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PHASE I CULTURAL AND PALEONTOLOGICAL ASSESSMENT: MAGNOLIA TANK FARM PROJECT CITY OF HUNTINGTON BEACH, ORANGE COUNTY, CALIFORNIA Prepared on Behalf of: SLF-HB Magnolia, LLC 2 Park Plaza Irvine, CA 92614 Principal Investigators/Authors: Tria Marie Belcourt, M.A., Registered Professional Archaeologist Jennifer Kelly, M.Sc., Geology, Professional Paleontologist Sonia Sifuentes, M.Sc., Registered Professional Archaeologist Material Culture Consulting Project Number: SRI-17-01 Type of Study: Cultural and paleontological resources assessment Cultural Resources within Area of Potential Impact: None Paleontological Formations: Younger Quaternary Alluvium USGS Quadrangle: Newport Beach APN(s): 114-150-36, 114-481-32 Survey Area: 29 acres Date of Survey: August 8, 2017 Key Words: Paleontology, Archaeology, CEQA, Phase I Survey, Negative Survey

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Page 1: PHASE I CULTURAL AND PALEONTOLOGICAL ASSESSMENT: …€¦ · Belcourt is a Registered Professional Archaeologist (RPA) and Qualified Orange County Archaeologist, with a M.A. in Anthropology

PHASE I CULTURAL AND PALEONTOLOGICAL ASSESSMENT:

MAGNOLIA TANK FARM PROJECT

CITY OF HUNTINGTON BEACH, ORANGE COUNTY, CALIFORNIA

Prepared on Behalf of: SLF-HB Magnolia, LLC

2 Park Plaza

Irvine, CA 92614

Principal Investigators/Authors:

Tria Marie Belcourt, M.A., Registered Professional Archaeologist

Jennifer Kelly, M.Sc., Geology, Professional Paleontologist

Sonia Sifuentes, M.Sc., Registered Professional Archaeologist

Material Culture Consulting Project Number: SRI-17-01

Type of Study: Cultural and paleontological resources assessment

Cultural Resources within Area of Potential Impact: None

Paleontological Formations: Younger Quaternary Alluvium

USGS Quadrangle: Newport Beach

APN(s): 114-150-36, 114-481-32

Survey Area: 29 acres

Date of Survey: August 8, 2017

Key Words: Paleontology, Archaeology, CEQA, Phase I Survey, Negative Survey

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November 2017 (Revised January 2018)
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Material Culture Consulting, Inc. | 2701-B North Towne Avenue Pomona CA 91767 | 626-205-8279 | www.materialcultureconsulting.com

MANAGEMENT SUMMARY

SLF-HB Magnolia, LLC proposes to convert a currently vacant and graded lot into a mixed-use community that provides visitor serving commercial uses, new residential neighborhoods, opportunities for coastal access and passive recreation and incorporates measures to protect adjacent natural resources, called the Magnolia Tank Farm Project (Project). The Project is located in the City of Huntington Beach, Orange County, California The Project includes construction of up to 250 for-sale residential units and visitor-and-resident-serving commercial uses facilities. Material Culture Consulting, Inc. (Material Culture) was retained by SLF-HB Magnolia, LLC (SLF-HB) to conduct the Phase I cultural and paleontological resource investigation of the Project Area. These assessments were conducted in accordance with the California Environmental Quality Act (CEQA), and included cultural and paleontological records searches, a search of the Sacred Lands File by the Native American Heritage Commission (NAHC), outreach efforts with ten Native American tribal representatives, background research, and a pedestrian field survey, all of which resulted in negative findings.

The records searches, SLF search, and communication with Native American groups did not identify any previously known cultural resources or fossil localities within the Project Area; however, two cultural resources are within a 1-mile buffer of the Project Area, historic-era water tanks and a prehistoric shell deposit. Prior and ongoing work associated with other construction projects have already established both of these resources are ineligible for National Register of Historic Places (HRHP) or California Register of Historical Resources (CRHR), and neither resource will be impacted by the Project. The geologic unit present within the Project Area is identified as younger Quaternary Alluvium, procured as fluvial deposits from the nearby Santa Ana River to the east. While these deposits are typically devoid of significant vertebrate fossils, they are usually underlain by older Quaternary deposits that can contain paleontological resources. Examination of historic topographic maps and aerials indicate that prior to the 1950s, the area was mainly coastal wetlands with a river south of the Project Area and smaller streams northwest of the area (earliest map from 1896). Starting in the 1950s, major development occurred in the area, changing the area into an industrial landscape. The pedestrian survey of the Project Area was conducted on August 8, 2017 by Judy Bernal, archaeologist and cross-trained paleontologist. During the course of fieldwork, survey conditions were very good and ground visibility averaged good (80 to 95%) due to recent grading activities within the Project Area. A dense concentration of unidentifiable marine shells and shell fragments is present throughout approximately 50% of the Project Area, mostly within the western and northwestern portions of the Project Area. Based on similar observations made on other projects, and the lack of cultural material associated with the shell, it is believed that this shell scatter is natural and not cultural. Beyond the shell scatter, no cultural or paleontological resources were identified during the survey.

The observed shell scatter is most likely associated with naturally occurring shell deposits. However, several nearby highly sensitive archaeological sites are found in similar coastal settings. Therefore, we recommend cultural monitoring during initial ground disturbance associated with the Project. While the majority of the Project Area is mapped in younger Quaternary Alluvium, the probability of older Quaternary deposits present underneath that may contain paleontological resources is high enough that we recommend a paleontological resource mitigation program be put in place to monitor, salvage, and curate any recovered fossils associated with the current study area. We only recommend paleontological monitoring during substantial ground disturbance activities, those whose depths are greater than 10-ft below surface, when such activities are likely to disturb sensitive sediments.

A copy of this report will be permanently filed with the SCCIC at California State University, Fullerton. All notes, photographs, correspondence and other materials related to this Project are located at Material Culture Consulting, Inc., located in Pomona, California.

