20200859 Ver 1_SHPO_Full_20200629

hdrinc.com 440 S Church Street, Suites 800, 900 & 1000, Charlotte, NC 28202-2075
[phone]
September 28, 2018
Ms. Renee Gledhill-Earley
North Carolina State Historic Preservation Office
State Historic Preservation Officer
4617 Mail Service Center
Raleigh, NC 27699-4617
REFERENCE: Review of Proposed Yadkin Regional Water Supply Project for Potential
Adverse Effects to Historic Properties
ER 13-2841 with Reference to ER 17-1357
Dear Ms. Gledhill-Earley,
Please find enclosed materials relating to Union County’s (County) proposed Yadkin Regional Water
Supply Project in Union and Stanly counties (Project). These are being provided for your review and
comment based on State Environmental Policy Act environmental review requirements and the potential
application for a United States Army Corps of Engineers Section 404 permit.
For your reference, the North Carolina State Historic Preservation Office (HPO) previously reviewed
effects from this Project under Environmental Review No. (ER) 13-2841. At that time, numerous
alternatives were being considered, and HPO decided to “await the selection of the preferred alternative
before … issu[ing] comments detailing the need for an archaeological investigation.” Since this
conclusion, an Environmental Impact Statement (EIS) was completed for the Project (Union County
2015), and a Preferred Alternative was selected. In reference to that EIS and previous correspondence
with HPO in relation to the Project, Alternative 1A was the selected alternative.
Based on the selected alternative, the area of potential effects (APE) associated with the Project is
defined as two parallel, approximate 40-mile long, 100-foot wide linear corridors adjacent to existing
roadway or railroad and associated right-of-way and an additional 50 acres associated with a proposed
25-foot-tall water treatment plant (WTP) (Figure 1). The APE encompasses approximately 1010 acres of
linear ground. No visual or other indirect effects to cultural resources are expected from the Project due to
all Project elements being underground or no more than 25 feet in height. In initial correspondence on this
Project, HPO responded with the thought that there were substantial aerial Project elements, possibly due
to use of the term “transmission line” for the proposed water line; however, the only aerial element
proposed in the APE is the 25-foot-high WTP.
Note that HPO previously reviewed a portion of the proposed Project location, two parcels together
totaling 0.60 acres where a pump station associated with the Project is proposed on the shore of Lake
Tillery. This portion was submitted for separate review due to its status within the Federal Energy
Regulatory Commission’s (FERC) Yadkin-Pee Dee Hydroelectric Project boundary surrounding Lake
Tillery and its regulation under the Historic Properties Management Plan: Yadkin-Pee Dee Hydroelectric
Project (FERC No. 2206), Anson, Montgomery, Richmond, and Stanly Counties, North Carolina (Stallings
2016). HPO assigned their review ER 17-1357 and had no comment on Project-related changes to this
0.60-acre portion of the Project APE. Therefore, this portion is not included in the APE, as described
above.
To assist in HPO’s consideration of Project effects and plan for potential survey of the current APE,
cultural resources specialist Harriet Richardson Seacat visited the Office of State Archaeology (OSA) to
identify previously conducted archaeological surveys and known archaeological sites in the APE and a

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surrounding 1-mile buffer, together referred to as the Project research radius. Richardson Seacat
compiled digitized data included in the OSA Geographic Information Systems (GIS) database and
nondigitized data shown on paper topographic quadrangles. Based on these data, two archaeological
surveys have been conducted and 18 archaeological sites have been identified in the Project research
radius. One archaeological survey and no sites intersect the APE. Numerous ERs have been conducted
by OSA within the Project research radius; however, in all but a few cases, OSA had no comment on the
project and did not recommend a survey.
Previous archaeological surveys conducted in the Project research radius are shown in Table 1 and on
Figure 1. Both of these surveys were conducted near the western extent of the Project APE, and one
occurred within the APE. These surveys utilized surface reconnaissance to identify sites in areas with
adequate ground surface visibility, and where surface visibility was low, subsurface testing was
employed.
Table 1. Previous Archaeological Surveys within 1 Mile of the Project APE
OSA BIB
No. Project Contractor Author Year
783 Historic and Prehistoric Resources Survey of Union
County 201 Waste Water Facilities of Crooked
Creek and Dry Fork, Union County
Museum of
Anthropology,
Catawba College
Cooper
and Joyce
1978
7825 Archaeological Survey of Piedmont Natural Gas
Line 429, Union County
Commonwealth
Heritage Group
Stair and
Bamann
2018

Stair and Bamann (2018) surveyed portions of an 8.2-mile-long linear APE that had not been previously
assessed for archaeological sites. Two portions of Stair and Bamann’s APE overlap with the current
Project APE. Where surface visibility was 50 percent or greater, surface reconnaissance was conducted
along transects spaced at 10 meters. Where surface visibility was less than 50 percent, shovel tests were
excavated at 30-meter intervals. No sites were recorded in the current Project APE, and the sites revisited
or newly recorded are located outside of the current Project research radius.
Cooper and Joyce (1978) surveyed an APE located at the western extreme of the current Project
research radius, outside of the current Project APE. All ground surfaces lacking vegetation were subject
to surface-level reconnaissance to locate sites. In areas with heavy vegetative growth, site identification
was conducted by examining tree falls and excavating “scratch squares” to depths of approximately 5
centimeters below surface. A total of 16 sites were recorded along the linear APE following Dry Fork and
Crooked creeks. No sites were identified within the current Project research radius.
Previously identified archaeological sites in the Project research radius are shown in Table 2.
Archaeological sites concentrate at the western extent and central portion of the APE. Ten sites have
been identified near the western terminus of the APE. These consist of five prehistoric sites (31UN209,
31UN210, 31UN354, 31UN355, and 31UN376), four historic sites (31UN351, 31UN352, 31UN353, and
31UN357), and one site with both prehistoric and historic components (31UN356). Seven archaeological
sites have been recorded in the central portion of the APE: six prehistoric sites (31ST50, 31ST173,
31ST174, 31ST175, 31ST179, and 31UN140) and one site with cultural affiliation in the prehistoric and
historic periods (31ST38). One prehistoric archaeological site (31ST65) has been documented near the
eastern extent of the APE, close to Lake Tillery.

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Table 2. Previously Identified Archaeological Sites within 1 Mile of the Project APE
Site No. Site Component OSA BIB No.
Distance from
Project APE (in
meters)
31UN209 Prehistoric 3851; 4070 8.3
31ST065 Prehistoric -- 33.2
31ST038 Prehistoric; Historic -- 212.0
31UN210 Prehistoric 3851; 4070; 6519 296.1
31UN353 Historic 6519 438.0
31UN354 Prehistoric 6519 548.7
31UN356 Prehistoric; Historic 6519 643.0
31UN355 Prehistoric 6519 690.8
31UN357 Historic 6519 982.9
31ST174 Prehistoric 339 1204.0
31ST179 Prehistoric 339 1249.2
31ST173 Prehistoric 339 1422.4
31ST050 Prehistoric 107 1505.3
31UN351 Historic 6519 1548.6
31ST175 Prehistoric 339 1586.9
31UN352 Historic 6519 1734.9
31UN140 Prehistoric -- 1908.1
31UN376 Prehistoric 7824 1920.3

