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2010-02-01_GENERAL DOCUMENTS - C1981018
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2010-02-01_GENERAL DOCUMENTS - C1981018
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Last modified
8/24/2016 3:59:09 PM
Creation date
2/2/2010 3:06:17 PM
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Template:
DRMS Permit Index
Permit No
C1981018
IBM Index Class Name
GENERAL DOCUMENTS
Doc Date
2/1/2010
Doc Name
Response to Letter on Perimeter Markers
From
Blue Mountain Energy
To
DRMS
Permit Index Doc Type
General Correspondence
Email Name
JDM
Media Type
D
Archive
No
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until final bond release negates the concern with various interpretations of 30 CFR Section <br />817.11(b) and CCR 407-2 4.02.4. <br />There may be some concern that GPS perimeter markers do not meet the wording found in the <br />regulations. First, GPS technology was only in the concept stage when these regulations were <br />written. Second, the use of GPS perimeter markers as we propose fully meet the intent of the <br />regulations. Furthermore, OSM has shown flexibility within the framework in addressing the <br />perimeter marker requirements. In Alaska, OSM approved regulations allowing for the reduction <br />or elimination of the marker requirements where the postings would serve no useful purpose. <br />With the availability and use of a GPS perimeter marker system perimeter marker `posts' would <br />not serve a useful purpose except as proposed. Therefore, what would constitute "...appropriate <br />markers..." as defined by Section 701(17) of SMCRA is satisfied. <br />To help come to a consensus, we would like to meet with you to discuss this issue in the near <br />future. <br />If you have any further questions please contact me at 970-675-4322. <br />Sincerely, <br />Scott Wanstedt <br />Environmental Engineer <br />swanstedt@deserado.com <br />enc: <br />cc: Jeff Dubbert <br />Jason Musick
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