Buried costs of mountain top removal coal mining – biological effects, regulatory reality, economic consequences

According to USEPA estimates, over 1000 miles of stream have been buried by mountain top removal (MTR) coal mining.  The impact of MTR extends far beyond the burial, and we have documented downstream biological impairment from MTR coal mining in the coalfields of Southern West Virginia.  New permits for mining continue to be issued despite the high probability that they will result in impairment downstream of permits.  Traditional resource management teaches us that regulations exist in part to apply a cost to pollution and that this cost will be reflected in the market for that commodity.  The current regulatory framework fails to account for many coal mining costs and effectively reduces the coal industry’s cost of compliance with the Clean Water Act.  We present examples from permit application to bond release that illustrates this phenomenon.