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believes they are inherently non-significant and recommends a finding of "no historic properties <br />affected" and recommends that there is no additional cultural resources work necessary for these <br />sites. <br />At the time of this NOI submittal, ,exploration sites CCU025 and CCU027 - CCU033 need <br />cultural/archeological resource clearance. It is anticipated that MAC will complete the cultural <br />resource inventories at these eight sites as soon as ground conditions allow for site access (early to <br />late May). The cultural resource inventories for sites CCU025 and CCU027 - CCU033 will be <br />submitted to CDRMS and State Office of Archaeology and Historic Preservation upon completion. <br />Table 2, Cow Camp Project - 2008 Exploration Program Drillhole Specifications, summarizes the <br />status of the cultural resource inventory for each exploration site. Based on recent cultural resources <br />surveys in the project area (completed for both this NOI drilling program and the 2007 Exploration <br />Program [NOI X-2007-229-00]), MAC considers historic and prehistoric sites, and/or isolated finds a <br />possibility. However, based on previous work and the isolated nature of the area, it is not anticipated <br />that sites of significant cultural interest or potentially eligible for listing on the National Register of <br />Historic Places will be identified. <br />CCR requests that CDRMS consider a three phase approval process for conducting the Cow Camp <br />2008 exploration activities. <br />• Phase I includes exploration sites CCU013 - CCU022. These nine sites are on lands with <br />executed surface access agreements (see Appendix A), fully leased or fee coal resources and <br />completed cultural resource inventories (see Appendix D). Exploration activities at these nine <br />sites can be initiated upon receipt of the necessary approvals (CDRMS, State Land Board, <br />Routt County Board of County Commissioners and BLM). <br />• Phase II involves sites CCU028, CCU029 and CCU032. These exploration sites are on lands <br />with full surface and coal access, but lack a completed cultural resource inventory (as of the <br />submittal date of this NOI). Exploration activities at these sites will not start until the <br />cultural resource inventory has been completed and approved by CDRMS and the State <br />Office of Archaeology and Historic Preservation. <br />Phase III covers exploration sites CCU012, CCU019, CCU023, CCU024, CCU025, <br />CCU027, CCU030, CCU031 and CCU033. These nine exploration sites are on lands with <br />surface use access, but unleased federal coal. A Federal Coal Exploration License <br />application has been submitted to BLM to conduct exploration activities at these nine <br />locations. Exploration activities at these nine sites will not start until BLM issues a coal <br />exploration license, and in the case of sites CCU025, CCU027, CCU030, CCU031 and <br />CCU033, cultural resource inventories are completed and approved by CDRMS and the State <br />Office of Archaeology and Historic Preservation. <br />5) Describe Exploration Activities <br />Proposed Exploration Activities: The primary methods of exploration and geologic and chemical <br />data collection proposed in this application include exploration drilling, geophysical logging, and <br />sampling, followed by reclamation of all exploration disturbances, as more specifically described in <br />the following sections. <br />CCR anticipates drilling 15 exploration drillholes during 2008 and the remaining 6 exploration <br />drillholes during 2009 to further delineate and characterize geologic conditions, coal seam occurrence <br />and quality, and overburden physical and chemical characteristics. The drillholes are designated as <br />Cow Camp Project - 1008 NO/ <br />J//S/OS <br />