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P111 OFFICE of ARCHAEOLOGY and HISTORIC PRESERVATION August 15, 2008 Berhan M. Keffelew Environmental Protection Specialist Division of Reclamation, Mining and Safety Department of Natural Resources 1313 Sherman Street, Room 215 Denver, Colorado 80203 b11, k RECEIVED /uG 2 0 2008 *0 ?7 . Division of Reclamation, 76 Mining and Safety RE: Cripple Creek & Victor Gold Mining Company, Cresson Project, Permit No. M-1980- 244 CHS # 52311 Dear Mr. Keffelew: Thank you for providing the application documents regarding the captioned project to Dan Corson and me immediately following the July 31, 2008 meeting including representatives from the Division of Reclamation. Mining and Safety [DRMS] [Ronald W. Cattany, Tony Waldron, David Berry, and you], Jeff Fugate from the Attorney General's Office, and Dan Corson and me from the Colorado Historical Society Office of Archaeology and Historic Preservation. We are prepared to offer comments on the application and do so both as a party interested in this matter pursuant to DRMS regulations and under the provisions of the State Register Act, CRS 24-80.1- 101 tol08. Our first comments are with respect to the piece of the Cripple Creek National Historic Landmark District [5TL.2] that is included within the affected area to be mined. The National Register nomination form states that, "The [historic district] boundary is established by points of elevation surrounding the town of Cripple Creek in order to provide the discrete natural setting reminiscent of the historic environment." Since National Historic Landmarks are a subset of the National Register, and National Register properties are by state statute listed in the State Register, we urge that special attention is given to this piece to avoid impacts and contour changes, or if the contours have already been changed, to plan restoring them to their historic configuration. It is unfortunate that the maps provided in the application do not demarcate this area listed on the State Register of Historic Properties, but we infer that the proposed mining area overlaps the historic district in the central portion of Section 18, T.15 S. R. 69 W. It appears that two of the historic mining structures listed in Attachment 7 of the applicant's submission to Teller County are within the boundaries of the National Historic Landmark District. These two structures are the relocated Deadwood Headframe [5TL.283] and the Ore Sorting House adjacent to the Simms Mine for which there is no cultural inventory form on file with our office. Should the proposed permit extension affect these structures, we anticipate further consultation with this office under the provisions of the State Register Act. Second, we would like to address reclamation plans. As we mentioned in previous correspondence to you, the mining landscape included in and surrounding the Cripple Creek National Historic Landmark District is an important component of its historic significance and integrity. During our meeting on July 31, 2008 meeting DRMS staff indicated that it requires that "an approximate original contour" is its goal when reviewing and approving reclamation plans. We urge that this principle is followed in this case in order to minimize any adverse effects on the national historic landmark district's visual setting. 1300 BROADWAY DENVER COLORADO 80203 TEL 303/866-3395 FAx 303/866-2711 www.coloradohistory-oahp.org