Skyline Mine Flat Canyon Coal Lease Tract UTU-77114
 

Mining Plan Modification
 

Environmental Assessment
 

April 2017
 

Prepared in cooperation with the
 

US Department of the Interior Bureau of Land Management, US Department of Agriculture Forest
 

Service, and Utah Division of Oil, Gas, and Mining
 

US Department of the Interior 

Office of Surface Mining Reclamation and Enforcement 

Program Support Division
 

1999 Broadway, Suite 3320
 

Denver, CO 80202
 

Phone 303-293-5000
 

Fax 303-293-5032
 

 

 

Environmental Assessment April 2017 Table of Contents 

Table of Contents 

Chapter 1 Introduction....................................................................................................................... 1
 

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

1.2 Background ..........................................................................................................................2
 

1.3 Regulatory Framework and Necessary Authorizations ..................................................4
 

1.4 Purpose and Need for the Proposed Action.....................................................................6
 

1.4.1 Purpose.............................................................................................................................6
 

1.4.2 Need..................................................................................................................................7
 

1.5 Outreach and Issues Identification....................................................................................7
 

1.5.1 Scoping .............................................................................................................................7
 

1.5.2 Draft EA and FONSI .........................................................................................................8
 

Chapter 2 Proposed Action and Alternatives................................................................................ 11
 

2.1 Introduction........................................................................................................................11
 

2.2 Existing Operations...........................................................................................................11
 

2.2.1 Mining Methods...............................................................................................................13
 

2.2.2 Topsoil.............................................................................................................................14
 

2.2.3 Waste Rock Storage.......................................................................................................14
 

2.2.4 Access and Haul Roads .................................................................................................14
 

2.2.5 Power Lines ....................................................................................................................14
 

2.2.6 Ponds, Impoundments, Diversions.................................................................................15
 

2.2.7 Water Source..................................................................................................................15
 

2.2.8 Hazardous Materials .......................................................................................................15
 

2.2.9 Mine Personnel ...............................................................................................................16
 

2.2.10 Rail Transport..................................................................................................................16
 

2.2.11 Reclamation....................................................................................................................16
 

2.2.12 Life of Operations............................................................................................................18
 

2.2.13 Project Design Features .................................................................................................18
 

2.3 Proposed Action Alternative ............................................................................................24
 

2.3.1 Topsoil.............................................................................................................................25
 

2.3.2 Waste Rock Storage.......................................................................................................25
 

2.3.3 Access and Haul Roads .................................................................................................25
 

2.3.4 Power Lines ....................................................................................................................25
 

2.3.5 Mine Facilities .................................................................................................................25
 

2.3.6 Ponds, Impoundments, Diversion...................................................................................25
 

2.3.7 Water Source..................................................................................................................27
 

2.3.8 Hazardous Material.........................................................................................................27
 

2.3.9 Mine Personnel ...............................................................................................................27
 

2.3.10 Rail Transport..................................................................................................................27
 

2.3.11 Reclamation....................................................................................................................27
 

2.3.12 Life of Operations............................................................................................................27
 

2.3.13 Project Design Features .................................................................................................27
 

2.4 No Action ............................................................................................................................33
 

2.4.1 Alternatives Considered but Eliminated from Detailed Analysis....................................34
 

Chapter 3 Affected Environment..................................................................................................... 37
 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA i 
 

 

Table of Contents April 2017 Environmental Assessment 

3.1 Introduction........................................................................................................................37
 

3.2 Topography and Geology.................................................................................................50
 

3.3 Air Quality and Climate Change.......................................................................................54
 

3.3.1 Air Quality........................................................................................................................54
 

3.3.2 Climate Change ..............................................................................................................62
 

3.4 Social and Economic.........................................................................................................65
 

3.5 Greater Sage-Grouse.........................................................................................................67
 

3.6 Water Resources................................................................................................................69
 

3.6.1 Surface Water .................................................................................................................69
 

3.6.2 Groundwater ...................................................................................................................71
 

3.6.3 Surface and Groundwater Quality ..................................................................................72
 

3.6.4 Mine Dewatering and Discharges...................................................................................72
 

3.7 Soils.....................................................................................................................................73
 

Chapter 4 Direct and Indirect Impacts............................................................................................ 75
 

4.1 Introduction ........................................................................................................................75
 

4.1.1 Summary of Direct and Indirect Environmental Impacts................................................76
 

4.2 Topography and Geology.................................................................................................77
 

4.2.1 Proposed Action..............................................................................................................77
 

4.2.2 No Action.........................................................................................................................78
 

4.3 Air Quality and Climate Change.......................................................................................78
 

4.3.1 Proposed Action..............................................................................................................79
 

4.3.2 No Action.........................................................................................................................89
 

4.4 Social and Economic.........................................................................................................89
 

4.4.1 Proposed Action..............................................................................................................89
 

4.4.2 No Action.........................................................................................................................91
 

4.5 Greater Sage-Grouse.........................................................................................................92
 

4.5.1 Proposed Action..............................................................................................................92
 

4.5.2 No Action.........................................................................................................................93
 

4.6 Water Resources................................................................................................................93
 

4.6.1 Proposed Action..............................................................................................................93
 

4.6.2 No Action.........................................................................................................................98
 

4.7 Soils.....................................................................................................................................98
 

4.7.1 Proposed Action..............................................................................................................99
 

4.7.2 No Action.......................................................................................................................100
 

Chapter 5 Cumulative Impacts...................................................................................................... 101
 

5.1 Introduction ......................................................................................................................101
 

5.1.1 Analysis Areas ..............................................................................................................101
 

5.1.2 Past, Present, and Reasonably Foreseeable Actions..................................................101
 

5.2 Cumulative Impacts.........................................................................................................103
 

5.2.1 Topography and Geology .............................................................................................103
 

5.2.2 Air Quality and Climate Change ...................................................................................103
 

5.2.3 Social and Economic ....................................................................................................105
 

5.2.4 Greater Sage-Grouse ...................................................................................................105
 

5.2.5 Water.............................................................................................................................105
 

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Environmental Assessment April 2017 Table of Contents 

5.2.6 Soils...............................................................................................................................106
 

Chapter 6 Coordination and Consultation................................................................................... 107
 

6.1 Agencies and People Consulted....................................................................................107
 

6.1.1 Tribal Consultation ........................................................................................................107
 

6.2 Preparers and Participants.............................................................................................108
 

References....................................................................................................................................... 109
 

List of Tables 

Table 1. Approved Facilities and Acres of Disturbance......................................................................11
 

Table 2. Annual Shipments to Power Plants from Skyline Mine No.3*, 2010-2015...........................13
 

Table 3. Summary of the Proposed Action..........................................................................................25
 

Table 4. Issue Disposition....................................................................................................................38
 

Table 5. NAAQS...................................................................................................................................56
 

Table 6. Federal Prevention of Significant Deterioration Limits..........................................................57
 

Table 7. MATS Emission Requirements – Coal and Oil-Fired Units ..................................................59
 

Table 8. Utah Large Industrial Source Emissions (Tons per Year) by Facility - 2012 .......................60
 

Table 9. 2012 Oil and Gas Compressor and Gas Plant Emissions (Tons per Year) .........................60
 

Table 10. 1995-2014 Estimated US Greenhouse Gas Emissions Allocated to Economic
 

Sectors (in Million Metric Tons of CO2e) ........................................................................63
 

Table 11. US SO2 (Indirect GHG) Emissions......................................................................................64
 

Table 12. Employment by Industry – Carbon and Sanpete Counties.................................................65
 

Table 13. 2015 Electricity Generation Fuel Sources...........................................................................67
 

Table 14. Comparison of Direct and Indirect Impacts.........................................................................76
 

Table 15. Regulated Pollutants Evaluated for Air Quality Permit .......................................................79
 

Table 16. Skyline Mine Criteria Pollutant Emission Calculations (tons per year)...............................81
 

Table 17. Black Carbon Emissions (tons per year) from Haul Trucks, Proposed Action...................82
 

Table 18. Direct GHG Emissions (metric tons per year), Maximum 8 Million Tons ...........................85
 

Table 19. Ozone Precursor Emissions Rates Based on Maximum Annual Coal
 

Production.......................................................................................................................85
 

Table 20. Railcar Criteria Pollutant Emissions....................................................................................86
 

Table 21. GHG Coal Combustion Emissions, Proposed Action.........................................................88
 

Table 22. Rail Transport GHG Emissions...........................................................................................88
 

Table 23. 2011 Triennial Inventory (tons/year) .................................................................................103
 

Table 24. Skyline Mine Direct and Indirect Emissions as a Percentage of the Utah 

Cumulative Total Emissions .........................................................................................104
 

Table 25. List of Preparers ................................................................................................................108
 

Table 26. Contractors ........................................................................................................................108
 

Table 27. Comments on the Draft EA Resulting in Modifications to the EA.....................................C-1
 

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Table of Contents April 2017 Environmental Assessment 

List of Figures 

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

Figure 2. Skyline Mine Coal Flow Diagram .........................................................................................12
 

Figure 3. Proposed Action ...................................................................................................................26
 

Figure 4. Topography...........................................................................................................................51
 

Figure 5. Previous Mining ....................................................................................................................52
 

Figure 6. Generalized Columnar Section ............................................................................................53
 

Figure 7. Regional Airshed ..................................................................................................................55
 

Figure 8. Sage Grouse Priority Habitat Management Areas ..............................................................68
 

Figure 9. Watershed Boundaries.........................................................................................................70
 

Figure 10. Subsidence.........................................................................................................................96
 

Figure 11. Project Vicinity Coal Mines...............................................................................................102
 

Appendices 

Appendix A Outreach Letters and Legal Notices 

Appendix B Water Monitoring Results 

Appendix C Draft EA Public Comments and Responses 

Appendix D Biological Assessment 

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Environmental Assessment April 2017 Acronyms 

Acronyms 

Acronym Definition 

°F Degrees Fahrenheit 

μS/cm Micro-Siemens per centimeter 

μg/m3 Micrograms per cubic meter 

AQI Air quality index 

ASLM Assistant Secretary of Land and Minerals Management (Department of the Interior) 

BLM Bureau of Land Management 

CAA Clean Air Act of 1970 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

cfs Cubic feet per second 

CH4 Methane 

CO Carbon monoxide 

CO2 Carbon dioxide 

CO2e Carbon dioxide equivalent 

CO3 Carbon trioxide 

CWA Clean Water Act of 1972 

DEQ Department of Environmental Quality (DEQ) 

DOGM Division of Oil, Gas, and Mining (Utah) 

DOI Department of the Interior 

EA Environmental Assessment 

EIS Environmental Impact Statement 

EPA Environmental Protection Agency 

ESA Endangered Species Act of 1973 

ETV Emission threshold value 

FCLAA Federal Coal Leasing Amendments Act of 1976 

FDR Forest Development Roads 

FEIS Final Environmental Impact Statement 

FLPMA Federal Land Policy and Management Act of 1976 

FONSI Finding of No Significant Impact 

GHG Greenhouse gas 

gpm Gallons per minute 

GWh Gigawatt hours 

HAPs Hazardous air pollutants 

HCO3 Bicarbonate 

HFCs Hydrofluorocarbons 

MATS Mercury and Air Toxics Standards 

MER Maximum Economic Recovery 

Mg Magnesium 

mg/L Milligrams per liter 

MLA Mineral Leasing Act of 1920 

MMPA Mining and Minerals Policy Act of 1970 

MMT Million metric tons 

MPDD Mining plan decision document 

N2O Nitrous oxide 

NAAQS National Ambient Air Quality Standards 

NEPA National Environmental Policy Act of 1969 

NFMA National Forest Management Act of 1976 

NHPA National Historic Preservation Act of 1966 

NO2 Nitrogen dioxide 

NOx Nitrogen oxides 

NOI Notice of Intent 

NRCS Natural Resources Conservation Service 

O3 Ozone 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

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Acronyms April 2017 Environmental Assessment 

Acronym Definition 

ONRR Office of Natural Resources Revenue 

OSMRE Office of Surface Mining Reclamation and Enforcement 

PAP Permit application package 

Pb Lead 

PFCs Perfluorocarbons 

PM10 Particulate matter less than 10 microns in diameter 

PM2.5 Particulate matter less than 2.5 microns in diameter 

ppb Parts per billion 

ppm Parts per million 

R2P2 Resource Recovery and Protection Plan 

ROD Record of Decision 

SC-CO2 Social Cost of Carbon 

SF6 Sulfur hexafluoride 

SHPO State Historic Preservation Office 

SIR Supplemental Information Report 

SMCRA Surface Mining Control and Reclamation Act of 1977 

SO2 Sulfur dioxide 

SO4 Sulfate 

SOx Sulfur oxides 

SR State Route 

TDS Total dissolved solids 

U.S.C. United States Code 

UAC Utah Administrative Code 

UDAQ Utah Division of Air Quality 

UDWR Utah Division of Wildlife Resources 

UPDES Utah Pollutant Discharge Elimination System 

US United States 

USFWS United States Fish Wildlife Service 

VOC Volatile Organic Compounds 

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Chapter 1
 

Introduction
 

1.1 Introduction 

This Environmental Assessment (EA) has been prepared by the United States (US) Department of 

the Interior (DOI), Office of Surface Mining Reclamation and Enforcement (OSMRE), Western 

Region Office, in cooperation with the Utah Division of Oil, Gas, and Mining (DOGM); US Forest 

Service Manti-La Sal National Forest; and the Bureau of Land Management (BLM) Utah State 

Office and Price Field Office. The EA analyzes the potential environmental impacts of a mining plan 

modification proposed by Canyon Fuel Company, LLC owned by Bowie Resource Holdings, to 

underground mine new federally leased coal in the Flat Canyon Federal Coal Lease Tract UTU77114 at the Skyline Mine. Canyon Fuel Company, LLC submitted a permit application package 

(PAP) which included Flat Canyon Federal Coal Lease Tract UTU-77114 into their Surface Mining 

Control and Reclamation Act of 1977 (SMCRA), as amended, permit. Including the new lease UTU77114 in the mining plan would extend the life of the Skyline Mine by approximately 9 to 12 years. 

The Skyline Mine is located 27 road miles west of Helper, Utah, and approximately 5 miles 

southwest of Scofield, Utah. 

OSMRE published a draft EA and unsigned Finding of No Significant Impact in June 2016 (see 

Section 1.5). Modifications made to the EA are indicated with gray shaded text. Appendix C – Draft 

EA Public Comments and Responses has also been added. 

Mining activities may produce up to 8 million tons per year of coal (a limit established in the air 

e 

permit Approval Order DAQE-AN0092007-03 issued by the Utah Department of Environmental 

Quality, Division of Air Quality) from UTU-77114. However, it is anticipated that the Skyline Min

would likely produce 3 to 4.5 million tons per year, which has been their general range of production 

over the past 10 years. 

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

1969 (NEPA) as amended and the President’s Council on Environmental Quality (CEQ) regulations 

for implementing NEPA (40 Code of Federal Regulations [Code of Federal Regulations (CFR)] 

1500-1508); DOI regulations for implementation of NEPA (43 CFR Part 46); DOI Departmental 

Manual Part 516; and OSMRE guidance on implementing NEPA, including the OSMRE Handbook 

on Procedures for Implementing the National Environmental Policy Act (OSMRE 1989). Information 

gathered from federal, state, and local agencies; Canyon Fuel Company, LLC; publicly available 

literature; and other sources such as Canyon Fuel Company, LLC’s PAP, were used in the 

preparation of this EA. 

The NEPA requires federal agencies to disclose 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. If OSMRE determines that the potential 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

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Chapter 1	 April 2017 Environmental Assessment 

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 

Canyon Fuel Company, LLC has operated the Skyline Mine (Figure 1) since 1981 under Utah 

DOGM Permit C/007/0005. On February 27, 2015, Canyon Fuel Company, LLC submitted a 

significant revision to their mining plan to the Utah DOGM for the inclusion of the new Flat Canyon 

Federal Coal Lease Tract UTU-77114 into their SMCRA permit. Figure 1 shows the areas of 

disturbance covered by the permit and bonding. The Flat Canyon Federal Coal Lease Tract UTU77114 encompasses approximately 2,692 acres of federal coal reserves of the Wasatch Plateau 

Coal Field on National Forest System lands within the Manti-La Sal National Forest: 

•	 Township 13 South, Range 6 East, Salt Lake Meridian 

Section 21, Lots 1-4, E1/2E1/2;
 

Section 28, Lots 1-8, S1/2NW1/4, SW1/4; and
 

Section 33, E1/2, E1/2W1/2, NW1/4NW1/4, SW1/4SW1/4.
 

Consisting of 1,430 surface acres of federal coal.
 

•	 Township 14 South, Range 6 East, Salt Lake Meridian
 

Section 4, Lots 1-4 S1/2N1/2, S1/2; and
 

Section 5, Lots 1-4 S1/2N1/2, S1/2.
 

Consisting of 1,262 surface acres of federal coal. 

Two areas of privately-owned land, consisting of approximately 1,100 surface acres, (which 

includes 268 coal acres) are adjacent to the Flat Canyon Federal Coal Lease Tract UTU-77114: 

•	 Township 13 South, Range 6 East, Salt Lake Meridian
 

Section 29 E1/2SE1/4, SE1/4NE1/4, S1/2NE1/4NE1/4 and
 

Section 32, E1/2E1/2.
 

•	 Township 14 South, Range 6 East, Salt Lake Meridian 

Section 3, Lots 1 and 2; S1/2NE1/4; E1/2SE1/4; E1/2W1/2SE1/4; NW1/4NW1/4SE1/4; 

Section 8, N1/2N1/2; 

Section 9, N1/2N1/2; and 

Section 10, N1/2NW1/4; NW1/4NE1/4; W1/2NE1/4NE1/4. 

The Flat Canyon Federal Coal Lease Tract UTU-77114 and adjacent private lands are collectively 

the Project Area; therefore, the total area analyzed in this EA is approximately 3,792 acres, with a 

probable maximum of 47 million tons of federal and private coal to be mined over 9 to 12 years. Flat 

Canyon Federal Coal Lease Tract UTU-77114 is in Sanpete County, Utah, while private surface 

and coal ownership extends into Emery County. The Skyline Mine surface facilities are in Carbon 

County. 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

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Environmental Assessment April 2017 Introduction 

Figure 1 - Project Location 

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Chapter 1 April 2017 Environmental Assessment 

The Forest Service, Manti-La Sal National Forest manages the surface resources within their 

jurisdiction and other uses including, but not limited to, special use permits for outfitting, rights-ofway, grazing permits, and scientific collection permits. Subsurface minerals are managed by the 

BLM. All of the coal resources are subsurface (1,500 feet underground). On March 18, 1998, 

Canyon Fuel Company, LLC requested to mine the Flat Canyon Lease tract. The Manti-La Sal 

National Forest, and the BLM Utah State Office, with OSMRE as a cooperating agency, completed 

a Final Environmental Impact Statement (FEIS) reviewing the impacts of the federal coal leasing 

action (US Forest Service, 2002a), the BLM also signed a Record of Decision (ROD) (BLM, 2002) 

to offer the lease for sale, and the Forest Service issued a ROD in 2002 (US Forest Service, 2002b) 

consenting to the leasing action proposed by the BLM. 

Canyon Fuel Company, LLC subsequently requested that the sale of the lease be delayed. On 

June 21, 2012, Canyon Fuel Company requested to reinitiate the lease sale. Because the NEPA 

review was more than 10 years old, in compliance with the Forest Service Handbook 1909.15, the 

Manti-La Sal National Forest reviewed the project and completed a supplemental information report 

(SIR) (US Forest Service, 2013), which identified the changed conditions, determined that the new 

information did “not constitute significant new circumstances or information relevant to 

environmental concerns and bearing” on the decision, and confirmed the Forest Service consent to 

lease decision. The Forest Service issued a consent letter on February 4, 2015. The BLM also 

completed a Determination of NEPA Adequacy (BLM, 2015a) under BLM Handbook 1700-1, 

determining that the 2002 analysis was adequate to support the NEPA decision under current 

circumstances. The Flat Canyon Federal Coal Lease Tract UTU-77114 was actioned on June 17, 

2015. Canyon Fuel Company, LLC leased the Flat Canyon Federal Coal Lease Tract UTU-77114 

from the BLM on July 1, 2015. 

1.3 Regulatory Framework and Necessary Authorizations 

The following key laws, as amended, establish the primary authorities, responsibilities, and 

requirements for developing federal coal resources: 

• Mineral Leasing Act of 1920 (MLA); 

• National Historic Preservation Act of 1966 (NHPA); 

• National Environmental Policy Act of 1969 (NEPA); 

• Mining and Minerals Policy Act of 1970 (MMPA); 

• Clean Air Act of 1970 (CAA); 

• Clean Water Act of 1972 (CWA); 

• Endangered Species Act of 1973 (ESA); 

• Utah Surface Coal Mining Reclamation Act of 1979; 

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

• Federal Coal Leasing Amendments Act of 1976 (FCLAA); 

• National Forest Management Act of 1976 (NFMA); and 

• Surface Mining Control and Reclamation Act of 1977 (SMCRA). 

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Environmental Assessment April 2017 Introduction 

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 Forest Service has authority to consent to BLM issuing leases on 

National Forest System lands. If consent is given, the Forest Service identifies conditions 

(stipulations) for use and protection of the non-mineral resources in the lands subject to leasing. 

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 and the Forest Service complies with NFMA to plan for multiple uses of 

public lands and determine if the land is 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 the potential impacts from coal leasing and 

development, and also complies with the NHPA, CAA, CWA, ESA, and other environmental laws 

ensuring appropriate protection of other resources. BLM then makes the lands determined suitable 

for coal development available for leasing. BLM is also 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 federal leases and 

ensures that waste of federal coal resources is minimized through review and approval of a mine’s 

Resource Recovery and Protection Plan (R2P2) as required under the MLA. BLM implements its 

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

at CFR, Title 43, Public Lands, Subtitle B, Chapter II, BLM, Department of the Interior, Subchapter 

C – Minerals Management, Parts 3400 – 3480. 

On surface estate managed by the Forest Service, the Forest Service must consent with the 

approval terms of coal mining, determine the adequacy of the reclamation bond, and ensure coal 

mining plans are consistent with lease stipulations. The Forest Service implements its 

responsibilities for oversight of coal exploration and development following the Forest Service 

Manual 2800. 

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 

society while also ensuring the mined land is returned to beneficial use when mining is finished. 

OSMRE implements its responsibilities for the MLA and SMCRA under regulations at CFR Title 30 ­

Mineral Resources, Chapter VII - OSMRE, Department of the Interior, Subchapters A-T, Parts 700­

955. 

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

regulatory programs to regulate coal mining. Once a regulatory program is approved for a state, 

OSMRE provides oversight. OSMRE has approved Utah DOGM’s coal regulatory program (30 CFR 

Part 944 (OSMRE, 1994)), therefore Utah DOGM manages its program under Utah Coal Mining 

and Reclamation Act (1979). Utah DOGM has the authority and responsibility to make decisions to 

approve surface and underground coal mining permits and regulate coal mining in Utah under Utah 

Administrative Code R645-301. The Utah DOGM will review the PAP specifying the mining and 

reclamation methods to be employed in the permit amendment. Once Utah DOGM finds the PAP 

administratively complete, the PAP will be submitted to OSMRE for review. The Utah DOGM will 

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Chapter 1	 April 2017 Environmental Assessment 

continue to work with the permittee to finalize the PAP. Publication of the proposed significant 

revision, which is required before DOGM can approve a permit revision, is required for 4 

consecutive weeks. The commenting period occurs over the course of the 4 consecutive weeks of 

publishing and also 30 days after the last publishing. After the public comment period and when the 

PAP is finalized, Utah DOGM will issue their findings and recommendations to OSMRE and, if 

deemed appropriate, issue the permit to the permittee. 

Once the State’s findings and recommendations are received, OSMRE will prepare a mining plan 

decision document (MPDD) in support of its recommendation to the Assistant Secretary for Land 

and Minerals Management (ASLM), who will decide whether or not to approve the mining plan 

modification and whether or not additional conditions are needed. Pursuant to 30 CFR 746.13, the 

OSMRE‘s recommendation shall be based on: 

•	 The PAP including the R2P2; 

•	 Information prepared in compliance with NEPA, including this EA including the federal land 

management agency;
 

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

regulations, and executive orders other than NEPA;
 

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

•	 Findings and recommendations of the BLM with respect to the R2P2, federal lease 

requirements, and the MLA;
 

•	 Findings and recommendations of the Utah DOGM regarding the PAP and the Utah State 

program; and
 

•	 The findings and recommendations of the OSMRE regarding additional requirements of 30 

CFR Chapter VII, Subchapter D.
 

1.4 Purpose and Need for the Proposed Action 

As described at §1502.13 (40 CFR 1500-1508) the purpose and need statement shall briefly specify 

the underlying purpose and need to which the agency is responding in proposing the alternatives 

including the Proposed Action. 

1.4.1 Purpose 

The purpose of the action is established by the MLA and the SMCRA, which requires the evaluation 

of Canyon Fuel Company, LLC’s PAP before Canyon Fuel Company, LLC may conduct 

underground mining and reclamation operations to develop the Flat Canyon Federal Coal Lease 

Tract UTU-77114. OSMRE is the agency responsible for making a recommendation to the ASLM to 

approve, disapprove, or approve with conditions the proposed mining plan modification. The ASLM 

will decide whether the mining plan modification is approved, disapproved, or approved with 

conditions. 

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Environmental Assessment April 2017	 Introduction 

1.4.2 Need 

The need for the action is to provide the opportunity for Canyon Fuel Company, LLC to exercise its 

valid existing rights granted under Flat Canyon Federal Coal Lease Tract UTU-77114 to extract coal 

from their leased federal coal under the MLA. The Proposed Action to approve the mining of the 

coal within Flat Canyon Federal Coal Lease Tract UTU-77114 would also provide access for mining 

of private coal reserves, which would be geographically and economically accessible through the 

federal coal lease and contribute to continued operations for approximately 9 to 12 additional years. 

1.5 Outreach and Issues Identification 

1.5.1 Scoping 

On October 9, 2015, a letter was sent to 62 addresses on a mailing list including adjacent 

landowners, federal, state, and local agencies, and other individuals and organizations known to be 

interested in coal mining activities in Carbon, Emery, and Sanpete counties. Legal notices 

announcing the project and requesting comments were published in the Emery County Progress 

and Sun Advocate newspapers on October 13 and 27, 2015, and the Sanpete Messenger on 

October 25 and 29, 2015. The letter and legal notices are in Appendix A. 

OSMRE developed a project website, which provided additional notice, information, and comment 

opportunities: http://www.wrcc.osmre.gov/initiatives/skylineMine.shtm. The website was activated 

on October 16, 2015, and is updated periodically as additional information becomes available. 

Five letters (WildEarth Guardians, Sierra Club, Sanpete County, Carbon County, Utah Office of the 

Governor Public Lands Policy Coordinating Office) were received (support and opposition), along 

with a mass mailing of approximately 273 emails largely stating the same opposition to the project. 

OSMRE reviewed all scoping comments received and issues identified to be evaluated in this EA. 

The primary focus of WildEarth Guardian’s letter was air quality and climate change, cumulative 

effects, threatened and endangered species, impacts on water quality, the social cost of carbon, 

and the need for an EIS. They also identified several potential alternatives, which are described in 

Section 2.4.1. The Sierra Club letter included issues similar to the WildEarth Guardians, along with 

the issues related to the Clean Power Plan. Sanpete County provided information on the economic 

impact Skyline Mine has on the county (jobs, royalty revenue, income, and revenue) to the state. 

Carbon County raised concerns about water resources and the importance of them, and economic 

importance (income and jobs). The mass mailing letters were generated by a WildEarth Guardians 

website alert and included the same issues as the letter from the WildEarth Guardians. The 

Governor’s Office generally supported the employment and power supply qualities of the proposal 

and stated concerns about wildlife. 

Examples of the comments related to the concerns listed include: 

•	 Climate Change Impacts, emissions of methane (including from mining activities), carbon 

dioxide, and other greenhouse gases that have been found to endanger public health and 

welfare, extent they contribute to global climate change.
 

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Chapter 1	 April 2017 Environmental Assessment 

•	 516 DM 13, approval of a mining plan requires an environmental impact statement (EIS) 

where “[t]he environmental impacts of the proposed mining operations are not adequately 

analyzed in an earlier environmental document covering the specific leases or mining activity,” 

“[t]he area to be mined is 1280 acres or more, or the annual full production level is 5 million 

tons or more,” and “[m]ining and reclamation operations will occur for 15 years or more.” 516 

DM 13.4(A)(4). Upon review of available information, it appears that all three criteria are met 

with regards to the proposed mining plan modification. 

•	 Use the social cost of carbon to analyze and disclose the climate impacts of the proposal. 

•	 [A]nalyze whether the proposed Flat Canyon expansion would interfere with efforts to meet 

federal greenhouse gas emission reduction targets established by the Obama Administration 

and are in line with the goals of the Clean Power Plan and Climate Action Plan. 

•	 Request for a social cost of carbon analysis 

•	 The greatest environmental impact to Sanpete County is reflected in the Socio-Economic 

benefit. Currently, Skyline Mine employs over 200 full-time employees which contribute 

significantly to our economy. This equates to approximately $14 million annually in wages and 

benefits for these employees. Therefore, it is imperative that this mine grow and continue to 

produce coal for the next 9-12 years. 

•	 The estimated royalty revenue to Sanpete would be somewhere around $2 million annually. 

•	 [M]aintaining the water management program to protect our watershed would be an issue to 

consider through the EA process. 

•	 [C]oal mining is the historic and economic backbone of Carbon County. Coal mining 

historically is the biggest supplier of high paying jobs in our county and for many years 

provided the highest royalty income to our government infrastructure until the last few years 

when oil and gas production over took it. 

•	 The primary impact to wildlife likely to result from mining operations as proposed involves 

potential reduction of surface water flow associated with and caused by mining subsidence. 

The issues and how they are included in the analysis are shown in in Table 4 (see Chapter 3). 

1.5.2 Draft EA and FONSI 

The Skyline Mine Flat Canyon Coal Lease Mining Plan Modification EA and unsigned Finding of No 

Significant Impact (FONSI) were released for public review on June 16, 2016. The public comment 

period ended on July 28, 2016. 

Letters notifying the public that the EA and unsigned FONSI were available were sent to 63 mailing 

addresses. This list of addresses included all who received the scoping notice and any others that 

commented during scoping, with the exception of those who submitted the campaign letters. A 

notice that the documents were available for review was published in the Sun Advocate, Emery 

County Progress, and Sanpete Messenger on June 16, 2016, stating that the EA would be available 

for review. Due to unforeseen circumstances, the EA was not published on the OSMRE’s website 

as anticipated; however, hardcopies of the EA were made available by June 16, 2016 at the public 

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locations listed below. Legal notices were again published on June 28 and 30 and July 12 and 14. 

The comment period was extended accordingly to allow the full 30 days. 

• Manti-La Sal National Forest Supervisor’s Office, 599 West Price River Road, Price, UT, 

84501; 

• Utah Division of Oil, Gas, and Mining, Public Information Center 1594 West North Temple, 

Salt Lake City, UT, 84116; 

• Office of Surface Mining and Reclamation, 1999 Broadway, Suite 3320, Denver, CO, 80202; 

• Bureau of Land Management, Utah State Office, 440 West 200 South, Suite 500, Salt Lake 

City, UT, 84101; and 

• Price Library, 159 East Main Street, Price, UT, 84501. 

The EA and unsigned FONSI were posted on the OSMRE’s project website on June 28, 2016. 

Revised notices were published in the same newspapers and revised letters were sent directly to 

the 63 addresses. 

A summary of the comments received and responses can be found in Appendix C. 

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Chapter 2
 

Proposed Action and Alternatives
 

2.1 Introduction 

This chapter describes the alternatives considered and analyzed in detail; the Proposed Action and 

the No Action. In addition, it identifies alternatives considered but eliminated from detailed analysis. 

This chapter also describes the current operations, which explains the continuation of activities 

under the Proposed Action and under the No Action. 

2.2 Existing Operations 

Utah DOGM originally approved the SMCRA permit for the Skyline Mine in 1981 (DNR, 2015). 

Since then, Skyline Mine has operated an underground mine on leasehold interests on 

approximately 10,733 acres and mined almost 100 million tons of coal in 3 mining areas named 

Upper O’Conner Mine No. 1, Lower O’Connor A-Lower O’Connor B Mine No. 2, and the Lower 

O’Connor A Mine No. 3. 

The Skyline Mine surface facilities are located in Township 13 South, Range 6 East, Section 13 

(see Figure 1). Support facilities include a rail load-out, conveyors, coal stockpiles, crushers, waste 

rock storage, ventilation, and other systems. The existing mine facilities total approximately 140 

acres of surface disturbance (Table 1). The coal is mined underground and transported by 

underground conveyor to the surface transfer building (see Figure 2). 

Table 1 - Approved Facilities and Acres of Disturbance 

Facility Disturbed Acres 

Swens Canyon Ventilation Facility (added 7/19/2016) 14.50 

Load-out 13.86 

Portal Yard 42.55 

Water tanks, water lines, and well pads 0.60 

Conveyor bench 14.18 

Waste rock disposal site and road 32.48 

South Fork breakout 0.96 

James Canyon Buried Power Line 0.30 

James Canyon Buried Pipeline 1.60 

James Canyon water wells and road 2.95 

Winter quarters ventilation facility 7.93 

North of Graben Shaft 3.00 

Winter Quarters Road 4.90 

Total 139.81 

Coal is transferred by covered conveyor either to a stockpile or to a silo. Stockpiled coal is 

eventually transferred via covered conveyor back to the transfer building (all transfer drop points are 

in buildings with baghouses) then on to the silo. After passing through the silo where waste rock 

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Figure 2 - Skyline Mine Coal Flow Diagram 

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and oversized material is segregated, coal is transferred by conveyor to crushers for crushing as 

needed. Some coal from the silos could enter the stoker circuit before going to another load-out bin, 

where it is loaded onto a truck for transportation to market. Waste rock from the silo is sent through 

a covered chute to the nearby waste rock pile. From the crushers, coal is transferred approximately 

2 miles by covered pipe belt fully exposed (“tube”) conveyor to a unit train loading system or may be 

transferred onto trucks to be transported to customers on the public highway system. 

Coal from Skyline Mine has typically gone to industrial customers and electrical power plants 

(Galecki, 2015a). Contracts are generally of short duration. Past contracts are not necessarily a 

predictor for future shipments. Table 2 provides information on which electricity generating plants 

received coal from Skyline Mine within the past 6 years. The remainder of the coal was shipped to 

customers for mineral processing, heat generation, and coal ash materials. Coal from Skyline Mine 

is blended and destinations are based on (1) specific characteristics of coal being mined; (2) the 

characteristics of coal being mined at other Bowie Resource Holdings mines; and (3) specific needs 

of a customer. 

Table 2 - Annual Shipments to Power Plants from Skyline Mine No. 3, 2010-2015 

Plant/Year1 2010 2011 2012 2013 2014 2015 

Colbert -­ -­ 6,661 -­ -­ -­

Paradise -­ -­ -­ -­ -­ -­

Shawnee -­ 90,986 31,188 -­ -­ -­

Reid Gardner 215,276 83,033 -­ -­ -­ -­

Allen Steam Plant -­ -­ 30 -­ -­ -­

Cumberland (TN) -­ -­ 6,035 5,152 -­ -­

Carbon 255,520 327,248 50,618 -­ -­ -­

Hunter -­ -­ -­ -­ 3,198 589,214 

Intermountain Power Project -­ 142,520 104,976 464,205 779,054 909,840 

Huntington -­ -­ -­ -­ -­ 303,216 

North Valmy 689,605 854,023 216,615 -­ -­ 193,149 

Stockton Cogen 98,964 83,772 -­ -­ -­ -­

Stockton Biomass -­ -­ -­ -­ -­ -­

Mt Poso Cogeneration 128,737 48,452 -­ -­ -­ -­

Total Shipped to Power Plants 1,388,102 1,630,034 416,123 469,357 782,252 1,995,419 

Total Production From Skyline 

Mine2 

2,805,489 2,948,091 1,894,468 3,137,170 4,170,162 Data Not 

Available 

Percentage used by Power 

Plants 

49 55 22 15 19 Not 

Applicable 

Source:
 

1 (Energy Information Administration, 2016a).
 

2 (Energy Information Administration, 2016b).
 

2.2.1 Mining Methods 

Mining methods include continuous miner and longwall panel extraction. Longwall panels are 

generally more than 2,500 feet long, although they vary depending on physical and economic 

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factors. The minimum thickness has been 6 feet. Continuous miners are used for mine 

development and some limited using the first-mining room and pillar method, where pillars remain 

permanently to avoid subsidence. 

Underground mine access is from 5 portals at different sites, which provide air intake, mining crew 

transportation, material transportation, and air exhaust. One additional portal is used for conveying 

coal from the mine. Portals were constructed in 1982. 

2.2.2 Topsoil 

Topsoil has been removed and stockpiled prior to construction and protected from wind and water 

erosion and contamination. To prevent suitable topsoil from being wasted or contaminated by spoil 

or other waste materials, topsoil removal was a separate operation. Stockpiled topsoil will not be 

removed or otherwise disturbed until required for redistribution operations on a prepared, regraded 

disturbed area. Stockpiled topsoil will be immediately seeded as they have in the past. The seed 

mix may need to be altered based on seed availability. Modifications will be based on consultation 

with Utah DOGM personnel. 

2.2.3 Waste Rock Storage 

The approved waste rock disposal site is 3.6 air miles from the Skyline Mine. It is an abandoned 

strip mine pit. Rock wastes are hauled by truck from the portal area and the rail load-out facility. 

Underground rock waste produced during mining operations is stored there when it cannot be 

permanently stored underground due to space. A very small portion is stored above ground 

because nearly all is kept underground. 

2.2.4 Access and Haul Roads 

The Eccles Canyon Road from Highway State Route (SR)-96 to Highway SR-31 has been included 

in the State Highway System as Utah State Highway SR-264. Approximately 2.5 miles of paving 

was completed on the road adjacent to Eccles Creek. The public road was constructed to bypass 

the mine portals and facilities. It is managed by the Utah Department of Transportation. The Mine 

Portal Road is approximately 1,200 feet of primary road, surfaced with crushed gravel. Other local 

roads provide access to the mine portals, storage areas, and various buildings. 

A truck loop around the storage silos was upgraded from gravel to asphalt in 2009. The loop is 

accessed from SR-96. The upgrade reduced dust and track-out onto the highway. Subsequently, 

some asphalt areas were upgraded to concrete when the asphalt deteriorated. 

2.2.5 Power Lines 

Overhead power lines provide power to the mine and surface facilities. Underground mining 

operations, conveyors, buildings, and wells are powered with electricity. Electricity reaches the site 

via overhead power lines. From there, some power is distributed by buried cable. Cables are 

generally buried in next to a road. 

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2.2.6 Ponds, Impoundments, Diversions 

Except for small areas, all water run-off from disturbed areas is directed to sediment ponds through 

a collection system of surface ditches, swales, and culverts. No drainage from the Utah State 

Highway system enters the mine drainage system. Four sediment ponds are used at the mine 

facilities. 

1.	 The mine site sedimentation pond contains additional volume to adequately treat mine water 

discharge. This pond is located at the mine site adjacent to the crushing and truck loading 

station. Mine water is permitted to be discharged directly to Eccles Creek. 

2.	 The coal load-out sediment pond treats surface runoff. This pond is designed to hold a peak 

run-off from a 6-hour 100-year storm event. 

3.	 The rock disposal sediment pond is located at the west end of the disposal site. The design 

capacity of this pond is for run-off from a 10-year, 24-hour precipitation event, and 2 years of 

sediment yield. 

4.	 The Winter Quarters ventilation facility pond is located at the east end of the Winter Quarters 

ventilation facility site. The volume of this pond provides retention of run-off from a 10-year, 

24-hour storm. 

When ponds are being cleaned of sediment (at least every 3 years), storm water discharge is 

discharged per the Utah Pollutant Discharge Elimination System (UPDES) permit requirements. All 

discharges from the ponds are permitted to discharge to nearby Creeks. 

The 3 main tributaries to Eccles Creek are diverted under the mine facilities through a system of 

large culverts. This diversion system is designed to handle the run-off from a 100-year, 24-hour 

precipitation event. Four seep areas are dewatered with French drains and discharged directly to 

the diversion culverts. Run-off from surrounding hillsides is intercepted by a system of diversion 

channels that handle a 10-year, 24-hour storm event. These channels are lined with mature 

vegetation to reduce erosion and to provide energy dissipation. Channels have been seeded and 

have well-established vegetation. 

The Mine and Reclamation Plan was updated in June 2016 to modify the monitoring for stream 

changes due to mine water discharge. The annual surveys will be conducted if sustained mine 

discharges are in excess of 7,500 gallons per minute (gpm) or 17 cubic feet per second (cfs). These 

surveys will be submitted in the respective Annual Report (Galecki, 2016b). 

2.2.7 Water Source 

Mine water is from underground sources on existing water rights. Underground storage sumps store 

mine drainage water. The water is used as mine process water within the mine. High or low pH is 

treated before discharge from the permit area. 

2.2.8 Hazardous Materials 

No toxic waste materials are anticipated. If any are identified, they will be stored and/or disposed of 

in accordance with all applicable state and federal regulations. 

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Diesel fuel, gasoline, and oil are stored in above ground tanks located behind impervious concrete 

walls, which form containment areas that will hold the entire contents of the single largest tank plus 

sufficient freeboard to allow for approximately 5 inches of precipitation. 

The explosive magazine (for storing explosives for underground construction and mining activities) 

is not located near power line, fuel tanks, storage areas, or other possible sources of fire. 

Construction material is noncombustible and covered with a fire retardant. 

According to the Mine and Reclamation Plan, extensive testing of soil material near the coal seams 

failed to identify the presence of any materials capable of causing acidity or toxicity problems. 

However, material placed in the waste disposal site will be sampled every 2,000 tons of waste 

placement and tested for potential toxic or acid forming material. Should acidity or toxicity problems 

be identified during operations or reclamation, remedial action will be taken in coordination with the 

Utah DOGM. Testing has not identified acid- or toxin-generating material to date. 

2.2.9 Mine Personnel 

The mine currently directly employs approximately 320 people plus indirectly 1,162 people total 

(Bacon & Kojima, 2011). 

2.2.10 Rail Transport 

The majority of coal is conveyed to the unit train load-out then shipped via rail. The Denver and Rio 

Grande Western Railroad Company designed the rail haulage system. The load-out facility is 

capable of loading a 12,000-ton unit train in less than 4 hours. Trains generally have anywhere from 

40 to 107 cars each. The cars hold 90 to 116 tons of coal. Depending on contracts, the needs of 

their customers, coal quality, and the needs of Bowie Resource Holdings, the number of trains 

leaving the mine varies from 2 to 10 per week (Galecki, 2017). 

2.2.11 Reclamation 

The Reclamation Plan is described in detail in Section 4.1 through Section 4.25 of the Mine and 

Reclamation Plan and summarized here. 

Eventual reclamation of the mine site will satisfy the standards current at the time of reclamation 

and will be conducted using the most applicable current technology. The mine site will be returned 

to a wildlife/grazing habitat. It is not intended that all of the disturbed areas will be returned to their 

original contours or configurations. Steep slopes will be stabilized and revegetated where returning 

them to their original condition is not practical as it could create additional disturbance. Stream 

diversions, other than those in the portal area, will be left in their present channels. 

