United States Department of the Interior

Office of Surface Mining Reclamation and Enforcement

Dry Fork Mine

Amendment 2, Tract 1

Federal Mining Plan Modification

Environmental Assessment

December 2017

Prepared by:

U.S. Department of the Interior

Office of Surface Mining Reclamation and Enforcement Program Support Division

1999 Broadway, Suite 3320

Denver, CO 80202

PH: 303-293-5000 / FAX: 303-293-5032
Dry Fork Mine A2Tr1 EA i

TABLE OF CONTENTS

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

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

1.2 Background.....................................................................................................................................1-2

1.2.1 Site History...........................................................................................................................1-2

1.2.2 Project Background.............................................................................................................1-6

1.2.3 Statutory and Regulatory Background............................................................................1-7

1.3 Purpose and Need ........................................................................................................................1-8

1.3.1 Purpose..................................................................................................................................1-8

1.3.2 Need.......................................................................................................................................1-8

1.4 Relationship to Statutes, Regulations, and Other Agency Plans.........................................1-8

1.4.1 Statutes and Regulations....................................................................................................1-8

1.4.2 Other Agency Plans..........................................................................................................1-10

1.5 Authorizing Actions....................................................................................................................1-11

1.6 Outreach and Issues...................................................................................................................1-11

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

2.1 DFM WDEQ-LQD Permit..........................................................................................................2-1

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

2.3 Description of Existing Mining and Reclamation Operations..............................................2-3

2.3.1 Current Bonding and Bond Release Status ...................................................................2-5

2.3.2 DFM Support Facilities.......................................................................................................2-6

2.4 Description of Alternatives.........................................................................................................2-6

2.4.1 Proposed Action..................................................................................................................2-7

2.4.1.1 Mine Operation Components within the Project Area Associated with the 

Proposed Action ..............................................................................................................2-8

2.4.1.2 Existing and Proposed Disturbance within the Project Area ................................2-8

2.4.1.3 Mining Operations Associated with the Proposed Action.....................................2-9

2.4.2 No Action Alternative........................................................................................................2-9

2.4.3 Alternatives Considered but Eliminated from Further Study .................................2-10

2.4.3.1 Underground Mining Alternative ...............................................................................2-10

2.4.3.2 Low or No Pollutant Emitting Equipment................................................................2-11

2.4.3.3 Air Quality Mitigation Alternatives............................................................................2-11
TABLE OF CONTENTS (Cont.)

Dry Fork Mine A2Tr1 EA ii

2.4.4 Project Environmental Protection and Mitigation Features.....................................2-11

2.4.4.1 Topography .....................................................................................................................2-12

2.4.4.2 Air Quality.......................................................................................................................2-12

2.4.4.3 Water Resources...........................................................................................................2-12

2.4.4.4 Vegetation........................................................................................................................2-13

2.4.4.5 Terrestrial Wildlife........................................................................................................2-13

2.4.4.6 Fish/Aquatic Life .............................................................................................................2-14

2.4.4.7 Threatened and Endangered Species.........................................................................2-14

2.4.4.8 Cultural Resources........................................................................................................2-14

2.4.4.9 Visual Resources............................................................................................................2-14

2.4.4.10 Soils...................................................................................................................................2-14

2.4.4.11 Post-mining Land Use ...................................................................................................2-15

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

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

3.2 Topography and Physiography ...................................................................................................3-2

3.3 Geology, Minerals, and Paleontology........................................................................................3-4

3.3.1 General Geology .................................................................................................................3-4

3.3.2 Mineral Resources...............................................................................................................3-9

3.3.3 Paleontology .......................................................................................................................3-10

3.4 Air Quality ....................................................................................................................................3-11

3.4.1 National Ambient Air Quality Standards.....................................................................3-11

3.4.2 Attainment/Nonattainment Area Designations..........................................................3-13

3.4.3 Prevention of Significant Deterioration........................................................................3-14

3.4.4 Best Available Control Technology...............................................................................3-15

3.4.5 New Source Performance Standards (NSPS) .............................................................3-16

3.4.6 Federal Operating Permit Program...............................................................................3-16

3.4.7 Existing DFM Air Quality Summary ..............................................................................3-16

3.4.7.1 Background ....................................................................................................................3-16

3.4.7.2 Air Quality-Monitoring Values....................................................................................3-16

3.4.7.3 Air Quality Related Values...........................................................................................3-21

3.4.7.3.1 Visibility.....................................................................................................................3-21

3.4.7.3.2 Air Quality Related Values Related to Coal Combustion.............................3-21
TABLE OF CONTENTS (Cont.)

Dry Fork Mine A2Tr1 EA iii

3.4.7.3.3 Acidification of Lakes/Acid Deposition..............................................................3-21

3.4.7.4 Greenhouse Gases (GHG)..........................................................................................3-22

3.4.7.5 Emission Standards at Coal Combustion Sources..................................................3-23

3.5 Water Resources........................................................................................................................3-26

3.5.1 Surface Water....................................................................................................................3-26

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

3.5.2.1 Alluvium ...........................................................................................................................3-27

3.5.2.2 Clinker (Wyoming Porcelanite or Scoria) ...............................................................3-30

3.5.2.3 Wasatch (Overburden) Formation ..........................................................................3-30

3.5.2.4 Coal Aquifers..................................................................................................................3-31

3.5.2.5 Backfill Aquifer................................................................................................................3-31

3.5.3 Water Rights......................................................................................................................3-32

3.6 Wetlands/Aquatic Resources...................................................................................................3-33

3.7 Soils................................................................................................................................................3-33

3.8 Vegetation.....................................................................................................................................3-34

3.8.1 Vegetation Community Types........................................................................................3-34

3.8.2 Special Status Plant Species.............................................................................................3-38

3.9 Wildlife ..........................................................................................................................................3-40

3.9.1 Raptors................................................................................................................................3-40

3.9.2 Greater Sage-Grouse .......................................................................................................3-40

3.9.3 Threatened, Endangered, and Candidate Species, and Special Status Species.....3-42

3.9.3.1 Threatened, Endangered, and Candidate Species...................................................3-42

3.9.3.2 Other Species of Special Interest...............................................................................3-43

3.10 Land Use and Recreation ..........................................................................................................3-44

3.11 Cultural Resources.....................................................................................................................3-44

3.12 Visual Resources..........................................................................................................................3-44

3.13 Noise..............................................................................................................................................3-48

3.14 Transportation Facilities............................................................................................................3-48

3.15 Hazardous and Solid Wastes....................................................................................................3-50

3.16 Socioeconomics...........................................................................................................................3-52

3.16.1 Local Economy...................................................................................................................3-52

3.16.2 Environmental Justice .......................................................................................................3-52
TABLE OF CONTENTS (Cont.)

Dry Fork Mine A2Tr1 EA iv

3.16.3 Population ...........................................................................................................................3-54

3.16.4 Employment........................................................................................................................3-54

4.0 Environmental Consequences/Cumulative Effects...........................................4-1

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

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

4.2 Topography and Physiography....................................................................................................4-6

4.2.1 Direct and Indirect Effects ................................................................................................4-6

4.2.1.1 Proposed Action ..............................................................................................................4-6

4.2.1.2 No Action Alternative....................................................................................................4-6

4.2.2 Cumulative Effects...............................................................................................................4-6

4.2.3 Mitigation Measures............................................................................................................4-6

4.3 Geology, Mineral Resources, and Paleontology......................................................................4-7

4.3.1 Direct and Indirect Effects ................................................................................................4-7

4.3.1.1 Proposed Action ..............................................................................................................4-7

4.3.1.2 No Action Alternative....................................................................................................4-7

4.3.2 Cumulative Effects...............................................................................................................4-8

4.3.3 Mitigation Measures............................................................................................................4-8

4.4 Air Quality ......................................................................................................................................4-8

4.4.1 Particulate Matter................................................................................................................4-8

4.4.1.1 Direct and Indirect Effects.............................................................................................4-8

4.4.1.1.1 Proposed Action.......................................................................................................4-8

4.4.1.1.2 No Action Alternative...........................................................................................4-10

4.4.1.2 Cumulative Effects.........................................................................................................4-10

4.4.1.3 Mitigation Measures ......................................................................................................4-12

4.4.2 Emissions of Carbon Monoxide (CO), Sulfur Dioxide (SO2), and Lead (Pb) ......4-12

4.4.2.1 Direct and Indirect Effects...........................................................................................4-12

4.4.2.1.1 Proposed Action.....................................................................................................4-12

4.4.2.1.2 No Action Alternative...........................................................................................4-13

4.4.2.2 Cumulative Effects.........................................................................................................4-13

4.4.2.3 Mitigation Measures ......................................................................................................4-13

4.4.3 Emissions of Nitrogen Oxides (NOX) and O3 ............................................................4-13

4.4.3.1 Direct and Indirect Effects...........................................................................................4-13
TABLE OF CONTENTS (Cont.)

Dry Fork Mine A2Tr1 EA v

4.4.3.1.1 Proposed Action.....................................................................................................4-13

4.4.3.1.2 No Action Alternative...........................................................................................4-14

4.4.3.2 Cumulative Effects.........................................................................................................4-14

4.4.3.3 Mitigation Measures ......................................................................................................4-15

4.4.4 Air Quality Related Values (AQRVs)............................................................................4-15

4.4.4.1 Direct and Indirect Effects...........................................................................................4-15

4.4.4.1.1 Proposed Action.....................................................................................................4-15

4.4.4.1.2 No Action Alternative...........................................................................................4-16

4.4.4.2 Cumulative Effects.........................................................................................................4-16

4.4.4.3 Mitigation Measures ......................................................................................................4-17

4.4.5 Air Quality Related to Coal Combustion....................................................................4-17

4.4.5.1 Direct and Indirect Effects...........................................................................................4-17

4.4.5.1.1 Proposed Action.....................................................................................................4-17

4.4.5.1.2 No Action Alternative...........................................................................................4-19

4.4.5.2 Cumulative Effects.........................................................................................................4-19

4.4.6 Greenhouse Gas Emissions.............................................................................................4-19

4.4.6.1 Direct and Indirect Effects of the Proposed Action ..............................................4-19

4.4.6.1.1 Proposed Action.....................................................................................................4-19

4.4.6.1.2 No Action Alternative...........................................................................................4-21

4.4.6.2 Cumulative Effects.........................................................................................................4-21

4.4.6.3 Mitigation Measures ......................................................................................................4-21

4.4.7 Climate Change Cause and Effect..................................................................................4-21

4.4.7.1 Proposed Action/No Action Alternative..................................................................4-21

4.4.7.2 Cumulative Effects.........................................................................................................4-23

4.4.7.3 Direct and Indirect Effects on the Proposed Action/No Action Alternative...4-24

4.5 Water Resources........................................................................................................................4-25

4.5.1 Surface Water....................................................................................................................4-25

4.5.1.1 Direct and Indirect Effects...........................................................................................4-25

4.5.1.1.1 Proposed Action.....................................................................................................4-25

4.5.1.1.2 No Action Alternative...........................................................................................4-26

4.5.1.2 Cumulative Effects.........................................................................................................4-26

4.5.1.3 Mitigation Measures ......................................................................................................4-26
TABLE OF CONTENTS (Cont.)

Dry Fork Mine A2Tr1 EA vi

4.5.2 Groundwater......................................................................................................................4-28

4.5.2.1 Direct and Indirect Effects...........................................................................................4-28

4.5.2.1.1 Proposed Action.....................................................................................................4-28

4.5.2.1.2 No Action Alternative...........................................................................................4-30

4.5.2.2 Cumulative Effects.........................................................................................................4-30

4.5.2.3 Mitigation Measures ......................................................................................................4-31

4.5.3 Water Rights......................................................................................................................4-31

4.5.3.1 Direct and Indirect Effects...........................................................................................4-31

4.5.3.1.1 Proposed Action.....................................................................................................4-31

4.5.3.1.2 No Action Alternative...........................................................................................4-32

4.5.3.2 Cumulative Effects.........................................................................................................4-32

4.5.3.3 Mitigation Measures ......................................................................................................4-32

4.6 Alluvial Valley Floors ..................................................................................................................4-32

4.6.1 Direct and Indirect Effects ..............................................................................................4-32

4.6.1.1 Proposed Action ............................................................................................................4-32

4.6.1.2 No Action Alternative..................................................................................................4-33

4.6.2 Cumulative Effects.............................................................................................................4-33

4.6.3 Mitigation Measures..........................................................................................................4-33

4.7 Wetlands/Aquatic Resources...................................................................................................4-33

4.7.1 Direct and Indirect Effects ..............................................................................................4-33

4.7.1.1 Proposed Action ............................................................................................................4-33

4.7.1.2 No Action Alternative..................................................................................................4-33

4.7.2 Cumulative Effects.............................................................................................................4-33

4.7.3 Mitigation Measures..........................................................................................................4-34

4.8 Soil ..................................................................................................................................................4-34

4.8.1 Direct and Indirect Effects ..............................................................................................4-34

4.8.1.1 Proposed Action ............................................................................................................4-34

4.8.1.2 No Action Alternative..................................................................................................4-35

4.8.2 Cumulative Effects.............................................................................................................4-35

4.8.3 Mitigation Measures..........................................................................................................4-35

4.9 Vegetation.....................................................................................................................................4-35

4.9.1 Direct and Indirect Effects ..............................................................................................4-35
TABLE OF CONTENTS (Cont.)

Dry Fork Mine A2Tr1 EA vii

4.9.1.1 Proposed Action ............................................................................................................4-35

4.9.1.2 No Action Alternative..................................................................................................4-36

4.9.2 Cumulative Effects.............................................................................................................4-36

4.9.3 Mitigation Measures..........................................................................................................4-36

4.10 Wildlife ..........................................................................................................................................4-36

4.10.1 Big Game .............................................................................................................................4-37

4.10.1.1 Direct and Indirect Effects...........................................................................................4-37

4.10.1.1.1 Proposed Action...................................................................................................4-37

4.10.1.1.2 No Action Alternative.........................................................................................4-37

4.10.1.2 Cumulative Effects.........................................................................................................4-38

4.10.1.3 Mitigation Measures ......................................................................................................4-38

4.10.2 Raptors................................................................................................................................4-38

4.10.2.1 Direct and Indirect Effects...........................................................................................4-38

4.10.2.1.1 Proposed Action...................................................................................................4-38

4.10.2.1.2 No Action Alternative.........................................................................................4-39

4.10.2.2 Cumulative Effects.........................................................................................................4-39

4.10.2.3 Mitigation Measures ......................................................................................................4-39

4.10.3 Greater Sage-Grouse .......................................................................................................4-39

4.10.3.1 Direct and Indirect Effects...........................................................................................4-39

4.10.3.1.1 Proposed Action...................................................................................................4-39

4.10.3.1.2 No Action Alternative.........................................................................................4-40

4.10.3.2 Cumulative Effects.........................................................................................................4-40

4.10.3.3 Mitigation Measures ......................................................................................................4-41

4.10.4 Threatened, Endangered, and Candidate Species and Other Species of 

Special Interest...................................................................................................................4-41

4.10.4.1 Direct and Indirect Effects...........................................................................................4-41

4.10.4.1.1 Proposed Action...................................................................................................4-41

4.10.4.1.2 No Action Alternative.........................................................................................4-42

4.10.4.2 Cumulative Effects.........................................................................................................4-42

4.10.4.3 Mitigation Measures ......................................................................................................4-43

4.11 Ownership and Use of Land .....................................................................................................4-43

4.11.1 Direct and Indirect Effects ..............................................................................................4-43
TABLE OF CONTENTS (Cont.)

Dry Fork Mine A2Tr1 EA viii

4.11.1.1 Proposed Action ............................................................................................................4-43

4.11.1.2 No Action Alternative..................................................................................................4-43

4.11.2 Cumulative Effects.............................................................................................................4-43

4.11.3 Mitigation Measures..........................................................................................................4-43

4.12 Cultural Resources.....................................................................................................................4-44

4.12.1 Direct and Indirect Effects ..............................................................................................4-44

4.12.1.1 Proposed Action ............................................................................................................4-44

4.12.1.2 No Action Alternative..................................................................................................4-44

4.12.2 Cumulative Effects.............................................................................................................4-44

4.12.3 Mitigation Measures..........................................................................................................4-44

4.12.4 Unanticipated Discoveries...............................................................................................4-44

4.13 Noise..............................................................................................................................................4-45

4.13.1 Direct and Indirect Effects ..............................................................................................4-45

4.13.1.1 Proposed Action ............................................................................................................4-45

4.13.1.2 No Action Alternative..................................................................................................4-45

4.13.2 Cumulative Effects.............................................................................................................4-45

4.13.3 Mitigation Measures..........................................................................................................4-46

4.14 Visual Resources..........................................................................................................................4-46

4.14.1 Direct and Indirect Effects ..............................................................................................4-46

4.14.1.1 Proposed Action ............................................................................................................4-46

4.14.1.2 No Action Alternative..................................................................................................4-46

4.14.2 Cumulative Effects.............................................................................................................4-46

4.14.3 Mitigation Measures..........................................................................................................4-46

4.15 Transportation Facilities............................................................................................................4-47

4.15.1 Direct and Indirect Effects ..............................................................................................4-47

4.15.1.1 Proposed Action ............................................................................................................4-47

4.15.1.2 No Action Alternative..................................................................................................4-48

4.15.2 Cumulative Effects.............................................................................................................4-48

4.15.3 Mitigation Measures..........................................................................................................4-48

4.16 Hazardous and Solid Waste......................................................................................................4-48

4.16.1 Direct and Indirect Effects ..............................................................................................4-48

4.16.1.1 Proposed Action ............................................................................................................4-48
TABLE OF CONTENTS (Cont.)

Dry Fork Mine A2Tr1 EA ix

4.16.1.2 No Action Alternative..................................................................................................4-49

4.16.2 Cumulative Effects.............................................................................................................4-49

4.16.3 Mitigation Measures..........................................................................................................4-49

4.17 Socioeconomics...........................................................................................................................4-49

4.17.1 Direct and Indirect Effects ..............................................................................................4-49

4.17.1.1 Proposed Action ............................................................................................................4-49

4.17.1.2 No Action Alternative..................................................................................................4-50

4.17.2 Cumulative Effects.............................................................................................................4-50

4.17.3 Mitigation Measures..........................................................................................................4-51

4.18 Short Term Uses and Long Term Productivity ....................................................................4-51

4.19 Unavoidable Adverse Effects.....................................................................................................4-51

5.0 Consultation and Coordination...........................................................................5-1

5.1 Public Comment Process............................................................................................................5-1

5.2 Preparers and Contributors.......................................................................................................5-1

5.3 Distribution of the EA..................................................................................................................5-2

6.0 References and Abbreviations/Acronyms ..........................................................6-1

6.1 References......................................................................................................................................6-1

6.2 Abbreviations/Acronyms...........................................................................................................6-10

LIST OF TABLES

Table 1-1. Summary of Coal Shipment Reports at the DFM, 2011 through 2015....................1-6

Table 1-2. Public Outreach Comments Categorized by Key Resource Category .................1-12

Table 2-1. Summary of Phased Bond Release Acreages in the Project Area.............................2-6

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

and Employees for the Current WDEQ-LQD Permit No. PT0599, the No 

Action Alternative, and the Proposed Action as of December 31, 2015 ...............2-7

Table 2-3. Mine Life Scenarios for the Proposed Action................................................................2-7

Table 2-4. Summary of Mining Related Surface Disturbance in Project Area............................2-9

Table 2-5. Proposed Project Area Mine Plan ....................................................................................2-9

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

Table 3-2. Average Physical Characteristics of the Mineable Portions of the WyodakAnderson Coal Seam in the Area.....................................................................................3-9

Table 3-3. Federal and Wyoming Ambient Air Quality Standards.............................................3-13
TABLE OF CONTENTS (Cont.)

Dry Fork Mine A2Tr1 EA x

Table 3-4. Distances and Directions from the General Analysis Area to Sensitive Air 

Quality Areas......................................................................................................................3-15

Table 3-5. Historical PM10 Ambient Data (μg/m3) and Production, 2011-2015 (PM10

WAAQS: 50 μg/m3 Annual, 150 μg/m324-Hour).......................................................3-17

Table 3-6. Measured PM2.5 Concentrations1in Campbell County, Wyoming (2011-

2015).....................................................................................................................................3-18

Table 3-7. Estimated Annual High 24-Hour STP PM2.5 Concentrations (μg/m3) (PM2.5

WAAQS: 35 μg/m3 Annual, 24-hour)............................................................................3-18

Table 3-8. Estimated Annual Mean STP PM2.5 Concentrations (μg/m3) (Annual Mean 

PM2.5 WAAQS: 12 μg/m3; NAAQS: 12 μg/m3)............................................................3-19

Table 3-9. Measured O3 Concentrations (4th-Highest Daily Maximum Value) at 

Selected AQS Monitoring Sites1, 2011 – 2015 ............................................................3-19

Table 3-10. Measured NO2 Concentrations in Campbell County, Wyoming, 2011-

2015, 98th Percentile 1-Hour NO2 Concentrations (μg/m3) ....................................3-20

Table 3-11. Measured SO2 Concentrations in Campbell County, Wyoming, 2011-2015, 

99th Percentile 1-Hour NO2 Concentrations (μg/m3)..............................................3-20

Table 3-12. Measured Annual Hg Air Emissions from Power Stations in Campbell 

County (Pounds) ................................................................................................................3-20

Table 3-13. Measured Annual1Pb Air Emissions1from Power Stations and One Coal 

Mine in Campbell County ................................................................................................3-20

Table 3-14. Estimated Annual PM10, PM2.5, SO2, NOX, Hg, and CO Contributions from 

Combustion of Coal Mined at the DFM, 2011-2015 .................................................3-22

Table 3-15. Measured Hydrogen Ion (H+) Concentrations1at Monitoring Site WY99, 

2011–2015 ...........................................................................................................................3-22

Table 3-16. Estimated 2011-2016 Emissions from Direct and Indirect CO2e Sources1

at the DFM...........................................................................................................................3-24

Table 3-17. MATS Emission Requirements1for Coal-Fired Units................................................3-25

Table 3-18. Dry Fork Station Reported Emissions, 2011-2015.....................................................3-25

Table 3-19. List of Map Units and Topsoil Salvage Depths for the A2Tr1 Tract......................3-35

Table 3-20. Sage-grouse Strutting Ground Survey Results (Maximum Male Attendance) 

for the Dry Fork Mine ......................................................................................................3-43

Table 3-21. Campbell County and City of Gillette Population Change, 2000 to 2015............3-54

Table 3-22. Wyoming and Campbell County Employment Rate Change, 2000 to 2015 ........3-54

Table 4-1. Ownership, Permitted Acres, and Production of Mines Adjacent to the 

DFM.........................................................................................................................................4-2

Table 4-2. Ownership and Power Output of Power Plants Adjacent to the DFM...................4-2
TABLE OF CONTENTS (Cont.)

Dry Fork Mine A2Tr1 EA xi

Table 4-3. Summary Comparison of Direct and Indirect Environmental Impacts as 

Compared to the Existing DFM Federal Mining Plan...................................................4-3

Table 4-4. DFM Particulate Matter Dispersion Modeling Results (μg/m3)................................4-10

Table 4-5. Average Annual Campbell County Air Quality Index Values, 2011-2016.............4-17

Table 4-6. Estimated Annual PM10, PM2.5, SO2, NOX, Hg, and CO Contributions from 

Combustion of Coal Mined at the DFM for 2011-2016 and 2017-2053, 

Compared to Campbell County and U.S. Total Emissions.......................................4-18

Table 4-7. Mercury (Hg) Emissions (in Tons) from Seven Wyoming Coal Fired Power 

Plants, 2011-2015...............................................................................................................4-18

Table 4-8. Estimated Annual Equivalent CO2 (CO2e) Emissions1for the Proposed 

Action from Coal Mined at the DFM (2011 through 2016, and 2017-2053 

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

Table 4-9. LOM Federal and State Revenues from Federal Coal Recovery within the 

DFM.......................................................................................................................................4-49

Table 4-10. LOM Federal and State Revenues from Federal Coal Recovery within the 

A2Tr1 Tract ........................................................................................................................4-50

Table 4-11. Unavoidable Adverse Effects of the Proposed Action...............................................4-51

Table 5-1. OSMRE Personnel................................................................................................................5-1

Table 5-2. Third Party Contractor Personnel...................................................................................5-1

LIST OF FIGURES

Figure 3-1. Stratigraphic Relationship and Hydrologic Characteristics of Upper 

Cretaceous, Lower Tertiary and Recent Geologic Units of the Powder 

River Basin, Wyoming .........................................................................................................3-5

Figure 3-2. Geologic Cross Sections for the A2Tr1 Tract..............................................................3-6

Figure 3-3. Geologic Cross Sections for the A2Tr1 Tract..............................................................3-7

Figure 3-4. Visibility in the Northern Cheyenne Indian Reservation ..........................................3-22

Figure 3-5. Relationship Between A-Scale Decibel Readings and Sounds of Daily Life...........3-49

Figure 3-6. Estimated 2016 Wyoming and Federal Revenues from 2015 Coal 

Production in Campbell County.....................................................................................3-53

LIST OF MAPS

Map 1-1. General Location Map with Federal Coal Leases .........................................................1-3

Map 1-2. Dry Fork Mine’s Federal Coal Leases..............................................................................1-4

Map 2-1. Dry Fork Mine’s Mining Sequence at 6.0 Mtpy..............................................................2-2

Map 2-2. Dry Fork Mine’s Currently Approved Disturbance, Disturbance Through 

August 2016, and Reclamation by Bond Release Phase...............................................2-4
TABLE OF CONTENTS (Cont.)

Dry Fork Mine A2Tr1 EA xii

Map 3-1. Wind Rose and Air Quality and Meteorological Monitoring Stations at the 

DFM.........................................................................................................................................3-3

Map 3-2. Surficial Geology Associated with the DFM...................................................................3-8

Map 3-3. Regional Air Quality Monitoring Sites...........................................................................3-12

Map 3-4. Watersheds and Surface Drainages Associated with the DFM ...............................3-28

Map 3-5. Surface Water Drainages and Surface Water Monitoring Sites at the DFM........3-29

Map 3-6. Soil Types Associated with the A2Tr1 Tract...............................................................3-36

Map 3-7. Vegetation Map Units (Community Types) Associated with the A2Tr1 

Tract......................................................................................................................................3-37

Map 3-8. Wildlife Use Associated with the A2Tr1 Tract...........................................................3-41

Map 3-9. Surface Ownership within the A2Tr1 Tract................................................................3-45

Map 3-10. Oil and Gas Wells and Oil and Gas Ownership within the A2Tr1 Tract.............3-46

Map 3-11. Transportation Facilities Associated with the A2Tr1 Tract.....................................3-51

Map 4-1. Maximum Modeled PM10 and NO2 Concentrations...................................................4-11

Map 4-2. Cumulative Impact Area for Potential Surface and Groundwater Impacts ..........4-27

Map 4-3. Predicted Drawdowns for the Wyodak-Anderson Coal Seam...............................4-29

LIST OF APPENDICES

Appendix A Legal Notices for Federal Lease Modification Approval WYW-0271199, WYW0271200

Appendix B Public Scoping Mailing Lists, Public Scoping and A2Tr1 EA Review Comments 

Summaries and A2Tr1 EA Review Comment Response Log

Appendix C PM10, PM2.5, SO2, NOx, And Hg Contributions from Coal Combustion 

Calculations and Greenhouse Gas Emissions Calculations

Appendix D Surface Water Rights Within 2 Miles of the A2Tr1 Tract and Groundwater 

Rights Within 2 Miles of the A2Tr1 Tract

Appendix E Dry Fork Mine Observed Wildlife Species List Special Status Species Summary 

Table for Federal Lease Modification Approval WYW-0271199, WYW-0271200

Appendix F State And Federal Revenue Calculations
Chapter 1 – Purpose and Need

Dry Fork Mine A2Tr1 EA 1-1

1.0 Purpose and Need

1.1 Introduction

The Dry Fork Mine Amendment 2, Tract 1 Federal Mining Plan Modification Environmental 

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

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

the Bureau of Land Management (BLM), Buffalo Field Office (BFO); the Wyoming Department of 

Environmental Quality (WDEQ) (including the Land Quality Division [LQD], the Air Quality 

Division [AQD], the Water Quality Division [WQD], and the Solid and Hazardous Waste

Division [SHWD]); the Wyoming Industrial Siting Agency; the Wyoming Office of State Lands 

and Investments (OSLI); Wyoming Game and Fish Department (WGFD); Wyoming Department 

of Health, Public Health Division (WDH-PHD); Campbell County Commissioners; and the 

Campbell County Conservation District. OSMRE is the lead federal agency responsible for 

development of this Environmental Assessment (EA) because, under the Surface Mining Control 

and Reclamation Act of 1977 (SMCRA), OSMRE has the authority to make a recommendation to 

the U.S. Department of the Interior (DOI) Assistant Secretary, Land and Minerals Management 

(ASLM) regarding federal mining plan modifications (OSMRE 1999).

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

future mining operations at the Dry Fork Mine (DFM) from January 1, 2016, through the life of 

the mine within a tract of land known as Amendment 2, Tract 1 (A2Tr1) that lies within the 

approved WDEQ-LQD permit area. The A2Tr1 tract encompasses approximately 364.5 acres 

that contains an estimated 32 million tons (Mt) of recoverable coal.

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

1969 (NEPA) and the Council on Environmental Quality (CEQ) regulations for implementing 

NEPA (40 Code of federal Regulations [CFR] 1500-1508); the Department of the Interior’s 

(DOI’s) regulations for implementation of NEPA (43 CFR Part 46); the DOI’s Departmental 

Manual Part 516; and OSMRE’s Directive REG-1, Handbook on Procedures for Implementing the 

National Environmental Policy Act of 1969 (OSMRE 1989). Information gathered from federal, 

state, and local agencies; Western Fuels-Wyoming, Inc. (WFW); publicly available literature; and 

in-house OSMRE sources, such as the DFM Permit Application Package (PAP), was used in the 

preparation of this EA.

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

projects they authorize and to make a determination as to whether the analyzed actions would 

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

OSMRE determines that the Project would have significant impacts following the analysis in this 

EA, then an Environmental Impact Statement (EIS) would be prepared for the Project. If OSMRE 

determines that the potential impacts would not be “significant,” OSMRE would prepare a Finding 

of No Significant Impact (FONSI) to document this finding, and, accordingly, would not prepare 

an EIS.
Chapter 1 – Purpose and Need

Dry Fork Mine A2Tr1 EA 1-2

1.2 Background

1.2.1 Site History

The DFM is located approximately 4.5 miles northeast of the City of Gillette in Campbell County, 

Wyoming, between Wyoming State Highway (SH) 59 and Garner Lake Road (map 1-1). 

According to information provided by WFW (WFW 2016a), the DFM currently includes coal

from five federal coal leases, one state lease, and one private lease, as listed below. A2Tr1 

overlaps portions of federal coal leases WYW-0271200 and WYW-0271201. Map 1-2 shows 

the federal coal leases.

1. State Coal Lease 0-26652, 

2. Federal Coal Lease WYW-5035,

3. Federal Coal Lease WYW-0271199,

4. Federal Coal Lease WYW-0271200,

5. Federal Coal Lease WYW-0271201,

6. Federal coal lease WYW-0311810,

7. Marshall et al. Private Coal Lease

State Coal Lease 0-26652 was obtained by Peabody Coal Co. on August 2, 1973. After changing 

hands several times, the lease was acquired by North Gillette Coal Company (NGCC) and Dry 

Fork Coal Company (DFCC) on April 3, 1989, and the lease was added to Permit No. PT0599. 

On August 24, 2000, WFW acquired sole ownership of the lease. 

Federal coal leases WYW-0271199, WYW-0271200, and WYW-0271201 were originally 

acquired by Sentry Royalty Company (a division of Peabody Energy) in 1967. The leases changed 

hands several times, however in 1989, NGCC and WFW acquired the leases through a Wyoming 

limited partnership known as DFCC. WFW was the general partner of DFCC and NGCC was 

the limited partner.

Federal coal lease WYW-5035 was originally issued to Humble Oil & Refining Company in 1967. 

After several transactions, this lease became the property of the Fort Union Mine Partnership. 

This lease received federal mine plan approval for mining on February 28, 1985. The Fort Union 

Mine Partnership eventually sold lease WYW-5035 to Wyoming Coal Resources Company 

(WCRC). WCRC obtained a separate WDEQ-LQD permit (PT0659) for the reserves in lease 

WYW-5035 and produced coal from the lease from 1996 through 1998. By an agreement dated 

October 20, 2003, Kennecott Energy and Coal Company, on behalf of WCRC, sold the remaining 

reserves to Tri-State Generation and Transmission Association, Inc. (Tri-State) and Basin Electric 

Power Cooperative (Basin Electric). In 2004, federal coal lease WYW-5035 was added to the 

Dry Fork Mine Logical Mining Unit. WFW merged the Fort Union state permit (PT0659) into the 

Dry Fork Mine in 2011 under Amendment 1 to Permit No. PT0599.

Federal coal lease WYW-0311810 was originally issued January 1, 1970 to Kerr McGee 

Corporation. A portion of the lease was included in the East Gillette Mine permit area. This area 

received federal mine plan approval in 1988. During the late 1990’s, Kerr McGee split the East 

Gillette Mine, selling a portion to the adjoining Wyodak Mine and lease WYW-0311810 to Dry 

Fork Coal Company on February 6, 1997. The previously permitted portion of lease 

WYW-0311810 was added to the Dry Fork Mine as part of the Amendment 2 permit revision.
Chapter 1 – Purpose and Need

Dry Fork Mine A2Tr1 EA 1-3

Map 1-1. General Location Map with Federal Coal Leases
Chapter 1 – Purpose and Need

Dry Fork Mine A2Tr1 EA 1-4

Map 1-2. Dry Fork Mine’s Federal Coal Leases
Chapter 1 – Purpose and Need

Dry Fork Mine A2Tr1 EA 1-5

The Marshall et al. private coal lease was originally issued on January 31, 1973 to Peabody Coal 

Co. The lease changed hands several times and was assigned to Philips Petroleum Company (later 

known as NGCC) on December 1, 1982. The mineable portion of this tract was added to Permit 

No. PT0599 and was mined out during the early 1990’s.

The DFM is located in the middle of the Wyoming Powder River Basin (PRB) region, a coal basin 

that spans from northeast Wyoming to southeast Montana. The PRB produces 80 percent of the 

coal mined from federal government owned coal leases in the U.S. The region has also been 

heavily developed for oil and gas recovery, most recently for coal bed natural gas (CBNG) 

recovery. All of the land surrounding A2Tr1 is currently leased for coal mining. The DFM permit 

area has overlapping coal permit areas with three other approved mining operations (Eagle Butte,

Wyodak, and Synthetic Fuels mines), and abuts mine permit areas on three sides. The A2Tr1 area 

adjoins a neighboring mine’s coal loadout railroad loop. Several heavy industrial facilities are also 

near A2Tr1, including an oilfield wastewater injection business, an activated carbon refinery, and 

a septic waste disposal business. An industrial park is in the process of being developed within 

0.75 mile of the tract.

Coal is mined at the DFM using truck and loader, multiple bench methods. The coal is transported 

by haul truck to the truck-dump hopper located near the mine silos. From the silos, coal is 

conveyed to the adjacent Dry Fork Station (DFS) power plant silos or to the railroad loadout 

facility, which is within the DFM railroad loop. The DFS power plant has a design capacity of 422 

megawatts (MW) and construction was completed during 2011, and the power plant began 

accepting coal from the DFM, which currently provides all of the coal for the power plant. The 

DFS is estimated to need approximately 2.0 million tons per year (Mtpy) through the life of that 

facility (estimated at 2071). Additionally, the DFM provides coal on the spot market (market in 

which coal is sold for immediate delivery), and coal is shipped to customers via an on-site rail 

spur connected to a BNSF Railway Company Railway (BNSF) main line that can accommodate 

coal shipments to all portions of the U.S. Mining operations are described in detail in chapter 2.

WFW operates the DFM under WDEQ-LQD Permit No. PT0599, issued by WDEQ-LQD, in 

accordance with the approved Wyoming State Coal Regulatory Program (30 CFR Part 950). The 

approved permit boundary includes the entire A2Tr1 tract. WDEQ-LQD approved the most 

recent version of Permit No. PT0599 with the condition that the DFM may not mine coal from 

any federal coal lease prior to receiving approval from the ASLM. Although WDEQ-LQD permits 

are issued based on the life-of-mine (LOM) plans for the mining operation, under the Wyoming 

Environmental Quality Act of 1973 (WEQA), permits must be renewed every 5 years (Wyo. Stat. 

§ 35-11-405, Wyoming Revised Statutes [WRS] 1973 as amended). This EA considers potential 

effects from mining A2Tr1 and does not reevaluate existing federal mining areas and operations, 

except in terms of cumulative effects.

The Resource Recovery and Protection Plan (R2P2) for the DFM is sequenced to concurrently 

operate two mining pits. This sequencing is necessary to ensure proper blending of the coal to 

meet coal contract stipulations. It is also necessary to lessen the risk of interrupted coal delivery 

in case an emergency (i.e., pit flooding) disrupts operations in one of the pits. The mine also has 

specific bench lengths and bench orientations. These specific pit lengths, orientations, and other 

mine design factors are done to optimize the coal haul distances and to improve coal drying at 

the benches. Coal drying at the benches is conducted at the DFM to provide an opportunity for 

water to settle out of the coal prior to hauling, which helps to improve pit road conditions, 

especially in the winter, and naturally improves coal quality. This mine plan design has been
Chapter 1 – Purpose and Need

Dry Fork Mine A2Tr1 EA 1-6

approved by the BLM in the R2P2 and is needed to ensure maximum recovery of the coal 

resource. As explained in the R2P2, interruptions to the mine plan sequence will disrupt these 

strategic decisions, resulting in illogical sequences, more overburden rehandle, longer haul 

distance, delayed reclamation, and lower coal recovery. 

WFW’s original purpose for acquiring the DFM in the late 1980’s was to obtain a long-term coal 

supply for the Laramie River Station (LRS) and to sell excess coal on the open market. WFW 

currently has a long-term coal supply contract through 2039 with the LRS for up to 2.7 Mtpy. 

The LRS is a coal-fired power plant located approximately 150 miles southeast of the Project that 

has three coal-based units, including Unit 1 (a 570 net megawatt unit operating since 1980), Unit 

2 (a 570 net megawatt unit operating since 1981), and Unit 3 (a 570 net megawatt unit operating 

since 1982) (Basin Electric Power Cooperative 2016). LRS typically receives the majority of its 

coal from mines other than the DFM. According to U.S. Energy Information Administration 

(USEIA) reporting data, from years 2011 through 2015, between 18 percent and 35 percent of 

the total coal burned at the LRS originated at the DFM (table 1-1).

Table 1-1. Summary of Coal Shipment Reports at the DFM, 2011 through 2015

Year 2011 2012 2013 2014 2015

Mt of Coal Recovered 5.77 6.01 5.43 5.37 6.37

Percent Shipped In State 79.2% 90.5% 86.1% 96.5% 98.0%

Percent of In State Shipped to LRS 17.5% 33.8% 36.6% 39.9% 33.0%

Percent Shipped Out of State 20.8% 9.5% 13.9% 3.5% 2.0%

Source: WFW 2016a

Producing at a 6.0 Mtpy coal mining rate is the current optimal mining rate for the DFM, and coal 

sales are expected to continue at that rate unless market conditions change. Typically, most of 

the sales are to power plants in the region. As seen on Table 1-1, the DFM shipped between 79 

percent and 98 percent of its coal to power plants located in Wyoming during the period between 

2011 and 2015. Since the DFS became fully operational in 2014, over 96 percent of DFM coal has 

been consumed in Wyoming. This trend of primarily selling coal to in-state power plants is 

expected to continue.

1.2.2 Project Background

DFM Permit No. PT0599 was most recently amended on August 19, 2013 to include Amendment 

2 Tracts 1 and 2 areas. The amendment tracts were approved by the WDEQ-LQD with the 

following conditions: 

1. The DFM may not mine coal from any federal coal lease prior to receiving approval 

from the Secretary of the DOI. 

2. The DFM shall report any unanticipated discovery of cultural or paleontological 

resources to the WDEQ-LQD within 5 days. The DFM shall protect the site from 

further disturbance and consult with the WDEQ-LQD District III Field Office to 

insure that the resource is properly evaluated. Identified sites shall be protected 

from any disturbance until they have been evaluated and salvaged, if necessary.

3. Within 90 days of the permit term renewal approval, DFM shall contact the U.S. 

Fish and Wildlife (USFWS) for guidance on conducting surveys for mountain 
Chapter 1 – Purpose and Need

Dry Fork Mine A2Tr1 EA 1-7

plovers, a proposed threatened species. If a survey is carried out and identifies 

suitable habitat for mountain plovers, Dry fork must submit a mitigation plan and 

document approved by the USFWS. The plan must be formatted as a NonSignificant Revision for inclusion in the permit.

4. Within 90 days of each LQD approval revision for Permit No. PT0428 (Eagle Butte 

Mine) and Permit No. PT0232 (Wyodak Mine) which affects the “Dual Permitted 

Areas” between Permit Nos. PT0599 and PT0428, and Permit Nos. PT0599 and 

PT0232, DFM shall submit a revision to Permit No. PT0599. This revision 

application shall update and revise all text and maps associated with the “Dual 

Permitted Area” in order to bring Permit No. PT0599 into accord with the revised 

Permit No. PT0428 and Permit No. PT0232. The WDEQ-LQD District III Office 

shall notify DFM of the need to submit any such revisions. 

Standard Conditions of WDEQ-LQD State Decision Document (SDD):

1. All operations shall be conducted in accordance with the approved mining and 

reclamation plan and any conditions of the permit or license;

2. The rights of entry shall be provided as described by the Act and any regulations 

promulgated pursuant thereto;

3. The operations shall be conducted in a manner which prevents violation of any 

other applicable State or federal law, and

4. All possible steps shall be taken to minimize any adverse impact to the 

environmental or public health and safety resulting in noncompliance with this 

approved mining and reclamation plan and other terms and conditions of any 

permit or license, including monitoring to define the nature of the noncompliance 

and warning of any potentially dangerous condition. 

5. All reclamation fee shall be paid as required by Title IV, P.L. 95087, for coal 

produced under the permit for sale, transfer or use. 

As seen on map 1-2, the A2Tr1 Tract is within the current DFM permit boundary. Until a 

decision regarding the federal mining plan modification request for the A2Tr1 tract is made, the 

DFM is continuing to mine federal coal from the portions of federal coal leases WYW-0271199, 

WYW-0271200 and WYW-0271201, WYW-5035 and WYW-0311810 approved in prior ASLM 

federal mining plan revisions, in accordance with conditions to WDEQ-LQD Permit No. PT0599.

1.2.3 Statutory and Regulatory Background

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

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

mining plans that are proposed to be modified, as is the case with this project, OSMRE prepares 

a MPDD for a mining plan modification request (30 CFR 746.13). The ASLM reviews the MPDD 

and decides whether or not to approve the mining plan modification, and, if approved, what, if 

any, conditions may be needed. Pursuant to 30 CFR 746.13, OSMRE’s recommendation to the 

ASLM is based, at a minimum, upon

1. the PAP,

2. information prepared in compliance with NEPA, including this EA,

3. documentation illustrating compliance with the applicable requirements of federal 

laws, regulations and Executive Orders (EOs) other than NEPA,
Chapter 1 – Purpose and Need

Dry Fork Mine A2Tr1 EA 1-8

4. comments and recommendations or concurrence from other federal agencies and 

the public,

5. findings and recommendations of the BLM with respect to the R2P2, federal lease 

requirements, and the Mineral Leasing Act of 1920 (MLA),

6. findings and recommendations of the WDEQ with respect to the mine permit 

application and the Wyoming State program, and

7. the findings and recommendations of the OSMRE with respect to the additional 

requirements of 30 CFR Chapter VII, Subchapter D.

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

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

the USFWS Section 7 consultation for threatened and endangered species potentially affected by 

the proposed mining plan under the Endangered Species Act of 1973 (ESA), and the Wyoming 

State Historic Preservation Office (SHPO) under the National Historic Preservation Act of 1966 

(NHPA) Section 106 consultation for the affected area.

1.3 Purpose and Need

The purpose of the Proposed Action is established by the MLA and the SMCRA, which requires 

the evaluation of WFW’s proposed mining plan modification for the DFM before conducting 

surface mining and reclamation operations to develop Federal coal lands included in Leases

WYW-0271200 and WYW-0271201. 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.

1.3.1 Purpose

The purpose of this action is to evaluate the environmental effects of coal mining on the proposed 

portions of federal coal leases WYW-0271200 and WYW-0271201 within the A2Tr1 area, which 

will assist OSMRE in developing a recommendation to the ASLM whether to approve, disapprove, 

or approve with conditions the federal mining plan modification. 

1.3.2 Need 

The need for this action is to provide WFW the opportunity to mine the federal coal obtained 

under federal coal leases WYW-0271200 and WYW-0271201 (issued by BLM) to access and 

mine these federal coal reserves located in the A2Tr1 area at the DFM. ASLM approval of the 

federal mining plan modification is necessary to mine the reserves.

1.4 Relationship to Statutes, Regulations, and Other Agency Plans

1.4.1 Statutes and Regulations

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

requirements for developing federal coal resources:

1. MLA,

2. NEPA,

3. Mining and Minerals Policy Act of 1970 (MMPA),

4. Federal Coal Leasing Act Amendment, 1976 (FCLAA),

5. Federal Land Policy Management Act of 1976 (FLPMA),
Chapter 1 – Purpose and Need

Dry Fork Mine A2Tr1 EA 1-9

6. SMCRA, 

7. Multiple-Use Sustained Yield Act of 1960,

8. Endangered Species Act of 1973 (ESA),

9. Clean Air Act, as amended (CAA),

10. Clean Water Act (CWA),

11. Safe Drinking Water Act, as amended (SDWA),

12. National Historic Preservation Act, as amended (NHPA),

13. American Indian Religious Freedom Act of 1978 (AIRFA), 

14. Paleontological Resources Preservation Act of 2009 (PRPA), and

15. Migratory Bird Treaty Act of 1918, as amended (MBTA).

In addition, this EA follows guidance in DOI 516 Department Manual (DOI 2004), which, as 

outlined in 43 CFR Part 46 (U.S. Government Publishing Office [GPO] 2011), is the DOI manual 

guiding the implementation of the NEPA process. An MPDD will be prepared and submitted to 

the ASLM for the reconsidered federal mining plan modification.

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

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

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

government to foster and encourage the orderly and economic development of domestic mineral 

resources. In that context, BLM complies with FLPMA to plan for multiple uses of public lands 

and determine those lands suitable and available for coal leasing and development. Through 

preparation of land use plans and/or in response to coal industry proposals to lease federal coal, 

BLM complies with NEPA to disclose to the public the potential impacts from coal leasing and 

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

environmental laws to ensure appropriate protection of other resources. BLM then makes the 

federal coal that is determined suitable for coal development available for leasing. BLM also is 

responsible for ensuring that the public receives fair market value for the leasing of federal coal. 

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

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

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

implements its responsibilities for leasing and oversight of coal exploration and development 

under its regulations at Public Lands, Subtitle B, Chapter II, BLM, DOI, Subchapter C – Minerals 

Management (43 CFR Parts 3400-3480).

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

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

ensuring the mined land is returned to beneficial use when mining is finished. OSMRE was created 

in 1977 under SMCRA to carry out and oversee those federal responsibilities. OSMRE implements 

its MLA and SMCRA responsibilities under regulations at Mineral Resources, Chapter VII – OSMRE, 

DOI (30 CFR Parts 700-End).

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

their own regulatory programs to permit coal mining. Once a regulatory program is approved for a 

state or tribe, OSMRE steps into an oversight role. OSMRE approved the State of Wyoming’s coal 

regulatory program on November 26, 1980 (30 CFR 950.10). As a result, the WDEQ-LQD 

manages its own program under the Wyoming Environmental Quality Act (Sections 35-11-101 

through 35-11-1104, Wyoming Statutes, 1977, as amended). LQD has the authority and 
Chapter 1 – Purpose and Need

Dry Fork Mine A2Tr1 EA 1-10

responsibility to make decisions to approve surface coal mining permits and regulate coal mining 

in Wyoming under Regulations of the Environmental Quality Council (EQC) and the 

Administrator of the WDEQ-LQD with oversight from OSMRE. The Cooperative Agreement 

between OSMRE and LQD allows the LQD to regulate surface coal mining on federal lands or 

leases while OSMRE continues to carry out its obligations under the MLA, NEPA and other public 

laws (30 CFR 950.30) which includes the recommendations related to mining plans and mining 

plan modifications. 

The PRPA requires the secretaries of the Interior and Agriculture to manage and protect 

paleontological resources on federal land using scientific principles and expertise. The PRPA 

includes specific provisions addressing management of these resources by the BLM, the National 

Park Service (NPS), the Bureau of Reclamation (BOR), the USFWS, and the U.S. Forest Service 

(USFS).

1.4.2 Other Agency Plans

The Project is within the BFO, which manages 780,291 acres of public lands and 4,731,140 acres 

of mineral estate within Campbell, Johnson and Sheridan counties in north-central Wyoming,

including BLM-managed mineral estate in the project area. As required by FLPMA, BLM 

periodically prepares and revises land use plans to determine those uses that are suitable and 

compatible on specific portions of public lands, and under what conditions those uses would be 

authorized to mitigate potential impacts on other resource values and protect human health and 

safety.

No existing BLM management plans (Resource Management Plans [RMP] or Management 

Framework Plans [MFP]) were available when DFM federal coal leases WYW-0271200, WYW0271201, WYW-5035, and WYW-0311810 were issued. MFPs were BLM’s land-use management 

plans utilized to administer public lands in Wyoming prior to 1985. These management plans 

were replaced in 1985 by the RMP concept for managing public lands. To the extent possible, the 

DFM federal coal leases were evaluated as part of the 1974 BLM Final Environmental Impact 

Statement Eastern Powder River Coal Basin of Wyoming (BLM 1974), the 1981 Powder River 

Final Environmental Impact Statement Coal (BLM 1981), the 1984 Draft Environmental Impact 

Statement for Round II Coal Lease Sale in the Powder River Region (BLM 1984), and the 

September 2015 Record of Decision (ROD) and approved Resource Management Plan (RMP)

and associated land use plans for the Rocky Mountain Region Greater Sage-Grouse Conservation 

Strategy (BLM 2015a, and 2015b, respectively). 

Since the DFM leases were issued by the BLM prior to the existence of an RMP or Management 

Framework Plan (MFP) for the BFO, the leases were issued based on valid existing rights (VER). 

The VER lease process conveyed certain rights of development to the leaseholder without

stipulations, unless there was consent of both the lessee and lessor. Conditions of Approval 

(COAs) and/or Best Management Practices (BMPs) required by the BLM in accordance with the 

newer RMPs would need to be consistent with the VER granted in existing leases. In this context, 

BLM made subsequent and periodic decisions regarding readjustment of the lease terms for each 

lease as required under the MLA and FCLAA. For each readjustment decision, BLM determined 

whether the lease terms were in conformance with the land use plan in effect at the time. In 

several cases the BLM, with the concurrence of WFW (or its predecessor), added stipulations to 

the lease adjustments to align the leases with the RMP in place at the time. 
Chapter 1 – Purpose and Need

Dry Fork Mine A2Tr1 EA 1-11

On January 10, 2011, the BLM Casper Field Office (CFO) approved the R2P2 for the DFM, which

included mining all the reserves in A2Tr1. In a letter dated June 29, 2012, the WDEQ-LQD 

provided information to the BLM CFO as part of the 2011 Amendment 2 approval process. In a 

reply dated July 20, 2012, the BLM CFO approved the pending application to mine Amendment 2.

1.5 Authorizing Actions

A state permit approved by the WDEQ-LQD and a federal mining plan or mining plan 

modification approved by the ASLM are needed for a coal mine operator to conduct mining 

operations on lands containing leased federal coal in Wyoming. On August 19, 2013, WDEQLQD issued a SDD approving with conditions mining in the project area, as described in section 

1.2.3. The WDEQ-LQD approval included the requirement that the ASLM must approve the 

mining plan modification before mining of federally leased coal can begin. 

In accordance with 30 CFR 746.13, OSMRE will prepare and submit an MPDD to the ASLM 

recommending approval, approval with conditions, or disapproval of the federal mining plan 

modification. The MPDD will include this EA, which includes consultation with federal and state 

agencies, Native American tribes, local governments, and the public; the consideration of 

alternatives and the potential effect of the Project on the environment and the public; the 

determination of whether the potential effects of the Project and alternatives considered are 

significant; and the determination that the proposed action complies with other applicable federal 

laws and executive orders.

1.6 Outreach and Issues

A scoping process was conducted during which public comments were solicited. OSMRE 

published legal notices of intent (NOIs) in the Gillette News Record on March 9 and March 23, 

2016 (appendix A). The notices described the Project in summary form and informed the public 

that scoping comments would be accepted until April 8, 2016. Outreach letters were mailed on 

March 8, 2016 to Native American tribes, federal and state agencies, city and county governments, 

elected officials, adjacent landowners, and other interested parties. On March 9, 2016, OSMRE 

made a project website available that provided project information and comment opportunities. 

The public scoping comment letters are included in appendix B and the summarized issues 

included

1. the effects on the economic impacts of the mining operation on the state and local 

economies including jobs and revenues generated from mining,

2. the effects on wildlife, including impacts on threatened and endangered species, 

assessing the MBTA, and guidelines to reduce impacts on birds,

3. the effects on and protection of wetlands,

4. the need to continue to provide coal resources to the area power plants to 

generate affordable and reliable electricity, and

5. the need to continue appropriate WDEQ-LQD reclamation standards and to 

continue to provide annual wildlife monitoring reports. 

OSMRE’s A2Tr1 project website continues to be updated periodically as additional information 

on the Project becomes available.

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

this EA. Table 1-2 summarizes the comment topics by resource category.
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Dry Fork Mine A2Tr1 EA 1-12

Table 1-2. Public Outreach Comments Categorized by Key Resource Category

Comment Category Number of Topics 

Discussed

% of Total 

Comments

Wetlands 1 3%

Reclamation 1 3%

Threatened and Endangered Species 1 3%

Support Coal-fired Power Generation 2 7%

Wildlife 3 10%

General Support without Specific Topic 6 21%

Economic Impacts to Local/State 15 52%

Total 29 100%

The majority of the comments received (21 of 23) during the public outreach period were general 

support letters received from a variety of individuals, and letters requesting this EA heavily weigh 

the economic impacts of mining to the state and local communities. The WGFD requested this 

EA ensure that the mine continues the wildlife monitoring protocol and annual LQD reporting, 

as well as continue to adhere to the WDEQ-LQD approved reclamation standards. The USFWS 

provided a reference to threatened, endangered, and candidate (T&E) species needing review, 

and a reminder to review the Project relative to responsibilities under the MBTA, wetlands, and 

avian protection procedures. 

The comments made in support of DFM asked that the economic impacts of the mine to the 

local and state community be discussed. Economic impacts were discussed in nearly every 

comment of support for DFM. One commenter asked that this EA address the positives of jobs 

and revenues generated by mining, the need to provide coal for area power plants, and the good 

record of the mine. Additional comments were submitted supporting the Project without specific 

focus on any one subject. All substantive comments received have been considered and included 

as appropriate in the preparation of this document.
Chapter 2 – Proposed Action and Alternatives

Dry Fork Mine A2Tr1 EA 2-1

2.0 Proposed Action and Alternatives

This chapter provides background information on the existing operations at the DFM, and 

describes the Proposed Action and the No Action Alternative. Alternatives that were considered, 

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

existing mining and reclamation methods can be found in the PAP. WFW submitted the PAP to 

WDEQ-LQD on January 13, 2012, which was approved on August 19, 2013. The latest permit 

renewal for Permit No. PT0599 was issued effective May 12, 2014. The PAP and state permit 

renewal are available at the DFM Office at 3629 N. Garner Lake Road, Gillette, Wyoming, 82716; 

WDEQ-LQD at 200 West 17th Street, Suite 10, Cheyenne, Wyoming, 82002; and the OSMRE 

Western Region Office located at 1999 Broadway, Suite 3320, Denver, Colorado, 80202. 

2.1 DFM WDEQ-LQD Permit

WFW operates the DFM in accordance with WDEQ-LQD issued Permit No. PT0599 (map 2-

1). As currently permitted, the DFM permit area includes a total of approximately 6,477.48 acres, 

of which approximately 4,364.8 are currently permitted for mining disturbance. The currently 

approved DFM permit boundary includes the entire A2Tr1 tract. While WDEQ-LQD approved 

the Amendment 2 permit revision, a condition was included that the DFM may not mine coal 

from any federal coal lease within the permit boundary prior to receiving approval from the 

Secretary of the DOI. WFW owns or controls the surface estate and coal resources within the 

DFM permit boundary. The surface ownership includes 5,613.42 acres of private surface, 39.43 

acres of federal surface, and 824.63 acres of state surface (WDEQ-LQD 2014a). The coal

ownership includes 195.3 acres of private coal, 5,541.5 acres of federal coal, and 740.7 acres of 

state owned coal. All mineable coal within the permit boundary is currently leased by WFW. 

Surface and mineral estate within the A2Tr1 tract is discussed in detail in section 3-10.

Environmental studies for the DFM began during 1978. WDEQ-LQD originally approved Permit 

No. PT0599 on April 13, 1989, and mining operations began in 1989. Section 1.2 discusses the 

various additions of other permitted lease areas to the DFM. Permit renewals approved under 

WDEQ-LQD regulations are for a 5-year permit term, and the permit must be updated with new 

information available at that time. Permit No. PT0599 for the DFM has been approved for renewal 

six times since 1989. The current approved permit term (T6) for operations at the DFM is from 

April 13, 2014 to April 12, 2019.

Changes to the state mining plan must be approved by WDEQ-LQD through a revision. Each 

time a permit revision is approved by WDEQ-LQD, the appropriate changes are made to the 

PAP so that the PAP remains current with the mining and reclamation plans.

2.2 Project Area

The project area for this EA is identified as the A2Tr1 tract and is located within portions of 

federal coal leases WYW-0271200 and WYW-0271201 that lie within the central/eastern portion 

of the DFM permit boundary (map 1-2, section 1.2.1). As determined from BLM Master Title 

Plats, the project area is approximately 364.48 acres (BLM 2010).
Chapter 2 – Proposed Action and Alternatives

Dry Fork Mine A2Tr1 EA 2-2

Map 2-1. Dry Fork Mine’s Mining Sequence at 6.0 Mtpy
Chapter 2 – Proposed Action and Alternatives

Dry Fork Mine A2Tr1 EA 2-3

This EA includes OSMRE’s assessment of the environmental impacts of WFW’s request to modify 

the DFM federal mining plan to include the federal coal in the A2Tr1 tract. The analysis considers

the full extent of disturbance contemplated over the LOM. Chapter 1.0 provides a detailed 

discussion regarding the status of current coal leases associated with the DFM permit area, 

including the status of leases within the project area. 

Prior to ownership by WFW, the project area was homesteaded and was leased at various times 

for oil and gas recovery and associated pipelines and power lines. There is one active oil well on 

the property. There are several small livestock ponds and some fields were dryland farmed and 

inter-seeded with cropland species. As presented on map 2-1, the Garner Lake Road (County 

Road 38N) bisects A2Tr1. The lower 33.7 acres of the tract were previously disturbed by mining 

under the Fort Union permit prior to ownership of lease WYW-5035 by WFW. The area was 

disturbed for a coal haul road used by WCRC to haul coal related to WYW-5035, to what is 

now known as the Synthetic Fuels Mine loadout facility. The 33.7 acres disturbed by WCRC have 

been reclaimed. The reclaimed area and active oil well pad are indicated on map 2-2.

2.3 Description of Existing Mining and Reclamation Operations

The DFM is an open-pit, sub-bituminous coal mine, located approximately 5 miles (8 km) north 

of the City of Gillette, in Campbell County, Wyoming, and the mine is accessed via the Garner 

Lake Road (map 1-2, section 1.2.1). Development of the DFM began in the late 1960’s with 

exploration drilling and continued with acquisition of state and federal coal leases, water rights, 

and permits to operate. Construction of mine facilities began in 1989 and mining operations began 

in 1989. The first coal was shipped in 1990. 

WFW currently employs approximately 82 people and estimates that the average production 

rate at the DFM would continue at the approximate current rate of 6 Mtpy. The DFM’s current 

Air Quality Permit No. MD-11723 allows a maximum coal production of 15 Mtpy (WDEQ-AQD 

2011). Through the end of 2015, an estimated 104.2 Mt of federal, state and private coal has been 

recovered at the mine. 

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

including SMCRA, the WEQA, WDEQ-LQD rules and regulations, and the WDEQ-LQD 

approved PAP. The PAP, including approved revisions, provides the most complete descriptions 

of mining, environmental protection measures, and reclamation activities within the project area 

for the LOM and, as such, is used and referenced by this EA. Coal is mined and either conveyed 

to the adjacent DFS or shipped from an onsite railroad loading facility to electric utilities and 

industrial customers in the United States (WFW 2016a).

Coal recovery at the DFM is conducted using conventional surface mining techniques. Vegetation 

would be removed in new disturbance areas in conjunction with topsoil removal, followed by 

blasting and removal of the overburden, overburden/interburden, and coal; pit backfilling; and 

reclamation. Mining uses a combination of loaders, trucks, and dozers to remove overburden and 

recover coal using conventional multiple bench techniques. Backfilling is completed as soon as 

safely possible, once the coal has been removed from an active pit. After the pit has been 

backfilled and mining has progressed away from the mined-out pit, the backfill material is rough 

graded using dozers in preparation for reclamation. In most cases, rough grading of the backfill 

begins within 60 days of its placement into the final lift. Rough grading of the backfill is important 
Chapter 2 – Proposed Action and Alternatives

Dry Fork Mine A2Tr1 EA 2-4

Map 2-2. Dry Fork Mine’s Currently Approved Disturbance, Disturbance

Through August 2016, and Reclamation by Bond Release Phase
Chapter 2 – Proposed Action and Alternatives

Dry Fork Mine A2Tr1 EA 2-5

in reducing risk of pit flooding by directing water that might pool in the backfill away from the 

active pit.

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

topography, create a reclaimed area in accordance with WDEQ-LQD approved post-mine 

topography (PMT), and construct drainage patterns. After the area is graded to the approved 

PMT, it is tested for spoil suitability. If it is suitable, the area is then prepared for topsoil placement 

and seeding.

