B_USCG-SHPO Consulation Package.pdf

R. Daniel Mackay Deputy Commissioner for Historic Preservation Deputy State Historic Preservation Officer New York State Office of Parks, Recreation and Historic Preservation (OPRHP) Division for Historic Preservation Pebbles Island State Park P.O. Box 189 Waterford, NY 12188-0189

Dear Mr. Mackay:

The U.S. Coast Guard (USCG) is proposing to rebuild its Sector New York family housing complex, located within the bounds of the former Fort Wadsworth on Staten Island, New York.

Pursuant to Section 106 of the National Historic Preservation Act (NHPA) and its implementing regulations, the USCG seeks your comment on its determination that the proposed undertaking would not adversely affect any historic property listed or eligible for listing on the National Register of Historic Places (NRHP).

Background

Fort Wadsworth is on the northeastern shore of Staten Island, on the Narrows of New York Harbor (see Enclosure 1). The USCG housing complex is an approximately 50-acre area in the southwestern corner of the former fort. The Navy constructed the Fort Wadsworth housing complex circa 1990. The housing was intended for families of Naval enlisted personnel assigned to the new Battleship Group planned for that area, but those plans changed and the Navy never occupied the buildings.

In 1995, as part of an action under the Department of Defense’s Base Realignment and Closure (BRAC) process, the Navy transferred the housing complex and select areas of Fort Wadsworth to the USCG and other branches of the military, and the remaining areas of Fort Wadsworth to the National Park Service (NPS). The area of Fort Wadsworth acquired by the NPS is now within the Staten Island Unit of the Gateway National Recreation Area (GNRA) and is administered by the NPS.

Within the USCG housing complex, there are currently 20 apartment buildings containing 152 family housing units (shown in green outline on Enclosure 2). The existing apartment buildings are 3-story, wood frame structures built over crawl spaces with shallow foundations and no

Commanding Officer United States Coast Guard Civil Engineering Unit Providence

475 Kilvert Street, Suite 100 Warwick, RI 02886 Staff Symbol: CEUP Phone: (401) 736-1777 Email: Eric.G.Para@uscg.mil

12 OCT 2021

USCG Sector New York Fort Wadsworth Project to Rebuild Housing 5090 basements. They have gable roofs and shed overhangs. See Enclosure 3 for photos of typical views of the apartment buildings and area of the USCG housing complex.

There were originally 32 apartment buildings, but the USCG has demolished 12 of them (demolished apartment buildings are shown in light gray outline on Enclosure 2). The two most recently demolished were Building 443 (USN 08501.003713) in 2017, and Building 442 (USN 08501.002541) in 2020. In addition to the 20 remaining apartment buildings, the housing complex includes a community center (shown on Enclosure 2).

Proposed Undertaking

The USCG requires suitable and safe housing for its members and their families in the greater New York area. The existing apartment buildings at Fort Wadsworth have severe structural, mechanical, plumbing, and life safety issues stemming from the original construction by the Navy. A major overhaul of the buildings is required to bring them into compliance with code and up to adequate and modern housing standards. The USCG has determined that demolishing the existing buildings and rebuilding them into a multiplex format (e.g., townhomes) is in the best interest of the USCG.

The USCG proposes to demolish the remaining 20 apartment buildings and replace them.

Conceptual plans include construction of about 30–31 new 2- or 3-story buildings, with 2–6 townhomes each (a notional layout of new buildings is shown as gray polygons with blue outline on Enclosure 2). The final design and number of buildings and units will depend on layout and space, but the new structures would stay within the USCG housing complex footprint and would be similar to the existing structures in character, size, and scope.

The area of potential effect (APE) for the proposed undertaking is shown on Enclosure 2.

Demolition and construction would occur only within the boundary of the USCG housing complex. The APE includes belowground areas within the USCG housing complex that would be affected by ground-disturbing activities (removal of foundations, removal of subsurface utilities, roads, construction, replacement of utilities, etc.).

To account for potential indirect effects on any nearby historic properties, and in consideration of the scale and nature of the proposed undertaking, the APE also extends slightly beyond the construction and demolition area. On the northwest, west, south, and southeast, the APE boundary coincides with the roads around the USCG housing complex because they provide a distinct separation of the housing complex from the surrounding areas. Dense vegetation and topography provide a natural separation of the housing complex from the surrounding areas to the north and northeast sides, where the APE generally includes an approximately 200-foot buffer from areas of construction or demolition.

In addition to construction of the new housing units, the project involves demolition and site clearing, underground utilities and roads, garages/parking, two overflow parking lots (notional layout shown as light gray/hatched polygons with blue outline on Enclosure 2), sidewalks, street lighting, and landscaping of new construction. The project also includes reconfiguring segments of the perimeter fence along the southeastern and southern boundary of the housing complex to close access at USS Tennessee Road and add a security gate for emergency access on USS North Carolina Road near the public walkway of Fort Wadsworth. The existing community center, many of the existing roads, and other parts of the complex (e.g., tot lots) would remain.

Historic Resources

Before becoming part of the GNRA, Fort Wadsworth was one of the oldest military installations in the nation. Frederick R. Black’s A History of Fort Wadsworth, New York Harbor (Cultural Resource Management Study No. 7, North Atlantic Regional Office, NPS, 1983) shows that the USCG housing complex land was acquired by the War Department for an expansion of Fort Wadsworth in 1892 (Black, 1983:106-110). For a detailed history of Fort Wadsworth, see also https://www.nps.gov/gate/learn/historyculture/ftwad.htm.

Historical U.S. Coast Survey (Coast Survey) navigation charts and U.S. Geologic Survey (USGS) quadrangle maps indicate that the vicinity of the APE was agricultural land in the nineteenth century, with scattered buildings arrayed primarily along roads and lanes.

