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<br />November 6, 1991 <br />Page 9 <br /> <br />anticipated production rate and implementation of the Fugitive <br />Particulate Control Plan, SMC believes that the fugitive emissions <br />are substantially reduced when compared to the uncontrolled <br />emissions generated by the previous operations under the permit. <br />In a further voluntary effort to improve its facilities, SMC has <br />paved an additional 700 foot segment of the road. The use <br />contemplated by the technical revision is not a major change in <br />operations, will result in substantially lower fugitive emissions <br />than contemplated in the existing permit and will have no effect on <br />the reclamation plan for the facility. Under any interpretation of <br />the regulatory definition such a revision is properly characterized <br />as a technical revision. <br />The Objectors further allege that SMC "has requested a permit <br />revision to enlarge the storage area" at the site and imply that <br />SMC's actions in this regard are an effort to circumvent CMLRB <br />review of the proposal. These allegations are totally false. SMC <br />has been working with local land use officials in Gunnison County <br />on a proposal to relocate the current stockpile to an alternative <br />location which is situated at a further distance from the town of <br />Somerset. This undertaking represents yet another effort on the <br />part of SMC to implement measures which could minimize potential <br />offsite fugitive emissions. SMC has received a positive initial <br />response to the proposal at the local level, and therefore intends <br />to submit the appropriate application materials to the MLRD for a <br />