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2020-06-23_REVISION - C1980007
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2020-06-23_REVISION - C1980007
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Entry Properties
Last modified
6/24/2020 1:01:39 PM
Creation date
6/23/2020 12:49:56 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1980007
IBM Index Class Name
Revision
Doc Date
6/23/2020
Doc Name
Objection
From
Wild Earth Guardians
To
MLRB
Type & Sequence
MR446
Email Name
JRS
LDS
CMM
JDM
Media Type
D
Archive
No
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authorizing temporary road -building to support coal mining. Because the Colorado Roadless <br />Rule generally prohibits road construction, tree cutting, and linear construction activities within <br />designated roadless areas, including the Sunset Roadless Area at issue here, 36 C.F.R. § 294.42— <br />.44, the North Fork Exception was an essential legal underpinning for DRMS's authorization of <br />Mountain Coal's expansion of the West Elk Mine, including construction of roads and methane <br />drainage wells ("MDWs"), in the Sunset Roadless Area. 36 C.F.R. § 294.43(c)(1)(ix). Vacatur of <br />the North Fork Exception renders the Exception void and DRMS's approvals for Mountain <br />Coal's surface activities in the Sunset Roadless Area — including MR -446 — unlawful. Mountain <br />Coal consequently lacks a legal right of entry to conduct surface -disturbing activities in violation <br />of the Colorado Roadless Rule. Despite this lack of legal authority, we understand that during the <br />week of June 1, the company illegally entered and completed approximately one mile of road <br />construction and extensive tree cutting above the Sunset 2 panel. See Conservation Groups, <br />Request for DRMS Inspection (June 11, 2020) (attached as Exhibit Q. On June 16, 2020 DRMS <br />granted Conservation Groups' request for inspection related to Mountain Coal's road -building <br />activities within the Sunset Roadless Area, and a formal inspection took place on June 18, 2020. <br />The inspection disclosed that Mountain Coal had, since June 11, constructed two drilling pads <br />for methane drainage wells along the illegally constructed route. Below are photos taken at this <br />inspection by Juli Slivka of Wilderness Workshop. <br />2 <br />
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