary. As the Trapper 

Mine direct and indirect emissions already exist and no changes to production at the Trapper Mine are 

proposed as part of the Project, any cumulative impacts associated with Trapper Mine-related emissions 

and other regional emissions are included in the O3 monitoring data from these locations. 

The measured O3 concentrations were compared to the O3 NAAQS adopted by USEPA in October 2015 

(70 ppb). Based on the current (2014) O3 monitoring levels representative of the airshed boundary (i.e., 

Lay Peak and Meeker monitoring stations), the O3 levels in the airshed would comply with the more 

restrictive NAAQS adopted in 2015. 

Table 5-5	 Western Colorado O3 Measurements Representative of Trapper Mine Air Quality 

Study Area Based on 2014 Monitoring Data 

Monitor 

Location 

(County) 

2014 O3 Concentrations (ppb) 

NAAQS 

1st Maximum 4th Maximum (ppb) 

3-year Average 

of 4th 

Maximum 

(2012-2014) 

Rifle Garfield 62 61 63 70 

Lay Peak Moffat 67 62 64 70 

Meeker Rio Blanco 63 62 63 70 

Rangely Rio Blanco 66 62 74 70 

Source: OSMRE 2015b. 

The Colorado Air Resource Management Modeling Study (CARMMS) also is a useful tool for assessing 

projected cumulative impacts to O3 levels. CARMMS was commissioned by BLM to track air quality 

across the different Colorado field offices, with a focus on addressing how potential future oil and gas 

development might affect air quality. CARMMS simulates the air quality effects of oil and gas 

development out to the year 2021, and simulates different levels of projected development. The “high” 

development scenario is based on reasonably foreseeable development scenarios developed by each 

local BLM field office. With the decline in oil prices in 2015, it remains to be seen whether the projections 

for new oil and gas development in western Colorado reflected by the BLM scenarios will occur. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-7 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 5.0 – Cumulative Impacts 

The CARMMS information is most useful in the projections of future O3 levels. The CARMMS modeling 

applied the Community Airshed Model with Extensions, which simulates pollutant emissions, transport, 

and dispersion using a four-km (2.5-mile) grid. The four-km grid spacing means that local features 

associated with the Trapper Mine would not be detected by the Community Airshed Model with 

Extensions, so the AERMOD modeling conducted for PM10, PM2.5, SO2, and NO2 is considered a more 

realistic depiction of the local impacts near the Trapper Mine (see Section 4.3.1.3). However, as O3 was 

not modeled for the Trapper Mine, the CARMMS information is useful for tracking potential O3 levels and 

is the only available information that would capture future emissions associated with expected oil and 

gas development in the region. 

The CARMMS modeling output for the 4th highest daily maximum concentration was reviewed for the 

“high” development scenario. The area of Moffat County surrounding Craig showed projected O3 levels 

from the CARMMS modeling generally in the 67 to 70 ppb range, which is within the updated NAAQS. 

Immediately near Craig and the Craig Station, the projected O3 levels from the CARMMS modeling 

would be in the 65 to 70 ppb range. In close proximity to the Craig Station, the NOX emissions from the 

power plant likely deplete the O3 levels, and this effect appears in the CARMMS modeling. 

In western sections of Moffat County and Rio Blanco County near Rangely, the projected O3 levels 

would be above the 70 ppb NAAQS level based on the CARMMS modeling for the “high” development 

scenario. However, the CARMMS areas of modeled O3 concentrations above 70 ppb are outside the 

Trapper Mine airshed boundary. As stated previously, the projected elevated O3 levels in western 

sections of Moffat County and Rio Blanco County are likely due to the emissions associated with existing 

and future oil and gas development in the Uinta Basin of eastern Utah and are not tied to the Trapper 

Mine direct and indirect emissions. 

Acid Deposition and Visibility Impacts 

Acid deposition and visibility are of concern in designated Class I PSD areas. Downwind of the air quality 

study area, Class I areas include the Mt. Zirkel Wilderness located in the Park Range east of Steamboat 

Springs. 

Acid deposition and visibility impacts are generally associated with SO2 and NOX emissions from coalfired electric generating stations, which would include the Craig Station. The indirect impacts associated 

with combustion of coal from Trapper Mine are presented in Section 4.3.1.2. Other coal fired electric 

generating stations that could impact visibility and acid deposition at the Mt. Zirkel Wilderness include the 

Hayden Station (Hayden, Colorado), the Jim Bridger Station (northeast of Rock Springs, Wyoming), and 

the Bonanza Station (southeast of Vernal, Utah). The relative impacts to acid deposition and visibility 

from Jim Bridger are somewhat mitigated by the distance to the Mt. Zirkel Class I area, and the relative 

impacts from Bonanza are somewhat mitigated by the distance and small electric generating capacity of 

this unit. 

Improved emission controls are expected at all nearby electric generating stations within the next five to 

10 years. These improvements are intended to help mitigate any ongoing impacts related to visibility and 

acid deposition. Most of the future emission control improvements would reduce NOX emissions. NOX 

reductions would occur at Craig Station from installation of SCR at Units 1 and 2 and SNCR at Unit 3 to 

meet emission limits established by the Colorado Regional Haze SIP (see Table 4-8). These reductions 

are required at the Craig Station over the 2018-2021 timeframe. Similar emissions reductions are 

scheduled to occur at the other regional coal-fired electric generating stations in response to BART 

regulations and other requirements of the Colorado Regional Haze SIP rules. After these emission 

reductions occur, the visibility and acid deposition impacts to Class I areas such as Mt. Zirkel Wilderness 

should be reduced. 

5.4.2.3 Cumulative GHG Impacts 

As summarized in Section 4.3, the project-related direct and indirect GHG emissions would be 

dominated by the indirect emissions linked to combustion of the Trapper Mine coal at the Craig Station. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-8 
 

 

 

 

 

 

 

 

 

Chapter 5.0 – Cumulative Impacts 

The indirect GHG emissions at Craig Station represent 4.1 percent of the Colorado GHG emissions total 

(2010 data) and 0.07 percent of the national GHG emissions total (2007 data) as shown on Table 4-14. 

The GHG-related impacts from an individual emissions unit cannot be accurately quantified. Possible 

GHG impacts have already been described in Section 4.3.1.2, and these impacts represent the possible 

cumulative effects of all GHG emissions (USEPA 2015). 

 The region will experience warmer temperatures with less snowfall. 

 Temperature are expected to increase more in the winter months than in summer, more at night 

than in the day, and more in the mountains than at lower elevations. 

 Earlier snowmelt will result in earlier peak stream flows, weeks before the peak needs of 

ranchers, farmers, recreationalists, and others. In late summer, rivers, lakes, and reservoirs will 

be drier. 

 More frequent, more severe, and possibly longer-lasting droughts will occur. 

 Crop and livestock production patterns could shift northward; less soil moisture due to increased 

evaporation may increase irrigation needs. 

 Drier conditions will reduce the range and health of ponderosa and lodgepole pine forests;) and 

increase the susceptibility to fire. 

 Grasslands and rangeland could expand into previously forested areas. 

 Ecosystems will be stressed and wildlife, such as mountain lion, black bear, long-nose sucker, 

pine marten, and bald eagle could be further stressed. 

5.4.2.4 Cumulative Air Quality and Climate Impacts – Alternative B 

Alternative B is not expected to have substantially different cumulative air quality and climate impacts 

compared to Alternative A. Cumulative impacts in the airshed boundary would be dominated by nonproject-related emissions, and these emissions and associated impacts would continue under 

Alternative B. Indirect impacts tied to coal combustion at the Craig Station would be expected to continue 

under Alternative B. TMI would mine alternative coal resources from lands outside the subject leases 

although the mining rate would be reduced. Craig Station could secure alternative coal sources to 

operate at or near current levels. Overall, the net result would be no substantial changes in the 

contribution to cumulative air emissions and impacts under Alternative B. 

5.4.3 Geology and Minerals 

The CIAA for geology and minerals is the SMCRA permit boundary. From 1978 to 2014, the Trapper 

Mine has cumulatively produced 78,740,532 tons of coal for an approximate average of 2.13 mtpy 

(TMI 2015). Under Alternative A, approximately 19 million tons of coal would be mined resulting in an 

additional increment of approximately 25 percent of the expected cumulative production by 2025 (or a 

total of 97,875,232 tons). The additional production would contribute an incremental removal of 

overburden and interburden which would be proportional to the amount of coal removed depending on 

the stripping ratio encountered during mining. 

Cumulative coal production from 1864 to 2014 in Moffat and Routt counties (including the Colowyo and 

the Foidel Creek mines) is approximately 594 million tons (Carroll 2004; CDRMS 2015). The mining of 

an additional 19 million tons of coal under Alternative A would represent 3 percent of the total cumulative 

production from these counties. However, the additional 19 million tons of coal represents a tiny fraction 

of the coal resource in the Yampa Coal Field which was estimated at 7.6 billion tons of coal less than 

500 feet deep (Brownfield et al. 2000). Overall, the contribution to cumulative impacts to geology during 

the life of the mine and backfilling operations would be negligible. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-9 
 

 

 

 

Chapter 5.0 – Cumulative Impacts 

Under Alternative A, the contribution to cumulative effects on other mineral resources would be minimal 

because impacts would be short term and probably avoidable in case of oil and gas drilling. 

It is not possible to assess the incremental cumulative effects of geologic hazards (landslides and slope 

instability) due to the proposed project because of widespread unstable conditions in the CIAA. Coal 

mining activities have contributed to slope instability (landslides) in the past. There also are naturally 

occurring landslides in the CIAA. Overall, given appropriate design and monitoring, geologic hazards are 

not expected to contribute appreciably to cumulative impacts in the CIAA. 

Under Alternative B, coal mining would cease in the Project Area resulting in a permanent loss of 

approximately 17.35 million tons of coal. Mining for coal would continue in areas outside the Project 

Area, with a projected known resource of 4.5 million tons. The loss of 17.35 million tons of coal reserves 

would be minimal compared to the total estimated coal resource mined in the CIAA. Overall, the 

contribution to cumulative impacts would be similar to Alternative A. There would be no expected 

contribution to cumulative effects to other mineral resources under Alternative B. As with Alternative A, it 

is not possible to assess the cumulative incremental effects of geologic hazards (landslides and slope 

instability) because of widespread unstable conditions in the CIAA. 

5.4.4 Water Resources 

The CIAA for water resources is the Upper Yampa River watershed in Moffat County. This area 

encompasses the Yampa River and its tributaries from Elkhead Creek to the Williams Fork River, and 

the Williams Fork from the confluence of its South and East forks to the confluence with the Yampa 

River. Within the CIAA, the types of past and present actions and reasonably foreseeable future actions 

that could contribute to cumulative water resources effects include oil and gas development, aggregate 

mining, power production at the Craig Station, and livestock grazing. 

The CIAA for water resources does not include other active coal mines in the Upper Yampa River 

watershed, most of which are located in Routt County. However, the analysis presented below does 

incorporate cumulative impacts from coal mining in the watershed by reference from the Yampa River 

Cumulative Hydrologic Impact Assessment (CHIA) completed by CDRMS (CDRMS 2010). 

There are a number of active oil and gas wells in the analysis area. Activities during the production 

phase of oil and gas development mainly include visiting well sites to take measurements, collect 

hydrocarbons, and collect and dispose of waste material. In the CIAA for water resources there are 

limited opportunities to pump hydrocarbons directly into distribution lines, and most wells have separate 

tanks for oil and produced water. Accidental spills of these materials could result in cumulative surface 

water or groundwater quality impacts. If a spill should occur, these impacts would generally be confined 

to a localized area around the well pad and would be considered negligible at the scale of the analysis 

area. 

Surface disturbance from future oil and gas exploration and development could contribute to cumulative 

water quality impacts through increased runoff and erosion as new well pads and access roads are 

constructed. In the short term, erosion from the disturbed areas could increase sediment loads in the 

Yampa River and its tributaries. However, during construction of oil and gas locations in Colorado, and 

prior to interim reclamation, oil and gas operations must be covered under a Stormwater Construction 

General Permit issued by the CDPHE. Once interim reclamation has been successfully completed, oil 

and gas sites are subject to water quality controls under COGCC regulations. With these controls in 

place, water quality impacts from oil and gas operations are expected to be negligible in the short term 

and long term. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-10 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 5.0 – Cumulative Impacts 

Aggregate mining also could contribute to cumulative water quality and water quantity effects. Current 

aggregate mining operations are concentrated around the Yampa River near Craig. The proximity of 

these operations to the river increases the potential for water quality impacts. Aggregate mines also have 

the potential to form “gravel pits,” which may need to be dewatered during active mining. Dewatering 

pumping can lower water levels in nearby groundwater supply wells and also may result in surface water 

depletions. Post-mining, evaporative losses can increase as gravel pits fill with runoff and groundwater. 

Relative to the size of their operations, aggregate mines have the potential for greater impacts to 

groundwater and surface water supplies than Alternative A, mainly because the aggregate mines are 

located in closer proximity to the Yampa where groundwater is present at shallower depths. 

Coal combustion at the Craig Station also could contribute to cumulative water resource effects. Some of 

these potential impacts, such as the amount of surface water diverted annually by the Craig Station, 

have already been discussed in Section 4.5 as indirect effects related to Alternative A. Other potential 

cumulative impacts from the Craig Station could result from runoff of oil, grease, sediment, or dissolved 

metals from operation areas and coal storage piles. The potential for these types of water quality impacts 

would (presumably) be managed through implementation of a CDPS permit and required routine 

monitoring of the Craig Station’s CDPS outfalls. 

Even with the presence of oil and gas development, aggregate mines, and the Craig Station, much of the 

CIAA is still undeveloped rangeland used for grazing. Livestock grazing can increase erosion and 

sedimentation with potential impacts to water quality. However, grazing practices on public lands in the 

Project Area are managed by the BLM LSFO to protect other resources and resource uses. In the long 

term, water resource effects from grazing are expected to be minor. 

The Yampa River CHIA (CDRMS 2010) identifies four main types of probable surface water 

consequences associated with surface and underground coal mining in the Yampa River Basin: 

• Increased erosion from mine permit areas 

• Temporary changes in the timing of runoff in nearby stream flow regimes 

• Development of spoil aquifers 

• Increased TDS concentrations in mine discharge 

Of these effects, CDRMS indicates that increasing TDS concentrations in mine discharge pose the 

greatest risk of cumulative impacts to the Yampa River. To further evaluate this impact, the agency 

developed a salinity mass-loading model for the Yampa River using a modeling routine written by USGS. 

The model sums streamflow discharge and dissolved solids concentrations based on a node system 

created for the stream network. The CDRMS model has been divided into three separate modeling 

domains; two upstream domains that account for coal mine discharges in the eastern part of the Upper 

Yampa River watershed, and a downstream model of the Yampa River main stem to a point below 

Colowyo Mine. Calculated TDS results from the two upstream models are used as inputs in the main 

stem model, along with TDS inputs associated with the Trapper Mine area, Williams Fork River, Colowyo 

Mine, and Dry Creek. 

The salinity model results provide an indication of the cumulative TDS increase from mining and a 

prediction of the average TDS concentration expected in the Yampa River at Maybell. The predicted 

TDS increase varies by month and by flow conditions in the river. For example, during the high flow 

month of June, mining discharges are expected to increase the average river TDS concentration by 

approximately 50 mg/L. However, prior to spring snowmelt in March, the TDS increase in the river could 

be as high as 200 mg/L. Predicted future TDS concentrations in the river at Maybell range from an 

average of 120 mg/L in June to 522 mg/L in March. Overall, this represents a 29 percent increase in the 

river TDS compared to baseline levels. Although this increase is entirely attributable to coal mining, it 

does not meet the material damage criteria for surface water quality established in the Yampa River 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-11 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 5.0 – Cumulative Impacts 

CHIA. As such, CDRMS concludes that cumulative surface water quality impacts from coal mining in the 

Yampa River watershed are not expected to be significant. 

For groundwater, CDRMS defines several smaller cumulative impact analysis areas in the CHIA 

because of the structural and stratigraphic controls that help confine groundwater impacts to a smaller 

area relative to surface water. The cumulative impact analysis area encompassing Trapper Mine 

includes only one other coal mining operation; the Williams Fork underground mine (formerly the Eagle 

No. 5 and No. 9 Mine) that is in temporary cessation. Even if the Williams Fork Mine resumes operation, 

cumulative groundwater impacts are expected to be negligible, largely because the mine has historically 

extracted coal from stratigraphic intervals below the upper Williams Fork Formation mined by TMI. 

There is some possibility for the two mines to create cumulative drawdown effects in the Twentymile 

Sandstone. Trapper uses the Twentymile Sandstone for its potable water supply, extracting 32 acre-feet 

of groundwater from the sandstone during water year 2014 (Cummins 2015). The Williams Fork Mine 

also may indirectly remove water from the Twentymile Sandstone by dewatering deeper formations. 

Groundwater level declines in the Twentymile Sandstone are predicted to reach 20 feet at a five-mile 

radius from the Williams Fork Mine and up to 60 feet at a one-mile radius from the affected area 

(CDRMS 2010). The additive effect of groundwater pumping and mine dewatering from the Twentymile 

Sandstone could lower groundwater levels in nearby private wells completed in this unit. Impacts are 

contingent upon resumed operations at the Williams Fork Mine and would likely be negligible. 

Overall, the contribution from Alternative A to cumulative water resource impacts is expected to be 

minor. Federal and state regulations that apply to mining, oil and gas, and power generation facilities in 

the analysis area are designed to reduce water quality and water supply impacts to acceptable levels. 

The contribution to cumulative impacts would still occur to some degree through the life of the mine and 

Phase III bond release, particularly with respect to sediment erosion from disturbed ground, water 

depletions for power generation, and evaporative losses from inactive gravel pits. TDS concentrations in 

the Yampa River also are projected to increase by 29 percent as a result of coal mining, but no material 

damage to water resources would occur (CDRMS 2010). 

Overall, the Project’s contribution to cumulative water resource impacts would be less under Alternative 

B because the rate and duration of mining at Trapper Mine would be reduced. Mining would shift away 

from the Project Area to other parts of the SMCRA permit boundary where coal reserves are only 

expected to last three to four years. Consequently, reclamation would be implemented sooner under 

Alternative B, shortening the length of time that mine operations would affect groundwater and surface 

water resources. Cumulative impacts from other past and present actions and reasonably foreseeable 

future actions in the CIAA would be the same as Alternative A and are not expected to result in material 

damage to water resources. 

5.4.5 Soils 

The SMCRA permit boundary is the CIAA for soils. Mined areas in the CIAA outside the Project Area 

have been subjected to ongoing reclamation activities. Under Alternative A, surface disturbing activities 

would continue within the permit boundary and would contribute to cumulative impacts to soils. Soil 

disturbance would be minimized by TMI’s reclamation efforts which help prevent erosion and compaction 

of soils. Placing topsoil directly into reclamation areas or temporary, vegetated stockpiles also would help 

reduce erosion and disturbance that occurs in the permit boundary. While mining activities occur within 

the SMCRA permit area, no other development (including oil and gas) would be permitted in the Project 

Area during mining, which would limit the cumulative impacts to surface disturbing activities. Overall, 

Alternative A would have a minor contribution to cumulative impacts to soils during the life of the mine. 

The Project’s contribution to cumulative impacts would cease following the completion of successful 

reclamation. 

Under Alternative B, mining operations would be discontinued within the Project Area in exchange for 

immediate reclamation activities, including filling, contouring, grading of soils, topsoil application, and 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-12 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 5.0 – Cumulative Impacts 

seeding. Mining would continue to occur in areas outside of the Project Area under Alternative B, so the 

contribution to cumulative impacts to soils would continue to be minor during the life of the mine and 

would cease following successful reclamation. 

5.4.6 Vegetation 

The CIAA for vegetation is the SMCRA permit boundary, and the duration is through the life-of-mine and 

Phase III bond release. Additional mining under Alternative A would impact vegetation in the CIAA. 

Mining under Alternative A would add to the past and present actions and reasonably foreseeable future 

actions in the SMCRA permit boundary, resulting in a minor contribution to cumulative impacts due to the 

removal of mountain shrubland for mining and the eventual reclamation to rangeland and wildlife habitat. 

This would ultimately convert 257 acres of vegetation through contemporaneous reclamation as mining 

is completed in the various parts of the Project Area and add to the current total of 494 acres that have 

been released from reclamation liabilities. Within the Project Area, 22 acres of big sagebrush shrubland 

and 597 acres of mountain shrubland would remain undisturbed. In the long-term, Alternative A would 

increase the past and present disturbance and reclamation footprint within the Project Area by about 

19 percent from 1,547 acres to 1,844 acres. 

As contemporaneous reclamation is implemented, an earlier seral stage plant community with a diverse 

mosaic of grasslands and grass-shrub rangelands would develop. The reclaimed lands provide a varied 

array of habitats that are productive for wildlife and livestock that forage in the Project Area. The change 

in vegetation could shift use patterns of livestock and big game in the CIAA to favor reclaimed sites with 

more productive forage. At moderate grazing levels, livestock and big game can help to maintain a 

diverse and healthy plant community. The overall contribution to cumulative impacts to vegetation under 

Alternative A would be minor due to the localized effects and the improved productivity on mined lands 

following reclamation. 

Mining and reclamation under Alternative B would conclude earlier and affect a smaller footprint within 

the Project Area than under Alternative A. However, mining would continue within the SMCRA permit 

boundary outside the Project Area. This would contribute to cumulative impacts to vegetation in areas 

outside of the Project Area where non-federal mining continues. There would be some additional 

disturbance of reclaimed lands to support mine facilities in this portion of Trapper Mine. Overall, with 

disturbance continuing but in a slightly smaller area, the contribution to cumulative impacts for vegetation 

under Alternative B is considered minor to negligible. 

5.4.7 Wetlands and Riparian Zones 

The CIAA for wetlands and WOTUS is the SMCRA permit boundary for the Trapper Mine. Approximately 

1.55 acres of wetlands and WOTUS have been identified in the SMCRA permit boundary, outside of the 

Project Area. Any past impacts to wetlands or WOTUS in the CIAA have been or will be mitigated (see 

Section 4.7). Impacts from construction activities that occur within the CIAA also are mitigated to prevent 

runoff into drainages and wetlands. Oil and gas permitting practices and leasing approvals generally 

include mitigation for wetlands and would not occur within the active mining area. Alternative A would not 

disturb additional wetlands within the SMCRA permit boundary. Overall cumulative impacts to wetlands 

and riparian areas would be negligible with the implementation of mitigation measures. 

Under Alternative B, mining activities would cease within the Project Area, and reclamation activities 

would occur earlier than under Alternative A. Mining would continue outside the Project Area. Any 

additional wetlands disturbance would be required to be permitted through the USACE including 

potential wetlands replacement or mitigation. Mining under Alternative B could result in a minor to 

negligible contribution to cumulative impacts to wetlands and WOTUS within the SMCRA permit 

boundary during the life of the mine and Phase III bond release. 

5.4.8 Fish and Wildlife Resources 

The CIAA for fish and wildlife resources is the SMCRA permit boundary for small game, mammals, 

reptiles, and migratory birds. The CIAA for big game is the surrounding Game Management Unit. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-13 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 5.0 – Cumulative Impacts 

Overall, mining in the Project Area would contribute to cumulative impacts to fish and wildlife species 

during the life of the mine and Phase III bond release; however, the contribution would be minor to 

negligible. In the long term, Alternative A would increase the footprint of productive reclaimed rangeland 

and wildlife habitat by about 17 percent in the Project Area from 1,548 acres to 1,805 acres, which could 

support more elk and deer and improve the quality of seasonal ranges within a small portion of the big 

game CIAA. 

Other activities in the region have the potential to contribute to cumulative impacts to wildlife under 

Alternative A. Livestock can compete for forage with big game and other wildlife species. Livestock 

grazing at Trapper Mine within the SMCRA permit boundary is managed to avoid harmful impacts on 

reclaimed lands and native habitats. With these management practices, it is unlikely that livestock would 

displace big game or other wildlife within the CIAA. Oil and gas development in the vicinity of the Project 

Area would have the potential to displace wildlife species from developed areas for the life of those 

projects. Big game species would be particularly susceptible to this type of impact. However, oil and gas 

development on both federal and state leases is strictly regulated and subject to wildlife protection 

mitigation measures and best management practices to minimize disturbance to big game and other 

wildlife. Dispersed recreation may disturb individual animals and could result in minor and temporary 

displacement of big game from suitable habitats in the big game CIAA. Cumulative impacts from these 

activities would likely be negligible due to the short-term duration and localized area of impacts. 

The additional surface disturbance under Alternative A in combination with dispersed recreation and oil 

and gas development increase the potential for sediment transport to occur and, therefore, may 

potentially impact fisheries downstream from the Project Area. However, with implementation of 

sediment control features in the Project Area, the additional potential for sediment transport under 

Alternative A would be negligible. As a result, the contribution to cumulative impacts to fisheries also 

would be negligible due to the lack of habitat and unlikelihood of impacts to this resource. 

Mining and reclamation under Alternative B would conclude earlier and within a slightly smaller footprint 

within the Project Area than with Alternative A. However, mining would continue within the SMCRA 

permit boundary outside the Project Area. This would continue to disturb wildlife habitat in areas outside 

of the Project Area where mining continues. There would be some additional disturbance of reclaimed 

lands to support mine facilities in this portion of Trapper Mine. Overall, with disturbance continuing but in 

a slightly smaller area, the contribution to cumulative impacts to wildlife resources under Alternative B 

would be negligible. 

5.4.9 Special Status Species 

The CIAA for BLM and state sensitive species is the SMCRA permit boundary plus a one-mile radius 

around the disturbance areas. The CIAA for the federally listed yellow-billed cuckoo is the SMCRA 

permit boundary plus two miles (3.2 km) upstream and downstream of the Craig Station on the Yampa 

River. The CIAA for the federally listed Colorado River fish species is the topographic airshed boundary. 

Continued development of mining operations in the Project Area would contribute incrementally to other 

surface uses that occupy and adversely modify habitat for the special status species that occur. 

The duration of the cumulative impacts for special status species would last through the life-of-mine and 

Phase III bond release. The duration of cumulative impacts to the federally listed species, for which the 

Project would indirectly contribute to cumulative impacts during the life-of-mine, would continue past the 

life of mine and Phase III bond release though the life of the Craig Station. 

Overall, there would be a negligible to minor contribution to the short-term cumulative loss or degradation 

of habitat for the northern leopard frog, golden eagle, burrowing owl, ferruginous hawk, American 

peregrine falcon, Brewer’s sparrow, and Columbian sharp-tailed grouse. Following reclamation, the 

contribution to cumulative impacts from these activities would be at negligible levels. 

The Colorado River fish are of particular concern. Other activities that occur in the region would have the 

potential to result in water depletions, including other mining operations in the region. However, any 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-14 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 5.0 – Cumulative Impacts 

future depletion(s) would be subject to the RIPRAP and would be offset through funding of the RIPRAP 

program. Given the combination of BMPs and design features that would be implemented as 

requirements under Alternative A and other reasonably foreseeable actions in the CIAA, these actions 

would not be expected to appreciably change the current aquatic conditions in the Yampa River. 

Consultation with the USFWS under Section 7 of the ESA also has included several conservation 

measures designed to mitigate cumulative impacts to the Colorado River fish species and western 

yellow-billed cuckoo. 

Neither Alternative A nor B would be expected to directly contribute to cumulative impacts to the 

Colorado River fish species or western yellow-billed cuckoo through the life of the mine and Phase III 

bond release. However, indirect impacts from the combustion of Trapper Mine coal at the Craig Station 

would continue to release mercury and selenium as long as Trapper Mine coal is being combusted at the 

Craig Station. Some portion of this mercury is reasonably likely to end up in the Yampa River, which 

would contribute to cumulative impacts to the Colorado River fish and western yellow-billed cuckoo. It is 

reasonably foreseeable that combustion at the Craig Station would continue to occur if coal was not 

supplied by Trapper Mine. Therefore, while mining within or outside the Project Area would contribute to 

cumulative impacts to the Colorado River fish and western yellow-billed cuckoo from water depletions, 

mercury deposition would occur even if mining was eliminated in the Project Area as coal would be 

supplied from elsewhere. The level of cumulative impacts to these federally listed species is unknown 

due to the uncertainties related to the impacts described in Chapter 4.0. 

Mining and reclamation under Alternative B would conclude earlier and within a slightly smaller footprint 

in the Project Area than with Alternative A. However, mining would continue within the SMCRA permit 

boundary outside the Project Area. This would continue to disturb potential habitat in areas outside of the 

Project Area where mining continues. Consequently, mining in these areas could contribute to 

cumulative impacts for the golden eagle, Brewer’s sparrow, and Columbian sharp-tailed grouse where 

suitable native habitats are disturbed. It is unlikely or uncertain whether the burrowing owl, ferruginous 

hawk, American peregrine falcon, or northern leopard frog would be impacted due to the limited 

distribution or limited potential to occupy undisturbed parts of the remaining SMCRA permit area. There 

would be some additional disturbance of reclaimed lands to support mine facilities in this portion of 

Trapper Mine. Overall, with disturbance continuing but in a slightly smaller area, the contribution to 

cumulative impacts to BLM and State sensitive species would remain negligible. 

5.4.10 Cultural Resources 

The CIAA for cultural resources encompasses the full SMCRA permit boundary plus a 0.25-mile (0.4-km) 

buffer. The 0.25-mile buffer is included because sites found in this area, especially those for which 

setting is a key element of their NRHP eligibility, could be indirectly affected by mining and miningrelated activities. 

Most cultural resources tend to degrade over time due to natural processes, but many can survive 

relatively intact for many years depending on the extent of erosion and deposition. Modern human 

activity can exacerbate the damage that naturally occurs to cultural resources. Cumulative impacts to 

cultural resources can be broad and include past, present, and future activity within and adjacent to the 

SMCRA permit area. The CIAA has been historically used for livestock grazing and recreational activities 

such as hunting, in addition to mining. All of these activities could have resulted in sustained impacts to 

extant historic properties (i.e., NRHP-eligible cultural resources) within the CIAA. 

Continued use and/or development of the CIAA would have the potential to diminish the integrity of 

cultural resources directly through physical disturbance or indirectly through the degradation of the 

historic environmental setting. Increased use of the area also opens up areas that have not been 

previously disturbed or are more remote, which could increase the potential for collection or vandalism of 

cultural resources by mine employees and other visitors. 

Previous studies conducted between 1970 and 2013, identified 32 cultural resources (14 sites and 18 

IFs) outside the direct APE but within the SMCRA boundary plus a 0.25-mile (0.4-km) buffer. An 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-15 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 5.0 – Cumulative Impacts 

unknown number of these sites have likely been impacted by past mining activities based on the fact that 

6,895 acres have been disturbed by mining activities within the CIAA. On a beneficial note, further 

development outside previously surveyed areas would result in additional cultural resource studies. 

Assuming that established documentation requirements are followed, these new areas of development 

would be intensively surveyed, newly recorded or known cultural resources would be evaluated or reevaluated for NRHP eligibility, and effects to any historic properties (NRHP-eligible sites) and “needs 

data” site would be assessed. Impacts to adversely affected historic properties would be appropriately 

mitigated. The information gained from any new cultural resources studies would expand knowledge and 

understanding of the regional culture history. The potential impacts of Alternative A would be avoided 

through implementing design features and mitigation measures described in Section 4.11.3. Similar 

measures could be implemented for other types of federal undertakings and also would limit additional 

impacts to cultural resources. Because no impacts to NRHP-eligible or “needs data” cultural resources 

have occurred or are predicted under Alternative A, overall there would be no contribution to cumulative 

impacts to cultural resources during the life of the mine. 

Mining and reclamation under Alternative B would conclude sooner than Alternative A within the Project 

Area and disturb less area. Mining elsewhere in the CIAA could disturb known or unrecorded cultural 

resources. While sites may have been impacted by past mining activities, it is anticipated that cultural 

resource surveys and evaluation of identified sites would be conducted prior to development outside of 

previously surveyed areas in the SMCRA permit boundary that may be mined in the future. Therefore, 

the overall contribution to cumulative impacts to cultural resources under Alternative B would be similar 

to Alternative A. 

5.4.10.1 American Indian Concerns 

The CIAA for American Indian concerns is the SMCRA permit area plus a 0.25-mile (0.4-km) buffer. The 

Hopi Tribe and the Southern Ute Indian Tribe have indicated an interest in the rock art site, 5MF.948 

(Section 6.3). Neither Tribe has indicated any other concerns about cultural resources within the CIAA. If 

additional cultural resources are identified within areas proposed for mining, additional consultation will 

be initiated. Cumulative impacts to areas of American Indian concerns is anticipated to be negligible 

under either Alternative A or B. 

5.4.11 Socioeconomics 

The socioeconomic CIAA includes Moffat and Routt counties, as well as a portion of Rio Blanco County 

including the town of Meeker. There are several active coal mines in the CIAA, including the Colowyo 

Coal Mine and Foidel Creek Mine; there are several other coal mines that are inactive and undergoing 

reclamation. There also are numerous active oil and gas wells within the CIAA, as well as aggregate 

mining activity. Furthermore, both the Hayden and Craig stations and the Yampa Valley Regional Airport 

are within the CIAA. The socioeconomic impacts of Alternative A would contribute, in addition to these 

additional mining and energy development activities, to the direct and indirect support of industries that 

supply services to these industries. This direct and indirect support would further support employment 

across a range of industries, resulting in sustained local income and a continuation of local spending. 

Steady employment in these industries also would assist in sustaining school enrollment as well as the 

local housing market. These cumulative activities combined with the incremental input from Alternative A 

also would continue to contribute to the federal, state, and local tax base, which in turn would provide 

continued support to local services such as health care, education, and law enforcement. This local and 

state economic contribution would continue until 2025 when mining would substantially decrease. 

Overall, the socioeconomic benefits from Alternative A would result in a beneficial contribution to 

cumulative impacts through the life of the mine and reclamation. 

Under Alternative B, the socioeconomic impacts described above as well as under Alternative A, 

Section 4.12, would end within the Project Area in 2016. Mining in other areas within the SMCRA permit 

boundary could continue with appropriate approvals from regulatory authorities. The lack of mining within 

the Project Area would result in the estimated loss, based on 2010-2015 averages, of approximately 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-16 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 5.0 – Cumulative Impacts 

$174.5 million in gross wages and benefits, $5.8 million in Abandoned Mine Land fees, $7.2 million in 

severance tax, $55.4 million in royalties, and $12.0 million in property tax revenue over the proposed 

mining timeframe, although this would be partially offset by the potential for mining on private and state 

lands within the SMCRA permit boundary. Ultimately, mine revenue would cease at the end of 

reclamation activities. Any decreases as a result of a reduced mining rate or delay in moving into other 

areas would add to the socioeconomic impacts already caused by uncertain oil and gas prices, as well 

as the unclear future of the local ranching and agriculture industry and the Craig Station as proposed 

carbon emissions rules may be implemented (Jaffe 2015). Potential limitations on land use within 

Northwest Colorado Greater Sage-grouse breeding areas and habitat could further contribute to 

socioeconomic impacts, across a range of resources, including but not limited to oil and gas 

development and ranching and agriculture (Jaffe 2015). Under Alternative B, closure of the Project Area 

to future mining would contribute negative cumulative socioeconomic impacts at the state and local level, 

depending on the amount of coal reserves available in other areas. Negative impacts at the local level 

would be higher than at the state level. Overall, Alternative B would result in a beneficial contribution to 

cumulative socioeconomic impacts through the life of the mine and reclamation; however, there would be 

a reduction in the contribution to cumulative impacts as compared to the Alternative A as a result of the 

reduced life of the mine. This may be partially offset by potential mining on private and state lands within 

the SMCRA permit boundary. 

5.4.12 Visual Resources 

The CIAA for visual resources is the viewshed for the Trapper Mine Project Area. Due to topography, the 

mine is only visible from intermittent locations to the north and northeast; the Town of Craig, U.S. 

Highways 40, and SH 13 (north of Craig). Under Alternative A, the visual impact of the mine would 

contribute to the visual changes to the landscape along with other non-natural components of the 

environment. Incremental changes would be minimal, due in part to the fact that Trapper Mine has 

previously disturbed approximately 6,900 acres within the SMCRA permit boundary. Non-natural 

components that are located within the viewshed of the mine include the Craig Station to the northwest 

of the Project Area; the Town of Craig; U.S. Highway 40; SH 13; electric transmission lines; sand, gravel, 

and stone quarries; and oil and gas wells and infrastructure. Intermittent portions of the Yampa River to 

the east and west of Craig have views of the Trapper Mine, multiple quarries, and oil and gas 

development. 

Other regional non-natural components not located within the viewshed of the mine include the Colowyo 

Mine, approximately 20 miles (32 km) southwest of the Project Area; the Foidel Creek, Sage Creek, 

Yoast, and Seneca II-West mines approximately 15 to 20 miles (24 to 32 km) to the east of the Project 

Area; and the Hayden Station, Town of Hayden, cities of Steamboat Springs and Craig, Yampa Valley 

Airport, highways and roads, electric transmission lines, and oil and gas wells and facilities. 

The contribution to cumulative impacts under Alternative A would continue throughout the life of the mine 

and reclamation (up to 30 years) and contribute to the visual impacts within the CIAA until final 

reclamation is complete. Under Alternative B, Trapper would cease mining operations and begin 

reclamation activities on the Project Area, and the cumulative impact contribution of the project would be 

shorter in duration, by approximately 10 years. Final reclamation would leave no scars where the mining 

has occurred. This may not result in a noticeable reduction to cumulative impacts for an additional 3 to 

4 years as mining would continue within the SMCRA permit boundary. 

Overall, the contribution to cumulative visual impacts under both Alternative A and Alternative B would 

be negligible to minor and would cease following the completion of successful reclamation. 

5.4.13 Paleontological Resources 

The CIAA for paleontological resources is the SMCRA permit boundary. Mining under Alternative A 

could incrementally add to the potential impacts to paleontological resources in the CIAA. Other regional 

activities that may impact paleontological resources include future oil and gas development and 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-17 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 5.0 – Cumulative Impacts 

additional mining. Future ground disturbing activities associated with mining within the Project Area 

would be subject to paleontological protection measures. Given the small area disturbed relative to the 

existing disturbance in the CIAA and the overall large land area of the region, as well as the limited 

number of surface disturbing activities other than mining that may occur, Alternative A’s overall 

contribution to cumulative impacts would be negligible and would cease following the completion of 

mining. 

Mining under Alternative B would create less surface disturbance then under Alternative A. Overall, the 

contribution to cumulative impacts would be negligible and would cease following the completion of 

mining. 

5.4.14 Access and Transportation 

The CIAA for access and transportation includes Moffat and Routt counties and the eastern third of Rio 

Blanco County, including the Colowyo Mine and the town of Meeker. Primary transportation routes in the 

CIAA are U.S. Highway 40 and SHs 13, 131, 317, and 394. Commuter and supply traffic to and from the 

mine is the only contribution to cumulative traffic rates in the CIAA. Transportation of coal and CCRs 

uses mine roads and has no effect to the local transportation network. Continued mining would 

contribute to the tax revenue generated for Moffat County that helps support road maintenance. Other 

projects that contribute to both negative (road use) and positive (tax revenue) impacts to transportation 

within the CIAA include the Craig and Hayden stations, Colowyo and Foidel Creek coal mines, stone and 

material quarries, and oil and gas development. The Steamboat Springs Ski Resort and Dinosaur 

National Monument also contribute to traffic volumes in the CIAA through visitation. In 2012 the 

Steamboat Ski Resort had 89,598 visitors (Yampa Valley Data Partners 2012) and Dinosaur National 

Monument had 261,643 visitors (National Parks Service 2012). 

Implementation of Alternative A would not contribute any additional daily traffic to the transportation 

routes in the CIAA. Under Alternative B, mining would continue at Trapper Mine in areas outside of the 

Project Area; however, transportation and access impacts would be slightly reduced as compared to 

Alternative A due to the lower mining rate. Overall, the contribution to cumulative access and 

transportation impacts under both Alternative A and Alternative B would be negligible and would cease 

following the completion of mining and reclamation. 

5.4.15 Solid Waste 

The CIAA for solid waste is the SMCRA permit area plus the Moffat County landfill and the Hayden 

Station CCRs placement area. The Moffat County landfill is a municipal landfill located about two miles 

(3 km) south of Craig, Colorado, accessed by CR 107. Alternative A is not expected to change the 

amounts of non-hazardous solid waste that is disposed at the landfill. 

The Hayden Station is located in Sections 7, 8, 17, and 18 in Township 6 North, Range 87 West about 

21 miles (34 km) east of Project Area. The CCRs placement area is located south of the Hayden Station. 

The Hayden Station generated approximately 128,000 tons of CCRs in 2014 (U.S. Energy Information 

Agency 2015). Alternative A would not be expected to change the amount of CCR disposed by the 

Hayden Station. 

Section 4.16 discusses the CCRs placement in the SMCRA permit area from the Craig Station. 

Alternative A would not be expected to change the amount of CCRs placed in the Trapper Mine SMCRA 

permit area. 

Alternative B would result in a decrease in the amount of municipal solid waste that is disposed at the 

county landfill due to the decreased mining rate and earlier cessation of mining. Alternative B would have 

no effect on the generation or handling of CCRs because the Craig Station is expected to continue to 

operate at current rates. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-18 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 5.0 – Cumulative Impacts 

Overall, the contribution to cumulative solid waste impacts under both Alternative A and B would be 

negligible and would cease following the completion of reclamation. 

5.4.16 Noise 

The CIAA for noise is the Project Area and a 0.5-mile (0.8-km) buffer surrounding the Project Area. 

Noise sources related to mining include haul trucks, excavation and drilling equipment, pre-blast/postblast warning sirens, backup alarms on mobile equipment, and impulsive noises associated with 

infrequent blasting activities within the mine pit. Noise levels under Alternative A would remain consistent 

with current activities as production rates would remain the same. The majority of noise creating 

activities would occur within the mine pit area including loading trucks, excavation activities, and drilling 

and blasting below grade which would attenuate noise. Haul road traffic and reclamation work that occur 

at grade would likely produce the majority of noise traveling off site. The nearest sensitive receptor is a 

single residence 0.46 mile (0.7 km) north of the permit boundary. Topography around the permit 

boundary is hilly to the north and becomes mountainous to the south. These features provide noise 

attenuation, and it is likely that most noise is attenuated before reaching any residences or receptors; 

therefore, noise related impacts would be negligible. Overall, Alternative A, including future reclamation 

activities, would create no changes to the current contribution to cumulative noise impacts. The 

contribution to these impacts would cease following the completion of reclamation. 

Under Alternative B, mining activities within the Project Area would cease and reclamation activities 

would begin. Noise generated under Alternative B would include filling and recontouring of the mine pit 

areas, distribution of topsoil, and seeding. Noise duration for this alternative would be shorter than 

Alternative A, but mining would continue in areas outside of the Project Area. Noise associated with 

these activities would involve the same sources as Alternative A in other areas of the SMCRA Permit 

boundary. Overall, Alternative B would result in no changes to the current contribution to cumulative 

noise impacts; however, the contribution to cumulative impacts would be shorter in duration than under 

Alternative A due to the decreased life of mine. This may be partially offset by potential mining on private 

and state lands within the SMCRA permit boundary. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-19 
 

Chapter 5.0 – Cumulative Impacts 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

5-20 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 6.0 – Consultation and Coordination 

6.0 Consultation and Coordination1 

The following individuals or organizations were notified of the Project and their input was requested. 

These individuals or organizations also were notified of the release of the EA and asked to provide any 

comments on the document. 

• USFWS 

• Colorado SHPO 

• Eastern Shoshone Tribe 

• Ute Mountain Ute Tribe 

• Ute Indian Tribe 

• Southern Ute Tribe 

• Navajo Nation 

• Hopi Tribe 

• City of Craig 

• Town of Hayden 

• Landowners Adjacent to the SMCRA permit boundary 

• WildEarth Guardians 

6.1 Public Comment Process 

Public comments were solicited through several methods. OSMRE published legal notices in the Craig 

Daily Press on October 14 and 21, 2015, and the Rio Blanco Herald Times on October 22, 2015 

(Appendix A). The legal notice also was posted in public locations in Craig and Meeker. A public 

outreach letter describing the Project, announcing the public outreach meeting, and soliciting comments 

was mailed on October 16, to a total of 15 recipients, including city governments, adjacent landowners, 

and other interested parties. On October 27, 2015, a total of six letters were sent to American Indian 

tribes. The legal notices and letters invited the public to comment on issues of concern for the Project, 

and informed the interested citizens of the public outreach meeting. 

OSMRE developed a Project website, which provided additional Project notice, Project information, and 

comment opportunities: http://www.wrcc.osmre.gov/initiatives/trappermine.shtm. The website was 

activated on October 16, 2015. The website provided the legal notices, outreach notices letters, outreach 

meeting materials, mailing address, and an email address for comments to be sent. 

The public outreach meeting was held on October 29, 2015, from 4:00 PM until 8:00 PM at the Moffat 

County Fairgrounds, Pavilion Building, 640 Victory Way, Craig, Colorado 81625. Five hundred and one 

individuals signed in at the public meeting and 195 comment forms were completed during the meeting. 

A total of 4,578 individuals or organizations submitted comments by the end of the comment period. 

Ninety two comments were received after the comment period closed on November 12, 2015. Both 

comments received during the comment period and comments received after the comment period ended 

were evaluated for relevance in preparing this EA. 

1 Italicized text denotes language inserted either in response to comments received on the EA (see Appendix E) or to clarify or 

update a topic based on new or additional information received. Each place where italicized text appears is denoted by a bar in 

the left hand margin. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

6-1 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 6.0 – Consultation and Coordination 

Public comments included the following issues: 

•	 General support of the project; 

•	 Concerns over impacts to air quality and climate change; 

•	 Concerns over impacts to socioeconomics if the mine were to shut down; 

•	 Community support and environmental stewardship activities completed by TMI; and 

All comments received have been considered in the preparation of this document. A summary 

discussion of the issues raised during scoping is discussed in Section 1.6. 

OSMRE released the EA and unsigned FONSI for public comment on January 25, 2016. The public 

comment period ran through February 19, 2016. Notice that the documents were planned for release, 

along with the release date, was published in the Craig Daily Press on January 21, 2016, and in the 

Meeker Herald Times on January 20, 2016. Once the documents were released, legal notice of 

availability was published in the Craig Daily Press on January 28, 2016, and in the Meeker Herald 

Times on January 27, 2016. The legal notice also was placed in public locations in Craig and Meeker. 

Copies of the EA and unsigned FONSI were placed in the following locations for public review: 

•	 OSMRE, Western Region, 1999 Broadway, Suite 3320, Denver, CO 80202 

•	 Colorado Division of Reclamation, Mining and Safety, 1313 Sherman St, Room 215, Denver, 

CO 80203 

•	 Moffat County Building, 221 W. Victory Way, Suite 130, Craig, CO 81625 

•	 Moffat County Library, 570 Green Street, Craig, CO 81625 

•	 Bureau of Land Management, Little Snake Field Office, 455 Emerson Street, Craig, CO 81625 

•	 Bureau of Land Management, White River Field Office, 220 East Market Street, Meeker, CO 

81641 

•	 Rio Blanco County Courthouse, 555 Main Street, Meeker, CO 81641 

•	 Meeker Public Library, 409 Main Street, Meeker, CO 81641 

•	 Rangely Public Library, 109 E. Main Street, Rangely, CO 81648 

Approximately 202 Notice of Availability letters were sent directly to those who requested notification of 

the release of the EA during the public scoping period. Fifty-eight electronic DVD copies of the EA and 

unsigned FONSI were sent to adjacent landowners, nearby community leaders and other interested 

individuals. During the comment period a number of DVDs were returned for incorrect postage. As a 

result, OSMRE re-mailed all 58 DVDs and extended the comment period for the addressees through 

March 4, 2016. 

Comments were accepted via mail and email. A total of 1,148 comment letters or emails were 

received. Revisions were made to the EA, as appropriate, and responses to comments prepared as 

part of the MPDD. The comment and response document is provided as Appendix E. 

U.S. Fish and Wildlife Service Section 7 Consultation 

On November 16, 2015, OSMRE reinitiated the Section 7 consultation process with USFWS when a 

draft BA was submitted. The BA requested to reinitiate the consultation process due to the indirect 

effects of mercury and selenium deposition on listed species. The final BA was submitted on 

December 9, 2015. A BO was issued by the USFWS on March 22, 2016, and is included in Appendix C. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

6.2 

6-2 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 6.0 – Consultation and Coordination 

6.3 American Indian Consultation 

On October 27, 2015, OSMRE sent a letter to the following tribes explaining the project and requesting 

consultation under Section 106 of the NHPA (Appendix D). 

• Eastern Shoshone Tribe 

• Southern Ute Indian Tribe 

• Ute Mountain Ute Tribe 

• Ute Indian Tribe 

• Navajo Nation 

• Hopi Tribe. 

The Hopi Tribe requested additional information on the Project by letter dated November 23, 2015. On 

January 25, 2016, OSMRE sent a letter and a hard copy of the EA and unsigned FONSI to each of the 

tribes explaining that the comment period would run through February 22, 2016. The Hopi Tribe 

responded to the information provided on February 8and indicated that any concerns regarding the 

project had been adequately addressed. However, on February 9, 2015, OSMRE sent the Hopi Tribe a 

letter and a report entitled: Class III Cultural Resources Inventory of a Lease Modification Area 

(758 Acres in 2 Block) in Moffat County, Colorado for Trapper Mining Inc. The Hopi Tribe responded in a 

letter dated February 22, 2016, stating that they reviewed the report and recommending that if prehistoric 

Fremont cultural resources are identified that could be affected by future project activities, additional 

consultation be initiated for avoidance or treatment for those locations. 

The Southern Ute Indian Tribe responded by letter on March 4, 2016 indicating a potential concern with 

mining activities in the Project Area, however no specific information was given as to their concerns. 

Through a letter, OSMRE responded on April 13, 2016. 

6.4 Cooperating Agencies 

The following is a list of Cooperating Agencies for the preparation of this EA: 

• BLM 

• Colorado DNR, including the Executive Director’s Office, CDRMS, CPW, and CSLB 

• CDPHE, APCD 

• Moffat County Commissioners 

• Rio Blanco County 

Table 6-1 lists the participants in the preparation of this EA from the Cooperating Agencies. 

Table 6-1 Participants from Cooperating Agencies 

Name Agency Title 

Kathy McKinstry BLM LSFO Planning and Environmental Coordinator 

Jennifer Maiolo BLM LSFO Mining Engineer 

Desa Ausmus BLM LSFO Wildlife Biologist 

Chad Meister BLM Colorado State Office Natural Resource Specialist (Air Quality) 

Amy Laughlin Colorado DNR Policy Advisor 

Dan Hernandez CDRMS Senior Environmental Protection Specialist 

Phillip Courtney CSLB Solid Minerals Leasing Manager 

Michael Warren CPW Energy Liaison, Northwest Region 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

6-3 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 6.0 – Consultation and Coordination 

Table 6-1 Participants from Cooperating Agencies 

Name Agency Title 

Ingrid Hewitson CDPHE APCD Air Quality Planner 

Chuck Grobe Moffat County County Commissioner 

Jeff Comstock Moffat County Director, Natural Resources Department 

Mark Sprague Rio Blanco County Natural Resource Specialist 

6.5 Preparers 

Table 6-2 shows a list of those who participated in the preparation of this EA from OSMRE.
	

Table 6-2 Office of Surface Mining Reclamation and Enforcement 

Name Title 

Robert Postle Manager, Program Support Division 

Marcelo Calle Manager, Field Operations Branch 

Nicole Caveny Environmental Protection Specialist 

Roberta Martinez-Hernandez Civil Engineer 

Gene Hay Mining Engineer 

Jeremy Iliff Archeologist 

Jacob Mullinix Soils Scientist 

Table 6-3 shows a list of the key preparers of this EA from the third party consultants, AECOM and Air 

Resource Specialists. 

Table 6-3 Consultants 

Name Title Resource/Role 

Bill Killam, AECOM Senior Project Manager Senior NEPA Reviewer 

Anne Baldrige, AECOM Senior Project Manager Project Manager 

Eve Bingham, AECOM Senior Project Manager Assistant Project Manager 

Bill Berg, AECOM Senior Geologist Geology, Paleontology, Solid Waste 

Sue Coughenour, AECOM Document Production Specialist Technical Editor 

Rob DeBaca, AECOM Senior Biologist Vegetation, Wildlife, Special Status 

Species 

Chris Dunne, AECOM Project Ecologist Recreation, Visual Resources, 

Livestock Grazing, Alluvial Valley 

Floors, Prime Farmland 

Steve Graber, AECOM Human Resource Specialist Socioeconomics, Environmental 

Justice 

Meagan Jones, AECOM Environmental Scientist Soils, Wetlands, Noise 

Matt Spansky, AECOM Project Hydrogeologist Water Resources 

Gordy Tucker, AECOM Cultural Resources Team Lead Cultural Resources 

Howard Gebhart, Air Resource 

Specialists 

Senior Project Scientist Air Quality and Climate Change 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

6-4 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

7.0 References 

Chapter 1.0 References 

Bureau of Land Management (BLM). 2015. Northwest Colorado Greater Sage-Grouse Approved 

Resource Management Plan, Attachment 3 from the Record of Decision and Approved 

Resource Management Plan Amendments for the Rocky Mountain Region Greater SageGrouse Sub-Regions of Lewistown, North Dakota, Northwest Colorado, and Wyoming, and 

the Approved RMPs for Billings, Buffalo, Cody, HiLine, Miles City, Pompeys Pillar National 

Monument, South Dakota, and Worland. September 2015. 

Bureau of Land Management (BLM). 2011. Record of Decision and Approved Resource Management 

Plan for the Little Snake Field Office. October 2011. 

Bureau of Land Management (BLM). 1989. Craig District, Colorado, Little Snake Resource Area 

Resource Management Plan and Record of Decision, June 1989. 

Bureau of Land Management (BLM). 1982. Environmental Assessment Coal Lease Readjustment 

C-079641 and Decision Record/Rationale. EA-CO-016-82-50. Signed September 28, 1982. 

Bureau of Land Management (BLM). 1980. Green River-Hams Fork Regional Coal Environmental 

Impact Statement. February 29, 1980. 

Bureau of Land Management (BLM). 1979. Nominal Environmental Assessment Record, 

Readjustment of Least (sic) Terms, Utah International Incorporated Federal Coal Lease 

C-07519. Signed February 12, 1979. 

Office of Surface Mining Reclamation and Enforcement (OSMRE). 1989. Handbook on Procedures for 

Implementing the National Environmental Policy Act of 1969. March 1989. 

U.S. District Court for the District of Colorado (D. Colo). 2015. Judge R. Brooke Jackson, Civil Action 

No 13-cv-00518-RBJ, WildEarth Guardians, plaintiff v. United States Office of Surface Mining 

Reclamation and Enforcement et al., 104 F. Supp.3d 1208. May 8, 2015. 

Chapter 2.0 References 

Colorado Division of Reclamation, Mining, and Safety (CDRMS). 1980. Regulations of the Colorado 

Mined Land Reclamation Board for Coal Mining. Most Recently Revised September 14, 2005. 

U.S. District Court for the District of Colorado (the District Court). 2015. Judge R. Brooke Jackson, 

Civil Action No 13-cv-00518-RBJ, WildEarth Guardians, plaintiff v. United States Office of 

Surface Mining Reclamation and Enforcement et al., 104 F. Supp.3d 1208. May 8, 2015. 

Hinkemeyer, S. 2015. Personal Communication with A. Baldrige, AECOM, November 12, 2015. 

Trapper Mining Inc. (TMI). 2016. 2015 Payroll and AP Spending, transmitted January 14, 2016. 

Trapper Mining Inc. (TMI). 2015. Coal Quality and Tons by Pit, transmitted September 21, 2005. 

Trapper Mining Inc. (TMI). 1981 et seq. An Application for a Permit to Conduct Coal Surface Mining 

and Reclamation Activities at the Trapper Mine in Moffat County, Colorado. C-81-010. 

Submitted January 1981, last updated October 2015. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-1 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

3.1 General Setting 

None 

3.2 Topography 

None. 

3.3 Air 

Colorado Department of Public Health and Environment (CDPHE). 2014. Colorado Visibility and 

Regional Haze State Implementation Plan for the Twelve Mandatory Class I Federal Areas in 

Colorado. Revisions approved by the Colorado Air Quality Control Commission on November 

20, 2014. 

Bureau of Land Management (BLM). 2006. Environmental Assessment for Lease-By-Application 

Collom Lease Tract COC-68590. Bureau of Land Management, Craig, Colorado. August 1, 

2006. 

Office of Surface Mining Reclamation and Enforcement (OSMRE). 2015. Colowyo Coal Mine, South 

Taylor/Lower Wilson Permit Expansion Area Project, Federal Mining Plan Modification 

Environmental Assessment. Issued August 2015. 

U.S. Environmental Protection Agency (USEPA). 2015. Inventory of US Greenhouse Gas Emissions 

and Sinks: 1990-2013. US Environmental Protection Agency, Washington, DC, EPA 430-R15-004, April 15, 2015. 

U.S. Environmental Protection Agency (USEPA). 2012. National Emission Standards for Hazardous 

Air Pollutants from Coal- and Oil-Fired Electric Utility Steam Generating Units and Standards 

of Performance for Fossil-Fuel-Fired Electric Utility, Industrial-Commercial-Institutional and 

Small Industrial-Commercial-Institutional Steam Generating Units: Final Rule. Federal 

Register, February 16, 2012. 

3.4 Geology References 

Brownfield, M. E. and E. A. Johnson. 2008. The Yampa Bed - A Regionally Extensive Tonstein in the 

Williams Fork Formation, Northwestern Piceance Creek and Southern Sand Wash Basins, 

Colorado. U.S. Geological Survey Scientific Investigations Report 2008-5033. 

Buchsbaum, L. 2011. A Landslide Victory: Coal Age News. Internet website: http://www.coalage.com/ 

features/1088-a-landslide-victory.html#.VgrOIrHnapo. Accessed September 29, 2015. 

Carroll, C. J. 2004. Summary of Coal Resources in Colorado 2003. Colorado Geological Survey 

Special Publication 54. 

Colorado Division of Reclamation Mining and Safety (CDRMS). 2015. Colorado Coal Production, 2001 

through 2015. Internet website: http://mining.state.co.us/Reports/Reports/Pages/Coal.aspx. 

Colorado Division of Reclamation, Mining and Safety (CDRMS). 2013. Proposed Decision and 

Findings of Compliance for the Trapper Mine, Permit C-081-010, Permit Renewal RN-06, 

July 9, 2013. 

Colorado Mining Association. 2015. Trapper Mining Inc. Internet website: 

https://www.coloradomining.org/project/trapper-mining-inc/. Accessed September 29, 2015. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-2 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

Colorado Oil and Gas Conservation Commission (COGCC). 2015. Online Production Data, Flume 

Gulch Field, Moffat County, Colorado. Internet website: http://cogcc.state.co.us/ 

data.html#/cogis. Accessed September 29, 2015. 

Guilinger, J. R. and J. W. Keller. 2002. Directory of Active and Permitted Mines in Colorado 2002. 

Colorado Geological Survey Information Series 68. 

Horn, G. H and E. E. Richardson. 1959. Geologic and Structure Map of the Williams Fork Mountains 

Coal Field, Moffat County, Colorado. U.S. Geological Survey Open-File Report 59-65. 

Johnson, E. A. 1987. Geologic Map and Coal Sections of the Round Bottom Quadrangle, Moffat 

County, Colorado. U.S. Geological Survey Coal Investigations Map C-108, scale 1:24,000. 

