Table of Contents J.2 Cultural Resources - Archaeological Resources

1. INTRODUCTION ...... 1642

2. ENVIRONMENTAL SETTING ...... 1642 a. Regulatory Setting ...... 1642 (1) State ...... 1642 (2) Local ...... 1644 (3) Native American Consultation ...... 1645 b. Cultural Setting ...... 1645 c. Local and Site Conditions ...... 1646

3. ENVIRONMENTAL IMPACTS ...... 1649 a. Methodology ...... 1649 b. Thresholds of Significance ...... 1651 c. Project Design Features ...... 1653 d. Project Impacts ...... 1653 (1) Project Construction ...... 1653 (a) Prehistoric Period ...... 1653 (b) Historical Period ...... 1657 (c) Native American Resources ...... 1659 (2) Project Operations ...... 1659 (3) Impacts Under the No Annexation Scenario ...... 1659

4. CUMULATIVE IMPACTS ...... 1660

5. PROJECT DESIGN FEATURES AND MITIGATION MEASURES ...... 1661 a. Project Design Features ...... 1661 b. Mitigation Measures ...... 1661 (1) Prehistoric Period ...... 1662 (2) Historic Period ...... 1664

6. LEVEL OF SIGNIFICANCE AFTER MITIGATION ...... 1664

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page i WORKING DRAFT - Not for Public Review Table of Contents

List of Figures

201 Predicted Sensitivity of Project Site for Prehistoric Surface Sites ...... 1655

202 Predicted Sensitivity of Project Site for Prehistoric Buried Sites ...... 1656

203 Predicted Sensitivity of Project Site for Historical Period Sites ...... 1665

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page ii WORKING DRAFT - Not for Public Review IV. Environmental Impact Analysis J.2 Cultural Resources - Archaeological Resources

1. Introduction

The following section is based on the archaeological resources technical report, the NBC Universal Evolution Plan: Cultural Resource and Paleontological Studies, Universal City, Los Angeles, California, prepared by Statistical Research, Inc., March 2010, for the proposed Project. The full text of the report is included as Technical Appendix L-2 to this Draft EIR.

2. Environmental Setting

a. Regulatory Setting

Federal, State, and local governments have developed laws and regulations designed to protect significant cultural resources that may be affected by actions that they undertake or regulate. The National Environmental Policy Act, National Historic Preservation Act, and the California Environmental Quality Act (CEQA) are the basic federal and state laws governing preservation of historic and archaeological resources of national, regional, State and local significance. As archaeological resources are also considered historic, regulations applicable to historic resources are also applicable to archaeological resources and are discussed and analyzed in this section. Whereas federal agencies must follow federal archaeological regulations, most projects by private developers and landowners do not require this level of compliance. As the Project does not require a federal permit and would not use federal money, federal archaeological regulations are not applicable to the Project.

(1) State

State archaeological regulations affecting this Project include the statutes and guidelines contained in CEQA (Public Resources Code Sections [PRC] 21083.2 and 21084.1) and the CEQA Guidelines (California Code of Regulations [CCR] Title 14) Section 15064.5). CEQA requires lead agencies to carefully consider the potential effects City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1642 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources of a project on archaeological resources. Several agency publications, such as the series produced by the Governor’s Office of Planning and Research, provide advice on procedures to identify such resources, evaluate their importance, and estimate potential effects.

CEQA recognizes that archaeological resources are part of the environment, and a project that “may cause a substantial adverse change in the significance of an historical resource [including archaeological resources] is a project that may have a significant effect on the environment” (PRC Section 21084.1). For purposes of CEQA, a historical resource is any object, building, structure, site, area, place, record, or manuscript listed in or eligible for listing in the California Register of Historic Resources (PRC Section 21084.1).

A resource is eligible for listing in the California Register of Historic Resources and considered a “historical resource” under CEQA if it meets any of the following criteria:

 Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage;

 Is associated with the lives of persons important in our past;

 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; or

 Has yielded, or may be likely to yield, information important in prehistory or history [CEQA Guidelines Section 15064.5(a)(3)].

Archaeologists assess sites based on all four criteria but usually focus on the fourth criterion, above. The California Code of Regulations also provides that cultural resources of local significance are eligible for listing in the California Register of Historic Resources (CCR Title 14, Section 4852).

In addition to “historical resources,” CEQA also considers project impacts to “unique archaeological resources.”

As used in CEQA, “a unique archaeological resource” means 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 any of the following criteria:

 Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information;

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1643 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources

 Has a special and particular quality such as being the oldest of its type or the best available example of its type; or

 Is directly associated with a scientifically recognized important prehistoric or historic event or person [PCR 21083.2(g)].

In addition to having significance, resources must have integrity for the period of significance. The “period of significance” is the date or span of time within which notable events transpired at a site, or the period that notable individuals made their important contributions to a site. Integrity is the ability of that property to convey its significance.

CEQA requires the lead agency to: consider whether the project would have a significant effect on unique archaeological resources or resources eligible for listing in the California Register of Historic Resources, and to avoid these resources when feasible or to mitigate any effects to less than significant levels (PRC Sections 21083.2 and 21084.1).

(2) Local

The City of Los Angeles guidelines for the protection of archaeological resources are specified in Section 3 of the City of Los Angeles General Plan Conservation Element. As stated therein, it is the policy of the City of Los Angeles that the City's archaeological resources be protected for research and/or educational purposes. Section 5 of the City of Los Angeles General Plan Conservation Element recognizes the City’s responsibility for identifying and protecting its cultural and historical heritage. The Element establishes the policy to continue to protect historic and cultural sites and/or resources potentially affected by proposed land development, demolition or property modification activities, with the related objective to protect important cultural and historical sites and resources for historical, cultural, research, and community educational purposes.308

The County of Los Angeles General Plan contains goals and policies regarding archaeological resources. The Conservation and Open Space Element of the General Plan establishes the goal to preserve and protect sites of historical, archaeological, scenic, and scientific value, and defines the following policies relative to archaeological resources: protect cultural heritage resources including historical archaeological, paleontological and geological sites; encourage public use of cultural heritage sites consistent with the

308 City of Los Angeles General Plan, Conservation Element. September, 2001, pages II-4, II-5, and II-8. http://www.planning.lacity.org/cwd/gnlpln/consvelt.pdf.

