In reply, refer to 2023-MRW-57606
May 3, 2023
Michael Kenneally EDR
5 E. Long Street, Suite 700 Columbus, OH 43215 mkenneally@edrdpc.com
RE: Crossroads Solar Project, Cardington, Lincoln, and Westfield Townships, Morrow County, Ohio
Dear Mr. Kenneally:
This letter is in response to the correspondence received on April 6, 2023 regarding the proposed Crossroads Solar Project, Cardington, Lincoln, and Westfield Townships, Morrow County, Ohio. We appreciate the opportunity to comment on this project. The comments of the Ohio State Historic Preservation Office (SHPO) are made pursuant to Section 149.53 of the Ohio Revised Code and the Ohio Power Siting Board rules for siting this project (OAC 4906-4 and 4906-5). The comments of the Ohio SHPO are also submitted in accordance with the provisions of Section 106 of the National Historic Preservation Act of 1966, as amended (54 U.S.C. 306108 [36 CFR 800]).
The proposed undertaking involves the construction of a 604-acre solar-powered electric generating facility in Morrow County. Our office has reviewed the Cultural Resources Research Design and Survey Methodology, Crossroads Solar Project, Cardington, Lincoln, and Westfield Townships, Morrow County, Ohio prepared by EDR. An archaeological sensitivity assessment was created to identify areas of elevated archaeological sensitivity based on Criterion 1 (within 1,000 feet of permanent water and on slopes equal to or less than 15%), Criterion 2 (within or near known archaeological sites) and Criterion 3 (locations of standing or demolished historic structures). Based on these criterion, it is recommended that 100% Phase I-level survey will take place in the elevated sensitivity for archaeological material (483 acres of the project area) and 100% Phase I survey (increased shovel testing interval to 30 meters and increased pedestrian survey to 20 meters) will take place in reduced sensitivity for archaeological material areas (121 acres of the project area). Our office agrees with this proposed archaeological survey methodology.
Our office also agrees to the proposed historic resources research design and survey methodology. However, we request a revised visual analysis showing one that combines both the topography only analysis with the digital surface model. We also request a proposed Area of Potential Effects (APE) line be added to the map. Based on where the proposed APE is located, at a minimum, street views of the southern edge of Cardington should be taken to determine if there is a potential historic district that might be affected by the solar facility.
Our office looks forward to additional coordination for the Crossroads Solar Project. If you have any questions, please contact me by e-mail at khorrocks@ohiohistory.org or Kristen Koehlinger at kkoehlinger@ohiohistory.org. Thank you for your cooperation.
Sincerely,
Krista Horrocks, Project Reviews Manager Resource Protection and Review
RPR Serial No: 1097681
OHIO
HISTORY CONNECTION
In reply, refer to: 2023-MRW-57606
June 5, 2023
Micliael Kenneally EDR
5 E Long Street, Ste 700 Columbus, OH 43215
RE: Crossroads Solar Project - Revised Area of Potential Effects Cardington, Lincoln, and Westfield Townsliips, Morrow County, Oliio
Dear Mr. Kenneally:
Tliis letter is in response to tlie correspondence received on April 6, 2023, regarding tlie proposed Crossroads Solar Project, Cardington, Lincoln, and Westfield Townships, Morrow County, Ohio. We appreciate tlie opportunity to comment on tliis project. The comments of the Ohio State Historic Preservation Office (SHPO) are made pursuant to Section 149.53 of the Oliio Revised Code and the Oliio Power Siting Board rules for siting this project (OAC 4906-4 and 4906-5). The comments of the Ohio SHPO are also submitted in accordance with the provisions of Section 106 of the National Historic Preservation Act of 1966, as amended (54 U.S.C. 306108 [36 CFR 8001).
In a letter dated May 3, 2023, our office agreed with the proposed survey methodology for both the proposed archaeological survey and tlie history/architecture survey. However, we did ask for a revised visual analysis sliowing both the topography only analysis witli the digital surface model. We also asked that a proposed Area of Potential Effects (APE) be denoted on the map. The recent correspondence provided tliis information. After reviewing tlie revised APE map, the SHPO agrees witli the area to be surveyed.
We look forward to continued coordination for tlie Crossroads Solar Project. If you have any questions, please contact us at (614) 298-2022, or by e-i'nail to Krista Horrocks at khorrocks@)ohiohistory.org or myself at kkoelilinger(24oliioliistory.org. Thank you for your cooperation.
Sincerely,
Inreply,pleasereferto: 2023-MRW-57606
June2,2025
MichaelKenneally EnvironmentalDesign&Research
5ELongStreet,Ste700 Columbus,OH43215
RE: CrossroadsSolarProject
MultipleTownships,MorrowCounty,Ohio
DearMr.Kenneally:
ThisletterisinresponsetothecorrespondencereceivedonMay1,2025,regardingtheproposed CrossroadsSolarProject.Weappreciatetheopportunitytocommentonthisproject.Thecommentsofthe OhioStateHistoricPreservationOffice(SHPO)aremadepursuanttoSection149.53oftheOhioRevised CodeandtheOhioPowerSitingBoardrulesforsitingthisproject(OAC4906-4).Thecommentsofthe OhioSHPOarealsosubmittedinaccordancewiththeprovisionsofSection106oftheNationalHistoric PreservationActof1966,asamended(54U.S.C.306108[36CFR800]).
