STICKY -Coal Exploration Drilling-Rock Creek Waldens Ridge

[cumnock]

RE: FYI

I know you realize that I am not going away. The purpose of this email is to light a fire at TDEC. The mining company is planning to submit a SMCRA application in the third quarter of 2010. I saw the recent TDEC website notice of additional land for the Cumberland Trail State Park’s southern section. The water quality of this section of the park will play a key role in its economic development of the park. The environment concerns associated with acid mine drainage upon the capitol dollar investment by the state of TN depends upon water quality in the Rock Creek section of the park. This has been a standing position for protecting our state parks at TDEC. It was established by former TDEC Commissioner Hamilton and Deputy Commissioner Justin Wilson. The citizens of the Rock Creek watershed are only asking that our rights under the Water Quality Control Act be enforced. As like in 1978 with the LUM Part A designation of the entire watershed. And, TDEC’s efforts in the past 23 years to continue water quality improvements in the Rock Creek watershed. This is our Alamo.

I am attaching a map of the past mining sites in the northern Rock Creek LUM area. The lighter green was where exploration drilling was done. The drilling permit area is only 250 acres. The Tier 2 Suzanne Branch and Hall Creek are not marked on map. The Walden Ridge Subdivision surrounds the large lake on the map (right bottom). Horn Creek is the habitat of the Laurel Dace.

The company is looking at a potential 1700 surface coal mining operation in this area. The future mining site maybe almost seven (7) time bigger then the light green tract. They now claim as much as 28,000 acres of mineral options.

And, a greater concern will be the company now having all of the Benchmark properties. Benchmark’s properties are next to the Cumberland Trail State Park (to the south).

TDEC’s concerns should be that once Rock Creek falls, the two sub-watersheds of Fall Creek Falls having the same designation as the Rock Creek watershed, will be next. TN Consolidated Coal Company has already tried once to mine. They would be seeking the same consideration as Americas Energy Corporation.

I fully understand that TDEC can not do anything until a NPDES permit is submitted, but TDEC can start looking at its options here. The ever-ending fear of “takings” lawsuits and efforts to do away with the TN Nuisance Law leaves you with very little to fight to protect the Rock Creek watershed. I hope that TDEC will review its options. I appreciate the efforts of Bobby Fulcher and his staff is building the Cumberland Trail State Park to nationwide recognition that the National Trail Conference will be held Chattanooga this year. TDEC should plan to showcase its Cumberland Trail State Park and the growing recreational industry of Chattanooga at this conference, not a surface coal mining site next to the Rock Creek section.

TDEC should consider requesting a full EIS since this will be the first SMCRA application in a Tennessee LUM area. TDEC should work with Fish and Wildlife Service to designate the Horn Creek’s Laurel Dace. The Rare Species of Rock Creek should be protected. TDEC should en-act its guidelines in the Responsible Mining Act of 2009. All of the watershed needs ONRW protection. It is considered by some as the last pristine streams on Walden Ridge.

Until next time. I hope that citizens and state agencies and state lawmakers can work together to protect 23 years of water improvements
and future land use for the Cumberland Trail State Park and the citizens in the Rock Creek Watershed.

For the citizens of the Rock Creek watershed (SOCM’s Bledsoe Chapter),
Landon Medley

CLICK ON THIS LINK

http://www.waldensridgewhitewater.com/images/maps/rockcreekmap.pdf

[cumnock]

Dear Earl,



Under Part B of the 1987 Rock Creek, Tennessee Watershed LUM the gorges was designated a completely unsuitable for surface coal mining. The OSMRE-PE-8 evaluation and the OSMRE-22 EIS

sites the Cumberland Trail State Trail, but does not have specific data relates to the park since it was a in the beginning stages in 1987.



We understand that plans are underway to develop the Benchmark properties. We are assuming that the State of Tennessee will object to any surface or underground adjacent to the Cumberland Trail or in the gorges or along the trail route outside of the gorges.



Additionally, we assume that OSM would seek to update the 1987 EIS to show new information, maps and data related to Hall Creek and Suzanna Branch designation as Tier 2. We would assume at some point the mining company would seek to mine the Benchmark properties. The Committee understands that OSM and the State of Tennessee can not address SOCM’s concerns until an actual permit is applied for by a mining company.



With recent ads about selling the Ratliff’s mineral rights properties along Bledsoe and Rhea Counties raises additional concerns by the Committee.



