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Only 1 more day left to tell the Office of Surface Mining what kind of job the UT abandoned mine program is doing!
Why UT DOGM AMRP needs heightened oversight
By Russell D. Hartill JD
Chief Legal Officer for the National Historic Mining Initiative
NHMI represents a consortium of several non-profit organizations and groups dedicated to preserving and recording the history of Western American mining.
I am the Chief Legal Officer for NHMI, and am speaking both in my individual capacity as a mining historian, as well as an officer in an organization that cares deeply about the preserving of Utah's mining heritage.
I have been studying the history of mining in America since 1973.I am a co-author of Desert Fever, a 200 yr history of mining in the California Desert.
In reviewing the activities and projects of the UTAMRP, it is apparent that this agency needs heightened oversight by OSM of their reclamation program.
1. UT stands unique in being the only state claiming to have over 17,000 abandoned mines with 100% of these mines having significant physical safety issues and 100% of them also having evidence of environmental degradation. No other state in the West makes this claim. Having overstated the severity of non-coal hardrock mining features in need of remediation, UT has received a disproportionate amount of federal coal royalty dollars with which to spend in backfilling mining history in UT.
background: The Myth of 17K abandoned mines in UT: http://www.goldrushexpeditions.com/g...viewtopic&t=12
2. UT AMRP has focused on reclaiming non-coal hardrock mine features to the detriment of coal related projects. Seventy-five year old coal fires still burn in UT, yet UTAMRP continues to focus on non-coal hardrock remediation of any and all known mine features in the State.
3. UT AMRP is largely insensitive to mining history and is dismissive of groups who enjoy exploring and researching mining history.
Dismissive of groups:
UT AMRP insensitive to mining history:
+hats&sid=2831cdd97cda7f03f81a7e3e8a05c56f
How Much Experience Can You Get from One project? by Anthony A. Gallegos NAAMLP paper
Taking on the White Hats: Interest Group Opposition to Mine Reclamation
UTAMRP employees have published NAAMPL papers on streamlining the recordation process, claiming that mining history somehow can withstand less scrutiny and observation in situ. They have documented how one project experienced unexpected blowback from stakeholders and citizens.
We have observed UTAMRP attempt to streamline the public input process and eliminate the need for fully documenting project impacts to the mining landscape and history.
I am concerned that Sec 106 violations are occuring in UT in that substantial impacts to historic register capable sites and features are being erased in the name of public safety. UTAMRP does not allow contractors or consultants to examine underground mining features before during or after having made recommendations to backfill.
A National Historic Mining Initiative was first proposed by Eric DeLony (Chief and Principal Architect, Historic American Engineering Record, National Park Service, Washington, D.C.) in the 1990s, the Initiative was a response to the fact that while archeological remains are extensive, little is left of the extant surface structures of Western mining operations—the headframes, mills, cyanide plants and smelters that processed the ore extracted from the ground. Historic mining structures are threatened with government-wide reclamation programs that close abandoned mine openings and remove potential liabilities like old mill buildings and headframes. (Quoted in Death Valley to Deadwood, Kennecott to Cripple Creek: Proceedings of the Historic Mining Conference January 23-27, 1989 p
UTAMRP has documented several cases of inadvertent damage to cultural resources while conducting reclamation activities. [ Chris Rohrer, Death Valley to Deadwood, p. 85.] Curiously, Chris states in this report how a severe, but unanticipated adverse effect was mitigated. He later defined mitigation as the preservation of “key values of something at risk…even if the item itself cannot be saved.” He goes on to admit that Utah has used sub-HABS/HAER documentation to mitigate adverse effects several times, particularly when the value has low integrity. Lastly, the concept of anticipatory demolition is discussed as well (When the Big Picture is too Big: A Simpler Alternative to HABS/HAER, pp. 1, 3)
The Utah DOGM does not see itself in the role of nominating sites they inventory and document. The opportunity is left to others.
