With regard to the July 2 article in the Hub concerning the proposal to rehabilitate historic buildings at Fort Hancock, the National Park Service (NPS) states Sandy Hook Partners (SHP’s) financial information is privileged and confidential and so it will not be made public at this time.

This caused me to reflect on comments that were written regarding the project’s programmatic agreement (PA), comment period open from May 3-June 3, for which no response has yet been provided by the NPS. As per Section 106 of the National Historic Preservation Act (36 CFR Part 800), the federal agency (NPS) must provide an opportunity for the public to comment on each step of the Section 106 process.

One of these comments/questions had to do with the SHP financial plan. It was questioned if the SHP plan takes into account the large costs associated with potential construction delays and the potential need for a "data recovery plan" for archaeological resources if such resources are discovered? Stipulation 8c of the PA notes, "If potentially significant archaeological resources are discovered during monitoring, ground-disturbing activities in the area of the resource shall cease. Consultation between the NPS, Sandy Hook, and the SHPO shall begin at the time of discovery. Attempts should be made to avoid impacting the resource, preserving it in place. If avoidance is impossible, data recovery will be implemented as described below."

Construction activities must cease if significant archaeological resources are discovered — which would obviously result in substantial time and cost overruns for SHP. And development and implementation of a data recovery plan could prove very expensive for SHP. There is a very real possibility significant archaeological resources will be found (by an independent archaeologist , not one that is paid by SHP) because:

• As the environmental assessment (EA) prepared by SHP and NPS points out (on page 43), "Archaeological evidence of the military activities conducted since the mid-19th century are to be found virtually everywhere within the core leasing area"; and

• The PA clearly outlines what would be required in a data recovery plan (Stipulations 8c i through vii), thus the ACHP and the SHPO obviously believe there is a very real potential for impact of archaeological resources with implementation of the proposed action.

Given the potential financial resources that would likely be required for an acceptable data recovery plan, my question is: does the SHP financial plan include costs for both construction delays and a data recovery plan? Given that SHP has yet to demonstrate its necessary funding is in place for the primary aspects of the project, this question regarding the ability to fund a data recovery plan is a very real concern. I wonder if "would-be" investors are aware of this somewhat obscure project concern, though it is a very real and, potentially costly concern.

Christine Ross

Manalapan