SECTION 106 FINDINGS CITY OF AFTON OLD VILLAGE IMPROVEMENTS PROJECT

SECTION 106 FINDINGS CITY OF AFTON OLD VILLAGE IMPROVEMENTS PROJECT August 2, 2016

ABSTRACT The City of Afton proposes to construct improvements to the Old Village area of Afton by installation of a new wastewater collection and treatment facility, road improvements, stormwater improvements, and levee improvements. The project must complete a Section 106 review according to the National Historic Preservation Act of 1966 (as amended). The Section 106 review requires an assessment of the project on historic properties. Section 106 review requires identification of historic properties listed in or eligible for listing in the National Register of Historic Places (NRHP) located within the Area of Potential Effects (APE). The project s potential effects to these properties must be assessed and actions taken to avoid, minimize and/or mitigate adverse effects, if any such effects are found to exist. The Minnesota Pollution Control Agency (MPCA) was the Lead Federal agency for completion of this Section 106 review, through a programmatic agreement with the United States Environmental Protection Agency (EPA). The U.S. Army Corps of Engineers (USACE) was also a Federal agency with Section 106 responsibilities for the project because it will be issuing a permit in connection with the levee improvements and has granted Lead Federal agency responsibilities to the MPCA. The review process included documenting and evaluating impacts to historic properties in the APE through public participation and input from consulting parties. During this Section 106 review, 11 properties within the APE were found to be listed in or eligible for listing in the NRHP. Numerous studies were completed during the identification and assessment processes. Two tribal consultation meetings were held to discuss the Rattlesnake Mound, an archaeological site located within the APE. Based on the Section 106 review process, the MPCA, as the Lead Federal agency, determined that the proposed project will result in No Adverse Effects to historic properties.

LIST OF ATTACHMENTS ATTACHMENT DOCUMENT NUMBER Attachment 1 Letter from U.S. Army Corps of Engineers-dated December 11, 2015 Attachment 2 Cultural Resource Assessment for City of Afton Flood Protection and Sanitary Sewer Improvements-dated November 11, 2015 Attachment 3 Copies of all comments received during December 2015 public comment period Attachment 4 MPCA response to comments document Attachment 5 Supplemental Report-dated March 14, 2016 Attachment 6 Phase II Archaeological Assessment and Evaluation of 21WA10-dated May 6, 2016 Attachment 7 Supplemental Report-dated May 16, 2016 Attachment 8 Update on the Archaeological Assessment-dated June 27, 2016 Attachment 9 Update on the Architectural Assessment-dated July 2, 2016 Attachment 10 Participants for February 19, 2016, consultation meeting Attachment 11 Participants for May 20, 2016, consultation meeting Attachment 12 Memo from WSB & Associates-dated July 25, 2016 Attachment 13 Area of Potential Direct Effects Map Attachment 14 Area of Potential Indirect Effects Map Attachment 15 Minnesota Archaeological Site Form-21WA10 Attachment 16 Minnesota Archaeological Site Form-21WA116 Attachment 17 Brick Schoolhouse (WA-AFC-011) Information Attachment 18 Afton Historical Museum (WA-AFC-012) Information Attachment 19 L.A. Bluff Bank Building (WA-AFC-067) Information Attachment 20 Charles and Electa Getchell House (WA-AFC-087) Information Attachment 21 Congregational Church Parsonage (WA-AFC-065) Information Attachment 22 Ferdinand Richert House (WA-AFC-069) Information Attachment 23 Selma s Ice Cream Parlor (WA-AFC-071) Information Attachment 24 Squire s House (WA-AFC-010) Information Attachment 25 Archaeological Monitoring Plan for Site 21WA10 and Unanticipated Discovery Plan

SECTION 106 REVIEW PROCESS The project design and historical/archaeological reports were completed by the City of Afton and its contractors in accordance with 36 CFR 800.2(a)(3). The MPCA is acting as the Lead Federal agency according to 36 CFR 800.2(a)(2). The MPCA received a letter dated December 11, 2015, from the U.S. Army Corps of Engineers regarding the Section 106 review for this project. This letter delegated the Lead Agency authority to the MPCA for this entire project. The MPCA s Section 106 review also satisfies the U.S. Army Corps of Engineers requirement to complete a Section 106 review. A copy of this letter can be found as Attachment 1. General Section 106 Review Timeline The MPCA published a public notice on December 1, 2015, to initiate the Section 106 review for this project. A notice letter was sent to interested parties and published on the MPCA website. The report titled A Cultural Resource Assessment for City of Afton Flood Protection and Sanitary Sewer Improvements dated November 11, 2015, by Blondo Consulting, LLC (Attachment 2), was included with the public notice document. During the 30-day public comment period (December 1-December 31, 2015) the MPCA received 55 comment letters. Copies of these comments can be found as Attachment 3. Written responses to these comments can be found as Attachment 4. The Minnesota Historic Preservation Office (MnHPO) provided comments to the MPCA in a comment letter dated December 22, 2015. As part of the continued consultation regarding historic properties, Blondo Consulting, LLC, submitted updated inventory forms, photos, and maps of the project area to MnHPO on March 4, 2016. The MPCA provided a Supplemental Report by Blondo Consulting, LLC, (Attachment 5) to MnHPO on March 15, 2016. MnHPO provided additional comments on recent submittals in a comment letter dated April 8, 2016. On May 6, 2016, the MPCA provided the Phase II Investigation by Blondo Consulting, LLC (Attachment 6) to MnHPO. On May 20, 2016, the MPCA provided a Memorandum from Blondo Consulting, LLC dated May 16, 2016, (Attachment 7) to MnHPO. On June 6, 2016, the MPCA provided the complete set of engineering plans from WSB & Associates, Inc. to MnHPO. MnHPO provided additional comments on recent submittals in a comment letter dated June 6, 2016. On June 15, 2016, the MPCA provided updated plans, information and a draft Unanticipated Discovery Plan to MnHPO.

