UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

 WASHINGTON D.C. 20460

OFFICE OF THE ADMINISTRATOR

SCIENCE ADVISORY BOARD

March 25, 2011

EPA-SAB-11-005

The Honorable Lisa P. Jackson

Administrator

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460

Subject: Review of EPA’s Draft Report on Aquatic Ecosystem Effects of Mountaintop 

 Mining and Valley Fills

Dear Administrator Jackson:

EPA’s Office of Research and Development (ORD) requested that the Science Advisory 

Board (SAB) the Agency’s draft Reports, entitled The Effects of Mountaintop Mines and Valley 

Fills on Aquatic Ecosystems of the Central Appalachian Coalfields (i.e., Aquatic Ecosystem 

Effects Report, or ‘draft EPA Report’) and A Field-based Aquatic Life Benchmark for 

Conductivity in Central Appalachian Streams. The two EPA reports were developed by ORD’s 

National Center for Environmental Assessment at the request of EPA’s Office of Water (OW) 

and Regions 3, 4, and 5, and provide scientific information to support EPA’s actions on 

environmental permitting requirements for Appalachian surface coal mining operations. The 

SAB’s advice is provided in two SAB Reports. The present SAB Advisory document provides 

advice on the Aquatic Ecosystem Effects Report. A companion SAB report (EPA-SAB-11-006) 

discusses the draft Conductivity Benchmark Report. 

The draft EPA Aquatic Ecosystem Effects Report assesses the state of the science on the 

ecological impacts of Mountaintop Mining and Valley Fill (MTM-VF) operations on streams in 

the Central Appalachian Coal Basin. This basin covers about 12 million acres in West Virginia, 

Kentucky, Virginia, and Tennessee. The draft EPA report reviews literature relevant to 

evaluating five potential ecological consequences of MTM-VF operations: (1) impacts on 

headwater streams; (2) impacts on downstream water quality; (3) impacts on stream ecosystems; 

(4) the cumulative impacts of multiple mining operations; and (5) effectiveness of mining 

reclamation and mitigation. The impacts of MTM-VF operations on cultural and aesthetic 

resources were not included in the review. Since the draft EPA report focuses on ecological 

impacts, this SAB Report does not address potential human health impacts related to MTM-VF. 
2

The SAB was asked to comment on the assessments and analyses regarding the 

conceptual model, literature review, loss of headwater streams, downstream water quality and 

stream biota, cumulative ecological impacts, and effectiveness of restoration methods. The 

enclosed report provides the advice and recommendations of the SAB through the efforts of the 

SAB Mountaintop Mining Panel. The Panel found that the overall approach and scope for the 

draft EPA report is appropriate and comprehensive. The draft EPA report has characterized 

many of the potential ecological effects that may occur with the loss of headwater streams due to 

valley fill operations, and acknowledges the limited availability of data on this topic. However, 

the Panel has made recommendations for improving the draft EPA report, some highlighted 

below, and anticipates that EPA will consider incorporating these recommendations as it moves 

forward with the report.

• ORD used a conceptual model to formulate the problems relative to MTM-VF consistent 

with EPA’s Ecological Risk Assessment Guidelines. The Panel found the model to be 

comprehensive and inclusive of most appropriate parameters. The Panel suggested some 

modifications of the conceptual model, placement of the model early in the draft EPA 

report to serve as an organizing tool for the remainder of the document, and use of 

submodels to highlight different sections. 

• The Panel reviewed the literature used as the foundation of the draft EPA report and 

found it to be generally thorough and comprehensive, although there were some

important omissions. Additional literature was suggested by the Panel for improvement 

of future drafts of the draft EPA report. 

• The Panel believes the draft EPA report’s assessment of the impacts regarding the loss of 

headwater streams should be strengthened by recognizing the importance of the 

ecosystem services provided by headwater streams and improving the report’s discussion 

of the following issues associated with loss of headwater and forest resources: (1) lack of 

an estimate of the ultimate area to be affected by MTM-VF over different timeframes; (2) 

lack of an explicit inventory of the diversity of freshwater habitats affected; (3) lack of 

detail regarding the loss of biodiversity; and (4) need for improved precision and 

accuracy in assessing the effects of MTM-VF on ecosystem function. 

• Regarding the causal linkages between MTM-VF downstream water quality and effects 

on stream biota, the Panel agrees with the overall conclusions that there is strong 

evidence for a causal relationship between MTM-VF and downstream water quality. The 

Panel also agreed with the reliance on field data which strongly supports a causal 

relationship between MTM-VF and impaired aquatic communities. The Panel 

recommends that the draft EPA report clarify that total dissolved solids (TDS) and 

conductivity are relatively coarse indicators of water quality, and that EPA consider 

developing a more robust characterization of MTM-VF effluents and receiving waters 

with respect to ionic composition. The Panel also cautions EPA regarding the reliance on 

acute toxicity tests with non-native surrogate species for inferring consequences of 

changes in water quality associated with MTM-VF activities. In preparation of the draft 

report, EPA should conduct a formal threshold response analysis for macroinvertebrates 

and provide further emphasis on effects of selenium on aquatic organisms, due to the 
3

preliminary indications of a risk of effects at higher trophic levels in the aquatic 

community analysis. The draft EPA report should also further assess the potential effects 

of MTM-VF releases on freshwater mussels, salamanders, crayfish, and other aquatic 

life. 

• Regarding cumulative ecological impacts of MTM-VF, the Panel agrees that the 

published literature on the cumulative ecological impacts of filling headwater streams 

with mining waste on terrestrial and aquatic ecosystems is sparse. EPA should evaluate 

cumulative impacts for aquatic ecosystems from at least five perspectives: (i) spatial; (ii) 

temporal; (iii) river continuum; (iv) food web; and (v) synergistic. The Panel provided 

details regarding each of these perspectives, and recommends that EPA use both direct 

and indirect studies related to MTM-VF activities, studies associated with perturbations 

which differ from MTM-VF but have similar characteristics, as well as similar studies 

that address other issues (e.g., selenium, ionic strength). 

• Finally, the Panel believes that currently employed restoration methods are neither well 

defined nor well implemented, and that it is essential to understand restoration 

effectiveness, shortcomings, and potential for improvement in order to best manage 

impacts from MTM-VF. The Panel also agrees that there is little published information 

indicating that current restoration and mitigation practices are effective in offsetting 

surface mine impacts to streams. The Panel provided suggestions for improving the draft 

EPA report’s characterization of the effectiveness of currently employed restoration 

methods including: (i) the need to relate current limitations to historic progress; (ii) the 

need to define restoration in the context of improving impacted locations; and (iii) the 

need to relate restoration to both on-site reclamation and off-site mitigation. 

The SAB appreciates the opportunity to provide EPA with advice on this important 

subject. We look forward to receiving the Agency’s response and potential future discussions 

with the Agency.

Sincerely,

/signed/ /signed/

Dr. Deborah L. Swackhamer, Chair Dr. Duncan T. Patten, Chair

Science Advisory Board SAB Mountaintop Mining Panel 

Enclosure
i

NOTICE

This report has been written as part of the activities of the EPA Science Advisory Board (SAB),

a public advisory group providing extramural scientific information and advice to the 

Administrator and other officials of the Environmental Protection Agency. The SAB is 

structured to provide balanced, expert assessment of scientific matters related to problems facing 

the Agency. This report has not been reviewed for approval by the Agency and, hence, the 

contents of this report do not necessarily represent the views and policies of the Environmental 

Protection Agency, nor of other agencies in the Executive Branch of the Federal government, nor 

does mention of trade names of commercial products constitute a recommendation for use. 

Reports of the SAB are posted on the EPA Web site at http://www.epa.gov/sab.
ii

U.S. Environmental Protection Agency

Science Advisory Board

PANEL ON ECOLOGICAL IMPACTS OF MOUNTAINTOP 

MINING AND VALLEY FILLS 

(Mountaintop Mining Panel) 

CHAIR

Dr. Duncan Patten, Research Professor, Hydroecology Research Program , Department of Land 

Resources and Environmental Sciences, Montana State University, Bozeman, MT

MEMBERS

Dr. Elizabeth Boyer, Associate Professor, School of Forest Resources and Assistant Director, 

Pennsylvania State Institutes of Energy & the Environment, and Director, Pennsylvania Water 

Resources Research Center, Pennsylvania State University, University Park, PA

Dr. William Clements, Professor, Department of Fish, Wildlife, and Conservation Biology, 

Colorado State University, Fort Collins, CO

Dr. James Dinger, Head, Water Resources Section, Kentucky Geological Survey, University of 

Kentucky, Lexington, KY

Dr. Gwendelyn Geidel, Research Professor/Assistant Director, Dept of Earth & Ocean Sci/ 

School of the Environment, University of South Carolina, Columbia, SC

Dr. Kyle Hartman, Professor, Wildlife and Fisheries Resources, Division of Forestry and 

Natural Resources, West Virgnia University, Morgantown, WV

Dr. Robert Hilderbrand, Professor, Appalachian Laboratory, University of Maryland Center 

for Environmental Science, Frostburg, MD

Dr. Alexander Huryn, Professor, Department of Biological Sciences, College of Arts & Sci., 

University of Alabama, Tuscaloosa, AL

Dr. Lucinda Johnson, Center Director, Center for Water and the Environment, Natural 

Resources Reserach Institute, University of Minnesota Duluth, Duluth, MN

Dr. Thomas W. La Point, Professor, Department of Biological Sciences, University of North 

Texas, Denton, TX

Dr. Samuel N. Luoma, Senior Research Hydrologist, John Muir Institute of the Environment, 

University of California–Davis, Sonoma, CA
iii

Dr. Douglas McLaughlin, Principal Research Scientist, Western Michigan University, National 

Council for Air and Stream Improvement, Kalamazoo, MI

Dr. Michael C. Newman, Professor of Marine Science, School of Marine Sciences, Virginia 

Institute of Marine Science, College of William & Mary, Gloucester Point, VA

Dr. Todd Petty, Associate Professor, Wildlife and Fisheries, Forestry and Natural Resources, 

West Virginia University, Morgantown, WV

Mr. Edward Rankin, Environmental Researcher, Ohio University, Athens, OH

Dr. David Soucek, Associate Professional Scientist, Illinois Natural History Survey, Institute of 

Natural Resource Sustainability, University of Illinois at Urbana-Champaign, Champaign, IL

Dr. Bernard Sweeney, Director, President, Senior Research Scientist, Stroud Water Research 

Center, Avondale, PA

Dr. Philip Townsend, Associate Professor, Forest & Wildlife Ecology, College of Agriculture 

and Life Sciences, University of Wisconsin–Madison, Madison, WI

Dr. Richard Warner, Professor, Biosystems & Agricultural Engineering, College of 

Agriculture, University of Kentucky, Lexington, KY

SCIENCE ADVISORY BOARD STAFF

Mr. Edward Hanlon, Designated Federal Officer, 1200 Pennsylvania Avenue, NW

1400R, Washington, DC, Phone: 202-564-2134, Fax: 202-565-2098 (hanlon.edward@epa.gov)
iv

U.S. Environmental Protection Agency

Science Advisory Board

CHAIR

Dr. Deborah L. Swackhamer, Professor and Charles M. Denny, Jr., Chair in Science, 

Technology and Public Policy, Hubert H. Humphrey Institute of Public Affairs, and Co-Director 

of the Water Resources Center, University of Minnesota, St. Paul, MN

SAB MEMBERS

Dr. David T. Allen, Professor, Department of Chemical Engineering, University of Texas, 

Austin, TX

Dr. Claudia Benitez-Nelson, Associate Professor, Department of Earth and Ocean Sciences and 

Marine Science Program, University of South Carolina, Columbia, SC

Dr. Timothy Buckley, Associate Professor and Chair, Division of Environmental Health 

Sciences, College of Public Health, The Ohio State University, Columbus, OH

Dr. Patricia Buffler, Professor of Epidemiology and Dean Emerita, Department of 

Epidemiology, School of Public Health, University of California, Berkeley, CA

Dr. Ingrid Burke, Director, Haub School and Ruckelshaus Institute of Environment and Natural 

Resources, University of Wyoming, Laramie, WY

Dr. Thomas Burke, Professor, Department of Health Policy and Management, Johns Hopkins 

Bloomberg School of Public Health, Johns Hopkins University, Baltimore, MD

Dr. Terry Daniel, Professor of Psychology and Natural Resources, Department of Psychology, 

School of Natural Resources, University of Arizona, Tucson, AZ

Dr. George Daston, Victor Mills Society Research Fellow, Product Safety and Regulatory 

Affairs, Procter & Gamble, Cincinnati, OH

Dr. Costel Denson, Managing Member, Costech Technologies, LLC, Newark, DE

Dr. Otto C. Doering III, Professor, Department of Agricultural Economics, Purdue University, 

W. Lafayette, IN
v

Dr. David A. Dzombak, Walter J. Blenko Sr. Professor, Department of Civil and Environmental 

Engineering, College of Engineering, Carnegie Mellon University, Pittsburgh, PA

Dr. T. Taylor Eighmy, Vice President for Research, Office of the Vice President for Research, 

Texas Tech University, Lubbock, TX

Dr. Elaine Faustman, Professor, Department of Environmental and Occupational Health 

Sciences, School of Public Health and Community Medicine, University of Washington, Seattle, 

WA

Dr. John P. Giesy, Professor and Canada Research Chair, Veterinary Biomedical Sciences and 

Toxicology Centre, University of Saskatchewan, Saskatoon, Saskatchewan, Canada

Dr. Jeffrey Griffiths, Associate Professor, Department of Public Health and Community 

Medicine, School of Medicine, Tufts University, Boston, MA

Dr. James K. Hammitt, Professor, Center for Risk Analysis, Harvard University, Boston, MA

Dr. Bernd Kahn, Professor Emeritus and Associate Director, Environmental Radiation Center, 

School of Mechanical Engineering, Georgia Institute of Technology, Atlanta, GA

Dr. Agnes Kane, Professor and Chair, Department of Pathology and Laboratory Medicine, 

Brown University, Providence, RI

Dr. Madu Khanna, Professor, Department of Agricultural and Consumer Economics, 

University of Illinois at Urbana-Champaign, Urbana, IL

Dr. Nancy K. Kim, Senior Executive, Health Research, Inc., Troy, NY

Dr. Catherine Kling, Professor, Department of Economics, Iowa State University, Ames, IA

Dr. Kai Lee, Program Officer, Conservation and Science Program, David & Lucile Packard 

Foundation, Los Altos, CA

Dr. Cecil Lue-Hing, President, Cecil Lue-Hing & Assoc. Inc., Burr Ridge, IL

Dr. Floyd Malveaux, Executive Director, Merck Childhood Asthma Network, Inc., Washington, 

DC

Dr. Lee D. McMullen, Water Resources Practice Leader, Snyder & Associates, Inc., Ankeny, 

IA
vi

Dr. Judith L. Meyer1

 1 Did not participate in this review.

, Distinguished Research Professor Emeritus, Odum School of Ecology, 

University of Georgia, Lopez Island, WA

Dr. James Mihelcic, Professor, Department of Civil and Environmental Engineering, University 

of South Florida, Tampa, FL

Dr. Jana Milford, Professor, Department of Mechanical Engineering, University of Colorado, 

Boulder, CO

Dr. Christine Moe, Eugene J. Gangarosa Professor, Hubert Department of Global Health, 

Rollins School of Public Health, Emory University, Atlanta, GA

Dr. Horace Moo-Young, Dean and Professor, College of Engineering, Computer Science, and 

Technology, California State University, Los Angeles, CA

Dr. Eileen Murphy, Grants Facilitator, Ernest Mario School of Pharmacy, Rutgers University, 

Piscataway, NJ

Dr. Duncan Patten, Research Professor, Department of Land Resources and Environmental 

Sciences, Montana State University, Bozeman, MT

Dr. Stephen Polasky, Fesler-Lampert Professor of Ecological/Environmental Economics, 

Department of Applied Economics, University of Minnesota, St. Paul, MN

Dr. Arden Pope, Professor, Department of Economics, Brigham Young University, Provo, UT

Dr. Stephen M. Roberts, Professor, Department of Physiological Sciences, Director, Center for 

Environmental and Human Toxicology, University of Florida, Gainesville, FL

Dr. Amanda Rodewald, Professor, School of Environment and Natural Resources, The Ohio 

State University, Columbus, OH

Dr. Jonathan M. Samet, Professor and Flora L. Thornton Chair, Department of Preventive 

Medicine, University of Southern California, Los Angeles, CA

Dr. James Sanders, Director and Professor, Skidaway Institute of Oceanography, Savannah, 

GA

Dr. Jerald Schnoor, Allen S. Henry Chair Professor, Department of Civil and Environmental 

Engineering, Co-Director, Center for Global and Regional Environmental Research, University 

of Iowa, Iowa City, IA

Dr. Kathleen Segerson, Professor, Department of Economics, University of Connecticut, Storrs, 

CT
vii

Dr. Herman Taylor, Professor, School of Medicine, University of Mississippi Medical Center, 

Jackson, MS

Dr. Barton H. (Buzz) Thompson, Jr., Robert E. Paradise Professor of Natural Resources Law 

at the Stanford Law School and Perry L. McCarty Director, Woods Institute for the 

Environment, Stanford University, Stanford, CA

Dr. Paige Tolbert, Associate Professor, Department of Environmental and Occupational Health, 

Rollins School of Public Health, Emory University, Atlanta, GA

Dr. John Vena, Professor and Department Head, Department of Epidemiology and 

Biostatistics, College of Public Health, University of Georgia, Athens, GA

Dr. Thomas S. Wallsten, Professor and Chair, Department of Psychology, University of 

Maryland, College Park, MD

Dr. Robert Watts, Professor of Mechanical Engineering Emeritus, Tulane University, 

Annapolis, MD

Dr. R. Thomas Zoeller, Professor, Department of Biology, University of Massachusetts, 

Amherst, MA

SCIENCE ADVISORY BOARD STAFF

Dr. Thomas Armitage, Designated Federal Officer, U.S. Environmental Protection Agency, 

Washington, DC

Dr. Angela Nugent, Designated Federal Officer, U.S. Environmental Protection Agency, 

Washington, DC
viii

Table of Contents

1. EXECUTIVE SUMMARY .................................................................................................. 1

2. INTRODUCTION................................................................................................................. 6

2.1. BACKGROUND.................................................................................................................. 6

2.2. CHARGE TO THE PANEL.................................................................................................... 6

3. RESPONSE TO THE CHARGE QUESTIONS ................................................................ 8

3.1. CONCEPTUAL MODEL ...................................................................................................... 8

3.2. LITERATURE REVIEW..................................................................................................... 13

3.3. LOSS OF HEADWATER STREAMS .................................................................................... 16

3.4. DOWNSTREAM WATER QUALITY AND STREAM BIOTA .................................................. 23

3.5. CUMULATIVE ECOLOGICAL EFFECTS ............................................................................. 31

3.6. EFFECTIVENESS OF RESTORATION METHODS................................................................. 40

LITERATURE CITED ............................................................................................................ R-1

APPENDIX A: EPA’S CHARGE TO THE PANEL............................................................ A-1

APPENDIX B: EPA’S MOUNTAINTOP MINING ASSESSMENT CONCEPTUAL 

MODEL ..................................................................................................................................... B-1
ix

Abbreviations and Acronyms 

AMD Acid Mine Drainage

Ca Calcium

CWA Clean Water Act

DOE U.S. Department of Energy

EPA U.S. Environmental Protection Agency

EPT Ephemeroptera, Plecoptera, Tricoptera

HCO3 Bicarbonate

LDOM Labile dissolved organic matter

Mg Magnesium

MTM-VF Mountaintop Mining and Valley Fill

ORD EPA Office of Research and Development

SAB EPA Science Advisory Board

Se Selenium

SMCRA Federal Surface Mining Control and Reclamation Act of 1977

SO4 Sulfate

TDS Total Dissolved Solids

μS/cm Microsiemens per centimeter

USGS U.S. Geological Survey
1

1. EXECUTIVE SUMMARY

EPA’s Office of Research and Development (ORD) requested that the Science Advisory 

Board (SAB) review the Agency’s draft Reports, entitled The Effects of Mountaintop Mines and 

Valley Fills on Aquatic Ecosystems of the Central Appalachian Coalfields and A Field-based 

Aquatic Life Benchmark for Conductivity in Central Appalachian Streams. These draft EPA 

reports were developed by ORD’s National Center for Environmental Assessment upon the 

request of EPA’s Office of Water and Regions 3, 4, and 5, and help provide scientific 

information to support EPA’s actions on environmental permitting requirements related to 

Appalachian surface coal mining operations. 

This SAB Advisory focuses on EPA’s draft Aquatic Ecosystem Effects Report. EPA

requested that the SAB comment on various aspects of the Aquatic Ecosystem Effects Report,

including the draft EPA report’s assessments and analyses regarding the conceptual model, 

literature review, loss of headwater streams, downstream water quality and stream biota, 

cumulative ecological impacts, and effectiveness of restoration methods. The enclosed SAB 

report provides the advice and recommendations of the SAB Panel regarding the draft EPA 

report. Since the draft EPA report focuses on ecological impacts, this SAB Report does not 

address potential human health impacts related to MTM-VF. 

In general, the SAB found that EPA’s overall approach and scope for the draft EPA 

report is appropriate and comprehensive. Several areas, however, can be enhanced and focused. 

Where data limitations were apparent, the SAB notes whether EPA could rely on existing 

publications or previous efforts to research or collect such data, whether EPA could consider 

gathering and evaluating existing data within published literature, or whether EPA could 

consider conducting future research efforts to produce this data. 

While a more detailed description of the technical recommendations is described in this 

SAB Report, the key points and recommendations are highlighted below. 

This SAB Report often provides similar responses to more than one Charge Question. 

This is because the draft EPA Report is integrated with related topics and the Charge Questions 

overlap with each other. 

Conceptual Model

The draft EPA report uses a conceptual model to formulate the problem, and EPA 

requested the SAB to comment on whether the model included the key direct and indirect 

ecological effects of MTM-VF. Overall, the Panel considered the conceptual model to be 

comprehensive and relatively complete regarding direct consequences of MTM-VF. Whether 

any parts of the conceptual model addressed indirect consequences of MTM-VF is unclear, and 

EPA should consider clarifying the text of the report and model regarding specific indirect 

consequences of MTM-VF. 
2

Several suggestions for additional components to be added to the model focused on the 

following: 

• Impacts resulting from loss or alteration of upland and riparian systems; 

• Activities and outcomes of the reclamation process; 

• Additional metrics to represent functional endpoints (e.g., impacts on functional aspects 

of stream ecosystems);

• Hyporheic zone modification and resulting impacts; 

• Recognition of importance of antecedent geologic conditions; and

• Additional modifying factors such as geology, landscape context (e.g., rain shadow), and 

potential biological productivity in streams. 

The Panel recommends that a relatively simple/general ‘pictorial’ conceptual model be 

placed near the beginning of the draft EPA report and used as an organizing tool for the 

remainder of the document. The Panel suggests that distinct, more detailed sub-components of 

the model representing the dominant activities and resulting impacts be incorporated into each 

section of the text where appropriate. The Panel also believes the model’s causal diagram should 

depict levels of uncertainty. 

The Panel provides several additional suggestions for improving the model. EPA should 

clarify the direction of impacts indicated in the model (e.g., note whether water quality impacts 

are increasing or decreasing during events or seasons). EPA should reassess whether it is 

appropriate to classify impacts with directional arrows or with changes (“∆”), especially for 

those stressors that have shown increased as well as decreased changes for the few sites from 

which data are available. EPA should also clarify the description of hydrological effects, and 

discuss why some processes are stressors and others are response variables in the model. Also, 

the component on metals and especially selenium (Se) contained inaccuracies (e.g. no 

connection to the food web for Se) which should be corrected. 

Literature Review

ORD requested SAB to consider whether the draft EPA report includes the most relevant 

peer-reviewed, published literature on this topic. In general, the Panel believes the draft EPA 

report includes much of the key literature available at the time the draft EPA report was written 

related to MTM-VF within the bounds defined by EPA for the draft EPA report. Several 

suggestions were provided by the Panel for improving the literature base for the draft EPA report 

(e.g., literature on Se, impacted biota other than aquatic macroinvertebrates, and stream 

conductivity). Headwater streams should be better defined through citations to available 

literature, and clarification provided regarding the degree that that literature and supporting data 

are related to ephemeral, intermittent or perennial streams. This relates to accurate accounting of 

miles of ephemeral vs. intermittent vs. perennial streams. Additional references that should be 

considered are included within the attached References.
3

Loss of Headwater Streams 

ORD requested the SAB to comment on whether the draft EPA report appropriately 

characterized the ecological effects of the loss of headwater streams. The Panel believes the 

draft EPA report has characterized most of the potential ecological effects that may occur 

associated with the loss of headwater streams due to valley fill operations, and acknowledged the 

limited available data on this topic. However, because changes in watershed land use, including 

loss of headwater and forest resources, can greatly influence most headwater ecosystem services, 

EPA’s assessment of the impacts regarding the loss of headwater streams can be strengthened by 

improving the discussion on the following issues associated with loss of headwater and forest 

resources: (1) lack of estimate of ultimate areas to be affected by MTM-VF over different 

timeframes, (2) lack of an explicit inventory of the diversity of freshwater habitats affected, (3) 

lack of depth to the assessment of the loss of biodiversity, and (4) need for improved precision 

and accuracy in assessment of effects of MTM-VF on ecosystem function. The degree to which 

ephemeral and intermittent headwater streams were adequately mapped by traditional data 

sources (e.g., U.S. Geological Survey topographic maps) limits the usefulness of the cumulative 

impacts assessment. 

Downstream Water Quality and Stream Biota

ORD requested the SAB comment on the causal linkages between MTM-VF, 

downstream water quality and effects on stream biota. With a few important caveats, the Panel 

agrees with EPA’s overall conclusions that there is strong evidence for a causal relationship 

between MTM-VF and downstream water quality. The draft EPA report links these changes in 

water quality to benthic communities, and the evidence assessed from various studies showing 

changes in ion concentrations associated with MTM-VF is very compelling. Several suggestions 

were provided by the Panel for improving the discussion on causal linkages between MTM-VF 

downstream water quality and effects on riparian and stream biota and functions. 

