RE: End of Field Letter for the Proposed Milton Mears Farm Road Solar Project, Milton, Chittenden County, Vermont

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October 10, 2017 Kirk Shields Green Mountain Power 163 Acorn Lane Colchester, VT 05446 RE: End of Field Letter for the Proposed Milton Mears Farm Road Solar Project, Milton, Chittenden County, Vermont Dear Kirk: The University of Vermont Consulting Archaeology Program (UVM CAP) conducted an archaeological Phase I site identification on October 5 th and 6 th, 2017, within the Area of Potential Effects (APE) of the proposed Milton Mears Farm Road Solar project located in Milton, Chittenden County, Vermont (Figures 1 and 2). Green Mountain Power (GMP) proposes to construct a 4.99 MW-AC fixed-tilt solar array with a Tesla Powerpack battery storage system that will include 18,465 solar modules on 4,614 framed on a 28.7 +/- acre parcel to the west of Mears Road in Milton, Chittenden County, Vermont (Figure 3). In addition, the perimeter of the solar array will be fenced. The proposed facility will be connected to Mears Road via a 420 m (1,377 ft) long access road that is currently used as a field access road. The Phase I site identification survey was predicated upon the results of a UVM CAP Desk Review of the proposed project and was undertaken as part of the Vermont Act 248 permit process. Phase I Field Methods and Results Specifically, the proposed project s APE, where the solar array and fence are to be emplaced, consists of varying topographical features that include broad gullies along its south, southeast, west and northwest sides; these gullies culminate in heads-of-gullies that extend into the interior of the APE. In terms of sensitivity, heads-of-gullies are considered to be highly sensitive as the gullies themselves provided easy access to elevated landforms. In turn, the gullies along the southern and southwestern sides of the APE form part of the watershed of Trout Brook, a minor stream that empties into Lake Champlain to the west (see Figures 1 and 2). The gully within the northwestern corner of the APE provides access to two small ponds, and ultimately to Lake Champlain farther to the west (see Figures 1 and 2). In essence, the proposed project s APE is located within a travel corridor between the Lamoille River and Lake Champlain.

Since the array APE is located in agricultural land, the initial step of the Phase I study entailed plowing and harrowing, and following sufficient rainfall, the UVM CAP field crew visually inspect the exposed ground surface for pre-contact era Native American artifacts. The surface inspection included members of the field crew spaced at 1.0 m (3.3 ft) intervals by which they traversed the field in linear swaths. When artifacts were identified, they were collected and two labelled orange pin flags were left in place. The locations of each artifact were recorded with a handheld Global Positioning System (GPS) to ensure their accurate location on project design plans. In addition, the perimeter of the plowed area was also recorded with the GPS. A total of nine pre-contact era Native American artifacts were identified as a result of the Phase I study. All are located in the northwestern portion of the APE (Figure 4) and are focused along the gullies that lead from the interior of the elevated landform and head west and northwest. Collectively, the nine artifacts were designated as site VT-CH-1218 in the Vermont Archaeological Inventory (VAI). Because groups of artifacts appear to be located on spatially discrete landforms, they were designated as Loci 1-4 of site VT-CH-1218 (Figure 5). Locus 1 of site VT-CH-1218 is located on an intermediate terrace along the western side of the northwestern gully (see Figure 5). Locus 1 includes two debitage specimens found 35 m (115 ft) apart. One is derived from chert and the other of quartzite, both locally available lithic raw materials. Lithic debitage is a by-product of the stone manufacturing process. As debitage is not temporally diagnostic, the age of Locus 1 is unknown at present. Locus 2 of site VT-CH-1218 is located on a prominent elevated landform that is bounded on the northwest and west by gullies (see Figure 5). Locus 2 is defined by three tightly spaced artifacts that include two tip/midsection fragments of unknown projectile point types, and a scraping/processing tool. One tip fragment and the processing tool are derived from local chert, and the second tip fragment from quartzite. As none of the artifacts are temporally diagnostic, the age of Locus 2 is unknown at present. Based on the three tools recovered at Locus 2, it appears that hunting and resource processing occurred in this portion of the site. Locus 3 includes a broad, level portion of land located to the southeast of the northwest head-of-gully and west of a smaller gully (see Figure 5). Three widely separated artifacts, encompassing an area approximately 1,257 m 2 (13,525 ft 2 ) in size, were collected at Locus 3. A quartzite Levanna type projectile point was collected from the ground surface just to the east of a prominent brush-covered ledge outcrop (see Figure 5). Levanna type projectile points are temporally diagnostic of the latter portion of the Middle Woodland period and all of the Late Woodland period, ca. 1,000-400 calendar years before present. A second quartzite projectile point, a rare Swanton Corner-notch type, was recovered approximately 56 m (184 ft) to the northwest of the Levanna (see Figure 5). Swanton Corner-notch projectile points are attributable to a localized Early Archaic culture, ca. 9,500-7,500 calendar years before present. The third artifact recovered at Locus 3 is characterized as a chert debitage specimen that may have been utilized and damaged during an expedient processing task. This artifact is located approximately 50 m (164 ft) to the east of Levanna projectile point (see Figure 5). 2

