Planning & Zoning Commission (linked)

State Historic Preservation Office 
Department of Economic and Community Development 
 
 
 
 
 
450 Columbus Blvd., Suite 5    I    Hartford, CT 06103    I    P: 860.500.2300    I    ct.gov/historic-preservation 
 
An Affirmative Action/Equal Opportunity Employer; An Equal Opportunity Lender 
January 11, 2023 
 
Mr. David George 
Heritage Consultants LLC 
830 Berlin Turnpike 
Berlin, CT 06057  
(sent only via email to dgeorge@heritage-consultants.com) 
 
Subject:  
Archaeological Reconnaissance Survey 
 
 
21 Gurley Road 
 
 
Waterford, Connecticut 
 
Dear Mr. George:  
 
The State Historic Preservation Office (SHPO) has reviewed the Cultural Resources 
Reconnaissance report titled Phase IB Cultural Resources Reconnaissance Survey of a 
Development Area at 21 Gurley Road in Waterford, Connecticut (dated June 2022) prepared by 
Heritage Consultants, LLC (Heritage) for the referenced project. SHPO understands that the 
proposed project entails the construction of a development consisting of six commercial 
buildings with associated site improvements that include the construction of new roads, 
driveways, utilities, and stormwater drainage structures. The subject parcel consists of 
approximately 22.2 acres on the north side of Gurley Road. The archaeological survey was 
completed in support of a Stormwater Discharge permit issued by the Department of Energy and 
Environmental Protection. The submitted report meets the standards set forth in the 
Environmental Review Primer for Connecticut’s Archaeological Resources 
 
Background research revealed nine previously recorded precontact archaeological sites (Sites 45-
25, 45-40, 45-44, 152-106, 152-107, 152-108, 152-109, 152-124, and 152-129) and 10 
previously recorded historical period archaeological sites (Sites 45-39, 45-48, 45-61, 152-37, 
152-67, 152-75, 152-81, 152-130, 152-131, and 152-134) located within a mile of the project 
area. One of the identified sites, Site 152-75 (The Almshouse Site/Waller-Moore House), was 
identified within the project parcel but outside of the Area of Potential Effect (APE) associated 
with the project. Site 152-75 is a contributing element to the Oil Mill Historic District. The Oil 
Mill Historic District is currently pending listing on the National Register of Historic Places 
(NRHP).  
 
During the reconnaissance survey, 91 of 94 planned shovel tests were excavated at 15-meter 
intervals throughout the APE. The three planned but unexcavated shovel tests fell within areas of 
standing water. The field effort resulted in three shovel tests positive for historical period cultural 
material. The identified cultural material included a machine-cut nail, a wire nail, a clear window 
glass shard, a plain creamware sherd, and a pearlware sherd recovered from plowzone and fill 
contexts. No additional archaeological examination of the APE was recommended prior to 
construction. SHPO concurs that no additional archaeological investigation within the APE, as 
currently proposed, is warranted and that no archaeological resources will be impacted by the 

State Historic Preservation Office 
Department of Economic and Community Development 
 
 
 
 
 
450 Columbus Blvd., Suite 5    I    Hartford, CT 06103    I    P: 860.500.2300    I    ct.gov/historic-preservation 
 
An Affirmative Action/Equal Opportunity Employer; An Equal Opportunity Lender 
proposed development. However, SHPO recommends additional archaeological investigation if 
construction plans change to include impacts to portions of the project parcel not subjected to 
subsurface archaeological testing.  
 
Finally, Site 152-75 is an important and tangible remnant of Waterford’s social history. 
Archaeology often is the only thing that remains for people that the history books did not record. 
This site offers a unique insight and tremendous research potential into the lives of these societal 
outcasts. As a result, SHPO requires assurances that Site 152-75 will not be impacted by the 
currently proposed project. Our office recommends indicating the boundaries of Site 152-75 on 
project maps as a sensitive resource area and installing construction fencing around its perimeter. 
SHPO also strongly urges the developer to consider placing a preservation easement on Site 152-
75 to allow our office the opportunity to comment on any future development that may impact it. 
  
SHPO appreciates the cooperation of all interested parties in the professional management of 
Connecticut’s archeological resources. This letter updates and supersedes all previous 
correspondence regarding the proposed project. Do not hesitate to contact Cory Atkinson, Staff 
Archaeologist and Environmental Reviewer, for additional information at (860) 500-2248 or 
cory.atkinson@ct.gov.  
 
Sincerely,  
 
 
 
Jonathan Kinney  
State Historic Preservation Officer