January 6th, 2010
Ms. Shari Wilson
Secretary
Maryland Department of Environment
1800 Washington Blvd.
Baltimore, Maryland 21230
Dear Secretary Wilson:
This is a request under the Maryland Public Information Act, State Government Article
§§10-611 to 628. I am making this request on behalf of Waterkeeper Alliance, Inc. In this capacity, I wish to inspect all records in your custody and/or control pertaining to the following:
(A) All documents in MDE’s possession (including, but not limited to, Nutrient Management Plans or Conservation Plans, Notices of Intent to seek coverage under the General Discharge Permit for Animal Feeding Operations, any issued State or Federal Discharge permits, inspection reports, enforcement actions, monitoring reports, evaluations and/or assessments, memoranda, water sample results, solid waste results, photographs, and videos) relating to Alan and Kristin Hudson Farm, located at 9101 Logtown Rd., in Berlin, MD, for the last ten years. This should include all correspondence, including electronic communications, memoranda, consultations, discussions, reports, notes, analysis, studies, photographs and electronic media, and transcripts.
(B) All documents, including correspondence between MDE, EPA Region 3 and EPA Headquarters or any two of these parties concerning Alan and Kristin Hudson Farm for the last five years. This should include all correspondence, including electronic communications, memoranda, consultations, discussions, reports, notes, analysis, studies, photographs and electronic media, and transcripts.
(C) All documents, including invoices, relating to the removal and transportation of any solid waste or any other type of material from Alan and Kristin Hudson Farm. This should include all correspondence, including electronic communications, memoranda, consultations, discussions, reports, notes, analysis, studies, photographs and electronic media, and transcripts.
(D) All documents, including correspondence between MDE and Perdue, Inc. concerning Alan and Kristin Hudson Farm for the last five years. This should include all correspondence, including electronic communications, memoranda, consultations, discussions, reports, notes, analysis, studies, photographs and electronic media, and transcripts.
(E) All documents pertaining to the use of sewage sludge, biosolids or other byproducts of waste water treatment systems on farms on the Eastern Shore of Maryland. This should include all correspondence, including electronic communications, memoranda, consultations, discussions, reports, notes, analysis, studies, photographs and electronic media, and transcripts.
If all or any part of this request is denied, I request that I be provided with a written statement of the grounds for the denial. If you determine that some portions of the requested records are exempt from disclosure, please provide me with the portions that can be disclosed.
Please advise me as to the cost, if any, for obtaining a copy of the records and the total cost, if any, for all the records described above. If you have adopted a fee schedule for obtaining copies of records and other rules or regulations implementing the Act, please send me a copy. As a nonprofit public interest organization with limited resources, we are requesting a waiver of any fees related to the copying and production of these records pursuant to the relevant provisions of the Act.
I respectfully request that these documents be provided as promptly as possible, but not later than 30 days after you receive this letter, as required by COMAR § 26.01.04.07. If you have any questions regarding this request, please do not hesitate to telephone me at the number below.
Sincerely,
Liane Curtis
Staff Attorney
Waterkeeper Alliance
T. 914.674.0622, ext. 15
lcurtis@waterkeeper.org
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