September 14, 2007
Department of Environmental Protection
Natural and Historic Resources
Historic Preservation Office
Trenton, NJ 08625-0404
RE: Phase II Archaeological Excavations, Work Plan and Research
Phase III Archaeological Data Recovery and Archaeological Monitoring at Thompson Park Historic Site
Monroe Township, Middlesex County, New Jersey
Dear Ms. Guzzo:
Thank you for the opportunity to examine Richard Grubb & Associate's, Inc.
recently submitted Draft report for
the Phase II Archaeological Excavations,
Work Plan and Research Design Phase III Archaeological Data Recovery and
Monitoring at Thompson Park Historic Site (28-Mi-243) Monroe Township, Middlesex County, New Jersey. Once again I would
like to point out that from a historic standpoint, the site of the Bethel Mission Settlement is of national significance and,
if it is expressed in any way archaeologically, would be among New Jersey's greatest archaeological treasures. Therefore,
as the president of the Archaeological Society of New Jersey I continue to watch with increased interest the debate concerning
the selection of the location for the proposed Monroe Township High School and I am even more excited by the results of the
recently completed Phase II Archaeological Investigations of the site undertaken.
Based on the findings presented in the above referenced report, it does appear that Richard Grubb & Associates have
located archaeological resources
on the site related to the Bethel Mission site. Although the exact nature of these
resources is unclear to researchers at Richard Grubb & Associates, I have no doubt the features and artifacts found during
the Phase II excavation have an association with the inhabitants of the Bethel Community. The numbers of artifacts identified
during the Phase II investigations are exactly what one would expect to see as evidence of a rudimentary mid-18th-century
community of scattered houses like the forty homes that are said to have been constructed by Native Americans at Bethel. The
number of artifacts found is substantial given the limited testing strategy that was employed. The artifacts exhibit
a range for the site which corresponds to the Bethel Mission Settlement.
I continue to be baffled that Richard Grubb & Associates, Inc. has not
fully recognized the importance
of what they have found and have continue to publicly dismiss any association with the Bethel Mission Settlement.
The following is a review of the Draft submission and HPO's comments on the
Comments on the Phase II Summary, Work Plan and Research Design Phase III
Archaeological Data Recovery and Archaeological
Monitoring at Thompson Park Historic Site (28-Mi-243)
1. Page 3 "Although a prehistoric Native American
artifacts were located during Phase I testing in Cluster B, no Native American artifacts were located within Clusters A and
B during Phase II testing". The level of testing in areas A (2 EUs) and B (6 EUs) is hardly an adequate sample
given clusters C and D consisted of eight and 27 EUs, more than a three to one difference. Given Prehistoric artifacts
were found in Cluster B during the Phase I suggest there may be more.
2. Page 3 Cluster A ".two eighteenth century artifacts: a wrought nail and a fragment of white slip decorated stoneware."
Is the "white slip decorated stoneware" white salt glazed stoneware?
3. No mention is made of the fossil shark tooth found in the plowzone from shovel test N1150 E1775. Given the current
thread of discussion concerning fossil remains found with Native American features this could be an important find.
Two other fossilized shark teeth and a piece of fossilized piece of coral were also recovered from the plowzone above the
two large features (7 and 10) in Cluster D. No Excavation Units were open in the area around N1150 E1775. The
nearest unit was located 75 feet away to the west.
4. Page 4 Cluster B within this cluster "two musket balls, a sleigh bell small brass possible hand bell rim fragment"
were found during the Phase I. They downplayed as "could not be dated and was considered not diagnostic of a specific
period of occupation". I beg to differ with this interpretation. Musket balls are not normally associated with
the later periods. The "sleigh bell" is more likely a hawk or a rumbler bell which have been found on Cherokee sites
dating to the same time period in Tennessee, where they have been found with Native American burials. The "hand bell"
is also typical of the type identified as a farm bell (also associated with a burial) at the Chota-Tanasee site in Tennessee.
Six widely spaced (between 25 and 100 feet apart) excavation units is hardly enough to write off an area measuring 230 by
5. Page 5 Cluster C Why were no units assigned to the look at the 18th century artifacts found during the Phase I at
N1700 E2550? The truncated trash or storage pit (Feature 2) is likely associated with other features in this area.
