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ENFORCE29301
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ENFORCE29301
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Entry Properties
Last modified
8/24/2016 7:36:21 PM
Creation date
11/21/2007 12:12:52 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1980006
IBM Index Class Name
Enforcement
Doc Date
9/19/1994
Doc Name
APPEAL FROM DENIAL OF APPLICATION FOR TEMPORARY RELIEF
Violation No.
TD1994020352002TV1
Media Type
D
Archive
No
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drainage system; 15 acres of drainage that used to drain east <br />into the Canadian River, now drains through the Bush Draw into <br />the Canadian River (Tr: 142-43). However, this change did not <br />significantly affect the drainage system and the site has posi- <br />tive drainage (Tr., 309, 381-82). <br />Based on these differences from the premining condition, <br />OSM found that Kerr had not met AOC standards. Basically, OSM's <br />position is that the land actually mined must be returned to pre- <br />mining condition (Tr., 86, 167-68). That is, Kerr must put the <br />ridge generally back to its same elevation and slope (Tr., <br />167-69). <br />DMG's position is that to determine AOC, the Division looks <br />at surrounding landforms, not just the exact area disturbed by <br />mining, and whether the drainage blends into the surrounding to- <br />pography (Tr., 395-96, 402-03). These requirements were met. <br />OSM's own policy directive provides that if the determina- <br />tion of AOC by the state is reasonable, the state's decision <br />should stand. The DMG's determination here was reasonable and is <br />supported by the evidence in the record. Given that DMG has pri- <br />macy, oSM should not second guess DMG's determination concerning <br />AOC, especially where there is no environmental benefit to <br />-14- <br />
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