-------
Two factors could reduce this dramatic shift from western
to east central coal. First, the coal industry may not be able
to shift production capacity this rapidly from western mining
areas back to the Midwest and Applachian areas. And, second, most
western coal is currently produced from nonunionized suface mines;
on the other hand, most midwestern and eastern coal is produced
by unionized miners. The protracted coal strike of 1977-78 has
heightened the concern industrial and utility coal users have
about the reliability of coal supplies from unionized mines.
This concern may result in a greater demand for western coal than
would be expected on the basis of economic cost alone.
Another important factor which makes.these calculations un-
certain is the degree to which increased pollution control costs
for coal-fired power plants will lead utilities to choose nuclear
power over coal. As indicated in Table 6-16, the difference in
total national coal demand between the base case and the 90 per-
cent sulfur removal case is not very large- However, recent
studies1 have reaffirmed the economic attractiveness of nuclear
power for baseload generation; and since the BACT requirement
should enhance the nuclear cost advantage, it could lead to sub-
stantial overall reduction in coal demand.2
(2) What Will be the Effect on SO 2 Emissions?
The other aspect of effectiveness important for this alter-
native is the impact it would have on air pollution levels both
within and outside the eight-state study area. This question has
been examined in a contract study of alternative NSPS definitions
performed for EPA.3 Table 6-17 presents some of the results of
this study which was based on a "moderate" energy demand growth
rate (5.8 percent annually through 1985 arid 3.4 percent annually
thereafter). The regions used in this report do not correspond
precisely with our eight-state study area, but the findings of
1 See for example, Rudasill, Charles L. "Comparing Coal and
Nuclear Generating Costs." EPRI Journal, Vol. 2 (October 1977),
pp. 14-17.
2Krohm, G.C., C.D. Dux, and J.C. Van Kuiken. Effect on
Regional Markets of the "Best Available Control Technology" Policy
for Sulfur Emission, National Coal Utilization Assessment.
Argonne,111.:Argonne National Laboratory, 1977, p. 49-51.
3Teknekron, Inc. Review of New Source Performance Standards
for Coal-Fired Utility Boilers, Volume I: Emissions and Non-Air
Quality Environmental Impacts. Berkeley, Calif.: Teknekron, 1978,
For this analysis Teknekron utilized their Utility Simulation
Model, a computer model which simulates the response of the poli-
cies and regulatory constraints.
286
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TABLE 6-17:
REGIONAL SULFUR DIOXIDE EMISSION
ESTIMATES FROM POWER PLANTS3
(million metric tons per year)
REGION
North Mountain
South Mountain0
U.S. Total
1976
0.12
0.34
13.6
1985
BASELINE
0.09
0.23
15.2
90% SULFUR
CONTROL
0.06
0.19
15.2
1995
BASELINE
0.18
0.28
15.8
90% SULFUR
CONTROL
0.06
0.16
13.6
Source: Teknekron, Inc. Review of New Source Performance Stan-
dards for Coal-Fired Utility Boilers, Volume I: Emissions and Non-
Air Quality Environmental Impacts. Berkeley, Calif.: Teknekron,
1978, pp. 3-12 through 3-15.
aBased on "moderate" electricity demand growth: 5.8 percent per
year through 1985 and 3.4 percent per year between 1985-2000.
Consists of Idaho, Wyoming, and Montana.
Consists of Nevada, Utah, Colorado, Arizona, and New Mexico.
this study do suggest what the impact of the 90 percent SC 2
control requirement might be on this area.
As indicated in Table 6-17, Teknekron's study shows that a 90
percent SO2 control requirement would have a large relative effect
on the emission levels in the mountain regions; e.g., emission
levels are reduced 43 percent and 67 percent by 1995 in the South
Mountain and the North Mountain regions respectively. However,
equally important are the low emissions for the Mountain regions
in the baseline case as compared to the U.S. total. For example,
the Mountain regions in the baseline case for 1995 account for
only about 3 percent of the total U.S. S02 emissions, and yet the
capacity of coal-fired power plants for the Mountain region is
7.7 percent of the U.S. total. The reasons for this low baseline
emissions rate for 'the Mountain region are the availability of
low-sulfur coal, the already strict state emissions standards, and
federal ambient air quality standards (e.g., PSD) that result in
relatively tight S02 controls for many plants even in the baseline
case. The strict controls required without BACT were indicated
previously in Table 6-4. The reason for the large percentage
difference between the baseline and 90 percent control cases for
the Mountain region is that given stringent controls, tightening
287
-------
them even slightly results in a relatively large percentage
reduction in emissions; for example, a tightening of SO2 percentage
removal rates from 80 to 90 percent means a 50 percent reduction
in emissions. In sum, the 90 percent S02 control alternative
shows a large relative drop in total S02 emissions in the West,
but in fact the standard would not, in general, be significantly
more strict than emission limits already imposed by many western
states or emission limits likely to be required on many plants in
order to meet PSD or new visibility standards.
In terms of national emissions, the data in Table 6-17 show
emissions reductions by 1995 of 2.2 million metric tons per year
relative to the baseline (a 14 percent drop).
One important disadvantage of this alternative may not be fully
accounted for in the above calculations. The 90 percent sulfur
control requirement provides no incentive whatsoever for utilities
to burn coals with a low or moderate sulfur content. Under this
alternative, they will be encouraged to seek the lowest priced
coal as long as 90 percent sulfur control will keep S02 emissions
below 1.2 lbs/106 Btu's.
(3) How Will Electricity Prices Be Affected?
The Teknekron study cited earlier also examined the effects
of this alternative on electricity prices;.1 Table 6-18 presents
projected real prices (1975 dollars) for the "baseline" and "90
percent S02 control" cases. Tighter S02 and particulate controls
are expected to increase electricity prices 0.05 cents/kWh na-
tionally (a 1.7 percent increase) in 1995. For the two Mountain
regions, the real price increases in 1995 are slightly larger--
0.07 cents/kWh for the North Mountain region (a 3.5 percent in-
crease) and 0.1 cents/kWh for the South Mountain region (a 3.75
percent increase).
As noted above, the 90 percent sulfur reduction requirement
provides no incentive for seeking low sulfur coals. Therefore,
this approach is inefficient since the same emissions levels could
be achieved at a lower economic cost by utilizing low sulfur coals
in conjunction with a lower percentage removal standard.
(4) Are There Other Costs or Benefits?
An across-the-board 90 percent sulfur control requirement
could have an adverse "efficiency" impact by limiting new, inno-
vative approaches for S02 control. The only demonstrated
Teknekron, Inc. Review of New Source Performance Standards
for Coal-Fired Utility Boilers, Volume II: Economic and Financial
Impacts. Berkeley, Calif.: Teknekron, 1978.
"> Q Q
ZOO
-------
TABLE 6-18:
ELECTRICITY PRICE IMPACTS OF 90 PERCENT SULFUR
DIOXIDE CONTROL: MODERATE GROWTH SCENARIO3
(cents per kilowatt hours: 1975 dollars)
REGION
North Mountain
South Mountain
United States
1985
BASELINE
2.30
2.67
2.81
90% CONTROLb
2.31
2.82
2.85
1995
BASELINE
2.02
2.67
2.93
90% CONTROLb
2.09
2.77
2.98
Source: Teknekron, Inc. Review of New Source Performance Stan-
dards for Coal-Fired Utility Boilers, Volume II: Economic and
Financial Impacts. Berkeley, Calif.: Teknekron, 1978, p. 3-20.
aThe "moderate electricity demand growth scenario" assumes a 5.8
percent annual increase through 1985 and 3.4 percent annually
between 1985 and 2000.
The 90 percent sulfur dioxide control scenario also includes a
tigntening of the particulate standard from 0.1 pounds per 106
British thermal units (lbs/106 Btu) to 0.03 lbs/106 Btu's. The
tighter particulate standard also contributes to the price in-
creases shown in this table, but the great bulk is due to the
sulfur dioxide removal requirement.
technology for achieving 90 percent reduction is throwaway FGD,l
either alone or in combination with some physical coal cleaning.
Other sulfur control technologies being developed include regener-
able FGD, chemical coal cleaning, fluidized bed combustion, and
low-Btu gasification/combined-cycle power plants. It is not cer-
tain that these new technologies can achieve a 90 percent reduc-
tion standard; thus industry may be reluctant to take the risk of
failure. EPA may need to develop some special procedures that
would not penalize industry for attempting innovative solutions
to the S02 control problem.
The use of currently available throwaway FGD processes also
creates a number of other environmental problems, including the
disposal of large amounts of sludge wastes, increased water
throwaway FGD, the used scrubbing material (a wet sludge)
must be disposed of. In contrast, with regenerable FGD the scrubbing
material is recycled, reducing a much smaller amount of waste and
some useful byproducts (e.g., elemental sulfur or sulfuric acid).
289
-------
TABLE 6-19: PROJECTIONS OF SLUDGE PRODUCED AND WATER CONSUMED
BY FLUE GAS DESULFURIZATION SYSTEMS:
DEMAND SCENARIO3
1995, HIGH
REGION
North Mountain
South Mountain
Nation
SLUDGE PRODUCED
(millions metric
tons per year, dry
basis)
BASELINE
.18
.76
12.0
90% CONTROL
1.3
1.8
55.0
WATER CONSUMED
(acre-feet
per year)
BASELINE
5,430
18,300
89,100
90% CONTROL
25,800
37,600
491,000
Source: Teknekron, Inc. Review of New Source Performance Stan-
dards for Coal-Fired Utility Boilers, Volume I:" Emissions "and '
Non-Air Quality Environmental Impacts. Berkeley, Calif.:
Teknekron, 1978, pp. 3-2TTFrough 3-T8.
aHigh demand growth scenario assumed 5.8 percent per year through
1985 and 5.5 percent per year thereafter.
This Is the make-up water (or the flue gas desulfurization sys-
tem) . It does not include increased water consumption for
cooling due to lowered efficiencies.
consumption, and lowered energy efficiencies due to the energy re-
quirements of the scrubbers. Table 6-19 gives estimates of the
sludge that will be produced and the water that will be required
in 1995 for the base case and the 90 percent sulfur removal
requirement.1 These data show large relative increases in solid
waste disposal and water consumption under the 90 percent sulfur
control option, both for the West and nationally. The land re-
quirements for sludge disposal should not be a significant problem
for the West, but they do create the threat of water pollution,
as discussed in Chapter 5. While the water consumption increases
are relatively large, these amounts represent only a small frac-
tion (around '5 percent) of that required for cooling.
In terms of energy efficiency, Teknekron estimates that, in
the 90 percent control case, 3.8 percent of the coal energy
Teknekron, Inc. Review of New Source Performance Standards
for Coal-Fired Utility Boilers, Volume I: Emissions and Non-Air
Quality Environmental Impacts. Berkeley, Calif.:Teknekron,~
1978, pp. 3-23 through 3-28.
290
-------
consumed will go to operate the FGD systems. This compares with
a 0.71 percent figure for the baseline case.1
(5) How Are Costs and Benefits Distributed Regionally?
The legislative history of the 1977 Amendments makes it clear
that one of the purposes of the BACT requirement was to redress
an inequity caused by the existing NSPS which gave low-sulfur
western coal a competitive advantage. That is, the intent was to
put western coal on a more equal footing with midwestern and
eastern coal. As indicated previously, this alternative does this
by substantially shifting the demand from western to east central
coal. The incremental electricity price increases due to this
requirement have been shown to be about twice as high in the west-
ern region as nationally—about 3.5 percent in the West compared
to 1.7 percent nationally.
In looking at the distribution of impacts among the states
in the eight-state study area, the equity question needs to be
looked at in both environmental and economic terms. Some states
in the West have much stricter emission and ambient air quality
standards than do others. Since air pollutants do not respect
state borders, this can become the basis for conflict. The states
with less stringent standards have some economic advantage in
attracting industry and yet the "clean-air state" could suffer air
degredation from energy facilities near their border or via the
long range transport of pollutants. The mandatory 90 percent SO2
removal requirement would remove the environmental and economic
inequities by requiring all states ~to control S02 to approximately
the same degree. Of course, it does this by taking away from
states the right to set emission standards as they wish and on the
basis of what they consider to be in their own best interest.
(6) Are Utilities or Investors Affected Financially?
Another aspect of "equity" to, be considered is the economic
impact of the 90 percent SC>2 control requirement on the utility
industry. In principle, regulators allow utilities to set prices
just high enough so that revenue collected will equal the costs
of providing service (including an appropriate return on invest-
ment) . In practice, ratemaking is subject to "regulatory lag,"
i.e., rates are adjusted to current circumstances only once every
few years. And although the full cost of such equipment as FGD
units is supposed to be borne by the utility customers, regulatory
lag often results in utility investors receiving less than the
allowed rate of return as long as intensive construction schedules
persist.
1Teknekron, Inc. Review of New Source Performance Standards
for Coal-Fired Utility Boilers, Volume I: Emissions and Non-Air
Quality Environmental Impacts. Berkeley, Calif.: Teknekron,
1978, pp. 3-30 and 3-31.
291
-------
TABLE 6-20:
RETURN ON EQUITY FOR ELECTRIC UTILITIES UNDER
ALTERNATIVE SCENARIOS, 1985-1995
(percent) (moderate electricity demand growth rate)
Baseline
90% standard
Difference.
NATION
12.4
11.9
.5
NORTH
MOUNTAIN
16.5
13.9
2.6
SOUTH
MOUNTAIN
13.2
12.7
.5
Source: Teknekron, Inc. Review of New
Source Performance Standards for Coal-Fired
Utility Boilers, Volume II:Economic and
Financial Impacts.
Teknekron, 1978, p,
Berkeley, Calif.:
3-37.
Teknekron has estimated the investor-borne costs associated
with a 90 percent sulfur removal standard.1 Two measures employed,
both considered important by participants in capital markets, are
summarized in Tables 6-20 and 6-21. It was assumed that return on
equity—the annual profit per dollar investment of the shareholder--
is targeted at 13 percent by the regulatory authorities. As can
be seen in Table 6-20, the average utility in the nation will
probably not achieve the allowed rate of return even in the base-
line scenario. Imposition of the 90 percent sulfur removal
TABLE 6-21:
INTEREST COVERAGE RATIOS FOR ELECTRIC UTILITIES
UNDER ALTERNATIVE SCENARIOS, 1985-1995
(moderate electricity demand growth rate)
Baseline
90% standard
Difference
NATION
3.14
3.14
0
NORTH
MOUNTAIN
4.38
4.36
.02
SOUTH
MOUNTAIN
3.42
3.31
.11
Source: Teknekron, Inc. Review of New
Source Performance Standards for Coal-Fired
Utility Boilers, Volume II: Economic and
Financial Impacts. Berkeley, Calif.:Tek-
nekron, 1978, p. 3-39.
Teknekron, Inc. Review of New Source Performance Standards
for Coal-Fired Utility Boilers, Volume I: Economic and Financial
Impacts. Berkeley, Calif.:Teknekron, 1978, p. 3-39.
292
-------
standard would double that discrepancy for the nation as a whole
(1.1 percentage points versus 0.6). The North Mountain states
would experience a much larger effect from the sulfur standard,
but these utilities would still end up with a higher-than-allowed
rate of return.
Table 6-21 expresses the returns to capital in terms which
highlight risks to lenders. The interest coverage ratio,
earnings + interest payments
interest payments
shows the safety margin which protects lenders in the face of the
utility's unpredictable earnings. Utilities often enter into
agreements with bond buyers not to extend their debt any further
if the interest coverage ratio falls below 2.0 to 1.75 range.
Table 6-21 shows that the proposed sulfur standard does not move
utilities very far toward ratios which would be considered finan-
cially risky., There is essentially no effect nationally or in the
North Mountain region.
In sum, Teknekron's modeling results indicate that, in a con-
text of regulatory lag, utility shareholders will bear a measurable
amount of costs due to implementing a sulfur control standard.
The actual effect on shareholders will probably exceed that indi-
cated by this model, since it assumes annual ratemaking reviews,
whereas in practice comprehensive reviews and adjustments normally
occur only once every two or three years. Nevertheless, the extra
cost borne by investors will not be large enough to have much
affect on the credit rating of the average utility.
(7) Is the Alternative Flexible and Easy to Implement?
The 90 percent SO 2 control requirement would not satisfy a
flexibility criterion since it sets an across-the-board requirement
and does not allow for setting S02 emissions limitations based on
the circumstances unique to different regions.
In a procedural sense, this alternative would be easy to im-
plement under the provisions of the 1977 CAA Amendments. However,
the standard could result in some very practical difficulties for
EPA monitoring activities. It would require EPA to monitor both
emission rates and effectiveness of sulfur removal systems. In
measuring the percentage of sulfur removal, EPA would have to
monitor both coal cleaning plants and FGD systems. No information
was available on the economic costs of these increased monitoring
tasks.
(8) Summary of BACT Alternative
Table 6-22 summarizes the findings just presented -for the
policy alternative of requiring 90 percent sulfur control on all
new, large coal burning facilities. Very briefly, on the positive
293
-------
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-------
side this alternative will contribute to a reduction in SO2 emis-
sion rates, although in the West strict state standards and PSD
regulations mean that relatively strict controls would be required
anyway. It will also help achieve the national goal of shifting
demand from western coal back to eastern and interior coals, while
allowing for an almost 300 percent growth in western coal produc-
tion between 1975 and 1990. Emission rates among the states will
be equalized, thus reducing the potential conflicts between "clean-
air" states and "prodevelopment" states. Implementation of this
alternative could be achieved directly under the requirements of
the 1977 CAA Amendments.
On the negative side, electricity prices are projected to in-
crease 1.7 percent nationally and about 3.5 percent for the West;
the approach is inefficient since the same emission levels could
be achieved with lower costs by giving credit for the use of low
sulfur coals. Due to regulatory lags some measurable proportion
of these increased costs will be borne by utility investors rather
than by consumers. There are a number of environmental costs
with currently available throwaway FGD processes: large amounts
of sludge wastes, some increase in water consumption, and a lowered
power plant efficiency of almost 4 percent. The alternative would
also present some enforcement difficulties for EPA; it would re-
quire monitoring coal cleaning plants and measuring both emission
rates and overall sulfur removal percentages.
C. Evaluation of the Smaller, Dispersed Energy Facilities Alter-
native
In evaluating this specific alternative, it will be assumed
that the basic hardware will be the same in the single, large plant
case and the dispersed, smaller plant case. For example, with
coal-fired power plants a single large plant of say 1,500 MWe
capacity might consist of three 500 MWe units, with each unit made
up of a boiler, turbine, generator, and cooling tower.1 Under the
smaller, dispersed facilities alternative, the basic units would
simply be dispersed rather than being built side by side.
It is interesting to note that the general approach suggested
by this specific alternative is receiving considerable attention
from both utilities and government. For example, the New York
Public Service Commission has required a utility to examine the
pros and cons of building 300 to 600 MWe facilities instead of
the more conventional strategy of relying on 900 to 1,200 MWe
plants. The commission stated: "It has been conventional system
planning wisdom for a long time that construction of plants of ever
increasing capacity is desirable (1) to achieve scale economies,
*With other types of cooling systems, such as once-through
cooling or cooling ponds, the three units might actually share the
same cooling systems rather than having three distinct systems.
296
-------
and (2) to reduce the environmental impact associated with siting
a number of smaller generating plants. We believe these arguments
must now be reexamined in light of current conditions and future
prospects."1 There are also two major research projects currently
underway which are comparing the environmental and economic trade-
offs between large versus small power plants, one at Los Alamos
Scientific Laboratory (sponsored by EPA), and one at the Electric
Power Research Institute.2 When the results of these studies are
completed, considerably better information will be available than
now exists.
(1) Will Increased Western Energy Development Be Allowed?
As was indicated previously in Section 6.2.1.A., only coal
conversion facilities (especially power plants) and oil shale plants
face serious size restrictions due to ambient air quality standards.
However, there is little flexibility in siting oil shale facili-
ties due to the concentration of the resources in a relatively
small geographical area and the impracticality of shipping the
raw shale for retorting at a distant location. Therefore, the
smaller, dispersed facilities option is primarily of interest for
coal. Because coal resources are widely distributed throughout
the eight-state study area and because it. is economically feasible
to ship coal some distance from the mine for conversion, there is
considerable flexibility in coal conversion facilities siting.
Even if plants meet strict BACT emission restrictions, air
quality regulations (i.e., NAAQS, PSD, or state standards), can
restrict the siting of large energy facilities. As indicated
previously in Section 6.2.2, the maximum size allowed will depend
on such factors as the emission rates of the various air pollut--
ants, terrain, meteorological conditions in the vicinity of the
site, and proximity to PSD Class I areas. Where large facilities
are prohibited because of air quality regulations, the approach
suggested by this alternative is to build the same desired total
capacity in smaller units dispersed, over a large enough area so
as to minimize significant air pollution interactions. This would
reduce air pollution concentration levels thus helping to avoid
energy growth restrictions.
Because it is assumed that the same basic hardware is being
used in both cases, the total emissions will be the same regardless
JNew York Public Service Commission. Opinion Analyzing Plans
Pursuant to Section 149-b of the Public Service Law and Order
Directing Additional Studies, Opinion No. 78-3, Case 27154--Long
Range Electric Plans. Albany, N.Y.: Public Service Commission,
March 6, 1978.
2Ford, Andrew, Los Alamos Scientific Laboratory, and Wyzga,
Ronald E., Electric Power Research Institute. Personal communi-
cations, May 1978.
297
-------
of the plant siting strategy. Thus, region-wide air impacts or
impacts from the long-range transport of pollutants would not be
significantly different under this alternative.
In addition to air quality considerations, the smaller facil-
ities approach could also alleviate siting difficulties caused by
limited water resources since the smaller plants will consume pro-
portionately less water than large facilities. For example,
smaller facilities could be sited near small rivers where it might
not be feasible to site a plant three or four times larger.
One potential drawback of this alternative in terms of its
effect on levels of energy development has to do with the siting
process. As discussed in Chapter 12, obtaining permits and meeting
other regulatory requirements can be a very time consuming, expen-
sive, and frustrating process. The smaller facilities alternative
increases the number of siting applications a developer would have
to make, including acquiring more sites, possibly preparing more
environmental impact statements, and obtaining more permits. This
could potentially "clog" the system, thereby slowing energy devel-
opment activities. However, this consequence might be avoided,
particularly since the concentration of negative environmental
impacts would generally be far less for the smaller facilities.
For this reason, they might face less opposition, thereby easing
the siting process for each small facility compared to a much lar-
ger one.
(2) Are There Economic Costs or Benefits Associated with this
Option?
The economic trade-offs between the large vs. smaller facil-
ities strategy depends on a large number of factors which can be
dealt with in detail only in a specific case-by-case basis. For
power plants, it is clear that utilities came to believe that very
large facilities offered an economy of scale advantage. However,
this thinking has begun to be questioned for a variety of reasons,
some of which will be discussed in this section. The general
trade-offs involved for electric power plants will be highlighted.
Similar considerations apply to other types of energy conversion
facilities although the specifics would, of course, vary.
There is little question that the large power plant strategy
offers capital cost advantages on a dollar per kilowatt-hour (kw)
capacity basis. Assuming that the basic hardware (i.e., boilers,
turbines, and generators) are the same regardless of facility
size, the capital costs for these items would be approximately the
same (the labor costs for construction might be lower for the large
plant option). However, the smaller facilities option would have
some diseconomies associated with coal handling equipment and land.
For example, three separate facilities would require from 2 to 2.5
times as much land (depending on the type of cooling system) as a
298
-------
large facility.1 The results of one study indicate that overall
three separate 700 MWe units would have a 20 percent higher capi-
tal cost than a single 2,100 MWe plant.2
The smaller, dispersed facilities option would also have some
operating cost disadvantages since single, large plants require
fewer operations personnel on a per kw basis. Coal supply costs
(including transportation) could also be higher with the smaller
facilities option, although this would depend on many site speci-
fic factors-, such as the location of potential coal supply sources
relative to the plant sites and the availability of existing rail
lines.
Another possible diseconomy associated with the smaller, dis-
persed facilities option would be the energy delivery system (e.g.,
electric transmission lines or gas pipelines). These energy
transportation systems offer significant economies of scale. For
example, an electric transmission line capable of handling 500 MWe
would cost approximately 30-40 percent more on a per kWh per mile
basis than a line capable of handling 1,500 MWe.3 The net effect
on energy delivery costs would depend on a variety of considerations
such as the location of a site in relation to the demand center
and the availability of transportation rights-of-way. If the
smaller facilities option allowed the plants to be located closer
to the demand centers, this option might well have the lowest
energy delivery costs.
Depending on how the construction of units is timed, the
smaller facilities option could offer certain economic advantages
which would outweigh the higher capital and operating costs. If
the large plant is constructed in such a way as to bring all of its
units on line simultaneously, the total elapsed time from the deci-
sion to proceed to commercial power production may range from
about 9.5 to 12 years. The equivalent time period for a small
plant would be from 5.5 to 7.5 years. The shorter planning
:Wyzga, Ronald E. "Concentrated vs. Large Dispersed vs. Dis-
persed vs. Atomized Power Plants-Overview." Paper presented at
Engineering Foundation Conference on Non-conventional Siting of
Power Plants, Henniker, New Hampshire, July 10-15, 1977.
2 Ibid.
Calculated from U.S., Federal Power Commission. 1970 National
Power Survey. Washington, D.C.: Government Printing Office, 1971,
Vol. I, p. 13-9, as cited in U.S., Congress, Senate, Committee on
Energy and Natural Resources and Committee on Commerce, Science,
and Transportation. National Energy Transportation, Vol. I:
Current Systems and Movements, Committee Print, by the Congressional
Research Service. Washington, D.C.: Government Printing Office,
1977, p. 357.