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1644 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources protection of these resources; promote public awareness of cultural resources; and, encourage private owners to protect cultural heritage resources.309

(3) Native American Consultation

Government Code Section 65352.3 (Senate Bill [SB] 18) requires local governments to consult with California Native American tribes identified by the California Native American Heritage Commission prior to the adoption or amendment of a general plan or specific plan. The State Office of Planning and Research’s technical advice series strongly recommends that agencies solicit the concerns of Native Americans and other interested persons and corporate entities, including, but not limited to, museums, historical commissions, associates and societies as part of the process of cultural resources inventory. In addition, California law protects Native American burials, skeletal remains, and associated grave goods regardless of the antiquity, and provides for the sensitive treatment and disposition of those remains.

b. Cultural Setting

Little is known about the broad patterns of prehistory in the vicinity of the Project Site. Information on the larger surrounding region of the San Fernando Valley, eastern Santa Monica Mountains and neighboring areas of the Los Angeles Basin was used to understand the prehistory of the area. The following is a chronology of native settlement and archaeological periods: Late Pleistocene-Paleoindian (prior to 10,000 B.P.); Early- Paleocoastal or San Diegito Period (10,000-8000 B.P.); Millingstone-Topanga I Complex (8,000-5000 B.P.); Intermediate-Topanga II-III Complex (5000–2000 B.P); Late-Cremation Complex (2000-300 B.P.); and Protohistoric Period (300-150 B.P). By the Protohistoric period, the Project Site lay within the ethnohistoric territory of the Gabrielino. The name Gabrielino was derived from the name given by the Spanish to the local people who gathered at the Mission San Gabriel. More recently, some have ascribed the native name Tongva to these people. The western edge of the San Fernando Valley, however, was the boundary with the Chumash, an unrelated Hokan-speaking group. Chumash resided in many Tongva villages, especially in the western San Fernando Valley. Although unrelated, the Chumash and Tongva were both hunter-gatherers who were distinguished from other California tribes by their wealth, social complexity, art, economy, and technology.

The historical period in the San Fernando Valley can be divided into four broad periods: the Spanish Mission period, the Mexican period, the early American period, and the twentieth century.

309 County of Los Angeles General Plan, Conservation and Open Space Element, 1980.

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1645 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources

A comprehensive discussion of these prehistoric and historic periods is included in Appendix L-2 of this Draft EIR.

c. Local and Site Conditions

The Project Site lies along the southern margin of the San Fernando Valley and the adjacent northern slopes of the Santa Monica Mountains. The San Fernando Valley is a large inland basin flanked by the Santa Monica Mountains on the south, the Simi Hills on the west, the Santa Susana Mountains to the north, and the San Gabriel and Verdugo Mountains on the east. Situated along the northern base of the Santa Monica Mountains, moderate to steep slopes are found in portions of the central and eastern areas of the Project Site. The Los Angeles River Flood Control Channel and relatively flat landscape of the San Fernando Valley characterize the northern and western parts of the Project Site. The Cahuenga Pass parallels the southern edge of the Project Site.

The Project Site falls within the Los Angeles Basin portion of the Transverse Ranges geologic province. The bedrock underlying the Project Site consists of interbedded sandstone, siltstone, and claystone of the Miocene-age Topanga Formations. The northern portion of the Project Site is within the floodplain of the Los Angeles River. Geotechnical logs from early geotechnical exploration of the Project Site indicate that native alluvial deposits within the Project Site consisted primarily of interdigitating slope wash and floodplain deposits of clay, silt and sand. Bedrock is typically located 10-20 meters below the modern ground surface in floodplain and alluvial fan areas of the Project Site.

The Project Site is located in the area where the Cahuenga Pass opens into the San Fernando Valley and meets the confluence of the Los Angeles River and one of the main channels of the Tujunga Wash. Even before the Spanish arrived in California, the Cahuenga Pass was an important route between the San Fernando Valley and the Los Angeles Basin; it linked the Gabrielino community of Yangna, later the site of the Pueblo of Los Angeles, and the many Native American communities located in what is now called the San Fernando Valley. Among the Gabrielino villages in the San Fernando Valley was Kawenga (also spelled Kawengna, or the Hispanicized version Cahuenga), which was listed in 1852 as one of the principal “lodges” or “rancherias” of the valley. The name most likely refers to Cahuenga Peak. Researchers placed Kawenga in Rancho Cahuenga “at the present day site of Universal City.”310 The actual location is unknown, however, it has been advanced that Kawenga was likely located in the geographically strategic location along the south bank of the Los Angeles River in the transition between the valley bottom

310 McCawley, William. 1996. The First Angelinos: The Gabrielino Indians of Los Angeles. Malki Museum Press, Banning, California.

