Council For West Virginia Archaeology, Inc.
P. O. Box 1596
Huntington, West Virginia 25716-1596
February 14, 2006


Peter K. Dodgion
Chief, Environmental Analysis Section
U. S. Army Engineer District
502 8th Street
Huntington, West Virginia
25701-2070

Subject: EA and FONSI for PK-8 War School

Dear Mr. Dodgion:

Thank you for your letter of October 28, 2005. We have reviewed your evaluation of the CRAI report and disagree with your findings. While the evaluation points to minor discrepancies in the description of the stratigraphy, by the archeological standards used in the Ohio Valley today, it does not demonstrate that the site lacks integrity. What it demonstrates is that it is a multi-component site with some mixing of the Woodland and Historic Strata. Using your criteria you could determine that all sites in Appalachia with the exception of deeply stratified sites, lack integrity. For example if you had reviewed the Albert Gallatin Jenkins House report as closely, you would have seen the same mixing of Woodland and Historic Strata. Does this mean that the Jenkins House site no longer qualifies for the National Register?

Furthermore, your evaluation was unable to determine that the postmolds were historic rather than prehistoric. If the postmolds do in fact represent a prehistoric structure as Mr. Jackson originally indicated in our meeting, does the site still lack integrity because of some temporal mixing in the strata?

Eligibility and research potential are generally determined by the presence or absence of features. In West Virginia, Woodland settlements are dispersed and generally lack concentrations of features like village sites. If you review the data for Huntington District evaluation and mitigation projects for Gallipolis (RC Byrd) and Winfield you will find that there is an average of approximately one feature for every 100 square meters of excavation. Your report indicates that ten test units were excavated comprising a total of 9.5 square meters of excavation. Given these statistics with the excavation of 9.5 square meters there is a 9.5% chance that Mr. Jackson is correct and the site has no subsurface prehistoric features and lacks integrity. How did the Corps and the West Virginia State Historic Preservation Office determine that 9.5 square meters of excavation was an adequate sample to determine that the site is ineligible?

Would it make more sense and be more responsible to do additional excavations to see if the postmolds are part of a prehistoric structure and to do enough excavation to determine that there are probably no intact prehistoric features. The topsoil will be stripped from the site before construction, why canít this be done under the supervision of professional archeologists and the features mapped and excavated?

In our original letter we asked to be included in the development of an MOA and to be signatories to that MOA. Why wasnít our request granted? There was no consultation as I recall. We were informed by the October 28 letter that the MOA was signed and the EA and FONSI were executed. We are curious how this complies with Section 106 of the National Historic Preservation Act and NEPA. Were our concerns actually addressed in the EA and FONSI?

Please provide us with evidence of consultation with the Shawnee and Cherokee and a final copy of the executed EA and FONSI.

Sincerely,

Dr. Robert F. Maslowski, RPA
President
Council for West Virginia Archaeology, Inc.

cc:

Ms. Susan Pierce, Deputy
State Historic Preservation Officer
Division of Culture and History
Capitol Complex
Charleston, West Virginia 25305

Mr. John M. Fowler, Executive Director
Advisory Council on Historic Preservation
The Old Post Office Building
1100 Pennsylvania Avenue, NW No. 809
Washington, D. C. 20004-2590