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DSEIS-Appendix-E_Summary-of-Cultural-Resources-Studies-Relative-to-Modified-Project.pdf
memorandum To: Marguerite Wells EDR Project No: 11060 From: Nicholas Freeland, RPA and Patrick Heaton, RPA Date: January 13, 2016 Reference: Black Oak Wind Farm Summary of Cultural Resources Studies Relative to Modified Project Layout Comments: This memorandum serves to summarize cultural resources studies conducted to date for the proposed Black Oak Wind Farm (the Project), located in the Town of Enfield, in Tompkins County, New York. Specifically, this memorandum addresses the findings and conclusions of previous cultural resources studies relative to recent changes to the Project layout that have occurred since the conclusion of the State Environmental Quality Review Act (SEQRA) permitting process. This summary was prepared by Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services, D.P.C. (EDR) cultural resources staff who meet the qualifications specified by the Secretary of the Interior’s Standards for Historic Preservation and Archaeology per 36 CFR Part 61. Following the submittal and acceptance of the Final Environmental Impact Statement (FEIS) and issuance of SEQRA Findings by the Town of Enfield Town Board (the SEQRA Lead Agency), ongoing landowner negotiations resulted in several changes to the Project layout. Therefore, a second Draft Environmental Impact Statement (DEIS 2) is being prepared to address the necessary modifications to the Project. Consistent with the requirements of SEQRA, the DEIS 2 will contain a comparative analysis of potential adverse impacts of the proposed modifications with the impacts of the permitted Project as analyzed in the original DEIS dated June 12, 2013, the FEIS dated November 12, 2014, and the Findings Statement issued by the Town of Enfield on January 14, 2015. This memorandum summarizes the information regarding cultural resources contained within the Approved Project Record. For clarification, the Project as previously proposed and approved is referred to as the “Approved Project”, whereas the currently proposed Project layout is referred to as the “Modified Project”. The Approved Project would generate 11.9 megawatts (MW) of electricity and consisted of seven GE 1.7 -100 model wind turbines, one wind measurement tower (meteorological tower), a system of gravel access roads, buried and above ground electrical collection lines (interconnect), a substation next to the existing NYSEG 115 kilovolt (kV) transmission line, and tow temporary construction staging areas. The Approved Project was addressed in the SEQRA Findings Statement issued by the Town of Enfield Town Board, as Lead Agency, on January 14, 2015. Subsequent to the issuance of the SEQRA Findings Statement, the Town Board passed a resolution on July 8, 2015, through a SEQRA review, a modification of the Approved Project wind turbine model from a GE 1.7 – 100 to a GE 2.3 – 107 which resulted in an increase in electrical generation capacity from 11.9 MW to 16.1 MW. The Modified Project will generate 16.1 MW of electricity and consist of seven GE 2.3 – 107 model wind turbines. The Modified Project will have the same ancillary facilities as the Approved Project including access roads, electrical collection lines, a substation, and one construction staging area. However, the Applicant, Black Oak Wind LLC (Black Oak Wind), proposes minor modifications to the locations of some project components. The specific changes are: Black Oak Wind – Cultural Resources Summary January 13, 2016 Page | 2 1) Relocation of two turbines (T2 and T7) to three possible locations (designated A, B and C) with associated access roads and collection lines. Location A is in the Town of Newfield. Locations B&C are in the Town of Enfield. 2) Shift of turbine T5 approximately 100 feet to the east to comply with GE recommended setback for ice throw. 3) Relocation of substation to new location with associated access road in Town of Enfield. 4) Addition of a new permanent 308-ft (94-m) tall wind measurement (meteorological) tower just south of turbine T4. 5) Relocation of approximately 2,200 linear feet of buried collection line between turbines T4 and T5. 