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1646 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources and foothills. Ethnohistoric accounts suggest that Kawenga, one of the largest Gabrielino villages in the valley, was located at this important junction and some recent reports suggest Kawenga was within the Project Site. No physical evidence of a prehistoric or Native American settlement, however, has ever been found in the area. In the early 1800s, the Project Site was uninhabited, although the Mission San Fernando owned the land, which was used for grazing as early as 1795. After the mission was broken up in the 1830s, portions of the Project Site were incorporated into the Rancho Providencia and the rancho associated with the Campo de Cahuenga. During this period, the Cahuenga Pass and what was to become Lankershim Boulevard were used as part of the El Camino Real and Camino Viejo by the Spanish and Mexicans, connecting all of southern and northern California. The Campo de Cahuenga served as a stage stop on these routes. The Cahuenga Pass was the site of two battles in the early 1800s. In 1847, Campo de Cahuenga, located west of what is now one of the main gates of the Project Site, was the site of the Treaty of Cahuenga, by which the Mexican forces in California capitulated to John C. Fremont. At the turn of the century, the Pacific Electric Railroad used Cahuenga Pass to connect downtown Los Angeles and the San Fernando Valley. Today, the Cahuenga Pass, which includes the Hollywood Freeway, continues to serve as an important transportation route in the network of southern California freeways.

Large portions of the Project Site have been disturbed by development of the property. Construction began at the Project Site in 1914, as part of the expansion of the growing film industry in the San Fernando Valley. Over the past 90 years, the film industry has dominated the area, and the growth of studios, back lots, and the theme park has resulted in the current conditions found at the Project Site.

A records search was conducted in September 2006 at the South Central Coastal Information Center located at the California State University, Fullerton. The South Central Coastal Information Center is associated with the larger statewide California Historical Resources Information System. The purpose of the records search was to determine if the Project Site and surrounding vicinity had been previously surveyed and if any cultural resources had been previously recorded within or near the Project Site. The records search area included the land within the Project Site and a 1-mile radius around the Project Site. The South Central Coastal Information Center files were reviewed for all projects and previously recorded cultural resources within and around the Project Site. Other resources that were consulted at the South Central Coastal Information Center included databases and information found in the National Register of Historic Places, the California Register of Historic Resources, California Historical Landmarks, and appropriate historical maps. In addition to the records search at the South Central Coastal Information Center, archival research was conducted at several federal, County, and private repositories in Los Angeles County, California, to locate information about historical period land uses at the Project Site. SRI archaeologists conducted an intensive pedestrian and vehicular survey of the Project Site on September 27 and 28, 2006. This survey focused entirely on the search for City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1647 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources archaeological remains. It did not take into account historical-period buildings, as they are addressed separately (see Section IV.J.1, Historic Resources, of this Draft EIR).

According to the South Central Coastal Information Center records, 51 previous cultural resource studies have been conducted within the Project Site and the 1-mile radius area surrounding it. These studies have included 35 archaeological surveys covering a total area of over 1,600 acres of land and 8 linear miles. Two surveys, one associated with the Los Angeles River (McKenna 2004) and the other with the Universal City Metro Red Line Station (WESTEC Services 1983), actually encompassed much larger areas surrounding the Project Site. Included among these cultural resource studies are six excavation and monitoring projects, all focused on Campo de Cahuenga and its surrounding area, and a variety of archival studies and assessments. Six previous studies have involved survey and assessments of the Project Site or have extended onto the Project Site (Historic Resources Group 2009; Rice 1975; Singer 1979, 1981a, 1981b). Despite the extent of investigation in the region, only 10 archaeological sites or historical properties have been previously identified and none within the boundaries of the Project Site.

All of the previously recorded sites or properties in the area near the Project Site are historical period in age, representing Mexican period and early-American period ranching in the San Fernando Valley, as well as the early-twentieth-century suburban occupation. No prehistoric sites have been identified in the area.

The records search identified ten previously recorded sites in proximity to the Project Site. Six sites are located on the west side of Lankershim Boulevard, opposite from the Project Site. These sites include, Campo de Cahuenga, which is listed in the National Register of Historic Places and has also been designated as a California State Landmark and City of Los Angeles Historic-Cultural Monument. This historical-period site is located just west of the main entrance to the Project Site along Lankershim Boulevard. Previous archaeological research at the Campo de Cahuenga revealed that it extends under the pavement of Lankershim Boulevard, although the remains of the site are poorly preserved in this area. A sketch of Casa Cahuenga, drawn in 1877 by Lt. John Goldworthy of the U.S. Army Corps of Engineers (see Figure 7 as presented in Appendix L-2 to this Draft EIR) shows other buildings that were associated with the main structure, which was identified by previous archaeological research. The buried remains of some of these buildings may extend into the Project Site. The possible locations of these buildings underlie the main administrative complex, one of the most heavily developed parts of the Project Site. It is unknown if any parts of these structures have survived. Excavations south of Campo de Cahuenga conducted in 2000 did not reveal any cultural resources or features associated with the occupation of the original adobe. Today, parts of the foundation are preserved underground and have been reproduced as an exhibit within the park and on Lankershim; at this time, no evidence of other outlying buildings has been City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1648 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources found. The other five sites located west of Lankershim are refuse dumps associated with early to mid-twentieth century residential and commercial activities. The remaining four sites in proximity to the Project Site are located across the Los Angeles River Flood Control Channel, a short distance north and northeast of the Project Site. Three are the presumed locations of nineteenth-century adobe houses associated with Rancho Providencia and Rancho Cahuenga, and the fourth is an early twentieth century French Provincial style residence.

As previously noted, the records search also revealed that Kawenga, an important Gabrielino village in San Fernando Valley during the late prehistoric and early historical period, may have been located in the area of the Project Site. However, previous archaeological surveys of the Project Site and the general vicinity have failed to identify any evidence of this village.

