Sign Letter to Gov. Hochul

The Honorable Kathy Hochul
Governor of New York State
NYS State Capitol Building
Albany, NY 12224

Re:  Safety issues at Cayuga Lake and Cayuga Salt Mine

Dear Governor Hochul:

Cayuga Lake Environmental Action Now (CLEAN) is a citizen group working to protect Cayuga Lake from industrial contamination including salt from Cayuga Salt Mine, coal ash leachate from Cayuga Operating Company, and PFAS compounds flowing into the lake from several facility outfalls.

We are writing to share our concern regarding the on-going lack of effective NYS laws to adequately protect lakes and other waterways from increasing salinization caused by salt mining and applications of road salt each winter.  New York State lacks the needed legislation to adequately regulate its two room and pillar salt mines as well as the two solution salt mines at the south end of Seneca Lake. At the same time, New York needs to more carefully regulate the application of salt to roads, parking lots and sidewalks each winter.

We urge you and your staff to consider the following:

1.   Passage of effective mining laws.  New York State’s Mined Land Reclamation Law—which was written largely to regulate surface mining–needs to be rewritten to:

a.   prohibit room and pillar mining under large lakes and rivers

b.   prohibit solution salt mining under large lakes and rivers

c.   implement rigorous use of the Environmental Impact Studies as part of mine permit issuance and renewal

d.   create and enforce effective mine egress regulations for room and pillar mines

e.   require rigorous environmental bonding to pay for potential harm to waterways and soil

f.    require rigorous mine closure planning for both solution mining cavities and for room and pillar mines including whether salt mine voids need to be conserved for alternative uses rather than flooded.

2.  Current mine egress issues at Cayuga Mine. Cargill recently completed Shaft 4 which effectively shortens in-mine commute times for miners to exit the mine by about 30 minutes.  The shaft also provides another means for miners to reach the surface.  On the other hand, neither Cargill nor the U.S. Dept. of Labor’s Mine Safety and Health Administration are enforcing Federal Law 30 CFR § 57.11050a which requires operators of underground non-metal mines to provide miners with: (bolding added for emphasis)

“two or more separate, properly maintained escapeways to the surface from the lowest levels which are so positioned that damage to one shall not lessen the effectiveness of the others.”

A 2017 Cargill mine map shows the southern end of NW3, the only tunnel that miners can use to exit from current active mining faces at the north end of Cayuga Mine. There are four rows of small yielding pillars within the <400-foot-wide tunnel that create a total of five parallel lanes or passageways within the tunnel.  It is not correct for MSHA and Cargill to be treating each lane or passageway as a separate escapeway.  A fire, explosion, or mine collapse in one or more lanes could readily “lessen the effectiveness of the others.”

3.   Cayuga and Seneca Lake Issues. Cayuga Lake  contains 9.5 cubic kilometers and Seneca Lake 15.9 cubic kilometers of potable drinking water.  These two lakes are the largest of the 11 Finger Lakes and >100 years of salt mining at the south end of each lake is thought to have more than doubled the sodium content of both lakes. These lakes are invaluable natural resource that grows increasingly valuable as climate change is melting the world’s glaciers and ice sheets globally. The sodium content of the water of both lakes is already more than twice that which is safe for people with hypertension, which may be as high as half the adult US population. The Syracuse salt formation extends from Syracuse NY to Detroit MI so it makes no sense to allow salt mining underneath large lakes just to accommodate a mining company’s preference to only negotiate with one owner and to enjoy the higher extraction ratios and thus higher profits that mining under water often enables.

We urge you to consider putting an immediate moratorium on mining salt under and near all large lakes in New York.  The DEC could be directed to require Cargill to halt its room and pillar mining under Cayuga Lake as well requiring Cargill and U.S. Salt to halt all solution mining under and near Seneca Lake and to shift to mining under land with a geologically reasonable setback from these lakes. (It’s not clear whether it would be physically possible for Cargill to adequately seal the existing connections between their existing on-land shafts and the mine under the lake so as to enable these shafts to be used for under-land mining without increasing future risks to Cayuga Lake.)

Sincerely yours,

The Undersigned

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