for Abandoned Mine Reclamation
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Western Pennsylvania Coalition for Abandoned Mine Reclamation Quarterly Meetings |
Testimony before the Citizen’s Advisory CouncilJuly 28, 2006 Bruce Golden, Regional Coordinator Western Pennsylvania Coalition for Abandoned Mine Reclamation (WPCAMR)
Regarding 15% match requirement for all Growing Greener grant awardsOn behalf of Western Pennsylvania Coalition for Abandoned Mine Reclamation’s board of directors and members, I’d like to express a serious concern with the current DEP implementation of the Growing Greener grant program. At issue is the new across-the-board departmental requirement of a minimum 15% match for all grant awards. Its one-size-fits-all nature could have serious unintended consequences. Furthermore we believe the policy is exclusionary, which favor the “haves” over the “have nots”. Should this policy go unchanged, it will be detrimental to the Department, the environmental movement, and, yes, to the promise made to voters who passed the $625 million bond initiative in last year’s referendum. To illustrate our concern, I’ll use an example. A watershed group submits a $500,000 Growing Greener grant request for design, permitting, and construction of an AMD passive treatment system, requiring a $75,000 match. Because of its specialized nature, practically all the resources needed to accomplish such a project require professionals for all phases of execution. Since the match has the further stipulation of being provided during the term of the grant, there exists little opportunity to match in the form of volunteer time, and certainly nothing on the order of $75,000 (equivalent to 6,000 volunteer hours @ $12.50/hr, or 3 full-time person years). So where does an all-volunteer, part-time group comprised of a limited number of people who have other things in their lives such as jobs and families come up with $75,000? A possibility is an OSM Watershed Cooperative Agreement Program construction grant for $100,000 (the typical grant). If so, problem solved. However, the OSM well is only so deep, and cannot be expected as a general rule. In fact, there are fears that this program may be phased out. Absent that, coming up with a combination of permissible matches totaling $75,000 may be next to impossible. That would be an extraordinary number of car washes and hoagie sales. For that matter, even finding $25,000 in match may be practically unattainable. The bar has been set so high by virtue of the one-size-fits-all 15% match requirement that watershed groups may effectively be priced out of even applying. That situation cannot serve the best interest of the Department, the watershed group, the local community, the environment, and does not appear to be in line with the wishes of the voters last year. Obviously there are some types of projects, e.g. construction, that are inherently at a disadvantage because of current policy. These projects have high costs and intensive need for professional services, little opportunity for in-kind match, and are often further disadvantaged by being located in impoverished areas where little financial or professional match is to be found. In crafting this new policy, DEP is promoting “sustainability” of watershed groups, where the department wants watershed groups to rely on additional sources of support for their long-term existence. While sustainability in this sense is a lofty and well-intentioned notion, it is not necessarily a practical business model given the realities of the all volunteer, part-time nature of watershed groups. We differ with DEP on the inherent capacities of watershed groups in generating match, be it cash or in-kind, in supporting projects. We are inclined to believe that certain types of projects very well lend themselves to providing more in-kind match than others, and are therefore not averse to requiring realistic match requirements consistent with project type. However we believe having a one-size-fits-all requirement is in the long run counterproductive. Also consider that historically watershed groups have done an admirable job of providing match for funded projects with an average of $1.25 leveraged for every Growing Greener dollar expended. Furthermore, in arriving at this policy, DEP did not seek comment from outside the agency including, to the best of our knowledge, Citizen’s Advisory Council or Mining Reclamation Advisory Board, nor was any other public comment solicited. I’m quite positive that groups other than WPCMAR would have liked to weigh in with detailed recommendations and are disappointed the opportunity was not offered. Different regions of PA have inherently different capabilities of raising cash match for environmental projects. Poorer and less populated areas are at a distinct disadvantage. Impoverished communities will bear the brunt of this policy, the very communities who most need the assistance. Watershed groups are not businesses and shouldn’t be expected to live by business standards. They have non-profit status because they are inherently in a non-profit making situation. They serve a public good and the law of the land recognizes that relationship. If these match requirements were in place in the past, much of the environmental success we’ve witnessed would have likely gone undone. Watershed groups extend the capacity of government, and often do their work at least as efficiently as government, perhaps more so. DEP, in fact, needs the watershed groups and depends on them to extend the capabilities through grants and will hurt its own efforts if these groups are unable to apply. This policy could undo years of work in developing the watershed movement. The rules of the grant program are now based on how applicants can be excluded. Instead it should be user friendly allowing the most environmentally meritorious projects to rise to the top. Coal field communities have been victimized long enough, and have suffered the consequences for decades. With Growing Greener there was hope, which ironically is now being muffled by current DEP policy. While we don’t believe the intention of the rules was meant to be exclusionary, the de facto result is exactly