New York State began planning for construction of masonry and earthen fortifications to help defend the Narrows in the early 1800s. Beginning in the 1890s, the War Department constructed a series of shore batteries to protect the Narrows approach to New York Harbor as part of a nationwide modernization of coastal fortifications resulting from the War Department’s mid- 1880s Endicott Board of Fortifications report and hurried along by the anxieties of the Spanish- American War.

Fortifications at Fort Wadsworth included what is now known as Battery Weed (NRIS No.

72000908 / SHPO No. 90NR01029) and the Fort Tompkins Quadrangle (NRIS No. 74001300 / SHPO No. 90NR01013), both of which are listed on the NRHP and the New York State Register of Historic Places (SRHP). Both of these are on the north side of the Verrazano Narrows Bridge and about 2,000 feet northeast of the APE.

Twelve additional Endicott period batteries at Fort Wadsworth, which are not listed on the NRHP but which are considered eligible, include the following:

Battery Duane; Battery Ayers; Battery Richmond; Battery Barry; Battery Upton; Battery Dix;

Battery Mills; Battery Hudson; Battery Barbour; Battery Turnbull; Battery Bacon; and Battery Caitlin. The closest of these is Battery Dix, which is outside of the USCG housing complex fence line and whose southern end is within about 150 feet of Buildings 452 and 454. Batteries Ayers, Richmond, and Barry are also within a few hundred feet north of the USCG housing complex.

Historical USGS quadrangle maps and aerial imagery from the USGS EarthExplorer website and Historicaerials.com suggest that the present location of the housing complex was relatively undeveloped until the middle or late 1950s, when what appears to be family housing was erected in the area on a street running roughly parallel to the shoreline. The 1950s generation of housing was replaced circa 1990 by the current set of dwellings.

In 1997, the NPS nominated the entirety of Fort Wadsworth to the NRHP as a historic district (i.e., including the areas not administered by NPS, such as the USCG housing complex). In 1998, the New York State Historic Preservation Office (SHPO) determined the Fort Wadsworth Historic District to be eligible for inclusion in the NRHP and listed it on the SRHP (SHPO No.

98NR01405). However, the NPS rejected the nomination for listing on the NRHP.

The NPS is currently in the process of re-nominating Fort Wadsworth to the NRHP as a historic district, although preliminary indications are that the revised nomination will exclude the USCG housing complex from the historic district.1

The apartment buildings of the USCG housing complex are not eligible for listing on the NRHP, nor do they contribute to the significance of the state-listed Fort Wadsworth Historic District.

Further, they are outside of the historic district the NPS intends to nominate for inclusion in the

NRHP.

Previous archeological survey work in the area identified two multicomponent sites within the USCG housing complex and in the immediate vicinity of where demolition and construction would be done. The Fountain-Mouquin House Historic and Prehistoric Site (USN 08501.000007), located close to former Building 444, is considered eligible for the NRHP.

Eligibility for inclusion in the NRHP has not been determined for the second site, the Oude Dorp (Old Town)–Arrochar Site (USN 08501.000027), which is located close to existing Building 428.

Determination of Effect

The buildings proposed to be demolished are not listed or eligible for inclusion in the NRHP, and they are not contributing elements to any such property. The new structures would stay within the USCG housing complex footprint and would be similar to the existing structures in character, size, and scope. Further, the USCG housing complex is delineated and separated from surrounding areas by roads, topography, and dense vegetation. Therefore, replacing the existing housing structures with new but substantially similar housing structures would not alter the character, use, or historic context of adjacent properties (e.g., nearby Endicott period batteries).

The history of development of the land occupied by the USCG housing complex indicates that over much of the area at least one cycle of building construction and demolition preceded the present apartment buildings. It is therefore anticipated that ground-disturbing demolition and construction activities will occur largely in previously disturbed soils and that the potential for potentially significant archeological deposits is relatively low.

In this context, “potentially significant” refers to the possibility that an archeological site possesses good integrity—i.e., relatively undisturbed deposits and spatial patterning reflecting the activities of people during an identifiable period of occupation—and meets Criterion D of the

1 Telephone communication between Kathleen LaFrank, New York Division for Historic Preservation, and Karen Ladd, U.S. Coast Guard, September 13, 2021.

NRHP, having the “ability to yield important information about prehistory or history,” or, if appropriate, meets one or more of the other NRHP criteria (National Register Bulletin, Guidelines for Evaluating and Registering Archeological Properties, which describes the application of NRHP criteria at Title 36 Code of Federal Regulations, Part 60 [36 CFR 60] to archeological sites).

Based on the available historical background, the excavation and removal of the foundations and underground utilities of the apartment buildings and other ground-disturbing activities likely will yield chronologically and functionally mixed secondary deposits and/or fill imported from elsewhere. Such deposits typically contain a mix of fragmentary demolition debris (broken masonry, window glass, metal fasteners and hardware, etc.) and fragments of household domestic items, such as ceramics, and/or traces of prehistoric Native American occupation, such as flakes and other debris left from the manufacture and/or maintenance of stone tools, along with occasional complete stone tools. Fragmentary animal bones left from the consumption of meat might be present, though prehistoric period deposits would not include domestic animals and historic period deposits would likely be predominantly domestic animals like pig, sheep, cattle, and horse.

There appears to be a low probability of encountering prehistoric or historic period deposits that have not been extensively disturbed by previous construction and demolition activities and that have the potential to yield information important to the history or prehistory of Fort Wadsworth and Staten Island. Nonetheless, the proximity of the proposed undertaking location to two inventoried archeological sites and to some of the Endicott period coastal artillery batteries suggests the unlikely possibility that intact, significant archeological deposits might be present in the vicinity of the proposed undertaking.

