2008-08-07_APPLICATION CORRESPONDENCE - C2008086

• Permit No: C2008086
• IBM Index Class Name: APPLICATION CORRESPONDENCE
• Doc Date: 8/7/2008
• Doc Name: Adequacy Review ‎(Interoffice Memo)‎
• From: Kent Gorham
• To: Mike Boulay
• Email Name: KAG
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
A
1313 Sherman St., Room 215
Denver, Colorado 80203 C O L
:?
A D O

Phone: [phone] D I V
I N O F
RECLTION
FAX: [phone] MINING
Interoffice Memo F
SA
TY
To: Mike Boulay Bill Ritter, Jr.
Governor
From: Kent Gorham Harris D. Sherman

CC: Sandy Brown Executive Director
Ronald W. Cattany
Date: August 7, 2008 Division Director
Natural Resource Trustee
Re: Permit Application Adequacy, Red Cliff Mine , #C-2008-086
have completed my review of Rule 2.05.6(6), Subsidence Survey, Monitoring, and
Subsidence Control for the Red Cliff permit application. Included in my review were permit
text in Volume I, pages 2.05-117 to 122, Exhibit 15, and Maps 9, 14, and 23. 1 also reviewed
the Cultural Resources permit text in Volume I and cultural reports in Volume VI for impacts
regarding subsidence. Where I have an adequacy issue, I phrased the question directly to
the applicant, included below in as numbered questions 1-8.
Rule 2.04.4 Cultural and Historic Resource Information
(1) The application shall contain a description of the cultural and historic resources
listed or eligible for listing on the National Register of Historic Places and significant known
archaeological sites existing on the date of application within all areas proposed or likely to
be affected by surface activities or planned or probable subsidence over the life of the mine.
The description shall be based on all available information, including, but not limited to, data
of State and local archaeological, historical, and cultural preservation agencies.
(2) The Division may require the applicant, for good cause shown, to identify and
evaluate important historic and archeological resources that may be eligible for listing on the
National Register of Historic Places through collection of additional information, conducting of
field investigations, or other appropriate analyses.
1. Subsidence has the potential, especially in areas of thin overburden, steep
slopes, and cliff outcrops to cause damage to cultural resources, including rock art.
rock shelters, and pictographs. From review of the maps in the Cultural Resources
section of Volume VI of the permit application package (PAP), it is not clear that areas
planned to be subsided were included in the cultural resources survey. Please
identify areas of potential rock art within the area to be subsided (affected area), show
them on a map, and submit the appropriate resource surveys for those areas so that
the Division can forward this information to the SHPO.
Office of Office of
Mined Land Reclamation Denver • Grand )unction • Durango Active and Inactive Mines