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ST9401-SY 971120TEXAS HISTORICAL COMMiSSiON Gem o~ W. Bush ° Governor John L. Nau, III ° Chairman Curtis Tunnell ° Executive Director . The State Agency for Historic Preservation November 20, 1997 Mr. Larry Banks Banks Archeological Research Associates 4909 Weyland Drive Hurst, TX 76053 Re: Request for additional information on Denton Tap Road investigations (City of Coppell, T2, T10, TAC # 1890) Dear Mr. Banks: We are in receipt of 20 copies of the report entitled Cultural Resources Investigation Denton Tap Road ST 94-01 Dallas County, Texas. However, we are unable to accept this report for a the reasons specified in the attached comments. Please address our comments and submit a single draft report for review. We will continue our review of this project upon receipt of the requested information. If you have any questions, please contact Mr. Bill Martin of my staff at 512/463-5867. Sincerely, James E. Bruseth, Ph.D. ~'~Deputy State Historic Preservation Officer JEB/wam cc: Mr. Ken Griffin, P.E., Director of Engineering & Public Works, City of Coppell P.O. Box 12276 · Austin, TX 78711-2276 ° 512/463-6100 ° Fax 512/475-4872 ° TDD 1-800-735-2989 Comments on Cultural Resources Investigation Denton Tap Road ST 94-01 Dallas County, Texas by Banks Archeological Research Associates General Comments This report has two basic deficiencies that make it unacceptable in its current form. First and foremost, the report incorrectly states that the primary purpose of this investigation was to assess effects on site 41DL252 m this office is equally concerned about the status of site 41DL296, which is recorded along the northwestern edge of the proposed bridge replacement (based on maps supplied with the permit application for permit 1890). We specifically stated that both sites should be evaluated in our letter to Mr. Ulys Lane HI of Wier & Associates, Inc., dated July 17, 1997. It does not appear that any effort was made to examine the portion of the project area that may affect site 41DL296. The second major deficiency is that this report does not follow the format specified in the Council of Texas Archeologists (CTA) Guidelines for Cultural Resource Management Reports. The lack of a map showing the project area and the location of the backhoe trench is especially troublesome. We need this type of information in order to maintain our database of areas that have been professionally surveyed in Texas. For your information, the CTA Guidelines for intensive survey reports call for the following headings: Abstract Management Summary Introduction Environmental Background Research Design Previous Investigations and Archeological Background A detailed history of cultural resource investigation in the region incorporating the study area should be provided. The archeological and historical problems that have been of interest to previous investigators in the region, and their successes and failures in addressing those problems, should be reviewed. A detailed discussion of the research problems in need of further study should be made, and it should be briefly noted whether the research design of the present study has addressed any of those issues. The elements of site-specific information listed in the reconnaissance report outline should be provided for every archeological site and architectural feature recorded by the survey. Again, the format of presentation is largely an editorial decision, but the minimum unit of information provenience must be the individual site at the survey level of reporting. It is highly desirable to include any sites and structures previously recorded in the study area, so that a complete inventory of all known cultural features will be provided. Artifact Descriptions_ Synthesis, Evaluation, and Interpretation of Cultural Resources The cultural resource data should be synthesized and analyzed in pursuit of the problems addressed by the research design. The significance of the recorded sites and structures should be evaluated. Any factors that were beyond the control of the archeologist, historian, architect, or any other involved professional, and that may have caused cultural resources to pass unrecorded or to have been incorrectly assessed should be discussed. Recommendations At this stage, both cultural resource management and research recommendations should be quite specific. Sites and structures should be earmarked for avoidance or protection, mitigative investigation, or further assessment through testing and research, as appropriate and possible on the basis of the available information. Research problems to be pursued during testing and mitigation should be stated and ranked in importance. The manner in which each problem can best be addressed should be briefly summarized to provide a core for subsequent research designs. It is perhaps more important at this stage of the resource management process than at any other that all recommendations be well reasoned and convincingly justified. Any quantification of estimates into labor and costs should be avoided since it is felt that such estimates may lead to errors which could adversely affect the resource. Focus should be placed on the recommendations for the resource and a very careful and detailed description of the recommended work. Glossary References Cited Specific Comments First sentence: A key word is missing: ... expanding the width of Denton Tap Road bridge across Denton Creek. Area of Potential Effect: According to the map and project plans supplied with the Antiquities Permit application, this project encompasses both sides of Denton Creek. According to our maps, site 41DL296 lies within the area of potential effect and needs to be evaluated. Authorizing Legislation: The work was performed to comply with the Antiquities Code of Texas -- not federal legislation. Also, "Texas Department of Antiquities" shotrid read, "Division of Antiquities Protection, Texas Historical Commission." Environment: There is no environmental information included in this section. The discussion presented under this heading belongs under "Previous Investigations and Archeological Background." The discussion of the archeological background is incomplete because it omits an important work by Yates and Ferring -- a study which actually included a profile description taken along the bank of Denton Creek at site 41DL252. The authors should include a discussion of the 1986 study. See: Yates, Boxrole C. and C. Reid Ferring, Editors 1986 An Assessment of the Cultural Resources In The Trinity River Basin, Dallas and Tarrant Counties, Texas. Institute of Applied Sciences, North Texas State University. Final report submitted to the US Army Corps of Engineers, Fort Worth District. File Search: This section should include the information currently included under the heading of "Environment," as noted above. The revised "Previous Investigations and Archeological Background" section should include better, more complete, information. For example, the authors state that two sites were noted near the project area, but only discuss one. They do not present any information that would allow the reader to figure out what these sites are like. How large are they? Are they deeply stratified? How old are they? What was found on these sites? Methods of Investigation: Please explain why one backhoe trench is considered sufficient documentation to ensure that the entire project area is unlikely to affect historic properties? What about effects on the north side of the bridge at 41DL2967 Results: The authors indicate that 9 ft. of floodplain deposit was removed and replaced with fill at the time the initial bridge was constructed. The City Engineer's records probably indicate how the original bridge was constructed and the amount of fill introduced during construction. We recommend that those records be examined to support the conclusion that the natural soil was removed and replaced with fill to this depth. If, indeed, everything within the area of potential effect for this bridge replacement can be demonstrated to have been destroyed at the time of initial bridge construction, then no additional field work will be necessary. If not, the authors should return to the project area and conduct further investigations before construction begins, focusing particularly on site 41DL296.