Three of the archaeological sites are within 215 meters of the APE: 31ST38, 31ST65, and 31UN209.
Based on OSA polygon GIS data, one of these is located approximately 8 meters from the APE defined
for the Project. The other two sites are approximately 33 and 212 meters away, respectively.
Site 31UN209 is a prehistoric lithic scatter of unknown cultural affiliation identified on a saddle between
ridges. The site is located approximately 8 meters outside of the APE, near its western extent. Site
recorders indicated few recovered artifacts from the 16 subsurface tests excavated and concluded that
the site had no research potential. In the compliance report discussing the newly recorded site, Ashley et
al. (1997) concluded that the site lacked the integrity and distinction necessary for inclusion in the
National Register of Historic Places (NRHP), with which HPO concurred. According to the report and site
form, the construction of the Monroe Bypass portion of US 74 likely destroyed 31UN209.
Site 31ST65 is a prehistoric lithic scatter with unknown cultural affiliation and no cultural midden
documented on a saddle near the top of a hill close to Lake Tillery, approximately 33 meters outside of
the APE. Site recorders indicated that most of the site had eroded downhill and that all known associated
artifacts, consisting of three lithic flakes, were collected. According to the site form, the site was
considered ineligible for the NRHP, and construction of a wastewater treatment plant likely destroyed the
site. While no report was found in relation to the site, the site form indicates that 31ST65 was recorded in
1984 as a result of a compliance project.
Site 31ST38 is a multicomponent prehistoric and historic Native American site that was recorded
approximately 212 meters from the APE, in its eastern-central portion. Based on the site form, the site
hdrinc.com 440 S Church Street, Suites 800, 900 & 1000, Charlotte, NC 28202-2075
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was recorded by an avocational archaeologist and unassessed for NRHP eligibility. Little more is known
about 31ST38.
In addition to accessing data on file at OSA, HDR also considered the potential for undisturbed
archaeological sites in the APE through a comparison of the Project with features shown on historical
USGS 7.5-minute series topographic quadrangles dating to the early 1970s. Except at the proposed WTP
site and seven locations along the linear corridor, the APE follows and is immediately adjacent to roads or
railroads that were extant at least by the 1970s but likely earlier. The WTP location and the seven
locations where the APE veers from historical roads or railroads are shown on Figures 2 – 11.
Representative locations where the APE follows roads or railroads are shown on Figures 12 – 16.
In summary, based on research conducted at OSA, one archaeological survey was previously conducted
in a small portion of the Project APE, and no archaeological sites have been recorded within the APE.
Neither of the two surveys conducted within the Project research radius identified any sites in that area.
The nearest known site to the Project APE (31UN209) was considered ineligible for inclusion on the
NRHP and was likely destroyed during construction of the US 74 Monroe Bypass.
While the entire APE has potential for archaeological sites, HDR concludes that the WTP site and the
seven APE locations that are not adjacent to roads or railroads have the highest likelihood for the
identification of archaeological sites with potential NRHP significance. The vicinity of known site
concentrations, at the western extent of the APE and in the APE’s central portion, may also have a higher
probability of sites with NRHP significance. However, any archaeological sites adjacent to extant roads
and railroads are likely to be disturbed by human activities associated with road and railroad maintenance
and the installation of drainage control infrastructure, utility lines, and pipes. The APE near roads and
railroads are also proximal to residential and commercial buildings and associated sidewalks, driveways,
and parking lots; these areas are also likely to be disturbed, and any archaeological sites in these
locations have a higher potential to have lost the integrity necessary for NRHP significance.
We seek your review and comment on the potential for adverse effects to historic properties in relation to
the Project. If you need additional information, please contact me at [e-mail]
or 256-614-9007.
Sincerely,
Harriet L. Richardson Seacat, M.A.
Senior Ethnographer / Archaeologist
Enclosures:
Figure 1: Area of Potential Effects, Project Research Radius, and Previous Surveys
Figures 2 – 11: Proposed WTP Location and the APE Locations Not Following Extant Roads/Railroads
Figures 12 – 16: Representative Project APE Locations Following Extant Roads/Railroads
hdrinc.com 440 S Church Street, Suites 800, 900 & 1000, Charlotte, NC 28202-2075
[phone]
Sources cited:
Ashley, Keith H., Greg C. Smith, and Vicki L. Rolland
1997 A Cultural Resource Assessment Survey of the US 74 Monroe Bypass Preferred Alternative,
Union County, North Carolina. Bibliography No. 4070, on file at the Office of State Archaeology,
North Carolina Department of Natural and Cultural Resources.
Cooper, Peter P., and Jane S. Joyc e
1978 An Historic and Prehistoric Resources Survey of Union County 201 Waste Water Facilities of
Crooked and Dry Fork, Union County, North Carolina. Bibliography No. 783, on file at the Office
of State Archaeology, North Carolina Department of Natural and Cultural Resources.
Stair, Joseph S., and Susan E. Bamann
1997 Archaeological Survey, Piedmont Natural Gas Line 429, Union County, North Carolina (ER 17-
1395). Bibliography No. 7825, on file at the Office of State Archaeology, North Carolina
Department of Natural and Cultural Resources.
Union County
2015 Union County Yadkin River Water Supply Project, Proposed Interbasin Transfer to the Rocky
River Basin. Prepared by HDR for Union County, North Carolina.
Stallings, F. Patricia
2016 Historic Properties Management Plan: Yadkin-Pee Dee Hydroelectric Project (FERC No. 2206),
Anson, Montgomery, Richmond, and Stanly Counties, North Carolina. Bibliography No. 7528,
on file at the Office of State Archaeology, North Carolina Department of Natural and Cultural
Resources.
Union
Stanly
Anson
Cabarrus
Mecklenburg
Montgomery
Richmond
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
Project Research Radius
NC/SC Counties
Nondigitized Survey
Active Review
Active
Surveyed
AREA OF POTENTIAL EFFECTS, PROJECT RESEARCH RADIUS, AND PREVIOUS SURVEYS
FIGURE 1
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
0 4.5Miles
O
Union
B
a
u
c
om

T
a
r
l
e
t
o
n

R
d
L
a
w
y
e
r
s

R
d
New Salem Rd
PROPOSED WTP LOCATION
FIGURE 2
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
NC Counties
0 300Feet
O
SikesMillRdFairway ParkBaucom RdSpring Lake DrSikes Mill RdRoanoke Church Rd
Hwy-601Union
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 3
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
NC Counties 0 550Feet
O
C riscoBranchHwy-2
1
8
Hwy-218
M
o
r
g
a
n
Ac
a
d
e
my
Rd
Dusty LnFish RdArmy RdHwy-205Union
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 4
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Streams
Area of Potential Effects
NC Counties
0 550Feet
O
Sta
te
H
ighway
742
CobleAve
Rocky River RdS
M
a
i
n

S
t
Aquadale Rd
Flame Rd
James Rd
Stanly
AberdeenCarolina&WesternRailway
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 5
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Railroads
Area of Potential Effects
NC Counties
0 550Feet
O
Rocky River Sp
r
i
n
g
s

R
dAquadale RdStanly
H a w
B ra n ch
Alligator BranchMurrayBranch
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 6
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Streams
Area of Potential Effects
NC Counties
0 550Feet
O
Rocky River Springs RdRocky River SpringsRd PlankRdStanlyMurrayBranch
H aw BranchAlligatorBranchAPE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 7
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Streams
Area of Potential Effects
NC Counties
0 550Feet
O
S Stanly School Rd
HerringRdCottonville RdHerringRdHerring RdHinson
RdCottonvilleRdStanlyAberdeenCarolina&WesternRailwayAPE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 8
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Railroads
Area of Potential Effects
NC Counties
0 550Feet
O
Winston-SalemSouthboundRailway
Aberdeen
Carolina
&
W
este
r
n
R
a
il
wayS Stanly Sch
o
o
l

R
d
Wall Dr Horn
eRd HorneRdO l d C o t t o n villeRdH
erring
Rd
HargettDrHerringRdHerring RdRoseHi
llDrStanly
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 9
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Streams
Railroads
Area of Potential Effects
NC Counties
0 550Feet
O
N M
a
i
n

S
t
DoodyAve Pee Dee
A
veMary-BranchRdOldRdKeltyAveSummit St Lehew-ParkerRdS
h
i
n
n
St LehueParkerRdShinnCir
Cauld
e
r
Flynn D
rNMainSt
Oneal
S
t
Story StPope
S
t
ClaudeLeeSt
Shipl
e
t
t
e

S
tCandalonFieldDr
ShadyLn Lehue Parker RdCollins AveParker Cir
I
nd
i
a
n
Mo
u
nd
Rd
Stanly
Aberdeen Carolina& Western Railway
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 10
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Railroads
Area of Potential Effects
NC Counties
0 550Feet
O
B e rryHillDrB e r r y H i l l DrStoryS t
V
in
e
yardRdC u rra n
P o in tD rA l l e n t o n S t
Lak
e

H
e
a
d

R
d UnknownBer r y HillDr
W a l l S tBrooksideDr
B
e
r
r
y
H
illDr
Albe
r
ta
LnLakeHeadR d
Lake Head RdStanly
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 11
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
NC Counties 0 550Feet
O
B
a
u
c
om

R
d
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
REPRESENTATIVE APE LOCATIONS THAT FOLLOW ROADS/RAILROADS
FIGURE 12
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
0 250Feet
O
Morgan Mill RdNew Salem
R
d
Baucom
Rd
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
REPRESENTATIVE APE LOCATIONS THAT FOLLOW ROADS/RAILROADS
FIGURE 13
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
0 250Feet
O
GoldBranchHwy-205NewHopeChurchRd
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Streams
Area of Potential Effects
REPRESENTATIVE APE LOCATIONS THAT FOLLOW ROADS/RAILROADS
FIGURE 14
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
0 250Feet
O
PlankRdRocky River Springs Rd DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
REPRESENTATIVE APE LOCATIONS THAT FOLLOW ROADS/RAILROADS
FIGURE 15
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
0 250Feet
O
Big Cedar Creek Win
s
ton
-Sa
lem
Sou
thbound
Ra
i
lwa
y
Ab
e
r
d
e
e
n

C
a
r
o
l
i
n
a

&

W
e
s
t
e
r
n

R
a
i
l
w
a
y
Nor
t
h
w
o
o
d

D
r
S Stanly Scho
ol
R
d
Brickya
r
d
R
d
DATA SOURCE: Esri, HERE, Garmin, Intermap,increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Streams
Railroads
Area of Potential Effects
REPRESENTATIVE APE LOCATIONS THAT FOLLOW ROADS/RAILROADS
FIGURE 16
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
0 250Feet
O

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper Office of Archives and History
Secretary Susi H. Hamilton Deputy Secretary Kevin Cherry
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

October 23, 2018

Harriet Seacat
HDR, Inc.
440 South Church Street
Suites 800, 900, & 1000
Charlotte, NC 28202-2075

Re: Alternative 1A, Yadkin River Water Supply Project, Interbasin Transfer, Union County, ER 13-2841
Dear Ms. Seacat:
Thank you for your letter of September 28, 2018, concerning the above project.
We have conducted a review of the project and are aware of no historic resources which would be affected by
the project. Therefore, we have no comment on the project as proposed.

The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation’s Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.

Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill-Earley, environmental review coordinator, at 919-807-6579 or
[e-mail]. In all future communication concerning this project, please cite the above
referenced tracking number.
Sincerely,

Ramona M. Bartos

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May 4, 2020
Ms. Renee Gledhill-Earley North Carolina State Historic Preservation Office
State Historic Preservation Officer
4617 Mail Service Center
Raleigh, NC 27699-4617

REFERENCE: Review of Proposed Yadkin Region al Water Supply Project for
Potential Adverse Effects to Historic Properties – Project Alignment
Changes
ER 13-2841
Dear Ms. Gledhill-Earley,
Please find enclosed materials relating to Union County’s proposed Yadkin Regional Water
Supply Project in Union and Stanly counties (Project). These are being provided for your review
and comment based on the State Environmental Policy Act environmental review requirements
and the need for a United States Army Corps of Engineers Section 404 permit.
For your reference, per a September 27, 2018 letter report from HDR, the North Carolina State
Historic Preservation Office (HPO) previously reviewed effects from this Project under
Environmental Review No. (ER) 13-2841 based on selection of Alternative 1A as the proposed
Project route (Attachment 1). At that time, HPO had no comment on the Project as proposed
(HPO, October 23, 2018; Attachment 2). Since HPO’s response, the proposed route was slightly
redesigned in some locations, and the Project team newly identified two cultural resources near
the proposed route (31ST265 and 31ST266). Additionally, a landowner along the route reported
the potential for one or more human gravesites near the proposed route. T he Project team
deemed that these Project changes warranted additional coordination with HPO.
Project Description and Area of Potential Effects
Based on the Project route as currently proposed, the revised area of potential effects (revised
APE) associated with the Project is defined as an approximate 40-mile long, 45- to 60-foot wide
linear corridor generally adjacent to existing roadway or railroad and overlapping or adjacent to
associated right-of-way (ROW) and an additional 50 acres associated with a proposed 40-foot -
tall water treatment plant (WTP) (Figure 1 ). Approximately 13 miles (33 percent) of the overall
40-mile corridor veers from road or railroad ROW; these portions of the revised APE generally
follow property lines and consist of agricultural fields or developed properties, with some
portions undeveloped and forested (Figures 3 to 16). The 50-acre proposed WTP location is
primarily plowed agricultural fields (Figure 2). No visual or other indirect effects to cultural
resources are expected from the Project due to all Project elements being underground or no
more than 40 feet in height.
Background Investigation
To assist in HPO’s consideration of Project effects, in August 2018, cultural resources specialist
Har riet Richardson Seacat visited the Office of State Archaeology (OSA) in Raleigh to identify

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previously conducted archaeological surveys and known archaeological sites within the Project
research radius, defined as Alternative 1A and a surrounding 1-mile buffer. Richardson Seacat
compiled digitized data included in the OSA Geographic Information Systems (GIS ) database
and nondigitized data shown on paper topographic quadrangles. T he results of the background
investigation conducted in 2018 are reconsidered for the revised APE, whi ch is located wholly
within the Project research radius. T he newly identified and potential cultural resources are also
considered with regard to the revised APE.
Based on the collected OSA data, two archaeological surveys have been conducted and 18
archaeological sites have been identified in the Project research radius. No archaeological
surveys and one archaeological site intersect the revised APE. Numerous ERs have been
conducted by OSA within the Project research radius; however, in all but a few cases, OSA had
no comment on the project and did not recommend a survey.
PREVIOUSLY CONDUCTED CULTURAL RESOURCES SURVEYS
T wo p revious archaeological surveys, OSA Bibliography Numbers (BIB No.) 783 and 7825,
were conducted in the Project research radius (see Fi gure 1). Both of these surveys were
conducted near the western extent of the Project research radius, and neither occurred within
the revised APE. These surveys utilized surface reconnaissance to identify sites in areas with
adequate ground surface visibility, and where surface visibility was low, subsurface testing was
employed. During these surveys, no sites were recorded or revisited within the current Project
research radius. More detail on these surveys is included in Attachment 1.
PREVIOUSLY RECORDED ARCHAEOLOGICAL SITES
Previously identified archaeological sites in the Project research radius are shown in Table 1.
Archaeological sites concentrate at the western extent and central portion of the Project
research radius. Near the western terminus of the Project research radius, four prehistoric sites
(31UN209, 31UN210, 31UN354, and 31UN376), four historic sites (31UN351, 31UN352,
31UN353, and 31UN357), and two sites with both prehistoric and historic components
(31UN355 and 31UN356) have been identified. In the central portion of the Project research
radius, six prehistoric sites (31ST50, 31ST173, 31ST174, 31ST175, 31ST179, and 31UN140)
and one site with cultural affiliation in the prehistoric and historic periods (31ST38) have been
identified. One prehistoric archaeological site (31ST65) has been documented near the eastern
extent of the Project research radius, close to Lake Tillery.
Table 1. Previously Identified Archaeological Sites within the Project Research Radius
Sit e No. Site Component(s) OSA BIB No.
31ST038 Prehistoric; Historic --
31ST050 Prehistoric 107
31ST065 Prehistoric --
31ST173 Prehistoric 339
31ST174 Prehistoric 339
31ST175 Prehistoric 339

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31ST179 Prehistoric 339
31UN140 Prehistoric --
31UN209 Prehistoric 3851; 4070
31UN210 Prehistoric 3851; 4070; 6519
31UN351 Historic 6519
31UN352 Historic 6519
31UN353 Historic 6519
31UN354 Prehistoric 6519
31UN355 Prehistoric; Historic 6519
31UN356 Prehistoric; Historic 6519
31UN357 Historic 6519
31UN376 Prehistoric 7824

Two of the archaeological sites are with in 150 feet (46 meters) of the revised APE: 31UN354
and 31UN355. Based on OSA GIS polygon data, 31UN354 is approximately 45 feet (14 meters)
away from the revised APE, and 31UN355 overlaps the revised APE. Both of the sites were
documented during a 2009 survey by New South Associates (New South) for the U.S. Highway
74 Monroe Connector (OSA BIB No. 6519). Neither of these sites were recommended eligible
for listing on the National Register of Historic Places (NRHP ), findings with which OSA
concurred, and the sites were mostly or largely destroyed by construction of the Monroe
Connector.
Site 31UN354 was documented as a prehistoric lithic scatter with unknown cultural affiliation,
located on a hill along the edge of a cultivated field with delineated boundaries between 45 and
296 feet (14 and 90 meters) south of the revised APE. The site was selected for evaluative
testing by New South during the 2009 survey. New South concluded that the site likely
represented a lithic flaking location utilized for a very short duration that had been disturbed by
modern cultivation . New South recommended 31UN355 ineligible for the NRHP, and OSA
concurred with that recommendation following report review. Construction of the Monroe
Connector likely destroyed all or the majority of the site.
Site 31UN355 was documented as a multicomponent surface-level site located in an upland
area, with delineated boundaries that overlap the revised APE and extend approximately 112
feet (34 meters) north of it. The majority of the delineated site boundaries are located outside of
the APE. The site constitutes a prehistoric lithic scatter with unknown cultural affiliation and a
19th to 20th century domestic trash scatter. New South reported that the site demonstrated a low
density of artifacts, no features, and poor depositional context due to erosion. New South
recommended 31UN355 ineligible for the NRHP, and OSA concurred with that recommendation
following report review. Construction of the Monroe Connector likely destroyed at least half of
the site, the portion which is outside the revised APE.

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In addition to accessing data on file at OSA, HDR also considered the potential for undisturbed
archaeological sites in the APE through a comparison of the Project with features shown on
historical USGS 7.5 -minute series topographic quadrangles dating to the early 1970s. Except at
the proposed WTP site and for a third of the overall corridor length, the APE is immediately
adjacent to roads or railroads that were extant at least by the 1970s but likely earlier. Further,
based on the research conducted at OSA, the revised APE is within an area that OSA has
consistently had no comment on reviewed projects, suggesting the area has a low potential for
significant archaeological sites.
Newly Identified Cultural Resources
During field survey for water resources within or near the revised APE, two cultural resources
were identified by survey teams. These consisted of 31ST265, a stone wall, and 31ST266, a
site consisting of the remnants of a probable historical mill and stone dam. These cultural
resources were later investigated through desktop research and field reconnaissance. Desktop
research was facilitated by the North Carolina Maps database maintained by the University
Library at University of North Carolina at Chapel Hill. Field research was conducted by HDR
cultural resources specialist Josh Fletcher, a Registered Professional Archaeologist, and
summarized in a brief report (Attachment 3).
Site 31ST265 is located in Stanly County south of State Route 138, just south of the road’s
intersection with Barbees Grove Road and east of Foreman Branch Road (35.216045, -
80.26417). The site is located in the vicinity of several roads and residences as shown on the
1904-1910 Map of Stanly County NC drawn by Calvin M. Miller and in the vicinity of “Coble Mill”
near “Skim Ford”, along a roadway connecting Aquadale and Oakboro that extends southward
to near the Rocky River, as shown on the Stanly County sheet of the 1916 Soil Map of North
Carolina. However, the former function of this resource or its association with historical features
shown on these maps is unclear, and the condition of the wall makes further interpretation
difficult. Given the lack of definitive information from historical maps, Fletcher surmised that the
stone wall may represent a property boundary marker. Based on the condition of the feature
and its common construction type, HDR recommends that 31ST265 is not eligible for the NRHP.
This resource is located outside of the revised APE and, thus, will not be impacted by the
Project.
Site 31ST266 is located on either side of the Rocky River in Stanly and Union counties, at a
point east of the bridge over Highway 205 and north of the highway’s intersection with Pleasant
Hill Church Road (mill foundation 35.170078, -80.345122; dam 35.169372, -80.345081).
Historical maps and a nearby landowner indicate that a mill and a ford were once operated at
this location (Mr. Everette Thomas, personal communication, March 6, 2019). The 1904-1910
Map of Stanly County depicts a tenant house in this location, and the nearby label “Q.B. Coble”
may be associated with the house. The 1916 Soils Map for Stanly County labels “Coble Ford” in
approximately this location. A 1920 map of Stanly County depicting rural delivery routes shows
the label “Griffin” in the vicinity, with a bridge or ford and at least two buildings depicted. Based
on this information, as well as the information provided by the nearby landowner, the mill and
ford were likely in operation from the early to middle 20th century. Based on the fair condition of
the resource, its likely significant contribution to the broad pattern of local history, and its

