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Technical Memorandum: Wabash and Erie Canal Comments on the FEIS 1 Technical Memorandum: Wabash and Erie Canal March 19, 2004 Comments on the Tier 1 Final Environmental Impact Statement (FEIS) for the I-69 Evansville to Indianapolis project raised questions regarding the historic status of a segment of the former Wabash and Erie Canal in the Patoka Bottoms area. This technical memorandum has been prepared in response to that comment and evaluates potential impacts to the canal remnants at all locations where Alternative 3C would cross the route of the canal. It has been prepared with the assistance of Weintraut & Associates, who have served as the project historians for FHWA and INDOT during this study. I. Wabash and Erie Canal – History and Current Status In 1827 Congress allotted a land grant to Indiana for the purpose of building a canal to link the Great Lakes with the Ohio River. In Indiana, construction of the Wabash and Erie Canal began in 1832 at Fort Wayne, Indiana. The final section was completed in Indiana in 1853. It operated for seven years and in 1860, the Terre Haute to Evansville portion of the Canal closed, with the exception of some point-to-point operations between towns. The owners of the canal officially ended operations in 1874. There are some scattered physical remains of the defunct canal system still visible in Southwest Indiana. These include abutments for aqueducts, remains of locks, dilapidated sections of canal earthworks, and evidence of water control structures, such as waste gates and guard locks. In general, however, little surface evidence remains of the Wabash and Erie Canal. The route of the canal in Southwest Indiana is shown in Figure 1. II. Eligibility Evaluation for Wabash and Erie Canal The eligibility of a former canal for the National Register of Historic Places generally is based on the characteristics of a particular section, rather than treating the entire length of the former canal as a single entity that is eligible or ineligible for the National Register. Individual canal segments may be determined eligible for the National Register based on the presence of historic (above-ground) and/or archeological (below-ground) resources. In order to be considered eligible based on above-ground resources, a canal segment generally must retain some extant building or structure the presence of a visible profile (i.e., earthworks) alone generally is not sufficient by itself to support a finding of eligibility as a historic (above-ground) resource. In the absence of extant above-ground structures, a canal segment may be found eligible based on the presence of below-ground archeological resources; these canal properties usually require intact cultural deposits, such as feeder canals, deposits of artifacts, wharfs, bridges, aqueducts, culverts, or locks.

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Page 1: Technical Memorandum: Wabash and Erie Canal › indot › projects › files › I69 › Tier1 › ROD › Appendi… · Technical Memorandum: Wabash and Erie Canal Comments on the

Technical Memorandum: Wabash and Erie Canal Comments on the FEIS

1

Technical Memorandum: Wabash and Erie Canal March 19, 2004 Comments on the Tier 1 Final Environmental Impact Statement (FEIS) for the I-69 Evansville to Indianapolis project raised questions regarding the historic status of a segment of the former Wabash and Erie Canal in the Patoka Bottoms area. This technical memorandum has been prepared in response to that comment and evaluates potential impacts to the canal remnants at all locations where Alternative 3C would cross the route of the canal. It has been prepared with the assistance of Weintraut & Associates, who have served as the project historians for FHWA and INDOT during this study. I. Wabash and Erie Canal – History and Current Status In 1827 Congress allotted a land grant to Indiana for the purpose of building a canal to link the Great Lakes with the Ohio River. In Indiana, construction of the Wabash and Erie Canal began in 1832 at Fort Wayne, Indiana. The final section was completed in Indiana in 1853. It operated for seven years and in 1860, the Terre Haute to Evansville portion of the Canal closed, with the exception of some point-to-point operations between towns. The owners of the canal officially ended operations in 1874. There are some scattered physical remains of the defunct canal system still visible in Southwest Indiana. These include abutments for aqueducts, remains of locks, dilapidated sections of canal earthworks, and evidence of water control structures, such as waste gates and guard locks. In general, however, little surface evidence remains of the Wabash and Erie Canal. The route of the canal in Southwest Indiana is shown in Figure 1. II. Eligibility Evaluation for Wabash and Erie Canal The eligibility of a former canal for the National Register of Historic Places generally is based on the characteristics of a particular section, rather than treating the entire length of the former canal as a single entity that is eligible or ineligible for the National Register. Individual canal segments may be determined eligible for the National Register based on the presence of historic (above-ground) and/or archeological (below-ground) resources. In order to be considered eligible based on above-ground resources, a canal segment generally must retain some extant building or structure the presence of a visible profile (i.e., earthworks) alone generally is not sufficient by itself to support a finding of eligibility as a historic (above-ground) resource. In the absence of extant above-ground structures, a canal segment may be found eligible based on the presence of below-ground archeological resources; these canal properties usually require intact cultural deposits, such as feeder canals, deposits of artifacts, wharfs, bridges, aqueducts, culverts, or locks.