Closure of large diameter openings will prevent mine drainage from entering surface water. They 

will be sealed using backfilling with other non-combustible material. Mine portals will be broken up 

and used as backfill at reclamation. Fans and motors will be salvaged. 

All surface structures will be removed and salvaged when possible. Silos will be demolished and 

used as backfill material or will be hauled away. The overland conveyor will be completely removed 

at reclamation. Steel, exterior siding and conveyor equipment will be salvaged. Disturbed areas will 

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be scarified and a minimum of 6 inches of topsoil will be placed. Regrading and revegetation of the 

conveyor route will be performed. Machinery will be removed and concrete stack tube and reclaim 

tunnel will be demolished and used as backfill in the portal entrances. The foundation for the stack 

tube and some of the reclaimed tunnel will be left in place where cover will avoid interference with 

final reclamation requirements. 

Final contours on rock disposal sites will remain as constructed. Part of the disturbed area will be 

leveled off and reclaimed to native rangeland as requested by the landowner. The access road to 

the rock disposal site will remain except the cattle guard will be removed. 

Vent shafts and emergency escape shaft will be sealed and backfilled with an engineered fill. The 

shafts will be backfilled above the pad surface with excess fill to allow for settling. The slope will be 

sealed with solid, substantial, incombustible materials. Slopes will be re-contoured and reseeded. 

Solid waste generated by the abandonment will be collected and removed. Concrete footers will be 

fractured to a minimum of 2 feet below the surface. Foundations will be broken up and removed, 

and used for backfill. 

At mine closure, benches will be ripped, topsoiled, and revegetated. The cut slopes will be reduced 

to a more gradual grade and will be topsoiled and revegetated. This will return the mine site to the 

desired wildlife and grazing (rangeland) habitat. 

No impoundments, sediment ponds, or treatment facilities will remain. Diversions and culverts 

which may remain will be renovated to the approved design specification prior to abandonment. 

Water transmission lines buried in the highway right-of-way will remain in place. Ponds will be 

drained; the sediment will be tested for toxicity and removed for disposal as appropriate, allowing 

the pond to dry out. When the soil is dry, the railroad load-out pond will be backfilled. The portal 

pond will be configured as part of stream reclamation. The landowner has requested the Scofield 

Waste Disposal Site sediment pond be retained. 

All highwalls and cut slopes will be reclaimed using geotechnically stable fill slopes with surfaces 

that have been sufficiently roughened with deep gouging. The bench slopes will be graded back to 

the approximate original contour at a two horizontal to one vertical slope or shallower upon 

abandonment with a bulldozer. A geotechnical analysis will be made of the slope at the time of 

reclamation and design adjustment made as necessary to insure slope stability. 

The mine support roads will be reclaimed in the permit area. Culverts and blacktop surfacing 

material will be removed. Reclamation would then include re-contouring, ripping, adding cross 

drains, water bars, topsoil, and seed. 

Vegetation will be established to prevent erosion, to optimize the edge effect and to provide cover. 

Perennial woody species will be emphasized along with those of proven nutritional value and ability 

to support wildlife. All areas to be reseeded will be mulched. Various mulches will be used including 

straw, wood fibers, and excelsior mats. 

Fencing, irrigation, and weed control will be used only as needed, according to operation testing 

results. 

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Chapter 2	 April 2017 Environmental Assessment 

2.2.12 Life of Operations 

The currently approved mining is anticipated to be complete in 2018 from the existing leases. 

2.2.13 Project Design Features 

2.2.13.1 Measures for the Mine and Reclamation Plan 

The Mine and Reclamation Plan was initially approved in 1981 by Utah DOGM and has been 

updated since. It has requirements and commitments to protect the environment and minimize 

impacts. Some of them include: 

Subsidence Impact Prevention Measures 

•	 Subsidence is monitored. 

•	 Where subsidence could damage surface resources, non-subsidence room and pillar first 

mining methods will be used.
 

•	 A natural gas pipeline will be protected from subsidence from coal mining. Wherever the 

pipeline and creek buffer zones coincide, creek buffer zone requirements will take 

precedence.
 

•	 No mining will be conducted beneath Electric Lake. 

•	 Subsidence damage of any surface structures despite the planned subsidence prevention 

measures will be repaired.
 

•	 If it is determined that subsidence causes surface damage or a loss of flow in a perennial 

stream, the best technology currently available to mitigate the damage will be employed. 

These may include backfilling with surrounding native material, incorporating bentonite or 

other water-retaining native material into the backfill, or possibly temporarily bypassing/piping 

flow through impacted areas until mitigation is achieved. 

Long-Term Topsoil Stockpile Protection 

•	 A stable surface is provided in an area outside the influence of active operation. 

•	 As a stockpile was completed, it was left in a rough condition to minimize erosion. 

•	 A diversion ditch was dug around these piles to divert runoff from entering the stockpiled area. 

•	 Storage piles were vegetated with quick-growing, soil-stabilizing plants. Revegetation involved 

the immediate seeding of stockpiled topsoil. 

•	 Signs are posted to protect the stockpiles from accidental use as fill or from other inadvertent 

material contamination. 

•	 The establishment of noxious plant species is prevented. 

•	 The slope of stockpiles does not exceed 2h:1v. 

Protection of Hydrological Balance 

• Canyon Fuel Company, LLC inspects and maintains diversion channels throughout the site. 

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•	 All mine site operations will be conducted in such a way as to minimize potential impacts to 

surface and subsurface water quality. 

•	 Water originating in or flowing through disturbed areas is collected by a drainage control 

system and suspended materials allowed to settle in sediment control ponds before being 

discharged into the natural drainage system. 

•	 Stream buffer zones are designated with signs. 

•	 Grease and oil in underground water is removed before the water is pumped out of the mine 

and discharged. 

•	 Groundwater and surface-water will be monitored to verify that mining-related impacts do not 

occur or to identify the magnitude and character of potential impacts. Samples are collected 

quarterly. The water monitoring program collects quantity and quality data at springs, streams, 

and well monitoring sites. Monitoring data is submitted to the Utah DOGM quarterly. 

Fish and Wildlife 

•	 Canyon Fuel Company, LLC will minimize disturbances and adverse impacts on fish, wildlife, 

and related environmental values identified in baseline studies. 

•	 Posted speed limits will be maintained on the Eccles Canyon road to minimize animal-vehicle 

collisions. Warning signs indicating animal crossings are installed. 

•	 Power transmission lines were designed and constructed to comply with the guidelines set 

forth in “Environmental Criteria for Electric Transmission System”. Power distribution was 

designed and constructed in accordance with the REA Bulletin 61-10 “Power line Contacts by 

Eagles and Other Large Birds”. 

•	 If necessary, a wire fence will be erected and maintained around the perimeter of the portal 

area to protect grazing stock and wildlife. Other vent shafts and structures will be similarly 

fenced, covered, or otherwise protected if required. 

•	 Wildlife will be excluded from ponds if necessary. 

•	 No persistent pesticides will be used unless approved by the regulatory authority as part of a 

reclamation management plan. 

•	 Raptor data will be updated annually in the late spring/early summer. 

2.2.13.2 Air Quality 

Skyline Mine’s Approval Order DAQE-AN0092007-03 (UDAQ, 2015b), includes requirements to 

prepare and operate in accordance with a submitted fugitive coal dust emissions control plan. The 

requirements are supported by the Utah Administrative Code. The requirements listed in Section 

II.B.1 (Requirements and Limitations) of Approval Order DAQE-AN0092007-03 are: 

•	 Coal shall be transferred only by enclosed conveyor. Inter-site truck haulage site may be used 

only during conveyor emergency periods. The direct offsite shipments by truck of coal and 

waste material combined total shall not exceed 8,000,000 tons per rolling 12-month period. 

The direct offsite shipments by truck of coal from each individual load-out shall not exceed 

4,500,000 tons per rolling 12-month period [R307-401-8]. 

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Chapter 2	 April 2017 Environmental Assessment 

•	 Compliance with the limitations shall be determined on a rolling 12-month total. The 

owner/operator shall calculate a new 12-month total by the twentieth day of each month using 

data from the previous 12 months. Records shall be kept for all periods when the plant is in 

operation. Records, including rolling 12-month totals, shall be made available to the Director 

or Director’s representative upon request and the records shall include the 2-year period prior 

to the date of the request. The records of shipments shall be determined by supervisor 

monitoring and maintenance of an operations log. The records shall be kept on a monthly 

basis [R307-401-8]. 

•	 Conveyor transfer points shall contain flaps on entry and discharge ends [R307-401-8]. 

•	 The upper elevation silo (8,000-ton capacity) shall be controlled by two baghouses, Day 

Model 72RF10 or equivalent. The baghouses shall be operated when coal being transported 

is dry (less than 4 percent (%) moisture) or whenever opacity readings exceed 20 percent 

[R307-401-8]. 

•	 Two lower elevation silos, rated at 15,000-ton capacity each, shall be controlled by two 

baghouses, Dynaclone Model 6A or equivalent. The baghouses shall be operated when the 

coal being transported is dry (less than 4 percent moisture) or whenever opacity readings 

exceed 20 percent [R307-401-8]. 

•	 The Headhouse rail load-out shall be controlled by one baghouse, Dynaclone Model 7A or 

equivalent. Storage at train load-out facilities shall be enclosed with venting to fabric filter 

baghouses. The baghouse shall be operated when the coal being transported is dry (less than 

4 percent moisture) or whenever opacity readings exceed 20 percent [R307-401-8]. 

•	 Visible emissions from the following emissions points shall not exceed the following values: 

A.	 All conveyor transfer points – 20 percent opacity 

B. Conveyor drop points – 20 percent opacity 

C. All other points – 20 percent opacity 

Opacity observations of emissions from stationary sources shall be conducted in 

accordance with 40 CFR 60, Appendix A, Method 9 [R307-401-8]. 

•	 Visible emissions from haul road traffic and mobile equipment shall not exceed 20 percent 

opacity. Visible emissions determinations for traffic sources shall use procedures similar to 

Method 9, but the requirement for observations to be made at 15-second intervals over a 6­

minute period shall not apply. Six points, distributed along the length of the haul road, shall be 

chosen by the Director or Director’s representative. An opacity reading shall be made at each 

point when a vehicle passes the selected point. Opacity readings shall be made no less than 

one half vehicle length behind the vehicle and no less than one half the height of the vehicle. 

The accumulated 6 readings shall be averaged for the compliance value [R304-401-8]. 

•	 The following production limits shall not be exceeded: 

A.	 600,000 tons maximum capacity in the upper elevation stockpile 

B. 8,000,000 tons maximum throughput for the upper elevation stockpile and lower 

elevation stockpile combined 

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C. 300 tons maximum capacity in the emergency storage pile 

D. 500,000 tons maximum capacity in the lower elevation stockpile 

E. 8,000,000 tons coal produced per rolling 12-month period [R307-401-8] 

o	 Compliance with the limitations shall be determined on a rolling 12-month total. The 

owner/operator shall calculate a new 12-month total by the twentieth day of each month 

using data from the previous 12 months. Records of production shall be kept for all periods 

when the plant is in operation. Records of production including rolling 12-month totals, 

shall be made available to the Director or Director’s representative upon request and the 

records shall include the 2-year period prior to the date of the request. The records of 

production shall be determined by examination of company coal sales records and 

examination of company throughput records for the points in question. The records shall 

be kept on a monthly basis [R307-401-8]. 

•	 All unpaved roads and other unpaved operational areas that are used by mobile equipment 

shall be water sprayed and/or chemically treated to control fugitive dust. The application of 

water or chemical treatment shall be used. Treatment shall be of sufficient frequency and 

quantity to maintain the surface material in a damp/moist condition. Records of water 

treatment shall be kept for all periods when the plant is in operation. The records shall include 

the following items. 

A.	 Date of treatment 

B. Number of treatments made, dilution ratio, and quantity 

C. Rainfall received, if any, and approximate amount 

D. Time of day treatments were made [R307-401-8] 

•	 The speed of vehicles on the haul roads shall not exceed 25 miles per hour [R307-401-8]. 

•	 The Eccles Canyon road (State Highway U-96) is paved, and the owner/operator shall clean 

all coal spills on the road immediately. There shall be no “track out” of fugitive dust from 

unpaved roads onto the paved haul roads [R307-401-8]. 

•	 The moisture content of the material shall be maintained at a value of no less than 4 percent 

of water by weight. The moisture content shall be tested, if directed by the Director, using the 

appropriate ASTM method [R307-401-8]. 

•	 The storage piles shall be watered to minimize generation of fugitive dusts as dry conditions 

warrant during recovery operations only or as determined necessary by the Director [R307­

401-8]. 

•	 The coal fines content of the stored coal shall not exceed 5.1 percent by weight, and that of 

the haul roads and pile areas shall not exceed 10 percent by weight. The coal fines content 

shall be determined, if directed by the Director, using appropriate ASTM method. The coal 

fines content is defined as all material passing a No. 200 US Standard Sieve [R307-401-8]. 

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•	 The sulfur content of any fuel oil burned shall not exceed 15 parts per million by weight as 

determined by ASTM Method D-4294-89 or approved equivalent. The sulfur content shall be 

tested, if directed by the Director [R307-401-8]. 

2.2.13.3 Utah Pollutant Discharge Eliminating Permit UT0023540 

The Utah Department of Environmental Quality (DEQ), Division of Water Quality issued a discharge 

permit (UT0023450) to Skyline Mine, effective May 1, 2015 and valid through midnight on April 30, 

2020 authorizing discharges. 

Skyline Mine is permitted to discharge mine water at outfall locations. The permit establishes limits 

on the discharge from these points into the Eccles Creek, UP Canyon Creek, and Winter Quarters 

Canyon Creek (all tributaries to the Price and Colorado River systems (UDEQ, 2015). The permit 

includes limits on discharge quality, monitoring requirements, sampling methods, testing methods, 

and reporting requirements. 

The permit also specifies the requirements of a storm water pollution prevention plan, which 

includes Measurements and Controls for minimizing water pollution: 

•	 Good Housekeeping – Good housekeeping requires the maintenance of areas that may 

contribute pollutants to storm water discharges in a clean, orderly manner. These are 

practices that would minimize the generation of pollutants at the source or before it would be 

necessary to employ sediment ponds or other control measures at the discharge outlets. 

Where applicable, such measures or other equivalent measures would include the following: 

sweepers and covered storage to minimize dust generation and storm runoff; conservation of 

vegetation where possible to minimize erosion; watering of haul roads to minimize dust 

generation; collection, removal, and proper disposal of waste oils and other fluids resulting 

from vehicle and equipment maintenance; or other equivalent measures. 

•	 Preventative Maintenance – A preventative maintenance program shall involve timely 

inspection and maintenance of storm water management devices as well as inspecting and 

testing facility equipment and systems to uncover conditions that could cause breakdowns or 

failures resulting in discharges of pollutants to surface waters, and ensuring appropriate 

maintenance of such equipment and systems. Where applicable, such measures would 

include the following; removal and proper disposal of settled solids, in catch basins to allow 

sufficient retention capacity; periodic replacement of siltation control measures subject to 

deterioration such as straw bales; inspections of storage tanks and pressure lines for fuels, 

lubricants, hydraulic fluid or slurry to prevent leaks due to deterioration of faulty connections; 

or other equivalent measures. 

•	 Spill Prevention and Response Procedures – Areas where potential spills that can contribute 

pollutants to storm water discharges can occur, and their accompanying drainage points shall 

be identified clearly in the storm water pollution prevention plan. Where appropriate, 

specifying material handling procedures, storage requirements, and use of equipment such as 

diversion valves in the plan should be considered. Procedures for cleaning up spills shall be 

identified in the plan and made available to the appropriate personnel. The necessary 

equipment to implement a clean-up shall be available to personnel. 

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•	 Inspections – In addition to or as part of the comprehensive site evaluation required under 

paragraph 3a.(4) of this section, qualified facilities personnel shall be identified to inspect 

designated areas of the facility at appropriate intervals specified in the plan. 

•	 Employee Training – Employee training programs shall inform personnel responsible for 

implementing activities identified in the storm water pollution prevention plan or otherwise 

responsible for storm water management at all levels of responsibility of the components and 

goals of the storm water pollution prevention plan. Training should address topics such as spill 

response, good housekeeping, and material management practices. The pollution prevention 

plan shall identify periodic dates for such training. 

•	 Record Keeping and Internal Reporting Procedures – A description of incidents (such as 

spills, or other discharges) along with other information describing the quality and quantity of 

storm water discharges shall be included in the plan required under this part. Inspections and 

maintenance activities shall be documented and records of such activities shall be 

incorporated into the plan. 

•	 Non-storm Water Discharges: 

o	 Certification – The plan shall include a certification that the discharge has been tested or 

evaluated for the presence of non-storm water discharges such as drainage from 

underground portions of inactive mines or floor drains from maintenance or coal handling 

buildings. The certification shall include the identification of potential significant sources of 

non-storm water discharges at the site, a description of the results of any test and/or 

evaluation of potential significant sources of non-storm water discharges at the site, a 

description of the results of any test and/or evaluation, a description of the evaluation 

criteria or testing method used, the data of any testing and/or evaluation, and the onsite 

drainage points that were directly observed during the test. Certifications shall be signed in 

accordance with Part IV.G.4 of this permit. 

o	 Exceptions – Except for flows from the firefighting activities, authorized sources of nonstorm water listed in Part I.E.2.a that are combined with storm water discharges 

associated with industrial activities must be identified in the plan. The plan shall identify 

and ensure the implementation of appropriate pollution prevention measures for the nonstorm water component(s) of the discharge. 

o	 Failure to Certify – If Skyline Mine is unable to provide the certification required (testing or 

other evaluation for non-storm water discharges), the Director must be notified within 180 

days after the effective date of this permit. If the failure to certify is caused by the inability 

to perform adequate tests or evaluations, such notification shall describe: the procedure 

for any test conducted for the presence of non-storm water discharges; the results of such 

test or other relevant observations; potential sources of non-storm water to the storm 

discharge lines; and why adequate tests for such storm discharge lines were not feasible. 

Non-storm water discharges to waters of the state that are not authorized by a UPDES are 

unlawful, and must be terminated. 

•	 Sediment and Erosion Control – The plan shall identify areas that, due to topography, 

activities, or other factors, have a high potential for significant soil erosion, and identify 

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structural, vegetative, and/or stabilization measures to be used to limit erosion and reduce 

sediment concentrations in storm water discharges. As indicated in paragraph I.E.3 above, 

SMCRA requirement regarding sediment and erosion control measures are primary 

requirements of the pollution prevention plan for mining-related areas subject to SMCRA 

authority. The following sediment and erosion control measures or other equivalent measures, 

should be included in the plan where reasonable and appropriate for all areas subject to storm 

water runoff: 

o	 Stabilization Measures – Interim and permanent stabilization measures to minimize 

erosion and lessen amount of structural sediment control measures needed, including: 

mature vegetation preservation; temporary seeding; permanent seeding and planting; 

temporary mulching, matting, and netting; sod stabilization; vegetative buffer strips; 

temporary chemical mulch, soil binders, and soil palliatives; nonacidic road surfacing 

material; and protective trees. 

o	 Structural Measures – Structural measures to lessen erosion and reduce sediment 

discharges, including; silt fences; earth dikes; straw dikes’ gradient terraces; drainage 

swales; sediment traps; pipe slope drains; porous rock check dams; sedimentation ponds; 

riprap channel protection; capping of contaminated sources; and physical/chemical 

treatment of storm water. 

•	 Management of Flow – The plan shall contain a narrative consideration of the appropriateness 

of traditional storm water management practices (other than those as sediment and erosion 

control measures listed above) used to manage storm water runoff in a manner that reduces 

pollutants in storm water runoff from the site. The plan shall provide that the measures, which 

the permittee determines to be reasonable and appropriate, shall be implemented and 

maintained. Appropriate measures may include: discharge diversions; drainage/storm water 

conveyances; runoff dispersion; sediment control and collection; vegetation/soil stabilization; 

capping of contaminated sources; treatment; or other equivalent measures. 

2.3 Proposed Action Alternative 

The Proposed Action is to approve the mining of the coal within Flat Canyon Federal Coal Lease 

Tract UTU-77114 and make a recommendation to the ASLM to approve the MPDD. The MPDD 

would authorize Canyon Fuel Company, LLC to expand their underground Skyline Mine operations 

west from the current mining operation. Table 3 summarizes the activities. No new surface facilities 

or disturbances are proposed. Access to the coal would be from the existing underground mine. 

The Proposed Action (Figure 3) would authorize Canyon Fuel Company, LLC to expand their 

underground Skyline Mine operations west from the current mining operations into approximately 

2,692 acres of federal coal reserves and to access another 1,100 acres of private coal. Typical 

depths of cover from the minable coal seam to the surface range from 900 feet to 2,300 feet. The 

Proposed Action would produce a probable maximum of 47 million tons of federal and private coal 

and extend the life of the Skyline Mine by approximately 9 to 12 years. Utah DOGM has not set a 

maximum number of tons Skyline Mine can produce annually; however, the current air quality 

permit, DAQE-AN0092007-03 (DEQ, UDAQ, 2015), at Skyline Mine limits the mine to a maximum 

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of 8 million tons per year. Over the last 6 years, Skyline Mine produced 1.9 to 4.2 million tons of 

coal a year (Table 2). In the future, Skyline Mine anticipates mining 3 to 4.5 million tons of coal per 

year. 

Table 3 - Summary of the Proposed Action 

Condition Evaluated Proposed Action 

Federal Coal Probable maximum of 42 

Federal Coal 2,692 coal acres 

Federal Surface 2,692 acres 

Federal Disturbance Area 0 acres 

Private Coal 5 million tons 

Private Coal 1,100 coal acres 

Private Surface 0 acres 

Private Disturbance Area 0 acres 

Remaining full production Approximately 9 to 12 years 

Mine operations would not change as a consequence of the modification and operations would 

continue to be conducted as described in Section 2.2 - Existing Operations. 

2.3.1 Topsoil 

No new topsoil will be removed and no waste rock piles are planned to facilitate the Flat Canyon 

Federal Coal Lease Tract UTU-77114 mining and there would be no impact from acid-or toxicforming materials. 

2.3.2 Waste Rock Storage 

Waste rock would be managed as described under the Existing Operations. 

2.3.3 Access and Haul Roads 

There would be no change in the access or haul roads as described under the Existing Operations. 

2.3.4 Power Lines 

There would be no change in the power supply or requirements as described under the Existing 

Operations. 

2.3.5 Mine Facilities 

There would be no change in the mine facilities as described under the Existing Operations. 

2.3.6 Ponds, Impoundments, Diversion 

There would be no change in the settling ponds, impoundments, or diversion described under the 

Existing Operations. 

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Figure 3 - Proposed Action 

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2.3.7 Water Source 

There would be no change in the water source described under the Existing Operations. 

2.3.8 Hazardous Material 

There would be no change in the handling or production of hazardous materials described under 

the Existing Operations. 

2.3.9 Mine Personnel 

There would be no change in the mine personnel described under the Existing Operations. 

2.3.10 Rail Transport 

There would be no change in the rail transport described under the Existing Operations. 

2.3.11 Reclamation 

There would be no change in the reclamation requirements described under the Existing 

Operations, except that reclamation would be initiated at the end of the future mining in 9 to 12 

years. 

2.3.12 Life of Operations 

The Proposed Action would extend the mine life by 9 to 12 years (2027 to 2030), depending on the 

rate of production between 3 and 4.5 million tons per year. 

2.3.13 Project Design Features 

Design Features listed in Section 2.2.14 and 2.3.7 of the Mine and Reclamation Plan and the Air 

Permit would apply, along with the additional measures attached to the Flat Canyon Federal Coal 

Lease Tract UTU-77114 listed below. 

In their letter concurring with the terms of the federal mining plan approval (US Forest Service, 

2017), the Manti-La Sal National Forest included a condition so that the project would conform to 

the 2015 Greater Sage-grouse Record of Decision for Idaho and Southwest Montana, Nevada, and 

Utah amendment to the Manti-La Sal Forest Plan (US Forest Service, 2015). 

Groundwater and Surface Water Monitoring 

The complete groundwater and surface water monitoring program for the Skyline Mine is outlined in 

Section 2.3.7, in Table 2.3.7-1, and on the Map 2.3.6-1 within the Mine and Reclamation Plan. The 

water monitoring program developed for the Flat Canyon lease is based upon recommendations 

within the Probable Hydrologic Consequences report (Petersen Hydrologic, LLC, 2014a) and 

analysis of all baseline hydrologic and geologic information. The monitoring sites within and directly 

adjacent to the Flat Canyon lease are as follows (see Figure 3): 

• At 12 spring monitoring locations, Canyon Fuel Company, LLC monitors flow and water quality 

at SW32-276/277, SW33-268, SW4-429, SW5-590, SW21-104, SW28-110/111, SW4-169/174 

3-290, and 8-253. 

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• Water level data at 6 piezometers along Boulger Creek - P17-4-1 (east and west), P17-33-1 

(east and west), P17-34-1 (north and south) adjacent to stream monitoring sites CS-30, CS33, and CS-34. 

• “Paired” springs have been added to the monitoring program. These include SW28-110/110, 

SW32-277/276, and SW4-173/169. 

• Water levels in the deeper inactive-zone of the Star Point Sandstone in wells 15-21-2, 99-4-1, 

and JC-2 and water quality in the Star Point Formation from JC-1. 

• Surface water quality and quantity monitoring at sites CS-27, CS-28, CS-29, CS-30, and CS31, and only water quality at CS-32, CS-33, CS-34, and CS-35. 

2.3.13.1 Stipulations Attached to Flat Canyon Federal Coal Lease UTU-77114 

The Flat Canyon Federal Coal Lease Tract UTU-77114 contains special stipulations. The following 

stipulations are attached to the executed coal lease (BLM, 2015a). 

1.	 In accordance with Section 523(b) of the “Surface Mining Control and Reclamation Act of 

1977,” surface mining and reclamation operations conducted on this lease are to conform 

with the requirements of this act and are subject to compliance with Office of Surface Mining 

regulations, or as applicable the Utah program approved under the cooperative agreement in 

accordance with Section 523(c). The US Government does not warrant that the entire tract 

will be susceptible to mining. 

2.	 Before undertaking activities that may disturb the surface of previously undisturbed leased 

lands, the Lessee may be required to conduct a cultural resource inventory and a 

paleontological appraisal of the areas to be disturbed. These studies shall be conducted by 

qualified professional cultural resource specialists or qualified paleontologists, as appropriate, 

and a report prepared itemizing the findings. A plan will then be submitted making 

recommendations for the protection of, or measures to be taken to mitigate impacts for 

identified cultural or paleontological resources. 

If cultural resources or paleontological remains (fossils) of significant scientific interest are 

discovered during operations under this lease, the Lessee prior to disturbance shall, 

immediately bring them to the attention of the appropriate authorities. Paleontological 

remains of significant scientific interest do not include leaves, ferns, or dinosaur tracks 

commonly encountered during underground mining operations. 

The cost of conducting the inventory, preparing reports, and carrying out mitigating measures 

shall be borne by the Lessee. 

3.	 If there is reason to believe that threatened or endangered species of plants or animals, or 

migratory bird species of high federal interest occur in the area, the Lessee shall be required 

to conduct an intensive field inventory of the area to be disturbed and/or impacted. The 

inventory shall be conducted by a qualified specialist and a report of findings will be 

prepared. A plan will be prepared making recommendations for the protection of these 

species or action necessary to mitigate the disturbance. 

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The cost of conducting the inventory, preparing reports, and carrying out mitigating measures 

shall be borne by the Lessee. 

4.	 The Lessee shall be required to perform a study to secure adequate baseline data to quantify 

the existing surface resources on and adjacent to the lease area. Existing data may be used 

if such data are adequate for the intended purposes. The study shall be adequate to locate, 

quantify, and demonstrate the interrelationship of the geology, topography, surface and 

ground water hydrology, vegetation, and wildlife. Baseline data will be established so that 

future programs of observation can be incorporated at regular intervals for comparison. 

5.	 Power lines used in conjunction with the mining of coal from this lease shall be constructed 

so as to provide adequate protection for raptors and other large birds. When feasible, power 

lines will be located at least 100 yards from public roads. 

6.	 The limited area available for mine facilities at the coal outcrop, steep topography, adverse 

winter weather, and physical limitations on the size and design of the access road, are 

factors which will determine the ultimate size of the surface area utilized for the mine. A site 

specific environmental analysis will be prepared for each new mine site development and for 

major modifications to existing developments to examine alternatives and mitigate conflicts. 

7.	 Consideration will be given to site selection to reduce adverse visual impacts. Where 

alternative sites are available, and each alternative is technically feasible, the alternatives 

involving the least damage to the scenery and other resources shall be selected. Permanent 

structures and facilities will be designed, and screening techniques employed, to reduce 

visual impacts, and where possible achieve a final landscape compatible with the natural 

surroundings. The creation of unusual, objectionable, or unnatural land forms and vegetative 

landscape features will be avoided. 

8.	 The Lessee shall be required to establish a monitoring system to locate, measure, and 

quantify the progressive and final effects of underground mining activities on the topographic 

surface, underground and surface hydrology, and vegetation. The monitoring system shall 

utilize techniques which will provide a continuing record of change over time and an 

analytical method for location and measurement of a number of points over the lease area. 

The monitoring shall incorporate and be an extension of the baseline data. 

9.	 The Lessee shall provide for the suppression and control of fugitive dust on haul roads and at 

coal handling and storage facilities. On Forest Development Roads (FDR), Lessees may 

perform their share of road maintenance by a commensurate share agreement if a significant 

degree of traffic is generated that is not related to their activities. 

10. Except at locations specifically approved by the Authorized Officer, with the concurrence of 

the Forest Service, underground mining operations shall be conducted in such a manner so 

as to prevent surface subsidence that would: (1) cause the creation of hazardous conditions 

such as potential escarpment failure and landslides, (2) cause damage to existing surface 

structures, and (3) damage or alter the flow of perennial streams. The Lessee shall provide 

specific measures for the protection of escarpments, and determine corrective measures to 

assure that hazardous conditions are not created. 

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Limited subsidence zones consisting of perennial streams in the lease, Boulger 

Reservoir/Dam, SR-264, and Flat Canyon Campground are specifically approved for 

subsidence resulting from a single-seam of full-extraction mining. The limited-subsidence 

zones, where subsidence from a second overlapping seam of full-extraction mining is not 

approved, will be determined based on the typical angle-of-draw for past operations in the 

Skyline Mine Permit Area (23 degrees). “Angle-of-draw” is defined in the FEIS (pages 4-7). 

The angle-of-draw will be applied to perennial stream buffer zones that include the natural 

floodplain and alluvium in perennial drainages, bounded by the first major slope break in the 

associated canyons. For structures, it will be applied to an area delineated by a 50-foot slope 

break in the associated canyons. For structures, it will be applied to an area delineated by a 

50-foot radius or distance from the major structures that could sustain damage. 

The Authorized Officer can approve full extraction of multiple seams in limited subsidence 

zones, if the Lessee can provide information, based on actual subsidence data from the tract, 

that impacts can be tolerated or mitigated. The Forest Service will have to consent to the 

decision and issue a new record of decision. 

11. In order to avoid surface disturbance on steep canyon slopes and to preclude the need for 

surface access, all surface breakouts for ventilation tunnels shall be constructed from inside 

the mine, except at specifically approved locations. 

12. If removal of timber is required for clearing of construction sites, etc., such timber shall be 

removed in accordance with the regulations of the surface management agency. 

13. The coal contained within, and authorized for mining under this lease, shall be extracted only 

by underground mining methods. 

14. Existing Forest Service owned or permitted surface improvements will need to be protected, 

restored, or replaced to provide for the continuance of current land uses. 

15. In order to protect big game wintering areas, elk calving and deer fawning areas, sagegrouse strutting areas, and other critical wildlife habitat and/or activities specific to surface 

uses outside the mine development area may be curtailed during specific periods of the year. 

16. Support facilities, structures, equipment, and similar developments will be removed from the 

lease area within 2 years after the final termination of use of such facilities. This provision 

shall apply unless the requirement of Section 10 of the lease form is applicable. Disturbed 

areas and those areas previously occupied by such facilities will be stabilized and 

rehabilitated, drainages, reestablished, and the areas returned to an acceptable post mining 

land use. 

17. The Lessee at the conclusion of the mining operation, or at other times as surface 

disturbance related to mining may occur, will replace all damaged, disturbed, or displaced 

corner monuments (section corners, quarter corners, etc.) their accessories and appendages 

(witness trees, bearing trees, etc.), or restore them to their original condition and location, or 

at other locations that meet the requirements of the rectangular surveying system. This work 

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shall be conducted at the expense of the Lessee, by BLM, to the standards and guidelines 

found in the Manual of Surveying Instructions, DOI. 

18. The Lessee, at his expense, will be responsible to replace any surface and/or developed 

ground water sources identified for protection, that may be lost or adversely affected by 

mining operations, with water from an alternate source in sufficient quantity and quality to 

maintain existing riparian habitat, fishery habitat, livestock and wildlife use, or other land uses 

(authorized by 36 CFR 251). 

19. The Licensee/Permittee/Lessee must comply with all the rules and regulations of the 

Secretary of Agriculture set forth at Title 36, Chapter 11, of the CFRs governing the use and 

management of the National Forest System when not inconsistent with the rights granted by 

the Secretary of the Interior in the license/permit/lease. The Secretary of Agriculture’s rules 

and regulations must be complied with for (1) all use and occupancy of the National Forest 

System prior to approval of a permit/operation plan by the Secretary of Interior, (2) uses of all 

existing improvements, such as FDR, within and outside the area licensed, permitted or 

leased by the Secretary of the Interior, and (3) use and occupancy of the National Forest 

System not authorized by a permit/operation plan approved by the Secretary of the Interior. 

All matters related to this stipulation are to be addressed to: 

Forest Supervisor
 

Manti-La Sal National Forest
 

599 West Price River Drive
 

Price, Utah 84501
 

Telephone No.: 435-637-2817
 

The Forest Supervisor is the authorized representative of the Secretary of Agriculture. 

20. Notwithstanding the approval of a resource recovery and protection plan by the BLM, lessor 

reserves the right to seek damages against the operator/Lessee in the event (1) the 

operator/Lessee fails to achieve maximum economic recovery [as defined at 43 CFR 

§3480.0-5(21)] of the recoverable coal reserves. Damages shall be measured on the bases 

of the royalty that would have been payable on the wasted or unrecovered coal. 

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

by the operator/Lessee of that plan. In the event a coal bed or portion thereof is not to be 

mined or is rendered un-minable by the operation, the operator shall submit appropriate 

justification to obtain approval by the Authorized Officer to leave such reserves unmined. 

Upon approval by the Authorized Officer, such coal beds or portions thereof shall not be 

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

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

authorized by statute and regulation. 

In the event the Authorized Officer determines that the R2P2 modification will not attain 

Maximum Economic Recovery (MER) resulting from changed conditions, the Authorized 

Officer will give proper notice to the operator/Lessee as required under applicable 

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regulations. The Authorized Officer will order a new R2P2 modification if necessary, 

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

or judicial ruling upholding such ordered modification, any reserves left unmined (wasted) 

under that plan will be subject to damages as described in the first paragraph under this 

section. 

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

unmined recoverable coal reserves shall become due and payable upon determination by the 

Authorized Officer that the coal reserves have been rendered un-minable or at such time that 

the Lessee has demonstrated an unwillingness to extract the coal. 

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

the ONRR demand for such royalties, or by issuing a notice of non-compliance. A decision or 

notice of non-compliance issued by the lessor that payment is due under this stipulation is 

appealable as allowed by law. 

21. WASTE CERTIFICATION: The Lessee shall provide upon abandonment and/or sealing off a 

mined area and prior to lease termination/relinquishment, certification to the lessor that, 

based upon a complete search of all the operator’s records for the mine and upon their 

knowledge of past operations, there has been no hazardous substances per (40 CFR 302.4) 

or used oil as per Utah State Management Rule R-315-15, deposited within the lease, either 

on the surface or underground, or that all remedial action necessary has been taken to 

protect human health and the environment with respect to any such substances remaining on 

the property. The back-up documentation to be provided shall be described by the lessor 

prior to the first certification and shall include all documentation applicable to the Emergency 

Planning and Community Right-to-know Act (Public Law 99-499), Title III of the Superfund 

Amendments and Reauthorization Act of 1986 or equivalent. 

22. ABANDONMENT OF EQUIPMENT: The Lessee/operator is responsible for compliance with 

reporting regarding toxic and hazardous material and substances under federal law and all 

associated amendments and regulations for the handling such materials on the land surface 

and in underground mine workings. 

The Lessee/operator mush remove mine equipment and materials not needed for continued 

operations, roof support and mine safety from underground workings prior to abandonment of 

mine sections. Exceptions can be approved by the Authorized Officer (BLM) in consultation 

with the surface management agency. Creation of a situation that would prevent removal of 

such material and by retreat or abandonment of mine sections without prior authorization 

would be considered noncompliance with lease terms and conditions and subject to 

appropriate penalties under the lease. 

23. UNDERGROUND INSPECTION: All safe and accessible areas shall be inspected prior to 

being sealed. The Lessee shall notify the Authorized Officer in writing 30 days prior to the 

sealing of any areas in the mine and state the reason for closure. Prior to seals being put into 

place, the Lessee shall inspect the area and document any equipment/machinery, hazardous 

substances, and used oil that is to be left underground. 

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The purpose of this inspection will be: (1) to provide documentation for compliance with 42 

United States Code (U.S.C.) 9620 Section 120(h) and State Management Rule R-315-15, 

and to assure that certification will be meaningful at the time of lease relinquishment, and (2) 

to document the inspection with a mine map showing location of equipment/machinery 

(model, type of fluid, amount remaining, batteries etc.) that is proposed to be left 

underground. In addition, these items will be photographed at the Lessee’s expense and 

shall be submitted to the Authorized Officer as part of the certification. The abandonment of 

any equipment/machinery shall be on a case by case basis and shall not be accomplished 

unless the Authorized Officer has granted a written approval. 

24. All shafts or portals will be filled after mining has ceased or abandoned and all designs will be 

approved by the Authorized Officer. 

25. Prior to development of the panels that would cause subsidence of the Boulger Reservoir, 

the Lessee shall submit a plan for approval of mining under the reservoir facilities to the 

Authorized Officer. This plan shall include, but not be limited to, type of mining, when and 

how the dam will be taken out of service while undermining and/or subjected to mininginduced acceleration of 0.1g and greater, and what mitigation measures will be taken to place 

the dam and reservoir back into full service. This plan shall be submitted to and be approved 

by the Authorized Officer of the BLM, with consent of the surface management agency, and 

any requirements by the regulatory authority. 

26. Prior to development of the panels that would cause subsidence of the Flat Canyon 

Campground, the Lessee shall submit a plan for approval to conduct mining under the 

campground. This plan shall include but not be limited to type of mining, when and how the 

Flat Canyon Campground will be taken out of service and what mitigation measures will be 

taken to place the Flat Canyon Campground back into full service. The plan shall be 

submitted to and be approved by the Authorized Officer of the BLM, with the consent of the 

surface management agency, in addition to any requirements required by the regulatory 

authority. 

27. The Lessee shall submit a plan for monitoring the gradient of the perennial streams within the 

lease and the associated effects to aquatic ecosystems and wetlands. The plan shall also 

include measures for mitigating detrimental effects discovered during monitoring. The plan 

shall be submitted to and be approved by the Authorized Officer of the BLM, with consent of 

the surface management agency in addition to any requirements by the regulatory authority, 

prior to mining. 

28. The Lessee shall immediately notify the Authorized Officer of any seismic events that trigger 

a Richter scale reading in excess of 3.0. 

2.4 No Action 

Under the No Action, the MPDD to mine the Flat Canyon Federal Coal Lease Tract UTU-77114 

would not be prepared by OSMRE and therefore ASLM approval would not occur. On February 10, 

2017, Utah DOGM approved the significant revision associated with the Proposed Action, without 

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Chapter 2	 April 2017 Environmental Assessment 

ASLM approval, Utah DOGM’s permit would not change, however mining would not occur in UTU77114. 

The federal coal reserves in the Flat Canyon Federal Coal Lease Tract UTU-77114 would not be 

recovered with this particular action. Mining would continue as described in Section 2.2 until 

available coal reserves are mined out in 2018 (Galecki, 2015b). Longwall panel development would 

cease within approximately one year and underground mining would cease completely within 

approximately two years. The state and private coal reserves to the south and west would not be 

accessible. While a portion of these state and private reserves might be reached by reorientation, 

the accessible coal would not be economically mineable. Coal resources would be economically 

isolated and sterilized from use for the public need and the mine would close prematurely. 

Reclamation would last two years after closure. Monitoring of the reclamation would continue for at 

least the 10-year bond period. 

Under the No Action, removal of coal, air quality impacts or any other effects associated with mining 

operations in the Flat Canyon Federal Coal Lease Tract UTU-77114 would not occur. 

2.4.1 Alternatives Considered but Eliminated from Detailed Analysis 

This section discusses alternatives that were considered but eliminated from detailed analysis. 

Reasons that an alternative might not be considered in detail, in accordance with the CEQ’s NEPA 

implementing regulations (40 CFR 1502.14), are: 

•	 Ineffective (does not respond to the purpose and need); 

•	 Technically or economically infeasible (consider whether implementation of the alternative is 

likely given past and current practice and technology); 

•	 Inconsistent with the basic policy objectives for the management of the area (such as, not in 

conformance with land use plans); 

•	 Remote or speculative; 

•	 Substantially similar in design to an alternative that is analyzed; or 

•	 Substantially similar in impacts to an alternative that is analyzed. 

Alternatives proposed during public outreach are described briefly below, along with the reasons 

they were eliminated from detailed analysis. 

2.4.1.1 Alternative Mining Levels 

Alternatives that would limit the amount of coal or acreage to be mined to lower levels than are 

currently proposed were suggested to reduce the impacts on air quality and climate change. 

These alternatives were not considered in detail because they would not meet the purpose and 

need (see Section 1.4) and would be inconsistent with the MLA requirement to maximize recovery 

by achieving MER of this energy resource (43 CFR § 3480.0-5 (21)). OSMRE’s purpose and need 

is to evaluate Canyon Fuel Company, LLC’s proposed mining plan modification submitted in 

accordance with the federal coal lease granted to Canyon Fuel Company, LLC. 

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Environmental Assessment	 April 2017 Proposed Action and Alternatives 

2.4.1.2 Low or No Pollutant Emitting Equipment 

This proposed alternative would require that equipment used for mining produce less or no 

emissions (natural gas-fired vehicles and machinery, and electric machinery powered by solar or 

other renewable energy sources), and establish equipment maintenance standards to minimize 

emissions to the maximum extent practicable. 

Mining at Skyline Mine has the potential to emit at the levels identified in Section 3.3 and Section 

4.3, which would not result in ambient quality concentrations exceeding the federal or state air 

quality standards. 

The Skyline Mine currently uses all electric production units underground. The shuttle cars and 

longwall system are driven by electricity while transport vehicles are diesel, managed by a stringent 

exhaust filtering replacement program. Ventilation is managed by both forced exhausting fans, and 

passive exhaust portals. Dust and other airborne particulates are managed using water sprays 

which sometimes include a binding additive. Since no significant impacts on air quality are 

anticipated, an alternative that requires low or non-polluting equipment is eliminated from detailed 

analysis as it would have impacts similar to the Proposed Action. 

