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RULE 2 - PERMITS <br />On January 2009, Metcalf Archaeological Consultants, Inc. conducted a Class III cultural <br />resource inventory within portions of the mine permit areas in T6N, R87W, Sections 34 and 35; <br />and T5N, R87W, Sections 2 and 3. Survey results are summarized in an Exhibit (Exhibit <br />2.04.4-E2, Cultural Information — Stockpile and Portal Areas (confidential), which contains the <br />Metcalf Archaeological Consultants, Inc. Report, titled A Class III Cultural Resources Inventory <br />of the Proposed Twentymile Coal Company Sage Creek Stockpile and Portal Areas, Routt <br />County, Colorado (Metcalf Archaeological, 2009b). The survey consisted of a Class III cultural <br />resource investigation for the proposed PSCM stockpile and portal areas, which accounts for a <br />small portion of the entire PSCM permit area, but the majority of the proposed surface <br />disturbance footprint. No archaeological materials were discovered during the inventory and a <br />finding of no historic properties affected was recommended for the project. <br />File searches for this field effort were conducted through the OAHP Compass database on <br />November 2008. The database indicates that eight cultural studies have occurred within the <br />sections covered in the inventory. All projects were cultural resource inventories for well line <br />and access roads, transmission lines, drill sites, and investigation of coal leases. Numerous other <br />inventories, most related to coal mining, seismic exploration, and powerline construction have <br />been conducted in nearby sections. Most are either linear or small block survey. <br />An additional Class III Survey of a small additional area to be disturbed by planned surface <br />activities was completed in July 2009. Survey results are included in a letter report titled; <br />"Twentymile Coal Company Sage Creek Portal Project: A Class III Cultural Resources <br />Inventory, Routt County, Colorado", in Exhibit 2.04.4-E2, Cultural Information. <br />For anticipated future subsidence areas, Metcalf Archaeology developed and submitted a <br />proposed methodology for Class I and limited Class II surveys to address SHPO requirements, <br />but limit the associated work efforts where the only impact would be surface subsidence, and <br />where the potential of occurrence for cultural resource values would be limited, based on prior <br />surveys of the area and the resulting identified patterns of use and occupation. The proposed <br />methodology is outlined in a report titled; "Class I Inventory and Proposed Class 11 Methodology <br />for Peabody Coal Company's Sage Creek Subsidence Expansion Area, Routt County, Colorado, <br />which is included in Exhibit 2.04.4-E2, Cultural Information. <br />RN15-01 2.04-14 Revision 10/17 <br />