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Technical Memorandum: Wabash and Erie Canal Comments on the FEIS

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In keeping with this overall approach, sections of the Wabash and Erie Canal encountered during the research for this study were treated as potential archaeological resources, because of the absence of extant above-ground elements. One of the commenters on the FEIS, Edith Sarra, questioned this finding, with regard to the section of the Wabash and Erie Canal in the Patoka Bottoms area. Ms. Sarra’s objections were based in part on the wording of a letter from Mr. Frank Hurdis of the Indiana Department of Natural Resources, Division of Historic Preservation and Archaeology (DHPA), dated August 27, 2003. Her objections also were based in part on documentation she had submitted to the DHPA as part of her effort to nominate a cluster of properties in the Patoka area (including a segment of the Wabash and Erie Canal) for listing in the National Register. In response to the FEIS comment received from Ms. Sarra, FHWA and INDOT undertook further coordination with the Indiana DHPA, which serves as the Indiana State Historic Preservation Officer (SHPO) for purposes of Section 106 consultation under the National Historic Preservation Act. In a letter dated February 20, 2004, Mr. Hurdis of the DHPA/SHPO staff confirmed that the Wabash and Erie Canal section in the Patoka Bottoms area should be viewed as a potential archaeological rather than historical resource, due to the lack of extant above-ground resources. In addition, FHWA and INDOT have examined other locations in Southwest Indiana (outside the Patoka area) at which Alternative 3C crosses or approaches the route of the former Wabash and Erie Canal. In each of these locations, the conditions are similar to those found at the Patoka area. Therefore, FHWA and INDOT find nothing to support the eligibility of those other segments as historic (above-ground resources), but acknowledge that those segments may contain archeological (below-ground) resources that are eligible for the National Register. For more information on all of the points where Alternative 3C crosses the route of the former canal, see Section III of this memorandum. Additional information regarding coordination with SHPO concerning the historic properties associated with Patoka Bottoms is contained in the project file as a technical memorandum dated March 19, 2003 entitled, SHPO Coordination – Wabash and Erie Canal in Patoka Bottoms.. III. Location of Alternative 3C in Relation to Wabash and Erie Canal The route of the former Wabash & Erie Canal approaches or intersects with the corridor for Alternative 3C in several locations. This section of the memorandum describes the current conditions of the former canal at each of those locations. For a general depiction of the former canal’s route in relation to Alternative 3C, see Figure 1.

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Technical Memorandum: Wabash and Erie Canal Comments on the FEIS

