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October 8, 1993 Page 3 <br />other than transportation of coal including, but not limited to, <br />roads used for monitoring, periodic maintenance of monitoring <br />facilities, or other occasional uses." <br />Rule 4.03.3(1)(a) states that "Each person who conducts surface <br />coal mining operations shall design, construct or reconstruct, <br />utilize, and maintain light-use roads to control or minimize <br />erosion and siltation, air and water pollution, and damage to <br />public or private property". Failure to provide permitting <br />documents to the Division potentially obstructs our ability to <br />inspect and ensure compliance with the Act. Additionally, a lack <br />of designs for light use roads prohibits the Division's ability to <br />determine if erosion will be controlled or minimized. <br />The Division regards the issuance of NOV C-93-114 to be appropriate <br />'and justified. 'The Division respectfully requests that the Board <br />uphold the Division's finding. <br />007BOA.108 <br />