Step by Step Process to Preparing

- DRAFT - Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression

Date Revised: March 24, 2003

Dan Foster and Rich Jenkins Senior State Archaeologists California Department of Forestry and Fire Protection

with contributions from:

Lisa Hanson Staff Archaeologist National Park Service, Rocky Mountain National Park

Brian D. Dillon Consulting Archaeologist North Hills, California

[email protected] [email protected] [email protected] [email protected]

CDF Editorial Note: This draft document is a work in progress. The current writing presents an initial proposal for consideration, which is currently being reviewed by CDF’s Fire Protection program. Fire Protection has agreed to help us further develop these draft procedures. Fire Protection has also agreed to advise us on appropriate procedural steps to introduce some of these ideas to the Department for its consideration. TABLE OF CONTENTS

Introduction ...... 1

Cultural Resource Values ...... 1

Legal Requirements ...... 2

Policy Statement ...... 3

Definition of Key Terms Used in These Procedures ...... 3

Recommended Training Standards ...... 8

Availability of Resources ...... 9

Recommended Procedures for Initial Attack Wildland Fires ...... 9

Recommended Procedures for Extended Attack Wildland Fires ...... 10

Recommended Procedures for Major Wildland Fires ...... 11

Recommended Tactics and Strategies ...... 14

Contract Archaeologist Resources ...... 17

Planning for the Future ...... 17

Acknowledgments ...... 18

References Cited ...... 18 Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 1

Introduction

The draft procedures outlined in this report provide assistance and direction to CDF personnel in the task of identifying and protecting cultural resources during fire suppression activities associated with CDF wildland fires, when such protection is possible, without delaying or hindering emergency response operations. For the purpose of this document, CDF wildland fires means those wildland fires where CDF is in command and those where CDF participates in joint agency command. There are three key terms used in these procedures; these are Archaeologist, Archaeological Aide, and Cultural Resource Officer. None of the three terms are official Incident Command System (ICS) working titles; they would be dispatched as a Technical Specialist which is an official ICS working title listed in the Field Operations Guide. We suggest CDF should consider inserting the terms Technical Specialist - Archaeologist and Technical Specialist - Archaeological Aide into CDF’s ICS Employee Development Guide and indicate the required duties, prerequisites and required training described in this report.

CDF is a state agency whose mission is to protect the resources and people of California from fires, respond to emergencies, and protect and enhance California’s forest, range, and watershed values, providing social, economic, and environmental benefits to rural and urban citizens. Protecting cultural resources during wildfire suppression, if such protection is possible, falls within our mission to protect California’s forest and range values. Effective procedures and actions resulting in protection to significant cultural resources are expected by the public, who look to CDF as a steward of California’s natural and cultural resources across 33 million acres of State Responsibility Area (SRA) lands within our jurisdiction.

Cultural Resource Values

California has a rich and diverse history that is reflected by a rich and widespread distribution of cultural resource occurrences throughout the state. This is particularly true in California’s wildlands where cultural resources have survived in the absence of residential and commercial development or major public works projects. The term cultural resources is used throughout this document to describe the types of sites and other resources that should be afforded protection. This term reflects public policy that is concerned not only with archaeological and historical sites but also with buildings, structures, objects and districts. We chose the term cultural resources over the legally defined terms historical resource or historic property for two reasons. First, because we felt that use of those terms might confuse some readers in the absence of a lengthy discourse on why they were selected and what they mean, and second, because in conducting a survey it is the search for non-structural sites that causes the most difficulty, not the identification of buildings and structures. Cultural resources include archaeological and historical sites, buildings, structures, objects, districts, and as a point of clarity, it also includes places of cultural or religious importance to California Native Americans. These are public-trust resources which are identified and protected during many of CDF’s projects and programs including prescribed fire activities under our Vegetation Management Program, Timber Harvesting, cost-share activities under CDF’s Forestry Assistance programs, and other types of CDF projects. Procedures to identify and protect cultural resources during such CDF projects was recently distributed to all CDF Units (Foster 2003) but those procedures do not apply to CDF’s Fire Protection program. Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 2

Unlike a house, a load of logs, or an acre of wildland, one cannot put a dollar value on an archaeological site. It is equally hard to assess the value of other cultural intangibles such as art, music, literature, amateur sports, local or family history, and so forth, but these are the things that enrich our lives in modern society. The understanding of our past is one of those priceless things. Archaeological sites contain the irreplaceable evidence to reconstruct the past. Without archaeological and other cultural resources, we would be ignorant of the very long and diverse history and prehistory that makes California stand apart from its neighbors, and helps us locate ourselves in time and space within our state. Our own lifetimes are but a drop in the bucket compared to the total time human beings have lived in what we now call California. California has a uniquely varied archaeological record, and one as old as anywhere else in North America. Hundreds of different prehistoric cultures have been and are still being found within our state, most of them discoverable only through archaeological methods. Unless we can recognize the fragile traces left behind by these earlier peoples and take steps to protect and preserve them, when possible, we can and will accidentally destroy these vanishing resources that contain the only remaining evidence of those who came before us.

California’s cultural resources incorporate many unique values, attributes, and characteristics. They are finite, fragile, easily overlooked, and nonrenewable. Unlike wildlife habitat, stands of trees, or water quality, damage to these types of resources can not be restored or repaired. The resources of the past are all we have left - we can’t produce new sites from bygone eras. Another unique aspect of cultural resources is that many of them are more vulnerable to damage caused by suppression efforts (such as dozer firelines, bladed safety areas, etc.) than by the actual wildfire. For these reasons, CDF is considering the implementation of procedures to identify and protect cultural resources, whenever possible and practical, during future wildland fire suppression efforts.