Whereas features below the ground hold much information about changes in mining practices through successive eras, but regrettably DOGM reclamation contracts prohibit consultants and contractors from documenting underground features and even entering the mines they are closing. See e.g. REQUEST FOR STATEMENTS OF INTEREST For Abandoned Mine Reclamation Program Reclamation Engineering and Design - San Francisco Project Solicitation Number NO7514, page 17 states clearly that “Archaeologists are not permitted to go underground. No underground surveys are required.” On Page 20 it is repeated that “No subsurface remains need to be evaluated.” On Page 30 it says “The following services and work are to be excluded from this contract, not considered WORK in this AGREEMENT, and/or will be completed by the OWNER: Environmental Assessment and compliance with Endangered Species Act, landowner consent for right of entry, any and all work requiring entering underground mine workings (this activity is extremely hazardous and is prohibited)…” However, the consultant is expected to assess the hazard potential of a mine feature without entering it-- Page 21: ”CONSULTANT shall assess the potential hazard and cultural significance at each mine feature and recommend the appropriate reclamation action… .” . Also of note is that DOGM specifically frowns upon securing a detailed cultural report from its consultants—page 17 “CONSULTANT shall research and write a historical overview of the project area. The historical overview must be sufficient to establish the necessary context to assess National Register eligibility. It should be based on a variety of information sources including local and regional libraries and museums. A lengthy treatise is not expected.”
NHMI efforts have been in securing photos, and videos of the current environmental status of cultural features before any further reclamation takes place. It may be important also to document the inventory and the reclamation itself, to ensure that the promises made by DOGM are in fact carried out. [They have assured the public that cultural resources will be protected, that work will stop if new values are discovered, yet in their own contract proposal procedures are in place and instructional guidelines are referenced on how a demolition would be conducted.]
One of our position papers and a consice summary of our ten goals can be found here:
Russell D. Hartill, JD
National Historic Mining Initiative
140 West 9000 South Suite 1
Sandy, UT 84070-2033
(801)561-4797
fax (801) 561-4798
russhartill@gmail.com
Why UT DOGM AMRP needs heightened oversight
By Russell D. Hartill JD
Chief Legal Officer for the National Historic Mining Initiative
NHMI represents a consortium of several non-profit organizations and groups dedicated to preserving and recording the history of Western American mining.
I am the Chief Legal Officer for NHMI, and am speaking both in my individual capacity as a mining historian, as well as an officer in an organization that cares deeply about the preserving of Utah's mining heritage.
I have been studying the history of mining in America since 1973.I am a co-author of Desert Fever, a 200 yr history of mining in the California Desert.
In reviewing the activities and projects of the UTAMRP, it is apparent that this agency needs heightened oversight by OSM of their reclamation program.
1. UT stands unique in being the only state claiming to have over 17,000 abandoned mines with 100% of these mines having significant physical safety issues and 100% of them also having evidence of environmental degradation. No other state in the West makes this claim. Having overstated the severity of non-coal hardrock mining features in need of remediation, UT has received a disproportionate amount of federal coal royalty dollars with which to spend in backfilling mining history in UT.
background: The Myth of 17K abandoned mines in UT: http://www.goldrushexpeditions.com/g...viewtopic&t=12
2. UT AMRP has focused on reclaiming non-coal hardrock mine features to the detriment of coal related projects. Seventy-five year old coal fires still burn in UT, yet UTAMRP continues to focus on non-coal hardrock remediation of any and all known mine features in the State.
3. UT AMRP is largely insensitive to mining history and is dismissive of groups who enjoy exploring and researching mining history.
Dismissive of groups:
UT AMRP insensitive to mining history:
+hats&sid=2831cdd97cda7f03f81a7e3e8a05c56f
How Much Experience Can You Get from One project? by Anthony A. Gallegos NAAMLP paper
Taking on the White Hats: Interest Group Opposition to Mine Reclamation
UTAMRP employees have published NAAMPL papers on streamlining the recordation process, claiming that mining history somehow can withstand less scrutiny and observation in situ. They have documented how one project experienced unexpected blowback from stakeholders and citizens.
