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<br />Permit Application. On the other hand, if the reference is to surface mining <br />facilities and disturbances, which will affect about ten sites, the three sites <br />warthp of further testing and delineation are not involved since they will not <br />be directly impacted (see response to next OSM comment below). <br />As discussed in the report, Site 5RB 1059 is not a prehistoric rock art site but <br />is, rather, an historic site. Furthermore, irregardless of a site's age, there <br />is no compelling assumption to suppose a priori that all prehistoric rock art <br />should be considered eligible to the National Register of Historic Places, as <br />the reviewer seems to conclude. <br />Archaeological sites recorded as part of the Moon Lake Project have been <br />evaluated in terms of the National Register criteria as set forth in 36 CFR <br />60.6, and we do not feel reevaluation is necessary. Neither do we feel a <br />designation as a National Register District is warranted in this case. In this <br />contest, our report on impacts to cultural resources resulting from development <br />o£ the Deserado Mine includes a discussion of the scientific importance of <br />sites, even those which do not qualify for inclusion on the National Register. <br />Additionally, a recommended program of mitigation for all affected sites was <br />offered in that report. It is our understanding that the eventual Memorandum of <br />Agreement on this topic between BLM and the SHPO for the Moon Lske Project will <br />include measures to mitigate adverse impacts to such resources. <br />U IF TESTING MUST BE PERFORMED ON THE THREE SITES IDENTIFIED AS WORTHY OF FURTHER <br />CONSIDERATIONS TO DETERMINE THEIR ELIGIBILITY FOR NOMINATION TO THE NATIONAL <br />REGISTER OF HISTORIC PLACES, THIS TESTING SHOULD BE COMPLETED. THE CONCLUSION <br />REACHED AS A RESULT OF THIS TESTING MUST BE IN AGREEMENT WITH THE COLORADO <br />HISTORIC PRESERVATION OFFICER. IF THESE SITES ARE ELIGIBLE FOR THE NATIONAL <br />REGISTER APPROPRIATE DOCUMENTATION MUST BE PROVIDED BEFORE OSM CAN COMMENCE THE <br />SECTION 106 CONSULTATION PROCESS. <br />As a result of the earlier survey by Pioneer Archaeological Consultants and the <br />work of Nickeas sad Associates, eight sites were designated as needing further <br />evaluation to finalize National Register significance. Three of these sites, <br />5RB 1008 (Nickens and Associates) and 5RB 859 and 922 (Pioneer Archaeological <br />Consultants) are located in the mining permit boundaries. These sites are <br />described as follows: <br />5RB 1008 consists of a buried basin-shaped hearth, located 1.9 m beneath the <br />present ground surface. The hearth was exposed by a backhoe. Only a single <br />flake was found on the present ground surface above the hearth, and its <br />association with the hearth is tenuous. A radiocarbon sample obtained from <br />charcoal in the hearth yielded a date of 3440 B.C. +210. It seems that the <br />entire site is buried, and the paucity of artifacts on the ground surface is no <br />indication of the site's horizontal extent. The backhoe trench exposed too <br />small as area of the site to provide sufficient data with which to judge the <br />site in terms of National Register criteria. Accordingly, more data is needed <br />prior to determining the site's significance. <br />5RH 859 is an extensive site consisting of thirteen concentrations of aboriginal <br />and recent cultural remains and other scattered cultural debris. Ten of these <br />1050 5 <br />