HomeMy WebLinkAboutArcheology comments rev6 FINAL - jkPage | Cultural Resources -Archeology -1 Rev6
CULTURAL RESOURCES (ARCHEOLOGY)
The DEIS scope states that development of the Project requires review by the New York State Office of
Parks, Recreation and Historic Preservation (OPRHP)1 “for archeological significance.” It calls for the DEIS
to discuss the “potential, adverse impacts to archeological and cultural resources from the action”
(p.22). The scope also notes that no archeological survey of the Project area had been made and the
question as to whether or not archeological resources might be affected could not be addressed with
available information.
In response to this requirement an archeological survey of the Project site was undertaken in 2021. The
survey included both a desk top study (Phase 1A investigation)2 and a field survey (Phase 1B
investigation)3. In response to comments from OPRHP, a supplemental Phase 1B survey report was
completed in January 2022.4 These studies are attached to the DEIS as part of Appendix T.
As defined in the New York Archaeological Council’s Standards for Cultural Resource Investigations and
the Curation of Archaeological Collections in New York State (NYAC Standards), adopted for use by
OPRHP, Phase 1A investigations consist primarily of a literature review to gather information concerning
the environmental/physical setting of a specific project area as well as its cultural setting, which can be
used to evaluate the archeological sensitivity of the project area (NYAC Standards, Section 2.2). Phase
1B investigations consist of systematic field investigations to identify archeological sites through
methods such as systematic surface survey, subsurface shovel testing, and remote sensing studies
(NYAC Standards, Section 2.3).
The Phase 1A and Phase 1B reports for the Project are considered here together. This is because a
significant amount of information which should have been incorporated into the Phase 1A survey is,
instead, included in the Phase 1B report. This information, which is significant, was apparently not
1 The New York State Historic Preservation Officer (SHPO) is the NYS Commissioner of Parks, Recreation and Historic
Preservation. The staff of the Division for Historic Preservation of the Office of Parks Recreation and Historic Preservation
(OPRHP) serves as the SHPO staff.
2 Strong’s Yacht Center – Proposed Boat Storage Buildings, Phase 1A Archaeology (v2), July 2021, prepared by Carol S. Weed
(included in DEIS Appendix T).
3 Phase 1B Archaeological Assessment, Strong’s Yacht Center – Proposed Boat Storage Buildings, 5780 W. Mill Road (NYOPRHP
21PR04396), October 4, 2021, prepared by Matthew D. Spigelman and Carol S. Weed (DEIS Appendix T).
4 Supplemental Phase 1B Archaeological Assessment, Strong’s Yacht Center – Proposed Boat Storage Buildings, 5780 W. Mill
Road (NYOPRHP 21PR04396), January 7,2022, prepared by Matthew D. Spigelman and Carol S. Weed (DEIS Appendix T).
Page | Cultural Resources -Archeology -2 Rev6
used in preparing the conclusions and recommendations presented in the Phase 1A report, rendering it
deficient. 5,6
The omission of this data does not appear to have been simple oversight. The Standards state:
“It is recognized that a variety of individuals, especially those interested in or living near
a specific project area, may have information not available from any other source. Such
information can enhance the data gathered from the written record alone. Informant
interviews with persons (e.g., avocational archaeologists, landowners, state or local
government agency staff) who may be familiar with the project area and possible
archaeological sites can make a valuable contribution to these investigations” (Section
2.2.2).
The Phase 1B report states that “No formal work plan for the proposed Phase 1B was submitted to
NYSOPRHP. However, Dr. Tim Lloyd, the OPRHP reviewer, did review the proposed survey grid and Ms.
Weed’s explanation of the proposed actions (see Appendix C – Agency Correspondence).” OPRHP’s July
22, 2021 comment letter states that “OPRHP concurs with your recommendation to conduct Phase 1B
archaeological testing at locations where proposed ground disturbances will take place in relatively level
intact soils.”
