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Hernandez, Daniel <br />From: Belka, Christine [cbelka@osmre.gov] <br />Sent: Monday, July 12, 2010 1:43 PM <br />To: Hernandez, Daniel <br />Subject: Disturbed area markers <br />Hi Dan, <br />I just wanted to touch base with you regarding your question on disturbed area markers (and the permit revision that <br />would do away with them). It seems clear to me that disturbed area markers are required to be in place before any <br />surface disturbance takes place. OSM considered the cost / burden to the operator when developing the rule. This is <br />why there are disturbed area markers rather than permit boundary markers on underground mines. Moreover, OSM <br />envisioned signs and markers staying in place until final bond release (44 FR 15137) for the purpose of facilitating <br />inspections. <br />This type of marker is intended to confine the activities of mine personnel within the areas approved for disturbance <br />and to help inspectors identify areas they should inspect. I know the Forest Service isn't a huge fan of signs and markers. <br />However, it is important to note that land owners may not negate SMCRA responsibilities i.e. if a surface owner didn't <br />want their land reclaimed, it would not relieve the operator from their responsibility to reclaim. <br />Disturbed area markers are fairly cheap compliance items in the grand scheme of coal mining. Ultimately, it will be your <br />decision. Do you believe you could achieve the purposes of the rules without employing the rules? <br />Christine Belka. <br />Environmental Protection Specialist <br />OSMRE Denver Field Division <br />1999 Broadway, Suite 3320 <br />Denver, CO 80202 <br />(303) 293-5020