The United States District Court for the Western District of Washington at Tacoma
THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT TACOMA Lighthouse Resources Inc.; Lighthouse Case No. -CV-______ Products, LLC; LHR Infrastructure, LLC; LHR Coal, LLC; and Millennium Bulk Terminals-Longview, LLC, COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF Plaintiffs, v. Jay Inslee, in his official capacity as Governor of the State of Washington; Maia Bellon, in her official capacity as Director of the Washington Department of Ecology; and Hilary S. Franz, in her official capacity as Commissioner of Public Lands, Defendants. INTRODUCTION . From the framing of the Constitution, the federal government has enjoyed supreme authority to regulate foreign and interstate commerce. . In giving the federal government this authority, the Constitution necessarily prohibits individual states from discriminating against, or unreasonably burdening the free flow of, such commerce. . Plaintiff Lighthouse Resources Inc. and its subsidiaries are filing this action because the Defendants are actively preventing coal mined in other states from moving in foreign and interstate commerce. 1 . In particular, the Defendants have unreasonably delayed and denied a number of permits and approvals for a port facility that would enable the export of coal to U.S. allies and trading partners in Asia. . Those Asian trading partners want the United States to help them meet their coal demands. They have specifically identified coal from the Powder River Basin in Wyoming and Montana as having ideal characteristics, including for the next generation of high efficiency, low emissions coal-fired power plants. . The United States, which possesses the largest coal reserves in the world, wants to supply coal to its Asian allies, and is aggressively pursuing a national policy that facilitates coal exports to Asia.
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