The mining company Amerikohl is planning to open a 500-acre surface coal mine adjacent to Ohiopyle State Park, State Gamelands #51, and 1000 feet from Great Allegheny Passage Bike Trail.

Known as the Curry property, the area is currently zoned for agricultural use. Amerikohl is petitioning the Fayette County Zoning Board for a zoning exception. Mining cannot proceed without this exception. It is a step separate from the DEP permit process.

The following is background material for preparation of testimony and letters, thanks to Krissy Kasserman.

Environmental Protection Significance:

The Curry property is part of a large contiguous forested area that is very wild and remote.  It harbors qualities of an interior forest that provides undisturbed habitat for many native animal and plant species and natural communities, some of which are dependent on a large, unfragmented forest ecosystem. The green salamander, which is listed as a PA Threatened species, is found in very few places in the state with a distribution limited to certain rock outcroppings in the southern portion of Fayette County. This species is known to occur on the Curry property and it might also live within the impact area of the proposed mine. The Allegheny woodrat, also listed as PA Threatened, inhabits similar habitat, but requires more area for foraging. Direct disturbance to habitat, removal of the nearby forest canopy or changes in hydrology will likely adversely affect these species. Development near and upslope of green salamander sites in Maryland have recently been implicated in the extirpation of more than one salamander colony.

This large, contiguous forested area of which the Curry property is at the heart of, has been the focus on large scale land protection for over 50 years by entities that include the Western Pennsylvania Conservancy, PA Dept. of Conservation and Natural Resources and the PA Game Commission. This property is part of the Youghiogheny River Landscape Conservation Area. It was given this designation by the Western PA Conservancy in the Fayette County Natural Heritage Inventory (WPC, 2000) because this river gorge contains a number of Biological Diversity Areas and because it is a large, contiguous forest that has retained much of its natural character and includes habitats for plants and animals that are recognized as state and/or federal species of special concern and natural communities that support exceptional native diversity. The site of the proposed Curry Mine is adjacent to the Youghiogheny River Biological Diversity Area which is the most significant biological site in the county and region and, arguably one of the most important sites in the state. Eleven species of plants and one species of animal of conservation concern are identified for this river corridor. The larger Landscape Conservation Area, which includes the river corridor, harbors an additional 5 plant species, 2 animal species, 2 herpetiles, 3 habitats and 3 geologic features all of special concern and designated as such by the PA Natural Heritage Program and potentially on or adjacent to the Curry Mine site.

The Yough River Gorge and its immediate watershed “feature a biologically diverse, minimally fragmented, forested corridor of striking beauty and great importance to the natural heritage of the county, Pennsylvania and the eastern United States (Fayette County Natural Heritage Inventory, WPC, 2000). The proposed mine site is adjacent to Ohiopyle State Park which is considered a ‘crown jewel’ as natural resources in PA and the region are concerned.

Stream Designation & NPDES Permit

Currently, the unnamed tributaries to the Yough River that are included in the proposed mining area are designated Warm Water Fisheries by the PA Department of Environmental Protection. This designation allows these streams to be impacted by the mining operation with no protections. A number of knowledgeable individuals contend that this designation is completely inaccurate and designation should minimally be High Quality – Cold Water Fishery based on the simple fact that these streams, based on their size, harbor diverse aquatic life (determined by DEP), have intact headwaters where forest canopy is completely intact.

If justification for WWF is based on the lack of population size or low species richness (total number of species) of macroinvertebrates sampled, then the result should not be to give the a lesser designation. The population and richness criteria are based on what would be found in a higher order stream that is designated HQ-CWF. These unnamed tributaries are smaller and do not have the capacity to support larger populations… it is that simple. The DEP is comparing apples to oranges in their designation process and should be revisiting the quality of these unnamed tributaries and basing their designations on criteria that are more appropriate for these smaller order streams. It can probably be argued that these streams are Exceptional Value by their very nature.

This site proposes to divert water out of the Morgan Run and Johnson Run watersheds, which are both designated as High Quality Cold Water Fisheries (HQ-CWFs), through the use of diversion ditches which will control the direction of surface water. As a result, these streams will be warmer as less water generally results in warmer water.  This is not an appropriate use of streams that are designated HQ-CWFs.

Deforestation and lack of riparian buffers will contribute to deterioration in water quality in these streams.

Chestnut Ridge Trout Unlimited is attempting to remediate Morgan Run from mine drainage, and recently received a Growing Greener grant from the PA DEP to install a passive treatment system. Further degradation in a stream that CRTU is attempting to remediate using hundreds of thousands of dollars worth of taxpayer funds would be extremely counterproductive.  Morgan Run is not currently reaching its HQ-CWF designation due to mining in the headwaters of the watershed; this is the area where CRTU is planning to construct a treatment system.

Should this system of diversion ditches break down or become overwhelmed due to a high precipitation event, the potential exists for untreated water to be discharged into Morgan and Johnson Run.

Recreation Significance:

Contrary to what the DEP spokesperson stated at the Wednesday, April 16 DEP Public Meeting, the area of the proposed Curry Mine is a highly utilized recreational area. The Great Allegheny Passage Bike Trail runs just below (elevationally) the proposed mine site and will be impacted, minimally, by noise and dust during mining operations. State Game Lands #51 shares a boundary with the site and is utilized for hunting, climbing and hiking in all seasons of the year.  The popular Craelick Rocks is within 1000 feet of the proposed mine site. This recreation destination is a premier rock climbing site. Blue Hole, a popular swimming spot on Morgan Run, is within 1000 feet of the proposed mine site. Morgan Run is becoming a highly sought after class V whitewater run by kayakers from all over the region.

Notable Area Destinations and Economic Impacts of Recreation:

• Fallingwater – 2.5 miles from mine site
• Kentuck Knob – 4.3 miles from mine site
• Great Allegheny Passage Bike Trail –1000 feet from mine site
• Craelick Rocks – less than 1000 feet from mine site
• Blue Hole – less than 1000 feet from mine site
• Ohiopyle State Park and State Gamelands #51 are directly adjacent to the proposed mine site

Ohiopyle State Park, the largest tourist attraction in the county, attracts between 1.3 and 1.9 million visitors per year. Visitors regularly fill Uniontown hotels during the summer months.

The portion of the Great Allegheny Passage that is adjacent to this proposed mine hosts approximately 200,000 visitors per year. The economic impact of the Great Allegheny Passage should not be underestimated as it generated $12 million in direct spending in the year 2008.  Ohiopyle is the most popular destination from which to access the trail.

Traffic & Invasive Species

This project, due to the amount of traffic (20 tri-axle truckloads per day for 21 months) into and out of the site as well as the amount of disturbed area, has the potential to introduce many invasive species that could cause harm to the threatened or endangered species. Invasive species thrive in areas that have recently been disturbed and are often introduced to areas through roadways and by piggybacking on equipment. Because the proposed mine area is bordered by contiguous forest, the danger of introduction of invasives is certainly a potential problem. There is currently no protocol (i.e. a plan to clean equipment before entering the site) from the mining company to address these issues.