Locus 4 is represented by a single, isolated quartzite projectile point fragment collected along the east side of secondary gully near the northern edge of the APE (see Figure 5). The base and tip section of this projectile point are missing, but based on its shape and morphology, it likely dates to the Late Archaic period, ca. 6,000-3,000 calendar years before present. Conclusions and Recommendations Based on the results of the Phase I study, site VT-CH-1218 minimally encompasses 13,300 m 2 or 1.33 ha (143,160 ft 2 or 3.28 acres). For management purposes, the site was delineated into four spatially discrete loci that were determined by landform and artifact proximity. It is likely that further archaeological study will refine the loci dimensions and designations. Two definitive time periods, the Early Archaic and Middle/Late Woodland periods are represented, and a third, the Late Archaic, is equivocal. The limited artifact inventory suggests that hunting was a primary activity, with evidence of resource processing and stone tool manufacturing/maintenance as well. It must be noted that naturally occurring chert cobbles were prevelant within the APE and these appear to have been glacially transported from known sources to the north. Many of these cobbles have been either mechanically broken by historic era plowing or have degraded and fractured naturally over time. For this reason, only unequivocal chert debitage artifacts were collected. The Phase I artifact inventory of site VT-CH-1218 indicates that this particular site likely represents numerous occupations spanning a broad portion of Vermont s pre-contact era. The strategic location of the APE between ponds, Trout Brook, Lamoille River and Lake Champlain likely provided a rich resource area encompassing changing environments as well as an important travel corridor. Therefore, the UVM CAP recommends that a Phase II site evaluation of the site be undertaken prior to any proposed project construction in order to assess the site s potential significance, better define its size, age(s), function and integrity. It may be possible that all or portions of the site may be preserved with protective buffers, the size of which would be determined with consultation between GMP, UVM CAP and the Vermont Division for Historic Preservation (VDHP). Please feel free to contact us if you have questions regarding this study or our progress with producing a final draft report of the Phase I study. Sincerely, Geoffrey A. Mandel Research Supervisor Charles Knight, Ph.D. Assistant Director 3

Figure 1. Topographic map showing the location of the proposed Milton Mears Farm Road Solar project, Milton, Chittenden County, Vermont. 4

Figure 2. Map showing the Area of Potential Effects (APE) of the proposed Milton Mears Farm Road Solar project in relation to archaeological sensitivity factors, Milton, Chittenden County, Vermont. 5

Figure 3. Draft layout of the proposed Milton Mears Farm Road Solar project, Milton, Chittenden County, Vermont. 6

Figure 4. Map showing the extent of archaeological Phase I surface survey and locations of Precontact era Native American artifacts at site VT-CH-1218 within the proposed Milton Mears Farm Road Solar project, Milton, Chittenden County, Vermont. 7

Figure 5. Map showing the locations of Loci 1-4 of site VT-CH-1218 within the proposed Milton Mears Farm Road Solar Project, Milton, Chittenden County, Vermont. 8