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Last Updated:
03/21/2013 17:37:54 MDT
FAQs 
 
 
 

What is the United Comstock Merger Mill at American Flat (AFM)?

The AFM (originally named the United Comstock Merger Mill) was built in 1922 to process local gold and silver ore using a cyanide solution and the Merill-Crowe process (a separation technique for removing gold from a cyanide solution). The mill operated from 1922 to 1926 and produced $7.5 million worth of silver and gold. Over its short life, the mill was owned by two different corporate entities, the United Comstock Mines and the Comstock Merger Mines. At the time it operated, AFM was considered the largest, most modern and sophisticated mill of its type in the U.S. The mill was shut down due to metallurgical problems and the dropping price of silver. When the mill closed, all equipment, metal, and wood materials were scrapped and salvaged. During the salvaging process, little care was taken in the removal of equipment and other materials. Concrete structural components were cut and broken as required to facilitate the removal process, resulting in a great deal of damage. Large holes and voids were left in the concrete, reinforcing steel was cut, and concrete structural members were broken.

Today the existing structures at the site consist of badly decaying concrete, exposed reinforcing steel, broken structural members, and large holes in the concrete floors; only the deteriorated concrete skeletons of the structures remain.

Is the AFM site open to the public?

A fatality occurred at the site in 1996 while an individual was ‘crawling’ stairs with an all-terrain vehicle (ATV) inside one of the AFM structures. In response, the BLM officially closed the interior of the AFM buildings to public entry on January 21, 1997. In addition to closing the interior of the AFM structures to public entry, the closure order also banned: use of fireworks; detonation of explosive devices or rockets; painting of graffiti and possession of paint or spray paint cans; and restricted motorized vehicles to existing dirt roads. The closure order further restricted use of the AFM site to daylight hours only (sunrise to sunset). Although the interior of the structures are closed to public entry, the site is open to passive viewing from outside existing fencing.

Has the AFM site been assessed for its physical hazards to the public?

A 2008 audit of the site by the Department of the Interior, Office of Inspector General (OIG) found the property to be a high-risk liability to the U.S. Government. In 2010 under contract by the U.S. Army Corps of Engineers, a report was prepared that identified the following types of physical hazards to be present, including but not limited to: falling or collapsing concrete structures; underground mill sumps filled with water; unmarked voids and tunnels; and holes in the concrete flooring.

What is the historical status of the AFM site?

The AFM site is within the boundary of the Virginia City National Historic Landmark (Landmark) and Virginia City National Register District (District). The AFM site was a ruin at the time the District was designated as a Landmark in 1961. The AFM is the last remnant of the United Comstock and the Comstock Merger mining and milling operations and as such contributes to the eligibility of the District under Criteria A and C. The AFM is also locally eligible under Criterion B.

Other historic features associated with AFM include: roads; a rock quarry pit and crusher; a series of terraces; a cement tank; several refuse dumps; an internal railroad spur; and a V&T Railroad spur. The railroad spurs are contributing elements to the V&T Railroad under Criteria A, C, and D. The quarry, crusher, and cement tank are contributing elements to the District under Criterion A. In addition, the quarry and cement tank are locally eligible under criterion B and the crusher is locally eligible under Criteria B and D. The terraces, roads, refuse dumps, and cyanide drum dumps are not eligible under any Criteria and none of the existing graffiti appears to be more than 50 years old, and the BLM in consultation with the SHPO, has determined that graffiti is not eligible for listing under any Criteria.


 The National Register's standards for evaluating the significance of properties were developed to recognize the accomplishments of all peoples who have made a significant contribution to our country's history and heritage. The criteria are designed to guide State and local governments, federal agencies, and others in evaluating potential entries in the National Register.

Criteria for Evaluation.  The quality of significance in American history, architecture, archeology, engineering, and culture is present in districts, sites, buildings, structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling, and association, and:

A. That are associated with events that have made a significant contribution to the broad patterns of our history; or
B. That are associated with the lives of persons significant in our past; or
C. That embody the distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or
D. That have yielded or may be likely to yield, information important in prehistory or history.

What is a Programmatic Agreement under the National Historic Preservation Act?

Under 36 CFR 800 and specifically Part 800.6 (a) an "agency official shall consult with the SHPO/THPO and other consulting parties, including Indian tribes and Native Hawaiian organizations, to develop and evaluate alternatives or modifications to the undertaking that would avoid, minimize or mitigate adverse effects on historic properties."  In the Programmatic Agreement (PA) executed on March 5, 2012 between the BLM, State Historic Preservation Officer, Advisory Council on Historic Preservation, and other consulting parties agreed to the following: "the BLM has consulted with the SHPO under, and in accordance with, Section 106 of the National Historic Preservation Act, 16 U.S.C. Part 470 (NHPA), and its implementing regulations (36CFR Part 800) to resolve the adverse effects of the Undertaking on historic properties."  The selection of any of the EA alternatives would constitute an adverse effect to the Landmark, District and AFM.  As a part of the PA, stipulations (mitigation) were agreed to by all parties for all alternatives considered.

Mitigation included in the PA varies depending on the alternative.  Measures agreed to in the PA include: publication of interpretive brochures; installation of wayside exhibits; and/or developing a high definition video documentary.  For more details on the measures included in the PA see the Documents section.