Legal Requirements

Many CDF activities constitute projects as defined in the California Environmental Quality Act (CEQA), and CDF is required by this state law and its accompanying guidelines and regulations to provide mitigation to negative impacts to cultural resources. Environmental documents for wildfire suppression are not required by CEQA because emergencies such as wildfires are clearly exempted by the Act in recognition that public safety comes before environmental protection in terms of agency priorities. That exemption, however, does not release us from compliance with other laws or from our professional obligation to protect all of California’s wildland resources.

Although CDF is not specifically required by law to develop procedures to protect significant cultural resources during CDF wildland fire suppression activities, appropriate actions are expected by the public, and without them, the Department’s public image has occasionally been damaged. CDF has sometimes been unable to adequately explain why the Department failed to put dozerlines around, rather than through, known archaeological sites during certain major wildland fires when contingency firelines were constructed miles ahead of the actual fire. The Pines Fire (2002) in eastern San Diego County is a recent example of a major wildland fire where CDF had time, opportunities, and resources to prevent some of the damage to archaeological sites that resulted from suppression efforts. There were over 75 recorded sites within the area affected by the Pines Fire, and at least 18 of them were Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 3 severely damaged by CDF and CDF-contract bulldozers constructing firelines (Jenkins and Grantham 2002, Berg, Ruby, and Sandelin 2003). Some of the observed damage to recorded sites could have been avoided if CDF had procedures in place that provided key personnel with the information needed to carry out protection efforts. In several instances CDF had opportunities to go around sites instead of through them had their locations and significance been given consideration during development of Incident Action Plans. Many of the damaged sites could have been avoided without delaying or impeding our suppression efforts in any way. This document is intended to provide our recommendations for draft procedures and guidance, which have been previously lacking, to CDF’s Fire Protection program.

Policy Statement

In response to CDF wildland fires, CDF is committed to deploy resources, seek information, and give consideration to the protection of cultural resources, to the extent prudent and feasible, if such efforts can be accomplished without delay or hindrance to necessary emergency response operations. CDF believes that certain opportunities to identify and protect cultural resources during wildland fire suppression efforts do occur within the existing ICS structure, particularly during major wildland fires where suppression activities may be extended for multiple days. In those instances, CDF may have opportunities to seek and collect information about known cultural resources, and possibly even undiscovered resources, and give consideration to them for protection efforts. The goal of these procedures is to protect cultural resources whenever possible. As note in this document, different procedures have been proposed for initial attack, extended attack, and major wildland fires. These procedures also apply to suppression repair efforts. CDF shall encourage key staff in both Resource Management and Fire Protection capacities to complete archaeological recognition training courses offered by the Department in order to increase the Department’s capability of completing these tasks and procedures, and heighten the awareness and sensitivity about the significance and fragility of California’s cultural resources.

Definition of Key Terms Used in These Procedures

Archaeologist: As used in these procedures, an Archaeologist is one of the important resources that may be deployed to a wildland fire. It means a professional archaeologist on staff at CDF. CDF Archaeologists hold at least a Bachelor of Arts or Science degree in Anthropology or Archaeology from a college or university, have completed at least three years of professional experience in research, writing, or project supervision in archaeological investigation or cultural resource management and protection programs, and have met the California State Personnel Board's series specifications and minimum qualifications for an Associate State Archaeologist in the State Archaeologist Series. In addition to the technical skills, education, and abilities, an Archaeologist must have completed ICS and fire safety training, and it is highly recommended to have completed Intermediate Fire Behavior, Field Observer, and Strike Team Leader(Dozers) training, to be utilized in key positions at the fire.

Archaeological Aide: As used in these procedures, an Archaeological Aide is one of the important resources deployed to a wildfire. This is a person on staff at CDF who has successfully completed the full course (currently four days in length) in the CDF Archaeological Training Program and who has kept this certification current through successful completion of a one-day refresher courses at least once every five years, and who Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 4 has demonstrated the ability to conduct professionally adequate cultural resource surveys and site protection work. The Archaeological Aide typically, but not always, works under the direction of an Archaeologist. In addition to the required Archaeology Training, an Archaeological Aide must have completed ICS and fire safety training, and it is highly recommended to have completed Intermediate Fire Behavior, Field Observer, and Strike Team Leader (Dozers) training, to be utilized in key positions at the fire.

Archaeological Records Check: In the context of these procedures, an archaeological records check means a review of the State's archaeological and historic resource files conducted at the appropriate Information Center of the California Historical Resource Information System for the area which could be affected by suppression activities. The records check can be accomplished through a personal visit at the Center or through telephone or electronic communications using Fax or E-mail to transmit information on cultural resources. A directory listing all 12 Information Centers and containing their address, phone number and list of counties of jurisdiction is posted on the Archaeological Records Check page of the CDF Archaeology Program Web Site at: http://www.indiana.edu/~e472/cdf/checks/checks.html This web page also contains a Memorandum of Agreement that specifies a series of stipulations for the conduct of these records checks, records check instructions, and other forms of assistance. The objective of the records check is to determine the presence or absence of any known or suspected cultural resources within the area that might be affected by the wildfire, and to obtain mapped locations and site records for those sites so they could be relocated and possibly protected during suppression efforts.

Archaeological Site: A specific location, identifiable on the ground, where ancient human activities took place, and where tangible physical remains in the form of artifacts and/or features can be recognized. For historic sites, “ancient” usually means at least 50 years of age. An archaeological site may include surface and/or subsurface elements. It may be historic, prehistoric, or both, be part of a larger unit (such as a historic landscape, site- cluster or district), and/or contain smaller units (such as loci).

Archaeological Survey: A comprehensive review of available records and information and an intensive systematic field inspection to locate and record the cultural resources occurring on a piece of land.

Artifact: An object that is made, modified, altered, or transported by human agency or workmanship which cannot be confused with an accident of nature.

