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2017-11-10_GENERAL DOCUMENTS - C1980007
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2017-11-10_GENERAL DOCUMENTS - C1980007
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Last modified
11/30/2017 11:03:45 AM
Creation date
11/22/2017 6:36:33 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1980007
IBM Index Class Name
General Documents
Doc Date
11/10/2017
Doc Name Note
Notice of Intent to File Suit Over Failure to Respond to Request for Inspection Under OSM Control
Doc Name
Notice of Intent to File Suit Over Failure to Respond to Request for Inspection Under OSM Control
From
Wild Earth Guardians
To
DRMS
Permit Index Doc Type
General Correspondence
Email Name
MPB
JRS
LDS
Media Type
D
Archive
No
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On October 20, 2017, WildEarth Guardians submitted a request for OSMRE to inspect <br />Arch Coal's West Elk coal mine in Gunnison County, Colorado. West Elk is permitted to mine <br />pursuant to Colorado permit number C-1980-007. The request for inspection presented <br />information and evidence demonstrating that methane venting activities at the West Elk mine <br />were occurring in a manner that violated state and federal air quality laws and regulations, <br />thereby violating permit C-1980-007 and applicable state and federal regulations implementing <br />SMCRA. <br />WildEarth Guardians' request for an inspection was e-mailed and mailed via certified <br />U.S. Priority Mail to the OSMRE Western Regional Director, David Berry, on October 20, 2017. <br />The e-mail version was presumably received by Mr. Berry on October 20, 2017 while the hard <br />copy request was received by OSMRE on October 23, 2017. <br />In accordance with SMCRA rules, OSMRE was required to respond to WildEarth <br />Guardians' request for an inspection no later than 15 days after its receipt. Even presuming that <br />OSMRE officially received the request for an inspection on October 23, 2017, a written decision <br />was required to send WildEarth Guardians a response on or before November 7, 2017. As of the <br />date of this notice letter, OSMRE has not responded to WildEarth Guardians' request for an <br />inspection. You are therefore in violation of an "act or duty under [SMCRA] which is not <br />discretionary[.]" 30 U.S.C. § 1270(a)(2). <br />By this letter, Guardians provides notice of its intent to file suit in federal court after 60 <br />days if a decision on its October 20, 2017 request for an inspection of the West Elk mine is not <br />responded to as required by SMCRA. Pursuant to 30 C.F.R. § 700.13(b), notice is being <br />provided by certified mail to the Secretary and to the Acting Director. <br />In accordance with 30 C.F.R. § 700.13(f), the name, address, and telephone number of <br />the person giving notice is as follows: <br />Jeremy Nichols - Climate and Energy Program Director <br />WildEarth Guardians <br />2590 Walnut St. <br />Denver, CO 80205 <br />(303)437-7663 <br />jnicholsLaswildearthguardians.org <br />Sin�e�y,� <br />Jeremy Nichols <br />Cc: David Berry, Regional Director, Western Regional Office OSMRE <br />Ginny Brannon, Director, Colorado Division of Reclamation, Mining and Safety <br />2 <br />
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