Cultural Resources

CULTURAL RESOURCES

INTRODUCTION This analysis considers the affected environment and environmental consequences to cultural resources for the Stillwater Mining Company’s (SMC’s) Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration on the Custer Gallatin National Forest. Cultural resources are the physical remains of archaeological, historical, and architectural sites and/or places of traditional cultural use. The goal of cultural resource management as stated in the Custer Forest Plan is “…to maintain and enhance historic and prehistoric cultural resource values. Conservation of archaeological and historic sites and information for research, public interpretation, and use by future generations is emphasized.” (USDA-FS 1986: 4) and as stated in the Gallatin Forest Plan “Cultural resources on the Gallatin Forest will be managed to maintain their scientific, social, and historical value in compliance with all applicable Federal and State laws” (USDA-FS 1987: II-3).

ISSUE STATEMENT The No Action, Proposed Action, and Agency Mitigated Proposed Action alternatives could potentially affect cultural resources. As such, the decision maker must consider the effects to all cultural resources that may be located within the boundary of the area of potential effect (APE). The APE consists of three proposed drilling areas (Blocks 1 and 2, and the 18.4 deep drilling location), at least eight proposed helicopter staging area (Sites 1, 2, 3, 4, 5, 6, 7, and 8), and proposed road maintenance on the Picket Pin Road #2140 and the Horseman Flat/West Fork Road #2846. Cultural resource surveys of the APE have recorded nine related cultural resources.

REGULATORY FRAMEWORK Since cultural resources are nonrenewable and easily damaged, laws and regulations exist to help protect them. These include the National Historic Preservation Act (NHPA), the Archeological Resources Protection Act (ARPA), the American Indian Religious Freedom Act (AIRFA), and the Native American Graves Protection and Repatriation Act (NAGPRA). Sacred sites fall under the purview of the Sacred Lands Executive Order (Executive Order 13007). Native American graves are protected under NAGPRA. The National Historic Preservation Act (NHPA) and its implementing regulations require Federal Agencies to consider the effects of their undertakings on historic properties. The term historic properties refer to cultural resources that have been determined eligible for the National Register of Historic Places (NRHP). Code of Federal Regulations 36 CFR 800 outlines the set of procedures established by the NHPA that Federal Agencies must follow before implementing an action that may affect historic properties. American Indians and Alaskan Natives are recognized as people with distinct cultures and traditional values. They have a special and unique legal and political relationship with the Government of the United States as defined by history, treaties, statutes, executive orders, court decisions and the U.S. Constitution. The 1992 amendments to the NHPA specify that properties

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of traditional religious and cultural importance, referred to as traditional cultural properties (TCPs), may be determined eligible for inclusion on the NRHP. Effects to “cultural resources of traditional religious and cultural importance” must be considered under the NHPA. In carrying out the responsibilities under Section 106 of the NHPA, the USFS is required to consult with any tribe that attaches religious and cultural significance to such properties when any federal undertaking may affect them {16 USC 470a(d)(6)(A)}. The SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project Area lies within traditional Crow Indian territory, as defined by the Fort Laramie Treaties. FOREST PLANS Since the APE is located on the Custer Gallatin National Forest, two Forest Plans provide direction for managing cultural resources. The Custer Forest Plan goal of cultural resource management is “…to maintain and enhance historic and prehistoric cultural resource values. Conservation of archaeological and historic sites and information for research, public interpretation, and use by future generations is emphasized.” (USDA-FS 1986: 4). The Gallatin Forest Plan goal of cultural resource management is “Cultural resources on the Gallatin Forest will be managed to maintain their scientific, social, and historical value in compliance with all applicable Federal and State laws” (USDA-FS 1987: II-3). There is no additional specific Management Area C, D or E (Custer Forest Plan) or Management Area 3, 6, 8, or 16 (Gallatin Forest Plan) direction for cultural resources. ENVIRONMENTAL CONSEQUENCES Prehistoric and historic heritage resources are a nonrenewable resource. Heritage resources have many values including their use to gather scientific information on human culture history, interpretive and educational value, values associated with important people and events of importance in our history, and often an aesthetic value as in a prehistoric petroglyph or an historic landscape. For the American tribes, as well as other traditional culture groups, archaeological and historic sites often have importance for religious and ceremonial purposes or simply as locations for traditional uses important in a particular group’s ongoing cultural identity. Since cultural resources would be protected under Section 106 of the NHPA, the potential to affect those properties becomes the measure of the effects of mineral exploration activities between the alternatives. An effect, according to 36 CFR 800.9(a), may include an alteration to the property’s characteristics of location, setting, or use. Adverse effects are defined as those which may diminish the integrity of the property’s location, design, setting, materials, workmanship, feeling or association and include but are not limited to:  Physical destruction, damage, or alteration of all or part of the property,  Alteration of the character of the setting when that character contributes to the property’s qualification for the National Register,  Introduction of visual, audible, or atmospheric elements that are out of character with the property or alter its setting. A direct effect occurs when the action of the undertaking itself impacts the heritage resource. For example, ground-disturbing activities such as road, pipeline, or building construction may damage or demolish a site. An indirect effect is not caused by the action itself but is the secondary result of the undertaking. An example would be manipulation of a watershed which could in turn cause

SMC Iron Creek and West Fork Stillwater Exploration Plan of Operations 2 increased erosion of heritage sites downstream or the upgrade of existing roads or trails which improves or allows public access into previously secluded site areas. Increased access can be directly related to an increase of vandalism or illegal/unauthorized artifact collection.

Analysis Framework

For this analysis, those cultural resource properties that have not been formally evaluated for nomination to the NRHP are treated as historic properties. File and literature search was conducted to define previous archaeological work within, and in the vicinity of, the APE. Table 1 summarizes the archaeological work within the SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project Area APE conducted to date. Table 1. Cultural Resource Investigations Within the SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project Area APE. Project Name/FS Number Year Consultant Acres Sites Comments (reference) Class III Cultural Resource 1979 Larry Lahren, unknown 24ST0100, These four sites are Evaluations of the Johns-Manville Anthro 24SW0146, located outside the Mineral Claims Area: Stillwater Research, Inc. 24SW0147, APE Complex, Montana (Lahren 1980) 24SW0148 /R1980010802009 Cultural Resource Investigations – 1997 Larry Lahren, 550.0 24ST0306 Site is near the Stillwater Mining Company Slurry Anthro (see Lahren 2003a) proposed helicopter Line Route & Tailings Pond Area, Research, Inc. staging area Site 5 Stillwater County, Montana (Lahren 1997) Cultural Resource Compliance 1999 Larry Lahren, 160.0 24ST0043 Site is near the Investigations – Hertzler Tailings Anthro (see Lahren 2003a) proposed helicopter Impoundment Area, Stillwater Research, Inc. staging area Site 5 Mining Company, Stillwater County, (Lahren 1999) Montana, 1999 Field Season Idaho Consolidated Crescent Creek 2001 Larry Lahren, 150.0 None Core Locations and Heli- Anthro pad/R2001010802010 Research, Inc. (Lahren 2001a) Idaho Consolidated Iron Creek Core 2001 Larry Lahren, 30.0 None Holes/R2001010802013 Anthro Research, Inc. (Lahren 2001b) Stillwater Big Horn Sheep Habitat 2001 USDA-FS 60.0 None Adjacent to proposed Project/R2001010802014 (Bergstrom helicopter staging area 2001) Site 4 West Fork Stillwater Road #2846 2003 USDA-FS 139.0 24ST0346, 24SW0469 Site 24ST0346 is Reconstruction/R2004010802020 (Bergstrom located within the 2004a) APE Rabbit Gulch Vault Toilet 2004 USDA-FS 10.0 24ST0354 Site is located outside Replacement/R2004010802031 (Bergstrom the APE 2004b) Beartooth District Travel 2004 USDA-FS 0.0 24SW0478 Site is located within Management Plan – road (Koenig 2004) the APE inventory/R2008010802004 Picket Pin Road retaining wall 2010 USDA-FS 40.0 24ST0392/24SW0640, Both sites are located replacement and Picket Pin Creek (Bergstrom 24SW0641 within the APE Bridge installation/R2010010802019 2010a)