CDF Wildland Fire: For the purpose of this document, a CDF wildland fire means those wildland fires where CDF is in command and those wildland fires where CDF participates in joint agency command.

Cultural Resource Officer (CRO): The CRO means the person responsible to implement tasks and carry out protection efforts for cultural resources during a CDF wildfire incident. This job will be given to either an Archaeologist or an Archaeological Aide. Typically, the CRO will be the first Archaeologist or Archaeological Aide assigned to the incident, however, if the incident progresses into a large, extended suppression effort, and additional resources are deployed, the CRO may be reassigned to another individual with greater expertise in cultural resource survey and protection work and supervision of teams to accomplish this Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 5 work.

Cultural Resources: This term describes the kinds of resources intended to be covered by these procedures. It is a broad category that includes archaeological and historical sites, buildings, structures, objects, and districts, even if unevaluated for legal significance. As a point of clarification, the term includes and traditional cultural properties, which is also defined in this report.

Emergency: as defined in the CEQA Guidelines (14 CCR Section 15359), an emergency is a sudden, unexpected occurrence, involving a clear and imminent danger, demanding immediate action to prevent or mitigate loss of, or damage to life, health, property, or essential public services. Emergencies include such occurrences as fire, flood, earthquake, or other soil or geologic movements, as well as such occurrences as riot, accident, or sabotage. An emergency is an event, not a condition. So while CDF suppression activities responding to an existing fire clearly constitute an emergency exempted from the provisions of CEQA, pre-fire projects designed to reduce a hazardous condition are not exempt.

Emergency Projects: as defined in the CEQA Guidelines (14 CCR Section 15269), emergency projects are statutorily exempt from the requirements of CEQA and include projects to maintain, repair, restore, demolish, or replace property or facilities damaged or destroyed as a result of a disaster in which a state of emergency has been proclaimed by the Governor; or emergency repairs to publicly or privately owned service facilities necessary to maintain service essential to the public health, safety or welfare; or specific actions necessary to prevent or mitigate an emergency. This exemption does not include activities undertaken for the purpose of preventing or mitigating a situation that has a low probability of occurrence in the short term.

Extended Attack Wildland Fire: As defined in Section 7000 of the Fire Operations Handbook, an Extended Attack wildland fire is one that can be contained within the first burning period (from the time the fire starts to 10:00am the following day), but requires substantial augmentation of the first-dispatched suppression resources.

Feasible: Capable of being accomplished in a successful manner within a reasonable period of time, taking into account safety, economic, environmental, legal, cultural and other technical factors. As used in cultural resource management, it means realistic alternatives, mitigations, or methods to protect resources.

Feature: An archaeological feature is either a large stationary artifact, such as a firepit, housepit, cairn, bedrock mortar, etc. or an association of related portable artifacts such as a cache or offering of related tools or ornaments. Human burials and bedrock mortars are features. These are forms of archaeological evidence that represent a particular activity.

High Probability Areas: As used in this report, means those areas likely to contain cultural resources. Such places include but are not limited to areas along springs or streams, ridgetops, margins of meadows, near bedrock outcroppings, and other places with favorable environmental or topographic settings, as instructed in the CDF Archaeological Training Course. Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 6

Historical Resource: In state law, this includes but is not limited to any object, building, structure, site, area, place, record or manuscript which is historically or archaeologically significant, or which is significant in of the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural history of California life as stipulated in PRC Section 5020.1(J) (and CCR Title 14, Chapter 11.5, Appendix A).

Historic Property: In federal law, a district, site, building, structure, or object that is significant in American history, architecture, engineering, archaeology, or culture at the national, state or local level, and that meets the National Register criteria.

Historic Site: An archaeological site of the historic period. Locations where important events during the historic period took place or historic artifacts or features important to our understanding of the region's recent development can be identified. Historic sites can be the remains of houses, barns, mines, logging camps, dumps, etc.

Information Center (Regional Information Center, IC): An Information Center of the California Historical Resources Information System, under contract to the Office of Historic Preservation, which receives, manages, and provides information on historical and archaeological resources. An Information Center also provides information and recommendations regarding such resources on a fee-for-service basis (CCR Chapter 14, Title 11.5, Appendix A).

Initial Attack Wildland Fire: As defined in Section 7000 of the Fire Operations Handbook, an Initial Attack wildland fire is one that can be contained by the suppression resources first dispatched, without substantial augmentation, within two hours of the report time.

Intensive Cultural Resource Survey: means an investigation to determine the presence or absence of cultural resources within a given project area. It is the process to determine precisely what cultural resources exist in a given area. It describes the distribution of cultural resources, determines the number, type, location, and condition of individual cultural resources within the area, and records their physical extent. The documentation for the survey shall include the boundaries of the area surveyed, the methods used during the survey including a description of the survey coverage achieved, and a record of the precise location of all cultural resources identified within a project area.

Local Native Americans: Those California Native American tribal organizations and individuals listed for the appropriate county or portion of a county on the most current version of CDF’s Native American Contact List. The terms Native American Contact List and Native Americans are also defined in this document.

Low Probability Areas: As used in this report, means those areas that are not likely to contain cultural resources. Such places include but are not limited to steep sloped, areas away from water, without rock outcroppings, and other places with unfavorable environmental or topographic settings, as instructed in the CDF Archaeological Training Course.

Major Wildland Fire: As defined in Section 7000 of the Fire Operations Handbook, a Major wildland fire is one that cannot be contained within the first burning period (from Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 7 the time the fire starts to 10:00am the following day), even with substantial augmentation of the first-dispatched suppression resources.

