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Twentymile Coal, LLC. <br />Page 4 <br />September 29, 2015 <br />.0132%), and does not require adjustment. From a practical standpoint, the only acreage <br />that are of significance are the surface disturbance and affected area acreages, which are <br />normally carried out to one decimal point, since they relate to reclamation obligations <br />under the permit. <br />£ Division's Response: The Division agrees the difference in surface/mineral ownership <br />acreage and permit area acreage is negligible. Upon discussion with Division <br />management, if PR10 is approved the permit area will be increased to match the <br />surface/mineral ownership acreage. <br />Rule 2.04.4 - Cultural and Historic Resource Information and Rule 2.05.6(4) — Protection of Public <br />Parks and Historic Places <br />PR10 requests an increase in affected area of 150 acres. It was found during the review of PRI 1 <br />(Which mirrors the PR10 application except for it excludes mining in the area TC is currently <br />seeking a lease modification for in the coal lease COC -54608) that permit section 2.04.4 was not <br />proposed to be revised with updated information required by Rule 2.04.4. Given this, TC hired <br />Metcalf Archaeological Consultants, Inc. to conduct a Class III Cultural Resources Inventory for <br />the newly proposed affected area. The Division received the results of this inventory on August <br />21, 2015. These results have been forwarded to the State Historic Preservation Officer's office <br />(SHPO) for review and the Division is awaiting their response. The following items will need to <br />be addressed: <br />a. The PR10 application revised pages do not include updates to section 2.04.4 of the permit <br />to discuss the cultural resources inventory conducted for this project. Such language is <br />included in revised pages currently under review for MR289. It would be appropriate to <br />include the language currently proposed with MR289. For consistency, please revise this <br />section of the permit to discuss the cultural resources found within the proposed WCR <br />affected area. <br />b. According to the inventory, two sites; 5RT3324 and 5RT3325 are recommended to be <br />eligible for inclusion on the National Register of Historic Places (NRHP) and total <br />avoidance is recommended. These two sites are within the area that will be affected by <br />subsidence. It does not appear surface disturbance activities other than possible impacts <br />from subsidence will occur in these areas. TC, the Division and SHPO will need to <br />coordinate to determine if appropriate mitigation and treatment measures are necessary <br />prior to undermining these areas. If mitigation and/or treatment measures are necessary <br />for these sites, a discussion of such measures will need to be included in Section <br />2.05.6(4) of the permit. <br />i. TC's Response: Section 2.04 has been reviewed and revised to reference and <br />discuss the results of the supplemental cultural resource survey covering the <br />additional subsidence area. Both of the recommended eligible sites are lithic <br />scatters with demonstrated potential for buried cultural material. TC has <br />requested that our archaeological consultant, Metcalf Archaeology, review their <br />information regarding the two subject sites, and provide an assessment of the <br />