6) Relocation of approximately 6,200 linear feet of buried collection line between turbines T5 and T6 and new substation location. This memorandum addresses modifications to the Black Oak Wind Farm and describes the potential impacts of those modifications to cultural resources in direct comparison to the Approved Project that was reviewed pursuant to SEQRA. The following table summarizes the Approved and Modified Project Layouts. Table 1. Comparison of Approved and Modified Project Layouts Project Component Approved Project Layout Modified (Current) Project Layout Wind Turbine Model GE 2.3 – 107 GE 2.3 – 107 Number of Wind Turbines 7 7 (although evaluating a total of 8 potential locations) Number of Met Towers 0 1 Length of Access Roads 2.7 No more than 3.2 miles (depending on which alternate turbine locations are developed) Length of Collection Lines 4.1 No more than 4.7 miles (depending on which alternate turbine locations are developed) Staging Areas 2 1 Substation 1 1 Summary of Cultural Resources Studies to Date: In the late winter of 2013, EDR prepared a Phase 1A Cultural Resources Survey on behalf of the Applicant which identified no previously recorded archaeological sites within the Project site or within 1 mile of the Project site (EDR, 2013). The Phase 1A report was submitted to the New York State Office of Parks, Recreation, and Historic Preservation (NYSOPRHP), in their capacity as State Historic Preservation Office (SHPO) on March 5, 2013, thereby initiating consultation with SHPO for the Project. NYSOPRHP responded on April 2, 2013, stating their concurrence with the findings and recommendations contained within the Phase 1A report (Perazio, 2013a) On June 13, 2013, the State University of New York, Binghamton, Public Archaeology Facility (PAF), submitted a Phase 1B Methodology, Testing Proposal and Structure Visibility Estimate for the Project (PAF, 2013a) to the NYSOPRHP on behalf of the Applicant. NYSOPRHP responded to the submission on July 17, 2013 stating their concurrence with the work plan contained within the report (Perazio, 2013b) On August 29, 2013, PAF submitted a Phase 1B archaeological reconnaissance report to NYSOPRHP (PAF, 2013b), on behalf of the Applicant. For the Phase 1B archaeological survey, PAF surveyed seven turbine locations, one meteorological tower location, one substation, one staging area, approximately 2.7 miles of access roads, and Black Oak Wind – Cultural Resources Summary January 13, 2016 Page | 3 approximately 1.3 miles of interconnect, totaling approximately 38 acres. For the survey, PAF excavated 643 shovel tests at 5-meter intervals within selected areas and conducted approximately 2.8 acres of pedestrian survey. No historic or prehistoric archaeological sites were identified during the Phase 1B archaeological reconnaissance survey. In review correspondence dated October 22, 2013, NYSOPHRP concurred with the Phase 1B archaeological survey report’s recommendation that no further archaeological investigation should be required for this Project (Perazio, 2013c) On September 10, 2013, PAF submitted their Phase 1B historic building survey (PAF, 2013c) to NYSOPRHP, on behalf of the Applicant. The Phase 1B historic building survey identified 403 buildings/structures within the Project viewshed and within 5-miles (8-km) of the Project area (as defined by the locations of the seven proposed turbines). One building was listed on the National Register of Historic Places (NRHP), and 36 others (27 individual buildings and nine buildings comprising the Iradell Historic District) were recommended as eligible for listing on the NRHP. In review correspondence dated October 22, 2013, NYSOPHRP, concurred with PAF’s (2013c) recommendations regarding eligibility determinations for historic buildings/structures (Perazio, 2013c). NYSOPRHP noted that visual impacts to the eligible and listed resources would need to be determined prior to the issuance of an effect determination for the Project (Perazio, 2013c). On July 18, 2014, EDR submitted a visual effects analysis for historic structures (EDR, 2014) to NYSOPRHP, on behalf of the Applicant. The visual effects analysis found that 16 NRHP-eligible Historic Properties had potential views of the Project. However, EDR (2014:18) found that the scale of visual impacts to NRHP-eligible historic structures would be minimal, relative to other wind projects. In review correspondence dated September 18, 2014, NYSOPHRP found the Project would have No Adverse Effect on properties listed in or eligible for listing on the NRHP (Bonafide, 2014). Conclusions and Recommendations To conclude, a Phase 1A Cultural Resources Survey, a Phase 1B Archaeological Survey, a Historic Architectural Resources Survey, and a Visual Effects Analysis were all completed for the Approved Project Layout with a finding of No Effect issued for archaeological resources and a finding of No Adverse Effect issued for historic architectural resources. The Approved Project Layout consisted of seven proposed turbine locations, 2.7 miles of access roads, 4.1 miles of interconnect, two staging areas, and one substation; and the Modified Project Layout consists of a total of 7 proposed turbine locations, no more than 3.2 miles of access roads (depending on which alternate turbines are developed), no more than 4.7 miles of interconnect (depending on which alternate turbines are developed), one meteorological tower, one staging area, and one substation. Additionally, the areas of potential impact for the Modified Project Layout are not significantly different, in terms of archaeological sensitivity, than the Approved Project Layout (both contain areas of moderate and high archaeological sensitivity, per PAF [2013b]). Therefore, it is anticipated that the results of the previous archaeological survey are applicable to the minor Project layout changes proposed in the Modified Project Layout. Thus far, cultural resources studies for the Project have been conducted with adherence to the New York State Historic Preservation Office Guidelines for Wind Farm Development Cultural Resources Survey Work (the SHPO Wind Guidelines; NYSOPRHP, 2006). The SHPO Wind Guidelines are based on the assumption that additional archaeological survey work is not necessary if minor changes to the Project layout occur during the Project development process, as long as the total area of ground disturbance for the Project does not significantly increase. No archaeological resources were identified as a result of the Phase 1B archaeological survey previously conducted for the Project, and the results of a visual effects analysis determined that the Project would not have an adverse impact on historic properties. The minor layout changes proposed in the Modified Project Layout will not change these findings. Black Oak Wind – Cultural Resources Summary January 13, 2016 Page | 4 Therefore, it is the opinion of EDR that the previous cultural resources studies conducted for the Project are sufficient for the purposes of evaluating the Project’s potential effect on archaeological and historic resources. No additional cultural resources studies or analyses are recommended for the Project. Attachments: Figure 1. Black Oak Wind Farm Project Layout Comparison References Cited: Bonafide, John A. 2014. Re: ACOE, DEC: Black Oak Wind Farm/7 Turbines/11.9 MW, Enfield, Tompkins County, 10PR03387. Review Correspondence dated 4/2/2013. New York State Office of Parks, Recreation, and Historic Preservation, Division for Historic Preservation, Waterford, NY. Environmental Design and Research (EDR). 2013. Phase 1A Cultural Resources Survey, Black Oak Wind Farm Town of Enfield, Tompkins County. EDR, Syracuse, NY. EDR. 2014. Historic Resources Visual Effects Analysis, Black Oak Wind Farm. EDR, Syracuse, NY. New York State Office of Parks, Recreation, and Historic Preservation (NYSOPRHP). 2006. New York State Historic Preservation Office Guidelines for Wind Farm Development Cultural Resources Survey Work. New York State Office of Parks, Recreation, and Historic Preservation, Waterford, NY. Perazio, Phillip A. 2013a. Re: CORPS PERMITS, DEC: Black Oak Wind Farm / 20 Units, Town of Enfield, Tompkins County, 10PR03387. Review Correspondence dated 4/2/2013. NYSOPRHP, Division for Historic Preservation, Waterford, NY. Perazio, Phillip A. 2013b. Re: CORPS PERMITS, DEC: Black Oak Wind Farm / 20 Units, Town of Enfield, Tompkins County, 10PR03387. Review Correspondence dated 7/17/2013. NYSOPRHP, Division for Historic Preservation, Waterford, NY. Perazio, Phillip A. 2013c. Re: CORPS PERMITS, DEC: Black Oak Wind Farm / 20 Units, Town of Enfield, Tompkins County, 10PR03387. Review Correspondence dated 10/22/2013. NYSOPRHP, Division for Historic Preservation, Waterford, NY. Public Archaeology Facility (PAF). 2013a. Phase 1B Methodology, Testing Proposal and Structure Visibility Estimate, Black Oak Windfarm Project, Town of Enfield, Tompkins County, New York. PAF, State University of New York, Binghamton. PAF. 2013b. Phase 1B Archaeological Reconnaissance Survey: Black Oak Wind Farm Project. PAF, State University of New York, Binghamton. PAF. 2013c. Phase 1B Historic Building Survey: Black Oak Wind Farm Project. PAF, State University of New York, Binghamton. Copies To: Project File &=! &=! &=! &=! &=! &=! &=! #0 &=! &=! &=! &=! &=! &=! &=! &=! H ar ve y H il l R d Leonard RdR ums e y H i ll R d Robert Treman State ParkTower RdWeat h e r b y R d Gr i ff i n R dBlack Oak RdC ayutaville R d CR 13 6 1 3 4 6 C A B 5 Sources: Esri, HERE, DeLorme, TomTom, Intermap, increment P Corp.,GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL,Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong),swisstopo, MapmyIndia, © OpenStreetMap contributors, and the GISUser Community www.edrdpc.com µ Black Oak Wind FarmTowns of Enfield a nd Newfield, Tompkins CountyFigure 1: Project Layout Comparison Notes: 1. Basemap: Esri ArcGIS Online World Topo Map2. This is a color graphic. Reproduction in grayscale may misrepresent the data. 0 1,000 2,000500Feet January 2016 Current Project Layout Tur bine &=!Modified &=!Approved Access Road Modified Approved Buried Interconnect Modified Approved #0 Meteorological Tower (Modified) Staging Area (Approved) Substation (Modified) Abandoned Portions of Approved Project Layout &=!Turbine Access Road Buried Interco nn ect Staging Area Substation Note: R evised turbine locations A, B, and C are currently being evaluated as alternates and only two out of the three locations (and associa ted Access R oads and Buried Interconne ct) will be developed.