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Material Culture Consulting, Inc. | 2701-B North Towne Avenue Pomona CA 91767 | 626-205-8279 | www.materialcultureconsulting.com

TABLE OF CONTENTS

INTRODUCTION 5

PROJECT LOCATION AND DESCRIPTION 5 PROJECT PERSONNEL 5

REGULATORY ENVIRONMENT 9

CALIFORNIA ENVIRONMENTAL QUALITY ACT 9 CALIFORNIA HISTORICAL LANDMARKS AND POINTS OF HISTORICAL INTEREST 10 ORANGE COUNTY GUIDELINES 11 CITY OF HUNTINGTON BEACH GUIDELINES 11 PALEONTOLOGY 11

BACKGROUND 14

ENVIRONMENTAL SETTING 14

PALEONTOLOGICAL SETTING 14 PREHISTORIC CONTEXT 14 ETHNOGRAPHY 15 HISTORICAL SETTING 16

METHODS 18

CALIFORNIA HISTORIC RESOURCES INVENTORY SYSTEM AND CULTURAL BACKGROUND RESEARCH 18 NATIVE AMERICAN OUTREACH AND BACKGROUND RESEARCH 18 PALEONTOLOGICAL RECORDS SEARCH 18 FIELD SURVEY 18

RESULTS 20

CALIFORNIA HISTORIC RESOURCES INVENTORY SYSTEM AND CULTURAL BACKGROUND RESEARCH 20 NATIVE AMERICAN OUTREACH AND BACKGROUND RESEARCH 22 PALEONTOLOGICAL RECORDS SEARCH 25 CULTURAL AND PALEONTOLOGICAL FIELD SURVEY 25

CONCLUSIONS AND RECOMMENDATIONS 29

CULTURAL RESOURCES CONCLUSIONS 29 CULTURAL RESOURCES RECOMMENDATIONS 29 PALEONTOLOGICAL RESOURCES CONCLUSIONS 30 PALEONTOLOGICAL RESOURCES RECOMMENDATIONS 30

REFERENCES 31

LIST OF FIGURES

FIGURE 1. MAGNOLIA TANK FARM PROJECT VICINITY ................................................................................................................ 6 FIGURE 2. MAGNOLIA TANK FARM PROJECT AREA (DEPICTED ON NEWPORT BEACH USGS 7.5 MINUTE QUADRANGLE) ....................... 7 FIGURE 3. MAGNOLIA TANK FARM PROJECT AREA (DEPICTED ON AERIAL PHOTOGRAPH) ................................................................. 8 FIGURE 4. PROJECT AREA (DEPICTED ON 1938 AERIAL PHOTOGRAPH)........................................................................................ 22 FIGURE 5. PROJECT AREA (DEPICTED ON 1963 AERIAL PHOTOGRAPH SHOWING AREA CUT/FILLED FOR TANKS) ................................... 23 FIGURE 6. MAGNOLIA TANK FARM PROJECT AREA (DEPICTED ON 1972 AERIAL PHOTOGRAPH – FIRST VISUAL PRESENCE OF TANKS) ....... 24 FIGURE 7. PROJECT OVERVIEW FROM ENTRANCE OF SITE (VIEW WEST) ...................................................................................... 26 FIGURE 8. PROJECT OVERVIEW FROM MOST SOUTHERN AREA (VIEW NORTH) .............................................................................. 27 FIGURE 9. PROJECT OVERVIEW FROM WEST STOCKPILE (VIEW NORTH) ...................................................................................... 27 FIGURE 10. REPRESENTATIVE PHOTO OF SHELLS OBSERVED IN PROJECT AREA (LIKELY DERIVED FROM FILL SOILS USED AT THE SITE) .......... 28

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Material Culture Consulting, Inc. | 2701-B North Towne Avenue Pomona CA 91767 | 626-205-8279 | www.materialcultureconsulting.com

LIST OF TABLES

TABLE 1. ADDITIONAL SOURCES CONSULTED FOR THE PROJECT ................................................................................................. 20 TABLE 2. PREVIOUS RESOURCES WITHIN 1-MILE BUFFER OF PROJECT AREA ................................................................................. 20 TABLE 3. PREVIOUS CONDUCTED RESOURCE INVESTIGATIONS WITHIN 1-MILE BUFFER OF PROJECT AREA .......................................... 20

APPENDIX A – QUALIFICATIONS APPENDIX B - NAHC AND NATIVE AMERICAN CORRESPONDENCE APPENDIX C - PALEONTOLOGICAL RECORDS SEARCH RESULT FROM NATURAL HISTORY MUSEUM OF LOS ANGELES COUNTY

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Magnolia Tank Farm Project Phase I Cultural and Paleontological Resources Assessment

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Material Culture Consulting, Inc. | 2701-B North Towne Avenue Pomona CA 91767 | 626-205-8279 | www.materialcultureconsulting.com

INTRODUCTION

SLF-HB Magnolia, LLC proposes to convert a currently vacant and graded lot into a residential housing community located in the City of Huntington Beach, Orange County, California. The Project involves the construction of up to 250 for-sale residential units of Medium Density made up of detached single-family homes and townhomes, with associated visitor-and resident-serving facilities and parking garage. Material Culture Consulting, Inc. (MCC) was retained by SLF-HB Magnolia, LLC to conduct a Phase I cultural and paleontological resource investigation of the Project Area in accordance with the California Environmental Quality Act (CEQA). The State of California Department of General Services is the Lead CEQA agency. This assessment was conducted pursuant to all applicable State regulations regarding cultural and paleontological resources, as well as paleontological guidelines established by the Society of Vertebrate Paleontology (SVP 2010). According to these regulations and guidelines, if development of a Project impacts significant cultural and/or paleontological resources, a plan must be developed to mitigate those impacts. This assessment documents the potential for encountering cultural and paleontological resources during development of this Project and provides recommendations on how to mitigate impacts to those resources.

