App D - Cultural Resources Assessment ASMBLD
Appendix D:
Cultural Resources Assessment
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NORTH AMERICA | EUROPE | AFRICA | AUSTRALIA | ASIA
WWW.FIRSTCARBONSOLUTIONS.COM
Cultural Resources Assessment
The Terrace Apartments
City of Orange, Orange County, California
USGS 7.5 Minute Anaheim Topo
Santiago Land Grant
Prepared for:
Bob Ormond
City Terrace Associates, Ltd., L.P.
9990 Santa Monica Boulevard
Beverly Hills, CA 90212
Prepared by:
FirstCarbon Solutions
250 Commerce, Suite 250
Irvine, CA 92602
714.508.4100
Contact: Jason Brandman, Project Director
Cecilia So, Project Manager
Authored by: David Smith, Archaeologist
April 2, 2018
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Cultural Resources Assessment Table of Contents
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Table of Contents
Management Summary ................................................................................................................. 1
Section 1: Introduction .................................................................................................................. 3
1.1 - Project Location and Description ...................................................................................... 3
1.2 - Natural Setting ................................................................................................................... 3
Section 2: Cultural Setting ............................................................................................................ 11
2.1 - Prehistoric Background ................................................................................................... 11
2.1.1 - Early Man ............................................................................................................. 11
2.1.2 - Millingstone .......................................................................................................... 12
2.1.3 - Intermediate ......................................................................................................... 12
2.1.4 - Late Prehistoric ..................................................................................................... 13
2.2 - Native American Background .......................................................................................... 13
2.2.1 - Gabrieliño ............................................................................................................. 13
Section 3: Results ......................................................................................................................... 15
3.1 - Record Search .................................................................................................................. 15
3.1.1 - Information Center Search ................................................................................... 15
3.1.2 - Historic Aerials ..................................................................................................... 15
3.1.3 - Native American Heritage Commission Record Search ........................................ 16
3.1.4 - Los Angeles County Museum of Natural History .................................................. 16
3.2 - Pedestrian Survey ............................................................................................................ 16
Section 4: Summary and Recommendations ................................................................................ 17
4.1 - Summary ......................................................................................................................... 17
4.2 - Recommendations ........................................................................................................... 17
4.3 - Inadvertent Discovery Procedures .................................................................................. 17
4.3.1 - Accidental Discovery of Cultural Resources ......................................................... 17
Section 5: References ................................................................................................................... 19
List of Appendices
Appendix A: Records Search
Appendix B: Native American Correspondence
B.1 - Native American Heritage Commission Sacred Lands File Search
B.2 - Native American Information Request Letters
B.3 - Native American Information Request Letter Responses
Appendix C: Paleontological Report
Appendix D: Regulatory Framework
List of Tables
Table 1: Cultural Resources Reports within a 0.25-mile Radius of the Project Area ............................ 15
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List of Exhibits
Exhibit 1: Regional Location Map ............................................................................................................ 5
Exhibit 2: Local Vicinity Map, Topographic Base ..................................................................................... 7
Exhibit 3: Local Vicinity Map, Aerial Base ............................................................................................... 9
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MANAGEMENT SUMMARY
The results of the records search indicate the project area has never been the subject of an
archaeological or historical study and that there are no known archaeological resources on or within
one-quarter mile radius of the project area. A review of historical aerials shows that the buildings on
the project are at least 45 years of age. Their exact construction date is unknown at this time. A
review of paleontological records shows that sensitive fossiliferous sediments could be encountered
during deep construction excavation on the project.
A review of historical aerials shows that the buildings on the project are at least 45 years of age. Their
exact construction date is unknown at this time. The existing buildings on the project area will require
evaluation by a qualified architectural historic to determine their age and historic significance under
the California Environmental Quality Act (CEQA). A qualified paleontologist should be retained and, in
consultation with the contractor, determine the duration that paleontological monitoring should be
conducted during construction.
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Cultural Resources Assessment Introduction
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SECTION 1: INTRODUCTION
1.1 - Project Location and Description
The project site is bounded by Chapman Avenue to the north, City Parkway West to the south and
east, and S. Lewis Street to the west in the City of Orange, California (Exhibits 1–3).
The project proposes to develop an additional 197 residential dwelling units in six new structures.
The existing project has 441 apartment units in eight buildings. There are 821 existing parking stalls,
the construction of the project will remove 302 stalls and add 719 parking stalls for a total of 1,238
parking stalls. The project proposes to designate 15 percent of the project area as open space
(approximately 110,258 square feet).
1.2 - Natural Setting
The project area is located entirely within a built environment in the City of Orange, California.
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Exhibit 1
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Project Site
Source: Census 2000 Data, The CaSIL, FCS GIS 2016.
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CITY TERRACE ASSOCIATES • TERRACE APARTMENTS
CULTURAL RESOURCES ASSESSMENT
50230001 • 08/2017 | 1_regional.mxd
Project Site
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Exhibit 2
Local Vicinity Map
Topographic Base
Source: USGS Anaheim (1981) 7.5' Quadrangle / Santiago de Santa Ana Land Grant
CITY TERRACE ASSOCIATES • TERRACE APARTMENTS
CULTURAL RESOURCES ASSESSMENT
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Feet
Legend
Project Site
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50230001 • 08/2017 | 3_aerial.mxd
Exhibit 3
Local Vicinity Map
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Source: ESRI Imagery
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SECTION 2: CULTURAL SETTING
Following is a brief overview of the prehistory, ethnography, and historic background, providing a
context in which to understand the background and relevance of sites found in the general project
area. This section is not intended to be a comprehensive review of the current resources available;
rather, it serves as a general overview.
Further details can be found in ethnographic studies, mission records, and major published sources,
including Beardsley (1948), Bennyhoff (1950), Fredrickson (1973), Kroeber (1925), Chartkoff and
Chartkoff (1984), and Moratto (1984).
2.1 - Prehistoric Background
Fagan (2003), Moratto (1984) and Chartkoff and Chartkoff (1984) provide recent overviews of
California archaeology and historical reviews of the inland southern California coast, among other
locales. The most accepted regional chronology for coastal and the southern coast of southern
California is from Wallace’s four-part Horizon format (1955), which was later updated and revised by
Warren (1968), and most recently by Chartkoff and Chartkoff (1984). The latter modified the term
“Period” to “Horizon,” a term more common among researchers today. Created to place temporal
structure upon materialistic phases observed during archaeological syntheses, the advantages and
weaknesses of southern California chronological sequences are reviewed by Warren (in Moratto
1984), Chartkoff and Chartkoff (1984), and Heizer (ed. 1978).
2.1.1 - Early Man
Spanning the period from approximately 17,000 to 9,500 Before Present (BP), archaeological
assemblages attributed to the Early Man Period are characterized by large projectile points and
scrapers. The limited data available suggests that prehistoric populations focused on hunting and
gathering, moving about the region in small nomadic groups. Technologies associated with ocean
resource gathering would have likely been utilized, but the sea level during this period was lower
than today, meaning that sites on the coast are inundated and unavailable for study. Californians of
this period are viewed as populations of big game hunters that were mobile enough to pursue herds.
The entirety of California may have been occupied near the beginning of the Holocene epoch, about
11,750 years ago. During the Holocene, sea levels rose about 60 meters between 11,750 and 7,000
years BP, due to melting of the Pleistocene ice sheet in the higher latitudes. Although the sea level
was about 120 meters lower off the coast of California roughly 22,000 years ago (Milne et al 2005),
sea level stabilization began about 7,000 years ago and only a slight rise has occurred since then.
Pleistocene flora and fauna are regularly uncovered from sediments at the La Brea tar pits, deep
construction-related excavations in coastal Orange County and in the Santa Ana watershed. Such
studies reinforce the idea that much of southern California exhibited a climate similar to that of
Monterey or the San Francisco Bay area during this period (Chartkoff and Chartkoff 1984), with
slightly drier conditions away from the coast.
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2.1.2 - Millingstone
As part of the slow restabilization effect of the melting continental ice sheet, rising sea levels and
other environmental changes up to the end of the Early Man Period, the southern California climate
became warmer and drier. Known as the Altithermal, Fagan (2003) notes that after 8,500 BP, the
climate of most of California became warmer and much drier, and remained so for 4,000 years.
Native groups altered their subsistence characteristics to compensate. Characterized by the
appearance of handstones and millingstones that would have been used to grind seeds, the
Millingstone Period tentatively dates to between 9,500 and 3,000 BP. Artifact assemblages in early
Millingstone sites reflect an emphasis on foraging subsistence systems. Because shrubby vegetative
communities replaced the temperate forest, native populations would likely have shifted to seasonal
rounds to take advantage of new patterns of seed ripening. Little is known about the types of
cultural changes that would be needed, but the types of artifacts seen during this Period can infer
the subsistence systems.
Artifact assemblages typically included choppers and scraper planes, but there is a general lack of
projectile points. Large projectile points began to appear in the late portion of the Millingstone
Period, which suggests the development of a more diverse economy. The distribution of
Millingstone sites reflects the theory that aboriginal groups may have followed a modified central-
based wandering settlement pattern. In this semi-sedentary pattern, a base camp would have been
occupied for a portion of the year, but small population groups seasonally occupied subsidiary camps
in order to exploit resources not generally available near the base camp. Sedentism apparently
increased in areas possessing an abundance of resources that were available for longer periods. Arid
inland regions would have provided a more dispersed and sporadic resource base, further restricting
sedentary occupations to locations near permanent water. The duration and intensity of
encampment occupations increased, especially in the latter half of the period in the coastal areas.
Huge shellmounds near coastal habitats indicated more intensive sedentism after 5,000 BP (Fagan
2003), suggests an increase in population.
2.1.3 - Intermediate
Dating between 3,000 and 1,250 BP, the Intermediate Period represents a transitional period.
