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paper exercise. While Conservation Groups indicated this concern to DRMS many times, no new public comment period commenced nor was the denial of access to private lands cured.13 This lack of response indicates a need for greater clarity as to what situations give rise to a renewed public engagement period and who makes that decision. CONCLUSION For the reasons set forth above, Conservation Groups request a hearing before the Board. Conservation Groups ask that the Board: • Order a new public comment period, per MLRB Rule 1.6.6; • Order that Conservation Groups shall have access to the private lands they were denied access to, per MLRB Rule 2.07.3(6)(b)(iii); • Order that Conservation Groups are provided another opportunity for an informal conference, per MLRB Rule 2.07.3(5); and • Set aside the permit revision until the agency provides the requested additional public engagement period and access to private lands within the permit revision boundary. DRMS regulations provide broad authority to protect the environment and that the agency failed to exercise this authority properly, executing the permit process improperly and failing to scrutinize Mountain Coal's permit revision application and subsequent revisions. While Conservation Groups have engaged since the beginning with serious concerns, the process marched on without pause. Despite the application's eventual completion, the final application that was approved by DRMS was not evaluated by the public, wholly circumventing its obligation to provide for engagement around decisions impacting our public lands and national forests. Conservation Groups' concerns remain valid. An additional comment period, access to private lands, and informal conference would allow Conservation Groups to meaningfully engage and allow for DRMS to meet their procedural obligations; especially crucial as it relates to actions involving our public lands and national forests. If you have any questions about this request, please contact me at (630) 699-7165. We look forward to the scheduled hearing within 30 days of receipt of this request, according to MLRB Rule 2.7.4(3)(a)). Thank you for your attention to this matter. Sincerely, Shannon A. Hughes Climate Guardian and Attorney for WildEarth Guardians 2590 Walnut Street Denver, CO 80205 13 Conservation Groups noted these concerns in the June 25, 2018 letter, during the August 1, 2018 informal conference, as well as the August 20, 2018 letter which provided additional comments pursuant to MLRB Rule 2.07.4(2)(a). 15