Native American Contact List (NACL): As defined in the Forest Practice Rules, the list developed and kept by CDF in consultation with the Native American Heritage Commission (NAHC) that identifies those Native Americans that must be notified or consulted for certain CDF projects. It is organized by counties or portions of counties, and includes all federally recognized tribal governments and other California Native American tribal organizations or individuals that CDF has placed on the list based upon demonstrated knowledge concerning the location of archaeological or other cultural resources within California. The NAHC is a required contact for each county to enable the NAHC to complete a check of its Sacred Lands File. The list is updated monthly and is available at the CDF Web Site at: http://www.indiana.edu/~e472/cdf/contacts/NACL.htm

Native Americans: as defined in the Forest Practice Rules and used in these procedures, the term Native Americans means the Native American Heritage Commission and those local Native American tribal groups and individuals that may have useful information concerning cultural resource locations. These are listed on CDF’s Native American Contact List.

Project: In state law (14 CCR Section 15378), a project means the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment, and that is any of the following: (a) An activity directly undertaken by any public agency including but not limited to public works construction and related activities clearing or grading of land, improvements to existing public structures, enactment and amendment of zoning ordinances, and the adoption and amendment of local General Plans or elements thereof pursuant to Government Code Sections 65100-65700. (b) An activity undertaken by a person which is supported in whole or in part through public agency contacts, grants, subsidies, loans, or other forms of assistance from one or more public agencies. (c) An activity involving the issuance to a person of a lease, permit, license, certificate, or other entitlement for use by one or more public agencies.

Prudent: Wise in handling practical matters; exercising good judgment or common sense; careful in regard to one's own interest; careful about one's conduct.

Significant Archaeological or Historical Site: As defined in the Forest Practice Rules, means a specific location which may contain artifacts or objects and where evidence clearly demonstrates a high probability that the site meets one or more of the following criteria: (a) Contains information needed to answer important scientific research questions. (b) Has a special and particular quality such as the oldest of its type or the best available example of its type. (c) Is directly associated with a scientifically recognized important prehistoric or historic event or person. (d) Involves important research questions that historical research has shown can be answered only with archaeological methods. (e) Has significant cultural or religious importance to California Indians as identified by the Native American Heritage Commission (NAHC) or Native American organizations or Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 8

individuals in concurrence with the NAHC or locally federally recognized tribal governments.

Strike Team Leader (Dozers): means a person responsible for directing dozerlines, which may include directing people to walk ahead of a dozer during wildland fire suppression efforts, to help look identify hazards, or sensitive environmental areas including cultural resources, and help guide the dozer operator the path to follow. Currently, to fill an assignment as Strike Team Leader (Dozers), completion of archaeological training is not a requirement. This document encourages CDF consider changing those prerequisites to include such training because these positions are of critical importance to the identification and protection of cultural resources.

Substantial Augmentation: as defined in the Section 7000 Procedures Handbook, substantial augmentation means the addition of multiple units of multiple types of suppression resources (e.g. two+ airtankers and two+ fire crews, or dozers, or engines, etc., to either an Extended Attack or Major wildland fire.

Traditional Cultural Property (TCP): These are places of cultural or religious importance to California Native American Indians. Examples include traditional gathering areas, prayer sites, or sacred/ceremonial locations. These sites may or may not contain features, artifacts, or physical evidence, and are usually identified through consultation with local Native American groups.

Recommended Training Standards

For Archaeologists working on a CDF wildland fire incident, we recommend the following minimum training standards:

ICS 200/300 Basic/Intermediate ICS (required) (no number) Basic Forest Firefighter Training Course (67-hour) (required) S-390 Intermediate Fire Behavior (highly recommended) I-244 Field Observer (highly recommended) S-330 Strike Team/Task Force Leader (Dozers) (highly recommended)

For Archaeological Aides working on a CDF wildland fire incident, we recommend the following minimum training standards:

ICS 200/300 Basic/Intermediate ICS (required) (no number) Basic Forest Firefighter Training Course (67-hour) (required) (no number) CDF Archaeological Training (36-hour) and Refresher Archaeology Training every five years (8-hour) S-390 Intermediate Fire Behavior (highly recommended) I-244 Field Observer (highly recommended) S-330 Strike Team/Task Force Leader (Dozers) (highly recommended)

Note: We also recommend that CDF change the prerequisites and training requirements for Field Observer and Strike Team/Task Force Leader (Dozer) positions. Currently, the 36- Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 9 hour Archaeological Training Course is not listed as required or even recommended for either position. We believe that archaeological training should at least be recommended, if not specifically required because these positions are critical to CDF’s ability to identify and protect cultural resources during wildland fire suppression.

Availability of Resources

Archaeologists There are currently 5 CDF Archaeologists that might be available to fill the assignment as an Archaeologist reporting to the fire. These are: Rich Jenkins, Steve Grantham, Linda Sandelin, Chuck Whatford, and Gerrit Fenenga. A current directory listing their locations, and pager and cell phone numbers, can be obtained from the CDF Archaeology Program Web Site at: http://www.indiana.edu/~e472/cdf/staff/staff.html For dispatch to fire assignments the CDF Archaeologists are listed in the Emergency Response Directory (ERD) maintained at the Unit, Region, or Headquarters Emergency Command Center (ECC).

Archaeological Aide There are currently approximately 200 CDF personnel that have completed (and kept current) CDF Archaeological Training and could fill assignments as an Archaeological Aide are listed in the CDF Archaeology Program Web Site at: http://www.indiana.edu/~e472/cdf/training/training.html When this page is visited, click on Course Roster Information, then click on Previous Course Rosters to open or download the Excel file. We are encouraging CDF to develop a plan add the proposed Archaeological Aide qualification to the existing list of ICS qualifications maintained for each eligible employee in the Unit, Region, or Headquarters ERD.