6. Page 6 Cluster C "Given the limited materials from this area and the lack of features, the western site limits are
likely to be no further west than the N2450 line." What about the sherds of redware found in shovel tests west of that
line which very likely date to that time period?
7. Page 6 Cluster D RGA excavated a total of 44 shovel test and did not recover any diagnostic 18th century
artifacts. This is the area where the two largest pits were found when units were opened. What does this imply
for the other clusters where 18th materials were found?
8. Page 6 Cluster D "a corroded iron hoe" was found in Feature 7. Hoes of this type are common on Native American
sites of this time period and should not be dismissed off hand as possibly belonging to anyone from that time period.
At that time most farmers were employing plows, where as Native American women are known to have used iron hoes to plant crops.
Hoes similar to this were also found at the Chota-Tanasee site in Tennessee.
9. Page 7 Cluster D Feature 7 A "dark gray elbow pipe bowl" was recovered from within Feature 7. On September
10th Rich Veit PhD examined the pipe and noted its similarities to Native American pipes found in Pennsylvania. If this
can be confirmed as Native American it adds to the mounting evidence of the association with the Bethel Mission Settlement.
10. Cluster D Feature 7 No mention is made of the window lead recovered from the plowzone above Feature 7, other
than in the catalog page A-26. This lead measures 2.1 inches long and if opened could likely contain an exact date for
11. Cluster D Feature 7 No mention is made in the text of the fossil shark tooth also found in the plowzone above the
feature (see comment 3 above).
12. Pages 8 and 9 Cluster D Feature 10 "a small black glass seed bead" "The bead resembles the type tentatively called
Kidd "Wlb?-6" by Fogelman (1991) and dated to circa 1800 or Kidd "11a53," which is much earlier." The bead can be dated
based on its association with the other artifacts in Feature 10.
13. Cluster D Feature 10 No mention is made in the text of the fossil shark tooth found in the plowzone above the feature
(see comments 3 and 11 above).
14. Page 8 Cluster D "Feature 10 is considered a significant feature, although its function is not understood, and is
possibly associated with a yet unidentified house or other feature". This pit is likely a cellar to a longer multi-family
cabin. Similar features have been observed in Tennessee at Chota.
15. Page 9 "It has been suggested after initial evaluation of the artifact assemblage from the undisturbed features,
that the site may pre-date 1740, which is too early for the Bethel Mission Settlement (1746-1759)". Then explain the
statement on page 13 "references to Native Americans with close ties to the Bethel Mission Settlement living on the land in
the late 1730s and early 1740s"
16. Page 10 "Richard Grubb & Associates, recommends that preservation in
place of the site through avoidance
and deed restriction is not feasible given the level of local media attention, making it potentially vulnerable to looting
in the future". The site is in a county park which is presumably patrolled by park employees. It is located in
an open field highly visible from the road and neighbors. Signs can be posted against metal detecting.
The only danger
to the site comes from construction of the school and Data
Recovery/Monitoring which is destructive and irreversible.
17. Page 12 Samuel R. Forman acquired a portion of the former Ashfield lands lying to the west in 1847. "He eventually
constructed a mid-nineteenth-century tenant farmer's house within the APE, approximately 450 feet southwest of 28-Mi-243".
Why was this not evaluated by Phase II testing?
18. Page 13 "Moreover, Indians associated with the settlement also owned or held claim to extensive tracts of land
within a five-mile radius of the APE, raising the possibility that the Bethel Mission Settlement covered a wide area".
What more needs to be said !
19. Page 14 ". Phase II data indicates that it has a high potential to yield additional cultural features". So
does the area to the west.
20. Page 20 "Evidence of acceptance or adoption of European-American culture, should result in large quantities
of European-American cultural materials". How much more do we need to see before this point is accepted?
21. Page 20 "The data recovery will attempt to determine if the quantity of wild taxa[ ] recovered is reflective
of resource availability, dietary preference, or both". It can also reflect ethnicity.
22. Page 27 ".the depressed gully-like area in the southeast section of the site will not be stripped due to the
low probability for presence of subsurface features in that portion of the site". Gullies are well-known areas for garbage
disposal during the historic period. Why wouldn't this area be examined?
