20221112 Ver 1_17BP.1.PE.88 Cemetery GPR Concurrence Letter from HPO_20220818

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary D. Reid Wilson
November 23, 2021
MEMORANDUM
Office of Archives and History
Deputy Secretary, Darin J. Waters, Ph.D.
To: Shelby Reap, Architectural Historian slreap(2ncdot.gov
NCDOT/EAU/Historic uArchitecture Group
From: Renee Gledhill -Earley a"k� / �
Environmental Review Coordinator
SUBJECT: Ground -Penetrating Radar Survey of the Union United Methodist Church Cemetery,
Replace Bridge No. 5 on SR 1103 over Chapel Creek, PA#19-08-0004, Pasquotank County,
ER 21-1421
Thank you for your October 21, 2021, letter transmitting the Ground -Penetrating Radar (GPR) Survey
Report, produced by New South Associates, for the above -referenced undertaking. We have reviewed the
report and offer the following comments.
The NC Department of Transportation (NCDOT) contracted New South Associates Inc. to conduct a GPR
survey and produce a marker map and cemetery inventory within the previously established boundary for
the Union United Methodist Church (UMC), a property determined eligible for listing in the National
Register of Historic Places (NRHP). The goal of the survey was to document markers and identify
unmarked graves within the Esclip and Griffin Swamp Road right-of-way (ROW) and a 10-foot (3-m)
buffer along the cemetery boundary. The GPR survey identified 109 graves arranged over three distinct
areas divided by Esclip and Griffin Swamp Roads, with 68 interments within the ROW and 10-foot buffer.
A significant number of unmarked graves were identified within the ROW. A fourth area of marked graves
was identified as "Strangers" burials by local informants.
The previous evaluation that recommended the Union United Methodist Church as eligible for listing on
the NRHP under Criterions A and C concluded that the cemetery was not a contributing element to the
church. However, New South Associates, recommended that, considering the new information provided by
the GPR, the cemetery be reassessed as a contributing element. New South also recommended the
boundary of the cemetery be re-evaluated to ensure that all the graves associated with the church property
are included in the NRHP boundary. We concur with both recommendations.
NCDOT has recommended that Criterion D be added as a criterion supporting NRHP listing due to the
information about burial practices that may be derived from the cemetery itself. We concur with this
recommendation, given the GPR results suggest several avenues of research, not only of specific burial
practices, but of changes in these practices over possibly 180 years.
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898

ER 21-1421, November 23, Page 2 of 2
NCDOT has recommended an expanded NRHP boundary to include all of the land within the parcel owned
by UMC (Parcel ID 8838 695115). The expanded NRHP boundary recommendation also includes visible
graves and those discovered during the GPR survey on the west side of Esclip Road. These include the
marked "Strangers" burials that are north of, and somewhat separate from the majority of the internments
and the Roughton plot that is on the southwest corner of Esclip and Griffin Swamp Roads. We agree that
all of these areas are related to Union Methodist Church and should be included in the National Register
boundary.
Because this survey was initiated by DOT'S planned replacement of Bridge 95 and associated road -
widening, the necessary mitigation concerning unmarked graves in the ROW will be addressed later. We
look forward to consulting on the effects to the eligible church, including its contributing cemetery.
The above comments are made pursuant to the terms of the 2013 MOA, 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.
If you have questions concerning the above comment, please contact Renee Gledhill -Earley, environmental
review coordinator, at 919/807-6579 or by email at renee.gedhill-earley(2ncdcr.gov. In all future
communication concerning this project, please cite the above -referenced tracking number.
cc: Matt Wilkerson, NCDOT, Archaeology mtwilkerson2ncdot.gov
Mary P. Furr, NCDOT Historic Architecture mpfurr e,ncdot.gov
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6898