299
-------
period for small plants reduces the uncertainty of forecasting
electricity demand and thus reduces the likelihood that a utility
will be caught with capacity excesses or shortages. Also, the
shorter lead time for smaller facilities means that the financial
burden of carrying a large amount of "construction work in prog-
ress" would be reduced. 1
In sum, it is not possible to state categorically that the
smaller, dispersed facilities option is either more or less eco-
nomically attractive than building a single large plant. The
economic trade-offs would depend on many factors that could only
be evaluated precisely on a case-by-case basis.
(3) Are There Other Environmental or Social Effects?
The construction of smaller, dispersed energy facilities
could have an important effect on the level of social and economic
impacts. Small facilities will generally have a larger peak labor
force on a per unit of energy basis than a larger facility. For
example, one estimate is that a 500 MWe power plant would have a
peak construction requirement of 650 persons (1.3 persons per MWe)
while a 3,000 MWe plant would only have a peak construction force
of 2,850 (.95 persons per MWe).2 However, if the smaller facili-
ties are built sequentially or are separated enough so that popula-
tion impacts fall on different communities, the "boomtown" effects
discussed in our impact analysis report3 and chapters 8 and 9 of
this report could be reduced significantly.
Two potential negative environmental impacts of the smaller
facilities option are difficult to quantify. First, the smaller
facilities approach will require more Icind for the facilities them-
selves (as indicated previously, on the order of 2 to 2.5 times as
for the same total capacity in 700 MWe power plant units as opposed
to a single 2,100 MWe facility) . However, given the vast land re-
sources in the eight-state study area, this is not necessarily a
significant factor. The second area of concern is that the smaller
facilities could possibly lead to a greater proliferation of power
lines which not only require more land for rights-of-way but also
have negative aesthetic impacts. However as mentioned earlier in
connection with transportation economics, it is not possible to
Andrew. "Expanding Generating Capacity for an Uncer-
tain Future: The Advantage of Small Power Plants." Paper pre-
sented at the Conference on Simulation, Modeling, and Decision in
Energy Systems, Montreal, Canada, June 1, 1978.
2Ford, Andrew, Los Alamos Scientific Laboratory. Personal
communication, May 1978.
3White, Irvin L., e t al . Energy From the West; Impact
Analysis Report. Washington, D.C.: U.S., Environmental Protection
Agency, 1977, forthcoming.
300
-------
generalize these factors since they will depend upon so many
case-specific variables.
(4) Are There Equity Considerations?
One disadvantage of the very large energy facilities approach
is that such facilities concentrate most of the associated adverse
environmental and social impacts in a very small area. In addi-
tion, once the facility is on-line and population levels stabi-
lized, overall tax benefits, particularly benefits for counties,
will often greatly exceed that governmental unit's needs. For
example, in Rosebud County, Montana, the school districts are ex-
pected to enjoy substantial financial surpluses if current tax
rates are maintained.1 This can create serious equity problems
if many of the energy facility employees live in other counties
or in municipalities which do not receive these tax benefits.2
The smaller, dispersed energy facilities alternative could
alleviate some of these inequities. Impacts would be distributed
more widely and, as noted previously, the undesirable social and
economic effects caused by "boomtown" conditions would be reduced.
Also, if the smaller facilities are sited in different towns or
counties the tax benefits would be more evenly ditributed over the
region.
(5) Is the Alternative Flexible?
The flexibility of this policy alternative depends on the spe-
cific implementation strategy followed. As indicated above, the
pros and cons of the smaller facilities alternative are not clear-
cut and can vary significantly from case to case. For this reason,
any implementation strategy for this approach should be flexible
enough to allow the alternative to be considered on a case-by-cas>e
basis.
One implementation strategy which gives flexibility without
ignoring possible benefits would be for state utility commissions
to require industry to evaluate the smaller, dispersed facilities
1White, Irvin L. , et al. Energy From the West: A Progress
Report of a Technology Assessment of Western Energy Resource Devel-
opment. Washington, B.C.: U.S., Environmental Protection Agency,
1977, Section 10.4.6.
2As noted in Chapters 8 and 9, the revenues problem has two
elements, timing and distribution. First, early in a development,
all affected governmental units experience a revenue shortfall un-
less special programs have been initiated to prevent this from oc-
curring; and second, some governmental units, particularly munici-
palities, usually have to meet the major services and facilities
needs but do not receive a very large share of the revenue benefits
associated with development.
301
-------
approach explicitly in their planning. (This is the tack taken by
the New York Public Service Commission.)l Alternatively, federal
agencies could require that this option be considered explicitly
in the alternatives section of environmental impact statements for
new energy facilities. These approaches would not necessarily
force industry to choose the option, but they would force them to
look at it. In the process, more information would be made pub-
licly available about possible costs and benefits of smaller, dis-
persed facilities.
(6) Would the Option Be Easy to Implement?
One implementation strategy suggested above was to require in-
dustry to consider the smaller, dispersed facilities approach in
its planning and environmental impact statements. This would be
easy for utility commissions and federal agencies to implement if
they were convinced that the ideas warranted serious consideration.
Of course, this approach is based on being flexible and not neces-
sarily "forcing" the developer to choose the smaller facilities
approach; and, therefore, this approach would not ensure that the
small facilities alternative is ever implemented.
More covert actions would be taken to force the construction
of smaller, dispersed facilities through such means as a graduated
emissions tax or a government prohibition on facilities above a
certain size. However, these implementation strategies would re-
quire new laws and would likely be strongly resisted by industry.
(7) Summary of Evaluation for Smaller Facilities Alternative
Table 6-23 summarizes the findings for the policy alternative
of constructing smaller, dispersed energy facilities. This ap-
proach offers the potential for contributing to the achievement of
the stated policy objective, but it also has several possible draw-
backs. The net effect will depend on a variety of case specific
factors so that generalizations are not possible. By reducing
plant size, negative impacts are diluted: peak air pollution con-
centration levels, water requirements, and "boomtown" impacts are
all reduced. Lead times for construction could also be reduced by
as much as 50 percent. For these reasons, siting a small facility
should be easier, thus possible allowing for more rapid energy
development. Also, tax and other economic benefits would be more
uniformly distributed in the region.
On the other hand, capital and operating costs will be some-
what higher for small facilities, although these possibly could be
*New York Public Service Commission. Opinion Analyzing Plans
Pursuant to Section 149-b of the Public Service Law and Order"
Directing Additional Studies, Opinion No. 78-3,,Case 27154--Long
Range Electric Plans. Albany, N.Y.: Public Service Commission,
March 6, 1978.
302
-------
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offset by reducing the costs of excess or inadequate capacity due
to demand forecasting errors and by reducing the financial costs
of carrying large amounts of "construction work in progress."
Also, the larger number of plant siting procedures could possibly
slow energy development. Land requirements for the smaller plants
will be 2 to 3 times larger, while land use for energy transporta-
tion systems will depend on the relative location of raw energy
production sites, the plant sites, and the energy demand points.
Since the net balance of the various pros and cons will vary
on a case-by-case basis, it is not advisable to force this policy
alternative across-the-board. However, state utility commissions
or the federal government could encourage this alternative by
requiring that industry consider it in their planning, and in the
process much more detailed information would be generated about
the costs and benefits of this approach.
D. Evaluation of Commercialization Programs
The threat to western air quality from large scale energy
development could be significantly reduced if cleaner production
technologies presently being developed prove out and become avail-
able to be utilized commercially. Thus, there are advantages for
the West in a policy alternative which rapidly moves new, clean
technologies through the research, development, and demonstration
(RD&D) phases to a point where they are commercially available in
the short term, that is, within the next 10 years. This means
efforts should focus on processes currently ready or which will
soon be ready for construction of commercial-scale demonstration
plants .
Commercial-scale demonstrations represent the final stage in
a scaling-up process and should take place only after the tech-
nology is well understood. Such demonstrations serve to determine
what the performance characteristics will be with scale-up (e.g.,
air emissions and efficiency) as well as to help identify market
demand and other important factors which need to be known to in-
form decisions on whether to adopt the; technology.1 Impacts of
particular concern in the West should be air quality, water con-
sumption, and labor (population) impacts.
Given the high cost of commercial demonstration projects
(as much as $1 billion for coal synthetic projects) , major federal
funding might be essential. At the same time, the need to demon-
strate the air quality advantages to western states and interest
groups requires that they be included in the planning and execution
Walter S.r Leland L. Johnson, and Edward W. Merrow.
Analysis of Federally Funded Demonstration Projects: Final Report ,
for U.S. , Department of Commerce, Experimental Technology Incentive
Program. Santa Monica, Calif. : Rand Corporation, 1976.
304
-------
of a demonstration program focused on the West. Thus, such a
demonstration program must involve at least four different cate-
gories of participants: the federal government, the western
states, western energy resource developers, and other affected
interest groups such as environmentalists, consumers, and agri-
culturalists .
Several possible strategies can be used to implement such a
program. It might be accomplished either by having the Department
of Energy establish a continuing committee or commission which in-
volves these interests, or by establishing a program within an
organization of the western states such as the Western Governors'
Policy Office. The committee approach would likely be easier to
manage, but would not be as likely to build a regional base of
support for the commercialization program as the link with the
regional organization.
(1) Is the Alternative Effective?
Tables 6-1 and 6-2 in this chapter listed the air emission
rates for the various technologies considered in this study. As
was discussed, many of these energy resource development systems
have fewer air emissions per unit of energy produced than conven-
tional coal-fired power plants. In addition, other new energy
conversion technologies which offer the potential for low air
emissions are not considered in this study. These include fluid-
ized bed combustion, low-Btu gasification/combined cycle power
plants, and solvent refined coal plants.
Of course, technologies cannot be ranked solely on the basis
of air emissions and air quality impacts. Economic costs are
crucial in any situation, while water consumption and labor re-
quirements are especially important in the West. A broad compari-
son of the energy resource development systems considered in this
study is given in Chapter 13. Since considerable uncertainty sur-
rounds the cost and impact characteristics of any new technology,
no options are clearly superior to conventional coal-fired power
plants in all respects. However, several offer potential advan-
tages for the West; for example, coal synthetic fuel processes
generally emit fewer air pollutants and require less water than
coal-fired power plants. The major current uncertainty with re-
gard to these technologies is their economics. A demonstration/
commercialization effort which will improve the available data on
these newer technologies and, thereby, possibly insure or speed
their commercialization would be an effective policy alternative
for protecting western air quality while still allowing western
energy resources to be developed.
However, there remains the question of just how effective an
expanded RD&D program would be in insuring or speeding 'the devel-
opment of these new technologies. Of course, such a question can
305
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not be answered precisely since the uncertainty surrounding the
technologies is what leads to the demonstration requirement.
Some of the potentially attractive processes are currently consid-
ered to be technically available but they are not being commer-
cially developed in the United States. For example, the Lurgi and
Koppers-Totzek coal gasification processes are being utilized
commercially in other countries, but their commercial development
has been slow in this country. Several commercial-scale coal
liquefaction, coal gasification, arid oil shale projects have been
in the discussion stage for at least the past five to ten years,
but few are currently being constructed and none are yet in opera-
tion. The reasons for this are primarily due to uncertainties in
production costs, future market prices for oil and gas which are
largely controlled by OPEC,, and environmental impacts and regula-
tions. Many of these synthetic fuel processes are ready now for
commercial-scale demonstration. For other technologies, such as
liquid-dominated geothermal, there is also the possibility of
demonstration plants in the near future, although some further
development work may be needed to test out alternative process
designs. In short, while the effectiveness of a well-designed
RD&D program cannot be predicted with certainty, it is probably
safe to state that without such a program these newer technologies
will not be rapidly developed and commercialized.
(2) What Are the Economic Costs and Risks?
The economic costs of energy RD&D, especially at the demon-
stration stage, are quite expensive. For example, a commercial-
scale coal gasification plant (250 million cubic feet per day)
would cost on the order of one billion dollars. In addition to
the cost of the plant, total costs would include the research
needed to determine the environmental and socioeconomic impacts
of the facility. Costs of a similar magnitude would apply for
coal liquefaction plants producing 50,GOD barrels per day (bbl/day)
while oil shale plants producing 50,000 bbl/day would cost or the
order of $0.6 billion.1 Commercial-scale geothermal demonstration
plants can be much smaller (say 25-50 MWe) and thus less costly.
Two demonstration power plants for liquid-dominated resources
would cost on the order of one hundred nillion dollars.
The costs of these facilities would presumably be divided
between the public sector (both federal and state governments) and
industry. The proportion of costs assumed by each party and the
future revenues (if any) would depend on the particular implemen-
tation strategy. Public sector front-end costs and economic risk
could be minimized by offering certain incentives to industry
(e.g., guaranteed prices for production) to construct and operate
the demonstration plant. However, the associated impact research
must be paid for by the public sector to insure credibility, and
JSee Chapter 10 on Capital Availability.
306
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the demonstration program must be organized so that there is a
viable option of shutting down the demonstration plant or at least
preventing further development if the impacts are found to be
unacceptable.1
Since the results of RD&D projects can never be guaranteed
ahead of time, it is not possible to quantify costs versus bene-
fits. However, as mentioned earlier, at the demonstration stage,
the technology is usually reasonably well in hand. Due to the
large costs involved, commercial-scale demonstrations would not
usually be undertaken if there is a high probability of failure.
If the RD&D program does lead to large-scale commercial develop-
ment, the demonstration costs would represent a small proportion
of the economic value of all future production.
(3) How Are Costs and Benefits Distributed?
If an RD&D program were successful in developing new techno-
logies for producing western energy resources while minimizing
air quality impacts, several sectors or groups would benefit: the
nation as a whole would presumably benefit from the increased
domestic production of energy; the western states would enjoy the
economic benefits that such development would bring while still
maintaining a high standard of air quality; and industry would
obtain the profits from undertaking the commercial development
activities. Thus, to be most equitable the demonstration/commer-
cialization program should be organized so as to share the costs
and risks among these sectors.
There has been considerable opposition to federal support of
some synthetic fuel demonstration plants. The issue is basically
one of equity. On one side, the argument is that these technolo-
gies are being utilized at a commercial-scale in other countries;
and, therefore, there is no need for government to spend public
money to support industry in these endeavors. On the other hand,
it is pointed out that the commercial-scale plants in other
countries do not operate in the same economic, environmental, and
social setting as exists in this country and, therefore, the risks
are not the same. The fact is that no large-scale synthetic fuel
plants (either coal gasification, coal liquefaction, or oil shale)
have been built in the U.S. although the technologies are
:See Kash, Don E., et al. Our Energy Future: The Role of
Research, Development, and Demonstration in Reaching a National
Concensus on Energy. Supply. Norman, Ok la. : University of Okla-
homa Press, 1976; and Baer, Walter S., Leland L. Johnson, and
Edward W. Merrow. Analysis of Federally Funded Demonstration
Projects: Final Report, for U.S., Department of Commerce, Experi-
mental Technology Incentive Program. Santa Monica, Calif.: Rand
Corporation, 1976, for a discussion of strategies for energy RD&D
programs.
307
-------
"available" in a strict engineering sense. It appears at the
present time that some form of public sector support will be re-
quired if commercial-scale synthetic fuel plants are to be built.
Given the distribution of benefits if this alternative is success-
ful, this seems to be an equitable policy. In any case, it is
necessary for credibility reasons for the public sector to fully
fund the impact assessments studies that should be performed be-
fore a full-scale synthetic fuel industry is developed.
(4) Is the Policy Flexible?
To be most flexible, the demonstration programs should pursue
a variety of technologies, subject, of course, to budget con-
straints, and the best option should then be chosen for large-
scale commercialization. Pursuing the fullest set of technologies
that funding allows will insure that potentially attractive op-
tions are not prematurely dropped. Each project should be fully
evaluated along the way using a broad set. of criteria including
technical and economic feasibility, environmental impacts, socio-
economic impacts, and institutional constraints. Both the plan-
ning and evaluation procedures should be open and allow for mean-
ingful public participation, in order to insure that legitimate
concerns are addressed in the demonstration program and to help
build public confidence in the decisionmaking process.
(5) Does the Alternative Face Implementation Constraints?
This alternative would rank low in terms of ease of implemen-
tation. There are several fundamental problems. Perhaps the most
important is that it requires large amounts of money from both the
public and private sectors. It also requires a considerable amount
of cooperation and coordination among industry, the federal govern-
ment, and western state governments; and depending on the imple-
mentation strategy pursued, it could require the creation of a new
institutional arrangement among the western states for the joint
demonstration program. The history of the COALCON demonstration
plant in Illinois points out the kinds of problems that such a
program can face.
(6) Summary of Evaluation of Commercialization Alternative
Table 6-24 summarizes the findings for the alternative aimed
at bringing new, cleaner energy conversion technologies into com-
mercial use in the West. The option is inherently attractive
since it offers the possibility for large levels of energy produc-
tion and conversion with much Lower levels of air pollution than
emitted by electric power plants, the predominant energy conver-
sion technology currently being used. However, the policy faces
several major hurdles, the most important being the large economic
costs involved and the required cooperation among the federal gov-
ernment, western state governments, and industry.
308
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E. Evaluation of Siting Task Force Option
This policy alternative aims at creating an overtly political
process for reaching an accommodation between the conflicting
interests of energy/economic development and air quality protec-
tion. The specific goal of the task force would be to reach a
consensus on future sites for major energy conversion facilities,
and thus avoid the expensive and time-consuming delays often en-
countered in energy facilities siting. This approach has been
undertaken in Utah, where the governor's office formed a task force
composed of representatives from federal land management agencies,
state and local governments, environmental groups, consumers, and
industry.1 Although the Utah "Interagency Task Force on Power
Plant Siting" was initially formed to resolve siting conflicts
with the Intermountain Power Project near Capitol Reef National
Park, utilities now have consistently sought the advice of the
task force, nominating six to twelve sites for task force evalua-
tion. The result has been an agreement to avoid power plant siting
in Utah's scenic and national park-filled southeast quadrant, with
eight sites in the central part of Utah identified for future
development.
(1) Is the Alternative Effective?
This policy alternative will do nothing directly to reduce
air emissions from energy development. What it will do, however,
is site power plants in locations where a consensus has been
reached that the air emissions will have the fewest adverse impacts.
In terms of levels of energy development, this policy would
produce two countervailing forces the net effect of which is dif-
ficult to predict. On the one hand, the process could help to
eliminate or significantly reduce the debilitating delays that
often accompany the siting of large energy facilities. For this
reason, it could help to increase energy development. On the
other hand, although industry would not be legally bound by the
consensus of the task force, they would probably find it difficult
to gain permission to site conversion facilities in areas found by
the group to be unacceptable. Thus, the conversion of substantial
energy resources in some areas could be foregone or delayed. This
type of effect has already been noted in the Utah experience, where
energy export schemes may be constrained. The head of Utah's
Energy Office stated that the Intermountain Power Project, backed
by the Los Angeles city utility, may be the last export project in
Utah "at least for a long time, since we can't afford to use up
any of those other seven sites for outsiders until we're sure we
won't need them for Utah's own future power."2
:Utah Energy Office, Staff. Personal communication, June 1978
2Gill, Douglas. "Deal Spares Utah Parks Area." Denver Post,
May 28, 1978, p. 35.
310
-------
(2) What Are the Economic Costs?
The administrative cost of the program would be relatively
low. Costs would include travel expenses, report preparation, and
possible per diem expenses or subsidies for some participants.
Costs would increase if research tasks or environmental studies
became a major element of task force activities. In the Utah ex-
perience many of these ~osts have been absorbed by partiHpating
agencies or groups.1
The program could have an effect on energy development costs.
By avoiding lengthy delays in the siting process, energy production
costs would be reduced. On the other hand, the task force consen-
sus could lead to site choices which are more expensive than would
otherwise be chosen by industry including such item? as land cost,
cooling system costs, coal transportation costs, etc.
(3) Are There Equity Issues?
While some groups may not agree with the final decisions of
the task force, the whole concept of this policy alternative is to
find an equitable way to reach an accommodation among conflicting
interests. If the task force is properly structured so as to per-
mit participation by any potentially impacted group, then the
approach should rate high on an equity criterion.
(4) Is the Alternative Flexible and Implementable?
Flexibility of the task force alternative is high, as it is
convened at the request of a governor or agency head. Its deci-
sions are an attempt to introduce flexibility into a system that
is often characterized by bureaucratic, industrial, and environ-
mental intransigence.
Implementability should also be relatively easy as advisory
functions are usually attractive to most participants and costs
are low. However, because the effectiveness of the task force
requires a specific response on the part of industry, some resis-
tance to implementation could occur. In the case of Utah though,
industry has been a very willing participant.2
(5) Summary of Evaluation of Siting Task Force Alternative
The conclusions for the evaluation of the siting task force
alternative are summarized in Table 6-25. This policy option and
the findings are based largely on the experience with the Utah
"Interagency Task Force on Power Plant Siting." If the task force
JUtah Energy Office, SteTi. Personal communication, June 1978
2Utah Energy Office, Staff. ^Personal communication, June 1978,
311
-------
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is successful in reaching a consensus on future sites, siting
delays and air pollution impacts would be reduced. This approach
is attractive since administrative costs are low and flexibility
is high; the goal is to avoid the bureaucratic and legalistic
conflicts that often surround energy facility siting decisions.
However, success of the approach will depend on a spirit of cooper-
ation and an ability to reach a consensus where there are often
fundamental value differences among interested parties. The
limited experience in Utah indicates that such an agreement is
possible, but this may not be the case in other states. Also,
energy development could be constrained due to a limited number
of sites agreed upon.
F. Summary and Comparison of Air Quality Policy Alternatives
Three categories of alternatives and nine specific alterna-
tives for protecting western air quality while proceeding with
western energy resource development have been identified and de-
scribed. Four of the specific alternatives were evaluated using
five criteria: effectiveness, efficiency, equity, flexibility,
and implementability. Table 6-26 provides a brief summary and
comparison of these four alternatives. While the net effect of
any one alternative is uncertain, each has the potential for con-
tributing to the achievement of the policy objective but in dif-
ferent ways and with different levels of efficiency, equity, etc.
The BACT definition of 90 percent sulfur removal is a regulatory
program aimed at limiting S02 emissions for large coal burning
facilities, especially power plants. This standard is not expected
to have a major effect on the number of power plants constructed
in the western region but it will dampen the demand for raw western
coal. A complimentary approach is offered by the commercializa-
tion program alternative, the goal of which is to bring into prac-
tical use new energy conversion technologies which are inherently
less polluting than conventional coal-fired power plants. This
could allow larger levels of western energy development while still
protecting air quality. Unlike these previous two policies the
smaller dispersed facilities alternative and the siting task force
alternative do nothing directly to reduce emission rates. Rather,
the smaller, dispersed facilities approach attempts to minimize
adverse air impacts by reducing the peak air pollution concentra-
tion levels that would otherwise occur. Its effect on overall
energy development levels is uncertain. The siting task force
option primarily aims at eliminating some of the procedural pro-
blems which constrain western energy development; it contributes
to the protection of air quality by identifying those areas where
it is agreed the air emissions would have the fewest adverse con-
sequences.
The other four criteria (efficiency, equity, flexibility,
and implementability) reflect other pros and cons of the policies
which can be measured against their effectiveness. Since, as just
313
-------
described, the goals of each policy vary widely and the net effects
are uncertain, it is difficult to make direct comparisons among
the alternatives. Nevertheless, in the preceeding evaluations
certain important conclusions stand out. The BACT option could
be easily implemented under the provisions of the 1977 CAA and
it would achieve certain equity goals. However, it is not very
flexible since locational variables are not taken into account
and it is not very efficient because there are no incentives
for using low sulfur coals. In some instances, lower or equal
S02 emission rates could be achieved by requiring a smaller
sulfur removal percentage in conjunction with the use of a lower
sulfur coal. This would also lessen the sludge disposal, water
consumption, and energy efficiency problems associated with cur-
rently available FGD processes.
While the smaller, dispersed facilities option offers some
potentially attractive features, as indicated in Table 6-26 the
pros and cons can vary greatly on a case-by-case basis. Given
the uncertainty, an attractive implementation strategy would be
for utility commissions and federal agencies to require industry
to consider this approach in its planning activities. This would
give recognition to the idea and generate better information on
its possible benefits, but it would not force an across-the-board
adoption of the alternative.
Over the long term, the commercialization program offers the
greatest possible benefits of the four specific alternatives con-
sidered. However, there are a number of major obstacles to this
approach. Economic costs for demonstration plants are high. Even
though these costs would be small relative to the value of future
energy production, the possibility of a negative decision on a
large-scale commercialization resulting from the demonstration
makes the economic risks substantial. These high initial costs
combined with the need for cooperation arid cost sharing among the
federal government, western state governments, and industry make
implementation difficult.
The siting task force alternative represents an attractive
option for policymakers. Economic costs for task force operation
are low, flexibility is high, and the alternative should be rela-
tively easy to implement. Thus, although the effectiveness is
uncertain, it does offer potential benefits with very little cost
or risk.
In conclusion, the systematic evaluation procedure followed
not only helps identify the particular strengths, weaknesses, and
uncertainties for each specific alternative but in some cases it
also suggests appropriate implementation strategies and/or modi-
fications to the policies which might correct some of the major
deficiencies. For example, with regard to the BACT alternative,
some of the negative aspects could be eliminated by an approach
which sets percentage sulfur removal requirements as a function
314
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of the sulfur content of the coal. Finally, it should be noted
that the four specific alternatives chosen for evaluation are not
mutually exclusive. These four (and others) could be implemented
simultaneously, with each making a different contribution to the
resolution of the problems and issues surrounding western energy
development and air quality.