Recommended Procedures for Initial Attack Wildland Fires

Most wildland fires suppressed by CDF are controlled or contained during Initial Attack by the local Unit. In these cases, CDF is unlikely to have opportunities to identify cultural resources that might be affected during suppression efforts. We recommended that CDF consider a policy that includes procedures for CDF Units to conduct an intensive cultural resource survey along all dozer firelines, staging areas, or other places that received ground-disturbing activities, if any such grading work was constructed within high probability areas as defined in this report. No survey would be required in those areas considered by the Unit to be of low probability to contain cultural resources. This survey should take place by someone from the local Unit that has received archaeological training, and completed as soon as possible after the fire is controlled or contained. The purpose is to identify any cultural resources that may exist within the areas disturbed by heavy equipment, conduct site damage assessment, develop a protection plan to be implemented during suppression repair efforts, and develop a plan for site documentation, if possible. Any observed cultural resources should be immediately reported to the appropriate CDF Regional Archaeologist. The CDF Archaeologist and/or contract archaeologists retained for this purpose may be able to assist in the completion of this work.

Recommended Procedures for Extended Attack Wildland Fires

For CDF wildland fires that evolve into extended attack, CDF will have opportunities to deploy resources that could carry out protection efforts. It is recommended that each Unit Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 10 designate a Cultural Resource Officer (CRO) from existing staff to evaluate/respond to local Extended Attack Wildland Fires. The CRO might be a Unit Forester, Forest Practice Inspector, VMP Coordinator, Pre-Fire Engineer, Battalion Chief, Station Captain, or other staff member with the required training - the choice is up to the Unit. In some Units, such as CDF’s San Diego Unit, that will soon have 26 Battalion Chiefs and Captains that have completed archaeology training, a CRO might be assigned to each Battalion.

Once apprised of the incident, the CRO should initiate an archaeological records check and evaluate the cultural resource sensitivity for the area potentially affected by the wildfire. This could result in a decision to request additional resources, including the Region Archaeologist. The CRO should take appropriate courses of action to protect known cultural resources, if possible, during suppression activities. The CRO should find out if there are any local agreements that may stipulate procedures concerning the protection of cultural resources.

We also recommended that CDF consider a policy that includes procedures for the CRO to conduct (or supervise) an intensive cultural resource survey along all dozer firelines, staging areas, or other places that received ground-disturbing activities, if any such grading work was constructed within high probability areas as defined in this report. No survey would be required in those areas considered by the Unit to be of low probability to contain cultural resources. This survey should take place by someone from the local Unit that has received archaeological training, and completed as soon as possible after the fire is controlled or contained. The purpose is to identify any cultural resources that may exist within the areas disturbed by heavy equipment, conduct site damage assessment, develop a protection plan to be implemented during suppression repair efforts, and develop a plan for site documentation, if possible. The CDF Archaeologist and/or contract archaeologists retained for this purpose may be able to assist in the completion of this work.

The purpose is to identify any cultural resources that may exist along such dozerlines, record them, conduct damage assessment, and give consideration to suppression repair efforts. Any observed cultural resources should be immediately reported to the appropriate CDF Regional Archaeologist. See discussion on page 17 for information about contract archaeologists that might be available.

Recommended Procedures for Major Wildland Fires

The appropriate CDF Region Archaeologist with responsibility within which the incident is located shall be contacted by the Region ECC whenever an Incident Command Team is assigned. This archaeologist will perform an initial assessment of the incident (tasks described below) or will find another CDF archaeologist to perform the needed analysis. In the event that none of the CDF Archaeologists are available, the Region Archaeologist will recommend that an Archaeological Aide, preferably from the CDF Unit that contains the incident, be assigned the duty.

The person conducting the Initial Assessment shall complete the following tasks:

1. Get the Location of the Fire. Obtain information from the ECC concerning the location of the fire. At a minimum this must include legal location including Township, Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 11

Range, and Sections. If a map is available it should be obtained via Fax or E-mail. When assessing the location of the fire, be sure to include surrounding areas that may become affected.

2. Get the List of Agencies. Obtain from the ECC a list of any other agencies whose lands are involved in the incident.

3. Collect Pertinent USGS Quad Maps. Obtain the original USGS 7.5 minute topographic map or maps covering the fire and surrounding areas. Also collect 15 minute and other maps for the general area if these are available. Note: the USGS discontinued publishing the 15’ map series about fifteen years ago, and these are now considered as historic maps, which is reinforces their value for cultural resource investigations. They often date to the 1940s or 1950s and display the locations, or former locations, of historic buildings, cemeteries, sites, mining areas, and other useful information. Many of the CDF Archaeologists have access to these maps for their areas of responsibility.

4. Conduct an Archaeological Records Check. Place a call to the appropriate Information Center (IC) and collect information about all known cultural resources within and near the area containing the fire. Pencil the locations of specific site locations onto the USGS quad map, record their designators, and take notes regarding what these resources consist of, including size, location, and description. If there are not too many site records involved, and this can be done quickly, obtain copies of pertinent site records via Fax, E-Mail, or through pick-up at the IC. There will be fee for this records check, and this work needs to be paid for by the incident. Make arrangements to have the invoice prepared quickly and sent to the appropriate location for payment. Contact any CDF Archaeologist if assistance is needed to complete this important task. Other sources may sometimes be used instead of checking at the IC (see discussion under “Planning for the Future” on page 17). During previous CDF fires, the ICs have demonstrated the ability to respond rapidly to such emergency requests. During the Piru Fire (1998), the request came from Archaeologist Brian Dillon at the incident and the response was sent directly to him at the Incident Command Post via Fax.