Regarding the use of conductivity as a surrogate stressor, the Panel recommends that the 

draft EPA report should acknowledge that measures such as total dissolved solids (TDS) or 

conductivity are relatively coarse indicators of water quality because the relative effects of 

cations and anions varies greatly. Although conductivity provides an integrated measure of 

major cations and anions that may cause stress, EPA should consider developing a more robust 

characterization of MTM-VF effluents with respect to ionic composition, including an analysis 

that explores the role of the matrix ions as well as trace constituents, since it would improve the

understanding of toxicological effects associated with releases from MTM-VF activities. 

The Panel identified several limitations of laboratory toxicity tests, and provided 

suggestions for improving the discussion on such tests within the draft EPA report. The Panel 

also generally agreed that the field data provided strong support for a causal relationship between 

MTM-VF and impaired aquatic communities. Inferences from field data combined with 

available information on how TDS increases downstream from MTM-VF strongly support

EPA’s conclusions. The draft EPA report should provide further emphasis on the effects of Se 

on aquatic organisms and additional information on the potential effects of MTM-VF releases on 

freshwater mussels, salamanders, crayfish, and other aquatic life. EPA should further consider 
4

the potential impacts of disturbances other than MTM-VF in the region. It would also be useful 

to conduct a formal threshold analysis on macroinvertebrate sensitivity to MTM-VF releases, 

including an analysis of the effects on Ephemeroptera (mayflies) relative to other 

macroinvertabrates. The Panel also made specific suggestions regarding other analyses that 

would enhance the basis of the draft EPA report’s conclusions. EPA should consider using 

direct measurements of functional feeding groups to assess stream function, assess MTM-VF 

effects on downstream hydrology, and provide a deeper discussion of the relationship among 

headwater streams, MTM-VF operations, and mitigation as related to hyporheic communities. 

Cumulative Ecological Impacts

ORD requested the SAB to comment on whether the draft EPA report accurately 

describes the state of knowledge on cumulative ecological impacts of MTM-VF. The Panel 

agrees with EPA that the published literature is sparse with regard to the cumulative ecological 

impacts on terrestrial and aquatic ecosystems of filling headwater streams with mining 

overburden. The Panel’s comments primarily focus on definitions and the framing of issues 

covered within the draft EPA report. Perhaps EPA could conduct an enhanced, more productive 

effort to find or generate relevant information which addresses the cumulative effects aspect of 

the topics covered within the draft EPA report. The search for available, published data for use 

in evaluating the extent (spatial and temporal) and significance of cumulative impacts can and 

should involve both direct and indirect studies related to MTM-VF activities as well as those 

associated with perturbations which differ from MTM-VF but have similar characteristics (e.g., 

peer reviewed papers of studies designed for a different purpose). Such efforts would not require 

producing new research and data collection.

Aquatic ecosystem cumulative impacts should be evaluated from at least five 

perspectives: (i) spatial; (ii) temporal; (iii) river continuum; (iv) food web; and (v) synergistic. 

The Panel provided details regarding each of these perspectives, and included suggestions for 

further assessing these perspectives:

• Spatial perspectives: EPA should gather relevant information to consider potential 

spatial effects. From this perspective, relevant information would be any detailed 

physical, chemical, or biological stream data at or near two or more of the MTM-VF 

operations within a given watershed as well as two or more points in the drainage 

downstream from all the point source operations. EPA should also gather and assess 

relevant information on the area and volume of earth movement associated with MTMVF operations, the percent change in vegetation (e.g., land clearing) that has occurred in 

a watershed from these operations based on pre-mine vs. post-mine land use, and the 

proximity of these activities to the streams. 

• Temporal perspectives: EPA should assess data collected before, during, and after one 

or more MTM-VF operations within a given watershed, with the emphasis on a time 

series of measurements taken both “before” and “after” for a given parameter. 

• River continuum perspectives: EPA should consider modeling the production, 

downstream routing, and reutilization of organic matter or nutrients; more closely 

consider cumulative impacts on flow paths and residence times of water; and assess 
5

whether MTM-VF affects flow and flow regimes downstream and, if so, how such 

changes affect aquatic life.

• Food web perspectives: EPA should evaluate cumulative food web impacts in 

published data on community structure, and assess tissue analyses archived or of freshly 

collected samples of taxa representing certain trophic levels. 

• Synergistic perspectives: EPA should consider assessing certain stressors using existing 

data to help assess whether the impacts associated with MTM-VF interact among 

stressors associated with mixed land use in the watershed. EPA should also assess 

whether potential bioaccumulative effects to the food web appear to be additive or 

multiplicative, or linear or non-linear. 

The Panel also suggests that EPA consider both positive and negative cumulative impacts 

(e.g., fragmentation from multiple forest losses) associated with new, altered terrestrial 

ecosystems within the analysis.

Effectiveness of Restoration Methods

ORD also requested the SAB to comment on whether the draft EPA report appropriately 

characterizes the effectiveness of currently employed restoration methods. In response, the 

Panel believes that currently employed restoration methods are neither well defined nor well 

implemented, and that it is essential to understand restoration effectiveness, shortcomings, and 

potential for improvement in order to best manage impacts from MTM-VF. The Panel also 

agrees with EPA’s contention that there is little published evidence that current restoration 

approaches are effective in recovering aquatic ecosystem functions that were lost as a result of 

MTM-VF. 

The review of restoration effectiveness would be improved by reorganizing this section 

of EPA’s draft report under two major subheadings: “On-Site Reclamation” and “Off-Site 

Mitigation, citing certain available literature on the topic of restoration effectiveness, and 

identifying the most important shortcomings of current reclamation processes related to aquatic 

resources. EPA should define restoration objectives, show how restoration can be used within 

the permitting process to ensure maintenance and improvement of watershed scale conditions, 

and discuss the relevance of state water quality standards and spatial and temporal boundaries 

associated with meeting restoration objectives. The Panel also provides various 

recommendations for improving the discussion on several important issues relating to the 

Federal Surface Mining Control and Reclamation Act of 1977 (SMCRA), off and on site 

activities, hydrologic processes, aquatic resources, and restoration within the draft EPA report. 

Suggestions for research needs and additional references that should be considered are also 

provided. 
6

2. INTRODUCTION

2.1. Background

EPA’s Office of Research and Development (ORD) requested that the Science Advisory

Board (SAB) review the Agency’s draft Reports, entitled The Effects of Mountaintop Mines and 

Valley Fills on Aquatic Ecosystems of the Central Appalachian Coalfields (draft EPA report) and 

A Field-based Aquatic Life Benchmark for Conductivity in Central Appalachian Streams. The 

reports were developed by ORD’s National Center for Environmental Assessment at the request 

of EPA’s Office of Water (OW) and Regions 3, 4, and 5, and provide scientific information to 

support EPA’s actions on environmental permitting requirements for Appalachian surface coal 

mining operations. 

The Panel met on July 20-22, 2010 to review and provide advice to ORD on the scientific 

adequacy, suitability and appropriateness of the two ORD reports. The Panel reviewed the draft 

EPA reports and background materials provided by ORD, and considered public comments and 

oral statements that were received. 

The Panel’s advice is provided in two SAB Reports. The Panel held follow-up public 

teleconference calls on October 20, 2010 and October 26, 2010 to discuss the two external draft 

SAB Reports dated September 28, 2010. The updated external draft SAB Reports dated 

November 8, 2010 and December 28, 2010 were submitted to the chartered SAB for discussion 

at the January 19, 2011 public teleconference. The external draft SAB Reports were revised 

based on comments received from the Board. The present SAB Advisory document provides 

advice on the Aquatic Ecosystem Effects Report. A companion SAB report (EPA-SAB-11-006) 

discusses the draft Conductivity Benchmark Report. 

The information in the draft Aquatic Ecosystem Effects Report will assist OW and the 

Regions to support EPA’s actions on environmental permitting requirements for Appalachian 

surface coal mining projects, in coordination with federal and state regulatory agencies. Using 

the best available science and applying existing legal requirements, EPA issued comprehensive 

guidance on April 1, 2010 that sets conductivity benchmarks for preventing significant and 

irreversible damage to Appalachian watersheds at risk from mining activities. 

In this SAB Report there often appear to be repetitive responses to Charge Questions. In 

some cases, similar topics are discussed under more than one Charge Question. This results 

from both the integrated nature of the draft EPA Report and an overlap in interpretation of the 

Charge Questions. 

2.2. Charge to the Panel

The Agency’s Charge to the Panel (Appendix A) included a total of 14 questions, of 

which the following 6 relate to the Aquatic Ecosystem Effects Report:
7

Charge Question 1: The Mountaintop Mining Assessment uses a conceptual model 

(Figure 12 of the draft document) to formulate the problem consistent with EPA’s 

Ecological Risk Assessment Guidelines. Does the conceptual diagram (i.e., model)

include the key direct and indirect ecological effects of MTM-VF? If not, please indicate 

the effects or pathways that are missing or need additional elucidation.

Charge Question 2: This report relied solely on peer-reviewed, published literature and 

the 2005 Final Programmatic Environmental Impact Assessment on Mountaintop 

Mining/Valley Fills. Does this assessment report include the most relevant peerreviewed, published literature on this topic? If not, please indicate which references are 

missing.

Charge Question 3: Valley fills result in the direct loss of headwater streams. Has the 

review appropriately characterized the ecological effects of the loss of headwater 

streams?

Charge Question 4: In addition to impacts on headwater streams, mining and valley fills 

affect downstream water quality and stream biota. Does the report effectively 

characterize the causal linkages between MTM-VF, downstream water quality, and 

effects on stream biota?

Charge Question 5: The published literature is sparse regarding the cumulative 

ecological impacts of filling headwater streams with mining waste (spoil). Does the 

review accurately describe the state of knowledge on cumulative ecological impacts of 

MTM-VF? If not, how can it be improved?

Charge Question 6: The Surface Mining Control and Reclamation Act and its 

implementing regulations set requirements for ensuring the restoration of lands disturbed 

by mining through restoring topography, providing for post-mining land use, requiring 

re-vegetation, and ensuring compliance with the Clean Water Act. Does the review 

appropriately characterize the effectiveness of currently employed restoration methods?
8

3. RESPONSE TO THE CHARGE QUESTIONS

3.1. Conceptual Model

Charge Question 1: The Mountaintop Mining Assessment uses a conceptual model (Figure 

12 of the draft document) to formulate the problem consistent with EPA’s Ecological Risk 

Assessment Guidelines. Does the conceptual model include the key direct and indirect 

ecological effects of MTM-VF? If not, please indicate the effects or pathways that are 

missing or need additional elucidation.

General Comments

The Panel engaged in a thoughtful and vigorous discussion about the conceptual model. 

The model’s diagram is Figure 12 of EPA’s draft report, and this diagram is attached as 

Appendix B of this SAB Report. Overall, the conceptual model was viewed as being 

comprehensive and relatively complete regarding direct consequences of MTM-VF. It does not 

appear that any parts of the conceptual model addressed indirect consequences of MTM-VF, and 

EPA should consider amending the text of the report and model to address specific indirect 

consequences of MTM-VF. Specific suggestions for additional components to be added to the 

model focused on the following:

• impacts resulting from loss or alteration of upland and riparian systems were not 

well-represented on the left side of the diagram; 

• activities and outcomes of the reclamation process were not addressed in the diagram 

at all (e.g., hyporheic zone modification, potential nutrient runoff from fertilized 

soils, sediment runoff from unprotected soils, altered flow regime, altered riparian 

structure and function, and, potentially, conversion from forest to grassland habitat);

• index of biotic quality is the only endpoint represented in the diagram, and other 

metrics could potentially be used that better represent functional endpoints (e.g., 

altered food web and energy flow). Even though data regarding functional endpoints 

specifically related to mining impacts are not well represented in the literature, 

substantial recent information about mining and other similar impacts on functional 

aspects of stream ecosystems are well represented and should be included in the 

diagram (e.g., functional links between activities and different components of 

hydrology such as altered base flow, peak flow, altered flow regime, flood frequency, 

and subsequent responses). Example references for this information include 

references for the Appalachian Regional Reforestation Initiatives (ARRI), including 

the reports that are prepared by the U. S. Forest Service and U. S. Department of 

Energy, and Gingerich, 2009. Such data assessment efforts would not require 

producing new research or conducting new data collection efforts, but rather would 

rely on existing publications or previous efforts to research or collect such data.

• hyporheic zone modification and resulting impacts were not well represented;

• the importance of antecedent geologic conditions is not adequately recognized; 
9

• additional modifying factors such as geology, landscape context (e.g., rain shadow), 

and potential biological productivity in streams could be helpful if included in the 

diagram; and

• risks to the food web from Se also need to be more clearly differentiated, perhaps in 

the diagram. 

There was agreement within the Panel that the document would benefit from placing the 

conceptual model near the beginning of the draft EPA report and using it as an organizing tool 

for the remainder of the document. EPA is encouraged to think about ways to point out what is 

more important and what is less important within the model itself. For example, first order 

impacts (e.g., related to Se or conductivity) should be highlighted, since those were the 

constituents deemed to have the largest impacts. The conceptual model also should suggest the 

relative importance of different issues or impacts and how the risks differ (e.g., the risks due to 

exposure to nickel [Ni] are not the same as those related to Se exposure). Further, near-field and 

far-field effects could be quite different depending on the flows and their interactions with the 

hyporheic and riparian zones. 

The Panel believes the conceptual model is so complex that its utility is somewhat 

limited. The style of this conceptual model, and the level of information portrayed, do not 

clearly portray the potential multi-scale (temporal, spatial) effects of mountaintop mining. The 

Panel recommends that a relatively simple/general ‘pictorial’ conceptual model be placed near 

the beginning of the draft EPA report and used as an organizing tool for the remainder of the 

document. The model should be separated into distinct sub-components representing the 

dominant activities and resulting impacts, and these be incorporated into each section of the text 

where appropriate. The simple/general “pictorial model” should be used at the beginning of the 

draft EPA report to indicate the most important/basic ecologically relevant features of a MTMVF operation, while more detailed “flow diagram” models (similar to, but only showing relevant 

subsets of Figure 12, perhaps with direction, uncertainty, etc represented) could be presented 

where specific issues are addressed later in the report. EPA should then consider providing the 

complete model as an Appendix, presented in a manner that facilitates viewing (e.g., larger 

format paper). Also, a pictorial diagram illustrating potential causes and effects, from upland 

landscapes to streams to downstream effects, may be more effective at conveying the multiscale, cumulative impacts of an example mining operation. 

In addition to the above comments, the causal model should depict levels of uncertainty. 

For example, the model should represent topics with substantial data and coherent results versus 

hypothesized outcomes with less substantiating evidence. Although indirect as well as direct 

pathways, temporal as well as spatial dimensions, and near-field versus far-field impacts would 

enhance the utility of the model, they might be difficult to depict. These dimensions should be 

addressed explicitly in the text if they cannot be depicted in the diagram. 

Specific Comments

The model is presented in two parts, one for mountaintop removal and one for valley fill, 

which the Panel believes is an acceptable approach. The removal portion addresses loss of 

forests, riparian areas, and issues with soil (e.g., bare soil areas, erosion). The valley fill portion 
10

indicates only one initial major impact - stream burial. Since valley fills may bury more than 

just streams, the draft EPA report should discuss concerns associated with the broader riverine 

system.

EPA should note and discuss interactions that may exist between the mountaintop 

removal and valley fill parts of the model. For example, materials removed in a given MTM 

operation may be deposited in an adjacent VF, and it may be useful to present whether and how 

such mass balance dynamics associated with MTM-VF operations may result in ecological 

consequences within local scale watersheds where MTM-VF activities are occurring. 

Also, the model refers to “headwater habitat” loss as an aspect of stream burial. 

However, in a riverine system, lost habitats include “instream,” riparian floodplain, and adjacent 

uplands, and the draft EPA report should clearly distinguish these lost habitats, since headwater 

taxa decline may be quite different among these components of the riverine system. The type of 

stream depicted in the diagram (e.g., perennial, ephemeral) should be made clear in the text, and 

the terminology within the diagram should reflect the language within the text. Where pathways 

differ for different hydrologic stream types (which should be defined in the text), the stream type 

should be explicitly identified. 

• The draft EPA report should define what is meant by headwater taxa and clarify why 

headwater taxa are considered differently from other aquatic taxa, amphibians and 

macroinvertebrates in the diagram. If specific components of the headwater assemblages 

are impacted by the processes in the model, they should be identified as such and 

distinguished from “aquatic” taxa in general.

• The directionality of the impacts through assignment of arrows in the diagram may not be 

accurate in every case or over all timescales (e.g., variability in an element of water 

quality, shifting up and down during events or seasons). Text should be added to the 

caption and narrative indicating that the directionality is considered to be a typical, 

important, and potential response over average time scales impacted by the operation. 

• The use of arrows versus changes (“∆”) should be reviewed, especially for those stressors 

that have shown increased as well as decreased changes for the few sites from which data 

are available.

• The draft EPA report should clarify why some processes are stressors and others are 

response variables. For example, headwater habitat decline is a stressor and stream

burial is not (it is a "source"). This is very confusing as one follows the steps in the 

model. It may be necessary to designate some variables as both response and stressors. 

• Hydrological effects: The description of hydrological effects should be improved in both 

the figure and in the narrative. There are a few components shown in the model, but they 

are not necessarily connected to each other and the model appears to be incomplete. 

Baseflow changes are related to valley fill, and stormflow and runoff is related to 
11

mountain top removal, and together these influence downstream hydrology. The model 

should provide a comprehensive output that incorporates these hydrologic influences. 

o The draft EPA report should have a separate section dealing with Hydrologic 

Impacts and Water Quantity. The topics that should be covered in this section 

include altered flows, general hydrological issues, groundwater movement, 

baseflows, surface runoff, and changing watershed water budgets relative to 

changing watershed size. These hydrological linkages should be clearly 

presented in the Conceptual Model.

o It would be helpful if the diagram indicated how changes within the diagram 

would affect changes to the entire water budget. For example, the diagram should 

indicate changes that would occur to flow paths and residence times of water in 

the landscape, both at the upland and in-stream sites and when considering 

cumulative downstream effects. 

o The model path from valley fill through infiltration and baseflow from fill should 

have outputs similar to those following the "water contact with overburden" 

outputs and not just nutrient responses. 

o The model seems to imply that streams are two dimensional threads which is not 

an accurate depiction of streams. “Stream burial” as described in the model 

should explicitly recognize stream drainages as fractal structures whose 

representation in “typical” maps and databases is limited to perennial and 

intermittent channels and does not represent many intermittent or ephemeral 

channels. 

• Additional missing model components include:

o Reclamation: On the first “line” of the diagram, a key human activity which does 

not appear directly stated and should be added is reclamation, which is on-going 

with most mining operations and occurs nearly concurrent with forest clearing 

and soil stockpiling. Reclamation is more than just replanting; it includes soil 

removal and stockpiling which would then be linked to regrading and replanting. 

o Stream type or stage: Another element that may impact the ecological effects is 

the identification of stream type or stage which should be added to the model 

prior to stream burial (e.g., see N.C. Division of Water Quality, 2005). It is 

important to recognize the differences between and the subsequent impacts on the 

various types of streams (e.g., ephemeral, intermittent, and perennial streams). 

Ephemeral streams flow only following storms. Intermittent streams flow only 

for a portion of a year - a true intermittent stream, from the standpoint of a 

characteristic community, must dry completely (i.e., hyporheic habitat is 

dewatered) during the annual cycle. Perennial streams flow year-round, although 

flow may at times be restricted to the hyporheic zone and not be visible at the 

surface. 

o Habitat fragmentation: A significant element that may impact the ecological 

effects is loss of genetic structure associated with small effective population size 

causing a decline in amphibians or macroinvertebrates. Such losses are in 

response to valley fill that increases the dispersal distance between headwater 

populations.

o Forest clearing impacts: Impacts from forest clearing that should be considered 

including: a) change in light regime; b) loss of coarse woody debris, in addition to 
12

organic matter; c) elimination of nutrient exchange between upland and stream, 

and back again; d) impacts to stream subsidies in the form of salamander, 

crayfish, and insect biomass; and e) loss of required upland habitat to support 

certain stages of amphibian life cycles. These impacts result in increased benthic 

primary production, a potential shift from heterotrophic to autotrophic processes, 

reduced organic matter inputs and processing, and food web shifts.

o Changes in biotic index: With changes in organic matter, light regime, and 

sedimentation, there will be measured changes in biotic index quality that should 

be considered (assuming published literature is available for use in the report). 

This may also result in an observed shift in the food web towards an autotrophic 

system, which is more heavily dependent upon instream algal production, and a 

resulting decrease in the top predators in the system (salamanders and brook 

trout) that represent a large shift in the structure and function of the ecosystem. 

Such data assessment efforts would not require producing new research or 

conducting new data collection efforts, but rather would rely on existing 

publications or previous efforts to research or collect such data. 

o Impacts on fauna: Impacts on other fauna such as birds and bats should be 

acknowledged, especially under situations where headwater riparian zones are 

lost or situations where Se accumulates up food webs.

o Sediment loads: Increased sediment loads have wider effects than indicated in the 

model. For example, an impact resulting from elevated sediment levels that may 

be added to the model include decreased benthic primary production with 

attendant impacts on stream metabolism. 

o Impacts on hydrology, landscape pattern, landscape connectivity, and 

biodiversity: Under scenarios where terrestrial vegetation is replanted as 

herbaceous cover, rather than forest cover, the impacts on hydrology, landscape 

pattern (i.e., fragmentation), landscape connectivity, and biodiversity should be 

addressed in the report and the diagram.

• Since increased nutrient levels have large effects on detrital pathways and primary 

producers in streams (as indicated in ecosystem-level experiments for Southern 

Appalachian streams), nutrient level effects on detrital pathways should be considered in 

the model.

• While it is highly valuable to include life history data for the benthic invertebrates within 

the model, relatively few data are available in published literature. The draft EPA should 

clarify how the limited data affect the statements and conclusions drawn in the report.

• In Figure 12 on page 81 of the draft EPA report, the ‘Forest Clearing’ box in the top left 

corner of the model’s diagram leads to a box entitled ‘Riparian Cover’. Please remove 

the word Riparian from this box in the model’s diagram. 
13

3.2. Literature Review

Charge Question 2: This report relied solely on peer-reviewed, published literature and the 

2005 Final Programmatic Environmental Impact Assessment on Mountaintop 

Mining/Valley Fills. Does this assessment report include the most relevant peer-reviewed, 

published literature on this topic? If not, please indicate which references are missing.

3.2.1. General Comments

In general, the draft EPA report includes much of the key literature associated with 

aquatic ecosystem effects related to MTM-VF that were available at the time the draft EPA 

report was written within the bounds defined by EPA for the draft EPA report. It would be 

appropriate to include some local grey literature to help scope some of the issues that are underrepresented. Since the scientific value of grey literature can be uncertain, EPA should 

appropriately qualify any use of such literature within the draft report. 

3.2.2. Specific Comments

Literature references need to be included or enhanced for several topic areas. In most 

cases these topic areas with citations are discussed in responses to other Charge Questions; 

however, below is a list of several specific topics the panel recommends be considered, with 

some appropriate references. 

• Either the draft EPA report should incorporate stream recovery literature or note that 

there is a gap in this information. References: Buehler et al., 2006; Blakely et al., 2006; 

Niemi et al., 1990; and Gingerich, 2009. 

• Selenium effects on higher trophic levels, as well as references related to the source of 

the Se would be important. Not all stratagraphic sequences and, therefore, not all valley 

fills contain Se or will be a source of Se. References: Luoma and Presser, 2009; 

Chapman et al., 2010; and Conley et al., 2009. 

• Semi-aquatic and riparian fauna (e.g., salamanders and their diversity; stream-related 

mammals such as raccoon and mink). References: Petranka et al., 1994; Jaeger et al.,

1998; Davic and Welsh, 2004; and Meyer et al., 2007b.

• Mussels and their complex life histories. References: Hairston, 1949; Davic and Welsh, 

2004; Grant et al., 2009; Jung, 2002; Peterman, et al., 2007; Regester et al., 2008; Rocco 

and Brooks, 2000; Southerland, 1986; Welsh and Droege, 2001; Williams and Wood, 

2004; Gingerich, 2009; and Burton and Likens, 1975a and 1975b. 

• Osmotic stress of aquatic biota. References: Kapoor, 1979; Nemenz, 1960; Pierce, 1982; 

and Scholz and Zerbst-Boroffka, 1998. 
14

• Sulfate effects from a book from The National Academies Press on coal bed methane. 

This book discusses sulfates and effects which could be drawn on for this study. 

Reference: National Research Council, 2010.

• Decreased resistance and resilience of populations or communities in the face of multiple 

stressors (i.e., synergistic effects), because communities already affected by a stressor are 

more susceptible to additional stressors). References: Brooks et al., 2007; Clements et 

al., 2008; Paine et al., 1998; Schindler et al., 1990; Karr et al., 1985; Trautman, 1981; 

Williams et al., 1989; Semlitsch et al., 2009; and Blomquist et al., 2010. 

• Sediment and treatment ponds and their downstream impacts. Hydrologic response 

addressed in the draft EPA report is from traditional reclamation consisting of compacted 

spoil and grasses. The draft EPA report needs to be expanded to encompass the 

hydrologic response using the Forest Reclamation Approach which has been widely

accepted throughout the surface mining industry. References: Provided in the attached 

References for Appalachian Regional Reforestation Initiatives (ARRI). Reports that are 

prepared by the U. S. Forest Service and U. S. Department of Energy. 

• Literature is available for the study region from the catchment science community which 

may be useful to improve how to articulate reference conditions. For example, literature 

indicates the range of conductivity found in “relatively undisturbed” watersheds of the

region that were monitored long-term might help indicate further contrasts between them 

and the paired studies (MTM-VF vs. reference). References appropriate for this topic 

area are discussed more comprehensively within the Panel's advice as provided in the 

companion SAB Report on EPA's draft "A Field-based Aquatic Life Benchmark for 

Conductivity in Central Appalachian Streams" report.