MnHPO provided additional comments on recent submittals in a comment letter dated June 22, 2016. On July 7, 2016, the MPCA provided the June 27, 2016, memo (Attachment 8) and the July 2, 2016, memo (Attachment 9) to MnHPO. These memos were completed by Blondo Consulting, LLC. MnHPO provided additional comments on recent submittals in a comment letter dated July 22, 2016. Tribal Consultation The MPCA received comments requesting that tribal entities be consulted regarding the Rattlesnake Mound. The MPCA provided public notice to all federally recognized tribes in Minnesota during the public notice period. The MPCA hosted two consultation meetings regarding this project and its potential impacts to the Rattlesnake Mound. The first consultation meeting occurred on February 19, 2016. This meeting consisted of a site visit to the project location in Afton and a follow up discussion at the MPCA St. Paul office. A conference call number was provided for those who were unable to participate in the discussion in person. A detailed list of the participants in this meeting can be found in Attachment 10. The participants agreed that additional studies of the Rattlesnake Mound were needed and that a Phase II investigation would be completed including LiDAR, ground penetrating radar, and additional subsurface investigation. After completion of the Phase II investigation, the MPCA hosted another tribal consultation meeting on May 20, 2016, at its St. Paul office. A conference call number was again provided for those who were unable to participate in the discussion in person. A detailed list of the participants in this meeting can be found in Attachment 11. The participants reviewed the Phase II investigation report and discussed its recommendations. In general, the participants agreed that the Rattlesnake Mound is eligible for listing in the NRHP. The participants also discussed the project s potential effects on the Rattlesnake Mound, including those that would improve or protect the Mound s future integrity. Findings 1. This document provides documentation supporting the MPCA s finding of no adverse effects in accordance with 36 CFR 800.11(e). 2. In accordance with 36 CFR 800.5(c), this document has been provided on August 2, 2016, to all consulting parties for their review. 3. These findings will become final according to 36 CFR 800.5(c)(1) unless written documentation is provided by a consulting party that meets the requirements of 36 CFR 800.5(c)(2).

UNDERTAKING An undertaking is defined under 36 CFR 800.16(y) as a project, activity, or program funded in whole or in part under the direct or indirect jurisdiction of a Federal agency, including those carried out by or on behalf of a Federal agency; those carried out with Federal financial assistance; and those requiring a Federal permit, license or approval. A Section 106 review is required for this undertaking because the project is partially funded with federal financial assistance, provided by the EPA. The project is seeking financial assistance through the Clean Water State Revolving Fund. Levee reconstruction is being completed to meet USACE and Federal Emergency Management Agency (FEMA) design criteria and will be done pursuant to a permit issued by USACE. The levee reconstruction will result in approximately 0.47 acres of permanent wetland impact and 0.06 acres of temporary wetland impact to wetlands on the east and west side of the levee. The construction of a stormwater pond and lift station will result in approximately 0.05 acres of impact to wetlands on the west side of the levee. The reconstruction of the parking lot adjacent to Steamboat Park will result in approximately 0.01 acres of impact to wetlands on the west side of the levee. Culvert replacement within Kelle s Creek will affect approximately 65 linear feet of Kelle s Creek. The City of Afton proposes to complete a downtown improvements project which will consist of a new wastewater collection and treatment facility, road improvements, stormwater improvements, and levee improvements in the Old Village area of Afton. The project will involve various at-grade or underground construction activities. Construction methods such as horizontal directional drilling and open cut installation methods can create certain conditions including, but not limited to, vibration, noise, dust, and visual intrusion from construction activities. These conditions are expected to be temporary during construction and standard construction practices will be followed to minimize these conditions. Wastewater Treatment Facility The City of Afton proposes to construct a new community wastewater treatment facility on the property located at 2318 St. Croix Trail South in Afton. The facility will be designed to treat 50,550 gallons per day. The facility will include a recirculating gravel filter, underground tanks, subsurface soil absorption beds, a small control building, a gravel access drive, fencing, and other appurtenances. Collection System The project will construct approximately 1.8 miles of new sanitary sewer collection system. This new collection system will collect sewage from residential and commercial establishments before being treated at the proposed wastewater treatment facility. The collection system will consist of standard gravity collection, two lift stations, and forcemain. Some areas of the collection system will utilize horizontal directional drilling to minimize potential impacts to the environment or historic properties. Road Improvements In general, the roads affected by installation of the collection system are being replaced in-kind. Local roadways vary in width from 15-20 feet wide and will be reconstructed at a consistent 20-foot width. The width of County Road 21 is being reduced. CR 21 and local roadways that were bituminous but have deteriorated will be returned to a bituminous surface. Curbing along CR 21 is intermittent and what is present is deteriorated. Concrete curbing will be placed along CR 21 for the length of the project. Sidewalk improvements are also proposed and include replacing the sidewalks along CR 21 with new concrete sidewalk.

