Comment on FR Doc # N/A

Office of Surface Mining Reclamation and Enforcement, Administrative Record, Room 252-SIB 1951 Constitution Avenue, NW, Washington, DC 20240 DOCKET ID -- OSM-2008-0003 To Whom It May Concern: For myself, and on behalf of a 16 county coalition of community watershed groups and Conservation Districts that support the reclamation and remediation of abandoned mine lands in PA, particularly the Anthracite and sub-Bituminous Northern Tier, gaining a comprehensive understanding of this rulemaking that took over a year to produce, will take some time. I would like to make an investment in that time to digest and form opinions and work with other partners in our region to respond to the document at hand. I suspect I’ll need at least two more weeks before I’ll be able to offer anything of substance. Earlier in August EPCAMR was able to make some comments related to the Remining Incentives package that went along with the SMRCA reauthorization, but has not had enough time to digest the language on the AML or AMD side of the issue. The comment period is too short and our organization has been a major non-governmental organization, regional non-profit partner in reclaiming abandoned mine lands in Northeastern PA. Along with our sister coalition, WPCAMR, we have just come off of the coordination of our 10th Annual Abandoned Mine Reclamation, 3 day Conference, in State College, PA with over 175 people in attendance, where many follow-up discussions were recently held by the PA DEP and others on the Reauthorization of SMRCA. Given that OSM has taken well over a year to produce this document and it is the first time that we are able to read in depth the details of the reauthorization language changes that will potentially affect how and when we will be able to prioritize future reclamation and AMD remediation projects, I am formally requesting that it would be entirely reasonable to have the comment period extended at least another 30-60 days. At first glance, one of the things that most interests EPCAMR is the definition of hydrologic unit, which we believe is critical to the upper end of how much AMD work can be done in PA and what kind of restoration plan will be acceptable that meet the State's criteria for future remediation funding. If I recall correctly, the Set-Aside program AND the provision whereby Priority 3 AMD work can be done in conjunction with a P1 or P2 reclamation both refer to qualified hydrologic units.) A definition of qualified hydrologic unit is provided, but uses the undefined term hydrologic unit as part of its definition and thus focuses on qualifications acceptable to the law. We are hearing that the definition of hydrologic unit would be decided by the individual states to each make their own definition, and indeed PA does have a working group grappling with that issue as we speak. What we do know at this point is that hydrologic unit will NOT be derived from the USGS definition that produces the HUC system many of our watershed groups and Conservation District supporters are familiar with. This is just some initial comments on the surface of the rulemaking that we have concerns about. We kindly request additional time for an adequate review of the rulemaking that is vitally importantly to all of PA, and in particular, our Northeast Region, in the heart of the Anthracite coal fields. Respectfully submitted, Robert Hughes Robert E. Hughes EPCAMR Executive Director 570-674-3411 www.orangewaternetwork.org