Friends of Moses Hall (FMH) is pleased with MDOT SHA’s commitment to help identify the natural boundaries of the cemetery in contracting Dr. Timothy Horsley to conduct a geophysical survey of portions of the cemetery and the existing state right-of-way. FMH appreciates the thoroughness of Dr. Horsley’s investigations and findings. The report and supporting materials shared with FMH will be helpful in the future stewardship of this historic burial ground. The report findings also led to MDOT SHA’s recently announced decision not to extend the managed lanes footprint into either the cemetery/hall site or the adjacent State right-of-way. While our report review is ongoing, we do have initial concerns.

1) The cemetery boundary remains incompletely established with respect to the proposed Limits of Disturbance.

2) Additional non-invasive archaeological investigations are needed to determine whether additional graves are located to the north of the Moses Hall foundations, including the portions of the adjacent State right-of-way that were not surveyed.

3) While FMH notes that MDOT SHA has stated a commitment to avoid “ground impacts,” physical avoidance of this historic site does not equate to evasion of all impacts, such as noise and visual impacts, nor does it address environmental justice concerns.

The number of potential burials in the portions of the cemetery surveyed was stunning news. Dr. Horsley’s report “indicated the location of 189 probable burials, and suggest a further 188 possible burials, the majority of which are seen to be arranged in rows. This total of 377 is likely lower than the actual total number of graves present.” Additionally, the report revealed “some 14 probable unmarked burials” and “as many as 34 burials are suggested in total” in the MDOT SHA right-of-way to the north of the cemetery property. The findings suggest substantially more graves than previous historical research and surface inspection had indicated. This raises questions about the full extent of burials. The findings also elevate the possibility that the cemetery is much older than previously thought. MDOT SHA has demonstrated its ability to engage with the stakeholder community, contract subject

matter experts, and address impacts to this historic African American site, and we look to its continued commitment to build upon this success. FMH will continue to review the report materials and will submit formal comments before the end of the 30-day Section 106 comment period.

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