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PDC Energy
Piceance Centralized Soil Treatment Facility
OLSSON
ASSOCIATES
OA Project No. 011 -2627
760 Horizon Drive, Suite 102 1 Grand Junction, CO 81506 1 TEL 970.263.7800 1 FAX 970.263.7456
O\oLSSON
ASSOCIATES
PDC Energy (PDC)
Piceance Centralized Soil Treatment Facility
Standards Narrative
Division 1 General Approval Standards for Land Use Change Permits
Article VII, § 7 -101 Compliance with Zone District Use Restrictions
The subject property is located in the Resource Lands — Gentle Slopes zone District of Garfield
County. The proposed soil treatment facility is considered a material handling use in Table 3-
503 of the Garfield County Unified Land Use Resolution (ULUR). This type of use requires a
Major Impact Review (MIR) in this zone District.
Article VII, § 7 -102 Compliance with Comprehensive Plan and Intergovernmental
Agreements
The Piceance Centralized Soil Treatment Facility generally conforms to the Garfield County
Comprehensive Plan. The existing use is not within an area governed by an intergovernmental
agreement.
Article VII, § 7 -103 Compatibility
The Piceance Centralized Soil Treatment Facility is compatible with the agricultural and
industrial (e.g. natural gas operations) uses on the subject parcel and adjacent properties. It will
not interfere with existing land uses in the surrounding area.
Article VII, § 7 -104 Sufficient Adequate, Legal, and Physical Source of Water
Potable water will not be required for workers utilizing the site during remediation of soils but
water will be delivered to the site and utilized the same day as soils are delivered and treated at
the facility. Water will be applied to soil as needed to maintain the appropriate level of moisture.
No water storage tanks are anticipated. The water will be used to facilitate the application and
maintain the viability of the microbes which are applied as part of the remediation process.
Fresh water will also be used for dust suppression.
PDC has entered into a water supply contract with the Colorado River Water Conservation
District (CRWCD) (Contract no. CW06004), under which PDC is entitled to the delivery of water.
Fresh water used for operational activities at the proposed facility may also be secured from a
760 Horizon Drive, Suite 102 TEL 970.263.7800
Grand Junction, CO 81506
FAX 970.263.7456 www.oaconsulting.com
licensed provider with demonstrated access to water supplies. Additional details specific to the
water source are provided in the supplemental materials section of this submittal.
Article VII, § 7 -105 Adequate Central Water Distribution and Wastewater Systems
This facility does not and will not require potable water source. A centralized wastewater system
will not be required by this facility. There will be no permanent structures or employees located
at the facility.
Article VII, § 7 -106 Adequate Public Utilities Supply
Public utilities will not be required for operation of the facility.
Article VII, § 7 -107 Access and Roadways
A. Access to Public Right -of -Way
Access to the facility will be via a private road. The private road will be utilized via an
existing permitted access that intersects with US Highway 6 & 24 (AKA 1 -70 Frontage
Road) approximately 3.25 miles northeast of the town of Parachute. The legal right to
use the road is shown by Non - Exclusive Mutual Access Agreement between Exxon Mobil
and Puckett Land Company /TOSCO Corporation. This agreement is an attachment to
the Surface Lease Agreement between Puckett and PDC. A new access permit
application has been submitted to the Colorado Department of Transportation (CDOT) to
address the minor increase in traffic generated by this proposed facility.
B. Safe Access
No new accesses or auxiliary lanes onto a County or State roadway will be required as
indicated in the Traffic Analysis.
C. Adequate Capacity
The proposed Piceance Centralized Soil Treatment Facility will not adversely impact
adjoining roadways due to the anticipated low operational traffic volumes. The roadway
accessing the facility will have the capacity to efficiently and safely service the traffic
generated by the use. See Traffic Analysis for further information.
Article VII, § 7 -108 No Significant Risk from Natural Hazards
A. Use of Land Subject to Natural Hazards
The existing facility is situated approximately 3.25 miles northeast of Parachute,
Colorado at an elevation of approximately 5,200 feet. The area has not been mapped
by Garfield County for slope, soil or surficial geology hazards. According to the Geologic
and Soil Hazard Report contained as an attachment to this application the overall
geologic and soil hazard at this site appears to be low. No faults or other hazards are
evident on the Geologic Map of Colorado. The proposed land use does not include any
structures or occupied buildings and would not exacerbate existing hazards.
