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California Flats Solar Project EIR Section 4.5 Cultural and Paleontological Resources

4.5 CULTURAL AND PALEONTOLOGICAL RESOURCES

4.5.1 Summary

Table 4.5-1 summarizes the identified environmental impacts, proposed mitigation measures, and residual impacts of the proposed project related to cultural and paleontological resources. Additional detail is provided in Section 4.5.3 (Impact Analysis).

Table 4.5-1 Impact and Mitigation Summary: Cultural and Paleontological Resources

Impact Mitigation Measures Residual Impact Impact CR-1 Construction and CR-1(a) Archaeological Site Implementation of Mitigation decommissioning of the proposed Avoidance. Wherever feasible, direct Measures CR-1(a) through CR-1(f) project would involve surface impacts on NRHP/CRHR-eligible would reduce impacts to historic and excavation, which has the potential to archaeological sites shall be avoided. archaeological cultural resources to a unearth or adversely impact identified Avoidance shall be accomplished by less than significant level. NRHP/CRHR-eligible prehistoric or preventing any direct ground historic archaeological resources. disturbance of the resource. If Impacts would be Class II, significant avoidance of any direct disturbance is but mitigable. [Threshold 1] deemed feasible by RMA – Planning based on the sensitivity of the resource relative to the severity of impact, the boundaries of the NRHP/CRHR-eligible sites shall be marked in the field by a Registered Professional Archaeologist prior to ground disturbance with exclusionary fencing, lath, flagging tape, or some other combination of material that is highly visible, durable, and which construction and management personnel can recognize as marking an exclusion zone where no earth disturbance or other activity shall occur. Exclusion zones shall be inspected weekly by an archaeological monitor or other environmental inspector to ensure that they are being honored, remain effective, and in place. If complete avoidance is not feasible, mitigation measures CR-1(b) and CR-1(c) shall apply.

CR-1(b) Site Capping and Data Indexing. If direct disturbance of NRHP/CRHR-eligible archaeological or historic resources cannot be avoided, placement of chemically neutral, culturally sterile, nonreactive fill on top of the sites, rather than cutting into the cultural deposits, shall be required, when determined feasible by the Monterey County RMA – Planning Department. Because sites on which fill would be placed would no longer be accessible to

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Table 4.5-1 Impact and Mitigation Summary: Cultural and Paleontological Resources

Impact Mitigation Measures Residual Impact research, a data indexing program shall be implemented to characterize the nature of the portions of the site to be buried (if they have not been sampled previously). The indexing program shall include mapping the location of surface artifacts within the proposed areas of fill; surface collection of those artifacts; and excavation of a small sample, determined by a Registered Professional Archaeologist, of the cultural deposit to characterize the nature of the buried deposit. All earth disturbances associated with placement of the fill shall also be monitored by a qualified archaeological monitor under the direction of a Registered Professional Archaeologist, as well as a tribal consultant if the site is of Native American origin, to prevent any residual impact associated with the loss of research data. Cultural materials recovered during the data indexing program shall be curated at an appropriate archaeological curation facility and copies of all reports shall be provided to RMA- Planning and the Northwest Information Center at Sonoma State University. The reports shall include detailed geospatial data regarding the locations of capped sites and these data shall be used to avoid new impacts during decommissioning.

CR-1(c) Data Recovery Excavation. If avoidance [CR-1(a)] or capping [CR-1(b)] of NRHP/CRHR-eligible cultural resources is not possible, the project applicant shall complete a Phase III data recovery excavation program for significant cultural resources that would be impacted prior to project disturbance. Phase III data recovery shall be directed by a Registered Professional Archaeologist and include the preparation of a work plan/research design, fieldwork, laboratory analysis of recovered artifacts and ecofacts, special studies if appropriate, the preparation of a technical report, and curation of recovered materials. The Research Design shall be reviewed and approved by the Monterey

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Table 4.5-1 Impact and Mitigation Summary: Cultural and Paleontological Resources

Impact Mitigation Measures Residual Impact County RMA—Planning Department prior to its implementation. A tribal consultant shall be present for all data recovery excavations of sites of Native American origin.

CR-1(d) Archaeological Resource Worker Environmental Awareness Program. Prior to the commencement of construction a Registered Professional Archaeologist or a monitor under their direction shall provide a Worker Environmental Awareness Program (WEAP) for the general contractor, subcontractor(s), and construction workers participating in earth disturbing activities. The WEAP training shall describe the potential of exposing archaeological resources, the types of cultural materials that may be encountered, and directions on the steps that shall be taken if such a find is encountered. This training may be presented alongside other environmental training programs required prior to construction. A WEAP acknowledgment form must be signed by all workers who receive the training.

CR-1(e) Archaeological Resource Construction Monitoring. A qualified archaeologist shall be retained by the Applicant to be present during all earth moving activities that have the potential to affect archaeological or historical sites. In the event that previously unidentified prehistoric or historic archaeological materials or human remains are encountered during project construction, mitigation measure CR-2 shall take effect. A monitoring report shall be submitted to RMA County Planning upon completion of construction.

CR-1(f) Native American Construction Monitoring. A tribal consultant (Native American monitor) shall be retained by the Applicant to be present during all earth moving activities that have the potential to affect prehistoric archaeological sites. The Native American monitor shall prepare daily logs and submit weekly updates to RMA – Planning.

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Table 4.5-1 Impact and Mitigation Summary: Cultural and Paleontological Resources

Impact Mitigation Measures Residual Impact Impact CR-2 Construction and CR-2 Previously Unidentified Implementation of mitigation measure decommissioning of the proposed Archaeological Resources. If CR-2 would reduce impacts to project would involve surface previously unidentified prehistoric or previously undiscovered cultural excavation, which has the potential to historic archaeological resources are resources to a less than significant unearth or adversely impact encountered during construction or level. previously unidentified cultural land modification activities, work resources. Impacts would be Class II, within the immediate vicinity of the significant but mitigable. [Threshold 2] find shall stop and the Applicant and the Monterey County RMA – Planning Department and project archaeologist shall be notified immediately. The project archaeologist, at the Applicant’s expense, will assess the content, age, association, and integrity of the find and the Applicant shall provide the Monterey County RMA – Planning Department with sufficient information to determine whether the resource is a CRHR- eligible resource. If the Monterey County RMA – Planning Department determines that the resource is not CRHR eligible or that it is CRHR eligible, but that additional data recovery would only yield redundant information, no additional mitigation will be required and construction can proceed. If the Monterey County RMA – Planning Department determines that the resource is CRHR eligible and that the discovery has significant historical associations or could yield additional scientific information about local or regional history or prehistory that has not been recovered during prior investigations, the Applicant shall implement MM- CR-1(a)-(c) and if of Native American origin CR-1(e).

If the site is determined insignificant, no further mitigation shall be required. However, archaeological and Native American monitoring may still be required in the vicinity of the site in accordance with mitigation measures CR-1(e) and CR-1(f). Impact CR-3 Construction and The project, as a standard condition Impacts would be less than decommissioning of the proposed of approval, would require compliance significant. project would involve surface with Section 7050.5 of the Health and excavation, which has the potential to Safety Code for the treatment and unearth or adversely impact disposition of human remains. previously unidentified human remains. Impacts would be Class III, less than significant. [Threshold 4]

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Table 4.5-1 Impact and Mitigation Summary: Cultural and Paleontological Resources

Impact Mitigation Measures Residual Impact Impact CR-4 Construction of the CR-4(a) Paleontological Resource Implementation of Mitigation proposed project would involve Mitigation Plan. Prior to grading Measures CR-4(a) and CR-4(b) would surface excavation. Although unlikely, activities, a Paleontological Resource reduce impacts to previously these activities have the potential to Mitigation Plan (PRMP) shall be undiscovered paleontological unearth or impact previously prepared for the project by a qualified resources to a less than significant unidentified paleontological professional paleontologist as defined level. resources. Impacts would be Class II, by the Society of Vertebrate significant but mitigable. [Threshold 3] Paleontology (SVP, 2010). The PRMP should include a map identifying the locations where monitoring is required, provide protocols for construction monitoring and the recovery of significant , identify the Project Paleontologist and on-site monitors, and make provisions for preparation, curation, and reporting. The PRMP shall be reviewed and approved by the Monterey County RMA- Planning Department prior to its implementation.

CR-4(b) Paleontological Resource Construction Monitoring. Full-time monitoring shall be required during ground disturbing activities in areas determined to have a high paleontological sensitivity. All work shall be conducted by a qualified paleontological monitor as defined by the SVP (2010) and in conformance with the PRMP (mitigation measure CR-4a). Monitoring efforts can be reduced or eliminated at the discretion of the Project Paleontologist if, after 50 % of the excavations are completed, no fossil resources are encountered. If deemed appropriate by the Project Paleontologist, part-time monitoring or spot checking may occur during the construction of the project in areas underlain by Quaternary surficial alluvial sediments to determine if underlying sensitive geologic units are being impacted by construction and at what depth.

If significant fossils are unearthed during construction, paleontological recovery shall be carried out. Recovery shall include: salvage of significant fossils; washing of representative samples of sediments that are likely to contain the remains of small fossil invertebrates and vertebrates; preparation of recovered

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Table 4.5-1 Impact and Mitigation Summary: Cultural and Paleontological Resources

Impact Mitigation Measures Residual Impact specimens to a point of identification to the lowest taxonomic level and permanent preservation; identification, curation, and accession of specimens into a museum repository with permanent retrievable storage; preparation of a report of findings by the Project Paleontologist with an appended itemized inventory of specimens. The report, inventory, and record of accession shall be submitted to Monterey County and the curation facility, and its submission shall signify completion of the program to mitigate impacts to paleontological resources.