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embodiment of distinctive characteristics of a type, period, and method of construction, HDR
recommends 31ST266 eligible for the NRHP under Criteria A and C. The Project corridor has
been shifted to avoid adverse effects to this eligible resource.
Potential Gravesite Field Investigations
In the course of property owner contact for the Project, a landowner alerted the Project team to
the potential for human burials to be present on a particular property within the revised APE. In
coordination with OSA staff, New South conducted a pedestrian and geophysical survey to
prospect for the undocumented cemetery within the approximate 2.5-acre portion of the property
within the revised APE and a surrounding 2- to 10-meter buffer (Attachment 4). The survey
consisted of a pedestrian reconnaissance survey over the entire temporary construction and
planned easement to identify possible surface expression of a cemetery, such as markers or
marker fragments, depressions formed from the collapse of graves, and/or elevated areas that
would suggest more limited human disturbance. No evidence of a cemetery was documented
during the reconnaissance survey. Additionally, a magnetic gradiometer and ground-penetrating
radar survey was conducted to identify disturbances in the ground consistent with historical
burials. Extensive disturbance was interpreted in the geophysical results across the survey
area, all of which were interpreted to be the results of erosion or human agricultural activities.
Magnetic point scatters, drainages, pits, roads, shallow bedrock, and other evidence of
disturbed soils were also identified; none of these were interpreted as associated with human
burials. Three possible gravesites were identified outside of the proposed easement, within the
marked cemetery associated with an adjacent church. More details on the survey can be found
in Attachment 4, a management summary of the survey being provided for HPO review and
comment in conjunction with response to this letter. A full report is currently being prepared that
will document the survey methods and the geophysical results and interpretations.
Summary and Conclusions
Based on background research conducted at OSA, no archaeological surveys were previously
conducted in the revised APE, and one archaeological site has been recorded within the revised
APE. The nearest known sites to the revised APE included in OSA’s database (31UN354 and
31UN355) were determined ineligible for the NRHP and were mostly or largely destroyed during
the construction of the U.S. 74 Monroe Connector. Two newly identified cultural resources
(NRHP -ineligible 31ST265 and NRHP-eligible 31ST266) will not be impacted by the Project.
Field investigations for potential gravesites on a particular property with in the revised APE
indicated that gravesites are likely not present in the revised APE.
While the entire APE has potential for archaeological sites, in its September 2018
correspondence, HDR concluded that the WTP site and the APE locations not within current
road or railroad ROW have the highest likelihood for the identification of archaeological sites
with potential NRHP significance. At that time, HPO had no comment on the Project as
proposed. HDR concludes that the currently reported changes in the Project APE do not warrant
different conclusions. The majority of the revised APE is disturbed, and overall, the revised APE
is within an area that OSA has consistently had no comment on reviewed projects. Any
undiscovered archaeological sites adjacent to extant roads and railroads within the revised APE
are likely to be disturbed by human activities associated with road and railroad maintenance and

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the installation of drainage control infrastructure, utility lines, and pipes. The revised APE near
roads and railroads are also proximal to residential and commercial buildings and associated
sidewalks, driveways, and parking lots; these areas are also likely to be disturbed, and any
archaeological sites in these locations have a higher potential to have lost the integrity
necessary for NRHP significance.
We seek your review and comment on the potential for adverse effects to historic properties in
relation to the revised APE associated with the Project. If you need additional information,
please contact me at [e-mail] or 256-614 -9007.
Sincerely,

Harriet L. Richardson Seacat, M.A.
Environmental Project Manager / Cultural Resources Specialist

Enclosures:
Figure 1: Revised Area of Potential Effects, Project Research Radius, and Previous
Surveys
Figures 2 – 16: Proposed WTP Location; Revised APE Locations Not Following Extant
Roads/Railroads
Attachment 1: Letter to HPO , September 27, 2018
Attachment 2: HPO Response, October 23, 2018
Attachment 3: Archaeological Investigations for the Yadkin Regional Water Supply
Project, March 15, 2019
Attachment 4: Archaeological Reconnaissance, Ground-Penetrating Radar, and
Magnetic Gradiometer Survey of Proposed Easement of Parcel
654302884696 to Prospect for an Undocumented Cemetery, Stanly
County, North Carolina, April 27, 2020

Review of Proposed Yadkin Regional Water Supply
Project for Potential Adverse Effects to Historic
Properties – Project Alignment Changes

FIGURE 1
Revised Area of Potential Effects,
Project Research Radius, and
Previous Surveys

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Mecklenburg
Cabarrus
Montgomery
Stanly
Union Anson
Richmond
CSXTransportationAberdeenCarolina&WesternRailway Winst
o
n
-Sal
emS
o
u
t
h
boun
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il
w
a
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DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
Project Research Radius
Nondigitized Survey
Active Review Surveyed
NC/SC Counties
Railroads
Interstate
US Route
NC Route
AREA OF POTENTIAL EFFECTS, PROJECT RESEARCH RADIUS, AND PREVIOUS SURVEYS
FIGURE 1
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
0 4Miles
O
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Review of Proposed Yadkin Regional Water Supply
Project for Potential Adverse Effects to Historic
Properties – Project Alignment Changes

FIGURES 2–16
Proposed WTP Location; Revised
APE Locations Not Following Extant
Roads/Railroads

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N e w S a le m R dL
a
w
y
e
r
s

R
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Union
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 2
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
NC Counties
Preferred WTP Site
0 550Feet
O
Spr
ing
Lake
D
rSikesMillRdFairwayParkBaucom RdSprin g La ke D r Sikes Mill RdRoanoke Church Rd Hwy-601Union
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 3
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
NC Counties 0 550Feet
O
Hwy-2
1
8
Hwy-218
M
o
r
g
a
nAcademyRdDusty LnFish RdArmy RdHwy-205UnionCriscoBranch
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 4
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
Streams
NC Counties
0 550Feet
O
Aquada
l
e

R
d
Sta
te
H
ighway
742
S

M
a
i
n

S
t
RockyRiverRdStateHighway138Coble Ave
State Hi gh w a y742Flame Rd Richard-SandyRdJames Rd
Stanly
AberdeenCarolina&WesternRailway
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 5
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
Railroads
NC Counties
0 550Feet
O
RockyRiverSpringsRdRocky River
S
p
r
i
n
g
s

R
dAquadale RdStanly
Alligator Branch
M u rra y B ra n chAPE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 6
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
Streams
NC Counties
0 550Feet
O
Rocky River Springs RdRocky River SpringsRd PlankRdStanlyMurrayBranch
H aw Bra nchAlligatorBranchAPE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 7
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
Streams
NC Counties
0 550Feet
O
SStanlySchoolRd
Herring RdCottonville RdHerringRdHerring RdHi
nsonRdCottonville RdStanlyAberdeenCarolina&WesternRailwayAPE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 8
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
Railroads
NC Counties
0 550Feet
O
S Stanly S
c
h
o
o
l

R
d
Wall Dr Horn
eRd Horne RdO
l
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C
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R
dOldCottonvilleRd
H
erring
Rd
O ld
Co tto n v illeRd
Ha rgettDrHerringRdHerring RdRoseHillDrStanly
B ig C e d a r C r e e k
Winston-SalemSouthboundRailway
Aberdeen Carolina&WesternRailway
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 9
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
Streams
Railroads
NC Counties
0 550Feet
O
N M
a
i
n

S
t
DoodyAve Pee Dee
AveAikman AveM ary-BranchRdGle
nHavenSt
OldRdKeltyAve
Summit St
EAndrewsStLehew-ParkerRdS
h
i
n
nSt
EPineStLehueParkerRdBerryHillDr
ShinnCir
Caul
d
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r
Flynn
D
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ig
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t
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A
v
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Onea
l

S
t
Story St
Pope

S
t
ClaudeLeeSt
Ship
l
e
t
t
e

S
tCandalonFieldDr ShadyLn Lehue Parker RdCollins AveParker Cir
I
ndi
anMoundRdStanly
Aberdeen Carolina& Western Railway
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 10
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
Railroads
NC Counties
0 550Feet
O
Allenton St
B e r r y H illDrBerryHillDrV
i
n
e
y
a
r
d
RdC u rra n
P o in tD rS toryS t
Al
lentonStVincentRdLa
k
e

H
e
a
d

R
d
W a l l S tB
e
rr
y
Hill
Dr
BrooksideDr
Albe
r
ta
LnLakeHeadR d
Stanly
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 11
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
NC Counties 0 550Feet
O
Ba
u
c
om
R
d
Fish er RidgeDrUnion
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 12
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
NC Counties 0 550Feet
O
CountryLandCtMorgan Mill RdTomberlinRd
New Salem
R
d
Baucom Rd
Union
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 13
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
NC Counties 0 550Feet
O
NewHope

C
hurchRd Hwy-205Union
Bran donB ranch
Gold
Br
anchAPE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 14
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
Streams
NC Counties
0 550Feet
O
R e h o b e th C h u rc h R d
PlankRdRockyRiverSpringsRdRockyRiverSp ringsRdStanlyAlligatorBranchHawBranch
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 15
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
Streams
NC Counties
0 550Feet
O
S Stanly Sch
o
ol
R
d
DupreeRdDelandDrHorneRdUnitedStatesHighway52SWindRdNor
t
h
w
o
o
d

D
r
Dela
n
d

D
r
N
M
a
i
n

S
t
B
r
i
c
k
y
a
r
d

R
d
Dale RdLefler Rd
Stanly
Bi
g
C
e
d
a
r
C
r
eekAberdeen C
ar
oli
n
a
&
W
e
st
er
n
R
ail
w
a
y
Winston-SalemSouthboundRailway
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 16
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
Streams
Railroads
NC Counties
0 550Feet
O

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Review of Proposed Yadkin Regional Water Supply
Project for Potential Adverse Effects to Historic
Properties – Project Alignment Changes

