State Historic Preservation Office Comments about EIS State of New Jersey
Department of Environmental Protection
Division of Parks & Forestry, Historic Preservation Office
PO Box 404, Trenton, NJ 08625
TEL: (609) 292-2023 FAX: (609) 084-0578
www.state.nj.us/dep/hpo
HPO-C2003-013 PROD
March 3, 2003
Log # 03-0817-1Mr. Jack McQuillan
Manager
Bureau of Evironmental Services
New Jersey Department of Transportation
1035 Parkway Avenue
Post Office Box 600
Trenton, New Jersey 08625-0600Dear Mr. McQuillan:
As Deputy State Historic Preservation Officer for New Jersey, in accordance with 36 CFR Part 800: Protection of Historic Properties, as published in the Federal Register on 12 December 2000 (65 FR 77725-77739), I am providing continuing consultation comments for the following federally funded proposed undertaking:
US Route 1, Sections 2S and 3J
Penns Neck Ares Environmental Impact Statement (ElS)
(previously Millstone By-Pass Environmental Assessment)
West Windsor Township, Mercer County and
Plainsboro Township, Middlesex County.These comments are in response to your letter requesting review of and comments on the Penns Neck Area EIS Cultural Resources Effects Document (dated December 2002), received at the Historic Preservation Office (HPO) on January 10, 2003. The HPO has also reviewed the Summary of Potential impacts to the Built Environment - Cultural Resources memorandum (dated January 23, 2003) that was distributed to the Penns Neck Area EIS Partners' Roundtable. The Penns Neck Area EIS Draft Historic Architectural Survey (2 volumes, revised draft report, August 2002) and Phase I Archaeological Survey (2 volumes, revised draft report, August 2002) included HPO comment letter HPO-H98-1, August 5, 1998, but did not include HPO-C97-9, March 10, 1997 and HPO-B2000-72, February 16, 2000. These letters responded to the earlier effects assessment for the following historic properties: Penns Neck [Baptist] Church, Penns Neck Cemetery, Washington Road Elm Alleé, Covenhoven-Silvers-Logan House (31 Logan Drive), Princeton Operating Station AT&T Building (Eden Institute), Aqueduct Mills Historic District and Historic District Extension, Delaware and Raritan Canal Historic District, Lake Carnegie Historic District, and three (3) archaeological sites (28 ME 2, 23, and 86).
The identification of additional historic properties (Pennsylvania Railroad Historic District [including contributing resources Princeton Junction Hotel, County Route 571 Bridge, and Nassau Interlocking Tower], Pennsylvania Railroad [NJ Transit] Bridge over the Delaware& Raritan Canal, David S. Voorhees House, David Sarnoff Research Center 13740 7Brurnswick Pike [US Route 1], and 1 archaeological site [28 ME 912]) and the revised delineation of a number alignments and project components necessitate the reconsideration of the previous assessment of effects.
The HPO appreciates graphic presentation of two (2) perspectives on adverse effects, first, adverse effects to individual historic resources by individual alternatives A through G.2 (table Possible Adverse Effects on National Register Listed and Eligible Historic Architectural Resources) and, second, adverse effects by proposed project component (table Adverse Effects to National Register Eligible or Listed Properties by Major Design Components), as well as the table Major Design Components of the Action Alternatives.
Alternative Alignments A through G2
The submitted effects assessment states end the table Effects on Historic Architectural Resources acknowledges that modification (expansion) of Route 1 and/or the replacement of the Route 1 bridge over the Millstone River, a feature of all currently delineated alignments (A - G.2), will have an adverse effect on the Aqueduct Mills Historic District / Historic District Extension. This anticipated adverse effect is the result of the proposed removal of a stone wall located along the west side of Route l. The widening of Route 1 ant the replacement of the Route 1 bridge over the Millstone River may occur even if a No Build (No Action) alternative is selected.