4.5.2 Setting

a. Regional Environmental Setting. The proposed project would be located in unincorporated southeastern Monterey County; approximately seven miles southeast of the community of Parkfield and 25 miles northeast of the City of Paso Robles, near the borders of Monterey, San Luis Obispo, Kings and Fresno counties (refer to Figures 2-1 and 2-2 in Section 2.0, Project Description). The unincorporated area of Monterey County contains a number of historic resources, including Mission Nuestra Señora de la Soledad and the Old Mission School near Soledad, the Site of the Battle of Natividad near Salinas, and the Glass House in Pajaro. Archaeological and paleontological resources have also been found at numerous sites in the County.

The California Flats project area is within the interior portion of the South Coast Ranges, a mountain group that runs north and south parallel to the Pacific Coast on the west and the Sierra Nevada Range to the east. This system forms much of the western margin of the San Joaquin Valley. The principal geologic structures within the Central Coast portion of the South Coast Range province include the Santa Lucia Mountains, the Temblor and Diablo ranges, the Salinas Valley, and the Carrizo Plain.

b. Project Site Setting. The proposed project site is located within the interior portion of the South Coast Ranges, in a northeastern extension of the Cholame Valley known as Turkey Flat. Turkey Flat is a gently undulating, largely treeless grassland incised by several springs and drainages; it is flanked on the east by the often-steep hills of the Diablo Range. Elevations within the project site range from 1,600-2,100 feet above mean sea level (amsl); the access road descends to 1,175 feet amsl where it meets State Route 41. Turkey Flat Road, the main graded dirt road, divides the property; numerous ranch roads intersect it.

The disturbance area of the proposed project encompasses all areas where the proposed project could affect paleontological resources and properties eligible for the National Register of Historic Places (NRHP) or the California Register of Historical Resources (CRHR). This includes

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not only the lands to be cleared of vegetation, graded, or otherwise prepared for installation of the PV solar modules themselves, but also the locations of inverters, transformers , substations, switching station, transmission lines, power poles, and all related electrical equipment. Construction laydown/staging areas, other temporary work locations, access roads, and the site of the O&M facility also are included in the disturbance area, along with any wells, leach fields, and other infrastructure needed to support the project.

c. Historical Background. The following setting information is based on the Cultural Resources Inventory and Evaluation for the California Flats Solar Project prepared by Applied Earthworks (AE) in July 2013.

Prehistory and Archaeology. The project site is located within the interior of the South Coast Ranges, 42 miles from the coast at Morro Bay and 35 miles from the western edge of the San Joaquin Valley. Lying between these two culturally and materially distinct regions, the interior South Coast Ranges have been virtually unstudied archaeologically and is thus poorly understood. Recent investigations, however, by Basgall and Giambastiani (1999) at Cottonwood Canyon, Berg and Hildebrandt (2000) near Cholame, Mikkelsen et al. (2003) along the SR 46 corridor near Shandon, Stevens et al. (2004) along the Salinas River in Paso Robles, and Hildebrandt (2006) in Priest Valley, have begun to shed light on the local prehistory. The following discussion summarizes both coastal and valley prehistory, as well as the corresponding evidence from the area in which the proposed project would be located.

David Fredrickson’s 1973 Early Cultures of the North Coast Ranges and his 1994 study Toward a New Taxonomic Framework for Central California Archaeology, divided California prehistory into six periods. The six periods of central California prehistory and their associated date ranges are listed in Table 4.5-2 below.

Table 4.5-2 Periods in Central California Prehistory Period Calibrated Radiocarbon Date Range Upper Emergent Cal A.D. 1500-1769 Lower Emergent Cal A.D. 1000-1500 Upper Archaic 600 cal B.C.-cal A.D. 1000 Middle Archaic 5000-600 cal B.C. Lower Archaic 8000-5000 cal B.C. Paleo-Indian Prior to 8000 cal B.C. Source: Applied Earthworks, Inc. (AE) Cultural Resources Inventory and Evaluation for the California Flats Solar Project. July 2013.

Paleo-Indian Period. Late Paleo-Indian occupation is recognized by the Clovis-like fluted projectile points that are the well-known markers of that period. Accurate calendar correlation of radiocarbon age determinations from Clovis sites is not currently possible because of correlation uncertainties. In California, the most substantial Clovis site currently known is located in the southern San Joaquin Valley and has produced hundreds of fluted projectile points as well as other artifacts (Riddell and Olsen, 1969). However, no Paleo-Indian sites have been recorded in the general vicinity of the proposed project (AE, July 2013). Along the Central Coast, evidence from this early period is limited to fluted projectile point fragments discovered

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near Santa Margarita, Nipomo, and the Goleta coast (Bertrando, 2004; Erlandson, 1994; Erlandson et al., 1987; Gibson, 1996; Mills et al., 2005) and sites on Santa Rosa and San Miguel Islands that have contemporary dates but did not produce Clovis points or similarly diagnostic artifacts (Agenbroad et al., 2005; Erlandson et al., 1996). These offshore sites provide clear evidence of watercraft use by California’s earliest colonizers.

Lower Archaic Period. Unlike the Paleo-Indian period, more conclusive evidence of human occupation has been found at sites dating to the Lower Archaic Period of the early Holocene, between 8000 and 5000 cal B.C. A growing number of Lower Archaic components have been identified, most located in coastal settings. This period is characterized by low population densities, semi-permanent settlements, subsistence activities aimed broadly at a diverse spectrum of terrestrial and marine resources, and evidence of widespread California Milling Stone adaptive patterns. The most common artifacts from this period are the eponymous milling slabs and hand stones used to grind hard seeds and process other foodstuffs. Choppers, core tools, and large bifaces also are common, while side-notched dart points, pitted stones, simple bone awls, bipointed bone gorges, and possible eccentric crescents occur in lesser frequencies (AE, July 2013).

Differences in site location, artifact assemblages, and faunal remains suggest that Lower Archaic populations were beginning to establish settlements tethered to the unique characteristics of the local environment and adopt subsistence practices responsive to local conditions. Obsidian found at some Lower Archaic sites originated on the east side of the Sierra Nevada, suggesting that long-distance trade networks were also established during the Lower Archaic period.

Middle Archaic Period. The Middle Archaic Period is not well represented in the southern San Joaquin Valley. Environmental changes including the onset of warmer, drier conditions resulted in the desiccation of Tulare and Buena Vista lakes and subsequent movement of populations upslope into the foothills of the Sierra Nevada and Transverse Range. Artifacts representative of this time include Rossi Square-stemmed and Contracting-stemmed projectile points, milling slabs, as well as pitted petroglyphs. These sites represent intensive use of upland valleys and drainages in the Diablo Range and a valley oak savannah adaption with an emphasis on hunting.

Upper Archaic Period. The Upper Archaic Period (600 cal B.C.–cal A.D. 1000) began with the onset of cooler, moister, and more stable late Holocene climatic conditions. Net weights and other artifacts of baked clay, stone-lined hearths, flexed burials, and circular houses indicate increasing sedentism. Exotic materials such as marine shell and obsidian point toward an expanded network of trade. Where ocean conditions were favorable, the Chumash utilized the tomol, a unique sewn plank canoe, which allowed for a greater reliance on marine resources, particularly fish, for food. The appearance of diverse archaeological site types during the Upper Archaic Period may reflect the rise of a logistically organized land-use system, wherein small task-specific groups of collectors leave the residential base temporarily to gather specific resources which are then returned to the residential settlement for processing, rather than moving the residential site frequently to exploit seasonally available resource patches (Hildebrandt and McGuire 2002).

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Emergent Period. The Emergent Period, from cal A.D. 1000 to the historic era, was a time of increasing economic and social complexity in many parts of California. Along the Central Coast and in the southern San Joaquin Valley, however, it appears that severe drought and environmental degradation reduced human population density and destabilized social and economic systems (Jones et al., 1999). Emergent Period sites in the southern San Joaquin Valley reflect greater material wealth and a diversified subsistence pattern typical of the ethnographically documented Yokuts Indians and their antecedents, whose settlements and subsistence practices focused on the unique lake-slough-marsh environments then present within the San Joaquin Valley (Latta, 1977; Moratto, 1984). The preponderance of bedrock and portable mortars attest to a greater emphasis on acorn, pine, and buckeye nuts. This adaptive pattern can be equated to the ethnographically documented Salinan people. As is probably the case with the ethnographic village site of Cholami, sites at the mouth of eastern Coast Range valleys may have served as trade centers linking the coast and the Central Valley (Milliken and Meyer, 1997:10)

Ethnography and Ethnohistory. The area in which the proposed project would be located lies on the historic boundary between the territories of two native groups: the Salinans and the Tachi Yokuts. It is possible the Cholame Valley area, which straddles a major trade route between the valley and the coast, served as a joint use area for both groups (Applied Earthworks, July 2013). The following is a general description of the aforementioned native groups.

Salinan. In general, Salinan territory consisted of a long narrow strip extending from the coast inland to the crest of the Coast Ranges. The area in which the proposed project would be located lies at the southeastern edge of the territory, within the sphere of the easternmost known ethnographic village at Cholame (Hester, 1978:501). The Salinans were never a politically united entity and may have numbered no more than 3,000 people prior to contact. To the south, the Salinans adjoined the Chumash, with whom they shared many cultural and linguistic traits. To the east, in the vicinity of the proposed project, was a more fluid boundary with the Tachi Yokuts, with whom they interacted freely (Hester, 1978:500; Mason, 1912:108).

