Addendum B – Cultural Resources Inventory Report
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City of San Carlos Fuel Management Project Addendum B – Cultural Resources Inventory Report April 14, 2019 Amy Newby, Director City of San Carlos Department of Parks and Recreation 600 Elm Street San Carlos, CA 94070 Subject: Cultural Resources Inventory Report for the San Carlos Fuel Management Project, City of San Carlos, California – Negative Findings Dear Ms. Newby: This letter documents the negative cultural resources inventory conducted by Dudek for the San Carlos Fuel Management Project (Project), located in the City of San Carlos, California. The City of San Carlos (City) is lead agency responsible for compliance with the California Environmental Quality Act (CEQA). All cultural resource fieldwork and reporting for this project has been conducted by archaeologists meeting the Secretary of the Interior’s Professional Qualifications Standards. A Native American Heritage Commission (NAHC) Sacred Lands File (SLF) search did not suggest the presence of any Native American cultural resources. A Northwest Information Center (NWIC) records search indicated that no cultural resources have been recorded within the area of potential effects (APE). Intensive-level pedestrian survey conducted of the APE did not identify cultural resources. PROJECT LOCATION DESCRIPTION The Project site is located in the southern portion of the City of San Carlos. The Project site is situated in Sections 14, 22, and 23, Township 18 South, Range 17 East and the very western portion of Section 9, Township 5 South, Range 4 West, on the Woodside U.S. Geological Survey 7.5- topographic quadrangles (Figure 1). The Project site is divided into four sections, each located in four parks within the city limits: Eaton Park, Big Canyon Park, Crestview Park, and Highlands Park (Figures 2 and 3). The parks are currently in use and contain athletic fields, parking lots, and hiking trails. All sections of the project area are extremely sloped with elevations ranging from 270 feet to 760 feet above mean sea level. The Project consists of vegetation treatment or removal in an effort to reduce wildfire fuel to ensure safety of the surrounding community. The City proposes to treat vegetation in selected areas of Subject: Cultural Resources Inventory Report for the San Carlos Fuel Management Project, City of San Carlos, California – Negative Findings Eaton Park, Big Canyon Park, Crestview Park, and Highlands Park. The City has described three main goals for the Project: Conduct targeted fuel reduction treatments using hand crews, masticators, track chippers, herbicides, and herbivory to reduce highly combustible underbrush and other flammable vegetation within the defensible space zone of adjacent private ownerships. Create strategic fuel breaks using hand crews, masticators, track chippers, and herbivory to reduce highly combustible underbrush and other flammable vegetation along access roads and ridgelines Remove dead/diseased and non-native shrubs/trees as part of a comprehensive fuel reduction effort. Maximum acreage of vegetation treatment consists 65.3 acres in Eaton Park, of 55.3 acres in Big Canyon Park, 3.4 acres in Crestview Park, and 7.4 acres in Highlands Park. The Project APE consists of all the areas of vegetation treatment, totaling 131.4 acres. REGULATORY CONTEXT While the Project as currently planned is subject only to state and local regulatory conditions, all work has been conducted in compliance with federal regulations as well. As such, federal regulations are also provided here for reference should they be required in the future. Federal Regulations National Historic Preservation Act The NHPA established the National Register of Historic Places (NRHP) and the President’s Advisory Council on Historic Preservation (ACHP), and provided that states may establish State Historic Preservation Officers (SHPOs) to carry out some of the functions of the NHPA. Most significantly for federal agencies responsible for managing cultural resources, Section 106 of the NHPA directs that “[t]he head of any Federal agency having direct or indirect jurisdiction over a proposed Federal or federally assisted undertaking in any State and the head of any Federal department or independent agency having authority to license any undertaking shall, prior to the approval of the expenditure of any Federal funds on the undertaking or prior to the issuance of any license, as the case may be, take into account the effect of the undertaking on any district, site, building, structure, or object that is included in or eligible for inclusion in the NRHP.” Section 106 also affords the ACHP a reasonable opportunity to comment on the undertaking (16 USC 470f). 11719 2 April 2019 Subject: Cultural Resources Inventory Report for the San Carlos Fuel Management Project, City of San Carlos, California – Negative Findings 36 Code of Federal Regulations, Part 800 (36 CFR 800) implements Section 106 of the NHPA. It defines the steps necessary to identify historic properties (those cultural resources listed in or eligible for listing in the NRHP), including consultation with federally recognized Native American tribes to identify resources with important cultural values; to determine whether or not they may be adversely affected by a proposed undertaking; and the process for eliminating, reducing, or mitigating the adverse effects. The content of 36 CFR 60.4 defines criteria for determining eligibility for listing in the NRHP. The significance of cultural resources identified during an inventory must be formally evaluated for historic significance in consultation with the California SHPO to determine if the resources are eligible for inclusion in the NRHP. Cultural resources may be considered eligible for listing if they possess integrity of location, design, setting, materials, workmanship, feeling, and association. The criteria for determining eligibility are essentially the same in content and order as those outlined under the California Environmental Quality Act (CEQA), but the criteria under NHPA are labeled A through D (rather than 1-4 under CEQA). Regarding criteria A through D of Section 106, the quality of significance in American history, architecture, archaeology, engineering, and culture is present in districts, cultural resources, buildings, structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling, and association, and that: A. are associated with events that have made a significant contribution to the broad patterns of our history; or B. are associated with the lives of persons significant in our past; or C. embody the distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or D. have yielded or may be likely to yield, information important in prehistory or history [36 CFR 60.4]. The current cultural resources inventory is not designed to generate enough data to make eligibility recommendations on previously recorded cultural resources that are outside of the project area, or newly discovered cultural resources; such determinations are typically made during a subsequent evaluation phase (e.g., excavations at prehistoric sites). However, the survey was designed to generate enough information to provide informal assessments of eligibility to help guide management considerations. 11719 3 April 2019 Subject: Cultural Resources Inventory Report for the San Carlos Fuel Management Project, City of San Carlos, California – Negative Findings State of California The California Register of Historical Resources In California, the term “historical resource” includes “any object, building, structure, site, area, place, record, or manuscript which is historically or archaeologically significant, or is significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California” (Public Resources Code (PRC) Section 5020.1(j)). In 1992, the California legislature established the California Register of Historical Resources (CRHR) “to be used by state and local agencies, private groups, and citizens to identify the state’s historical resources and to indicate what properties are to be protected, to the extent prudent and feasible, from substantial adverse change” (PRC Section 5024.1(a)). The criteria for listing resources on the CRHR, enumerated in the following text, were developed to be in accordance with previously established criteria developed for listing in the NRHP. According to PRC Section 5024.1(c)(1–4), a resource is considered historically significant if it (i) retains “substantial integrity,” and (ii) meets at least one of the following criteria: (1) Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage (2) Is associated with the lives of persons important in our past (3) 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 (4) Has yielded, or may be likely to yield, information important in prehistory or history To understand the historic importance of a resource, sufficient time must have passed to obtain a scholarly perspective on the events or individuals associated with the resource. A resource less than 50 years old may be considered