Thanks to all the people who replied to my inquiry with suggestions, on and off both HISTARCH and SUB-ARCH

I appreciate all your help. I am working to assemble a full summary of comments for the lists.

In the interim, I attach a link to a recent news article that explains this cluster of projects. Since there are some potential market-based reasons while companies would like to dredge these old stamp sands, there are both pull and push forces at play here beyond the immediate and urgent need to protect this very important reef in the ecological system of south-central Lake Superior. There are no fewer than five separate dredging permits in various stages of the process, including both the south and north shores of the Keweenaw Peninsula, where companies hope to extract the old mine waste so they can sell the copper-rich basalt sands for industrial applications in manufacturing. This article discusses four of the projects that focus on one major stamp sand deposit. Another is just starting in the permit pipeline for the North shore that includes a large swath of the coast. Because of the scope of these projects, I am trying to sound the alarm about the sensitivity of cultural resources in the coastal waters of the Keweenaw.
http://keweenawnow.blogspot.com/2017/11/dnr-stamp-sand-dredging-buys-time-epa.html <http://keweenawnow.blogspot.com/2017/11/dnr-stamp-sand-dredging-buys-time-epa.html>

Even through I left out most detail in my request, the basic opinion among all the commenters was that good dredge operators can do precision work when several conditions are present:
1. A skilled operator who cares about the motivation behind the precision, using a “snorkel” type hydraulic dredge.
2. Detailed maps of the contour of the current surface vs. the historic surface of the lake bottom so the dredge can be set properly.
3. A lake bottom that generally has consistent and even contours. When surfaces are very uneven, it becomes impossible to do precision work.

In this case, I cannot answer these questions because I do not know if the core samples were taken to generate such maps and I think that the old lake bottom varies in it’s composition from smooth sand in areas to exposed bedrock and to areas of glacial boulder/cobble bottom that is jumbled with varied sizes and shapes of rock.

Many also agreed with Bob Nyland’s comment that the concern is not just for damage caused by the initial dredging, but also that newly exposed sloped surfaces can often be destabilized and thus prone to slumping, which is also a risk to sites above, on, and below steeper contours. 

Many people suggested that survey made sense before the survey, but some also said that monitoring the dredging itself would be sufficient (when many of the above conditions are met to allow quality work). Most explained that documentation and mapping during or after the dredging should be expected, when the paleo-surfaces are exposed.

I reported on the spirit of these comments to the agency staff with whom I’ve been able to meet.

Resources suggested included: 
https://www.boem.gov/BOEM-Newsroom/Library/Publications/2004/2004-005.aspx <https://www.boem.gov/BOEM-Newsroom/Library/Publications/2004/2004-005.aspx>
“ARCHAEOLOGICAL DAMAGE FROM OFFSHORE DREDGING: RECOMMENDATIONS FOR PRE-OPERATIONAL SURVEYS AND MITIGATION DURING DREDGING TO AVOID ADVERSE IMPACTS” (Prepared for the Mineral Management Service)

I also passed along this booklet that I thought would be helpful in a general sense. In 2013, the Council on Environmental Quality, the Executive Office of the President, and the Advisory Council on Historic Preservation published this handbook to harmonize and integrate the processes defined in law by the National Historic Preservation Act of 1966 (NHPA) (P.L. 89-665; 80 Stat. 915; 16 U.S.C. 470) and the National Environmental Policy Act of 1969 (NEPA) (P.L. 91-190; 83 Stat. 852; 42 U.S.C. 4321).
http://www.achp.gov/docs/NEPA_NHPA_Section_106_Handbook_Mar2013.pdf <http://www.achp.gov/docs/NEPA_NHPA_Section_106_Handbook_Mar2013.pdf>


For those who don’t know about current research in Great Lakes maritime archaeology, I can quickly explain my concerns:
1. Most of these areas have not been inventoried or surveyed for either terrestrial or maritime resources. The Keweenaw is largely private land in rural setting, mostly forest reserve, so few surveys are mandated under Section 106. 