Stormwater Improvements Afton s downtown area currently has very minimal stormwater facilities. Stormwater flows un-managed and untreated to the St. Croix River, causing flooding on its way to the river and water quality problems once it reaches the river. The project includes the construction of an underground storm sewer system to capture and transport stormwater to two new stormwater ponds to treat the water before it flows into the St. Croix River. In addition to the new stormwater ponds, the project also includes a linear rain garden at the foot of the river bluff on the west side of Town Square Park to capture and treat stormwater drainage from the bluff, and two bio-infiltration basins in the park area on the east side of St. Croix Trail and south of 36 th Street to capture and infiltrate stormwater before it reaches the St. Croix River. All of the stormwater facilities listed above and detailed below are designed to provide a natural character and appearance. Particularly, the pond located along a portion of the Rattlesnake Mound will be designed with native plantings to provide a natural character and setting for the Mound. The project also includes a stormwater lift station, for use during flood events, to be built into the levee at Upper 34 th Street. Levee Improvements The project will include improvements to 2,200 linear feet of levee. The levee will be reconstructed and raised approximately one (1) to two (2) feet to meet accreditation requirements outlined by the USACE and FEMA. A portion of the levee located south of the stormwater pond will be relocated approximately 40 feet east to provide space for the trail on the west side of the levee to the parking lot at Steamboat Park to meet Americans with Disabilities Act (ADA) slope requirements and setback requirements. For the levee trail, excavation will occur to a maximum depth of 0.5 feet. This excavation will occur on top of the levee and will not involve excavation into native soils. The levee improvements will include a toe drain, installed at a depth of six (6) feet, along the western toe of the levee.

FINDINGS ON THE AREA OF POTENTIAL EFFECTS 36 CFR 800.16(d) identifies the Area of Potential Effects (APE) as the geographic area or areas within which an undertaking may directly or indirectly cause alterations in the character or use of historic properties, if any such properties exist. The area of potential effects is influenced by the scale and nature of an undertaking and may be different for different kinds of effects caused by the undertaking. The project identified separate Areas for Potential Direct Effects and Potential Indirect Effects. The Area of Potential Direct Effects includes the construction limits of the proposed undertaking. This area includes the Old Village area of Afton where street, sanitary sewer, stormwater, and levee improvements are proposed. This area is generally bounded by the intersection of St. Croix Trail and Stagecoach Trail to the north, the intersection of St. Croix Trail and River Road to the south, Perrot Avenue to the west, St. Croix Trail to the northeast and the St. Croix River to the southeast. It also includes the area where the sanitary sewer forcemain will be directionally drilled along St. Croix Trail from the Old Village area to the wastewater treatment facility site north of the Old Village area, as well as the wastewater treatment facility site itself, located at 2318 St. Croix Trail. The extent of these potential direct effects is described in detail in Attachment 12. The Area of Potential Direct Effects is also shown on the map in Attachment 13. Defining Potential Indirect Effects that the project may have on the character or use of historic properties is more difficult than defining Potential Direct Effects. Most of the project work will involve installation of below-ground sanitary sewer collection and treatment systems that will not be visible upon completion of the project. Furthermore, most of the work that will be visible aboveground upon completion of the Project; new curb and gutter, alterations to the existing levee, will replace existing above-ground features. Nevertheless, attached as Attachment 14, is a map showing the Area of Potential Indirect Effects in which the proposed undertaking could potentially have indirect effects on historic properties, such as effects on the properties setting, feeling, and association with surrounding landscaping. The Area of Potential Indirect Effects includes the Old Village area of Afton where street, sanitary sewer, stormwater and levee improvements are proposed, which is generally bounded by the intersection of St. Croix Trail and Stagecoach Trail to the north, the intersection of St. Croix Trail and River Road to the south, Perrot Avenue to the west, St. Croix Trail on the northeast and the St. Croix River to the southeast. It also includes the area where the sanitary sewer forcemain will be directionally drilled along St. Croix Trail from the Old Village area to the wastewater treatment facility site north of the Old Village area, as well as the wastewater treatment facility site itself, located at 2318 St. Croix Trail.