A TTACHMENT 1
Letter to HPO, September 27, 2018

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hdrinc.com 440 S Church Street, Suites 800, 900 & 1000, Charlotte, NC 28202-2075
[phone]
September 27, 2018
Ms. Renee Gledhill-Earley
North Carolina State Historic Preservation Office
State Historic Preservation Officer
4617 Mail Service Center
Raleigh, NC 27699-4617
REFERENCE: Review of Proposed Yadkin Regional Water Supply Project for Potential
Adverse Effects to Historic Properties
ER 13-2841 with Reference to ER 17-1357
Dear Ms. Gledhill-Earley,
Please find enclosed materials relating to Union County’s (County) proposed Yadkin Regional Water
Supply Project in Union and Stanly counties (Project). These are being provided for your review and
comment based on State Environmental Policy Act environmental review requirements and the potential
application for a United States Army Corps of Engineers Section 404 permit.
For your reference, the North Carolina State Historic Preservation Office (HPO) previously reviewed
effects from this Project under Environmental Review No. (ER) 13-2841. At that time, numerous
alternatives were being considered, and HPO decided to “await the selection of the preferred alternative
before … issu[ing] comments detailing the need for an archaeological investigation.” Since this
conclusion, an Environmental Impact Statement (EIS) was completed for the Project (Union County
2015), and a Preferred Alternative was selected. In reference to that EIS and previous correspondence
with HPO in relation to the Project, Alternative 1A was the selected alternative.
Based on the selected alternative, the area of potential effects (APE) associated with the Project is
defined as two parallel, approximate 40-mile long, 100-foot wide linear corridors adjacent to existing
roadway or railroad and associated right-of-way and an additional 50 acres associated with a proposed
25-foot-tall water treatment plant (WTP) (Figure 1). The APE encompasses approximately 1010 acres of
linear ground. No visual or other indirect effects to cultural resources are expected from the Project due to
all Project elements being underground or no more than 25 feet in height. In initial correspondence on this
Project, HPO responded with the thought that there were substantial aerial Project elements, possibly due
to use of the term “transmission line” for the proposed water line; however, the only aerial element
proposed in the APE is the 25-foot-high WTP.
Note that HPO previously reviewed a portion of the proposed Project location, two parcels together
totaling 0.60 acres where a pump station associated with the Project is proposed on the shore of Lake
Tillery. This portion was submitted for separate review due to its status within the Federal Energy
Regulatory Commission’s (FERC) Yadkin-Pee Dee Hydroelectric Project boundary surrounding Lake
Tillery and its regulation under the Historic Properties Management Plan: Yadkin-Pee Dee Hydroelectric
Project (FERC No. 2206), Anson, Montgomery, Richmond, and Stanly Counties, North Carolina (Stallings
2016). HPO assigned their review ER 17-1357 and had no comment on Project-related changes to this
0.60-acre portion of the Project APE. Therefore, this portion is not included in the APE, as described
above.
To assist in HPO’s consideration of Project effects and plan for potential survey of the current APE,
cultural resources specialist Harriet Richardson Seacat visited the Office of State Archaeology (OSA) to
identify previously conducted archaeological surveys and known archaeological sites in the APE and a

hdrinc.com 440 S Church Street, Suites 800, 900 & 1000, Charlotte, NC 28202-2075
[phone]

surrounding 1-mile buffer, together referred to as the Project research radius. Richardson Seacat
compiled digitized data included in the OSA Geographic Information Systems (GIS) database and
nondigitized data shown on paper topographic quadrangles. Based on these data, two archaeological
surveys have been conducted and 18 archaeological sites have been identified in the Project research
radius. One archaeological survey and no sites intersect the APE. Numerous ERs have been conducted
by OSA within the Project research radius; however, in all but a few cases, OSA had no comment on the
project and did not recommend a survey.
Previous archaeological surveys conducted in the Project research radius are shown in Table 1 and on
Figure 1. Both of these surveys were conducted near the western extent of the Project APE, and one
occurred within the APE. These surveys utilized surface reconnaissance to identify sites in areas with
adequate ground surface visibility, and where surface visibility was low, subsurface testing was
employed.
Table 1. Previous Archaeological Surveys within 1 Mile of the Project APE
OSA BIB
No. Project Contractor Author Year
783 Historic and Prehistoric Resources Survey of Union
County 201 Waste Water Facilities of Crooked
Creek and Dry Fork, Union County
Museum of
Anthropology,
Catawba College
Cooper
and Joyce
1978
7825 Archaeological Survey of Piedmont Natural Gas
Line 429, Union County
Commonwealth
Heritage Group
Stair and
Bamann
2018

Stair and Bamann (2018) surveyed portions of an 8.2-mile-long linear APE that had not been previously
assessed for archaeological sites. Two portions of Stair and Bamann’s APE overlap with the current
Project APE. Where surface visibility was 50 percent or greater, surface reconnaissance was conducted
along transects spaced at 10 meters. Where surface visibility was less than 50 percent, shovel tests were
excavated at 30-meter intervals. No sites were recorded in the current Project APE, and the sites revisited
or newly recorded are located outside of the current Project research radius.
Cooper and Joyce (1978) surveyed an APE located at the western extreme of the current Project
research radius, outside of the current Project APE. All ground surfaces lacking vegetation were subject
to surface-level reconnaissance to locate sites. In areas with heavy vegetative growth, site identification
was conducted by examining tree falls and excavating “scratch squares” to depths of approximately 5
centimeters below surface. A total of 16 sites were recorded along the linear APE following Dry Fork and
Crooked creeks. No sites were identified within the current Project research radius.
Previously identified archaeological sites in the Project research radius are shown in Table 2.
Archaeological sites concentrate at the western extent and central portion of the APE. Ten sites have
been identified near the western terminus of the APE. These consist of five prehistoric sites (31UN209,
31UN210, 31UN354, 31UN355, and 31UN376), four historic sites (31UN351, 31UN352, 31UN353, and
31UN357), and one site with both prehistoric and historic components (31UN356). Seven archaeological
sites have been recorded in the central portion of the APE: six prehistoric sites (31ST50, 31ST173,
31ST174, 31ST175, 31ST179, and 31UN140) and one site with cultural affiliation in the prehistoric and
historic periods (31ST38). One prehistoric archaeological site (31ST65) has been documented near the
eastern extent of the APE, close to Lake Tillery.

hdrinc.com 440 S Church Street, Suites 800, 900 & 1000, Charlotte, NC 28202-2075
[phone]

Table 2. Previously Identified Archaeological Sites within 1 Mile of the Project APE
Site No. Site Component OSA BIB No.
Distance from
Project APE (in
meters)
31UN209 Prehistoric 3851; 4070 8.3
31ST065 Prehistoric -- 33.2
31ST038 Prehistoric; Historic -- 212.0
31UN210 Prehistoric 3851; 4070; 6519 296.1
31UN353 Historic 6519 438.0
31UN354 Prehistoric 6519 548.7
31UN356 Prehistoric; Historic 6519 643.0
31UN355 Prehistoric 6519 690.8
31UN357 Historic 6519 982.9
31ST174 Prehistoric 339 1204.0
31ST179 Prehistoric 339 1249.2
31ST173 Prehistoric 339 1422.4
31ST050 Prehistoric 107 1505.3
31UN351 Historic 6519 1548.6
31ST175 Prehistoric 339 1586.9
31UN352 Historic 6519 1734.9
31UN140 Prehistoric -- 1908.1
31UN376 Prehistoric 7824 1920.3

