Pleasant City v. Ohio Dept. of Natl. Resources, Div. of Reclamation

1993 Ohio 220
CourtOhio Supreme Court
DecidedSeptember 14, 1993
Docket1992-1102
StatusPublished

This text of 1993 Ohio 220 (Pleasant City v. Ohio Dept. of Natl. Resources, Div. of Reclamation) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Pleasant City v. Ohio Dept. of Natl. Resources, Div. of Reclamation, 1993 Ohio 220 (Ohio 1993).

Opinion

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Village of Pleasant City, Appellee, v. Division of Reclamation,

Ohio Department of Natural Resources et al., Appellants.

[Cite as Pleasant City v. Ohio Dept. of Natl. Resources, Div. of

Reclamation (1993), ___ Ohio St.3d ___.]

Mining — Requirements of R.C. 1513.073(A)(2)(c) in determining

unsuitability of lands for coal mining.

In determining the unsuitability of lands for coal mining, R.C.

1513.073(A)(2)(c) requires consideration of the impact that

mining and reclamation could have on the long-range

productivity of aquifers and aquifer recharge areas, not solely the impact on their current use as a water supply.

(No. 92-1102 — Submitted June 1, 1993 — Decided September

15, 1993.) Appeal from the Court of Appeals for Guernsey

County, No. 91-CA-09. On September 21, 1988, pursuant to

Revised Code Section 1513.073, appellee, the village of Pleasant

City (“Pleasant City”), filed a “Lands Unsuitable Petition” with

the Division of Reclamation (“Division”), Ohio Department of

Natural Resources. In its petition, Pleasant City requested that

approximately eight hundred thirty-three acres of land

surrounding Pleasant City be designated unsuitable for coal

mining.

The underlying science involved in this case is very

complicated. However, a general understanding of only a few

terms and principles is necessary for the court to resolve this

appeal. On the whole, these terms and principles relate to how

water gets into the ground and what happens to the water when it

is pumped out of the ground.

Groundwater does not occur as underground rivers and lakes.

Instead, water from rain and snow infiltrates the soil and

percolates down, filling pores and cracks in rocks and other

material beneath the surface of the earth. Depending on the

hydraulic gradient and the rock material’s permeability, the

groundwater moves more or less slowly through these underground

materials toward points of discharge, such as lakes or pumping

wells. The permeable rock materials that the groundwater travels

through are known as aquifers.

Generally, an “aquifer” is defined as an underground

section of material capable of storing and transmitting water in useable quantities. Typically, an aquifer is composed of sand

and gravel deposits (unconsolidated), or a layer of sandstone or

fractured limestone (consolidated). Usually, unconsolidated

acquifers provide much greater yields than consolidated

aquifers.

In the present case, unconsolidated alluvial deposits filled

an ancient preglacial stream bed underlying a portion of the

floodplain in which Pleasant City’s water well field is located.

These deposits act as an aquifer. The aquifer is a mixture of

sand and gravel located below clay and above bedrock. Because it

consists of a series of intertwining channels of permeable

material that weave throughout the valley, the aquifer is oddly

shaped and its precise outline is unknown. This aquifer system

is unique, being the only groundwater system in Noble or Guernsey

Counties capable of producing any significant quantity of

groundwater.

In September 1987, the United States Environmental

Protection Agency designated approximately one thousand acres,

which includes most of the petition area, as a sole-source

aquifer. 52 F.R. 32342 et seq. This is a protective designation

which restricts federal funding for projects that might adversely

affect the aquifer.

Since 1914, Pleasant City has been obtaining its water from

the aquifer that is the subject of the petition. Currently, it

utilizes two wells, CW-1 and CW-2, which are the sole source of

public water for the village. The wells are alternately pumped,

at approximately ninety-five gallons per minute, for a total of

eight to ten hours per day. The system serves nine hundred

ninety residents and has operated in essentially the same manner at the same pumping rates, for the past decade.

As water is pumped from an aquifer, the groundwater level is

lowered. The distance that the level is lowered is referred to

as the “drawdown.” The drawdown does not occur as a straight

line, but rather as a curve. Creating a phenomenon resembling

an inverted cone, with the peak pointing down toward the aquifer

and the base expanding around the wellhead, this underground

surface of the groundwater level is called a cone of depression.

Whenever groundwater deposits are depleted by pumping, a cone of

depression is created.

The outer boundary of the cone defines the area of influence

of the well that creates the cone. The cone of depression forms

within the aquifer, and both are dependent on the recharge area

for replenishment. Consequently, a recharge area, which is

simply an area that contributes water to the groundwater system,

is larger than the cone of depression. In the present case,

although the exact boundaries of the village aquifer and recharge

area are not known, it appears that the entire floodplain (land

below the eight hundred twenty foot contour) of Buffalo Fork,

Buffalo Creek and Wills Creek is part of the recharge area.

Certain activities, such as mining, can adversely affect the long-

range productivity of the well, the aquifer and the recharge

area. For example, excavated mine pits are dewatered, creating a

cone of depression which may intersect the cone of depression of

an adjacent well. This dewatering may also reduce groundwater

levels, at least temporarily. During reclamation the original

stratified deposits removed during excavation are replaced with

“mine spoil.” Mine spoil is a mixture of the excavated material and is less permeable than the original stratified material.

This can affect the water storage capacity and water transmission

ability of the aquifer and recharge area.

Appellant R.T.G., Inc. (“RTG”) has mined, pursuant to

permits issued by the division, one hundred acres within the

petition area. Mining of this one hundred acres would not

affected by designation of the lands as unsuitable for mining.

RTG also owns the coal-mining rights to additional land located

in the petition area. RTG’s mining permits were issued over the

opposition of the village. After issuance of the mining permit,

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