CITIZENS COAL COUNCIL
130 FRIEND ROAD, WASHINGTON, PA 15301 www.citizenscoalcouncil.org

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Organizations Filed Purposes: THE CITIZENS COAL COUNCIL IS A NATIONAL NETWORK THAT ADVOCATES FOR THE FULL ENFORCEMENT OF THE FEDERAL SURFACE MINING CONTROL AND RECLAMATION ACT (SMCRA) AND ITS DELEGATED STATE PROGRAMS. OUR MISSION IS TO INFORM, EMPOWER AND WORK FOR AND WITH COMMUNITIES AFFECTED BY THE MINING, PROCESSING AND USE OF COAL.

THE OFFICE OF SURFACE MINING RECLAMATION AND ENFORCEMENT (OSMRE) WATCH - IN MAY 2020 THE FEDERAL OFFICE OF SURFACE MINING, RECLAMATION & ENFORCEMENT (OSMRE) PUBLISHED PROPOSED RULEMAKING CHANGES IN THE FEDERAL REGISTER TO THE TEN-DAY NOTICE (TDN) RULE, WITH A THIRTY (30) DAY DEADLINE FOR COMMENTING AMIDST THE COVID-19 PANDEMIC. THROUGH THIS RULEMAKING, THE OSMRE IS ATTEMPTING TO TAKE AWAY CITIZEN RIGHTS WITHIN THE TDN PROCESS. THE DEPARTMENT OF THE INTERIOR REFUSED TO GRANT OUR REQUEST FOR A REASONABLE EXTENSION OF TIME FOR PREPARING THE COMMENTS. HAVING REFUSED CCC'S EXTENSION REQUEST, CCC SOUGHT OUT AND SECURED THE ASSISTANCE OF 9 EXPERT ATTORNEYS AND A FORMER DIRECTOR OF THE OSMRE IN DRAFTING EXTENSIVE AND DETAILED COMMENTS TO THE TDN RULEMAKING. WE FACILITATED CALLS AND E-MAIL EXCHANGES BETWEEN THE ATTORNEYS AND WITHIN TWO WEEKS WE SUBMITTED 65 PAGES OF FORMAL COMMENTS ON BEHALF OF COALFIELD CITIZENS. THOSE COMMENTS INCLUDED SERIOUS QUESTIONS CONCERNING THE POWER AND THE AUTHORITY OF THE ACTING ADMINISTRATION OFFICIAL IN THE OFFICE OF THE SECRETARY OF THE INTERIOR UNDER THE FEDERAL VACANCIES REFORM ACT (FVRA). COAL ASH IMPOUNDMENT - IN AUGUST 2019, SEVERAL WARREN COUNTY PA CITIZENS REACHED OUT TO CCC FOR ASSISTANCE CONCERNING THE WARREN GENERATING STATION NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT. THE GENERATING STATION HAD BEEN DEACTIVATED, BUT A FORMER COAL ASH DISPOSAL SITE CONTINUES TO DISCHARGE TOXIC POLLUTANTS INTO THE SCENIC ALLEGHENY RIVER. RECREATION IS A PRIMARY ECONOMIC ACTIVITY IN WARREN COUNTY, ESPECIALLY ON AND ALONG THE ALLEGHENY RIVER. THE NPDES PERMIT HAD EXPIRED AND WAS BEING CONSIDERED FOR RENEWAL BY THE PADEP. CCC, ALONG WITH THE ENVIRONMENTAL INTEGRITY PROJECT AND CONCERNED CITIZENS AND BUSINESS PEOPLE IN WARREN, SUBMITTED COMMENTS TO THE PADEP OPPOSING THE DISCHARGE PERMIT RENEWAL. BASED ON THE COMMENTS WE SUBMITTED, THE PADEP REDRAFTED THEIR PROPOSED CONDITIONS FOR THE NEW NPDES PERMIT. THE DRAFT NPDES PERMIT INCLUDED MORE STRINGENT MONITORING REQUIREMENTS, INCLUDING THE ADDITION OF OIL AND GREASE EFFLUENT LIMITS AND MONITORING FOR TOTAL NICKEL AND CHLORIDE. MONITORING FOR THESE PARAMETERS WAS NOT REQUIRED IN PREVIOUS NPDES PERMITS FOR THIS DISCHARGE.

PA ACT 54 - IN LATE 2019, CCC COMMISSIONED SCHMID & COMPANY, WITH EXTENSIVE SCIENTIFIC EXPERTISE IN WETLANDS AND ENVIRONMENTAL IMPACT IN THE CONTEXT OF AGENCY REGULATIONS, TO DO AN IN-DEPTH REVIEW OF THE PADEP'S 5TH ACT 54 REPORT. OUR REPORT, ENTITLED "UNDERMINING TRUST: THE COLLAPSE OF ENVIRONMENTAL PROTECTION IN PENNSYLVANIA," DETAILS THE PADEP'S FAILURES TO ENFORCE RESTRICTIONS ON LONGWALL MINING OPERATIONS IN PENNSYLVANIA.

PA ABANDONED MINE LANDS (AML)REAUTHORIZATION - CCC COLLABORATED WITH THE PA AML CAMPAIGN IN ADVOCATING FOR AML FEE COLLECTION REAUTHORIZATION. THE AML FEES ARE COLLECTED ON CURRENTLY MINED COAL FOR DISTRIBUTION TO STATES AND INDIAN TRIBES FOR RECLAMATION OF ABANDONED COAL MINES AND ASSOCIATED WATERS. THE AML FEE, ON WHICH BOTH THE FEDERAL AND STATE/TRIBAL AML PROGRAMS RELY FOR THE VAST MAJORITY OF FUNDING, IS SET TO EXPIRE IN SEPTEMBER 2021. WITHOUT THIS FUNDING SOURCE, THE STATES AND TRIBES WILL BE UNABLE TO CONTINUE OPERATING THEIR AML PROGRAMS. THE FEE COLLECTION PROGRAM MUST BE "REAUTHORIZED" BY CONGRESS.

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