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Gary Isaac <br />CAM-Colorado, LLC <br />August 29, 2008 <br />Page 3 <br />Subsidence has the potential, especially in areas of thin overburden, steep slopes, and <br />cliff outcrops to cause damage to cultural resources, including rock art, rock shelters, and <br />pictographs. From review of the maps in the Cultural Resources section of Volume VI of <br />the PAP, it is not clear that areas planned to be subsided were included in the cultural <br />resources survey. Please identify all archeological resources including but not limited to <br />areas of potential rock art, shelters, and pictographs within the area to be subsided <br />(affected area), show them on a map, and submit the appropriate resource surveys for <br />those areas so that the Division can forward this information to the SHPO. <br />6. The application states on page 2.10-2 that "The Cultural Resources Inventory Report is <br />presented in Volume VI. The BLM withholds the locations of the sites from the <br />applicant." Also on page 2.05-116 CAM states "The applicant will have to work with the <br />BLM to assure these sites are preserved since the Applicant does not know the location of <br />the sites." <br />Please be advised that Rule 2.10(1) (g) requires that this map be submitted. Also, Rule <br />2.07.5(b) reads "Information in permit applications which pertains to the quantity of the <br />coal or stripping ratios, or the analysis of the chemical and physical properties of coal to <br />be mined (excepting information which the Division reasonably believes to concern a <br />mineral or elemental content which is potentially toxic in the environment) and <br />information on the nature and location of archeological resources on public and Indian <br />land (as required under the Archeological Resources Protection Act of 1971, PUB. L. <br />96-95, 93 State. 721, 16 U.S.C. 470) shall be kept confidential and not made a matter of <br />public record..." <br />Please submit the required map showing eligible cultural sites and sites to be avoided, <br />clearly labeling this map as CONFIDENTIAL, and revise the text on pages 2.10-2 and <br />2.05-116 accordingly. <br />Rule 2.04.3 General Requirements: Site Description and Land Use Information <br />7. Narrative on page 2.04-2 states that the land uses in the permit and adjacent areas are <br />Rangeland and Wildlife Habitat, which corresponds to the land uses indicated on Map-12 <br />Premining Land Use. Subsequent narrative on page 2.04-2 and 2.04-3 describes steep, <br />poorly vegetated Mancos shale slopes in the area to be disturbed by surface facilities as <br />Undeveloped Land; however these Undeveloped Land areas are not delineated on Map <br />12. Although the steep Mancos slopes are largely barren and are of low value for most <br />wildlife species, they are a natural component of the larger landscape that is used for <br />livestock grazing and provides wildlife habitat. As such, reference to portions of the <br />affected area as Undeveloped Land is not appropriate, and should be deleted, to be <br />consistent with the Land Uses indicated on Map-12.