Complaintu vi 4 1 / V y iUn lu. D0 4 V 0 -140 0 1 V 4 AY C;AYIIUL hhLENA
02/12/1991 22:51 UuuUuu
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JACK R. WHOLSKE
AtloznCy at Law P.C.
234 East Pinc Street
P.O, Box 7458
c'hissoula, Mcmtana 59807
Telephone: (406) 721-6986
Allorncy for the Plaintis
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Cawe No.
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DEFENDANTS.
I, INTRODUCTION
This utter 4hses out of We failure of the Department of jNutural Resources and
Couservadon (the astmcnt) and the Montana Board of Land Commissioners (the Hoard) to
comply %I;h tl,e Montaua 1Envzonmcntal Polity Act (MOPA) aikar establishing a plan to develop
a wction of state school mist land near ,Kalispell. In 1998, the Dvpamnent began preparation of
a master development plea (denoted she Nei&bborhood Plan) that provides for commamial
establishments, industrial uses, rM-dcntinl development, profcssional officee and rocreationsl
UL i U o� r.a.r tua i ad e,ua ar CAwi1OL HELENA HT
22'5, aa@00R2? ?Z oaccc�
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uses for the entire s tiQn of land. The De?wtnieait and the board committcd to preparing a
z NrEPA, analysis on the entire proposed development at a public meeting of the Board on
3 September 20, 1999. :Now the Deparartent hAs reneged on that cotnmitrneot, and intends to
e prepare MEPA +maJysas only as individual portions of the development are leased.
5 The Department's picccrneal approach violat: s MEPA, Comprebensive envirotimcnial
6 rcvi:w is required on the entire proposed development. The Departmenem Neigborhood Plans is
sct forth witty ample specificity to allow for such ate ysis, The =viro=ental impacts of
e commercial and residetatial development of land previously devoted to agricultural aac, direct,
9 indirect and cwnulntave, may be significant; rite change in use from icu)tural to comrrbmial
101 snd residential for Section 36 will Weci t1aIIMc, noiae and air pollation, open space, and
ii cor tmarcial and residential growth patterns throughow the greater Kalispelt area. The
12 development of ticir, 36 is likely to have sipuf1cant social and economic couyequencm for the
13 greater spcli area. Those consegLC.nCCs had yet to be analyzed and disclosed to the public
14 before the prUject was apFnaved in its present form. In boll, the Departmeric hu not
5_ considered a.ltcrttatives to the 14eighborbood Plan. Viable alterrativc uses ,for Section 36 exist
i6 and mL st be aaalyaed through A!MEPA now, bafoze irreversible commianMta Of land arp made by
i z leasing individual tracts, The Depamnent and the Board must be helm to thair cotnrrdtment to
is comply with , A on the entire Section before leasing individual tracts. Until the Department
19 and the Board comply with the law, development of the land must be enjoined_
2 0 11, JURISDICTION, PARTIES AND VENUE
�2 1, Jtu-�sdiotivn i� hosed on tha Montart:d Declaratory Islj�utctjon Act, 278-I01, Mancini
1r..junction Statute$, 27 1�-101, and the Montana Environmental Policy Act 75-1-101 er seq.,
<3 M.C,A. (1,999), Venue is proper in this distitct because the defendants area state agency and
24 mate board respectively, both located in Helena, Montana.
. 5 z- Plaictiff Monatarna Envirenrnentaj lnformat au Center Inc. is a Montana non-profit
26 public bcmcfit corporation pursuant to 35-2-101, et. seq , with over 4,000 members nation-wide,
2' and at all timea pcTtinent hcrtto has had its principal office in Lawis and Clark County, Motstana.
25 -�-
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i�£ i0p : 3:: ti 1 FEERS + -
i Plaintiff 062ens for a Better Flathead is a idlontana non-profit corporation founded in 1992.
