2016-03-29_REVISION - C1981010 (2)

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9 HISTORY March 22, 2016 Tabetha N. Lynch Environmental Protection Specialist Division of Reclamation, Mining and Safety 1313 Sherman St., Room 215 Denver, Colorado 80203 RECEIVE® MAR 2 9 2016 1 5AFEW Re: "Trapper Mine (Permit No, C-1981-010), Technical Revision No. 115 (TR -115), POhIT and Mine Plan Updates Including Selected 2015 Midterm Review (HC #67393) Dear Ms. Lynch: We received your correspondence dated March 3, 2016 on March 9, 2016 and a copy of the project area map showing the proposed disturbance expansion area on March 21, 2016 as requested by our March 18, 2016 email. While we have no comment regarding the post -mining topography changes proposed for the K Strike pit, we offer three comments for the 49.7 -acre disturbance area. First, it appears that the expansion is located within Section 5, Township 5N, Range 90W of the 6th Principal Meridian, yet the permit area (as per your letter) does not include this section. We request clarification regarding this apparent discrepancy. Second, while there are no known historic properties located directly within the proposed disturbance (expansion) area, the Recurve Rockshelter (5MF948)—determined eligible for listing to the National Register of Historic Places in august 1982—is located nearby, specifically on the south -side of the landform slated for mining. As Section 106 of the National Historic Preservation Act requires that the agency consider direct, indirect and cumulative effects that may result from its undertaking, we request that you provide supplemental information regarding potential indirect and cumulative effects associated with ongoing and proposed coal miring on this site. "Third, we are unable to determine whether prior historic property identification has occurred within the 49.7 -acre area proposed for disturbance. We request additional information regarding prior survey within this area. If this area has not been surveyed for historic properties in accordance with currently acceptable methodological standards, we recommend that DRMS complete supplemental identification within the 49.7 -acre expansion area. This comment may apply to other areas of the proposed Trapper Mine where historic property identification has not occurred and we request that you evaluate the adequacy of this survey. We request being involved in the consultation process with the local government, which as stipulated in 36 CFR 800.3 is required to be notified of the undertaking, and with other consulting parties. Additional information provided by the local government or consulting parties might cause our office to re-evaluate our eligibility and potential effect findings. Please note that our compliance letter does not end the 30 -day review period provided to other consulting parties.