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Ms. Pat Nelson, CDOH <br />September 12, 1991- page 2 <br />Additional discussion pertaining to the exclusion of access roads separate from a facilities' <br />industrial activities can be found on page 48065 of the final stormwater regulation. <br />The federal rules and regulations governing stormwater permits is specific in excluding <br />roads outride of active facilities. Trapper encourages the state to not adopt more stringent <br />requirements for stormwater permitting than those already imposed by the federal gov- <br />ernment. The future burden for the state to oversee the proposed federal regulation is <br />significant without additional requirements that would make the program totally <br />unmanageable. <br />For purposes of future stormwater permitting requirements, Trapper will assume access <br />roads not associated with the active mining facility are exempt from stormwater permitting <br />and/or monitoring requirements. If this is not the case, please contact me. <br />Sincere~ly,/~, <br />William Agnew <br />Sr. Environmental Engineer <br />WA~jsb <br />~SEPT12~ <br />c ].M. M ern <br />Davi er CMLRD <br />Dave Cole, CMA <br />Raissa Kirk, AMC <br />file <br />