The submitted effects assessment states and the table Effects on Historic Architectural Resources acknowledges that neither the No Build (No Action) Alternative nor Alternative G.2 would cause adverse effects through the demolition or physical alteration of other historic properties. I agree with this conclusion. I also agree with the conclusions presented in the effects assessment and the table Effects on Historic Architectural Resources that adverse effects arising from the demolition or physical alteration of the following historic properties will be generated by the following alternatives as currently delineated:
Alternative A, A.l, A.2, A.3, A.4 (adverse effects to 7 additional historic resources)
Covenhoven-Logan-Silvers Home, Princeton Operating Station, and Pennsylvania Railroad Historic District (contributing resources) and 4 archaeological resources (28 ME 2, 23' 86, and 291)Alternative B (adverse effects to 6 additional historic resources)
Covenhoven-Logan-Silvers House, Princeton Operating Station, and Washington Road Elm Alleé and 3 archaeological resources (28 ME 2, 23, and 86)Alternative B.1, B.2 (adverse effects to 8 additional historic resources)
Covenhoven-Logan-Silvers House, Princeton Operating Station, Washington Road Elm Allee, and Pennsylvania Railroad Historic District (contributing resources) and 4 archaeological resources (28 MB 2, 23, 86, and 291)Alternative C.1 (adverse effects to 4 additional historic resources)
Princeton Operating Station, Washington Road Elm Allee, and Pennsylvania Railroad Historic District (contributing resources) and 2 archaeological resources (28 ME 2 and 291)Alternative C.1 (adverse effects to 4 additional historic resources)
Princeton Operating Station and Pennsylvania Railroad Historic District (contributing resources) and 2 archaeological resources (28 ME ~ and 291)Alternative D, D.1 (adverse effects to 4 additional historic resources)
Pennsylvania Railroad Historic District (contributing resources) and 4 archaeological resources (28 ME 2, 23, 86, and 291)Alternative E adverse effects to 4 additional historic resources)
Pennsylvania Railroad Historic District (contributing resources) and 3 archaeological resources (28 ME 23, 86, and 291)Alternative F, F.1 (adverse effects to 6 a additional historic resources)
Princeton Operating Station and Pennsylvania Railroad Historic District (contributing resources) and 4 archaeological resources (28 ME 2, 23, 86, and 291)Alternative G (adverse effects to 2 additional historic resources)
Pennsylvania Railroad Historic District (contributing resources) and 1 archaeological resource (28 ME 291)Alternative G.1 (adverse effects to 3 additional historic resources)
Washington Road Elm Allee and Pennsylvania Railroad Historic District (contributing resources) and I archaeological resource (28 ME 291)East-Site Connector Alignments
The table Adverse Effects by Design Components indicates that all east-side connector alignments will have adverse effects to historic properties, primarily archaeological historic properties. I agree with this conclusion. The revised regulations implementing Section 106 of the National Historic Preservation Act, (65 FR 65 77725-77739, December 12, 2000) classify the disturbance of an archaeological site as an adverse effect This change in the regulations applies to the no adverse effect with data recovery assessment previously given to archaeological sites 28 ME 2, 23, and 86 that are within the path of some proposed east-side connector road alignments.
The effect of an east-side connector road on the David Samoff Research Center (3740 Brunswick Pike [US Route 1]) remains to be evaluated.
West-Side Connector Alignments
I agree with the assessment that the west-side connector alignments will not adversely affect the historic character of the ~ Carnegie Historic District. Correspondingly, all three (3) west-side connector alignments (B, B.1, and B.2) would have an adverse effect upon the Washington Road Elm Allee.
Previous HPO comments respectfully disagreed with the assessment that the proposed west-side connector road would have no adverse effect upon the Delaware and Raritan Canal Historic District: (D&R Canal). Currently alternatives B, B. I, and B.2 propose a west-side connector road between Route1/Harrison Street ant Washington Road. The west-side connector road in B and B.1 is closest to the D&R Canal and the west-side connector road in B.2 is approximately 1,000 feet east of the D&R Canal. Consistent with previously issued HPO comments, construction of a west-site connector road as delineated in both Alternatives B and B.1 would substantially change the character of physical features within a portion of the D&R Canal's setting and would introduce visual, atmospheric, and audible elements that diminish the integrity of significant historic features in this portion of the D&R Canal.
The introduction of a west-side connector roadway along alignment B or B.1 would result in a significant change in the character of the D&R Canal in the area between Washington Road and Harrison Street. The area to the east of the D&R Canal between Washington Road on the south and Harrison Street on the north has historically been undeveloped ant lightly vegetated with no substantial roadway features. Currently, the land to the east of the D&R Canal is undeveloped open space wed primarily for recreation and for the storage of cut wood, stone, and recycled construction material. A narrow paved driveway provides limited access to the area.
The roadway proposed by alternatives B and B.1 would introduce visual, atmospheric, ant audible elements that diminish the integrity of this particular portion of the D&R Canal. The Federal Highway Administration (FHWA) noise impact criteria assist in understanding the magnitude of potential noise impacts but do not establish a decibel level threshold for determining an adverse effect pursuant to 36 CFR Part 800, Protection of Historic Properties.
