Historic Resources Commission accepts Section 106 reports for Blackstone Ranch; suggests mitigation to avoid MOA

The Carson City Historic Resources Commission on July 2 accepted archaeological and architectural inventory reports prepared for the Blackstone Ranch development on the west side of Interstate 580 at the end of Railroad Drive, and recommended adding mitigation measures to try to avoid a formal memorandum of agreement under Section 106 of the National Historic Preservation Act.

Commissioners said the reports, prepared for review under Section 106, address potential adverse effects from a proposed extension of Railroad Drive through pastureland. The commission voted unanimously to accept the reports and recommendations as prepared by NCE Engineering and Environmental Services, asking staff to supply comments as the project’s consulting local government.

The commission’s discussion focused on whether mitigation measures could reduce the project’s adverse effects enough to achieve a "no adverse effect" determination. Commissioner Lou Anne Block suggested adding visual screening — for example a row of trees along the west side of the new roadway — so the pasture would remain visually intact from public vantage points. Vice Chair Michelle Schmitter said she shared concern for an iconic barn and pasture visible from the street and supported exploring screening.

Heather Ferris, Carson City staff, told commissioners that subdivision design and road names are reviewed by Community Development and Development Engineering and that road-name changes are possible but unlikely late in the review process. Jeremy Hall, project manager for NCE Cultural Resources, described how the area of potential effect (APE) was drawn for the Army Corps review. He said his team followed guidance in the Advisory Council on Historic Preservation’s 2019 memo when distinguishing direct and indirect effects and folded cumulative effects into the analysis. Hall said the Army Corps typically frames its APE around the culvert and the immediate crossing point for a Railroad Drive extension, and that some impacts farther south were being addressed separately in Corps reviews.

Commissioners asked to be signatories on any future memorandum of agreement (MOA) if one is required. Several commissioners said that embedding mitigation recommendations directly in the architectural and archaeological reports — e.g., specific screening or other measures — could allow all concurring parties, including the State Historic Preservation Office (SHPO) and the U.S. Army Corps of Engineers, to agree to measures and avoid a separate MOA.

When asked whether avoiding an MOA was possible, Jeremy Hall said, "Within the guidelines I believe that you can, put in measures to mitigate for the adverse effect. If you include those and the SHPO agrees and the Corps of Engineers would have to agree to. But it is possible to do that and avoid having to do an MOA." Ferris added that the Washoe Tribe had not yet been contacted but, as a potentially interested party, would be expected to participate in federal consultation as the Corps and lead federal agencies move forward.

Motion and vote: Commissioner [name on file] moved to accept the reports and recommendations for effect on the Blackstone Ranch project as prepared by NCE Engineering and Environmental Services. The motion was seconded and carried unanimously. (The commission recorded the action as acceptance of the Section 106 inventory and recommendations; the reports themselves remain subject to further comment by the Corps and SHPO.)

The commission’s action is procedural: accepting the inventory and recommendations positions the HRC to submit formal comment as a consulting party. Future steps — including Army Corps permitting under Clean Water Act Section 404 and federal consultation with SHPO and the Washoe Tribe — will determine whether an MOA is required or whether mitigation embedded in the reports can secure a no-adverse-effect finding.

Commissioners asked staff to circulate Corps and SHPO comments when they arrive and to return any revised materials to the commission for further comment.