The Salinans appear to have been quite mobile, moving their residences seasonally in the pursuit of a wide range of plant and small animal resources. Important resources include acorn, pine nuts, grass seeds, and chia, supplemented by buckeye, prickly pear, agave, seaweed, blackberries, wild grapes, and various nuts, roots, and tubers. Game included deer, rabbit, dove, quail, waterfowl, and occasionally bear. Although few of the small streams contained an abundance of fish, the Salinans caught salmon, trout, suckers, and bullhead, and obtained other species from Tulare Lake when visiting Tachi Yokuts territory. Abalone, clams, and other shellfish were obtained from the coast (Hester, 1978:501).

Salinan external economy was based on exchange of shell beads and ornaments with neighboring groups (Hester, 1978:502). Material culture, known mainly from the archaeological record, centered around resource procurement and processing. Mortars, pestles, and bedrock milling features were common food processing tools. The first known outside contact with the Salinans came in 1769, when the Portolá expedition crossed their territory en route to Monterey (Hoover et al., 1990). By 1808, much of the Salinan population was concentrated in mission communities (Bean and Rawls, 1988).

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Some researchers place the Salinan’s principal village of Cholami near the present-day Jack Ranch Café (Hester, 1978; Larson and Combs, 1988). Other evidence supports a location in the northern end of the Cholame Valley, with the smaller, related village of Tisagues located near the old Cholame store, now the Jack Ranch Café (Gibson, 1983:244; Glover et al., 1999:12; Milliken, 2000). Concentrating the native population at the missions made the Salinans especially susceptible to introduced diseases such as smallpox, influenza, tuberculosis, and treponematosis (Castillo, 1978:100). The Salinans had never been numerous, and the combined forces of acculturation, disease, and outright violence rapidly reduced the population that remained. Today, a few families keep some traditions and parts of the language alive, but most Salinans have blended into the larger population.

Tachi Yokuts. The nearest local group of Yokuts to the project area was the Tachi, whose territory centered around Tulare Lake, although it extended west to the Kettleman Hills (Cummins, 1978:143). The Tachi Yokuts were primarily valley dwellers, situating themselves along stream channels and on the shores of shallow lakes. While living along the sloughs and rivers in the valley, they procured fish, mussels, turtles, and waterfowl, complemented by terrestrial mammals, roots, and seeds. The Tachis’ contribution to the local trade network was primarily obsidian obtained from the Owens Valley Paiutes in exchange for items from the coast and San Joaquin Valley.

Housing was sometimes communal at the larger settlements, with large steep-roofed structures housing as many as ten families. Single-family dwellings were oval with a wood frame and tule matted floors (Wallace, 1978:450–451). Granaries covered in mats were suspended in trees or on poles and held acorns, dried fish, roots, seeds, and other foods. Resistance to mission establishment by the Yokuts took the form of a guerrilla war, which continued until the 1840s (Wallace, 1978:460). Elk and pronghorn hunting proved important to the Yokuts economic base as raiding parties expanded the stock of horses, discouraging European settlement in outlying areas (McCarthy, 1999). However, once the territory was annexed to the United States, settlers began to pour in. Many Southern Yokuts went to the Tejon and Fresno reservations (McCarthy, 1999); however, both these reservations failed, causing many Yokuts to reside at Tule River in 1859 (Wallace, 1978:460). In 1921 Santa Rosa Rancheria was established at an old village site approximately 45 miles east of the current project site. The federal government formally recognized the Tachi in the 1930s. The Santa Rosa Rancheria has remained a vital community that has successfully established numerous tribal programs and acquired additional lands (McCarthy, 1999).

History. Mission San Miguel Archangel was established in July 1797 as the sixteenth in the chain of 21 California Franciscan missions. The mission lay along the El Camino Real approximately 25 miles southwest of the project site, between the missions at San Luis Obispo and San Antonio and about halfway between Los Angeles and San Francisco. The missions in general produced an impressive quantity and array of agrarian goods. In 1805 alone, 19 missions held a quarter-million head of livestock, including 130,000 sheep, 95,000 cattle, 21,000 horses, 1,000 mules, 800 pigs, and 120 goats (Hackel, 1998:116). By far the most important commercial commodity was cattle. Along with livestock, the missions produced over four million bushels of wheat, corn, barley, beans, peas, lentils, and chick-peas in the period 1783– 1832 (Engelhardt, 1915:535).

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Native American labor was the essential ingredient for all economic endeavors of the missions. Engelhardt (1915:529) reports that the total population of missionized Native Americans reached its peak of 21,196 in 1821. Based on the figures compiled by Engelhardt (1915:529, 531, 535), Mission San Miguel appears to have been better suited for ranching than agriculture. Although not nearly as prodigious as the southern missions—like Mission San Luis Rey, which maintained over 55,000 head of cattle and sheep in the late 1820s and early 1830s—its capacity to raise livestock was generally higher than other missions on the Central Coast. Mission San Miguel produced 14,079 sheep in 1819 and 10,588 cattle in 1822. As with other missions, the agrarian operations of Mission San Miguel were not limited to its immediate vicinity but occurred on several farming and ranching estates located in modern southern Monterey County and northern San Luis Obispo County. Mission San Miguel lands included the proposed project site.

Secularization (i.e., the legal process whereby the Mexican government took possession of and then distributed the rich estates of the missions) figures prominently into the current historical study, as it directly led to the establishment of private property in the Cholame Valley region. In 1841, the California governor began to dispense the various estates of Mission San Miguel to soldiers and affluent individuals. Ten private ranchos were created from former San Miguel mission lands. These ranchos included Rancho Cholame, which was granted to Mauricio Gonzales in 1844 (Ohles, 1997:6, 21). The L-shaped property totaled 26,600 acres and covered most of the lower reaches of the Cholame Valley. However, the government proved wholly incapable of defending such remote holdings let alone the province itself—a failing that eventually led to Mexico’s cessation of California to the Union following the Mexican-American War. Helpless against Yokuts raids, Gonzales retreated from the Cholame Valley and did not return until the early 1850s (Ohles, 1997:240; Ryan and Breschini, 2010).

In 1851, Gonzales paid $99.00 in real and personal property taxes on the Cholame ranch, which includes the current project site, indicating that by this time he had resettled (or was intending to resettle) this property (Ohles, 1997:109). As a stipulation of the Treaty of Guadalupe Hidalgo, which ended the Mexican- American War, the United States was obligated to honor the property rights of the various Mexican land grantees, pending verification of ownership. The property remained in Gonazales’ family into the 1860s.

Contemporary land valuations indicate that the property was neither a particularly choice property nor one that was predisposed for development. San Luis Obispo County assessed real property into four classes based on accessibility and the quality of soil. The Cholame ranch was placed into the third assessment class (second lowest), which in 1855 was valued at $0.75 per acre (Angel, 1883; Ohles, 1997:22).

In 1867, stockman William Hollister purchased the Cholame Ranch and later delegated its management to his son-in-law Robert E. Jack. Jack’s son Howard stated that prior to the 1890s the high price of wool made sheep-tending a more profitable venture; in 1877, the ranch held 70,000 sheep (Thomason, 1991:155). By the twentieth century, cattle had replaced sheep as the primary stock. The Jack family owned the ranch until the 1960s.

The Imus brothers, the region’s first Anglo-American settlers, came to Cholame Valley around 1854 (Thomason, 1991:7–12). Through the 1862 Homestead Act, settlers could acquire 160 acres

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of public land for a minimal filing fee by settling and improving the property. By 1875, the region’s first post office was established at Imusdale, the site of William Imus’ homestead (Thomason, 1991:36–37). In the 1870s and early 1880s, stagecoaches brought mail and other goods from either end of the valley. By the mid 1880s, the rudiments of a community had taken root in the Cholame Valley region. The Red Rock School District was formed in 1875; shortly after, a school was built about 4 miles east of Imusdale near the future site of the township of Parkfield (Thomason, 1991:38–39). Parkfield would soon emerge as the region’s social and commercial center. Settlers constructed the Parkfield School and a meeting hall in 1882 (Thomason, 1991:21). In 1884, the Parkfield post office opened in the store of F. W. Hunter.

In 1886, the railroad first steamed into San Miguel, which is the closest it would get to the Cholame Valley. To shorten the distance between themselves and the nearest railhead, the valley’s residents collectively underwrote the construction of Vineyard Canyon Road between Parkfield and San Miguel (Ohles, 1997:146). By late 1887, Vineyard Canyon Road was completed and increased stage traffic between San Miguel and the Cholame Valley.

Without a nearby rail station, valley residents came to rely heavily on the stagecoach runs, which brought mail, goods, and news from the outside world to Imusdale and Parkfield. At the close of the century, the region was serviced by five schools, a visiting preacher and dentist, and a bimonthly newspaper, the Parkfield Sand Storm (Ohles, 1997:248; Thomason, 1991:21–23). Along with cattle and sheep, the region produced other types of livestock such as hogs and flocks of turkey. Turkey Flat, the portion of the Cholame Valley on which the project site is located, likely received its name from the presence of turkey ranchers at this locality.

A June 1887 issue of the Inland Messenger makes note of a sawmill in Cholame Valley and an increasing demand for lumber (Ohles, 1997:242). Mineral exploration in the valley began as early as September 1887, as a result of the discovery of petroleum in Little (upper) Cholame Valley (Ohles, 1997:242–243). Oil wells were commonly drilled, including one at Turkey Flat in 1902 (Thomason, 1991:140), and the 1910 Great Register lists three oil operators working in the Cholame Valley region, indicating interest in petroleum continued into the twentieth century. However, prospects never proved sufficient to seriously exploit the area’s oil reserves. Quicksilver or mercury mining enjoyed relatively better success.

