The Association filed comments this week to the proposed Title 56, Series 3 Rules governing “Surface Mining”. In addition to comments to various technical and operational provisions of the rule, the Association’s comments also questioned the underlying need in support of the proposed rule changes and whether adequate authority exist for the Agency to unilaterally propose and promulgate new safety standards, new miner certifications and training requirements in light of the statutory authority and charge of the WV Board of Coal Mine Health and Safety and the WV Board of Miner Training, Education & Certification.
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