Six cultural resource studies have been conducted within the boundaries of the Project Site. The earliest study was conducted by Ultrasystems as part of a draft EIR for the extreme northeast corner of the current Project Site (Rice 1975). The area investigated was not specified but was described as a level portion of the valley floor bordering the Los Angeles River. Most of this area was under asphalt and was used as a parking lot at the time of the current survey by SRI. A single large quartz flake was the only prehistoric artifact found in the survey area. This isolate was located in a graded area on the southwest corner of the previous survey by Rice (1975). Rice concluded that this flake indicated a limited use of the lower hillside and that a habitation site was probably located nearby. He further speculated that the site might underlie the parking lot. Rice made no observations regarding historical-period materials. No archaeological or historical sites or resources in or adjacent to the Project Site were identified in the other five studies.

3. Environmental Impacts

a. Methodology

Archaeology is the recovery and study of material evidence of human life and culture of past ages. Since, over time, this material evidence becomes buried, fragmented, or scattered or otherwise hidden from view, it is not always evident from a field survey of a project site. Thus, the possible presence of archaeological materials must often be determined based upon secondary indicators. These include the presence of geographic, vegetative, and rock features which are known or thought to be associated with early human life and culture, as well as knowledge of events or material evidence in the surrounding area. The identification, evaluation, and treatment of cultural resources are generally divided into phases for discussion and management purposes. The initial

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1649 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources resource identification study is referred to as a Phase I reconnaissance survey. This may be followed by a Phase II resource evaluation study.

The archaeological study for the Project Site included a Phase 1 cultural resources survey and archival review of the Project Site, a geoarchaeological assessment, a geomorphic sensitivity study, a Phase II investigation of a 12-acre portion of the Project Site, and consultation with California Native American Tribes.

The Phase I survey of the Project Site involved a comprehensive search of existing California Historical Resources Information System and South Central Coastal Information Center records and other information sources, physical inspection of the Project Site, and a written report describing the Project, the existing conditions, a summary of identified cultural resources within and adjacent to the Project Site, and recommendations. During the survey, no prehistoric archaeological sites or isolated cultural resources were discovered within the Project Site. The remains of three early-twentieth-century residences were found in the southeast corner of the Project Site near the intersection of Barham Boulevard and Buddy Holly Drive (Coral Drive). This area is referred to by SRI as SR-1. The SR-1 site is located with the boundaries of the City under existing conditions and would remain within City boundaries if the Project’s proposed annexation request is implemented. This is the only historical-period resource identified during the survey.

A visual survey by SRI’s geoarchaeologist to identify areas most likely to contain sediments that might yield cultural deposits was included as part of the Phase I survey. Based on this survey, a geoarchaeological assessment of the Project Site was conducted to evaluate the likelihood of intact prehistoric archaeological resources on the Project Site. This assessment integrated several types of data, including typical prehistoric land-use patterns, geologic maps, geotechnical data, soils maps, topographic maps, historical maps, and aerial photographs, in addition to the pedestrian and vehicular reconnaissance of the Project Site. These lines of evidence were used to identify portions of the Project Site where intact archaeological deposits are most likely to exist.

Because of the extensive transformation of the landscape within the Project Site and the lack of surface visibility throughout most of the area, SRI also conducted a geomorphic sensitivity study to identify areas that have a potential for the preservation of cultural resources.

In addition, SRI conducted a Phase II testing and evaluation program of SR-1, which covers approximately 12 acres in the southeast corner of the Project Site near the intersection of Barham Boulevard and Buddy Holly Drive (Coral Drive). Methods used in the Phase II consisted of extensive clearing, and limited hand- and backhoe-excavation to remove soil accumulations and rubble to expose house foundations and surface features.

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1650 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources

Detailed maps of the entire site were produced using a total station. Features were also hand-drawn and photographed. In addition, because of their complex three-dimensional character, a laser scanner (LIDAR) was used to draw the larger landscape features. The goals of the Phase II study were fourfold: (1) to provide a detailed documentation of the currently exposed elements of the landscape features and any other exposed historical- period resources, (2) to determine how the features functioned or were integrated within the landscape, (3) to determine if there are any associated buried historical-period features or resources, and (4) to conduct additional archival research on the history of SR-1 and its former inhabitants. A comprehensive discussion of the research protocol, including Phase I and II analyses conducted for the Project Site is included in Appendix L-2 of this Draft EIR.

Pursuant to Government Code Section 65352.3 (SB 18), SRI contacted the California Native American Heritage Commission to identify California Native American Tribes to be consulted regarding the potential effect of the proposed Project to the Universal City area. The California Native American Heritage Commission responded on June 29, 2007. The Commission conducted a search of the Sacred Lands File, and no known Native American cultural resources exist on the Project Site. However, the Commission recommended consulting directly with the tribes and provided a list of recommended contacts. No written responses were received. Phone calls were received from two contacts; both requested that Native American monitors be present during any ground-disturbing activities in archaeologically sensitive areas. The complete Phase I survey and Phase II study can be found in the Combined Phase I Cultural Resource Survey, Archival Study, and Phase II Evaluation for SR-1, Universal City, Los Angeles, California included as Appendix C to The NBC Universal Evolution Plan: Cultural Resource and Paleontological Studies, Universal City, Los Angeles, California, attached as Appendix L-2 to this Draft EIR.

b. Thresholds of Significance

The City of Los Angeles CEQA Thresholds Guide (2006, pp. D.2-3 and D.2-4) states that a project would normally have a significant impact on archaeological resources if it could disturb, damage, or degrade an archaeological resource or its setting is found to be important under the criteria of CEQA because it:

 Is associated with an event or person of recognized importance in California or American prehistory or of recognized scientific importance in prehistory;

 Can provide information which is both of demonstrable public interest and useful in addressing scientifically consequential and reasonable archaeological research questions;

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1651 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources

 Has a special or particular quality, such as the oldest, best, largest, or last surviving example of its kind;

 Is at least 100- years-old311 and possesses substantial stratigraphic integrity; or

 Involves important research questions that historical research has shown can be answered only with archaeological methods.

