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                 it is categorically not eligible for listing in the National Register of Historic Places.  The project
                 will have no effect on the artifacts since their informational content will be exhausted by
                 identifying them and mapping their location.  These artifacts are not pursuant (36 CFR 60.4)
                 eligible because they are not associated with events that have made a significant contribution to
                 the broad pattern of our history; they are not associated with the lives of pe.rsons significant in
                 our past, they have not embodied the distinctive characteristic of a type, period or method of
                 construction. and they do not yield or contain, have not yielded or may not be likely to yield
                 information important in prehistory or history.


                 Page 37.  Site SCM-2 was examined by Chambers and by BLM archaeologist Kaldenberg and
                 found to contain no artifacts.  It is not an archaeological site.  It is a fan conglomerate with .
                 cobbles and weather fractured rocks.  Several hours were expended at the location with out
                 locating a single item even of dubious nature.

                 Page 38.  This discussion is out of context.  36 CFR 800 4 (b)(l) is written for maximum
                 flexibility an states that "The agency official shall make a reasonable and good faith effort to
                 carry out appropriate identification efforts, which may include background research, consultation,
                 oral history interviews, sample field investigation, and field survey.  If this is done then those
                 item shall be taken into account.


                 The Bureau made good faith efforts through the initial survey and follow up investigations by
                 Cambers and found no sites which will be effected by the project.  The Criteria of Effect applied
                 to three '1)ossible sites" has found that none of them are eligible for listing in the National
                 Register of Historic Places.  SCM 1, being an ash smear of unknown origin.  If it was a roasting
                 pit it still would not be eligible for listing in the National Register of Historic Places because it
                 does not contain information important to prehistory and a simple testing program with shovel
                 tests would extract any possible data contained in the sites.


                 Executive Order 13007 states that heads of federal agencies shall consult with Federally
                 recognized tribes regarding sacred sites.  There are no federally recognized sites within 100 miles
                 of the property.  The site has been private property for almost 100 years.  Even it had once been
                 significant for Native American use, the break in continuity of use for at least 100 if not 200
                 years would preclude it from being a Traditional Cultural Property (National Register Bulletin
                 38).

                 There are no adverse effects to sites because two of the properties identified by King are not
                 archaeological sites, the historic sites is not within the APE and the third (SCMI) property is
                 perhaps a single function feature which has been destroyed as a result of heavy equipment
                 maintenance on a dirt road.
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                 The Bureau of Land Management is in full compliance with the National Historic Preservation
                 Act and no additional work is required.
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