IndianLakeSP.Sec106Application.24Mar2021.pdf

APPLICATION FOR SHPO SECTION 106 CONSULTATION

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Submit one application for each project for which comment is requested. Consult the Instructions for the Application for SHPO Section 106 Consultation Form when completing this application.

Mail form, all attachments, and check list to: Michigan State Historic Preservation Office, 300 North Washington Square, Lansing, MI 48913

I. GENERAL INFORMATION ☐ New submittal

☒ More information relating to SHPO ER# 98-52.12

☐ Submitted under a Programmatic Agreement (PA)

PA Name/Date: PA name/date, if applicable

a. Project Name: Indian Lake State Park – Toilet/Shower Buildings Replacement and

New Drain Fields

b. Project Municipality: City of Manistique

c. Project Address (if applicable): 8970 County Highway 442, Manistique, MI 49854

d. County: Schoolcraft County

II. FEDERAL AGENCY INVOLVEMENT AND RESPONSE CONTACT INFORMATION

a. Federal Agency: U.S. Department of the Interior - National Park Service, Midwest Region, Land and Water Conservation Fund

Contact Name: Michael Reynolds

Contact Address: 601 River Front Drive City: Omaha State: NE Zip: 68102

Email: Federal contact email Specify the federal agency involvement in the project: Federal Grant Source

b. If HUD is the Federal Agency: 24 CFR Part 50 ☐ or Part 58 ☐

Responsible Entity (RE): Name of the entity that is acting as the Responsible Entity

Contact Name: RE Contact name

Contact Address: RE mailing address City: RE city State: RE State Zip: RE zip code

RE Email: RE contact’s email Phone: RE contact’s phone #

c. State Agency Contact (if applicable): Michigan Department of Natural Resources, Finance & Operations Division, Land and Water Conservation Fund Program

Contact Name: Christie Bayus

Contact Address: P.O. Box 30257 City: Lansing Zip: 48909-7973

Email: bayusc@michigan.gov Phone: 517-284-5923

d. State Agency Contact (if applicable): Michigan Department of Natural Resources, Parks and Recreation Division

Contact Name: Eric Cadeau, Western Upper Peninsula Regional Field Planner

Contact Address: 427 US-41 North City: Baraga Zip: 49946

Email: cadeaue@michigan.gov Phone: 906-241-8318

e. Applicant (if different than federal agency): Sanders & Czapski Associates, PLLC

Contact Name: Ken Czapski Contact Address: 109 South Front St, Suite 210 City: Marquette State: MI Zip: 49855

Email: ken@sanders-czapski.com Phone: 906-273-1207

f. Consulting Firm (if applicable): Commonwealth Heritage Group, Inc.

Contact Name: Brandon Gabler

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Contact Address: 3215 Central Street City: Dexter State: MI Zip: 48197

Email: bgabler@chg-inc.com Phone: 571-488-5912

III. PROJECT INFORMATION

a. Project Location and Area of Potential Effect (APE)

i. Maps. Please indicate all maps that will be submitted as attachments to this form.

☐Street map, clearly displaying the direct and indirect APE boundaries

☒Site map

☒USGS topographic map Name(s) of topo map(s): Manistique West quadrangle, 7.5’ ☒Aerial map

☒Map of photographs

☐Other: Identify type(s) of map(s)

ii. Site Photographs

iii. Describe the APE:

The archaeology APE is defined to include all areas that may be impacted by ground disturbing activities related to the Project undertaking. Ground disturbing activities related to the new wastewater disposal system and construction of the new toilet/shower building are planned to occur in a 7.0 ha (17.3 ac) wooded area south of the 0.28 ha (0.70 ac) partially grass covered and wooded area that may become disturbed as a result of removing the central toilet/shower building.

The above-ground APE encompasses the entirety of the south unit of Indian Lake State Park. It is 69.0 ha (170.5 ac) and is roughly bounded by County Highway 442 on the south, County Highway 441 on the east, Sandy Shores Campground on the west, and Indian Lake on the north.

iv. Describe the steps taken to define the boundaries of the APE:

The archaeology APE was defined by the Sanders & Czapski and the DNR – Parks and Recreation Division (PRD) as the area in which project related ground disturbing activity is planned to occur.

The above-ground APE was defined to include the entirety of the south unit of Indian Lake State Park to account for any indirect effects on the campground as a whole. Developed in the mid-1930s, the park comprises a designed cultural landscape. Any alterations to the park’s design, such as the removal of the toilet/shower buildings, may affect the integrity of the overall landscape. No parcels outside of the park were included in the above-ground APE; heavy tree cover precludes views to and from any of the neighboring properties.

b. Project Work Description Describe all work to be undertaken as part of the project:

The Indian Lake State Park Project includes removing and replacing the north and central toilet/shower buildings with one standardized toilet/shower building. The north toilet building will be demolished to 24 inches below grade and undergo site restoration. The new standard toilet building will be constructed at the site of the existing central toilet building. New ADA compliant sidewalks, site grading, and landscaping to connect the building to the existing parking area and roadway will be constructed. Three to four new parking spaces, at least one of which will be a van accessible ADA-compliant parking space and access aisle, will be constructed near the new toilet building as well. The second component of the project involves demolishing or abandoning two standalone drain fields and removing the existing lagoon and replacing all three on-site sewage disposal systems with one combined sewage disposal system. The new combined sewage disposal system will be either a lagoon or drain field. A third component of the Project includes replacing the existing waterline that supports the north toilet building.

