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4.4 Cultural Resources
4.4.1 Introduction
This section describes the environmental and regulatory setting for cultural resources and tribal
cultural resources. It also describes impacts associated with cultural resources and tribal cultural
resources that would result from implementation of the proposed project and mitigation for
significant impacts where feasible and appropriate.
4.4.2 Environmental Setting
4.4.2.1 Prehistoric Context
Summaries of the cultural chronologies of the Bay Area have divided the prehistoric cultural
sequence into multiple phases or periods, which are delineated by changes in regional patterns of
land use, subsistence, and tool types over time. The most recent chronologies encompass a time
period that ranges from around 13,500 calibrated years before present (cal BP) to around 170 cal
BP. The early periods of this section’s chronology are based on research from along the California
coast,1,2 while the later periods of this chronology are based on time periods that were recently
proposed by Groza et al.,3 with additional information integrated from the other chronologies
mentioned above. The sequence incudes four periods. Importantly, these periods are academic
constructs and do not necessarily reflect Native American viewpoints.
This summary presents the prehistory of the Bay Area by the geologic time segment.
Terminal Pleistocene (13,500–11,600 cal BP)
Traditionally, it was thought that the earliest human inhabitants of North America were highly mobile
terrestrial hunters. Commonly referred to as the Clovis, these people used intricate bone and stone
technology. On the western coast of North America, Clovis assemblages are characterized by a wide
but sparse distribution of isolated tools and caches, which have been dated to between 12,800 and
12,500 cal BP. However, over the last few decades, along the western coasts of North and South
America, several archaeological sites and sets of human remains have been documented in island and
mainland coastal contexts that date to the same period as the Clovis. These discoveries have forced
researchers to reconsider how early humans migrated to the Americas and their land use strategies,
with a greater emphasis placed on coastal environments.
Early Holocene (11,600–7700 cal BP)
The Early Holocene landscape of Central California is characterized by semi-mobile hunter-gatherers
who exploited a wide range of food resources from marine, lacustrine, and terrestrial contexts.
1 Rick, T.C., J.M. Erlandson, R.L., Vellanoweth. 2001. Paleocoastal Marine Fishing on the Pacific Coast of the
Americas: Perspectives from Daisy Cave, California. In American Antiquity 66(4). Pp. 595-613.
2 Erlandson, Rick, T.C., Jones, T., Porcasi, J.F. One if by Land, Two if by Sea: Who Were the First Californians? In
California Prehistory: Colonization, Culture, and Complexity. Pp. 53-62. AltaMira Press. Lanham, Maryland
3 Groza, R.G., J. Rosenthal, J. Southon, R. Milliken. 2011. A Refined Shell Bead Chronology for Late Holocene Central
California. Journal of California and Great Basin Anthropology 31(2). Pp. 135-154.
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Middle Holocene (7700–3800 cal BP)
The Middle Holocene is characterized by a diverse range of habitation sites and artifact assemblages,
which suggest higher population levels, more complex adaptive strategies, and longer seasonal
occupations than those of the Early Holocene. The presence of seasonal waterfowl within assemblages
dated to the Middle Holocene suggests more diverse, local niche-based exploitation strategies.
Late Holocene (3800–170 cal BP)
There are more than 200 documented Late Holocene sites in the Bay Area. The beginning of the Late
Holocene is marked by the establishment of a number of large shell mounds. Sites of this type are
present within 0.25 miles of the project area.
Middle Period of the Late Holocene (2050–900 cal BP)
The Middle Period of the Late Holocene is characterized by greater settlement permanence (either
sedentary or multi-season occupation), mound building, and social complexity and ritual
elaboration.
Late Period of the Late Holocene (700–170 cal BP)
The Late Period of the Late Holocene is the best-documented Late Holocene division in the greater Bay
Area. Small seed exploitation increased, as evidenced by archaeobotanical remains, and sea otters,
rabbits, deer, clams, and horn snails were frequently exploited as foodstuffs. The bow and arrow first
appeared during the Late Period, and extensive trade relations with neighboring groups continued.