23. Page 27 "Large features, such as wells, broad pits, cellar holes, will be bisected, and a minimum of 50 percent
sample excavated". This was a recent topic at the 17th Century Workshop held in Delaware. To fully understand
these early features on sites that are poorly understood and under represented they NEED to be fully excavated. You
don't get a secondchance. What happens to the portions not excavated? Does this invite night-time looting knowing
they are opened but left unexcavated?
24. Page 28 ".to ensure that resources are preserved to the greatest extent possible, wherever compatible with
the overall needs of the project". So does the construction of the school come before the need to preserve this important
25. Page 29 ".non-extant buildings associated with a late-nineteenth-century (1847) tenant farmstead along the
north side of School House road in the southern central portion of the APE will not be excavated". When was it evaluated
26. Page 29 #4 ".construction at that location will be temporarily halted for no more than 48 hours." What
if it is a burial or a very large feature? There should not be a limit on this type of site.
27. Page 29 #4 "The project will be halted for no more than four (4) hours while RGA personnel attempt to contact NJDEP-HPO."
Who wrote this RGA or a lawyer? What happens to the resource if the NJDEP-HPO cannot be reached?
28. Page 30 #5 "A designated representative from Monroe Township will be on-site at all times during archaeological
monitoring. Decisions to temporarily document a cultural resource(s) will be made in consultation with representatives
from Monroe Township and RGA". Since when do the clients tell the archaeologists what is important enough to dig?
This is outrageous.
29. Page 32 ".two specified days where the general public and archaeologists will be invited to tour the site under the
direction of the principal investigator(s)". Due to the size of the proposed data recovery and probable time to excavate
it, I would like to see this expanded to four visits.
30. I would also suggest a one day meeting be held at the HPO offices similar to the one held during excavations at Beverwyck,
which would include Native American and African American representatives, and all interested parties.
Comments on the letter dated September 7, 2007
From Dorothy Guzzo to Judeth Yeany.
1. Page 1 "The following
comments are based on HPO review of the draft management Summary and my be subject to our revision if any of the material
presented differs" Can it require to the school to built elsewhere?
2. Page 2 Western Portion "Archaeological, metal detector and geophysical surveys in the western part of the parcel
failed to identify significant archaeological remains". The metal detector survey failed to identify the large iron
hoe and nails from Feature 7 which, suggests the metal detectors were set to discriminate against iron. In light of
the type of metal artifacts found in features to date another metal detector survey to located iron artifacts would be appropriate.
The geophysical survey was a gross survey which was NEVER ground-truthed. Phase II testing was based in shovel test
and metal detector hits. Excavation units from the western portion which is very large area was reduced from the original
excavation plan of 10 EUs in Cluster A to 2 and in Cluster B from 10 down to 6. This does not constitute a reasonable
or adequate work effort to identify archaeological remains. Monitoring of this portion of the property may reveal numerous
cultural features related to the Bethel Mission Settlement which would then be lost to sampling.
3. Page 2 Eastern Portion "Completion of analysis and reporting and/or data recovery may demonstrate that the site is
eligible for National Register inclusion under additional criteria." It will also eradicate the site. It is already
eligible under Criterion D, why does it more than one reason to be included?
4. Page 3 "We also concur, that at this time, it is not possible to determine whether 28-Mi-243 is associated with residents
of Bethel other Native Americans, enslaved African Americans, indentured servants, tenants, landowners or some combination
of these groups". Remember that is only looking at from one side and there are other opinions of the same materials.
The archaeological community is not in complete agreement on this one and therefore peer review should be considered.
5. Page 3 the lack of stone tools may reflect "Evidence of acceptance or adoption of European-American culture, should
result in large quantities of European-American cultural materials".
6. Page 3 "the large number of status ceramics (e.g. Chinese export porcelain) and glass (e.g. stemware). The number
of Chinese export porcelain sherds is extremely low and so is the number of stemware fragments.
7. Page 3 the "Caribbean" coral was viewed by Rich Viet who thinks it was utilized as a hammer or grinding
implement. Sounds like a Native American activity to me.
8. Page 3 "the longer period of occupancy as evidenced by the recovery of creamware, pearlware, etc. than has been
indicated for Bethel by written record. When the settlement was disbanded the residents dispersed into the general area.
9. Once again I would like to request a one day meeting at the HPO offices similar to the one held during excavations
at Beverwyck which would include Native American and African American representatives, and all interested parties.
B. Liebeknecht, MA
Archeological Society of New Jersey, President