PERMFILE101811

• Permit No: M1993041
• IBM Index Class Name: Permit File
• Doc Date: 7/21/1993
• Doc Name: SU-93-14 DOWE FLATS MINING & RECLAMATION PROJECT
• From: BOULDER CNTY HEALTH DEPT
• To: ROB HELMICK
• Media Type: D
• Archive: No

INDIAN PEAKS CHAPTER •
O F THE ~~~~~~
COLORADO
ARCHAEOLOGICAL .
SOCIETY
D4r. Rob Helmick, Staff Planner
Boulder County land Use Department
Post Office Box 471
Boulder, CO 80306
Dear Mr. Helmick:
•
August~~~~~ ~/
k~~~ ~~
04199
~4A/D USE DEPT
The Executive Boazd of the Indian Peaks Chapter of the Colorado
Archaeological Society would like to go on record as having serious concerns
about the impact of the proposed Dowe Flats Mining and Reclamation Project
(SHB AGRA Project E92-7075, June 1, 1993) on the prehistoric resources in the
project azea. We feel it is imperative to have appropriate measures in place to
deal with the non-renewable cultural resources located in Dowe Flats before a
permit for mining and subsequent reservoir development is granted.
The applicant, Southwestern Portland Cement, has detailed the extent of the
problem in their "Application for Boulder County Special Use Permit and Site
Specific Development Plan For Mining and Reclamation--Dowe Flats":
Based on these recent surveys and research of archaeological site files
and literature, it is well documented that Dowe Flats had been
intensively occupied for thousands of years by Indian peoples....ln
studying the archaeological history of Dowe
Flats, one is impressed with the number of prehistoric artifacts that
have been collected and removed from the area since historic
settlement began. Despite this irretrievable loss, archaeological
resources still exist. (Page 48)
Through the cumulative effects of collecting, defacing, development,
plowing, and other disturbances, the prehistoric resources of north-
central Boulder have been diminished. The state of archaeological
resources is regrettable both in terms of the loss of significant amounts
of material, and the integrity of what remains. As archaeological
resources become increasingly diminished, the long term conservation
of the remaining resources becomes even more significant. (Page 49)
The extent of subsurface cultural material in the area to be mined is unknown
because no testing has been done in the area to be mined. The proposed
mining operation is not located in the area of presently documented sites.
However, acknowledging the probable existence of significant buried data,
Southwestern Portland Cement proposes monitoring during mining operations
and the establishment of a Cultural Resources Management Plan (Page SO of
the permit application).
We concur with Southwestern's plan of avoidance when possible, and
monitoring of ground disturbing activities when they occur. However, a
comprehensive plan must be implemented now for data retrieval because the
eventual reservoir will destroy any remaining cultural material. The
"Proposed Cultural Resources Management Process" (Permit application Table
5.5.G-2) outlined by Southwestern lacks a timeline and specific details of
P. O. Box 18301, Boulder CO 80308