Jefferson County Foundation asks WV EQB to reopen Rockwool Construction Stormwater Permit appeal after bombshell emails discovered from DEP
It seems that the WV Department of Environmental Protection’s (DEP) permit review process has been tainted by political pressure disregarding the environmental impact of Rockwool’s factory construction in Jefferson County. In an email thread that started on January 14, 2020, Yogesh Patel, Assistant Director of the Water and Waste Management division and supervisor of the permit writing team, tells the permit reviewer, Rick Adams, “Permit need (sic) to get it out on or before 01/24/2020.” Adams pushes back, stating, “I don’t think we can get permit out by Friday.” Patel responds moments later, “We have too (sic). Cabinet Secretary has committed, we do not have any choice.”
This alarming discovery comes after the hearing in the Foundation’s appeal of Rockwool’s construction stormwater permit has been completed, after post-hearing briefs were filed, and while the case is awaiting a decision by the state Environmental Quality Board (EQB). At least four DEP employees, three of whom were deposed and testified under oath, failed to identify these facts. The emails were not produced as part of the Certified Record of the Construction Stormwater Appeal 20-02-EQB. Needless to say, had this email been produced when it should have been during the case proceedings, the Foundation would have had the chance to dig further into the apparent political pressure on DEP staff to issue Rockwool’s permit.
In light of the emails that have just been discovered, on June 10, 2021 attorneys for the Foundation filed a motion before the EQB asking for reopening of the record and proceedings in the Construction Stormwater Permit Appeal, stating that “[i]f the DEP is allowed to selectively and without consequences withhold documents from the Certified Record, the process is without credibility. Presumably that is why the Legislature set as the first requirement after an appeal is filed in an environmental case, the production [of] a full and complete record.” The motion continues, “The disclosure of political influence on the permit review process, apparently exercised by the former Secretary, are matters of significant concern and information about same should properly have been put before the EQB and should have been available during the hearing process.”
On June 11, the EQB responded to the Motion and scheduled a hearing for June 24 requiring the parties to fully brief the issue before the hearing. Relatedly, the Foundation continues to work on its appeal of Rockwool’s Operational Stormwater Permit, 20-13-EQB (the email string that just came to light was recently produced by DEP during discovery for this appeal).
Jefferson County Foundation continues to spring forward with momentum in the fight to protect our region’s natural resources. Recent developments prove that we must act with incredible urgency. Now is the time to support these critical actions. Please donate if you can. To update you:
Educate and Empower the Public
The Foundation has filed four more FOIA to state and federal government agencies due to new issues which continue to arise. The FOIA requests are time consuming but necessary as we continue to seek truth in matters that affect our region’s natural resources.
Advocate to Regulators and Leaders
Photo of B170 as of July 15, 2020. Gravel-covered. No enclosure.
The Foundation sent a letter to the West Virginia Department of Environmental Protection (DEP) and the federal Environmental Protection Agency (EPA) regarding Rockwool’s inaccurate and incomplete form submission for Resource Conservation and Recovery Act (RCRA), which requires the company to notify the EPA about how it intends to handle regulated waste at its facility. Rockwool cannot continue to be allowed to submit inconsistent, incomplete and inaccurate information for permits. It’s simply not protective of the environment and will lead to the degradation of our natural resources and the downturn of our economy, health, safety, and welfare. Read the full letter here.
The Foundation sent a letter of complaint to the DEP regarding the lack of proper public notice about the Sheetz Truck Facility Construction Stormwater General Permit (CGP) application. Sheetz, Inc. applied for a new permit on November 20, 2020, and as of the date of our letter, still had not posted the public notice sign as required by this type of permit. A public notice sign is the only method by which the public may become aware of this type of project and be drawn to review the permit and offer comment. Violations of these requirements in the CGP effectively eliminate the involvement of the public in the review process, and remove an avenue for the public to seek relief that was clearly intended by the CGP. We continue to hold the DEP to the requirements of the law and await the response on this matter.
Legal Updates
Constitutionality of the $150M Tax Abatement Deal with WVEDA
The Foundation is appealing the decision of the judge who dismissed the case in the legal challenge of the constitutionality of the $150 Million tax abatement deal the WVEDA made with Rockwool. The case was dismissed because the business court concluded that the legislature intended to allow these types of arrangements. The court did not answer the constitutional question or if the constitution allows these arrangements. We are appealing the decision as constitutionality was the basis of our suit. The constitution requires equity; every entity pays their fair share. For more information about this case and our view of PILOTs in general, read here.