FINDINGS ON THE IDENTIFICATION OF HISTORIC PROPERTIES Background research was completed online, at the Minnesota State Historic Preservation Office (MnHPO), and at the Afton Historical Museum. Historic plat maps and current aerial photographs were also examined. Historic age resources were identified through the Washington County Recorder s Office records and on current aerial photographs. These resources were also verified with the Afton Historical Museum. Fieldwork included a pedestrian survey. Each resource was photographed and notes were made regarding historic potential. The integrity of each resource was also assessed. Minnesota Architecture-History Inventory Forms were completed for each of the inventoried properties. Two previously identified archaeological sites are recorded within the project APE. These sites are 21WA10 and 21WA106. 21WA10 is known as the Rattlesnake Mound Group and 21WA106 is known as the Valley Branch Creek Site. During project planning, a third archaeological site was found. This site is identified as Site 21WA116. A total of fifty eight (58) inventoried properties were identified within the project APE. These 58 properties are summarized in Table 1 below. Table 1: Inventoried sites within APE. Inventory Number Site Name Address WA-AFC-062 St. Paulus German Lutheran Church Parsonage 3032 St. Croix Trail S WA-AFC-084 James Johnson House 15890 31st St. S WA-AFC-063 Martin Lind House 3085 St. Croix Trail S WA-AFC-064 Inter-State Lumber Company 3121 St. Croix Trail S WA-AFC-085 St. Croix Valley Academy 15895 31st St. S WA-AFC-012 Afton Historical Museum 3165 St. Croix Trail S WA-AFC-065 Congregational Church Parsonage 3192 St. Croix Trail S WA-AFC-086 Buswell House 15872 32nd St. S WA-AFC-016 Thomas House 3222 St. Croix Trail S WA-AFC-006 Andrew Mackey House 3290 St. Croix Trail S WA-AFC-066 Lerk's Bar and Grill 3321 St. Croix Trail S WA-AFC-067 L.A. Bluff Bank Building 3329 St. Croix Trail S WA-AFC-068 Barber Shop 3335 St. Croix Trail S WA-AFC-069 Ferdinand Richert House 3326 St. Croix Trail S WA-AFC-070 Garage Building 3343 St. Croix Trail S WA-AFC-010 Squire's House 3390 St. Croix Trail S WA-AFC-011 Brick Schoolhouse 15888 34th St. S WA-AFC-088 Afton Village Park St. Croix Trail S & Upper 34th Street S WA-AFC-071 Selma's Ice Cream Parlor 3419 St. Croix Trail S WA-AFC-089 Professor Ahl House 15904 Afton Blvd S WA-AFC-015 The Slater Store 3466 St. Croix Trail S WA-AFC-072 Joseph Dernley House 3494 St. Croix Trail S WA-AFC-090 Afton Methodist Church Parsonage 15945 35th St. S WA-AFC-073 Asa Tracy House 3632 St. Croix Trail S

WA-AFC-074 Emil Asp Blacksmith Shop 3xxx St. Croix Trail S WA-AFC-075 House 3060 St. Croix Trail S WA-AFC-076 House 3055 St. Croix Trail S WA-AFC-109 House 15953 31st St. S WA-AFC-091 House 15954 Afton Blvd S WA-AFC-077 House 3185 St. Croix Trail S WA-AFC-087 Charles and Electa Getchell House 15990 32nd St. S WA-AFC-078 House 15871 St. Croix Trail S WA-AFC-092 House 15892 33rd St. S WA-AFC-108 House 3xxx St. Croix Trail S WA-AFC-093 House 15858 34th St. S WA-AFC-079 House 3395 St. Croix Trail S WA-AFC-094 House 15885 Upper 34th St. S WA-AFC-095 House 15859 Upper 34th St. S WA-AFC-080 House 3491 St. Croix Trail S WA-AFC-096 House 15960 35th St. S WA-AFC-097 Frank Spreeman House 15895 35th St. S WA-AFC-098 House 15887 35th St. S WA-AFC-099 House 15880 36th St. S WA-AFC-081 House 3602 St. Croix Trail S WA-AFC-100 House 15847 36th St. S WA-AFC-082 Spruce Hill House 3710 St. Croix Trail S WA-AFC-101 House 3752 River Road S WA-AFC-102 House 3786 River Road S WA-AFC-103 House 3904 River Road S WA-AFC-104 House 3968 River Road S WA-AFC-105 House 15909 Afton Blvd S WA-AFC-106 House 3936 River Road S WA-AFC-107 House 1595 35th St. S WA-AFC-083 Ole Theuson House 3xxx St. Croix Trail S WA-AFC-005 Cushing Hotel 3291 St. Croix Trail S 21WA10 Rattlesnake Mound Group Archaeological Site 21WA106 Valley Branch Creek Site Archaeological Site 21WA116 Site 21WA116 Archaeological Site For an inventoried property to be considered eligible for listing in the National Register of Historic Places (NRHP) the site must be at least 50 years old and the following conditions must be met. The quality of significance in American history, architecture, archeology, engineering, and culture is present in districts, sites, buildings, structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling, and association and meet at least one of the following criteria:

