Industry Comments on MTM/VF Environmental Impact Study

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Comments on MTM/VF Environmental Impact Statement
To: WVCA Membership
From: Jason Bostic

January 21, 2006

The comment period on the draft programmatic Environmental Impact Statement issued by several federal agencies and the West Virginia Department of Environmental Protection ends at the stroke of midnight tonight. The comment period was originally scheduled to close on January 6, 2004. The Association, in conjunction with the National Mining Association, Ohio Coal Association, Kentucky Coal Association and Coal Operators and Associates filed voluminous, detailed comments on the draft EIS on January 6.

Several regional and national environmental organizations have dulged the agencies with typical "form letter" responses that provide no substantive comments but do inundate the agencies with correspondence generally opposed to mining activities in the region. In an effort to counter balance this massive response by the extremists, the Kentucky Coal Association has put together a few talking points that can be included in an e-mail response to the EIS agencies.

Please take the time today to compose an e-mail incorporating the points below or use the more specific information supplied in the Association's comments (attached) and send it to:

Mr. John Forren
U.S. Environmental Protection Agency, Region III


General discussion points: Response to draft EIS:

The mining industry supports Alternative III, as outlined in the EIS, as the preferable approach:

Based on the results of voluminous technical studies, mining has only minimal, temporary impacts to the environment of the region. As such, mining permits should be processed as Nationwide Permit 21s by the Corps of Engineers.

Any potential adverse impacts from a proposed mining operation can be addressed in the detailed and exhaustive SMCRA permitting process.

Specific comments:

1. Mining activity will only effect about 6.8% of the dense forest cover present in the region. The states in the Central Appalachian region will remain the most heavily forested states in the Nation.

2. Mining created wetlands and grassland habitats have enhanced the wildlife diversity of Central Zppalachia by providing unique habitat that is not naturally present in the region.

3. Mining is a heavily regulated enterprise and is subject to numerous federal and state laws and regulations designed to protect the environment. Several provisions of these laws positively sanction and apply directly to mountaintop mining operations.

4. The Draft EIS is a programmatic EIS and is not intended to make substantive changes to regulations or statutes.


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