PROJECT LOCATION AND DESCRIPTION

The proposed Project Area is located at 21845 Magnolia Street, Huntington Beach, which is in the southeastern area of the Huntington Beach (Figures 1 and 2). The area of potential impact (API) includes two parcels that encompass a total of 29 acres (Figures 2 and 3). The site is a triangular shaped parcel, and is bound by Magnolia Street on the east and southeast, the Huntington Beach Channel and Magnolia Marsh on the south and southwest, and the vacant Ascon property, a former landfill, on the north. The inland embankment of the Huntington Beach Channel is adjacent to the project site and is lined by metal sheet piles. Specifically, the proposed Project is located on the Newport Beach USGS 7.5-minute quadrangle, Section 18 of Township 6 South and Range 10 West (San Bernardino Base Meridian) (Figure 2).

On the eastern end of the project site, adjacent to Magnolia Street, is an area commonly referred to as Squirrel Park, a private, landscaped setback area comprised of turf, ornamental trees, decorative rocks and an earthen berm, which provides some visual screening of the project site from Magnolia Street. The site is separated from the inland metal sheet pile bank of the Huntington Beach Channel by a chain link fence and a gated maintenance road and unpaved, bare earth strip abutting the project property boundary. Near the midpoint of the western property line is a concrete bridge extending across the Huntington Beach Channel to the Magnolia Marsh. The project property has an appurtenant access easement over the bridge and beyond. The project site is visible along Pacific Coast Highway (PCH) from south of the intersection of PCH and Magnolia Street until the AES Southland facility.

PROJECT PERSONNEL

Tria Belcourt, M.A., RPA, President of Material Culture Consulting Inc., served as the Project Manager and Principal Archaeologist for the study. Ms. Belcourt coordinated the records searches, created the maps for the report, and performed editorial review of this report. Belcourt is a Registered Professional Archaeologist (RPA) and Qualified Orange County Archaeologist, with a M.A. in Anthropology from the University of Florida, a B.A. in Anthropology from the University of California at Los Angeles, and is a cross-trained paleontologist with over twelve years of experience in California archaeology and seven years of experience in California paleontology (See Appendix A). Jennifer Kelly, M.Sc., a Geologist and Qualified Orange County Paleontologist, served as the Principal Paleontologist for the study. Ms. Kelly oversaw the paleontological resource literature and map reviews, directed the field study, and co-prepared this report. Ms. Kelly has a M.Sc. in Geology from California State University, Long Beach. Ms. Kelly has over ten years of experience in environmental and paleontological compliance in California (See Appendix A). Sonia Sifuentes, M.Sc, RPA, co-prepared this report. Ms. Sifuentes is a Registered Professional Archaeologist (RPA) with a M.Sc. in Archaeology of the North from University of Aberdeen, Scotland, a B.A. in Anthropology from University of Southern California, Los Angeles, as well as nine years of professional experience working in Southern California archaeology and three years of experience in California paleontology. Judy Bernal, B.A, conducted pedestrian survey and technical support for this report.

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Material Culture Consulting, Inc. | 2701-B North Towne Avenue Pomona CA 91767 | 626-205-8279 | www.materialcultureconsulting.com

Figure 1. Magnolia Tank Farm Project Vicinity

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Magnolia Tank Farm Project Phase I Cultural and Paleontological Resources Assessment

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Figure 2. Magnolia Tank Farm Project Area (depicted on Newport Beach USGS 7.5 Minute Quadrangle)

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Magnolia Tank Farm Project Phase I Cultural and Paleontological Resources Assessment

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Figure 3. Magnolia Tank Farm Project Area (depicted on aerial photograph)

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REGULATORY ENVIRONMENT

This Project is subject to state regulations, including CEQA and the California Public Resources Code. These state regulations require the identification of archaeological and paleontological resources during the planning stage of new Projects; include application review for Projects that would potentially involve land disturbance; provide a Project-level standard condition of approval that addresses unanticipated archaeological and/or paleontological discoveries; and provide requirements to develop specific mitigation measures if resources are encountered during any development activity.

CALIFORNIA ENVIRONMENTAL QUALITY ACT

CEQA declares that it is state policy to "take all action necessary to provide the people of this state with...historic environmental qualities." It further states that public or private Projects financed or approved by the state are subject to environmental review by the state. All such Projects, unless entitled to an exemption, may proceed only after this requirement has been satisfied. CEQA requires detailed studies that analyze the environmental effects of a proposed Project. In the event that a Project is determined to have a potential significant environmental effect, the act requires that alternative plans and mitigation measures be considered. CEQA includes historic and archaeological resources as integral features of the environment. If paleontological resources are identified as being within a proposed Project Area, the sponsoring agency must take those resources into consideration when evaluating Project impacts. The level of consideration may vary with the importance of the resource.

CEQA requires a lead agency to determine whether a Project may have a significant effect on historical resources. A historical resource is a resource listed in, or determined to be eligible for listing in, the California Register of Historical Resources (CRHR) (Section 21084.1), a resource included in a local register of historical resources (Section 15064.5(a)(2)), or any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant (Section 15064.5 (a)(3)). Public Resources Code (PRC) Section 5024.1, Section 15064.5 of the Guidelines, and Sections 21083.2 and 21084.1 of the Statutes of CEQA were used as the basic guidelines for the cultural resources study. PRC Section 5024.1 directs evaluation of historical resources to determine their eligibility for listing on the CRHR. The purpose of the register is to maintain listings of the state's historical resources and to indicate which properties are to be protected from substantial adverse change.

The criteria for listing resources on the CRHR were expressly developed to be in accordance with previously established criteria developed for listing on the NRHP, enumerated above, and require similar protection to what NHPA Section 106 mandates for historic properties. According to Public Resources Code (PRC) Section 5024.1(c)(1-4), a resource is considered historically significant if it meets at least one of the following criteria:

1. Associated with events that have made a significant contribution to the broad patterns of local or regionalhistory or the cultural heritage of California or the United States;

2. Associated with the lives of persons important to local, California or national history;3. Embodies the distinctive characteristics of a type, period, region or method of construction or represents

the work of a master or possesses high artistic values; or4. Has yielded, or has the potential to yield, information important to the prehistory or history of the local

area, California or the nation.