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Initial Creek Trail/R2010010802011 2010 USDA-FS 20.0 24ST0393/24SW0642 Site is located within (Bergstrom the APE 2010b) Cultural Resource Evaluations of the 2012 Larry Lahren, 10.0 None Proposed Iron Creek 35.5 DDH Core- Anthro Drill Location, Stillwater Complex, Research, Inc. Custer National Forest, Stillwater (Lahren County, Montana/R2015010802041- 2012a) 01 Cultural Resource Evaluations of the 2012 Larry Lahren, 10.0 None Proposed Iron Creek 36.5 DDH Core- Anthro Drill Location, Stillwater Complex, Research, Inc. Custer National Forest, Stillwater (Lahren County, Montana/R2015010802041- 2012b) 02 Cultural Resource Evaluations of the 2012 Larry Lahren, 10.0 None Proposed Iron Creek 37.5 DDH Core- Anthro Drill Location, Stillwater Complex, Research, Inc. Custer National Forest, Stillwater (Lahren County, Montana/R2015010802041- 2012c) 03 Cultural Resource Evaluations of the 2012 Larry Lahren, 10.0 None Proposed Iron Creek 38.5 DDH Core- Anthro Drill Location, Stillwater Complex, Research, Inc. Custer National Forest, Stillwater (Lahren County, Montana/R2015010802041- 2012d) 04 Cultural Resource Evaluations of the 2012 Larry Lahren, 10.0 None Proposed Iron Creek 39.5 DDH Core- Anthro Drill Location, Stillwater Complex, Research, Inc. Custer National Forest, Stillwater (Lahren County, Montana/R2015010802041- 2012e) 05 Cultural Resource Evaluations of the 2012 Larry Lahren, 10.0 None Proposed Iron Creek 40.5 DDH Core- Anthro Drill Location, Stillwater Complex, Research, Inc. Custer National Forest, Stillwater (Lahren 2012f) County, Montana/R2015010802041- 06 Cultural Resource Evaluations of the 2012 Larry Lahren, 10.0 None Proposed Iron Creek 41.5 DDH Core- Anthro Drill Location, Stillwater Complex, Research, Inc. Custer National Forest, Stillwater (Lahren County, Montana/R2015010802041- 2012g) 07 Cultural Resource Evaluations of the 2012 Larry Lahren, 10.0 None Proposed Iron Creek 42.5 DDH Core- Anthro Drill Location, Stillwater Complex, Research, Inc. Custer National Forest, Stillwater (Lahren County, Montana/R2015010802041- 2012h) 08 Cultural Resource Evaluations of the 2012 Larry Lahren, 10.0 None Proposed Iron Creek 42.5 Alternate Anthro DDH Core-Drill Location, Stillwater Research, Inc. Complex, Custer National Forest, (Lahren 2012i) Stillwater County, Montana/R2015010802041-09 Cultural Resource Evaluations of the 2012 Larry Lahren, 10.0 None Proposed Iron Creek 43.5 DDH Core- Anthro Drill Location, Stillwater Complex, Research, Inc. Custer National Forest, Stillwater (Lahren 2012j)

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County, Montana/R2015010802041- 10 Cultural Resource Evaluations of the 2012 Larry Lahren, 10.0 None Proposed Iron Creek 44.5 DDH Core- Anthro Drill Location, Stillwater Complex, Research, Inc. Custer National Forest, Stillwater (Lahren County, Montana/R2015010802041- 2012k) 11 Cultural Resource Evaluations of the 2012 Larry Lahren, 10.0 None Proposed Iron Creek 45.5 DDH Core- Anthro Drill Location, Stillwater Complex, Research, Inc. Custer National Forest, Stillwater (Lahren 2012l) County, Montana/R2015010802041- 12 Cultural Resource Evaluations of the 2012 Larry Lahren, 48.0 None Proposed Iron Creek DDH Core-Drill Anthro Location Access Road Inventory, Research, Inc. Stillwater Complex, Custer National (Lahren Forest, Stillwater County, 2012m) Montana/R2015010802041 Horseman Flats Fuels 2013 USDA-FS 635.0 24ST0017, 0099, Sites 24ST0346 and CE/R2013010802002 (Bergstrom 0346, 0354, 0457, 24ST0393/24SW0642 2013) 0458, 0707, 0708, are located within the 0709, 24SW0469, APE; proposed 24ST0393/24SW0642 helicopter staging area Site 4 is located adjacent to this project Cultural Resource Evaluations of 2014 Larry Lahren, 1305.0 None 24SW0763 was Stillwater Mining Company’s Iron Anthro recorded in Block Mountain Exploratory Core-Drilling Research, Inc. Area 2 in 2016 (see Block Areas 1 & 2, Sweet Grass (Lahren Bergstrom 2016) County, Montana/R2015010802016 2014a) Cultural Resource Evaluations of the 2014 Larry Lahren, 50.0 None Proposed Stillwater Mining Company Anthro 18400W DDH Core-Drilling Block, Research, Inc. Custer National Forest, Sweet Grass (Lahren County, Montana/R2015010802040 2014b) Stillwater Mining Company’s 2016 USDA-FS 15.0 None 24ST0392/24SW0640, (SMC’s) Iron Creek and West Fork of (Bergstrom 24SW0763 the Stillwater River Plan of 2017) Operations for Mineral Exploration/R2017010802002 Horseman Flat/West Fork Road 2016 USDA-FS 0.0 24ST____/24SW____ Horseman Flat/West #2846 (Bergstrom in Fork Road #2846 is prep) located within APE

Twenty-nine previous cultural resource investigations directly or partially associated with the APE have been conducted since 1979. Twenty-two of these investigations, representing a total of approximately 2428.0 inventory acres and four recorded cultural sites (24ST0043, 24ST0306, 24ST0392/24SW0640, 24SW0763, and 24ST____/24SW____) within the APE, were conducted in support of the CGNF Minerals Program associated with SMC mining activities. The remaining seven investigations—representing approximately 904.0 inventory acres and five recorded sites (24ST0346, 24ST0392/24SW0640, 24ST0393/24SW0642, 24SW0478, and 24SW0641) within the APE—were conducted in support of proposed road improvement projects (N=3), a proposed recreation project, a proposed wildlife improvement project, a proposed trail project, and a proposed fuels reduction project.

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The earliest cultural resource investigation in the APE was conducted in 1979 by Anthro Research, Inc. Over 4545.0 acres were inventoried by helicopter viewing or pedestrian inspection. Twenty- two specific areas were intensively investigated due to their high potential for the presence of cultural resources. Four sites—consisting of a concentration of at least seven vision quest structures (24ST0100) and three prehistoric lithic scatters (24SW0146, 24SW0147, and 24SW0148)—were recorded during this 1979 project. Projectile points recovered from the lithic scatter sites suggested dates of occupation from 2,500 to 1,000 years before present. These sites have not been formally evaluated in terms of their eligibility to the National Register of Historic Places (NRHP). These four sites are located outside the APE.

During the late 1990s Anthro Research, Inc. conducted two cultural resource investigations associated with the Stillwater Mining Company Slurry Line Route & Tailings Pond Area. Two sites (24ST0043 and 24ST0306)—located off forest but in the vicinity of the SMC proposed Hertzler Tailings Impoundment helicopter staging area Site 5—were recorded. These two sites consist of multiple stone features (i.e. alignments, cairns, stone circles) along with a cave, bone and lithics, and trails. Both sites are tentatively recommended eligible for nomination to the NRHP under criterion d (Lahren 2003a).

In 2001, Anthro Research, Inc. conducted two cultural resource investigations for proposed SMC mineral exploration drill holes in the Crescent Creek and Iron Creek areas. No cultural resources were observed during these investigations.

From 2001-2010 the Forest Service conducted one project aimed toward Big Horn Sheep habitat improvement, one project involving an existing toilet replacement, two projects involving road improvements, one project associated with the Beartooth District Travel Management Plan and one project involving a proposed trail project. Two cairn sites (24ST0346 and 24ST0354), abandoned bridge abutments (24SW0469), a historic artifact scatter (24SW0478), the abandoned Picket Pin Sawmill (24SW0641), the historic Picket Pin Road #2140 (24ST0392/24SW0640), and the historic Bryant Cabin/Bridge Abutments/Road (24ST0393/24SW0642) were recorded.

Five of these sites (24ST0346, 24ST0392/24SW0640, 24ST0393/24SW0642, 24SW478, and 24SW0641) are located within the APE. The Picket Pin Road #2140, the Bryant Cabin/Bridge Abutments/Road, and the Picket Pin Sawmill have been determined Eligible for nomination to the NRHP under criterion a for their association with early-day homesteading, chrome mining exploration, logging, sheep herding activities, and the Montana Polytechnical College training facility in the Picket Pin and Iron Mountain areas (Warhank 2010a, 2010b). The cairn and historic artifact scatter sites have not been formally evaluated in terms of their eligibility to the NRHP but at this time they are considered eligible.

In 2012 Anthro Research, Inc. conducted cultural resource investigations for twelve proposed SMC mineral exploration drill holes and an access road corridor along Iron Creek. No cultural resources were observed.

In 2013 the Forest Service conducted cultural resource investigations above the SMC mine, on Horseman Flats and along the Horseman Flat/West Fork Road #2846 for a proposed fuels reduction project. Eleven sites—consisting of the Bryant Cabin/Bridge Abutments/Road

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(24ST0393/24SW0642), bridge abutments (24SW0469), several cairns (24ST0017, 24ST0346, 24ST0354, 24ST0457, 24ST0458), historic mining prospect pits (24ST0707), a historic trail (24ST0709), and stone structures (24ST0099, 24ST0708)—were observed. Two of these sites (24SW346 and 24ST0393/24SW0642) are located within the APE. The Bryant Cabin/Bridge Abutments/Road (24ST0393/24SW0642) site was determined Eligible for nomination to the NRHP under criterion a, due to its association with early recreation use in the Beartooth Mountains and its association with chrome ore development during World War II (Warhank 2010b).

In 2014 Anthro Research, Inc. conducted cultural resource investigations in three block areas for proposed SMC mineral exploration drill holes near Iron Mountain and along the West Fork Stillwater River. No cultural resources were observed.

In 2016 a fifteen-acre cultural resource inventory was conducted for the proposed helicopter staging area Site 1. The previously recorded Picket Pin Road #2140 (24ST0392/24SW0640) is adjacent to this inventory area. In addition, the historic Godtel-Gahl Cabin (24SW0763)—located within the previously recorded Block Area 2—was recorded in 2016 by the Forest Service. A site form for the historic Horseman Flat/West Fork Road #2846 is currently in preparation.