During the World War I, the devastation of Europe’s agrarian base and the mass production of munitions created an unprecedented demand for food products and strategic minerals. When the war ended, the market for these commodities fell dramatically; among the worst affected were small farming families that often had to give up their land to pay off debt. However, history provides evidence that settlement in the Cholame Valley region did not evaporate after World War I. The agricultural programs of the New Deal supported commodity prices and brought general relief to the nation’s farmers. In 1934, a local chapter of the Grange opened in Parkfield (Thomason, 1991:65). In 1966, the Jack family sold Cholame Ranch to the Hearst Corporation (Ohles, 1997:240). By that time, the ranch had grown to 58,000 acres, more than double the size of the original 26,600-acre grant (Thomason, 1991:155). Today, the ranch consists of 72,000 acres over San Luis Obispo, Monterey, and Kings counties (Jack Ranch, 2014).

d. Paleontological Setting. The following setting information is drawn from the Paleontological Resources Assessment for the California Solar Flats Project, prepared by AE in April 2013. This report was peer reviewed by Rincon Consultants in July 2013, and a Revised

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Paleontological Resources Assessment for the California Solar Flats Project was prepared by AE in August 2013. The project area is located in the Coast Ranges geomorphic province. The Coast Ranges are dominated by elongate ranges and narrow valleys that parallel the coast line. They have two basement rock complexes, the Franciscan basement and the Salinian block. The Franciscan basement is composed of about 90% grayish green graywackes formed during the Mesozoic by the rapid erosion of volcanic highlands into deep marine basins. The Salinian block is composed of metamorphic rocks including gneiss, schist, quartzite, and marble of Mesozoic and Paleozoic age. The basement complexes are overlain by various units of Mesozoic and Cenozoic aged sedimentary formations consisting of marine and non-marine shales, sandstones and conglomerates.

The northern portion of the project area is located southwest of Table Mountain within the Turkey Flat area. The project area extends southeast across Cottonwood Creek and into Cholame Valley. Based on geological mapping of the project area (Jennings, 1958; Dibblee, 2005a, 2005b, 2005c) as presented in Paleontological Resources Assessment for the California Solar Flats Project, the project is underlain by three Tertiary aged formations and quaternary alluvial deposits (See Figures 4.5-1a,b, and c). The Tertiary formations include, from oldest to youngest, the Temblor Formation, the Monterey Shale and the Etchegoin Formation.

The Etchegoin Formation outcrops intermittently along the northern portion of the project area on either side of the Turkey Flat area. This formation is in age and is composed of weakly lithified light gray bedded sandstone with gray silty clay shale (Dibblee, 2005b). The Etchegoin Formation is well known for its fossil mollusks, including pelecypods and gastropods, and its echinoderms (Durham, 1950; Hanna and Grant, 1929). It also has yielded numerous vertebrate specimens of marine and terrestrial origin, including the holotype of the fossil horse Merychuppus brevidontus (McLeod, 2012).

The includes two mapped units in the project area: the late Miocene (16.0 – 11.6 Ma) McClure Member and the middle Miocene (11.6 – 5.3 Ma) Devilwater Member. This formation outcrops along the margins of portions of the project area. The Monterey Formation is well known for producing marine vertebrates, plants, and invertebrates from hundreds of localities in California. Dozens of vertebrate localities have been recorded from this unit and have yielded large sea turtles, whales, pinnipeds, sharks, sea cows, fish, birds, and many other fauna (UCMP collections data).

The early Miocene (23–16 Ma) to in age (33.9–23.0 Ma) Temblor Formation is composed of six unnamed members (Graham et al. 1989). Two members outcrop in the southern portion of the project area, and consist of early Miocene marine and terrestrial deposits. The Temblor Formation has yielded a wealth of fossil resources, including more than 700 localities in central California. Of those localities, 38 yielded hundreds of vertebrate specimens, including sea cows, gomphothere, mastodon, extinct horse, pinnipeds, fish, and sharks, among other taxa (UCMP collections data).

Quaternary alluvial deposits in the project area include Holocene age (10,000 years before present [B.P.] to recent) surficial deposits, older surficial deposits of Pleistocene age (2.6 Ma– 10,000 B.P.) and landslide rubble of Late Pleistocene and Early Holocene age. Quaternary alluvial deposits of Pleistocene age have proven to yield significant vertebrate fossils throughout California (University of California Museum of Paleontology [UCMP] collections

County of Monterey 4.5-13 California Flats Solar Project EIR Section 4.5 Cultural and Paleontological Resources

data). In addition, the Paso Robles Formation has yielded at least two vertebrate localities in Monterey and San Luis Obispo counties and is considered highly sensitive for fossil resources (UCMP collections data; Kellogg, 1921).

The paleontological sensitivity of the project area varies based on presence of geologic units at the surface (See Figures 4.5-2a, b, and c). The Etchegoin, Monterey, and Temblor Formations are all considered to have high paleontological sensitivity. Quaternary surficial deposits and landslide rubble are considered to have low paleontological sensitivity, and older surficial deposits are considered to have low to high paleontological sensitivity with sensitivity increasing with depth. The majority of the project site is mapped as Pleistocene aged older surficial deposits where sensitivity increases with depth. Smaller areas of the northern portion of the project site and within the access road corridor on the margins of Stone Corral Canyon are mapped as Monterey, Temblor, and Etchegoin Formations with high paleontological sensitivity. Figure 4.5-2a depicts the northern portion of the project area, including the majority of the proposed solar development site. Figure 4.5-2b depicts the central portion of the project area, including the southern portion of the solar development site and the northern portion of the access road. Figure 4.5-2c depicts the southern portion of the project area, which is entirely access road, more than half of which is proposed within areas of low paleontological sensitivity.

e. Inventory and Evaluation of Cultural Resources within the Project Site. This section is based in part on a Cultural Resources Inventory and Evaluation for the California Solar Flats Project prepared for the project by Applied Earthworks (AE) (April, 2013), which was peer reviewed by Rincon Consultants, Inc. A revised Cultural Resources Inventory and Evaluation was provided by AE in July 2013 (in confidential Appendix F). A Supplemental Cultural Resources Inventory and Evaluation for the California Flats Solar Project, was provided in February 2014 (in confidential Appendix F). It describes AE’s study of a utility corridor and other elements that were added as a result of design changes. This section provides the results of a records search, Native American scoping, and field study for the project. The results of this study are summarized below.

Records Search. Records searches of the California Historical Resource Information System (CHRIS) were conducted at the Northwestern Information Center (NWIC) located at Sonoma State University and at the Central Coast Information Center (CCIC) located at the University of California, Santa Barbara. Each records search revealed that no prehistoric or historic cultural resources had been previously recorded within or adjacent to the project area. They also revealed that four previous cultural resources studies had been conducted on the most southern portions of the project area.

Native American Scoping. AE contacted the Native American Heritage Commission (NAHC) to request a search of the Sacred Lands File (SLF) on April 24, 2012 to identify any known places of importance to Native Americans within or adjacent to the project area. The NAHC responded that no sacred lands or other Native American cultural resources were identified within the project area and provided a contact list of representatives for southern Monterey and northern San Luis Obispo Counties. AE prepared and mailed letters to each of the contacts on the list requesting any information related to the project area and soliciting any concerns or comments they may have. John Burch of the Salinan Tribe of Monterey and San Luis Obispo Counties expressed interest in the project. The Salinan Tribe subsequently provided Native American monitoring services for Phase 2 archaeological testing. No other Native Americans contacted had questions or concerns.

County of Monterey 4.5-14 California Flats Solar Project EIR Section 4.5 Cultural Resources

THE DARK HOLE CHOLAME VALLEY

Legend Project Area

Index Map SCALE 1:24,000 1 0.5 0 1 Miles

1,000 0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 Feet

1 0.5 0 1 Kilometers ° Geologic Maps: Dibblee 2005b and 2005c Cholame Valley and The Dark Hole, CA, 7.5' USGS Quadrangles

Figure 5-1 Project area depicted on geology map (please see geologic map index for key geologic units).

Source: Applied Earthworks, 2014 Geologic Map Figure 4.5-1a County of Monterey California Flats Solar Project EIR Section 4.5 Cultural Resources

THE DARK HOLE CHOLAME VALLEY

Legend Project Area

Index Map SCALE 1:24,000 1 0.5 0 1 Miles

1,000 0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 Feet

1 0.5 0 1 Kilometers ° Geologic Map: Dibblee 2005b Cholame Valley, CA, 7.5' USGS Quadrangles

Figure 5-2 Project area depicted on geology map (please see geologic map index for key geologic units).

Source: Applied Earthworks, 2014 Geologic Map Figure 4.5-1b County of Monterey California Flats Solar Project EIR Section 4.5 Cultural Resources

CHOLAME VALLEY CHOLAME

Legend Project Area

Index Map SCALE 1:24,000 1 0.5 0 1 Miles

1,000 0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 Feet

1 0.5 0 1 Kilometers ° Geologic Maps: Dibblee 2005a and 2005b Cholame and Cholame Valley, CA, 7.5' USGS Quadrangles

Figure 5-3 Project area depicted on geology map (please see geologic map index for key geologic units).

Source: Applied Earthworks, 2014 Geologic Map Figure 4.5-1c County of Monterey California Flats Solar Project EIR Section 4.5 Cultural Resources

THE DARK HOLE CHOLAME VALLEY

Legend High Sensitivity Low-High Sensitivity Low Sensitivity Project Boundary

Index Map SCALE 1:24,000 1 0.5 0 1 Miles

1,000 0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 Feet

1 0.5 0 1 Kilometers ° Geologic Maps: Dibblee 2005b and 2005c Cholame Valley and The Dark Hole, CA, 7.5' USGS Quadrangles

Figure 6-1 Paleontological sensitivity.