We have observed UTAMRP attempt to streamline the public input process and eliminate the need for fully documenting project impacts to the mining landscape and history.
I am concerned that Sec 106 violations are occuring in UT in that substantial impacts to historic register capable sites and features are being erased in the name of public safety. UTAMRP does not allow contractors or consultants to examine underground mining features before during or after having made recommendations to backfill.
A National Historic Mining Initiative was first proposed by Eric DeLony (Chief and Principal Architect, Historic American Engineering Record, National Park Service, Washington, D.C.) in the 1990s, the Initiative was a response to the fact that while archeological remains are extensive, little is left of the extant surface structures of Western mining operations—the headframes, mills, cyanide plants and smelters that processed the ore extracted from the ground. Historic mining structures are threatened with government-wide reclamation programs that close abandoned mine openings and remove potential liabilities like old mill buildings and headframes. (Quoted in Death Valley to Deadwood, Kennecott to Cripple Creek: Proceedings of the Historic Mining Conference January 23-27, 1989 p
UTAMRP has documented several cases of inadvertent damage to cultural resources while conducting reclamation activities. [ Chris Rohrer, Death Valley to Deadwood, p. 85.] Curiously, Chris states in this report how a severe, but unanticipated adverse effect was mitigated. He later defined mitigation as the preservation of “key values of something at risk…even if the item itself cannot be saved.” He goes on to admit that Utah has used sub-HABS/HAER documentation to mitigate adverse effects several times, particularly when the value has low integrity. Lastly, the concept of anticipatory demolition is discussed as well (When the Big Picture is too Big: A Simpler Alternative to HABS/HAER, pp. 1, 3)
The Utah DOGM does not see itself in the role of nominating sites they inventory and document. The opportunity is left to others.
Whereas features below the ground hold much information about changes in mining practices through successive eras, but regrettably DOGM reclamation contracts prohibit consultants and contractors from documenting underground features and even entering the mines they are closing. See e.g. REQUEST FOR STATEMENTS OF INTEREST For Abandoned Mine Reclamation Program Reclamation Engineering and Design - San Francisco Project Solicitation Number NO7514, page 17 states clearly that “Archaeologists are not permitted to go underground. No underground surveys are required.” On Page 20 it is repeated that “No subsurface remains need to be evaluated.” On Page 30 it says “The following services and work are to be excluded from this contract, not considered WORK in this AGREEMENT, and/or will be completed by the OWNER: Environmental Assessment and compliance with Endangered Species Act, landowner consent for right of entry, any and all work requiring entering underground mine workings (this activity is extremely hazardous and is prohibited)…” However, the consultant is expected to assess the hazard potential of a mine feature without entering it-- Page 21: ”CONSULTANT shall assess the potential hazard and cultural significance at each mine feature and recommend the appropriate reclamation action… .” . Also of note is that DOGM specifically frowns upon securing a detailed cultural report from its consultants—page 17 “CONSULTANT shall research and write a historical overview of the project area. The historical overview must be sufficient to establish the necessary context to assess National Register eligibility. It should be based on a variety of information sources including local and regional libraries and museums. A lengthy treatise is not expected.”
NHMI efforts have been in securing photos, and videos of the current environmental status of cultural features before any further reclamation takes place. It may be important also to document the inventory and the reclamation itself, to ensure that the promises made by DOGM are in fact carried out. [They have assured the public that cultural resources will be protected, that work will stop if new values are discovered, yet in their own contract proposal procedures are in place and instructional guidelines are referenced on how a demolition would be conducted.]
One of our position papers and a consice summary of our ten goals can be found here:
Russell D. Hartill, JD
National Historic Mining Initiative
140 West 9000 South Suite 1
Sandy, UT 84070-2033
(801)561-4797
fax (801) 561-4798
russhartill@gmail.com