Three of the archaeological sites are within 215 meters of the APE: 31ST38, 31ST65, and 31UN209.
Based on OSA polygon GIS data, one of these is located approximately 8 meters from the APE defined
for the Project. The other two sites are approximately 33 and 212 meters away, respectively.
Site 31UN209 is a prehistoric lithic scatter of unknown cultural affiliation identified on a saddle between
ridges. The site is located approximately 8 meters outside of the APE, near its western extent. Site
recorders indicated few recovered artifacts from the 16 subsurface tests excavated and concluded that
the site had no research potential. In the compliance report discussing the newly recorded site, Ashley et
al. (1997) concluded that the site lacked the integrity and distinction necessary for inclusion in the
National Register of Historic Places (NRHP), with which HPO concurred. According to the report and site
form, the construction of the Monroe Bypass portion of US 74 likely destroyed 31UN209.
Site 31ST65 is a prehistoric lithic scatter with unknown cultural affiliation and no cultural midden
documented on a saddle near the top of a hill close to Lake Tillery, approximately 33 meters outside of
the APE. Site recorders indicated that most of the site had eroded downhill and that all known associated
artifacts, consisting of three lithic flakes, were collected. According to the site form, the site was
considered ineligible for the NRHP, and construction of a wastewater treatment plant likely destroyed the
site. While no report was found in relation to the site, the site form indicates that 31ST65 was recorded in
1984 as a result of a compliance project.
Site 31ST38 is a multicomponent prehistoric and historic Native American site that was recorded
approximately 212 meters from the APE, in its eastern-central portion. Based on the site form, the site
hdrinc.com 440 S Church Street, Suites 800, 900 & 1000, Charlotte, NC 28202-2075
[phone]
was recorded by an avocational archaeologist and unassessed for NRHP eligibility. Little more is known
about 31ST38.
In addition to accessing data on file at OSA, HDR also considered the potential for undisturbed
archaeological sites in the APE through a comparison of the Project with features shown on historical
USGS 7.5-minute series topographic quadrangles dating to the early 1970s. Except at the proposed WTP
site and seven locations along the linear corridor, the APE follows and is immediately adjacent to roads or
railroads that were extant at least by the 1970s but likely earlier. The WTP location and the seven
locations where the APE veers from historical roads or railroads are shown on Figures 2 – 11.
Representative locations where the APE follows roads or railroads are shown on Figures 12 – 16.
In summary, based on research conducted at OSA, one archaeological survey was previously conducted
in a small portion of the Project APE, and no archaeological sites have been recorded within the APE.
Neither of the two surveys conducted within the Project research radius identified any sites in that area.
The nearest known site to the Project APE (31UN209) was considered ineligible for inclusion on the
NRHP and was likely destroyed during construction of the US 74 Monroe Bypass.
While the entire APE has potential for archaeological sites, HDR concludes that the WTP site and the
seven APE locations that are not adjacent to roads or railroads have the highest likelihood for the
identification of archaeological sites with potential NRHP significance. The vicinity of known site
concentrations, at the western extent of the APE and in the APE’s central portion, may also have a higher
probability of sites with NRHP significance. However, any archaeological sites adjacent to extant roads
and railroads are likely to be disturbed by human activities associated with road and railroad maintenance
and the installation of drainage control infrastructure, utility lines, and pipes. The APE near roads and
railroads are also proximal to residential and commercial buildings and associated sidewalks, driveways,
and parking lots; these areas are also likely to be disturbed, and any archaeological sites in these
locations have a higher potential to have lost the integrity necessary for NRHP significance.
We seek your review and comment on the potential for adverse effects to historic properties in relation to
the Project. If you need additional information, please contact me at [e-mail]
or 256-614-9007.
Sincerely,
Harriet L. Richardson Seacat, M.A.
Senior Ethnographer / Archaeologist
Enclosures:
Figure 1: Area of Potential Effects, Project Research Radius, and Previous Surveys
Figures 2 – 11: Proposed WTP Location and the APE Locations Not Following Extant Roads/Railroads
Figures 12 – 16: Representative Project APE Locations Following Extant Roads/Railroads
hdrinc.com 440 S Church Street, Suites 800, 900 & 1000, Charlotte, NC 28202-2075
[phone]
Sources cited:
Ashley, Keith H., Greg C. Smith, and Vicki L. Rolland
1997 A Cultural Resource Assessment Survey of the US 74 Monroe Bypass Preferred Alternative,
Union County, North Carolina. Bibliography No. 4070, on file at the Office of State Archaeology,
North Carolina Department of Natural and Cultural Resources.
Cooper, Peter P., and Jane S. Joyc e
1978 An Historic and Prehistoric Resources Survey of Union County 201 Waste Water Facilities of
Crooked and Dry Fork, Union County, North Carolina. Bibliography No. 783, on file at the Office
of State Archaeology, North Carolina Department of Natural and Cultural Resources.
Stair, Joseph S., and Susan E. Bamann
1997 Archaeological Survey, Piedmont Natural Gas Line 429, Union County, North Carolina (ER 17-
1395). Bibliography No. 7825, on file at the Office of State Archaeology, North Carolina
Department of Natural and Cultural Resources.
Union County
2015 Union County Yadkin River Water Supply Project, Proposed Interbasin Transfer to the Rocky
River Basin. Prepared by HDR for Union County, North Carolina.
Stallings, F. Patricia
2016 Historic Properties Management Plan: Yadkin-Pee Dee Hydroelectric Project (FERC No. 2206),
Anson, Montgomery, Richmond, and Stanly Counties, North Carolina. Bibliography No. 7528,
on file at the Office of State Archaeology, North Carolina Department of Natural and Cultural
Resources.
Union
Stanly
Anson
Cabarrus
Mecklenburg
Montgomery
Richmond
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
Project Research Radius
NC/SC Counties
Nondigitized Survey
Active Review
Active
Surveyed
AREA OF POTENTIAL EFFECTS, PROJECT RESEARCH RADIUS, AND PREVIOUS SURVEYS
FIGURE 1
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
0 4.5Miles
O
Union
B
a
u
c
om

T
a
r
l
e
t
o
n

R
d
L
a
w
y
e
r
s

R
d
New Salem Rd
PROPOSED WTP LOCATION
FIGURE 2
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
NC Counties
0 300Feet
O
SikesMillRdFairway ParkBaucom RdSpring Lake DrSikes Mill RdRoanoke Church Rd
Hwy-601Union
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 3
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
NC Counties 0 550Feet
O
C riscoBranchHwy-2
1
8
Hwy-218
M
o
r
g
a
n
Ac
a
d
e
my
Rd
Dusty LnFish RdArmy RdHwy-205Union
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 4
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Streams
Area of Potential Effects
NC Counties
0 550Feet
O
Sta
te
H
ighway
742
CobleAve
Rocky River RdS
M
a
i
n

S
t
Aquadale Rd
Flame Rd
James Rd
Stanly
AberdeenCarolina&WesternRailway
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 5
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Railroads
Area of Potential Effects
NC Counties
0 550Feet
O
Rocky River Sp
r
i
n
g
s

R
dAquadale RdStanly
H a w
B ra n ch
Alligator BranchMurrayBranch
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 6
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Streams
Area of Potential Effects
NC Counties
0 550Feet
O
Rocky River Springs RdRocky River SpringsRd PlankRdStanlyMurrayBranch
H aw BranchAlligatorBranchAPE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 7
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Streams
Area of Potential Effects
NC Counties
0 550Feet
O
S Stanly School Rd
HerringRdCottonville RdHerringRdHerring RdHinson
RdCottonvilleRdStanlyAberdeenCarolina&WesternRailwayAPE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 8
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Railroads
Area of Potential Effects
NC Counties
0 550Feet
O
Winston-SalemSouthboundRailway
Aberdeen
Carolina
&
W
este
r
n
R
a
il
wayS Stanly Sch
o
o
l

R
d
Wall Dr Horn
eRd HorneRdO l d C o t t o n villeRdH
erring
Rd
HargettDrHerringRdHerring RdRoseHi
llDrStanly
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 9
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Streams
Railroads
Area of Potential Effects
NC Counties
0 550Feet
O
N M
a
i
n

S
t
DoodyAve Pee Dee
A
veMary-BranchRdOldRdKeltyAveSummit St Lehew-ParkerRdS
h
i
n
n
St LehueParkerRdShinnCir
Cauld
e
r
Flynn D
rNMainSt
Oneal
S
t
Story StPope
S
t
ClaudeLeeSt
Shipl
e
t
t
e

S
tCandalonFieldDr
ShadyLn Lehue Parker RdCollins AveParker Cir
I
nd
i
a
n
Mo
u
nd
Rd
Stanly
Aberdeen Carolina& Western Railway
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 10
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Railroads
Area of Potential Effects
NC Counties
0 550Feet
O
B e rryHillDrB e r r y H i l l DrStoryS t
V
in
e
yardRdC u rra n
P o in tD rA l l e n t o n S t
Lak
e

H
e
a
d

R
d UnknownBer r y HillDr
W a l l S tBrooksideDr
B
e
r
r
y
H
illDr
Albe
r
ta
LnLakeHeadR d
Lake Head RdStanly
APE LOCATIONS THAT VEER FROM ROADS/RAILROADS
FIGURE 11
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
NC Counties 0 550Feet
O
B
a
u
c
om

R
d
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
REPRESENTATIVE APE LOCATIONS THAT FOLLOW ROADS/RAILROADS
FIGURE 12
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
0 250Feet
O
Morgan Mill RdNew Salem
R
d
Baucom
Rd
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
REPRESENTATIVE APE LOCATIONS THAT FOLLOW ROADS/RAILROADS
FIGURE 13
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
0 250Feet
O
GoldBranchHwy-205NewHopeChurchRd
DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Streams
Area of Potential Effects
REPRESENTATIVE APE LOCATIONS THAT FOLLOW ROADS/RAILROADS
FIGURE 14
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
0 250Feet
O
PlankRdRocky River Springs Rd DATA SOURCE: Esri, HERE, Garmin, Intermap,
increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Area of Potential Effects
REPRESENTATIVE APE LOCATIONS THAT FOLLOW ROADS/RAILROADS
FIGURE 15
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
0 250Feet
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Big Cedar Creek Win
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-Sa
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Sou
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Nor
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DATA SOURCE: Esri, HERE, Garmin, Intermap,increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN,
GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), swisstopo,
© OpenStreetMap contributors, the GIS User Community,
and OSA GIS Database.
LEGEND
Streams
Railroads
Area of Potential Effects
REPRESENTATIVE APE LOCATIONS THAT FOLLOW ROADS/RAILROADS
FIGURE 16
NCHPO CONSULTATION
REVIEW OF PROPOSED YRWSP FOR POTENTIAL ADVERSE EFFECTS TO HISTORIC PROPERTIES
0 250Feet
O
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Review of Proposed Yadkin Regional Water Supply
Project for Potential Adverse Effects to Historic
Properties – Project Alignment Changes

ATTACHMENT 2
HPO Response, October 23, 2018

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North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper Office of Archives and History
Secretary Susi H. Hamilton Deputy Secretary Kevin Cherry
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

October 23, 2018

Harriet Seacat
HDR, Inc.
440 South Church Street
Suites 800, 900, & 1000
Charlotte, NC 28202-2075

Re: Alternative 1A, Yadkin River Water Supply Project, Interbasin Transfer, Union County, ER 13-2841
Dear Ms. Seacat:
Thank you for your letter of September 28, 2018, concerning the above project.
We have conducted a review of the project and are aware of no historic resources which would be affected by
the project. Therefore, we have no comment on the project as proposed.

The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation’s Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.

Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill-Earley, environmental review coordinator, at 919-807-6579 or
[e-mail]. In all future communication concerning this project, please cite the above
referenced tracking number.
Sincerely,

Ramona M. Bartos

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Review of Proposed Yadkin Regional Water Supply
Project for Potential Adverse Effects to Historic
Properties – Project Alignment Changes

ATTACHMENT 3
Archaeological Investigations for the
Yadkin Regional Water Supply
Project, March 15, 2019

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1
Archaeological Investigations for the Yadkin Regional Water Supply Project
Union and Stanly Counties, North Carolina

By Josh Fletcher, RPA
March 15, 2019

Introduction
On March 6, 2019, Josh Fletcher, RPA, and field assistant Maggie Yayac investigated two
separate cultural features that were noticed by wetlands crews on the project.
Site 31ST265 – Stone Wall
Site 31ST265 (formerly Site 1) is located to the southwest of North Carolina State Highway 138,
to the southwest of an unnamed creek that is outside of the project study area (Figure 1;
35.216045, -80.26417). The site consists of one feature consisting of three segments of a
stacked stone wall, located in a wooded area with moderate undergrowth. Each segment
extends approximately west (246°)-east (66°) (Figure 2). A small unnamed creek/seasonal
drainage separates the small rubble section of the western end from the central portion, and the
central portion is separated from the eastern portion by an approximately two f oot four inch (70
cm) deep hole. From west to east, including the small unnamed creek/seasonal drainage and
the hole that separates the three sections, the cultural feature is approximately 89 feet (27 m)
long, ending at the larger creek to the east. The land to the west of the western segment of the
wall rises fairly steeply away from the creek bottom. From west to east, the eastern segment, at
the base of the slope and to the west of the small unnamed creek/seasonal drainage is
approximately 10 feet 10 inches (3.3 m) long and is in rubble. The small creek is approximately
five feet (1.5 meters) wide. The central section of the wall includes approximately 4 feet 7 inches
(1.4 m) of rubble to the east of the small creek, 28 feet 10 inches (8.8 m) of largely intact
stacked stone wall, and another approximately 5 feet (1.5 m) long section of rubble adjacent to
the large hole. The intact portion of this wall measures approximately 2 feet 9 inches (85 cm)
high from the ground surface to the north of the wall and approximately 3 feet 11 inches (1.2 m)
high from the ground surface to the south of the wall, meaning that the ground surface is higher
to the north of the wall. The wall is approximately 3 feet 9 inches (1.15 m) wide at the base and
2 feet 9 inches (85 cm) wide at the top. Next, the hole is approximately 2 feet four inches (70
cm) deep and measures 5 feet 3 inches (1.6 m) wide (east-west) and 19 feet (5.8 m) long
(north-south). It is unclear if the hole was created in more recent times than when the wall was
in use, though the presence of segments of wall rubble to either side of it suggests that the hole
may have been a later intrusive occurrence. To the east of the hole is a section of wall rubble
approximately 10 feet 10 inches (3.3 m) long, followed by a 19 foot 8 inch (6.0 m)-long segment
of relatively intact stone wall. This eastern segment is 1 foot 10 inch (55 cm) high from the
ground surface to the north of the wall and 2 feet 11 inches (90 cm) high from the ground
surface to the south of the wall. This segment is approximately 3 feet 3 inches (1.0 m) wide at
the top and 4 feet 7 inches (1.4 m) wide at the base. This intact segment is followed by an
approximately 3 foot 3 inch (1.0 m) wide segment of rubble that falls into the unnamed creek
that defines the eastern end of the cultural feature.

2
Figure 1. Site 31ST265 location.

3

Figure 2. Site 31ST265, from eastern extent looking west.
The wall does not appear on any known historic maps and the former function was unclear. It
does not appear to have been used as a dam, as the stacked stone wall is porous and it does
not extend to the east of the larger unnamed creek. The land may be higher to the north of the
wall due to periodic flooding events that deposit silt to the north of the wall (both creeks flow
approximately north-south). The wall may have simply been a property boundary marker across
this lowland area.
NRHP ASSESSMENT AND MANAGEMENT RECOMMENDATIONS
Site 31ST265 was evaluated for NRHP eligibility based on its significance under the four criteria
for evaluation (A, B, C, and D [Townsend et al. 1993:16-23]). The criteria for NRHP evaluation
are applied to 31ST265 below, followed by management recommendations.
Under Criterion A, a resource can be eligible for the NRHP if it is associated with events that
have made a significant contribution to the broad pattern of history. The former function of the
wall was unclear. The wall has experienced a considerable amount of degradation over the
years, likely due to flooding events and possible stone “robbing” events. Site 31ST265 is not
significant under Criterion A.

4
Under Criterion B, properties may be eligible for the NRHP if they are associated with the lives
of persons significant in our past. It is unknown who the wall was associated with/constructed
by. Site 31ST265 is not significant under Criterion B.
Under Criterion C, resources may be eligible for the NRHP that embody “the distinctive
characteristics of a type, period, or method of construction, or that represent the work of a
master, or that possess high artistic values, or that represent a significant and distinguishable
entity whose components may lack individual distinction…” (Keller and Keller 1994:6). It is
unclear who constructed the wall, and it is a fairly common construction type. Site 31ST265 is
not significant under Criterion C.
Under Criterion D, a resource may be eligible if it has yielded or is likely to yield information
important in history. It is unlikely that historic research or archaeological investigations will
provide significant information not already gleaned from the current field observations.
Therefore, 31ST265 is not significant under Criterion D. Therefore, we recommend 31ST265 not
eligible for the NRHP.
We recommend 31ST265 not eligible for the NRHP. The project as currently designed will not
intrude into the boundaries of the site and, thus, will not affect 31ST265. No further work related
to 31ST265 is necessary prior to implementation of the project.
Mill Foundation and Stone Dam Remnants
Site 31ST266 (formerly Site 2) is located to the east of NC 205, to the north (Stanly County) and
south (Union County) of the Rocky River, which flows from west to east (Figure 3; mill
foundation 35.170078, -80.345122; dam 35.169372, -80.345081). Site 31ST266 consists of the
remnants of a mill, located to the north of the river, in Stanly County, and a stone dam,
remnants of which are located to the north of the river, in the middle of the river, and onto the
south bank of the river, in Stanly and Union counties (Figures 4 and 5). The concrete mill
remnants on the north bank are located in a fairly grassy area with mature trees, while the stone
dam remnants on the south bank are located in an area with no vegetation.
The concrete foundation for the former mill is located to the north of the Rocky River,
approximately 66 feet east of the NC 205 bridge over the river. A local landowner (Mr. Everette
Thomas, personal communication, March 6, 2019), who moved to the area in 1958, recalled
that there was once a mill here, though the superstructure had burned down before his time. Mr.
Thomas pointed out remnants of a stone dam in the middle of the Rocky River (which appeared
to be above normal levels at the time of our investigations), as well as more -intact remnants on
the opposite south bank of the river, closer to the NC 205 bridge. Mr. Thomas noted that the
dam washed out prior to the mill burning down, but that when the dam was still in place, a ford
was present in this area, with trips across costing five cents. Mr. Thomas also noted that in the
previous weeks, the river had been higher than he had ever witnessed, and pointed to a rack
line of debris to the north of the mill foundation that would have put the site area under several
feet of water during the recent flood event (Mr. Everette Thomas, personal communication,
March 6, 2019). Investigators also observed that considerable amounts of sediment had
collected against the western/upstream side of the mill foundation over the years, leaving only a
small amount of the foundation wall visible above the ground level on that side of the feature.

5

Figure 3. Site 31ST266 location.

6

Figure 4. Mill foundation, located on the north side of the Rocky River, looking southwest.

7

Figure 5. Main portion of the dam, located on the south side of the Rocky River, looking north.
The long axis of the mill foundation is oriented nearly north/south (355°-175 °). The top of the mill
foundation has an outside measurement of 23 feet 8 inches north/south by 13 feet east/west.
The foundation walls taper out slightly into the ground. The top of the western (upstream) wall is
the thickest, measuring 1 feet 11 inches thick. The three remaining exterior walls are each one
foot thick. An interior wall foundation, running east-west through the center of the mill
foundation, is 1 foot 5 inches thick. Therefore, the two spaces within the mill foundation created
by this interior dividing wall foundation measure 10 feet by 10 feet. Around the top of the
perimeter of the mill foundation are 13 (one is missing) iron threaded bolts, each rising
approximately seven inches out of the concrete. Iron bolts are also present in the interior wall
foundation. These bolts would have attached the superstructure to the foundation.
The concrete is unfinished with inclusions of rough rocks/pebbles. The concrete was poured in
approximately eight inch thick levels. The southern edge of the mill foundation is approximately
12 feet 9 inches from the edge of the river. The eastern exterior face measures approximately 2
feet 9 inches tall from the ground surface on the northern (upslope) end, while it measures
approximately 6 feet 11 inches tall from the ground surface on the southern (river) end. The
western exterior face measures approximately five inches tall from the ground surface on the
northern (upslope) end, while it measures approximately 3 feet 8 inches tall from the ground

