1

Kelly, Shaheerah

From: Saanii <dinetahdoo@yahoo.com>

Sent: Monday, February 09, 2015 11:34 AM

To: Kelly, Shaheerah

Subject: RE: Report for McElmo Flare

Shaheerah,

Ok, we are going to hand carry the report to the NNHPD tomorrow. We have a meeting with them on another project.

Rena Martin

Dinetahdoo Cultural Resources Management, LLC P.O. Box 2012, Farmington NM 87499

10076 US Hwy 371, S of Farmington, NM

Phone (505) 960‐9478Fax (505) 960‐9749

Email dinetahdoo@yahoo.com

Website: www.dinetahdoo.com

‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 

On Mon, 2/9/15, Kelly, Shaheerah <Kelly.Shaheerah@epa.gov> wrote:

Subject: RE: Report for McElmo Flare

To: "Saanii" <dinetahdoo@yahoo.com>

Date: Monday, February 9, 2015, 12:00 PM

  

Rena,

  

You can move forward on the report. I will  follow up with the applicant separately if necessary.  

  

Thanks.

  

************************************

Shaheerah Kelly

Permits Office,

Air Division (AIR‐3)

U.S. Environmental

Protection Agency, Region 9

San Francisco,

CA 94105

Phone: 415‐947‐4156

Fax: 415‐947‐3579

Email: kelly.shaheerah@epa.gov

  

 ‐‐‐‐‐Original Message‐‐‐‐‐ 

From: Saanii [mailto:dinetahdoo@yahoo.com]

  

Sent: Monday, February 09, 2015 9:56 AM

To: Kelly, Shaheerah

Subject:

RE: Report for McElmo Flare

  
2

Good morning Shaheerah,

I am

wondering what your thoughts are on this project. I really  need to invoice Resolute for this portion of work and I do  

not know if I should call it "final" and send the  report into NNHPD TCP or wait on your advisement.

  

Rena Martin

  

Dinetahdoo Cultural Resources

Management, LLC P.O. Box 2012, Farmington NM 87499

10076 US Hwy 371, S of Farmington, NM

Phone (505) 960‐9478Fax (505) 960‐9749

Email dinetahdoo@yahoo.com

Website: www.dinetahdoo.com

  

 ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 

On Fri, 2/6/15, Kelly, Shaheerah <Kelly.Shaheerah@epa.gov>

wrote:

  

  Subject: RE: Report

for McElmo Flare

  To: "Saanii"

<dinetahdoo@yahoo.com>

  Date: Friday, February 6, 2015, 2:18 PM

   

  Rena, thanks for the

  opportunity to review and comment on the  report. I apologize  for the delay in getting back to you.

Below are my comments  on the report. Feel free to contact  me if you have any  questions or would like to discuss  

them. Thanks.

   

  1. The

first page states

  "Confidential

Report". Are you claiming the report  to be  confidential business information (CBI)?  If so, and  the  EPA receives a

Freedom of Information Act (FOIA) request  for the report, we will have to ask you to substantiate  your  claim of CBI.  

EPA will review your substantiation  and  determine if the report is CBI.  If it is determined  to be  CBI, the EPA will not

release the report to the  public; but  if EPA determines it is not CBI the document  will be  released (barring the

initiation of legal

action).     

   

  2.

Pursuant to Section 106 of

  the National

Historic Preservation Act (NHPA), and its  implementing  regulations at 36 CFR Part 800, prior to  approval of the  

undertaking, EPA is required to take into  account the  effects of its undertakings on historic  properties. Page

10 of the draft report states  "Pursuant to  consultations between the US EPA and  NNHPD, the Navajo  Nation's

Traditional Cultural Program  decided to  concentrate on the potential effects of this  undertaking  on traditional lifeways

and traditional cultural  places  within a 50 km radius of the main flare, and to  require  consultation with traditional

practitioners who  perform  cultural activities within this area radius."  It also  states "NNHPD decided not to require  

consideration of  archaeological resources within this 50 km  radius area  except for any that are also considered  

traditional  cultural places in the literature or the  interviews."
3

There is a question whether the radius is  appropriate  given the nature and scope of the project. We  understand  you

have already completed much field work on  traditional  lifeways and traditional cultural places. We  would like to  

discuss whether a smaller radius is more  appropriate (e.g.

