The Broad River Pointe Development, Dekalb County, Georgia

The Historic Preservation Division (HPD) has reviewed the draft report entitled, "An Archaeological Assessment of the Broad River Pointe Subdivision Tract, DeKalb County, Georgia,," carried out under the direction of Thomas H. Gresham, Principal Investigator, as well as comments on this report dated April 30, 1997 which were prepared by Corps of Engineers Staff Archaeologist Dave Crampton.

Based on the information contained in this report, and on site visits conducted by our staff, HPD concurs with the recommendation that the intact portions of archaeological site 9DA 17 (the McGarityEtheridge Site) retain sufficient integrity to be considered eligible for listing in the National Register of Historic Places under Criterion "D." HPD further concurs with the recommendation that archaeological sites 9DA23, 9DA24, 9DA60, 9DA82 and 9DA84 no longer retain sufficient integrity to meet the National Register eligibility criteria. Based on the April 3 0, 1997 report comments provided, as well as previous consultation, HPD understands that the Corps of Engineers agrees with these eligibility recommendations, as well as the determination that this undertaking has resulted in an adverse effect to the Soapstone Ridge Historic District. Furthermore, HPD concurs with the recommendation that in-place preservation of a 6-acre archaeological preserve, as described in the report, is an appropriate mitigation measure for the destruction of a portion of this resource.

The next step in the Section 106 process is to enter into consultation and execute a Memorandum of Agreement (MOA) stipulating the mitigation measures to be carried out. The Corps first forwarded a "preliminary first draft" of an MOA to OW" office on March 19, 1997. Under 36 CfR Part 800, the regulations implementing the Section 106 review process, we understand that the Corps would normally prepare a revised MOA for signature and circulation. However, because of the extraordinary delays already experienced in regulatory review of this project, we have taken the liberty of redrafting your March 19th draft MOA.