Excavated assemblages retain many attributes of the Millingstone Period but with more elaborate
and diverse artifact types in these deposits. Additionally, Intermediate Period sites can contain
large-stemmed or notched small projectile points suggestive of bow and arrow use, especially near
the end of the period, and the use of portable grinding tools continues. Intensive use of mortar and
pestles signaled processing of acorns as the primary vegetative staple as opposed to a mixed diet of
seeds and acorns. Because of a general lack of data, neither the settlement and subsistence systems
nor the cultural evolution of this Period are well understood, but it is very likely that the nomadic
ways continued. It has been proposed that sedentism increased with the exploitation of storable
food resources, such as acorns, but coastal sites from the period exhibit higher fishing activity than
in previous periods. The first permanently occupied villages make their appearance (Chartkoff and
Chartkoff 1984).
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2.1.4 - Late Prehistoric
Extending from 1,250 BP to Spanish Contact in 1769, the Late Prehistoric Period reflects a slight
increase in technological sophistication and diversity. Exploitation of marine resources continued to
intensify. Assemblages characteristically contain projectile points, and toward the end of the period
the size of the points decrease and notched and stemmed bases appear, which imply the use of the
bow and arrow. Use of personal ornaments, such as shell beads, are widely distributed east of the
coast suggesting well-organized and codified trade networks. In addition, assemblages include
steatite bowls, asphaltum, grave goods, and elaborate shell ornaments. Use of bedrock milling
stations was widespread during this horizon. Increased hunting efficiency and widespread
exploitation of acorns provided reliable and storable food resources. Village size increases, and
some of these villages may hold 1,500 persons or more (Chartkoff and Chartkoff 1984). Analyses of
skeletons show that the first signs of malnutrition appear in this period, signaling greater
competition for food resources (Fagan 2003).
The earliest part of this Period may have seen an incursion of Cupan-Takic speakers from the Great
Basin country (the so-called “Shoshonean wedge” of Kroeber 1925), who may have replaced the
Hokan speakers in the area. At the time of Spanish conquest, Cupan-Takic speakers were located in
Orange County, western Riverside County, and the Los Angeles Basin (Gabrieliño, Juaneño and
Cahuilla peoples). Serran-Takic speakers are now represented by the Serranos in the San Bernardino
Mountains. Recent work (O’Neil 2002) has concluded that the “Shoshonean wedge” is misnamed:
the original Los Angeles inhabitants replaced by the incoming Takic speakers may have actually been
Yuman speakers (similar to those in the California Delta region of the Colorado River) and not Hokan
Salinan-Seri (Chumash) speakers as was suggested by Kroeber.
At the time of Spanish conquest, local Indian groups were composed of constantly moving and
shifting clans and cultures. Early ethnographers applied the concept of territorial boundaries to local
Indian groups purely as a conceptualization device, and the data was based on fragmented
information provided to them from second-hand sources.
2.2 - Native American Background
2.2.1 - Gabrieliño
The project area lies at the far eastern edge of the Gabrieliño cultural area as defined by Kroeber
(1925) and Bean and Smith (1978). The Gabrieliño also spoke a language that belongs to the Cupan
group of the Takic subfamily of the Uto-Aztecan language family, a language family that includes the
Shoshonean groups of the Great Basin. The total Gabrieliño population 350 years ago was roughly
5,000 persons, based on an estimate of 100 small villages of 50 to 200 people apiece (Goldberg and
Arnold 1988). Their range is generally thought to have been located on the Pacific coast from Malibu
to San Pedro Bay and south to Aliso Creek, then east to Temescal Canyon and the San Bernardino
area, then north to the headwaters of the San Gabriel River. Also included were several islands,
including Catalina. This large area encompasses the city of Los Angeles, much of Rancho
Cucamonga, Corona, Glendale, and Long Beach. In general, Gabrieliño peoples occupied most of the
fertile bottomlands in the Los Angeles basin.
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The first modern social analyses of Gabrieliño culture took place in the early part of the 20th century
(Kroeber 1925), but by that time acculturation and disease had taken their toll. The population
studied at that time was a mere remnant and a shadow of their cultural form prior to contact with
the Spanish Missionaries. Nonetheless, the Gabrieliño are viewed as a chief-oriented society of
semi-sedentary hunter-gatherers. Technology was sophisticated and reflected seasonal resource
exploitation originating from village-centered territories. Influenced by the wide variety of coastal
and interior environmental settings, their material culture was quite elaborate and consisted of well-
made wood, bone, stone and shell items. Included among these was a hunting stick made to bring
down different types of game. Located in an area of extreme environmental diversity, large villages
may have been permanent, such as that found on or near Red Hill in Alta Loma, with satellite villages
utilized seasonally. Their living structures were large, domed and circular thatched rooms that may
have housed multiple families. The society exhibited ranked individuals, possibly chiefs, who
possessed a much higher level of economic power than unranked persons did.
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SECTION 3: RESULTS
3.1 - Record Search
3.1.1 - Information Center Search
FCS conducted a record search at the South Central Coastal Information Center (SCCIC), California
State University, Fullerton, California. To identify any historic properties or resources, the current
inventories of the National Register of Historic Places (NR), the California Register of Historic
Resources (CR), the California Historical Landmarks list (CHL), the California Points of Historical
Interest (CPHI) list, and the California State Historic Resources Inventory (HRI) for Orange County
were reviewed to determine the existence of previously documented local historical resources
(Appendix A).
According to records on file at SCCIC, no archaeological or historical sites have been recorded on or
within a 0.25-mile radius of the project. There have been six technical studies conducted within the
records search buffer, but none included the project area (Table 1) .
Table 1: Cultural Resources Reports within a 0.25-mile Radius of the Project Area
Report Number Author/Date Additional Details
OR-01949 Padon, Beth, McLean, Deborah,
and Strudwick, Ivan 1995
Cultural Resource Assessment for the City of
Garden Grove
OR-01954 Padon, Beth 1995 Archaeological Archival Review and Survey of the
Co 5 and Co 6 Flood Control Channels, Anaheim,
Newport, and Seal Beach USGS 7.5 Quadrangles,
Orange County, California
OR-01977 Duke, Curt 1999 Cultural Resource Assessment for Pacific Bell
Mobile Services Facility Cm 281-09, County of
Orange, California
OR-02519 Houghtby, Michael A. 2001 Doj010427a, the Lacy Branch Jail Build Out,
Orange County, CA
OR-02899 McKenna, Jeanette A. 2003 Block at Orange Expansion Project
OR-03373 Arrington, Cindy and Nancy Sikes
2006
Cultural Resources Final Report of Monitoring and
Findings for the Qwest Network Construction
Project State of California; Volumes I and II
The records search also indicated that no historic or prehistoric cultural resources have been
recorded within the buffer area or on the subject property.
3.1.2 - Historic Aerials
An examination of historic aerials of the project area indicates that the buildings on the property first
appear in a 1972 aerial. The next earliest aerial is 1963 in which most of the property appears to be
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plowed fields. The actual construction date of the buildings is currently unknown; however, their
appearance in the 1972 aerial indicates they are at least 45 years of age or older.
3.1.3 - Native American Heritage Commission Record Search
On August 15, 2017 FCS sent a letter to the Native American Heritage Commission (NAHC) in an
effort to determine whether any sacred sites are listed on its Sacred Lands File for the project area.
The response from the NAHC was received on August 23, 2017 and it noted that the files search was
negative for cultural resources within the project area. A list of Native American tribal members who
may have additional knowledge of the project area was included with the results. These tribal
members were sent letters on September 14, 2017 asking for any additional information they might
have concerning the project area (Appendix B).
3.1.4 - Los Angeles County Museum of Natural History
The Los Angeles County Museum of Natural History conducted a review of its paleontological
records to determine the relative sensitivity of the project area for fossil remains. According to the
museum:
Surficial sediments at the proposed project site and in the surrounding area consist of
younger terrestrial Quaternary Alluvium, with older terrestrial Quaternary sediments
occurring at various depths, as part of the general floodplain of the Santa Ana River
that flows just east of the proposed project area. These younger Quaternary deposits
typically do not contain significant vertebrate fossils in the uppermost layers, but we
have a vertebrate fossil locality, LACM 1652, along Rio Vista Avenue south of Lincoln
Avenue north-northeast of the proposed project area, that produced a fossil specimen
of sheep, Ovis. Our closest vertebrate fossil locality in older Quaternary sediments is
LACM 4943, situated almost due east of locality LACM 1652 along Fletcher Avenue
east of Glassell Street east of the Santa Ana River, that produced a specimen of fossil
horse, Equus, at a depth of 8–10 feet below the surface.
The museum concluded that grading or shallow construction excavations are unlikely to encounter
any significant fossil remains; however, deeper excavations could encounter fossiliferous sediments
and should be closely monitoring during construction (Appendix C).
3.2 - Pedestrian Survey
A pedestrian survey was not conducted for this project.
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SECTION 4: SUMMARY AND RECOMMENDATIONS
4.1 - Summary
The results of the records search indicate the project area has never been the subject of an
archaeological or historical study and that there are no known archaeological resources on or within
a 0.25-mile radius of the project area. A review of historical aerials shows that the buildings on the
project are at least 45 years of age. Their exact construction date is unknown at this time. A review
of paleontological records shows that sensitive fossiliferous sediments could be encountered during
deep construction excavation on the project.
4.2 - Recommendations
A review of historical aerials shows that the buildings on the project are at least 45 years of age. Their
exact construction date is unknown at this time. The existing buildings on the project area will require
evaluation by a qualified architectural historic to determine their age and historic significance under
CEQA. A qualified paleontologist should be retained to consult with the contractor to determine the
duration that paleontological monitoring should be conducted during construction.
4.3 - Inadvertent Discovery Procedures
4.3.1 - Accidental Discovery of Cultural Resources
If human remains are encountered during excavations associated with this project, Mitigation
Measures CUL-1 and CUL-2 would be required. If archaeological resources are encountered during
construction, Mitigation Measure CUL-3 would be required. Implementation of Mitigation Measures
CUL-1 through CUL-3 would reduce impacts to a level of less than significant.