IV. IDENTIFICATION OF HISTORIC PROPERTIES

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a. Scope of Effort Applied

i. List sources consulted for information on historic properties in the project area (including but not limited to SHPO office and/or other locations of inventory data).

Commonwealth conducted a literature review at the Michigan SHPO compiling information regarding previously identified archaeological sites and surveys in the archaeology APE and in a 1.6-km (1.0-mi) area surrounding the archaeology APE (Archaeology Study Area). Commonwealth compiled information derived from a review of the National and State Registers of Historic Places, historic aerials, and maps.

Commonwealth also conducted a desktop review of above-ground architectural/historic resources in the Above-Ground Study Area, which extends in a radius of 0.8 km (0.5 mi) beyond the project location.

Sanders & Czapski provided photographs of the toilet/shower buildings slated for demolition.

ii. Provide documentation of previously identified sites as attachments.

iii. Provide a map showing the relationship between the previously identified properties and sites, your project footprint and project APE.

iv. Have you reviewed existing site information at the SHPO: ☒Yes ☐ No

v. Have you reviewed information from non-SHPO sources: ☒Yes ☐ No

b. Identification Results

i. Above-ground Properties

A. Attach the appropriate Michigan SHPO Architectural Identification Form for each resource or site 50 years of age or older in the APE. Refer to the Instructions for the Application for SHPO Section 106 Consultation Form for guidance on this.

B. Provide the name and qualifications of the person who made recommendations of eligibility for the above-ground identification forms.

Name Katie Remensnyder Agency/Consulting Firm: Commonwealth Heritage Group, Inc.

Is the individual a 36CFR Part 61 Qualified Historian or Architectural Historian ☒ Yes ☐ No

Are their credentials currently on file with the SHPO? ☒ Yes ☐ No If NO attach this individual’s qualifications form and resume.

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ii. Archaeology (complete this section if the project involves temporary or permanent ground disturbance)

Submit the following information using attachments, as necessary.

A. Attach Archaeological Sensitivity Map.

B. Summary of previously reported archaeological sites and surveys:

SHPO records indicate that in an area that overlaps the planned ground disturbance, three structures from the Indian Lake CCC Camp (20ST280) were standing as of 1996 and that wooden foundation remains of two structures were still present. Although some form of archaeological investigation has occurred, no systematic surveys appear to have occurred in the Archaeology APE. For additional information, refer to the Application For Permit to Perform Archaeological Exploration On State- Owned Land dated February 12, 2021, Attachment A.

C. Town/Range/Section or Private Claim numbers: E/12 of Section 17, T41N R16W

D. Width(s), length(s), and depth(s) of proposed ground disturbance(s): North area; 68 m (225 ft) northeast-southwest by 43 m (142 ft) northwest-southeast. South Area: 389 m (1227 ft) northeast-southwest by 202 m (663 ft) northwest-southeast.

E. Will work potentially impact previously undisturbed soils? ☒ Yes ☐ No If YES, summarize new ground disturbance:

In the south area, mechanized excavation for the construction of the new wastewater disposal system is planned. The limits of tis disturbance are planned to exceed the footprint of the current wastewater disposal system. In the north area, the existing structure is planned to be removed. Ground disturbance caused by the removal of the existing structure may exceed the area disturbed during the building’s construction, and tracked vehicle and other construction/demolition vehicle traffic is likely to cause ground surface and near ground surface disturbance.

F. Summarize past and present land use:

The area is near the shore of Indian Lake. The Indian Lake CCC camp occupied the area, which is now a developed campground.

G. Potential to adversely affect significant archaeological resources:

☐ Low ☐ Moderate ☒ High

For moderate and high potential, is fieldwork recommended? ☒ Yes ☐ No Briefly justify the recommendation:

Because the aerial extent of the camp and the locations of potentially buried cultural resources are unknown, Commonwealth recommends archaeological field investigation of the areas of planned ground disturbance prior to ground disturbing activity. Commonwealth's research objectives include determining if any part site 20ST280, or another site, is in or partly in the areas where ground disturbance is planned to occur, identifying intact features or in-context cultural materials in the area surveyed, establishing site boundaries, and establishing the period of site occupancy.

H. Has fieldwork already been conducted? ☐ Yes ☒ No If YES:

☐ Previously surveyed; refer to A. and B. above.

☐ Newly surveyed; attach report copies and provide full report reference here:

Full report reference

I. Provide the name and qualifications of the person who provided the information for the Archaeology section:

Name: Ethan A. Epstein, PhD Agency/Firm: Commonwealth Heritage Group Inc.

Is the person a 36CFR Part 61 Qualified Archaeologist? ☒ Yes ☐ No

Are their credentials currently on file with the SHPO? ☒ Yes ☐ No If NO, attach this individual’s qualifications form and resume.

Archaeological site locations are legally protected.

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This application may not be made public without first redacting sensitive archaeological information.

