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technology already comes into play to identify locations of future disturbances and to verify <br />proper placement of other markers on site. The one drawback to relying solely on GPS to satisfy <br />the perimeter marker requirement is when a proposed disturbance is in close proximity to the <br />permit area boundary. In such cases, physical markers may be advisable to provide a visual <br />boundary for equipment operators during construction. <br />A certain degree of latitude is allowed in the regulations as to the proper means of addressing <br />perimeter markers. OSM's acceptance of Alaska's regulations concerning perimeter markers is <br />an example. Alaska's regulations 11 AAC 90.301(b) states: "(b) The commissioner will, in his <br />or her discretion, reduce sign and marker requirements where the areas are inaccessible and <br />posting would serve no useful purpose." 11AAC 90.301(d) specifically addressing perimeter <br />markers further states: "(d) The perimeter of all areas affected by surface operations or_facilities <br />must be clearly marked before operations begin, except as provided in (b) of this section. " <br />This degree of latitude is supported in SMCRA's definition of "permit area" where it specifies <br />that "appropriate" markers be used. One must consider if it is "appropriate" to require marker <br />posts in areas where they serve no useful purpose. The placement and maintenance of posts <br />which serve no useful purpose would impose adverse environmental impacts without providing <br />any offsetting benefits. <br />Proposed Perimeter Marker Plan for the Deserado Mine <br />Perimeter marker posts will consist of steel posts with approximately the top foot marked red or <br />orange or posts fitted with a similarly marked plastic pipe. Each marker must be visible from <br />each adjacent marker. Additional markers may be warranted depending on the proximity of the <br />mine activity, character of the mine activity, and other features between the operations or <br />facilities and the permit area boundary. <br />Marker posts will be placed at points between the permit area boundary and the edge of approved <br />areas affected by surface operations or facilities where such areas: <br />• are within 200 feet of the permit area boundary, and <br />• no substantial stream, road, or similar feature substantially aids in limiting off-site <br />impacts nor provides a visual landmark for the inspector and operator between the <br />operations or facilities and the permit area boundary. <br />For the purpose of placement of perimeter marker posts "areas affected by surface operations or <br />facilities" do not include exploration holes or power lines and their associated disturbances. <br />Perimeter marker posts must be maintained until no additional activities are foreseen which <br />could conceivably lead to offsite disturbances. This will usually be when surface grading is <br />complete during reclamation. If the Division deems additional regrading necessary to meet the <br />final desired contour they may request that the markers be reinstalled prior to reinitiating <br />regrading activities.