HomeMy WebLinkAbout20241004_Criteria A B and C_City of CaldwellDEPARTMENT OF THE ARMY
U.S. ARMY CORPS OF ENGINEERS,
BOISE FIELD OFFICE
720 E PARK BLVD #245 BOISE, ID 83712
October 4, 2024
Regulatory Division
USACE No. NWW-2021-00626
SUBJECT: Eligibility of 10CN157 Under National Register Criteria A, B, and C
Ms. Morgan Besaw
Depty Director, City of Caldwell
621 Cleveland Blvd.
Caldwell, Idaho 83605
mbessaw@cityofcaldwell.org
Dear Ms. Besaw:
On September 12, 2024 the United States Army Corps of Engineers (USACE) sent a
cultural resources survey report out for comment that documented an auger testing and
geophysical survey conducted by Cannon Heritage Consultants to define the
boundaries of archaeological site 10CN157 affiliated with the Huntington Ridge East
Subdivision Project (SHPO Review Number 2023-887). On September 13, 2024 the
Nez Perce Tribal Historic Preservation Officer responded to USACE requesting that
USACE specifically consult on the eligibility of 10CN157 under National Register criteria
A, B, and C, since USACE has only been talking about our evaluation of the site under
Criterion D. This letter addresses that comment.
Criterion A
Under criterion A, a property can be eligible for the NRHP if it is associated with a
"specific event marking an important moment in American prehistory or history" or
associated with "a pattern of events, repeated activities or historic trends" (from How to
Complete the National Register Form, National Register Bulletin No. 15). In addition to
this association with events the site must also demonstrably convey significance. For an
archaeological site, this would require "well-preserved features, artifacts and intra-site
patterning...to illustrate a specific event or patterns of events…" (from Guidelines for
Evaluating and Registering Archaeological Sites, National Register Bulletin No. 36). The
high bar for the eligibility of archaeological sites under criterion A is also eluded to in
National Register Bulletin No. 15 which states "for archaeological sites, well-reasoned
inferences drawn from data recovery at the site can be used to establish the association
between the site and events". These statements illustrate the relatively high evidentiary
burden for establishing the NRHP eligibility of an archaeological site under Criterion A.
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Archaeological investigations at site 10CN157 have shown that it is an
archaeological site preserving multiple precontact components in a good archaeological
context. To date, the work has not established specific events or activities conducted at
the site, whether the individual components represent single occupations or repeated
visits, the presence of well-preserved features, etc. As such, the site does not
demonstrate an ability to convey significance in association with historic events.
Therefore, USACE recommend that the site be considered not eligible for the NRHP
under criterion A
Criterion B
Criterion B provides for the eligibility of a property through its association with a
specific historic individual. The associated historic individual must have made some
important contribution to history. This contribution must be individually significant. We
have found no association between site 10CN157 and any historic individual. Therefore,
USACE recommend that the site be considered not eligible for the NRHP under criterion
B.
Criterion C
For criterion C to apply "the property must embody distinctive characteristics of a
type, period, or method of construction, represent the work of a master, possess high
artistic value, or represent a significant and distinguishable entity whose components
lack individual distinction" (National Register Bulletin No. 15). The final clause of
criterion C applies to historic districts and does not apply to this discussion. The intent of
criterion C is to "distinguish those properties that are significant as representatives of
human expression of culture or technology (especially architecture, artistic value,
landscape architecture, or engineering [National Register Bulletin No. 36]). To date,
archaeological investigations at site 10CN157 have not documented any feature that
conforms to criterion C's definition or intent. Since such a feature must be demonstrated
to both exist and convey its significance for criterion C to apply, we recommend that site
10CN157 be considered not eligible for the NRHP under criterion C.
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USACE would appreciate your concurrence or comment on this evaluation within 30
days from the date of this letter. If you have any information that would change the
evaluation of the site under any of these criteria, please let us know. This letter has
been furnished to the following parties: Shoshone-Paiute Tribes, Shoshone Bannock
Tribes, Nez Perce Tribe, Idaho State Historic Preservation Office, Ken Reid, Hayden
Homes, City of Caldwell, Chris Hill, and Canyon County. If you have any questions,
please do not hesitate to contact Ms. Carolyn Smith by telephone at (208) 433-4497 or
by email at carolyn.d.smith@usace.army.mil or Ms. Anna Jansson, Regulatory Division
Archaeologist, by telephone at 971-295-1443 or by email at
anna.m.jansson@usace.army.mil.
Sincerely,
Anna Jansson
Archaeologist, Regulatory Division