Johnson, E. A., L. N. R. Roberts, M. E. Brownfield, and T. J. Mercier. 2000. Geology and Resource 

Assessment of the Middle and Upper Coal Groups in the Yampa Coal Field, Northwestern 

Colorado in Kirschbaum, M.A. L.N.R. Roberts, and L.R.H. Biewick (editors), Geologic 

Assessment of Coal in the Colorado Plateau: Arizona, Colorado, New Mexico, and Utah, 

Chapter P, U.S. Geological Survey Professional Paper 1625–B. 

Madole, R. F. 1989. Surficial geologic map of the Meeker 30' x 60' quadrangle, Garfield, Moffat, Rio 

Blanco and Routt Counties, Colorado. US Geological Survey Miscellaneous Investigations 

Series Map Map I-1823, scale 1:100,000. 

Petersen, M. D., M. P. Moschetti, P. M. Powers, C. S. Mueller, K. M. Haller, A. D. Frankel, Y. Zeng, 

S. Rezaeian, S. C. Harmsen, O. S. Boyd, E. H. Field, R. Chen, N. Luco, R. L. Wheeler, R. A. 

Williams, A. H. Olsen, and K. S. Rukstales. 2015. Seismic-hazard Maps for the Conterminous 

United States, 2014: U.S. Geological Survey Scientific Investigations Map 3325, Sheet 2, 

Peak Horizontal Acceleration with 2 Percent Probability of Exceedance in 50 Years, 

scale 1:7,000,000. 

Trapper Mining Inc. (TMI). 2015. Powerpoint Presentation Given to Colorado Air Quality Control 

Commission, June 19, 2015, Slide 34. 

Trapper Mining Inc. (TMI). 1981 et seq. An Application for a Permit to Conduct Coal Surface Mining 

and Reclamation Activities at the Trapper Mine in Moffat County, Colorado. C-81-010. 

Submitted January 1981, last updated October 2015. 

Tweto, O. 1976. Geologic Map of the Craig 1 degree X 2 degree Quadrangle, Northwestern Colorado. 

U.S. Geological Survey Miscellaneous Investigations Series Map I-972. 

U.S. Geological Survey (USGS). 2015. Earthquake Search. Internet website: 

http://earthquake.usgs.gov/earthquakes/search/. Accessed September 29, 2015. 

U.S. Geological Survey and Colorado Geological Survey. 2006. Quaternary Fault and Fold Database 

for the United States. Internet website: http://earthquake.usgs.gov/hazards/qfaults/. Accessed 

January 18, 2016. 

3.5 Water Resources References 

AECOM. 2015. Trapper Mine SMCRA Permit Area Annual Runoff Contribution to the Yampa and 

Williams Fork Rivers. 

Colorado Department of Public Health and Environment (CDPHE). 2015. Classification and Numeric 

Standards for Lower Colorado River Basin. 5 CCR 1002-37, Regulation No. 37. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-3 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

Colorado Department of Public Health and Environment (CDPHE). 2012. Colorado’s Section 303(d) 

List of Impaired Waters and Monitoring and Evaluation List. 5 CCR 1002-93, Regulation 

No. 93. 

Colorado Division of Water Resources (CDWR). 2015. Map Viewer (CDSS). On-line resource 

available at: http://water.state.co.us/DataMaps/GISandMaps/MapViewer/Pages/FAQ.aspx. 

Environmental Sciences Laboratory. 2011. Natural Contamination from the Mancos Shale. ESL-RPT2011-01. Prepared for U.S. Department of Energy. 

Hydro-Engineering, LLC. 2015. 2014 Annual Hydrologic Report for Trapper Mine, 

Maura, W. S. 1982. Water-Quality Data for Streams in the Southern Yampa River Basin, Northwestern 

Colorado. U.S. Geological Survey Open-File Report 82-1017. 

Robson, S. G. and M. Stewart. 1990. Geohydrologic Evaluation of the Upper Part of the Mesaverde 

Group, Northwestern Colorado. U.S. Geological Survey, Water-Resources Investigations 

Report 90-4020. 

Steele, T. D., D. P. Bauer, D. A. Wentz, and J. W. Warner. 1979. The Yampa River Basin, Colorado 

and Wyoming—A Preview to Expanded Coal-Resource Development and Its Impacts on 

Regional Water Resources. U.S. Geological Survey, Water-Resources Investigations 78 126. 

Trapper Mining Inc. (TMI). 1981 et seq. An Application for a Permit to Conduct Coal Surface Mining 

and Reclamation Activities at the Trapper Mine in Moffat County, Colorado. C-81-010. 

Submitted January 1981, last updated October 2015. 

Tweto, O. 1976. Geologic Map of the Craig 1° x 2° Quadrangle, Northwestern Colorado. U.S 

Geological Survey, Miscellaneous Investigations Series Map I-972, 1:250,000 scale. 

U.S. Geological Survey (USGS). 2015. USGS Surface-Water Data for Colorado. On-line resource 

available at: http://waterdata.usgs.gov/co/nwis/sw. Accessed September 30, 2015. 

3.6 Soils 

Crofts, K., 2015. Personnel communication with A. Baldrige, AECOM. November 9, 2015. 

U.S. Department of Agriculture (USDA). 2015. Soil Survey Geographic Database. Accessed at 

http://www.nrcs.usda.gov/wps/portal/nrcs/detail/soils/survey/geo ?cid=nrcs142p2_053627. 

U.S. Department of Agriculture (USDA). 2006. Land Resource Regions and Major Land Resource 

Areas of the United States, the Caribbean, and the Pacific Basin, USDA Handbook 296. 

U. S. Department of Agriculture (USDA). Natural Resource Conservation Service (NRCS). 2005. Soil 

Survey of Moffat County Area, Colorado. 

U.S. Department of Agriculture (USDA). Natural Resource Conservation Service (NRCS). 1989. Soil 

Survey of Moffat County Area, Colorado. 

3.7 Vegetation 

Colorado Division of Reclamation Mining and Safety (CDRMS). 1995. Guideline Regarding Selected 

Coal Mine Bond Release Issues, April 18, 1995. 

Moffat County. 2001. Land Use Plan, Amended September 2001. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-4 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

Trapper Mining Inc. (TMI). 2015. Trapper Mine (Permit No. C-81-010) Technical Revision TR-114 

2014 Annual Report, Submitted March 10, 2015. 

3.8 Wetlands 

IME Consulting (IME). 2008. Wetland Delineation Report for the Horse Gulch Wetland Polygon Z, 

Near Craig, Moffat County, Colorado. August 29, 2008. 

IME Consulting (IME). 1998. Trapper Mine – 1998 Topsoil Stripping/Wetland Delineation Study. June 

1998. 

National Wetlands Inventory. Accessed at http://wetlandslb-557172182.us-east1.elb.amazonaws.com/WetlandsMap/WetlandsMapper. Accessed February 4, 2016. 

U.S. Army Corps of Engineers. 2010. Regional Supplement to the Corps of Engineers Wetlands 

Delineation Manual: Western Mountains, Valleys, and Coast Regions (version 2.0). ERDC/EL 

TR-10-3. May 2010. 

U.S. Army Corps of Engineers. 1987. Corps of Engineers Wetlands Delineation Manual, Wetlands 

Research Program technical Report Y-87-1. January 1987. 

3.9 Wildlife References 

Armstrong, D. M., J. P. Fitzgerald, and C. A. Meany. 2011. Mammals of Colorado. 2nd Edition. The 

University Press of Colorado. Boulder, Colorado. 620 pp. 

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, Wyoming. 

Colorado Parks and Wildlife (CPW). 2015-2016. Big Game Hunt Guide. Northwestern and 

Southwestern Regions. Internet website: 

http://cpw.state.co.us/thingstodo/Pages/BigGameHuntGuides.aspx. Date accessed: 

December 27, 2015. 

Colorado Parks and Wildlife (CPW). 2015a. Herd Management – DAU Plans. Internet website: 

http://cpw.state.co.us/thingstodo/Pages/HerdManagementPlans.aspx. Accessed October 15, 

2015. 

Colorado Parks and Wildlife (CPW). 2015b. Big Game Hunting Statistics. Retrieved from 

http://cpw.state.co.us/thingstodo/Pages/Statistics.aspx. Various dates. 

Colorado Parks and Wildlife (CPW). 2014a. Colorado Department of Natural Resources species range 

data. Updated December 2014, available at: https://gisftp02.state.co.us/. 

Colorado Parks and Wildlife (CPW). 2014b. Moose. Internet website: 

http://cpw.state.co.us/learn/Pages/SpeciesProfiles.aspx?species=moose. Date accessed: 

December 28, 2015. 

Colorado Parks and Wildlife (CPW). 2014c. Moose Reintroduction Program - Grand Mesa. Internet 

website: http://cpw.state.co.us/learn/Pages/MooseReintroductionProgram.aspx. Date 

accessed: December 28, 2015. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-5 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

Colorado Parks and Wildlife (CPW). 2012a. Elk. Internet website: 

http://wildlife.state.co.us/WildlifeSpecies/Profiles/Mammals/Pages/Elk.aspx. Last updated 

November 6. Date accessed: December 5, 2015. 

Colorado Parks and Wildlife (CPW). 2012b. Mammal Management. Internet website: 

http://wildlife.state.co.us/WildlifeSpecies/Profiles/Mammals/Pages/MammalManagement.aspx. 

Last updated November 6. Date accessed: December 5, 2015. 

Colorado Parks and Wildlife (CPW formerly CDOW). 2010. Yampa River basin aquatic wildlife 

management plan. Aquatic Wildlife Section, Denver, Colorado, 117pp. 

Johnson, B. H., P. J. Martinez, J. A. Hawkins, and K. R. Bestgen. 2008. Ranking predatory threats by 

nonnative fishes in the Yampa River, Colorado, via bioenergetics modeling. North American 

Journal of Fisheries Management, 28:1941-1953. 

Kingery, H. E. (Ed.).1998.Colorado Breeding Bird Atlas. Colorado Bird Atlas Partnership and the 

Colorado Division of Wildlife. Denver, Colorado. 

Prior-Magee, J. S., K. G. Boykin, D. F. Bradford, W. G. Kepner, J. H. Lowry, D. L. Schrupp, K. A. 

Thomas, and B. C. Thompson, Editors. 2007. Ecoregional Gap Analysis of the Southwestern 

United States. The Southwest 35 Regional Gap Analysis Project (SWReGAP) Final Report. 

December. 

Stokes, D. W. and L. Q. Stokes. 1996. Field Guide to Birds: Western Region. Little, Brown, and 

Company. 

Trapper Mining Inc. (TMI). 2015. Historic Prairie Falcon Nest Site Survey At The Southeast Corner Of 

Trapper’s Permit Boundary Near Hamill Property. 2001-2015. 

Trapper Mining Inc. (TMI). 1981 et seq. An Application for a Permit to Conduct Coal Surface Mining 

and Reclamation Activities at the Trapper Mine in Moffat County, Colorado. C-81-010. 

Submitted January 1981, last updated October 2015. 

3.10 Special Status Species 

Andrews, R. A. and R. Righter. 1992. Colorado Birds. Denver Museum of Natural History. Denver, 

Colorado, pp 167. 

Beason, J. P. 2012. 2011 Surveys for Yellow-billed Cuckoos in Western Colorado. Tech Rep. RYBCU-USFWS-09-3. Rocky Mountain Bird Observatory, Brighton, Colorado. 30 pp. 

Bennett, J. and D. A. Keinath. 2003. Species Assessment for Yellow-billed Cuckoo (Coccyzus 

americanus) in Wyoming. Prepared by Bureau of Land Management, Wyoming State Office, 

Cheyenne, Wyoming. University of Wyoming, Laramie, Wyoming. December. 

Bestgen, K. R., J. A. Hawkins, G. C. White, C. D. Walford, P. Badame, and L. Monroe. 2010. 

Population Status of Colorado Pikeminnow in the Green River Basin, Utah and Colorado, 

2006-2008. Final Report of the Larval Fish Laboratory, Colorado State University to the Upper 

Colorado River Endangered Fish Recovery Program, Denver, Colorado. 

Bureau of Land Management (BLM). 2015. List of BLM Special Status Species updated in 2015.E-mail 

from Desa Ausmus BLM LSFOP to Anne Baldrige dated November 9, 2015. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-6 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

Bureau of Land Management (BLM). 2012. Draft Resource Management Plan Amendment and 

Environmental Impact Statement for Oil and Gas Development. BLM, White River Field Office, 

Colorado. 

Colorado Natural Heritage Program (CNHP). 2015. Species Tracking List. Retrieved from 

http://www.cnhp.colostate.edu/download/list.asp. 

Dexter, C. 1998. River survey of west-central Colorado, for yellow billed cuckoo and riparian weeds. 

Report prepared for the Bureau of Land Management. 26 pp. 

Halterman, M. D., M. J. Johnson, J. A. Holmes, and S. A. Laymon. 2015. A Natural History Summary 

and Survey Protocol for the Western Distinct Population Segment of the Yellow-billed Cuckoo: 

U.S. Fish and Wildlife Techniques and Methods, 45 pp. 

Hammerson. 1986. Amphibians and reptiles of Colorado. Colorado Division of Wildlife, Denver, 

Colorado, 131pp. 

Holden, P. B. and C. B. Stalnaker. 1970. Systematic Studies of the Cyprinid Genus Gila in the Upper 

Colorado River Basin. Copeia 1970(3):409-420. 

Kaeding, L. R., B. D. Burdick, P. A. Schrader, and C. W. McAda. 1990. Temporal and Spatial 

Relations between the Spawning of Humpback Chub and Roundtail Chub in the Upper 

Colorado River. Transactions of the American Fisheries Society, 119:135-144. 

Keading, L. R., B. D. Burdick, P. A. Schrader, and W. R. Noonan. 1986. Recent capture of a bonytail 

(Gila elegans) and observations on this nearly extinct cyprinid from the Colorado River. 

Copeia 1986:1021-1023. 

Kingery, H. E. (editor). 1998. Colorado Breeding Bird Atlas. Colorado Bird Partnership, and Colorado 

Division of Wildlife, 637pp. 

Lower Colorado Multi-Species Conservation Program. 2014. Bonytail (Gila elegans). Available at: 

http://www.lcrmscp.gov/fish/bony_chub.html; updated on December 15, 2014; accessed 

November 5, 2015. 

Maddux, H. R., L. A. Fitzpatrick, and W. R. Noonan. 1993. Colorado River endangered fishes critical 

habitat-draft biological support document. USFWS, Utah/Colorado Field Office, Salt Lake City, 

Utah. pp. 225. 

Marks, R. 2007. Sharp-tailed grouse (Tympanuchus phasianellus): Fish and wildlife habitat 

management leafelet. Natural Resources Conservation Service and Wildlife Habitat Council, 

Number 40:14pp. 

Office of Surface Mining Reclamation and Enforcement (OSMRE). 2015. Reinitiation of Consultation 

for the Trapper Mining Inc., Trapper Mine, Mining Plan Modification . Issued December 2015. 

Travsky, A. and G. P. Beauvais. 2005. Species assessment for the ferruginous hawk (Buteo regalis) in 

Wyoming: Cheyenne, Wyoming. Report prepared for Bureau of Land Management Wyoming 

State Office, 39 pp., at http://www.blm.gov/pgdata/etc/medialib/blm/wy/wildlife/animalassessmnts.Par.1082.File.dat/FerruginousHawk.pdf. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-7 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

U.S. Fish and Wildlife Service (USFWS). 2015a. List of threatened and endangered species that May 

occur in your proposed project location, and/or may be affected by your proposed project. 

Consultation Code: 06E24100-2015-SLI-0270; Event Code: 06E24100-2015-E-00585, 

Western Colorado Ecological Services Field Office, Grand Junction, 7 pp. 

U.S. Fish and Wildlife Service (USFWS). 2015b. Humpback chub (Gila cypha) species profile. ECOS 

data services, available at: 

http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=E000. Accessed 

September 16, 2015. 

U.S. Fish and Wildlife Service (USFWS). 2015c. Reinitiation of Consultation for the Colowyo Coal 

Company, L.P. “Colowyo” Mine, Permit C-81-019 – South Taylor/Lower Wilson Mining Area, 

Permit Revision PR-02. August 24, 2015. 

U.S. Fish and Wildlife Service (USFWS). 2014a. 2013-2014 Assessment of sufficient progress under 

the Upper Colorado River Endangered Fish Recovery Program in the Upper Colorado River 

Basin, and of implementation of action items in the January 10, 2005, Final Programmatic 

Biological Opinion on the Management Plan for Endangered Fished in the Yampa River Basin. 

Mountain Prairie Region, Lakewood, Colorado, September 10, 2014, 41pp. 

U.S. Fish and Wildlife Service (USFWS). 2014b. Species Fact Sheet, Yellow-Billed Cuckoo (Coccyzus 

americanus). Arizona Ecological Services, http://www.fws.gov/southwest/es/arizona/ 

Documents/SpeciesDocs/YellowBilledCuckoo/WYBC-factsheet-southwestlearning.pdf. 

Accessed September 20, 2015. 

U.S. Fish and Wildlife Service (USFWS). 2014c. Endangered and Threatened Wildlife and Plants; 

Determination of Threatened Status for the Western Distinct Population Segment of the 

Yellow-billed Cuckoo (Coccyzus americanus); Final Rule. Federal Register Vol. 79. No. 192. 

October 3, 2014. 

U.S. Fish and Wildlife Service (USFWS). 2011. U.S. Fish and Wildlife Service species assessment 

and listing priority assignment form: Coccyzus americanus. Region 8, California/Nevada 

Region, 41 pp. 

U.S. Fish and Wildlife Service (USFWS). 2008. Programmatic Biological Opinion for Water Depletions 

Associated with BLM’s Fluid Minerals Program within the Upper Colorado River Basin in 

Colorado. USFWS, Ecological Services, Grand Junction, Colorado. December 19, 2014. 

U.S. Fish and Wildlife Service (USFWS). 2002a. Bonytail Chub (Gila elegans) Recovery Goals: 

Amendment and Supplement to the Bonytail Chub Recovery Plan. USFWS, Rocky MountainPrairie Region, Denver, Colorado. August 1, 2002. 

U.S. Fish and Wildlife Service (USFWS). 2002b. Colorado Pikeminnow (Ptychocheilus lucius) 

Recovery Goals: Amendment and Supplement to the Colorado Squawfish Recovery Plan. 

USFWS, Mountain Prairie Region 6, Denver, Colorado. August 28, 2002. 

U.S. Fish and Wildlife Service (USFWS). 2002c. Humpback Chub (Gila cypha) Recovery Goals: 

Amendment and Supplement to the Humpback Chub Recovery Plan. USFWS, Rocky 

Mountain-Prairie Region, Denver, Colorado. August 1, 2002. 

U.S. Fish and Wildlife Service (USFWS). 2002d. Razorback Sucker (Xyrauchen texanus) Recovery 

Goals: Amendment and Supplement to the Razorback Sucker Recovery Plan. USFWS, 

Mountain Prairie Region 6, Denver, Colorado. August 1, 2002. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-8 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

Vanicek, C. D. 1967. Ecological Studies of Native Green River Fishes Below Flaming Gorge Dam, 

1964–1966. Unpublished PhD dissertation, Utah State University, Logan, Utah. 

Wickersham, L (project manager). 2015. Colorado Breeding Bird Atlas II (in press), The Colorado Bird 

Atlas Partnership. Data accessed online at: http://www.cobreedingbirdatlasii.org/index.asp. 

May 13, 2013. 

3.11 Cultural Resources References 

Athearn, F. J. 1982. An Isolated Empire: A History of Northwestern Colorado. BLM Cultural Resources 

Series 2, Denver. 

Arthur et al. 1981. Arthur, Christopher S., Jeffrey L. Brower, Susan M. Collins, J. Earl Ingmanson, 

Calvin H. Jennings, George J. Krause, and Laura M. Viola. 1981. Archaeological 

Investigations Along the Colowyo Coal Company Railroad Spur in Moffat County, Colorado. 

Report of the Laboratory of Public Archaeology No. 52. Colorado State University, Fort 

Collins. 

Colorado State Historic Preservation Office (SHPO). 2015. Archaeological Isolated Find/Feature Form 

Instructions. Electronic document, http://www.historycolorado.org/oahp/survey-inventoryforms, accessed October 19, 2015. 

Grady, J. 1984. Northwest Colorado Prehistoric Context. Colorado Historical Society, Denver. 

King, T. F. 1998. Cultural Resources Laws & Practice: An Introductory Guide. AltaMira Press, Walnut 

Creek, California. 

Lischka, J. 1975. W.R. Grace & Company Railroad Corridors and Colowyo Mine Site. University of 

Colorado, Boulder. 

Mehls, S. and C. Mehls. 1991. Coal Mining Survey in Routt and Moffat Counties, 1990-1991. Western 

Historical Studies, Inc., Louisville, Colorado. 

National Historic Preservation Act of 1966, as Amended (NHPA). 2015. Electronic document, 

http://www.achp.gov/nhpa.html. Accessed September 25, 2015. 

Reed, A. D. and M. D. Metcalf. 1999. Colorado Prehistory: A Context for the Northern Colorado River 

Basin. Colorado Council of Professional Archaeologists, Denver. 

Sherman et al. 1999. Sherman, Stephen A. Tania R. Metcalf, Mary W. Painter, D. Chadwick Jones, 

and Christian J. Zier. 1999. A Cultural Resources Survey of Interstates 25, 70, 225, and 270; 

U.S. Highways 34 and 160; and State Highways 13 and 470; for the Proposed Adesta 

Communications Fiber Optic System, Colorado. Centennial Archaeology, Inc., Fort Collins, 

Colorado. 

Treat, P. and J. A. Newkirk. 1981. A Class II Cultural Resource Investigation of the Proposed Craig to 

Rifle 230-kV to 345-kV Transmission Line Update, Northwest Colorado. Gilbert 

Commonwealth, Jackson, Michigan. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-9 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

3.12 Socioeconomic References 

Colorado. 2010. Mineral taxes. Internet website: http://www.colorado.gov/cs/Satellite?blobcol= 

urldata&blobheader=application%2Fpdf&blobkey=id&blobtable=MungoBlobs&blobwhere=125 

1672450913&ssbinary=true. Accessed September 27, 2015. 

Colorado Department of Local Affairs (DOLA). 2015. Department of Local Affairs Announces 

Payments of More Than $73 Million to Local Governments. Internet website: 

https://drive.google.com/file/d/0B-vz6H4k4SESMy1sakdjNjY0c28/view. Accessed 

September 28, 2015. 

Colorado Division of Reclamation, Mining and Safety (CDRMS). 2015. Reports & Data. Colorado Coal 

Production. Internet website: http://mining.state.co.us/Reports/Reports/Pages/Coal.aspx. 

Accessed December 14, 2015. 

Craig Chamber of Commerce. 2014. Housing & Real Estate. Internet website: http://www.craigchamber.com/housing-craig-colorado.html. Accessed December 14, 2015. 

Economic Development Council of Colorado (EDCC). 2015. Measurement of Economic Activity for 

Coal Industry and Electrical Power Generation Industry in the Yampa-White River Region of 

Northwest Colorado. Internet website: http://50.87.144.88/~cgm4edcc/edcconline.org/wpcontent/uploads/2015/05/EDCC_Measurement-of-Economic-Activity-for-Coal-Industry.pdf. 

Accessed September 27, 2015. 

Office of Surface Mining Reclamation and Enforcement (OSMRE). 2015. Colowyo Coal Mine, South 

Taylor/Lower Wilson Permit Expansion Area Project, Federal Mining Plan Modification 

Environmental Assessment. Issued August 2015. 

Trapper Mining Inc. (TMI). 2016a. 2015 Payroll and AP Spending, Received January 14, 2016. 

Trapper Mining Inc. (TMI). 2016b. AML and Black Lung Taxes and Fees. Received January 4, 2015. 

Trapper Mining Inc. (TMI). 2015. Trapper Mine Socioeconomic Information for 2010 through 2014. 

Received August 2015. 

U.S. Bureau of Economic Analysis (BEA). 2015. Table CA25N Total Full-Time and Part-Time 

Employment by NAICS Industry. Internet website: 

http://www.bea.gov/iTable/iTable.cfm?reqid=70&step=1&isuri=1&acrdn=5#reqid=70&step=24 

&isuri=1&7022=11&7023=7&7001=711&7090=70. Accessed December 14, 2015. 

U.S. Bureau of Economic Analysis (BEA). Compensation of Employees by Industry (CA6, CA6N). 

Internet website: http://www.bea.gov/iTable/iTable.cfm?reqid=70&step= 

1&isuri=1&acrdn=5#reqid=70&step=1&isuri=1. Accessed September 27, 2015. 

U.S. Bureau of Labor Statistic (BLS). 2015. Local Area Unemployment Statistics. Internet website: 

http://data.bls.gov/cgi-bin/dsrv?la. Accessed September 28, 2015. 

U.S. Census Bureau. 2015. American Fact Finder. Community Facts. Internet website: 

http://factfinder.census.gov/faces/nav/jsf/pages/index.xhtml. Accessed December 14, 2015. 

U.S. Census Bureau. 2013. Community Facts search page. Internet website: http:// 

factfinder.census.gov/faces/nav/jsf/pages/community_facts.xhtml. Accessed September 27, 

2015. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-10 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

U.S. Department of the Interior. 2016. Abandoned Mine Lands. Internet website: 

http://www.abandonedmines.gov/aa.html. Accessed January 5, 2016. 

Zillow.com. 2015. Craig Home Prices & Values. Internet website: http://www.zillow.com/craigco/home-values/. Accessed December 15, 2015. 

3.13 Environmental Justice References 

U.S. Census Bureau. 2015. American Fact Finder. Community Facts. Internet website: 

http://factfinder.census.gov/faces/nav/jsf/pages/index.xhtml. Accessed December 14, 2015. 

U.S. Census Bureau. 2014. Poverty Thresholds. Internet website: 

https://www.census.gov/hhes/www/poverty/data/threshld/. Accessed December 14, 2015. 

U.S. Environmental Protection Agency (USEPA). 1998. Guidance for Incorporating Environmental 

Justice Concerns in EPA’s NEPA Compliance Analyses. April 1998. Internet website: 

http://www3.epa.gov/environmentaljustice/resources/policy/ej_guidance_nepa_epa0498.pdf. 

Accessed September 28, 2015. 

3.14 Recreation References 

Bureau of Land Management (BLM). 2010. Little Snake Proposed Resource Management Plan and 

Final Environmental Impact Statement. August 2010. 

3.15 Visual Resources 

Bureau of Land Management (BLM). 2011. Record of Decision and Approved Resource Management 

Plan for the Little Snake Field Office. 

Bureau of Land Management (BLM). 1986. Manual H-8410-1 - Visual Resource Inventory. 

3.16 Paleontology References 

Bureau of Land Management (BLM). 2011. Record of Decision and Approved Resource Management 

Plan for Public Lands Administered by the Bureau of Land Management Little Snake Field 

Office Craig, Colorado. Prepared by United States Department of the Interior Northwest 

Colorado District Bureau of Land Management Little Snake Field Office, October 2011. 

Bureau of Land Management (BLM). 2010. Proposed Resource Management Plan and Final 

Environmental Impact Statement for Public Lands Administered by the Bureau of Land 

Management Little Snake Field Office Craig, Colorado. 

Bureau of Land Management (BLM). 2007. Instruction Memorandum 2008-009: Potential Fossil Yield 

Classification (PFYC) System for Paleontological Resources on Public Lands. 

Hinkemeyer, S. 2015. TMI, personal communication with A. Baldrige of AECOM. Received 

December 14, 2015. 

Massoth, T.W. 1982. Depositional Environments of Some Upper Cretaceous Coal-Bearing Strata at 

Trapper Mine, Craig, Colorado. Unpublished MS thesis University of Utah, 137 p. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-11 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

Sullivan, R. M. and S. G. Lucas. 2006. The Kirklandian Land Vertebrate “Age” – Faunal Composition, 

temporal Position, and Biostratigraphic Correlation in the Nonmarine Upper Cretaceous of 

Western North America in Lucas, S.G. and R.M. Sullivan (editors), Late Cretaceous 

Vertebrates from the Western Interior: New Mexico Museum of Natural History & Science, 

Albuquerque, New Mexico, 2006, p, 7-29. 

3.17 Access and Transportation References 

Air Resource Specialists, Inc. 2015. Personal Communication between Howard Gebhart (Air 

Resources) and Anne Baldrige (AECOM). September 29, 2015. 

Colorado Department of Transportation (CDOT). 2015. Traffic Data. Internet website: 

http://dtdapps.coloradodot.info/otis/TrafficData. Accessed on September 25, 2015. 

Hinkemeyer, S. 2016. Personal Communication between S. Hinkemeyer and A. Baldrige. January 14, 

2016. 

3.18 Solid Waste References 

Trapper Mining Inc. (TMI). 1981 et seq. An Application for a Permit to Conduct Coal Surface Mining 

and Reclamation Activities at the Trapper Mine in Moffat County, Colorado. C-81-010. 

U.S. Environmental Protection Agency (USEPA). 2015a. Environmental Compliance History Online. 

Detailed Facility Report, Trapper Mine, Inc. Internet website: http://echo.epa.gov/detailedfacility-report?redirect=page&fid=110008302522. Accessed December 15, 2015. 

U.S. Environmental Protection Agency (USEPA). 2011. RCRA Orientation Manual, 2011. Office of 

Resource Conservation and Recovery Program Management, Communications, and Analysis 

Office. EPA 530–F-11-003, October 2011, 241 p. 

U.S. Environmental Protection Agency (USEPA). 2000. EPCRA Section 313 Industry Guidance: Coal 

Mining Facilities. Office of Pollution Prevention and Toxics Washington, DC, February 2000, 

EPA 745-B-00-00, 146. 

3.19 Noise 

Colorado Department of Transportation (CDOT). 2015. Noise FAQs. Internet Website: 

https://www.codot.gov/programs/environmental/noise/noise-faqs.html. Accessed January 19, 

2016. 

Federal Highway Administration. 2006. Highway Traffic Noise. Construction Noise Handbook. August 

2006. Accessed at 

https://www.fhwa.dot.gov/environment/noise/construction_noise/handbook/. 

Sensogut. 2007. Occupational Noise in Mines and its control-A Case Study. Polish Journal of Environ. 

Studies Volume 16, Number 6. 

Suter. 2002. Construction Noise: Exposure, Effects and the Potential for Remediation; A Review and 

Analysis. In American Industrial Hygiene Association Journal Volume 63, Issue 6. 

3.20 Livestock Grazing References 

GeoCommunicator. 2015. Allotment Data. Internet website: http://www.geocommunicator.gov/blmMap/ 

Map.jsp?MAP=GA&MAP=ENERGY. Accessed September 29, 2015. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-12 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

3.21 Prime Farmlands References 

Colorado Division of Reclamation Mining and Safety (CDRMS). 2015. Proposed Decision and Finding 

of Compliance for the Trapper Mine Permit Revision PR-07. August 31, 2015. 

U.S. Department of Agriculture (USDA) 2015. Prime Farmlands Definitions. Internet website: 

http://www.nrcs.usda.gov/wps/portal/nrcs/detailfull/pr/soils/?cid=nrcs141p2_037285. Accessed 

September 30, 2015. 

3.22 Alluvial Valley Floors References 

Colorado Division of Reclamation Mining and Safety (CDRMS). 2015. Proposed Decision and Finding 

of Compliance for the Trapper Mine Permit Revision PR-07. August 31, 2015. 

Chapter 4.0 References 

Agapito Associates, Inc. 2015. Determination of Appropriate Blasting Vibration Limits to Protect a 

Nearby Archaeological Rock Art Site. Unpublished report prepared for Trapper Mining Inc., by 

Agapito Associates, Inc., Grand Junction, Colorado. 

Agapito Associates, Inc. 2008. Trapper G-Pit Landslide Mining Assessment, Tapper Mine, Colorado. 

Prepared for Trapper Mining Inc., January 2008. 

Air Resource Specialists. 2016. Trapper Mine Environmental Assessment Technical Support 

Document, Air and Climate Resources. January 7, 2016. 

Beckvar, N., T. M. Dillon, and L. B. Reads. 2005. Approaches for linking whole-body fish tissue 

residues of mercury or DDT to biological effects thresholds. Environ. Toxicol. and Chemistry 

24(8): 2094-2105. 

Bestgen, K. R., J. A. Hawkins, G. C. White, C. D. Walford, P. Badame, and L. Monroe. 2010. 

Population Status of Colorado Pikeminnow in the Green River Basin, Utah and Colorado, 

2006-2008. Final Report of the Larval Fish Laboratory, Colorado State University to the Upper 

Colorado River Endangered Fish Recovery Program, Denver, Colorado. 

Boening, D. W. 2000. Ecological Effects, Transport, and Fate of Mercury: A General Review. 

Chemosphere 40:1335-1351. 

Bryan, A. L., W. A. Hopkins, J. A. Baionno, and B. P. Jackson. 2003. Maternal Transfer of 

Contaminants to Eggs in Common Grackles (Quiscalus Quiscala) Nesting On Coal Fly Ash 

Basins. Archives of Environmental Contamination and Toxicology 45:273-277. 

Buckland-Nicks, A., K. N. Hillier, T. S. Avery, and N. J. O’Driscoll. 2014. Mercury Bioaccumulation in 

Dragonflies (Odonata: Anisoptera): Examination of Life Stages and Body Regions. 

Environmental Toxicology and Chemistry 33:2047–2054. 

Buhl, K. J. and S. J. Hamilton. 2000. The Chronic Toxicity of Dietary and Waterborne Selenium to 

Adult Colorado Pikeminnow in a Water Quality Simulating That in the San Juan River. Final 

Report prepared for the San Juan River Recovery Implementation Program Biology. 

Bureau of Land Management (BLM). 2011. BLM Little Snake Field Office Record of Decision and 

Approved Resource Management Plan. BLM Little Snake Field Office, Craig, Colorado, 

October 2011. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-13 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

Cai and Wang. 2014. Estimation of Emission Factors of Particulate Black Carbon and Organic Carbon 

from Stationary, Mobile, and Non-Point Sources in the United States for Incorporation into 

GREET. Argonne National Laboratory, Energy Systems Division, Systems Assessment 

Group, May 2014. 

Colorado Cultural Resources Survey Form, 5MF.948. Manuscript on file with the Office of Archaeology 

and Historic Preservation, History Colorado, Denver. 

Colorado Department of Public Health and Environment (CDPHE). 2015a. Personal communication 

with Emmett Malone, Air Quality Meteorologist, Air Pollution Control Division, E-Mail dated 

October 19, 2015. 

Colorado Department of Public Health and Environment (CDPHE). 2015b. Personal communication 

with Nancy Chick, Environmental Protection Specialist, Air Pollution Control Division, Email 

dated October 16, 2015. 

Colorado Department of Public Health and Environment (CDPHE). 2014a. Colorado Visibility and 

Regional Haze State Implementation Plan for the Twelve Mandatory Class I Federal Areas in 

Colorado. Revisions approved by the Colorado Air Quality Control Commission on 

November 20, 2014. 

Colorado Department of Public Health and Environment (CDPHE). 2014b. Colorado Greenhouse Gas 

Inventory - 2014 Update (Including Projections to 2020 and 2030). October 2, 2014. 

Colorado Department of Public Health and Environment (CDPHE). 2009. Air Emissions Permit 

#11MF253-1, Modification #2, issued to Trapper Mining Inc., May 8, 2009. 

Colorado Division of Reclamation, Mining and Safety (CDRMS). 2010. Cumulative Hydrologic Impact 

Assessment, Yampa River Basin. Revised May 4, 2010. 

Colorado Division of Reclamation, Mining and Safety (CDRMS).2009. Proposed Decision and 

Findings of Compliance for the Trapper Mine Permit No 08C110 Permit Revision P0R6, 

formerly Colorado Division of Minerals and Geology, September 21, 2009. 

Colorado Division of Water Resources. 2015. Map Viewer CDSS accessed at 

http://water.state.co.us/DataMaps/GISandMaps/MapViewer/Pages/FAQ.aspx. 

Colorado Parks and Wildlife (CPW). 2003. Conservation Plan for Grassland Species in Colorado. 

205 pp. 

Colorado Water Conservation Board. 2015. Instream Flow Water Rights Database. On-line resource 

available at: http://cwcb.state.co.us/technical-resources/instream-flow-water-rightsdatabase/Pages/main.aspx. 

Colorado Water Court, Water Division 6 2005. Case No. 02CW106: Application of Colorado River 

Water Conservation District and its Colorado River Water Projects Enterprise, in Routt and 

Moffat Counties, Colorado. Decree of the Water Court, the Honorable Michael A. O’Hara 

presiding. 

Cristol, D. A., R.L. Brasso, A.M. Condon, R.E. Fovargue, and others. 2008. The Movement of Aquatic 

Mercury through Terrestrial Food Webs. Science 320:335. 

Cummins, T. 2015. Annual Water Usage by Trapper Mining Inc. Letter dated January 14, 2015, from 

Tim Cummins, Senior Mining Engineer, Trapper Mining Inc., to Erin Light, Division Engineer, 

Water Division No. 6. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-14 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

Edmonds, S. T., N. J. O’Driscoll, N. K. Hillier, J. L. Atwood, and D. C. Evers. 2012. Factors Regulating 

the Bioavailability of Methylmercury to Breeding Rusty Blackbirds in Northeastern Wetlands. 

Environmental pollution, 171: 148–54. 

Environmental Integrity Project. 2011. America’s Power Plant Mercury Polluters: The Good, the Bad, 

and the Dirty, January 2011, available at www.environmentalintegrity.org. 

Electrical Power Research Institute. 2008. Multimedia fate of selenium and boron at coal-fired power 

plants equipped with particulate and wet FGD controls. Palo Alto, Colorado. 

Evers, D. C., A. K. Jackson, T. H. Tear, and C. E. Osborne. 2012. Hidden Risk-Mercury in Terrestrial 

Ecosystems of the Northeast. Biodiversity Research Institute Report BRI 2012- 07, Gorham, 

Maine. 

Gann, G. L., C. H. Powell, M. M. Chumchal, and R. W. Drenner. 2014. Hg-contaminated terrestrial 

spiders pose a potential risk to songbirds at Caddo Lake (Texas/Louisiana, USA). 

Environmental Toxicology and Chemistry. 34:303-306. 

Hamilton S. J., K. M. Holley, K. J. Buhl, and F. A. Bullard. 2005a. Selenium Impacts of Razorback 

sucker, Colorado: Colorado River II. Eggs. Ecotoxicology and Environmental Safety 61. 2005. 

Hamilton S. J., K. M. Holley, K. J. Buhl, and F. A. Bullard. 2005b. Selenium Impacts of Razorback 

sucker, Colorado: Colorado River III. Larvae. Ecotoxicology and Environmental Safety 61. 

2005. 

Hamilton, S. J. 2004. Review of Selenium Toxicity in the Aquatic Food Chain. Science of the Total 

Environment, 326: pp 1-31. 

Heinz, G. H., D. J. Hoffman, J. D. Klimstra, K. R. Stebbins, S. L. Kondrad, and C. A. Erwin. 2009. 

Species Differences in the Sensitivity of Avian Embryos to Methyl-Mercury. Archives of 

Environmental Contamination and Toxicology 56:129-138. 

Hinkemeyer, S. 2015. Commitment to findings of AAI report. 

Howie, M. 2010. The Lateral Extent and Spatial Variation of Mercury Exposure in Birds and the Prey 

near a Polluted River. Unpublished Master’s Thesis. College of William and Mary. 

Hydro-Engineering, LLC. 2015. 2014 Annual Hydrologic Report, Section 2.5. 

Larkin, R. 1996. Effects of Military Noise on Wildlife: A Literature Review. U.S. Army Construction 

Engineering Research Laboratory Technical Reports. January 1996. 

Lusk, J. 2010. Mercury (Hg) and selenium (Se) in Colorado pikeminnow and in razorback sucker from 

the San Juan River. USFWS, New Mexico Ecological Services presentation to SJRRIP, 

Biology Committee Meeting. January 13. 

National Park Service. 2015. Professional Qualifications Standards. National Park Service. Electronic 

document, Internet website: http://www.nps.gov/history/local-law/arch_stnds_9.htm. 

Accessed November 15, 2015. 

National Atmospheric Deposition Program. 2015. Annual Data for the Mercury Deposition Network 

Sites. Available at: http://nadp.sws.uiuc.edu/data/MDN/annual.aspx. Accessed on October 10, 

2015. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-15 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

Office of Surface Mining Reclamation and Enforcement (OSMRE). 2015. Colowyo Coal Mine South 

Taylor/Lower Wilson Permit Expansion Area Project, Federal Mining Plan Modification, 

Environmental Assessment, Moffat and Rio Blanco Counties, Colorado. Prepared in 

cooperation with the Bureau of Land Management, State of Colorado’s Department of Natural 

Resources, and Moffat County. 

Office of Surface Mining Reclamation and Enforcement (OSMRE). 2014. Four Corners Power Plant 

and Navajo Mine Energy Project Biological Assessment. August 2014. 

Office of Surface Mining Reclamation and Enforcement (OSMRE). 2013. Informal section 7 

consultation for the Trapper Mine owned and operated by Trapper Mining Inc., Colorado State 

Permit C-1981-010, Permit Renewal Application No. 6 (RN-6), February 28, 2013. 

Osmundson, B. C. and J. D. Lusk. 2012. Field Assessment of Mercury Exposure to Colorado 

Pikeminnow within Designated Critical Habitat. Project ID: FFS#6F54 and DEC# 

200860001.1. June 15, 2012. 

Scheuhammer, A. M., N. Basu, D. C. Evers, G. H. Heinz, M. B. Sandheinrich, and M. S. Bank. 2012. 

Ecotoxicology of Mercury in Fish and Wildlife-Recent Advances, in Bank, M.S., Ed., Mercury 

in the Environment-Pattern and Process. Berkeley, California, University of California Press, 

chap. 11, p. 223–238. 

Scheuhammer, A. M., M. W. Meyer, M. B. Sandheinrich, and M. W. Murray. 2007. Effects of 

Environmental Methylmercury on the Health of Wild Birds, Mammals, and Fish. Ambio 36:12-

18. 

Sharma, S and R. Singh. 1984. Selenium in soil, plant and animal systems. CRC Critical Reviews in 

Environmental Control 13: 23-50. 

Stubblefield, G. M. and R. W. Fish. 1992. Monolithic Overburden, Inclined Coal Seams: Trapper Mine, 

in Hartman, H.L., (editor) Society of Mining, Metallurgy, and Exploration, Mining Engineers 

Handbook, 2nd edition, Section 14.3.4, pages 1421 to 1426. 

Tan, S. W., J. C. Meiller, and K. R. Mahaffey. 2009. The Endocrine Effects of Mercury in Humans and 

Wildlife. Critical Reviews in Toxicology 39:228–269. 

Trapper Mining Inc. (TMI). 2015. Semi-annual Geotechnical Monitoring Report – September 2015. 

Trapper Mining Inc. (TMI). 2012. NPDES Permit CO-0032115. Effective November 1, 2012. 

Trapper Mining Inc. (TMI). 2008. Semi-Annual Geotechnical Monitoring Report, March 2008. 

Submitted to Colorado Division of Mines and Geology (now Colorado Division of Reclamation, 

Mining and Safety), March 24, 2008. 

Trapper Mining Inc. (TMI). 1981 et seq. An Application for a Permit to Conduct Coal Surface Mining 

and Reclamation Activities at the Trapper Mine in Moffat County, Colorado. C-81-010. 

Submitted January 1981, last updated October 2015. 

Tri-State Generation and Transmission Association. 2015. Mercury Emissions Data. 

U.S. Department of the Interior (DOI). 2003. United States Department of the Interior (USDI). 2003. 

Final Statewide Oil and Gas Environmental Impacts Statement and Proposed Amendment of 

the Powder River and Billings Resource Management Plans, Volume I. U.S. Department of 

the Interior, Bureau of Land Management and Montana Board of Oil and Gas Conservation, 

and Montana Department of Environmental Quality. January 2003. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-16 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

U.S. Department of the Interior (DOI). 1998. Guidelines for Interpretation of the Biological Effects of 

Selected Constituents in Biota, Water, and Sediment. National Irrigation Water Quality 

Program Information Report No. 3. 198 p. + appendices. http://www.usbr.gov/niwqp. 

U.S. Environmental Protection Agency (USEPA). 2015a. Compilation of Air Pollutant Emission Factors 

(AP-42). Accessed at https://www3.epa.gov/ttnchie1/ap42/. 

U.S. Environmental Protection Agency (USEPA). 2015b. AERMOD Implementation Guide. U.S. 

Environmental Protection Agency, Office of Air Quality Planning and Standards, Air Quality 

Assessment Division, Revised August 3, 2015. 

U.S. Environmental Protection Agency (USEPA). 2014a. Motor Vehicle Emissions Simulator 

(MOVES), User Guide for MOVES2014. U.S. Environmental Protection Agency, Office of 

Transportation and Air Quality, Assessment and Standards Division. EPA-420-B-14-055, July 

2014. 

U.S. Environmental Protection Agency (USEPA). 2014b. Toxic Release Inventory. Accessed at 

https://www.epa.gov/enviro/tri-search. 

U.S. Environmental Protection Agency (USEPA). 2013. Fact Sheet: Social Cost of Carbon, November 

2013. 

U.S. Environmental Protection Agency (USEPA). 2005a. Revision to the Guideline on Air Quality 

Models, 40 CFR 51 Appendix W. Federal Register, November 9, 2005. 

U.S. Environmental Protection Agency (USEPA). 2004. User’s Guide for the AMS/EPA Regulatory 

Model – AERMOD. U.S. Environmental Protection Agency, EPA-454/B-03-001, 

September 2004. 

U.S. Fish and Wildlife Service (USFWS). 2015. Biological opinion on the approval of a mining plan 

modification for the South Taylor/Lower Wilson Area at the Colowyo Coal Mine. Ecological 

Services, Grand Junction, 80pp. 

U.S. Fish and Wildlife Service (USFWS). 2014. Endangered and Threatened Wildlife and Plants; 

Determination of Threatened Status for the Western Distinct Population Segment of the 

Yellow-billed Cuckoo (Coccyzus americanus); Final Rule. Federal Register Vol. 79. No. 192. 

October 3, 2014. 

U.S. Fish and Wildlife Service (USFWS). 2013. DRAFT Flow recommendations for the endangered 

fish of the White River, Colorado and Utah. December 30, 2013. 

U.S. Fish and Wildlife Service (USFWS). 2011. USFWS. Colorado Pikeminnow (Ptychocheilus Lucius) 

5-Year Review: Summary and Evaluation. 2011. 

U.S. Geological Survey (USGS). 2015. USGS Surface-Water Data for Colorado. On-line resource 

accessed November 24, 2015, at: http://waterdata.usgs.gov/co/nwis/sw. 

Young, R. 1998. Toxicity Summary for Mercury. Chemical Hazard Evaluation Group, Health Sciences 

Research Division, Oak Ridge National Laboratory, Oak Ridge, Tennessee. 

Zhang, L., P. Blanchard, D. A. Gray, E. M. Prestbo, M. R. Risch, D. Johnson, J. Narayan, R. Zsolway, 

T. M. Holsen, E. K. Miller, M. S. Castro, J. A. Graydon, V. L. St. Louis, and J. Dalziel. 2012. 

Estimation of speciated and total mercury dry deposition at monitoring locations in eastern and 

central North America. Atmos. Chem. Phys. 12:4327-4340. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-17 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

Zolfaghari, G., A. Esmaili-Sari, S. M. Ghasempouri, R. R. Baydokhti, and B. H. Kiabi. 2009. A 

Multispecies Monitoring Study about Bioaccumulation of Mercury in Iranian Birds (Khuzestan 

to Persian Gulf): Effect of Taxonomic Affiliation and Trophic Level. Environmental Research 

109:830-836. 

Chapter 5.0 References 

Brownfield, M. E, R. D. Hettinger, and E. A. Johnson. 2000. A Summary of the Stratigraphy, Coal 

Resources, and Coal-Bed Methane Potential of Northwest Colorado, in M.A. Kirschbaum, 

L.N.R. Roberts, and L.R.H. Biewick (editors), Geologic Assessment of Coal in the Colorado 

Plateau Arizona, Colorado, New Mexico, and Utah: U.S. Geological Survey Professional 

Paper 1625–B, Chapter I. 

Bureau of Land Management (BLM). 2015. NEPA in the vicinity of the Trapper Mine. Personal 

communication between Kathy McKinstry (BLM) and Eve Bingham (AECOM). November 16, 

2015. 

Carroll. 2004. Summary of Coal Resources in Colorado 2003. Colorado Geological Survey Special 

Publication 54. 

Colorado Department of Public Health and Environment (CDPHE). 2014. Colorado Greenhouse Gas 

Inventory - 2014 Update (Including Projections to 2020 and 2030). October 2, 2014. 

Colorado Division of Reclamation and Mining Safety (CDRMS). 2015. Email correspondence from 

CDRMS Amy Yandell, Dan Hernandez to AECOM Evelyn Bingham November 17, 2015 to 

November 20, 2015, Subject Trapper EA cumulative effects-questions on mines within 

20 miles. November 2015. 

Colorado Division of Reclamation and Mining Safety (CDRMS). 2015. Colorado Division of 

Reclamation Mining and Safety (CDRMS). 2015. Colorado Coal Production, 2001 through 

2015. Internet website: http://mining.state.co.us/Reports/Reports/Pages/Coal.aspx. 

Colorado Division of Reclamation, Mining and Safety (CDRMS). 2010. Cumulative Hydrologic Impact 

Assessment, Yampa River Basin. Revised May 4, 2010. 

Colorado Oil and Gas Conservation Commission (COGCC). 2015a. Colorado Oil and Gas Information 

System (COGIS) Database. Accessed November 18, 2015. 

Colorado Oil and Gas Conservation Commission (COGCC). 2015b. 

Cummins, T. 2015. Annual Water Usage by Trapper Mining Inc. Letter dated January 14, 2015, from 

Tim Cummins, Senior Mining Engineer, Trapper Mining Inc., to Erin Light, Division Engineer, 

Water Division No. 6. 

Jaffe, M. 2015. Denver Post. Moffat County Facing Fate of the Changing West. Internet website: 

http://www.denverpost.com/business/ci_28395568/craig-colorado-facing-fate-changingwestern-united-states. Accessed November 18, 2015. 

National Park Service. 2012. Dinosaur National Monument Visitation up Over 54 Percent. Internet 

website: http://www.nps.gov/dino/learn/news/dinosaur-national-monument-visitation-up-over54-percent.htm. Accessed January 6, 2016. 

Office of Surface Mining Reclamation and Enforcement (OSMRE). 2015. Colowyo Coal Mine, South 

Taylor/Lower Wilson Permit Expansion Area Project, Federal Mining Plan Modification 

Environmental Assessment. Issued August 2015. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-18 
 

 

 

 

 

 

 

 

 

 

 

 

Chapter 7.0 – References 

Trapper Mining Inc. (TMI). 2015. Semi-annual Geotechnical Monitoring Report – September 2015. 

Tri-State Generation and Transmission Association. 2015. Craig Station Description. Internet website: 

http://www.tristate.coop/AboutUs/baseload-resources.cfm. Accessed on January 15, 2016. 

U.S. Energy Information Agency. 2015. Annual Electric Utility Data, Form EIA-923 Detailed Data. 

Internet website: https://www.eia.gov/electricity/data/eia923/. Accessed January 7, 2016. 

U.S. Environmental Protection Agency (USEPA). 2015b. Climate Impacts in the Southwest (Updated 

July 21, 2015). Available at http://www.epa.gov/climatechange/impactsadaptation.U.S. 

U.S. Environmental Protection Agency (USEPA). 2009. Regulation of Oil and Gas Construction 

Activities. Internet website: http://water.epa.gov/polwaste/npdes/stormwater/Regulation-of-Oiland-Gas-Construction-Activities.cfm. Accessed December 28, 2015. 

Yampa Valley Data Partners. 2012. Steamboat Visitors Winter Visitor Estimates. Internet website: 

http://www.steamboattoday.com/news/2012/may/15/data-visitor-numbers-flat-steamboat/. 

Accessed January 6, 2016. 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-19 
 

 

Chapter 7.0 – References 

This page intentionally left blank 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

7-20 
Appendix A 

Appendix A 

Legal Notice and 

Outreach Letter 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

 

Public Notice
 

Trapper Mine Mining Plan Modification
 

Environmental Assessment
 

The U.S. Department of the Interior (DOI), Office of Surface Mining Reclamation and Enforcement 

(OSMRE), Western Region, will prepare an environmental assessment (EA) to analyze environmental 

impacts of a Federal mining plan approval for current and future mining within Federal Coal Leases Nos. 

C-079641 and C-07519 held by Trapper Mining Inc. as part of the Trapper Mine. The EA will cover the 

time period beginning July 1, 2015, and continuing through the planned life of mine for the portion of the 

two Federal coal lease areas lying within the approved Surface Mining Control and Reclamation Act of 

1977 (SMCRA) Permit Area (the Project). As required by the National Environmental Policy Act of 1969 

(NEPA), the EA will disclose the potential for direct, indirect, and cumulative impacts to the environment 

from the Project. 

Preparation of the EA will be completed pursuant to the Court-approved Joint Proposed Remedy, as 

approved by the United States District Court for the District of Colorado on September 14, 2015, in the 

case entitled WildEarth Guardians v. U.S. Office of Surface Mining et al., Case 1:13-cv-00518-RBJ (D. 

Colo. 2015). As part of the Court-approved remedy, OSMRE agreed to conduct a new NEPA analysis for 

Trapper’s current and future mining activities within Federal Coal Leases Nos. C-079641 and C-07519. 

The Trapper Mine is located approximately 6 miles south of the town of Craig in Moffat County, 

Colorado, east of Colorado Highway 13. The proposed Project is occurring on two federal coal leases 

administered by the Bureau of Land Management (BLM) and located within the eastern portion of the 

Trapper Mine’s approved SMCRA Permit Area. Federal Coal Lease C-07519 was issued by the BLM in 

June 1958 and Federal Coal Lease C-079641 was issued by the BLM in October 1962. The leases within 

the SMCRA Permit Area cover a total of approximately 2,423 acres of Federal mineral estate. As of July 

1, 2015, approximately 19 million tons of recoverable Federal coal remains within the Project Area. The 

Trapper Mine uses a combination of dragline, truck shovel, and highwall mining methods to remove the 

overburden and mine the coal. 

The EA will update, clarify, and provide new and additional environmental information for the Project. 

As a result of the EA process, OSMRE will determine whether or not there are significant environmental 

impacts. An environmental impact statement will be prepared if the EA identifies significant impacts. If a 

finding of no significant impact is reached, and pursuant to 30 CRF 746.13, OSMRE will prepare and 

submit to the Assistant Secretary for Lands and Minerals Management (ASLM) a mining plan decision 

document recommending approval, disapproval, or conditional approval of the mining plan. The ASLM 

will approve, disapprove, or conditionally approve the mining plan approval document within the mining 

plan decision document, as required under the Mineral Leasing Act of 1920. 

OSMRE will hold an open-house public outreach meeting that will include displays and handouts 

explaining the status of the Project. The public outreach meeting will also provide opportunities to ask 

questions of OSMRE and Trapper representatives about the Project and the NEPA process, and 

opportunities to provide written comments on the project. The meeting will be held on, October 29, 2015, 

from 4-8 pm at Moffat County Fairgrounds, Pavilion Building, 640 E. Victory Way, Craig, Colorado 

81625. 

OSMRE is soliciting public comments on the Project. Your comments will help to determine the issues 

and alternatives that will be evaluated in the environmental analysis. You are invited to direct these 

comments by email: osm-nepa-co@osmre.gov, ensure the subject line reads: ATTN: OSMRE, Trapper 

1 
 

Mine MPDD EA. Comments may also be received by mail: OSMRE WR, C/O Nicole Caveny, C-079641 

and C-07519 EA, 1999 Broadway, Suite 3320 Denver, CO 80202 and be postmarked no later than 

November 12, 2015, in order to be considered during the preparation of the EA. Comments received, 

including names and addresses of those who comment, will be considered part of the public record for 

this Project and will be available for public inspection. Additional information regarding the Project may 

be obtained from Nicole Caveny at (303) 293-5078. When available, the EA and other supporting 

documentation will be posted at and may be obtained from 

http://www.wrcc.osmre.gov/initiatives/trappermine.shtm. 

2 
 

 

 

 

United States Department of the Interior 

OFFICE OF SURFACE MINING
 

RECLAMATIONANDENFORCEMENT
 

Western Region Office 

1999 Broadway, Suite 3320 

Denver, CO 80202-3050 

October 13, 2015 

Dear Interested Public Land User, 

The U.S. Department of the Interior (DOI), Office of Surface Mining Reclamation and Enforcement (OSMRE), 

Western Region, will prepare an environmental assessment (EA) to analyze environmental impacts of a Federal 

mining plan approval for current and future mining within Federal Coal Leases Nos. C-079641 and C-07519 

held by Trapper Mining Inc. as part of the Trapper Mine. The EA will cover the time period beginning July 1, 

2015, and continuing through the planned life of mine for the portion of the two Federal coal lease areas lying 

within the approved Surface Mining Control and Reclamation Act of 1977 (SMCRA) Permit Area (the Project). 

As required by the National Environmental Policy Act of 1969 (NEPA), the EA will disclose the potential for 

direct, indirect, and cumulative impacts to the environment from the Project. 

Preparation of the EA will be completed pursuant to the Court-approved Joint Proposed Remedy, as approved by 

the United States District Court for the District of Colorado on September 14, 2015, in the case entitled 

WildEarth Guardians v. U.S. Office of Surface Mining et al., Case 1:13-cv-00518-RBJ (D. Colo. 2015). As part 

of the Court-approved remedy, OSMRE agreed to conduct a new NEPA analysis for Trapper’s current and 

future mining activities within Federal Coal Leases Nos. C-079641 and C-07519. 

The Trapper Mine is located approximately 6 miles south of the town of Craig in Moffat County, Colorado, east 

of Colorado Highway 13. The proposed Project is occurring on two federal coal leases administered by the 

Bureau of Land Management (BLM) and located within the eastern portion of the Trapper Mine’s approved 

SMCRA Permit Area. Federal Coal Lease C-07519 was issued by the BLM in June 1958 and Federal Coal 

Lease C-079641 was issued by the BLM in October 1962. The leases within the SMCRA Permit Area cover a 

total of approximately 2,423 acres of Federal mineral estate. As of July 1, 2015, approximately 19 million tons 

of recoverable Federal coal remains within the Project Area. The Trapper Mine uses a combination of dragline, 

truck shovel, and highwall mining methods to remove the overburden and mine the coal. 

The EA will update, clarify, and provide new and additional environmental information for the Project. As a 

result of the EA process, OSMRE will determine whether or not there are significant environmental impacts. An 

environmental impact statement will be prepared if the EA identifies significant impacts. If a finding of no 

significant impact is reached, and pursuant to 30 CFR 746.13, OSMRE will prepare and submit to the Assistant 

Secretary for Lands and Minerals Management (ASLM) a mining plan decision document recommending 

approval, disapproval, or conditional approval of the mining plan. The ASLM will approve, disapprove, or 

conditionally approve the mining plan approval document within the mining plan decision document, as required 

under the Mineral Leasing Act of 1920. 