317
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CHAPTER 7
LAND USE AND RECLAMATION
EXECUTIVE SUMMARY
Energy resource development can lead to three kinds of land-
use and reclamation problems arid issues in the West. First, energy
development will often produce or intensify conflicts between en-
ergy developers and farmers, ranchers, environmentalists, recre-
ationists and other land users. Second, £ilthough only a small per-
centage of lands will be affected region-wide, the percentage of
land affected in some locations within the region can be extensive.
Third, it is not clear that lands disturbed by energy resource de-
velopment can be successfully reclaimed in all parts of the region.
Dealing with these land-use and reclamation issues will challenge
the planning, monitoring, and enforcement capabilities of all lev-
els of government.
Impacts
Energy development will disturb lands used for mines, access
roads, support and conversion facilities, waste disposal, and
population uses for housing and recreation. Results of our anal-
ysis of land-use and reclamation impacts suggest, that:
• Direct land use by coal surface mines can be about 10
times greater than for underground mines and coal con-
version facilities (Figure 7ES-1).
• Compared on a thermal energy equivalent basis, oil
shale retorts require at least twice as much land
as any other conversion facility. About 70 percent
of the land required for an oil shale retort is for
spent shale disposal. Compared on a typical facil-
ity size basis, electric power generation requires
more land than any other conversion facility.
• Siting choices affect land requirements for coal
mining because of the heating value (British ther-
mal unit content) of the resource and its seam
thickness. For example, the number of acres dis-
turbed at Beulah, North Dakota, and at Farmington,
318
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•C
O
C CJ
10 <
'''*t
1.2 .
1.0 .
0.8 .
0.6.
0.4 .
0.2 .
4. 4
Mm.
Max.
0 --H
d. 0,
C 0
a o
3 0)
0 t-l
UJ
•a -•
3110
' Lc
ol
-H
nlo
Conversion Facilities Mines
F'igare 7ES-1: Land Use by Technology
aThe range of values is the range found in the four sites utilizing
surface coal mining and calculated based on 12 MMtpy production rates.
Ranges are attributable to variations in coal seam thicknesses and
heating value.
New Mexico, could be more than twice that disturbed at
Gillette, Wyoming, or Colstrip, Montana, for the same
size power plant (Table 7ES-1).
• Land use to meet the needs of energy-related popula-
tion growth generally produces more significant eco-
logical impacts than land used directly by the energy
facilities. Public lands (national parks, forests,
recreation, and wilderness areas), particularly those
in a natural state, are likely to experience the great-
est changes, primarily as a result of increased use
due to population growth.
319
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TABLE 7ES-1: LAND USE FOR MINES FOR SIX SPECIFIC LOCATIONS3
TYPE/SITE
Surface Coal
Navajo/Farminqton
Gillette
Colstrip
Beulah
Underground Coal
Kaiparowits
Underground Oil
Shale
Rifle
TYPICAL SIZE MINE
(acres over 30 years)
4,000 - 27,820
4,030
9,680
24,210
1,700
4,200
EQUIVALENT ENERGY
(acres per 10 Btu)
.5 - 3.2
0.5
1.2
3.0
0.2
0.5
Btu = British thermal unit
aAverage includes all surface lands disturbed, including disposal
of wastes such as spent oil shale.
• By the year 2000, large-scale land use associated with
energy development could disturb and fragment wildlife
habitat to the point of eliminating some local mammal
and bird populations.
• The long-term potential for reclaiming mined lands, de-
pends on important locatiorial features, including cli-
mate (especially annual rainfall and its seasonal dis-
tribution) , soil composition, topography of the land,
and existing biological communities. For example, the
arid climate and poor topsoil characteristics of the
Southwest region provide for an ecosystem that is more
difficult to restore than in the Northern Great Plains.
• On a region-wide basis, population increases are ex-
pected to double or triple recreation demands in the
areas of the Upper Colorado and Missouri River Basins.
These demands will stress surrounding natural resources,
especially national parks and wilderness areas.
The Policy Context
In the western states, competing values and interests with
regard to land use and energy development have already produced
conflicts. Expanded energy development will heighten existing
conflicts and also result in new problems and issues. Social and
political considerations relevant to land use and reclamation con-
flicts include:
320
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• Demands for land by energy developers come at a time
when the public interest in land use is being redefined,
both in terms of broad environmental goals and the pol-
icies and institutions which control land use. For ex-
ample, the proposition that land, like air and water, is
a basic national resource in which the public has a broad
interest is gradually being accepted and codified.
• Public awareness of the direct and indirect adverse ef-
fects of mineral extraction and utilization on environ-
mental quality is growing.
• Reclaiming disturbed lands remains a critical policy
problem even though new coal surface mine regulations
have been developed as a result of the 1977 Surface
Mining Control and Reclamation Act.
• Comprehensive reclamation objectives and requirements
have not been formulated for oil shale and uranium.
• To the extent that it exists in the West, land-use
planning is characteristically fragmented among levels
of government and among agencies within each jurisdic-
tion. Land use and administrative priorities practices
vary greatly between private lands and public lands ad-
ministered by the Bureau of Land Management, National
Forest Service, Park Service, and Bureau of Sport Fish-
eries and Wildlife.
The potential impacts of energy resource development on land-
use requirements and the nature of the existing policy system sug-
gest why land-use and reclamation issues have become so important.
More specifically, the following conflicts over land-use and recla-
mation problems could increase:
• Most of the energy resources developed in the West will
be extracted by surface mining which not only disrupts
large land areas, but also produces more visible land
impacts than underground mining. Relatively little is
known about the long-term success of land reclamation
in the West, raising questions about the adequacy of
existing policies and institutional arrangements for
returning mined lands to their preexisting or some other
productive use.
• As shown in Figure 7ES-2, energy development must com-
pete with other economically productive land uses such
as grazing and row crops; and it must compete with pres-
ervation and conservation and leisure-time and recrea-
tional uses. Large-scale energy resource development
321
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Land Use_
Economically
Productive
Preservation
"and Conservation
Leisure-Time and
.Recreation
Urban development
Row crops
-Hayland or pasture
Grazing range
• Watershed or impoundments
- Forest
-Energy and nin.era]!
Crita ca; habilat
Wilderners
Scenic
Fragile, historic or o.jltjra'
i nil) e IT.'-J
and the associated large population increase that can be
expected will intensify this competition during the next
two decades or so, taxing the capabilities of all levels
of government.
• Activities associated with mining and conversion create
an influx of people. Long valued for scenic beauty, the
recreational areas of the region would undergo signifi-
cant transformation if a high percentage of energy re-
sources were developed rapidly and large numbers of peo-
ple moved into the region, Conflicts emerge among a
variety of constituents and among government agencies as
to how this increased use should be accommodated or con-
trolled (see box "New Recreation Demands").
Alternative Policies
Two general policy objectives for dealing with land-use and
reclamation issues associated with western energy resource devel-
opment have been identified:
322
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• Insure that the institutions
and processes for making
land-use and reclamation
policies give adequate con-
sideration to a range of in-
terests ;
• Provide for and protect a
diversity of present and
future land-use patterns.
These two objectives could
incorporate a broad range of pol-
icy alternatives. Thus this pol-
icy analysis has been narrowed to
focus on an objective more spe-
cifically related to western en-
ergy resource development:
• To meet the land-use needs
of energy development, in-
cluding the land require-
ments of energy-related pop-
ulation increases, while
providing for and protect-
ing a diversity of present
and future land uses.
NEW RECREATION DEMANDS
Grand Teton National Park is
located 100 miles north of energy
boom town Rock Springs, Wyoming.
Residents combined with out-of-
state tourists resulted in 3 mil-
lion visitors to the park in 1976.
"Wyoming is feeling the effects of
energy development," says Senator
John Turner. "It's doubled the
population in some communities,
brought in a rough crowd, caused
in increase in mental health prob-
lems, divorce, alcoholism, and
crime." Due to these increases
70 percent of the respondents in
a public opinion survey of resi-
dents of Jackson Hole (in the
park) favored strong land-use con-
trols and very limited growth.
—Leydet, Francois. "Jackson
Hole: Good-Bye to the Old Days."
National Geographic, Vol. 150
(December 1976), p. 771.
As shown in Table 7ES-2, establishing a better coordinated, compre-
hensive land-use planning and management system to control land use
is one way to try to achieve this objective. Specific alternatives
include designating permissible land uses, controlling access to
public and private lands, requiring reclamation, and requiring re-
development. These alternatives are not mutually exclusive and a
comprehensive land-use planning and management system would prob-
ably include both control and rehabilitation choices.1 Each alter-
native could be designed to achieve the objective of supporting en-
ergy development while providing for and protecting a diversity of
present and future uses. The two categories of alternatives differ
primarily in emphasis.
The first category of alternatives emphasizes a comprehensive
planning approach which attempts to insure the most appropriate or
least damaging combination of technologies and locations (see Chap-
ter 12 on Energy Facility Siting). Based on an understanding of
terminology in this problem area is not standardized. As
used here, rehabilitation means that disturbed lands will be re-
stored to some productive use; reclamation means restoring to
the predevelopment use; redevelopment means restoring to some
other productive use.
323
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TABLE 7ES-2: POLICY ALTERNATIVES FOR LAND-USE AND RECLAMATION
POLICY OBJECTIVE
Meet the land-use
needs of energy
resource devel-
opment, includ-
ing those asso-
ulation in-
creases, while
providing for
and protecting
a diversity of
present and
future land
uses
CATEGORY OF
ALTERNATIVE
Control land
use and
changes in
land use
Require re-
habilitation
of all lands
disturbed by
energy re-
source de-
velopment
SPECIFIC ALTERNATIVE
Designate permissible land
uses
Control, access to and ac-
tivi:ies on all public
and private lands
Require reclamation (return
to predevelopment use)
Require redevelopment (re-
turn to some other pro-
ductive use)
present and future land needs and the coripatability of specific
land areas and land uses, permissible land uses for these land ar-
eas are identified. This means, of course, that certain land uses
may be explicitly prohibited, for example, surface mining on prime
agricultural lands. And it may be considered desirable to control
access to and activities in designated permissible use areas. For
example, the number of people allowed in a recreation area at any
one time may be limited; and snowmobiles may be permitted but not
other kinds of off-road vehicles.
The second category of alternatives emphasizes returning lands
disturbed by energy resource development to a productive use.
Within the existing land-use and management system, lands would be
made available to meet energy needs with the stipulation that they
be rehabilitated. Specific alternatives would be to require either
reclamation or redevelopment (e.g., public parks and services).
Reclamation could be implemented by continuing existing requirements
or making the system more flexible. The redevelopment alternative
would Require changes in the regulatory structure, such as requir-
ing approval of a redevelopment plan. As with the first category
of alternatives, this approach, could give the lead planning and
management role to the federal government, to the states, or to a
multistate organization.
324
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Findings
Two specific alternatives for dealing with land-use issues re-
lated to western energy research development are considered in this
report: reclamation and revegetation. Findings of our evaluation
and comparison of these two alternatives include:
• Redevelopment of surface mined land appears more likely
to succeed than does reclamation, primarily because of
the uncertainty of reclamation success in arid and semi-
arid areas. In general, redevelopment can put lands back
to productive uses three to four years earlier than rec-
lamation, is much more adjustable to site-specific con-
ditions, and allows local officials much more discretion
in interpreting local needs.
• Economic costs for reclamation and redevelopment appear
to be about the same. Reclamation is estimated to cost
about $1,000 to $7,000 per acre; redevelopment will cost
about $1,000 to $6,000 per acre.
• Environmental costs appear substantially higher for re-
development than for reclamation, since reclamation is
more aesthetically beneficial and preserves a broader
range of future land uses. However, more environmental
risks are associated with reclamation since its poten-
tial success in many areas is uncertain.
Conclusion
One obvious conclusion which can be drawn from these findings
is that several trade-offs can be made by choosing one alternative ,
over another. For example, if getting lands back into production
as soon as possible is the value which ranks highest for policy-
makers, redevelopment is the better choice; but if maximizing po-
tential environmental benefits is most highly valued, reclamation
is the more appropriate choice.
It is also clear that this analysis is incomplete. This is
largely because of the lack of adequate information but also be-
cause it was not possible in this study to evaluate all potential
policy alternatives. What is reported can be interpreted to imply
that policymakers are faced with an either-or choice, either re-
claim to predevelopment use or redevelop for a recreational use.
Obviously, the choices are not this constrained. In fact, neither
reclamation nor redevelopment emerges as the "best" choice; recla-
mation because there are areas where it will probably be impracti-
cal if not impossible and and redevelopment because there are lim-
its as to how much and where there is an additional recreational
need and because it may also require some of the same things as
reclamation, for example, revegetation. But the point that the
325
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results of this analysis leads to, despite its limitations, is that
it is not at all obvious that the current policy of most states
and the federal government is as well-informed as it might be.
Given the high level of uncertainty about being able to reclaim
arid and semiarid lands successfully, present policies seem to be
an oversimplified response to a complex problem. A blanket policy
of returning disturbed lands to their predevelopment uses largely
ignores the possibility of land-use changes in the surrounding area
due both to energy and other developments. In particular, the es-
tablished need for expanded recreational opportunities for energy-
related population increases challenges the appropriateness of a
policy which emphasizes only reclamation. Further, current policy
can require large per acre reclamation expenditures that may be
ineffective regardless of how vigorous the reclamation attempt is,
and will almost certainly require the use of scarce water resources
for activities of uncertain environmental or economic value. A
more balanced policy would provide for determining local needs and
basing the choice between reclamation and redevelopment (and the
specific redevelopment use) on what the needs are determined to be.
Clearly there is a need for more knowledge in this problem
area and a need to review land use and reclamation policies on a
continuing basis. The experience gained from current developments
will help to provide the knowledge base needed for this review as
will the numerous research efforts currently under way.
Finally, current laws and regulations ignore surface mining
for other energy resources such as oil shale and uranium. Given
the quantity of those resources in the West, this omission can-
not continue unless we are prepared to have these lands withdrawn
from productive uses for an extended time period.
326
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CHAPTER 7
LAND USE AND RECLAMATION
7.1 INTRODUCTION
Energy resource development can lead to three kinds of
serious land-use and reclamation problems and issues .in the West.
First, energy development will often produce or intensify con-
flicts between energy developers and other land users such as
farmers, ranchers, environmentalists, and recreationists; second,
although only a small percentage of lands will be affected region-
wide, the percentage of land affected in some areas within the
region can be quite large; and third, it is not clear that lands
disturbed by energy resource development can be successfully re-
claimed in all parts of the region. Dealing with these land use
and reclamation issues will challenge the planning, monitoring,
and enforcement capabilities of all levels of government.
Energy development will disturb land in a variety of ways,
including the lands used for mines, access roads, support and con-
version facilities, waste disposal, and recreation. Demand for
land for energy development comes at a time when the public inter-
est in land use is being substantially redefined, both in terms of
broad environmental goals and the policies and institutions which
control land use. Increasingly, the proposition that land, like
air and water, is a basic national resource in which the public
has a substantial interest is being accepted and codified. 1
Historically, land use was discussed almost exclusively in
terms of the interests of the developer or land user. A major
reason that this has changed is a growing public awareness of
the direct and indirect adverse effects of minerals extraction
and utilization on environmental quality.
1For elaboration of this point, see Clawson, Marion, and
Burnell Head. The Federal Lands. Baltimore, Md.: published for
Resources for the Future by Johns Hopkins University Press, 1957;
Bosselman, Fred and David Callies. The Quiet Revolution in Land
Use Control. Washington, D.C.: Government Printing Office, 1972;
and Healy, Robert G. Land Use and the States. Baltimore, Md.:
published for Resources for the Future by Johns Hopkins University
Press, 1976.
327
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Recently passed national coal strip mine legislation under-
scores the current emphasis on regulating the use of public and
private lands in the interest of both mine operators and the gen-
eral public. In fact, land use as an issue category highlights
conflicts among energy and environmental values.
In the western states, competing values and interests with
regard to land use and energy development have already produced
significant conflicts. Findings reported in our Energy From the
West impact analysis reports1 suggest that projected energy devel-
opment in the West is not only likely to exacerbate existing con-
flicts but to result in new problems and issues as well.
These problems and issues are expected to be a consequence
of several closely related technological and social considerations
discussed below. First, as noted in Chapter 2, a majority of the
minerals in the western states are owned or administered by agen-
cies of the federal government or Indian tribes. A unilateral
decision by the federal government or an Indian tribe to develop
these resources will intensify tensions already existing among
the states, Indian tribes, and the federal government.
Second, many of the energy resources developed in the West
will be extracted by surface mining techniques which not only
disrupt large land areas, but also produce much more visible land
impacts than does underground mining. Moreover, energy resources
are frequently located in forest, range, or farm areas. Develop-
ment in these areas raises questions about appropriate land uses
and the long-term potential of postmining reclamation.
Third, regardless of the mining or conversion technology
used, energy development means an influx of people. Long valued
for its scenic beauty and pristine air quality, the region would
undergo significant transformation if a high percentage of its
energy resources were developed rapidly and large numbers of
people moved into the region.
As noted in Chapter 2, westerners' attitudes toward energy
resource development are mixed. While many view it in essentially
negative terms, many others consider it desirable. To those who
hold the latter view, development means more jobs, an expanded
economic and tax base, more and better public services, and a
1See White, Irvin L., et al. Energy From the West: A Prog-
ress Report of a Technology Assessment of Western Energy Resource
Development. Washington, D.C.: U.S., Environmental Protection
Agency, 1977; and White, Irvin L., et al. Energy From the West;
Impact Analysis Report. Washington, D.C.: U.S., Environmental
Protection Agency, forthcoming.
328
-------
chance for new social and cultural experiences. This is especially
the case in areas which stand to benefit economically from growth.
In this light, land for energy development is given up or traded
for a variety of benefits. The extent to which social, economic,
and environmental costs and benefits can be equitably distributed
is an important policy consideration, especially when public lands
are involved. It is because this range of interests and values
is at stake, and competing claims to the benefits of finite land
resources have to be accommodated that land use and reclamation
is a significant category of policy problems and issues in west-
ern energy resource development.
In the following section, these land-use problems and issues
are discussed beginning with a summary of land-use and reclamation
impacts. The social and political context within which these im-
pacts will occur is then described, and the problems and issues
likely to arise when these impacts occur within this context are
identified and defined. Alternative policies and implementation
strategies for dealing with these problems and issues are then
identified, evaluated, and compared.
7.2 LAND-USE AND RECLAMATION PROBLEMS AND ISSUES
7.2.1 The Land-Use Impacts of Energy Resource Development
As described in our Energy From the West progress report, the
extent and type of land-use impacts can vary depending on the
choice of energy technology and location.1 Technological factors
which can significantly affect impacts include the method of min-
eral extraction, the type of conversion facility, and the labor
requirements of the technology. Critical locational factors in-
clude overburden characteristics, coal seam thickness, heat con-
tent of the resource, climatic and soil characteristics, the nature
of the terrain, and existing biological communities in an area.
A. Variations in Land Use by Technology
Variations in land use by technology are shown in Table 7-1
for the size facilities deployed in our scenarios and on an equiv-
alent energy basis. Compared on an equivalent energy basis, land
requirements for conversion facilities do not differ significantly,
and land requirements for an underground coal mine are similar to
that for conversion facilities. However, land disturbed by surface
White, Irvin L., et al. Energy From the West: A Prog-
ress Report of a Technology Assessment of Western Energy Resource
Development. Washington, D.C.: U.S., Environmental Protection
Agency, 1977; and White, Irvin L., et al. Energy From 'the West:
Impact Analysis Report. Washington, D.C.: U.S., Environmental
Protection Agency, forthcoming.
329
-------
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coal mine can be ten times greater than for conversion facilities
or underground mining depending on the seam thickness and the heat-
ing value of the coal (see the discussion below of locational char-
acteristics) .
Depending on the level of development, between 1,000 and 1,500
square miles of land could be disturbed in the eight-state study
area by the year 2000 by coal mining alone. As shown in Table 7-2,
the magnitude of this surface land disturbance is projected to be
larger for the Northern Great Plains than for any other area. At
some locations up to 18 percent of entire counties could be dis-
rupted. Although impacts assessed for the eight states indicate
that coal mining will disturb the largest amount of land region-
ally, uranium, oil shale, oil and gas, and geothermal development
will also produce local land disruption.
Direct land use produces a range of impacts. The magnitude
of land disruption can be visually shocking. Protective vegeta-
tion is destroyed and soil and rock overlying the coal (or other
mineral deposit) are scraped away, resulting in a massive, visible
alteration of the surface. Such activities can also lead to water
pollution problems, disrupt normal surface and groundwater flows,1
cause soil erosion and related
ecological impacts, and, ulti-
mately, restrict future land
uses.
Ecological impacts may show
up in reductions in the overall
carrying capacity of an area
(see box). Generally, ecologi-
cal impacts will be local, al-
though if many facilities are
sited in an area, direct land
use can eliminate or reduce a
large percentage of habitat
types and result in significant
areawide reductions in carrying
capacity. Also, impacts from
erosion and water pollutants, as
well as air pollutants, from
both mines and power plants can
cause widespread ecological
effects.
ECOLOGICAL IMPACTS IN
RIFLE, COLORADO
Development of one oil shale re-
torting facility in the vicinity of
Rifle, Colorado disturbs less than
one percent of the land area in Gar-
field and Rio Blanco Counties. How-
ever, ecological impacts can increase
rapidly with expanded development;
for example, carrying capacity of
deer can decrease dramatically as an
area is developed.
—White, Irvin L., et al. Energy
From the West: A Progress Report of
a Technology Assessment of Western
Energy Resource Development. Wash-
ington, D.C.: U.S., Environmental
Protection Agency, 1977, p. 91.
1 For elaboration, see Chapters 4 and 5 on water availability
and quality.
331
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TABLE 7-2: ACREAGE DISTURBED BY COAL SURFACE MINING
AREA
Northern Great Plains
North Dakota Lignite
Powder River
Intermountain Area
Four Corners Areae
LOW DEMAND CASE
(thousands of acres!
447
396
39
69
Source: White, Irvin L., et al. Energy From the
West; A Progress Report of a Technology Assess-
ment of Western Energy Resource Development.
Washington, D.C.: U.S., Environmental Protection
Agency, 1977, p. 877.
aBased on energy demand for coal projected by Low
Demand level of development (124 quadrillion British
thermal units supply) by the year 2000.
Includes Billings, Bowman, Dunn, Hettinger,
McKenzie, McLean, Mercer, Oliver, Slope, Stark,
and .Williams Counties, North Dakota. Assumed
average seam thickness of 12.5 feet.
clncludes Powder River, Bighorn, and Rosebud
Counties, Montana, assumed average seam thick-
ness 27 feet; and Campbell, Johnson, and Sheridan
Counties, Wyoming. Assumed average seam thick-
ness is 64 feet.
Includes Rio Blanco, Garfield, and Huerfano
Counties, Colorado, assuming one-third of the
projected mines are underground, and an average
seam thickness of seven feet.
elncludes San Juan County, New Mexico, with an
assumed average seam thickness of 10.3 feet; and
Kane and Garfield Counties, Utah, assuming half
the projected mines are underground, and an
average seam thickness of 10 feet.
332
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SINKING HOMES IN ROCK SPRINGS
Subsidence has recently become
a serious problem in Rock Springs,
Wyoming. The town sits on a network
of mine tunnels created over the
last 100 years or so. Just within
the last several years, it has be-
come necessary to condemn and de-
stroy several houses which sank
into the ground as much as four
feet.
—Strabala, Bill. "Age Transforms
Subsurface Mines' Beauty Into
Beast." Denver Post, March 13, 1977,
p. 20.
Underground coal, oil
shale, and uranium mining poses
surface problems in preventing
and controlling land subsidence
(see box). Changes range from
surface impacts (uneven ground
and/or cracks) to drastic alter-
ations (gaping holes). Like
strip mining, underground mining
also can: lead to water pollu-
tion problems, intercept ground-
water aquifers, require mine de-
watering, deplete aquifers and,
ultimately, change land uses.
Other land-use problems
concern waste disposal (e.g., _
coal ash and toxic mine wastes),
such as the stabilization of
evaporative holding ponds for energy conversion facilities, mine
settling ponds, and tailing ponds for uranium mills. These ponds
continue to require maintenance, especially after sites and facil-
ities are abandoned.1 In the past, erosion has contributed to
atmospheric and water pollution, and uranium tailings have con-
tributed to public exposure to radiation.
Finally, a network of unpaved service and maintenance roads
contributes to area-wide water and air pollution and fragments
wildlife habitats. Wells in oil and gas fields are linked by a
web of eroding roads that reduce aesthetic and biological values.
Procedures to stabilize these various kinds of roads may not be
adequate and new roads may have to be added when washouts occur.2
B. Energy-Related Population Increases
Variations in the labor intensity of technologies can be an-
other important land-use factor. That is, some technologies re-
quire a larger work force to produce the same quantity of energy
than do others. This is significant for land use primarily in
terms of the overall population increases resulting from different
White, Irvin L., et al. Energy From the West: A Prog-
ress Report of a Technology Assessment of Western Energy Resource
Development. Washington, D.C.: U.S., Environmental Protection
Agency, 1977, pp. 55-57; and White, Irvin L., et al. Energy From
the West; Impact Analysis Report. Washington, D.C.: U.S. Envi-
ronmental Protection Agency, forthcoming.
2U.S. Geological Survey, staff.
Reston, Va., 1977.