The USCG will therefore prepare and implement an Inadvertent Discoveries Plan (IDP)/Unanticipated Discoveries Plan (UDP), to include an archeological monitoring program conducted by a qualified archeologist. The qualified archeologist will continuously monitor for archeological discoveries during ground-disturbing activities associated with demolition and construction. The IDP/UDP will be similar to Enclosure 4, which was implemented in 2020 for the demolition of Building 442 USS Iowa Circle (USN 08501.002541).

Conclusion and Request for Comment

In conclusion, the buildings proposed to be demolished are not listed or eligible for inclusion in the NRHP, nor are they contributing elements to any such historic property. Replacing the existing housing structures with new but substantially similar housing structures would not alter the character, use, or historic context of adjacent properties. There appears to be a low probability of encountering prehistoric or historic period deposits that have not been extensively disturbed by previous construction and demolition activities and that have the potential to yield information important to the history or prehistory of Fort Wadsworth and Staten Island. In addition, the USCG will implement an IDP/UDP with an archeological monitoring program conducted by a qualified archeologist during ground-disturbing demolition and construction activities. For these reasons, the USCG has determined that the proposed undertaking would not have an adverse effect on historic properties listed or eligible for listing on the NRHP.

The USCG seeks your comment on its determination that the proposed undertaking would not adversely affect any historic property listed or eligible for listing on the National Register of Historic Places (NRHP). If you have any questions or would like additional information, please contact Ms. Karen Ladd at (510) 915-7695 or by email at Karen.Ladd@uscg.mil.

Sincerely, COMMANDER E. G. PARA

Commanding Officer Civil Engineering Unit Providence U.S. Coast Guard

Enclosures: (1) Gateway National Recreation Area map

(2) Notional Layout of Townhomes and Area of Potential Effect

(3) Photos of USCG housing complex, typical views

(4) Example Inadvertent Discovery Plan

PARA.ERIC.G.1011218918

2021.10.12 15:45:31 -04'00'

Enclosure 1. Gateway National Recreational Area Map

Enclosure 3. Photos of USCG Housing complex, typical views

Aerial view of Building 448 on USS Florida Court.

Aerial view of USS Iowa Circle.

View behind apartment buildings.

Greenspace and gazebo.

View of USS Florida Court.

INADVERTENT DISCOVERIES PLAN (IDP) /

UNANTICIPATED DISCOVERIES PLAN (UDP)

Demolition of Multifamily House at 442 USS Iowa Circle

Fort Wadsworth, Staten Island, Richmond County, New York

Prepared for

RENOVA ENVIRONMENTAL SERVICES, LLC

3417 SUNSET AVENUE

OCEAN TOWNSHIP, NJ 07712

Prepared by

TETRA TECH, INC.

6 CENTURY DRIVE, SUITE 300

PARSIPPANY, NJ 07054

February 2020

Demolition at 442 USS Iowa Circle, Staten Island, NY Inadvertent / Unanticipated Discoveries Plan (IDP/UDP) i

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 PROJECT BACKGROUND

1.2 POTENTIAL ARCHAEOLOGICAL RESOURCES

2.0 POLICIES, GUIDELINES, REGULATIONS AND LEGISLATION RELATED TO THE

INADVERTENT DISCOVERY OF CULTURAL RESOURCES AND HUMAN REMAINS

2.1 FEDERAL

2.2 NEW YORK

3.0 CONSULTATION WITH SHPOs AND NATIVE AMERICAN TRIBES

4.0 INADVERTENT DISCOVERY PROTOCOL

4.1 NOTIFICATION AND ASSESSMENT PROCEDURES (NOT INCLUDING HUMAN

REMAINS)

4.2 NOTIFICATION AND ASSESSMENT PROCEDURES (HUMAN REMAINS)

5.0 CONTACTS TABLE

1.0 INTRODUCTION

RENOVA Environmental, LLC (RENOVA), under contract to the United States Coast Guard (USCG), plans to demolish a fire-damaged building located at 442 USS Iowa Circle, Staten Island, New York 10305 (the Project). The building is located in the Fort Wadsworth Area of the Staten Island Unit of Gateway National Recreation Area (GATE), a unit of the National Park Service (NPS). In addition to demolition of the building above ground, the Area of Potential Effects (APE) also includes belowground areas affected by the removal of the foundation and subsurface utilities.

To ensure that RENOVA complies with applicable federal and state regulations concerning the protection of cultural resources, an Inadvertent Discoveries Plan (IDP, also known as an Unanticipated Discoveries Plan, UDP) has been prepared for the Project. The IDP provides protocols for the evaluation and disposition of cultural resources unexpectedly encountered during Project-related ground-disturbing activities. Cultural resources in this context are defined as archaeological sites, objects, and features, and include human remains and associated grave goods. This plan is developed on behalf of RENOVA and conforms to standards and guidelines established by the Secretary of the Interior, the New York Archaeological Council as adopted by the New York State Historic Preservation Office (SHPO), and the New York City Landmark Preservation Commission (LPC).

1.1 PROJECT BACKGROUND

The building at 442 USS Iowa Circle is south of the Verrazano Narrows Bridge I-278 approaches within the boundaries of the Fort Wadsworth Area of GATE. It is approximately 200 meters (660 feet) northwest of the present shoreline of Staten Island along New York Lower Bay, just below the entrance to the Narrows of New York Harbor.