Rockwool Stormwater Construction Permit Hearing Continues this Thursday
The Jefferson County Foundation v. WVDEP and Rockwool case that challenges Rockwool’s Construction Stormwater permit continues this Thursday. The hearing, which started last year, was originally continued into January at the request of the DEP so they could complete the certified record. The DEP was again unable to deliver the certified record in time for the hearing and now the hearing has been rescheduled for this Thursday. For more information on this case, please read here. We will share the link to watch the hearing on our Facebook page closer to the date.
Preparing for Discovery for Rockwool’s Operational Stormwater Permit Appeal
The Foundation continues to work on discovery in the appeal of Rockwool’s operational stormwater permit. The new expert’s assessment is underway. The evidentiary hearing has been set for April 8 and 9. Read the appeal.
Charles Town Votes on Resolution to Abandon the Bond to Pay for the Super Sewer to Rockwool
We are relieved to see that Mayor Trainor listened to the Foundation’s call last November to abandon the bond and require Rockwool to pay for its own sewer through the 5.5-7h process it has relied upon to build the sewer. The Charles Town City Council will vote on Monday, March 15 on a resolution to declare the ordinance moot. The Foundation would like to thank the over 1,500 people who signed the petition in opposition of the bond, and the volunteers from the Super Blue Petition Crew that helped gather these signatures. We collected signatures from well over 30% of the free holders, representing 34% of the adult population of Charles Town, all in eight weeks. As the Blue Petition Project Manager, I would personally like to thank those who gave countless hours of tireless dedication to getting the job done, in an amazingly short amount of time!
Support the Foundation’s Work
Please check out our 2020 Annual Report. The discovery process is expensive, but necessary in order to submit more evidence into the record. We appreciate your support while we are conducting this process. Please, if you are able, consider a donation to the Foundation Legal Fund. You can donate safely and easily online at the Foundation’s website. You can also help by sending a check to Jefferson County Foundation, Inc., PO Box 460, Ranson, WV 25438.
For those that are contributing, we thank you for your dedication to bring truth to light and to protect our natural resources. We appreciate your continued support! In the meantime, we’ll keep you posted on how our active cases are going.
There’s lots of activity to report on, and we have some good news to share. Thanks to your generosity, we met our match last week! We are also excited to announce today that another generous donor has come forward and is matching donations the Foundation Legal Fund. So, if you missed the last opportunity, now’s your chance; donate today and your money will go twice as far.
The Foundation has filed FOIA to four state and federal government agencies this month. We hope the new administration will lead to more accurate information production. This information will be key for continued protection of the the air and water in region.
Advocate to Regulators and Leaders
The Foundation, in partnership with the Eastern Panhandle chapter of the Sierra Club, met with Senator Manchin’s office recently to update them on the situation with the DEP and Rockwool. This is part of a broader strategy to engage leaders at the federal level.
Legal Updates
Constitutionality of the $150M Tax Abatement Deal with WVEDA
A scheduling order was made by the judge in the Foundation’s legal challenge of the constitutionality of the $150 Million tax abatement deal the WVEDA made with Rockwool. The motion to dismiss made by Rockwool and joined by the WVEDA has been fully briefed and we await the decision of the judge. For more information about this case, please read here.
Rockwool Stormwater Construction Permit Hearing to be Continued… now in March
The Jefferson County Foundation v. WVDEP and Rockwool case that challenges Rockwool’s Construction Stormwater permit, which was due to resume last Thursday, has been postponed again. Thursday’s hearing was supposed to complete the hearing that started on December 11 and 12 but which was continued into January at the request of the DEP so they could complete the certified record. The DEP once again was unable to deliver the certified record in time for the hearning and now the hearing has now been rescheduled for March. For more information on this case and the reason for another delay, please read here.
Update: the DEP finally produced the certified record yesterday. The legal team is poring over the document so please stay tuned for more information.
Preparing for Discovery for Rockwool’s Operational Stormwater Permit Appeal
The Foundation is currently mid-discovery in the appeal of Rockwool’s operational stormwater permit. Multiple depositions and expert witnesses will be required for this case. While this will be resource intensive, it is critical to the success of our case. This case is critical to protecting the groundwater in the region. The evidentiary hearing has been set for April 8 and 9. Read the notice of appeal here.