The Phase 1B report notes that the DEIS scope for the Project calls for the archeological sensitivity of the
“direct impact areas within the Project Site” to be evaluated. The qualifier “direct” does not appear in
the DEIS scope. While it is true that Phase 1B investigations are generally confined to “direct” impact
areas, possible misinterpretations of both environmental data and land use history, discussed below,
resulted in portions of the “direct impact area” being inappropriately excluded from investigation during
the initial Phase 1B investigations.7
The Phase 1A report presents both historic map and aerial photo evidence to support a conclusion that
a small, and since filled, inlet to Mattituck Creek, existed southeast of, and possibly intruding slightly
5 The information consists primarily of notes and records of archeological work conducted in Mattituck during the 1920’s by
Charles F. Goddard, a founding member of the New York State Archaeological Association and the Southold Indian Museum.
The Phase 1A report author notes (p.5) that she did contact Dr. Joel Klein, a retired professional archeologist resident in
Mattituck, as part of the Phase 1A investigation. However, the author does not mention that during a March 21, 2021
telephone call that she initiated, that Dr. Klein specifically advised her of the existence of the Goddard records, their potential
relevance, or that he recommended that she contact Dr. Tim Lloyd at the State Historic Preservation Office, as Dr. Lloyd was
familiar with the Goddard records and could advise her on how to access them. On July 22, 2021, OPRHP noted in a review of
the Phase 1A report that information from the Goddard records was missing, and directed that it be included in any future
report submissions (Phase 1B report, Appendix C). It is unclear whether the information from the Goddard records was used
in determining specific field methodologies to be used for Phase 1B field investigations.
6 The Phase 1A report does not appear to be a carefully prepared document. There are numerous incorrect and missing
citations and references.
7 This omission was noted by OPRHP which requested additional subsurface testing in the previously omitted areas (see below).
Page | Cultural Resources -Archeology -3 Rev6
into, the Project’s Construction Excavation Area (CEA). The report notes that this corresponds to the
current location of existing marina Bldg. 8. The report concludes that the fill was “gradually” placed
between 1962 and 1978. This is incorrect. A 1957 surveyor’s map of the property identifies a roughly
200 ft x 600 ft area corresponding to the location of the former inlet as “Sand Filled”. Anecdotal
information from local residents suggests that the former inlet area was filled by a previous owner—not
the Army Corps of Engineers (ACOE). Additionally, both the 1957 survey (COMMENT FIGURE
ARCHEOLOGY-1), and a 1931 survey (COMMENT FIGURE ARCHEOLOGY-2) suggest that the “inlet”
(labeled as “Basin”) extended considerably farther west into the CEA, well beyond the area occupied by
Bldg. 8.
The report author notes that she observed spoil piles along the east side of the CEA, and goes on to say
that “[T]he origin of the spoil is unknown but historic documents indicate that dredge spoil has been
deposited on the floodplain and in valley locations particularly on the west side of Mattituck Creek by
the US Army Corps of Engineers (Morgan et al. 2005, Friends 1986)”. This conclusion is unfounded and
likely incorrect.
The 1A report describes the observed spoil piles as including “concrete fragments, a tire, and other
[unspecified] cultural debris.” This description, as well as the included photograph (B5) of one of the
spoil piles (the author does not indicate how many, how large, or where these are located), strongly
suggest that these piles are not dredge spoil. First, the quantities of cultural debris described are not
typical of dredge spoil. Second, it is obvious from Photograph B5, even though it contains no scale, that
the size of the pile in the photo is relatively small, and totally inconsistent with the large quantities of
material one would expect from a dredge spoil disposal operation.
The 1A report cites Morgan et al. (2005) and Friends (1986)8 as the source of the claim that “dredge
spoil has been deposited on the floodplain and in valley locations particularly on the west side of
Mattituck Creek by the US Army Corps of Engineers” (emphasis added). No such statement appears in
Morgan et al. However, Batten and Kraus (2006), a source listed among the report’s references cited,
but which is never mentioned in the text, states that
“[I]n total, approximately 391,000 cu yd of sediment was dredged from Mattituck Inlet
between 1921 and 2004. Condition surveys for the 1946, 1950, 1955, and 1965 dredging
show that dredged material was placed either on the subaerial beach or below the
waterline directly to the east of the inlet. Records indicate that, after these initial
placements on the beach or in the nearshore, disposal of maintenance dredged
sediment on the eastern beach became standard practice” (2006:10) (emphasis added).