4.4.2.2 Historic Context
Spanish colonization of what is now California began in the late 1700s. It was based around a system
of missions that intended to convert the native peoples to Catholicism, gain control of the native
population, and create economically self-sufficient colonial communities. When Mexico won its
independence from Spain in 1824, one of the first acts of the new government was to secularize the
missions and redistribute the mission land holdings in the form of land grants to individuals who
promised to work the land, primarily by raising cattle.4
In 1848, the United States won the Mexican-American War and, as a result, gained approximately 50
percent of Mexico’s territory, including what would become the state of California. Within weeks of
the end of the war, gold was discovered in the Sierra Nevada foothills, and by the summer of 1849,
thousands of people were arriving in California in search of their fortunes.
After most of the Mexican land grants were judged invalid, the land was subject to sale, opening
large areas to new ownership and initiating a shift to farming to supply the growing demand for
fresh food. In the South Bay, a combination of wheat and barley production, dairy farms, and
orchards dominated the valley floor from the 1860s until the late 1870s.
By the 1890s, orchard production was the dominant agricultural activity in the valley; it remained in
that position through the 1940s. In the late nineteenth century, Leland Stanford, Sr., established the
Palo Alto Stock Farm on his 8,650 acres of land along San Francisquito Creek. In 1891, he founded
4 Rawls, J.J. and W. Bean. 2003. California: An Interpretive History. McGraw Hill. Boston, Massachusetts.
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Stanford University on this land. The population in the region grew substantially during the early
twentieth century. Palo Alto expanded significantly, eventually incorporating Mayfield and Stanford
University by the early part of World War II.5 Following World War II, the growth of light industry and
high-tech R&D, coupled with expanding suburbanization, gradually eroded the valley’s orchards.
4.4.2.3 Ethnographic Context
The project site is on the cusp of what was traditionally the Lamchin territory, north of the border
of the Puichon territory.6 Both the Lamchin and the Puichon spoke the Ramaytush dialect of
Costanoan. The Costanoan languages are part of the larger Utian language family, which is part of
a larger language family, the Penutian language, with languages and dialects spoken by groups of
Native Americans across California, Oregon, and Washington.7 The territory of the Ohlone people,
who were referred to as the Costanoans by the Spanish because they lived along the coast,
extended from the Golden Gate to just below Carmel as well as through several valleys that led
inland from the coastline.8
As with other Ohlone tribelets, the Lamchin and Puichon were primarily hunters and gatherers.
They hunted terrestrial game such as mule deer, tule elk, pronged antelope, and mountain lion.
Traps were set for smaller game such as rabbit and quail. Marine resources were hunted along the
shores, including sea lions and whales, which were prized for their blubber. Water fowl were a very
important part of the tribal diet and trapped along the tidal marshes. Other marine resources, such
as salmon, steelhead, school fish, and shellfish, including mussels, were collected and were a major
dietary staple. Tule boats were used to collect both saltwater and freshwater marine resources.
The Ohlone also used a wide range of other foods, including various seeds (the growth of which
was promoted by controlled burning), buckeye, berries, roots, acorns, nuts, fruits, land and sea
mammals, water fowl, reptiles, and insects. The Ohlone used tule balsas for watercraft, bows and
arrows, cordage, and bone and ground-stone tools to procure and process their foodstuffs.9,10
The Ohlone were politically organized by tribelet, with each having a designated territory. A
territory consisted of one or more villages and camps designated by physiographic features. Each
tribelet consisted of several households, which averaged from 10 to 15 individuals and were
grouped into clans and moieties. Primary sources describe tribelets as small groups of people,
averaging 60 to 90 individuals, which were located 3 to 5 miles apart. These groups within a
territory were often linked by marriage. The office of tribelet chief, which was inherited
patrilineally, could be occupied by a man or a woman. If there was no son to inherit the position, a
5 Byrd, Brian F. and Jack Meyer. 2011. Initial Cultural Resources Investigation San Francisquito Creek Flood
Damage Reduction and Ecosystem Restoration Project, Santa Clara and San Mateo Counties, California. Prepared
by Far Western Anthropological Research Group. Prepared for Santa Clara Valley Water District.
6 Milliken, R. 1995. A Time of Little Choice: The Disintegration of Tribal Culture in the San Francisco Bay Area 1769-
1810. Ballena Press. Novato, CA.
7 Callaghan, C.A. 1967. Miwok-Costanoan as a Subfamily of Penutian. International Journal of American Linguistics
33(3) Pp. 224-227.
