2023-02-03_REVISION - C1981010 (5)

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KC116 �. History Colorado Graham Roberts Environmental Supervisor Trapper Mining Inc. P.O. Box 187 Craig, CO 81626 RE: Trapper Mine (Permit No. C-1981-010)Permit Revision Application No. 11 (PR-11)PR-II 5-Year Mine Plan Update (HC4 67393) Dear Mr. Roberts, Thank you for your correspondence received by our office on January 17,2023 continuing consultation for the above referenced undertaking under Section 106 of the National Historic Preservation Act (NHPA)and its implementing regulations 36 CFR 800. We appreciate the documentation provided for our review in response to our recommendation that a cultural resource specialist that meets the Secretary of the Interior's Standards (SOI) complete a class III cultural resource inventory in the area of potential of effect(APE). The provided documentation notes that the APE has been previously inventoried as well as previously disturbed by mining activities. While we agree that some of the APE has been previously disturbed by mining activity, a review of orthoimagery shows that areas proposed for disturbance in the J-Pit as well as proposed expansion areas in the L-Pit remain relatively undisturbed. This is further supported by the provided documentation that notes that the proposed expansion of the L-Pit would extend beyond the current areas of disturbance. An initial review of our records shows that the majority of these areas have not been inventoried by a cultural resource specialist in over 30 years. These inventories do not meet current standards. Previous research has shown a high potential for the area to contain previously unidentified cultural remains. In particular,two inventories completed in the location of the I-Pits in 2020 resulted in the identification of a relative high frequency of previously unidentified cultural resources that include at least three historic properties. The APE has the potential to contain previously unidentified cultural resources including archaeological remains and the undertaking has the potential to affect these types of cultural resources. As a result,we continue to recommend that a class III cultural resource inventory be completed by a cultural resource specialist who meets the Secretary of the Interior's Standards prior to construction activities to determine the presence of previously unidentified cultural resources within the locations discussed above. The cultural resource specialist should also assess the eligibility of the resources for the National Register of Historic Places and assess the undertaking's potential effects to these resources. This level of effort is recommended in accordance with 36 CFR 800.4(b)(1). Upon completion of the appropriate identification efforts,our office should be provided with the results of the cultural resource inventory for review of professional adequacy and compliance with regulations,as well as to evaluate the appropriateness of the recommended effect finding. We look forward to continuing consultation for the subject undertaking. We request being involved in the consultation process with the local government,which as stipulated in 36 CFR 800.3 is required to be notified of the undertaking, and with other consulting parties. Additional information provided by the local government or consulting parties might cause our office to re-evaluate our eligibility and potential effect findings. Please note that our compliance letter does not end the 30-day review period provided to other consulting parties.