Source: Applied Earthworks, 2014 Paleontological Sensitivity Figure 4.5-2a County of Monterey California Flats Solar Project EIR Section 4.5 Cultural Resources

THE DARK HOLE CHOLAME VALLEY

Legend High Sensitivity Low-High Sensitivity Low Sensitivity Project Boundary

Index Map SCALE 1:24,000 1 0.5 0 1 Miles

1,000 0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 Feet

1 0.5 0 1 Kilometers ° Geologic Map: Dibblee 2005b Cholame Valley, CA, 7.5' USGS Quadrangles

Figure 6-2 Paleontological sensitivity.

Source: Applied Earthworks, 2014 Paleontological Sensitivity Figure 4.5-2b County of Monterey California Flats Solar Project EIR Section 4.5 Cultural Resources

CHOLAME VALLEY CHOLAME

Legend High Sensitivity Low-High Sensitivity Low Sensitivity Project Boundary

Index Map SCALE 1:24,000 1 0.5 0 1 Miles

1,000 0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 Feet

1 0.5 0 1 Kilometers ° Geologic Maps: Dibblee 2005a and 2005b Cholame and Cholame Valley, CA, 7.5' USGS Quadrangles

Figure 6-3 Paleontological sensitivity.

Source: Applied Earthworks, 2014 Paleontological Sensitivity Figure 4.5-2c County of Monterey California Flats Solar Project EIR Section 4.5 Cultural and Paleontological Resources

Field Investigation and Results. Fieldwork conducted by AE identified 82 cultural resources within the project area, including 37 isolated artifacts and 45 prehistoric or historic archaeological sites (Table 4.5-3). Thirty-one of the archaeological sites are prehistoric; most are simple scatters of flaked stone debris. Six sites are historic-era remains related to ranching and agriculture. Eight sites contain both prehistoric and historic components. The 45 sites represent various resource types that reflect different past human activities including: simple lithic scatters with a low quantity and variety of diffusely scattered material remains; complex tool and debris scatters with large and varied assemblages; simple scatters of unassociated historic debris; complex historical sites with multiple features and refuse scatters reflecting the agricultural and ranching history of the property; and combinations of these resource types. Isolates include prehistoric flakes, tools, and unassociated historic features.

None of the 37 identified isolates are considered significant resources and none are eligible for the NRHP or the CRHR because they lack important associations and scientific data potential. Phase II investigations were conducted on a representative sample of the archaeological sites to facilitate NRHP and CRHR significance evaluations of all identified archaeological sites. AE classified all archaeological sites according to artifact and feature content, structure and complexity, quantity and variety of material remains, and other physical characteristics. All sites were classified into five property types: simple lithic scatters, complex lithic scatters, simple historic-period debris scatters, historic ranching or agricultural complexes, or a combination of two of the other property types. Phase II excavations were then carried out at 11 representative sites, including three simple lithic scatters, six complex lithic scatters, one simple historic debris scatter, and three ranching or agricultural complexes. Results of Phase II investigations are provided in Table 4.5-3.

During testing, simple lithic scatters proved not to contain substantial subsurface deposits and lack chronological indicators, and generally lack the associative or scientific research values that would make them significant. For these reasons, all simple lithic scatters were judged ineligible for the NRHP or CRHR. Similarly, the simple historic-period debris scatters which cannot be associated with a particular time period, theme, event, or individual were judged insignificant and ineligible for the NRHP and CRHR. Complex lithic scatters proved to have intact subsurface deposits containing temporally and technologically diagnostic artifacts, datable organic remains, and a broad quantity and variety of artifacts and debris. In most cases, complex lithic scatters were judged eligible for the NRHP under Criterion D and CRHR under Criterion 4 based on scientific data potential. Most complex historic ranching and agricultural sites were considered insignificant based on architectural and aesthetic qualities. However, some contained domestic refuse deposits that were judged significant for their data potential. Based on these findings, the project site is located in a High Sensitivity Zone for archaeological resources (Applied Earthworks, July 2013).

Five resources identified within the utility corridor could not be evaluated because of differences between the setting and context of these sites and those on Turkey Flat. It is possible that these sites can be avoided during project development, and thus no further evaluation was undertaken. If avoidance is not feasible, resources that were not evaluated are assumed eligible for listing in the CRHR for the purposes of this EIR (AE, 2014).

County of Monterey 4.5-27 California Flats Solar Project EIR Section 4.5 Cultural and Paleontological Resources

Table 4.5-3 Summary of Archaeological and Historical Resources and Significance Evaluations

Site Designation Agea Description Phase 2 Fieldwork NRHP/CRHR Eligibility Complex lithic scatter CA-SLO-2717 P with flaked and Yes Eligible ground stone tools Complex lithic scatter CA-MNT-2302 P with flaked and Yes Not Eligibleb ground stone tools CA-MNT-2303 P Simple lithic scatter Yes Not Eligible Ranching and CA-MNT-2304H H No Not Eligible agricultural complex CA-MNT-2305H H Simple debris scatter No Not Eligible Ranching and CA-MNT-2306H H Yes Not Eligible agricultural complex Complex lithic scatter CA-MNT-2307 P with flaked and No Eligible ground stone tools Complex lithic scatter CA-MNT-2308 P with flaked and Yes Eligible ground stone tools Complex lithic scatter and raw material CA-MNT-2309 P Yes Eligible procurement and production area Simple lithic scatter CA-MNT-2310/H P with a single historic No Not Eligible artifact Simple debris scatter with historic rock piles CA-MNT-2311/H P/H No Not Eligible and chert flake tool Complex lithic scatter CA-MNT-2312 P with flaked and Yes Eligible ground stone tools CA-MNT-2313 P Simple lithic scatter No Not Eligible

CA-MNT-2314 P Simple lithic scatter No Not Eligible

CA-MNT-2315 P Simple lithic scatter No Not Eligible

CA-MNT-2316 P Simple lithic scatter No Not Eligible

CA-MNT-2317 P Simple lithic scatter No Not Eligible Agricultural homestead atop a CA-MNT-2318/H P/H complex prehistoric Yes Eligible tool and debris scatter CA-MNT-2319 P Simple lithic scatter No Not Eligible

County of Monterey 4.5-28 California Flats Solar Project EIR Section 4.5 Cultural and Paleontological Resources

Table 4.5-3 Summary of Archaeological and Historical Resources and Significance Evaluations

Site Designation Agea Description Phase 2 Fieldwork NRHP/CRHR Eligibility Agricultural complex CA-MNT-2320/H P/H atop a simple lithic No Eligible scatter Simple lithic scatter with historic rock piles CA-MNT-2321/H P/H No Eligible and agricultural debris Ranching and CA-MNT-2322H H Yes Not Eligible agricultural complex CA-MNT-2323 P Simple lithic scatter No Not Eligible

CA-MNT-2324H H Simple debris scatter No Not Eligible Historic rock piles with CA-MNT-2325/H P/H prehistoric isolated No Not Eligible artifact CA-MNT-2326 P Simple lithic scatter No Not Eligible

CA-MNT-2327 P Simple lithic scatter No Not Eligible Complex lithic scatter CA-MNT-2328 P with flaked and No Eligible ground stone tools CA-MNT-2329 P Simple lithic scatter No Not Eligible Complex lithic scatter with flaked stone tools CA-MNT-2330 P No Eligible and fire-altered rock CA-MNT-2331 P Simple lithic scatter No Not Eligible

CA-MNT-2332 P Simple lithic scatter No Not Eligible

CA-MNT-2333 P Simple lithic scatter No Not Eligible Simple lithic scatter CA-MNT-2334 P/H Yes Not Eligible with historic debris CA-MNT-2335 P Simple lithic scatter Yes Not Eligible Ranching and CA-MNT-2336H H No Eligible agricultural complex CA-MNT-2359 P Complex lithic scatter No Eligible Complex lithic scatter CA-MNT-2360/H P/H No Eligible with historic debris CA-MNT-2361 P Complex lithic scatter No Eligible

CA-MNT-2362 P Complex lithic scatter No Eligible

CA-MNT-2363 P Lithic scatter No Eligiblec

CA-MNT-2364 P Lithic scatter No Eligiblec

County of Monterey 4.5-29 California Flats Solar Project EIR Section 4.5 Cultural and Paleontological Resources

Table 4.5-3 Summary of Archaeological and Historical Resources and Significance Evaluations

Site Designation Agea Description Phase 2 Fieldwork NRHP/CRHR Eligibility

Lithic scatter with c CA-MNT-2365/H P/H No Eligible historic debris CA-MNT-2366 P Lithic scatter No Eligiblec

CA-MNT-2367 P Lithic scatter No Eligiblec Sources: AE. Cultural Resources Inventory and Evaluation for the California Flats Solar Project. July 2013, and Supplemental Cultural Resource Inventory and Evaluation for the California Flats Solar Project, February 2014. California Historical Resources Information System – Northwest Information Center. Primary Number and/or Trinomial Assignment for the California Flats Solar Project. E-mail correspondence. April 9, 2014. aP=prehistoric, H=historic, and P/H=both prehistoric and historic components bThis evaluation applies only to that portion of CA-MNT-2302 within the current proposed disturbance area. cThese sites are assumed to be eligible for listing in the NRHP/CRHR for the purposes this EIR.

f. Regulatory Setting.

Federal. The following federal laws and regulations are presented because the project may require federal permitting or licensing.

