DATE:  September 27, 2010

Colonel William H. Graham, District Engineer
Pittsburgh District, US Army Corps of Engineers
2200 William S. Moorhead Federal Building
1000 Liberty Avenue Pittsburgh, PA 15222-4186

RE: Water Flow, Water Quality, Sediment Prevention and Erosion Control

We are writing on behalf of the WV/PA Monongahela River Area Watersheds Compact, a recently formed organization of volunteer watershed groups in northern West Virginia and southwestern Pennsylvania.  To date, some 18 groups have been represented at the two meetings held at the Morgantown (Hart Field) Airport.  Our focus is on water availability, water quality, sediment prevention and erosion control in this region, although other related issues have been identified as concerns of one or more of the groups.

The participation of the Pittsburgh District of the Army Corps of Engineers has been an important and valuable component of these meetings, as well as with the 13 Water Quality Forums and 5 Monongahela River Summits conducted by our Upper Monongahela River Association (UMRA).

In 2008, it was observed via the USGS monitoring system that TDS in the Monongahela River had reached levels not seen for decades.  This problem is coupled to the problems of low-flow conditions and has persisted into 2009 and 2010.  And, just last year in September of 2009 the Dunkard Creek disaster occurred in which TDS levels climbed into the tens of thousands expressed in the common terms of parts per million (ppm).  This TDS problem with low flow conditions resulted in an extensive blooming of “golden algae” over a distance of about 40 stream miles resulting in the death of approximately 22,000 fish and all of the 14 species of mussels that were resident in Dunkard Creek, a stream that crosses the Mason-Dixon line some six times.

Now we are faced with additional problems. The geologic formation known as the Marcellus shale has been identified as a huge source of natural gas (and some natural gas liquids) in southcentral New York state, in northeastern, central and southwestern Pennsylvania, as well as northern and central West Virginia.  For example, here in West Virginia the number of permitted wells in the Marcellus formation has tripled to over 1000 and in Pennsylvania this has ballooned to over 2000.  These are in addition to the continued development of conventional oil and gas wells in both States.  The State of New York has imposed a moratorium on Marcellus well drilling until a better environmental impact study can be completed and implemented.

Within the past month, it was announced that 22,000 acres of Marcellus lands were acquired for development in just one county of the Pittsburgh District, namely Wetzel County, WV.  And, additional gas pipelines and compressor stations have been scheduled for installation in our local counties of Pennsylvania and West Virginia, including a 20 inch line and a 24 inch line. Further, Consol Energy Inc., in March of this year purchased Dominion Resources Inc.’s natural gas and oil exploration and production business for $3.48 billion to expand its Marcellus Shale holdings. The sale includes rights to 491,000 acres in West Virginia and Pennsylvania, which will increase Consol’s natural gas reserves by 50 percent to 3 trillion cubic feet from 1.9 trillion. [CONSOL will become the largest natural gas producer in Appalachia.]

It is now certain that extra-ordinary attention is needed for the streams of the Pittsburgh District. The three primary problems are: (1) the disturbances to streams, stream beds and shorelines by heavy equipment due to stream crossings, construction of drilling pads, holding ponds and pipelines, as well as breaches in holding ponds, and other sources of pollutants, sediment and erosion, (2) excessive water withdrawals from sub-surface aquifers, from small local streams and from primary water bodies, as well as (3) degraded water quality due to the disposal of liquid wastes either directly into the streams or via leakage or migration of contamination.  The Monongahela River is already at a crisis point relative to total dissolved solids as are a number of the smaller streams in our region; and, without the imposition of some limitations beyond those now in place, the situation is clearly going to get much worse.

Immediate action is needed to prevent further harm to the streams and rivers in our region. While the continued monitoring of streams is of the highest importance, monitoring alone is not adequate to meet the challenges that we face. Hopefully, we can work together to protect the stream beds, our stream flows and their water quality while industry continues to develop the extensive valuable natural gas reserves in our region.  We look forward to continuing our working relationship, given how significant that has been in the past.

The urgency of our current situation requires strong leadership and action within the individual agencies of government.  Hopefully, substantial cooperation can take place involving the coal, oil and gas industries with meaningful public participation. Your help and cooperation are requested as we continue to work on these challenges.

Respectfully submitted,

Original signed by:

Barry G. Pallay, Co-Chair               Duane G. Nichols, Co-Chair

WV/PA Monongahela River Area Watersheds Compact
330 Dream Catcher Circle, Morgantown, WV 26508


cc:  WV/PA Watershed Groups, UMRA Board Members