• The draft EPA report focuses on traditional reclamation technology. Reclamation 

technology for restoring natural stream and other ecological functions affected by MTMVF activities has changed and there has been a transition to more environmentally sound 

reclamation of hydrology, sediment, conductivity that more closely mimic natural 

forested hydrology after some period of time. References and text should be added to 

recognize these changes in technology. References: Ashby, 1999a and 1999b; Burger et 

al., 2009; Burger et al., 2005; Groninger et al., 2007; and Sweigard et al., 2007a. The 

Proceedings of the American Society of Mining and Reclamation is an invaluable 

resource for peer-reviewed articles on surface mine reclamation. An example paper from 

these Proceedings is Chermak et al., 2004. 

• References and text should be added to support the draft EPA report’s discussion on the 

Appalachian region as a refuge for organisms during the past glaciation (page 13). This 

section is important because this topic sets the scene for the assemblage of organisms 

present today and also the changes that naturally occur with changing climate and other 
15

variables. References: Church et al., 2003; Delcourt and Delcourt, 1984; Walker et al., 

2009; and Willis and Whittaker, 2000. 

• References and text should be added to support the draft EPA report’s discussion on the 

West Virginia gap analysis (page 17). Reference: Strager and Yuill, 2002.

• Additional references that should be considered and are related to this Charge Question 

are included within the attached Additional References for Consideration at the end of 

this document. Also, references that are cited in each response to the specific charge 

questions are included in the Literature Cited at the end of this document.
16

3.3. Loss of Headwater Streams

Charge Question 3: Valley fills result in the direct loss of headwater streams. Has the 

review appropriately characterized the ecological effects of the loss of headwater streams?

3.3.1. General Comments

The Panel believes that the draft EPA report has characterized many of the potential 

ecological effects that may occur associated with the loss of headwater streams due to valley fill 

operations, and has acknowledged the limited available data on this topic. Headwater streams 

provide important ecosystem services which include clean drinking water, habitat for aquatic 

life, food for aquatic and amphibious vertebrates, woody debris and processing and uptake of 

nutrients which reduces downstream delivery of nitrogen and phosphorus (see, for example, 

Wipfli and Gregovich, 2002; Meyer et al., 2007a and 2007b; Wipfli et al., 2007a and 2007b; and 

Elmore and Kaushal, 2008). Because changes in watershed land use, including loss of 

headwater and forest resources, can greatly influence most headwater ecosystem services, the 

assessment of the ecological effects of the loss of headwater streams can be strengthened by 

improving the draft EPA report’s discussion on the following issues associated with loss of 

headwater and forest resources: (1) lack of estimate of ultimate area to be affected by MTM-VF 

over different timeframes, (2) lack of an explicit inventory of the diversity of freshwater habitats 

affected, (3) lack of depth in information regarding the loss of biodiversity, and (4) need for 

improved precision and accuracy in assessment of effects of MTM-VF on ecosystem function. 

Additional topics of potential concern are articulated below the following discussion on the four 

issues noted above.

3.3.2. Specific Comments

3.3.2.1. Provide estimates of ultimate area to be affected over different timeframes. 

Headwater streams can be classified as ephemeral, intermittent or perennially flowing 

systems. A clear definition of what a headwater stream is should be provided, with clarification 

regarding how the cited literature and supporting data used within the draft EPA report are 

related to ephemeral, intermittent vs. perennial streams (see suggested definitions under response 

to Charge Question 1). It would be helpful if EPA stated which type of stream is being 

addressed by the literature that is cited because this would help provide an accurate accounting 

of miles of ephemeral vs. intermittent vs. perennial streams, and because it has been pointed out 

that biodiversity in streams varies by stream type (Meyer et al., 2007b). 

EPA should clarify in the draft report whether data is already available or published that 

quantifies the miles of each type impacted by MTM-VF. If such data do not exist, EPA should 

consider modeling these data based on literature values. The draft EPA should also clarify how 

the limited or non-existent data on this topic affect the statements and conclusions drawn in the 

report. Such data assessment efforts would not require producing new research or conducting

new data collection efforts, but rather would rely on existing publications or previous efforts to 

research or collect such data. 
17

Two forms of headwater loss occur due to MTM-VF operations: a) the removal of 

headwater streams coupled with rearrangement and conversion of the catchments from steep 

forested catchments to low gradient grassland catchments, in general, and b) the burial of 

streams. However, as noted above, the report must define “headwater streams” prior to 

attempting to characterize changes to the ecological effects of the streams. The assessment of 

the effect of these losses on the ecology of the central Appalachian coalfield region, however, is 

hindered by the lack of information on the proportion, extent and form (e.g., river and upland 

terrestrial) of the landscape that could ultimately be affected by MTM-VF. This information is 

critical for any realistic assessment of the different approaches to managing the effects of MTMVF. For example, if MTM-VF will affect 70% of a particular region or geographic area over 

time, a different strategy and a different regulatory framework would likely be implemented if 

MTM-VF only affected 10% of that region or area. As indicated in the draft EPA report, MTMVF has already resulted in the loss of >2% of river miles in the study region, and an estimate of 

the potential changes in the remainder of river miles and the associated upland landscape should 

be added to the revised report. This should be provided in the form of best and worst case (or 

minimum and maximum mining permit or land disturbance) scenarios. Finally, EPA should 

discuss whether and how a reasonably acceptable threshold could be determined that would 

identify the amount of land area or stream length that could be affected by MTM-VF. For 

example, would 10%, 20%, or possibly 50% of land affected by MTM-VF be ‘acceptable’? 

Such an assessment should consider the cumulative impacts associated with MTM-VF 

operations. The assessment should also determine and justify the percentage of what is affected 

using a definition of order of stream and stream length, assuming the streams noted are perennial 

streams. Based on Figure 7, some fills are already impacting or filling 2nd order streams.

3.3.2.2. Provide an explicit inventory of the diversity of freshwater habitats affected. 

In its current form, the draft EPA report focuses on the loss of stream channels, often 

reporting this as miles of channel lost. In reality, however, a range of habitats is being changed, 

each with a characteristic biological community. These include, but are not limited to: seeps, 

springs, dripping cliff faces, wetlands, temporary pools, and groundwater habitats. The draft 

EPA report should acknowledge that these habitats are affected by MTM-VF in addition to the 

stream channel, since these water resources are as critical, if not more critical, as water sources 

and habitat than streams, and many are refuges for endemic species and offer quite different 

aquatic habitat than flowing water (e.g., see Arscott et al., 2005; Meyer et al., 2007a; Malard et 

al., 2003; and Morse et al., 1993).

The limited degree to which ephemeral and intermittent headwater streams were 

adequately mapped by traditional data sources (e.g., U.S. Geological Survey topographic maps) 

limits the usefulness of the cumulative impacts assessment, in part because it has been pointed 

out that biodiversity in streams varies by stream type (Meyer et al., 2007b). 

Also, it is difficult to assess the effects of mining activities on stream habitats without 

consideration of the close link between upland forest communities and those of the associated 

freshwater communities (see Nakano et al., 1999; Nakano and Murakami, 2001; and Fausch et 

al., 2002). For example, the draft EPA report should more explicitly discuss the reliance of 
18

many salamanders and other aquatic organisms on upland habitats during certain stages of 

amphibian life cycles. EPA should discuss to what extent these upland habitats support premining species of amphibians, and what are the anticipated and/or measured levels of postmining species richness of amphibians in the aquatic environments or the ditches, groins, 

retention basins and downstream channel (see Gingerich, 2009).

Finally, the treatment of the different types of headwater streams was vague. For 

example, the distinction between ephemeral, intermittent, and perennial streams as habitats must 

be strengthened. As suggested under the response to Charge Question 1, ephemeral streams flow 

only following storms. Intermittent streams flow only for a portion of a year - a true intermittent 

stream, from the standpoint of a characteristic community, must dry completely (i.e., hyporheic 

habitat is dewatered) during the annual cycle. Perennial streams flow year-round, although flow 

may at times be restricted to the hyporheic zone and not be visible at the surface. In the latter 

case, perennial streams may be misclassified as intermittent leading to confusion about the true 

structure of intermittent versus perennial stream communities. The majority of literature 

addressing biotic and functional characteristics of headwater streams is most likely to focus on 

perennial and intermittent types. Traditional bioassessment is almost exclusively confined to 

perennial streams. The traditional bioassessment techniques will not work well in intermittent or 

ephemeral streams. In addition, surveys occurring when flow is absent or very low (e.g., fall) 

might skew assessment metrics (Larned et al., 2009; Williams, 1996). The imprecise 

characterization of these stream types has bearing on any regulatory structure that depends on 

invertebrate community structure as an indicator of habitat quality. 

3.3.2.3. Elaborate on information regarding the loss of biodiversity. 

In its present form the draft EPA report does not adequately assess the effect of 

biodiversity loss resulting from MTM-VF. The draft EPA report should consider that headwater 

streams contribute considerably to the biodiversity of the area as well as river networks 

downstream from the headwater streams (Meyer et al., 2007). Clearly, such an assessment is 

hampered by the lack of knowledge of the ultimate area that will be affected by MTM-VF over 

different timeframes, as well as lack of attention to the diversity of certain key groups of aquatic 

animals (see discussion in Section 4.4.2.5. of this SAB Report). Nonetheless, the region contains 

a significant level of biodiversity that is imperiled to varying degrees.

• First, although the draft EPA report correctly points out that the central Appalachians 

contains a level of biodiversity that is of national and global significance, the draft EPA 

report should discuss the reasons for the implications of losing this biodiversity and 

importance of preserving this biodiversity (Harding et al., 1998; Meyer et al., 2007b). 

Such explanation is required to make a compelling case for its proper management and 

protection.

• Second, the draft EPA report does an unsatisfactory job of describing this biodiversity. 

There is a great deal of information that is readily available from the West Virginia 

Natural Heritage Database (online) and the Kentucky Department of Fish and Game 

Species List (online) that summarizes information on the conservation status of 

freshwater fauna for both vertebrates and invertebrates. In addition, information also 
19

exists on the conservation status of plants and plant communities in this region (e.g., see 

Estill, 2001). Sources of information such as these should be summarized to provide 

some depth as to exactly what is at risk due to mining activities in the central 

Appalachians. Such data assessment efforts would not require producing new research or 

conducting new data collection efforts, but rather would rely on existing publications or 

previous efforts to research or collect such data. 

• Third, some text should address differences in community structure between streams of 

different sizes. For example, the invertebrate communities of first order streams are 

radically different from those of third and fourth order streams (Vinson and Hawkins, 

1998). This would help readers understand that one “river mile” is not necessarily 

equivalent to another lost “river mile” in terms of diversity and species affected by 

mining activities. Since headwater streams represent the vast majority of total stream 

miles in a watershed (i.e., between 65-75%) (Leopold et al., 1964), protection of this 

important habitat is vital.

• Fourth, the draft EPA report should discuss the effect of fragmentation on population 

viability of stream biota. Upstream headwater reaches that are unaffected by mining 

might become isolated from other reaches by the contamination of higher order stream 

channels, resulting in the fragmentation of otherwise continuous populations (see Hughes 

et al., 2009). Although the information is sparse, some recent research is available on 

population-level effects concerning the effect of habitat fragmentation on brook trout 

population viability (see Letcher et al., 2007). Other sources of information that provide 

background on the population-level effects of stream habitat fragmentation are Fagan 

(2002a and 2002b). Also, Hughes et al. (2009) addressed some of these issues with 

respect to the degree of isolation among stream communities. 

• Fifth, some assessment of the “recovery” of and long-term effects on biodiversity as 

affected by reclamation is recommended. For example, the conversion of upland centralAppalachian forest to what is essentially prairie grassland with an avifauna that includes 

quail, indigo bunting, and horned lark results in a dramatic change in community 

structure, even though biodiversity might be increased from mining sites prior to 

reclamation. Also, the consequences of change in upland terrestrial ecosystems, 

including certain sensitive and globally-declining species, are equally critical to consider. 

For example, the Cerulean Warbler is a steeply-declining migratory songbird that is 

thought to have lost 70% of the global population since the 1960s and has twice been 

petitioned for Federal protection (Hamel et al., 2004). Not only does the heart of the 

breeding distribution of Ceruleans co-occur with areas most strongly impacted by MTMVF, but the bird shows a strong affinity for breeding on steep slopes and ridgetops. A 

recent study projected that up to 23% of breeding Cerulean Warblers in the Cumberland 

Mountains of Tennessee, a region that supports an estimated 20% of the global 

population could be displaced from MTM-VF activities (Buehler et al., 2006). The 

potential effects of the replacement of central Appalachian mountain communities with 

assemblages of invasive or non-native species should also be acknowledged in the draft 
20

EPA report. The Report should discuss the desirability of restoration of native species 

and ecosystems, and undesirability of loss of native species, as endpoints in reclamation,

3.3.2.4. Provide improved precision and accuracy in discussion of ecosystem function. 

The Panel believes two areas should be focused on regarding this issue. 

• First, EPA should be more specific about the types of functions being addressed, along 

with the characteristics (i.e., types and rates) of the functions under discussion. 

Statements in the draft EPA report indicate that stream channels, once removed or buried, 

lose their function. Although this is certainly true for stream channels draining 

catchments that are physically removed, it is unclear that this is always the case for 

streams that are buried. While not all functions may be lost in buried streams, a large 

number of functions are altered, degraded, or eliminated. Once a stream is buried 

beneath or reconstructed on the surface of valley fill, it may still be collecting and 

conveying water, although the solutes and the rates of conveyance may differ. Similar to 

the former streams that they replace, stream channels formed on and buried beneath 

reconstituted valley fill also export solutes to downstream reaches. In the case of valley 

fill channels, this is indicated by increases in conductivity of downstream reaches that 

would otherwise be unaffected. Presumably these reconstituted channels also will be 

sources of export of dissolved other materials to downstream reaches and sites of some 

biological processes, including microbial production, primary production in the case of 

surface channels, and nutrient cycling. 

• Second, statements concerning the dependence of downstream macroinvertebrate 

communities on material and energy exported from upstream tributaries or reaches are 

unhelpful without accompanying information describing spatial scale. Distances 

regarding effects on downstream reaches are measureable). Although the concept of the 

“dependence of downstream communities on the inefficiencies of those upstream” is well 

entrenched in the literature, studies that have directly and effectively quantified such 

linkages between macroinvertebrate communities are scarce. There is uncertainty in the 

actual magnitude of these energetic linkages, but recent published data (Newbold et al., 

2002) suggest that it can be significant. If statements concerning the effects of upstream 

communities on the structure and productivity of those downstream are made, the EPA 

should cite studies that have actually demonstrated a material or energetic link. One such 

study (Newbold et al., 2002) involves the development of a model that represents 

production, downstream routing, and reutilization of labile dissolved organic carbon 

(LDOC). Although estimates vary with assumed parameter values, preliminary results 

from this study suggest that 1st and 2nd order streams may support approximately 50%, 

25%, and 20%, of the LDOC utilization in third, fourth, and fifth-order streams, 

respectively. Also, the strength of the linkages and the spatial scale associated with 

upstream-downstream nutrient cycling should be further described within the report.

In summary, the discussion regarding animal community function focuses on changes in 

community structure which is manifested in an alteration of the relative abundance of different 

functional feeding groups. EPA should consider whether the report would be improved if it 
21

simplified the discussion by focusing on taxonomic structure - which is what is actually 

measured - rather than on function. In considering this, if EPA decides to link the discussion of 

community structure and functional feeding groups, EPA should be aware that while the 

literature indicating direct measures of ecosystem function impacts due to MTM-VF are few, the 

link between community structure and some ecosystems processes (e.g., nutrient cycling) is well 

established in the literature (e.g., see Wallace et al., 2009; Rodriguez-Iturbe, 2000; and 

Greenwood et al., 2007). Such data assessment efforts would not require producing new 

research or conducting new data collection efforts, but rather would rely on existing publications 

or previous efforts to research or collect such data. 

Additional issues that could be further assessed in the draft EPA Report include the time 

and spatial scales of the effects of MTM-VF, and how effects cascade downstream or affect 

downstream waters. For example, the draft EPA Report could clarify whether the time scales are 

for localized, short-term or widespread, permanent effects. In addition, further consideration on 

the potential impacts from changes in flow due to valley fills and the effects related to type of 

stream filled (ephemeral, intermittent or perennial) would be helpful, in part because, as 

discussed earlier, the imprecise characterization of these stream types has bearing on any 

regulatory structure that depends on invertebrate community structure as an indicator of habitat 

quality. Figure 6 provides a limited description of the more complex system described above, 

and should be updated to incorporate the above-noted impacts and effects.

Regarding ephemeral streams, the first and second paragraphs in section 3.1 are not in 

agreement. While the literature on the structure, function, and magnitude of the length and 

temporal dynamics of ephemeral streams is limited, it is clear that these streams do perform 

various functions including transporting solutes and sediments across the landscape (Larned et 

al., 2009: Reid and Laronne, 1995). While the physical removal of a mountain changes the flow 

of water across the landscape, thereby eliminating some ephemeral channels, ephemeral 

channels may be established in the newly formed landscape in reclaimed and restored habitats. 

There is a general lack of data on ephemeral channels, and the report accurately reflects that lack 

of knowledge. However, particular attention should be paid to characterization and 

identification of ephemeral streams in order to adequately characterize the ecological impacts of 

MTM-VF on the bulk transport of solutes and sediments in these streams and what is the 

downstream impact, if any, of their transformation after MTM-VF. 

The draft EPA report would benefit from further discussion and a stronger emphasis on 

the critical importance between the form of allochthonous inputs, how they are impacted by 

MTM-VF, and how, in turn, the types and diversity of invertebrate fauna are impacted. 

The draft EPA report states (on page 15) that EPA does not know how to measure the 

incremental effects of small stream loss on downstream functions. This lack of an assessment 

tool is critical to understanding the effects of MTM/VF. EPA could potentially solve this 

measurement issue by convening a workshop of experts on eastern forest streams to discuss the 

topic. 

The draft EPA report also refers to small stream tributaries as among the primary factors 

for runoff control in high gradient watersheds. The draft EPA report should note the important 
22

role of these tributaries play in groundwater recharge which in turn maintains baseflow within 

streams. 

The impacts of loss of upland and instream salamander habitat were not well-addressed. 

There is substantial literature available on this topic (see Hairston, 1949; Davic and Welsh, 2004; 

Grant et al., 2009; Jung, 2002; Peterman, et al., 2007; Regester et al., 2008; Rocco and Brooks, 

2000; Southerland, 1986; Welsh and Droege, 2001; and Williams and Wood, 2004) which 

addresses the numerical dominance of salamanders in the southern Appalachian Mountains, and 

Burton and Likens (1975a and 1975b) in Hubbard Brook. Further references are included in the 

attached References. Such data assessment efforts would not require producing new research or 

conducting new data collection efforts, but rather would rely on existing publications or previous 

efforts to research or collect such data. 

The loss of some ecosystem functions and services such as nutrient cycling were 

addressed, but some additional information about food webs and the links to nutrient processing 

could have been addressed more fully (e.g., Benke and Wallace, 1997; Hall et al., 2000). For 

example, organic matter processing issues focused exclusively on leaves, but woody debris is 

also an important constituent of the organic matter pool (see Wallace and Webster et al., 2001).
23

3.4. Downstream Water Quality and Stream Biota

Charge Question 4: In addition to impacts on headwater streams, mining and valley fills 

affect downstream water quality and stream biota. Does the report effectively characterize 

the causal linkages between MTM-VF, downstream water quality, and effects on stream 

biota?

3.4.1. General Comments

The Panel generally agrees that the draft EPA report provides strong evidence for a

causal relationship between MTM-VF and downstream water quality. The draft EPA report also 

links these changes in water quality to aquatic communities. The evidence from the peer 

reviewed literature (e.g., Howard et al., 2001; Hartman et al., 2005; Merricks et al., 2007; Pond 

et al., 2008) showing changes in ion concentrations associated with MTM-VF is very 

compelling, although limited in the number of sites evaluated. The biological responses, 

particularly those based on field evidence, show a clear reduction or extirpation of sensitive taxa 

associated with sites experiencing high ion concentrations. The SAB agrees with the general 

conclusions of EPA that MTM-VF results in the loss of headwater streams, degrades water 

quality and negatively impacts aquatic communities. Therefore, most of the comments below 

are intended to enhance EPA’s presentation of the discussion. As with many of the responses to

charge questions, these comments especially demonstrate linkages among the important points 

emphasized in responses in other charge questions.

There was some discussion among members of the SAB Panel of the relative importance 

of mining versus other stressors. While mining clearly represents the largest impact to the 

watersheds assessed in the draft EPA report, it is not the only disturbance in the region. For 

example, the draft EPA report notes that some streams were impacted by residential 

development, which may interact with MTM-VF to structure aquatic communities. Therefore 

the impacts of MTM-VF should be interpreted within the context of these other potential 

stressors. Residential and industrial development should be considered, as well as state and 

county road building and repair activities. The effects of potentially confounding variables such 

as legacy land use, residential development, and proximity to ponds should also be considered in 

this data interpretation. EPA should consider gathering and evaluating existing, available data

on these topics. Such data assessment efforts would not require producing new research, but 

rather would rely on existing publications or previous efforts to produce such research 

information. 

Potential causal linkages between conductivity and aquatic communities could also be 

improved by assessing and including discussion on available literature regarding studies 

conducted within other ecoregions that consider how organisms respond to high TDS effluents in 

the field. For example, a large field study is currently underway in the Powder River basin, 

Wyoming, to assess effects of high TDS effluents on stream communities (Peterson et al., 2009). 

Such data assessment efforts would not require producing new research or conducting new data 

collection efforts, but rather would rely on existing publications or previous efforts to research or 

collect such data. 
24

3.4.2. Specific Comments

3.4.2.1. Improve discussion on use of conductivity as a surrogate stressor 

The most consistent changes in water quality downstream from MTM-VF were increases 

in concentrations of several cations and anions, resulting in significantly elevated TDS and 

conductivity. Reported concentrations of SO4

2-

, HCO3

-

, Ca2+ and Mg2+, are approximately 10 

times higher downstream of MTM-VF than in reference systems. There was much discussion 

among the SAB Panel regarding the use of conductivity as a surrogate measure of toxicological 

effects for the ions that are causing stress. Because the relative toxicity of cations and anions 

varies greatly (> 10X), the draft EPA report should note that measures such as TDS or 

conductivity are relatively coarse indicators of water quality. For example, recent experiments 

conducted by the U.S. Geological Survey (USGS) suggest that bicarbonate (HCO3

-

) is likely the 

major source of toxicity in high TDS effluents (see Farag et al., 2010). 

Although conductivity is an integrated measure of these major cations and anions in 

surface waters, minor and trace constituents that do not greatly influence conductivity (e.g., 

dissolved organics, trace metals, minerals such as selenium) may also affect aquatic life. EPA

should consider developing a more robust characterization of MTM-VF effluents and their 

receiving waters with respect to ionic composition, including an analysis that explores the role of 

the matrix ions as well as trace constituents. Such an analysis would improve the understanding 

of toxicological effects associated with releases from MTM-VF activities. Variation in relative 

toxicity of SO4

2-

, HCO3

-

, Ca2+ and Mg2+ is important for the analysis, but it is equally important 

to emphasize that each of these ions increased significantly downstream of MTM-VF streams 

(Table 4) relative to the reference stream data provided. 

To enhance the causal link narrative, biological plausibility needs reinforcement. A 

mechanistic understanding between conductivity and biological responses could be enhanced by 

including some of the relevant environmental physiology published literature on specific ions 

and osmotic pressure (see Kapoor, 1979; Nemenz, 1960; Pierce, 1982; and Scholz and ZerbstBoroffka, 1998). Finally, because most of the information on toxicity of major cations and 

anions are based on single species toxicity tests, a significant information gap exists in 

understanding of how aquatic communities respond to major ions. EPA’s use of available 

experimental data on sensitive indigenous species or sensitive life stages of these species would 

strengthen the case for a causal relationship between conductivity and species extirpation (see 

Cao et al., 1998; and Clements and Newman, 2002). Such data assessment efforts would not 

require producing new research or conducting new data collection efforts, but rather would rely 

on existing publications or previous efforts to research or collect such data. These 

recommendations are discussed more comprehensively within the Panel’s advice as provided in 

the companion SAB Report on EPA’s draft “A Field-based Aquatic Life Benchmark for 

Conductivity in Central Appalachian Streams” report.

Another important consideration with respect to evaluating toxicity of high TDS effluents 

is the amount of variation in specific ionic composition that occurs spatially or temporally. For 

example, Merovich et al. (2007) reported that the amount of temporal variation in water quality 
25

differed between reference and mined watersheds. Spatial variation in ionic composition among 

watersheds also will influence responses from MTM-VF operations and is likely a result of 

differences in soils and underlying geology. Predicting downstream responses to mining will 

require an understanding of these natural geological conditions. EPA should include information 

and a figure depicting the percentages of conductivity that are made up by the various matrix 

ions, and indicate the consistency and/or variability of such matrix ions in surface and 

groundwaters across the region. The case for conductivity as a surrogate is greatly strengthened 

if it can be shown that the relative proportion of the constituent ions contributing to conductivity 

is about the same in stream water sampled downstream of most MTM-VF operations in the 

region. In that context, it is important that information be presented in the context of the percent 

of conductivity made up by individual ions, by calculating the equivalent ionic conductance of 

the each individual matrix ions and their contributions to the overall conductance of the water 

solution (e.g., following Laxen, 1977, with summary tables presented by Boyd, 2000). 

3.4.2.2. Clarify statements and conclusions drawn in the draft EPA report regarding 

limitations of laboratory toxicity tests

There was considerable discussion by the Panel regarding the usefulness of laboratory 

toxicity tests for predicting effects of stressors associated with MTM-VF. Much of what is 

known about toxicity of major ions is based on results of laboratory toxicity tests using surrogate 

species (Ceriodaphnia, fathead minnows). The acute test results are not especially useful for 

inferring consequences of changes in water quality associated with MTM-VF activities. The test 

species are not present in the regional area assessed by the draft document, and the abrupt acute 

exposures do not adequately reflect exposure conditions associated with MTM-VF in this region. 