Fighting the Super Sewer to Rockwool
We are waiting for the Kanawha County circuit court Judge to direct the schedule in the Foundation’s circuit court appeal of the EQB decision to dismiss the appeal of DEP Unilateral Order 9080, which allowed Charles Town to construct the Route 9 sewer extension (the super sewer to Rockwool) without a valid stormwater permit. Rockwool, one of three interveners, submitted a motion to dismiss in late December. For more information about this case, please read here.
Support the Foundation’s Work
Please check out our 2020 Annual Report. The discovery process is expensive, but necessary in order to submit more evidence into the record. We appreciate your support while we are conducting this process. Please, if you are able, consider a donation to the Foundation Legal Fund. For a limited time, all donations are again being matched by a generous donor, so your donation will go twice as far. You can donate safely and easily online here. You can also help by sending a check to Jefferson County Foundation, Inc., PO Box 460, Ranson, WV 25438.
For those that have contributed, we thank you for your dedication to bring truth to light and to protect our natural resources. We appreciate your continued support! In the meantime, we’ll keep you posted on how our active cases are going.
Jefferson County Foundation’s legal team is on fire these last few weeks. We have two big things to share:
Arbitrary and capricious! That’s how WVDEP acted in rubber-stamping Rockwool’s stormwater permit which allows discharge of 86,000 gallons a day to sinkhole-prone land, says Jefferson County Foundation’s legal team in its latest regulatory legal action. With that kind of volume – more than 10 large tanker trucks a day – even small quantities of pollutants caught in rainwater and runoff can concentrate and run into the ground impacting our region’s water. We filed an appeal on Friday, December 4 to the Environmental Quality Board regarding Rockwool’s Multi-Sector Stormwater Permit Registration. Read the appeal here.
Our hearing on Rockwool’s Stormwater Construction General Permit Registration is tomorrow and Friday, December 10 and 11 starting at 8:30 a.m. and you can tune in to hear the case! This hearing is open to the public and is going to be worth listening to, so please tune in. This is the evidentiary hearing you and we have been fighting for since October 23, 2019. Jefferson County Foundation is following through and standing strong. Help us hold the line.
How many sinkholes does it take to get to the center of our drinking water supply, DEP? Inquiring minds want to know.
The Rockwool Construction Stormwater Permit Modification was approved November 20, 2020. Rockwool uploaded a new Site Map, and now we have another new sinkhole, #22, within the Limit of Disturbance (LOD) and a few feet away from the conduit to the Bioretention Pond and outlet #2. It is an active sinkhole 180 feet from the natural gas pipeline and 420 feet from the 8-story furnace and smoke stack #1.
If the sinkhole causes failure of the conduit, then all the water in the conduit that was going to the pond carrying all the pollutants that are in it will go straight into the groundwater. These include pollutants that will fall to the ground from the air emissions, other industrial processes and other outdoor storage areas.
We are working on filing an appeal to Rockwool’s Multi-Sector Stormwater Permit. We will not tolerate the DEP turning a blind eye to what can turn into a multigenerational disaster.
The Environmental Quality Board (EQB) inappropriately decided that Jefferson County Foundation’s appeal of order 9080—which allowed the City of Charles Town (CTUB) to construct the super sewer to Rockwool WITHOUT a valid permit (and over 700 other entities)—was moot. On November 25, the Foundation filed an appeal of this decision to the Kanawha County Circuit Court.
Every challenge presents an opportunity to affect change. This case in particular is another step to make the DEP and the EQB follow the law. The DEP cannot be allowed to utilize enforcement orders to permit entities to sidestep the Clean Water Act and the EQB cannot just turn a blind eye to what’s right because it’s the easy way out. We stand up to such tactics because it’s the right thing to do. And we will every time.
We got to this place of dysregulation because the people did not hold the government to account. We have to now hold the line and never give up.
The dates for the hearing have been moved from November 12 and 13 to December 10 and 11 due to judge availability. This will be a public hearing and will be open to the public to listen in. In the meantime, the Foundation is working on several new legal challenges to protect the region’s water and hold the DEP accountable. We will keep you updated.