2 The organization baa over 1,000 r er ers and is dedicated to ptornoting sustainable
3 develerpment and eaocouilc diversity through eompmher>,sive, citizen -drivers plannkg and to
n protecting the ecological ar)d cultural values of the Flatbeect Valley. This actiaa is broughi on
5 each Plaintiff orgasu2anons' own behalf and on behalf of its members. Members of both
6 orgaaizadoris reside in the greater K"speil area, including the area affected by the proposed
7 action. Mcmb&T-4 Ww live and, worlt it1 the gm3tez Kali ll area and use and enjoy the area
because of .its acAhctic qualities and ufeseyle oFpQrtim1tie3 and have an 'interen in pr rsrvictg
9 them. Plaintifis and their rneznbers are actively %avolved in land -use pllmmg lmues in the
2.0 gmater "spell area and througtsout the state, Plaintiffs and their members are actively
I a involved is isaue8 pWain r g to state scb.00l trust lands. plaintiffs and their members are thus
12 &ectly and adversely affected by the proposed cation of the Dcparrmeat, and will sustain actual
13 injury if the ptoposcd action ;s cat7led font without adequatt~ envt.rorttzrenWl review and
14 disclosure The Plaintiffs and their members nave a further interest is participating jn
�> governmental decisions, in dlsscmina'ung rel.avant information, about those decisions to the
15 ,ge.nera: public and in insuring that all laws and procedures are cotsiplied with, 1-1hose interests
17 I arc directly and adversely affected by the fai'1► ms of the Defendants as alleged herein.
i a I 3- Dofmidex Montana Depar=icnt ol* Natural Resources and Coriservatio:s (tote
i
19 Department). formerly the Deparrmem of State Lands is the state agency charged with the
2 responstbiliry for swing school trust lands held in trust by the State of MoatwA under the
21 general direz'tion of the Board of Land Commissioners. The Deportment is respo=ible for
z2 managing the state lands at issue in this lawsuit and for MEPA compliance For all state land
� ;� aGCiyZrtGB.
2,1 a. Defendant Montana. Board of Land Commissioners (the Board) is a BoLrd
25 composed of the Governor, Anomey Quacrtal, Scclrctary of State, State Auditor, and
26 Sup=ntertdesnt of Public Instruction. The Board hus general authority for the managetrient of
,27 state lands and approves all leases and other uses of state lands, including those that pertain to the
26 - 3 -
?2r' 2/1991, 22: 51
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1 sate land at issue in this lavUSU t,
III. GENERAL ALLEGATIONS
3 5 The State of Montane owns app;oxirnately 5-2 million acres of laud granted by
a the fademl governmet-, al the tune of statehood. These lands, referred to as the state school trust
s lands. am to be managed "in v%st for the support of education an4 for the artainment of other
5 Worthy ebjccts helpful to the well being of the people of tius state." § 77-1-202; M.C.A. (1999).
7 In additiot4 s,41a lands roust be inanaged for the " b gbest anal toast use" and rnuA be developed in
a such a fashion, that bi=fits the economy of the local ;ortnunity as well as the suile us a whole.
u 77-1-601 M.C.A. (1999).
10 6. Artiong the state lands managed by the Depa=ent is Section 36 locat;c d in'ibw-riship
it 29 N. Range 22 West, Flathead County, Montarta (hurw&er referred to as Section 36). This
is switori of state trust lands is located an the north, edge of the city of Kalispell. It is boundasied
13 on the Gast by US, Kighway 93, the major acmh/south arterial througb Kalispell and flathead
1.9 Couwy, on the south by FourMile drive, ob tkc west by S611watcc Road; and on the north by
15 West Reserve Drive. Mans for a major future potential ultrial, the isprll by-pass, indicate
16 the by-pass may crass ponions of Section 36,
1-7 T Section 36, with the exccp6Qn of a portion thal is cwycntly Icased for an athletic
le field, aril a small portion also usC for a ,Oep&=cw office, is currently used for agricul1=1
19 purposes. 'This land is op= space and is not currently the subject of any commcrcial or
20 residwial development,
2 8. In the spring of 19977.. thq Board and tit; D.cpzmncmt entemd into a 1:a-s.: of
22 portion of Section 36 for a recreational athletic complex. The Depa=ent at that time prepared a
3 c list Environmental AeseSamernt addressing the impacts of leasing these particular acres for
z 4 apt athletic complex, No further MEPA documentation wu prepamd. The cbevUst EA
25 approycd by the Department on or about Mmb 17, 1997, constitutes the only MEiPA document
26 that the Depamnent has prepared and approved to date for SErction 36.
L % 9, In May, 1 r398, the Dapament hired a consultant to initiate a p4mning process for
2s .a.