SOCM would like to know if OSM and the State of Tennessee have shared any updating of the Cumberland Trail development since 1987 and any Long Range development plans. We have notice that the State of Tennessee recently added more land to its trail properties. If so, the OSM database at the OSM office should be updated showing recent trail development lands.



Part B of the 1987 designation specifically spell-outs what is allowable as it relates to surface and underground mining in the gorges. As well as Part A that covers the watershed designation in 1987. The Committee would just like to know if OSM and the State of Tennessee have been updating one another. The Gorges cover under Part B is mapped out on the attachment.



SOCM has no knowledge of any proven toxic material handling plan or mining operational standards to meet Part A and Part B designations. SOCM assumes that OSM would require such proven mining methods be shown workable outside of the 1987 LUM Rock Creek watershed and gorges before allowing such mining methods within the watershed or gorges.



Thousands of dollars are been given to develop the Rock Creek Section of the Cumberland Trail State Park by the State of Tennessee and private groups and individuals who work the trail. Any potential surface or underground mining would directly and indirectly impact development plans by all. More and More we see private individuals donation monies and time toi develop the Rock Creek section of the trail. It would be heartbreaking to see all of this lost. The OSM EIS-22 cites OSM’s concerns regarding impacts to land use in the Rock Creek watershed. The wisdom shown in 1987 is a standard for everyone today. The water quality improvement in 23 years within the Rock Creek section justifies stringent protection in the future. These concerns have been expressed several times over the past four years in meetings with OSM. We appreciate the late Mr. Doug Siddell open-door policy and OSM’s understanding and willingness to hear SOCM’s concerns.



SOCM’s Stripmine Issue Committee would appreciate any update regarding discussions with the State of Tennessee to protect the Cumberland Trail’s Rock Creek Section. Setting aside mining issues, the committee feels that such update meetings and discussions should be ongoing between OSM and TDEC. If no discussions or updating have taken place, maybe this email will jump-start such discussions.



Sincerely,

Landon Medley

Rock Creek Ad Hoc Committee

SOCM

Lake City, TN

[cumnock]

Davis,

The SOCM Ad Hoc Committee is seeking Hydrologic data for the Rock Creek watershed and its headwaters. Any related hydro-data will be helpful. It will help to establish water quality in the watershed. SOCM have already filed a request before the TN Water Quality Board to designated Rock Creek watershed as "Outstanding National Resource Waters". Suzanna Branch and Hall Creek Hall are already designated Tier 2 streams.

One hydro point of interest to us is collecting data showing potential flooding issues downstream of the proposed Skiles and Reel Creek mining area, the applicant will have to do some sort of flooding analysis which identifies all of the structures and the ability of the stream channel to carry the existing flood flows and any increase resulting from the mine.

All of this would depend on the size and numbers or mines and what is downstream of the mines as to what type of flooding analysis may get done.
But, any related data would be useful to us. The company in question has stating that the potential size of the mine site would be around 1700 acres.
This size would be the largest surface mining site ever in the Sewanee coal seam. It would be larger then the old Skyline site on the Cumberland Plateau.

We need:

Identifying the number and types of streams Well water users in the community Flow pattern during the year pH levels or any water quality data Flooding conditions during rain fall or after snow period Type of aquatic life found in streams

We can compare new data with the old data found in the Rock Creek EIS.

The Horn Creek sub-watershed has been cited by Fish and Wildlife Service as the habitat range of the Laurel Dace. If the company moves westward from the recent core drilling site, it would impact Suzanna Branch (a Tier 2 stream) and Horn Creek. Any data showing the Laurel Dace downstream from Horn Creek is very important. It would show that the Laurel Dace feeding range is much larger then just Horn Creek.

Any of the above information would be helpful to us.

PS: TDEC does not keep records on the number of people using the Rock Creek section of the Cumberland Tail. If you know individuals or groups or organizations that use the Rock Creek or the Cumberland Trail for recreation, please ask them to contact us.

The Office of Surface Mining Reclamation and Enforcement (OSMRE) issues surface coal mining permits in TN.

TN Water Pollution Control's Mining Section issues NPDES permits and ARAP permits at surface coal mining sites. The Responsible Mining Act of 2009 cite that TDEC would not allow mining in streams with high risks of being impacted by acid mine drainage.



Feel free to contact me or Ann League at the SOCM Lake City Office

Landon Medley
Rock Creek Ad Hoc Committee
SOCM

[cumnock]

Found this really nice blog on the Rock Creek Watershed

http://rcgorge.blogspot.com/