Fort Wadsworth was transferred to NPS from its previous occupant, Naval Station New York, in 1994 as part of an action under the Department of Defense’s Base Realignment and Closure (BRAC) process. After the closure in 1996 of the USCG’s Atlantic Area headquarters and base on Governors Island in New York Harbor, their New York-based operations moved to Fort Wadsworth as tenants and occupied buildings and housing previously used by the Navy. Today, the portions of Fort Wadsworth tenanted by the USCG serve as the headquarters of Sector New York of USCG District 1 and, unlike the parts of Fort Wadsworth directly administered by NPS, are closed to public visitation.

The New York State Historic Preservation Office (NY-SHPO) determined in 1998 that the NPS’s Fort Wadsworth Area (SHPO No. 98NR01405) is eligible for the National Register of Historic Places (NRHP).

Fort Wadsworth is listed on the New York State Register of Historic Places (SRHP). Two elements of Fort Wadsworth to the north of Verrazano Narrows Bridge I-278 approaches, Battery Weed (NRIS No.

72000908 / SHPO No. 90NR01029) and Fort Tompkins Quadrangle (NRIS No. 74001300 / SHPO No.

90NR01013), are listed on the NRHP.

The building to be demolished is a three-story frame multi-family dwelling that is part of a USCG family housing complex built by the U.S. Navy in 1989. The building was severely damaged by fire on November 4, 2019. Review of SHPO’s online New York Cultural Resources Information System (NY-CRIS) suggests that in a consultation on or about December 20, 2019, the SHPO determined or concurred that the building, SHPO Unique Site Number (USN) 08501.002541, was a non-contributing element of the Fort Wadsworth historic district.

Review of NY-CRIS established that there are no recorded archaeological sites at 442 USS Iowa Circle.

Previous archaeological survey in the area identified two multicomponent sites in the immediate vicinity of the structure to be demolished. The Fountain-Mouquin House Historic and Prehistoric Site (USN 08501.000007) is located approximately 140 meters (460 feet) northeast of the structure and the Oude Dorp (Old Town)–Arrochar Site (USN 08501.000027) is located approximately 150 meters (500 feet) to the south.

Frederick R. Black’s A History of Fort Wadsworth, New York Harbor (Cultural Resource Management Study No. 7, North Atlantic Regional Office, NPS, 1983) shows that the land where 442 USS Iowa Circle stands was acquired by the War Department for an expansion of Fort Wadsworth in 1892 (Black 1983:106- 110). Historical U.S. Coast Survey (Coast Survey) navigation charts and U.S. Geologic Survey (USGS) quadrangle maps indicates that the vicinity of the APE was agricultural land in the nineteenth century, with scattered buildings arrayed primarily along roads and lanes. Beginning in the 1890s, the War Department constructed a series of shore batteries to protect the Narrows approach to New York Harbor as part nationwide modernization of coastal fortifications resulting from the War Department’s mid-1880s Endicott Board of Fortifications report and hurried along by the anxieties of the Spanish-American War.

The closest of these was Battery Ayers, situated approximately 40 to 90 meters (130 to 300 feet) north and northeast of the present location of 442 USS Iowa Circle. The battery, completed in 1901, mounted two 12-inch breechloading rifles on disappearing carriages. It was removed from service in 1942 (Black 1943:Table 2, 115).

Historical USGS quadrangle maps and aerial imagery from the USGS EarthExplorer website and Historicaerials.com suggest that the present location of the dwelling, situated almost immediately below Battery Ayers, was relatively undeveloped until the middle or late 1950s, when what appears to be family housing was erected in the area on a street running roughly parallel to the shoreline, which is approximately 200 meters (660 feet) to the southeast. The 1950s generation of housing was replaced in 1989 by the current set of dwellings, which are laid out in a comparatively dense garden apartment plan.

1.2 POTENTIAL ARCHAEOLOGICAL RESOURCES

The history of development of the land occupied by the building at 442 USS Iowa Circle indicates that at least one cycle of building construction and demolition preceded the present building and its neighbors. It is therefore anticipated that ground-disturbing demolition activities for removal of the building, its foundation, and utilities will occur largely in previously disturbed soils and that the potential for potentially significant archaeological deposits is relatively low. In this context, “potentially significant” refers to the possibility that an archaeological site possesses good integrity – i.e., relatively undisturbed deposits and spatial patterning reflecting the activities of people during an identifiable period of occupation – and meets Criterion D of the National Register of Historic Places (NRHP), having the “ability to yield important information about prehistory or history,” or, if appropriate, meets one or more of the other NRHP criteria (National Register Bulletin, Guidelines for Evaluating and Registering Archaeological Properties, which describes the application of NRHP criteria at Title 36 Code of Federal Regulations, Part 60 [36 CFR 60] to archaeological sites).

Based on the available historical background, the excavation and removal of the building’s foundation and underground utilities likely will yield chronologically, and functionally mixed secondary deposits and/or fill imported from elsewhere. Such deposits would typically contain a mix of fragmentary demolition debris (broken masonry, window glass, metal fasteners and hardware, etc.) and fragments of household domestic items, such as ceramics, and/or traces of prehistoric Native American occupation, such as flakes and other debris left from the manufacture and/or maintenance of stone tools, along with occasional complete stone tools. Fragmentary animal bones left from the consumption of meat might be present, though prehistoric period deposits would not include domestic animals and historic period deposits would likely be predominantly domestic animals like pig, sheep, cattle, and horse.

There appears to be a low probability of encountering prehistoric or historic period deposits that have not been extensively disturbed by previous construction and demolition activities and that have the potential to yield information important to the history or prehistory of Fort Wadsworth and Staten Island. Nonetheless, the relatively proximity of the Project location to two inventoried archaeological sites and to one of the Endicott period coastal artillery batteries suggests the unlikely possibility that intact, significant archaeological deposits might be present in the vicinity of the Project.