5. Conduct Literature and Map Review. Review pertinent anthropological and archaeological source books for prehistoric site information. Review historic mining, lumbering, emigrant trails, and other source books for historic site information. Review maps, including out-of-print Government Land Office (GLO) Plats and USGS 15’ quadrangles, for indications of unrecorded sites and features. Gather other pertinent information and literature for the area including phone number lists for key contacts (ICs, agency archaeologists, SHPO staff, Native American Contact List, etc.). Standard references such as Handbook of North American Indians-Volume 8-California (Heizer 1978) and California Archaeology (Moratto 1984) should be included. Gather these materials and assemble them in an archive box that can be efficiently utilized at the fire.

6. Check with the NAHC. Place a call to the Native American Heritage Commission at (916) 653-4040 or (916) 653-4082. Ask for Rob Wood, or Debbie Pilas-Treadway. Report that you are responding to an emergency incident, and wish to check the Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 12

incident location against the Sacred Lands File or any other File or database on cultural resources they may have. For any “hits” plot the site locations and make notes of site descriptions. If you are unable to make contact leave a message and provide a callback number. Ask for assistance from a CDF Archaeologist to continue to follow-up should you be unable to reach the NAHC with the initial attempt.

7. Check with Local Native Americans. Place a call to local Native American groups listed on CDF’s Native American Contact List, notify of the location of the fire, provide your telephone numbers, and request information regarding cultural resource locations that may be threatened by fire or suppression efforts. If you are unable to make contact, leave a message, and provide a callback number. Ask for assistance from a CDF Archaeologist to continue to follow-up should you be unable to reach any local Native Americans with the initial attempt.

8. Check with Agency Archaeologists. Place a call to agency archaeologists for any agency identified in step (2) listed above. Request information on known cultural resources they may have on file and invite their participation in protection efforts.

9. Conduct Sensitivity Assessment. The above-listed eight steps should be completed quickly as part of a sensitivity assessment to determine what if any level of participation by Archaeologists or Archaeological Aides on the incident is warranted. If this assessment determines that important cultural resources are unlikely to be affected by suppression or suppression repair activities, an Archaeologist or Archaeological Aide may not need to be deployed to the fire. If the review does result in the determination that important cultural resources are threatened, the reviewer will contact the CDF Region Archaeologist for input. If it is determined that important cultural resources are threatened by suppression activities the Region Archaeologist will contact the ECC Duty Chief and request assignment of an Archaeologist, or if none is available an Archaeological Aide to the incident.

An Archaeologist or Archaeological Aide should follow the below listed set of procedures once he or she accepts a fire assignment:

1. Contact Person that Completed Initial Assessment. After receiving an incident assignment from a CDF Command Center contact the Region Archaeologist or other person that performed the initial assessment of the incident. Obtain information including the locations of known archaeological sites and/or locations of perceived high archaeological sensitivity.

2. Gather Equipment. Have your Personal Protective Equipment (PPE) already packed in a field bag. Also assemble appropriate field equipment for archaeological survey work, pertinent reference materials, available topographic maps that cover the incident area, and respond to the assigned reporting location.

3. Check-in at Incident. Following check-in at the incident report to the Planning Section, ascertain who you will be reporting to (this will typically be the Situation Unit Leader), and obtain an incident briefing. Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 13

4. Prepare Map. Plot known archeological site locations and high sensitivity locations on an archaeological base map. Review Incident Action Plan (IAP) for description of general fire control objectives in these areas.

5. Develop Work Plan. Develop prioritized plan for 1) field inspecting known site locations based upon estimated threats from fire and/or suppression, 2) inspecting proposed new fire control line construction, and 3) inspecting existing fire control line in potentially sensitive areas. In addition to firelines, give consideration to other suppression activities such as Incident Command Post, Incident Base, camp locations, staging areas, air operations sites such as helitack bases, portable water tank locations and water collecting localities.

6. Consider Additional Resource Needs. Work with the Planning Section Chief (or Situation Unit Leader) to acquire any additional resources (Archaeologists or Archaeological Aides) that may be needed to implement the plan.

7. Implement Work Plan. Conduct field surveys and flag previously recorded and newly discovered sites. Prepare notes regarded needed site protection strategy and work with Planning Section/Situation Unit personnel to get these protection included in the next IAP. Give consideration to the need for confidentiality. It may be possible and appropriate to designated places as “sensitive area” or “special treatment areas” in the IAP and related maps.

8. Fire Suppression Repair. Participate in development and implementation of the fire suppression repair plan to ensure that cultural resources are adequately addressed.

9. Record Keeping. Collect and transmit records and logs to Documentation Unit at the end of each operational period.

10. Logs. Maintain Unit/Activity Log (ICS Form 214).

Recommended Tactics and Strategies

1. When you accept an assignment as an Archaeologist or Archaeological Aide, the ECC will let you know the logistical specifics. Write down your order number and request numbers. They will be needed when you check in at the incident and also on all timesheets.

2. If you can drive, do it. Fires always seem to be short on vehicles, and having your own transportation will help you accomplish your job since you will be working relatively independently. It will be helpful too if the vehicle you drive to the fire is a four-wheel drive vehicle. When you arrive at the fire, go directly to check in. This is typically at the ICP or on the incident itself.

3. When you check in, find out who the Planning Section Chief is - this is your contact, within the ICS. If you're headed to a smaller local fire, with no team assigned, ask ECC who your contact is at the incident. Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 14

4. Go to every operational briefing before the upcoming shift. This will usually be a morning briefing, although evening briefings are also possible. These briefings are where you will get your assignment and the Incident Action Plan (IAP) that includes the communications plan (frequencies and channels for all aspects of the incident), and incident objectives. Operational briefings are where you will hear the plans for the next operational period; where equipment is working, crew assignments, air operations, etc. The CRO should try to attend the planning meeting too, if you can get invited (it is usually just the Section Chiefs) because this is where the Incident Action Plan (IAP) is developed. Resource protection is usually one of the objectives, so if there are cultural resource concerns, ask the Planning Section Chief to address them (or let you address them) at the operational briefings and at the planning meetings. On major wildland fires there is likely to be evening shifts, and a lot of dozerline may be constructed at night while the fire may have calmed. In such cases, attend the evening operational briefing to supply any cultural resource information that would be useful for the upcoming shift.