Most importantly, the laboratory toxicity tests involved abrupt, unacclimated exposures that 

likely do not reflect the exposures that occurred near MTM-VF activities. Field exposures that 

occurred near MTM-VF activities involved time for acclimation to occur. In general, these acute 

toxicity data seem too sparse and weak to draw any conclusions. The draft EPA report briefly 

acknowledges the limitations of these tests for assessing effects of TDS and elevated 

conductivity on benthic macroinvertebrates (e.g., short duration, focus on mortality as an 

endpoint, non-indigenous species). Also, relatively few data are available regarding life history 

data for the benthic invertebrates. The draft EPA report should clarify how the limited data 

affect the statements and conclusions drawn in the report related to benthic invertebrate life 

histories.

Unfortunately, because of difficulties culturing aquatic insects in the laboratory, 

information on toxicity of major ions and other chemicals on indigenous species is very limited. 

More importantly, the relatively few laboratory studies conducted with aquatic insects often 

show these organisms to be considerably more tolerant to various ions or metal salts than would 

be predictable based on field observations. At least part of this difference results from the focus 

on relatively large, later instars which are significantly more tolerant than earlier instars. Thus, 

reconciling differences between laboratory and field studies is a major challenge in hazard 

assessment of these effluents.

The Panel recognizes the inherent limitations of demonstrating causation based 

exclusively on descriptive studies, and generally agreed that the field data provided strong 
26

support for a causal relationship between MTM-VF and impaired aquatic communities. Because 

of the inferential weaknesses of single species toxicity tests described above and the general lack 

of information on sensitivity of aquatic insects to specific ions, a viable alternative is to conduct 

field-based microcosm or mesocosm experiments using intact assemblages of macroinvertebrate 

communities (Clements et al., 2004). These experiments could be employed to quantify speciesspecific sensitivity to individual ions or to examine interactions among MTM-VF stressors (e.g., 

elevated conductivity, and metals including Se). Inferences from field data combined with 

available information on how TDS increases downstream from MTM-VF are the most 

convincing in the document. Fish and macroinvertebrate communities below the MTM-VF 

activities are consistently deemed “poor quality” based on field surveys (see Fulk et al., 2003; 

Pond et al., 2008; and Stauffer and Ferreri, 2002). These results provide support for the 

hypothesis that MTM-VF is responsible for degradation of aquatic communities and these data 

that are cited in the draft EPA report could be presented with more confidence. 

3.4.2.3. Revise draft EPA report discussion regarding sensitivity of Ephemeroptera to 

MTM-VF

The draft EPA report notes the sensitivity of mayflies (Ephemeroptera, EPT) to high TDS 

effluents, a finding that has been frequently observed in studies of heavy metal contamination. It 

is important to realize that the reported sensitivity of mayflies to elevated TDS is relative to other 

macroinvertebrate groups (Trichoptera, Diptera, and Coleoptera). There is considerable 

variation in sensitivity to MTM-VF stressors among mayflies, and some genera may be 

relatively tolerant to elevated TDS and conductivity. Nonetheless, within the aquatic insects, 

mayflies are the most appropriate group to consider, since mayflies are important in the food 

webs of most freshwater ecosystems and a mainstay of water quality monitoring programs (and 

are recognized and appreciated by fly fishermen throughout the world).

The similarity of responses of macroinvertebrate communities to metals and major ions 

suggests that similar mechanisms may be responsible (e.g., effects on osmoregulation and ionic 

composition). More importantly, it suggests that the extensive database available on responses 

of macroinvertebrate communities to trace metals could potentially be used to characterize 

effects of major ions. Such data assessment efforts would not require producing new research or 

conducting new data collection efforts, but rather would rely on existing publications or previous 

efforts to research or collect such data. 

A threshold response of 500 μS/cm was identified by Pond et al. (2008) for mayfly 

richness and proportion abundance. It would be useful to subject these and other 

macroinvertebrate field data to a formal threshold analysis to determine if this level is a valid or 

statistically significant threshold response (Dodds et al., 2010). These analyses would 

complement results of the species sensitivity distributions reported in EPA’s draft “A Fieldbased Aquatic Life Benchmark for Conductivity in Central Appalachian Streams” report. Such 

data assessment efforts would not require producing new research or conducting new data 

collection efforts, but rather would rely on existing publications or previous efforts to research or 

collect such data. 
27

Differences in relative sensitivity among major macroinvertebrate groups demonstrate 

that some traditional metrics employed to characterize responses of aquatic communities to other 

stressors may be less effective for high TDS effluents. For example, caddisflies and some 

stoneflies are relatively tolerant to major ions, a finding often reported for trace metals (Nelson, 

1994). Thus, measures such as Ephemeroptera richness and abundance are less sensitive to 

water quality changes associated with MTM-VF than measures based on mayflies alone. The 

tolerance of many caddisflies to high TDS effluents may account for the “mixed effects of 

mining on EPT aggregate measures” noted on page 47 of the draft EPA report. 

Finally, the effects on mayflies should be put into proper perspective for the non-expert 

reader. For example, while most stream ecologists recognize the important functional role that 

mayflies play in streams, some readers may not be familiar with this information. It may also be 

useful to remind readers that because mayflies are highly sensitive to anthropogenic stressors, 

their abundance and diversity is a useful measure of stream integrity. The recent study by Pond 

(2010) has a good overview of these issues that could be incorporated into the text of the report. 

3.4.2.4. Provide more emphasis on selenium effects 

The draft EPA report indicates that selenium concentrations downstream from MTM-VF 

are significantly elevated above the Chronic Ambient Water Quality Criterion and that levels in 

fish tissue exceed concentrations toxic to other consumers. Studies from coal mine leachate are 

moderately useful for inferring potential Se effects, but do not provide definitive evidence. 

Regardless, Se concentrations could increase risk of mortality and deformities of fish and/or 

reduce hatching success of birds. Therefore, it would be useful to include existing, available 

data on Se concentrations in macroinvertebrates and the conceptual models might include a food 

web model showing expected Se transport among trophic levels (see Luoma and Presser, 2009; 

and Chapman et al., 2010). Such data assessment efforts would not require producing new 

research or conducting new data collection efforts, but rather would rely on existing publications 

or previous efforts to research or collect such data. 

The basic concepts of Se dynamics in such environments are published but not 

recognized in this report (see Luoma and Presser, 2009; and Chapman et al., 2010). Recognition 

of the importance of recycling in downstream wetlands, accumulation in food webs, and 

extirpation of fish and birds could be discussed in the context of the environment in question. 

The draft EPA report should cite the preliminary data utilized from recent “grey literature” 

reports prepared by the West Virginia Department of Environmental Protection that show Se in 

local food webs. Since the scientific value of grey literature can be uncertain, EPA should 

appropriately qualify any use of such literature within the draft report. Because Se 

concentrations are likely influenced by local geology, some understanding of underlying 

geological processes could improve the ability to predict the degree of Se contamination among 

watersheds. Also, while the draft EPA report assumes minimal geologic variability within these 

eco-regions, the differences may profoundly impact the ecological effects and may explain some 

of the variability observed (see Caruccio et al., 1977). Such data assessment efforts would not 

require producing new research or conducting new data collection efforts, but rather would rely 

on existing publications or previous efforts to research or collect such data. 
28

3.4.2.5. Revise draft EPA report discussion regarding sensitivity of mussels and other 

organisms

The draft EPA report does not provide sufficient information on potential effects of 

MTM-VF operations on the freshwater mussels of the region. The biodiversity of this group is 

unique on the Cumberland Plateau, with many species often being threatened or endangered 

species (Layzer et al., 2006). Mussels are generally no more sensitive than other taxa to 

potential effects of MTM-VF operations. However, mussels are especially sensitive to the 

changes described in the draft EPA report because they tend to be among the poorest of osmoionoregulators (Dillon, 2000). Furthermore, because many freshwater mussels use specific fish 

hosts for reproduction, the effects of MTM-VF on fish assemblages (e.g., Carlisle et al., 2008)

will likely have indirect effects on mussels. Mussel populations may also be indirectly impacted 

by sedimentation, degradation of habitat, and alteration of upstream ecosystem functions (i.e., 

carbon cycling) (Strayer, 2008).

The draft EPA report does an excellent job highlighting the unique biodiversity of the 

southern Appalachian region. However, the potential impacts MTM-VF on some critical groups, 

particularly salamanders, mussels and crayfish, could be expanded. For example, there is 

substantial available literature available on this topic beginning with Hairston (1949) which 

addresses the numerical dominance of salamanders in the southern Appalachian Mountains. In 

particular, the draft EPA report should consider impacts to crayfish species such as burrowing 

headwater species that do not live in-stream but rather inhabit areas uphill from the streams. 

Such data assessment efforts would not require producing new research or conducting new data 

collection efforts, but rather would rely on existing publications or previous efforts to research or 

collect such data. 

Also, the draft EPA report should note that aquatic organisms in streams and rivers 

further downstream of the valley fill operations such as hellbenders (Cryptobranchus 

alleganiensis) and other amphibians may be especially sensitive to elevated dissolved 

materials/salinity because they inhabit these waters year round and can be long-lived (e.g., Hart 

et al., 1984; Turtle, 2000; Watts and Schorr, 1998).. In addition, EPA should also consider 

including discussion on potential impacts to species found higher up in terrestrial foodwebs.

3.4.2.6. Clarification of Soucek papers 

The authors should further clarify the discussion on the Soucek papers cited in sections 

5.3, 5.4 and 6.4 of the draft EPA report. Results of acute experiments conducted with Hyalella 

azteca may be less relevant because they were conducted in a standardized moderately hard 

reconstituted laboratory water formulated in accordance with EPA standard methods (U.S. EPA, 

2002b) which may not have sufficient chloride to promote healthy cultures, based on personal 

observations from Dr. David Soucek (University of Illinois – Urbana); Dr. Chris Ingersoll 

(USGS, Columbia, MO), and Dr. David Mount (EPA, Duluth, MN). Since Hyalella cannot be 

cultured in that particular water even when sulfate levels are low, the sulfate toxicity data 

generated in MHRW are probably not reliable. In Section 6.4., the draft EPA report should note 

that the Soucek et al. (2000) paper was a study of acid mine drainage (AMD) and was not 

designed to investigate effects of elevated conductivity. Finally, a recent paper by Lasier and 
29

Hardin (2010) which investigated chronic toxicity of chloride, sulfate and bicarbonate to 

Ceriodaphnia dubia in low and moderate hardness waters should be included in the draft EPA 

report.

3.4.2.7. Other considerations

Revise draft EPA report discussion regarding functional measures. 

Section 404 of the CWA states that mining permits should “strive for no net loss of 

aquatic functions.” It is difficult to evaluate the success of this requirement given the lack of 

studies on MTM-VF and ecosystem function. The limited information on ecosystem function 

downstream from MTM-VF effluents is a significant data gap; however, published studies using 

other stressors with similar responses could be used to fill this data gap (e.g., Niyogi et al., 2001; 

Carlisle and Clements, 2005). Such data assessment efforts would not require producing new 

research or conducting new data collection efforts, but rather would rely on existing publications 

or previous efforts to research or collect such data. The dependence on functional feeding group 

analysis to assess stream function is a problem due to insufficient data for some taxa with respect 

to the functional feeding groups themselves, and the implicit dependence on structural metrics. 

The draft EPA report would be strengthened by future efforts by EPA to conduct direct 

measurement of functional measures, or as stated above, use of existing data from studies with 

similar stress profiles, instead of using structural characteristics (e.g., abundance of functional 

feeding groups) as surrogates for ecosystem processes. 

There have been a number of recent presentations at scientific meetings (e.g., J. D. 

Newbold's presentation titled " Geomorphic Scaling of Uptake Length in Channel Networks and 

the Potential Importance of Headwater Streams" at the July, 2002 American Water Resources 

Association meeting) associated with acid mine drainage which demonstrate how loss of stream 

ecosystem structure translates into loss of some stream ecosystem functions and the ability of the 

stream to deliver ecosystem services. These studies could strengthen the link between MTM-VF 

and stream ecosystem impacts. Unfortunately, many of these studies have yet to reach the peer 

reviewed literature. Consequently, EPA is encouraged to examine the rich literature on effects 

of heavy metals associated with hard rock mining on functional measures to support their 

argument that MTM-VF affects ecosystem processes (e.g., Niyogi et al., 2001; Carlisle and 

Clements, 2005). Such data assessment efforts would not require producing new research or 

conducting new data collection efforts, but rather would rely on existing publications or previous 

efforts to research or collect such data. 

Revise draft EPA report discussion regarding hyporheic communities. 

One component missing in the draft EPA report is a deeper discussion of the relationship 

among headwater streams, MTM-VF operations, and mitigation as related to hyporheic 

communities. This could also be further developed and incorporated into the conceptual model. 

The hyporheos is a critical sub-habitat for benthos, particularly the juvenile stages of aquatic 

insects. As mining processes or reclamation procedures continue, the hyporheos may be the 

habitat most affected. These habitat changes will affect the aquatic individuals, populations and 

communities relying on such habitat. Further, the sediment sections in the draft EPA report
30

seem to focus exclusively on the surficial component of the biota (e.g., how transported 

sediments will influence the biota) rather than a more holistic treatment that includes hyporheic 

communities.

Revise draft EPA report discussion regarding hydrologic alterations. 

In addition to MTM-VF effects on downstream water quality, the draft EPA report 

should address effects on downstream hydrology. In particular, the draft EPA report should 

assess hydrologic connections to water quality and the physical condition of components of the 

downstream riverine system. These hydrologic alterations will likely play a critical role in 

structuring macroinvertebrate communities through alteration of a range of hydrologic 

characteristics (e.g., change in timing and duration of peak flow and base flow, and flow 

periodicity). 
31

3.5. Cumulative Ecological Effects

Charge Question 5: The published literature is sparse regarding the cumulative ecological 

impacts of filling headwater streams with mining waste (spoil). Does the review accurately 

describe the state of knowledge on cumulative ecological impacts of MTM-VF? If not, how 

can it be improved?

3.5.1. General Comments

The Panel agrees with EPA that the published literature is sparse with regard to the 

cumulative ecological impacts on terrestrial and aquatic ecosystems of filling headwater streams 

with mining waste. The Panel’s comments focus primarily on definitions and framing of issues 

covered within the draft report. EPA should conduct an expanded effort to find or generate 

relevant information that addresses the cumulative effects aspect of the topics covered within the 

draft report. EPA’s search for data to evaluate the extent (spatial and temporal) and significance 

of cumulative impacts can and should involve both direct (peer reviewed papers designed to test 

for cumulative effects) and indirect (peer reviewed papers of studies designed for a different 

purpose) studies related to MTM-VF activities as well as those associated with perturbations 

which differ from MTM-VF but have similar characteristics. Such data assessment efforts 

would not require producing new research or conducting new data collection efforts, but rather 

would rely on existing publications or previous efforts to research or collect such data. 

The Panel proposes that aquatic ecosystem cumulative impacts be evaluated from at least 

five perspectives: (i) spatial; (ii) temporal; (iii) river continuum; (iv) food-web; and (v) 

synergistic. Each of these perspectives is described further below. To better understand the 

context of these recommended perspectives, some background discussion is also provided. 

MTM-VF operations under review in this document occur in a landscape that was historically 

old growth forest and is presently mostly second growth forest. In addition, some of the areas 

were previously mined, and in such areas current mining represents re-mining efforts. Thus, a 

forested landscape is the natural ecological setting within which the terrestrial and aquatic 

ecosystems under consideration have developed and into which MTM-VF operations described 

in the draft EPA report have been implemented. In the simplest of terms, MTM-VF operations 

in this region, regardless of scale, involve the deforestation of a significant patch of local interior 

forest, removal of substrate from the mountaintop and placement into the adjacent headwater 

stream valley, and revegetation of both the valley fill and the mined area after the coal has been 

removed. Thus, potential ecological impacts of MTM-VF operations accrue from the loss of 

interior forest and aquatic habitat and their associated populations/communities of organisms in 

response to both direct impact of the operations themselves and indirect effects (downwind or 

downstream) from them. In that context, cumulative impacts: (i) occur when the overall spatial 

or temporal impact is immediately greater, or gradually becomes greater, than the sum of the 

individual impacts; and (ii) should be evaluated from several different perspectives because of 

the four dimensional aspects of terrestrial and aquatic ecosystems. For all practical purposes, the 

term aquatic ecosystem here refers largely to streams and rivers. The four dimensions of 

ecosystems (i.e., vertical, latitudinal, longitudinal and temporal) should be clearly defined in the 

text of the report.
32

For evaluating cumulative impacts in streams and rivers, it is assumed that the upstream 

to downstream nature of flow provides a high degree of ecological interconnectivity and 

interdependence within the ecosystem. Moreover, this unique characteristic may make streams 

and rivers more vulnerable than terrestrial ecosystems to both the individual and cumulative 

effects of point and non-point source changes in a given watershed. Thus, potential impacts 

from upstream watershed activities, both positive (e.g., water and chemical/particulate food 

inputs, shade, in-stream processing of nutrients and pollutants) and negative (e.g., loss or 

modification of water/food inputs, shade, addition of pollutants), can and do reverberate in a 

downstream direction. 

To help provide additional relevant literature regarding the cumulative ecological impacts 

of filling headwater streams with mining waste on terrestrial and aquatic ecosystems, EPA

should consider gathering and evaluating data on long-term cumulative impacts on second-order 

streams within larger watersheds, either through conducting future research efforts to gather this 

data, or by mining data that has been published in existing literature (such as from peer-reviewed 

symposium papers including those within the Proceedings of the American Society of Mining 

and Reclamation). Additional relevant literature on these impacts may also be evident in 

published data on community structure (e.g., loss of taxa in certain functional groups described 

in Howard et al. (2001), Hartman et al. (2005), Merricks et al. (2007), and Pond et al. (2008)) or 

might be gleaned from archived tissue analyses or from freshly collected samples of taxa 

representing certain trophic levels along a gradient downstream from the MTM-VF sites in a 

watershed (as suggested by Conley et al.’s ( 2009) recent experimental evidence with selenium). 

Such data assessment efforts would not require producing new research or conducting new data 

collection efforts, but rather would rely on existing publications or previous efforts to research or 

collect such data. 

3.5.2. Specific Comments (Aquatic Ecosystems)

The Panel proposes that for aquatic ecosystems, there are at least five perspectives from 

which to evaluate cumulative impacts:

3.5.2.1. Evaluate cumulative impacts through Spatial perspectives: Do the downstream 

effects from a series of repeated MTM-VF’s being implemented in a given watershed have a 

greater overall spatial effect than the sum of their individual effects? What is the comparative 

impact of downstream cumulative impacts (indirect) versus the individual local impacts? 

Specifically, is there a threshold of repeated MTM-VF’s that – once exceeded – yields 

significant downstream impacts?

Examples: If MTM-VF reduces summer baseflow in two or more headwater (i.e., first or 

second order) streams in a watershed, does this translate into summer baseflow falling below 

some critical “minimum flow requirement” in downstream tributaries? If individual MTM-VF 

operations elevate some pollutant (e.g., selenium) to levels that are significantly above 

background and have a toxic effect, does the confluence of tributaries carrying this pollution 

with other, uncontaminated tributaries result in a tributary carrying a toxic load even though 

there are no MTM-VF operations located on it? If MTM-VF caused slight warming of small 
33

individual headwater tributaries, does this accumulate and cause significant warming (i.e., 

exceeding some threshold) of downstream reaches? 

From this perspective, relevant information would be any detailed physical, chemical, or 

biological stream data at or near two or more of the MTM-VF operations within a given 

watershed as well as two or more points in the drainage downstream from all of the point source 

operations. From an analytical perspective, it would be relevant to determine if the changes 

appear to be additive or multiplicative, or linear or non-linear. 

In addition, it is important to gather and assess relevant information on the area and 

volume of earth movement associated with MTM-VF operations, the percentage change in 

vegetation cover and type that has occurred in a watershed from these operations based on premine vs. post-mine land use, and the proximity of these activities to the streams. The numbers of 

mining permits and amount of permitted fill area (which has been exceeded in many cases) are 

not adequate measures of mining activity. EPA should consider conducting or reviewing 

previously performed comprehensive remote sensing and air photo interpretation analyses to 

adequately understand the extent and distribution of valley fill activities. Such information 

should be publicly available to allow analysis within and across regions. EPA should consider 

gathering and evaluating existing, available data, or consider conducting future research efforts 

to produce this data.

Relevant information could also be gleaned by analogy from careful mining of existing, 

available data for pollutants not necessarily associated with MTM-VF (e.g., acid mine drainage, 

watershed urbanization). For example, the cumulative impacts of acid mine drainage (AMD) 

were widely published such as within the Proceedings of the American Society of Mining and 

Reclamation and might be a good analog for MTM-VF induced changes in chemistry such as 

conductivity. AMD is chemical, rather than biological or physical, in nature, is produced as a 

point source (similar to MTM-VF) usually in headwater streams, has a distinct signature (pH) 

which can be readily measured (similar to the readily measured conductivity), is known to be 

toxic to macroinvertebrates and fish, and is not confounded by certain other factors which can be 

common in streams (e.g., sediment). There are confounding factors (such as aluminum toxicity) 

but they are well known and can be factored into the analysis. There are also several geographic 

regions of the country impacted by AMD drainage. There are existing, available studies in most, 

if not all regions, demonstrating the cumulative impact of AMD (see Geidel and Caruccio, 1982; 

Soucek et al., 2000; Niyogi et al., 2001; and Carlisle and Clements, 2005). For example, the 

mainstem of the West branch of the Susquehanna River is significantly impacted by AMD 

chemistry but most of it represents the cumulative impact of over a thousand miles of AMD 

impacted headwater streams located significant distances upstream from the mainstem. Such 

data assessment efforts would not require producing new research or conducting new data 

collection efforts, but rather would rely on existing publications or previous efforts to research or 

collect such data. 

EPA should also assess river continuum perspectives and related effects to aquatic life 

(discussed further below). 
34

3.5.2.2. Evaluate cumulative impacts through Temporal perspectives: Do the cumulative 

downstream effects from one or more MTM-VF’s being implemented in a given watershed 

increase with time? 

Examples: Does the persistent release of a contaminant (e.g., Se) at low, non-toxic levels 

from one or more MTM-VF’s gradually result in a high level, toxic exposure for downstream 

ecosystems through processes such as in-stream storage/sequestration, chemical transformation, 

or bioaccumulation? Do localized reductions in population size for key aquatic species due to 

stress related to changes in habitat associated with MTM-VF operations set the stage for 

extirpation of the taxa due to the regional impact of low recruitment from lost genetic structure 

such as from inbreeding due to small effective population size, or additional mortality related to 

random stochastic events (e.g., floods, droughts)? Do elevated, unnatural levels of contaminants, 

substances, or habitat factors associated with MTM-VF operations gradually decline to natural, 

quasi-natural, or non-toxic levels due to in-stream biogeochemical transformation and/or 

processing or other mitigating agents?

From this perspective, relevant information would include quantitative (e.g., flow), 

physical, chemical, or biological parameters collected ideally before, during, and after one or 

more MTM-VF operations within a given watershed, but with the emphasis on a time series of 

measurements taken “after” for a given parameter. Post operation studies of long lived species 

such as mussels, which were not included in most MTM-VF effect studies, could be a good 

source of information in this arena. 

Similar to the discussion above, relevant information could also be gleaned by analogy 

from careful mining of exiting, available cumulative impact data for other non-MTM-VF 

pollutants (e.g., PCB’s, metals, pesticides, and pH). For example, the cumulative impacts of 

DDT, mercury, and other contaminants were widely studied in aquatic ecosystems (Niemi et al.,

1990). Such data assessment efforts would not require producing new research or conducting

new data collection efforts, but rather would rely on existing publications or previous efforts to 

research or collect such data. 

3.5.2.3. Evaluate cumulative impacts through River Continuum perspectives: Does the 

loss of ecosystem function in one or more MTM-VF headwater streams produce a negative

effect on the structure and/or function of larger downstream ecosystems? 

It is suspected that the loss of ecosystem function in one or more MTM-VF headwater 

streams may have detrimental effects, but the Panel is uncertain of the strength of the literature 

support for this idea. EPA should conduct an additional review of available peer-reviewed 

literature on this topic, not necessarily limited to cumulative impacts associated with MTM-VF, 

to provide context. Such data assessment efforts would not require producing new research or 

conducting new data collection efforts, but rather would rely on existing publications or previous 

efforts to research or collect such data. 

Background: First order streams flowing through forests receive large amounts of 

particulate organic matter (e.g., leaves, fruits, seeds, flowers, twigs, branches) and dissolved 

nutrients such as nitrogen, phosphorus, and carbon that fall or wash into them from the terrestrial 
35

environment. Most of this “food” material is processed and tied up in the food web, lost through 

respiration, or exported downstream. Downstream exports from functional headwater streams 

are substantial (see Fisher and Likens, 1973; and Webster and Meyer, 1997) and these exports 

support downstream ecosystem processes (see Mulholland and Rosemond, 1992; Cole and 

Carco, 2001; Kaplan et al., 2008; and Battin et al., 2008). The cumulative impact of removing a 

large fraction of the headwater streams from a river network is not amenable to experimental 

examination. However, modeling and mass-balance studies indicate that permanent loss of 

cumulative exports from several headwater streams could substantially affect the microbial 

processes and potentially the invertebrate and fish productivity of downstream reaches (see 

Meyer and Wallace, 2001; Newbold et al., 2002; and Wipfli, 2005). 

Downstream reaches may hold the greatest number of rare, endangered, and sensitive 

species as well as sought-after sport fish (e.g., trout and smallmouth bass). Increasing loads of 

dissolved materials that are not readily reduced in concentration except by dilution would only 

increase over time with increasing numbers of MTM-VFs. The populations of amphibians are of 

particular concern related to downstream cumulative impacts, and these species were not 

assessed in depth in the draft EPA report. Larger streams in the geographic areas addressed by 

the draft EPA report can harbor populations of hellbenders (Cryptobranchus alleganiensis) 

which are already in decline and could suffer from increasing salinity.