Criterion A: Sites that are associated with events that have made a significant contribution to the broad patterns of our history. Criterion B: Sites that are associated with the lives of persons significant in our past. Criterion C: Sites that embody the distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or Criterion D: Sites that have yielded, or may be likely to yield, information important in prehistory or history. Of the 58 sites, 47 sites were determined to be not eligible for listing in the NRHP. The remaining 11 sites were determined to be eligible for listing in the NRHP. These 11 sites are summarized in Table 2 below. Table 2: Sites determined to be listed or eligible for listing in the NRHP. Inventory Number Property Name Eligibility Criteria WA-AFC-011 Brick Schoolhouse A WA-AFC-012 Afton Historical Museum A WA-AFC-067 L.A. Bluff Bank Building C WA-AFC-087 Charles and Electa Getchell House B WA-AFC-065 Congregational Church Parsonage A, B WA-AFC-069 Ferdinand Richert House A, B WA-AFC-071 Selma s Ice Cream Parlor B WA-AFC-010 Squire s House A WA-AFC-005 Cushing Hotel Listed in NRHP 21WA10 The Rattlesnake Mound within 21WA10 A, C, D 21WA116 Site 21WA116 D The Brick Schoolhouse (WA-AFC-011) is located at 15888 34 th St. S. This site has been determined to be eligible for listing in the NRHP under Criterion A for its significant role in the early development of the school system in the City of Afton. MnHPO agreed with this recommendation in a comment letter dated April 8, 2016. The Afton Historical Museum (WA-AFC-012) is located at 3165 St. Croix Trail S. This site has been determined to be eligible for listing in the NRHP under Criterion A for its association with the early development of the City of Afton, demonstrated through the Early Agriculture and River Settlement statewide historic context. MnHPO agreed with this recommendation in a comment letter dated April 8, 2016. The L.A. Bluff Bank Building (WA-AFC-067) is located at 3329 St. Croix Trail S. This site has been determined to be eligible for listing in the NRHP under Criterion C for being the only standing work of distinctive Romanesque Revival architecture within Afton s Historic Village. MnHPO agreed with this recommendation in a comment letter dated April 8, 2016.

The Charles and Electa Getchell House (WA-AFC-087) is located at 15990 32 nd Street S. This site has been determined to be eligible for listing in the NRHP under Criterion B for its association with Charles Getchell, a locally prominent person in Afton s history. MnHPO agreed with this recommendation in a comment letter dated April 8, 2016. The Congregational Church Parsonage (WA-AFC-065) is located at 3192 St. Croix Trail S. This site has been determined to be eligible for listing in the NRHP under Criterion A for its association with the early development of the City of Afton, demonstrated through the Early Agriculture and River Settlement statewide historic context. This site has also been determined to be eligible for listing in the NRHP under Criterion B for its association with Reverend Putnam, a notable figure in the history of the City of Afton. MnHPO agreed with this recommendation in a comment letter dated April 8, 2016. The Ferdinand Richert House (WA-AFC-069) is located at 3326 St. Croix Trail S. This site has been determined to be eligible for listing in the NRHP under Criterion A for its association with the early development of the City of Afton, demonstrated through the Early Agriculture and River Settlement statewide historic context. This site has also been determined to be eligible for listing in the NRHP under Criterion B for its association with Ferdinand Richert, a prominent person in the development of the village of Afton. MnHPO agreed with this recommendation in a comment letter dated April 8, 2016. Selma s Ice Cream Parlor (WA-AFC-071) is located at 3419 St. Croix Trail S. This site has been determined to be eligible for listing in the NRHP under Criterion B for its association with Ed and Selma Holberg, prominent persons within the City of Afton. MnHPO agreed with this recommendation in a comment letter dated April 8, 2016. Squire s House (WA-AFC-010) is located at 3390 St. Croix Trail S. This site has been determined to be eligible for listing in the NRHP under Criterion A for its association with the early development of the City of Afton, demonstrated through the Early Agriculture and River Settlement statewide historic context. MnHPO agreed with this recommendation in a comment letter dated April 8, 2016. The Cushing Hotel (WA-AFC-005) was previously inventoried and is listed in the NRHP as of January 17, 1985. A Phase II evaluation was completed for the 21WA10 site and is included as Attachment 6. The Rattlesnake Mound within 21WA10 has been determined to be eligible for listing in the NRHP under Criterion A for its association with the Effigy Mound Culture. The Mound has also been determined to be eligible for listing in the NRHP under Criterion C as a site that embodies the distinctive characteristics of a type, period, or method of construction or that represent the work of a master, or that possess high artistic values. The Mound has also been determined to be eligible for listing in the NRHP under Criterion D for the potential to yield information important in prehistory or history. MnHPO agreed with this recommendation in a comment letter dated June 6, 2016. The updated Minnesota Archaeological Site Form for this site can be found as Attachment 15. During project planning, the 21WA116 site was found to be located in the APE. This site was found to contain post contact 19 th century artifacts which may be associated with early Afton history. Artifacts were found including: concrete, Styrofoam, plastic, glass, ceramic, and metal. This site has been determined to be eligible for listing on the NRHP under Criterion D for the potential to yield further information about early Afton and early Minnesota history. MnHPO agreed with this recommendation

in a comment letter dated July 22, 2016. The new Minnesota Archaeological Site Form for this site can be found as Attachment 16. The City of Afton will be relocating the levee to the east of its current location, in the area near Steamboat Park. Archaeological reconnaissance surveying of the area was completed to explore observed mound-like landscape features. The results of this testing can be found in Attachment 8 and concluded the features were a combination of natural deposits and disturbed remnants of historic railroad construction, use, and abandonment. The surveying identified no prehistoric cultural materials but did identify historic and modern debris in a disturbed context. No historic properties were identified in this area.

