NBAF Draft Environmental Impact Statement 3.9 CULTURAL RESOURCES 3.9.1 Methodology The National Historic Preservation Act of 1966 (NHPA) requires federal agencies to record, evaluate, preserve, and plan for management of cultural resources. The NHPA further requires federal agencies to consult with the State Historic Preservation Officer (SHPO) and the Advisory Council on Historic Preservation before modifying, removing, or demolishing any historic structure potentially eligible, eligible, or listed in the National Register of Historic Places (NRHP). The NRHP is the official national list of cultural resources that are deemed worthy of preservation. Properties listed in the NRHP include districts, sites, buildings, structures, and objects that are significant in American history, architecture, archaeology, engineering, and culture. Additional historic preservation laws and executive orders that must be adhered to include the Archeological and Historic Preservation Act of 1974, the Archeological Resources Protection Act of 1979, Native American Graves and Repatriation Act of 1990, American Indian Religious Freedom Act of 1978, Executive Order 13007: Indian Sacred Sites, and Executive Order 11593: Protection and Enhancement of the Cultural Environment. Database searches were conducted for known archaeological and historically significant resources at each of the proposed NBAF sites. Archaeological and historical sites were identified and the footprint for the conceptual design was overlaid on the site boundaries to assist in determining the potential for adverse effects from the proposed construction and operation of the proposed NBAF. Intensive archaeological surveys were performed for sites with significant potential for archaeological resources. Once compiled for each of the sites, in compliance with Section 106 consultation requirements under NHPA, the resulting information pertaining to archaeological and historical resources and potential effects from proposed construction was submitted to the appropriate SHPO for review and concurrence with the findings. In the event it is determined historic or archaeological resources that are listed or eligible for listing in the NRHP would be harmed, either a legally binding agreement would be developed to establish how DHS would address the adverse effects or the ACHP would issue advisory comments that the head of DHS must consider in making a final decision (ACHP 2002). A list of contacts was generated for each site by the respective SHPO, identifying Native American Indian tribes whose ancestral lands could be affected by the proposed NBAF. In some instances, the contacts included state-recognized tribes. An information package was sent to each of the contacts, describing the proposed project and its anticipated effects. One response has been received to date. Copies of the letters and additional responses received will be provided in the Fnal EIS. 3.9.2 No Action Alternative 3.9.2.1 Affected Environment PIADC’s continued operation constitutes the No Action Alternative. DHS indicated in their April 7, 2007 letter to the New York State Office of Parks, Recreation, and Historic Preservation (NYPR&HP) that an extensive survey of all buildings, structures, and related appurtenances on the island was undertaken by a historic preservation consultant in 1998. In 2003, a historic preservation plan was prepared for the historical features documented in the 1998 survey. The preservation plan serves to satisfy the requirements of Section 106 of the NHPA, and provides specific preservation actions for historically significant buildings and structures on the island. The plans were developed to accommodate potential future construction/expansion of PIADC. No known archaeological studies have been conducted at PIADC to date, and it is currently unknown if any prehistoric archaeological resources eligible for listing in the NRHP or NYPR&HP are present. 3.9.2.2 Construction Consequences No construction would occur under the No Action Alternative, although the infrastructure improvements previously authorized would proceed. A Categorical Exclusion determined that the improvements would not June 2008 3-221 NBAF Draft Environmental Impact Statement affect any listed or eligible for listing archaeological or cultural resources (DHS 2007). The historic preservation plan developed in 2003 provides specific preservation actions for historic buildings and structures on Plum Island. Adherence to the preservation plan will preclude adverse consequences to historically significant features from any potential future construction activities. 3.9.2.3 Operation Consequences Continued operation of PIADC is not likely to result in adverse effects to historically significant features. 