2.4.1.3 Other Air Quality Mitigation	 to Limit or Reduce Other Greenhouse Gas 

(GHG) Emissions 

Other alternatives were suggested that: 

•	 Require stronger emission limits at power plants that use coal from the Skyline Mine; 

•	 Eliminate nitrogen dioxide (NO2) emissions during any blasting operations (including an 

alternative that prohibits cast blasting to prevent orange clouds from forming);
 

•	 Require a compensatory reduction in emissions for any and all emissions that would continue 

or increase as a result of the proposed coal lease by securing commitments from oil and gas 

operators in the region to reduce their emissions; 

•	 Require the use of low carbon fuels for the operation of any heavy machinery; or 

• Require that the Skyline Mine use renewable energy for power. 

These alternatives were eliminated from detailed analysis because OSMRE does not have the 

regulatory authority to require electricity generating plants to reduce emissions and the emissions 

are regulated by states or countries where the plants are located. 

The Skyline Mine is an underground mine and does not use “cast blasting”. Alternatives to prohibit 

cast blasting are unnecessary. Emissions from mining underground are released to the atmosphere 

through the mine’s ventilation system. 

Requiring additional emission control measures for those that use the Skyline Mine coal and nearby 

oil and gas operations would be outside the scope of OSMRE's authority. Further, such an 

alternative would not be reasonable, as the Skyline Mine must comply with the requirements of the 

CAA and obtain approval of an air quality permit from the DEQ, Department of Air Quality, under 

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Chapter 2 April 2017 Environmental Assessment 

the requirements of the Utah Air Conservation Act (Title 19, Chapter 2 of the Utah Code). The air 

permit incorporates measures that address the issues raised. 

2.4.1.4 Offsite Mitigation or Compensation 

Comments suggested that there should be mitigation requirements, such as offsite mitigation, 

mitigation that requires compensation, or offset carbon dioxide (CO2) emissions from the Skyline 

Mine and the power plants fueled with coal from the Skyline Mine. Offsite mitigation could include 

developing a comparable amount of renewable energy. 

The Proposed Action has the potential to emit CO2 at the levels identified in Section 3.3 and 

Section 4.3. CO2 emissions from the Proposed Action are estimated at 14,893 metric tons per year, 

well below the US Environmental Protection Agency’s (EPA) Final Mandatory Reporting of 

Greenhouse Gases Rule threshold of 25,000 metric tons per year of carbon dioxide equivalent 

(CO2e) (40 CFR Part 98). 

Because no significant impacts are predicted from CO2 emissions attributed to the Proposed Action, 

an alternative that requires compensatory mitigation is eliminated from detailed analysis. 

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Chapter 3
 

Affected Environment
 

3.1 Introduction 

This chapter describes the current condition of resources that could be affected by the Proposed 

Action. Table 4 lists the issues, along with how they are incorporated into the analysis or otherwise 

addressed. 

The summary of cumulative impacts in Table 4 refers to Table 2.1 in the Forest Service’s 2002 

ROD (US Forest Service, 2002b). The analysis of the impacts of the selected alternative included 

surface disturbance, vent shafts, and exploration holes. These activities were either completed or 

no longer proposed and are not included in the Proposed Action or No Action analyzed in this EA. 

Table 4 includes the summary of cumulative impacts from the mining of the Flat Canyon Federal 

Coal Lease Tract UTU-77114 identified in the Forest Service’s 2002 ROD, but excludes the impacts 

from surface disturbance, vent shaft, or exploration drilling. 

The CEQ’s definition of a cumulative impact is “the impact on the environment which results from 

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

actions regardless of what agency (federal or non-federal) or person undertakes such other actions. 

Cumulative impacts can result from individually minor, but collectively significant actions taking 

place over a period of time” (40 CFR 1508.7). Therefore, if a project would have no direct or indirect 

effect, it would not have any cumulative effect. 

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Table 4 - Issue Disposition 

Resource 

Affected 

Environment 

(FEIS or SIR 

Reference) 

Environmental 

Consequences 

(FEIS, SIR, or 

ROD Reference) 

Cumulative Impacts 

(FEIS or ROD Table 2.1 

Selected Alternative) 

Brought 

Forward for 

Further 

Analysis 

Rationale for Elimination, Summary 

of Impacts from ROD or EA 

Air Quality and FEIS Section Not Applicable Not Applicable Yes On July 13, 2015, the DEQ approved 

Climate Change 2.4; 

SIR pages 5-8 

Air Quality 

and Climate 

change 

analysis is 

the modification to Skyline Mine’s air 

quality permit (DQAE-AN0092007-03) 

to increase haulage of coal and add 

staking tube (DEQ, UDAQ, 2015). 

discussed in 

EA Sections 

3.3, 4.3 and 

5.3. 

Cultural FEIS Section FEIS Section No impact from mining, 

Resources 3.1.12 4.1.11 subsidence impacts indicates little potential for damage from 

avoided through subsidence. Cracks would heal in 1 or 2 

“subsidence protection years. The State Historic Preservation 

zones” No Office (SHPO) concurred with a 

determination that no historic properties 

would be affected (Utah SHPO, 2001). 

There would be no direct or indirect 

impacts and therefore, no cumulative 

impact on cultural resources. 

Environmental 

Justice 

Not Addressed Not Addressed Not Addressed There are no environmental justice 

populations present in the Project Area 

Yes or vicinity and therefore it is not 

Sections 3.4, 

4.4, and 

analyzed further in this EA. No minority 

or low-income populations 1 are located 

5.2.3. in Sanpete County; minority population 

is 14.1 percent (white alone) according 

to the 2014 (US Census Bureau, 2014). 

The Forest Service’s 2002 ROD 

1 Minority population: Minority populations should be identified where either: (a) the minority population of the affected area exceeds 50 percent or 

(b) the minority population percentage of the affected area is meaningfully greater than the minority population percentage in the general 

population or other appropriate unit of geographic analysis. Low Income annual statistical poverty thresholds from the Bureau of the Census’ 

Current Population Report. http://www3.epa.gov/environmentaljustice/resources/policy/ej_guidance_nepa_ceq1297.pdf 

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Environmental Assessment April 2017 Affected Environment 

Resource 

Affected 

Environment 

(FEIS or SIR 

Reference) 

Environmental 

Consequences 

(FEIS, SIR, or 

ROD Reference) 

Cumulative Impacts 

(FEIS or ROD Table 2.1 

Selected Alternative) 

Brought 

Forward for 

Further 

Analysis 

Rationale for Elimination, Summary 

of Impacts from ROD or EA 

The poverty level is 15.7 percent (2009­

2013). 

Emery County’s minority population in 

2013 was 3.4 percent (white alone) 

according to the Census Bureau the 

poverty level was 10.0 percent (2013) 

(US Census Bureau, 2014). Power 

stations supplied by Skyline Mine 

provide relatively low cost electrical 

power to populations that include lowincome populations. As there are no 

direct or indirect impacts on 

environmental justice populations, there 

would be no cumulative impacts. 

Farm Lands 

(prime or 

unique) 

Not Addressed Not Addressed Not Applicable 

No 

No prime or unique farm lands occur in 

the vicinity (NRCS, 2014) and therefore 

there would be no direct, indirect, or 

cumulative impacts on farmlands. 

Fish (Aquatic FEIS Section FEIS Section 4.1.7 FEIS 4.1.7, pages 4-56; The FEIS found there would be no 

Wildlife) 3.1.8 Impacts considered: 

surface disturbance and 

logging, human uses. 

Cumulative impacts study 

area would not change. 

No 

direct impacts on fish populations from 

subsidence and mine water discharge. 

Tributaries to Upper Huntington Creek 

provide spawning habitat for cutthroat 

trout, and there is low probability that 

subsidence will alter drainages. 

Rainbow trout are stocked yearly in 

Boulger Reservoir. The Forest Service’s 

2002 FEIS determined no impact on 

Boulger Reservoir from subsidence and 

no cumulative impacts on fish. 

Indirectly, coal combustion can affect 

fish. Coal combustion facilities are 

regulated to minimize emissions that 

adversely affect fish. Due to the 

representative nature of the emissions 

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Chapter 3 April 2017 Environmental Assessment 

Resource 

Affected 

Environment 

(FEIS or SIR 

Reference) 

Environmental 

Consequences 

(FEIS, SIR, or 

ROD Reference) 

Cumulative Impacts 

(FEIS or ROD Table 2.1 

Selected Alternative) 

Brought 

Forward for 

Further 

Analysis 

Rationale for Elimination, Summary 

of Impacts from ROD or EA 

analysis for coal combustion in this EA, 

OSMRE determined that indirect 

impacts to biological and water 

resources were not quantifiable, and 

therefore could not be analyzed, as 

those resources depend on site-specific 

landscape and ecosystem 

characteristics that would be different 

for every location. 

Wildlife FEIS Section 

3.1.8 

SIR (pages 4­

5) 

FEIS Section 4.1.7 Cumulative impacts study 

area would not change. 

There are no new past, 

present or reasonably 

foreseeable actions that 

have or would cause 

additional cumulative 

impacts. 

No 

The FEIS found impacts from 

underground mining or subsidence 

would be negligible, and cited 

monitoring requirements that would be 

implemented. Indirectly, coal 

combustion can affect wildlife 

resources. Coal combustion facilities 

are regulated to minimize emissions 

that adversely affect wildlife Due to the 

representative nature of the emissions 

analysis for coal combustion in this EA, 

OSMRE determined that indirect 

impacts to biological and water 

resources were not quantifiable, and 

therefore could not be analyzed, as 

those resources depend on site-specific 

landscape and ecosystem 

characteristics that would be different 

for every location. 

Floodplains Not Applicable ROD findings of 

consistency with 

Other Laws and 

Regulations, pages 

20 and 21. 

Not Applicable 

No 

The ROD found that floodplains would 

not be affected. Proposed activities 

would not alter natural floodplains; 

Project Area would be within Zone C 

(low risk). The selected alternative will 

be in compliance with Executive Order 

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Environmental Assessment April 2017 Affected Environment 

Resource 

Affected 

Environment 

(FEIS or SIR 

Reference) 

Environmental 

Consequences 

(FEIS, SIR, or 

ROD Reference) 

Cumulative Impacts 

(FEIS or ROD Table 2.1 

Selected Alternative) 

Brought 

Forward for 

Further 

Analysis 

Rationale for Elimination, Summary 

of Impacts from ROD or EA 

11988 (Floodplain Management) and 

therefore, there would be no direct, 

indirect, or cumulative impacts 

Geology FEIS Section 

3.1.2 

FEIS Section 4.1.2; 

addressed surface 

disturbance, 

subsidence, and 

seismicity 

FEIS Section 4.1.2, pages 

4-20; Cumulative impacts 

study area would not 

change. There are no new 

past, present or 

reasonably foreseeable 

actions that have or would 

cause additional 

cumulative impacts. 

Yes Section 

3.2 and 

Section 4.2. 

Geology is carried forward for 

informational purposes and for 

supporting related resources. 

Geology analysis is discussed in EA. 

Grazing FEIS Section FEIS Section FEIS Section No range improvements were identified 

Management 2.4 2.4 2.4 

No 

that could be damaged by subsidence 

and a no impact determination was 

made on forage in the Forest Service’s 

2002 FEIS. 

Hazardous FEIS Section FEIS Section 4.1.5; FEIS pages 4-43 The potential for surface and 

Materials 4.1.4, 4.1.5 ROD page 11 

No 

groundwater contamination is unlikely 

as Canyon Fuel Company, LLC is 

required to obtain approval from 

regulatory agencies to abandon 

equipment underground and given 

present evidence that there would be no 

connection between equipment and 

surface and groundwater; low 

permeability of rock layers exposed in 

Project Area. Canyon Fuel Company, 

LLC is required to remove all fluids, 

batteries, etc. prior to abandoning any 

approved equipment underground and 

therefore, there would be no direct, 

indirect, or cumulative impacts. 

Land Use 

Authorization 

FEIS Section 

2.4 (Issues Not 

FEIS Section 

2.4 (Issues Not 

FEIS Section 

2.4 (Issues Not No Mining-induced subsidence and seismicity would not damage Beaver 

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Chapter 3 April 2017 Environmental Assessment 

Resource 

Affected 

Environment 

(FEIS or SIR 

Reference) 

Considered) 

Environmental 

Consequences 

(FEIS, SIR, or 

ROD Reference) 

Considered) 

Cumulative Impacts 

(FEIS or ROD Table 2.1 

Selected Alternative) 

Considered). 

Migratory Birds 

Native American 

Cultural 

Concerns 

FEIS Section 

3.1.8 

Not Addressed 

FEIS Section 

4.1.7 

Not Addressed 

Cumulative impacts study 

area would not change. 

There are no new past, 

present or reasonably 

foreseeable actions that 

have or would cause 

additional cumulative 

impacts. 

Not Addressed 

Noise Not identified 

as an issue 

during scoping, 

therefore; not 

addressed. 

ROD pg. 12. Not identified as an issue 

during scoping, therefore; 

not addressed. 

Brought 

Forward for
 

Further
 

Analysis
 

No 

No 

No 

Rationale for Elimination, Summary 

of Impacts from ROD or EA 

Dams Reservoir or Electric Lake, and 

their associated dams as neither dam 

would be mined-under or subsided. The 

Maximum Credible Event of Richter 

3.45 would not produce ground shaking 

sufficient to damage facilities or dams at 

Beaver Dams Reservoir or Electric 

Lake. Additionally, the BLM has no 

plans to develop the lease area so no 

conflict would develop with a BLM 

Withdrawal in the lease area. 

The Forest Service’s 2002 FEIS found 

impacts from underground mining or 

subsidence would be negligible, and 

cited monitoring requirements that 

would be implemented. 

In 2001, the Hopi Tribe (The Hopi Tribe, 

2001) and Utah SHPO concurred that 

no historic property resources were 

present. Government-to-Government 

consultation between OSMRE and the 

Hopi and Southern Ute Tribes, and 

Santa Clara Pueblos under Section 106 

of the Historic Resources Preservation 

Act for this project are ongoing. 

All mining production would be 

underground. Current levels of noise 

would continue, however, there would 

be no additional noise generated on the 

surface. There are no noise-sensitive 

receptors (such as schools or hospitals) 

in the Project Area or within a distance 

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Environmental Assessment April 2017 Affected Environment 

Resource 

Affected 

Environment 

(FEIS or SIR 

Reference) 

Environmental 

Consequences 

(FEIS, SIR, or 

ROD Reference) 

Cumulative Impacts 

(FEIS or ROD Table 2.1 

Selected Alternative) 

Brought 

Forward for 

Further 

Analysis 

Rationale for Elimination, Summary 

of Impacts from ROD or EA 

which would warrant analysis. The 

nearest school is approximately 13 

miles away from the mine and 

separated by mountains. The nearest 

greater sage-grouse lek is 

approximately 10 miles away and would 

not be affected by mine-related noise. 

ROD states, “there would be no longterm noise that would displace [wildlife] 

use.” There would be no direct or 

indirect impacts, and therefore no 

cumulative impacts. 

Noxious Weeds, FEIS Section FEIS Section FEIS Section Requirements for the prevention and 

Invasive and 2.4 2.4 2.4 spread of noxious weeds and 

Non-native reclamation are included in stipulations 

Species 

No 

and Utah DOGM permit. Outside of 

these reclamation activities there would 

be no surface disturbance associated 

with mining of the Flat Canyon Coal 

Lease Tract. UTU-77114, therefore 

there would be no direct, indirect, or 

cumulative impacts. 

Paleontological FEIS Section FEIS Section FEIS 4-73; potential for Fossils of bone material are rarely 

Resources 3.1.12 4.1.11 unanticipated discoveries; 

protection measures in 

place; No change in 

cumulative impacts study 

area and no new past, 

present or reasonably 

foreseeable actions that 

have or would cause 

additional cumulative 

impacts. 

No 

found in the coal seams. No significant 

sites with Cretaceous plants and 

animals, including dinosaurs have been 

identified in the Project Area. No 

discoveries of Pleistocene mammal 

remains have been made in the Project 

Area; although it is likely they occur 

within the canyon bottoms and 

floodplains in the Project Area. 

Therefore, there would be no direct, 

indirect, or cumulative impacts. 

Recreation FEIS Section FEIS Section 4.1.8 FEIS 4.1.8, pages 4-62; No The Forest Service’s 2002 FEIS 

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Chapter 3 April 2017 Environmental Assessment 

Resource 

Affected 

Environment 

(FEIS or SIR 

Reference) 

Environmental 

Consequences 

(FEIS, SIR, or 

ROD Reference) 

Cumulative Impacts 

(FEIS or ROD Table 2.1 

Selected Alternative) 

Brought 

Forward for 

Further 

Analysis 

Rationale for Elimination, Summary 

of Impacts from ROD or EA 

3.1.9 Impacts considered: 

human use of reservoirs, 

oil and gas development 

evaluated subsidence and determined 

no impact on Boulger Reservoir or Flat 

Canyon Campground due to 

subsidence and subsidence prevention 

zones. 

Social and 

Economic 

Values 

FEIS 

Section 3.1.14 

FEIS Section 

3.1.13 

FEIS pages 4-74; Impacts 

considered: employment, 

mining economy in Utah. 

Yes 

Sections 3.4, 

4.4, and 5.2.3 

Updated information is provided for 

revenue, employment, and coal value. 

Soils Not Addressed Not Addressed Not Addressed 

Yes 

Sections 3.7, 

4.7, and 5.2.6 

Subsidence may result in cracks or 

larger openings on the surface where 

soil could be lost if it falls into the 

subsurface or washed away. The 

potential is negligible to minor and 

would be mitigated by a stipulation 

included in the Flat Canyon Lease 

requiring mining to be conducted to 

prevent surface subsidence that would 

create hazardous condition. 

Threatened or FEIS Sections FEIS Sections Not Addressed There would be no impact on 

Endangered, 3.1.7 and 3.1.8; 4.1.6 and 4.1.7; threatened and endangered species. 

Candidate, and SIR pages 4-5. SIR pages 4-5. The Forest Service SIR identified no 

Proposed suitable habitat within the Flat Canyon 

Wildlife and Federal Coal Lease Tract UTU-77114 

Plants for 3 candidate species added to the US 

Fish and Wildlife Service county list 

since the Forest Service’s 2002 FEIS. 

No There would be no impact on 

threatened and endangered species. 

Indirectly, coal combustion can affect 

threatened, endangered, candidate, or 

proposed wildlife or plants. Coal 

combustion facilities are regulated to 

minimize emissions that adversely 

affect these species. Due to the 

representative nature of the emissions 

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Environmental Assessment April 2017 Affected Environment 

Resource 

Affected 

Environment 

(FEIS or SIR 

Reference) 

Environmental 

Consequences 

(FEIS, SIR, or 

ROD Reference) 

Cumulative Impacts 

(FEIS or ROD Table 2.1 

Selected Alternative) 

Brought 

Forward for 

Further 

Analysis 

Rationale for Elimination, Summary 

of Impacts from ROD or EA 

analysis for coal combustion in this EA, 

OSMRE determined that indirect 

impacts to biological and water 

resources were not quantifiable, and 

therefore could not be analyzed, as 

those resources depend on site-specific 

landscape and ecosystem 

characteristics that would be different 

for every location. 

Rare Plants, FEIS Sections FEIS Sections Not Applicable There would be no impact on sensitive 

Fish, and 3.1.7 and 3.1.8; 4.1.6 and 4.1.7; species (ROD, Attachment 3, pages 12­

Wildlife, SIR pages 4-5. SIR pages 4-5. 13). 

Including For Forest Service sensitive species, 

greater sage- the SIR identified the western boreal 

grouse 

Yes Greater 

sage-grouse 

is discussed 

in Sections 

3.5, 4.5, and 

5.2.4. 

toad as the only species with suitable 

habitat within the lease area. The SIR 

concluded that the original amphibian 

analysis was complete in the FEIS and 

no additional analysis was necessary. 

Indirectly, coal combustion can affect 

rare plant, fish, and wildlife. Coal 

combustion facilities are regulated to 

minimize emissions that adversely 

affect these species. Due to the 

representative nature of the emissions 

analysis for coal combustion in this EA, 

OSMRE determined that indirect 

impacts to biological and water 

resources were not quantifiable, and 

therefore could not be analyzed, as 

those resources depend on site-specific 

landscape and ecosystem 

characteristics that would be different 

for every location. 

Inventoried FEIS Section FEIS Section FEIS Section No There would no direct, indirect, or 

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Chapter 3 April 2017 Environmental Assessment 

Resource 

Roadless Area 

Transportation The Forest Service’s 2002 FEIS 

and Access 

Vegetation 

Visual 

Resources 

Affected 

Environment 

(FEIS or SIR 

Reference) 

2.4; SIR page 

3. 

FEIS Section 

3.1.11 

FEIS Section 

3.1.7 

FEIS Section 

3.1.10 

Environmental 

Consequences 

(FEIS, SIR, or 

ROD Reference) 

2.4; SIR page 3. 

FEIS Section 

4.1.10 

FEIS Section 4.1.6 

FEIS Section 4.1.9 

Cumulative Impacts 

(FEIS or ROD Table 2.1 

Selected Alternative) 

2.4; SIR page 3. 

FEIS pages 4-68; Impacts 

considered: other uses on 

SR-264 and SR-31. No 

change in cumulative 

impacts study area or new 

past, present or 

reasonably foreseeable 

actions that have or would 

cause additional 

cumulative impacts 

FEIS Section 4.1.6; 

Impacts considered: 

surface disturbance, 

grazing, human uses. No 

change in cumulative 

impacts study area or new 

past, present or 

reasonably foreseeable 

actions that have or would 

cause additional 

cumulative impacts. 

FEIS pages 4-66: 

considered additional 

private development, oil 

and gas. No change in 

cumulative impacts study 

area or new past, present 

or reasonably foreseeable 

actions that have or would 

cause additional 

cumulative impacts 

Brought 

Forward for
 

Further
 

Analysis
 

No 

No 

No 

Rationale for Elimination, Summary 

of Impacts from ROD or EA 

cumulative impacts on Inventoried 

Roadless Areas or Unroaded 

Undeveloped Areas because none are 

located within the Project Area. 

disclosed that minor cracks from 

subsidence could occur on SR-264 that 

would need repair. On National Forest 

and private roads, larger cracks are 

expected. These cracks would also 

require repair by Lessee. 

There would be no impact on vegetation 

because no surface disturbance is 

negligible and would not affect 

proposed. Subsidence would be 

vegetation. 

Visual quality would not be affected. 

There would be no apparent visible 

impacts of mining-induced subsidence 

and seismicity. Impacts from past mine 

development are consistent with visual 

quality objectives. 

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Environmental Assessment April 2017 Affected Environment 

Affected Environmental Cumulative Impacts Brought Environment Consequences (FEIS or ROD Table 2.1 Forward for Rationale for Elimination, Summary Resource (FEIS or SIR (FEIS, SIR, or Selected Alternative) Further of Impacts from ROD or EA 

Reference) ROD Reference) Analysis 

Water Quality, FEIS Sections FEIS Sections FEIS Section 4.1.4; Impacts on water determined in the 

Surface/ 3.1.5 and 3.1.6; 4.1.4 and 4.1.5; Impacts considered: Forest Service’s 2002 FEIS included 

Groundwater SIR page 3. SIR pages 3-4. Skyline Mine construction, mine water discharge, possible 

water diversions and subsidence in Huntington drainage, 

changes in discharge, possible interception of groundwater 

grazing pressure on and contamination from oils and other 

riparian; subsidence fluids. Indirectly, coal combustion can 

impacts on surface flows, affect water quality. Coal combustion 

dewatering of deep- facilities are regulated to minimize Yes perched aquifers. No emissions that adversely affect water Sections 3.6, change in cumulative quality. Due to the representative nature 4.6, and impacts study area or new of the emissions analysis for coal 5.2.5. past, present or combustion in this EA, OSMRE 

reasonably foreseeable determined that indirect impacts to 

actions that have or would biological and water resources were not 

cause additional quantifiable, and therefore could not be 

cumulative impacts. analyzed, as those resources depend 

on site-specific landscape and 

ecosystem characteristics that would be 

different for every location. 

Water Rights Not Addressed FEIS Section 4.1.5, The Proposed Action would not affect 

pg. 4-40 

Not Applicable 

groundwater or surface water flow and 

therefore no impacts on water rights. 

There would be no impact on water 

rights. Water rights in the Project Area 

are addressed under Water No Replacement Rules. Utah Code 40-10­

18 requires the mine operator to 

"promptly replace any state 

appropriated water in existence prior to 

the application for a surface coal mining 

and reclamation permit." 

Wetlands/ FEIS Section FEIS Section 4.1.6 FEIS page 4-48 states that The Forest Service’s 2002 FEIS noted No Riparian Zones 3.1.7 “...current management subsidence of perennial stream 

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Chapter 3 April 2017 Environmental Assessment 

Resource 

Wild and Scenic 

Rivers 

Wilderness/ 

Wilderness 

Study Areas 

Affected 

Environment 

(FEIS or SIR 

Reference) 

Not Addressed 

Not Addressed 

Environmental 

Consequences 

(FEIS, SIR, or 

ROD Reference) 

Not Addressed 

Not Addressed 

Cumulative Impacts 

(FEIS or ROD Table 2.1 

Selected Alternative) 

practices are leading to 

conditions”. 

improvement of riparian 

Not Addressed 

Not Addressed 

Brought 

Forward for
 

Further
 

Analysis
 

No 

No 

Rationale for Elimination, Summary 

of Impacts from ROD or EA 

channels would not occur with the 

possible exception of the Cunningham 

Drainage. No impacts to riparian 

vegetation in the vicinity of the stream 

channel are anticipated. Most of the 

springs that maintain wetlands are 

located adjacent to the valley bottom 

and would be within the subsidence 

protection zone. No adverse impacts to 

wetlands are anticipated. Indirectly, coal 

combustion can affect wetlands and 

riparian areas. Coal combustion 

facilities are regulated to minimize 

emissions that adversely affect 

wetlands and riparian areas. Due to the 

representative nature of the emissions 

analysis for coal combustion in this EA, 

OSMRE determined that indirect 

impacts to biological and water 

resources were not quantifiable, and 

therefore could not be analyzed, as 

those resources depend on site-specific 

landscape and ecosystem 

characteristics that would be different 

for every location. 

Wild and Scenic Rivers would not be 

affected because no Wild and Scenic 

rivers occur in or near the Project Area. 

Virgin River, at a distance of 175 miles 

to the southwest, is closest Wild and 

Scenic River. 

Wilderness or Wilderness Study Areas 

are not present within or near the 

Project Area. Mt. Nebo Wilderness 

Area, located 25 miles to the northwest, 

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Environmental Assessment April 2017 Affected Environment 

Resource 

Affected 

Environment 

(FEIS or SIR 

Reference) 

Environmental 

Consequences 

(FEIS, SIR, or 

ROD Reference) 

Cumulative Impacts 

(FEIS or ROD Table 2.1 

Selected Alternative) 

Brought 

Forward for 

Further 

Analysis 

Rationale for Elimination, Summary 

of Impacts from ROD or EA 

is the closest wilderness area. 

SIR – Supplemental Information Report 

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Chapter 3 April 2017 Environmental Assessment 

3.2 Topography and Geology 

The Flat Canyon Coal Lease Tract UTU-77114 lies in the interior of the Wasatch Plateau. The 

Wasatch Plateau has been incised by deep canyons shaped by glaciers and by wind and water 

erosion. Huntington Canyon drains the eastern flank of the Wasatch Plateau. Upper Huntington 

Creek along the eastern project boundary forms the headwaters of Huntington Canyon, trending 

north-south (see Figure 4). The Flat Canyon Coal Lease Tract UTU-77114 lies on the western 

slope of Upper Huntington Creek and the tributaries that drain the west slope of Huntington 

Canyon. The major tributaries generally trend east-west. 

Previous mining includes the Skyline Mine with surface facilities located to the east in Eccles 

Canyon (see Figure 4, single seam mining shown for simplicity). Coal was extracted from 

underground using the longwall mining method. Mining occurred in 3 separate coal seams that 

partially overlap. Historically, two sets of longwall mining equipment operating were used 

concurrently in separate mine levels. However, current production is from a single longwall face 

operating in the Lower O’Conner A Seam of the Skyline No. 3 Mine (DNR, 2015). See Figure 6 for 

a generalized columnar section for the Flat Canyon Coal Lease Tract UTU-77114. 

Full extraction longwall mining results in failure of the immediate roof strata, leading to fracture and 

flexure of the overburden rocks progressing upwards and resulting in surface subsidence. The 

degree of subsidence varies with the mining layout, geology, thickness of extraction, and amount 

and type of overburden. With the overburden depths at the Skyline Mine, flexure of the rock strata 

occurs near the surface due to differential subsidence, generally without fracture. However, in some 

isolated areas, tension fractures can open, such as where massive rock beds are located near the 

surface or above stacked barrier pillars. 

Subsidence produces a zone of flexure where tension can sometimes result in minor cracking of the 

surface that soon close and rapidly heal. Permanent tensile zones that produce fractures may take 

longer to heal. Of the total area mined at Skyline Mine (10,733 acres), less than 0.5 percent of the 

area has produced tensile fractures. Additionally, the overburden depth in this subsided area was 

as low as 600 feet. Figure 4 shows past areas of subsidence, along with the current Project Area 

and previously mined areas of Skyline Mine. Similar conditions are not present in the Project Area. 

The depth of overburden is greater than 1,000 feet. No major slope failures have been observed at 

Skyline Mine. 

Mining-induced seismicity has also been experienced as a direct result of longwall mining at Skyline 

Mine. Seismicity, the propagation of measurable earthquake waves, results from collapsing ground. 

A study of this phenomenon was carried out from 1986 to 1996 while the Skyline Mine was 

operating in the northern section of the current mining area (Arabasz, et al., 1997). Results of the 

study indicated a very strong correlation between mining induced seismicity and longwall production 

at depths greater than 1,500 feet. No surface damage or slope failure was reported due to the 

seismicity. 

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Environmental Assessment April 2017 Affected Environment 

Figure 4 - Topography 

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Chapter 3 April 2017 Environmental Assessment 

Figure 5 - Previous Mining 

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Environmental Assessment April 2017 Affected Environment 

Figure 6 - Generalized Columnar Section 

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Chapter 3 April 2017 Environmental Assessment 

3.3 Air Quality and Climate Change 

3.3.1 Air Quality 

3.3.1.1 Airshed for Analysis 

The regional airshed for analysis was delineated using topography with consideration of the climatic 

wind regime based on the location of Skyline Mine’s surface facilities (where the emissions occur). 

The Skyline Mine facilities were assessed to determine the likely region where local emission 

impacts could occur to determine the likely region of influence. The regional airshed is 

approximately 1,891 square miles (Figure 7). The airshed’s northern boundary runs along the north 

side of Highway 6 from the town of Tucker to Helper, Utah. The northeast part of the airshed is 

bounded by the Book Cliffs from Helper to just south of East Carbon. The southeast boundary of 

the airshed is made up of Flattop Mountain, Cedar Mountain, Sids Mountain and various ridges in 

between to approximately 4 miles north of County Road 803. The southwest boundary lies between 

the towns of Ferron and Moore and turns north at Young’s Peak. The western boundary runs along 

the eastern boundary of the Manta-La Sal National Forest north to Red Point then heads northwest 

to Candland Mountain. The boundary continues north on along the east side of Electric Lake along 

ridgetops to the town of Tucker. 

3.3.1.2 Regulatory Requirements 

Federal actions must meet the requirements of the CAA and must not cause or contribute to a 

violation of applicable air quality standards. The State of Utah, Division of Air Quality (UDAQ) is the 

delegated authority for implementing the CAA in Utah and has developed a State Implementation 

Plan, outlining the requirements and regulations that the state will follow to assure that it is and will 

remain in compliance. There is no county or local air quality permitting requirements. 

Criteria Pollutants National Ambient Air Quality Standards 

The EPA sets the standards for the criteria pollutants (Table 5). The National Ambient Air Quality 

Standards (NAAQS) include primary and secondary standards for criteria pollutants. Primary 

standards provide for the protection of the public health, including “sensitive” populations such as 

asthmatics, children, and the elderly. Secondary standards provide for the protection of the public 

welfare, including protection against decreased visibility and damage to animals, crops, vegetation, 

and buildings. The EPA designates whole or partial counties as attainment, non-attainment, or 

maintenance for each criteria air pollutant. Areas of the country where air pollution levels 

persistently exceed the NAAQS are designated as nonattainment. Areas that are able to meet the 

NAAQS are designated as attainment areas. These designations have been developed to help 

areas with air pollution above the NAAQS to conform, and to prevent the deterioration of air quality 

in areas that currently meet the NAAQS. The monitored ambient air quality levels in the regional 

airshed indicate that the criteria pollutant levels for all criteria pollutants are below the applicable 

NAAQS (Table 5), therefore, EPA has designated the area as an attainment area for all criteria 

pollutants. In attainment areas like Carbon County, the CAA allows for growth and limited 

degradation of the ambient air quality that may be associated with that growth. 

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Environmental Assessment April 2017 Affected Environment 

Figure 7 - Regional Airshed 

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Chapter 3 April 2017 Environmental Assessment 

Table 5 - NAAQS 

Pollutant - Primary/ 

Secondary 

Averaging 

Time Level Form 

Carbon Monoxide 

(CO) 

primary 8 hours 9 ppm Not to be exceeded more 

1 hour 35 ppm than once per year 

Lead (Pb) primary and 

secondary 

Rolling 3 

month period 0.15 μg/m3(1) Not to be exceeded 

Nitrogen Dioxide 

(NO2) 

primary 1 hour 100 ppb 

98th percentile of 1-hour daily 

maximum concentrations, 

averaged over 3 years 

primary and 

secondary 1 year 53 ppb(2) Annual Mean 

Ozone (O3) primary and 

secondary 8 hours 0.070 ppm(3) 

Annual fourth-highest daily 

maximum 8-hour 

concentration, averaged over 

3 years 

Particle Matter 

(PM) 

PM2.5 

primary 1 year 12.0 μg/m3 annual mean, averaged over 

3 years 

secondary 1 year 15.0 μg/m3 annual mean, averaged over 

3 years 

primary and 

secondary 24 hours 35 μg/m3 98th percentile, averaged over 3 years 

PM10 primary and 

secondary 24 hours 150 μg/m3 

Not to be exceeded more than 

once per year on average 

over 3 years 

Sulfur Dioxide 

(SO2) 

primary 1 hour 75 ppb 

99th percentile of 1-hour daily 

maximum concentrations, 

averaged over 3 years 

secondary 1 year 15.0 μg/m3 Not to be exceeded more than 

once per year 

Source: (EPA, 2016a) 

(1) In areas designated nonattainmentfor the Pb standards prior to the promulgation of the current (2008) standards, 

and for which implementation plans to attain or maintain the current (2008) standards have not been submitted and 

approved, the previous standards (1.5 μg/m3 as a calendar quarter average) also remain in effect. 

(2) The level of the annual NO2 standard is 0.053 ppm. It is shown here in terms of ppb for the purposes of clearer 

comparison to the 1-hour standard level. 

(3) Final rule signed October 1, 2015, and effective December 28, 2015. The previous (2008) O3 standards additionally 

remain in impact in some areas. Revocation of the previous (2008) O3 standards and transitioning to the current (2015) 

standards will be addressed in the implementation rule for the current standards. 

μg/m3 – micrograms per cubic meter of air 

ppm – parts per million 

ppb – parts per billion 

Prevention of Significant Deterioration 

The CAA also divides areas where air quality is already cleaner than required by federal standards 

into 3 classes, and specifies the increments of SO2, NO2 and PM pollution allowed in each class 

(Table 6) as regulated by the Prevention of Significant Deterioration regulations (40 CFR 52.21). 

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Environmental Assessment April 2017 Affected Environment 

Table 6 - Federal Prevention of Significant Deterioration Limits 

Pollutant Averaging Time Class I Area 

Maximum Allowable 

Increase (μg/m3) 

Class II Area 

Maximum Allowable 

Increase (μg/m3) 

Class III Area 

Maximum Allowable 

Increase (μg/m3) 

PM2.5 Annual 1 4 8 

24-hour 2 9 18 

PM10 Annual 4 17 34 

24-hour 8 30 60 

Annual 2 20 40 

SO2 24-hour 5 91 182 

3-hour 25 512 700 

NO2 Annual 2.5 25 50 

μg/m3 = Micrograms per cubic meter of air 

The 5 mandatory Class I areas in Utah include: Zion National Park, Bryce National Park, Capitol 

Reef National Park, Arches National Park, and Canyonlands National Park (UAC, 2016). The 

closest Class I area is Capitol Reef, approximately 75 miles to the southwest of the project. This 

Class I area would not be affected by the proposed action. The allowable increments of new 

pollution in these areas are very small. All other areas are designated as Class II except nonattainment areas (UAC, 2016); where allowable increments of new pollution are modest. Class III 

represents selected areas that states may designate for development; allowable increments of new 

pollution are large (but not exceeding NAAQS). No Class III areas are designated in Utah (UAC, 

2016). Because the Project Area is not in a national park or a non-attainment area, it is located in a 

Class II area2

. 

The regulations are applicable to a source pollutant if the source has the potential to exceed the 

major source thresholds of either 100 or 250 tons per year of a regulated New Source Review 

pollutant, depending on the type of source pollutant. For stationary source categories listed in the 

regulation, the threshold is 100 tons per year, while the threshold for source categories that are not 

listed, such as surface mining operations, is 250 tons per year. The potential to emit calculation 

does not include fugitive emissions for the purpose of determining if the facility exceeds 250 tons 

per year. Fugitive emissions are defined by EPA as, “those emissions that could not reasonably 

pass through a stack, chimney, vent, or other functionally-equivalent opening”. 

The Skyline Mine is classified as a minor source of emissions that would not exceed the 250 tons 

per year threshold for non-listed sources. Therefore, Prevention of Significant Deterioration 

regulations and preconstruction monitoring are not applicable to the mine or the Proposed Action. 

Hazardous Air Pollutants 

The CAA also enacted the New Source Performance Standards and National Emissions Standards 

for Hazardous Air Pollutants (HAPs) for specific types of equipment located at new or modified 

stationary pollutant sources. New Source Performance Standards regulations limit emissions from 

2 R307-405 Permits: Major Sources in Attainment or Unclassified Areas. 

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Chapter 3 April 2017 Environmental Assessment 

source categories to minimize the deterioration of air quality. Stationary sources are required to 

meet these limits by installing newer equipment or adding pollution controls to older equipment that 

reduce emissions below the specified limit. The Proposed Action would not include equipment that 

is subject to these regulations. New Source Performance Standards and National Emissions 

Standards for HAPs standards will apply to final coal combustion. 

Unlike criteria pollutants, there are no NAAQS for HAPs. Although, these pollutants are also 

regulated under the CAA, the approach taken is focused on restricting or limiting emissions of 

pollutants, setting emission standards and control requirements, and requiring record keeping and 

reporting of emissions to demonstrate on-going compliance with applicable limits and requirements. 

HAPs are defined in 40 CFR Part 61 as a pollutant that causes or may cause cancer or serious 

health impacts such as birth defects. There are currently 187 listed HAPs (EPA, 2016b) The 

majority of HAPs originate from stationary sources (e.g., factories, refineries, power plants) and 

mobile sources (e.g., cars, trucks, buses), as well as indoor sources (building materials and 

cleaning solvents). Specific permitting requirements are a function of the type of source or activity to 

be permitted, the type(s) of pollutants, and the quantity of pollutants to be emitted. Sources that 

have the potential to emit greater than 10 tons per year of one of any one HAP; or more than 25 

tons per year of all HAPs in aggregate; are classified as major sources. Sources are considered 

minor if they are less than the limits set for major sources. 

The Skyline Mine would not be categorized as a major source for HAPs because the mine produces 

a maximum of 0.23 tons per year of total HAPs (HDR Engineering, Inc., 2015). Skyline Mine is not 

required to obtain a Federal Title V operating permit. 

Mercury 

The final location of coal combustion is regulated under environmental regulations. On December 

16, 2011, the EPA finalized the first national standards (40 CFR Part 63) to reduce mercury and 

other toxic air pollution from coal and oil-fired power plants. 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 sets standards for all HAPs 

emitted by coal- and oil-fired electric generating units with a capacity of 25 megawatts or greater. All 

regulated units are considered major under the final rule. EPA did not identify any size, design, or 

engineering distinction between major and area sources. Existing sources generally have up to 4 

years to comply with the Mercury and Air Toxics Standards (MATS). 

The emissions limits associated with the MATS rule are presented in Table 7. The National Electric 

Energy Data System identified coal and oil fueled electricity generating plants where the MATS rule 

is likely to apply (EPA, 2011). In Utah, the power plants that the MATS rule is likely to apply to are 

all coal fired. The plants and the county they are in are Bonanza (Uintah), Carbon (Carbon), Hunter 

(Emery), Huntington (Emery), Intermountain Power Project (Millard), KUCC (Salt Lake), and 

Sunnyside Cogen Associates (Carbon). 

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Environmental Assessment April 2017 Affected Environment 

Table 7 - MATS Emission Requirements – Coal and Oil-Fired Units 

Subcategory Existing 

Mercury Emission 

Limit (lb/GWh) 

New 

Mercury Emission 

Limit (lb/GWh) 

Regular Coal 0.013 0.0002 

Designed for Low Rank Coal1 0.12 or 0.040 0.04 

IGCC (Gasified Coal) 0.03 0.003 

Solid-oil Derived & Continental Liquid Oil 0.002 0.002 

Continental Liquid Oil NA 0.0001 

Non-continental Liquid Oil 0.004 0.0004 

Source: 40 CFR Part 63.
 

lb/GWh = pounds of pollutant per gigawatt – electric output
 

Greenhouse Gases 

There are no NAAQS for GHGs. In its Endangerment and Cause or Contribute Findings for 

Greenhouse Gases under CAA Section 202(a) (FR EPA-HQ-OAR-2009-0171), EPA determined 

that GHGs are air pollutants subject to regulation under the CAA. EPA 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. The amount of GHG emissions produced by mining or burning coal varies depending on 

the mining technique used (i.e., surface versus underground mining) and combustion technologies 

employed. 

EPA has regulated 6 key GHGs: CO2, methane (CH4), nitrous oxide (N2O), hydrofluorocarbons 

(HFC), perfluorocarbons (PFC), and sulfur hexafluoride (SF6). Because CO2 is the most prevalent of 

the regulated GHGs, the EPA references the impact of GHG emissions in terms of their 

equivalence to CO2 or CO2e. 

Under the EPA’s GHG Mandatory Reporting Rule (74 FR 56260, 40 CFR 98), coal mines subject to 

the rule are required to report emissions in accordance with the requirements of Subpart FF, which 

is applicable to underground coal mines. The EPA Tailoring Rule (70 FR 31514, 40 CFR 51, 52, 70, 

and 71) was, in part, struck down by a 2014 Supreme Court decision. Based on the Supreme Court 

decision, an underground mine is subject to permitting for GHGs only if the mine has the potential 

to emit more than 100,000 tons per year of CO2e and if the mine exceeded the major source 

threshold for one or more criteria pollutants. 

The Obama Administration’s Clean Power Plan [40 CFR Part 60 Carbon Pollution Emission 

Guidelines for Existing Stationary Sources: Electric Utility Generating Units; Final Rule, 2015, (EPA, 

2015a)] directs regulations for power plants and does not apply to OSMRE’s Proposed Action to 

approve a mining plan modification. 