Personal communication,
333
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levels of energy development.1 As illustrated in Table 7-3,
operation-related or permanent population increases alone for the
Low Demand Case (124 quadrillion British thermal units (Btu) sup-
ply) would result in 157,200 new people coming to the region by"
1990 and 456,600 by 2000.2 Most of these regional population in-
creases are projected to occur in rural locations. In some in-
stances these increases will occur in areas used extensively for
recreation in both summer and winter, such as in the mountains of
Colorado and Wyoming. Population increases are also projected
for areas where much of the land is used for grazing or agricul-
tural crops, such as in the Northern Great Plains.
TABLE 7-3:
PERMANENT POPULATION INCREASES AFTER 1975 DUE TO
ENERGY DEVELOPMENT IN EIGHT-STATE REGION
YEAR
1980
1985
1990
2000
LOW DEMAND CASE&
45,000
118,200
157,200
456,600
Source: The 1975 estimated population for the eight states
was 9,551,000. See U.S., Department of Commerce, Bureau of
Census. "Estimates of the Population of States, By Age:
July 1, 1974 and 1975 Advanced Reports." Current Population
Reports, Series P-25, No. 619, January 1976.
aBased on energy demand for coal projected by Low Demand
level. of development (124 quadrillion British thermal units
supply). See White, Irvin L. , et al . Energy From the West:
A Progress Report of a Technology Assessment of Western En-
ergy Resource Development. Washington, D.C.: U.S., Environ
mental Protection Agency, 1977, Chapter 12.
a more detailed breakdown of populations and levels of
development, see White, Irvin L. , et al . Energy From the West:
A Progress Report of a Technology Assessment of Western Energy Re-
source Development. Washington, D.-C. : U.S., Environmental Pro-
tection Agency, 1977, Chapter 12; and White, Irvin L. , et al .
Energy From the West; Impact Analysis Report. Washington, D.C.:
U.S., Environmental Protection Agency, forthcoming, Chapter 11.
2The large increase during the 1990 "s would primarily be due
to the large-scale development in Colorado and extensive coal pro-
duction in the Northern Great Plains. For a discussion of the Low
Demand Case energy forecast, see White et al . Energy From the
West; Progress Report; and White et al . Energy From the West :
Impact Analysis ReporT, Chapter 11.
334
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Ecological stresses brought on by energy development are
closely related to the size of human populations in the study area.
Anticipated population growth will occur disproportionately near
areas with high value for backcountry recreation. Estimates made
for the Missouri River Basin Comprehensive Framework Study1
indicate that it is reasonable to expect recreation demand to
double or triple by the year 2000. Since the early 1970's, back-
country recreational activities such as hiking, snowmobiling,2
jeeping, and backpacking or packing with horses have been rising
in popularity, accounting for 5-15 percent of the total use in
areas such as national forests. These activities are particularly
popular in the West.
Although the intensity of use is uncertain, the locations of
recreation activities generally fall into three categories: major
established tourist attractions (e.g., Yellowstone and Grand Teton
National Parks); areas near population centers (e.g., Grand Mesa
National Forest, near Grand Junction); isolated areas or areas
with limited recreation opportunities (e.g., Black Hills National
Forest in Wyoming and South Dakota). Figure 7-1 shows some major
areas likely to be used more intensively because of region-wide
energy development. If access to these areas is limited or con-
trolled, the bulk of the growing demand will fall on adjacent
nondesignated areas which have a strong aesthetic appeal.3
Missouri Basin Inter-Agency Committee. The Missouri River Ba-
sin Comprehensive Framework Study. Denver, Colo.: U.S., Department
of the Interior, Bureau of Land Management, 1971, Vol. 1, p. 137.
2In Hayden, Colorado (pop. 10,000), which is located in the
middle of the Yampa coal field, snowmobiling is the most popular
form of recreation. At least one, and often two snowmobiles can
be found in every yard: "At one residence, there were four, lined
up like bicycles." Gits, Victoria. "Boom Town on the Brink."
Colorado/Business, Vol. 5 (February 1978), p. 32.
3An important limitation in projecting recreational demands
is the difficulty of anticipating trends in recreational styles.
For example, such technological innovations as snowmobiling are
recent phenomena. Hydrofoil and shallow draft boats make many
western rivers available for recreational use. Similarly, uncer-
tainty exists in land management practices. Current trends are
to increase restrictions on wilderness and backcountry areas, but
economics encourages the Forest Service to promote dispersed rec-
reation activities by building trails and improving access. See
White, Irvin L., et al. Energy From the West; A Progress Report
of a Technology Assessment of Western Energy Resource Development.
Washington, D.C.: U.S., Environmental Protection Agency, 1977,
p. 872; and White, Irvin L., et al. Energy From the West; Impact
Analysis Report. Washington, D.C.: U.S.,Environmental Protection
Agency, forthcoming.
335
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if NATIONAL MONUMENT
O RECREATION AREA
POINT OF INTEREST
FIGURE 7-1: MAJOR BACK-COUNTRY AREAS LIKELY TO RECEIVE
INCREASED PRESSURE DUE TO ENERGY DEVELOPMENT
336
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FIGURE 7-1:
MAJOR BACK-COUNTRY AREAS LIKELY TO RECEIVE INCREASED
PRESSURE DUE TO ENERGY DEVELOPMENT3 (Continued)
1. Cabinet Mountains WA 39.
2. Glacier NP 40.
3. Theodore Roosevelt NP 41.
4. Yellowstone NP 42.
5. Bighorn Canyon RA 43.
6. N. Absaroka WA 44.
7. Bighorn NF 45.
8. Cloud Peak PA 46.
9. Washakie WA 47.
10. Shoshone NF 48.
11. Grand Teton NP 49.
12. Teton WA 50.
13. Bridger WA 51.
14. Popo Agie PA 52.
15. Medicine Bow NF 53.
16. Flaming Gorge RA 54.
17a. Wind Cave NP 55.
17b. Badlands NM 56.
18. High Unitas PA 57.
19. Ashley NF 58.
20. Fishlake NF 59.
21. Capitol Reef NP 60.
22. Dixie NF 61.
23. Zion NP 62.
24. Cedar Breaks NM 63.
25. Bryce Canyon RA 64.
26. Glen Canyon RA 65.
27. Canyonlands NP 66.
28. Arches NP 67.
29. Hovenweep NM 68.
30. Dinosaur NM 69.
31. Mt. Zirkel WA 70.
32. Routt NF 71.
33. Rawah WA 72.
34. White River NF 73.
35. Eagles Nest WA 74.
36. Grand Mesa NF 75.
37. Maroon Bells/Snowmass WA
38. Black Canyon of the
Gunnison WA
La Garita WA
Upper Rio Grande PA
San Juan WA
San Juan NF
Mesa Verde NP
Rio Grande NF
Carson NF
Chaco Canyon NM
San Pedro Parks WA
Santa Fe NF
Wheeler Peak WA
Gila WA
Gila PA
Gila NF
Black Range PA
Canyon de Chelly NM
Kaibab NF
Grand Canyon NP
Wupatki NM
Coconino NF
Sunset Crater NM
Sitgreaves NF
Petrified Forest NP
Apache NF
Blue Range PA
Mr. Baldy WA
Prescott NF
Pine Mountain WA
Mazatzal WA
Tonto NF
Superstition WA
Sierra Ancha WA
Saquaro NM
Galiuro WA
Chiricahua NM
Chiricahua WA
Four Corners Area
WA = wilderness area
NP = national park
RA = recreation area
NF = national forest
PA - primitive area
NM = national monument
337
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Other impacts resulting from population increases are similar
to those caused by facilities. Increased housing, roads, and ser-
vice activities fragment wildlife habitats into small parcels that
are less usable either by resident or migratory species, and can
cause some species to desert an area. Easier access to recre-
ational areas can lead to increasing erosion, vegetation damage,
damage to fish, birds, and other wildlife, and diminished enjoy-
ment of resources. Based on patterns identified in our Energy
From the West impact analysis reports, this is likely to occur in
four areas: western Colorado and eastern Utah, the coal regions
in Wyoming, the Four Corners area,1 and the coal fields of Montana
and North Dakota. In western Colorado, the large population in-
flux is expected to locate near
prime outdoor recreation areas
(including national forests,
parks, monuments, and wilder-
GOOD-BYE TO THE OLD DAYS
/ . . , . > 2 /-•, Grand Teton National Park is lo-
ness/primitive areas) . Conse- . , inr. . n , ,. ,
' i . -I j_ • • cated 100 miles north of energy boom-
quently, growing populations in 010- TT • ™L
this area will cause the most town Rock Springs, Wyoming Three
conflict with "national heri- mlllon residents and out-of-state
tourists visited the park in 1976.
North Dakota areas will also ex-
tage" lands. The Wyoming and „., ....... , ,,.
Wyoming is feeling the effects of
perience substantial population development says State Sen-
increases; however, in these at or John Turner. "It's doubled the
places, outdoor recreationists Population in some communities,
will be limited in their choice
of recreation areas. The three
closest such areas, Theodore divorce, alcoholism and crime. Due
Roosevelt National Memorial to thef increases 70 percent of the
Park, Black Hills National For- respondents in a public opinion sur-
est and Bighorn National Forest, !f °f ""dents of Jackson Hole (in
, ., , , . , the park; favored strong land-use
are likely to receive greater .. -, * ->••-,
„ . ., , controls and very limited growth.
use. Some evidence suggests * 5
that prime recreation areas are —Leydet, Francois. "Jackson Hole:
already becoming used inten- Good-Bye to the Old Days." National
sively as a result of recent Geographic, Vol. 150 (December 1976),
energy development (see box).
brought in a rough crowd, caused an
increase in mental health problems,
p. 771.
:The energy-related population growth in Utah and New Mexico
may affect such areas as San Juan National Forest (in Colorado),
Chaco Canyon National Monument (New Mexico), and the Dixie Na-
tional Forest and Glen Canyon National Recreation Area (Utah).
2For example, Rio Grande National Forest, San Juan National
Forest, Rio Grande National Wilderness Area, Upper Rio Grande
Primitive Area, Gore Range/Eagles Nest Wilderness Area, and
Mesa Verde National Park.
338
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C. Variations in Land-Use Impacts by Location
Land impacts may also vary according to several locational
factors. For example, in the case of coal, the amount of land
disturbed for each unit of energy extracted is highly dependent
on the Btu content of the coal and its seam thickness. Table
7-4 shows that land requirements for mines at different sites
vary considerably. Mining coal with a high Btu content and a
thick coal seam disturbs less land than will mining low-Btu coal
with a thin coal seam.
Climate, soil, topography, and existing biological communi-
ties at a site are also important locational features that affect
the extent and type of land impacts. These factors are signifi-
cant particularly because they affect the cost and potential suc-
cess of reclamation.
Rainfall, including its seasonal distribution, is one of the
most important climatic variables affecting the reclamation of
TABLE 7-4: LAND USE FOR MINES FOR SIX SPECIFIC LOCATIONS'
TYPE
Surface Coal
Surface Coal
Surface Coal
Surface Coal
Underground
Coal
Underground
Oil Shale
SITEb
Nava jo/Farming ton
Gillette
Colstrip
Beulah
Kaiparowits
Rifle
TYPICAL SIZE MINE0
(acres over 30 years)
4,000 - 27,820
4,030
9,680
24,210
1,700
' 4,200
EQUIVALENT ENERGY
(acres per 10 12 Btu)
.5 - 3.2
0.5
1.2
3
0.2
0.5
Btu = British thermal units
Average includes all surface lands disturbed, including disposal of wastes
such as spent oil shale.
Seam thickness and heating values assumed: Navajo/Farmington - 10.3 feet
between 1 and 7 multiple seams, 8,600 Btu per pound; Gillette - 64 feet,
8,000 Btu per pound; Colstrip - 28 feet, 8,600 Btu per pound; Beulah - 13
feet, 6,950 Btu per pound.
cln all cases the mine size assumed supports a 3,000 megawatts-electric
power plant.
339
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mined lands. Average rainfall and seasonal distribution data for
three areas in the region are given in Table 7-5. The Southwest
receives the least amount of rainfall overall; the Rocky Mountain
region and Northern Great Plains have similar total rainfall, but
during the summer growing season, rainfall in the Northern Great
Plains is twice that of the Rocky Mountains. A comparison of
Tables 7-4 and 7f-5 suggests an important land-use problem. For
a mine supplying a 3,000 megawatts-electric power conversion
facility, the amount of land requiring reclamation is generally
largest in the Southwest which also happens to be the area with
the least average annual rainfall.
TABLE 7-5: PRECIPITATION AVERAGES IN THE WEST
REGION
Northern Great Plains
Rocky Mountains
Southwest
PRECIPITATION
(inches)
WINTER SUMMER
<5 10-20
5-10 5-10
<5 <5
a
ANNUAL
10-20
10-20
<10
< = less than
Espenshade, Edward B., ed. Goode's World Atlas, 13th
ed. Chicago, 111.: Rand McNally, 1971. Winter corres-
ponds to November I/April 30; summer corresponds to
May I/October 31.
The semiarid climate and good topsoil of the Northern Great
Plains provide for an ecosystem that can be restored with less
difficulty than in the Southwest. Forest areas of the Rocky Moun-
tains are more difficult to restore due to difficult topography
and the long time required to establish a mature forest. In
deserts, infrequent rainfall and overgrazing by livestock limit
the success of reclamation efforts. For example, reclamation
success in the arid Black Mesa area that does not have a source
of irrigation is almost nonexistent.1 But through irrigation, the
Navajo and San Juan mines near Farmington in northwest New Mexico
have established vegetation in some areas with greater cover
Gordon, Suzanne. Black Mesa; The Angel of Death. New York,
N.Y.: John Day, 1973, p. 68; Goodman, Jim. The Navajo Nation and
Energy Development: A Study of the Cultural, Social, and Political
Environments, Draft, Sub-Contract Report to Science and Public
Policy Program. Norman, Okla.: University of Oklahoma, Science
and Public Policy Program, September 1977.
340
-------
than exists in adjadent unmined areas.1 Still unanswered, however,
is whether reclaimed areas will remain productive. In part, this
is because problems are unresolved concerning the effects of phas-
ing out water supplements on arid sites. Even in semiarid places,
such as the coal mining areas of Decker, Montana and Carbon County,
Wyoming, withdrawing irrigation and fertilizer supplements may be
difficult because of unfavorable spoil and soil properties. The
Bureau of Land Management (BLM), Bureau of Reclamation, and U.S.,
Geological Survey (USGS) recommend that supplemental irrigation
should not be used in the revegetation plan for land in the Hanna
Basin of Wyoming unless all other methods for establishing vegeta-
tion fail. This recommendation was based principally on an as-
sessment of the shock to established stands of vegetation cover
once irrigation and fertilizer were removed after a period of in-
tensive use (e.g., three years).3 Reclamation research at Forest
Service experiment stations and in agriculturally-oriented univer-
sity research centers is being conducted with regard to the poten-
tial of returning mined lands to productive uses.1*
In sum, using present reclamation techniques, areas with 6-10
inches of rainfall per year can generally support plant regrowth
without supplemental irrigation. Annual precipitation levels on
1 Annual precipitation rates at the Navajo mine of approxi-
mately six inches have called for the use of supplemental water for
at least 1.5 years. U.S., Environmental Protection Agency, Office
of Energy Activities, Region VIII, et al. Surface Coal Mining in
the Northern Great Plains of the Western United States; An Intro-
duction and Inventory Utilizing Aerial Photography Collected in
1974 and 1975. Denver, Colo.: U.S., Environmental Protection
Agency, 1976.
2See Farmer, E.E., et al. Revegetation Research on the
Decker Coal Mine in Southeastern Montana, Research Paper INT-162.
Ogden, Utah: U.S., Department of Agriculture, Forest Service,
Intermountain Forest and Range Experiment Station, 1974, p. 10.
3U.S., Department of the Interior, Bureau of Land Management.
Resource and Potential of Reclamation Evaluation: Hanna Basin
Study Site, EMRIA Report No. 2. Rawlins, Wyo.: Bureau of Land
Management, 1975, p. 172.
^Davis, Grant, Associate Program Manager for Research, Sur-
face Environment and Mining Program (SEAM), Forest Service, U.S.,
Department of Agriculture. Personal communication, 1977; McKell,
Cy, Utah State University. Personal communication, 1977; and
Grogan, Sterling, Utah International. Personal communication,
1977. All appear to be optimistic.
5National Academy of Sciences. Rehabilitation Potential of
Western Coal Lands, a report to the Energy Policy Project of the
Ford Foundation. Cambridge, Mass.: Ballinger, 1974, p. 2.
341
-------
strippable land in northeastern New Mexico, southwestern Wyoming,
and south-central Utah often fall below 10 inches. However, based
on the results of several years of investigating revegetating min-
ing spoils, the U.S. Forest Service has found that when "mined and
graded with care, and planted properly to suitable species, areas
receiving as little as 6 inches average annual precipitation have
been revegetated." However, the key words here are "with care,"
"properly," and "suitable species."1 Interpretation of each of
these requires consideration of site-specific characteristics.
The timing of the precipitation appears to be much more crit-
ical than the average annual precipitation.2 If most of the mois-
ture occurs during the winter and practically none occurs during
the growing season, reclamation practices may be further con-
strained by the need for and cost of irrigation, by wind erosion,
and by other factors.3 In addition, periodic dry periods lasting
up to several years curtail successful revegetation unless irriga-
tion can be provided. "*
1 Davis, Grant, Associate Program Manager for Research, Surface
Environment and Mining Program (SEAM), Forest Service, U.S. Depart-
ment of Agriculture. Personal communication, 1976.
2This is stated in the National Academy of Sciences (NAS)
study referred to earlier and is noted in Grant Davis's personal
communication. In his comments on the NAS report, Robert R. Curry,
Associate Professor of Environmental Geology from the University
of Montana, stated: "Both soil formation and plant growth rely
upon soil moisture, not rainfall, and in the arid west rainfall
bears relatively little relationship to soil moisture. In addi-
tion to summer rainfall, concomitant summer evaporation which re-
duces soil moisture must be considered." Reviewer comments in
National Academy of Sciences. Rehabilitation Potential of West-
ern Coal Lands, a report to the Energy Policy Project of the
Ford Foundation. Cambridge, Mass.: Ballinger, 1974, p. 168.
3The Forest Service has been working with supplementary irri-
gation and finds that such equipment should be available for use
as insurance against long dry periods regardless of average annual
precipitation in the West. Davis, Grant, Associate Program Manager
for Research, SEAM, Forest Service, U.S.. Department of Agriculture.
Personal communication, 1976.
4NAS. Rehabilitation Potential of Western Coal Lands;
Packer, Paul E. Rehabilitation Potentials and Limitations of
Surface-Mined Land in the Northern Great Plains, General Technical
Report INT-14. Ogden, Utah: U.S., Department of Agriculture,
Forest Service, Intermountain Forest and Range Experiment Station,
1974.
342
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7.2.2 The Context of Land-Use and Reclamation Issues in the West
Although the problems and issues addressed here are likely
to become more intense as western energy development proceeds,
they are by no means entirely new. In several instances, they
have been before the public for most of this century: for ex-
ample, the problems and issues related to developing appropriate
mining laws, or in making public lands available for other pri-
vate or public uses. In other instances, policy debates asso-
ciated with land use are relatively new, such as recent federal
regulations for developing and implementing state reclamation
programs.
Existing laws and regulations, institutions, and values and
interests of involved participants make up the context within which
energy-related land issues are evolving. This context affects how
conflicts are being dealt with and how new problems and issues will
be handled. Consequently, the discussion below summarizes key ele-
ments in the historical development of land-use policies and is-
sues. It is organized around three general themes: the role of
government in planning and controlling land use; the objectives
and requirements of postmining reclamation; and accommodating and
controlling recreational and agricultural uses of public lands.
A. Planning and Managing Land Use
Conflicts in planning and managing land use in development
areas have surfaced not only on the basis of findings in this tech-
nology assessment, but also on the basis of analyses conducted by
other policy research groups. For example, the Task Force Report
sponsored by the Rockefeller Brothers Fund found that a central
problem confronting both the entire U.S. and the West specifically,
was the unrestricted patchwork of urbanization and development
that sprawls across scenic hills, valleys, forests, and farms.1
Indeed, managing growth and planning land use have already become
major political issues in some western states, and account in part
for differences in public attitudes about potential energy devel-
opment in western states; between Colorado and Utah, for example.2
Furthermore, federal legislation to manage both state and federal
lands has been before Congress during three of the past four
legislative sessions.
JSee Reilly, William K., ed. The Use of Land; A Citizens'
Policy Guide to Urban Growth. New York, N.Y.: Thomas Y. Crowell,
1973.
2Gill, Douglas. "Utah Seeks Federal Okay to Set Own Pollu-
tion Level." Denver Post, December 19, 1976.
343
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(1) Multiple Interests in Land-Use Planning
Land-use policy has undergone.substantial change in the U.S.,
ranging from a trial and error approach during early colonization
and development, through periods when management and stewardship
were more important considerations, to recent periods where zoning
and planning have been emphasized. In each of these periods,
policymakers have responded to conflicts between divergent inter-
ests such as the needs of homesteaders, mining companies, conser-
vationists, and those interested in preservation of naturally
scenic or historically significant areas.1
Industry interests, including energy and mining companies,
have played a major role in affecting land-use policies. In the
eight western states, firms such as Kennecott Copper, Utah Inter-
national, Anaconda, and others have attempted to maintain unre-
stricted access to minerals on both public and private lands.
These companies typically work closely with western congressmen
to maintain or expand their interests.2 In general, mining indus-
tries have played a major role in either defeating or limiting
attempts at restrictive land-use planning, and have promoted
legislation which permit free access to federal lands.3
During the 19th century when environmental impacts on land
were for the most part ignored, the only government policy for
mineral lands was one of "noninterference." The Mining Act of
1866 ** legitimized this policy by declaring the public domain5 to
be "free and open" to exploration for minerals and mining. The
General Mining Law of 18726 clarified some procedural ambiguities
in the 1866 Act. It allowed a claim to be filed and a patent
granted for the use of feder£il lands irrespective of any consider-
ation of specific land use. Since stringent controls were not
Stairs, Gerald R. "Land-Use Planning: An Overview," in
Thames, John L., ed. Reclamation and Use of Disturbed Land in the
Southwest. Tucson, Ariz.: University of Arizona Press, 1977, p. 3,
2Peirce, Neal R. The Mountain States of America. New York,
N.Y.: Norton, 1972, p. 205.
3Jones, Douglas N., et al. The Energy Industry; Organiza-
tion and Public Policy. Washington, D.C.: Government Printing
Office, 1974.
^Mining Act of 1866, 14 Stat. 251.
5The public domain is lands, either acquired by the federal
government during the expansion of the West or purchased from
private owners.
6General Mining Law of 1872, 17 Stat. 91.
344
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placed on the use of public lands, mining industries enjoyed a
period of rapid growth. Once minimum and perfunctory criteria
were met, public lands passed into private ownership.
By the late 1890's and early 1900's, it was recognized that
the government's resource disposal policies were being abused.1
Reservation and withdrawals of public lands followed, beginning
the modern era of viewing these lands as a resource to be managed
and conserved. Congress also allowed nonmineral entries (such
as farming) on public lands, first on coal lands,2 then on lands
bearing all types of minerals.3 Between 1914 and 1920 Congress
was under increasing pressure to open public "withdrawn" lands
to mineral development. This six-year period of debate and rec-
ognition of the inequities of limited management made the need
for a comprehensive leasing system clear, leading to the passage
of the Mineral Leasing Act of 1920. ** This act established a sys-
tem for leasing "soft minerals" such as coal, oil, and gas on
public lands. A primary impetus behind this Act was the wish to
encourage competition and receive some compensation for the use
of federal coal lands.
Numerous congressional acts and executive policies have re-
stricted the availability of federal lands for minerals explor-
ation and development. The Department of the Interior (DOI) es-
timates that on about 40 percent of federal lands, energy devel-
opment activities have been prohibited.5 In addition, another
20 percent are restricted so that energy resource exploration
and development appears unlikely. Since 1968 the total for fed-
eral lands on which formal restrictions or prohibitions pertain
has increased from 20 percent to more than 50 percent of all fed-
eral lands.6 This increase is due primarily to the establishment
of wilderness areas and temporary land withdrawals in Alaska.
:Beard, Daniel P. "Public Policy Milestones in the Develop-
ment of the Oil Industry," in Jones, Douglas N., et al. The Energy
Industry: Organization and Public Policy. Washington, D.C.:
Government Printing Office, 1974.
235 Stat. 844 (1909), 36 Stat. 583 (1910), 37 Stat. 105 (1912).
338 Stat. 509 (1914).
"Mineral Leasing Act of 1920, 41 Stat. 437. Lands subject
to the Mineral Leasing Act for Acquired Lands of 1947, 61 Stat.
913, 30 U.S.C.A. 351-59 are also covered by the 1920 Act.
5U.S., Department of the Interior. Mining and Minerals Policy,
1976 Annual Report of the Secretary of the Interior. Washington,
D.C.: Government Printing Office, 1976, p. 27.
6 Ibid.
345
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In sum, there is currently less land available for the exploration
and development of domestic energy resources than has historically
been the case.
These restrictions raise a number of policy problems and
issues. In making decisions regarding development, policymakers
must weigh the advantages of energy production against disadvan-
tages to the public. However, such determinations are difficult
and most estimates are uncertain. Congress attempted to deal with
this problem by calling on the BLM and USGS to evaluate the min-
eral values in wilderness areas. These resource appraisals are
to assist policymakers in choosing among different land uses.
