Laserfiche WebLink
IBLA 94-366 <br />u <br />[s]uch areas shall also include any adjacent land the use of <br />which is incidental to any such activities, all lands affected by <br />the construction of new roads or the ir~rovement or use of <br />existing roads to gain access to the site of such activities and <br />for haulage, and excavations, workings, impoundments, dams, <br />ventilation shafts, entryways, refuse banks, dw[q~s, stockpiles, <br />overburden piles, spoil banks, calm banks, tailings, holes or <br />depressions, repair areas, storage areas, processing areas, <br />shipping areas and other areas upon which are sited structures, <br />facilities, or other orooerty or materials on the surface, <br />• <br />30 U.S.C. ~ 1291(28}(B) (1994) (emphasis added). In enacting SMCRA, <br />Congress stated that "surface coal mining operations" thus include "all <br />roads, facilities[,] structures, property, and materials on the surface <br />resulting from or incident to [surface coal mining] activities, such as <br />refuse banks, duag>s, calm banks, impouncknents and processing wastes." S. <br />Rep. No. 128, 95th Cong., 1st Sess. 98 (1977) (e~hasis added). <br />We find nothing in section 701(28)(B) of SMCRA, or its legislative <br />history, which expressly provides that transportation facilities, <br />especially ones that carry processed coal to a remote point of sale/use, <br />should generally be considered "surface coal mining operations," subject to <br />regulation under SMCRA. Rather, the statute indicates that the point at <br />which the coal is loaded for shipment, following all processing/preparation <br />necessary for marketing and associated transportation, constitutes the last <br />stage of mining and related operations subject to SMCRA, either under <br />section 701(28)(A) or (B). See Ann Lorentz Coal Co. v. OSM, 79 IBLA 39, <br />43, 91 Interior Dec. 108, 113 (1984). Congress made no specific provision <br />for regulating the transportation of processed coal, even though that <br />activity is itself a "major industrial sector," which enccx~g~asses <br />railroads, barges, trucks, and pipelines "that collectively stretch over <br />thousands of miles throughout the nation." (PWCC Answer at 2, 9.) The <br />fact that it did not, strongly indicates that Congress did not intend to <br />regulate the transportation of processed coal under SMCRA, presumably <br />leaving it to regulation pursuant to other Federal and state laws. <br />We turn to SMCRA's implementing regulations. When the Department <br />first promulgated regulations in 1979 designed to permanently govern <br />surface coal mining activities, it established general standards for <br />constructing and maintaining transportation facilities other than roads, <br />which were said to include "[r]ailroad loops, spurs, sidings, surface <br />conveyor systems, chutes, aerial tramways, or other transportation <br />facilities." 30 C.F.R. ~ 816.180 (1979). The Department explained >n the <br />preamble to the final rulemaking that the regulation was intended to cover <br />transportation facilities "incident to coal mining operations," which are <br />required for the "[m]ovement of coal, equipment and personnel within the <br />mine plan area." 94 Fed. Reg. 15260, 15261 (Mar. 13, 1979) (emphasis <br />added). <br />142 IBLA 36 <br />I • <br />WWW Version <br />