Recommended Mitigation Measures
MM CUL-1 If human remains are encountered during excavations associated with this project,
all work shall stop within 50 feet of the find, and the County Coroner shall be
notified (Section 7050.5 of the California Health and Safety Code). If the coroner
determines that the remains are of Native American origin, he or she shall contact
the Native American Heritage Commission (NAHC).
MM CUL-2 The NAHC shall be responsible for designating the most likely descendant (MLD),
who shall be responsible for the ultimate disposition of the remains, as required by
Public Resources Code Section 5097.98. The MLD shall make his or her
recommendations within 48 hours of having been notified by the NAHC.
MM CUL-3 A qualified paleontologist shall be retained to consult with the contractor to
determine the duration that paleontological monitoring should be conducted during
construction.
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In the event that archaeological resources are encountered during development of
this project, work near the resource shall be diverted and a qualified archaeologist
shall be notified. The archaeologist will assess the significance of the find and
provide mitigation recommendations.
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SECTION 5: REFERENCES
Bean, L.J. 1972. Mukat’s People: The Cahuilla Indians of Southern California. Los Angeles:
University of California Press.
Bean, L.J. 1978. Cahuilla. In Handbook of North American Indians, Vol. 8: California, edited by R.F.
Heizer, pp. 575-587. Washington, DC: Smithsonian Institution.
Bean, L.J. and C.R. Smith. 1978. Serrano. In R.F. Heizer, (ed.), Handbook of North American Indians,
Vol. 8: California. Washington, DC: Smithsonian Institution.
Bean, L.J. and F.C. Shipek. 1978. Luiseño. In Handbook of North American Indians, Vol. 8:
California, edited by R.F. Heizer, pp. 550–563. Washington, DC: Smithsonian Institution.
Beardsley, R.K. 1948. “Cultural Sequences in Central California Archaeology.” American Antiquity
14:1–28.
Bennyhoff, J. 1950. Californian Fish Spears and Harpoons. University of California Anthropological
Records 9(4):295–338.
Chartkoff J.L. and K.K. Chartkoff. 1984. The Archaeology of California. Menlo Park. Stanford
University Press.
Fagan, B.M. 2003. Before California: An Archaeologist Looks at Our Earliest Inhabitants. New York:
Alta Mira Press.
Frederickson, D.A. 1973. Early Cultures of the North Coast Ranges, California. Unpublished Ph.D.
dissertation, Department of Anthropology, University of California, Davis.
Heizer, R. F., ed. 1978. Handbook of North American Indians, Vol. 8: California. Washington, DC:
Smithsonian Institute.
Hudson, Travis, Janice Timbrook, and Melissa Rempe, ed. 1978. Historic Spots in California. Menlo
Park: Stanford University Press.
Kroeber, A.L. 1925. Handbook of the Indians of California. Bulletin 78. Bureau of American
Ethnology. Washington, DC: Smithsonian Institution.
Moratto, M.J. 1984. California Archaeology. San Diego. Academic Press.
O’Neil, S. 2002. The Acjachemen in the Franciscan Mission System: Demographic Collapse and
Social Change. Master Thesis, Department of Anthropology, CSU-Fullerton.
Strong, W.D. 1929. Aboriginal Society in Southern California. University of California Publications in
American Archaeology and Ethnology 26(1):1–358.
Tierra Environmental Services. 1999. Where Territories Merge: An Ethnohistoric and Ethnographic
Review of Traditional Native American Territories and Traditional Cultural Properties for
March Air Force Base, California. March AFB, California. On-line version.
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Wallace, W.J. 1955. “A Suggested Chronology for Southern California Coastal Archaeology.”
Southwestern Journal of Anthropology 11(3):214–230.
Warren, C.N. 1968. “Cultural Tradition and Ecological Adaptation on the Southern California Coast.”
Archaic Prehistory in the Western United States; C. Irwin-Will, editor.
City Terrace Associates, Ltd., L.P.—The Terrace Apartments
Cultural Resources Assessment
FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\5023\50230001\CRA\50230001 The Terrace Apts - CRA.docx
Appendix A:
Records Search
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THIS PAGE INTENTIONALLY LEFT BLANK
City Terrace Associates, Ltd., L.P.—The Terrace Apartments
Cultural Resources Assessment
FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\5023\50230001\CRA\50230001 The Terrace Apts - CRA.docx
Appendix B:
Native American Correspondence
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City Terrace Associates, Ltd., L.P.—The Terrace Apartments
Cultural Resources Assessment
FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\5023\50230001\CRA\50230001 The Terrace Apts - CRA.docx
B.1 - Native American Heritage Commission
Sacred Lands File Search
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City Terrace Associates, Ltd., L.P.—The Terrace Apartments
Cultural Resources Assessment
FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\5023\50230001\CRA\50230001 The Terrace Apts - CRA.docx
B.2 - Native American Information Request Letters
THIS PAGE INTENTIONALLY LEFT BLANK
North A
America | Euro
Septembe
Andrew S
Gabrielen
P.O. Box 3
Covina, CA
Subject:
Dear And
FirstCarbo
Study/Mit
bounded
to the we
The proje
existing p
construct
stalls. The
110,258 s
FCS condu
University
of the Nat
California
California
existence
According
within a ¼
search bu
The prope
Please no
and is not
the Natio
handled b
ope | Africa | A
er 15, 2017
alas
no Band of Mi
393
A, 91723
The Terr a
rew Salas,
on Solutions (
tigated Negat
by Chapman
st in the City
ct proposes t
roject has 44
ion of the pro
e project prop
square feet).
ucted a record
y, Fullerton, C
tional Registe
Historical La
State Histori
of previously
g to records o
¼ mile radius
ffer, but none
erty is entirely
ote that this le
t notification
nal Historic P
by designated
Australia | Asia
ission Indians
ace Apartmen
(FCS) is condu
tive Declarati
Avenue to th
of Orange, Ca
to develop an
1 apartment
oject will rem
poses to desig
d search at th
California. To
er of Historic P
ndmarks list (
c Resources I
y documented
on file at SCCIC
of the project
e included th
y built out at
etter is a req
of a project
Preservation
d lead agencie
a
‐ Kizh Nation
nts in the City
ucting a cultu
on (IS/MND)
he north, City
alifornia.
additional 19
units in eight
ove 302 stalls
gnate 15 perc
he South Cent
identify any h
Places (NR), t
(CHL), the Ca
nventory (HR
d local histori
C, no archaeo
t. There have
e project area
this time, the
uest for infor
under Senate
Act. Project
es under CEQA
y of Orange, C
ral resources
for an approx
Parkway Wes
97 residentia
t buildings. Th
s and add 719
cent of the pr
tral Coastal In
historic prope
the California
lifornia Points
RI) for Orange
cal resources
ological or his
e been six tech
a.
erefore, a ped
rmation perta
e Bill (SB) 18,
notification a
A and NEPA.
California
assessment
ximately 16.8
st to the sout
l dwelling un
here are 821
9 parking stal
oject are as o
nformation Ce
erties or reso
Register of H
s of Historica
e County were
s.
storical sites h
hnical studies
destrian surve
aining to a cu
, Assembly Bi
and consultat
www
in support of
88‐acre site. T
th and east, a
its in six new
existing parki
lls for a total
open space (a
enter, Califor
urces, the cu
Historic Resou
l Interest (CP
e reviewed to
have been rec
s conducted w
ey was not co
ultural resour
ill (AB) 52 or
ion requirem
w.firstcarbonso
Requ
f an Initial
The project sit
and S. Lewis S
structures. T
ing stalls, the
of 1,238 park
approximately
nia State
rrent invento
urces (CR), the
HI) list, and th
o determine t
corded on or
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onducted.
rces assessme
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ents are bein
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olutions.com
est Letter
te is
Street
The
king
y
ories
e
he
he
cords
ent
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ng
If you hav
relation to
contact m
assistance
Sincerely,
David M.
Project M
FirstCarbo
250 Comm
Irvine, CA
Enc: P
ve any additio
o the propose
me at 714.508
e.
Smith
Manager, Archa
on Solutions
merce, Suite 2
A 92602
roject Map
onal informati
ed project are
.4100 or via e
aeologist
250
ion regarding
ea, we would
email at dsmi
potential his
greatly appre
th@fcs‐intl.c
storic or cultu
eciate your in
om and than
ural resources
nput. Please f
k you for you
Requ
s in proximity
feel free to
ur valuable
est Letter
or
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America | Euroope | Africa | AAustralia | Asiaa www
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Records
w.firstcarbonso
ttachmen
s Search M
olutions.com
nt A:
Map
50230001 • 08/2017 | 2_topo.m xd
Exhibit 2Local Vicinity MapT opographic Base
Sourc e: USGS Anahe im (1981) 7.5' Quad rangle / Santiago d e Santa Ana Land Grant
CIT Y T ERRACE ASSOCIAT ES • T ERRACE APART MENT S CULT URLA RESOURCES ASSESSMENT
I 2,000 0 2,0001,000
Fee t
Legend
Project Site
North A
America | Euro
Septembe
Anthony M
Gabrielen
P.O. Box 6
San Gabri
Subject:
Dear Anth
FirstCarbo
Study/Mit
bounded
to the we
The proje
existing p
construct
stalls. The
110,258 s
FCS condu
University
of the Nat
California
California
existence
According
within a ¼
search bu
The prope
Please no
and is not
the Natio
handled b
ope | Africa | A
er 15, 2017
Morales
no/Tongva San
693
el, CA, 91778
The Terr a
hony Morales
on Solutions (
tigated Negat
by Chapman
st in the City
ct proposes t
roject has 44
ion of the pro
e project prop
square feet).