Recent initiatives for land-use legislation have come from
both the executive branch and from Congress. Members of Congress
from western states have been heavily involved in these actions.
For example, former Colorado
Representative Wayne Aspinall
was active as chairman of the
Public Land Law Review Commis-
sion, and author of the Na-
tional Land Policy, Planning
and Management Act (HR 7211)
proposed in 1972. Although no
action was taken on the bill,
the bill reflected recognition
of the need to coordinate ef-
forts between federal agencies,
other landowners, state and
local governments, and private
individuals.1
A number of public inter-
est groups support comprehen-
sive land-use legislation, in-
cluding the National Wildlife
Federation, National Audubon
Society, and Sierra Club (see
box). However, these groups,
the Isaac Walton League and
Friends of the Earth, have
opposed some of the land-use
bills that have been introduced
recently because they believe
that the proposed planning,
funding, and review procedures
IMPLEMENTING ENVIRONMENTAL
OBJECTIVES
Groups like the Sierra Club im-
plement their objectives through the
courts, by lobbying and through tech-
nical review. The Sierra Club Legal
Defense Fund has been instrumental
in delaying development for several
years of Northern Great Plains Coal
in Sierra Club v. Morton.. This case
called for the Department of the In-
terior to file an environmental im-
pact statement (EIS) for the re-
gional development of coal. Follow-
ing several years of litigation, the
Supreme Court ruled in 1976 that an
EIS was not required. The Department
of the Interior, however, is proceed-
ing on regional EIS's at this time.
—lierra Club v. Morton, 507 F. 2nd
533 (District Court D.C. 1975),
affirmed, 514 F. 2nd 856 (D.C. Cir.
1975).
Congressional Quarterly, Inc. Congress and the Nation,
Vol. Ill: 1969-1972. Washington, D.C.: Congressional Quarterly,
1973, 809-10.
346
-------
were oriented to commercial
exploitation of public lands
rather than to their preserva-
tion and conservation. In ad-
dition, many environmental orga-
nizations criticized the 1970
report of the Public Land Law
Review Commission as support-
ing land-use concepts that
would sacrifice soil, water,
wildlife, and aesthetic values
to mining, grazing, and logging
interests1 (see box).
Although land-use planning
on federal lands is obviously
a dominant issue in western en-
ergy development, states and
localities have traditionally
been the locus of land-use
control. Historically, wide
ranging authority has been
delegated by states to commu-
nities. Since energy develop-
ment will stress the capabil-
ities of existing institutional
arrangements at these levels as well as at the federal level, sev-
eral additional issues are outlined below.
Local governments typically have discretionary authority
that goes beyond mere zoning tools. They also may legislate
against public nuisances, adopt subdivision regulations and build-
ing codes, institute solid waste management plans and regulations,
require open space areas for parks and recreational facilities,
apply floodplain regulations and environmental controls, estab-
lish housing commissions or development authorities, and create
special purpose districts to attempt to deal more effectively
with development.2 Yet, local efforts are seldom adequate to cope
with regional (and ultimately statewide or national) impacts or
THE GOSPEL HUMP WILDERNESS
Although the federal bureaucracy
is often called upon to mediate con-
flicts between diverse interests, a
Sierra Club spokesman reported an op-
posite effect following meetings with
the timber industry. The limitations
of government were discovered during
negotiations over the boundaries of
the Gospel Hump wilderness in the
Northwest. Negotiations only proved
to be successful after the industry
and environmental participants agreed
to exclude representatives of the
Forest Service and a state fish and
game agency.
—Carter, Luther J. "Coal: Invoking
the Rule of Reason in an Energy-
Environment Conflict." Science, Vol.
198 (October 21, 1977), p. 279.
Congressional Quarterly, Inc. Congress and the Nation,
Vol. Ill; 1969-1972. Washington, D.C.: Congressional Quarterly,
1973, pp. 809-10.
2Council of State Governments, Task Force on Natural Re-
sources and Land Use Information and Technology. Land; State
Alternatives for Planning and Management. Lexington, Ky.:
Council of State Governments, 1975, pp. 4-6.
347
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planning needs. This is compounded by the fact that much of the
land in rural energy development areas is unincorporated.1
Many western states have established additional planning re-
quirements. For example, Wyoming and North Dakota now require
local governments to appoint planning commissions and engage in
comprehensive planning. Colorado and Wyoming have state land-use
commissions. Colorado has a permit system that requires a facil-
ity to be approved in accordance with a county land-use commis-
sion's guidelines or regulations. In 1975 Montana passed a law
that calls for subdivisions to be in "harmony" with their environ-
ment. Wyoming's state land-use planning act requires state and
local land-use plans and requires coordination with the Industrial
Siting Board via the State Land-Use Commission.2
A number of other state and local agencies affect land uses.
Attempts to coordinate programs at the state level are typically
through the Office of Management and Budget Circular A-95 process
established in the mid-1960's. Substate planning districts in
most states coordinate Environmental Protection Agency (EPA) pro-
grams in wastewater and drinking water treatment, and area-wide
wastewater management planning. Together with other federal pro-
grams, the intent of the substate planning districts is to estab-
lish an organized review process, although the planning has had
limited effectiveness, and has had only a minimal effect on
decisionmaking.3
(2) Diversity of Land Uses
Minerals that are frequently located in forest, range, or
farm areas raise concerns about the most appropriate of alternative
uses of the land. Although multiple uses'* may be encouraged, it is
!For more discussion of this point, see Chapter 9 on Growth
Management.
2Relevant state statutes for these examples are given in
White, Michael D. "Constitutional Derivation and Statutory
Exercise of Land Use Control Powers," in Rocky Mountain Miner£il
Law Foundation. Rocky Mountain Mineral Law Institute: Proceed-
ings of the Twenty First Annual Institute, July 17-39, 1975.
Albany, N.Y.: Matthew Bender, 1975, pp. 695-97.
3Council of State Governments, Task Force on Natural Re-
sources and Land Use Information and Technology. Land; State
Alternatives for Planning and Management. Lexington, Ky.:
Council of State Governments, 1975, p. 27.
^Multiple use refers to simultaneous utilization of the sur-
face or subsurface of a tract of land for more than one ongoing
productive purpose, including recreation, energy development,
timber harvesting, agriculture, and
348
-------
more typical that one use threatens another.' These conflicts are
usually expressed in terms of individual occupational interests.
Ranchers and farmers are troubled over competition for land and
water, about the loss of agricultural water to energy development,
and about the impact of increasing air pollution on grasslands,
crops, and other natural resources.1
Of special concern are prime farmlands and alluvial valleys
in the Northern Great Plains region. Together these lands are
usually the most productive, support local cattle ranches and
dairy farming, and help provide good hay crops. Agriculture in
Montana and Wyoming is particularly dependent on alluvial valley
floors.
Questions about appropriate land uses also include attempts
by conservationists to protect the natural beauty of the land-
scape and environment. Long valued for its aesthetics and pris-
tine condition, the region could undergo significant transforma-
tion if a high percentage of its energy resources were to be
utilized. Many environmentalists fear that ill-planned and unco-
ordinated development would threaten these aesthetic qualities.2
As shown in the previous section, although comprehensive
land-use control lav.s have been considered, only public land-use
planning has been initiated. Public planning has been undertaken
principally through the BLM within the DOI and the Forest Service
in the Department of Agriculture.
Bureau of Land Management
BLM has primary responsibility for administering resources
on public domain and acquired federal lands and is the surface
management agency for most federal lands (except National Forests;
Parks, and Indian Reservations). The Federal Land Policy and Man-
agement Act of 19763 requires BLM programs to provide for land
manac.eraerr. which promotes "multiple use and sustained yield" while
maini.ai uLng and enhancing the quality of the environment. It re-
quires the development of comprehensive land-use plans for BLM
lands and authorizes Congress to veto any decision to exclude
"from one or more principal uses a tract of 100,000 acres or more
''Grim, Elmore C. "Environmental Assessment of Western Coal
tJ-. • L,;,JO Mining," in Proceedings of National Conference on Health,
Environmental Effects, and Control of Energy Use. Washington,
D.C.: U.S., Environmental Protection Agency, 1976, pp. 177-78.
2See, as one example, Josephy, Alvin M., Jr. "Kaiparowits:
The Ultimate Obscenity." Audjubon, Vol. 78 (Spring 1976), pp. 64-90
3Federal Land Policy and Management Act of 1976, Pub. L. 94-
579, 90 Stat. 2743.
349
-------
for two years or longer."1 Principal uses are defined as domestic
livestock grazing, fish and wildlife development, mineral explor-
ation and production, rights-of-way, timber production, and
recreation.
BLM plans and makes available coal lands for development
through an industry and government nominating system that also
considers market interest for new coal production. A recent court
suit brought by the Natural Resources Defense Council caused a mor-
atorium on the sale of new coal leases by the government.2 The
Bureau's "Energy Minerals Allocation Resource System" (EMARS) is
currently under review, and the DOI is examining existing leases
and applications to determine if production is environmentally
acceptable.3 Based on these reviews, BLM is not likely to resume
coal leasing activities at least until 1980. ^ However, oil, gas,
and geothermal resource leasing programs are continuing, as is
the evaluation of uranium mining claims.
Forest Service
The Forest Service in the Department of Agriculture is a sur-
face management and research oriented agency. It manages surface
lands in close cooperation with developers. The National Forest
Management Act of 19765 established standards and guidelines for
Forest Service land-use plans and revised federal policy towards
managing national forest resources.
Both the Federal Land Policy and Management Act and the Forest
Management Act are intended to develop more comprehensive land-use
planning for federal lands. They both address the range of compet-
ing interests and conflicts that result in managing for multiple
uses. Even so, neither of these recent laws appears able to deal
with problems and issues relative to prospecting and claims
Congressional Quarterly, Inc. Congress and the Nation,
Vol. Ill; 1969-1972. Washington, D.C.: Congressional Quarterly,
1973, p. 314.
2For a discussion of the moratorium, see Chapter 2.
3"Interior May End EMARS Leasing." Old West Regional
Bulletin, Vol. 4 (August 1, 1977), p. 4.
"*Rattner, Steven. "Tough Task in Implementing Crippled
Energy Plan." New York Times National Economic Survey,
January 8, 1978, Section 12, p. 13. ~
5National Forest Management Act of 1976, Pub. L. 94-588,
90 Stat. 2949.
350
-------
procedures of the 1872 Mining Law.l For uranium, public domain
lands under jurisdiction of a surface management agency subse-
quently move from federal to private ownership. Under these cir-
cumstances almost all uranium lands are under state control.
The 1964 Wilderness Act, which established a national wilder-
ness preservation system, is also managed by the Forest Service.
This act will eventually close millions of acres of federal land
to energy resource development. On January 1, 1984, lands which
the Forest Service has designated as wilderness areas will be with-
drawn from mining and leasing laws. Although minerals exploration
and production is not now formally prohibited on these withdrawn
lands, the risk associated with attempts to bring development on-
line by 1984 has already severely restricted energy development
ventures for these areas.3 In addition, proposed wilderness areas
managed by the Forest Service, e.g., primitive and roadless areas,
have been identified for possible inclusion in the wilderness
system.
Evaluation of wilderness and roadless areas to be withdrawn
from development is the focus of the Forest Services ongoing Road-
less Area Review and Evaluation (RARE) program. "RARE II" which
delineates the most recent classification of these lands proposed
the addition of some 67 million acres (104,688 square miles) to
the wilderness/roadless system. "* Included in these lands are for-
est lands which had been classified as commercial timberland. Rep-
resentatives of the timber industry have questioned the single-use
wilderness designation in view of the historical multiple-use con-
cept whereby industry and recreationists shared use of the national
forests.
forest management provision's are generally considered to be
more favorable to the timber industry than to environmentalist.
See Congressional Quarterly, Inc. Congress and the Nation, Vol.
Ill: 1969-1972. Washington, D.C.: Congressional Quarterly,
1973, p. 313. This issue is discussed below in Subsection "B," on
land reclamation.
2Also, a number of uranium lands are on Indian Reservations
under Indian, Bureau of Indian Affairs, and USGS management.
3U.S., Department of the Interior. Mining and Minerals
Policy, 1976 Annual Report of the Secretary of the Interior.
Washington, D.C.: Government Printing Office, 1976, p. 90.
^Wilkinson, Bruce. "Timber Groups Decry Shrinkage in Product
Base." Denver Post, November 1, 1977
351
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National Park Service
The National Park Service, administering agency for the Na-
tional Park System, has an ongoing planning process to develop
"General Master Plans" for the various parks under its control.
The Resources Management Plan, one part of the General Plan,
deals specifically with mineral development activities. In gen-
eral, mining is prohibited in National Parks; however, the Sec-
retary of the Interior does have authority to allow utilization
of resources in certain recreation areas. For this to occur, it
must be demonstrated that energy development activities will not
"conflict or significantly impair recreation and the conservation
of the scenic, scientific, or other values of any park in the
National Park System."1
B. Objectives and Requirements of Land Reclamation
Questions of land reclamation are closely tied to issues of
planning and managing land uses. Given the competing uses and
need for large quantities of land, reclamation objectives and re-
quirements are probably among the most critical problems and is-
sues associated with western energy development. That is, if mined
lands can be "satisfactorily" restored, conflict presumably would
be reduced.
Public interest concerning the effects of mining, conversion,
and waste disposal on land is manifested in a number of general
and more specific concerns. A general concern is the "irrevers-
ibility" of mining decisions—the possibility that the land will
be modified in a way that will make the land be of irreversibly
lower value to society. As indicated in the description of im-
pacts earlier, it is possible that, without adequate reclamation,
future land-use alternatives will be lost and that severe ecologi-
cal damage will result.
A specific concern is the effect of mining on water. Coal
seams and oil shale deposits are major sources of groundwater for
a variety of domestic and livestock uses. Consequently, surface
mining-can affect the availability and quality of water for farms
and ranches. Mining interests may also conflict with other envi-
ronmental values if reclamation objectives are not carefully pre-
scribed and enforced. For example, improperly restored lands have
a lower aesthetic value to those who want to protect the natural
ecology and topography of an area.
All of these concerns are compounded by legal and admin-
istrative arrangements for land management and reclamation.
1Moore, Russell, and Thomas Mills. An Environmental Guide to
Western Surface Mining, Part One.; Federal Leasible and Locatable
Mineral Regulations. Washington, D.C.: Government Printing
Office, 1977, p. 64.
352
-------
Requirements for restoring lands affected by energy development
differ according to resource and jurisdiction. In the case of
surface coal mining, this issue has been on the public agenda for
decades, and more uniform regulations for coal mine reclamation
have recently been made (see below). However, reclamation objec-
tives and requirements vary widely for other minerals. Even with
coal, the limited knowledge of the probability of successfully
reclaiming, and the trade-offs associated with this diversion,
are perceived differently by various stakeholders.
Revegetation efforts have generally involved both "native"
and "introduced" species. Some reclamation policies call for the
use of native species because they are well adapted to the condi-
tions that exist at the reclamation site. But limited availa-
bility of seeds for native vegetation in arid and semiarid loca-
tions may limit the use of native species.1 Also, some reclama-
tion efforts use introduced species because they germinate and
grow more quickly. However, it is uncertain whether or not intro-
duced species will persist and become a component in the ecosystem.
Problem "weeds" frequently colonize and outcompete other species
used in revegetation and are not suitable as food for wildlife
or livestock.
(1) Policies for Reclaiming Disturbed Lands
From the beginning of mining activities in the 19th century,
western mining companies have done some reclaiming of mined lands,
but with few controls by government agencies. Until the early
1970's governments at all levels largely ignored reclamation prob-
lems. During the 1970's a majority of western states enacted leg-
islation to require reclamation provisions as summarized in
Table 7-6.
The most sweeping changes in reclamation law came in 1977
with the passage of the Surface Mining Control and Reclamation Act,2
which called for state implementation of surface mining standards
for coal extraction. The specific intent of the act is to provide
minimum uniform standards to regulate mining. Lobbying for this
type of surface mining law during the last several sessions of
Wyoming mine official. Personal communication, 1977. While
limited availability of seeds is often a problem for some species
needed for revegetation, not all native seeds are in short supply.
Instead the most significant problem is that wild seed must be
collected in the same general area where it will be planted.
Streeter, Robert G., Coal Research Manager, Fish and Wildlife Ser-
vice, U.S., Department of the Interior. Personal communication,
1977.
2Surface Mining Control and Reclamation Act of 1977, Pub. L.
95-87, 91 Stat. 445.
353
-------
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Congress by a coalition of environmentalists' groups was intense.
Opposition by the National Coal Association and other industry
groups was equally intense. Most minerals, including oil, gas,
oil shale, and uranium, are still not covered by a uniform rec-
lamation policy.
Strongly supported by Secretary of the Interior, Cecil Andrus,
the Surface Mining and Reclamation Act of 1977 substantially
changes the federal role in controlling coal surface mine recla-
mation. : The principal objective of the act, as indicated by
House Interior Committee Chairman Udall of Arizona, is to provide
a uniform system of restoring strip mined lands to approximately
original conditions. As shown in Table 7-7, the act established
an Office of Surface Mining Reclamation and Enforcement (OSM) in
the DOT, with responsibility for developing detailed reclamation
performance standards. It also establishes an Abandoned Mine
Reclamation Fund, requires reclamation plans to provide for pub-
lic hearings and citizens suits, and outlines procedures for des-
ignating lands unsuitable for mining.
Strip mining of highly productive farmland was a contro-
versial element of the new law. Environmentalists and some agri-
cultural interests had sought to prohibit any strip mining of
farmlands. Coal industry lobbyists argued that the land could
be restored and made even more useful after reclamation. As a
compromise, the act permits mining of "prime farmlands" and in
alluvial valleys when the developer can show that the proposed
mining operations would not preclude farming and not adversely
affect the quantity of water in the valley floor system.2 Sur-
face owner consent is required before mining can take place on
federal strippable lands beneath an owner's land. Finally, re-
vegetation and restoration to original topography is generally
required except in rare circumstances (see box "Modifying To-
pography" ) .
The act also provides uniform reclamation standards on all
lands whether federal or not, and assigns states management and
enforcement responsibility. Officials of the OSM are to inspect
periodically all mines and report on the: progress of reclamation
work. Regardless of where produced, a tax on mined coal is used to
Although its title does not indicate it, the legislation
covers both the adverse effects of surface mining and, to a lesser
extent, the surface impacts of underground coal mining operations.
But there is no broad legislation addressing subsidence in the way
surface mine reclamation is addressed.
2However, the law does not include grazing pasture or hay
meadows in its definition of "prime farmland" where special rec-
lamation provisions will apply. See "Farm Land Mining Standards
Studied." Denver Post, February 1, 1978.
356
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TABLE 7-7: SELECTED REQUIREMENTS OF THE SURFACE MINING
CONTROL AND RECLAMATION ACT OF 1977
Scope:
Institutions:
Abandoned Mine
Fund:
Implementation/
Monitoring:
Procedures:
Citizen
Participation:
Performance
Standards:
Designation of
Lands Unsuit-
able for
Mining:
Surface Owner
Consent:
Enforcement:
Coal resources that are surface mined (some coverage of
surface activities of underground mines), requires studies
of reclamation needs of other minerals, and provides method
of designating areas as unsuitable for mines over two acres.
Establishes an Office of Surface Mining Reclamation and
Enforcement (OSM) in the Department of the Interior
Establishes a fund based on a coal tax of 35 cents per ton
for surface mined coal, 15 cents/ton for underground coal,
and 10 cents/ton for lignite. Fifty percent of the fund
goes to states for their reclamation needs.
States implement the plan with approved programs. States
inspect and monitor. At least two Federal inspections at
each mine each year, plus inspections at certain inactive
mines.
All surface coal mines require a permit. The permit has
reclamation plan requirements, hearing, approval and denial
procedures, and provision for revised plans. Posting a
reclamation bond is required. Inspection is provided with
administrative and judicial review.
Provides for hearings on reclamation plans with participa-
tion by interested parties, provides for citizens' suits
against agencies and/or the Secretary of the Interior.
Provides detailed performance standards for stabilization,
restoration, revegetation, and postmining land use, and
prevention of water pollution or off-site effects.
Provides for protection of prime farmlands and alluvial
valley floors, and designation of other lands as unsuit-
able for mining by interested parties.
Requires surface owner written consent, and consultation
in development of a comprehensive land-use plan.
OSM enforces reclamation requirements at existing mines,
fines and civil penalties.
357
-------
reclaim abandoned lands, with
states sharing 50 percent of
the fee. The Administrator of
the EPA must concur with pub-
lished regulations, and must
also concur in approving
state programs.1
As shown in Table 7-8,
many other federal agencies
are now involved directly in
administering and managing
reclamation provisions for en-
ergy development. Except for
uranium (and other hard rock
minerals) this involves a sur-
face management agency that can
make stipulations in a lease if
the lands are publicly held.
These agencies are typically
BLM, Forest Service, or the
Bureau of Indian Affairs. In
the case of coal, extensive and
additional requirements have been
gated regulations.
MODIFYING TOPOGRAPHY
There is an opposite extreme to
the original contour concept, the
leveling of hills and mountains to
tabletop flatness. A recent EPA
study indicated that mine operators
in rough topography generally prefer
this approach, questioning the desir-
ability of reestablishing an original
contour. The new Strip Mine Act has
provisions for making possible use of
exceptionally flat tops for airports
or parking lots.
—Chironis, Nicholas P. "Imaginative
Plans Make Mined Land Better Than
Ever." Coal Age, Vol 82 (July 1977.),
p. 49.
specified in recently promul-
For oil, gas, oil shale, and ge^-herrnal resources, most re-
quirements are informal and have developed on the basis of
1 EPA has administrative and managerial interest in reclamation
particularly in its air, water, and research programs. Mine dust
measurements are a part of EPA's air monitoring programs, as is
measurement of mine runoff. For example, as of July 1, 1977, coal
mines that have discharges are required to comply with Final Efflu-
ent Limitations Guidelines promulgated by EPA. Heeman, Michael T.
"EPA Sets Water Pollution Limits." Coal Age, Vol. 82 (July 1977),
p. 141. Mine runoff, and other surface disturbances from energy
development are also supposed to be included in area-wide waste-
water management planning. See: Federal Water Pollution Control
Act Amendments of 1972, Pub. L. 92-500, § 208, 33 U.S.C.A. § 1288
(Supp, 1976).
2The Surface Mining Control and Reclamation Act of 1977 (Pub.
L. 95-87, 91 Stat. 445) requires the Secretary of Agriculture to
demonstrate that adverse effects from surface mining for coal will
not occur in national forests; the act does not contain a similar
provision for national grasslands. Development is therefore easier
on grasslands (which are lands acquired during the 1930fs). In
addition, fewer revenues from grasslands are distributed locally
than are revenues from lands in the public domain, e.g., national
forests.
358
-------
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cooperation between energy company personnel and field agency
management staff, whose development-oriented background usually
facilitates effective communication with energy company employees,
Specific reclamation re-
quirements for uranium mining
are largely nonexistent at both
the state and federal levels.
Since the early 1970's, envi-
ronmental groups (especially
the Sierra Club and Wilderness
Society) have fought to bring
land disturbances from uranium
development under closer fed-
eral control. Interior and
Forest Service personnel also
favor federal legislation and
regulations to ensure that min-
eral uses on public domain lands
are balanced and coordinated
with other surface uses. Most
of these groups and organiza-
tions favor the adoption of a
leasing system over the current
location-patent system.: They
contend that uniform federal
controls would lead to more
production from claims and
minimize abuses by claimants
who have no intention of mining
the claimed lands (see box).
Moreover, a leasing system
could contain provisions requir-
ing reclamation and assure a
"fair return" for "hard rock"
minerals extracted from public lands.
UNMINED CLAIMS
In 1974, officials from the Gen-
eral Accounting Office (GAO) visited
240 unpatented mining claims and 93
patented claims selected randomly
throughout the U.S. Of the 240 min-
ing claims, GAO found that "239 were
not being mined at the time of our
visit, and there was no evidence that
any mineral extraction had ever taken
place on 237 of the claims." The
agency reported that only seven of
the 93 patented claims were being
used for any apparent purpose, while
20 were being utilized for nonmining
purposes? for example, for residences
or grazing activities. Based on
these observations, GAO concluded
that the government had "no opportun-
ity to induce mining of these lands"
since the 1872 Mining Law does not
require that the holder of a claim
must mine the land.
—Choitz, Jackie. "Mining Law
Update." Colorado/Business, Vol. 5
(February 1978), p. 27.
At least two bills are now before Congressional committee
to modify existing controls over uranium mining.2 One bill,
Choitz, Jackie. "Mining Law Update."
Vol. 5 (February 1978), pp. 27-28.
Colorado/Business,
2See House of Representatives Bills 9292 and 5831. Several
committees of the Congress formulate reclamation policies. Two
of the most important are the House Interior and Insular Affairs
Committee, especially its Subcommittee on Mines and Mining, and
the Senate Interior and Insular Affairs Committee and its Sub-
committee on Energy and the Environment. The latter has juris-
diction over legislation on environmental impact of the produc-
tion of energy and energy conservation.
360
-------
supported by the Carter Administration, calls for a leasing sys-
tem as noted above. The bill would also impose uniform controls
to protect the environmental values of the land. However such
changes to the Mining Law of 1872 are being strongly opposed by
the American Mining Congress and state mining organizations.1
Another bill (H.R. 5831) seeks to preserve the present location-
patent system, keep the public domain open, and contains no pro-
visions for increased environmental protection, calling for mini-
mal change in the law to limit adverse economic consequences.2
The contrasting bills underscore the fundamental issues with re-
gard to "hard rock" mineral resources: what actions need to be
taken to provide for adequate exploration and development; how
much control should the federal government exercise; and what pri-
ority should energy development have over other public land uses.