8 Levy, R. 1978. Costanoan. In The Handbook of North American Indians Volume 8: California. Heizer, R.F., Editor.
Pp. 485-493. Smithsonian Institution. Washington, D.C.
9 Krober, A.L. 1925. Handbook of the Indians of California. Dover Press. New York, New York.
10 Milliken, R. 1995. A Time of Little Choice: The Disintegration of Tribal Culture in the San Francisco Bay Area 1769-
1810. Ballena Press. Novato, CA.
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sister or daughter would assume the position. Duties of the chief included providing for visitors,
directing ceremonial activities, and leading fishing, hunting, gathering, and warfare expeditions.
The chief served as the leader of a council of elders, which functioned primarily in an advisory
capacity to the community.
As stated above, a single tribelet, comprising patrilineal family groups, would occupy a village
location at different times of the year. Ohlone villages in the Late Period of the Late Holocene
typically had four types of structures. Dwellings were generally domed structures with central
hearths. They were thatched with tule, grass, or other vegetal material and bound with willow
withes. Permanent settlements were usually placed away from the ocean shore, on high ground.
Sweathouses were used by men and women and usually located along streambanks. A sweathouse
consisted of a pit that was excavated into the streambank, with a thatched portion constructed
against the bank. Dance structures were circular or oval in plan and enclosed by a woven fence of
brush or laurel branches and stood approximately 5 feet. These structures would have one main
doorway, with a smaller opening directly opposite. The assembly house was a thatched dome
structure that was large enough to accommodate all of the inhabitants of the village.11
Although they have yet to receive formal recognition from the federal government, the Ohlone are
becoming increasingly organized as a political unit and have developed an active interest in preserving
their ancestral heritage. In the later part of the twentieth century, the Galvan family of Mission San José
worked closely with the American Indian Historical Society and successfully prevented destruction of
a mission cemetery that was in the path of a proposed freeway. These descendants incorporated as the
Ohlone Indian Tribe and now hold title to the Ohlone Indian Cemetery in Fremont.12 The descendants
are active in maintaining their traditions and advocating for Native American issues.
4.4.3 Regulatory Framework
4.4.3.1 State
Cultural Resources
State Historic Significance Criteria
The CEQA Guidelines provide three ways for a cultural resource to qualify as a historical resource
for the purposes of CEQA:
1. The resource is listed in, or determined eligible for listing in, the California Register of Historical
Resources (CRHR).
2. The resource is included in a local register of historical resources, as defined in PRC Section
5020.1(k), or identified as significant in a historical resource survey meeting the requirements
of PRC Section 5024.1(g), unless the preponderance of evidence demonstrates that it is not
historically or culturally significant.
3. The lead agency determines the resource to be significant, as supported by substantial evidence
in light of the whole record (14 California Code of Regulations [CCR] Section 15064.5[a]).
11 Crespi, J. 1927. Manuscripts of Friar Juan Crespi. University of California Press. Berkeley, California.
12 Bean, L.J. 1994. The Ohlone Past and Present: Native Americans of the San Francisco Bay Region. Ballena Press.
Novato, California.
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For a historical resource to be eligible for listing in the CRHR, it must be significant at the local, state, or
national level under one or more of the following criteria from Public Resources Code Section 5024.1(c):
1. The resource is associated with events that have made a significant contribution to the broad
patterns of California’s history and cultural heritage.
2. The resource is associated with the lives of persons important in our past.
3. The resource embodies the distinctive characteristics of a type, period, region, or method of
construction; represents the work of an important creative individual; or possesses high artistic
values.
4. The resource has yielded, or may be likely to yield, information important in prehistory or history.
Historical resources automatically listed in the CRHR include those historic properties listed in, or
formally determined to be eligible for listing in, the National Register of Historic Places (NRHP) (PRC
Section 5024.1). In addition, CEQA distinguishes between two classes of archaeological resources:
archaeological sites that meet the definition of a historical resource, as defined above, and unique
archaeological resources.
An archaeological resource is considered unique if 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:
l Contains information needed to answer important scientific research questions and that there is a
demonstrable public interest in that information;
l Has a special and particular quality, such as being the oldest of its type or the best available
example of its type; or
l Is directly associated with a scientifically recognized important prehistoric or historic event or
person (PRC Section 21083.2).