In addition to having significance, resources must have integrity for the period of significance. The period of significance is the date or span of time within which significant events transpired, or significant individuals made their important contributions. Integrity is the authenticity of a historical resource’s physical identity as evidenced by the survival of characteristics or historic fabric that existed during the resource’s period of significance. Alterations to a resource or changes in its use over time may have historical, cultural, or architectural significance. Simply, resources must retain enough of their historic character or appearance to be recognizable as historical resources and to convey the reasons for their significance. A resource that has lost its historic character or appearance may still have sufficient integrity for the California Register, if, under Criterion 4, it maintains the potential to yield significant scientific or historical information or specific data. Note that California Historical Landmarks with numbers 770 or higher are automatically included in the CRHR.

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Under CEQA, if an archeological site is not a significant “historical resource” but meets the definition of a “unique archeological resource” as defined in PRC Section 21083.2, then it should be treated in accordance with the provisions of that section. A unique archaeological resource is defined in PRC Section 21083.2(g) as follows:

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 ademonstrable public interest in that information.

2. Has a special and particular quality such as being the oldest of its type or the best available example of itstype.

3. Is directly associated with a scientifically recognized important prehistoric or historic event or person.

Resources that neither meet any of these criteria for listing on the NRHP or CRHR nor qualify as a “unique archaeological resource” under CEQA PRC Section 21083.2 are viewed as not significant. Under CEQA, “A non-unique archaeological resource need be given no further consideration, other than the simple recording of its existence by the lead agency if it so elects” [PRC Section 21083.2(h)].

Impacts to historical resources that alter the characteristics that qualify the historical resource for listing on the CRHR are considered to be a significant effect (under CEQA). The impacts to a historical resource are considered significant, if the Project activities physically destroy or damage all or part of a resource, change the character of the use of the resource or physical feature within the setting of the resource which contribute to its significance, or introduce visual, atmospheric, or audible elements that diminish the integrity of significant features of the resource. If it can be demonstrated that a Project will cause damage to a unique archaeological resource, the lead agency may require reasonable efforts to be made to permit any or all of these resources to be preserved in place or left in an undisturbed state. To the extent that they cannot be left undisturbed, mitigation measures are required (Section 21083.2 (a), (b), and (c)).

CALIFORNIA HISTORICAL LANDMARKS AND POINTS OF HISTORICAL INTEREST

Historical landmarks are sites, buildings, features, or events that are of statewide significance and have anthropological, cultural, military, political, architectural, economic, scientific or technical, religious, experimental, or other value. In order to be considered a California Historical Landmark, the landmark must meet at least one of the following criteria:

1. Associated with events that have made a significant contribution to the broad patterns of local or regionalhistory or the cultural heritage of California or the United States;

2. Associated with the lives of persons important to local, California, or national history;3. Embodies the distinctive characteristics of a type, period, region, or method of construction; represents

the work of a master; or possesses high artistic values;4. Has yielded, or has the potential to yield, information important to the prehistory or history of the local

area, California, or the nation.

If a site is primarily of local or countywide interest, it may meet the criteria for the California Point of Historical Interest Program. Points of Historical Interest are sites, buildings, features, or events that are of local (city or county) significance and have anthropological, cultural, military, political, architectural, economic, scientific or technical, religious, experimental, or other value. To be eligible for designation as a Point of Historical Interest, a resource must meet at least one of the following criteria:

1. The first, last, only, or most significant of its type in the local geographic region (city or county);2. Associated with an individual or group having a profound influence on the history of the local area;3. A prototype of, or an outstanding example of, a period, style, architectural movement or construction; or4. One of the more notable works or the best surviving work in the local region of a pioneer architect,

designer, or master builder.

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Points of Historical Interest designated after December 1997 and recommended by the State Historical Resources Commission are also listed in the California Register. No historical resource may be designated as both a Landmark and a Point of Interest. If a Point of Interest is subsequently granted status as a Landmark, the Point of Interest designation will be retired.

ORANGE COUNTY GUIDELINES

The Orange County General Plan (2011) Resources Element contains explicit guidelines for archaeological and paleontological resources in the Cultural Resources portion of the document. Additionally, Orange County has an archaeological and paleontological certification program to identify qualified technical specialists for work within the County.

Cultural Resources Goal 1 requires the County to raise the awareness and appreciation of Orange County's cultural and historic heritage. To achieve this, Objective 1.1 requires that the County facilitate and participate in activities that inform people about the social, cultural, economic, and scientific values of Orange County's heritage. Objective 1.2 requires that the County work through the Orange County Historical Commission in the areas of history, paleontology, archaeology, and historical preservation. Goal 2 states that the County shall encourage through a resource management effort the preservation of the county's cultural and historic heritage. Objective 2.1 states that the County shall promote the preservation and use of buildings, sites, structures, objects, and districts of importance in Orange County through the administration of planning, environmental, and resource management programs. Objective 2.2 requires that the County take all reasonable and proper steps to achieve the preservation of archaeological and paleontological remains, or their recovery and analysis to preserve cultural, scientific, and educational values. Additionally, Orange County has a well-defined set of guidelines regarding paleontological resources, their disposition, and distribution throughout the County (Cooper and Eisentraut, 2002).

The following policies addressing archaeological, paleontological, and historical resources shall be implemented at appropriate stage(s) of planning, coordinated with the processing of a project application, as follows:

• Identification of resources shall be completed at the earliest stage of project planning and review such asgeneral plan amendment or zone change.

• Evaluation of resources shall be completed at intermediate stages of project planning and review such assite plan review, subdivision map approval, or at an earlier stage of project review.

• Final preservation actions shall be completed at final stages of project planning and review such asgrading, demolition, or at an earlier stage of project review.