Example: Is the amount of downstream microbial production and biomass limited by the 

lack of downstream transport of labile dissolved organic matter (LDOM) from headwater 

streams impacted by valley fill? 

Evaluating these types of cumulative impacts becomes, almost by default, a modeling 

exercise of the production, downstream routing, and reutilization of organic matter or nutrients 

(e.g., LDOM model in a fifth order basin).

In addition, the cumulative impacts on flow paths and residence times of water should be 

considered more closely, particularly regarding how such impacts that may be indicated in 

headwater streams result in such impacts in downstream waters. The draft EPA report should 

assess whether MTM-VF affects flow and flow regimes downstream, and, if so, how in turn does 

this affect aquatic life. 

3.5.2.4. Evaluate cumulative impacts through Food Web perspectives: Do food web 

impacts downstream of one or more MTM-VF’s develop in a cumulative fashion as an upward 

cascade from lower to higher trophic levels due to differences in exposure mechanisms (e.g., 

vulnerable physiology vs. bioaccumulation)? Do changes in downstream functional feeding 

groups reflect altered food inputs due to VF?

Selenium may occur at low, non-toxic, but persistent levels below MTM-VF’s initially 

but, because of its lipophilic nature, could gradually reach levels in the tissue of stream 

organisms that are toxic or debilitating. Similarly, some food inputs may be conspicuously 

reduced or missing below MTM-VF’s (e.g., whole leaves, large woody debris) which, in turn, 

could simplify the food web and cause the extirpation of certain taxa (e.g., caddisfly genus Lype

which feeds on woody debris) or functional feeding groups (e.g., shredders, miners). Tests on 
36

salamanders as well as brook trout would be recommended to assess such impacts. EPA should 

consider gathering and evaluating existing, available data to assess this issue. Such data 

assessment efforts would not require producing new research, but rather would rely on existing 

publications or previous efforts to produce such research information. 

Additional relevant literature on cumulative food web impacts may also be evident in 

published data on community structure (e.g., loss of taxa in certain functional groups described 

in Howard et al. (2001), Hartman et al. (2005), Merricks et al. (2007), and Pond et al. (2008)) or 

might be gleaned from archived tissue analyses or from freshly collected samples of taxa 

representing certain trophic levels along a gradient downstream from the MTM-VF sites in a 

watershed (as suggested by Conley et al.’s [2009] recent experimental evidence with selenium). 

Such data assessment efforts would not require producing new research or conducting new data 

collection efforts, but rather would rely on existing publications or previous efforts to research or 

collect such data. 

3.5.2.5. Evaluate cumulative impacts through Synergistic perspectives: Do the impacts 

associated with MTM-VF interact among stressors associated with mixed land use in the 

watershed (e.g., forest clearing, agriculture or urbanization) or with more regional stressors (acid 

rain, atmospheric deposition of nutrients, climate change)?

In terms of synergistic cumulative impacts associated with interactions among stressors, 

the relationship between MTM-VF stressors and those associated with other watershed 

alterations have apparently not been pursued. Studies on interacting stressors should be included 

in the EPA review. Some confounding stressors can be tested and evaluated with existing, 

available data (see example citations noted below). Such data assessment efforts would not 

require producing new research or conducting new data collection efforts, but rather would rely 

on existing publications or previous efforts to research or collect such data. For example, it is 

known that the toxicity of many compounds is, in fact, dependent on temperature and the level of 

hardness of the water. Thus, the extent to which clear cutting and ponding of water associated 

with MTM-VF increases stream temperature and could or does exacerbate the toxicity of 

suspected key factors should be considered. In addition, some potentially toxic substances (e.g., 

Se) may reach toxic levels only after cross contamination with inputs from other land uses (e.g., 

application of pesticides especially fungicides for agriculture). A few studies that have reported 

an interaction between chemical stressors and regional factors include Brooks et al. (2007), 

Clements et al. (2008), Paine et al. (1998), and Schindler et al. (1990).

As an alternative to the above, the Panel also briefly considered the following approach 

to viewing cumulative impacts by dividing them as follows: 

(i) time (i.e., slow vs. fast responses, and the associated continuum)

(ii) space (see above)

(iii) activities (see synergistic cumulative impacts above: target contaminant + x + y + z 

and so forth)
37

(iv) biotic responses (how many response variables need to change by how much before 

the system no longer functions normally?)

3.5.3. Specific Comments (Terrestrial Ecosystems)

For evaluating the cumulative impacts on terrestrial ecosystems eliminated by MTM-VF 

operations, the Panel proposes that equal consideration needs to be given to the negative impacts 

associated with forest fragmentation (e.g., loss of interior forest, loss of forest due to road 

construction) and degradation of interior forest at the periphery of MTM-VF sites, as well as 

potential positive cumulative impacts associated with the new, altered terrestrial ecosystems left 

behind. Certain types of alteration may be considered positive in some aspects and negative in 

other aspects (e.g., conversion to grassland is positive for some wildlife but negative for interior 

birds). In particular, potential negative ecological impacts from MTM-VF activities such as 

mountaintop preparation, deforestation, access road building, and use of explosives were not 

taken into account in the draft EPA report and should be considered. These potential negative 

impacts and the fate and transport of contaminants released from such activities should be 

assessed by EPA. Such data assessment efforts would not require producing new research or 

conducting new data collection efforts, but rather would rely on existing publications or previous 

efforts to research or collect such data. 

Cumulative negative impacts accrue both directly and indirectly. Direct impacts include 

the permanent loss of interior forest and replacement with a more simplified terrestrial 

ecosystem (usually grassland). This process fragments species associated with the remaining 

interior forest of the region and creates areas of unnatural local habitat colonized by species 

whose populations are highly fragmented due to the patchy nature of the new habitat. It is well 

known that the local abundance of almost every breeding species studied in the interior of upland 

forests is significantly influenced by factors such as reduced forest area, increased isolation, and 

loss of structure (e.g., Lynch and Whigham, 1984; Villard et al., 1999). Unlike streams, where 

locating MTM-VF’s in nearby but different watersheds might help ameliorate downstream 

cumulative effects from a high density of sites, increased density of MTM-VF sites causes 

cumulative impacts to the overall forest and these impacts ignore watershed boundaries. 

The draft EPA report should recognize and consider the relationship between the impacts 

due to MTM-VF and extent of impact from other land uses. Cumulative direct impacts on 

terrestrial ecosystems due to forest removal associated with MTM-VF currently remain 

theoretical due to lack of published data but reasonable estimates of the degree and extent of 

impact might be gleaned from published literature on forest fragmentation associated with other 

land uses that involve deforestation (e.g., Whitcomb et al., 1981; Gibbs, 1998; Brown et al., 

2000). Such data assessment efforts would not require producing new research or conducting

new data collection efforts, but rather would rely on existing publications or previous efforts to 

research or collect such data. 

A recent analysis shows that a cumulative effect of MTM-VF is loss of interior forest 

loss that was 1.75–5.0 times greater than the direct forest loss attributable to the practice (~1,540 

km^2 between 1992-2002) (Wickham et al., 2007). The loss of Southern Appalachian interior 

forest is of global significance because of the worldwide rarity of large expanses of temperate 
38

deciduous forest. In some respects, however, the effects of these other conversions will likely 

differ markedly from MTM-VF. For example, data from Ohio and other agriculturally drained 

streams in the Midwest has identified that cumulative loss of habitat has over the past 100 years 

caused the extirpation of sensitive species from watersheds and basins and lead to broadly 

degraded aquatic assemblages (see Karr et al., 1985; Trautman, 1981; and Williams et al., 1989). 

It is difficult to detect the short-term gradual changes in aquatic assemblages in response 

to gradually increasing stressor loads that might accrue over time. Species can often persist for 

years or decades until a combination of natural events (e.g., drought) and anthropogenic stressors 

result in local extirpations (e.g., Frissell and Bayles, 1996). Indirect impacts result because 

factors associated with deforestation of the MTM-VF sites penetrate the residual forest 

surrounding each site and cause gradual and cumulative changes (mostly negative), especially to 

the understory and associated wildlife. Penetrating factors include, among other things, 

increased levels of light and temperature, decreased levels of moisture (e.g., Gergel et al., 2002; 

Turner et al., 2005), and higher density of herbivorous mammals and parasitic birds. These 

indirect effects mean that the scale of the overall impact of deforestation due to MTM-VF’s on 

interior forest habitat of a region is greater than the sum of the absolute total loss of forest 

associated with the specific MTM-VF’s. Measurements of the cumulative indirect impact might 

include the gradual increase in certain penetrating factors. For example, an increase in species 

such as deer, elk or invasive plants in edge-of-woods habitat surrounding the MTM-VF’s or an 

increase in invasive species preferring grassland habitat bordering woods such as cowbirds 

which negatively affect nearby forest-nesting bird species may occur.

The Panel also felt that inclusion of birds and bats that rely on adult forms of aquatic 

insects and even mammals such as raccoon, opossum, and mink that are typically water-oriented 

also bear mention even if indirect effects are likely difficult to quantify. The report should 

further discuss the impact of loss of headwater streams on amphibian populations. For example, 

over 10% of the world’s salamander diversity is found in this region and headwater streams are 

critical to their existence (Hairston, 1949; Jaeger et al., 1998; Grant et al., 2009). The importance 

and diversity of amphibian taxa other than salamanders should also be emphasized in the draft 

EPA report. 

Another potentially important component could be interactions between pH and algal 

production. Significant pH swings related to photosynthetic activity resulting from increased 

light and nutrients could cause metals—already at higher concentrations in MTM-VF streams 

than reference streams—to come in and out of solution, potentially increasing toxicity. 

As noted above, although forest fragmentation is generally viewed as one of the greatest 

threats to biodiversity in forests, one could view some of the cumulative impacts associated with 

permanent conversion of interior forest to grassland as being beneficial. For example, creating 

new habitat for species such as elk, deer, or native grassland species of birds could be viewed as 

a positive effect associated with forest fragmentation in a forested area where such habitat is 

rare. Moreover, patches of grassland habitat could have a beneficial effect by increasing the 

regional population size and facilitating gene flow for grassland species (Partel et al., 2005),

although this must be balanced against the loss of regional biodiversity in a region where 

biodiversity is among the greatest in the world. 
39

However, it must be recognized that these same benefits come at a cost to interior forest 

species (e.g., Semlitsch et al., 2009; and Blomquist et al., 2010) where forest fragmentation can 

reduce population viability. Currently, it is not clear that there are sufficient data available to 

quantify the short and long-term (cumulative) benefits and costs associated with the type of 

ecological trading that has been and is being precipitated by MTM-VF. Existing, published

studies of clear cut timber harvesting may be worth mining as they could provide good insights 

into the potential impacts of this ecological trading. Such data assessment efforts would not 

require producing new research or conducting new data collection efforts, but rather would rely 

on existing publications or previous efforts to research or collect such data. 

Also, given the limited available data, perhaps the draft EPA report should include 

additional comparison of how MTM-VF effects may be similar or different from urban and 

agricultural impacts where cumulative effects have been documented. 

In addition, EPA should assess whether potential bioaccumulative effects to the food web 

appear to be additive or multiplicative, or linear or non-linear. 
40

3.6. Effectiveness of Restoration Methods

Charge Question 6: The Surface Mining Control and Reclamation Act and its implementing 

regulations set requirements for ensuring the restoration of lands disturbed by mining 

through restoring topography, providing for post-mining land use, requiring re-vegetation, 

and ensuring compliance with the Clean Water Act. Does the review appropriately 

characterize the effectiveness of currently employed restoration methods?

3.6.1. General Comments

The Panel believes that currently employed restoration methods are neither well defined 

nor well implemented, and that it is essential to understand restoration effectiveness, 

shortcomings, and potential for improvement in order to best manage impacts from MTM-VF. 

The Panel also agrees with EPA’s contention that there is little published evidence that current 

restoration approaches are effective in recovering aquatic ecosystem functions that have been 

lost as a result of MTM-VF. 

The review of restoration effectiveness would be improved by reorganizing this section 

under two major subheadings: “On-Site Reclamation” and “Off-Site Mitigation, citing certain 

available literature on the topic of restoration effectiveness, and identifying the most important 

shortcomings of current reclamation processes related to aquatic resources. EPA should define 

restoration objectives, show how restoration can be used within the permitting process to ensure 

maintenance and improvement of watershed scale conditions, and discuss the relevance of state 

water quality standards and spatial and temporal boundaries associated with meeting restoration 

objectives. The Panel also provides various recommendations for improving the discussion on 

restoration within the draft EPA report, and suggestions for research needs and additional 

references that should be considered.

3.6.2. Specific Comments

3.6.2.1. Objectives of Restoration: The effectiveness of currently employed restoration 

methods cannot be evaluated without a statement regarding the objectives of restoration. 

EPA should address the following issues as they relate to restoration objectives:

The term “restoration” must be explicitly defined. There is considerable debate in the 

literature regarding what is meant by the term restoration (e.g., Higgs, 1997). For some, 

restoration implies full recovery of ecosystem structure and function to conditions that precede 

any human impact. This sets restoration apart from related terms such as reclamation, 

rehabilitation, enhancement, and mitigation. Recently, there has been emerging consensus that 

“restoration” encompasses all actions designed to recover all or part of ecosystem functions lost 

due to development activities. Following this trend, EPA should consider defining restoration in 

the current context as “all reclamation and mitigation actions designed to recover ecological 

functions lost as a result of MTM-VF mining.” 
41

The charge question refers to all Federal Surface Mining Control and Reclamation Act 

of 1977 (SMCRA) requirements, including topography, land use, re-vegetation, and compliance 

with the Clean Water Act (CWA). Based on discussion with EPA at the July 20-22, 2010 

meeting, it does not appear that the draft EPA report is seeking to address all of these 

requirements, but rather is focused on compliance with the CWA only. Assuming this, EPA 

should use the report as an opportunity to address this question: “To what extent has it been 

shown that on-site reclamation and off-site mitigation (such as old mine retrofitting, stream 

channel restoration, riparian revegetation, acid mine drainage remediation, or municipal waste 

water treatment) are effective in restoring aquatic ecosystem function that is lost or degraded as a 

result of MTM-VF?”

ORD should discuss how a state’s water quality standards are relevant to meeting 

restoration objectives within the draft EPA report. The definition of restoration should take into 

consideration how the restoration of surface mined areas relates back to the link with water 

quality standards. States designate their waters with regard to potential use which affects how 

their water quality standards would be set. The designated uses of the waters within state water 

quality standards would assist in clarifying restoration objectives and potential for success within 

a water body. The discussion should include a regulatory context regarding whether the CWA 

Section 404 permitting process allows the filling of valley areas and when or whether such 

filling constitutes the removal of an aquatic life use in the small headwater streams in the valley 

fills, and whether States have assigned aquatic life uses to these streams. The discussion should 

also include whether such fill would be considered an impairment to a use and whether such fill

would affect the protection of downstream uses. EPA should also consider adding discussion on 

situations where states have only designated a single aquatic life use to reflect the wide range of 

potential aquatic life uses within its streams. This discussion should also consider related issues 

such as the difficulty in differentiating between ephemeral and intermittent streams and the 

inability to distinguish between high quality waters (either in the headwaters or further 

downstream), more “typical” waters, or more limited waters (i.e., those already affected by 

historical mining) with single aquatic life use designations, and the difficulty of customizing 

protection or restoration efforts in streams and watersheds with such aquatic life use 

designations. 

The final issue relating to restoration objectives has to do with spatial and temporal scale. 

Several questions arise related to these objectives that should be considered by EPA when 

assessing restoration effectiveness. For example, does the draft EPA report seek to describe 

restoration effectiveness only at the localized stream segment scale or does it include larger 

watershed scales? Likewise does the draft EPA report seek to describe near-term and long-term 

effectiveness of restoration actions? Over what time frames should conductivity and aquatic life 

be measured to assess effectiveness of restoration objectives? Where should conductivity and 

aquatic life be measured, given that the inflows and outflows to the region may have completely 

changed before and after a MTM-VF operation? If there is poor conductivity at first, does this 

last for the long term? How is conductivity quantified given natural variability over flow 

regimes? Regarding when to measure – should measurements occur during periods in the life 

cycle of the aquatic response variables? Is restoring “good” conductivity sufficient to ensure 

success in terms of protecting aquatic life? How should habitat be quantified and defined, both 

before and after restoration occurs? These are important questions because restoration objectives 
42

must be set, and ultimately assessed, within a spatial and temporal scale context. The draft EPA 

report should define restoration objectives within the spatial and temporal scales of interest. 

Also, EPA should consider developing a case study for the draft EPA report that highlights key 

considerations for EPA-decision-making, to help the reader more fully understand how 

restoration objectives should be identified and assessed.

Helpful citations can be found in the attached References. The attached References 

include papers on the importance of setting objectives for restoration as well as papers on the 

effectiveness of restoration.

3.6.2.2. Reorganize Section: The review of restoration effectiveness would be improved by 

organizing this section around two major subheadings: “On-Site Reclamation” and “OffSite Mitigation.”

The review of restoration effectiveness would be improved by reorganizing the draft EPA 

report’s discussion on restoration under two major subheadings: “On-Site Reclamation” and 

“Off-Site Mitigation, citing certain available literature on the topic of restoration effectiveness, 

and identifying the most important shortcomings of current reclamation processes related to 

aquatic resources. 

On-Site Reclamation

The draft EPA report should discuss current mine reclamation efforts within the historical 

context of SMCRA implementation. It is particularly important to consider the significant 

progress that has been made over the past 30+ years, especially as it relates to: slope stability, 

soil development, reforestation, revegetation, storm-water control, sediment reduction, and acid 

mine drainage prevention and minimization. The CWA emphasizes “progress” with regards to 

environmental protection and impact minimization. Therefore, in order to properly assess the 

current management of surface mining impacts, EPA must consider current shortcomings within 

the context of historical progress. Only then can the following question be answered: Are we 

making progress with regards to mine reclamation and mitigation?

The reclamation methods that have become most extensively used are grounded in more 

than just the current SMCRA recommendations. In the Appalachian ecosystems addressed by 

this document, SMRCA was concerned with the impacts of surface mining on hydrology (both 

surface and groundwater quality and quantity), soil erosion and development, and aesthetics. 

The lack of success reforesting surface mines, coupled with stream sedimentation and decreased 

water quality, impacted the decisions for the early SCMRA reclamation. Some state laws were 

more effective than others at protecting the water and terrestrial environments. Reclamation 

initially applied a preference for herbaceous ground cover to limit erosion, decrease impacts on 

stream water quality and improve soil development processes. Under this phase of SMCRA, 

storm-water and surface water were controlled, AMD impacts were decreased with metal and pH 

improvement, sulfide oxidation was minimized, mine soils were improved, and slope stability 

issues, especially with regard to mountaintop mine-valley fills, were controlled. Recent 

advances in revegetation, reforestation and soil development on reclaimed mines have been 

dramatic (see Ashby, 1999a and 1999b; Burger et al., 2009; Burger et al., 2005; Groninger et al., 
43

2007; and Sweigard et al., 2007a). The Proceedings of the American Society of Mining and 

Reclamation is an invaluable resource for peer-reviewed articles on surface mine reclamation. 

An example paper from these Proceedings includes Chermak et al. (2004). In addition, recent 

advances in mine reclamation processes allow for reforestation (e.g., the Forestry Reclamation 

Approach). For example, the Appalachian Regional Reforestation Initiative, a cooperative effort 

of citizens, the coal industry, and government (such as between the U.S. Office of Surface 

Mining and Appalachian States), has been successful in helping to restore forests on 

mountaintop mining sites (see http://arri.osmre.gov/). 

Once it has been acknowledged that there have been dramatic improvements in mine 

reclamation, then it should be possible to reach objective conclusions regarding current 

reclamation shortcomings. It also should be possible to assess whether there is any published 

evidence that the current shortcomings can be addressed through improved reclamation 

procedures. The Panel encourages EPA, through a review of the published literature, to identify 

the most important shortcomings of current reclamation processes as it relates to aquatic 

resources. The Panel understands that there are very few, if any, studies that have addressed this 

question directly within the MTM-VF region. Such data assessment efforts would not require 

producing new research or conducting new data collection efforts, but rather would rely on 

existing publications or previous efforts to research or collect such data. 

Off-Site Mitigation

ORD decided to omit the topic of off-site mitigation in the original draft of the draft EPA 

report. The Panel believes that the topic is too important to avoid, and thus encourages EPA to 

add a section on off-site mitigation in a revised document. It is impossible to fully assess the 

effectiveness of restoration as currently practiced without considering off-site mitigation, 

because it is such an important part of the MTM-VF permitting process. Based on current 

literature, on-site reconstruction of stream channels on mined lands have not been able to fully 

recover lost ecosystem functions (Bradshaw, 1997). Consequently, off-site mitigation has been a 

means for filling the lost function gap. Determining whether or not this is happening and 

whether or not mitigation actions can be improved must be a central part of future permitting 

procedures. EPA should assess current literature on the recovery of on-site reconstruction of 

stream channels and cite literature within the report regarding this topic. Such data assessment 

efforts would not require producing new research or conducting new data collection efforts, but 

rather would rely on existing publications or previous efforts to research or collect such data. 

The Panel is not aware of published research on the effectiveness of stream restoration as 

a form of mitigation in the MTM-VF region. Consequently, the Panel encourages EPA to assess 

the potential effectiveness of mitigation with reference to the general stream restoration literature 

(several papers are listed in the attached bibliography). Most studies of the effectiveness of 

stream restoration suggest that there are few “functional” benefits from structural restoration, 

with a few notable exceptions (e.g., Lepori and Palm, 2005). Of greatest concern, however, is 

that the Panel is not aware of any published studies indicating that structural restoration is 

capable of meeting water quality goals related to conductivity and elevated TDS. Consequently, 

it is very unlikely that current mitigation procedures are having any positive effect on reducing 

important potential MTM-VF stressors related to TDS and/or conductivity. These recommended 
44

data assessment efforts would not require producing new research or conducting new data 

collection efforts, but rather would rely on existing publications or previous efforts to research or 

collect such data. 

3.6.2.3. Watershed Scale: On-site reclamation and off-site mitigation are part of a broader 

process designed to restore and protect aquatic functions at a watershed scale.

Restoration is one component of a complex process needed to manage impacts associated 

with MTM-VF. In recognition of this, the Panel encourages EPA to: (1) discuss explicitly how 

restoration fits into the causative flow diagram (Figure 12 of the draft EPA report, and Appendix 

2 of this SAB Report); and (2) show how restoration can be used within the permitting process to 

ensure maintenance and improvement of watershed scale conditions.

Figure 12 already includes some reference to the role of reclamation in affecting the 

causative pathways linking MTM-VF to aquatic impacts (e.g., reduced sedimentation). The 

Panel encourages the addition of other ways that on-site reclamation and off-site mitigation 

could be used to minimize impacts and maximize watershed scale conditions in addition to 

adding it as a human activity.

Lastly, restoration is a critical element of a holistic process of managing impacts from 

MTM-VF. A successful management program will include various components related to 

restoration, and the Panel encourages EPA to incorporate these components of restoration into 

the causative flow diagram. These components include:

• Identification and long-term protection of relatively large blocks of undisturbed 

headwater catchments to serve as a source of dilute freshwater and sensitive lotic 

taxa;

• Setting mining intensity thresholds or development intensity thresholds for sensitive 

watersheds to ensure maintenance of downstream conditions;

• Development and implementation of best management practices for surface mine 

reclamation that are designed to minimize conductivity, minimize sulfide oxidation, 

maximize sulfate reduction, and maximize ecosystem functions of reconstructed 

stream channels on reclaimed mines; and

• Use of off-site mitigation as a way to target dominant limiting factors in a region and 

maximize recovery of aquatic ecosystem functions at a watershed scale.

Within the draft EPA report, EPA should consider discussing which is the preferred 

restoration approach: on-site restoration (e.g., stream reconstruction) or off-site mitigation (e.g., 

improved water treatment systems). This discussion may assess whether both approaches should 

be required, whether EPA has the authority to require off site mitigation, whether the mining 

companies have the authority and/or desire to pay for off-site mitigation, and whether the public 

sees on-site and off-site restoration as equivalent approaches for protecting the environment in 

MTM-VF operations.
45

3.6.2.4. Other Considerations

As with on-site reclamation, it is critical for EPA to examine the potential for improved 

mitigation procedures moving forward. The Panel believes that the draft EPA report should 

recognize that there are opportunities to improve the mitigation process through three lines of 

action:

1. Retrofitting old mines using procedures to minimize conductivity, maximize sulfate 

reduction, and maximizing ecosystem function of perimeter sediment channels (see 

discussion above under “on-site reclamation”).

2. Enabling municipal waste water treatment in the surrounding areas as a form of 

mitigation for mining impacts. Merriam et al. (In Review) demonstrated that the effects 

of mining and untreated wastewater interact to produce highly impaired stream 

conditions in some areas of the central Appalachians. Consequently, it should be 

possible to achieve measureable benefits through improved waste water treatment. The 

Panel recommends that the draft EPA report assess and perhaps encourage the use of 

wastewater treatment as a form of mitigation for mining related impacts due to the 

potential for resultant significant improvements in aquatic resources at the whole 

watershed scale.

3. Allowing structural restoration as a form of mitigation, but only in cases where 

quantitative watershed assessment has identified degraded physical habitat as a dominant 

factor limiting the condition of aquatic resources in the region. If elevated ions resulting 

in higher conductivity and/or poor wastewater services are dominant stressors in a 

watershed, then it does not make sense to invest resources in stream channel restoration. 

However, in some areas of the Appalachians, it is possible that degraded structural 

habitat is the dominant stressor limiting ecological functions. In cases such as this, it 

should be possible to use structural enhancements as a form of mitigation and a means 

for increasing watershed condition.

Several recent studies call into question the value of stream channel reconstruction in 

restoring natural stream functions (see Palmer et al., 2005; and Palmer and Allan, 2006). 