Thefollowingcommentspertaintothe Historic Resources Survey Report, Crossroads Solar Grazing Center, Cardington, Lincoln, and Westfield Townships, Morrow County, Ohio (EDR,August2025).In thereport,onehundredsixty-two(162)propertiesweresurveyed.Oftheseproperties,nonewere recommendedaseligibleforlistingintheNationalRegisterofHistoricPlaces(NRHP).TheSHPO agreeswiththeserecommendations.Therefore,weagreethattheproposedconstructionworkwillhave noeffectonhistoricproperties.
Pleasenotethatthisdeterminationofeffectsisforabovegroundresourcesonly.Thearchaeological componentoftheprojectisbeingcoordinatedseparately.Ourofficelooksforwardtoadditional coordinationfortheproject.
Ifyouhaveanyquestions,pleasecontactmeatkkoehlinger@ohiohistory.orgor(614)298-2000.Thank youforyourcooperation.
Sincerely,
KristenKoehlinger,DepartmentHead&DeputyStateHistoricPreservationOfficerfor ResourceProtectionandReview
“Please be advised that this is a Section 106 decision. This review decision may not extend to other SHPO programs.”
RPR Serial No: 1108794
In reply refer to: 2023-MRW-57606
August 19, 2025
Janna Napoli
Environmental Design & Research (EDR)
Midwest Region
5 E. Long Street, Suite 700 Columbus, Ohio 43215
Email: jnapoli@edrdpc.com
RE: Section 106 Review: Phase I Archaeological Survey – Crossroads Solar Grazing Center Project, Cardington, Lincoln, and Westfield Townships, Morrow County, Ohio
Dear Ms. Napoli:
This letter is in response to the correspondence received on July 7, 2025, regarding the Phase I archaeological survey for the proposed Crossroads Solar Grazing Center Project in Cardington, Lincoln, and Westfield Townships, Morrow County, Ohio. We appreciate the opportunity to comment on this project. The comments of the Ohio State Historic Preservation Office (SHPO) are made pursuant to Section 149.53 of the Ohio Revised Code requesting cooperation among state agencies in the preservation of historic properties, Ohio Administrative Code Chapters 4906-4-08 (D). The comments of the Ohio SHPO are also submitted in accordance with the provisions of Section 106 of the National Historic Preservation Act of 1966, as amended (54 U.S.C. 306108 [36 CFR 800]).
The proposed undertaking involves the construction of a solar-powered electric generating and sheep grazing facility and its’ related infrastructure (e.g., collection lines, substations, access roads, and laydown yards) within a series of land parcels totaling approximately 730-acres, which is defined as the project area. The following review and comments pertain only to Phase I Archaeology Survey, Crossroads Solar Grazing Center, Cardington, Lincoln, and Westfield Townships, Morrow County, Ohio by Environmental Design & Research, Landscape Architecture, Engineering & Environmental Services, D.P.C. (EDR) (Way and Napoli, 2025). The architectural component was submitted in a separate, standalone report, and therefore was reviewed under a separate cover.
The archaeological survey involved a literature review, shovel test unit excavations, surface collection, and visual inspection of 660-acres of the project area Approximately 17.0-acres will be surveyed in the Fall of 2025 and submitted as an addendum to the aforementioned report. The literature review identified 55 Ohio Archaeological Inventory (OAI) sites, nine cemeteries, one National Register of Historic Places (NRHP) property, 86 Ohio Historic Inventory (OHI) structures/buildings, and six previous cultural resource surveys within a 2.0-mile radius of the project area Four of the OAIs are documented adjacent to the project area while two of the previous surveys overlap a portion of it.
The current survey resulted in the identification of 90 previously undocumented archaeological sites, 33MW331-33MW420. Eighty-five of these are documented as pre-contact Native American sites consisting of isolated finds to low-density lithic scatters. The remaining five sites were documented as historic-era sites representing mid-19th to early 20th century scatters. Based on the data presented in the
2023-MRW-57606
August 19, 2025
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report, the SHPO agrees with EDR that most of these sites are not considered eligible for inclusion to the National Register of Historic Places (NRHP) However, EDR recommends two sites, 33MW352 and 33MW366, both of which are historic-era sites, for additional work. The SHPO agrees with this recommendation, and it has been proposed that the sites will be avoided, and a 50-ft buffer established around them Therefore, the SHPO requests that a Memorandum of Understanding (MOU) be drafted that will outline the final design plan of the solar facility and appropriate avoidance plan for sites 33MW352 and 33MW366. The avoidance plan should include the 50-ft buffer around the established site boundary to ensure that no incidental impacts occur during construction. The buffer should be clearly marked in the field (e.g., silt fence) to help minimize impacts. If avoidance of these sites is not feasible, then a Phase II work plan, including research design, should be developed and submitted to our office prior to the commencement of field work.
We look forward to further coordination regarding the MOU/avoidance plan or Phase II work plan/research design. If you have any questions concerning this review, please contact me by email at sbiehl@ohiohistory.org. Thank you for your cooperation.
Sincerely,
Stephen M. Biehl, Project Reviews Manager-Archaeology
Resource Protection and Review
State Historic Preservation Office
RPR Serial No. 1109834
