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S~BY~ 2-21-96 ;10=58AM ; WSC/FPD-' 303 832 8106;# 2/ 2 • underground mining in the mine permit area. Both of these inventories testify to the low site density that can be expected for the permit area as a whole. The "no effect" concurrence for the Mt. Gunnison Permit ql was conditioned with a stipulation concerning subsidence. Review of subsidence information on completed mining indicates that it is not a problem thus far, with minimal surface disturbance noted. It is anticipated Chat, given the depth of the overburden, subsidence will continue to be minimal for most of the permit area but with increased subsidence anticipated in those areas where the B seam will be recovered. Given the steeply sloping nature oP t~xe most of the permit area, limited suitable human habitation area, and the low density of archaeological sites we feel that the potential to impact significant cultural resources from subsidence is minimal. We also feel that additional archaeological inventory is unwarranted at this time and a continuation of the "no effect" determination, with enclosed conditions concerning unanticipated finds and subsidence, is in order for this proposed mine plan modification. The Office of Surface Mining Reclamation and Enforcement will closely monitor subsidence particularly in the areas where the mining of seams will overlap and will follow through with the subsidence stipulation. We seek your concurrence with our recommendations and a continuation of a "no effect" determination with conditions if second seam mining and the addition of 36 underground acres is approved. Should you have any questions, please call Foster Kirby, Archaeologist, at 844-2618. I CONCUR WITH THE ~~ Sincerely, ~~ Pa111 Heitzenr ter Chief Biological Sciences Branch 1 5 DEC x':,89 cc. R.Holbrook, FPD enclosures