CITY OF HUNTINGTON BEACH GUIDELINES

According to the City of Huntington Beach’s Historic and Cultural Resource Element of the General Plan, the following goal and policy are potentially relevant to the Project Area as they relate to the cultural resources:

• Goal HCR 1 To promote the preservation and restoration of the sites, structures and districts which have architectural, historical and/or archaeological significance to the City of Huntington Beach.

• Objective HCR 1.1 Ensure that all of the City’s historically and archaeologically significance to theCity of Huntington Beach

PALEONTOLOGY

The State of California Public Resources Code (Chapter 1.7), Sections 5097.5 and 30244, includes additional state level requirements for the assessment and management of paleontological resources. These statutes require reasonable mitigation of adverse impacts to paleontological resources resulting from development on state lands, define the removal of paleontological “sites” or “features” from state lands as a misdemeanor, and prohibit the removal of any paleontological “site” or “feature” from State land without permission of the jurisdictional agency. These protections apply only to State of California land, and thus apply only to portions of the Project, if any, which occur on State land.

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As defined by Murphey and Daitch (2007): “Paleontology is a multidisciplinary science that combines elements of geology, biology, chemistry, and physics in an effort to understand the history of life on earth. Paleontological resources, or fossils, are the remains, imprints, or traces of once-living organisms preserved in rocks and sediments. These include mineralized, partially mineralized, or unmineralized bones and teeth, soft tissues, shells, wood, leaf impressions, footprints, burrows, and microscopic remains. Paleontological resources include not only fossils themselves, but also the associated rocks or organic matter and the physical characteristics of the fossils’ associated sedimentary matrix.

The fossil record is the only evidence that life on earth has existed for more than 3.6 billion years. Fossils are considered non-renewable resources because the organisms they represent no longer exist. Thus, once destroyed, a fossil can never be replaced. Fossils are important scientific and educational resources because they are used to:

1. Study the phylogenetic relationships amongst extinct organisms, as well as their relationships to moderngroups;

2. Elucidate the taphonomic, behavioral, temporal, and diagenetic pathways responsible for fossilpreservation, including the biases inherent in the fossil record;

3. Reconstruct ancient environments, climate change, and paleoecological relationships;4. Provide a measure of relative geologic dating that forms the basis for biochronology and biostratigraphy,

and which is an independent and corroborating line of evidence for isotopic dating;5. Study the geographic distribution of organisms and tectonic movements of land masses and ocean basins

through time;6. Study patterns and processes of evolution, extinction, and speciation; and7. Identify past and potential future human-caused effects to global environments and climates.”

Fossil resources vary widely in their relative abundance and distribution and not all are regarded as significant. Vertebrate fossils, whether preserved remains or track ways, are classed as significant by most state and federal agencies and professional groups (and are specifically protected under the California Public Resources Code). In some cases, fossils of plants or invertebrate animals are also considered significant and can provide important information about ancient local environments. According to BLM IM 2009-011 a “Significant Paleontological Resource” is defined as: Any paleontological resource that is considered to be of scientific interest, including most vertebrate fossil remains and traces, and certain rare or unusual invertebrate and plant fossils.

Assessment of significance is also subject to the California Environmental Quality Act (CEQA) criterion that the resource constitutes a “unique paleontological resource or site.” A significant paleontological resource is considered to be of scientific interest if it is a rare or previously unknown species, it is of high quality and well-preserved, it preserves a previously unknown anatomical or other characteristic, provides new information about the history of life on earth, or has an identified educational or recreational value. Paleontological resources that may be considered not to have scientific significance include those that lack provenience or context, lack physical integrity due to decay or natural erosion, or that are overly redundant or are otherwise not useful for research. Vertebrate fossil remains and traces include bone, scales, scutes, skin impressions, burrows, tracks, tail drag marks, vertebrate coprolites (feces), gastroliths (stomach stones), or other physical evidence of past vertebrate life or activities (BLM, 2008).

The full significance of fossil specimens or fossil assemblages cannot be accurately predicted before they are collected, and in many cases, before they are prepared in the laboratory and compared with previously collected material. Pre-construction assessment of significance associated with an area or formation must be made based on previous finds, characteristics of the sediments, and other methods that can be used to determine paleoenvironmental conditions. A separate issue is the potential of a given geographic area or geologic unit to preserve fossils. Information that can contribute to assessment of this potential includes:

1. The existence of known fossil localities or documented absence of fossils nearby and in the same geologicunit (e.g. “Formation” or one of its subunits);

2. Observation of fossils within the Project vicinity;

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3. The nature of sedimentary deposits in the area of interest, compared with those of similar depositsknown elsewhere (size of particles, clasts and sedimentary structures conducive or non-conducive to fossilinclusion) that may favor or disfavor inclusion of fossils; and

4. Sedimentology details, and known geologic history, of the sedimentary unit of interest in terms of theenvironments in which the sediments were deposited, and assessment of the favorability of thoseenvironments for the probable preservation of fossils.

As so defined, significant paleontological resources are determined to be fossils or assemblages of fossils that are unique, unusual, rare, uncommon, or diagnostically important. Significant fossils can include remains of large to very small aquatic and terrestrial vertebrates or remains of plants and animals previously not represented in certain portions of the stratigraphy. Assemblages of fossils that might aid stratigraphic correlation, particularly those offering data for the interpretation of tectonic events, geomorphologic evolution, and paleoclimatology are also critically important (Scott and Springer 2003; Scott et al. 2004).

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BACKGROUND

ENVIRONMENTAL SETTING

The proposed Project Area is relatively flat, with elevations within the Project Area averaged 2.5 m (8.2 feet) above mean sea level (AMSL). Climate in the region is mostly sunny, dry and cool with cooler evenings due to the ocean breeze, with temperatures ranging 65° to 80° F (City of Huntington Beach 2017). Average annual precipitation in Huntington Beach is less than 12 inches, with most rainfall between December and March (City of Huntington Beach 2017).