V. IDENTIFICATION OF CONSULTING PARTIES

a. Provide a list of all consulting parties, including Native American tribes, local governments, applicants for federal assistance/permits/licenses, parties with a demonstrated interest in the undertaking, and public comment:

The DNR is pursuing a National Park Service – Land and Water Conservation Fund grant. The National Park Service will become one of the key consulting parties. Contact:

U.S. Department of the Interior – National Park Service Midwest Region, Land & Water Conservation Fund Attn: Mr. Michael Reynolds 601 River Front Drive Omaha, NE 68102 Phone: 402-661-1736

State Agency contact:

Michigan Department of Natural Resources Michigan Land & Water Conservation Fund Program Finance and Operations Division Attn: Ms. Christie Bayus P.O. Box 30257 Lansing, MI 48909-7973 Phone: 517-284-5923 E-mail: bayusc@michigan.gov

b. Provide a summary of consultation with consultation parties:

No consultation has occurred at this time.

c. Provide summaries of public comment and the method by which that comment was sought:

There has been no public comment solicited at this time. The DNR did not intend to solicit public comment on the proposed improvements. The proposed improvements are typical of a replacement-in-kind project scope, and it is anticipated that there is limited to no demonstrated public interest.

VI. DETERMINATION OF EFFECT

Guidance for applying the Criteria of Adverse Effect can be found in the Instructions for the Application for SHPO Section 106 Consultation Form.

a. Basis for determination of effect:

Commonwealth recommends archaeological field investigation of the areas of planned ground disturbance prior to ground disturbing activity. An Application for Permit to Perform Archaeological Exploration on State-Owned Land was submitted February 5, 2021, to the Michigan DNR that encompasses the northern and southern areas of planned ground disturbance. Additional discussion related to 20ST280 and the results of Commonwealth’s field investigation, expected to occur following spring 2021 ground thaw, will subsequently be reported separately.

Commonwealth recommends additional survey for determining the eligibility of the south unit of Indian Lake State Park as a whole. Built using CCC and WPA labor in the mid-1930s, it may be eligible under Criterion A for Politics/Government and in the area of Recreation. It may also be eligible under Criterion C for its Rustic-style architecture. Its period of significance would be from 1932 through 1937, which encompasses the state’s acquisition of the land and the initial development of the park using CCC and WPA labor. Despite the

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campground’s potential eligibility, the two toilet/shower buildings slated for demolition were built in 1952, after the potential period of significance. They have no associations with the CCC or WPA and do not reflect any significant developments in recreation. They are recommended as non-contributing to any potential historic district that encompasses the entirety of the south unit of Indian Lake State Park. Both buildings are also recommended as not individually eligible for listing in the NRHP under Criteria A or Criteria C for architecture.

Further, both toilet/shower buildings have previously received clearance from SHPO. SHPO concurred with the removal of the both the north toilet/shower building and the central toilet/shower building (ER-98-52.12) on February 22, 2012.

b. Determination of effect

☐ No historic properties will be affected or

☐ Historic properties will be affected and the project will (check one):

☐ have No Adverse Effect on historic properties within the APE.

☐ have an Adverse Effect on one or more historic properties in the APE and the federal agency, or federally authorized representative, will consult with the SHPO and other parties to resolve the adverse effect under 800.6.

☒ More Information Needed: We are initiating early consultation. A determination of effect will be submitted to the SHPO at a later date, pending results of survey.

Federally Authorized Signature:___________________________________ Date:_______________

Type or Print Name: _____________________________________________

Title: ______________________________________________________________

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ATTACHMENT CHECKLIST

Identify any materials submitted as attachments to the form:

☐ Additional federal, state, local government, applicant, consultant contacts

☒ Maps of project location

Number of maps attached: 2

☒ Site Photographs

☒Map of photographs

☐ Plans and specifications

☐ Other information pertinent to the work description: Identify the type of materials attached

☐ Documentation of previously identified historic properties

☒ Architectural Properties Identification Forms

☒ Map showing the relationship between the previously identified properties, your project footprint, and project

APE

☐ Above-ground qualified person’s qualification form and resume

☒ Archaeological sensitivity map

☐ Survey report

☐ Archaeologist qualifications and resume

☐ Other: Identify other attached materials

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Aerial image showing areas of planned ground disturbing activity

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Previously recorded archaeological sites and recorded surveys within 1.6 m (1.0 mi) of planned ground disturbing activity

Attachment A: Application For Permit to Perform Archaeological Exploration On State-Owned Land

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Michigan Department of Natural Resources – Michigan Historical Center

APPLICATION FOR PERMIT TO

PERFORM ARCHAEOLOGICAL EXPLORATION ON

STATE-OWNED LAND

By Authority of Part 761, 1994 PA 451, as amended

DNR USE ONLY

Permit AE -

Date Received

Applicant Ethan A. Epstein, Ph.D.

Affiliation (title and university/company/agency/ tribe, etc.)

Commonwealth Heritage Group, Inc.

Business Address 3215 Central Street

Telephone

(517) 788-3550

City, State, ZIP Dexter, Michigan 48130

Alternate Telephone/Cell Phone

(715) 482-0273

Email Ethan.epstein@chg-inc.com

FAX

LOCATION OF PROPOSED EXPLORATION

Provide the legal description of lands for which a permit is requested. Include county and township names, town-range-section, and any surface jurisdiction information available. Attach a 1:24,000 scale, 7.5’ USGS Topographic Quadrangle map indicating the proposed permit area and provide the quadrangle name. Attach any additional maps to indicate detail, including aerials, where appropriate; list any attachments below.

