Sample Letter for OSM stream buffer DEIS

Comment period extended through November 23, public meeting October 24 at Pellissippi State Technical Community College, Goins Auditorium, 10915 Hardin Valley Road, Knoxville, Tennessee.

Mr. David Hartos
Office of Surface Mining Reclamation & Enforcement
3 Parkway Center
Pittsburgh, PA 15220

The Draft Environmental Impact Statement issued by the Office of Surface Mining on enforcement of the stream buffer-zone rule is unacceptable. The analysis is incomplete and imbalanced. Viable alternatives were dismissed without adequate justification, leaving only minor variations of a single approach from which to choose the preferred alternative.
It is apparent that considerable biological and technical analysis went into preparing the statement, yet most of it was squandered. Much of the ecological information was discarded in deference to economic considerations, yet the economic analysis was limited only to the value of coal, disregarding the value of water for health, recreation and fisheries and disregarding the value of natural contours for flood control, tourism and forestry.
The report also makes clear the low and declining value of the relatively inaccessible, high sulfur Appalachian coal. The low quality, high cost Appalachian supply is simply not critical to our nation’s current coal reserves. A full economic analysis balancing the value of this coal against the value of the land and water must be done before a fair decision can be made on which alternatives to consider.
Because alternatives that better address the full economic picture were eliminated, it is not possible to register a different preference. Instead, I must ask that the decision be rescinded and reconsidered. A complete economic analysis will restore some of the discarded alternatives, and from there a balanced decision can be made. If that is not possible, the “no action” alternative is preferable to codifying this flawed decision.

Your name
Your address

Take a moment to share with the Office of Surface Mining your thoughts on the proposed stream buffer rule change and draft Enivornmental Impact Statement.

Phone: 412-937-2909
E-mail: dhartos@osmre.gov
Mail:
David Hartos, OSMRE
3 Parkway Center
Pittsburgh, PA 15220