2. Cultural resources compliance has been an afterthought on all stamp sand remediation projects and this has been an ongoing problem that started with inland deposits in river systems. Now the problem is extended into the Lake Superior bottom lands and the same pattern has been repeated. 

3. There have been several recent discoveries about ancient land uses in recent years (hunting blinds in Lake Michigan, isolated point finds in Superior) that point to the critical importance of lake bottom sites in understanding antiquity. At the same time, ancient copper collectors have been legally picking ancient terrestrial sites on private land to the point of seriously compromising the resources. Precious few of these sites are protected on Federal, State, or other trust-type lands.

So in summary, we don’t really know what we don’t know while we continue to be put in positions where we are forced to comment on permitting plans after they are issued or during public comment periods. I would prefer to see Phase I assessments completed by professionals and reports presented to the public before asking for public comment.

Thanks for all the help,
Best regards,
Tim Scarlett










> On Nov 30, 2017, at 7:36 AM, John Mark Joseph <[log in to unmask]> wrote:
> 
> Tim,
> 
> What’s the depth of the deposits to be removed?
> 
> John Mark Joseph 
> 
> Sent from my iPhone
> 
>> On Nov 30, 2017, at 7:54 AM, ROBERT Neyland <[log in to unmask]> wrote:
>> 
>> Hello Tim. I would agree with you that a survey would be in order. The overlaying intrusive sands may have intermingled with cultural material laying on or above the bottom. I don’t know the specifics of the site but would think that the original lake floor would have some erosion and possible exposure of cultural material that could be then intermingled with the intrusive sand. I would also question if the original lake floor depth is consistent. IF they are a dredging to a prescribed depth that depth might not be consistent.
>> 
>> 
>> 
>> At the Navy we advise the USACE to survey areas that have been previously dredged because the previous dredging might not have completed removed any wrecks, especially if they are iron. Another consideration is if they are deepening a channel, cultural material on the slopes of the channel may be impacted and slide into the channel.
>> 
>> 
>> 
>> I am traveling at present and will not be back in US until next week but if you would like to discuss in more detail. I also copied two of our Underwater Archaeologists on this email. I am sure they would be glad to consider the problem.
>> 
>> 
>> 
>> Bob
>> 
>> 
>> 
>> Sent from Mail<https://go.microsoft.com/fwlink/?LinkId=550986> for Windows 10
>> 
>> 
>> 
>> ________________________________
>> From: HISTORICAL ARCHAEOLOGY <[log in to unmask]> on behalf of Timothy Scarlett <[log in to unmask]>
>> Sent: Wednesday, November 29, 2017 4:40:48 PM
>> To: [log in to unmask]
>> Subject: hydraulic dredge effects
>> 
>> Hi all,
>> 
>> I had a conversation today with group of resource managers engaged in permitting a series of proposed dredging projects to remove massive mine tailings deposits on the beach and underwater in a great lake.
>> 
>> I was given the impression by these officials that crews working hydraulic dredges can remove the stamp sand without removing any of the underlying natural sand or sediment, which lead that manager to conclude that “no adverse effect” was a reasonable determination without requiring any survey. I find that conclusion hard to believe, but I am a terrestrial archaeologist with no expertise in this topic. It seems to me that the permitting process by the state DEQ and USACE should have at least required a survey and consideration of cultural resources.
>> 
>> I may be mistaken about general practice in maritime compliance practices.
>> 
>> The sands to be removed are secondary eroded deposits moved by the longshore current and they overlay natural sands and gravels that have never been dredged before (i.e. not in a shipping channel).
>> 
>> Can anyone comment on this? I would appreciate any advice on publications, technical reports, and agency guidelines that specifically examine or guide decisions regarding hydraulic and other dredge processes.
>> 
>> I have been reading USACE reports found through Google Scholar and books, but the vast majority of these are decisions of no adverse effect because the APE has been periodically dredged in the past, and the proposed project in maintenance dredging. I hope my colleagues can help me sift through this more quickly.
>> 
>> Thanks for any advice- please reply off or on list, as you wish.
>> 
>> Thanks,
>> Tim Scarlett
>> Michigan Technological University
>> Houghton, Michigan
>> 
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