ucted a record
y, Fullerton, C
tional Registe
Historical La
State Histori
of previously
g to records o
¼ mile radius
ffer, but none
erty is entirely
ote that this le
t notification
nal Historic P
by designated
Australia | Asia
n Gabriel Band
8
ace Apartmen
s,
(FCS) is condu
tive Declarati
Avenue to th
of Orange, Ca
to develop an
1 apartment
oject will rem
poses to desig
d search at th
California. To
er of Historic P
ndmarks list (
c Resources I
y documented
on file at SCCIC
of the project
e included th
y built out at
etter is a req
of a project
Preservation
d lead agencie
a
d of Mission I
nts in the City
ucting a cultu
on (IS/MND)
he north, City
alifornia.
additional 19
units in eight
ove 302 stalls
gnate 15 perc
he South Cent
identify any h
Places (NR), t
(CHL), the Ca
nventory (HR
d local histori
C, no archaeo
t. There have
e project area
this time, the
uest for infor
under Senate
Act. Project
es under CEQA
ndians
y of Orange, C
ral resources
for an approx
Parkway Wes
97 residentia
t buildings. Th
s and add 719
cent of the pr
tral Coastal In
historic prope
the California
lifornia Points
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ological or his
e been six tech
a.
erefore, a ped
rmation perta
e Bill (SB) 18,
notification a
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California
assessment
ximately 16.8
st to the sout
l dwelling un
here are 821
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nformation Ce
erties or reso
Register of H
s of Historica
e County were
s.
storical sites h
hnical studies
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aining to a cu
, Assembly Bi
and consultat
www
in support of
88‐acre site. T
th and east, a
its in six new
existing parki
lls for a total
open space (a
enter, Califor
urces, the cu
Historic Resou
l Interest (CP
e reviewed to
have been rec
s conducted w
ey was not co
ultural resour
ill (AB) 52 or
ion requirem
w.firstcarbonso
Requ
f an Initial
The project sit
and S. Lewis S
structures. T
ing stalls, the
of 1,238 park
approximately
nia State
rrent invento
urces (CR), the
HI) list, and th
o determine t
corded on or
within the rec
onducted.
rces assessme
Section 106 o
ents are bein
1
olutions.com
est Letter
te is
Street
The
king
y
ories
e
he
he
cords
ent
of
ng
If you hav
relation to
contact m
assistance
Sincerely,
David M.
Project M
FirstCarbo
250 Comm
Irvine, CA
Enc: P
ve any additio
o the propose
me at 714.508
e.
Smith
Manager, Archa
on Solutions
merce, Suite 2
A 92602
roject Map
onal informati
ed project are
.4100 or via e
aeologist
250
ion regarding
ea, we would
email at dsmi
potential his
greatly appre
th@fcs‐intl.c
storic or cultu
eciate your in
om and than
ural resources
nput. Please f
k you for you
Requ
s in proximity
feel free to
ur valuable
est Letter
or
North A
America | Euroope | Africa | AAustralia | Asiaa www
At
Records
w.firstcarbonso
ttachmen
s Search M
olutions.com
nt A:
Map
50230001 • 08/2017 | 2_topo.m xd
Exhibit 2Local Vicinity MapT opographic Base
Sourc e: USGS Anahe im (1981) 7.5' Quad rangle / Santiago d e Santa Ana Land Grant
CIT Y T ERRACE ASSOCIAT ES • T ERRACE APART MENT S CULT URLA RESOURCES ASSESSMENT
I 2,000 0 2,0001,000
Fee t
Legend
Project Site
North A
America | Euro
Septembe
Sandonne
Gabrielino
106 1/2 Ju
Los Angel
Subject:
Dear Sand
FirstCarbo
Study/Mit
bounded
to the we
The proje
existing p
construct
stalls. The
110,258 s
FCS condu
University
of the Nat
California
California
existence
According
within a ¼
search bu
The prope
Please no
and is not
the Natio
handled b
ope | Africa | A
er 15, 2017
e Goad
o/Tongva Nat
udge John Ais
es, CA, 90012
The Terr a
donne Goad,
on Solutions (
tigated Negat
by Chapman
st in the City
ct proposes t
roject has 44
ion of the pro
e project prop
square feet).
ucted a record
y, Fullerton, C
tional Registe
Historical La
State Histori
of previously
g to records o
¼ mile radius
ffer, but none
erty is entirely
ote that this le
t notification
nal Historic P
by designated
Australia | Asia
tion
so St., #231
2
ace Apartmen
(FCS) is condu
tive Declarati
Avenue to th
of Orange, Ca
to develop an
1 apartment
oject will rem
poses to desig
d search at th
California. To
er of Historic P
ndmarks list (
c Resources I
y documented
on file at SCCIC
of the project
e included th
y built out at
etter is a req
of a project
Preservation
d lead agencie
a
nts in the City
ucting a cultu
on (IS/MND)
he north, City
alifornia.
additional 19
units in eight
ove 302 stalls
gnate 15 perc
he South Cent
identify any h
Places (NR), t
(CHL), the Ca
nventory (HR
d local histori
C, no archaeo
t. There have
e project area
this time, the
uest for infor
under Senate
Act. Project
es under CEQA
y of Orange, C
ral resources
for an approx
Parkway Wes
97 residentia
t buildings. Th
s and add 719
cent of the pr
tral Coastal In
historic prope
the California
lifornia Points
RI) for Orange
cal resources
ological or his
e been six tech
a.
erefore, a ped
rmation perta
e Bill (SB) 18,
notification a
A and NEPA.
California
assessment
ximately 16.8
st to the sout
l dwelling un
here are 821
9 parking stal
oject are as o
nformation Ce
erties or reso
Register of H
s of Historica
e County were
s.
storical sites h
hnical studies
destrian surve
aining to a cu
, Assembly Bi
and consultat
www
in support of
88‐acre site. T
th and east, a
its in six new
existing parki
lls for a total
open space (a
enter, Califor
urces, the cu
Historic Resou
l Interest (CP
e reviewed to
have been rec
s conducted w
ey was not co
ultural resour
ill (AB) 52 or
ion requirem
w.firstcarbonso
Requ
f an Initial
The project sit
and S. Lewis S
structures. T
ing stalls, the
of 1,238 park
approximately
nia State
rrent invento
urces (CR), the
HI) list, and th
o determine t
corded on or
within the rec
onducted.
rces assessme
Section 106 o
ents are bein
1
olutions.com
est Letter
te is
Street
The
king
y
ories
e
he
he
cords
ent
of
ng
If you hav
relation to
contact m
assistance
Sincerely,
David M.
Project M
FirstCarbo
250 Comm
Irvine, CA
Enc: P
ve any additio
o the propose
me at 714.508
e.
Smith
Manager, Archa
on Solutions
merce, Suite 2
A 92602
roject Map
onal informati
ed project are
.4100 or via e
aeologist
250
ion regarding
ea, we would
email at dsmi
potential his
greatly appre
th@fcs‐intl.c
storic or cultu
eciate your in
om and than
ural resources
nput. Please f
k you for you
Requ
s in proximity
feel free to
ur valuable
est Letter
or
North A
America | Euroope | Africa | AAustralia | Asiaa www
At
Records
w.firstcarbonso
ttachmen
s Search M
olutions.com
nt A:
Map
50230001 • 08/2017 | 2_topo.m xd
Exhibit 2Local Vicinity MapT opographic Base
Sourc e: USGS Anahe im (1981) 7.5' Quad rangle / Santiago d e Santa Ana Land Grant
CIT Y T ERRACE ASSOCIAT ES • T ERRACE APART MENT S CULT URLA RESOURCES ASSESSMENT
I 2,000 0 2,0001,000
Fee t
Legend
Project Site
North A
America | Euro
Septembe
Robert Do
Gabrielino
P.O. Box 4
Bellflower
Subject:
Dear Robe
FirstCarbo
Study/Mit
bounded
to the we
The proje
existing p
construct
stalls. The
110,258 s
FCS condu
University
of the Nat
California
California
existence
According
within a ¼
search bu
The prope
Please no
and is not
the Natio
handled b
ope | Africa | A
er 15, 2017
orame
o Tongva Indi
490
r, CA, 90707
The Terr a
ert Dorame,
on Solutions (
tigated Negat
by Chapman
st in the City
ct proposes t
roject has 44
ion of the pro
e project prop
square feet).
ucted a record
y, Fullerton, C
tional Registe
Historical La
State Histori
of previously
g to records o
¼ mile radius
ffer, but none
erty is entirely
ote that this le
t notification
nal Historic P
by designated
Australia | Asia
ans of Californ
ace Apartmen
(FCS) is condu
tive Declarati
Avenue to th
of Orange, Ca
to develop an
1 apartment
oject will rem
poses to desig
d search at th
California. To
er of Historic P
ndmarks list (
c Resources I
y documented
on file at SCCIC
of the project
e included th
y built out at
etter is a req
of a project
Preservation
d lead agencie
a
nia Tribal Cou
nts in the City
ucting a cultu
on (IS/MND)
he north, City
alifornia.
additional 19
units in eight
ove 302 stalls
gnate 15 perc
he South Cent
identify any h
Places (NR), t
(CHL), the Ca
nventory (HR
d local histori
C, no archaeo
t. There have
e project area
this time, the
uest for infor
under Senate
Act. Project
es under CEQA
uncil
y of Orange, C
ral resources
for an approx
Parkway Wes
97 residentia
t buildings. Th
s and add 719
cent of the pr
tral Coastal In
historic prope
the California
lifornia Points
RI) for Orange
cal resources
ological or his
e been six tech
a.
erefore, a ped
rmation perta
e Bill (SB) 18,
notification a
A and NEPA.
