2018-03-19_PERMIT FILE - C1981019 (2)

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Data Recovery Report for Three Sites at the Collom Project Colowyo Coal Company 1.0 PROJECT AND UNDERTAKING DESCRIPTION In 2017, Colowyo Coal Company L.P. (Colowyo) began constructing the haul road and associated facilities for the Collom Expansion Project (Project). As part of the Project, Tetra Tech was contracted to provide archaeological monitoring services for Elk Ridge Mining and Reclamation, LLC (Elk Ridge) on the behalf of Colowyo. Elk Ridge requested the archaeological monitoring be conducted for all topsoil stripping within the permit boundary in accordance with Exhibit 5, Item 3 - Cultural Resource Protection Plan for the Collom Mine Expansion. The plan was filed by Colowyo to the Office of Surface Mining, Reclamation, and Enforcement (OSMRE) as part of Colowyo's project mine permit. On July 26, 2017, prehistoric site 5MF.8393 (field number BK -1-072617) was discovered by a Tetra Tech archaeological monitor during topsoil stripping activities along the haul road disturbance footprint west of Wilson Creek. On August 23, 2017, prehistoric sites 5MF.8394 and 5MF.8395 (field numbers MK -1-082317 and MK -2-082317) were discovered by Tetra Tech archaeological monitors during topsoil stripping activities within the haul road disturbance footprint at the Moffat County Road 51 crossing and immediately west of Wilson Creek. In accordance with Exhibit 5, Item 3; topsoil stripping activities were stopped within 100 feet (ft) [30 meters (m)] of each discovery and each site was flagged for avoidance. Tetra Tech produced a notification report for Colowyo to submit for review to OSMRE; Colorado Division of Reclamation, Mining, and Safety (DRMS); and Office of Archaeology and Historic Preservation (OAHP). The sites could not be avoided by the Project and faced complete removal. OSMRE, in consultation with DRMS and OAHP, determined the Project would cause an adverse impact to each site in the form of complete removal of any additional data potential. The data potential was argued to be in the form of the remains of intact man-made features and a significant the potential for additional subsurface cultural components to occur at each of the discoveries. The consulted agencies requested the development of a historic properties treatment plan (HPTP) to mitigate the adverse effects. Tetra Tech produced two HPTPs with Site 5MF.8393 (Karpinski 2017a) being first discovered and sites 5MF.8394 and 5MF.8395 (Karpinski 2017b) being discovered second. Each HPTP was reviewed and approved by Colowyo, OSMRE, DRMS, and OAHP prior to data recovery field work commencing at any of the sites. The discovery areas had been subjected to Class III cultural resource inventory in 2005 and no cultural resources were observed on the ground surface at each location (Lowe et al. 2006). Prior to ground disturbance, Tetra Tech's archaeological monitors walked the disturbance footprint for the haul road and did not observe any surface cultural resources. The discovered sites are near the previously recorded Site 5MF.1652. The site is located to the north and west outside the disturbance area on top of a low knoll immediately east of Moffat County Road 51. The site was recorded as a prehistoric artifact scatter with features that was originally recorded in 1983 and revisited in 2005 and 2015 (Lowe et al. 2006 and Karpinski and Dugmore 2016). OAHP lists the site's National Register of Historic Places (NRHP) status as Needs Data pending further investigation. The previously recorded site's boundary is completely outside of the Project's disturbance footprint and away from the discoveries. The three discoveries are similar in character and makeup, but are not being considered extensions of the previously recorded site. 1.1 Environmental Setting 1.1.1 Project Setting The Project is situated in the Southern Rocky Mountain physiographic province among a series of long broad northeast/southwest-trending ridges that make up the Danforth Hills. (Fennerman 1931; Thombury 1965). The Project extends into the southern part of the Axial Basin in the north. Tetra Tech February 2018