2.0 POLICIES, GUIDELINES, REGULATIONS AND LEGISLATION RELATED TO

THE INADVERTENT DISCOVERY OF CULTURAL RESOURCES AND HUMAN

REMAINS

This Plan will be followed in the event that cultural resources and/or human remains are encountered during construction of the Project. The stipulations of the Plan as set forth below are in accordance with the current guidelines detailed in the following federal and state guidelines, regulations and legislation:

2.1 FEDERAL

• Sections 106 and 110 of the National Historic Preservation Act (NHPA), as amended (54 United

States Code [USC] 306108 and 306101 et seq.)

• Section 6 of the Archaeological Resources Protection Act, as amended (16 USC 470ee)

• Secretary of the Interior’s Standards for Archaeology and Historic Preservation (48 FR 44716-42)

• Advisory Council for Historic Preservation (ACHP): Protection of Historic Properties (36 CFR

800, 2004)

• Advisory Council for Historic Preservation (ACHP): Policy Statement Regarding Treatment of

Burial Sites, Human Remains, and Funerary Objects (February 23, 2007)

• National Park Service (NPS), NPS-28: Cultural Resource Management Guideline (1998)

• National Park Service (NPS) Archeology Program, National Park Service Archeology Guide

(2006)

• U.S. Coast Guard (USCG): Commandant Instruction 5090.1 – U.S. Coast Guard Environmental

Planning Policy and Environmental Planning Implementing Procedures (2019)

2.2 NEW YORK

• The New York State Historic Preservation Act of 1980, Section 14.09 https://parks.ny.gov/shpo/environmental-review/state-regulations.aspx

• New York State Cemetery Board: Cemeteries and Crematories – Laws, Rules and Regulations...

https://www.dos.ny.gov/cmty/cemlaw.html

• New York Archaeological Council: Standards for Cultural Resource Investigations and the

Curation of Archaeological Collections in New York State (1994)

• New York Archaeological Council: Cultural Resource Standards Handbook: Guidance for

Understanding and Applying The New York State Standards for Cultural Resource Investigations (2000)

• New York Archaeological Council: Guidelines for the use of Archaeological Monitoring as an Alternative to Other Field Techniques (2002)

• New York State Historic Preservation Office (SHPO): Phase I Archaeological Report Format Requirements (2005)

• New York State Historic Preservation Office (SHPO): Human Remains Discovery Protocol (2018)

• New York State Historic Preservation Office in Consultation with the Indian Nations of New York State Indian Nation Areas of Interest (For Tribal Consultation Purposes ONLY) (2018) https://parks.ny.gov/shpo/environmental-review/documents/IndianNationAreasofInterest.pdf

• New York City Landmarks Preservation Commission Guidelines for Archaeological Work in New York City (2018)

3.0 CONSULTATION WITH SHPOs AND NATIVE AMERICAN TRIBES

To the extent required and authorized under scopes-of-work and other contractual instruments, RENOVA and its subcontractors will assist federal and state agencies in conducting consultations with Native American Tribes and other participating parties in conducting consultations concerning inadvertent archaeological finds and/or human remains discovered during ground disturbing activities as part of this Project. Responsibility for completing consultations, however, is the responsibility of the USCG as a federal agency tenant at Fort Wadsworth and NPS as the agency responsible for the federal property as a whole.

4.0 INADVERTENT DISCOVERY PROTOCOL

4.1 NOTIFICATION AND ASSESSMENT PROCEDURES (NOT INCLUDING

HUMAN REMAINS)

The following steps outline the protocols to be taken in the event an unanticipated discovery is made during Project demolition activities:

1. Work in the immediate vicinity of the discovery shall cease once an unanticipated discovery has been encountered.

2. The Site Supervisor shall be notified as soon as possible of the unanticipated discovery.

3. Flag or fence off the discovery location and take measures to ensure the security and integrity of the discovery without delay. Work in the area of the discovery shall not resume until the Site Supervisor grants clearance.

4. The Site Supervisor will promptly contact the RENOVA Project Manager (PM) and the Qualified Archaeological Monitor (Archaeologist).

5. If the Archaeologist determines that the find is not a potentially significant archaeological deposit, they will report the information to the Site Supervisor and the PM. The Site Supervisor will then grant clearance to the construction crews for work to resume at the location of the find.

6. If the Archaeologist determines that the find may a potentially significant archaeological deposit, the Archaeologist will inform the Site Supervisor and PM of this determination.

a. RENOVA shall, within 24 hours of the determination that the archaeological deposit may be significant, contact the USCG. If so directed, the Archaeologist may contact the USCG on behalf of RENOVA. Work shall not resume until authorized by the appropriate agencies.

b. Following consultation with the USCG, the Archaeologist will evaluate the discovery and assess its horizontal and vertical extent, cultural association(s), and degree of disturbance. RENOVA will ensure that the Archaeologist has full access to the discovery.

c. The Archaeologist will inform the Site Supervisor and the USCG of the findings and recommendations. If the finds are determined to not be significant, the PM and Archaeologist, after consultation with the USCG, will grant clearance to the construction team to resume work. If a determination of potential archaeological significance is made, RENOVA will develop an archaeological treatment plan which will be submitted to the USCG. If so directed, the Archaeologist may develop the plan on behalf of RENOVA

d. If the archaeologically significant discovery cannot be avoided by Project activities, RENOVA, in consultation with the USCG, shall authorize the archaeological investigators to implement the mitigation plan, in accordance with a task authorization.

e. At the conclusion of archaeological fieldwork, the Archaeologist will, in accordance with a task authorization, submit a report of the treatment results and recommendations to RENOVA. RENOVA will provide the report for review to the USCG.

f. Upon receiving written acceptance of the results of the implemented treatment from the USCG, the PM and Site Supervisor will grant clearance to the construction team to resume work in the vicinity of the find location.