In addition to this guidance provided by the City of Los Angeles, CEQA recognizes that historical resources, which include but are not limited to archaeological resources, are part of the environment, and a project that “may cause a substantial adverse change in the significance of a historical resource is a project that may have a significant effect on the environment” (Public Resources Code Section 21084.1). For purposes of CEQA, a historical resource is any object, building, structure, site, area, place, record, or manuscript listed in or eligible for listing in the California Register of Historic Resources (Public Resources Code Section 21084.1).

The factors established by the City of Los Angeles reflect the intent of the California Register of Historic Resources criteria and address the criteria established for defining unique archaeological resources as set forth in CEQA, with one exception. As such, the following is also used to assess the potential significance of a unique archaeological resource;

 Involves important research questions that historical research has shown can be answered only with archaeological methods.

Based on the above, the proposed Project would have a significant impact on archaeological resources if:

 Project activities would disturb, damage, or degrade a unique archaeological resource or an archaeological historical resource, or setting of the resource.

311 As noted in the City of Los Angeles CEQA Thresholds Guide (p. M.2-12, fn. 3), although the CEQA criteria state that “important” archaeological resources are those which are at least 100-years-old, the California Register provides that any site found eligible for nomination to the National Register will automatically be included within the California Register and subject to all protections thereof. The National Register requires, except in exceptional circumstances, that resources be at least 50-years-old. In addition, it is important to note that the California 100-year limitation was repealed on September 27, 1992, via Assembly Bill 2881. This legislation, which became effective on January 1, 1993, also created the California Register of Historic Resources. Based on current legislation, the time period referenced in this factor should be 50 years.

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1652 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources

c. Project Design Features

No project design features are proposed with regard to archaeological resources.

d. Project Impacts

Development of the proposed Project, including associated grading, excavations, and the development of proposed structures and other improvements could disturb existing, but as of yet undiscovered, archaeological resources. Although present and past surveys of the Project Site did not locate any artifactual material, except for a single isolated flake not considered significant, there is an extensive history of human habitation in the San Fernando Valley and the important Gabrielino/Tongva village of Kawenga is believed to have been in the vicinity of the Project Site. Furthermore, the Project Site is located in an area that would have provided the basic necessities for a prehistoric population. Therefore, there is the possibility of the existence of archaeological material on the Project Site.

(1) Project Construction

(a) Prehistoric Period

The results of the Phase I and Phase II surveys establish that over the past 90 years most of the Project Site has been considerably developed, with buildings and landscaped environments covering much of the ground surface. Only the eastern portion of the Project Site has remained underdeveloped, although alteration of the landscape to create movie sets and roads is apparent. During the current investigations, no prehistoric archaeological sites or isolated cultural resources were discovered within the Project Site boundaries.

Large portions of the Project Site have been disturbed by the post-1914 development of the property. The extent and nature of this disturbance varies from place to place, depending on the type of development. Channelization of the Los Angeles River in the 1940s also had a major impact on the Project Site, especially along the northern portion of the Project Site. Most of the grading activities that altered the Project Site topography and landforms occurred from the 1960s through the early 1980s and involved removing material from the hilltops and filling in the canyons, creating the relatively level “central hilltop”. In the northwestern portion of the Project Site, the low ridge immediately east of the core area that Universal Studios first developed in 1915 was largely graded away between 1951 and 1960. The top of this ridge, fairly level and situated immediately adjacent to the Los Angeles River floodplain, was probably the most likely location for a prehistoric archaeological site within the Project Site area.

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1653 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources

The Phase I and Phase II records search also served as a guide to assess the relative cultural resource sensitivity of the Project Site and its vicinity. Figure 201 on page 1655 identifies the predicted current sensitivity for prehistoric surface sites. Areas with heavy or light disturbance were classified as having very low sensitivity for surface sites because the integrity of shallow sites would have been destroyed by even light grading. Areas with no evident disturbance were classified as having high or low sensitivity. This classification identifies 2.5 acres (0.6 percent) with high sensitivity for surface sites, 9.1 acres (2.3 percent) with low sensitivity, and 379.5 acres (97.1 percent) with very low sensitivity. The areas with high sensitivity are located solely along the eastern edge of the Project Site. Because of the extensive transformation of the landscape within the Project Site, it is unlikely that any prehistoric materials are preserved on the surface anywhere within the Project Site. Although no surface sites were found during the pedestrian survey of this part of the Project Site, there is a potential to impact subsurface sites in areas of high sensitivity from future earth-moving activities. With the implementation of the recommended mitigation measure, this significant impact would be reduced to a less than significant level.

Figure 202 on page 1656 identifies the predicted current sensitivity for prehistoric buried sites. The classification identifies 8.9 acres (2.3 percent) with high sensitivity for buried sites, 66.4 acres (17.0 percent) with moderate to low sensitivity, 75.5 acres (19.3 percent) with low sensitivity, and 240.2 acres (61.4 percent) with very low sensitivity. Most of the more sensitive areas are located along the northern margin of the Project Site in portions of the historical-period floodplain area of the Los Angeles River Flood Control Channel near the northern edge of the Project Site. Historical-period materials may also be buried in much of the old floodplain area and in the southeast corner of the Project Site, near the intersection of Barham Boulevard and the Hollywood Freeway. As some additional areas have a high sensitivity for historical-period sites, potential impacts could occur within these designated areas of the Project Site. With the implementation of the recommended mitigation measure, this significant impact would be reduced to a less than significant level.

The actual existence of any prehistoric archaeological resources, and the significance of such resources if found, would not be known until such time that subsurface activity actually occurs. If proposed Project activities disturb, damage, or degrade a unique archaeological resource or an archaeological historic resource, or setting of the resource, the proposed Project could have a significant impact on archaeological resources. With implementation of the proposed mitigation measures, potential impacts on archaeological resources would be reduced to a less than significant level.