The DFM’s overall reclamation objectives are to reclaim the disturbed areas to the approved 

post-mining land uses of cropland, livestock grazing, or wildlife habitat. Through September 12, 

2016, mining at the DFM has disturbed approximately 2,103 acres, and a total of 588 acres have 

been reclaimed since the start of mining, using approved seed mixes suitable for livestock grazing 

and wildlife habitat. Revegetation of all tracts is monitored until the vegetation establishment 

meets the approved standards provided in the PAP.

In addition to land formerly reclaimed, an additional 291 acres have been temporarily seeded, 

which are used by wildlife, with some agricultural use. The temporarily seeded areas include 

long-term topsoil storage areas and hydrologic control structures. Including the permanently 

reclaimed areas and the temporarily reclaimed lands, approximately 879 acres, or about 42 

percent of the total disturbed area, is used by wildlife and sustains some agricultural use.

The DFM was not a mine-mouth operation prior to 2011, as all coal sales were shipped out via 

rail. In 2011, the DFS was opened adjacent to and outside (north of) the DFM permit boundary 

(map 2-2) and the DFM became the long-term, sole-source coal supplier for the DFS. At the 

current 6.0 Mtpy mining rate, approximately 33 percent of the coal produced from the DFM is 

conveyed to the adjoining DFS silos. 

While no coal-processing waste is generated from activities at the DFM, the mine is permitted 

to take the coal combustion byproduct (CCB) wastes from the DFS (map 2-2). CCBs are utility 

wastes generated during the burning of coal and include fly ash, bottom ash, and scrubber sludge. 

An estimated 100,000 tons annually are placed at the DFM in an area located within the DFM 

permit boundary, but outside of the project area. CCB waste is in dry form (not a slurry), and is 

hauled via belly or side dump trucks from the DFS to the active disposal cell. CCB waste is laid 

in the cells in lifts, watered for dust control, and compacted with the water to harden the ash to 

a concrete form. Runoff from cells drains to a lined pond where it is stored for use for dust 

control in the ash landfill. CCBs from DFS are in the process of being tested for use in cement 

products, wallboard, or as road base.

2.3.1 Current Bonding and Bond Release Status

SMCRA provides that, as a prerequisite for obtaining or modifying a coal mining permit, 

permittees must post a reclamation bond to ensure that the regulatory authority would have 

sufficient funds to reclaim the site if the permittee fails to complete obligations set forth in the 

approved reclamation plan (OSMRE 2016). The bond is made payable to the State of Wyoming 

and OSMRE and covers performance of all requirements contained in regulations, the PAP, and 

the WDEQ-LQD reclamation plan. A bond must remain in place until reclamation is completed 

in accordance with the regulatory requirements and permit documents, and to the satisfaction of 

the regulatory authorities. The bond is based on the cost of having a third-party contractor 

complete the required reclamation work if for some reason WFW is unable to do so. 
Chapter 2 – Proposed Action and Alternatives

Dry Fork Mine A2Tr1 EA 2-6

Reclamation liabilities at the DFM, as calculated by WDEQ-LQD as part of the annual report for 

Permit No. PT0599, are $26.7 million (WDEQ 2016). The DFM is self-bonded, with the bonding 

guaranteed by Basin Electric Power Cooperative and Tri-State Generation and Transmission 

Association in the amount of $29.4 million to cover all reclamation liabilities at the DFM 

(WDEQ-LQD 2013). 

As outlined in WDEQ-LQD Guideline No. 20 (Bond Release Categories and Submittal 

Procedures for Coal Mines), there are four types of bond release, based on completion of certain 

portions of the reclamation plan (WDEQ-LQD 2014b). The four types of bond release lands 

disturbed by coal mining are

1. area bond release (rough backfilling has been completed),

2. Phase 1(backfilling, regrading, topsoil replacement, recontouring, and drainage 

control of a bond area, in accordance with the approved reclamation plan, has 

been completed,

3. Phase 2 (when the reclamation plan for any affected land has been completed), and

4. Phase 3 (occurs once all surface coal mining and reclamation activities have been 

completed in accordance with the requirements of SMCRA, the Wyoming 

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

completion of seeding.

Bond release is successive, meaning that reclaimed land must achieve Phase 1 bond release before 

being eligible for Phase 2 and must achieve Phase 2 bond release before being eligible for Phase 

3. Each successive phase of bond release is a subset of the previous phase.

WFW has received approval for Phase I bond releases for areas within the DFM permit boundary, 

and in the project area. Map 2-2 shows the reclaimed areas by bond release phase within the 

project area and table 2-1 provides acreages for each phase of bond release within the DFM. 

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

Phased Bond Releases Status1 Mine 

Wide

Percent 

of Total

Specific to 

the A2Tr1 

tract

Percent 

of Total

Current2 Total Acres Disturbed 2,103 -- 33.7 1.6%

Current2 Total Acres Reclaimed 588 28% 33.7 5.7%

Acres That Have Achieved Phase 1 Bond Release 568 27% 33.7 5.9%

Acres That Have Achieved Phase 2 Bond Release 265 13% 33.7 12.7%

Acres That Have Achieved Phase 3 Bond Release 0 0% 0 0%

1 Area Bond Release has been obtained

2 As of September 12, 2016

2.3.2 DFM Support Facilities 

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

boundary and include facilities buildings, coal handling facilities, and ancillary facilities (roads, 

ponds, power lines, etc.). Other facilities not considered as the main facilities described above 

include the train loadout, railroad loop, explosives storage area, scoria pits, landfarm, sediment 

control ponds and diversions, the access road and miscellaneous haul roads and light use roads. 

2.4 Description of Alternatives

Descriptions of the alternatives analyzed by this EA are discussed below and a summary 

comparison of coal production, surface disturbance, mine life, and employees under the No 
Chapter 2 – Proposed Action and Alternatives

Dry Fork Mine A2Tr1 EA 2-7

Action Alternative and Proposed Action as of December 31, 2015 is provided in table 2-2. The 

No Action Alternative would leave operations as currently stated in the currently approved 

federal mining plan. The Proposed Action would add additional coal associated with federal leases 

WYW-0271200 and WYW-0271201. These scenarios are described in greater detail, below.

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

Life, and Employees for the Current WDEQ-LQD Permit No. PT0599, 

the No Action Alternative, and the Proposed Action as of 

December 31, 2015

1

Includes federal, state, and private coal leases

2

From 1989 OSMRE recommendation to approve the Dry Fork Mine Mining Plan (OSMRE 1989)

3 WDEQ-LQD Permit PT0599, Table MP-9

2.4.1 Proposed Action

Under the Proposed Action, OSMRE would prepare a MPDD recommending approval of the 

WFW’s federal mining plan modification request to include the federal coal within the A2Tr1 

tract associated with federal leases WYW-0271200 and WYW-0271201 and the ASLM would 

approve the federal mining plan modification. The mine would use similar mining and reclamation 

methods as described in section 2.3. The operations within the proposed 364.5-acre project 

area are estimated to disturb a total of 306.4 acres. Of that total, 276.8 acres are considered 

lands unaffected by mining and 26.4 acres are re-disturbance of reclaimed land. An area of 3.2 

acres was disturbed through end of year (EOY) 2015 as approved in support of the adjoining 

ongoing permitted mining activities and approximately 9.7 acres of the 276.8 acres of lands 

unaffected by mining are non-mining related disturbance associated with oil wells, farming, and 

oilfield roads.

Approving the Proposed Action would add 32 Mt of recoverable federal coal to the mine. Table

2-3 shows the effects of adding Proposed Action reserves on the estimated LOM under 6-Mtpy 

and 15-Mtpy scenarios.

Table 2-3. Mine Life Scenarios for the Proposed Action

Production Rate 

Scenarios

Current 

Anticipated LOM

Estimated Years 

Extended1

Anticipated LOM 

with the Proposed 

Action

6.0 Mtpy 09/2047 5.3 01/2053

15.0 Mtpy209/2028 2.1 10/2030

1 Estimated using tons of additional recoverable coal (32 Mt)

2 The maximum production permitted under DFM’s current Air Quality Permit No. MD-11723

Item

Current 

DFM 

Permit No. 

PT0599

Current OSMRE 

Federal Mining Plan 

(No Action 

Alternative) 

Projections 

Under

Proposed Action

Remaining Recoverable Leased Coal1190.3 190.3 Mt 222.3 Mt

Currently Approve Federal Mine Plan Acres -- 2,2202 2,584.5

WDEQ-LQD Permit Acres (PT05991) 6,477.5 -- No change

Total Area to Be Disturbed 4,364.834,058.7 acres 4,364.8 acres3

Estimated Average Annual Production 6 Mt 6 Mt 6 Mt

Remaining Years from Recovering All Leased 

Coal 37.0 yrs. 31.7 yrs. 37.0 yrs. 

Average Number of Employees 82 82 82 
Chapter 2 – Proposed Action and Alternatives

Dry Fork Mine A2Tr1 EA 2-8

2.4.1.1 Mine Operation Components within the Project Area Associated with the Proposed Action

Map 2-1 shows the projected coal recovery sequence in the Proposed Action, at the 6.0 Mtpy 

mining rate. The Proposed Action would consist of the following mine components and facilities 

located within the project area. The major pit facilities indicated below are also shown on map 

2-1:

1. Pit 1 is a currently active open pit operating in federal lease WYW-0271201 and 

WYW-0271199. At the 6.0 Mtpy projected mining rate, this pit would be 

recovering coal from the A2Tr1 area from 2023 through 2041.

2. Pit 2 is a currently active open pit operating in federal lease WYW-0271201 and 

state lease 0-26652. At the 6.0 Mtpy projected mining rate, this pit would be 

recovering coal in the A2Tr1 area during years 2020 through 2030.

3. Existing 120-volt power lines would provide power to facilities within the project 

area.

4. Support facilities necessary to conduct mining operations within the project area 

would include

 haul roads used by haul trucks to transport coal to the DFM truck dump 

hopper, or move overburden and connect with in-pit roads and ramps;

 temporary light use ancillary roads;

 temporary in-pit ramps and roads;

 temporary stockpile areas to store topsoil removed from disturbed areas for 

use in reclamation;

 temporary berms for control of water, material placement, or traffic;

 dewatering wells and associated waterlines;

 temporary construction staging areas;

 environmental monitoring stations for air and water monitoring; and

 Sediment ponds and diversion ditches.

2.4.1.2 Existing and Proposed Disturbance within the Project Area

The Proposed Action would include mining related disturbance in the A2Tr1 tract, with topsoil 

salvage anticipated to occur between years 2016 and 2036 and coal removal projected to occur 

in the project area between years 2020 and 2041. All acreages for disturbance and reclamation 

used in this EA are based on the disturbance and reclamation status as of the EOY 2015. Table 

2-4 summarizes the total projected mining related surface disturbance in the A2Tr1 project area, 

by disturbance class. The overall disturbed areas for the Proposed Action are shown on map 2-

2. 

Coal recovery within the project area will require disturbing a total of 306.4 acres within the 

364.5-acre project area. The existing WDEQ-LQD issued Permit No. PT0599 has approved a 

disturbance of 4,364.8 acres, which includes 306.4 acres of disturbance associated with the tract. 

The WDEQ-LQD approved disturbance is contingent on approval of the federal mining plan 

modification by the ASLM (WDEQ-LQD 2014a). 
Chapter 2 – Proposed Action and Alternatives

Dry Fork Mine A2Tr1 EA 2-9

Table 2-4. Summary of Mining Related Surface Disturbance in Project Area

Row Disturbance Class1 Acreage

A Total Project Area 364.5

B Previously Disturbed and Reclaimed Acres as of EOY 2015 33.7

C Previously Disturbed and Not Reclaimed Acres as of EOY 2015 3.2

D Previously Disturbed within Project Area (Row B + Row C) 36.9

E Proposed New Disturbance Associated with the Proposed Action 276.8

F Proposed Redisturbance Associated with the Proposed Action 26.4

G Total New Proposed Disturbance Associated with the Proposed Action ( Row E + 

Row F)

303.2

H Total Disturbance within the Project Area (Existing Unreclaimed and Proposed) 

(Row C + Row G)

306.4

I Surface Disturbance within Project Area Permitted Under Previous Approvals 155.4

J New Surface Disturbance Associated with the Proposed Action (Row H – Row I) 151.0

1 Excludes non-mining disturbances, such as oil wells, roads, farming activities.

2.4.1.3 Mining Operations Associated with the Proposed Action

Mining operations associated with the Proposed Action would continue to be conducted in a 

similar manner as described for existing operations in section 2.3. Vegetation would be removed 

in new disturbance areas followed by topsoil removal, blasting of the overburden, 

overburden/interburden and coal removal, pit backfilling, and reclamation. Table 2-5 provides 

additional information on the projected total tons of recoverable coal in Pits 1 and 2 within the 

project area.

Table 2-5. Proposed Project Area Mine Plan

Mine Pit

Coal Recovery 

Area (Acres)1

in Acres

Estimated Recoverable Federal

Coal Tons2

Estimated Period 

of Mining

Years

Pit 1 249 29,708,942 2023-2041

Pit 2 19 2,254,727 2020-2030

Total 268 31,963,670 2020-2041

1

From EOY 2015, through LOM (estimated 2054 at 6 Mtpy mining rate), from coal blocks shown on map 2-2.

2

From “Application for Approval of a Revised Resource Recovery and Protection Plan for DFM, September 2010”, approved January 5, 

2011.

2.4.2 No Action Alternative

Under the No Action Alternative, the proposed mining plan modification would not be approved 

by the ASLM and WFW would continue to operate under the currently approved federal mining 

plan. Under this alternative, OSMRE would not recommend approval or approval with conditions 

of the federal mining plan modification and the ASLM would issue a decision based on the No 

Action Alternative. If the ASLM does not approve the federal mining plan modification to allow 

recovery of federal coal in the proposed project area, WFW would continue to mine according 

to the most recent federal mining plan.

If the No Action Alternative is selected, WFW would bypass the coal in the project area, resulting 

in 32 Mt of federal coal not being recovered and 117.4 acres of previously undisturbed ground 

not being disturbed. The No Action Alternative would require revisions to the WDEQ-LQD 

approved Permit No. PT0599 and the BLM approved R2P2 to modify the reclamation plan, 
Chapter 2 – Proposed Action and Alternatives

Dry Fork Mine A2Tr1 EA 2-10

maximum economic recovery conditions, and coal recovery plans for areas within boundaries of 

the Permit No. PT0599 by excluding mining activities within the A2Tr1 tract. Economic and social 

impacts of the No Action Alternative are discussed in section 4.17. 

2.4.3 Alternatives Considered but Eliminated from Further Study

OSMRE considered alternative scenarios to the approval or denial of the federal mining plan 

modification. However, since OSMRE's decision would be limited to approving, approving with 

conditions, or denying the mining plan modification, OSMRE concluded that there are no other 

reasonable action alternatives to the Proposed Action that would meet the agency’s purpose and 

need. The following alternatives were considered but eliminated from detailed analysis. The 

discussions include reasons the alternatives were eliminates from detailed analysis.

2.4.3.1 Underground Mining Alternative

An alternative to require WFW to use underground mining methods to extract the coal was 

identified in public comments received during the outreach period for similar recent projects. It 

was considered by OSMRE for this project, and eliminated from detailed study because 

WDEQ-LQD has approved a surface mining permit for this project using surface mining 

techniques, and underground mining is inconsistent with the approved permit. The purpose and 

need for this EA is predicated upon review of a surface mining plan included as part of the 

WDEQ-LQD approved surface mining permit. An Underground Mining Alternative would, thus, 

be inconsistent with the Purpose and Need for this action.

This alternative also would be economically infeasible. The facilities and equipment needed for 

underground mining are different from surface mining. Because the infrastructure for underground 

mining is not in place at the DFM, new infrastructure for underground mining would need to be 

constructed. The capital expenditure to develop an underground mine would be prohibitive. In 

addition, all new surface facilities would need to be constructed, including, but not limited to, 

conveyors, coal stockpiles, and maintenance and support facilities. In addition, all new underground 

mining equipment would need to be purchased, such as, but not limited to, a long wall mining 

system, conveyor systems, drives and power stations, vehicles for transporting workers and 

supplies, several continuous miners, shuttle cars, large and small ventilation fans, and roof bolters.

Underground mining of the coal seams at the DFM is not a method approved by the BLM in the 

approved R2P2 for the mine. Proposing to mine the seams by underground mining methods 

would require a new R2P2 to be developed and approved by the BLM prior to permitting with 

WDEQ-LQD. The coal recovery would be significantly reduced, resulting in noncompliance with 

the goals of the BLM to maximize coal recovery in approved leases. There is very little chance 

the BLM would approve this option.

Underground mining of the coal seams at the DFM is additionally not a method authorized by the 

mine’s Mine Safety and Health Administration (MSHA) required ground control plan. Proposing 

to mine the seams by underground mining methods would require a new ground control plan to 

be developed and approved by MSHA prior to permitting with WDEQ-LQD. This would take 

years of study prior to submittal of the permit. Given the shallow overlying sedimentary geologic 

strata, it is unlikely an acceptable and adequately safe underground mining plan could be permitted 

with MSHA.

Mining the large (60 feet – 100 feet thick) coal seams in the Wyoming Powder River Basin using 

conventional underground mining techniques is not conducted, therefore detailed cost or 
Chapter 2 – Proposed Action and Alternatives

Dry Fork Mine A2Tr1 EA 2-11

feasibility analysis is not readily available. This alternative was not brought forward for analysis 

because underground mining would not respond to the purpose and need for this action, is not 

in conformance with the maximum economic recovery requirements of the federal coal leases 

and the R2P2, and would result in a prohibitive economic burden on the mine. Given these 

factors, bringing this alternative forward for further review would not be reasonable.

2.4.3.2 Low or No Pollutant Emitting Equipment

Public comments received during the outreach period for similar recent projects suggested 

considering an alternative that required reduced air emissions at the mine by changing or 

modifying mining related equipment to equipment which would produce lower air emissions. As 

described in section 3.4.7, the DFM is a relatively small contributor of the emissions related to 

engine combustion (primarily carbon dioxide [CO2] and oxides of nitrogen [NOX]) in the region.

The cost to make the switch to equipment powered by a different fuel (such as natural gas or 

solar powered equipment) for recovery of 32 Mt of federal coal would be cost prohibitive for 

the minimal benefit to the regional air quality. In addition, the use of natural gas powered engines 

in mining equipment is relatively new and some types of equipment would not be available for 

replacement with natural gas powered engines. The use of solar power to run large equipment

has not been tested and is not considered technologically feasible at this time. Similarly, 

retrofitting existing equipment with additional emissions control devices would be expensive with 

limited effect on regional air emissions.

OSMRE has not brought forward this alternative for full analysis because requiring natural gas 

and solar powered engine technology and retrofitting existing equipment is not economically or 

technologically feasible for all equipment at the DFM; and would likely have substantially similar 

effects to an alternative that is analyzed. Given these factors, bringing this alternative forward for 

further review would not be reasonable.

2.4.3.3 Air Quality Mitigation Alternatives

Some public comments received during the outreach period for similar recent projects suggested 

that OSMRE consider alternatives that mitigate air quality impacts, specifically by imposing more 

stringent emission limits at power plants fueled by the DFM and by requiring oil and gas operators 

in the region to reduce their emissions. These proposals are not alternatives to the mining plan 

being considered. The effects of coal combustion are analyzed in the Proposed Action as well as 

in the No Action Alternative because they are considered to be indirect effects. CEQ regulations 

at 40 CFR 1508 (b) define “indirect effects” as those which are caused by the proposed action 

and are later in time or farther removed in distance, but are still reasonably foreseeable. These 

indirect effects would occur as a result of burning the coal that is mined. The analysis concluded 

impacts to air resources under the Proposed Action would be minor and there would not be 

significant impacts to air resources under the Proposed Action and no mitigation was 

recommended. Any mitigation measure proposed by OSMRE imposing more stringent emission 

limits on non-coal operators is beyond OSMRE’s authority and its implementation would be highly 

remote and speculative. Given these factors, bringing this alternative forward for further review 

would not be reasonable.

2.4.4 Project Environmental Protection and Mitigation Features

The surface mining permitting process under WDEQ-LQD coal regulatory program requires 

applicants to obtain approvals from various agencies, including the WGFD, SHPO, and the 
Chapter 2 – Proposed Action and Alternatives

Dry Fork Mine A2Tr1 EA 2-12

USFWS. The applicant is then required to incorporate agency required design features into their 

mining proposals that are intended to protect, or minimize impacts to, environmental resources. 

Each PAP submitted to WDEQ-LQD for review and approval contains resource-specific plans, 

design features, and associated performance standards. The resource-specific plans describe the 

design features for reducing or eliminating the potential impacts to various resources or how 

those resources would be restored to approved post-mining conditions after mining is complete. 

WDEQ-LQD approval commits the applicant to implementing the design features contained in 

the PAP. It is important to note that the design features of the original permit also apply to a 

newly revised permit, unless WDEQ-LQD approves changes.

The following is a summary of the environmental commitments for environmental protection and 

mitigation, by resource, included in the PAP. More detailed descriptions of these environmental 

commitments are included in the PAP, which is available at the DFM Office at 3629 N. Garner 

Lake Road, Gillette, Wyoming, 82716; the WDEQ District 3 office at 200 West 17th Street, Suite 

10, Cheyenne, Wyoming, 82002; and the OSMRE Western Region Office located at 1999 

Broadway, Suite 3320, Denver, Colorado, 80202.

2.4.4.1 Topography

 Reclaim the area to the WDEQ-LQD approved post-mining topography.

 Grade backfilled mining areas to establish a stable post-mine topography that 

blends into the undisturbed areas outside the mining limits.

2.4.4.2 Air Quality 

 Water roads and apply chemical dust suppressants as necessary to control fugitive 

dust emissions.

 Operate in compliance with the WDEQ-AQD Permit No. MD-11723. 

 Revegetate long-term topsoil stockpiles.

2.4.4.3 Water Resources

 Route all runoff from disturbed areas through one or more sediment ponds or 

approved alternative sediment control measures (ASCMs). 

 Construct new sedimentation structures and diversion ditches prior to topsoil 

removal to control runoff, avoid erosion and an increased contribution of 

sediment load to runoff, and protect surface water and groundwater quality.

 Give new-hire training to employees regarding sediment control requirements and 

construction techniques.

 Maintain temporary sediment ponds and ASCMs until vegetative establishment is 

complete and acceptable runoff water quality is achieved.

 Monitor performance of diversion ditches and sediment control structures and 

maintain or upgrade as needed.

 Control and monitor the quantity and quality of any discharges from the permit 

area in compliance with the Wyoming Pollutant Discharge Elimination System 

(WYPDES) Permit Number WY-0032964 issued by the WDEQ-WQD under the 

National Pollutant Discharge Elimination System (NPDES) program.
Chapter 2 – Proposed Action and Alternatives

Dry Fork Mine A2Tr1 EA 2-13

 Revegetate permanent drainage ditches unless an alternative is approved by 

WDEQ-LQD and install other erosion control measures where necessary based 

on the approved design. 

 Seed disturbance related to sediment pond construction, including embankments 

and surrounding areas, after the pond construction is completed.

 Design sediment ponds to contain the water and settleable sediment load from a 

10-year, 24-hour storm event.

 Construct ASCMs in small drainage basins, where sediment ponds are 

inappropriate, to provide secondary sediment controls for precipitation and 

snowmelt events in disturbed areas of the mine site. ASCMs are typically dozer 

sumps and ditches to the dozer sumps or a series of straw wattles (permeable 

barriers used to detain surface runoff long enough to reduce flow velocity). 

 Size haul road culverts to maintain proper drainage during high snowmelt or other 

exceptional runoff events. 

2.4.4.4 Vegetation

 Revegetate to achieve the approved post-mining land uses.

 Reclaim the post-mine disturbed land with shrubs in accordance with approved 

permit commitments.

 Eliminate livestock grazing during vegetation establishment.

 Once vegetation is established, manage livestock usage to protect the established

 vegetative cover.

 Evaluate revegetation success in accordance with the standards approved by the 

WDEQ-LQD.

2.4.4.5 Terrestrial Wildlife

 Re-establish appropriate and suitable forage, shrubs and trees on reclaimed areas 

in accordance with approved permit commitments to provide wildlife habitat.

 Construct permanent stock and wildlife watering ponds.

 Leave undisturbed islands throughout the disturbed area to provide habitat for 

wildlife.

 Provide training to employees on WGFD topics for protecting wildlife, and inform 

them of wildlife prone locations.

 Post and set the maximum speed of 45 mph on the mine access road to limit 

collisions with wildlife. 

 Manage livestock grazing to ensure that adequate forage is left for wildlife use and 

that the range is not over used.

 Control pesticide and herbicide use to protect livestock and wildlife.

 Provide rock piles and varying topographic design in the reclamation to provide 

habitat diversity for wildlife habitat.

 Limit soil salvage activities near active Greater sage-grouse leks during the 

breeding and rearing season, mid-March through mid-July.

 Install fencing in accordance with PAP requirements for wildlife protection.
Chapter 2 – Proposed Action and Alternatives

Dry Fork Mine A2Tr1 EA 2-14

2.4.4.6 Fish/Aquatic Life

 Restrict access to the Moyer Spring riparian habitat area with fencing and signs.

 Continuously monitor flows in Moyer Creek, and submit monthly reports to 

WDEQ-LQD documenting adequate flows and maximum temperatures.

 Setback mining from the recharge area to Moyer Creek. 

 Monitor the wells around the creek monthly. 

 Augment flows to Moyer Spring from approved alternative sources, if low flow 

triggers are reached.

 Allow WGFD personnel to periodically access Moyer Creek to conduct various 

assessments.

 Ensure all discharges into Moyer Spring Creek are in compliance with WYPDES 

limitations.

 If augmentation occurs, comply with water treatment requirements in the PAP.

2.4.4.7 Threatened and Endangered Species

 Construct power lines to Suggested Practices for Raptor Protection on Power lines -

The State of the Art in 2006. 

 Conduct annual wildlife surveys of raptors and migratory birds of high federal 

interest (MBHFI), and prepare/submit annual reports. 

 If a nest develops within 1⁄4 mile (or line of sight) of the active mining area, consult 

with USFWS before continuing activities near the nest. Implement site specific 

protections and mitigation measures as required.

 Prepare raptor mitigation plans as required by USFWS. Comply with the 

requirements in the plans, such as installing raptor platforms.

 Conduct surveys and develop mitigation plans for newly listed T&E species that 

are present in the mine area as they are newly listed.

2.4.4.8 Cultural Resources

 Perform pre-disturbance field surveys.

 If an unidentified cultural or historical resource is discovered within or adjacent 

to the project area, halt activities that may damage the resource and report the 

findings to the responsible regulatory agency.

 Complete required mitigation for cultural and historic resources.

2.4.4.9 Visual Resources

 Reclaim disturbed areas to the approved post-mining topography.

2.4.4.10 Soils

 Live-handle topsoil where possible to apply the benefits of topsoil that has not 

been stored in topsoil piles for an extended period of time.

 Locate topsoil stockpiles to avoid erosion from wind and water and additional 

compaction or contamination.

 Regrade topsoil stockpiles with outside slopes no steeper than 3H:1V and protect 

topsoil stockpiles by revegetating as soon as conditions allow.

 Clearly label topsoil stockpiles.
Chapter 2 – Proposed Action and Alternatives

Dry Fork Mine A2Tr1 EA 2-15

 Reserve adequate topsoil for reclamation of wetlands, bottomlands and croplands.

 Periodically recalculate the mine-wide soil balance and adjust the replacement 

depth as necessary. 

 Sample the regraded spoil in accordance with the PAP before applying topsoil to 

ensure it is not toxic to vegetation.

 Control weeds on topsoil stockpiles by monitoring and treating with an herbicide 

as needed.

 If soil compaction occurs after topsoil replacement, rip the soil to minimize 

compaction, promote stability and assist in revegetation. 

 Leave reapplied topsoil in a rough condition to help control wind and water 

erosion prior to seeding.

 Monitor topsoil removal and maintain replacement balances to ensure adequate 

topsoil is available for reclamation.

2.4.4.11 Post-mining Land Use

 Reclaim affected areas to land uses as high as or higher than those in effect prior 

to mining.

 Establish vegetation to support livestock grazing.

 Establish adequate forage and cover to support year-round wildlife usage.

 Establish permanent stock and wildlife watering ponds.

 Establish the post-mining hydrologic conditions in accordance with the approved 

hydrologic reclamation plan.
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-1

3.0 Affected Environment

The CEQ regulations state that NEPA documents “must concentrate on the issues that are truly 

significant to the action in question, rather than amassing needless detail” (40 CFR 1500.1(b)). 

While many issues may arise during scoping, not all of the issues raised warrant analysis in an EA. 

Issues are analyzed if an analysis of the issue is necessary to make a reasoned choice between 

alternatives, or if the issue is associated with significant direct, indirect, or cumulative impact, or 

where analysis is necessary to determine the significance of the impacts. Table 3-1 lists the 

resources considered for this EA and the determination as to whether the resource required 

additional analysis. For the purposes of discussion, the general analysis area includes an area that 

contains the Dry Fork, Rawhide, Buckskin, Eagle Butte, Synthetic Fuels, and Wyodak mines 

(referred to as the northern group of mines) (map 1-1). Resource specific analyses may utilize 

an analysis area specific to the resource, which is described if different from the general analysis 

area.

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

Resource Determination1 Rationale for Determination

General Setting PI See discussion below

Topography PI See discussion below

Geology, Minerals, and Paleontology PI See discussion below

Air Quality/Climate Change PI See discussion below

Water Resources PI See discussion below

Alluvial Valley Floors NP No Alluvial Valley Floors are located within the Project 

Area

Wetlands/Aquatic Features PI See discussion below

Soils PI See discussion below

Vegetation PI See discussion below

Wildlife PI See discussion below

Land Use and Recreation PI See discussion below

Cultural and Historic Resources PI See discussion below

Visual Resources PI See discussion below

Noise PI See discussion below

Transportation PI See discussion below

Hazardous and Solid Waste PI See discussion below

Socioeconomics PI See discussion below.

Prime Farmlands NP No Prime Farmlands are located within the Project Area

Floodplains NP No Federal Emergency Management Agency-designated 

floodplains are located within the Project Area

1 NP = not present in the Project Area. PI = present with the potential for impact. Only PI designated resources are analyzed in this EA.
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-2

3.1 General Setting

The DFM is located approximately 4.5 miles north of Gillette, in Campbell County, Wyoming 

(map 1-1). The general analysis area includes a group of mines referred to as the northern-group 

of mines, including Dry Fork, Rawhide, Buckskin, Eagle Butte, Synthetic Fuels, and Wyodak, in the 

part of the Northern Great Plains that includes most of northeastern Wyoming. This region is 

also within the Northwestern Great Plains Ecoregion of Wyoming (Chapman et al. 2004).

Map 2-1 depicts the limits of the A2Tr1 tract and the currently approved DFM WDEQ-LQD 

PT0599 permit boundary. The existing disturbance as of September 12, 2016, and the future 

disturbance from September 12, 2016, through the LOM within the mine are shown on map 

2-2. The A2Tr1 tract is the focus of the Affected Environment for this EA. However, in order to 

provide context for a specific resource, resource discussions may include a larger area.

The climate associated with the A2Tr1 tract is semi-arid and characterized by cold winters, warm 

summers, and a large variation in annual and seasonal precipitation and temperature. Wind, 

precipitation, and temperature patterns in the A2Tr1 tract are affected by the mountain ranges 

to the west, especially by the nearby Bighorn Mountains.

Annual precipitation for the period 1902-2012 (period of record) at the National Oceanic and 

Atmospheric Administration (NOAA) National Climatic Data Center (NCDC) Gillette 9 ESE 

station (483855) located about 7 miles southeast of the DFM was 15.72 inches (Western Regional 

Climate Center [WRCC] 2012). Precipitation ranged from a low of about 8.1 inches in 1936 to 

a high of about 26.4 inches in 1982 (WRCC 2012). Approximately 45 percent of the annual 

precipitation falls in the 3-month period April through June. Average annual snowfall at the 

Gillette 9 ESE station is approximately 55.7 inches, with March (10.0) and December (8.5) 

recording the highest monthly average snowfall. Approximately 29 percent of the annual 

precipitation falls as snow in the 6-month period October through March (WRCC 2012). The 

remainder generally occurs as summer thunderstorms, which are commonly accompanied by high 

winds and hail. Most flooding in the area likely occurs in response to high-intensity thunderstorms 

of comparatively short duration.

The seasonal and daily variations between maximum and minimum temperatures are often 

extreme. Daily variations of 30° to 50° F are common as a result of characteristic radiative effects. 

Temperatures at Gillette 9 ESE station range from -40° to 110° F. Temperatures in the proposed 

lease modification tract will probably lie between these extremes. The frost-free period for this 

area lasts between 101 and 120 days (Curtis and Grimes 2004).

Map 3-1 illustrates the wind direction and percent of total for the directions. The figure shows 

prevailing wind directions coming from the south-southeast (15.3 percent of the time) and the 

north-northwest (11.6 percent of the time) quadrants. Meteorological data collected in 2015 at 

the DFM indicate an average wind velocity of 9.4 miles per hour; however, a maximum wind

velocity of 40.6 miles per hour was recorded (WFW 2016a).

3.2 Topography and Physiography

The following discussions on topography and physiography were taken from Appendix D5

(Geology, Topography, and Overburden Assessment) of the DFM’s WDEQ-LQD Permit No. 

PT0599 (WFW 2011).
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-3

Map 3-1. Wind Rose and Air Quality and Meteorological Monitoring Stations at 

the DFM
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-4

The DFM is physiographically part of the unglaciated Missouri Plateau section of the Great Plains 

Province (Fenneman 1931). This part of the Great Plains Province is characterized by broad 

plateaus which are dissected by incised stream valleys. In the western portion, the plateaus merge 

with the PRB and other broad regional downfolds. These basins are separated by major 

mountainous uplifts.

The landscape of the PRB consists of broad plains, low hills, and tablelands. Incised stream valleys 

create most of the topographic relief. Generally, the topography changes from open hills with 

500 to 1000 feet of relief in the northern part of the basin to plains and tablelands with 300 to 

500 feet of relief in the southern part (Keefer 1974). The PRB is bounded by the Platte River 

drainage basin to the south, the Yellowstone River in Montana to the north, the Big Horn 

Mountains to the west, and the Black Hills to the east. 

3.3 Geology, Minerals, and Paleontology

3.3.1 General Geology

The strata in the DFM permit area generally show northwest to north-northwest strikes and 

gentle westward dips. The synclinal axis trends north to northwest near the western edge of the 

PRB, adjacent to the Casper Arch and the Big Horn Mountains. Gentle folds occur on the eastern 

and northern flanks, while faults and locally overturned beds are characteristic of the much 

steeper western and southern flanks. The northern and eastern areas of the basin have gentle 

dips that seldom exceed a few degrees. Regional dips in the Gillette area are from 0.5 degrees in 

the surface sediments to 3 degrees in the deeper sediments toward the southwest. No major 

faults have been mapped in the Gillette area (Hodson et al. 1973).

The general analysis area (northern group of mines) contains the following stratigraphic units or 

layers (in descending order from the surface): Quaternary (most recent) deposits, the Eocene 

Wasatch Formation, and the Paleocene Fort Union Formation. The Paleocene Fort Union 

Formation contains the coal seams that would be mined under the Proposed Action. Figure 3-1

shows the stratigraphic relationships of the geologic units in the general analysis area. These 

stratigraphic units are discussed below. Figures 3-2 and 3-3, which have been modified from 

DFM’s WDEQ-LQD Permit PT0599, Appendix D5, Addendum D, Exhibits 1 through 6, depict 

geologic cross sections of the Project Area, including the Anderson and Canyon coal seams.

Surficial Geology – Surficial geology within the Project Area is shown on map 3-2. Quaternary 

deposits in the general analysis area consist of alluvium, sheetwash, colluvium, and lacustrine 

deposits. Quaternary deposits represent a minor component of the surficial geology within the 

DFM area. Exposed and weathered Wasatch Formation residuum comprises the majority of the 

surficial geology within the Project Area. The Wasatch Formation residuum flanks a ridge of 

exposed Wasatch bedrock that occupies the central portion of the general analysis area. 

Wasatch Formation - The Eocene Wasatch Formation comprises the majority of the 

overburden, which consists mainly of interfingering lenses of claystone, siltstone, and sandstone. 

The overburden contains clinker (variously called Wyoming porcelanite or scoria), coal stringers 

and carbonaceous shales. 
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-5

Sources: Stratigraphy from Stratigraphic Nomenclature Committee, Wyoming Geological Association, 1969. 

Hydrogeology from Lewis and Hotchkiss, 1981.

Figure 3-1. Stratigraphic Relationship and Hydrologic Characteristics of Upper 

Cretaceous, Lower Tertiary and Recent Geologic Units of the 

Powder River Basin, Wyoming

Geologic Unit Hydrologic Characteristics

RECENT ALLUVIUM

HOLOCENE

Typically, fine grained and poorly sorted sands interbedded with silts and clays in ephemeral 

drainages. Occasional very thin, clean interbedded sand lenses. More laterally extensive, 

thicker, and coarse-grained along the larger stream courses. Excessive dissolved solids 

generally make this aquifer unsuitable for domestic and agricultural use and marginal for 

livestock (Class III) WDEQ water quality use standards. Low infiltration capacity in ephemeral 

draws unless covered by sandy eolian blanket.

CLINKER

HOLOCENE TO

PLEISTOCENE

Baked and fused bedrock resulting from burning coal seams where the seam outcrops were 

ignited by lightning, wildfires, or spontaneous combustion. The reddish clinker (locally called 

scoria, etc.) formed by melting and partial fusing of overburden above the burning coal. The 

baked rock varies greatly in the degree of alteration; some is dense and glassy while some is 

vesicular and porous. It is commonly used as a road construction material and is an aquifer 

wherever saturated. 

WASATCH FORMATION

EOCENE

Lenticular fine sandstones interbedded in predominantly very fine grained siltstone and 

claystone may yield low to moderate quantities of poor to good quality water. The 

discontinuous nature and irregular geometry of these sandstones result in low overall 

permeabilities and very slow groundwater movement in the overburden on a regional scale. 

Water quality in the Wasatch Formation generally does not meet Wyoming Class I (domestic 

use) standards due to the dissolved mineral content. Some wells do, however, produce water 

of considerably better quality that does meet the Class I standard. 

FORT UNION FORMATION

PALEOCENE

TONGUE RIVER 

MEMBER

The coal beds serve as regional groundwater aquifers and exhibit highly variable aquifer 

properties. Permeability and porosity associated with the coal arise almost entirely from 

fractures. Coal water typically does not meet Wyoming Class I or Class II (irrigation use) 

standards. In most cases, water from coal wells is suitable for livestock use. The coal water is 

used throughout the region as a source of stock water and occasionally for domestic use. 

LEBO MEMBER

The Lebo member, also referred to as the “Lebo Confining Layer” or “Lebo Shale”, has a mean 

thickness of 711 feet (ft) in the PRB, although ranges between 400 and 1,000 ft in the Gillette 

area. The Lebo typically yields small quantities of poor quality groundwater. Where sand 

content is locally large, caused by channel or deltaic deposits, the Lebo may yield as much as 10 

gallons per minute (gpm). 

TULLOCK

MEMBER

The Tullock member has a mean thickness of 785 ft in the PRB and a mean sand content of 53 

percent which indicates that the unit generally functions well as a regional aquifer. Yields of 15 

gpm are common but vary locally and may be as much as 40 gpm. Records from the Wyoming 

State Engineers Office (WSEO) indicate that maximum yields of approximately 300 gpm have 

been achieved from this aquifer. Water quality in the Tullock Member often meets Class I 

standards. The extensive sandstone units in the Tullock Member are commonly developed 

regionally for domestic and industrial uses. The City of Gillette is currently using 13 wells 

completed in this zone to meet part of its municipal water requirements 

UPPER CRETACEOUS

LANCE 

FORMATION/H

ELL CREEK 

FORMATION

Silty, calcareous sandstones and interbedded sandy shales, claystones, and coals. Provides yields 

generally less than 20 gpm. Higher yields can occur where sand thicknesses are greatest. Water 

quality is typically fair to good. Also referred to as the “Upper Lance Confining Layer.” 

FOX HILLS

SANDSTONE

Marine sandstones and sandy shales. Has a mean thickness of 818 ft and a mean sand content 

over 50 percent in the PRB. Yields up to 200 gpm are common; however, yields can be 

significantly less. Water quality is good, with total dissolved solids (TDS) concentrations 

commonly less than 1,000 milligrams per liter (mg/L). The City of Gillette is currently using 

three wells completed in this aquifer to meet part of its municipal water requirements. 

PIERRE SHALE

This unit is comprised predominantly of dark marine shales with only occasional local thin 

sandstone lenses. Maximum yields are minor and overall the unit is not water bearing. Water 

obtained from this unit is poor with high concentrations of sodium and sulfate as the 

predominant ions in solution. 
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-6

Figure 3-2. Geologic Cross Sections for the A2Tr1 Tract
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-7

Figure 3-3. Geologic Cross Sections for the A2Tr1 Tract
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-8

Map 3-2. Surficial Geology Associated with the DFM
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-9

Fort Union Formation - The Paleocene Fort Union Formation consists primarily of siltstones, 

mudstones, claystones, shales, lenticular sands/sandstones, and coal seams. The Fort Union 

Formation is divided into three members, in descending order, the Tongue River (which contains 

the mineable coal seams), the Lebo, and the Tullock (Flores et al. 1999). The coal to be mined in 

this area is within the Wyodak-Anderson coal seam, which is the uppermost unit of the Tongue 

River Member of the Paleocene Fort Union Formation. In the mine permit area, a claystone and 

carbonaceous coal lens separate the Wyodak-Anderson seam into the upper Anderson coal seam 

and the lower Canyon coal seam. For this EA, the coal to be mined will be referred to as the 

Wyodak-Anderson seam. The coal is consistently underlain by shale, claystone, or occasionally 

siltstone throughout the Dry Fork mine. The Wyodak coal seam is nearly flat-lying with minor 

variations and dip reversals, which very likely reflect the depositional environment (structural 

highs and lows) and/or differential compaction, rather than major tectonic deformation.

Underlying the Fort Union Formation are the Cretaceous age Lance Formation, Fox Hills 

Sandstone, and Pierre Shale. Occasionally, mine water supply wells are constructed in the 

Lance-Fox Hills aquifer; otherwise, no mine related disturbance extends below the Fox Hills 

Sandstone.

3.3.2 Mineral Resources

The Anderson and Canyon coal seams are the primary shallow mineral resources within the Project 

Area. Coal from the Anderson and Canyon coal seams are ranked as sub-bituminous coals (35 percent

to 45 percent carbon and 8,300 to 11,500 Btu/lb. (U.S. Department of Energy [USDOE] 2016 and 

Environmental Protection Agency [EPA] 1993). The Anderson and Canyon coals are generally low in 

sulfur and ash when compared to other mines in the Powder River Basin (table 3-2).

Table 3-2. Average Physical Characteristics of the Mineable Portions of the 

Wyodak-Anderson Coal Seam in the Area

Parameter Anderson1 Canyon1 Powder River Basin Range2

Btu’s per pound 8,144 8,112 8,000-9,500

Sulfur 0.34 percent 0.23 percent 0.2-0.7 percent

Ash 4.1 percent 4.37 percent 4.2-9.0 percent

Range of Thickness 15-24 Feet 56-65 Feet --

1 WFW Unpublished Data

2

John T. Boyd Company (2011)

The Wyodak-Anderson coal seam, which has been tapped for CBNG development, is the same seam 

that is being mined at the DFM. Wyoming Oil and Gas Conservation Commission (WOGCC) records 

indicate that as of October 2016, 341 CBNG wells have been completed in the analysis area (N1⁄2 

T. 50 N., R. 71 W.; N1⁄2 T. 50 N., R. 72 W.; S1⁄2 T. 51 N., R. 71 W.; and S1⁄2 T. 51 N., R. 72 W.). 

Approximately 41 percent (139 wells) are producing or are capable of producing gas, with the 

remaining wells listed as shut in or abandoned. WOGCC records indicate that no CBNG wells have 

been completed within the A2Tr1 tract. As described in section 3.10, four conventional oil and gas 

wells were completed within the tract but only one is still capable of producing oil. Additionally, no 

bentonite or uranium reserves have been identified in the general analysis area. Wyoming porcelanite

(known locally as scoria or clinker) breaks are present along the east border of the A2Tr1 tract, but 

these breaks are outside of the proposed coal recovery area.
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-10

3.3.3 Paleontology

The BLM’s Potential Fossil Yield Classification (PFYC) system ranks geologic formations based on 

their potential to yield significant paleontological resources. The five main classes in the system 

are:

1. Class 1 - Very Low. Geologic units that are not likely to contain recognizable 

fossils. Management concern for paleontological resources in Class 1 units is 

usually negligible or not applicable;

2. Class 2 - Low. Sedimentary geologic units that are not likely to contain vertebrate 

fossils or scientifically significant non-vertebrate fossils. Management concern for 

paleontological resources is generally low;

3. Class 3 - Moderate or Unknown. Fossiliferous sedimentary geologic units where 

fossil content varies in significance, abundance, and predictable occurrence; or 

sedimentary units of unknown fossil potential. Management concern for 

paleontological resources is moderate; or cannot be determined from existing 

data;

4. Class 4 – High. Geologic units containing a high occurrence of significant fossils. 

Vertebrate fossils or scientifically significant invertebrate or plant fossils are known 

to occur and have been documented, but may vary in occurrence and 

predictability. Surface disturbing activities may adversely affect paleontological 

resources in many cases. Management concern for paleontological resources in 

Class 4 is moderate to high, depending on the proposed action;

5. Class 5 - Very High. Highly fossiliferous geologic units that consistently and 

predictably produce vertebrate fossils or scientifically significant invertebrate or 

plant fossils, and that are at risk of human-caused adverse effects or natural 

degradation. Management concern for paleontological resources in Class 5 areas 

is high to very high.

The following discussion regarding paleontological resources within the A2Tr1 tract was taken 

from Appendix D3 (Prehistoric (Archeological) and Paleontological Resources), Amendment 2 

Area of DFM’s WDEQ-LQD Permit No. PT0599 document (WFW 2011). 

A literature search indicated that the A2Tr1 tract lies on a single geological unit, the 

Paleocene-Eocene Wasatch Formation, which is known to yield significant paleontological 

resources in nearby areas. This formation has been rated by the BLM as a PFYC Class 5 unit, very 

high potential. In addition, mining operations impact the Tongue River Member of the Paleocene 

Fort Union Formation (PFYC 3) that underlies the Wasatch Formation. Vertebrate fossils from 

the Tongue River Member in the Powder River Basin are much less common than in the Wasatch 

Formation, but they are known from further north in central Montana. In addition, vertebrate 

bones were reported from the Fort Union Formation in the nearby Wyodak mine in Campbell 

County, WY, but the identification of these fossils and their location is currently unknown.

A locality search showed that no known vertebrate fossil localities are recorded from within 

either the original mine permit area or the A2Tr1 tract. Cultural resource surveys done in the 

early 1980's for the original mine permit area recorded several localities with large fossil tree 

trunks. No vertebrate fossils were discovered during these surveys, but because these surveys 
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-11

were done before fossil resources were protected under federal law, paleontologists were not 

present.

3.4 Air Quality

Ambient air quality and air pollution emissions are regulated under federal and state laws and 

regulations. The WDEQ-AQD is responsible for managing air quality through the Wyoming Air 

Quality Standards and Regulations (WAQSR) and the Wyoming State Implementation Plan (SIP). 

The WDEQ-AQD has also been delegated authority by the EPA to implement federal programs 

of CAA. The analysis area for air quality discussion is primarily associated with the general analysis 

area (northern group of mines) but also includes portions of northeastern Wyoming and 

southeastern Montana (map 3-3).

Air Quality regulations applicable to surface coal mining may include the National Ambient Air 

Quality Standards (NAAQS), Wyoming Ambient Air Quality Standards (WAAQS), and 

Prevention of Significant Deterioration (PSD). Additional air quality regulations applicable to 

surface coal mining include the New Source Performance Standards (NSPS), Hazardous Air 

Pollutants (HAPs), Mercury and Air Toxics Standards (MATS), and the Federal Operating Permit 

Program (Title V).

The analysis presented herein serves to summarize attainment/nonattainment areas discussions; 

update discussions with recent air quality monitoring findings; revise air quality modeling results; 

and update discussions on carbon monoxide (CO), sulfur dioxide (SO2), nitrogen dioxide (NO2), 

ozone (O3), fine particulate matter (PM2.5), lead (Pb), hydrogen sulfide (H2S), and HAPs 

(specifically mercury [Hg]). Dispersion modeling conducted in 2011 (Carter Lake Consulting 

2011) demonstrated that modifications to the DFM’s current permit would be compliant with 

short-term and long-term WAAQS for particulate matter (PM10 and PM2.5), where PM10 is coarse 

particulate with mean aerodynamic diameters less than 10 microns and PM2.5 is fine particulate 

with a diameter of 2.5 microns or less. Furthermore, dispersion modeling performed for NO2, 

which included regional NOX emissions sources, demonstrated that the operation of the Dry 

Fork Mine would comply with the annual Wyoming ambient air quality standard for NO2. The 

results of this modeling are presented in section 4.4.

According to EPA (IPCC 2014), there is scientific evidence that increased atmospheric 

concentrations of greenhouse gases (GHG) and land use changes are contributing to increases in 

average global temperatures. GHG are not currently regulated pollutants (not subject to NAAQS 

or WAAQS regulations). GHG discussions are included in section 3.4.7.4 and in section 4. 

4.4.

3.4.1 National Ambient Air Quality Standards 

The CAA requires the EPA to establish NAAQS to protect public health and welfare. These 

standards define the maximum level of air pollution allowed in the ambient air. The CAA 

established NAAQS for six pollutants, known as “criteria” pollutants, which “... cause or 

contribute to air pollution which may be reasonably anticipated to endanger public health or 

welfare and the presence of which in the ambient air results from numerous or diverse mobile 

or stationary sources.” The six, present-day criteria pollutants are Pb, NO2, SO2, CO, O3 and 

PM10 and PM2.5. 
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-12

Map 3-3. Regional Air Quality Monitoring Sites
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-13

The CAA and its amendments allow states to promulgate additional ambient air standards that 

are at least as stringent, or more stringent, than the NAAQS. The NAAQS and WAAQS, 

established by the WDEQ-AQD, are listed in table 3-3. WAAQS values also include H2S.

Table 3-3. Federal and Wyoming Ambient Air Quality Standards

Emissions Averaging

Period

Wyoming

Standard

(WAAQS)

Federal

Standard

(NAAQS)

Carbon Monoxide (CO) 1-hour

8-hour

35 ppma

9 ppma

35 ppma

9 ppma

Sulfur Dioxide (SO2)

1 1-Hour

3-hour

75 ppbd

0.50 ppma

75 ppbd

0.50 ppma

Nitrogen Dioxide (NO2)

2 1-Hour

annual

100 ppba

53 ppbb

100 ppbi

53 ppbf

Ozone (O3)

3

8-hour 0.070 ppme0.070 ppme

PM10

24-hour

annual

150 μg/m3a

50 μg/m3f

150 μg/m3c

--

PM2.5

24-hour

annual

35 μg/m3g

12 μg/m3f

35 μg/m3i

12 μg/m3h

Lead (Pb)490-Day 0.15 μg/m3h

0.15 μg/m3b

Hydrogen Sulfide (H2S) 1-Hour 70/40 μg/m3j--

a Not to exceeded more than once per calendar year

b Not to be exceeded rolling 3-month average

c Not to exceed more than once per calendar year on averaged over 3 years

d 99th percentile of 1-hour daily maximum concentrations, averaged over 3 years

e Annual 4th-highest daily maximum 8-hour concentration, averaged over 3 years

f Annual mean

g 98th percentile of 24-hour daily average concentration

h Annual mean, averaged over 3 years

i 98th percentile 1-hour average, averaged over 3 years

j 1⁄2-hour average not to be exceeded more than 2 times per year/1⁄2-hour average not to be exceeded more than 2 times in any five 

consecutive days

-- Values not included in NAAQS or WAAQS and were not calculated.

1 The previous SO2 standards (0.14 ppm 24-hour and 0.03 ppm annual) will additionally remain in effect in certain areas: (1) any area for which 

it is not yet 1 year since the effective date of designation under the current (2010) standards, and (2)any area for which implementation plans 

providing for attainment of the current (2010) standard have not been submitted and approved and which is designated nonattainment under 

the previous SO2 standards or is not meeting the requirements of a SIP call under the previous SO2 standards (40 CFR 50.4(3)), A SIP call is 

an EPA action requiring a state to resubmit all or part of its State Implementation Plan to demonstrate attainment of the require NAAQS.

2 The level of the annual NO2 standard is 0.053 ppm. It is shown here in terms of parts per billion (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 effect 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.

4

In areas designated nonattainment for 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/m3as a calendar quarter average) also remain in effect.

Source: EPA (2016a) and WDEQ-AQD (2016)

3.4.2 Attainment/Nonattainment Area Designations

Pursuant to the CAA, EPA developed a method for classifying existing air quality in distinct 

geographic regions, known as air basins, air quality control regions, and/or metropolitan 

statistical areas. For each federal criteria pollutant, each air basin (or portion of a basin or 

statistical area) is classified as in “attainment” if the area has complied with the adopted NAAQS 

for that pollutant, as “nonattainment” if the levels of ambient air pollution exceed the NAAQS for 

that pollutant, or as “unclassifiable” if the area cannot be classified on the basis of available 

information as meeting or not meeting the national primary or secondary ambient air quality 

standard for the pollutant.
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-14

Through the State Implementation Plan (SIP) process, which is approved by EPA, states use the 

EPA method to designate areas within their borders as being in “attainment”, “nonattainment”, 

or “unclassifiable” with the NAAQS. The A2Tr1 tract is in an area that is designated an 

attainment area for all pollutants (EPA 2016b). However, the city of Sheridan, Wyoming, located 

about 79 miles northwest of the project area, is currently a nonattainment area for PM10 (map 

3-3). It should be noted that WDEQ/AQD has requested that the Wyoming Air Quality 

Advisory Board consider a request to review the State of Wyoming’s Request for Redesignation 

and Limited Maintenance Plan for the Attainment in the Particulate Matter (PM10) Moderate 

Nonattainment Area in Sheridan (WDEQ-AQD 2016). The request is based on the fact that 

WDEQ-AQD has submitted over 25 years of monitoring data demonstrating that the Sheridan 

nonattainment area has attained the PM10 NAAQS for over 25 years. Upon review and 

completion of a finalized draft, the request will be submitted to EPA. The final determination 

has not been made at this time.

3.4.3 Prevention of Significant Deterioration

Under provisions of the CAA, the EPA has established prevention of significant deterioration 

(PSD) rules, intended to prevent deterioration of air quality in attainment and unclassified areas. 

Increases in ambient concentrations of NO2, SO2, and PM10 are limited to modest increments 

above the existing or “baseline” air quality in most attainment/unclassified areas of the country 

(Class II areas discussed below), and to very small incremental increases in pristine attainment 

areas (Class I areas discussed below).

For the purposes of PSD, the EPA has categorized each attainment area in the U.S. into one of 

three area classifications. PSD Class I is the most restrictive air quality category, and was created 

by Congress to prevent further deterioration of air quality in national and international parks, 

national memorial parks, and national wilderness areas of a given size threshold which were in 

existence prior to 1977, when the CAA was enacted, or those additional areas which have since 

been designated Class I by federal regulation (40 CFR 52.21). Such parks and wilderness areas 

are considered “mandatory” Class I areas, because they cannot be redesignated. Attainment 

areas defined as Class I at the request of a state or tribe (e.g., Northern Cheyenne Reservation, 

northwest of the A2Tr1 tract) are considered “designated” Class I areas; this category is 

intended to protect air quality in areas of particular interest to the requesting entity. Because 

designated Class I areas are given that status by request rather than by assignment from the 

EPA, they can be redesignated at the option of the requesting state or tribe. All remaining areas 

outside of mandatory or designated Class I boundaries were classified as Class II areas, which 

allow a relatively greater deterioration of air quality over that in existence in 1977, although still 

within the NAAQS. No Class III areas, which would allow further degradation, have been 

designated. The federal land managers have also identified certain federal assets with Class II 

status as “sensitive” Class II areas for which air quality and/or visibility are valued resources.

Table 3-4 shows approximate distances and directions from the general analysis area to 30

PSD Class I and sensitive Class II areas in the vicinity of the PRB.

The closest mandatory Class I areas to the general analysis area are Wind Cave National Park 

and Badlands National Park in South Dakota, located about 115 miles southeast and 165 miles 

east-southeast of the site, respectively. The closest designated Class I area is the Northern 

Cheyenne Indian Reservation (in Montana), located about 74 miles from the general analysis 

area. The closest “sensitive” Class II areas are the Devils Tower National Monument and the 

Cloud Peak Wilderness Area, which are approximately 42 and 81 miles from the general analysis 

area, respectively. PSD regulations limit the maximum allowable increase (increment) in ambient 

PM10 in a Class I airshed resulting from major stationary sources or major modifications to 4 

micrograms per liter (μg/m3) (annual geometric mean) and 8 μg/m3(24-hour average). Increases 

in other criteria pollutants are similarly limited. Specific types of facilities listed in the PSD rules 
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-15

which emit, or have the potential to emit, 100 tons per year or more of PM10 or other criteria 

air pollutants, or any other facility which emits, or has the potential to emit, 250 tons per year 

or more of PM10 or other criteria air pollutants, are considered major stationary sources and 

must demonstrate compliance with those incremental standards during the new source 

permitting process. Fugitive emissions are not counted against the PSD major source 

applicability threshold unless the source is so designated by federal rule (40 CFR 52.21). As a 

result, the surface coal mines in the PRB have not been subject to permitting under the PSD 

regulations because the mine emissions have never triggered the PSD applicability levels. The 

proposed action constitutes a minor permit modification to an existing minor source; therefore, 

PSD permitting is not an issue.

Table 3-4. Distances and Directions from the General Analysis Area to 

Sensitive Air Quality Areas

Distance (miles) Direction to 

Receptor

MANDATORY FEDERAL PSD CLASS I AREA

Badlands National Parka165 ESE

Bridger Wilderness Area 225 WSW

Fitzpatrick Wilderness Area 215 WSW

Gates of the Mountain Wilderness Area 343 NW

Grand Teton National Park 265 WSW

North Absaroka Wilderness Area 210 WNW

Red Rocks Lake Wilderness Area 307 W

Scapegoat Wilderness Area 393 NW

Teton Wilderness Area 237 WSW

Theodore Roosevelt National Park (North Unit) 242 NNE

Theodore Roosevelt National Park (South Unit) 196 NNE

U.L. Bend Wilderness Area 287 NW

Washakie Wilderness Area 215 WSW

Wind Cave National Park 123 SE

Yellowstone National Park 236 W

TRIBAL FEDERAL PSD CLASS I

Fort Peck Indian Reservation 252 N

Northern Cheyenne Indian Reservation 74 NNW

FEDERAL PSD SENSITIVE CLASS II 

Absaroka-Beartooth Wilderness Area 219 WNW

Agate Fossil Beds National Monument 168 SSE

Bighorn Canyon National Recreation Area 137 WNW

Black Elk Wilderness Area 113 ESE

Cloud Peak Wilderness Area 81 W

Crow Indian Reservation 120 NW

Devils Towner National Monument 42 ENE

Fort Belknap Indian Reservation 316 NNW

Fort Laramie National Historic Site 164 SSE

Jewel Cave National Monument 117 ESE

Mount Rushmore National Memorial 112 ESE

Popo Agie Wilderness Area 208 SW

Soldier Creek Wilderness Area 197 SE

a The U.S. Congress designated the wilderness area portion of Badlands National Park as a mandatory federal PSD class I area. The 

remainder of Badlands National Park is a PSD class II area.

3.4.4 Best Available Control Technology

All sources being permitted in Wyoming must meet state-specific Best Available Control 

Technology (BACT) requirements, regardless of whether the source is subject to state/federal 

PSD review. During new source review, a BACT analysis is developed for the proposed project 
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-16

for each emission unit and pollutant. BACT analyses must evaluate all technically feasible control 

options on the basis of environmental, economic, and energy considerations. BACT for mining 

operations in the PRB is subject to categorical control requirements defined in the WAQSR, 

and other mitigation measures as determined by the WDEQ-AQD on a case-by-case basis.

3.4.5 New Source Performance Standards (NSPS)

The NSPS are a federal program of “end-of-stack” technology-based controls/approaches 

adopted by reference in the WAQSR. These standards, which apply to specific types of new, 

modified or reconstructed stationary sources, require the sources to achieve some base level 

of emissions control. Certain activities at coal preparation plants are subject to an NSPS. 

Specifically, the applicable requirements can be found at 40 CFR Part 60, Subpart Y (Standards 

of Performance for Coal Preparation Plants), and in the WAQSR. However, these standards 

are typically less stringent than state-level BACT limits.

3.4.6 Federal Operating Permit Program

The Clean Air Act Amendments require the establishment of a facility-wide permitting program 

for larger sources of pollution. This program, known as the Federal Operating Permit Program, 

or Title V, requires that major sources of air pollutants obtain a federal operating permit. Under 

this program, a “major source” is a facility that has the potential to emit more than 100 tons 

per year of any regulated pollutant, 10 tons per year (TPY) of any single hazardous air pollutant, 

or 25 tons per year or more of any combination of hazardous air pollutants, from applicable 

sources. The federal operating permit is a compilation of all applicable air quality requirements 

for a facility and requires an ongoing demonstration of compliance through testing, monitoring, 

reporting and recordkeeping requirements. Under the Proposed Action, the DFM’s relevant 

potential to emit (PTE) PM10 from point sources would be 26.6 tons per year, which is below 

the 100 tons per year threshold (Carter Lake Consulting 2011). Fugitive emissions at coal mines 

do not contribute to the Title V applicability determination. 

An inventory of all point sources, controls, and emissions for MD-11723 showed that the PTE 

is below the PSD 250 tpy major source threshold limit specified in Chapter 6, Section 4 of the 

WAQSR and below the 100 tpy major source threshold for Title V permitting specified in 

Chapter 6, Section 4 of the WAQSR. The DFM is also not subject to Title V regarding HAPs 

because its PTE is less than 25 tpy for HAPs and less than 10 tpy for any single HAP. According 

to MD-11723, a PSD increment consumption analysis is not necessary and WFW is not required 

to obtain a Title V Operating Permit (WDEQ-AQD 2011).