5. After the morning briefing (which usually lasts about 30-40 minutes), let the Division Supervisor know that you're there, what you're doing, and what your schedule is. The Division Supervisor may want you to check in with him/her on a regular basis to keep tabs on you. If fire conditions are especially dangerous you will probably be requested to "attach" yourself to another resource, like a dozer boss, or a crew. When you leave a division to go back to the incident base or to a new assignment, let the Division Supervisors know. This will allow everyone to avoid considerable frustration when someone is looking for you - personal accountability is critical.

6. Walking in front of the dozer is a potentially dangerous assignment; let the dozer supervisor and operator know what you are trying to do. If you can route the equipment around a site, you've earned your pay... remember that the dozer supervisor has the final say on what the equipment does - that person is responsible for the safety of the equipment and operator. Do not second guess the dozer supervisor’s decisions about routing the line -- this is his or her job, and he or she is responsible for getting it done, safely. Safety is the overriding concern on any fire - think about everything that you do, as the consequences of a mistake are magnified to a potentially fatal level. Be mentally prepared for this assignment. Don't attempt to walk in front of a dozer at night, or if you feel unsafe (like direct attack or in a very smoky situation) - keep in mind, that to complete pedestrian survey, you have to be able to see the ground. A note on safety - you need to have a certain familiarity with working around heavy equipment.

7. On the communication note, don't even think about walking the line without a radio. As a single resource, you must have a radio for personal safety and accountability. If you do not feel that you have been adequately trained to operate the radio, be sure to update this training before you accept an assignment to an incident. You can use your home unit radio on large fires, but be sure to see the Communication Unit Leader to have it programmed for the frequencies on that particular fire. On larger incidents, you may be able to check out a radio from the Communication Unit. Get a copy of the communications plan (usually in the IAP that you can get at the operational briefing), so that you know who is using what channels. Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 15

8. If more than one dozer is operating, lots of new fireline construction will take place, or if you are finding lots of cultural resources, ask for another/more Archaeologists or Archaeological Aides to be assigned. The goal is to survey before initial line construction and other ground disturbance; there are many additional opportunities to further impact a site after the initial line is cut (line improvement, mop up, and suppression repair work), so survey as soon as you can.

9. After new fireline construction has been completed, the dozers and crews will usually be put to work improving the fireline (breaking up slash piles, widening the line, etc.). Now is the time to get out and walk those lines, helispots, camp locations, etc. that perhaps could not be surveyed before initial impact. Do this as soon as possible. The point in doing this, is to avoid additional impact to sites that were hit during initial impacts, either from improvements, mop up, or suppression repair work. If there are sites that have been hit, or are close to the line, flag them heavily. Be sure to use the color designated for cultural resources use on this fire. It can't be stressed enough that between line improvement, mop up, and suppression repair work, there are many opportunities for additional impacts to sites. After you've looked at the dozer lines, look at the hand constructed fire lines. Although the potential for damage is less on hand lines, it does exist, and the impacts should be surveyed.

10. Look around for other impacts from the fire suppression activities. A few examples are the Incident Command Post and Incident Base, camps, helipads/spots, bladed safety zones, water source (portable tanks) locations, staging areas, and areas that might contain resources particularly sensitive to smoke (like rock art). Other possible impacts are new roads or dozer lines to access the fire. All ground disturbance and other direct impact to cultural resources from the fire and fire suppression activities need to be accounted for in the report.

11. When you obtain a better idea of the kind of cultural resources you're dealing with, consider your ability to locate and protect them. If you need additional resources that have broader expertise or regional expertise, or if you need experts that can help identify special kinds of cultural resources, consider ordering them. For example, if Native American traditional cultural properties are identified, you may want to request a local Native American expert to assist in its identification. If so, they may request to be placed on the payroll, and if this is approved, they will need an order and request number. Some of these experts have fire training and can work with you on the line. Other situations may require consultation over the telephone. Likewise, cultural resource experts with experience identifying cultural landscapes, petroglyphs or pictographs, or emigrant trails, may on occasion be needed for assistance.

12. Be prepared to prioritize the survey work that needs to be done. Always try to get to the known site locations and high probability areas that are about to be impacted first, and then to the impacts that have already occurred, realizing that there are often subsequent phases of impact (especially lines, but also consider camps, bladed safety areas, air ops, and portable water tank locations). After a few assignments, you'll get a feel for what impacts are associated with specific activities; this will help you set priorities.

13. The archaeologists will have at least two, and possibly three separate reporting Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 16

requirements. The first of these is Unit Activity Log (ICS Form 214). Check with the Planning Section Chief/Situation Unit Leader for direction concerning the expected content and frequency of these periodic reports. They will be provided to the Documentation Unit. The Planning Section may request to prepare a report describing the entirety of your efforts on the incident. You may also be requested to develop a section for the Suppression Repair Plan that contains management recommendations for cultural resources. Note: the term suppression repair is being developed by CDF to replace the term rehabilitation. The archaeologist should consult and work closely with the Unit Forester in the development of the suppression repair plan. The Unit Forester is a great source of information and will probably be in a key position in the Suppression Repair Team. If you can not locate the Unit Forester, you should always find the Suppression Repair Team Leader, if there is one. We suggest these efforts to make sure that cultural resources are fully considered in the development of suppression repair plans. Be sure that you have an opportunity to contribute to them. Be as specific as possible on this - for example, if they need to stay out of areas for waterbarring, but seeding is OK, write it in the report. If at all possible, show the locations of sensitive sites to key personnel on the ground to discuss specific protection strategies.