8 The references cited section of both the HRS and the Phase1A report contain a citation for “Friends of the Mattituck Free
Library 1986.” No further information is provided and it is not possible to identify the nature of this document or verify any of
the information it might contain.
Page | Cultural Resources -Archeology -4 Rev6
The Phase 1A report’s questionable conclusions in regard to the existence of large quantities of dredge
spoil within the Project area, which is on the west side of Mattituck Inlet, was used to support a decision
to inappropriately exclude a significant portion (much larger than just the area of the former inlet) of the
Project site from subsurface testing.
The section of the Phase 1A report describing walkover observations of the CEA (Construction
Excavation Area) claims that “The PWGC 2021 geotechnical bores clearly distinguish dredge spoil layers
in Bores B9, B10, and B11 (Figure 20)”. In fact, the author of the PWGC geotechnical report (in DEIS
Appendix H) was uncertain in regard to the classification of sediment recovered from bores as dredge
spoil; witness the decision to refer to them in boring logs as “potential” and “possible” dredged spoil. 9,10
The Phase 1A report goes on to say that, “Overall, the soil layers above the dredge spoils generally agree
with the CpE texture description (see comments on Geology and Soils) and represent erosion sediments
from upslope.” In fact, the USDA description of CpE soils (Warner et al. 1975) included in the Phase 1A
report, describes them as “glaciofluvial deposits.” Such deposits would result from a considerably
different formative process than would be associated with “erosional sediments”.11,12
Surprisingly little attention is given in the Phase 1A report to the prehistoric context associated with the
Project area. Specific prior archeological investigations conducted in the general Project area vicinity in
advance of planned development projects are discussed, as are three previously recorded Native
American archeological sites. However, discussion of the broader archeological context is limited to a
single sentence in a standard archeological reference (Ritchie 1980) which states only that its discussion
of Long Island is “exceptionally brief.”13
9 Section 2G(3) of OPRHP’s Phase I Archaeological Report Format Requirements state that “If soil boring logs are discussed in
the body of the report they must be provided as an appendix.” Copies of the boring logs were not included in the Phase 1A or
1B reports. They were not made available to OPRHP until a specific request for them was made by that office. The Phase 1A
report also mentions a 2018 test bore location (p.13) and includes a citation for an associated report by McDonald
Geoscience in the possession of the Project Applicant. This report does not appear to have been made available to OPRHP.
10 Borings B-10 and B-11 are within the “Sand Filled” area shown on the 1957 survey map.
11 A more detailed discussion of the possibility that extensive dredge spoil deposits are present in the Project area is included in
comments relating to the DEIS’ discussion of soil and DEIS Appendix H. As noted in those comments, the most significant
basis for questioning whether the material observed in the three borings (referred to as Stratum 3) is dredge spoil is the fact
that the top of Stratum 3 is found at depths varying from four to eight feet below ground surface. This begs the question: if
Stratum 3 is in fact dredge spoil, what is the material overlying it? Any such material could not have been deposited earlier
than the early twentieth century when the first dredging of Mattituck Inlet occurred. If the overlying strata are natural, then
Stratum 3 cannot be dredge spoil.
12 The misinterpretation of some soils in the Project area as dredge spoils is discussed in greater detail in comments on the soils
section of the DEIS.
13 As noted above, while the Phase 1B report contains an analysis of information from the Goddard notebooks, that data was
not considered during preparation of the Phase 1A report.
Page | Cultural Resources -Archeology -5 Rev6
The Phase 1A report Assessment Conclusions and Recommendations section does include a discussion
of the environmental characteristics of the Project area and vicinity that inform the assessment of the
areas likelihood of containing prehistoric Native American sites. The absence of known nearby sources
of potable water necessary to support long term habitations is noted. However, the Phase 1A report
also notes that “micro-terraces [within the CEA] would provide usable space for short term stays while
exploiting the Mattituck Creek and associated inlet riverine resources and the exposed glacial till along
the bluff faces”.14 No consideration is given to the possibility that archeological site types other than
occupation sites (e.g. short-term camps) might be present. Of special concern is the possibility that
burial sites could be present. This possibility is especially relevant because the Project area included a
topographic high point in close proximity to major water bodies (Mattituck Inlet and Long Island Sound).