Despite the evidence that reclamation methods are improving, the current literature questions 

whether stream channel reconstruction can effectively restore natural stream functions. This is 

based on: (1) a general understanding about the difficulty of reconstructing stream channels that 

function naturally (see Palmer et al., 2005; and Palmer and Allan, 2006); (2) a basic 

understanding of stream ecology; and (3) published studies that have quantified downstream 

impacts (see Harrison et al., 2004; Lepori et al., 2005; Merovich and Petty, 2007; and Sudduth 

and Meyer, 2006). As indicated in the literature, effective restoration is particularly difficult on 

surface mines because of the diverse geology and rock fragment which, without high quality 

control construction oversight, results in infiltration rates that tend to create reconstructed 

channels that are dry except following heavy rain events (see Geidel and Caruccio, 1982). 

However, restoration efforts have improved and stream channels have been reconstructed. 

Further discussion is provided below on this topic.
46

Stream ecologists have spent much of the past 30 years working to elucidate the 

mechanisms of stream ecosystem processes. From this research, it is known that critical 

headwater stream functions include: habitat for sensitive, stream dwelling invertebrates 

(mayflies especially) and amphibians (stream salamanders); source of dilute, freshwater; detritus 

based food webs; and delivery of carbon and nutrients downstream (see Meyer and Wallace, 

2001). Although the effects of MTM-VF on all of these functions have not been thoroughly 

examined, the Panel believes that current reclamation approaches are not likely to be effective in 

recovering all of these functions.

Some of the data presented indicates that MTM-VF effects on downstream ecosystems 

show elevated TDS and in some cases Se as important stressors. However, the data upon which 

these effects are based compare mined and/or filled areas versus unmined areas with no 

comment regarding the potential differences in geology. Differences in background water 

quality based on the environment of the coal deposition have been long known (Caruccio et al., 

1977). While this information suggests that current reclamation processes are not completely 

effective in controlling TDS levels and associated increases in conductivity, the EPA should 

clearly define or recognize the range of variation of stratigraphic sequences for which 

conductivity and Se may reach problematic levels. 

In the draft EPA report’s Section 7.1.2 “Reclamation Bonds” discussion, several 

statements suggest potential difficulties in developing successful restoration. This discussion 

includes statements on the release of bonds upon completion of revegetation activities, and 

statements noting that reclamation to forested land is preferred. These statements both require 

further evaluation and discussion within the draft EPA report regarding the long-term success of 

such options. In addition, the draft EPA report should also consider assessing existing, 

published studies and research that emphasize typical restoration methods and benefits for 

planting grasses, often non-native, instead of forests. Such data assessment efforts would not 

require producing new research or conducting new data collection efforts, but rather would rely 

on existing publications or previous efforts to research or collect such data. 

In relation to this, the draft EPA report should also note that restoration with non-native 

grasses may result, in all likelihood, in permanent loss of forest habitat, which will alter levels of 

regional forest cover and fragmentation. For this reason, the impacts of MTM-VF are not akin to 

those from timber harvests, which, when allowed to regenerate, only temporarily result in forest 

loss. Moreover, ecological studies of wildlife (especially birds) show that early-successional 

forest is required by certain disturbance-dependent animals as well as heavily used by a wide 

variety of interior/mature-forest specialists during juvenile, post-breeding, or migratory periods

(e.g., Askins, 2001; Hunter et al., 2001). Although non-native grasses may provide habitat for 

certain grassland and openland species, the change in community composition is profound. 

Introduction of non-native species by future utilization of restored sites (e.g., recreation) also 

should be of concern. Also, inclusion of more data (information) into the draft EPA report from 

some existing, available literature (e.g., from citations discussed below) or from new research or 

new data collection efforts by EPA would improve the draft EPA report’s discussion. Despite 

the lack of published research on improved reclamation procedures, researchers from West 

Virginia University (WVU) and University of Kentucky (UK) have generated recent data that 

may be relevant to this discussion (for example, Gingerich, 2009; Chermak, et al., 2004). 
47

Of all the research needs listed in this document the most critical may be to develop and 

demonstrate methods that: (1) reduce the generation of conductivity in valley fills, (2) reestablish a functional forest (e.g., hydrology, water quality, sediment, organic matter, 

temperature regime), (3) re-establish a headwater stream that has critical functional capabilities 

and (4) address active fill construction impacts through passive treatment systems that 

encompass enhanced sediment/treatment pond capabilities. EPA should first consider assessing 

the available information associated with these research needs. Such information should be 

based on the following conditions: a) Achievement of low conductivity from valley fills; b) 

Consideration of the Forest Reclamation Approach (FRA); c) Consideration of use of natural 

stream channel design techniques; d) Design and operation of sediment control; and e) 

Aggressive monitoring of stream functions and water quality. These conditions are further 

discussed below:

• Achievement of low conductivity from valley fills. The UK studies discussed below 

have shown acceptable conductivity levels were achieved at two reclaimed valley 

fills that were constructed using conductivity-producing material identification and 

isolation techniques (values less than 250 μS/cm). 

• The Forest Reclamation Approach (FRA) has been clearly shown to be capable of regenerating mixed hard wood species on lands reclaimed using this technique (over 

2.2 million trees as of 2007). The hydrologic response is that of a forested watershed 

which has quick flow from riparian areas and delayed flow (base flow) from upland 

areas. Once the forest is progressively established, the terrestrial-related functions 

become increasing evident. Functional capabilities can be accelerated by replanting 

more established trees and shrubs in the riparian zone of re-established ephemeral and 

intermittent streams.

• Streams established using natural channel design techniques that address compaction 

below the stream bed and inter-connectivity to the riparian zone and ecosystem to 

undisturbed ephemeral and/or intermittent streams in close proximity to the valley fill 

should be further considered. 

• Design and operate sediment control – treatment ponds to enhance performance,

especially regarding flow regime, water quality (conductance and sulfate), organics 

(including nutrients), and sediment contributions to more closely mimic natural 

forested conditions. This includes integration of passive riparian zone treatment 

systems that receive controlled discharge from the pond. 

• Aggressively monitor stream functions and water quality of established headwater 

streams and down-stream impacts below the sediment/treatment pond throughout the 

pre-development, construction and well-after the reclamation. 

The West Virginia University research, which is reported in a graduate student thesis 

(Gingerich, 2009), and is ongoing at West Virginia University, focuses on quantifying the full 
48

suite of aquatic ecosystem functions that are and are not recovered using current reclamation 

procedures. The major conclusions from the Gingerich studies include:

1. The headwater catchments are completely rearranged by the mining/reclamation 

process.

2. The predominant stressors to the reconstructed systems are elevated TDS and 

sulfates. 

3. There is a consistent replacement of sensitive lotic taxa with tolerant lentic taxa 

(invertebrates and amphibians).

4. Many of the typical headwater “functions” are retained to some degree, including 

organic matter (OM) retention, OM decomposition, and production of dissolved and 

fine particulate organic matter.

A summary table of the results indicated in the Gingerich studies shows the ratio 

between what is observed in reference headwater streams vs. what is observed in perimeter

channels. Values less than one indicate conditions where that particular function is lower in 

constructed channels relative to native channels. It is critical to note that the headwaters are 

completely transformed and many functions are highly altered, but not all functions are 

completely lost, and still others are “accentuated.” The question is, are there ways to 

improve the reclamation process such that functional losses or extreme modifications (+ or -) 

are minimized?

Ecosystem Function Variable Functional Ratio

% lotic amphibians 0.06

% EPT* 0.10

Conductivity (inverse) 0.21

EPT richness 0.25

RVHA* 0.52

OM* decomposition rate 0.57

WVSCI* 0.71

Invertebrate biomass 0.92

Invertebrate richness 1.14

% lentic amphibians 1.65

OM processing (ret X decomp) 1.86

Dissolved organic carbon 2.32

OM retention 3.24

Larval amphibian biomass 26.60

*EPT = Ephemeroptera, Plecoptera, Trichoptera 

RVHA = Rapid Visual Habitat Assessment score 

OM = Organic matter 

WVSCI = WV Stream Condition Index

The UK research has focused on achievement of lowered conductivity from valley 

fills and from reconstructed on-site channels. Not only were acceptable conductivity levels 

achieved, but a valley fill was retrofitted with four ephemeral streams and one intermittent 
49

stream using natural channel design and construction techniques and water quality and EPT 

(measured for the up-gradient reaches) has been re-established. 

The combined WVU/UK research underscores the need to develop and demonstrate 

conductivity reducing technologies for application on newly constructed mines and through 

retro-fitting of existing mines. Research indicates that improved reclamation approaches 

should focus on conductivity-producing material isolation, under-channel compaction, 

natural stream channel design, and improved construction of perimeter sediment control 

structures to maximize aquatic ecosystem function and sulfate reduction. 

Section 7.4 of the draft EPA report (‘Evidence of Recovery’) discusses the need to 

gather evidence of return of “normal” hydrology to downstream channels, and relates to the 

potential success of recovery of water quality, aquatic biota and stream ecological function. 

Efforts to re-create channels, wetlands, and other habitat on-site have had limited success. 

The draft EPA report emphasizes downstream conditions and functions and provides limited 

discussion relating size of area removed and filled to size of area that is or may be restored or 

mitigated, and additional discussion on this topic is warranted. 

The Panel also encourages EPA to address upland/terrestrial objectives of reclamation 

within the draft EPA report or make a stronger argument for why consideration of this topic is 

outside the scope of the draft EPA report. This is an important issue in its own right, especially 

as it relates to wildlife habitat (e.g., elk and other grassland dependent wildlife), reforestation and 

timber production, landowner preferences, and soil development and carbon sequestration. 

Public comments considered by the SAB Panel also support this statement. The Panel 

understands that it is a large topic that may add an unacceptable level of complexity to an 

already cumbersome document. Nevertheless, the topic is too important to simply pass by. At 

the very least, the draft EPA report needs to make clear the difference between upland 

reclamation for upland objectives and upland reclamation as a means for meeting aquatic 

objectives.

Little attention was given to the issue of upland recovery relative to the habitats required 

for species that use both the upland and aquatic ecosystems (e.g., amphibians). The draft EPA 

report should more explicitly discuss the reliance of many salamanders and other aquatic 

organisms on upland habitats during certain stages of amphibian life cycles. EPA should discuss 

to what extent these upland habitats support pre-mining species of amphibians, and what are the 

anticipated and/or measured levels of post-mining species richness of amphibians in the aquatic 

environments or the ditches, groins, retention basins and downstream channel (see Gingerich, 

2009). 

Additional issues associated with restoration include the following:

• The draft EPA report should discuss the impacts that currently employed restoration 

methods have in introducing invasive species (e.g., resulting from mountain top removal 

and restoration activity heavy equipment use). The Report should discuss the desirability 

of restoration of native species and ecosystems, and undesirability of loss of native 

species, as endpoints in reclamation. For example, an increase in species such as deer, 
50

elk or invasive plants in edge-of-woods habitat surrounding the MTM-VF’s or an 

increase in invasive species preferring grassland habitat bordering woods such as 

cowbirds which negatively affect nearby forest-nesting bird species may occur.

• The restoration conveyance and retention structures are designed for 100 year storms (as 

noted on page 66 of the draft EPA report). The draft EPA report does not discuss and

EPA should consider discussing the potential effects of failures in these systems, 

including the potential that large storms could “blow out” the sediment retention 

structures. Further, EPA should consider discussing the potential effect of increased 

stormwater flow through the modified landscape with respect to ion concentrations, 

nutrients, and sediments.

• Impacts from reclamation activities on temperature regime were documented, with 

elevated temperatures during fall, winter and spring, and reduced temperature ranges 

during summer.

• Reconstituted soils used in the restoration may contain fertilizers. EPA should consider 

discussing what is the effect of elevated nutrient levels in runoff on stream nutrient 

levels, and whether this could be the cause of the elevated nitrate levels downstream. 

 

• EPA should consider assessing and incorporating available literature from the field of 

landscape ecology with respect to the re-establishment of patch structure and diversity in 

regards to the reclamation process and potential long-term impacts on stream and riparian 

networks. Such data assessment efforts would not require producing new research or 

conducting new data collection efforts, but rather would rely on existing publications or 

previous efforts to research or collect such data. 

• In addition, EPA should consider assessing and incorporating available literature on 

stream recovery timeframe if elevated conductivity is reduced over time through 

application of Best Management Practices (BMPs). Either the draft EPA report should 

incorporate such literature or note that there is a gap in this information. Such data 

assessment efforts would not require producing new research or conducting new data 

collection efforts, but rather would rely on existing publications or previous efforts to 

research or collect such data. 
R-1

LITERATURE CITED

Arscott, D. B., K. Tockner, et al. (2005). Lateral organization of aquatic invertebrates along 

the corridor of a braided floodplain river. Journal of the North American Benthological 

Society 24(4): 934-954.

Ashby, W.C. 1999a. Growth of white and red oak planted as seedlings and seed on mined 

ungraded cast overburden. Stringer, J.W.; Loftis, D.L., eds. Proceedings, 12th Central 

Hardwood Forest Conference. General Technical Report SRS-24, U.S. Department of 

Agriculture Forest Service. pp. 84-89.

Ashby, W.C. 1999b. Status of reforestation technology in southern Illinois. Enhancement of 

Reforestation at Surface Coal Mines: Technical Interactive Forum, Fort Mitchell, KY. U.S. 

Department of Interior Office of Surface Mining, Alton, IL and Coal Research Center, 

Southern Illinois University, Carbondale, IL. pp. 109-120.

Askins, R.A., 2001. Sustaining biological diversity in early successional communities: The 

challenge of managing unpopular habitats. Wildlife Society Bulletin 29:407-412. 

Battin, T.J., L.A. Kaplan, S. Findlay, C.S. Hopkinson, E. Marti, A.I. Packman, J.D. Newbold, 

and F. Sabater. 2008. Biophysical controls on organic carbon fluxes in fluvial networks. 

Nature Geoscience 1:95-100.

Benke, A.C. and J. B. Wallace. 1997. Trophic basis of production among riverine caddisflies: 

implications for food web analysis. Ecology 78:4, 1132-1145.

Boyd, C.E. 2000. Water Quality: An Introduction. Kluwer Academic Publisher. Cao, Y., 

D.D. 10 Williams, and N.E. Williams. 1998. How important are rare species in aquatic 11 

community ecology and bioassessment? Limnology and Oceanography 43:1403–1409.

Bradshaw, A. 1997. Restoration of mined lands—using natural processes. Ecological 

Engineering 8:255-269.

Brooks, M.L., McKnight, D.M., and Clements, W.H. 2007. Photochemical control of copper 

complexation by dissolved organic matter in Rocky Mountain Streams, Colorado. Limnology 

and Oceanography 52:766-779.

Brown, D.G., B.C. Pijanowski and J.D. Duh. 2000. Modeling the relationship between land 

use and land cover on private lands in the Upper Midwest, USA. Journal of Environmental 

Management 59:247-263.

Buehler, D.A., J.J. Welton and T.A. Beachy. 2006. Predicting Cerulean Warbler habitat use 

in the Cumberland Mountains of Tennessee. Journal of Wildlife Management 70(6):1763-

1769.

Burger, J., V. Davis, J. Franklin, C. Zipper, J. Skousen, C. Barton, and P. Angel. 2009. Tree-
R-2

Compatible ground covers for reforestation and erosion control. The Appalachian Regional 

Reforestation Initiative (ARRI) Forest Reclamation Advisory No. 6 July 2009. 

http://arri.osmre.gov/.

Burger, J., D, Graves, P. Angel, V. Davis, and C. Zipper. 2005. The Forestry reclamation 

approach. The Appalachian Regional Reforestation Initiative (ARRI) Forest Reclamation

Advisory No. 2, December 2005. http://arri.osmre.gov/.

Burton, T.M., and Likens, G.E. 1975a. Salamander populations and biomass in the Hubbard 

Brook experimental forest, New Hampshire. Copeia 1975:541–46

Burton, T.M., and Likens, G.E. 1975b. Energy flow and nutrient cycling in salamander 

populations in the Hubbard Brook experimental forest, New Hampshire. Ecology 56:1068–

80.

Cao, Y., D.D. Williams and N.E. Williams. 1998. How important are rare species in aquatic 

community ecology and bioassessment? Limnology and Oceanography 43:1403-1409. 

Carlisle, D. and W.H. Clements. 2005. Leaf litter breakdown, microbial respiration and 

Shredder Production in Metal-polluted Streams. Freshwater Biology 50:380-390. 

Carlisle, D.M., C.P. Hawkins, M.R. Meador, M. Potapova and J. Falcone. 2008. Biological 

assessments of Appalachian streams based on predictive models for fish, macroinvertebrate, 

and diatom assemblages. Journal of the North American Bentological Society 27:16-37. 

Caruccio, F.T., J. Ferm, J. Horne, G. Geidel, and B. Baganz. 1977. Paleoenvironment of Coal 

and its Relation to Drainage Quality. Interagency Energy-Environment Research and 

Development Series, EPA-600/7-77-067, Environmental Protection Agency, Washington, DC. 

Chapman, P.M., W.J. Adams, M.L. Brooks, C.G. Delos, S.N. Luoma, W.A. Maher, H.M. 

Ohlendorf, T.S. Presser and D.P. Shaw. 2010. Ecological assessment of selenium in the 

aquatic environment. ISBN: 9781439826775. SETAC Press, Pensacola, Florida. 

Chermak, J.A., B. Wielinga, E.G. Wyatt and J. Taylor. 2004. Cost-effective acid rock 

drainage water treatment applied to mining impacted watersheds. Proceedings of the 

American Society of Mining and Reclamation 21:272-292. 

http://dept.ca.uky.edu/asmr/W/Full%20Papers%202004/0272-Chermak%20VA.pdf. 

Church, S.A., J.M. Kraus, J.C. Mitchell, D.R. Church and D.R. Taylor. 2003. Evidence for 

multiple pleistocene refugia in the postglacial expansion of the eastern tiger salamander 

Ambystoma tigrinum tigrinum. Evolution 2:372-383.

Chugh, D., C. Davin, and K R. Dietz. 1990. Proceedings, First Midwestern Region 

Reclamation Conference.. Coal Research Center: Southern Illinois University at Carbondale.

Clements, W.H., Brooks, M.L., D.R. Kashian1, and R.E. Zuellig. 2008. Changes in dissolved 
R-3

organic material determine exposure of stream benthic communities to UV-B radiation and 

heavy metals: implications for climate change. Global Change Biology 14:2201-2214.

Clements W.H. and M.C. Newman. 2002. Community ecotoxicology. John Wiley and Sons 

Ltd, 14 Chichester, West Sussex.

Cole, J.J. and N.F. Caraco. 2001. Carbon in catchments: connecting terrestrial carbon losses 

with aquatic metabolism. Marine and Freshwater Research 52:101-110.

Conley, J.M., D. H. Funk, and D. B. Buchwalter. 2009. Selenium Bioaccumulation and 

Maternal Transfer in the Mayfly Centroptilum triangulifer in a Life-Cycle, Periphyton-Biofilm 

Trophic Assay. Environmental Science and Technology, 2009, 43 (20), pp 7952–7957.

Davic, R.D. and H.H. Welsh. 2004. On the evolutionary role of salamanders. Annual Review 

of Ecology, Evolution, and Systematics, 35:405-434.

Dillon, R.T. 2000. The Ecology of Freshwater Molluscs. Cambridge University Press. 

Dodds, W.K., W.H. Clements, K. Gido and R.H.Hilderbrand. 2010. Thresholds, breakpoints, 

and non-linearity in freshwater systems as related to management. Journal of the North 

American Benthological Society 29:988-997.

Elmore, A.J., and S.S. Kaushal. 2008. Disappearing headwaters: patterns of

stream burial due to urbanization. Frontiers of Ecology and Environment 6: 308–312.

Estill, J.C. and M. Cruzan. 2001. Phytogeography of rare plant species endemic to the 

Southeastern United States. Castanea 66(1-2): 3-23.

Fagan, W.F. 2002. Connectivity, fragmentation, and extinction risk in dendritic 

metapopulations. Ecology 83: 3243-3249. 

Fagan, W.F., P.J. Unmack, C. Burgess, and W.L. Minckley. 2002. Rarity, fragmentation, and 

extinction risk in desert fishes. Ecology 83: 3250-3256. 

Farag, A.M., D.D. Harper, A. Senecal and W.A. Hubert. 2010. Potential effects of coalbed 

natural gas development on fish and aquatic resources. Chapter 11, Pages 227-242. In. K.J. 

Reddy (ed). 2010. Coalbed Natural Gas: Energy and Environment. Nova Scienc Publishers, 

Inc. Hauppange, NY

Fausch, K.D., C.E. Torgersen, C.V. Baxter, and H.W. Li. 2002. Landscapes to riverscapes: 

bridging the gap between research and conservation of stream fishes. BioScience 52:483-498.

Fisher, S.G. and G.E. Likens. 1973. Energy flow in Bear Brook, New Hampshire: An 

integrative approach to stream ecosystem metabolism. Ecological Monographs 43:421-439.

Frissell. C.A. and D. Bayles. 1996. Ecosystem management and the conservation of aquatic 
R-4

biodiversity and ecological integrity. Journal of the American Water Resources Association 

(JAWRA) 32:229–240.

Geidel, G. and F.T. Caruccio. 1982. An evaluation of a surface application of limestone for 

controlling acid mine discharges from abandoned strip mines, Sewellsville, Ohio. U.S. 

Environmental Protection Agency EPA-600/2-84-004 - National Technical Information 

Service, Springfield, VA 22161.

Geidel, G. and F.T Caruccio. 2000. Geochemical factors affecting coal mine drainage quality. 

Chapter 5, Reclamation of Drastically Disturbed Lands, American Society of Agronomy, 

Madison, Wisconsin. 

Gergel, S.E., M.G. Turner, J.R. Miller, J.M. Melack and E.H. Stanley. 2002. Landscape 

indicators of human impacts to riverine systems. Aquatic Sciences-Research Across 

Boundaries 64:118-128. Gibbs, J.P., 1998. Distribution of woodland amphibians along a 

forest fragmentation gradient. Landscape Ecology 13:263-268.

Gingerich, G. 2009. Quantifying ecological functions of aquatic habitats on reclaimed 

surface mines in WV. MS Thesis. West Virginia University, Morgantown, WV. 

Grant, E.H.C., L.E. Green, and W.H. Lowe. 2009. Salamander occupancy in headwater 

stream networks. Freshwater Biology 54:1370-1378. 

Greenwood, J.L., A.D. Rosemond, J.B. Wallace, W.F. Cross, and H.S. Weyers. 2007. 

Nutrients stimulate leaf breakdown rates and detritivore biomass: bottom-up effects via 

heterotrophic pathways. Oecologia (Berlin) 151: 637-649. 

Groninger, J., J. Skousen, P. Angel, C. Barton, J. Burger, C. Zipper. 2007. Mine reclamation 

practices to enhance forest development through natural succession. The Appalachian 

Regional Reforestation Initiative (ARRI) Forest Reclamation Advisory No. 5 July 2007. 

http://arri.osmre.gov/.

Hairston, N.G. Sr. 1949. The local distribution and ecology of the plethodontid salamanders 

of the southern Appalachians. Ecological Monographs 19:49–73.

Hall, R.O. Jr., J. B. Wallace, S. L. Eggert. 2000. Organic matter flow in stream food webs 

with reduced detrital resource base. Ecology 81:12, 3445-3463.

Hamel, P.B., D.K. Dawson and P.D. Keyser. 2004. How can we learn more about the 

Cerulean Warbler (Dendroica cerulea). The Auk 121:7-14.

Harding, J.S., E.F. Benfield, P.V. Bolstad, G.S. Helfman and E.B.D. Jones III. 1998. Stream 

biodiversity: The ghost of land use past. Proceedings of the National Academy of Sciences 

95:14843-14847.

Harrison, S.S.C., J.L. Pretty, D.Shepherd, A.G. Hildrew, C.Smith, and R.D. Hey. 2004. The 
R-5

effect of instream rehabilitation structures on macroinvertebrates in lowland rivers. Journal of 

Applied Ecology 41:1140-1154.

Hart, B.T., P. Bailey, R. Edwards, K. Hortle, K. James, A. McMahon, C. Meredith and K.

Swadling. 1984. Effects of salinity on river, stream and wetland ecosystems in Victoria, 

Australia. Water Research 24: 1103-1117.

Hartman, K.J., M.D. Kaller, J.W. Howell, and J.A. Sweka. 2005. How much do valley fills 

influence headwater streams? Hydrobiologia 532:91-102.

Hartman, K.J., M.D. Kaller, J.W. Howell, and J.S. Sweka. 2005. How much do valley fills 

influence headwater streams? Hydrobiologia 532:91−102. 

Higgs, E.S. 1997. What is good ecological restoration? Conservation Biology 11:338-348. 

Howard, H.S., B. Berrang, M. Flexner, G. Pond, and S. Call. 2001. Kentucky mountaintop 

mining benthic macroinvertebrate survey: Central Appalachian Ecoregion, Kentucky. 

Appendix D in Programmatic Environmental Impact Statement on Mountaintop Mining / 

Valley Fills in Appalachia (2003, 2005). U.S. Environmental Protection Agency, Region 3,

Philadelphia, PA.

Hunter, W.C., D.A. Buehler, R.A. Canterbury, J.L. Confer and P. B. Hamel. 2001. 

Conservation of Disturbance-Dependent Birds in Eastern North America. Wildlife Society 

Bulletin 29:440-455.

Jaeger, R.G., C.R. Gabor and H.M. Wilbur. 1998. An assemblage of salamanders in the 

Southern Appalachian Mountains: Competitive and predatory behavior. Behaviour 135:795-

821.

Jung, R.E. 2002. Streamside salamander inventorying and monitoring: Northeast refuges and 

parks – Summer 2002. United States Geological Survey, Patuxent Wildlife Research Center,

Laurel, Maryland.

Kolar, C.A., W. C. Ashby, and G. R. Philo. 1981. Differential performance of trees planted 

on reclaimed surface-mined land. D. H. Graves, ed. 1981 Symposium on Surface Mining 

Hydrology, Sedimentology and Reclamation. University of Kentucky, Lexington. pp. 271-

278.

Kolar, C.A. and W.C. Ashby. 1982. Reclamation: what about trees? Coal Mining and 

Processing 19(7):68-69, 72.