1 
 

 

 

 

 

 

OSMRE will hold an open-house public outreach meeting that will include displays and handouts explaining the 

status of the Project. The public outreach meeting will also provide opportunities to ask questions of OSMRE 

and Trapper representatives about the Project and the NEPA process, and opportunities to provide written 

comments on the project. The meeting will be held on October 29, 2015, from 4-8 pm at Moffat County 

Fairgrounds, Pavilion Building, 640 E. Victory Way, Craig, Colorado 81625. 

OSMRE is soliciting public comments on the Project. Your comments will help to determine the issues and 

alternatives that will be evaluated in the environmental analysis. You are invited to direct these comments by 

mail to: 

OSMRE WR 

C/O: Nicole Caveny 

Trapper Mine EA 

1999 Broadway, Suite 3320 

Denver, CO 80202-3050 

Comments may also be emailed to: osm-nepa-co@osmre.gov, ensure the subject line reads: ATTN: OSMRE, 

Trapper Mine MPDD EA. Comments sent by mail or email should be postmarked or received no later than 

November 12, 2015, in order to be considered during the preparation of the EA. Comments received, including 

names and addresses of those who comment, will be considered part of the public record for this Project and will 

be available for public inspection. Additional information regarding the Project may be obtained from Nicole 

Caveny at (303) 293-5078. When available, the EA and other supporting documentation will be posted at, and 

may be obtained from, http://www.wrcc.osmre.gov/initiatives/trappermine.shtm. 

Sincerely, 

Marcelo Calle, Manager
 

Field Operations Branch
 

2 
Appendix B 

Appendix B 

Air Technical Support Document 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

TRAPPER MINE ENVIRONMENT AL ASSESMENT 


TECHNICAL SUPPORT DOCUMENT 


AIR AND CLIMATE RESOURCES 


Prepared for 

OFFICE OF SURFACE MINING RECLAMATION & ENFORCEMENT 

Denver, Colorado 

Prepared by 

1901 Sharp Point Dr., Suite E 

Fort Collins, CO 80525 

970-484-7941 

www.au-resource.com 

D. Howard Gebhart 


Updated March 21, 2016 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

TABLE OF CONTENTS
 

Section	 Page 

1.0 INTRODUCTION & BACKGROUND 1-1 

2.0 EMISSIONS INVENTORY FOR DIRECT AIR QUALITY IMPACTS 

FROM MINING ACTIVITIES 2-1 

2.1 Particulate Matter (PM10/PM2.5) 2-1 

2.2 Combustion Emissions (NOX, SO2, CO, and VOCs) 2-6 

2.3 Black Carbon Emissions 2-7 

3.0 EMISSIONS INVENTORY FOR INDIRECT IMPACTS ASSOCATED 

WITH COAL COMUBSTION 3-1 

3.1 Indirect Criteria Pollutant Emissions from Electricity 

Generation (SO2, NOX, CO, and VOCs) 3-2 

3.2 Mercury Emissions from Electricity Generation 3-4 

3.3 Coal Combustion Residual Disposal at Trapper Mine 3-5 

4.0 DISPERSION MODELING ANALYSIS FOR DIRECT AND INDIRECT 

MINE EMISSIONS 4-1 

4.1 Modeling Overview 4-1 

4.2 Technical Approach 4-4 

4.2.1 Receptor Information 4-4 

4.2.2 Background Concentrations 4-5 

4.2.3 Emissions Information 4-6 

4.2.4 Particle Disposition 4-10 

4.2.5 Ozone Limiting Method 4-11 

4.3 AERMOD Modeling Results 4-13 

4.3.1 NAAQS Compliance Demonstration 4-13 

4.3.2 Maximum Impact Locations 4-16 

5.0 DIRECT AND INDIRECT GREENHOUSE GAS (GHG) EMISSIONS AND 

ASSOCIATED CLIMATE IMPACTS 5-1 

5.1 Direct Greenhouse Gas Emissions 5-1 

5.2 Indirect Greenhouse Gas Emissions 5-2 

6.0 SUMMARY OF AIR QUALITY & CLIMATE IMPACTS 6-1 

7.0 REFERENCES 7-1 

LIST OF FIGURES 

Figure	 Page 

4-1	 Trapper Mine On-Site Wind Rose 4-2 

4-2	 Gossard Wind Rose 4-3 

4-3	 AERMOD Receptor Map – Trapper Mine EA Modeling 4-5 

4-4	 Geographic Allocation of Emissions during Worst-Case Year (2020) 4-7 

i 
2-5 

3-1 

5-2 

LIST OF TABLES 

2-1 Fugitive Dust Emission Controls at Trapper Mine as Required by CDPHE 2-1 Q 

2-2 Trapper Mine PM,o and PM2_5 Emission Factors 2-3 Q 

2-3 Projected Trapper Mine PM10 and PM2_5 Emissions through 2025 2-4 Q 

2-4 Worst-Case Year (2020) Trapper Mine PM10 and PM2_

5 Direct Emissions 2-5 Q 

Direct Mining Emissions for Worst-Case Year (2020): Fuel Combustion and Blasting 2-6 Q



2-6 Direct Mining Emissions for Worst-Case Year (2020) Hazardous Air Pollutants 2-7 Q



2-7 Direct Mining Related Emissions for Worst-Case Year (2020)- Black Carbon (tpy) 2-7 Q



3-1 Summary of Air Emission Controls -Craig Generating Station 

3-2 Indirect Coal Combustion Emissions: Craig Generating Station (tpy) 

3-3 Actual 2014 Craig Generating Station - Mercury Emissions 3-4 Q 

3-4 Craig Generating Station Mercury Emissions from Trapper Mine Coal (lb/yr) 3-5 Q 

3-5 Indirect PM10 and PM2.

5 Emissions from Coal Combustion Residual Disposal 3-6 Q 

3-6 Indirect Emissions for Worst-Case Year (2020) Fuel Combustion 3-6 Q 

4-1 Recommended Background Concentration Values from CDPHE 4-6 Q 

4-2 Volume Source Emissions and Data Parameters for Trapper Mine Haul Road Emissions 4-8 Q 

4-3 Area-Poly Source Emissions and Data Parameters for Trapper Mining Pits 4-10 Q 

4-4 AERMOD Particle Size Data for PM10 Deposition Modeling 4-11 Q 

4-5 Seasonal/Diurnal Ozone Profile for OLM 4-12 Q 

4-6 AERMOD Modeling Results - Trapper Mine: Trapper Mine On-Site Meteorological Data 4-14 Q 

4-7 AERMOD Modeling Results - Trapper Mine: Gossard Meteorological Data 4-15 Q 

5-1 Direct Mining Emissions for Worst-Case Year (2020) GHG Emissions 5-2 Q 

Adjustment of COrOnly Coal Combustion Emissions for C02e 

5-3 Indirect Trapper Mine GHG Emissions Reported as C02e 5-3 Q 

11 

3-2 

5-3 
 

 

 

 

1.0 INTRODUCTION & BACKGROUND 

This Technical Support Document (TSD) describes the air and climate resource analyses 

conducted in support of the Trapper Mine Environmental Assessment (EA). The Air-Climate 

TSD reviews the technical air resources and climate analyses conducted on the proposed action 

and covers both direct and indirect air resources and climate resource impacts from continued 

operation of the Trapper Mine. 

The TSD provides additional technical details about the emission calculations, dispersion 

modeling, and other aspects of the air and climate resource analysis. The air quality and climate 

resource discussion in the EA is covered at the appropriate level for the general public, while the 

TSD provides supplemental technical details of interest to the air quality/climate professional 

which may not be covered in the EA. 

Direct impacts associated with the Trapper Mine include the following: 

•	 Particulate matter (PM10 and PM2.5) emissions associated with the Trapper Mine 

operations, including but not limited to emissions from drilling, blasting, coal excavation 

and removal, overburden excavation and removal, and emissions from coal/overburden 

hauling on unpaved roads within the mine. 

•	 Emissions of nitrogen oxides (NOX), sulfur dioxide (SO2), carbon monoxide (CO), and 

volatile organic compounds (VOCs) associated with fuel combustion in mining 

equipment and haul trucks. 

•	 Greenhouse gas (GHG) emissions, including but not limited to fugitive methane releases 

from the coal mining seams and GHGs associated with fuel combustion in mining 

equipment and haul trucks. 

•	 Black carbon emissions associated with fuel combustion in mining equipment and haul 

trucks. 

Ozone impacts are discussed in the Trapper Mine EA under the Cumulative Impacts 

section (EA Chapter 5) since the contribution of individual source emissions to regional ozone 

levels cannot be accurately quantified. However, emissions of ozone precursors (NOX and 

VOCs) are quantified in this TSD. 

Indirect impacts associated with coal combustion have been evaluated and include 

emissions at the Craig Station from combustion of coal to generate electricity. Based on the 

CDPHE-issued Title V operating permit (CDPHE, 2005), the Craig Station includes three coalfired electric generating units (EGUs), with a combined net electric generating capacity of 1,264 

megawatts (MW). Unit 1 was placed in service in 1980, Unit 2 in 1979, and Unit 3 in 1984. Coal 

from the Trapper Mine is used almost exclusively at Units 1 and 2 and coal from other sources is 

fired in Unit 3. 

1-1 
 

 

 

 

 

 

The Trapper Mine Air Quality & Climate TSD is organized as follows: 

•	 Chapter 2: Emissions Inventory for Direct Air Quality Impacts from Mining Activities 

•	 Chapter 3: Emissions Inventory for Indirect Air Quality Impacts Associated with Coal 

Combustion 

•	 Chapter 4: Dispersion Modeling Analysis for Direct and Indirect Trapper Mine 

Emissions 

•	 Chapter 5: Direct and Indirect Greenhouse Gas (GHG) Emissions and Associated 

Climate Impacts 

•	 Chapter 6: Summary of Air Quality and Climate Impacts 

•	 Chapter 7: References 

1-2 
 

 

 

 

 

 

 

2.0	 EMISSIONS INVENTORY FOR DIRECT AIR QUALITY IMPACTS 

FROM MINING ACTIVITIES 

All direct emission calculations were quantified based on the maximum allowable mining 

rate at the Trapper Mine, i.e., 2.6 million tons per year (mtpy). The maximum mining rate is 

based on the air quality permit issued by the Colorado Department of Public Health & 

Environment (CDPHE) - Permit 11MF253-1, Modification 2, Issued May 8, 2009 (CDPHE 

2009). Operating data for each year of future mine life supplied by Trapper Mining, Inc. (TMI) 

was used with the maximum coal production rate to derive the emissions information. 

For PM10 and PM2.5, emissions were quantified for each year up to 2025 (when the coal 

reserves in the subject leases will be exhausted based on TMI’s current mining plans). Based on 

the calculated PM10/PM2.5 emissions, a “worst-case” year was selected and all other pollutants 

emissions were then evaluated for the selected “worst-case” year. As documented below, the 

“worst-case” future emissions year was determined to be 2020. 

2.1 Particulate Matter (PM10/PM2.5) 

Particulate matter emissions (PM10 and PM2.5) occur from mining activities as well as 

emissions associated with diesel fuel combustion in the mining equipment and trucks. Mining 

activities include drilling, blasting, coal and overburden removal and handling, and coal hauling 

by truck from the Trapper Mine to the adjacent Craig Station. 

PM10 and PM2.5 emission controls are imposed through the fugitive dust control plan 

contained in the Trapper Mine air emissions permit issued by the CDPHE. These emissions 

controls are summarized in Table 2-1. 

Table 2-1
 

Fugitive Dust Emission Controls at Trapper Mine as Required by
 

CDPHE Air Permit 11MF253-1, Modification 2, Issued May 8, 2009 

Trapper Mine Fugitive Dust Control Measures 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

Topsoil and overburden stockpiles shall be compacted and revegetated within 1 year of completion of 

stockpile construction. 

Emissions from material handling (i.e., removal, loading, and hauling), except for dragline 

operations, shall be controlled by watering two or more times per day except when ambient 

temperatures are below 32°F or precipitation is occurring. 

Unpaved haul roads shall be treated with chemical stabilizers per suppliers’ recommendations and 

watered as often as needed to control fugitive particulate emissions. Haul roads shall be graveled. 

Reclamation works and sequential extraction of material shall be initiated to keep the total disturbed 

areas at any one time to a minimum. 

Drilling of overburden for blasting shall employ water spray units or bag filters. 

Sequential blasting shall be employed for particulate reduction associated with blasting activities. No 

blasting shall take place when wind speeds exceed 30 miles per hour, unless safety conditions 

warrant otherwise. 

The utility waste placed at the mine shall be kept sufficiently moist until the waste is covered to 

control fugitive emissions. 

2-1 
 

 

 

 

Direct PM10 and PM2.5 emissions associated with the mining activities include a number 

of individual sources of particulate emissions, including drilling, blasting, bulldozing of 

coal/overburden, truck loading for coal and overburden, dragline operation, overburden 

replacement, scraper activities, hauling of coal and overburden by truck, wind erosion of 

disturbed areas, road maintenance (graders), and light duty vehicle traffic. Emissions were 

calculated using appropriate emission factors and TMI’s operating data on mine activity. 

Table 2-2 documents the emission factors used for the PM10 and PM2.5 emissions for 

each mining activity along with the technical source for each factor. The emission calculations 

used standard US Environmental Protection Agency (USEPA) factors for western surface coal 

mines from USEPA’s Compilation of Air Pollutant Emission Factors, or AP-42 (USEPA 

Undated). The calculations used AP-42 Section 11.9 (Western Surface Coal Mines) or other AP42 sections as appropriate for each individual emissions source. For PM10 and PM2.5, given that 

the AP-42 factors already included any contribution associated with fuel combustion in mining 

equipment and trucks to the total particulate emissions, it was not necessary to separately 

calculate the PM10 and PM2.5 emissions from fuel combustion in mining equipment and trucks. 

Detailed emission calculations for each source category are available by CD upon 

request. 

2-2 
 

 

 

 

 

 

 

 

 

 

 

 

 

Table 2-2
 

Trapper Mine PM10 and PM2.5 Emission Factors
 

Mining Operation Technical Source for 

Factor PM10 Factor PM2.5 Factor 

Drilling: Coal AP-42 Table 11.9-41 0.08 lb/hole 0.08 lb/hole 

Drilling: Overburden AP-42 Table 11.9-41 0.46 lb/hole 0.46 lb/hole 

Blasting: Coal AP-42 Table 11.9-1 77.5 lb/blast 4.5 lb/blast 

Blasting: Overburden AP-42 Table 11.9-1 83.8 lb/blast 4.8 lb/blast 

Dragline AP-42 Table 11.9-1 0.011 lb/yd^3 0.0011 lb/yd^3 

Bulldozing: Coal AP-42 Table 11.9-1 13.3 lb/hr 1.1 lb/hr 

Bulldozing: Overburden AP-42 Table 11.9-1 0.8 lb/hr 0.4 lb/hr 

Bulldozing: Ash AP-42 Table 11.9-1 98.9 lb/hr 4.6 lb/hr 

Topsoil Removal: Scraper AP-42 Tab le 11.9-41 0.02 lb/ton 0.02 lb/ton 

Topsoil: Scraper Travel Mode AP-42 Tab le 11.9-41 0.014 lb/ton 0.014 lb/ton 

Truck Loading: Coal AP-42 Table 11.9-1 6.5E-3 lb/ton 6.5E-4 lb/ton 

Truck Loading: Overburden AP-42 13.2.4 Eqn 12 1.68E-4 lb/ton 2.54E-5 lb/ton 

Grading: Coal/OB Roads AP-42 Table 11.9-1 1.1 lb/VMT 0.11 lb/VMT 

Truck Hauling: Coal AP-42 13.2.2 Eqn 1a3 6.63 lb/VMT 0.663 lb/VMT 

Truck Hauling: Overburden AP-42 13.2.2 Eqn 1a3 4.23 lb/VMT 0.423 lb/VMT 

Truck Hauling: Ash AP-42 13.2.2 Eqn 1a3 3.45 lb/VMT 0.345 lb/VMT 

Light Duty Vehicle Traffic AP-42 13.2.2 Eqn 1a3 0.82 lb/VMT 0.082 lb/VMT 

Wind Erosion AP-42 Tab le 11.9-42 0.73 lb/acre/day 0.11 lb/acre/day 

1

PM10/PM2.5 assumed to be the same 

2

The AP-42 Emission Factor represents TSP. Particle sizes from AP-42 Section 13.2.4 used to adjust for PM10/PM2.5 

3

AP-42 Section 13.2.2 Eqn 2 used to correct for the number of wet days (90) in AP-42 equation 

2-3 
 

 

 

 

 

 

Table 2-3 summarizes the PM10 and PM2.5 emissions for each year through 2025 when 

the TMI coal reserves on the subject leases will be exhausted based on the current mining plans. 

The emission calculations in each year assume a constant coal production rate of 2.6 mtpy. 

The emissions calculations for Table 2-3 used standard USEPA factors for western 

surface coal mines from USEPA’s Compilation of Air Pollutant Emission Factors, or AP-42 

(USEPA, Undated). These factors were combined with year-by-year projections of mine 

operations provided by TMI to calculate the PM10 and PM2.5 emissions for each year. 

Table 2-3
 

Projected Trapper Mine PM10 & PM2.5 Emissions through 2025
 

Mining Year PM10 Emissions 

(tpy) 

PM2.5 Emissions 

(tpy) 

2016 533.88 79.75 

2017 537.06 82.08 

2018 526.23 80.25 

2019 534.62 84.50 

2020 603.51 93.25 

2021 615.89 96.83 

2022 569.46 88.21 

2023 525.76 80.76 

2024 450.35 69.22 

2025 335.46 48.00 

Table 2-3 includes indirect emissions from CCRs disposal. The total PM10 and PM2.5 emissions including 

CCRs disposal were evaluated to select the worst-case year. 

Based on Table 2-3, the peak PM10/PM2.5 emissions occur in Calendar Years 2020 and 

2021. In the TMI mining plans, both 2020 and 2021 are years with higher than average 

overburden stripping ratios, so the overburden volumes to be handled and transported within the 

mine pit are greater along with the associated air emissions. As noted in Table 2-3, the 

magnitude of the emissions between 2020 and 2021 are virtually the same, so the selection of the 

worst-case year also considered the relative location of the PM10/PM2.5 emissions within the 

mine. 

Beginning in 2019, TMI plans to open a new mining pit (“N Pit”) and from 2019 

forward, air emissions will occur in both “N Pit” and the current mining pit (“L Pit”). However, 

in 2020, there is a higher concentration of emissions in the current “L Pit”. The “L Pit” also 

encroaches on the eastern SMCRA Permit Boundary in 2020, meaning that the separation 

distance between the emissions location and off-site ambient air is less. Given the higher density 

of emissions from “L Pit” and the proximity of “L Pit” to the ambient air boundary, 2020 was 

2-4 
 

 

 

 

 

 

 

 

 

 

selected as the “worst-case year” for the air quality analysis as these conditions would be 

expected to produce higher air quality impacts in the air dispersion model. In 2021, the emissions 

would be less concentrated, with more of the emissions in “N Pit”. Once the worst-case year 

was selected based on the emissions data for PM10 and PM2.5, the same worst-case year (2020) 

was also used for all other pollutants. 

It should be noted that only a fraction of the area encompassing the proposed “N Pit” 

actually lies within the boundaries for the coal leases that are the subject of the current Trapper 

Mine EA. Also, for the worst-case emissions years (2020 and 2021), the “N Pit” mining activity 

would occur outside of the lease boundary, but within the Trapper Mine SMCRA permit 

boundary. Nevertheless, because some of “N Pit” lies within the leases in question, all expected 

air emissions over the expected future life of mine, including both “N Pit” and “L Pit”, were 

considered in the Trapper EA and air dispersion model. 

A more detailed PM10/PM2.5 inventory for the worst-case year (2020) is summarized in 

Table 2-4. The AP-42 emission factors were combined with projections of mine operations 

provided by TMI to calculate the total PM10 and PM2.5 emissions for the worst-case year (2020). 

Where specific PM2.5 emission factors were unavailable, the calculations used a worst-case 

assumption that all PM10 emissions were in the PM2.5 fraction. 

Table 2-4
 

Worst-Case Year (2020) Trapper Mine 

PM10 and PM2.5 Direct Emissions
 

Mining Operation PM10 (tpy) PM2.5 (tpy) 

Drilling: Coal & Overburden 0.98 0.98 

Blasting: Coal & Overburden 0.06 0.003 

Truck Loading: Coal 8.48 0.88 

Bulldozing: Coal 30.93 2.53 

Bulldozing: Overburden 35.70 19.62 

Overburden Replacement 78.58 11.79 

Dragline 111.55 9.60 

Topsoil Removal: Scraper 2.15 2.15 

Topsoil: Scraper Travel Mode 27.93 2.79 

Topsoil Unloading: Scraper 1.48 1.48 

Grading: Coal/OB Haul Roads 6.03 0.60 

Coal/Overburden Truck Hauling 87.95 8.79 

Light Duty Vehicle Traffic 2.05 0.20 

Wind Erosion 196.84 29.53 

TOTAL 590.71 90.94 

2-5 
 

 

 

 

2.2 Combustion Emissions (NOX, SO2, CO, and VOCs) 

Combustion emissions include consumption of diesel fuel in mining equipment and 

trucks along with emissions from blasting. Except for emissions from blasting, these emissions 

are not regulated by CDPHE Air Pollution Control Construction Permits and emissions from 

these sources are not counted against permit limits. Blasting emissions are limited in Permit 

11MF253-1 by limiting the annual quantity of explosives used at Trapper Mine (13,500 tons per 

year). Whether or not such emissions are regulated under Permit 11MF253-1, all combustion 

emissions were quantified for the EA and such emissions were included in the air dispersion 

modeling to verify compliance with air quality standards. 

Emissions for mining equipment/trucks were calculated with the MOVES2014 model 

(USEPA 2014) using the most relevant equipment listed under the “nonroad construction” 

category and TMI-provided data listing the annual operating time (hours) for each major piece of 

mining equipment and/or truck. Blasting emissions were calculated using the emissions factor 

from AP-42 Chapter 13, Table 13.3-1 with the anticipated use of explosives (ANFO) and the 

expected number of blasts during the worst-case year (2020). 

The combustion emissions are documented in Table 2-5, reported in units of tons per 

year (tpy). Emissions are reported in Table 2-5 for NOx, SO2, CO, and VOCs. PM10 and PM2.5 

emissions associated with blasting are already quantified in Table 2-4. Also, any PM10 and 

PM2.5 emissions associated with fuel combustion in trucks and mining equipment are already 

included as part of the applicable fugitive dust calculations for truck traffic summarized in Table 

2-4. Calculations for hazardous air pollutant (HAP) emissions associated with fuel combustion 

in the mining equipment and trucks are reported in Table 2-6, also in tpy. All fuel combustion 

and blasting calculations are documented on digital spreadsheets available by CD upon request. 

Table 2-5
 

Direct Mining Emissions for Worst-Case Year (2020): Fuel Combustion and Blasting
 

NOX (tpy) SO2 (tpy) CO (tpy) VOCs (tpy) 

Fuel Combustion: Mining 987 52 378 72 Equipment & Trucks
 

Blasting
 74 9 291 No Data 

TOTAL 1,061 61 669 72 

2-6 
 

 

 

Table 2-6
 

Direct Mining Emissions for Worst-Case Year (2020)
 

Hazardous Air Pollutants – Fuel Combustion (tpy)
 

Benzene Toluene Xylene 1,3-Butadiene Formaldehyde Acetaldehyde Acrolein Napthalene 

0.41 0.15 0.11 0.02 0.13 0.07 0.01 0.06 

As noted above, PM10 and PM2.5 emissions associated with blasting and fuel combustion 

are included within the emissions factors in Table 2-2 and the total emissions shown in Tables 

2-3 and 2.4. The fuel combustion contribution to PM10 and PM2.5 emission totals is small 

compared to the fugitive dust totals for PM10 and PM2.5 emissions. 

2.3 Black Carbon Emissions 

Black carbon is a subset of the PM10/PM2.5 emissions associated with diesel fuel 

combustion. Black carbon is effective at absorbing light and has a disproportionally larger 

impact on visibility degradation compared to other forms of particulate matter. Some researchers 

also link black carbon emissions to climate-related air quality impacts. 

Black carbon has been calculated as a percentage of the PM2.5 emissions associated with 

diesel fuel combustion based on Cai and Wang (2014). The calculated black carbon emissions 

based on diesel fuel consumption from the worst-case year (2020) is provided in Table 2-7. 

Table 2-7
 

Direct Mining Related Emissions for Worst-Case Year (2020) – Black Carbon (tpy)
 

PM2.5 Black Carbon Ratio Black Carbon Emissions 

64 tpy 0.813 52 tpy 

2-7 
	 


 


 


 

----------------------------------------------- --------------- --------------------------------

3.0	 EMISSIONS INVENTORY FOR INDIRECT IMPACTS ASSOCIATED WITH 

COAL COMBUSTION 

Indirect impacts associated with coal combustion include emissions at the Craig Station 

from combustion of coal to generate electricity. Based on the CDPHE-issued Title V operating 

permit (CDPHE, 2005), the Craig Station includes three coal-fired EGUs, with a combined net 

electric generating capacity of 1,264 MW. Unit 1 was placed in service in 1980, Unit 2 in 1979, 

and Unit 3 in 1984. Coal from the Trapper Mine is used almost exclusively at Units 1 and 2 and 

coal from other sources is fired in Unit 3. The emission controls at the Craig Station are 

summarized in Table 3-1. 

Table 3-1 

Summary of Air Emission Controls – Craig Generating Station 

Unit 1 Unit 2 Unit 3 

Capacity (Net) 428 MW 428 MW 408 MW 

In-Service Date 1980 1979 1984 

Particulate Matter Fabric Filter Baghouse Fabric Filter Baghouse Fabric Filter Baghouse 

SO2 Wet Limestone Scrubber Wet Limestone Scrubber Spray Dryer Absorber 

(Dry Scrubber) 

Low NOX Burners with Low NOX Burners with Low NOX Burners with 

Overfire Air Overfire Air Overfire Air 

Add SCR by 2021 to 

NOX meet emission limits of 

the Colorado Regional 

Add SCR by 2018 to 

meet emission limits of 

Add SNCR by 2018 to 

meet emission limits of 

Haze State the Colorado Regional the Colorado Regional 

Implementation Plan Haze SIP. Haze SIP. 

(SIP). 

Ancillary control Ancillary control 

Mercury provided by existing 

systems for other 

provided by existing 

systems for other 

Activated Carbon 

Injection 

pollutants pollutants 

In addition, Craig Station places some of its fly ash and bottom ash (e.g., coal combustion 

residuals or CCRs) at the Trapper Mine. Some of the CCRs are shipped off-site for beneficial 

uses and the remainder are placed in former mining pits at the Trapper Mine. The CCRs 

transport and placement emissions for the fraction handled at Trapper Mine are included in the 

indirect air quality impacts because the placement activities occur within the Trapper Mine 

SMCRA permit boundary but outside of the Project Area. These emissions would include 

fugitive dust emissions (PM10 and PM2.5) associated with the CCRs hauling by truck to the 

placement site, and associated diesel fuel combustion emissions from the trucks, including GHG 

emissions. 

The fugitive dust emissions associated with CCRs placed at Trapper Mine are regulated 

under the current air permit (Permit 11MF253-1). 

3-1
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

3.1	 Indirect Criteria Pollutant Emissions from Electricity Generation 

(SO2, NOX, CO, and VOCs) 

Coal combustion for generation of electricity produces air emissions. The indirect 

emission calculations were not based on a specific worst-case year, but were instead estimated 

based on coal combustion at Craig Station Units 1 and 2 for the maximum coal production rate 

under Trapper’s air permit, or 2.6 mtpy. 

As described previously, coal from the Trapper Mine is used almost exclusively at Craig 

Units 1 and 2. Where supported by reliable technical information, emissions data unique to Units 

1 and 2 were used to help estimate the Trapper Mine-related indirect emissions. 

A summary of Craig Station indirect emissions is provided in Table 3-2. These 

calculations are based on the maximum Trapper coal production rates of 2.6 mtpy and do not 

represent any particular year of operation. 

For the SO2 and NOX calculations, unit-specific emissions data for 2014 were obtained 

for the Craig Station from the USEPA Air Markets Program Data (AMPD). Based on these data, 

it is evident that the level of SO2 emissions control at Units 1 and 2 is significantly better than 

Unit 3. The AMPD data show that more than 50 percent of the total SO2 emissions at Craig 

Station during 2014 were from Unit 3. As described above, Units 1 and 2 control SO2 through a 

wet scrubber while Unit 3 uses a spray dryer absorber. NOX emissions control may be better at 

Units 1 and 2 (estimated 45 – 65% control efficiency) compared to Unit 3 (estimated 35 – 55% 

control efficiency), although the differences in NOx emissions are not as dramatic as the unit-tounit variation in SO2 emissions. 

Table 3-2 

Indirect Coal Combustion Emissions: Craig Generating Station (tpy) 

SO2 Emissions NOX Emissions 

Unit 1 Unit 2 Unit 3 Unit 1 Unit 2 Unit 3 CO VOCs PM10 PM2.5 

Craig 

Emissions Total 

(2014) 

799.02 963.36 2,000.90 3,768.07 4,603.28 5,367.91 110.0 68.5 

Trapper 

Contribution 

(78.67%) 

628.59 757.88 -­ 2,964.34 3,621.40 -­ 86.5 53.9 

Trapper 

Contribution 

Adjusted to 

2.6 mtpy 

710.58 856.73 -­ 3,350.99 4,093.76 -­ 650.0 78.0 97.8 60.9 

Note: PM10 and PM2.5 emissions are the total for Units 1 and 2 as reported on the Tri-State 

Generation and Transmission APEN for the 2014 calendar year. 

3-2 
 

 

 

 

 

 

 

 

 

 

The USEPA AMPD database lists SO2 and NOX emissions, but not emissions for CO and 

VOCs. The SO2 and NOX estimate were based on the reported 2014 emissions at Craig Station 

Units 1 and 2, adjusted to a coal consumption level of 2.6 mtpy, as explained below. The AMPD 

data are documented in digital files available by CD upon request. 

Trapper Mine contributes about 50 percent of the coal used at Craig Station. In 2014, the 

total coal consumption for Craig Station was estimated to be about 4.6 mtpy, which means that 

Trapper Mine contributed 2.3 mtpy. Based on 2014 load data reported to the AMPD database, 

Units 1 and 2 represented 63.56 percent of the total electric load generated at Craig Station. 

Assuming that the load and coal consumption are related, then, the overall coal consumption at 

Units 1 and 2 would have been 2.92 mtpy in 2014 (63.56 percent of 4.6 mtpy). Using this figure, 

the 2.3 mtpy contributed by Trapper Mine would have been 78.67 percent of the overall coal 

consumption at Units 1 and 2. This fraction was used to estimate the appropriate level of 2014 

Craig Station Unit 1 and Unit 2 emissions assigned to coal sourced at TMI. The 2014 emissions 

assigned to coal sourced at TMI at a rate of 2.3 mtpy were then adjusted to the maximum 

allowable mining rate of 2.6 mtpy. 

For CO and VOCs, Craig Station emissions were based on data listed in AP-42 Section 

1.1.1 (Coal Combustion). The AP-42 factors (CO = 0.5 lb/ton, VOC = 0.06 lb/ton) were applied 

to the 2.6 mtpy mining rate to derive the indirect emissions information for these pollutants. For 

PM10 and PM2.5, these emissions data were extracted from Air Pollution Emission Notices 

(APENs) for Craig Units 1 and 2 submitted by Tri-State Generation and Transmission to 

CDPHE. The APEN data report the total PM10 and PM2.5 emissions for each unit during 

Calendar Year 2014. The reported APEN emissions were extrapolated to derive the Unit 1 and 2 

PM10 and PM2.5 emissions for that portion of emissions attributable to TMI coal using a 

consumption rate of 2.6 mtpy. The Craig Unit 1 and Unit 2 PM10 and PM2.5 emissions were 

adjusted following the same procedure that was described above for SO2 and NOx emissions. 

Based on the above data, the Craig Station emissions associated with Trapper Mine coal 

at a 2.6 mtpy mining rate would be: SO2 – 1,567 tpy, NOX – 7,445 tpy, CO – 650 tpy, VOCs – 

78 tpy, PM10 – 97.8 tpy, and PM2.5 – 60.9 tpy. 

Please note that the NOX emissions estimates shown in Table 3-2 do not include the 

expected future benefits of improved emissions controls at Craig Station. Both Unit 1 and Unit 2 

plan to install selective catalytic reduction (SCR) for NOX emissions control to meet the 

emission limits contained in the Colorado Visibility and Regional Haze SIP (CDPHE 2014a). 

The SIP specifies the required NOX emissions limits and the owner/operator (Tri-State 

Generation & Transmission) then selects the appropriate pollution control technology to achieve 

the required emission limits (See Table 3-1). 

The SCR NOx control is scheduled to be installed and operational by 2018 at Unit 2 and 

by 2021 at Unit 1. Based on the SIP, Unit 1 will have a maximum allowable NOX limit of 0.07 

lb/million British thermal unit (MMBtu) and Unit 2 will have a maximum allowable NOX limit 

of 0.08 lb/MMBtu. CDPHE (2014a) lists the baseline NOX emissions level for Units 1 and 2 at 

0.35 lb/MMBtu, so the reduction in NOX would be on the order of 80 percent at each unit, for a 

total reduction of about 8,000 tpy. The reductions attributable to Trapper Mine coal would be a 

3-3 
 

 

 

 

 

 

 

fraction of the total Unit 1 and 2 reductions, or about 6,300 tpy, leaving post-control indirect 

NOX emissions of 1,145 tpy. 

3.2 Mercury Emissions from Electricity Generation 

The CDPHE has provided mercury emissions data for Craig Station for the 2014 

reporting year (Tri-State Generation and Transmission Association 2015). These Craig Station 

mercury emissions data are based on continuous emissions monitoring system equipment 

installed at each Craig Station unit. 

The Craig Station is generally recognized to have one of the lower mercury emission 

rates for electric generating units in the United States. Based on 2009 mercury emissions data 

compiled by Environmental Integrity Project (2011), Craig Station was ranked second-lowest at 

the time among U.S. coal-fired power plants in terms of mercury emissions per unit of electrical 

generation output, expressed as lbs per GW-hr. The 2014 mercury emissions data for Craig 

Generating Station are summarized in Table 3-3. 

Table 3-3
 

Actual 2014 Craig Generating Station
 

Mercury Emissions (lb/yr) as reported by Craig Station to CDPHE
 

Unit 1 4.41 

Unit 2 4.85 

Unit 3 33.69 

Total 42.95 

In the CDPHE mercury emissions reports, data for Units 1 and 2 are reported in terms of 

mass (lb/yr) and these data are reported directly in Table 3-3. The Unit 3 mercury data were 

calculated using data in the CDPHE mercury emission reports. The Unit 3 mercury emissions 

rate (0.009 lb/GW-hr) was converted to total mass (lb/yr) using the Unit 3 2014 production data 

listed in the AMPD database and described in the prior section. The total mercury emissions 

derived here (about 43 lb/yr) are consistent with the Craig Station mercury emissions listed in the 

2014 USEPA Toxic Release Inventory. 

The Craig Station emissions monitoring data show that mercury emissions are 

substantially less at Unit 1 and Unit 2 compared to Unit 3. This is most likely due to the 

differences in pollution control systems at the three Craig Station units. As described previously, 

Units 1 and 2 each use wet scrubbing systems for SO2 emissions control, compared to a spray 

dryer absorber (dry scrubbing) at Unit 3. Wet scrubbing systems have been shown to be very 

effective at providing ancillary control benefits for mercury emissions. This is because the 

oxidized form of mercury (Hg2+) is water soluble and can be easily removed by the wet scrubber 

technology. Even though Unit 3 does not reduce mercury to the same level of effectiveness as 

Units 1 and 2, the Unit 3 mercury emissions are still well below the maximum allowable limits 

established by Colorado state regulation. 

3-4 
 

 

 

 

 

 

As described in the indirect emission calculations for SO2 and NOX (See Section 3.1), 

Trapper Mine contributes about 50 percent of the total coal consumed at Craig Station. In 2014, 

the coal consumption for Craig Station was estimated to be about 4.6 mtpy, which means that 

Trapper Mine contributed 2.3 mtpy. However, Trapper Mine coal is almost exclusively used at 

Units 1 and 2. Based on the 2014 load data reported to the AMPD (described in TSD Section 

3.1), Units 1 and 2 combined represented 63.56 percent of the total electric load generated at 

Craig Station. If the load and coal consumption are assumed to be related, then the coal 

consumption at Units 1 and 2 would have been 2.92 mtpy in 2014 (63.56 percent of 4.6 mtpy). 

Using this figure, the 2.3 mtpy contributed by Trapper Mine would have been 78.67 percent of 

the overall coal consumption at Units 1 and 2. 

Applying the 78.67 percent factor to the reported 2014 mercury emissions, the Trapper 

contribution to the Craig mercury emissions at Units 1 and 2 can be calculated. Then, the last 

step for the mercury emissions analysis is to adjust the estimate to the maximum Trapper Mine 

coal production rate of 2.6 mtpy. 

As summarized in Table 3-4, the above calculations derive 8.23 lb/yr as the indirect 

mercury emissions rate derived from combustion of 2.6 mtpy of Trapper Mine coal at Craig 

Station Units 1 and 2. 

Table 3-4 

Craig Generating Station Mercury Emissions from Trapper Mine Coal (lb/yr) 

Mercury Emissions for Trapper Mine 

2014 Consumption Rates (2.3 mtpy) 

Mercury Emissions at Maximum Trapper Coal 

Consumption Rates 

(2.6 mtpy) 

Unit 1 3.47 3.92 

Unit 2 3.82 4.31 

TOTAL 7.29 8.23 

The associated environmental impacts from these mercury emissions are described in the 

Special Status Species Section of the EA. 

3.3 Coal Combustion Residuals Placement at Trapper Mine 

The delivery and placement of coal combustion residuals or ash at Trapper Mine is 

characterized as an indirect emission because placement occurs in areas outside of the Project 

Area (defined as the area covered by the coal leases). TMI receives a fraction of the fly 

ash/bottom ash from Craig Station for placement, with the remainder shipped off-site for 

beneficial use. The emission calculations address the CCRs returned to Trapper Mine for 

placement, regardless of the origin of the coal. The annual CCRs volume returned to TMI for 

placement was estimated at 507,000 tpy and this figure was used to estimate the indirect 

emissions linked to CCRs placement at Trapper Mine. 

3-5 
 

 

 

 

 

 

 

 

PM10 and PM2.5 emissions are principally fugitive dust from truck traffic carrying the 

CCRs from Craig Station to the placement site at Trapper Mine. Other emissions include 

bulldozing, wind erosion, and exhaust emissions associated with the diesel fuel combusted by the 

haul trucks. Again, any PM10 and PM2.5 associated with the fuel combustion in the CCRs truck 

fleet is captured in the fugitive dust emissions factor and is not quantified separately. Table 3-5 

summarizes the indirect PM10 and PM2.5 emissions associated with the coal combustion residuals 

placement. 

Table 3-5
 

Indirect PM10 and PM2.5 Emissions from
 

Coal Combustion Residual Placement at Trapper Mine
 

PM10 (tpy) PM2.5 (tpy) 

Ash/Sludge Hauling: Truck Traffic 7.85 1.38 

Ash Bulldozing 1.16 0.35 

Wind Erosion 3.80 0.57 

TOTALS 12.81 2.30 

The fuel combustion for haul trucks that transport the CCRs to the Trapper Mine 

placement site also releases pollutants such as NOX, SO2, CO, and VOCs. These emissions were 

calculated using the USEPA MOVES2014 model (USEPA 2014) and estimated operating time 

for the trucks. The relevant emissions are summarized in Table 3-6. 

Table 3-6
 

Indirect Emissions for Worst-Case Year (2020) Fuel Combustion:
 

Coal Combustion Residuals Transfer by Truck to Trapper Mine
 

NOX (tpy) SO2 (tpy) CO (tpy) VOCs (tpy) 

Fuel Combustion: Coal Combustion 

Residuals Haul Trucks 12.1 1.5 5.15 0.7 

The calculations for the CCRs fugitive dust and diesel fuel combustion emissions are 

documented in electronic spreadsheets available by CD upon request. 

3-6 
 

4.0 DISPERSION MODELING ANALYSIS FOR DIRECT AND INDIRECT 

TRAPPER MINE EMISSIONS 

An air dispersion modeling analysis was conducted to assess the air quality impacts 

associated with the Trapper Mine EA Proposed Action against the National Ambient Air Quality 

Standards (NAAQS). The modeling analysis was based on the emissions calculated for the 

Proposed Action for the future “worst-case year”, which as described earlier, was determined to 

be 2020. 

4.1 Modeling Overview 

The air quality modeling analysis was conducted using the USEPA AERMOD dispersion 

model – Version 15181 (USEPA, 2004). AERMOD is the standard air dispersion model 

recommended by the US Environmental Protection Agency (USEPA) for use in regulatory 

actions such as permitting. The AERMOD modeling for the Trapper Mine EA generally 

followed the recommendations in USEPA’s Guideline for Air Quality Models (USEPA, 2005a) 

and USEPA’s current AERMOD Implementation Guidance (USEPA, 2015a). Recommended 

regulatory defaults were used for all AERMOD model inputs unless otherwise described in the 

discussion below. 

One of the basic inputs to AERMOD is meteorological information (wind speed, wind 

direction, temperature, etc.). In the Trapper Mine EA modeling analysis, the AERMOD 

modeling was performed using two different meteorological data sets. One data set was the onsite monitoring data collected at Trapper Mine for the period March through September 2015. 

However, as the Trapper Mine on-site data do not span a full 12-month period, a second more 

complete dataset was also used. The CDPHE was solicited to recommend the alternate 

meteorological data, and CDPHE provided data collected at the Colowyo Mine Gossard 

monitoring site during 2012 (CDPHE, 2015a). The Gossard monitoring site is located at Latitude 

40.313 N and Longitude 107.799 W at an elevation of 6,325 feet. 

Wind roses showing the Trapper on-site monitoring data and the Gossard monitoring data 

are shown in Figure 4-1 and Figure 4-2. Both wind roses show similar wind patterns, with the 

predominant winds from the south through southwest. 

4-1 
Figure 4-1: Trapper Mine On-Site Wind Rose 

4-2 
Figure 4-2: Gossard Wind Rose 

4-3 
 

 

 

Both the Trapper on-site data and Gossard data were processed using the USEPA 

AERMET program (Version 15181) following current regulatory recommendations and 

recommended regulatory data defaults. The Gossard data covers January 1 through December 

31, 2012 and the Trapper on-site data covers the partial year period March 11 through September 

30, 2015. Upper air data for these time periods from the closest National Weather Service 

(NWS) upper air monitoring station (Grand Junction, CO) were also used in AERMET. 

Supplemental meteorological data for AERMET were taken from the Craig-Moffat County 

Airport for these same time periods to substitute for any missing data from either monitoring site. 

Any wind velocity under 0.5 m/sec was considered to be “calm”. 

AERMET requires land use characteristics to properly define surface characteristics such 

as albedo, Bowen ratio, and surface roughness length within the meteorological data file. The 

current AERSURFACE processor was used to derive these data parameters based on the four 

seasons and twelve 30 degree sectors across an area centered on a 1 km circle surrounding each 

meteorological monitoring site (Gossard and Trapper On-Site). 

Once the modeling was conducted, it was observed that the Gossard meteorological data 

consistently returned higher AERMOD model predictions compared to the on-site Trapper data. 

4.2 Technical Approach 

4.2.1 Receptor Information 

The AERMOD model calculations are performed at “receptors”, which are defined 

geographic locations where the public has access. Locations within the Trapper Mine permit 

boundary are not accessible to the public and as such, model receptors are excluded from these 

locations. 

Because emissions at a surface mine are released at or near the ground, the expectation is 

that the maximum predicted model impacts would occur at or near the Trapper Mine permit 

boundary. Only if the emissions are elevated would the modeling predict maximum impacts 

downwind of the permit boundary. In fact, once the AERMOD modeling was completed, it was 

confirmed that the maximum impacts for all pollutants did in fact occur at or near the Trapper 

Mine permit boundary. 

Given this expected behavior, the AERMOD receptors were placed at 100 meter intervals 

along the TMI permit boundary and out to a distance of approximately 500 meters downwind of 

the boundary. The selected receptor density was 100 meters, i.e., receptors were placed using a 

rectangular grid pattern with the separation between receptors of 100 meters. More receptors 

were placed along and near the north and east permit boundary as the emission sources at 

Trapper Mine tended to be clustered near those areas of the mine. 

4-4 
 

 

 

 

A map showing the AERMOD receptor locations around the Trapper Mine is provided in 

Figure 4-3. Please note that any property internal to Craig Station is treated as ambient air in the 

Trapper Mine modeling study, consistent with EPA/CDPHE guidelines given that Craig Station 

employees are treated as the “public” for the purposes of Trapper Mine. However, the general 

public does not have access to property within the Craig Station fenceline. 

Figure 4-3: AERMOD Receptor Map – Trapper Mine EA Modeling 

4.2.2 Background Concentrations 

Background is how the model accounts for those emissions not explicitly included in the 

modeling inputs and is used to generate the “cumulative impact” from all emission sources. For 

background, recommendations were provided by CDPHE (2015b) for each of the pollutants and 

averaging times of concern. The recommended CDPHE background values were based on 

nearby ambient air monitoring data collected in northwest Colorado. Table 4-1 summarizes the 

background concentration values recommended by CDPHE and also includes the source/year for 

the nearby monitoring data used to assign the background value. In some cases, the background 

values were provided in units of parts per million (ppm) or parts per billion (ppb), so the table 

also displays the background concentration after being converted to the appropriate modeling 

units (micrograms per cubic meter or μg/m3

). 

4-5 
 

 

 

 

 

Table 4-1 

Recommended Background Concentration Values from CDPHE
 

Pollutant Averaging 

Time 

CDPHE-provided 

Background 

Background 

Concentration 

(micrograms per cu 

meter) 

Monitoring Site 

& Data Year 

CO 

1-hour 1 ppm 1,145 

Williams Willow Creek, 2012 

8-hour 1 ppm 1,145 

SO2 1-hour 1 ppb 2.62 Williams Willow Creek, 2012 

NO2 

1-hour 7 ppb 13.16 

Williams Willow Creek, 2012 

Annual 1 ppb 1.88 

PM10 24-hour 23 μg/m3 23 ColoWyo West, 1997-98 

PM2.5 

24-hour 14 μg/m3 14 

Williams Willow Creek, 2012 

Annual 3 μg/m3 3 

The background concentrations listed above for each pollutant and averaging time were 

added to the AERMOD concentration results for determination of the cumulative impacts and for 

comparison to the NAAQS. 

4.2.3 Emissions Information 

This section summarizes how the Trapper Mine emissions information was input to the 

modeling. The emissions data for the 2020 worst-case modeling year are summarized in 

Chapters 2 and 3 of the TSD. The modeling analysis included the direct emissions associated 

with mining activities and the indirect emissions associated with CCR transfer and placement to 

the extent that the modeled indirect emissions occur within the Trapper Mine permit boundary. 

Emissions associated with the Craig Generating Station were included in the modeling analysis 

through the background concentrations. 

In the AERMOD modeling, emissions were assigned as either occurring in the mining pit 

or along the coal/ash haul roads. In cases where travel occurs internal to the mining pit (such as 

overburden hauling), these emissions were assigned to the pit. Road emissions included the 

following category of emissions: coal haul trucks, ash haul trucks, light-duty vehicles, and road 

graders. All other emissions were assigned to the mining pit or ash placement area as 

appropriate. The emissions layout for the 2020 worst-case year modeling is shown in Figure 4-4. 

4-6 
 

 

Figure 4-4: Geographic Allocation of Emissions during Worst-Case Year (2020) 

The road locations were modeled based on the existing road locations as determined 

using digital images of the Trapper Mine, i.e., Google Earth. Please note that the coal haul road 

between Trapper Mine and Craig Station is a private road with no access by the general public. 

For the worst-case year (2020), the proposed N pit will bisect the haul road leading from L Pit 

back to the Craig Station, so the L Pit coal haul road will be relocated to the north in order to 

bypass N Pit. TMI defined the expected future haul road location through this region for input to 

the model. 

Each road segment was assigned the appropriate level of emissions based on the expected 

traffic volume and type of truck traffic along that particular road segment (coal truck vs. ash 

truck). Each segment was assigned a color for tracking the associated emissions (black, red, 

green, or blue....See Figure 4-4). The allocation of the haul road emissions along each segment 

and the related volume source release parameters are described in Table 4-2. 

4-7 
 

 

 

 

 

 

 

 

 

Table 4-2
 

Volume Source Emissions and Data Parameters for Trapper Mine Haul Road Emissions
 

Source 

Description # of segments 

Release 

Height 

(above 

ground) 

Initial 

Sigma Y 

Initial 

Sigma Z 

PM10 

Emissions 

PM2.5 

Emissions 

m m m tpy/segment tpy/segment 

L Pit Haul 

Road (Blue) 301 5.848 19.53 5.44 0.197 0.049 

N Pit Haul 

Road (Green) 76 5.848 19.53 5.44 0.024 0.004 

Ash Haul 

Road (Red) 91 5.848 19.53 5.44 0.060 0.010 

Combined 

Haul Road 

(Black) 

85 5.848 19.53 5.44 0.280 0.064 

The haul road sources were modeled using the “volume source” option in AERMOD and 

current recommendations for modeling emissions from haul roads (USEPA, 2011). The 

horizontal dimension for the volume source (initial sigma-y) was based on the road width plus a 

small buffer to account for the lateral air displacement generated by the passing truck. The 

vertical dimension for the volume source (initial sigma-z) was assigned based on 1.7 times the 

truck height, with the release height at the mid-point of the volume. The 90-ton coal haul truck 

dimensions were used for these calculations as the coal haul trucks comprise most of the road 

traffic emissions. 

For the mining pits and ash placement areas, the “area poly source” option in AERMOD 

was employed. The “pit source” option within AERMOD was considered for the Trapper Mine 

modeling analysis, but not selected. At TMI, the mining pit is not the classic “hole-in-the 

ground” simulated by AERMOD’s pit source option to calculate the retention of particulate 

emissions within the pit. At TMI, the mining pit instead carves into the side of the hill, and the 

pit is relatively open to the north, which is also the direction of the prevailing winds. As the 

mining pit generally lacks a well-defined wall on the downwind side, the pit retention 

calculations in AERMOD’s pit source option were not believed to be technically appropriate. 

Instead, the “area poly source” option was selected and pit retention of PM emissions was not 

modeled. 

As mentioned previously, the mining operations in the worst-case year (2020) cover two 

separate mining pits. L Pit is the current mining pit at Trapper, but by 2020 has progressed from 

its current location to the east (See Figure 4-4). However, by 2020, L Pit is nearing the end of its 

reserves, so by 2019, TMI is starting to mine its coal reserves in N Pit. The initial mining in the 

N Pit is outside of the Project Area. Emissions were assigned between the two pits based on the 

activity levels for each pit as estimated by TMI for the worst-case year. These data are provided 

in various electronic spreadsheets available by CD upon request. 

4-8 
 

 

 

 

 

 

 

 

 

Within AERMOD, L Pit (blue...See Figure 4-4) was characterized as four area-poly 

sources and N Pit (green...See Figure 4-4) was characterized as two area-poly sources. Within 

each pit, each area-poly source was approximately of equal dimensions (area). However, since 

the overburden stripping ratios increase as one moves further south in both pits, a higher fraction 

of the pit emissions were assigned to the southernmost area-poly sources in each pit. 

The area-poly source locations were assigned based on the expected disturbance areas for 

Year 2020 as defined by Trapper’s mining plans, plus the projected disturbance areas for the year 

prior and also the preceding year, i.e., Years 2019-2021. The three year period accounts for land 

disturbance generated during the 2020 worst-case year from pre-stripping and from 

backfilling/reclamation. 

It is also necessary to properly simulate the vertical distribution of emissions within the 

mining pit. The vertical distribution of emissions can be large given the vertical separation 

between the pit floor and the top of the pit and not properly simulating the vertical distribution of 

pit emissions could lead to serious errors in the AERMOD results. The “area poly source” option 

includes an optional vertical dimension value (initial sigma-z), which in essence turns the twodimensional area-poly source into a three-dimensional pseudo-volume source. The vertical 

separation distance between the pit floor and the top of the pit was used to assign the vertical 

dimension value in AERMOD. This value was larger for those area sources at the south end of 

the pit where the pit walls are higher. The base elevation for all pit sources within a given pit (L 

Pit and N Pit) was assigned a single value, which assumes that the pit floor remained at a 

constant elevation for all pit area-poly sources. The source release height also considers the 

vertical distribution of the in-pit emissions, given that all pit sources were assigned the same base 

elevation. The release height was set at 25% of the vertical separation between the pit floor and 

the top of the pit, which skewed the majority of the emissions toward the bottom of the pit and is 

a conservative assumption in terms of the AERMOD modeling. The selected modeling approach 

recognizes that the location of individual emission sources within the pit are likely to vary over 

the year being simulated, such that a precise placement of each individual emission source within 

the pit area (e.g., haul road, dragline, etc.) is not practical. Any such placement of emission 

sources for the purpose of modeling would only be valid for a fixed point in time and would not 

represent the worst-case year as a whole. 

Lastly, the PM10/PM2.5 emissions inventory for the pit sources showed that wind erosion 

was a significant contributor to the total emissions. Wind erosion emissions do not occur 

continuously, but instead only occur during period of high wind velocities. This effect was 

simulated in the AERMOD model by restricting the wind erosion emissions to those hours of 

where the wind speed exceeded the defined threshold velocity - approximately 12 miles per hour. 

Table 4-3 shows the emissions distributions and area-poly source parameters for the pit 

emission sources. 

4-9 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 4-3 

Area-Poly Source Emissions and Data Parameters for Trapper Mining Pits
 

Source ID Base 

Elevation 

Release 

Height 

# Vertices Initial 

Vertical 

Dimension 

PM10 

Emissions 

PM2.5 

Emissions 

Area 

m m m tpy/ft^2 tpy/ft^2 ft^2 

LPIT1 2112.68 15 4 32.25 9.45E-06 2.94E-06 3,064,191 

LPIT2 2112.68 27.5 4 59.13 2.11E-05 6.56E-06 2,743,601 

LPIT3 2112.68 40 4 86 3.12E-05 9.71E-06 2,781,169 

LPIT4 2112.68 40 4 86 4.15E-05 1.29E-05 2,787,479 

NPIT1 2001.89 12.5 4 26.875 7.72E-06 1.39E-06 1,515,810 

NPIT2 2001.89 10 4 21.5 2.02E-05 3.63E-06 1,351,211 

ASH 2144.74 10 8 9.3 2.97E-05 1.44E-06 765,753 

LPITWIND1 2112.68 15 4 32.25 1.85E-05 2.81E-06 3,064,191 

LPITWIND2 2112.68 27.5 4 59.13 1.85E-05 2.81E-06 2,743,601 

LPITWIND3 2112.68 40 4 86 1.85E-05 2.81E-06 2,781,169 

LPITWIND4 2112.68 40 4 86 1.85E-05 2.81E-06 2,787,479 

NPITWIND1 2001.89 12.5 4 26.875 3.36E-05 5.10E-06 1,515,810 

NPITWIND2 2001.89 10 4 21.5 3.36E-05 5.10E-06 1,351,211 

ASHWIND 2144.74 10 8 9.3 2.43E-06 3.68E-07 765,753 

4.2.4 Particle Deposition 

For the PM10/PM2.5 modeling, the particle deposition options in AERMOD were 

employed. With particle deposition, some of the plume mass is lost during transport downwind 

due to the fact that particles can fall from the plume and adhere to the ground and/or vegetation. 

Larger sized particles are deposited at a faster rate than smaller particles. 

For the Trapper Mine modeling, the PM10 emissions were classified as either “coarse” or 

“fine” based on the particle size and the emissions inventory. The coarse fraction represents 

those particles larger than PM2.5, but smaller than PM10. The coarse particles were assigned a 

mean diameter of 6.25 microns, which is the middle of the size range (2.5 to 10 microns). The 

fine fraction represents those particles smaller than PM2.5, and were assigned a mean diameter of 

1.25 microns, again based on the midpoint of the size range (0 to 2.5 microns). The emissions 

inventory was used to assign the mass fraction to each category (coarse vs. fine). The assigned 

mass fraction varied depending on whether the emissions being modeled were from the road 

volume sources or the pit area-poly sources. The particle size data input to AERMOD are shown 

in Table 4-4. 

4-10 
 

 

 

 

 

 

 

Table 4-4 

AERMOD Particle Size Data for PM10 Deposition Modeling
 

Pollutant Group Name Diameter 

[microns] 

Mass Fraction for 

listed size category Density [g/cm^3] 

PM10 

Roads 

1.25 0.2 2.2 

6.25 0.8 2.2 

N –PIT 

1.25 0.25 2.2 

6.25 0.75 2.2 

L-PIT 

1.25 0.21 2.2 

6.25 0.79 2.2 

ASH 

1.25 0.128 2.2 

6.25 0.872 2.2 

WIND 

6.25 0.872 2.2 

1.25 0.132 2.2 

PM2.5 ALL 1.25 1 2.2 

As noted in Table 4-4, PM2.5 emissions were also modeled using deposition. However, 

for the PM2.5 modeling, the only classification was the “fine” category and 100% of the PM2.5 

emissions were assigned to this size category. 

4.2.5 Ozone Limiting Method 

For the NO2 modeling only, AERMOD was employed using the “ozone limiting method” 

option. When this option is applied, the chemical conversion of NOX emissions to the regulated 

form, nitrogen dioxide (NO2), is assumed to be limited by the available ozone (O3) in the 

atmosphere. The atmospheric conversion to NO2 is assumed to occur by the following reaction: 

NO + O3  NO2 + O2 

The inputs to the ozone limiting method are the fraction of NOX emissions released as 

NO2 and the background ozone concentrations. The NO2 fraction of emissions from diesel-fired 

equipment and trucks was derived using data generated by Caterpillar (2011), where it was stated 

that the NO2 emissions fraction for Caterpillar’s diesel-fired equipment was in the range of 5­

15%. The mid-range of 10% was used for the Trapper Mine NOX emissions modeling analysis. 

For the background ozone levels, monitored ozone data from the CDPHE Lay Peak 

ozone monitoring site located near Maybell (west of Craig) was used to develop a conservative 

seasonal/diurnal ozone concentration profile. For each month of data (January through 

December), a diurnal (24-hour) ozone concentration profile was developed using the peak 

monitored monthly ozone concentration for that hour (See Table 4-5). 

This approach for identifying the background ozone concentrations retains some 

conservatism in the OLM analysis because the peak ozone concentration in any month would 

overestimate the background level during most hours, and the resulting NO2 model prediction 

would be higher, i.e., conservative. 