The proposed Permit Area is in the E/12 of Section 17, T41N R16W, Thompson Township, Schoolcraft County, Michigan and is included on Manistique West 7.5’ USGS quadrangle maps. The Permit Area encompasses approximately 14.5 ha (36.0 ac) and includes two areas in which ground disturbing activity is planned to occur; a 7.0 ha (17.3 ac) southern area and a 0.28 ha (0.70 ac) northern area.

Attachment A – Proposed Permit Area, 1:24,000 scale. The proposed 14.5 ha (36.0 ac) Permit Area is in Indian Lake State

Park.

Attachment B – Proposed Permit Area, 2020 aerial image. Image shows a trail entering the proposed Permit Area from the east, existing sewage lagoons near the center of the southern area of planned ground disturbance, a smaller oblong shaped clearing adjacent to the west side of the lagoons, and a series of graveled roads, graveled parking areas, and grass covered camping areas near the Permit Area’s northwest and southwest boundaries.

Existing restroom facilities are present in or adjacent to the southern area and a restroom facility is present in the northern area of planned ground disturbance.

Attachment C – Proposed Permit Area, 1953 aerial image. The sewage lagoons do not appear to be present on this 1953 aerial image, however, the clearing adjacent to the west side of the lagoons visible on Attachment B appears larger, rectangular, and more well defined. A second cleared area, or ground scar, is visible in the northwest corner of the proposed southern area and one possible structure is discernable in the northwest corner of the southern area.

QUALIFICATIONS

Describe the applicant’s training and experience in archaeology. The applicant should meet the Secretary of the Interior’s professional qualification standards for archaeology (36 CFR Part 61; 48 Fed. Reg. 44716, 1983). Are the applicant’s qualifications currently on file with the State Archaeologist? If not, list and attach appropriate supporting documents (curriculum vitae, etc.).

Dr. Ethan Epstein (University of Wisconsin-Milwaukee, 2016) has over 16 years of experience in archaeology. His specialties include early pre-contact, pre-contact, early post-contact, and post-contact archaeology of the Upper Great Lakes, Great Basin regions, northern Great Plains, and he has experience in select southeastern areas as well. He has cultural resource management experience serving both private and public-sector clients, including the USFS, USACE, BLM, NPS, National Guard, and state transportation and natural resource departments. Having conducted numerous Phase I and Phase II investigations in Michigan, his work is known to the MI SHPO.

PURPOSE OF EXPLORATION AND RESEARCH DESIGN

Provide a detailed description of the purpose of the proposed archaeological exploration and the research questions and design guiding the work. Include background information about the project area, including information obtained from the State Archaeological Site File. Identify specific research questions to be addressed. List and attach any supporting documents.

The purpose of the proposed archaeological survey is to identify postcontact and/or precontact artifacts, sites, or features that may be present in the proposed areas of ground disturbance in the Permit Area for new facilities. The MI DNR – Parks and

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Recreation Division (PRD) proposes to replace the existing wastewater lagoon with either a septic tank and tile field or a PSC recommended wastewater disposal system (lagoon, etc.) per consultation with the local health department and EGLE (DEQ) wastewater disposal design requirements (Attachment D), construct a new restroom facility in the southern area of planned ground disturbing activity near the possible structure visible on the 1958 aerial (see Attachment C), and remove a restroom facility in the northern area of planned ground disturbing activity. Pre-field research in an area that includes the proposed Permit Area and a one-mile buffer around the proposed Permit Area was completed. SHPO records indicate three structures from the Indian Lake CCC Camp (20ST280, Attachment E, Attachment F, Attachment G) were standing as of 1996 and that wooden foundation remains of two structures were still present. Because the total area of the camp is unknown, Commonwealth's research objectives include determining if any part of the site (or another site) is in or partly in the areas where ground disturbance is planned to occur, identifying intact features or in-context cultural materials in the area surveyed, establishing site boundaries, and establishing the period of site occupancy.

METHODS

Describe field methods to be employed, whether surface survey, shovel testing, test excavations, block excavations, etc., and the rationale behind the methods to be used. Explain what data will be sought, and how the data will help answer the specified research questions. Explain how resulting earth disturbance will be restored. Include a plan of action for the unanticipated discovery of human remains. List and attach any supporting documents.

The archaeological survey of the north grass covered and partially wooded area and the south wooded area – the areas of planned ground disturbance –is proposed to consist of surface survey and shovel testing. Typically, surface survey would not be employed in wooded areas such as these; however, the reported presence in 1996 of foundation remains from the CCC camp warrants surface inspection at closer interval than is afforded during shovel testing at standard intervals. Systematic surface survey at an interval not to exceed 10 m (32 ft) is planned to target foundations, other features, and cultural materials that might help to define, set the boundaries of, and establish the period of occupancy for 20ST280 or another site if present.

The placement of shovel test probes at 15-m (49-ft) intervals across the proposed areas of ground disturbance is planned to target near-surface cultural material that might help to define, set the boundaries of, and establish the period of occupancy for 20ST280 or another site if present. All precontact cultural material and non-architectural postcontact material will be collected by Commonwealth unless the cultural deposits identified are considered in the field as too voluminous, in which case a representative sample of artifacts will be collected. Architectural debris will not be collected; rather, it will be inventoried and recorded.

PRELIMINARY RESULTS

The State Archaeologist reserves the right to examine results of field research upon its completion. Indicate where the recovered materials and supporting documentation will be available for inspection:

Recovered cultural material, supporting documentation, and all field records will be available at Commonwealth’s Dexter, Michigan facilities.