02/12/1991 22: 5P 2?Ja��JO@ � uUUU.0
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the dcvelopmcnt of Section 36 for commercial, business and reslderttial purposes. Tkus type of
2 develop%ocnz was detenniried to be appropriate bmcause Kalispell had grown substantially over
3 the last decade, and Section 36 was Largely surrounded by urDawsuburbazt development. As pact
4, of that process several public rnesrings were held in Kalispell during the sirrarner and fall of
1993.
10. to behalf of the -err, on February 8, 1999, Montana .Plaszrung Consulr ,rs
oC KAIispell. Montam completed a docummit enr,.tic:d'T)NRC Neighborhood Plan S=lion 36
a Kalispell, Manuma as a proposed amendment to the KO!ipell City County Master Plata", Ttiis
3 document is referred to as the "Neighborhood plan" in this cotnpla-int, The plaza was presccatcd
10 on April 20, 1999,
11 11. The IScighborhood Plan sets out thc'range of pertnissible u= for 5cctiori 36, 7 he
12 Ncighboftod Plait rmognizcs the need for a "land uBc plan for the property." Tbe Neighborhood
1.3 PI= recognizes that the type of devaloptnen.i allowed for Suction 36 will affect pvwth and
14 transportauon to the g7ratcr Kalispell area
15 12. The Nci$hborhood Plait cstabliabed a number of specific parameters that control
16 aopd dictate appropriate cypcs of development on tlLe entire sections. The purpose of the
17 Neighborhood Plan was to develop a pla.ti, for a corra,patible crux of land uses within section 36
a ' azd with that of the entire sae -rounding area, and, to idenrify an integrated internal Uanspertadon
' system to link the land use pods and rr iAinuzz appr6aclus onto pubEio roads. In mddiTtdn, the
20 Neigbbarhood Plait also stated that the entire land use plan for Section 36 i� gtridied by these
21 Neig):i1 rhood r.::als az--' lie Aolicim of the four Dirt',,; t ?and, tt6e pods.
22 13. In the Neighborhood Plan. the Dqxrtinerit outlined foua different zanies of
23 development within Section 36 they it labeled lend use; "pads". The four pods are? 1. Maxcd
2 t Commercial (to provide eor=r-zGial uses at an urb4tt "c derisity); I Mixed prof4*3ional (to
25 develop ofTice orientated commercial at a "suburban" densiry), 3. Mixed residential (residential
26 aid ou= compatible uses): 4. Sports field (athletic Meld complex), Of the four pod$, number a
2" is the only one that has been developed to date. For mh pod the magc of potential rases and
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i development paramatm at'e explicitly specified.tn the Neighborhood Plan.
2 14, to addidon, the Neighborhood Plan provides for aderall implementation with a sat
3 j of policies that apply to the entire plan. The Neighborbood Pl= included a map which alearty
4 defined the permissible uses for all of Section 36, The map wag attachec to the Neighborhood
5 FUn and ixtcorporated by : eference therein. The Neipborhood Flan does not present or analyze
6 alternative taa d uses or sc-narios for development of Soctiwtt 36, nor does It analyze the
7 coosaqueftces cf taking no act,o❑ with respect to Section 36.
R 15. At the September 20, 1999, meeurtg of the Board, the Neighborhood Plan and the
9 d$vetopiment of Section 36 were discussed as an agenda item. The Depa=eW reQucsted thr-
a Board's approya.1 to proceed with the adoption of local zoning ot^dinance and development of a
1 i Memoragdurn of Uoderscacding (MOU) with Flathead County and the city of Kalispell with
1 respect to the development of Section 36
i 3 16. At that same meetir1g, Clive Rooney, an eMployee ,and representative of the
14 Depargmemt, stealer] or. the record that "NaPA re uiremeors will be completed FjW as xn
! 5 umbrella doeament to the entire plan and then specific to any staXa action.'* At that s me mesttng
- Governor Raeicot asked if the Depa"nent intends to have full scale NEPA analysis of the ent.v'e
17 dJeveloptnezL not just on a lease by lease basis bcfnre it proceeds. In respoow to that question.
i a Mr. Rooney said "it is the Depamaent's lntcn6on to do NUPA analysis on the entire of the
19 project wlucb will be condt~tcted before the MOU signed." Mr. Rooney further stated that cbe
20 plant is to "go forward with the it immon that tins is the plan fox the section and analyze those
2-1 imp3zts.''