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A. Daviess County In Daviess County, the route of the former Wabash and Erie Canal approaches, but does not intersect with, the corridor for Alternative 3C in two locations – one in the northern part of the county near Elnora and one at the Pike/ Daviess County Line. See Figure 1. Therefore, an alignment developed within the corridor for Alternative 3C would have no impact on the route of the former canal in Daviess County. B. Pike County Crossing near Private Coal Road: At the crossing at the intersection of SR 57 and Private Coal Road in Pike County (see Figure 2), it appears that the profile of the canal has been filled in to construct the roadway; the profile disappears at this point. There are no buildings, structures, or objects visible from public roadway. (See inset photo, showing where Alternative 3C intersects with the path of the former canal.) C. Gibson County Description of the canal at the crossing near Dongola: The crossing of the canal near Dongola (see Figure 3) is located in a field that is presently being cultivated; no profile was visible from CR 150. No buildings, structures, or objects associated with the canal were visible from CR 150. Nearby the profile of the canal is evident, but as noted previously, profiles alone are generally not eligible for listing in the National Register. (See inset photo, showing the view from CR 150 to the location where the corridor of Alternative 3C crosses the canal). Crossing near CR 900 and CR 550: The crossing near the intersection of CR 900 and CR 550 (see Figure 4) has no profile to indicate the presence of the canal at all. From the roadway, it was not possible to distinguish the path of the canal through the cultivated field; there are no buildings, structures, or objects to indicate its presence. However, in a wetland located to the southeast of the intersection of the path of the canal and the corridor of Alternative 3C where the canal turns southeast, the profile and the towpath are visible. (See inset photo, showing the open field where the route of Alternative 3C crosses the former path of the canal.) IV. Section 4(f) Evaluation Based on the information summarized above, the following Section 4(f) evaluation has been prepared for the former Wabash and Erie Canal. It documents the basis for finding that the crossing of this former canal by Alternative 3C does not require a Section 4(f) approval.

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Technical Memorandum: Wabash and Erie Canal Comments on the FEIS

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Description: The Wabash and Erie Canal as a whole is not eligible for the National Register of Historic Places; individual sections may be eligible based on the presence of above-ground or below-ground (archaeological) resources. The canal sections within the area of potential effects for Alternative 3C lack extant above-ground structures and thus are not considered to be eligible for the National Register as historic resources. It is possible that these canal sections may contain below-ground archaeological resources that are eligible for the National Register. Direct Use: Alternative 3C crosses the route of the former Wabash and Erie Canal at three points. At each point, there are no extant above-ground structures, but below-ground archaeological resources may be present. Therefore, these canal sections are considered potentially eligible for the National Register as archaeological resources. However, crossing an archaeological site does not necessarily result in the “use” of a Section 4(f) resource; a “use” is only found if the archaeological site is valued “for preservation in place.”. See 23 C.F.R. § 771.135(g)(2). It is relatively rare for archaeological sites to be determined valuable for preservation in place. Therefore, it is anticipated that the crossings of the Wabash and Erie Canal will not result in the “use” of a Section 4(f) resource. Constructive Use: Proximity impacts (noise, visual, and atmospheric) would not have any effect on the protected features, activities, or attributes of an archaeological resource. Therefore, proximity of Alternative 3C would not result in a constructive use of the Wabash and Erie Canal sections, even if those sections are found to be eligible for the National Register. Avoidance Alternatives: In the unlikely event that a canal section crossed by Alternative 3C is found to be eligible as an archaeological resource that is valuable for preservation in place, it would be necessary to consider avoidance alternatives. These alternatives could involve shifting the alignment to avoid the section that contains the protected archaeological resources. The same analysis would be needed in the unlikely event that a portion of the canal was found eligible for the National Register based on above-ground structures as a historic resource. Minimization of Harm: In the unlikely event that Alternative 3C is found to “use” a section of the canal that is eligible for the National Register, and there is no prudent and feasible avoidance alternative, measures to minimize harm to that resource will be considered. Such measures may include alignment shifts, design changes, or conservation and preservation of the resource. Potential eligibility of, and impacts to, the Wabash and Erie Canal will be evaluated further in Tier 2.

Page 5: Technical Memorandum: Wabash and Erie Canal › indot › projects › files › I69 › Tier1 › ROD › Appendi… · Technical Memorandum: Wabash and Erie Canal Comments on the

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Page 9: Technical Memorandum: Wabash and Erie Canal › indot › projects › files › I69 › Tier1 › ROD › Appendi… · Technical Memorandum: Wabash and Erie Canal Comments on the