ADDITIONAL INFORMATION

Provide any other information for use in evaluating this application. List and attach any supporting documents.

REPORTING - Approved permits expire one year from date of issuance.

A draft report detailing the results of this archaeological exploration must be submitted to the State Archaeologist for comment prior to permit expiration. This report shall follow the Secretary of the Interior’s Standards and Guidelines for Archaeological Documentation (36 CFR Part 61; 48 Fed. Reg. 44716, 1983) and any additional standards stipulated by the State Archaeologist and will include state site numbers for any resources identified. Two copies of the final report (one hardcopy on acid-free archival paper and one pdf on compact disc) must be submitted to the State Archaeologist within three months following receipt of the State Archaeologist’s comments on the draft report. The State Archaeologist will distribute copies of the final report to the Michigan Department of Natural Resources (DNR) and interested federally recognized tribal organizations.

DATA DISPOSITION

All materials recovered and original documentation created, including, but not limited to, notes, photographs, maps, and data logs are the property of the State. All such data will be submitted to the State Archaeologist with the final report of exploration, or at a time formally agreed to by the State Archaeologist and will meet the collections standards outlined by the State Archaeologist. If the applicant desires to retain data for an extended period of study or exhibit, a formal loan agreement should be requested.

Do you anticipate that a loan agreement will be requested? No

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PERMIT HISTORY

List previous Archaeological Exploration Permits received from Michigan DNR; include number, purpose, and date.

AE2019-05, Survey for the Iosco Exploration Trail, August 1, 2019.

This permit process assures that cultural and environmental resources of the State of Michigan are protected and treated with responsible stewardship. Be advised that a complete application for permit can take up to 45 days to process.

I hereby certify that all statements on this application and the attachments hereto are true.

February 12, 2012

Applicant Signature Date

RETURN COMPLETED APPLICATION TO:

SANDRA S. CLARK, DIRECTOR

MICHIGAN HISTORICAL CENTER

702 W. KALAMAZOO STREET

PO BOX 30740

LANSING, MI 48909-8240

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Attachment A – Proposed Permit Area, 1:24,000 scale

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Attachment B – Proposed Permit Area, 2020 aerial image

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Attachment C – Proposed Permit Area, 1953 aerial image

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Attachment D – State of Michigan Project Statement, page 1

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Attachment D – State of Michigan Project Statement, page 2

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Attachment D – State of Michigan Project Statement, page 3

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Attachment D – State of Michigan Project Statement, page 4

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Attachment D – State of Michigan Project Statement, page 5

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Attachment E – Previously identified archaeological sites and previous surveys in 1.0 miles of the Proposed Permit Area overlain on 2020 aerial image

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Attachment F – Previously identified archaeological sites and previous surveys in 1.0 miles of the Proposed Permit Area, 1:24,000 scale

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Attachment G – Site record for 20ST280, the Indian Lake CCC Camp – page 1

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Attachment G – Site record for 20ST280, the Indian Lake CCC Camp – page 2 Att

ANDREW J. WEIR, PRESIDENT

ajweir@chg-inc.com

HEADQUARTERS

3215 Central Street Dexter, MI 48130 P: (517) 788-3550

OTHER LOCATIONS

Alexandria, VA (703) 354-9737 Columbus, OH (614) 549-6190 Gainesville, FL (352) 372-2633 Littleton, MA (978) 793-2579

Milwaukee, WI (414) 446-4121 Minneapolis, MN (763) 354-9313 Ogden, UT (801) 394-0013 Tarboro, NC (252) 641-1444 Traverse City, MI (517) 262-3376 Tucson, AZ (517) 262-3376 West Chester, PA (610) 436-9000 www.commonwealthheritagegroup.com

March 15, 2021 J-1118/R-1533

Ken Czapski, AIA Sanders & Czapski Associates, PLLC 109 South Front Street, Suite 210 Marquette, MI 49855

RE: Indian Lake State Park – Toilet/Shower Buildings Replacement and New Drain Fields, Schoolcraft County, Michigan

Dear Mr. Czapski, Commonwealth Heritage Group, Inc. (Commonwealth) completed a preliminary cultural resources assessment for Sanders & Czapski (Client) for the Indian Lake State Park Toilet/Shower Building Replacement and New Drain Fields Project (Project) in the S½ of Section 19, T41N R16W, Schoolcraft County, Michigan (Figure 1). The Client provided maps and photographs of the Project location to Commonwealth on January 23, 2021, and additional photographs and information on February 10, 2021, including Keyhole Markup language Zipped (.kmz) files delineating the three component areas relating to the Project. Project funding is through the Michigan Department of National Resources – Parks and Recreation Division

(DNR).

The first component of the Project includes removing and replacing the north and central toilet/shower buildings with one standardized toilet/shower building. The north toilet building will be demolished to 24 inches below grade and undergo site restoration. The new standard toilet building, which is based on the toilet/shower design for Wilderness State Park, will be constructed at the site of the central toilet building. New ADA compliant sidewalks, site grading, and landscaping to connect the building to the existing parking area and roadway will be constructed. Three to four new parking spaces, at least one of which will be a van accessible ADA-compliant parking space and access aisle, will be constructed near the new toilet building as well. The second component of the Project involves demolishing or abandoning two standalone drain fields and removing the existing lagoon and replacing all three on-site sewage disposal systems with one combined sewage disposal system. The new combined sewage disposal system will be either a lagoon or drain field. The third component of the Project includes replacing the existing waterline that supports the north toilet building.