California
assessment
ximately 16.8
st to the sout
l dwelling un
here are 821
9 parking stal
oject are as o
nformation Ce
erties or reso
Register of H
s of Historica
e County were
s.
storical sites h
hnical studies
destrian surve
aining to a cu
, Assembly Bi
and consultat
www
in support of
88‐acre site. T
th and east, a
its in six new
existing parki
lls for a total
open space (a
enter, Califor
urces, the cu
Historic Resou
l Interest (CP
e reviewed to
have been rec
s conducted w
ey was not co
ultural resour
ill (AB) 52 or
ion requirem
w.firstcarbonso
Requ
f an Initial
The project sit
and S. Lewis S
structures. T
ing stalls, the
of 1,238 park
approximately
nia State
rrent invento
urces (CR), the
HI) list, and th
o determine t
corded on or
within the rec
onducted.
rces assessme
Section 106 o
ents are bein
1
olutions.com
est Letter
te is
Street
The
king
y
ories
e
he
he
cords
ent
of
ng
If you hav
relation to
contact m
assistance
Sincerely,
David M.
Project M
FirstCarbo
250 Comm
Irvine, CA
Enc: P
ve any additio
o the propose
me at 714.508
e.
Smith
Manager, Archa
on Solutions
merce, Suite 2
A 92602
roject Map
onal informati
ed project are
.4100 or via e
aeologist
250
ion regarding
ea, we would
email at dsmi
potential his
greatly appre
th@fcs‐intl.c
storic or cultu
eciate your in
om and than
ural resources
nput. Please f
k you for you
Requ
s in proximity
feel free to
ur valuable
est Letter
or
North A
America | Euroope | Africa | AAustralia | Asiaa www
At
Records
w.firstcarbonso
ttachmen
s Search M
olutions.com
nt A:
Map
50230001 • 08/2017 | 2_topo.m xd
Exhibit 2Local Vicinity MapT opographic Base
Sourc e: USGS Anahe im (1981) 7.5' Quad rangle / Santiago d e Santa Ana Land Grant
CIT Y T ERRACE ASSOCIAT ES • T ERRACE APART MENT S CULT URLA RESOURCES ASSESSMENT
I 2,000 0 2,0001,000
Fee t
Legend
Project Site
North A
America | Euro
Septembe
Charles A
Gabrielino
23454 Va n
West Hills
Subject:
Dear Char
FirstCarbo
Study/Mit
bounded
to the we
The proje
existing p
construct
stalls. The
110,258 s
FCS condu
University
of the Nat
California
California
existence
According
within a ¼
search bu
The prope
Please no
and is not
the Natio
handled b
ope | Africa | A
er 15, 2017
lvarez
o‐Tongva Tri b
nowen Street
s, CA 91307
The Terr a
rles Alvarez,
on Solutions (
tigated Negat
by Chapman
st in the City
ct proposes t
roject has 44
ion of the pro
e project prop
square feet).
ucted a record
y, Fullerton, C
tional Registe
Historical La
State Histori
of previously
g to records o
¼ mile radius
ffer, but none
erty is entirely
ote that this le
t notification
nal Historic P
by designated
Australia | Asia
be
t
ace Apartmen
(FCS) is condu
tive Declarati
Avenue to th
of Orange, Ca
to develop an
1 apartment
oject will rem
poses to desig
d search at th
California. To
er of Historic P
ndmarks list (
c Resources I
y documented
on file at SCCIC
of the project
e included th
y built out at
etter is a req
of a project
Preservation
d lead agencie
a
nts in the City
ucting a cultu
on (IS/MND)
he north, City
alifornia.
additional 19
units in eight
ove 302 stalls
gnate 15 perc
he South Cent
identify any h
Places (NR), t
(CHL), the Ca
nventory (HR
d local histori
C, no archaeo
t. There have
e project area
this time, the
uest for infor
under Senate
Act. Project
es under CEQA
y of Orange, C
ral resources
for an approx
Parkway Wes
97 residentia
t buildings. Th
s and add 719
cent of the pr
tral Coastal In
historic prope
the California
lifornia Points
RI) for Orange
cal resources
ological or his
e been six tech
a.
erefore, a ped
rmation perta
e Bill (SB) 18,
notification a
A and NEPA.
California
assessment
ximately 16.8
st to the sout
l dwelling un
here are 821
9 parking stal
oject are as o
nformation Ce
erties or reso
Register of H
s of Historica
e County were
s.
storical sites h
hnical studies
destrian surve
aining to a cu
, Assembly Bi
and consultat
www
in support of
88‐acre site. T
th and east, a
its in six new
existing parki
lls for a total
open space (a
enter, Califor
urces, the cu
Historic Resou
l Interest (CP
e reviewed to
have been rec
s conducted w
ey was not co
ultural resour
ill (AB) 52 or
ion requirem
w.firstcarbonso
Requ
f an Initial
The project sit
and S. Lewis S
structures. T
ing stalls, the
of 1,238 park
approximately
nia State
rrent invento
urces (CR), the
HI) list, and th
o determine t
corded on or
within the rec
onducted.
rces assessme
Section 106 o
ents are bein
1
olutions.com
est Letter
te is
Street
The
king
y
ories
e
he
he
cords
ent
of
ng
If you hav
relation to
contact m
assistance
Sincerely,
David M.
Project M
FirstCarbo
250 Comm
Irvine, CA
Enc: P
ve any additio
o the propose
me at 714.508
e.
Smith
Manager, Archa
on Solutions
merce, Suite 2
A 92602
roject Map
onal informati
ed project are
.4100 or via e
aeologist
250
ion regarding
ea, we would
email at dsmi
potential his
greatly appre
th@fcs‐intl.c
storic or cultu
eciate your in
om and than
ural resources
nput. Please f
k you for you
Requ
s in proximity
feel free to
ur valuable
est Letter
or
North A
America | Euroope | Africa | AAustralia | Asiaa www
At
Records
w.firstcarbonso
ttachmen
s Search M
olutions.com
nt A:
Map
50230001 • 08/2017 | 2_topo.m xd
Exhibit 2Local Vicinity MapT opographic Base
Sourc e: USGS Anahe im (1981) 7.5' Quad rangle / Santiago d e Santa Ana Land Grant
CIT Y T ERRACE ASSOCIAT ES • T ERRACE APART MENT S CULT URLA RESOURCES ASSESSMENT
I 2,000 0 2,0001,000
Fee t
Legend
Project Site
North A
America | Euro
Septembe
Sonia Joh
Juaneno B
P.O. Box 2
Santa Ana
Subject:
Dear Soni
FirstCarbo
Study/Mit
bounded
to the we
The proje
existing p
construct
stalls. The
110,258 s
FCS condu
University
of the Nat
California
California
existence
According
within a ¼
search bu
The prope
Please no
and is not
the Natio
handled b
ope | Africa | A
er 15, 2017
nston
Band of Missi
25628
a, CA, 92799
The Terr a
a Johnston,
on Solutions (
tigated Negat
by Chapman
st in the City
ct proposes t
roject has 44
ion of the pro
e project prop
square feet).
ucted a record
y, Fullerton, C
tional Registe
Historical La
State Histori
of previously
g to records o
¼ mile radius
ffer, but none
erty is entirely
ote that this le
t notification
nal Historic P
by designated
Australia | Asia
on Indians
ace Apartmen
(FCS) is condu
tive Declarati
Avenue to th
of Orange, Ca
to develop an
1 apartment
oject will rem
poses to desig
d search at th
California. To
er of Historic P
ndmarks list (
c Resources I
y documented
on file at SCCIC
of the project
e included th
y built out at
etter is a req
of a project
Preservation
d lead agencie
a
nts in the City
ucting a cultu
on (IS/MND)
he north, City
alifornia.
additional 19
units in eight
ove 302 stalls
gnate 15 perc
he South Cent
identify any h
Places (NR), t
(CHL), the Ca
nventory (HR
d local histori
C, no archaeo
t. There have
e project area
this time, the
uest for infor
under Senate
Act. Project
es under CEQA
y of Orange, C
ral resources
for an approx
Parkway Wes
97 residentia
t buildings. Th
s and add 719
cent of the pr
tral Coastal In
historic prope
the California
lifornia Points
RI) for Orange
cal resources
ological or his
e been six tech
a.
erefore, a ped
rmation perta
e Bill (SB) 18,
notification a
A and NEPA.
California
assessment
ximately 16.8
st to the sout
l dwelling un
here are 821
9 parking stal
oject are as o
nformation Ce
erties or reso
Register of H
s of Historica
e County were
s.
storical sites h
hnical studies
destrian surve
aining to a cu
, Assembly Bi
and consultat
www
in support of
88‐acre site. T
th and east, a
its in six new
existing parki
lls for a total
open space (a
enter, Califor
urces, the cu
Historic Resou
l Interest (CP
e reviewed to
have been rec
s conducted w
ey was not co
ultural resour
ill (AB) 52 or
ion requirem
w.firstcarbonso
Requ
f an Initial
The project sit
and S. Lewis S
structures. T
ing stalls, the
of 1,238 park
approximately
nia State
rrent invento
urces (CR), the
HI) list, and th
o determine t
corded on or
within the rec
onducted.
rces assessme
Section 106 o
ents are bein
1
olutions.com
est Letter
te is
Street
The
king
y
ories
e
he
he
cords
ent
of
ng
If you hav
relation to
contact m
assistance
Sincerely,
David M.
Project M
FirstCarbo
250 Comm
Irvine, CA
Enc: P
ve any additio
o the propose
me at 714.508
e.