Prior to major development activities after the turn of the century, the Project Area was mostly coastal wetlands that was encompassed in the Las Bolsas Spanish/Mexican land grant during 1850s (BLM GLO 2008). In modern times, the remaining section of coastal wetlands in the area makes up the Bolsa Chica Ecological Reserve, located approximately 6.5 miles north/northwest of the Project Area. This natural reserve is a home to numerous wildlife such as the Ridgway’s rail (Rallus obsoletus), Western snowy plover (Charadrius alexandrinus nivosus), osprey (Pandion haliaetus), coyotes (Canis latrans), cottontail rabbit (Sylvilagus audubonii), California legless lizard (Anniella stebbinsi) and over 60 species of marine life (Bolsa Chica Ecological Reserve 2017). Floral life in the coastal wetlands include rushes (Juncaceae), California sage (Artemisia californica), mule fat (Baccharis salicifolia), coyote bush (Baccharis pilularis) as well as California seablite (Suaeda californica), and coast woolly-heads (Nemacaulis denudate var. denudata) (Bolsa Chica Ecological Reserve 2017). Currently, the Project is a graded, vacant lot with a power plant (AES Corp) and Cenco oil tank farm located to the west, a landfill (Ascon) to the north and residential homes to the east (Mellen and Collins 2016).

PALEONTOLOGICAL SETTING

Located within the southwestern portion of the Los Angeles Basin, the City of Huntington Beach is part of a coastal plain that is underlain by geologic units consisting of the Peninsular Ranges and Geomorphic Province, characterized by Quaternary deposits of the Pleistocene epoch (11,000 to 1,600,000 years) through the Holocene epoch (less than 11,000 years) (Michael Baker International 2014). The Project Area is situated within the Newport-Inglewood fault zone, which is an active northwest trending fault system that extends 44 miles between Newport Beach on the south and Beverly Hills on the south (State of California- Department of Toxic Substances Control 2013: 35). Within the Project Area, the geotechnical study for the project describes a transition from shallow marine to coastal estuary (LGC Valley, Inc. Geotechnical Consulting 2017). In the Project Vicinity, these units are often derived as fluvial deposits from the Santa Ana River to the east, and within the Project Area, are mapped as younger Quaternary alluvium (McLeod 2017). While these deposits are usually devoid of significant vertebrate fossils within the uppermost layers, they are usually underlain by older Quaternary deposits that can contain significant vertebrate fossils (McLeod 2017).

PREHISTORIC CONTEXT

The prehistoric cultural chronology for the proposed Project Area is based on chronological information provided by Mason, Koerper and Langenwalter (1997) and Koerper, Mason and Peterson (2003). Three prehistoric periods are defined:

Milling Stone Period. The Milling Stone Period dates back well over 8,000-3,000 years before present (YBP) and is characterized by a generalized plant collecting economy supplemented by hunting and fishing. Regional interaction is limited when compared to later periods. Sites from this period appear to be part of an expansion of settlement to take advantage of new habitats and resources that became available as sea levels stabilized between about six to five thousand years ago. Gorges were used for fishing and mano/metate pairs were used to process plant materials. Most sites were in coastal areas. Around 3500 YBP, there was an economic shift to more reliance on hunting. Sites attributed to this period appear to have been occupied by small groups of people. This period persisted over thousands of years without great change (Mason et al. 1997 and Koerper et al. 2003).

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Intermediate Period. The Intermediate Period dates from roughly 3000-1000 YBP. Sites attributed to this time period indicate an increased reliance on coastal resources and with continued reliance on hunting and collecting. In addition, the advent of the bow and arrow, the appearance of increased quantities of bone tools, and increased reliance on the mortar and pestle, typify this time period. The first circular fish hooks appear in the tool kit in this period and use of plant grinding tools increases. Hunting tools consist of the atlatl and dart. Most sites were in coastal areas (Mason et al. 1997 and Koerper et al. 2003).

Late Prehistoric Period. The period dates from 1, 350 YBP to 150 YBP and is characterized by an increasing political-economic-social complexity. Villages tend to be larger, with a more varied assemblage, and there appears to be an increase in smaller satellite sites, established to support the main village, and reflecting seasonal use of a particular area. There seems to be more intensive exploitation of localized resources, and social contacts and economic influences appear accelerated through trade and social interaction. There is an increase in the number of sites in the area, which are interpreted as a result of population increase. The Late Period was a time when there are a greater number of more specialized sites in terms of their location and function, and an amplification of all aspects of the cultural system. In this period the atlatl and dart hunting tools are replaced by the bow and arrow. In addition, manos/metates were gradually replaced by pestle/mortars. Use of other traditional tools continued. Settlement was expanded into the hills and canyons inland (Mason et al. 1997 and Koerper et al. 2003).

ETHNOGRAPHY

Ethnographic records identify the lands surrounding the project area as being inhabited by the Gabrielino, at the time of contact by Europeans. After European contact, many Gabrielino were induced to live at Mission San Gabriel. Groups became known by the names of missions built in their territories. The Gabrielino suffered population decline due to introduced diseases and restrictions on their native reproductive practices by the padres (McCawley 1996). Most mission Indians were trained as vaqueros, sheepshearers, farm laborers and domestic laborers and continued in those professions after the mission were secularized (Talley 1984). Later in time, other Native Americans, now known as the Juaneño (Acjachemen) moved into southern Orange County and are likely to have also used the Project Area at some points in time. Material culture was very similar between these two groups but the Juaneño were known to produce Tizon brownware ceramics which might differentiate sites (Belcourt et al 2014).

The Tongva (Gabrielino) inhabited the entire Los Angeles basin including most of Orange County. The name “Gabrielino” is Spanish in origin and was used in reference to the Native Americans associated with the Mission San Gabriel. It is unknown what these people called themselves before the Spanish arrived, but today they call themselves “Tongva”, meaning “people of the earth”.

Villages were comprised of 50-100 people. Each community included one or more patrilineal extended families or lineal kinship groups (clans) (Kroeber 1976, Johnson 1962, Bean and Smith 1978, McCawley 1996). Each village was united under the leadership of a chief who inherited the position from his father. The chief was the leader of the religious and secular life of the community and served as chief administrator, fiscal officer, war leader, legal arbitrator and religious leader (Harrington 1942, Bean and Smith 1978). The chief was assisted by a Council of Elders consisting of the heads of the lineages residing in the community. Shamans were also important as doctors, therapists, philosophers and intellectuals (Bean 1974).