Currently some noise is transmitted up and down the D&R Canal as vehicles make a perpendicular crossing of the D&R Canal at Washington Road and Harrison Street. No significant noise source abuts or parallels the D&R Canal to either the east or west between these two perpendicular road crossings. The introduction of a roadway, with a 40 mile per hour design speed, abutting and parallel to this section of the D&R Canal would substantially expand the noise paths, currently limited to the perpendicular crossings at Washington Road and Harrison Street, to the length of this section of the D&R Canal, despite the presence of some natural and possibly engineered noise attenuators.
Previous HPO comments also noted that the introduction of berms and supplemental
vegetation to screen the roadway and dampen roadway noise represented 1 one approach to mitigating adverse visual and audible effects, however, these comments also noted that the berms and supplemental vegetation would not preclude these adverse effects to this portion of the Canal Historic District. I recognize that immediately north of Washington Road a large earthen berm rises on the eastern side of the D&:R Canal and would separate a segment of the proposed roadway from the Historic District. However, beading north from Washington Road the land east of the Historic District flattens and, beginning approximately 1,400 feet north of Washington Road, is level with the D&R Canal. This is also where the proposed roadway would be closest to 1he Historic District. Here, project plans originally called for the construction of an earthen berm and the planting of supplemental vegetation to visually screen the roadway from the D&R Canal and dampen the roadway noise. Consequently, the proposed roadway would substantially alter the physical and visual setting of this portion of the Historic District and represent the introduction of visual elements not currently or previously present. This segment of the D&R Canal has been devoid of development or transportation infrastructure since the removal of the Camden and Amboy Branch Railroad from the eastern berm in the 1860s.Vaughn Drive Connector Road
The submitted materials indicate that of the three (3) currently delineated Vaughn Drive connector road alignments, alignment number 2 will not affect any historic properties, number 1 may possibly adversely affect 1 or 2 historic properties (Princeton Junction Hotel of the Pennsylvania Railroad Historic Dis1rict sad David S. Voorhees House), and number 3 may possibly adversely affect 1 archaeological history property (28 ME 291). I agree with this assessment.
Route 1 In a Cut
The submitted effects assessment states that the impacts to the Penns Neck [Baptist] Church arising from the depression of Route 1 in a cut would be temporary. I agree that, with conditions, depressing Route 1 in a cut would have no adverse effect on the Penns Neck [Baptist] Church and would, as noted in the effects assessment, result in a long term improvement to the physical environment in proximity to this historic property.
Route 1 at Grade
The submitted effects assessment states that the only effect associated with widening Route 1 at grade (as per the preliminary geometry plans included with the effects assessment) would be the removal of a stone wall within the Aqueduct Mills Historic District. I agree conclusion.
Eastern Frontage Road
Although an eastern frontage road might require the acquisition of property within the David Sarnoff Research Center, I agree that the retention of a substantial landscape buffer between Route 1 and the Samoff Research Center buildings would permit a no adverse effect or possibly even a no effect determination.
Western Frontage Road
The submitted effects assessment states that a western frontage road would not adversely affect any historic properties. With continued access to Washington Road and an alignment that avoided disturbing the Washington Road Elm Allee, I agree that a western frontage road could avoid adversely affecting historic properties.
Loop-Type Interchange at Harrison
The submitted effects assessment states that a loop-type interchange in the vicinity of Harrison Street would adversely affect archaeological site 28 ME 2, Covenhoven-Logan-Silvers Home, and Princeton Operating Station. I agree with this conclusion.
Diamond Interchange at Harrison
The submitted effects assessment states that a diamond interchange in the vicinity of Harrison Street would adversely effect archaeological site 28 ME 2 and Princeton Operating Station. I agree with this conclusion.
Archaeological Resources
Public comments, received at the HPO and expressed at the meetings of the Penns Neck Area EIS Partners' Roundtable have questioned the adequacy of the evaluation of archaeological resources. These comments have focused upon the potential for an archaeological historic district encompassing as contributing resources both the archaeological resources evaluated as individually eligible for the National Register of Historic Places (NRHP) and some of the archaeological sites discovered but not evaluated (such as 28 ME 185, 284, 91, 201, 60, 283, 282, 186, 181, 55, 190, and 28 MI 129, 136). Given the large number of archaeological sites within the immediate APE and larger Study Area, the potential for an archaeological historic district that includes as contributing resources individual sites currently unevaluated or evaluated as not individually eligible for inclusion in the NRHP must be seriously explored. This consideration of an archaeological historic district is especially important for Site 28 ME 264 within the right of way of the proposed west-side connector road associated with Alternative B, B.1, and B.2.