In addition to these twenty-nine previous cultural resource investigations an ethnohistoric/ethnographic study of the entire Beartooth District was conducted in the early 1990s which described culturally sensitive site types as “…have the highest probability of being the subject of traditional cultural concerns. Sensitive site types include: burials, rock art, stone rings of greater than 7 m in diameter, monumental rock features, fasting structures, eagle catching pits, sweat lodges, wooden structures, Sun Dance lodges and grounds, offering and prayer locales and historic battle sites.” (Deaver and Kooistra-Manning 1995: 3.13). The vision quest structures described above at site 24ST0100, even though located outside of the APE, were specifically included in this manuscript as culturally sensitive site types. Sites 24ST0043, 24ST0306, and 24ST0346 described above are located within the APE and are considered culturally sensitive site types.

In summary, the proposed SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project Area has been inventoried by intensive pedestrian examinations or by helicopter examination and nine cultural resource sites are present. Three sites—the Picket Pin Road #2140 (24ST0392/24SW0640), the Bryant Cabin/Bridge Abutments/Road (24ST0393/24SW0642), and the Picket Pin Sawmill (24SW0641)—have been determined Eligible for nomination to the NRHP. Five sites—the Moraine Edge (24ST0043), the Rocky Pass (24ST0306), a cairn (24ST0346), a historic artifact scatter (24SW0478), and the Godtel-Gahl Cabin (24SW0763) have not been formally evaluated for nomination to the NRHP but for this analysis they are treated as historic properties and are considered Eligible. The Moraine Edge (24ST0043), the Rocky Pass (24ST0306), and the cairn (24ST0346) are considered culturally sensitive site types. A site form for the historic Horseman Flat/West Fork Road #2846 is currently in preparation. Analysis of effects from the action alternatives will concentrate on these nine cultural resource sites.

One proposed helicopter staging area (Site 1) was inventoried for cultural resources in 2016. Three proposed helicopter staging areas (Site 2, Site 3, and Site 4) are existing helicopter landing pads

SMC Iron Creek and West Fork Stillwater Exploration Plan of Operations 7 and no cultural resource inventories were conducted at these locations for the SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration project. The proposed helicopter staging area Site 5 was previously inventoried for cultural resources. The proposed helicopter staging area Sites 6, 7, and 8 locations have not yet been determined. Cultural resource inventories will be conducted for these proposed helicopter staging areas when the locations are determined and proposed by SMC.

Issue Indicators and Measures

For cultural resources, the issue indicator is the number of historic properties located within the APE that could be affected by the action alternatives. The measure used to analyze the effect is whether there will be an adverse effect to these historic properties, as defined by the NRHP regulations (36 CFR 800) that would threaten the historic property’s eligibility for nomination to the NRHP.

Spatial and Temporal Bounds of Analysis

Temporally, the analysis discloses direct/indirect/cumulative economic effects of the proposed February 2016 Plan of Operations For Mineral Exploration construction scheduled provided by Stillwater Mining Company and the alternatives developed by the Forest Service. The APE consists of three proposed drilling areas (Blocks 1 and 2, and the 18.4 deep drilling location), at least eight proposed helicopter staging area (Sites 1, 2, 3, 4, 5, 6, 7, and 8), and proposed road maintenance on the Picket Pin Road #2140 and the Horseman Flat/West Fork Road #2846. Legal locations for the Blocks 1, 2, and 18.4 deep drilling locations include T5S, R13E, Section 1, and T5S, R14E Sections 6, 7, 8, 9, 12, 15, 16. Legal locations for the proposed helicopter staging areas include T5S, R14E, Section 1 (Site 1), T4S, R14E, Section 3, (Site 2), T5S, R15E, Section 21 (Site 3 and Site 4), and T4S, R16E, Section 30 (Site 5). The proposed helicopter staging area Sites 6, 7, and 8 locations have not yet been determined. Road repair/maintenance, installation of new drainage features and culverts, replacement of an existing cattle guard on the Picket Pin Road #2140, and selective minimum-width widening on the Horseman Flat/West Fork Road #2846 is proposed but, except for the proposed cattleguard replacement, the exact locations for these activities is unknown. Therefore, the APE considers the entire length of both roads where these activities may occur. Legal locations for the proposed road maintenance on the Horseman Flat/West Fork Road #2846 include T5S, R14E, Section 12 and T5S, R15E, Sections 7, 8, 9, 16, 21. Legal locations for the proposed road maintenance on the Picket Pin Road #2140 include T4S, R13E, Section 31, T4S, R14E, Sections 29, 30, 31, 32, 33, 36, T4S, R15E, Sections 29, 30, 31, T5S, R14E, Sections 1, 2, 3, 4, 6, and T5S, R15E, Section 6.

Affected Environment

In general, the character of the Beartooth District has been described as a “…complex and varied geology…”. More specifically the Beartooth Range, within and surrounding the SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project Area, is defined as being “…formed by an uplift of Precambrian crystalline rock through a sequence of sedimentary rock layers. Structural deformation was so intense that it caused thrusting of the ancient rock out over the more sedimentary materials. Glacial activity and erosion has

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removed the sedimentary rock except for along the fringe of the Beartooths (Beckes and Keyser 1983: 307).

The mineralized area where exploration is proposed is known as the Stillwater Complex and lies along the northern edge of the Absaroka-Beartooth Mountains in portions of Park, Sweet Grass, Stillwater and Carbon Counties, Montana. The elevation of this mineralized zone ranges from 5000 feet on the valley floor at the town of Nye to 10,088 at Iron Mountain. The SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project Area is located in the mid-to-high elevations (7980-9400 feet) on open meadows, ridges, and timbered slopes near Iron Mountain and in the mid elevations (6100-6960 feet) in open meadows and near timbered slopes along the West Fork Stillwater River.

Pre‐contact

The Precontact Period of the Northwestern Plains prehistory is generally divided into cultural periods distinguished in the archaeological record by changes in artifact and feature types. These periods include Paleo-Indian, Plains Archaic, and Late Prehistoric/Protohistoric. The following is a summary of these periods - for a more detailed description see Beckes and Keyser (1983), Frison (1991), and Lahren (2008).

The Paleo-Indian Period could date as early as 13,000 to 15,000 years before present (YBP) and ended about 7,500 YBP. This period is characterized by a human population heavily dependent on hunting of now extinct fauna such as giant bison and mammoth. Large lanceolate shaped and stemmed projectile points characterize this early period but details on complete artifact assemblages are currently fragmentary. Some of the common projectile point types include Clovis, Folsom, Goshen, Agate Basin, and Hell Gap.

While there are no known Paleo-Indian artifacts recorded within the SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project Area there have been several artifacts recovered nearby that date to this time period. The Red Lodge Site—a multi- component site situated on a high, open bench approximately one mile northeast of Red Lodge— was excavated in the late 1930’s and several Paleo-Indian lanceolate projectile points were recovered (Mulloy 1943). On the alpine plateaus of the Beartooth Mountains, several Paleo-Indian artifacts have been found in past years by independent investigators (Husted 1990, 1991, 1993) and by amateur collectors (Husted 1992). The Waples Collection—a lithic artifact collection consisting, in part, of over one hundred diagnostic projectile points amassed by Vern Waples during his thirty-plus year career as a Montana State game warden—contains several examples of Paleo-Indian projectile points collected from within and around the Beartooth Mountains. A complete atlatl fore shaft was recently recovered on the margin of an ice patch and radiocarbon dated to approximately 10,400 YBP (Lee 2012).

The Plains Archaic Period began around 8,000 YBP and ended about 1,300 YBP. This period began with the cultural adaptation to the Plains area, which can be related to modern flora and fauna, and to the disappearance of the large mega fauna which characterized the Paleo-Indian Period. The Plains Archaic Period is usually divided into overlapping periods consisting of Early, Middle, and Late Plains Archaic Periods.

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The Early Plains Archaic Period (8,000-5,000 YBP) generally coincides with the warming trend referred to as the Altithermal Climatic Episode, a possible cultural hiatus on the Great Plains that saw human population movement to refugiam peripheral to the Great Plains (Frison 1991). The earlier emphasis on big game hunting gave way to a more diversified economy. A transition from lanceolate shaped to large stemmed and side-notched projectile points appears in the archaeological record of this time period.

The Red Lodge Site contained several stemmed and large side-notched projectile points that appear to fall within the Early Plains Archaic Period (Mulloy 1943). As was the case with Paleo-Indian Period artifacts in the Waples Collection, several Early Plains Archaic Period artifacts are represented as surface finds in this collection from sites on the nearby Beartooth Mountain plateaus. In addition, recent ice-patch investigations on the Beartooth Mountain plateaus have recovered several organic (i.e. culturally modified plant or wood) artifacts dating to this time period (Lee 2012).

The Middle Plains Archaic Period (5,000-2,700 YBP) is identified by the appearance of the McKean Complex (5,000-3,000 YBP), the Duncan-Hannah Complex (3,700-3,200 YBP), and the Yonkee Complex (3,200-2,600 YBP). The McKean Complex roughly corresponds with the Sub- Boreal climatic episode that was cool and moist, reflecting modern conditions. Artifacts of the Middle Plains Archaic Period are represented in slightly higher frequency in the Waples Collection as surface finds from the Beartooth Mountain plateaus.

The Late Plains Archaic Period (3,200-1,300 YBP) is characterized by several different point styles including Pelican Lake, Besant, and a larger number of small, bulky dart points that are unnamed variations of the basic corner or side-notched dart point design (Beckes and Keyser 1983). Further adaptations toward upland living and the exploitation of open prairie resources mark the Late Plains Archaic Period. This change of focus is illustrated by their adoption of new cooperative hunting techniques and the development of the tipi, a specialized structure suited for open plains habitation.

