Raney stated that companies told his association that permit delays of the type McCabe has mentioned would force operating mines to close and new mines not to open.
In all, Raney said the seven companies reported the permit delays would cause 2,403 current direct and contract jobs to be lost and 389 new direct and contract jobs to be lost.
Harvey added in his brief that the delays would cost coal companies "millions of dollars in potentially idle capital investment" and the state millions in lost annual tax revenues and reduction in payments to coal industry vendors.
"The Settlement Agreement will throw off the planned sequence of many operations - resulting in unemployment, lost capital expenditures and a host of secondary harms (lost tax revenues, lost indirect employment) which accompany reduction in economic activity," Harvey wrote.
"A two-year delay in the permitting process will be devastating to the coal mining industry and those who depend upon it," he wrote.
"As surface mining operations are mining coal, they are at the same time applying for new permits to conduct their next operation," Harvey wrote. "If these new permits are not granted before the completion of mining at current operations, miners must be laid off and mining equipment must be idled until the new permits can be obtained.
"To ensure that this does not occur, mine operators work to ensure that permit applications will be submitted and approved in time to allow operators to proceed seamlessly from one permitted operation to the next," he wrote.
"In the past, companies have been able to do this - with a safe margin of error - because they knew approximately how long it would take to obtain permits for their next operation," he wrote. "The Settlement Agreement will disrupt all of this careful planning and place countless operations in jeopardy."