West Virginia Coal Association
April 30, 2014
The State of West Virginia is the nation’s leading underground coal producing state, producing 120 million tons of annual coal production [down from over 165 million tons as recent as five years ago] which comes from 152 underground mining operations and approximately 14,000 underground miners. Consequently, the State of West Virginia and our member companies are arguably more directly affected by this proposal than any other state.
Our member companies and their professional workforce work together diligently and continuously to achieve the lowest possible level of respirable coal dust in their respective operations. They do this through the deployment of state-of-the-art dust control and mine ventilation technologies combined with intensive miner training programs and critical oversight of best management practices.
These improvements are also prevalent throughout the industry and are supported by the ever-improving conditions of underground mining and the decrease in the incidence of coal workers pneumoconiosis (CWP) over the last couple of decades. These improvements are a matter of record today.
We wholeheartedly support the goal of eliminating CWP, however these rules incorporate “cherry-picked” information, ignoring the most recent data regarding the prevalence of black lung disease. These rules also create a complicated and costly administrative burden for MSHA and the coal industry. The rules threaten the job security of our nation’s coal miners while ignoring common sense solutions to end black lung disease, such as proven personal protection technologies and mandatory screening that would allow the industry and MSHA to better understand disease prevalence and craft tailored solutions to meet our shared goal of eliminating this disease.
The rule appears to be fraught with technical and operational impracticalities; misapplication of dust control technologies; convoluted, inappropriate and uneven enforcement schemes; and, represents a departure from the cooperative approach deemed necessary to eradicate CWP from the industry.
The Central Appalachian mining region, including West Virginia, has clearly been under attack by the Obama Administration and its federal agencies. They collectively seem destined to severely restrict production, while elevating all associated permitting and operational costs to the point of reducing the production of coal from this region for use in domestic and international markets. It is our sincere hope that this rule is not part of that strategy. Further analysis and actual experience following August 1st will either embrace or refute this contention.
For more information or questions contact the WVCA at 304-342-4153.