The West Rosebud Lake Site, located several miles to the southeast of the SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project Area contained evidence of prehistoric use over a 6,000 year span during the Plains Archaic Period and into the Late Prehistoric Period (Greiser and Plochman 1981). The Red Lodge Site contained several corner-notched projectile points tentatively identified as Pelican Lake and Besant (Mulloy 1943). The Blakely-Brownlee Divide Site and the Brownlee Head Site, located within five miles to the northwest of the SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project Area contained projectile points dating to 2500-1000 years before present or possible earlier (Lahren 1980: 21).

The Late Prehistoric/Protohistoric Period (1,300 YBP to Historic Times) is recognized as a shift in hunting techniques that involves the introduction of the bow and arrow. Euro-Americans contact is represented by an increase in the use of horses and the presence of trade items predating Euro-American movement into the area. A variety of small projectile point types—including corner-notched, side-notched and tri-notched—are known as Avonlea and Prairie/Plains side-

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notched. Communal bison hunting, although evident in earlier time periods, appears as a dominant and highly refined activity during the Late Prehistoric Period.

Numerous small Late Prehistoric Period projectile points were recovered during excavation at the Red Lodge Site (Mulloy 1943). A number of surface finds of Late Prehistoric Period projectile points are reported on the Line Creek Plateau. The Keogh Buffalo Jump, located just off Forest Service administered lands several miles to the northeast of SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project Area is attributed to this period (Conner 1962). The Blowing Ridge Site (Lahren 2012n), recorded by Anthro Research Inc. and located northwest of the historic Benbow Mill Site, contained a small triangular obsidian point associated with the Late Prehistoric Period.

The Protohistoric Period, representing the transitional time between the Late Prehistoric Period and the beginning of written records, has been described as “…a time of complex populations movements, technological innovations, and social change.” (Beckes and Keyser 1983: 335). Material items that define the Protohistoric Period include trade beads and metal objects such as guns, projectile points and knives.

Post‐contact

Historic occupation of the SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project Area and surrounding country by Native Americans is most often attributed to the Crow but other tribes such as the Blackfeet, the Northern Cheyenne, and the Shoshone are known to have used the area too. Aboriginal trails pass through, or near, the SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project Area and later may have served as templates for some of the roads and trails that are present on the forest today.

The Arapahoe Trail is one such aboriginal trail that was likely utilized for hundreds of years and by numerous Native Americans and Euro-Americans. A portion of this trail began at the Yellowstone River near Livingston, coursed east-southeast past Natural Bridge on the Boulder River, and continued toward the east past Nye and Dean and on to the Red Lodge area (Bonney and Bonney 1970: 462). Lahren describes the route in more detail, based upon his knowledge of the area, and refers to a later naming of the trail as the Skookum Joe Trail (Lahren 2003b: 106).

The 1851 Treaty of Fort Laramie defined a broad area encompassing over 38.5 million acres (in present-day Montana, South Dakota, and Wyoming) as the Crow Reservation. The Fort Laramie Treaty of 1868 established the first reservation agency (Fort Parker) located several miles northeast of present-day Livingston, MT and at the same time reduced the reservation to about nine million acres. In 1875 the Fort Parker agency was relocated to just south of Absarokee, MT and by 1882 another 1.5 million acres of reservation lands were relinquished by the Crow. In 1884, following a nine-year occupation, the Absarokee agency was relocated for the final time to Crow Agency near the banks of the Little Bighorn River.

Despite these massive reductions to their reservation lands the Crow have not altered their view toward the broader landscape they still consider Crow Territory. Provisions in the Ft. Laramie

SMC Iron Creek and West Fork Stillwater Exploration Plan of Operations 11

Treaties include the tribal reserved rights to hunt on “all unoccupied lands of the United States”. In addition to hunting, traditional practices such as harvesting teepee poles and gathering medicinal plants are also recognized. Many distant places located off their reservation share as keen a traditional importance as do places on, and adjacent to, their reservation and even today many of these places are visited and used by the Crow. Based on similarities to sites reported in the literature, a series of rock structures located on a high isolated ridge above the Stillwater River is possibly associated with historic period Crow vision quest activities (Lahren 1980: 39).

One of the main reasons the Crow were being forced to give up their reservation land was due to pressure directed toward the government by homesteaders, miners, ranchers, and railroad speculators in efforts to open up more land for settlement, exploration and development. In addition to coal and limestone deposits around Red Lodge, the vast expanse of the Beartooth Mountains contained a variety of other minerals that drew prospectors to the area during the late 1800s. By 1870 gold and silver discoveries were made in the Cooke City area with A. B. Henderson credited as being in one of the first mining parties (Clark 1982: 14). Just prior to this time, during the late 1860s, Joseph Anderson and Jack V. Nye found gold in the Stillwater River drainage but were unable to develop the deposits since they were located within the boundary of the Crow Reservation (Wolle 1963: 409). An 1882 survey of the area determined the deposits were actually located outside the reservation which led to an immediate rush of white miners eager to file claims (GCM 1990: 8).

In 1883 Nye, along with brothers Jimmy and Jonas Hedges, found evidence of copper, nickel and chromium deposits in the areas later to be known as Mountain View, Benbow and Initial Creek. The following year Nye traveled to Minneapolis where he convinced friends and relatives of the potential wealth to be made with his mineral claims. Before the end of the year the Stillwater Mining Company was incorporated and by the fall of 1885 they had purchased all of Nye’s mining claims. In a quick turn of events the Stillwater Mining Company sold these claims to the Minneapolis Mining and Smelting Company. Serious mining development began in 1886—the same year that the town of Nye City was established—and by 1887 the town boasted a population of 300-400 people, five or six restaurants, six or seven saloons, a store, a commissary, a laundry, a boarding house, an assay office, a post office, and a small smelter (Annin 1964: 73; Czamanske and Zientek 1985: 77-78; GCM 1990: 8; Wolle 1963: 410).

Around this same time another government survey was conducted in the Stillwater Basin area and determined that Nye City was actually on the Crow Reservation. The town was ordered to be evacuated and mining operation dismantled and removed. Three years later, in 1890, the Crow ceded the land and mine claims and mining activities once again became legal operations (Czamanske and Zientek 1985: 78; GCM 1990: 8; Wolle 1963: 410).

In 1904 a six-ton sample of Nye area ore was sent to Omaha, Nebraska for smelting. Recovery was considerably less than the assays indicated and ore production in the Nye area halted—at least for a few years (Czamanske and Zientek 1985: 78; GCM 1990: 8). In 1914 M. W. “Bill” Mouat acquired the property which consisted of fifty patented claims and about twenty unpatented claims. Limited tonnage of chromite ore were mined during World War I and during the next three decades the mine operation continued with five levels developed, a mile-long aerial tramway built, and a mill constructed on the west side of the Stillwater River. In 1941 the property was incorporated

SMC Iron Creek and West Fork Stillwater Exploration Plan of Operations 12

by Mouat and Edward Sampson as Mouat Nickel Mines, Inc., but due to litigation no mining activity was performed (Czamanske and Zientek 1985: 78; GCM 1990: 8).

Events of World War II saw foreign supplies of strategically vital chromite ore cut off which led to the government take-over of all the mining properties in the Stillwater Complex. The Anaconda Minerals Company (AMC) took over the Mouat-Sampson mining operation, on behalf of the Federal Government Metals Reserve Corporation, and immediately began an extensive development program which included building a large mine plant, an ore-treatment plant, two large workers camps, a new aerial tram, nearly 30,000 feet of drifts, crosscuts and laterals, and 8500 feet of raises. The mine and mill operated for seven months and then shut down when cheaper/higher grade foreign sources of chromite ore once again became available (GCM 1990).

Government leases on the Mouat-Sampson properties were cancelled in 1946. Despite estimates of over five million tons of chromite ore still present at this location, the next few years saw equipment and structures at the mine and mill dismantled or removed. In 1953 a new surge of mining activity, this time brought on by the Korean War conflict, resulted in a government- awarded contract to the American Chrome Company (ACC) to produce 900,000 tons of chromite concentrate as a strategic minerals stockpile effort. The Mouat Mine (now called the American Mine) mill was rebuilt and eventually 920,000 tons of concentrate were stockpiled at Nye within an eight-year period. In 1963 the government bought the stockpile for $35/ton and terminated ACC’s contract. In 1973 the government sold the chromite ore stockpile to a German company for about $6.70/ton. Exploration work at the Mouat Mine continued from the late 1960s and into the 1970s by AMC, but no further production occurred (GCM 1990: 8-9).

In 1905, approximately five miles to the east of the Mouat Mine operations, T.C. Benbow of Columbus, Montana was developing a chromite mine in the Stillwater Complex with a small mine along Little Rocky Creek. Benbow operated the deposits sporadically for several years but only a small amount was shipped due to its low grade compared to higher grade ores from foreign sources. In similar fashion, World War 1 brought the first round of serious development of the chromite ores in the Benbow area but still little was shipped (Czamanske and Zientek 1985: 83). Benbow, along with two partners, worked the Benbow Chrome Mine, driving the Eclipse adit among others, but the end of the war caused a drop in demand for chromite and the operation shut down. In the 1920s Benbow built roads and installed machinery for developing the ore, but development work was halted by the stock market crash of 1929.

In the early 1930s the Chromium Products Corporation formed and bought interests in the Benbow area. A consortium headed by Chrysler Corporation, under a lease obtained from Chromium Products Corporation, extended the Eclipse adit and drove the Majestic adit just west of Chrome Peak. Two other adits, the Black Rock and Big 7, were also worked but again little or no ore was shipped from the Benbow area. After Benbow’s death in 1932, seven claims at the Benbow Mine, Black Rock, Majestic, Big 7, Titanic, Lucky Strike, Eclipse and War Eagle, were patented by Chromium Products Corporation.

