Harman Mining Corp. v. Hodel

662 F. Supp. 629, 1987 U.S. Dist. LEXIS 5164
CourtDistrict Court, W.D. Virginia
DecidedJune 3, 1987
DocketCiv. A. No. 86-0198-A
StatusPublished

This text of 662 F. Supp. 629 (Harman Mining Corp. v. Hodel) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harman Mining Corp. v. Hodel, 662 F. Supp. 629, 1987 U.S. Dist. LEXIS 5164 (W.D. Va. 1987).

Opinion

MEMORANDUM OPINION

GLEN M. WILLIAMS, District Judge.

The plaintiff, Harman Mining Corporation (Harman), seeks review of an administrative law judge’s decision denying its request for temporary relief from a Notice of Violation (NOV) which the defendant’s enforcement office, the Office of Surface Mining Reclamation and Enforcement (OSM), issued to the plaintiff. This court has jurisdiction pursuant to 30 U.S.C. § 1276 and 28 U.S.C. § 1331.

BACKGROUND

In 1974, Harman, through Kimberly Coal Company (Kimberly), its contract miner, began mining certain coal reserves which Harman owned in Buchanan County. Kimberly operated the underground mine, which Harman designated Kimberly No. 4 Mine, from 1974 until October 1981. Neither Harman nor Kimberly, however, permitted the mine initially because it was underground.

After the Virginia Division of Mined Land Reclamation (DMLR) acquired jurisdiction over the surface effects of underground mines in 1978, Kimberly applied for a permit. DMLR determined that the mine affected 1.5 acres and issued a state permit.1 In determining the site’s affected area, DMLR did not include the acreage of several access roads (hereinafter referred to as “road”) because it considered the roads public. DMLR based this determination on the fact that Harman had deeded its interest in the road to the county and that Buchanan County had accepted it into its road system. DMLR concluded that the definition in the then-current regulation 30 C.F.R. § 710.52 excluded the road.

[631]*631In 1979, Virginia abandoned its dual permit system. Virginia reasoned that if two-acre mines were exempt from the Surface Mining Control and Reclamation Act (SMCRA), they should also be exempt from state regulation. Accordingly, DMLR notified all permit holders, whose affected area was two acres or less, that they could request withdrawal of their permit. Kimberly requested withdrawal of its permit and on August 29,1979, DMLR determined that the mine was no longer subject to regulation. Kimberly operated under no regulation until it closed in October 1981.

In October 1985, OSM inspected Kimberly’s abandoned mine site. On February 5, 1986, OSM issued a Ten-Day Notice to DMLR alleging that Kimberly did not properly reclaim the site in accordance with the federal interim program standards. DMLR conducted a field investigation in response to the Ten-Day Notice and concluded that it had no jurisdiction over the matter because the affected area was less than two acres. OSM reinspected the mine site on March 1 and March 26. OSM then issued a NOV (86-132-423-002) on April 1, 1986 to Harman rather than to Kimberly because Kimberly had gone out of business in 1982.

OSM concluded that the mine was not exempt because it in fact affected more than two acres. OSM based this conclusion on the fact that it did not believe that the road qualified for exemption as a public county road, and that after adding the road’s acreage (2.39), the mine’s total affected area exceeded two acres. OSM noted that even though Harman deeded its easement rights to Buchanan County on September 1, 1978 pursuant to Va.Code § 33.1-246.1, no party had maintained the road for the previous five years and that the road was now chained to prevent public access.

Harman filed an application for review of and a request for temporary relief from the NOV on April 21, 1986. On June 25, 1986, the Department of the Interior held a hearing in Abingdon, Virginia and in an opinion dated July 24, 1986, AU Joseph E. McGuire denied plaintiff’s request for temporary relief. Pursuant to 30 U.S.C. § 1276(a), Harman filed its complaint requesting temporary relief on August 5, 1986.

OPINION

The issue before the court is whether this court should temporarily enjoin OSM from enforcing the NOV against Harman with respect to the Kimberly No. 4 Mine. The SMCRA specifically authorizes district courts to review an ALJ’s decision denying temporary relief from a NOV. See 30 U.S.C. § 1276(a)(2), (c). The Fourth Circuit has clearly set forth the standard by which the district court shall enjoin the Secretary:

(1) all parties to the proceedings have been notified and given an opportunity to be heard on a request for temporary relief;
(2) the person requesting such relief shows that there is substantial likelihood that he will prevail on the merits of the final determination of the proceeding; and
(3) such relief will not adversely affect the public health or safety or cause significant environmental harm to land, air, or water resources.

Virginia Surface Mining and Reclamation Association v. Andrus, 604 F.2d 312, 315 (4th Cir.1979). Indeed, the Fourth Circuit’s criteria is the same criteria which Congress adopted in 30 U.S.C. § 1276(c).

It is important to note, however, that a district court in reviewing a request for temporary relief applies a different standard of review than a district court which [632]*632reviews an AU’s decision on the merits. In reviewing a decision of an AU on the merits or any other related order or decision, a district court must affirm if the findings are ‘supported by substantial evidence on the record considered as a whole.’ § 1276(b). An exception to this rule arises when a district court considers a request for temporary relief pending final determination. In this instance § 1276(c) directs the court to conduct its own examination of the criteria in § 1276(c) to determine if temporary relief is proper. See § 1276(c)(1), (2), and (3).

Harman Mining Corp. v. Office of Surface Mining, 669 F.Supp. 806, 810 (W.D.Va.1987). Therefore, this court may grant temporary relief only if Harman satisfies the above criteria. Criterion 1, however, is not in dispute.

With respect to criterion 3, the AU found that Harman had failed to demonstrate that granting temporary relief would not adversely affect the public health or safety. The unsafe conditions resulted from the unsealed and/or improperly sealed portal entries which the AU concluded presented a hazard to “unwary children and hunters.” However, the AU found that temporary relief would not “cause significant environmental harm to land, air or water resources.” This court, however, is not persuaded by the AU’s reasoning with respect to public health or safety. This court finds that Harman’s evidence that this condition has existed for five to six years without incident is more than sufficient to demonstrate that temporary relief will not affect public health or safety. In addition, the relief is only temporary not permanent, and failure to grant the relief disturbs rather than maintains the status quo.

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Related

In Re Permanent Surface Mining Regulation Litigation
620 F. Supp. 1519 (District of Columbia, 1985)
McKinstry v. Genesee County Circuit Judges
669 F. Supp. 801 (E.D. Michigan, 1987)

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Bluebook (online)
662 F. Supp. 629, 1987 U.S. Dist. LEXIS 5164, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harman-mining-corp-v-hodel-vawd-1987.