2008-02-22_APPLICATION CORRESPONDENCE - C2008086 (42)

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Undertaking Description: Proposed Red Cliff Mine Project in Garfield and Mesa Counties, Colorado BLM CRIR GJFO 1106-11 The Area of Potential Effect (APE) for the exploration is relatively small but anticipating the need for additional information for EIS analysis CAM Colorado LLC contracted Grand River Institute to conduct a Class III cultural resource inventory to evaluate the entire area that would be potentially affected by the surface operations of the mine. A total of 2,220 acres were surveyed; 1,940 acres of BLM land and 280 acres of private land. The surface disturbance from the exploration phase of this undertaking involves road construction and drill exploration used to design the proposed facilities for the Red Cliff Mine. Existing roads, an upgraded portion of an existing road, and overland travel would be used to access the drill sites on BLM managed lands. Drill sites are ioeated immediately adjacent to roads or at the terminus of overland travel There are no related structures or facilities during the exploration phase. The surface disturbance from the development of the mine will be significant. CAM is proposing a new portal and associated facilities to extract low-sulfur coal from Federal Coal Leases C-0125515 and C-0125516 and from several potential new Federal leases as well as a small amount of private coal. The proposed railroad line would traverse approximately 9.5 miles of Federal land, and include one crossing of State Highway 139 and approximately 5 miles of private land. The EIS will analyze the potential impacts associated with the construction and operation of facilities proposed in CAM's Right-of--Way and Land Use Applications, and other potential impacts associated with the Red Cliff Mine project. Twenty-one Isolated Finds (IF) were recorded. By definition IFs are not eligible for nomination to the National Register of Historic Places (NRHP). A total of eight sites were recorded; six prehistoric sites, one historic site, and one site with both a prehistoric and historic component. During the inventory survey phase one site, SGF3880, was tested with BLM's permission to determine eligibility. The final evaluation was that four prehistoric sites were evaluated as NRHP eligible under criterion "d"; SGF3878, SGF3879, SGF3880, and SME15398. The remaining four sites were evaluated as not eligible. Detailed documentation of the findings and evaluations is enclosed. Sites SGF3878, SGF3879, and SME15398 are outside of the APE for exploration. SGF3880 will be avoided during exploration phase by incorporating the following mitigation. A Colorado BLM permitted archeological consultant must be present to monitor and ensure the avoidance of SGF3880 during any work associated with the overland travel that is proposed to access drill sites #6 and #8. Following overland use from the end of the existing route hand tools should be used to obscure the vehicle tracks to avoid the public from extending the existing route and thereby creating a new 2-track road which would impact the site. Any changes in drill location or access routes will require review by the archaeologist prior to authorization. Only two of the eligible sites are within the APE from the proposed development of the mine. SGF3880 is located between the proposed conveyor, the waste rock disposal area, and the Unit Train Loadout. As currently located in the preferred alternative it will be avoided but may require monitoring during conveyor construction. A different location for the waste rock disposal area is anticipated as an alternative in the EIS because of habitat concerns identified by the Colorado Division of Wildlife in the scoping phase. If the design changes in this area of the mine project and facilities cannot avoid the site a testing plan to determine if any remaining cultural deposits are present will be developed and submitted for review through additional consultation with your office. SME15398 will be avoided by the mine project but because of it's location overlooking the train loadout, it may be affected by secondary impacts associated with off highway vehicle use or changes in the current BL"v1 transportation plan in this area of the North Fruita Desert Planning Area. If the road is not closed as a result of the mine development secondary impacts will be avoided by fencing the road along the site boundary. Sites SGF3878 and SGF3879 are located east of the mine entrance access road and are isolated by terrain. They will be avoided. DBMS 381