January 31, 2011
The total dollar value of proposed penalties assessed by MSHA under the Act for which disclosure is required by Section 1503 (a) of should be limited to those penalties proposed for type of violations required to be disclosed under Section 1503 (a) i.e, Serious and Substantial ("SS")violations 104b (withdrawal) orders, 104d (unwarrantable) orders 110b (2) (flagrant) violations and 107a (imminent danger) orders. As written, the rules required diclosing all proposed assessments for all 104a citations whether or not SS. This goes beyond the intent of Dodd-Frank and any purported disclosure purpose of Dodd-Frank and increases the burden on mine operators unneccesarily.