SHPO Broadband Project Review Guidance

For MnDEED State-Funded Fiber Optic Cable Installation Projects Only

Updated May 2026.

This guidance assists applicants seeking broadband project funding through the Minnesota Department of Employment and Economic Development (MN DEED) Office of Broadband Development (OBD). It reflects updated processes at MN DEED and the relaunch of the Minnesota Office of the State Archaeologist (OSA) Portal.

This guidance applies only to state-funded fiber optic projects. For questions about federally funded BEAD projects through NTIA, contact OBD directly.

Minnesota Historic Preservation Laws

Minnesota law requires DEED to consult with SHPO and other resource agencies regarding the identification and preservation of significant historic, architectural, and archaeological resources prior to project implementation.

Relevant statutes include:

DEED OBD developed a coordinated review process with SHPO, the Minnesota Indian Affairs Council (MIAC), the Office of the State Archaeologist (OSA), and the Minnesota Historical Society (MNHS). Applicants or project proponents for MnDEED broadband assistance should follow the guidance provided by MnDEED OBD for state funded grant projects.

Submitting a State Broadband Project for SHPO Review

  1. OBD Determines Whether an Archaeological Survey is Required.
    After a broadband grant is awarded, the applicant must work with OBD’s Environmental and Land Use Coordinator to determine if an archaeological survey is needed.
  2. If a Survey is Required.
    The applicant must hire a qualified archaeologist. The Minnesota Historical Society’s Preservation Specialists Directory maintains a list of archaeological consultants.
    The archaeological consultant should:
    1. Identify and document the entire geographic area that may be affected by the project.
      • Review the proposed fiber route, construction methods, and any staging or access areas.
    2. Complete a literature review and archaeological assessment.
      • Identify previously documented archaeological sites and designated historic properties (as defined in Minn. Stat. 138.665) within or adjacent to the project.
      • Identify areas with high potential for undocumented, intact archaeological resources.
      • Determine ways to avoid adverse effects to historic properties designated in sections 138.662 and 138.664 or listed in the National Register of Historic Places.
      • Determine ways to preserve significant archaeological sites (i.e. those that are listed or have previously been determined eligible for listing in the National Register of Historic Places).
      • Use LiDAR imagery to assess prior ground disturbance.
      • Identify cemeteries and burial locations within and adjacent to the project.
      • If cemeteries or burials cannot be avoided, consult MIAC and OSA under Minn. Stat. 307.08 (Private Cemeteries Act).
    3. Conduct a field investigation.
    4. Prepare an archaeology survey report.
      • Follow SHPO Archaeology Survey Manual guidance.
      • If any archaeological sites, designated or listed historic properties, cemeteries, or burial locations are identified within or directly adjacent to the proposed fiber route during the investigations, the archaeologist should describe in the report (and to the grant applicant) how to avoid impacts to those resources.
    5. Prepare project maps.
      • Use standard printable PDF sizes (8.5x11 inches or 11x17 inches).
      • Clearly show the fiber route and cemeteries, burial locations, archaeological sites, and/or designated historic properties located within or directly adjacent to the proposed fiber optic cable route.
    6. Submit the report.
      • The archaeologist must submit the report through the OSA Portal following SHPO’s How to Submit an Archaeology Report guidance.
      • The archaeologist must provide the report title, authors, and date to the grant applicant.
  3. Applicant Responsibilities After the Survey Report.
    The applicant must prepare the following materials for SHPO:
    1. Prepare a cover letter.
      • Provide a detailed description of the project and installation methods.
      • Describe fiber placement relative to roadway features (ditch bottom, backslope, outside the ditch etc.) and the location of the cable as measured in feet form the centerline of the roadway.
      • Describe how the project will avoid impacts to archaeological sites, designated or listed historic properties, cemeteries or burials.
      • Include the DEED grant program name (e.g., Border-to-Border Round ##) and grant cycle timeline.
    2. Example depiction of cable installation locationInclude installation graphics.
      Figure 1. Example depiction of cable installation location
      • Include a graphic showing where the fiber will be installed and describe the installation method (e.g., vibratory plow, directional bore).
      • Note: Stating the fiber is “within the public right of way” is not sufficient, as intact archaeological resources may remain in undisturbed right-of-way areas.
    3. Submit project to SHPO for review.
      • The grant applicant should submit the cover letter and required documentation to:
        ENReviewSHPO@state.mn.us. Copy deed.broadband@state.mn.us.
      • File size limits:
        Attachments up to 15 MB per email are accepted;
        Larger files may be sent across multiple emails or through an FTP service;
        If using FTP, email the cover letter and a notification of the file transfer to SHPO separately;
      • The cover letter must reference the archaeological report submitted in the OSA Portal (title, author, date).
  4. SHPO Review and Response
    • SHPO will issue comment letters by email.
      Typical response time is 30 days from receipt of complete documentation.
    • For questions about SHPO review:
      Contact SHPO Environmental Review Specialist Kelly Gragg-Johnson at kelly.graggjohnson@state.mn.us.
    • For DEED OBD grant process questions:
      Email deed.broadband@state.mn.us.