1 km or 5 km) for evaluating potential  effects of the  undertaking on historic properties within the  smaller  radius. If

this is feasible, we would need to get  agreement from the parties involved (i.e., THPO, Resolute,  and EPA), and have

this information included in the  report.

   

  3. It is not

clear

  whether the recommendations on pages

18‐19 are adverse  impacts on historic properties. Is it  your position that  there will be adverse effects on  historic

properties? If  there are going to be adverse  impacts on historic  properties, it will likely necessitate  the need for all of  

the appropriate parties to enter into  a memorandum of  agreement in order to delineate the  mitigation measures  

which must be followed.  

   

  4.

  Part of

the address (i.e., the city, state, and zip code)  for  Resolute Energy Company is missing from the cover page  of  the

report.

   

  

************************************

  

Shaheerah Kelly

  Permits Office,

  Air Division (AIR‐3)

  U.S.

Environmental

  Protection Agency, Region

9

  San Francisco,

  CA

94105

  Phone: 415‐947‐4156

  

Fax: 415‐947‐3579

  Email: kelly.shaheerah@epa.gov

   

  ‐‐‐‐‐Original

Message‐‐‐‐‐ 

  From: Saanii [mailto:dinetahdoo@yahoo.com]

   

  Sent: Friday, February 06,

2015 8:39 AM

  To: Kelly, Shaheerah

  Subject:

  RE: Report for

McElmo Flare

   

  

Shaheerah,

   
4

  It

  is always good to get a report off our desks  so I am waiting  on you move. Resolute Natural Resources,  LLC completed

their  review and basically the report is  ready to be submitted to  the Navajo Nation Historic  Preservation Department

for  complianre review.

   

  Rena  

   

  Dinetahdoo Cultural Resources

  

Management, LLC P.O. Box 2012, Farmington NM 87499

  10076 US Hwy 371, S of Farmington, NM

  Phone (505) 960‐9478Fax (505) 960‐9749

  Email dinetahdoo@yahoo.com

  Website: www.dinetahdoo.com

  

  

  

 ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 

  On Thu, 2/5/15, Kelly, Shaheerah <Kelly.Shaheerah@epa.gov>

  wrote:

   

   

Subject: RE: Report

  for McElmo Flare

   To: "Saanii"

  

<dinetahdoo@yahoo.com>

   Date: Thursday, February 5, 2015, 6:40 PM

    

   Rena,  

    

   I apologize for the

delay and

   

  will try to get

back to you tomorrow on the report. Please  let me know if  this is fine with you.

    

   Thanks.

    

  

  

  ************************************

   

  Shaheerah Kelly

   Permits Office,

   Air

Division (AIR‐3)

   U.S.

  

Environmental

   Protection Agency,

Region
5

  9

   San

Francisco,

   CA

  94105

   Phone: 415‐947‐4156

   

  Fax: 415‐947‐3579

   Email: kelly.shaheerah@epa.gov

    

   ‐‐‐‐‐Original

  Message‐‐‐‐‐ 

   From: Saanii

[mailto:dinetahdoo@yahoo.com]

    

   Sent: Thursday, January

29,

  2015 1:36 PM

   To:

Kelly, Shaheerah

   Subject:

   Re: Report for

  McElmo

Flare

    

   Hello

  Shaheerah,

    

   The report is

  attached for

your review. Please  add any names or  statements. As I  have been telling you,  this was a very  interesting  project. We

tried our best to  cover what the  NNHPD  wanted. If you need to discuss anything  I am here at  the  office today and

tomorrow.

    

   I will send you a copy of the

   

  fieldnotes without the names

shortly too.  

   

   

   Rena Martin

    

   Dinetahdoo Cultural Resources

   

  Management, LLC P.O. Box

2012, Farmington NM 87499

   10076 US Hwy

371, S of Farmington, NM

   Phone (505)

960‐9478Fax (505) 960‐9749

   Email dinetahdoo@yahoo.com

   Website:
6

   

  

www.dinetahdoo.com