3.3.1.3 Regional and Local Air Quality 

The Project Area and regional airshed are currently in attainment or unclassified for all criteria 

pollutants. Population centers or areas of specific interest in the region are monitored for criteria 

pollutants and as a result the data collected for this analysis is regionally representative. The UDAQ 

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Chapter 3 April 2017 Environmental Assessment 

maintains a network of monitoring stations across the state. One of these monitoring stations is 

located in Price, Utah (Carbon County). There are no monitoring stations in the surrounding 

counties (Sanpete and Emery). In the late 1990s the EPA allowed monitoring to cease where 

pollutants were less than 60 percent of the NAAQS (UDAQ, 2015a). There are no local monitoring 

stations. 

Industrial Sources 

Permitted air quality emission sources located within 50 miles of the Skyline Mine are shown in 

Table 8. DEQ includes all sources of air quality emissions that are required by law to acquire a 

state air quality permit. Sources such as dust from dirt roads, agricultural operations, recreational 

activities, and automobile use are not included because they are not regulated as stationary 

industrial sources but have the capacity to produce air quality emissions regionally. 

Table 8 - Utah Large Industrial Source Emissions (Tons per Year) by Facility - 2012 

Site Name 

(Miles from Skyline Mine) 

City County CO NOx PM10 SOx PM2.5 VOC 

Wellington Asphalt Plant (28) Wellington Carbon 3.59 8.8 0.8 3.5 0.3 4.8 

Oak Spring Turbine 

Compressor Station (12) 

Spring Glen Carbon 2.6 55.2 11.1 0.2 11.1 0.9 

Carbon Power Plant (18) Helper 153.6 3,587.8 459.8 8,307.7 432.7 18.4 

Price Dew Point Plant (21) - Carbon 4.0 1.5 0.1 0.0 0.1 21.2 

East Carbon Landfill (40) East 

Carbon 

Carbon 9.0 18.8 11.4 1.9 3.2 42.5 

Sunnyside Cogeneration 

Facility (45) 

Carbon 

County 

Carbon 68.3 400.6 61.2 586.3 38.9 11.7 

Huntington Power Plant (22) Huntington Emery 4,012.2 7,389.8 665.9 2,301.2 244.1 83.1 

South Town Quarry & Concrete 

Batch Plant (34) 

Nephi Juab 2.9 11.7 8.7 0.9 3.1 1.1 

Salem Aggregate Facility (34) Salem Utah 1.3 4.5 13.8 0.7 1.4 0.4 

Gomex Pit- Aggregate 

Processing Plant (33) 

Spanish 

Fork 

Utah 0.3 1.1 1.9 0.1 0.9 0.1 

Source: http://enviro.deq.utah.gov/. (UDAQ, 2016) 

NOx – nitrogen oxides 

SOx – sulfur oxides 

VOC – volatile organic compounds 

Table 9 indicates the oil and gas compressor and gas plant emissions for 2012 in Utah. 

Table 9 - 2012 Oil and Gas Compressor and Gas Plant Emissions (Tons per Year) 

Site Name (Miles from Skyline Mine) NOx VOC NOx & VOC Combined 

Scofield Compressor Station (6.7) 2.05 1.66 3.70 

Oak Spring Turbine Compressor Station (12.1) 55.16 0.89 56.05 

Drunkards Wash Compressor Station (19.6) 58.91 44.45 103.36 

Emma Park Natural Gas Treatment Plant (24.4) 58.91 44.45 103.36 

Aberdeen Field Compressor Station (24.5) 58.91 44.45 103.36 

Cave Pad Compressor Station (25.2) 6.95 2.55 9.50 

Source: (UDAQ, 2016).
 

NOx – nitrogen oxides VOC – volatile organic compounds
 

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Environmental Assessment April 2017	 Affected Environment 

Ambient Background Monitoring 

The record keeping and reporting required by the Approval Order: DAQE-AN10092001-15 provides 

evidence that Skyline Mine is in compliance with all permit standards. The Skyline Mine is required 

to maintain records of operational throughput to provide evidence of compliance with all throughput 

limitations. The maximum throughputs listed in the Approval Order were used to calculate the 

facility potential to emit emissions. The facility emissions will not be exceeded as long as the 

throughput limits are not exceeded. 

The only monitoring station in the regional airshed is in Price, Utah, approximately 25 miles eastsoutheast of the Project Area. 

PM10 

PM10 data monitoring data from Price showed the highest 24-hr concentration was 48 micrograms 

per cubic meter of air; below the NAAQS of 150 micrograms per cubic meter (Table 5).The 

meteorological data is for January 1, 2006 thought December 31, 2010 (HDR Engineering, Inc., 

2015). 

NO2 

The Price monitoring station registered one exceedance of the NO2 1-hour NAAQS in 2012 and 

none in 2013 or 2014 (UDAQ, 2015a). The highest hourly background at the site during 2014 was 

6.1 parts per billion (ppb) which is below the NAAQS (100 ppb). 

Ozone 

The Price monitoring station registered one exceedance of the ozone 8-hour 2008 NAAQS in 2012, 

and none in 2013 or 2014 (UDAQ, 2015a). The highest 8-hr background at the site during 2014 was 

0.067 parts per million which is below the NAAQS (0.070 parts per million [ppm], or 70 ppb). 

SO2 and CO 

The monitoring station in Price does not measure SO2 or CO. Three network stations outside the 

regional airshed monitor CO (in Hawthorne, Ogden, and North Provo). During the reporting period 

2010 through 2015, none of the monitoring stations in the network registered exceedances of the 

NAAQS for CO. UDAQ reports that all areas in Utah are in compliance with the NAAQS for CO. 

(UDAQ, 2015a). Stations that monitor SO2 are in Beach, Magna, North Salt Lake, Hawthorne, 

Bountiful, and Roosevelt. Of these, only the Beach station registered an exceedance of the primary 

1-hour SO2 NAAQS during the 2011 through 2014 reporting period. The exceedance occurred one 

time in 2013. All sites show a decreasing trend (UDAQ, 2015a). 

EPA Air Quality Index 

The air quality index (AQI) is a range used by the EPA to measure and characterize the quality of 

air at a given location (EPA, 2014). The AQI focuses on health impacts that may be experienced 

within a few hours or days after breathing polluted air. AQI index ranges from 0 to 500. 

•	 0 to 50 – good; • 101 to 150 - unhealthy for sensitive 

groups; • 51 to 100 – moderate; 

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• 151 to 200 – unhealthy; • 301 to 500 – hazardous; 

• 201 to 300 - very unhealthy; 

The 2014 Carbon County AQI consisted of 350 days when air quality was good, and 15 days that 

experienced moderate conditions. From 2012 through 2014 Carbon County AQI consisted of 950 

days registered as good, 144 days registered as moderate, and 1 day registered as unhealthy for 

sensitive groups. 

3.3.2 Climate Change 

Following publication of the draft EA, OSMRE determined that a revised GHG and climate change 

assessment would provide useful information to the decision maker and the public. The direct, 

indirect, and cumulative impacts (Chapters 4 and 5) were revised, which required revising the 

affected environment. 

This document assesses the effects of the proposed action on climate change and the effect of 

climate change on the proposed action, and its environmental impacts through assessment of direct 

and indirect GHG emissions as a proxy for the assessment of potential climate change effects. 

Executive Order 13693 defines GHGs as CO2, CH4, N2O, and fluorinated gases 

(hydrofluorocarbons, perfluorocarbons, nitrogen trifluoride, and sulfur hexafluoride). These 

constituents are referred to as GHGs throughout the analysis. For consistency between projects, 

we describe GHG emissions in terms of “CO2-equivalents” (CO2e). 

3.3.2.1 Analysis Area for Climate Change 

For climate, climate change, and GHG analysis there is no specific analysis area, and project 

emissions are used as a proxy. 

3.3.2.2 Greenhouse Gas Emissions and Climate Change 

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. 

Human-caused 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. N2O is emitted during 

agricultural and industrial activities, as 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 carbon trioxide (CO3)­

depleting substances. 

Utah 

On a regional scale, the EPA estimated the 2013 CO2 emissions in Utah were 66 million metric tons 

(MMT) which converts to 73 million tons, although coal mined from the Skyline Mine may or may 

not be used in Utah (Energy Information Administration, 2015a). The US emissions from fossil fuels 

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in 2015 was 5,264 MMT, of which 1,499 MMT were from coal (Energy Information Administration, 

2015b). 

United States 

The EPA estimates the trend in GHG emissions in the US 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.). Table 10 

shows the estimated GHG emissions by economic sector calculated based on output in units of 

CO2e (EPA, 2016d). Compared to 1995, the 2014 US GHG emissions increased by 35 percent 

(based on total net emissions in 1995 divided by the total net emissions in 2014). CO2e estimates 

are based on guidelines recommended by the Intergovernmental Panel on Climate Change from 

fossil fuel combustion, non-energy use of fuels, and stationary combustion, wastewater treatment, 

composting, landfills, cultivation, fermentation, etc. Reporting of emissions over 25,000 metric tons 

per year did not begin until 2009. The reporting is not used in the calculations of the estimated 

emissions in the EPA’s report, but is used to “improve the national estimates presented” in the 

inventory (EPA, 2016d). 

Table 10 - 1995-2014 Estimated US Greenhouse Gas Emissions Allocated to Economic 

Sectors (in Million Metric Tons of CO2e) 

Implied Sectors 1995 2005 2010 2014 

Electric Power Industry 1,864.80 2,443.90 2,300.50 2,080.70 

Transportation 1,551.30 1,999.60 1,827.40 1,810.30 

Industry 1,620.90 1,486.20 1,394.50 1,461.70 

Agriculture 563.40 600.20 631.10 625.40 

Commercial 418.10 420.30 425.50 453.90 

Residential 344.90 370.40 361.20 393.70 

US Territories 33.70 58.20 45.30 44.70 

Total Emissions 6,397.10 7,378.80 6,985.50 6,870.40 

Land Use, Land-Use Change, and Forestry (Sink) (738.00) (698.50) (766.40) 762.50 

Net Emissions (Sources and Sinks) 5,659.10 6,680.30 6,219.10 7,632.90 

Source: Table 2-10 (EPA, 2016d)
 

Note that “Land Use, Land-Use Change, and Forestry” represents a sink rather than a source, and is therefore 

presented in parentheses.
 

Additionally, some of these gases may react with other chemical compounds in the atmosphere to 

form compounds that are GHGs. 

National SO2 emissions across the US are listed in Table 11. 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. 

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Table 11 - US SO2 (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 

3.3.2.3 Regional Climate 

The proximity of the Wasatch Mountains exerts a strong influence on the climate and weather of the 

area. Areas east of the Wasatch Range are characterized by hot, dry summers and cold, dry 

winters. Air movement at this latitude is predominately from the west and northwest year-round. The 

lower elevations receive less than 10 inches of precipitation annually. Higher elevations receive 

more than 14 inches of precipitation annually. Snow amounts are low east of the Wasatch 

Mountains. Average maximum temperatures in the area range from 97 degrees Fahrenheit (°F) in 

July to 33 °F in January. Average minimum temperatures range from 7 °F in January to 58 °F in 

July (BLM, 2008). 

According to a report by the US Global Change Research Program (Melilo, et al., 2014), current 

temperatures are “almost 2 °F higher than historic averages”, over the last 110-year instrumental 

record. Based on predictions that average annual temperatures in the southwestern US will 

increase by 3.5 °F to 9.5 °F by 2099 (maximum 0.11 °F annually) (EPA, 2012a), during the 10-year 

additional life of the mine (through 2028), average annual temperatures might increase up to 1.5 °F. 

This report states that snowpack and streamflows have and will decrease and provides quantitative 

analysis for California and the Colorado River, but not Utah. 

3.3.2.4 Local Climate and Meteorology 

The Project Area and Skyline Mine are in an alpine subarctic climate with long cold winters and 

abundant snowfall, in excess of 200 inches per year. Additional climatic data can be found in the 

Probable Hydrologic Consequences report (Petersen Hydrologic, LLC, 2014a). Precipitation 

measured at the Skyline Mine surface facilities between 1985 and 2014 ranged from 17.2 inches to 

29.4 inches per year (Canyon Fuel Company, LLC, 2014). Monthly average temperatures at the 

Skyline Mine range from 8.0 to 74.4 oF. 

The Palmer Hydrologic Drought Index for the Utah Region 4 (south central) and Utah Region 5 

(northern mountains), where the Project Area is situated were characterized from 2006 through 

2010 by generally near-normal climatic conditions with brief alternating periods of wetness and 

dryness. During 2011 the region experienced a period of severe wetness. During 2012, 2013, and 

early 2014 the region has experienced a period of continuous dryness (Petersen Hydrologic, LLC, 

2014a). 

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Black Carbon 

Black carbon is a by-product of incomplete combustion of fossil fuels, biofuels, and biomass. Black 

carbon is a likely by-product that would be emitted from haul trucks used during coal mining 

operations and locomotives used to haul coal from the mine. Black carbon is an unregulated 

pollutant; however, the EPA does regulate diesel fuel quality, such that in recent years diesel fuel 

quality has been improved. 

Of all mobile source emissions, 93 percent came from diesel engines in 2005 (EPA, 2016e). Black 

carbon directly absorbs light and reduces the reflection of heat off snow and ice as it gets 

deposited. Black carbon has been linked to climate impacts due to increased temperatures and 

accelerated ice and snow melt. 

Black carbon is a component of the anthropogenic climate phenomenon; however, it is very shortlived in the atmosphere, lasting only a few days to a few weeks. Although short lived, while in the 

atmosphere black carbon is the most strongly light-absorbing component of particulate matter. 

Black carbon can absorb a million times more energy than CO2. Black carbon is a major component 

of “soot”, a complex light-absorbing mixture that also contains some organic carbon. 

3.4 Social and Economic 

The Skyline Mine surface facilities are located in Carbon County. Historically, most of the mining 

has been located in Emery County and Carbon County. In 2013, the population of Carbon County 

was about 21,000 (US Department of Commerce, 2014a). The Flat Canyon Coal Lease Tract UTU77114 is in Sanpete County, with private surface and coal ownership extending into Emery County. 

As the mining operations function through the mine facility in Carbon County, the tax revenue is 

recognized in Carbon County. 

Table 12 shows the employment trend by industry and the overall contribution that each industry 

makes to the total labor earnings in Carbon and Sanpete counties. The average labor earnings per 

job in each industry were calculated by dividing the total labor earnings by the number of jobs. 

Table 12 - Employment by Industry – Carbon and Sanpete Counties 

Industry 

Total Number of 

Jobsa,c 

Total Labor Earnings 

per Industry 

($1000)b,d 

Average Labor 

Earnings per Job 

Carbon1 Sanpete2 Carbon1 Sanpete2 Carbon Sanpete 

Farm 301 1,025 $329 $55,135 $1,093 $53,790 

Forestry, fishing, and agriculture 

services 

NA 196 NA 12,211 NA 62,301 

Mining (including fossil fuels) 935 93 88,699 5,648 94,865 60,731 

Construction 562 644 29,744 23,548 52,925 36,565 

Manufacturing 393 893 22,829 34,828 58,089 39,001 

Utilities 123 17 16,028 1,397 130,309 82,176 

Wholesale trade 490 152 35,245 3,865 71,929 25,427 

Retail trade 1,440 1,215 44,451 23,548 30,869 19,381 

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Chapter 4 April 2017 Environmental Assessment 

Industry 

Total Number of 

Jobsa,c 

Total Labor Earnings 

per Industry 

($1000)b,d 

Average Labor 

Earnings per Job 

Carbon1 Sanpete2 Carbon1 Sanpete2 Carbon Sanpete 

Transportation and warehousing 521 276 $30,464 $12,077 $58,472 $43,757 

Information 85 228 2,423 11,642 28,506 51,061 

Finance and insurance 371 431 9,761 7,388 26,310 17,142 

Real estate and rental and leasing 352 498 3,480 6,020 9,886 12,089 

Professional and technical services 565 494 21,677 14,249 38,366 28,844 

Management of companies and 

enterprises 

72 NA 5,037 NA 69,958 NA 

Administrative and waste services 525 252 16,236 4,602 30,926 18,262 

Educational services NA 378 NA 10,983 NA 29,056 

Health care and social assistance NA 848 NA 27,694 NA 32,658 

Arts, entertainment, and recreation 152 177 1,381 1,026 9,086 5,797 

Accommodation and food services 716 565 11,795 7,060 16,473 12,496 

Other services, except public 

administration 

820 717 31,716 27,416 38,678 38,237 

Government 2,090 2,668 104,966 121,161 50,223 45,413 

Total/Average 11,765 11,819 507,605 403,068 43,145 34,103 1 2013 data; 2 2014 data
 

NA = Not Applicable
 

Sources:
 

a (US Department of Commerce 2014b)
 

b (US Department of Commerce, 2014b)
 

c (US Department of Commerce, 2015a)
 

d (US Department of Commerce, 2015b)
 

The mining sector is an important contributor to the employment and income in Carbon, Emery, and 

Sanpete counties. The Skyline Mine employment contributes approximately $39 million annually in 

wages and benefits for these employees. The estimated royalty revenue from Skyline Mine to the 

federal government is $134 million, with about 50 percent or $67 million to the State of Utah, and 50 

percent from the State of Utah or $33 million to the counties of Sanpete and Emery (Jarrett, 2015). 

Of the 320 employees, the employee distribution is approximately 30 percent from Carbon and 

Emery counties, 60 percent from Sanpete County, and 10 percent from Utah County (Galecki, 

2015b). The mine currently directly employs approximately 320 people (Galecki, 2015b) plus 

indirectly 1,162 people total (Bacon & Kojima, 2011). 

On July 1, 2015, Canyon Fuel Company, LLC was the successful bidder for the Flat Canyon 

Federal Coal Lease Tract UTU-77114 at $17.2 million ($0.4095 per ton) (BLM, 2015b). Revenue 

generated by this continued production of coal also benefits the State of Utah via the mineral lease 

funds, a portion of which funds the Permanent Community Impact Board. The Permanent 

Community Impact Board has been a major source for infrastructure projects in rural affected 

counties. Recent lower oil prices have decreased this fund. 

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In 2015 in the U.S., the industrial sector is the leading form of energy consumption (32 percent of 

total) followed by transportation (28 percent), residential (21 percent), and commercial (18 percent) 

(Energy Information Administration, 2016c). 

Electricity generated for use in the US in 2015 came from sources listed in Table 13. 

Table 13 - 2015 Electricity Generation Fuel Sources 

Fuel Source Percent of Total 

Coal 33 

Natural gas 33 

Nuclear 20 

Hydropower 6 

Other renewables 7 

Biomass 1.6 

Geothermal 0.4 

Solar 0.6 

Wind 4.7 

Petroleum 1 

Other gases <1 

Source: (Energy Information Administration, 2016d). 

3.5 Greater Sage-Grouse 

The SIR identified 3 candidate species that were added to the U.S. Fish and Wildlife Service 

(USFWS) county list since the 2002 FEIS. The SIR also confirmed that no suitable habitat for the 

additional species is found in the Project Area. For Forest Service sensitive species, the SIR 

identified the western boreal toad as the only species with suitable habitat within the lease area. 

The SIR concluded that the FEIS amphibian analysis was complete and no additional analysis was 

necessary. The greater sage-grouse (Centrocercus urophasianus) is the only species carried 

forward for analysis. 

The BLM and Forest Service have identified Priority Habitat Management Areas and General 

Habitat Management Areas for greater sage-grouse. The Project Area is within the greater sagegrouse Carbon Biologically Significant Unit (Figure 8). In addition, BLM and Forest Service have 

mapped sagebrush focal areas, which are stronghold areas that contain the highest breeding 

densities of greater sage-grouse and highest quality sagebrush habitat. Both the Land Management 

Plan Amendments and Approved Resource Management Plan Amendments identify management 

decisions that apply to these habitat management areas on National Forest or BLM-administered 

land, such as limiting or eliminating new disturbance in Priority Habitat Management Areas and 

sagebrush focal areas, and minimizing surface disturbance in General Habitat Management Areas. 

The Project Area is partially located in a Priority Habitat Management Areas but is not within a 

sagebrush focal area. Approximately 78.3 acres of the Priority Habitat Management Areas falls 

within the Project Area (22.8 acres of which are located on National Forest, and 55.5 acres are on 

private land).The closest lek is approximately 9.8 miles to the northeast around Scofield Reservoir. 

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Figure 8 - Sage Grouse Priority Habitat Management Areas 

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There is no nesting/brood rearing habitat or winter habitat in the Project Area (UDWR, 2014) This 

was confirmed in a letter finding from the Utah Division of Wildlife Resources dated October 9, 

2014: “...classified as non-habitat for greater sage-grouse (Utah Division of Wildlife Resources, 

2014). 

The Forest Service and the BLM, as cooperating agencies, engaged in a collaborative, landscapelevel conservation effort for greater sage-grouse to conserve the species’ habitat and avoid the 

continued decline of populations. The process was in response to the 2010 USFWS finding that 

greater sage-grouse was warranted but precluded for listing as a threatened or endangered species 

under the Endangered Species Act (USFWS, 2010). The conservation effort culminated in the 

incorporation of greater sage-grouse conservation measures into agency land use plans. In 

September 2015, the Forest Service issued a Greater Sage-Grouse ROD for Idaho/Southwest 

Montana, Nevada, and Utah and Land Management Plan Amendments for these states (US Forest 

Service, 2015). In September 2015, the BLM issued a ROD and Approved Resource Management 

Plan Amendments for the Great Basin Region (including the Utah subregion) (BLM, 2015c). The 

Land Management Plan Amendments provide direction and guidance for management activities in 

sage-grouse habitat management areas on National Forest and the Approved Resource 

Management Plan Amendments provide direction and guidance for activities on lands administered 

by the BLM, including split-estate lands with BLM subsurface mineral rights. 

3.6 Water Resources 

3.6.1 Surface Water 

The Project Area lies within the Right Fork Huntington Creek Sub-watershed (Hydrologic Unit Code 

140600090102) within the Huntington Creek Watershed (HUC 1406000901) (Figure 9). The 

Huntington Creek watershed is a tributary of the larger San Rafael River drainage which in turn 

drains to the Green River approximately 80 miles below the Project Area. Less than 6 percent of the 

southwestern project boundary lies in the Gooseberry Creek Sub-watershed (140600070201), 

which is part of the Price River drainage (Figure 9). The Price River flows to the Green River 

approximately 60 miles below the Project Area. Upper drainages in the Price River watershed drain 

first into Mud Creek, which empties to the Scofield Reservoir. Eccles Creek is the largest. 

Perennial streams in the Project Area have been identified in Boulger, Flat, Swens, and Little 

Swens canyons; and in the upper portions of Huntington Canyon (Figure 9). The geomorphology of 

these sub-basins was described in detail in the 2002 FEIS (US Forest Service, 2002a). Stream 

flows are typical of intermountain regions, with relatively large flow volumes from snowmelt 

occurring in the spring and early summer months. As the spring runoff decreases in the later 

summer months, discharges drastically decrease to baseflows supported by active zone 

groundwater systems (Petersen Hydrologic, LLC, 2014a). 

Electric Lake lies within Huntington Creek. The upper reaches above the dam of Electric Lake lie 

within the current Skyline Mine lease areas, but not within the footprint of the Project Area. 

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Figure 9 - Watershed Boundaries 

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Many streams in the Project Area are gaining which suggests that perching layers identified 

beneath the systems effectively prevent streamflow losses to deeper groundwater systems in the 

subsurface (US Forest Service, 2002a). A study conducted by Canyon Fuel Company, LLC in 

Burnout Canyon, a tribuary to Huntington Creek, concluded that there is little hydraulic connection 

between the perched perennial stream and their associated active shallow groundwater systems 

and the deeper groundwater systems, which may be intersected by mining. The study stated that 

“no perceptible or quantifiable diminutions in peak flow or baseflow discharge rates are apparent” 

(and the shallow groundwater system that sustains them) due to multiple-seam longwall mining 

occurring beneath the watershed (Petersen Hydrologic, LLC, 2014a). Monitoring was done in 8 

stream locations. The study indicates that the Skyline Mine workings (and deeper groundwater 

system) below Burnout Canyon, would not affect discharge rates because streams are hydraulically 

isolated from the perched stream channel – shallow groundwater system. 

Spring and seep surveys were conducted in the Project Area during low-flow conditions in the fall of 

1997 and during high-flow conditions in the spring of 1998. Monitoring of springs and seeps during 

both low- and high-flow conditions were continued until 2000. Monitoring for flow and water quality 

for baseline conditions was resumed in 2006 and has continued to present, including 18 spring 

monitoring sites on 14 springs. The monitoring indicates that the potential for contamination, 

diminution, or interruption of groundwater systems is remote because the underground mining 

would intersect the inactive-zone groundwater in perched systems. These perched systems do not 

have any known uses or State appropriations (Peterson Hydrologic, LLC 2014a). 

3.6.2 Groundwater 

The geologic formations in the Project Area generally consist of interbedded shale, mudstone and 

siltstone that are laterally discontinuous. This discontinuity results in a lack of heterogeneity that 

affects water storage and transmission. In effect, groundwater flow is discontinuous and not 

generally transmitted great distances, either vertically or horizontally (Petersen Hydrologic, LLC, 

2014a). 

The shallow groundwater – surface water systems primarily consist of colluvial/shallow bedrock or 

alluvial deposits with enhanced weathering and fracturing. These systems occur in the thick soil 

mantle and slope wash colluvial deposits or higher permeable alluvial deposits. The relatively lowpermeability horizons in bedrock formations hinder appreciable migration of groundwater to deeper 

stratigraphic horizons and create perched surface water conditions (Petersen Hydrologic, LLC, 

2014a). 

An additional formation called the Star Point Sandstone Formation does not outcrop in the Project 

Area, but lies both above (in some areas) and beneath the mining zones of the Skyline Mine. The 

Star Point Sandstone Formation is massive, moderately fine- to medium-grained sandstone that is 

moderately well consolidated. Individual sandstone units are separated in portions of the area by 

partings of low-permeability siltstones or mudstones. Studies have indicated that groundwater 

flowrates in the Star Point Sandstone Formation are low with hydraulic conductivities measured in 

minimally-fractured zones immediately south of the Project Area of 4.8 x 10-8 to 7.4 x 10-8 feet per 

second (Petersen Hydrologic, LLC, 2014b). However, in the Skyline Mine, inflows of groundwater 

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have occurred that are associated with fault and/or fracture systems (secondary permeability) 

encountered in the Star Point Sandstone Formation. 

There are no known uses of the Star Point Sandstone water in the vicinity of the Project Area 

(Peterson Hydrologic, LLC 2014a). This is likely because of the extremely low primary hydraulic 

conductivity and the lateral discontinuous nature of the deep groundwater systems. 

3.6.3 Surface and Groundwater Quality 

Water quality results from the spring and seep monitoring program within the Project Area 

(Petersen Hydrologic, LLC, 2014a) show the shallow groundwater are low in total dissolved solids 

(TDS) (i.e. salts) and is of the calcium-bicarbonate geochemical type. This geochemical type is 

consistent with the dissolution of carbonate minerals and buffers against oxidation of sulfide 

minerals eliminating the potential for acid mine drainage or metal leaching. 

The water quality of surface water drainages in the Project Area is similar to that observed in the 

springs and seeps that discharge from the perched shallow groundwater systems. The water quality 

is also of the calcium-bicarbonate geochemical type with low TDS concentrations (Petersen 

Hydrologic, LLC, 2014a). The Probable Hydrologic Consequences report (Petersen Hydrologic, 

LLC, 2014a) also concluded that the stream water quality compositions are generally the same 

because the streamflow is supported by the active shallow groundwater perched system. 

Groundwater quality, including that of the Star Point Sandstone, meets State of Utah drinking water 

standards for the parameters that have been analyzed. Untreated spring water is used at cabins 

and campgrounds. 

3.6.4 Mine Dewatering and Discharges 

Eccles Creek drains to Mud Creek and then to the Scofield Reservoir. The Scofield Reservoir is 

approximately 2,800 acres with a capacity of approximately 74,000 acre-feet (US Forest Service, 

2002a). Water produced in the underground workings of the Skyline Mine has historically been 

discharged into Eccles Creek just below the Manti-La Sal National Forest boundary. The discharge 

is permitted by a UPDES permit (UT0023540) (DWQ, 2015). The outfall which discharges to Eccles 

Creek is both the continuous pumped groundwater and storm water runoff from the mine. Because 

the mine water is comingled with storm water, the discharge is run through a small sedimentation 

pond as a best management practice. The water quality in Eccles Creek is monitored above the 

discharge outfall and at the point source of discharge as specified in the UPDES permit, included in 

the mine permit. Effluent limitations were established for total effluent flow, iron, total suspended 

solids, total dissolved solids, dissolved oxygen, pH, oil and grease, and whole effluent toxicity. 

Before 1999, very little water was intercepted by underground mining. Small quantities of water 

were sometimes intercepted in some of the Skyline Mine workings, while adjacent workings were 

dry. The combined water discharge from the Skyline Mine was generally less than 1,000 gallons per 

minute and was typically a few hundred gallons per minute (Petersen Hydrologic, LLC, 2014a). 

Mining operations progressed to the southwestern portion of the Skyline Mine beginning in 1999, 

where appreciably more groundwater was intercepted. The primary source of the groundwater was 

upwelling from intercepted faults and fractures in the Star Point Sandstone Formation, which 

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underlay the Skyline Mine workings. In 2001, Canyon Fuel Company, LLC mined through a more 

significant fault which resulted in higher flows into the Skyline Mine workings and increased 

discharges to the Eccles Creek outfall. Groundwater inflows peaked in 2003 with discharges 

exceeding 8,000 gallons per minute (Petersen Hydrologic, LLC, 2014b). As a result of these 

increased flows, a groundwater pumping well (JC-1) was drilled and completed in a fracture system 

of the Star Point Sandstone Formation to depressurize this section of the formation. Water is 

pumped from this well and discharges to Electric Lake. Pumping rates have varied between 2,000 

and 4,000 gallons per minute and continue to this day. Mining in this area was completed in 2003 

and water levels in the Skyline Mine pool were allowed to rise and flood that portion of the Skyline 

Mine. By September 2004, the water levels in the southwest Skyline Mine pool had risen to the 

8,350 foot level where it is maintained for current mining activities by pumping discharges to the 

Eccles Creek outfall. The pumping from the southwest pool decreased with additional head on the 

inflows with the discharge rates decreasing to a present day rate of approximately 1,880-2,000 

gallons per minute. 

Groundwater discharge supports base flow to creeks that are classified as “High Quality Waters – 

Category 1” by the State of Utah, Utah Administrative Code (UAC) R317-2 (Petersen Hydrologic, 

LLC, 2014a). 

3.7 Soils 

County soil survey data are not available for the Project Area (NRCS, 2016). However, based on 

similar elevation, topography, and vegetation, soils within the Project Area and Skyline Mine area 

can be expected to be similar to those found in a mapped area located immediately east of 

Huntington Creek. The 4 soil map units occupy the majority of this area are: 

• Curecanti family – Pathead complex (Map Unit 23); 

• Senchert family – Senchert complex (Map Unit 105); 

• Trag – Croydon complex (Map Unit 118); 

• Uinta – Toze families complex (Map Unit 125); 

The Curecanti family – Pathead complex is found on convex and linear mountain slopes and 

canyons with slopes ranging from 40 to 70 percent located at elevations between 6,980 to 8,970 

feet above sea level. These soils consist of loams and sandy loams derived from sandstone and 

shale colluvium. In areas where Curecanti family soils are present soil depths exceed 60 inches. 

Pathead soils are shallower, extending between 20 and 40 inches in depth before encountering 

lithic bedrock. 

The Senchert family – Senchert complex is found on convex mountain slopes with slopes ranging 

from 30 to 50 percent located at elevations between 7,980 to 9,070 feet above sea level. These 

soils consist of loams, clay loams, and sandy loams derived from sandstone and shale alluvium and 

colluvium. These soils are between 20 and 40 inches deep and overlie lithic bedrock. 

The Trag – Croydon complex is found on convex mountain slopes with slopes ranging from 30 to 60 

percent located at elevations between 7,580 to 9,470 feet above sea level. These soils consist of 

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loams and clay loams derived from sandstone and shale alluvium and colluvium. In areas where 

Trag soils are present soil depths exceed 60 inches. Where Croydon soils are present, soil depths 

extend between 40 and 60 inches before encountering bedrock. This map unit is not prime 

farmland. 

The Uinta – Toze families’ complex is found on convex mountain slopes with slopes ranging from 

35 to 70 percent located at elevations between 7,780 to 9,570 feet above sea level. These soils 

consist of clay loams, sandy loams, and silty loams derived from sandstone, shale, and siltstone 

colluvium. Areas where Uinta soils are present range from 40 to 60 inches before encountering 

bedrock. Toze soils are deeper and extend below 60 inches in depth. 

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Chapter 4
 

Direct and Indirect Impacts
 

4.1 Introduction 

This chapter describes the direct and indirect impacts in sufficient detail to understand a change 

from the present as a result of the alternatives considered in detail (OSMRE, 1989). Direct impacts 

are those that are caused directly by the proposed activities at the same time and place (40 CFR 

1508.8(a)). Indirect impacts are those that are removed in time and place (40 CFR 1508.8(b)). 

Impacts may be short-term (also referred to as temporary) or long-term. Short-term impacts 

generally occur for a short period during a specific time. Long-term impacts would generally last the 

life of the project and beyond. Impacts are also described by level of significance 

•	 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 impact that could cause an 

insignificant change or stress to an environmental resource or use.
 

• No Impact: No discernible or measurable impacts. 

Impacts are adverse unless specifically stated that they are beneficial. 

The determination of impacts varies for each resource and the context of the specific Proposed 

Action. When available, the analysis applies quantitative thresholds to determine the level of 

significance. Other issues have been analyzed qualitatively. 

Direct and indirect impacts from the Proposed Action would result from mining the coal, subsidence, 

water use and discharge, extending the life of the Skyline Mine by 9 to 12 years, coal 

transportation, and coal combustion. Direct and indirect impacts are analyzed in this EA for 

topography and geology from subsidence (to support the understanding of the impacts on water 

and soils), water (to update monitoring data), air quality and climate change (criteria pollutants and 

GHG), social and economic (environmental justice populations and updated employment and tax 

revenue), greater sage-grouse, and soils. The analysis of other resources is adequately addressed 

in the previously completed Flat Canyon Coal Lease Tract FEIS (US Forest Service, 2002a), its 

ROD (US Forest Service, 2002b), and the associated SIR (US Forest Service, 2013). The analysis 

in this EA tiers to the 2002 FEIS (40 CFR 1502.20) The 2002 FEIS, the Forest Service and BLM 

RODs, SIR, and BLM’s Determination of NEPA Adequacy (see Section 1.2) are incorporated by 

reference (40 CFR 1502.21). 

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4.1.1 Summary of Direct and Indirect Environmental Impacts 

Table 14 summarizes and compares the potential direct and indirect environmental impacts 

associated with the Proposed Action and the No Actions. 

Table 14 - Comparison of Direct and Indirect Impacts 

Resource Proposed Action No Action 

Topography and 

Geology 

Direct impacts on topographical changes 

or horizontal tension fractures from 

subsidence would be negligible and longterm. There would be no indirect impacts. 

No direct or indirect long or short 

term impacts on topography. 

Air Quality and Climate 

Change 

Emissions of Criteria 

Pollutants 

Impacts on emissions of criteria pollutants 

would be negligible and long-term. 

Although is it possible to calculate the 

direct emissions of criteria pollutants from 

mining and processing coal under the 

Proposed Action, they would not be 

discernable or measure at any of the 

regional monitoring locations. Indirect 

effects would be negligible and long-term, 

remaining below levels as allowed under 

the current approval order. 

There would be no direct 

impacts. Indirect impacts would 

be negligible and short-term, 

ending in 2018. 

HAPs There would be negligible long-term 

impact from the emission of HAPs. There 

would be negligible, long-term impact 

from the emission of mercury 14 pounds 

per year, or 166 pounds of mercury for 

the probable maximum total 47 million 

tons of federal and private coal. 

There would be no direct 

impacts. Indirect impacts would 

be negligible and short-term, 

ending in 2018. 

GHG The direct emission of GHG would be 

negligible and long-term based on the 

measured emissions. GHG effects on the 

climate are negligible and long-term. 

CO2e from rail transport would be 

negligible and long-term, 36,476 tons per 

year for 9 to 12 years. 

There would be no direct 

impacts. Indirect impacts would 

be negligible and short-term, 

ending in 2018. 

Social and Economic Continued mine operation would extend 

320 jobs at the mine and an 

undetermined number of support service 

jobs for 9 to 12 years. Impacts would be 

considered minor, beneficial, and longterm. 

320 jobs at the mine and an 

undetermined number of 

associated jobs in the 

community would be end with 

mine closure in 2018. No 

royalties would be paid to the 

federal, state, or local 

governments. Industries to which 

Skyline Mine contributes 

indirectly would experience a 

decline in business and 

associated revenue. Impacts 

would be major and long-term. 

Greater Sage-Grouse No direct or indirect impacts are expected 

as Proposed Action concerns continuation 

of underground mining. Subsidence 

There would be no direct or 

indirect impacts. 

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Resource Proposed Action No Action 

impacts to Priority Habitat Management 

Areas would be negligible and not likely to 

be perceptible to sage grouse. 

Water Resources 

Surface Water Direct impacts to surface water from 

subsidence would be unlikely, as an 

adequate overburden exists between the 

surface water and the mining void. 

Additionally, overburden consists of 

bedrock formations with very low 

permeability. Surface water resources 

from potential subsidence cracks are not 

anticipated or would be negligible and 

long-term. Minor, short-term impacts on 

stream flow would continue. Additionally, 

based on past history, impacts on water 

quality of surface waters, groundwater, or 

springs would be negligible and shortterm. 

There would be no direct 

impacts because mining the Flat 

Canyon Lease would not occur. 

Indirect impacts would be 

negligible and short-term lasting 

until 2018 when mining would 

cease. 

Groundwater Additional mining in the Project Area 

would not result in any long-term or shortterm impacts on groundwater flow. No 

indirect impacts on groundwater are 

anticipated. 

There would be no impact on 

groundwater. 

Soils There would be no surface disturbance. 

Subsidence may cause minor cracks and 

larger openings where potential soil loss 

could occur. Direct impacts on soils would 

be negligible and short-term. Indirect 

impacts from ongoing mining operations 

would be minor and long-term until 

reclamation is achieved. 

There would be no direct 

impacts. Indirect impacts from 

current ongoing mining activities 

would be minor and long-term 

until reclamation is achieved. 

Resource mitigation measures can be found in the Flat Canyon Coal Lease Tract FEIS (US Forest 

Service, 2002a) and this document does not offer additional mitigation measures. 

4.2 Topography and Geology 

4.2.1 Proposed Action 

A probable maximum of 42 million tons of mineable coal would be recovered from federal lands and 

another 5 million from private land through underground mining with the approval of the mining plan 

modification. Removal of the coal would affect the geologic structure in the Project Area. 

4.2.1.1 Direct Impacts 

Surface subsidence from extraction of the underground coal seams, would result in changes to 

topography depending upon rock strength, discontinuities, stress, thickness, and types of 

overburden, topography, mining methods and orientation, and the thickness of the coal seam 

extracted. Models (adjusted to local conditions based on monitoring) developed adjacent to the 

Project Area have improved the accuracy of subsidence predictions. Skyline Mine predicted the 

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subsidence associated with the Flat Canyon Federal Coal Lease Tract UTU-77114 to be a 

maximum of 2 feet (Canyon Fuel Company, LLC, 2015).The lease includes a stipulation that 

requires mining to be done in a manner that prevents surface subsidence that would cause 

hazardous conditions, result in damage to existing surface structures, or damage the flow of 

perennial streams (BLM, 2015d). 

The likelihood that horizontal tension fractures from subsidence would develop is low, as the 

majority of mining would be conducted in single-seam mining. Observations of subsidence at the 

Skyline Mine from past mining have not found large tension fractures to be common and those were 

mitigated by filling the cracks or recontouring. Section 4.5 further discusses the Probable 

Hydrologic Consequences report (Petersen Hydrologic, LLC, 2014a), which presents information 

supporting the low likelihood of significant subsidence to occur. Therefore, impacts to topography 

due to subsidence would be negligible and long-term because subsidence would occur for the 

duration of the project and beyond. 

4.2.1.2 Indirect Impacts 

There would be no indirect impacts on topography and geology under the Proposed Action. 

4.2.2 No Action 

4.2.2.1 Direct Impacts 

Under the No Action, no coal would be recovered from the Flat Canyon Federal Coal Lease Tract 

UTU-77114 or the adjacent private lands with non-federal coal reserves. Even if an underground 

right-of-way were granted through the Flat Canyon Coal Lease Tract UTU-77114 for the purpose of 

mining the private reserves, it is unlikely that it would be economical to develop access tunnels the 

distance needed to reach the small amount of recoverable private coal reserves using the methods 

the Skyline Mine proposes. Subsidence on remaining accessible areas would be negligible; 

therefore there would be no direct long- or short-term impacts on topography. 

4.2.2.2 Indirect Impacts 

There would be no indirect impacts on topography under the No Action. 

4.3 Air Quality and Climate Change 

Direct impacts are those from activities including mining the coal in the Flat Canyon Federal Coal 

Lease Tract UTU-77114, moving the coal to the stockpile and the CH4 emissions in the stock pile 

attributable to the Flat Canyon coal. 

Indirect impacts result from taking coal from the stockpile, processing, and shipping it, as are all 

other mining activities at the Skyline Mine. Indirect impacts include CH4 released from the stockpiles 

attributable to coal mined at the Skyline Mine other than the Flat Canyon coal. Indirect impacts also 

include transportation of the coal from Skyline Mine and coal combustion. 

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4.3.1 Proposed Action 

4.3.1.1 Direct Impacts 

Criteria Pollutants 

Operations and Tailpipe Emissions 

At Skyline Mine, direct mining-related air quality impacts would include fugitive dust emissions from 

coal handling and wind erosion of coal and other material stockpiles. The location, amount, and 

types of emission sources would not change from current permitted operations. The Proposed 

Action would extend these impacts by 9 to 12 years. 

Coal would be mined underground, transported by underground conveyor and stockpiled. Fugitive 

dust from stockpiles is controlled by naturally occurring 8.5 percent moisture content and, when 

moisture content drops below 4 percent, process source emissions are controlled with a filter 

baghouse (HDR Engineering, Inc., 2015). 

The Proposed Action would extend the life of an underground mine and coal storage in stockpiles 

(see Section 2.2), such as it has been since 1981. Emissions associated with permitted sources 

would continue for approximately 9 to 12 years. Skyline Mine is currently operating under Approval 

Order DAQE-AN00092007-03 (DEQ, UDAQ, 2015). As Skyline Mine’s current Approval Order 

covers proposed activities in the Flat Canyon Federal Coal Lease Tract UTU-77114, the UDAQ 

does not anticipate that the mining plan would result in emissions that would adversely affect 

human health or the environment. The proposed modifications would not alter the current 

production limits allowed under the Approval Order. 