On October 29, the Environmental Quality Board heard arguments on the pre-trial motions in the Jefferson County Foundation v. WVDEP and Rockwool case challenging Rockwool’s Construction Stormwater permit. Rockwool’s five motions asked the Board to preclude evidence and decide nearly all of the case before evidence is heard. After hearing arguments and reviewing the motions, the Board found IN FAVOR of JEFFERSON COUNTY FOUNDATION and DENIED Rockwool’s motions. The evidentiary hearing is set for November 12 and 13, 2020.
Jefferson County Foundation sends Notice of Intent to File Suit
Ranson is administering the Northport Avenue road extension construction project — the road to Rockwool — for the West Virginia Department of Highways without a valid construction stormwater permit. The project has been inspected by the West Virginia Department of Environmental Protection (DEP) three times and each time, Ranson has had violations. Jefferson County Foundation filed a Notice of Intent to file suit on Friday, August 7. “Our hope is that Ranson will apply for a valid Construction Stormwater General Permit Registration (CGPR) under the 2019 General Permit,” states Foundation president, Christine Wimer. “We want the DEP to require Ranson and all such entities to obtain a valid construction stormwater general permit registration. And we want the EPA to require the DEP to abide by the EPA’s objection to the DEP allowing entities to continue to operate under the invalid and less protective 2012 permit.”
The Northport Avenue extension is a project administered by the City of Ranson for the West Virginia Department of Highways (WVDOH) to extend the road and utilities in front of Rockwool. It comprises approximately 0.65 miles (or approximately 3200 LF) of a multimodal Urban Local Road and utilities that will extend the existing Northport Avenue from West Virginia Route 9 to the northern boundary of the former Jefferson Orchards parcel with a reported limit of disturbance of 24.4 acres.
Ranson accepted bids for this project from February 13, 2019 to March 11, 2019. The project was awarded to Jefferson Asphalt on April 2, 2019 by a vote of the city council (Resolution #2019-13 – A Resolution of the City Council of Ranson, West Virginia Approving a Contract with Jefferson Asphalt for the Construction of Northport Avenue).
Permitting:
A Construction Stormwater General Permit Registration (CGPR) has been applied for three times for this project by the City of Ranson.
The CGPR application was first applied for, for this project on July 23, 2018 under the 2012 Construction Stormwater General Permit (CGP). This application was terminated on December 14, 2018, by the DEP for lack of response by Ranson to DEP requests.[1] Ranson started a second Construction Stormwater General Permit Registration application on January 9, 2019. The permit was issued less than a month later on February 6, 2019. In this application, it was stated that construction would start on February 1, 2019 and end by December 31, 2019. As this was less than one year, no public comment or public notice was provided for.
The last (chronologically) comment from the permit reviewer on February 5, 2019 stated:
“The re-issued permit, WV0115924, effective February 9, 2019 requires that all BMP’s listed in the application are required to be ENHANCED BMP’s. This permit can [be] found on our website:”
“All permits issued between Feb. 9, 2018 & Feb. 9, 2019 will be given an opportunity to submit a form stating that they will be following the new permit.
This permit application has shown that “silt fence” will be used rather than the Enhanced BMP “Super Silt Fence” or “Belted Silt Fence”. Please replace these in your application and make this correction on all of your maps and narrative showing that the Re-issued Permit will be followed.”
Clearly it was the intention of the DEP to approve the permit by February 9, 2019 to afford the city of Ranson the opportunity to qualify for this provision, and allow Ranson to avoid applying under the 2019 permit. This comment was at least partially addressed by the city. In the SWPPP, 4 of the 11 times that silt fence is referred to, it was updated to belted silt fencing. However, the much larger issue here is that the permit reviewer incorrectly implies that the only difference between the 2012 and 2019 is the Enhanced BMP. This is an egregious oversimplification. Most notably, this project would have to have a stand-alone project specific GPP (Groundwater Protection Plan) with a Karst Mitigation Plan. This was not done.
Nevertheless, after issuance of the permit registration on February 6, 2019, this project was not started in February as initially planned.
On June 7, 2019, a reissuance of the registration under the 2019 permit was applied for and granted on September 11, 2019. This application was incomplete with only 7 out of 20 sections submitted and provided for; no substantive changes to the actual stormwater handling. The only two changes were to the signature page, now referred to the 2019 general permit, and the timeline was lengthened to over one year. No actual review of this application seems to have been done with no comment or applicant comments recorded, and no record of review in the application tracking page.
