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\~ .~ ,~ ~ <br />• records, the 1983 permit for Hawk's Nest tha lwas approved by the <br />Board. Division staff were told of this by ~s. Johnson, but they <br />did not require New Castle to amend its application and, as far <br />as we know, made no check of the Division's records to confirm <br />our finding and correct the entries in the A-V system. Nor did <br />the Division staff check other sources available such as the <br />Nexus system. The New Castle application was approved despite <br />the failure of Mr. Matthies to amend his application with the <br />required information. <br />GCA Proposal: <br />a. The staff be instructed to perform independent <br />verification of applicants' legal and financial interests and to <br />require all applicants to make full public disclosure in the <br />permit applications. Such verification should use information in <br />addition to that found in the OSM Applicator-Violator System. <br />b. The staff be instructed in writing on their <br />responsibilities in dealing with citizens including: to inform <br />citizens fully and correctly of their rights, to discuss citizen <br />concerns in a professional, non-adversarial manner, and to avoid <br />actions and words that discourage citizens from exercising their <br />rights. <br />S. a. Eastside has applied to remove the Rifle load out <br />from its permit area. The current mine permit is not complete <br />because it includes no description and maps of facilities for <br />transporting the coal from the mine site and a description of how <br />the permitted production, 200,000 tons of coal, will enter inter- <br />state commerce. Mines don't produce coal for the fun of it and <br />the basic question of the coal processing and transportation must <br />be answered in all permit applications to ensure that the permit <br />application addresses all required facilities and land disturb- <br />ances that are encompassed in the Act. At our meeting with you <br />on October 24, 1990, you seemed very surprised when Alliance <br />members told you about the company's plans to build a power plant <br />adjacent to the mine. In fact, the company has not comprehen- <br />sively described and disclosed the array of operations contem- <br />plated or required in this five-year permit term nor for the life <br />of mine operations. This failure does not meet the requirements <br />of Section 34-33-111(1)(a) and (e) of the Act and Rule 2.05, <br />b. By letter on May 1, 1990, Eastside requested permission <br />from the Garfield County Commission to load and sell coal, de- <br />claring these activities were necessary to control "fine coal <br />blowing during periods of high winds." We have evidence that the <br />operations at the mine are not sufficiently controlling air and <br />water pollution. <br />The attached photographs show enormous amounts of dust being <br />generated by loading operations at the mine on September 12, <br />1990. (The company informed the Division it was dropping its <br />temporary cessation status on September 10, 1990.) These photo- <br />graphs also show that the coal stockpile is located very near the <br />3 <br />