Table 15 shows the outcome of the inventory for operations currently permitted under Approval 

Order DAQE-AN00092007-03 (UDAQ, 2015b). An inventory is sufficient to demonstrate compliance 

with the NAAQS (per UDAQ Air Quality Rule R307-410-4) Modelling of Criteria Pollutant Impacts in 

Attainment Areas, because (except for PM10) emission would not come near to the limits 

establishing the need to model emissions. Emissions below these limits are presumed not to pose a 

threat to exceeding the NAAQS and therefore no modeling is required. 

Table 15 - Regulated Pollutants Evaluated for Air Quality Permit 

Pollutant Potential to Emit Facility Total 

(tons/year) 

Requiring modeling per Air Quality Rule R307-410-4(1) 

(tons/year) 

PM10 22.90 5 fugitive,15 non-fugitive 

PM2.5 5.01 NA 

NOx 12.33 40 

CO 10.36 100 

SO2 0.07 40 

VOC 0.68 NA 

Source: (HDR Engineering, Inc., 2015). Operations included in the inventory are, natural gas fired heaters, natural gas 

fired boilers, conveyor transfer points, crushing operations, screening operations, rail/truck loading, stockpiling, stockpile 

conveyor transfer, truck loading, truck traffic, and truck traffic rail load-out. 

(1) http://www.rules.utah.gov/publicat/code/r307/r307-410.htm. 

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The AERMOD model results for potential to emit PM10 is 147 micrograms per cubic meter (μg/m3), 

which is below the NAAQS of 150 μg/m3 (Table 5). The modeled PM10 impact of 99 μg/m3

, 

combined with distant background of 48 μg/m3 (see Section 3.3.1.3) is lower than the applicable 

NAAQS of 150 μg/m3 (Table 5); therefore, the Skyline Mine is in compliance with the standard. 

Fugitive Sources 

Emission sources at Skyline are predominantly fugitive in nature. Sources include conveyor transfer 

points, stockpile storage, truck, and railcar loading. Fugitive sources are included in Table 15. 

There are multiple storage piles at various locations on the mine property, which contribute to 

windblown fugitive emissions. Covered conveyors are used to transport coal around the mine. 

Truck hauling at the mine is only allowed by the air permit when the conveyor system is not 

operational. Calculations of particulate matter emissions from wind erosion of the coal stockpile 

used the factors from EPA. The analysis assumed each stockpile would have a maximum of 5 

percent of the surface disturbed in any 24-hours. Surface disturbance includes surface grading and 

stockpile management. Emissions from placing in or removing coal from the stockpile were 

calculated as transfer point operations. Because the stockpiles are not used for daily coal 

production, this method provides a conservatively high calculation (HDR Engineering, Inc., 2015). 

Calculations of particulate emissions were estimated for the haul roads from the haul trucks 

entering and exiting the mine for coal load-out. There are 3 truck load-outs located at the mine. The 

truck load-outs are comprised of a semi enclosed structure. (HDR Engineering, Inc., 2015). 

Process Emission Sources 

The Skyline Mine includes several process sources of emissions through the mine conveyor 

system, which are included in Table 15. The emission sources consist of 2 crushers, 2 screens, 

multiple storage silos and bins, fifteen natural gas space heater, and 2 boilers. The majority of coal 

produced is directly transferred by conveyor through the system to the rail load-out where it is 

transported offsite after being loaded on to railcars. Dust emissions associated with the process 

emissions are controlled with 5 filter baghouses, 2 at the run of mine silo, one at a crusher, 2 at 

storage silos, and one at a rail load-out (HDR Engineering, Inc., 2015). 

Tailpipe Emissions 

Transportation of coal around the mine is by covered conveyor. Truck hauling at the mine is only 

allowed by the air permit when the conveyor system is not operational. Tailpipe emissions were 

estimated for the haul trucks entering and exiting the mine for coal load-out. There are 3 truck loadout locations located at the mine. The access road to the mine is paved and primarily used by 

employees coming to and from the mine using typical passenger vehicles. 

Total Emissions 

Using the assumptions and processes described above, emissions were calculated for criteria 

pollutants and HAPs (Table 16). This information is summarized from the notice of intent (NOI) to 

Construct (HDR Engineering, Inc., 2015) for a completed project and is assumed represent the 

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maximum direct emissions from mining Flat Canyon. Overall impacts would be negligible and longterm, lasting for 9 to 12 years. There would be no change in the attainment status of the airshed. 

The haul road is primarily unpaved road with the exception the access point from the public road 

that is paved. Emissions were calculated using EPA factors (HDR Engineering, Inc., 2015). Water is 

used as a dust suppressant, which reduces the dust emissions by 75 percent. Trucks will use the 

haul roads at the rail load-out and stoker area which are paved. 

Table 16 - Skyline Mine Criteria Pollutant Emission Calculations (tons per year) 

Source PM10 PM2.5 NOx CO SO2 VOC 

Fugitive 13.29 2.45 NA NA NA NA 

Process 9.61 2.55 12.33 10.36 0.07 0.68 

Tailpipe1 0.019 0.017 0.796 0.225 0.000 0.039 

Total Annual Emissions2 22.92 5.02 13.13 10.59 0.07 0.72 

Source: (HDR Engineering, Inc., 2015)
 

1 Tailpipe Emissions are calculated using EPA Emission facts, Average In-Use Emissions from Heavy-Duty Trucks
 

Table 2 GVW Class VIIIb. Tailpipe emissions are only calculated for the haul trucks that operate onsite.
 

2 Total Annual Emissions will be slightlyhigher than the emissions identified for the facility in the Approval Order with 

the inclusion of Tailpipe emissions. Tailpipe emissions are not estimated in the NOI nor provided in the Approval Order.
 

PM10 and PM2.5 

Particulate matter emissions from wind erosion of coal stockpiles used the factors from EPA. The 

analysis assumed each stockpile would have a maximum of 5 percent of the surface disturbed in 

any 24-hours (Table 16). Surface disturbance includes surface grading and stockpile management. 

Emissions from placing in or removing coal from the stockpile were calculated as transfer point 

operations. Because the stockpiles are not used for daily coal production, this method provides a 

conservatively high calculation (HDR Engineering, Inc., 2015). The stockpile and mine tube stacker 

combined are 7.3 acres. Canyon Fuel Company, LLC provided a PM10 modeling analysis as part of 

their air application package and results indicate that the maximum predicted concentration of PM10 

would total 147 μg/m3, below the NAAQS concentration of 150 μg/m3 (HDR Engineering, Inc., 

2015).The modeling was done using AERMOD version 14134. 

NOx, CO, SO2, and VOC 

In 2015, as part of the air permit, an emission inventory was completed on the mine’s operations 

potential to emit (HDR Engineering, Inc., 2015). NOx, CO, SO2, and VOC emissions were 

estimated for the combustion sources located at the mine (Table 16). These emissions sources are 

comprised of fifteen natural-gas space heaters located at various locations throughout the mine, 

and 2 natural gas-boilers that are used for heating the mine shop building. 

Black Carbon Emission Estimates 

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. 

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Chapter 4 April 2017 Environmental Assessment 

Black Carbon has been calculated as a percentage of PM2.5 emissions associated with the diesel 

fuel combustion of the coal transportation off site (Cai & Wang, 2014). The calculated black carbon 

emissions are based on emissions associated with the diesel haul trucks that transport coal offsite. 

Amounts emitted are not regulated and, therefore, not measured. Black carbon emissions from 

diesel fuel would be negligible as seen in Table 17. 

Table 17 - Black Carbon Emissions (tons per year) from Haul Trucks, Proposed Action 

PM2.5 Black Carbon Ratio Black Carbon Emissions 

0.017 0.56 0.0097 

Source: Table 8. (Cai & Wang, 2014). 

Black carbon and GHG emissions have been linked to climate impacts such as increased 

temperatures. Black carbon is a by-product of incomplete combustion of fossil fuels, biofuels, and 

biomass, and can be emitted from the tailpipes of diesel engines at Skyline Mine. Black carbon is 

an unregulated pollutant. 

Because these negligible impacts on air quality would occur for the duration of the project, they are 

long term. Although is it possible to calculate the direct emissions of criteria pollutants from mining 

and processing coal under the Proposed Action, they would not be discernable or measure at any 

of the regional monitoring locations. 

HAPs 

Utah Administrative Code R307-410-5 requires any source submitting an NOI, which proposes to 

increase HAP emissions, evaluate the emission increase with respect to Acute Emission Threshold 

Values (ETVs) to determine if dispersion modeling is required. The Skyline will not increase HAP 

emissions because no sources of combustion will change from the Proposed Action. The total 

potential to emit of formaldehyde was evaluated with respect to the ETV for formaldehyde in order 

to provide a conservative estimate. Formaldehyde, a HAP, is estimated at 0.002 pounds per hour, 

well below the “worst-case” Acute Emissions Threshold Value of 0.0140. Because the potential 

emissions are lower than the worst-case ETV, no further analysis is required. Likewise, dispersion 

modeling is not required according to the Utah Administrative Code R307-410-5. 

The majority of HAPs emitted would be the result of vehicle use. The major source threshold for 

HAPs is 10 tons per year of any one HAP or 25 tons per year of aggregate HAPs. The Skyline Mine 

would not be categorized as a major source for HAPs because the mine produces a maximum of 

0.23 tons per year of total HAPs (HDR Engineering, Inc., 2015). 

The impacts discussed above would be negligible, long-term from the emission of HAPs because 

they would be at the lower limits of detection. 

GHG 

GHG emissions may be comprised of any combination of emissions of CO2, CH4, N2O, HFCs, 

PFCs, and SF6. GHG emissions are calculated on a CO2e basis per EPA’s Greenhouse Gas 

Reporting Program. GHG emissions may be comprised of any combination of emissions of CO2, 

CH4, N2O, HFCs, PFCs, and SF6. GHG emissions are calculated on a CO2e basis. 

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As presented in Table 16, the proposed action will potentially emit 14,893 tons CO2e per year (from 

space heaters and boilers), which is less than the reference level established in the guidance. 

Consequently the mining plan modification will have no significant impact or impact on GHG annual 

emissions associated with the inventoried sources listed in the Approval Order. 

Each regulated GHG has an associated global warming potential. Global warming potential (how 

much energy the emissions of one ton of a gas will absorb over a given period of time, relative to 

the emissions of one ton of carbon dioxide) was developed to allow for direct comparisons of global 

warming impacts of different gases. CO2 is used as the reference gas and therefore has a global 

warming potential of 1. According to the EPA (EPA, 2016f), CH4, and N2O have global warming 

potentials over 100 years of 28 and 298, respectively. All associated GHG emissions are multiplied 

by each applicable global warming potential and aggregated together to obtain a final value of CO2e 

in units of metric tons. 

The potential to emit CO2e from Skyline Mine operations (HDR Engineering, Inc., 2015) is 14,893 

tons per year. As stated in Section 3.3.2, this level is below the 25,000 metric tons reporting limit 

established by EPA. Based on emission estimates for the Skyline Mine (HDR Engineering, Inc., 

2015), no GHG reporting or permitting would apply because CO2e emissions would be less than 

100,000 tons per year and the mine is not a major source for other pollutants (see Section 3.3.1.2). 

GHG emissions reporting do apply to the facilities where coal from Skyline Mine would be used and 

future GHG permitting could apply for future modifications (if any). Impacts from GHG would be 

negligible and long-term, lasting from 9 to 12 years. 

Climate Change Impacts on the Proposed Action 

According to the U.S. Geological Survey’s (USGS) National Climate Change Viewer3 , climate 

change could produce the following impacts in Sanpete County, UT (USGS, 2016): 

• Annual mean temperature increase of up to 4.5 °F, 

• Annual mean precipitation increase of up to 0.4 inches per day, 

• Annual mean snowfall decrease of up to 0.7 inches per year, 

• Annual mean evaporation deficit increase of up to 0.2 inches per month, and 

• No annual mean changes to runoff. 

The Proposed Action would be expected to be completed by 2028 and therefore would not be 

subject to the full extent of these potential climate change impacts. However, for analysis purposes 

the EA assumes that the maximum annual mean value would be realized during the life of the mine. 

Changes to the temperature, snowfall, precipitation levels, and streamflow (Section 3.3.2.3) could 

impact surface water, subsidence, greater sage grouse, and reclamation activities. 

3The USGS National Climate Change Viewer was run for years 2025 – 2049 using the conservative climate 

change scenario (RCP8.5) which assumes no new climate change regulations or reductions would be 

implemented (USGS, 2016). 

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Surface Water 

In the 10 to 12 year life of the project, natural variation results in dryer or wetter years (see Section 

3.6). Considering the overall climate change timeframe of centuries, it is possible that decreased 

snowpack may be observable locally, or may not during the project timeframe. Likewise, decreases 

in streamflow may be observed, but during the mining dewatering timeframe of 10 to 12 years, mine 

dewatering may compensate for climate change related stream flow reduction, or may have no 

additional influence on streamflow. The Proposed Action would not affect any surface water bodies 

and groundwater sources due to the location of the groundwater formations. Therefore, the 

Proposed Action would also not affect these resources due to climate change. 

Subsidence 

The Proposed Action would not involve any new surface disturbance, therefore, it would not be 

impacted by changes to soil erosion. Also, the USGS National Climate Change Viewer does not 

predict any annual mean changes to runoff therefore it is anticipated that there wouldn’t be any 

impacts from climate change to subsidence. 

Greater Sage-grouse 

The Proposed Action is consistent with the greater sage-grouse Land Management Plan 

Amendments for Utah and the Utah Approved Resource Management Plan Amendments which 

take into account potential climate change impacts on the greater sage-grouse (Section 4.5.1). 

Reclamation 

The post reclamation land use would be wildlife habitat and grazing, consisting of vegetation cover 

of grasses and shrubs. Potential changes to the natural environment, as listed above, could result 

in the need to consider different seed mixes during reclamation to account for the higher 

temperatures and increased precipitation levels. This change in reclamation would be re-evaluated 

before beginning reclamation activities and the Operator would consult with OSMRE and Utah 

DOGM if it resulted in changes to the approved reclamation plan. 

Methane Emissions from Coal Extraction 

CH4 emissions were calculated in the Notice of Intent for Construction (HDR Engineering, Inc., 

2015). Potential sources identified that emit CH4 are natural gas-fired heaters in the rail load-out 

building and the one of the transfer points (BC-13 reclaim). No CH4 emission sources were 

identified for conveyors, crushers, screening, load-out facilities (other than the heaters), truck 

loading, transfer points, or stockpiles, or emissions were not calculated. 

Skyline Mine (Skyline Mine, 2015) reports that in 2015, the direct surface coal extraction at the mine 

released 17.3 tons of CH4. This amount is equivalent to 364 metric tons of CO2e. The CH4 release 

was calculated using samples that were collected at monitoring points located at, Portal No.1 ­

No.5, Trespass Portal, BC-2 Portal, and Winter Quarters Portal. The CO2e from the emissions 

inventory and the methane release from mining totals 15,257 metric tons of CO2e emissions per 

year. 

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Another way to assess the potential impacts on GHG emissions is to use EPA emissions factors 

and the maximum mining rate of 8 million tons per year identified in their air permit. These 

calculated annual emissions are shown in Table 18. These calculations do not represent the mine’s 

actual emissions under current or proposed operations, nor do they represent the mine’s reporting 

requirements. 

The direct emission of GHG would be negligible and long-term based on the measured emissions. 

GHG effects on the climate are negligible and long-term (see discussion above). 

Table 18 - Direct GHG Emissions (metric tons per year), Maximum 8 Million Tons 

Activity CO2 CH4 N2O CO2e 

Truck Transport Load-out 21.5 .005 .0002 21.67 

CH4 Release Post Mining -­ 2,144 -­ 15,008 

CH4 Release Mining -­ 4,288 -­ 107,200 

Total 21.5 6432 .0002 122,229 

4.3.1.2 Indirect Impacts 

Criteria Pollutants 

Operations 

Indirect air quality impacts at the mine complex would include exhaust from combustion sources 

(i.e. trucks, maintenance equipment, and other motor vehicles). Ventilation emissions from the mine 

and coal preparation facility would also occur. These sources would continue to contribute CO, 

NOx, SO2, and PM. However, these emissions would be negligible and long-term, remaining below 

levels as allowed under Skyline Mine’s current Approval Order. 

Precursors of O3 including NOx and VOCs are generated by the combustion of coal. O3 impacts 

from coal combustion are not quantifiable for the project specifically because Skyline Mine ships 

coal to many consumers which change over-time which creates high uncertainties and an inability 

to analyze indirect emissions. Emissions were estimated using EPA AP-42 emission factors for 

Bituminous and Subbituminous Coal Combustion (Table 19). 

Table 19 - Ozone Precursor Emissions Rates Based on Maximum Annual Coal Production 

Coal Combustion Rate (tons per year) NO2 (tons per year) VOC (tons per year) 

8,000,000 29,600 240 

Tailpipe Emissions Sources 

Tailpipe emissions would be the same as the direct impacts. 

Rail Transportation 

Indirect emissions were estimated based on the largest, single, U.S.-based power plant consumer 

of Skyline Mine coal in 2015 as presented in Table 2, the Intermountain Power Project located in 

Millard County, Utah. Intermountain Power Project is used as a representative coal-fired power 

plant to quantify potential indirect emissions. The actual future coal destination as part of the 

Proposed Action is unknown because the distribution of coal from Skyline Mine varies every year. 

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The Intermountain Power Project is owned and operated by Intermountain Power Service 

Corporation. In 2015 Skyline Mine had shipped 909,840 tons of coal to Intermountain Generation 

Station; Intermountain used approximately 5,445,459 tons of coal in 2015 (Energy Information 

Administration, 2016a). The Skyline Mine accounts for approximately 16.7 percent of the total coal 

that was used at Intermountain Power Project in 2015. 

The rail emissions are estimated on an annual shipping rate of 4 million tons per year (Table 20). 

The 4 million tons shipped was used as a conservative estimate. Four million tons per year is an 

approximate average of the amount of coal that Skyline produces annually. The mass of coal per an 

individual railcar is assumed to be 100 tons. A conservative estimate of 110 railcars was used to 

estimate the potential maximum number of railcars that could be associated with the coal train. This 

equates to 11,000 tons of coal per rail shipment. The maximum number of annual shipments is 364. 

It was assumed that 3 engines would be associated with each coal train rated at 4,000 

brake/engine horsepower per engine. 

Table 20 - Railcar Criteria Pollutant Emissions 

Pollutant Emission Factor (grams/brake horsepower-hour)1 Emissions (tons per year) 

PM10 0.015 0.294 

PM2.5 2 0.01 0.285 

NOx 1.00 19.60 

CO 1.28 25.09 

SO2 3,4 Mass Balance 0.0005 

VOC 0.04 0.78 

Black Carbon 5 0.77 0.23 1Unless otherwise noted, these emission factors are from Table 1 of EPA’s Emission Factors for Locomotives dated April 

2009.Tier 4 factors. 

2PM2.5 emissions are estimated to be 0.97 times PM10 emission per EPAs Emission Factors for Locomotives publication 

April 2009 (page 4). 

3Emission (tpy) = annual engine load (bhp-hr/yr) x BSFC (British Thermal Unit/hp-hr) x density (lb/gal) x Fuel S-content 

(ppm S/106) x MW ratio (lb SO2/lb S) / (heating value (Btu/gal) x conversion (lb/ton) 

4SO2 fuel content is 15 ppm; bsfc = 7,000 Btu/hp-hr, heating value of 137,000 British Thermal Unit/gal, density = 7.05 

lb/gal Molar weight ratio = 2.0 lb/SO2/ lb S 

5Appendix 2 of the EPA Report to Congress on Black Carbon 2012 indicates black carbon to be 77 percent of total PM 

https://www3.epa.gov/blackcarbon/2012report/Appendix2.pdf 

6EPA Climate Leaders Greenhouse Gas Inventory Protocol Core Module Guidance, Optional Emissions From 

Commuting, Business Travel and Product TransportMay 2008 

A one-way haul distance was estimated at 163 miles with an assumed maximum speed of 80 miles 

per hour for freight trains. Emissions were calculated for the roundtrip assuming this distance each 

way. Based on this scenario, the maximum annual operating hours of the train is 1,482. The 

emissions were determined on an annual power usage, which are 17 million brake horsepowerhours. 

HAPs 

Indirect HAPs from operations would be the same as the direct impacts. In addition, mercury would 

be emitted from coal combustion. 

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Mercury emissions from burning coal depend on control strategies and equipment used to minimize 

emissions and the quality and characteristics of the coal. The final destination of the Skyline Mine’s 

coal varies annually and frequently includes many different destinations. The indirect mercury 

emissions from combustion of the Skyline Mine coal cannot consider specific control strategies and 

equipment. Instead, indirect emissions were estimated based on the largest, U.S.-based power 

plant consumer of Skyline Mine coal in 2015 as presented in Table 2, the Intermountain Power 

Project. The actual mercury emissions from coal mined from the Flat Canyon Federal Coal Lease 

UTU-77114 will depend on the final destination and emissions control technology and permit 

requirements at those facilities. 

In 2015, approximately 910,000 tons (equivalent to approximately 25 percent of Skyline Mine’s 

2014 production) of Skyline Mine’s coal was shipped to the Intermountain Power Project. Using the 

2015 Intermountain mercury stack test data, the Unit 1 mercury emission factor of 0.156 

pounds/1012 British thermal unit was used in the calculation. Unit 1 will generate more mercury 

emissions than Unit 2 which has a lower sampled emission rate. The 910,000 tons delivered in 

2015 constituted approximately 17 percent of the total coal consumed by the Intermountain Power 

Project. Based on an average annual production at Skyline of 4 million tons (8 billion pounds), the 

mercury emissions from burning 100 percent Skyline Coal in the Intermountain Power Project 

generating stations would be 14 pounds per year, or 166 for the probable maximum total of 47 

million tons of federal and private coal in the Proposed Action. These productions of HAPs impacts 

would be negligible and long-term. 

GHG 

Coal Combustion 

Indirect air quality impacts also occur with coal combustion. Coal-fired power plants have a known 

association with GHGs, mercury, and selenium emissions. 

In 2015, the EPA finalized a rule revising regulations for steam electric power plants. Based on 

technological improvements (particularly at coal-fired plants), the rule sets limits on toxic metals, 

nutrients, and other pollutants (e.g., arsenic, lead, mercury, selenium, chromium, and cadmium) in 

wastewater that can be discharged from power plants. The rule is projected to reduce the amount of 

targeted pollutants by 1.4 billion pounds (EPA, 2015b). 

EPA introduced the Greenhouse Gas Reporting Program in 2010. The program collects GHG data 

from forty-one source categories. Most industries began reporting for 2010; additional industries 

began reporting for 2011. The regulations also provided a standardized means to assess and 

calculate GHG emissions. These calculation methods were codified in 40 CFR Part 98 for the 

calculation of combustion emissions the methods. These emissions calculations are an approved 

method for tabulating GHG emissions for the most common GHGs. The emissions are not 

dependent on emissions location or combustion type and provide both speciated and CO2e 

emissions. CO2e is a quantity that describes, for a given mixture and amount of GHG, the amount 

of CO2 that would have the same global warming potential. 

The EPA provides prepopulated spreadsheets for the calculation of stationary fuel combustion, 

which are based on their approved methodologies for GHG reporting. These spreadsheets were 

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used to assess the total GHG emissions from combustion of the coal produced by mining the Flat 

Canyon Federal Coal Lease Tract. CO2e produced per ton of coal is 1.8846 metric tons. 

By using the CO2 GHG emissions calculation method found in 40 CFR Part 98 Mandatory Green 

House Gas Reporting, Subpart C General Stationary Fuel Combustion, Calculating GHG 

Emissions, Equation C-1, the emissions factor of 95.52 kilograms of CO2 per million British thermal 

unit can be used to estimate emissions assumed from burning bituminous of coal in a power plant 

(Table 21) for the total coal from the Flat Canyon Federal Coal Lease Tract UTU-77114 

(approximately 42 million tons) and the associated 5 million tons of private coal. The values detailed 

in Table 21 represent 3 separate components. The first presents the total GHG emissions from the 

combustion of average annual rate of production (first row). These emissions would occur over the 

life of the mine until 2017. The second represents the maximum annual emissions assuming that all 

mined coal (at the maximum mining rate) is combusted in one year (second row). The third row 

shows CO2 emissions from total consumption of the entire maximum probable amount in the Flat 

Canyon Federal Coal Lease Tract UTU-77114. 

Table 21 - GHG Coal Combustion Emissions, Proposed Action 

Coal Combusted 

(Short Tons) 

CO2 Emissions 

(Metric tons) 

Anticipated annual production range 3 million 

to 4.5 million 

5,653,800 

to 8,480,700 

Maximum allowable under the Approval Order 8.0 million 15,076,877 

Total Federal and Private Coal 47 million 88,576,651 

Tailpipe Emissions 

Tailpipe emissions of criteria pollutants would be the same as the direct impacts. 

Rail Transportation 

Transportation emissions for the indirect emissions were not calculated for the indirect impact of 

coal movement for rail. The transportation distance is not identifiable because the final location of 

the coal varies. Railroad transportation emissions require that the haul distance be used to estimate 

emissions. Indirect emissions were estimated based on the rail distance to the single, largest, U.S. 

based power plant consumer of Skyline Mine coal in 2015 as presented in Table 2 Intermountain 

Power Project. The actual future coal destination varies from year to year and it is uncertain where 

Skyline Mine coal will be consumed. 

Table 22 - Rail Transport GHG Emissions 

GHG Emission Factor (pounds per mile) Emissions (tons per year) 

CO2 0.055 36,147 

CH4 0.0000044 2.87 

CH4, CO2e 71.85 

N2O 0.0000013 0.86 

N2O, CO2e 256.94 

CO2e 36,476 

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GHG Emission Factor (pounds per mile) Emissions (tons per year) 

EPA Climate Leaders Greenhouse Gas Inventory Protocol Core Module Guidance, Optional Emissions From 

Commuting, Business Travel and Product Transport May 2008 

GHG emissions from diesel-fuel trains hauling coal were estimated using the same assumptions 

listed above for the criteria pollutants. The indirect emission of GHG would be negligible and longterm based on the calculated emissions. 

4.3.2 No Action 

Under the No Action, emissions would not be released from within the federal coal lease area or the 

associated private lands as no coal would be recovered. 

4.3.2.1 Direct Impacts 

As the Flat Canyon coal would not be mined and transported, there would be no direct impacts on 

criteria pollutants, HAPs, or GHG from the No Action. 

4.3.2.2 Indirect Impacts 

Permitted emissions from the operations at the surface facilities complex would continue until the 

mine closes in about 2018 and then it would end. Air quality would continue to meet existing permit 

requirements and state and federal standards through the current mining plan for the life of the 

mine. 

Criteria Pollutants 

Under the No Action, direct impacts from coal stockpiling and transportation of non-Flat Canyon 

coal would produce criteria pollutant emissions at current emissions rates. Overall impacts would be 

negligible and short-term, lasting until 2018. 

HAPs 

The indirect impacts on HAPs under the No Action would be the same as those described under the 

Proposed Action except that the impacts would occur for a shorter duration (through 2018). These 

impacts would be negligible and short-term. 

GHG 

Under the No Action, 14,893 tons of CO2e would continue to be emitted from mining activities 

through 2018. This would be a negligible impact. Impacts from rail transport would be the same as 

described under the annual indirect impacts of the Proposed Action. 

Indirect GHG emission impacts from the No Action would be negligible and short-term. 

4.4 Social and Economic 

4.4.1 Proposed Action 

Under the Proposed Action, the Proposed Action would be approved, and operation of the Skyline 

Mine would continue at its current level for up to 9 to 12 additional years. 

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4.4.1.1 Direct Impacts 

Continued mine operation would extend the 320 jobs at the mine (with the exception of small 

variances based on production rates) and an undetermined number of support service jobs for 9 to 

12 additional years. In 2015, Canyon Fuel Company, LLC spent approximately $35,439,177 in 

gross wages including benefits. Approval of the mining plan modification would have a beneficial 

impact on employment and economic revenue in Sanpete, Carbon, and Emery counties. With 

current downsizing in the mine industry, there are several companies that rely on Skyline Mine 

including Badlands, Longwall Mining, Bookcliff Sales, Seetech, Morgantown, and United Central. 

A probable maximum of 42 million tons of federal coal could be recovered at a total value of about 

$1.6 billion, based on the approximate current average value as the coal leaves the mine (which 

does not include shipping) of $40 per ton. Royalties to the Federal Treasury would amount to about 

$134 million, the State of Utah would receive about $67 million, and $33 million could be dispersed 

to the counties including Sanpete, Carbon, and Emery counties. In the past, Skyline Mine has 

averaged $14 million per year in royalty payments. Impacts would be considered minor (because 

they are an extension of the existing condition), beneficial, and long-term. Royalties are not paid to 

the Federal Treasury on the privately owned coal. 

4.4.1.2 Indirect Impacts 

Indirectly, mining plan modification approval would benefit numerous service industries including 

real estate, temporary employment, mining supplies, automotive supplies, office supplies, plumbing, 

heating-and-air conditioning, and construction. Skyline Mine also contributes to student enrollment 

at local schools and funding for social services. 

Social Cost of Carbon 

The EPA and other federal agencies estimate the social cost of carbon (SC-CO2) to calculate the 

climate benefits of rulemakings and for use in cost-benefit analyses of proposed regulations that 

could impact cumulative global emissions. Calculating the SC-CO2 is a way to estimate the 

economic damages associated with an increase in CO2 emissions. The calculated dollar cost of a 

metric ton of CO2e, typically expressed as one million tons in a single year, represents the value of 

damages avoided for an associated carbon emissions reduction. 

According to the EPA: “The SC-CO2 is meant to be a comprehensive estimate of climate change 

damages and includes changes in net agricultural productivity, human health, property damages 

from increased flood risk, and changes in energy system costs, such as reduced costs for heating 

and increased costs for air conditioning. However, given current modeling and data limitations, it 

does not include all important damages. The models used to develop SC-CO2 estimates, known as 

integrated assessment models, do not currently include all of the important physical, ecological, and 

economic impacts of climate change recognized in the climate change literature because of a lack 

of precise information on the nature of damages and because the science incorporated into these 

models naturally lags behind the most recent research. Nonetheless, the SC-CO2 is a useful 

measure to assess the benefits of CO2 reductions.” (EPA, 2016g). 

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While an estimate of the GHG emissions is made, given data and resources available, the net effect 

on global GHG emissions or climate change cannot be made. Given the global nature of climate 

change, calculating the SC-CO2 from an individual project would require assessing the impact on 

the global market for coal and the corresponding global effect on GHG emissions. An estimation of 

the SC-CO2 for this project would necessitate speculation and use of assumptions about (1) the 

global market for various energy sources, (2) future emissions of greenhouse gases, (3) the effects 

of past and future emissions on the climate system, (4) the impact of changes in climate on the 

physical and biological environment, and (5) the translation of these environmental impacts into 

economic costs or benefits on a global scale. 

Although CEQ NEPA regulations allow agencies to use a cost-benefit analysis in a NEPA analysis 

in certain circumstances (40 CFR § 1502.23), it is not required. The CEQ regulation states (in part), 

“...for the purposes of complying with the Act, the weighing of the merits and drawbacks of various 

alternatives need not be displayed in a monetary cost-benefit analysis and should not be when 

there are important qualitative considerations.” Unlike a cost-benefit analysis, the disclosure of 

revenue, wages, jobs, and royalties is primarily a regional economic impact analysis that estimates 

impacts on economic activity, which are not considered benefits or costs. There may be adverse 

environmental impacts from the use of fossil fuels and this EA discloses the impacts qualitatively as 

potential emissions. The analysis in total for all resources compares and discloses the impacts 

without converting them to a monetary value. Without any monetized benefits or costs for other 

resource impacts, monetized estimates of the SC-CO2 would be presented in isolation, without any 

context for evaluating their significance. 

OSMRE did not apply the social cost of carbon protocol in this analysis because the purpose of an 

environmental assessment is to determine whether to prepare an environmental impact statement 

or a finding of no significant impact (43 CFR Part 46 Subpart D). Specific threshold levels for the 

determination of significance based on cost or benefit have not been established and therefore 

would not be useful in determining significance. The Social Cost of Carbon would generate 

numbers that are OSMRE cannot compare to reference point for determining whether the numbers 

are significant. 

4.4.2 No Action 

4.4.2.1 Direct Impacts 

Under the No Action, the life of Skyline Mine would not be extended beyond the current projection 

of 2018. The beneficial impacts described under the Proposed Action would end. 

The probable maximum of 42 million tons of federal coal would not be recovered under the No 

Action. In addition some of the reserves (approximately 5 million tons) are on adjacent private land 

(see Table 3). If the mining plan modification is not approved, none of the reserves could be 

recovered and it is highly unlikely that it would be mined in the future by the Skyline Mine. Access 

from any other location would not be economical due to the costs of developing alternative portal 

facilities on adjacent lands and the small amount of coal in the private reserves. 

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With the closure of Skyline Mine, 320 jobs at the mine and an undetermined number of associated 

jobs in the community would be lost, along with the indirect 1,162 people total. Additionally, no 

royalties would be paid to the federal, state, or local governments. Wages and benefits, Abandoned 

Mine Land fees, royalties, and property tax revenue from mining would be eliminated if mining did 

not continue. The estimated potential revenue to the counties would not be distributed by the State. 

The Permanent Community Impact Board, which has been a major source for infrastructure 

projects in rural counties, would also receive less funding. The No Action constitutes a major, longterm impact to the social conditions and economics of the local area and a lesser impact to the 

State of Utah. 

4.4.2.2 Indirect Impacts 

Without continued operation of Skyline Mine, industries to which the mine contributes indirectly 

would incur a decline in business and associated revenue. These industries include retail, 

accommodations, and real estate. With the loss of 320 high-paying jobs, houses would likely flood 

the market and school enrollment would decline as mine workers and their families leave the area. 

Additionally, with the downturn in the mining industry, local communities would likely need to 

consider raising revenue through other means to maintain the same level of social services. The No 

Action would have a major, long-term impact local businesses, schools, and social services. 

4.5 Greater Sage-Grouse 

4.5.1 Proposed Action 

Removal of the coal would not affect special status plants, fish, and wildlife, including greater sagegrouse, as all mining would occur underground. No surface disturbance would occur. 

4.5.1.1 Direct Impacts 

The Proposed Action would not directly affect greater sage-grouse as all activities would be 

underground. When consenting to new underground coal leases, the Land Management Plan 

Amendments and Approved Resource Management Plan Amendments prohibit the placement of 

surface facilities on federal land in Priority Habitat Management Areas. Because no new surface 

facilities would be located within Priority Habitat Management Areas, disturbance and density limits 

would not apply and the Proposed Action is consistent with the Greater Sage-grouse Land 

Management Plan Amendments for Utah and the Utah Approved Resource Management Plan 

Amendments. Therefore, there would be no impacts on greater sage-grouse. 

4.5.1.2 Indirect Impacts 

No indirect impacts on greater sage-grouse or Priority Habitat Management Areas would occur. 

Estimated subsidence areas (as shown on Figure 8) encompass approximately 18.9 acres within 

the Priority Habitat Management Areas. As the Priority Habitat Management Areas within the 

subsidence zone is minimal and on the edge where subsidence would be reduced there would be 

no impacts because they would not be detectible. As analyzed in the Forest Service’s 2002 FEIS 

and described in Table 4, there would be no impacts on general vegetation due to subsidence. 

Greater sage-grouse use of the Priority Habitat Management Areas would not be altered by 

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subsidence-related surface cracks. If cracks occur, they would be negligible changes to the ground 

surface and would not result in sage grouse avoiding the area. Thus there would be no impact on 

greater sage-grouse. 

There would be no noise impacts on greater sage-grouse because all activity in the Project Area 

would be underground. The closest leks are more than 9.8 miles away. No lek buffers, noise 

restrictions, or seasonal restrictions would be required. Therefore, there would be no indirect 

impacts on sage-grouse. 

4.5.2 No Action 

There would be no direct or indirect impacts on greater sage-grouse because no greater sagegrouse habitat occurs within the current mine subsidence area. 

4.6 Water Resources 

4.6.1 Proposed Action 

4.6.1.1 Direct Impacts 

Surface Water 

Impacts on water resources are evaluated based on the potential for subsidence and mine water 

discharge. 

The geologic conditions, lithologies, and bedrock formations in the Project Area are similar to those 

in the current mine area. The deeper groundwater system of the Star Point Sandstone Formation is 

not in hydraulic connection with the land surface or the shallow alluvial or colluvial bedrock 

groundwater systems which support perennial stream flow and springs. As a result, mining at 

Skyline Mine has not affected surface water flow and additional mining is not expected to result in 

any long-term or short-term impacts on surface water flow. 

If subsidence results from mining activity and causes cracks to form on the surface in an area of a 

perennial stream, there is the potential for surface waters to be diverted, to pond, or for water to 

infiltrate to deeper groundwater systems. Skyline Mine predicted the subsidence to be a maximum 

of 2 feet (Canyon Fuel Company, LLC, 2015). As discussed in Section 3.6.1, mining at the Skyline 

Mine and associated subsidence has not impacted surface water flows. Petersen Hydrologic 

(2014a) reports that the potential for impacts to surface water from the upward migration of tension 

cracks at the Skyline Mine is low for the following reasons: 

•	 The Society for Mining, Metallurgy, and Exploration Mining Engineers Handbook recommends 

a minimum vertical distance between the mine and an overlying waterbody or aquifer be 60 

times the height of the mining void (SME, 2011). Since the mined coal-seams in the Skyline 

Mine are approximately 10 feet, the recommended best mining practices would suggest a 

minimum overburden of at least 600 feet would be sufficient to protect overlying water 

resources. The overburden at the Skyline Mine ranges from 900 to 2,300 feet, suggesting 

impacts to surface water or shallow groundwater systems from upwardly propagating fractures 

are not anticipated (Petersen Hydrologic, LLC 2014a). 

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•	 The bedrock formations which overlie the coal seams and that perch the shallow aquifer and 

perennial stream systems have very low permeability and are discontinuous. As a result, 

these formations are likely not capable of accepting or transporting appreciable quantities of 

water. Additionally, many of these formations contain swelling clays which would naturally 

heal cracks or fractures (Petersen Hydrologic, LLC 2014a). 

•	 The results of Canyon Fuel's longwall extraction beneath Burnout Creek, adjacent to the tract, 

show that obvious detrimental effects to perennial stream-flow are unlikely if these drainages 

are undermined. The geology, overburden and degree of fracturing and faulting are expected 

to be similar to the Burnout Creek area. (US Forest Service, 2002a). 

Figure 10 shows past and predicted areas of subsidence. Because of the geology of the area, 

impacts to surface water resources have not occurred from subsidence phenomena for over 30 

years of mining at the Skyline Mine (Petersen Hydrologic, LLC, 2014a). Appendix B provides 

results of water monitoring. Subsidence-related impacts on water resources are not anticipated with 

approval of the mining plan modification. Because of the stated conditions above, impacts to 

surface water resources from potential subsidence cracks are not anticipated or would be negligible 

and self-healing and long-term. 

Currently, discharges of pumped mine water from dewatering activities to Eccles Creek has been of 

good quality and meets water quality standards for the designated beneficial uses of the surface 

water. The Forest Service’s 2002 FEIS reported that discharges of pumped mine water to Eccles 

Creek improved the water quality in Scofield Reservoir, which was listed in 2000 as an impaired 

water body for meeting water quality standards for phosphorous. Stream water quality and mine 

discharges are monitored under a UPDES permit which would continue through the life of the mine. 

Industrial activities associated with mining have the potential to result in the spillage of fuels, oils 

and grease, or other potentially harmful compounds during equipment maintenance and operations, 

filling of storage tanks and vehicle tanks, or from storage tank leakage. The Skyline Mine operates 

under a Spill Prevention Control and Countermeasures Plan, which specifies site-specific practices 

to prevent, control, and remediate potential spills and pollution from oil based substances. To date, 

no spills have been reported from normal mine activites that resulted in signficant impacts to 

surface or groundwater quality. Practices to manage, mitigate, and report minor incidental spills of 

petroleum products, such as could occur from vehicles are defined in the plan and regulated by the 

EPA. With approval of the Proposed Action, the potential for impacts to stream or groundwater 

quality from potential spills is considered low. 

Spring and seep flow and water quality has been monitored since 1997 with no perceptible impacts 

to water quality (Petersen Hydrologic, LLC, 2014a). According to the Forest Service’s 2002 FEIS, at 

closure surface water flow and quality would return to near pre-mining condition (US Forest Service, 

2002a) 

Based on past history, impacts on water quality of surface waters, groundwater, or springs would be 

negligible and short-term, because impacts from sediment or spills would be individually resolved 

within a few hours or days and water quality standards would continue to be met. 

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As mining at the Skyline Mine progresses westward into the Flat Canyon Lease Tract area and on a 

downward dip, there is the potential to further intercept substantial faults and fractures in the Star 

Point Sandstone similar to those encountered in the early 2000s. Water could discharge from water 

bearing faults and fractures occurring in tongues of the formation immediately below the mine area. 

Therefore, there is the potential for inflows into the Flat Canyon Lease Tract area that are as large, 

or larger, than those previously encountered. This would result in increased pumping and 

dewatering requirements to continue mine operations. 

Increased discharge rates to Eccles Creek could impact stream geomorphology in both Eccles 

Creek and Mud Creek downstream. Early 2000s average discharge rate of 22 cfs did not result in 

observable changes to stream geomorphology (Petersen Hydrologic, LLC, 2014a). However, 

studies have been conducted that show sediments in Eccles Creek would entrain and be 

transported at discharge rates approximating 35 cfs (15,700 gallons per minute). A streamflow 

duration study showed that at a sustained discharge of 35 cfs, the number of sediment-transporting 

days would increase from 7 to 31 days in Eccles Creek and 13 to 20 days in Mud Creek (US Forest 

Service, 2002a). Potential increases to these levels or higher in the average annual discharge of 

these creeks could cause stream bank erosion, widening of the channel, a steepening of the 

channel gradient due to degradation of the substrate, bank sloughing or channel head cutting (US 

Forest Service, 2002a). 

Upon publishing a notice of permit modification, Utah DOGM received comments from area water 

users. The water users raised concerns relative to potential impacts to state appropriated water 

rights and requested an informal hearing. During the hearing, the water users iterated their support 

for the project and the proposed mining within the Flat Canyon Lease; however, they also 

discussed their concerns that mining in the Flat Canyon Lease posed a potential threat to their state 

appropriated water rights. A contributing factor for their concerns was previously alleged impacts to 

Electric Lake Reservoir during the mining of Mine No. 2 in the Skyline Mine in the late 1990s early 

2000s. 

In response to the concerns raised by area water users, Utah DOGM hired a third party contractor, 

Loughlin Water Associates, Inc, to: (1) Review previously produced reports of the Electric Lake 

issue that arose from the mining of the No. 2 mine and provide comments as to the findings of said 

reports and (2) Review the proposed mining plan within the Flat Canyon Lease and determine if 

the proposed water monitoring plan was adequate to detect impacts to the hydrologic balance/state 

appropriated water rights during mining activity within the Flat Canyon Lease. 

The Loughlin Report (Loughlin Water Associates, 2016) concluded that the historical reports did not 

provide conclusive evidence that the mining activity within the Lower O’Connor A-Lower O’Connor 

B Mine No. 2 Mine had produced connectivity between Electric Lake Reservoir and the mine 

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Figure 10 - Subsidence 

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Environmental Assessment April 2017 Direct and Indirect Impacts 

workings. The Loughlin Report did identify deficiencies with the proposed water monitoring plan for 

the Flat Canyon Lease. Loughlin et al. recommended additional water monitoring points are 

established in order to insure that the proposed water monitoring program was robust enough to 

detect potential impacts to Electric Lake and state appropriated water rights. 