This is the type of setting associated with the well-known prehistoric Orient-period burial sites located
east and west of the Project area in Orient and Jamesport (Ritchie 1959, 1969).15
Significantly, the Phase 1A report concludes that “the Project Site may retain archaeological sensitivity
within the CEA. It is recommended that the areas as outlined on Figure 20 and discussed above should
be subjected to Phase 1B archaeological survey as both locations are evaluated as having medium
sensitivity for the presence of Indigenous Nation use.”16 However, it also concluded that no subsurface
testing needed to be undertaken in areas believed to be covered by dredge spoil, and in fact, the Phase
1B survey did not test in those areas. The likelihood that significant volumes of dredge spoil are, in fact,
present within the CEA is unlikely for the many reasons mentioned above and in comments on the
portions of the DEIS dealing with soils an in DEIS Appendix H. However, even if the Phase 1A report is
correct in its conclusion that is no reason for excluding supposed areas of dredge spoil from
archeological testing. In all cases Project-related excavation will extend below the supposed levels of
presumed dredge spoil.17 This means that there is a potential for intact ground surfaces and
archeological remains to be present below any dredge spoil deposits. The presence of dredge spoil in
an area does not in and of itself constitute a basis for considering an area “disturbed.” The presence of
significant volumes of fill resulting in the deep burial of archeological deposits is a not uncommon
phenomenon. Archeological survey in such locations is routinely successfully undertaken through the
use of deep testing, most often involving backhoe excavations, or the collection of wide diameter soil
14 The riverine resources are plant and animal food sources. Exposed glacial till would have been a source of material for the
manufacture of stone tools.
15 As noted above, Ritchie (1969) The Archaeology of New York State, revised edition, is the sole standard archeological
reference cited in the Phase 1A report. One of the initial investigators of the Orient sites was Charles Goddard whose
notebooks were not consulted by the Phase 1A report author until she was advised to do so by SHPO staff. The principal
reference relating to North Fork burial sites, Ritchie, W.A. (1959), The Stony Brook Site and its Relation to Archaic and
Transitional Cultures on Long Island, New York State Museum and Science Service Bulletin 372, was apparently not consulted
as it is not included in the references section of any of the archeological reports.
16 Figure 20 in the Phase 1A report delineates only a single “area of archeological sensitivity”. It is located almost entirely
northwest of, and outside of, the CEA. No definition of what constitutes “medium” sensitivity is provided.
17 The Phase 1A report author was aware of this. The 1A report notes that “C-horizon soils will be encountered throughout the
new building excavation area . . . “
Page | Cultural Resources -Archeology -6 Rev6
borings in cases where backhoe excavation is not feasible because of the depths involved. The depths of
supposed dredge spoil in the CEA would not preclude backhoe testing. When test bores are employed,
they generally consist of 5-inch or greater bores designed to retrieve intact samples which can be
examined by archeologists for evidence of past human activity.18 These are far superior to the small
diameter split spoon samples collected during the geotechnical investigation conducted for the Project.
The final sentence of the Phase 1A report text reads: “If NYSHPO accepts this recommendation [to limit
Phase 1B work to the area delineated on Figure 20 of the Phase 1A report], a Phase 1B work plan will be
submitted that outlines the exact locations that will be subject to systematic shovel testing” (p.14).
However, it appears that Phase 1B work was carried out without a work plan being submitted.
The Phase 1A report author’s lack of familiarity with the Project vicinity is apparent when she states,
using the past tense, that “At one point, [the North Fork] was also known for its shellfish and fishing
opportunities” (emphasis added).19 The seeming lack of familiarity with relevant professional literature
(see fn 15, above) underscores the general lack of familiarity with the Project vicinity.
Phase 1B fieldwork appears to have been carried out by ACME Heritage Consultants (a third-tier
subcontractor) in accordance with the general plan described in the Phase 1A report. The field methods
employed appear to have been consistent with accepted archeological practice and the standards.
