On June 6, the Citizens Advisory Council to DEP issued comments on the 2003-2008 5-year report on the effects of subsidence resulting from longwall coal mining on surface structures and water resources required by Act 54 of 1994.

Here are some of the issues the CAC highlighted in its cover letter--

-- There has been steady improvement in the quality and quantity of the data collected with each successive report.  The latest report continues this positive trend and DEP and the authors are to be commended.

-- We note, however, that the report emphasizes data gathering rather than data analysis.  In order to be in compliance with Section 18.1 (b) of Act 54, DEP needs to analyze the data and determine the total effects of deep mining subsidence on surface structures and features, and on water resources, including sources of public and private water supplies.  Future reports should go beyond data gathering and provide a review and at least a preliminary analysis of these issues.

-- (A review of the report) raises numerous concerns about the impacts of deep mining and response times over the reporting period that need to be responded to and addressed.  For example, their analysis contends that, according to the latest 5-year report, less than 10 percent of damaged homes and wells actually are being repaired.  If correct, these figures alone demonstrate a loack of balance between resource and surface owners.

-- Each of the succeeding 5-year reports should address issues of cumulative impacts and trends including: What are the cumulative impacts in each category over all four reporting periods?  What trends can be discerned in the extent of damage and impacts in each category?  What trends can be discerned in resolution times over the whole time period?

-- Regarding water impacts, the focus in the reports has been on water supplies and stream segments, rather than an assessment of cumulative hydrological impacts.  Do reported claims capture impacts to natural resources, e.g. losing a spring vs. damage to aquifer, as well as consider the duration of impact, temporary vs. long term?

Report Findings

The Act  54 report complied by Schmid and Company for DEP covers the period of August 21, 2003 to August 20, 2008 and had these major findings--

-- Mining Activity: Fifty underground coal mines were active during the report’s assessment period undermining 38,256 acres of land.  Thirty-six of the mines are room-and-pillar, eight are longwall, and six are room-and-pillar mines with pillar recovery.

-- Structures Affected: The report found 456 structures and 108 lands with reported effects occurred from a total 3,735 inventoried structures and 3,587 properties.  That is 12 percent of the total structures and 3 percent of the total properties undermined.

-- Resolution of Impacts to Structures: The eight longwall mines operating in Greene and Washington counties account for almost 94 percent of the structure and 89 percent of land reported effects.  The average number of days to resolved structure reported effects was 207 days and for land 246.  Compared with other feature types, i.e. water supplies, streams, and wetlands, this is a relative low time frame.

-- Water Resource Impacts: 2,789 wells, spring, and ponds were undermined with 683 reported effects accounting for 24.5 percent of the total water supplies undermined.  Water supplies have proven a challenge but they are being resolved.  234 reported effects or 34 percent of the cases were still awaiting a final resolution.  The average number of days to resolve water supplies reported effects was 321, a considerable increase compared to structures and land reported effects. Resolution strategies for recovering water supplies are often multi-step, especially when wells and springs are being replaced.

-- Stream Segment Impacts: Fifty-five stream investigation reports occurred and 20 have been resolved.  The average number of days to resolve stream impacts was 688, nearly double the time required to resolve water supply reported effects.

A copy of the complete report is available online.  A copy of the CAC’s comments are also available online.

6/25/2012