Kolar, C.A. and W.C. Ashby. 1985. Successful forestation as a guide for future reclamation, 

Proceedings Fourth Annual Conference Better Reclamation with Trees, compiled by P. E. 

Pope. Owensboro, Ky. pp. 117-133.

Larned, S. T., T. Datry, Arscott. D.B., and Tockner, K. Emerging concepts in temporary-river 
R-6

ecology." Freshwater Biology 55(4): 717-738.

Lasier P. and I. Hardin. 2010. Observed and predicted reproduction of Ceriodaphnia dubia 

exposed to chloride, sulfate, and bicarbonate. Environmental Toxicology and Chemistry 29: 

347-358. 

Layzer, J.B., M.E. Gordon, and R.M. Anderson. 2006. Mussels: The forgotten fauna of 

regulated rivers. A case study of the Caney Fork River. Regulated Rivers: Research and 

Management 8:63-71. 

Laxen, D.P.H. 1977. A specific conductance method for quality control in water analysis. 

Water Research 11: 91-94.

Leopold, L.B., W.G. Wolman, and J.P. Miller. 1964. Fluvial processes in geomorphology. 

Dover Publications, Inc. New York, New York.

Lepori, F., D. Palm, and B. Malmqvist. 2005. Effects of stream restoration on ecosystem 

functioning: detritus retentiveness and decomposition. Journal of Applied Ecology 42:228-

238. 

Letcher, B.H., K.H. Nislow, J.A. Coombs, M.J. O’Donnell, and T.L. Dubreuil. 2007. 

Population response to habitat fragmentation in a stream-dwelling brook trout population. 

Plos ONE 2(11): e1139. 

Luoma, S.N. and Presser, T.S. 2009. New opportunities in management of selenium 

contamination. Environmental Science and Technology 43: 8483-8487. 

Lynch, J.F. and and D. F. Whigham. 1984. Effects of forest fragmentation on breeding bird 

communities in Maryland, USA. Biological Conservation 28:287-324.

Malard, F., D. Galassi, M. Lafont, S. Doledec and J.V. Ward. 2003. Longitudinal patterns of 

invertebrates in the hyporheic zone of a glacial river. Freshwater Biology 48:1709-1725.

Merovich, G.T. and J.T. Petty. 2007a. Interactive effects of multiple stressors and restoration 

priorities in a mined Appalachian watershed. Hydrobiologia 575:13-31. 

Merovich, G.T., Stiles, J.M., Petty, J.T., Ziemkiewicz, P.F., and Fulton, J.B. 2007b. Water 

chemistry-based classification of streams and implications for restoring mined Appalachian 

watersheds. Environmental Toxicology and Chemistry 26: 1361-1369. 

Merriam, E., J.T. Petty, G.T. Merovich, Jr., J.B. Fulton, and M.P. Strager. IN REVIEW. 

Additive effects of mining and residential development on stream ecosystem condition in an 

intensively mined Appalachian watershed. Journal of the North American Benthological 

Society.

Merricks, T.C., D.S. Cherry, C.E. Zipper, R.J. Currie, and T.W. Valenti. 2007. Coal-mine 
R-7

hollow fill and settling pond influences on headwater streams in southern West Virginia, USA. 

Environmental Monitoring and Assessment 129(1−3):359−378.

Meyer, J.L. and J. B. Wallace. 2001. Lost linkages and lotic ecology: rediscovering small 

streams. Chp. 14, Pages 295-317. In M. Press, N. Huntly and S. Levin (eds.) Ecology: 

Achievement and Challenge. Blackwell Science, Oxford, UK.

Meyer, J.L., L.A. Kaplan, J.D. Newbold, D.L. Strayer, C.J. Woltemade, J.B. Zedler, R. 

Beilfuss, Q. Carpenter, R. Semlitsch, M.C. Watzin, and P.H. Zedler. 2007a. Where rivers are 

born: The scientific imperative for defending small streams and wetlands. Special publication 

of American Rivers.

Meyer, J.L., D.L. Strayer, J.B. Wallace, S.L. Eggert, and G.S. Helfman, 2007b. The 

Contribution of Headwater Streams to Biodiversity in River Networks. Journal of the 

American Water Resources Association 43: 86-103.

Morse, J.C., B.P. Stark, and W. P. McCafferty. 1993. Southern Appalachian streams at risk: 

Implications for mayflies, stoneflies, caddisflies, and other aquatic biota. Aquatic 

Conservation: Marine and Freshwater Ecosystems 3:293-303.

Mulholland, P.J. and A.D. Rosemond. 1992. Periphyton response to longitudinal nutrient 

depletion in a woodland stream - evidence of upstream downstream linkage. Journal of the 

North American Benthological Society 11:405-419.

Nakano, S., H. Miyasaka, and N. Kuhara. 1999. Terrestrial-aquatic linkages: riparian 

arthropod inputs alter trophic cascades in a stream food web. Ecology 80:2435-2441.

Nakano, S., and M. Murakami. 2001. Reciprocal subsidies: dynamic interdependence 

between terrestrial and aquatic food webs. Proceedings of the National Academy of Science, 

U.S.A. 98:166-170.

Nelson, S.M. 1994. Observed field tolerance of caddisfly larvae (Hesperophylax sp.) to high 

metal concentrations and low pH. Journal of Freshwater Ecology 9:169-170.

Nemenz, H. 1960. On the osmotic regulation of the larvae of Ephydra cinerea. Journal of 

Insect Physiology 4(1):38-44.

National Research Council. 2010. Management and effects of coalbed methane produced 

water in the Western United States. The National Academies Press, Washington, DC. 

Newbold, J.D., L.A. Kaplan, and P.R. Claggett. 2002. Geomorphic scaling and dissolved 

organic carbon in channel networks. Annual Water Resources Conference Proceedings, TPS02-04. American Water Resources Association, Philadelphia, Pennsylvania, USA.

Niemi, G.J.; P. DeVore, N. Detenbeck, D. Taylor, A. Lima, J. Pastor, J.D. Yount and R.J. 

Naiman. 1990. Overview of case studies on recovery of aquatic systems from disturbance. 

Environmental Management 14(5):571-587.
R-8

Niyogi, D.K., Lewis, W.M., and McKnight, D.M. 2001. Litter breakdown in mountain 

streams affected by mine drainage: biotic mediation of abiotic controls. Ecological 

Applications 11: 506-516. 

North Carolina Division of Water Quality (NCDWQ). 2005. Identification methods for the 

origins of intermittent and perennial streams. Version 3.1. North Carolina Department of 

Environment and Natural Resources, Division of Water Quality. Raleigh, NC. Online at

http://h2o.enr.state.nc.us/ncwetlands/documents/NC_Stream_ID_Manual.pdf 

Paine R.T., Tegner M.J., and Johnson, E.A. 1998. Compounded perturbations yield 

ecological surprises. Ecosystems 1:535-545.

Palmer, M.A., E.S. Bernhardt, J.D. Allan, P.S. Lake, G. Alexander, S. Brooks, J. Carr, S. 

Clayton, C. Dahm, J. Follstad Shah, D.J. Galat, S. Gloss, P. Goodwin, D.H. Hart, B. Hassett, 

R. Jenkinson, G.M. Kondolf, R. Lave, J.L. Meyer, T.K. O’Donnell, L. Pagano, P. Srivastava, 

and E. Sudduth. 2005. Standards for ecologically successful river restoration. Journal of 

Applied Ecology 42:208-217. 

Palmer, M.A. and J.D. Allan. 2006. Restoring River. National Academy of Science Journal: 

Issues in Science and Technology, Winter 2006. 

Partel, M., H. H. Bruun, and M. Sammul. 2005. Biodiversity in temperate European 

grasslands: origin and Conservation. In Integrating efficient grassland farming and 

biodiversity. Proceedings of the 13th International Occasional Symposium of the European 

Grassland Federation, Tartu, Estonia. R. Lillak, R. Viiralt, A. Linke and V. Geherman 

Editors.

Peterman, W.E; J.A. Crawford, and R.D. Semilitsch. 2007. Productivity and significance of 

headwater streams: population structure and biomass of the black-bellied salamander 

(Desmognathus quadramaculatus) Freshwater Biology 53: 347-357.

Peterson, D.A., P.R. Wright, G.P. Edwards, Jr., E.G. Hargett, D.L. Feldman, J.R. Zumberge, 

and P. Dey. 2009. Ecological Assessment of Streams in the Powder River Structural Basin, 

Wyoming and Montana, 2005–06, Scientific Investigations Report 2009–5023, U.S. 

Department of the Interior, U.S. Geological Survey.

Petranka, J.W., M.P. Brannon, M.E. Hopey, C.K. Smith. 1994. Effects of timber harvesting 

on low elevation populations of southern Appalachian salamanders. Forest Ecology and 

Management 67:135-147. 

Pierce, S.K. 1982. Invertebrate cell volume control mechanisms: A coordinated use of 

intracellular amino acids and inorganic ions as an osmotic solute. The Biological Bulletin

163:405-419.

Pond, G.J., M.E. Passmore, F.A. Borsuk, L. Reynolds, and C.J. Rose. 2008. Downstream 

effects of mountaintop coal mining: comparing biological conditions using family- and genus-
R-9

level macroinvertebrate bioassessment tools. Journal of the North American Benthological 

Society 27:717−737.

Pond, G.J. 2010. Patterns of Ephemeroptera taxa loss in Appalachian headwater streams 

(Kentucky, USA). Hydrobiologia 641:185-201.

Regester, K.J, M.R. Whiles and K.R. Lips. 2008. Variation in the trophic basis of production 

and energy flow associated with emergence of larval salamander assemblages from forest 

ponds. Freshwater Biology 53(9):1754-1767.

Reid, I. and J.B. Larone. 1995. Bedload sediment transport in an ephemeral stream and 

comparison with seasonal and perennial counterparts. Water Resources Research 31:773-

781. 

Rocco, G.L. and R.P. Brooks. 2000. Abundance and distribution of a stream plethodontid 

salamander assemblage in 14 ecologically dissimilar watersheds in the Pennsylvania Central 

Appalachians. Final Report No. 2000-4, prepared for U.S. Environmental Protection Agency 

Region III by Penn State Cooperative Wetlands Center, Forest Resources Laboratory, 

Pennsylvania State Univ., State College.

Semlitsch, R.D., B.D. Todd, S.M. Blomquist, A.J.K. Calhoun , J.W. Gibbons, J.P. Gibbs, 

G.J. Graeter, E.B. Harper, D.J. Hocking, M.L. Hunter Jr., D.A. Patrick, T.A.G. Rittenhouse 

and B.B. Rothermel. 2009. Effects of Timber Harvest on Amphibian Populations: 

Understanding Mechanisms from Forest Experiments. BioScience 59(10):853-862. 

Schindler, D.W., Beaty, K.G., Fee, E.J., Cruikshank, D.R., DeBruyn, E.R., Findlay D.L., 

Linsey, G.A., Shearer, J.A., Stainton, M.P., and Turner, M.A. 1990. Effects of climatic 

warming on lakes of the Central Boreal Forest. Science 250:967-970.

Scholz, F. and I. Zerbst-Boroffka. 1998. Environmental hypoxia affects osmotic and ionic 

regulation in freshwater midge-larvae. Journal of Insect Physiology 44(5-6):427-436.

Soucek, D.J., D.S. Cherry and G.C. Trent. 2000. Relative acute toxicity of acid mine 

drainage water column and sediments to Daphnia magna in Puckett's Creek watershed, 

Virginia, USA. Achives of Environmental Contamination and Toxicology 38:305-310.

Southerland, M.T. 1986. The effects of variation in streamside habitats on the composition of 

mountain salamander communities. Copeia: American Society of Ichthyologists and 

Herpetologists.3:731-741.

Stauffer, J.R., and Ferreri, C.P. 2002. Characterization of stream fish assemblages in selected 

regions of mountain top removal/valley fill coal mining. In: Draft programmatic 

environmental impact statement on mountaintop mining /valley fills in Appalachia - 2003. 

Appendix D. U.S. Environmental Protection Agency, Region 3, Philadelphia, PA. Available 

online at http://www.epa.gov/Region3/mtntop/pdf/appendices/d/fisheries-study/staufferferrerioct2002.pdf
R-10

Strager, J.M. and C.B. Yuill. 2002. The West Virginia Gap Analysis Project, Final Report.

USGS GAP Analysis Program. http://www.nrac.wvu.edu/projects/gap/index.html

Strayer, D. L. 2008. Freshwater Mussel Ecology: A Multifactor Approach to Distribution 

and Abundance. University of California Press. 216 pp. 

Sudduth, E.B., and J.L. Meyer. 2006. Effects of bioengineered streambank stabilization on 

bank habitat and macroinvertebrates in urban streams. Environmental Management 38:218-

226. 

Sweigard, R., J. Burger, C. Zipper, J. Skousen, C. Barton, and P. Angel. 2007. Low 

compaction grading to enhance reforestation success on coal surface mines. The Appalachian 

Regional Reforestation Initiative (ARRI) Forest Reclamation Advisory No. 3 July 2007. 

http://arri.osmre.gov/.

Trautman, M.B. 1981. The Fishes of Ohio with Illustrated Keys, Revised Edition. Ohio State 

University Press, Columbus, 782 pp.

Turner, M.G., S. M. Pearson, P. Bolstad and D. N. Wear. 2005. Effects of land-cover change 

on spatial pattern of forest communities in the Southern Appalachian Mountains (USA). 

Landscape Ecology 18:449-464.,

Turtle, S.L. 2000. Embryonic survivorship of the Spotted Salamander (Ambrystoma 

maculatum) in roadside and woodland vernal ponds in southeastern New Hampshire. Journal 

of Herpetology 34:60-67. 

U.S. Environmental Protection Agency. 2002a. Guidance on how decision criteria may be 

influence by 1) tiered aquatic life uses and 2) the implementation of “primary” headwater 

tiered aquatic life uses. A) Summary of Biological Assessment Programs and Biocriteria 

Development for States, Tribes, Territories, and Interstate Commissions: Streams and 

Wadeable Rivers (EPA-822-R-02-048); and B) Biological Assessments and Criteria: Crucial 

Components of Water Quality Programs (EPA 822-F-02-006). 

http://www.epa.gov/waterscience/biocriteria/ 

U.S. Environmental Protection Agency. 2002b. Methods for Measuring the Acute Toxicity of 

Effluents and Receiving Waters to Freshwater and Marine Organisms, EPA/812/R/02/012; 

U.S. Environmental Protection Agency, Office of Water: Washington, D.C.

Villard, M, M. K. Trzcinski and G. Merriam. 1999. Fragmentation effects on forest birds: 

relative influence of woodland cover and configuration on landscape occupancy. 

Conservation Biology 13:774-783.

Vinson, M.R. and C.P. Hawkins. 1998. Biodiversity of Stream Insects: Variation at Local, 

Basin, and Regional Scales. Annual Review of Entomology 43: 271-293.

Walker, M.J., A.K.Stockman, P.E. Marek and J.E. Bond. 2009. Pleistocene glacial refugia 

across the Appalacian Mountains and coastal plain in the millipede genus Narceus: Evidence 
R-11

from population genetic, phylogeographic and palioclimatic data. Evolutionary Biology 9:

25doi:10.1186/1471-2148-9-25.

Wallace, J.B., and S.L. Eggert. 2009. Terrestrial and longitudinal linkages of headwater 

streams. Canaan Valley and its Environs: A Landscape Heritage Celebration. Canaan Valley 

Institute, Davis, West Virginia. 

http://www.canaanvi.org/canaanvi_web/uploadedFiles/Events/Past_Events/Wallace%20& 

%20Eggert%20Paper.pdf

Wallace, J.B., J.R. Webster, S.L. Eggert, and J.L. Meyer. 2001. Small woody debris 

dynamics in a headwater stream. Verhandlungen des Internationalen Verein Limnologie 27: 

1361-1365.

Watts, T., and M.S. Schorr. 1998. Impacts of coal mine drainage on water quality and aquatic 

salamanders in a Cumberland Plateau stream. Association of Southeastern Biologists 45:104-

105.

Webster, J.R. and J.C. Meyer. 1997. Organic matter budgets for streams: a synthesis. 

Journal of the North American Benthological Society 16:141-161.

Welsh, H.H. Jr. and S. Droege. 2001. A case for using plethodontid salamanders for 

monitoring biodiversity and ecosystem integrity of North American forests. Conservation 

Biology 15:558–69.

Whitcomb, R.F., C.S. Robbins, J.F. Lynch, B.L. Whitcomb, M.K. Klimkiewicz and D. 

Bystrak. 1981. Effects of forest fragmentation on avifauna of the eastern deciduous forest. 

Ecological Studies. Springer-Verlag, New York. 310 pp.

Wickham, J.D., K.H. Riitters, T.G. Wade, M. Coan, and C. Homer. 2007. The effect of 

Appalachian mountaintop mining on interior forest. Landscape Ecololgy 22:179–187.

Williams, D. D. 1996. Environmental constraints in temporary fresh waters and their 

consequences for the insect fauna. Journal of the North American Benthological Society

15(4): 634-650.

Williams, J.E., D. Johnson, S. Hendrickson, J.D. Contreras-Balsderas, M. Williams, D.E.

Navarro-Mendoza, and J.E. Deacon. 1989. Fishes of North America, endangered, threatened, 

of special concern. Fisheries 14:2–20.

Williams, J.M., and P.B. Wood. 2004. Streamside salamanders in valley fill and reference 

streams in southern West Virginia. 2004 Proceedings of the American Society of Mining and 

Reclamation. pp. 2027-2041

Wipfli, M.S. 2005. Trophic linkages between headwater forests and downstream fish 

habitats: implications for forest and fish management. Landscape and Urban Planning

72:205-213.
R-12

Wipfli, M.S., and D.P. Gregovich. 2002. Export of Invertebrates and Detritus From Fishless 

Headwater Streams in Southeastern Alaska: Implications for Downstream Salmonid 

Production. Freshwater Biology 47:957-969.

Wipfli, M.S., J.S. Richardson, and R.J. Naiman. 2007. Ecological linkages between 

headwaters and downstream ecosystems: transport of organic matter, invertebrates, and wood 

down headwater channels. Journal of the American Water Resources Association 43:72-85.

ADDITIONAL REFERENCES FOR CONSIDERATION

Ashby, W. C. 1987. Reclamation with trees under P.L 95-87. D. H. Graves, ed. 

Proceedings, 1987 National Symposium on Mining, Hydrology, Sedimentology, and 

Reclamation, Springfield, IL. pp. 315-319.

Ashby, W. C. 1996. Red oak and black walnut growth increased with minesoil ripping. 

International Journal of Surface Mining, Reclamation and Environment 10:113-116.

Ashby, W. C. 1998. Reclamation with trees pre- and post-SMCRA in southern Illinois, USA.

International Journal of Surface Mining, Reclamation and Environment 12:117-121.

Ashby, W. C., W.C. Hood, and M.L. Guerke. 1979. Geochemical factors affecting plant 

growth in reclamation. Weeds Trees and Turf 18(4):28, 30,34,36, 43, 61.

Ashby, W.C., C.A. Kolar, and N.F. Rogers. 1980. Results of 30-year-old plantations on 

surface mines in the Central States. U.S. Department of Agriculture Forest Service General 

Technical Report NE-61. pp. 99-107.

Ashby, W.C., C.A. Kolar, and G.R. Philo. 1981. Environmental constraints on revegetation 

success from an Illinois perspective: rooting media, plant materials, climate. Proceedings 

Evaluation of Revegetation Success. Columbia, Missouri. 13 p.

Ashby, W.C. 1996. Growth of hardwoods and conifers after 47 years on coal mine spoils in 

southern Illinois. Tree Planter’s Notes 47(1):24-29.

Ashby, W.C. 1998. Tree planting on mined lands in the midwest. Proceedings MidContinent Regional Coal Symposium, St. Louis, Missouri, U.S. Department of Interior Office 

of Surface Mining. pp. 34-42.

Ashby, W.C. 2006. Sustainable stripmine reclamation. International Journal of Mining, 

Reclamation and Environment 20:87-95

Bernhardt, E.S., M.A. Palmer, J.D. Allan, G. Alexander, K. Barnas, S. Brooks, J. Carr, S. 

Clayton, C. Dahm, J. Follstad-Shah, D. Galat, S. Gloss, P. Goodwin, D. Hart, B. Hassett, R. 

Jenkinson, S. Katz, G.M. Kondolf, P.S. Lake, R. Lave, J.L. Meyer, T.K. O’Donnell, L. 
R-13

Pagano, B. Powell, and E. Sudduth. 2005. Synthesizing U.S. river restoration efforts. 

Science 308:636-637. 

Bernhardt, E.S., and M.A. Palmer. 2007. Restoring streams in an urbanizing world. 

Freshwater Biology 52:738-751. 

Binkley, C.A., M.S. Wipfl, R.B. Medhurst, K. Polivka, P. Hessburg, R.B. Salter, and J.Y. Kill. 

2010. Ecoregion and land-use influence invertebrate and detritus transport from headwater 

streams. Freshwater Biology 55(6): 1205-1218.

Binns, N.A. 2004. Effectiveness of habitat manipulations for wild salmonids in Wyoming 

streams. North American Journal of Fisheries Management 24:911–921. 

Blakely, T.J., Harding, J.S., McIntosh, A.R., and Winterbourn, M.J. 2006. Barriers to the 

recovery of aquatic insect communities in urban streams. Freshwater Biology 51:1634-1645. 

Blomquist, S.M. and M.L. Hunter Jr. 2010. A Multi-Scale Assessment of Amphibian Habitat 

Selection: Wood Frog Response to Timber Harvesting. Ecoscience 17 ( 3): 251-264.

Bohn, B.A., and J.L. Kershner. 2002. Establishing aquatic restoration priorities using a 

watershed approach. Journal of Environmental Management 64:355-363. 

Bonfert, G.A., S.J. Josiah, and W.C. Ashby. 1986. Reclamation techniques and combustion 

technologies. D.H. Graves, ed. Proceedings, 1986 National Symposium on Mining, 

Hydrology, Sedimentology, and Reclamation, Lexington, KY. pp. 185-190.

Boulton, A.J., S. Findlay, P. Marmonier, E.H. Stanley, and H.M. Vallet. 1998. The functional 

significance of the hyporheic zone in streams and rivers. Annual Review of Ecology, 

Evolution, and Systematics 29:59–81.

Buehler, D.A., J.J. Welton, and T.A. Beachy. 2006. Predicting Cerulean Warbler habitat use 

in the Cumberland Mountains of Tennessee. Journal of Wildlife Management 70(6):1763-

1769.

Bunn, S.E. and P.M. Davies. 2000. Biological processes in running waters and their 

implications for the assessment of ecological integrity. Hydrbiologia 422:61-70.

Clements, W.H. 2004. Small-scale experiments support causal relationships between metal

contamination and macroinvertebrate community responses. Journal of Applied Ecology 14: 

954-967. 

Dyer, K.L. 1982. Stream water quality in the coal region of West Virginia and Maryland. U. 

S. Department of Agriculture, Forest Service, Northeastern Forest Experimental Station, Gen. 

Tech. Rep. NE-70. 215 p.

Dyer, K.L. 1982. Stream water quality in the coal region of Alabama and Georgia. U. S. 
R-14

Department of Agriculture, Forest Service, Northeastern Forest Experimental Station, Gen. 

Tech. Rep. NE-73. 109 p. 

Dyer, K.L. 1982. Stream water quality in the coal region of Eastern Kentucky. U. S. 

Department of Agriculture, Forest Service, Northeastern Forest Experimental Station, Gen. 

Tech. Rep. NE-74. 208 p. 

Dyer, K.L. 1982. Stream water quality in the coal region of Ohio. U. S. Department of 

Agriculture, Forest Service, Northeastern Forest Experimental Station, Gen. Tech. Rep. NE75. 138 p. 

Dyer, K.L. 1982. Stream water quality in the coal region of Pennsylvania. U. S. Department 

of Agriculture, Forest Service, Northeastern Forest Experimental Station, Gen. Tech. Rep. 

NE-76. 168 p. 

Dyer, K.L. 1982. Stream water quality in the coal region of Tennessee. U. S. Department of 

Agriculture, Forest Service, Northeastern Forest Experimental Station, Gen. Tech. Rep. NE77. 125 p.

Dyer, K.L. 1982. Stream water quality in the coal region of Virginia. U. S. Department of 

Agriculture, Forest Service, Northeastern Forest Experimental Station, Gen. Tech. Rep. NE78. 76 p. 

Findlay, S. 1995. Importance of surface subsurface exchange in stream ecosystems: the 

hyporheic zone. Limnology and Oceanography 40:159–64.

Freeman, M.C., C.M. Pringle, and C.R. Jackson. 2007. Hydrologic connectivity and the 

contribution of stream headwaters to ecological integrity at regional scales. Journal of the 

American Water Resources Association. 43:5-14. 

Frissell, C.A. and R.K. Nawa. 1992. Incidence and causes of physical failure of artificial 

habitat structures in streams of western Oregon and Washington. North American Journal of 

Fisheries Management 12:182–197. 

Fritz, K.M., S. Fulton, B.R. Johnson, C.D. Barton, J,D. Jack, D.A. Word, and R.A. Burke. 

2010. Structural and functional characteristics of natural and constructed channels draining a 

reclaimed mountaintop removal and valley fill coal mine. Journal of the North American 

Benthological Society 29(2):673–689.

Fulk, F., Autrey, B., Hutchens, J., Gerritsen, J., Burton, J., Cresswell, C., and Jessup, B. 2003. 

Ecological assessment of streams in the coal mining region of West Virginia using data 

collected by the U.S. EPA and environmental consulting firms. In: Mountaintop mining/valley 

fills in Appalachia. Final programmatic environmental impact statement. U.S. 

Environmental Protection Agency, Region 3, Philadelphia, PA. Appendix D. Available online 

at http://www.epa.gov/Region3/mtntop/pdf/mtm-vf_fpeis_full-document.pdf. 
R-15

Graves, D.H., J.M.Ringe, M.H. Pelkki, R.J. Sweigard, and R.C. Warner, 2000. High Value 

Tree Reclamation Research. Environmental Issues and Management of Waste in Energy and 

Mineral Production. Singhal and Mehrotra (Eds.). Balkema, Rotterdam.