Technical Memorandum: Wapehani Mountain Bike Park Comments on the FEIS

1

Technical Memorandum: Wapehani Mountain Bike Park March 11, 2004 Based upon comments received on the I-69 Evansville to Indianapolis, Indiana Tier 1 Final Environmental Impact Statement, a Section 4(f) evaluation was conducted on the Wapehani Mountain Bike Park. Figure 1 shows the Wapehani Mountain Bike Park in relation to the I-69 alternatives. Wapehani Mountain Bike Park Description: The City of Bloomington Parks and Recreation Department is responsible for the Wapehani Mountain Bike Park. This 43 acre park is located in southwestern Bloomington and borders the right-of-way of SR 37 just south of the interchange with SR 45. Since this resource is a publicly owned park, the resource is protected under Section 4(f) of the Department of Transportation Act of 1966. Direct Use: As currently planned, Alternative 3C would remain within the existing right-of-way in this area. No right-of-way would be acquired from this park. With no right-of-way needed, there is no direct use of this Section 4(f) resource. Constructive Use: The working alignments of Alternatives 3C, 5A, and 5B will be located on existing SR 37 which is adjacent to the Wapehani Mountain Bike Park. The park was established in 1990, at a time when SR 37 was already a major multi-lane highway. Therefore, the proximity impacts associated with a highway (noise and visual) were accepted at the time the park was established. Given that the park exists presently next to the SR 37 facility, it appears that there would be no substantial impairment of the protected features, activities, or attributes of this park by Alternatives 3C, 5A, and 5B. Avoidance Alternatives: The working alignment of Alternative 3C avoids the use of the Wapehani Mountain Bike Park. If necessary, the alignment could be shifted to the west and further away from the park. Measures to Minimize Harm: If required for this resource, measures to minimize harm could include vegetative screening, design modifications, and other appropriate techniques to minimize impacts. Potential impacts to the Wapehani Mountain Bike Park will be evaluated further in Tier 2.

Page 10: Technical Memorandum: Wabash and Erie Canal › indot › projects › files › I69 › Tier1 › ROD › Appendi… · Technical Memorandum: Wabash and Erie Canal Comments on the

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Page 11: Technical Memorandum: Wabash and Erie Canal › indot › projects › files › I69 › Tier1 › ROD › Appendi… · Technical Memorandum: Wabash and Erie Canal Comments on the

Technical Memorandum: Trail for the Monon Rail Preservation Corporation Comments on the FEIS

1

Technical Memorandum: Railroad owned by the Monon Rail Preservation Corporation March 2004 Based upon comments received on the I-69 Evansville to Indianapolis, Indiana Tier 1 Final Environmental Impact Statement, a Section 4(f) evaluation was conducted on a section of railroad owned by the Monon Rail Preservation Corporation. Figure 1 shows this railroad in relation to Alternative 3C, which follows existing State Road 37 alignment in this area. Railroad owned by the Monon Rail Preservation Corporation Description: The Monon Rail Preservation Corporation owns a section of the old CSX railroad in Monroe County. This section begins at Hunter Switch just east of Curry Pike and continues northwest approximately 4 – 5 miles ending at SR 46 in Ellettsville, Indiana. The tracks on this section are maintained by the Indiana Rail Road Company and the tracks are on occasion used by a train. Section 4(f) does not apply to this corridor because (1) this section of the old CSX railroad is still functioning as a railroad corridor, and thus cannot be considered a recreational area, and (2) even assuming that a railroad in active use could be considered a recreational resource, Section 4(f) would not apply to this section of the railroad because Section 4(f) applies to recreational areas only if they are publicly owned, and this section of the railroad is owned by a private entity, the Monon Rail Preservation Corporation. Additional Information: As stated above, the section of railroad owned by Monon Rail Preservation Corporation (shown in green in Figure 1) is not a Section 4(f) resource. Therefore, it is unnecessary to consider the potential for a use. However, it should be noted that: • None of the alternatives under consideration directly cross the section owned by the Monon

Rail Preservation Corporation, which is shown in green in Figure 1. The alternatives located closest to that section of the railroad are located on SR 37, approximately 0.5 miles to the east of the section owned by Monon Rail Preservation Corporation. At this point, where SR 37 crosses over the railroad, the railroad is currently an active CSX railroad line that is regularly used by freight trains.

• The CSX railroad currently passes under SR 37, a major highway. Even if this section of the

railroad were to be transferred to Monon Rail Preservation Corporation and converted to a trail, the alternatives that involve upgrading SR 37 to an Interstate would not result in a use of that resource, as long as the continuity of the trail were preserved.

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