Smith
Manager, Archa
on Solutions
merce, Suite 2
A 92602
roject Map
onal informati
ed project are
.4100 or via e
aeologist
250
ion regarding
ea, we would
email at dsmi
potential his
greatly appre
th@fcs‐intl.c
storic or cultu
eciate your in
om and than
ural resources
nput. Please f
k you for you
Requ
s in proximity
feel free to
ur valuable
est Letter
or
North A
America | Euroope | Africa | AAustralia | Asiaa www
At
Records
w.firstcarbonso
ttachmen
s Search M
olutions.com
nt A:
Map
50230001 • 08/2017 | 2_topo.m xd
Exhibit 2Local Vicinity MapT opographic Base
Sourc e: USGS Anahe im (1981) 7.5' Quad rangle / Santiago d e Santa Ana Land Grant
CIT Y T ERRACE ASSOCIAT ES • T ERRACE APART MENT S CULT URLA RESOURCES ASSESSMENT
I 2,000 0 2,0001,000
Fee t
Legend
Project Site
North A
America | Euro
Septembe
Matias Be
Juaneno B
32161 Ave
San Juan C
Subject:
Dear Mat
FirstCarbo
Study/Mit
bounded
to the we
The proje
existing p
construct
stalls. The
110,258 s
FCS condu
University
of the Nat
California
California
existence
According
within a ¼
search bu
The prope
Please no
and is not
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handled b
ope | Africa | A
er 15, 2017
elardes
Band of Missi
enida Los Am
Capistrano, C
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ias Belardes,
on Solutions (
tigated Negat
by Chapman
st in the City
ct proposes t
roject has 44
ion of the pro
e project prop
square feet).
ucted a record
y, Fullerton, C
tional Registe
Historical La
State Histori
of previously
g to records o
¼ mile radius
ffer, but none
erty is entirely
ote that this le
t notification
nal Historic P
by designated
Australia | Asia
on Indians Ac
migos
CA, 92675
ace Apartmen
(FCS) is condu
tive Declarati
Avenue to th
of Orange, Ca
to develop an
1 apartment
oject will rem
poses to desig
d search at th
California. To
er of Historic P
ndmarks list (
c Resources I
y documented
on file at SCCIC
of the project
e included th
y built out at
etter is a req
of a project
Preservation
d lead agencie
a
cjachemen Na
nts in the City
ucting a cultu
on (IS/MND)
he north, City
alifornia.
additional 19
units in eight
ove 302 stalls
gnate 15 perc
he South Cent
identify any h
Places (NR), t
(CHL), the Ca
nventory (HR
d local histori
C, no archaeo
t. There have
e project area
this time, the
uest for infor
under Senate
Act. Project
es under CEQA
ation ‐ Belard
y of Orange, C
ral resources
for an approx
Parkway Wes
97 residentia
t buildings. Th
s and add 719
cent of the pr
tral Coastal In
historic prope
the California
lifornia Points
RI) for Orange
cal resources
ological or his
e been six tech
a.
erefore, a ped
rmation perta
e Bill (SB) 18,
notification a
A and NEPA.
des
California
assessment
ximately 16.8
st to the sout
l dwelling un
here are 821
9 parking stal
oject are as o
nformation Ce
erties or reso
Register of H
s of Historica
e County were
s.
storical sites h
hnical studies
destrian surve
aining to a cu
, Assembly Bi
and consultat
www
in support of
88‐acre site. T
th and east, a
its in six new
existing parki
lls for a total
open space (a
enter, Califor
urces, the cu
Historic Resou
l Interest (CP
e reviewed to
have been rec
s conducted w
ey was not co
ultural resour
ill (AB) 52 or
ion requirem
w.firstcarbonso
Requ
f an Initial
The project sit
and S. Lewis S
structures. T
ing stalls, the
of 1,238 park
approximately
nia State
rrent invento
urces (CR), the
HI) list, and th
o determine t
corded on or
within the rec
onducted.
rces assessme
Section 106 o
ents are bein
1
olutions.com
est Letter
te is
Street
The
king
y
ories
e
he
he
cords
ent
of
ng
If you hav
relation to
contact m
assistance
Sincerely,
David M.
Project M
FirstCarbo
250 Comm
Irvine, CA
Enc: P
ve any additio
o the propose
me at 714.508
e.
Smith
Manager, Archa
on Solutions
merce, Suite 2
A 92602
roject Map
onal informati
ed project are
.4100 or via e
aeologist
250
ion regarding
ea, we would
email at dsmi
potential his
greatly appre
th@fcs‐intl.c
storic or cultu
eciate your in
om and than
ural resources
nput. Please f
k you for you
Requ
s in proximity
feel free to
ur valuable
est Letter
or
North A
America | Euroope | Africa | AAustralia | Asiaa www
At
Records
w.firstcarbonso
ttachmen
s Search M
olutions.com
nt A:
Map
50230001 • 08/2017 | 2_topo.m xd
Exhibit 2Local Vicinity MapT opographic Base
Sourc e: USGS Anahe im (1981) 7.5' Quad rangle / Santiago d e Santa Ana Land Grant
CIT Y T ERRACE ASSOCIAT ES • T ERRACE APART MENT S CULT URLA RESOURCES ASSESSMENT
I 2,000 0 2,0001,000
Fee t
Legend
Project Site
North A
America | Euro
Septembe
Joyce Perr
Juaneno B
4955 Pase
Irvine, CA
Subject:
Dear Joyc
FirstCarbo
Study/Mit
bounded
to the we
The proje
existing p
construct
stalls. The
110,258 s
FCS condu
University
of the Nat
California
California
existence
According
within a ¼
search bu
The prope
Please no
and is not
the Natio
handled b
ope | Africa | A
er 15, 2017
ry
Band of Missi
eo Segovia
A, 92603
The Terr a
e Perry,
on Solutions (
tigated Negat
by Chapman
st in the City
ct proposes t
roject has 44
ion of the pro
e project prop
square feet).
ucted a record
y, Fullerton, C
tional Registe
Historical La
State Histori
of previously
g to records o
¼ mile radius
ffer, but none
erty is entirely
ote that this le
t notification
nal Historic P
by designated
Australia | Asia
on Indians Ac
ace Apartmen
(FCS) is condu
tive Declarati
Avenue to th
of Orange, Ca
to develop an
1 apartment
oject will rem
poses to desig
d search at th
California. To
er of Historic P
ndmarks list (
c Resources I
y documented
on file at SCCIC
of the project
e included th
y built out at
etter is a req
of a project
Preservation
d lead agencie
a
cjachemen Na
nts in the City
ucting a cultu
on (IS/MND)
he north, City
alifornia.
additional 19
units in eight
ove 302 stalls
gnate 15 perc
he South Cent
identify any h
Places (NR), t
(CHL), the Ca
nventory (HR
d local histori
C, no archaeo
t. There have
e project area
this time, the
uest for infor
under Senate
Act. Project
es under CEQA
ation ‐ Belard
y of Orange, C
ral resources
for an approx
Parkway Wes
97 residentia
t buildings. Th
s and add 719
cent of the pr
tral Coastal In
historic prope
the California
lifornia Points
RI) for Orange
cal resources
ological or his
e been six tech
a.
erefore, a ped
rmation perta
e Bill (SB) 18,
notification a
A and NEPA.
des
California
assessment
ximately 16.8
st to the sout
l dwelling un
here are 821
9 parking stal
oject are as o
nformation Ce
erties or reso
Register of H
s of Historica
e County were
s.
storical sites h
hnical studies
destrian surve
aining to a cu
, Assembly Bi
and consultat
www
in support of
88‐acre site. T
th and east, a
its in six new
existing parki
lls for a total
open space (a
enter, Califor
urces, the cu
Historic Resou
l Interest (CP
e reviewed to
have been rec
s conducted w
ey was not co
ultural resour
ill (AB) 52 or
ion requirem
w.firstcarbonso
Requ
f an Initial
The project sit
and S. Lewis S
structures. T
ing stalls, the
of 1,238 park
approximately
nia State
rrent invento
urces (CR), the
HI) list, and th
o determine t
corded on or
within the rec
onducted.
rces assessme
Section 106 o
ents are bein
1
olutions.com
est Letter
te is
Street
The
king
y
ories
e
he
he
cords
ent
of
ng
If you hav
relation to
contact m
assistance
Sincerely,
David M.
Project M
FirstCarbo
250 Comm
Irvine, CA
Enc: P
ve any additio
o the propose
me at 714.508
e.
Smith
Manager, Archa
on Solutions
merce, Suite 2
A 92602
roject Map
onal informati
ed project are
.4100 or via e
aeologist
250
ion regarding
ea, we would
email at dsmi
potential his
greatly appre
th@fcs‐intl.c
storic or cultu
eciate your in
om and than
ural resources
nput. Please f
k you for you
Requ
s in proximity
feel free to
ur valuable
est Letter
or
North A
America | Euroope | Africa | AAustralia | Asiaa www
At
Records
w.firstcarbonso
ttachmen
s Search M
olutions.com
nt A:
Map
50230001 • 08/2017 | 2_topo.m xd
Exhibit 2Local Vicinity MapT opographic Base
Sourc e: USGS Anahe im (1981) 7.5' Quad rangle / Santiago d e Santa Ana Land Grant
CIT Y T ERRACE ASSOCIAT ES • T ERRACE APART MENT S CULT URLA RESOURCES ASSESSMENT
I 2,000 0 2,0001,000
Fee t
Legend
Project Site
North A
America | Euro
Septembe
Teresa Ro
Juaneno B
31411‐A L
San Juan C
Subject:
Dear Ter e
FirstCarbo
Study/Mit
bounded
to the we
The proje
existing p
construct
stalls. The
110,258 s
FCS condu
University
of the Nat
California
California
existence
According
within a ¼
search bu
The prope
Please no
and is not
the Natio
handled b
ope | Africa | A
er 15, 2017
mero
Band of Missi
La Matanza St
Capistrano, C
The Terr a
sa Romero,
on Solutions (
tigated Negat
by Chapman
st in the City
ct proposes t
roject has 44
ion of the pro
e project prop
square feet).
ucted a record
y, Fullerton, C
tional Registe
Historical La
State Histori
of previously
g to records o
¼ mile radius
ffer, but none
erty is entirely
ote that this le
t notification
nal Historic P
by designated
Australia | Asia
on Indians Ac
treet
CA, 92675
ace Apartmen
(FCS) is condu
tive Declarati
Avenue to th
of Orange, Ca
to develop an
1 apartment
oject will rem
poses to desig
d search at th
California. To
er of Historic P
ndmarks list (
c Resources I
y documented
on file at SCCIC
of the project
e included th
y built out at
etter is a req
of a project
Preservation
d lead agencie
a
cjachemen Na
nts in the City
ucting a cultu
on (IS/MND)
he north, City
alifornia.
