State says study inadequate

MONTEREY — Apparently walking around and digging the ground four times with a shovel is not enough for an archaeological study.

For more than two years, the state Department of Historical Resources has asked the company planning an industrial wind utility here to provide evidence of how 400-foot towers and heavy construction might affect historic views, landmarks, and special archaeological features on and around Allegheny Mountain.

So far, Highland New Wind Development LLC has failed to satisfy the agency's requests, and DHR again rejected one of HNWD's studies last week.

After a site visit a couple of years ago, DHR officials determined there was more to potential effects from the project than HNWD had indicated. The agency solicited comments and information from several sources, including groups involved in Civil War history preservation.

DHR insisted again that HNWD provide an archaeological survey of the project site, and the company hired Dr. Linda Perry to conduct one. Perry provided a one-page conclusion after walking the site and examining four shovelfuls of earth. Perry concluded the project would have no significant impact on archaeological resources.

Last Thursday, July 9, DHR sent a letter to HNWD attorney John Flora, saying Perry's study did not meet the agency's minimum standards for phase I archaeological survey.

DHR had specific concerns it asked the developer to address, including providing a detailed site plan, something DHR had not received.

"Any archaeological study must consider all aspects of the project, and this has not been demonstrated," wrote Roger Kirchen, archaeologist with DHR's office of review and compliance. "We do understand that much of the project area contains depleted soils or is severely sloped with little potential to contain intact archaeological sites; however, standard reporting should discuss specific areas with justifications as to why they were not subjected to subsurface testing and depict these areas on project maps."

Kirchen told HNWD that while DHR guidelines encourage "predictive modeling" to guide field studies, "all models must employ some level of subsurface investigation in all areas to demonstrate the validity of the model."

Further, he said, maps showing the location of all test pits and detailed soil profiles with full soil descriptions "will help us understand the physical context of this study."

He also asked for a detailed curriculum vitae of Perry, since DHR was unfamiliar with her qualifications under its standards.

"At your earliest convenience, please revise this study to comply with our (guidelines) and to address the specific comments … and submit to DHR two bound copies for review," Kirchen wrote.

DHR said it would also like to see the computer simulations HNWD has prepared.

Tuesday, Flora told Highland's Technical Review Committee he intends to reply to Kirchen about the survey.