(2) Reclamation and Waste Disposal
Major concerns with mine wastes have generally been over the
quality of wastes and the expectation that land used for disposal
is irreversibly committed, rather than with "quantities" of land
affected. Many mine wastes, especially uranium tailings, solid
wastes from coal, and flue gas desulfurization wastes can pose
threats to human health and the environment. And because of its
volume, spent shale can also pose environmental problems.3 The
seriousness of such threats depends on how the wastes are managed
and monitored, including where and how wastes are disposed of or
stored and how they are treated and transported.
Governmental regulation of mine wastes typically focus on
specific types of wastes or address selected impacts. Two of the
more important federal laws relevant to managing the impacts of
energy-related waste disposal are the Surface Mining and Reclama-
tion Act (discussed earlier) and the Resource Conservation and
Recovery Act of 1976.1*
, Jackie. "Mining Law Update." Colorado/Business ,
Vol. 5 (February 1978), p. 27.
2"Mineral Rights Raise New Dust." Business Week, October 3,
1977, p. 48.
3See White, Irvin L. , et al. Energy From the West: A Prog-
ress Report of a Technology Assessment of Western Energy Resource
Development. Washington, D.C.: U.S., Environmental Protection
Agency, 1977; and White, Irvin L. , et al. Energy From the West;
Impact Analysis Report. Washington, D.C.: U.S., Environmental
Protection Agency, forthcoming.
^Resource Conservation and Recovery Act of 1976, Pub. L. 94-
580, 90 Stat. 2795.
361
-------
As discussed above, the 1977 Reclamation Act establishes fed-
eral control over the surface effects of mining. With regard to
wastes, the thrust of the act is to control water pollution. In
general, the accompanying regulations require burial of mine wastes.
However, the initial regulatory program still deals only with toxic-
forming and acid-forming wastes, and with proper reclamation of
wastes produced from coal preparation facilities where they are
used in backfilling or grading mined areas, placed in impoundments,
or used in construction of dams. Complete controls over waste
placement, tailings, coal processing wastes, and others are to be
addressed later. Sedimentation ponds are included, and inspection
by the Mining Enforcement and Safety Administration (MESA) of all
settling ponds regardless of embankment heights or volume is re-
quired. But the role of MESA regulations once complete controls
are developed remains open to question.1
The Resource Conservation and Recovery Act provides a frame-
work for dealing with all solid waste disposal. Under this act,
land, like air and water resources, is placed under strict federal
regulatory control. In attempting to conserve virgin resources,
the law seeks to develop a nationwide system for the management of
hazardous and solid wastes (regional solid waste plans) and for
the recovery of resources from these wastes. If some solid wastes
from the coal fuel cycle are classified as hazardous, this could
have far reaching effects on the way such wastes are presently
handled, and on the final regulations under the Surface Mine Act.
At the present time, regulations dealing with hazardous wastes
and regional solid waste plans are still being developed. EPA is
charged with establishing criteria for regional and solid waste
plans, including mine wastes, and conducting detailed studies of
mine wastes. Recognizing the close mandate between reclamation,
land use, and EPA's role in maintaining environmental quality, re-
organization studies in the Office of Management and Budget have
suggested incorporating EPA into the DOI or combining"them in a
new Department of Natural Resources and the Environment. In part,
such a reorganization may be due to the strong environmental ap-
proach in Interior by its current Secretary.2 Some westerners have
expressed concern that such a reorganization would "destroy local
autonomy, break down communication and cooperation among already
existing resource agencies" and could mean decisions affecting
western states would be made without sufficient regional repre-
sentation.^
lSee 42 Fed. Reg. 62,646 (December 13, 1977).
2Kirschten, J. Dicken. "Reorganizing Natural Resources May
be Tougher Than Carter Thought." National Journal, Vol. 9 (Oct-
ober 15, 1977), pp. 1613-18.
3Sibley, Whit. "Resources Shake-Up Idea Shakes Up Westerners.
Denver Post, February 8, 1978.
362
-------
C. Access to and Control of Recreational and Critical
Environmental Areas
The environmental quality of most western states has been
stereotyped: New Mexico is "The Land of Enchantment"; Wyoming is
"Sportsman's Paradise"; Montana is the "Big Sky" country; and
Arizona is a "Retirement Capitol."1 Yet, these areas are also
centers for mining and resource exploitation. Congressmen from
the western states are most active in committees that deal with
natural resources, and they represent industrial, recreational,
and environmental interests that frequently conflict.2 Providing
for wilderness recreational experiences,3 and for more intensive
use of national parks, is a continuing conflict for land managers
and policymakers. **
As land-use planning has developed during the past decade,
so has the government role in controlling individual uses of nat-
ural resources such as wildlife, and scenic or recreational areas.
These policies are a part of the government activities in planning
land use, but they deal more with managing and accommodating the
activities of individuals. Many of these controls have been in
response to sportsmen and environmental interest group demands to
sustain or improve the population status of endangered species and
wildlife. Interest groups such as Trout Unlimited, Ducks Unlimited,
and the National Wildlife Federation are especially active in the
West. The National Wildlife Federation, the Sierra Club, and the
National Audubon Society have been historically important groups,
and have lobbied for wilderness areas, wildlife areas, wildlife
refuges, and controls over endangered species, especially since
the 1950's. In response to these lobbying efforts, Congress passed
the Endangered Species Acts of 1968 and 1973, the Wilderness Act
of 1964, and has added significantly to wildlife refuges in the
western states.
, Neal R. The Mountain States of America. New York,
N.Y.: Norton, 1972, pp. 290-91.
2Wagner, James R. "Interior Subcommittees Move Slowly on
Legislation to Reform Public Lands Policy." National Journal,
Vol. 3 (August 21, 1971), pp. 1768-73.
3Wagner, James R. "Agencies Speed Up Review in Push to Ex-
pand Wilderness System." National Journal, Vol. 2 (1970) , pp.
2826-31; and U.S., President, Office of the White House Press
Secretary. "Message to the Congress from the President."
Mimeographed copy, Washington, D.C., May 23, 1977.
^Scher, Zeke. "The Great Canyonlands Double Cross." Denver
Post, Empire Magazine, August 21, 1977, p. 16.
363
-------
These same groups have been active; in promoting increased
recreational and scenic resources for tourists and westerners,
resulting in legislation1 establishing the Bureau of Outdoor Rec-
reation (now the Bureau of Heritage Corservation and Recreation)
to coordinate recreation planning, and a fund to acquire lands
for recreation.2
The Bureau is responsible for coordinating Wild and Scenic
Rivers, National Trails, and state and local recreation programs.
It also coordinates government policy restricting recreational
activities such as President Carter's recent Executive Order that
establishes federal policy to designate areas in which off-road-
vehicles (ORV) can be used and in which they are prohibited.3 In
the latter case, the effect of such a role has been to antagonize
a major sector of the recreational public which frequently uses
western lands.
The role of a number of federal agencies dealing with wild-
life and the quality of the ecosystem is indirect, such as the
Soil Conservation Service or the EPA. EPA has a direct research
mission in understanding the role of plants and animals in the
ecosystem and it regulates air emissions and water quality to min-
imize adverse effects on wildlife. Russell Train, a past Adminis-
trator of EPA, has been critical of agencies in the DOI, suggesting
that their guardianship of wildlife resources is too often governed
by narrow interests and near-term concerns of income-producing
sportsmen.^ Train cited a Council on Environment Quality estimate
that 97 percent of the funds on wildlife management go to three
percent of the species, the ones used for hunting, trapping, or
fishing.5
•In the past both individual energy development companies and
their lobbies, such as the American Petroleum Institute and the
American Mining Congress, have opposed restrictions on vehicle
use or setting aside large tracts of land for primitive areas or
Bureau of Outdoor Recreation Act of May 28, 1963, Pub. L. 88-
29, 77 Stat. 49, 16 U.S.C. 460.
2Land and Water Conservation Fund Act of 1965, Pub. L. 88-578,
78 Stat. 897, as amended by Federal Water Project Recreation Act,
Pub. L. 89-72, 79 Stat. 2.13.
3"Off-Road Vehicles on Public Lands," Executive Order 11989
(May 24, 1977)'. 42 Fed. Reg. pp. 26959-60 (May 25, 1977).
4"Interests Governing Wildlife Too Narrow, Train Says."
Environment News . (Boston, Mass.: U.S., Environmental Protection
Agency,Region I, New England Regional Office), November 1976.
5Ib_id.
364
-------
national parks (see box).J
These groups have been active
in commenting on management pro-
posals such as restrictions on
vehicle use that may be impor-
tant in gaining access to or ex-
ploring for energy resources.2
State government control
over recreational activities
is diffuse. Programs exist
in a number of administrative
agencies, including surface
management agencies and those
involved in managing natural
resources. Most states pro-
vide for a park and recreation
department or commission that
manages parks, campgrounds, or
recreational areas. A separate
department of fish and game
typically controls access and
catch of game or fish resources,
and a state department of for-
estry controls use of state
forests (see Table 7-9).
7.2.3 Summary
As the above discussion demonstrates, the land-use impacts of
energy resource development occur as a consequence of two kinds of
land-use requirements: first, the land requirements of the energy
development itself such as for mines, conversion and support facil-
ities, and waste disposal; and second, land required to meet the
needs of energy-related population increases, such as housing and
recreation. Both kinds of land-use requirements affect competition
for public and private lands and environmental quality and aes-
thetics .
On the basis of the above discussion, land uses can be di-
vided into the three categories shown in Figure 7-2: economic/
production, preservation/conservation, and leisure-time/recreation.
ACCESS TO RECREATION
There has been considerable op-
position to designating lands as na-
tional parks. In the case of Canyon-
lands National Park at the confluence
of the Green and Colorado Rivers in
Utah, oil, uranium, and other mineral
interests as well as stockmen and
businessmen opposed creation of the
park in the early 1960's. The idea
of the park was sold through Park Ser-
vice films and documents which showed
that opening the park to tourists
would bring prosperity to Utah resi-
dents. In 1977, the National Park
Service established the policy that
Canyonlands would not be developed
for vehicle access, and that it would
largely remain a wilderness park. It
is now one of the least used national
parks, with 79,100 visitors in 1976.
—Scher, Zeke. "The Great Canyon-
lands Double Cross." Denver Post,
Empire Magazine, August 21, 1977,
p. 10.
1Scher, Zeke. "The Great Canyonlands Double Cross."
Post, Empire Magazine, August 21, 1977, p. 10.
Denver
2U.S., Department of the Interior, Bureau of Outdoor Recre-
ation. Draft Environmental Impact Statement: Departmental Imple-
mentation of Executive Order 11644 Pertaining to the Use of Off-
Road Vehicles on the Public Lands. Washington, D.C.: Bureau of
Outdoor Recreation, July 1976.
365
-------
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Energy resource development must compete for land with other eco-
nomically productive land uses such as grazing and row crops; and
it must compete with preservation and conservation, and leisure-
time and recreational uses. Competition already exists within and
among these three categories of land use in the West. Large-scale
energy resource development and the associated large population
increase that can be expected will intensify this competition
during the next two decades or so, taxing the conflict resolution
and problem-solving capabilities of all levels of government.
The major environmental and aesthetic impacts of energy de-
velopment will occur as a consequence of surface lands being dis-
turbed, both by the construction and operation of energy facil-
ities and by the leisure-time and recreational activities of an
enlarged population. Surface mining, site preparation, road
building, and other energy development activities will disturb
surface lands, usually in relatively small amounts for any single
facility, but in large amounts in areas of concentrated, large-
scale development. Whether these lands can be successfully re-
claimed and returned to their original or some other economically
productive use is still problematic; and, as in dealing with
increased competition for land, successfully reclJiimirig these
lands will challenge the planning, monitoring, and enforcement
capabilities of all levels of government.
Leisure-time and recreational environmental and aesthetic
impacts may be more lasting and may prove to be more difficult to
deal with successfully. The increased, easier access needed for
energy development will open up more lands for leisure-time and
recreational activities. The use of ORV and other vehicles will
be greatly increased and, unless adequately controlled, will de-
face and scar the land. Hunting will also increase, stepping up
the pressure on game animals in the vicinity of energy develop-
ments. Population encroachments will cause certain species of
animals to retreat from their present habitat; and, in some
cases, habitat fragmentation and encroachment together with the
land disturbed directly by energy development activities may con-
sume a significant proportion of certain types of habitat.
As noted above, all of these land-use and reclamation impacts
and problems and issues will challenge n;he planning, monitoring,
and enforcement capabilities of all levels of government. It is
riot clear that the existing institutional mechanisms described
above will be adequate to meet the challenge. This problem is com-
plicated by the fact that the federal government and Indian tribes
are major landowners in the eight-state study area. Several fed-
eral agencies have a management role and responsibility for these
lands, including Indian lands. Coordinated, cooperative planning
and management among these several agencies is limited, but the
major problem appears to be coordination and cooperation among
levels of government. For example, state governments cannot be
certain that they will be able to participate and have a decisive
368
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role in decisions concerning energy developments within their own
boundaries. As the analyses in other chapters in this report
demonstrate, this is but one area in which serious intergovern-
mental problems and issues are being raised in connection with
western energy resource development.
Given both the range of interests and values at stake in
land use in the West and the pluralistic nature and federal struc-
ture of our political system, it is unlikely that any one land
use or one level of government will prevail over all others. It
is much more likely that some lands will be allocated for all
three land-use categories identified earlier in Figure 7-2; and
that an effort will be made to insure that land-use policymaking
institutions and processes are adequate to deal effectively with
both present and future land-use and reclamation problems. It
can also be expected that an effort will be made to accommodate
the multiplicity of interests and various governments involved.
Therefore, the overall public policy problems and issues in this
category involve both substantive and procedural concerns: Which
lands will be allocated for which use in what quantity? Can lands
disturbed by energy development be returned to their original state
or to some economically productive state? How and by whom will
allocations be made, access and activities controlled, and recla-
mation insured? In the following section, alternative policies
and implementation strategies for dealing with these problems and
issues are identified, evaluated, and compared.
7.3 ALTERNATIVE POLICIES FOR LAND USE AND RECLAMATION
7.3.1 Introduction
The above discussion led to the conclusion that land-use and
reclamation problems and issues likely to arise as a consequence
of western energy resource development reflect two kinds of con-
cerns: procedural and substantive. Procedural concerns focus on
how policies are made; for example, on whether state and local
governments are given adequate opportunities to protect their in-
terests when decisions about the development of federal lands are
made. Substantive concerns focus on the content and anticipated
consequences of land-use and reclamation policies; for example,
on which lands are to be allocated for surface mining and what
the effects of those allocations will be.
Based on the extended discussion in the preceding section, it
appears that land-use and reclamation policies relating to western
energy resource development must address two closely related, over-
lapping general policy objectives, one primarily procedural, the
other primarily substantive. These two general policy objectives
are:
• To insure that the institutions and processes for making
land-use and reclamation policies and decisions give
369
-------
adequate consideration to all current and future
uses;
• To provide for and protect a diversity of present and
future land uses.
7.3.2 Description of Alternatives
To achieve either or both of these objectives, a more com-
prehensive and better coordinated land-use planning and manage-
ment system will be required which provides participation oppor-
tunities for a broad range of parties-at-interest, coordinates
cooperative planning -and management among agencies and levels of
governments, and specifies what lands can be used for what pur-
poses. Specific alternatives for creating such a system differ
primarily in terms of the extent to which the system would be
centralized, how comprehensive it would be, and the degree of
control over land uses that would be exercised. The possible
range of specific alternatives is from establishing a central-
ized federally coordinated comprehensive land-use planning and
management system to incrementally improving the decentralized
fragmented system described above; and from making case by case
decisions for selected kinds of land uses (such as energy facil-
ity siting) to preparing a comprehensive land-use plan which des-
ignates permissible land uses and requires all lands disturbed
by energy development either to be reclaimed to their predevelop-
ment condition or redeveloped for some productive use.
A. What Are the Alternatives?
It is not feasible to deal here with the entire range of pol-
icy alternatives for achieving the two general objectives stated
above. The scope of the analysis can be narrowed considerably by
focusing on a more specifically western energy objective drawn
from the two objectives described in Section 7.3.1:
• To meet the land-use needs of energy development,
including the land requirements of energy-related
population increases, while providing for and pro-
tecting a diversity of present and future land uses.
As shown in Table 7-10, establishing a better coordinated, more
comprehensive land-use planning and management system to control
land use and changes in land use is one way to go about attempt-
ing to achieve this objective. Specifically, to achieve this
objective, land use and changes in land use would have to be con-
trolled and all lands disturbed by energy resource development
would have to be either reclaimed or redeveloped. The alterna-
tives are not mutually exclusive and a comprehensive land-use
370
-------
TABLE 7-10:
LAND-USE AND RECLAMATION OBJECTIVES
AND POLICY ALTERNATIVES
OBJECTIVE
CATEGORY
OF
ALTERNATIVES
SPECIFIC
ALTERNATIVES
Meet the land-use
needs of energy
resource develop-
ment, including
those associated
with population
increases, while
providing for and
protecting a di-
versity of pres-
ent and future
land uses
Control land use
and changes in
land use
Designate permis-
sible land uses
Control access to
and activities on
all public and
private lands
Require rehabili-
tation of all
lands disturbed by
energy resource
development
Require reclama-
tion (return to
predevelopment use)
Require redevelop-
ment (return to
some other pro-
ductive use)
planning and management system would probably include both.1 Each
alternative could be designed to achieve the stated objective of
supporting energy development while providing for and protecting a
diversity of present and future uses. The two alternatives differ
primarily in terms of emphasis.
B. How Can the Alternatives Be Implemented?
The first category of alternatives emphasizes a comprehensive
planning approach which attempts to insure "appropriate" or "best"
fit of land and land-use activities (see Chapter 12 on Energy Facil-
ity Siting). Based on an understanding of present and future land
needs and the compatibility of specific land areas and land uses,
permissible land uses for these land areas would be identified.
This means, of course, that certain land uses may be^ explicitly
prohibited; for example, surface mining on prime agricultural
lands. And it may be considered desirable to control access to
and activities in designated permissible use areas. For example,
Terminology in this problem area is not standardized. As
used here, rehabilitation means that disturbed lands will be re-
stored to some productive use; reclamation means restoring to the
predevelopment use; redevelopment means restoring to some other
productive use.
371
-------
the number of people allowed in a recreation area at any one time
may be limited; and snowmobiles may be permitted but not other
kinds of ORV's.
This comprehensive planning approach could be centralized with
the federal government formulating the goals and the states imple-
menting them. (This is the pattern in waiter and air quality, see
Chapters 5 and 6.) Or the federal role could be limited to provid-
ing financial and technical assistance. However, because of the
large amount of federal land in the West, it is unlikely that a
state system could deal effectively with the land-use problems and
issues discussed earlier unless the federal government were to co-
operate with the states to coordinate planning for federal lands
with state planning for state and private lands. An intermediate
alternative that would address this federal-state problem, would
be to establish a multistate land-use planning organization as a
forum for cooperative, coordinated land-use planning and management
in the region.
The second category of alternatives emphasizes returning lands
disturbed by energy resource development to a productive use. With-
in the current land-use and management system, lands would be made
available to meet energy needs with the stipulation that they be re-
habilitated. Specific alternatives would be to require either rec-
lamation or redevelopment. As with the first category of alterna-
tives, this approach could give the lead planning and management
role to the federal government, to the states, or to a multistate
organization.
In the following section, only reclamation and redevelopment
alternatives are evaluated and compared. This narrower focus is
necessary because of the scope of this topic, but it also seems
appropriate because of the importance of the reclamation issue for
western energy resources development.
7.3.3 Evaluation of Alternatives
In general, energy resource development can be viewed as a
temporary or "interim" land use. With some possible exceptions,
lands withdrawn for energy resource development will be available
for other uses after development is completed. The basic question
is whether these lands will be returned to their predevelopment use
or to some other productive use. That is, will they be reclaimed
so they can be used as they were before energy development, or re-
developed so they can be used for some other productive use. Cur-
rent state and federal laws and regulations generally require that
lands disturbed by surface mining be reclaimed. In the West, this
usually means returning them to an agricultural use.
Comparable requirements have not been established for other
surface-mined resources such as oil shale and uranium.
372
-------
Current regulations permit some variation in meeting these
objectives depending on site-specific conditions. However, the
clear preference articulated in both state and federal require-
ments is for reclamation rather than redevelopment. It is not
obvious that this is always the "best" policy alternative; and it
is not clear that reclamation is possible in all parts of the West.
What follows is an analysis of the reclamation and redevelopment
alternatives. To the extent possible given the limited informa-
tion available, these two alternatives are evaluated and compared.
Information is limited in large part because experience in the
West with both reclamation and redevelopment is limited.
A. Evaluation Criteria
The five basic evaluation criteria identified and defined in
Chapter 3 will be used in this analysis: definitions of these cri-
teria as they apply to reclamation and redevelopment are presented
in Table 7-11 together with appropriate quantitative and qualita-
tive measures. As Table 7-11 illustrates, applying these criteria
raises both substantive and procedural questions. Although there
is some overlap, questions about achieving objectives, costs, risks,
and benefits and the distribution of costs, risks, and benefits are
primarily substantive while questions about flexibility and imple-
mentability are primarily procedural. This is appropriate since,
as noted above, the overall policy objectives for land use and re-
clamation are also substantive and procedural.
B. Evaluation of the Reclamation Alternative
Almost all energy resource development in the eight-state
study area will take place in rural settings where the most com-
mon current land uses are agricultural, primarily ranching, graz'-
ing, and farming. As noted earlier, reclamation in this setting
means returning the lands disturbed by energy development to these
predevelopment agricultural uses. Two strategies for implementing
this alternative are identified in Table 7-12: continue current
requirements or make the system more flexible. As the evaluation
in this section will show, the major reasons for considering an
alternative to the current requirements is that their dollar costs
are generally high and the probability of successful reclamation
in all parts of the study area is uncertain.
At the present time, reclaiming surface-mined coal lands goes
on simultaneously with mining and, in this area, usually involves
backfilling, grading, replacing topsoil (which is now often sepa-
rated and stockpiled during mining), and establishing a vegetation
cover. Revegetating requires soil preparation, seeding and/or
planting, and perhaps fertilizing and irrigating. At most west-
ern mine sites, seeding can be accomplished by either broadcasting
or drilling. If trees and shrubs are planted, they are usually
planted by hand.
373
-------
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A wide variety of seeds, shrubs , and trees are being used.
Native seeds and seedlings are usually required unless it can be
shown that an "introduced" species will have "equal or superior
utility for the approved postmining land use, or are necessary to
achieve a quick, temporary, and stabilizing cover."1 However, no
concensus exists among state reclamation authorities and mining
companies as to which varieties are preferable. Sweet clover,
crested wheatgrass, smooth broomgrass, and alfalfa are relatively
quick and easy to get started; and cattle do well on these vari-
eties. However, there is some question about their long-term
survival and, in some instances, state authorities have refused
to release the reclamation bonds of coal companies which have used
only these varieties in their reclamation program.2 Most of the
states in the study area now call for the use of native seeds to
produce a native vegetation cover even though it takes longer to
establish.
As shown in Table 7-11, five criteria can be used to evaluate
the reclamation alternative. These five criteria raise five basic
questions: How effective will reclamation be? What costs, risks,
and benefits does it involve? How will these costs, risks, and
benefits be distributed? Can the alternative be used at a variety
of sites under a range of conditions? And, how difficult will the
alternative be to implement?
(1) How Effective Will Reclamation Be?
The effectiveness of reclamation can be evaluated in terms of;
What is the probability of success? How long will the disturbed
lands be withdrawn from productive agricultural uses? How compat-
ible will agricultural uses of the reclaimed lands be with other
land uses and environmental plans and programs in the area? And,
to what extent will reclamation requirements constrain energy re-
source development?
As noted earlier, current practice is for reclamation to be
an integral part of the mining activity itself. The time required
to return surface-mined lands to productive uses depends on site-
specific factors such as climate and soil characteristics. Long-
term success in reclaiming land, especially in arid and semiarid
areas, is uncertain, but will depend largely on the management
*42 Fed. Reg. 62691 (December 13, 1977).
2Thoem, Terry, Environmental Protection Agency, Region VIII.
Personal Communication.
377
-------
commitment made by the landowners and/or the mining company,
including controlling grazing and other potentially damaging
activities.J
Assuming success in reclaiming to predevelopment agricultural
uses, some lands will be withdrawn from use from the time of the
initiation of mining site preparation until some five to seven
years after the mining operation is terminated. However, because
reclamation and mining go on simultaneously, blocks of land would
be returned to productive agricultural uses thoughout the lifetime
of the mine.
In terms of the other measures of effectiveness in achieving
land-use objectives, reclamation ranks high on compatibility with
other land uses, particularly if the implementation strategy is
designed to meet current requirements with regard to contours and
seeding. However, unless proper preventive steps are taken, re-
claimed lands can be a nonpoint source of water pollutants, partic-
ularly if fertilizers are used and if erosion and leaching occur.
Sedimentation in local streams can also be a problem. And the re-
claimed area is a potential source of particulates that can con-
tribute to air quality problems. If these kinds of problems are
not controlled, reclamation may well conflict with environmental
plans and programs in the area.
(2) What Costs, Risks, and Benefits Are Involved in Reclamation?
