2015-11-19_REVISION - C1982056

• Permit No: C1982056
• IBM Index Class Name: Revision
• Doc Date: 11/19/2015
• Doc Name: Response
• From: BLM
• To: Mark Tabias
• Type & Sequence: PR10
• Email Name: JLE
• Email Name: DIH
• Media Type: D
• Archive: No

11/20/2015 State.co.us Executive Branch Mail -Re: Subsidence Effects to Archaeological Sites in the Twentymile Mine
STATE, OF Hernandez - DNR Alysha <alysha-hernandez@state-co-us>
COLORADO'
Re: Subsidence Effects to Archaeological Sites in the Twentymile Mine
1 message
Naze, Brian <[e-mail]> Thu, Nov 19, 2015 at 4:35 PM
To: "Tobias - HC, Mark" <mark.tobias@state. co. us>, Brian Naze <[e-mail]>
Cc: "Ebert - DNR, Jared" <[e-mail]>, Alysha Hernandez - DNR <[e-mail]>,
Jennifer Maiolo <[e-mail]>
Hi Mark, et al.
Mark, I will do my best to respond to your e-mail regarding subsidence at the Foidel Creek Mine and the
proposed Sage Creek Mine (both of which are owned by Peabody). DRMS is the lead agency for consulting
with SHPO about the potential effect of subsidence on historic and prehistoric sites that may result from the
permit revisions, etc. involved in the proposal to mine the Wolf Creek seam at the Foidel Creek Mine. BLM -
LSFO will be the lead agency when consulting with SHPO in the future about the effects of subsidence at the
proposed Sage Creek Mine. Putting this mine into production in the years to come will require acquisition of one
or more federal coal leases that would be issued by BLM.
BLM's consultation with SHPO regarding the Sage Creek mine was "put on a back burner," but I hope to
facilitate completion of the consultation process by the end of December. Jennifer informs me that Peabody's
plans to develop the Sage Creek mine are currently on hold. Because of this, I turned my attention to more
pressing matters in recent weeks. As you mentioned, Metcalf Archaeological Consultants (MAC) is
recommending a case study that documents the condition of eligible prehistoric sites in open terrain before and
after subsidence in order to provide an evidence -based assessment of exactly what (besides a decrease in
elevation) are the effects of subsidence on sites, if any. Your e-mail is timely because if the necessity of a
case study is to be decided by the current LSFO management, it needs to happen sooner rather than later.
have discussed the proposed case study with Assistant Field Manager Tim Wilson, but he is leaving LSFO at
the end of the week to accept a position in Wyoming. I have yet to discuss the matter with Field Manager
Wendy Reynolds, but plan to do so in the near future. She will be retiring at the end of December.
Your e-mail implies that the MAC report for the Sage Creek Mine may have useful information to help SHPO
consider the effects of subsidence of sites at the Foidel Creek Mine. The report does have a discussion of
subsidence resulting from Iongwall mining and from information in the report, one might suggest that concerns
about subsidence are less in the center of the mined area where subsidence is uniform in comparison to areas
around the periphery of the mined area where the "angle of draw" will affect the degree of slope. If you think the
report would help you to consider the effects of subsidence on sites at the Foidel Creek Mine, I could ask MAC
to e-mail you an electronic version of the final report. I do not have an electronic version. Let me know.
will call you about this next week, but since you included me and the Sage Creek Mine consultation in your e-
mail discussion with DRMS about the Foidel Creek Mine, I felt obliged to respond in writing.
Bye for now.
On Wed, Nov 18, 2015 at 1:01 PM, Tobias - HC, Mark <mark.tobias@state. co.us> wrote:
Jared:
Thanks for forwarding Metcalf s analysis of potential effects associated with Twentymile's Wolf Creek Seam
project. Unfortunately, our office has not yet received a copy of the report titled "Peabody Sage Creek LLC: A
Class III Cultural Resource Inventory of the Sage Creek Subsidence Expansion Area, Routt County, Colorado
(2013, revised April 2015) from BLM Little Snake. And as this report appears somewhat central to Metcalf s
letter and as it may inform this consultation, I've copied Brian Naze, the Little Snake FO archaeologist, in my
response. I will also say that while Brian and I have informally discussed the possibility of baseline subsidence
studies as terms of mitigation for the Sage Creek Expansion which Metcalf recommends as worthwhile, no
hftps://mail.google.com/mail/u/0/?ui=2&ik=e29129fcb5&vi ew=pt&search= i nbox&th=151221 a57896659d&si m 1=151221 a57896659d 1/3