The Gabrielino tribe carried out food exploitation strategies that utilized local resources ranging from plants to animals; coastal resources were also exploited. Rabbit and deer were hunted and acorns, buckwheat, chia, berries, fruits and many other plants were collected. Artifacts associated with their occupations include a wide array of chipped stone tools including knives and projectile points, wooden tools like digging sticks and bows, and ground stone tools like bedrock and portable mortars, metates and pestles. Local vegetation was used to construct shelters as well as for medicinal purposes. Cooked foods were prepared on hearths (Kroeber 1976, Bean and Smith 1978, McCawley 1996).

Acorns were one of the most important food resources utilized by the Gabrielino and other Native American groups across California. The acorns were ground into a fine powder in order to make an acorn mush or gruel. A dietary staple, acorns provided a large number of calories and nutrients. The ability to store and create stockpiles

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in case of lean times also contributed to the importance of acorns as a vital natural resource. Much of the material evidence available to archaeologists concerning the Gabrielino is a result of tools and technologies related to their subsistence activities.

The nearest Gabrielino community to the city of Los Alamitos is the Povuu’nga community located along the San Gabriel River within the coastal region, approximately one mile from the project area. It is one of three important Gabrielino communities within the region and was founded by refugees from the San Gabriel area. Povuu’nga most likely served as a ritual center for the Gabrielino communities of the area based on the description given by Father Geronimo Boscana. Povuu’nga was descriped as the birthplace of both Wewyoot, the first tomyaar, and the creator-god and spiritual being Chengiichngech (McCawley 1996). Povuu’nga is likely located on a hilltop site occupied by historic Rancho Los Alamitos in the city of Long Beach. The community existed until at least 1805 based on baptismal records from the San Gabriel mission and the San Juan Capistrano mission.

HISTORICAL SETTING

While indigenous peoples adapted (and thrived) to environmental conditions in what is now “California,” those same lands remained isolated from European and Asian cultures until the early-sixteenth century. In 1521, Spain sent explorer and conquistador Hernan Cortes and his army into what is now Mexico to conquer the indigenous Aztecs and capture the wealth of the land and its people. “New Spain,” as the region soon became known, quickly became the hub of Spanish colonial efforts in the New World. Cortes, hopeful of finding comparable wealth in the northern Pacific, authorized the first explorations, and in 1535, founded the first nonnative settlement in Baja (or Lower) California. Inspired by Cortes’ success in the New World and hoping to find a waterway from the Pacific to the Atlantic, the Spanish dispatched Juan Rodriguez Cabrillo in 1542 to explore the northwest coast of New Spain. It is believed that Cabrillo sailed as far north as the Oregon border, and that he became the first European to see what was then termed “Alta (or Upper) California” (Paddison 1999: xi).

In 1602, the Spanish Crown ordered Sebastian Vizcaino to make the first detailed survey of the Alta California coast. Vizcaino eventually anchored at Monterey Bay, and in subsequent reports to Spain, greatly exaggerated the quality of the natural harbor he found (Paddison 1999: xii). Despite Vizcaino’s inflated recommendations, it took the Spanish almost 170 years to act. The so-called “Sacred Expedition” of 1769, led by Spaniard Gaspar de Portola and Franciscan Fray (or Father) Junipero Serra, was meant to begin the permanent settlement of Alta California, beginning in San Diego. The plan called for the Spanish to converge on San Diego by land and sea, and to use the newly established San Diego settlement as a base to begin further colonization and mission-building activities along the California coast.

When the expedition of Spaniards, led by Gaspar De Portola, arrived to explore and colonize Upper California in 1769, they found the land marked by many Indian villages, or “rancherias,” containing from 500 to 1500 huts, in the area which later became Los Angeles and Orange Counties. The Portola expedition consisted of colonists to settle in selected pueblos or towns; missionaries to convert the natives and prepare them to become “civilized” enough to assume control of the land which the missions held in trust for the Indians; and, soldiers to establish military strong points or “presidios” to protect both groups, as well as to keep foreign interests such as Russia or England from invading lands claimed by Spain.

During the Spanish Period of California, the Project Area was part of a large land grant owned by Jose Manuel Nieto. In 1834, Rancho Las Bolsas, which covered 21 square miles that included present day Huntington Beach, Westminster, and Garden Grove, was granted to Catarina Ruiz, widow of Jose Antonio, son of Jose Manuel Nieto (Galvin Preservation Associates Inc 2014). After Mexican independence in California, a smaller land grant, approximately 6 square miles, called Rancho La Bolsa Chica, was partitioned by Mexican Governor Jose Figueroa and granted to Joaquin Ruiz in 1841 (Galvin Preservation Associates Inc 2014). By the late 1800s, the land ownership of Las Bolsas and La Bolsa Chica was transferred to the Stearns Rancho Company, with no buildings or structures representing this period currently known to existing within the Project Area (Galvin Preservation Associates Inc 2014).

From the late 1800s into the 1940s, the general area of Huntington Beach was populated by agriculture and ranching settlements, including those populated by Japanese immigrants. During the early 1900s, development of

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a beach town resort was successful, with the beach and pier in Huntington Beach’s Downtown area offering entertainment for tourists in the area. The oil industry boomed in Huntington Beach from 1920-1950, which lead to new subdivisions developed for oil workers and their families to live in, establishing modest residential homes intermixed with oil wells and changing the cultural landscape of the area from agricultural-based to industrial-based (Galvin Preservation Associates Inc 2014). Another culture associate with Huntington Beach is the surf culture, which has become a commercial business and way of life in the area since the 1950 (Galvin Preservation Associates Inc 2014). Surfing events are held annually within Huntington Beach and other regional beaches and the culture has become a mainstream way of life.