14. The archaeologist should be sure to send copies of all appropriate reports to appropriate agency archaeologists, and the appropriate Information Center of the California Archaeological Information System.

Contract Archaeologist Resources

Each year, CDF develops a contract with a large private archaeological survey firm to respond on demand for services in response to CDF wildland fires. For the past two years, the firm Far Western Anthropological Research Group, Inc, from Davis, California, has been retained for this purpose. When so requested by CDF, and if sufficient funds are still available in the contract, this contractor can provide additional resources to complete archaeological survey work following CDF wildland fires. Contact Dan Foster or any CDF Archaeologist to inquire upon the availability of recruiting contract surveyors to complete this work.

Planning for the Future

CDF is developing a new Computer Automated Drafting (CAD) program that may have the capability of GIS layers containing the locations of known cultural resources. CDF should continue to explore the possibility of developing a statewide data base of cultural resources so such information can be more efficiently gathered during an emergency incident. We recommend that CDF continue to work with the State Office of Historic Preservation and the Information Centers to explore ways to obtain and develop this information. CALTRANS is one state agency that has been funding a project leading to the digitization of archaeological site locations along Highway rights-of-way in Northern California. Perhaps CDF, some day in the future, if funds are ever available for this purpose, could assist with funding similar data collection projects, leading to a complete Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 17 data set for all 33 million acres of SRA lands and those other lands CDF is responsible for Direct Protection.

CDF’s San Diego Unit is currently exploring the possibility of obtaining a data set containing the digitized locations of all 16,000 recorded archaeological and historical sites within San Diego County. Half of this data entry has already been completed for the entire western half of the county. The Unit is considering a project for a CDF GIS expert to participate in the digitization of recorded cultural resource locations for the eastern part of the county, in exchange for CDF’s access to the entire data set. Of course, confidentially provisions will need to be clarified, but this is an example of a project that is intended to better plan for future CDF wildland fires. If completed, the Unit intends to implement a system that would immediately advise personnel responding to the fire of the existence and general location of sensitive resources in the area.

Some planning efforts can be done right now, even without funding support. CDF has three databases for three small areas within California: Jackson Demonstration State Forest, Mountain Home Demonstration State Forest, and the Coalinga Battalion in Fresno- Kings Unit. The first project completed by CDF to gather information about all known cultural resources within a given area, so those cultural resources could be protected, if possible, during CDF wildland fires, occurred in CDF’s Coalinga Battalion on the west side of the Fresno-Kings Unit. Battalion Chief Bill Johnson initiated the effort, with the support of the CDF Archaeology Program. Over 100 archaeological sites were identified during the inventory work which took place from 1988-1994 (Betts and Foster 2001). Although this information was provided to CDF in paper, not electronic, form, we hope that it can be utilized to help protect cultural resources during CDF wildland fire suppression work in this remote part of central California.

Also, one day in the future, if the economy of state government ever recovers sufficiently to allow state agencies like CDF to recruit additional staff, we recommend that CDF Fire Protection program give consideration to hiring staff archaeologists. They are needed to help carry our training assignments and important archaeological survey work following wildfires. In the interim, CDF’s small team of archaeologists is committed to do everything possible to conduct, assist, and support this important work, but with thousands of annual Resource Management projects, including training and review responsibilities mandated by the Forest Practice Rules, our availability is extremely limited and without additional staff resources, CDF’s ability to carry out effective procedures will be affected.

Acknowledgments

This document was written by Dan Foster and Rich Jenkins. We were fortunate, however, to have received permission to incorporate some excellent material previously written on this subject by Hanson (2001) and Dillon (1996) who are listed as contributing authors. Both Hanson and Dillon also reviewed earlier versions of the draft report and offered helpful suggestions. We also want to acknowledge the contributions made by many of our CDF colleagues who helped us develop these procedures, provided information, or carefully edited our draft report. These include Kevin Locke, Frank Goddard, Carol Jolley, Pete Scully, Ken McLean, Allen Robertson, Doug Wickizer, Linda Sandelin, and Dennis Hall. Foster, Jenkins, Hanson, and Dillon Draft Procedures to Protect Cultural Resources During CDF Wildland Fire Suppression 18

References Cited

Betts, John and Daniel G. Foster 2001 Investigations of the Coalinga Archaeological Research Group 1988 to 1994. CDF Archaeological Reports Number 29, California Department of Forestry and Fire Protection, Sacramento.

Berg, John, Allika Ruby, and Linda C. Sandelin 2003 Archaeological Survey and Fire Damage Assessment Report for the Pines Fire, Julian, San Diego County, California. Manuscript in Preparation, California Department of Forestry and Fire Protection, Sacramento.

Dillon, Brian D. 1996 Why Archaeology is Important. An article on the CDF Archaeology Program Web Site at: http://www.indiana.edu/~e472/cdf/why/why.html

Foster, Daniel G. 2002 Archaeological Review Procedures for CDF Projects. California Department of Forestry and Fire Protection, Sacramento.

Hanson, Lisa 2001 Technical Specialist - Archaeology. CDF Manuscript Number 168, on file at the CDF Archaeology Office, Sacramento.

Heizer, Robert F. (the Volume Editor) 1978 Handbook of North American Indians, Volume 8, California. Smithsonian Institution Press, Washington, D.C.

Jenkins, Richard C. and Steven Grantham 2002 Archaeological Property Damage Assessment for the Pines Fire, August 2002, CA- MVU-005658. California Department of Forestry and Fire Protection, Sacramento.

Moratto, Michael J. 1984 California Archaeology. Academic Press, Orlando, Florida.