http://www.lyon-county.org/ArchiveCenter/ViewFile/Item/2259
Silver City
June 13, 2016
Lyon County Planning Commission
27 S. Main Street
Yerington, Nevada 89447
To the Lyon County Planning Commission,
I am writing with respect to South Comstock Tailings Disposal Company’s special use permit application. Work commitments prevent me from attending today’s meeting, and I respectfully request that this letter be read in full into the record during discussion of this agenda item. This letter concerns cultural resources—specifically archaeological resources—within the Gold Canyon Mill project area. The Staff Report states on page 8, under the heading “Impacts to Tourism, Historic, Archeological and Cultural Resources [etc.] that:
“The project site has no historic structures nor does it encompass any known historic, archeological or cultural resources nor are there any known features immediately adjacent to the project site.”
This statement is directly contradicted both by a letter from Kautz Environmental Consultants included with the applicant materials, and the staff report itself. The letter, from Barbie Harmon, Director of Heritage Resources at Kautz Environmental Consultants to Dr. Chris Ross of Robison Engineering, states that as a result of her research Ms. Harmon found that “Two archaeological sites are located within the boundaries of the private parcels in which development is expected to occur.”
In addition, the Staff Report and applicant materials refer throughout to “historic tailings” and a “historic tailings dam” located within the project area. Page 4 of the Staff Report provides the first of many examples, under “Background:”
“The subject site contains historic tailings on the eastern portion of the two parcels that appear to have been generated upstream from the subject site . . .”
Photograph 3 on Page 3 of the photograph section of the applicant materials includes an illustration of the tailings dam, with the caption “Looking Easterly along historic Tailings Dam towards Dayton.” Cultural resource management industry standards consider historic tailings and historic tailings dams to be cultural resources, as historic period archaeological sites or features.
The failure to acknowledge the existence of cultural resources in the project area calls into question Finding F of the Recommended Motion on Page 1 of the Staff Report:
“That the scenic, historic, recreational, archaeological values of the applicant’s property and those of the surrounding property owners are protected.”
This failure also affects the Land Use section of the Staff Report (page 7), which points out that under Section 10.10.02(B)of Lyon County Code the County will consider a number of factors “in the processing of a Special Use Permit for mining within the Comstock Historic District.” Item 4 in this list of factors is:
“The potential resultant impact upon tourism, historic, archaeological and cultural resources, recreational areas, agriculture and public health and safety.”
As with Finding F above, it is impossible for the County to consider impacts to historic, archaeological and cultural resources if it denies their existence within the project area in light of clear evidence to the contrary. The restatement on Page 8, under consideration of “Impacts to Tourism, Historic, Archaeological and Cultural Resources,” that the project area has no known historic, archaeological or cultural resources is equally unsupportable.
I believe this problem with the application can be solved by first recognizing the existence of these cultural resources and adding requirements that the applicant take action with respect to them. The “historic tailings” and “historic tailings dam,” as mundane as they may seem, are important parts of the historic mining landscape. It is clear that they will be destroyed or altered during what is hoped to be many years of operation, however they can be “preserved” through mapping, photography, and detailed descriptions. In addition to a physical description, their study should also include research into whatever mill or milling operation they were associated with, their age, and their role in local mining history and the evolution of milling technology on the Comstock. The two sites referred to in Ms. Harmon’s letter are more problematic, however it seems reasonable that the professional staff in the Lyon County Planning Department would be qualified to work with confidential information about archaeological sites, and then outline appropriate steps to identify and protect their value.
Thank you for your time and consideration.
Erich Obermayr
775-847-0344
historicinsight@gbis.com
1 comment:
Erich - Just FYI your letter was not read into the record at the Planning Commission Meeting. The Commission voted to recommend approval at the County Commission meeting on July 7th.
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