Powder River Basin Resource Council (Resource Council) and many Sheridan County landowners and concerned citizens filed objections to Ramaco’s proposed Brook Mine this month. The mine is proposed approximately six miles north of Sheridan, in the scenic Tongue River Valley, an area with important agricultural and recreational attributes. Most of the objecting landowners live in close proximity to the mine and are concerned about impacts to their property, health and safety, and quality of life.
Ramaco’s coal mine permit underwent six rounds of technical review from the Department of Environmental Quality (DEQ) back in 2014-2016. After a contested hearing before the Environmental Quality Council (EQC) in 2017 and an order in favor of the Resource Council, local landowners the Fishers, and Big Horn Coal Co., the company resubmitted a revised permit application to DEQ in October 2018. The permit application then underwent another six rounds of technical review and was released for public comment in early March.
While the permit has improved over its many rounds of technical review, the Resource Council and the citizens argued that the permit application is still too vague to analyze and understand the impacts to air, land, and water resources and public health and safety. Additionally, the permit application fails to consider any cumulative impacts of Ramaco’s proposed iPark and iCam carbon manufacturing facilities, which are linked to the proposed Brook Mine. Ramaco has proposed a 39-year mine plan, but it remains unclear how much coal they will actually need and for how long.
In its comments to DEQ, the Resource Council wrote “Ramaco’s facilities are highly dependent on government funding, technology breakthroughs, and other unknowns that make them speculative. The company has not provided any justification for its 39-year proposed mine life and/or the amount of coal it proposes to mine.”
Ramaco has gone from claiming the mine would produce 6-8 million tons per year to more recently saying the mine will be on a “very limited basis” with no more than a couple hundred thousand tons a year and a handful of employees or contractors. Over the many years of mine plan review, Ramaco has never been transparent about the economic case to open a new coal mine at a time when existing mines are cutting production and a surplus of coal reserves is widely available to meet any needs. In its comments to DEQ, the Resource Council argued that the mining plan is a plan to make a plan, and it is not complete and accurate as the law requires.
The Resource Council and the Sheridan residents raised numerous concerns about impacts to water resources, and other impacts from blasting, subsidence, increased traffic, and industrial activity. Many of the landowners have lived and owned property in the historic mining area and have been there for multiple generations.
Local landowner and Resource Council Board Member Joan Tellez stated, “There is too much at stake to allow an incomplete mine plan to proceed without having sufficient data, studies, and monitoring in this historic alluvial valley. We call on the DEQ to ensure the Tongue River Valley’s preservation and protection of its inhabitants, and we will continue working to make sure that our land and water remain preserved.”
Landowners and citizens also raised concerns about impacts to the historic area and to recreational activities. The area is a popular recreation spot frequently used for fishing, hunting, hiking, canoeing, and winter sports.
“As an outdoor recreationist, I use the Tongue River corridor for boating, birding, and hiking or skiing year-round, and the proposed mine would virtually put an end to these forms of recreation,” said Resource Council Board Member Gillian Malone. “The proposed mine not only represents a completely incompatible use for this pristine area from the human standpoint, but it threatens a large number of nesting and migrating birds, including raptors and water fowl, and many other species of wildlife that occupy the Tongue River corridor.”
Along with its comments, the Resource Council also submitted reports from two technical experts.
Mike Wireman, a hydrogeologist with decades of experience reviewing mining permit applications, concluded that Ramaco failed to conduct adequate baseline monitoring to identify pre-mining conditions of critical water resources. Additionally, Wireman found that Ramaco’s mining operations will likely impact water wells, groundwater resources, and alluvial valley floors, which are important to local agricultural operations.
Dr. Jerry Marino, one of the nation’s foremost experts on mine subsidence, concluded that the permit application still fails to assess subsidence risk – the risk of the ground caving in during underground mining operations. He called on the DEQ to limit the permit application to the initial strip mining period, and to prevent permitting of any underground or highwall mining operations until subsidence risk can be better addressed.
In response to the comments, DEQ will hold a public hearing. However, the process for that public hearing is in doubt given the executive orders in response to the COVID-19 pandemic. The Resource Council argues that any public hearing should not take place until the public health restrictions on meetings with more than ten people are lifted. Otherwise, public participation opportunities for concerned citizens will be thwarted.
The Resource Council’s comments can be downloaded here. For further information, please contact the Resource Council at email@example.com.