National Register of Historic Places. Federal regulations for cultural resources are primarily governed by Section 106 of the National Historic Preservation Act (NHPA) of 1966, as amended, which applies to actions taken by federal agencies. The goal of the Section 106 review process is to offer a measure of protection to sites that are determined eligible for listing on the National Register of Historic Places (National Register or NRHP). The criteria for determining NRHP eligibility are found in Title 36 Code of Federal Regulations (CFR) Part 60. Section 106 of the NHPA requires federal agencies to take into account the effects of their undertakings on historic properties and affords the federal Advisory Council on Historic Preservation a reasonable opportunity to comment on such undertakings. The Council’s implementing regulations, “Protection of Historic Properties,” are found in Title 36 CFR Part 800.

The NRHP is the official list of the Nation's historic places worthy of preservation. Authorized under the NHPA, it is part of a national program to coordinate and support public and private efforts to identify, evaluate, and protect the country’s historic and archaeological resources. The National Register is administered by the National Park Service under the Secretary of the Interior. Properties listed in the National Register include districts, sites, buildings, structures, and objects that are significant in American history, architecture, archaeology, engineering, and culture. Property owners must agree to such listing. The National Register includes:

 All historic areas in the National Park System;  National Historic Landmarks that have been designated by the Secretary of the Interior for their significance to all Americans; and  Properties significant to the nation, state, or community which have been nominated by state historic preservation offices, federal agencies, and tribal preservation offices, and have been approved by the National Park Service (National Park Service, 2014a).

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To be considered eligible, a property must meet the National Register Criteria for Evaluation, found in Title 36 CFR Part 60.4. This involves examining the property’s age, integrity, and significance as follows:

 Age and Integrity. Is the property old enough to be considered historic (generally at least 50 years old) and does it still look much the way it did in the past?  Significance. Is the property associated with events, activities, or developments that were important in the past? With the lives of people who were important in the past? With significant architectural history, landscape history, or engineering achievements? Does it have the potential to yield information through archaeological investigation about our past?

Archaeological site evaluation assesses the potential of each site to meet one or more of the criteria for NRHP eligibility based on visual surface and subsurface evidence (if available) at each site’s location, information gathered during the literature and records searches, and the researcher’s knowledge of and familiarity with the historic or prehistoric context associated with each site.

American Indian Religious Freedom Act. The American Indian Religious Freedom Act, Title 42 U.S. Code Section 1996, protects Native American religious practices, ethnic heritage sites, and land uses.

National Historic Landmarks. National Historic Landmarks are nationally significant historic places designated by the Secretary of the Interior because they possess exceptional value or quality in illustrating or interpreting the heritage of the United States. Today, fewer than 2,500 historic places bear this national distinction. National Historic Landmarks are places where nationally significant historic events occurred, that are associated with prominent Americans that represent those pivotal ideas that shaped the nation, that teach Americans about their ancient past, or that are premier examples of design or construction. While many historic places are important locally or at a state level, a lesser number have meaning for all Americans. National Historic Landmarks are places that “possess exceptional value or quality in illustrating and interpreting the heritage of the United States” (National Park Service, 2014b).

Paleontological Resources Regulations. Paleontological resources are afforded protection under numerous federal laws and regulations, including the National Environmental Policy Act of 1969, the Antiquities Act of 1906, the Federal Land Policy and Management Act of 1976, Title 43 of the Code of Federal Regulations, and the Paleontological Resources Preservation Act (PRPA). The PRPA was recently enacted as a result of the passage of the Omnibus Public Lands Management Act of 2009 and requires federal land management agencies to manage and protect paleontological resources, affirming the authority of existing policies already in place.

State.

California Register of Historical Resources. According to Section 15064.5(a)(3)(A-D) in the State CEQA Guidelines, a resource is considered historically significant under three circumstances: (1) if it is CRHR-listed or determined to be eligible for such listing by the State Historical Resources Commission; (2) if it is included in a local register of historical resources (though this is a presumption that may be rebutted where the agency can prove by a

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preponderance of the evidence that it is not historically or culturally significant); or (3) if it meets at least one of the following criteria for listing on the CRHR:

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; or 4. Has yielded, or may be likely to yield, information important in prehistory or history.

When a project would impact an archaeological site, the lead agency must determine whether the site represents a historical resource as defined in Section 15064.5 (a)(3)(A-D), described above. If it the site qualifies as a historical resource, then it is entitled to protection under CEQA. If the site does not meet the requirements of a historical resource, the agency must then determine whether the site is a “unique archaeological resource.” Section 21083.2 of the Public Resources Code defines a “unique archaeological resource” to mean “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:

1. Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information. 2. Has a special and particular quality such as being the oldest of its type or the best example available of its type. 3. Is directly associated with a scientifically recognized important prehistoric or historic event or person.

Should a site qualify as a “unique archaeological resource,” it is protected under CEQA. If the agency determines the site does not qualify, then the site merits no further consideration.

Historical resources are “significantly” affected if there is demolition, destruction, relocation, or alteration of the resource or its surroundings. Preservation in place is the preferred form of mitigation for a “historical resource of an archaeological nature” as it retains the relationship between artifact and context, and may avoid conflicts with groups associated with the site [PRC 15126.4 (b)(3)(A)]. Impacts to historical resources of an archaeological nature and “unique archaeological resources” can be mitigated to below a level of significance by:

1. Relocating construction areas such that the site is avoided; 2. Incorporation of sites within parks, greenspace, or other open space; 3. “Capping” or covering the site with a layer of chemically stable soil before building; or 4. Deeding the site into a permanent conservation easement. [PRC 15126.4 (b)(3)(B)]

In the event that resources cannot be preserved, “unique archaeological resources” can only be excavated as mitigation if they are threatened with damage or destruction by the proposed project. The time and cost limitations that may apply to the excavation of archaeological resources do not apply to activities that determine whether the archaeological resources are “unique” [PRC 15064.5 (c)(3)].

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If an archaeological resource does not meet either the historical resource or the more specific “unique archaeological resource” definition, impacts do not need to be mitigated [13 PRC 15064.5 (e)]. Where the significance of a site is unknown, it is presumed to be significant for the purpose of the EIR investigation.

Native American Consultation. Prior to the adoption or amendment of a general plan proposed on or after March 1, 2005, Government Code Sections 65352.3 and 65352.4 require a city or county to consult with local Native American tribes that are on the contact list maintained by the Native American Heritage Commission. The purpose is to preserve or mitigate impacts to places, features, and objects described in Public Resources Code Sections 5097.9 and 5097.993 (Native American sanctified cemetery, place of worship, religious or ceremonial site, or sacred shrine located on public property) that are located within a city or county’s jurisdiction. As the proposed project does not entail a General Plan amendment, no such consultation is required; however, AE conducted Native American scoping as part of the process of identifying cultural resources important to Native Americans.

Human Remains. Section 7050.5 of the California Health and Safety Code states that in the event of discovery or recognition of any human remains in any location other than a dedicated cemetery, there shall be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains until the coroner of the county in which the remains are discovered has determined whether or not the remains are subject to the coroner’s authority. If the human remains are of Native American origin, the coroner must notify the Native American Heritage Commission within 24 hours of this identification. The Native American Heritage Commission will identify a Native American Most Likely Descendant (MLD) to inspect the site and provide recommendations for the proper treatment of the remains and associated grave goods. State CEQA Guidelines Section 15064.5 directs the lead agency (or Applicant), under certain circumstances, to develop an agreement with the Native Americans for the treatment and disposition of the remains.

Public Resources Code Section 5097.5. California Public Resources Code Section 5097.5 prohibits excavation or removal of any “vertebrate paleontological site…or any other archaeological, paleontological or historical feature, situated on public lands, except with express permission of the public agency having jurisdiction over such lands.” Public lands are defined to include lands owned by or under the jurisdiction of the state or any city, county, district, authority or public corporation, or any agency thereof. Section 5097.5 states that any unauthorized disturbance or removal of archaeological, historical, or paleontological materials or sites located on public lands is a misdemeanor.

Local.

Monterey County General Plan. The Conservation and Open Space Element of the Monterey County General Plan includes specific policies and procedures to identify and protect archaeological, paleontological, and historical resources. The policies encourage avoidance of impacts to significant resources, protection of Native American cemeteries, and preservation of shrines and sacred places to the greatest extent feasible. Where avoidance and preservation in place are not feasible, Phase 2 and Phase 3 archaeological studies shall be carried out, as appropriate, and the requirements of CEQA and other state laws will apply. The objectives and

County of Monterey 4.5-33 California Flats Solar Project EIR Section 4.5 Cultural and Paleontological Resources

policies applicable to this project are discussed in greater detail in Section 4.10, Land Use and Planning.

Monterey County Code of Ordinances. The Monterey County Zoning Ordinance (Title 21 of the Monterey County Code) provides development standards which help to ensure the protection and appropriate treatment of archaeological sites. Title 21.66.050 requires that an Archaeological Survey Report be prepared for any development project located in a “High Archaeological Sensitivity Zone,” as well as environmental review. Development on parcels containing archaeological resources shall be designed to avoid such resources where feasible; where impacts cannot be avoided, a mitigation plan shall be required for the project.

San Luis Obispo County General Plan. The southern portion of the four-mile existing private ranch road, which provides access to the project site, is in San Luis Obispo County. The Conservation and Open Space Element of San Luis Obispo County’s General Plan establishes goals and policies “to identify and protect areas, sites, and buildings having architectural, historical, Native American, or cultural significance.” Among other things, these goals and policies require archaeological, historical, and paleontological surveys, and avoidance of impacts to significant resources whenever feasible. Native American tribal representatives are to be consulted in all phases of cultural resource investigation and should be present during archaeological excavation and construction in areas likely to contain archaeological sites.

