Mr. Robert Uram, Director
Office of Surface Mining
1951 Constitution Avenue, N.W.
Washington, D.C. 20240
Dear Bob:
I am writing on behalf of the Reclamation Committee of the Western Interstate Energy Board to convey the Committee's views on the draft "Progress Report on Shared Commitment"
and to express our disappointment at the inability of OSM and states to reach agreement on a workable solution to the issue of federal enforcement in primacy states. In our view, the recent letter from the Interstate Mining Compact Commission accurately reflects the sequence of events leading to the impasse on defining an appropriate role for OSM in primacy states. The bottom line is that despite numerous attempts, this important issue remains unresolved. This impasse, however, should not hinder the progress OSM and western states are making in other areas.
We are concerned that the draft "Progress Report" does not adequately reflect the real progress that has been made between OSM and western states in implementing a shared commitment in critical areas such as oversight of state programs, development of common technical priorities, and delivery of critical technical assistance. We suggest that if OSM issues a final "Progress Report" that it include reference to these areas.
It was our hope that the recent meetings in Indianapolis and Williamsburg would have produced a workable resolution to the issue of the appropriate role of OSM in primacy states -- a resolution that would have furthered the effective and efficient enforcement of the Surface Mining Control and Reclamation Act. It was our hope that such a workable solution could have been jointly presented by the states and OSM to Congress. Clearly, this did not happen and fundamental disagreements remain regarding how to efficiently administer the Act in non-imminent harm situations. While western states are willing to participate in any productive forum to resolve this issue, at the moment it appears that it is best left to Congress to find a solution.
Sincerely,
Michael Long, Chairman
Reclamation Committee