World War II brought another surge of mining activity to the Benbow area when Axis victories at sea disrupted chromite shipments from Turkey, South Africa and the Philippines early in the war. Chromite ore was a strategic mineral which was critical for the war effort and the development of

SMC Iron Creek and West Fork Stillwater Exploration Plan of Operations 13 a domestic source became imperative. Anaconda Minerals Company, acting as an agent for the U.S. Government, began developing the Benbow deposits in June of 1941. The Benbow Mine was leased for ten years by the government and during the period from 1941 to 1943 over 35,000 feet of mine workings were driven and 200,625 tons of ore were mined. Over 30 cabins, five bunkhouses, a mess hall, store, recreation hall and a school was constructed for the miners. The mine surface facilities included a head frame, hoist house, carpenter shop, warehouse, shop, change house, office, garage, first aid station, tram shed, aerial tram from the mine to the mill, a 1400 foot long incline tram covered by a shed which ran to the adits, one oil and two water tanks (GCM 1990).

Earnest mineral exploration in the Iron Mountain and Crescent Creek area has fairly recent beginnings. United States Steel Corporation conducted geologic mapping, sampling, claim staking, trenching, and drilling during the late 1950s. In addition to airborne geophysical surveys, several exploratory drill holes were placed on Iron Mountain and nearby. It was during this time that the upper portion of the Picket Pin Road #2140 was constructed in order to provide access for these mineral activities. During the 1970s and 1980s the Brass Monkey, a minerals exploration camp located on a ridge between Iron Mountain and Picket Pin Mountain, operated under the direction of the Johns-Manville Corporation (Czamanske and Zientek 1985: 89, 258).

Through a series of joint ventures and company name changes, mining continues in the area. In 1979 the Chevron Resource Company joined with the Johns-Manville Corporation to form the Stillwater PGM Resources Company. Three years later this company joined with the Anaconda Minerals Company to form the Stillwater Mining Company. Stillwater Mining Company has developed and currently operates a platinum group metals mine and related mining/milling and waste rock/tailings/water management facilities adjacent to the Stillwater River, portions of which are on and under Forest Service lands. Stillwater Mining Company currently owns patented mining claims in the Iron Creek and West Fork Stillwater areas.

Early historic trails in the SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project Area include the Picket Pin Road #2140 which accesses the Picket Pin drainage up to the top of Iron Mountain, the Horseman Flat/West Fork Road #2846, and the Bryant Road/Trail which access a portion of the West Fork Stillwater River. These three travel corridors likely saw their origins prior to the late 1800s and early 1900s as game or aboriginal trails which later evolved due to use by miners/prospectors, homesteaders, sheep herders, trappers, and loggers. Evidence of wagon road segments are still visible along the Picket Pin Road #2140, and the Bryant Road/Trail is still visible as a narrow, abandoned corridor coursing through the timber. Most of the Horseman Flat/West Fork Road #2846 is a narrow, rough road— used primarily for recreation and Forest Service administration activities—that received only periodic maintenance. Eastern portions of Road #2846 go through SMC’s Nye mine site, which is an active mining area where regular road maintenance occurs to ensure compliance with storm water best management practices (BMP’s) and mine safety requirements.

Remnants of the Picket Pin Sawmill—including building foundations, pits, cast-iron and tin artifacts, steel cable, glass, lumber, etc.—are present along both sides of the Picket Pin Road #2140. This sawmill began operation around 1918 and provided a considerable quantity of timber products to nearby chromite mines for nearly three decades. The sawmill was operated as a

SMC Iron Creek and West Fork Stillwater Exploration Plan of Operations 14

training facility by the Billings-based Montana Polytechnical College during the late 1940s and then changed operational hands twice during the 1950s until it was ordered shut down by the Forest Service in 1958 (Bergstrom 2009).

Effects Common to All Alternatives

Design Features and Mitigations

To ensure compliance with applicable cultural resource law/regulation/policy, the Agency Mitigated Proposed Action Alternative 3 would require the following mitigations. This analysis assumes that the following mitigation/design features would be implemented as part of the Agency Mitigated Alternative.

1. Avoiding the cairn site location (24ST0346) with any proposed selective minimum-width widening on the Horseman Flat/West Fork Road #2846 would protect this site. Monitoring this site would be conducted during project implementation. Consultation with the Crow Cultural Committee would be required to determine if this is a proper and respectful mitigation option for this site.

2. Consultation with the MTSHPO would be conducted prior to any proposed road alterations—such as new drainage feature/culvert installation, existing cattle guard replacement, or use of the helicopter staging area Site 1—on the Picket Pin Road #2140. Routine maintenance on the Picket Pin Road #2140, where it courses past the two Bryant Road termini (24ST0393/24SW0642), past the historic artifact scatter site (24SW0478), or through the Picket Pin Sawmill site (24SW0641) would occur within the existing road prism width to insure no disturbance occurs at these three sites. Monitoring at these sites would be conducted during project implementation.

3. Relocating the present proposed drill site 28,500 W and archaeological monitoring at the Godtel-Gahl Cabin (24SW0763) would be required in order to insure an adequate buffer between the cabin and proposed drill site. Monitoring at the cabin would also be required during access and drill activity in order to insure the cabin is not disturbed or vandalized.

4. Consultation with the Montana State Historic Preservation Office (MTSHPO) would be conducted prior to any proposed road alterations—such as selective minimum width widening—on the Horseman Flat/West Fork Road #2846 (24ST____/24SW____).

5. The proposed helicopter staging area (Site 6, 7, and 8) locations have not yet been precisely determined, but a cultural resource inventory would be conducted when they are determined and prior to helicopter use activity.

6. Project implementation activities would cease immediately at any location where cultural resources were discovered and the Forest Archaeologist would be notified. Project activity would resume only after authorized by the Forest Service.

SMC Iron Creek and West Fork Stillwater Exploration Plan of Operations 15

Effects to cultural resources vary according to the scale of the proposed activities dictated by alternative. There are nine recorded historic properties within the APE. All nine are considered eligible for nomination to the NRHP. Table 2 describes these sites and the NRHP eligibility status.

Table 2. Historic Properties Within the SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project Area APE. Site Number/Name Site Type Eligibility Status Remarks 24ST0043/Moraine Cairns & stone Undetermined Potential effect from activity at Edge structures proposed helicopter staging area Site 5 under the Proposed Action Alternative. Site 5 is not used under the Agency Mitigated Action Alternative, so there would be no potential effects. 24ST0306/Rocky Pass Alignments, bone, Undetermined Potential effect from activity at cairns, caves, lithics, proposed helicopter staging area Site 5 stone structures, trail under the Proposed Action Alternative. Site 5 is not used under the Agency Mitigated Action Alternative, so there would be no potential effects. 24ST0346 Cairn Undetermined Potential effect from repair/maintenance and selective minimum-width widening of Horseman Flat/West Fork Road #2846 which is less than twenty feet from the site 24ST0392/24SW0640/ Picket Pin Road #2140 Determined Eligible - 2010 Potential effect from activity at Picket Pin Road #2140 proposed helicopter staging area Site 1 which is adjacent to the site 24ST0393/24SW0642/ Cabin, bridge Determined Eligible - 2010 Potential effect from maintenance to Bryant Cabin/Bridge abutments, road Picket Pin Road #2140 which is adjacent Abutments/Road to the road features of the site 24SW0478 Historic artifact scatter Undetermined Potential effect from maintenance to Picket Pin Road #2140 which is adjacent to the site 24SW0641/Picket Pin Picket Pin Sawmill Determined Eligible - 2010 Potential effect from maintenance to Sawmill Picket Pin Road #2140 which courses through the site 24SW0763 Godtel-Gahl Cabin Undetermined Potential effect from drilling activity at proposed drill site 28,500 W which is located within 85 feet of the site 24ST____/24SW____ Horseman Flat/West Undetermined Potential effect from repair/maintenance Horseman Flat/West Fork Road #2846 and selective minimum-width widening Fork Road #2846 of the road (Alt 2 and 3) as well as helicopter staging under Alt 3.

The Moraine Edge Site (24ST0043) and the Rocky Pass Site (24ST0306) are adjacent sites, located on non-Forest Service administered land, consisting of multiple stone features (i.e. alignments, cairns, stone circles) along with a cave, bone and lithic artifacts, and trails dating to the prehistoric and historic era. Both sites, considered culturally sensitive sites, are near proposed helicopter staging area Site 5, which would be used under the Proposed Action Alternative and would not be used under the No Action and Agency Mitigated Action Alternatives.

A medium-size, low-profile cairn (24ST0346) is located near the edge of the Horseman Flat/West Fork Road #2846. The age and function of this feature is unknown but it is considered a culturally sensitive site. Road repair/maintenance and selective minimum-width widening is proposed on the Horseman Flat/West Fork Road #2846.

SMC Iron Creek and West Fork Stillwater Exploration Plan of Operations 16

The Picket Pin Road #2140 (24ST0392/24SW0640) is presently recorded as an approximately 13.0 mile long corridor, coursing across private and Forest Service administered lands, and was constructed or improved during various intervals dating to the early 1900s. Its progressive development coincided with early homesteading, logging, mining, and sheep-herding activities. Remnants of several abandoned road segments, likely original wagon trail segments, are still visible along the existing Picket Pin Road #2140 northeast of Iron Mountain. Today, the Picket Pin Road #2140 exhibits a rough, unpaved surface character that receives only periodic maintenance as specific needs arise or limited funding becomes available.

