2015-12-08_REVISION - C1982056 - Laserfiche WebLink

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Twentymile Coal, LLC. Page 4 December 8, 2015 Rule 2.04.4 - Cultural and Historic Resource Information and Rule 2.05.6(4) — Protection of Public Parks and Historic Places 15. PRI l requests an increase in affected area of 150 acres. TC hired Metcalf Archaeological Consultants, Inc. to conduct a Class III Cultural Resources Inventory for the newly proposed affected area. The Division received the results of this inventory on August 21, 2015. These results have been forwarded to the State Historic Preservation Officer's office (SHPO) for review and the Division is awaiting their response. The following item will need to be addressed: a. According to the inventory, two sites; 5RT3324 and 5RT3325 are recommended to be eligible for inclusion on the National Register of Historic Places (NRNP) and total avoidance is recommended. These two sites are within the area that will be affected by subsidence. It does not appear surface disturbance activities other than possible impacts from subsidence will occur in these areas. TC, the Division and SHPO will need to coordinate to determine if appropriate mitigation and treatment measures are necessary prior to undermining these areas. If mitigation and/or treatment measures are necessary for these sites, a discussion of such measures will need to be included in Section 2.05.6(4) of the permit. i. TC's response: Section 2.04.4 has been reviewed and revised to reference and discuss the results of the supplemental cultural resource survey covering the additional subsidence area. The recommended eligible sites are lithic scatters with demonstrated potential for buried cultural material. TC requested that our archaeological consultant, Metcalf Archaeology, review their information regarding the subject sites, provide an assessment of the potential adverse impacts to these sites from the anticipated mining -related subsidence. On November 11, 2015, Metcalf submitted a letter to the CDRMS summarizing their evaluation of potential subsidence -related impacts on the identified NHRP eligible sites. Given the very limited potential subsidence displacement and change in gradient for the subject sites, Metcalf indicated that potential subsidence effects would be negligible. ii. Division response: On December 1, 2015, the Division received correspondence from the SHPO's office indicating that they concur with the determination that the sites in question will not be adversely affected. This item is considered resolved. Ownership and Control Information; AVS System Review (Division's October 9, 2015 Letter) • The Colorado Division of Reclamation, Mining, and Safety (Division) has reviewed the Ownership and Control information for the mine contained in Exhibit 47 against the information in the Applicant Violator System (AVS). The following item will need to be addressed prior to the approval of PR10 or PRI 1.