PERMFILE42025

• Permit No: X200621401
• IBM Index Class Name: Permit File
• Doc Date: 6/1/2006
• Doc Name: NOI Application
• From: BTU Empire Corporation
• To: DMG
• Media Type: D
• Archive: No

MAC
Metcalf Archaeological Consultants, Inc.
May 5, 2006
Jerry Nettleton
Twentymile Coal Company
29515 Routt County Road 27
Oak Creek, CO 80467
re: Empire BTU 2006 core hole program
Dear Jerry,
I have reviewed the maps and aerial photo coverage of [he.ptoposed Empire BTU 2006 coring program,
which includes ten proposed core hole locations along Colorado Highway 13 approximately seven miles
southwest of Craig, Colorado, in Moffat County (see attached location map). I understand that these core
holes will all be drilled from private or State-owned surface, and that all are exploring private or State-
held coal deposits. I also understand that there is no federal agency involvement in the project, and thus
section 106 of the National Historic Preservation Act does not apply.
Because there is some State surface and mineral ownership, Colorado state law governing protection of
antiquities may apply. However, this requires only that the state take into consideration affects to known
cultural resources, and does not require any inventory to determine whether unlmown cultural resources
may be present.
Based on aerial photo information and information provided by Scott Cowman, Environmental Specialist
for Twentymile Coal Company, it is also clear that six of the proposed core holes (PDS-06-01 through
PDS-06-0S, and PDS 06-08) are located in areas that have been completely disturbed by prior and
ongoing mining activity which has completely negated any potential for intact Holocene sediments at
these locations, and thus also negated any potential for intact cultural resources. The remaining four core
holes (PDS-O6-06, -06-07, -06-09, and -06-10) are located in fields that have been and continue to be
actively cultivated, and thus the surface has been completely disturbed with no potential for intact
cultural resources in the plow zone.
I conducted a files search on the Office of Archaeology and Historic Preservation's Compass On-line
Database on May 4, 2006. In a search of sections 29, 30, 31, and 32 of T6N R91 W, within which all ten
core holes are located, a total of 37 cultural resources have been recorded. Of these, 1 S are isolated finds
and are not considered further. Isolated finds are, by definition, not eligible for the National Register.
The remaining 22 resources are sites, of which only seven are located in the same quarter sections as the
proposed core holes. These are listed in the table a[ the end of this letter.
Six of these sites are located some distance from the nearest core hole and will not be impacted (most of
these sites have or have probably been destroyed by recent Honing activity). Only SMF442 is located at
or near one of the core holes, but it has been reported by previous investigators to have been destroyed or
totally disturbed, and thus will not be impacted by the proposed coring.
[phone] ~ - [phone]
FAX: [phone] - ~ ~ FAX: [phone]
P.O. Box 899 P.O. Box 2154
Eagle, CO 61631 Bismarck, ND 58502
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