Dysart Woods is, in the words of Ohio University, the ecological crown jewel of Ohio. It is among the last .004 percent of the remaining ancient forest in Ohio and it is a National Natural Landmark. But this permit would allow the undermining of every single acre of Dysart Woods, causing a disastrous destruction of this ancient forest. Trees would topple from subsidence, groundwater would be lowered, disrupting the hydrological balance and the unique value as an undisturbed remnant of what once covered 95 percent of Ohio would be lost forever.
I will show through Ohio Valley Coal Company’s own permit application why it is in violation of law and must be denied.
In Addendum to page 18, Part 2, E of OVCC’s permit, OVCC admits that it will permanently disrupt water supplies. While OVCC says that it will replace water supplies that are permanently disrupted, this will do nothing to curb the disastrous affects that this would have on Dysart Woods. In fact the streams and springs in Dysart Woods are labeled “unused.” I personally have used the springs to drink from, as has countless wildlife of scores of specie. They are not unused as OVCC claims.
OVCC admits that most springs on the ridgetops will be severely affected by longwall mining. Further, OVCC says it can leave massive voids under the ground without causing subsidence. To claim that room and pillar mining does not cause subsidence is ludicrous, as anyone who has suffered house damage from that kind of mining can readily attest. OVCC says that groundwater is located between 50 and 100 feet below the ground on ridgetops and hillsides. They further show how these aquifers feed springs. These springs are used by the giant 400-year-old trees as well as the diversity of wildlife in the ancient forest of Dysart Woods.
OVCC further admits that “the stratigraphy identified in the Geology Description section shows numerous lithologic units that are probably capable of transmitting water.” Thus, the fracturing will likely drain water to the depth of the mine, rendering it unusable for the ancient forest.
OVCC admits that, “wells, springs or streams may experience significant water loss.” OVCC further admits that “changes to individual ground water and surface water source availability are anticipated. Wells and springs may go dry, streams may flow less, ponds may de-water.”
Further OVCC admits that this can cause increases in pollution to surface water including sediment yield, acidity, total suspended solids and flooding. While at one point OVCC claims that water will only be temporarily disrupted, it later admits that it may be permanently affected.
On page 9 of the permit, OVCC states that 91 percent of the springs that they undermined in previous permits had severe decreases in flow rates that did not recover to pre-mining levels within six months.
OVCC said that we can expect that 48 percent of the wells under the –12 permit will be severely impacted by mining. Surface subsidence is approximately 66 percent of the mining height, or about 42 inches – three and a half feet. While OVCC claims that there will be no subsidence under the room and pillar mining area, such a claim is ludicrous with the plethora of scientific data showing that room and pillar mining does indeed cause subsidence and dewatering, just over a longer time that longwall mining.
In the Addendum to page 28, part 3, “Engineering and Mining techniques,” OVCC writes, “Coal pillars between the longwall mining panels crush after both adjacent longwall panels are extracted. Subsidence of the surface occurs over these panels during longwall mining as a result of the pillars crushing and from the extraction of both adjacent longwall panels.
For those areas mapped as no longwall mining areas, room-and-pillar mining is anticipated, consisting mainly of main entries and gate entries. With a maximum extraction ration of 48.7 percent, clearly there will be subsidence. Any claim of no subsidence violates the basic knowledge of deep mining that we have today.
In fact, in a study that OVCC included in their permit by P-squared, “Effects of longwall mining on forested areas, longwall mining is described to be preferred to room and pillar because it “provides a means to manage mining-caused subsidence so that subsidence occurs in an orderly manner.” Room and pillar mining causes a disorderly series of collapses over decades that disrupts water tables, topples trees and creates sink holes.
The study goes on to explain that “subsidence occurs not as a single event, such as pulling one book out of a stack might lower the stack’s overall height immediately, but as a series of movements that result in a final subsidence basin.”
OVCC’s hired scientists also explain how “in areas with multiple panels, the area of maximum subsidence will encompass all mined panels as the chain of coal support pillars between panels will be crushed and expand the area of maximum subsidence across panel boundaries.” Thus, Permit D-0360-12, which is a vast series of panels across more than 2,400 acres, would cause subsidence to Dysart Woods as the coal pillars OVCC claims would be kept in place would in fact be crushed according to their hired scientists.
In a summary on tree data, OVCC claims that there is a total of 273 trees with heights greater than 20 feet. This is a gross miscalculation. In fact, there are thousands of trees in the old growth forest areas that are greater than 20 feet in height. OVCC and their scientists claim that Dysart Woods only has two old growth forest patches, while their own map shows three patches. They claim it is only 42 acres, when the ODMR finds more than 50 acres. Clearly they have not thoroughly investigated the issue.
Furthermore, OVCC admits that all they have is “preliminary data.” OVCC’s commissioned studies are not complete, and they are full of contradictions clearly intended to belittle and outright lie about the actual amount of impact that mining would have.
In their permit, OVCC describes in great detail how surface subsidence occurs with longwall mining. “Surface subsidence occurs as rock fractures above a mined panel, due to removal of its support, and falls into the area excavated by the mining machinery. This collapse of rock above the mined panel results in a ‘caved zone’ forming a rubble-filled cavity several tens-of-feet high. Above the caved zone, stresses in the rock relieved by the creation of the caved zone result in an increase in size and distribution of existing fractures for many feet above the caved zone to create a ‘facture zone.’ Lying over the fracture zone is the ‘continuous deformation zone’ in which … strata deform downward.” At the surface, cracks occur. OVCC says that cracking is more prevalent in the clay soils of southeast Ohio than in sandy soils.
