But a recently published analysis from the Washington County-based nonprofit claims that the latest DEP report illustrates the program’s shortcomings. ”DEP is continuing to review the claims in the report from Citizens Coal Council,” the spokesperson said. “Major step backwards”The Citizens Coal Council report highlighted numerous issues they found in the latest Act 54 report. DEP’s most recent Act 54 report was prepared in-house. The Citizens Coal Council report calls this “a striking and counterintuitive result the report does not explore, explain, or even appear to notice.”