Resources that qualify as unique archaeological resources also typically meet at least one of the CRHR
criteria. For the purposes of this project, significant cultural resources, as defined by CEQA, are those
resources that meet at least one of the CRHR eligibility criteria or are unique archeological resources.
Notably, a project that causes a substantial adverse change in the significance of a historical resource is
a project that may have significant impact under CEQA (14 CCR Section 15064.5[b]). A substantial
adverse change in the significance of an historical resource means physical demolition, destruction,
relocation, or alteration of the resource or its immediate surroundings such that the significance of the
historical resource is materially impaired.
The significance of a historical resource is materially impaired if a project demolishes or materially
alters any qualities that justify:
l Inclusion in, or eligibility for inclusion in, the CRHR (14 CCR Section 15064.5[b][2][A],[C]).
l Inclusion in a local register (14 CCR Section 15064.5[b][2][B]).
Tribal Cultural Resources
Assembly Bill 52
Tribal cultural resources were originally identified as a distinct CEQA environmental category with
the adoption of Assembly Bill 52 (AB 52) in September 2014. For all projects that are subject to
CEQA that received a notice of preparation, notice of negative declaration, or mitigated negative
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declaration on or after July 1, 2015, AB 52 requires the lead agency on a proposed project to consult
with the geographically affiliated California Native American tribes. The legislation creates a broad new
category of environmental resources, “tribal cultural resources,” which must be considered under
CEQA. AB 52 requires a lead agency to not only consider the resource’s scientific and historical value
but also whether it is culturally important to a California Native American tribe.
AB 52 defines tribal cultural resources as sites, features, places, cultural landscapes, sacred places, and
objects with cultural value to a California Native American tribe that are included or determined to be
eligible for inclusion in the CRHR; included in a local register of historical resources, as defined in Public
Resources Code Section 5020.1(k); or determined by the lead agency, in its discretion and supported by
substantial evidence, to be significant pursuant to the criteria of Public Resources Code Section
5024.1(c) (CEQA Section 21074).
The CRHR criteria for the listing of resources, as defined in Public Resources Code Section 5024.1(c), are
the following:
1. The resource is associated with events that have made a significant contribution to the broad
patterns of California’s history and cultural heritage.
2. The resource is associated with the lives of persons important in our past.
3. The resource embodies the distinctive characteristics of a type, period, region, or method of
construction; represents the work of an important creative individual; or possesses high artistic
values.
4. The resource has yielded, or may be likely to yield, information important in prehistory or history.
AB 52 also sets up an expanded consultation process. For projects initiated after July 1, 2015, lead
agencies are required to provide notice of the proposed projects to any tribe that is traditionally and
culturally affiliated with the geographic area that requested to be informed by the lead agency,
following Public Resources Code Section 21018.3.1(b). If, within 30 days, a tribe requests consultation,
the consultation process must begin before the lead agency can release a draft environmental
document. Consultation with the tribe may include discussion of the type of review necessary, the
significance of tribal cultural resources, the significance of the project’s impacts on the tribal cultural
resources, and alternatives and mitigation measures recommended by the tribe. The consultation
process will be deemed concluded when either (a) the parties agree to mitigation measures or (b) any
party concludes, after a good-faith effort, that an agreement cannot be reached. Any mitigation
measures agreed to by the tribe and lead agency must be recommended for inclusion in the
environmental document. If a tribe does not request consultation, or otherwise assist in identifying
mitigation measures during the consultation process, a lead agency may still consider mitigation
measures if the agency determines that a project will cause a substantial adverse change to a tribal
cultural resource.
4.4.3.2 Local
Cultural Resources
South San Francisco General Plan
The 1999 General Plan provides a vision for long-range physical and economic development of the
City, provides strategies and specific implementing actions, and establishes a basis for judging
whether specific development proposals and public projects are consistent with the City of South
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San Francisco’s (City’s) plans and policy standards. The General Plan contains an Open Space and
Conservation Element, which outlines policies relating to habitat and biological resources, water
quality, air quality, greenhouse gas emissions and historic and cultural resources conservation. The
General Plan includes the following policies applicable to cultural resources:
l Policy 7.5-G-1: Conserve historic, cultural, and archaeological resources for the aesthetic,
educational, economic, and scientific contribution they make to South San Francisco’s identity
and quality of life.
l Policy 7.5-G-2: Encourage municipal and community awareness, appreciation, and support for
South San Francisco’s historic, cultural, and archaeological resources.