San Luis Obispo County Code of Ordinances. Section 19.02.70 of the County Code lists policies for the protection of archaeological resources and human remains, in the event that such discoveries are made during project construction. These policies require construction activities to halt until the discovery has been recorded by a qualified archaeologist and if the discovery includes human remains the County coroner is to be notified.

4.5.3 Impact Analysis

a. Methodology and Significance Thresholds. This evaluation is based in part on the findings contained in Cultural Resources Inventory and Evaluation for the California Flats Solar Project, (AE, April 2013) and Paleontological Resource Assessment for the California Flats Solar Project, (AE, April 2013) prepared for the proposed project. Both reports were reviewed by Rincon Consultants, Inc. and were revised in July 2013 and August 2013, respectively, based on comments supplied at that time. This evaluation is also based on the findings in Supplemental Cultural Resources Inventory for the California Flats Solar Project, Monterey and San Luis Obispo Counties, California (AE, February 2014).

Following completion of the field survey, AE carried out Phase 2 test excavation at 11 sites representing all archaeological property types. The Phase 2 investigations were conducted to facilitate NRHP and CRHR significance evaluations of all identified sites. While the important scientific research potential and possible historical associations of many sites were obvious based on their surface characteristics, subsurface testing was carried out to confirm predictions regarding the content and structure of each property type, the potential for preserved subsurface deposits, and to gather additional information useful for developing mitigation measures for sites judged to be significant. The potential for paleontological resources to occur

County of Monterey 4.5-34 California Flats Solar Project EIR Section 4.5 Cultural and Paleontological Resources

on the project site was assessed by conducting a literature review of available documentation, museum records search results, and a field survey of the project site.

Decommissioning. As stated in Section 2, Project Description, at the end of the project’s useful life (anticipated to be 30 years or more), the proposed solar facility and associated infrastructure may be decommissioned in accordance with then-current decommissioning practices. At this time it is not possible to evaluate potential impacts to cultural resources that would result from project decommissioning, due to the uncertainty of when decommissioning would occur, or the technology or construction practices that would be available at that time. However, it is reasonably assumed that cultural resources that required avoidance measures during construction would require the same avoidance measures during decommissioning. For example, a significant archaeological site that was temporarily fenced off and monitored during construction to avoid inadvertent impact should be fenced off and monitored during decommissioning, too. Therefore, based on current decommissioning practices, as a reasonable- worst case, this analysis assumes that impacts to cultural resources generated during future decommissioning would be possible, though considerably less likely than during the construction phase of the proposed project.

In accordance with Appendix G of the CEQA Guidelines, a significant impact could occur if the proposed project would result in any of the following:

1. Cause a substantial adverse change in the significance of an historical resource as defined in Section 15064.5; 2. Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5; 3. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature of paleontological or cultural value; 4. Disturb any human remains, including those interred outside of formal cemeteries

The proposed project would not disturb unique architectural features or the character of surrounding buildings.

b. Project Impacts and Mitigation Measures.

Impact CR-1 Construction and decommissioning of the proposed project would involve surface excavation, which has the potential to unearth or adversely impact identified NRHP/CRHR-eligible prehistoric or historic archaeological resources. Impacts would be Class II, significant but mitigable. [Threshold 1]

The proposed project would involve grading to accommodate the installation of certain project improvements including: widening of existing access road; widening of existing internal roadways; construction of new internal roadways; leveling some areas for module placement; leveling for the O&M building; and potential roadway crossings over drainage features. According to the applicant’s preliminary grading plan, grading would include approximately 880,000 cubic yards (CY) of cut and 880,000 CY of fill, and would be balanced on-site. Grading would disturb large areas where the upper soil surface would be loosened and removed, potentially impacting cultural resources.

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At the end of the project’s life (anticipated to be 30 to 40 years), it may be repowered, but would most likely be decommissioned. Decommissioning activities would include removing the solar arrays and related infrastructure. Some minor grading may be required to remove solar infrastructure, and address any erosion or alteration of the topography that occurs during the removal of the facilities. Dismantling of project components may require the use of heavy equipment including and may also involve temporary land clearing and material removal, laydown area reconstruction and removal, temporary storage areas, and temporary modifications to the access road. These activities would likely occur within the same footprint as project construction.

Construction and decommissioning activities associated with the proposed project could affect prehistoric archaeological resources, as well as historic sites within the project disturbance area. As discussed in Section 4.5.2(d) (Project Site Setting), the field survey of the proposed project site recorded 45 prehistoric and historic sites, as well as 36 isolated artifacts and features (AE, February 2014). The significance of and potential impacts to the prehistoric and historic sites, as well as to the isolated artifacts and unassociated historic features, are described below.

Isolated Artifacts and Features. According to the Cultural Resources Inventory and Evaluation for the California Flats Solar Project, none of the 36 isolates are unique, unusual, rare, or otherwise exceptional, and thus they are considered insignificant resources a priori under NRHP and CRHR criteria because they lack important associations and scientific data potentials. None of the isolates are considered eligible for the NRHP or CRHR due to a lack of important associations and scientific data potential (AE, February 2014). Therefore, potential impacts to these resources would be less than significant.

Prehistoric and Historic Archaeological Resources. As previously mentioned in Section 4.5.2(e), 45 prehistoric and historic resources were recorded during the field survey of the project area. Of these, 31 are prehistoric archaeological sites, six are historic period resources, and eight sites contain both prehistoric and historic components (AE, July 2013). Table 4.5-3 lists and describes the 45 resources, indicates whether or not the site was tested during Phase 2 fieldwork, and whether or not the site is eligible for either NRHP or CRHR listing. Sites that were not evaluated are assumed eligible for the purposes of this EIR.

AE concluded that 14 archaeological and historical sites in the project disturbance area are eligible for either NRHP or CRHR listing. Construction and decommissioning activities involving ground disturbance have the potential to damage these resources. Therefore, impacts would be potentially significant and mitigation is required.

Mitigation Measures. The following mitigation measures are required to reduce impacts to known historic and archaeological resources.

CR-1(a) Archaeological Site Avoidance. Wherever feasible, direct impacts on NRHP/CRHR-eligible archaeological sites shall be avoided. Avoidance shall be accomplished by preventing any direct ground disturbance of the resource. If avoidance of any direct disturbance is determined feasible by RMA – Planning based on the sensitivity of the resource relative to the severity of impact, the boundaries of

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the NRHP/CRHR-eligible sites shall be marked in the field by a Registered Professional Archaeologist prior to ground disturbance with exclusionary fencing, lath, flagging tape, or some other combination of material that is highly visible, durable, and which construction and management personnel can recognize as marking an exclusion zone where no earth disturbance or other activity shall occur. Exclusion zones shall be inspected weekly by an archaeological monitor or other environmental inspector to ensure that they are being honored, remain effective, and in place. If complete avoidance is not feasible, Mitigation Measures CR-1(b) or CR-1(c) shall apply.

CR-1(b) Site Capping and Data Indexing. If direct disturbance of NRHP/CRHR-eligible archaeological or historic resources cannot be avoided, placement of chemically neutral, culturally sterile, nonreactive fill on top of the sites, rather than cutting into the cultural deposits, shall be required, when determined feasible by the Monterey County RMA – Planning Department. Because sites on which fill would be placed would no longer be accessible to research, a data indexing program shall be implemented to characterize the nature of the portions of the site to be buried (if they have not been sampled previously). The indexing program shall include mapping the location of surface artifacts within the proposed areas of fill; surface collection of those artifacts; and excavation of a small sample, determined by a Registered Professional Archaeologist, of the cultural deposit to characterize the nature of the buried deposit. All earth disturbances associated with placement of the fill shall also be monitored by a qualified archaeological monitor under the direction of a Registered Professional Archaeologist, as well as a tribal consultant if the site is of Native American origin, to prevent any residual impact associated with the loss of research data. Cultural materials recovered during the data indexing program shall be curated at an appropriate archaeological curation facility and copies of all reports shall be provided to the Northwest Information Center at Sonoma State University. The reports shall include detailed geospatial data regarding the locations of capped sites and these data shall be used to avoid new impacts during decommissioning.

CR-1(c) Data Recovery Excavation. If avoidance [CR-1(a)] or capping [CR- 1(b)] of NRHP/CRHR-eligible cultural resources is not possible, the project applicant shall complete a Phase III data recovery excavation program for significant cultural resources that would be impacted prior to project disturbance. Phase III data recovery shall be directed by a Registered Professional Archaeologist and include the preparation of a work plan/research design, fieldwork, laboratory analysis of recovered artifacts and ecofacts,

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special studies if appropriate, the preparation of a technical report, and curation of recovered materials. The Research Design shall be reviewed and approved by the Monterey County RMA – Planning Department prior to its implementation. A tribal consultant shall be present for all data recovery excavations of sites of Native American origin.

CR-1(d) Archaeological Resource Worker Environmental Awareness Program. Prior to the commencement of construction activities, a Registered Professional Archaeologist or a monitor under their direction shall provide a Worker Environmental Awareness Program (WEAP) for the general contractor, subcontractor(s), and all construction workers participating in earth disturbing activities. The WEAP training shall describe the potential of exposing archaeological resources, the types of cultural materials that may be encountered, and directions on the steps that shall be taken if such a find is encountered. This training may be presented alongside other environmental training programs required prior to construction. A WEAP acknowledgment form must be signed by all workers who receive the training.