2: IT At that same meeting, Gov,.ma; Raeicot evade a motion to direct the Department
23 with the preparation and drafting of a MOU that lays out a broad framework to address the issues
24 of a master pi=, zoning. sub-divistor, review, MEPA and the simultaneous dispensing of any
25 fwtber movcmerit ttncil such time that MOU has been appmved by the locAl govcr=cratg. The
26 Board approved the motion unararnously. .
21 t B On or about April 19, 2OW, [he Department, Flathead County and the City of
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ve 17 : 19 CrtNEL_ -FtEKS
Kalia`pcll entered into a MOB rcgardXag the developmer_t of Scctiats 36, IN MOU stlsted thal.
a the Department iaa.d prepared a neighborhood plan Which was adopted as an amevXlment to the
3 etly county masterplaz by the Board of Commigsiort;r of Flathizad County on May 20,,1999 and
4 by the c;ty of K&.liVrll on aunt 7, 1,999. The MOU further slated that the Depertment seeks to
s �, pm=t development of Section 36 in accordance with the Neighborhood Plan.
5 19, Upon Motion by Govemor Racicot, the Hoard unanimously approved the MOU
7 at its regular meeting on .May 15. 2000 At that meeting Mr. Rooney stated diax the Deep ent
a bad changed its position and would not do WPA on t;he entire project,
9 20. Ai the time of the suing anal approval of the MOU, neither the Depa=mt nor
the Board Gad prepared wy .VFPA document examining the direct, Indirect and cumutarive
,1 impacts of leasing Section 36 for,residermil, industrial and carnmarcial development as set forth
zN in the Neighborhood plan. The Dcpartnent did not exaniina alternatives to the p o,-ed
3 Nei hood Plan and the MOU, nor did the Depa mew examine a no actioo aRemative o£acit
14 ieaswg aIJ of part of Sectioa 36 for development
is 21, The decisior, made by the Department to change the use of $Getion 36 fZoux
=6 agnculhu-al to leased residenrial and commcrc.al development, followed by the arattQn and
17 approval of the NcWbbQrhood Plan titer clearly specifies the rase of permitted acri%ides within
is various pis of Sect: oA 36, and then the sipmg of a M=orandum of Uadcrsu iriding between
19 the Dup ent_ FlaCounty and city of laligcll, agreeing to odriain terms and conditions
20 required by the city of K,tilispell and l:latheta4 County for the development of Section 36, together
i constitute state action with;. Lbit meaning of the Montafia Bnvironmenta.l Policy Act and
162 i,rztplemcuting regulations,
23 22. The development of Section 36 as defeated by the Neigbborbood Phut will had?
24 en%ironmental and soclo-ecortortuc impacts. Those consequences ineludt, but ere not limited to,
a S the following' changes in land use, changes in development and transportation pact M5 in areas
205 adjaccrA to ani surrounding Suction 36, growth.inducing i3npac.ts in the grcator Y.413spoll area,
2- increa,Qes in noise and air pollution, economic and social impacts to other portions of Kalispell
2/12/1y91
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i zrd Flathead County, i)cludizg the downtown business d stria of Kalispell in terrns of
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z de'-elopment and existing businesses, impacts t.e wildlife that use the land, loss of open space,
3 I and offer direct or uWirect and cumulative impacts.
4 ' 23, Despite ale representation. by the sand Board and the Govcrzzor of Montana that a
s ' MEPA review would be conducted on tho entire Section 36, no such review under MEPA has
U been c.arrducw4. The Depa=cat nerd the Board do not intend to conduct a NMPA review of the
7 entire dcvelopmenl fcr Section 36.
24. The Department and the Board have now repMented that they wilt prepare
IbiEPA, ravicw only on individual lease develop°uents at the rime the individual leases are
o proposed. The Deparimuni and the Board refuse to carry fpdh the cornmitmcnt rude by
1 merribeTs of the Board to prepare jui appropinate M.EPA document addressing the impacts of
12 devclopLig Section 36 as set forth in the Neighborhoodplatq.
13 25. On June 7,200 the DWar=ent relund a docurnmmt cmitled "fort rnercia) and
.a Industrial Development OppQmxriitius." The document solicits proposals fo: leasing 60 acres
15 within the Mixed Corntuercial POD of the approved 'Neig,hlacaxhood Plan for Section 36. The
z6 doCutnCnt eels specific requircmcnts for the appkations wW sets deadlines ,for submitting
17 proposals.