4.2 NOTIFICATION AND ASSESSMENT PROCEDURES (HUMAN REMAINS)

Human remains are physical remains of a human body or bodies including, but not limited to, bones, teeth, hair, and preserved soft tissues (mummified or otherwise preserved) of an individual. Remains may be articulated or disarticulated bones or teeth. Intentionally interred remains may be accompanied by grave furniture such markers, coffins and traces of coffins, and shroud pins, as well as goods intentionally interred with the deceased. Disturbance of human remains, burial places and/or burial offerings and other grave furnishings without appropriate permits on federal property can be prosecuted as a felony.

The “Human Remains Discovery Protocol” of the NY-SHPO (2018) and Section D ("Burials and Human Remains: Detailed Discovery Procedures") of the New York City Landmark Preservation Commission's Guidelines for Archaeological Work in New York City (2018).

The following steps outline the protocols to be taken in the event an unanticipated discovery of human remains is made during ground-disturbing Project activities.

1. Cease activity at the location of the remains or where further remains may be reasonably thought to exist and for a distance of 15 meters (50 feet) around the find. Secure the location with flagging or fencing. Work will not resume in the area of the find until the Site Supervisor grants clearance to recommence.

2. Immediately notify the Site Supervisor and Archaeologist of the discovery that appears to be associated with human remains or an unmarked grave.

3. The Site Supervisor will contact the following parties on the day of the discovery:

a. RENOVA PM

b. USCG point of contact

c. U.S. Park Police

4. It is the responsibility of the Park Police to notify county coroner and the New York Police Department (NYPD) in accordance with their interagency agreements and obligations.

a. If it the discovery represents a crime scene, the Park Police will coordinate with the county coroner to determine jurisdiction.

b. If the location is not a crime scene, the responsible law enforcement will return jurisdiction to the USCG and consultation will begin to ensure that all provisions of the Native American Grave Protection and Repatriation Act and Section 106 of the National Historic Preservation Act are followed.

c. If the human remains are determined by the appropriate agency to be ineligible for inclusion in the NRHP, RENOVA will proceed with coordinating the proper removal of the remains through cooperation with the local police, the medical examiner, and the USCG. Only after the human remains have been properly removed from the site should demolition be resumed.

d. Under no circumstances should human remains be removed from the site without completing all coordination processes with the local police, the medical examiner, and the USCG. Further work at the site will be suspended until all criteria of Section 106 of the National Historic Preservation Act and other related state and federal regulations have been successfully completed.

5.0 CONTACTS TABLE

RENOVA

Site Supervisor To Be Determined Prior to Construction

Project Manager (PM) Kelly Giles Office: 732-945-5133 Cell: 732-513-4906 Email: kelly@renovaenviro.com

Project Archaeologist (PA) Adam Maskevich Office: 973-630-8346 Cell: 908-451-9838 Email: adam.maskevich@tetratech.com

U.S. COAST GUARD

USCG Project Manager Michael Obisanya Office: 401-736-1792 Cell: 401-871-8108 Email: michael.f.obisanya@uscg.mil

USCG FEDERAL PRESERVATION OFFICER (FPO)

Chief, Office of Environmental Management Commandant (CG-47) Brendan Deyo U.S. Coast Guard - Stop 7714 2703 Martin Luther King Jr. Avenue SE Washington, D.C. 20593-7714 Office: 202-372-1821 Email: brendan.deyo@uscg.mil

LAW ENFORCEMENT

United States Park Police - Jamaica Bay and Staten Island Units 210 New York Ave Staten Island, NY 10305 718-338-3988 718-354-4600

NYPD, 122nd Precinct Staten Island (Richmond County) 2320 Hylan Blvd.

New Dorp, NY, 10306-3207 718-667-2211

NYC Office of the Chief Medical Examiner, Seaview Hospital Campus (Staten Island) 460 Brielle Avenue Staten Island, NY 10314 212-447-2030 (ask for the Forensic Anthropology Unit)

HISTORIC PRESERVATION OFFICE CONTACTS

NEW YORK STATE HISTORIC PRESERVATION OFFICE

(SHPO)

Contact for Richmond County: Linda Mackey Office: 518-268-2148 Email: Linda.Mackey@parks.ny.gov

NEW YORK CITY LANDMARKS PRESERVATION

COMMISSION (LPC)

David N. Dinkins Municipal Building 1 Centre Street, 9th Floor North New York, NY 10007 212-669-7855

INADVERTENT DISCOVERIES PLAN (IDP) /

UNANTICIPATED DISCOVERIES PLAN (UDP)

Demolition of Multifamily House at 442 USS Iowa Circle

Fort Wadsworth, Staten Island, Richmond County, New York

Prepared for

RENOVA ENVIRONMENTAL SERVICES, LLC

3417 SUNSET AVENUE

OCEAN TOWNSHIP, NJ 07712

Prepared by

TETRA TECH, INC.

6 CENTURY DRIVE, SUITE 300

PARSIPPANY, NJ 07054

February 2020 i

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 PROJECT BACKGROUND

1.2 POTENTIAL ARCHAEOLOGICAL RESOURCES

2.0 POLICIES, GUIDELINES, REGULATIONS AND LEGISLATION RELATED TO THE

INADVERTENT DISCOVERY OF CULTURAL RESOURCES AND HUMAN REMAINS

2.1 FEDERAL

2.2 NEW YORK

3.0 CONSULTATION WITH SHPOs AND NATIVE AMERICAN TRIBES

4.0 INADVERTENT DISCOVERY PROTOCOL

4.1 NOTIFICATION AND ASSESSMENT PROCEDURES (NOT INCLUDING HUMAN

REMAINS)

4.2 NOTIFICATION AND ASSESSMENT PROCEDURES (HUMAN REMAINS)

5.0 CONTACTS TABLE

1.0 INTRODUCTION

RENOVA Environmental, LLC (RENOVA), under contract to the United States Coast Guard (USCG), plans to demolish a fire-damaged building located at 442 USS Iowa Circle, Staten Island, New York 10305 (the Project). The building is located in the Fort Wadsworth Area of the Staten Island Unit of Gateway National Recreation Area (GATE), a unit of the National Park Service (NPS). In addition to demolition of the building above ground, the Area of Potential Effects (APE) also includes belowground areas affected by the removal of the foundation and subsurface utilities.

