From: Mick McCaslin <
mick.mccaslin@live.com>
Sent: Thursday, April 18, 2024 8:27 AM
Subject: Call to Action - Planned Changes Utah Administrative Code - R647-4
To the Membership of Utah MMSA:
I urge you to contact the Utah Mining Association (UMA) today and express concerns about their review of the planned changes to Utah Administrative Code R647-4. These changes could have serious implications for Utah mines. UMA was asked to comment, but their response has apparently been minimal. They are the best avenue to have your voice heard by the Utah Division of Oil, Gas, & Mining (DOGM), as DOGM contacted them directly about the proposed changes, which are likely to be adopted in the next meeting on April 24.
Utah Mining Association
4286 S Main St, Murray, UT 84107
Phone: (801) 364-1874
https://utahmining.org/
Of course, you can attend the DOGM meeting yourself, but with no time to get on the docket, you will not have an opportunity to express your views. Hence, I think UMA is the best option.
Why:
DOGM is planning to improve the definitions for what changes at a mine are Significant vs. Insignificant. While providing better definition is laudable, I think the proposed language is not well considered and will put a great many relatively minor changes into the "Significant" category, which means public comment would be required before the change can be made. For example, adopting a new type of process equipment for an operation could be held up awaiting input from the general public; regardless of whether that equipment reduces emissions, improves efficiency, increases efficacy, etc.
Background:
Link to the last DOGM meeting. Rule-making started at approximately 3 pm, more than 5 hrs into the Board meeting.
https://www.youtube.com/watch?v=jQkmY8ZAV8g&list=PLWIxD5-tnhxoPWemeI_i7l6wwX6DYFS8z&index=4
Link to the Board's website:
https://www.ogm.utah.gov/board-home/
Link to agenda for the next meeting on Wednesday the 24th.
https://ut-dnr-ogm-prod-sf-public-bucket.s3.amazonaws.com/a0S8z000001L2NbEAK_1713371038228_20240424_AprAgenda.pdf
Thank you for your attention to this matter.
Sincerely,
Mick
Mick L. McCaslin, P.E.
764 Labrum Avenue
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__________________________
ABANI R. SAMAL, Ph.D.
CPG, RM- SME, Fellow - SME, Fellow-SEG
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