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1/6/22,2:03 PM State.co.us Executive Branch Mail-Fwd:HC#67752 Colowyo Mine Permit Technical Revision 152 <br /> STATE OF DRMS—CoalAdmin -DNR, DNR<dnr—drms—coal—admin@state.co.us> <br /> COLORADO — <br /> Fwd: HC# 67752 Colowyo Mine Permit Technical Revision 152 <br /> 1 message <br /> Trujillo - DNR, Zach <zach.trujillo@state.co.us> Thu, Jan 6, 2022 at 12:50 PM <br /> To: DNR DRMS_CoalAdmin - DNR<dnr—drms—coal—admin@state.co.us> <br /> The following is correspondence from SHPO to DRMS regarding Colowyo Mine (C-1981-019)TR-152. Thanks. <br /> ---------- Forwarded message--------- <br /> From: Marques - HC, Matthew<matthew.marques@state.co.us> <br /> Date: Thu, Jan 6, 2022 at 9:02 AM <br /> Subject: HC#67752 Colowyo Mine Permit Technical Revision 152 <br /> To: Zach Trujillo- DNR <zach.trujillo@state.co.us> <br /> Hi Zach, <br /> We appreciate the additional information provided for our review. We, however, have additional questions and comments <br /> regarding the proposed undertaking. <br /> You noted that the technical revision consists of highwall mining to the northeast and southeast of the South Taylor Pit. <br /> While areas to the northeast of the mine appear to be previously disturbed, it remains unclear where the mine proposes <br /> to expand mining operations to the northeast of the Pit. Could you please clarify the extent of activities that will occur as <br /> a result of the undertaking including in this area to the northeast of the Pit? <br /> We understand that the proposed undertaking will involve subsurface mining activities and that the proposed undertaking <br /> will not result in surface mining. The proposed expansion of subsurface mining operations has the potential to affect <br /> cultural resources through the development of infrastructure (i.e. ventilation, access roads, and surface borings), <br /> temporary use areas, and reclamation activities as well as through reasonably foreseeable effects such as subsidence <br /> and ground vibrations. Similar types of underground operations in similar geological locations have resulted in <br /> subsidence that posed impacts to cultural resources including archaeological sites, rock art sites, and historic structures. <br /> The Advisory Council on Historic Preservation has previously commented on effects posed by subsidence in Colorado <br /> and noted that"subsidence, in general, with or without subsidence cracks, should be considered an effect on historic <br /> properties as it may include changes in the relationship of a property to its surroundings, including changes in its surface <br /> contours, topography, and erosional patterns. Following the same reasoning it appears that the opening and subsequent <br /> refilling of subsidence fractures, if they were to occur, should be considered at least an effect on archaeological sites." <br /> According to our records, portions of the mine expansion area have not been previously inventoried by cultural resource <br /> specialists and inventories that were completed were completed between 33 and 44 years ago. These inventories do not <br /> meet current standards and resources considered modern at the time would be considered historic by current standards. <br /> Aerial images show that a high frequency of the proposed expansion areas remain relatively undisturbed. In particular, <br /> the area to the west and south of the Pit remains relatively undisturbed. These areas show the potential for containing <br /> previously unidentified cultural remains. As a result, we recommended a cultural resource inventory. <br /> The provided map suggests that inventory was completed in a higher frequency of the area than we have in our files. <br /> Has the area recently been inventoried by a cultural resource specialist(s)? If so, could you please send us a copy of the <br /> results of the inventory(ies). If not, we continue to request the completion of a class III cultural resource inventory <br /> considering the reasons discussed above. <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 /> Matthew Marques <br /> Section 106 Compliance Manager <br /> https://mail.google.com/mail/b/ALGkd0y8elLUpphO-cw_b4dRu9Vtn4AuagQgJnHQChhDjud92irb/u/O/?ik=deb7fOcd20&view=pt&search=all&permthid=t... 1/2 <br />