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WFC submits that based upon this relatively high level of previous surveys and the fact that very <br />little material has been found, none of significance, there is realistically no reason why any <br />additional surveys need to be conducted in this area. Most of this site has been previously <br />disturbed by agricultural practices and there is insufficient justification for conducting additional <br />surveys in the area. Since there is only a very limited potential for cultural resources to be found <br />on these lands, "any remains of prehistoric materials have been obliterated or obscured by land <br />use activities ", there is no justification for additional cultural resource surveys to be conducted <br />within this proposed mine permit area. As summarized on Map 2.04.4, New Horizon North <br />Mine - Cultural Resources Map, the existing land use information as complied for Section 2.04.3 <br />Land Use, reveals that 79.7 percent of the existing vegetation has been entirely destroyed and <br />planted to a dryland or irrigated pasture. Wetlands consisting of dense cattails, willows and <br />other wetland species on mostly "swampy" ground correspond to 8.7 percent of the remaining <br />area. Virtually every cultural resource survey performed previously has indicated that it is not <br />practicable to survey these areas. <br />WFC acknowledges that the DRMS regulations at 2.04.4 "may require the applicant, for good <br />cause shown, to identify and evaluate important historic and archeological resources ..." Since <br />there has been such a high intensity of surveys previously performed on this site, without any <br />significant cultural resources being identified, WFC requests that the DRMS acknowledge that <br />there is no "good cause" or need for additional surveys being conducted in the area. The DRMS <br />acknowledged this situation on the West Panel portion of the existing NH2 Mine and waived the <br />requirement to perform a new survey specific to this site and given the high level of information <br />already collected from the proposed NHN Mine permit area, there is no justifiable reason why <br />those small remaining areas, not previously surveyed within the proposed NHN Mine permit <br />area, must now be covered by a new survey. Should unidentified archaeological resources be <br />discovered in the course of the project, work will be interrupted until the resources have been <br />evaluated in terms of the National register of Historic Places eligibility criteria (36 CFR 60.4) in <br />consultation with Colorado Historical Society. <br />Section 204.4 Page 4 April 2011 <br />