4-11 
 

 

Table 4-5 

Seasonal/Diurnal Ozone Profile for OLM
 

Ozone Concentrations in parts per billion (ppb)
 

Hour Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 

0 40 43 49 59 65 57 49 55 42 44 44 42 

1 39 42 50 57 60 60 48 52 41 43 44 41 

2 39 43 50 55 57 59 46 48 37 41 43 41 

3 38 46 49 55 54 58 42 47 39 39 41 42 

4 38 48 49 55 56 58 39 47 38 41 40 40 

5 39 47 48 52 54 51 41 48 38 41 39 40 

6 40 46 48 56 50 53 44 47 41 41 38 41 

7 40 45 48 63 57 57 44 48 34 40 38 40 

8 41 45 50 64 62 59 52 51 46 42 41 40 

9 41 46 56 68 63 62 58 61 54 43 45 41 

10 41 47 57 73 65 63 61 61 54 47 44 42 

11 41 48 69 72 67 72 67 66 57 51 47 43 

12 42 49 58 73 67 66 68 69 58 50 49 45 

13 45 51 59 72 68 64 68 72 58 53 50 44 

14 45 52 58 70 70 64 66 72 59 53 50 44 

15 46 51 60 70 68 65 65 74 60 53 50 46 

16 44 50 58 70 67 69 68 75 61 53 49 46 

17 45 49 58 73 67 70 64 75 63 53 47 45 

18 44 49 57 70 70 68 62 72 61 50 45 44 

19 43 47 56 67 68 66 57 68 60 47 45 44 

20 44 48 54 68 66 64 60 63 57 46 44 45 

21 44 48 54 59 66 60 58 61 52 46 44 43 

22 42 46 51 58 72 57 60 59 52 45 45 42 

23 41 46 50 55 71 57 52 60 46 43 42 41 

4-12 
 

 

 

 

 

4.3 AERMOD Modeling Results 

4.3.1 NAAQS Compliance Demonstration 

This section summarizes the AERMOD modeling results for Trapper Mine emissions and 

compares the predicted concentrations to the applicable NAAQS. Where the NAAQS is 

expressed in units of parts per billion or parts per million, the NAAQS concentration value has 

been converted to micrograms per cubic meter to allow for direct comparison against the 

AERMOD modeling results. The AERMOD modeling addressed the following regulated 

pollutants: CO, SO2, NO2, PM10, and PM2.5. 

The AERMOD modeling results are summarized in Table 4-6 for the on-site Trapper 

meteorological data and in Table 4-7 for the Gossard meteorological data. The modeling results 

are presented using the appropriate form of the NAAQS. As seen by the AERMOD results in 

these tables, the Gossard data provided the worst-case modeling result for all pollutants and 

averaging times. 

As demonstrated by Tables 4-6 and 4-7, the predicted AERMOD concentration for each 

pollutant and averaging time, plus an appropriate background level to account for impact from 

emission sources not explicitly included in the modeling, demonstrates compliance with all 

applicable NAAQS. 

4-13 
 

 

 

 

 

 

 

 

 

 

Table 4-6 

AERMOD Modeling Results – Trapper Mine: Trapper On-Site Meteorological Data
 

All concentrations in micrograms per cubic meter
 

Pollutant Averaging 

Time 

Form1 - AERMOD 

Modeled Concentration 

Background 

Concentration 

Cumulative Impact 

(AERMOD plus 

Bkgnd) 

NAAQS2 

CO 

1-hour 2nd - 2154.02 1,145 3,299.02 10,000 

8-hour 2nd - 526.6 1,145 1,671.60 40,000 

SO2 

1-hour 4th - 30.4 2.62 33.02 195.6 

3-hour 1st

- 14.22 2.62 16.84 700 

NO2 

1-hour 8th - 135.23 13.16 148.39 188 

Annual NA3 1.88 NA 100 

PM10 24-hour 2nd – 25.55 23 48.55 150 

PM2.5 

24-hour 8th - 3.21 14 17.21 35 

Annual NA3 3 NA 12 

1

The AERMOD concentration shown is the concentration expressed in the form of the NAAQS. For example, since the SO2 

NAAQS is based on the 99th percentile daily maximum concentration, the 4th highest concentration value from AERMOD is 

reported (i.e., over 365 days, the highest 3 days are excluded to reach the 99th percentile concentration). Other pollutants are 

addressed similarly based on the form of the NAAQS. 

2 NAAQS concentrations expressed as the equivalent concentration in micrograms per cubic meter. The 3-hr SO2 standard 

represents the State of Colorado SO2 standard and not the NAAQS. 

3 No annual average computed for Trapper Mine on-site data as the meteorological data span less than a full year. 

4-14 
 

 

 

 

 

 

 

 

 

 

Table 4-7 

AERMOD Modeling Results – Trapper Mine: Gossard Meteorological Data
 

All concentrations in micrograms per cubic meter
 

Pollutant Averaging 

Time 

Form1 - AERMOD 

Modeled Concentration 

Background 

Concentration 

Cumulative Impact 

(AERMOD plus 

Bkgnd) 

NAAQS2 

CO 

1-hour 2nd - 3791.54 1,145 4,936.54 10,000 

8-hour 2nd - 907.4 1,145 2,052.40 40,000 

SO2 

1-hour 4th - 49.41 2.62 52.03 195.6 

3-hour 2nd – 26.32 2.62 28.94 700 

NO2 

1-hour 8th - 159.27 13.16 172.43 188 

Annual 1st - 24.67 1.88 26.55 100 

PM10 24-hour 2nd – 67.16 23 90.16 150 

PM2.5 

24-hour 8th - 12.78 14 26.78 35 

Annual 1st - 3.96 3 6.96 12 

1

The AERMOD concentration shown is the concentration expressed in the form of the NAAQS. For example, since the SO2 

NAAQS is based on the 99th percentile daily maximum concentration, the 4th highest concentration value from AERMOD is 

reported (i.e., over 365 days, the highest 3 days are excluded to reach the 99th percentile concentration). Other pollutants are 

addressed similarly based on the form of the NAAQS. 

2 NAAQS concentrations expressed as the equivalent concentration in micrograms per cubic meter. The 3-hr SO2 standard 

represents the State of Colorado SO2 standard and not the NAAQS. 

4-15 
 

 

 

 

 

 

4.3.2 Maximum Impact Locations 

The location of the maximum modeled concentration described in Tables 4-6 and 4-7 

varies between pollutants and averaging periods and depends largely on the emission distribution 

and the nature of the meteorology data. The dominant wind direction (south through southwest) 

caused all maximum modeled concentrations to be along either the north or east Trapper Mine 

permit boundary. 

For PM10 and PM2.5, the emissions were dominated by mining activities in and near the 

mining pits. As such, the maximum modeled PM10 24-hour concentration occurred along the 

Trapper Mine permit boundary to the northeast of N-Pit. This impact was believed to be 

dominated by mining-related emissions associated with the N-Pit and also from emissions 

associated with the L-pit coal hauling where the haul road bypasses N-Pit on the north side. 

Even though N-Pit had fewer emissions compared to L-Pit, the shorter transport distance from 

N-Pit to the boundary plus the contribution from the coal hauling emissions helped increase the 

PM10 impacts in this area. 

The maximum modeled PM2.5 concentrations both occurred along the eastern Trapper 

Mine permit boundary to the northeast of L-Pit. The worst-case PM2.5 impact locations were 

caused by the relatively high concentration of emissions within L-Pit and the direction of the 

prevailing winds. 

The maximum modeled 1-hour average NO2 concentration occurred along the 

northeastern section of the Trapper Mine permit boundary to the north of the L-Pit. These 

impacts were influenced by the high concentration of NOX emissions from the truck and mining 

equipment in L-Pit. 

For pollutants such as carbon monoxide (CO), annual mean nitrogen dioxide (NO2), and 

sulfur dioxide (SO2), combustion emissions from haul road trucks is the dominant source of 

emissions. For these pollutants, the maximum modeled impacts occurred near where the coal 

haul road leading to the Craig Station passes through the permit boundary of the Trapper Mine. 

As mentioned before, the coal haul road is a private road with no public access. The maximum 

modeled impacts occur near this particular location because the transport distance between the 

emission source and potential receptors is minimized where the haul road exits the Trapper 

Mine. The CO 1-hr and 8-hr, NO2 annual, and SO2 1-hr maximum modeled impacts were all 

located near where the coal haul road passes through the Trapper Mine permit boundary. 

4-16 
 

 

 

5.0 DIRECT AND INDIRECT GREENHOUSE GAS (GHG) EMISSIONS 

AND ASSOCIATED CLIMATE IMPACTS 

GHG emissions associated with the Trapper Mine include carbon dioxide (CO2), methane 

(CH4), and nitrous oxide (N2O). The direct Trapper Mine GHG emissions are associated with the 

fuel combustion in mining equipment and trucks, and blasting. In addition, fugitive methane 

emissions are released at surface mines from the coal seams. Indirect GHG emissions occur from 

the combustion of Trapper Mine coal at the Craig Station plus fuel combustion associated with 

truck and equipment associated with CCR placement within the Trapper Mine. 

GHG emissions are reported on the basis of carbon dioxide equivalents (CO2e). This 

accounts for the differences in the global warming potential (GWP) of the individual 

constituents. 

5.1 Direct Greenhouse Gas Emissions 

Direct GHG emissions from fuel combustion in mining equipment and trucks were 

calculated using the equipment operating time for the worst-case year (2020) and applicable 

emission factors from the USEPA MOVES2014 model (USEPA 2014). Similar to the other 

pollutant estimates, data from MOVES2014 was applied using the most applicable equipment 

type under the “nonroad construction” category. For blasting, emissions data from AP-42 Table 

13-3.1 were applied using the estimated explosives (ANFO) use in blasting for the worst case 

year (2020). 

Emissions estimates for methane releases at surface coal mines were taken from an 

USEPA’s Surface Mines Emissions Assessment (USEPA 2005b), which reports methane 

releases in cubic feet per ton of coal removed. 

Table 5-1 lists the estimated direct GHG emissions and the GWP for the individual GHG 

gasses. GHG emissions are shown in Metric Tons (MT) for consistency with international 

standards (1 MT = 1,000 kg = 1.1 tons US). For the N2O estimates, if specific N2O emissions 

data were not available for a given source category, all NOX emissions were assumed to be in the 

form of N2O in order to provide for a worst-case assessment. All GHG calculations are 

documented in the electronic spreadsheets available by CD upon request. 

5-1 
 

 

 

 

 

 

 

Table 5-1
 

Direct Mining Emissions for Worst-Case Year (2020) GHG Emissions
 

(tons and MT per year)
 

CO2 CH4 N2O CO2e 

Global Warming Potential 1 361 298 -­

Fuel Combustion (tons) 86,711 -­ 9872 380,973 

Blasting (tons) 291 3 742 22,364 

Coal Seams (tons) -­ 3,524 -­ 126,878 

TOTAL (tons) 87,002 3,527 1,061 530,215 

TOTAL (Metric Tons) 79,093 3,206 965 482,014 

1: EPA lists the GWP for methane in the range of 28-36. The upper bound (36) was used in order to provide for a 

worst-case estimate for the CO2e emissions. 

2: All NOX emissions assumed to be in the form of N2O for the GHG calculation 

5.2 Indirect Greenhouse Gas Emissions 

Indirect GHG emissions are associated with combustion of coal provided to Craig Station 

by the Trapper Mine and secondarily from diesel fuel combustion associated with the haul trucks 

which carry the coal to Craig Station and the coal combustion residuals materials back to 

Trapper Mine for final placement. 

At the Craig Station, CO2 emissions associated with coal combustion are listed in the 

AMPD database, so the CO2 emissions estimates were handled in a manner similar to the SO2 

and NOX emissions described in Section 3.1 of the TSD. The total 2014 Craig Station CO2 

emissions were obtained from the AMPD and the portion derived from Trapper Mine coal was 

calculated. This value was then adjusted to a coal production level of 2.6 mtpy. 

Because the AMPD reports only CO2 emissions, the total GHG emissions as CO2e 

needed to be determined by including emissions of other GHG pollutants, specifically CH4 and 

N2O. Using the AP-42 emission factors (Section 1.1, Coal Combustion) and the global warming 

potential of each pollutant, a CO2e factor was determined and compared to the CO2-only 

emissions factor from AP-42. This ratio was then used to adjust the CO2-only emissions reported 

in the AMPD for Craig Station. Because CO2 dominates the GHG emissions for coal combustion 

compared to CH4 and N2O, the calculated adjustment factor was very small (0.5 percent). These 

calculations are shown in Table 5-2. 

5-2 
 

 

 

 

 

 

Table 5-2 

Adjustment of CO2-Only Coal Combustion Emissions to CO2e
 

CO2 CH4 N2O Total 

AP-42 Factors (lb/ton) 4810 0.04 0.08 

Global Warming Potential 1 36 298 

AP-42 Factors as CO2e (lb/ton) 4810 1.44 23.84 4835 

For the coal combustion residuals placement, GHG emissions associated with the diesel 

fuel combustion in the trucks hauling ash to the coal combustion residuals placement site were 

calculated using the USEPA MOVES2014 emissions model (USEPA 2014). MOVES2014 only 

lists data on CO2 emissions; so other GHG emissions were not calculated for the coal 

combustion residuals placement. However, like coal combustion, GHGs from diesel fuel 

combustion are dominated by the CO2 emissions and omitting the other GHG pollutants from the 

calculation does not introduce a significant error in the overall estimate. Also, the coal 

combustion residuals placement is a very small fraction of the overall indirect GHG emissions. 

The indirect GHG emissions calculated for Trapper Mine are shown in Table 5-3. The 

coal combustion emissions dominate and the GHG emissions contribution associated with the 

CCR placement is very small in comparison to the coal combustion GHG emissions. The 

indirect GHG emissions are shown in MT for consistency with international standards (1 MT = 

1,000 kg = 1.1 tons US). Also, in order to provide some perspective on the estimated indirect 

Trapper Mine GHG emissions, the calculated GHG emissions are compared against national 

(2007) and statewide (2010) totals. The indirect Trapper Mine GHG emissions are about 4.5% of 

the statewide GHG emissions total (2010) and are less than 0.1% of the national GHG emissions 

total (2007). 

Table 5-3
 

Indirect Trapper Mine GHG Emissions reported as CO2e
 

Trapper Mine Coal Combustion and Coal Combustion Residual Placement
 

GHG Emissions as CO2e 

(MT per yr) 

Indirect Project Emissions as 

compared to State/National Totals 

Coal Combustion 

at 2.6 mtpy 

5,341,966 

CCR transportation 985 

Total Indirect GHG Emissions 5,342,951 

Colorado GHG Emissions (2010) 129.95 mtpy 4.1% 

Nationwide GHG Emissions 

(2007) 7,150.1 mtpy 0.07% 

5-3 
 

Although it is impossible to connect a single emitter of GHGs to the degree of impact that 

emitter may have on global climate change, EPA has predicted that Colorado will experience the 

following general trends related to climate change (USEPA 2015b). 

 The region will experience warmer temperatures with less snowfall. 

 Temperature are expected to increase more inwinter than in summer, more at night than 

in the day, and more in the mountains than at lower elevations. 

 Earlier snowmelt will result in earlier peak stream flows, weeks before the peak needs of 

ranchers, farmers, recreationalists, and others. In late summer, rivers, lakes, and 

reservoirs will be drier. 

 More frequent, more severe, and possibly longer-lasting droughts. 

 Crop and livestock production patterns could shift northward; less soil moisture due to 

increased evaporation may increase irrigation needs. 

 Drier conditions will reduce the range and health of ponderosa and lodgepole pine 

forests; and increase the susceptibility to fire. 

 Grasslands and rangeland could expand into previously forested areas 

 Ecosystems will be stressed and wildlife as mountain lion, black bear, long-nose sucker, 

marten, and bald eagle could be further stressed. 

Another approach to address climate change impacts is to calculate the “social cost of 

carbon” (SCC). The SCC protocol was developed for use in cost-benefit analyses for proposed 

regulations that could impact cumulative global GHG emissions (USEPA 2013). The SCC 

estimates economic damages associated with increases in carbon emissions and includes but is 

not limited to changes in net agricultural productivity, human health, and property damages 

associated with increased flood risks. 

The SCC is typically expressed as the cost in dollars per metric ton of emissions and 

there is a wide range of costs, with the greatest influence on costs caused by the discount rate. 

The discount rate is a measure to estimate the present value for costs/damages that may occur far 

out into the future. For 2020 emissions, the range in SCC presented by the USEPA is $13/MT to 

$137/MT, represented as 2011 dollars (USEPA 2013). 

For the Trapper EA, OSMRE has elected not to specifically quantify the social cost of 

carbon. First, there is no certainty that GHG emissions at Craig Station would actually be 

reduced if the subject Trapper Mine coal was not mined given that Craig Station has alternative 

sources for coal and that Trapper Mine also has non-federal coal reserves that could be mined 

(see additional discussion of this topic under the No Action Alternative in the EA). 

Also, in order to provide any meaningful insight, the projected SCC costs would need to 

be viewed in context with other project costs and benefits associated with the proposed action. 

Given the uncertainties associated with assigning a specific and accurate SCC cost to the project 

and also given the uncertainties that indirect GHG emissions would actually be reduced under 

any reasonable project alternatives, OSMRE has elected not to quantify the social cost of carbon 

for this EA and has instead quantified direct and indirect GHG emissions and evaluated these 

emissions in the context of state and national GHG emission inventories (see Table 5-3). 

5-4 
6.0 SUMMARY OF AIR QUALITY & CLIMATE IMPACTS 

Direct air quality impacts from mining activities include emissions associated with 

recovery of the coal resource, including coal/overburden handling and transfer along with 

emissions from combustion of diesel fuel in trucks and mining equipment. Although air 

emissions are released into the environment from mining activities, air quality dispersion 

modeling has demonstrated that health-based air quality standards will not be exceeded in the 

vicinity of Trapper Mine. As such, the direct air quality impacts are negligible. Direct air quality 

impacts are short-term and will occur for the life of mining activities. 

Indirect air quality impacts occur from combustion of coal mined by TMI at Craig Station 

Units 1 and 2. The coal combustion releases air emissions, most notably SO2 and NOX. Craig 

Station employs pollution abatement equipment to reduce these emissions and has plans to 

further reduce NOX emissions at Units 1 and 2 in the 2018-2021 timeframe. The indirect air 

quality emissions are short-term and occur for the life of mining activities and are also 

negligible. 

The indirect air quality impacts associated with mercury emissions released during coal 

combustion are discussed in the Special Status Species Section of the Trapper Mine EA. 

Emissions of greenhouse gasses (GHGs) occur from both direct and indirect sources. 

Direct GHG emissions include fugitive releases of methane from the coal seams and GHG 

emissions from combustion of diesel fuel in the truck fleet and other mining equipment. Indirect 

GHG emissions, primarily CO2, occur from coal combustion at Craig Station Units 1 and 2. Any 

climate impacts that may occur are difficult to assign to an individual emission source of GHGs 

such as Trapper Mine and/or Craig Station. Climate impacts are potentially long-term, but any 

contribution to climate change associated with direct/indirect emissions from Trapper Mine is 

likely to be negligible and would cease after the life of the mine. 

6-1 
 

 

 

7.0 REFERENCES
 

Cai, H. and M.Q. Wang, 2014. Estimation of Emission Factors of Particulate Black Carbon and 

Organic Carbon from Stationary, Mobile, and Non-Point Sources in the United States for 

Incorporation into GREET. Argonne National Laboratory, Energy Systems Division, 

Systems Assessment Group, May 2014. 

Caterpillar, 2011. Letter communication dated April 27, 2011. 

Colorado Department of Public Health and Environment, 2005. Title V Air Quality Operating 

Permit for Craig Generating Station, Permit #96OPMF155, issued May 1, 2005. 

Colorado Department of Public Health and Environment (CDPHE), 2009. Air Emissions Permit 

#11MF253-1, Modification #2, issued to Trapper Mining, Inc., May 8, 2009. 

Colorado Department of Public Health and Environment, 2014a. Colorado Visibility and 

Regional Haze State Implementation Plan for the Twelve Mandatory Class I Federal 

Areas in Colorado. Revisions approved by the Colorado Air Quality Control Commission 

on November 20, 2014. 

Colorado Department of Public Health and Environment, 2014b. Colorado Greenhouse Gas 

Inventory - 2014 Update (Including Projections to 2020 and 2030). October 2, 2014. 

Colorado Department of Public Health and Environment, 2015a. Personal communication with 

Emmett Malone, Air Quality Meteorologist, Air Pollution Control Division, E-Mail dated 

October 19, 2015. 

Colorado Department of Public Health and Environment, 2015b. Personal communication with 

Nancy Chick, Environmental Protection Specialist, Air Pollution Control Division, EMail dated October 16, 2015. 

Environmental Integrity Project, 2011. America’s Power Plant Mercury Polluters: The Good, 

the Bad, and the Dirty, January 2011, available at www.environmentalintegrity.org. 

Tri-State Generation and Transmission Association, 2015. Mercury Emissions Data. 

US Environmental Protection Agency, Undated. Compilation of Air Pollutant Emissions Factors 

(AP-42), available at www.epa.gov/ttn/chief/. 

US Environmental Protection Agency, 2004. User’s Guide for the AMS/EPA Regulatory Model 

– AERMOD. U.S. Environmental Protection Agency, EPA-454/B-03-001, September 

2004. 

US Environmental Protection Agency, 2005a. Revision to the Guideline on Air Quality Models, 

40 CFR 51 Appendix W. Federal Register, November 9, 2005. 

7-1 
 

US Environmental Protection Agency, 2005b. U.S. Surface Mines Emissions Assessment. U.S. 

Environmental Protection Agency, Coalbed Methane Outreach Program, October 2005. 

US Environmental Protection Agency, 2011. Haul Road Workgroup Final Report. U.S. 

Environmental Protection Agency, Region V, Chicago, IL. December 6, 2011. 

US Environmental Protection Agency (EPA), 2013. Fact Sheet: Social Cost of Carbon, 

November 2013. 

US Environmental Protection Agency, 2014. Motor Vehicle Emissions Simulator (MOVES), 

User Guide for MOVES2014. U.S. Environmental Protection Agency, Office of 

Transportation and Air Quality, Assessment and Standards Division. EPA-420-B-14-055, 

July 2014. 

US Environmental Protection Agency, 2015a. AERMOD Implementation Guide. U.S. 

Environmental Protection Agency, Office of Air Quality Planning and Standards, Air 

Quality Assessment Division, Revised August 3, 2015. 

US Environmental Protection Agency (EPA), 2015b. Climate Impacts in the Southwest (Updated 

July 21, 2015). Available at http://www.epa.gov/climatechange/impacts-adaptation. 

7-2 
Appendix C 

Appendix C 

Biological Opinion 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

, 

United States Department of the Interior 

FISH AND WILDLIFE SERVICE 

COLORADO FIELD OFFICE/LAKEWOOD 

PO BOX 25486, DENVER FEDERAL CENTER 

DENVER, COLORADO 80225-0486 

IN REPLY REFER TO: 

ES/GJ-6-CO-l 6-F-005 

TAILS 06E24100-2016-F-0050 

March 22, 2016 

Memorandum 

To: Supervisor, Program Support Division, Field Operations Branch, Office of Surface 

Mining Reclamation and Enforcement, Denver, Colorado 

From: Acting Colorado Field Supervisor, U.S. Fish J7ildli£ Se ic , cologic

Services Field Office, Lakewood, Colorado (!)f  

Subject: Reinitiation of Consultation for the Trapper Mining Inc. Trapper Mine, Mining Plan 

Modification of Federal Coal Leases C-07519 and C-079641, Moffat County, 

Colorado 

This memorandum and the attached Biological Opinion (BO) responds to the Office of Surface 

Mining Reclamation and Enforcement (OSMRE) request for reinitiation of consultation with the 

Fish and Wildlife Service (Service) on effects of the subject project to species and habitats listed 

under the Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.; [Act]). 

OSMRE's request received December 9, 2015, included a biological assessment (BA) entitled 

Reinitiation of Consultation for the Trapper Mining Inc. Trapper Mine, Mining Plan 

Modification (OSMRE 2015a). OSMRE analyzed the effects from the subject project to a 

number of listed species identified in the BA; the final determinations of OSMRE are presented 

below. 

Species Listing status Determination 

Colorado pikeminnow (Ptychocheilus Lucius) endangered, critical habitat likely to adversely affect 

Razorback sucker (Xyrauchen texanus) endangered, critical habitat likely to adversely affect 

Humpback chub (Gila cypha) endangered, critical habitat likely to adversely affect 

Bonytail ( Gila elegans) endangered, critical habitat likely to adversely affect 

Western yellow-billed cuckoo (Coccyzus threatened not likely to adversely affect 

americanus)

W estem yellow-billed cuckoo proposed critical habitat not likely to destroy or 

adversely modify 

Greenback cutthroat trout ( Oncorhynchus threatened no effect 

clarki stomias) 

Dudley Bluffs Twinpod (Physaria obcordata) threatened no effect 

Ute ladies' -tresses (Spiranthes diluvialis) threatened no effect 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Three other listed species, Black-footed ferret (Mustela nigripes), Canada lynx (lynx 

canadensis), and Mexican spotted owl (Strix occidentalis lucida), were analyzed in past 

consultations between OSMRE and the Service on Trapper Mine activities (see 1.2 Consultation 

History in BA). OSMRE had determined that there would be no effect to those three species. 

OSMRE found past analyses to be adequate and did not reanalyze effects to those species in the 

current BA. 

Below, the Service has prepared a BO with a finding that the proposed project is not likely to 

jeopardize the four endangered fish, nor is it likely to destroy or adversely modify their critical 

habitats (attached). We also concur (below) with OSMRE’s determination for the western 

yellow-billed cuckoo (cuckoo) and its proposed critical habitat. 

For the Dudley Bluffs Twinpod, Ute ladies’-tresses, black-footed ferret, Mexican spotted owl, 

and Canada lynx, we acknowledge your determination of no effect, but neither 7(a)(3) of the Act, 

nor implementing regulations under section 7(a)(2) of the Act require the Service to review or 

concur with this determination; therefore the Service will not address these species further. 

However, we do appreciate you informing us of your past and current analyses for these species. 

Concurrence for western yellow-billed cuckoo and its proposed critical habitat 

No cuckoos have been found at the Trapper Mine or the Craig Generating Station (Craig 

Station), both of which lack cuckoo habitat. Cuckoo habitat is present approximately 1.5 miles 

to the northwest of the Craig Station along the Yampa River. Critical habitat has been proposed 

for the western yellow-billed cuckoo (79 FR 48547), including a unit along the Yampa River 

between the towns of Craig and Hayden. Cuckoos and their proposed critical habitat are found 

within the airshed analyzed for mercury deposition from the Craig Station, as outlined in the BA 

and discussed in our BO below. 

We have records of only six cuckoos from the Yampa proposed critical habitat unit. The most 

recent observation was from 2015. We do not know whether any of these cuckoos were nesting 

or not. There is potential for contamination of cuckoo insect prey items and habitats from 

mercury emissions from the Craig Station. However, we have no data on mercury levels from 

cuckoos or their prey in this area. Aquatic insects are more likely to accumulate mercury from 

the environment than terrestrial insects due to the mercury methylation process which takes place 

in the presence of anoxic lentic environments (Sandheinrich and Wiener 2011). Aquatic insects 

(e.g., dragonflies, caddisflies) are only a minor component of a cuckoo’s diet (79 FR 48587). 

As described in the BA (Appendix B), in order to further our collective knowledge regarding the 

use of the Yampa proposed critical habitat unit by yellow-billed cuckoos, Trapper Mining Inc. 

(Trapper) plans to commit $5,000 for a yellow-billed cuckoo survey during the breeding season 

within the recently proposed critical habitat unit along the Yampa River. Trapper would either 

conduct the survey itself or hire a contractor to perform the survey (in either case the official 

survey protocol would be followed by a qualified permit holder). The results of the survey will 

be provided to the Service. 

You have determined that your proposed action may affect, but is not likely to adversely affect 

the cuckoo. You have also determined that your proposed action is not likely to destroy or 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

adversely modify proposed critical habitat for the cuckoo. We concur with your determinations. 

We base our concurrence on the rationale provided in the BA and additional Service review and 

analysis. We would like to point out, however, that many questions remain regarding the 

cuckoo’s status and the potential contaminant levels in the action area; new information could 

lead to different conclusions in the future. 

We conclude informal consultation under section 7 of the Act for the cuckoo and its proposed 

critical habitat. Further consultation pursuant to section 7(a) (2) of the Act is not required at this 

time. As provided in 50 CFR §402.16, reinitiation of formal consultation is required and shall be 

requested by the Federal agency or by the Service, where discretionary Federal involvement or 

control over the action has been retained or is authorized by law and: (a) If the amount or extent 

of taking specified in the incidental take statement is exceeded; (b) If new information reveals 

effects of the action that may affect listed species or critical habitat in a manner or to an extent 

not previously considered; (c) If the identified action is subsequently modified in a manner that 

causes an effect to the listed species or critical habitat that was not considered in the BO; or (d) If 

a new species is listed or critical habitat designated that may be affected by the identified action. 

In accordance with section 7 of the Act and its implementing regulations, this BO incorporates 

the best scientific and commercial information available on the effects of the proposed action to 

federally listed species and their critical habitats, including from the mining and combustion of 

coal resulting in mercury and selenium emissions and subsequent deposition and accumulation in 

listed species within the Yampa and White River Basins. A complete record of this consultation 

is on file at the Service’s Western Colorado Ecological Services Field Office, in Grand Junction, 

Colorado. 

If you have questions regarding this consultation, please contact Creed Clayton at 

(970) 628-7187. 
p 

BIOLOGICAL OPINION 

On effects to the Colorado pikeminnow, razorback sucker, humpback chub, and bonytail 

from 

coal mining of Federal coal leases C-07519 and C-079641 at the Trapper Mine and 

subsequent combustion of the coal at the Craig Generating Station 

TAILS No. 06E24100-2016-F-0050 

Colorado pikeminnow (Ptychocheilus lucius) 

FISH AND WILDLIFE SERVICE 

Mountain Prairie Region 

Grand Junction, Colorado 

Acting Colorado Field Supervisor, Ecological Services ? · 0 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Purpose of this Document 

In 1973, Congress passed the Endangered Species Act (ESA) in order to “...provide a means 

whereby the ecosystems upon which endangered species and threatened species depend may be 

conserved...” (ESA section 2). Included in section 7 of that Act, is the requirement that every 

federal agency must insure that any action “...authorized, funded, or carried out...is not likely to 

jeopardize the continued existence of any endangered or threatened species...”. To meet this 

requirement, Congress required that the action agencies request assistance from the U. S. Fish 

and Wildlife Service (Service) and seek their biological opinion (BO) regarding whether the 

proposed action is likely to jeopardize the continued existence of a listed species. 

This document is that required examination of the OSMRE’s proposed action (mine plan 

approval) and the Service’s BO on the proposed action’s effects to the Colorado pikeminnow, 

razorback sucker, humpback chub, and bonytail (four endangered fish). This BO also determines 

whether the proposed action would destroy or adversely modify critical habitats for the four 

endangered fish. 

This BO relies on the newly revised (2016) regulatory definition of “destruction or adverse 

modification” of critical habitat (Federal Register, February 11, 2016, Volume 81, No. 28 p. 

7226), which states, “Destruction or adverse modification means a direct or indirect alteration 

that appreciably diminishes the value of critical habitat for the conservation of a listed species. 

Such alterations may include, but are not limited to, those that alter the physical or biological 

features essential to the conservation of a species or that preclude or significantly delay 

development of such features.” 

Background 

As a result of a legal challenge (WildEarth Guardians v. U.S. Office of Surface Mining et al., 

Case 1:13-cv-00518-RBJ (D. Colo. 2015)), the District Court of Colorado required the Office of 

Surface Mining and Reclamation Enforcement (OSMRE) to review their approval of mining 

plans at the Colowyo and Trapper Mines in Moffat County, Colorado (including any effects from 

the action of mining plan approval) and complete additional analysis under the National 

Environmental Policy Act (NEPA). Among other things, the court’s findings indicated that the 

indirect effect of combustion at the Craig Generating Station, where the coal would be burned, 

from coal mined under the plan should be considered as “reasonably foreseeable” under NEPA 

and should be included in the NEPA analysis. The Court’s direction to explore those indirect 

effects under NEPA had the unintended consequence of leading to an examination of these 

effects under section 7 of the ESA. 

Indirect effects under regulations implementing section 7 of the ESA are defined as “...those that 

are caused by the proposed action and are later in time, but still are reasonably certain to occur.” 

(Emphasis added.) This definition differs from the NEPA phrase “reasonably foreseeable.” This 

difference may reflect a distinction between the procedural nature of NEPA vs. the substantive 

nature of section 7 and is touched on briefly in the Federal Register notice finalizing the 1986 

regulations on conducting section 7 consultation (FR June 3, 1986, Volume 51, No. 106, 

p. 19933). 

1 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

OSMRE does not have discretion or authority over determining where the Colowyo and Trapper 

mined coal would be taken to be combusted. OSMRE also does not have discretion or authority 

regarding the manner in which the coal will be combusted. In the past, coal mined at the 

Colowyo and Trapper mines has been burned at the Craig Generating Station to produce power. 

The decision space in between OSMRE’s plan approval and the combustion of the coal at the 

Craig Generating Station may make the causal connection somewhat less than reasonably 

certain. However, OSMRE has assumed (for analysis) the causal connection for indirect effects. 

The Service therefore, will base our analysis on that assumption. 

Consultation History 

On February 28, 2013, OSMRE submitted a consultation request and BA for a 5-year permit 

renewal for Trapper Mine (SMCRA Permit C-1981-010) Permit Renewal Application Number 6 

(RN-06). The BA determined that the endangered fish in the Upper Colorado River Basin would 

be adversely affected by water depletions (amount updated), it contained “no effect” 

determinations for the Canada lynx, Mexican spotted owl, and Ute ladies'-tresses orchid, a 

determination of “may affect, not likely to adversely affect the continued existence of” the North 

American wolverine (Gulo gulo luscus) and greater sage-grouse (Centrocercus urophasianus), 

and made a determination that mining activities would “not affect the continued existence of” the 

black-footed ferret and western yellow-billed cuckoo. In response, the Service issued a 

Biological Opinion on June 21, 2013 (TAILS 06E24100-2013-F-0098), that addressed a revised 

assessment of 160.1 acre-feet/year (AF/yr) of water depletions from the Yampa River. No new 

water depletions have been identified as part of the current consultation and are not addressed 

further in this BO. 

On June 15, 2009, OSMRE submitted a consultation request and BA documenting a 94.8 AF/yr 

net water depletion for a mining plan modification for Permit C-1981-010 at the Trapper Mine, 

which would result from an additional 312 acres of mining disturbance. The BA also contained 

“no effect” determinations for the black-footed ferret, Canada lynx, Mexican spotted owl, and 

Ute ladies'-tresses orchid. The Service issued a Biological Opinion on September 17, 2009, 

(TAILS 65413-2009-F-0179), that addressed the 94.8 AF/yr of water depletions from the Yampa 

River for the expansion of mining into the additional 312 acres within Trapper Mine’s 10,382.3 

acre permit area. 

1.0 PROPOSED ACTION (as described in the BA) 

The Trapper surface coal mine is located in Moffat County, Colorado, approximately 6 miles 

south of the Town of Craig, Colorado on State of Colorado, and private lands. The Trapper mine 

approved Colorado Division of Reclamation and Mining Safety (CDRMS) permit area 

encompasses approximately 11,157 acres, of which approximately 2,423 acres are part of the two 

federal coal leases under analysis in this BO (Federal coal leases C-079641 and C-07519). The 

other acres within the permit area have already been mined, contain non-Federal coal, or are not 

currently under consideration for mining; thus, those acres are not part of the proposed action 

and will not be considered further in this BO. 

2 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The Yampa River flows generally east to west approximately 6 miles north of the Project Area, 

and the Williams Fork River skirts the south side of the permit area and flows into the Yampa 

River approximately one mile west of the permit area. Within the permit area, on north facing 

slopes, portions of the Buzzard, Coyote, No Name, Johnson, Pyeatt and Flume gulches flow 

generally south to north primarily in response to snowmelt or heavy rains. These gulches 

eventually discharge flows into the Yampa River. Drainages within the southern portion of the 

permit area include portions of Ute, Castor, Deer, Elk, and Horse gulches that flow generally 

southward into the Williams Fork River. 

1.1 Action Area 

The description of action area is informed by the following definitions. 

Action – “all activities or programs of any kind authorized, funded, or carried out, in whole or in 

part, by Federal agencies..... or (d) actions directly or indirectly causing modifications to the 

land, water, or air.” (50 C.F.R. § 402.02) 

Action Area – “all areas to be affected directly or indirectly by the Federal action and not 

merely the immediate area involved in the action.” (50 C.F.R. § 402.02) 

Effects of the action – "refers to the direct and indirect effects of an action on the species or 

critical habitat, together with the effects of other activities that are interrelated or 

interdependent with that action that will be added to the environmental baseline.... Indirect 

effects are those that are caused by the proposed action and are later in time, but still are 

reasonably certain to occur. Interrelated actions are those that are part of a larger action and 

depend on the larger action for their justification. Interdependent actions are those that have 

no independent utility apart from the action under consideration.” (50 C.F.R. § 401.02) 

[Emphasis added] 

Based on the area where “modifications to the land, water, or air” (directly or indirectly) from 

this proposed action occur and can be perceived, the action area for this BO covers: 1) the 

Trapper Mine, 2) the topographic airshed (airshed) (BA Fig. 6), and 3) critical habitats 

designated for all four endangered fish species found along the Yampa and White Rivers down 

to where each meets the Green River, which are within, adjacent to, and downriver from the 

airshed. The airshed encompasses the Trapper Mine and Craig Generating Station; it generally 

covers the area from Steamboat Springs west nearly to Dinosaur National Monument, and from 

the Flat Top Mountains north to the Elkhead Mountains (BA Fig. 6). The airshed includes 

portions of Moffat, Rio Blanco, Garfield, and Routt Counties. Examining air quality through a 

topographic airshed methodology allows for an assessment that utilizes the theoretical motion of 

the atmosphere, the blocking features of local topography, and the location of emissions sources. 

1.2 Mining 

Trapper production from the two lease areas is expected to be approximately 19.1 million tons 

from July 1, 2015, through the life of mine, currently anticipated to extend to 2024. The average 

production rate is approximately 2.3 million tons per year from eight coal seams of the Williams 

3 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Fork Formation with a maximum production rate of 2.6 million tons per year. Trapper currently 

produces coal and will continue to produce coal in the future from the L Pit located on Federal 

Coal Lease C-079641. Future mining also will occur in the N Pit located partially within Federal 

Coal Lease C-07519. Coal is mined using dragline, truck and shovel and highwall augering 

methods. The coal is transported by haul truck to the Craig Generating Station located to the 

north of the mine. Trapper currently has no provisions to ship coal to other locations (OSMRE 

2015a). 

1.3 Coal Combustion 

The destination of the coal, once mined, is not under the jurisdiction of OSMRE. However, all 

of the coal produced at the Trapper Mine is sent to the Craig Generating Station in Craig, 

Colorado. Trapper coal supplies as much as 54 percent of the annual fuel for the Craig 

Generating Station. The Craig Generating Station is a coal burning power plant that was 

constructed between 1974 and 1984 (Units 1, 2, and 3 were completed in 1980, 1979, and 1984 

respectively). It generates approximately 1,303 megawatts at peak capacity. 

Combustion of coal releases the following pollutants: sulfur dioxide, particulate matter, nitrogen 

oxides (NOx), mercury (Hg), selenium, and carbon dioxide. The Craig Generating Station, along 

with all coal fired power plants, has measures in place that reduce mercury and other emissions. 

Environmental control equipment at the station includes (OSMRE 2015b): 

•	 Wet limestone scrubbers on Units 1& 2 to remove sulfur dioxide. 

•	 Fabric filter “baghouse” on all Units to control particulate matter. 

•	 Dry limestone scrubber on Unit 3 to remove sulfur dioxide. 

•	 Low nitrogen oxide burners with over fire air on all three Units. 

•	 Mercury emission control on Unit 3, installed in 2014/2015. (Units 1 and 2 do not 

require mercury controls as they qualify as low emitters under the Environmental 

Protection Agency’s (EPA) Mercury and Air Toxics Standards (MATS) rule for power 

plants.) 

Selective Catalytic Reduction (SCR) emission controls are also planned to be constructed on 

Units 1 and 2 for NOx reduction by 2018. While not specific to mercury, the SCRs will provide 

the additional benefit of capturing some mercury before it is emitted. However, the amount 

captured is not known. Selective Non-Catalytic Reduction is also planned to be installed on Unit 

3 for NOx reduction by 2018. 

Of the contaminants listed above, mercury is of greatest concern for endangered fish, which is 

discussed further in the Effects of the Action section along with Selenium. The emissions 

information that follows here therefore pertains to mercury and selenium. 

1.4 Conservation Measures 

Conservation measures are actions that will be taken by the Federal agency or applicant, and 

serve to minimize or compensate for, project effects on the species under review. Trapper plans 

to commit $45,000 for Colorado River endangered fish research and $10,000 for Colorado River 

4 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

endangered fish on-the-ground recovery efforts. These proposed conservation measures would 

become mandatory commitments with the approval of the BA and issuance of the BO. Trapper 

commits to fund these projects within 45 days of issuance of the Trapper Mine BO. Further 

details are as follows: 

I. Commitment for Research Purposes for the Colorado River Fish 

a. Water Quality Testing. Trapper will be able to provide funding in the amount of $23,280 for 

quarterly water quality testing in two locations along both the White River and the Yampa River, 

beginning in June 2016 and ending in March of 2019. This amount is designed to allow 

sampling for 12 quarters of data from each of the four designated sites, or a total of 48 individual 

water quality samples. The water from these sites will be tested for both total mercury (Hg) and 

methylmercury (MeHg). 

b. Fish Tissue Mercury Sampling. Trapper will provide $21,720 for a mercury deposition 

study that will be conducted by the United States Geological Survey (USGS) (in cooperation 

with the BLM's Little Snake Field Office) for the investigation of MeHg uptake in fish tissues to 

be conducted in coordination with Colorado Parks and Wildlife. This study is to help the Service 

(and other interested parties) find out what the current mercury and selenium concentrations are 

in fish in the Yampa and White Rivers. Most likely a surrogate fish species (probably 

smallmouth bass) will need to be sampled due to the difficulty of obtaining enough endangered 

fish for sampling. 

The information obtained through these study efforts will advance the scientific understanding of 

the potential effects of coal combustion to the four endangered fish and will facilitate future 

conservation efforts for these species 

II. Commitment for Colorado River Fish Recovery Efforts 

Trapper will provide $10,000 for recovery actions that are managed by the Upper Colorado 

River Endangered Fish Recovery Program (Recovery Program). Trapper will provide the 

funding to the National Fish and Wildlife Foundation to distribute to the Recovery Program. 

2.0 STATUS OF THE SPECIES AND CRITICAL HABITAT 

The purpose of this section is to summarize the best available information regarding the current 

range-wide status of the four listed fish species. Additional information regarding listed species 

may be obtained from the sources of information cited for these species. The latest recovery 

goals for all four endangered fish, which provide information on species background, life history, 

and threats, can be found on the internet at: http://www.coloradoriverrecovery.org/documentspublications/foundational-documents/recovery-goals.html. 

2.1 Colorado Pikeminnow 

2.1.1 Species description 

5 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The Colorado pikeminnow is the largest cyprinid fish (minnow family) native to North America 

and evolved as the main predator in the Colorado River system. Individuals begin consuming 

other fish for food at an early age and rarely eat anything else. It is a long, slender, cylindrical 

fish with silvery sides, greenish back, and creamy white belly (Sigler and Sigler 1996). 

Historically, individuals may have grown as large as 6 feet (ft) long and weighed up to 100 

pounds (estimates based on skeletal remains) (Sigler and Miller 1963), but today individuals 

rarely exceed 3 ft or weigh more than 18 pounds (lbs) (Osmundson et al. 1997). 

The species is endemic to the Colorado River Basin, where it was once widespread and abundant 

in warm-water rivers and tributaries from Wyoming, Utah, New Mexico, and Colorado 

downstream to Arizona, Nevada, and California. Currently, wild populations of pikeminnow 

occur only in the Upper Colorado River Basin (above Lake Powell) and the species occupies 

only 25 percent of its historic range-wide habitat (Service 2002b). Colorado pikeminnow are 

long distance migrators, moving hundreds of miles to and from spawning areas, and requiring 

long sections of river with unimpeded passage. They are adapted to desert river hydrology 

characterized by large spring peaks of snow-melt runoff and low, relatively stable base flows. 

The Office of Endangered Species first included the Colorado pikeminnow (as the Colorado 

squawfish) in the List of Endangered Species on March 11, 1967 (32 FR 4001). It is currently 

protected under the ESA as an endangered species throughout its range, except the Salt and 

Verde River drainages in Arizona. The Service finalized the latest recovery plan for the species 

in 2002 (Service 2002b), but is currently drafting an updated revision. 

The Service designated six reaches of the Colorado River System as critical habitat for the 

Colorado pikeminnow on March 21, 1994 (59 FR 13374). These reaches total 1,148 miles (mi) 

as measured along the center line of each reach. Designated critical habitat makes up about 29 

percent of the species’ historic range and occurs exclusively in the Upper Colorado River Basin. 

Portions of the Colorado, Gunnison, Green, Yampa, White, and San Juan Rivers are designated 

critical habitat. The primary constituent elements of the critical habitat are water, physical 

habitat, and the biological environment (59 FR 13374). 

Water includes a quantity of water of sufficient quality delivered to a specific location in 

accordance with a hydrologic regime required for the species. The physical habitat includes 

areas of the Colorado River system that are inhabited or potentially habitable for use in spawning 

and feeding, as a nursery, or serve as corridors between these areas. This includes oxbows, 

backwaters, and other areas in the 100-year floodplain that provide access to spawning, nursery, 

feeding, and rearing habitats when inundated. The biological environment includes food supply, 

predation, and competition from other species. 

Recovery of Colorado pikeminnow in the Colorado River Basin is considered necessary only in 

the Upper Colorado River Basin (above Glen Canyon Dam, including the San Juan, and Green 

River subbasins) because of the present status of populations and because existing information 

on Colorado pikeminnow biology support application of the metapopulation concept to extant 

populations (Service 2002b). As a result, this BO will focus on the status of the Colorado 

pikeminnow in that unit. 

6 
 

 

 

 

 

 

 

 

2.1.2 Life history 

The Colorado pikeminnow requires relatively warm waters for spawning, egg incubation, and 

survival of young. Males become sexually mature at approximately 6 years of age, which 

corresponds to a length of about 400 millimeters (mm) (17 inches (in.)), and females mature 1 

year later (Sigler and Sigler 1996). 

Mature adults migrate to established spawning areas in late spring as water temperatures begin to 

warm, with migration events up to 745 river kilometers round-trip on record (463 mi) (Bestgen et 

al. 2005). Spawning typically begins after peak flows have subsided and water temperatures are 

above 16° Celsius (°C) (60.8° Fahrenheit (°F)). Mature adults deposit eggs over gravel substrate 

through broadcast spawning and eggs generally hatch within 4 to 6 days (multiple references in 

Bestgen et al. 2005). River flows then carry emerging larval fish (6.0 to 7.5 mm long (0.2 to 0.3 

in.)) downstream 40 to 200 km to nursery backwaters (25 to 125 mi), where they remain for the 

first year of life (Service 2002b). 

Colorado pikeminnow reach lengths of approximately 70 mm by age 1 (juveniles) (2.8 in.), 230 

mm by age 3 (subadults) (9 in.), and 420 mm by age 6 (adults) (16.5 in.), with mean annual 

growth rates of adult and subadult fish slowing as fish become older (Osmundson et al. 1997). 

The largest fish reach lengths between 900 and 1000 mm (35 to 39 in.); these fish are quite old, 

likely being 47 to 55 years old with a minimum of 34 years (Osmundson et al. 1997). 

Reproductive success and recruitment of Colorado pikeminnow is pulsed, with certain years 

having highly successful productivity and other years marked by failed or low success (Service 

2002b). The most successful years produce a large cohort of individuals that is apparent in the 

population over time. Once individuals reach adulthood, approximately 80 to 90 percent of 

adults greater than 500 mm (20 in.) survive each year (Osmundson et al. 1997; Osmundson and 

White 2009). Strong cohorts, high adult survivorship, and extreme longevity are likely life 

history strategies that allow the species to survive in highly variable ecological conditions of 

desert rivers. 

2.1.3 Population Dynamics 

The Colorado pikeminnow is endemic to the Colorado River basin, where it was once 

widespread and abundant in warm-water rivers and tributaries. Wild populations of Colorado 

pikeminnow are found only in the upper basin of the Colorado River (above Lake Powell). 

Three wild populations of Colorado pikeminnow are found in about 1,090 miles of riverine 

habitat in the Green River, upper Colorado River, and San Juan River subbasins (Service 2011a). 

We measure population dynamics of Colorado pikeminnow separately in the Green, upper 

Colorado, and San Juan River basins because distinct recovery criteria are delineated for each of 

these three basins. In the 2002 recovery plan, preliminary abundance estimates for wild adults in 

the basins were: upper Colorado River, 600 to 900; Green River, 6000 to 8000; and San Juan 

River, 19 to 50 (Service 2002b). 

7 
 

 

 

 

 

 

 

 

 

UPPER COLORADO RIVER
 

To monitor recovery of the Colorado pikeminnow, the Recovery Program conducts
	

multiple-pass, capture-recapture sampling on two stretches of the upper Colorado River which 

are roughly above and below Westwater Canyon (Osmundson and White 2009). In their most 

recent summary of those data (Osmundson and White 2013, in draft) the principal investigators 

conclude that during the 19-year study period [1992-2010], the population remained 

self-sustaining. The current downlisting demographic criteria for Colorado pikeminnow 

(USFWS 2002b) in the Upper Colorado River Subbasin is a self-sustaining population of at least 

700 adults maintained over a 5-year period, with a trend in adult point estimates that does not 

decline significantly. Secondarily, recruitment of age-6 (400–449 mm TL), naturally produced 

fish must equal or exceed mean adult annual mortality (estimated to be about 20 percent). The 

average of all adult estimates (1992 – 2010) is 644. The average of the five most recent annual 

adult population estimates is 658. Osmundson and White (2014) determined that recruitment 

rates were less than annual adult mortality in six years and exceeded adult mortality in the other 

six years when sampling occurred. The estimated net gain for the 12 years studied was 32 fish > 

450 mm TL. Whereas the Colorado River population may meet the trend or ‘self-sustainability’ 

criterion, it has not met the abundance criteria of ‘at least 700 adults’ during the most recent five 

year period. Updated graphs of Colorado pikeminnow abundance in the Colorado River are 

shown in Figure 1 (adults) and Figure 2 (subadults) (Service 2015a). 

0 

200 

400 

600 

800 

1000 

1200 

1400 

1991 1993 1995 1997 1999 2001 2003 2005 2007 2009 2011 2013 2015 

Adult Abundance Estimates 

Year 

Upper Colorado River Subbasin: Colorado pikeminnow adults 

Figure 1. Adult Colorado pikeminnow population abundance estimates for the Colorado River 

(Osmundson and Burnham 1998; Osmundson and White 2009; 2014). Error bars represent the 

95 percent confidence intervals. The 2013 and 2014 data are preliminary and represented by 

hollow data points. 

8 
 

 

 

 

 

 

 

 

 

 

 

 

 

0 

100 

200 

300 

400 

500 

600 

700 

800 

900 

1000 

1991 1993 1995 1997 1999 2001 2003 2005 2007 2009 2011 2013 2015 

Recruiting Subadults Abundance Estimates 

Year 

Upper Colorado River Subbasin: Colorado pikeminnow 

subadults 

Figure 2. Colorado pikeminnow recruitment abundance estimates (calculated using the same 

mark recapture methodology as for the adults) for the Colorado River (Osmundson and White 

2009, 2014; Service 2015a). Recruits are age-6 (400-449mm TL). Error bars represent the 95 

percent confidence intervals. The 2013 and 2014 are preliminary and represented by hollow data 

points. 

To summarize, in the Upper Colorado River Subbasin, the Colorado pikeminnow subpopulation 

may be self-sustaining, but the number of adults is below the level needed for recovery. 

Recruitment is quite variable over time, but has exceeded adult mortality in approximately half 

of the years when measured over the past two decades. The number of age-0 (young of year) 

Colorado pikeminnow is also quite variable over time, but appears to be less, on average, since 

the year 2000 than prior to 2000 (Figure 5). Colorado pikeminnow are also generally distributed 

throughout the Colorado River now to the same extent that they were when they became listed. 

GREEN RIVER 

Population estimates for adult Colorado pikeminnow in the Green River subbasin began in 2000. 

Sampling occurs on the mainstem Green River from the Yampa confluence to the confluence 

with the Colorado River and includes the Yampa and White Rivers. The initial year of sampling 

did not include the lower Green River (near the confluence of the White River to the confluence 

with the Colorado River). Beginning in 2001, the sampling regime has consisted of three years 

of estimates followed by two years of no estimates (Bestgen et al. 2005). The first set of 

estimates showed a declining trend; however, estimates collected in 2006–2008 showed an 

increasing trend approaching the level of the estimate made in 2000 (Figure 3) (Bestgen et al. 

2010). Data from the third round (2011–2013) of population estimates for the Green River 

subbasin are still being analyzed (thus no confidence intervals are shown for the 2011–2013 

estimates in Figure 3) (Bestgen et al. 2013). Preliminary results from Bestgen (2013) analysis 

9 
 

 

 

 

 

 

 

 

 

 

 

 

indicate adults and sub-adults are decreasing throughout the entire Green River subbasin (Service 

2014b). 

The downlisting demographic criteria for Colorado pikeminnow in the Green River subbasin 

require that separate adult point estimates for the middle Green River and lower Green River do 

not show a statistically significant decline over a 5-year period, and each estimate for the Green 

River subbasin exceeds 2,600 adults (estimated minimum viable population [MVP] number) 

(Service 2002b). The average of the first two sets of adult estimates was 3,020 (between 2000 – 

2008). The preliminary estimates for 2011-2013 are below 2,600 adults in each year. Adult Abundance Estimate 

Green River Subbasin: Colorado Pikeminnow Adults 6000 

5000 

4000 

3000 

2000 

1000 

0 

Year 1999 2001 2003 2005 2007 2009 2011 2013 

Figure 3. Adult Colorado pikeminnow population abundance estimates for the Green River 

(2000-2008 estimates from Bestgen et al. 2010; preliminary estimates for 2011-2013 from 

Bestgen et al. 2013). Error bars represent the 95 percent confidence intervals. In 2000, the 

lower Green River was not sampled. The data depicted for 2000 incorporates an extrapolated 

lower Green River contribution to the overall population estimate and therefore lacks a 

confidence interval. 

Another demographic requirement in the 2002 Recovery Goals is that recruitment of naturally 

produced fish reaching the age of 6 must equal or exceed mean annual adult mortality. Estimates 

of recruitment age-6 fish have averaged 1,455 since 2001, but have varied widely (Figure 4). 

Recruitment has exceeded annual adult mortality in some years, but not others, which falls short 

of meeting the recruitment recovery goal for the Green River subbasin (Service 2011a; Service 

2015a). However, this criterion is currently being revised to allow for a longer tracking period to 

accommodate natural fluctuations observed in the Green River population (Service 2011a). 

10 
 

 

 

 

 

 

 

 

 

Green River Subbasin: Colorado pikeminnow subadults 

Recruiting Subadults Abundance Estimates 

3000 

2500 

2000 

1500 

1000 

500 

0 

2000 2002 2004 2006 

Year 

2008 2010 2012 2014 

Figure 4. Estimated numbers of Colorado pikeminnow recruits (400–449 mm TL) in the Green 

River subbasin (Yampa, White, Middle Green, Desolation-Gray Canyons, and Lower Green) for 

2001–2013. Data from Bestgen et al. (2010). Estimates of recruitment for the most recent 

2011-2013 sampling period are preliminary. 

Bestgen et al. (2010) recognized that the mechanism driving frequency and strength of 

recruitment events was likely the strength of age-0 Colorado pikeminnow production in 

backwater nursery habitats. Osmundson and White (2014) saw a similar relationship between a 

strong age-0 cohort in 1986 and subsequent recruitment of late juveniles five years later, but that 

relationship was more tenuous in later years. Researchers are particularly concerned with what 

appears to be very weak age-0 representation in the Middle Green reach (1999 thru 2008) and in 

the lower Colorado River (2001 thru 2008) (Figure 5). In some years, the Bureau of 

Reclamation has released higher summer base flows in the Green River based on the 

understanding that this may improve survival of young Colorado pikeminnow and disadvantage 

smallmouth bass. 

11 
 

 

 

 

 

 

 

 

 

 

Number Collected Annually 

2000 

1800 

1600 

1400 

1200 

1000 

800 

600 

400 

200 

0 

19861987198819891990199119921993199419951996199719981999200020012002200320042005200620072008200920102011201220132014 

Year 

Middle Green Lower Green Lower Colorado 

Figure 5. Numbers of age-0 Colorado pikeminnow collected each year from three different
	

habitat reaches of river. A total of 2,892 Age-0 were collected in the lower Green River in
	

1988; the significance of strong Age-0 cohorts collected in the late 1980’s was discussed in
	

Bestgen et al. 2010. Data from Breen et al. 2014.
	

To summarize, in the Green River Subbasin, the Colorado pikeminnow subpopulation appears to 

have declined somewhat and the number of adults is below the level needed for recovery. 

Recruitment is quite variable over time, and has not exceeded adult mortality in all years when 

measured over the past two decades. The number of age-0 Colorado pikeminnow is also quite 

variable over time, but fewer have been captured, on average, since the year 2000 than prior to 

2000 (Figure 5). Colorado pikeminnow are generally distributed throughout the Green River 

Subbasin now nearly to the same extent that they were when they became listed, although their 

numbers have dwindled in the Yampa River and the reach in the White River above the Taylor 

Draw Dam is no longer occupied (see Baseline section). 

SAN JUAN RIVER 

Unlike the Green and upper Colorado River Basins, wild Colorado pikeminnow are extremely 

rare in the San Juan River. Between 1991 and 1995, 19 (17 adult and 2 juvenile) wild Colorado 

pikeminnow were collected in the San Juan River by electrofishing between RM 142 (the former 

Cudei Diversion) and Four Corners at RM 119 (Ryden 2000; Ryden and Ahlm 1996). The 

multi-threaded channel, habitat complexity, and mixture of substrate types in this area of the 

river appear to provide a diversity of habitats favorable to Colorado pikeminnow on a year-round 

basis (Holden and Masslich 1997). Estimates made during the seven-year research period 

between 1991 and 1997 suggested that there were fewer than 50 adult Colorado pikeminnow in a 

given year (Ryden 2000). 

12 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Monitoring for adult Colorado pikeminnow currently occurs every year on the San Juan River. 

In 2013, 149 Colorado pikeminnow were collected during monitoring from RM 180-77, the 

eighth consecutive year that more than 100 Colorado pikeminnow were caught in this reach 

(Schleicher 2014). However, only 7 of these fish were greater than 450 mm (18 in). In addition, 

19 Colorado pikeminnow greater than 450 mm (18 in) were collected during the non-native fish 

removal trips in 2013 (Duran et al. 2014). In order to downlist the species, the San Juan River 

population of Colorado pikeminnow must reach at least 1,000 Age-5 fish (Service 2002). 

The majority of individuals come from hatchery reared stocks supported by the San Juan River 

Recovery Implementation Program. This program has stocked more than 2 million age 0 and 

age 1+ fish in the San Juan River since 2002 (Furr and Davis 2009). River wide population 

estimates for age-2+ pikeminnow that have been in the San Juan River at least one year was 

approximately 4,600 and 5,400 individuals in 2009 and 2010, respectively (Duran et al. 2010; 

2013). However, because few adult Colorado pikeminnow were detected in the San Juan River, 

this population estimate largely consists of juveniles. Other Colorado pikeminnow abundance 

estimates exhibit substantial annual variation, likely due to the effects of short-term retention 

from recent stocking events, but no clear population trends were evident in the San Juan River 

Basin (Durst 2014). 

