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In addition, the perimeter of the permit area is marked by GPS. A GPS unit is available with the <br />perimeter of the permit area marked as a track or other appropriate feature and easily identified. <br />This unit is available for the inspector's use at the place where the mine records are kept. A <br />computer file of standard GPS transfer format or other format as accepted by the Division <br />containing the permit area boundary will be provided to the Division for entry into GPS units <br />provided by the Division. This GPS permit area perimeter and GPS unit will be maintained by <br />the operator until final bond release. <br />Discussion of Plan Concepts <br />Perimeter marker posts would be installed only where they may serve a useful purpose. In areas <br />where the permit area boundary is greater than 200 feet from the edge of areas affected by <br />surface operations or facilities there is little risk of inadvertent offsite impacts occurring due to <br />the lack of marker posts. <br />The character of areas affected by surface operations or facilities at the Deserado Mine is such <br />that continued systematic expansion does not occur. As opposed to the uncertainty of locations <br />discussed in the preamble to 817.11 all proposed disturbances are surveyed in the field with a <br />GPS then verified with a highly accurate orthophoto and/or conventional survey methods. Most <br />such activities require BME to intersect with the underground mine workings at a very precise <br />location such as with ventilation shafts and nitrogen injection holes. Missing our targets by only <br />a few feet can be very costly to BME. Degas borehole locations are slightly more flexible but <br />must fall within the longwall panel, well inside the permit area boundary. <br />Provisions are made to avoid needless placement of perimeter marker posts in situations where a <br />prominent feature, such as a road or stream, separates the areas affected by surface operations or <br />facilities and the permit area boundary. The case in point is the raw water pipeline from the <br />White River to the Raw Water Lagoon. For a short stretch this surface pipeline comes within <br />200 feet of the permit area boundary. However, the portion of the permit area boundary in <br />question is across County Road 65 and in no risk of impacts due to the absence of perimeter <br />marker posts. Prominent features serve as a `do-not-cross' boundary for construction crews as <br />well as serving as an easily identifiable feature for the inspector to use when verifying proper <br />facility placement. <br />The entire permit area boundary is currently marked on a GPS. This system is very accurate, <br />easy to use by both the operator and inspector, cost effective, easy to update and maintain, and <br />provides the Division with a means to verify locations of areas affected by surface operations or <br />facilities relative to the permit area. Utilization of GPS technology avoids the needless <br />placement of highly visible markers on our public lands. In addition, removal of markers at final <br />bond release will not be an issue. Perimeter marker posts can be removed once they no longer <br />serve a useful purpose not already served by the GPS. Retaining the perimeter marked by GPS