The General Plan also establishes several specific guidelines for implementation of the guiding
principles of the document. Specific guidelines that are relevant to this project include:
l Guideline 7.5-I-3: Explore mechanisms to incorporate South San Francisco’s industrial heritage
in historic and cultural preservation.
l Guideline 7.5-I-4: Ensure the protection of known archaeological resources in the City by
requiring a records review for any development proposed in areas with known resources.
l Guideline 7.5-I-5: In accordance with state law, require the preparation of a resource mitigation
plan and monitoring program by a qualified archaeologist in the event that archaeological
resources are uncovered.
4.4.4 Impacts and Mitigation Measures
4.4.4.1 Significance Criteria
Cultural Resources
Based on Appendix G of the CEQA Guidelines, the proposed project would have a significant cultural
resources impact if it would:
l Cause a substantial adverse change in the significance of a historical resource pursuant to
Section 15064.5;
l Cause a substantial adverse change in the significance of an archaeological resource pursuant to
Section 15064.5; or
l Disturb any human remains, including those interred outside of dedicated cemeteries.
Tribal Cultural Resources
Based on Appendix G of the CEQA Guidelines, the proposed project would have a significant tribal
cultural resources impact if it would:
l Cause a substantial adverse change in the significance of a tribal cultural resource, defined in
PRC Section 21074 as either a site, feature, place, or cultural landscape that is geographically
defined in terms of the size and scope of the landscape, sacred place, or object with cultural
value to a California Native American tribe and that is:
l Listed in, or eligible for listing in, the CRHR or a local register of historical resources, as defined
in PRC Section 5020.1(k), or
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l A resource determined by the lead agency, in its discretion and supported by substantial
evidence, to be significant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1.
In applying the criteria set forth in subdivision (c) of PRC Section 5024.1, the lead agency shall
consider the significance of the resource to a California Native American tribe.
4.4.4.2 Approach to Analysis
Cultural Resources
Evaluation of the proposed project is based on a records search conducted by ICF archaeologist
Yuka Oiwa on February 21, 2020, at the Northwestern Information Center of the California Historic
Resources Information System in Rohnert Park, California. Information centers are depositories of
documentation for known archaeological and historic resources in California. The records search
was conducted to identify all known archaeological and built-environment resources within the
project area and within approximately 0.25 mile of the project site as well previous survey coverage
of the project area. Records search results indicate that nineteen previous cultural resources studies
have been conducted within 0.25 miles of the project site. Two of these studies have been conducted
within the project site. The project site was previously surveyed in its entirety by Archaeological
Resources Technology in 2016 and 2018. No cultural resources were identified within the project
site as a result of the surveys.
Table 4.4-1 identifies the eight previously recorded cultural resources within 0.25 mile of the
project site, including six built environment resources and two archaeological resources. The two
archaeological resources within 0.25 mile of the project site, P-41-000044 and P41-002207, are
prehistoric shell midden sites. There are no known archaeological or built-environment resources
within the project site.
Table 4.4-1. Cultural Resources within 0.25 Mile of the Project Site
Primary
Number Trinomial Age Name Description
Within
Project Site?
P-41-000044 CA-SMA-40 Prehistoric N/A Shell Midden No
P-41-000814 Historic Grand Hotel Hotel Building No
P-41-000885 Historic 205 Juniper Avenue Craftsman
Bungalow
No
P-41-000956 Historic 225 Juniper Avenue Italianate False
Front House
No
P-41-002207 CA-SMA-386 Prehistoric Airport & Armour
Buried Site
Shell Midden No
P-41-002318 Historic T-Mobile West LLC
SF73113B
PG&E Tower No
P-41-002433
Historic Signal Bridge North of
Grand Ave Overpass
Signal Bridge No
P-51-002434 Historic 129 Sylvester Road Industrial
Building
No
Source: Records search conducted by ICF archaeologist Yuka Oiwa on February 21, 2020, at the Northwestern
Information Center of the California Historic Resources Information System in Rohnert Park, California.