However, the excavation of shovel test pits (STPs) was initially “restricted to areas with less than 15%
slope and without known evidence of 20th century dredge spoil dumping” (p.7). While the elimination
of areas of steep slopes is appropriate, eliminating areas from testing solely because they were believed
to be covered with dredge spoil was not.
Areas of “potential dredge spoil” (emphasis added) are shown on Figure 20 in the Phase 1A report. They
are not shown on any of the graphics in the Phase 1B report. Figure 7 in the Phase 1B report shows the
location of planned and excavated STPs. Inexplicably/inconsistently, a significant number (approximately
20 out of a total of 70) of these are shown as having been excavated within the northeast portion of the
CEA in an area designated on Figure 20 in the Phase 1A report as an area of “potential dredge spoils.”
The soils profiles associated with these STPs are described in Appendix D (Stratigraphy Summary) and
are recorded as showing O, A, B, and E horizons typical of undisturbed soils. No evidence of the
presence dredge spoil is indicated.
18 In situations where deep testing is not feasible, as less desirable alternative is a requirement for archeological monitoring
during construction. Such monitoring must be carried out in accordance with Project-specific protocols that provide work
stoppages in the event that archeological remains are observed by monitors.
19 Another problem with the Phase 1A report is indicative of the lack of care with which it was prepared. Numerous references
in the References Cited section are not, in fact, cited in the texts of either the Phase 1A or 1B reports. At least several of
these appear to have been inappropriately copied from the References Cited section of the Historic Resources Survey
prepared for the Project. The References Cited section of the Phase 1A report identifies 44 separate books, reports, and
articles as being cited. Fewer than half of these are actually mentioned in the report text.
Page | Cultural Resources -Archeology -7 Rev6
No STPs were excavated within the southwest portion of the Project’s Construction Excavation Area.
While a portion of this area does have steep slopes, and was properly excluded from subsurface testing,
detailed topographic data shown on Project site plans indicates that much of the area is relatively level
and should have been tested during the initial Phase 1B survey.
The Phase 1B report concludes that “No further archaeological work is recommended for the Strong’s
Yacht Center – Proposed Boat Storage Buildings, 5780 W. Mill Road (NYOPRHP 21PR04396) project.”
Given the deficiencies described above, notably the failure to adequately test all of the areas that will be
affected by Project construction, this conclusion was premature.
Subsequent to the submittal of the DEIS in December 2021, because of deficiencies in the Phase 1B
survey, OPRHP requested that supplemental Phase 1B investigations be conducted in portions of the
Project site that were excluded during the initial Phase 1B field work. The report on that supplemental
fieldwork was completed on January 7, 2022 and submitted to OPRHP for review. OPRHP responded on
January 24, 2022 indicating that “no additional archeological investigation is needed.”
The report on the supplemental fieldwork is confusing, contains numerous errors and omissions20, and
possible misinterpretations. These may have resulted in OPRHP’s incorrectly concluding that no
additional archeological investigation is necessary.
The discussion of soils and stratigraphy in the Phase 1B reports is confusing. For example, soils mapping
by USDA is discussed in tables and text, but this information is not presented in a coherent or consistent
manner.21
20 For example, no scale is provided for four of the six figures in the report, making it very difficult to match locations on one
figure with locations on another.
21 For example, Table 2.1 describes the stratigraphy for PIC soils (Plymouth loamy coarse sand, 8 to 15 percent slopes) as
described in two USDA sources (WSS 2021 and Warner et al. 1975). WSS 2021 (USDA-NRCS Web soil survey) describes the
uppermost 50+ inches of PIC soils as consisting of 8 distinct strata. Warner et al. contains no description for PIC soils, but the
generic description for the Plymouth soil series includes 5 distinct strata in the uppermost 50+ inches. The description in
Table 2.1 has compressed these into three strata and omitted Munsel color codes. While Munsel color codes are provided in
Appendix D for each excavated STP, no attempt was made to correlate this information with information in either of the
USDA surveys.