3.4.7 Existing DFM Air Quality Summary

3.4.7.1 Background

Air quality information specific to the DFM is included in WFW’s WDEQ-AQD MD-11723 air 

quality permit (WDEQ-AQD 2011). Typical climate conditions for the Gillette 9 ESE station 

(483855) located about 7 miles southeast of the DFM are included in section 3.1.

3.4.7.2 Air Quality-Monitoring Values

WFW has monitored particulate matter levels around the DFM throughout the life of the 

operation. Ambient air monitoring data has been collected by the mining community in the 

Powder River Basin for over twenty years. Initially, concentrations were measured as total 

suspended particles (TSP), but in 1989, PM10 monitors were being installed at various sites 

throughout the basin. All monitoring was being conducted on a one-in-six (1/6) day schedule. 

However, in the early part of 2001, PM10 readings in excess of 150 μg/m3 were being recorded 

in the southern area of the basin. In a letter from the Division dated October 26, 2001, the 
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-17

mines in the PRB were notified that the waiver the Division had issued in 1997 allowing

monitoring on a (1/6) day schedule had been revoked. As of January 2002, all the PM10

monitoring sites in the PRB were required to conduct monitoring on a one-in-three (1/3) day 

schedule. This mandate did not apply to PM10 monitors currently operating on an everyday (1/1) 

schedule, PM10 monitors already on a 1/3-day schedule, or to any existing TSP monitors on a 

1/6-day schedule. Additionally, a mine that had been monitoring TSP would be allowed to follow 

a 1/6-sampling schedule until such time a 24-hour TSP concentration in excess of 150 μg/m3was 

recorded or an annual average TSP concentration in excess of 50 μg/m3 was recorded.

The DFM operates four high volume PM10 samplers (DF-2, DF-4S, DF-4N, and DF-4M) 

(map 3-1). Samplers DF-4N and DF-4S are collocated and with sampler DF-4M, operate on a 

1/3-day schedule. Sampler DF-2 operates on a 1/6- day schedule. Sampler DF-2 replaced the 

TSP sampler DF-1, which was shut down at the beginning of the 4th quarter of 2008.

Table 3-5 lists the current estimated annual mean, annual high, and high-second high PM10

micrograms per cubic meter (μg/m3) at the DFM. The average annual mean PM10 values for the 

2011-2015-time period ranged between 5.6 and 14.7 μg/m3. These concentrations ranged from 

about 11 to 29 percent of the annual standard of WAAQS annual standard of 50 μg/m3. During 

the same time period, the 24-hour high PM10 values ranged between 15 and 61 μg/m3. Thus, 

these maximum concentrations have ranged from approximately 10 to 40 percent of NAAQS

and WAAQS 24-hour standard of 150 μg/m3. Fluctuations in monitoring values have occurred 

but all values are below the WAAQS annual standard of 50 μg/m3 and the 24-hour standard of 

150 μg/m3.

Table 3-5. Historical PM10 Ambient Data (μg/m3) and Production, 2011-2015

(PM10 WAAQS: 50 μg/m3 Annual, 150 μg/m324-Hour)

Year Site #1

Annual 

Arithmetic 

Mean (μg/m3)

Highest 24-

Hour Reading 

(μg/m3)

2

nd Highest 24-

Hour Reading 

(μg/m3)

Mt Coal 

Produced

MBCY3

Overburden

2011 DF-2 12.2 45 36 5.77 8.19

DF-3

2

9.5 31 31

2012 DF-2 14.3 52 49

DF-3

2

5.6 15 14 6.01 9.33

DF-4N & 4M 13.0 43 40

DF-4S 13.5 39 38

2013 DF-2 14.7 57 39

DF-4N & 4M 8.2 23 21 5.43 8.98

DF-4S 7.3 20 17

2014 DF-2 12 28 22

DF-4N & 4M 7.8 30 23 5.38 8.74

DF-4S 6.9 16 15

2015 DF-2 13.7 61 41

DF-4N & 4M 9.6 54 31 6.34 8.06

DF-4S 9.2 53 29

1

See map 3-1

2 DF-3 site was relocated to DF-4 in 2012

3 Million bank cubic yards

Source: WFW 2016

Because PM2.5 monitoring is not required by WDEQ-AQD, data were not gathered onsite. 

However, data from PM2.5 monitors located nearby were used to estimate PM2.5 emissions at 

the mine. PM2.5 data gathered from four sites between 2011 and 2015 (map 3-1) were used to 

assess PM2.5 levels at the DFM (table 3-6). Exceptional events (if observed) are noted in the 

data acquired from the EPA database. Exceptional events are defined as occasional instances 

where a natural and exceptional occurring event impacts monitoring, causing a reading that is 

in exceedance with the NAAQS (WDEQ-AQD 2016). In the case that this occurs, the Final
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-18

Table 3-6. Measured PM2.5 Concentrations1in Campbell County, Wyoming 

(2011-2015)

Site ID1 Year 24-hour (μg/m3) Annual (μg/m3)

Btm-26-2 2007 19 6.6

(Black Thunder Mine) 2008 11 4.9*

2011 14 3.4*

Btm-36-2 2012 16 4.9*

(Black Thunder Mine) 2013 14 4.2*

(560050891) 2014 10 3.9

2015 22 4.9*

2016 12 3.3*

2011 20 5.3*

Belle Ayr Ba-4,5n,5s 2012 22 7.9*

(560050892) 2013 14 6.4*

2014 10 5.2

2015 18 5.0

2016 14 4.6*

2011 16 4.8*

Buckskin Mine North Site 2012 18 5.9*

(560051899) 2013 14 4.8

2014 12 5.5

2015 21 2.2

2016 10 2.5*

1

See map 3-3 for locations

* indicates the mean does not satisfy minimum data completeness criteria

Source: EPA 2015a

“Treatment of Data Influenced by Exceptional Events” Rule (40 CFR 50.14) allows the state to 

request a data flag and justify the flag by submitting documentation showing that NAAQS 

exceedance would not have occurred in the absence of a natural/exceptional event. Monitoring 

during the period of 2011 to 2015 demonstrated that ambient concentrations of PM2.5, as 

determined by the 98th Percentile 24-hour standard and annual average values, were within 

established short-term (24-hour) and long term (annual) NAAQS and WAAQS values indicated 

in table 3-3.

EPA referenced emission factors are available for use in estimating PM2.5 values based on PM10

values (Pace 2005). Because no specific data were available for western coal mines, these 

emission factors were developed from sources with similar characteristics, including large open 

cut aggregate mines and large-scale construction projects with considerations toward unpaved 

fugitive emissions from heavy haul trucks. Generally accepted estimates consistently presented 

emission fractions of PM2.5 values at a range of 0.1 to 0.15 of PM10 values for unpaved roadways 

and 0.15 to 0.2 for wind erosion from industrial and construction sites (Pace 2005). 

DFM-specific PM10 monitoring data were used to estimate PM2.5 ambient concentrations for 

annual mean and annual high 24-hour by application a 0.2 factor (PM2.5 to PM10) (tables 3-7 and 

3-8, respectively).

Table 3-7. Estimated Annual High 24-Hour STP PM2.5 Concentrations (μg/m3)

(PM2.5 WAAQS: 35 μg/m3 Annual, 24-hour)

Site Name1 2011 2012 2013 2014 2015

DF-1 **   **  **

DF-2 9 10.4 11.4 5.6 12.2

DF-3 6.2 3   ** 

DF-4N & 4M ** 8.6 4.6 6 10.8

DF-4S ** 7.8 4 3.2 10.6

1

See map 3-1 for site locations

** Indicates that the site is inactive
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-19

Table 3-8. Estimated Annual Mean STP PM2.5 Concentrations (μg/m3) (Annual 

Mean PM2.5 WAAQS: 12 μg/m3; NAAQS: 12 μg/m3)

Site Name1 2011 2012 2013 2014 2015

DF-1   **  ** **

DF-2 2.4 2.9 2.9 2.4 2.7

DF-3 1.1   **  **

DF-4N & 4M ** 2.6 1.6 1.56 1.9

DF-4S ** 2.7 1.5 1.4 1.8

1

See map 3-1 for site locations

** Indicates that the site is inactive

These data indicate that projected PM2.5 ambient design concentrations should be below the 

prescribed 24-Hour WAAQS and NAAQS (35 μg/m3) and the annual WAAQS and NAAQS 

(15 μg/m3and 12 μg/m3, respectively), which supports the findings of Gillette area PM2.5 data 

evaluation presented in table 3-5.

Under the CAA, EPA has set protective health-based standards for O3 in the air we breathe. 

Prior to May 27, 2008, the NAAQS 8-hour standard for O3 was 0.080 ppm (157 μg/m3 at 

standard temperature and pressure [STP]). On March 27, 2008 (effective May 27, 2008), EPA 

revised the 8-hour standard to 0.075 ppm (148 μg/m3at STP) and EPA revised the 8-hour 

standard for O3 again on October 26, 2015 (effective on December 28, 2015) to 0.070 ppm 

(138 μg/m3at STP). O3 monitoring is not required at the DFM but levels have been monitored 

at the Thunder Basin National Grassland Air Quality System (AQS) Site (560050123), which is 

located approximately 22 miles north of the A2Tr1 tract, and at the South Campbell County 

air quality (AQ) Site (560050456), which is located approximately 17 miles south of the A2Tr1 

tract (map 3-3). An exceedance of the O3 8-hour standard occurs if the 4th-highest daily 

maximum value is above the level of the standard (0.08 parts per million [ppm] prior to 2008 

0.075 ppm from 2008 to October 2015). Table 3-9 shows no exceedances of the 8-hour 

standard for the NAAQS O3 standard that were in effect at the time.

Table 3-9. Measured O3 Concentrations (4th-Highest Daily Maximum Value) at 

Selected AQS Monitoring Sites

1

, 2011 – 2015

Parameter Measure 2011 2012 2013 2014 2015

Thunder Basin (560050123)

8-hour (ppm)20.061 0.071 0.061 0.058 0.059

8-hour (μg/m3) at STP 119.8 139.4 119.8 113.9 115.8

# of Days Maximum Exceeded 0 0 0 0 0

South Campbell County (560050456)

8-hour (ppm) 0.062 0.069 0.061 0.059 0.062

8-hour (μg/m3) at STP 121.7 135.5 119.8 115.8 121.7

# of Days Maximum Exceeded 0 0 0 0 0

1

See map 3-3 for locations

2 ppm – parts per million. The standard is attained when the expected number of days per calendar year with maximum hourly average 

concentrations above 0.12 parts per million (235 μg/m3) is equal to or less than 1, as determined by Appendix H of 40 CFR 50.

NO2 concentrations (98th percentile, 1-hour) are currently being monitored in Campbell County 

at four AQS monitoring sites (table 3-10). These monitoring sites are the closest to the DFM,

and the distances between the monitoring sites and the A2Tr1 tract range between 

approximately 17 miles and approximately 37 miles (map 3-3). As shown in table 3-10, all 

monitored NO2 values are well below the NAAQS and WAAQS of 100 μg/m3.
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-20

Table 3-10. Measured NO2 Concentrations in Campbell County, Wyoming, 2011-

2015, 98th Percentile 1-Hour NO2 Concentrations (μg/m3)

AQS1 Site ID Sampler ID 2011 2012 2013 2014 2015

560050011 Hilight-Reno Junction Gas Plant ** 46 52 55 41

560050123 Thunder Basin Grassland Site 11 11 9 10 8

560050456 South Campbell County 33 32 32 32 32

560050892 Belle Ayr Ba-4,5n,5s 36 34 35 35 32

1

See map 3-3 for location

** Indicates the monitoring site was inactive

Source: EPA 2015a

SO2 concentrations (99th percentile, 1-hour) are currently being monitored in Campbell County 

at one AQS monitoring site (table 3-11). This monitoring site is approximately 7 miles from 

the A2Tr1 tract (map 3-3). As shown in table 3-11, all monitored SO2 values are well below 

the NAAQS and WAAQS of 75 parts per billion (ppb).

Table 3-11. Measured SO2 Concentrations in Campbell County, Wyoming, 2011-

2015, 99th Percentile 1-Hour NO2 Concentrations (μg/m3)

AQS1 Site ID2 Sampler ID 2011 2012 2013 2014 2015

560050857 Wyodak Site 4 37 39 37 32 16

1 AQS-Air Quality System

2

See map 3-3 for location

Source: EPA 2015a

Annual Hg (a HAP) and Pb (a criteria pollutant) monitoring values are not collected specifically 

for the DFM. Table 3-12 shows the Hg emissions from three coal fired power plants in 

Campbell County. 

Table 3-12. Measured Annual Hg Air Emissions from Power Stations in Campbell 

County (Pounds)

Power Station 2011 2012 2013 2014 2015

Wyodak Plant 159.8 250.9 204.3 301.1 111.2

Dry Fork Station 63.0 67.0 67.0 50.0 38.3

Neil Simpson Complex 379.0 357.0 378.0 354.0 351.0

Combined Percent of Total Emission Emitted to Air 71% 57% --

1

66% 46%

1 2013 Neil Simpson total emissions value on website appears to be incorrect given the significantly lower values in 2011, 2012, 2014, and 

2015 so 2013 calculations are not included

Source: EPA (2017)

Table 3-13 shows the Pb emissions from three coal fired power plants, one mine, and one

AQS monitoring site in Campbell County. As shown in table 3-13, the Pb values from the 

Thunder Basin site (the only station reporting in μg/m3) are well below the NAAQS and 

WAAQS of 0.15 μg/m3.

Table 3-13. Measured Annual1 Pb Air Emissions1from Power Stations and One 

Coal Mine in Campbell County 

Power Station 2011 2012 2013 2014 2015

Wyodak Plant (pounds) 20.5 42.6 43.1 35.3 33.2

Dry Fork Station (pounds) 32.0 9.0 9.0 21.0 8.6

Neil Simpson Complex (pounds) 63.0 62.0 60.0 31.0 24.0

Buckskin Mining Co (pounds) 18.0 15.9 8.1 9.2 6.6

Thunder Basin (560050123) (μg/m3) 0.005 0.002 0.002 0.001 0.002

1 Pb monitoring at the Thunder Basin AQS site in presented as annual 1st maximum value 

Source: EPA (2017)
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-21

3.4.7.3 Air Quality Related Values

The evaluation of air quality related values (AQRVs) is based on the closest Class I PSD area. 

AQRVs are evaluated by the land management agency responsible for a Class I area, according 

to the agency’s level of acceptable change (LAC). These AQRVs include potential air pollutant 

effects on visibility and the acidification of lakes and streams. The AQRVs, and the associated 

LAC, are applied to PSD Class I and sensitive Class II areas and are the land management 

agency’s policy and are not legally enforceable as a standard. WAAQS do include a standard for 

visibility. Class I areas are afforded specific AQRV protection under the Clean Air Act. The 

Class I designation allows very little deterioration of air quality. The AQRVs associated with this 

action include visibility and acidification of lakes. The nearest federal Class I area is located 

approximately 74 miles north-northwest of the proposed tracts at the Northern Cheyenne 

Indian Reservation (map 3-3). CO was not monitored in Campbell County so monitoring 

results are not available.

3.4.7.3.1 Visibility

Surface coal mines are not considered to be major emitting facilities in accordance with the 

WDEQ Rules and Regulations (chapter 6, section 4). Therefore, the State of Wyoming does 

not require mines to evaluate their impacts on Class I areas, though the BLM does consider 

such issues during leasing. The current visibility discussions have been inferred from the 

currently permitted mining activities related to the existing coal leases at the DFM. Visibility can 

be defined as the distance one can see and the ability to perceive color, contrast, and detail. 

Particulates finer than 2.5 microns in effective diameter (PM2.5) are the main cause of visibility 

impairment. Visibility impairment is expressed in terms of deciview (dv). The dv index was 

developed as a linear perceived visual change (Pitchford and Malm 1994), and is the unit of 

measure used in the EPA’s Regional Haze Rule to achieve the National Visibility Goal. A change 

in visibility of 1.0 dv represents a “just noticeable change” by an average person under most 

circumstances. Increasing dv values represent proportionately larger perceived visibility 

impairment. Figure 3-4 shows annual averages for the 20 percent best, worst, and middle 

visibility days at Northern Cheyenne Indian Reservation monitoring site (the nearest PSD Class 

I area, see map 3-3) for 2003 through 2014 (Interagency Monitoring of Protected Environments

[IMPROVE] 2016). Lower dv values indicate better visibility conditions (BLM 2014). As indicated 

on figure 3-4, the long-term trend in visibility at the Northern Cheyenne Indian Reservation 

appears to be relatively stable, if not improving slightly. 

3.4.7.3.2 Air Quality Related Values Related to Coal Combustion

Emissions that affect air quality also result from combustion of fossil fuels. Table 3-14 presents 

the estimated PM10, PM2.5, SO2, NOX, Hg, and CO emissions estimates for coal mined at the 

DFM that was used for power generation.

3.4.7.3.3 Acidification of Lakes/Acid Deposition

Table 3-3 includes the WAAQS standards for H2S. Surface coal mines are not considered to 

be major emitting facilities in accordance with the WDEQ Rules and Regulations (chapter 6, 

section 4). Therefore, the state of Wyoming does not require mines to monitor H2S. Because 

the DFM is not required by WDEQ to monitor H2S, a direct comparison to WAAQS standards 

is not possible. The current H2S values for the DFM have been inferred from the currently 

permitted impacts of mining the existing coal leases at the DFM. The primary concern related 

to H2S associated with mining is from acid deposition. Acid deposition causes acidification of 

lakes and streams, which has direct impacts on aquatic habitats, and contributes to the damage 

of trees at high elevation and many sensitive forest soils (EPA 2016c). According to the EPA
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-22

Figure 3-4. Visibility in the Northern Cheyenne Indian Reservation 

Table 3-14. Estimated Annual PM10, PM2.5, SO2, NOX, Hg, and CO Contributions 

from Combustion of Coal Mined at the DFM, 2011-2015

Source: WWC Engineering (WWC) completed the calculations, which are provided in appendix C

(2002), hydrogen ion (H+) concentrations are the primary indicator of precipitation acidity. 

Table 3-15 provides the measured hydrogen ion concentrations as determined at the Site 

WY99, the closest to the DFM, for the years 2011 through 2015. The location of WY99 in 

relationship to the DFM is indicated on map 3-3. As indicated in table 3-15, the 2011-2015

trend in H+ at monitoring site WY99 appears to be relatively stable.

Table 3-15. Measured Hydrogen Ion (H+) Concentrations1at Monitoring Site 

WY99, 2011–2015

Parameter 2011 2012 2013 2014 2015

pH 5.7 5.8 5.8 5.7 5.8

Wet (kg/hectare) 0.01 <0.01 0.01 0.01 0.01

1 Measured as pH and WET (whole effluent toxicity) deposition

2 EPA 2015a

3.4.7.4 Greenhouse Gases (GHG)

According to the EPA, GHG include CO2, methane (CH4), nitrous oxide (N2O) and several 

fluorinated species of gas (EPA 2016d). CO2 is emitted from the combustion of fossil fuels, 

including coal. CH4 can be emitted during the production and transport of coal and N2O is 

emitted during agricultural and industrial activities, as well as during combustion of fossil fuels 

Source 2011 2012 2013 2014 2015 2016

Tons of Coal Combusted 5,770,964 6,006,787 5,433,936 5,373,973 6,369,206 6,135,546

PM10 (Tons) 4,009.9 4,173.7 3,775.7 3,734.0 4,425.5 4,263.2

PM2.5 (Tons) 1,223.0 1,273.0 1,151.6 1,138.9 1,349.8 1,300.3

SO2 (Tons) 50,495.9 52,559.4 47,546.9 47,022.3 55,730.6 53,686.0

NOX (Tons) 20,775.5 21,624.4 19,562.2 19,346.3 22,929.1 22,088.0

Hg (Tons) 0.2 0.2 0.2 0.2 0.3 0.3

CO (Tons) 1,442.7 1,501.7 1,358.5 1,343.5 1,592.3 1,533.9
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-23

and solid waste. CO2 and other GHGs are naturally occurring gases in the atmosphere; their 

status as a pollutant is not related to their toxicity but instead is due to the added long-term 

impacts they have on climate because of their increased incremental levels in the earth’s 

atmosphere.

The Global Warming Potential (GWP) was developed to allow comparisons of the global 

warming impacts of different gases. Specifically, it is a measure of how much energy the 

emissions of 1 ton of a gas will absorb over a given period of time, relative to the emissions of 

1.0 ton of CO2 (EPA 2014c). Each GHG has a different lifetime in the atmosphere and a different 

ability to trap heat in the atmosphere. To allow different gases to be compared and added 

together, emissions can be converted into carbon dioxide equivalent (CO2e) emissions. The 

CO2e emissions that occurred at the DFM from 2011 through 2016 have been estimated, based 

on an estimated annual coal production (table 3-16). The inventories included emissions from 

direct sources, including all types of carbon fuels used in the mining operations; electricity used 

on site (i.e., lighting for facilities, roads, and operations and conveyors); and mining processes 

(i.e., blasting, coal fires caused by spontaneous combustion, and methane released [vented] from 

exposed coal seams). CO2e emissions from indirect sources (transportation of coal via rail and 

coal combustion) were also estimated.

As determined from information in table 3-16, emissions from direct sources accounted for 

approximately 43,429 metric tons of CO2e in 2016. This equates to approximately 0.4 percent 

of the total 2016 CO2e emissions related to mining and combusting approximate 6.1 Mt of DFM 

coal (see appendix C for calculations).

Emissions from transporting the coal via rail to final destinations at power plants and loading 

terminals were calculated using annual average rail miles from the DFM to final destinations. 

The average haul distances were calculated using the weighted average of haul distances from 

the DFM for annual coal sales for 2011 through 2016 (WFW 2016a). As indicated in table 3-

16, approximately 21,199 metric tons of CO2e were produced in 2016 from the transport of 

the 6.1 Mt of coal mined at the DFM (see appendix C for calculations). The amount of CO2e 

emitted during the combustion of fossil fuels varies according to the carbon content and heating 

value of the fuel used (EPA 2008). Table 3-16 shows that approximately 10.3 Mt of CO2e were 

produced in 2016 from the combustion of the 6.1 Mt of coal mined at the DFM (see appendix 

C for calculations). Therefore, emissions from indirect sources accounted for approximately 

99.6 percent of the total 2016 CO2e emissions related to mining and combusting 6.1 Mt of DFM 

coal.

The potential for emissions of dust can be an environmental concern for coal use/transport 

projects due to the large volumes of coal transported to large generating stations (Ramboll 

Environ 2016). Coal dust and fines blowing or sifting from moving, loaded rail cars has been 

linked to railroad track stability problems resulting in train derailments and to rangeland fires 

caused by spontaneous combustion of accumulated coal dust (BLM 2009). While no specific 

studies of coal dust impacts have been conducted in the PRB, BNSF has been involved in 

research regarding the impacts of coal dust escaping from loaded coal cars on rail lines in the 

PRB. BNSF has determined that coal dust poses a serious threat to the stability of the track 

structure and the operational integrity of rail lines in, and close to, the mines in the PRB.

3.4.7.5 Emission Standards at Coal Combustion Sources

As stated in section 1.2.1, the DFM currently supplies the DFS with approximately 2.0 Mtpy 

of coal for power generation. The CAA enacted the NSPS and National Emissions Standards 

for HAPS for specific types of equipment located at new or modified stationary pollutant

sources. NSPS regulations limit emissions from new, modified, or reconstructed emission units
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-24

Table 3-16. Estimated 2011-2016 Emissions from Direct and Indirect CO2e Sources1at the DFM

2011 2012 2013 2014 2015 2016 Average

General

Mt of Coal Recovered 5.77 6.01 5.43 5.37 6.37 6.14 5.8

Mt of Coal Shipped by Conveyor (All 

to DFS) 1.01 2.03 1.99 2.14 2.10 1.83 1.85

Mt of Coal Shipped by Rail 4.76 3.98 3.44 3.24 4.27 4.30 3.94

Average Transport Miles (One Way) 365 192 250 142 132 141 216

Number of Train Trips (One Way) 308 257 222 209 276 278 258

Direct Emissions Sources

Fuel 18,853 19,624 19,624 17,556 20,808 20,026 19,415

Electricity Consumed in Mining Process 15,409 16,039 16,039 14,349 17,006 16,368 15,868

Mining Process 6,623 6,894 6,894 6,168 7,310 7,035 6,821

Total from Direct Sources 40,886 42,556 42,556 38,073 45,124 43,429 42,104

Indirect Emissions Sources

Rail Transport260,693 26,675 30,030 16,044 19,687 21,199 29,055

From Coal Combustion39,666,365 10,061,368 9,101,843 9,001,405 10,668,420 10,277,040 9,796,073

Total from Indirect Sources 9,727,058 10,088,043 9,131,873 9,017,448 10,688,107 10,298,239 9,825,128

Total Estimated CO2e Emissions 9,767,943 10,130,599 9,174,429 9,055,521 10,733,231 10,341,668 9,867,232

1

In metric tons - see appendix E for calculations

2 Coal haulage emissions based on 130-car trains with four locomotives, train trips per year; 488.2 kg CO2e per mile per loaded train, 96.1 Kg CO2e per mile per empty train; and round-trip mileage to 

power plants. Coal haulage emissions calculations includes a loaded train and a returning empty train, per train trip. 

3 Based on 1.683 metric tons CO2e per ton of coal burned for electrical generation (EPA 2008) and calculated by WWC (2017). 
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-25

under the regulated source categories. Stationary sources typically meet the NSPS limits by 

installing modern equipment and/or adding air pollution control equipment. Specific to this EA, 

NSPS emissions standards apply to combustion of coal at the DFS. Other NSPS standards also 

may apply at the DFS Station related to coal processing (i.e., crushing and screening).

Beginning in 2011, the DFS and other electricity generating facilities became subject to new 

emission standards to reduce Hg and other toxic air pollution from coal and oil combustion at 

Electric Generating Units (EGUs). These rules set technology-based emission limitation 

standards for Hg and other toxic air pollutants, reflecting levels achieved by the best-performing 

sources currently in operation. The final rule established HAP standards for new and existing 

coal- and oil-fired EGUs with a capacity of 25 MW or greater. All regulated EGUs are considered 

major sources under the final rule. While new sources must meet the standards at start-up of 

operations, existing sources generally have up to 4 years to comply with the MATS. The 

emissions limits associated with the MATS rule are presented in table 3-17. The DFS Station 

is considered an existing facility and currently only burns coal to generate electricity. As 

indicated in WDEQ-AQD correspondence, as of the time of the inspection (October 6, 2015), 

the DFS was in compliance with all applicable WAQSR (WDEQ-AQD 2014). There are four

existing coal-fired EGUs currently operating in Campbell County. 

Table 3-17. MATS Emission Requirements1for Coal-Fired Units

EGU Subcategory Mercury Emission Limit

(lb./GWh)

Existing Regular Coal 0.013

Designed for Low Rank Coal20.12 or 0.040

New Regular Coal 0.0002

Designed for Low Rank Coal 0.04

1 The Supreme Court recently held that the EPA did not properly consider the costs of the MATS rule. See Michigan v. USEPA, 192 L. Ed. 

2d 674 (June 29, 2015). The consequences of this decision are still being assessed by EPA and the lower courts. For purposes of the A2Tr1 

EA, the analysis includes the 2011 MATS rule because the DFS has already complied with those standards.

2 Most of these units burn lignite coal.

lb./GWh = pounds of pollutant per gigawatt hour – electric output.

Source: EPA 2012.

The DFS is located adjacent to the DFM and is operated by Basin Electric Power Cooperative. 

The DFS consists of one coal-fired steam driven EGU with a net electric generating capacity of 

422 MW. The DFM provides all of the coal utilized at the DFS. Actual emissions data for DFS 

are listed in table 3-18.

Table 3-18. Dry Fork Station Reported Emissions, 2011-2015

Emissions 2011 2012 2013 2014 2015

CO2 (Tons) 1,342,695 3,555,746 3,588,183 3,635,576 3,415,773

NOX (Tons) 232.1 619.6 635.6 657.2 672.0

SO2 (Tons) 278.6 691.5 829.7 884.1 869.7

Hg (Tons) 0.036 0.042 0.043 0.035 0.033

Source: SNL 2016 (CO2, NOX, and SO2), EPA 2017a (Hg)

The Wyodak Power Plant (owned and operated by PacifiCorp) is located approximately 7 miles 

southeast of the A2Tr1 tract. It consists of one coal-fired steam-driven EGU. The Wyodak plant 

has a rating of 402 MW. The DFM does not provide coal to the Wyodak Power Plant.

Neil Simpson Complex consists of the Neil Simpson 1 and Neil Simpson 11 stations, owned and 

operated by Black Hills Corporation. The complex is located approximately 7 miles southeast 

of the A2Tr1 tract. The Neil Simpson 1 station was retired in 2014. The Neil Simpson 11 has a 

rating of 80 MW. The DFM does not provide coal to the Neil Simpson Complex.
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-26

Wygen Station is a coal-fired power station owned and operated by Black Hills Corporation 

located approximately 7 miles southeast of the A2Tr1 tract. It consists of three coal-fired 

steam-driven stations (Wygen I, II, and III). The Wygen Station has a combined rating of 294 

MW. The DFM does not provide coal to the Wygen Station.

3.5 Water Resources

3.5.1 Surface Water

The following discussions on surface water are summarized from Appendix D6 (Hydrology) of 

the DFM Permit No. PT0599 (WFW 2011) and from the WDEQ-LQD’s Cumulative Hydrologic 

Impact Assessment of Coal Mining in the Northern Powder River Basin, Wyoming (2013 CHIA)

(WDEQ-LQD/Lidstone 2013).

The DFM is located along the Dry Fork Little Powder River (LPR). Watersheds and surface 

drainages associated with the DFM are shown on map 3-4. Dry Fork LPR is joined within the 

permit boundary by Moyer Springs Creek. The drainage area of Dry Fork LPR is approximately 

10,720 acres (16.75 square miles). Dry Fork LPR joins the Little Powder River about 2.5 miles 

north of the permit boundary. The Little Powder River joins the Powder River in Montana, and 

the Powder River then flows into the Yellowstone River. According to information included in 

the 2013 CHIA, Dry Fork LPR is ephemeral upstream of Moyer Springs Creek. Streamflows 

monitored at Dry Fork Mine station CR-3 upstream of the confluence with Moyer Springs 

Creek illustrate the effect of Moyer Springs on the flow regime of the Dry Fork LPR. From 

October 1980 to December 1982, flow was only recorded during 23 days, or 3 percent of the 

period. Streamflow at the station was caused by snowmelt or summer rain events, with flows 

usually lasting less than five days after an event. The maximum mean daily discharge during the 

monitoring period was 13.6 cubic feet per second (cfs).

At CR-3 on Dry Fork upstream of the confluence with Moyer Springs (map 3-5), five water 

quality samples were collected from May 1981 to August 1982 (WDEQ-LQD/Lidstone 2013). 

The dominant ions were calcium and sulfate. Total dissolved solids (TDS) and total suspended 

solids (TSS) concentrations were generally higher and more variable than further downstream. 

TDS ranged from 218 to 4,710 milligrams per liter (mg/L), with a median of 2,720 mg/L. TSS 

ranged from 34 to 2,680 mg/L, with a median of 60 mg/L. Most dissolved metals had 

concentrations below detection limits. There were no exceedances of Class 3B standards 

(WDEQ-WQD 2016) for any constituent. Water quality of the surface waters within the DFM 

permit area is suitable for livestock watering.

Boron and sulfate concentrations consistently exceed domestic and agricultural use

designations, with total dissolved solids, Pb, and cadmium levels occasionally exceeding the 

maximum values for domestic and agricultural use, particularly during the summer months. 

Streamflow and surface-water quality associated with the DFM are currently being monitored 

at five monitoring sites (map 3-5). Water-quality data from surface water sites are included in 

the 2013 CHIA.

The surface water hydrologic system within the A2Tr1 tract is dominated by two drainage 

systems. One of these is Moyer Springs Creek and the other is East Draw. These drainage 

systems or basins are tributaries to Dry Fork LPR. A very small portion of the combined Draw 

1, 2, and 3 system and one internally drained basin (IDB) #2 are also associated with the tract. 

According to information presented in Appendix D6 (Hydrology) of the DFM Permit No. 

PT0599, the portions of Moyer Springs Draw, East Draw, and the combined Draw 1, 2, and 3 

system within the tract have ephemeral flows (respond only to rainfall or snowmelt events) 

(WFW 2011). Moyer Springs Creek below Moyer Springs maintains a perennial flow due to 

ground-water discharge from Moyer Springs. Within the A2Tr1 tract, the drainage area of 

Moyer Springs Creek is approximately 95.8 acres, East Draw is approximately 221.9 acres in 
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-27

size, the combined size of Draws 1, 2, and 3 system is approximately 0.7 acres, and IDB 2 is 

approximately 46.1 acres in size.

The surface-water quality varies with stream flow rate; the higher the flow rate, the lower the 

TDS concentration but the higher the suspended solids concentration. Due to the flow 

fluctuations (no flow to 3.3 cfs, as determined from flows at CS-1, CS-2, CS-4, CS-5, CS-6 

surface water monitoring sites [WFW 2014]), the surface water quality is usually unsuitable for 

domestic use but suitable for irrigation and livestock use, as determined from parameters 

presented in Ayers and Westcot (1976).

According to information included in the 2013 CHIA, Moyer Springs is comprised of a series of 

groundwater discharge points along the lower reaches of Moyer Springs Creek. Discharge from 

the springs originates in coal and scoria aquifers in the east, south, and southeast. Recharge to 

the aquifers is affected by precipitation inputs, which in turn affect the quantity of discharge 

from Moyer Springs. The DFM estimated that approximately 0.25 cfs of base flow can be 

attributed to clinker recharge and 0.17 cfs of base flow comes from the coal overburden aquifer 

groundwater discharging along the Dry Fork LPR. An additional 0.04 cfs is predicted to be lost 

to evaporation, totaling 0.42 cfs of groundwater discharge to surface flows. Water balance 

calculations demonstrate that the outflow from the Moyer Springs Creek valley totals 

approximately 948 acre-feet (ac-ft), with 919 ac-ft being contributed from Moyer Springs and 

groundwater in alluvium (WDEQ-LQD/Lidstone 2013).

The dominant ions measured in samples collected from the Moyer Springs between 1979 and 

1982 were calcium and sulfate. The pH ranged from 6.7 to 9.7, with a median of 7.8. The 

maximum pH of 9.7 exceeds Class 2AB standards (WDEQ-WQD 2016). TDS ranged from 

1,030 to 1,256 mg/L, with a median of 1,119 mg/L. The consistent TDS concentrations reflect 

the quality of the spring discharge in contrast to the more variable surface water concentrations 

usually observed following runoff events. TSS concentrations were very low and reflective of 

spring discharge, ranging from 1 to 19 mg/L with a median of 1 mg/L. Dissolved metal 

concentrations were also very low, with numerous values below detection limits. Class 2AB 

criteria were met with the exception of 18 exceedances of Pb, seven exceedances of copper, 

and 18 exceedances of cadmium. The cadmium and Pb exceedances occurred during the first 2 

years of sampling (WDEQ-LQD/Lidstone 2013).

3.5.2 Groundwater

The following discussions on groundwater are summarized from Appendix D6 (Hydrology) of 

the DFM WDEQ-LQD Permit No. PT0599 (WFW 2011) and from the 2013 CHIA 

(WDEQ-LQD/Lidstone 2013).

Hodson et al. (1973) list a number of geologic units in the mine area that are water-bearing. 

Only five of these will be affected by the proposed mining operations. The affected aquifers are 

the Quaternary alluvium, the burned and fused bedrock (Wyoming porcelanite or scoria), the 

early Tertiary Wasatch Formation, the coals of the Paleocene Fort Union Formation, and the 

reclaimed backfill. The Fort Union Formation that underlies the target coal seams will not be 

physically disturbed by mining activities but may be used for water supply.

3.5.2.1 Alluvium

Groundwater in recent alluvium (sediments deposited by water flow) occurs primarily near and 

along the valley and draw bottoms associated with Dry Fork LPR. Most of the alluvial deposits 

within the Dry Fork Mine property are very fine-grained, reflecting the texture of the Wasatch 

Formation from which they were derived. Some coarse-grained material occurs in the

lowermost alluvial strata and exhibits the greatest permeability of the alluvial deposits. This

alluvium is directly connected to and recharged by groundwater in adjacent clinker and the
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-28

Map 3-4. Watersheds and Surface Drainages Associated with the DFM
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-29

Map 3-5. Surface Water Drainages and Surface Water Monitoring Sites at the 

DFM
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-30

Wasatch overburden. Alluvial groundwater flow generally follows topography, flowing out of 

upland areas into the valley and draw bottoms, then down-valley along the Dry Fork LPR 

drainage. 

The 2013 CHIA presented water quality analysis from 50 alluvial wells in the northern PRB. 

When compared to select parameters with the WDEQ/WQD Class III livestock standards, 

exceedances were observed for aluminum (one well), arsenic (one well), boron (five wells), 

chromium (nine wells), Pb (12 wells), Hg (44 wells), selenium (one well), sulfate (24 wells), TDS 

(24 wells), and pH (two wells). TDS ranged from 300 to 15,636 mg/L with a median of 3,859 

mg/L (Table 21). The water quality of the alluvial aquifer generally exhibited the highest TDS 

concentrations among all the aquifers. Water-quality data from the 50 alluvial wells are included 

in the 2013 CHIA.

Hydraulic gradients are similar to the topographic and valley-bottom slopes on which the 

deposits reside. The hydraulic conductivities in the alluvial aquifer ranged from 0.42 to 203 feet 

per day (ft/d). The median hydraulic conductivity of the alluvial aquifer was 12 ft/d. The hydraulic 

conductivities of the alluvial aquifer are generally higher when they are in close proximity to the 

clinker. Additionally, the hydraulic conductivity in the alluvial aquifer varies due to the 

discontinuous nature of the lenses within the sediments (WDEQ-LQD/Lidstone 2013).

3.5.2.2 Clinker (Wyoming Porcelanite or Scoria)

The other major bedrock unit is clinker (also variously called porcelanite, shale, or scoria). 

Clinker is generally resistant to erosion and forms round topped hills. Clinker is a material that 

results from the baking and fusing of overlying rocks during the burning of underlying coal beds. 

It is red to purple, porcelaneous and hard, and has a slag-like texture. Drainages developed on 

porcelanite usually exhibit an irregular pattern due to fracturing and a low drainage density due 

to high infiltration rates.

The 2013 CHIA presented water quality analysis from 15 clinker wells in the northern PRB. The 

analysis showed that the water quality of the clinker is poor, with six parameters exceeding the 

Class III livestock standards, including: chromium (one well), Pb (one well), Hg (seven wells), 

sulfate (two wells), TDS (two wells), and pH (one well). TDS ranged from 530 to 7,930 mg/L, 

with a median of 2,051 mg/L. A water quality type analysis indicated that the dominant baseline 

water quality type in the clinker was calcium sulfate (WDEQ-LQD/Lidstone 2013). Waterquality data from the 15 clinker wells are included in the 2013 CHIA.

Aquifer tests were conducted at a total of 17 wells completed in the clinker at the Rawhide, 

Dry Fork, and Synthetic Fuels mines. Hydraulic conductivities ranged from 3.0 to 504,000 ft/d, 

with a median of 414 ft/d. The high hydraulic conductivities calculated for the clinker likely 

incorporate a considerable level of uncertainty due to the difficulty of calculating conductivity 

from the small amount of drawdown measured in the observation wells (WDEQ-LQD/Lidstone 

2013).

3.5.2.3 Wasatch (Overburden) Formation

The overburden in the DFM permit area is almost entirely composed of the Eocene Wasatch 

Formation and is commonly overlain by weathered residuum. In the permit area, the 

overburden ranges from approximately 10 feet to 210 feet thick and averages approximately 

110 feet. In the permit area, the Wasatch Formation is a complex interfingering of claystones, 

shales, siltstones, sandstones, and minor, thin limestone beds. The overburden is dominated by 

claystones and siltstones, but is extremely variable.
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-31

There are some relatively thick sandstone units present, but these are very discontinuous and 

usually well cemented. The result is isolated and perched aquifers in the Wasatch overburden 

that are capable of producing, at best, only low yields. Perched aquifers tend to drain fast and 

to be quite seasonal, becoming dry during periods of low rainfall.

The 2013 CHIA presented water quality analysis collected at 22 overburden wells. When 

compared to select parameters with the WDEQ/WQD Class III livestock standards, 

exceedances were observed for aluminum (one well), chromium (two wells), Pb (two wells), 

Hg (12 wells), sulfate (two wells), TDS (one well), and pH (six wells). TDS concentrations ranged 

from 180 to 5,290 mg/L, with a median of 1,975 mg/L. In general, TDS concentrations were less 

variable and lower in concentration than in the alluvial wells. A water quality type analysis (piper 

diagram) indicated that the baseline water type in the overburden varied between calcium 

sulfate, sodium sulfate, and sodium bicarbonate (WDEQ-LQD/Lidstone 2013). 

Aquifer tests were conducted at a total of 38 overburden wells. The median hydraulic

conductivity was 0.34 ft/d, with a maximum of 103 ft/d and a minimum of 0.001 ft/d. The 

variability in conductivity is likely due to the discontinuous nature of the sediments and the 

difficulty in testing wells that are low yielding (WDEQ-LQD/Lidstone 2013).

3.5.2.4 Coal Aquifers

As described in section 3.3.1, the coal to be mined is within the Wyodak-Anderson coal seam 

(made up of the upper Anderson coal seam and the lower Canyon coal seam separated by a 

claystones and carbonaceous coal lens) is the uppermost unit of the Tongue River Member of 

the Paleocene Fort Union Formation. In terms of lithology, the Fort Union Formation consists 

of approximately 2,500 feet of a predominantly claystone and siltstone sequence with some coal 

units and lenticular sandstones. The thicker coal units, such as the Wyodak-Anderson seam, are 

generally suitable for use as low yield aquifers.

The 2013 CHIA presented water quality analysis collected at 61 coal wells. When compared to 

select parameters with the WDEQ/WQD Class III livestock standards, Exceedances were 

observed for aluminum (one well), boron (two wells), cadmium (one well), chromium (four 

wells), Pb (three wells), Hg (30 wells), sulfate (six wells), TDS (three wells) and pH (13 wells). 

TDS concentrations ranged from 324 to 5,620 mg/L with a median of 1,117 mg/L. The water 

quality type in the coal was highly variable as it is dependent on several factors, including the 

proximity of a coal well to the clinker and the alluvial aquifers, depth of the well, and the local 

geochemistry (WDEQ-LQD/Lidstone 2013). Water-quality data from the 61 coal wells are 

included in the 2013 CHIA.

There were 59 aquifer tests conducted in the Wyodak-Anderson coal aquifer by the six coal 

mines. The permeability of coal is characterized by cleat permeability (natural opening-mode 

fractures in coal beds) and secondary permeability due to folding and faulting. The median 

hydraulic conductivity was 1.1 ft/d, with a maximum of 715 ft/d and a minimum of 0.01 ft/d.

3.5.2.5 Backfill Aquifer

When coal mines are reclaimed, the overburden is returned to the mined-out portion of the 

pit as backfill, and the mined area is reclaimed to the approved post-mining topography. The 

backfill material gradually saturates with groundwater entering through surface infiltration and 

from the adjacent aquifers and becomes a shallow backfill aquifer with unique aquifer properties 

and water chemistry (WDEQ-LQD/Lidstone 2013). Backfill aquifers include deeper backfill 

aquifer and shallow backfill aquifer in reclaimed alluvial valley floors (AVFs), if present.
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-32

The 2013 CHIA presented water quality analysis collected at 26 deeper backfill wells located 

within the Dry Fork, Rawhide, Buckskin, Eagle Butte, and Wyodak mines. The minimum median 

TDS was 1,265 mg/L and the maximum median TDS 8,590 mg/L. There were eight wells with a 

2009-2011 median TDS greater than 5,000 mg/L. The TDS time-series plots show trends of 

increasing TDS concentrations until the mid-1990s and then concentrations generally stabilize.

The predominant water quality type in the backfill is calcium sulfate or magnesium sulfate. 

Although calcium and sulfate are the dominant ions, significant quantities of bicarbonate, sodium, 

and magnesium are also present (WDEQ-LQD/Lidstone 2013). Water-quality data from the 26 

deeper backfill wells are included in the 2013 CHIA.

The 2013 CHIA presented water quality analysis collected at four alluvial backfill wells. TDS 

concentrations have varied between the AVF backfill wells. TDS concentrations have exceeded 

the WQD Class III livestock standard of 5,000 mg/L beginning in 2001 at three of the four 

alluvial backfill wells, with a maximum value of 17,900 mg/L in one well. While TDS 

concentrations at two wells are elevated relative to baseline conditions, recent data from two 

of the AVF backfill wells suggests that water quality is comparable to pre-mining conditions 

(WDEQ-LQD/Lidstone 2013). Water-quality data from the four alluvial backfill wells are

included in the 2013 CHIA.

There were eight aquifer tests conducted by the mines in the backfill aquifer. The median 

hydraulic conductivity was 0.07 ft/d, with a maximum of 2.7 ft/d and a minimum of 0.004 ft/d 

(WDEQ-LQD/Lidstone 2013).

3.5.3 Water Rights

The State Engineer’s Office administers water rights in Wyoming, which are granted for both 

groundwater and surface water. Their records indicate that, as of October 2016, 311 permits 

for ground-water rights are within 2 miles of the A2Tr1 tract, 109 of which are for valid, 

non-coal applicants. Valid ground-water rights for non-coal applicants are listed in appendix 

D. The breakdown of non-coal ground-water rights is as follows:

 25 Stock

 19 Miscellaneous

 19 Monitoring

 11 CBNG

 7 CBNG, Miscellaneous 

 7 Domestic, Stock

 7 Industrial

 5 Domestic

 5 Industrial, Miscellaneous

 1 CBNG, Irrigation

 1 CBNG, Miscellaneous, Stock

 1 CBNG, Stock

 1 Domestic, Industrial

State Engineer’s Office records indicate that, as of October 2016, 71 permits for surface water 

rights are within 2 miles of the A2Tr1 tract, 38 of which are for non-coal applicants. Surface 

water rights for non-coal applicants are listed in appendix D. The breakdown of non-coal 

surface water rights is as follows:

 14 Irrigation Stock

 13 Reservoir Supply
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-33

 6 Domestic, Irrigation

 2 Industrial

 1 CBNG, Industrial

 1 Industrial, Storage

 1 Blank

3.6 Wetlands/Aquatic Resources

Wetlands are aquatic features defined as “those areas that are inundated or saturated by surface 

or groundwater at a frequency and duration sufficient to support, and that under normal 

circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil 

conditions. Wetlands generally include swamps, marshes, bogs, and similar areas” (33 CFR 

328.3(b)). The prolonged presence of water creates conditions that favor the growth of specially 

adapted plants and promote the development of characteristic wetland (hydric) soils (EPA 

2017b). Vegetation in wetland environments is highly productive and diverse and provides 

habitat for many wildlife species. These systems as a whole play important roles in controlling 

floodwaters, recharging groundwater, and filtering pollutants (Niering 1985).

Jurisdictional wetlands are defined as those wetlands that are within the extent of the U.S. Army 

Corps of Engineers (USACE) regulatory review. These wetlands must contain three 

components: hydric soil, a dominance of hydrophytic vegetation, and wetland hydrology. 

Nonjurisdictional wetlands are generally associated with internally drained depressions/playas 

that are isolated; nonjurisdictional other waters generally occur where areas of open water are 

ponded in a depression/playa area.

Aquatic resources associated with the A2Tr1 tract (the analysis area) were delineated according 

to the 1987 USACE wetlands delineation Manual and the 2008 Great Plains Regional 

Supplement. Other Waters of the United States were determined according to definitions in 33 

CFR 328.3. Potential aquatic resources were identified by examining topographic maps and 

National Wetlands Inventory (NWI) maps. All potential wetlands identified through those 

reviews were surveyed in the field from May through September of 2010. Surveys were also 

conducted on the remainder of the lands in traverses across the study area. Vegetation, 

hydrology, and soil characteristics of aquatic sites and uplands were recorded on field data 

sheets and locations of observations were plotted on topographic maps. 

Four sites within the A2Tr1 tract were evaluated for wetland characteristics in 1997 and 2011 

by Intermountain Resources (WFW 2011). Based on the results of the surveys, no wetlands 

were identified in the A2Tr1 tract. The USACE determined that Department of Army 

authorization is not required for the remaining LOM coal mining activities at Dry Fork Mine 

(USACE 2012).

3.7 Soils

The following discussions on soils resources are summarized from Appendix D7.2 (Soils) of the 

DFM WDEQ-LQD Permit No. PT0599 (WFW 2011).

The soil resources of the A2Tr1 tract (the analysis area) were investigated by Jim Nyenhuis, 

Certified Professional Soil Scientist/Soil Classifier, during the spring, summer, and fall of 2010. 

All lands within the area were mapped at the Order 1-2 level of intensity. The entire area was 

traversed on foot. Soil map unit boundaries were delineated by observing surface conditions, 

vegetation, slope position, and soil profiles exposed using a sharpshooter and bucket auger. Soil 

survey information for adjacent and nearby permitted areas was reviewed to determine whether 

soils and their recommended salvage depths were similar to those within the A2Tr1 tract. 
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-34

WDEQ-LQD determined that the soils within the tract are similar to those currently being 

salvaged and utilized for reclamation at the DFM (WDEQ-LQD Permit No. PT0599), and these 

soils have been previously sampled a sufficient number of times.

Table 3-19 lists the 17 soil map units (plus disturbed lands [DL], reclaimed lands [RL], and 

water [W]) within the A2Tr1 tract (map 3-6). Also included in the table are the total soil 

depths, the current recommended soil salvage depths, and any limitations to deeper salvage. 

According to information provided on the Natural Resources Conservation Service (NRCS) 

website, no soil map units within the A2Tr1 tract were classified as prime or unique farmlands 

(NRCS 2016).

3.8 Vegetation

The following discussions on vegetation are summarized from Appendix D8.2 (Vegetation 

Assessment) of the DFM WDEQ-LQD Permit No. PT0599 (WFW 2011).

The field mapping of the area was completed in 2010. This survey was designed to map 

vegetation types, prepare a plant species list and collect sampling data. Cover data was collected 

in July for the grassland, upland sagebrush, bottomland, clinker/breaks, pastureland and 

reclaimed community types on the A2Tr1 tract. Shrub density sampling was also completed for 

the grassland, upland sagebrush, and clinker/breaks types, and shrub density sampling was 

completed on the reclaimed land and pastureland. Vegetation types were determined through 

identification of major plant species, approximate coverage of these species, dominant ground 

cover classes, and percentage of bare ground.

The vegetation community types identified on the study areas include grassland, upland 

sagebrush, bottomland, clinker/breaks, pastureland and reclamation. No cultivated croplands 

are found within the tract (map 3-7).

3.8.1 Vegetation Community Types

Grassland - Western wheatgrass (Agropyron smithi) was the dominant plant species recorded on 

this amendment area vegetation type, followed by blue grama (Bouteloua gracilis), threadleaf 

sedge (Carex filifolia), needleandthread (Stipa comata), and crested wheatgrass (Agropyron 

cristatum). Perennial forb species made up 6.0 percent of the total absolute vegetation cover for 

the grassland vegetation type. The shrub density data for the area showed that fringed sagewort 

(Artemisia frigida) was the most dominant subshrub species recorded on this area while silver 

sagebrush (Artemisia cana) was the most dominant full shrub species. Other common shrub 

species recorded on this type included big sagebrush (Artemisia tridentata), and rubber 

rabbitbrush (Chrysothamnus nauseosus). Other commonly recorded subshrubs on this type 

included broom snakeweed (Gutierrezia sarothrae), granite pricklygilia (Leptodactylon pungens) and 

Gardner saltbush (Atriplex gardnen). 

Upland Sagebrush - Western wheatgrass was the dominant plant species recorded on this 

vegetation type, followed blue grama, big sagebrush, needleandthread and fringed sagewort. 

Perennial forb species made up 7.2 percent of the total absolute vegetation cover for the upland 

sagebrush vegetation type. Big sagebrush was the most dominant species recorded in shrub 

density transects on this vegetation type. Fringed sagewort was the most dominant subshrub

species recorded on this vegetation type. Silver sagebrush (Artemisia cana) was also commonly 

recorded on this type in 2010. Other shrub and subshrub species were also recorded but were 

observed in limited numbers.
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-35

Table 3-19. List of Map Units and Topsoil Salvage Depths for the A2Tr1 Tract 

Map Unit 

Symbol Map Unit Name

Total Soil 

Depth 

(in.)

Total 

Salvage 

Depth (in.)

Limitations to Deeper 

Salvage

1A Haverson loam,

0 to 0.03 slopes 60+ 60 High salinity at depth

c26CD Vona fine sandy loam,

6 to 15% slopes 60+ 31

Low organic matter content 

below 31", possible loamy sand 

texture at depth

75CD Cushman loam,

3 to 6% slopes 20-40 30 Possible high salinity at depth

b768 Renohill loam,

3 to 6% slopes 20-40 24 No major limits

79DB Shingle loam,

3 to 15% slopes 10-20 8 Heavy clay texture

c798 Briggsdale loam,

3 to 6% slopes 20-40 30 Heavy clay texture

c85AB Ulm clay loam,

0 to 6% slopes 60+ 36 Possible higher sodicity at depth

94C Stoneham fine sandy loam,

6 to 15% slopes 60+ 45

No unsuitability but higher 

sodium adsorption rate (SAR)

and EC below 45"

347D

Shingle-Rock OutcropSamsil,

10 to 15% slopes

10-20

RO=0 0

Soil depth, heavy clay texture 

(Samsil)

403D Shingle-Cushman,

10 to 15% slopes

10-20 (Sh)

20-40 (Cu) 15 Soil depth, possible highsalinity at depth (Cushman)

404CD Tassel-Tullock-Vona,

6 to 30% slopes

TA: 10-20

Tu: 20-40

Vo:60+

26

Salvage to sandstone

bedrock or coarse sand

texture

412AB Potts Variant-Wibux,

0 to 6% slopes

PV: 60+

Wi: 10-20 24 Fragmental subsoil

412CD Potts Variant-Wibaux,

6 to 15% slopes

PV: 60+

Wi: 10-20 12 Fragmental subsoil

2-6

Bowbac loam, 

3 to 6% slopes 20-40 24 Heavy clay texture below 24"

2-26 Tullock Variant sandy loam, 

10 to 30% slopes 20-40 30 Weathered bedrock, loamy sand texture at depth

2-29 Vona sandy loam, 

6 to 15% slopes 60+ 33

Low organic matter content and 

possible loamy sand or sand 

texture below 33"

DL Disturbed Land -- -- No soil salvage

RL Reclaimed Land -- 18 No more topsoil to salvage

W Water -- -- No soil salvage

Source: WFW 2011
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-36

Map 3-6. Soil Types Associated with the A2Tr1 Tract
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-37

Map 3-7. Vegetation Map Units (Community Types) Associated with the A2Tr1 

Tract
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-38

Bottomland - Western wheatgrass was the dominant plant species recorded on this amendment 

area vegetation type followed by Kentucky bluegrass (Poa pratensis), crested wheatgrass, and 

foxtail barley (Hordeum jubatum). Perennial forb species made up 10.0 percent of the total 

absolute vegetation cover for the bottom land vegetation type. Shrub density sampling was not

required by the WDEQ-LQD for this vegetation community in 2010.

Scoria/Breaks - Crested wheatgrass was the dominant plant species recorded on this amendment 

area vegetation type followed by bluebunch wheatgrass (Agropyron spicatum), western wheatgrass, 

big sagebrush and green needlegrass (Stipa viridula). Perennial forb species made up 11.2 percent 

of the total absolute vegetation cover for the scoria/breaks vegetation type. The shrub density 

data for this map unit shows that big sagebrush was the most dominant full shrub species while 

fringed sagewort was the most dominant subshrub species recorded on this area. Other common 

shrub species recorded on this type included rubber rabbitbrush. Other commonly recorded 

subshrubs on this type included broom snakeweed and fewflower wildbuckwheat (Eriogonum 

pauciflorum).

Pastureland - Crested wheatgrass was the dominant plant species recorded on this amendment 

area vegetation type and accounted for approximately 93.5 percent of the total vegetation cover 

recorded on this type. Other plant species were also recorded but in lower numbers. Perennial 

forb species made up 1.4 percent of the total absolute vegetation cover for the pastureland

vegetation type. Broom snakeweed was the most dominant subshrub species recorded in shrub

density transects on this vegetation type. Woods rose (Rosa woodsii) was the most dominant 

shrub species recorded on this vegetation type in 2010. Other shrub and subshrub species were 

also recorded but were observed in limited numbers. 

Reclaimed - The most dominant plant species recorded on this type was intermediate wheatgrass 

(Agropyron intermedium) followed by western wheatgrass, slender wheatgrass (Agropyron 

trachycaulum), the annual forb flixweed tansymustard (Descurainia sophia) and green needlegrass.

Perennial forb species made up 3.2 percent of the total absolute vegetation cover for the 

reclaimed vegetation type. No shrub or subshrub species were recorded in shrub density 

transects on this type. However, a few shrub and subshrub species were observed growing on 

this type in 2010.

Disturbed Land - This type is typically oil well pads, paved roads or ranch associated areas. This 

area was not sampled during the 2010 study because of the limited amount of vegetation present 

on those areas.

Water/Wetland - This type is discussed in detail in section 3.6 and consists of stockponds, 

playas, wet ephemeral streams and small depressions.

3.8.2 Special Status Plant Species

Threatened or endangered plants or other plant species of special concern, as listed by the 

USFWS and other agencies, were not encountered within the DFM A2Tr1 tract (WFW 2011). 

Habitat for the Ute ladies' tresses orchid (Spiranthes diluvialis) is marginal on this amendment area 

due to the lack of suitable wetlands. However, the marginal wetlands were surveyed on August 

13, 2010 but no Ute ladies'-tresses orchids were found.

The State of Wyoming maintains a list of designated noxious weeds (Wyoming Department of 

Agriculture [WDOA] 2016). This list includes invasive and nonnative plant species, that once 

established, can out-compete and eventually replace native species, thereby reducing forage 

productivity and the overall vigor and diversity of existing native plant communities. The following 

26 plant species are currently designated as noxious weeds by the State of Wyoming:

1. Field bindweed (Convolvulus arvensis),

2. Canada thistle (Cirsium arvense),
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-39

3. Leafy spurge (Euphorbia esula),

4. Perennial sowthistle (Sonchus arvensis)

5. Quackgrass (Agropyron repens),

6. Hoary cress (Cardaria draba),

7. Perennial pepperweed (giant whitetop) (Lepidium latifolium), 

8. Ox-eye daisy (Chrysanthemum leucanthemum),

9. Skeletonleaf bursage (Franseria discolor Nutt.),

10. Russian knapweed (Centaurea repens),

11. Yellow toadflax (Linaria vulgaris),

12. Dalmatian toadflax (Linaria dalmatica),

13. Scotch thistle (Onopordum acanthium),

14. Musk thistle (Carduus nutans),

15. Common burdock (Arctium minus),

16. Plumeless thistle (Carduus acanthoides),

17. Dyers woad (Isatis tinctoria),

18. Houndstongue (Cynoglossum officinale),

19. Spotted knapweed (Centaurea maculosa),

20. Diffuse knapweed (Centaurea diffusa),

21. Purple loosestrife (Lythrum salicaria.),

22. Saltcedar (Tamarix spp.),

23. Common St. Johnswort (Hypericum perforatum),

24. Common tansy (Tanacetum vulgare), 

25. Russian olive (Elaeagnus angustifolia.), and

26. Black Henbane (Hyoscyamus niger).

The following three plant species are currently designated as noxious weeds by Campbell County 

in addition to those listed above.

1. Buffalobur (Solanum rostratum),

2. Common cocklebur (Iva xanthifolia), 

3. Poison hemlock (Conium maculatumand), and

4. Jointed goatgrass (Aegilops cylindrical).

The state listed noxious weed species that were found within the A2Tr1 tract include Canada 

thistle, Scotch thistle, dalmatian toadflax, musk thistle, salt cedar, skeletonleaf bursage, and field 

bindweed. These noxious weeds were not abundant. Selenium indicator species were not 

common on this amendment area in 2010.

Cheatgrass brome (Bromus inermis), an annual grass, is not designated as a noxious weed but is 

considered a noxious weed in some Wyoming counties. Total annual grasses comprised from 0.4 

to 3.0 percent of the total relative vegetative cover on the 2010 study areas. Cheatgrass was the 

major annual grass species encountered during the 2010 amendment area study.
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-40

3.9 Wildlife

The following discussions on wildlife resources are summarized from Appendix D9.2 (Wildlife) 

of the DFM WDEQ-LQD Permit No. PT0599 (WFW 2011). Sections 3.1, 3.2, and 3.8 provide 

detailed descriptions of the general setting, topography, and vegetative composition, respectively, 

of the general analysis area. 

There has been an extensive amount of wildlife data collected associated with the DFM. The 

primary baseline inventory on the mine area was conducted starting in 1981, but early work was 

conducted in 1974, 1975, and 1979. Studies were conducted to determine the species of 

mammals, birds, reptiles and amphibians occupying principal habitats on and adjacent to the study 

area, and to determine distributions and relative abundance of these species, where possible. 

Annual monitoring was initiated in 1989 and continues at present. The following information is 

derived from the baseline data and the subsequent studies and WDEQ-LQD Annual Reports that 

have been completed for the DFM. OSMRE determined that Appendix D9 of the DFM Permit 

adequately described the affected environment for big game, small mammals, lagomorphs, 

passerine bird species, upland game birds (excluding the Greater sage-grouse [GRSG] 

[Centrocercus urophasianus]), and reptiles and amphibians. Because no significant changes to wildlife 

use areas for these species have been noted from the discussion presented in Appendix D9, these 

species specific data are incorporated by reference into the affected environment portion of this 

EA in their entirety and not reiterated. There have been changes in discussions related to raptor 

nest locations; the status of GRSG; T&E species; and other species of special interest (SOSI, 

including federal Migratory Birds of Conservation Concern [MBCC] and WGFD Native Species 

Status). Therefore, these species discussions have been updated in this EA.

Because of the elevated level of concern in recent years for GRSG leks, a 3-mile radius was also 

analyzed for this EA. The 3-mile radius is the area in which two-thirds of the hens that were bred 

at those leks would be expected to nest.