To ensure that RENOVA complies with applicable federal and state regulations concerning the protection of cultural resources, an Inadvertent Discoveries Plan (IDP, also known as an Unanticipated Discoveries Plan, UDP) has been prepared for the Project. The IDP provides protocols for the evaluation and disposition of cultural resources unexpectedly encountered during Project-related ground-disturbing activities. Cultural resources in this context are defined as archaeological sites, objects, and features, and include human remains and associated grave goods. This plan is developed on behalf of RENOVA and conforms to standards and guidelines established by the Secretary of the Interior, the New York Archaeological Council as adopted by the New York State Historic Preservation Office (SHPO), and the New York City Landmark Preservation Commission (LPC).

1.1 PROJECT BACKGROUND

The building at 442 USS Iowa Circle is south of the Verrazano Narrows Bridge I-278 approaches within the boundaries of the Fort Wadsworth Area of GATE. It is approximately 200 meters (660 feet) northwest of the present shoreline of Staten Island along New York Lower Bay, just below the entrance to the Narrows of New York Harbor.

Fort Wadsworth was transferred to NPS from its previous occupant, Naval Station New York, in 1994 as part of an action under the Department of Defense’s Base Realignment and Closure (BRAC) process. After the closure in 1996 of the USCG’s Atlantic Area headquarters and base on Governors Island in New York Harbor, their New York-based operations moved to Fort Wadsworth as tenants and occupied buildings and housing previously used by the Navy. Today, the portions of Fort Wadsworth tenanted by the USCG serve as the headquarters of Sector New York of USCG District 1 and, unlike the parts of Fort Wadsworth directly administered by NPS, are closed to public visitation.

The New York State Historic Preservation Office (NY-SHPO) determined in 1998 that the NPS’s Fort Wadsworth Area (SHPO No. 98NR01405) is eligible for the National Register of Historic Places (NRHP).

Fort Wadsworth is listed on the New York State Register of Historic Places (SRHP). Two elements of Fort Wadsworth to the north of Verrazano Narrows Bridge I-278 approaches, Battery Weed (NRIS No.

72000908 / SHPO No. 90NR01029) and Fort Tompkins Quadrangle (NRIS No. 74001300 / SHPO No.

90NR01013), are listed on the NRHP.

The building to be demolished is a three-story frame multi-family dwelling that is part of a USCG family housing complex built by the U.S. Navy in 1989. The building was severely damaged by fire on November 4, 2019. Review of SHPO’s online New York Cultural Resources Information System (NY-CRIS) suggests that in a consultation on or about December 20, 2019, the SHPO determined or concurred that the building, SHPO Unique Site Number (USN) 08501.002541, was a non-contributing element of the Fort Wadsworth historic district.

Review of NY-CRIS established that there are no recorded archaeological sites at 442 USS Iowa Circle.

Previous archaeological survey in the area identified two multicomponent sites in the immediate vicinity of the structure to be demolished. The Fountain-Mouquin House Historic and Prehistoric Site (USN 08501.000007) is located approximately 140 meters (460 feet) northeast of the structure and the Oude Dorp (Old Town)–Arrochar Site (USN 08501.000027) is located approximately 150 meters (500 feet) to the south.

Frederick R. Black’s A History of Fort Wadsworth, New York Harbor (Cultural Resource Management Study No. 7, North Atlantic Regional Office, NPS, 1983) shows that the land where 442 USS Iowa Circle stands was acquired by the War Department for an expansion of Fort Wadsworth in 1892 (Black 1983:106- 110). Historical U.S. Coast Survey (Coast Survey) navigation charts and U.S. Geologic Survey (USGS) quadrangle maps indicates that the vicinity of the APE was agricultural land in the nineteenth century, with scattered buildings arrayed primarily along roads and lanes. Beginning in the 1890s, the War Department constructed a series of shore batteries to protect the Narrows approach to New York Harbor as part nationwide modernization of coastal fortifications resulting from the War Department’s mid-1880s Endicott Board of Fortifications report and hurried along by the anxieties of the Spanish-American War.

The closest of these was Battery Ayers, situated approximately 40 to 90 meters (130 to 300 feet) north and northeast of the present location of 442 USS Iowa Circle. The battery, completed in 1901, mounted two 12-inch breechloading rifles on disappearing carriages. It was removed from service in 1942 (Black 1943:Table 2, 115).

Historical USGS quadrangle maps and aerial imagery from the USGS EarthExplorer website and Historicaerials.com suggest that the present location of the dwelling, situated almost immediately below Battery Ayers, was relatively undeveloped until the middle or late 1950s, when what appears to be family housing was erected in the area on a street running roughly parallel to the shoreline, which is approximately 200 meters (660 feet) to the southeast. The 1950s generation of housing was replaced in 1989 by the current set of dwellings, which are laid out in a comparatively dense garden apartment plan.

