The Corps of Engineers selected only “two components at the site” — the Native American settlement and British Army Redoubt No. 1.
James Boyer, Corps of Engineers, wrote on Jan. 22, 2008:
“Please understand that some of us involved in this consultation do not have a professional background in the field of history or archaeology.”
Without that expertise, the Corps of Engineers cannot determine National Register potential. Further, Boyer refuses to comply with the National Historic Preservation Act, Section 106:
“The agency official shall ensure that a determination, finding, or agreement under the procedures in this subpart is supported by sufficient documentation to enable any reviewing parties to understand its basis” [36 CFR § 800.11]
After repeated requests by Torben Jenk for that “sufficient documentation,” Boyer wrote on Aug. 4, 2008:
“We will get back to you once we have had a chance to discuss your message with our archaeologist, who is on vacation.”
That sufficient documentation has NOT been delivered and there is no basis for their determination that “other archaeological resources at the site do not possess integrity due to the past centuries of land disturbance on the site.”
Boyer relied upon the false assertions of Terrence McKenna (Keating) and his revolving-door of Principal Investigators: Daniel Bailey, Richard Baublitz and Judson Kratzer (A.D. Marble).
The applicant, Corps, PHMC and ACHP knew nothing about British Army Redoubt No. 1, Batchelors’ Hall and many other historic structures that stood on the Sugar House site. The Corps cannot ignore the historic documentary evidence for Masters’ Tide Mill (c. 1715), Kensington Bank (ca. 1826), Burtis & Keen’s Cotton Mill (ca. 1820), Kensington Screw Dock & Spermaceti Works (ca. 1830), Point Pleasant Foundry (ca. 1809), plus the 18th & 19th century shipyards, associated industries, residences and taverns.
That extensive historic documentary evidence provided by local historians should have been studied by the Corps, PHMC and ACHP prior to authorizing the “removal of obstructions (foundations, slabs, walls, etc.), to whatever extent they are now present” — to preserve the sufficient integrity of association and setting, and the preserved contextual relationship between artifacts in an environment that can be reconstructed.