3.9.1 Raptors

Eleven raptor species (northern harrier [Circus cyaneus], ferruginous hawk [Buteo swainsoni], 

Swainson's hawk [Buteo swainsoni] red-tailed hawk [Buteo jamaicensis], golden eagle [Aquila 

chrysaetos], bald eagle [Haliaeetus leucocephalus], prairie falcon [Falco mexicanus], American kestrel 

[Falco sparverius], great-horned owl [Bubo virginianus], short-eared owl [Asio flammeus], and 

burrowing owl [Athene cunicularia]) were recorded within the raptor monitoring area (map 3-8) 

during DFM baseline inventories. The ferruginous hawk, red-tailed hawk, Swainson's hawk, golden 

eagle, burrowing owl, and great horned owl are raptor species common to the region that are 

known to have nested within the DFM raptor monitoring area in the past. The 2015 annual report 

identified the location of and annual status of raptor nests for 2015 (WFW 2015b). The location 

and status of raptor nests as of 2015 are included on map 3-8. Two intact raptor nests (SH-4a 

and SH-4c/RTH-18) are located within the A2Tr1 tract. Nest SH-4a was last active in 2007, 

producing one young. SH-4c/RTH-18 was successful in 2015 when two red-tailed hawks fledged 

from the nest. Both nests are located in trees associated with a ranch facility and home site. BLM 

sensitive raptor species that could potentially occur in the area include the burrowing owl, 

ferruginous hawk, golden eagle, northern goshawk (Accipiter gentilis), Swainson’s hawk, and 

peregrine falcon (Falco peregrinus) (appendix E). None of these species has been documented 

as nesting within the tract (map 3-8).

3.9.2 Greater Sage-Grouse

Five historical GRSG leks have been documented within 3 miles of the A2Tr1 tract (map 3-8). 

Three leks (Dry Fork IIA, Schiemiester, and Eagle Butte) are intact and two leks (Dry Fork I and 

Dry Fork II) have been destroyed by mining. The WGFD currently classifies the Dry Fork IIA, 

Schiemiester leks as occupied and the Eagle Butte lek as unoccupied (WGFD 2016). The summary 
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-41

Map 3-8. Wildlife Use Associated with the A2Tr1 Tract
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-42

of sage-grouse strutting ground inventories shown in Table 3-20 indicates that bird numbers on 

all leks have fluctuated over the past 16 years. However, counts from 2000 through 2015 

indicated overall lek attendance numbers have significantly declined to zero. No sage-grouse were 

observed at the alternate Dry Fork II Lek site (Lek IIA Lek) in 2015. No sage-grouse were

observed at the Schiermiester Lek during the 2015 surveys either. Both the Dry Fork IIA Lek and 

the Schiermiester Lek have been exposed to increasing disturbances since 2002 that may have 

caused these birds to find more suitable areas to display.

On September 22, 2015, USFWS determined that listing the GRSG as an endangered or 

threatened species under the Endangered Species Act (Act) was not warranted (USFWS 2015). 

Recent documents regarding GRSG include the Approved Resource Management Plan (ARMP) 

and Final Environmental Impact Statement (FEIS) for the Buffalo Field Office Planning Area (Buffalo

ARMP/FEIS) (BLM 2015a), the Wyoming Greater Sage-Grouse Amendment (BLM 2015b), and 

the State of Wyoming, Office of the Governor, Executive Order 2015-4 (Office of the Governor 

2015). The documents include management procedures to consolidate GRSG protection within 

the State of Wyoming in light of the federal government’s recent decision not to list the GRSG 

under the ESA.

Executive Order 2015-4 regarding sage-grouse core area protection on state trust lands (Office 

of the Governor 2015). The sage-grouse core area protection concept came about because of 

work by the Sage-Grouse Implementation Team. The implementation team developed a core 

population strategy for the state “to maintain habitats and viable populations of sage-grouse in 

areas where they are most abundant.” As part of that effort, the team delineated approximately 

40 areas of state trust lands around Wyoming with a goal of maintenance and enhancement of 

grouse habitats and populations within the core areas. Using mapping included in the Executive 

Order, it has been determined that the closest core area is over 10 miles from the A2Tr1 tract.

3.9.3 Threatened, Endangered, and Candidate Species, and Special Status Species

3.9.3.1 Threatened, Endangered, and Candidate Species

The USFWS maintains a list of T&E species, and designated critical habitats on their official 

website for each county in Wyoming (USFWS 2016a). The USFWS also provides the Information 

for Planning and Conservation (IPaC) system in order to evaluate the potential of encountering 

USFWS trust resources, including T&E species, related to a specific project area. The agency 

updates those species lists annually, or more frequently if any listing changes occur. An official list 

of potential T&E species within the project area was requested on October 10, 2016 (USFWS 

2016b). The USFWS list of wildlife species includes the black-footed ferrets (Mustela nigripes), 

which is listed as experimental, non-essential, and the northern long-eared bat (Myotis 

septentrionalis), which is listed as threatened. The analysis area for most T&E species includes the 

DFM permit boundary. The analysis area for the northern long-eared bat includes the airshed 

analysis boundary for Hg deposition from mining and coal combustion. Additional information 

was gathered through incidental observations of species recorded during other field surveys. No 

critical habitat for these species was identified.

On March 6, 2013, the USFWS issued a letter acknowledging ‘block clearance’ for the State of 

Wyoming in response to a request from the Wyoming Game and Fish Department. 

Consequently, the USFWS no longer recommends surveys for the black-footed ferrets in either 

black- or white-tailed prairie dog towns in the State of Wyoming (USFWS 2016c). Prairie dog 

towns, which provide habitat for black-footed ferrets, are not found within the A2Tr1 tract. 
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-43

Table 3-20. Sage-grouse Strutting Ground Survey Results (Maximum Male 

Attendance) for the Dry Fork Mine

Schiermiester Lek Dry Fork II Lek Dry Fork IIA Lek Eagle Butte Lek

2000 12 20 * NM

2001 7 15 * 7

2002 6 15 * 6

2003 8 6 * NM

2004 2 2 * NM

2005 5 -- 6 0

2006 0 -- 6 NM

2007 0 -- 4 NM

2008 0 -- 0 0

2009 0 -- 2 NM

2010 0 -- 0 NM

2011 0 -- 1 NM

2012 0 -- 0 NM

2013 0 -- 0 0

2014 0 -- 0 NM

2015 0 -- 0 NM

NM - Not monitored

* - Lek not in existence

-- Lek destroyed by mining

Source: WFW 2015

While USFWS information indicates that the northern long-eared bat could occur in the area, 

habitat (caves and mine shafts as winter habitat and caves, mine shafts, and trees for summer 

habitat, USFWS [2016d]) is not present in the A2Tr1 tract to support the threatened northern 

long-eared bat.

3.9.3.2 Other Species of Special Interest

The A2Tr1 tract provides habitat for wildlife species that are classified as SOSI. Watch was kept 

during all surveys and site visits for species that are listed as SOSI. 

For the purposes of this discussion, other SOSI include federal birds of conservation concern and

Wyoming Natural Diversity Database (WYNDD) species of concern. The USFWS has identified 

birds of conservation concern as species, subspecies, and populations of migratory and nonmigratory birds that “...without additional conservation actions, are likely to become candidates 

for listing under the Endangered Species Act” (USFWS 2008). As defined by the USFWS, bird 

species considered for inclusion on lists of birds of conservation concern include nongame birds, 

gamebirds without hunting seasons, candidate and proposed endangered or threatened species, 

and recently delisted species (USFWS 2008). These species represent the USFWS’s highest 

conservation priorities beyond those species already designated as T&E species. The conservation 

concerns may be related to population declines, small range or population sizes due to natural 

or human-caused influences, threats to habitat, or other factors.

The most current list of MBCC is included in appendix E. The bald eagle is present on the study 

area as a migrant and winter resident as discussed previously. The Brewer’s sparrow is common 

during the spring and summer as a breeder. The ferruginous hawk nested on the DFM raptor 

study area in 2015. The golden eagle is a yearlong resident and was observed on the DFM raptor 

study area in 2015 but active nests were not found. The prairie falcon was observed as a transient 

however suitable nesting habitat is not present on the site for this species. The Swainson’s hawk 

was present as a spring and summer breeder and, as discussed above, nested within the A2Tr1 

tract in 2015. The grasshopper sparrow (Ammodramus savannarum), loggerhead shrike (Lanius 

ludovicianus), sage thrasher (Oreoscoptes montanus), short-eared owl, burrowing owl, GRSG, longbilled curlew (Numenius americanus), McCown’s longspur (Calcarius mccownii), and upland 

sandpiper (Bartramia longicauda) have been recorded on the DFM wildlife study area. The 
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-44

American bittern (Botaurus lentiginosus), black rosy-finch (Leucosticte atrata), dickcissel (Spiza 

americana), Lewis woodpecker (Melanerpes lewis), mountain plover (Charadrius montanus), pinyon 

jay (Gymnorhinus cyanocephalus), and Sprague’s pipit have not been recorded on the study area, as 

habitat for most of these species does not occur on the study area.

3.10 Land Use and Recreation

Campbell County completed a comprehensive countywide land use plan in 2013, which provides 

general goals and policies for land use in the county, including countywide coal and mineral 

extraction and its integral part of the overall plan for Campbell County (Campbell County 2013). 

The proposed modification area is within an area recognized by Campbell County as a mining 

land use.

The surface ownership within the DFM permit boundary includes 5,613.42 acres of private 

surface, 39.43 acres of federal surface, and 824.63 acres of state surface (map 3-9). The entire 

surface of the A2Tr1 tract is owned by Western Fuels-Wyoming, Inc. All of the coal reserves in 

the A2Tr1 tract are federally owned, whereas the remaining subsurface minerals (i.e., oil and gas 

reserves) are under a mixture of private and federal ownership (map 3-10). All oil and gas 

production infrastructure located in the tract is privately owned. Coal mining has been ongoing 

in the general analysis area since 1918 (Wyodak Mine). Mining has been the primary land uses in 

the general analysis area since the early 1980s. Secondary land uses include pastureland (ranching), 

dryland cropland, transportation, wildlife habitat, and CBNG development. Coal mining has been 

the dominant land use in the general analysis area since the mid-1980s.

3.11 Cultural Resources

Information regarding background cultural resources within the current DFM WDEQ-LQD 

PT0599 permit boundary was summarized from Appendices D-2.2 (Historic Cultural Resources 

Inventory, Amendment 2 Area) and D-3.2 (Prehistoric and Paleontological Resources Inventory, 

Amendment 2 Area) of the DFM WDEQ-LQD Permit No. PT0599 (WFW 2011). According to 

information provided in these appendices, six cultural resources sites (48CA1134, 48CA1300, 

48CA1302, 48CA1565, 48CA7048, and 48CA7049) were identified in the overall Amendment 2 

survey area, which includes the A2Tr1 tract. Only two of the six cultural resources sites 

(48CA7048, and 48CA7049) were identified within the A2Tr1 tract. Both sites are associated 

with historic activity (post-1920 era) and both sites are ineligible for listing on the National 

Register of Historic Places (NRHP) and do not require further investigation (OSMRE 2011). 

Letters of consultation were sent out to 30 Native American tribes/tribal representatives during 

the scoping process. OSMRE received responses from the Comanche Nation and the Cheyenne 

Arapaho. The Comanche Nation responded that “No Properties” were identified within the 

proposed project boundary. The Cheyenne Arapaho THPO requested more information 

regarding the project to which OSMRE responded by providing a project map and other project 

material. On May 23, 2017, OSMRE received a response from the Cheyenne Arapaho stating that 

“No Properties” were identified within the proposed project boundary.

3.12 Visual Resources

Visual sensitivity levels are determined by people’s concern for what they see and the frequency 

of travel through an area. Landscapes within and around the A2Tr1 tract are characterized by a 

gently rolling topography and large, open expanses of sagebrush and short-grass prairie, which 

are common throughout the PRB. There are also areas of altered landscape, such as oil and gas 

fields and surface coal mines. The existing active surface mines that are located on the eastern
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-45

Map 3-9. Surface Ownership within the A2Tr1 Tract
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-46

Map 3-10. Oil and Gas Wells and Oil and Gas Ownership within the A2Tr1 Tract
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-47

side of the PRB form three geographic groups that are separated by areas with no mining 

operations. The tract is located within a group of coal mines located on the east side of U.S. 

Highway 14/16 from Gillette going north for about 13 miles. Two other groups of surface mines 

are located east of State Highway 59 from south of Gillette to south of Wright, a distance of 

about 50 miles. Other man-made intrusions on the natural landscape in the area include oil and 

gas development (oil well pumpjacks, pipeline and utility right-of-way (ROW), water storage 

reservoirs, access roads, CBNG well shelters, and natural gas compressor stations), 

transportation facilities (public and private roads, road signage, power and utility transmission 

lines, and railroads), ranching activities (fences, ranch buildings, livestock, and abandoned 

homesteads), and environmental monitoring installations. The natural scenic quality in and near 

the A2Tr1 tract is fairly low because of the industrial nature of the adjacent existing mining 

operations and oil and gas field development.

State Highway 59 is adjacent to the DFM permit boundary and lies approximately 1.75 miles to 

the west of the A2Tr1 tract. Active mining (Eagle Butte and DFM) can be viewed from this 

roadway. The Garner Lake Road passes through the eastern portion of the A2Tr1 tract, and 

active mining at the DFM is visible from the road.

For management purposes, the BLM evaluated the visual resources on lands under its jurisdiction 

in the 2015 Buffalo Approved RMP. The inventoried lands were classified into visual resource 

management (VRM) classes used to describe increasing levels of change within the characteristic 

landscape (BLM 2015b). The objectives of the four VRM classes are:

1. Class I - To preserve the existing character of the landscape. The level of change 

to the characteristic landscape should be very low and must not attract attention. 

It is applied to wilderness and wilderness study areas, some natural areas, wild 

portions of Wild and Scenic Rivers, and other similar situations in which 

management activities are to be restricted.

2. Class II - To retain the existing character of the landscape. The level of change to 

the characteristic landscape should be low. Proposed alterations should be 

designed so as to retain the existing character of the landscape. Management 

activities may be seen, but should not attract the attention of the casual observer. 

Any changes must repeat the basic elements of form, line, color, and texture found 

in the predominant natural features of the characteristic landscape.

3. Class III - To partially retain the existing character of the landscape. Contrasts to 

the basic elements (form, line, color, and texture) caused by a management activity 

may be evident and begin to attract attention in the characteristic landscape; 

however, the changes should remain subordinate to the existing characteristic 

landscape. The level of change to the characteristic landscape should not exceed 

the moderate threshold.

4. Class IV - To provide for management activities that require major modification 

of the existing character of the landscape. Contrasts may attract attention and be 

a dominant feature of the landscape in terms of scale; however, changes should 

repeat the basic elements (form, line, color, and texture) inherent in the 

characteristic landscape. The level of change to the characteristic landscape can be 

high.
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-48

According to Map 3-24 of the 2015 Buffalo Approved RMP, the general analysis area is classified 

as VRM Class IV because of the industrial nature of the energy development and active farming 

and residential use in the area (BLM 2015a). The overall natural scenic quality of Class IV area is 

considered relatively low.

3.13 Noise

Existing noise sources in the A2Tr1 tract analysis area (DFM permit boundary) includes coal 

mining activities, rail traffic, traffic on nearby federal and state highways, county and access roads, 

natural gas compressor stations, and wind. Noise originating from CBNG development 

equipment (e.g., drilling rigs and construction vehicles) is apparent locally over the short term 

(i.e., 30 to 60 days) where well drilling and associated construction activities are occurring. The 

amount of noise overlap between well sites is variable and depends on the timing of drilling 

activities on adjacent sites and the distance between the site locations. Studies of background 

noise levels at PRB mines indicate that ambient sound levels generally are low, owing to the 

isolated nature of the area. Mining operations are conducted 24 hours a day, 7 days a week, which 

contributes to nearly continuous noise from the mine.

The unit of measure used to represent sound pressure levels (decibels) using the A-weighted 

scale is a dBA (A-weighted decibel). It is a measure designed to simulate human hearing by placing 

less emphasis on lower frequency noise because the human ear does not perceive sounds at low 

frequency in the same manner as sounds at higher frequencies. Figure 3-5 presents noise levels 

associated with some commonly heard sounds.

In 2004, Matheson Mining Consultants, Inc. conducted a noise survey at the two occupied 

locations closest to the existing Antelope Mine operations. The Antelope Mine is located about 

57 miles south of the A2Tr1 tract. Measurements were taken at a residence located directly west 

of the Antelope Mine on State Highway 59 and at the Dyno Nobel West Region office located 

northeast of the Antelope Mine on Campbell County Road 4 (Antelope Road). The maximum Leq

(equivalent noise level) noise readings at the residence and the Dyno Nobel office were 51 and 

52.6 dBA, respectively, which is equivalent to the noise level of light traffic (Kimley-Horn and 

Associates 2008).

No site-specific noise level data are available for the proposed lease modification tract, however, 

the physical setting and general land uses are similar at the Dry Fork and Antelope mines; 

therefore, the current median noise level is estimated to be similar at 40-60 dBA for day and 

night, with the noise level increasing with proximity to the currently active mining operations. 

Mining activities are characterized by noise levels of 85-95 dBA in the immediate vicinity of mining 

operations and activities (BLM 1992). The nearest residence is approximately 1,900 feet from the 

proposed A2Tr1 tract.

3.14 Transportation Facilities

Potential impacts to transportation facilities within the analysis area (DFM permit boundary) 

would include impacts to State Highway 59 and Garner Lake Road (County Road 38N), several 

unimproved local roads and accesses (unnamed two-track trails), mine rail spurs used by the 

BNSF Railroad, oil and gas pipelines, utility/power lines, telephone lines, and associated ROW. 

State Highway 59 and the Garner Lake Road are the major north-south public transportation 

corridors in this area (map 1-2). State Highway 59 is located directly adjacent to the west side 

of the DFM permit boundary. The Garner Lake Road passes through the eastern portion of the 

A2Tr1 tract. Both roadways are paved two-lane roads. The DFM facilities are accessed from 

Garner Lake Road.
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-49

Noise Source

(at Given Distance) Noise Environment A-WeightedSound Level

Human Judgment

of Noise Loudness

(Relative to Reference 

Loudness of 70 

decibels*)

Military jet Takeoff

With Afterburner (50 ft) Carrier Flight Deck 140 Decibels 128 times as loud

Civil Defense Siren (100 ft) 130 64 time as loud

Commercial Jet Take-off

(200 ft) 120 32 times as loudThreshold of Pain

Pile Driver (50 ft)

Rock Music Concert

Inside Subway Station (New 

York)

110 16 times as loud

Ambulance Siren (100 ft)

Newspaper Press (5 ft)

Gas Lawn Mower (3 ft)

100 8 times as loud

Very Loud

Food Blender (3 ft)

Propeller Plane Flyover

(1,000 ft)

Diesel Truck (150 ft)

Boiler Room

Printing Press Plant 90 4 time as loud

Garbage Disposal (3 ft) Higher Limit of Urban 

Ambient Sound 80 2 times as loud

Passenger Car, 65 mph (25 ft)

Living Room Stereo (15 ft)

Vacuum Cleaner (10 ft)

70 Reference Loudness

Moderately Loud

Normal Conversation (5 ft)

Air Conditioning Unit (100 ft)

Data Processing Center

Department Store 60 1/2 as loud

Light Traffic (100 ft) Large Business Office

Quiet Urban Daytime 50 1/4 as loud

Bird Calls (distant) Quiet Urban Nighttime 40 1/8 as loud

Quiet

Soft Whisper (5 ft)

Library and Bedroom at 

Night

Quiet Rural Nighttime

30 1/16 as loud

Broadcast and Recording 

Studio 20 1/32 as loudJust Audible

10 1/64 as loud

0

1/128 as loud

Threshold of Hearing

Source: Kimley-Horn and Associates 2008

Figure 3-5. Relationship Between A-Scale Decibel Readings and Sounds of 

Daily Life
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-50

As discussed in section 1.2.1, coal is conveyed from the DFM to the DFS via a 0.86-mile overland 

conveyor system (map 3-11). The mine is the sole-source of coal for the DFS, providing 

approximately 2.0 Mt of coal per year to the power plant. This conveyor does not cross any 

public roads.

The nearest railroad facilities are rail spurs that provide access to the Dry Fork, Buckskin, 

Rawhide, and Eagle Butte mines (map 1-2). The rail spurs are connected to a BNSF rail line 

which runs south and connects to the east-west BNSF rail which runs through Gillette. The 

closest railroad is the Synthetic Fuels Mine rail spur, which is adjacent to the A2Tr1 tract. Coal 

mined from the tract would be processed and shipped from the existing DFM facilities.

Coal extracted from the existing surface coal mines in the Wyoming PRB is transported in rail 

cars along the BNSF and Union Pacific (UP) rail lines. The coal mines north of Gillette, including 

the DFM, ship most of their coal via the east-west BNSF rail line that runs through Gillette for 

destinations in the Midwest. The coal mines south of Gillette ship most of their coal via the

Gillette to Douglas BNSF and UP joint trackage that runs south through Campbell and Converse 

Counties and then east over separate BNSF and UP mainlines for destinations in the Midwest.

Power lines, utility corridors, and oil and gas pipelines are present within and adjacent to the 

A2Tr1 tract. An overhead power line runs through the tract; this power line serves an abandoned 

residence and an oil pad facility. Several abandoned pipelines and one active pipeline run within 

the A2Tr1 tract (map 3-11). 

3.15 Hazardous and Solid Wastes

Potential sources of hazardous or solid waste within the analysis area (DFM permit boundary)

would include spilled, leaked or dumped hazardous substances, petroleum products, and/or solid 

waste associated with coal and oil and gas exploration, oil and gas development, the BNSF 

railroad, utility line installation and maintenance, or agricultural activities. No such hazardous or 

solid wastes are known to be present on any of the hazardous or solid waste analysis area. Wastes 

produced by current mining activities at the DFM are handled according to the Waste Disposal 

Program described in DFM WDEQ-LQD Permit No. PT0599. The program is summarized below.

DFM does not have an on-site solid waste landfill. Most waste generated at the mine is disposed 

of offsite at the Campbell County Municipal Landfill. General mining wastes are disposed in the 

municipal landfill only if generated on site, and only if non-hazardous per regulation under the

Resource Conservation and Recovery Act (RCRA). The mine is permitted to occasionally 

construct disposal areas for inert non-toxic wastes such as scrap wood, scrap metal, tires, and 

broken concrete. Typically, these wastes are too large for dumpsters or generated in areas away 

from dumpsters. Examples may include wood pallets and paper. The mine rarely operates an onsite solid waste pit.

No hazardous wastes are transported to the municipal landfill or any on-site solid waste pits. 

While some of the following items are permitted for onsite disposal, scrap metal, tires, batteries, 

used filters, computers, and most wood pallets are recycled. Used filters are drained, crushed 

and recycled. Fifty-five-gallon drums and totes are properly emptied, cleaned and are then are 

recycled. Spent lead acid batteries and fluorescent lamps are stored in designated areas with 

secondary containment for periodic shipment to an approved recycling vendor.

As stated in section 2.3, the mine is permitted to take the CCB wastes from the DFS (map 2-

2). CCBs are utility wastes generated during the burning of coal and include fly ash, bottom ash,

and scrubber sludge. The CCB is permitted according to the requirements of Chapter 3 –

Industrial Landfill Regulation of the WDEQ Solid Waste Rules and Regulations (Wyoming 

Administrative Rules 2017). An estimated 100,000 tons annually are placed at the DFM in an area 

located within the DFM permit boundary, but outside of the A2Tr1 tract. CCB waste is in dry
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-51

Map 3-11. Transportation Facilities Associated with the A2Tr1 Tract
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-52

form (not a slurry), and is hauled via belly or side dump trucks from the DFS to the active disposal 

cell. CCB waste is laid in the cells in lifts, watered for dust control, and compacted with the water 

to harden the ash to a concrete form. Runoff from cells drains to a lined pond where it is stored 

for use for dust control in the ash landfill. CCBs from DFS are in the process of being tested for 

use in cement products, wallboard, or as road base.

Used oil is collected from equipment, the shop oil/water separator and other sources in an above 

ground tank with secondary containment. It is disposed, recycled, burned for energy recovery, 

or otherwise handled in accordance with RCRA. Ethylene glycol (antifreeze) is stored in bulk 

within the lube room in the maintenance shop, distributed via a service truck throughout the 

mine and via pipes to the shop. Used glycol is also collected for onsite recycling and reuse. In the 

unlikely event of coolant spills, the spill will be contained and prevented from mixing with flowing 

water.

DFM’s WDEQ-LQD Permit PT0599 allows the mine to operate an onsite landfarm for treatment 

of oil or glycol contaminated soils. In accordance with the permit, contaminated soils are placed 

in 6 inch lifts and are periodically disced or rotated to assist with breakdown of the oil products.

3.16 Socioeconomics

This section describes existing socioeconomic conditions in Wyoming and Campbell County

specific to the local and state economy, population, employment, and environmental justice.

3.16.1 Local Economy

Wyoming’s coal mines produced an estimate 372.6 million tons in 2015, a decrease of about 93.7 

million tons (20%) over the record 466.3 million tons produced in 2008. Coal produced from 14 

active mines in Campbell County, which makes up approximately 5 percent of the surface area 

of Wyoming, accounted for approximately 97% of total statewide coal production in 2015 

(Wyoming Department of Workforce Services [WDWS] 2015). According to coal production 

numbers from the USEIA, the coal from Campbell County accounted for approximately 45 

percent of the coal produced in the U.S. in 2015 (USEIA 2016a).

The estimated total fiscal benefit from coal production in Campbell County to the State of 

Wyoming in 2016 was calculated by including half of the bonus bid payments, half of the federal 

mineral royalties based on current prices, a designated portion the AML fees, and all of the ad 

valorem taxes, severance taxes, and sales and use taxes for coal produced in Campbell County 

in 2015. The sale of coal from Campbell County in 2015 resulted in an estimated $1,633.7 million, 

or $2.54 per ton (figure 3-6).

3.16.2 Environmental Justice

Economic and demographic data indicate that neither minority populations nor people living at 

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

Gillette or Campbell County than they do in the state as a whole, or that they would be unequally 

impacted if the DFM federal mining plan modification request is approved. Also, the Native 

American population is smaller than in the state as a whole and there are no known Native 

American sacred sites on or near the A2Tr1 tract. Consequently, no environmental justice 

populations or concerns are present in Campbell County.

Recent (2015) Gross Domestic Product (GDP) calculations for Wyoming indicate that the 

minerals industry (mining and oil and gas) accounted for about 23 percent of the state’s total 

GDP of $38.6 billion, which made it the largest sector of the Wyoming economy. The 

contribution of mining was nearly three times that of government, the next largest sector, and 
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-53

Figure 3-6. Estimated 2016 Wyoming and Federal Revenues from 2015 Coal 

Production in Campbell County
Chapter 3 – Affected Environment

Dry Fork Mine A2Tr1 EA 3-54

nearly three times more than the contribution of the real estate industry, the next largest private 

sector. In 2014, mining alone accounted for 11 percent of the Wyoming GDP (WDAI-EAD 2016).

Wyoming’s economy was exposed to a substantial decline in the price of oil in 2015, an extended 

period of low natural gas prices, and the decline in the price of coal (WDWS 2016). This trend 

continued into 2016. As well as direct effects to oil and gas and mining employment, the effects 

of the reduced demand for these natural resources also effects the required support industries 

for the mining and quarrying of minerals and for the extraction of oil and gas.

3.16.3 Population

According to U.S. census data, in 2015 Campbell County had a population of 49,220 (U.S. Census 

Bureau 2016a). The 2011 population of Campbell County was 46,600. Campbell County’s

population ranks it as the third most populous of Wyoming’s 23 counties (U.S. Census Bureau 

2016).

The majority of the Campbell County mine employees and support services reside in Gillette. It 

is estimated that the total population in the Gillette city limits increased from 19,646 in 2000 to 

32,649 in July 2015, an increase of 66.2 percent over the period (U.S. Census Bureau 2017). 

Table 3-21 presents the population changes for Campbell County and Gillette. As of July 2015, 

Gillette accounted for roughly 66.3 percent of the county’s residents (WDAI-EAD 2016a and 

2016b). Gillette was the third largest city in the state, following Cheyenne and Casper (U.S. 

Census Bureau 2017).

Table 3-21. Campbell County and City of Gillette Population Change, 2000 to 

2015

2000 2011 2012 2013 2014 2015 2000-2015 

Increase

2000-2015 

% Change

Campbell County 33,698 46,600 47,881 48,121 48,243 49,220 14,478 43.0

City of Gillette 19,646 30,432 31,423 31,732 31,920 32,649 13,003 66.2

Source: U.S. Census Bureau (2016 and 2017)

3.16.4 Employment

Table 3-22 presents the employment changes for Wyoming and Campbell County. The 

statewide total employment increased by 4,243 jobs (1.5 percent) from 2011 to 2015 while the 

employment in Campbell County increased by 338 (1.4 percent) during the same time period 

(Bureau of Labor 2016). The average unemployment rate in Campbell County for 2011 was 4.9 

percent and 3.8 percent for 2015 (Bureau of Labor 2016). Between the second quarter of 2014 

and the second quarter of 2016, the mining sector is projected to lose approximately 1,644 jobs 

(WDWS 2015). The Natural Resources and Mining sector in Campbell County experienced an 

approximate 14.7 percent decline in employment between June 2015 and June 2016 (WDWS 

2016).

Table 3-22. Wyoming and Campbell County Employment Rate Change, 2000 to 

2015

2000 2011 2012 2013 2014 2015 August 

2016

Wyoming (Number Employed) 256,414 289,019 291,076 292,157 294,207 293,262 287,084

Wyoming (Number Unemployed) 10,394 17,796 16,349 14,414 12,726 12,750 14,686

Wyoming Unemployment Rate 3.9 5.8 5.3 4.7 4.1 4.2 5.5

Campbell County (Number Employed) 17,975 24,605 24,919 24,609 25,423 24,943 23,446

Campbell County (Number Unemployed) 830 1,267 1,213 1,087 882 987 1,708

Campbell County Unemployment Rate 3.4 4.9 4.6 4.2 3.4 3.8 6.8

Source: Bureau of Labor & Statistics 2016
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-1

4.0 Environmental Consequences/Cumulative Effects

4.1 Introduction

This chapter discusses the potential direct, indirect, and cumulative effects of the Proposed 

Action and the No Action Alternative, as described in chapter 2. The discussion is organized by 

the affected resource in the same order as they are described in chapter 3 and then by 

alternative. The environmental consequences have been assessed assuming an estimated 6 Mtpy 

production rate, which was provided by WFW based on current contract and anticipated demand 

(WFW 2016a). The estimated annual production is in line with recent annual production (see 

table 3-14). 

An impact, or effect, is defined as a modification to the environment brought about by an outside 

action. Impacts vary in significance from no change, or only slightly discernible change, to a full 

modification or elimination of the resource. Impacts can be beneficial (positive) or adverse 

(negative). Impacts are described by their level of significance (i.e., significant, moderate, minor, 

negligible, or no impact). For purposes of discussion and to enable use of a common scale for all 

resources, resource specialists considered the following impact levels in qualitative terms.

Significant 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 that potentially could cause an 

insignificant change or stress to an environmental resource or use.

No Impact: No discernible or measurable impacts.

Direct impacts are defined as those impacts which are caused by the action and occur at the 

same time and place (40 CFR 1508.8[a]). Indirect impacts are those that are caused by the action 

and occur later in time or are farther removed in distance, but are still reasonably foreseeable 

(40 CFR 1508.8[b]). Cumulative impacts are those impacts that result from incremental effects 

of an action when added to other past, present, and reasonably foreseeable future actions 

regardless of what agency or other entity undertakes such other actions. Cumulative impacts 

occur over a given time period. The time period for cumulative effects includes the time period 

when the impacts of past and present actions and reasonably foreseeable future actions overlap 

with the time period when project impacts would occur (including construction, operation, and 

reclamation phases).

Impacts can be short term meaning these impacts generally occur over a short period during a 

specific point in the mining process and these changes generally revert to pre-disturbance 

conditions at or within a few years after the ground disturbance has taken place. Long-term 

impacts are defined as those that substantially would remain beyond short-term grounddisturbing activities. Long-term impacts would generally last the life of the federal mining plan 

modification approval and beyond.

The direct, indirect, and cumulative effects of the Proposed Action and No Action Alternative 

are described below. In addition to addressing the specific issues identified in chapter 1, this 
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-2

environmental consequences analyses reflect changes to the mining operations presented in 

chapter 2 and updated descriptions of the affected environment presented in chapter 3.

Regarding other relevant regional activity, WFW submitted Amendment 2 PAP for WDEQ-LQD 

Permit No. PT0599 to WDEQ-LQD on January 12, 2012 to revise the permit boundary. 

WDEQ-LQD approved the Amendment 2 application on August 19, 2013 with the condition that 

the DFM may not mine coal from any federal coal lease prior to receiving approval from the 

ASLM. The Dry Fork, Rawhide, Buckskin, Eagle Butte, Synthetic Fuels, and Wyodak mines

(northern group of mines) are adjacent to or in the immediate vicinity of the A2Tr1 tract (Map 

1-1). Information regarding ownership, permitted acres, and 2015 coal production from these 

mines in included in table 4-1.

Table 4-1. Ownership, Permitted Acres, and Production of Mines Adjacent to the 

DFM

Mine Ownership Permitted 

Acres

2015 

Production (Mt)

Rawhide Peabody Caballo Coal, LLC 9,171 15.2

Buckskin Buckskin Mining Company 9,020 13.6

Eagle Butte Contura Coal West, LLC 10,261 19.6

Synthetic Fuels Green Bridge Holdings Inc. 2,370 0.0

Wyodak Wyodak Resources Development Corporation 6,038 4.1

Total 36,860 52.5

Four power plants are located adjacent to or in the vicinity of the A2Tr1 tract (map 3-2). 

Information regarding ownership and power output of the power plants is included in

table 4-2.

Table 4-2. Ownership and Power Output of Power Plants Adjacent to the DFM

Mine Ownership Power Output 

(MW)

Dry Fork Station Basin Electric Power Cooperative 422

Wyodak Power Plant PacifiCorp 402

Neil Simpson Complex Black Hills Corporation 80

Wygen Station Black Hills Corporation 294

The environmental and cumulative effects discussions below assume that under the Proposed 

Action, the federal mining plan modification to mine coal in the federal coal leases within the 

A2Tr1 tract, would be approved. Coal recovery would continue within the DFM permit boundary 

at an estimated annual rate of 6 Mt, in accordance with WDEQ-LQD approved mine permit. The 

recovery of the federal coal would continue for approximately 5.3 additional years over the No 

Action Alternative. 

Under the No Action Alternative, the mining plan modification to recover the federal coal within 

the A2Tr1 tract would not be approved. Currently approved mining operations associated with 

existing coal leases would continue for approximately 31.7 years within state coal lease 0-26652; 

federal coal leases WYW-5035, WYW-0271199, WYW-0271200, WYW-0271201, and 

WYW-0311810, and the Marshall et al. private coal lease.

4.1.1 Summary Comparison of Direct and Indirect Environmental Impacts

A summary comparison of the direct and indirect environmental impacts is included in

table 4-3.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-3

Table 4-3. Summary Comparison of Direct and Indirect Environmental Impacts as Compared to the Existing DFM 

Federal Mining Plan

Resource Name Proposed Action No Action Alternative

Added In-Place Coal (Mt) 32.0 0.0

Added disturbance 151.0 Acres 0.0 

(155.4 acres with the A2Tr1 tract currently 

approved for disturbance to recover coal on 

adjacent leases)

Topography and Physiography Moderate, permanent on the tract. Local impacts only. Moderate, permanent on the tract due to coal 

recovery activity on adjacent lands authorized under 

a revised state mine permit and revised federal 

mining plan. Local impacts only.

Geology, Minerals and Paleontology Moderate, permanent on the tract. Recovery of 32 Mt

of Wyodak-Anderson coal and CBNG within WyodakAnderson coal. While CBNG is not part of the 

Proposed Action, there would be a loss of CBNG 

through venting and/or depletion of hydrostatic 

pressure in Wyodak-Anderson coal resulting from 

mining adjacent areas. However, CBNG recovery has 

been greatly reduced in the area. Local impacts only.

Moderate, permanent on the tract due to coal 

recovery activity on adjacent lands authorized under 

a revised state mine permit and revised federal 

mining plan. Approximately 32 Mt of coal would not 

be removed on the tract but loss of CBNG would 

occur though venting and/or depletion of 

hydrostatic pressure in Wyodak-Anderson coal 

resulting from mining adjacent areas. Local impacts 

only.

Air Quality Minor to negligible, short term (5.3 years) from full 

mining on the tract. Primarily local impacts, with the 

potential for regional and global impacts from 

transportation and combustion of coal.

Minor to negligible, short term on the tract due to 

coal recovery activity on adjacent lands authorized 

under a revised state mine permit and revised 

federal mining plan. Primarily local impacts, with the 

potential for regional and global impacts from 

transportation and combustion of coal.

Water Resources-Groundwater Moderate, short and long term on the tract due to 

aquifer (alluvial, overburden, and coal) removal. Local 

impacts only.

Moderate, short and long term on the tract due to 

coal recovery activity on adjacent lands authorized 

under a revised state mine permit and revised 

federal mining plan. Local impacts only.
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Dry Fork Mine A2Tr1 EA 4-4

Table 4-3. Summary Comparison of Direct and Indirect Environmental Impacts as Compared to the Existing DFM 

Federal Mining Plan (Continued)

Resource Name Proposed Action No Action Alternative

Water Resources – Surface Water Moderate, short term (5.3 years) on the tract from full 

mining. Primarily local impacts, with the potential for 

regional impacts from combustion of coal.

Moderate, short term on the tract due to coal 

recovery activity on adjacent lands authorized under 

a revised state mine permit and revised federal 

mining plan. Primarily local impacts, with the 

potential for regional impacts from combustion of 

coal.

Alluvial Valley Floors No impact – Not present Same as Proposed Action

Wetlands No impact -Not present Same as Proposed Action

Soils Moderate, short term (5.3 years) on the tract from full 

mining. Local impacts only.

Moderate, short term on the tract due to 

mine-related activity authorized under a revised 

state mine permit and revised federal mining plan. 

Local impacts only.

Vegetation Moderate, short term (5.3 years) on the tract from full 

mining. Local impacts only.

Moderate, short term on the tract due to coal 

recovery activity on adjacent lands authorized under 

a revised state mine permit and revised federal 

mining plan. Local impacts only.

Wildlife Moderate, short term (5.3 years) on the tract from full 

mining. Local impacts only for most species. Hg 

emissions would be extended by 5.3 years, which may

affect northern long-eared bats.

Moderate, short term on the tract due to coal 

recovery activity on adjacent lands authorized under 

a revised state mine permit and revised federal 

mining plan. Local impacts only.

Ownership and Use of Land Moderate, short term (5.3 years) on the tract from full 

mining. Local impacts only.

Moderate, short term on the tract due to mine 

related activity authorized under a revised state 

mine permit and federal mining plan. 
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Dry Fork Mine A2Tr1 EA 4-5

Table 4-3. Summary Comparison of Direct and Indirect Environmental Impacts as Compared to the Existing DFM 

Federal Mining Plan (Continued)

Resource Name Proposed Action No Action Alternative

Cultural Resources Negligible, long term on the tract from full mining. No

NRHP eligible cultural resources sites would be 

disturbed. Local impacts only.

Negligible, long term on the tract due to coal 

recovery activity on adjacent lands authorized under 

a revised state mine permit and revised federal 

mining plan. Local impacts only.

Visual Resources Moderate, short term (5.3 years) on the tract from full 

mining. Local impacts only.

Moderate, short term on the tract due to coal 

recovery activity on adjacent lands authorized under 

a revised state mine permit and revised federal 

mining plan. Local impacts only.

Noise Minor to moderate, short term (5.3 years) on the 

tract from full mining. The impacts would moderate 

rapidly due to the reduction effect related to distance.

Minor to moderate, short term on the tract due to 

coal recovery activity on adjacent lands authorized 

under a revised state mine permit and revised 

federal mining plan. Local impacts only.

Transportation facilities No impact Same as Proposed Action

Hazardous and Solid Waste Negligible Same as Proposed Action

Socioeconomics Moderate, short term (5.3 years) on the tract from full 

mining. LOM State and Federal revenues from tract 

coal would be $124 million. Local and regional impacts.

Moderate socioeconomic effects short term on the 

tract due the loss of $124 million in federal and 

state revenues, compared to Proposed Action. Local 

and regional impacts.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-6

4.2 Topography and Physiography

4.2.1 Direct and Indirect Effects 

4.2.1.1 Proposed Action

The Proposed Action would impact the topography and physiography of lands included in the 

A2Tr1 tract but these impacts would be similar to those currently occurring on the existing DFM

coal leases as coal is mined and the mined-out areas are reclaimed. The direct effects on 

topography and physiography resulting from the Proposed Action are expected to be moderate 

and permanent on the tract. Typically, a direct permanent impact of coal mining and reclamation 

is topographic moderation. After reclamation, the restored land surfaces are generally gentler, 

with more uniform slopes and restored basic drainage networks. Portions of the original 

topography of the tract are somewhat rugged. As a result, the expected post-mining topography 

would be more subdued, but would blend with the undisturbed surroundings. Following 

reclamation, the average post-mining topography would be slightly lower in elevation than the premining topography due to removal of the coal. The removal of the coal would be partially offset 

by the swelling that occurs when the overburden and interburden are blasted, excavated, and 

backfilled. There would be no indirect effects under the Proposed Action. As discussed in section 

1.2, WDEQ-LQD, through the PAP process, considered and approved the impacts of mining coal 

related to within the A2Tr1 tract, including effects to topography and physiography and reclaiming 

the area to approximate original contour as required by provisions included in WDEQ-LQD 

Permit No. PT0599. Table 2-1 provides comparisons between the acres of disturbance versus 

the acres of reclamation, by bond release phase, as of September 2016. The DFM is bound by 

reclamation responsibilities included in WDEQ-LQD Permit No. PT0599 and the BLM-approved 

R2P2.

4.2.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing

federal mining plan to recover the coal included in the A2Tr1 tract. The impacts to topography 

under the No Action Alternative would be similar to those under the Proposed Action although 

the impacts to approximately 151 acres to recover federal coal within the tract would not occur.

4.2.2 Cumulative Effects

The cumulative impacts to topography and physiography would not be substantially different than 

those described in the existing DFM federal mining plan. According to the 2013 CHIA, 

approximately 31,606 acres of land have been approved for disturbance within the northern group 

of mines (WDEQ-LQD/Lidstone 2013). The cumulative effects would primarily be related to the

northern group of mines. Following surface coal mining and reclamation, topography would be 

modified within the permit boundary of the DFM. The cumulative effects on topography and 

physiography resulting from the Proposed Action are expected to be moderate and permanent 

on the tract.

4.2.3 Mitigation Measures

No mitigation measures would be necessary for topography.
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Dry Fork Mine A2Tr1 EA 4-7

4.3 Geology, Mineral Resources, and Paleontology

4.3.1 Direct and Indirect Effects

4.3.1.1 Proposed Action

The direct and indirect effects to geology, mineral resources, and paleontology would not be 

substantially different than those described in the existing DFM federal mining plan. The geology 

from the base of the Wyodak-Anderson coal seam to the land surface would be subject to 

permanent change on the areas of coal removal and mining would substantially alter the resulting 

subsurface physical characteristics of these lands. These impacts are occurring on the existing DFM

coal leases as coal is mined and the mined-out areas are reclaimed. The Proposed Action would 

result in the recovery of approximately 32 Mt of federal coal within the Wyodak-Anderson coal 

seam. The Proposed Action would also result in the loss of CBNG though venting and/or depletion 

of hydrostatic pressure in Wyodak-Anderson coal resulting from mining adjacent areas. 

As described in section 3.3.2, as of October 14, 2016, 341 CBNG wells had been completed 

within the general analysis area (WOGCC 2016), with six CBNG wells completed within the tract. 

Three of those wells are currently producing gas. CBNG would be recovered from the 

Wyodak-Anderson coal seam within the A2Tr1 tract until mining approaches near enough to the 

wells to result in loss through venting and/or depletion of hydrostatic pressure. CBNG reserves 

not recovered from the Wyodak-Anderson coal seam prior to mining would be vented to the 

atmosphere. There are existing facilities and equipment associated with CBNG production and 

development within the tract.

A locality search for paleontological resources (conducted through geological references and 

paleontological records) that included the A2Tr1 tract showed that no known vertebrate fossil 

localities are recorded from within either the original mine permit area or the A2Tr1 tract. 

However, site specific paleontological ground surveys have not been conducted and the tract lies 

on the Paleocene-Eocene Wasatch Formation, which is known to yield significant paleontological 

resources in nearby areas. If vertebrate fossils do exist, they would be scientifically significant and 

could be negatively impacted by mining operations. Potential impacts to vertebrate fossils during 

construction could be both direct and indirect. Ground disturbance of significant fossil beds could 

result in direct damage to or destruction of fossils. Indirect effects during construction include 

erosion of fossil beds due to slope re-grading and vegetation clearing, and unauthorized collection 

of significant fossils by construction workers or the public due to increased public access to fossil 

localities. Lease and permit conditions require that should previously unknown, potentially 

significant paleontological sites be discovered, work in that area must stop and measures must be 

taken to assess and protect the site.

The direct and indirect effects on mineral resources and paleontology are expected to be 

moderate and permanent on the tract.

4.3.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. Impacts to the geological 

resources have resulted from current mining activity and therefore under this alternative, 

geological resources in the area would be similar to those under the Proposed Action although 

the impacts to the geological and paleontological resources on approximately 151 acres to recover 
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-8

federal coal within the tract would not occur. Impacts to CBNG resources may still occur as a 

result of mining activities in adjacent lands.

4.3.2 Cumulative Effects

The cumulative effects on geology, mineral resources, and paleontology would primarily be related 

to the northern group of mines. The PRB coalfield encompasses an area of about 12,000 square 

miles. As presented in table 4-1, the combined area of the permit boundaries of the northern 

group of Campbell County mines totals approximately 36,860 acres (57.6 mi2), or approximately 

0.5 percent of the PRB coalfield (WDEQ-LQD 2016). The U.S. Geological Survey (USGS) 

estimates that there are approximately 162 billion tons of recoverable coal in the PRB, of which, 

an estimated 25 billion tons are considered economically recoverable coal, with a maximum 

stripping ratio of 10:1 (USGS 2013). Information in table 4-1 shows that annual coal recovery at

the six mines identified as the northern group of mines accounts for 52.5 Mt of coal, or 0.2 percent 

of the recoverable coal within the PRB.

According to October 17, 2016 information from the WOGCC website, 21,360 CBNG wells have 

been drilled in Campbell County. The WOGCC records indicate that a majority of the wells are 

privately held or state minerals, with approximately 36.7 percent of the wells (7,846 of 21,360) 

being federal minerals. Status of these wells includes shut-in, producing, plugged and abandoned, 

and injection. Currently, 139 of the 341 CBNG wells completed in the analysis area are considered 

to be in production. The pace of CBNG development in Wyoming has recently slowed 

considerably (WOGCC 2016). 

Impacts to paleontological resources as a result of the currently authorized and reasonably 

foreseeable cumulative energy development occurring in the PRB consist of losses of plant, 

invertebrate, and vertebrate fossil material for scientific research, public education (interpretive 

programs), and other values. Losses have and would result from the destruction, disturbance, or 

removal of fossil materials as a result of surface-disturbing activities, as well as unauthorized 

collection and vandalism. A beneficial impact of surface mining can be the exposure of fossil 

materials for scientific examination and collection, which might never occur except as a result of 

overburden removal, exposure of rock strata, and mineral excavation.

4.3.3 Mitigation Measures

No mitigation measures would be necessary for geology or mineral resources. Should significant 

paleontological resources be encountered as a result of the Proposed Action, the appropriate 

agencies would be consulted.

4.4 Air Quality

4.4.1 Particulate Matter

4.4.1.1 Direct and Indirect Effects 

4.4.1.1.1 Proposed Action

Based on values included in table 3-5, between 2011 and 2015, the average annual mean PM10

values ranged between 5.6 and 14.7 μg/m3. These concentrations ranged from about 11 to 29 

percent of the annual standard of WAAQS annual standard of 50 μg/m3. During the same time 

period, the 24-hour high PM10 values ranged between 15 and 61 μg/m3. Thus, these maximum 

concentrations have ranged from approximately 10 to 40 percent of NAAQS and WAAQS 24-
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-9

hour standard of 150 μg/m3. PM2.5 monitoring at the DFM is not required by WDEQ. Actual PM2.5

values presented in table 3-5 from four monitoring locations in Campbell County (map 3-3) 

reveal that between 2011 and 2015, PM2.5 concentrations ranged between approximately 29 and 

63 percent of the 24-hour NAAQS of 35 μg/m3. During the same time period, PM2.5 concentrations 

ranged between approximately 18 and 66 percent of the annual NAAQS of 12 μg/m3. The 

estimated PM2.5 values for the DFM presented in tables 3-7 and 3-8 also show that estimated 

2011 through 2015 PM2.5 concentrations were well below the prescribed NAAQS.

WFW projects that the annual coal production is expected to average 6 Mt with mining the 

remaining federal coal within the A2Tr1 tract (WFW 2016a). DFM’s currently approved air quality 

permit (MD-11723) from WDEQ limits annual coal production to 15 Mt of coal. According to 

WFW, production would continue at an average rate of 6 Mtpy for approximately 5.3 additional 

years under the Proposed Action. Public exposure to particulate emissions from surface mining 

operations is most likely to occur along publicly accessible roads and highways that pass through 

the area of the mining operations. Occupants of residences in the area could also be affected. As 

indicated on map 3-1, the closest occupied residence is located approximately 1,900 feet from 

A2Tr1 disturbance and the closest public transportation route is the Garner Lake Road (County 

Road 38N), which is immediately adjacent to disturbance associated with the A2Tr1 tract. The 

nearest recreational opportunities are within the Gillette city limits, approximately 15,000 feet 

from the A2Tr1 tract.

WDEQ-AQD issued air quality permit MD-11723 for the DFM on September 20, 2011. This air 

quality permit was issued based on an analysis using emission factors, estimation methods, and 

model selection consistent with WDEQ-AQD policy. The emission inventory was prepared based 

on site-specific operations projections associated with the 15 Mtpy mine plan.

PM10 inventories for the mining activities at DFM were prepared for all years in the currently 

anticipated LOM. Two years were then selected for worst-case dispersion modeling of PM10 based 

on mine plan parameters and emission inventories. Fugitive emission sources and point sources 

were modeled using the Industrial Source Complex Long Term 3 (ISCLT3) model. The modeling 

follows the methods presented in a dispersion modeling protocol for the project originally 

submitted to WDEQ-AQD in February 2011 (Carter Lake Consulting 2011). Based on comments 

received from WDEQ-AQD, the package was resubmitted in April, 2011. 

Modeling indicates the currently projected mine activities would be in compliance with the 24-

hour and annual PM10 ambient air standard for the life of the DFM. Based on mine plan parameters 

and highest emissions inventories, the years 2015 and 2019 were selected as the worst-case years 

for PM10 evaluation, because those years had the highest modeled PM10 concentrations. Coal 

production in both years was modeled at the maximum permitted production level of 15 Mt

(Carter Lake Consulting 2011). The results of 24-hour and annual dispersion modeling are included 

in table 4-4. The locations of the maximum-modeled PM10 concentrations for 2015 and 2019 are 

shown on map 4-1. Under the modified mining plan proposed, the DFM would not cause or 

contribute to a violation of the federal 24-hour PM10 NAAQS of 150 μg/m3(Carter Lake 

Consulting 2011).

WDEQ has determined that the DFM is not a major stationary source, in accordance with Chapter 

6, Section 4 of the WAQSR (WDEQ-AQD 2011); therefore, a PSD increment consumption 

analysis was not necessary.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-10

Table 4-4. DFM Particulate Matter Dispersion Modeling Results (μg/m3)

Pollutant Averaging

Period

Modeled 

Concentration 

Background 

Concentration 

Total 

Concentration WAAQS/NAAQS

2015 Mine Year

PM10 Annuala38.4 b11.4 49.8 50 c

2019 Mine Year

PM10 Annuala37.7 b12.0 49.7 50 c

a Violation occurs with more than one expected exceedance per calendar year, averaged over 3-years

b Highest modeled value

c Violation occurs when the 3-year average of the arithmetic means over a calendar year exceeds the value. EPA revoked the annual PM10

standard effective December 17, 2006.

There have been no recorded exceedances of the 24-hour or annual PM10 WAAQS or NAAQS 

at the DFM and, based on estimated PM2.5 values, there were no exceedances of the 24-hour or 

annual PM2.5 WAAQS/NAAQS at the mine. While the initial modeling predicted exceedances of 

annual PM10 WAAQS at two receptors along the Buckskin Mine lands necessary to conduct mining 

(LNCM), refined ISCLT3 modeling conducted in 2011 predicted no future exceedances of the 

annual PM10 WAAQS/NAAQS at a 15-Mtpy production rate (Carter Lake Consulting 2011). The 

DFM used the existing PM2.5 monitor in the north group of mines to demonstrate that the 

WAAQS/NAAQS for PM2.5 would be protected during the life of the mine (Carter Lake Consulting 

2011). The measured and estimated PM2.5 values, as shown in tables 3-6, 3-7, and 3-8, indicate 

that the PM2.5 WAAQS/NAAQS will be protected.

At the estimated average annual production rate of 6 Mt there would be an extension of 

approximately 5.3 years in the time the mine would produce and there would be an increase in 

overburden thickness, but fugitive dust emissions are projected to remain within daily and annual 

WAAQS and NAAQS limits (Carter Lake Consulting 2011). The direct and indirect effects from 

particulate matter emissions resulting from the Proposed Action are expected to be moderate 

and they would be extended by approximately 5.3 years. As discussed in section 4.4.3, the effects 

of particulate matter emissions from coal combustion would be minor. 

4.4.1.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. Impacts from particulate 

matter emissions have resulted from current mining activity and therefore under this alternative, 

particulate matter emission impacts in the area would be similar to those under the Proposed 

Action but would not be extended for an additional 5.3 years.

4.4.1.2 Cumulative Effects

The adjacent northern group of mines would contribute additional particulate matter emissions 

to the surrounding area. Cumulative impacts from particulate matter emissions could be higher in 

the short term in this area due to coal mining activities if surface inversions occur in the northern 

portion of the PRB. This would be temporary, lasting only during the inversion event. Air quality 

impacts would cease to occur after mining and reclamation are completed. The effects of 

particulate matter emissions from coal combustion are included in section 4.4.5. Modeling 

conducted for MD-11723 air quality permit included effects the adjacent northern group of mines. 

As the revised model indicated, the requested modification to DFM’s federal mining plan would 
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-11

Map 4-1. Maximum Modeled PM10 and NO2 Concentrations
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-12

not contribute to a violation of the federal annual PM10 WAAQS/NAAQS of 50 μg/m3(Carter 

Lake Consulting 2011). As discussed in section 3.4.2, the city of Sheridan is a nonattainment area 

for PM10. According to WDEQ-AQD information (WDEQ-AQD 2016), the Sheridan 

nonattainment area has attained the PM10 NAAQS for over 25 years. In light of the data from the 

past 25 years that shows compliance with PM10 NAAQS while mining has been ongoing in the PRB, 

it can be projected that the Proposed Action would not significantly contribute particulate matter 

to this nonattainment area. The cumulative effects from particulate matter emissions are expected 

to be moderate and they would be extended by approximately 5.3 years.

4.4.1.3 Mitigation Measures

No mitigation measures beyond those required by the DFM air quality permit would be required 

for emissions of particulate matter (WDEQ-AQD 2011).

4.4.2 Emissions of Carbon Monoxide (CO), Sulfur Dioxide (SO2), and Lead (Pb)

4.4.2.1 Direct and Indirect Effects 

4.4.2.1.1 Proposed Action

WFW projects that the annual coal production is expected to average 6 Mt, with mining of the 

federal coal associated with the A2Tr1 tract (WFW 2016a). DFM’s currently approved air quality 

permit from WDEQ limits annual coal production to 15 Mt of coal. According to WFW, the 

recovery of federal coal would continue at an average rate of 6 Mtpy for approximately 5.3 

additional years under the Proposed Action. The DFM is not required to monitor CO, SO2, or Pb 

so a direct comparison between current CO, SO2, or Pb at the mine and state or federal standards 

is not possible. 

SO2 monitoring data were available from Wyodak Site 4 (560050857), which is approximately 7 

miles south of the A2Tr1 tract. As presented in table 3-11, SO2 data collected at the Wyodak 

Site 4 were below the 1-hour NAAQS and WAAQS 99th percentile concentration of 75 ppb, 

indicated in table 3-3. Therefore, it is likely that ambient air quality within the vicinity of the 

proposed action is currently in compliance with the SO2 WAAQS and NAAQS.

Hg emissions data collected from three coal-fired power plants are shown in table 3-12. A direct 

comparison between the monitored values at the power plants and NAAQS and WAAQS is not 

possible since the monitored values were presented in pounds, rather than the NAAQS and 

WAAQS units (μg/m3). According to WDEQ-AQD annual inspection reports, the DFS appeared 

to be operating in compliance with all applicable Wyoming Air Quality Standards & Regulations 

(WAQSR), including those for Hg (WDEQ-AQD 2011, 2012, 2013, 2014, and 2015).

Pb emissions data collected from three coal-fired power plants, one mine, and one AQS site are 

shown in table 3-13. A direct comparison between the monitored values at the power plants/ 

mine and NAAQS and WAAQS is not possible since the monitored values were presented in 

pounds, rather than the NAAQS and WAAQS units (μg/m3). According to WDEQ-AQD annual 

inspection reports, the DFS appeared to be operating in compliance with all applicable WAQSR, 

including those for Pb (WDEQ-AQD 2011, 2012, 2013, 2014, and 2015). The 2011-2015 

monitoring results from the Thunder Basin AQS site showed that annual 1st maximum Pb 

monitoring values were well below the 90-day average NAAQS and WAAQS of 0.15 μg/m3.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-13

CO is not monitored in Campbell County, therefore the effects of CO emissions from the 

Proposed Action are difficult to assess based on monitored values. However, there are currently 

no counties/cities in Wyoming, Montana, or South Dakota that are considered as nonattainment 

for CO, based on NAAQS and WAAQS (EPA 2016b).

The effects of emissions of CO, SO2 and Pb from the Proposed Action would be minor.

4.4.2.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. Impacts from CO, SO2, and 

Pb emissions have resulted from current mining activity and therefore the impacts related to CO, 

SO2, and Pb emissions under the No Action Alternative would be similar to those under the 

Proposed Action but would not be extended for an additional 5.3 years.

4.4.2.2 Cumulative Effects

The adjacent northern group of mines would contribute additional CO, SO2, and Pb emissions to 

the surrounding area. Based on past monitoring, the permit modification request would not likely 

increase CO, SO2, or Pb emissions. Cumulative impacts from CO, SO2, and Pb could be higher in 

the short term in this area due to coal mining activities if surface inversion occurs in the northern 

portion of the PRB. This would be temporary, lasting only during the inversion. Air quality impacts 

would cease to occur after mining and reclamation are complete. The cumulative effects from CO, 

SO2, and Pb emissions are expected to be minor and they would be extended by approximately 

5.3 years.

4.4.2.3 Mitigation Measures

No mitigation measures beyond those required by the DFM air quality permit would be required 

for emissions of CO, SO2, or Pb.

4.4.3 Emissions of Nitrogen Oxides (NOX) and O3

4.4.3.1 Direct and Indirect Effects 

4.4.3.1.1 Proposed Action

WFW projects that the annual coal production is expected to average 6 Mt with mining of the 

federal coal associated with the A2Tr1 tract (WFW 2016a). DFM’s currently approved air quality 

permit from WDEQ limits annual coal production to 15 Mt of coal. According to WFW, the 

recovery of federal coal would continue at an average rate of 6 Mtpy for approximately 5.3 

additional years under the Proposed Action. The DFM is not required to monitor NOX or O3 so 

a direct comparison between current NOX or O3 at the mine and state or federal standards is not 

possible.

As presented in table 3-10, NO2 data collected at the currently active AQS monitoring sites in 

Campbell County nearest to the DFM were below the 1-hour NAAQS 98th percentile 

concentration of 100 ppb (188 μg/m3) and below the 1-hour WAAQS 98th percentile 

concentration of 188 μg/m3(100 ppb) indicated in table 3-3). Therefore, ambient air quality within 

the vicinity of the proposed action is currently in compliance with the NO2 WAAQS and NAAQS.

While, per WDEQ guidance, modeling for NO2 is not required because estimated NOx PTE would 

be well below 40 tpy, modeling was conducted a part of the MD-11723 air quality permit 
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-14

application. The year 2026 was selected as the worst-case year because that year had the highest 

modeled NOX concentrations. NOX modeling closely followed many of the same procedures used 

in the PM10 analysis. Emissions were apportioned in a similar manner and the same meteorological 

data set was used. Area source, haul road, and point source information for the DFM and Rawhide, 

Buckskin, Eagle Butte, Synthetic Fuels, and Wyodak mines and information for railroads, roads, 

power plants, and regional sources provided by WDEQ-AQD were included in the model (Carter 

Lake Consulting 2011). The amount of NOX emissions from blasting is related to the amount of 

ammonium nitrate fuel oil (ANFO) blasting agent used. Total annual NOX emission rate for 2026 

is expected to be 558.9 tons. This NOX value is included in WFW’s 2014 air quality permit 

application that was submitted to WDEQ-AQD for a revision to MD-11723 (Carter Lake 

Consulting 2011). WDEQ-AQD determined that, based on the modeling analysis and past 

monitoring, the permit modification request would not likely substantially degrade air quality 

(WDEQ-AQD 2014). Public exposure to NOX emissions caused by surface mining operations is 

most likely to occur along publicly accessible roads and highways that pass through the area of the 

mining operations. Occupants of residences in the area could also be affected. The closest public 

transportation route is the Garner Lake Road (County Road 38N), which runs through A2Tr1

and there are occupied dwellings located approximately 1,900 feet south of the A2Tr1 tract. The 

nearest recreational opportunities are within the City of Gillette, approximately 15,000 feet from 

the A2Tr1 tract. The direct and indirect effects from NOX emissions resulting from the Proposed 

Action are expected to be moderate and they would be extended by approximately 5.3 years on 

the tract.

