2017-05-04_REVISION - C1981010 (2)

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Page 2 of 8 PR8 Letter to Robin Reilley May 3, 2017 Information from soils and vegetation reports for the PR -7 area, combined with information determined during a field evaluation conducted by Ranch Advisory Partners for TMI's Williams Fork Land Company in July 2014 to assess rangeland health and wildlife habitat, were used to determine land capability and cattle carrying capacity of the PR -7 expansion area. The land capability for most of the PR -7 lands is high for wildlife foraging. Table 2.5-5 to be inserted into the permit document shows the vegetative productivity by soil type for the soils within the PR -7 area in accordance with the Natural Resources Conservation Service Web Soil Survey at htto://websoilsurvey.nres.usda.gov/al)p/HomePage.htm. Based on the field evaluation by Ranch Advisory Partners, much of the PR -7 land is too steep for effective cattle grazing with only 86 of the total 795.71 acres assessed as good cattle grazing area. Except for a spring at the extreme south end, there are no water sources available within the of the PR -7 expansion area; however, there is water on mining and reclaimed lands to the west and across County Road 33 to the east. The cattle carrying capacity for the 86 acres of grazeable land is approximately 11 animal days/acre and approximately 2.7 acres/animal unit month. The discussion of the land capability and productivity is contained in Section 2.5 of the permit document. A narrative discussion of the capability and productivity for the PR -7 area has been added to Section 2.5 of the permit document with the replacement pages 2-181 and 2-181a attached to this letter for review. b) Cultural and historic resource information for areas proposed or likely to be affected by surface mining activities in accordance with Rule 2.04.4. In 2013 and 2014 three Class III surveys were conducted by Grand River Institute within the 795.71 acre expanded permit area as part of PR -7. The surveys also included approximately 2,568 acres to the east of the revised permit boundary. The area covered by these surveys is shown on the enclosed revised Map M45 and the results of these surveys are enclosed to be inserted in Appendix K. The surveys identified 12 sites for new recording. Seven of the newly recorded sites required additional testing to determine eligibility for listing on the National Register of Historic Places; the remaining five sites were determined not eligible for listing. The seven locations requiring additional testing were evaluated in 2015. Upon completion of the additional evaluation all seven sites were determined not eligible for listing. All surveys were authorized by and submitted to the Bureau of Land Management Little Snake Field office and conducted in accordance with the requirements of the National Historic Preservation Act. In addition to evaluating the PR -7 area and areas to the east, site number 5MF948 previously identified within the Trapper Mine permit boundary (the cliff rock art site) was re-evaluated during a 2013 re -survey by Grand River Institute. The site's original recorded location was determined to have been incorrect (approximately 550 meters to the east-southeast of the corrected location assessed in 2013). The features of this site were determined to demonstrate association with prehistoric and native lifeways. The potential for additional buried cultural deposits was determined by the 2013 survey to be significant and the survey recommended that expansion of the mining activities into the canyon in which the site is located be curtailed and the entire canyon area be avoided by any surface disturbing activities or blasting. TMI has conducted an evaluation of the potential impacts to this site from blasting which will be submitted to the CDRMS as part of the five-year operating plan to be submitted later this year.