FINDINGS ON THE ASSESSMENT OF ADVERSE EFFECTS The criteria of adverse effect (36 CFR 800.5(a)) were applied to the historic properties in the APE which were determined to be eligible for or listed in the NRHP. For a Section 106 review, an effect is defined in 36 CFR 800.16(i) as alteration to the characteristics of a historic property qualifying it for inclusion in or eligibility for the National Register. An adverse effect under 36 CFR 800.5(a)(i) is found when an undertaking may alter, directly or indirectly, any of the characteristics of a historic property that qualify the property for inclusion in the National Register in a manner that would diminish the integrity of the property s location, design, setting, materials, workmanship, feeling, or association. It should be noted that the physical structure of the historic buildings identified below will not be impacted during construction of this project. Brick Schoolhouse (WA-AFC-011) The Brick Schoolhouse (WA-AFC-011) is located at 15888 34 th Street South. 34 th Street is a road consisting of deteriorated bituminous pavement filled in with gravel, with no curb or drainage system. The road is functional, but is visibly worn with numerous cracks and potholes, and requiring maintenance. Parking is already available for the park along the southern edge of 34 th Street, though parking is not specifically designated. There is also an existing concrete driveway that leads north from 34 th Street to the site and its associated garage. Proposed improvements in this area include sanitary sewer installations (of which the property owners will be individually responsible for connecting) and replacement of bituminous pavement along 34 th Street. The southern half of the existing driveway will also be repaved in concrete, and storm sewer catch basins will be installed adjacent to the driveway and across the street and will be connected to storm sewer lines on the north and south sides of 34 th Street. The existing parking spaces for the neighboring park across the road from the site along the southern edge of 34 th Street will be reconstructed with pervious pavers. The completed Minnesota Architecture- History Inventory Form and maps showing the existing site conditions and proposed side conditions can be found in Attachment 17. The proposed improvements may affect the current setting of the property by repairing existing deteriorated infrastructure. These effects will not adversely alter the characteristics that make the site eligible for inclusion in the NRHP. The undertaking will result in no adverse effects to this historic property. MnHPO agreed with this recommendation in a comment letter dated July 22, 2016. Afton Historical Museum (WA-AFC-012) The Afton Historical Museum (WA-AFC-012) is located at 3165 St. Croix Trail S. The existing road north of the property (Afton Boulevard) is a road consisting of deteriorated bituminous pavement filled in with gravel, with no curb or drainage system. The road is functional, but is visibly worn with numerous cracks and potholes, and requiring maintenance. St. Croix Trail S is an asphalt paved road with a curb existing in only a few areas, minimal drainage, no designated turn lanes, and minimal pedestrian crossing points. This road is functional, and in fair condition, but requires maintenance for its numerous cracks, potholes, and eroding roadsides. There is currently a concrete sidewalk running north-south in front (west) of the site, though it also suffers from cracks, holes, and uneven pave blocks. Proposed improvements in this area include sanitary sewer installations (of which the property owners will be individually responsible for connecting) and replacement of bituminous pavement and concrete sidewalks along St. Croix Trail S. Bituminous pavement will also be replaced on Afton Boulevard, north of the site, and a catch basin constructed north of the property on St. Croix Trail S. Bump-outs, turn lanes, crosswalks, and curb and gutter are also planned along St. Croix Trail S. The repaved sidewalk would be the only portion of the proposed improvements that sits on the property line for the site. The completed Minnesota

Architecture-History Inventory Form and maps showing the existing site conditions and proposed side conditions can be found in Attachment 18. The proposed improvements may affect the current setting of the property by repairing existing deteriorated infrastructure. These effects will not adversely alter the characteristics that make the site eligible for inclusion in the NRHP. The undertaking will result in no adverse effects to this historic property. MnHPO agreed with this recommendation in a comment letter dated July 22, 2016. L.A. Bluff Bank Building (WA-AFC-067) The L.A. Bluff Bank Building (WA-AFC-067) is located at 3329 St. Croix Trail S. The proposed improvements in this area include sanitary sewer installations (of which the property owners will be individually responsible for connecting) and replacement of bituminous pavement and concrete sidewalks along St. Croix Trail S and 33 rd St. The completed Minnesota Architecture-History Inventory Form and maps showing the existing site conditions and proposed side conditions can be found in Attachment 19. The undertaking will not alter the characteristics of the property that qualify the property for inclusion in the National Register in a manner that would diminish the integrity of the property s location, design, setting, materials, workmanship, feeling, or association. The undertaking will result in no adverse effects to this historic property. MnHPO agreed with this recommendation in a comment letter dated April 8, 2016. Charles and Electa Getchell House (WA-AFC-087) The Charles and Electa Getchell House (WA-AFC-087) is located at 15990 32 nd Street S. The proposed improvements in this area include sanitary sewer installations (of which the property owners will be individually responsible for connecting) and replacement of bituminous pavement along 32 nd St and Pike Ave. The completed Minnesota Architecture-History Inventory Form and maps showing the existing site conditions and proposed side conditions can be found in Attachment 20. The undertaking will not alter the characteristics of the property that qualify the property for inclusion in the National Register in a manner that would diminish the integrity of the property s location, design, setting, materials, workmanship, feeling, or association. The undertaking will result in no adverse effects to this historic property. MnHPO agreed with this recommendation in a comment letter dated April 8, 2016. Congregational Church Parsonage (WA-AFC-065) The Congregational Church Parsonage (WA-AFC-065) is located at 3192 St. Croix Trail S. The proposed improvements in this area include sanitary sewer installations (of which the property owners will be individually responsible for connecting) and replacement of bituminous pavement and concrete sidewalks along St. Croix Trail S and 32 rd St. The completed Minnesota Architecture-History Inventory Form and maps showing the existing site conditions and proposed site conditions can be found in Attachment 21. The undertaking will not alter the characteristics of the property that qualify the property for inclusion in the National Register in a manner that would diminish the integrity of the property s location, design, setting, materials, workmanship, feeling, or association. The undertaking will result in no adverse effects to this historic property. MnHPO agreed with this recommendation in a comment letter dated April 8, 2016. Ferdinand Richert House (WA-AFC-069) The Ferdinand Richert House (WA-AFC-069) is located at 3326 St. Croix Trail S. The existing road north of the property (33 rd St S) is a road consisting of deteriorated bituminous pavement filled in with gravel, with no curb or drainage system. The road is functional, but is visibly worn with numerous cracks and potholes, and requiring maintenance. St. Croix Trail S is an asphalt paved road with a curb existing in only a few areas, minimal drainage, no designated turn lanes, and minimal pedestrian crossing points.