Table 2.2 attempts to compare USDA soil descriptions with both the logs from borings and “the closest supplemental Phase
IB STPs to the bores in the supplemental Phase IB area.” For example, the stratigraphic descriptions from the boring B-7 log
are compared with the stratigraphic descriptions from STP 106. However, the comparisons seem to be at odds with the
statement that “stratigraphy was generally consistent with the . . . geotechnical borings.” For example Stratum 2 of STP 106
is described as “loamy sand”, whereas Stratum 2 of boring B-7 is described as “very loose reddish brown silty sand, trace
gravel, roots.” Differences are even more apparent when one realizes that the color of the soil is STP 106 is included in
Appendix D and reported as 10YR4/4 (dark yellowish brown). Further adding to the confusion is that STP 106 may not be the
STP closest to boring B-7. A comparison of Figure 6 in the supplemental Phase IB report with Figure C-101 in the geotechnical
engineering report memo appears to show STP 110 as the closes STP to B-7. Had the supplemental Phase IB report simply
included the locations of the geotechnical soil borings on the same figure as the STPs, this uncertainty could have been
avoided.
Page | Cultural Resources -Archeology -8 Rev6
The supplemental Phase IB report states that
“STPs along the southernmost margin of the CEA showed extensive deposits of dredge
spoil. The location of this spoil deposition is consistent with that shown in a 1955
historic aerial photograph (Figure 5). The bank of the former inlet was documented in
five STPs, with a truncated soil sequence covered in a thin (10–20cm thick) layer of
dredge spoil. The former inlet channel was identified in 10 STPs, with deep (80 cm+)
deposits of dredge spoil that continued below the limits of excavation. The presence of
these deep spoil deposits confirms that additional testing along the southern boundary
of the CEA is not needed.”
This conclusion is not supported by the data. The stratigraphic descriptions of excavated STPs in
Appendix D (but not the report text) record that “Fill,” or “Fill/Dredge” was found in STPs 113, 114, 117-
122, and 126-129. The report never discusses the criteria used to determine why a deposit should be
identified as “dredge,” or what the distinction is between “dredge” and “fill” (all dredge deposits are fill,
but not all fill is dredge). All of these STPS are located within an area that historic aerial photographs
show as a former inlet off of Mattituck Creek. The Phase IA report concluded that this inlet was filled by
dredge spoil sometime between 1962 and 1978. However, the 1957 survey map of the Project parcel
notes that the area corresponding to the former inlet is “sand filled” (COMMENT FIGURE ARCHEOLOGY-
1).
All of the STPs with strata recorded (Table D-1) as having “fill/dredge” deposits are recorded as showing
those deposits being found from 7 to a maximum of 90 cm (36 in) below the surface. (“STPs in deep
dredge spoil were excavated to the maximum depth possible based on soil conditions, typically 32 in.
(80 cm) below ground level” p.9). The presence of near-surface dredge spoil or fill is inconsistent with
boring log data.22
Borings B-9, B-10 and B-11 are the only borings made within what appears to be area of the former
inlet. Those borings show the top of the “Potential Dredge Spoil” at 4.0 ft, 4.5 ft and 8.0 ft below ground
surface, respectively. As archeological STPs were terminated above those depths, they never
encountered the stratum identified in the geotechnical report as “Potential Dredge Spoil”. This
discrepancy is not mentioned in the Phase IB supplemental report. Nor is mention made of the fact that
the presence of traces of shell noted in geotechnical borings appears to have been a criterion for the
geotechnical report classifying a stratum as “Potential Dredge Spoil.” No mention is made of shell being
present in any STPs excavated during the Phase IB investigation.
Historic period artifacts were found in ten STPs. The report states that most “artifacts were found in low
concentrations, typically one or two per STP, and were not retained for analysis” (p.11). This statement
raises several concerns. An artifact density of one or two per STP is not a “low” density. In some
22 Figure 5 does distinguish between STPs showing “Deep Dredge Spoil” and those showing “Shallow Dredge Spoil”.
Page | Cultural Resources -Archeology -9 Rev6
contexts it would be considered high. More important is the density and distribution of positive STPs. In
this case, as shown on Figure 6 of the supplemental Phase 1B report, all but one of these is clustered
within an area approximately 150 ft in diameter in the southwest corner of the Construction Excavation
Area. In fact, adjacent STPs 112 and 113 contained artifacts including glass, metal, ceramics and bricks,
possibly dating as early as the mid-nineteenth century. This is more than half of all the artifacts found.