8
surface on the southern (river) end. On the western exterior face, approximately 1 foot 5 inches
from the southern edge of the wall, there is an attached concrete “pier” measuring
approximately 10 inches wide, 7 inches thick, and 19 inches tall from the ground surface. To the
south of this, at approximately the same height as the top of this “pier”, there is an iron bolt
extending from the face of the foundation wall. Metal wires/brads folded down on the western
exterior wall likely would have attached to some sort of siding/exterior material. Stacked/piled
stones with no visible concrete are located in the area between the base of the mill foundation
southern wall and the river.
Dependent on the water level, the Rocky River is approximately 200 feet wide in the area
between the concrete mill foundation and the dam remnants on the southern bank of the river.
On the southern bank of the river, the dam remnants consist of stones joined by concrete. In
several portions of the structure, it is apparent that the concrete was poured in levels, though it
was difficult to get a consistent measurement on the thickness. The dam consists of a straight
section of stone wall extending north/south approximately 36 feet south from the southern edge
of the river, followed by a slight bend, and a continuation of a 10 foot 10 inch long section of
stone wall running approximately northwest/southeast (300°-120°). The long section of the dam
measures approximately 2 feet 6 inches thick. At its northern end, near the edge of the river, it is
4 feet 10 inches tall from the ground surface. Near the central portion, it is approximately 2 feet
10 inches tall from the ground surface. At the southern end, where it joins with the short
northwest/southeast section, it is approximately 1 foot 5 inches tall from the ground surface.
Portions of the wall are covered in mud from high water events. The short northwest/southeast
leg of the dam tapers from 2 feet 6 inches thick at the northern end to 2 feet thick at the
southern end. It is approximately 1 foot 5 inches tall at the northern end and 1 foot tall at the
southern end. A considerable amount of stone rubble extends into the river, with a visible
grouping of joined/toppled stones present in the middle of the river. It is likely that the remaining
portions of the dam “blew out” in a flood event and/or were removed for boat passage.
A 1920 Rural Delivery Routes map for Stanly County shows a “Griffin” in the approximate
location of the mill/dam complex, with at least two buildings near river, and a bridge or ford
appears to be in place. The 1916 Soils Map for Stanly County shows a “Coble Ford” in the
approximate location of the mill/dam complex. Based on this information, as well as the
information provided by a local informant (Mr. Everette Thomas, personal communication,
March 6, 2019), the mill and ford was likely in operation from the early twentieth to middle
twentieth century.
NRHP ASSESSMENT AND MANAGEMENT RECOMMENDATIONS
Site 31ST266 was evaluated for NRHP eligibility based on its significance under the four criteria
for evaluation (A, B, C, and D [Townsend et al. 1993:16-23]). The criteria for NRHP evaluation
are applied to 31ST266 below, followed by management recommendations.
Under Criterion A, a resource can be eligible for the NRHP if it is associated with events that
have made a significant contribution to the broad pattern of history. The mill complex and likely
associated historic ford present at 31ST266 is associated with common early to middle
twentieth century production and travel in rural North Carolina. Additional studies and research
on the mill and ford in this area could be compared to similar systems across the state. While

9
portions of the mill and dam have been destroyed, the layout and design of the system is still
quite clear and visible. Though the complex has experienced an unknown amount of
degradation over the passing decades due to fire and flooding events, the remaining features
retain more than enough of their original integrity and form to allow the viewer to visualize the
original functioning layout. Therefore, we recommend 31ST266 eligible for the NRHP under
Criterion A.
Under Criterion B, properties may be eligible for the NRHP if they are associated with the lives
of persons significant in our past. At this time, it is unclear who the mill and ford were associated
with, though the names “Griffin” and “Coble” are present in this area on early twentieth century
maps. While Griffin and Coble were likely valuable, contributing members of their society, the
footprint they left on the landscape (the mill/ford system that is 31ST266) is not sufficient for
eligibility under Criterion B. The property must be illustrative of a person demonstrably important
within a local, state, or national historic context (Townsend et al. 1993:21). Site 31ST266 is not
significant under Criterion B.
Under Criterion C, resources may be eligible for the NRHP that embody “the distinctive
characteristics of a type, period, or method of construction, or that represent the work of a
master, or that possess high artistic values, or that represent a significant and distinguishable
entity whose components may lack individual distinction…” (Keller and Keller 1994:6). It is
unclear who constructed/operated the mill/ford complex, and it is uncertain if it was the “work of
a master”, but the complex does embody the distinctive characteristics of a type, period, and
method of construction. Therefore, we recommend 31ST266 eligible for the NRHP under
Criterion C.
Under Criterion D, a resource may be eligible if it has yielded or is likely to yield information
important in history. Though additional historic research may provide additional information on
the mill/ford complex, it is unlikely that archaeological investigations will provide significant
information not already gleaned from the current field observations. Therefore, 31ST266 is not
significant under Criterion D.
We recommend 31ST266 eligible for the NRHP under Criteria A and C. The project as currently
designed will not intrude into the boundaries of the site. No construction activities will take place
with in the site. The proposed construction activities will not degrade the aspects of the site that
contribute to its NRHP eligibility. Therefore, the proposed project will not affect 31ST266.
References Cited
Keller, J. Timothy, and Genevieve P. Keller. 1994. National Register Bulletin 18: How to
Evaluate and Nominate Designed Historic Landscapes. United States Department of the
Interior, National Park Service, Washington, DC.
Townsend, Jan, John H. Sprinkle, Jr., and John Knoerl. 1993. National Register Bulletin 36:
Guidelines for Evaluating and Registering Historical Archaeological Sites and Districts.
United States Department of the Interior, National Park Service, Washington, DC.

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Review of Proposed Yadkin Regional Water Supply
Project for Potential Adverse Effects to Historic
Properties – Project Alignment Changes

ATTACHMENT 4
Archaeological Reconnaissance,
Ground-Penetrating Radar, and
Magnetic Gradiometer Survey of
Proposed Easement of Parcel
654302884696 to Prospect for an
Undocumented Cemetery, Stanly
County, North Carolina, April 27,
2020

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April 27, 2020

Tracy L. Randazzo, AIA, PMP, NCARB, CDT
Senior Project Manager, HDR
440 S. Church Street, Suite 1000
Charlotte, NC 28202-2075
[e-mail]
Phone: [phone]
Mobile: [phone]

Subject: Archaeological Reconnaissance, Ground-Penetrating Radar, and Magnetic Gradiometer
Survey of Proposed Easement of Parcel 654302884696 to Prospect for an Undocumented
Cemetery, Stanly County, North Carolina
Dear Ms. Randazzo,
New South Associates, Inc. (New South) conducted a pedestrian and geophysical survey of parcel
654302884696 in Stanly County, North Carolina from April 6-10, 2020. An approximately 2.5-
acre portion of the parcel is planned for a utility easement for the Yadkin Regional Water Supply
Project. The landowner has an oral tradition that an unmarked cemetery is located on the property,
but its location is unknown and there is no known evidence of it being in the planned utility
easement. The survey described in this management summary consisted of a pedestrian
reconnaissance survey combined with ground-penetrating radar (GPR) and magnetic gradiometer
surveys in the planned easement to determine if there is evidence of any possible graves. The
geophysical survey was accomplished using eight GPR grids over 3.17 acres (12,833 sq. m), and
16 gradiometer grids over the same area, resulting in a combined total of 6.34 acres (25,666 sq m)
surveyed. The pedestrian survey was conducted in the same area as the geophysical survey. A
buffer measuring approximately 2-10 meters around the proposed easement was also surveyed to
ensure the entire proposed easement was covered.
Geophysical data processing has been completed and three possible graves have been identified
using the processed GPR data (Figure 1). All possible graves are located within the marked
cemetery and outside of the proposed easement. Extensive disturbance has been interpreted in the
geophysical results across the survey area and are all believed to be natural (the results of erosion)
or associated with farming. Anomalies that were identified included magnetic point scatters,
drainages, pits, roads, shallow bedrock, and other evidence of disturbed soils. These are not
believed to be associated with human burials. No features indicative of a cemetery or human
burials were identified in the pedestrian survey.

2
New South takes a conservative approach to the identification of graves detected with geophysical
data. In this case “conservative” means that if an anomaly has any of the attributes of a grave, it
is marked as one. It is impossible to conclusively ascertain the presence of graves without
excavation, and caution is used in all interpretations made with the GPR and magnetic gradiometer.
Geophysical interpretations are dependent on the presence of contrasts between the grave and the
surrounding soils. It is possible that unmarked graves were missed if they do not present enough
contrast with the surrounding soils. It is also possible that false positives were identified.
Reporting for this project is ongoing. The draft report will include background information,
methods, results and interpretations, and recommendations. Additionally, the report will include
detailed methods, GPR slice maps, magnetic gradiometer maps, and interpretations. It will include
profile examples for all interpretations. The report will be submitted within sixty (60) calendar
days of completion of fieldwork (April 10, 2020), so is scheduled for delivery June 9, 2020.
Sincerely,
NEW SOUTH ASSOCIATES, INC.

Sarah Lowry
Director of Geophysics and Archaeologist

3
Figure 1. Results Map

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North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper Office of Archives and History
Secretary Susi H. Hamilton Deputy Secretary Kevin Cherry
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

June 19, 2020

Harriet Richardson Seacat [e-mail]
HDR, Inc.
440 South Church Street, Suite 1000
Charlotte, NC 28202

Re: Alternative 1A, Yadkin River Water Supply Project, Interbasin Transfer, Union County, ER 13 -2841

Dear Ms. Richardson Seacat:

Thank you for your submission received May 28, 2020, concerning the above-referenced project. We have
reviewed the information provided and offer the following comments:

We have determined that the project as proposed will not have an effect on any historic buildings or structures.

We appreciate the notification regarding the newly identified archaeological sites as well as t ransmitting the
management summary of the pedestrian and geophysical survey to prospect for an undocumented cemetery.
We support shifting the project corridor to avoid 31ST266 and concur with New South’s initial findings that
the three potential graves identified were located within the marked cemetery and no evidence of burials was
found within the project area. When the full geophysical report is available, we ask that a courtesy copy be
submitted to our office.

We have conducted a review of the proposed changes to the project and are aware of no historic resources
which would be affected by the project. The proposed changes to the redesigned route appear to be modest
and do not to impact any new high probability areas. Therefore, we have no comment on th e project as
proposed.

The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation’s Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.

Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill-Earley, environmental review coordinator, at 919-814-6579 or
[e-mail]. In all future communication concerning this project, please cite the above
referenced tracking number.

Sincerely,

Ramona Bartos, Deputy
State Historic Preservation Officer