This road is functional, and in fair condition, but requires maintenance for its numerous cracks, potholes, and eroding roadsides. There is currently a concrete sidewalk running north-south in front (west) of the site, thought it also suffers from cracks, holes, and uneven pave blocks. Proposed improvements in this area include sanitary sewer installations (of which the property owners will be individually responsible for connecting) and replacement of bituminous pavement and concrete sidewalks along St. Croix Trail S. Bituminous pavement will also be replaced on 33 rd St. S, north of the site, adding space for parking, and several catch basins constructed near the property on St. Croix Trail S. Bump-outs, turn lanes, additional parking, crosswalks, and curb and gutter are also planned along St. Croix Trail S. The repaved sidewalk would be the only portion of the proposed improvements that sits on the property line for the site. The completed Minnesota Architecture-History Inventory Form and maps showing the existing site conditions and proposed side conditions can be found in Attachment 22. The proposed improvements may affect the current setting of the property by repairing existing deteriorated infrastructure. These effects will not adversely alter the characteristics that make the site eligible for inclusion in the NRHP. The undertaking will result in no adverse effects to this historic property. MnHPO agreed with this recommendation in a comment letter dated July 22, 2016. Selma s Ice Cream Parlor (WA-AFC-071) Selma s Ice Cream Parlor (WA-AFC-071) is located at 3419 St. Croix Trail S. The proposed improvements in this area include sanitary sewer installations (of which the property owners will be individually responsible for connecting) and replacement of bituminous pavement and concrete sidewalks along St. Croix Trail S. The completed Minnesota Architecture-History Inventory Form and maps showing the existing site conditions and proposed side conditions can be found in Attachment 23. The undertaking will not alter the characteristics of the property that qualify the property for inclusion in the National Register in a manner that would diminish the integrity of the property s location, design, setting, materials, workmanship, feeling, or association. The undertaking will result in no adverse effects to this historic property. MnHPO agreed with this recommendation in a comment letter dated April 8, 2016. Squire s House (WA-AFC-010) Squire s House (WA-AFC-010) is located at 3390 St. Croix Trail S. 34 th Street is a road consisting of deteriorated bituminous pavement filled in with gravel, with no curb or drainage system. The road is functional, but is visibly worn with numerous cracks and potholes, and requiring maintenance. Parking is already available for the park along the southern edge of 34 th Street, though parking is not specifically designated. There is also an existing concrete driveway that leads north from 34 th Street to the site and its associated garage, and an existing concrete sidewalk that runs north-south just east of the property. The currents sidewalk suffers from cracks, holes, and uneven pave blocks. St. Croix Trail S is an asphalt paved road with a curb existing in only a few areas, minimal drainage, no designated turn lanes, and minimal pedestrian crossing points. This road is functional, and in fair condition, but requires maintenance for its numerous cracks, potholes, and eroding roadsides. Proposed improvements in this area include sanitary sewer installations (of which the property owners will be individually responsible for connecting) and replacement of bituminous pavement and concrete sidewalks along St. Croix Trail S. Bump-outs, turn lanes, crosswalks, and curb and gutter are also planned along St. Croix Trail S. The southern half of the existing driveway will also be repaved in concrete, and a catch basin will run along the northern edge of 34 th Street. Parking spaces will also be added across the road from the site along the southern edge of 34 th Street for the neighboring park. The concrete driveway south of the property and the concrete sidewalk east of the property are the only affected elements included in the proposed improvements that sit on the property for the site. The completed Minnesota Architecture-History Inventory Form and maps showing the existing site conditions and proposed side conditions can be found in Attachment 24. This property is included on the maps for WA-AFC-011. The Squire s House