As indicated in section 3.4.7.2, O3 monitoring is not required at the DFM but O3 levels have 

been monitored at AQS sites 560050123 and 560050456 (map 3-3) since 2011, which are located 

approximately 22 miles north and 17 miles south of the tract, respectively. No exceedances of the 

8-hour or O3 standard have occurred at monitoring site 560050123 since monitoring began in 

2010. Based on information provided by WFW that mining methods would not be significantly 

different that those currently employed at the mine (WFW 2016a), the direct and indirect effects 

from O3 emissions resulting from the Proposed Action are expected to be minor they would be 

extended by approximately 5.3 years.

4.4.3.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. Impacts from NOX and O3

emissions have resulted from current mining activity and therefore the impacts related to NOX

and O3 emissions under the No Action Alternative would be similar to those under the Proposed 

Action but would not be extended for an additional 5.3 years.

4.4.3.2 Cumulative Effects

The adjacent northern group of mines would contribute additional NOX and O3 emissions to the 

surrounding area. Modeling conducted for MD-11723 air quality permit included effects the 

adjacent northern group of mines. WDEQ-AQD determined that, based on the modeling analysis 

and past monitoring, the permit modification request would not likely substantially degrade air 

quality (WDEQ-AQD 2014). Cumulative impacts from NOX and O3 could be higher in the short 

term in this area due to coal mining activities if surface inversion occurs in the northern portion 

of the PRB. This would be temporary, lasting only during the inversion. Air quality impacts would 

cease to occur after mining and reclamation are complete. The cumulative effects from NOX and 
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-15

O3 emissions are expected to be moderate and they would be extended by approximately 5.3 

years.

O3 monitoring at AQS sites 560050123 and 560050456 (map 3-3), which are located 

approximately 22 miles north and 17 miles south of the tract, respectively, has been conducted 

since 2010. Monitoring at these sites provides an estimate of cumulative O3 emissions effects. No 

exceedances of the 8-hour or O3 standard have occurred at the monitoring sites since monitoring 

began in 2010. The cumulative effects from O3 emissions resulting from the Proposed Action are 

expected to be minor but they would be extended by approximately 5.3 years.

4.4.3.3 Mitigation Measures

No mitigation measures beyond those required by the DFM air quality permit would be required 

for emissions of NOX or O3.

4.4.4 Air Quality Related Values (AQRVs)

4.4.4.1 Direct and Indirect Effects 

4.4.4.1.1 Proposed Action

Visibility

WDEQ has determined that the DFM is not a major stationary source, in accordance with Chapter 

6, Section 4 of the WAQSR (WDEQ-AQD 2011). While the state of Wyoming does not require 

mines to evaluate impacts on Class I areas, OSMRE considers such issues during the federal mining 

plan modification review process.

Because WDEQ does not require the DFM to evaluate visibility impacts on Class I areas, the mine 

does not monitor visibility. Therefore, a direct comparison with the Wyoming standards is not 

possible. The impacts to visibility from mining the A2Tr1 tract have been inferred from the 

currently permitted impacts of mining the existing coal leases at the DFM. The nearest Class I area 

is located approximately 74 miles northwest of the A2Tr1 tract at the Northern Cheyenne Indian 

Reservation. As indicated on figure 3-4, the long-term trend in visibility at the Northern 

Cheyenne Indian Reservation appears to be relatively stable, if not improving slightly. If the coal 

within the tract is mined, the tract would be mined as an integral part of the DFM. The average 

annual coal production for the mine is anticipated to be approximately 6 Mt if the federal mining 

plan modification is approved to include the remaining federal coal in the A2Tr1 tract. 

Overburden is generally thicker in the tract than the current lease areas; therefore, state-of-theart methods to minimize any increases in blast sizes and/or blasting agents would be employed. 

Thus, emissions from blasting are not expected to increase substantially, notwithstanding the 

increased thicknesses of overburden that would be excavated in the tract. The expected levels of 

pollutants and particulates that effect visibility would be within the approved MD-11723. The 

proposed project area is not directly influenced by other air quality regulations (i.e. Class I air 

shed). The direct and indirect effects to visibility resulting from the Proposed Action are expected 

to be moderate and they would be extended by approximately 5.3 years.

Acidification of Lakes/Acid Deposition

Because the DFM is not required by WDEQ to monitor H2S, a direct comparison to WAAQS 

standards is not possible. Because factors affecting H2S emissions would not change as a result of 

the Proposed Action, the direct and indirect effects have been inferred from the currently 

permitted impacts of mining the existing coal leases at the DFM. As indicated in table 3-15, the 
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-16

2011-2015 trend in H+ at monitoring site WY99 appears to be relatively stable. Based on this 

comparison of the current information available, the Proposed Action is not expected to 

contribute to increased direct or indirect effects from acidification of lakes or to acid deposition 

that may affect soils.

4.4.4.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. Impacts to the air quality 

related values have resulted from current mining activity and therefore under this alternative, 

impacts to air quality related values in the area would be similar to those under the Proposed 

Action but would not be extended by approximately 5.3 years. 

4.4.4.2 Cumulative Effects

The cumulative AQRVs would be affected by mines in Campbell County. One method of evaluating 

the cumulative effects of the Proposed Action on AQRVs would be to assess the air quality index 

(AQI) for Campbell County. As described by the AirNow website, the AQI provides an index of 

how clean or polluted the air is within an area, and what associated health effects might be a 

concern (AirNow 2017). The AQI focuses on health affects experienced within a few hours or 

days after breathing polluted air. EPA calculates the AQI for five major air pollutants regulated by 

the Clean Air Act: ground-level ozone, particle pollution (also known as particulate matter), CO, 

SO2, and NO2. For each of these pollutants, EPA has established national air quality standards to 

protect public health. Ground-level ozone and airborne particles are the two pollutants that pose 

the greatest threat to human health in this country. The AQI evaluates air quality based on six 

levels (categories) of health concern that correspond to a different level of health concern.

The six categories of health concern are:

Good - Number of days in the year having an AQI value 0 through 50, indicating that air quality is 

considered satisfactory, and air pollution poses little or no risk.

Moderate - Number of days in the year having and AQI value 51 through 100, which means that 

air quality is acceptable; however, for some pollutants there may be a moderate health concern 

for a very small number of people who are unusually sensitive to air pollution.

Unhealthy for Sensitive Groups - Number of days in the year having an AQI value 101 through 

150, where members of sensitive groups may experience health effects. The general public is not 

likely to be affected.

Unhealthy - Number of days in the year having an AQI value 151 through 200. Everyone may begin 

to experience health effects; members of sensitive groups may experience more serious health 

effects.

Very Unhealthy - Number of days in the year having an AQI value 201 or higher. This category is 

a health alert: everyone may experience more serious health effects.

Hazardous - Number of days in the year having an AQI greater than 300. This would trigger a 

health warnings of emergency conditions with the entire population more likely to be affected.

According to information obtained from the AirNow Website, approximately 98.9 percent of the 

days between 2011 and 2015 were classified as having a good or moderate AQI and no days were 

classified as very unhealthy or hazardous (table 4-5).
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-17

Table 4-5. Average Annual Campbell County Air Quality Index Values, 2011-2016

Days 

Evaluated Good Moderate

Unhealthy for 

Sensitive 

Groups

Unhealthy Very 

Unhealthy Hazardous

2011 365 201 159 4 1 0 0

2012 365 130 221 13 2 0 0

2013 365 222 142 1 0 0 0

2014 365 262 102 1 0 0 0

2015 365 252 110 2 1 0 0

20161366 262 103 1 0 0 0

Average 365 221.5 139.5 3.7 1.0 0 0

Percent of 

Average Number 

of Days

-- 60.7% 38.2% 1.0% 0.3% 0.0% 0.0%

1 Annual statistics for 2016 are not final until May 1, 2017

Source: AirNow (2017)

Blasting, coal crushing, loading and hauling of coal, moving equipment, and other activities 

associated with surface coal mining and the combustion of coal at power plants produce 

particulates that can be released into the air, which could impact AQRVs. The cumulative effects 

on AQRVs are expected to be minor but they would be extended by approximately 5.3 years. 

Impacts to AQRVs from mining the federal coal within the A2Tr1 tracts would cease to occur 

after mining and reclamation are completed.

4.4.4.3 Mitigation Measures

No mitigation measures beyond those required by the DFM air quality permit would be required 

for AQRVs.

4.4.5 Air Quality Related to Coal Combustion

4.4.5.1 Direct and Indirect Effects

4.4.5.1.1 Proposed Action

Emissions that affect air quality also result from combustion of fossil fuels. As discussed in section 

2.4.3.3, the environmental effects of coal combustion are to be analyzed in the Proposed Action 

as well as in the No Action Alternative because they are considered to be indirect effects. CEQ 

regulations at 40 CFR 1508 (b) define “indirect effects” as those which are caused by the proposed 

action and are later in time or farther removed in distance, but are still reasonably foreseeable.

Table 4-6 presents the PM10, PM2.5, SO2, NOX, and Hg emissions estimates from coal mined at 

the DFM used for power generation. Emission estimates for 2016 through 2053 are also provided 

based on the projected average coal recovery for the time period. Using information from table 

4-6, comparisons can be made between combustion emissions from coal mined DFM and 

emissions from coal mined from Campbell County. Total U.S. emissions are also included in the 

table.

Impacts to air quality related to coal combustion under the Proposed Action would be similar to

the conditions currently experienced. When compared to Campbell County emissions, direct and 

indirect effects would be minor (less than 2 percent of the Campbell County average emissions) 

but they would be extended by approximately 5.3 years.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-18

Table 4-6. Estimated Annual PM10, PM2.5, SO2, NOX, Hg, and CO Contributions 

from Combustion of Coal Mined at the DFM for 2011-2016 and 2017-

2053, Compared to Campbell County and U.S. Total Emissions

Year

Coal 

Combusted

(Mt)

PM10 

(Tons)

PM2.5

(Tons)

SO2

Emissions 

(Tons)

NO2

Emissions 

(Tons)

Hg 

Emissions 

(Tons)

CO 

Emissions 

(Tons)

2011 5.8 4,009.9 1,223.0 50,495.9 20,775.5 0.2 1,442.7

2012 6.0 4,173.7 1,273.0 52,559.4 21,624.4 0.2 1,501.7

2013 5.4 3,775.7 1,151.6 47,546.9 19,562.2 0.2 1,358.5

2014 5.4 3,734.0 1,138.9 47,022.3 19,346.3 0.2 1,343.5

2015 6.4 4,425.5 1,349.8 55,730.6 22,929.1 0.3 1,592.3

2016 6.1 4,263.2 1,300.3 53,686.0 22,088.0 0.3 1,533.9

2017-2053

Annual Average 6.0 4,169.0 1,271.5 52,500.0 21,600.0 0.2 1,500.0

Total Campbell 

County1 369.7 256,893.4 78,352.5 3,235,037.5 1,330,986.8 15.3 92,429.6

2017-2053 

Annual Average 

Percent of 

Campbell Co.

-- 1.62% 1.62% 1.62% 1.62% 1.62% 1.62%

Total U.S. 

Emissions (2015) 824.8 573,077.7 174,788.7 7,216,720.0 2,969,164.8 34.2 206,192.0

2017-2053 

Annual Average 

Percent of U.S.

-- 0.73% 0.73% 0.73% 0.73% 0.73% 0.73%

1 Based on an estimated production of 3369.7 Mt (average of 2011 through 2016 production)

Source: WWC completed calculations, which are provided in appendix C

Power plants can release trace metals, such as Hg, during the combustion of coal to generate 

electricity. Hg is a heavy metal that is a known persistent, bioaccumulative and toxic (PBT) 

substance that occurs naturally in coal and air releases of Hg are associated with a variety of 

important environmental and human health consequences (CEC 2011). The DFM provides all of 

the coal utilized at the DFS. The estimated Hg emissions from combustion of coal combusted at 

the DFS are indicated in table 4-7.

Table 4-7. Mercury (Hg) Emissions (in Tons) from Seven Wyoming Coal Fired 

Power Plants, 2011-2015

2011 2012 20131 2014 2015 2011-2015 

Average

Wyodak Plant 0.099 0.213 0.169 0.174 0.160 0.163

Dry Fork Station 0.036 0.042 0.043 0.035 0.033 0.038

Neil Simpson Complex 0.289 0.341 (6.543) 0.327 0.356 0.328

Dave Johnston Plant 0.220 0.207 0.206 0.134 0.251 0.204

Jim Bridger Plant 0.246 0.271 0.276 0.261 0.097 0.230

Laramie River Station 0.211 0.302 0.331 0.149 0.128 0.224

Naughton Plant 0.054 0.063 0.046 0.063 0.045 0.054

Power Plant Cumulative Total 1.155 1.439 1.071 1.143 1.07 1.241

Percent of Hg Emissions from DFS 3.12% 2.92% 4.01 3.06% 3.08% 3.06%

1 2013 Neil Simpson value on website appears to be incorrect given the significantly lower values in 2011, 2012, 2014, and 2015 so 2013 

calculations are highlighted. The 2013 Neil Simpson values were not included in cumulative or average calculations.

Source: EPA 2017a

Based on the average of 2011-2015 emissions from the DFS (average coal use of 1.8 Mtpy), the 

estimated Hg emissions resulting from coal combusted at the DFS would contribute approximately 
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-19

0.04 ton of Hg emissions per year for an additional 5.3 years (WWC 2016). Therefore, the 

Proposed Action would not increase Hg emissions at the DFS but would extend the emissions by 

approximately 5.3 years.

4.4.5.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. Impacts to the air quality have 

resulted from current mining activity and therefore under this alternative, impacts to air quality 

from combustion would be similar to those under the Proposed Action but would not be extended 

by approximately 5.3 years.

4.4.5.2 Cumulative Effects

In 2015, approximately 98 percent of coal mined at the DFM was burned in Wyoming power 

plants (WFW 2016a). Therefore, the cumulative effects area related to coal combustion would 

include the state of Wyoming. The Hg emissions from seven Wyoming coal-fired power plants are 

indicated in table 4-7. Hg emissions from the Wygen Station were not available. 

The Proposed Action would not increase cumulative Hg emissions but would extend the emissions 

from coal-fired power plants by approximately 5.3 years. When compared to emissions from these 

Wyoming power plants, cumulative effects from the Proposed Action would be minor 

(approximately 3 percent of the Wyoming average emissions) but they would be extended by 

approximately 5.3 years.

4.4.6 Greenhouse Gas Emissions

4.4.6.1 Direct and Indirect Effects of the Proposed Action

4.4.6.1.1 Proposed Action

Each GHG has a different lifetime in the atmosphere and a different ability to trap heat in the 

atmosphere. To allow different gases to be compared and added together, emissions can be 

converted into CO2e emissions. DFM estimated emissions from direct emissions sources based 

on annual coal recovered from 2011 through 2016 and known production and variables used to 

calculate CO2e emissions, and for the 2017-2053-time period using estimated production and 

estimated variables (table 4-8). As determined from data in table 4-8, the emissions from direct 

sources account for approximately 0.4 percent of the total emissions. Based on estimated average 

annual CO2e emissions of 42,508 metric tons (0.043 million metric tons) from direct emission 

sources for an additional 5.3 years, the estimated direct CO2e emissions resulting from the 

Proposed Action would increase by 225,292 metric tons (0.23 million metric tons). Because 

emissions would remain constant and because the estimated average annual 2017-2053 emissions

from direct sources (0.43 million metric tons) are estimated to represent only 0.001 percent of 

the projected 2020 U.S. CO2 emission (5,774 million metric tons, USEIA 2011), impacts would be 

in the lower limit of detection that potentially could cause an insignificant change or stress to a 

resource as described in section 4.1.

Indirect effects from GHG emissions would occur as a result of emissions from indirect sources 

such as transporting and burning coal that is mined at the DFM. As determined from data in table 

4-8, the transportation and combustion of the coal are the primary contributing factors related 

to CO2e emissions from the Proposed Action, accounting for approximately 99.6 percent of the 

total emissions. Based on estimated average annual CO2e emissions of 10,085,320 metric tons 

(10.1 million metric tons) from coal transported and burned for an additional 5.3 years, the 

estimated indirect CO2e emissions resulting from the Proposed Action would increase by
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-20

Table 4-8. Estimated Annual Equivalent CO2 (CO2e) Emissions1for the Proposed Action from Coal Mined at the 

DFM (2011 through 2016, and 2017-2053 Average)

2011 2012 2013 2014 2015 2016 2017-2053 

Average

General

Mt of Coal Recovered 5.77 6.01 5.43 5.37 6.37 6.14 6.00

Mt of Coal Shipped by Conveyor (All to 

DFS) 1.01 2.03 1.99 2.14 2.10 1.83 2.00

Mt of Coal Shipped by Rail 4.76 3.98 3.44 3.24 4.27 4.30 4.00

Average Transport Miles (One Way) 365 192 250 142 132 141 216

Number of Train Trips (One Way) 308 257 222 209 276 278 302

Direct Emissions Sources

Fuel 18,853 19,624 19,624 17,556 20,808 20,026 19,601

Electricity Consumed in Mining Process 15,409 16,039 16,039 14,349 17,006 16,368 16,021

Mining Process 6,623 6,894 6,894 6,168 7,310 7,035 6,886

Total Direct Emissions 40,886 42,556 42,556 38,073 45,124 43,429 42,508

Indirect Emissions Sources

Rail Transport2

60,693 26,675 30,030 16,044 19,687 21,199 35,320

From Coal Combustion 9,666,365 10,061,368 9,101,843 9,001,405 10,668,420 10,277,040 10,050,000

Total Indirect Emissions 9,727,058 10,088,043 9,131,873 9,017,448 10,688,107 10,298,239 10,085,320

Total Estimated CO2e Emissions 9,767,943 10,130,599 9,174,429 9,055,521 10,733,231 10,341,668 10,127,829

1 Based on 1.683 metric tons CO2e per ton of coal burned for electrical generation (EPA 2008) and calculated by WWC (2017)

2 Coal haulage emissions based on train trips per year; 452.7 kg CO2e per mile per loaded train, 87.2 Kg CO2e per mile per empty train; and round-trip mileage to power plants. Coal haulage emissions 

calculations includes a loaded train and a returning empty train, per train trip. 2017-2053 Rail distance calculated as the average 2011-2016 rail miles

Source: WWC (2017), calculations are provided in appendix C
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-21

53,452,196 metric tons (53.5 million metric tons). Because emissions would remain constant and 

because estimated average annual 2017-2053 emissions from indirect sources (10.1 million metric 

tons) are estimated to represent only 0.18 percent of the projected 2020 U.S. CO2 emission (5,774 

million metric tons, USEIA 2011), impacts would be potentially detectable but slight, meeting the 

definition of “minor” as described in the EA.

While annual CO2e emissions would remain the same as the No Action Alternative for 

approximately 31 years, the LOM CO2e emissions would increase by approximately 16 percent 

over the No Action Alternative, based on 5.3-additional years of combustion of DFM coal.

4.4.6.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. The impacts directly and 

indirectly resulting from GHG emissions under the No Action Alternative would be similar to 

those under the Proposed Action but would not be extended by approximately 5.3 years. While 

annual CO2e emissions would remain the same as the Proposed Action for approximately 31 

years, the LOM CO2e emissions would decrease by approximately 16 percent as a result of the 

No Action Alternative, based primarily on 5.3-fewer years of combustion of DFM coal.

4.4.6.2 Cumulative Effects

The analyses provided above include direct and indirect effects analysis for GHG emissions. Due 

to the global nature of climate change, and the difficulty therefore of predicting climate change 

impacts caused by an incremental increase in GHG emissions from specific actions separately or 

together, a separate cumulative impacts analysis for GHG emissions is not appropriate.

4.4.6.3 Mitigation Measures

A majority (approximately 99. 7 percent) of the GHG emitted identified in the EA are from nonmining activities. Therefore, no mitigation measures beyond those required by the DFM air quality 

permit would be implemented to mitigate GHG effects from mining the coal within the A2Tr1 

tract.

4.4.7 Climate Change Cause and Effect

4.4.7.1 Proposed Action/No Action Alternative

Although the effects of GHG emissions and other contributions to climate change in the global 

aggregate are estimable, it is currently not feasible to determine what effect GHG emissions in a 

specific area resulting from a specific activity might have on climate change and resulting 

environmental impacts. It is therefore not currently possible to associate any particular action with 

the creation or mitigation of any specific climate-related environmental effects, including the costsbenefits of an action. Therefore the emissions are calculated as a relative indicator to allow 

comparison of the Proposed Action and the No Action Alternative based on their potential 

contribution to climate change.

Historically, the coal mined in the PRB has been used as one of the sources of fuel to generate 

electricity in power plants located throughout the U.S. Coal-fired power plant emissions include 

CO2, which has been identified as a principal anthropogenic greenhouse gas. According to the EPA 

(2016) in 2014 (the most recent year of available CO2 data at this time):

1. CO2 emissions represent approximately 81 percent of the total 2014 U.S. 

greenhouse gas emissions.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-22

2. Estimated CO2 emissions in the U.S. totaled 6,870.5 million metric tons in 2014, 

which was a 7.7 percent decrease from the estimated high emissions in 2007.

3. Estimated CO2e emissions from energy-related consumption in the U.S. totaled 

5,556 million metric tons in 2014.

4. Estimated CO2 emissions from the electric power sector totaled 2,080.7 million 

metric tons, or approximately 37 percent of total U.S. energy-related CO2

emissions in 2014.

5. Estimated CO2 emissions from fossil fuel electric power generation totaled 2,039.3 

million metric tons, or about 36.7 percent of total U.S. energy-related CO2

emissions in 2014.

Approximately 824.8 Mt of coal were used to generate electricity in the U.S. in 2014, of which 

approximately 387.1 Mt was produced in Wyoming (USEIA 2016b). Approximately 96 percent of 

the coal mined in Wyoming in 2014 came from the PRB (WDWS 2014) was used to generate 

electricity in 2014. Therefore, coal production from the Wyoming PRB coal represented 

approximately 45.1 percent of the coal used for power generation in 2014. Applying this 

percentage to the estimated 2,039.3 million metric tons of total U.S. CO2 emissions from fossil 

fuel electric power generation, Wyoming PRB surface coal mines were responsible for 

approximately 918.8 million metric tons CO2 emissions from coal power generation in 2014. The 

DFM produced 5.4 Mt of coal in 2014, which represents approximately 1.4 percent of the coal 

produced in Wyoming in 2014, or about 12.9 million metric tons of CO2 emissions from coal 

power generation. In 2015, approximately 98 percent of coal mined at the DFM was burned in 

Wyoming power plants (WFW 2016a). 

A protocol to estimate what is referenced as the “social cost of carbon” (SCC) associated with 

GHG emissions was developed by a federal Interagency Working Group (IWG), to assist agencies 

in addressing Executive Order (EO) 12866. That EO required federal agencies to assess the cost 

and the benefits of intended regulations as part of their regulatory impact analyses. The SCC 

protocol was also developed for use in cost-benefit analyses of proposed regulations that could 

impact cumulative global emissions (Shelanski and Obstfeld 2015). 

Notably, the SCC protocol does not measure the actual incremental impacts of a project on the 

environment and does not include all damages or benefits from carbon emissions. The SCC 

protocol estimates economic damages associated with an increase in carbon dioxide emissions --

typically expressed as a one mt increase in a single year -- and includes, but is not limited to, 

potential changes in net agricultural productivity, human health, and property damages from 

increased flood risk over hundreds of years. The estimate is developed by aggregating results 

“across models, over time, across regions and impact categories, and across 150,000 scenarios” 

(Rose et al. 2014). The dollar cost figure arrived at based on the SCC calculation represents the 

value of damages avoided if, ultimately, there is no increase in carbon emissions.

A recent EO entitled, “Promoting Energy Independence and Economic Growth,” issued March 28, 

2017, directed that the IWG be disbanded and that technical documents issued by the IWG be 

withdrawn as no longer representative of federal policy. The 2017 EO further directed that when 

monetizing the value of changes in greenhouse gas emissions resulting from regulations, agencies 

follow the guidance contained in OMB Circular A-4 of September 17, 2003. In all cases, a Federal 

agency should ensure that its consideration of the information and other factors relevant to its 

decision is consistent with applicable statutory or other authorities, including requirements for 

the use of cost-benefit analysis. 
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-23

Based on emission estimates for coal combustion, SCC calculations can quickly rise to large values; 

however, specific threshold levels for the determination of significance can vary depending on 

numerous project factors. OSMRE has elected not to specifically quantify the SCC in its assessment 

of the Dry Fork mining plan modification. NEPA does not require a cost-benefit analysis (40 C.F.R. 

§ 1502.23) or the presentation of the SCC cost estimates quantitatively in all cases, and that 

analysis was not undertaken here. Without a complete monetary cost-benefit analysis, which 

would include the social benefits of energy production to society as a whole and other potential 

positive benefits, inclusion solely of a SCC analysis would be unbalanced, potentially inaccurate, 

and not useful. Given the uncertainties associated with assigning a specific and accurate social cost 

of carbon resulting from 5.3 additional years of operation under the mining plan modification, and 

that the SCC protocol and similar models were developed to estimate impacts of regulations over 

long time frames, this EA quantifies direct and indirect GHG emissions and evaluates these 

emissions in the context of national and Wyoming GHG emission inventories as discussed in 

Section 4.4.6 Greenhouse Gas Emissions.

Further, any increased economic activity, in terms of revenue, employment, labor income, total 

value added, and output, that is expected to occur with the proposed action is simply an economic 

impact, rather than an economic benefit, inasmuch as such impacts might be viewed by another 

person as negative or undesirable impacts due to potential increase in local population, 

competition for jobs, and concerns that changes in population will change the quality of the local 

community. Economic impact is distinct from “economic benefit” as defined in economic theory 

and methodology, and the socioeconomic impact analysis required under NEPA is distinct from 

cost-benefit analysis, which is not required.

To summarize, this EA does not undertake an analysis of SCC because 1) it is not engaged in a 

rulemaking for which the protocol was originally developed; 2) the IWG, technical supporting 

documents, and associated guidance have been withdrawn; 3) NEPA does not require cost-benefit 

analysis and the agency did not undertake one here; and 4) because the full social benefits of coalfired energy production have not been monetized, quantifying only the costs of GHG emissions 

would provide information that is both potentially inaccurate and not useful.

Estimated CO2 emissions in the U.S. decreased 10.4 percent from 2007 through 2015 (EPA 2017a). 

Under the Proposed Action, WFW anticipates producing the coal included in the A2Tr1 tract at 

6 Mtpy levels, using existing production and transportation facilities. This would extend the mine’s 

current GHG emissions by approximately 5.3 years and combustion of A2Tr1 tract federal coal 

in coal-fired power plants would also continue for approximately 5.3 additional years. Climate 

impacts associated with direct/indirect emissions from A2Tr1 from mining, transportation, and 

combustion would be moderate but short term (5.3 years). The impacts would diminish after the

LOM.

4.4.7.2 Cumulative Effects 

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. As stated in 40 CFR 1502.22(b), the variables involved in such an analysis would make this 

determination conjectural and not within the rule of reason. 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.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-24

4.4.7.3 Direct and Indirect Effects on the Proposed Action/No Action Alternative

USGS predicted GHG potential impacts between 2025 and 2049 using the conservative climate 

change scenario (RCP8.5), which assumes no new climate change regulations or reductions would 

be implemented (USGS 2016). According to the USGS National Climate Change Viewer 

(USGS 2016), potential climate change impacts in Campbell County, Wyoming could include: 

1. annual mean temperature increases of up to 3.8 degrees Fahrenheit, 

2. annual mean precipitation increases of up to 0.4 inch per day, 

3. annual mean snowfall decrease of up to 0.1 inch per year,

4. annual mean soil water storage decrease of up to 0.1 inch per year,

5. annual mean evaporation deficit increase of up to 0.2 inch per month, and 

6. annual mean runoff increases up to 0.1 inch per month. 

For analysis purposes, the EA assumes that the maximum annual mean values would be realized 

during the life of the mine. 

Hydrology

The potential changes to the annual snowfall, precipitation levels, and streamflow could impact 

area surface water body levels, groundwater recharge, and soil erosion. During the anticipated 

5.3-year life of the project, natural variations results in dryer or wetter years. 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 5.3 years, mine dewatering may 

compensate for climate change related stream flow reduction, or may have no additional influence 

on streamflow. Therefore, there will be no climate change impacts on streamflows where project 

impacts occur or they may be negligible during the project timeframe. The Proposed Action would 

have moderate, short-term impacts to surface water bodies and groundwater, however, the 

impact from changes to these resources based on climate change would be negligible and longterm. 

Soils

The Proposed Action would involve new surface disturbance of approximately 155.4 acres. As 

described in section 4.8.1.1, the direct and indirect effects related to the Proposed Action to 

soils would be moderate and they would be extended by approximately 5.3 years on the tract. 

However, the USGS climate viewer does not predict any significant annual mean changes to runoff 

so there would be negligible impacts from climate change on soils. 

Sage Grouse

The Proposed Action is consistent with Executive Order 2015-4 guidance (Office of the Governor 

2015) and BLM’s Approved Resource Management Plan (BLM 2015b), which take into account 

potential climate change. Impacts from climate change on the greater sage-grouse during the life 

of the project are anticipated to be negligible.

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 plant species during reclamation to account for the higher 

temperatures and increased precipitation levels. WDEQ-LQD regulates surface coal mining 

operations and the surface effects of underground coal mining on federal lands within the state of 
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-25

Wyoming. Federal coal leaseholders in Wyoming must submit a permit application package to 

OSMRE and WDEQ-LQD for any proposed revisions to reclamation operations on federal lands 

in the state. Therefore, any change to reclamation practices (i.e., seed mix) at the DFM would 

require the approval of WDEQ. Climate change impacts on reclamation during the life of the 

project would be negligible. Reestablishment of wildlife and vegetation in areas that have been 

disturbed is reliant on the reclamation process which would be negligibly impacted by climate 

change; therefore, climate change impacts to wildlife and vegetation in reclaimed areas would be 

negligible and long-term.

4.5 Water Resources

4.5.1 Surface Water

4.5.1.1 Direct and Indirect Effects 

4.5.1.1.1 Proposed Action

Discussions regarding surface water can be found in section 3.5.1 and in Appendix D-6 

(Hydrology) of the DFM Permit No. PT0599 (WFW 2011) and in the DFM, Permit 0599 CHIA 

(WDEQ-LQD/Lidstone 2013). The 2013 CHIA analyzed the impact of the amendment along with 

existing coal mining at the Buckskin, Rawhide, Eagle Butte, Dry Fork, Synthetic Fuels, and Wyodak 

mines to determine whether mining would result in material damage to surface and groundwater 

resources outside of the mine permit areas (WDEQ-LQD/Lidstone 2013). Changes in surface 

runoff characteristics and sediment discharges would occur during mining on A2Tr1 tract because 

of the mining and reconstruction of drainage channels as mining progresses and because of the use 

of sediment control structures to manage discharges of surface water from the mine permit areas. 

According to WDEQ-LQD Rules and Regulations, proposed mining operations must be designed 

and conducted “to minimize disturbance of the hydrologic balance within the permit and adjacent 

areas, to prevent material damage to the hydrologic balance outside the permit area, to assure the 

protection or replacement of water rights, and to support approved post-mining land uses in 

accordance with the terms and conditions of the approved permit and the performance standards” 

of Chapter 4, Environmental Protection Performance Standards (WDEQ-LQD 2012). Because the 

A2Tr1 tract would be mined as extension of the existing DFM, there would not be a significant 

increase in the size of the area that is disturbed at any given time. Reclamation would be ongoing 

and concurrent with mining.

As stated in the Addendum MP-T of the DFM Permit No. PT0599 (Permit Application for Industrial 

Solid Waste Landfill) (WFW 2011), the CCB the facility (discussed in section 3.15) is not 

expected to have a detrimental effect on surface water quality. There are no surface water intake 

structures located within 1,000 feet of the facility. The potential impacts to local surface water 

systems will be minimized through proper engineering design of the landfill and associated storm 

water controls, as discussed in Addendum MP-T (WFW 2011).

Effects from air deposition of pollutants for coal combustion are discussed in section 4.4.3.

The overall results of the 2013 CHIA stated that material damage has not occurred to surface 

water quality outside the mine permit areas. The additional mining proposed by Amendment 2 is 

not expected to change the potential for material damage to surface water quality 

(WDEQ-LQD/Lidstone 2013). Therefore, the direct and indirect effects to surface water would 

not be significantly different than those described in the existing DFM federal mining plan and are 

expected to be moderate and they would be extended by approximately 5.3 years.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-26

4.5.1.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. The impacts to surface water 

(mining and reconstruction of drainage channels) under the No Action Alternative would be 

similar to those under the Proposed Action but the extent of surface water feature removal would 

be reduced by approximately 151 acres. Impacts to surface water features have already occurred 

within the tract related to coal recovery on adjacent federal coal leases, as approved by WFW’s 

WDEQ-LQD Permit No. PT0599 and OSMRE’s 1985 and 1989 federal MPDDs. In addition, 

currently approved state and federal mining plans include disturbance of approximately 155.4 acres 

within the A2Tr1 tract. Therefore, implementation of the No Action Alternative would have 

negligible effect on reducing the extent of these impacts.

4.5.1.2 Cumulative Effects

The cumulative impact area for potential surface water impacts includes proposed LOM 

disturbance areas for the adjacent northern group of mines within local drainage basins (map 4-2). 

Pre-mine stream morphology measurements have been used to design and evaluate reconstructed 

stream channels. Runoff modeling is used to evaluate hydraulic suitability and predict post-mine 

discharges in reconstructed channels for varied recurrence intervals. The reclaimed topography 

includes the reconstruction of portions of several of the main channels associated with the DFM 

and adjacent mines, including the main stem of Rawhide Creek, Little Rawhide Creek, Hay Creek, 

and the Dry Fork LPR. Cumulative mining related impacts to surface water resources associated 

within the LPR cumulative impacts area (CIA) were analyzed in the 2013 CHIA (WDEQ-LQD/Lidstone 

2013). As described in the 2013 CHIA, some bed and bank erosion is likely to occur, but the

channel slope and cross-sectional dimensions should not change substantially during the design 

discharge event. Post-mine channels are generally wider, often having shallower gradients than 

corresponding pre-mine channels. These post-mine channels often have greater cross-sectional 

areas that result in flow resistance and lower velocities that can enhance erosional stability of the 

drainages (WDEQ-LQD/Lidstone 2013).

According to the 2013 CHIA, the post-mining water quality in the LPR CIA should be similar to 

pre-mine water quality (WDEQ-LQD/Lidstone 2013). The number of lower gradient slopes (0 to 

10 percent) is generally increased at each mine, which decreases the production and delivery of 

sediment to streams, assuming the post-mine hydrologic and geomorphic conditions approximate 

pre-mine conditions following reclamation.

Mining related cumulative impacts to surface water are expected to be measureable in the short 

term within and below mined area drainages, but would diminish with reclamation and distance 

downstream.

4.5.1.3 Mitigation Measures

The WDEQ-LQD Rules and Regulations require surface coal mine permittees to enhance or 

restore the hydrologic conditions of disturbed land surfaces and minimize adverse impacts to the 

hydrologic balance (WDEQ-LQD 2012). And, as stated above, proposed mining operations must 

be designed and conducted in a way to prevent material damage to the hydrologic balance outside 

the permit area (WDEQ-LQD 2012). The DFM is required to be in compliance with WYPDES 

Permit Number WY-0032964 issued by the WDEQ-WQD under the NPDES program.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-27

Map 4-2. Cumulative Impact Area for Potential Surface and Groundwater 

Impacts
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-28

4.5.2 Groundwater

4.5.2.1 Direct and Indirect Effects 

4.5.2.1.1 Proposed Action

Discussions regarding groundwater can be found in section 3.5.2, in Appendix D-6 (Hydrology) 

of the DFM Permit No. PT0599 (WFW 2011), and in the 2013 CHIA (WDEQ-LQD/Lidstone 

2013). The existing federal leases at the DFM include approximately 5,541.5 acres, including 155.4 

acres within the A2Tr1 tract that are currently approved for disturbance (unrelated to recovery 

of federal coal within the tract) by WDEQ-LQD. Under the Proposed Action, disturbance within

the A2Tr1 tract would extend the area of federal coal removal included in the federal mining plan 

onto 151 additional acres.

The general impacts to groundwater as a result of surface coal mining include the following:

1. The removal of the coal aquifer and any overburden and alluvial aquifers within the 

areas that are mined would continue, as would the replacement of these aquifers 

with backfilled overburden material. Should any overburden or alluvial aquifer be 

critical to the area’s hydrologic balance, and restoration of the essential hydrologic 

functions can only be achieved by reestablishment of the aquifer, these materials 

may be selectively salvaged and replaced.

2. A lowering of static water levels in the coal and overburden aquifers around the 

mine would continue due to dewatering associated with removal of these aquifers 

within the mine boundaries. This reduction in static water levels would not be 

permanent, and recharge to the backfill and adjacent undisturbed aquifers would 

occur as mined areas are reclaimed.

Other groundwater impacts may or may not occur, or may occur only at specific locations, include 

changes in water quality (usually deterioration) outside the area that is mined and reclaimed. This 

would result from communication between the reclaimed aquifer and the unmined aquifer, and 

changes in recharge-discharge conditions and/or groundwater flow patterns.

Additional alluvial, overburden, and Wyodak-Anderson coal aquifers would be removed in the 

A2Tr1 tract during the mining process. These aquifers would be replaced with backfilled 

overburden and interburden materials. The physical characteristics of the reclaimed backfill 

material are dependent upon mining methods and premining overburden lithology. Overall, the 

permeability and porosity of the spoils within the tract are expected to be greater than the original 

material. The reclaimed spoil aquifer could provide adequate water quantity for stock wells. 

Predicted drawdowns for the Wyodak-Anderson coal seam is presented on map 4-3. 

According to the 2013 CHIA, the groundwater migrating from the backfill aquifer in the future is 

not expected to cause material damage to the coal aquifer. The additional mining proposed by the 

Dry Fork Amendment 2 is not expected to change the potential for material damage to 

groundwater quality. 

As stated in the Addendum MP-T (Permit Application for Industrial Solid Waste Landfill) of the 

DFM Permit No. PT0599 (WFW 2011), the CCB from the facility is not expected to have a 

detrimental effect on groundwater quality. There are no permitted domestic wells and only one 

stock watering well within 0.5 mile of the facility. The single stock watering well is permitted by 

WFW. The potential impacts to local groundwater systems will be minimized through proper
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-29

Map 4-3. Predicted Drawdowns for the Wyodak-Anderson Coal Seam
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-30

engineering design of the landfill and associated storm water controls, as discussed in Addendum 

MP-T (WFW 2011).

Effects from air deposition of pollutants for coal combustion are discussed in section 4.4.3.

Overall, evaluation of the three material damage indicators (physical characteristics, water level 

recovery, and water quality of the backfill aquifer) suggests that there is limited potential for the 

A2Tr1 tract development at the Dry Fork Mine to cause material damage to the native aquifers 

outside the coal mine permit boundaries (WDEQ-LQD/Lidstone 2013). Therefore, the direct and 

indirect effects to groundwater resources resulting from the Proposed Action are expected to be 

moderate and they would be extended by approximately 5.3 years on the tract due to aquifer 

removal.

4.5.2.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. The impacts to groundwater 

under the No Action Alternative would be similar to those under the Proposed Action but the 

extent of groundwater aquifers removal would be reduced by approximately 151 acres. Impacts 

to groundwater aquifers have already occurred within the tract related to coal recovery on 

adjacent federal coal leases, as approved by WFW’s WDEQ-LQD Permit No. PT0599 and 

OSMRE’s 1985 and 1989 federal MPDDs. In addition, currently approved state and federal mining 

plans include disturbance of approximately 155.4 acres within the A2Tr1 tract. Therefore, 

implementation of the No Action Alternative would have negligible effect on reducing the extent 

of these impacts.

4.5.2.2 Cumulative Effects

The effects of removal of the coal and overburden aquifers and replacing them with backfilled 

overburden are the foremost groundwater concerns regarding cumulative effects. Continued 

mining of the A2Tr1 tract would increase the cumulative size of the backfill area in the northern 

group of mines in the PRB. The extent of water level drawdown in the coal and shallower aquifers 

in the area surrounding the mines also would be expected to increase slightly as a result of 

continued mining in the tract and from dewatering the active mine pits. Where the effects of 

pumping from Dry Fork, Rawhide, Buckskin, Eagle Butte, Synthetic Fuels, and Wyodak mines

overlap, additional water level declines result from concurrent operations.

As described in the 2013 CHIA, CBNG dewatering in the CIA has caused drawdown of water 

levels in the Wyodak-Anderson coal aquifer within the CIA, making it difficult to accurately 

distinguish the impacts caused by mining and to estimate groundwater recovery rates. However, 

the saturated thickness of the coal seams increases to the west as the coal seams dip below the 

water table. Therefore, the effect of this predicted mining induced drawdown on the WyodakAnderson coal seam is likely negligible. The coal aquifer is expected to begin to recover as soon 

as the mining stops by 2065 and would be on a recovery trend when reclamation is completed by 

approximately 2080 (WDEQ-LQD/Lidstone 2013).

The cumulative effects to groundwater resources resulting from the Proposed Action are 

expected to be moderate and they would be extended by approximately 5.3 years on the tract 

due to aquifer removal.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-31

4.5.2.3 Mitigation Measures

WDEQ-LQD Rules and Regulations require surface coal mine permittees to replace any domestic, 

agricultural, industrial, or any other legitimate use groundwater supplies if, as a result of mining, a 

supply is diminished, interrupted, or contaminated, to the extent of precluding use of the water. 

The WDEQ-LQD Rules and Regulations also require surface coal mine permittees to enhance or 

restore the hydrologic conditions of disturbed land surfaces and minimize adverse impacts to the 

hydrologic balance. The recharge capacity of the reclaimed lands will be restored to a condition 

which minimizes disturbance to prevailing hydrologic balance in the permit area and in adjacent 

areas (WDEQ-LQD 2012).

Surface water control structures associated with the CCB facility will be used to divert surface 

water flows around active landfill areas (run-on control), and to collect and contain surface water 

run-off from active landfill areas (run-off control).

4.5.3 Water Rights

4.5.3.1 Direct and Indirect Effects 

4.5.3.1.1 Proposed Action

Prior to energy development in the area, water appropriations (both groundwater and surface 

water) were typically for livestock use. Currently, mining companies hold the majority of the water 

rights in the vicinity of the EA project area. According to Wyoming Rules and Regulations, 

proposed mining operations must be designed and conducted in a way to prevent material damage 

to the hydrologic balance outside the permit area (WDEQ-LQD 2012). According to Wyoming 

Statue (W.S.) 35-11-415(b) (xii), the Dry Fork Mine must replace, in accordance with state law, 

the water supply of an owner of interest in real property, who obtains all or part of his supply of 

water for domestic, agricultural, industrial or any other legitimate use from an underground or 

surface source where the supply has been affected by contamination, diminution or interruption 

resulting from the surface coal mine operation.

Monitoring wells are placed between mine operations and nearby private wells to monitor for 

water level and water quality changes to anticipate any downgradient impacts. Currently, CBNG 

production has exceeded the amount of drawdown predicted to result from mining. Therefore, 

potential impacts from mining to stock and domestic wells in the area have become largely 

irrelevant.

Numerous livestock water wells have been removed over the years to facilitate mining operations 

but no effects to domestic supplies have been reported. No material damage has been identified 

outside the permit boundaries of the DFM, and based on hydrologic analyses, no material damage 

to water rights is anticipated (WDEQ-LQD/Lidstone 2013).

In general, the proposed federal mining plan amendment would contribute to additional, more 

extensive mining disturbance that may impact groundwater and surface-water rights in the DFM

area. As stated in section 3.5.2, current groundwater conditions have already changed in the 

DFM area as a result of CBNG development and ongoing mining operations at the Dry Fork, 

Rawhide, Buckskin, Eagle Butte, Synthetic Fuels, and Wyodak mines. Therefore, the Proposed 

Action would not result in substantial declines in the groundwater availability, due to reduced 

groundwater quantity and quality, over what is currently being experienced. In addition, only a 

slight reduction in streamflow downstream of the DFM during mining is expected because runoff 
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-32

is currently being controlled within the DFM as a result of mining unrelated to the Proposed 

Action. Therefore, impacts to groundwater or surface-water rights have already occurred from 

mining within the DFM and from CBNG development and implementation of the Proposed Action 

would have negligible effect on increasing the extent of impacts.

4.5.3.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. The impacts to surface and 

groundwater rights under the No Action Alternative would be similar to those under the 

Proposed Action but the extent of surface water feature and groundwater aquifers removal would 

be reduced by approximately 151 acres. Impacts to water rights have already occurred within the 

tract related to coal recovery on adjacent federal coal leases, as approved by WFW’s WDEQ-LQD 

Permit No. PT0599 and OSMRE’s 1985 and 1989 federal MPDDs. In addition, currently approved 

state and federal mining plans include disturbance of approximately 155.4 acres within the A2Tr1 

tract. Therefore, implementation of the No Action Alternative would have negligible effect on 

reducing the extent of these impacts.

4.5.3.2 Cumulative Effects

While the approval of the federal mining plan modification request would contribute to additional 

mining disturbance to 151 acres in the Dry Fork, Rawhide, Buckskin, Eagle Butte, Synthetic Fuels, 

and Wyodak mine areas, there would be minor additional cumulative water rights impacts because 

groundwater systems have already been affected by CBNG removal and ongoing mining and 

because runoff is currently being controlled within the Dry Fork, Rawhide, Buckskin, Eagle Butte, 

Synthetic Fuels, and Wyodak mines.

4.5.3.3 Mitigation Measures

WDEQ-LQD Rules and Regulations require surface coal mine permittees to replace any domestic, 

agricultural, industrial, or any other legitimate use groundwater supplies if such supplies are 

diminished, interrupted, or contaminated, to the extent of precluding use of the water as a result 

of mining. The regulations also require restoration of the essential hydrologic function of disturbed 

land surfaces. Therefore, no additional mitigation measures are required to protect water rights.

4.6 Alluvial Valley Floors

4.6.1 Direct and Indirect Effects

4.6.1.1 Proposed Action

The direct and indirect effects to alluvial AVF would not be significantly different than those 

described in the existing DFM federal mining plan. According to Appendix D11 (Alluvial Valley 

Floor Assessment of the DFM Permit No. PT0599), while there is approximately 0.65 mile of 

unconsolidated stream-laid deposits along an ephemeral drainage within the tract, no AVFs have 

been delineated within the A2Tr1 tract (WFW 2011). The nearest AVF is located along Dry Fork 

LPR, approximately 2 miles from the A2Tr1 tract. This ephemeral drainage contributes an 

insignificant amount of runoff to this section of Dry Fork LPR, so there would be no direct or 

indirect effects to AVFs from the Proposed Action.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-33

4.6.1.2 No Action Alternative

Because no AVFs have been delineated within the tract, impacts to alluvial valley floors in the area 

under the No Action Alternative would remain as described in section 4.6.1.1.

4.6.2 Cumulative Effects

The identified AVFs for all coal mines in the PRB Coal Review study area are described in the 

updated 2012 Task 1D Report (BLM 2014), and are based on individual mine state decision 

documents. Regulatory determinations of AVF occurrence and location are completed as part of 

the permitting process for coal mining operations because their presence can restrict mining 

activities under SMCRA and Wyoming laws. The WDEQ administers the AVF regulations for coal 

mining activities in Wyoming. Coal-mine-related impacts on designated AVFs generally are not 

permitted if the AVF is determined to be significant to agriculture. If an AVF is determined not to 

be significant to agriculture or if the permit to affect the AVF was approved prior to the effective 

date of SMCRA, the AVF can be disturbed during mining but must be restored to essential 

hydrologic function during reclamation.

The formal AVF designation and related regulatory programs described above are specific to coal 

mining operations; however, other development-related activities in the study area would 

potentially impact AVF resources. The portions of the PRB Coal Review study area that lie outside 

of the mine permit areas have generally not been surveyed for the presence of AVFs; therefore, 

the locations and extent of the AVFs outside of the mine permit areas have not been determined. 

No AVFs are present in the A2Tr1 tract and the Proposed Action would not contribute to the 

cumulative effects to area AVFs.

4.6.3 Mitigation Measures

No mitigation measures would be necessary for AVFs.

4.7 Wetlands/Aquatic Resources

4.7.1 Direct and Indirect Effects 

4.7.1.1 Proposed Action

No wetlands or aquatic resources, including jurisdictional wetlands, are present within the A2Tr1 

tract so there would be no direct or indirect effects to wetlands or aquatic resources from the 

Proposed Action.

4.7.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. Since no wetlands (including 

jurisdictional wetlands) have been delineated within the tract, impacts to wetlands would be similar 

to those under the Proposed Action. There would be no direct or indirect effects to wetlands 

from the No Action Alternative.

4.7.2 Cumulative Effects

The cumulative effects on wetlands/aquatic resources would occur primarily from livestock 

grazing, agricultural water withdrawals, and coal mining operations at the Dry Fork, Rawhide, 

Buckskin, Eagle Butte, Synthetic Fuels, and Wyodak mines. CBNG activities and associated 

discharge of produced water have declined significantly so effects from these activities has also 
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-34

declined. Any artificially created wetlands resulting from CBNG and mining water discharges 

would likely return to an upland ecosystem following cessation of discharges. Wetlands 

disturbance within the DFM permit boundary are under the jurisdiction of the USACE and 

WDEQ-LQD requires postmine reclamation plans that restore wetlands (WDEQ-LQD 2012).

No wetlands have been delineated within the A2Tr1 tract and the Proposed Action would not 

contribute to the cumulative effects to area wetlands.

4.7.3 Mitigation Measures

No mitigation measures would be necessary for wetlands or aquatic resources.

4.8 Soil

4.8.1 Direct and Indirect Effects

4.8.1.1 Proposed Action

Topsoil, like the overburden, is removed and replaced during mining and reclamation process. This 

process results in differences between premining and postmining soils. Premining soils occur as 

soil series and are often combined into mappable units, which are distinguishable, by their physical 

and chemical characteristics, depths, locations in the landscape, and other factors. The postmining 

topsoil is a composite of premining soils resulting in more uniform soil chemistry and nutrient 

distribution. Prior to mining, the operator is required to map the soils, test them for physical and 

chemical suitability to support plant growth, and provide a plan for their salvage and replacement. 

Soil material determined to be unsuitable due to physical or chemical characteristics is not salvaged 

or replaced. 

Direct impacts to soil resources as a result of mining include potential changes in soil structure, 

texture, organic matter content, infiltration rate, permeability, water-holding capacity, soil plant 

nutrient level, soil microbial composition and activity, and soil fertility. Mining exposes lower soils 

or overburden material that could contain chemical constituents at levels that could be harmful to 

plants and animals. Regarding soil fertility, stockpiling soil material for several years before it is 

redistributed potentially degrades biological, chemical, and physical properties. Stockpiling could 

lower the organic matter content, microbial activity and viability of plant seeds, disrupt nutrient 

cycles, upset the carbon-nitrogen ratio, and increase near-surface bulk density. Live handling 

(direct placement) of topsoil would enhance revegetation success due to using topsoil that has not 

been stored in topsoil piles for an extended period of time. The exposure, compaction, and 

stockpiling of salvaged soil material can increase potential for soil loss from both wind erosion and 

water erosion until the soil is revegetated. Reclamation measures currently implemented during 

mining would reduce the effects of increased erosion potential. Currently approved and proposed 

disturbance would be progressively reclaimed, according to contemporaneous reclamation 

requirements, by planting appropriate vegetation species to restore soil productivity and prevent 

soil erosion.

An indirect effect of the Proposed Action on soils would be impacts from acid deposition resulting 

from coal combustion (see section 3.4.7.3.3).

No “prime” or “unique” farmland exists within the proposed A2Tr1 tract so none would be 

disturbed. Drainage features would be reconstructed on the area similar to reclamation techniques 

used at the DFM. Therefore, special handling techniques would not be required for soils within 

the tract.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-35

Disturbance has been approved on approximately 155.4 acres so approximately 151 additional 

acres of soil resources within the tract would be altered under the Proposed Action. As stated 

above, areas within the tract would be progressively disturbed and progressively reclaimed by 

planting appropriate vegetation species to restore soil productivity and prevent soil erosion. This 

sequence of disturbance/reclamation would maintain a relatively constant amount of disturbance, 

over time. Under the Proposed Action, surface coal mining in the proposed tract and mine-related 

activities in the support area would have a moderate, long-term impact on bulk density and 

infiltration rates in soils. However, reclamation in these areas following mining could be enhanced 

by increasing topsoil thickness in some instances and by decreasing surface runoff due to seedbed 

preparations (soil laydown and ripping prior to seeding). Spoil sampling prior to topsoil laydown 

would ensure the spoil within the rooting zone is not toxic to vegetation. The Proposed Action 

would have a moderate, short- to long-term impact on biological properties in soils that are 

stockpiled before reclamation.

4.8.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. However, approximately 155.4 

acres within the tract have been approved for disturbance related to recovery of coal outside of 

the A2Tr1 tract under OSMRE’s 1985 and 1989 federal MPDDs and impacts to the soils within 

the tract have already resulted from current mining activity. Therefore, under this alternative, 

disturbance related impacts to soils in the area would remain as described in section 4.8.1.1, but 

to a lesser extent (151 acres). 

4.8.2 Cumulative Effects

Cumulative effects would be related to disturbance at Dry Fork, Rawhide, Buckskin, Eagle Butte, 

Synthetic Fuels, and Wyodak mines. According to the 2013 CHIA, approximately 31,606 acres of 

land have been approved for disturbance within the northern group of mines (WDEQLQD/Lidstone 2013). Following reclamation, the replaced topsoil should support a stable and 

productive native vegetation community adequate in quantity and quality to support planned postmining land uses (i.e., rangeland and wildlife habitat). Areas within active mines are progressively 

disturbed and are progressively reclaimed. This sequence of disturbance/reclamation would 

maintain a relatively constant amount of disturbance, over time. The cumulative effects related to 

soils would be moderate and they would be extended by approximately 5.3 years.

4.8.3 Mitigation Measures

Sediment control structures would be built to trap eroded soil and revegetation would reduce 

wind erosion. Topsoil will also be protected from acid or toxic materials and will be preserved in 

a usable condition for sustaining vegetation when placed over affected land (WDEQ-LQD 2012). 

These measures are required by state regulations and are therefore considered part of the 

Proposed Action.

4.9 Vegetation

4.9.1 Direct and Indirect Effects

4.9.1.1 Proposed Action

The direct and indirect effects to vegetation would not be significantly different than those 

described in the existing DFM federal mining plan. Short-term impacts associated with the removal 
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-36

of vegetation from the A2Tr1 tract would include increased soil erosion and habitat loss for wildlife 

and livestock. Potential long-term impacts on reclaimed lands include loss of habitat or loss of 

habitat carrying capacity for some wildlife species as a result of reduced plant species diversity or 

plant density, particularly big sagebrush. However, livestock and grassland-dependent wildlife 

species would benefit from the increased grass cover and production.

Reclamation of disturbed lands within the DFM permit boundary is performed according to 

WDEQ-LQD Rules and Regulations (WDEQ-LQD 2012). Reclamation would occur 

contemporaneously with mining on adjacent lands, i.e., reclamation would begin once an area is 

mined. In an effort to approximate premining conditions, WFW would plan to reestablish 

vegetation types during the reclamation operation that are similar to the premine types. 

Reestablished vegetation would be dominated by species mandated in the reclamation seed 

mixtures (to be approved by WDEQ). The reclamation plan for the DFM includes steps to control 

invasion by weedy (invasive nonnative) plant species. Approximately 155.4 acres within the A2Tr1 

tract have been disturbed as approved by WFW’s WDEQ-LQD Permit No. PT0599 and OSMRE’s 

1985 and 1989 federal MPDDs. The direct and indirect effects related to the Proposed Action on 

vegetation would be moderate and they would be extended by approximately 5.3 years.

4.9.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. However, approximately 155.4

acres within the tract have been approved for disturbance related to recovery of coal outside of 

the A2Tr1 tract under OSMRE’s 1985 and 1989 federal MPDDs and impacts to vegetation within 

the tract have already resulted from current mining activity. Therefore, under this alternative, 

disturbance related impacts to vegetation in the area would remain as described in section 

4.9.1.1 but disturbance would be reduced by approximately 151 acres.

4.9.2 Cumulative Effects

Cumulative effects would be related to disturbance at Dry Fork, Rawhide, Buckskin, Eagle Butte, 

Synthetic Fuels, and Wyodak mines. According to the 2013 CHIA, approximately 31,606 acres of

land have been approved for disturbance within the northern group of mines 

(WDEQ-LQD/Lidstone 2013). The overall contribution to cumulative impacts to vegetation under 

Proposed Action would be minor due to the localized effects and the improved productivity on 

mined lands that have been reclaimed.

4.9.3 Mitigation Measures

No mitigation measures would be necessary for vegetation resources.

4.10 Wildlife

If the MLA mining plan modification for the DFM is approved to include recovering coal within the 

A2Tr1 tract, disturbance would continue on the A2Tr1 tract. Mining would be extended by 

approximately 5.3 years at the DFM. Impacts to wildlife that would be caused by mining the tract 

have been addressed by the WGFD and WDEQ when the mining and reclamation permits were 

amended to include the tract.

Mining directly and indirectly impacts local wildlife populations. These impacts are both short term 

(until successful reclamation is achieved) and long term (persisting beyond successful completion 

of reclamation). The direct impacts of surface coal mining on wildlife occur during mining and are 
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Dry Fork Mine A2Tr1 EA 4-37

therefore short-term. They include road kills by mine-related traffic, restrictions on wildlife 

movement created by fences, spoil piles, and pits, and displacement of wildlife from active mining 

areas. Displaced animals may find equally suitable habitat that is not occupied by other animals, 

occupy suitable habitat that is already being used by other individuals, or occupy poorer quality 

habitat than that from which they were displaced. In the second and third situations, the animals 

may suffer from increased competition with other animals and are less likely to survive and 

reproduce. If the proposed federal mining plan modification is approved, the moderate impacts to 

wildlife related to mine operations would be extended by approximately 5.3 years.

The indirect impacts are longer term. After the tract is mined and reclaimed, alterations in the 

topography and vegetative cover and diversity, particularly the reduction in sagebrush density, 

would cause a decrease in carrying capacity for some species. Sagebrush would gradually become 

reestablished on the reclaimed land, but the topographic changes would be permanent. 

Microhabitats may be reduced on reclaimed land due to flatter topography, less diverse vegetative 

cover, and reduction in sagebrush density.

The environmental consequences related to mining the A2Tr1 tract for other mammals; upland 

game birds (excluding the GRSG); other birds; and amphibians, reptiles, and aquatic species are 

not significantly different than those presented in existing DFM federal mining plan and are not 

presented herein. Updated discussions for big game, raptors, GRSG, T&E species, and other SOSI

are included below.

4.10.1 Big Game

4.10.1.1 Direct and Indirect Effects 

4.10.1.1.1 Proposed Action

Under the Proposed Action, big game would be displaced from portions of the tract to adjacent 

ranges during mining. The permit area is in winter/yearlong mule deer range, as classified by the 

WGFD in the 2015 Sheridan Region Job Completion Report (WGFD 2015). The Dry Fork Mine 

permit area is generally considered out of normal pronghorn and white-tailed deer ranges (WGFD 

2015). Through September 12, 2016, approximately 2,103 acres of these big game ranges have 

been disturbed and about 588 acres have been permanently reclaimed to primarily mixed-grassshrub habitats. 

DFM would be required to reclaim disturbed habitats within the area back to wildlife habitat, as 

outlined in the reclamation requirements of revised state and federal mine permits. After mining 

and reclamation, alterations in the topography and vegetative cover, particularly the reduction in 

sagebrush density, would cause a decrease in carrying capacity and diversity on the tract. Sagebrush 

would gradually become re-established on the reclaimed land, but the topographic changes would 

be permanent. The direct and indirect effects related to the Proposed Action on big game would 

be moderate and they would be extended by approximately 5.3 years.

4.10.1.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. However, approximately 155.4

acres within the tract have been approved for disturbance related to recovery of coal outside of 

the A2Tr1 tract under OSMRE’s 1985 and 1989 federal MPDDs and impacts to big game within 

the tract have already resulted from current mining activity. Therefore, under this alternative, 
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Dry Fork Mine A2Tr1 EA 4-38

disturbance related impacts to big game species in the area would remain as described in section 

4.10.1.1 but the extent of the impacts would be reduced by approximately 151 acres and the 

duration of the impacts would be reduced by approximately 5.3 years.

4.10.1.2 Cumulative Effects

Cumulative effects would be related to disturbance at Dry Fork, Rawhide, Buckskin, Eagle Butte, 

Synthetic Fuels, and Wyodak mines. According to the 2013 CHIA, approximately 31,606 acres of 

land have been approved for disturbance within the northern group of mines 

(WDEQ-LQD/Lidstone 2013). The overall contribution to cumulative impacts to big game species

under Proposed Action would be moderate due to the localized effects and the improved 

productivity on mined lands that have been reclaimed. No severe mine-caused mortalities have 

occurred and no long-lasting impacts on big game species have been noted on the DFM. The 

cumulative effects on regional big game populations would be moderate and they would be 

extended by approximately 5.3 years.

4.10.1.3 Mitigation Measures

No mitigation measures specific to big game are necessary. General reclamation practices for 

establishing or enhancing post‐mine wildlife habitat at the DFM described in the Reclamation Plan 

of WDEQ-LQD Permit No. PT0599 are in place. 

4.10.2 Raptors

4.10.2.1 Direct and Indirect Effects 

4.10.2.1.1 Proposed Action

Two intact raptor nests are located within the A2Tr1 tract boundaries and both nests are within 

the proposed disturbance boundary for the tract. Nest SH-4a was last active in 2007, producing 

one young. SH-4c/RTH-18 was successful in 2015 when two red-tailed hawks fledge from the nest. 

Both nests are located in trees associated with a ranch facility and home site (WFW 2016b).

WFW has an approved Raptor Management Plan in place to minimize impacts to nesting raptors 

and ensure proper reclamation techniques are implemented to enhance habitat in the post-mine 

landscape for both raptors and their primary prey species. Inactive, non-eagle raptor nests may be 

removed from areas likely to be impacted in potential disturbance areas to discourage nesting of 

raptors and other migratory birds, in accordance with USFWS guidance provided in the Migratory 

Bird Permit Memorandum (USFWS 2003). Decisions as to whether nest removal or relocation is 

the most appropriate approach would be based on the long-term history of the nest site, including 

historic and recent raptor use; presence/absence, location, and potential vulnerability of alternate 

nests within the territory; number, proximity, and/or orientation of conspecific territories; 

historical use of artificial nest structures, if any; timing, duration (e.g., continuous and ongoing or 

short-term); proximity, and visibility of potentially disturbing mine activities; and other pertinent 

factors. Various species of trees (plains cottonwood [Populus sargentii] peachleaf willow [Salix 

amygdaloides], and Rocky Mountain juniper [Juniperus scopulorum]) will be planted to provide 

potential nesting habitat.