B. Platting of Land Subject to Natural Hazards
The applicant is not requesting further subdivision or platting of the property. There are
no significant natural hazard risks at the property. There is only a minor potential for
falling rock, landslides, snow slides, mud flows, radiation, or flooding or high water
tables. The risks from these hazards are reduced since no structures or buildings are
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proposed and personnel will be on site only on an as- needed basis. There is some
potential for grassland fires, though there are no recent occurrences in the vicinity and
no evidence of fires occurring.
Division 2 General Resource Protection Standards for Land Use Change Permits
Article VII, § 7 -201 Agricultural Lands
C. No Adverse Affect to Agricultural Operations
The facility has not and will not adversely impact agricultural operations that are
conducted on the subject property or adjacent lands.
D. Domestic Animal Controls
No domestic animals will be kept at this facility. This standard is not applicable.
E. Fences
The facility has not and will not generate a potential hazard to domestic livestock or
wildlife. No open storage of hazardous material or activities attractive to animals will be
conducted on -site. The area will be fenced in order to reduce impacts to agricultural
operations within the area and protect the facility from possible livestock damage. The
fencing surrounding the facility will be constructed according to Colorado Parks and
Wildlife (CPW) requirements for wildlife protection and COGCC E &P waste facility
requirements for security. Any fencing that may be necessary will be constructed to
exclude big -game from the site without restricting access to winter range along 1 -70 on
either side of the facility. The fence surrounding the facility will be constructed of chain-
link a minimum of eight feet tall to completely exclude deer and elk.
F. Roads
An existing private access is being utilized to approach the subject parcel and proposed
location. A short access spur approximately 30 feet long and 25 feet wide will be
constructed from the existing private roadway to the facility. Maintenance of these roads
will not damage boundary fences. Additional roads will not be required. Dust control will
be utilized in accordance with PDC's Fugitive Dust Control Plan.
G. Irrigation Ditches
Implementation of the engineered drainage plan and conformance with stormwater best
management practices will assure irrigation ditches on and adjacent to the subject
property will not be impacted by the facility.
Article VII, § 7 -202 Wildlife Habitat Areas
A. Buffers
Any fencing that may be necessary will be constructed to exclude big -game from the site
without restricting access to winter range along 1 -70 on either side of the facility. The
fence surrounding the facility will be constructed of chain -link a minimum of eight feet tall
to completely exclude deer and elk.
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B. Locational Controls of Land Disturbance
Potential impacts to wildlife and suggested mitigations are detailed in the Wildlife
Assessment included in the supplemental materials accompanying this submittal. The
Wildlife Assessment concluded that the facility will not create hazardous attractions to
avian or mammalian wildlife species, block migration routes, or cause a change in
habitat use. No impacts to federally listed or locally significant plant or animals are
anticipated. Noxious weeds will be removed as applicable on site.
The primary use of the site and surrounding area is natural gas extraction /development,
industrial storage yards, and wildlife habitat. The general project area is currently
undergoing rapid natural gas development including the drilling of wells, and the
construction of pipelines, compressors, and access roads.
C. Preservation of Native Vegetation
Vegetative communities around the project area are disturbed by natural gas
development and nearby industrial development. The surrounding area near the site is
dominated by sagebrush shrublands with mixed forb /grass understory. Pinon- juniper
woodlands are widely scattered on the hillsides and ridge tops near the project area.
Pinon- juniper woodlands are dominated by Utah juniper (Juniperus osteosperma) and
occasional pinon pine (Pinus edulis). Other vegetation observed in the area includes
greasewood (Sarcobatus vermiculatus), rabbitbrush (Chrysothamnus nauseosus), and
crested wheatgrass (Agropyron cristatum) throughout the understory.
The site will be reclaimed as outlined in the Reclamation Plan included in this submittal.
Noxious weeds will be controlled as shown in the Noxious Weed Management Plan.