L6 26. Plaintiffs have no oomplete remedy at lave. If the enrVmceeds with
.13 leasing without preparmdo.n of an appropriate:viRPA docwnent addressing the overall impacts of
20 developing Seudan 36 as allcged hvzzin,'Plaintiffs a*e entitled to preliminary and/or permanent
21 miuncttvc relief t:,ndzr 27-1c3-101 ct IAiL for the violations and ha.m alleged herein.
22 C®'Ci:adT ONE • MEPA - FAILURE TO PRFPARE EIS
23 2;. Plaintiffs reallcge all previous paragraphs as if set forth in full,
z; 2S. The Montana Envirorunental Policy .act (IPA) requires Chat state agencies
5 prepare a "d- tWltld statemcnv (known as an Fxviro=entsl )mpact Statement or ETS) fnr actions
26 tbw significantly affect ibe human environment, 75-1-201 KC -A. (1991). MEPA i.ntpirments
and s4pporis the constirutional provision for maintenEmce of a clean anal hemlthful environrnetlt,
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1 Article 1X, Section 1, Mont. Const, 1272),
2 29. in its detailed szatemtn,t, the state agency must address:
3 (A) the envuopxneilta7 "pa.ets of the proposed actiort;
($) adverse affects that cannot be avoided;
A
5 (C) 4wrnativcs to the proposed pelion;
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(D) the rclacioansh,tp between local short term uses and tho maintertarice and
cnliancemiw of the long -tram pt"oductivit'y; and
(E) i,-mVCraiblc corm - fitments of%escurccs if the project is implemented.
M.C.A.75-t-201 (1)(b)(iii)(1999),
30. )n addition, the Deparement has adopted regulaticTis that dictate how the Deportment
will comply -idi MEPA. 36,2.521 ARM. These regulations are binding upon the Dopaa'crerit
31. The development and approval of the Neighborhood Plan and the development and
j'ppruvai of the Memorandum of U tandut,g covering all of Section 36 by the Defemdants
consotutcs state acnon within The =aning of MEPA and applicable regulations, It arnsticutee a
project, program or activiry undetiakett by the agency. 36.2,522 (1), Such state action is not
categorically exempt from tv EFA. The Disfend'dnts theml'are must przpare an Enwimnmcrital
Assessment or Envirotuusrlt&l Impact Sudeffient that addrems the .siplif7cance of the
eovironu==W1 apd wcio-economic cvn strew of such action. A,R.M. 36,2.524
32. The tsnt's actions in developing and approving the Neighborhood Pram
aad =tering into :he Memorandum of Underst=dirig that commit to the development of section
36 as spacified LD the Neigbbvrhood Plan will have environmental and wcio-econortiac
cQDscqueoces as defined by 1► EPA"iis implcrmenting reguiadons and alleged herein. These
coo_sequcn,;" can be discerned and, analyzed based on °.Ito iiaformetiun contaimod in the
Nej?,bborhvud Plan and M,Ot: and the location of section 36. ctz-=tly undeveloped, given
current land -use paacros, transportation systerns and resid=ial and eommarcial devetoornent in
the gxeater Kalispell area,
02/12/`� 91 22: 5-1 ai� LI, �Jee0OCuuuuuu
2 3T To date the Defendants raise neither prepared an Envtto»mental Assess,rner,t ror
2 an Env uonzuental lmpact Statement addresgir,g ncc eavttcsnmental =pats of Implementing the
3 Neighborhnod Plan and'MOU on Section 36. The Dcparm= has acted unlawfully, vmhout
® observing procedures required by law, to an arbitrary and caPr-cious manner, all iz riolation of
s MEPA and this Depw-une is implementing regulations,
34. Nairitiffs reallegc all previous pa;agrapbs ss if set fonh in (tall.
a 35. MEPA requires Vial the Depa=iW con§idcr alta=tivos to the proposed action.
y 75-1-201 M.C.,A. (1999). The Dapwtment's MEYA regulations also requite that the
.0 Dcp&nYn=t consider alternatives during the MEFA praccss. An alternative is defined as an
alternative approach that would app'rdciahly accomplish the mme objectives. For aget2cy
z inietated acrsons, an alternative under IVEPA includes a different program or series of actions that
13 -ovld accomplish other objectives or a difficrerit use of moureGs A.R M. 36.2, 522 (2) (a).
