Wetlands and Longwall Mining -- Preface

PREFACE: Who Should Read This Report

This report is directed at several audiences, at minimum including:

Anyone concerned with wetlands in Pennsylvania. This report documents the inadequacy of regulatory protection for a class of resources that are especially scarce in the southwestern counties.
Those concerned with the environmental impacts of the high-extraction (longwall and retreat) methods for the underground mining of bituminous coal. Longwall mining currently is the dominant method of coal production in Pennsylvania. This report focuses on one set of resources --- wetlands --- whose unmitigated destruction by this particular industry is routinely allowed by State regulators in contravention to State and Federal laws.
Residents of Pennsylvania coalfields, especially in Washington and Greene Counties, who are directly affected whenever the regulatory process fails to uphold the environmental protections which every Pennsylvanian has the right to expect. Residents who seek to understand and comment on mining permit applications that portend widespread environmental and social destruction in their landscape find the State permit paperwork arcane and defective and their comments routinely ignored. This report provides a guide through the longwall mining permit review process, focused on wetland resources.
Regulators of the underground coal mining industry at all levels who are charged with implementing Pennsylvania environmental laws. This report exposes State regulators' longstanding failure to protect wetlands and suggests ways to comply with existing law, including opportunities to rectify existing permit application forms.
Staffers in government agencies and private-sector organizations concerned with resource management and protection in Pennsylvania. This report shows the need for redoubled efforts to inventory and protect the wetland resources critical to the maintenance of fish, wildlife, and waterways in southwestern Pennsylvania.
Operators of underground bituminous mines and their consultants who are obligated to comply with Pennsylvania laws. This report highlights the existing laws and regulations that require wetland protection in the context of underground mining, identifies the current systematic failure to comply with those requirements, and points out what should be done.
Elected officials and office-seekers wanting to understand how environmental laws are being administered in Pennsylvania and who can provide legislative oversight. This report raises issues of serious administrative failure that need public debate and legislative scrutiny.
Environmental groups seeking opportunities to achieve environmental protection through improved compliance with existing laws, as a result of litigation if necessary. This report shows how much work needs to be done to gain compliance with existing requirements, focusing on wetlands as the tip of the iceberg with respect to longwall mining impacts.
Charitable foundations concerned with environmental protection and improving the quality of life in Appalachian coalfields. This report shows for one class of resources the kind of analysis desperately needed across the board regarding the devastating impacts of currently ongoing longwall mining.
Publicists in the news media who want to inform the public regarding environmental issues and to foster public discussion of covert environmental destruction. This report provides specific examples of serious regulatory failures and administrative unwillingness to protect wetlands that are hidden from the public, and calls for similar investigation of other impacts from longwall mining.
Academics studying environmental science, environmental impact assessment, and especially mine engineering. This report points out real-world problems that need the attention of academia, especially the engineers whose challenge is to make wetland impacts unnecessary through use of appropriate technology for mining bituminous coal.
Financial analysts and investors in the vast conglomerates that operate longwall mines. This report hints at the sizable investment needed to comply with existing laws that protect wetlands and the financial penalties to which coal mine operators would be liable if existing laws were ever enforced regarding present or past wetland destruction. To date investors have had strong marketplace incentives to provide funds for research and implementation of longwall technology that increases coal production per man hour and per acre; State regulators have not yet provided equal incentives for operators to assume the true costs of impacts heretofore imposed on the environment, on surface owners in the coalfields, and on Pennsylvania taxpayers.

In short, this report aims at a broad and diverse audience.

This report provides insight into the longstanding inability and deliberate refusal of the Bureau of Mining and Reclamation in the Pennsylvania Department of Environmental Protection to protect scarce wetlands from high-extraction coal mines. It shows which regulations are routinely ignored and where critical gaps appear in the mass of regulatory paperwork that constitutes an underground mining permit application. It shows actual examples of recent mining applications that expose the hollow pretense of State wetland protection. It points out opportunities for improvement in the regulatory process and makes recommendations for achieving genuine environmental protection through wetland inventory and disclosure followed by impact minimization and mitigation. It suggests ways to compensate for past, unregulated wetland loss as well as to guard against continuing losses in the future.

This report views wetlands as a microcosm of environmental damage as caused by high-extraction mining, and it calls for similar analysis of the myriad other impacts of this mining on the natural and human environment of southwestern Pennsylvania. It is a fundamental tenet of this report that technological measures which effectively protect wetlands will automatically provide significant protection to other social and natural resources at the same time. The residents of Appalachia have long experienced environmental destruction as a consequence of coal mining (Caudill 1976, 1963). The underground mines of southwestern Pennsylvania in the 21^st century, far from incorporating new technologies to minimize environmental and social impacts, continue to wreak environmental havoc across hundreds of thousands of acres, across the lives of surface owners, and across highways, gamelands, and other public property. If this report helps to focus public attention on one small part of the ongoing damage from coal mining---that part relating to wetlands---it will have served its purpose.

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