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8/20/2021 State.co.us Executive Branch Mail - Fwd: New Elk Mine (Permit No. C-1981-012) Permit Revision Application No. 5 (PR-5), Permit Revisi... <br />A STATE OF Ebert - DNR, Jared <jared.ebert@state.co.us> <br />COLORADO <br />Fwd: New Elk Mine (Permit No. C-1981-012) Permit Revision Application No. 5 (PR- <br />5), Permit Revision 5 (HC# 71066) <br />Marques - HC, Matthew <matthew.marques@state.co.us> <br />To: "Ebert - DNR, Jared" <jared.ebert@state.co.us> <br />Hi Jared, <br />Fri, Aug 20, 2021 at 9:49 AM <br />Thank you for updating us on the point of contact for this undertaking. I will let our other staff know about the changes for <br />contacts for the New Elk Mine in case other reviewers have questions or projects that they are reviewing. Do you know if <br />DJ was the point of contact for any other permits? From what I can remember, I do not believe so. <br />As far as the current project, we are happy to review any additional information you can provide regarding the potential for <br />subsidence including any quantitative or qualitative data. It, however, seems that some level of subsidence or vibrations <br />would comprise a reasonably foreseeable effect for the undertaking. Similar types of underground operations have <br />resulted in subsidence that posed impacts to cultural resources including archaeological sites, rock art sites, and historic <br />structures. <br />It should be noted that the Advisory Council on Historic Preservation (ACHP) has previously commented on effects posed <br />by subsidence in Colorado. The ACHP commented on an undertaking associated with King II Coal Mine noting in <br />response to claims regarding the limited potential for impacts to cultural resources from subsidence that any such claims <br />should be substantiated by data. The ACHP noted that subsidence appears reasonably foreseeable and they "believe <br />subsidence, in general, with or without subsidence cracks, should be considered an effect on historic properties as it may <br />include changes in the relationship of a property to its surroundings, including changes in its surface contours, <br />topography, and erosional patterns. Following the same reasoning it appears that the opening and subsequent refilling of <br />subsidence fractures, if they were to occur, should also be considered at least an effect on archaeological sites." <br />In addition to subsidence, it seems reasonably foreseeable that surface borings, access roads, ventilation, and potentially <br />additional infrastructure would result from the proposed expansion. Similar features are observed within the current <br />boundaries of the mine and appear to be necessary features for the operation of the mine. <br />We continue to request the completion of a class III cultural resource inventory considering the potential effects of the <br />undertaking on historic properties, the dearth of previous inventory, and the potential for previously unidentified cultural <br />resources. As mentioned previously, we are open to discussion and reviewing any additional data or information that you <br />could provide that could change our recommendation. <br />Please let me know if you would like to discuss this over the phone or if you have any additional questions. <br />Thank you, <br />[Quoted text hidden] <br />https://mail.google.com/mail/u/0?ik=86aa78d9e6&view=pt&search=all&permmsgid=msg-f%3Al 708627970952437044&simpl=msg-f%3A17086279709... 1 /1 <br />