2020-07-14_REVISION - C1981010

• Permit No: C1981010
• IBM Index Class Name: Revision
• Doc Date: 7/14/2020
• Doc Name: Correspondence
• From: History Colorado
• To: DRMS
• Type & Sequence: PR10
• Email Name: RAR
• Email Name: JLE
• Media Type: D
• Archive: No

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Robin A. Reilley, GISP
Environmental Protection Specialist
Division of Reclamation, Mining, and Safety
1313 Sherman Street, Room 215
Denver, CO 80203
RE: Trapper Mine (Permit No. C-1981-010) (HC# 67393)
Dear Ms. Reilley,
Thank you for your correspondence dated June 26, 2020 and received by our office on July 6, 2020 regarding
the review of the above referenced undertaking under Section 106 of the National Historic Preservation Act
(NHPA) and its implementing regulations 36 CFR Part 800.
After review of the documentation provided, we note that in accordance with the 1991 Memorandum of
Understanding (MOU) between our agencies, because the technical revision may incorporate additional lands
into the permit area or might otherwise alter previously approved permit conditions or mitigation measures,
concurrence between our agencies is required due to the potential for impacts to cultural and/or historic
resources. After review of the MOU, we note that not only was it signed 29 years ago, but the only
amendment (containing categorical exclusions) was made 17 years ago. We suggest that our offices collaborate
in the near future to assess the continuing usefulness of the MOU and the possibility of terminating the MOU
and creating a Programmatic Agreement or several Programmatic Agreements tailored to the specific needs of
the various resource types managed by your office.
The technical revision proposes expanding mining operations to approximately 206.7 acres. The technical
revision application may incorporate additional lands into the permit area or might otherwise alter previously
approved permit conditions or mitigation measures. As a result, impacts to cultural and historic resources must
be evaluated.
A search of the Colorado Cultural Resource Inventory Database indicates that twenty cultural resource
inventories have been conducted in the area proposed for mining expansion. While cultural resource
specialists have inventoried portions of the area, a high frequency of the area has not been inventoried and
approximately half of the previous inventories remain over 30 years old and not up to current standards.
Previous inventories have identified 47 cultural resources in or near the proposed expansion areas: 28 of the
previously identified cultural resources (5MF.445, 5MF.446, 5MF.475, 5MF.903, 5MF.904, 5MF.1130 -
5MF.1195, 5MF.4516, 5MF5138, 5MF.6377, and 5MF.6378) have not been officially evaluated for eligibility
on the National Register of Historic Places (NRHP); one resource (5MF.948) was determined eligible for the
NRHP; 14 resources (5MF.290, 5MF.348, 5MF.448, 5MF.449, 5MF.945, 5MF.946, 5MF.947, 5MF.950,
5MF.1202, 5MF.1399, 5MF.1960, 5MF.2253, 5MF.2427, and 5MF.7764) were determined not eligible for the
NRHP; one resource (5MF.7540.2) was determined as not supporting 5MF.7540 for the NRHP; and three
cultural resources (5MF.288, 5MF.447, and 5MF.1196) need data to determine if the resources are eligible for
the NRHP.
Our files contain incomplete information for this area and there is the possibility that as yet unidentified
cultural resources exist within the proposed mine expansion area. Further, previously unidentified resources
that have not been evaluated for eligibility on the NRHP could comprise historic properties. Due to the age
and paucity of previous inventories as well as the potential for previously unidentified cultural resources, it is
our recommendation that a cultural resource inventory be completed by a cultural resource specialist who
(-HISTORY COLORADO CENTER 1200 BROADWAY DENVER CO 80203