These were all recovered from what the supplemental report identifies as Stratum 3 (varying from 17-36
cm [7-14 in] below the surface). Although the supplemental report interprets these deposits as fill, both
are located adjacent to, but outside of, the area shown on aerial photos (Figure 5) as the location of the
former inlet. Given that the deposit may pre-date the date of the earliest map consulted during
background research 23, it is possible that the deposits are associated with a 19th century structure of
unknown function. The location, adjacent to the former inlet would have been a possibly desirable
location for a variety of structure types.
It is also possible that the authors of the supplemental report are correct in interpreting the deposit as
evidence of dumping. However, given the limited areal extent of the deposit, and the possibly tight time
frame (based on the limited artifact identifications) of the deposit, it is possible that the deposit
represents a single dumping episode which could have archeological significance because it would
represent a single point in time, or, represent dumping by a single individual/family over a period of
time—in effect, an archeological time capsule. No attempt was made to more precisely define the limits
of the historic deposit. Section 2.3.2 of the NYAC Standards “When cultural materials are discovered in
isolated shovel-test units, a minimum of four additional units should he dug in the vicinity or the initial
test units should he expanded to insure against mistaking evidence of actual sites for ‘stray finds’.” No
supplemental STPs were excavated as part of the Phase IB investigation.
The second point of concern is the statement that at least some artifacts “were not retained for
analysis.” The report contains no discussion of the criteria used to determine which artifacts would be
retained, and which discarded. Only one photograph in the report illustrates artifacts, and that photo
shows only some of the artifacts from only a single STP. The three (complete?) bricks found in STP 113
are neither illustrated nor described.24 The three corroded nails recovered from STP 113 are included in
Photograph 4. However, it is impossible to confirm from the photo if these nails are, in fact, square
nails, as they are described in Table 2.3. Square nails pre-date 1850 when they were largely supplanted
by machine cut nails with rectangular, not square, shank cross-sections.25
23 The earliest historic map consulted for both the Phase IA archeological report and the Historic Resources Survey report (DEIS
Appendix T) is dated 1902. Earlier maps, e.g. Beers 1873 Atlas of Long Island, which shows structure-level detail, were
apparently never consulted as they are not mentioned in any reports prepared for the Project. The review of 19th century
atlases is standard practice during archeological background research. The fact they were not consulted is another indication
of failure to adequately investigate the archeological potential of the Project site.
24 Whole bricks can be especially diagnostic and are frequently dateable. The size, the presence and nature of inclusions and
markings on bricks can be especially diagnostic as to determining the age, clay source, and/ or manufacturer (e.g. the Sage
Brickworks in Greenport, the C. L. Sanford Brick Co. of Southold, both of which operated during the nineteenth century).
25 The report cites only a single on-line reference as the basis for all artifact identifications. This may reflect the report author’s
general unfamiliarity with historic period artifact identification.
Page | Cultural Resources -Archeology -10 Rev6
In the absence of additional investigation, including supplemental background research (e.g. a title
search of the property associated with historic artifact deposit, and supplemental map research
[which should have been conducted as part of the Phase IA investigation]), and/or a Phase II field
investigation (including the excavation of a limited number of larger test units in the vicinity of STPs
112 and 113) it is not possible to determine that the Project will not affect a significant archeological
site.
It is within the scope of the Planning Board’s authority to request that OPRHP/SHPO review its prior
conclusion that no additional archeological work is required, or as lead agency, to direct the Applicant
to conduct the additional investigations. Either or both of these options should be exercised to ensure
that the Planning Board has taken a “hard look” at the Project’s potential to affect archeological
resources.
Page | Cultural Resources -Archeology -11 Rev6
COMMENT FIGURE ARCHEOLOGY-1
1957 Ketcham Survey (reduced, scale shown is inaccurate)
Page | Cultural Resources -Archeology -12 Rev6
COMMENT FIGURE ARCHEOLOGY-2
Town of Southold Highway Map Book
http://24.38.28.228:2040/weblink/0/doc/925821/Page1.aspx