D. Habitat Compensation
Minimal suitable raptor habitat is available near and at the project site. Tree height and
size near the site is generally 10 ft to 15 ft tall and widely scattered. Rock outcrops near
the project area are small and typically low to the ground. Many raptors prefer to nest in
locations higher off the ground than what is available near the project site.
No birds of conservation concern were observed during at the proposed location. There
is potential for Pinyon Jays and Brewer's Sparrows to nest and forage in the sagebrush
shrublands and scattered pinon juniper trees near the project area.
The soil treatment facility site is located within mule deer and American elk overall
ranges. The site is also situated within mule deer overall winter range, and mule deer
severe winter range.
E. Domestic Animal Controls
Domestic animals will not be kept on the property. This standard is not applicable.
Wildlife Habitat Conclusions:
The Wildlife Assessment Report accompanying this submittal has concluded that the facility will
not create hazardous attractions to avian or mammalian wildlife species, block migration routes,
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or cause a change in habitat use. No impacts to federally listed or locally significant plant or
animals are anticipated. The proposed project area will affect site - specific native vegetation and
wildlife habitat adjacent to the project site. Because the area has already been disturbed, the
project will minimally affect wildlife. The project will contribute to the overall cumulative impacts
to the wildlife populations in the area that are experiencing gradual habitat loss, fragmentation,
alteration, and displacement through increased development. Therefore, the facility will have
minimal impact, if any, to the surrounding flora and fauna; the Reclamation Plan has addressed
the restoration of the site to pre - facility conditions by re- contouring and re- vegetating.
Article VII, § 7 -203 Protection of Wetlands and Waterbodies
As noted in the report prepared by WestWater Engineering, WWE biologists determined that no
wetlands or drainages showing characteristics of Waters of the U.S. (WOUS) were located
within the boundaries of the proposed soil treatment facility. There are no hydric vegetation
communities, hydric soils, or supportive hydrology at the site. Operation of the facility will not
impact wetlands or adversely affect water quality in the nearby waterways. Implementation of
the engineered Drainage Plan and stormwater Best Management Practices (BMP) will be
utilized to ensure the continued protection of water bodies from stormwater runoff during
construction and operation of the facility.
Article VII, § 7 -204 Water Quality from Pollutants
A. Compliance with State and Federal Regulations
The purpose of the facility will be to remediate hydrocarbon impacted soils and store
these soils temporarily following treatment prior to their beneficial reuse at other PDC
locations. PDC will transport impacted soils to the proposed facility on an "as needed"
basis. Operation of the facility will be dependent upon the frequency and volume that
contaminated soils are generated by PDC's ongoing natural gas production operations.
The soils that will be remediated at the proposed facility will be under the jurisdiction of
the COGCC.
After consultation with the COGCC and in order to ensure protection of water quality,
PDC will install up to three (3) ground water monitoring wells in proximity to the facility.
Laboratory test results indicate that the on -site soils have a relatively low permeability
that would limit infiltration of surface water into the ground. The results of the perc tests
indicate a higher infiltration rate than the permeability test results. If a further reduction
in the permeability in the soils is desired, the soils could be reworked.
B. Storage Near Waterbodies
No hydrocarbon liquids or associated tanks will be located on the proposed facility. The
operator will operate the facility and associated activities in order to maintain the
required buffer between the disturbed area and the natural vegetation and waterways.
No hazardous materials will be stored on the proposed facility.
C. Spill Prevention
Since no hydrocarbon liquids or associated tanks will be located on the proposed facility,
a Spill Prevention Control and Countermeasures Plan (SPCC) is not required. Any
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accidental spills or leaks from temporary mobile equipment will be cleaned up
immediately and properly disposed.
D. Machine Maintenance
No machine maintenance will be done on the proposed facility.
E. Fuel Storage Areas
No fuel will be stored on the proposed facility.
F. Waste Storage
No waste will be stored on the proposed facility. If necessary, human generated wastes
will be accommodated by portable toilets placed near the boundary of the proposed
facility.
Article VII, § 7 -205 Erosion and Sedimentation
PDC will obtain all necessary CDPHE permits required for this site. The facility has been
included in the area wide Stormwater Management Plan (SWMP) included with this submittal.