The proposed helicopter staging area Site 1 is located adjacent to the Picket Pin Road #2140. An existing cattle guard—located in section 30, T4S, R15E—is proposed for replacement, along with road repair/maintenance and installation of new drainage features and culverts on the Picket Pin Road #2140 by SMC.

Two road termini associated with the Bryant Road (24ST0393/24SW0642) join with the Picket Pin Road #2140. The Picket Pin Road #2140 is proposed for road repair/maintenance and installation of new drainage features and culverts by SMC.

A historic artifact scatter (24SW0478) is located adjacent to the Picket Pin Road #2140. The age and function of the materials at this site is unknown, but they may be related to the nearby Picket Pin Sawmill. The Picket Pin Road #2140 is proposed for road repair/maintenance and installation of new drainage features and culverts by SMC.

The Picket Pin Sawmill (24SW0641) was operating in the Picket Pin drainage as early as 1918 and continued until around 1958. Logged timber from the surrounding area was processed and the products were sold locally to individuals and to nearby chromite mines. At least five different owners—including private individuals and the Rocky Mountain College—operated the facility. The U. S. Government assumed operations of the sawmill during World War II for its chromite ore mining effort. Today, evidence of the sawmill operation consists of collapsed buildings, building foundations, depressions, and historic artifacts (buttons, crockery, glass, lumber, nails, steel cable, and tin cans). The Picket Pin Road #2140 courses through the site and is proposed for road repair/maintenance and installation of new drainage features and culverts by SMC.

The Godtel-Gahl Cabin (24SW0763) consists of a small, partially collapsed log cabin located on a slope east of Iron Mountain. The cabin was built during the late 1800s by trappers and served as shelter, usually during winter month activities. The proposed drill site 28,500 W is located approximately eighty-five feet from the cabin. Access to the proposed drill site has not yet been determined.

The Horseman Flat/West Fork Road #2846 (24ST____/24SW____) courses across private and Forest Service administered lands for a distance of approximately 8.74 miles. This historic road was constructed or improved during various intervals dating to the early 1900s. Its progressive development coincided with early homesteading, logging, mining, and sheep-herding activities. Today, the Horseman Flat/West Fork Road #2846 exhibits a rough, unpaved surface character that receives only periodic maintenance as specific needs arise or limited funding becomes available.

SMC Iron Creek and West Fork Stillwater Exploration Plan of Operations 17

The Horseman Flat/West Fork Road #2846 is proposed for repair/maintenance and selective minimum-width widening.

No Action Alternative (Alternative 1)

Under this alternative there would be no effect to historic properties due to lack of ground disturbing activities associated with the proposed SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project or from helicopter support and access activities. No helicopter staging activities would occur at Site 1 adjacent to the Picket Pin Road #2140 or at Site 5 near the Moraine Edge Site (24ST0043) or the Rocky Pass Site (24ST0306), so there would be no effects to these sites. The existing cattle guard on Picket Pin Road #2140 would not be replaced at this time. The Picket Pin Road #2140 (24ST0392/24SW0640) would continue to receive periodic maintenance as specific needs arise or limited funding becomes available. This periodic road maintenance would be restricted to the present road prism width past the two Bryant Road termini (24ST0393/24SW0642), past the historic artifact scatter site (24SW0478), and through the Picket Pin Sawmill site (24SW0641) and would not result in any disturbance to these sites.

The Horseman Flat Road #2846 (24ST____/24SW____) would continue to receive periodic maintenance as specific needs arise or limited funding becomes available but would not receive any selective minimum-width widening. This periodic road maintenance would be restricted to the present road prism width near the cairn site (24ST0346) and would not result in any disturbance to the site. No exploratory drilling would be conducted at drill site 28,500 W near the Godtel-Gahl Cabin (24SW0763).

Site monitoring would occur on a five-year, or greater interval, rotation for at least the three NRHP eligible sites—the Picket Pin Road #2140 (24ST0392/24SW0640), the Bryant Road (24ST0393/24SW0642), and the Picket Pin Sawmill (24SW0641). The remaining six sites would be monitored on a less frequent interval.

Proposed Action Alternative (Alternative 2)

Under this alternative there would be exploration drilling over a six year period at up to thirty-six drill sites in the Iron Creek area and one drill site in the West Fork Stillwater River area. In addition, there would be six proposed helicopter staging areas for use in support of the Iron Creek area exploration program, routine maintenance on the Horseman Flat/West Fork Road #2846 and the Picket Pin Road #2140, selective minimum-width widening on the Horseman Flat/West Fork Road #2846, and installation of new drainage features and culverts and replacement of an existing cattle guard on the Picket Pin Road #2140. Table 3 shows the potential direct/indirect effects of Alternative 2 actions of known cultural resources.

Table 3. Potential Direct/Indirect Effects on Known Historic Properties for Alternative 2. Project Component Site Direct Effect Indirect Effect Helicopter staging area Site 24ST0043, 24ST0306 Increased access/vandalism 5 Moraine Edge & Rocky Pass to the sites Access road use on the 24ST0346 cairn Selective minimum-width Horseman Flat/West Fork widening of road would Road #2846 disturb site

SMC Iron Creek and West Fork Stillwater Exploration Plan of Operations 18

Helicopter staging area Site 24ST0392/24SW0640 Potential effect from 1 Picket Pin Road #2140 blading/prepping activity at proposed helicopter staging area Site 1 which is adjacent to the site Access road use on the 24ST0392/24SW0640 Possibly new drainage Vandalism to historic artifact Picket Pin Road #2140 Picket Pin Road #2140; features/culverts installed scatter and Picket Pin 24ST0393/24SW0642 and one existing cattle Sawmill during road Bryant Road termini; guard replacement on road; maintenance 24SW0478 historic artifact disturbance to Bryant Road scatter; termini; disturbance to 24SW0641 Picket Pin historic artifact scatter and Sawmill Picket Pin Sawmill during road maintenance Proposed drill site 28,500 W 24SW0763 Godtel-Gahl Disturbance to cabin during Increased access/vandalism Cabin drilling activity to cabin Access road use on the 24ST____/24SW____ Selective minimum-width Horseman Flat/West Fork Horseman Flat/West Fork widening of the road may Road #2846 Road #2846 alter its historic character

Direct Effects

Direct effects to a cairn (24ST0346) would consist of selective minimum-width widening of the Horseman Flat/West Fork Road #2846 at this site location. The cairn is located within thirty feet of the road. Direct effects to the Picket Pin Road #2140 (24ST0392/24SW0640) would consist of any new drainage feature, culvert, or existing cattle guard replacement proposed for installation during the implementation of the project, which may alter the character that make this road eligible to the NRHP. Blading/prepping activity for the use of helicopter staging area Site 1, located adjacent to the Picket Pin Road #2140 (24ST0392/24SW0640) may alter the character that make this road eligible to the NRHP.

Routine maintenance on the Picket Pin Road #2140, where it courses past the two Bryant Road termini (24ST0393/24SW0642), past the historic artifact scatter site (24SW0478), or through the Picket Pin Sawmill site (24SW0641) may damage or expose historic components or historic artifacts associated with these sites.

The proposed drill site 28,500 W has not yet been staked on the ground but tentative SMC coordinates place it within approximately 85.0 feet of the Godtel-Gahl Cabin (24SW0763). The cabin may be disturbed during access by the helicopter or drilling equipment or during drilling activity.

Selective minimum-width widening on the Horseman Flat/West Fork Road #2846 may alter the historic character of this road.

Indirect Effects

An indirect effect may occur to the Moraine Edge (24ST0043) and Rocky Pass (24ST0306) sites by increased access and/or vandalism to the site, and to the historic artifact scatter (24SW478) and the Picket Pin Sawmill (24SW0641) if routine road maintenance on the Picket Pin Road #2140 extends beyond the existing road prism and exposes historic features or artifacts that may be

SMC Iron Creek and West Fork Stillwater Exploration Plan of Operations 19

observed by travelers on the road. Vandalism to the Godtel-Gahl Cabin (24SW0763) may occur during drilling of the proposed site 28,500 W.

Design Features

Alternative 2 would not be in compliance with applicable cultural resource laws, regulations, policy, including the Forest Plans for the Custer National Forest and Gallatin National Forest. Nine cultural resource sites would be affected—either directly, indirectly, or both—under this alternative.

The sixth proposed helicopter staging area (Site 6) has not yet been determined, but a cultural resource inventory will be conducted when it is determined and prior to helicopter use activity.

Project implementation activities would cease immediately at any location where cultural resources are discovered, and the District Ranger and Forest Archaeologist would be notified. Project activity would resume only after authorized by the Forest Service.

Cumulative Effects

Agency Mitigated Proposed Action/Public Comment (Alternative 3)

Under this alternative—which includes the same exploration drilling over a six year period at up to thirty-six drill sites in the Iron Creek area and one drill site in the West Fork Stillwater River area, routine maintenance on the Horseman Flat/West Fork Road #2846 and the Picket Pin Road #2140, selective minimum-width widening on the Horseman Flat/West Fork Road #2846, and replacement of an existing cattle guard on the Picket Pin Road #2140 as described in Alternative 2—there would be at least seven proposed helicopter staging areas (Sites 1, 2, 3, 4, 6, 7, and 8). The proposed helicopter staging area Site 5 would be dropped. Additional helicopter staging area locations would be used at certain times of the year along the Limestone County Road and the Horseman Flat/West Fork Road #2846. Table 4 shows the potential direct/indirect effects of Alternative 3 actions of known cultural resources.