The Project Area, or area of potential effects (APE) for archaeological resources (Archaeology APE), is defined to include all areas that may be impacted by ground disturbing activities related to the Project undertaking. Ground disturbing activities related to the new wastewater disposal system and construction of the new toilet/shower building are planned to occur in a 7.0 ha (17.3

ac) area south of the 0.28 ha (0.70 ac) area that may become disturbed as a result of removing the north toilet/shower building (Figure 1). The Above-Ground APE encompasses the entirety of the south unit of Indian Lake State Park. It is 69.0 ha (170.5 ac) and accounts for any indirect effects on the park as a whole. Developed in the mid-1930s, the park comprises a designed cultural landscape. Any alterations to the park’s design, such as the removal of the toilet/shower buildings, may affect the integrity of the overall landscape. No parcels outside of the park were included in the above-ground APE; heavy tree cover precludes views to and from any of the neighboring properties.

This letter report provides the results of the background research as well as an assessment of the potential for the APE to contain National Register of Historic Places (NRHP) eligible or listed historic properties that are protected under NHPA. For the background research, Commonwealth conducted a literature review at the Michigan SHPO compiling information regarding previously identified archaeological sites and surveys in the Archaeology APE and in a 1.6-km (1.0-mi) area surrounding the Archaeology APE (Archaeology Study Area). Commonwealth compiled information derived from a review of the National and State Registers of Historic Places, historic aerials and maps, for understanding the archaeological potential in the Archaeology APE.

Commonwealth also conducted a desktop review of above-ground architectural/historic resources in the Above-Ground Study Area, which extends in a radius of 0.8 km (0.5 mi) beyond the project location. Sanders & Czapski provided photographs of the toilet/shower buildings slated for demolition. Any additional above-ground field survey and photography that may be required will be carried out in the spring when there is no snow on the ground, if necessary.

Archaeological Review

As Commonwealth understands the Project, the DNR proposes to replace the existing wastewater lagoon with either a septic tank and tile field or a wastewater disposal system (lagoon, etc.), construct a new toilet/shower building in the same location as the existing central toilet/shower building, and remove the north toilet/shower building. Ground disturbing activities related to the new wastewater disposal system and construction of the new toilet/shower building are planned to occur in a 7.0 ha (17.3 ac) area south of the 0.28 ha (0.70 ac) area that may become disturbed as a result of removing the north toilet/shower building (Figure 2).

Pre-field research in the area that includes the northern and southern planned areas of ground disturbance and a one-mile buffer around the proposed ground disturbance areas was completed (Figure 3). SHPO records indicate that in an area that overlaps the planned ground disturbance, three structures from the Indian Lake Civilian Conservation Corps (CCC) Camp (20ST280) were standing as of 1996 and that wooden foundation remains of two structures were still present.

Because the total area of the camp and the locations of potentially buried cultural resources are unknown, Commonwealth recommended archaeological field investigation of the areas of planned ground disturbance prior to ground disturbing activity. The purpose of the proposed archaeological survey is to identify postcontact and/or precontact artifacts, sites, or features that may be present in the proposed areas of ground disturbance. Commonwealth's research objectives include determining if any part site 20ST280, or another site, is in or partly in the areas where ground disturbance is planned to occur, identifying intact features or in-context cultural materials in the area surveyed, establishing site boundaries, and establishing the period of site occupancy.

An Application for Permit to Perform Archaeological Exploration on State-Owned Land was submitted February 5, 2021, to the Michigan DNR that encompasses the northern and southern areas of planned ground disturbance (Permit Area, see Figure 2 and Figure 3). The recommended archaeological survey of the north grass covered and partially wooded area and the south wooded area – the areas of planned ground disturbance –is proposed to consist of surface survey and shovel testing. Typically, surface survey would not be employed in wooded areas such as these;

however, the reported presence in 1996 of foundation remains from the CCC camp warrants surface inspection at closer interval than is afforded during shovel testing at standard intervals.

Systematic surface survey at an interval not to exceed 10 m (32 ft) was recommended to target foundations, other features, and cultural materials that might help to define, set the boundaries of, and establish the period of occupancy for 20ST280 or another site if present. The placement of shovel test probes at 15-m (49-ft) intervals across the proposed areas of ground disturbance was recommended to target near-surface cultural material that might help to define, set the boundaries of, and establish the period of occupancy for 20ST280 or another site if present.

Additional discussion related to 20ST280 and the results of Commonwealth’s field investigation, expected to occur following spring 2021 ground thaw, will subsequently be reported separately.

Above-Ground Resources

For the Indian Lake State Park Project, the Above-Ground APE that accounts for indirect effects is considered to include those cultural resources (buildings, structures, objects, or sites) that are in the Project Area and the entirety of Indian Lake State Park. Commonwealth conducted a literature review for the Above-Ground Study Area, which extends 0.5 mi (0.8 km) beyond the Project location, to identify any previously recorded above-ground resources. Review of SHPO survey files revealed that there are no previously recorded above-ground resources in the Above- Ground Study, and that Indian Lake State Park remains unevaluated.