1.2 POTENTIAL ARCHAEOLOGICAL RESOURCES

The history of development of the land occupied by the building at 442 USS Iowa Circle indicates that at least one cycle of building construction and demolition preceded the present building and its neighbors. It is therefore anticipated that ground-disturbing demolition activities for removal of the building, its foundation, and utilities will occur largely in previously disturbed soils and that the potential for potentially significant archaeological deposits is relatively low. In this context, “potentially significant” refers to the possibility that an archaeological site possesses good integrity – i.e., relatively undisturbed deposits and spatial patterning reflecting the activities of people during an identifiable period of occupation – and meets Criterion D of the National Register of Historic Places (NRHP), having the “ability to yield important information about prehistory or history,” or, if appropriate, meets one or more of the other NRHP criteria (National Register Bulletin, Guidelines for Evaluating and Registering Archaeological Properties, which describes the application of NRHP criteria at Title 36 Code of Federal Regulations, Part 60 [36 CFR 60] to archaeological sites).

Based on the available historical background, the excavation and removal of the building’s foundation and underground utilities likely will yield chronologically, and functionally mixed secondary deposits and/or fill imported from elsewhere. Such deposits would typically contain a mix of fragmentary demolition debris (broken masonry, window glass, metal fasteners and hardware, etc.) and fragments of household domestic items, such as ceramics, and/or traces of prehistoric Native American occupation, such as flakes and other debris left from the manufacture and/or maintenance of stone tools, along with occasional complete stone tools. Fragmentary animal bones left from the consumption of meat might be present, though prehistoric period deposits would not include domestic animals and historic period deposits would likely be predominantly domestic animals like pig, sheep, cattle, and horse.

There appears to be a low probability of encountering prehistoric or historic period deposits that have not been extensively disturbed by previous construction and demolition activities and that have the potential to yield information important to the history or prehistory of Fort Wadsworth and Staten Island. Nonetheless, the relatively proximity of the Project location to two inventoried archaeological sites and to one of the Endicott period coastal artillery batteries suggests the unlikely possibility that intact, significant archaeological deposits might be present in the vicinity of the Project.

2.0 POLICIES, GUIDELINES, REGULATIONS AND LEGISLATION RELATED TO

THE INADVERTENT DISCOVERY OF CULTURAL RESOURCES AND HUMAN

REMAINS

This Plan will be followed in the event that cultural resources and/or human remains are encountered during construction of the Project. The stipulations of the Plan as set forth below are in accordance with the current guidelines detailed in the following federal and state guidelines, regulations and legislation:

2.1 FEDERAL

• Sections 106 and 110 of the National Historic Preservation Act (NHPA), as amended (54 United

States Code [USC] 306108 and 306101 et seq.)

• Section 6 of the Archaeological Resources Protection Act, as amended (16 USC 470ee)

• Secretary of the Interior’s Standards for Archaeology and Historic Preservation (48 FR 44716-42)

• Advisory Council for Historic Preservation (ACHP): Protection of Historic Properties (36 CFR

800, 2004)

• Advisory Council for Historic Preservation (ACHP): Policy Statement Regarding Treatment of

Burial Sites, Human Remains, and Funerary Objects (February 23, 2007)

• National Park Service (NPS), NPS-28: Cultural Resource Management Guideline (1998)

• National Park Service (NPS) Archeology Program, National Park Service Archeology Guide

(2006)

• U.S. Coast Guard (USCG): Commandant Instruction 5090.1 – U.S. Coast Guard Environmental

Planning Policy and Environmental Planning Implementing Procedures (2019)

2.2 NEW YORK

• The New York State Historic Preservation Act of 1980, Section 14.09 https://parks.ny.gov/shpo/environmental-review/state-regulations.aspx

• New York State Cemetery Board: Cemeteries and Crematories – Laws, Rules and Regulations...

https://www.dos.ny.gov/cmty/cemlaw.html

• New York Archaeological Council: Standards for Cultural Resource Investigations and the

Curation of Archaeological Collections in New York State (1994)

• New York Archaeological Council: Cultural Resource Standards Handbook: Guidance for

Understanding and Applying The New York State Standards for Cultural Resource Investigations (2000)

• New York Archaeological Council: Guidelines for the use of Archaeological Monitoring as an Alternative to Other Field Techniques (2002)

• New York State Historic Preservation Office (SHPO): Phase I Archaeological Report Format Requirements (2005)

• New York State Historic Preservation Office (SHPO): Human Remains Discovery Protocol (2018)

• New York State Historic Preservation Office in Consultation with the Indian Nations of New York State Indian Nation Areas of Interest (For Tribal Consultation Purposes ONLY) (2018) https://parks.ny.gov/shpo/environmental-review/documents/IndianNationAreasofInterest.pdf

• New York City Landmarks Preservation Commission Guidelines for Archaeological Work in New York City (2018)

3.0 CONSULTATION WITH SHPOs AND NATIVE AMERICAN TRIBES

To the extent required and authorized under scopes-of-work and other contractual instruments, RENOVA and its subcontractors will assist federal and state agencies in conducting consultations with Native American Tribes and other participating parties in conducting consultations concerning inadvertent archaeological finds and/or human remains discovered during ground disturbing activities as part of this Project. Responsibility for completing consultations, however, is the responsibility of the USCG as a federal agency tenant at Fort Wadsworth and NPS as the agency responsible for the federal property as a whole.

4.0 INADVERTENT DISCOVERY PROTOCOL

4.1 NOTIFICATION AND ASSESSMENT PROCEDURES (NOT INCLUDING

HUMAN REMAINS)

The following steps outline the protocols to be taken in the event an unanticipated discovery is made during Project demolition activities:

1. Work in the immediate vicinity of the discovery shall cease once an unanticipated discovery has been encountered.

2. The Site Supervisor shall be notified as soon as possible of the unanticipated discovery.

3. Flag or fence off the discovery location and take measures to ensure the…