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What You Need To Know About LART
San Diego, Calif. - July 7, 2011- The Lead Agency Review Team [LART] was created to ensure all lead agencies are in compliance with the Surface Mining and Reclamation Act of 1975 [SMARA], and plans to review all lead agencies in California by 2015.
LART has been conducting reviews of the lead agency's SMARA program and issuing recommendations for improvements to solve compliance problems. However, in locations where a lead agency has several mine sites, LART will only visit a sampling of sites based on certain criteria.
When LART visits, they may review all documents that are required by SMARA, to see if they are up-to-date and in compliance. Items to be reviewed for each mine site in a lead agency include:
- Financial Assurances
- Reclamation Plans
- Inspection Reports
- Annual Reports
- Interim Management Plans
Although we have found the LART to be quite pragmatic, they are also charged with a strict interpretation of SMARA. As a result, they quite frequently identify violations that the lead agency has missed or excused. When this occurs, the lead agency is forced to require compliance. Compliance can be as simple as moving equipment off of a neighboring property to complex modifications to permits and reclamation plans.
In order to avoid violations and the costs that often result, take the time to review your compliance documents to insure that everything is in order. At times, lead agency staff will turn a blind eye to compliance issues. Do not be complacent; take the time to closely scrutinize your administrative documents against site conditions. If potential compliance issues are identified, make sure that they are adequately addressed. Substantial (and unnecessary) costs can result once the lead agency and OMR become involved.
Check below to see where LART is going, where they have been, and what you can do to prepare before a visit. |
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Upcoming LART Visits:
- Colusa County -- July 2011
- Sierra County -- July 2011
- Bakersfield County -- August 2011
- City of Taft -- August 2011
- Kern County -- August 2011
- Humboldt County -- October 2011
Past LART Visits:
- Del Norte County
- Madera County
- Mariposa County
- Mendocino County
- San Benito County
- San Diego County
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Things to Watch Out For:
- Make sure your Financial Assurance is update annually.
- Idle mine? - If operations have slipped below 90% of the previous maximum, you must submit an Interim Management Plan [IMP] within 90 days of reporting this. If you do not submit the IMP within this period, OMR could determine that the site is abandoned and demand that reclamation be commenced.
- Mining disturbance extends beyond the reclamation plan limits. This requires a reclamation plan amendment. If this disturbance exceeds 10% of the reclamation plan area, it will be necessary to complete a full amendment of the reclamation plan, which may result in compliance with current reclamation standards.
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What You Can Do Before and After LART Visits You:
- Check your files to make sure they are complete
- Check your lead agency files to make sure they are complete
- Be in compliance with Conditions of Approval
- Be in compliance with your Reclamation Plan
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How EnviroMINE Can Help:
If you have questions related to SMARA compliance, please call us. We have substantial experience with SMARA compliance issues and have recent experience with compliance issues that have been identified during a LART review. Call us at 619-284-8515 with questions or with your recent experience with compliance issues related to LART.
For additional information about us please visit: www.EnviroMINEinc.com.
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