4.4 EAW Attachment - Laserfiche WebLink

Home Browse Search

Oakwater Ridge EAW 2 Findings of Fact and Conclusions, Response to Comments, and Record of Decision RESPONSES TO COMMENTS The following information and clarifications are provided in response to all EAW comments received during the 30-day comment period. Comment responses are provided in italicized text. Letter 1: State Historic Preservation Office Comment 1: 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. Response: So noted. Thank you for the comment. Comment 2: 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 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. Response: In Situ based their investigation methods from the well documented concept that based on soil formation processes, within upland areas and/or areas with minimal to no deposition, archaeological material ranging from as early as the Paleoindian Period to present, are typically located at the ground surface or are shallowly buried. The Principal Investigator concluded that the shovel testing depths for the project were sufficient for the identification of archaeological sites during the Phase I shovel testing, as there is a low potential for deeper archaeological deposits within the uplands. In consultation for previous projects with SHPO and OSA, In Situ was informed that a Principal Investigator may deviate from the methods outlined in the guidelines, as long as the Principal Investigator can justify the change in methodology in the report, which was the case for this project. However, after recent consultations with OSA and SHPO, In Situ will implement these methodology comments moving forward. Regarding the shovel test size, the shovel test shown in the report was 40 cm in diameter with strait walls. Unfortunately, photographs may not portray these factors well, as the topsoil in the hole may blend in with the ground surface making the hole look narrower. Also in photographs, the walls of the shovel test can have a “tunnel” effect, making the walls appear smaller at the bottom. In Situ does have additional photographs of the shovel test with another ruler/scale to show the width of the shovel test.