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digging into the C horizon, or encountering it in the case of bedrock, is to demonstrate that the sample from the shovel test addresses the entire time period when archaeological materials might be present. Also, the report states that the shovel tests are 30-40 cm in diameter, but the photos of representative shovel tests appear to be at the lower end of that or smaller. It is difficult to be certain from the photographs, but it also appears that the diameter is smaller at the bottom than at the top. It is likely that 40 cm diameter tests would be needed for the sample to reach into the C horizon in this area. Archaeological site 21SH0093 is identified as 21CA0794 in the report section header (pg. 25). We assume this is a typo. Based on the information provided in the report, we do not agree with the consultant's recommendation that the site is not eligible for listing in the National Register of Historic Places (NRHP). We recommend that either a Phase II evaluation of the site be conducted to determine the site's eligibility for listing in the NRHP, or the site area be protected and preserved during the development. For a Phase II evaluation, a 1x1 formal excavation unit is the most effective method for assessing the site's historic context and integrity. To make an argument regarding Criterion D significance (or lack thereof), we recommend using the historic context document for lithic scatters, because it provides established guidelines for this type of site. This and related documents are available at the State Historic Preservation Office if needed. In our opinion, applying the lithic scatter context with a sample that includes a formal excavation unit should be sufficient to make a defensible statement regarding the site's eligibility for listing in the NRHP. Please note that this comment letter does not address the requirements of Section 106 of the National Historic Preservation Act of 1966 and 36 CFR § 800. If this project is considered for federal financial assistance, or requires a federal permit or license, then review and consultation with our office will need to be initiated by the lead federal agency. Be advised that comments and recommendations provided by our office for this state -level review may differ from findings and determinations made by the federal agency as part of review and consultation under Section 106. If you have any general questions regarding our comments, please contact Kelly Gragg-Johnson, Environmental Review Specialist, at For questions regarding archaeology, please contact David Mather, SHPO National Register Archaeologist, at david.mather@s.. Sincerely, e Amy Spong Deputy State Historic Preservation Officer cc: Ben Leonard, Senior Vice President of Historic Sites Network & Operations, Minnesota Historical Society