Table 4. Potential Direct/Indirect Effects on Known Historic Properties for Alternative 3. Project Component Site Direct Effect Indirect Effect Access road use on the 24ST0346 cairn Selective minimum-width Horseman Flat/West Fork widening of road would Road #2846 disturb site Helicopter staging area Site 24ST0392/24SW0640 Potential effect from 1 Picket Pin Road #2140 blading/prepping activity at proposed helicopter staging area Site 1 which is adjacent to the site Access road use on the 24ST0392/24SW0640 Possibly new drainage Vandalism to historic artifact Picket Pin Road #2140 Picket Pin Road #2140; features/culverts installed scatter and Picket Pin 24ST0393/24SW0642 and one existing cattle

SMC Iron Creek and West Fork Stillwater Exploration Plan of Operations 20

Bryant Road termini; guard replacement on road; Sawmill during road 24SW0478 historic artifact disturbance to Bryant Road maintenance scatter; termini; disturbance to 24SW0641 Picket Pin historic artifact scatter and Sawmill Picket Pin Sawmill during road maintenance Proposed drill site 28,500 W 24SW0763 Godtel-Gahl Disturbance to cabin during Increased access/vandalism Cabin access and drilling activity to cabin Access road use on and 24ST____/24SW____ Selective minimum-width helicopter staging area Horseman Flat/West Fork widening of the road may adjacent to the Horseman Road #2846 alter its historic character Flat/West Fork Road #2846

Direct Effects

Selective minimum-width widening on the Horseman Flat/West Fork Road #2846 and development/use of a proposed helicopter staging area may alter the historic character of this road.

Indirect Effects

An indirect effect may occur to the Picket Pin Sawmill (24SW0641) if routine road maintenance on the Picket Pin Road #2140 extends beyond the existing road prism and exposes historic features or artifacts that may be observed by travelers on the road. Vandalism to the Godtel-Gahl Cabin (24SW0763) may occur during drilling of the proposed site 28,500 W.

Cumulative Effects

Past and present exploration and development of minerals within the Stillwater Complex has created a Historic Mining Landscape consisting of the abandoned Mouat Mine and Mountain View Town Site, numerous smaller mining exploration activities, and the present Stillwater Mining

SMC Iron Creek and West Fork Stillwater Exploration Plan of Operations 21

Company operation (both the East Boulder Mine and the Stillwater Mine) which is focused on development, extraction, and processing of platinum group metals. Continued exploration and development of minerals would have a beneficial cumulative effect to this landscape by maintaining its function and protecting its integrity. Other activities including grazing, hazardous fuel reduction, road maintenance/repair, and recreation would continue and, to date, have had little effect to cultural resources in the SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project Area.

Conclusion

Summary of Alternatives

Alternative 1 would result in no disturbance to cultural resources due to lack of ground disturbing activities associated with the proposed SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project or from helicopter support and access activities. The Picket Pin Road #2140 and the Horseman Flat/West Fork Road #2846 would continue to receive only periodic maintenance as specific needs arise or limited funding becomes available. Site monitoring would occur on a five-year, or greater interval, rotation for at least the three NRHP eligible sites—the Picket Pin Road #2140 (24ST0392/24SW0640), the Bryant Road (24ST0393/24SW0642), and the Picket Pin Sawmill (24SW0641). The remaining six sites would be monitored on a less frequent interval.

Alternative 3 would remove proposed helicopter staging area Site 5 which would eliminate concerns at two cultural sites—Moraine Edge (24ST0043) and Rocky Pass (24ST0306). Mitigation efforts at the remaining seven sites would remove or reduce effects associated with the proposed SMC’s Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration Project. Monitoring would occur at all seven sites during the project. Table 5 presents a summary and comparison of the three alternatives.

Table 5. Summary and Comparison of Alternatives. Alternative Sites Affected Site Disturbance 1 None None

2 24ST0043 Increased access/vandalism to the site 24ST0306 Increased access/vandalism to the site 24ST0346 Disturbance to the site 24ST0392/24SW0640 Disturbance to the site 24ST0393/24SW0642 Disturbance to the site 24SW0478 Disturbance/vandalism to the site 24SW0641 Disturbance/vandalism to the site 24SW0763 Disturbance/vandalism to the site 24ST____/24SW____ Disturbance to the site

SMC Iron Creek and West Fork Stillwater Exploration Plan of Operations 22

3 24ST0346 Disturbance to the site 24ST0392/24SW0640 Disturbance to the site 24ST0393/24SW0642 Disturbance to the site 24SW0478 Disturbance/vandalism to the site 24SW0641 Disturbance/vandalism to the site 24SW0763 Disturbance/vandalism to the site 24ST____/24SW____ Disturbance to the site

The proposed helicopter staging area (Site 6, 7, and 8) locations have not yet been determined, but a cultural resource inventory will be conducted when they are determined and prior to helicopter use activity.

Consistency with Laws, Regulations, and Policy

Alternative 1 would be in compliance applicable cultural resource laws, regulations, policy, including the Forest Plans for the Custer National Forest and Gallatin National Forest.

Alternative 2 would not be in compliance applicable cultural resource laws, regulations, policy, including the Forest Plans for the Custer National Forest and Gallatin National Forest.

Formal consultation with the MTSHPO would be required for Alternative 3 to mitigate the potential adverse effects to historic properties and to ensure compliance with applicable law, regulation, and policy. Formal consultation with the Crow Cultural Committee would be required for Alternatives 3 in order to determine if proposed mitigation of potential adverse effects to one culturally sensitive site—24ST0346—is a proper and respectful mitigation option. Such consultation and implementation of any resultant required mitigations would result in Alternative 3 complying with applicable cultural resource laws, regulations, policy, including the Forest Plans for the Custer National Forest and Gallatin National Forest.

Consistency with Forest‐Wide Standards:

Alternative 1 would be in compliance applicable cultural resource standards in the Forest Plans for the Custer National Forest and Gallatin National Forest.

Alternative 2 would not be in compliance applicable cultural resource standards in the Forest Plans for the Custer National Forest and Gallatin National Forest.

With implementation of cultural resources mitigations listed above, Alternative 3 would be in compliance applicable cultural resource standards in the Forest Plans for the Custer National Forest and Gallatin National Forest.

Consistency with Management Area Standards:

None identified specific to cultural resources.

Other Laws, Regulations & Policy

SMC Iron Creek and West Fork Stillwater Exploration Plan of Operations 23

None identified specific to cultural resources. REFERENCES CITED

Annin, Jim. 1964. They Gazed on the Beartooths. Volume II. Reporter Printing & Supply Company, Billings, Montana. Beckes, M.R. and J.D. Keyser. 1983. The Prehistory of the Custer National Forest: An Overview. USDA Forest Service, Northern Region, Missoula, Montana.

Bergstrom, Mike W. 2001. Heritage Resource Review for the Stillwater Big Horn Sheep Habitat Project. Report #R2001010802014 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana.

Bergstrom, Mike W. 2004a. West Fork Stillwater Road #2846 Reconstruction. Project Effects Report #R2004010802020 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana.

Bergstrom, Mike W. 2004b. Rabbit Gulch Vault Toilet Replacement. Project Effects Report #R2004010802031 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana.

Bergstrom, Mike W. 2010a. Picket Pin Road retaining wall replacement and Picket Pin Creek Bridge installation. Project Effects Report #R2010010802019 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana.

Bergstrom, Mike W. 2010b. Initial Creek TrailR2010010802011. Project Effects Report #R2010010802011 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Bergstrom, Mike W. 2009. Picket Pin Road retaining wall replacement and Picket Pin Creek Bridge installation. Project Effects Report #R2010010802019 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Bergstrom, Mike W. 2013. Horseman Flats Fuels CE. Project Effects Report #R2013010802002 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Bergstrom, Mike W. 2016. Custer Gallatin National Forest Heritage Resource Program Site Record for 24SW0763 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Bergstrom, Mike W. 2017. Stillwater Mining Company’s (SMC’s) Iron Creek and West Fork of the Stillwater River Plan of Operations for Mineral Exploration. Report #R2017010802002 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Bonney, Orrin H. and Lorraine Bonney. 1970. Battle Drums and Geysers – the Life and Journals of Lt. Gustavus Cheyney Doane, Soldier and Explorer of the Yellowstone and Snake River Regions. Swallow Press, Inc., Chicago, Illinois. Clark, Wilson F. 1982. A General History of Custer National Forest. Manuscript on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Conner, Stuart W. 1962. Unusual Characteristics of the Keogh Buffalo Jump. In Symposium to Buffalo Jumps, Carling Malouf and Stuart Conner (editors). Montana Archaeological Society Memoir No. 1, pp. 8-11. Czamanske, Gerald K. and Michael L. Zientek (Technical Editors). 1985. The Stillwater Complex, Montana: Geology and Guide. Special Publication 92. Printed December 1989 by Advanced Litho Printing, Great Falls, Montana.

