National Institute for Occupational Safety and Health (NIOSH) (a part of the Centers for Disease Control and Prevention (CDC)) wants to build a facility that it could use for studies and research on mine explosions, mine seals, mine rescue, ventilation, diesel exhaust, new health and safety technologies, ground control, and fire suppression.  It would like to build it on 461 acres in Randolph and Pocahontas Counties near Mace, WV.  Much of the facility would be underground. Including a tunnel 500 feet below the surface where testing would be carried out.

It would replace a facility 60 miles south of Pittsburgh.  The National Institute for Occupational Safety and Health (NIOSH) considered sites in two other states and determined that the one near Mace would be most suitable to its needs

NIOSH has lost its lease in Pennsylvania so it can’t stay there.

As part of its consideration, the National Institute for Occupational Safety and Health (NIOSH) has prepared a Draft Environmental Impact Statement.  In an effort led by the West Virginia Rivers Coalition, several groups, including the West Virginia Highlands Conservancy, have reviewed the Draft.  While not opposing the facility, the groups have suggested some things that the agency should consider before going ahead with the facility.

Most of the questions raised about the project centered on things that were omitted or things that should have been considered but were not.  For example, the Draft Environmental Impact Statement (DEIS) says that there are no caves on site.  Yet the West Virginia Department of Natural Resources and the West Virginia Speleological Survey submitted comments which said that there were caves on the property.  The groups suggest that this is a deficiency that must be corrected by preparing a new DEIS which discusses the caves and how the agency will address any problems that may arise because of them.

The same thing is true of sinkholes.  The proposed site is in karst terrain which, by definition, has sinkholes.  The Draft Environmental Impact Statement (DEIS) has not identified sinkholes that may exist on the property.

The existence of caves and sinkholes raise concerns about threats to groundwater that the Draft Environmental Impact Statement does not address.  Most of the residents of the area get their water from wells and springs.  The caves and sinkholes present pathways for any spills or anything that happens on the site to reach water supplies as well as other ground or surface water.

There are also questions about erosion prevention measures.  The Draft Environmental Impact Statement (DEIS) assumes that standard practices for erosion prevention in road construction would be sufficient.  The comments say that, with the type of soils that are present, standard practices would not be enough and that more is needed.

Erodibility of the soils is especially important in this location because of the presence of a trout stream.  The Tygart River Valley is a designated trout stream and has stricter water quality standards.  Construction has to be taken with care to avoid damage to the trout fishery.

The entire point of doing an Environmental Impact Statement is to avoid doing something that is environmentally harmful out of ignorance. It assumes that if we have adequately identified the potential threats, we will take proper steps to avoid them.

Right now, the groups do not say that there are environmental harms that will definitely occur.  The thrust of the comments is that there are several areas where there are potential threats and that, right now, we are ignorant of the extent of those threats. Before making a decision, we should do the following information gathering:

• Survey the property for caves, sinkholes, springs, seeps, wetlands, and springs.At present only 10% of the property has been surveyed.
• Consider the project’s potential to introduce invasive species to the site and consider what can be done to prevent that.
• Look at the dangers to the trout habitat. The Tygart Valley River is a significant part of the range of brook trout.  The impact of any facility upon trout habitat would have to be considered and plans made to mitigate it.
• Consider what impact the facility would have on recreation and tourism