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• - 6 - SE 1/4 SW 1/4, Section 29, TSN, R86W S, 1/2, Section 20, TSN, R86W except mined areas and NW 1/4 SW 1/4 Generally, most of the locations never surveyed correspond to areas which have been mined or otherwise disturbed. In additioq, two of the surveys included in the mine plan were no[ designed as intensive (100%) inventories. Olson's survey only included "feasible locations for occupation" and it is stated that vegetative cover inhibited 100`: coverage of the areas specified. Areas not surveyed are not identified in his report. The LOPA survey was designed as a reconnaissance, no[ a 100: survey. Survey efforts were directed prlmarilp to localities where it was felt sites were likely to occur. Areas not surveyed by LOPA are indicated on the map in the LOPA report. The BLM surveys of coal leases C-22644 and C-26913 were asserted to be 1007, surveys but were actualy limited to terraces above drainages within the lease boundaries. Areas with heavy grass ground cover or other vegetative cover were not surveyed. The areas actually surveyed were delineated on [he map provided to th±s office by Sherry Hansen, BLM. It is concluded [hat some doubt remains as [o [he adequacy of the cultural resouces coverage. (b) Energy Fuels states that there are ". no known cultural or historic resources listed or eligible for listing on [he National Register of Historic Places within the mine plan or adjecent areas." This determination was made without consultation o•i[h [he Stale Historic Preservation Officer (36 CFR 800.4). There is no indication in [he mine plan that the State Archaeologist was consulted by the BLPt for a determination on the results of the LOPA survey, the BLK surveys or Olson's survey. Therefore, OSM consulted with [he State Historic Preservation Officer (attachment /;3). The State Historic Preservation Officer concured in OSM's evaluation of site eligibility and with OSM's proposal to approve the mine plan with certain stipulations (attachment ;;4 ). The SHPO determined that if the mine plan had these stipulations there would be a "No Effect" determination pursuant to 36 CFR 80.4(b)(1). (c) 779.24(1) The intention of Map 5 of the mine plan, titled "Histoical and Archaeological Resources" is to show the locations of cultural resources in the mine plan area. Smithsonian site numbers are not given on the map, making coordination with [he text of the mine plan and the archaeological reports difficult. Two sites recorded bti• LOPA, sites SRT33 and SRT34, are not on the map. Historic sites EF-001 (SRT35), EF-002, EF-003 and F,F-006 were plotted on Map 5 by OSM. P.reas surveyed within [he mine plan area do not appear on Map 5. A map was prepared by [he consultant to assist in [h~ technical analysis which shows areas encompassed by the archaeological reports and site locations.