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  • ACOEM Urges Department of Interior to Protect Water Supply from Coal Mine Waste

    November 17, 2008

    The Honorable Dirk Kempthorne
    Secretary
    U.S. Department of the Interior
    1849 C Street, NW
    Washington, DC 20240

    Dear Mr. Secretary:

    On behalf of the American College of Occupational and Environmental Medicine (ACOEM), I am writing to urge you to not issue the final regulation revising the excess spoil and coal mine waste disposal rules as well as the stream buffer zone rule. We are very concerned that the revisions recommended by the Office of Surface Mining rules will further degrade already problematic protection of national water supplies and the health of downstream communities.

    Based on the final environmental impact statement (FEIS), ACOEM believes that the regulation will not meet the stated intent to require mine operators to minimize the creation of excess coal mine waste. Therefore, I urge you to reopen the rulemakings for further public comment.

    Heavy metals, mine debris, and pollutants that come from the surface activities of coal mines do not belong in our waterways, whether intermittent or permanent. The trade off between a year of coal and many, many generations of water contamination is not reasonable. Such water pollution is partly preventable by separation of the debris from the proximity to water.

    Waterways, ground water, private wells, and community drinking water at nearby and downstream locations are already known to be affected by current mine waste disposal practices. Future reversal of lax environmental practices and undoing of historical waste dumping will prove far more expensive than the application of reasonable precautions during the extraction process.

    America's surface water and its groundwater are among its most precious resources. Clean water sources permit the growth of communities and value-added industries. They are essential to regional, sustainable agriculture. And, environmental means to protect clean water are well known and do not include dumping mine debris into permanent and intermittent streams. Short-term foreclosure on the future of clean water is not a reasonable or responsible decision. There is no reason to relax, and every reason to strengthen, current regulations which protect surface and ground water from industrial pollutants.

    The American College of Occupational and Environmental Medicine (ACOEM) represents more than 5,000 physicians and other health care professionals specializing in the field of occupational and environmental medicine. ACOEM is the pre-eminent organization of physicians who champion the health and safety of workers, workplaces, and environments.

    Thank you for your consideration of these comments.

    Sincerely,

    Robert R. Orford, MD
    President