The City of Ranson is now operating this project under this reissuance and has incurred multiple violations.
Northport Avenue: A Timeline
July 23, 2018
1st Construction Stormwater General Permit Registration (CGPR) Application
Ranson applies under the 2012 Construction Stormwater Permit
July 23, 2018
December 18, 2018
Application Terminated by the DEP
This application was terminated on December 14, 2018, by the DEP for lack of response by Ranson to DEP requests.
December 18, 2018
January 9, 2019
2nd CGPR Application Submitted by Ranson
Ranson started a second Construction Stormwater General Permit Registration application on January 9, 2019
January 9, 2019
February 5, 2019
DEP Requests Permit Correction
The DEP makes several comments on the permit about making Best Management Practices (BMPs) into ENHANCED BMPs, including comments about silt fencing and signing a statement that the permitee will follow the new 2019 guidelines.
February 5, 2019
February 6, 2019
DEP Approves the Permit Registration under 2012
The permit stated that construction would start on February 1, 2019 and end by December 31, 2019. As this was less than one year, no public comment or public notice was provided for. However, this project was not started in February as initially planned.
February 6, 2019
June 7, 2019
3rd CGPR Application by Ranson
Ranson completes only 7 out of 20 sections, extends construction timeline to over one year.
June 7, 2019
September 11, 2019
DEP Approves Permit Registration under 2019
No change to registration materials from the 2012 application. No actual review of this application seems to have been done with no DEP comment or applicant comments recorded, and no record of review in the application tracking page.
September 11, 2019
February 6, 2020
1st DEP Inspection and Notice of Violation Issued
The DEP goes to the site to inspect and writes up a notice of violation for several issues. They were found to have sediment-laden water leaving the construction site.
February 6, 2020
March 11, 2020
2nd DEP Inspection
Some issues noted in February appear to be unresolved.
March 11, 2020
May 14, 2020
3rd Inspection and Notice of Violation
Ranson repeatedly has the same violations.
May 14, 2020
Issues:
The DEP seems to have rushed Ranson’s registration application for this project such that Ranson would avoid having to reapply under the 2019 permit. The DEP did so by approving the permit registration just two days before the deadline and less than 30 days after the application was first initiated. Only a cursory attempt was made 24 hours before the application was approved to bring it up to the standards of the 2019 general permit. Only a few words were changed and no substantive changes were made. Most notably, a Karst mitigation plan was not required. Several months later, prior to the start of construction, the permit was reissued under the 2019 general permit with no change to the substance of the application. The only change was to the timeline, which was lengthened from 11 months to more than 13. No public notice or comments were performed, as required by the permit conditions of the 2019 (and 2012) permit. Here in this case yet again we have no public notice and an end run around the 2019 permit conditions.
Though Ranson has a registration under the 2019 CGP, they do not have the required elements of that registration including a site-specific groundwater protection plan and a karst mitigation plan. Without these critical components Ranson is unable to meet the requirements of the 2019 and is effectively operating under the 2012 permit conditions. Therefore Ranson’s registration is invalid, and they are operating a construction project in violation of the Clean Water Act. Jefferson County Foundation hopes this letter persuades Ranson to apply for a valid registration under the 2019 permit, the DEP to require Ranson to do so, and the EPA to force the DEP to stop allowing entities to operate under the 2012 permit conditions.
Site inspection and violations:
The site has been inspected three times (February 6, March 11, and May 14) and incurred two notices of violations (February 6 and May 14). They repeatedly have the same violations and have even been found to have sediment-laden water leaving the construction site. Despite the warnings and violations Jefferson Asphalt seems unable to correct the errors. For example, they have been cited all three times for not having an outflow marker (permit cite evaluation number 4). Not only are they operating without a valid CGPR, but they are incurring multiple violations endangering the water resources of the county and region.
[1] Quoted directly from the Application Milestones page of the application RANSON, CITY OF New NPDES/State Storm Water Construction #1 WVR110004
Watershed protection organizations from three states plead with the EPA to make West Virginia follow the Clean Water Act
A coalition of advocates has asked the Environmental Protection Agency (EPA) to investigate the actions of the West Virginia Department of Environmental Protection (WVDEP), a state agency charged with protecting the environment but which appears to have allowed hundreds of polluters to operate in violation of the Clean Water Act, putting the surface and ground waters of the Chesapeake Bay and Ohio River Valley watersheds at risk. Documents recently obtained by Jefferson County Foundation show that the DEP advised the companies how it was going to assist them in avoiding operating without a permit, but never told the public.
