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<br />CCC had already decided to cease coal extraction in Section 17 until TR-53 was approved. They <br />provided me with a copy of their ground survey (attached), as well as their approved Mine Plan <br />Map 23 (attached; certified 9/30/98), which indicates the approved limits of coal mining. <br />Comparison of these two documents indicates the extent and location of this violation. <br />I took several photographs of the area where the coal had been removed (in NOV file). Harry <br />Ranney also took some aerial photographs from the same area a few days later (in NOV file). <br />These photos indicate surface disturbances such as topsoil stripping and salvaging, overburden <br />drilling and blasting, and spoil handling, occurring in Section 17. There is also evidence of these <br />surface disturbances having already occurred in Section 21. It does not appear that these type of <br />disturbances have occurred in Section 20. <br />CCC asserts that the 1992 OSM mine plan modification document (attached) gave CCC the <br />approval to conduct surface disturbances in leases C-29225 (Section 17) and C-29226 (Sections <br />20 and 21). I contacted the BLM from CCC's offices on May 16, to confirm CCC had the right <br />to enter both C-29225 and C-29226. Mr. Jerry Strahan said they did, and he has submitted letters <br />to DMG to that effect (in NOV file). <br />After weighing as much of the evidence as I could on May 16, I wrote NOV CV-2001-011 for <br />CCC's failure to comply with its approved mine plan (specifically Map 23), and for <br />implementing a TR before obtaining final DMG approval. The two required abatement steps <br />were for CCC to cease extracting coal immediately (which they have done) and to obtain <br />approval of TR-53 (for which they have diligently provided responses to our adequacy review, <br />and for which we e-mailed yesterday our second adequacy letter). <br />