yes I see your point, but following that logic, you wouldn't buy shares that weren't at their highs, which seems to me to be just as risky.
I think if there is a valid reason for the share-price to be going down (i.e. low demand for coal in this case) that is likely to reverse in the future (non-renewable resource, increasing global population) then why not average down.
I'm not suggesting buy on the way down, and I'm not about to try and pick the bottom, but I think to say averaging down is always a waste of time is too much of a generalisation.
MCC Price at posting:
$3.60 Sentiment: None Disclosure: Held