February 26, 2018
Mr. Kyle Wendtland, Administrator
Wyoming Department of Environmental Quality
Land Quality Division
200 W. 17th St., Suite 10
Cheyenne, WY 82002
RE: Draft Proposed Chapter 11 LQD Rules (proposed 11/2017)
Dear Administrator Wendtland:
Powder River Energy Corporation is northeast Wyoming’s electric service provider, serving more than
12,000 members throughout the region with reliable, efficient, and affordable electric service. A large
portion of our electricity is generated at the Dry Fork Station. We respectfully comment on the draft
Chapter 11 self-bonding regulations preliminarily proposed by the Wyoming Department of
Environmental Quality, Land Quality Division.
We are concerned that the cooperative owned Dry Fork Mine, which supplies the Dry Fork Station
power plant, would only qualify for partial self-bonding, and would have to purchase outside reclamation
performance bonding instruments under the draft proposed rules.
Cooperative mining companies are substantially different from typical Wyoming mining companies.
Risk of bankruptcy and mine abandonment is virtually nonexistent for utility or cooperative owned
mines. Cooperative owned mines are not subject to commodity price volatility and the costs to operate
cooperative owned mines are covered by the parent cooperative for the sole purpose of generating
electricity for its cooperative members.
While we appreciate the Agency’s desire to update the financial assurance regulations, we believe the
11/2017 draft proposal needs to give the Administrator the ability to allow cooperative owned mines to
self-bond at or near 100%. There is no risk of forfeiture of a self-bond guaranteed by the Dry Fork
Mine’s parent cooperatives.
Any increase in mining costs for reclamation liability instruments would ultimately increase the cost of
electricity for our members. We don’t want our rural Wyoming member-owner/customers to be impacted
by this unnecessary expense.
Thank you for this opportunity to comment on these draft proposed rules. We look forward to working
with you on the regulation process.
Sincerely,

Michael E. Easley
Chief Executive Officer
MEE/sjp