Today, mountaintop removal mines use 240-ton trucks. Valley fills sometimes measure 100 million cubic yards or more.
Larger equipment isn't very mobile, and it costs a lot to move.
Companies want to permit contiguous mines, so equipment can move easily from one site to the next.
Operators also concentrate several groups of large equipment (a large shovel with a fleet of trucks, with a loader and a fleet of trucks, for example) together on one mining complex. These complexes must be very large so the groups of equipment have their own operating areas and don't interfere with each other.
"In summary, the trend to larger equipment will result in the demand for larger permits," Morgan wrote in his report.
Driving the dragline At most mountaintop removal mines in Southern West Virginia, draglines drive everything.
Draglines cost $25 million or more. They must be transported in parts, and take years to assemble. Once a company brings in a dragline, they want to make the most of their investment.
They run the dragline 24 hours a day, every day, at full capacity.
Mine trucks and shovels are chosen based on whether they work well with the dragline. Production schedules are designed to the dragline's capacity.
Draglines are huge. Some have circular bases that are 60 feet or more in diameter. Because they are so big, draglines need wide, flat areas - often 120 feet or more - to sit on to operate at full speed.
So companies cut off huge slices of mountains to create those flat areas These cuts, known as pre-stripping, create huge amounts of leftover rock and dirt. Companies need somewhere to put this material.
That's one major reason they build bigger valley fills.
This means draglines end up operating far behind pre-strip equipment.
Large areas of the mine are left disturbed for months as the dragline catches up to the pre-stripping.
"The separation of the mining operation into pre-stripping and dragline tasks increases the overall footprint of the active mining area," Morgan said in his report. "This additional area makes operation easier, but is not critical for the operation of the equipment." Morgan suggests companies reduce the size of the pre-strip cuts and work draglines and pre-strip equipment closer together.
This is called contemporaneous reclamation. Under this practice, operators reclaim mines as they go, rather than leaving larger amounts of disturbed area between the pre-stripping and dragline operations.
Proper contemporaneous reclamation minimizes dust and erosion and reduces the potential reclamation costs if an operator goes belly up.
It also limits the size of valley fills.
In his report, Morgan says contemporaneous reclamation is like laying pipe: First, assume that pipe is only available in 10-yard pieces. To lay this pipe, you would dig a 10-yard-long trench, and place the dirt from it at one end of the trench. Then you would lay the pipe in the trench and dig another 10-yard hole at the other end of the first trench. The dirt from the second trench would be used to cover the pipe in the first trench.
In this example, a total of 20 yards would be dug up at any one time (10 yards from each of the two trenches). Also, you would be left with nowhere to put the 10 yards of dirt from the first trench. (The second trench would be filled with dirt from the third trench, and so on.) If this were a mountaintop removal mine, that leftover dirt from the first trench would be the material from the first pre-strip cut. It would have to be dumped into a valley fill.
But if you could use 5-yard-long pieces of pipe, only 10 yards of land would be disturbed at any one time (5 yards each from two trenches).
And the amount of leftover dirt you would have nowhere to put would be cut in half, to 5 yards.
"The same principal applies to surface mining," Morgan wrote. "A smaller mining area will decrease the overall disturbed area. More importantly, it will decrease the amount of material placed in excess spoil disposal areas." The long haul Under federal law, strip mines must generally be restored to their "approximate original contour." Unless they plan to develop flattened land, companies are supposed to rebuild the mountains they tear down.
In West Virginia, this hasn't happened. Companies have removed mountains and flattened land, but never developed factories, schools or subdivisions. At the same time, because companies didn't have to rebuild mountains, they simply dumped the rock and dirt into streams.
"Historically, the mining companies have tried to reduce the elevation of the overburden backfilled on the mined-out area because this reduces their mining costs," Morgan wrote in his report.
"The costs are increased as the distance that the material has to be hauled increases," he wrote. "Costs are also increased if the trucks have to haul uphill to place the excavated overburden on the upper portions of the backfill. It is cheapest to haul short and level." In mid-March, DEP and OSM announced a plan that could fix this problem.
Under the plan, coal operators will have to pile most of the rock and earth they blast or dig up back onto the hilltops they mine. The only material that could be dumped into valley fills would be that which can't be placed back on hilltops because of rules on stability, drainage or sediment control, and access to and maintenance of mined areas.
In his report, Morgan found that if Hobet Mining had to follow the new OSM guidelines, it "could and should have maximized the backfill" and proposed smaller valley fills.
Recently, OSM inspectors applied the new guidelines to two other mountaintop removal applications filed with the state. In each case, they found that, by complying with the guidelines, operators could rebuild more of the mountains and dump less waste into streams. "It appears the fill volume could be significantly reduced," an internal OSM study reports.
Morgan also found that most valley fills in West Virginia are built from the top down. Trucks dump rock and dirt over hillsides, and gravity carries the material into the fill.
Industry engineers praise this approach. For one thing, it's cheaper.
Trucks don't have to go as far. Dozers aren't needed to move material around at the bottom of the fill. For another, gravity automatically sends larger rocks falling to the bottom, creating a rock underdrain for the fill.
But this method also makes fills bigger. Rocks and dirt don't always compact as much as they could. Fills are not stacked as high as they could be because it costs more to truck uphill.
In his report, Morgan suggests that fills could be smaller if they were built from the bottom up.
"The environmental effects of end-dump durable rock fills can be reduced if the fill is placed in a controlled manner by hauling with trucks plus leveling and compaction with a dozer," Morgan wrote.
He also suggests that fills could be stacked higher. "This increase in elevation will result in the decrease in the length of the fill and a decrease in the amount of stream buried." Morgan concluded: "Mine planning seldom has been a blank canvas on which to work, and historically the development of mining operations has adjusted to the conditions in which it wants to operate.
"The solution is creative thinking and acknowledgment that environmental and regulatory constraints are a critical component of mine design." Since he filed his report two months ago, Morgan has tried to convince the West Virginia coal industry that he's right. Some of them are starting to come around, at least a little.
"I think he's got some good ideas," said Raney of the Coal Association. "We can talk this thing out." Arch Coal's Woodring said, "We've had a lot of discussions, and we've exchanged a lot of information.
"Right now, we're getting some input from those discussions but can't really say right now whether we are learning anything of any value." Rank said that even if a settlement is reached, government regulators need to do more to scrutinize the effects of mountaintop removal.
"There are ongoing discussions," Rank said. "The engineering proposals would minimize the effects of removing the same amounts of coal by the same methods.
"There's something between the pick and shovel and removing every ounce of coal that's out there," Rank said. "I'm not sure we're really in the process of looking at these alternatives the way an environmental impact study or the permit process should.
"Does the law dictate the permits, or does the technology and the will of industry dictate what the regulations will say? The laws are there, but with little will by agencies to enforce them, citizens have to go to court and get some judge to enforce the laws."