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Mike Boulay <br />-45- October 16, 2012 <br />Appendix J — Class III Cultural Resource Inventory (Grand River Institute) <br />• Site 5GF879.6, a segment of the historic Davenport Ditch, is described <br />beginning on page 10 of this report. Portions of a 1981 archaeological <br />analysis are quoted, which describe the construction of a ditch and cement <br />diversion dam in the late 1890's by the Quaker Oats Co. According to the <br />quoted text, because of accumulated silt "the dam was then dynamited and <br />the ditch never used." <br />• This study then documents the remains of a diversion feature (Feature #1), <br />the dynamited diversion dam (Feature #2), and a headgate (Feature #3), <br />along with two segments of the ditch. Photos and a map of these features <br />were not provided to the Division, but based on descriptions in the text, it <br />appears that Feature #2 may be the concrete wall shown in Photos 1 and 2 of <br />the AVF determination. <br />• The historical narrative regarding the attempt made by Quaker Oats Co. to <br />dam and divert flows from East Salt Creek more than 100 years ago is <br />illuminating, but the elongated landform does not appear to have been <br />evaluated for the Cultural Resource Inventory. Rather, attention was focused <br />solely on the concrete dam /diversion structures located at the present -day <br />constriction of East Salt Creek. <br />Conclusions <br />• With PR -2, MCM has attempted to re- characterize a landform previously <br />identified as "man -made fill" as being the result of natural processes, <br />specifically a landslide which originated west of East Salt Creek and SH 139. <br />The Division does not find the arguments now being presented to be <br />compelling, and suggests that the shape and location of the feature are more <br />consistent with the intentional construction of an earthen dam than they are <br />with landforms created by natural processes. <br />• Assuming the landform is determined to be human -made, the question that <br />next arises is, "When was the dam constructed ?" The earthwork may well <br />have been accomplished as part of the Quaker Oats project, but if that effort <br />merely took advantage of a "constriction" that already existed at this location, <br />is it possible that construction of the dam predated the arrival of settlers in the <br />area? This may need to be further evaluated as part of the Cultural Resource <br />Inventory. The Division will consult with the Bureau of Land Management <br />and /or the State Historic Preservation Officer as to whether additional study is <br />warranted. <br />Please consider the comments above and provide a plausible, consistent <br />description of the structure throughout the permit revision application. <br />