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,, • • -3- C. Summary of Compliance The applicant will continue to be.. in compliance if all stipulations in • Section F are adhered to. OSM will be in compliance when the Colorado SHPO concurs in a "No Effect," "No Adverse Effect" determination. H. Proposed Departmental Action The Secretary could approve the Munger and ilcClane Canyon plans with the proposed special stipulations and pending the Colorado SHPO concurrence on a "No Effect," "No Adverse Effect" detezmiration. I. Residual Impacts of Proposed Departmental Action The three identified cultural resource sites under the current mine plan will not be directly impacted by mining operations; however, they may be indirectly impacted by the proposed departmental approval of the plan. Two of the sites are currently recommended as being eligible and their determination of eligibility is undergoing review. Unknown cultural resources With potential information may also be destroyed by applicant activities or as a result of increased population. Adverse impacts to unknown cultural resources through vandalism and unauthorized collection can be anticipated. An anticipated beneficial effect will be the preservation of cultural data associated with sites SGF741,'SGF74 2 for future study. As cultural resource inventories continue to be conducted in the region, it is expected that discoveries regarding ptehistoric utilization of the region will allow for the formulation of detailed research designs through which to organllze the focus of data recovery and analysis. Preservation of the integrity of both SGF741 and SGF742 will allow a future analysis to be conducted utilizing more refined and sophis[Sca[ed archeological techniques and methods within a strongly based theoretical framework. J. Alternatives to the Proposed Action One alternative is not to build the lfunger and 11cClane Canyon Mines and thus no cultural resources would be directly impacted. A second alterative would be to instigate a full data recovery program at sites SGF741 and SGF742, thus preventing anticipated loss of data through natural processes and/or unauthorized disturbance. However, the beneficial effects of site preservation would not be realized. Since site avoidance and protection is easily accomplished, data recovery at this point in time is not considered to constitute a prudent management alternative. The avoidance alternative (implementing stipulations in Section F) will allow the applicant to proceed and allow OSM to comply with all applicable federal legislation and regulation. The avoidance alternative is the preferred one.