Commonwealth evaluated the south unit of Indian Lake State Park1 as a cultural landscape that includes the two toilet/shower buildings slated for demolition and a third toilet building, which are in a modern campground with 143 tent and trailer campsites and two mini cabins; asphalt-paved parking areas; unpaved foot trails; a boat launch; a picnic area; a large, limestone picnic shelter; a sanitation station; a contact station; and a park headquarters building.

The State of Michigan acquired the land for the south unit of Indian Lake State Park in 1932. At the park’s official dedication on August 9, 1937, P. J. Hoffmaster, Michigan’s first

1 Indian Lake Park is divided into two units: one on the south end of Indian Lake and the other on the west side.

superintendent of state parks, noted that “this particular park land was obtained by the state by trading other lands owned by the state for this property” (Escanaba Daily Press [EDP], 11 August 1937: 10). However, it is not noted if the state traded with federal or private land owners for the property. Workers from the Camp Manistique Civilian Conservation Corps (CCC) began developing the park in 1933. By late June 1937, a large, log-constructed, Rustic style bath house was open to the public (EDP, 25 July 1937: 14). It is also likely that men with the Works Progress Administration (WPA) helped with the park’s development as well, although additional research is needed in this area.

Because of its associations with the CCC and WPA, the south unit of Indian Lake State Park may be eligible for listing in the NRHP under Criterion A for Politics/Government and in the area of Recreation. It may also be eligible under Criterion C for its Rustic-style architecture. Its period of significance would be from 1932 through 1937, which encompasses the state’s acquisition of the land and the initial development of the park using CCC and WPA labor. However, survey of all of the resources in the park is required to determine what remains extant from this period before a recommendation of eligibility for the south unit of Indian Lake State Park can be made.

Despite the campground’s potential eligibility, the two toilet/shower buildings slated for demolition were built in 1952, after the potential period of significance (Figure 4). They have no associations with the CCC or WPA and do not reflect any significant developments in recreation.

They are recommended as non-contributing to any potential historic district that encompasses the entirety of the south unit of Indian Lake State Park. Both buildings are also recommended as not individually eligible for listing in the NRHP under Criteria A or Criteria C for architecture.

Further, both toilet/shower buildings have previously received clearance from SHPO. SHPO concurred with the removal of the both the north toilet/shower building and the central toilet/shower building (ER-98-52.12) on February 22, 2012.

Recommendations

Commonwealth recommends archaeological field investigation of the areas of planned ground disturbance prior to ground disturbing activity. An Application for Permit to Perform Archaeological Exploration on State-Owned Land was submitted February 5, 2021, to the Michigan DNR that encompasses the northern and southern areas of planned ground disturbance.

Additional discussion related to 20ST280 and the results of Commonwealth’s field investigation, expected to occur following spring 2021 ground thaw, will subsequently be reported separately.

Commonwealth also recommends survey of the south unit of Indian Lake State Park as a whole for determining its eligibility for listing in the NRHP. Built using CCC and WPA labor in the mid-1930s, it may be eligible under Criterion A for Politics/Government and in the area of Recreation. It may also be eligible under Criterion C for its Rustic-style architecture. Its period of significance would be from 1932 through 1937, which encompasses the state’s acquisition of the land and the initial development of the park using CCC and WPA labor. Despite the campground’s potential eligibility, the two toilet/shower buildings slated for demolition were built in 1952, after the potential period of significance. They have no associations with the CCC or WPA and do not reflect any significant developments in recreation. Therefore, the toilet/shower buildings slated for demolition are recommended as non-contributing to any potential historic district that encompasses the entirety of the south unit of Indian Lake State Park. Both buildings are also recommended as not individually eligible for listing in the NRHP under Criteria A or Criteria C for architecture. Further, both toilet/shower buildings have previously received clearance from SHPO. On February 22, 2012, SHPO concurred that the removal of the both the north toilet/shower building and the central toilet/shower building (ER- 98-52.12) would have no adverse effects.

Commonwealth is pleased to have been able to assist with your cultural resource review. Please do not hesitate to contact either of us or the Michigan Regional Director, Brandon Gabler (571- 488-5912; bgabler@chg-inc.com) if you have any additional questions or concerns related to this letter or require assistance with future cultural resources projects.

Sincerely, Katie Remensnyder Ethan Epstein, PhD, RPA Architectural Historian Principal Investigator kremensnyder@chg-inc.com ethan.epstein@chg-inc.com P: 517.262.9484 P: 715.482.0273

Freedom of Information Act (FOIA) Notice The location of any archaeological site is considered sensitive information and is protected from release under the Freedom of Information Act (FOIA). Site location data should not be released to the public because the information may create a risk, harm, theft, or destruction of a non-renewable resource. Information on archaeological sites should only be shared with those individuals directly involved with the subject project. Archaeological site information should not be used for future unrelated projects.

References Cited

Escanaba Daily Press (EDP) 1937 “Indian Lake Park Bath House Opened.” 25 July: 14. Escanaba, Michigan.

1937 “Park Dedicated by Hoffmaster.” 11 August: 10. Escanaba, Michigan.