Economic costs and benefits are an important measure of the
efficiency of reclamation. Clearly the economic costs of regrading
and revegetation alternatives are high. As shown in Table 7-13,
these costs vary from site to site. Currently, predictions of rec-
lamation costs are uncertain. In part, this is because of differ-
ences in the accounting procedures used by mining companies to
calculate reclamation and related costs. In part it is because
many locational factors cause costs to vary from one site to an-
other. These factors include such things as terrain, soil, vege-
tation, type and thickness of overburden, seam thickness, ground
and surface water, climate, type and size of equipment used, mining
technique, applicable reclamation laws and regulations, and the
mining companies' land reclamation methods.2 On the basis of pub-
lished reports, the range for total reclamation costs in the
xSee Hodder, Richard L. "Surface Mined Land Reclamation Re-
search in Eastern Montana," in National Coal Association. Papers
Presented Before Research and Applied Technology Symposium on Mined-
Land Reclamation. Monroeville, Pa.: Bituminous Coal Research, Inc.,
1973, p. 85.
2U.S., Department of the Interior, Bureau of Mines. Coal Sur-
face Mining Reclamation Costs in the Western United States"Wash-
ington, D.C.: Government Printing Office, 1977, p. 6.
378
-------
TABLE 7-13: ESTIMATES OF RECLAMATION COSTS IN THE WEST, 1977
COST ITEM
Design, engineering
and overhead:1
Range, per acre
Range, per ton
Bond and permit fees"
Range, per acre
Range , per ton
Backfilling and
grading: '
Range, per acre
Range , per ton
Revegetation : -1
Range, per acre
Range, per con
Total reclamation:
Range, per acre
Range, per ton
HIGH DESERT AREA
(Sites 1 & 2) a
$480-1,070
0.04-0.06
0-80
0.0-<0.01
l,250i-3,420
0.08i-0.18
110-470
0.01-0.02
1,840-5,040
0.12-0.26
MOUNTAIN, AREA
SITEb
$650-750
0.06-0.08
25-45
<0.01-<0.01
990-1,970
0.10-0.20
30-45
<0.01-<0.01
1,670-2.810
0.16-0.28
NORTHERN GREAT PLAINS
SITE 1C
$350-730
0.01-0.02
50-70
<0.01-<0.01
3,700-6,200
0.12-0.20
100-200
<0.01-<0.01
4,200-7.200
0.13-0.23
SITE 2d
$350-650
0.04-0.07
20-40
<0.01-<0.01
2,200-5,500
0.24-0.61
100-150
0.01-0.02
2,670-6,340
0.29-0.70
SITE 3e
$200-400
<0. 01-0. 01
60-100
<0.01-<0.01
1,800-2,900
0.05-0.09
140-200
<0.01-<0.01
2,200-3,600
0.06-0.10
' = less than
Source: Adapted from U.S., Department of the Interior, Bureau of Mines. Coal Surface Mining
Reclamation Costs in the Western United States. Washington, D.C.: Government Printing Office,
1977, p. T~.
Sites 1 and 2 were selected from five surface mines operating in the Four Corners area of
Arizona and New Mexico.
Site is representative of four low-sulfur bituminous coal operations in Yampa coal field, Routt
County, Colorado.
Site 1 is a single bed area stripping operation like those in Montana and Wyoming (25 foot seam)/
Site 2 is an area strip mine producing lignite (North Dakota).
Site 3, an area stripping operation like those in Montana and Wyoming (40 foot seam).
Includes reclamation plan development, preparation of periodic environmental reports, supervision
of reclamation work, engineering and surveying for environmental protection, water quality protec-
tion and monitoring, overhead of environmental activities, outside environmental consultants, some
surveying and mapping, dust control associated with reclamation, miscellaneous expense.
O
Estimated using annual charge divided by the number of acres disturbed each year.
'Includes removal of vegetative cover where topsoil must be salvaged, removing and stockpiling top-
soil, backfilling troughs, ramps, and final cuts, rough and fine grading of spoil, replacing topsoil.
Where available topsoil is removed and replaced, which more than doubles costs for backfilling and
regrading compared to areas with no topsoil.
Soil preparation, seeding and/or planting, reseeding and/or replanting if required, and irrigation.
379
-------
West appears to be from less than $1,000 per acre to $6,000 or
$7,000 per acre (see Table 7-13).
The Surface Mining Act of 1977 is expected to add to these
costs since it requires more extensive and detailed surveys and
monitoring as part of the requirement for obtaining a lease or
permit. For example, the act requires monitoring climate and air
quality, and a detailed survey of previous and current land use
and soil and water characteristics, as well as improved sedimenta-
tion control. However, an analysis of the potential energy and
economic impacts of the Surface Mining Act as proposed in 1976 sug-
gests that the cost impacts associated with the new legislation
will not be great.1 The report does point out that several provi-
sions with regard to alluvial valley floors and other lands de-
clared unsuitable for mining are subject to varying interpreta-
tions. However, strict interpretation of these provisions will
affect production more than cost.2
If an evaluation of the economic costs of reclamation is to
be meaningful, these costs must be weighed against the potential
return to the energy developer, landowner, and the public-at-1arge.
In other words, the question in monetary terms is: Can the invest-
ment be justified in cost-effective terms? Based on cost estimates
representing the range of land areas likely to be disturbed and av-
erage reclamation costs, reclamation of western surface mined lands
can require an investment of from $600 million to $5 billion (1976
dollars). Although additional work is needed to quantify this (to
the extent that it can be quantified), it has not been generally
shown that reclamation is cost-effective.3
Efficiency considerations also include an evaluation of the
social benefits gained (or costs deferred) as well as dollar costs
incurred by developers. Since current laws and regulations require
reclamation, they imply that as a society, we are willing to pay
the price for land restoration (e.g., in higher energy prices and
higher costs for administering reclamation programs) and/or are un-
willing to accept the social costs associated with "sacrificed" or
abandoned lands.
1ICF, Inc. Energy and Economic Impacts of H.R. 13950 (Surface
Mining Control and Reclamation Act of 1976, 94th Congress), Draft
Final Report. Washington, D.C.: ICF, Inc., 1977, p. 2.
2Ibid.
«
3For example, see LaFevers, James T., Donald 0. Johnson, and
Anthony J. Dvorak. Extraction of North Dakota Lignite; Environ-
mental and Reclamation Issues. Argonne, 111.: Argonne National
Laboratory, 1976, p. 177.
380
-------
Recontour-revegetation alternatives appear to be highly effi-
cient in mitigating indirect impacts, such as those of an aesthe-
tic nature.1 These alternatives include maintaining the natural
topography of the landscape and protecting farmlands and other
agricultural lands.
Environmental or social costs are more difficult to deal with.
For example, regrading and soil compaction may cause higher erosion
rates which will result in increased stream sedimentation and some
loss of agricultural productivity. Other direct impacts may stem
from the intensive use of fertilizer to stimulate rapid revegeta-
tion. Over the long term, the extensive use of fertilizer may have
an adverse cumulative effect on surrounding or adjacent lands,2
but it is often needed to reestablish vegetation. It does seem,
however, that these impacts are primarily short-term trade-offs
which are required if sites are to be returned to their previous
use.3 For example, if revegetation is rapid, fertilizer runoff
will be a short-term problem.
Longer-term trade-offs that affect the efficiency of recla-
mation decisions are foregone opportunity costs, such as the loss
of public and private benefits that might be gained from the land
if it were returned to some other use. For example, marginal agri-
cultural lands in some western states may be of such low economic
value that the several thousand dollars per acre investment needed
to return the land to its former use cannot be justified on the
basis of economic efficiency alone.
(3) How VCiii These Costs, Risks, and Benefits Be Distributed?
Overall, reclamation costs will result in increased coal
prices, Long-term contracts for western coal now set a per ton at-
the-mine price of between $2.50 and $7.50.4 If reclamation costs
are between 1.2 and 70 cents per ton, reclamation costs will range
from 2 to 2^ percent of the price of coal. In terms of equity,
th<=> f' J str i but Ion of these costs can be an important factor
'King. David A. "Recreational Opportunity Costs," in Thames,
John, j",, , ed. Reclamation and Use of Disturbed Land in the South-
west-. Tuscon, Ariz.: University of Arizona Press, 1977, p. 174.
;jFevers, James R. , Donald O. Johnson, and Anthony J. Dvorak.
'l-'-l J- ^i°n °f North Dakota Lignite; Environmental and Reclamation
I_ss!aes_. Argonne, 111.: Argonne National Laboratory, 1976, pp.
175-76.
3 Ibid.
4Asbury, J.G., H.T. Kim, and A. Kouvalis. Survey of Electric
Utility Demandfor Western Coal. Argonne, 111.: Argonne National
Laboratory, 1977, pp. 45-61.
381
-------
influencing the profit margin of a mining company. In the short
term, most of these costs are borne almost exclusively by devel-
opers. And where the landowner is someone other than the energy
company, the benefits of the investment go largely to the owner.
As shown above, reclamation costs may often exceed what is consid-
ered to be the potential value of the land after restoration, thus
raising an equity issue. Mining companies may believe they are
being asked to bear an unreasonable share of the financial costs.
Of course, in the long term, these costs will be passed on to the
energy consumer. If reclamation becomes too costly, monetarily,
it could eventually constrain production at some locations, or
could increase demands by developers for financial assistance.
In sum, however, the basic equity question is whether it is fair
for future generations to be left with unreclaimed mined lands.
As addressed by the 1977 Reclamation Act, the public policy re-
sponse has been to define this as an unacceptable alternative.
Cost-effectiveness issues and equity considerations concern-
ing who bears the reclamation burden may be two reasons why indus-
try has been willing to accept uniform reclamation standards. Al-
though this often entails the acceptance of somewhat arbitrary cri-
teria for land rehabilitation, regrading peaks and ridges to the
original or approximate contour and revegetation to an extent at
least equal to natural cover is generally preferred by mine oper-
ators. 1
(4) Can Reclamation Be Used at a Variety of Sites Under a
Range of Conditions?
Decisions concerning reclamation are generally negotiated
among the surface owner, energy company, and the state reclamation
authorities before development begins. Depending on the discre-
tionary authority granted the state agency, these decisions may or
may not accommodate site-specific factors.2 As a rule, the more
specific the state requirements in terms of criteria, the less
flexible they are. However, the reclamation alternative does keep
many other land-use options open should adjacent or surrounding
uses change. This is in contrast to development for residential
^hironis, Nicholas P. "Imaginative Plans Make Mined Land
Better Than Ever." Coal Age, Vol. 82 (July 1977), p. 48.
2In August 1976 Colorado's Mined Land Reclamation Board was
confronted with the question of how much discretion should be given
to its staff to approve changes in reclamation plans once the Board
has issued a permit. Colorado's 1976 law appears to require public
hearings for any change in mining plans, but the agency seemed to
be pushing for authority to make changes so that mining companies
would not be inconvenienced by delays. See Wynkoop, Steve. "Rec-
lamation Board Ponders Authority." Denver Post, August 20, 1976.
382
-------
uses, industrial uses, and other redevelopment options which are
generally less reversible.
(5) How Difficult Will It Be to Implement Reclamation?
The reclamation alternative should be straightforward and
easy to implement. Reclamation appears to be preferred by both
developers and environmentalists. The uniformity of requirements
for reclamation should make administration easy if the rules are
closely followed. Costs of administration are likely to be low
but will increase if the time period is very long, if success is
elusive, and/or if administration becomes more flexible.
The results of this evaluation of the reclamation alternative
are summarized in Table 7-14. Briefly, what the table shows is
that reclamation may not be successful, will take at least five to
seven years to accomplish if it is successful, is expensive, has
not been demonstrated to be cost-effective, and may not return the
land to its most productive use. The major beneficiaries of rec-
lamation will be future generations and landowners. Current re-
quirements do not cover oil shale and uranium surface mining and
do not adequately accommodate site-specific differences between
coal mines. The table also shows that reclamation is generally
the rehabilitation option preferred by both developers and envi-
ronmentalists .
C. Evaluation of the Redevelopment Alternative
As noted earlier, in addition to the alternative of returning
disturbed lands to their predevelopm.ent use, they can be redevel-
oped for some other productive use such as residential subdivisions,
new towns, industrial parks, wildlife refuges, public parks, and
waste disposal facilities, among others. Table 7-15 shows that
two general implementation strategies can be followed: the first
is to change current state and federal laws and regulations and
require approval of a redevelopment plan similar to the current
reclamation plan; and the second is to include plans for redevel-
opment when land-use plans are prepared, including specifying
which redevelopment uses are preferred.
Because of the pressures that energy-related population
growth will place on outdoor recreational facilities, redevelop-
ment for recreational use is given special attention here. Since
experience with the redevelopment alternative has been limited in
the West, information for a detailed evaluation of this option is
not available. As a result, this evaluation is based on general-
izations from the experience with several redevelopment efforts
in other parts of the country.
383
-------
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Federal agencies (especially the Bureau of Mines),1 develop-
ment companies, arid mining companies2 are actively investigating al-
ternative concepts for redeveloping energy resource lands. Most of
their studies are based on actual demonstration projects to rede-
velop "abandoned" lands where strip, open-pit, or underground mining
occurred sometime in the recent past; and they provide useful infor-
mation for policymakers who wish to consider a productive land use
other than reclamation. As noted in one of these studies, "Possible
uses for surface-mined lands have been scarcely 'scratched.'"3
One of the redevelopment alternatives which has been discussed
in a number of studies'* is the establishment of public parks with
recreational facilities as postmining land-use options. In general,
redevelopment of energy lands for use as public parks with recrea-
tional facilities takes place in several sequential stages: plan-
ning; site preparation; and additional project work. The planning
phase is critical because it involves the cooperation and assis-
tance of numerous parties-at-interest. For example, in a project
to develop a state park on 117 acres of abandoned lands conducted
in Butler County, Pennsylvania, the Bureau of Mines, several agen-
cies of the state of Pennsylvania, the county, and private contrac-
tors were involved in the project.5 Where resource development
fowler, Dale K., and Charles H. Perry III. "Three Years De-
velopment of a Public Use Wildlife Area on a Mountain Coal Surface
Mine in Southwest Virginia," in Bituminous Coal Research, Inc., ed.
Research and Applied Technology Symposium on Mined-Land Reclamation.
MonroeVilie, Pa.: Bituminous Coal Research, Inc., 1973, p. 319.
2For examples, see Camin, Kathleen 0., et al. Mined-Land Re-
development. Lawrence, Kan.: University of Kansas, State Geologi-
cal Survey, 1972; National Academy of Sciences. Rehabilitation Po-
tential of Western Coal Lands. Cambridge, Mass.: Ballinger Pub-
lishing Co., 1974; Carter, Ralph P., et al. Surface Mined Land in
the Midwest; A Regional Perspective for Reclamation Planning.
Springfield, Va.:National Technical Information Service, 1974;
and Matter, Fred S., et al. A Balanced Approach to Resource Ex-
traction and Creative Land Development. Tuscon, Ariz.: University
of Arizona, College of Architecture and College of Mines, 1974.
3 See, for example, Andreuzzi, Frank C. Reclaiming Strip-Mined
Land for Recreational Use in Lackawanna County, P'a.; A Demonstra-
tion Project. Washington, D.C.: U.S., Department of the Interior,
Bureau of Mines, 1976.
"For example, see "Concept of Mining as 'Interim Land Use' Keys
Amax's Coal Policies." Coal Age, Vol. 79 (October 1974), pp. 131-38
5McNay, Lewis M. Surface Mine Reclamation, Moraine State Park,
Pennsylvania. Washington, D.C.: U.S., Department of the Interior,
Bureau of Mines, 1970.
387
-------
has not yet begun, the planning phase would undoubtedly include
input from citizens and local governments to assist in determining
the need for and type of second use for the disturbed lands. Co-
operative agreements must be worked out between federal and state
agencies where the land is owned by the federal government, and
similar ownership arrangements must be made between state and/or
county governments to acquire lands held in private ownership.
Friendship Park, a multiple recreational use facility in Jefferson
County, Ohio, was developed on 1,100 acres of strip-mined land do-
nated to the County by Hanna Coal Company (a division of Consoli-
dated Coal) of Cadiz, Ohio.1
In addition to planning requirements and acquiring the land,
state and federal reclamation laws and regulations must be fol-
lowed. For example, regardless of the postmining land use, mini-
mum recontour and revegetation requirements have to be met (where
applicable), or variances obtained. As noted earlier, in the rec-
lamation discussion, states generally prefer reclamation to pre-
development uses, thus, efforts to create a new second use may re-
quire even closer cooperation among all participants to ensure
adherence to reclamation standards.
Finally, the planning phase includes activities to identify
funds available from both public and private sector sources. In
the Appalachian region, the Regional Commission has in the past
been a major financial source for states and counties interested
in pursuing redevelopment options. Support has also come from
agencies of the federal government with substantive programs re-
lated to the redevelopment alternative chosen, for example, from
the Bureau of Outdoor Recreation to develop picnic areas, from the
Corps of Engineers to develop reservoirs.
Site preparation is not easily generalized, largely because it
depends on numerous locational factors; for example, the type of
energy resource development which disturbs the land, the intended
redevelopment use, geography of the area, and climate. However,
work accomplished in this phase typically entails backfilling,
grading and terracing, compacting, reapplication of topsoils, and
construction of parking lots, reservoirs or ponds, and secondary
roads. Except where variances are obtained, restored areas will
have to be compacted and graded to conform and blend with the sur-
rounding areas. Soil characteristics of an area determine the kind
of preparation needed if lakes or ponds are to be included in the
park. Topsoil requirements and topsoil amendments will also vary
xZande, Richard D. "Friendship Park: One Use of Reclaimed
Strip Mine Land," in Bituminous Coal Research, Inc., ed. Research
and Applied Technology Symposium on Mined-Land Reclamation. Monroe-
vllie,Pa. : Bituminous Coal Research, Inc. , 1973, p~. 294.
388
-------
depending on the particular activity.1 Land development companies
and state and mining company reclamation officials need to co-
operate closely in this phase to ensure that activities which can
be incorporated into the ongoing mining plan are carried out si-
multaneously with energy development.
Additional project work represents the last step in the re-
development activity. Site preparation is completed by revegeta-
ting open areas that were not previously stabilized, planting trees
where required, and constructing park and recreational facilities.
Facilities and attractions to make a public park operational have
typically been provided by government agencies. These have in-
cluded park facilities for outdoor recreational activities, pic-
nic grounds, children's play areas, overnight camping facilities,
and even museums. Indeed, a major attraction at Keyser Park, de-
veloped on .strip-mined land in Lackawanna County, Pennsylvania,
is the Anthracite Museum constructed by the Pennsylvania Historical
and Museum Commission. This Museum presents a comprehensive de-
scription of anthracite from the mine to the consumer. Besides
the 27,000 square feet of exhibit area, facilities include an
auditorium, library, conference rooms, and staff offices.
The need to consider the public parks redevelopment alterna-
tive for some sites in the West appears justified given the antic-
ipated pressure of energy-related population on recreational fa-
cilities in the region. This is particularly the case where en-
ergy development is taking place, or projected to occur, close to
growing rural communities where few parks or related amenities
presently exist. Of course, the costs and benefits of this alter-
native must ultimately be weighed against other types of reclama-
tion and redevelopment.
(1) How Effective Will Redevelopment Be?
The effectiveness of redeveloping some lands to public parks
with receational facilities can be evaluated in terms of: the
probability of success; the time lands will be out of productive
uses; compatibility with existing surrounding land uses; and the
extent to which the redevelopment alternative might constrain west-
ern energy resource development. A primary reason for considering
site-specific redevelopment is that the probability of success is
high and the time out of productive use appears to be minimized.
For example, Keyser Park (Pennsylvania) required three years to re-
develop 125 acres of abandoned strip-mine land. This was viewed
as an "extended period," necessary to allow for seeding, planting,
and seasonal construction. The implication is that this time
;Andreuzzi, Frank C. Reclaiming Strip-Mined Land for Recrea-
tional Use in Lackawanna County, Pa.; "A Demonstration Project.
Washington, B.C.: U.S., Department of the Interior, Bureau of
Mines, 1976, pp. 9-14.
389
-------
could be shortened if redevelopment took place simultaneously with
extraction processes. That is, site preparation activities could
proceed as in the case of reclamation so that minimal seeding and
planting would be required prior to actual construction and devel-
opment of facilities.1
Redevelopment alternatives, however, may be constrained by
recent federal regulations regarding postmining uses. These reg-
ulations require that a postmining use which is not the same as
the preexisting use be approved by the state after consultation
with the landowner or the appropriate state or federal land man-
agement agency. In addition, the proposed use must be compatible
with adjacent and surrounding uses and in compliance with existing
land-use policies and plans. 2 Thus, it appears that some public
uses and facilities could not be deemed compatible with present
uses which are predominantly agricultural. This determination
would have to be based on site-specific conditions and needs and
projections of land-use trends in an area. In addition to limit-
ing redevelopment options, such planning requirements could delay
the processing of premining reclamation plans, thereby constraining
resource development.
(2) What Costs, Risks, and Benefits Are Involved in Redevelopment?
Economic costs and benefits are an important measure of the
efficiency of the redevelopment alternative. However, because of
a lack of western experience with redevelopment, these costs and
benefits are not known at this time. In two of the abandoned land
projects cited above, Keyser and Moraine Parks, development costs
ranged from $1,100 to $6,000 per acre. The high figure is proba-
bly more representative since it includes construction of a pond
within the park area, a facility that would likely be included in
many redevelopment plans. Based on the review of studies cited
earlier, the only generalizations that can be made are that costs
vary according to the type and variety of planned facilities and
that they seem to parallel reclamation costs. Clearly, economic
costs would be higher if the redevelopment included a large num-
ber of recreational attractions. Also, as in reclamation costs,
total costs will depend on how much earth moving is involved.
These costs vary depending on the contour of the land, quantity of
spoils, and distance spoils and topsoil must be moved. In one
project the average cost was 16 cents per cubic yard (based on
Moraine State Park, which included redevelopment of 117 acres
of abandoned mine lands, took about two years of time for revegeta-
tion and adequate survival rates of vegetation is included. The
time frame for Friendship Park in Ohio was comparable.
2These requirements are stipulated in 42 Fed. Reg. 62,681
(December 13, 1977).
390
-------
equipment operating time and not including repair and maintenance
costs) . l
Benefits to states, counties, and individuals in the form of
receipts or income will, like costs, vary according to the kind,
number, and quality of facilities which involve the payment of
usage fees by visitors (e.g., utility hookups, campsites, and cab-
ins) . Reservoirs or lakes could be stocked with sport fish to
produce license fee income to states and income to private entre-
prenuers from retail sales of supplies and equipment to visitors,
to cite but two examples. Other benefits could accrue to the com-
munities through jobs created and gross receipts from year-round
use of the park facilities. For example, operation of Friendship
Park (Ohio) requires a park commissioner and 30 to 50 employees
with a yearly payroll of almost $200,000. Receipts from the park
were estimated to be in the range of $500,000 per year.2
Viewing these facilities as a source of income for counties
and states must be put in a context of risk; for example, the fa-
cilities will require careful planning to anticipate and provide
for recreational needs. The risk involved here is the assessment
of the "market" potential for usage fee facilities.3 As discussed
earlier, the population fluctuations associated with energy devel-
opment may lead to "overbuilding" of facilities or unused facil-
ities, adversely affecting the potential income from the parks.
(3) How Will the Costs, Risks, and Benefits Be Distributed?
A fundamental question concerning how these costs and benefits
will be distributed is: what is the ratio of public and private
funding to redevelop lands for public benefit? In other words,
how much does the energy developer contribute towards developing
the park and related amenities? Beyond basic requirements for re-
grading and revegetation , the developer, the landowner (if other
than the developer) , and related government agencies will have to
determine who pays for what. Aside from the obvious benefits which
will accrue to the persons who live in the area and to visitors
from outside the area, the energy company could benefit from this
alternative through reduced reclamation costs. For example, as
:McNay, Lewis M. Surface Mine Reclamation, Moraine State
Park, Pennsylvania. Washington, D.C.: U.S., Department of the
Interior, Bureau of Mines, 1970, p. 23.
2Zande, Richard D. "Friendship Park: One Use of Reclaimed
Strip Mine Land," in Bituminous Coal Research, Inc., ed. Research
and Applied Technology Symposium on Mined-Land Reclamation. Monroe-
ville, Pa.: Bituminous Coal Research, Inc., 1973, p. 294.
3Camin, Kathleen 0., et al . Mined-Land Redevelopment. Law-
rence, Kan.: University of Kansas, State Geological Survey, 1972.
391
-------
noted above and in the reclamation discussion, a significant part
of reclamation costs stem from earth moving (backfilling, terrac-
ing, and topsoil regrading). Some park facilities, such as ponds
and motorcycle or ORV trails, could require that some part of the
park lands be left unreclaimed to enhance the ruggedness of the
terrain. Thus, companies would have to do only minimal regrading
and terracing, thereby reducing the total earth moving costs. The
risks, especially of environmental degradation and for wildlife
habitat, will depend on careful site selection for such activities.
Public sector economic costs, although uncertain, will prob-
ably be higher due to the cost of acquiring the land from the land-
owner, lost real estate taxes, and administrative costs to main-
tain and protect the park and the facilities in the park. But a
long-term benefit can be identified with regard to future gener-
ations. New public parks in energy development areas should re-
lieve a part of the pressure that increased populations in the
West will place on "national heritage lands." On the other hand,
committing lands to recreational uses means forgoing future oppor-
tunities since most of these commitments will be, for all practi-
cal purposes, irreversible.
(4) Can Redevelopment Be Used at a Variety of Sites Under a
Range of Conditions?