that. Taxpayers overwhelmingly approved last year’s referendum, and would likely be surprised, perhaps outraged, to find out grants are in many cases now more difficult to get because of one-size-fits-all match requirement. I for one definitely would not have actively supported the referendum as I did had I known about the fine print. Many others I know also have similar misgivings with what we’ve wound up with versus what t was promoted. In the past few years, we’ve witnessed governmental cutbacks, especially at the federal level, on everything but “essential” programs. The squeeze is on. Concurrently, the demand for philanthropic giving is at unprecedented levels. Non-profits are being pinched to the breaking point. Having to do more with less and less is the name of the game. Many non-profits are as lean as they can possibly be. Finding alternate sources of funding is becoming increasingly difficult and competitive. With this situation, watershed groups are increasingly devoting more of their scarce resources to survival versus focusing on the environmental causes for which they were formed. Watershed groups are also being squeezed on the other end: DEP is increasingly partially funding worthy projects (not awarding requested amount). This often places watershed groups in impossible situations of having some, but not adequate money, to do their projects. No one wants to return grant money because it’s inadequate, but cutting corners to be able to do something may not be wise either. This practice needs to be examined. DEP also makes planning for watershed groups difficult by no longer having an established date where Growing Greener grant award announcements are made. The recent trend has been to announce later and later in the year. Not knowing whether a project will receive funding for 9 months following the strict submission date is a disservice to watershed groups and for their planning for the coming year. If a project is funded, it is now common for an executed contract to take over a year from the time of submission. Pennsylvania has become a role model of the watershed movement nationwide, primarily as a result of the Growing Greener program. And so it should be, as Pennsylvania has the greatest amount of legacy coal mining problems of any state. Growing Greener is not just about money, it’s been a highly successful philosophy of cooperation and partnerships where each partner plays to its strengths, providing the resources it can uniquely supply, all reaching for a common goal. The current one-size-fits-all match requirement is eroding that philosophy. Projects should be judged on their environmental merit, not how deep the local community’s pockets are. Looking at the situation more broadly, there are a number of factors coming into play that should be considered when determining if a project should be funded. Among them are:
Each project is unique and shouldn’t be subject to an arbitrary threshold for match. Each project should be judged on its own inherent merits, where the amount of match is simply one factor to be considered. A project should not be disqualified based on a group’s inability to provide a specified percentage of match, although it is perfectly valid to include match as a scoring criterion along with other scoring criteria. The watershed community has already proved itself by providing an average of sponsor generated match of $1.25 for every Growing Greener dollar spent. If it works, why fix it? Much of the phenomenal success in improving the environment over the past dozen or so years, especially as it pertains to the legacy problems of yesteryear coal mining, is directly attributable to the watershed movement and the state’s embracing a philosophy of working in partnership with volunteer organizations in reaching common goals. The “people power” of these volunteer groups and the passion they have in making things better are the real assets they bring to the table. It saddens us that admirable attributes of hope, good will, determination, a vision for the future, a cooperative spirit, and the desire of leaving a legacy of a robust environment are so easily devalued when they can’t be quantified with a dollar figure. Regarding Operations, Maintenance, and Replacement of AMD Passive Treatment SystemsIn 2001 DEP established the Operations, Maintenance, and Replacement Workgroup comprised of a number of experts on passive treatment systems for mitigating abandoned mine drainage. Of prime concern was the amount of resources needed for the ongoing operation and maintenance of these facilities, as well as their eventual replacement as they were designed with a finite lifetime. Over a course of time the Workgroup made a number of recommendations to the Department on realistic resources required in keeping these facilities functioning nominally and for their eventual replacement. Of particular note are the recommendations for resources DEP should accept as its cost share of OM&R. Of the recommendations made, the Department has made progress on most of the recommendations, and has provided funding towards implantation those recommendations. In a nutshell, the problem is the Department is not providing near the amount of funding and resources needed to support the number of passive treatment systems now on the ground. Areas where the department is falling short include providing adequate funding for
There exist quite a few passive treatment systems which are not functional. There exist those that are in decline and headed for failure. And there exist those which we have little idea of the current state of repair. Tens of millions of dollars have so far been expended on improving and protecting the environment through the construction of AMD passive treatment systems. It only makes sense that we protect that considerable investment through proper funding of OM&R activities. We urge the Department to review the recommendations of the OM&R workgroup against the progress that has been made to date, and work in earnest to rectify shortcomings that currently exist. |
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PO Box 295 Luxor, Pennsylvania 15662 © Western Pennsylvania Coalition for Abandoned Mine Reclamation |