ML22084A027

3-24-22 Kanner Letter to Court (DC Cir.)(Case No. 21-1048)(Consolidated)

ML22084A027
Person / Time
Site:	HI-STORE, Consolidated Interim Storage Facility
Issue date:	03/24/2022
From:	Kanner A Fasken Land & Minerals, Ltd, Kanner & Whiteley, Permian Basin Land and Royalty Owners
To:	Langer M NRC/OGC, US Federal Judiciary, Court of Appeals, for the District of Columbia Circuit
References
1940356, 21-1048
Download: ML22084A027 (2)

Text

USCA Case #21-1048 Document #1940356 Filed: 03/24/2022 Page 1 of 2 701 Camp Street New Orleans, Louisiana 70130 (504) 524-5777 Fax (504) 524-5763 March 24, 2022 Mark Langer, Clerk U.S. Court of Appeals for the D.C. Circuit 33 Constitution Avenue N.W.

Washington, D.C. 20001 RE: Dont Waste Michigan, et al. v. U.S. Nuclear Regulatory Commission, No. 21-1048 (consolidated)

Filing of Corrected Opening Brief for Petitioners Fasken Land and Minerals, Ltd.

and Permian Basin Land and Royalty Owners (No. 21-1179)

Dear Mr. Langer:

Pursuant to the Clerks Notice of Uncommon Acronyms received on March 21, 2022, Petitioners Fasken Land and Minerals, Ltd. and Permian Basin Land and Royalty Owners submit the enclosed Corrected Opening Brief in the above-captioned matter.

The following acronyms were removed and replaced in the Corrected Opening Brief: AEA, ASLB, CISF, DEIS, EIS, ER, ISFSI, MRS, NWPA, PBLRO, RAI, and SNF.

Because the removal of acronyms impacted the word count, additional changes were made to the brief in order to comply with the applicable word limit. The changes made include the following:

• The Statutes and Regulations sentence was shortened;

• Footnote 2 was shortened;

• The final paragraph of the Statement of the Case § A was deleted;

• The first sentence of the first paragraph of Argument § II(A) was shortened;

• Footnote 4 was shortened;

• The first sentence of the fourth paragraph of Argument § III was shortened; and

• The last sentence of the final paragraph of Argument § III was deleted and replaced with the final sentence of the preceding paragraph.

USCA Case #21-1048 Document #1940356 Filed: 03/24/2022 Page 2 of 2 Finally, we made corresponding changes to the Table of Contents, Glossary, and Certificate of Compliance. No other substantive changes were made in the Corrected Opening Brief.

Sincerely, KANNER & WHITELEY, L.L.C.

By: _/s/ Allan Kanner____________

Allan Kanner Counsel for Petitioners cc: ECF Service List 2