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January 28, 2015
S. Alan Skinner
805 Business Parkway
Richardson, Texas 75081
Re: Project review under the Antiquities Code of Texas
Draft Report: Archeological Evaluation - Freeport Parkway, City of Coppell, Dallas County
(City of Coppell)
Dear Dr. Skinner:
Thank you for providing the evaluation referenced above. This letter serves as comment on the project
from the State Historic Preservation Officer, the Executive Director of the Texas Historical Commission.
As the state agency responsible for administering the Antiquities Code of Texas, these comments also
provide recommendations on compliance with state antiquities laws and regulations.
The review staff, led by Rebecca Shelton, has completed its review. Since the majority of the roadway
construction had taken place before archeological investigations could commence, the City of Coppell
has foreclosed our opportunity to comment under the Antiquities Code (Texas Natural Resource Code,
Title 9, Chapter 191). If there is any federal connection to this project, such as a Corps of Engineers
permit, then the City of Coppell could be liable for Anticipatory Demolition by beginning construction
before allowing us or the Advisory Council on Historic Preservation to comment, as discussed in
36CFR800.9(b).
It appears from the photographs and the description in the evaluation that a reconnaissance survey was
conducted of the proposed project areas. Because the City of Coppell is a political subdivision of the State
of Texas, an Antiquities permit should have been issued by this office prior to initiation of the
reconnaissance survey.
Unfortunately, we have no choice but to register this situation as a "permit application offense." All
principal investigators are allowed one permit application offense per year. However, if another permit
application offense occurs within the year (through January 2016) you may be ineligible to be issued a
permit for that work. Additional offenses could result in censure by the Antiquities Advisory Board,
which would prevent us from issuing any permits to you for a period of six months.
Thank you for your assistance in this matter. If you have any questions, please contact Rebecc
Shelton of our staff at 512.463.6043 or Rebecca.Shelton@,thc.state.tx.us.
Sincerely,
for
Mark Wolfe, State Historic Preservation Officer
MW/rls
AR Consultants, Inc.
Archaeological and Environmental Consulting
80,', Pmris—y, R111611r1s n,'��`exas 75D11
P61"! (211) S68-0178
F'm 1?11) 2121-11519
February 5, 2015
Rebecca Shelton, Archaeologist
Texas Historical Commission
PO Box 12276
Austin, TX 78711
Dear Ms. Shelton:
Thank you for your review of our December 18, 2014 letter reporting the conditions on the
Freeport Parkway project in Coppell. As per our letter, we were only reporting the land
disturbance and construction conditions on this project. I do not know what role the Corps of
Engineers has had with this project. As indicated in the first paragraph of my letter, the City had
already violated the Texas Antiquities Code by beginning construction without clearance.
However, recognizing the error of their ways, their engineers asked ARC to assess the potential
of there having been significant resources in the roadway corridor. I assumed that there might be
the potential of doing a survey before additional construction continued or possibly in the
unconstructed areas, so I decided to go out and see just what the conditions were.
In 1999, we had surveyed the proposed site for Wagon Wheel Park and of course we reviewed
site records. Based on Coppell's history and information provided by Paul Lorrain, I had
expected that historic residences might be present in the park site. I hoped that if Cottonwood
Branch was spring -fed that prehistoric sites might also be present. I took all this information
along with a drive down State Street into consideration when I wrote the 1999 proposal to do the
survey. Despite good exposure in much of the area, we found nothing worth recording during the
1999 survey. This is discussed in a little more detail in the second paragraph of our evaluation
letter.
In the process of evaluating the amount of work already done and in order to be able to provide
you a visual depiction for review, Kandi Doming and I drove up and down the road, she
photographing while I drove. We never got out of our vehicle and this is the kind of scouting that
I like to do before determining what to recommend on a project before bidding it. I imagine that
architectural historians scout project areas before they bid on a job. As it started out, I thought
that this situation would provide us an opportunity to survey another section of Cottonwood
Branch. When we got out there, it appeared to me that a survey would probably not be
recommended by you or me. Knowing the guidelines for the need to secure an Antiquities Permit
to do a reconnaissance survey, I realized that we could drive down the road without violating the
permit guidelines. We were providing information that I felt you would want in order to advise
the city that they had overstepped the bounds of the Antiquities Code. This is even mentioned in
HISTORIC BUILDINGS ARCHAEOLOGY NATURAL SCIENCES
the last sentence of our letter. Our evaluation reviewed the results of records checks, of aerial
photograph and map review, and drive-by pictures but in no way can our evaluation letter be
considered the result of a reconnaissance survey. I request that you recognize what we did as a
planning document evaluation and not a survey, and that it should not be considered a "permit
application offense."
Thank you for reviewing our evaluation document which concluded that the Freeport Parkway
construction had a low archaeological potential even before construction began.
Sincerely,
S. Alan Skinner, PhD
President
cc. Chris Schmitt, PE, teague nall & perkins
HISTORIC BUILDINGS LDINGS ARCD AAO LOGY NATURAL SCIENCES