Figures

Figure 1. Project location

Figure 2. Aerial image showing areas of planned ground disturbing activity

Figure 3. Previously recorded archaeological sites within 1.6 m (1.0 mi) of planned ground disturbing activity

Figure 4. Above Ground APE and toilet/shower buildings to be demolished

Figure 5. North toilet/shower building, view to the southeast

Figure 6. Central toilet/shower building, view to the north

Figure 1. Project location

Figure 2. Aerial image showing areas of planned ground disturbing activity

Figure 3. Previously recorded archaeological sites within 1.6 m (1.0 mi) of planned ground disturbing activity

Figure 4. Above Ground APE and toilet/shower buildings to be demolished

Figure 5. North toilet/shower building, view to the southeast

Figure 6. Central toilet/shower building, view to the north

Michigan SHPO Cultural Landscape Identification Form Landscape Overview and Location

Landscape Historic Name (if applicable)

Indian Lake State Park

Current/Common Name (if applicable)

Indian Lake State Park

Boundary Description 8970 County Highway 442; Roughly bounded by County Highway 442 on the south, County Highway 441 on the east, Sandy Shores Campground on the west, and Indian Lake on the north

City, State, Zip Code(s) Manistique, MI, 49854 County Schoolcraft Total Acres in the Landscape 170.5 Parent Cultural Landscape Ownership Private Public-Local Public-State Public-Federal

Landscape Classification and Type

Historic Designed Landscape

Historic Vernacular Landscape

Ethnographic Landscape Historic Site Other

(Insert aerial photo with boundaries below.)

Historic Use Campground & recreation area Current Use Campground & recreation area Landscape Type (Select one or more of the following)

Garden (private) Park (public)

Green/Common/Plaza

Boulevard/Parkway/Trail Other Transportation

Agricultural

Exhibition/Fairgrounds

Mine/Quarry Other Industrial

Campus

Sports/Recreation

Cemetery Commemorative/Memorial

Natural Landform or other Geological Formation:

Other, Please Specify:

National Register Eligibility

Is the landscape listed in the National Register?

Yes No If yes, provide:

Date Listed: NRIS #:

If not already listed, complete the information below:

Eligible Under: Criterion A Criterion B Criterion C Criterion D Criteria Considerations: a. b. c. d. e. f. g.

Not Eligible

Form date: 6/25/2019

Survey Date Recorded By For SHPO Use Only SHPO Concurrence?: Y / N Date:

National Register Eligibility Continued

Area(s) of Significance Politics/Government, Recreation, Architecture

Period(s) Significance 1932–1937

Integrity – Does the landscape possess integrity in all or some of the 7 aspects?

General Integrity: Intact Altered Moved Date(s):

Location Design Materials Workmanship Setting Feeling Association Condition of District? Good Fair Poor Threats to Resource?

Landscape Description

Provide a description of the landscape, including general character of the landscape, specific information regarding the landscape characteristics, and the qualities distinguishing the landscape from its surroundings. This is required for all landscapes.

Natural Features

Topography

Topography in the State Park is relatively flat, with no major topographic features.

Vegetation

The park is forested with red pine, cedar, spruce, hemlock, and northern hardwoods such as aspen and maple.

Water The 8,400-acre Indian Lake forms the northern boundary of the park.

Geology NA

Ecology NA

Climate NA

Designed/Cultural Features

Land use patterns The park has been a State Park since it was opened to the public ca. 1937.

Planting patterns No formal planting patterns appear to be present. Trees may have been planted in the campground to provide privacy between campsites, although these have matured and there is little undergrowth. Native species of wildflowers appear to have recently been planted at the shoreline to help stop erosion.

Boundary demarcations

The boundary is primarily defined by county highways and Indian Lake.

Spatial organization/layout

The park is divided into two areas: a day-use area with picnic grounds and footpaths on the western side of the park, and a modern campground on the east side. The headquarters area is near the park entrance and County Highway 442, whereas the buildings for public use are near the lakeshore.

Circulation Networks The park is accessed by a two-way road that extends north and east from County Highway

442. Past a checking station, the road splits in two. One branch leads north and west to the day-use area and boat launch, and the other heads east to the campground. In the campground, the road forms four loops that generally follow the curve of the lakeshore.

Views and vistas Public use areas, including the picnic grounds, picnic shelter, and campground are clustered near the shore of Indian Lake. However, large trees between these areas and the lake somewhat obstruct any large, sweeping view of the lake.

Water features Constructed water features include a drain field/lagoon near County Highway 442 that is surrounded by heavy tree cover.

Buildings, structures, and objects*

A cluster of three headquarters buildings are near the entrance to the park. A checking station stands next to the road near the entrance to the campground and day-use area

Small-scale elements (markers, statuary, site furnishings)

Small-scale features include picnic tables, fire pits, signs, curb stops, playground equipment, and fencing.

Other (including ephemeral qualities – sounds, activities, wildlife, smells, etc.)

*list and briefly describe each and attach an Architectural Resource Inventory Form for each major resource

History of the Cultural Landscape

Provide a general history that includes the people, trends, and time periods that shaped the landscape over time. This could include information on previous owners, land use, construction and alteration dates in a narrative format. This is required for all intensive level surveys and recommended for other identification efforts.

The State of Michigan acquired the land for the south unit of Indian Lake State Park in 1932. At the park’s official dedication on August 9, 1937, P. J. Hoffmaster, Michigan’s first superintendent of state parks, noted that “this particular park land was obtained by the state by trading other lands owned by the state for this property” (Escanaba Daily Press [EDP], 11 August 1937: 10). However, it is not noted if the state traded with federal or private land owners for the property. Workers from the Camp Manistique Civilian Conservation Corps (CCC) began developing the park in 1933. By late June 1937, a large, log-constructed, Rustic style bath house was open to the public (EDP, 25 July 1937: 14).