SHPO Broadband Project Review Guidance

April 2024: Important updates on the SHPO Environmental Review Program.

For MnDEED State-Funded Fiber Optic Cable Installation Projects Only 

^{Date updated 01.22.2024}

Due to increased funding for the expansion of broadband infrastructure in the state, the Minnesota State Historic Preservation Office (SHPO) has developed guidance to help those who apply for broadband project funding through the Minnesota Department of Employment and Economic Development (MnDEED) Office of Broadband Development streamline their non-federal project reviews with SHPO.

Minnesota’s historic preservation laws require MnDEED to consult with the SHPO and other resource agencies regarding the identification and preservation of significant historic, architectural, and archaeological resources prior to carrying out state-funded undertakings (i.e., broadband projects). For more on Minnesota’s historic preservation laws please visit: 

• Minnesota Historic Sites Act (Minn. Stat. 138.665) 
• Minnesota Historic Site Act (Minn. Stat. 138.666) 
• Minnesota Field Archaeology Act (Minn. Stat. 138.40)

SHPO has worked with other resource and project review agencies including the Minnesota Indian Affairs Council (MIAC), the Office of the State Archaeologist (OSA), and the Minnesota Historical Society (MNHS) to develop the following best practices for incorporating planning for potential impacts to significant historic, architectural, and archaeological resources for these types of infrastructure projects. Applicants or project proponents for MnDEED broadband assistance should follow the guidance provided below when preparing and submitting a non-federal broadband project to SHPO for review.

Submitting a State Broadband Project for SHPO Review 

1. After a broadband grant has been awarded by MnDEED, a qualified professional archaeologist should be hired to prepare documentation to submit to SHPO with a project review request. The Minnesota Historical Society’s Preservation Specialists Directory maintains a list of archaeological consultants. Search for "archaeologist" by Specialty. In preparing documentation for SHPO broadband project review, the archaeological consultant should:
   1. In collaboration with the project proponent/grantee, review the proposed fiber optic cable route, the anticipated construction means and methods to install fiber optic cable, the ancillary areas or access routes, and identify an appropriate geographic area that encompasses the proposed fiber optic route, as well as any other areas needed for staging, access, etc. which may be impacted by project construction/installation.
   2. Complete a literature review and archaeological assessment (desktop research) to identify previously documented archaeological sites and designated historic properties within or adjacent to the proposed fiber optic cable route. The archaeological assessment should also identify areas that have a high probability for containing undocumented, intact archaeological sites.
   3. Use LiDAR imagery to help determine previous ground disturbance within the fiber optic cable route.
   4. Complete a field investigation, which may include pedestrian survey and shovel testing as necessary, in order to both field verify and ascertain the extant level of disturbance along the proposed fiber optic cable route. Reference the SHPO Archaeology Survey Manual for recommended methodology or reach out to Environmental Review Archaeologist Lucy Harrington, (651) 201-3283, for assistance.
   5. Please Note: state law requires an archaeological license for any survey work conducted in the public right of way. Please visit the Office of the State Archaeologist website for information on licensing.
   6. Identify cemeteries and burial locations within and adjacent to the proposed fiber optic cable route. If cemeteries and/or burial locations cannot be avoided, consult with the Minnesota Indian Affairs Council and the Office of the State Archaeologist under MN Statute 307.08, the Private Cemeteries Act to determine how to proceed.
   7. Prepare a cultural resources survey report following the guidance provided in the SHPO Archaeology Survey Manual.
      1. If any archaeological sites, designated historic structures, cemeteries, or burial locations are identified within or directly adjacent to the proposed fiber optic cable route during the investigations, the archaeologist should describe in the report (and to the grant applicant) how to avoid impacts to those resources.
   8. Prepare maps of the proposed cable route on standard printable page size PDF documents (8.5 x 11 inches, 11 x 17 inches) with the proposed fiber optic cable route marked in detail. The maps should clearly identify any cemeteries, burial locations, archaeological sites, and/or designated historic properties located within or directly adjacent to the proposed fiber optic cable route.
2. Once the cultural resources survey report is complete, the grant applicant should complete the following:
   1. Prepare a cover letter that has a detailed narrative description of the proposed project that includes specific language related to where and how the cable will be installed. This language should reference the location of the cable in relation to extant roadways and ditches (i.e. the bottom of the ditch slope, the ditch backslope, outside the ditch, etc.) and the location of the cable as measured in feet from the centerline of the roadway.
      1. If archaeological sites, designated historic structures, cemeteries or burials were identified during the investigations, the grant applicant should describe how the project construction will or will not avoid impacts to those resources.
      2. Copy the MnDEED contact person for the project on the letter.
   2. Prepare graphics showing where the cable will be installed and a description on how it will be installed (i.e., vibratory plow, directional bore) relative to existing disturbances.
   3. Please Note: stating that the cable will be installed within public right of way is not sufficient. Archaeological sites can remain intact in undisturbed portions of the right of way and right of way can extend well outside of previously disturbed roadway prisms (roadbed, shoulder, slope/backslope, ditch) see example depiction of cable installation location at right
3. The grant applicant should submit all project documentation materials (cover letter, cultural resources survey report, and maps) to ENReviewSHPO@state.mn.us with a valid return email address for the SHPO response letter. Copy the MnDEED contact person for the project.
   1. Attachment sizes up to 15MB total per email can be accepted in the ENReviewSHPO Inbox. If the file size is larger, please send multiple emails or submit documentation using a file transfer program (FTP). If you submit via FTP, please send a cover letter and notification of the file transfer separately to ENReviewSHPO@state.mn.us.
4. At the conclusion of the SHPO review, comment letters will be issued and sent to submitters via email only. The SHPO will typically respond within thirty (30) days of receiving the documentation, however, at times reviews may take longer due to limited staff and a high volume of project reviews. Review times may be extended if projects are submitted with incomplete documentation, or if consultation is not complete after the initial review. For more information, contact SHPO Environmental Review Specialist, Kelly Gragg-Johnson, (651) 201-3285.