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Tribal Cultural Resources
Efforts to identify tribal cultural resources within the project area included consultation with
interested Native American groups under AB 52.
On January 15, 2020, the City distributed tribal consultation letters to the following organizations:
the Amah Mutsun Tribal Band of Mission San Juan, the Costanoan Rumsen Carmel Tribe, the Indian
Canyon Mutsun Band of Costanoan, the Muwekma Ohlone Indian Tribe of the San Francisco Bay
Area, and the Ohlone Indian Tribe. Included in the letters was a brief description of the project, the
results of a records search, project location maps, and a request for comments, concerns, or
knowledge regarding sacred lands or heritage sites in the project area. Native American groups had
30 days from the receipt of the letter to request consultation under AB 52; no requests for
consultation were received during the 30-day period, which ended on February 15, 2020. A record
of all AB 52 consultation is provided in Appendix C of this draft EIR.
4.4.4.3 Impact Evaluation
Impact CR-1: The proposed project would not cause a substantial adverse change in the
significance of a historical resource, pursuant to Section 15064.5. (No Impact)
The project site is currently developed with a six-story, approximately 170,235-square-foot office
building at 701 Gateway Boulevard and surface parking lots. The existing building at 701 Gateway
Boulevard was constructed in 1998. This existing structure is not historic in age and is not eligible
for designation on the CRHR. Records search results indicate that there are no known built-
environment resources within the project site. Therefore, the proposed project would have no
impact on historical resources. No mitigation is required.
Impact CR-2: The proposed project would not cause a substantial adverse change in the
significance of an archaeological resource, pursuant to Section 15064.5. (Less than
Significant with Mitigation)
Records search results indicate the project site is close to the prehistoric coastline, making it
sensitive for the presence of prehistoric shell midden sites. There are two previously recorded
cultural resources within 0.25 mile of the project site, P-41-000044 and P41-002207. Both
resources are prehistoric shell midden sites. However, there are no previously recorded
archaeological resources within the project site. In addition, the project site was previously
surveyed in its entirety by Archaeological Resources Technology in 2016 and 2018. No cultural
resources were identified within the project site as a result of the surveys. Furthermore, the project
site is fully developed and lacks surface visibility. Any visible ground surface has been disturbed
and/or covered with fill and gravel. All visible ground surfaces appear to have been graded,
landscaped, or developed. Notwithstanding, given the presence of two known prehistoric sites
within the vicinity of the project, and given the proximity of the project site to the coast, the project
site has a moderate sensitivity for similar buried archaeological resources.
The proposed project would excavate approximately 1,850 cubic yards of soil that would be
reused as fill on-site, and would import an additional 750 cubic yards of soil to be used as fill on-
site. To accommodate utility trenches, the project would require a maximum depth of excavation
reaching approximately 9 feet below ground surface. Previously unknown archaeological
resources could be inadvertently unearthed during ground-disturbing activities, which would be a
significant impact. Implementation of Mitigation Measure CR-1, Cultural Resources Worker
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Environmental Awareness Program (WEAP), and Mitigation Measure CR-2, Halt Construction
Activity, Evaluate Find, and Implement Mitigation for Archaeological, Historical, and Tribal
Resources, would reduce this impact to less than significant with mitigation by ensuring that
project activities would not result in the inadvertent destruction of an archaeological resource.
Mitigation Measure CR-1: Cultural Resources Worker Environmental Awareness
Program
The project applicant shall ensure that a qualified archaeologist shall conduct WEAP training
for all construction personnel on the project site prior to construction and ground-disturbing
activities. The training shall include basic information about the types of artifacts that might
be encountered during construction activities, and procedures to follow in the event of a
discovery. This training shall be provided for any additional personnel added to the project
even after the initiation of construction and ground-disturbing activities.
Mitigation Measure CR-2: Halt Construction Activity, Evaluate Find, and Implement
Mitigation for Archaeological, Historical, and Tribal Resources
In the event that previously unidentified archaeological, historical, or tribal resources are
uncovered during site preparation, excavation, or other construction activity, the project
applicant shall cease or ensure the ceasing of all such activity within 25 feet of the discovery
until the resources have been evaluated by a qualified professional, and specific measures can
be implemented to protect these resources in accordance with Sections 21083.2 and 21084.1
of the California Public Resources Code. If the find is significant, the project applicant shall
ensure that a qualified archaeologist excavate the find in compliance with state law, keeping
project delays to a minimum. If the qualified archaeologist determines the find is not
significant, then proper recordation and identification will ensue and the project shall
continue without delay.
