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Department of Mines, Minerals and Energy
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6/24/21  3:31 pm
Commenter: Anonymous

Environmental Justice Considerations

DMME's recommendations for providing support to Virginia's coalfield region should fully take into account environmental justice considerations. DMME should also provide clear and detailed recommendations to ensure that funded projects in Virginia's coalfield region adhere to state and federal environmental regulations, including the establishment of meaningful accountability mechanisms to verify that funded projects abide by applicable regulations and experience consequences when such regulations are violated. Some previously-funded projects through VCEDA, for example, have resulted in serious and ongoing environmental degradation as a result of projects not adhering to existing regulations, resulting in enforcement agencies expending excessive amounts of time and public resources to inspect locations of concern, train project managers on applicable regulations, and address/remediate existing impacts. These issues have also impacted (and continue to impact) residents of low-income communities throughout the coalfields in negative ways, with little accountability for damage caused by these projects to date. These issues not only increase environmental harm to public resources but also increase costs to coalfield residents and communities through the funding and resources required to mitigate what are largely preventable impacts.

Adjustments to existing funding structures need to account for these serious deficiencies in accountability for recipients of funding and develop a rigorous framework to ensure the environmental sustainability of funded projects, as well as to verify adherence to existing environmental regulations during the planning and implementation phase of projects and outline clear and meaningful consequences for projects when such regulations are ignored or violated using public funding.

CommentID: 99254