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What Happened?
On January 10, 2019, the WVDEP submitted its draft of an updated Construction Stormwater General Permit (General Permit) to the EPA. On February 8, 2019, the day before it was to take effect, several industry groups appealed the new General Permit, and a stay was issued by the West Virginia Environmental Quality Board (EQB), the quasi-judicial review agency overseeing the Water and Waste Division of the WVDEP, allowing covered entities to continue to operate under an expired permit which dated back to 2012 and lacked the more-protective provisions that would have been in the 2019 General Permit. The EPA, in an October 31, 2019 specific objection letter, roundly rejected a new draft General Permit that the WVDEP submitted to it, citing backsliding, unenforceable ambiguity, and violations of the Clean Water Act. The EPA advised the WVDEP that the 2012 permit was expired and had been replaced, and directed the WVDEP not to allow any entity to continue operating under the 2012 permit or its conditions.
The WVDEP did not incorporate the suggested changes from the EPA and withdrew the draft revised permit from consideration. The WVDEP then took two even worse actions. First, the WVDEP allowed the issuance of General Permit registrations without valid applications or required materials. Second, in March of 2020, the agency issued 697 unilateral enforcement orders—almost entirely in one day—allowing entities to continue working under the 2012 General Permit. These irregularities are allowing the WVDEP to circumvent the normal permitting process and avoid complying with EPA’s requirements.
Meanwhile, the EPA has remained painfully silent for months, even though hundreds of entities in West Virginia are operating without a valid Clean Water Act permit. Jefferson County Foundation, along with watershed protection organizations from three states, have sent a formal letter of inquiry to the EPA pleading with the federal agency to exercise its oversight powers to find out why this has happened and take action to correct the situation urgently.
Lack of regulation and oversight could prove detrimental to the Ohio River Valley and Chesapeake Bay watersheds
These irregularities in process will lead to more sediment in the runoff from hundreds of construction sites entering the waterways. This can damage or destroy habitats, kill plants, and other vertebrate and non-vertebrate organisms within the water, and on the beds and banks of these waterways. Loss of vegetation can lead to further erosion and damage to the banks of waterways. Increased sediment can also affect water treatment plants and waterway recreation. The effects can further challenge rare or endangered native plant species and other vertebrate and invertebrate organisms.
In areas of karst hydrogeology, the groundwater is also at risk, affecting drinking water, and invertebrates that inhabit cave water. This includes the federally threatened Madison Cave Isopod. In the Chesapeake Bay watershed, the WVDEP’s cavalier approach means that entities are not following the newest standards to protect the bay. Clearly these actions by the WVDEP pose an unacceptable risk to water quality.
“Our goal is to make sure the WVDEP is doing their job in protecting the ground and surface water resources in West Virginia and beyond,” states Dr. Christine Wimer, president of Jefferson County Foundation. “We want the EPA to make sure that the DEP does it right; no more free passes for corporations and industries that are being allowed to skate by. Our water depends on it.”
The letter was co-signed by:
Jefferson County Foundation, Inc.
Aileen Curfman, Co-Chair, and Jim Kotcon, Conservation Chair, WV Chapter of Sierra Club
Linda Frame, President, West Virginia Environmental Council
Vivian Stockman, President, The Ohio Valley Environmental Coalition
Rosa P. Hance, Chair, Maryland Chapter Sierra Club
Paul Walker, Group Chair, Sierra Club Catoctin Group
Christopher G. Miller, President, The Piedmont Environmental Council
Brent Walls, Upper Potomac Riverkeeper
Gail Kohlhorst, Chair, Eastern Panhandle Sierra Club
Larry Thomas, President, West Virginia Highlands Conservancy
Betty L. Wiley, President, Dunkard Creek Watershed Association, Inc.
Jeff Iliff, Advocacy Committee Chairperson, Warm Springs Watershed Association
Kevin Sellner, PhD, Senior Scholar (retired), Hood College, Center for Coastal & Watershed Studies
John Doyle, Member, West Virginia House of Delegates, 67th district
Sammi Brown, Member, West Virginia House of Delegates, 65th district