Impact CR-3: The proposed project would not disturb any human remains, including those
interred outside of formal cemeteries. (Less than Significant with Mitigation)
Records search results did not indicate the presence of human remains within the project site. As
discussed under Impact CR-3, no formal cemeteries have been located on the project site, and
human remains would be unlikely to be found. However, if inadvertent discovery of human remains
occurs during ground-disturbing activities, this would be a significant impact. Implementation of
Mitigation Measure CR-3, Halt Construction Activity, Evaluate Remains, and Take Appropriate
Action in Coordination with Native American Heritage Commission, would reduce this impact to less
than significant with mitigation by ensuring that discovery procedures for human remains would
be implemented.
Mitigation Measure CR-3: Halt Construction Activity, Evaluate Remains, and Take
Appropriate Action in Coordination with Native American Heritage Commission
In the event that human remains are uncovered during site preparation, excavation, or other
construction activity, the project applicant shall cease or ensure the ceasing of all such activity
within 25 feet of the discovery until the remains have been evaluated by the County Coroner
and appropriate action taken in coordination with the NAHC, in accordance with Section
7050.5 of the CHSC or, if the remains are Native American, Section 5097.98 of the California
Public Resources Code.
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Impact CR-4: The proposed project would not cause a substantial adverse change in the
significance of a tribal cultural resource, as defined in Public Resources Code Section 21074.
(Less than Significant with Mitigation)
No Native American tribes have identified tribal cultural resources within the project site. In
addition, no Native American tribes requested further consultation under AB 52 regarding the
project, and no Native American tribes have identified unrecorded tribal cultural resources within
the project area. However, if inadvertent discovery of tribal cultural resources occurs during
ground-disturbing activities, this would be a significant impact. Implementation of Mitigation
Measure CR-1, Cultural Resources Worker Environmental Awareness Program (WEAP), and
Mitigation Measure CR-2, Halt Construction Activity, Evaluate Find, and Implement Mitigation for
Archaeological, Historical, and Tribal Resources, would reduce this impact to less than significant
with mitigation by ensuring that discovery procedures for tribal cultural resources would be
implemented.
4.4.4.4 Cumulative Impacts
Impact C-CR-1: The proposed project would not result in a cumulatively considerable
contribution to significant cumulative impacts on archaeological resources, human remains,
and tribal cultural resources. (Less than Significant with Mitigation)
The cumulative geographic context for archaeological resources and human remains is the
immediate vicinity of the project site, which is the area where construction activities, including
ground-disturbing activities, could encounter archaeological resources, human remains, and tribal
cultural resources that may be present on or near the site. The cumulative projects within 0.5 mile of
the project site are described in Section 4.1.5, Approach to Cumulative Impact Analysis, of this draft
EIR and shown in Figure 4.1-1.
The cumulative projects in the vicinity of the project site would be constructed on infill sites in highly
disturbed areas. It is likely that the cumulative projects would be constructed on sites where the
ground surface has been disturbed and/or covered with fill and gravel. Similar to the proposed
project, all cumulative projects would be required to implement mitigation measures to ensure that
project activities would not result in the inadvertent destruction of an archaeological resource
and that human remains discovery procedures would be implemented. Nonetheless, cumulative
impacts on archaeological resources, human remains, and tribal cultural resources could be
significant because the reasonably foreseeable projects would likely involve ground-disturbing
activities that could uncover resources related to resources that could be uncovered by the project.
Implementation of Mitigation Measure CR-1, Cultural Resources Worker Environmental
Awareness Program; Mitigation Measure CR-2, Halt Construction Activity, Evaluate Find, and
Implement Mitigation for Archaeological, Historical, and Tribal Resources; and Mitigation Measure
CR-3, Halt Construction Activity, Evaluate Remains, and Take Appropriate Action in Coordination
with Native American Heritage Commission, would ensure that the proposed project’s contribution to
cumulative impacts on archaeological resources, human remains, and tribal cultural resources would
be less than cumulatively considerable.