BMPs are being utilized to ensure the continued protection of water bodies from stormwater
runoff during construction and operation of the facility.
General design of the site is to prevent off -site stormwater from entering the site, while
stormwater generated within the site is self- contained. The risks associated with stormwater
run -on and run -off are mitigated by design methods and BMPs described in the Stormwater
Management Plan included in this submission. These methods are in conformance with
COGCC rules. Drainage facilities associated with the site have been designed and the
associated calculations can be found within "Drainage Report, PDC Centralized Soil Treatment
Facility, Garfield County, Colorado" prepared by Olsson Associates.
Article VII, § 7 -206 Drainage
A complete Drainage Plan that addresses standards for drainage including potential on -flows
and off -flows has been prepared for this project and accompanies this submittal. This plan is
also a component of the COGCC permitting review and approval. The plan will be engineered
to accommodate typical stormwater construction activities and addresses existing drainage
conditions both on- and off -site, per COGCC regulation for E &P waste facilities. It also
accommodates drainages associated with a 100 year, 24 hour stormwater event.
The Drainage Plan was developed and submitted by a Colorado P.E., and complies with all
County drainage requirements. Please see complete Drainage Plan included with this
submittal.
A. Site Design to Facilitate Positive Drainage
This standard requires that lots be laid out to provide positive drainage. Lots are not
proposed as part of this land use application. A grading and drainage plan has been
prepared and is included in this application. The site will not create any impacts to
existing drainage patterns.
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B. Coordination with Area Storm Drainage Pattern
This standard also addresses individual lot drainage within a residential development
and is not applicable to this use. The proposed facility will not impact natural drainage
patterns. General design of the site is to prevent off -site stormwater from entering the
site, while stormwater generated within the site is self- contained. Drainage facilities
associated with the site have been designed and the associated calculations can be
found within "Drainage Report, PDC Centralized Soil Treatment Facility, Garfield County,
Colorado" prepared by Olsson Associates.
Article VII, § 7 -207 Stormwater Run -Off
The SWMP has been included with this application and covers all applicable activities
associated with the facility's disturbance. The existing facility is not within 100 feet of a water
body and will not create greater than 10,000 feet of impervious surface.
A. Avoid Direct Discharge to Streams or Other Waterbodies
General design of the site is to prevent off -site stormwater from entering the site, while
stormwater generated within the site is self- contained.
B. Minimize Directly- Connected Impervious Areas
No impervious surface areas will be created at the proposed facility.
C. Detain and Treat Runoff
A complete Drainage Plan that addresses standards for drainage including potential on-
flows and off -flows has been prepared for this project and accompanies this submittal.
This plan is also a component of the COGCC permitting review /approval. The plan will
be engineered to accommodate typical stormwater construction activities and addresses
existing drainage conditions both on- and off -site, per COGCC regulation for E &P waste
facilities. It also accommodates drainages associated with a 100 year, 24 hour
stormwater event.
Article VII, § 7 -208 Air Quality
The land use change shall not cause air quality to be reduced below acceptable level
established by the Colorado Department of Public Health and Environment (CDPHE). PDC will
obtain all applicable federal and state air quality permits.
Article VII, § 7 -209 Areas Subject to Wildfire Hazards
A. Location Restrictions
The project site is designated in a low to low moderate wildfire hazard on the Garfield
County Wildfire Hazard Map.
B. Development Does Not Increase Potential Hazard
The proposed facility will not increase the wildfire hazard for this area.
C. Fuel Modifications
The site is located in a low to moderate wildfire area according to maps available on the
Garfield County GIS website. The proposal will not increase the threat of wildfire in the
area.
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D. Roof Materials Design
No structures will be built at the proposed facility.
E. Safety Areas in Residential Development
This standard is not applicable.
F. Dead -End Roads
The proposed facility is accessed via a private road. There will be a short spur off of the
road leading to the facility through an access gate.
G. Hammerhead
There will be no hammerhead turnaround for this facility.
H. Road Grade
The maximum road grade leading to the proposed facility is less than 8 %.