Hairston, N.G. Sr. 1987. Community Ecology and Salamander Guilds. New York: 

Cambridge Univ. Press. 230 pp.

Hartwell, H., Welsch, J.R. Garth, and R. Hogdson. 2008. Amphibians as metrics of critical 

biological thresholds in forested headwater streams of the Pacific Northwest, U.S.A. 

Freshwater Biology 53(7):1470-1488.

Hassett, B., M. Palmer, E. Bernhardt, S. Smith, J. Carr, and D. Hart. 2005. Restoring 

watersheds project by project: trends in Chesapeake Bay tributary restoration. Frontiers in 

Ecology 3:259-267. 

Hilderbrand, R.H. 2003. The roles of carrying capacity, immigration, and population 

synchrony on persistence of stream-resident cutthroat trout. Biological Conservation 110:257-

266.

Hilderbrand, R.H., and J.L. Kershner. 2000. Conserving inland cutthroat trout in small 

streams: how much is enough? North American Journal of Fisheries Management 20:513-

520.

Hilderbrand, R.H., A.C. Watts, and A.M. Randle. 2005. The myths of restoration ecology. 

Ecology and Society 10(1):19. http://www.ecologyandsociety.org/vol10/iss1/art19/

Hiscock, I.D. 1953. Osmoregulation in Australian Freshwater Mussels (Lamellibranchiata): 

1. Water and Chloride Exchange in Hydridella Australis (Lam.). Australian Journal of 

Marine and Freshwater Research 4:317-329.

Howard, H.S., B. Berrang, M. Flexner, G. Pond and S. Call. 2000. Kentucky mountaintop 

mining benthic macroinvertebrate survey. October 2001. U.S. Environmental Protection 

Agency, Science and Ecosystem Support Division, Ecological Assessment Branch, Athens, 

Georgia. Available online at 

http://www.epa.gov/Region3/mtntop/pdf/appendices/d/kentucky-macroinvertebratestudy/report.pdf.

Hughes, J.M., D.J. Schmidt, and D.S. Finn. 2009. Genes in Streams: Using DNA to 

Understand the Movement of Freshwater Fauna and Their Riverine Habitat. Bioscience 

59(7):573-583. 

Humphries, W.J., and K. Pauley. 2005. Life History of the Hellbender, Cryptobranchus 

alleganiensis, in a West Virginia Stream. The American Midland Naturalist 154(1):135-142.

Hynes, H.B.N. 1972. The Ecology of Running Waters. Liverpool University Press.
R-16

Jenkinson, R.G., K.A. Barnas, J.H. Braatne1, E.S. Bernhardt, M.A. Palmer, and J.D. Allan. 

2006. Stream restoration databases and case studies: a guide to information resources and 

their utility in advancing the science and practice of restoration. Restoration Ecology 14:177-

186. 

Karr, J.R. L.A. Toth, and D.R. Dudley. 1985. Fish communities of midwestern rivers: a 

history of degradation. BioScience 35(2):90-95.

Kaplan, L., T. Wiegner, J. Newbold, P. Ostrom, and H. Gandhi. 2008. Untangling the 

complex issue of dissolved organic carbon uptake: a stable isotope approach. Freshwater 

Biology 53:855-864.

Kapoor, N.N. 1979. Osmotic regulation and salinity tolerance of the stonefly nymph 

Paragnetina media. Journal of Insect Physiology 25:17-20.

Karr, J.R., L.A. Toth, and D.R. Dudley. 1985. Fish Communities of Midwestern Rivers: A 

History of Degradation. BioScience 35, No. 2 (Feb., 1985), pp. 90-95.

Kolar, C.A. and W. C. Ashby. 1978. Potential for woodland habitat from surface-mine tree 

plantings. Transactions 43rd North American Wildlife and Natural Resources Conference.

43:323-330.

Kolar, C.A., G.R. Philo, and W.C. Ashby. 1981. Suitability of direct seeding for establishing 

trees on mined-land sites. Proceedings 1981 Direct Seeding of Trees. Madisonville 

Community College, Kentucky. pp. 42-53.

Lepori, F., D. Palm, E. Brannas, and B. Malmqvist. 2005. Does restoration of structural 

heterogeneity in streams enhance fish and macroinvertebrate diversity? Ecological 

Applications 15:2060-2071. 

Levin, S. (eds.) Ecology: Achievement and Challenge. Blackwell Science, Oxford, UK.

Malard, F. 2003. Influence of groundwater upwelling on the distribution of the hyporheos in 

a headwater river flood plain. Archiv für Hydrobiologie 157:89-116.

McClurg, S.E., J.T. Petty, P.M. Mazik, and J.L. Clayton. 2007. Stream ecosystem response to 

limestone treatment in acid impacted watersheds of the Allegheny Plateau. Ecological 

Applications 17:00-000. 

Merovich, G.T., Jr, and J.T. Petty. IN PRESS. Continuous response of benthic 

macroinvertebrate assemblages to a discrete disturbance gradient: consequences for 

diagnosing stressors. Journal of the North American Benthological Society 00:000-000. 

Meyer, J.L., M.J. Paul, and W.K. Taulbee. 2005 Stream ecosystem function in urbanizing 

landscapes. Journal of the North American Benthological Society 24(3): 602–612.
R-17

Moerke, A.H. and G.A. Lamberti. 2003. Responses in fish community structure to restoration 

of two Indiana streams. North American Journal of Fisheries Management 23:748–759. 

Moerke, A.H., and G.A. Lamberti. 2004. Restoring stream ecosystems: lessons from a 

Midwestern state. Restoration Ecology 12:327-334. 

Montgomery, D.R., J.M. Buffington, N.P. Petersen, D. Schuett-Hames, and T.P. Quinn. 1996. 

Streambed scour, egg burial depths, and their influence of salmonid spawning on bed surface 

mobility and embryo survival. Canadian Journal of Fisheries and Aquatic Sciences 53:1061–

70.

Newbold, D. 2010. Geomorphic scaling of uptake length in channel networks and the 

potential importance of headwater streams. Pre-Publication. Stroud Water Research Center, 

Avondale, PA. 

Newbold J.D., T.L. Bott, L.A. Kaplan, C.L. Dow, J.K. Jackson, A.K. Aufdenkampe, L.A. 

Martin, D.J. Van Horn, and A.A. de Long. 2006. Uptake of nutrients and organic C in 

streams in New York City drinking-water-supply watersheds. Journal of the North American 

Benthological Society 25(4):998–1017. 

Northington, R.M., and A.E. Hershey. 2006. Effects of stream restoration and wastewater 

treatment plant effluent on fish communities in urban streams. Freshwater Biology 1959-

1973.

Odum, E.P. 1971. Fundamentals of Ecology. 3rd Ed. Philadelphia, PA: W. B. Saunders. 574 

pp.

Olsen, D.A. and C.R. Townsend. 2005. Flood effects on invertebrates, sediments and 

particulate organic matter in the hyporheic zone of a gravel-bed stream. Freshwater Biology

50:839–853.

Opperman, J.J., and A.M. Merenlender. 2004. The effectiveness of riparian restoration for 

improving instream fish habitat in four hardwood-dominated California streams. North 

American Journal of Fisheries Management 24:822–834.

Palmer, M.A., E.S. Bernhardt, W.H. Schlesinger, K.N. Eshleman, E. Foufoula-Georgiou, M.S. 

Hendryx, A.D. Lemly, G.E. Likens, O.L. Loucks, M.E. Power, P.S. White, and P.R. Wilcock. 

2010. Mountaintop mining consequences. Science 327:148-149.

Petranka, J.W., Mp.P. Brannon, M.E. Hopey, C.K. Smith. 1994. Effects of timber harvesting 

on low elevation populations of southern Appalachian salamanders. Forest Ecology and 

Management 67:135-147.

Petty, J.T., and D. Thorne. 2005. An ecologically based approach to identifying restoration 

priorities in an acid-impacted watershed. Restoration Ecology 13:348-357. 
R-18

Petty, J.T., J.B. Fulton, M. Strager, G.T. Merovich, J. Stiles, and P. Ziemkiewicz. 2010. 

Landscape indicators and thresholds of stream ecological impairment in an intensively mined 

Appalachian watershed. Journal of the North American Benthological Society 29:1292-1309. 

. 

Philo, G.R., C.A. Kolar, and W.C. Ashby. 1981. Direct seeding of black walnut on surfacemine spoils. pp. 85-93 In: Proceedings 1981 Direct Seeding of Trees. Madisonville 

Community College, Kentucky.

Philo, G.R., C.A. Kolar, and W.C. Ashby. 1982. Effects of ripping on minesoil compaction 

and black walnut establishment. 1982 Symposium on Surface Mining Hydrology, 

Sedimentology and Reclamation. University of Kentucky, Lexington. pp. 551-557,

Philo, G.R., J.A. Spaniol, C.A. Kolar, and W.C. Ashby. 1983. Weed control for better black 

walnut on strip mines. Tree Planters' Notes 34(1):13-15.

Poplar-Jeffers, I., J.T. Petty, J.A. Anderson, and S.J. Kite. 2010. Culvert replacement and 

stream habitat restoration: Implications from brook trout management in an Appalachian 

watershed, U.S.A. Restoration Ecology 17:404-413. 

Pough, H.F. 1983. Amphibians and reptiles as low-energy systems. Behavioral Energetics: 

The Cost of Survival in Vertebrates, ed. WP Aspey, SI Lustick, Columbus: Ohio State Univ. 

Press. 300 pp. pp. 141–88.

Preece, J.E., C.A. Huetteman, W.C. Ashby, D.F. Bresnan, and P.L. Roth. 1988. Provenance 

Tests For Biomass Production Using Micropropagated Clonal Silver Maple. Hortscience 23: 

803-803.

Pretty, J.L., S.S.C. Harrison, D.J. Sheperd, C. Smith, A.G. Hildrew, and R.D. Hey. 2003. 

River rehabilitation and fish populations: assessing the benefits of instream structures. 

Journal of Applied Ecology 40:251–256. 

Quinn, J.W. and T.J. Kwak. 2000. Use of rehabilitated habitat by brown trout and 

rainbowtrout in an Ozark tailwater river. North American Journal of Fisheries Management

20:737–751. 

Ritter, J.B. and T.W. Gardner. 1991. Runoff curve numbers for reclaimed surface mines in 

Pennsylvania. Journal of Irrigation and Drainage Engineering 117: 656–666.

Rodriguez- Iturbe. 2000. Ecohydrology: A hydrologic perspective of climate-soil-vegetation 

dynamics. Water Resources Research 36 (1): 3-9. 

Roni, P., T.J. Beechie, R.E. Bilby, F.E. Leonetti, M.M. Pollock, and G.R. Pess. 2002. A 

review of stream restoration techniques and a hierarchical strategy for prioritizing restoration 

in Pacific Northwest watersheds. North American Journal of Fisheries Management 22:1–20. 
R-19

Rosi-Marshall, E.J. and J.B. Wallace. 2002. Invertebrate food webs along a stream resource 

gradient. Freshwater Biology 47: 129-141.

Rosi-Marshall, E.J., A.H. Moerke, and G.A. Lamberti. 2006. Ecological responses to trout 

habitat rehabilitation in a northern Michigan stream. Environmental Management 38:99-107. 

Scott, T.C. III and W.C. Ashby. 1986. Variable performance of black walnut on reclaimed 

lands. Proceedings Fifth Annual Conference Better Reclamation with Trees, compiled by C. 

A. Kolar, Carbondale, IL. pp. 15-23.

Scwartz, J.S., and E.E. Herricks. 2007. Evaluation of pool-riffle naturalization structures on 

habitat complexity and the fish community in an urban Illinois stream. River Research and 

Applications 23:451-466.

Shields, F.D., Jr., S.S. Knight, N. Morin, and J. Blank. 2003. Response of fishes and aquatic 

habitats to sand-bed stream restoration using large woody debris. Hydrobiologia 494:251-257. 

Shotola, S.J., G.T. Weaver, P.A. Robertson, and W.C. Ashby. 1992. Sugar maple invasion of 

an old-growth oak-hickory forest in southwestern Illinois. American Midland Naturalist 127: 

125-138.

Slonecker, E.T. and M.J. Benger. 2001. Remote Sensing and Mountaintop Mining. Remote 

Sensing Reviews 20(4) 293-322. 

Smith, W.H. and L.J. Rissler. 2009. Quantifying Disturbance in Terrestrial Communities: 

Abundance-Biomass Comparisons of Herpetofauna Closely Track Forest Succession.

Restoration Ecology 18: 195-204.

Sobczak, W.V. and S. Findlay. 2002. Variation in bioavailability of dissolved organic carbon 

among stream hyporheic flowpaths. Ecology 83:3194–3209.

Society of Ecological Restoration. 2004. The SER International Primer on Ecological 

Restoration. www.ser.org and Tuscon: Society for Ecological Restoration International. 

Spight, T.M. 1967. Population Structure and Biomass Production by a Stream Salamander. 

American Midland Naturalist 78(2). 437-447.

Sweigard, R., J. Burger, D. Graves, C. Zipper, C. Barton, J. Skousen, and P. Angel. 2007. 

Looesning compacted soils on mined sites. The Appalachian Regional Reforestation Initiative 

(ARRI) Forest Reclamation Advisory No. 4 July 2007. http://arri.osmre.gov/.

Taylor, C.A., G.A. Schuster, J.E. Cooper, R.J. DiStefano, A.G. Eversole, P. Hamr, H.H. 

Hobbs, H.W. Robison, C.E. Skelton, and R.F. Thoma. 2007. A reassessment of the 

conservation status of crayfishes of the United States and Canada after 10+ years of increased 

awareness. Fisheries 32/8:372–389.
R-20

Taylor, T.J., C.T. Agouridis, R.C. Warner, and C.D. Barton. 2008. Runoff curve numbers for 

loose-dumped spoil in the Cumberland Plateau of eastern Kentucky. International Journal of 

Mining, Reclamation and Environment 23: 103-120.

Taylor, T.J., C.T. Agouridis, R.C. Warner, and C.D. Barton. 2009. Runoff Curve Numbers 

for Loose-Dumped Spoil in the Cumberland Plateau of eastern Kentucky. International 

Journal of Mining, Reclamation and Environment 24(2):1-12.

Thorp, J.H., and A.P. Covich. 2001. Ecology and classification of north american freshwater 

invertebrates. Second Edition. Academic Press. USA. p1056. 

Van Sambeek, J.W., W.C. Ashby, and P.L. Roth. 1992. Performance of trees and shrubs on 

sludge-amended acidic minesoils. Proceedings of the Ninth National Meeting of the American 

Society for Surface Mining and Reclamation, Duluth, MN. pp. 587-592.

Wallace, J.B., S.L. Eggert, J.L. Meyer, and J.R. Webster. 1997. Multiple Trophic Levels of a

Forest Stream Linked to Terrestrial Litter Inputs. Science 277:102 – 104.

Wallace, J.B. 2001. Lost linkages and lotic ecology: rediscovering small streams. Chp. 14, 

Pages 295-317. In M. Press, N. Huntly and the Sierra Club. 26pp.

Walsh, C.J., A.H. Roy, J.W. Feminella, P.D. Cottingham, P.M. Groffman, and R.P. Morgan. 

2005. The urban stream syndrome: current knowledge and the search for a cure. Journal of 

the North American Benthological Society 24(3): 706-723.

Walters, R.C. and D.J. Merritts. 2007. Natural streams and the legacy of water-powered 

mills. Science 319:299-304. 

Warner, R.C; C. Agouridis, and C. Barton. 2009. Modeling hydrology and sediment loss on 

head-of-hollow fills: geomorphic versus traditional approach. Geomorphic Reclamation and 

Natural Stream Design at Coal Mines. A technical Interactive Forum. April 28-30, 2009. 

Proceedings. Edited by Kimery Vories and Anna Caswell. Proceeding published by U.S. 

Department of Interior, Office of Surface mining, Coal Research Center, Southern Illinois 

University, Carbondale.

Weaver, G.T. and W.C. Ashby. 1971. Composition and structure of an old-growth forest 

remnant in un glaciated southwestern Illinois. The American Midland Naturalist Journal

86(1):46-56.

Webster, J.R., J.L. Tank, J.B. Wallace, J.L. Meyer, S.L. Eggert, T.P. Ehrman, B.R. Ward, B.L. 

Bennett, P.F. Wagner, and M.E. McTammany. 2001. Effects of litter exclusion and wood 

removal on phosphorus and nitrogen retention in a forest stream. Verhandlungen des 

Internationalen Verein Limnologie 27: 1337-1340.

Welsh, Jr. H.H. and L.M. Ollivier. 1998. Stream amphibians as indicators of ecosystem 

stress: a case study from California’s Redwoods. Ecological Applications 8:1118-1132.
R-21

Whiles, M.R, K.R Lips, C.M. Pringle, S.S. Kilham, R.J. Bixby, R. Brenes, S.Connelly, J. 

Checo Colon-Gaud, M. Hunte-Brown, A.D Huryn, C. Montgomery, and S. Peterson. 2006. 

The effects of amphibian population declines on the structure and function of Neotropical 

stream ecosystems. Frontiers in Ecology and the Environment 4(1):27.

Wilcox, S.J. and T.H. Dietz. 1998. Salinity tolerance of the freshwater bivalve Dreissena 

polymorpha (Pallas, 1771)(Bivalvia, Dreissenidae). Nautilus 111: 143-148., 

Williams, D.D. and H.B.N. Hynes. 1974. The occurrence of benthos deep in the substratum 

of a stream. Freshwater Biology 4:233–56.
A-1

APPENDIX A: EPA’s CHARGE TO THE PANEL

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

National Center for Environmental Assessment 

Office of Research and Development

June 10, 2010 

MEMORANDUM

SUBJECT: Review of (1) “The Effects of Mountaintop Mines and Valley Fills on Aquatic 

Ecosystems of the Central Appalachian Coalfields” and (2) “A Field-based 

Aquatic Life Benchmark for Conductivity in Central Appalachian Streams” 

FROM: Michael Slimak, Associate Director /signed/

National Center for Environmental Assessment 

Office of Research and Development 

TO: Vanessa Vu, Director

Science Advisory Board Staff Office

This memorandum provides background information and specific charge questions to the 

Science Advisory Board (SAB) in its review of two reports prepared by EPA’s Office of 

Research and Development (ORD). These reports were developed by the National Center for 

Environmental Assessment (NCEA) upon the request of EPA’s Office of Water and Regions 3, 

4, and 5. These reports help provide scientific information to support a set of actions EPA is 

undertaking to clarify and strengthen environmental permitting requirements for Appalachian 

surface coal mining operations, in coordination with other federal and state regulatory agencies. 

Background

The purpose of the report entitled “The Effects of Mountaintop Mines and Valley Fills on 

Aquatic Ecosystems of the Central Appalachian Coalfields,” is to assess the state of the science 

on the ecological impacts of Mountaintop Mining and Valley Fill (MTM-VF) operations on 

streams in the Central Appalachian Coal Basin. This basin covers about 12 million acres in 

West Virginia, Kentucky, Virginia, and Tennessee. The draft EPA report reviews literature 

relevant to evaluating five potential consequences of MTM-VF operations: 1) impacts on 

headwater streams; 2) impacts on downstream water quality; 3) impacts on stream ecosystems; 

4) the cumulative impacts of multiple mining operations; and 5) effectiveness of mining 

reclamation and mitigation. The impacts of MTM-VF operations on cultural and aesthetic 

resources were not included in the review. EPA used two primary sources of information for the 

evaluation: (1) the peer reviewed, published literature and (2) the federal Programmatic 

Environmental Impact Statement (PEIS) on Mountaintop Mining/Valley Fills in Appalachia and 

its associated appendices prepared in draft in 2003 and finalized in 2005.

The second report entitled, “A Field-based Aquatic Life Benchmark for Conductivity in 

Central Appalachian Streams,” uses field data to derive an aquatic life benchmark for 
A-2

conductivity. This benchmark value may be applied to waters in the Appalachian Region that 

are near neutral or mildly alkaline in their pH and where dissolved ions are dominated by salts of 

sulfate and bicarbonate. This benchmark is intended to protect the biological integrity of waters 

in the region. It is derived by a method modeled on EPA’s standard methodology for deriving 

water quality criteria. In particular, the methodology was adapted for the use of field data. Field 

data were used because sufficient and appropriate laboratory data were not available and because 

high quality field data were available to relate conductivity to effects on biotic communities. 

This draft EPA report provides the scientific basis for a conductivity benchmark in a specific 

region rather than for the entire United States.

Both of these reports were commissioned by EPA’s Office of Water (OW) and Regions 

3, 4, and 5 in order to provide information that will assist OW and the Regions to further clarify

and strengthen environmental permitting requirements for Appalachian surface coal mining 

projects, in coordination with federal and state regulatory agencies. Using the best available 

science and applying existing legal requirements, EPA issued comprehensive guidance on April 

1, 2010 that sets clear benchmarks for preventing significant and irreversible damage to 

Appalachian watersheds at risk from mining activities. 

Specific Charge in Reviewing the Mountaintop Mining – Valley Fill Effects Report

Charge Question 1: The Mountaintop Mining Assessment uses a conceptual model 

(Figure 12 of the draft document) to formulate the problem consistent with EPA’s 

Ecological Risk Assessment Guidelines. Does the conceptual diagram include the key 

direct and indirect ecological effects of MTM-VF? If not, please indicate the effects or 

pathways that are missing or need additional elucidation.

Charge Question 2: This report relied solely on peer-reviewed, published literature and 

the 2005 Final Programmatic Environmental Impact Assessment on Mountaintop 

Mining/Valley Fills. Does this assessment report include the most relevant peerreviewed, published literature on this topic? If not, please indicate which references are 

missing.

Charge Question 3: Valley fills result in the direct loss of headwater streams. Has the 

review appropriately characterized the ecological effects of the loss of headwater 

streams?

Charge Question 4: In addition to impacts on headwater streams, mining and valley fills 

affect downstream water quality and stream biota. Does the report effectively 

characterize the causal linkages between MTM-VF downstream water quality and effects 

on stream biota?

Charge Question 5: The published literature is sparse regarding the cumulative 

ecological impacts of filling headwater streams with mining waste (spoil). Does the 

review accurately describe the state of knowledge on cumulative ecological impacts of 

MTM-VF? If not, how can it be improved?
A-3

Charge Question 6: The Surface Mining Control and Reclamation Act and its 

implementing regulations set requirements for ensuring the restoration of lands disturbed 

by mining through restoring topography, providing for post-mining land use, requiring 

re-vegetation, and ensuring compliance with the Clean Water Act. Does the review 

appropriately characterize the effectiveness of currently employed restoration methods?

Specific Charge in Reviewing the Conductivity Benchmark Report

Charge Question 1: The data sets used to derive a conductivity benchmark (described in 

Section 2 of this report) were developed primarily by two central Appalachian states 

(WV and KY). Please comment on the adequacy of these data and their use in 

developing a conductivity benchmark. 

Charge Question 2: The derivation of a benchmark value for conductivity was adapted 

from EPA’s methods for deriving water quality criteria. The water quality criteria 

methodology relies on a lab-based procedure, whereas this report uses a field-based 

approach. Has the report adapted the water quality criteria methodology to derive a 

water quality advisory for conductivity using field data in a way that is clear, transparent 

and reasonable?

Charge Question 3: Appendix A of the report describes the process used to establish a 

causal relationship between the extirpation of invertebrate genera and levels of 

conductivity. Has the report effectively made the case for a causal relationship between 

species extirpation and high levels of conductivity due to surface coal mining activities? 

 

Charge Question 4: In using field data, other variables and factors have to be accounted 

for in determining causal relationships. Appendix B of the report describes the 

techniques for dealing with confounding factors. Does the report effectively consider 

other factors that may confound the relationship between conductivity and extirpation of 

invertebrates? If not, how can the analysis be improved? 

Charge Question 5: Uncertainty values were analyzed using a boot-strapped statistical 

approach. Does the SAB agree with the approach used to evaluate uncertainty in the 

benchmark value? If not, how can the uncertainty analysis be improved?

Charge Question 6: The field-based method results in a benchmark value that the report 

authors believe is comparable to a chronic endpoint. Does the Panel agree that the 

benchmark derived using this method provides for a degree of protection comparable to 

the chronic endpoint of conventional ambient water quality criteria?

Charge Question 7: As described, the conductivity benchmark is derived using central 

Appalachian field data and has been validated within ecoregions 68, 69, and 70. Under 

what conditions does the SAB believe this method would be transferable to developing a 

conductivity benchmark for other regions of the United States whose streams have a 

different ionic signature?
A-4

Charge Question 8: The amount and quality of field data available from the states and the 

federal government have substantially increased throughout the years. In addition, the 

computing power available to analysts continues to increase. Given these enhancements 

in data availability and quality and computing power, does the Panel feel it feasible and 

advisable to apply this field-based method to other pollutants? What issues should be 

considered when applying the method to other pollutants?

Background Reading Materials 

The following documents are accessible via the hyperlinks provided below. These 

documents provide important background information from scientific, regulatory, and policy 

perspectives on mountaintop mining and valley fills and are recommended reading for the SAB 

Panel members.

1. Final Programmatic Environmental Impact Statement on Mountaintop Mining/Valley 

Fills in Appalachia – 2005

htttp://www.epa.gov/region3/mtntop/eis2005.htm) 

2. April 1, 2010 Guidance Memorandum on Appalachian Surface Coal Mining

http://www.epa.gov/owow/wetlands/guidance/pdf/appalachian_mtntop_mining_d

etailed.pdf.
B-1

1

2 Appendix B: EPA’s Mountaintop Mining Assessment Conceptual Model 

3 (Figure 12 of EPA’s Draft Report) 

4

5 The following is Figure 12 within EPA’s draft Report entitled “The Effects of 

6 Mountaintop Mines and Valley Fills on Aquatic Ecosystems of the Central Appalachian 

7 Coalfields”:

8
B

-2

1