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1654 WORKING DRAFT - Not for Public Review COUNTY OF LOS ANGELES

CITY OF LOS ANGELES Page 1655

CITY OF LOS ANGELES

Property Boundary CITY OF LOS ANGELES

SR-1 Location Proposed Jurisdictional Boundaries

Source: Statistical Research, Inc., March 2010. Figure 201 Predicted Sensitivity of Project Site for Prehistoric Surface Sites COUNTY OF LOS ANGELES

CITY OF LOS ANGELES Page 1656

CITY OF LOS ANGELES

Property Boundary CITY OF LOS ANGELES

SR-1 Location Proposed Jurisdictional Boundaries

Source: Statistical Research, Inc., March 2010. Figure 202 Predicted Sensitivity of Project Site for Prehistoric Buried Sites IV.J.2 Cultural Resources - Archaeological Resources

(b) Historical Period

For the proposed Project, a historical-period archaeological feature refers to a stationary cultural resource that is more than 50 years of age and includes structures such as roads, walls, ponds, faux-rock escarpments, or building-foundation stem walls. Individual artifacts, in contrast to features, are movable objects such as historical-period bottles, old toys, construction parts, or other singular specimens that may or may not be associated with a particular feature. A single historical-period site was identified in the southeastern portion of the Project Site during a pedestrian survey conducted by SRI, designated with the temporary identification of SR-1. SR-1 is located on a small hill overlooking the Cahuenga Pass area in the southeast corner of the Project Site north of the Hollywood Freeway, west of Barham Boulevard, and south of Blair Drive. Phase II investigations at SR-1 revealed the presence of at least two temporally and functionally distinct occupancies.

The remains of three private residences and associated landscaping features were found at SR-1. Two of the properties were developed between 1915 and 1922 as part of a large estate initially covering about 67 acres and built by Frederick and Grace Blanchard and Frederick’s sister, Elizabeth Hartwell. This estate appears to be the earliest large residential development in the Cahuenga Pass area and predates the adjacent historical Hollywood Knolls and Hollywood Manor developments by as much as 10 years. The original estate encompassed all of SR-1, extended south of the Project Site boundaries across the Pacific Electric Railroad to Cahuenga Boulevard, and included the Hollywood Manor area. The estate was reduced when Blanchard sold 50 acres for the Hollywood Manor development and again after construction of the Hollywood Freeway and Coral Drive (now Buddy Holly Drive). The third residence is a subterranean complex built by Paul Grosso in 1949. This site was divided into two loci. The features in Locus A at SR-1, with the exception of the reservoir that forms the core of the underground complex, lack the qualities required to be eligible for listing in the California Register of Historic Resources. The features in Locus B at SR-1 are historical-period resources that retain a high degree of integrity and could yield information relevant to early twentieth century residential development in the Hollywood Hills and Cahuenga Pass area. Most of the features in Locus B were covered in dense foliage, and their extents and connectivity were determined only after feature areas were fully exposed by brush and sometimes soil/rubble removal. For the remainder of the Project Site, archaeological monitoring would occur during any earth-moving activities in those areas of the Project Site that have a high, moderate, and low sensitivity for buried prehistoric archaeological deposits.

The Phase I survey results suggested that SR-1 is potentially eligible for listing in the California Register of Historic Resources. As a result, a Phase II site testing and evaluation program and archival research were undertaken to assess the eligibility and integrity of the site. A detailed documentation and archival research effort was also City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1657 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources undertaken (see Appendix L-2 of this Draft EIR). The Phase II results indicate that SR-1 is potentially significant based on Criterion 2, its association with an event or person of recognized importance in California or American history or of recognized scientific importance in history. In the case of SR-1, that person was Frederick W. Blanchard. Mr. Blanchard was recognized as being instrumental in furthering the development of the cultural arts within Los Angeles in the early twentieth century and was also noted for his numerous and substantial contributions to civic development within the City of Los Angeles between 1899 and his death in 1928. In addition, SR-1 may be eligible for listing in the California Register of Historic Resources based on Criterion 4 as it can yield information important to understanding early-twentieth-century residential development in the area.

The SR-1 site also may be significant with respect to the distinctive characteristics and special quality of the landscape features found at the site. The “fantasy” landscape features may also be historically significant under Criterion 3 as they may embody the distinctive characteristics of a type, period, region, or method of construction, or represent the works of an important creative individual, or possess high artistic values. Most estates built during the early twentieth century were associated with formal classical, European, and Japanese style gardens. The naturalistic style of the Blanchard-Hartwell estate landscape is thus unusual. The characteristics reflect several styles of early twentieth century landscaping. The fake trees and decorated steps exhibit a high level of craftsmanship and artistic qualities. Research conducted to date has not identified the landscape architect who designed these features. Further archival research should be conducted to attempt to identify the landscape architect who designed these features and determine whether better examples of this individual’s work are preserved elsewhere. Siegried Goetze has been identified as the architect who was likely responsible for the original layout of the estate and perhaps the design of the homes, gatehouse and initial landscaping efforts. The naturalistic features, however, were built after construction of the homes, but before 1922, several years subsequent to Goetze’s documented association with the estate. Additionally, the style is not characteristic of Goetze’s work. Although the buildings on the estate were demolished in the early 1960s, most of the landscape features retain a high degree of integrity. For purposes of this analysis, SR-1 is considered an important archaeological resource.

The closed on-site landfill that contains trash from the early days of on-site activity may contain refuse dating from the 1920s until as late as 1980. This landfill was specifically associated with Universal City functions and is not related to the SR-1 site. The landfill may have a high sensitivity for historical-period sites, and would also be monitored during any earthmoving activities. Please refer to Sections IV.F, Geotechnical, and IV.M, Environmental Safety, for additional information regarding the closed on-site landfill.