Based on the limited number of nesting raptors within the tract (only two known intact nest) and 

the WFW’s approved plans and procedures in place to reduce impacts to raptors, the direct and 

indirect effects related to the Proposed Action on site-specific raptors would be moderate and 

they would be extended by approximately 5.3 years.
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Dry Fork Mine A2Tr1 EA 4-39

4.10.2.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. However, approximately 155.4

acres within the tract have been approved for disturbance related to recovery of coal outside of 

the A2Tr1 tract under OSMRE’s 1985 and 1989 federal MPDDs and impacts to raptors within the 

tract have already resulted from current mining activity. Therefore, under this alternative, 

disturbance related impacts to raptors in the area would remain as described in section 

4.10.2.1.1 but the extent of the impacts would be reduced by approximately 151 acres and the 

duration of the impacts would be reduced by approximately 5.3 years.

4.10.2.2 Cumulative Effects

Cumulative effects would be related to disturbance at Dry Fork, Rawhide, Buckskin, Eagle Butte, 

Synthetic Fuels, and Wyodak mines. According to the 2013 CHIA, approximately 31,606 acres of 

land have been approved for disturbance within the northern group of mines 

(WDEQ-LQD/Lidstone 2013). The overall contribution to cumulative impacts to raptors under 

Proposed Action would be moderate due to the localized effects and the improved productivity 

on mined lands that have been reclaimed. The cumulative effects on regional raptor populations

would be moderate and they would be extended by approximately 5.3 years.

4.10.2.3 Mitigation Measures

No mitigation measures specific to raptors are necessary. The approved Raptor Management Plan 

and general reclamation practices for establishing or enhancing post‐mine wildlife habitat at the 

DFM described in the Reclamation Plan of WDEQ-LQD Permit No. PT0599 are in place. WFW

also has developed plans and procedures to minimize impacts to nesting raptors and ensure proper 

reclamation techniques are implemented to enhance habitat in the post-mine landscape for raptors 

and their primary prey species.

4.10.3 Greater Sage-Grouse

4.10.3.1 Direct and Indirect Effects 

4.10.3.1.1 Proposed Action

Five historical GRSG lek sites have been documented within 3 miles of the A2Tr1 tract (map 

3-7). Three leks (Dry Fork IIA, Schiemiester, and Eagle Butte) are intact and two leks (Dry Fork I 

and Dry Fork II) have been destroyed by mining. The WGFD currently classifies the Dry Fork IIA

and Schiemiester leks as occupied and the Eagle Butte Lek as unoccupied (WGFD 2015). The Dry 

Fork IIA Lek is approximately 0.39 mile north of the A2Tr1 tract and the Schiemiester Lek is 

approximately 2.14 miles west the tract. The Dry Fork IIA Lek is within the existing permit area 

and is already subject to disturbance from previously permitted activities. This lek has not been 

attended by male GRSG since 2011. Long-term results from annual lek monitoring suggest that 

GRSG populations in the DFM annual monitoring area are cyclic, with periodic peaks and declines 

(WFW 2016b). These data suggest that the DFM area may only support larger groups of GRSG 

when regional populations are especially high (WFW 2016b).

Using mapping included in the Executive Order, it has been determined that the closest core area 

to the A2Tr1 tract is over 10 miles distant. 
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Dry Fork Mine A2Tr1 EA 4-40

WDEQ-LQD Permit No. PT0599 currently contains multiple monitoring and protection plans that 

include numerous specific measures for GRSG and their habitats, including those mentioned above. 

The WDEQ has strict bonding, reclamation, and bond-release requirements for all surface coal 

mines in Wyoming, including detailed reclamation plans and post-reclamation monitoring 

requirements that extend 10 years or more to ensure that all reclamation standards have 

successfully been met prior to full bond release. 

Potential impacts to GRSG would likely be limited primarily to indirect influences resulting from 

habitat disturbance, though loss of individual birds may occur at times. Ongoing DFM operations 

may adversely impact individual GRSG but are not likely to result in a loss of population viability 

in the wildlife monitoring area or cause a trend toward federal listing. The use of appropriate 

timing and spatial buffers, timely implementation of reclamation, and application of targeted 

conservation measures in suitable habitats both on- and off-property throughout the region are 

expected to sufficiently reduce overall impacts to maintain a viable population within the area. The 

direct and indirect effects related to the Proposed Action on GRSG would be moderate and long

term.

According to Executive Order No. 12-2015, existing land uses and activities (including those 

authorized by existing permit but not yet conducted) would be recognized and respected by state 

agencies, and those uses and activities that exist at the time the Program becomes effective would 

not be managed under the stipulations included in Executive Order No. 12-2015. Because the 

tract evaluated under the Proposed Action is entirely within the DFM’s currently approved 

WDEQ-LQD Permit No. PT0599 permit boundary, these activities would not be managed 

according to the executive order. 

4.10.3.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. However, approximately 155.4

acres within the tract have been approved for disturbance related to recovery of coal outside of 

the A2Tr1 tract under OSMRE’s 1985 and 1989 federal MPDDs and impacts to GRSG within the 

tract have already resulted from current mining activity. Therefore, under this alternative, 

disturbance related impacts to GRSG in the area would remain as described in section 4.10.3.1.1

but the extent of the impacts would be reduced by approximately 151 acres and the duration of 

the impacts would be reduced by approximately 5.3 years.

4.10.3.2 Cumulative Effects

Cumulative effects would be related to disturbance at Dry Fork, Rawhide, Buckskin, Eagle Butte, 

Synthetic Fuels, and Wyodak mines. As described in the updated 2012 Task 1D Report (BLM 

2012), substantial areas of GRSG habitats have been altered from their natural conditions as a 

result of past and on-going human activities in the Wyoming PRB study area. Human disturbances 

include, but are not limited to, agriculture, mining, roads, urban areas, and oil and gas development. 

Potential temporary impacts arise from habitat removal and disturbance associated with a project’s 

development and operation (e.g., coal mines, CBNG wells, etc.) and would cease upon project 

completion and successful reclamation in a given area. Potential long-term impacts consist of 

permanent loss of habitats and the wildlife populations that depend on those habitats, irrespective 

of reclamation success, and habitat disturbance related to longer term projects (e.g., power plant 

facilities, rail lines, etc.) (BLM 2012). The severity of both temporary and long-term impacts to 
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Dry Fork Mine A2Tr1 EA 4-41

GRSG would depend on factors such as seasonal use patterns, type and timing of a project’s 

activities, and physical parameters (e.g., topography, cover, forage, and climate).

The GRSG population in the WGFD Sheridan Region (including the A2Tr1 tract) appears to follow 

a 10-year cycle (BLM 2012). WGFD information indicated that over 42,300 male sage grouse were 

recorded 2016 in Wyoming. The average number of male grouse per lek was up 16 percent in 

2016 compared to 2015, which was 66 percent higher than 2014 (WGFD 2016). 

The cumulative effects related to the Proposed Action on regional GRSG populations would be 

moderate and long term.

4.10.3.3 Mitigation Measures

No mitigation measures specific to GRSG are necessary. The general reclamation practices for 

establishing or enhancing postmine wildlife habitat at the DFM described in the Reclamation Plan 

of WDEQ-LQD Permit No. PT0599 are in place. Shrub seedlings will be planted in shrub pockets 

in order to improve the beneficial effects of the shrubs for wildlife.

4.10.4 Threatened, Endangered, and Candidate Species and Other Species of 

Special Interest

4.10.4.1 Direct and Indirect Effects 

4.10.4.1.1 Proposed Action

The USFWS maintains a list of T&E species, and designated critical habitats on their official website 

for each county in Wyoming (USFWS 2016a). The USFWS also provides the IPaC system to 

evaluate the potential of encountering USFWS trust resources, including T&E species, related to 

a specific project area. The USFWS list of wildlife species includes the black-footed ferrets, which 

is listed as experimental, non-essential, and the northern long-eared bat, which is listed as 

threatened. The analysis area for most T&E species includes the DFM permit boundary. The 

analysis area for the northern long-eared bat includes the Campbell County boundary to consider

Hg deposition from mining and coal combustion. There are no critical habitats for these T&E 

species within the A2Tr1 tract or within Campbell County.

According to information in Yates et al. (2014), bats, including long-eared bat, captured near Hg 

point sources have a higher Hg concentration in tissue samples compared to bats captured in 

nonpoint source areas. This indicates that long-eared bats near the four coal fired power plants 

may have higher Hg concentrations in tissue. According to the USFWS, the primary threat to the 

northern long-eared bat is white-nose syndrome (WNS), a disease caused by the cold-loving 

fungus, (Pseudogymnoascus destructans) (USFWS 2016d). The northern long-eared bat is also 

threatened by the loss and degradation of summer habitat, by collision with or barotrauma (injury 

to the lungs due to a change in air pressure) caused by wind turbines, and mine closures and 

vandalism of winter roosts and hibernacula. Due to the relatively low Hg emissions that would 

result from the Proposed Action (tables 4-3 and 4-5), and the fact that Hg emissions would not 

increase over current rates, the direct and indirect effects of the Proposed Action are expected 

to be minor but they would be extended by approximately 5.3 years. The USFWS has established 

an area of influence (AOI) for the Northern long-eared bat. Any projects that would occur within 

the AOI are anticipated to have impacts on Northern long-eared bat. USFWS has a 4(d) rule for 

this species, which provides flexibility to landowners, land managers, government agencies and 

others as they conduct activities in areas that could be northern long-eared bat habitat. In areas 
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Dry Fork Mine A2Tr1 EA 4-42

of the northern long-eared bat’s range that have not yet been affected by WNS, defined as outside 

the WNS zone in the final 4(d) rule, such as in Wyoming, incidental take (unintentional harm to 

bats incidental to otherwise lawful activities) is not prohibited. Even though the final 4(d) rule 

excepts incidental take, federal agencies still have an obligation to consult on “may affect”

determinations. This obligation is addressed if the federal agency complies with measures outlined 

in the framework for the USFWS’s January 5, 2016, programmatic biological opinion (BO) on the 

final 4(d) rule. 

A portion of the proposed project as defined in this EA falls within the AOI; therefore, OSMRE 

has complied with the programmatic BO and fulfilled the Section 7 consultation requirements 

under the Endangered Species Act through submission of the Northern Long Eared Bat 4(d) rule 

streamlined consultation form to the Wyoming Ecological Field Services Office.

The most current list of birds of conservation concern presented in appendix E indicates that 

23 birds of conservation concern occur in the DFM area. The bald eagle is present on the study 

area as a migrant and winter resident as discussed previously. The Brewer’s sparrow is common 

during the spring and summer as a breeder. The ferruginous hawk nested on the DFM raptor

study area in 2015. The golden eagle is a yearlong resident and was observed on the DFM raptor 

study area in 2015 but active nests were not found. The prairie falcon was observed as a transient 

however suitable nesting habitat is not present on the site for this species. The Swainson’s hawk 

was present as a spring and summer breeder and, as discussed above, nested within the A2Tr1 

tract in 2015. The grasshopper sparrow, loggerhead shrike, sage thrasher, short-eared owl,

burrowing owl, GRSG, long-billed curlew, McCown’s longspur, and upland sandpiper have been 

recorded on the DFM wildlife study area. The American bittern, Cassin’s finch, dickcissel, Lewis 

woodpecker, mountain plover, pinyon jay, red-headed woodpecker, western grebe, and Sprague’s 

pipit have not been recorded on the study area, as habitat for most of these species does not 

occur on the study area.

If present, these species would be temporarily displaced, but current reclamation practices inplace at the DFM would promote the return of these species once reclamation has been 

completed. The direct and indirect effects related to the Proposed Action on species of special 

interest would be moderate and they would be extended by approximately 5.3 years.

4.10.4.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. However, approximately 155.4

acres within the tract have been approved for disturbance related to recovery of coal outside of 

the A2Tr1 tract under OSMRE’s 1985 and 1989 federal MPDDs and impacts to T&E species and 

other species of special interest within the tract have already resulted from current mining activity. 

Therefore, under this alternative, disturbance related impacts to these species of special interest 

in the area would remain as described in section 4.10.4.1.1 but the extent of the impacts would 

be reduced by approximately 151 acres and the duration of the impacts would be reduced by 

approximately 5.3 years.

4.10.4.2 Cumulative Effects

Cumulative effects would be related to disturbance at Dry Fork, Rawhide, Buckskin, Eagle Butte, 

Synthetic Fuels, and Wyodak mines. According to the 2013 CHIA, approximately 31,606 acres of 

land have been approved for disturbance within the northern group of mines (WDEQ-
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Dry Fork Mine A2Tr1 EA 4-43

LQD/Lidstone 2013). The overall contribution to cumulative impacts to T&E species and other 

species of special interest under Proposed Action would be moderate due to the localized effects 

and the improved productivity on mined lands that have been reclaimed. The cumulative effects 

on regional T&E species and other species of special interest populations would be moderate and 

they would be extended by approximately 5.3 years.

4.10.4.3 Mitigation Measures

No mitigation measures specific to T&E species and other species of special interest are necessary. 

General reclamation practices for establishing or enhancing post‐mine wildlife habitat at the DFM

described in the Reclamation Plan of WDEQ-LQD Permit No. PT0599 are in place.

4.11 Ownership and Use of Land

4.11.1 Direct and Indirect Effects

4.11.1.1 Proposed Action

Surface ownership in the area includes federal, state, and private lands and the proposed coal 

removal area is managed by the BLM, the State of Wyoming, and WFW. The primary adverse 

environmental consequences of mining the A2Tr1 tract on land use would be reduction of 

livestock grazing, loss of wildlife habitat, and curtailment of other mineral development on about 

151 additional acres during active mining. Disturbance has been approved on approximately 155.4

acres. Wildlife (particularly big game) use would be displaced while the tract is being mined and 

reclaimed. Livestock grazing has already been prohibited due to the tract being inside the permit 

boundary and adjacent to active mine areas. Hunting on the tract is currently not allowed because 

they are within the mine permit boundary and would continue to be disallowed during mining 

and reclamation. Following reclamation, the land would be suitable for grazing and wildlife uses, 

which are the historic land uses. The direct and indirect effects related to the ownership and use 

of the land would be moderate and they would be extended by approximately 5.3 years.

4.11.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. However, approximately 155.4

acres within the tract have been approved for disturbance related to recovery of coal outside of 

the A2Tr1 tract under OSMRE’s 1985 and 1989 federal MPDDs and impacts to ownership and 

use of the land within the tract have already resulted from current mining activity. Therefore, 

under this alternative, disturbance related impacts would remain as described in section 4.11.1.1

but disturbance would be reduced by approximately 151 acres.

4.11.2 Cumulative Effects

The cumulative impacts on ownership and use of the land would be similar to the direct and 

indirect impacts, discussed above.

4.11.3 Mitigation Measures

No mitigation measures specific to ownership and use of the land are necessary.
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Dry Fork Mine A2Tr1 EA 4-44

4.12 Cultural Resources

4.12.1 Direct and Indirect Effects

4.12.1.1 Proposed Action

Information regarding background cultural resources within the current DFM WDEQ-LQD 

PT0599 permit boundary was summarized from Appendices D-2.2 (Historic Cultural Resources 

Inventory, Amendment 2 Area) and D-3.2 (Prehistoric and Paleontological Resources Inventory, 

Amendment 2 Area) of the DFM Permit No. PT0599 (WFW 2011). According to information 

provided in these appendices, six cultural resources sites (48CA1134, 48CA1300, 48CA1302, 

48CA1565, 48CA7048, and 48CA7049) were identified in the overall Amendment 2 survey area, 

which includes the A2Tr1 tract. Only two of the six cultural resources sites (48CA7048, and 

48CA7049) were identified within the A2Tr1 tract. Both sites are associated with historic activity 

(post-1920 era) and both sites are ineligible for listing on the National Register of Historic Places 

(NRHP) and do not require further investigation (OSMRE 2011). The direct and indirect effects 

on cultural resource from the Proposed Action would be negligible but long term.

As stated in section 3.11, 30 Native American tribes/tribal representatives were consulted during 

the scoping process. OSMRE received responses from the Comanche Nation and the Cheyenne 

Arapaho. The Comanche Nation responded that “No Properties” were identified within the 

proposed project boundary. The Cheyenne Arapaho THPO requested more information 

regarding the project to which OSMRE responded by providing a project map and other project 

material. On May 23, 2017, OSMRE received a response from the Cheyenne Arapaho stating that 

“No Properties” were identified within the proposed project boundary.

4.12.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. However, approximately 155.4 

acres within the tract have been approved for disturbance related to recovery of coal outside of 

the A2Tr1 tract under OSMRE’s 1985 and 1989 federal MPDDs and impacts to cultural resources 

within the tract have already resulted from current mining activity. Therefore, under this 

alternative, disturbance related impacts would remain as described in section 4.12.1.1 but 

disturbance would be reduced by approximately 151 acres.

4.12.2 Cumulative Effects

The individual evaluation of cultural resource sites in the WFW study area suggests that through 

avoidance of sensitive site types and mitigation through data recovery for all unavoidable 

disturbance to NRHP eligible sites, the cumulative effects to cultural resources have been minor. 

The cumulative impacts on cultural resource would be negligible but long term.

4.12.3 Mitigation Measures

No mitigation measures specific to cultural resources are necessary.

4.12.4 Unanticipated Discoveries 

If a previously unidentified cultural resource is discovered in the Project Area, WFW would take 

measures to protect the find locality and provide written notice to WDEQ and the OSMRE within 

48 hours of the discovery. A Wyoming-permitted archaeologist meeting the Secretary of the 

Interior’s Professional Qualification Standards would, as soon as possible, evaluate the discovery, 
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Dry Fork Mine A2Tr1 EA 4-45

make a recommendation as to the NRHP eligibility of the resource, and provide written notice to 

WDEQ and the OSMRE within 48 hours. The WDEQ-LQD and OSMRE would then consult with 

the Tribal Historic Preservation Office (THPO), SHPO, and the BLM (for federally managed sites) 

on the NRHP eligibility determination(s) and develop appropriate measures necessary to mitigate 

any adverse effects through the development of a treatment plan. 

Should the discovery involve a burial or a resource thought to have potential religious and cultural 

significance, the tribe(s) with an interest would be notified and consulted as appropriate. When 

agreement is reached among all of the involved parties, the appropriate mitigation, if necessary, 

would be implemented. The tribes, OSMRE, WDEQ-LQD, SHPO, and the surface landowner must 

agree to any proposed treatment measures.

4.13 Noise

4.13.1 Direct and Indirect Effects 

4.13.1.1 Proposed Action

Existing noise sources in the A2Tr1 tract area includes coal mining activities, rail traffic, traffic on 

nearby federal and state highways, county and access roads, natural gas compressor stations, and 

wind. The nearest residence is approximately 1,900 feet from the A2Tr1 tract and the Garner Lake 

Road passes through the A2Tr1 tract and is immediately adjacent to the disturbance limit proposed 

to recover the coal within the tract. Noise levels in wildlife habitat adjacent to the expansion area 

might increase, but anecdotal observations indicate wildlife can adapt to mine noise, especially 

since similar mining operations have been conducted in the area for many years. No increase in 

average daily railroad traffic or railroad noise would occur under any of the alternatives analyzed.

Given the proposed distance from active mining, direct and indirect effects to residences would be 

moderate and short term. Impacts to people using the Garner Lake Road would increase over 

current conditions but would be minor considering the short duration of noise exposure.

4.13.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. However, approximately 155.4 

acres within the tract have been approved for disturbance related to recovery of coal outside of 

the A2Tr1 tract under OSMRE’s 1985 and 1989 federal MPDDs and impacts from noise within 

the tract have already resulted from current mining activity. Distance to disturbance would be less 

than the Proposed Action. Therefore, under this alternative, noise impacts would remain as 

described in section 4.13.1.1 but the extent of the impacts would be reduced by approximately 

151 acres and the duration of the impacts would be reduced by approximately 5.3 years.

4.13.2 Cumulative Effects

Cumulative effects would be related to disturbance at Dry Fork, Rawhide, Buckskin, Eagle Butte, 

Synthetic Fuels, and Wyodak mines. Potential sources of noise disturbances include, but are not 

limited to, agriculture, mining, roads, urban areas, and oil and gas development. Potential impacts 

would cease upon project completion and successful reclamation in a given area. 

Recreational users, local residents and grazing lessees using lands surrounding active mining areas 

do hear mining-related noise, but this has not been reported to cause a substantial impact. Wildlife 

in the immediate vicinity of mining may be adversely affected by noise; however, observations at 
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Dry Fork Mine A2Tr1 EA 4-46

the DFM indicate that wildlife generally adapt to noise conditions associated with active coal 

mining. The cumulative impacts related to noise as discerned by the public would be moderate but 

short term (5.3 years).

4.13.3 Mitigation Measures

No mitigation measures specific to noise impacts are necessary.

4.14 Visual Resources

4.14.1 Direct and Indirect Effects 

4.14.1.1 Proposed Action

Mining would affect landscapes classified by the BLM as visual resource management Class IV; the 

overall natural scenic quality of that class rating is considered relatively low. Impacts of coal mining 

on visibility in the general analysis area would be minor and short-term. Mining activities would be 

visible from State Highway 59 and the Garner Lake Road (County Road 38N), though the extent 

and duration of visibility would vary under the Proposed Action. No unique visual resources have 

been identified in or near the general analysis area, and the landscape character would not be 

significantly changed following reclamation. Current mining activities (blasting procedures and 

sizes, coal haul rates and distances, dust suppression, etc.) at the DFM would not change if the 

federal mining plan modification is approved. Current best available control technology measures 

for particulates that could contribute to impaired visibility would continue to be employed. While 

the direct and indirect effects related to the visual resources on the general area would be minor 

due to the ongoing mining activities in the area, the direct and indirect effect specific to the 

project area would be moderate but long term.

4.14.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. However, approximately 155.4 

acres within the tract have been approved for disturbance related to recovery of coal outside of 

the A2Tr1 tract under OSMRE’s 1985 and 1989 federal MPDDs and impacts to visual resources 

within the tract have already resulted from current mining activity. Therefore, under this 

alternative, disturbance related impacts would remain as described in section 4.14.1.1 but the 

extent of the impacts would be reduced by approximately 151 acres and the duration of the 

impacts would be reduced by approximately 5.3 years.

4.14.2 Cumulative Effects

Cumulative visual resources effects would be related to disturbance at Dry Fork, Rawhide, 

Buckskin, Eagle Butte, Synthetic Fuels, and Wyodak mines. Human disturbances include, but are 

not limited to, agriculture, mining, roads, urban areas, and oil and gas development. Potential 

temporary impacts arise from disturbance associated with a project’s development and operation 

(e.g., coal mines, CBNG wells, etc.) and would cease upon project completion and successful 

reclamation in a given area. Potential long-term impacts consist of permanent changes to existing 

topography and the vegetative component of the area, irrespective of reclamation success. The 

cumulative effects related to the visual resources would be moderate but long term.

4.14.3 Mitigation Measures

No mitigation measures specific to visual resources are necessary.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-47

4.15 Transportation Facilities

4.15.1 Direct and Indirect Effects 

4.15.1.1 Proposed Action

Major roads and railroads in the general area of the A2Tr1 tract are presented on map 1-2. Existing

transportation facilities, including roads, railroads, coal conveyors, and overhead electrical

transmission lines associated with the A2Tr1 tract (map 3-11) would continue to be used under

the Proposed Action. A majority of the coal mined at the DFM is transported by rail (BNSF 

trackage), with approximately 33 percent transported to the adjacent DFS via an overland 

conveyor system. Based on an estimated annual production rate of 4 Mt of coal shipped by rail 

and an estimated 15,470 tons of coal per train, the Proposed Action would result in approximately 

260 train trips per year (one way). Employees and vendors travel the Garner Lake Road to access 

the mine. No traffic count data are available for the road but the Proposed Action will not result 

in increased mine related traffic. Therefore, mining the A2Tr1 tract would not increase the current 

level of impact on the Garner Lake Road or the BNSF railroad.

As discussed in section 3.4.7.4, the potential for emissions of dust from the large volumes of 

coal transported to large generating stations can be an environmental concern (Ramboll Environ 

2016). Coal dust and fines blowing or sifting from moving, loaded rail cars has been linked to 

railroad track stability problems resulting in train derailments and to rangeland fires caused by 

spontaneous combustion of accumulated coal dust (BLM 2009). In response to suits brought on 

by environmental groups alleging that coal spilled from trains pollutes waterways, BNSF Railway 

has agreed to study the use of physical covers for coal trains to reduce the effects of blowing coal 

particles (Seattle Times 2016). BNSF has cited studies and experience to demonstrate that 

shippers can take steps in the loading of coal cars using existing, cost-effective technology that will 

substantially reduce coal dusting events. BNSF has a Coal Loading Rule, in effect since October 

2011, specifically requiring all shippers loading coal at any Montana or Wyoming mine to take 

measures to load cars in such a way that ensures coal dust losses in transit are reduced by at least 

85% compared to cars where no remedial measures have been taken (BNSF 2016).

Two recent Australian studies involved measuring particle concentrations in the air near a coal 

haul transport corridor to assess whether coal dust was being emitted from the railcars and 

whether any such emissions would result in particulate matter concentrations that would be 

considered potentially harmful to human health. The two reports presented strong evidence that, 

while particulate levels were elevated for the several minutes during and after trains passed the 

monitoring station, coal trains did not result in any more emissions than any other freight-hauling 

trains (Ramboll Environ 2016). Rail traffic to and from the mines would continue at existing levels 

for an additional 5.3 years since coal recovery would continue at an estimated annual rate that is 

consistent with the 2009 through 2016 average annual recovery rate.

The Dry Fork Mine has cooperated with BNSF by implementing dust controlling modifications at 

its load out system. The mine also operates a coal topper facility that sprays a BNSF-approved 

dust control agent on each car as specified in the individual coal contracts.

The continuation of mining on tract analyzed in this EA would extend the time period over which 

WFW would produce coal, which would extend the period of time coal would be transported 

from the mine. The added direct and indirect effects of the Proposed Action on transportation

would be minor but they would be extended by approximately 5.3 years.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-48

4.15.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. Indirect impacts on 

transportation have resulted from current mining activity. Therefore, under this alternative, 

transportation impacts in the area would remain as described in section 4.15.1.1 but the duration 

of the impacts would be reduced by approximately 5.3 years.

4.15.2 Cumulative Effects

Cumulative impacts to transportation are related to coal production levels. If coal production 

levels increase, cumulative impacts to transportation would increase. Highway traffic accidents and 

delays at grade crossings could result from train traffic. The transportation facilities for the 

northern group of mines are already in place, and coal production and employment levels would 

not change with the Proposed Action. The Proposed Action would extend the duration of mining 

by approximately 5.3 years at the DFM, and thus the length of employment and associated 

transportation utilization would be extended. 

Coal extracted from the existing surface coal mines in the Wyoming PRB is transported in rail 

cars along the BNSF and UP rail lines. The coal mines north of Gillette, including the DFM, ship 

most of their coal via the east-west BNSF rail line that runs through Gillette for destinations in 

the Midwest. The coal mines south of Gillette ship most of their coal via the Gillette to Douglas 

BNSF and UP joint trackage that runs south through Campbell and Converse Counties and then 

east over separate BNSF and UP mainlines for destinations in the Midwest. The Proposed Action 

would extend the duration of mining by approximately 5.3 years at the DFM, and thus the duration 

of utilization of BNSF and UP rail lines would be extended by that amount.

The added cumulative impacts related to transportation would be minor but they would be 

extended by approximately 5.3 years.

4.15.3 Mitigation Measures

No mitigation measures specific to transportation are necessary.

4.16 Hazardous and Solid Waste

4.16.1 Direct and Indirect Effects 

4.16.1.1 Proposed Action

Wastes classified as non-hazardous, hazardous, and universal are generated during mining 

operations at the DFM. DFM does not have an on-site solid waste landfill. Most waste generated 

at the mine is disposed of offsite at the Campbell County Municipal Landfill. General mining wastes 

are disposed in the municipal landfill only if generated on site, and only if non-hazardous per 

regulation under RCRA. No hazardous wastes are transported to the municipal landfill or any onsite solid waste pits. Scrap metal, tires, batteries, used filters, computers, and most wood pallets 

are recycled. Used filters are drained, crushed and recycled. Fifty-five-gallon drums and totes are

properly emptied, cleaned and are then are recycled. Spent lead acid batteries and fluorescent 

lamps are stored in designated areas with secondary containment for periodic shipment to an 

approved recycling vendor. The DFM mine operates an onsite landfarm for treatment of oil or 

glycol contaminated soils. Disposal sites will be located at least 25 feet away from the edges of 

reclaimed stream channels. Wastes will be covered to a depth of at least 4 feet below the backfill 

surface prior to applying topsoil (WFW 2011). While coal mining and associated coal processing 

associated with the Proposed Action would yield additional coal waste, mining wastes are currently 
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-49

being generated on site and are handled according to WDEQ-LQD rules and regulations. No 

increase in direct or indirect effects from hazardous and solid waste are anticipated as a result of 

the Proposed Action. The added direct and indirect effects of the Proposed Action from hazardous 

wastes would be minor but they would be extended by approximately 5.3 years.

4.16.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. Hazardous and solid wastes 

are currently being generated at the DFM. Therefore, under this alternative, impacts from 

hazardous and solid wastes in the area would remain as described in section 4.16.1.1 but the 

duration of the impacts would be reduced by approximately 5.3 years.

4.16.2 Cumulative Effects

Cumulative hazardous and solid wastes effects would be related to disturbance at Dry Fork, 

Rawhide, Buckskin, Eagle Butte, Synthetic Fuels, and Wyodak mines. The Proposed Action would 

extend the duration of mining by approximately 5.3 years at the DFM and, thus, the duration of 

effects from hazardous and solid wastes would be extended.

4.16.3 Mitigation Measures

No mitigation measures specific to hazardous and solid wastes are necessary.

4.17 Socioeconomics

4.17.1 Direct and Indirect Effects 

4.17.1.1 Proposed Action

Wyoming, Campbell County, Campbell County School District 1, the City of Gillette, and many 

other governmental entities across the state receive revenues derived directly and indirectly from 

taxes and royalties on the production of federal coal, including that at the DFM. Such revenues 

include lease bonus bids, ad valorem taxes, severance taxes, royalty payments, sales and use taxes 

on equipment and other taxable purchases, and portions of required contributions to the federal 

AML program and Black Lung Disability Trust Fund. A summary of federal and state revenues 

generated from recovery of federal coal within the DFM, including federal coal within the A2Tr1 

tract, is provided in table 4-9 and table 4-10 provides an estimate of the revenues derived from

recovering the federal coal within the A2Tr1 tract, only.

Table 4-9. LOM Federal and State Revenues from Federal Coal Recovery within 

the DFM

Revenue Source Total $ Collected Federal Revenue State Revenue

Federal Mineral Royalties 171.5 85.8 85.8

Abandoned Mine Lands Fund 29.0 14.5 14.5

Severance Tax 70.0 --

1

70.0

Bonus Bid Annual Revenues20.0 0.0 0.0

Ad Valorem Tax 57.0 --

1

57.0

Black Lung 57.0 57.0 --

1

Sales and Use Tax 8.3 --

1

8.3

Totals $392.8 $157.3 $235.6

1 No revenues disbursed

2 No bonus bid revenues collected after 2016

Source: WWC calculation – provided in appendix F.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-50

Table 4-10. LOM Federal and State Revenues from Federal Coal Recovery within 

the A2Tr1 Tract

Revenue Source Total $ 

Collected Federal Revenue State Revenue

Federal Mineral Royalties 53.6 26.8 26.8

Abandoned Mine Lands Fund 9.1 4.5 4.5

Severance Tax 20.9 --

1

21.0

Bonus Bid Annual Revenues20.0 0.0 0.0

Ad Valorem Tax 17.8 --

1

17.8

Black Lung 17.8 17.8 --

1

Sales and Use Tax 2.6 --

1

2.6

Totals $121.8 $49.1 $72.7

1 No revenues disbursed

2 No bonus bid revenues collected after 2016

Source: WWC calculation – provided in appendix F.

Under the Proposed Action, LOM Wyoming revenues could be increased by approximately $72.7

million and federal revenues could be increased by $49.1 million. The primary difference between 

state and federal revenues is related to the fact that severance taxes are only paid to the state of 

Wyoming. The Proposed Action would extend the duration of the economic impacts related to 

mining the federal coal.

Continued mining in the A2Tr1 tract would not directly create new jobs and therefore, the 

availability of housing units would not be impacted. No additional employees are anticipated as a 

result of the tract being mined, although the Proposed Action would extend the duration of 

employment for current employees and extend the economic impacts related to mining the federal 

coal.

No additional changes in the current socioeconomic situation, as described in section 3.16, are 

anticipated but the effects would be extended by approximately 5.3 years.

4.17.1.2 No Action Alternative

Under the No Action Alternative, OSMRE would not approve the modification of the existing 

federal mining plan to recover the coal included in the A2Tr1 tract. In terms of coal conservation; 

the No Action Alternative would mean that approximately 32 Mt of federal coal within the A2Tr1 

tract would not be recovered. Wyoming revenues of approximately $72.7 million and federal 

revenues of approximately $49.1 million related to this coal would not be realized over the LOM 

under the No Action Alternative. The selection of the No Action Alternative would likely not 

result in direct job losses. It is likely that state funded programs and services would be affected by 

the loss of the revenue and fewer abandoned mine lands and black lung fees would be collected. 

The No Action Alternative would not extend the LOM by 5.3 years resulting in moderate direct 

and indirect socioeconomic effects.

4.17.2 Cumulative Effects

Cumulative effects would be related to socioeconomic conditions in Campbell County. Cumulative 

impacts related to the Proposed Action are not significantly different than those described in 

section 4.17.1.1 because Wyoming, Campbell County, Campbell County School District 1, the 

City of Gillette, and many other governmental entities across the state receive revenues derived 

directly and indirectly from taxes and royalties on the production of federal coal from Campbell 

County. The cumulative effects on socioeconomics are expected to be moderate and long term.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-51

4.17.3 Mitigation Measures

No mitigation measures specific to socioeconomic impacts are needed.

4.18 Short Term Uses and Long Term Productivity

This section relates to the balance or trade-off between short-term uses and long-term productivity 

for each resource in relation to the Proposed Action. However, the discussions contained

throughout this environmental consequences chapter and in the existing DFM federal mining plan

provide adequate analyses and relationships of shorter uses (such as mining coal) and long-term

productivity (such as generating electricity for homes, schools, and industry).

4.19 Unavoidable Adverse Effects

Unavoidable adverse impacts are the effects on natural and human resources that would remain 

after mitigation measures have been applied. For the Proposed Action, details regarding these

impacts are presented in the preceding resource sections and the existing DFM federal mining 

plan. Unavoidable adverse effects are summarized in table 4-11.

Table 4-11. Unavoidable Adverse Effects of the Proposed Action

Resource Unavoidable Adverse Effect

Topography and

Physiography

Topographic effects of mining are unavoidable because mining activities such as blasting, 

excavating, loading and hauling of overburden and coal are required to recover coal in 

an economical manner.

Geology, Mineral

Resources and

Paleontology

Geology, mineral resources and buried paleontological resources may be permanently

impacted by mining activities. Such impacts are unavoidable as the resources are not

locatable and, therefore, cannot be avoided by construction.

Air Quality/GHGs Emissions and associated impacts are unavoidable, but are not expected to degrade 

ambient air quality in the area. Mined coal is primarily used for combustion; therefore,

any associated GHG emissions are unavoidable if the Proposed Action is implemented.

Water Resources Impacts to water resources resulting from coal extraction are unavoidable. However,

these impacts would be mitigated through replacement of groundwater or surface water 

supplies for domestic, agricultural, industrial, or any other legitimate use if such a supply 

is diminished, interrupted, or contaminated, to the extent of precluding use of the water, 

as a result of mining.

Soil Soil in disturbance areas would exhibit more homogenous textures and may have coarser

fragments near the surface following mining. Some soil loss may occur

as a result of erosion, prior to stabilization.

Vegetation Vegetation would be eliminated beginning with the initial disturbance and continuing until

reclamation is complete, which would extend to the end of the mining term for many

facilities. Noxious weeds may be introduced as a result of mining activity, potentially

affecting vegetation communities and requiring implementation of control measures in 

the long term.

Wildlife Wildlife would be temporarily affected by mine activities, which would alter habitat 

conditions, particularly in the vicinity of surface disturbance. These impacts would be

short-term and habitats would be reclaimed following mining.

Cultural Resources No sites within the A2Tr1 tract have been designated as eligible for listing on the NRHP. 

Undiscovered cultural resources could be impacted by surface disturbing activities. All 

discovered sites would be mitigated as required by Section 106 of the NHPA. 

Visual Resources Mining activity and associated disturbances and facilities would unavoidably alter the

landscape during the mining term, affecting the aesthetic qualities. Some features would

be visible from public access points, including the Garner Lake Road. The effects would

be negligible following reclamation.
Chapter 4 – Environmental Consequences/Cumulative Impacts

Dry Fork Mine A2Tr1 EA 4-52

Table 4-11. Unavoidable Adverse Effects of the Proposed Action (Continued)

Resource Unavoidable Adverse Effect

Noise Noise would result from mining activities similar to the existing condition. 

Transportation

Facilities

The Garner Lake Road would continue to experience mine related traffic. The effects

would occur during the mining term.

Hazardous and Solid

Waste

Coal mining and associated with coal processing would yield coal waste.
Chapter 5 – Consultation and Coordination

Dry Fork Mine A2Tr1 EA 5-1

5.0 Consultation and Coordination

5.1 Public Comment Process 

OSMRE developed a project specific website that provided legal notices, outreach notice letters, 

mailing address, and an email address for comments to be sent. The website was activated on 

March 9, 2016 and was available at: http://www.wrcc.osmre.gov/initiatives/DryForkMineA2.shtm.

OSMRE published legal notices of intent (NOIs) in the Gillette News Record on March 9 and 

March 23, 2016. Public outreach letters describing the EA and soliciting scoping comments were 

mailed on March 9, 2016 to city governments, adjacent landowners, and other interested parties. 

The legal notices and letters invited the public to comment on issues of concern related to the 

EA. OSMRE also sent letters of notification to tribes/tribal representatives. These tribal 

notification letters were mailed on March 9, 2016.

A total of 29 comment letters were received during the public scoping period. Comment letters 

received during the public review period for this EA will be considered during the ASLM approval 

process. Appendix B presents a summary of the substantive EA scoping comments.

5.2 Preparers and Contributors

OSMRE personnel that contributed to the development of this EA are listed in table 5-1.

Table 5-1. OSMRE Personnel

Name Organization Project Responsibility

Logan Sholar OSMRE Project Lead/Project Coordination

Lauren Mitchell OSMRE Project Assistance

Gretchen Pinkham OSMRE Air Quality

Karen Jass OSMRE Geology/Physiology/Topography

Jeremy Iliff OSMRE Cultural/Historical/Paleontological

Flynn Dickinson OSMRE Water

Jacob Mulinix OSMRE Soils

Third party contractors who contributed to the development of this EA are identified in table

5-2.

Table 5-2. Third Party Contractor Personnel

Name Organization Project

Responsibility Education/Experience

John Berry WWC Engineering Project Manager,

Primary Author B.S. Wildlife Management

Sarah Myers WWC Engineering Document Preparation B.S. Civil Engineering, PE

Chris McDowell WWC Engineering Document Preparation, Quality 

Assurance/Quality Control B.S. Geology

Beth Kelly WWC Engineering Quality Assurance/Quality Control B.S. Chemical Engineering
Chapter 5 – Consultation and Coordination

Dry Fork Mine A2Tr1 EA 5-2

5.3 Distribution of the EA

This EA will be distributed to individuals who specifically request a copy of the document. It will 

also be made available electronically on the OSMRE website at 

https://www.wrcc.osmre.gov/initiatives/dryForkMineA2.shtm.
Chapter 6 – References and Abbreviations/Acronyms

Dry Fork Mine A2Tr1 EA 6-1

6.0 References and Abbreviations/Acronyms

6.1 References

4Rail, 2017. 4rail.net - BNSF Locomotives. Available on the internet as of April 2017: 

http://www.4rail.net/reference_nam_bnsf_locos1.php

AirNow, 2017, Outdoor Air Quality Data. Air Quality Index Report. Available from website on 

the Internet as of January 2017: https://www.epa.gov/outdoor-air-quality-data/air-qualityindex-report.

Ayers, R.S. and D.W. Westcot, 1976, Water Quality for Agriculture. Available from website as 

of January 2017: 

http://www.waterboards.ca.gov/water_issues/programs/tmdl/records/state_board/1985/

ref2648.pdf.

Basin Electric Power Cooperative, 2016, Laramie River Station, Available from website on the 

Internet as of December 19, 2016: https://www.basinelectric.com/Facilities/LaramieRiver/.

BNSF 2016, BNSF Railway Statement on STB Coal Dust Decision. Available on the internet as 

of April 2017: http://www.bnsf.com/customers/what-can-i-ship/coal/coal-dust.html

Bureau of Land Management (BLM), 1974, Final Environmental Impact Statement, Eastern 

Powder River Coal Basin of Wyoming. U.S. Department of the Interior, Bureau of Land 

Management. Document not yet available on BLM E-Planning Website. Electronic copy 

available on request from OSMRE.

Bureau of Land Management (BLM), 1981, Final Environmental Impact Statement, Powder River 

Coal Region, U.S. Department of the Interior, Bureau of Land Management. December 

1981. Document not yet available on BLM E-Planning Website. Electronic copy available 

on request from OSMRE.

Bureau of Land Management (BLM), 1984, Draft Environmental Impact Statement for Round II 

Coal Lease Sale in the Powder River Region. USDI, BLM. Available on the Internet as of 

January 2017: https://archive.org/details/draftenvironment3623unit. 

Bureau of Land Management (BLM), 2010, Master Title Plats, Available from website on the 

Internet as of December 19, 2016: https://www.wy.blm.gov/mtps/search.php.

Bureau of Land Management (BLM), 2009. Environmental Impact Statement for the South 

Gillette Area Coal Lease Applications WYW172585, WYW173360, WYW172657, 

WYW161248. Document not yet available on BLM E-Planning Website. Electronic copy 

available on request from OSMRE.

Bureau of Land Management (BLM), 2010, Master Title Plats, Available from website on the 

Internet as of December 19, 2016: https://www.wy.blm.gov/mtps/search.php .
Chapter 6 – References and Abbreviations/Acronyms

Dry Fork Mine A2Tr1 EA 6-2

Bureau of Land Management (BLM), 2012, Powder River Basin Coal Review, Task 15 Wildlife, 

Prepared for the BLM State Office and BLM Wyoming Casper Field Office. 

https://www.wy.blm.gov/mtps/search.php.

Bureau of Land Management (BLM), 2014, Powder River Basin Coal Review—Prepared for the 

BLM State Office and BLM Wyoming Casper Field Office. 

https://www.wy.blm.gov/mtps/search.php.

Bureau of Land Management (BLM), 2015a, Record of Decision and Approved Resource 

Management Plan Attachment 6. Document not yet available on BLM E-Planning 

Website. Electronic copy available on request from OSMRE.

Bureau of Land Management (BLM), 2015b, Record of Decision and Approved Resource 

Management Plan Amendments for the Rocky Mountain Region, Including the Greater 

Sage-Grouse Sub-Regions. Document not yet available on BLM E-Planning Website. 

Electronic copy available on request from OSMRE. 

Carter Lake Consulting, LLC, 2011, Ambient Air Quality Analysis for the Western Fuels 

Wyoming, Inc Dry Fork Mine, February 9, 2011. Electronic Copy Only. Available on 

request from OSMRE.

Campbell County, 2013, Campbell County, Wyoming 2013 Comprehensive Plan. Available on 

the Internet as of April 2017: https://www.ccgov.net/DocumentCenter/Home/View/227.

Commission for Environmental Cooperation (CEC), 2011, North American Power Plant Air 

Emissions. Available on the Internet as of April 2017: 

http://www3.cec.org/islandora/en/item/10236-north-american-power-plant-airemissions-en.pdf.

Chapman, S. S., S. A. Bryce, J. M. Omernik, D. G. Despain, J. Zumberge, and M. Conrad, 2004, 

Ecoregions of Wyoming (color poster with map, descriptive text, summary tables, and 

photographs): Reston, VA, U.S. Geological Survey (map scale 1:1,400,000). Available 

from website on the Internet as of February 2017: 

ftp://newftp.epa.gov/EPADataCommons/ORD/Ecoregions/wy/wy_eco_pg.pdf.

Curtis, J. and K. Grimes, 2004, Wyoming Climate Atlas. Available from website on the Internet 

as of December 2016: http://www.wrds.uwyo.edu/sco/climateatlas. 

Fenneman, Nevin M., 1931, Physiography of Western United States, McGraw-Hill, pages 54-60.

Flores, R.M., A.M. Ochs, L.R. Bader, R.C. Johnson, and D. Vogler, 1999, Framework Geology of 

the Fort Union Coal in the Powder River Basin, in U.S. Geological Survey Professional 

Paper 1625-A.

Government Publishing Office (GPO), 2011, 43 CFR Part 46 – Implementation of the National 

Environmental Policy Act of 1969. Available on the internet as of December 2016: 

http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title43/43cfr46_main_02.tpl.
Chapter 6 – References and Abbreviations/Acronyms

Dry Fork Mine A2Tr1 EA 6-3

Hodson, W.G., R.H. Pearl, and S.A. Druse, 1973, Water Resources of the Powder River Basin 

and Adjacent Areas, Northeastern Wyoming. USGS Hydrologic Investigations Atlas HA465.

Interagency Monitoring of Protected Environments (IMPROVE), 2016, Data Acquired from 

Interagency Monitoring of Protected Visual Environments. Available on the Internet as 

of January 2017: http://vista.cira.colostate.edu/improve/. 

IPCC, 2014, Climate Change 2014: Synthesis Report. Contribution of Working Groups I, II and

III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change 

[Core Writing Team, R.K. Pachauri and L.A. Meyer (eds.)]. IPCC, Geneva, Switzerland, 

151 pp. Available on the Internet as of January 2017:

https://www.ipcc.ch/pdf/assessment-report/ar5/syr/SYR_AR5_FINAL_full_wcover.pdf.

John T. Boyd Company, 2011, Powder River Basin Coal Resource and Cost Study, Campbell, 

Converse and Sheridan Counties Wyoming, Big Horn, Powder River, Rosebud and 

Treasure Counties, Montana. September 2011.

Keefer, William R., 1974, Regional Topography, Physiography, and Geology of the Northern 

Great Plains: U.S. Geol. Survey Open File Report 74-50.

Kimley-Horn and Associates, 2008, Table 1 from Club Estates Exterior Noise Analysis, 

Prepared by Kimley-Horn and Associates. Available from website as of February 2017: 

http://www.sandiegocounty.gov/dplu/docs/081024/TM5499-NOISE-T.pdf.

Lewis, Barney D., and William R. Hotchkiss, 1981, Thickness, Percent Sand, and Configuration 

of Shallow Hydrogeologic Units in the Powder River Basin, Montana and Wyoming: U.S. 

Geol. Survey.

Niering, William A., 1985, Wetlands: National Audubon Society Nature Guides. Electronic 

Copy Only. Available on request from OSMRE.

NRCS (USDA Natural Resources Conservation Service), 2016, Web Soil Survey (WSS) 

database. Available from website as of October 7, 2016: 

https://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm.

Office of the Governor, 2015, State of Wyoming Executive Department Executive Order 2015-

4, Greater Sage-Grouse Core Area Protection, July 29, 2015, Available from website as 

of January 2017: http://governor.wyo.gov/documents/executive-orders.

Office of Surface Mining Reclamation and Enforcement (OSMRE), 1989, Handbook on 

Procedures for Implementing the National Environmental Policy Act of 1969. March 

1989.

Office of Surface Mining Reclamation and Enforcement (OSMRE), 1999, REG-31 881-

Preparation of Mining Plan Decision Documents. Available from website as of January 

2017: http://www.osmre.gov/lrg/directives.shtm. 
Chapter 6 – References and Abbreviations/Acronyms

Dry Fork Mine A2Tr1 EA 6-4

Office of Surface Mining Reclamation and Enforcement (OSMRE), 2011, Cultural Resources 

SHPO Findings. Electronic Copy Only. Available on request from OSMRE.

Office of Surface Mining Reclamation and Enforcement (OSMRE), 2016, Reclamation 

Performance Bonds: Bonding Overview. Available from website as of January 2017: 

https://www.osmre.gov/resources/bonds/bondsoverview.shtm.

Pace, Thomas G., 2005, Examination of the Multiplier Used to Estimate PM2.5 Fugitive Dust 

Emissions from PM10. Available from website as of May 2016: 

http://www3.epa.gov/ttnchie1/conference/ei14/session5/pace_pres.pdf.

Pitchford, M.L., and W.C. Malm, 1994, Development and Applications of a Standard Visual 

Index. Atmospheric Environment 28(5):1,049–1,054.

Ramboll Environ, 2016, Coal Dust from Rail Transport. Available from website as of April 2017: 

https://ngskmc-eis.net/wp-content/uploads/2016/09/NGS-KMC-Railroad-Coal-DustWhite-Paper-2016.1.16.pdf.

Rose, S.K., D. Turner, G. Blanford, J. Bistline, F. de la Chesnaye, and T. Wilson. Understanding 

the Social Cost of Carbon: A Technical Assessment. EPRI, Palo Alto, CA: 2014. Report 

#3002004657.

Seattle Times (2016), BNSF to Study Coal Covers Under Tentative Lawsuit Agreement. 

Available on the internet as of April 2017: http://www.seattletimes.com/seattlenews/environment/enviros-bnsf-railway-reach-agreement-in-coal-dust-lawsuit/

Shelanski, H., M. Obstfeld. 2015. Estimating the Benefits from Carbon Dioxide Emissions 

Reductions. https://obamawhitehouse.archives.gov/blog/2015/07/02/estimating-benefitscarbon-dioxide-emissions-reductions

SNL Financial, 2016, Dry Fork Station Plant Environmental Profile. Electronic Copy Only. 

Available on request from OSMRE.

U.S. Army Corps of Engineers (USACE), 2012, Correspondence from Matthew A. Bilodeau 

(Program Manager USACE Wyoming Regional Office) to Beth Goodnough, Director of 

Regulatory Affairs Western Fuels-Wyoming, Inc. March 19, 2012. 

U.S. Census Bureau, 2016, Community Facts-Find popular facts and frequently requested data 

about your community – Campbell County, Wyoming. Available from website as of 

February 2017: https://factfinder.census.gov/faces/nav/jsf/pages/community_facts.xhtml.

U.S. Census Bureau, 2017, Annual Estimates of the Resident Population: April 1, 2010 to July 1, 

2015. Available on the Internet as of April 2017: 

https://factfinder.census.gov/faces/nav/jsf/pages/community_facts.xhtml

U.S. Department of Energy (USDOE), 2016, National Energy Technology Laboratory. Coal and 

Biomass Coal Ranks. Available from website as of February 2017: 

https://www.netl.doe.gov/research/coal/energy-systems/gasification/gasifipedia/coal.
Chapter 6 – References and Abbreviations/Acronyms

Dry Fork Mine A2Tr1 EA 6-5

U.S. Department of Interior (DOI), 2004, Department of the Interior Departmental Manual 

Part 516. Available on the Internet as of January 2017: 

http://www.blm.gov/wo/st/en/prog/planning/nepa/webguide/departmental_manual.html.

U.S. Department of Labor – Bureau of Labor Statistics, 2016, Employment Status of the Civilian 

Noninstitutional Population, 1976 to 2015 Annual Averages, Available from website as 

of February 2017: https://www.bls.gov/.

U.S. Energy Information Administration (USEIA), 2016, Annual Coal Distribution Report 2015. 

Available from website as of January 2017: 

http://www.eia.gov/coal/distribution/annual/pdf/acdr_fullreport2015.pdf.

U.S. Environmental Protection Agency (EPA), 1993, Emission Factor Documentation for AP-42 

Section 1.1 Bituminous and Subbituminous Coal Combustion, April 1993.

U.S. Environmental Protection Agency (EPA), 2002, Latest Findings on National Air Quality, 

2002 Status and Trends. Available from website as of January 2017: 

https://nepis.epa.gov/Exe/tiff2png.cgi/P1003URM.PNG?-r+75+-

g+7+D%3A%5CZYFILES%5CINDEX%20DATA%5C00THRU05%5CTIFF%5C00001326%

5CP1003URM.TIF.

U.S. Environmental Protection Agency (EPA), 2008, Direct Emissions from Stationary 

Combustion Sources. Available on the Internet as of January 2017: 

https://www.epa.gov/climateleadership.

U.S. Environmental Protection Agency (EPA), 2012, National Emission Standards for Hazardous 

Air Pollutants From Coal and Oil-Fired Electric Utility Steam Generating Units. Available 

on the Internet as of February 2017: https://www3.epa.gov/ttn/atw/utility/fr16fe12.pdf.

U.S. Environmental Protection Agency (EPA), 2014a, Inventory of U.S. Greenhouse Gas 

Emissions and Sinks: 1990-2012. Available on the Internet as of April 2017: 

https://www3.epa.gov/climatechange/Downloads/ghgemissions/US-GHG-Inventory-2014-

Main-Text.pdf.

U.S. Environmental Protection Agency (EPA), 2014b. Emission Factors for Greenhouse Gas 

Inventories. Available on the Internet as of April 2017: 

https://www.epa.gov/sites/production/files/2015-07/emission-factors_2014.xlsx.

U.S. Environmental Protection Agency (EPA), 2015a, AirData – Reports. Download Data. 

Available from website as of January 2017: https://www.epa.gov/outdoor-air-quality-data.

U.S. Environmental Protection Agency (EPA), 2016a, NAAQS Table, Available from the website 

on the Internet as of January 2017: https://www.epa.gov/criteria-air-pollutants/naaqstable.

U.S. Environmental Protection Agency (EPA), 2016b, Current Nonattainment Counties for All 

Criteria Pollutants, Available from the website as of January 2017: 

https://www.epa.gov/green-book.
Chapter 6 – References and Abbreviations/Acronyms

Dry Fork Mine A2Tr1 EA 6-6

U.S. Environmental Protection Agency (EPA), 2016c, Report on the Environment, Acid Rain. 

Available from website as of January 2017: https://cfpub.epa.gov/roe/indicator.cfm?i=1.

U.S. Environmental Protection Agency (EPA), 2016d, Inventory of U.S. Greenhouse Gas 

Emissions and Sinks: 1990-2014, EPA 430-R-16-002, April 15, 2016. Available from the 

website as of January 2017: 

https://www3.epa.gov/climatechange/Downloads/ghgemissions/US-GHG-Inventory-2016-

Main-Text.pdf.

U.S. Environmental Protection Agency (EPA), 2017a, Toxics Release Inventory (TRI) Program. 

Available from website on the Internet as of January 2017: https://www.epa.gov/toxicsrelease-inventory-tri-program/tri-basic-data-files-calendar-years-1987-2015. U.S.

Environmental Protection Agency (EPA), 2017b, Wetlands, What is a Wetland? Wetland 

Components. Available from website as of April 2017: 

https://www.epa.gov/wetlands/what-wetland.

U.S. Environmental Protection Agency (EPA), 2017c. Inventory of U.S. Greenhouse Gas 

Emissions and Sinks: 1990 – 2014. Available on the Internet as of December 2016: 

https://www3.epa.gov/climatechange/Downloads/ghgemissions/US-GHG-Inventory-2016-

Main-Text.pdf.

U.S. Fish and Wildlife Service (USFWS), 2003, Migratory Bird Permit Memorandum: Nest 

Destruction. Available from website as of February 2017: 

https://www.fws.gov/policy/m0208.pdf.

U.S. Fish and Wildlife Service (USFWS), 2008, Birds of Conservation Concern 2008. Available 

from website as of February 2017: 

http://www.fws.gov/migratorybirds/pdf/grants/BirdsofConservationConcern2008.pdf.

U.S. Fish and Wildlife Service (USFWS), 2015, September 22, 2015 Press Release – Historic 

Campaign Protects Greater Sage-Grouse. Available from website as of February 2017:

https://www.fws.gov/news/ShowNews.cfm?ID=F5B7455D-0824-997C47667F8ABBFFBA86.

U.S. Fish and Wildlife Service (USFWS), 2016a, Dry Fork Mine IPaC Trust Resources Report, 

Available from website as of October 10, 2016: https://ecos.fws.gov/ipac/.

U.S. Fish and Wildlife Service (USFWS), 2016b, List of Threatened and Endangered Species for 

the Dry Fork Mine, Letter dated October 10, 2016. Electronic Copy Only. Available on 

request from OSMRE.

U.S. Fish and Wildlife Service (USFWS), 2016c, Wyoming Ecological Services Office, Federally 

Listed, Proposed and Candidate Species: Black-footed Ferret, Available from website as 

of January 2017: https://www.fws.gov/wyominges/Species/BFF.php.

U.S. Fish and Wildlife Service (USFWS), 2016d, Endangered Species Midwest Region Fact Sheet: 

Northern Long-Eared Bat Myotis septentrionalis, Available from website as of January 

2017: https://www.fws.gov/midwest/endangered/mammals/nleb/nlebFactSheet.html.
Chapter 6 – References and Abbreviations/Acronyms

Dry Fork Mine A2Tr1 EA 6-7

U.S. Geological Survey (USGS), 2013. Assessment of Coal Geology, Resources, and Reserve 

Base in the Powder River Basin, Wyoming and Montana, Fact Sheet 2012–3143. 

Available from website as of December 2016: http://pubs.usgs.gov/fs/2012/3143/fs-2012-

3143.pdf.

U.S. Geological Survey (USGS), 2016. National Climate Change Viewer. Available on the 

internet as of April 2017: https://www2.usgs.gov/climate_landuse/clu_rd/nccv.asp

Western Fuels-Wyoming Inc. (WFW), 2011, Dry Fork Mine WDEQ-LQD Permit No. PT0599. 

Electronic Copy Only. Available on request from OSMRE.

Western Fuels-Wyoming Inc. (WFW), 2015, 2015 Annual Wildlife Monitoring Report. 

Submitted to WDEQ-LQD. Prepared by Intermountain Resources. Electronic Copy 

Only. Available on request from OSMRE.

Western Fuels-Wyoming Inc. (WFW), 2016, Information provided by Dry Fork Mine. 

Electronic Copy Only. Available on request from OSMRE.

Western Regional Climate Center (WRCC), 2014, General Climate Summary – Precipitation 

and Temperature. Available from website on the Internet as of December 2016: 

http://www.wrcc.dri.edu/cgi-bin/cliMAIN.pl?wy3855.

Wyoming Administrative Rules, 2017, Dept. of Environmental Quality, Solid Waste 

Management. Chapter 3: Industrial Landfill Regulations. Available from website on the 

Internet as of January 2017: 

https://rules.wyo.gov/DownloadFile.aspx?source_id=3291&source_type_id=81&doc_typ

e_id=110&include_meta_data=Y&file_type=pdf&filename=3291.pdf&token=0400940911

31097241147004045124014253179004212179.

Wyoming Department of Administration and Information – Economic Analysis Division 

(WDAI-EAD), 2016, Gross Domestic Product for Wyoming by Industry, Available from 

website as of February 2017: http://eadiv.state.wy.us/i&e/.

Wyoming Department of Agriculture (WDOA), 2016, Wyoming Weed & Pest Control Act, 

State Designated Weeds and Pests. Available from website as of January 2017: 

http://www.wyoweed.org/images/Designated_List.pdf.

Wyoming Department of Environmental Quality (WDEQ), 2016, Letter to Mr. J. Brent Helms 

and Ms. Beth Goodnough dated August 19, 2016. Electronic Copy Only. Available on 

request from OSMRE. 

Wyoming Department of Environmental Quality- Air Quality Division (WDEQ-AQD), 2011,

Letter to Ms. Beth Goodnough dated September 20, 2011. Electronic Copy Only. 

Available on request from OSMRE.

Wyoming Department of Environmental Quality- Air Quality Division (WDEQ-AQD), 2012, FY 

2012 Annual Inspection of the Dry Fork Station. Electronic Copy Only. Available on 

request from OSMRE.
Chapter 6 – References and Abbreviations/Acronyms

Dry Fork Mine A2Tr1 EA 6-8

Wyoming Department of Environmental Quality- Air Quality Division (WDEQ-AQD), 2013, FY 

2013 Annual Inspection of the Dry Fork Station. Electronic Copy Only. Available on 

request from OSMRE.

Wyoming Department of Environmental Quality- Air Quality Division (WDEQ-AQD), 2014a, 

Air Quality Permit Modification Request. Electronic Copy Only. Available on request 

from OSMRE

Wyoming Department of Environmental Quality- Air Quality Division (WDEQ-AQD), 2014b, 

FY 2014 Annual Inspection of the Dry Fork Station. Electronic Copy Only. Available on 

request from OSMRE.

Wyoming Department of Environmental Quality- Air Quality Division (WDEQ-AQD), 2015, FY 

2015 Annual Inspection of the Dry Fork Station. Electronic Copy Only. Available on 

request from OSMRE.

Wyoming Department of Environmental Quality- Air Quality Division (WDEQ-AQD), 2016, 

Current Rules & Regulations, Chapter 2: Ambient Standards. Available from website as 

of February 2017: http://deq.wyoming.gov/admin/resources/rules-regs/.

Wyoming Department of Environmental Quality- Land Quality Division(WDEQ-LQD) 

/Lidstone and Associates, 2013, Cumulative Hydrological Impact Assessment of Coal 

Mining in the Northern Powder River Basin, Wyoming (WDEQ-CHIA-33), WDEQLQD, August 2013. Electronic Copy Only. Available on request from OSMRE.

Wyoming Department of Environmental Quality- Land Quality Division (WDEQ-LQD), 2013.

Approval of Amendment 2 Application for the Dry Fork Mine, Permit No. 59 -TS, TFN 

5 4/172, Change No. 30. Electronic copy only. Available on request from OSMRE.