Based on its own internal review and the recommendations within the Loughlin Report (Loughlin 

Water Associates, 2016), Utah DOGM identified deficiencies with the proposed water monitoring 

plan and requested additional water monitoring points be established. The Skyline Mine and Utah 

DOGM resolved the identified deficiencies and Utah DOGM approved of the proposed water 

monitoring plan. The additional monitoring and reporting is described in Section 2.3.13. 

Discharge is currently monitored (Petersen Hydrologic, LLC, 2014a). Before dewatering increases 

to discharges above 17 cfs (see Section 2.2.6), the monitoring program would be adjusted to 

document stream geomorphological parameters and characteristics. If needed, energy dissipation 

structures could be constructed to mitigate higher velocities associated with sustained higher 

discharges and prevent impacts to stream geomorphology. Water quality standards in streams that 

receive mine water discharge would continue to be met as a condition of the mine permit. 

Discharge permits are managed by the State of Utah and renewed on a 5 year cycle. Permit 

conditions are modified as needed to adjust to potentially changing conditions in the water quality or 

discharge rate of the discharge. Minor, short-term impacts on stream flow would continue because 

discharge rates will be well below 15,700 gallons per minute (see Section 3.6.2) and monitoring will 

continue. 

Groundwater 

As discussed in Section 3.6.2, mining at the Skyline Mine and associated subsidence has not 

affected groundwater flows (Petersen Hydrologic, LLC, 2014a). The expected overburden will 

generally be greater than 1,000 feet suggesting that impacts on shallow groundwater systems are 

not likely. Based on this past experience, additional mining in the Project Area would not result in 

any long-term or short-term impacts on groundwater flow. 

4.6.1.2 Indirect Impacts 

Surface Water 

Mine dewatering and discharges of groundwater to Eccles Creek creates a minor localized increase 

in stream flow in the Mud Creek watershed. Eccles Creek is well-armored and has shown little or no 

visual indication of erosional impacts (DOGM, 2013). No adverse impacts on water quality are 

being observed in Eccles Creek or Electric Lake, but any possible adverse trends are being 

documented (DOGM, 2013). There are no known uses or allocations of this localized minor 

increase in streamflow or identified impacts to water quality which could affect indirect impacts 

downstream. Consequently, indirect impacts from discharges of groundwater are not anticipated. 

Power plants can emit mercury into the atmosphere with coal combustion. Mercury can affect the 

quality of surface water as it settles into streams and lakes through deposition or precipitation. 

Mercury can go through a series of chemical transformations that convert it to a highly toxic form, 

which may concentrate in fish and birds (Irwin, 2007). However, mercury contamination through 

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Chapter 4 April 2017 Environmental Assessment 

atmospheric deposition (see Section 4.3.1.1) is extremely difficult to determine as atmospheric 

mercury can be derived from any number of local, regional, or global sources. Thus, it is not 

possible to determine how much mercury would be deposited into surface water or where as an 

indirect impact of mining at Skyline Mine. 

Groundwater 

As discussed in Section 3.6, mining and associated subsidence has not impacted groundwater 

flows (Petersen Hydrologic, LLC, 2014a). There would be no impact on groundwater. 

4.6.2 No Action 

4.6.2.1 Surface and Groundwater Flow 

Direct Impacts 

Under the No Action, there would be no additional impacts to surface or groundwater systems. 

Mining would stop in 2018, and mine water discharge would no longer augment the flow in Eccles 

Creek. 

Stream water quality and mine discharge monitoring would continue through the life of the mine. 

Spring and seep flow and water quality have also been monitored since 1997 with no perceptible 

impacts to water quality (Petersen Hydrologic, LLC, 2014a). Therefore, if the mining plan 

modification is not approved there would be negligible and short-term impacts on the quality of area 

surface waters, groundwater, or springs. Additionally, the potential for impacts to area stream water 

or groundwater quality from potential spills from continued operation of mine activites would be 

negligible and short term because spills would be individually resolved within a few hours or days 

and water quality standards would continue to be met 

With no additional mining, and continued mining to the end of the current mining plan, no additional 

impacts to stream channel morphology in either Eccles Creek or Mud Creek would occur. Because 

the potentiometric surface is expected to recover to approximate pre-mining conditions after mining 

ceases, the overlying unsaturated zone should also be expected to recover to approximate premining conditions (DOGM, 2013). There would be no long-term impacts. 

Indirect Impacts 

No indirect impacts from the No Action were identified. If the mine modification plan is not 

approved, indirect impacts associated with power plant coal combustion would continue until 2018. 

After this date, indirect impacts from Skyline Mine would cease; however, power plants would 

presumably obtain coal from other sources. Therefore, there would be no indirect impacts on mine 

dewatering discharges from the no action. 

4.7 Soils 

Impacts on soils are evaluated due to subsidence and past disturbance at the mine site. 

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Environmental Assessment April 2017 Direct and Indirect Impacts 

4.7.1 Proposed Action 

Under the Proposed Action, mining production activity would continue solely underground. No 

changes in mining methods or rates are proposed. 

4.7.1.1 Direct Impacts 

If subsidence results from mining activity and causes cracks or larger openings to form on the 

surface, there is the potential for soil to be lost if it falls into the subsurface either directly or after 

being washed into the opening by overland water flow. As discussed in Sections 3.6.1, 4.2, and 

4.6, the potential for subsidence to occur to such an extent is negligible; also cracks are anticipated 

to self-heal. 

If subsidence does occur, it will likely be limited to a settling of the ground surface resulting in the 

formation of shallow depressions without the formation of tension cracks or larger openings to the 

subsurface (see Section 4.2). If such depressions did form, it will be possible for adjacent soil to be 

washed into the depressions during periods of overland flow if vegetative cover was insufficient to 

prevent soil movement. This would result in an increase in soil depth within the depression and a 

corresponding decrease along its periphery. The extent of any soil movement would be limited by 

the presence of vegetation, frequency and severity of runoff events, and the depth and geometry of 

depressions formed by subsidence. The Flat Canyon Lease contains a stipulation requiring mining 

to be conducted in such a way as to prevent surface subsidence that would create hazardous 

conditions (including landslides) (BLM, 2015d). Impacts on soils would be negligible and short-term 

occurring at the time the longwall panel passes beneath the surface, then the soils will be 

undisturbed by mining allowing for the continuance of natural soil building and/or erosion processes 

to occur. 

4.7.1.2 Indirect Impacts 

Soil within existing soil stockpiles could undergo a reduction in productivity due to loss of soil 

structure, nutrients, and biological function and may also be subject to erosion. Drainage from mine 

site facilities is captured in sediment ponds and discharged after testing for toxicity, per the Mine 

and Reclamation Plan (Canyon Fuel Company, LLC, 2002). Impacts would be limited by best 

management practices such as revegetating the stockpiles until they are ready for use in 

reclamation. 

Mine area reclamation will entail ripping soils regrading to a gradual slope, placing topsoil and 

revegetating to rangeland habitat, per the Mine and Reclamation Plan (Canyon Fuel Company, 

LLC, 2002). The mine also maintains a spill prevention control and counter measures plan to 

prevent and mitigate potential impacts from spilling hydrocarbon based products. Therefore indirect 

impacts would be minor and long-term until reclamation is achieved. 

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4.7.2 No Action 

4.7.2.1 Direct Impacts 

Direct impacts would be the same as indirect. No direct impacts would occur from mining the Flat 

Canyon Federal Coal Lease Tract UTU-77114. 

4.7.2.2 Indirect Impacts 

Indirect impacts on soils from the No Action would be the same as the indirect impacts from the 

Proposed Action, minor and long-term until reclamation of current mining activities are achieved. 

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Chapter 5
 

Cumulative Impacts
 

5.1 Introduction 

Cumulative impacts are defined as “the impact on the environment which results from the 

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

actions regardless of what agency (federal or non-federal) or person undertakes such other actions. 

Cumulative impacts can result from individually minor, but collectively significant actions taking 

place over a period of time” (40 CFR 1508.7). 

5.1.1 Analysis Areas 

The geographic extent of cumulative impacts varies by the type of resources, resource issues, and 

by the intensity and timeframe of the potential impacts. Different spatial and temporal analysis 

areas for cumulative impacts are identified by resource. 

5.1.2 Past, Present, and Reasonably Foreseeable Actions 

Past and present coal mining and exploration activities were for the Skyline Mining Complex, with 

surface facilities located in Eccles Canyon to the north and east of the Project Area. Abundant coal 

reserves have resulted in past and present exploration activities and federal coal tract leasing in the 

region. Other mines in the cumulative impacts analysis area include a small gravel pit outside 

Huntington Creek watershed and a few small gypsum mines downstream from the confluence of 

Huntington Creek and San Rafael River (Galecki, 2016a). Additionally, Carbon County’s oil and gas 

industry produces an average of 67,000 barrels of oil and 73,304,025 thousand cubic feet) of gas 

volume over the last 4 years (Utah Department of Natural Resources, 2016). 

The Project Area and vicinity is a highly used recreation area of the Manti-La Sal National Forest, 

offering camping, hiking, boating, fishing, motorized sightseeing, hunting, snowmobiling, and crosscountry skiing. The cumulative impacts analysis areas encompass canyons in the Project Area 

which provide recreation access: Upper Huntington Creek Canyon, Flat Canyon, Boulger Canyon, 

Eccles Canyon, Little Swens, and Swens Canyon. Recreational attractions in the cumulative 

impacts analysis areas include stream fisheries, reservoirs, roads, trails, developed recreation sites, 

cabins, a girl’s camp, and boat ramp facilities. With current population growth projections and the 

increasing popularity of outdoor recreation, it is likely that recreational use in the Project Area and 

vicinity will increase. 

National Forest System Roads of the Manti-La Sal National Forest have also been used to support 

livestock grazing by private permittees. This activity is ongoing and will likely continue into the 

future. 

Figure 11 Shows past and present mines nearby, as identified in a coal mine dataset from the Utah 

GIS portal that originated from USGS, and the Princess Mine from FindtheData.com 

(FindtheData.com, 2016). 

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Figure 11 - Project Vicinity Coal Mines 

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5.2 Cumulative Impacts 

5.2.1 Topography and Geology 

The cumulative analysis area for subsidence-related impacts is the Project Area plus areas of past 

subsidence and an estimated area of future subsidence, as shown in Section 4.2.1.1. This area is 

of sufficient size to account for the minor and long-term impacts to topography due to subsidence 

from mining the Flat Canyon lease. Subsidence has the potential to affect topography and geologic 

resources and water resources. Reasonably foreseeable actions identified (other surface mining 

operations, recreation and grazing) would not have impacts on topography and geology. 

There would be no incremental increase from the Proposed Action on topography and geology in 

the cumulative effects study area beyond those assessed in the direct and indirect impacts. 

5.2.2 Air Quality and Climate Change 

The cumulative impacts analysis area for air quality encompasses the state of Utah. For air quality, 

similar direct and indirect emissions would be associated with the Flat Canyon Federal Coal Lease 

UTU-77114 (due to implementation of the current air quality permit) are already occurring in the 

local environment. As such, any cumulative air quality impacts from past and present actions are 

reflected in the air quality monitoring data collected in Utah, and the cumulative air quality impacts 

are represented by the baseline air quality conditions described in Section 3.3.1.3. The future 

impacts are also reflected because they are limited by the air permit. 

Utah Air Emission Sources 

Table 23 summarizes the county-by-county data for Utah as compiled every 3 years (triennial) in 

2011 (UDAQ, 2014). This is the most recent inventory available in May 2016. These data include 

point (industrial/commercial), on-road, off-road, area, biogenic (soil decay), and wildfire emissions. 

Table 23 - 2011 Triennial Inventory (tons/year) 

County PM10 PM2.5 NOX CO VOC SOX 

Beaver 2,655 436 2,079 13,876 26,490 75 

Box Elder 10,313 2,121 7,366 40,012 38,771 163 

Cache 10,854 1,647 3,842 22,511 13,437 172 

Carbon 4,676 1,152 7,153 11,116 17,875 8,381 

Daggett 604 94 1,324 3,858 8,386 2 

Davis 7,601 1,807 9,368 38,462 12,718 474 

Duchesne 6,912 1,082 11,934 19,793 57,798 144 

Emery 5,390 1,133 22,212 30,835 36,805 7,246 

Garfield 2,718 506 1,057 23,180 44,848 17 

Grand 1,831 446 3,125 22,149 37,253 27 

Iron 6,178 1,178 4,254 26,643 37,644 167 

Juab 2,846 567 3,319 18,323 26,898 94 

Kane 2,227 358 1,264 22,008 43,727 22 

Millard 7,270 1,889 33,160 35,525 51,878 5,085 

Morgan 2,898 377 2,582 5,964 7,401 385 

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Chapter 5 April 2017 Environmental Assessment 

County PM10 PM2.5 NOX CO VOC SOX 

Piute 838 146 309 6,528 8,932 6 

Rich 1,422 275 547 7,018 8,962 9 

Salt Lake 31,874 6,747 31,941 145,225 35,626 4,208 

San Juan 6,673 952 3,052 36,431 85,753 53 

Sanpete 5,847 791 1,516 10,700 15,802 85 

Sevier 6,757 916 2,092 12,780 18,106 91 

Summit 7,736 1,145 4,466 15,066 18,904 215 

Tooele 8,058 2,360 8,243 37,606 45,444 224 

Uintah 9,547 1,420 12,348 26,282 109,809 228 

Utah 12,551 3,045 14,613 63,421 30,939 426 

Wasatch 3,689 597 1,448 8,705 12,590 16 

Washington 11,644 1,697 6,026 39,318 44,443 92 

Wayne 1,440 192 529 10,747 22,363 26 

Weber 10,332 1,815 6,811 33,034 12,086 222 

Statewide County Totals 193,380 36,892 207,979 787,115 931,690 28,358 

Point Source Portables 86 38 394 163 39 60 

Total 193,466 36,929 208,373 787,278 931,729 28,418 

Source: Table 4 (UDAQ, 2014) Note: This report includes the following disclaimer “This report is intended to provide 

an overviewof Utah’s air quality.This report is published before end-of-year data can be audited and may be subject 

to change.” 

5.2.2.1 Proposed Action 

The analysis above provided direct and indirect effects analysis for GHG emissions (See Sections 

4.3.1.1 and 4.3.1.2). This document does not, however, attempt to translate these emissions into a 

cumulative climate change impact. It is not scientifically possible to determine the impact that would 

result on the global climate conditions from the emissions from this specific proposed action or in 

total from the emissions of other actions. The variables involved in such an analysis would make 

this determination conjectural and not within the rule of reason (40 CFR 1502.22(b)). 

Criteria and HAPs Pollutants 

The Skyline Mine facilities are located in Carbon County and the total emissions for Carbon County 

include the emissions from the Skyline Mine. Table 24 provides the Skyline Mine emission 

contribution to the cumulative total emissions. 

Table 24 - Skyline Mine Direct and Indirect Emissions as a Percentage of the Utah 

Cumulative Total Emissions 

Pollutant PM10 PM2.5 NOX CO VOC SOX 

Contribution to Cumulative Total (percent) 0.49 0.44 0.18 0.10 0.00 0.01 

Source: These percentages are calculated based on the total annual emissions shown in Table 16 divided 

by the Total in Table 23. 

The Skyline Mine direct and indirect emissions already exist and no changes to production are 

proposed for criteria pollutants and HAPs. Cumulative impacts from Skyline Mine-related emissions 

and other regional emissions are included in the monitoring data described in Section 3.3.1.3. 

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Environmental Assessment April 2017 Cumulative Impacts 

Continued mining, operation of mine surface facilities, and associated vehicle traffic would 

contribute to the release of air pollution into the atmosphere at current levels for criteria pollutants 

and HAPs. Increasing recreational use in the area will contribute additional emissions, but the level 

will increase gradually and is unknown. Emissions would remain local in impact and there would be 

no cumulative impacts on larger scale particulate levels. 

5.2.3 Social and Economic 

The cumulative assessment area for impacts to social and economic resources includes Carbon, 

Emery, and Sanpete counties. The resource issues affected by the mining of the Flat Canyon 

Federal Coal Lease UTU-77114 include employment to tax revenue. The Proposed Action would 

not have an incremental increase within the cumulative assessment areas beyond those assessed 

in the direct and indirect impacts. 

Royalties paid to the federal government from coal mined from federal leases is distributed to the 

state where the coal was mined. The state distributes the revenue to the cities, towns, counties, and 

other political subdivisions (school districts, special service districts, etc.). Utah received $116.4 

million in fiscal year 2015 from mineral royalties, including coal, oil, and gas lease royalties (ONRR, 

2016). In Utah the distribution comes through the Permanent Community Impact Fund and the Utah 

Department of Transportation. In fiscal year 2015, the Permanent Community Impact Fund 

distributed $156.6 million through grants and loan (Utah Department of Workforce Services, 2016). 

Mineral Lease Distributions for fiscal year 2015 through the Department of Transportation totaled 

$53.3 million (Utah Department of Transportation, 2016). Carbon County received $5.4 million, 

Emery County received $2.1 million, and Sanpete County received $7.8 million. 

5.2.4 Greater Sage-Grouse 

The Proposed Action would have no incremental increase in the cumulative assessment area for 

Greater sage-grouse beyond those assessed in the direct and indirect impacts. 

5.2.5 Water 

The cumulative impacts analysis area for water is the Right Fork Huntington Creek subwatershed. 

None of the past and present mines shown on Figure 11 are located in this subwatershed. This 

area is of sufficient size to account for the minor and self-healing impacts on water resource due to 

subsidence from mining the Flat Canyon Federal Coal Lease (see Section 4.2.1.1). 

The Cumulative Hydrologic Impact Analysis completed by the Utah DOGM found no evidence of 

material damage from the past mining operations, and no probability of material damage from 

actual or anticipated mining operations. The actual and proposed coal mining and reclamation 

operations have been designed to prevent material damage to the hydrologic balance outside the 

permit areas. (DOGM, 2013). 

The Proposed Action would have no incremental increase in the cumulative assessment area for 

water in the Right Fork Huntington Creek subwatershed from other mines beyond those assessed 

in the direct and indirect impacts. Recreation and grazing have likely caused minor and localized, 

short-term impacts on water quality. Subsidence-related impacts have occurred within the 

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Chapter 5 April 2017 Environmental Assessment 

subwatershed (see Section 5.2.1), but no impacts to surface or groundwater resources have been 

identified and therefore do not contribute cumulative impacts. Impacts from past mining have been 

mitigated in the Trough Springs Ridge area by infilling tension fractures with soil. Subsidence from 

known potential future mining is related to the Proposed Action and addressed in the direct and 

indirect (Galecki, 2016a) impacts in Section 4.5. 

5.2.6 Soils 

The cumulative analysis area for soil-related impacts is the Project Area, plus areas of past 

subsidence, and existing soil stockpiles. Reasonably foreseeable actions identified include 

continued surface mining operations, recreation and grazing which could also increase soil erosion. 

This would occur under both the Proposed Action and the No Actions. There would be no 

incremental increase from the Proposed Action on soil in the cumulative effects study area beyond 

those assessed in the direct and indirect impacts. 

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Chapter 6
 

Coordination and Consultation
 

6.1 Agencies and People Consulted 

The following people or agencies were consulted prior to and during the preparation of this EA: 

• U. S. Forest Service, Price Ranger District 

• U. S. Forest Service, Ferron Ranger District 

• Carbon County 

• Sanpete County 

• Eastern Shoshone Chairperson and Tribal Council 

• Hopi Chairperson and Tribal Council 

• Confederated Tribes of the Goshute Reservation Chairperson and Tribal Council 

• Ute Chairperson and Tribal Council 

• Ute Mountain Chairperson and Tribal Council 

• Pueblo of Zia Governor and Tribal Council 

• Navajo President and Tribal Council 

• Northwestern Band of the Shoshone Nation Chairperson and Tribal Council 

• Paiute Tribe of Utah Chairperson and Tribal Council 

• Pueblo of Jemez Governor and Tribal Council 

• Pueblo of Laguna Governor and Tribal Council 

• Pueblo of Santa Clara Governor and Tribal Council 

• Pueblo of Zuni Governor and Tribal Council 

• Shoshone-Bannock Tribes of Fort Hall Chairperson and Tribal Council 

• Southern Ute Chairperson and Tribal Council 

• Affected Landowners 

• Sierra Club 

• WildEarth Guardians 

6.1.1 Tribal Consultation 

Letters describing the proposed Project were sent to the Eastern Shoshone Chairperson and Tribal 

Council, the Hopi Chairperson and Tribal Council, the Confederated Tribes of the Goshute 

Reservation Chairperson and Tribal Council, the Ute Chairperson and Tribal Council, the Ute 

Mountain Chairperson and Tribal Council, the Pueblo of Zia Governor and Tribal Council, the 

Navajo President and Tribal Council, the Northwestern Band of the Shoshone Nation Chairperson 

and Tribal Council, the Paiute Tribe of Utah Chairperson and Tribal Council, the Pueblo of Jemez 

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Chapter 6 April 2017 Environmental Assessment 

Governor and Tribal Council, the Pueblo of Laguna Governor and Tribal Council, the Pueblo of 

Santa Clara Governor and Tribal Council, the Pueblo of Zuni Governor and Tribal Council, the 

Shoshone-Bannock Tribes of Fort Hall Chairperson and Tribal Council, and the Southern Ute 

Chairperson and Tribal Council on November 3 and 5, 2015. 

The Hopi, Southern Ute, and Santa Clara Pueblo have corresponded with OSMRE and further 

discussions are ongoing. 

6.2 Preparers and Participants 

Table 25 shows a list of the preparers of this EA and those who participated in the preparation of 

this EA from OSMRE. 

Table 25 - List of Preparers 

Organization Name Title/ Project Responsibility 

OSMRE Marcelo Calle Manager, Field Operations Branch 

OSMRE Nicole Caveny Environmental Protection Specialist 

OSMRE Gretchen Pinkham Natural Resource Specialist 

BLM Roger Bankert Minerals Support Supervisor 

BLM Jefferson McKenzie Mining Engineer 

BLM Leonard Herr Air Quality Physical Scientist 

BLM Steve Rigby Assistant Field Manager, Coal 

Forest Service Kyle Beagley Minerals Specialist 

Forest Service Debra Miller Assistant Regional Air Program Manager 

Forest Service Jeffrey Salow Geologist 

Utah DOGM Steve Christensen Utah Division of Oil & Gas, Hydrologist 

Utah DOGM Amanda Daniels Utah Division of Oil & Gas, Hydrologist 

Utah DOGM Dana Dean Utah Division of Oil & Gas, Associate Director of Mining 

Utah DOGM Daron Haddock Utah Division of Oil & Gas, Environmental Manager 

Table 26 shows a list of the preparers of this EA and those who participated in the preparation of 

this EA from the third party consultants Tetra Tech, Inc. 

Table 26. Contractors 

Organization Name Title/ Project Responsibility 

Tetra Tech, Inc. Cameo Flood Project Manager 

Tetra Tech, Inc. Mark Asoian Air Quality 

Tetra Tech, Inc. Lynn Peterson GIS, Cultural, and Editor 

Tetra Tech, Inc. Tim Reeves Water 

Tetra Tech, Inc. Wendy Rieth Wildlife Biologist Sage-Grouse 

Tetra Tech, Inc. Stephen Tartaglia Air Quality 

Tetra Tech, Inc. Michele Weidner Reviewer 

Tetra Tech, Inc. Shane Matolyak Environmental Scientist 

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References
 

Arabasz, W. J., Nava, S. J. & Phelps, W. T., 1997. Mining seismicity in the Wasatch Plateau and 

Book Cliffs Coal Mining Districts, Utah. USA. Overview and update. 4th International 

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BLM, 2008. Proposed Resource Management Plan and Final Environmental Impact Statement. 

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4.17.3-1A. Revision 9. September 25, s.l.: s.n. 

DEQ, DAQ, 2015. Approval order: Modification to approval order dAQE-AN0092007-03 to increase 

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13, s.l.: s.n. 

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http://www.eia.gov/forecasts/steo/report/renew_co2.cfm?src=Environment-b1, Washington DC: 

US Departpment of Energy. 

Energy Information Administration, 2016a. BETA. Coal Data Browser. Skyline Mine No.3 2014. 

Available online: https://www.eia.gov/beta/coal/data/browser/#/shipments/mine/4201566, 

Washington DC: US Departpment of Energy. 

Energy Information Administration, 2016b. BETA Coal Data Browser. Skyline Mine No.3 production. 

Available online 

http://www.eia.gov/beta/coal/data/browser/#/mine/4201566?freq=A&start=2001&end=2014&cty 

pe=linechart<ype=pin&pin=&maptype=0&linechart=COAL.MINE.PRODUCTION.4201566-BITUND, Washington, DC: US Department of Energy. 

Energy Information Administration, 2016c. Total Energy. Monthly review. Avaiable onine 

http://www.eia.gov/beta/MER/index.cfm?tbl=T02.01#/?f=A&start=200001. Accessed May 22., 

Washington DC: US Departpment of Energy. 

Energy Information Administration, 2016d. What is U.S. electricity generation by energy sources? 

Updated April 1, 2016. Available online http://www.eia.gov/tools/faqs/faq.cfm?id=427&t=3, 

Washington DC: US Department of Energy. 

EPA, 2011. Power plants likely covered by the toxics rule. Available online 

https://www3.epa.gov/mats/pdfs/20111221PowerPlantsLikelyCoveredbyMATS.pdf, s.l.: s.n. 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

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Accessed on March 16, 2016.: Available at 

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EPA, 2014. AQI Air Quality Index. A guide to air quality and your health. Available online 

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EPA, 2015a. Clean Power Plan: State at a Glance. Available online 

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EPA, 2015b. Steam Electric Power Generating Effluent Guidelines - 2015 Final Rule. 

Available at: https://www.epa.gov/eg/steam-electric-power-generating-effluent-guidelines-2015­

final-rule#documents 

[Accessed March 2016]. 

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002. April 15. Available online 

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EPA, 2016e. Black Carbon. Basic Information. February 23. Available online 

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EPA, 2016f. Understanding global warming potentials. February 23. Available online 

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EPA, 2016g. The Social Cost of Carbon, Viewed March 2, 2016: Available at 

http://www3.epa.gov/climatechange/EPAactivities/economics/scc.html. 

FindtheData.com, 2016. FindtheData. 

Available at: http://mines.findthedata.com/l/64125/Princess-Mine 

[Accessed 1 August 2016]. 

Galecki, G., 2015a. Personal communication with Cameo Flood concerning information on 

customers and contracts. Environmental Engineer, Nov. 25th. s.l.:s.n. 

Galecki, G., 2015b. Personal communication with Cameo Flood stating the current Skyline Mine 

employment is 320. Gregg Galecki. Environmental Engineer. November 20, s.l.: s.n. 

Galecki, G., 2016a. Personal communication with Lynn Peterson concerning other mines in project 

vicinity, Jan. 15., s.l.: s.n. 

Galecki, G., 2016b. Email 35 cfs vs. 15 CFS. August 8. Helper, UT: Canyon Fuel Company. 

Galecki, G. E. E. B. R., 2017. Email regarding rail transport. (21 February 2017). 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

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References April 2017 Environmental Assessment 

HDR Engineering, Inc., 2015. NOI to Construct. Canyon Fuel Company LLC Skyline Mines. 

January 19, s.l.: s.n. 

Irwin, B. B. a. M., 2007. Basic Mercury Data & Coal Fired Power Plants. 

Available at: https://www.purdue.edu/discoverypark/energy/assets/pdfs/cctr/outreach/Basics2­

Mercury-Mar07.pdf 

[Accessed March 2016]. 

Jarrett, C., 2015. Sanpete County Commission scoping comment letter. Claudia Jarrett (Chair). 

November 9, Manti, Utah: s.n. 

Loughlin Water Associates, 2016. Groundwater and Surface Water Hydrologic Review. Skyline 

Mine - Flat Canyon Lease Additional. Federal Coal Lease Tract UTU-71144. Carbon and Emery 

Counties, Utah. December, Salt Lake City, Utah: Prepared for the Utah Division of Oil, Gas and 

Mining. 

Melilo, J. M., Richmond, T. (., Yohe, G. W. & eds., 2014. Climate Change Impacts in the United 

States: The Third National Climate Assessment. US Global Change Research Program, 

Washington DC: US Government Printing Office. 

NRCS, 2014. Email correspondence from Joseph Dyer, Area Resource Soil Scientist. Natural 

Resources Conservation Service, US Department of Agriculture. June 19. Price Utah: s.n. 

NRCS, 2016. Web Soil Survey. Natural Resources Conservation Service. 

http://websoilsurvey.nrcs.usda.gov/app/HomePage.htm, s.l.: s.n. 

ONRR, 2016. Office of Natural Resources Revenue. Statisticial Information. Disbursements. 

FY2105 by state., s.l.: s.n. 

OSMRE, 1989. Handbook on Prodedures for Implementing the National Enviornmental Policy Act. 

US Department of the Interior. Available online http://www.google.com/ur . March, s.l.: s.n. 

OSMRE, 1994. Federal Register Notice. 30 CFR Part 944. July 29, Washington DC: Federal 

Register Volumn 59, Number 145 . 

Petersen Hydrologic, LLC, 2014a. Investigation of Groundwater and Surface-Water Systems in the 

Flat Canyon Tract and Adjacent Area; Probably Hydrologic Consequences of Coal Mining in the 

Flat Canyon Tract, Sanpete County, Utah. August 13, Lehi, Utah: Peterson Hydrologic, LLC 

Consultants in Hydrogeology. 

Petersen Hydrologic, LLC, 2014b. Groundwater Conditions in the Star Point Sandstone in the 

Vicinity of the Skyline Mine, 2014. August 18, s.l.: s.n. 

Skyline Mine, 2015. 40 CFR Par FF Methane Emissions Calculations. Adit, Fan, Sharts. , s.l.: s.n. 

The Hopi Tribe, 2001. Letter to Elaine Zieroth, Forest Supervisor, Manti-La Sal National Forest. 

November 12, s.l.: s.n. 

UAC, 2016. Utah Administrative Code R307-405-4. Available online 

http://www.rules.utah.gov/publicat/code/r307/r307-405.htm#T4, s.l.: s.n. 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

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Environmental Assessment April 2017 References 

UDAQ, 2014. 2014 Annual Report. Utah Division of Air Quality. Available online 

http://www.airquality.utah.gov/docs/2015/02Feb/2014DAQAnnualReport_FINAL.pdf, s.l.: s.n. 

UDAQ, 2015a. Utah Air Quality Monitoring Network, Five-year Network Assessment. Utah Division 

of Air Quality, Air Monitoring Section. June. Available online 

http://www.airmonitoring.utah.gov/network/docs/2015/05May/2015FiveYearReport.pdf, s.l.: s.n. 

UDAQ, 2015b. Approval order: Modification to approval order dAQE-AN0092007-03 to increase 

haulage of coal and add staking tube. Approval order number DAQE-AN1000*20001-15. Utah 

Division of Air Quality. July 13, s.l.: s.n. 

UDAQ, 2016. Large Industrial, Oil and Gas Compressor and Gas Plant Emittors (2012 data). 

Available online http://enviro.deq.utah.gov/, s.l.: s.n. 

DEQ, 2015. Permit No. UT0023510. Major Industrial. Autorhization to Discharge under the Utah 

Pollutant Discharge Elimination System. Available online at 

http://www.deq.utah.gov/Permits/water/updes/docs/2010/07Jul/CANYONFUELCO%20LLCSKY 

LINEUT0023540.pdf, s.l.: s.n. 

UDWR, 2014. SGMAs2014. Utah Division of Wildlife Resources. GIS data for Sage-Grouse 

Management Areas (SGMAs), September 15, s.l.: s.n. 

US Census Bureau, 2014. Census Bureau, American Community Survey Office, Washington, D.C., 

s.l.: s.n. 

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Table CA30, Washington, DC: s.n. 

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Table CA05, Washington, DC: s.n. 

US Forest Service, 2002a. Flat Canyon Coal Lease Tract Final Environmental Impact Statement. 

Intermountain Region. January, s.l.: s.n. 

US Forest Service, 2002b. Record of Decision based on the Final Environmental Impact Statement 

for the Flat Canyon Coal Lease Tract (UTU-77114). January, Price, UT: Manti-La Sal National 

Forest. 

US Forest Service, 2013. Supplemental Information Report: Flat Canyon Coal Lease Tract FEIS. 

February 1, s.l.: s.n. 

US Forest Service, 2015. Greater Sage-grouse Record of Decision. Idaho and Southwest Montana, 

Nevada, Utah. Available online http://www.fs.fed.us/sites/default/files/great-basinROD-package­

.pdf, s.l.: s.n. 

US Forest Service, 2017. Letter of concurrence, mining plan modification, Skyline Mine's coal 

mining permit. Signed by Brian M. Pentecost on February 9, Price Utah: Manti-La Sal National 

Forest. 

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References April 2017 Environmental Assessment 

USFWS, 2010. Endangered and Threatened Wildlife and Plants; 12-Month Findings for Petitions to 

List the Greater Sage-Grouse (Centrocercus urophasianus) as Threatened or Endangered. 

Federal Register Vol. 75, No. 55: 13910 – 14014. March 23, s.l.: s.n. 

USGS, 2016. USGS. 2016. National Climate Change Viewer. Accessed: August 15, 2016. Available 

at: https://www2.usgs.gov/climate_landuse/clu_rd/nccv.asp 

[Accessed 15 August 2016]. 

Utah Department of Natural Resources, 2016. Utah Oil and Gas. 

Available at: http://oilgas.ogm.utah.gov/Statistics/Statistics.cfm 

[Accessed 26 April 2016]. 

Utah Department of Transportation, 2016. Fiscal Year 2015 Mineral Lease Distribution. Avaliable 

online http://www.udot.utah.gov/main/uconowner.gf?n=16029631452820105., s.l.: s.n. 

Utah Department of Workforce Services, 2016. Permanent Community Impact Fund Board. 

Available online http://jobs.utah.gov/housing/cib/index.html, s.l.: s.n. 

Utah Division of Wildlife Resources, 2014. Letter to Ahmed Mohson, BLM Field Office Manager 

from Cristopher Wood, Regional Supervisor. October 9, Price, UT: Utah Department of Natural 

Resources, Division of Wildlife Resources. 

Utah SHPO, 2001. State of Utah. Utah State Historical Society. Letter regarding Flat Canyon 

Federal Coal Lease Tract. Case No. 01-1540. Septermber 27, s.l.: s.n. 

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Appendix A 

Outreach Letters and Legal Notices 

Environmental Assessment Appendix A – Outreach Letters and Legal Notices 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

Shaded text indicates a change between draft and final EA A-1 
Appendix A – Outreach Letters and Legal Notices Environmental Assessment 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

A-2 Shaded text indicates a change between draft and final EA 
 

Legal notice published in the Sun Advocate and Emery County Progress on October 13 and 

October 27, 2015, and the Sanpete Messenger on October 15 and October 29, 2015. 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

Shaded text indicates a change between draft and final EA A-3 
Appendix A – Outreach Letters and Legal Notices Environmental Assessment 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

A-4 Shaded text indicates a change between draft and final EA 
Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

Shaded text indicates a change between draft and final EA A-5 
 

 

Appendix A – Outreach Letters and Legal Notices Environmental Assessment 

Legal notice published in the Sun Advocate and Emery County Progress on June 14, and the 

Sanpete Messenger on June 16, 2016. 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

A-6 Shaded text indicates a change between draft and final EA 
Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

Shaded text indicates a change between draft and final EA A-7 
Appendix A – Outreach Letters and Legal Notices Environmental Assessment 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

A-8 Shaded text indicates a change between draft and final EA 
Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

Shaded text indicates a change between draft and final EA A-9 
 

 

Appendix A – Outreach Letters and Legal Notices Environmental Assessment 

Legal notice published in the Sun Advocate and Emery County Progress on June 28 and July 12, 

2016, and the Sanpete Messenger on June 30 and July 11, 2016. 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

A-10 Shaded text indicates a change between draft and final EA 
Appendix B 

Water Monitoring Results 

 

 

 

 

Appendix B – Water Quality Monitoring Results Environmental Assessment 

Average Discharge Rates and Solute Geochemical Compositions for Springs and Streams 

Springs 

Price River springs 

Site Temp 

°C 

pH Cond. 

μS/cm 

Flow 

gpm 

TDS 

mg/L 

Ca Mg Na K HCO3 CO3 SO4 C 

29-138 5.6 7.26 439 24.1 272 83 8.0 2.2 0.0 300 0.0 4.0 3 

32-277 6.1 7.33 257 1.8 170 41 6.8 1.2 0.2 163 0.0 7.8 0.8 

MSS-1 4.9 7.71 374 1.05 228 62 8.5 1.0 0.0 240 0.0 10.0 1.0 

Ave. 5.5 7.4 357 9.0 223 61.8 7.8 1.5 0.1 234 0.0 7.3 1.6 

Price River/Castlegate contact springs 

Site Temp 

°C 

pH Cond. 

μS/cm 

Flow 

gpm 

TDS 

mg/L 

Ca Mg Na K HCO3 CO3 SO4 

29-133 4.0 7.33 324 35.5 193 60 4.8 1.7 0.0 211 0.0 5.3 1.2 

Ave. 4.0 7.3 324 35.5 193 60 5 1.7 0.0 211 0.0 5.3 1.2 

Castlegate Sandstone springs 

Site Temp 

°C 

pH Cond. 

μS/cm 

Flow 

gpm 

TDS 

mg/L 

Ca Mg Na K HCO3 CO3 SO4 

33-268 4.4 7.25 89 1.8 72 14 2.0 1.5 0.0 46 0.0 7.0 2.0 

4-429 6.8 7.39 139 1.7 87 22 4.0 1.0 0.0 85 0.0 2.0 0.7 

8-253 3.6 7.13 136 16.0 86 23 2.5 1.2 0.0 91 0.0 5.0 0.3 

Ave. 4.9 7.3 122 6.5 81 19.7 2.8 1.2 0.0 73.9 0.0 4.7 1.0 

Castlegate/Blackhawk contact springs 

Site Temp 

°C 

pH Cond. 

μS/cm 

Flow 

gpm 

TDS 

mg/L 

Ca Mg Na K HCO3 CO3 SO4 C 

21-222 4.8 7.37 322 7.7 190 49 11.2 1.3 0.0 202 0.0 6.5 0.7 

32-183 3.3 7.23 169 7.7 122 28 5.2 1.5 0.0 117 0.0 5.2 0.7 

32-279 5.5 7.35 321 2.7 225 54 15.0 1.7 0.0 240 0.0 8.5 0.8 

Ave. 4.5 7.3 271 6.0 179 43.7 10.4 1.5 0.0 186 0.0 6.7 0.7 

Blackhawk Formation springs 

Site Temp 

°C 

pH Cond. 

μS/cm 

Flow 

gpm 

TDS 

mg/L 

Ca Mg Na K HCO3 CO3 SO4 C 

28-110 6.0 7.51 340 2.0 208 56 9.8 2.0 0.0 225 0.0 7.0 1.5 

3-290 7.0 8.00 219 14.9 158 39 6.3 2.6 0.43 155 0.07 5.3 2.0 

4-173 4.7 7.45 233 1.1 185 48 9.2 1.8 0.0 195 0.0 5.2 1.5 

5-231 2.9 7.15 206 3.2 138 37 4.3 1.8 0.0 141 0.0 7.3 0.8 

Ave. 5.1 7.5 249 5.3 172 45.1 7.4 2.1 0.1 179 0.0 6.2 1.5 

Groundwater storate tanks 

Site Temp 

°C 

pH Cond. 

μS/cm 

Flow 

gpm 

TDS 

mg/L 

Ca Mg Na K HCO3 CO3 SO4 C 

MST-1 9.6 7.80 369 --­ 200 62 8.0 1.0 0.0 237 0.0 0.0 1.0 

MST-2 8.0 8.20 195 --­ 140 30 2.0 2.0 0.0 112 0.0 0.0 2.0 

MST-3 11.9 7.85 353 8.3 236 58 16.5 1.0 0.0 264 0.0 5.5 1.0 

Creeks 

Site Temp 

°C 

pH Cond. 

μS/cm 

Flow 

gpm 

TDS 

mg/L 

Ca Mg Na K HCO3 CO3 SO4 C 

C-5 7.5 7.85 192 28 141 36 5.8 2.3 0.0 148 0.0 4.3 1.2 

C-6 8.9 8.46 235 240 137 37 6.0 3.0 0.0 132 6.5 5.5 3.5 

C-7 9.4 8.45 261 1,200 139 38 7.0 2.0 0.0 161 2.5 4.0 1.0 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

B-1 
Environmental Assessment Appendix B – Lease Special Stipulations 

Site Temp 

°C 

pH Cond. 

μS/cm 

Flow 

gpm 

TDS 

mg/L 

Ca Mg Na K HCO3 CO3 SO4 C 

C-8 8.1 8.47 267 1,275 150 42 6.5 2.0 0.0 163 3.0 4.5 1.5 

CS-10 7.9 7.72 241 984 143 39 4.9 2.9 0.4 131 0.6 17.9 3.0 

CS-16 8.0 8.39 296 515 183 53 7.4 1.8 0.4 193 1.8 7.8 1.1 

CS-17 7.8 8.37 278 187 173 48 6.8 1.8 0.4 171 1.2 8.3 1.6 

CS-18 10.1 8.47 270 2,067 150 42 7.0 3.5 0.3 156 1.2 7.3 5.5 

UPL-10 9.7 8.07 313 3,120 198 53 8.7 5.7 0.7 177 1.9 13.4 11.7 

Source. Table 3 (Petersen Hydrologic, LLC, 2014a) 

gpm – gallons per minute 

mg/L – milligrams per liter 

μS/cm – Micro-Siemens per centimeter 

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Appendix C 

Draft EA Public Comments and Responses 

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Environmental Assessment Appendix C – Draft EA Public Comments and Responses 

Response to Draft EA Publication 

Legal notices notifying the public of the available Draft EA and FONSI for review and comment 

were published in the Sun Advocate and Emery County Progress on June 14, 2016, and the 

Sanpete Messenger on June 16, 2016. Fifty-nine outreach letters were sent directly to adjacent 

landowners, nearby community leaders, and other interested individuals announcing the availability 

of the Draft EA and FONSI. Twenty-five letters were sent to tribal contacts. Hard copies of the Draft 

EA were sent to public reading rooms as indicated in the legal notices. Legal notices notifying the 

public about an extension to the comment period of the Draft EA and FONSI for review and 

comment were published in the Sun Advocate and Emery County Progress on June 28 and July 12, 

2016, and the Sanpete Messenger on June 30 and July 14, 2016. Outreach letters were sent to the 

adjacent landowners, nearby community leaders, other interested individuals and tribal contacts 

announcing the availability of the Draft EA and FONSI. Hard copies of the Draft EA and FONSI 

were sent to the public reading rooms as indicated in the legal notice. Comments were accepted 

from June 16, 2016, through July 28, 2016. 

