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MINNESOTA STATE HISTORIC PRESERVATION OFFICE 50 Sherburne Avenue ▪ Administration Building 203 ▪ Saint Paul, Minnesota 55155 ▪ 651-201-3287 mn.gov/admin/shpo ▪ mnshpo@state.mn.us AN EQUAL OPPORTUNITY AND SERVICE PROVIDER June 10, 2025 Zack Carlton Community Development Director City of Elk River 13065 Orono Parkway Elk River, MN 55330 RE: EAW - Oakwater Ridge Residential/Commercial Development Project T32 R26 S11 & S14, Elk River, Sherburne County SHPO Number: 2025-1197 Dear Zack Carlton: Thank you for providing this office with a copy of the Environmental Assessment Worksheet (EAW) for the above-referenced project. According to the EAW, the proposed residential/commercial development will include the construction of 536 single-family residential homes, a commercial parcel likely consisting of a multi-tenant retail strip and gas station, a river overlook, an open space/recreational area, a future trail, a greenway corridor, and stormwater and other infrastructure. As stated in the EAW, the proposed development is located immediately adjacent to the Oliver H. Kelley Homestead, which is a National Historic Landmark, is listed in the National Register of Historic Places, and is also part of the State Historic Site Network. We understand that the developer and the city have been consulting with the Minnesota Historical Society (MNHS) and that the historic farm and modern visitor center are located downhill from any open sight lines to the proposed development. MNHS has informed us that they have been working with the developer and the city on measures to help minimize any effects to the historic property, which include planting trees to help screen the development as people drive into the Historic Site and installing a split rail wood fence along the development’s southern property line. We agree that these appear to be reasonable measures to minimize any adverse effects to the historic property. We recommend that the city and the developer continue to work with MNHS as the design for the project proceeds to ensure that any effects to the historic property are considered, especially any visual effects to the historic farmstead’s rural setting. We have reviewed the submitted survey report, Phase I Archaeological Survey for the Oakwater Ridge Project, Sherburne County, Minnesota (April 14, 2025) as prepared by In Situ Archaeological Consulting. According to the report, one archaeological site was identified during the investigations, site 21SH0093. More information is needed about the survey methodology and archaeological site 21SH0093. The shovel test methods as described in the report do not meet current survey standards and guidelines because they do not extend into the C horizon. The report incorrectly states that digging into the B horizon is sufficient. Both the A and B horizons are part of Holocene-age soil development, and therefore both have the potential to contain archaeological materials. The C horizon is the parent material for the soil (either bedrock or Pleistocene-age sediments such as glacial till). The standard of