Wyoming Department of Environmental Quality- Land Quality Division (WDEQ-LQD), 2012, 

Chapter 4: Environmental Protection Performance Standards. Available from website as 

of February 2017:

https://rules.wyo.gov/DownloadFile.aspx?source_id=8882&source_type_id=81&doc_typ

e_id=110&include_meta_data=Y&file_type=pdf&filename=8882.pdf&token=0001180840

27017224239034070171243090224018229100

Wyoming Department of Environmental Quality- Land Quality Division (WDEQ-LQD), 2014a, 

Form 1: Application for Permit to Mine or Amendment to a Permit to Mine or Coal 

Permit Renewal, Submitted October 14, 2013 and approved May 12, 2014. Electronic 

copy only. Available on request from OSMRE.

Wyoming Department of Environmental Quality- Land Quality Division (WDEQ-LQD), 2014b, 

Guideline No. 20 - Bond Release Categories and Submittal Procedures For Coal Mines.

Available from website as of February 2017: 

http://deq.wyoming.gov/media/attachments/Land%20Quality/Guidelines/Guidelines20_Coal-Bond-Release-guide-20.pdf.
Chapter 6 – References and Abbreviations/Acronyms

Dry Fork Mine A2Tr1 EA 6-9

Wyoming Department of Environmental Quality- Land Quality Division (WDEQ-LQD), 2016, 

WDEQ-LQD Mine Information. Electronic copy only. Available on request from 

OSMRE.

Wyoming Department of Environmental Quality – Water Quality Division (WDEQ-WQD),

2016, Current Rules & Regulations, Chapter 1: Wyoming Surface Water Quality 

Standards. Available from website as of February 2017: 

http://deq.wyoming.gov/admin/resources/rules-regs/.

Wyoming Department of Workforce Services (WDWS), 2014, Annual Report of the State 

Inspector of Mines of Wyoming, Year Ending December 31, 2014. Available from 

website as of February 2017: 

http://www.wyomingworkforce.org/_docs/mines/ar/2014.pdf.

Wyoming Department of Workforce Services (WDWS), 2015, Annual Report of the State 

Inspector of Mines of Wyoming, Year Ending December 31, 2015. Available from 

website as of February 2017: 

http://www.wyomingworkforce.org/_docs/mines/ar/2015.pdf.

Wyoming Department of Workforce Services (WDWS), 2016, TRENDS. Available from 

website as of February 2017: http://doe.state.wy.us/LMI/trends/1116/1116.pdf.

Wyoming Geological Association, 1969, Wyoming stratigraphic nomenclature chart. Wyoming 

Geological Association. Stratigraphic Nomenclature Committee. Available for document 

retrieval at: http://www.worldcat.org/title/wyoming-stratigraphic-nomenclaturechart/oclc/50794708.

Wyoming Game and Fish Department (WGFD), 2015, Sheridan Region Job completion report

Available for document retrieval at: 

https://wgfd.wyo.gov/WGFD/media/content/PDF/Hunting/JCRS/JCR_BGSHERCOMP_20

15.pdf.

Wyoming Game and Fish Department (WGFD), 2016, Wyoming Game and Fish Department 

Unpublished Data – 2016 Annual Lek Monitoring. 

Wyoming Oil and Gas Conservation Commission (WOGCC), 2016. Well Data Search. 

Available on the internet as of December 2016:

http://wogcc.state.wy.us/urecordsMenu.cfm?Skip='Y'&oops=ID83640

WWC Engineering (WWC), 2017. GHG, Air Quality, and Socioeconomic Calculations located 

in Appendix E.

Yates, David E. Adams, Evan M. Angelo, Sofia E. Evers, David C. Schmerfeld, John. Moore, 

Marianne S. Kunz, Thomas H. Divoll, Timothy. Edmunds, Samuel T. Perkins, 

Christopher. Taylor, Robert. O’Driscoll, Nelson J. 2013, Mercury in Bats from the 

Northeastern United States. Available on the Internet as of April 2017: 

http://link.springer.com/article/10.1007/s10646-013-1150-1
Dry Fork Mine A2Tr1 EA 6-10

6.2 Abbreviations/Acronyms

A2Tr1 Amendment 2, Tract 1

Ac-ft acre-feet

AIRFA American Indian Religious Freedom Act of 1978

ANFO Ammonium Nitrate and Fuel Oil

AOI area of influence

AQ air quality

AQI air quality index

AQRVs air quality related values

AQS Air Quality System

ASCM alternative sediment control measures

ASLM Assistant Secretary, Land and Mineral Management (DOI)

AVF alluvial valley floor

BACT Best Available Control Technology

BFO BLM Buffalo Field Office

BLM U.S. Bureau of Land Management

BMP Best management practice

BNSF BNSF Railway Company

BOR Bureau of Reclamation

BO biological opinion

Btu British thermal unit

CAA Clean Air Act, as amended

CBNG coal bed natural gas

CCB coal combustion byproduct

CEQ Council on Environmental Quality

CFO BLM Casper Field Office

CFR Code of Federal Regulations

cfs cubic feet per second

CH4 methane

CHIA cumulative hydrologic impacts

CIA cumulative impacts area

CO carbon monoxide

COA condition of approval

CO2 carbon dioxide

CO2e Equivalent CO2

CWA Clean Water Act

dBA adjusted decibels, a logarithmic unit of sound levels

DFCC Dry Fork Coal Company

DFM Dry Fork Mine

DFS Dry Fork Station

DL disturbed land

DOE U.S. Department of Energy

DOI U.S. Department of the Interior

dv deciview

EA Environmental Assessment
Dry Fork Mine A2Tr1 EA 6-11

EGU electric generating unit

EIS Environmental Impact Statement

EPA U.S. Environmental Protection Agency

EO Executive Order

EOY end of year

EQC Environmental Quality Council

ESA Endangered Species Act of 1973

FCLAA Federal Coal Leasing Act Amendment (1976)

FEIS Final Environmental Impact Statement

FLPMA Federal Land Policy Management Act of 1976

FONSI Finding of No Significant Impact

GDP gross domestic product

GHG Greenhouse gas 

GPO U.S. Government Publishing Office

GRSG Greater sage-grouse

GWh gigawatt hour

GWP Global Warming Potential

ft/d feet per day

H+ hydrogen ion

H2S hydrogen sulfide

HAP hazardous air pollutants

Hg mercury

IDB internally drained basin

IMPROVE Interagency Monitoring of Protected Environments

in. inches

IPaC Information for Planning and Conservation

ISCLT3 Industrial Source Complex Long Term 3

LAC level of acceptable change

lb. pounds

LNCM lands necessary to conduct mining

LOM life of mine

LPR Little Powder River

LRS Laramie River Station

μg/m3 micrograms per cubic meter

MATS Mercury and Air Toxic Standards

MBCC migratory birds of conservation concern

MBCY million-bank cubic yards

MBHFI migratory birds of high federal

MBTA Migratory Bird Treaty Act of 1918, as amended

MFP Management Framework Plans

Mg/L milligrams per liter

MLA Mineral Leasing Act (1920)

MMPA Mining and Minerals Policy Act of 1970

MPDD Mining Plan Decision Document

MSHA Mine Safety and Health 

Mt million tons
Dry Fork Mine A2Tr1 EA 6-12

Mtpy million tons per year

MW megawatts

N2O nitrous oxide

NAAQS National Ambient Air Quality Standards

NCDC National Climatic Data Center

NEPA National Environmental Policy Act (1969) 

NGCC North Gillette Coal Company

NHPA National Historic Preservation Act

NOA Notice of Availability

NOAA National Oceanic and Atmospheric Administration

NO2 nitrogen dioxide

NOI Notice of Intent

NOX oxides of nitrogen

NP Not Present

NPDES National Pollutant Discharge Elimination System

NRCS Natural Resources Conservation Service

NRHP National Register of Historic Places

NSPS New Source Performance Standards

NWI Nation Wetlands Inventory

O3 ozone

OSLI Wyoming Office of State Lands and Investments

OSMRE Office of Surface Mining Reclamation and Enforcement

PAP Permit Application Package

Pb lead

PBT bioaccumulative and toxic

PFYC Potential Fossil Yield Classification

pH power of hydrogen

PI present with the potential for impact

PM2.5 fine particulates less than 2.5 microns

PM10 fine particulates less than 10 microns

PMT post-mine topography

PRB Wyoming Powder River Basin

ppb parts per billion

ppm parts per million

PRPA Paleontological Resources Preservation Act of 2009

PSD Prevention of Significant Deterioration

PTE potential to emit

R2P2 Resource Recovery and Protection Plan

RCRA Resource Conservation and Recovery Act

RL reclaimed land

RMP Resource Management Plan

ROD Record of Decision

ROW right-of-way

SAR sodium adsorption rate

SDD State Decision Document

SDWA Safe Drinking Water Act
Dry Fork Mine A2Tr1 EA 6-13

SH State Highway

SHPO State Historic Preservation Office

SIP State Implementation Plan

SMCRA Surface Mining Control and Reclamation Act (1977)

SO2 sulfur dioxide

SOSI species of special interest

STP standard temperature and pressure

T&E threatened and endangered

TDS total dissolved solids

THPO Tribal Historic Preservation Office

tpy tons per year

TSP total suspended particles

TSS total suspended solids

UP Union Pacific

USACE U.S. Army Corps of Engineers

USEIA U.S. Energy Information Administration

USFS U.S. Forest Service

USFWS U.S. Fish and Wildlife Service

USGS U.S. Geological Survey

VOC volatile organic compound

VRM visual resource management

W water

WAAQS Wyoming Ambient Air Quality Standards

WAQSR Wyoming Air Quality Standards and Regulations

WCRC Wyoming Coal Resources Company

WDEQ Wyoming Department of Environmental Quality 

WDEQ-AQD Wyoming Department of Environmental Quality – Air Quality Division

WDEQ-LQD Wyoming Department of Environmental Quality – Land Quality Division

WDEQ-SHWD Wyoming Department of Environmental Quality – Solid and Hazardous Waste 

Division

WDEQ-WQD Wyoming Department of Environmental Quality – Water Quality Division

WDH-PHD Wyoming Department of Health, Public Health Division (WDH-PHD

WDOA Wyoming Department of Agriculture

WDWS Wyoming Department of Workforce Services

WEQA Wyoming Environmental Quality Act of 1973

WET whole effluent toxicity

WFW Western Fuels-Wyoming, Inc.

WGFD Wyoming Game and Fish Department

WOGCC Wyoming Oil and Gas Conservation Commission

WRS Wyoming Revised Statutes

W.S. Wyoming Statue

WYNDD Wyoming Natural Diversity Database

WYPDES Wyoming Pollutant Discharge Elimination System
APPENDICES

Appendix A Legal Notices for Federal Lease Modification Approval WYW-0271199, WYW0271200

Appendix B Errata/Revisions, Public Scoping Mailing Lists, Public Scoping and A2Tr1 EA 

Review Comments Summaries and A2Tr1 EA Review Comment Response Log

Appendix C PM10, PM2.5, SO2, NOx, And Hg Contributions from Coal Combustion 

Calculations and Greenhouse Gas Emissions Calculations

Appendix D Surface Water Rights Within 2 Miles of the A2Tr1 Tract and Groundwater 

Rights Within 2 Miles of the A2Tr1 Tract

Appendix E Dry Fork Mine Observed Wildlife Species List Special Status Species Summary 

Table for Federal Lease Modification Approval WYW-0271199, WYW-0271200

Appendix F State And Federal Revenue Calculations
APPENDIX A

LEGAL NOTICES

FOR FEDERAL LEASE MODIFICATION APPROVAL

WYW-0271199, WYW-0271200
Appendix A

Dry Fork Mine A2Tr1 EA A-1

Public Notice

Dry Fork Mine Mining Plan Modification

Environmental Assessment

The U.S. Department of the Interior (DOI), Office of Surface Mining Reclamation and 

Enforcement (OSMRE), Western Region Office, will prepare an environmental assessment (EA) 

for the Dry Fork Mine (DFM) mining plan modification for federal coal leases W-0271200 and 

W-0271201 (the Project). On June 2, 1989, in accordance with the Mineral Leasing Act of 1920 

(MLA), the operator of the DFM, Dry Fork Coal Co. (currently Western Fuels Wyoming) 

received federal mining plan approval from the ASLM to mine portions of federal coal leases W0271200 and W-0271201 at the DFM, in accordance with the approved surface coal mining 

Permit No. 599 issued by the state regulatory authority; the Wyoming Department of 

Environmental, Land Quality Division (WDEQ-LQD). The DFM also has approval from WDEQLQD and the ASLM to mine federal coal lease W-5035 and portions of federal coal leases W0271199 and W-0311810. On August 19, 2013, in accordance with its responsibilities under the 

federal Surface Mining Control and Reclamation Act of 1977, the WDEQ-LQD approved 

Amendment 2 (A2) for surface coal mining Permit No. 599, including the mining of portions of 

federal coal leases W-0271200 and W-0271201, not previously approved by the ASLM. In 

accordance with MLA, The ASLM must approve the mining plan modification for federal coal 

leases W-0271200 and W-0271201 before mining of the federal coal can occur.

OSMRE is preparing this EA to evaluate the environmental impacts resulting from the Project, 

pursuant to the requirements of the National Environmental Policy Act of 1969 (NEPA). The 

DFM is located approximately 4.5 miles north of Gillette, Wyoming. The total amount of federal 

coal authorized for removal at the DFM is approximately 255.1 million tons (mt) and an estimated 

126.8 mt of coal remains to be mined. A2 proposes to add zero federal surface acres, 

approximately 268.0 federal coal acres and 33.4 mt of federal coal to the approved federal mining 

plan. The DFM conducts open pit surface coal mine using conventional truck and loader methods. 

The average production rate at the DFM is approximately 6 million tons per year (mtpy) and the 

maximum production rate is 15 mtpy. A2 would not change the average production rate or the 

maximum production rate for the life of the mining operation. This mining plan modification 

would extend the life of the mine by approximately 5.6 years, concluding in 2042.

The EA will disclose the potential for direct, indirect, and cumulative impacts to the environment 

from the Project. Through the EA, OSMRE will determine whether or not there are significant 

environmental impacts. If a finding of no significant impact is reached, the OSMRE Director will 

make a recommendation to the ASLM on the federal mining plan modification, and the ASLM will 

approve, approve with conditions, or disapprove the federal mining plan modification. If the EA 

identifies significant impacts, an environmental impact statement will be prepared.

OSMRE is soliciting public comments. Your comments will help to determine the issues and 

alternatives that will be evaluated in the environmental analysis. You are invited to direct these 

comments to: ATTN: Dry Fork Mine A2 EA, C/O: Lauren Mitchell, Western Region Office, Office 

of Surface Mining Reclamation and Enforcement, 1999 Broadway, Suite 3320, Denver, CO 80202. 

Email: OSM-NEPA-WY@OSMRE.gov.
Appendix A

Dry Fork Mine A2Tr1 EA A-2

Comments should be received or postmarked no later than April 8, 2016 to be considered during 

the preparation of the EA. Comments received, including names and addresses of those who 

comment, will be considered part of the public record and will be available for public inspection. 

Additional information regarding the project may be obtained from Lauren Mitchell, telephone 

number (303) 293-5028 and the project website provided below. When available, the EA and 

other supporting documentation will be posted at:

http://www.wrcc.osmre.gov/initiatives/DryForkMineA2.shtm
Appendix A

Dry Fork Mine A2Tr1 EA A-3
Appendix A

Dry Fork Mine A2Tr1 EA A-4
Appendix A

Dry Fork Mine A2Tr1 EA A-5
APPENDIX B

ERRATA/REVISIONS,

PUBLIC SCOPING MAILING LISTS,

PUBLIC SCOPING and A2Tr1 EA REVIEW COMMENTS SUMMARIES

and

A2Tr1 EA REVIEW COMMENT RESPONSE LOG

(INDIVIDUAL LETTERS RECEIVED HAVE NOT BEEN INCLUDED)
Appendix B

Dry Fork Mine A2Tr1 EA B-1

Errata/Revisions

Title Page Revised EA date

Table of Content (TOC) The TOC has been revised to address changes in the 

document.

Table 2-2, page 2-8 Table 2-2 has been revised to add additional 

information (Federal Mining Plan acre and WDEQLQD permit acres), to correct disturbance acres 

(revised from 4,365.1 to 4,364.8) and to update the 

remaining LOM (revised from 37.1 to 37.0), and to 

update the footnotes.

The text of the EA has been revised where 

appropriate to change the reference of the LOM from 

37.1 to 37.0.

Table 2-4, page 2-10 Table 2-4 has been revised to correct the acres of 

surface disturbance in Row I from 152.6 to 155.4 and 

in Row J from 153.8 to 151.0. These changes did not 

result in any change to the EA discussion since the 

correct acres were used through the EA.

Table 3-14, page 3-22 Table 3-14 has been revised to indicate that the 

analysis was conducted on coal that was combusted 

rather than coal recovered. The title of the table was 

also revised to state that the analysis included CO.

Table 3-16, page 3-24 Table 3-16 has been revised to clarify the title and to 

update the several of the row headings. 

Table 4-5, page 4-17 Table 4-5 has been revised to add a column for the 

number of days evaluated each year.

Table 4-7, page 4-18 Tale 4-7 has been revised to correct errors, to clarify 

the 2013 emissions discussions, and to update the 

footnotes.

Table 4-8, page 4-20 Table 4-8 has been revised to correct errors.

Section 4.4.7.3, page 4-24 The text in the first para. under the Soils heading on 

page 4-24 has been revised to clarify the potential to 

predict changes to runoff.

Section 4.14.1.1, page 4-46 The text in the 1st para. of section 4.14.1.1 has been 

revised to clarify.

Section 5.3, page 5-2 The link provided has been revised to correctly link to 

the OSMRE website for the Dry Fork A2Tr1 EA.

Chapter 6 - References The CEQ 2016 reference has been removed.

The Shelanski, H. and M. Obstfeld, 2015 reference has 

been added.

The 2010 BLM reference for Master Title Plats has 

been revised.

Appendix B Appendix B has been revised to add an 

Errata/Revisions table and a table of the public 

comments log
Appendix B

Dry Fork Mine A2Tr1 EA B-2

Mailing List

Name Title

Tribal

Darwin St. Clair Chairman Eastern Shoshone Business Council

Dean Goggles Chairman Northern Arapaho Business Council

Shaun Chapoose Chairperson The Ute Tribe of the Uintah and Ouray Reservation

Harold C. Frazier Chairman Cheyenne River Sioux Tribal Government

Roxanne Sazue Chairwoman Crow Creek Sioux Tribe

Wanda Wells Cultural Affairs Crow Creek Sioux Tribe

Anthony Reider President Flandreau Santee Sioux Tribe

Michael Jandreau Chairman Lower Brule Sioux Tribe

Clair Green Cultural Resources/Public Affairs Lower Brule Sioux Tribe

John Yellow Bird Steele President Oglala Sioux Tribal Council

William Kindle President Rosebud Sioux Tribe 

Garryl Rousseau Sr. Vice-Chairman or Acting Chairman Sisseton-Wahpeton Oyate Tribes

Robert Flying Hawk Chairman Yankton Sioux Tribe

Lyman Guy Tribal Chairman Apache Tribe of Oklahoma

Lisa Martin Tribal Council Coordinator Cheyenne-Arapaho Tribes of Oklahoma

Wallace Coffey Chairman Comanche Nation Tribe

Amber Toppah Lady Chairman Kiowa Business Committee

Roger Trudell Chairman Santee Sioux Tribe of Nebraska

Mark Fox Chairman MHA Nation Tribal Council, Three Affiliated Tribes 

Dave Archambault II Chairman Standing Rock Sioux Tribe

Vernon Finley Chairman Confederated Salish and Kootenai Tribes of the Flathead Reservation

Floyd Azure Chairman Ft. Peck Assiniboine and Sioux Tribes

Harry Barnes Chairman Blackfeet Tribal Business Council

Darrin Old Coyote Chairman Crow Tribal Council

Llevando “Cowboy” Fisher Sr. President Northern Cheyenne Tribal Council 

Blaine Edmo Chairman Shoshone-Bannock Tribes of the Fort Hall Reservation
Appendix B

Dry Fork Mine A2Tr1 EA B-3

Name Title

State and Local Agencies

Doug Miyamoto Director Wyoming Department of Agriculture

Todd Parfitt Director Wyoming Department of Environmental Quality

Mark Rogaczewski WDEQ Land Quality Division 

David Waterstreet Program Director WDEQ Natural Resources

Scott Talbott Director Wyoming Department of Game and Fish

Mary Hopkins SHPO Wyoming Historic Preservation Office, SHPO

Milward Simpson Director Wyoming Department of Parks and Cultural Resources

Bridget Hill Director Office of State Lands and Investment

Bill Crapser State Forester Wyoming Forestry Division

John Cox Director Wyoming Department of Transportation

Thomas A. Drean Director/State Geologist Wyoming Geological Survey

Dan Noble Director Wyoming Department of Revenue

Mark W. Watson State Oil and Gas Supervisor Wyoming Oil and Gas Conservation Commission

Patrick T. Tyrrell State Engineer Wyoming State Engineer’s Office

Domenic Bravo Division Administrator Wyoming State Parks, Historic Sites & Trails Division

Harry C. LaBonde Director Wyoming Water Development Commission

Wyoming Office of the Governor

Delbert McOmie Interim Director Wyoming Department of Workforce Services

Diane Shober Executive Director Wyoming Office of Tourism Board

Alan B. Minier Chairman Wyoming Public Service Commission

Economic Analysis Division Wyoming Department of Administration and Information

Bridget Hill Office of State Lands and Investments

Mark Gordon Office of the State Treasurer

Kelly Bott WY DEQ Air Quality Division 

Pat Tyrrell WY State Engineer's Office

Sarah Needles WY State Historic Pres Office

Kyle Wendtland Wyoming LQD - DEQ 

Wyoming State Board of Land Commissioners
Appendix B

Dry Fork Mine A2Tr1 EA B-4

Name Title

WY Dept of Employment Research & Planning

Kelly Bott WY DEQ Air Quality Division 

Milward Simpson WY Parks & Cultural Res Dept

Pat Tyrrell WY State Engineer's Office

Sarah Needles WY State Historic Pres Office

Natural Resources & Policy Section Wyoming Dept of Agriculture

Scott Talbott Wyoming Game and Fish Department

Al Minier Chairman Wyoming Public Service Comm

Thomas A. Drean Director Wyoming State Geological Survey

Harry LaBonde Wyoming Water Dev Comm

Mark Christensen Campbell County Commissioners

Dr. Garry Becker Campbell County Commissioners

Matt Avery Campbell County Commissioners

Rusty Bell Campbell County Commissioners

Micky Shober Campbell County Commissioners

Campbell County Airport 

Keith Bowar Chief Building Official Campbell County Building Division

Phillip Giffin P.E. Campbell County Engineering Division

Megan Nelms

AICP, County Planner & Zoning 

Administrator Campbell County Planning & Zoning Division 

David King CCEMA Coordinator Campbell County Emergency Management 

Bill Shank Fire Chief Campbell County Fire Department

Dave McCormick Executive Director Campbell County Parks and Recreation

Kevin King P.E., Director Campbell County Department of Public Works

Kevin F. Geis P.E., Executive Director Campbell County Road & Bridge

Quade Schmelzle Director Campbell County Weed & Pest

Campbell County Conservation District

Campbell County School District 1

Executive Director Campbell County Economic Development Corporation
Appendix B

Dry Fork Mine A2Tr1 EA B-5

Name Title

Campbell County Public Land Board

Tom Langston Gillette Department of Commercial Development

Louise Carter-King Mayor City of Gillette

Kevin McGrath City Council City of Gillette

Tim Carsrud City Council City of Gillette

Robin Kuntz City Council City of Gillette

Dan Barks City Council City of Gillette

Billy Montgomery City Council City of Gillette

Ted Jerred City Council City of Gillette

Dustin Hamilton Development Services Director City of Gillette

Sawley Wilde Public Works Director City of Gillette

Kendall Glover Director of Utilities City of Gillette

Jim Hloucal Chief of Police City of Gillette

Pam Boger Administrative Services Director City of Gillette

Cartier Napier City Administrator City of Gillette

Hon. Matthew H. Mead Governor Wyoming Governor

Representative Scott Clem District HD31 Wyoming Legislature

Representative Roy Edwards District HD53 Wyoming Legislature

Representative Bill Pownall District HD52 Wyoming Legislature

Senator Ogden Driskill District SD01 Wyoming Legislature

Senator Michael Von Flatern District SD24 Wyoming Legislature

Federal Agencies

Darryl LaCounte Regional Director Rocky Mountain Regional Office, Bureau of Indian Affairs

Carlie Ronca Area Manager Wyoming Area Office, Bureau of Reclamation

Wyoming Regulatory Office, US Army Corps of Engineers, Omaha District

Mary Jo Rugwell State Director Wyoming State Office, Bureau of Land Management

Stephanie Connolly High Plains District Manager High Plains District Office, Bureau of Land Management

Mitchell Leverette Division Chief Bureau of Land Management

Jamie Connell State Director Montana State Office, Bureau of Land Management
Appendix B

Dry Fork Mine A2Tr1 EA B-6

Name Title

Todd Yeager Miles City Office, Bureau of Land Management

Duane Spencer Buffalo Field Office, Bureau of Land Management

Rhen Etzelmiller Casper Field Office, Bureau of Land Management

Library, Bureau of Land Management

Coal Coordinator Montana State Office, Bureau of Land Management

Coal Coordinator Wyoming State Office, Bureau of Land Management

Lawrence S. Roberts Acting Assistant Secretary Bureau of Indian Affairs

Environmental Division US Air Force Headquarters/CEVP

NPS

NPS - Air Quality

NPS Air Resources Division

NPS 2310

U.S. Department of Energy

Shaun McGrath Administrator US EPA, Region 8 

Mark Sattelberg Field Supervisor Wyoming Ecological Services Field Office, US Fish and Wildlife Service

Dennis Jaeger Forest Supervisor's Office Thunder Basin National Grassland, USDA Forest Service

Devils Tower National Monument, National Park Service

Astrid Martinez State Conservationist Wyoming State Office, Natural Resources Conservation Service 

Marcelo Calle

Office of Surface Mining Reclamation and Enforcement

Program Support Division, Field Operations Branch

Advisory Council on Historic Preservation

US Army Corps of Engineers

US EPA

Ecological Services US Fish and Wildlife Service

US Geological Survey

BLM Cooperator Lead USDA-FS Douglas Ranger District

USGS Water Resources Division 

US Fish and Wildlife Service, Ecological Services 

U.S. Department of Energy
Appendix B

Dry Fork Mine A2Tr1 EA B-7

Name Title

US Army Corps of Engineers

US EPA

US Geological Survey

Michael Enzi US Senate Gillette Office

John Barrasso US Senate Casper Office

Cynthia Lummis US House of Representatives Casper Office

Landowners

Green Bridge Holdings Inc

Burkhardt Jackie Michael

Green Bridge Holdings Inc

Dept of Interior/Blm

Basin Electric Power Coop &

State of Wyoming

Macintosh Property Group Inc

Western Fuels Wyoming Inc

Western Fuels Wyoming Inc

Kawulok Joseph Living Trust

Interested Groups and Businesses

Mark Thrall Belle Ayr Mine

H.A. True President, Belle Fourche Pipeline Company

Mitchell J. Reneau VP Land, Bill Barrett Corporation

Biodiversity Conservation Alliance

BNSF Railway Company

Buckskin Mine-Kiewit Mining Group

Jason Adrians Casper Star Tribune

Amy M. Atwood Center for Biological Diversity

John Trummel Cloud Peak Energy

Converse County Commission

Dr. Dan Espelan Converse County School District #1
Appendix B

Dry Fork Mine A2Tr1 EA B-8

Name Title

Kirk M. Hughes Converse County School District #2

Paul W. Musselman Converse Cty, Special Projects

Cordero Rojo Mine

Defenders of Wildlife

Devils Tower National Monument

Matt Adelman Publisher, Douglas Budget

Environmental Policy and Culture Program

Federation for North American Wild Sheep

Energy Reporter Gillette News-Record

Steve Bullock Governor of Montana

Scott Child Interwest Mining Company

Joe Mehl Kiewit Mining Group Inc 

Jim McLeland Eric Bjordahl M&K Oil Company Inc

Greg Julian Mineral Management Service

Hal Quinn National Mining Association

National Wildlife Federation

Natural Resources Defense Council

Shannon Anderson Powder River Basin Resource Council

Phil Dinsmoor Powder River Coal Company 

James M. Piccone Resolute Wyoming

Bob Comer Rocky Mtn Region Solicitor

Peter Morgan Sierra Club

Lecia Craft Thunder Basin Coal Company

Ralph Kingan Mayor, Town of Wright

Roger Miller President, Trout Unlimited

Lance Fritz President, Chief Executive Officer, Union Pacific Railroad

US West Communications (Qwest Corp.)

Jason M. Ryan Business Analytics Director, US Western Surface Operations

Wendi Chatman UW Libraries
Appendix B

Dry Fork Mine A2Tr1 EA B-9

Name Title

Taylor Jones WildEarth Guardians

Mike Evers WWC Engineering

Dave Spencer WY Business Council/NE Region

Bill Schilling Wyoming Business Alliance

Matt Grant Wyoming Mining Association 

Gary Wilmont Wyoming Outdoor Council

Niels Hansen Wyoming Stock Growers Assoc

Steve Kilpatrick Wyoming Wildlife Federation

Amy Wallop Wyoming Wool Growers Association, Executive Director

Mike McCraken Publisher Wyoming-Tribune Eagle

Katie Parker Yates Petroleum Corp et al
Appendix B

Dry Fork Mine A2Tr1 EA B-10

Summary of Scoping Comments

ID# Date Organization Comment 

Category Comment Campaign

1 3/25/2016 Alpha Natural 

Resources Economics I urge the scope of the EA to heavily weigh consideration of the economic impacts of the mining operation on the State and local economies. yes

2 3/22/2016 General Support

3 4/12/2016 Basin Electric Power 

Cooperative Economics I urge the scope of the EA to heavily weigh consideration of the economic impacts of the mining operation on the State and local economies. yes

4 3/21/2016 Individual Economics I urge the scope of the EA to heavily weigh consideration of the economic 

impacts of the mining operation on the State and local economies. yes

5 3/21/2016 Nelson Brothers 

Mining Services, LLC Economics I urge the scope of the EA to heavily weigh consideration of the economic impacts of the mining operation on the State and local economies. yes

6 3/19/2016 Individual Economics I urge the scope of the EA to heavily weigh consideration of the economic 

impacts of the mining operation on the State and local economies. yes

7 4/4/2016 Individual Economics I urge the scope of the EA to heavily weigh consideration of the economic 

impacts of the mining operation on the State and local economies. yes

8 3/21/2016 Individual Economics I urge the scope of the EA to heavily weigh consideration of the economic 

impacts of the mining operation on the State and local economies. yes

9 3/16/2016 Basin Electric Power 

Cooperative Economics I urge the scope of the EA to heavily weigh consideration of the economic impacts of the mining operation on the State and local economies. yes

10 3/18/2016 Bowie Resources 

Partners, LLC Economics I urge the scope of the EA to heavily weigh consideration of the economic impacts of the mining operation on the State and local economies. yes

11 3/19/2016 HIIG Energy Economics I urge the scope of the EA to heavily weigh consideration of the economic 

impacts of the mining operation on the State and local economies. yes

12 3/28/2016 J.E. Stover & 

Associates, Inc. General Support

13 3/18/2016 United Central 

Industrial Supply General Support

14 3/18/2016 Nelson Brothers 

Incorporated Economics I urge the scope of the EA to heavily weigh consideration of the economic impacts of the mining operation on the State and local economies. yes

15 3/21/2016 Individual Economics I urge the scope of the EA to heavily weigh consideration of the economic 

impacts of the mining operation on the State and local economies. yes

16 4/8/2016 RESPEC Economics I urge the scope of the EA to heavily weigh consideration of the economic 

impacts of the mining operation on the State and local economies. yes

17 3/23/2016 Individual General Support
Appendix B

Dry Fork Mine A2Tr1 EA B-11

ID# Date Organization Comment 

Category Comment Campaign

18 3/18/2016 Interstate 

PowerSystem General Support

19 3/16/2016 Individual Economics

In fact, the economic impacts of mining companies are so very important that 

you must give those impacts great consideration when developing the scope of 

the Environmental Assessment for the Dry Fork Mine, or any other mine in the 

State of Wyoming. 

20 3/24/2016 Manpower General Support

21 3/28/2016 USFWS T&E Species For species identified by IPAC, you should review the recommendations and 

measures at http://www.fws.gov/wyoming/species_endangered.php.

22 3/28/2016 USFWS Wildlife

Review your Project relative to responsibilities under the Migratory Bird Treaty 

Act (see http://www.fsw.gov/mountainprairie/es/wyoming/species_Migratory.php)

23 3/28/2016 USFWS Wildlife Review Avian Power Line Interaction Committee (APLIC) guidelines to avoid 

and minimize electrocutions and collision (see http://www.aplic.org).

24 3/28/2016 USFWS Wetlands Review your Project relative to responsibilities for wetland protection (see 

http://www.fws.gov/wyominges/landscapeConservation.php)

25 3/18/206 Individual Purpose and 

Need

The Dry Fork Mine Environmental Assessment should address the critical need 

to continue to provide coal resources to the area power plants to generate 

affordable, reliable electricity. 

26 3/18/206 Individual Economics Please be sure to address the positives of the jobs and revenues generated by 

the mining process.

27 3/18/206 Individual Purpose and 

Need

The EA should reflect their good record and enable the company to continue to 

mine and to serve the region for years to come. 

28 4/6/2016 WYGF Reclamation We recommend the mining plan continue to include appropriate WY DEQ/LQD 

reclamation standards.

29 4/6/2016 WYGF Wildlife In addition, this amendment portion should include the wildlife monitoring 

protocol with annual reports provided to DEQ in Section D-9. 
Appendix B

Dry Fork Mine A2Tr1 EA B-12

Public Outreach (Scoping) Comments Categorized by Key Resource Category

Comment Category Number of Topics Discussed % of Total Comments

Wetlands 1 3%

Reclamation 1 3%

Threatened and Endangered Species 1 3%

Support Coal-fired Power Generation 2 7%

Wildlife 3 10%

General Support without Specific Topic 6 21%

Economic Impacts to Local/State 15 52%

Total 29 100%
Appendix B

Dry Fork Mine A2Tr1 EA B-13

Public Review Comments Summary

Commenter Date Address/Email Water 

Quality Air QualityWildlife

Level of 

NEPA/

NEPA 

Process

Reclamation Climate 

Change Permitting Economy Cultural Resources

Pro 

Mining

Against 

Coal 

Mining

Typographical 

changes Notes # ofComments

# 

Commenters

(Form Letters 

Counted as 

One 

Commenter)

# 

Commenters

(Counting 

Each 

Commenter)

Beth 

Goodnough 

(Western Fuels 

Association) 

6/1/17

1901 Energy Court, 

Suite 328 Gillette, 

WY 82718

1 1 1 1 1 1 1 1

Letter 

containing 

suggested text 

changes for 

multiple 

sections of the 

EA. More 

specific 

comment were 

related to 

effects 

determinations 

for wildlife, 

surface water, 

ownership and 

use of the land, 

visual 

resources, and 

socioeconomic

s. The letter 

also addressed 

the social cost 

of carbon.

8 1 1

WildEarth 

Guardians 

(Shannon A. 

Hughes)

6/2/17

2590 Walnut St. 

Denver Colorado 

80205. 

shughes@wildearthg

uardians.com

1 1 1 1 1 1 1

The letter 

containing 

general 

comments 

against mining. 

More specific 

comment were 

related to the 

level of NEPA 

analysis, the 

perceived 

failure to 

adequately 

address direct 

and indirect 

impacts for air 

quality, 

surface-water 

quality, climate 

change, coal 

exports, coal 

combustion 

byproduct 

wastes, and 

coal 

transportation. 

The letter also 

includes the 

perceived 

failure to 

address 

impacts of 

similar or 

cumulative 

actions related 

to pending coal 

leases and 

other 

7 1 1
Appendix B

Dry Fork Mine A2Tr1 EA B-14

Commenter Date Address/Email Water 

Quality Air QualityWildlife

Level of 

NEPA/

NEPA 

Process

Reclamation Climate 

Change Permitting Economy Cultural Resources

Pro 

Mining

Against 

Coal 

Mining

Typographical 

changes Notes # ofComments

# 

Commenters

(Form Letters 

Counted as 

One 

Commenter)

# 

Commenters

(Counting 

Each 

Commenter)

generating 

stations in 

proximity to 

the DFM.

Campbell 

County 

Commissioners

5/1/17

500 South Gillette 

Avenue, Gillette, 

WY 82716

www.ccgov.net

1 1 1

Pro mining 

letter with 

comments 

about the 

economic 

benefits to 

mining, 

supplying coal 

to the DFS, 

adequate level 

of NEPA 

analysis, and 

support for the 

project.

3 1 1

Matt Mead 

(Governor of 

Wyoming)

6/1/17

2323 Carey Avenue 

Cheyenne, WY 

82002

1 1 1

Pro mining 

letter 3 1 1

Wyoming 

Game and Fish 

Department 

(Scott Smith)

6/7/17

5400 Bishop Blvd., 

Cheyenne, WY 

82006

No terrestrial 

or aquatic 

wildlife 

concerns

0 1 1

Wyoming 

Mining 

Association 

(Travis Deti)

6/1/17

1401 Airport 

Parkway, Ste. 230, 

Cheyenne, WY 

82001

1 1 1

Pro mining 

letter with 

comments 

about the 

Social Cost of 

Carbon and 

global climate 

change 

wording in EA.

3 1 1

WildEarth 

Guardians 

Form Letter

Variou

s

Various - submitted 

Online 1 1

Against mining 

form letters

from multiple 

individuals with 

general 

comments 

stating that 

OSMRE needs 

to consider the 

facts regarding 

climate change 

and protecting 

the public 

interest.

2 1 3,920
Appendix B

Dry Fork Mine A2Tr1 EA B-15

Commenter Date Address/Email Water 

Quality Air QualityWildlife

Level of 

NEPA/

NEPA 

Process

Reclamation Climate 

Change Permitting Economy Cultural Resources

Pro 

Mining

Against 

Coal 

Mining

Typographical 

changes Notes # ofComments

# 

Commenters

(Form Letters 

Counted as 

One 

Commenter)

# 

Commenters

(Counting 

Each 

Commenter)

Dry fork 

support letters 

with comments 

on EA

Variou

s

Various - Submitted 

by WFA via scanned 

letters

1 1 1 1 1 1 1 1

Pro mining 

form letters 

from multiple 

individuals with 

comments 

about the 

Social Cost of 

Carbon and 

global climate 

change 

wording in EA. 

These letters 

also have 

general 

comments 

regarding the

permitting 

process, water 

and air quality, 

reclamation 

and the 

positive effects 

on the 

economy.

8 1 21

I Support the 

Dry Fork Mine 

Letters

Variou

s

Various 1 1 1

Contains 

multiple letters 

from 

individuals -

general pro 

mining. The 

letters state 

that the EA 

adequately 

evaluates the 

impacts.

3 1 1,627

Pro-mining 

Form Letters 

to OSMRE 

Website

Variou

s

Various - Submitted 

Online 1 1 1 1 1

Contains 

multiple letters 

from 

individuals -

general pro 

mining. The 

letters state 

that the EA 

adequately 

evaluates the 

impacts and 

provided an 

finding of no 

significant 

impacts.

5 1 429

Total by Topic 3 3 2 7 3 6 2 6 1 6 2 1 42 10 6,003

Percent of Total 

Number of 

Comments

30.0% 30.0% 20.0% 70.0% 30.0% 60.0% 20.0% 60.0% 10.0% 60.0% 20.0% 10.0%

Pro 

Mining 7 2,081

Against 

Mining 2 3,921

Neutral 1 1

Total 10 6,003
Appendix B

Dry Fork Mine A2Tr1 EA B-16

Public Review Comments Log

Commenter Comment Final Response Final Revision

Project Support 

Form letters with 

comments

The Social Cost of Carbon (SCC) discussion is 

out of date and should be removed, and the 

statement "it is now well established that rising 

global atmospheric GHG emissions 

concentrations are significantly affecting the 

Earth's climate" should be removed or balanced. 

Third para (SCC) on 4-22 conflicts with first 

sentence of 4th para. EPA 2015b reference 

(SCC) not available. 

On March 27, 2017, President Trump issued an executive order revoking 

Executive Order 13693, which defined GHGs and instructed the CEQ to 

formulate guidance related to GHG discussions in NEPA analyses. OSMRE has 

elected to quantify direct and indirect GHG emissions and evaluated these 

emissions in the context of Wyoming and national GHG emission inventories. 

Please see sections 4.4.6 and 4.4.7 for further discussion.

Section 4.4.7.1 has been significantly revised in 

consideration of the recent revocation of Executive 

Order 13693.

Wild Earth 

Guardians

OSMRE should prepare an EIS. According to NEPA guidance provided in BLM Handbook H-1790-1, an EA is 

intended to be a concise public document that provides sufficient evidence and 

analysis for determining the significance of effects from a proposed action (40 

CFR 1508.9) and that serves as a basis for reasoned choice. Based upon the EA 

analysis, either an EIS or a FONSI will be prepared. Section 1.2.1 (Statutory 

and Regulatory Background) and section 1.4 (Regulatory Framework and 

Necessary Authorizations) include the rationale for selecting an EA for the 

level of NEPA analysis. OSMRE has completed the EA process and has not 

identified significant negative effects.

No changes made.

The EA fails to fully analyze and assess the direct 

and indirect impacts of mining the DFM on 

surface water quality, particularly with respect 

to how increased inflows may lead to discharge 

violations and how increased inflows and 

resulting discharges can

be mitigated.

Section 3.5.1 provides a detailed discussion on the current surface water 

quality and section 4.5.1 provides a detailed discussion of surface-water quality 

effects. OSMRE has evaluated the potential effects and has determined that the 

direct and indirect effects to surface-water resources resulting from the 

Proposed Action are expected to be moderate and short term on the tract 

due to surface water runoff characteristics. According to WDEQ-LQD Rules 

and Regulations, proposed mining operations must be designed and conducted 

“to minimize disturbance of the hydrologic balance within the permit and 

adjacent areas, to prevent material damage to the hydrologic balance outside 

the permit area, to assure the protection or replacement of water rights, and 

to support approved post-mining land uses in accordance with the terms and 

conditions of the approved permit and the performance standards” of Chapter 

4, Environmental Protection Performance Standards. This would include any 

potential changes resulting from the Proposed Action. In addition, section 

2.4.4.3 includes a statement that the DFM must control and monitor water 

quality and quantity in compliance with the WYPDES permit.

Section 4.5.1.3 has been modified to add a reference to 

compliance with WYPDES limitations.

The EA fails to fully analyze and assess the direct 

and indirect impacts of mining the DFM on air 

quality (coal combustion, non-attainment areas, 

designated Class I areas).

Section 3.4.2 includes a detailed discussion on the current status of 

nonattainment areas and section 4.4.1.1.1 includes detailed discussion on the 

direct and indirect effects of particulate matter on Class I areas. Section 

3.4.7.3.2 includes a detailed discussion on the current air quality related values 

related to coal combustion and section 4.4.5 discusses air quality related to 

combustion. OSMRE staff has reviewed the determination and is in agreement.

No changes made.
Appendix B

Dry Fork Mine A2Tr1 EA B-17

Public Review Comments Log (Cont.)

Commenter Comment Final Response Final Revision

The EA fails to fully analyze and assess the direct 

and indirect impacts of mining the DFM from 

climate change impacts.

On March 27, 2017, President Trump issued an executive order revoking 

Executive Order 13693, which defined GHGs and instructed the CEQ to 

formulate guidance related to GHG discussions in NEPA analyses. To help 

facilitate this policy action , President Trump directed agencies to use costbenefit estimates that are consistent with OMB Circular A-4, a guidance 

document “embodying the best practices for conducting regulatory costbenefit analysis.” According to the circular, if an agency cannot quantify a 

benefit or cost, the agency should explain why and present any available 

quantitative information. Since it is currently not feasible to accurately 

determine the cost-benefits of the Proposed Action or the No Action 

Alternative from a GHG emissions perspective, OSMRE elected to discuss 

climate change by calculating emissions as a relative indicator to allow 

comparison of the Proposed Action and the No Action Alternative based on 

their potential contribution to climate change. Section 4.4.7 includes a 

thorough discussion on climate change cause and effect based on comparisons 

between the Proposed Action and the No Action Alternative and GHGs 

generated in Wyoming and the U.S. OSMRE has determined that the analysis in 

the EA adequately discloses impacts to climate.

No changes made.

The EA fails to fully analyze and assess the direct 

and indirect impacts of mining the DFM from 

coal export impacts.

The DFM will not be exporting coal. No changes made.

The EA fails to fully analyze and assess the direct 

and indirect impacts of mining the DFM from 

coal combustion byproduct wastes.

Section 2.3 includes a detailed discussion of CCB wastes that are currently 

received from the DFS power plant. The DFM is permitted by WDEQ to 

receive these products and the mine adheres to a strict protocol regarding 

transportation, dust control, and runoff control. 

No changes made.

The EA fails to fully analyze and assess the direct 

and indirect impacts of mining the DFM from 

coal transportation impacts

Section 3.14 includes a detailed discussion on transportation facilities and 

section 3.4.7.4 includes a detailed discussion on dust emissions from coal 

transport. Section 4.15.1.1 includes thorough discussions on the direct and 

indirect effects of coal dust related to transportation and the DFM's protocol 

for minimizing effects of dust from coal transportation.

No changes made.

The EA fails to address impacts of similar and 

cumulative actions related to pending coal leases

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 GHG emissions related to the Proposed Action are thoroughly discussed 

in section 4.4.7.1. 

No changes made.

The EA fails to address impacts of similar and 

cumulative actions related to generating stations 

in close proximity to DFM.

Section 4.4.2 includes detailed discussions on CO, SO2 and Pb emissions from 

area power plants. Section 4.4.3 includes discussions of modeling conducted 

for NOx that included area power plants and section 4.4.4.2 discusses the 

cumulative effects of area power plants on air quality related values. It was 

determined that since the Proposed Action is an extension of current impacts 

and that since Campbell County is currently meeting WAAQS and NAAQS, 

the cumulative effects would be minor.

No changes made.
Appendix B

Dry Fork Mine A2Tr1 EA B-18

Public Review Comments Log (Cont.)

Commenter Comment Final Response Final Revision

Beth Goodnough 

(WFA)

The statement "Coal drying at the benches 

reduces the potential for spontaneous 

combustion in coal stockpiles" is inaccurate.

Noted The text in the 5th para. on page 1-5 has been revised 

to clarify the reason for coal drying.

We are confused by Table 1-1. Did you mean to 

say "Percent of In State Shipped to LRS"?

Noted Table 1-1 has been revised to replace DFS with LRS

The coal ownership includes 195.3 acres of 

private coal, 5,541.5 acres of federal coal, and 

740.7 acres of state owned coal." Should the 

740.7 be changed to 640.7?

Noted. The 740.7-acre number has been verified. No changes made. 

The privately owned coal is not shown on Map 

1-2. It is the mined-out area in Section 24.

Per B. Goodnough (WFA), a response to this comment is unnecessary. No changes made.

The statement " Permit renewals approved 

under WDEQ-LQD regulations are for a 5-year 

permit term and the permit must be renewed 

every 5 years, updating the application with new 

information and planned changes in the mining 

or reclamation activities" Should be changed to 

"Permit renewals approved under WDEQ-LQD

regulations are for a 5-year term, and the permit 

must be updated with new information at that 

time."

Noted The 2nd para. of section 2.1 has been revised to clarify 

the discussion on permit renewal.

The sentence " Changes to the state mining plan 

occurring during the 5-year permit term must 

be approved by WDEQ-LQD through a 

revision" should state "Changes to the state 

mining plan must be approved by WDEQ-LQD 

through a revision."

Noted The 3rd para. of section 2.1 has been revised to clarify 

the discussion on permit renewal.

The statement "Control dust from coal 

stockpiles by compaction and applying water" is 

inaccurate .

Noted The 2nd bulleted item in section 2.4.4.2 has been 

removed since stockpiles are not used at the DFM.

The cross section location maps do not show 

G'.

Noted Figures 3-2 and 3-3 have been revised to indicate G'.

The statement "Table 3-9 shows one 

exceedance of the 8-hour standard for the 

NAAQS O3 standard having occurred during 

the 2011-2015 monitoring period" is inaccurate.

Noted The text directly above table 3-9 has been revised to 

clarify the discussion on exceedances. Table 3-9 has 

been revised accordingly.

Section 3.4.7.3.2 should clarify that these are 

indirect effects not directly caused by mining 

coal.

Direct and indirect effects discussions are intended to be in Chapter 4. 

Language included in section 2.4.3.3 addresses the reasons for discussing coal 

combustion in the EA.

The text in section 4.4.5.1.1 has been revised to state 

that emissions from combustion are indirect effects.

Table 3-14 should be split into two tables one 

indicating direct emissions and one showing 

indirect effects.

Direct and indirect effects discussions are intended to be in Chapter 4. No changes made.

Section 3.4.7.4 should be split to separate direct 

and indirect emissions.

Direct and indirect effects discussions are intended to be in Chapter 4. No changes made.
Appendix B

Dry Fork Mine A2Tr1 EA B-19

Public Review Comments Log (Cont.)

Commenter Comment Final Response Final Revision

The last paragraph of section 3.4.7.4 is awkward 

and not about GHG emissions should be 

changed.

Direct and indirect effects discussions are intended to be in Chapter 4. No changes made.

Table 3-16 should be split to separate direct and 

indirect emissions

Direct and indirect effects discussions are intended to be in Chapter 4. No changes made.

Section 3.4.7.5 should be clearly identified as 

describing indirect effects.

Direct and indirect effects discussions are intended to be in Chapter 4. No changes made.

The statement "There were no exceedances of 

Class 3B standards (WDEQ-WQD 2016) for 

any constituent" appears to conflict with a 

statement in the next paragraph.

Noted The 4th para. of section 3.5.1 has been revised to 

replace standards with designations.

Table 4-3 should not include discussion of 

"potential for regional impact from 

transportation and combustion of coal" in the 

"proposed action" column.

Table 4-3 discusses direct and indirect impacts. Regional impacts from 

transportation and coal combustion would be indirect impacts so disclosing 

that in this table is appropriate.

No changes made.

Table 4-3 , the draft determination that the 

impacts to wildlife are "moderate" for the 

proposed action are incorrect. 

Section 4.10 provides evidence that impacts to some wildlife species would 

persist and could be considered moderate. OSMRE has determined that the 

analysis in the EA adequately discloses impacts to wildlife. Definition of the 

levels of impacts are defined in section 4.1.

No changes made.

Discussing Hg emissions as a direct impact of 

the proposed action is inaccurate.

Long-eared bats (a T&E species) has the potential to occur in the area. As such 

an evaluation of this species is required since the DFM provides coal to the 

DFS, which is immediately adjacent to the mine. 

No changes made.

Table 4-3, discussing the "potential for regional 

impact from combustion of coal" as a direct 

impact of the proposed action is inaccurate.

As discussed in section 2.4.3.3 of the EA, OSMRE considers coal combustion 

to be an indirect effect of the Proposed Action and therefore needs to be 

discussed in the EA.

No changes made.

Table 4-3, describing the impact to ownership 

and use of land as moderate is inaccurate.

While land ownership will not change, land use would change from rangeland 

to developed area for a period of time. OSMRE has determined that the 

analysis in the EA adequately discloses impacts to land ownership.

No changes made.

Table 4-3, describing the impact to visual 

resources as moderate is inaccurate.

While the effect to the Dry Fork Mine area would be minor, the visual effects 

would be moderate to the specific project area. OSMRE has determined that 

the analysis in the EA adequately discloses impacts to visual resources.

Section 4.14.1.1 has been revised to clarify the 

reasoning behind the moderate designation.

Table 4-3, describing the impact to 

socioeconomics as "moderate, beneficial, local 

and regional" is inaccurate.

While the $124 million dollars in revenues seem significant, the annual 

contribution to state and federal revenues would be moderate when 

considering the percentages to total revenues. OSMRE has determined that 

the analysis in the EA adequately discloses impacts to socioeconomic 

resources.

The socioeconomics portion of table 4-3 has been 

revised to change the designation from significant to 

moderate under the No Action Alternative.

Table 4-3, description of impact of no action 

alternative on socioeconomics as significant is 

correct.

While the $124 million dollars in revenues seem significant, the annual 

contribution to state and federal revenues would be moderate when 

considering the percentages to total revenues. OSMRE has determined that 

the analysis in the EA adequately discloses impacts to socioeconomic 

resources.

The socioeconomics portion of table 4-3 has been 

revised to change the designation from significant to 

moderate under the No Action Alternative.

PM10 concentrations as percentage of annual 

standard appear to be incorrectly calculated.

Noted The 1st para. of section 4.4.1.1 has been revised to 

correct the errors in the discussion.
Appendix B

Dry Fork Mine A2Tr1 EA B-20

Public Review Comments Log (Cont.)

Commenter Comment Final Response Final Revision

PM 10 concentrations as a percentage of the 24-

hour standard appear to be incorrectly 

calculated.

Noted The 1st para. of section 4.4.1.1 has been revised to 

correct the errors in the discussion.

Suggest that "well" be added to that last 

sentence of the first paragraph of page 4-9 to 

indicate that PM2.5 concentrations are "well

below the prescribed NAAQS".

OSMRE agrees with this suggestion since the percentages have been revised. The last sentence of the 1st para. of Section 4.4.1.1 has 

been revised to add the word "well".

2nd paragraph of section 4.4.3.1.1 should 

reference table 3-10 instead of 3-9.

Noted The 2nd para. of section 4.4.3.1.1 has been revised to 

reference table 3-10.

2nd paragraph of section 4.4.3.1.1 references 

values of 188ug/m3 and 189ug/m3 as being in 

table 3-3, however those values were not found 

in table 3-3 or the footnotes.

Noted The 2nd para. of section 4.4.3.1.1 has been revised to 

correctly PM10 values.

Page 4-14, reference to section 3.4.7.3 should be 

section 3.4.7.2.

Noted The 2nd para. on page 4-14 has been revised to 

correctly reference section 3.4.7.2.

Reference to figure 3-1 on page 4-15 should 

instead reference figure 3-4.

Noted The 2nd para. of section 4.4.4.1.1 has been revised to 

correctly reference figure 3-4.

Table 4-5, recalculate the figures in row entitled 

"percent of total average" values appear to be 

incorrect.

Noted Table 4-5 has been revised to correctly label the row.

Suggest splitting section 4.4.6.1.1 into direct 

effect and indirect effect sections.

OSMRE is aware of the concern regarding splitting up the GHG discussions 

into separate direct and indirect sections. Since all other sections are 

presented as a combined section for direct and indirect effects the formatting 

will remain as currently presented. However, the section has been revised to 

clarify the difference between direct and indirect effects.

Additional text has been added to the 3rd para. of 

section 4.4.6.1.1 to clarify the direct and indirect 

effects. Section 4.4.6.1.1 has been revised significantly to 

update the GHG discussion.

Table 4-8, footnote 3 appears to be inaccurate. Noted The footnotes in table 4-8 have been revised to 

eliminate Footnote 3.

Typographical error at end of section 4.4.6.1.2 

"4.4.5.2 Cumulative Effects" should be deleted.

Noted The wording has been removed from the end of section 

4.4.6.1.2 and the following section headers have been 

revised to accurately reflect the section flow.

Section 4.4.6.4 is the first section to describe 

minimal direct impacts of the proposed action, 

should be explained before this section.

OSMRE agrees that "minimal" is not the correct wording as it is not a 

previously use term. 

The 2nd para. of section 4.5.2.2 has been revised to 

replace the word "minimal" with "negligible".

Remove or modify first sentence of section 

4.4.7.1. 

OSMRE agrees with the suggestion. Section 4.4.7.1 has been significantly revised in 

consideration of the recent revocation of Executive 

Order 13693.

Correct typographical error in section 4.4.7.1. 

"(see section x)" in the third paragraph, perhaps 

reference table 4-8.

Noted Section 4.4.7.1 has been significantly revised in 

consideration of the recent revocation of Executive 

Order 13693, which resolved this comment.
Appendix B

Dry Fork Mine A2Tr1 EA B-21

Public Review Comments Log (Cont.)

Commenter Comment Final Response Final Revision

Suggest that 3rd paragraph on page 4-22 be 

removed. Social Cost of Carbon does not 

appear to be required by guidance.

On March 27, 2017, President Trump issued an executive order revoking 

Executive Order 13693, which defined GHGs and instructed the CEQ to 

formulate guidance related to GHG discussions in NEPA analyses, including 

discussions on the SCC. To help facilitate this policy action and in place of any 

SCC evaluations, President Trump directed agencies to use cost-benefit 

estimates that are consistent with OMB Circular A-4, a guidance document 

“embodying the best practices for conducting regulatory cost-benefit analysis.” 

According to the circular, if an agency cannot quantify a benefit or cost, the 

agency should explain why and present any available quantitative information. 

Since it is currently not feasible to accurately determine the cost-benefits of 

the Proposed Action from a GHG emissions perspective, OSMRE has elected 

to provide a detailed qualitative description of any potential direct and indirect 

effects of GHG emissions.

Section 4.4.7.1 has been significantly revised in 

consideration of the recent revocation of Executive 

Order 13693, which resolved this comment..

Suggest adding text to fourth paragraph of page 

4-22 to balance the discussion.

On March 27, 2017, President Trump issued an executive order revoking 

Executive Order 13693, which defined GHGs and instructed the CEQ to 

formulate guidance related to GHG discussions in NEPA analyses, including 

discussions on the SCC. To help facilitate this policy action and in place of any 

SCC evaluations, President Trump directed agencies to use cost-benefit 

estimates that are consistent with OMB Circular A-4, a guidance document 

“embodying the best practices for conducting regulatory cost-benefit analysis.” 

According to the circular, if an agency cannot quantify a benefit or cost, the 

agency should explain why and present any available quantitative information. 

Since it is currently not feasible to accurately determine the cost-benefits of 

the Proposed Action from a GHG emissions perspective, OSMRE has elected 

to provide a detailed qualitative description of any potential direct and indirect 

effects of GHG emissions.

Section 4.4.7.1 has been significantly revised in 

consideration of the recent revocation of Executive 

Order 13693, which resolved this comment..

Section 4.9.1.1 the acreage listed in paragraph 2 

(554.2) appears to high is it supposed to be 

154.2?

Noted The text in section 4.9.1.1 has been revised to replace 

554.2 with 155.4.

Suggest removing the comma after "2,103 

acres," in first paragraph section 4.10.1.1.

Noted The text in the 1st para. of section 4.10.1.1.1 has been 

revised to remove the comma after 2,103 acres.

section 4.15.1.1 mentions that railroads are 

shown on map 1-1, is this supposed to be map 

1-2?

Noted The text in the 1st para. of section 4.15.1.1 has been 

revised to correctly reference map 1-2.

It should be mentioned that there are other 

possible taxes that were not included in this 

evaluation, including corporate income tax, real 

estate tax, and indirect taxes from sale of 

electricity and shipping coal.

While OSMRE acknowledges that all forms of tax revenue might not be 

included in the evaluation, this method of calculations has been a standard for 

some time.

No changes made.

Section 4.17.2 should acknowledge the impacts 

to the power plant if alternative fuels are not 

available and the power plant needs to shut 

down 5.3 years earlier. 

Noted Section 4.17.1.2 has been revised to add a discussion on 

the potential to impact the DFS power plant.

Section 4.18 appears to be missing discussion on 

short term and long term productivity.

Noted Text has been added to section 4.18 to help clarify the 

discussion.
Appendix B

Dry Fork Mine A2Tr1 EA B-22

Public Review Comments Log (Cont.)

Commenter Comment Final Response Final Revision

Headers in chapter 4 and 5 are incorrect. Noted The headers of chapters 4 and 5 have been revised 

where appropriate

appendix F page F-4 is missing footnotes beyond 

footnote #4.

Noted Footnotes have been added to the Revenues 

Calculations Table in appendix F.

Page FONSI-2, "WFW proposed to meet 

demand for coal and continue mine operation 

through approximately 2025" year should be 

changed from 2025 to 2055.

Noted The text under "Context" has been revised to change 

the date from 2025 to 2055.

Page FONSI-2, "Approval of the Proposed 

Action is a site-specific action that would 

authorize mining of approximately 32 Mt of 

federal coal at a maximum rate of 6 Mtpy..." the 

average rate is 6 Mtpy but the mine is permitted 

for up to 15 Mtpy. Should replace 6 Mtpy with 

15 Mtpy or change wording from maximum to 

average.

Noted The text under "Context" has been revised to change 

the tonnage from 6 Mtpy to 15 Mtpy.

Page FONSI-4, the phrase "and the federal 

surface will continue to be managed by BLM for 

public use and enjoyment" is inappropriate since 

there are no federal surface lands, phrase should 

be deleted.

Noted The text under #2 (The degree to which the Proposed 

Action affects public health or safety) has been modified 

to remove any reference to federal management.

Page FONSI-4, the phrase "There are no park 

lands, prime farmlands, wilderness, wild and 

scenic rivers, or ecologically critical areas within 

the EA project area", is it worth noting that 

there are also no federal surface lands?

This comment has been noted. However, federal ownership is not considered 

an unique characteristic of the area.