Comments on the draft EA in response to the notices of availability included individual comments 

and form letters. OSMRE received 3 individual letters from: the Shoshone Bannock Tribes (Fort 

Hall, Idaho), Mason Bishop (private citizen), and the WildEarth Guardians/Grand Canyon Trust 

(Denver, Colorado). Additionally, a letter campaign resulted in 6,240 submissions of similar form 

letters. On August 4, 2016, WildEarth Guardians/Grand Canyon Trust supplemented their 

comments. 

A total of 6,243 comment letters and emails were received. OSMRE has reviewed and considered 

all comments. 

Comment Analysis 

All comments received were analyzed to identify substantive comments. Comments were 

considered substantive if they resulted in a modification to the EA (to correct information, provide 

additional information, or consideration of additional alternatives) or were specific and warranted a 

response. In addition, all comments (substantive and non-substantive) were categorized into a 

resource area to summarize where the public concerns occur (see Table C.1). 

The purpose of this appendix is to provide responses to substantive comments and characterize the 

public comment concerns. The comment analysis is not used to count votes, but instead helps 

identify the public’s concerns and determine if modifications need to be made to the EA to address 

them. All comments are part of the project record and have been considered in the decision. 

Characterization Summary 

The content of comments were categorized into resource areas and counted. Nearly all of the form 

letters contained similar if not identical comment text. Many people submitted the same form letter 

multiple times. In addition to the 3 separate letters identified above, the form letters were 

categorized and counted. For the purposed of this analysis 6,243 comment submissions were 

received (6,240 form letters and 3 individual letters). Results are shown in the table below. 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification EA 

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Appendix C – Draft EA Public Comments and Responses Environmental Assessment 

Table C.1 - Comments by Resource Category 

Comment Category Number of Submissions 

with this comment 

Percent of total 

comments 

Air Quality and Climate Change 6,241 20% 

Use of Public Lands 6,239 20% 

Exporting Coal 6,239 20% 

Social and Economic 6,242 20% 

General Environmental Concerns 6,241 20% 

Indian Trust Responsibilities and Treaty Rights 1 <1% 

Cultural Resources 1 <1% 

Water 2 <1% 

Compliance with SMCRA and NEPA 1 <1% 

Recreation 2 <1% 

Access 1 <1% 

Reclamation 2 <1% 

Total 31,212 100% 

Summary Comments 

Comment 1: 

Reject Bowie Resources' demands to expand its Skyline coal mine into the Flat Canyon area on the 

Manti-La Sal National Forest. 

Response: 

OSMRE is recommending the selection and approval of the Proposed Action because the impacts 

of approval of the mining plan modification would not have a significant impact on the quality of the 

human environment. The Proposed Action would not violate any known federal, state, local, or tribal 

law or requirement imposed for the protection of the environment, and is consistent with applicable 

plans, policies, and programs. OSMRE’s decision rationale is explained in further detail in the 

FONSI. 

Comment 2: 

We cannot afford to shoulder the costs of more coal mining and more climate destruction. 

Response: 

See detailed response to Comment 14. 

Comment 3: 

The taxpayers will be left paying for reclamation due to bankruptcy of mining companies. 

Response: 

The State of Utah determines the bonding provisions and oversees reclamation under Utah Code 

Annotated 40-10. Bonding in the form of a surety bond ($5,799,000 payable to the State of Utah 

and OSMRE) covers the cost of reclamation in the event the state has to complete the work due to 

Bowie’s financial condition. Determining compliance with the bonding provisions of SMCRA is 

Skyline Flat Canyon Coal Lease Tract Mining Plan Modification EA 

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Environmental Assessment Appendix C – Draft EA Public Comments and Responses 

outside the scope of this EA. Pursuant to 30 CFR 746.13, OSMRE’s recommendation to the ALSM 

for a decision on the mining plan modification is based on separate and distinct actions including 

compliance with NEPA; the findings and recommendations of the BLM with respect to the R2P2; 

and the findings and recommendations of the regulatory authority with respect to the permit 

application. The OSMRE action of determining compliance with SMCRA and other requirements of 

federal laws, regulations, and executive orders is distinguished at 30 CFR 746.13 from OSMRE's 

action to assure compliance with NEPA. 

Specific Comments 

Commenter: The Shoshone-Bannock Tribe 

Comment 4: 

The proposed project is located within the traditional lands of the Shoshone-Bannock Tribes and 

has the potential to negatively impact use of the area and interfere with the Tribes ability to exercise 

inherent and treaty reserved rights on the unoccupied lands of the United States. Article IV of the 

Fort Bridger Treaty reserved the right to hunt on unoccupied lands of the United States. This right 

includes off-reservation hunting, gathering, and performing traditional cultural practices. The Tribes 

continue a subsistence lifestyle to maintain Tribal traditions, improve our health, and return to our 

aboriginal territories. In addition, the Tribes work diligently to ensure the protection, preservation 

and enhancement of those rights for future generations. Please add text that discusses the 

inclusion of Tribal Treaty rights and resources as the OSMRE analysis and determines mitigation 

required for this project. The OSMRE must, to the fullest extent possible, make every effort to 

protect Treaty rights and resources. 

Response: 

OSMRE discussed the cultural reports with and forwarded the cultural reports to the Tribe. The 

proposal is to conduct underground mining and would result in no surface disturbance (see 

individual resource impact summaries in Table 4, particularly wildlife and transportation), therefore, 

treaty rights to hunt on unoccupied lands will not be affected. Thus there would be no impacts on 

hunting, fishing, gathering, performing traditional cultural practices, or continuation of a subsistence 

lifestyle. No additional surface disturbance would occur and access to surface resources would not 

be modified. Executive Order 13175 (2000), Presidential Memorandum on Tribal Consultation 

(2009), Department of the Interior Secretary’s Order 3292, Secretarial Order 3317 (2011), and 

OSMRE Directive 979 (2013) all affirm the direction for recognizing tribal rights in federal programs 

and projects and sets forth policies, procedures, and responsibilities for implementing them. 

Comment 5: 

The Tribes expect the OSMRE to fully protect Tribal rights and interests throughout the project, 

implementing management activities (surveys, inspections, and monitoring) that demonstrate a 

commitment to the federal trust responsibility. In order to make land management decisions for 

resource use on federal lands, the OSMRE must consult with the Tribes to gain an understanding of 

Tribal traditional and contemporary uses of natural resources, location and significance of historical 

and cultural sites, and Tribal customs. Without this information, direct, indirect and cumulative 

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Appendix C – Draft EA Public Comments and Responses Environmental Assessment 

impacts to resources protected under Treaty Rights cannot be determined. Please add text to the 

scoping documents that acknowledges the Federal Trust Responsibility of the OSMRE to the 

American Indian Tribes to protect natural and cultural resources as defined by treaties and other 

laws and policies. 

Response: 

Cultural surveys were conducted for the 2002 EIS (see Table 4). The EIS also discloses that 

subsidence would not affect prehistoric Native American sites. The Shoshone Bannock tribe 

received notification of the project during scoping through the Notice of Intent letter and when the 

EA was available for review through the Notice of Availability letter. OSMRE will continue to meet 

their obligations regarding government-to-government consultation, as will the Forest Service and 

the BLM per Executive Order 13175, Consultation and Coordination with Indian Tribal 

Governments, work with tribes on a government-to-government bases to address tribal trust 

responsibilities, Department of the Interior directives 979, Presidential Memorandum on Tribal 

Consultation (November 9, 2009). 

Comment 6: 

The Tribes request, per Federal regulations, that cultural resource surveys (an archaeological site 

survey and a culturally-sensitive plant survey) be conducted prior to the commencement of work for 

all previously undisturbed areas (trench excavations, off road travel corridors, drill pads and sumps, 

and onsite facility locations) at the Flat Canyon Federal Coal Lease, Skyline Mine, including areas 

of overland travel to get to the site. These surveys must be conducted by qualified personnel and 

the results documented and archived in the project file. Any artifacts, culturally significant sites, or 

other significant findings must be assessed by the State Historic Preservation Office. Heritage 

resources are protected as mandated by the 1966 National Historic Preservation Act, as amended 

(NHPA), 36 CFR 800, the American Indian Religious Freedom Act, the Archaeological Resource 

Protection Act, the National Environmental Policy Act (NEPA), and the Native American Graves 

Protection and Repatriation Act (NAGPRA). 

Response: 

Cultural resources surveys were conducted (see response to Comment 4) and the results were 

approved by the SHPO (see Table 4). These reports have been forwarded to the tribe. No historic 

properties will be affected. No new surface areas would be disturbed under the Proposed or No 

Action Alternatives. Therefore the National Historic Preservation Act, the American Indian Religious 

Freedom Act, the Archaeological Resource Protection Act, and the Native American Graves 

Protection and Repatriation Acts would be met. The EA was conducted to meet the requirements of 

the National Environmental Policy Act, as was the 2002 Final Environmental Impact Statement. 

Comment 7: 

The Tribes do not support the disturbance of natural federal land and resources for this project. 

Therefore, the Tribes request that the proponent, in cooperation with the OSMRE, prepare and 

submit for approval, prior to disturbance, a mitigation/reclamation plan. This plan shall specify full 

restoration of overland routes and timber-cleared areas associated with this project, including the 

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use of native plant species for revegetation, decommissioning temporary roads/travel routes, 

capping/abandoning coreholes, mitigating impacts from housing and sanitation facilities, 

decommissioning all housing and sanitation facilities and their associated impacts, and other 

transportation/use corridors. 

The Tribes urge the OSMRE to actively restore the native plant communities (including those 

defined during the culturally-sensitive plant survey) affected by project activities and require specific 

management protocols for preventing the spread of noxious or invasive species during and after the 

project. Traditional, subsistence and medicinal plants and resources the Tribal members and of 

other tribes, rely upon have often been unduly compromised due to the introduction and invasion of 

non-native plants. 

With regard to the use of hazardous materials at the exploration sites, please require immediate 

notification to the OSMRE of all spills, leaks, and accidental disposal of hazardous 

materials/chemicals. 

The Tribes express concern about the potential impacts to visual resources and wilderness 

characteristics from this proposed exploration and any subsequent mineral discovery and 

development activities which may occur. Please add text to the scoping documents that every effort 

will be made to limit and restore visual resource destruction. 

Water that is to be acquired for drilling/coring activities must be obtained from an approved potable 

water source to avoid introduction of contaminants to the surface and subsurface at the project 

area, in accordance with applicable state regulatory requirements. In addition, any lubrication or 

other drilling products to be used during coring must be approved for use in a potable well in order 

to protect the groundwater resource as a potential drinking water supply. 

After coring is completed, please abandon and close the coreholes per applicable state regulatory 

requirements. 

The Tribes request that all timber cut during the project be made available to local Tribal members 

for personal use as firewood. We also ask for adequate access to that firewood by locating it in an 

area easily accessible by Tribal member vehicles. 

Response: 

Reclamation is already accounted for and bonded by the Utah DOGM (see response to Comment 

2). No new disturbance (including timber clearing, overland routes, native plant disturbance, roads, 

core holes, or facilities) would occur on National Forests under the Proposed and No Action 

Alternatives. Visuals and wilderness characteristics were addressed in the 2002 EIS. Because there 

would be no surface disturbance, there will be no impacts on visual quality or wilderness 

characteristics (see Table 4). Subsidence would not be visible and there are no wilderness areas 

within 25 miles of the project. Measures to control weeds and reestablish vegetation are already 

included in permits and stipulations. Spill prevention and response measures and reporting 

requirements are already included in the UPDES permit (see Section 2.2.13 of the EA). No drilling 

is proposed and no water or use of drilling materials will be required for drilling. 

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Commenter: WildEarth Guardians 

Comment 8: 

We are concerned first and foremost that OSMRE is apparently moving forward to approve the 

mining plan modification even before outstanding litigation over the issuance of federal coal lease 

UTU-77114, or the Flat Canyon coal lease, has been resolved. 

As OSMRE is aware, Guardians and the Trust are in the U.S. District Court for the District of Utah 

challenging, among other things, the adequacy of the underlying National Environmental Policy Act 

(“NEPA”) analysis. See Exhibit 1, Proposed Second Amended Complaint, WildEarth Guardians and 

Grand Canyon Trust v. Jewell, Case No. 2:16-cv-00168- DN (June 24, 2016).[Footnote 1: We 

further aver that the claims raised in our complaint would be equally applicable to any final action 

taken by OSMRE and the Secretary with regards to approval of the Skyline Mining Plan.] The sale 

and issuance of the Flat Canyon Coal lease occurred more than 13 years after the initial Record of 

Decision (“ROD”) was issued by the Bureau of Land Management (“BLM”) and U.S. Forest Service 

(“USFS”) and after a final environmental impact statement (“EIS”) was prepared documenting and 

disclosing the reasonably foreseeable impacts of issuing the lease. Our federal court action 

challenges the fact that the BLM and USFS determined this 13 year-old FEIS adequately disclosed 

the potentially significant impacts of the Flat Canyon coal lease, even though the EIS did not even 

mention a number of potentially significant impacts. Further, the agencies determined no 

supplementation of the EIS was necessary, despite the development of significant new information 

and circumstances that occurred in the more than 13 years between the issuance of the FEIS and 

the issuance of the lease. 

OSMRE, as well as Bowie Resources and its subsidiary, must understand that if we succeed in this 

litigation, we have requested the Flat Canyon lease be vacated. If this request for relief is granted, it 

is very likely that any mining plan modification approved by the Secretary of the Department of the 

Interior will necessarily become void given the absence of leased federal coal. This would mean 

that any mining and development of the Flat Canyon lease would cease. 

To this end, with this comment letter, we are putting the agency, as well as the lessee, on notice 

that if mining are development are halted, any harms that may be claimed to befall OSMRE and/or 

Bowie Resources would be self-imposed. If OSMRE moves forward to recommend approval of the 

mining plan modification and the Secretary approves the modification, and if Bowie proceeds to 

commence mining and development, the parties would be doing so under the awareness that their 

actions could be halted as a result of our court action. If the parties choose to accept this risk, they 

do so at their own peril. 

Furthermore, we hereby put OSMRE and the lessee on notice that, given the flaws in the Flat 

Canyon FEIS and the failure of the BLM and the USFS to supplement the FEIS, any approval by 

OSMRE that relies upon this FEIS would be equally flawed and invalid. 

Given this, we strongly urge OSMRE and the Secretary to delay taking action on the proposed 

mining plan modification until litigation is fully resolved. Justification for delaying action on the 

proposed mining plan is bolstered by recent actions undertaken by the Secretary of the Interior. In 

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Secretarial Order 3338, issued on January 15, 2016, the Secretary proclaimed both a halt on the 

leasing of federal coal and the initiation of a programmatic environmental impact statement to 

consider and implement sweeping reforms to the federal coal program. In support of her actions, 

the Secretary cited concerns over “fair return,” “climate change,” and “market conditions.” 

Secretarial Order 3338 § 2(b). Although the Order did not put a halt to decisions undertaken by 

OSMRE, it speaks to the depth of the contemporary controversy and concerns surrounding federal 

coal management. Given that the Flat Canyon coal lease was approved in 2002, before fair return, 

climate change, and market conditions were remotely concerns related to the management of 

federal coal, it speaks to the need for OSMRE to proceed carefully and deliberately. 

Put another way, OSMRE should not simply be a rubberstamp, but rather truly take into account the 

myriad changed circumstances that influence today’s coal management decisions and apply 

contemporary deliberation to the present mining plan modification. 

Response: 

There is a pending challenge to the BLM’s and the Forest Service’s compliance with the National 

Environmental Policy Act and the Administrative Procedure Act in approving and consenting to the 

Flat Canyon Coal Lease. WildEarth Guardians v. Jewell, et al., No. 15-cv-01984-REB (D. Colo.). 

But BLM’s decision to offer the lease has not been stayed or enjoined. Accordingly, the decision is 

in effect and it is appropriate for OSMRE to tier to the EIS. CEQ encourages tiering to reduce 

redundancy in analysis. Per the CEQ regulations implementing NEPA (40 C.F.R. §§ 1502.20 and 

1508.28), tiering is appropriate when proceeding from a broader environmental impact statement on 

a specific action to an analysis at a later stage, so that the agencies can focus on the issues which 

are ripe for decision and exclude from consideration issues already decided. 

Comment 9: 

In our prior comments, we pointed to the need for OSMRE to prepare an EIS. These comments do 

not appear to have been adequately addressed in the EA. In the meantime, we have additional 

concerns over the agency’s decision to prepare an EA, even though mining of the Flat Canyon coal 

lease clearly poses significant impacts to the environment. 

To begin with, OSMRE’s attempt to tier its EA to the 2002 Flat Canyon coal lease FEIS, and in 

doing so avoid preparing its own EIS or supplemental EIS, is not supported by Interior Department 

NEPA regulations at 43 C.F.R § 46.140. These regulations state that: An environmental 

assessment may be prepared, and a finding of no significant impact reached, for a proposed action 

with significant effects, whether direct, indirect, or cumulative, if the environmental assessment is 

tiered to a broader environmental impact statement which fully analyzed those significant effects. 43 

C.F.R. § 46.140(c). Here, the EIS being tiered to, namely the 2002 Flat Canyon coal lease FEIS, 

did not fully analyze the significant impacts of leasing and mining the lease. As Guardians explained 

in a 2015 letter to the BLM and USFS, the 2002 FEIS failed to address a number of potentially 

significant impacts, including the climate impacts related to the reasonably foreseeable 

consequence of coal combustion, air quality impacts, fish and wildlife impacts, and cumulative 

impacts related to additional federal coal management decisions, including additional leasing that 

had occurred since 2002. 

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To its credit, OSMRE appears to acknowledge the shortcomings in the 2002 FEIS in its current EA. 

The EA provides an air quality analysis, climate analysis, and significant updates to the dated 

analysis presented in the 2002 FEIS, implicitly acknowledging that the 2002 FEIS did not fully 

analyze significant relevant to the 2015 leasing action. However, what OSMRE does not seem to 

recognize is that an EA cannot tier to a deficient EIS, nor can it serve to “fix” deficiencies in an EIS. 

If an EIS is inadequate, or in need of updating or gap-filling, then the proper means of doing this is 

through a revised or supplemental EIS, not through an EA. Put another way, if an EIS fails to 

disclose significant impacts, an EA cannot be the vehicle for disclosing those impacts under NEPA. 

Only an EIS can be utilized to analyze and assess significant environmental impacts under NEPA. 

See 40 C.F.R. § 1502.3. 

Response: 

OSMRE has reviewed the conclusions in the EIS (including fish and wildlife) and determined that 

the EIS is sufficient (see Table 4). This EA tiers to the EIS which is appropriate according to 40 

CFR 1508.28 because the EA is “a subsequent statement or analysis at a later stage...” and 

excludes “from consideration issues already decided or not yet ripe.” The EA analyzed the sitespecific impacts including coal combustion on air quality and greater sage-grouse related to the 

federal mining plan modification. Rationale and findings are included in the FONSI. 

Comment 10: 

It is instructive to look to the BLM’s NEPA Handbook for guidance on this issue.[Footnote 2: This is 

especially true given that OSMRE’s NEPA Handbook was prepared in 1989, while BLM’s Handbook 

was prepared in 2008. Comparatively, BLM’s guidance is more up-to-date, on point, and 

instructive.] The agency’s Handbook states that, when tiering to an EIS, “If there are new 

circumstances or information that would result in significant effects of an individual action not 

considered in the EIS, tiering to the EIS cannot provide the necessary analysis to support a [Finding 

of no Significant Impact] FONSI for [an] individual action[.]” BLM NEPA Handbook, Section 5.2.2 at 

27. The Handbook further states that, “An EIS would need to be prepared for the individual action 

only if there are significant effects that have not been analyzed in the broader EIS.” 

Here, there are significant impacts related to the mining of the Flat Canyon coal lease that were not 

considered in the 2002 FEIS. Accordingly, tiering is not allowed. Given this, an EIS must be 

prepared, not an EA. 

Response: 

See the response to Comment 9 regarding the purpose for the EA and the responses to Comments 

8 and 9 on the appropriateness of tiering to the 2002 FEIS. The analysis in the EA did not show 

significant impacts that would require an EIS. The draft FONSI published with the EA provides 

rationale supporting the FONSI. 

Comment 11: 

Regardless, an EIS is compelled based solely on the Interior Department’s Departmental Manual, 

516 DM 13. The Manual states that, approval of a mining plan requires an EIS where “[t]he 

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environmental impacts of the proposed mining operations are not adequately analyzed in an earlier 

environmental document covering the specific leases or mining activity,” “[t]he area to be mined is 

1280 acres or more, or the annual full production level is 5 million tons or more,” and “[m]ining and 

reclamation operations will occur for 15 years or more.” 516 DM 13.4(A)(4). 

Upon review of available information, it still appears that all 3 criteria are met with regards to the 

Skyline Mining Plan. 

In the case of the Flat Canyon tract, mining will impact more than 1,280 acres. 

According to OSMRE’s notice, the mining plan modification will add more than 2,000 acres of 

federal coal to the Skyline Mine. Furthermore, the Skyline Mine is permitted to produce more than 5 

million tons of coal annually. Additionally, according to OSMRE’s notice, the proposed mining plan 

would extend the life of the mine by 9 to 12 years. Already, the life of the mine is projected to 

extend to 2023 based on the addition of coal reserves through a modification of Federal Coal Lease 

UTU-67939. OSMRE’s approval would extend the life of the mien beyond 2030, or cumulatively 

more than 15 years.[Footnote 3: Additionally, post-mining reclamation activities are likely to occur 

for several years, further indicating OSMRE’s decision will authorize mining and reclamation 

activities for 15 years or longer.] Thus, 2 of the 3 factors for an EIS are met in this case. 

With regards to the third criteria—whether the environmental impacts of the proposed mining have 

been adequately addressed in an earlier document—OSMRE’s EA confirms the 2002 FEIS did not 

adequately address the environmental impacts of the proposed action. The EA not only analyzes 

impacts that were not even addressed in the 2002 FEIS, but clearly presents updated analysis to 

compensate for the fact that the 2002 FEIS fails to adequately analyze the reasonably foreseeable 

impacts of mining the Flat Canyon lease. 

Furthermore, as our complaint over the Flat Canyon lease alleges, the FEIS is flawed in a number 

of key regards and fails to demonstrate compliance with NEPA. If OSMRE chooses to rely on, or 

tier to, this FEIS, its decision would be legally flawed for the same reasons identified in our 

complaint. 

To this end, it does not appear as if an EA or a Finding of no Significant Impact (“FONSI”) is 

warranted or justified. We again urge OSMRE to prepare an EIS for the proposed mining plan and 

comply with relevant procedures governing the preparation of an EIS. 

Response: 

The project was reviewed in light of Departmental Memorandum 516 (see Section 1.1). The 

complete text of the reference section of Chapter 13 of the Departmental Memorandum (page 3, 

item 4) states the following: 

Approval of a proposed mining and reclamation plan for a surface mining operation that meets the 

following: 

(a) The environmental impacts of the proposed mining operation are not adequately analyzed in 

an earlier environmental document covering the specific leases or mining activity; and 

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(b) The area to be mined is 1280 acres or more, or the annual full production level is 5 million
 

tons or more; and
 

(c)	 Mining and reclamation operations will occur for 15 years or more. 

The Proposed Action does not meet the scenario described in the Departmental Manual 516 DM 

13, which requires all 3 criteria to be met to initiate an EIS. With regard to criteria (a), in 2002, 

the Forest Service completed the EIS for Flat Canyon Lease Tract and ROD. Therefore 

criteria (a) is not met. 

•	 With regard to criteria (b), while the lease tract to be mined includes more than 1,280 acres, 

there would be no surface disturbance associated with it (per SMCRA, 30 U.S.C. 1266 

Section 516). 

•	 Similarly, while the air permit approves up to 8 million tons to mined annually, the actual
 

proposed is a maximum of 4.5 million tons, which is below the 5 million ton annual full
 

production level listed in criteria (b) (see Section 2.3 of the EA). 

•	 Finally, mining and reclamation operations would occur over 2 years following completion of 

mining, for a total timeframe of “mining and reclamation operations of approximately 11-14 

years, below the criteria (c) threshold of 15 years (see Section 2.3.12 of the EA). 

Departmental Manual 516 13 does not automatically mandate the preparation of an EIS if certain 

criteria are met. This guidance document only identifies major actions “normally requir[ing] the 

preparation of an EIS.” 516 DM 13.4(A). It also explicitly recognizes that OSMRE may choose not to 

prepare an EIS for any of the listed actions. See 516 DM 13.4(A) “If for any of these actions it is 

proposed not to prepare an EIS, an EA will be prepared and handled in accordance with Section 

1501.4(e)(2)”. Thus, there is nothing in the Departmental Manual that diminishes OSMRE’s 

discretion to follow the NEPA requirements in order to determine whether any particular action is 

significant. 

OSMRE has completed an EA to determine whether there would be significant effects as a result of 

approving the Skyline Flat Canyon Coal Lease Tract Mining Plan Modification. Under the MLA and 

SMCRA, the Secretary, as delegated to the ASLM, has the authority to approve, approve with 

conditions, or disapprove an application for a mining plan modification. As described in the EA 

Section 1.3, Regulatory Framework and Necessary Authorizations, OSMRE makes a 

recommendation to the ASLM on the decision for the mining plan modification. That 

recommendation is based on OSMRE’s consideration of 7 factors, one of which is compliance with 

NEPA (30 CFR 746.13). 

The determination of significance is based on the context and intensity as defined by CEQ 

regulations 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 FONSI, OSMRE has determined that there are no significant impacts. Therefore, 

an EIS is not required under this pretext. OSMRE has not yet submitted a recommendation to the 

ASLM on the decision. 

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Comment 12: 

On May 27, 2016, the Utah Division of Oil, Gas and Mining (“DOGM”) issued a citation to Canyon 

Fuel for pumping water from the Skyline Mine directly into Eccles Creek and intentionally bypassing 

a sedimentation pond meant to prevent pollution of the creek. DOGM assessed a $4,070 penalty 

against Canyon Fuel after concluding that the company violated numerous provisions of Utah’s 

coalmine-permitting regulations and the Skyline Mine’s reclamation plan. 

This was not the first time that Canyon Fuel had violated water-quality conditions in its permits. The 

company was issued a similar citation in August 2008 after it repeatedly let “coal sediment-laden 

materials” discharge into Eccles Creek out of a damaged and poorly repaired pipe. And back in 

November 2001, the Utah Division of Water Quality issued a notice of violation to the company for 

violating its state issued Clean Water Act permit by pumping excess mine water directly into Eccles 

Creek. 

None of these permit violations is mentioned in the EA, and OSMRE did not analyze the possibility 

that they may recur or the impacts that would result should they recur. See EA at 90–93. Indeed, 

the EA acknowledges that mining the Flat Canyon Lease area may well result in increased inflows 

into the mine “that are as large, or larger” than those encountered in the early 2000s. EA at 92. And 

those increased inflows are the very condition that caused Canyon Fuel to violate its water-quality 

permit in November 2001. 

The EA should be revised to analyze whether increased inflows as the Flat Canyon lease area is 

mined may lead to comparable discharge violations and how increased inflows and resulting 

discharges can be mitigated. For example, the EA acknowledges that increased sedimentation of 

Eccles Creek will occur “at discharge rates approximating 35 [cubic feet per second (cfs)].” EA at 

92. The EA then simply assumes that “the monitoring program” would be adjusted to document 

degradation of the creek if dewatering increases such that there are “sustained higher discharges 

above 35 cfs.” EA at 93. That analysis is illogical. If sustained discharge rates of 35 cfs are enough 

to degrade the creek, the EA should analyze mitigation measures to keep discharge rates below 

that threshold, rather than assume that the State of Utah can simply modify the mine’s discharge 

permit to “adjust to potentially changing conditions,” EA at 93. 

OSMRE should revise the EA to consider Canyon Fuel’s history of violations, reassess the 

conclusions in the EA that “[w]ater quality standards would continue to be met” and “[i]mpacts on 

water quality would be negligible and short-term,” EA at 92, re-evaluate whether water-quality 

impacts from the Skyline Mining Plan may be significant, and determine whether additional waterquality-protection requirements should be imposed as a condition of approving the Mining Plan (if 

OSMRE maintains that proposed recommendation). 

If OSMRE persists in its recommendation to approve the Skyline Mining Plan, it should also 

recommend that additional conditions be imposed to protect water quality given Canyon Fuel’s 

history of unauthorized discharges from the Skyline Mine into Eccles Creek...History suggests that 

Canyon Fuels’ state-issued SMCRA permit and state-issued federal Clean Water Act permit are 

insufficient to ensure that the company will discharge mine water in compliance with Utah’s Coal 

Mining and Reclamation Act (Utah Code Ann. § 40-10-2, et seq.) and the federal Clean Water Act. 

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And the stipulations included in the Flat Canyon lease (UTU-77114) include no provisions to protect 

water quality. They simply require Canyon Fuel to replace water that is adversely affected by mining 

operations rather than protect water quality in the first place.[Footnote 4: The Lease stipulations 

also require the company to monitor the gradient of perennial streams and “mitigate detrimental 

effect discovered during monitoring.” EA at 31. If that vague requirement even relates to water 

quality, it should be clarified to explain how and augmented to explain exactly what Canyon Fuel is 

required to do.] Thus, if OSMRE continues to recommend approval of the Modification, it should 

also recommend that additional stipulations be imposed as condition of approval to better protect 

water quality, such as augmented monitoring, inspection, preventative-maintenance, employee 

training, or bonding requirements. 

Response: 

OSMRE, through this analysis, has not determined a need for additional mitigation measures for 

water. Skyline Mine is permitted to discharge directly to the creek by the UPDES permit. Surface 

water quality is carefully monitored by Skyline Mine and regularly submitted to Utah DOGM. Utah 

DEQ and DOGM will continue to monitor and protect surface water quality through Skyline’s 

UPDES permit. 

Skyline Mine has monitored and appropriately reported any water issues to the State of Utah 

DOGM, who has in turn responded (reports available online from the Utah Coal Program 

http://linux3.ogm.utah.gov/WebStuff/wwwroot/coal/filesbypermit.php?C0070005). Please see Table 

27 below for modifications made to the EA in response to this comment. 

Determining compliance with the SMCRA permit is outside the scope of the EA. The basis for 

OSMRE’s recommendation to the ASLM on a decision on the mining plan modification is described 

in Section 1.3. 

Comment 13: 

The EA fails to analyze and assess impacts to air quality related to the combustion of coal from the 

Skyline Mine. In its EA, OSMRE asserts, for example, that emissions of ozone precursors 

generated by coal combustion “are not quantifiable because Skyline Mine ships coal to many 

consumers which change over-time which creates high uncertainties and in ability to analyze 

indirect emissions.” EA at 82. This assertion is not supported by the agency’s own disclosures in 

the EA, which indicate that coal from the Skyline Mine is consistently sold and burned at power 

plants in Utah, including the Hunter, Huntington, and Intermountain Power Project power plants. 

Response: 

The text referred to was incorrect and has been corrected because the EA does analyze the ozone 

precursors. See Table 27 at the end of this Appendix. 

The EA includes an analysis of the impacts from the combustion of coal (see Section 4.3.1.2). 

Coal combustion related impacts to fish and wildlife species are not quantifiable for the project 

specifically because Skyline Mine ships coal to many consumers that change over-time which 

creates high uncertainties and an inability to analyze indirect emissions pursuant to CEQ 40 Most 

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Questions (Question 18) and 40 CFR 1502.22. The EA includes an indirect coal combustion 

emissions analysis for a representative power plant in Section 4.3.1.2. 

Comment 14: 

The EA appears to fail to analyze and assess the climate change impacts of approving the 

proposed mining plan. We are especially concerned that OSMRE did not calculate the costs of 

projected carbon emissions that would result from the Skyline Mining Plan. 

In our prior comments, we detailed the need and appropriateness for an assessment of carbon 

costs. In the EA, OSMRE provides various reasons for rejecting such an analysis, including that 

there are no “specific threshold levels” and that inclusion of such an analysis would be misleading 

absent a full cost benefit analysis. EA at 87-88. With regards to a full cost benefit analysis, it is 

troubling to see that while OSMRE dismissed carbon costs, it was perfectly comfortable disclosing 

purported economic benefits associated with the Skyline Mine (EA at 87) and a clear monetary 

analysis of the economic benefits of more mining (EA at 62-64). If anything, the current analysis is 

misleading because it presumes carbon costs are $0 and only discloses economic benefits. This is 

the hallmark of an analysis that lacks objectivity. 

As to significance thresholds, it is unclear what barrier this presents for OSMRE. Is the agency 

looking for another entity to establish these thresholds? Under NEPA, agencies are tasked with the 

independent obligation to assess significance, not pass the duty off to some undefined entity. This 

does not serve to support OSMRE’s assertion that the climate impacts are not significant or that it 

was unreasonable to calculate carbon costs as a means to assess the potential significance of the 

climate impacts of the Skyline Mining Plan. 

Response: 

The information in the EA disclosing the employment and payments from coal mining were included 

to update the 2002 FEIS information on these subjects based on the current market value and 

employment. Section 4.4.1.2 of the EA explained why OSMRE determined that a social cost of 

carbon (SCC) analysis was not necessary for this project. NEPA does not require a cost-benefit 

analysis or the presentation of the SCC cost estimates quantitatively. Without a complete monetary 

cost-benefit analysis, which includes the social benefits of energy production, inclusion solely of a

SCC analysis would be misleading. Therefore, OSMRE did not apply the SCC protocol in this 

analysis. Also, the analysis of the socioeconomic conditions presented in the EA is not dependent 

on the inclusion of SCC values and therefore no value was attributed to the potential impacts of 

climate change. The Skyline Flat Canyon Coal Lease Tract Mine Plan Modification EA evaluated the 

climate change impacts using GHG emissions (see Section 4.3 of the EA). 

In accordance with NEPA's implementing regulations, “the weighing of the merits and drawbacks of 

the various alternatives need not be displayed using a monetary cost-benefit analysis and should 

not be when there are important qualitative considerations.” 40 C.F.R. 1502.23. Accordingly, 

OSMRE is not required to conduct an analysis of the SCC and has chosen not to use that method 

for this EA. See also Earthports, Inc., et al, v. FERC et al., 828 F.3d 949 (D.C. Cir. 2016). 

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Comment 15: 

The EA is entirely silent on the impacts of coal exports, even though we called on OSMRE to 

address such impacts. 

That Bowie Resources likely exports coal from the Skyline Mine appears very certain. In a recent 

statement regarding an Initial Public Offering, Bowie stated that it exports coal “to a variety of 

growing economies on the Pacific Rim.” See Exhibit 10, NASDAQ, “Bowie Resource Partners LP,” 

website available at http://www.nasdaq.com/markets/ipos/company/bowieresource-partners-lp968514-78744. Reports indicate Bowie exports 1-3 million tons annually from its mines in Utah and 

is moving to lock in additional approvals, including a new coal export facility in Oakland, CA and 

additional federal coal leases, to maintain and/or increase its export capacity. See Exhibit 11, 

Maffly, B., “Utah coal: California here it comes—and not everyone is happy,” Salt Lake Tribune 

(April 25, 2015), available at http://www.sltrib.com/home/2425141-155/utah-coal-california-here-itcomes?fullpage=1. Although Oakland recently voted against a new coal export facility, a recent 

story indicates that Bowie’s plans are by no means dead and that the company remains dead set 

on its export plans. See Exhibit 12, Tory, S., “How Utah coal interests helped push a secret plan to 

export coal from California,” High Country News (July 21, 2016), available online at 

https://www.hcn.org/articles/how-a-utah-coal-company-fueled-asecret-plan-to-export-coal-fromcalifornia-Keep-It-In-The-Ground-Oakland-terminal/print_view. 

Given this, OSMRE must fully analyze and assess the impacts of exporting coal from the Skyline 

Mine. Such an analysis and assessment must take into account the impacts of hauling coal by rail, 

the impacts of port operations and coal handling at export terminals, the impacts of shipping coal 

overseas, and the combustion impacts of burning coal overseas. To this end, OSMRE must 

address the reasonably foreseeable impacts of the new coal export facility in Oakland, CA. 

Response: 

Canyon Fuel Company, LLC has not indicated the regularity or amount of Skyline coal that may be 

exported. It would be speculative to assume an amount or frequency of exportation would occur. 

Thus only indirect impacts associated with domestic coal combustion were analyzed in the EA. As 

shown in Table 2 of the Draft EA, the Skyline Mine has historically supplied domestic power plants 

with the coal over the past 5 years. The EA assumes that the domestic coal market would be 

sufficient for the Proposed Action as demonstrated by the historical data. 

Comment 16: 

OSMRE did not respond to our initial comments regarding the need to analyze and assess the 

impacts of similar and cumulative mining and coal leasing approvals that are under consideration by 

the U.S. Department of the Interior in the same area. Under NEPA, an agency must analyze the 

impacts of “similar” and “cumulative” actions in the same NEPA document in order to adequately 

disclose impacts in an Environmental Impact Statement (“EIS”) or provide sufficient justification for 

a FONSI in an EA. See 40 C.F.R. §§ 1508.25(a)(2) and (3). 

Here, the U.S. Department of the Interior is currently weighing numerous coal decisions, similar to 

the proposed action at hand, which pose similar and cumulative impacts in terms of greenhouse 

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Environmental Assessment Appendix C – Draft EA Public Comments and Responses 

gas emissions and climate impacts, particularly in terms of carbon costs [See original comment for 

full list of projects]. 

These are just a handful of the coal decisions pending before Interior that pose potentially 

significant climate impacts. Other proposals include BLM’s consideration of numerous lease 

modifications and lease readjustments, as well as other OSMRE mining plan reviews that may not 

yet be proposed or public. Given past approvals, the cumulative impacts could be even more 

significant. 

The justification for addressing these similar and cumulative actions in a single NEPA document is 

underscored by OSMRE’s own EA. As the agency acknowledges, the proper scope of analysis for 

greenhouse gas emissions and climate impacts is at least national in scale. See EA at 101. Given 

this broad geographic scope, it is imperative that OSMRE analyze the impacts of mining at the 

Skyline Mine consistent with the scope required under NEPA in order to ensure that impacts are 

fully analyze and assessed. 

Response: 

These other activities are not identified specifically as additional cumulative effects because, while 

new mining plans may be approved, OSMRE analyzes the potential impacts associated with mines 

that have submitted a new or modified lease application. The overall production of coal is not 

anticipated to increase and current uses are already accounted for in Section 5.2.2.1. 

All GHG emissions contribute to cumulative climate change on a global scale. However, it is not 

scientifically possible to determine the impact that would result on the global climate conditions from 

the emissions from this specific proposed action or in total from the emissions of other actions. The 

variables involved in such an analysis would make this determination conjectural and not within the 

rule of reason. 40 CFR 1502.22(b). Therefore, it would be inconsistent with the NEPA to require 

the preparation of an EIS for every Federal action that may cause GHG emissions regardless of the 

magnitude of those emissions. For this reason, past projects and other projects that may or may 

not be approved by OSMRE are not included in the GHG emissions cumulative effects analysis. 

Comment 17: 

In analyzing and assess the impacts of the proposed mining plan modification, as well as the 

appropriateness of issuing the plan, OSMRE must analyze and assess whether Utah’s SMCRA 

permit is sufficient to meet the requirements of SMCRA. If the permit is not adequate, OSMRE must 

either craft its mining plan approval to address the inadequacies and/or disapprove of the proposed 

mining plan. The duty for OSMRE and the Secretary to ensure compliance with SMCRA is 

supported by both the Mineral Leasing act and SMCRA...Here, we are concerned that the Skyline 

Mine may not be appropriately permitted and regulated under SMCRA by the State of Utah, which 

would warrant disapproval or modification of the proposed Skyline Mining Plan. 

Our first concern relates to the bonding of the Skyline Mine. As WildEarth Guardians pointed out in 

a citizen complaint filed at the end of 2015, the State of Utah has failed to ensure the reclamation 

bond for the Skyline Mine, as well as other Bowie mines in Utah, has been increased to reflect 

inflation. In response, OSMRE sent Ten Day Notice letters to the State of Utah acknowledging the 

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Appendix C – Draft EA Public Comments and Responses Environmental Assessment 

likelihood of violations of SMCRA bonding requirements. To date, our complaint has yet to be 

resolved and all indications are that Skyline continues to be inadequately bonded. Given this, 

OSMRE cannot recommend approval of the Skyline Mining Plan. Either the agency must 

recommend disapproval or modification to ensure adequate bonding under SMCRA. 

Response: 

OSMRE has a State-Federal cooperative agreement with Utah DOGM under 30 CFR Part 944 and 

coordinates with the State of Utah on the management of their SMCRA program. The State of Utah 

has their own program that is federally approved allowing them to manage the mines. OSMRE 

operates as oversight to ensure the mine is complying with requirements of SMCRA. Utah DOGM 

can request additional support when needed. Determining compliance with the SMCRA permit is 

outside the scope of the EA. The basis for OSMRE’s recommendation to the ASLM on a decision 

on the mining plan modification is described in Section 1.3. 

Comment 18: 

Our second concern relates to Bowie Resources’ apparent pattern and practice of violating water 

quality standards at the Skyline Mine. SMCRA regulations require that coal mine operators 

discharge water “in compliance with all applicable State and Federal water quality laws and 

regulations[.]” Here, it appears that the Skyline Mine SMCRA permit is not sufficient to ensure that 

mining operations consistently and effectively comply with state and federal water quality laws and 

regulations, and thus is not consistent with SMCRA. Given this, OSMRE cannot recommend 

approval of the Skyline Mining Plan. Either the agency must recommend disapproval or modification 

to ensure compliance with water quality standards under SMCRA. 

Response: 

See responses to Comment 12 and Comment 17.
 

Also see response to comments that resulted in changes to the EA in Table 27.
 

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Environmental Assessment Appendix C – Draft EA Public Comments and Responses 

Comments Resulting in Changes to the EA 

Some comments were best addressed with changes or additions to the EA. These comments and 

the changes to address them are shown in Table 27. 

Table 27 Comments on the Draft EA Resulting in Modifications to the EA 

Comment Response EA Changes 

The EA should be revised to analyze whether 

increased inflows as the Flat Canyon lease area is 

mined may lead to comparable discharge violations 

and how increased inflows and resulting discharges 

can be mitigated. For example, the EA acknowledges 

that increased sedimentation of Eccles Creek will 

occur “at discharge rates approximating 35 [cubic feet 

per second (cfs)].” ... If sustained discharge rates of 

35 cfs are enough to degrade the creek, the EA 

should analyze mitigation measures to keep discharge 

rates below that threshold, rather than assume that 

the State of Utah can simply modify the mine’s 

discharge permit to “adjust to potentially changing 

conditions,” 

Canyon Fuel Company, 

LLC updated their Mine 

and Reclamation Plan 

June 31, 2016, at the 

request of DOGM. 

Section 2.2.6 has 

been updated and 

the analysis in 

Section 4.6.1.1 has 

been updated to 

reflect the new 

standard. 

We are especially concerned that OSMRE did not Section 4.4.1.2 Additional rationale 

calculate the costs of projected carbon emissions that 

would result from the Skyline Mining Plan 

addresses the cost of 

carbon question. 

for foregoing an 

analysis of the social 

cost of carbon is 

provided in Section 

4.4.1.2. 

