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3 <br /> <br />3 <br />Trapper Mine PR8 Preliminary Adequacy Review <br />Prepared by: R. Reilley July 2017 <br />new recording. Seven of the newly recorded sites required additional testing to determine eligibility for listing <br />on the National Register of Historic Places; the remaining five sites were determined not eligible for listing. <br />The seven locations requiring additional testing were evaluated in 2015. Upon completion of the additional <br />evaluation all seven sites were determined not eligible for listing. All surveys were authorized by and <br />submitted to the Bureau of Land Management Little Snake Field office and conducted in accordance with the <br />requirements of the National Historic Preservation Act. <br /> <br />In addition to evaluating the PR-7 area and areas to the east, site number 5MF948 previously identified <br />within the Trapper Mine permit boundary (the cliff rock art site) was re-evaluated during a 2013 re-survey <br />by Grand River institute. The site's original recorded location was determined to have been incorrect <br />(approximately 550 meters to the east-southeast of the corrected location assessed in 2013). The features of <br />this site were determined to demonstrate association with prehistoric and native lifeways. The potential for <br />additional buried cultural deposits was determined by the 2013 survey to be significant and the survey <br />recommended that expansion of the mining activities into the canyon in which the site is located be curtailed <br />and the entire canyon area be avoided by any surface disturbing activities or blasting. TMI has conducted an <br />evaluation of the potential impacts to this site from blasting which will be submitted to the DRMS as part of <br />the five-year operating plan to be submitted later this year. <br /> <br />A narrative has been added to Sections 2.9, 2.9.I and 2.9.2 of the permit document. Replacement pages 2- <br />588, 2-590, 2-591, 2-59I b and 2-59 I c are attached to this letter. The following cultural resource surveys are <br />included for insertion into Appendix K. <br /> <br />Section XIII: Class III Cultural Resource Inventory by Grand River Institute, BLM-LSFO No. <br />I 1.7.2013 (860 acres) <br />Section XIV: Class III Cultural Resource Inventory by Grand River Institute, BLM-LSFO No. <br />I 1.10.2013 (752 acres) <br />Section XV: Class III Cultural Resource Inventory by Grand River Institute, BLM-LSFO No. <br />11.1.2016 (1752 acres) <br />Section XVI: Text Excavation of Site 5MF7762 by Grand River Institute, BLM-LSFO No. <br />11.2.2016 <br />Section XVII: Text Excavation of Six Sites (5MF319, 5MF7691, 5MF7682, 5MF7727, <br />5MF7794 and 5MF7795) by Grand River Institute, BLM-LSFO No. 11.1.2016 <br /> <br />Note that older Section VII is included as a two-sided document. This section should replace the previous <br />one-sided Section VII. This was done to make room for the new sections added to the Appendix K binder. <br />July 2017 DRMS <br />1. Appendix K and the above mentioned cultural resource surveys are under review by History <br />Colorado as per Rules 2.04.4 and 2.05.6 (4). Once DRMS receives conclusions from <br />History Colorado, their comments and the status of Appendix K will be shared with TMI. <br /> <br />2. DRMS is awaiting submittal of the report detailing blasting impacts to site 5MF948. <br /> <br />May 2017 Trapper <br />c) A geology description that updates Sections 2.7.2 and 2.7.3 of the Trapper Mine permit application <br />package with the information required by Rule 2.04.6(2)(a) and (b). <br /> <br />As discussed in several previous adequacy responses related to the PR-7 area geologic description, the <br />general geology of the PR-7 area is similar to the remainder of the mine area as described in Section 2.7.I <br />of the Trapper permit document. Geologic cross-sections through the PR-7 Mine Expansion Area were <br />included in a prior submittal in response to adequacy comments. At this time, TMI is not asking for