Successful Colorado pikeminnow reproduction was documented in the San Juan River in 1993, 

1995, 1996, 2001, 2004, 2007, 2009-2011, and 2013. A total of 58 larval Colorado pikeminnow 

were collected since 1993 (Farrington and Brandenburg 2014); however, there has been little to 

no recruitment documented in the San Juan River. A total of 48 Age-1+ Colorado pikeminnow 

were collected in 2013; all presumably the result of augmentation efforts (Farrington and 

Brandenburg 2014). Since 1998, Colorado pikeminnow were collected during small-bodied 

monitoring every year except 2001-2003; however, young of year (YOY) Colorado pikeminnow 

were stocked in each of these years prior to monitoring efforts so these fish were likely 

hatchery-reared (Service 2015b). Larval Colorado pikeminnow detections occurred throughout 

the San Juan River from Reach 4 (RM 106-130) downstream to Reach 1 (RM 0-16) (Farrington 

and Brandenburg 2014, Service 2015b). Franssen et al. (2007) found that maintenance of a 

natural flow regime favored native fish reproduction and provided prey at the appropriate time 

for Age-1 Colorado pikeminnow. 

Tissue samples from Colorado pikeminnow caught during research conducted under the 

Recovery Program have been analyzed as part of a basin-wide analysis of endangered fish 

genetics. The results of that analysis indicate that the San Juan River fish exhibit less genetic 

variability than the Green River and Colorado River populations, likely due to the small 

population size, but they were very similar genetically to pikeminnow from the Green, Colorado, 

and Yampa rivers (Morizot in litt. 1996). These data suggest that the San Juan population is 

probably not a separate genetic stock (Holden and Masslich 1997; Houston et al. 2010). 

To summarize, the Colorado pikeminnow was quite rare in the San Juan River in the 1990s, with 

an estimate of less than 50 adults. Since 2002, millions of young Colorado pikeminnow have 

been stocked into the river. Adult fish are still rather uncommon, however, and not nearly at the 

level yet needed for recovery. Despite low numbers of adults, reproduction is occurring to some 

extent, but recruitment is low. Most of the Colorado pikeminnow in the San Juan River are 

13 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

stocked juveniles. Through augmentation, Colorado pikeminnow are generally distributed 

throughout the San Juan River within critical habitat. 

2.1.4 Threats 

The Colorado pikeminnow was designated as an endangered species prior to enactment of the 

ESA, and therefore a formal listing package identifying threats was not assembled. Construction 

and operation of mainstem dams, nonnative fish species, and local eradication of native minnows 

and suckers in advance of new human-made reservoirs in the early 1960's were recognized as 

early threats (Service 2002a). According to the 2002 Recovery Goals for the species, the 

primary threats to Colorado pikeminnow populations are streamflow regulation and habitat 

modification (including cold-water dam releases, habitat loss, and blockage of migration 

corridors); competition with and predation by nonnative fish species; and pesticides and 

pollutants (Service 2002a). 

In the Upper Basin, 435 miles of Colorado pikeminnow habitat has been lost by reservoir 

inundation from Flaming Forge Reservoir on the Green River, Lake Powell on the Colorado 

River, and Navajo Reservoir on the San Juan River. Cold water releases from these dams have 

eliminated suitable habitat for native fishes, including Colorado pikeminnow, from river reaches 

downstream for approximately 50 miles below Flaming Gorge Dam and Navajo Dam. In 

addition to main stem dams, many dams and water diversion structures occur in and upstream 

from critical habitat that reduce flows and alter flow patterns, which adversely affect critical 

habitat. Diversion structures in critical habitat can divert fish into canals and pipes where the 

fish become permanently lost to the river system. It is unknown how many endangered fish are 

lost in irrigation systems, but in some years, in some river reaches, the majority of the river flow 

is diverted into unscreened canals. Peak spring flows in the Green River at Jensen, Utah, have 

decreased 13–35 percent and base flows have increased 10–140 percent due to regulation by 

Flaming Gorge Dam (Muth et al. 2000). 

Although a good portion of the recovery factor criteria (Service 2002a) are being addressed, 

nonnative fish species continue to be very problematic. Recovery Goals (Service 2002a, 2002b, 

2002c, 2002d) identified predation or competition by nonnative fish species as a primary threat 

to the continued existence or the reestablishment of self-sustaining populations of Colorado 

pikeminnow and the other three endangered fishes (Martinez et al. 2014). Predation and 

competition from nonnative fishes have been clearly implicated in the population reductions or 

elimination of native fishes in the Colorado River Basin (Dill 1944, Osmundson and Kaeding 

1989, Behnke 1980, Joseph et al. 1977, Lanigan and Berry 1979, Minckley and Deacon 1968, 

Meffe 1985, Propst and Bestgen 1991, Rinne 1991). Data collected by Osmundson and Kaeding 

(1991) indicated that during low water years nonnative minnows capable of preying on or 

competing with larval endangered fishes greatly increased in numbers. The Colorado River 

Basin is an altered riverscape and the interaction of native and nonnative species with 

non-adapted and competing life histories has contributed to what may be the largest expansion of 

nonnative fishes and displacement of native fishes in a North America river basin (Martinez et al. 

2014). More than 50 nonnative fish species were intentionally introduced in the Colorado River 

Basin prior to 1980 for sportfishing, forage fish, biological control and ornamental purposes 

14 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

(Minckley 1982, Tyus et al. 1982, Carlson and Muth 1989). The numerous nonnative species 

have begun to overshadow the 14 native fish species in the basin. 

Nonnative fishes compete with native fishes in several ways and include predation, habitat 

degradation, competition for resources, hybridization or disease transmission (Martinez et al. 

2014). The capacity of a particular area to support aquatic life is limited by physical habitat 

conditions and increasing the number of species in an area usually results in smaller populations 

of most species. The size of each species population is controlled by the ability of each life stage 

to compete for space and food resources and to avoid predation. Some life stages of nonnative 

fishes appear to have a greater ability to compete for space and food and to avoid predation in the 

existing altered habitat than do some life stages of native fishes. Tyus and Saunders (1996) cite 

numerous examples of both indirect and direct evidence of predation on eggs and larvae by 

nonnative species. 

The Service has begun discussions about the potential downlisting of Colorado pikeminnow, but 

the biggest obstacle may become the existing and future threat of invasive ecological impacts by 

nonnative aquatic species, particularly predatory sport fishes. The most problematic nonnative 

fish species in the basin have been identified as northern pike, smallmouth bass and channel 

catfish Ictalurus punctatus, although other nonnative percid, ictalurid, cyprinid, centrarchid and 

catastomid species continue to be problematic as well (Martinez et al. 2014). Arguably the 

biggest efforts of the Recovery Program today center on the control of nonnatives species. 

Threats from pesticides and pollutants include accidental spills of petroleum products and 

hazardous materials; discharge of pollutants from uranium mill tailings; and high selenium 

concentration in the water and food chain (Service 2002a). Accidental spills of hazardous 

material into occupied habitat can cause immediate mortality when lethal toxicity levels are 

exceeded. Researchers now speculate that mercury may pose a more significant threat to 

Colorado pikeminnow populations of the upper Colorado River basin than previously recognized 

(Service 2014b). Osmundson and Lusk (2012) have recently reported elevated mercury 

concentrations in Colorado pikeminnow muscle tissue; the highest concentrations were from the 

largest adults collected from the Green and Colorado River sub-basins. 

To summarize, Colorado pikeminnow habitat loss and degradation from dams and diversions 

constructed decades ago generated some of the early, primary impacts to the species. Most of 

the long-term impacts from these structures continue and are unlikely to change significantly in 

the near term. In the remaining suitable habitats, nonnative fish species pose a significant 

ongoing threat and challenge to recovery. Contaminants, including mercury and selenium, pose 

a threat as well, but the magnitude of this threat is in need of further investigation.

 2.2 Razorback Sucker 

2.2.1 Species description 

Like all suckers (family Catostomidae meaning “down mouth”), the razorback sucker has a 

ventral mouth. It is a robust, river catostomid endemic to the Colorado River Basin (Sigler and 

Sigler 1996; Service 2002b) and is the largest native sucker to the western United States. The 

15 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

species feeds primarily on algae, aquatic insects, and other available aquatic macroinvertebrates 

using their ventral mouths and fleshy lips (Sigler and Sigler 1996). Adults can be identified by 

olive to dark brown coloration above, with pink to reddish brown sides and a bony, sharp-edged 

dorsal keel immediately posterior to the head, which is not present in the young. The species can 

reach lengths of 3 ft and weights of 16 pounds (7.3 kg), but the maximum weight of recently 

captured fish is 11 to 13 pounds (5 to 6 kg) (Sigler and Sigler 1996; Service 2002b). 

Taxonomically, the species is unique, belonging to the monotypic genus Xyrauchen, meaning 

that razorback sucker is the only species in the genus (Service 2002b). Like Colorado 

pikeminnow, razorback suckers may live to be greater than 40 years. 

Historically, the razorback sucker occupied the mainstem Colorado River and many of its 

tributaries from northern Mexico through Arizona and Utah into Wyoming, Colorado, and New 

Mexico (Service 2002b). In the late 19th and early 20th centuries, it was abundant in the Lower 

Colorado River Basin and common in parts of the Upper Colorado River Basin, with numbers 

apparently declining with distance upstream (Service 2002b). Bestgen (1990) reported that this 

species was once so numerous that it was commonly used as food by early settlers and that a 

commercially marketable quantity was caught in Arizona as recently as 1949. Distribution and 

abundance of razorback sucker declined throughout the 20th century across its historic range, 

and the species now exists naturally only in a few small, unconnected populations or as dispersed 

individuals. Specifically, razorback sucker are currently found in small numbers in the Green 

River, upper Colorado River, and San Juan River sub-basins; the lower Colorado River between 

Lake Havasu and Davis Dam; Lakes Mead and Mohave; in small tributaries of the Gila River 

sub-basin (Verde River, Salt River, and Fossil Creek); and in local areas under intensive 

management such as Cibola High Levee Pond, Achii Hanyo Native Fish Facility, and Parker 

Strip (Service 2002b). 

The razorback sucker is listed as endangered under the Endangered Species Act of 1973, as 

amended (ESA; 16 U.S.C. 1531 et. seq.), under a final rule published on October 23, 1991 

(56 FR 54957). The Service finalized the latest recovery plan for the species in 2002 (2002b), 

but is currently drafting an updated revision. 

Fifteen reaches of the Colorado River system were designated as critical habitat for the razorback 

sucker totaling 2,776 km (1,724 mi) as measured along the center line of the river within the 

subject reaches. Designated critical habitat makes up about 49 percent of the species’ original 

range and occurs in both the Upper and Lower Colorado River Basins. In the Upper Basin, 

critical habitat is designated for portions of the Green, Yampa, Duchesne, Colorado, White, 

Gunnison, and San Juan Rivers. Portions of the Colorado, Gila, Salt, and Verde Rivers are 

designated in the Lower Basin. 

Separate, objective recovery criteria were developed for each of two recovery units (the Upper 

Colorado and Lower Colorado River Basins as delineated at Glen Canyon Dam) to address 

unique threats and site specific management actions necessary to minimize or remove those 

threats. This BOs focus is on the Upper Colorado River Basin recovery unit and will therefore 

describe the status of the razorback sucker in that unit. 

16 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2.2.2 Life history 

Except during periods before and after spawning, adult razorback sucker are thought to be 

relatively sedentary and have high fidelity to overwintering sites (Service 2002b). Adults 

become sexually mature at approximately 4 years and lengths of 400 mm (16 in.) (Zelasko et al. 

2009), at which time they travel long distances to reach spawning sites (Service 2002b). Mature 

adults breed in spring (mostly April–June) on the ascending limb of the hydrograph, 

congregating over cobble/gravel bars, backwaters, and impounded tributary mouths near 

spawning sites (Service 2002b; Snyder and Muth 2004; Zelasko et al. 2009). Flow and water 

temperature cues may play an important role prompting razorback adults to aggregate prior to 

spawning (Muth et al. 2000). Tyus and Karp (1990) and Osmundson and Kaeding (1991) 

reported off-channel habitats to be much warmer than the mainstem river and that razorback 

suckers presumably moved to these areas for feeding, resting, sexual maturation, spawning, and 

other activities associated with their reproductive cycle. 

Razorback sucker have high reproductive potential, with reported average female fecundity of 

approximately 50,000 to 100,000 eggs per fish (Service 2002b). They are broadcast spawners 

that scatter adhesive eggs over gravel-cobble substrate (Snyder and Muth 2004). High springs 

flows are important to egg survival because they remove fine sediment that can otherwise 

suffocate eggs. Hatching is limited at temperatures less than 10°C (50° F) and best around 20°C 

(68° F) (Snyder and Muth 2004). Eggs hatch 6 to 11 days after being deposited and larval fish 

occupy the sediment for another 4 to 10 days before emerging into the water column. Larval fish 

occupy shallow, warm, low-velocity habitats in littoral zones, backwaters, and inundated 

floodplains and tributary mouths downstream of spawning bars for several weeks before 

dispersing to deeper water (Service 2002b; Snyder and Muth 2004). It is believed that low 

survival in early life stages, attributed to loss of nursery habitat and predation by non-native 

fishes, causes extremely low recruitment in wild populations (Muth et al. 2000). Wydoski and 

Wick (1998) identified starvation of larval razorback suckers due to low zooplankton densities in 

the main channel and loss of floodplain habitats which provide adequate zooplankton densities 

for larval food as one of the most important factors limiting recruitment. 

Razorback sucker in the Upper Basin tend to be smaller and grow slower than those in the Lower 

Basin, reaching 100 millimeters (4 in.) on average in the first year (Service 2002b). Based on 

collections in the middle Green River, typical adult size centers around 510 mm (20 in.) (Modde 

et al. 1996). Razorback suckers are long-lived fishes, reaching 40+ years via high annual 

survival (Service 2002b). Adult survivorship was estimated to be 71 to 73 percent in the Middle 

Green River from 1980-1992 (Modde et al. 1996; Bestgen et al. 2002) and 76 percent from 1990 

to 1999 (Bestgen et al. 2002). 

Outside of the spawning season, adult razorback suckers occupy a variety of shoreline and main 

channel habitats including slow runs, shallow to deep pools, backwaters, eddies, and other 

relatively slow velocity areas associated with sand substrates (Tyus and Karp 1989, Osmundson 

and Kaeding 1989, Osmundson and Kaeding 1991, Tyus and Karp 1990). Their diet consists 

primarily of algae, plant debris, and aquatic insect larvae (Sublette et al. 1990). 

17 
 

 

 

 

 

 

 

 

 

 

 

 

2.2.3 Population dynamics 

Population estimates during the 1980 to 1992 period were on average between 300 and 600 wild 

fish (Modde et al. 1996). By the early 2000s, the wild population consisted of primarily aging 

adults, with steep decline in numbers caused by extremely low natural recruitment (Service 

2002b). Although reproduction was occurring, very few juveniles were found (Service 2002b). 

In the early part of the 2000s, population numbers were extremely low. Population estimates 

from sampling efforts in the Middle Green River had declined to approximately 100 by 2002, 

with researchers hypothesizing that wild fish in the Green River Basin could become extirpated 

because of lack of recruitment (Bestgen et al. 2002). Similarly, in the upper Colorado River, 

razorback sucker were exceedingly rare. In the 2002 recovery plan, razorback sucker were 

considered extirpated in the Gunnison River, where fish were last captured in 1976 (Service 

2002b). Similarly, in the Grand Valley, only 12 fish were collected from 1984 to 1990, despite 

intensive sampling (Service 2002b). No young razorback sucker were captured in the Upper 

Colorado River since the mid-1960s (Service 2002b). 

Razorback sucker likely occurred in the San Juan River as far upstream as Rosa, New Mexico 

(now inundated by Navajo Reservoir) (Ryden 1997). In the San Juan River we know of only two 

wild razorback suckers that were captured in 1976 in a riverside pond near Bluff, Utah, and one 

fish captured in the river in 1988, also near Bluff (Ryden 2006). No wild razorback sucker were 

found during the 7-year research period (1991–1997) of the San Juan River Basin Recovery 

Implementation Program (Ryden 2006). 

Because of the low numbers of wild fish, the Recovery Program has been rebuilding razorback 

sucker populations in the upper Colorado River Basin with hatchery stocks. Since 1995, over 

375,000 subadult razorback suckers have been stocked in the Green and upper Colorado River 

subbasins. Preliminary population estimates were generated for razorback sucker in the 

Colorado River as a whole (from Palisade, CO downstream to its confluence with the Green 

River), for adult fish > 400 mm TL (Figure 6). Although razorback sucker numbers have begun 

increasing in the past decade in the Green River subbasin due to stocking efforts, no standardized 

monitoring program to produce a population estimate has begun for the Green River subbasin 

(Service 2012a). 

18 
 

 

 

 

 

Adult Abundance Estimate 

3000 

2500 

2000 

1500 

1000 

Colorado River Subbasin: Razorback sucker Adults 

2008 2009 2010 2011 

Year 

Figure 6. Preliminary population estimates of the adult razorback sucker in the Colorado River 

(Palisade, CO to the confluence of the Green River). Error bars represent the 95 percent confidence 

intervals (Service 2015a). 

Razorback sucker stocked in the Green and Colorado Rivers have been recaptured in 

reproductive condition and often in spawning groups. Larval captures in the Green, Gunnison, 

and Colorado rivers document reproduction. Survival of larvae through their first year remains 

rare, largely due to a decrease in the availability of warm, food-rich floodplain areas and 

predation by a suite of nonnatives when the flood plain nursery habitats are available (Bestgen et 

al. 2011). However, occasional captures of juveniles (just over age-1) in the Green and Colorado 

rivers suggest that survival of early life stages is occurring. Collections of larvae by light trap in 

the middle Green River have been generally increasing since 2003; in 2013, the largest collection 

of light trapped larvae occurred (7,376; Figure 7, Service 2015a). 

500 

0 

2004 2005 2006 2007 

19 
 

 

 

 

 

 

 

 

0 

1000 

2000 

3000 

4000 

5000 

6000 

7000 

8000 

Number of Razorback Sucker Larvae 

Year 

Figure 7. Numbers of razorback sucker larvae collected in light traps in the middle Green River since 

1993. 

In the San Juan River, 130,473 razorback suckers were stocked from 1994 through 2012. The 

number of endangered fishes stocked in the San Juan River is reported annually (see 

http://www.fws.gov/southwest/sjrip/). After stocking in the San Juan River began, river wide 

razorback sucker population estimates of 268 in October 2000 (Ryden 2001) have since grown to 

1,200 in October 2004 (Ryden 2005), and to about 2,000 and 3,000 in 2009 and 2010, 

respectively (Duran et al. 2013). Additional mark-recapture data indicates increasing razorback 

sucker abundance estimates since 2009 (Durst 2014). However, because there is little to no 

documented recruitment in the San Juan River, this population increase should be attributed 

almost entirely to augmentation with hatchery-reared razorback suckers. 

Three razorback sucker stocked in the San Juan River near Farmington, NM, for the San Juan 

Recovery Program were captured between Moab, UT and the state line with Colorado in 2008. 

This demonstrates that exchange of stocked razorback sucker between the San Juan River and 

the Upper Colorado River is certain, and may have ramifications for recovery criteria. 

Researchers have confirmed that hundreds of razorback sucker are using both transitional inflow 

areas and fully lacustrine (lake-like) habitats in Lake Powell. Razorback sucker are spawning in 

the lake and there is now evidence that recruitment may be occurring (Service 2015a). While the 

role of Lake Powell in the recovery of razorback sucker is unclear, 75 individuals were detected 

in the San Juan arm of Lake Powell in 2011 (Francis et al. 2013). 

To summarize, the razorback sucker was facing extirpation in the Upper Colorado River basin 

approximately 20 years ago. To build population numbers in the Green, Colorado, and San Juan 

River subbasins, over a quarter of a million razorbacks have been stocked in these rivers. 

Stocking continues today and reproduction is occurring and increasing. Recruitment has also 

20 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

been documented recently, but appears to be the most limiting factor for re-establishing a 

self-sustaining population in the wild. 

2.2.4 Threats 

According to the 2002 Recovery Goals for the species, the primary threats to razorback sucker 

populations are streamflow regulation and habitat modification (including cold-water dam 

releases, habitat loss, and blockage of migration corridors); competition with and predation by 

nonnative fish species; and pesticides and pollutants (Service 2002b). No new threats have 

emerged since the completion of this document. The Service’s status review of razorback sucker 

completed in 2012 (Service 2012b) reported that 85 percent of the downlisting recovery factor 

criteria (Service 2002b) have been addressed to varying degrees; however, nonnative fish species 

continue to be problematic. 

Many researchers believe that nonnative species are a major cause for the lack of recruitment and 

that nonnative fish are the most important biological threat to the razorback sucker (e.g., McAda 

and Wydoski 1980, Minckley 1983, 59 FR 54957, Service 2002b, Muth et al. 2000). There are 

reports of predation of razorback sucker eggs and larvae by common carp, channel catfish, 

smallmouth bass, largemouth bass, bluegill, green sunfish, and red-ear sunfish (Marsh and 

Langhorst 1988, Langhorst 1989). 

Marsh and Langhorst (1988) found higher growth rates in larval razorback sucker in the absence 

of predators in Lake Mohave, and Marsh and Brooks (1989) reported that channel catfish and 

flathead catfish were major predators of stocked razorback sucker in the Gila River. Juvenile 

razorback sucker (average total length [TL] 171 mm [6.7 in.]) stocked in isolated coves along the 

Colorado River in California, suffered extensive predation by channel catfish and largemouth 

bass (Langhorst 1989). 

Carpenter and Mueller (2008) tested nine non-native species of fish that co-occur with razorback 

sucker and found that seven species consumed significant numbers of larval razorback suckers. 

The seven species consumed an average of 54 – 99 percent of the razorback sucker larvae even 

though alternative food was available (Carpenter and Mueller 2008). Lentsch et al. (1996) 

identified six species of nonnative fishes in the upper Colorado River Basin as threats to 

razorback sucker: red shiner, common carp, sand shiner, fathead minnow, channel catfish, and 

green sunfish. Smaller fish, such as adult red shiner, are known predators of larval native fish 

(Ruppert et al. 1993). Large predators, such as walleye, northern pike (Esox lucius), and striped 

bass, also pose a threat to subadult and adult razorback sucker (Tyus and Beard 1990). Until 

recently, efforts to introduce young razorback sucker into Lake Mohave have failed because of 

predation by nonnative species (Minckley et al. 1991, Clarkson et al. 1993, Burke 1994, Marsh et al. 

2003). 

Overall, the threats to the razorback sucker from nonnative fish are similar to those facing the 

Colorado pikeminnow, as described above. See the discussion on threats to the Colorado 

pikeminnow above for further information, particularly regarding the threat to all endangered 

fish due to predation from nonnative species. One threat from nonnative species peculiar to the 

razorback sucker is from hybridization. While hybridization between native and endangered 

razorback sucker may occur in the wild at a low level (Buth et al. 1987), the mass release of any 

21 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

native suckers hybridized with nonnative suckers would threaten gene pools of wild native or 

endangered suckers. McDonald et al. (2008) revealed that hybridization of native bluehead 

(Catostomus discobolus) and flannelmouth (Catostomus latipinnis) suckers with the nonnative 

white sucker (Catostomus commersonii) increased introgression between the native suckers. 

This mechanism could ultimately pose an increased threat of hybridization for razorback sucker 

(USFWS 2002b). 

Selenium, a trace element, is a natural component of coal and soils in many areas of the western 

United States and can be released to the environment by the irrigation of selenium-rich soils and 

the burning of coal in power plants with subsequent emissions to air and deposition to land and 

surface water. Contributions from anthropogenic sources have increased with the increases of 

world population, energy demand, and expansion of irrigated agriculture (Mayer et al. 2010). 

Selenium can enter surface waters through erosion, leaching, and runoff. Excess selenium in fish 

have been shown to have a wide range of adverse effects including mortality, reproductive 

impairment, effects on growth, and developmental and teratogenic effects including edema and 

finfold, craniofacial, and skeletal deformities (Lemly 2002, Hamilton et al. 2004; Holm et al 

2005). Excess dietary selenium causes elevated selenium concentrations to be deposited into 

developing eggs, particularly the yolk (Buhl and Hamilton 2000, Lemly 2002, Janz 2010). If 

concentrations in the egg are sufficiently high, developing proteins and enzymes become 

dysfunctional, leading to embryo deformation and a higher risk of mortality. Embryos that do 

survive, hatch, and grow may experience an elevated risk of predation as small fish. Of all the 

endangered fish in the Colorado River system, concern regarding elevated selenium levels is 

greatest for the razorback sucker (Hamilton et al. 2002; Osmundson et al. 2010). 

Hamilton (1999) hypothesized that historic selenium contamination of the upper and lower 

Colorado River basins contributed to the decline of these endangered fish by affecting their 

overall reproductive success, including loss of eggs and larvae. Selenium concentrations in 

whole-body fish in the Colorado River Basin have been among the highest in the nation 

(Hamilton 1999). Several Department of the Interior National Irrigation Water Quality Program 

(NIWQP) studies in the Colorado River Basin have reported elevated levels of selenium in 

water, sediment, and biota, including fish (Hamilton 1999). In the NIWQP studies of 25 areas in 

the 15 western states, the middle Green River ranked 3rd for the highest median water 

concentration of selenium, 1st for sediment, and 1st for fish, and 14th for birds. The Gunnison 

River Basin/Grand Valley ranked 4th for the highest median water concentration of selenium, 2nd 

for sediment, 7th for fish, and 1st for birds (Engberg, 1998, as seen in Hamilton 1999). Unlike the 

Green, Gunnison, and Colorado Rivers, high selenium levels have not been reported in the 

Yampa and White Rivers (see section 3.3 Contaminants in the Action Area below for further 

discussion). While selenium has been more the focus of contaminants research involving the 

razorback sucker, mercury, which can pose a threat to any animal species, could also pose a 

threat at elevated concentrations. Because the razorback sucker is not a top predator, as is the 

Colorado pikeminnow, we expect mercury bioaccumulation (through prey) to pose less of a 

problem for this species. 

To summarize, razorback sucker habitat loss and degradation from dams and diversions 

constructed decades ago posed some of the early, primary impacts to the species. Most of the 

long-term impacts from these structures continue and are unlikely to change significantly in the 

22 
 

 

 

 

 

 

 

 

 

 

 

 

 

near term. In the remaining suitable habitats, nonnative fish species pose a significant ongoing 

threat and challenge to recovery. Contaminants, including mercury and selenium, pose a threat 

as well, but the magnitude of this threat is in need of further investigation. 

2.3 Humpback Chub 

2.3.1 Species description 

The humpback chub is a medium-sized freshwater fish of the minnow family endemic to the 

Colorado River basin. The species evolved around 3 to 5 million years ago (Sigler and Sigler 

1996). The pronounced hump behind its head gives the humpback chub a striking, unusual 

appearance. It has an olive-colored back, silver sides, a white belly, small eyes, and a long snout 

that overhangs its jaw (Sigler and Sigler 1996). This fish can grow to nearly 500 mm (20 in.) 

and may survive more than 30 years in the wild (Service 2002c). The humpback chub does not 

have the swimming speed or strength of species such as the Colorado pikeminnow. Instead, it 

uses its large fins to "glide" through slow-moving areas, feeding on insects. 

Historic distribution is surmised from various reports and collections that indicate the species 

inhabited canyons of the Colorado River and four of its tributaries: the Green, Yampa, White, 

and Little Colorado Rivers. Presently the species occupies about 68 percent of its historic 

habitat. Historic to current abundance trends are unclear because historic abundance is unknown 

(Service 2002c). 

The Office of Endangered Species first included the humpback chub in the List of Endangered 

Species on March 11, 1967 (32 FR 4001). Subsequently, it was considered endangered under 

provisions of the Endangered Species Conservation Act of 1969 (16 U.S.C. 668aa) and was 

included in the United States List of Endangered Native Fish and Wildlife issued on June 4, 1973 

(38 FR No. 106). It is currently protected under the Endangered Species Act of 1973 as an 

endangered species throughout its range (ESA; 16 U.S.C. 1531 et. seq.). The Service finalized 

the latest recovery plan for the species in 2002 (Service 2002c), but is currently drafting an 

updated revision. 

Separate, objective recovery criteria were developed for each of two recovery units (the Upper 

Colorado and Lower Colorado River Basins as delineated at Glen Canyon Dam) to address 

unique threats and site-specific management actions necessary to minimize or remove those 

threats. This biological opinion’s focus is on the Upper Colorado River Basin recovery unit and 

will therefore describe the status of the humpback chub in that unit. 

2.3.2 Life History 

Like other large desert river fishes, the humpback chub is an obligate warm-water species that 

requires relatively warm temperatures for spawning, egg incubation, and survival of larvae. 

Unlike Colorado pikeminnow and razorback sucker, which are known to make extended 

migrations of up to several hundred miles to spawning areas, humpback chubs do not appear to 

make extensive migrations. Instead, humpback chub live and complete their entire life cycle in 

canyon-bound reaches of the Colorado River mainstem and larger tributaries characterized by 

23 
 

 

 

 

 

 

 

 

deep water, swift currents, and rocky substrates (Service 2002c). Individuals show high fidelity 

for canyon reaches and move very little. 

Mature humpback chub typically spawn on the descending hydrograph between March and July 

in the Upper Basin (Karp and Tyus 1990). Humpback chub are broadcast spawners who may 

mature as young as 2 to 3 years old. Eggs incubate for three days before swimming up as larval 

fish (Service 2002c). Egg and larvae survival are highest at temperatures close to 19 to 22oC 

(Service 2002c). Unlike larvae of other Colorado River fishes (e.g., Colorado pikeminnow and 

razorback sucker), larval humpback chub show no evidence of long-distance drift (Robinson et 

al.1998). 

Recruitment appears to be successful in all known Upper Basin populations (Service 2002c). 

Survival of humpback chub during the first year of life is low, but increases through the first 2 to 

3 years of life with decreased susceptibility to predation, starvation, and environmental changes. 

Survival from larvae to adult life stages was estimated at 0.1 percent (0.001) (Service 2002c). 

Survival of adults is high, with estimates approximating 75 percent based on Grand Canyon 

adults (Service 2002c). 

Growth rates of humpback chub vary by populations, with fish in the Upper Basin growing 

slower than those in the Grand Canyon (Service 2002c). Individuals in Cataract Canyon were 

50, 100, 144, 200, 251, and 355 mm total length from 1 to 6 years, respectively (Service 2002c). 

Based on sexual maturity and age-to-length ratios, adults are classified as those fish 200 mm or 

longer. Maximum life span is estimated to be 30 years in the wild. 

Humpback chub move substantially less than other native Colorado River fishes, with studies 

consistently showing high fidelity by humpback chub for specific riverine locales occupied by 

respective populations. Despite remarkable fidelity for given river regions, individual humpback 

chub adults are known to move between populations. Movement by juveniles is not as well 

documented as for adults, but is also believed to be limited in distance. For example, no 

out-migration by young fish is seen from population centers such as Black Rocks and Westwater 

Canyon. 

2.3.3 Population dynamics 

Currently, five wild humpback chub populations occur upstream of Glen Canyon Dam and two 

downstream. In the Upper Colorado River Basin the two most stable populations are found near 

the Colorado/Utah border: one at Westwater Canyon in Utah; and one in an area called Black 

Rocks, in Colorado (Upper Colorado River Endangered Fish Recovery Program and San Juan 

River Basin Recovery Implementation Program 2010). Smaller numbers in the Upper Basin 

were found in the Yampa and Green Rivers in Dinosaur National Monument, Desolation and 

Gray Canyons on the Green River in Utah, and Cataract Canyon on the Colorado River in Utah 

(Service 2002c). The two populations in the Lower Colorado River Basin occur in the mainstem 

Colorado and Little Colorado Rivers. The Little Colorado River population, found in the Grand 

Canyon, is the largest known population, harboring up to 10,000 fish (Service 2002c). 

24 
 

 

 

 

 

 

 

Recovery goal downlisting demographic criteria (USFWS 2002c) for humpback chub require 

each of five populations in the upper Colorado River basin to be self-sustaining over a 5-year 

period, with a trend in adult point estimates that does not decline significantly. Secondarily, 

recruitment of age-3 (150–199 mm TL) naturally produced fish must equal or exceed mean adult 

annual mortality. In addition, one of the five populations (e.g., Black Rocks/Westwater Canyon 

or Desolation/Gray Canyons) must be maintained as a core population such that each estimate 

exceeds 2,100 adults (estimated minimum viable population number). 

Population estimates for four of the five upper basin population are shown in Figure 8. No 

population estimate is available for the Yampa/Green River population in Dinosaur National 

Monument (see Baseline section for further details). The Desolation/Gray Canyons population 

of wild adults was estimated at 1,300 in 2001, 2,200 in 2002, and 940 in 2003 (Jackson and 

Hudson 2005). Sampling in 2001 and 2002 was conducted in summer, whereas beginning in 

2003, sampling was shifted to fall to avoid capturing Colorado pikeminnow that use Desolation 

Canyon for spawning. In a report on 2006–2007 estimates, researchers (Badame 2012) indicated 

that this population was trending downward. Badame (2012) linked declining catch of 

humpback chub in the upper portions of Desolation Canyon in the 2006–2007 estimates with 

increasing densities of nonnative smallmouth bass. Utah Division of Wildlife Resources 

(UDWR) researchers recommended securing a representative sample of adults in captivity. In 

2009, 25 adults were taken to Ouray National Fish Hatchery. In 2011, six sites throughout 

Desolation Canyon were monitored for adults, 55 individual adults were encountered, but 

recaptures were too few to calculate a population estimate. 

25 
 

 

 

 

 

 

 

 

 

 

 

Cataract Canyon 

0 

200 

400 

600 

800 

1000 

1200 

1400 

1600 

1800 

2002 2003 2004 2005 2006 

Adult Abundance Estimate 

Figure 8. Adult humpback chub population estimates with confidence intervals for four 

populations in the upper Colorado River Basin (note that the scale differs among the graphs for 

the different populations). Clockwise from upper left: Desolation-Gray Canyons (from Badame 

2011, 2012; Service 2015a); Black Rocks (from Francis and McAda 2011); Westwater Canyon 

(from Elverud 2011); and Cataract Canyon (from Badame 2008). 

On the Colorado River of the upper Colorado River basin, three humpback chub populations are 

recognized. Black Rocks and Westwater Canyon have enough exchange of individuals that they 

are considered a single core population. In Black Rocks, estimates of wild adults have varied 

from about 800 in 1998, 900 in 1999, and 500 in 2000 and 2003 (Figure 8) (McAda 2007). The 

most recent estimates, in 2007–2008 were 345 and 287, respectively. During the fall of 2011 

and 2012, 78 and 112 individual adult humpback chub were caught respectively - similar to the 

numbers caught in 2007 and 2008 (61 and 74, respectively). Population estimates for Black 

Rocks for 2011 and 2012 were 379 and 403, respectively. Researchers caution that 78 

largemouth bass and the same number of gizzard shad were collected in Black Rocks in 2012. 

This represents a ten-fold increase over the 2011 catch. The Westwater Canyon estimates of 

wild adults range from about 4,700 in 1998 to 2,500 in 1999, 2000, and 2003 (Jackson and 

Hudson 2005). The 2007–2008 estimates were about 1,750 and 1,300. The large declines in 

humpback chub densities in both Black Rocks and Westwater Canyons occurred in the late 

1990’s and are not attributed to more recent increases of nonnative predators in the Colorado 

River. 

In 2008, the core population (Black Rocks / Westwater combined) dropped below the population 

size downlist criterion (MVP = 2,100 adults) for the first time. In 2011, we saw some recovery 

in those populations where the estimate for adults in Westwater Canyon alone was 1,467; 

26 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

however, UDWR reported 1,315 adults in 2012. The core population estimates in 2011 and 2012 

were 1846 and 1718, respectively (Figure 9). Population estimates in both Black Rocks and 

Westwater canyons declined dramatically during the first population estimation rotation in the 

late 1990s, but have remained relatively stable since that time. Colorado State University’s 

recent robust population estimate analysis more clearly indicated that declines in the Westwater 

and Black Rock humpback chub populations are due to lapses in recruitment (i.e. adult survival 

rates have remained stable). Principle investigators agree that reinitiating an age-0 monitoring 

component is advisable. It should be noted that whatever is affecting humpback chub 

recruitment has not affected sympatric populations of native roundtail chub; roundtail chubs 

populations in both canyons have remained stable or have increased since population estimation 

started. In addition to the potential and recent negative interactions between humpback chub and 

nonnative predators discussed above, both the Westwater and Black Rocks populations are at 

risk of potential chemical contamination due to the proximity of a railroad located on the right 

bank of the Colorado River which at times transports toxic substances. 

Black Rocks & Westwater Canyons "Core Population" Estimates 

Combined Population Estiamte 

0 

1000 

2000 

3000 

4000 

5000 

6000 

7000 

8000 

9000 

1996 1998 2000 2002 2004 2006 2008 2010 2012 2014 

Figure 9. Combined population estimates for humpback chub in Black Rocks and Westwater 

Canyon based on a robust open model created by Dr.’s Bestgen and White, Colorado State 

University. The 2002 Recovery Goal downlist criteria for these combined (“core population”) 

estimates is 2,100 adults. 

The Cataract Canyon humpback chub population is small, with estimates of about 150 wild 

adults in 2003 and 66 in 2005 (Badame 2008). Estimates are difficult to obtain in Cataract; 

therefore, catch-per-unit-effort (CPUE) has been determined to be an effective replacement 

(began in 2008 on a 2-years-on, 2-years-off sampling regime). In 2011, UDWR reported that the 

Cataract population appears to be stable with CPUE ranging between 0.010 and 0.035 

fish/net-hour. Despite additional effort to sample below Big Drop Rapid, no additional 

humpback chub were encountered in the new riverine habitat created by low Lake Powell levels. 

27 
 

 

 

 

 

 

 

 

 

 

 

 

 

2.3.4 Threats 

The humpback chub was designated as an endangered species prior to enactment of the ESA, and 

therefore a formal listing package identifying threats was not assembled. Construction and 

operation of mainstem dams, nonnative fish species, and local eradication of native minnows and 

suckers in advance of new human-made reservoirs in the early 1960's were recognized as early 

threats (Service 2002c). According to the 2002 Recovery Goals for the species, the primary 

threats to humpback chub are streamflow regulation, habitat modification, predation by 

non-native fish species, parasitism, hybridization with other native Gila species, and pesticides 

and pollutants (Service 2002c). No new threats have emerged since the completion of this 

document. The Service’s status review of humpback chub completed in 2011 (Service 2011b) 

reported that 60 percent of the recovery factor criteria (Service 2002c) have been addressed to 

varying degrees; however, nonnative fish species and issues dealing with the potential chemical 

contamination of the river from spills and pipelines continue to be problematic. Overall, the 

threats to the humpback chub from nonnative fish are similar to those facing the Colorado 

pikeminnow, as described above. See the discussion on threats to the Colorado pikeminnow 

above for further information, particularly regarding the threat to all endangered fish due to 

predation from nonnative species. 

To summarize, humpback chub habitat loss and degradation from dams and diversions 

constructed decades ago posed some of the early, primary impacts to the species. Most of the 

long-term impacts from these structures continue and are unlikely to change significantly in the 

near term. In the remaining suitable habitats, nonnative fish species pose a significant ongoing 

threat and challenge to recovery. Contaminants, including mercury and selenium, may pose a 

lesser threat as well, but the magnitude of this threat is in need of further investigation. 

2.4 Bonytail 

2.4.1 Species description 

The bonytail is a medium-sized freshwater fish in the minnow family, endemic to the Colorado 

River Basin. The species evolved around 3 to 5 million years ago (Sigler and Sigler 1996). 

Individuals have large fins and a streamlined body that typically is very thin in front of the tail. 

They have a gray or olive colored back, silver sides, and a white belly (Sigler and Sigler 1996). 

The mouth is slightly overhung by the snout and there is a smooth low hump behind the head 

that is not as pronounced as the hump on a humpback chub. A very close relative to the 

roundtail chub (Gila robusta), bonytail can be distinguished by counting the number of rays in 

the fins, with bonytail having 10 dorsal and anal fin rays (Sigler and Sigler 1996). The fish can 

grow to be 600 mm (24 in.) and are thought to live as long as 20 to 50 years (Sigler and Sigler 

1996). Little is known about the specific food and habitat of the bonytail because the species 

was extirpated from most of its historic range prior to extensive fishery surveys, but it is 

considered adapted to mainstem rivers, residing in pools and eddies, while eating terrestrial and 

aquatic insects (Service 2002d). 

Bonytail were once widespread in the large rivers of the Colorado River Basin (Service 2002a). 

The species experienced a dramatic, but poorly documented, decline starting in about 1950, 

28 
 

 

 

 

 

 

 

 

 

 

 

 

following construction of mainstem dams, introduction of nonnative fishes, poor land-use 

practices, and degraded water quality Service 2002d). Population trajectory over the past 

century and reasons for decline are unclear because lack of basin-wide fishery investigations 

precluded accurate distribution and abundance records. 

Bonytail are now rarely found in the Green and Upper Colorado River sub-basins and are the 

rarest of all the endangered fish species in the Colorado River Basin. In fact, no wild, 

self-sustaining populations are known to exist upstream of Lake Powell. In the last decade only 

a handful of bonytail were captured on the Yampa River in Dinosaur National Monument, on the 

Green River at Desolation and Gray canyons, and on the Colorado River at the Colorado/Utah 

border and in Cataract Canyon. In the lower basin, bonytail exist in Lake Mohave and Lake 

Havasu. 

The bonytail is currently listed as endangered under the Endangered Species Act of 1973, as 

amended (ESA; 16 U.S.C. 1531 et. seq.), under a final rule published on April 23, 1980 (45 FR 

27710). The Service finalized the latest recovery plan for the species in 2002 (U.S. Fish and 

Wildlife Service 2002d), but is currently drafting an updated revision. 

The Service designated seven reaches of the Colorado River as critical habitat for the bonytail on 

March 21, 1994 (59 FR 13374). These reaches total 499 km (312 mi) as measured along the 

center line of each reach. Portions of the Green, Yampa, and Colorado Rivers are designated as 

critical habitat, representing about 14 percent of the species’ historic range. 

Separate, objective recovery criteria were developed for each of two recovery units (the Upper 

Colorado and Lower Colorado River Basins as delineated at Glen Canyon Dam) to address 

unique threats and site specific management actions necessary to minimize or remove those 

threats. This biological opinion’s focus is on the Upper Colorado River Basin recovery unit and 

will therefore describe the status of the humpback chub in that unit. 

2.4.2 Life history 

Natural reproduction of bonytail was last documented in the Green River in 1959, 1960, and 

1961 at water temperatures of 18°C (Service 2002d). Similar to other closely related Gila 

species, bonytail in rivers probably spawn in spring over rocky substrates. While age at sexually 

maturity is unknown, they are capable of spawning at 5 to 7 years old. Recruitment and survival 

estimates are currently unknown because populations are not large enough for research to occur. 

Individuals in Lake Mohave have reached 40 to 50 years of age (Service 2002d), but estimates 

for river inhabiting fish are not available. 

2.4.3 Population dynamics 

Bonytail are so rare that it is currently not possible to conduct population estimates. In response 

to the low abundance of individuals, the Recovery Program is implementing a stocking program 

to reestablish populations in the Upper Basin; stocking goals were met or exceeded from 

2008-2010 (Upper Colorado River Endangered Fish Recovery Program and San Juan River 

29 
 

 

 

 

 

 

 

 

 

 

 

 

Basin Recovery Implementation Program 2010). Since 1996, over 380,000 tagged bonytail 

subadults have been stocked in the Green and upper Colorado River subbasins. 

To date, most stocked bonytail do not appear to survive very long after release into a given river. 

To date, the bonytail stocking program has not been as successful as the razorback sucker 

stocking program. Researchers continue to experiment with pre-release conditioning and 

exploring alternative release sites to improve their survival. Since 2009, an increasing number of 

bonytail have been detected at several locations throughout the Upper Colorado River Basin 

where stationary tag-reading antennas are used. During high spring flows in 2011, more than 

1,100 bonytail (16.6 percent of the 6,804 stocked in early April of that year) were detected by 

antenna arrays in the breach of the Stirrup floodplain on the Green River. The Price Stubb 

antenna array on the Colorado River detected 138 bonytail between October 2011 and September 

2013. The fish detected in fall 2011 had been stocked above Price-Stubb in Debeque Canyon, 

but in spring 2012, some of those fish were moving upstream through the fish passage. 

2.4.4 Threats 

The bonytail was designated as an endangered species under a final rule published 

April23, 1980, (45 FR 27710–27713). Reasons for decline of the species were identified as the 

physical and chemical alteration of their habitat and introduction of exotic fishes. The 1990 

Bonytail Chub Recovery Plan further stated that the decline of the bonytail chub is attributed to 

stream alteration caused by construction of dams, flow depletion from irrigation and other uses, 

hybridization with other Gila, and the introduction of nonnative fish species. Hence, the primary 

threats to bonytail populations are streamflow regulation and habitat modification (including 

cold-water dam releases, habitat loss, and blockage of migration corridors); competition with and 

predation by nonnative fish species; hybridization; and pesticides and pollutants (Service 2002d). 

No new threats have emerged since the 2002 recovery goals were published. The Service’s 

status review of bonytail completed in 2012 (USFWS 2012c) reported that 72 percent of the 

recovery factor criteria (USFWS 2002d) have been addressed to varying degrees. 

Overall, the threats to the bonytail from nonnative fish are similar to those facing the Colorado 

pikeminnow, as described above. See the discussion on threats to the Colorado pikeminnow 

above for further information, particularly regarding the threat to all endangered fish due to 

predation from nonnative species. 

No known wild, self-sustaining populations of bonytail exist in the Upper Colorado River Basin. 

Since listing, bonytail were stocked in the Upper Basin to augment populations, but recruitment 

and natural reproduction have not been documented. Recent recaptures of bonytail in the Green 

and Colorado Rivers a year after stocking provide promising results that individuals are 

surviving. 

To summarize, bonytail habitat loss and degradation from dams and diversions constructed 

decades ago posed some of the early, primary impacts to the species. Most of the long-term 

impacts from these structures continue and are unlikely to change significantly in the near term. 

In the remaining suitable habitats, nonnative fish species pose a significant ongoing threat and 

30 
 

 

 

 

 

 

 

 

 

 

 

challenge to recovery. Contaminants may pose a lesser threat as well, but the magnitude of this 

threat is in need of further investigation. 

2.5 Critical Habitat 

Critical habitat was designated for all four endangered fish in 1994 (59 FR 13374). It consists of 

river segments and associated areas within the 100-year floodplain within each species' historical 

range. Different reaches have been designated for each species, and are discussed for each 

species within the action area in the Baseline section below. Figure 6 shows critical habitat for 

the Colorado pikeminnow, which is confined to the upper Colorado River Basin (above Lake 

Powell). Critical habitats for the other three endangered fish are found in the lower Colorado 

River Basin as well. Within the upper Colorado River Basin, critical habitats for the other three 

endangered fish are largely subsets of that designated for the Colorado pikeminnow (i.e., shorter 

reaches) (see 59 FR 13374 for maps of all critical habitat units designated for each endangered 

fish). 

Figure 6. Designated critical habitat for the Colorado pikeminnow. 

Critical habitat is defined as specific geographic areas, whether occupied by a listed species or 

not, that are essential for its conservation and that are formally designated by rule. In the 

Colorado and elsewhere, many of these critical habitat reaches overlap. Critical habitat for the 

humpback chub and bonytail are primarily canyon-bound reaches, while critical habitat for the 

31 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Colorado pikeminnow and razorback sucker include long stretches of river required for 

migration corridors and larval fish drift. 

Concurrently with designating critical habitat, the Service identified primary constituent 

elements (PCEs) of the habitat, which are identical for all four endangered fish species. PCEs 

are physical or biological features essential to the conservation of a species for which its 

designated or proposed critical habitat is based on, such as: space for individual and population 

growth, and for normal behavior; food, water, air, light, minerals, or other nutritional or 

physiological requirements; cover or shelter; sites for breeding, reproduction, rearing of 

offspring, germination, or seed dispersal; and habitats that are protected from disturbance or are 

representative of the species historic geographic and ecological distribution. The PCEs of 

critical habitat are the same for each of the four endangered fish within the Colorado River system. 

The PCEs include: 

Water: a quantity of water of sufficient quality (i.e., temperature, dissolved oxygen, lack of 

contaminants, turbidity, etc.) that is delivered to a specific location in accordance with a 

hydrologic regime that is required for the particular life stage for the species; 

Physical habitat: areas of the Colorado River system that are inhabited or potentially habitable 

for spawning, feeding, rearing, as a nursery, or corridors between these areas, including oxbows, 

backwaters, and other areas in the 100-year floodplain which when inundated provide access to 

spawning, nursery, feeding, and rearing habitats; and, 

Biological environment: adequate food supply and ecologically appropriate levels of predation 

and competition. 

2.6 Climate Change 

The EPA (2015) has predicted that Colorado will experience the following general trends related 

to climate change (summarized from OSMRE EA, p. 4-19): 

• The region will experience warmer temperatures with less snowfall. 

• Temperatures are expected to increase more in winter than in summer, more at night than in 

the day, and more in the mountains than at lower elevations. 

• Earlier snowmelt will result in earlier peak stream flows, weeks before the peak needs of 

ranchers, farmers, recreationalist, and others. In late summer, rivers, lakes, and reservoirs 

will be drier. 

• More frequent, more severe, and possibly longer-lasting droughts will occur. 

• Drier conditions will reduce the range and health of ponderosa and lodge pole pine forests, 

and increase the susceptibility to fire. 

Climate change has and will occur and affect endangered species and their habitat over the 

duration of the Proposed Action and beyond, whether or not the Proposed Action occurs. 

32 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Climate change over the coming decades and centuries has the potential to affect many 

organisms, including freshwater fish. EPA (2015) discussed a change in precipitation patterns, 

including the timing, intensity, and type of precipitation received; runoff patterns based on the 

amount of precipitation falling as snow and when snowmelt occurs; and atmospheric 

temperatures, which exhibit a strong influence on water temperatures. 

According to the National Research Council (2012), air temperature has increased by 1.4°C in 

the last century. The Colorado River Basin has warmed more than any other part of the U.S. 

(Service 2015b). Drier conditions, warmer air temperatures, and earlier spring runoff peaks are 

expected to affect water availability and the quality and quantity of fish habitat, which are 

important elements to native fish in action area. It is impossible to predict with any degree of 

precision, however, to what extent endangered fish and their habitats will be affected. 

However, given that these endangered fish live in main-stem rivers, generally downstream from 

most of the dams on tributaries within the Upper Colorado River Basin, it is possible that some 

of the effects of climate change in the area could be moderated by dam releases, particularly if 

they are done to benefit endangered fish. For example, earlier snow melt and runoff in upper 

tributaries would influence stream levels above downstream dams, but downstream flows are 

controlled by dam releases. Warming water temperatures would be counteracted to some extent 

by cold water releases from the base of a dam. These endangered fish are not cold water 

dependent fish; cool water temperatures may be more limiting to some or all of them than warm 

water temperatures (on the up-river limits of their distribution). Higher summer-time base flows 

as a result of dam releases also work to keep water temperatures from climbing as high as they 

otherwise would under lower flows. Most or all of the reaches occupied by these endangered 

fish are influenced by upstream dams. 

These dams, whether main-stem dams or on up-basin tributaries, have numerous negative effects 

on the endangered fish and their habitats. However, in the face of a warming and drying climate, 

some of the potentially negative effects of climate change (e.g., change in timing of runoff, water 

temperature increase, drop in base flows) could be ameliorated by dam releases. Alternatively, 

some of the negative effects of existing dams may be ameliorated by climate change (e.g., 

warming of below-dam cold waters, a lower water level in Lake Powel resulting in the eventual 

emergence of more potentially habitable river miles on the Colorado and San Juan Rivers). 

Aside from the interaction of dams and climate change, increasing water temperatures could 

potentially extend suitable habitat for one or more of the endangered fish (non-canyon bound 

species) up river into what may currently be too cold. 

See also Climate Change in the Action Area (section 3.4) within the Baseline below. 

3.0 ENVIRONMENTAL BASELINE 

The environmental baseline includes the past and present impacts of all Federal, State, and 

private actions and other human activities in the action area; the anticipated impacts of all 

proposed Federal projects in the action area that have already undergone formal section 7 

consultation; and the impact of State or private actions contemporaneous with the consultation 

process. 

33 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

The action area is defined at 50 CFR 402 to mean "all areas to be affected directly or indirectly 

by the Federal action and not merely the immediate area involved in the action." For the 

purposes of this consultation, the action area, as defined earlier, has been defined to include the 

mercury deposition airshed (Figure 1 in BA), along with endangered fish critical habitats within 

and downstream from the airshed along the Yampa and White Rivers. 

3.1 Critical Habitat In The Action Area 

The PCEs of critical habitat are identical for all four endangered fish species and are discussed in 

section 2.5 above. Descriptions of critical habitats within the action area are provided below. 

The BA provides a map of showing critical habitat in the action area. 

3.1.1 Colorado pikeminnow 

Critical habitat designated for the Colorado pikeminnow along the Yampa River extends from 

the Highway 13 Bridge over the Yampa River down to the confluence with the Green River. 

This is an undammed, free-flowing, approximately 145-mile reach. Along the White River, it 

extends from Rio Blanco Lake down to the confluence with the Green River in Utah. Within this 

reach, Taylor Draw Dam above the town of Rangely, Colorado, built in 1984, completely blocks 

fish passage. Although Colorado pikeminnow previously occupied the White River above 

Taylor Draw Dam, that is no longer the case. Colorado pikeminnow currently occupy the 

106-mile reach below Taylor Draw Dam. 

3.1.2 Razorback sucker 

Critical habitat designated for the razorback sucker along the Yampa River extends from the 

mouth of Cross Mountain Canyon to the confluence with the Green River in Utah. This 

approximately 55-mile reach is largely within Dinosaur National Monument. Critical habitat has 

been designated for the razorback sucker along the lower 24 miles of the White River as it 

travels through the Uintah and Ouray Indian Reservation. 

3.1.3 Humpback chub and bonytail 

Critical habitats designated for the humpback chub and bonytail along the Yampa River are 

identical and extend 45 miles from the boundary of Dinosaur National Monument downstream to 

its confluence with the Green River. No critical habitat has been designated along the White 

River for the humpback chub or bonytail. Critical habitats for all four endangered fish continue 

out of the action area downstream along the Green River below its confluence with the Yampa 

River and below its confluence with the Green River. 

3.2 Endangered Fish In The Action Area 

Broader population estimates, which may include fish in the action area, are provided above in 

the Status of the Species section. Additional information specific to the endangered fish 

populations and their threats in the Yampa and White Rivers is included here. 

34 
 

 

 

 

 

 

 

 

 

 

 

3.2.1 Colorado pikeminnow 

Low numbers of Colorado pikeminnow were captured in the Yampa River during population 

estimation sampling in 2011-2013. Bestgen et al. (2013, p.4) states, “Captures were particularly 

low in the Yampa River, where only six Colorado pikeminnow were captured, in spite of high 

effort associated with northern pike and smallmouth bass removal sampling, as well as regular 

Colorado pikeminnow sampling passes (up to eight sampling passes).” And for 2013, only 8 

Colorado pikeminnow were captured in the Yampa River, in spite of high effort, once again. 

Preliminary population estimates based on these captures are shown in Figure 7. 

A somewhat higher number of Colorado pikeminnow currently occupy the White River. 

Captures in the White River during population estimation sampling between 2011-2013 ranged 

from 50-96 fish (Bestgen et al. 2013). Final population estimates based on these captures are not 

yet available. However, numbers of Colorado pikeminnow have been larger in the past. Adult 

Colorado pikeminnow abundance estimates in the White River declined from 1,115 animals in 

2000 to 465 animals in 2003. Adult Colorado pikeminnow resident to the White River are 

known to spawn in the Green and Yampa rivers. However, in 2011, researchers documented for 

the first time Colorado pikeminnow spawning in the White River. Juvenile and subadult 

Colorado pikeminnow also utilize the White River on a year-round basis (Recovery Program 

2015). 

As part of the process of revising the 2002 Colorado Pikeminnow Recovery Goals into recovery 

plans, a recovery team for Colorado pikeminnow was assembled in late 2012 consisting of 

species and threat experts. During initial discussions in November 2012, the Recovery Team 

linked persistent low densities of adult Colorado pikeminnow in the Yampa River to persistent 

high densities of nonnative predators (e.g., smallmouth bass and northern pike; northern pike 

abundance shown in Figure 7). These estimates, which indicate that northern pike are 

outnumbering Colorado pikeminnow at least 3:1, point up the ongoing challenge of managing 

nonnative predators (Service 2015a). A published fish density model (McGarvey et al. 2010) 

supported the importance of competition among top predators in lotic systems and suggested that 

partitioning available energetic resources among multiple predator species would inevitably 

reduce carrying capacity for Colorado pikeminnow. Examination of historic and recent trends in 

densities of large-bodied Colorado pikeminnow, northern pike, and smallmouth bass in the 

middle Yampa River suggests that large-bodied invasive predators have functionally replaced 

Colorado pikeminnow as the river’s top predator (Martinez et al. 2014). 

The number of adult Colorado pikeminnow residing in the Yampa River has been greatly 

reduced, largely because of persistent high densities of nonnative predators, and perhaps also 

because of extended drought (Recovery Program 2015). The Recovery Program initiated a 

campaign to remove nonnative predators from the critical habitat reaches of the Yampa River in 

the early 2000s when it became apparent that smallmouth bass were decimating the native fish 

populations (Anderson 2005). Since that time removal efforts have increased both 

geographically (now encompassing ~ 170 miles of Yampa River + Catamount Reservoir) and in 

intensity (with some reaches receiving more than 10 removal passes / yr). 

35 
 

 

 

 

 

 

 

 

 

 

 

 

Figure 7. Comparison of Colorado pikeminnow population estimates (CPM) (2000 – 2008 data 

from Bestgen et al. 2010) and northern pike (Battige 2012) in the middle Yampa River. The 

2011-2013 data points for Colorado pikeminnow are preliminary. Northern pike population 

estimates were not conducted in 2013. 

As stated in Martinez et al. (2014), the dramatic decline of native fishes in the Yampa River 

provides a stark example of the cumulative detrimental impacts of an increase in the number and 

abundance of nonnative aquatic species, particularly increases in the range and abundance of 

invasive species including northern pike and smallmouth bass, and virile crayfish Orconectes 

virilis. The Yampa River has been previously described as the “crown jewel” of the upper 

Colorado River Basin due to its formerly robust native fish populations (Johnson et al. 2008) and 

its comparatively unregulated hydrograph. It contains designated critical habitat for all four of 

the endangered fish in the basin. In recent decades, the Yampa River has been progressively 

invaded by nonnative species, altering the native aquatic community and food web and 

increasing the threat of invasive impacts to native and endangered fishes (Johnson et al. 2008; 

Martinez 2014). Examples of these threats include the detection of Asian tapeworm 

Bothriocephalus acheilognathi, hybridization between native sucker species and nonnative white 

sucker Catostomus commersoni, and predation or apparent competition with and hyperpredation 

on native and endangered fishes (Martinez 2014). Endangered Colorado pikeminnow have 

steadily declined in the Yampa River, despite pikeminnow increases in four other major 

population areas in the Green River basin (Bestgen et al. 2010; Martinez et al. 2014). It has 

become imperative that preventive, eradication and control measures be diligently, vigorously, 

and more rapidly applied to restore the native aquatic community in the Yampa River (Martinez 

et al. 2014). 