additional 19
units in eight
ove 302 stalls
gnate 15 perc
he South Cent
identify any h
Places (NR), t
(CHL), the Ca
nventory (HR
d local histori
C, no archaeo
t. There have
e project area
this time, the
uest for infor
under Senate
Act. Project
es under CEQA
ation ‐ Romer
y of Orange, C
ral resources
for an approx
Parkway Wes
97 residentia
t buildings. Th
s and add 719
cent of the pr
tral Coastal In
historic prope
the California
lifornia Points
RI) for Orange
cal resources
ological or his
e been six tech
a.
erefore, a ped
rmation perta
e Bill (SB) 18,
notification a
A and NEPA.
ro
California
assessment
ximately 16.8
st to the sout
l dwelling un
here are 821
9 parking stal
oject are as o
nformation Ce
erties or reso
Register of H
s of Historica
e County were
s.
storical sites h
hnical studies
destrian surve
aining to a cu
, Assembly Bi
and consultat
www
in support of
88‐acre site. T
th and east, a
its in six new
existing parki
lls for a total
open space (a
enter, Califor
urces, the cu
Historic Resou
l Interest (CP
e reviewed to
have been rec
s conducted w
ey was not co
ultural resour
ill (AB) 52 or
ion requirem
w.firstcarbonso
Requ
f an Initial
The project sit
and S. Lewis S
structures. T
ing stalls, the
of 1,238 park
approximately
nia State
rrent invento
urces (CR), the
HI) list, and th
o determine t
corded on or
within the rec
onducted.
rces assessme
Section 106 o
ents are bein
1
olutions.com
est Letter
te is
Street
The
king
y
ories
e
he
he
cords
ent
of
ng
If you hav
relation to
contact m
assistance
Sincerely,
David M.
Project M
FirstCarbo
250 Comm
Irvine, CA
Enc: P
ve any additio
o the propose
me at 714.508
e.
Smith
Manager, Archa
on Solutions
merce, Suite 2
A 92602
roject Map
onal informati
ed project are
.4100 or via e
aeologist
250
ion regarding
ea, we would
email at dsmi
potential his
greatly appre
th@fcs‐intl.c
storic or cultu
eciate your in
om and than
ural resources
nput. Please f
k you for you
Requ
s in proximity
feel free to
ur valuable
est Letter
or
North A
America | Euroope | Africa | AAustralia | Asiaa www
At
Records
w.firstcarbonso
ttachmen
s Search M
olutions.com
nt A:
Map
50230001 • 08/2017 | 2_topo.m xd
Exhibit 2Local Vicinity MapT opographic Base
Sourc e: USGS Anahe im (1981) 7.5' Quad rangle / Santiago d e Santa Ana Land Grant
CIT Y T ERRACE ASSOCIAT ES • T ERRACE APART MENT S CULT URLA RESOURCES ASSESSMENT
I 2,000 0 2,0001,000
Fee t
Legend
Project Site
City Terrace Associates, Ltd., L.P.—The Terrace Apartments
Cultural Resources Assessment
FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\5023\50230001\CRA\50230001 The Terrace Apts - CRA.docx
B.3 - Native American Information Request Letter Responses
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Gabrieleno Band of Mission Indians <gabrielenoindians@yahoo.com>
to me
Click here to Reply or Forward
Dear David M. Smith,
Mr. Salas would like to go over the above project. If you have any questions please feel free to contact us at
Sincerely,
Brandy Salas
Andrew Salas, Chairman
Gabrieleno Band of Mission Indians - Kizh Nation
PO Box 393
Covina, CA 91723
Office: 844-390-0787
Cell: (626)926-4131
Email: gabrielenoindians@yahoo.com
website: www.gabrielenoindians.org
MoreMail
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City Terrace Associates, Ltd., L.P.—The Terrace Apartments
Cultural Resources Assessment
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Appendix C:
Paleontological Report
THIS PAGE INTENTIONALLY LEFT BLANK
Vertebrate Paleontology Section
Telephone: (213) 763-3325
e-mail: smcleod@nhm.org
1 September 2017
FirstCarbon Solutions
250 Commerce, Suite 250
Irvine, CA 92602
Attn: David M. Smith, Project Manager, Archaeologist
re: Paleontological resources for the proposed Terrace Apartments Project, in the City of Orange,
Orange County, project area
Dear David:
I have conducted a thorough search of our paleontology collection records for the locality
and specimen data for the proposed Terrace Apartments Project, in the City of Orange, Orange
County, project area as outlined on the portion of the Anaheim USGS topographic quadrangle map
that you sent to me via e-mail on 15 August 2017. We do not have any vertebrate fossil localities
that lie within the project boundaries, but we do have localities nearby from the same sedimentary
units that occur as subsurface deposits in the proposed project area.
Surficial sediments at the proposed project site and in the surrounding area consist of younger
terrestrial Quaternary Alluvium, with older terrestrial Quaternary sediments occurring at various
depths, as part of the general floodplain of the Santa Ana River that flows just east of the proposed
project area. These younger Quaternary deposits typically do not contain significant vertebrate
fossils in the uppermost layers, but we have a vertebrate fossil locality, LACM 1652, along Rio Vista
Avenue south of Lincoln Avenue north-northeast of the proposed project area, that produced a fossil
specimen of sheep, Ovis. Our closest vertebrate fossil locality in older Quaternary sediments is
LACM 4943, situated almost due east of locality LACM 1652 along Fletcher Avenue east of Glassell
Street east of the Santa Ana River, that produced a specimen of fossil horse, Equus, at a depth of 8-
10 feet below the surface.
Grading or very shallow excavations in the uppermost few feet of the younger Quaternary
alluvial sediments in the proposed project site area are unlikely to uncover significant fossil
vertebrate remains. Deeper excavations at the proposed project site area that extend down into older
deposits, however, may well encounter significant vertebrate fossils. Any substantial excavations
below the uppermost layers, therefore, should be closely monitored to quickly and professionally
collect any specimens without impeding development. Sediment samples should also be collected
and processed to determine the small fossil potential in the proposed project area. Any fossils
recovered during mitigation should be deposited in an accredited and permanent scientific institution
for the benefit of current and future generations.
This records search covers only the vertebrate paleontology records of the Natural History
Museum of Los Angeles County. It is not intended to be a thorough paleontological survey of the
proposed project area covering other institutional records, a literature survey, or any potential on-site
survey.
Sincerely,
Samuel A. McLeod, Ph.D.
Vertebrate Paleontology
enclosure: invoice
City Terrace Associates, Ltd., L.P.—The Terrace Apartments
Cultural Resources Assessment
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Y:\Publications\Client (PN-JN)\5023\50230001\CRA\50230001 The Terrace Apts - CRA.docx
Appendix D:
Regulatory Framework
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City Terrace Associates, Ltd., L.P.—The Terrace Apartments
Cultural Resources Assessment
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Y:\Publications\Client (PN-JN)\5023\50230001\CRA\50230001 The Terrace Apts - CRA.docx
REGULATORY FRAMEWORK
Government agencies, including federal, state, and local agencies, have developed laws and
regulations designed to protect significant cultural resources that may be affected by projects
regulated, funded, or undertaken by the agency. Federal and state laws that govern the preservation
of historic and archaeological resources of national, state, regional, and local significance include the
National Environmental Policy Act (NEPA), the National Historic Preservation Act (NHPA), and the
California Environmental Quality Act (CEQA). In addition, laws specific to work conducted on federal
lands includes the Archaeological Resources Protection Act (ARPA), the American Antiquities Act,
and the Native American Graves Protection and Repatriation Act (NAGPRA).
The following Federal or CEQA criteria were used to evaluate the significance of potential impacts on
cultural resources for the proposed project. An impact would be considered significant if it would
affect a resource eligible for listing in the National Register of Historic Places (NRHP) or the California
Register of Historical Resources (CR), or if it is identified as a unique archaeological resource.
Federal-Level Evaluations
Federal agencies are required to consider the effects of their actions on historic properties and
afford the Advisory Council on Historic Preservation (ACHP) a reasonable opportunity to comment
on such undertakings under NEPA § 106. Federal agencies are responsible for initiating NEPA § 106
review and completing the steps in the process that are outlined in the regulations. They must
determine if NHPA § 106 applies to a given project and, if so, initiate review in consultation with the
State Historic Preservation Officer (SHPO) and/or Tribal Historic Preservation Officer (THPO). Federal
agencies are also responsible for involving the public and other interested parties. Furthermore,
NHPA S106 requires that any federal or federally assisted undertaking, or any undertaking requiring
federal licensing or permitting, consider the effect of the action on historic properties listed in or
eligible for the NRHP. Under the Code of Federal Regulations (CFR), 36 CFR Part 800.8, federal
agencies are specifically encouraged to coordinate compliance with NEPA § 106 and the NEPA
process. The implementing regulations “Protection of Historic Properties” are found in 36 CFR Part
800. Resource eligibility for listing on the NRHP is detailed in 36 CFR Part 63 and the criteria for
resource evaluation are found in 36 CFR Part 60.4 [a-d].
The NHPA established the NRHP as the official federal list for cultural resources that are considered
important for their historical significance at the local, state, or national level. To be determined
eligible for listing in the NRHP, properties must meet specific criteria for historic significance and
possess certain levels of integrity of form, location, and setting. The criteria for listing on the NRHP
are significance in American history, architecture, archaeology, engineering, and culture as present in
districts, sites, buildings, structures and objects that possess integrity of location, design, setting,
materials, workmanship, feeling, and association. In addition, a resource must meet one or all of
these eligibility criteria:
a.) Is associated with events that have made a significant contribution to the broad patterns of
our history.