3.9.3 South Milledge Avenue Site 3.9.3.1 Affected Environment The 67-acre site consists primarily of pastureland, but the northwestern and southwestern portions contain mature hardwood forest. The site has been undeveloped since at least 1936, and all lands adjacent to the site currently exist as undeveloped open lands or woodlands (Terracon 2007f). An intensive archaeological survey of the site was conducted in December 2007 (SAS 2007). The survey also included 26 acres southwest of the site and adjacent to the Middle Oconee River. No historical resources that are listed or eligible for listing with the NRHP or the Historic Preservation Division (HPD) of GONR were found on or adjacent to the site. However, the field survey identified 11 archaeological sites within the project area. None are listed or would be considered eligible for listing in the NRHP or HPD (Personal communication, Chad Braley, Southeastern Archaeological Services, Inc., January 11, 2008). A formal Section 106 review of the site was requested in April 2008. No response has been received from HPD as of yet. The list of contacts generated for Native American Indian tribes whose ancestral lands could be affected by the proposed NBAF at the South Milledge Avenue Site is included in Table 3.9.3.1-1. Table 3.9.3.1-1 — Native American Contacts Consulted, South Milledge Avenue Site The Cherokee of Georgia Tribal Council The Georgia Tribe of Eastern Cherokee Mr. Ralph Crews Mr. Walker Dan Davis Blackshear, Georgia Dahlonega, Georgia Georgia Council on American Indian Concerns The Lower Muskogee Creek Tribe Ms. Nealie McCormick, Chairman Ms. Marian S. McConnick Palham, Georgia Whigham, Georgia 3.9.3.2 Construction Consequences No adverse effects would likely occur to historical sites from the construction of the proposed NBAF because none are located on the South Milledge Avenue Site. Adverse effects to the 11 known archaeological sites adjacent to the proposed project area are not likely to occur from construction associated with the proposed project. Ten of the 11 archaeological sites identified within the 92-acre survey area are either highly disturbed or have low research potential and, therefore, would have little significance. These 10 sites have been recommended as ineligible for listing in the NRHP. If the review agencies concur the sites are ineligible, then no additional archaeological work would be necessary in these areas. The eleventh site is a small prehistoric site that would have research potential, and although the site would be eligible for listing, it is located well outside the 67-acre construction zone and would not likely be affected by the proposed development (SAS 2007). June 2008 3-222 NBAF Draft Environmental Impact Statement 3.9.3.3 Operation Consequences Adverse effects to cultural resources would not likely occur as a result of operation of the proposed NBAF on the South Milledge Avenue Site. 3.9.4 Manhattan Campus Site 3.9.4.1 Affected Environment The approximately 48.4-acre site proposed for development near Manhattan, Kansas is part of a land grant dating back to the mid-1800s. The property is open, agricultural land that has been used for agricultural purposes, primarily animal husbandry, research, and education (AEC 2007). A review of Kansas State Historical Society (KSHS) records indicated no cultural resources are listed on or in the vicinity of the site proposed for development. The nearest listed historical site is the Washington and Julia Marlatt Homestead, which is located approximately 0.6 miles west of the proposed NBAF site. KSHS concluded in their December 7, 2007 letter that they have no objections to the project and asserted the site has low archaeological potential. They furthered that the proposed project would have no effect on archaeological sites. The list of contacts generated for Native American Indian tribes whose ancestral lands could be affected by the proposed NBAF at the Manhattan Campus Site is included in Table 3.9.4.1-1. Table 3.9.4.1-1 — Native American Contacts Consulted, Manhattan Campus Site Delaware Tribe of Indians Kaw Nation Dr. Brice Obermeyer Kaw City, Oklahoma Emporia Kansas 3.9.4.2 Construction Consequences Because no archaeological resources are known to exist on or in the immediate vicinity of the site, no adverse impacts are likely to result from the construction of the proposed NBAF at the Manhattan Campus Site. KSHS records indicate that no historical sites are in the project area. Although KSHS has requested review of final construction plans for reassurance that sites listed or eligible for listing in the NRHP or KSHS would remain unaffected, it is unlikely that any adverse impacts would occur as a result of the proposed NBAF, given the distance between the nearest historical site and the