36 
 

 

 

 

 

 

 

 

 

 

 

3.2.2 Razorback sucker 

Less is known about the numbers of the other three endangered fish within the Yampa and White 

Rivers. The Yampa River at the mouth of Yampa Canyon was an historical site for razorback 

sucker reproduction, and in fact, was the first such spawning site described in the Upper 

Colorado River Basin (McAda and Wydoski 1980, Bestgen 1990). More recently, only a few 

razorback larvae have been captured in the lower Yampa River in 2000, 2008, and 2011 

(Bestgen et al. 2012). Although substantial numbers of razorback sucker do not occur in the 

Yampa River, scattered individuals can occasionally be found (Bestgen et al. 2012). 

Razorback suckers are not stocked into the Yampa River or White Rivers. They are, however, 

stocked into the Green River and can swim up and into the Yampa or White River. A few 

substantial captures of adult razorback suckers occurred in the lower White River in 2011. A 

passive integrated antenna array near the Bonanza Bridge (installed September 2012) 

demonstrated that razorback sucker and Colorado pikeminnow use the Utah portion of the White 

River in higher numbers than previously thought. However, a recent expansion of smallmouth 

bass in the White River is a cause for concern for this native fish stronghold (Recovery Program 

2015). In 2011, researchers documented spawning by razorback sucker in the White River for 

the first time (Bestgen et al. 2012). 

The current and increasingly most significant threat to the razorback sucker in the action area is 

from nonnative species, which is discussed in the Status of the Species section. See also the 

discussion regarding nonnative species in the Colorado pikeminnow Status of the Species and 

Baseline sections above, as this threat is similar for all endangered fish in the upper Colorado 

River basin, particularly regarding predation from nonnative predators. 

3.2.3 Humpback chub 

The Yampa River humpback chub population exists in the lower Yampa River Canyon and into 

the Green River through Split Mountain Canyon. This population is small, with an estimate of 

about 400 wild adults in 1998-2000. Sampling during 2003–2004 caught only 13 fish, too few to 

estimate population size (Finney 2006). In 2007, the Recovery Program brought 400 young-ofyear Gila spp. caught in Yampa Canyon into captivity as a research activity to determine the best 

methods for capture, transport, and holding at two different hatchery facilities. Approximately 

15 percent of the Gila species were tentatively identified as humpback chub by physical 

characteristics. Geneticists at Southwest Native Aquatic Resources and Recovery Center 

(SNARRC), Dexter, NM, have since provided preliminary results indicating that the Yampa fish 

in captivity were hybrids between humpback chub and roundtail chub. These fish were 

considered unsuitable for broodstock and were released into the Green River in Dinosaur 

National Monument. Currently, it is not known if pure humpback chubs occur in Yampa 

Canyon. The Recovery Program (2015) states that a small population of humpback chub 

historically existed in the Yampa River in Dinosaur National Monument (Service 2002a), but is 

now believed to be reduced to a few individuals. 

The current and increasingly most significant threat to the humpback chub in the action area is 

from nonnative species, which is discussed in the Status of the Species section. See also the 

37 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

discussion regarding nonnative species in the Colorado pikeminnow Status of the Species and 

Baseline sections above, as this threat is similar for all endangered fish in the upper Colorado 

River basin, particularly regarding predation from nonnative predators. 

3.2.4 Bonytail 

As stated in the Status of the Species section, wild bonytail are so rare that it is currently not 

possible to conduct population estimates. However, the Recovery Program is implementing a 

stocking program to reestablish populations in the Upper Basin. Limited stocking of bonytail 

has begun recently in the Yampa River and White River (in Utah). 

The current and increasingly most significant threat to the bonytail in the action area is from 

nonnative species, which is discussed in the Status of the Species section. See also the 

discussion regarding nonnative species in the Colorado pikeminnow Status of the Species and 

Baseline sections above, as this threat is similar for all endangered fish in the upper Colorado 

River basin, particularly regarding predation from nonnative predators. 

3.3 Contaminants In The Action Area 

3.3.1 Mercury 

An analysis of mercury deposition and its effects on endangered fish in the San Juan River was 

recently completed for the Four Corners Power Plant (EPRI 2014). Over 1000 times more coal 

was involved in the modeling for that effort than under consultation here, but the mechanics of 

mercury emissions and deposition analyzed there are informative for this consultation. 

Numerous activities, natural sources, and legacy sources have emitted mercury in the past, and, 

given that mercury is a global pollutant, we can assume an unknown quantity of that mercury has 

been deposited in the action area over time. Since the surface area of water is low in the Yampa 

and White River Basins compared with land area, almost all mercury deposition falls on land, 

primarily as elemental or ionic mercury. The deposited mercury either evades back to the 

atmosphere or sequesters to soil. Over time, when overland flow takes place, soil is eroded from 

the catchment surface and carries adsorbed mercury (e.g., mercury ions; EPRI 2014) with it to 

the river. A very small portion (about 0.1 percent in the San Juan River, EPRI 2014) of ionic 

mercury deposited in the watershed enters surface waters. Because of the relatively large 

amount of past mercury deposited to the soils in a watershed from local, regional and global 

sources, mercury in water and fish are slow to respond to changes in mercury deposition, 

including reductions in the deposition of mercury (EPRI 2014). Thus, due to the time it takes for 

mercury to cycle through the environment, mercury emission and deposition in the action area 

that may have occurred in the past may continue to affect the listed species and critical habitats 

today and into the future, and yet are considered part of the environmental baseline. 

Water mercury concentrations in the Yampa and White Rivers, which includes all critical 

habitats in the action area, have not been measured within endangered fish critical habitat in over 

a decade. Older measurements were made at imprecise detection levels. Water mercury 

concentrations were tested in the White River above Kinney Reservoir (formed by Taylor Draw 

Dam) from 1990-1993 (USGS 2015). This reach of the White River is within the action area, as 

is all of the White River below Rio Blanco Lake, which marks the upper limit of critical habitat 

38 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

for the Colorado pikeminnow. Although total mercury was not detected in 6 of the 8 samples 

(lab reporting level unknown), the maximum concentration measured was 0.10 μg/L, which is 10 

times the chronic aquatic toxicity standard of 0.01 μg/L; the level of concern was listed as High, 

but clearly more sampling is needed. Chronic toxicity is the development of negative effects as 

the result of long term exposure to a toxicant or other stressor. It can manifest as direct lethality 

but more commonly refers to sub-lethal endpoints such as decreased growth, reduced 

reproduction, or behavioral changes such as impacted swimming performance. 

Total mercury concentrations of 0.20 and 0.1 μg/L were also measured in the 1990s in the 

Yampa River at the Maybell and Craig stations, respectively, although the median values for the 

datasets were below the detection limit (assumed to be zero) (USGS 2015). Despite occasional 

high water mercury concentrations, most values were low enough that the Yampa and White 

Rivers are not listed as impaired for mercury on the EPA 303(d) list (CDPHE 2012b) (all median 

values were below the detection limit of 0.018 μg/L at the Craig station, unknown limit at the 

Maybell station). Water mercury concentrations are not currently measured in the Yampa or 

White Rivers within endangered fish critical habitat. 

As explained more fully in the Effects of the Action section below, and provided as reference 

here, mercury in whole body fish ≤ 0.2 micrograms per gram (μg/g) wet weight (WW) is an 

approximate threshold below which mercury tissue concentrations can be considered protective 

of juvenile and adult fish (see Beckvar et al. 2005 and further discussion in Effects of the Action 

section). Using the Model B regression equation (slope = 0.9048, intercept = -0.2387) developed 

by Peterson et al. (2005) for the northern pikeminnow (Ptychocheilus oregonensis), which is 

very similar physiologically to the Colorado pikeminnow, this translates to a value of 0.31 μg/g 

WW in muscle tissue. Muscle tissue is often sampled as muscle plugs—a small, circular, 

shallow sample of muscle tissue taken from a live fish without significant injury. Osmundson 

and Lusk (2012) found a range of 0.39 to 0.58 μg/g WW mercury in Yampa River pikeminnow 

muscle tissue, with a mean of 0.49. Colorado pikeminnow that were captured in the 1960’s from 

the Yampa River and more recently tested had slightly higher mercury concentrations (all 

archival pikeminnow averaged 0.65 μg/g WW mercury in muscle tissue) (Osmundson and Lusk 

2012). Additionally, muscle tissue samples, taken from 4 adult pikeminnow (length 20-26 

inches) in the Yampa River in 2006, had levels of mercury between 0.42 and 0.68 μg/g WW, 

with a mean of 0.56 μg/g (CDPHE 2015). 

Within the White River, Osmundson and Lusk (2012) found that mercury concentrations in 

pikeminnow muscle plugs were higher there than within any other occupied critical habitat unit, 

with muscle plug concentrations for these fish ranging from 0.43 to 1.83 μg/g WW (Osmundson 

and Lusk 2012). Roundtail chub (Gila robusta) were also tested in the White River as a part of 

the same study and were found to have elevated mercury levels as well (Osmundson and Lusk 

2012). Whole body mercury concentrations in four adult pikeminnow (502-760 mm in length) 

taken from the White River immediately below Kinney Reservoir in 1986 ranged from 0.31 to 

0.96 μg/g (after conversion to wet weight from dry weight (Krueger 1988)). Using the 

conversion factor derived from Peterson et al. (2005), the 1986 Colorado pikeminnow samples 

from the White River then ranged from concentrations of 0.50 to 1.75 μg/g WW mercury in 

muscle tissue (quite elevated). Osmundson and Lusk (2102) state that the White, Green, 

39 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Colorado, and Yampa Rivers should be placed on the 303(d) list of state impaired waters due to 

these high mercury concentrations found in fish tissue. 

To summarize, Colorado pikeminnow have repeatedly shown elevated mercury concentrations in 

both the Yampa and White Rivers. Some of the mercury concentrations measured in 

pikeminnow from the White River have been especially high. After reviewing several studies on 

mercury toxicity in fish, it is reasonable to assume that some individual Colorado pikeminnow 

are being adversely affected by elevated mercury tissue residues. However, we do not know 

what level of impact mercury has had on the Colorado pikeminnow at the population level in the 

action area in the past. We do not know if it is limiting or preventing successful reproduction, 

particularly in the White River where mercury levels are higher and reproduction rates are low. 

Although likely to be lower than Colorado pikeminnow, due in large part, to trophic position, 

mercury levels have not been tested in the other three endangered fish species. 

3.3.2 Selenium 

During surface water sampling of the Yampa River between 1997 and 1998, selenium 

concentrations ranged from; <1 to 4.8 μg/L near Craig, CO < 1 to 4.9 μg/L near Maybell, CO 

and <1 to 3.6 μg/L near Deerlodge Park, CO (USGS 2001). The peak reported selenium 

concentrations for these sites occurred in March, possibly during the beginning of the snow 

runoff. Concentrations were <1 μg/L during May through October. A longer term data set from 

1991 to 2011 for the Yampa River below Craig Colorado (USGS Station 09247600) (n=91), 

showed that close to half of the sample values were reported at less than the laboratory reporting 

level (0.030 μg/L), and the maximum reported selenium concentration was 17.0 μg/L (USGS 

2015). The chronic aquatic life standard for selenium is 5 μg /L total and 4.6 ug/L dissolved 

(CDPHE 2012a). In sum, historic selenium concentrations measured in the Yampa River below 

Craig have exceeded the chronic aquatic life selenium standard approximately 10 percent of the 

time, but are generally below the standard, and this segment is not state listed under 303(d) of the 

Clean Water Act as impaired for selenium (CDPHE 2012b; USGS 2015). 

According to USGS (2015) water sampling in the White River beginning in the 1990s, water 

selenium concentrations have always remained below the chronic aquatic life standard both 

above and below Taylor Draw Dam. 

Because selenium bioaccumulates in aquatic food chains, selenium concentrations in fish tissue, 

rather than water, provide a better indication of potential adverse impacts. The available data is 

limited, but a few studies have provided selenium concentrations measured in fish tissue samples 

collected from the Yampa and White Rivers. Osmundson and Lusk (2012) reported on selenium 

in muscle plug samples taken from archival Colorado pikeminnow collected from the Yampa 

River during 1962-1966, which averaged 7.5 μg/g DW (5.9-10.1ug/g DW). According to Lemly 

(1995, p.281), these fish would be ranked into the “High” hazard category (after conversion of 

whole body to egg concentrations), which “denotes an imminent, persistent toxic threat sufficient 

to cause complete reproductive failure in most species of fish and aquatic birds.” Selenium 

concentrations in muscle plugs taken from five Colorado pikeminnow collected from the Yampa 

River during 1996 ranged from 1.7-2.8 μg/g DW (mean of 2.3 ug/g DW) (Hamilton et al. 2004) 

which places them in the “Minimal” hazard category (Lemly 1995). The Minimal hazard 

40 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

category which indicates “that no toxic threat is identified but concentrations of selenium are 

slightly elevated in one or more ecosystem components (water, sediment, invertebrates, fish, 

birds) compared to uncontaminated reference sites; continued comprehensive environmental 

monitoring is recommended.” Thus, tissue selenium concentrations in Colorado pikeminnow 

from the Yampa River have varied over time, with earlier values indicating a high hazard and 

more recent values indicating a minimal hazard. 

3.4 Climate Change In The Action Area 

We discuss climate change on a global and regional level in the Status of the Species section 

above (2.6). That discussion includes the action area. In this section we provide further insights 

into the potential effects of climate change within the action area. 

Native fish in the Yampa River could potentially move upstream in response to periods of 

warming and drying associated with climate change because there is no dam blocking up-river 

migration. In the White River, however, the Taylor Draw Dam precludes migration to 

potentially more favorable upstream areas as a behavioral adaptation to changing climatic 

conditions. The Yampa and White Rivers are at the upper end of the distribution of the 

endangered fishes within the Colorado River watershed, however. As far as water temperatures 

are concerned, these fish inhabit warmer waters downstream and are presumably not currently 

near the upper limit of their temperature tolerances within any given season unless low flows and 

dry conditions become a problem, which can greatly affect water temperature. 

If the modeled predictions of more frequent, more severe, and possibly longer-lasting droughts, 

along with generally warmer temperatures and less snowfall occur, it will likely become 

increasingly challenging to meet the established flow recommendations for the protection of 

listed and native fish in the Yampa and White Rivers (Service 2005, 2013). Reduced flow levels 

may also exacerbate contaminant issues, as less dilution of contaminants in the river would 

occur. 

Climate change could also affect nonnative fish in the action area, which we believe to be the 

greatest threat to the endangered fish in the action area. As stated in Martinez et al. (2014), the 

challenges in restoring and conserving native aquatic species will likely become more difficult 

due to the interaction of invasive species and climate change. The abundance of nonnative 

species can increase rapidly under favorable conditions such as low flow prolonged by drought. 

Reductions in water stores and stream flows due to climate change may intensify demand for 

remaining water supplies and may hasten proposed water development, including in the Yampa 

River. 

Long-term climate and water development forecasts suggest flow scenarios for the Yampa River 

that will functionally mimic drought conditions, including reduced stream discharge, smaller 

stream size, and an increase in summertime water temperatures (Roehm 2004; Johnson et al. 

2008). Several invasive species, including green sunfish Lepomis cyanellus and largemouth bass 

Micropterus salmoides, have higher thermal tolerances than many of the fish species native to 

the Colorado River Basin. The projected increase in channel catfish growth rate (McCauley and 

Beitinger 1992) could increase piscivory by larger catfish in the Colorado River Basin. 

41 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Climate change and its effects on water temperature may also alter the dynamics of parasite and 

disease transmission and host susceptibility, exposing immunologically naïve native fish to 

outbreaks of pathogens. For example, thermophilic Asian tapeworm Bothriocephalus 

acheilognathi may become more widespread and increase its infection intensity due to higher 

water temperatures associated with lower summertime flows. Incidence of infection may be 

higher in small fish and infected fish may grow more slowly, prolonging their exposure to 

increased infection and predation, and potentially reducing the survival of native cyprinids 

(Martinez et al. 2014). 

Given the uncertainties, however, involved with climate change, including the possibility for 

both positive and negative effects on endangered fish, particularly at a local level such as the 

action area, it is currently not possible to predict with any confidence how endangered fish and 

their habitats will be affected overall. We believe, however, that the primary net effect is likely 

to be in an increase in the competitive edge for nonnative fish at the expense of native fish, 

including the four endangered fish in the upper Colorado River Basin. We also believe, 

however, that in the near term, over the course of the projected coal mining at the Foidel Creek 

Mine that is under review, climate change impacts will not be great enough to be readily 

measurable or have an immediate effect on the endangered fish. 

4.0 EFFECTS OF THE ACTION 

In this section we analyze the direct and indirect effects of the action on the four endangered fish 

species and their critical habitats, together with the effects of other activities that are interrelated 

or interdependent with the proposed action, that will be added to the environmental baseline (per 

50 CFR 402.02). Indirect effects are those that are caused by a proposed action and are later in 

time, but are still reasonably certain to occur. If a proposed action includes off-site measures to 

reduce or offset net adverse effects by improving habitat conditions and survival, the Service will 

evaluate the net combined effects of that proposed action and the off-site measures as interrelated 

actions. Interrelated actions are those that are part of a larger action and depend on the larger 

action for the justification; ‘interdependent actions’ are those that have no independent utility 

apart from the action under consideration (50 CFR 402.02). Future federal actions that are not a 

direct effect of the action under consideration, and not included in the environmental baseline or 

treated as indirect effects, are not considered in this consultation. 

Analysis challenges 

There are many unique challenges to analyzing the effects of the proposed action. They are 

outlined below: 

•	 We have an estimate as to the amount of mercury released from the combustion of 

Federal Trapper Mine coal at the Craig Station, but there is currently a lack of specific 

information on the amount of selenium released during this process. 

•	 There is currently a lack of reliable information on how much of the emitted mercury and 

selenium are deposited on the landscape within the action area. 

42 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

•	 There is currently a lack of reliable information on the amount of deposited mercury and 

selenium that eventually enters occupied and critical habitat and becomes available to be 

taken up by the four endangered fish species. 

•	 The analysis is confounded by other sources of selenium. 

•	 The analysis is especially confounded by other sources of mercury, a global pollutant, 

which also contribute to the amounts available to be taken up by the four endangered fish 

species. 

•	 There is currently a lack of information regarding the specific effects of elevated mercury 

and selenium on any of the four endangered fish. Assumptions can be drawn only from 

information relative to other fish species. 

These limitations make it difficult to precisely describe the effects to individuals of the four 

endangered fish species. To satisfy Congress’s direction in 7(a)(2) regarding ensuring that an 

action not jeopardize the species, OSMRE and the Service must use the best available 

information and basic conservation biology principles to explore the overall impact to the 

populations that are likely to occur and how those effects relate to the likelihood of Jeopardy. 

The OSMRE has committed to a conservation action--an analysis of mercury concentrations in 

fish tissue in the Yampa and White Rivers--as described above. The results of this effort will 

help to fill information gaps noted above and to provide data to inform the reasonableness of 

assumptions that have to be made to move the analysis forward. And, as provided for in the 

regulations, reinitiation of this consultation is triggered if new information reveals effects to the 

species in a manner or to an extent that was not considered in this analysis. 

In the discussion below we describe the effects of the action on the four endangered fish. There 

are many uncertainties and unanswered questions, however, leading us to necessarily make some 

reasonable assumptions. Some of these unanswered questions will be addressed through the 

mercury fish tissue analysis as described above. As OSMRE states in the BA, the primary 

impact from coal combustion to threatened and endangered species and their critical habitats is 

the emission and subsequent deposition of mercury and selenium. We agree, and discuss these 

effects below. 

4.1 Emissions from the Craig Generating Station 

4.1.1 Mercury 

Mercury is a naturally occurring element. It can be found in soils and the atmosphere, as well as 

water bodies. Mercury is contained in coal and can be released upon combustion. Atmospheric 

transport and deposition is an important mechanism for the global deposition of mercury (EPRI 

2014), as it can be transported over large distances from its source regions and across continents. 

It is considered a global pollutant. Atmospheric mercury is primarily inorganic and is not 

biologically available. However, once this mercury is deposited to the earth, it can be converted 

into a biologically available form, methylmercury (MeHg), through a process known as 

43 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

methylation. Methylmercury bioaccumulates in organisms and biomagnifies up food chains, 

particularly in aquatic food chains. Organisms exposed to MeHg in their food can build up 

concentrations that are many times higher than the ambient concentrations in the environment. 

Inorganic atmospheric mercury occurs in three forms: 

• Elemental mercury vapor (Hg(0)), also referred to as gaseous elemental mercury (GEM); 

• Gaseous divalent mercury, Hg(II), also referred to as reactive gaseous mercury (RGM) or 

gaseous oxidized mercury; 

• Particulate mercury, Hg(p), also referred to as particle bound mercury (PBM); PBM can be 

directly emitted or can form when RGM adsorbs on atmospheric particulate matter. 

In the global atmosphere, Hg(0) accounts for more than 90 percent of total mercury, on average, 

while both RGM and PBM typically account for less than 5 percent (EPRI 2014). The reactive 

form of mercury (RGM) is often deposited to land or water surfaces much closer to their sources 

due to its chemical reactivity and high water solubility. PBM is transported and deposited at 

intermediate distances depending on aerosol diameter or mass. Within the atmosphere, 

numerous physical and chemical transformations of mercury can occur depending on many 

factors. 

The various forms of mercury have very different physical and chemical characteristics, resulting 

in large differences in their removal rates from the atmosphere, and consequently, in their 

atmospheric lifetimes (EPRI 2014). GEM has a lifetime on the order of several months to more 

than a year because of its low reactivity, low water solubility, and slow deposition rate. Thus, it 

is considered a global pollutant since it is transported over long distances. On the other hand, the 

lifetimes of both RGM and PBM are much smaller, ranging from a few hours to days, because 

they are removed efficiently by dry and wet deposition, particularly RGM. Thus, mercury is a 

pollutant at all scales ranging from global to local. 

Mercury is emitted by both natural and anthropogenic sources. Natural sources include 

volcanoes, geothermal sources, and exposed naturally mercury-enriched geological formations. 

These sources may also include re-emission of historically deposited mercury as a result of 

evasion from the surface back into the atmosphere, fires, meteorological conditions, as well as 

changes in land use and biomass burning. Anthropogenic sources of mercury include burning of 

fossil fuels, incinerators, mining activities, metal refining, and chemical production facilities. 

Once mercury is emitted from the smoke stacks at the Craig Station it is transported some 

distance through the atmosphere before deposition on the land scape takes place. Apportioning 

the deposition of mercury based on emissions from multiple emissions sources is a complicated 

endeavor. Currently no requirement or program exists for modeling the source apportionment of 

mercury emissions. Regional scale photochemical modeling that accounts for simulated 

chemical transport, dispersion within the atmosphere, and chemical interactions of pollutants 

within the atmosphere are required for such an effort. Independent from the project under 

consideration in this consultation, an effort to conduct such a mercury deposition modeling effort 

44 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

in the Yampa River Basin has begun recently, conducted by the Electric Power Research 

Institute (EPRI) and funded by the Colowyo Coal Company, L.P. and their parent organization, 

Tri-State Generation and Transmission Association, Inc. Results of that study will aid in 

planning for the recovery of endangered fish and other listed species potentially affected by 

mercury contamination in the Yampa and White River Basins. 

While mercury emission and subsequent deposition occurs at varying spatial scales (i.e., 

globally, nationally and regionally), this consultation evaluates the potential for mercury emitted 

from the combustion of Trapper coal at the Craig Generating Station and its possible impact to 

the Colorado River Fish and their habitat. Two coal fired power plants operate in the region; the 

Craig Generating Station is located near Craig, Colorado and the Hayden Generating Station is 

sited approximately four miles east of Hayden, Colorado (21 miles east of the Craig Generating 

Station). 

According to the BA, Trapper Mine sends all of its produced coal to the Craig Generating 

Station; their coal supplies as much as 54 percent of the annual fuel for the Craig Generating 

Station. In 2014 (the last year data are available), the Craig Generating Station emitted 19.2 kg 

of mercury. In that year, the total coal consumption rate for Craig Generation Station was about 

4.6 million tons (mtpy) of coal, which means that Trapper Mine contributed at a rate of 2.3 mtpy. 

The Craig Generating Station has three power generating units, and Trapper Mine coal is almost 

exclusively used at Units #1 and #2. Based on 2014 load data reported to the EPA Clean Air 

Markets database, Units #1 and #2 represented 63.56 percent of the total electric load generated 

at Craig Generation Station. If the load and coal consumption are assumed to be directly related, 

then the coal consumption at Units #1 and #2 would have been 2.92 mtpy in 2014 (63.56 percent 

of 4.6 mtpy). Using this figure, the 2.3 mtpy contributed by Trapper Mine would have been 

78.76 percent of the overall coal consumption at Units #1 and #2. 

Emissions monitoring data obtained from CDPHE for 2014 show that mercury emissions are 

substantially less at Unit #1 (2.0 kg) and Unit #2 (2.20 kg) compared to Unit #3 (15.28 kg). This 

is most likely due to the differences in pollution control systems at the three Craig generating 

units. Units #1 and #2 each use wet scrubbing systems for sulfur dioxide (SO2) emissions 

control, compared to a spray dryer absorber (dry scrubbing) at Unit #3. Wet scrubbing systems 

have been shown to be extremely effective at providing ancillary control benefits for mercury 

emissions. This is because the oxidized form of mercury (Hg2+) is water soluble and can be 

readily removed by the wet scrubber technology. 

Applying the 78.76 percent factor to the reported 2014 mercury emissions listed above, the 

Trapper contribution to the Craig mercury emissions would be 1.57 kg at Unit #1 and 1.73 kg at 

Unit #2. Adjusting the mercury emissions estimate to the maximum production rate of 2.6 mtpy 

under the proposed action would result in mercury emissions of 3.73 kg per year that is 

attributable to combustion of Trapper Mine coal at the Craig Generating Station. 

The proposed action assumes a constant rate of mining at Trapper Mine and a stable rate of 

combustion at the Craig Generating Station each year from July 1, 2015, through the life of the 

mine in 2024. This would result in a total of 35.06 kg of mercury emitted from the Craig 

45 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Generating Station as a result of the combustion of Trapper Mine coal over the next 9.4 years 

(3.73 kg x 9.4 = 35.06 kg). 

No current data or modeling are available to indicate how much of the mercury that is emitted by 

either the Craig Station or the Hayden Station is deposited annually within the airshed used in 

this assessment. However, a recent contaminant modeling effort conducted for the Four Corners 

Power Plant and Navajo Mine Energy Project (FCPP & NMEP) (EPRI 2014) included detailed 

modeling of the emissions and deposition of mercury produced at the Four Corners Power Plant. 

In those models, it was determined that approximately 95 percent of all mercury emitted by the 

Four Corners Power Plant rises high enough into the atmosphere to be carried by prevailing wind 

currents and out of the local area analyzed in that effort. Although environmental conditions at 

the Craig Generating Station may be somewhat different, and our analysis here involves a much 

smaller amount of coal to be combusted, that modeling effort provides a roughly comparable 

situation that will assist us with our analysis. 

Assuming a five percent local mercury deposition rate, 0.187 kg of mercury would be deposited 

in the local action area each year from the combustion of the proposed Trapper Mine coal at the 

Craig Generating Station (3.73 kg x 0.05). Over the proposed life of the project (9.4 years), this 

would equate to 1.76 kg of locally-deposited mercury (0.187 kg x 9.4). 

An alternative method of estimating the amount of mercury that would be deposited from the 

proposed project can be derived from an examination of a local mercury deposition monitoring 

site. A Mercury Deposition Network (MDN) monitoring site is located in Routt County just east 

of Steamboat Springs on Buffalo Pass. It is at the eastern edge of the airshed analyzed for this 

project (see map in BA). These monitoring stations measure the levels of mercury that are 

deposited during precipitation events (i.e. wet deposition). The Buffalo Pass site is the nearest 

MDN receptor to the action area. The Craig Generating Station is approximately 45 miles west 

of the Buffalo Pass MDN site. This site has provided data on the wet deposition of mercury to 

the MDN since 2007. Data from this station in 2013 indicated that there was an annual 

deposition of 9.757 μg/m2 of mercury at that location (NAPD 2015). 

Using the results of the emission and deposition modeling conducted at FCPP as a possible 

scenario, and assuming that the average annual deposition of 9.757 μg/m2 of mercury is equally 

distributed throughout the Yampa and White River watersheds (a combined total of 34,362 

km2); an annual deposition of 335.27 kg of mercury is calculated. The entirety of the Colorado 

River Fish Action Area is within these two watersheds and is 10,514 km2 (BA, Figure 6). 

Therefore, assuming an even distribution of mercury deposition, there would be a total of 102.59 

kg of mercury deposited annually over the entire Action Area. However, if the results of the 

FCPP & NMEP model are used, then only five percent of the mercury deposited would be 

emitted from local sources and the other 95 percent would come from global or other distant 

sources. If we assume that all local mercury deposition is from the two coal-fired power plants 

(likely an overestimate), this would indicate that the proportional amount of mercury deposited 

annually that comes from the two local generating stations is 5.13 kg (5 percent from local 

sources) across the entire Action Area (102.59 kg x 0.05). 

The proportion of local mercury attributable to the Craig Generating can be estimated by 

comparing the ratio of coal that is combusted amongst the two generating stations. According to 

46 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

the BA, the Craig Generating Station consumes coal at a rate of 4.8 mtpy, and the Hayden 

Generating Station uses coal at a rate of 1.75 mtpy (i.e., the Craig Generating Station consumes 

73.3 percent of total coal consumed at both generating stations). Using these numbers, the Craig 

Generating Station would contribute 3.75 kg of local mercury (0.733 x 5.13 kg); and the Hayden 

Generating Station would contribute 1.37 kg of local mercury (0.267 x 5.13 kg). Applying 

percentages to the sourced coal that is consumed in the three units at the Craig Generating 

Station estimates Trapper’s contribution to locally deposited mercury. Trapper sourced coal that 

is combusted in Unit #1 and Unit #2 contributes 19.16 percent of the mercury emitted from the 

Craig Generating Station, and other coal that is consumed in Unit #1, Unit #2, and Unit #3 

contributes 80.84 percent of the mercury emissions. Relating these percentages to the local 

mercury deposition from the Craig Generating Station indicates that Trapper Mine coal results in 

0.72 kg of locally deposited mercury (3.75 kg x 0.1916); and other coal results in 3.04 kg of 

locally deposited mercury. It is worth noting that, due to the prevailing winds generally being 

west to east in the action area, more of the mercury emitted by the Craig Generating Station is 

likely to be deposited east of Craig than to the west (i.e., further upstream along the Yampa and 

White Rivers than endangered fish critical habitats). 

It is also important to note that the calculations above are in reference to wet deposition of 

mercury. Some research has shown that dry deposition can be equal to or greater than wet 

deposition. Research has shown this rate to be anywhere from 0.8 to 4.8 times higher in the 

central and eastern United States (Zhang et al. 2012). The rate of dry deposition is highly 

dependent on the meteorological conditions and the chemical speciation of the mercury. 

Although most all of the sites analyzed in Zang et al. (2012) were in the eastern United States 

with more precipitation than that experienced in western Colorado, one site analyzed was in Salt 

Lake City, Utah. At that site, total mercury was 2.5 times that of the wet deposition of mercury 

(Zhang et al. 2012). Applying this factor to the Trapper Mine coal that is combusted at the Craig 

Generating Station provides a total mercury deposition of 1.8 kg (0.72 kg x 2.5) in the Action 

Area from the proposed action. 

We see that estimating the amount of mercury locally deposited from the combustion of the 

proposed Trapper coal using emissions data from the Craig Generating station (and assumptions 

regarding local deposition), results in a smaller estimate of locally deposited mercury (0.187 

kg/yr) than that obtained from the estimate using the mercury deposition data at the MDN site 

(and associated conservative assumptions regarding mercury sources) (1.8 kg/yr). In terms of 

volume, this translates to between 0.47 and 4.4 ounces of mercury per year, if it were to be 

consolidated. 

4.1.2 Selenium 

In addition to mercury emissions from the combustion of coal, another element known to be 

emitted is selenium. Selenium, a trace element, is a natural component of coal and soils in the 

region. While it may be released during combustion, it is not monitored at coal combustion 

stations to the same degree as mercury. No estimate as to the amount of selenium emitted 

annually and potentially deposited into the area was made in the BA. 

When selenium is present in flue gas after combustion, it tends to behave much like sulfur and is 

removed to some extent via the Sulfur dioxide (SO2) air scrubbers in place and also absorbs onto 

47 
 

 

 

 

 

 

 

 

 

 

 

 

 

alkaline fly ash that is subsequently removed by a fabric filter bag house (EPRI 2008). 

Nevertheless, combustion of coal at the Craig Generating Station could result in some amount of 

selenium moving beyond pollution control processes, being emitted, and subsequently deposited 

on the landscape. 

4.2 Effects to Endangered Fish 

4.2.1 Mercury 

Mercury is an environmental contaminant that can have adverse effects on riparian and aquatic 

wildlife (Scheuhammer et al. 2012; Wentz et al. 2014). Elevated levels of mercury in living 

organisms in mercury-contaminated areas may persist for as long as 100 years after the source of 

pollution has been discontinued (Eisler 1987). Eisler (1987, p. iii) states: 

Most authorities agree on six points: (1) mercury and its compounds have no known 

biological function, and the presence of the metal in the cells of living organisms is 

undesirable and potentially hazardous; (2) forms of mercury with relatively low toxicity can 

be transformed into forms of very high toxicity, such as methylmercury, through biological 

and other processes; (3) mercury can be bioconcentrated in organisms and biomagnified 

through food chains; (4) mercury is a mutagen, teratogen, and carcinogen, and causes 

embryocidal, cytochemical, and histopathological effects; (5) some species of fish and 

wildlife contain high concentrations of Hg that are not attributable to human activities; (6) 

anthropogenic use of Hg should be curtailed, as the difference between tolerable natural 

background levels of Hg and harmful effects in the environment is exceptionally small. 

Aquatic systems receive mercury by direct deposition from the atmosphere and from overland 

transport from within the watershed (EPA 1997). Mercury primarily enters aquatic systems in an 

inorganic form where it can adsorb to suspended solids and settle to the bottom (EPA 1997). It 

can also be photo reduced in the upper few centimeters of the water’s surface and then evade to 

the atmosphere. RGM at the sediment water boundary can be transformed into MeHg by 

sulfate-reducing bacteria, but this process can also go the other direction, depending on 

site-specific conditions. The most important areas for methylation are anoxic areas of the 

aquatic environment, such as wetlands or poorly mixed aquatic areas. The vast majority of 

mercury in fish tissue is in the form of MeHg (EPA 1997). Rates of methylation processes and 

bioaccumulation typically vary and depend on many factors. 

The potential effects of mercury on fish are numerous. Lusk (2010) describes the potential 

affects as: 

1. Potent neurotoxin: 

a. Affects the central nervous systems (reacts with brain enzymes, then lesions); 

b. Affects the hypothalamus and pituitary, affects gonadotropin-secreting cells; 

c. Altered behaviors: Reduced predator avoidance, reproduction timing failure; 

d. Reduced ability to feed (emaciation and growth effects). 

2. Endocrine disruptor 

a. Suppressed reproduction hormones in male and female fish; 

b. Reduce gonad size and function, reduced gamete production; 

48 
 

 

 

 

 

 

 

 

 

 

c. Altered ovarian morphology, delayed oocyte development; 

d. Reduced reproductive success; 

e. Transfer of dietary Hg of the maternal adult during oogenesis and into the developing 

embryo. 

3. Inability to grow new brain cells or significantly reduce brain mercury. 

Mercury contamination is a widespread problem across the United States. Nearly half of all 

lakes and reservoirs in the country are above the human health screening value for mercury (EPA 

2009). The vast majority (97 percent) of health advisories issued by the EPA for the 

consumption of fish from lakes and reservoirs in 2008 were due to mercury, PCBs, dioxins and 

furans, DDT, and chlordane. Of these contaminants, mercury was by far the most commonly 

detected. Of the predacious fish sampled (as opposed to bottom-dwellers), 48.8 percent of the 

sampled population of lakes across the country had mercury tissue concentrations that exceeded 

the 0.3 micrograms per gram (parts per million) human health screening value for mercury, 

which represented a total of 36,422 lakes (EPA 2009). 

4.3.3.1 Colorado pikeminnow 

Of the four endangered fish in the Yampa and White Rivers, we expect the Colorado 

pikeminnow to be at greatest risk from exposure to mercury that has been deposited within the 

Yampa and White rivers from project-related emissions from the Craig Generating Station. This 

is due to two factors. First, Colorado pikeminnow have a higher likelihood of bioaccumulating 

mercury. Predatory organisms at the top of the food web generally have higher mercury 

concentrations in their bodies because mercury tends to biomagnify up through the food chain 

and concentrate in upper trophic levels (EPA 1997). Unlike the other three endangered fish, the 

Colorado pikeminnow is a top predator and is almost entirely piscivorous once it grows to be 

80-100 mm (3 to 4 inches) long (Vanicek and Kramer 1969). The Colorado pikeminnow is also 

a long-lived fish, living 55 years or more (Osmundson et al. 1997). Thus, mercury will 

accumulate more rapidly and over a longer time period than in the other three endangered fish 

species. 

Second, Colorado pikeminnow occupy habitats closer to the Craig Generating Station than the 

other endangered fish and would, therefore, be exposed to the highest concentrations of mercury 

resulting from the project. Critical habitats designated for each endangered fish were based on 

areas of known occupancy. Only critical habitat designated for the Colorado pikeminnow is 

found within the airshed identified for analysis, centered around the Craig Generating Station. 

The other three endangered fish and their critical habitats are found lower down in and along the 

Yampa River (razorback sucker, humpback chub, bonytail), and lower down in and along the 

White River (razorback sucker). We expect the contribution of mercury from the Craig 

Generating Station in the Yampa and White Rivers to diminish with distance from that point 

source through dilution (from additional water entering from tributaries) and removal (through 

biological uptake and potential adsorption to sediments). 

Beckvar et al. (2005) suggested a threshold-effect level of ≤ 0.2 micrograms per gram (μg/g) wet 

weight (WW) mercury in whole body fish as being generally protective of juvenile and adult 

fish; concentrations below this level would not result in any detectible effects to these fish. To 

49 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

be able to compare concentrations in muscle tissue with whole body tissue, estimates have been 

calculated using the Model B regression equation and the intercept developed for Northern 

pikeminnow presented in Peterson et al. (2005), as explained earlier in the Environmental 

Baseline section. Using this equation, a concentration of 0.2 μg/g WW in whole body fish 

translates to a value of 0.31 μg/g WW in muscle tissue. 

More recently, after an examination of numerous mercury studies, Sandheinrich and Wiener 

(2011) stated that freshwater fish begin to exhibit sub-lethal, yet detectible negative effects 

through changes in biochemical processes, damage to cells and tissues, and reduced reproduction 

at methylmercury concentrations of about 0.5-1.2 μg/g WW mercury in muscle tissue (0.3-0.7 

μg/g WW mercury in whole body fish). They state that nearly all mercury in fish is in the form 

of methylmercury, as this is the form that bioaccumulates and biomagnifies up through the food 

chain. Note also that the EPA human health consumption advisory is 0.3 μg/g/day of mercury 

(WW) in fish tissue (EPA 2001). 

As stated in the Environmental Baseline section above, we have historic information on the 

mercury concentrations found in Colorado pikeminnow tissue that were collected in the Yampa 

and White Rivers, but are lacking this historic data for the other three endangered fish. The 

mercury concentrations reported by Osmundson and Lusk (2012) ranged from 0.39 to 0.58 μg/g 

with a mean level of 0.49 μg/g in muscle plug samples taken from Colorado pikeminnow in the 

Yampa River (9 fish sampled 2008-2009). Prior to that, muscle plug samples taken from 

Colorado pikeminnow in the Yampa River in 2006 had concentrations of mercury between 0.42 

and 0.68 μg/g (CDPHE 2015). Earlier still, Osmundson and Lusk (2012) reported on the 

mercury concentrations in muscle plugs taken from archival pikeminnow collected in the Yampa 

River during 1964-1966, which measured 0.41-0.88 μg/g total mercury. Most of these mercury 

concentrations are above the effects threshold suggested by Beckvar et al. (2005) (muscle tissue 

equivalent) at 0.31 μg/g, but are below or at the concentrations identified by Sandheinrich and 

Wiener (2011) where negative effects would become detectible (0.5-1.2 μg/g). 

Osmundson and Lusk (2012) found that mercury concentrations in White River Colorado 

pikeminnow were higher than concentrations in Colorado pikeminnow in other river segments of 

critical habitat. They found a mean muscle tissue concentration of 0.95 μg/g in White River 

pikeminnow with a range of 0.43 to 1.83 μg/g (Osmundson and Lusk 2012). Colorado 

pikeminnow taken from the White River over 20 years earlier was reported at 0.5 to 1.75 μg/g of 

mercury in muscle tissue WW by Krueger (1988) (after conversion from whole body dry 

weight). The measured mercury concentrations indicate that some individuals of this endangered 

fish species with higher mercury concentrations have exceeded toxicity measurement thresholds 

and have mercury concentrations at a level where sub-lethal harmful effects become measurable 

in many other fish species (Sandheinrich and Wiener 2011). 

Based on these results, we expect that some Colorado pikeminnow in the action area may already 

be experiencing chronic, sub-lethal harmful effects, such as potentially reduced reproductive 

success or reduced vigor, from elevated mercury concentrations. It should be noted, however, 

that piscivorous fish living in fresh waters in the midwestern and eastern United States, and some 

waters in the western United States contaminated by mining activities, have been reported to 

contain concentrations exceeding 1.0 μg/g WW in muscle tissue (Sandheinrich and Wiener 

50 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2011). Thus, harmful effects to predatory fish from mercury are not isolated to this action area, 

but are part of a geographically widespread problem. These studies indicate that while harmful 

effects may begin to be measurable in individual fish with concentrations of 0.5 μg/g WW in 

muscle tissue, or possibly less, some adult fish can persist with muscle tissue concentrations 

exceeding 1.0 μg/g (WW) (Sandheinrich and Wiener 2011). At these levels they would 

presumably be exhibiting sub-lethal effects, such as those described below. 

The harmful effects of methylmercury on fish populations at existing exposure levels in many 

North American freshwaters would be sub-lethal, such as cellular damage, reduced vigor, and 

reduced reproduction. Direct mortality due to methylmercury has been observed only at high 

concentrations (6-20 μg/g WW in muscle) (Sandheinrich and Wiener 2011). 

Rather than direct mortality, we expect that chronic toxicity from exposure to mercury in the 

action area may be affecting the endangered fish, as discussed below. Chronic toxicity is the 

development of negative effects as the result of long term exposure to a toxicant or other 

stressor. It can manifest as direct lethality but more commonly refers to sub-lethal endpoints 

such as decreased growth, reduced reproduction, or behavioral changes such as impacted 

swimming performance. 

Data from the Colorado Department of Public Health and Environment, Water Quality Control 

Division maintains a list of all waters in Colorado that exceed the total maximum daily loads for 

a variety of contaminants (CDPHE 2012b). Maintenance of this list is in accordance with 

Section 303(d) of the Federal Clean Water Act. The Water Quality Control Division does not 

list the Yampa or White Rivers as impaired for mercury levels. It should be noted, however, that 

impairment under this program relates to risk to humans and not necessarily to risk to aquatic 

species. 

As stated above, we know that the combustion of coal from the Trapper Mine at the Craig 

Generating Station is releasing mercury into the air and we have an estimate of this quantity. We 

do not know specifically, however, what proportion of that mercury deposits within the action 

area, the greater Yampa or White River watersheds, or is transported to distant locations beyond 

the limits of the local watersheds, although we have made a reasonable assumption of this 

amount. 

Although not fully understood or quantified, we believe the primary impact from coal 

combustion to the Colorado River fish is from the emission and subsequent deposition of 

mercury and eventual integration into fish tissue. Mercury poses a greater threat to the Colorado 

pikeminnow, as compared to the other endangered fish in the action area, and a greater threat 

than selenium, which is discussed below. Mercury has no beneficial use at any concentration for 

vertebrates and is considered toxic at much lower tissue concentrations than selenium. The 

chronic aquatic life standard for mercury concentrations in water is more than two orders of 

magnitude smaller than that for selenium. In most endangered fish tissue samples analyzed from 

the action area, mercury was close to or somewhat above the more conservative safe tissue level 

presented by Beckvar et al. (2005) and some also above the higher risk threshold presented by 

Sandheinrich and Wiener (2011). As discussed below, selenium tissue concentrations tested in 

the action area have ranged from levels indicating a minimal hazard to those indicative of a high 

hazard. 

51 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

It is possible that the mercury concentrations measured in Colorado pikeminnow might result in 

a minor reduction of vigor through reduced mental and physical reaction times, which would 

impact their ability to escape predation from northern pike, smallmouth bass, or other 

piscivorous predators. Reduced swimming ability could also lead to a reduction in feeding 

success (i.e., capturing other fish to eat). However, the nonnative competitors and predators in 

the action area, such as northern pike and smallmouth bass, are experiencing the same water 

mercury concentrations and therefore may not have a significant competitive advantage or 

increased predation success over Colorado pikeminnow in the presence of elevated mercury. 

There is also evidence, however, that different predaceous fish species bioaccumulate mercury at 

different rates even within the same river segment due, in part, to differences in fish physiology 

and diet (CDPHE 2015, MacRury et al. 2002, EPA 2004). In fact, CDPHE (2015) found average 

mercury levels in Colorado pikeminnow adults were more than twice as high as northern pike 

adults in the Yampa River, although the sample size was small and different river segments were 

sampled for each species (CDPHE 2015). 

Despite the uncertainties outlined above, we can come to basic conclusions regarding the effect 

to endangered fish from the mining of coal and its eventual combustion. Given fish tissue 

mercury concentrations have been determined to be elevated in Colorado pikeminnow from both 

the Yampa and White Rivers, but in particular in the White River, and coal mining and local 

combustion adds mercury to the system, this additional mercury adds to any negative effects 

resulting from mercury exposure. Based on the best available science, we believe some 

Colorado pikeminnow individuals are experiencing low, chronic negative health effects from 

mercury already in the action area. The mercury added by this project will add to the effects of 

this chronic condition, although the relative contribution of project-related mercury is assumed to 

be a very small percentage of the total mercury that has been and will continue to be deposited in 

the action area, as explained above. 

Additionally, as stated in the Baseline section above, mercury concentration measurements have 

been higher in Colorado pikeminnow taken from the White River than from the Yampa River 

despite the fact that there are two coal-fired power plants (the Craig and Hayden Stations) 

located along the Yampa River and none within the White River watershed. This adds evidence 

to the assumption that local coal combustion from these power plants does not appear to 

constitute the primary source of mercury contamination in these watersheds. 

Despite the chronic, low-level harmful effects of mercury that Colorado pikeminnow are likely 

experiencing, we believe the population decline seen in Colorado pikeminnow populations 

within the Yampa and White Rivers over the past decade or more is primarily a result of 

increased nonnative species in these rivers, especially northern pike and smallmouth bass. As 

explained in the baseline section above, these nonnative fish populations have increased and 

have applied increasing pressure on the Colorado pikeminnow population. Coal emissions from 

the Craig and Hayden Stations have been largely constant since they became fully operational in 

the 1970s. The more recent decline of Colorado pikeminnow numbers in the action area 

coincides more closely with the expansion of nonnative fish, rather than any increase in mercury 

in the action area. 

52 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In addition, as discussed in the Baseline section above, the decline in Colorado pikeminnow 

numbers within the Yampa River has been more dramatic than the decline seen within the White 

River. This contrasts with the fact that mercury concentration measurements have been lower in 

Colorado pikeminnow taken from the Yampa River than from the White River. 

While some Colorado pikeminnow individuals are likely to be experiencing low-level harmful 

effects from mercury in the system, we do not believe that the additional amount of mercury 

from the project will be enough to significantly or measurably reduce population numbers, 

reproduction, or constrain Colorado pikeminnow distribution. 

4.3.3.2 Razorback sucker 

The effects to the razorback sucker from project-generated mercury are similar to those 

described for the Colorado pikeminnow above, although likely to be less severe in the action 

area. The razorback sucker is not a piscivorous fish and would not bioaccumulate mercury as 

rapidly. Additionally, the razorback sucker does not occur as far upstream in the Yampa and 

White Rivers as the Colorado pikeminnow; thus, it does not occur as close to the point-sources 

for mercury resulting from the project. As with the Colorado pikeminnow, we believe nonnative 

species are the primary limiting factor for razorback sucker numbers, successful recruitment, and 

their distribution within the action area. While the evidence indicates that some razorback 

sucker individuals are likely being adversely affected by mercury in the system, we do not see 

evidence indicating that the negative effects from mercury rise to the level of reducing 

population numbers, are limiting reproduction, or are constraining razorback sucker distribution. 

4.3.3.3 Humpback chub 

The effects to the humpback chub in the action area from project-generated mercury are similar 

to those described for the Colorado pikeminnow above, although perhaps less severe. The 

humpback chub is not a top predator and may not bioaccumulate mercury as rapidly. 

Additionally, the humpback chub does not occur as far upstream in the Yampa River as the 

Colorado pikeminnow, and is not known to occupy the White River in any significant way; thus, 

it does not occur as close to the point-sources for mercury resulting from the project. As with the 

Colorado pikeminnow, we believe nonnative species are the primary limiting factor for 

humpback chub numbers, successful recruitment, and their distribution within the action area. 

While the evidence indicates that some humpback chub individuals are likely being adversely 

affected by mercury in the system, we do not see evidence indicating that the negative effects 

from mercury rise to the level of reducing population numbers, are limiting reproduction, or are 

constraining humpback chub distribution. 

4.3.3.4 Bonytail 

The effects to the bonytail in the action area from project-generated mercury are similar to those 

described for the Colorado pikeminnow above, although perhaps less severe. The bonytail is not 

a top predator and may not bioaccumulate mercury as rapidly. Additionally, the bonytail does 

not occur as far upstream in the Yampa River as the Colorado pikeminnow, and has only 

recently been stocked into the lower White River; thus, it does not occur as close to the 

53 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

point-sources for mercury resulting from the project. As with the Colorado pikeminnow, we 

believe nonnative species are the primary limiting factor for bonytail numbers, successful 

recruitment, and their distribution within the action area. While the data presented above 

supports the reasonable assumption that some bonytail individuals are likely being adversely 

affected by mercury in the system, we do not see evidence indicating that the negative effects 

from mercury rise to the level of reducing population numbers, are limiting reproduction, or are 

constraining bonytail distribution. 

4.2.2 Selenium 

Selenium is required in the diet of fish at very low concentrations (0.1 μg/g) (Sharma and Singh 

1984), but at higher concentrations it becomes toxic. The safe level of selenium concentration in 

water for protection of fish and wildlife is considered to be less than 2 ug/L, and chronically 

toxic levels are considered by some to be greater than 2.7 ug/L (Lemly 1993; Maier and Knight 

1994). In Colorado, the chronic aquatic life standard for total selenium in water is 5 μg /L (=4.6 

ug/L dissolved) (CDPHE 2012a). However, dietary selenium is the primary source for selenium 

in fish (Lemly 1993); selenium in water is less important than dietary exposure when 

determining the potential for chronic effects to a species (USEPA 1998). 

Excess selenium in fish has been shown to have a wide range of adverse effects including 

mortality, reproductive impairment, effects on growth, and developmental and teratogenic effects 

including edema and finfold, craniofacial, and skeletal deformities (Lemly 2002). Excess dietary 

selenium also causes elevated selenium concentrations to be deposited into developing eggs, 

particularly the yolk (Lemly 2002, Janz et al. 2010, Buhl and Hamilton 2000). If concentrations 

in the egg are sufficiently high, developing proteins and enzymes become dysfunctional or result 

in oxidative stress, conditions that may lead to embryo mortality, deformed embryos, or embryos 

that may be at higher risk for mortality. 

Of the four Colorado River fish species, we expect that excess selenium would 

disproportionately affect the razorback sucker somewhat more than the other three species 

(Hamilton et al. 2002; Osmundson et al. 2010). As with all sucker species, the razorback sucker 

is a bottom feeder and more likely to ingest selenium that has adsorbed to river sediments. 

Simpson and Lusk (1999) and Osmundson and Lusk (2011) reported on the concentrations of 

selenium in muscle tissues collected from Colorado pikeminnow and razorback suckers from the 

San Juan River. They found higher concentrations in razorback sucker than in Colorado 

pikeminnow; however, the average difference was only modest (3.5 mg/kg in razorback suckers 

vs. 3.0 mg/kg in Colorado pikeminnow, dry weight). 

As stated in the Baseline section, the Yampa River has not exceeded the aquatic chronic toxicity 

standard for selenium. Water selenium concentrations in the White River have always registered 

below the chronic standard. Neither river is listed as impaired in the 303(d) EPA Clean Water 

Act list. 

4.3.2.1 Colorado pikeminnow 

Despite low selenium concentrations in the Yampa and White Rivers, selenium was detected at 

high levels in Colorado pikeminnow tissue in the 1960s in the Yampa River. In the White River, 

54 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

the few Colorado pikeminnow that were tested in the 1980s showed that their selenium fish 

tissue levels indicated a minimal hazard. We do not know where current selenium fish tissue 

levels stand in Colorado pikeminnow in the Yampa or White Rivers, but given that water 

concentrations in these two rivers are generally below the chronic standard, we have no recent 

data indicating that there is immediate cause for alarm. This contrasts with the water selenium 

concentrations that have been measured within Colorado pikeminnow critical habitat along the 

Gunnison River, for example, where surface waters have often exceeded Colorado Water Quality 

Standards for selenium (CDPHE 2011). 

As stated above, we believe nonnative species are the primary limiting factor for Colorado 

pikeminnow numbers, successful recruitment, and their distribution within the action area. 

While we do believe that further sampling and testing for selenium is warranted, we do not see 

any evidence indicating that potential effects from selenium rise to the level of reducing 

population numbers, are limiting reproduction, or are constraining Colorado pikeminnow 

distribution. 

4.3.2.2 Razorback sucker 

We have no data on past or current selenium fish tissue levels in razorback sucker in the Yampa 

or White Rivers. However, water selenium concentrations in these two rivers are generally 

below the chronic standard; we have no indication that there is immediate cause for alarm. This 

contrasts with the water selenium concentrations that have been measured within razorback 

sucker critical habitat along the Gunnison River, for example, where surface waters have often 

exceeded Colorado Water Quality Standards for selenium (CDPHE 2011). 

As stated above, we believe nonnative species are the primary limiting factor for razorback 

sucker numbers, successful recruitment, and their distribution within the action area. While 

further sampling and testing for selenium is warranted, we do not see any evidence indicating 

that potential effects from selenium rise to the level of reducing population numbers, are limiting 

reproduction, or are constraining razorback sucker distribution. 

4.3.2.3 Humpback chub 

We have no data on past or current selenium fish tissue levels in humpback chub in the Yampa 

or White Rivers. However, water selenium concentrations in these two rivers are generally 

below the chronic standard. Very few humpback chub currently occupy the Yampa River and 

we have no data indicating that they occur in the White River. We have no data indicating that 

there is immediate cause for alarm, although further sampling and testing for selenium is 

warranted. 

As stated above, we believe nonnative species are the primary limiting factor for humpback chub 

numbers, successful recruitment, and their distribution within the action area. While further 

sampling and testing for selenium is warranted, we do not see any evidence indicating that 

potential effects from selenium rise to the level of reducing population numbers, are limiting 

reproduction, or are constraining humpback chub distribution. 

55 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

4.3.2.4 Bonytail 

We have no data on past or current selenium fish tissue levels in bonytail in the Yampa or White 

Rivers. However, water selenium concentrations in these two rivers are generally below the 

chronic standard. Bonytail have only recently been stocked into the lower Yampa and White 

Rivers. We have no data indicating that there is immediate cause for alarm, although further 

sampling and testing for selenium is warranted. 

As stated above, we believe nonnative species are the primary limiting factor for bonytail 

numbers, successful recruitment, and their distribution within the action area. While further 

sampling and testing for selenium is warranted, we do not see any evidence indicating that 

potential effects from selenium rise to the level of reducing population numbers, are limiting 

reproduction, or are constraining bonytail distribution. 

4.3 Effects to Critical Habitat 

In addition to impacts to individual Colorado River fish, impacts would also potentially occur to 

those species’ designated critical habitats in the action area. The PCEs of critical habitat for all 

four endangered fish are identical and contain the following (50 CFR 13378): 

1.		 Water: This includes a quantity of water of sufficient quality (i.e. temperature, dissolved 

oxygen, lack of contaminants, nutrients, turbidity, etc.) that is delivered to a specific 

location in accordance with a hydrologic regime that is required for the particular life 

stage for each species; 

2.		 Physical Habitat: This includes areas of the Colorado River system that are inhabited or 

potentially habitable by fish for use in spawning, nursery, feeding, and rearing, or 

corridors between these areas. In addition to river channels, these areas also include 

bottom lands, side channel, secondary channels, oxbows, backwaters, and other areas in 

the 100-year floodplain, which when inundated provide spawning, nursery, feeding and 

rearing habitats, or access to these habitats; 

3.		 Biological Environment: Food supply, predation, and competition are important elements 

of the biological environment and are considered components of this constituent element. 

Food supply is a function of nutrient supply, productivity, and availability to each life 

stage of the species. Predation and competition, although considered normal components 

of this environment, can be out of balance due to introduced nonnative fish species. 

4.3.1 Colorado pikeminnow 

Mercury from the combustion of Trapper coal at the Craig Generating Station that is deposited 

either directly or indirectly into the designated critical habitat for this species would have the 

potential to adversely impact its critical habitat. As stated in the Baseline section above, critical 

habitat for the Colorado pikeminnow occurs within the mercury deposition zone of analysis for 

this project. An increase in the amount of mercury in river water negatively impacts water 

quality (PCE #1). It is difficult to quantify the level of impact from the proposed actions to 

critical habitat given the lack of information on where the mercury in the analysis area originates 

from. However, if it assumed that only five percent of the mercury deposited into the analysis 

56 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

area is generated locally, the impact directly from the proposed action may be relatively small. 

Nevertheless, when added to the other regional and global sources of mercury being deposited 

into the action area and the mercury already within the system, additional mercury from the 

proposed action is likely to result in an adverse impact to critical habitat through a reduction in 

water quality. 

Although potentially smaller than mercury, impacts to critical habitat from selenium added to the 

system through coal combustion, together with selenium added to the system by other sources, 

may also result adverse impacts to critical habitat for the endangered fish. However, current 

water quality data from the Yampa and White Rivers indicate that selenium levels have not 

exceeded the chronic aquatic life standard, and are likely to have less of an impact on water 

quality in critical habitat than mercury. 

The Yampa and White Rivers are not currently listed as impaired for either mercury or selenium 

on the EPA 303(d) list (CDPHE 20102b). However, mercury concentrations have not been 

tested as recently as selenium and have exceeded the chronic aquatic life standard at given water 

quality monitoring stations along both the Yampa and White Rivers in the past. 

Considering together the contributions of mercury and selenium from the project to the Yampa 

and White Rivers in the context of existing water quality data, the weight of evidence indicates 

that PCE #1 in Colorado pikeminnow critical habitat would be adversely affected through a 

reduction in water quality, but is not and would not be compromised to a point that it no longer 

provides water of sufficient quality essential for the conservation of the species. 

As discussed in the Status of the Species and Baseline sections above, endangered fish physical 

habitat (PCE#2) and the biological environment (PCE#3) are currently experiencing the most 

severe impacts, which are unrelated to the project and unaffected by the project (e.g., dams and 

diversions impacting PCE#2, nonnative species impacting PCE#3). 