Further discussion, analysis, and conclusions regarding potential impacts related to historical resources are provided in Section IV.J.1, Historical Resources, of this Draft EIR. City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1658 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources

(c) Native American Resources

Pursuant to Government Code Section 65352.3 (SB 18), California Native American Tribes identified by the California Native American Heritage Commission were contacted regarding the potential effect of the proposed Project to Native American resources.312 The Commission conducted a search of the Sacred Lands File, and no known Native American cultural resources exist on the Project Site. However, the Commission provided a list of recommended contacts and recommended consulting directly with the tribes. Two responses were received in response to the SB 18 consultation process. Both responses requested that a Native American monitor be present during all periods of on-site archaeological monitoring. This request has been incorporated into Mitigation Measure J.2-1.

As noted for prehistoric and historic period archaeological resources, if proposed Project activities disturb, damage, or degrade a unique archaeological resource or an archaeological historic resource, or setting of the resource, the proposed Project could have a significant impact on such resources. With implementation of the proposed mitigation measures, potential impacts on these resources would be reduced to a less than significant level.

(2) Project Operations

Operational aspects of the proposed Project would not cause ground disturbances with the potential to encroach or disturb unknown archaeological resources; therefore, no operational impacts to archaeological resources would occur. As described above, archaeological resources are impacted primarily during the construction phase of a project.

(3) Impacts Under the No Annexation Scenario

The proposed annexation/detachment of land areas between the City of Los Angeles and County of Los Angeles would not alter the potential for encountering archaeological resources on the Project Site; the potential significance level of any artifact would be independent of jurisdictional boundaries. The responsible agencies and those groups or agencies involved in consultation and establishing a mitigation protocol would be the same as those identified above. As such, potential impacts would remain the same (i.e., less than significant with the implementation of the recommended mitigation measures), if the proposed annexation/detachment was not implemented.

312 Native American Heritage Commission response dated June 29, 2007.

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1659 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources

4. Cumulative Impacts

The Project in combination with cumulative development could contribute to the progressive loss of and access to archaeological resources beginning with the initiation of Project construction during those periods of new on-site development when the majority of site disturbance is anticipated to occur. Although no prehistoric archaeological sites have been found in the Project Site or its vicinity, implementation of the recommended mitigation measures regarding the protection of such resources would insure that potential impacts would be reduced to a less than significant level.

An archaeological record search of the Universal City area revealed that the Project Site is within one mile of previously discovered artifactual remains. No prehistoric remains were identified in the archaeological survey conducted for the Project Site.313 A single large quartz flake is the only prehistoric cultural resource that has been found at the Project Site (Rice, 1975). The records search identified ten sites in proximity to the Project Site. Six sites are located on the west side of Lankershim Boulevard opposite the Project Site and include the Campo de Cahuenga (State Historic Landmark No. 151) and five refuse dumps associated with early to mid-twentieth century residential and commercial activities. The four remaining sites are located across the Los Angeles River Flood Control Channel a short distance north and northeast of the Project Site and include three locations of ranch houses contemporary with the Campo de Cahuenga and a standing French Provencal style residence built in 1932. Development of the proposed Project in combination with the related projects would result in the development of additional low- to high-density residential, commercial, institutional, studio/entertainment-related, and industrial land uses. The extent of the cultural resources (if any) that occur at the related project sites is generally unknown, however, one of the related projects could potentially meet the above conditions as a cumulative development that could contribute to the progressive loss of and access to archaeological resources. The proposed Metro Universal project, located on the Universal City Metro Red Line Station property across Lankershim Boulevard from the Project Site, is currently proposing two high-rise office buildings and above-ground parking structures, all of which could potentially contribute to a cumulative impact due to its location near the historic Campo de Cahuenga site, as described above. The analysis of the proposed Project's impacts to cultural resources concluded that through the implementation of the mitigation measures, recommended below, Project related impacts to cultural resources would be less than significant. Similarly, the proposed Metro Universal project

313 Earlier surveys of the Project Site identified “modern” trash within the development area boundaries. These deposits were not described or located on maps and therefore cannot be relocated and evaluated. SRI found no evidence of these deposits during the pedestrian survey. Surveys referenced relate to the 1996 Universal Project Draft EIR and are identified in Appendix l-2 of this Draft EIR.

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1660 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources concluded that through the implementation of mitigation measures, including consultation with the Native American Heritage Commission-appointed Most Likely Descendent, archaeological monitoring during construction, suspension of construction in the event archaeological resources or human remains are discovered, and controlled grading for ground disturbance on the historic Campo de Cahuenga site, that impacts related to cultural resources would be less than significant. Therefore, the proposed Project would not contribute to any potential cumulative impacts, and cumulative impacts to cultural resources would be less than significant.

5. Project Design Features and Mitigation Measures

a. Project Design Features

No project design features are proposed with regard to archaeological resources.

b. Mitigation Measures

The following mitigation measures are designed to assure that should any archaeological resources exist, they would not be significantly affected by development of the Project. Mitigation is recommended in the form of archaeological monitoring in the Project Site and limited data recovery and archival research at SR-1 to protect potential resources where Project grading, excavations, and construction would occur.

Mitigation of the potential impacts through the recommended data recovery investigation (described above and detailed in Mitigation Measure J.2-6 below) is the best means to preserve the scientific, historical, and artistic value of SR-1. The greatest value of these resources is the scientific, historical, and artistic information they represent. The research efforts undertaken already to record and evaluate the significance of SR-1 and those resources proposed for data recovery are designed to elicit this information and preserve it for the future. Given the current condition of the features, this approach to mitigation is the best means to preserve the value of SR-1.