Article VII, § 7 -210 Areas Subject to Natural Hazards and Geologic Hazards
Geologic hazards have not been mapped by Garfield County in this area. According to the
Geologic and Soil Hazard Report submitted with this application the site has a low potential for
geologic hazards. No faults or other hazards are evident on the Geologic Map of Colorado. No
other hazards have been observed by PDC.
A. Utilities
No public utilities will be necessary to service the facility. If required, all wires, cables,
fixtures and other equipment shall be installed in compliance with the requirements of
the National Electric Safety Code and all FCC, FAA, state and local regulations, and in
such a manner that will not interfere with radio communications, electronic transmissions
or all other electromagnetic communications or otherwise cause a safety hazard.
B. Development in Avalanche Hazard Areas
The proposed facility is not located in a mapped avalanche hazard area. The risk from
avalanche appears to be low. No structures or buildings are proposed.
C. Development in Landslide Hazard Areas
The proposed facility is not located in a mapped landslide hazard area. The risk from
landslide appears to be low. No structures or buildings are proposed. No weight will be
added to a top of a slope subject to a landslide hazard. No support materials will be
removed from the toe of a slope subject to landslide hazard.
D. Development in Rockfall Hazard Areas
The proposed facility is not located in a mapped rock fall hazard area. The risk from
rockfall hazard appears to be low. No structures or buildings are proposed. No weight
will be added to a top of a slope subject to a rockfall hazard. No support materials will be
removed from the toe of a slope subject to rockfall hazard.
E. Development in Alluvial Fan Hazard Area
The proposed facility is not located in a mapped alluvial fan hazard area. According to
the Geologic and Soil Hazard Report submitted with this application the site is located on
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gravels and alluvium glacial deposits. The risk from alluvial fan hazard appears to be
low. No structures or buildings are proposed. The proposal plans no disturbance in the
drainage basin above the alluvial fan.
F. Slope Development
The site is not located on a slope that is 20- percent or greater. This standard is not
applicable.
G. Development on Corrosive or Expansive Soils and Rock
No structures or buildings are proposed. This standard is not applicable.
H. Development in Mudflow Areas
The proposed facility is not located in a mapped mudflow hazard area. The risk from
mudflow hazard appears to be low. No structures or buildings are proposed.
I. Development Over Faults
According to the Geologic and Soil Hazard Report submitted with this application no
faults are located in the immediate vicinity of the proposed facility.
Article VII, § 7 -211 Areas with Archeological, Paleontological or Historical Importance
No protected or registered archaeological, cultural, paleontological or historic resources will be
impacted. See the Cultural Resources Report for additional details.
Article VII, § 7 -212 Reclamation
A Reclamation Plan has been provided as a component of the Impact Analysis. During the
reclamation phase, the property will be re- seeded and re- graded to pre- disturbance levels. A
copy of the full Reclamation Plan is also included.
Division 3 Site Planning & Development Standards
Article VII, § 7 -301 Compatible Design
A. Site Organization
The site is organized to efficiently use the property for soil treatment and control
stormwater.
B. Operational Characteristics
Operation of the proposed facility will be consistent with nearby uses. Activities at the
facility will be intermittent and the use of internal combustion engines will be minimal.
Adjacent property will not be impacted by the generation of vapor, dust, smoke, glare or
vibration. The facility will be unmanned and will operate 24 hours a day, 7 days a week,
and 365 days a year. There will be minimal impacts, if any, to the roadway system
during the operational phase.
C. Lighting
No lighting other than for emergency purposes is currently proposed. Any lighting
utilized at the site will meet the requirements for downcast, shielded, flashing, and
hazardous lighting.
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D. Buffering
Property adjacent to this site is generally zoned the same as the subject property,
Resource Lands, or zoned Public Lands. An exception is the property northeast of the
site is zoned Commercial /Limited and appears to be used as an office and contractor
yard.
E. Materials
No buildings are proposed. This standard is not applicable.
F. Building Scale
No buildings are proposed. This standard is not applicable.
Article VII, § 7 -302 Building Design
The facility will be constructed to minimize sound and visibility and will meet the Garfield
County Building Department requirements. No structures are currently anticipated on
the proposed location.