4.3.2 Razorback sucker 

Razorback sucker critical habitat would be affected in a similar way by the project that Colorado 

pikeminnow critical habitat would be, as described above, although we expect the impacts to be 

of a lesser magnitude. Razorback sucker critical habitat does not extend as far up the Yampa or 

White Rivers and is, therefore, further from the point source of the Craig Generating Station. 

Razorback sucker critical habitat is located downstream from, but not within, the mercury 

deposition airshed analyzed for this consultation. Mercury and selenium contributions from the 

project to the action area diminish with distance from this point source. This increases our 

confidence that the project would not diminish water quality to a point where critical habitat can 

no longer provide the PCEs essential for the conservation of the species. 

57 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

4.3.3 Humpback chub and bonytail 

Critical habitat for the humpback chub and bonytail along the Yampa River is identical and no 

critical habitat has been designated for either of these species along the White River. Their 

critical habitats would be affected in a similar way by the project that Colorado pikeminnow 

critical habitat would be, as described above, but we expect the impacts to be of a lesser 

magnitude. Humpback chub and bonytail critical habitat does not extend as far up the Yampa 

River as Colorado pikeminnow or razorback sucker critical habitats and is, therefore, further 

from the point source of the Craig Generating Station. Humpback chub and bonytail critical 

habitat is located downstream from, but not within, the mercury deposition airshed analyzed for 

this consultation. This increases our confidence that the project would not diminish water 

quality to a point where these critical habitats can no longer provide the PCEs essential for the 

conservation of these two species. 

4.4 Cumulative Effects 

The implementing regulations for section 7 define cumulative effects as “...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 § 402.02 

Within the action area, two coal fired power plants exist, the Craig Generating Station and the 

Hayden Station. According to a recent OSMRE biological assessment (OSMRE 2015), in 2013, 

the last year data is available, the Craig and Hayden Generating Stations emitted 19.2 and 7.5 kg 

of mercury, respectively for a total of total of 26.7 kg. The Craig Station emits more than twice 

the amount of mercury than the Hayden Generating Station, and is 21 miles closer to habitats 

occupied by endangered fish in the Yampa River; both generating stations are within the airshed 

analyzed for effects in this consultation, and therefore are in the action area. The effects from all 

non-federal coal combusted at both of these two power plants, which is expected to continue 

(i.e., reasonably certain to occur), are considered to be cumulative effects. 

As explained above, according to the EPRI (2014) modelling effort, the majority of mercury 

depositions (95 percent) within the greater area surrounding a power plant are from regional and 

global sources. Mercury deposition from non-federal actions generated outside of the action area 

are considered part of the cumulative effects. Thus, the bulk of the mercury that will be 

deposited in the action area in the future will come from regional and global non-federal actions 

(e.g., coal-fired power plants in Asia). These regional and global mercury sources have been 

depositing and will continue to deposit mercury within the action area. We assume that these 

inputs will continue at roughly the same deposition rate the action area has experienced in the 

past. We have no information about any increase or decrease of coal-fired power plants globally, 

or of the increasing use of pollution control measures that would work to reduce mercury 

emissions. 

Therefore, we assume mercury inputs into the action area will be consistent with those of the last 

many years. These inputs have contributed to the current state of the action area regarding 

mercury. We assume these inputs will continue and current mercury levels will be maintained 

within the action area through future emissions, as described in the Baseline section above. The 

58 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

effects to the endangered fish and their critical habitats from mercury within the action area are 

described in the Effects of the Action above. We are not assuming an increase or decrease in 

mercury inputs or outputs to the action area, and thus, do not expect a worsening of the condition 

of the endangered fish or their critical habitats from mercury contamination. Instead we expect a 

continuation of the status quo—chronic, sub-lethal insults to the most sensitive individuals, 

which does not rise to the level of a large and detectable decrease in numbers, reproduction, or 

distribution. 

4.5 Jeopardy discussion and Conclusion 

After reviewing the current status of the Colorado pikeminnow, razorback sucker, humpback 

chub, and bonytail, the environmental baseline for the action area, the effects of the proposed 

action, and the cumulative effects, it is the Service’s biological opinion that the project, as 

described in this biological opinion, is not likely to jeopardize the continued existence of the four 

endangered fish. We have reached this conclusion based on the following reasons: 

•	 Of the four endangered fish, mercury concentrations in fish tissue have only been 

recorded in the Colorado pikeminnow, which is the species most likely to bioaccumulate 

mercury because it is at the top of the food chain and very long-lived. Mercury 

concentrations in many Colorado pikeminnow within the action area have been 

somewhat elevated in the past and indicate that the species is likely to be experiencing 

negative, sub-lethal impacts from mercury that are not insignificant. We do not have 

evidence, however, that mercury in the action area, in general, or the mercury released by 

project activities, in particular, is causing population level effects for any of the 

endangered fish species. 

•	 To the extent a degraded baseline condition exists for the endangered fish because of 

mercury contamination, we believe the proposed action does not contribute to the 

deepening of such degradation in a significant way. The baseline condition is not 

degraded by mercury to an extent that the likelihood of recovery would be reduced 

appreciably solely due to the additional amount of mercury that will result from the 

action. 

•	 Although fish tissue selenium concentrations have not been measured in all four of the 

endangered fish (Colorado pikeminnow only), the most recent fish tissue concentrations 

indicated a minimal risk to fish health. 

•	 None of the four endangered fish species are meeting recovery targets within the Green 

River subbasin, which includes the Yampa and White Rivers in the action area. 

However, we believe this is primarily a result of nonnative species that have increased in 

the action area and large-scale habitat alteration (e.g., dams and diversions). These 

impacts are not increased as a result of the proposed action. 

59 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

4.6 Destruction and Adverse Modification Discussion and Conclusion 

After reviewing the current status of the critical habitats for the Colorado pikeminnow, razorback 

sucker, humpback chub, and bonytail, the environmental baseline for critical habitats within the 

action area, the effects of the proposed action, and the cumulative effects, it is the Service’s 

biological opinion that the project is not likely to destroy or adversely modify any of the critical 

habitats designated for the four endangered fish. We have reached this conclusion based on the 

following reasons regarding water quality: 

•	 Despite a few elevated mercury concentrations in the water, most reported values in both 

the White and Yampa Rivers, which includes all critical habitats in the action area, have 

been below the detection limit. Neither the Yampa River nor the White River is on the 

303(d) list of impaired waters for mercury. If the project is approved, current project 

activities would continue. Given this, we do not expect mercury water concentrations to 

increase from project activities if approved. 

•	 Water selenium concentrations in the Yampa and White Rivers, which includes all 

critical habitats in the action area, have not exceeded the chronic aquatic life standard in 

the past, according to the best available data. Neither the Yampa River nor the White 

River is on the 303(d) list of impaired waters for selenium. If the project is approved, 

current project activities would continue. We do not expect water selenium 

concentrations to increase from project activities if approved. 

5.0 INCIDENTAL TAKE STATEMENT 

Section 9 of the Act, as amended, and federal regulations prohibit the take of endangered and 

threatened species, without a special exemption. Take is defined as to harass, harm, pursue, 

hunt, shoot, wound, kill, trap, capture or collect, or attempt to engage in any such conduct. Harm 

is further defined by the Service as an act which actually kills or injures wildlife. Such act may 

include significant habitat modification or degradation where it actually kills or injures wildlife 

by significantly impairing essential behavioral patterns including breeding, feeding, or 

sheltering. Under the terms of section 7(b)(4) and section 7(o)(2) of the Act, taking that is 

incidental to and not intended as part of the agency action is not considered to be a prohibited 

taking under the Act provided that such taking is in compliance with the terms and conditions of 

this Incidental Take Statement. 

As the Service explained in the effects section, there were many challenges to describing specific 

effects to individuals of the four endangered fish. Anticipation and exemption of incidental take 

is at the scale of the individual of a species and must be reasonably certain to occur (CFR 50 

402.14(g)(7)). This requires that the Service build a reasonable basis to conclude that individuals 

of the four endangered fish will be subjected to adverse effects that in turn are reasonably certain 

to result in actual injury or death. In this biological opinion we are unable, based on the best 

available information, to find circumstances that support such a conclusion. Without, specific 

information on the potential range of effects to individuals, we are also unable to develop a 

surrogate for the potential take of the four endangered fish. Therefore, no take is anticipated or 

exempted by this incidental take statement. 

60 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

We were, however, able to explain that the broad range of potential adverse effects to the 

Colorado pikeminnow, razorback sucker, humpback chub, and bonytail in the action area would 

not be likely to result in jeopardy to any of these species or destruction or adverse modification 

to their critical habitats. This finding satisfies Congress’ direction in 7(a)(2) of the Act that 

“Each Federal agency ...insure that any action ...is not likely to jeopardize the continued 

existence of any endangered species or threatened species, or result in destruction or adverse 

modification of habitat...determined by the Secretary... to be critical.” 

We also explained that OSMRE committed to a study examining the potential effects in more 

specific detail and it may increase our knowledge regarding specific effects to individuals. This 

may reveal whether (and to what extent), and how many individuals (if any) will be actually 

injured or killed. 

Monitoring and Reporting 

OSMRE shall monitor the progress of the proposed action (including implementation of the 

conservation measures) and report that progress to the Service on an annual basis. The report 

shall be sent to the Western Colorado Ecological Services office by no later than March 31st. 

This information can also be used by OSMRE to identify any potential need to reinitiate 

consultation on this action (see reinitiation triggers below). 

6.0 CONSERVATION RECOMMENDATIONS 

1.		 Efforts are underway to measure mercury concentrations in the White and Yampa Rivers 

both in fish and in the water. Riparian and aquatic insects living in and along these 

rivers, which are eaten by endangered fish (e.g., humpback chub, bonytail) and 

yellow-billed cuckoos, are likely to also contain some level of mercury. Should funding 

become available, we recommend that mercury concentrations be measured in insects 

that serve as food sources for these threatened and endangered species (e.g., large 

terrestrial insects found in cottonwood galleries and common aquatic insects found within 

endangered fish critical habitat). 

7.0 REINITIATION 

This concludes formal consultation on OSMRE’s proposed action involving the approval of a 

coal mining plan at the Trapper Mine and eventual combustion of the mined coal at the Craig 

Generating Station. As provided in 50 CFR §402.16, reinitiation of formal consultation is 

required and shall be requested by the Federal agency or by the Service, where discretionary 

Federal involvement or control over the action has been retained or is authorized by law and: (a) 

If the amount or extent of taking specified in the incidental take statement is exceeded; (b) If new 

information reveals effects of the action that may affect listed species or critical habitat in a 

manner or to an extent not previously considered; (c) If the identified action is subsequently 

modified in a manner that causes an effect to the listed species or critical habitat that was not 

considered in the biological opinion; or (d) If a new species is listed or critical habitat designated 

that may be affected by the identified action. 

61 
 

 

 

 

 

 

 

 

 

 

 

As part of our approach to analysis we have had to make a series of assumptions. One of those 

assumptions is that the current levels of mercury in endangered fish tissue within the action area 

is similar to what has been measured in the past, as discussed in the Baseline and Effects of the 

Action sections above. The Trapper-funded conservation measures, as described above, are 

expected to shed new light on mercury concentrations in the Yampa and White Rivers and in fish 

tissue in the action area. If the results of these or similar studies indicate that water or fish tissue 

concentrations are much higher than expected based on past sampling, reinitiation of this 

consultation may be necessary. Other future studies may contribute information relevant to the 

effects of the action and this consultation. 

If, during implementation of the proposed action, changes in circumstances, situation, or 

information regarding the proposed action occur, OSMRE will assess the changes and any 

potential impacts to listed species, review the re-initiation triggers above, coordinate with the 

Service, and make a determination as to whether reinitiation is necessary. 

8.0 LITERATURE CITED 

Anderson, R. 2005. Riverine Fish Flow Investigations. Colorado Division of Wildlife Federal 

Aid Project F-289-R7. Job Progress Report. 

Badame, P. 2008. Population Estimates for Humpback Chub (Gila cypha) In Cataract Canyon, 

Colorado River, Utah, 2003–2005. Upper Colorado River Endangered Fish Recovery 

Program Project #22L. 24 pages. 

Badame, P. 2011. Humpback chub population estimates for Desolation/Gray Canyons, Green 

River Utah. Annual Report Project 129 of the Upper Colorado River Endangered Fish 

Recovery Program, Denver, Colorado. 

Badame, P. 2012. Population estimates for humpback chub (Gila cypha) in Desolation and Gray 

Canyons, Green River, Utah 2006-2007. Final Report of Utah Division of Wildlife 

Resources to Upper Colorado River Endangered Fish Recovery Program, Denver, 

Colorado. 

Beckvar, N., T.M. Dillon, and L.B. Reads. 2005. Approaches for linking whole-body fish tissue 

residues of mercury or DDT to biological effects thresholds. Environ. Toxicol. and 

Chemistry 24(8): 2094-2105. 

Bestgen, K. R. 1990. Status review of the razorback sucker, Xyrauchen texanus. Larval Fish 

Laboratory #44. Colorado State University, Fort Collins, Colorado. 91 pp. 

Bestgen, K. R., J. A. Hawkins, G. C. White, K. Chrisopherson, M. Hudson, M. H. Fuller, D. C. 

Kitcheyan, R. Brunson, P. Badame, G. B. Haines, J. Jackson, C.D. Walford, T. A. Sorenson 

& T. B. Williams. 2005. Population status of Colorado pikeminnow in the Green River 

Basin, Utah and Colorado. Colorado River Recovery Implementation Program Project 

Numbers 22i and 22j. 113 pages. 

62 
 

 

 

 

 

Bestgen, Kevin R., G. Bruce Haines, Ronald Brunson, Tom Chart, Melissa Trammell, Robert T. 

Muth, G. Birchell, K. Chrisopherson & J. M. Bundy. 2002. Status of Wild Razorback 

Sucker in the Green River Basin, Utah and Colorado, Determined from Basinwide 

Monitoring and Other Sampling Programs. Colorado River Recovery Implementation 

Program Project Number 22D. 79 pages. 

Bestgen, K. R., J. A. Hawkins, G. C. White, C.D. Walford, P. Badame & L. Monroe. 2010. 

Population Status of Colorado pikeminnow in the Green River Basin, Utah and Colorado, 

2006-2008. Colorado River Recovery Implementation Program Project Number 128. 112 

pages. 

Bestgen, K.R., J.A. Hawkins, G.C. White, C.D. Walford, M. Breen, T. Jones, A. Weber, and J. 

Howard. 2013. Abundance Estimates for Colorado pikeminnow in the Green River Basin, 

Utah and Colorado. Colorado River Recovery Program FY 2013 Annual Project Report. 

Recovery Program project number: 128. 

Bestgen, K. R., K. A. Zelasko, and G. C. White. 2012. Monitoring reproduction, recruitment, and 

population status of razorback suckers in the Upper Colorado River Basin. Final Report to 

the Upper Colorado River Endangered Fish Recovery Program, U. S. Fish and Wildlife 

Service, Denver. Larval Fish Laboratory Contribution 170. 

Breen, M.J., J.T. Herdmann and C.M. Michaud. 2014. Annual fall monitoring of young of year 

Colorado pikeminnow and smallbodied native fishes. Annual Report Project 138, from 

Utah Division of Wildlife Resources to Upper Colorado River Endangered Fish Recovery 

Program, Denver, Colorado. 

Behnke, R.J. 1980. The impacts of habitat alterations on the endangered and threatened fishes of 

the Upper Colorado River Basin: A discussion. In Energy Development in the Southwest: 

Problems of water, fish, and wildlife in the Upper Colorado River Basin. vol. 2, ed. W.O. 

Spofford. Jr., A.L. Parker, and A.V. Kneese, pp. 182-192. Research Paper R-18. 

Washington, D.C.: Resources for the Future. 

Buhl, K.J., and S.J. Hamilton. 2000. The chronic toxicity of dietary and waterborne selenium to 

adult Colorado pikeminnow in a water quality simulating that in the San Juan River. Final 

Report prepared for the San Juan River Recovery Implementation Program Biology. 

Burke, T. 1994. Lake Mohave native fish rearing program. U.S. Bureau of Reclamation, Boulder 

City, Nevada. 

Buth, D.G., R.W. Murphy, and L. Ulmer. 1987. Population differentiation and introgressive 

hybridization of the flannelmouth sucker and of hatchery and native stocks of the razorback 

sucker. Transactions of the American Fisheries Society 116:103-110. 

Carlson, C.A., and R.T. Muth. 1989. The Colorado River: lifeline of the American Southwest. 

Pages 220-239 in D.P. Dodge, ed. Proceedings of the International Large River 

Symposium. Canadian Special Publication of Fisheries and Aquatic Sciences 106, Ottawa. 

63 
 

Carpenter, J. and G. A. Mueller. 2008. Small nonnative fishes as predators of larval razorback 

suckers. Southwestern Naturalist 53:236-242. 

Clarkson, R. W., E. D. Creef, and D. K. McGuinn-Robbins. 1993. Movements and habitat 

utilization of reintroduced razorback suckers (Xyrauchen texanus) and Colorado squawfish 

(Ptychocheilus lucius) in the Verde River, Arizona. Special Report. Nongame and 

Endangered Wildlife Program, Arizona Game and Fish Department, Phoenix, AZ. 

Colorado Division of Public Health and Environment (CDPHE). 2012a. Regulation No. 31. The 

Basic Standards and Methodologies for Surface Water. Water Quality Control 

Commission. Amended September 11, 2012. Effective January 31, 2015. 

Colorado Division of Public Health and Environment (CDPHE). 2012b. Colorado’s section 

303(D) list of impaired waters and monitoring and evaluation list. 

Colorado Division of Public Health and Environment (CDPHE). 2015. Yampa River Analytical 

Results for Mercury. Available at: 

https://www.colorado.gov/pacific/sites/default/files/YampaRiver.pdf. Accessed August, 

2015. 

Dill, W.A. 1944. The fishery of the lower Colorado River. California Fish and Game 30:109-

211. 

Duran, B. R. J. E. Davis, and E. Teller. 2010. Nonnative species monitoring and control in the 

upper/middle San Juan River: 2010. U.S. Fish and Wildlife Service, Albuquerque, New 

Mexico. 

Duran, B. R. J. E. Davis, and E. Teller. 2013. Endangered fish monitoring and nonnative species 

monitoring and control in the upper/middle San Juan River: 2012. U.S. Fish and Wildlife 

Service, Albuquerque, New Mexico. 

Duran, B. R., J. E. Davis, W. Furr, and E. Teller 2014. Endangered fish monitoring and 

nonnative species monitoring and control in the upper/middle San Juan River: 2013. U.S. 

Fish and Wildlife Service, Albuquerque, New Mexico. 

Durst, S. L. 2014. 2013 Colorado pikeminnow and razorback sucker integrated PIT tag database 

summary, 22 May 2014. San Juan River Basin Recovery Implementation Program, 

Albuquerque, New Mexico. 

Eisler, R. 1987. Mercury hazards to fish, wildlife, and invertebrates: a synoptic review. U.S. Fish 

Wildl. Serv. Biol. Rep. 85(1.10). 90 pp. 

Electrical Power Research Institute (EPRI). 2008. Multimedia fate of selenium and boron at 

coal-fired power plants equipped with particulate and wet FGD controls. Palo Alto, CO. 

64 
 

 

 

 

 

Electrical Power Research Institute (EPRI). 2014. A Case Study Assessment of Trace Metal 

Atmospheric Emissions and Their Aquatic Impacts in the San Juan River Basin. Draft Final 

Report, March 2014. Palo Alto, CA. 208 pp. 

Elverud, D. 2011. Population estimate of humpback chub in Westwater Canyon, Colorado 

River, Utah. Annual Report Project 132 of the Upper Colorado River Endangered Fish 

Recovery Program, Denver, Colorado. 

Electrical Power Research Institute (EPRI). 2014. A Case Study Assessment of Trace Metal 

Atmospheric Emissions and Their Aquatic Impacts in the San Juan River Basin. Palo Alto, 

CA. 

Environmental Protection Agency (EPA). 1997. Mercury study report to Congress. Office of Air 

Quality Planning & Standards and Office of Research and Development. 

Environmental Protection Agency (EPA). 1998. Report of the peer consultation workshop on 

selenium aquatic toxicity and bioaccumulation. USEPA Report #EPA-822-R-98-007, 

Washington, D.C. 

Environmental Protection Agency (EPA). 2001. Mercury update: impact on fish advisories. EPA 

Fact Sheet, EPA-823-F-01-011. 

Environmental Protection Agency (EPA). 2004. Origin of 1 meal/week noncommercial fish 

consumption rate in national advisory for mercury. Technical Memorandum, Office of 

Water, March 11, 2004. 

Environmental Protection Agency (EPA). 2009. The national study of chemical residues in lake 

fish tissue. EPA-823-R-09-006. Office of Water, Washington D.C. 

Environmental Protection Agency (EPA). 2015. Climate Impacts in the Southwest. 

http://www.epa.gov/climatechange/impacts-adaptation. 

Farrington and Brandenburg. 2014. 2013 San Juan River Colorado Pikeminnow and Razorback 

Sucker larval fish monitoring. Presentation prepared for the Biology Committee of the San 

Juan River Basin Recovery Implementation Program, American Southwest Ichthyological 

Researchers, L.L.C., Albuquerque, New Mexico. 

Finney, Sam T. 2006. Adult and Juvenile Humpback Chub Monitoring for the Yampa River 

Population, 2003-2004. Upper Colorado River Basin Recovery Implementation Program: 

Project No. 133. 34 pages. 

Francis, T.A., and C.W. McAda. 2011. Population status of structure of humpback chub, Gila 

cypha, and roundtail chub, G. robusta, in Black Rocks, Colorado River, Colorado, 2007– 

2008. Final Draft Report of U.S. Fish and Wildlife Service to Upper Colorado River 

Endangered Fish Recovery Program, Denver, Colorado. 

65 
 

 

Francis, T., B. Schleicher, D. Ryden, B. Gerig, and D. Elverud. 2013. Razorback Sucker Survey 

of the San Juan Arm of Lake Powell, Utah 2011 & 2012. USFWS Presentation to the 

Upper Colorado River Basin Endangered Fishes Recovery Implementation Program, Grand 

Junction, Colorado. 

Franssen, N. R., K. B. Gido, and D. L. Propst. 2007. Flow regime affects availability of native 

and nonnative prey of an endangered predator. Biological Conservation 138:330-340. 

Furr, D. Weston & Jason E. Davis. 2009. Augmentation of Colorado pikeminnow (Ptychocheilus 

lucius) in the San Juan River: 2008 Interim Progress Final Report. 15 pages. 

Hamilton, S. J. 1999. Hypothesis of historical effects from selenium on endangered fish in the 

Colorado River basin. Human and Ecological Risk Assessment 5:1153-1180. 

Hamilton, S.J., K.M. Holley, K.J. Buhl, F.A. Bullard, L.K. Weston, and S.F. McDonald. 2002. 

Impact of selenium and other trace elements on the endangered adult razorback sucker. 

Environmental Toxicology 17:297-323. 

Hamilton, S.J., K.M. Holley, K.J. Buhl, F.A. Bullard, L. K. Weston, and S.F. McDonald. 2004. 

Evaluation of flushing of a high-selenium backwater channel in the Colorado River. 

Published online in Wiley Interscience.wiley.com, DOI 10.1002/tox.10151. 

Holden, P. B. and W. Masslich. 1997. Summary Report 1991-1997, San Juan River Recovery 

Implementation Program. Unpublished report of the San Juan River Recovery 

Implementation Program. 87 pp. 

Holm, J., V. Palace, P. Siwik, G. Sterling, R. Evans, C. Baron, J. Werner, and K. Wautier. 2005. 

Developmental effects of bioaccumulated selenium in eggs and larvae of two salmonid 

species. Environmental Toxicology and Chemistry 24: 2372-2381. 

Houston, D. D., T. H. Ogden, M. F. Whiting, and D. K. Shiozawa. 2010. Polyphyly of the 

pikeminnows (Teleostei: Cyprinidae) inferred using mitochondrial DNA sequences. 

Transactions of the American Fisheries Society, 139:303-315. 

Interstate Mercury Education and Reduction Clearinghouse (IMERC). 2004. Unpublished 

Summary Report prepared by IMERC staff. 1 pp. 

Janz, D.M., D.K. Deforest, M.L. Brooks, P.M. Chapman, G.Gilron, D. Hoff, W.A. Hopkins, 

D.O. McIntyre, C.A. Mebane, V.P. Palace, J.P. Skorupa, M. Wayland. 2010. . IN: 

Ecological Assessment of Selenium in the Aquatic Environment. Editors: Chapman, P.M., 

W.J. Adams, M.L. Brooks, C.G. Delos, S.N. Luoma, W.A. Maher, H.M. Ohlendorf, T.S. 

Presser, and D.P. Shaw. SETAC Workshop, CRC Press, New York. 339 pp. 

Johnson, B. M., P. J. Martinez, J. A. Hawkins, and K. R. Bestgen. 2008. Ranking predatory 

threats to nonnative fishes in the Yampa River, Colorado, via bioenergetics modeling. 

North American Journal of Fisheries Management 28:1941-1953. 

66 
 

 

 

 

Joseph, T.W., J.A. Sinning, R.J. Behnke, and P.B. Holden. 1977. An evaluation of the status, life 

history, and habitat requirements of endangered and threatened fishes of the Upper 

Colorado River system. U.S. Fish and Wildlife Service, Office of Biological Services, Fort 

Collins, Colorado, FWS/OBS 24, Part 2:183. 

Karp, Catherine and Harold Tyus. 1990. Humpback chub (Gila cypha) in the Yampa and Green 

Rivers, Dinosaur National Monument, with observations on roundtail chub (Gila robusta) 

and other sympatric fishes. Great Basin Naturalist 50:257-264. 

Krueger, R.P. 1988. Heavy metals analysis of seven Colorado squawfish from the Colorado and 

White Rivers. U.S. Fish & Wildlife Service. Grand Junction, CO. 

Lanigan, S.H., and C.R. Berry, Jr. 1979. Distribution and abundance of endemic fishes in the 

White River in Utah, final report. Contract #14-16-006-78-0925. U.S. Bureau of Land 

Management, Salt Lake City, Utah. 84 pp. 

Langhorst, D. R. 1989. A monitoring study of razorback sucker (Xyrauchen texanus) 

reintroduced into the lower Colorado River in 1988. Final report for California Department 

of Fish and Game Contract FG-7494, Blythe, California. 

Lemly, A. D. 1993. Guidelines for evaluating selenium data from aquatic monitoring and 

assessment studies. Environmental Monitoring and Assessment 28:83-100. 

Lemly, A.D. 1995. A protocol for aquatic hazard assessment of selenium. Ecotoxicology and 

Environmental Safety 32:28-288. 

Lemly, A. D. 2002. Selenium Assessment in Aquatic Ecosystems: A Guide for Hazard 

Evaluation and Water Quality Criteria. Editor D.E. Alexander. Springer-Verlag, New 

York, Inc., 161 pp.. 

Lentsch, L. D., Y. Converse, and P. D. Thompson. 1996. Evaluating habitat use of age-0 

Colorado squawfish in the San Juan River through experimental stocking. Utah Division of 

Natural Resources, Division of Wildlife Resources. Publication No. 96-11, Salt Lake City, 

Utah. 

Lusk, J. 2010. Mercury (Hg) and selenium (Se) in Colorado pikeminnow and in razorback sucker 

from the San Juan River. USFWS, New Mexico Ecological Services presentation to 

SJRRIP, Biology Committee Meeting. January 13. 

MacRury, N.K., B.D.S. Graeb, B.M. Johnson, and W.H. Clements. 2002. Comparison of dietary 

mercury exposure in two sympatric top predator fishes, largemouth bass and northern pike: 

a bioenergetics modeling approach. Journal of Aquatic Ecosystem Stress and Recovery 

9:137-147. 

Maier, K. J. and A. W. Knight. 1994. Ecotoxicology of selenium in freshwater systems. Reviews 

of Environmental Contamination and Toxicology 134:31-48. 

67 
 

 

 

 

Martinez, P., K. Wilson, P. Cavalli, H. Crockett, D. Speas, M. Trammell, B. Albrecht, and D. 

Ryden. 2014. Upper Colorado River basin nonnative and invasive aquatic species 

prevention and control strategy. Upper Colorado River Endangered Fish Recovery 

Program. 74 pp. + Appendices. 

Marsh, P. C. and J. E. Brooks. 1989. Predation by ictalurid catfishes as a deterrent to 

reestablishment of hatchery-reared razorback suckers. Southwestern Naturalist 34:188-195. 

Marsh, P. C. and D. R. Langhorst. 1988. Feeding and fate of wild larval razorback sucker. 

Environmental Biology of Fishes 21:59-67. 

Marsh, P. C., C. A. Pacey, and B. R. Kesner. 2003. Decline of razorback sucker in Lake Mohave, 

Colorado River, Arizona and Nevada. Transactions of the American Fisheries Society 

132:1251-1256. 

Maher W., A. Roach, M. Doblin, T. Fan, S. Foster, R. Garrett, G. Moller, L. Oram, D. 

Wallschlager. 2010. IN: Ecological Assessment of Selenium in the Aquatic Environment. 

Editors: Chapman, P.M., W.J. Adams, M.L. Brooks, C.G. Delos, S.N. Luoma, W.A. 

Maher, H.M. Ohlendorf, T.S. Presser, and D.P. Shaw. SETAC Workshop, CRC Press, 

New York. 339 pp. 

McAda, Charles W. 2007. Population Size and Structure of Humpback Chub, Gila cypha, in 

Black Rocks, Colorado River, Colorado, 2003-2004. Recovery Program Project Number 

22a3. 31 pages. 

McAda, C. W. and R. S. Wydoski. 1980. The razorback sucker, Xyrauchen texanus, in the upper 

Colorado River basin, 1974-76. U.S. Fish and Wildlife Service Technical Paper 99. 15 pp. 

McCauley, R., and T. Beitinger. 1992. Predicted effects of climate warming on the commercial 

culture of the channel catfish, Ictalurus punctatus. GeoJournal 28:61-66. 

McDonald, D. B., T. L. Parchman, M. R. Bower, W. A. Hubert, and F. J. Rahel. 2008. An 

introduced and a native vertebrate hybridize to form a genetic bridge to a second native 

species. Proceedings of the National Academy of Sciences 105:10837-10842. 

McGarvey, D. J., J. M. Johnston, and M. C. Barber. 2010. Predicting fish densities in lotic 

systems: a simple modeling approach. Journal of the North American Benthological 

Society 29:1212-1227. 

Meffe, G.K. 1985. Predation and species replacement on American southwestern fishes: a case 

study. Southwestern Naturalist 30(2):173-187. Miller, R.R. 1961. Man and the changing 

fish fauna of the American Southwest. Papers of the Michigan Academy of Science, Arts, 

and Letters 46:365-404. 

68 
 

 

 

 

 

Metcalf, J.L., S.L. Stowell, C.M. Kennedy, K.B. Rogers, D. McDonald, J. Epp, K. Keepers, A. 

Coopper, J.J. Austin, and A.P. Martin. 2012. Historical stocking data and 19th century 

DNA reveal human-induced changes to native diversity and distribution of cutthroat trout. 

Molecular Ecology 21:5194-5207. 

Modde, Timothy, Kenneth P. Burnham & Edmund J. Wick. 1996. Population Status of the 

Razorback Sucker in the Middle Green River (U.S.A.). Conservation Biology 10:110-119. 

Minckley, W.L.1982. Trophic Interrelations Among Introduced Fishes in the Lower Colorado 

River, Southwestern United States. California Fish and Game 68: 78-89 

Minckley, W. L. 1983. Status of the razorback sucker, Xyrauchen texanus (Abbott), in the lower 

Colorado River basin. Southwestern Naturalist 28:165-187. 

Minckley, W.L., and J.E. Deacon. 1968. Southwest fishes and the enigma of "endangered 

species". Science, 159:1424-1432. 

Minckley, W. L., P. C. Marsh, J. E. Brooks, J. E. Johnson, and B. L. Jensen. 1991. Management 

toward recovery of razorback sucker (Xyrauchen texanus). Pp. 303-357 in W.L. Minckley 

and J.E. Deacon, eds. Battle against extinction. University of Arizona Press, Tucson, 

Arizona. 

Morizot, D. C. 1996. September 11, 1996, Letter to Tom Czapla, U.S. Fish and Wildlife Service, 

Denver, CO, on genetic analysis of upper basin Colorado squawfish samples. 

Muth, Robert T., Larry W. Crist, Kirk E. LaGory, John W. Hayse, Kevin R. Bestgen, Thomas P. 

Ryan, Joseph K. Lyons & Richard A. Valdez. 2000. Flow and Temperature 

Recommendations for Endangered Fishes in the Green River Downstream of Flaming 

Gorge Dam: Upper Colorado River Endangered Fish Recovery Program, Project FG-53. 

National Atmospheric Deposition Program (NAPD). 2015. Annual Data for the Mercury 

Deposition Network Sites. Available at: http://nadp.sws.uiuc.edu/data/MDN/annual.aspx. 

National Research Council. 2012. Climate Change: Evidence, Impacts, and Choices; answers to 

common questions about the science of climate change. Available at: http://nassites.org/americasclimatechoices/files/2012/06/19014_cvtx_R1.pdf. 

Office of Surface Mining and Reclamation Enforcement (OSMRE). 2015a. Biological 

Assessment for the Reinitiation of Consultation for the Trapper Mining Inc. Trapper Mine, 

Mining Plan Modification. Denver, CO. 

Office of Surface Mining and Reclamation Enforcement (OSMRE). 2015b. Biological 

Assessment for the Reinitiation of Consultation for the Colowyo Coal Company, L.P. 

“Colowyo” Mine, Permit C-81-019 – South Taylor/Lower Wilson Mining Area, Permit 

Revision PR-02. Denver, CO. 

69 
 

 

 

 

Osmundson, B.C., C. Williams, and T. May. 2010. Water quality assessment of razorback sucker 

grow-out ponds, Grand Valley, Colorado. Unpublished report, Environmental 

Contaminants Program, U.S. Fish and Wildlife Service, Region 6. May 10, 2010. 68 pp. 

Osmundson, B.C. and J.D. Lusk. 2012. Field Assessment of Mercury Exposure to Colorado 

Pikeminnow within Designated Critical Habitat. Project ID: FFS#6F54 and DEC# 

200860001.1. June 15, 2012. 

Osmundson, D.B., and L.R. Kaeding. 1989. Studies of Colorado squawfish and razorback sucker 

use of the "15-mile reach" of the Upper Colorado River as part of conservation measures 

for the Green Mountain and Ruedi Reservoir water sales. Final Report. U.S. Fish and 

Wildlife Service, Grand Junction, Colorado. 

Osmundson, D.B., and L.R. Kaeding. 1991. Flow recommendations for maintenance and 

enhancement of rare fish habitat in the 15-mile reach during October-June. Final Report. 

U.S. Fish and Wildlife Service, Grand Junction, Colorado. 

Osmundson, D. B., R. J. Ryel & T. E. Mourning. 1997. Growth and survival of Colorado 

squawfish in the Upper Colorado River. Transactions of the American Fisheries Society 

126:687-698. 

Osmundson, D. B. & G. C. White. 2009. Population Status and Trends of Colorado Pikeminnow 

of the Upper Colorado River, 1991–2005. Grand Junction, Colorado: U. S. Fish and 

Wildlife Service. 111 pages. 

Osmundson, D.B., and G.C. White. 2014. Population Structure, Abundance and Recruitment of 

Colorado Pikeminnow of the Upper Colorado River, 2008–2010. Report of U.S. Fish and 

Wildlife Service to Upper Colorado River Endangered Fish Recovery Program, Lakewood, 

Colorado 

Peterson, S.A., J.V. Sickle, R.M. Hughes, J.A. Schacher, and S.F. Echols. 2005. A biopsy 

procedure for determining filet and predicting whole-fish mercury concentration. Archives 

of Environmental Contamination and Toxicology 48:99-107. 

Propst, D.L., and K.R. Bestgen. 1991. Habitat and biology of the loach minnow, Tiaroga cobitis, 

in New Mexico. Copeia 1991(1):29-30. 

Rinne, J.N. 1991. Habitat use by spikedace, Meda fulgida (Pisces:Cyprinidae) in southwestern 

streams with reference to probable habitat competition by red shiner (Pisces:Cyprinidae). 

Southwestern Naturalist 36(1):7-13. 

Robinson, Anthony, Robert W. Clarkson & Robert E. Forrest. 1998. Dispersal of Larval Fishes 

in a Regulated River Tributary. Transactions of the American Fisheries Society 127:772-

786. 

70 
 

 

 

 

Rogers, K. B. 2012b. Characterizing genetic diversity in Colorado River cutthroat trout: 

identifying Lineage GB populations. Colorado Parks and Wildlife, Fort Collins. 

Ruppert, J. B., R. T. Muth, and T. P. Nesler. 1993. Predation on fish larvae by adult red shiner, 

Yampa and Green Rivers, Colorado. Southwestern Naturalist 38:397-399. 

Ryden, D. W. 1997. Five year augmentation plan for the razorback sucker in the San Juan River. 

U.S. Fish and Wildlife Service, Colorado River Fishery Project Office, Grand Junction, 

Colorado. 41 pp. 

Ryden, D. W. 2000. Adult fish community monitoring on the San Juan River, 1991-1997. Final 

report. U.S. Fish and Wildlife Service, Grand Junction, Colorado. 269 pp. 

Ryden. D. W. 2001. Monitoring of razorback sucker stocked into the San Juan River as part of a 

five-year augmentation effort: 2000 Interim Progress Report. USFWS, Grand Junction, 

Colorado. 

Ryden, D. W. 2005. Augmentation and monitoring of the San Juan River razorback sucker 

population: 2004 interim progress report. U.S. Fish and Wildlife Service, Grand Junction, 

Colorado. 47 pp. 

Ryden, Dale W. 2006. Augmentation and monitoring of the San Juan River razorback sucker 

population: 2005 Interim progress report (Final). 104 pages. 

Ryden, D. W. and L. A. Ahlm. 1996. Observations on the distribution and movements of 

Colorado squawfish, Ptychocheilus lucius, in the San Juan River, New Mexico, Colorado, 

and Utah. Southwestern Naturalist 41:161-168. 

Sandheinrich M.B.and J.G. Wiener. 2011. Methylmercury in Freshwater Fish-Recent Advances 

in Assessing Toxicity of Environmentally Relevant Exposures. pages 170-186. IN: 

Environmental Contaminants In Biota-Interpreting Tissue Concentrations. Edited by 

W.Nelson Beyer and J.P. Meador. CRC Press 

Scheuhammer, A. M., Basu, N., Evers, D. C., Heinz, G. H., Sandheinrich, M. B., and Bank, M. 

S. 2012. Ecotoxicology of mercury in fish and wildlife-Recent advances, in Bank, M.S., 

ed., Mercury in the environment-Pattern and process: Berkeley, California, University of 

California Press, chap. 11, p. 223–238. 

Schleicher, B. J. 2014. Long term monitoring of sub-adult and adult large-bodied fishes in the 

San Juan River: 2013. USFWS Interim Progress Report for Agreement #08-AA-40-2715, 

Grand Junction, Colorado. 

Sigler, William F. & Robert R. Miller. 1963. Fishes of Utah. Salt Lake City, Utah: Utah State 

Department of Fish and Game. 

71 
 

 

 

Sigler, William F. & John W. Sigler. 1996. Fishes of Utah: A Natural History. Salt Lake City, 

Utah: University of Utah Press. 

Snyder, Darrel E. & Robert T. Muth. 2004. Catostomid fish larvae and early juveniles of the 

upper Colorado River basin - morphological descriptions, comparisons, and computerinteractive key. Colorado Division of Wildlife Technical Publication 42. 122 pages. 

Sublette, J. E., M. D. Hatch, and M. Sublette. 1990. The fishes of New Mexico. University of 

New Mexico Press, Albuquerque, New Mexico. 

Tyus, H. M. and J. Beard. 1990. Esox lucius (Esocidae) and Stizostedion vitreum (Percidae) in 

the Green River basin, Colorado and Utah. Great Basin Naturalist 50:33-39. 

Tyus, H M, and J.F. Saunders. 1996. Nonnative fishes in the upper Colorado River basin and a 

strategic plan for their control. Final Report of University of Colorado Center for 

Limnology to Upper Colorado River Endangered Fish Recovery Program. Denver. 

Tyus, H.M., B.D. Burdick, R.A. Valdez, C.M. Haynes, T.A. Lytle, and C.R. Berry. 1982. Fishes 

of the Upper Colorado River Basin: Distribution, abundance and status. Pages 12-70 in 

Miller, W. H., H. M. Tyus and C. A. Carlson, eds. Fishes of the Upper Colorado River 

System: Present and Future. Western Division, American Fisheries Society, Bethesda, 

Maryland. 

Tyus, H.M., and C.A. Karp. 1990. Spawning and movements of razorback sucker, Xyrauchen 

texanus, in the Green River Basin of Colorado and Utah. Southwestern Naturalist 35:427-

433. 

Upper Colorado River Endangered Fish Recovery Program & San Juan River Basin Recovery 

Implementation Program. 2010. 2009 - 2010 Highlights. 22 pages. 

Upper Colorado River Endangered Fish Recovery Program (Recovery Program). 2015. DRAFT 

Recovery Implementation Program Recovery Action Plan (RIPRAP). March 12, 2015 

draft. 

U.S. Fish and Wildlife Service (Service). 2002a. Colorado pikeminnow (Ptychocheilus lucius) 

Recovery Goals: amendment and supplement to the Colorado Squawfish Recovery Plan. 

Denver, Colorado: US Fish and Wildlife Service, Mountain-Prairie Region. 111 pages. 

U.S. Fish and Wildlife Service (Service). 2002b. Razorback Sucker (Xyrauchen texanus) 

Recovery Goals: amendment and supplement to the Razorback Sucker Recovery Plan. 

Denver, Colorado: US Fish and Wildlife Service, Mountain-Prairie Region. 113 pages. 

U.S. Fish and Wildlife Service (Service). 2002c. Humpback chub (Gila cypha) Recovery Goals: 

amendment and supplement to the Humpback Chub Recovery Plan. Denver, Colorado: US 

Fish and Wildlife Service, Mountain-Prairie Region. 107 pages. 

72 
 

 

 

 

U.S. Fish and Wildlife Service (Service). 2002d. Bonytail (Gila elegans) Recovery Goals: 

amendment and supplement to the Bonytail Chub Recovery Plan. Denver, Colorado: US 

Fish and Wildlife Service, Mountain-Prairie Region. 97 pages. 

U.S. Fish and Wildlife Service (Service). 2004. Application of the “Destruction or Adverse 

Modification” Standard under Section 7(a)(2) of the Endangered Species Act. Memo from 

Acting Director Marshall Jones to Regional Directors. December 9, 2004. 

U.S. Fish and Wildlife Service (Service). 2005. Final Programmatic Biological Opinion on the 

Management Plan for Endangered Fishes in the Yampa River Basin. Biological Opinion 

ES/GJ-6-C0-04- F-012. Denver, Colorado. 

U.S. Fish and Wildlife Service (Service). 2007. Final Biological Opinion for Colowyo Coal 

Company, L.P. Colowyo Mine Permit C-81-019, Revision 2. TAILS 65413-2006-F-0178. 

March 9, 2007. 

U.S. Fish and Wildlife Service (Service). 2011a. Colorado pikeminnow (Ptychocheilus lucius) 5 

Year Review: Summary and Evaluation. Denver, Colorado: US Fish and Wildlife Service, 

Mountain-Prairie Region. 25 pages. 

U.S. Fish and Wildlife Service (Service). 2011b. Humpback chub (Gila cypha) 5 Year Review: 

Summary and Evaluation. Denver, Colorado: US Fish and Wildlife Service, MountainPrairie Region. 26 pages. 

U.S. Fish and Wildlife Service (Service). 2012a. Razorback Sucker (Xyrauchen texanus) 5 Year 

Review: Summary and Evaluation. Denver, Colorado: US Fish and Wildlife Service, 

Mountain-Prairie Region.35 pages. 

U.S. Fish and Wildlife Service (Service). 2012b. Bonytail (Gila elegans) 5 Year Review: 

Summary and Evaluation. Denver, Colorado: US Fish and Wildlife Service, MountainPrairie Region. 26 pages. 

U.S. Fish and Wildlife Service. 2014a. Final Summary Report: Greenback Cutthroat Trout 

Genetics and Meristics Studies Facilitated Expert Panel Workshop. USFWS Region 6, 

Lakewood, CO, Order No. F13PB00113. Accessed Nov 6, 2014. Available: 

http://cpw.state.co.us/Documents/Research/Aquatic/CutthroatTrout/2014GreenbackCutthro 

atTroutWorkshopSummary.pdf. 

U.S. Fish and Wildlife Service (Service). 2014b. 2013-2014 assessment of sufficient progress 

under the Upper Colorado River Endangered Fish Recovery Program in the Upper 

Colorado River Basin, and of implementation of action items in the January 10, 2005, final 

programmatic biological opinion on the management plan for endangered fishes in the 

Yampa River Basin. Memo from Noreen Walsh, Regional Director, Region 6. September 

10, 2014. 

73 
 

 

 

 

 

 

U.S. Fish and Wildlife Service (Service). 2015a. Draft 2014-2015 assessment of sufficient 

progress under the Upper Colorado River Endangered Fish Recovery Program in the Upper 

Colorado River Basin, and of implementation of action items in the December 20, 1999, 

15-Mile Reach Programmatic Biological Opinion and December 4, 2009, Gunnison River 

Basin Programmatic Biological Opinion. Draft memo from Noreen Walsh, Regional 

Director, Region 6. August 4, 2014. 

U.S. Fish and Wildlife Service (Service). 2015b. Biological Opinion for the Four Corners Power 

Plant and Navajo Mine Energy Project. Consultation No. 02ENNM00-2014-F-0064. 

U.S. Fish and Wildlife Service (Service). 2013. DRAFT Flow recommendations for the 

endangered fish of the White River, Colorado and Utah. 12/30/13 mark-up. 

U.S. Geological Survey (USGS). 2015. USGS. Comparison of 2012-13 Water Years and 

Historical Water-Quality Data, Yampa River Basin, Colorado. See 

http://co.water.usgs.gov/infodata/yampa_summaries/index.html. 

Vanicek, C.D., and R.H. Kramer. 1969. Life history of the Colorado squawfish Ptychocheilus 

lucius and the Colorado chub Gila robusta in the Green River in Dinosaur National 

Monument, 1964-1966. Transactions of the American Fisheries Society 98(2):193-208. 

Wentz, D. A., Brigham, M. E., Chasar, L. C., Lutz, M. A., and Krabbenhoft, D. P. 2014. 

Mercury in the Nation’s streams-Levels, trends, and implications: U.S. Geological Survey 

Circular 1395, 90 p. 

Wydoski, R.S. and E.J. Wick. 1998. Ecological Value of Floodplain Habitats to Razorback 

Suckers in the Upper Colorado River Basin. Upper Colorado River Basin Recovery 

Program, Denver, Colorado. 

Xcel. 2015. Hayden Generating Station fact sheet. See 

http://www.xcelenergy.com/Energy_Portfolio/Electricity/Hayden_Generating_Station. 

Yeardley, R.B., Jr., J.M. Lazorchak, and S.G. Paulsen. 1998. Elemental fish tissue 

contamination in northeastern U.S. lakes: evaluation of an approach to regional 

assessment. Environ. Toxicol. and Chem. 17: 1875-1884. 

Zhang, L., P. Blanchard, D.A. Gray, E.M. Prestbo, M.R. Risch, D. Johnson, J. Narayan, R. 

Zsolway, T.M. Holsen, E.K. Miller, M.S. Castro, J.A. Graydon, V.L. St. Louis, and J. 

Dalziel. 2012. Estimation of speciated and total mercury dry deposition at monitoring 

locations in eastern and central North America. Atmos. Chem. Phys. 12:4327-4340. 

74 
Appendix D 

Appendix D 

American Indian Consultation 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

 

 

 

 

 

 

 

 


 


 


 

United States Department of the Interior 

OFFICE OF SURFACE MINING
 

RECLAMATIONANDENFORCEMENT
 

Western Region Office 

1999 Broadway, Suite 3320 

Denver, CO 80202-3050 

November 5, 2015 

Chairman Herman G. Honanie 

P.O. Box 123 

Kykotsmovi, AZ 86039 

Dear Chairman Honanie, 

The U.S. Department of the Interior (DOI), Office of Surface Mining Reclamation and Enforcement 

(OSMRE), Western Region, will prepare an environmental assessment (EA) to analyze environmental 

impacts of a Federal mining plan approval for current and future mining within Federal Coal Leases 

Nos. C-079641 and C-07519 held by Trapper Mining Inc. as part of the Trapper Mine. The EA will 

cover the time period beginning July 1, 2015, and continuing through the planned life of mine for the 

portion of the two Federal coal lease areas lying within the approved Surface Mining Control and 

Reclamation Act of 1977 (SMCRA) Permit Area (the Project). As required by the National 

Environmental Policy Act of 1969 (NEPA), the EA will disclose the potential for direct, indirect, and 

cumulative impacts to the environment from the Project. In accordance with the 2011 Department of 

Interior Policy on Consultation with Indian Tribes and 36 CFR Part 800.2(c)(2)(ii), the regulations 

implementing Section 106 of the National Historic Preservation Act of 1966 (as amended), OSMRE 

requests continued consultation with your tribe for the stages of the proposal development and 

implementation of the final federal action. 

Preparation of the EA will be completed pursuant to the Court-approved Joint Proposed Remedy, as 

approved by the United States District Court for the District of Colorado on September 14, 2015, in the 

case entitled WildEarth Guardians v. U.S. Office of Surface Mining et al., Case 1:13-cv-00518-RBJ (D. 

Colo. 2015). As part of the Court-approved remedy, OSMRE agreed to conduct a new NEPA analysis 

for Trapper’s current and future mining activities within Federal Coal Leases Nos. C-079641 and C07519. 

The Trapper Mine is located approximately 6 miles south of the town of Craig in Moffat County, 

Colorado, east of Colorado Highway 13. The proposed Project is occurring on two federal coal leases 

administered by the Bureau of Land Management (BLM) and located within the eastern portion of the 

Trapper Mine’s approved SMCRA Permit Area. Federal Coal Lease C-07519 was issued by the BLM 

in June 1958 and Federal Coal Lease C-079641 was issued by the BLM in October 1962. The leases 

1
 
 

 

 

 

 

 

 


 

within the SMCRA Permit Area cover a total of approximately 2,423 acres of Federal mineral estate. 

As of July 1, 2015, approximately 19 million tons of recoverable Federal coal remains within the 

Project area. The Trapper Mine uses a combination of dragline, truck shovel, and highwall mining 

methods to remove the overburden and mine the coal. 

The EA will update, clarify, and provide new and additional environmental information for the Project. 

As a result of the EA process, OSMRE will determine whether or not there are significant 

environmental impacts. An environmental impact statement will be prepared if the EA identifies 

significant impacts. If a finding of no significant impact is reached, and pursuant to 30 CFR 746.13, 

OSMRE will prepare and submit to the Assistant Secretary for Lands and Minerals Management 

(ASLM) a mining plan decision document recommending approval, disapproval, or conditional 

approval of the mining plan. The ASLM will approve, disapprove, or conditionally approve the mining 

plan approval document within the mining plan decision document, as required under the Mineral 

Leasing Act of 1920. 

A site that may be of interest is the Recurve Rockshelter (site number 5MF948). The site was first 

recorded in 1980 and was plotted in a side canyon of an intermittent tributary of the Williams 

Fork. The location of the 5MF948 can be found on Map M45 in the Trapper Mining Inc. (Trapper) 

Permit. In 2013, Trapper hired archaeological consulting firm Grand River Institute (GRI) to complete 

three block surveys to allow for planned expansion of the mine to the east. GRI found that 5MF948 

was incorrectly documented. The site is actually located within the permit area approximately 700 feet 

of mining projected to occur in 2016 based on map M10a of the permit. Site 5MF948 appears to 

consist of a number of petroglyphs on an outcrop of the Twentymile Sandstone. The outcrop has a 

south southeast aspect and is located on the opposite side of the mountain from where the Trapper mine 

is located. Unfortunately, a number of the petroglyphs have been shot with a firearm and have been 

damaged. The Colorado Division of Reclamation and Mining Safety (DRMS) have not found evidence 

that the damage has occurred from mining operation. However, DRMS has required that Trapper 

complete a study to evaluate if 5MF948 is far enough away from blasting at the mine, and given the 

expected sizes of the blasts, whether or not site will be affected. 

If you are interested, we would be willing to meet with you at your convenience to discuss the 

proposed mining plan modification and its impact on cultural resources. If you wish to provide 

comments please send those to: 

OSMRE WR 

C/O: Nicole Caveny 

Trapper Mine EA 

1999 Broadway, Suite 3320 

You also have the option to submit comments and/or questions to: OSM-NEPA-CO@OSMRE.gov, 

please ensure the subject line reads: ATTN: OSMRE, Trapper Mine MPDD EA. Additional 

information regarding the Project may be obtained from Nicole Caveny, telephone number (303) 293­

5078. We would appreciate receiving those comments with the next 60 days. For your convenience, 

information about the South Taylor Project can be accessed on the OSMRE Western Region website 

at: http://www.wrcc.osmre.gov/initiatives/trappermine.shtm. 

2
 
 


 

Thank you for taking the time to consider this project. If this letter has not been sent to the correct 

representative, please help us update our records. OSMRE will be in contact with your office in the 

coming weeks to inquire if you have had time to consider this project further. In the meantime, if you 

have any questions, please contact me directly at (303) 293-5035. 

Sincerely, 

Marcelo Calle, Manager 

Field Operations Branch 

Copy: 

Alfred Lomahquahu, Jr., Vice Chairman 

Vernita Selestewa, Tribal Secretary 

Attachments 

3
 
 

 

 

 

 

 

 

 

 


 


 


 

United States Department of the Interior 

OFFICE OF SURFACE MINING
 

RECLAMATIONANDENFORCEMENT
 

Western Region Office 

1999 Broadway, Suite 3320 

Denver, CO 80202-3050 

October 27, 2015 

President Russell Begaye 

P.O. Box 7440 

Window Rock, AZ 86515 

Dear President Begaye, 

The U.S. Department of the Interior (DOI), Office of Surface Mining Reclamation and Enforcement 

(OSMRE), Western Region, will prepare an environmental assessment (EA) to analyze environmental 

impacts of a Federal mining plan approval for current and future mining within Federal Coal Leases 

Nos. C-079641 and C-07519 held by Trapper Mining Inc. as part of the Trapper Mine. The EA will 

cover the time period beginning July 1, 2015, and continuing through the planned life of mine for the 

portion of the two Federal coal lease areas lying within the approved Surface Mining Control and 

Reclamation Act of 1977 (SMCRA) Permit Area (the Project). As required by the National 

Environmental Policy Act of 1969 (NEPA), the EA will disclose the potential for direct, indirect, and 

cumulative impacts to the environment from the Project. In accordance with the 2011 Department of 

Interior Policy on Consultation with Indian Tribes and 36 CFR Part 800.2(c)(2)(ii), the regulations 

implementing Section 106 of the National Historic Preservation Act of 1966 (as amended), OSMRE 

requests continued consultation with your tribe for the stages of the proposal development and 

implementation of the final federal action. 

Preparation of the EA will be completed pursuant to the Court-approved Joint Proposed Remedy, as 

approved by the United States District Court for the District of Colorado on September 14, 2015, in the 

case entitled WildEarth Guardians v. U.S. Office of Surface Mining et al., Case 1:13-cv-00518-RBJ (D. 

Colo. 2015). As part of the Court-approved remedy, OSMRE agreed to conduct a new NEPA analysis 

for Trapper’s current and future mining activities within Federal Coal Leases Nos. C-079641 and C07519. 

The Trapper Mine is located approximately 6 miles south of the town of Craig in Moffat County, 

Colorado, east of Colorado Highway 13. The proposed Project is occurring on two federal coal leases 

administered by the Bureau of Land Management (BLM) and located within the eastern portion of the 

Trapper Mine’s approved SMCRA Permit Area. Federal Coal Lease C-07519 was issued by the BLM 

in June 1958 and Federal Coal Lease C-079641 was issued by the BLM in October 1962. The leases 

1
 
 

 

 

 

 

 

 


 

within the SMCRA Permit Area cover a total of approximately 2,423 acres of Federal mineral estate. 

As of July 1, 2015, approximately 19 million tons of recoverable Federal coal remains within the 

Project area. The Trapper Mine uses a combination of dragline, truck shovel, and highwall mining 

methods to remove the overburden and mine the coal. 

The EA will update, clarify, and provide new and additional environmental information for the Project. 

As a result of the EA process, OSMRE will determine whether or not there are significant 

environmental impacts. An environmental impact statement will be prepared if the EA identifies 

significant impacts. If a finding of no significant impact is reached, and pursuant to 30 CFR 746.13, 

OSMRE will prepare and submit to the Assistant Secretary for Lands and Minerals Management 

(ASLM) a mining plan decision document recommending approval, disapproval, or conditional 

approval of the mining plan. The ASLM will approve, disapprove, or conditionally approve the mining 

plan approval document within the mining plan decision document, as required under the Mineral 

Leasing Act of 1920. 

A site that may be of interest is the Recurve Rockshelter (site number 5MF948). The site was first 

recorded in 1980 and was plotted in a side canyon of an intermittent tributary of the Williams 

Fork. The location of the 5MF948 can be found on Map M45 in the Trapper Mining Inc. (Trapper) 

Permit. In 2013, Trapper hired archaeological consulting firm Grand River Institute (GRI) to complete 

three block surveys to allow for planned expansion of the mine to the east. GRI found that 5MF948 

was incorrectly documented. The site is actually located within the permit area approximately 700 feet 

of mining projected to occur in 2016 based on map M10a of the permit. Site 5MF948 appears to 

consist of a number of petroglyphs on an outcrop of the Twentymile Sandstone. The outcrop has a 

south southeast aspect and is located on the opposite side of the mountain from where the Trapper mine 

is located. Unfortunately, a number of the petroglyphs have been shot with a firearm and have been 

damaged. The Colorado Division of Reclamation and Mining Safety (DRMS) have not found evidence 

that the damage has occurred from mining operation. However, DRMS has required that Trapper 

complete a study to evaluate if 5MF948 is far enough away from blasting at the mine, and given the 

expected sizes of the blasts, whether or not site will be affected. 

If you are interested, we would be willing to meet with you at your convenience to discuss the 

proposed mining plan modification and its impact on cultural resources. If you wish to provide 

comments please send those to: 

OSMRE WR 

C/O: Nicole Caveny 

Trapper Mine EA 

1999 Broadway, Suite 3320 

You also have the option to submit comments and/or questions to: OSM-NEPA-CO@OSMRE.gov, 

please ensure the subject line reads: ATTN: OSMRE, Trapper Mine MPDD EA. Additional 

information regarding the Project may be obtained from Nicole Caveny, telephone number (303) 293­

5078. We would appreciate receiving those comments with the next 60 days. For your convenience, 

information about the South Taylor Project can be accessed on the OSMRE Western Region website 

at: http://www.wrcc.osmre.gov/initiatives/trappermine.shtm. 

2
 
 

 


 

Thank you for taking the time to consider this project. If this letter has not been sent to the correct 

representative, please help us update our records. OSMRE will be in contact with your office in the 

coming weeks to inquire if you have had time to consider this project further. In the meantime, if you 

have any questions, please contact me directly at (303) 293-5035. 