The mitigation measure recommended for SR-1 was selected only after consideration was first given to preserving the resource at its current location (i.e., preservation in place). The analysis of the preservation in place option for mitigation was concluded to not be a viable means to preserve the scientific and historical value of SR-1. This conclusion is independent of whether the Project is implemented as proposed. Should the Project not proceed and no future impact to SR-1 occur, preservation in place is not viable as most of the features at SR-1 are above the ground and subject to natural destructive elements such as erosion and root growth, which undermine and destabilize the City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1661 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources aboveground features. Furthermore, some of the features are already crumbling or are in a severe state of disrepair. None of the fountains, pools, or waterfalls are currently in a functional state, and some features represent hazards to the public. The features also attract vagrants. As such, preserving SR-1 in place would result in demolition by neglect.

Preservation in place is also not a viable option if the Project proceeds and the area is left as open space. Many of the features cannot be simply buried and covered with landscape. It would be necessary to remove a large amount of rubble and vegetation to make the area safe for nearby residents. Furthermore, a labor-intensive long-term landscape maintenance program would be required to prevent damage to the SR-1 features from unwanted vegetation. Even if such measures are undertaken, preservation in place would not be ensured unless access to the area was limited. Fencing the area, without monitoring, would not control access sufficiently, and it would again make the area attractive to vagrants. Based on this analysis, it is concluded that the provisions set forth in Mitigation Measure J.2-6 would be the best means to preserve the scientific, historical, and artistic value of SR-1.

The recommended mitigation measures would avoid any potentially significant and adverse impact to the archaeological resources that may be present at the Project Site.

(1) Prehistoric Period

Mitigation Measure J.2-1: During construction, an archaeologist and Native American monitor shall be retained by the Applicant or its successor to monitor any earth-moving activities, including grading, in areas designated as high, moderate or low sensitivity for the presence of buried prehistoric archaeological sites (see Figure 202).

Mitigation Measure J.2-2: Prior to any future earthmoving activities, areas designated as high sensitivity for the presence of surface prehistoric archaeological sites (see Figure 201), shall be resurveyed after vegetation is removed.

Mitigation Measure J.2-3: If potentially significant archaeological resources are encountered during Project development, site preparation/ construction activities in the area of potential impact shall be halted until the archaeological consultant and/or Native American monitor, as appropriate, have evaluated the resources and, if necessary, developed a plan to mitigate associated impacts. The construction manager at the Project Site shall be notified, and shall notify the responsible lead agency of the discovery. The archaeologist and/or the Native American monitor, as appropriate, with the concurrence of the City or County, as applicable, shall determine the area of City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1662 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources

potential impact and the timing when construction activities can resume.

a) Discovered cultural resources shall be stored in a protected environment to prevent vandalism, damage, or theft until such time as they are examined by an archaeologist and/or Native American monitor, as appropriate.

b) The identification and handling of archaeological resources at the site shall be conducted by a qualified archaeologist and overseen by local Native American monitor.

c) All project-related notes, records, photographs, and artifacts, both prehistoric and historical period, shall be curated at a repository in accordance with 36 Code of Federal Regulations 79. Any items of cultural patrimony, however, shall be returned to an appropriate Native American community, which shall be responsible for the disposition of these materials.

Mitigation Measure J.2-4: If human remains are encountered during construction, work in the affected area and the immediate vicinity shall be halted immediately. The construction manager at the Project Site shall be notified, and shall notify the archaeologist and Native American monitor, if they are not on-site at the time, as well as the responsible lead agency of the discovery, who in turn shall notify the Native American Heritage Commission and the County Coroner pursuant to procedures and requirements set forth in California Health and Safety Code Section 7050.5. Disposition of the human remains and any associated grave goods shall also be in accordance with this regulation and Public Resources Code 5097.91 and 5097.98, as amended. The archaeologist and the Native American monitor, with the concurrence of the City or County, as applicable, shall determine the area of potential impact and the timing when construction activities can resume.

Mitigation Measure J.2-5: All construction-phase employees shall undergo a cultural resources orientation and awareness training prior to commencing work activities on the Project Site. Such training shall include familiarization with the stop-work restrictions, noticing, and handling procedures, and ultimate disposition of cultural resources as described below. The construction manager shall provide the responsible lead agency with a verification list of the employees completing the orientation.

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1663 WORKING DRAFT - Not for Public Review IV.J.2 Cultural Resources - Archaeological Resources

(2) Historic Period

Mitigation Measure J.2-6: Prior to the grading in the area of the SR-1 site, a limited program of data recovery shall be undertaken at SR-1. In particular, the foundations of the Hartwell house, gatehouse, tennis court, aviary and water systems shall be further investigated. Data recovery investigations shall be restricted to areas associated with possible building foundations and the two reservoirs. These investigations shall be conducted via a combination of mechanical trenching and hand excavation in the vicinity of the house foundations, gatehouse, tennis court, pools, and reservoirs. In addition, certain features within SR-1, as recommended by the archaeologist, shall be documented according to Historic American Engineering Record Standards of photo documentation and measurement.

Mitigation Measure J.2-7: An archaeologist shall be retained by the Applicant to monitor any earthmoving activities, including grading, in areas designated as high sensitivity for the presence of buried historical period archaeological sites (see Figure 203 on page 1665 of the Draft EIR).

6. Level of Significance After Mitigation

With the implementation of the recommended mitigation measures, potential impacts to unique archaeological resources and historical resources would be reduced to a less than significant level.

City of Los Angeles NBC Universal Evolution Plan Draft Environmental Impact Report November 2010

Page 1664 WORKING DRAFT - Not for Public Review Page 1665

Source: Statistical Research, Inc., March 2010. Figure 203 Predicted Sensitivity of Project Site for Historic Period Sites