IN AUGUST, REGION VII BEGAN A REFERRAL FOR COOPER LAND SITES IN MISSOURI(?). UPON THE RESULT OF A 308, THEY FOUND THAT THERE WERE VIOLATIONS ALSO NOTED IN WV SITES. THEY ASKED US TO JOIN THEM IN THE REFERRAL. WE FOUND THROUGH THE RECORDS THAT THERE WERE NUMEROUS INSPECTION REPORTS MISSING. WE CALCULATED THAT THERE WOULD BE $115,835 IN PENALTIES (BOTTOM LINE). WE SENT THIS REFERRAL TO DOJ ON DECEMBER 23, 2008. SINCE THEN, REGION VI HAS ALSO JOINED THE REFERRAL. COOPER LAND DEVELOPER HAVE SITES IN WV. THESE SITES HAVE FAILED TO SUBMIT INSPECTION REPORTS FROM 2001 TO 2006 (JUNE) AND VARIOUS MONTHS IN LATER PART OF 2006 AND 2007.