No changes made.
APPENDIX C

PM10, PM2.5, SO2, NOX, Hg, CO, and CO2e CONTRIBUTIONS FROM COAL COMBUSTION 

CALCULATIONS

(Completed by WWC Engineering)

GREENHOUSE GAS EMISSIONS CALCULATIONS

(Completed by WWC Engineering)
Appendix C

Dry Fork Mine A2Tr1 EA C-1

GHG Calculations Assumptions 

Direct Emissions Variables

Source: SGAC Calculations (BLM 2009)

Indirect Emissions Assumptions

Train: 130 Cars/Train, 1/2 aluminum rotary, 1/2 aluminum bottom dump (From DFM)

23 Tons/car empty - 1/2 are 21 tons and 1/2 are 25 tons (BNSF 2016)

119 Tons of Coal/Car (BNSF 2016)

15,470 Tons of Coal/Train (calculated)

200 Tons/locomotive – four per train (BNSF 2016)

3,790 Weight of empty 130-car train (tons) (calculated)

19,260 Weight of loaded coal train (tons) (calculated)

Transportation Emissions Variables

Emission Rate (kg/gal) CO2e Conversion Rate Kg CO2e/Gal Diesel Kg CO2e/Mile/Ton

CO2 10.21 1 10.21 0.023417431

CH4 0.0000112 25 0.00028 0.000001

N2O 0.0000224 298 0.0066752 0.000015

Total 10.2169552 0.0234

Source: Conversion Rate – EPA 2017c

Emission Rate – EPA 2014b

Transportation Variables

Miles/gal/1 Ton1 Miles Kg 

CO2e/Mile/Ton2 Tons Gal/Train Kg CO2e/Mile Kg CO2e/Trip Metric Tons CO2e/Trip

Loaded 436 1,090 0.0234 19,260.0

(Calculated)

451.3

(Calculated)

4,611.2

(Calculated)

5,026,194.3

(Calculated)

5,026.2

(Calculated)

Empty 436 1,090 0.0234 3,790.0 88.8 907.4 989,059.0 989.1

1

FactCheck 2008

2 EPA 2014b

DFM Production, 2009-2016

2009 2010 2011 2012 2013 2014 2015 2016 Average

Production (Tons) 5,230,000 5,450,000 5,770,964 6,006,787 5,433,936 5,373,973 6,369,206 6,135,546 5,721,302

Source: WDWS (2009 through 2016)

Source CO2e/Mt Coal Mined

FUEL subtotal 3,266.9

ELECTRICITY subtotal 2,670.1

PROCESS subtotal 1,147.7
Appendix C

Dry Fork Mine A2Tr1 EA C-2

Estimated 2011 DFM Equivalent CO2e (in metric tons)

Source Coal (Mt) Ave. Known Ratio (tons/Mt coal) Tons

Direct

Fuel 5.8 3,266.9 18,853

Electricity 2,670.1 15,409

Mining Process 1,147.7 6,623

Total Direct 40,886

Indirect

Rail Transport 

2011 Coal Production 5,770,964

2011 Coal to DFS 1,008,509

2011 Coal Shipped by Rail 4,762,455

Tons Coal/Train 15,470

Empty Train Tons 3,790

Loaded Train Tons 19,260

# Loaded Trains/year 308

# Empty Trains/year 308

Rail miles to power plant 365

Kg CO2e/Mi/Loaded Train 451.3

Kg CO2e/Mi/Empty Train 88.81

Kg CO2e/year Empty 9,979,473.9

Kg CO2e/year Loaded 50,713,632.4

Kg CO2e/year Total 60,693,106.3

Total Metric Tons CO2e/year 60,693

Combustion (CO2e) 9,666,365

Total Indirect CO2e 9,727,058

Total Direct + Indirect CO2e 9,767,943

100% Coal shipped to U.S. power plants
Appendix C

Dry Fork Mine A2Tr1 EA C-3

Estimated 2012 DFM Equivalent CO2e (in metric tons)

Source Coal (Mt) Ave. Known Ratio (tons/Mt coal) Tons

Direct

Fuel 6.0 3,266.9 19,624

Electricity 2,670.1 16,039

Mining Process 1,147.7 6,894

Total Direct 42,556

Indirect

Rail Transport 

2011 Coal Production 6,006,787

2011 Coal to DFS 2,027,692

2011 Coal Shipped by Rail 3,979,095

Tons Coal/Train 15,470

Empty Train Tons 3,790

Loaded Train Tons 19,260

# Loaded Trains/year 257

# Empty Trains/year 257

Rail miles to power plant 192

Kg CO2e/Mi/Loaded Train 451.33

Kg CO2e/Mi/Empty Train 88.81

Kg CO2e/year Empty 4,386,008.1

Kg CO2e/year Loaded 22,288,790.7

Kg CO2e/year Total 26,674,798.8

Total Metric Tons CO2e/year 26,675

Combustion (CO2e) 10,061,368

Total Indirect CO2e 10,088,043

Total Direct + Indirect CO2e 10,130,599

100% Coal shipped to U.S. power plants
Appendix C

Dry Fork Mine A2Tr1 EA C-4

Estimated 2013 DFM Equivalent CO2e (in metric tons)

Source Coal (Mt) Ave. Known Ratio (tons/Mt coal) Tons

Direct

Fuel 5.4 3,266.9 19,624

Electricity 2,670.1 16,039

Mining Process 1,147.7 6,894

Total Direct 42,556

Indirect

Rail Transport 

2011 Coal Production 5,433,936

2011 Coal to DFS 1,993,629

2011 Coal Shipped by Rail 3,440,307

Tons Coal/Train 15,470

Empty Train Tons 3,790

Loaded Train Tons 19,260

# Loaded Trains/year 222

# Empty Trains/year 222

Rail miles to power plant 250

Kg CO2e/Mi/Loaded Train 451.33

Kg CO2e/Mi/Empty Train 88.81

Kg CO2e/year Empty 4,937,659.1

Kg CO2e/year Loaded 25,092,167.4

Kg CO2e/year Total 30,029,826.5

Total Metric Tons CO2e/year 30,030

Combustion (CO2e) 9,101,843

Total Indirect CO2e 9,131,873

Total Direct + Indirect CO2e 9,174,429

100% Coal shipped to U.S. power plants
Appendix C

Dry Fork Mine A2Tr1 EA C-5

Estimated 2014 DFM Equivalent CO2e (in metric tons)

Source Coal (Mt) Ave. Known Ratio (tons/Mt coal) Tons

Direct

Fuel 5.4 3,266.9 17,556

Electricity 2,670.1 14,349

Mining Process 1,147.7 6,168

Total Direct 38,073

Indirect

Rail Transport 

2011 Coal Production 5,373,973

2011 Coal to DFS 2,138,037

2011 Coal Shipped by Rail 3,235,936

Tons Coal/Train 15,470

Empty Train Tons 3,790

Loaded Train Tons 19,260

# Loaded Trains/year 209

# Empty Trains/year 209

Rail miles to power plant 142

Kg CO2e/Mi/Loaded Train 451.33

Kg CO2e/Mi/Empty Train 88.81

Kg CO2e/year Empty 2,637,984.0

Kg CO2e/year Loaded 13,405,692.0

Kg CO2e/year Total 16,043,676.0

Total Metric Tons CO2e/year 16,044

Combustion (CO2e) 9,001,405

Total Indirect CO2e 9,017,448

Total Direct + Indirect CO2e 9,055,521

100% Coal shipped to U.S. power plants
Appendix C

Dry Fork Mine A2Tr1 EA C-6

Estimated 2015 DFM Equivalent CO2e (in metric tons)

Source Coal (Mt) Ave. Known Ratio (tons/Mt coal) Tons

Direct

Fuel 6.4 3,266.9 20,808

Electricity 2,670.1 17,006

Mining Process 1,147.7 7,310

Total Direct 45,124

Indirect

Rail Transport 

2011 Coal Production 6,369,206

2011 Coal to DFS 2,097,518

2011 Coal Shipped by Rail 4,271,688

Tons Coal/Train 15,470

Empty Train Tons 3,790

Loaded Train Tons 19,260

# Loaded Trains/year 276

# Empty Trains/year 276

Rail miles to power plant 132

Kg CO2e/Mi/Loaded Train 451.33

Kg CO2e/Mi/Empty Train 88.81

Kg CO2e/year Empty 3,237,109.2

Kg CO2e/year Loaded 16,450,322.8

Kg CO2e/year Total 19,687,432.0

Total Metric Tons CO2e/year 19,687

Combustion (CO2e) 10,668,420

Total Indirect CO2e 10,688,107

Total Direct + Indirect CO2e 10,733,231

100% Coal shipped to U.S. power plants
Appendix C

Dry Fork Mine A2Tr1 EA C-7

Estimated 2016 DFM Equivalent CO2e (in metric tons)

Source Coal (Mt) Ave. Known Ratio (tons/Mt coal) Tons

Direct

Fuel 6.1 3,266.9 20,026

Electricity 2,670.1 16,368

Mining Process 1,147.7 7,035

Total Direct 43,429

Indirect

Rail Transport 

2011 Coal Production 6,135,546

2011 Coal to DFS 1,829,403

2011 Coal Shipped by Rail 4,306,143

Tons Coal/Train 15,470

Empty Train Tons 3,790

Loaded Train Tons 19,260

# Loaded Trains/year 278

# Empty Trains/year 278

Rail miles to power plant 141

Kg CO2e/Mi/Loaded Train 451.33

Kg CO2e/Mi/Empty Train 88.81

Kg CO2e/year Empty 3,485,711.6

Kg CO2e/year Loaded 17,713,669.2

Kg CO2e/year Total 21,199,380.8

Total Metric Tons CO2e/year 21,199

Combustion (CO2e) 10,277,040

Total Indirect CO2e 10,298,239

Total Direct + Indirect CO2e 10,341,668

100% Coal shipped to U.S. power plants
Appendix C

Dry Fork Mine A2Tr1 EA C-8

Summary of Estimated DFM 2011-16 CO2e Emissions

CO2e Source 2011 2012 2013 2014 2015 2016 2011 - 2016 

Ave.

%

From Indirect

Direct Emissions

 Fuel 18,853 19,624 19,624 17,556 20,808 20,026 19,415 0.0%

 Electricity 15,409 16,039 16,039 14,349 17,006 16,368 15,868 0.0%

 Mining Process 6,623 6,894 6,894 6,168 7,310 7,035 6,821 0.0%

 Total Direct Emissions 40,886 42,556 42,556 38,073 45,124 43,429 42,104 0.0%

Indirect Emissions

 Rail Transport 60,693 26,675 30,030 16,044 19,687 21,199 29,055 0.3%

 Power Plant Combustion 9,666,365 10,061,368 9,101,843 9,001,405 10,668,420 10,277,040 9,796,073 99.7%

 Total Indirect Emissions 9,727,058 10,088,043 9,131,873 9,017,448 10,688,107 10,298,239 9,825,128 100.0%

Total Emissions 9,767,943 10,130,599 9,174,429 9,055,521 10,733,231 10,341,668 9,867,232 99.6%
Appendix C

Dry Fork Mine A2Tr1 EA C-9

Estimated Annual 2017-2053 DFM Equivalent CO2e (in metric tons)

Source Coal (Mt) Ave. Known Ratio (tons/Mt coal) Tons

Direct

Fuel 6.0 3,266.9 19,601

Electricity 2,670.1 16,021

Mining Process 1,147.7 6,886

Total Direct 42,508

Indirect

Rail Transport 

2017-2053 Coal Production 6,000,000

2017-2053 Coal to DFS 2,000,000

2017-2053 Coal Shipped by Rail 4,000,000

Tons Coal/Train 13,225

Empty Train Tons 35

Loaded Train Tons 13,260

# Loaded Trains/year 302

# Empty Trains/year 302

Rail miles to power plant 216

Kg CO2e/Mi/Loaded Train 451.33

Kg CO2e/Mi/Empty Train 88.8

Kg CO2e/year Empty 5,807,566.7

Kg CO2e/year Loaded 29,512,859.0

Kg CO2e/year Total 35,320,425.7

Total Metric Tons CO2e/year 35,320

Combustion (CO2e) 10,050,000

Total Indirect CO2e 10,085,320

Total Direct + Indirect CO2e 10,127,829

100% Coal shipped to U.S. power plants
Appendix C

Dry Fork Mine A2Tr1 EA C-10

Summary of Estimated DFM 2017-2053 CO2e Emissions (in metric tons)

CO2e Source 2017-2053

Ave

% From 

Indirect

Direct Emissions

Fuel 19,601 0.0%

Electricity 16,021 0.0%

Mining Process 6,886 0.0%

Total Direct 42,508 0.0%

Indirect Emissions

 Rail Transport 35,320 0.4%

 Power Plant Combustion 10,050,000 99.6%

 Total Indirect Emissions 10,085,320 100.0%

Total Emissions 10,127,829 99.6%
Appendix C

Dry Fork Mine A2Tr1 EA C-11

Parameters Used to Calculate Combustion Emissions

Btu per short ton 16,890,000 CEC 2011

tons per kg 0.00110231 Conversion

tons to generate 1KW-h 0.000618735 CEC 2011

tons to generate 1 MW-h 0.61873467 Calculated

PM10 Emissions per Btu (kg/MW-h) 0.39 CEC 2011

PM10 Emissions per Btu (ton/MW-h) 0.000429901 Calculated

PM2.5 Emissions per Btu (kg/MW-h) 0.305 CEC 2011

PM2.5 Emissions per Btu (ton/MW-h) 0.00013112 Calculated

SOx Emissions factor (lb/ton) 17.5 CEC 2011

NOx Emission factor (lb/ton) 7.2 CEC 2011

Hg Emission factor (lb/ton) 0.000083 CEC 2011

CO Emission factor (lb/ton) 0.5 Calculated

Combustion Emissions Values

Past 

Production

Proposed

Action No Action Campbell County1 US Emissions2

Years 2011 2012 2013 2014 2015 2016 2017-2053 2017-2047 2011-2016 Avg 2015

Tons mined (From DFM) 5,770,964 6,006,787 5,433,936 5,373,973 6,369,206 6,135,546 6,000,000 6,000,000 369,718,568.0 824,768,000.0

mw-h from coal mined 9,327,424 9,708,577 8,782,697 8,685,780 10,294,343 9,916,686 9,697,608 9,697,608 597,564,269 1,333,046,078.5

PM10 Emissions 4,009.9 4,173.7 3,775.7 3,734.0 4,425.5 4,263.2 4,169.0 4,169.0 256,893.4 573,077.7

PM 2.5 Emissions 1,223.0 1,273.0 1,151.6 1,138.9 1,349.8 1,300.3 1,271.5 1,271.5 78,352.5 174,788.7

SO2 Emissions 50,495.9 52,559.4 47,546.9 47,022.3 55,730.6 53,686.0 52,500.0 52,500.0 3,235,037.5 7,216,720.0

NOx Emissions 20,775.5 21,624.4 19,562.2 19,346.3 22,929.1 22,088.0 21,600.0 21,600.0 1,330,986.8 2,969,164.8

Hg Emissions 0.2 0.2 0.2 0.2 0.3 0.3 0.2 0.2 15.3 34.2

CO Emissions 1,442.7 1,501.7 1,358.5 1,343.5 1,592.3 1,533.9 1,500.0 1,500.0 92,429.6 206,192.0
APPENDIX D

SURFACE WATER RIGHTS WITHIN 2 MILES of the A2Tr1 TRACT

GROUNDWATER RIGHTS WITHIN 2 MILES of the A2Tr1 TRACT
Appendix D

Dry Fork Mine A2Tr1 EA D-1

Surface Water Rights within 2 Miles of A2Tr1 Tract

Permit No. Priority Twn Rng Sec Qtr-Qtr Applicant Facility Name Status Stream Source Uses

P4492.0S 03/06/1962 050N 071W 4 NWNW EUGENESPRINGEN CHRIS STOCK RESERVOIR Complete Chris Draw STO

P4493.0S 03/06/1962 050N 071W 4 SESW EUGENESPRINGEN KENIS STOCK RESERVOIR Complete Garner Lake Draw STO

CR CR05/145 03/06/1962 050N 071W 4 SESW EUGENE D.SPRINGEN Kenis Stock Reservoir Garner Lake Draw STO

CR CR05/147 03/06/1962 050N 071W 4 NWNW EUGENE D.SPRINGEN Chris Stock Reservoir Chris Draw STO

P2618.0S 01/19/1959 050N 071W 8 NWSW O. H.KENITZER SPRING STOCK RESERVOIR Complete Spring Draw

CR CR02/339 01/19/1959 050N 071W 8 NWSW O. H.KENITZER Spring Stock Reservoir Spring Draw STO

P5275.0S 05/27/1963 050N 072W 1 NWSE BASIN ELECTRIC POWER COOP RATTLESNAKE STOCK RESERVOIR Complete Rattlesnake Draw STO

P1697.0S 11/19/1956 050N 072W 12 NWSE BASIN ELECTRIC POWER COOP DUBOIS STOCK RESERVOIR Complete Little Powder River STO

P12395.0D 05/04/1914 051N 071W 20 NESW Nellie A.Wilson Nellie A. Wilson Ditch Fully 

Adjudicated Prairie Creek IRR_SW 

P2281.0D 09/16/1899 051N 071W 20 SESE C.A.MOYER Lake Ditch Fully 

Adjudicated North Creek IRR_SW

P2646.0R 05/04/1914 051N 071W 20 NESW NELLIE WILSON WILSON RESERVOIR Complete Prairie Creek IRR_SW

CR CC13/046 09/16/1899 051N 071W 20 SESE C AMOYER LAKE DITCH Fully 

Adjudicated North Creek IRR_SW

CR CC38/033 05/04/1914 051N 071W 20 NESW NELLIE A WILSON Nellie A. Wilson Ditch Prairie Creek IRR_SW

CR CR38/034 05/04/1914 051N 071W 20 NESW NELLIE A WILSON Wilson Reservoir Prairie Creek IRR_SW

P6530.0S 11/28/1969 051N 071W 21 NWNE ELMORE LIVESTOCK ELMORE #6 STOCK RESERVOIR Complete Little Powder River STO

P6532.0S 11/28/1969 051N 071W 21 NWNE ELMORE LIVESTOCK ELMORE #8 STOCK RESERVOIR Complete Little Powder River STO

P5725.0S 10/12/1966 051N 071W 27 NWSW TOTAL CONSTRUCTION ELMORE #1 STOCK RESERVOIR Complete Elmore Draw STO

P6529.0S 11/28/1969 051N 071W 28 NWNE ELMORE LIVESTOCK ELMORE #5 STOCK RESERVOIR Complete Elmore Draw STO

P8898.0R 08/22/1984 051N 071W 32 SENW LANDRICA DEVELOPMENT CO. RAILROAD LOOP TS-1 CONTAINMENT 

RESERVOIR Complete Railroad Loop Draw (Drainage of)

CNG_SW; 

IND_SW

P13782.0R 04/12/2010 051N 071W 32 SENE LANDRICA DEVELOPMENT COMPANY FACILITIES AREA SEDIMENT POND #7 

RESERVOIR Complete Facilities Area Draw IND_SW

P13783.0R 04/19/2010 051N 071W 32 SENW LANDRICA DEVELOPMENT COMPANY RAILROAD LOOP SEDIMENT POND #6 

RESERVOIR Complete Railroad Loop Draw IND_SW

P8020.0R 03/27/1979 051N 071W 33 NENW GREEN BRIDGE HOLDINGS INC FT. UNION SEDIMENT POND NO. 4 

RESERVOIR Complete Little Prairie Creek IND_SW; STO

P5798.0S 01/11/1967 051N 071W 34 NWNE EUGENE D AND PHYLLIS SPRINGEN BLACK BUTTE STOCK RESERVOIR Complete Elmore Draw STO

CR CR05/146 01/11/1967 051N 071W 34 NWNE EUGENE D SPRINGEN Black Butte Stock Reservoir Elmore Draw STO

P11561.0D 11/13/1912 051N 072W 25 SWNW A. S.FRENCH Rabbit Ditch Rabbit Draw IRR_SW

P13200.0D 07/10/1915 051N 072W 25 SESW ANDREW S.FRENCH Duck Ditch Little Powder River IRR_SW

CR CC36/246 11/13/1912 051N 072W 25 SWSW A. S.FRENCH Sage Hen Ditch Sage Hen Draw IRR_SW
Appendix D

Dry Fork Mine A2Tr1 EA D-2

Permit No. Priority Twn Rng Sec Qtr-Qtr Applicant Facility Name Status Stream Source Uses

CR CR36/247 11/13/1912 051N 072W 25 SWSW A. S.FRENCH Sage Hen Reservoir Sage Hen Draw IRR_SW

P11562.0D 11/13/1912 051N 072W 26 SWSW A.S.FRENCH Sage Hen Ditch Sage Hen Draw IRR_SW 

P12220.0D 04/12/1913 051N 072W 36 SWNW A.S.FRENCH Moyer Dry Fork Little 

Powder River IRR_SW 

P2576.0R 04/12/1913 051N 072W 36 SWNW A S.FRENCH MOYER RESERVOIR Complete Dry Fork Little 

Powder River

DOM_SW; 

IRR_SW

P2577.0R 04/12/1913 051N 072W 36 SWNW A S.FRENCH STORAGE RESERVOIR Complete Dry Fork Little 

Powder River

DOM_SW; 

IRR_SW

CR CR37/324 04/12/1913 051N 072W 36 SWNW A. S.FRENCH Storage Reservoir Dry Fork Little 

Powder River

DOM_SW; 

IRR_SW

CR CR37/325 04/12/1913 051N 072W 36 SWNW A. S.FRENCH Moyer Reservoir Dry Fork Little 

Powder River

DOM_SW; 

IRR_SW

CR CR37/326 04/12/1913 051N 072W 36 SWNW LUELLA MOYER Storage Reservoir Dry Fork Little 

Powder River

DOM_SW; 

IRR_SW

CR CR37/327 04/12/1913 051N 072W 36 SWNW LUELLA MOYER Moyer Reservoir Dry Fork Little 

Powder River

DOM_SW; 

IRR_SW

CR CC37/336 04/12/1913 051N 072W 36 SWNW LUELLA MOYER Moyer Dry Fork Little 

Powder River IRR_SW

CR CC37/337 04/12/1913 051N 072W 36 SWNW A. S.FRENCH Moyer Dry Fork Little 

Powder River IRR_SW
Appendix D

Dry Fork Mine A2Tr1 EA D-3

Groundwater Rights within 2 Miles of A2Tr1 Tract

Permit 

No. Priority Twn Rng Sec Qtr-Qtr Applicant Facility Name Status Uses Yld. TD (Ft)

P22983.0P 07/31/1963 050N 071W 3 NWSE PHYLLIS A. SPRINGEN SPRINGEN #1 Complete STK 10 420

P204916.0W 11/17/2015 050N 071W 3 NENE ERIC FALLON FALLON #1 Incomplete DOM_GW; 

STK 25

P22987.0P 12/31/1944 050N 071W 4 SENW PHYLLIS A. SPRINGEN SPRINGEN #5 Complete STK 15 90

P21674.0P 03/31/1955 050N 071W 5 SWNW Arthur J. & Edna E. Burkhardt JINGLES #1 Complete STK 10 80

P21676.0P 12/31/1925 050N 071W 5 SWNW Arthur J. & Edna E. Burkhardt JINGLES #2 Complete DOM_GW; 

STK 15 60

P21677.0P 09/30/1943 050N 071W 5 NWSW Arthur J. & Edna E. Burkhardt CORRAL #1 Complete STK 4 100

P40362.0W 08/29/1977 050N 071W 5 SENW ARTHUR BURKHARDT JACK #1 Complete STK 10 300

P6536.0W 09/18/1970 050N 071W 5 NWSW ARTHUR J. BURKHARDT JINGLES #1 Complete STK 3 744

P24358.0W 09/10/1973 050N 071W 6 NENW JEAN M. RYAN JEAN M RYAN #2 Complete STK 5 50

P24662.0P 09/10/1973 050N 071W 6 SWNE JOE KAWULOK JAY KAY #1 Complete STK 10 250

P24663.0P 09/10/1973 050N 071W 6 SESE JOE KAWULOK JAY KAY #2 Complete STK 3 240

P24664.0P 09/10/1973 050N 071W 6 SWSE JOE KAWULOK JAY KAY #3 Complete STK 2 80

P31460.0W 11/06/1975 050N 071W 6 SENE JOE KAWULOK BINKY #1 Complete DOM_GW; 

STK 20 700

P33655.0W 06/04/1976 050N 071W 7 NENE Carter Oil Co. TCOC #201 Complete STK 25 292

CR 

UW03/300 12/08/1975 050N 071W 9 SENW WYO BOARD LAND COMMISSIONERS EAST GILLETTE MINE #6 MIS 30

CR 

UW03/301 01/05/1976 050N 071W 9 SENW WYO BOARD LAND COMMISSIONERS EAST GILLETTE MINE #10 MIS 100

CR 

UW04/194 05/19/1978 050N 071W 9 NESW WYO BOARD LAND COMMISSIONERS EAST GILLETTE MINE #13 MIS 125

P32378.0P 03/03/1976 050N 071W 10 SENW WANDA L. BRICKER BRICKER #1 Complete STK 5 235

P191997.0W 12/21/2009 050N 071W 10 NWNW CRYSTAL PLUMB PLUMB #1 STOCK WELL Complete STK 15 565

P193976.0W 09/24/2010 050N 071W 10 NWNW CRYSTAL PLUMB ENL PLUMB #1 STOCK WELL Complete STK 0

P104994.0W 02/06/1997 050N 072W 1 SWSW JIMS WATER SERVICE, INC FORT UNION LTD 1-14-1 Complete CBM 27 329

P40835.0W 11/16/1977 050N 072W 1 SWNE CARTER OIL COMPANY PT 2 Complete MON 0 270

P105275.0W 03/17/1997 050N 072W 2 NWSW JIMS WATER SERVICE, INC DRY FORK COAL 1-13-2 Complete CBM 26.5 373

P111496.0W 08/17/1998 050N 072W 2 NWSW Lance Oil & Gas Co. Enl Dry Fork Coal 1-13-2 Incomplete CBM; MIS; 

STK

P178174.0W 10/26/2006 050N 072W 2 NESW HIGH PLAINS GAS, LLC DRY FORK 23-2-5072 Complete CBM; MIS 32 372

P178689.0W 11/14/2006 050N 072W 2 NWNW HIGH PLAINS GAS, LLC EAGLE BUTTE 11-2-5072 Incomplete CBM; MIS 60

P101308.0W 12/18/1995 050N 072W 11 NWSW WRANGLER ESTATES INC ENL MAKI NO. 1 WELL Fully 

Adjudicated MIS 35 1,620
Appendix D

Dry Fork Mine A2Tr1 EA D-4

Permit 

No. Priority Twn Rng Sec Qtr-Qtr Applicant Facility Name Status Uses Yld. TD (Ft)

P105001.0W 02/06/1997 050N 072W 11 NENW JIMS WATER SERVICE, INC BARBARA B HOGUE TRUST 4-21-11 Complete CBM 26 380

P131454.0W 11/22/2000 050N 072W 11 NWSW WESTERN GAS RESOURCES, INC. MGU NO.9 11-50N-72W CBM; STK 0 8,220

P132906.0W 01/25/2001 050N 072W 11 NWSW WRANGLER ESTATES INC ENL MAKI NO. 1 WELL Fully 

Adjudicated MIS 5

P132907.0W 01/25/2001 050N 072W 11 SENW WRANGLER ESTATES INC MAKI #2 Fully 

Adjudicated MIS 35 2,100

P141488.0W 12/27/2001 050N 072W 11 NWNW THUNDER CREEK GAS SERVICES, LLC TC-MW1 Complete MON 0 26

P141489.0W 12/27/2001 050N 072W 11 NWNW THUNDER CREEK GAS SERVICES, LLC TC-MW2 Complete MON 0 26

P141490.0W 12/27/2001 050N 072W 11 NWNW THUNDER CREEK GAS SERVICES, LLC TC-MW3 Complete MON 0 33

P141491.0W 12/27/2001 050N 072W 11 NWNW THUNDER CREEK GAS SERVICES, LLC TC-MW4 Complete MON 0 26

P154686.0W 10/23/2003 050N 072W 11 NENW THUNDER CREEK GAS SERVICES, LLC TC-MW5-TC-MW14 Complete MON 0 33

P154687.0W 10/23/2003 050N 072W 11 NWNW THUNDER CREEK GAS SERVICES, LLC TC-MW15-TC-MW21 Complete MON 0 34

P20318.0W 03/13/1973 050N 072W 11 SWSE ROBERT MAUL MAUL #1 Complete DOM_GW 20 420

P34327.0W 07/16/1976 050N 072W 11 SWSE SHELDON ANDERSON WRIGHT #1 Complete DOM_GW 20 168

P66935.0W 04/12/1984 050N 072W 11 SWSE WALLY & GEORGIA CASH CASH #1 Complete DOM_GW 24 1,228

P69546.0W 03/07/1985 050N 072W 11 SWSW TERRY & BONNIE GLADSON 1 GLADSON Complete DOM_GW 10 638

P70505.0W 06/27/1985 050N 072W 11 SWSE WALLY & GEORGIA CASH ENL CASH #1 Complete STK 0 1,228

P93598.0W 12/01/1993 050N 072W 11 NWSW WRANGLER ESTATES INC MAKI NO. 1 WELL Fully 

Adjudicated

DOM_GW; 

STK 25 1,620

P95667.0W 06/20/1994 050N 072W 11 NWSW Wyo State Water Development Commission G-MON-7 Complete MON 0 1,584

P189564.0W 08/11/2008 050N 072W 11 NWSW RODNEY MAKI 3RD ENL. MAKI #1 Incomplete MIS 85

P189569.0W 12/22/2008 050N 072W 11 NWSW RODNEY MAKI 1ST ENL MAKI #2 Incomplete MIS 0

CR 

UW15/180 12/01/1993 050N 072W 11 NWSW WRANGLER ESTATES, INC. MAKI NO. 1 WELL Fully Adjudicated

DOM_GW; 

STK 25

CR 

UW15/181 12/18/1995 050N 072W 11 NWSW WRANGLER ESTATES, INC. ENL. MAKI NO. 1 WELL Incomplete MIS 35

CR 

UW15/182 08/11/1998 050N 072W 11 NWSE PHILIP HOY PHILIP'S NO. 2 WELL Fully Adjudicated MIS 50

CR 

UW15/183 01/25/2001 050N 072W 11 NWSW WRANGLER ESTATES, INC. ENL. MAKI NO. 1 WELL Fully Adjudicated MIS 5

CR 

UW15/184 01/25/2001 050N 072W 11 SENW WRANGLER ESTATES, INC. MAKI NO. 2 WELL Fully Adjudicated MIS 35

P107571.0W 07/28/1997 050N 072W 12 NESW JIMS WATER SERVICE, INC FORT UNION LTD. 4-23-12 Complete CBM 24 178

P107573.0W 07/28/1997 050N 072W 12 NWNE JIMS WATER SERVICE, INC FORT UNION LTD. 5-31-12 Complete CBM 23.5 305

P107574.0W 07/28/1997 050N 072W 12 NENW JIMS WATER SERVICE, INC FORT UNION LTD. 2-21-12 Complete CBM 26 275

P168472.0W 06/06/2005 050N 072W 12 SWSE L & J OPERATING, INC KLUVER 15-12 (API NUMBER 551178) CBM; 

IRR_GW 5.5
Appendix D

Dry Fork Mine A2Tr1 EA D-5

Permit 

No. Priority Twn Rng Sec Qtr-Qtr Applicant Facility Name Status Uses Yld. TD (Ft)

P43845.0W 06/13/1978 051N 071W 20 SESE DELZER CONST 21-13C-OB2 MIS 0 85

P53133.0W 07/25/1980 051N 071W 20 SWNW GLADYS STEPHENSON S W 1 Complete MON 0 160

P22990.0P 12/31/1943 051N 071W 27 NWNE PHYLLIS A. SPRINGEN SPRINGEN #8 Complete STK 7.5 5

P107860.0W 10/15/1997 051N 071W 28 SENE BELLE FOURCHE PIPELINE CO. ER-1 Complete MON 0 20

P107861.0W 10/15/1997 051N 071W 28 SENE BELLE FOURCHE PIPELINE CO. ER-2 Complete MON 0 20

P107862.0W 10/15/1997 051N 071W 28 SENE BELLE FOURCHE PIPELINE CO. ER-3 Complete MON 0 20

P107863.0W 10/15/1997 051N 071W 28 NESE BELLE FOURCHE PIPELINE CO. ER-4 Complete MON 0 20

P14810.0W 07/21/1972 051N 071W 28 NESE Amoco Production Co. SPRINGEN RANCH WATER SUPPLY #2 Fully 

Adjudicated IND_GW 450 3,620

P22985.0P 12/31/1944 051N 071W 28 NENW PHYLLIS A. SPRINGEN SPRINGEN #3 Complete STK 15 85

P22988.0P 12/31/1955 051N 071W 28 SENW PHYLLIS A. SPRINGEN SPRINGEN #6 Complete DOM_GW; 

STK 15 25

P22989.0P 12/31/1953 051N 071W 28 SENW PHYLLIS A. SPRINGEN SPRINGEN #7 Complete DOM_GW 15 25

P5227.0W 04/10/1970 051N 071W 28 SESE N. C. GINTHER GASOLINE PLANTS GINTHER #1 DOM_GW; 

IND_GW 10 578

P56344.0W 08/11/1980 051N 071W 28 NWNW ELMORE LIVESTOCK COMPANY FT UNION #2 E Complete STK 25 22

CR 

UW02/296 07/21/1972 051N 071W 28 NESE AMOCO PRODUCTION CO. SPRINGEN RANCH WATER SUPPLY #2 IND_GW 450

P182018.0W 04/25/2007 051N 071W 29 NENW BASIN ELECTRIC POWER COOPERATIVE LANCE-FOX HILLS MONITOR #1 Complete MON 0 3,754

P182039.0W 08/18/2006 051N 071W 29 SENW BASIN ELECTRIC POWER COOPERATIVE LANCE-FOX HILLS NO. 2 WELL Fully 

Adjudicated IND_GW; MIS 525 3,628

P22991.0P 12/31/1955 051N 071W 29 SENE PHYLLIS A. SPRINGEN SPRINGEN #9 Complete STK 7.5 130

CR 

UW19/271 08/18/2006 051N 071W 29 SENW BASIN ELECTRIC POWER COOPERATIVE LANCE-FOX HILLS NO. 2 Fully Adjudicated IND_GW; MIS 525

P27745.0W 08/15/1974 051N 071W 30 NWNE PEABODY T H C MIS -1 171

P130688.0W 11/03/2000 051N 071W 31 NWNE RMG I, LLC WALLS 31-31-A Complete CBM 25 398

P131854.0W 12/29/2000 051N 071W 31 NWNE RMG I, LLC ENL Walls 31-31-A Complete CBM 75 398

P131855.0W 12/29/2000 051N 071W 31 SWNE RMG I, LLC ENL Walls 31-32-A Complete CBM 75 453

P131856.0W 12/29/2000 051N 071W 31 NWSE RMG I, LLC ENL Walls 31-33 Complete CBM 75 571

P6523.0P 12/31/1949 051N 071W 31 SWSE GLENN M. GROVES SHAW #1 Complete STK 2 180

P6525.0P 08/21/1968 051N 071W 31 SWSW JEAN RYAN RYAN #1 Complete STK 10 19

P101307.0W 11/13/1995 051N 071W 32 SWSE LANDRICA DEVELOPMENT COMPANY KFX-4

Fully 

Adjudicated MIS 200 1,747

P101309.0W 01/05/1996 051N 071W 32 NWNE LANDRICA DEVELOPMENT COMPANY MED #3 Fully 

Adjudicated MIS 25 144

P107664.0W 09/17/1997 051N 071W 32 NWSE LANDRICA DEVELOPMENT COMPANY ENL KFX-4

Fully 

Adjudicated IND_GW; MIS 20 1,747
Appendix D

Dry Fork Mine A2Tr1 EA D-6

Permit 

No. Priority Twn Rng Sec Qtr-Qtr Applicant Facility Name Status Uses Yld. TD (Ft)

P108950.0W 02/20/1998 051N 071W 32 SWNE GREEN BRIDGE HOLDINGS, INC KFP-1 Complete MON 0 137

P2267.0W 07/26/1968 051N 071W 32 SWSW GLENN M. GROVES GROVES #1 Complete DOM_GW; 

STK 18 738

P26527.0W 04/29/1974 051N 071W 32 NESE REX MONAHAN SPRINGEN RANCH MUDDY FORMATION 

UNIT BATTERY #2 IND_GW 300 -1

P6524.0P 12/11/1959 051N 071W 32 SWSW GLENN M. GROVES SHAW #2 Complete STK 2 311

P76017.0W 11/19/1987 051N 071W 32 NWSE LANDRICA DEVELOPMENT COMPANY ENERGY BROTHERS #1 Fully 

Adjudicated MIS 45 843

CR 

UW10/294 01/05/1996 051N 071W 32 NWNE ENERGY DEVELOPMENT CO. MED #3 MIS 25

CR 

UW10/338 11/13/1995 051N 071W 32 ENERGY DEVELOPMENT CO. KFX-4 IND_GW; MIS 200

CR 

UW10/339 09/17/1997 051N 071W 32 ENERGY DEVELOPMENT CO. ENL KFX-4 IND_GW; MIS 20

P197516.0W 02/17/2012 051N 071W 32 NWNE QUALITY ENVIRONMENTAL TECH 

SOLUTIONS, LLC QE #1 Incomplete MIS 25

P21675.0P 12/31/1943 051N 071W 33 SESW Arthur J. & Edna E. Burkhardt JINGLES #3 Complete STK 4 230

P22986.0P 12/31/1944 051N 071W 33 NWNW PHYLLIS A. SPRINGEN SPRINGEN #4 Complete STK 15 100

P26526.0W 04/29/1974 051N 071W 33 NENE REX L. MONAHAN SPRINGEN RANCH MUDDY FORMATION 

UNIT BATTERY #1 IND_GW 250 -1

P43849.0W 06/13/1978 051N 071W 33 NWNW GREEN BRIDGE HOLDINGS, INC EP 01A Complete MON 0 75

P43861.0W 06/13/1978 051N 071W 33 SESE GREEN BRIDGE HOLDINGS, INC EP-11 Complete MON 0 140

P9928.0W 07/26/1971 051N 071W 33 NENE LANDRICA DEVELOPMENT COMPANY SPRINGEN RANCH WATER SUPPLY WELL 

NO. 1

Fully 

Adjudicated IND_GW 510 3,685

CR 

UW02/292 07/26/1971 051N 071W 33 NENE AMOCO PRODUCTION CO. SPRINGEN RANCH WATER SUPPLY #1 IND_GW 625

P22984.0P 08/31/1960 051N 071W 34 NENW PHYLLIS A. SPRINGEN SPRINGEN #2 Complete STK 10 52

P140135.0W 10/16/2001 051N 072W 25 NENE RMG I, LLC RAG FED 25-41A Complete CBM 100 701

P178179.0W 10/26/2006 051N 072W 26 SESE HIGH PLAINS GAS, LLC DRY FORK 44-26-5172 Complete CBM; MIS 46 322

P178183.0W 10/26/2006 051N 072W 35 SWSE HIGH PLAINS GAS, LLC DRY FORK 34-35-5172 Complete CBM; MIS 60 360

P178184.0W 10/26/2006 051N 072W 35 SENE HIGH PLAINS GAS, LLC DRY FORK 42-35-5172 Complete CBM; MIS 54 217

P178185.0W 10/26/2006 051N 072W 35 NESE HIGH PLAINS GAS, LLC DRY FORK 43-35-5172 Complete CBM; MIS 50 244

P178186.0W 10/26/2006 051N 072W 35 SESE HIGH PLAINS GAS, LLC DRY FORK 44-35-5172 Complete CBM; MIS 60 260

P58261.0W 07/07/1981 051N 072W 36 NESW Wyo State Office of Lands & Investments DF 48 Complete MON 0 210

P58262.0W 07/07/1981 051N 072W 36 NWNW Wyo State Office of Lands & Investments DF 49 Complete MON 0 220

P69750.0W 04/21/1985 051N 072W 36 SESE MASEK OIL COMPANY MILL GILLETTE UNIT #2 IND_GW 30 8,083
APPENDIX E

DRY FORK MINE OBSERVED WILDLIFE SPECIES LIST

SPECIAL STATUS SPECIES SUMMARY TABLE

FOR FEDERAL LEASE MODIFICATION APPROVAL

WYW-0271199, WYW-0271200
Appendix E

Dry Fork Mine A2Tr1 EA Dry Fork Mine A2Tr1 EA E-1

Campbell County Species of Concern

Group Common

Name Scientific Name

Observed 

During 

Wildlife 

Surveys1

USFWS WY_BLM USFS WGFD STATE 

RANK

GLOBAL 

RANK

Amphibians Tiger Salamander Ambystoma mavortium No S4 G5

Amphibians Great Plains Toad Anaxyrus cognatus No NSSU (U) S3 G5

Amphibians Northern 

Leopard Frog Lithobates pipiens No Not Warranted for Listing (NW) Sensitive Region 2 Sensitive NSSU (U) S3 G5

Amphibians Plains Spadefoot Spea bombifrons No NSSU (U) S4 G5

Birds Northern 

Goshawk Accipiter gentilis No Not Warranted for Listing (NW) Sensitive Region 4 Sensitive NSSU (U) S2B;S3N G5

Birds Baird's Sparrow Ammodramus bairdii No Sensitive S1?B G4

Birds Grasshopper 

Sparrow Ammodramus savannarum Yes MBCC Region 2 Sensitive NSS4 (Bc) S4 G5

Birds Sprague's Pipit Anthus spragueii No Not Warranted for 

Listing (NW) SNA G4

Birds Golden Eagle Aquila chrysaetos Yes MBCC S4B;S4N G5

Birds Sagebrush 

Sparrow Artemisiospiza nevadensis No Sensitive Region 2 Sensitive NSS4 (Bc) S3 G5

Birds Short-eared Owl Asio flammeus Yes MBCC Sensitive NSS4 (Bc) S2 G5

Birds Burrowing Owl Athene cunicularia Yes MBCC Sensitive Region 2 

Sensitive NSSU (U) S4B G4

Birds Ring-necked Duck Aythya collaris No S4B G5

Birds Upland Sandpiper Bartramia longicauda Yes MBCC NSSU (U) S3B G5

Birds American Bittern Botaurus lentiginosus No MBCC Region 2 

Sensitive NSS3 (Bb) S3B G4

Birds Bufflehead Bucephala albeola No S2B G5

Birds Common Bucephala clangula Yes S3B G5
Appendix E

Dry Fork Mine A2Tr1 EA Dry Fork Mine A2Tr1 EA E-2

Group Common

Name Scientific Name

Observed 

During 

Wildlife 

Surveys1

USFWS WY_BLM USFS WGFD STATE 

RANK

GLOBAL 

RANK

Goldeneye

Birds Ferruginous Hawk Buteo regalis Yes MBCC Sensitive Region 2 

Sensitive NSSU (U) S4B;S5N G4

Birds Swainson’s Hawk Buteo swainsoni Yes MBCC S4B G5

Birds Chestnut-collared 

Longspur Calcarius ornatus Yes Region 2 Sensitive NSS4 (Bc) S1 G5

Birds Greater SageGrouse Centrocercus urophasianus Yes

Not Warranted for 

Listing (NW)

MBCC

Sensitive Region 4 

Sensitive NSS2 (Ba) S4 G3G4

Birds Mountain Plover Charadrius montanus No

Not Warranted for 

Listing (NW)

MBCC

Sensitive Region 2 

Sensitive NSSU (U) S2B;S3B G3

Birds Black-billed 

Cuckoo Coccyzus erythropthalmus No S2 G5

Birds Bobolink Dolichonyx oryzivorus No NSS4 (Bc) S2 G5

Birds Merlin Falco columbarius Yes NSSU (U) S3B;S4N G5

Birds Prairie Falcon Falco mexicanus Yes MBCC

Birds Peregrine Falcon Falco peregrinus No Delisted; formally 

monitored (DM) Sensitive Region 4 Sensitive NSS3 (Bb) S2 G4

Birds Common Loon Gavia immer No Region 4 

Sensitive NSS1 (Aa) S1B;S2N G5

Birds Whooping Crane Grus americana No

Listed Endangered 

(LE); and 

Endangered -

Nonessential 

Experimental 

Population (LEXN)

SH G1

Birds Sandhill Crane Grus canadensis No NSS4 (Bc) S3B;S5N G5
Appendix E

Dry Fork Mine A2Tr1 EA Dry Fork Mine A2Tr1 EA E-3

Group Common

Name Scientific Name

Observed 

During 

Wildlife 

Surveys1

USFWS WY_BLM USFS WGFD STATE 

RANK

GLOBAL 

RANK

Birds Pinyon Jay Gymnorhinus cyanocephalus No MBCC

Birds Bald Eagle Haliaeetus leucocephalus Yes

Delisted; formally 

monitored (DM)

MBCC

Sensitive Region 4 

Sensitive NSS2 (Ba) S3B;S5N G5

Birds Black-necked Stilt Himantopus mexicanus No S3B G5

Birds Dark-eyed Junco Junco hyemalis No S5B;S5N G5

Birds White-winged 

Junco Junco hyemalis aikeni Yes S3S5BS5N G5T4

Birds Loggerhead Shrike Lanius ludovicianus Yes MBCC Sensitive Region 2 

Sensitive S3 G4

Birds Herring Gull Larus argentatus Yes SNA G5

Birds California Gull Larus californicus No S2B G5

Birds Ring-billed Gull Larus delawarensis No MBCC S2 G5

Birds Black Rosy-Finch Leucosticte atrata No MBCC NSSU (U) S3S5BS5N G4

Birds Eastern ScreechOwl Megascops asio No S3 G5

Birds Lewis's 

Woodpecker Melanerpes lewis No Region 2 Sensitive NSSU (U) S2 G4

Birds Long-billed 

Curlew Numenius americanus Yes MBCC Sensitive Region 2 Sensitive NSS3 (Bb) S3B G5

Birds Sage Thrasher Oreoscoptes montanus Yes MBCC Sensitive NSS4 (Bc) S5 G5

Birds Osprey Pandion haliaetus No S3B G5

Birds American White 

Pelican Pelecanus erythrorhynchos No S1B G4

Birds Red-necked 

Phalarope Phalaropus lobatus No S3N G4G5

Birds Rose-breasted 

Grosbeak Pheucticus ludovicianus No S1 G5
Appendix E

Dry Fork Mine A2Tr1 EA Dry Fork Mine A2Tr1 EA E-4

Group Common

Name Scientific Name

Observed 

During 

Wildlife 

Surveys1

USFWS WY_BLM USFS WGFD STATE 

RANK

GLOBAL 

RANK

Birds White-faced Ibis Plegadis chihi No Sensitive NSS3 (Bb) S1B G5

Birds Virginia Rail Rallus limicola No NSS3 (Bb) S3B G5

Birds American Avocet Recurvirostra americana Yes S3B G5

Birds Golden-crowned 

Kinglet Regulus satrapa Yes S3B;S4N G5

Birds McCown's 

Longspur Rhynchophanes mccownii Yes MBCC Region 2 Sensitive NSS4 (Bc) S2 G4

Birds Eastern Bluebird Sialia sialis No S2 G5

Birds Pygmy Nuthatch Sitta pygmaea Yes NSSU (U) S2 G5

Birds Dickcissel Spiza americana No MBCC NSS4 (Bc) S1 G5

Birds Brewer's Sparrow Spizella breweri No MBCC Sensitive Region 2 

Sensitive NSS4 (Bc) S5 G5

Birds Clay-colored 

Sparrow Spizella pallida No S3B G5

Birds Forster's Tern Sterna forsteri No NSS3 (Bb) S1 G5

Birds Common Tern Sterna hirundo No S1 G5

Birds Barn Owl Tyto alba No S2 G5

Mammals Plains Bison Bos bison No Not Warranted for 

Listing (NW) S1 G4TU

Mammals Gray Wolf Canis lupus No

Listed Threatened -

Nonessential 

Experimental 

Population (LTXN)

Region 4 

Sensitive S1 G4G5

Mammals Black-tailed 

Prairie Dog Cynomys ludovicianus No Not Warranted for Listing (NW) Sensitive Region 2 Sensitive S2 G4
Appendix E

Dry Fork Mine A2Tr1 EA Dry Fork Mine A2Tr1 EA E-5

Group Common

Name Scientific Name

Observed 

During 

Wildlife 

Surveys1

USFWS WY_BLM USFS WGFD STATE 

RANK

GLOBAL 

RANK

Mammals Thirteen-lined 

Ground Squirrel Ictidomys tridecemlineatus No S5 G5

Mammals Black-footed 

Ferret Mustela nigripes No

Listed Endangered 

(LE); and 

Endangered -

Nonessential 

Experimental 

Population (LEXN)

NSS1 (Aa) S1 G1

Mammals Western Smallfooted Myotis Myotis ciliolabrum No NSS4 (Cb) S3B G5

Mammals Long-eared 

Myotis Myotis evotis No Sensitive NSS3 (Bb) S4 G5

Mammals Northern Longeared Bat Myotis septentrionalis No Listed Threatened 

(LT) NSS3(Bb) S1BS1N G2G3

Mammals Little Brown 

Myotis Myotis lucifugus No Petition Under Review (UR) NSS4 (Cb) S3 G3

Mammals Long-legged 

Myotis Myotis volans No NSS3 (Bb) S3B G5

Mammals Olive-backed 

Pocket Mouse Perognathus fasciatus No NSS4 (Cb) S4 G5

Mammals White-footed 

Deermouse Peromyscus leucopus No S3 G5

Mammals Dwarf Shrew Sorex nanus No NSS3 (Bb) S4 G4

Mammals Plains Spotted 

Skunk Spilogale putorius interrupta No Petition Under Review (UR) S3 G4T4

Mammals Grizzly Bear Ursus arctos No

Listed Threatened 

(LT) – Proposed for 

Delisting (PDL)

S1 G4T4

Mammals Swift Fox Vulpes velox No Not Warranted for 

Listing (NW) Sensitive Region 2 Sensitive NSS4 (Cb) S2 G3
Appendix E

Dry Fork Mine A2Tr1 EA Dry Fork Mine A2Tr1 EA E-6

Group Common

Name Scientific Name

Observed 

During 

Wildlife 

Surveys1

USFWS WY_BLM USFS WGFD STATE 

RANK

GLOBAL 

RANK

Reptiles Eastern Spiny 

Softshell Apalone spinifera No NSS4 (Bc) S4 G5T5

Reptiles Eastern Yellowbellied Racer

Coluber constrictor 

flaviventris No S4 G5T5

Reptiles Pale Milksnake Lampropeltis triangulum 

multistriata No NSS3 (Bb) S3 G5TNR

Reptiles Bullsnake Pituophis catenifer sayi No S4 G5T5

Reptiles Plains 

Gartersnake Thamnophis radix No NSSU (U) S5 G5

Reptiles Red-sided 

Gartersnake

Thamnophis sirtalis 

parietalis No NSSU (U) S5 G5T5

1 Highlights indicates species has been observed during DFM wildlife surveys

MBCC – Migratory Birds of Conservation Concern

USFS:

Region 2 Sensitive, R2 - In Wyoming, sensitive in Bighorn, Black Hills, Medicine Bow, and Shoshone National Forests, and Thunder Basin National Grassland

Region 4 Sensitive, R4 - In Wyoming, sensitive in Bridger-Teton, Caribou, Targhee, Wasatch-Cache, and Ashley (including Flaming Gorge National Recreation Area) National Forests

WGFD:

NSS1-NSS4:

The NSS rank of the species is subtracted from 5 and multiplied by 6: [(5-NSS)x6]. This would result in scores of NSS1 = 24, NSS2 = 18, NSS3 = 12, NSS4 = 6.

The species is assigned a score of 1-10 based on the variable "Wyoming's contribution to the species' overall conservation"; 10 being the highest contribution and 1 being the lowest contribution. The WYNDD 

G rank (global chance of extinction) and Wyoming Conservation Contribution score were consulted in determining this score. The species is assigned a score of 1-5; 5 being the highest and 1 the lowest for 

each of the following variables:

Regulatory/monetary impacts of the species' listing under the Endangered Species Act.

Urgency of conservation action.

Ability to implement effective conservation actions.

The species' ecological or management role as a keystone, indicator, or umbrella species.

Rank: 

G = Global rank assigned by NatureServe: range-wide probability of extinction for a species

S = Subnational (state/jurisdiction) rank assigned by WYNDD biologists for Wyoming

T = Trinomial rank: refers to the range-wide probability of extinction for a subspecies or variety

These letters are each followed by a numeric, 1-5 score: 

1 = critically imperiled

2 = imperiled

3 = vulnerable

4 = apparently secure

5 = secure

Source: WYNDD (2016)
Appendix E

APPENDIX F

STATE AND FEDERAL REVENUE CALCULATIONS 
Appendix F

Dry Fork Mine A2Tr1 EA F-1

Estimated 2016 Fiscal Revenue from 2015 Coal Production in Campbell Co. (Million U.S. Dollars)

Revenue Source Total Collected Federal Revenue State Revenue

Federal Mineral Royalties 564.2 282.1 282.1

Abandoned Mine Lands Fund 95.4 67.4 28.0

Severance Tax 241.1 241.1

Bonus Bid Annual Revenues 307.9 153.9 153.9

Ad Valorem Tax 187.6 187.6

Black Lung 182.1 182.1

Sales and Use Tax 29.8 29.8

Totals 1,608.0 685.5 922.5

$/Ton $2.48

Total Future Revenues from DFM (No Action Alternative) (Million U.S. Dollars)

Revenue Source Total Collected Federal Revenue State Revenue

Federal Mineral Royalties 117.9 59.0 59.0

Abandoned Mine Lands Fund 19.9 10.0 10.0

Severance Tax 49.1 49.1

Bonus Bid Annual Revenues 0.0 0.0 0.0

Ad Valorem Tax 39.20 39.2

Black Lung 39.16 39.2

Sales and Use Tax 5.7 5.7

Totals 271.0 108.1 162.9

$/Ton $2.29

Future Revenues added by the A2Tr1 Tract only (Million U.S. Dollars)

Revenue Source Total Collected Federal Revenue State Revenue

Federal Mineral Royalties 53.6 26.8 26.8

Abandoned Mine Lands Fund 9.1 4.5 4.5

Severance Tax 20.9 20.9

Bonus Bid Annual Revenues 0.0 0.0 0.0

Ad Valorem Tax 17.8 17.8

Black Lung 17.8 17.8

Sales and Use Tax 2.6 2.6

Totals 121.8 49.1 72.7

$/Ton $2.25

Total Future Revenues from DFM (existing mine plus A2Tr1 tract) (Million U.S. Dollars)

Revenue Source Total Collected Federal Revenue State Revenue

Federal Mineral Royalties 171.5 85.8 85.8

Abandoned Mine Lands Fund 29.0 14.5 14.5

Severance Tax 70.0 70.0

Bonus Bid Annual Revenues 0.0 0.0 0.0

Ad Valorem Tax 57.0 57.0

Black Lung 57.0 57.0

Sales and Use Tax 8.3 8.3

Totals 171.5 85.8 85.8

$/Ton $2.27
Appendix F

Dry Fork Mine A2Tr1 EA F-2

Difference Between the No Action Alternative and the Proposed Action (Million U.S. Dollars)

Revenue Source Total Collected Federal Revenue State Revenue

Federal Mineral Royalties 53.6 26.8 26.8

Abandoned Mine Lands Fund 9.1 4.5 4.5

Severance Tax 20.9 20.9

Bonus Bid Annual Revenues 0.0 0.0 0.0

Ad Valorem Tax 17.8 17.8

Black Lung 17.8 17.8

Sales and Use Tax 2.6 2.6

Totals 121.8 49.1 72.7

Estimated 2022 Campbell Co. Fiscal Revenue (Million U.S. Dollars)

Revenue Source Total Collected Federal Revenue State Revenue

Federal Mineral Royalties 600.6 300.3 300.3

Abandoned Mine Lands Fund 101.5 50.8 50.8

Severance Tax 234.7 234.7

Bonus Bid Annual Revenues 0.0 0.0 0.0

Ad Valorem Tax 199.7 199.7

Black Lung 199.4 199.4

Sales and Use Tax 29.0 29.0

Totals 1,364.9 550.5 814.4

$/Ton $2.25

All revenues were calculated using variables presented below
Appendix F

Dry Fork Mine A2Tr1 EA F-3

Bonus Bid Payments, 2008-2017

Source: BLM 2017. Bids are paid off in equal four annual payments, after the initial 1/5 amount payment attached to the bid. 

Revenue Variables

Coal Surface # Units of Taxable 

Valuation

Taxable 

Valuation

Taxable Valuation 

Per Unit

Average Tax 

Levy (Mills)

Estimated Ad 

Valorem Tax Levied

Average Tax 

Per Unit

Sev. Tax 

Rate %

Estimated Severance 

Tax Collectible

Average Sev. 

Tax Per Unit

2015 Wyoming 392,418,629 $3,894,432,347 9.92 $0.059925 $233,373,858 0.5947 0.07 $272,610,264 $0.6947

2015 Campbell Co. 358,196,669 $3,348,921,099 9.35 $0.059592 $199,568,906 0.5571 0.07 $234,424,477 $0.6545

2016 Wyoming 372,577,808 $3,646,317,231 9.79 $0.059910 $218,450,865 0.5863 0.07 $255,242,206 $0.6851

2016 Campbell Co. 340,675,046 $3,149,810,399 9.25 $0.059554 $187,583,809 0.5506 0.07 $220,486,728 $0.6472

Source: WDOR 2015 and 2016a

Bonus Bids Lease-Month Tons Total Bid $/Ton 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

WYW155132 Eagle Butte 

West - May 255,000,000 $180,540,000.00 $0.71 $36,108,000.00 $36,108,000.00 $36,108,000.00 $36,108,000.00 $36,108,000.00

$144,432,000.00 $108,324,000.00 $72,216,000.00 $36,108,000.00 $0.00

WYW174407 South Maysdorf 

- August 288,100,000 $250,800,000.00 $0.87 $50,160,000.00 $50,160,000.00 $50,160,000.00 $50,160,000.00 $50,160,000.00

$200,640,000.00 $150,480,000.00 $100,320,000.00 $50,160,000.00 $0.00

WYW154432 North Maysdorf 

- August 54,657,000 $48,098,424.00 $0.88 $9,619,684.80 $9,619,684.80 $9,619,684.80 $9,619,684.80 $9,619,684.80

$38,478,739.20 $28,859,054.40 $19,239,369.60 $9,619,684.80 $0.00

WYW177903 West Antelope 

South 56,356,000 $49,311,500.00 $0.88 $9,862,300.00 $9,862,300.00 $9,862,300.00

$39,449,200.00 $29,586,900.00 $0.00

WYW163340 West Antelope 

North 350,263,000 $297,723,228.00 $0.85 $59,544,645.60 $59,544,645.60 $59,544,645.60 $59,544,645.60 $59,544,645.60

$238,178,582.40 $178,633,936.80 $119,089,291.20 $59,544,645.60 $0.00

WYW161248 Belle Ayr North 221,734,800 $210,648,060.00 $0.95 $42,129,612.00 $42,129,612.00 $42,129,612.00 $42,129,612.00 $42,129,612.00

$168,518,448.00 $126,388,836.00 $84,259,224.00 $42,129,612.00 $0.00

WYW172657 Caballo West 130,196,000 $143,417,403.80 $1.10 $28,683,480.76 $28,683,480.76 $28,683,480.76 $28,683,480.76 $28,683,480.76

$114,733,923.04 $86,050,442.28 $57,366,961.52 $28,683,480.76 $0.00

WYW174596 South Hilight 222,676,000 $300,001,011.66 $1.35 $60,000,202.33 $60,000,202.33 $60,000,202.33 $60,000,202.33 $60,000,202.33

$240,000,809.33 $180,000,607.00 $120,000,404.66 $60,000,202.33 $0.00

WYW176095 South 

Porcupine LBA 401,830,508 $446,031,864.00 $1.11 $89,206,372.80 $89,206,372.80 $89,206,372.80 $89,206,372.80 $89,206,372.80

$356,825,491.20 $267,619,118.40 $178,412,745.60 $89,206,372.80 $0.00

WYW173408 North 

Porcupine LBA 721,154,828 $793,270,311.00 $1.10 $158,654,062.20 $158,654,062.20 $158,654,062.20 $158,654,062.20 $158,654,062.20

$634,616,248.80 $475,962,186.60 $317,308,124.40 $158,654,062.20 $0.00

Average $0.98 $86,268,000.00 $95,887,684.80 $95,887,684.80 $236,107,723.16 $543,968,360.49 $457,700,360.49 $438,218,375.69 $438,218,375.69 $307,860,637.33 $0.00
Appendix F

Dry Fork Mine A2Tr1 EA F-4

Revenue Calculations Variables

Coal Production (tons)1

Campbell Wyoming

2015 Tons Produced 340,675,046 372,577,808

2022 Tons Produced (Estimated) 362,625,000 375,000,000

From Campbell Co. 91.44%

DFM Tract2(tons minable) (tons recoverable)

No Action Alternative 75,700,000 71,200,000

Added by Proposed Action 34,800,000 32,364,000

Average 2015 Sales Price ($/ton)

2015 8800 Btu Coal $13.232 $13.253

2015 Price without BLT4 $12.68 $12.70

Federal Royalties

WY share of FR = 0.5 x FR

Federal Royalties3 $564,243,044.94

Wyoming Share $282,121,522.47

Abandoned Mine Lands Funds5

Campbell AML Total $95,389,012.88

WY Share6 $28,000,000.00

Severance Taxes7

Campbell ST Rate/Ton $0.6472

2016 Severance Taxes8 $241,132,357.34

Lease Bonus Bids (2017 Payments)

2016 $307,860,637.33

2017 $0.00

2019+ $0.00

Total 2017+ Bonus Bid Payments $0.00

WY share $0.00

Campbell Ad Valorem Taxes7

AVT Rate/ton $0.55

AVT (Total) $187,575,680.33

Black Lung

2016 BLT Rate/Ton9 $0.534

2016 BLT Collected10 $182,058,833.01

Future BLT Rate/Ton11 $0.535

Future BLT Collected $194,094,683.91

2015 Campbell Co. Employment (mining)12

Buckskin 218

Belle Ayr 286

Eagle Butte 290

Cordero Rojo 521

Antelope 632

Caballo 133

NARM 1428

Rawhide 195

Black Thunder 1622

Coal Creek 153

Dry Fork 80

Wyodak 68

Total 5626

Federal Income Tax13

Head of Household income info:

10% on first $12,750

15% on next (up to $48,600)

Rate10 13.6%

Tax/employee $6,185.55

Fed Tax $34,799,904.30

Fiscal Year 2016 Sales and Use Tax14

Coal Mining $29,765,322

$/ton $0.08

1 Source: WDOR 2016a

2 CCW 2017

3 Calculated - Tons produced x 2014 sales price per ton x 12.5%

4 Black lung tax removed since it is included in the sale price 

5 Calculated - AML = $0.28 per ton produced - through 2021, WY share = 0.5 x AML (Max 28,000,000/yr as of September 2013), Price 

from CREG 2016

6 Calculated - Wyoming’s portion of 2015 + AML Funds (Max out at $75,000,000)

7 WDOR 2016, recalculated using Campbell Co. numbers only 

8 CREG 2016

9 Calculated - Maximum per ton rate is $0.55 [(.10)(12750) + (.15)(45487-12750)]

10 IRS 2011
Appendix F

Dry Fork Mine A2Tr1 EA F-5

11 Calculated - Rate x 2022 Estimated Production

12 WDWS 2015

13 WDOE 2013 (This is the most current doc as of March 2106)

14 WDOR 2016b