OVCC in its Addendum to page 29, part 3. K(5)(a) Page 2, under the heading “Potential Mechanisms for Damage,” Ohio Valley Coal Company details five different ways that longwall mining can harm Dysart Woods.
They are, as follows. First, longwall mining can cause trees to “tilt in response to the subsidence wave, both as the wave passes and as the ground assumes the subsidence trough. Although this tilt may have occurred… it is not believed to be a danger to the trees.” With OVCC’s track record, they are not to be believed. Clearly, tilting the trees will snap roots, and cause major problems.
The second way that mining destroys forests and the hydrological balance is the “compressive and tensile forces that the ground and what is in them experience. As the subsidence wave approaches a point on the surface, it begins to experience tension followed by rapid compression after the wave passes the point. This ‘dynamic’ wave occurs very quickly and in some instance, the compressive forces are not as great as the tensile forces and some cracks remain open… Larger cracks sometimes require intervention by OVCC with a backhoe to fill the cracks with soil from around the cracked areas.”
OVCC said that the third mechanism of damage to the forests “is soil slippage. This area of Ohio contains soil-types that are slip-prone. Historically, the topography of Belmont County was formed from these slips, as is evidenced by alternating steeply sloping and benched areas found on the hillsides.”
OVCC says that the “fourth mechanism of damage is that changes in ground or surface water may adversely impact trees. But, regardless of the impacts to ground or surface water… trees in this area of the country derive their moisture from the soil.” While OVCC claims that this is “available from the rain,” it goes on to explain the fifth mechanism, of how “springs add moisture to the soil, and thus contribute to the tree and vegetative growth.” OVCC cannot dispute this, instead claiming that the mining plan has been designed to stay a minimum of 300 to 500 feet away from the old growth forest.
But this is an outright lie, as OVCC has continuously done, by claiming that there will be no mining under Dysart Woods, while this permit allows for mining underneath every single acre of Dysart Woods. It is through this deception that OVCC is trying to slip this permit through. On The Ohio Valley Coal Company Addendum to page 29, part 3, K (5)(a) page 5, the company states, “the fact that in this application, the old-growth forest will not be undermined.” By the very statement, mining cannot be allowed under the ancient forest, as the maps that OVCC submitted and that ODMR officials claim the permit would allow.
But do not be fooled. This permit would be permanently destructive to Dysart Woods. OVCC fails to document or study the impacts of room and pillar mining on the ancient forest. All of the studies are based on longwall mining. None are based on room and pillar mining. OVCC at the very least needs to provide studies on room and pillar mining before the permit can be deemed complete, let along approved.
OVCC, while claiming to have scientific evidence to back up their claim, has no evidence based on room and pillar mining, which is the very type of mining that it wants to do directly underneath Dysart Woods.
Furthermore, OVCC’s own data shows impacts from longwall mining far in excess of 500 feet, while it allows longwall mining within 300 feet of the ancient forest.
While OVCC continue to claim that trees depend solely on rain water, and not on ground water, they describe how the only water usable to trees are gravitational water and capillary water. Gravitational water is “just passing through” and typically only present when a precipitation even has recently occurred. It passes through the soil as a wetting front that increases capillary water as it passes and flows through the soil to either runoff or infiltrate to recharge groundwater.
OVCC goes on the explain how groundwater is located 20-30 feet below the surface of Dysart Woods. Furthermore, they admit that longwall mining “has been found to lower the groundwater surface,” and that “recovery of the groundwater surface to its original level has seldom occurred.” While OVCC claims that there is a separation between this groundwater and the surface, they also explain how it is this groundwater that feeds surface springs, which clearly can be usable by tree roots.
P squared found soil slippage in forested areas after longwall mining. They further found that fissures of an inch or more in width have been observed in Smith Township. The company said that the impact of longwall mining on tree growth has not been extensively studies. Most troubling, is the OVCC-paid scientists assertion that “Since Dysart Woods is managed for research of natural processes rather than value accretion, uncertainty over growth should not represent a significant issue.”
They are saying it would not matter if Dysart Woods were harmed because OU does not intend to log it. That is the anti-environmental mindset that we are dealing with. Clearly, changes will affect those studying Dysart Woods, as the only significant ancient forest in southeast Ohio. It is also the only ancient forest with the wealth of data that has been collected over several decades. All of that data is worthless if mining occurs, because it would no longer be a virgin forest if mining occurs. The irreplaceable value of the ancient forest would be lost.
Further, OVCC admits that the affects of longwall mining on natural slopes is limited, and that Dysart Woods “may be impacted by the ongoing OVCC mining operations.” The company also found that the soils of Dysart Woods are slip-prone. “It is not uncommon for natural slopes in Southeastern Ohio to experience stability problems. Longwall mining increases slope steepness and in the long term causes “dewatering of the soil mass.”
The type of geology at Dysart Woods “can develop perched water zones which can produce springs and seeps above the valley floors,” OVCC’s scientists report. Furthermore, they report that the perched water table-caused seeps and springs saturate the soil mass below where they are found. “Fracturing of the rock formations caused by longwall mining will often lead to the elimination of these seeps and springs… Longwall mining can be expected to dewater perched zones and dry up some seep areas.”
Ohio Revised Code seciond 1513.35 (11) states that coal operations must “Minimize disturbances and adverse impacts of the operation on wildlife, fish, and related environmental values, and achieve enhancement of such resources where practicable, to the extent possible using the best currently available technology.” The technology exists to backfill the voids create in mining, thus greatly decreasing the subsidence and dewatering affect of mining. With the unique value of Dysart Woods, the ODMR must require backfilling if mining of any type were to be allowed. But I want to make it clear that it is Dysart Defenders’ position that no mining occur under Dysart Woods or the watershed buffer zone as outlined by Moid Ahmed.