Additionally, recognizing both the quantity and quality of the currently identified archaeological resources (including those within the APE but outside of currently delineated alignments), cultural resources section of the pending Draft Environmental Impact Statement (DEIS) must give serious consideration to the merits of in situ preservation of NRH, eligible archaeological sites. A serious discussion of the merits of both in situ preservation and data recovery must be presented in the DEIS. Again, this is especially important for archaeological sites, located in proximity to the environmentally important Millstone River, that may be adversely affected by an east-side connector road.
Additional Comments
Section 800.5(a)(1), Assessment of Adverse Effects, defines adverse effect as altering "directly or indirectly, any of the characteristics of a historic property that qualify the property for inclusion in the National Register in a manner that would diminish the integrity of the property's location, design, setting, materials, workmanship, feeling or association.Adverse effects may inc1ude reasonab1y foreseeable effects caused by the undertaking that may occur later in time, be farther removed in distance or be cumulative.'' The Council on Environmenta1 Quality regulations define cumulative effects as "the impactwhich results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such actions." United States Department of Transportation guidance notes that indirect, secondary, and cumulative impact assessment is especially appropriate in areas of moderate to rapid development and when the stated purpose of a transportation project is to enhance economic development.
The number, quality, and diversity of the archaeological and architectural historic properties within the EIS Area of Potential Effects (APE) makes the effort to anticipate and examine indirect, secondary, and cumulative effects particularly important.
Although HPO looks forward to the pubic distribution of the DEIS as the formal opportunity to comprehensively evaluate and comment on the relationships among historic properties, environmental resources, transportation needs, and proposed project alternatives, the submitted effects assessment clearly suggests that the avoidance or minimization of adverse effects to historic architectural or archaeological properties, consistent with the goal of eliminating at grade intersections and traffic signals, substantially enhancing the capacity of Route 1, and minimizing east-west traffic volumes on Washington Road and Fisher Place in West Windsor should focus on:
1 Avoiding adverse effects to The Delaware and Raritan Canal Historic District and
Washington Road Elm Allee by eliminating the proposed west-side connector road2 Avoiding adverse effects to archaeological sites 28 ME 2, 23, and 86 by eliminating the proposed east-side connector road
3 Providing enhanced east-west access to Route 1 by constructing a Vaughn Drive connector road (possibly along the no historic properties affected alignment G.2) that permits and encourages the use of the existing multiple lane Alexander Road grade separated interchange (The application of traffic calming techniques to Washington Road and Fisher Place in conjunction with this alternative would further encourage the diversion of east-west traffic from these roads to the already multi-lane Alexander Road grade separated interchange. This alternative might also provide a viab1e opportunity for diverting some traffic from Alexander Road east of the Northeast Corridor (NEC) Railroad once a new Alexander Road bridge over the NEC is built.)
4 Avoiding adverse effects to historic properties in the vicinity of Harrison Street by using frontage road access to Route 1 and avoiding a loop interchanges in this area.
5 Maintaining Washington Road access to Princeton and West Windsor and substantially improving the environment of the National Register of Historic Places listed Penns Neck [Baptist] Church (despite any temporary construction impacts associated with this project component), by depressing Route 1 in a cut, creating a grade separated Washington Road crossing, and using frontage roads for access to 1ocal streets.
Because these five (5) strategies focus on avoiding adverse effects to historic properties
and satisfying all presently identified project needs, they have the added benefit of being compatible with the United States Department of Transportation Act Section 4F requirements to develop prudent and feasible alternatives that avoid the taking of historic properties.The Washington Road Elm Allee, Penns Neck [Baptist] Church, and Aqueduct Mills Historic District are listed on the New Jersey Register of Historic Places, therefore, the effects of the preferred or chosen alignments) on these historic resources will, eventually need to be assessed and reviewed in accordance with the New Jersey Register of Historic Places Act.
I look forward to continuing consultation as the EIS data is refined and the public comments are compiled and integrated into the EIS. If you have questions concerning this project review, please call HPO Transportation and Planning Coordinator Charles Scott at 609-633-2396 and/or HPO staff Mike Gregg for archaeology at 609-633-2395.
Sincerely,
Dorothy P. Guzzo
Deputy State Historic
Preservation Officer
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