OSMRE must prepare a NEPA analysis that properly The climate change Sections 3.3.2, 

compares greenhouse gas emission increase and analysis has been revised 5.2.2.1, and 5.2.5. 

decreases between the action and no action since publication of the Draft

alternatives, properly assesses the significance of the EA. 

greenhouse gas emission in terms of relevant and OSMRE recognizes that 

proper context and intensity, considers mitigation relevant, reasonable 

measures, and uses current scientific information and mitigation measures may 

methodologies to assess impacts. be discussed even if they 

CEQ’s NEPA guidance makes clear that agencies are outside the agency’s 

must consider the effects of climate change on a jurisdiction per the CEQ 

proposed action and its environmental impacts. While regulations on 

the EA acknowledges that temperatures in the area implementing NEPA (40 

are likely to increase by 1.5 °F in the next 10 years, CFR 1502.14(c). However, 

there is no analysis of what this increase temperature OSMRE does not have the 

will mean in terms of water quantity and quality regulatory authority to 

impacts, vegetation impacts, soils impacts, among monitor or enforce 

other things. More importantly, there is no analysis or mitigation on the 

assessment of the impacts this temperature increase transportation or 

will have on Bowie Resource’s ability to fully comply combustion of coal 

with its mining permit and meet other applicable associated with this project 

environmental and public health protection standards. in accordance with the 

June 2016 DOI 

Landscape-scale 

Mitigation in NEPA 

Analysis, Decision-Making, 

and Implementation 

Monitoring Memorandum. 

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Appendix C – Draft EA Public Comments and Responses Environmental Assessment 

Comment Response EA Changes 

GHG emissions from coal 

combustion are regulated 

by EPA and state air 

quality departments and 

are out of scope of the 

mining plan modification 

EA. As required, the EA 

does analyze the impacts. 

Since we submitted our comment letter, the White 

House Council on Environmental Quality (“CEQ”) 

finalized guidance regarding agency analysis and 

assessment of climate impacts under the National 

Environmental Policy Act. 

As CEQ’s guidance makes clear, OSMRE’s analysis 

and assessment is not supported under NEPA. 

The EA has been updated 

following publication of the

Draft EA. The comparison 

to the national GHG 

emissions has been 

removed. 

Section 5.2.2.1. 

In its EA, OSMRE asserts, for example, that OSMRE agrees that this Section 4.3.1.2. 

emissions of ozone precursors generated by coal statement is incorrect 

combustion “are not quantifiable because Skyline because the Ozone 

Mine ships coal to many consumers which change precursors were 

over-time which creates high uncertainties and in quantified. The text has 

ability to analyze indirect emissions.” EA at 82. been modified to explain 

that calculations are not 

specific to the project but 

are general from standard 

calculation methods. 

Skyline Flat Canyon Coal Lease Tract Mining Plan Modification EA 

C-2 
Appendix D 

Biological Assessment 
 

Biological Assessment for the Skyline Mine 

Flat Canyon Coal Lease Tract Mining Plan 

Modification 

December 28, 2015 

PRESENTED TO PRESENTED BY 

Office of Surface Mining Reclamation and Tetra Tech, Inc. P +1-801-364-1064 

Enforcement 4750 West 2100 South, Ste 400 F +1-801-364-2021 

Salt Lake City, Utah 84120 tetratech.com 

Western Region Office 

Nicole Caveny 

1999 Broadway St., Suite 3320 

Denver, Colorado 80202-3050 

Prepared by: 

1/19/2017 

Wendy Rieth Date 

Senior Wildlife Biologist/GIS Analyst 

Reviewed by: 

1/19/2017 

Michele Weidner Date 

Ecologist 

Reviewed and Accepted by: 

1/19/2017 

Nicole Caveny Date 

Environmental Protection Specialist 
Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification Biological Assessment 

TABLE OF CONTENTS
 

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

2.0 PROPOSED ACTION ..........................................................................................................................................1
 

2.1 action area .....................................................................................................................................................3
 

3.0 ECOLOGICAL SETTING .....................................................................................................................................3
 

4.0 SPECIES/CRITICAL HABITAT CONSIDERED ..................................................................................................4
 

5.0 EFFECTS ANALYSIS ..........................................................................................................................................7
 

6.0 CONCLUSION AND DETERMINATION OF EFFECTS......................................................................................9
 

7.0 LITERATURE CITED ........................................................................................................................................ 11
 

LIST OF TABLES 

Table 1. Threatened and Endangered Species List for the Project ...........................................................................4
 

Table 2. Effects Determinations .................................................................................................................................9
 

LIST OF FIGURES 

Figure 1. Project Area and Action Area .....................................................................................................................2
 

APPENDICES 

APPENDIX A – USFWS OFFICIAL IPAC LIST FOR THE PROJECT 

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Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification Biological Assessment 

ACRONYMS/ABBREVIATIONS
 

Acronyms/Abbreviations Definition 

BA Biological Assessment 

BLM Bureau of Land Management 

CP Colorado Plateau 

DOI United States Department of the Interior 

DPS Distinct Population Segment 

EA environmental assessment 

EIS environmental impact statement 

ESA Endangered Species Act 

IPAC Information, Planning, and Conservation 

OSMRE Office of Surface Mining Reclamation and Enforcement 

SMCRA Surface Mining Control and Reclamation Act 

USFS United State Forest Service 

USFWS United States Fish and Wildlife Service 

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Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification Biological Assessment 

1.0 INTRODUCTION 

The United States (U.S.) Department of the Interior (DOI), Office of Surface Mining Reclamation and Enforcement 

(OSMRE), Western Region, is preparing an environmental assessment (EA) for the Skyline Mine, federal coal 

lease UTU-77114, mining plan decision document (MPDD) modification. The Proposed Action is for OSMRE to 

make a recommendation to the Assistant Secretary of Land and Minerals Management (ASLM) about whether or 

not to approve the permit application package (PAP) to expand the life of their underground Skyline Mine near 

Helper, Utah for inclusion of the Flat Canyon Lease to the Skyline Mine. The ASLM will review the MPDD and 

make a decision to approve, conditionally approve or deny the PAP submitted by Canyon Fuel Company (owned 

by Bowie Resources) , which proposes an additional 3,792 acres of federal and private coal reserves at Skyline 

Mine. In 2002, the U.S. Forest Service (USFS), in cooperation with the Bureau of Land Management (BLM), 

completed an Environmental Impact Statement (EIS) analyzing the BLM action of offering the Flat Canyon Coal 

Lease Tract (UTU-77114) for competitive leasing (USFS and BLM 2002). BLM issued the lease for this tract to 

Canyon Fuel Company on July 1, 2015. 

Section 7 of the Endangered Species Act (ESA) requires federal agencies to ensure that any activities they 

authorize, fund, or carry out, do not jeopardize the continued existence of any species federally listed as 

threatened or endangered. This Biological Assessment (BA) has been prepared to analyze and disclose impacts 

from the Proposed Action on federally listed threatened, endangered, candidate, and proposed species. This 

analysis will determine if the Proposed Action would adversely affect any listed species or result in adverse 

modification or destruction of critical habitat, requiring consultation with the U.S. Fish and Wildlife Service 

(USFWS). 

2.0 PROPOSED ACTION 

The Skyline Mine has been in operation since 1981. The Proposed Action is to modify the mining plan for the 

Skyline Mine to include approximately 2,692 acres of federal coal within the Flat Canyon Coal Lease Tract 

(UTU77114) and 1,100 acres of private coal reserves. Mining the Flat Canyon lease would extend the life of the 

mine by 10.5 years. The Proposed Action would take place approximately five miles southwest of the town of 

Scofield, Utah in Emery and Sanpete counties, Utah. It would be located on the Manti-La Sal National Forest and 

private lands within sections 21, 28, 29, 32, and 33 in Township 13 South, Range 6 East; and sections 3, 4, 5, 8, 

9 and 10 in Township 14 South, Range 6 East (Salt Lake Meridian) (Figure 1). The Flat Canyon Coal Lease Tract 

and private coal reserves are located to the south and west of the existing Skyline Mine. The ‘Project Area’ is 

defined in this BA as all areas where underground mining activities would occur, which is delineated by the Flat 

Canyon Coal Lease Tract and the private coal reserves as shown on Figure 1. 

Coal occurs in two seams, which would be mined using longwall mining technology. No surface facilities are 

proposed. There would be no new sources of noise or other human disturbances/activities above ground as a 

result of the Proposed Action. 

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Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification Biological Assessment 

Figure 1. Project Area and Action Area 

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Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification Biological Assessment 

2.1 ACTION AREA
 

This BA evaluates the potential for the Proposed Action to cause subsidence, which in turn may modify 

topography, surface flows, and potentially result in water depletions downstream. Water depletions from the 

Colorado River or any tributary to the Colorado River may result in adverse effects to endangered fish. To analyze 

effects on aquatic species listed in Emery and Sanpete counties, which occur in the Colorado River system, the 

Action Area is defined as the upper Colorado River watershed (Figure 1). However, a smaller effects area is 

considered for terrestrial species because the Proposed Action’s area of influence on terrestrial species is 

localized to the Project Area and to where subsidence may occur rather than throughout the Upper Colorado 

River Basin. The area of estimated subsidence is shown in Figure 1. 

3.0 ECOLOGICAL SETTING 

The Project Area is located in east-central Utah southwest of the town of Helper in Emery and Sanpete counties 

on the Manti-La Sal National Forest and private lands. It lies within the Wasatch Plateau physiographic province. 

This plateau has been incised by deep canyons shaped by glaciers and by wind and water erosion. Topography 

in the area is mountainous with narrow ridges and deep U- shaped canyons. Elevations range from approximately 

8,550 to 9,800 feet. The area experiences four seasonal weather patterns, ranging from relatively hot summers to 

cold winters with snowpack accumulations. From 1981-2010, average minimum temperatures ranged from 11°F 

in December to 46°F in July. Average maximum temperatures range from 32°F in December to 76°F in July. 

Precipitations falls mostly as snow from October to April, with average annual precipitation over this period 

totaling 25.7 inches (Western Regional Climate Center, 2016). 

The most common vegetation community is aspen (Populus tremuloides) forest, which is characterized by mature 

aspen trees and various montane shrubs and forbs in the understory. Coniferous forests and mixed aspenconiferous forests are also present. Coniferous cover types typically occur on hillsides with northern or eastern 

exposures, and are dominated by Engelmann spruce (Picea engelmannii) and subalpine fir (Abies lasiocarpa) 

(Alpine Ecological 2015). Intermixed with the forest types are montane grasslands, dry and wet meadows, and 

sagebrush-steppe communities. Dominant montane grasses include slender wheatgrass (Elymus trachycaulus), 

mountain brome (Bromus marginatus), and Letterman’s needlegrass (Achnatherum lettermanii). Dry meadows 

are characterized by Kentucky bluegrass (Poa pratensis), bentgrass (Agrostis gigantean), and Ross sedge (Carex 

rossii) while wet meadows are vegetated with various sedges (Carex aquatilis, C. nebrascensis, C. utriculata). 

Sagebrush species include mountain big sage (Artemisia tridentate vaseyana) and silver sage (Artemisia cana). 

There are riparian communities associated with streams and springs. In the steeper areas, the drainages are 

narrow and lined with coniferous and aspen forest types. In flatter drainages, such as Flat Canyon, wide, subirrigated wet meadows comprise the drainage bottom. The majority of the riparian areas are wet meadow and 

grassland types (USFS and BLM 2002). The Project Area is located west of Upper Huntington Creek and Electric 

Lake (a reservoir formed by a dam on Huntington Creek), and is within the San Rafael River watershed within the 

larger Upper Colorado River Basin. Perennial, intermittent, and ephemeral streams show seasonal peak flows in 

the spring and early summer from snow melt (Petersen 2014). Perennial streams drain Boulger Canyon, Flat 

Canyon, Swens Canyon, and Little Swens Canyon, which flow east into Upper Huntington Canyon. Upper 

Huntington Creek is perennial, and flows into the San Rafael River drainage. The San Rafael River flows into the 

Green River approximately 80 miles to the southeast of the Project Area, and then into the Colorado River. A 

small portion of the Project Area drains west into Beaver Dam and Gooseberry Creek, which flows into the Price 

River and eventually into the Green River. Numerous springs are located throughout the Project Area. 

Past and present influences on baseline conditions include underground coal mining (other portions of the Skyline 

Mine have been mined adjacent to the Flat Canyon lease tract), exploratory drilling for coal, occasional timber and 

wood products recovery, livestock grazing, roads and trails, and outdoor recreation activities. The Manti-La 

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Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification Biological Assessment 

National Forest manages land in and around the project area and these lands are a highly used recreation area, 

offering camping, hiking, boating, fishing, motorized sightseeing, hunting, snowmobiling, and cross-country skiing. 

4.0 SPECIES/CRITICAL HABITAT CONSIDERED 

An official species list was obtained for the project from the USFWS Information, Planning, and Conservation 

(IPaC) website on November 2, 2015 (Appendix A). There are nine threatened or endangered species on the list, 

but no designated critical habitat. Table 1 presents the federally listed species identified on the USFWS list, and 

describes the species’ distribution, habitat, and consideration for further analysis. 

Table 1. Threatened and Endangered Species List for the Project 

Species and Status Habitat and Distribution Consideration for 

Analysis 

Birds 

Mexican Spotted Owl Ranges year-round across the southwestern U.S. and Mexico in Not Considered. The 

(Strix occidentalis lucida) disjunct areas consisting of isolated mountain ranges and species does not occur 

canyon lands. Range-wide habitat consists of old growth or in the Project Area. 

Threatened (Emery mature forests as well as rocky canyons (USFWS 2012a) No suitable habitat is 

County) The Project Area is located in the Colorado Plateau (CP) where present. Forest 

this species is generally limited to rocky canyon land and rarely communities are 

occurs in forested habitat. In the CP, it inhabits deep, steep- patches intermixed with 

walled canyons and hanging (side) canyons where the dominant sagebrush openings, 

cover type is typically pine juniper woodlands and mixed conifer and lack the complex 

forest (USFWS 2012a). structure and closed 

Extensive surveys have documented few breeding pairs on canopy this species 

National Forests in Utah (USFWS 2012a). On the Manti La Sal requires. There are no 

National Forest, breeding is known only from the Monticello rocky canyons present. 

District in San Juan County (140 miles to the southwest of the 

Project) (USFS 2010). The closest designated critical habitat is 

located 55 miles to the east of the Project Area along the Green 

River. 

Southwestern Breeding range for this subspecies includes the southwestern Not considered. 

Willow Flycatcher U.S. and northern Mexico. It inhabits dense riparian tree and The species does 

(Empidonax traillii shrub habitat, especially where willows and/or tamarisk are not occur in the 

extimus) present as well as standing water or saturated soils. It is Project Area. 

Endangered 

(Emery 

County) 

typically found below 8,500 feet in elevation (USFWS 2014). 

Published range maps indicate this subspecies occurs only in 

southern Utah (USFWS 2002a). However, USFWS lists it in 

portions of central Utah. Due to the difficulty in distinguishing 

Riparian habitat 

consists of open wet 

meadows or forest 

types. Small, isolated 

between subspecies in the field and their intermixing during 

migration, the range limits of the subspecies extimus are not 

fully understood (Bosworth 2003). The subspecies of willow 

flycatchers that occur in high elevation areas of central Utah 

may be either Empidonax traillii extimus or E. t. adastus 

(USFWS 2002a), though it is likely the adastus subspecies 

(Bosworth 2003). 

patches of willow 

shrubs may occur but 

dense, extensive 

stands of willows are 

not present. In 

addition, the Project 

Area is above the 

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Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification Biological Assessment 

Species and Status Habitat and Distribution Consideration for 

Analysis 

The closest designated critical habitat is located in southern 

Utah 170 miles to the south of the Project. 

upper elevational limit 

for this species. 

Yellow-billed The Western U.S. DPS historically bred throughout riparian areas Not considered. 

Cuckoo (Coccyzus west of the Continental Divide, but is currently found only in The species does 

americanus), 

Western U.S. 

scattered locations within this range. It is a riparian obligate that 

nests almost exclusively in large tracts of low to moderate 

elevation riparian woodlands with native broadleaf trees and 

not occur in the 

Project Area. 

Distinct Population shrubs, most commonly in cottonwood-willow-dominated The Project Area is 

Segment (DPS) woodlands (Halterman et al. 2015). Suitable breeding habitat in above the upper 

Threatened 

Utah is multi-layered riparian woodlands (with a tree overstory 

and shrubby understory) and at least 12 acres (five hectares) in 

size. The species is typically found below 8,500 feet USFWS 

elevational limit for 

this species and 

(Emery and 2015). there are no 

Sanpete counties) The closest critical habitat proposed for this species is 85 miles to 

the northeast along the Green River. 

cottonwooddominated riparian 

woodlands present. 

Fish 

Bonytail Chub (Gila Historically, bonytail chub inhabited the larger rivers of the Upper Considered. This 

elegans) and Lower Colorado River Basin. Currently, there are no selfsustaining populations of bonytail that exist in the wild, and few species does not occur 

in the Project Area, as 

Endangered individuals have been caught throughout the Colorado River there is no large river 

(Emery and Sanpete Basin (USFWS 2012b). In the Upper Colorado River Basin, habitat, and the Project 

counties) stocking occurs in the Green and Colorado rivers (UCREFRP 

2015). 

The closest designated critical habitat to the Project area is 65 

miles to the east in Desolation/Gray Canyon (Green River). 

Area is outside the 

species’ geographic 

range. 

However, this species 

is addressed further in 

order to analyze the 

potential for 

underground mining 

result in water 

depletions and the 

associated potential 

effect on downstream 

waters in the Action 

Area. 

Colorado Historically, this species was abundant in the main stem of the Considered. This 

Pikeminnow Upper and Lower Colorado River and most of its major species does not 

(=squawfish) tributaries (UCREFRP 2015b). In the Upper Colorado River occur in the Project 

(Ptychoceilus lucius) Basin, wild, reproducing populations occur in the Green, 

Colorado, and San Juan river subbasins (USFWS 2002b). 

Area because there is 

no large river habitat 

Endangered 

(Emery and 

Sanpete counties) 

The closest designated critical habitat to the Project area is the 

Green River, located 65 miles to the east. 

and the Project is 

outside the species’ 

geographic range. 

However, this 

species is addressed 

further in order to 

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Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification Biological Assessment 

Species and Status Habitat and Distribution Consideration for 

Analysis 

analyze the potential 

for the underground 

mining to result in 

water depletions and 

the associated 

potential effect on 

downstream waters 

in the Action Area. 

Humpback Historically, this species inhabited the swift and turbulent Considered. This 

Chub (Gila waters in canyons of the Colorado River Basin, including the species does not 

cypha) Colorado, Green, Yampa, and Little Colorado River (UCREFRP 

2015c). In the Upper Colorado River Basin there are currently 

occur in the Project 

Area because there is 

Endangered five self-sustaining populations (USFWS 2011a). The closest to no large river habitat 

(Emery and the Project Area is in Desolation/Gray Canyon on the Green and the Project is 

Sanpete counties) River, located 65 miles to the east. It is also designated critical 

habitat. 

outside the species’ 

geographic range. 

However, this 

species is addressed 

further in order to 

analyze the potential 

for underground 

mining result in water 

depletions and the 

associated potential 

effect on downstream 

waters in the Action 

Area. 

Razorback Sucker Historically, this species was widely distributed in warm-water Considered. This 

(Xyrauchen reaches of larger rivers of the Upper and Lower Colorado River species does not 

texanus) basins. In the Upper Colorado River basin it is currently found 

in small numbers in the Green, Colorado, and San Juan river 

occur in the Project 

Area because there is 

Endangered basins (USFWS 2002c). All populations in the Upper Colorado no large river habitat 

(Emery and River Basin are currently supplemented with stocked fish and the Project is 

Sanpete counties) (UCREFRP 2015d). 

The closest designated critical habitat to the Project area is the 

Green River, located 65 miles to the east. 

outside the species’ 

geographic range. 

However, this 

species is addressed 

further in order to 

analyze the potential 

for underground 

mining to result in 

water depletions and 

the associated 

potential effect on 

downstream waters in 

the Action Area. 

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Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification Biological Assessment 

Species and Status Habitat and Distribution Consideration for 

Analysis 

Plants 

Barneby Reed- This species is endemic to Wayne and Emery counties in Utah. Not Considered. 

mustard Populations occur on the Moenkopi Formation, Kaibab This plant does not 

(Schoenocrambe Limestone, and on the Carmel Formation on coarse soils occur in the Project 

barnebyi) derived from cobble and gravel river terrace deposits, or rocky Area. 

Endangered 

(Emery 

County) 

surfaces. It grows in desert shrublands with shadscale, Indian 

ricegrass, and pygmy sagebrush. Elevation range is 4,800 to 

6,500 feet (USFWS 2011b). 

No critical habitat has been designated for this species 

No desert scrub 

habitat is present 

and the Project Area 

is above the upper 

elevational limit of 

this species. 

Jones Cycladenia The jonesii variety of this species is known from five different Not Considered. 

(Cycladenia humillis areas in Arizona and Utah. It grows on gypsiferous, saline soils This plant does not 

var. jonesii) of the Cutler, Summerville, and Chinle formations. Typical plant occur in the Project 

communities where it occurs include mixed desert scrub, Area. 

Threatened 

(Emery 

County) 

juniper, or wild buckwheat-Mormon tea. Elevation range is 

4,390 to 6,000 feet in elevation (USFWS 2008) 

No critical habitat has been designated for this species 

No desert scrub or 

juniper habitat is 

present and the 

Project Area above 

upper elevational limit 

of this species. The 

two sites known from 

Emery County, Utah 

occur on lower 

elevation BLM lands 

(USFWS 2008). 

None of the listed bird or plant species or their critical habitats occur in the Project Area or area of estimated 

subsidence. They will not be evaluated further in this analysis. 

The potential effects of subsidence on federally listed fish within the Upper Colorado River Basin are considered 

in this analysis. 

5.0 EFFECTS ANALYSIS 

All mining activities would be underground; mining would continue at current levels for an additional 10.5 years. 

There would be no new surface development. No direct or indirect effects from surface disturbance activities or 

above ground noise would occur. Mining-related subsidence may occur within the estimated subsidence area 

shown on Figure 1. General effects of subsidence on water resources were evaluated. In general, subsidence 

may affect groundwater and quantity of surface water and by altering spring discharge locations, or changing 

stream gradient and morphology. Pooling of water and increased deposition of sediment, or reductions in surface 

flows could result in degraded water quality. 

The potential for subsidence to occur as a result of underground mining activities was evaluated. The potential 

has been found to be low due to the thickness of the overburden (greater than 1,000 feet) and past experience in 

other portions of the Skyline Mine (Petersen 2014). Petersen Hydrologic completed a recent study on 

December 28, 2015 7 
 

 

 

 

 

 

 

 

 

 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification Biological Assessment 

groundwater and surface water, and analyzed probable hydrologic consequences (Petersen 2014). The springs 

and streams in the Project Area discharge from a shallow active-zone groundwater system, which has active 

groundwater flow from recharge to surface discharge areas. 

Below the active zone, an impermeable layer is present, which prevents downward migration of active-zone 

groundwater into deeper horizons and also creates perched groundwater conditions in this deeper layer of strata. 

This inactive groundwater zone contains 2,000 to 19,000-year old groundwater that is independent of seasonal 

precipitation or short-term climatic variability at the surface. The inactive zone is not part of a regionally 

continuous aquifer but occurs in isolated partitions in the bedrock. The water from active and inactive zones 

underlying the Project Area and area of estimated subsidence do not interact, rather these zones are 

independent. Mining would occur in the inactive zone where groundwater is isolated from interactions with surface 

waters. Groundwater intercepted during underground mining would be from the perched inactive zone and not 

from the active surface water zone. Therefore, no measurable decrease in the flow of surface streams or springs 

is expected. This has been the case in previously mined areas of the Skyline Mine, and was specifically studied at 

Burnout Canyon, which has similar hydrogeologic conditions. In addition, mining has made available water from 

the inactive zone that was previously unavailable, but is now discharged at a rate of several thousands of gallons 

per minute. The amount of water that is discharged would gradually diminish over time as the water encountered 

underground in the mine is removed. 

Petersen (2014) concluded that availability of surface water would not be affected by underground mining 

associated with the Proposed Action. No downward water migration or loss of springs or other surface waters is 

anticipated following underground mining. Therefore, there would be no loss of water in the Project Area nor in 

the Action Area (Upper Colorado River Basin). 

Skyline Mine currently discharges water into Electric Lake and Eccles Creek to minimize water flowing into the 

mine. Underground water encountered during mining of the Project Area would also be discharged to these 

locations. The outfall which discharges to Eccles Creek is both the continuous pumped groundwater and 

stormwater runoff from the mine. Because the mine water is comingled with stormwater, the discharge is run 

through a small sedimentation pond as a best management practice. The mine monitors its discharge into Electric 

Lake and Eccles Creek, as well as the condition of other streams and springs, and implements a sediment control 

program for these discharge areas (BLM 2002; USFS and BLM 2002; Petersen 2014). Water quality and 

discharge flow would continue to be monitored under a Utah Pollutant Discharge Elimination System permit (BLM 

2002). 

Potential effects on surface water quality, or changes in stream morphology or spring discharge locations are not 

anticipated, but should they occur, they would be limited and localized within the estimated subsidence area. As 

discussed above, the geology of the area greatly reduces the risk of subsidence, and during the 30 years of 

mining at Skyline Mine, there have been no impacts to surface water resource from subsidence. Although impacts 

are not anticipated, impacts may occur from potential subsidence cracks. In the past, fractures were observed 

after mining in the Trough Springs Ridge area. Tension fractures opened in a zone that was 1,500 feet long with 

fractures that were several inches to five feet wide and up to 200 feet long. The fractures created a short-term 

safety hazard, but were mitigated by filling in with soil and no long-term adverse impact was expected. If 

subsidence cracks do occur in the Flat Canyon lease area, they would likely be minor and self-healing. They 

would not affect the endangered Colorado River fish because the fish occur at least 80 miles downstream of the 

Project Area. Potential effects of the Proposed Action would not affect listed fish downstream in larger rivers of 

the Colorado River system. 

In addition, special stipulations of the lease approval require monitoring of perennial stream gradients and 

associated effects to aquatic ecosystems and wetlands (BLM 2002). Mitigation measures are required if 

detrimental effects are discovered during monitoring (BLM 2002). The special stipulations also require the 

replacement of any surface or developed groundwater source that may be lost or adversely affected by mining 

December 28, 2015 8 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification Biological Assessment 

(USFS and BLM 2002; BLM 2002). Currently, springs or spring-fed water tanks and streams are monitored or 

proposed for monitoring (Petersen 2014). 

For these reasons, effects on water quality and quantity due to subsidence would be negligible, and would be 

mitigated if effects do occur. Therefore, there would be no effect to bonytail chub (Gila elegans), Colorado 

pikeminnow (Ptychoceilus lucius), humpback chub (Gila cypha), or razorback sucker (Xyrauchen texanus) or their 

downstream critical habitat. 

6.0 CONCLUSION AND DETERMINATION OF EFFECTS 

The Proposed Action would have no effect on any of the nine federally listed species. No critical habitat is present 

in the Project Area, and no critical habitat in the Action Area would be destroyed or adversely modified. Formal 

consultation with USFWS is not required. Table 2 lists the Section 7 effects determinations for the nine federally 

listed species and critical habitat identified for the Project, as well as the rationale for the determinations. 

Table 2. Effects Determinations 

Species Effects Determination for Species Effects Determination for 

Critical Habitat 

Birds 

Mexican Spotted Owl No Effect. This species would not occur in 

the portions of the Action Area considered 

for effects (i.e., the Project Area). 

No destruction or adverse modification. 

There is no critical habitat within 140 miles 

of the effects analysis area. 

Southwestern 

Willow Flycatcher 

No Effect. This species would not occur in 

the portions of the Action Area considered 

for effects (i.e., the Project Area). 

No destruction or adverse modification. 

There is no critical habitat within 170 miles 

of the effects analysis area. 

Yellow-billed 

Cuckoo, Western 

U.S. DPS 

No Effect. This species would not occur in 

the portions of the Action Area considered 

for effects (i.e., the Project Area). 

No destruction or adverse modification. 

There is no critical habitat within 85 miles 

of the effects analysis area. 

Fish 

Bonytail Chub No Effect. This species would not occur in 

the Project Area Individuals in the Action 

Area (i.e., Upper Colorado River Basin) 

would not be affected by water depletions 

since none are anticipated. 

No destruction or adverse modification. 

There is no critical habitat in the Project 

Area. No water depletions would occur; 

therefore, there would be no adverse 

modification to critical habitat downstream in 

the Action Area. 

Colorado Pikeminnow No Effect. This species would not occur in 

the Project Area. Individuals in the Action 

Area (i.e., Upper Colorado River Basin) 

would not be affected by water depletions 

since none are anticipated. 

No destruction or adverse modification. 

There is no critical habitat in the Project 

Area. No water depletions would occur; 

therefore, there would be no adverse 

modification to critical habitat downstream in 

the Action Area. 

December 28, 2015 9 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification Biological Assessment 

Species Effects Determination for Species Effects Determination for 

Critical Habitat 

Humpback Chub No Effect. This species would not occur in 

the Project Area Individuals in the Action 

Area (i.e., Upper Colorado River Basin) 

would not be affected by water depletions 

since none are anticipated. 

No destruction or adverse modification. 

There is no critical habitat in the Project 

Area. No water depletions would occur; 

therefore, there would be no adverse 

modification to critical habitat downstream in 

the Action Area. 

Razorback Sucker No Effect. This species would not occur in 

the Project Area. Individuals in the Action 

Area (i.e., Upper Colorado River Basin) 

would not be affected by water depletions 

since none are anticipated. 

No destruction or adverse modification. 

There is no critical habitat in the Project 

Area. No water depletions would occur; 

therefore, there would be no adverse 

modification to critical habitat downstream in 

the Action Area. 

Plants 

Barneby Reed-mustard No Effect. This species would not occur in 

the portions of the Action Area considered for 

effects (i.e., the Project Area). 

N/A 

Jones Cycladenia No Effect. This species would not occur in 

the portions of the Action Area considered for 

effects (i.e., the Project Area). 

N/A 

December 28, 2015 10 
 

 

 

 

 

 

 

 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification Biological Assessment 

7.0 LITERATURE CITED 

Alpine Ecological. 2015. U.S. Fish and Wildlife Service’s Species by County Review, Skyline Mine, Carbon 

County, Utah. Alpine Ecological, Greenwich, Utah. 7 p. October 2015. 

Bosworth, W.R. 2003. Vertebrate Information Compiled by the Utah Natural Heritage Program. Utah Division of 

Wildlife Resources, Publication 03-45. December 2003. 

Bureau of Land Management (BLM). 2002. Record of Decision. Federal Lease Sale Offering: “Flat Canyon Coal 

Tract” (UTU-77114). U.S. Department of the Interior, Bureau of Land Management, Utah State Office. 

Salt Lake City, Utah. 12 p. 

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: United States Fish 

and Wildlife Techniques and Methods, 45 p. 

Petersen, E.C. 2014. Investigation of Groundwater and Surface-Water Systems in the Flat Canyon Tract and 

Adjacent Area; Probably Hydrologic Consequences of Coal Mining in the Flat Canyon Tract. Petersen 

Hydrologic, LLC, Lehi, Utah. 42 p. + appendices. 

Upper Colorado River Endangered Fish Recovery Program (UCREFRP). 2015a. Bonytail (Gila elegans). 

Accessed: October 28, 2015. Available at: http://www.coloradoriverrecovery.org/generalinformation/the-fish/bonytail.html 

Upper Colorado River Endangered Fish Recovery Program (UCREFRP). 2015b. Colorado pikeminnow 

(Ptychocheilus lucius). Accessed: October 28, 2015. Available at: 

http://www.coloradoriverrecovery.org/general-information/the-fish/bonytail.html 

Upper Colorado River Endangered Fish Recovery Program (UCREFRP). 2015c. Humpback chub (Gila cypha). 

Accessed: October 28, 2015. Available at: http://www.coloradoriverrecovery.org/generalinformation/the-fish/humpback-chub.html 

Upper Colorado River Endangered Fish Recovery Program (UCREFRP). 2015d. Razorback sucker (Xyrauchen 

texanus). Accessed: October 28, 2015. Available at: http://www.coloradoriverrecovery.org/generalinformation/the-fish/razorback-sucker.html 

U.S. Fish and Wildlife Service (USFWS). 2002a. Southwestern Willow Flycatcher Recovery Plan. Albuquerque, 

New Mexico. 210 p. + Appendices. 

U.S. Fish and Wildlife Service (USFWS). 2002b. Colorado pikeminnow (Ptychocheilus lucius) Recovery Goals: 

amendment and supplement to the Colorado Squawfish Recovery Plan. United States Fish and Wildlife 

Service, Mountain-Prairie Region (6), Denver, Colorado. 

U.S. Fish and Wildlife Service (USFWS). 2002c. Razorback sucker (Xyrauchen texanus) Recovery Goals: 

Amendment and supplement to the Razorback Sucker Recovery Plan. United States Fish and Wildlife 

Service, Mountain-Prairie Region (6), Denver, Colorado. 

U.S. Fish and Wildlife Service (USFWS). 2008. Recovery Outline for the Jones Cycladenia (Cycladenia humilis 

var. jonesii). December 2008. 

U.S. Fish and Wildlife Service (USFWS). 2011a. Humpback chub (Gila cypha) 5-Year Review: Summary and 

Evaluation. United States Fish and Wildlife Service. Upper Colorado River Endangered Fish Recovery 

Program, Denver, Colorado. 

December 28, 2015 11 
 

 

 

Skyline Mine Flat Canyon Coal Lease Tract Mining Plan Modification Biological Assessment 

U.S. Fish and Wildlife Service (USFWS). 2011b. Schoenorcrambe barnebyi (Barneby Reed-Mustard) 5-Year 

Review: Summary and Evaluation. U.S. Fish and Wildlife Service, Utah Field Office – Ecological 

Services, West Valley, Utah. July 2011. 46 p 

U.S. Fish and Wildlife Service (USFWS). 2012a. Final Recovery Plan for the Mexican Spotted Owl (Strix 

occidentalis lucida), First Revision. United States Fish and Wildlife Service. Albuquerque, New Mexico, 

USA. 413 pp. 

U.S. Fish and Wildlife Service (USFWS). 2012b. Bonytail (Gila elegans) 5-Year Review: Summary and 

Evaluation. Upper Colorado River Endangered Fish Recovery Program, Denver, Colorado. July 2012. 

U.S. Fish and Wildlife Service (USFWS). 2014. Southwestern Willow Flycatcher 5-Year Review: Summary and 

Evaluation. U.S. Fish and Wildlife Service, Arizona Ecological Services Office, Phoenix, Arizona. 

U.S. Fish and Wildlife Service (USFWS). 2015. Guidelines for identification of suitable breeding and nesting 

habitat for western yellow-billed cuckoo in Utah. United States Fish and Wildlife Service, Utah 

Ecological Field Office. June 2015. 

U.S. Forest Service and Bureau of Land Management (USFS and BLM). 2002. Flat Canyon Federal Coal Lease 

Tract (UTU-77114) Final Environmental Impact Statement. USDA Forest Service, Intermountain 

Region, Manti-La Sal National Forest. January 2002. 

U.S. Forest Service (USFS). 2010. Annual monitoring report for the Manti La Sal National Forest Land and 

Resource Management Plan. USDA Forest Service, Price, Utah. 

December 28, 2015 12 
APPENDIX A – USFWS OFFICIAL IPAC LIST FOR THE PROJECT 
United States Department of the Interior

FISH AND WILDLIFE SERVICE

Utah Ecological Services Field Office

2369 WEST ORTON CIRCLE, SUITE 50

WEST VALLEY CITY, UT 84119

PHONE: (801)975-3330 FAX: (801)975-3331

URL: www.fws.gov; www.fws.gov/utahfieldoffice/

Consultation Code: 06E23000-2016-SLI-0029 November 02, 2015

Event Code: 06E23000-2016-E-00061

Project Name: Skyline Mine - Mining Plan Modification EA

Subject: List of threatened and endangered species that may occur in your proposed project

location, and/or may be affected by your proposed project

To Whom It May Concern:

The enclosed species list identifies threatened, endangered, proposed and candidate species, as

well as proposed and final designated critical habitat, that may occur within the boundary of

your proposed project and/or may be affected by your proposed project. The species list fulfills

the requirements of the U.S. Fish and Wildlife Service (Service) under section 7(c) of the

Endangered Species Act (Act) of 1973, as amended (16 U.S.C. 1531 ). et seq.

New information based on updated surveys, changes in the abundance and distribution of

species, changed habitat conditions, or other factors could change this list. Please feel free to

contact us if you need more current information or assistance regarding the potential impacts to

federally proposed, listed, and candidate species and federally designated and proposed critical

habitat. Please note that under 50 CFR 402.12(e) of the regulations implementing section 7 of

the Act, the accuracy of this species list should be verified after 90 days. This verification can

be completed formally or informally as desired. The Service recommends that verification be

completed by visiting the ECOS-IPaC website at regular intervals during project planning and

implementation for updates to species lists and information. An updated list may be requested

through the ECOS-IPaC system by completing the same process used to receive the enclosed

list.

The purpose of the Act is to provide a means whereby threatened and endangered species and

the ecosystems upon which they depend may be conserved. Under sections 7(a)(1) and 7(a)(2)

of the Act and its implementing regulations (50 CFR 402 ), Federal agencies are required et seq.

to utilize their authorities to carry out programs for the conservation of threatened and

endangered species and to determine whether projects may affect threatened and endangered

species and/or designated critical habitat.
A Biological Assessment is required for construction projects (or other undertakings having

similar physical impacts) that are major Federal actions significantly affecting the quality of the

human environment as defined in the National Environmental Policy Act (42 U.S.C. 4332(2)

(c)). For projects other than major construction activities, the Service suggests that a biological

evaluation similar to a Biological Assessment be prepared to determine whether the project may

affect listed or proposed species and/or designated or proposed critical habitat. Recommended

contents of a Biological Assessment are described at 50 CFR 402.12.

If a Federal agency determines, based on the Biological Assessment or biological evaluation,

that listed species and/or designated critical habitat may be affected by the proposed project, the

agency is required to consult with the Service pursuant to 50 CFR 402. In addition, the Service

recommends that candidate species, proposed species and proposed critical habitat be addressed

within the consultation. More information on the regulations and procedures for section 7

consultation, including the role of permit or license applicants, can be found in the "Endangered

Species Consultation Handbook" at:

http://www.fws.gov/endangered/esa-library/pdf/TOC-GLOS.PDF

Please be aware that bald and golden eagles are protected under the Bald and Golden Eagle

Protection Act (16 U.S.C. 668 ), and projects affecting these species may require et seq.

development of an eagle conservation plan

(http://www.fws.gov/windenergy/eagle_guidance.html). Additionally, wind energy projects

should follow the wind energy guidelines (http://www.fws.gov/windenergy/) for minimizing

impacts to migratory birds and bats.

Guidance for minimizing impacts to migratory birds for projects including communications

towers (e.g., cellular, digital television, radio, and emergency broadcast) can be found at:

http://www.fws.gov/migratorybirds/CurrentBirdIssues/Hazards/towers/towers.htm;

http://www.towerkill.com; and

http://www.fws.gov/migratorybirds/CurrentBirdIssues/Hazards/towers/comtow.html.

We appreciate your concern for threatened and endangered species. The Service encourages

Federal agencies to include conservation of threatened and endangered species into their project

planning to further the purposes of the Act. Please include the Consultation Tracking Number in

the header of this letter with any request for consultation or correspondence about your project

that you submit to our office.

Attachment

2
http://ecos.fws.gov/ipac, 11/02/2015 01:59 PM

1

Official Species List

Provided by:

Utah Ecological Services Field Office

2369 WEST ORTON CIRCLE, SUITE 50

WEST VALLEY CITY, UT 84119

(801) 975-3330

http://www.fws.gov 

http://www.fws.gov/utahfieldoffice/

Consultation Code: 06E23000-2016-SLI-0029

Event Code: 06E23000-2016-E-00061

Project Type: MINING

Project Name: Skyline Mine - Mining Plan Modification EA

Project Description: The OSMRE will prepare an EA for a mine plan modification for the Canyon

Fuel Co.'s Skyline Mine. Skyline Mine is an underground coal operation proposing to modify their

min permit to include 2,692 acres of federal coal within the Flat Canyon Coal Lease Tract, and

1,100 acres of private coal reserves. The majority of this coal could be mined using long wall

mining technology. No surface disturbance or water withdrawals are proposed at this time.

Please Note: The FWS office may have modified the Project Name and/or Project Description, so it

may be different from what was submitted in your previous request. If the Consultation Code

matches, the FWS considers this to be the same project. Contact the office in the 'Provided by'

section of your previous Official Species list if you have any questions or concerns.

United States Department of Interior

Fish and Wildlife Service

Project name: Skyline Mine - Mining Plan Modification EA
http://ecos.fws.gov/ipac, 11/02/2015 01:59 PM

2

Project Location Map: 

Project Coordinates: MULTIPOLYGON (((-111.24750287113136 39.68227894306945, -

111.24790034105413 39.63904737137909, -111.23797525414733 39.63906812828951, -

111.2310656651646 39.62145253928513, -111.28508835346888 39.6213432497518, -

111.28522481644228 39.639486890535935, -111.27132774324481 39.639336396668526, -

111.27147810989962 39.66507877834774, -111.26682190464679 39.665083989017674, -

111.26682311760204 39.665139126044096, -111.25687490105874 39.664264053442885, -

111.2569094009873 39.68233370037775, -111.24750287113136 39.68227894306945)))

Project Counties: Emery, UT | Sanpete, UT

United States Department of Interior

Fish and Wildlife Service

Project name: Skyline Mine - Mining Plan Modification EA
http://ecos.fws.gov/ipac, 11/02/2015 01:59 PM

3

Endangered Species Act Species List

There are a total of 9 threatened or endangered species on your species list. Species on this list should be considered in

an effects analysis for your project and could include species that exist in another geographic area. For example, certain

fish may appear on the species list because a project could affect downstream species. Critical habitats listed under the

Has Critical Habitat column may or may not lie within your project area. See the Critical habitats within your

project area section further below for critical habitat that lies within your project. Please contact the designated FWS

office if you have questions.

Birds Status Has Critical Habitat Condition(s)

Mexican Spotted owl (Strix

occidentalis lucida)

 Population: Entire

Threatened Final designated

Southwestern Willow flycatcher

(Empidonax traillii extimus)

 Population: Entire

Endangered Final designated

Yellow-Billed Cuckoo (Coccyzus

americanus)

 Population: Western U.S. DPS

Threatened Proposed

Fishes

Bonytail chub (Gila elegans)

 Population: Entire

Endangered Final designated

Colorado pikeminnow (Ptychocheilus

lucius)

 Population: Entire, except EXPN

Endangered Final designated

Humpback chub (Gila cypha)

 Population: Entire

Endangered Final designated

Razorback sucker (Xyrauchen Endangered Final designated

United States Department of Interior

Fish and Wildlife Service

Project name: Skyline Mine - Mining Plan Modification EA
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4

texanus)

 Population: Entire

Flowering Plants

Barneby reed-mustard

(Schoenocrambe barnebyi)

Endangered

Jones Cycladenia (Cycladenia humilis

var. jonesii)

Threatened

United States Department of Interior

Fish and Wildlife Service

Project name: Skyline Mine - Mining Plan Modification EA
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5

Critical habitats that lie within your project area

There are no critical habitats within your project area.

United States Department of Interior

Fish and Wildlife Service

Project name: Skyline Mine - Mining Plan Modification EA