2012-06-20_PERMIT FILE - C2010089A (8)

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that have been impacted by agricultural activities. The 1979 report acknowledges the "surface of Site 5MN1258 has been virtually destroyed by previous cultivation activities" resulting in a "severe loss of contextual integrity" with respect to this and other sites that are associated with improved agricultural practices. In summarizing the conditions associated with Site 5MN1257, which corresponds to a largely undisturbed Sagebrush site, this report concludes that even these areas "appears to have experienced some wind deflation and sheet erosion." In describing the original study area, the report states "the southern portion of the site has been disturbed by activities or unknown origin; the western portion of the site by ranching operations; and the eastern portion by a road; and the northern portion by a dirt road." Regarding the potential need for additional surveys being conducted in this area, the report concludes that "for much of the study area, ground visibility was very poor due to the heavy vegetative cover or grass, alfalfa and wheat." In fact the report acknowledges the problems associated with this site by stating that the low laying drainage areas "consists of marsh areas indicative of a high water table. This small marshy area was not surveyed because of the soggy ground conditions and heavy plant growth." The cultural resources report completed on New Horizon 2 (NI-12) Mine Tracts I and II for PCC in 1986, further documents the problems of performing cultural resource surveys on disturbed agricultural lands. This report states that no cultural resources were found on areas that had been "cultivated, grazed, or otherwise denuded of native vegetation ..." According to this report, these areas could not be adequately surveyed on foot and these areas were surveyed by "vehicular reconnaissance." This report also acknowledges the problems of conducting surveys in "the bottoms of some of the larger drainages ... covered with dense thickets of cattails." The most recent cultural resource survey conducted on the existing NH2 Mine areas was preformed in 1988 on what was called the Tracts IIA and III area, located on Tuttle and Calamity Draws in the northeast and southeastern part of the existing mine area. This report acknowledges that both of these tracts would be considered as "primarily agricultural acreage" and that this area consists "almost entirely of disturbed land mostly of an agricultural nature." This report states that with respect to Tract IIA, this area has been "extensively disturbed by habitation and agricultural activities." The report states that nearly all of the site "had been leveled or cultivated." With respect to the bottom of Calamity Draw, it states that the "land along the drainage is swampy in nature and supports a dense growth of grasses which obscures the ground surface." This report concludes by stating "the survey results at this tract are consistent with those Tucker found in his 1986 coverage of adjacent Tract II. If once present at all, any remains of prehistoric materials have been obliterated or obscured by land use activities. On the other hand, a subjective observation is that the acreage within Tract IIA does not possess a medium or high probability of prehistoric occurrence." This report contains the following recommendation, "given the results of the survey of Tract IIA, it is impossible to add to any interpretation of historic or prehistoric utilization of this land." Section 2.04.4 Page 3 April 2011