CR-1(e) Archaeological Resource Construction Monitoring. A qualified archaeologist shall be retained by the Applicant to be present during all earth moving activities that have the potential to affect archaeological or historical sites. In the event that previously unidentified prehistoric or historic archaeological materials or human remains are encountered during project construction, Mitigation Measure CR-2 shall take effect. A monitoring report shall be submitted to RMA County Planning upon completion of construction.

CR-1(f) Native American Construction Monitoring. A tribal consultant (Native American monitor) shall be retained by the Applicant to be present during all earth moving activities that have the potential to affect prehistoric archaeological sites. The Native American monitor shall prepare daily logs and submit weekly updates to RMA – Planning.

Significance After Mitigation. Implementation of Mitigation Measures CR-1(a) through CR-1(f) would reduce impacts to historic and archaeological cultural resources to a less than significant level.

Impact CR-2 Construction and decommissioning of the proposed project would involve surface excavation, which has the potential to unearth or adversely impact previously unidentified cultural resources. Impacts would be Class II, significant but mitigable. [Threshold 2]

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As the site has historically been used for cattle grazing rather than development or agriculture, the project disturbance area has not experienced substantial previous ground disturbance as a result of construction activities. In addition, the project site has not been subject to a prior prehistoric and archaeological cultural resources survey. Construction of the proposed project may therefore result in potentially significant impacts to as yet undiscovered prehistoric or archaeological cultural resources. This is a potentially significant impact.

Mitigation Measures. The following mitigation measure is required.

CR-2 Previously Unidentified Archaeological Resources. If previously unidentified prehistoric or historic archaeological resources are encountered during construction or land modification activities, work within the immediate vicinity of the find shall stop and the Applicant and the Monterey County RMA – Planning Department and project archaeologist shall be notified immediately. The project archaeologist, at the Applicant’s expense, will assess the content, age, association, and integrity of the find and the Applicant shall provide the Monterey County RMA – Planning Department with sufficient information to determine whether the resource is a CRHR-eligible resource. If the Monterey County RMA – Planning Department determines that the resource is not CRHR eligible or that it is CRHR eligible, but that additional data recovery would only yield redundant information, no additional mitigation will be required and construction can proceed. If the Monterey County RMA – Planning Department determines that the resource is CRHR eligible and that the discovery has significant historical associations or could yield additional scientific information about local or regional history or prehistory that has not been recovered during prior investigations, the Applicant shall implement MM- CR-1(a)-(c) and if of Native American origin CR-1(e).

If the site is determined insignificant, no further mitigation shall be required. However, archaeological and Native American monitoring may still be required in the vicinity of the site in accordance with mitigation measures CR-1(e) and CR-1(f).

Significance After Mitigation. Implementation of Mitigation Measure CR-2 would reduce impacts to previously undiscovered cultural resources to a less than significant level.

Impact CR-3 Construction and decommissioning of the proposed project would involve surface excavation, which has the potential to unearth or adversely impact previously unidentified human remains. Impacts would be Class III, less than significant. [Threshold 4]

No cemeteries are known to occur within or adjacent to the proposed project area and no evidence of a cemetery or burial areas was identified within or adjacent to the proposed project area during the data research and fieldwork performed by AE for the Cultural Resources

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Inventory and Evaluation: California Flats Solar Project (July 2013). Thus, discovery of buried human remains is not likely to occur with construction or decommissioning of the proposed project. Nonetheless, excavation and soil removal of any kind, irrespective of depth, would have the potential to encounter human remains. While unlikely, ground disturbing construction activities, such as excavation, trenching, and grading, have the potential to uncover human remains.

California Health and Safety Code Section 7050.5 requires that:

“in the event of discovery or recognition of any human remains in any location other than a dedicated cemetery, there shall be no further excavation or disturbance of the site, or any nearby area reasonably suspected to overlay adjacent remains, until the County Coroner has examined the remains. If the Coroner determines the remains to be those of a Native American, or has reason to believe that they are those of a Native American, the Coroner shall contact by telephone within 24 hours the NAHC. In addition, any person who mutilates or disinters, wantonly disturbs, or willfully removes any human remains in or from any location other than a dedicated cemetery without authority of law is guilty of a misdemeanor.”

Compliance with these existing requirements would reduce impacts to a less than significant level.

Mitigation Measures. No mitigation measures are required.

Significance After Mitigation. Impacts would be less than significant without mitigation.

Impact CR-4 Construction of the proposed project would involve surface excavation. Although unlikely, these activities have the potential to unearth or impact previously unidentified paleontological resources. Impacts would be Class II, significant but mitigable. [Threshold 3]

The proposed project is underlain by three Tertiary aged formations and quaternary alluvial deposits. The Tertiary formations include, from oldest to youngest, the Temblor Formation, the Monterey Shale and the Etchegoin Formation. Museum records identified no previously recorded paleontological resources within the project boundaries. However, at least 33 previously documented fossil localities have been recorded within the same geologic units underlying the project area in Monterey and San Luis Obispo counties. Much of the project area is underlain either at the surface or at depth by geologic units with a documented record of yielding scientifically significant paleontological resources (refer to Figures 4.5-1a, 4.5-1b, and 4.5-1c). Most of the project site is mapped as Pleistocene aged Quaternary older surficial deposits, and is considered to have a paleontological sensitivity that ranges from low to high, with sensitivity increasing with depth. Smaller areas of the northern part of the project site and within the access road corridor on the margins of Stone Corral Canyon are mapped as Monterey, Temblor, and Etchegoin Formations with high paleontological sensitivity. Excavations and grading that extends beyond the depth of surface soils (typically 3 to 5 feet) have a high likelihood of disturbing geologic units with high paleontological sensitivity, and therefore there is a potential to disturb scientifically significant paleontological resources. As a

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result, project construction activities, including ground clearing, grading and excavation, could have adverse impacts on previously unidentified paleontological resources.

Mitigation Measures. The following mitigation measures are required to reduce impacts to unidentified paleontological resources.

CR-4(a) Paleontological Resource Mitigation Plan. Prior to grading activities, a Paleontological Resource Mitigation Plan (PRMP) shall be prepared for the project by a qualified professional paleontologist as defined by the Society of Vertebrate Paleontology (SVP, 2010). The PRMP shall include a map identifying the locations where monitoring is required, provide protocols for construction monitoring and the recovery of significant fossils, identify the Project Paleontologist and on-site monitors, and make provisions for fossil preparation, curation, and reporting. The PRMP shall be reviewed and approved by the Monterey County RMA- Planning Department prior to its implementation.

CR-4(b) Paleontological Resource Construction Monitoring. Full-time monitoring shall be required during ground disturbing activities in areas determined to have a high paleontological sensitivity. All work shall be conducted by a qualified paleontological monitor as defined by the SVP (2010) and in conformance with the PRMP (Mitigation Measure CR-4a). Monitoring efforts can be reduced or eliminated at the discretion of the Project Paleontologist if, after 50 % of the excavations are completed, no fossil resources are encountered. If deemed appropriate by the Project Paleontologist, part-time monitoring or spot checking may occur during the construction of the project in areas underlain by Quaternary surficial alluvial sediments to determine if underlying sensitive geologic units are being impacted by construction and at what depth.

If significant fossils are unearthed during construction, paleontological recovery shall be carried out. Recovery shall include: salvage of significant fossils; washing of representative samples of sediments that are likely to contain the remains of small fossil invertebrates and vertebrates; preparation of recovered specimens to a point of identification to the lowest taxonomic level and permanent preservation; identification, curation, and accession of specimens into a museum repository with permanent retrievable storage; preparation of a report of findings by the Project Paleontologist with an appended itemized inventory of specimens. The report, inventory, and record of accession shall be submitted to Monterey County, RMA-Planning, and the curation facility, and its submission shall signify

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completion of the program to mitigate impacts to paleontological resources.

Significance After Mitigation. Implementation of Mitigation Measures CR-4(a) and CR- 4(b) would reduce impacts to previously undiscovered paleontological resources to a less than significant level.

c. Cumulative Impacts. A description of the cumulative analysis methodology and development scenario, including proposed development in the South County Planning Area and the surrounding counties, and other solar projects that would affect similar resources, is included in Section 5.0, Cumulative Scenario and Methodology, of this EIR.

Geographic Extent. The geographic scope for considering cumulative impacts to cultural resources is based on the historic, ethnographic, and prehistoric period use patterns of the project site and surrounding region. The geographic extent of cumulative impacts for the historic period is the Cholame Valley. For the ethnographic period, the geographic extent includes the entire traditional Salinan territory, primarily within Monterey and northern San Luis Obispo counties. The geographic context for the prehistoric period includes southeastern Monterey County and nearby portions of adjacent counties, as this portion of the interior South Coast Ranges has had relatively little archaeological study, compared to the Central Coast and lower San Joaquin Valley.

Cumulative Impact Analysis. Cumulative projects evaluated as part of this section include projects listed in Section 5.0, Cumulative Scenario and Methodology, within this EIR. The proposed project, in conjunction with other cumulative projects in the South County Planning Area of Monterey County, as well as northern San Luis Obispo County in the vicinity of the communities of Cholame and Shandon, and western Kings and Fresno counties (west of Interstate 5), would have the potential to adversely impact additional historic and prehistoric cultural resources. However, as noted previously, implementation of project mitigation measures will reduce these impacts to less than significant. The proposed California Flats Solar Project would not contribute to any significant cumulative impacts, and cumulative construction impacts related to known and unknown prehistoric and archaeological cultural resources would be similar to that which is described for project-specific impacts and would be addressed on a project-by-project basis. Due to existing laws and regulations in place to protect historical and cultural resources and prevent significant impact to paleontological resources, the potential incremental effects of the proposed project would not be cumulatively considerable.

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