property is denoted by the address of 3390 on these maps. The proposed improvements may affect the current setting of the property by repairing existing deteriorated infrastructure. These effects will not adversely alter the characteristics that make the site eligible for inclusion in the NRHP. The undertaking will result in no adverse effects to this historic property. MnHPO agreed with this recommendation in a comment letter dated July 22, 2016. Cushing Hotel (WA-AFC-005) The Cushing Hotel (WA-AFC-005) is located at 3291 St. Croix Trail S. The existing road south of the property (33 rd St S) is a road consisting of deteriorated bituminous pavement filled in with gravel, with no curb or drainage system. The road is functional, but is visibly worn with numerous cracks and potholes, and requiring maintenance. St. Croix Trail S is an asphalt paved road with a curb existing in only a few areas, minimal drainage, no designated turn lanes, and minimal pedestrian crossing points. This road is functional, and in fair condition, but requires maintenance for its numerous cracks, potholes, and eroding roadsides. There is currently a concrete sidewalk running north-south in front of the site, thought it also suffers from cracks, holes, and uneven pave blocks. Proposed improvements in this area include sanitary sewer installations (of which the property owners will be individually responsible for connecting) and replacement of bituminous pavement and concrete sidewalks along St. Croix Trail S. Bituminous pavement will also be replaced on 33 rd St. S., south of the site, adding space for parking, and several catch basins constructed near the property on St. Croix Trail S. Bump-outs, turn lanes, additional parking, crosswalks, and curb and gutter are also planned along St. Croix Trail S. The repaved sidewalk would be the only portion of the proposed improvements that sits on the property line for the site. The proposed improvements may affect the current setting of the property by repairing existing deteriorated infrastructure. These effects will not adversely alter the characteristics that made the site eligible for inclusion in the NRHP. The undertaking will result in no adverse effects to this historic property. MnHPO agreed with this recommendation in a comment letter dated April 8, 2016. Rattlesnake Mound (21WA10) Previous investigations of the 21WA10 site indicated that the site has been previously impacted. Prior to initiation of the Section 106 review, the City of Afton completed investigations of the 21WA10 site and redesigned part of its project to avoid impacts to the 21WA10 site. These investigations were completed in consultation with the Office of the State Archaeologist, the Minnesota State Historic Preservation Office, and the Minnesota Indian Affairs Council. The 21WA10 area has been significantly damaged by previous activities in the area. Septic systems are currently discharging sewage into the Rattlesnake Mound. During the proposed project, these septic systems will be abandoned in place to avoid further disruption and excavation in the Rattlesnake Mound. Construction will occur in very close proximity to the Mound and includes directional drilling underneath the Mound. The new sanitary sewer services will be directionally drilled in areas of previous disturbance to avoid new impacts. Temporary construction fencing will be provided to delineate and protect a 20-foot wide buffer around the perimeter of the Rattlesnake Mound. An archaeologist will be on site to monitor construction within 21WA10. Monitoring during construction is required under Minn. Stat. 307.08 and the State Disposal System (SDS) permit issued by the MPCA to the City of Afton for the treatment facility. In addition, several entities during the Section 106 review consultation process recommended that monitoring occur for construction activities near the 21WA10 site. The City of Afton will monitor this site during construction. An Archaeological Monitoring Plan for Site 21WA10 and Unanticipated Discovery Plan is included as Attachment 25. These plans will become part of the contract documents and the contractor will be required to follow them.

The abandonment of the existing septic systems in 21WA10 will not adversely impact the site and will ultimately be a benefit by ending the discharge of sewage into the Mound. The proposed stormwater pond has the potential to enhance the historical integrity of the site because the design and plantings will be designed to be as natural as possible using only native plants. The MPCA has determined that the project will not alter any of the characteristics that make the Mound eligible for inclusion in the NRHP and therefore will result in no adverse effects to the 21WA10 site, including the Rattlesnake Mound. In a comment letter dated July 22, 2016, MnHPO expressed an opinion that a finding of no adverse effect may be appropriate for this site. 21WA116 Site This site was encountered during the Phase II testing for the Rattlesnake Mound. A lift station was originally planned to be constructed at the location of this archaeological site. The lift station was redesigned in a new location in order to fully avoid this historic property. An archaeological reconnaissance survey at the new lift station location was completed and the survey at the new location was negative. The project will result in no adverse effects to the 21WA116 site. Additional subsurface explorations were completed on the area east of the levee to explore observed mound-like landscape features. The levee is planned to be slightly relocated in this area. The area of the levee realignment has been adequately tested.

CONCLUSION A thorough investigation was completed to identify historic properties within the APE and assess effects to those historic properties. After completing this investigation, the MPCA determined that the proposed project will result in No Adverse Effect on historic properties. In addition, while not part of the scope of this review, the MPCA notes that the project as proposed provides significant environmental improvements within the APE by addressing issues with stormwater management, flooding, and improper wastewater treatment. It also addresses concerns regarding the existing septic systems discharging sewage into the Rattlesnake Mound and helps preserve the Mound s future integrity.