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Deaver, Sherri and Ann Kooistra-Manning. 1995. Ethnographic Overview of the McKenzie, Medora, Sioux, Ashland and Beartooth Ranger Districts of the Custer National Forest. Prepared by Ethnoscience, Billings, Montana. Manuscript on file at the Supervisor's Office, Custer National Forest, Billings, Montana. Frison, G.C. 1991. Prehistoric Hunters of the High Plains. Academic Press, New York, New York. GCM. 1990. Cultural Resource Inventory and Evaluation of the Benbow Mine and Mill and the Mouat Mine in the Stillwater Complex, Stillwater County, Montana. Report #R1980010802002 prepared by GCM Services, Inc., Butte, Montana for the Montana Department of State Lands, Helena, Montana. Manuscript on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Greiser, Sally T. and Heidi Plochman. 1981. Archaeological Investigations at the West Rosebud Lake Archaeological Site (24ST651). Manuscript on file at the Supervisor's Office, Custer National Forest, Billings, Montana. Husted, Wilfred M. 1990. The Beartooth Alpine Archeology Project: Annual Report to the Regional Forester, 1990. Manuscript on file at the Supervisor's Office, Custer National Forest, Billings, Montana. Husted, Wilfred M. 1991. The Beartooth Alpine Archeology Project: Annual Report to the Regional Forester, 1991. Manuscript on file at the Supervisor's Office, Custer National Forest, Billings, Montana. Husted, Wilfred M. 1992. The Beartooth Alpine Archeology Project: Preliminary Observations and Suggestions for Future Research. Manuscript on file at the Supervisor's Office, Custer National Forest, Billings, Montana. Husted, Wilfred M. 1993. The Beartooth Alpine Archeology Project: Annual Report to the Regional Forester, 1992. Manuscript on file at the Supervisor's Office, Custer National Forest, Billings, Montana. Koenig, Orrin. 2004. Beartooth District Travel Management Plan – road inventory. Project Effects Report #R2008010802004 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 1980. Class III Cultural Resource Evaluations of the Johns-Manville Mineral Claims Area: Stillwater Complex, Montana. Anthro Research, Inc., Livingston, Montana. Manuscript on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 1997. Cultural Resource Investigations – Stillwater Mining Company Slurry Line Route & Tailings Pond Area, Stillwater County, Montana, 1987. Anthro Research, Inc., Livingston, Montana. Manuscript on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 1999. Cultural Resource Compliance Investigations – Hertzler Tailings Impoundment Area, Stillwater Mining Company, Stillwater County, Montana, 1999 Field Season. Anthro Research, Inc., Livingston, Montana. Manuscript on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 2001a. Cultural Resource Reconnaissance Evaluations – Idaho Consolidated Crescent Creek Core Locations and Heli-pad. Anthro Research, Inc., Livingston, Montana. Manuscript on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 2001b. Cultural Resource Reconnaissance Evaluations – Idaho Consolidated Iron Creek Core Holes. Anthro Research, Inc., Livingston, Montana. Manuscript on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 2003a. Research Design and Mitigation Plan for the Rocky Pass Site (24ST306) Moraine Edge Site (24ST43). Volume 3. Anthro Research, Inc. Livingston, Montana. Manuscript on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana.

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Lahren, Larry. 2003b. Stillwater Time – An Overview of 11,500 Years of Human Adaptation and Change in the Stillwater Valley Area of Montana. Manuscript on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Dr. Larry. 2008. Homeland: An archaeologist’s view of Yellowstone Country’s past. Cayuse Press, Livingston, MT. Lahren, Larry. 2012a. Cultural Resource Evaluations of the Proposed Iron Creek 35.5 DDH Core-Drill Location, Stillwater Complex, Custer National Forest, Stillwater County, Montana. Anthro Research, Inc., Livingston, Montana, October 8, 2012. Report #R2015010802041-01 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 2012b. Cultural Resource Evaluations of the Proposed Iron Creek 36.5 DDH Core-Drill Location, Stillwater Complex, Custer National Forest, Stillwater County, Montana. Anthro Research, Inc., Livingston, Montana, October 8, 2012. Report #R2015010802041-02 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 2012c. Cultural Resource Evaluations of the Proposed Iron Creek 37.5 DDH Core-Drill Location, Stillwater Complex, Custer National Forest, Stillwater County, Montana. Anthro Research, Inc., Livingston, Montana, October 8, 2012. Report #R2015010802041-03 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 2012d. Cultural Resource Evaluations of the Proposed Iron Creek 38.5 DDH Core-Drill Location, Stillwater Complex, Custer National Forest, Stillwater County, Montana. Anthro Research, Inc., Livingston, Montana, October 8, 2012. Report #R2015010802041-04 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 2012e. Cultural Resource Evaluations of the Proposed Iron Creek 39.5 DDH Core-Drill Location, Stillwater Complex, Custer National Forest, Stillwater County, Montana. Anthro Research, Inc., Livingston, Montana, October 8, 2012. Report #R2015010802041-05 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 2012f. Cultural Resource Evaluations of the Proposed Iron Creek 40.5 DDH Core-Drill Location, Stillwater Complex, Custer National Forest, Stillwater County, Montana. Anthro Research, Inc., Livingston, Montana, October 8, 2012. Report #R2015010802041-06 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 2012g. Cultural Resource Evaluations of the Proposed Iron Creek 41.5 DDH Core-Drill Location, Stillwater Complex, Custer National Forest, Stillwater County, Montana. Anthro Research, Inc., Livingston, Montana, October 8, 2012. Report #R2015010802041-07 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 2012h. Cultural Resource Evaluations of the Proposed Iron Creek 42.5 DDH Core-Drill Location, Stillwater Complex, Custer National Forest, Stillwater County, Montana. Anthro Research, Inc., Livingston, Montana, October 8, 2012. Report #R2015010802041-08 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 2012i. Cultural Resource Evaluations of the Proposed Iron Creek 42.5 Alternate DDH Core-Drill Location, Stillwater Complex, Custer National Forest, Stillwater County, Montana. Anthro Research, Inc., Livingston, Montana, October 8, 2012. Report #R2015010802041-09 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 2012j. Cultural Resource Evaluations of the Proposed Iron Creek 43.5 DDH Core-Drill Location, Stillwater Complex, Custer National Forest, Stillwater County, Montana. Anthro Research, Inc., Livingston, Montana, October 8, 2012. Report #R2015010802041-10 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana.

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Lahren, Larry. 2012k. Cultural Resource Evaluations of the Proposed Iron Creek 44.5 DDH Core-Drill Location, Stillwater Complex, Custer National Forest, Stillwater County, Montana. Anthro Research, Inc., Livingston, Montana, October 8, 2012. Report #R2015010802041-11 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 2012l. Cultural Resource Evaluations of the Proposed Iron Creek 45.5 DDH Core-Drill Location, Stillwater Complex, Custer National Forest, Stillwater County, Montana. Anthro Research, Inc., Livingston, Montana, October 8, 2012. Report #R2015010802041-12 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 2012m. Cultural Resource Evaluations of Twelve Proposed Iron Creek Core-Drill Locations, Stillwater Complex, Custer National Forest, Stillwater County, Montana. Anthro Research, Inc., Livingston, Montana, October 8, 2012. Report #R2015010802041-01 thru 12 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. (Anthro Research evaluated 48.0 acres of access road corridor during the evaluation of twelve proposed drill locations) Lahren, Larry. 2012n. Cultural Resource Evaluations of Component III of the Stillwater Mining Company Fat Tire/Benbow Decline Portal Project, Stillwater County, Montana. Anthro Research, Inc., Livingston, Montana, May 16, 2012. Report #R2012010802018 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 2014a. Cultural Resource Evaluations of Stillwater Mining Company’s Iron Mountain Exploratory Core-Drilling Block Areas 1 & 2, Sweet Grass County, Montana. Anthro Research, Inc., Livingston, Montana, October 6, 2014. Report #R2015010802016 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lahren, Larry. 2014b. Cultural Resource Evaluations of the Proposed Stillwater Mining Company 18400W DDH Core-Drilling Block, Custer National Forest, Sweet Grass County, Montana. Anthro Research, Inc., Livingston, Montana, October 17, 2014. Report #R2015010802040 on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Lee, Craig M., Ph.D. 2012. Final Report of Ice Patch Investigations (2006-2011) on the Custer and Gallatin National Forests, Montana, and the Shoshone National Forest, Wyoming (Draft). Prepared at Institute of Artic and Alpine Research (INSTAAR), University of Colorado, Boulder. Prepared for USDA Forest Service, Custer, Gallatin and Shoshone National Forests, Bozeman and Billings, Montana and Cody, Wyoming. Mulloy, W. 1943. A Prehistoric Campsite Near Red lodge, Montana. American Antiquity, Volume 9, Number 2. USDA Forest Service (USDA-FS). 1986. Custer National Forest and National Grasslands Land and Resource Management Plan, United States Department of Agriculture, Forest Service, Billings, Montana. USDA Forest Service (USDA-FS). 1987. Gallatin National Forest, Forest Plan, United States Department of Agriculture, Forest Service, Bozeman, Montana. USDA Forest Service (USDA-FS). 2016. In prep site form 24ST____/24SW____ (Horseman Flat/West Fork Road #2846) by Mike W. Bergstrom. On file at the Billings Office, Custer Gallatin National Forest, Billings, Montana.

Warhank, Josef (Review and Compliance Officer, Montana State Historic Preservation Office). 2010a. Stamp of concurrence, dated 5/5/2010, on two-page letter (dated April 19, 2010), to Mark Baumler (Montana State Historic Preservation Officer) from Traute Parrie (Beartooth District Ranger) on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana.

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Warhank, Josef (Review and Compliance Officer, Montana State Historic Preservation Office). 2010b. Stamp of concurrence, dated 5/26/2010, on one-page letter (dated May 3, 2010), to Mark Baumler (Montana State Historic Preservation Officer) from Traute Parrie (Beartooth District Ranger) on file at the Billings Office, Custer Gallatin National Forest, Billings, Montana. Wolle, Muriel Sibell. 1963. Montana Pay Dirt, A Guide to the Mining Camps of the Treasure State. Sage Books, Denver, Colorado.

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