Sincerely, 

Marcelo Calle, Manager 

Field Operations Branch 

Copy: 

Jonathan Nez, Vice President 

Dr. Alan S. Downer, THPO 

Attachments 

3
 
 

 

 

 

 

 

 

 

 


 


 


 

United States Department of the Interior 

OFFICE OF SURFACE MINING
 

RECLAMATIONANDENFORCEMENT
 

Western Region Office 

1999 Broadway, Suite 3320 

Denver, CO 80202-3050 

October 27, 2015 

Chairman Darwin St. Clair 

P.O. Box 538 

Fort Washakie, WY 82514 

Dear Chairman St. Clair, 

The U.S. Department of the Interior (DOI), Office of Surface Mining Reclamation and Enforcement 

(OSMRE), Western Region, will prepare an environmental assessment (EA) to analyze environmental 

impacts of a Federal mining plan approval for current and future mining within Federal Coal Leases 

Nos. C-079641 and C-07519 held by Trapper Mining Inc. as part of the Trapper Mine. The EA will 

cover the time period beginning July 1, 2015, and continuing through the planned life of mine for the 

portion of the two Federal coal lease areas lying within the approved Surface Mining Control and 

Reclamation Act of 1977 (SMCRA) Permit Area (the Project). As required by the National 

Environmental Policy Act of 1969 (NEPA), the EA will disclose the potential for direct, indirect, and 

cumulative impacts to the environment from the Project. In accordance with the 2011 Department of 

Interior Policy on Consultation with Indian Tribes and 36 CFR Part 800.2(c)(2)(ii), the regulations 

implementing Section 106 of the National Historic Preservation Act of 1966 (as amended), OSMRE 

requests continued consultation with your tribe for the stages of the proposal development and 

implementation of the final federal action. 

Preparation of the EA will be completed pursuant to the Court-approved Joint Proposed Remedy, as 

approved by the United States District Court for the District of Colorado on September 14, 2015, in the 

case entitled WildEarth Guardians v. U.S. Office of Surface Mining et al., Case 1:13-cv-00518-RBJ (D. 

Colo. 2015). As part of the Court-approved remedy, OSMRE agreed to conduct a new NEPA analysis 

for Trapper’s current and future mining activities within Federal Coal Leases Nos. C-079641 and C07519. 

The Trapper Mine is located approximately 6 miles south of the town of Craig in Moffat County, 

Colorado, east of Colorado Highway 13. The proposed Project is occurring on two federal coal leases 

administered by the Bureau of Land Management (BLM) and located within the eastern portion of the 

Trapper Mine’s approved SMCRA Permit Area. Federal Coal Lease C-07519 was issued by the BLM 

1
 
 

 

 

 

 


 

in June 1958 and Federal Coal Lease C-079641 was issued by the BLM in October 1962. The leases 

within the SMCRA Permit Area cover a total of approximately 2,423 acres of Federal mineral estate. 

As of July 1, 2015, approximately 19 million tons of recoverable Federal coal remains within the 

Project area. The Trapper Mine uses a combination of dragline, truck shovel, and highwall mining 

methods to remove the overburden and mine the coal. 

The EA will update, clarify, and provide new and additional environmental information for the Project. 

As a result of the EA process, OSMRE will determine whether or not there are significant 

environmental impacts. An environmental impact statement will be prepared if the EA identifies 

significant impacts. If a finding of no significant impact is reached, and pursuant to 30 CFR 746.13, 

OSMRE will prepare and submit to the Assistant Secretary for Lands and Minerals Management 

(ASLM) a mining plan decision document recommending approval, disapproval, or conditional 

approval of the mining plan. The ASLM will approve, disapprove, or conditionally approve the mining 

plan approval document within the mining plan decision document, as required under the Mineral 

Leasing Act of 1920. 

A site that may be of interest is the Recurve Rockshelter (site number 5MF948). The site was first 

recorded in 1980 and was plotted in a side canyon of an intermittent tributary of the Williams 

Fork. The location of the 5MF948 can be found on Map M45 in the Trapper Mining Inc. (Trapper) 

Permit. In 2013, Trapper hired archaeological consulting firm Grand River Institute (GRI) to complete 

three block surveys to allow for planned expansion of the mine to the east. GRI found that 5MF948 

was incorrectly documented. The site is actually located within the permit area approximately 700 feet 

of mining projected to occur in 2016 based on map M10a of the permit. Site 5MF948 appears to 

consist of a number of petroglyphs on an outcrop of the Twentymile Sandstone. The outcrop has a 

south southeast aspect and is located on the opposite side of the mountain from where the Trapper mine 

is located. Unfortunately, a number of the petroglyphs have been shot with a firearm and have been 

damaged. The Colorado Division of Reclamation and Mining Safety (DRMS) have not found evidence 

that the damage has occurred from mining operation. However, DRMS has required that Trapper 

complete a study to evaluate if 5MF948 is far enough away from blasting at the mine, and given the 

expected sizes of the blasts, whether or not site will be affected. 

If you are interested, we would be willing to meet with you at your convenience to discuss the 

proposed mining plan modification and its impact on cultural resources. If you wish to provide 

comments please send those to: 

OSMRE WR 

C/O: Nicole Caveny 

Trapper Mine EA 

1999 Broadway, Suite 3320 

You also have the option to submit comments and/or questions to: OSM-NEPA-CO@OSMRE.gov, 

please ensure the subject line reads: ATTN: OSMRE, Trapper Mine MPDD EA. Additional 

information regarding the Project may be obtained from Nicole Caveny, telephone number (303) 293­

5078. We would appreciate receiving those comments with the next 60 days. For your convenience, 

information about the South Taylor Project can be accessed on the OSMRE Western Region website 

2
 
 


 

at: http://www.wrcc.osmre.gov/initiatives/trappermine.shtm. 

Thank you for taking the time to consider this project. If this letter has not been sent to the correct 

representative, please help us update our records. OSMRE will be in contact with your office in the 

coming weeks to inquire if you have had time to consider this project further. In the meantime, if you 

have any questions, please contact me directly at (303) 293-5035. 

Sincerely, 

Marcelo Calle, Manager 

Field Operations Branch 

Copy: 

Clint Wagon, Co-Chairman 

Willie Ferris, Historic Preservation 

Attachments 

3
 
 

 

 

 

 

 

 

 

 

 

 


 


 


 

United States Department of the Interior 

OFFICE OF SURFACE MINING
 

RECLAMATIONANDENFORCEMENT
 

Western Region Office 

1999 Broadway, Suite 3320 

Denver, CO 80202-3050 

October 27, 2015 

Chairman Clement Frost 

P.O. Box 737 

356 Ouray Drive 

Ignacio, CO 81137 

Dear Chairman Frost, 

The U.S. Department of the Interior (DOI), Office of Surface Mining Reclamation and Enforcement 

(OSMRE), Western Region, will prepare an environmental assessment (EA) to analyze environmental 

impacts of a Federal mining plan approval for current and future mining within Federal Coal Leases 

Nos. C-079641 and C-07519 held by Trapper Mining Inc. as part of the Trapper Mine. The EA will 

cover the time period beginning July 1, 2015, and continuing through the planned life of mine for the 

portion of the two Federal coal lease areas lying within the approved Surface Mining Control and 

Reclamation Act of 1977 (SMCRA) Permit Area (the Project). As required by the National 

Environmental Policy Act of 1969 (NEPA), the EA will disclose the potential for direct, indirect, and 

cumulative impacts to the environment from the Project. In accordance with the 2011 Department of 

Interior Policy on Consultation with Indian Tribes and 36 CFR Part 800.2(c)(2)(ii), the regulations 

implementing Section 106 of the National Historic Preservation Act of 1966 (as amended), OSMRE 

requests continued consultation with your tribe for the stages of the proposal development and 

implementation of the final federal action. 

Preparation of the EA will be completed pursuant to the Court-approved Joint Proposed Remedy, as 

approved by the United States District Court for the District of Colorado on September 14, 2015, in the 

case entitled WildEarth Guardians v. U.S. Office of Surface Mining et al., Case 1:13-cv-00518-RBJ (D. 

Colo. 2015). As part of the Court-approved remedy, OSMRE agreed to conduct a new NEPA analysis 

for Trapper’s current and future mining activities within Federal Coal Leases Nos. C-079641 and C07519. 

The Trapper Mine is located approximately 6 miles south of the town of Craig in Moffat County, 

Colorado, east of Colorado Highway 13. The proposed Project is occurring on two federal coal leases 

administered by the Bureau of Land Management (BLM) and located within the eastern portion of the 

Trapper Mine’s approved SMCRA Permit Area. Federal Coal Lease C-07519 was issued by the BLM 

1
 
 

 

 

 

 

 


 

in June 1958 and Federal Coal Lease C-079641 was issued by the BLM in October 1962. The leases 

within the SMCRA Permit Area cover a total of approximately 2,423 acres of Federal mineral estate. 

As of July 1, 2015, approximately 19 million tons of recoverable Federal coal remains within the 

Project area. The Trapper Mine uses a combination of dragline, truck shovel, and highwall mining 

methods to remove the overburden and mine the coal. 

The EA will update, clarify, and provide new and additional environmental information for the Project. 

As a result of the EA process, OSMRE will determine whether or not there are significant 

environmental impacts. An environmental impact statement will be prepared if the EA identifies 

significant impacts. If a finding of no significant impact is reached, and pursuant to 30 CFR 746.13, 

OSMRE will prepare and submit to the Assistant Secretary for Lands and Minerals Management 

(ASLM) a mining plan decision document recommending approval, disapproval, or conditional 

approval of the mining plan. The ASLM will approve, disapprove, or conditionally approve the mining 

plan approval document within the mining plan decision document, as required under the Mineral 

Leasing Act of 1920. 

A site that may be of interest is the Recurve Rockshelter (site number 5MF948). The site was first 

recorded in 1980 and was plotted in a side canyon of an intermittent tributary of the Williams 

Fork. The location of the 5MF948 can be found on Map M45 in the Trapper Mining Inc. (Trapper) 

Permit. In 2013, Trapper hired archaeological consulting firm Grand River Institute (GRI) to complete 

three block surveys to allow for planned expansion of the mine to the east. GRI found that 5MF948 

was incorrectly documented. The site is actually located within the permit area approximately 700 feet 

of mining projected to occur in 2016 based on map M10a of the permit. Site 5MF948 appears to 

consist of a number of petroglyphs on an outcrop of the Twentymile Sandstone. The outcrop has a 

south southeast aspect and is located on the opposite side of the mountain from where the Trapper mine 

is located. Unfortunately, a number of the petroglyphs have been shot with a firearm and have been 

damaged. The Colorado Division of Reclamation and Mining Safety (DRMS) have not found evidence 

that the damage has occurred from mining operation. However, DRMS has required that Trapper 

complete a study to evaluate if 5MF948 is far enough away from blasting at the mine, and given the 

expected sizes of the blasts, whether or not site will be affected. 

If you are interested, we would be willing to meet with you at your convenience to discuss the 

proposed mining plan modification and its impact on cultural resources. If you wish to provide 

comments please send those to: 

OSMRE WR 

C/O: Nicole Caveny 

Trapper Mine EA 

1999 Broadway, Suite 3320 

You also have the option to submit comments and/or questions to: OSM-NEPA-CO@OSMRE.gov, 

please ensure the subject line reads: ATTN: OSMRE, Trapper Mine MPDD EA. Additional 

information regarding the Project may be obtained from Nicole Caveny, telephone number (303) 293­

5078. We would appreciate receiving those comments with the next 60 days. For your convenience, 

information about the South Taylor Project can be accessed on the OSMRE Western Region website 

2
 
 

 


 

at: http://www.wrcc.osmre.gov/initiatives/trappermine.shtm. 

Thank you for taking the time to consider this project. If this letter has not been sent to the correct 

representative, please help us update our records. OSMRE will be in contact with your office in the 

coming weeks to inquire if you have had time to consider this project further. In the meantime, if you 

have any questions, please contact me directly at (303) 293-5035. 

Sincerely, 

Marcelo Calle, Manager 

Field Operations Branch 

Copy: 

Elise Redd, Culture Department Director 

Alden Naranjo, NAGPRA Coordinator 

Attachments 

3
 
 

 

 

 

 

 

 

 

 


 


 


 

United States Department of the Interior 

OFFICE OF SURFACE MINING
 

RECLAMATIONANDENFORCEMENT
 

Western Region Office 

1999 Broadway, Suite 3320 

Denver, CO 80202-3050 

October 27, 2015 

Chairperson Gordon Howell 

P.O. Box 190 

Ft. Duchesne, UT 84026 

Dear Chairperson Howell, 

The U.S. Department of the Interior (DOI), Office of Surface Mining Reclamation and Enforcement 

(OSMRE), Western Region, will prepare an environmental assessment (EA) to analyze environmental 

impacts of a Federal mining plan approval for current and future mining within Federal Coal Leases 

Nos. C-079641 and C-07519 held by Trapper Mining Inc. as part of the Trapper Mine. The EA will 

cover the time period beginning July 1, 2015, and continuing through the planned life of mine for the 

portion of the two Federal coal lease areas lying within the approved Surface Mining Control and 

Reclamation Act of 1977 (SMCRA) Permit Area (the Project). As required by the National 

Environmental Policy Act of 1969 (NEPA), the EA will disclose the potential for direct, indirect, and 

cumulative impacts to the environment from the Project. In accordance with the 2011 Department of 

Interior Policy on Consultation with Indian Tribes and 36 CFR Part 800.2(c)(2)(ii), the regulations 

implementing Section 106 of the National Historic Preservation Act of 1966 (as amended), OSMRE 

requests continued consultation with your tribe for the stages of the proposal development and 

implementation of the final federal action. 

Preparation of the EA will be completed pursuant to the Court-approved Joint Proposed Remedy, as 

approved by the United States District Court for the District of Colorado on September 14, 2015, in the 

case entitled WildEarth Guardians v. U.S. Office of Surface Mining et al., Case 1:13-cv-00518-RBJ (D. 

Colo. 2015). As part of the Court-approved remedy, OSMRE agreed to conduct a new NEPA analysis 

for Trapper’s current and future mining activities within Federal Coal Leases Nos. C-079641 and C07519. 

The Trapper Mine is located approximately 6 miles south of the town of Craig in Moffat County, 

Colorado, east of Colorado Highway 13. The proposed Project is occurring on two federal coal leases 

administered by the Bureau of Land Management (BLM) and located within the eastern portion of the 

Trapper Mine’s approved SMCRA Permit Area. Federal Coal Lease C-07519 was issued by the BLM 

in June 1958 and Federal Coal Lease C-079641 was issued by the BLM in October 1962. The leases 

1
 
 

 

 

 

 


 

within the SMCRA Permit Area cover a total of approximately 2,423 acres of Federal mineral estate. 

As of July 1, 2015, approximately 19 million tons of recoverable Federal coal remains within the 

Project area. The Trapper Mine uses a combination of dragline, truck shovel, and highwall mining 

methods to remove the overburden and mine the coal. 

The EA will update, clarify, and provide new and additional environmental information for the Project. 

As a result of the EA process, OSMRE will determine whether or not there are significant 

environmental impacts. An environmental impact statement will be prepared if the EA identifies 

significant impacts. If a finding of no significant impact is reached, and pursuant to 30 CFR 746.13, 

OSMRE will prepare and submit to the Assistant Secretary for Lands and Minerals Management 

(ASLM) a mining plan decision document recommending approval, disapproval, or conditional 

approval of the mining plan. The ASLM will approve, disapprove, or conditionally approve the mining 

plan approval document within the mining plan decision document, as required under the Mineral 

Leasing Act of 1920. 

A site that may be of interest is the Recurve Rockshelter (site number 5MF948). The site was first 

recorded in 1980 and was plotted in a side canyon of an intermittent tributary of the Williams 

Fork. The location of the 5MF948 can be found on Map M45 in the Trapper Mining Inc. (Trapper) 

Permit. In 2013, Trapper hired archaeological consulting firm Grand River Institute (GRI) to complete 

three block surveys to allow for planned expansion of the mine to the east. GRI found that 5MF948 

was incorrectly documented. The site is actually located within the permit area approximately 700 feet 

of mining projected to occur in 2016 based on map M10a of the permit. Site 5MF948 appears to 

consist of a number of petroglyphs on an outcrop of the Twentymile Sandstone. The outcrop has a 

south southeast aspect and is located on the opposite side of the mountain from where the Trapper mine 

is located. Unfortunately, a number of the petroglyphs have been shot with a firearm and have been 

damaged. The Colorado Division of Reclamation and Mining Safety (DRMS) have not found evidence 

that the damage has occurred from mining operation. However, DRMS has required that Trapper 

complete a study to evaluate if 5MF948 is far enough away from blasting at the mine, and given the 

expected sizes of the blasts, whether or not site will be affected. 

If you are interested, we would be willing to meet with you at your convenience to discuss the 

proposed mining plan modification and its impact on cultural resources. If you wish to provide 

comments please send those to: 

OSMRE WR 

C/O: Nicole Caveny 

Trapper Mine EA 

1999 Broadway, Suite 3320 

You also have the option to submit comments and/or questions to: OSM-NEPA-CO@OSMRE.gov, 

please ensure the subject line reads: ATTN: OSMRE, Trapper Mine MPDD EA. Additional 

information regarding the Project may be obtained from Nicole Caveny, telephone number (303) 293­

5078. We would appreciate receiving those comments with the next 60 days. For your convenience, 

information about the South Taylor Project can be accessed on the OSMRE Western Region website 

at: http://www.wrcc.osmre.gov/initiatives/trappermine.shtm. 

2
 
 

 


 

Thank you for taking the time to consider this project. If this letter has not been sent to the correct 

representative, please help us update our records. OSMRE will be in contact with your office in the 

coming weeks to inquire if you have had time to consider this project further. In the meantime, if you 

have any questions, please contact me directly at (303) 293-5035. 

Sincerely, 

Marcelo Calle, Manager 

Field Operations Branch 

Copy: 

Ronald Wopsock, Vice Chairperson 

Betsy Chapoose, NAGPRA Representative 

Attachments 

3
 
 

 

 

 

 

 

 

 


 


 


 

United States Department of the Interior 

OFFICE OF SURFACE MINING
 

RECLAMATIONANDENFORCEMENT
 

Western Region Office 

1999 Broadway, Suite 3320 

Denver, CO 80202-3050 

October 27, 2015 

Chairman Manuel Heart 

124 W. Mike Wash Road Tribal Complex 

P.O. Drawer JJ 

Towaoc, CO 81334 

Dear Chairman Heart, 

The U.S. Department of the Interior (DOI), Office of Surface Mining Reclamation and Enforcement 

(OSMRE), Western Region, will prepare an environmental assessment (EA) to analyze environmental 

impacts of a Federal mining plan approval for current and future mining within Federal Coal Leases 

Nos. C-079641 and C-07519 held by Trapper Mining Inc. as part of the Trapper Mine. The EA will 

cover the time period beginning July 1, 2015, and continuing through the planned life of mine for the 

portion of the two Federal coal lease areas lying within the approved Surface Mining Control and 

Reclamation Act of 1977 (SMCRA) Permit Area (the Project). As required by the National 

Environmental Policy Act of 1969 (NEPA), the EA will disclose the potential for direct, indirect, and 

cumulative impacts to the environment from the Project. In accordance with the 2011 Department of 

Interior Policy on Consultation with Indian Tribes and 36 CFR Part 800.2(c)(2)(ii), the regulations 

implementing Section 106 of the National Historic Preservation Act of 1966 (as amended), OSMRE 

requests continued consultation with your tribe for the stages of the proposal development and 

implementation of the final federal action. 

Preparation of the EA will be completed pursuant to the Court-approved Joint Proposed Remedy, as 

approved by the United States District Court for the District of Colorado on September 14, 2015, in the 

case entitled WildEarth Guardians v. U.S. Office of Surface Mining et al., Case 1:13-cv-00518-RBJ (D. 

Colo. 2015). As part of the Court-approved remedy, OSMRE agreed to conduct a new NEPA analysis 

for Trapper’s current and future mining activities within Federal Coal Leases Nos. C-079641 and C07519. 

The Trapper Mine is located approximately 6 miles south of the town of Craig in Moffat County, 

Colorado, east of Colorado Highway 13. The proposed Project is occurring on two federal coal leases 

administered by the Bureau of Land Management (BLM) and located within the eastern portion of the 

Trapper Mine’s approved SMCRA Permit Area. Federal Coal Lease C-07519 was issued by the BLM 

1
 
 

 

 

 

 


 

in June 1958 and Federal Coal Lease C-079641 was issued by the BLM in October 1962. The leases 

within the SMCRA Permit Area cover a total of approximately 2,423 acres of Federal mineral estate. 

As of July 1, 2015, approximately 19 million tons of recoverable Federal coal remains within the 

Project area. The Trapper Mine uses a combination of dragline, truck shovel, and highwall mining 

methods to remove the overburden and mine the coal. 

The EA will update, clarify, and provide new and additional environmental information for the Project. 

As a result of the EA process, OSMRE will determine whether or not there are significant 

environmental impacts. An environmental impact statement will be prepared if the EA identifies 

significant impacts. If a finding of no significant impact is reached, and pursuant to 30 CFR 746.13, 

OSMRE will prepare and submit to the Assistant Secretary for Lands and Minerals Management 

(ASLM) a mining plan decision document recommending approval, disapproval, or conditional 

approval of the mining plan. The ASLM will approve, disapprove, or conditionally approve the mining 

plan approval document within the mining plan decision document, as required under the Mineral 

Leasing Act of 1920. 

A site that may be of interest is the Recurve Rockshelter (site number 5MF948). The site was first 

recorded in 1980 and was plotted in a side canyon of an intermittent tributary of the Williams 

Fork. The location of the 5MF948 can be found on Map M45 in the Trapper Mining Inc. (Trapper) 

Permit. In 2013, Trapper hired archaeological consulting firm Grand River Institute (GRI) to complete 

three block surveys to allow for planned expansion of the mine to the east. GRI found that 5MF948 

was incorrectly documented. The site is actually located within the permit area approximately 700 feet 

of mining projected to occur in 2016 based on map M10a of the permit. Site 5MF948 appears to 

consist of a number of petroglyphs on an outcrop of the Twentymile Sandstone. The outcrop has a 

south southeast aspect and is located on the opposite side of the mountain from where the Trapper mine 

is located. Unfortunately, a number of the petroglyphs have been shot with a firearm and have been 

damaged. The Colorado Division of Reclamation and Mining Safety (DRMS) have not found evidence 

that the damage has occurred from mining operation. However, DRMS has required that Trapper 

complete a study to evaluate if 5MF948 is far enough away from blasting at the mine, and given the 

expected sizes of the blasts, whether or not site will be affected. 

If you are interested, we would be willing to meet with you at your convenience to discuss the 

proposed mining plan modification and its impact on cultural resources. If you wish to provide 

comments please send those to: 

OSMRE WR 

C/O: Nicole Caveny 

Trapper Mine EA 

1999 Broadway, Suite 3320 

You also have the option to submit comments and/or questions to: OSM-NEPA-CO@OSMRE.gov, 

please ensure the subject line reads: ATTN: OSMRE, Trapper Mine MPDD EA. Additional 

information regarding the Project may be obtained from Nicole Caveny, telephone number (303) 293­

5078. We would appreciate receiving those comments with the next 60 days. For your convenience, 

information about the South Taylor Project can be accessed on the OSMRE Western Region website 

2
 
 


 

at: http://www.wrcc.osmre.gov/initiatives/trappermine.shtm. 

Thank you for taking the time to consider this project. If this letter has not been sent to the correct 

representative, please help us update our records. OSMRE will be in contact with your office in the 

coming weeks to inquire if you have had time to consider this project further. In the meantime, if you 

have any questions, please contact me directly at (303) 293-5035. 

Sincerely, 

Marcelo Calle, Manager 

Field Operations Branch 

Copy: 

Juanita Plentyholes, Vice-Chairwoman 

Terry Knight, THPO 

Attachments 

3
 
 

 

 

Archeological Site 5MF948; Petroglyph 

Archeological Site 5MF948; Petroglyph 

Archeological Site 5MF948; Petroglyph 
 

 

 

Archeological Site 5MF948; Petroglyph 

Archeological Site 5MF948; Petroglyph 

Archeological Site 5MF948; Petroglyph 
 

 

 

Archeological Site 5MF948; Petroglyph 

Archeological Site 5MF948; Petroglyph 

Archeological Site 5MF948; Petroglyph 

 

 

 

 

 

 


 


 


 

	 

	 

UV13 

£¤40 

Y a

m

p a 

R i v e r 

CRAI

STAT 

G

ION UV13 

N PIT AREA 

CRAIG 

FEDERAL

C-07519 

HORSE

GULCH

FILL 

FEDERAL

C-079641 

L PIT AREA

CUTS 1-28 

UV394 

£¤40 

Craig 

Grand Junction 

C O L O R A D O Denver 

Map extent shown in red. 

Legend 

SMCRA Permit Boundary 

Project Area 

Pit Outline 

Horse Gulch Fill 

Landslide 

Previous Mining 

Leases 

Federal | C-07519 

Federal | C-079641 

UV317 

DRAFT 

0 1.25 2.5 

Miles 

Feet 0 4,000 8,000 o 

Trapper Mine EA 

Pro

Figure 1-1 

ject Location 

C:\Trapper_Mine_EA\FIGs\DOC\1_PDEIS\FIG_xx_Project_Location.mxd 10/13/2015 

Appendix E 

Appendix E 

Public Comments and 

Responses 

OSMRE Federal Coal Leases C-07519 and C-079641 Mining Plan Modification 

Trapper Mine, Moffat County, Colorado – Environmental Assessment 

 

 

OSMRE - Trapper Mine 

Federal Coal Leases C-07519 and 

C-079641 Mining Plan Modification 

Public Comments on the Draft EA and 

OSMRE Response 
 

 

 

 

 

 

 

 

E-i 

Contents 

1.0 Introduction.....................................................................................................................................E-1
 

2.0 Comment Analysis Process..........................................................................................................E-1
 

3.0 Comment Overview........................................................................................................................E-2
 

3.1 Summary Comments and Responses .................................................................................E-2
	

3.1.1 Summary Comment 1............................................................................................E-2
	

3.1.2 Summary Comment 2............................................................................................E-3
	

3.1.3 Summary Comment 3............................................................................................E-4
	

3.1.4 Summary Comment 4............................................................................................E-5
	

3.1.5 Summary Comment 5............................................................................................E-6
	

List of Tables 

Table E-1 Comments Resulting in Changes to the EA.......................................................................E-7
	

Public Comment Response Summary 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

E-1 

1.0 Introduction 

The Trapper Mine Federal Coal Leases C-07519 and C-079641 Mining Plan Modification Environmental 

Assessment (Trapper Mine EA) and Unsigned Finding of No Significant Impact (FONSI) were released 

for public comment on January 25, 2016. The public comment period ran through February 19, 2016. 

Notice that the documents were planned for release, along with the release date, was published in the 

Craig Daily Press on January 21, 2016 and in the Meeker Herald Times on January 20, 2016. Once the 

documents were released, legal notice of availability was published in the Craig Daily Press on 

January 28, 2016 and in the Meeker Herald Times on January 27, 2016. Copies of the legal notice were 

also placed in several locations in Craig and Meeker. Copies of the EA were placed in the following 

public locations for public review: 

•	 OSMRE, Western Region, 1999 Broadway, Suite 3320, Denver, CO 80202 

•	 Colorado Division of Reclamation, Mining and Safety, 1313 Sherman St, Room 215, Denver, 

CO 80203 

•	 Moffat County Building, 221 W. Victory Way, Suite 130, Craig, CO 81625 

•	 Moffat County Library, 570 Green Street, Craig, CO 81625 

•	 Bureau of Land Management, Little Snake Field Office, 455 Emerson Street, Craig, CO 81625 

•	 Bureau of Land Management, White River Field Office, 220 East Market Street, Meeker, CO 

81641 

•	 Rio Blanco County Courthouse, 555 Main Street, Meeker, CO 81641 

•	 Meeker Public Library, 409 Main Street, Meeker, CO 81641 

•	 Rangely Public Library, 109 E. Main Street, Rangely, CO 81648 

Approximately 202 Notice of Availability letters were sent directly to those who requested notification of 

the release of the Trapper Mine EA during the public scoping period. Fifty-eight electronic DVD copies of 

the EA and unsigned FONSI were sent to adjacent landowners, nearby community leaders and other 

interested individuals. During the comment period a number of DVDs were returned for incorrect 

postage. As a result, OSMRE re-mailed all 58 DVDs and extended the comment period for the 

addressees through March 4, 2016. 

2.0 Comment Analysis Process 

Consistent with the National Environmental Policy Act (NEPA), 40 CFR 1503.4(b) and 43 CFR 46.305, 

responses included in this report address the comments received during the public comment period on 

the Trapper Mine EA and unsigned FONSI. Each comment letter or email received was read by OSMRE 

to ensure that all substantive comments were identified. The comments were not weighted by 

organizational affiliation or status of respondents, and the number of duplicate comments did not bias the 

analysis. The process was not one of counting votes, and no effort was made to tabulate the exact 

number of people for or against any given aspect of the Trapper Mine EA. Rather, emphasis was placed 

on the content of a comment. Conclusions on whether or not comments were considered substantive 

were based on the following definitions: 

•	 Substantive comments include those that challenge, with reasonable basis, the information in 

the Trapper Mine EA or the unsigned FONSI as being inadequate or inaccurate; develop 

reasonable alternatives not considered by the agency, or offer new specific information that may 

have a bearing on the decision. 

Public Comment Response Summary 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

E-2 

•	 Non-substantive comments are those that do not pertain to the Project Area, Proposed Action or 

alternatives, or express opinions or position statements about the project or agency policy 

without accompanying factual basis or rationale to support the opinion. 

All comments, substantive and non-substantive, and agency responses, are part of the Project record for 

the Trapper Mine EA, and have been considered during the decision-making process. The comment 

letters were reviewed, commenter data logged into a spreadsheet, and all information entered into the 

Project record. The purpose of this document is to provide responses to substantive comments received 

on the Trapper Mine EA and the unsigned FONSI. 

3.0 Comment Overview 

Comments were accepted from the release of the Trapper Mine EA on January 25, 2016 through March 

4, 2016. A total of 1,148 comment letters and emails were received. If substantive comments were 

identified within a letter, the resource area or concern was noted and summarized in the response to 

comments presented below in five summary comments and responses. Several comment letters 

contained corrections to the Trapper Mine EA that required specific responses and changes to the 

documents. Those comments with specific changes are shown on Table E-1 located following the 

summary comments and responses. 

3.1 Summary Comments and Responses 

This section paraphrases the substantive comments into Summary Comments and provides both 

general and specific responses. The following summary comments were identified after reviewing all of 

the comments. 

3.1.1 Summary Comment 1 

OSMRE should adopt the No Action Alternative. If approval is necessary, then OSMRE must prepare an 

environmental impact statement for the proposed mining plan. 

OSMRE has completed the Trapper Mine EA to determine if there would be significant effects as a result 

of approving the mining plan modification or if an Environmental Impact Statement (EIS) is required. 

OSMRE has properly and fully analyzed the direct, indirect and cumulative impacts in this EA in 

accordance with CEQ regulations. In NEPA documents, significance is determined by context and 

intensity as defined by CEQ regulations at 40 CFR 1508.27. The significance of the impacts to all 

resources is analyzed in the EA in chapters 4 and 5, and the rationale for the conclusions reached is 

provided. For the reasons described in the unsigned FONSI, we have determined that there are no 

significant impacts for the preferred alternative (Alternative A). Thus, an EIS is not warranted. 

Under the Mineral Leasing Act of 1920 the Secretary, as delegated to the Assistant Secretary Land and 

Minerals Management (ASLM), has the authority to approve, approve with conditions or disapprove an 

application for a mining plan modification. As described in Trapper Mine EA Chapter 1, 1.2.3 Statutory 

and Regulatory Background, OSMRE makes a recommendation to the ASLM on the decision for the 

mining plan modification. That recommendation is based on OSMRE consideration of seven factors 

listed in 30 CFR 746.13, one of which is “information prepared in compliance with NEPA, which includes 

the Trapper Mine EA.” OSMRE has not as yet submitted a recommendation to the ASLM on the 

decision. 

Public Comment Response Summary 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

E-3 

3.1.2 Summary Comment 2 

The Trapper Mine EA Fails to Analyze and Assess the Impacts of All Similar and Cumulative Actions 

including the Colowyo Mine and other mining operations in the western U.S. 

We disagree with the comment and believe that the Trapper Mine EA adequately considers direct and 

indirect effects of the Colowyo Mine and other mines in the region as appropriate. 

The cumulative impacts are discussed in Chapter 5.0 of the Trapper Mine EA. The Colowyo Mine is 

specifically discussed under Past and Present Actions in Section 5.2 with the Collom Expansion 

discussed under Reasonably Foreseeable Future Actions in Section 5.3. As shown in Table 5-1 in 

Section 5.1, the cumulative area, as defined for direct impacts for most of the resources, does not 

encompass the Colowyo Mine due to geographic distance and lack of connection. The cumulative 

impacts to air quality and climate change, special status species, socioeconomics, access and 

transportation do extend to include the Colowyo Mine and are discussed in the Trapper Mine EA at 

Sections 5.4.2, 5.4.9, 5.4.11, and 5.4.14, respectively. As discussed for air resources, the emissions 

associated with existing mining activities in the region are ongoing and ongoing air quality and climate 

impacts are reflected in the baseline data described in the Affected Environment, Section 3.3. In 

addition, although the cumulative impact assessment area for water resources does not extend 

downstream to the Colowyo Mine or upstream to other mines in the region, the Trapper Mine EA does 

include a discussion of the findings of the Colorado Division of Reclamation, Mining and Safety’s 

Cumulative Hydrologic Impact Assessment with regard to water resources in Section 5.4.4. 

In addition to the Colowyo Mine, two other active coal mining operations are discussed, as well as 

several coal mining operations in temporary cessation and permanent cessation. Other mining activities 

within Moffat, Routt and the eastern third of Rio Blanco County also were discussed. These activities 

meet the definition of similar actions because they are common in timing while more distant in 

geography. Mining activities outside of the defined area were not considered common in either timing or 

geography and were not included as similar actions in the Trapper Mine EA. 

The Trapper Mine EA also analyzes the indirect impacts of combustion of both the Colowyo Mine and 

Trapper Mine coal at the Craig Station and indirect impacts from placement of coal combustion residuals 

(CCRs) at the Trapper Mine. Because the CCRs are not distinguishable as coming from coal burned 

from the Trapper Mine or coal burned from the Colowyo Mine, there is no distinction of the coal source 

for the CCRs. 

The commenter indicated that because the Trapper Mine EA provides information on indirect impacts 

from combustion of Trapper mined coal and relates that information to statewide and national GHG 

emissions, the Trapper Mine EA must evaluate all similar coal mining projects on a national level. 

Information on how the annual emissions attributable to the Trapper Mine contribute to statewide and 

national GHG emissions was provided for context. The Trapper Mine EA discusses that there are no 

reliable scientific methods to quantify how the contribution of the GHG emissions attributable to Trapper 

individually affects global climate changes, so presenting the Trapper-attributable emissions in context of 

state and national emissions allows the public to better understand the context. 

Further the commenter indicates that other pending Interior Department coal decisions throughout the 

western US must be addressed by OSMRE in the Trapper Mine EA as similar or cumulative coal leasing 

and mining decisions when considering impacts to GHG and climate in the Trapper Mine EA. The 

analysis of all potential coal decisions in the western US as cumulative actions is outside of the scope of 

analysis as defined in the Purpose and Need in Section 1.3 of the EA. Although these activities are not 

within the scope of this Trapper Mine EA, to the extent that the commenter seeks a programmatic 

analysis of federal coal leasing managed by the Department of Interior’s Bureau of Land Management, 

we encourage the commenter to actively participate in the process surrounding the Department of 

Interior’s development of a programmatic Environmental Impact Statement on the federal coal leasing 

Public Comment Response Summary 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

E-4 

program. For more information about this initiative, please see http://www.blm.gov/wo/st/en/prog/energy/ 

coal_and_non-energy/details_on_coal_peis.html. 

The scope of cumulative actions analyzed in the Trapper Mine EA analysis is appropriate and meets the 

Purpose and Need for the Trapper Mine EA and as such is appropriate for making a FONSI 

determination. 

3.1.3 Summary Comment 3 

The Trapper Mine EA Fails to Analyze and Assess Impacts to Endangered Fish 

We disagree with the comment that the statement that the EA fails to analyze and assess impacts to 

endangered fish. Section 4.10 includes an impact analysis to the federally endangered Colorado 

pikeminnow, humpback chub, bonytail chub, and razorback sucker and the critical habitats of each of 

these species. These are specified by name where impacts would differ, but are collectively analyzed 

and referred to as Colorado River Fish where impacts would be similar. Impacts have been provided in 

separate subsections describing direct and indirect impacts (Sections 4.10.1 and 4.10.2, respectively). 

In order to provide further clarification, additional information has been brought forward from the 

Biological Assessment that has been submitted to the U.S. Fish and Wildlife Service as part of the 

Section 7 consultation in accordance with the Endangered Species Act. The Biological Assessment was 

included as Appendix B to the public review Trapper Mine EA. The Trapper Mine EA analysis specifies 

that the magnitude or level of indirect impacts cannot be determined due to the many uncertainties 

regarding the actual exposure and uptake of mercury and selenium that these endangered fish species 

and critical habitat are experiencing from Trapper Mine coal. 

The commenter expressed particular concern over the impacts of mercury and selenium discharge from 

water outflows, as well as deposition of mercury and selenium from the combustion of coal at Craig 

Station. Water outflows and the relationship of selenium and mercury discharge are described in 

Section 4.5.1.1 of the Trapper Mine EA. Given the water quality monitoring results observed to date and 

sediment controls in place, there is negligible direct exposure to selenium from Trapper Mine. TMI’s 

CDPS permit does not include an effluent limit for mercury (TMI 2012). However, in 2014, TMI began 

sampling for mercury at several of the mine CDPS outfall locations. Although the results have 

consistently indicated mercury is below the detection limit, the analyses to date has not achieved a 

detection limit below the 0.01 microgram per liter mercury standard for the Yampa River. Thus, it is not 

possible to determine the degree to which (if any) the mine has in the past or would in the future 

contribute mercury to the Yampa River and the associated effects to the Colorado River fish species. As 

part of conservation/mitigation measures required in the USFWS Biological Opinion, TMI will commit to 

providing funding for 12 quarters of mercury and methyl mercury sampling from 4 designated locations, 2 

in the White River and 2 in the Yampa River. TMI will also provide funding for a mercury deposition study 

to be conducted by the US Geological Survey investigating the methyl mercury uptake in fish tissue. 

Both of these conservation/mitigation measures are discussed in the Biological Opinion in Appendix C. 

The analysis in Section 4.10.2 comprehensively examines the amount of mercury attributable to Trapper 

Mine coal that is consumed at the Craig Generating Station. Our analysis process and results regarding 

indirect mercury emissions attributable to Trapper Mine coal for analysis area described in the Trapper 

Mine EA is consistent with the modeled results have been provided as Exhibit 1 from the commenter. 

Our calculated value of 0.1726 g/km2

/yr falls slightly above the median of the upper category (0.033284 -

0.264639 g/km2

/yr) shown on Exhibit 1 provided by the commenter. However, the Exhibit 1 information 

did not describe how the mercury categories were classified (i.e. quantiles, manual intervals, defined 

intervals, equal intervals, natural breaks, etc.), which is crucial to unbiasedly depicting the Exhibit 1 

analysis results. Furthermore, the Trapper Mine EA study area is based on an airshed boundary that 

differs from the area mapped on Exhibit 1 provided by the commenter so direct correlation of the two 

analyses is not possible. However, as pointed out above, the Trapper Mine EA calculations of mercury 

Public Comment Response Summary 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

E-5 

emissions attributable to combustion of coal from Trapper Mine are within the upper range of the data 

the commenter provided. 

The Trapper Mine EA analysis has taken a hard look at the published literature relevant to the region to 

identify the possible impacts related to mercury on the Colorado River Fish species. Results from studies 

by Hamilton et al. (2005) have been added to the selenium analysis for razorback sucker in 

Section 4.10.2. The values from Beckvar et al. (2005) that are summarized in the commenter referenced 

section of Exhibit 3 were present already in Section 4.10.2. The hypothesized population level impacts 

described by the U.S. Fish and Wildlife Service to Colorado pikeminnow have been added to the 

analysis. 

The commenter indicated that OSMRE must consult with the U.S. Fish and Wildlife Service over 

potential project impacts to threatened and endangered species in accordance with Section 7 of the 

Endangered Species Act. We agree and OSMRE has completed Section 7 consultation with USFWS to 

address impacts to federally listed species associated with the proposed action and this is discussed in 

Section 4.10 of the EA. A Biological Opinion has been issued by the U.S. Fish and Wildlife Service on 

impacts to the western yellow-billed cuckoo, Colorado pikeminnow, humpback chub, bonytail chub, 

razorback sucker, and associated proposed or designated critical habitat. The Biological Opinion is 

included in the final EA as Appendix C. The Biological Opinion found that the Project is not likely to 

jeopardize the four endangered fish, nor is it likely to destroy or adversely modify their critical habitats. 

The Biological Opinion also found that the project is not likely to adversely affect the western yellowbilled cuckoo and not likely to destroy to adversely modify proposed critical habitat. Mitigation and 

conservation measures are included in the Biological Opinion in Appendix C and discussed in 

Section 4.10. 

3.1.4 Summary Comment 4 

The Trapper Mine EA Fails to Analyze and Assess Impacts to Air Quality 

The commenter indicates that the Trapper Mine EA fails to contain any analysis or assessment of 

impacts to air quality and instead defers to the permitting of the State of Colorado to assert that air 

quality impacts will not be significant. The commenter goes on to discuss that the State of Colorado does 

not adequately regulate nitrogen dioxide from blasting emissions or the recently adopted NAAQS for 

ozone, and, therefore, the impacts are not adequately addressed. 

We disagree with the commenter’s assertions: the Trapper Mine EA includes a robust air quality analysis 

in Chapter 4 Environmental Consequences, Section 4.3, Air and Climate Resources, and does not defer 

to CDPHE permitting. This analysis includes an assessment of NAAQS compliance for blasting 

emissions that includes PM10, PM2.5, NOx, SO2, CO, and VOCs as shown in Chapter 4.0 for the worse 

case year on Tables 4-4 and 4-5, respectively. 

In addition, ozone emissions and compliance with the recently reduced ozone standard of 70 parts per 

billion is discussed in Chapter 5.0 of the EA. The ozone emissions are discussed in terms of cumulative 

ozone emissions and the current monitoring data for the airshed boundary which indicates that the area 

within the airshed boundary is in compliance (Table 5-5). Because the mining at Trapper Mine and coal 

combustion at Craig Station are not expected to change as a result of the proposed mining plan 

modification, the regional analysis based on existing monitoring is appropriate. 

The Trapper Mine EA also includes a discussion of the Colorado Air Resource Management Modeling 

Study (CARMMS) commissioned by BLM to track air quality across the different Colorado field offices, 

with a focus on addressing how potential future oil and gas development might affect air quality and is 

particularly useful in discussing projections of future O3 levels as described in Section 5.4.2.2 of the EA. 

CARMMS simulates the air quality effects of oil and gas development out to the year 2021, and 

simulates different levels of projected development. The “high” development scenario is based on 

reasonably foreseeable development scenarios developed by each local BLM field office. 

Public Comment Response Summary 
 

 

 

 

E-6 

The CARMMS modeling output for the 4th highest daily maximum concentration was reviewed for the 

“high” development scenario. The area of Moffat County surrounding Craig showed projected O3 levels 

from the CARMMS modeling generally in the 67 to 70 ppb range, which is within the updated NAAQS. 

Immediately near Craig and the Craig Station, the projected O3 levels from the CARMMS modeling 

would be in the 65 to 70 ppb range. In close proximity to the Craig Station, the NOX emissions from the 

power plant likely deplete the O3 levels, and this effect appears in the CARMMS modeling. 

In western sections of Moffat County and Rio Blanco County near Rangely, the projected O3 levels 

would be above the 70 ppb NAAQS level based on the CARMMS modeling for the “high” development 

scenario. However, the CARMMS areas of modeled O3 concentrations above 70 ppb are outside the 

Trapper Mine airshed boundary defined for the cumulative impact area. The projected elevated O3 levels 

in western sections of Moffat County and Rio Blanco County are likely due to the emissions associated 

with existing and future oil and gas development in the Uinta Basin of eastern Utah. 

3.1.5 Summary Comment 5 

The Trapper Mine EA Fails to Analyze and Assess Climate Change Impacts 

The potential impacts on climate change and GHG are discussed in Section 4.3 and Section 5.4.2 of 

the EA. The EA analysis follows the Draft CEQ Guidance regarding GHG and Climate Change in NEPA 

analyses (CEQ 2014). 

The commenter indicates that OSMRE inappropriately rejected analyzing and assessing the social cost 

of carbon emissions that would result from the proposed mining plan modification. 

As stated in the Trapper Mine EA OSMRE has elected not to specifically quantify the SCC for several 

reasons. 

1. There is no certainty that GHG emissions at Craig Station would actually be reduced if 

Trapper Mine coal from the Project Area was not mined given that Craig Station has 

alternative sources for coal, and the Trapper Mine also has non-federal coal reserves that 

could be mined (see Section 2.5). 

2. In order to provide any meaningful insight, the projected SCC would need to be viewed in 

context with other Project costs and benefits associated with the Proposed Action. 

The Trapper Mine EA further states that given the uncertainties associated with assigning a specific and 

accurate SCC to the Project, and the uncertainties that indirect GHG emissions would actually be 

reduced under any reasonable Project alternatives, OSMRE has elected to quantify direct and indirect 

GHG emissions and evaluated these emissions in the context of state and national GHG emission 

inventories (Table 4-14). 

Despite not using the SCC protocol, OSMRE did not ignore the effects or costs of carbon emissions. The 

Trapper Mine EA did evaluate the climate change impacts of the proposed action and alternatives using 

quantitative measures rather than dollars. The Trapper Mine EA quantified the estimated greenhouse 

gas emissions that would result from both direct and indirect actions associated with the alternatives. 

The direct and indirect effects from mining operations and coal combustion on GHGs and Climate 

Change are discussed in Section 4.3 of the EA and cumulative effects are discussed Section 5.4.2. 

Both analyses included a quantification of projected GHG emissions as CO2 equivalents. In addition to 

the quantitative measures, the Trapper Mine EA also qualitatively described the potential GHG/climate 

change impacts associated with emissions increases and complexities of these linkages in order to 

inform OSMRE’s decision making. 

Public Comment Response Summary 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

E-7 

Table E-1 Comments Resulting in Changes to the EA 

Comment Response Changes to EA 

Table 4-1; page 4-3 Air and Climate Resources. The 

indirect impacts of the combustion of GHG should be OSMRE is in agreement that the impacts related to 

classified as “negligible” rather than “minor,” based on the direct and indirect impacts of the combustion of GHG Table 4-1, page 4-2. 

precedent from other recent EA’s. gases are negligible. There is a high level of uncertainty - Change made under Air and Climate 

In the recently approved South Taylor EA, an emission rate associated with quantifying climate change impacts and Resources, Direct GHG emissions reduced 

of 13,000,000 metric tons per year was classified as a further uncertainty associated with linking those impacts impact from minor to negligible. 

“negligible impact” and not a “minor impact.” The Trapper to an individual emission source. GHG emissions Table 4-1, Page 4-3

EA estimated that even in the worst case, the emissions attributable to the Trapper Mine will not result in - Under Air and Climate resources, Indirect 

would only amount to 5,342,951 per year. As this number is detectable effects and would fit within the definition of GHG emissions reduced the impact from 

2-1/2 times less than that in the South Taylor EA, this negligible impacts as provided in Section 4.1. minor to negligible. 

should be reclassified as a negligible impact for purposes of 

this EA. 

Table 4-1; page 4-4 Water Resources. The phrase “and 

acid mine drainage” should be deleted. 

There is no potential for acid forming run-off at Trapper 

Mine because of the carbonate within the waste rock. 

OSMRE agrees with the comment. As discussed in 

Section 4.5.1.1, the acid generating potential at TMI is 

relatively low at less than 0.5 percent and the mine spoil 

material typically contains enough available carbonate 

for dissolution to effectively buffer acidic water 

generated by Pyritic oxidation. As a result, water quality 

impacts from acid mine drainage and release of trace 

metals are not expected to occur. The text has been 

changed to reflect this information. 

Table 4-1, Page 4-4

- Under Water Resources, Direct Surface 

Water Impacts, eliminated the reference to 

negligible impacts from acid mine drainage. 

Section 4.5.1.1, Page 4-29, Next to Last 

Paragraph 

- Reworded the last sentence to read “As 

such, surface water quality impacts from acid 

mine drainage and trace metals are not 

expected to occur.” 

Table 4-1, page 4-5 Fisheries and Wildlife. After “Minor 

impacts to Columbian sharp-tailed grouse due to loss of 

production area within the Project Area,” the commenter 

recommends adding “in the short run. In the long run, 

reclamation is expected to improve habitat over the original 

baseline.” 

The commenter notes that there would be no long-term 

impact to Columbian sharp-tailed grouse habitat. As mining 

disturbance is reclaimed, the reclaimed areas will create 

CSTG habitat superior to the pre-disturbance habitat for 

breeding, nesting and brood rearing. According to Figure 3-

13, Columbian Sharp-Tailed Grouse Range, some winter 

habitat may be lost but great gains in their production area 

would be seen with Alternative A. This revision is consistent 

with the findings in the text: “Reclaimed areas at Trapper 

Mine have shown an increased presence of Columbian 

sharp-tailed grouse. TMI has worked cooperatively with 

OSMRE agrees with the comment. Changes have been 

made to the discussion in Table 4-1 and in the 

discussion of Columbian sharp-tailed grouse Page 4-45. 

These changes clarify that impacts to the Columbian 

sharp-tailed grouse are minor in the short-term and 

following reclamation habitat for the Columbian sharptailed grouse will be improved over pre-mining 

conditions. 

Table 4-1, Page 4-6, Special Status 

Species, Direct Impacts 

- Changed the minor impact to indicate it 

would be short-term. Added the following 

sentence to the discussion; “In the long-term 

reclamation will improve Columbian sharptailed grouse habitat over the pre-mining 

conditions.” 

Section 4.10.1.1, Page 4-45, Columbian 

Sharp-Tailed Grouse heading - Reworded the 

last sentence to indicate the minor impacts 

would be short-term. Added a sentence at the 

end reading “Following reclamation habitat 

will be improved over the pre-mining 

conditions.” 

Public Comment Response Summary 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

E-8 

Table E-1 Comments Resulting in Changes to the EA 

Comment Response Changes to EA 

CPW to develop reclaimed areas to promote Columbian 

sharp-tailed grouse habitat and evaluate the presence of 

the species.” EA at 3.10.2.7. 

Page 4-29; final paragraph. There are seven permitted 

outfalls downstream, including Oak (017) and West Flume 

(019). 

Although Oak (017) and West Flume (019) are 

downstream of the Project Area, they are not directly 

downstream of the L and N Pits and would not receive 

significant runoff from the active mining areas. The 

discussion in the text has been revised to provide this 

clarification. 

Section 4.5.1.1, Page 4-29 Last Paragraph

- Reworded fifth sentence to read “Permitted 

outfalls directly downstream of the proposed 

Project Area mine pits include CDPS site 016 

on Sage Gulch.....” 

Page 4-35. The EA states that “The area of the I Pit in the 

western SMCRA permit boundary has not been previously 

mined, so there is no post-mining data available for 

comparison to help predict future impacts.” However, nearly 

all of the area above both Coyote Gulch and No Name 

Gulch ponds has been mined out for a number of years, so 

these ponds offer the best post-mining data available for 

comparison as they show history for all phases of mining 

OSMRE has reviewed the information presented in the 

comment and agrees that the No Name and Coyote 

Gulch ponds lie downstream of the proposed I Pit area. 

Water quality has been evaluated for these ponds and 

indicates that impacts from mining to water quality 

would be negligible in the short and long term. 

Section 4.5.2.1, Page 4-35 

- The sentence in the middle of the third 

paragraph has been revised to read as 

follows, “The area of the I Pit in the western 

SMCRA permit boundary has not been 

previously mined, but areas of No Name 

Gulch and Coyote Gulch upstream of the I Pit 

have been mined and post-mining drainage 

flows into the No Name and Coyote Gulch 

ponds. Hydrologic data collected from the No 

Name Gulch pond and the Coyote Gulch 

pond as well as near the L and N Pits 

and reclamation up to and including Phase III bond release. suggest that implementation of TMI’s CDPS 

Permit and drainage control measures would 

help limit surface water quality and quantity 

impacts to negligible levels in the short term 

and long term.” 

Page 4-37, last paragraph of 4.6.1.1. The following two 

sentences could potentially be confusing when read 

together: “This can make poor soils more productive and 

stable in areas that were unproductive before mining. 

However, mixing the horizons can make productive areas 

less productive leading to difficulty with revegetation of 

some species.” The commenter recommends replacing 

these statements with: “The net environmental effects of 

mixing horizons can be difficult to predict because it can 

make poor soils more productive and stable in areas that 

were unproductive before mining but also may have the 

effect of making previously productive areas less 

productive, leading to difficulty with revegetation of some 

species.” 

OSMRE agrees with the comment and has revised the 

wording of Chapter 4 to reflect this change. 

Section 4.6.1.1, last paragraph of section 

- The third sentence has been revised to read 

“The net environmental effects of mixing 

horizons can be difficult to predict because it 

can make poor soils more productive and 

stable in areas that were unproductive before 

mining, but also may have the effect of 

making previously productive areas less 

productive, leading to difficulty with 

revegetation of some species.” 

Public Comment Response Summary 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

E-9 

Table E-1 Comments Resulting in Changes to the EA 

Comment Response Changes to EA 

The commenter also recommends replacing the word 

“Scraping,” both here and in the following paragraph, with 

the more accurate term “salvaging.” 

Page 4-40, First paragraph of 4.9.1.1. Delete the 

sentence “Development of big sagebrush may take an 

additional 10 to 20 years.” There is simply not sufficient 

information to confidently estimate when the big sagebrush 

community will return or even that it necessarily will return. 

There are just too many variables. 

OSMRE agrees with the comment. However, instead of 

eliminating the sentence entirely, OSMRE has replaced 

the sentence with additional clarification on the inability 

to quantify the timing for full development of a big 

sagebrush community. 

Section 4.9.1.1, Page 4-40, end of first

paragraph 

- The last sentence has been replaced with 

the following, “The time required for 

development of a mature big sagebrush 

community is difficult to predict given the 

many factors which could affect the 

development of this community.” 

Page 4-59, First paragraph under 4.16.2.1. Delete 

“Facility structures would be demolished in-place and 

covered with a minimum of 6 feet (2 meters) of suitable 

material. The area will be regraded to achieve the approved 

post-mining topography followed by topsoil and seeding as 

described in the reclamation plan. All demolition materials 

(e.g. culverts, fencing) related to sedimentation ponds will 

be placed within the ponds and covered with a minimum of 

6 feet (2 meters) of suitable material or transported to the 

pit area during the reclamation process.” 

This is not contained within the Trapper approved permit. 

Trapper disposes of any solid waste in compliance with its 

solid waste permit. 

OSMRE agrees and the discussion has been deleted. 

Text has been inserted indicating that solid waste is 

disposed in accordance with the approved solid waste 

permit. 

Page 4-49, Section 4.16.2.1 

- The suggested language has been deleted. 

The following discussion has been added, 

“The removal of materials and products would 

considerably reduce the risks associated with 

spills and contamination of soil and 

groundwater. Solid waste would be disposed 

in accordance with the TMI approved solid 

waste permit. Inert materials that can be 

disposed in mine pits would be placed into 

pits during backfilling. When active 

reclamation is complete, the potential impacts 

of waste generation and disposal would be 

negligible.” 

The EA appears to fail to analyze and assess impacts to 

endangered fish and their critical habitat in the Yampa River 

drainage and downstream, including the endangered 

razorback sucker and Colorado pikeminnow and their 

designated critical habitat. 

Section 4.10 includes an impact analysis to the federally 

endangered Colorado pikeminnow, humpback chub, 

bonytail chub, and razorback sucker and the critical 

habitats of each of these species. These are specified 

by name where impacts would differ, but are collectively 

analyzed and referred to as Colorado River Fish where 

impacts would be similar. Impacts have been provided 

in separate subsections describing direct and indirect 

impacts. 

OSMRE does not agree that the EA failed to analyze 

and assess impacts to endangered fish and their critical 

habitat in the Yampa River drainage and downstream. 

The analysis is discussed in Section 4.10.2. Specific 

information in Section 4.10.2 was taken from the 

Section 4.10.2 

- Added information after the first paragraph 

to further describe the impacts to the 

endangered fish. Information was taken from 

the Biological Assessment. 

Public Comment Response Summary 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

E-10 

Table E-1 Comments Resulting in Changes to the EA 

Comment Response Changes to EA 

Biological Assessment developed as part of the 

consultation with the U.S. Fish and Wildlife Service in 

accordance with Section 7 of the Endangered Species 

Act, included as Appendix B to the EA. Additional 

information that defines the types of impacts to the 

endangered fish and their critical habitat has been 

brought forward from the Biological Assessment for 

inclusion in Section 4.10.2. Note that the analysis in the 

EA specifies that the magnitude or level of indirect 

impacts cannot be determined due to the many 

uncertainties regarding the actual exposure and uptake 

of mercury and selenium that these endangered fish 

species and critical habitat are experiencing from 

Trapper Mine Coal (see Section 4.10.2). 

....These findings are buttressed by reports indicating that 

mercury and selenium contamination are adversely 

affecting the Colorado pikeminnow and razorback sucker 

and their critical habitat in other rivers in the Colorado 

Plateau region and that contamination may be 

preventing the recovery of these species. With regards to 

the Colorado pikeminnow, the U.S. Fish and Wildlife 

Service recently reported: 

“Management strategies for controlling anthropogenic 

mercury emissions are necessary as atmospheric pollution 

can indirectly affect this endangered species, its critical 

habitat, and its recovery by ambient air exposure, 

deposition into aquatic habitat and bioaccumulation in diet 

OSMRE agrees with the findings mentioned in the 

referenced U.S. Fish and Wildlife Service report. The 

EA analysis has taken a hard look at the published 

literature relevant to the region to identify the possible 

impacts related to mercury on the Colorado River Fish 

species. The values from Beckvar et al. (2005) that are 

summarized in the referenced section of Exhibit 3 were 

present already in section 4.10. The hypothesized 

population level impacts described by U.S. Fish and 

Wildlife Service to Colorado pikeminnow have been 

added to the analysis in the EA. 

Section 4.10.2, Page 4-48 

- Paragraph added at the bottom of the page 

describing the U.S. Fish and Wildlife Service 

hypothesized population level impacts. 

Section 4.10.2, Page 4-49 

- References to the findings of Hamilton et al 

relative to selenium analysis for the razorback 

sucker have been added to the second full 

and fish tissues.” paragraph on the page. 

See Exhibit 3, U.S. Fish and Wildlife Service, “Colorado 

pikeminnow (Ptychocheilus lucius) 5-Year Review: 

Summary and Evaluation” (hereafter referred to as the 

In addition, reference to results from studies by 

Hamilton et al. (2005) has been added to the selenium 

analysis for razorback sucker. 

“Colorado pikeminnow 5-Year Review”) at 21. 

Public Comment Response Summary