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Schmid & Company Publications




  • The Increasing Damage from Underground Coal Mining in PA
    A Review and Analysis of PADEP's Third Act-54 Report.    2011.




  • Protection of Water Resources from Longwall Mining in Southwestern PA.     2010.



  • Wetlands and Longwall Coal Mining in Pennsylvania    2000.



  • Recommendations to Expedite the Department’s Underground Bituminous Coal Mine Permit Application Reviews. 2012. 17 p.



  • A Need to Identify Special Protection Status
    and Apply Existing Use Protections to Certain Waterways in Greene and Washington Counties, PA
    . 2010.
    In accordance with the federal Clean Water Act and the Pennsylvania Clean Streams Law, the PADEP has adopted regulations that recognize Exceptional Value (EV) and High Quality (HQ) waters as special protection waters. Before any PADEP permit can be issued, the water quality and uses of a potentially affected waterway must be determined, and the proposed activity must protect and maintain that waterbody at its highest use. Data on the physical and biological conditions of streams are being collected as part of premining inventories for longwall mine applications, but those data are not being used to make the required existing use determinations. As a result, streams and their associated wetlands are not receiving the appropriate level of protection from impacts associated with longwall coal mining and Marcellus Shale gas production.

    Read the report:



    Proposed Redesignation of Tributaries to South Fork Tenmile Creek, 2009.

    On behalf of Citizens for Pennsylvania's Future, Schmid & Company prepared an illustrated report on a petition to reclassify tributaries in the South Fork Tenmile Creek watershed in southwestern Pennsylvania from HQ-WWF to WWF. Foundation Mining, LLP, was seeking the less protective classification to make it easier and cheaper to undermine coal from a nearly 15-square-mile area containing the streams. Schmid & Company concluded that, rather than being downgraded, many of the subject streams should instead be upgraded to EV (the State’s highest, most protective, classification).

    Read the report:

    Also Online at Penn Future:


    Impacts of Longwall Mining 2005...
    The second Act 54 Report confirmed the assertions we made in our report to the Raymond Proffitt Foundation in 2000 regarding the consistent failure of PADEP-BMR to enforce laws and regulations that claim to protect wetland resources in Pennsylvania. Even today the State continues to issue mining permits in the absence of required information, with the result that adverse impacts on streams and wetlands are carefully concealed. For the second time in a row, the Act 54 review process, as embodied in the 2005 Report, is perpetuating the myth that the BMR protects the environment of southwestern Pennsylvania from the very real damages being inflicted by longwall mining, now that Act 54 allows mine operators to undermine any kind of surface resources. Yet even a university heavily supported by the coal industry has admitted that PADEP-BMR permit files continue to be devoid of information on wetlands and other waters. The updated PADEP Technical Guidance Document could be a small step in the right direction, but only if BMR were actually to start requiring information that on paper has been required for years but in fact continues to be ignored. The mining industry has no incentive to submit complete applications when they know permits will be issued for incomplete applications. Business as usual at BMR will continue to make a mockery of the regulatory process for longwall mining, so long as the bureaucracy is allowed to ignore the very real environmental damage being experienced by residents of the coalfields. SEE detailed comments below.
    Stephen P. Kunz Comments on Second Act 54 Five-Year Report, 21 April 2005. 17 p.
    Read it online...


    Schmid, James A. and Stephen P. Kunz Wetlands and Longwall Mining: Regulatory Failure in Southwestern Pennsylvania. Prepared for the Raymond Proffitt Foundation. Media, PA: Schmid & Co., Inc., 2000. 83 p.

    Read it Online...


    Stephen P. Kunz Comments on Draft Technical Guidance Document 563-2000-655 . 1 May 2002. 17 p.
    Read it online...


    Stephen P. Kunz Comments to CAC on Study of the Effects of Longwall Mining on Streams, Wetlands, and Riparian Areas . 3 May 2002. 12 p.
    Read it online...


    Stephen P. Kunz Comments on Draft Technical Guidance Document 563-2000-655 Surface Water Protection - Underground Bituminous Coal Mining. 23 March 2005. 8 p.
    Read it online...


    Stephen P. Kunz Comments to OSM on Excess Spoil, Coal Mine Waste, and Buffers for Waters of the United States . 22 October 2007. 7 p.
    Read it online...


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