14, 36. The Department did not consider any alternatives to the Ncighboribood Plan rrr the
is MOU prior to its adoption in an appropriate NMPA document. Reasornablc eltermatives inccludc.
1 but am not limited to, different types ark mitres of development wish Section 36 overall, diffe.-cm
1 types and mixea of devcloprrent within the four podA of developmem, including teaviog Section
18 36 For open space, or some other lesser progr= for development and designarir3g space to
15 promote inter -governmental cooperation for sound economic development of a busiaess park and
20 teGbnplogy center with potential joint ceoperation between the city, county, community collcee
L. and the D.-paxrmtmt.
aL 37. MIPA mgk4ires that the Department consider a "Do ration" alternative. A.R.M.
23 36.2.522 (2) (a) (iii). At the tune the Deparoment prepumd the Noighbot+icod Plan and entered
2 1� inro the MOU it bad not considered a no motion alternative such, as maintaining Ow land as
2s cu+ -maly lea.6;cd for a�cui❑aral u.c.
2G 38, The Dopa=cnt is also required to consider the relationship botween local short-
2 term uses and Cne maintenance and enhano=enl uflong-eat peodu&Mty. The Depw-tsrtent did
23 10.
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i. not conaidea- rzason&e altmaw cs that u;olu;ie, bt}t are not Ji,-Iited to Ion ,and shot° tetra
2 cca)ivinas invostmcnt strategies, and cooperative intes•goverrnmental actions co promote
3 ecaricm,; develupment as well as the sus liry of poiMhal development see aTios.
a 1 39. The failure of the Departznct,t axrd the Board to evaluate atttmauves to the
5 Ncighbostood Plan and to consider a no action altertiativ'e through a proper MFPA document is
6 walawful, does not a to required prpcedures, and is arbitrary and capexioUs in violation of
7 NCEP A
eWUEREFORE PL . 'TIFF PRAYS FOR RELIEF AS FOLLOWS:
y 1. For a declaratory jwigmew detlari,ag that the Defendants have failed to carnpt-
i o with liIEP'A and its impictnoitting regulations by faihng to prepare in CIS or other appropriate
1 i N�YA dwwnvat for the zcasons set forth hcreui;
z z. For an cries remanding the matter to the Department and the Soud for
3 prepazaiioa of an appropriate MZPA documcnt, addressing the rnarim at issue bemin and
24 allowing for public panicipation in that docwnew;
3. For an ordtr perrnarient;y eajouning the Defondanu from prccetrding with rbe
16 awwdirag of a lease or otherwise allowing deyelopment on Section 36 or implementation of the
i 7 Ncighbothood ,Plan until, suet tune as the L)epar=ent prepares an eavirQnmsntal review
I
18 docum,cat that complies with the Montana Environmental Policy Act and its regulations.
'_ 9 4, For tests, atwrcey fens and any and all ottser such,10lict as the court demq )ust
20 and proper.
z : DATED Uujk duy o . 2000.
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C K T'UVOLSKE
za ti Cy at Law F,C ,
i A 4rricy For the Plaintiffk
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2'%
DEPART ✓TENT OF NATURAL RES URCES
AND CONSERVATION
MARC RACICOT, GOVERNOR 1625 ELEVENTH AVENUE
- STATE OF MONTANA
DIRECTOR'S OFFICE (406) 444-2074
TELEFAX NUMBER (406) 444-2684
July 7, 2000
Mr. Chris Kukulski
Kalispell City Manager
P.O. Box 1997
Kalispell, MT 59903-1997
RE: MEIC, et al. v. DNRC, and State Bd. of Land Commissioners
Cause No. ADV-2000-396
Mont. 1" Judie. Distr. Ct., Lewis and Clark County
Dear Mr. Kukulski:
PO BOX 201601
HELENA, MONTANA 59620-1601
Enclosed is a copy of the recent litigation which was served upon the state of
Montana. Mr. David Greer in the Department's local Kalispell office will visit with you
and your legal staff in the near future to determine whether the city of Kalispell would
care to intervene in this litigation as an interested party. If you have questions or
concerns about this litigation, please feel free to contact me at (406) 444-3776.
Sincerely,
Tommy H. Butler
Trust Lands Attorney