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New Elk Mine, PR5 Adequacy Review 2 <br /> November 2,2021 <br /> Page 4 of 11 <br /> Rule 2.04.4—Cultural and Historic Resource Information <br /> 15. On August 6th,2021,DRMS received the enclosed undated letter from History Colorado,from the State <br /> Historic Preservation Officer(SHPO). They requested additional information from DRMS regarding PR5 <br /> which we have provided to them. Also,the SHPO recommended that a class III cultural resource inventory <br /> be completed prior to construction activities to determine the presence of cultural resources in the area of <br /> potential effect and to assess the eligibility of any resources for the National Register of Historic Places <br /> (NRHP). Rule 2.04.4 requires such an analysis for areas potentially impacted by surface activities or <br /> probable subsidence. Given this,DRMS sought clarification on SHPO's recommendation since no new <br /> surface disturbance is proposed with PR5 and since subsidence is not anticipated given the proposed mining <br /> method. SHPO responded to DRMS with the enclosed correspondence dated August 20,2021. Upon review <br /> of Section 2.05.6 of the PAP and Exhibit 24,the current mine plan and subsidence control plan anticipates <br /> multi-seam mining and planned subsidence from retreat mining in certain circumstances. Please see the <br /> adequacy review questions under the section for Rule 2.05.6 below. Either provide the results of the class III <br /> cultural resource survey and update Section 2.04.4 accordingly,or provide a detailed rationale for not <br /> providing this information. <br /> a. NECC Response: Section 2.05.6 has been revised to include mining method and extraction of coal. <br /> With room and pillar mining and no proposed secondary mining,subsidence will not occur.As a <br /> result,NECC requests that a class III cultural resource inventory of the PR5 not be required. <br /> b. DRMS Response:The Division did not receive a revised section 2.05.6(6)subsidence survey, <br /> monitoring,and control plan. Please submit a revised section as indicated above and ensure that if <br /> no subsidence is anticipated that an analysis is included that supports this conclusion and justification <br /> for not providing a cultural resource survey. Simply stating that subsidence will not occur is not <br /> sufficient,please see section 2.05.6(6)for details.Please revise page 2.04-8 as necessary to comply <br /> with Rule 2.04.4 regarding the proposed PR5 expansion and increase in affected area. <br /> c. DRMS Response#2:NECC Submitted a revised Exhibit 7—Archaeological Information,the cover <br /> page indicates a letter from the SHPO dated August 6,2021 and an email from the SHPO dated <br /> August 20,2021 was to be included in the Exhibit. However these documents were not included in <br /> revised Exhibit 7,please submit the documents. <br /> Rule 2.04.5—General Description of Hvdroloev and Geolo�v <br /> 16. Please revise Map 5 and 6 to depict the revised permit boundary. <br /> a. NECC Response:Maps 5 and 6 have been revised to include the permit boundary. <br /> b. DRMS Response:The revised maps must be certified by a qualified registered professional engineer <br /> or professional geologist,with assistance from experts in related fields such as land surveying and <br /> landscape architecture in accordance with Rule 2.10.3(2). Please revise the maps accordingly to <br /> include this certification. <br /> 17. Map 7 includes geologic cross sections,however the A-A' cross section does not extend into the proposed <br /> PR5 expansion area fully to the northeast. Please update Map 7 to take the expanded permit area and affected <br /> area into account. <br /> a. NECC Response:Map 7 of the PAP has been updated to include the expanded permit area. <br />