It appears that redevelopment is best implemented on a site-
specific, case-by-case basis and therefore can be applied under a
variety of conditions and over time. Redevelopment requires the
close cooperation of interest groups in the planning for each site,
and thereby increases local and regional control of land use.
(5) How Difficult Will It Be to Implement a Redevelopment
Alternative?
Implementing this alternative will require changing existing
state and federal laws and requirements. Consequently, its inno-
vation requirements are high. In addition, it increases the need
for early planning and public involvement to determine what kind
of facilities are needed; it demands closer cooperation among all
public and private parties-at-interest; and introduces additional
participants into the decision process (siuch as land developers) .
Because of these requirements, the level of uncertainty with
regard to administering and monitoring redevelopment is also high,
but this is the case for all rehabilitation activities. Although
administrative costs cannot be estimated from existing studies, it
seems that they might be higher than for some other alternatives
simply because of the cost of being flexible (it generally takes
more people and time to deal with individual cases) and the ex-
tensive planning needed for the alternative to be implemented.
392
-------
If cooperative agreements are reached between participants,
the redevelopment to parks alternative could reduce energy-
environmental conflicts, especially since it can provide an out-
let for perceived recreational needs in the West. However, as
stated at the beginning of this discussion, the evaluation must
be viewed as exploratory since experience with this option is
limited to areas outside the West. Yet, as summarized in Table
7-16, the evaluation does provide at least a general characteri-
zation of costs and benefits. Based on these findings, redevelop-
ment of lands for public parks with recreational facilities appears
to pose few problems regarding its potential success, except where
states and counties view the parks as income sources; redevelop-
ment allows lands to be returned to productive uses within a rel-
atively short time period (2-3 years). Although economic costs
have not been pinpointed, they seem to parallel those for recla-
mation. Beneficiaries include the public-at-large, and possibly
energy companies when basic site preparation costs can be mini-
mized as a part of the redevelopment plan. Implementation will
require responsible public officials to be innovative in develop-
ing an institutional capability to administer the redevelopment
flexibly and responsibly.
D. A Comparison of the Reclamation and Redevelopment Alternatives
Table 7-17 summarizes the results of a comparison of the two
alternatives evaluated in this section. Several findings stand
out. First, there are some obvious trade-offs that can be made by
choosing one alternative rather than the other. Policymakers have
to decide which values and interests they want to promote. For
example, if getting lands back into production as soon as possible
is the value which ranks highest, redevelopment appears to offer a
significant advantage; and if minimizing cost of administration is
highly valued, reclamation appears to be the most appealing choice.
The analysis of these two alternatives and the findings summa-
rized in Table 7-17 also demonstrates that this analysis is incom-
plete, in part because of a lack of adequate information and re-
source limitations, but also because only one type of redevelopment
alternative was considered. What is reported can be interpreted to
imply that policymakers are faced with an either-or choice, either
reclaim to predevelopment use or redevelop for a recreational use.
Obviously, the choices are not this constrained. In fact, neither
reclamation nor redevelopment emerges as the "best" choice: rec-
lamation because there are areas where it will probably be imprac-
tical if not impossible; and redevelopment because there are lim-
its as to how much and where there is an additional recreational
need, and because it may also require some of the same things as
reclamation, for example, revegetation. But the point that the
results of our analysis leads us to make despite its limitations
is that it is not at all obvious that the current policy of most
states and the federal government is as well-informed a policy
choice as it might be. Given the high level of uncertainty about
393
-------
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being able to reclaim arid and semiarid lands successfully,
present policies seem to be an oversimplified policy response to
a complex problem. A blanket policy of returning disturbed lands
to their predevelopment uses largely ignores both the possibility
of land-use changes in the surrounding area due to energy and
other developments, and the possibility that large per-acre recla-
mation expenditures may be ineffective. In particular, the estab-
lished need for expanded recreational opportunities for energy-
related population increases challenges of the appropriateness of
a policy which emphasizes only reclamation. A more balanced pol-
icy would provide for determining local needs and basing the
choice between reclamation and redevelopment (and the specific
redevelopment use) on what the needs are determined to be.
Clearly there is a need for more knowledge in this problem
area and a need to review land-use and reclamation policies on a
continuing basis. The experience gained from current developments
will help to provide the knowledge base needed for this review as
will the numerous research efforts currently under way.
Finally, as noted above, current laws and regulations pretty
much ignore surface mining for other energy resources such as oil
shale and uranium. Given the quantity of those resources in the
West, this omission cannot continue unless we are prepared to have
these lands withdrawn from productive uses for an extended time
period.
398
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CHAPTER 8
HOUSING
EXECUTIVE SUMMARY
Population growth associated with western energy resource de-
velopment can have serious impacts on housing supply and quality
in nearby communities. The majority of growth-related housing
problems result because energy communities experience a rapid and
large population increase which quickly declines from the peak con-
struction level but remains higher than the predevelopment popula-
tion. The private housing market does not respond adequately to
meet the new housing needs created by energy development, and fed-
eral programs are not designed to deal with housing shortages in
rapid-growth areas. As a result, few new homes are built, avail-
able housing is very expensive, and the use of mobile homes usually
increases dramatically.
Impacts
The construction of energy facilities, especially large con-
version facilities, is a major cause of population changes. Both
the number of people required to construct and operate a facility
and the ratio of construction to operation workers are critical
causes of population-related impacts. Table 8ES-1 summarizes pop-
ulation changes associated with construction and operation of sev-
en conversion facilities. These changes contribute to several im-
pacts :
• Coal liquefaction and gasification facilities have the
largest peak population increases during construction,
resulting in about 14,000 to 15,500 new people in the
area of typical-sized facilities. These peak population
increases are nearly twice as much as those for power
plants and oil shale retorts.
• Construction booms can be large but are usually short-
lived, lasting from 3 years (uranium milling) to 8
years (power plants).
• The boom and bust cycle will be most dramatic for coal
gasification, power plants, and oil shale retorts, since
399
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TABLE 8ES-1: POPULATION INCREASES FROC ENERGY FACILITIES
FACILITY
Coal Gasification
(250 MMcfd)
Power Plant
(3,000 MWe)
Oil Shale Retort
(100,000 bbl/day)
Natural Gas Production
(250 MMcfd)
Coal Liquefaction
(100,000 bbl/day)
Crude Oil Production
(100,000 bbl/day)
Uranium Milling
(1,200 tpd)
PEAK POPULATIONS
CONSTRUCTION
14,040
7,620
8,040
5,100
15,660
11,760
270
OPERATION
2,360
1,760
2,600
3,160
12,240
12,200
440
RATIO OF
CONSTRUCTION
TO(~lDT^IJa^pT nw
U±rlj.KAJ. -L UW
POPULATIONS
6.0
4. 3
3..L
1. 6
1.3
1.0
0.6
MMcfd = million cubic feet per day bbl/day = barrels pc=r day
MWe = megawatt-electric tpd = tons per day
each of these facilities has a high ratio of construc-
tion to operation populations (Table 8ES-1). In con-
trast, coal liquefaction, crude oil production, and
uranium milling have relatively stable populations.
Western towns facing this rapid and fluctuating population
growth because of energy development are likely to experience
severe housing problems. Few homes are built and few, if any,
apartments or other housing types are avciilable in most energy-
impacted communities. Consequently, mobile homes are usually the
only alternative available to residents (see box, "Boomtown Hous-
ing") .
The Policy Context
Two critical factors combine with the impacts of energy re-
source developments to create these housing problems:
• Risks of housing construction in boomtowns are apparently
too great for lenders, developers, emd energy firms to
invest in these towns. Housing is traditionally a private
market service, and without direct financing of home con-
struction and mortgages by local financial institutions,
few new homes can be built.
400
-------
• Public sector programs have
not dealt effectively with
the housing problem and no
federal programs are di-
rected toward the specific
housing shortages in energy
related, rapid-growth situ-
ations. Although several
western states have estab-
lished housing finance pro-
grams designed to overcome
the lack of mortgage money
and federal assistance,
these actions have had lit-
tle effect on housing mar-
kets.
The reluctance of local
lenders and the resultant low
level of homebuilding activity
have had a dramatic effect on
housing prices, causing -further
housing shortages. The 1977
average price of new homes in
western energy-impacted commu-
nities was about 30 percent
higher than the national average
for nonmetropolitan areas, while
apartment rents (in towns where
they are available) were nearly
double the national median.
BOOMTOWN HOUSING
"During the Sweetwater County,
Wyoming boom's early stages, the
housing stock of the county was ap-
proximately doubled with 6,000 new
units. Fifty-five hundred of these
were mobile homes... The housing
market demand drove prices and rents
up, yet investors and developers
were skeptical of putting money in-
to boom-town housing. Even if they
had been willing, mortgage money
was not available for the typical
miner wishing to buy a home. This
same pattern is reproduced in most
boom-towns. Even when mining or
utility companies bring housing
into being, little or no provision
is made for the local service work-
ers who must also be accommodated
in a fast growing community."
—Gilmore, John S. Prepared state-
ment in U.S., Congress, Senate,
Committee on Environment and Public
Works. Inland Energy Development
Impact Assistance Act of 1977.
Hearings before the Subcommittee
on Regional and Community Develop-
ment, 95th Congress, 1st session,
August 2 and 27, 1977, pp. 266-67.
Energy developers have tried to alleviate housing shortages
for their employees by supporting mobile home parks (see box "Wright
Again"), single- and multifamily developments, and developing com-
pany towns such as Colstrip, Montana. Single-family subdivisions
are becoming more common, largely because of the overwhelming pref-
erence of families for such homes. Energy firms typically give
preference to their employees in allocating such housing, so out-
side contractors and service workers in nearby towns seldom benefit
from these actions.
Because of the failure of lenders, developers, and the public
sector to successfully address housing problems, several issues re-
lated to the overuse of mobile homes are likely to intensify as en-
ergy resource development increases:
• Dissatisfaction with mobile home parks will increase because
the homes are usually very close together, paved streets are
rare, park maintenance is often inadequate, and parks are
generally clustered outside of towns.
401
-------
• Mobile home ownership has
few of the financial advan-
tages of a conventional
single-family home. Except
in Wyoming, mobile homes
are considered personal
rather than real property,
and interest on personal
property loans tend to be
2 to 3 percent higher than
on mortgage loans. Also,
the value of mobile homes
often depreciates rapidly,
in contrast to single-
family homes which usually
increase in value.
• Mobile homes designated as
personal property contrib-
ute little to local govern-
ment tax roles. Thus,
housing problems are re-
lated to the inability of
local governments to pro-
vide adequate services and
facilities to expanding
populations.
Alternative Policies
WRIGHT AGAIN
Wright, Wyoming, has reap-
peared on the map after a 40-year
absence. A ranch house post of-
fice closed its doors during the
Depression, but the name has been
given to a mobile home park for
employees of ARCO's Black Thunder
Mine 40 miles south of Gillette.
By liviag closer to the mine than
they would have in Gillette, the
only town in Campbell County,
workers will commute shorter dis-
tances. But this alternative has
been at considerable cost to ARCO.
The telephone system which cost
$600,000 would have cost ARCO
nothing in Gillette. Families
still must drive to Gillette for
shopping and other services.
—"Town Revived in Coal Boom."
Denver Post, July 13, 1976; and
Enzi, Michael, Mayor of Gillette,
Wyoming. Personal communication.
Three overall objectives can be identified for improving hous-
ing in energy-impacted communities: (1) reduce the peak demand for
temporary housing; (2) use the existing housing market to increase
the quantity of housing financing and construction; and (3) improve
the quality of housing. General categories of alternatives and
specific alternatives for achieving these objectives are listed in
Table 8ES-2.
Policymakers can reduce housing demand by decreasing the size
of the labor force living on-site. Specific policy responses are
to adjust project schedules, encourage long-distance commuting, or
encourage facility siting choices which consider the impacts of
various technological and locational factors. These alternatives
generally add costs and delays to energy development; for example,
adjusting project schedules can add 5 percent to the annual con-
struction costs. Thus, energy firms are not likely to initiate
them without inducements, such as financial incentives or state
siting requirements. If construction workers commute to the site
from metropolitan areas, peak demands for temporary housing will
spread over a wider area and risks of overbuilding in any nearby
community is reduced.
402
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TABLE 8ES-2: POLICY OBJECTIVES AND ALTERNATIVES FOR HOUSING
POLICY OBJECTIVE
Reduce the peak de-
mand for tempo-
rary housing
Increase the quantity
of housing financ-
ing and construc-
tion through the
private market
Improve housing
qua] i ty
CATEGORY OF
ALTERNATIVES
Decrease the num-
ber of workers
living on-site
Increase the
quantity of
housing con-
struction
Diversify housing
mix
Improve mobile
home situ-
ation
SPECIFIC ALTERNATIVE
Adjust project schedules
Long distance commoting
Siting based on technological/locational
factors
Make state siting permits conditional on
housing
Stimulate industry investment in housing
Tax incentives for rental housing
Financial assistance for lenders and de-
velopers of apartments, condominiums,
and town houses
Change financial and tax structure for
mobile homes
Develop quality mobile home parks
Institute local land-use controls for all
areas of a county
To increase homebuilding activity, policymakers can make sit-
ing permits conditional on provision of adequate housing, stimulate
industry investment in housing, increase guarantees in the second-
ary mortgage market, and provide grants and loans to developers.
States can become involved in these actions, particularly through
siting procedures. However, siting permit requirements could in-
crease the costs and risks of development, unless all western
states adopted similar, requirements, thereby discouraging energy
developers from making investments only in some states.
Policymakers may also choose to improve housing quality by
diversifying the housing mix or improving the mobile home situa-
tion. Incentives can be given to local lenders, developers, and
renters to encourage the construction and purchase of alternative
housing types. Even if policymakers can successfully diversify
the housing choices available in western boomtowns, mobile homes
will still remain the predominant housing type in the immediate
future. Thus, a third category of alternatives is to improve the
quality of mobile homes. One specific alternative would change
the tax classification from personal to real property, making them
eligible for lower interest loans and slowing their depreciation
rate. Two other alternatives to improve the quality of mobile
homes are the development of quality mobile home parks, and the
extension of land-use controls to all areas of the county to facil-
itate control of mobile home parks.
403
-------
Findings
Three categories of alternatives to improve the housing situ-
ation have been evaluated in this policy analysis: decrease the
number of workers living on-site, increase the quantity of housing
construction, and increase the financing available for new home
construction. The results of our analysis suggest that if policy-
makers choose to reduce the number of workers living on-site, the
following results can be anticipated.
• Each of the specific alternatives—Long distance commuting,
adjusting project schedules, and siting considerations—
can effectively reduce the number of temporary workers
living on-site. As shown in Figure 8ES-1, if construction
schedules for coal gasification plants are extended from
five to eight years, peak employment and associated tem-
porary housing demand could be reduced by about one-third
during the construction phase. If workers were encouraged
to commute long distances, the reduction in local peak de-
mand for temporary housing would correspond to the propor-
tion of the work force commuting. Consideration of siting
8-Year
Construction ,.—,
Schedule E3
5-Year
Construction _
Schedule I I
1000 .
Years
Figure 8ES-1: Personnel Requirements For Coal
Gasification Plant Construction
Source: Carasso, M., et a1. The Energy Supply Planning
Model, Vol. 1. San Francisco, CaliFTi Bechtel Corporation,
1975, pp. 6-30 to 6-31.
404
-------
choices to match technologies and locations could avoid
many housing problems if the most labor-intensive tech-
nologies were prohibited in areas least capable of han-
dling population increases.
• Adjusting project schedules will have the highest eco-
nomic costs among these three alternatives. They include
increased interest costs for financing as well as infla-
tion of construction costs and consequent increases in
energy prices paid by consumers. The costs and risks of
the commuter and siting alternatives appear lower, since
neither would delay the start of energy production and
communities would face less risk of overbuilding for a
boom that failed to materialize.
• Adjusting project schedules raises questions about the
distribution of costs, risks, and benefits. Industry
would presumably pass increased construction and finan-
cing costs on to consumers. These consumers, especially
those outside the West, will likely resent having to pay
higher prices for energy. This situation is not neces-
sarily inequitable, since many westerners feel ultimate
energy users should pay the "full costs" of producing
the energy. However, the perceived inequities in cost-
sharing will probably increase interregional conflicts.
Second, increased construction times could delay goals
of the national energy plan to convert from oil and gas
to coal.
• The amount of new housing generated by these alternatives
is uncertain. Based on limited experience with housing
programs in the West, the alternative to siting permits
contingent upon industry agreement to provide additional
housing appears to be more effective than stimulating in-
vestment or providing guarantees.
• The costs of housing construction programs can range from
$5,000 per unit for site development alone, to more than
$30,000 per unit for house construction. On the other
hand, firms face the risk of holding unsold homes if en-
ergy development plans are delayed or cancelled.
• Siting permits conditional on industry provision of hous-
ing are especially flexible in dealing with energy devel-
opment impact needs of specific communities. Industry's
willingness to provide housing for its workers will de-
pend both on the advantages of the siting procedure and
on the incentives offered by the states and federal gov-
ernments. Generally, permit application procedures that
result in time and cost savings will be more acceptable
to industry.
405
-------
Conclusion
Many housing problems associated with western energy resource
development can be avoided if policymakers locate fewer workers in
small western communities. Long-distance commuting, adjustment of
project schedules, and discouraging the most labor-intxensive tech-
nologies in some areas could significantly redupe housing demands.
Housing shortages, and to a lesser extent, poor housing quality
could be mitigated by policies to increctse financing and construc-
tion funds.
•
This analysis also suggests that federal programs will be
more difficult to enact and implement than state or private sec-
tor responses. This is in part because federal programs charac-
teristically apply uniform policies, whereas the housing needs of
western boomtowns vary considerably by area and type of develop-
ment. It is also because interregional disputes, likely to be
worsened by housing issues, may make it more difficult to apply
federal programs to meet the needs of one region. This suggests
that western areas facing large population changes will increas- -
ingly need the assistance of state governments, energy developers,,
and private investors.
406
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CHAPTER 8
HOUSING
8 .1 INTRODUCTION
Energy resource development will create a housing shortage in
most energy-impacted communities. Housing will be inadequate,
both in quantity and quality; and housing costs will be greatly
inflated. These problems are a consequence of the population
growth associated with energy development. When energy develop-
ment begins, a large, rapid population increase occurs. This in-
crease, which often exceeds the predevelopment population of the
community, is usually larger during construction than during opera-
tion. This fluctuation exacerbates the housing problem.
In communities that have experienced these impacts, the pri-
vate market has not met the new needs created by energy develop-
ment, and current federal programs are not designed to deal with
housing shortages in rapid-growth areas. As a consequence, con-
ventional housing is expensive and difficult to obtain and mobile
homes provide a high percentage of the housing for newcomers.
Housing is but one component of the planning and growth man-
agement problems experienced when energy resources are developed
in the West.1 Other aspects of the growth management problem area
are discussed in Chapter 9. Most of these problems are a conse-
quence of population growth associated with energy development.
Consequently, a general overview of the growth phenomenon provides
a framework for both chapters.2
identification of local services, planning, and housing
as major problem areas is similar to those identified in Bolt,
R.M., et al. Boom Town Financing Study. Denver, Colo.: Colorado
Department of Local Affairs, 1976, Vol. 1, p. 36. See also U.S.,
Congress, Senate, Committee on Environment and Public Works. In-
land E'nergy Development Impact Assistance Act of 1977. Hearings
before the Subcommittee on Regional and Community Development,
95th Congress, 1st session, August 2 and 21, 1977.
2Related topics, such as energy transportation and energy
facility siting, are discussed in greater depth in Chapters 11 and
12.
407
-------
Most growth-related problems which communities in energy re-
source areas have to deal with result either from large and rapid
population increases or population fluctuations which result from
differences in the work force required during construction and op-
eration. Siting energy conversion facilities near mines results
in the greatest local impacts on western towns.1
The magnitude or rate of population growth that begins to af-
fect communities seriously is not easy to identify, even though
recent rapid growth in many western towns has been well documented.
An annual growth rate of five percent (which will double the popu-
lation in 14 years) tends to produce serious impacts for a commu-
nity.2 Rock Springs, Wyoming, for example, grew at an annual rate
of 19 percent from 1970 to 1974, and rapid growth has been a seri-
ous problem in many western towns (Table 8-1). Reipid growth is a
greater problem for small communities than for large towns, as
discussed in Section 8.I.I.C.
Private sector services such as housing and retailing tend
to lag behind local needs in rapid growth situations. Since tem-
porary, short-term construction activity does not provide a stable
market or tax base, it is difficult to associate energy develop-
ment with long-term urban and economic growth in western towns.
As a result, private sector parties to western energy development
have not responded to many of the needs of western communities and
their residents.
Housing is a particularly severe problem in western towns
affected by energy development. It has long been a private market
service, rather than one provided by government, but the usual
market forces are not providing the quantity or quality of housing
needed in many western communities. Home construction is going on
only in the larger towns, and mobile homes "are everywhere."3
*Energy facility locations outside the West, even when using
western resources, are not the focus of this problem area. These
broader issues are discussed in the analysis of energy facility
siting found in Chapter 12.
2Gilmore, J.S., and M.K. Duff. Boom Town Growth Management.
Boulder, Colo.: Westview Press, 1975, p. 2. See also U.S., Fed-
eral Energy Administration, Region VIII, Socioeconomic Program
Data Collection Office. Regional Profile: Energy Impacted Com-
munities. Lakewood, Colo.: Federal Energy Administration, 1977,
p. 20, for alternative criteria.
3Federal Interagency Team. The Energy Boom in Southwest Wyo-
ming. Washington, D.C.: U.S., Department of Housing and Urban
Development, 1976; U.S., Congress, Senate, Committee on Environment
and Public Works. Inland Energy Development Impact Assistance Act
of 1977. Hearings before the Subcommittee on Regional and Commu-
nity Development, 95th Congress, 1st session, August 2 and 27, 1977,
408
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TABLE 8-1:
POPULATION GROWTH IN SELECTED WESTERN
COMMUNITIES, 1970-1977
TOWN
Colorado
Carbondale
Craig
Grand Valley
Rifle
Montana
Hardin
North Dakota
Washburn
Utah
Cedar City
Huntington
Vernal
Wyoming
Douglas
Gillette
Moorcrof t
Rock Springs
Wheatland
ENERGY
RESOURCE IMPACT
Coal
Coal
Oil Shale
Oil Shale
Coal
Coal
Coal
Coal
Oil Shale
Coal, Uranium, Oil, Gas
Coal, Oil, Gas, Uranium
Coal, Gas, Oil, Uranium
Coal, Gas, Oil
Coal
POPULATION
1970
726
4,205
270
2,150
2,733
805
8,946
857
3,908
2,677
7,192
981
10,500
2,500
1977
1,600
6,657
500
3,500
3,637
1,400
12,000
1,700
5,200
7,200
10,20Qa
2,000
23,250
4,500
AVERAGE
ANNUAL INCREASE
PERCENT
17
8
12
9
5
10
5
14
5
25
6
15
17
11
Source: U.S., Federal Energy Administration, Region VIII, Socioeconomic
Program Data Collection Office. Regional Profile: Energy Impacted Commu-
nities. Lakewood, Colo.: Federal Energy Administration, 1977.
aThis estimate of Gillette's population is probably low. Other estimates
for 1977 put the city's population at 12,500-14,000, a growth rate since
1970 of 10-13 percent. See Campbell County Chamber of Commerce. Economic
Impact of Anticipated Growth: City of Gillette and Campbell County,
Wyoming. Gillette, Wyo.: Campbell County Chamber of Commerce, 1976.
Too-rapid population growth, local financial market conditions,
and uncertainty about the future of energy development all con-
tribute to a shortage of housing in all energy impact towns. The
national system of housing financing and construction is not work-
ing effectively in towns affected by western energy development.
409
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8.1.1 The Population Growth Impacts of Energy Resource Development
In attempting to identify combinations of energy technologies
and locations that would minimize or avoid impacts, several criti-
cal factors were identified as significantly affecting energy
development impacts,1 The factors that affect growth management
related impacts can be divided into technological and locational
factors. Critical technological factors include labor requirements
and scheduling; locational factors include community characteris-
tics such as size and location and the jurisdictional distribution
of revenues.
A. Labor Requirements
Many energy facilities require far more personnel during con-
struction than during operation. This is particularly true for
coal conversion and oil shale processing technologies whose opera-
tion is capital rather than labor intensive, and for which con-
struction requires over four times more personnel than operation
(Table 8-2). Larger numbers of workers, over half of whom bring
their families to construction jobs, rec[uire a range of local ser-
vices and facilities, including housing. In addition to the per-
sons directly employed in energy development, there is an indirect
population increase due to service and support personnel in nearby
towns. This further increases the need for housing and services.
As shown in Table 8-2, direct population impacts, as measured
by person-years, are generally greater for conversion than for
mining. In addition, there are large differences in the labor
intensity of conversion technologies, as indicated by the peak
construction employment and operation employment columns in Table
8-2. The construction/operation employment ratio also indicates
the boom-bust cycle associated with large construction projects.
More capital-intensive facilities involve larger booms in local
employment, but they also result in greater employment declines
when construction work is completed.
B. Scheduling
Scheduling can play a major role in determining the actual
magnitude of population impacts. For example, construction of a
coal gasification facility normally takes about five years. The
population impacts during construction are typical of large-scale
energy projects; thousands of people are needed for only a short
time (Figure 8-1-A). Simultaneous construction of two facilities
xWhite, Irvin L., et al. Energy From the West: A Progress
Report of a Technology Assessment of Western Energy Resource
Development. Washington, D.C.: U.S., Environmental Protection
Agency, 1977.
410