City Terrace Associates, Ltd., L.P.—The Terrace Apartments
Cultural Resources Assessment
FirstCarbon Solutions
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b.) Is associated with the lives of persons significant in our past.
c.) Embodies the distinctive characteristics of a type, period, or method of construction;
represent the work of a master; possess high artistic values, represent a significant and
distinguishable entity whose components may lack individual distinction.
d.) That have yielded, or may be likely to yield, information important in prehistory or history.
Criterion D is usually reserved for archaeological resources. Eligible properties must meet at least
one of the criteria and exhibit integrity, measured by the degree to which the resource retains its
historical properties and conveys its historical character.
Criteria Considerations
Ordinarily cemeteries, birthplaces, graves of historical figures, properties owned by religious
institutions or used for religious purposes, buildings that have been moved from their original
locations, reconstructed historic buildings, properties primarily commemorative in nature, and
properties that have achieved significance within the past 50 years shall not be considered eligible
for the NRHP. However, such properties will qualify if they are integral parts of districts that do meet
the criteria or if they fall within the following categories:
a.) A religious property deriving primary significance from architectural or artistic distinction or
historical importance.
b.) A building or structure removed from its original location but which is primarily significant
for architectural value, or which is the surviving structure most importantly associated with
a historic person or event.
c.) A birthplace or grave of a historical figure of outstanding importance if there is no
appropriate site or building associated with his or her productive life.
d.) A cemetery that derives its primary importance from graves of persons of transcendent
importance, from age, from distinctive design features, or from association with historic
events.
e.) A reconstructed building when accurately executed in a suitable environment and
presented in a dignified manner as part of a restoration master plan, and when no other
building or structure with the same association has survived.
f.) A property primarily commemorative in intent if design, age, tradition, or symbolic value
has invested it with its own exceptional significance.
g.) A property achieving significance within the past 50 years if it is of exceptional importance.
Thresholds of Significance
In consultation with the SHPO/THPO and other entities that attach religious and cultural significance
to identified historic properties, the Agency shall apply the criteria of adverse effect to historic
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properties within the Area of Potential Effect (APE). The Agency official shall consider the views of
consulting parties and the public when considering adverse effects.
Federal Criteria of Adverse Effects
Under federal regulations, 36 CFR Part 800.5, an adverse effect is found when an undertaking alters,
directly or indirectly, any of the characteristics of a historic property that qualifies the property for
inclusion in the NRHP in a manner that diminishes the integrity of the property’s location, design,
setting, materials, workmanship, feeling, or association. Consideration will be given to all qualifying
characteristics of a historic property, including those that may have been identified subsequent to
the original evaluation of the property’s eligibility for listing in the NRHP. Adverse effects may
include reasonably foreseeable effects caused by the undertaking that may occur later in time, be
farther removed in distance, or be cumulative.
According to 36 CFR Part 800.5, adverse effects on historic properties include, but are not limited to,
those listed below:
• Physical destruction of or damage to all or part of the property.
• Alteration of a property, including restoration, rehabilitation, repair, maintenance,
stabilization, hazardous material remediation, and provision of handicapped access, that is not
consistent with the U.S. Secretary of the Interior’s Standards for the Treatment of Historic
Properties per 36 CFR Part 68 and applicable guidelines.
• Removal of the property from its historic location.
• Change of the character of the property’s use or of physical features within the property’s
setting that contribute to its historic significance.
• Introduction of visual, atmospheric, or audible elements that diminish the integrity of the
property’s significant historic features.
• Neglect of a property that causes its deterioration, except where such neglect and
deterioration are recognized qualities of a property of religious and cultural significance to an
Indian tribe or Native Hawaiian organization.
• Transfer, lease, or sale of property out of federal ownership or control without adequate and
legally enforceable restrictions or conditions to ensure long term preservation of the
property’s historic significance.
If Adverse Effects Are Found
If adverse effects are found, the agency official shall continue consultation as stipulated at 36 CFR
Part 800.6. The agency official shall consult with the SHPO/THPO and other consulting parties to
develop alternatives to the undertaking that could avoid, minimize, or mitigate adverse effects to
historic resources. According to 36 CFR Part 800.14(d), if adverse effects cannot be avoided then
standard treatments established by the ACHP may be used as a basis for Memorandum of
Agreement (MOA).
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According to 36 CFR Part 800.11(e), the filing of an approved MOA, and appropriate documentation,
concludes the § 106 process. The MOA must be signed by all consulting parties and approved by the
ACHP prior to construction activities. If no adverse effects are found and the SHPO/THPO or the
ACHP do not object within 30 days of receipt, the agencies’ responsibilities under § 106 will be
satisfied upon completion of report and documentation as stipulated in 36 CFR Part 800.11. The
information must be made available for public review upon request, excluding information covered
by confidentiality provisions.
State-Level Evaluation Processes
An archaeological site may be considered an historical resource if it is significant in the architectural,
engineering, scientific, economic, agricultural, educational, social, political, military or cultural annals
of California per PRC § 5020.1(j) or if it meets the criteria for listing on the CR per California Code of
Regulations (CCR) at Title 14 CCR § 4850.
The most recent amendments to the CEQA guidelines direct lead agencies to first evaluate an
archaeological site to determine if it meets the criteria for listing in the CR. If an archaeological site
is an historical resource, in that it is listed or eligible for listing in the CR, potential adverse impacts to
it must be considered as stated in PRC §§ 21084.1 and 21083.2(l). If an archaeological site is
considered not to be an historical resource, but meets the definition of a “unique archeological
resource” as defined in PRC § 21083.2, then it would be treated in accordance with the provisions of
that section.
With reference to PRC § 21083.2, each site found within a project area will be evaluated to
determine if it is a unique archaeological resource. A unique archaeological resource is described as
an archaeological artifact, object, or site about which it can be clearly demonstrated that, without
merely adding to the current body of knowledge, there is a high probability that it meets one or
more of the following criteria:
1. Contains information needed to answer important scientific research questions and that
there is a demonstrable public interest in that information.
2. Has a special and particular quality such as being the oldest of its type or the best available
example of its type.
3. Is directly associated with a scientifically recognized important prehistoric or historic event
or person.
As used in this report, “non-unique archaeological resource” means an archaeological artifact,
object, or site that does not meet the criteria for eligibility for listing on the CR, as noted in
subdivision (g) of PRC § 21083.2. A non-unique archaeological resource requires no further
consideration, other than simple recording of its components and features. Isolated artifacts are
typically considered non-unique archaeological resources. Historic structures that have had their
superstructures demolished or removed can be considered historic archaeological sites and are
evaluated following the processes used for prehistoric sites. Finally, OHP recognizes an age
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threshold of 45 years. Cultural resources built less than 45 years ago may qualify for consideration,
but only under the most extraordinary circumstances.
Title 14, CCR, Chapter 3 § 15064.5 is associated with determining the significance of impacts to
archaeological and historical resources. Here, the term historical resource includes the following:
1. A resource listed in, or determined eligible by the State Historical Resources Commission,
for listing in the CR (PRC § 5024.1; Title 14 CCR, § 4850 et seq.).
2. A resource included in a local register of historical resources, as defined in PRC § 5020.1(k)
or identified as significant in an historical resource survey meeting the PRC § 5024.1(g)
requirements, shall be presumed to be historically or culturally significant. Public agencies
must treat any such resource as significant unless the preponderance of evidence
demonstrates that it is not historically or culturally significant.
3. Any object, building, structure, site, area, place, record, or manuscript, which a lead agency
determines to be historically significant or significant in the architectural, engineering,
scientific, economic, agricultural, educational, social, political, military, or cultural annals of
California may be considered a historical resource, provided the lead agency’s
determination is supported by substantial evidence in light of the whole record. Generally,
a resource shall be considered by the lead agency to be historically significant if the
resource meets the criteria for listing on the California Register of Historical Resources (PRC
§ 5024.1; Title 14 CCR § 4852) including the following:
A. Is associated with events that have made a significant contribution to the broad patterns
of California’s history and cultural heritage.
B. Is associated with the lives of persons important in our past.
C. Embodies the distinctive characteristics of a type, period, region, or method of
construction, or represents the work of an important creative individual, or possesses
high artistic values.
D. Has yielded, or may be likely to yield, information important in prehistory or history.
Typically, archaeological sites exhibiting significant features qualify for the CR under Criterion D
because such features have information important to the prehistory of California. A lead agency may
determine that a resource may be a historical resource as defined in PRC §§ 5020.1(j) or 5024.1 even
if it is:
• Not listed in or determined to be eligible for listing in the CR.
• Not included in a local register of historical resources pursuant to PRC § 5020.1(k).
• Identified in an historical resources survey per PRC § 5024.1(g).
Threshold of Significance
If a project will have a significant impact on a cultural resource, several steps must be taken to
determine if the cultural resource is a “unique archaeological resource” under CEQA. If analysis
and/or testing determine that the resource is a unique archaeological resource and therefore subject
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to mitigation prior to development, a threshold of significance should be developed. The threshold
of significance is a point where the qualities of significance are defined and the resource is
determined to be unique under CEQA. A significant impact is regarded as the physical demolition,
destruction, relocation, or alteration of the resource or its immediate surroundings such that the
significance of the resource will be reduced to a point that it no longer meets the significance
criteria. Should analysis indicate that project development will destroy the unique elements of a
resource; the resource must be mitigated for under CEQA regulations. The preferred form of
mitigation is to preserve the resource in-place, in an undisturbed state. However, as that is not
always possible or feasible, appropriate mitigation measures may include, but are not limited to:
1. Planning construction to avoid the resource.
2. Deeding conservation easements.
3. Capping the site prior to construction.
If a resource is determined to be a “non-unique archaeological resource,” no further consideration of
the resource by the lead agency is necessary.