2015-09-11_REVISION - C1982056 (3)

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€CI HISTORY September 8, 2015 Jared L. Ebert Environmental Protection Specialist Division of Reclamation, Maung and Safety23q Department of Natural Resources 1313 Sherman Street, Room 215 Denver, Colorado 80203 SEP � 12015 DN�SION OF ND S Re: Foidel Creek Mine (Permit No. C-1982-056), Minor Revision No. 289 (MR289), Permit Revision No. 10 (PR10) and Permit Revision No. 11 (PR11) (HC # 67400) Dear Mr. Ebert: We received the final report titled "Twentyrrule Coal Company LLC: A Class III Cultural Resources Inventory of the Proposed Wolf Creek Bleeder Air Exhaust and Subsidence Block in Routt County, Colorado" as well as associated cultural resources inventory forms from Melissa Elkins, Project Director/ Regional Project Coordinator with Metcalf Archaeological Consultants, on August 31, 2015 that documents cultural resources survey completed within the area of potential effects associated untlun the above permit revisions currently, under review by your office. After review of the contractor's report, we concur with its recommendation that sites 5RT3324 and 5RT3325 are eligible for listing to the National Register of Historic Places (NRHP) for significant information (criterion D) that may be present within buried depositional contexts. We concur with the contractor's recommendation that sites 5RT157, 5RT3259 2, 5RT3322.1, 5RT3323, 5RT3326, and 5RT3327 are not eligible for listing to the NRIIP under any criteria. Likewise, we concur that isolated finds 5RT3328, 5RT3329, 511'173330, and 51113331 are not eligible for listing to the NRHP. With regards to project effect, it is our opinion that MR289 that proposes to construct an emergency air borehole and access road will result in no historic properties affected. Effects associated with the remaining two permit revisions are more complex when we consider effects that may result from subsidence. While we concur that both NRHP-eligible sites should be avoided by future construction activities, as is currently recommended, we understand that subsidence of up to 76 -inches is possible for portions of the project area including the locations of the above properties In order to fully consider possible effects associated with surface subsidence associated with PR10 and PR11, we request additional information regarding the nature and extent of potential effects to sites 5RT3324 and 5RT3325. Please keep in mind that an adverse effect is found when an undertaking mai alter, directly or indirectly, any of the characteristics that qualify a property for inclusion in the National Register. The Section 106 consultation process does involve other consulting parties such as local governments and Tribes, which as stipulated in 36 CFR 800.3 are required to be notified of the undertaking. Additional information provided by the local government, "Tribes or other consulting parties may cause our office to re-evaluate our comments and recommendations. We thank you for the opportunity to cominent. If we may be of further assistance, please contact Mark Tobias, Section 106 Compliance Manager, at (303) 866-4674 or mark. tobiasgstate.co.us. Sincerely, E �tard C.ichols State Historic Preservation Officer ECN/mt