Article VII, § 7 -303 Design and Scale of Development
A. Excessive Site Disturbance
The nature of the facility is such that the site will be disturbed on an ongoing basis. At
the end of the useful life of the facility, it will be recontoured and revegetated back to its
predisturbance condition.
B. Minimize Adverse Influences by Airport Operations
Airport operations will not affect the proposed operations at this site. This standard is not
applicable.
C. Efficiency in Provision of Services and Access to Facilities
This site has been designed to provide efficient use of the property as a soil treatment
facility.
Article VII, § 7 -304 Off - Street Parking and Loading Standards
This proposal does not require dedicated parking or loading facilities. This standard is not
applicable. All parking and loading will take place on the subject property.
Article VII, § 7 -305 Landscaping
No landscaping is proposed. The operator will follow the attached Weed Management and
Reclamation Plan recommendations and guidelines.
Article VII, § 7 -306 Lighting Standards
No lighting other than for emergency purposes is currently proposed. Any lighting utilized at the
site will meet the requirements for downcast, shielded, flashing, and hazardous lighting.
Article VII, § 7 -307 Snow Storage Standards
Snow will be stored in a vacant section of the existing disturbed area. The site has been
designed by a professional engineer and graded to accommodate snowmelt to insure sufficient
drainage.
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Article VII, § 7 -308 Roadway Standards
No new accesses or auxiliary lanes onto a County or State roadway will be required as
indicated in the Traffic Study. The existing private roadway has been constructed to limit
erosion and dust. The existing private roadway serves the natural gas development industry
and has been constructed to accommodate the typical truck traffic associated with operation of
this facility. The access roadway's characteristics are a hybrid of the Primitive Residential and
Semi Primitive details provided in Garfield County ULUR of 2008, Section 7- 308.B, Table 7 -308,
Roadway Standards. Based on the existing condition and historical use of the roadway by
natural gas developers, the existing private roadway meets the appropriate standards for
capacity, width, grade and surface materials.
Article VII, § 7 -309 Trail and Walkway Standards
The site is located in an area that is not suitable for a public trail system or walkway. This
standard is not applicable.
Article VII, § 7 -310 Utility Standards
No public utilities will be necessary to service the facility. If required, all wires, cables, fixtures
and other equipment shall be installed in compliance with the requirements of the National
Electric Safety Code and all FCC, FAA, state and local regulations, and in such a manner that
will not interfere with radio communications, electronic transmissions or all other
electromagnetic communications or otherwise cause a safety hazard.
Division 11 Additional Standards for Industrial Uses
Section 7 -1101 Industrial Use
A. Residential Subdivisions
This site is not in a residential subdivision. This standard is not applicable.
B. Setbacks
This site is not adjacent to a residential property. This standards is not applicable
C. Concealing and Screening
There will be no outside storage of equipment on this site. The proposed facility will be
fenced. No landscaping is proposed.
D. Loading and Unloading
The property does not include public road right -of -way on the subject site. All operations
will be conducted on site (private property).
E. Storing
No vehicles, tanks or structures will be stored on site. Appropriate equipment will be
delivered to the site as needed. Soil amendments and microbes required for the
remediation will be delivered on an as- needed basis, but will not be stored on site.
There will be no on site fuel storage and water required for the remediation process will
accompany delivery of the equipment.
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F. Hours of Operation
The facility will be accessible to PDC personnel 24 hours a day, 365 days a year,
however personnel will primarily use this facility during normal working hours from
approximately 7:30 am to 6:00 pm, Monday through Friday.
G. Industrial Wastes
No industrial waste (IW) is anticipated or associated with the operation of this facility.
Should any IW be generated, it will be disposed of according to Federal, State, and
Local regulations.
H. Noise
Operation of the facility will not exceed the Residential /Agricultural /Rural Zone
Standards established by the COGCC and Colorado Noise Statue 25 -12 -103
requirements.
I. Ground Vibration
Ground vibration will not be measurable at any point along the property boundary lines.
J. Interference, Nuisance, or Hazard
The facility will comply with all applicable Federal, State, and Local regulations.
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