Specifically within the Project Area, examination of historic topographic maps and aerials indicate that prior to the 1950s, the area was mainly submerged marsh/swamp land with a river south of the Project Area and smaller streams northwest of the area (earliest map from 1896). During the 1950s, there was an unpaved landing runway labeled “Huntington Beach Airport” within the Project Area and emergence of secondary highways in the area. From 1972 until 2009, the Project Area was used as a fuel oil storage facility with three aboveground, 45-foot tall, 25-million-gallon fuel storage tanks, and other oil-related infrastructure including roads, pipelines and ancillary buildings. The oil storage tanks provided fuel for the adjacent power generating facility (now owned by AES Southland) until that facility was converted to an all-natural gas facility in the 1990s. The tanks have since been removed and the site is now being used as a construction staging area for the redevelopment of the AES Southland power generation facility.

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METHODS

CALIFORNIA HISTORIC RESOURCES INVENTORY SYSTEM AND CULTURAL BACKGROUND RESEARCH

A search for archaeological and historical records was conducted by MCC Archaeologist Sonia Sifuentes at the South Central Coastal Information Center (SCCIC) of the California Historical Resources Inventory System (CHRIS), located at California State University Fullerton, on July 24, 2017. The record search included a 1-mile radius around the Project Area, as well as the Project Area itself. In addition to the records at the SCCIC, a variety of sources were consulted by Sonia Sifuentes in August 2017 to obtain information regarding the cultural context of the Project Area (See Table 1).

NATIVE AMERICAN OUTREACH AND BACKGROUND RESEARCH

A sacred lands record search was requested by Material Culture from the Native American Heritage Commission (NAHC) on August 9, 2017. The Commission responded on August 23, 2017, stating that there are no known/known sacred lands within a one-half mile of the Project Area. The NAHC requested that ten Native American tribes or individuals be contacted for further information regarding the general Project vicinity. Material Culture Consulting subsequently sent letters to the ten Native American contacts on August 24, 2017, requesting any information related to cultural resources or heritage sites within or adjacent to the Project Area. Additional attempts at contact by letter, email or phone call were made on September 1 and September 7, 2017.

PALEONTOLOGICAL RECORDS SEARCH

A search for paleontological records was completed by staff of the Natural History Museum of Los Angeles County (LACM) in Los Angeles, on August 17, 2017. The record search included a 1-mile radius around the Project Area, as well as the Project Area itself. Based on the review of several geology maps from the region, the geologic unit underlying the Project Area is mapped as younger Quaternary Alluvium, derived as fluvial deposits from the Santa Ana River that currently flows to the east (McLeod 2017) with most of the area is young alluvial fan arenaceous deposits (Qyfa) with the most southern portion within young axial channel silt deposits (Qyas) and small southwestern portion within Eolian deposits (Qe), all within late Holocene epoch (Morton 2004). The closest fossil vertebrate localities from similar deposits is LACM 7366, west-northwest of the proposed project area north of the Pacific Coast Highway that produced specimens of marine, freshwater, and terrestrial speciemens including leopard shark (Triakis), three-spined stickleback (Gasterosteus), garter snake (Thamnophis), desert shrew (Notiosorex) and pocket gopher (Thomomys) (McLeod 2017). Further away from the Project Area but still realtively nearby, there is a series of vertebrate fossil localities, LACM 7422-7425, which produced fossil specimens of mammoth (Mammthus), bison (Bison), and horse (Equus), as well as locality LACM 7679 which produced freshwater and terrestrial fossil vertebrates including three-spine stickleback (Gasterosteus aculeatus), western toad (Bufo Boreas), pacific treefrog (Hyla regilla), arboreal salamander (Aneides lugubris), slender salamander (Batrachoseps), lungless salamander (Ensatina), western pond turtle (Clemmys marmorata), southern alligator lizard (Gerrhonotus multicarinatus), legless lizard (Anniella pulchra), fence lizard (Sceloporus), side-blotched lizard (Uta stansburiana), ringneck snake (Diadophis punctatus), kingsnake (Lampropeltis getulus), coachwhip (Masticophis), gopher snake (Pituophis melanoleucus), long-nosed snake (Rhinocheilus lecontei), garter snake (Thamnophis), scaled quail (Callipepla squamata), virginia rail (Rallus limicola), ornate shrew (Sorex ornatus), broad-footed mole (Scapanus latimanus), brush rabbit (Sylvilagus bachmani), meadow vole (Microtus californicus), wood rat (Neotoma), deer mouse (Peromyscus maniculatus), harvest mouse (Reithrodontomys megalotis), pocket gopher (Thomomys), pacific kangaroo rat (Dipodomys agilis), and squirrel (Eutamias) (McLeod 2017). None of the above mentioned fossil localities documented the depths of recovery, thus their depths are unknown.

FIELD SURVEY

The survey stage is important in a Project’s environmental assessment phase to verify the exact location of each identified cultural or paleontological resource, the condition or integrity of the resource, and the proximity of the resource to areas of cultural resources sensitivity. In addition, the field survey provides invaluable information on the type of sediment present within the Project Area, which informs the assessment of paleontological sensitivity. Judy Bernal, archaeologist and cross-trained paleontologist, conducted the survey of the proposed Project Area on

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August 8, 2017. The survey consisted of walking in parallel transects spaced at approximately 15-meter intervals over the Project parcel, while closely inspecting the ground surface.

All undeveloped ground surface areas within the ground disturbance portion of the Project Area were examined for artifacts (e.g., flaked stone tools, tool-making debris, stone milling tools or fire-affected rock), soil discoloration that might indicate the presence of a cultural midden, soil depressions and features indicative of the former presence of structures or buildings (e.g., postholes, foundations), or historic-era debris (e.g., metal, glass, ceramics). Existing ground disturbances (e.g., cutbanks, ditches, animal burrows, etc.) were visually inspected. Representative photographs were taken of the entire Project Area.

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RESULTS

CALIFORNIA HISTORIC RESOURCES INVENTORY SYSTEM AND CULTURAL BACKGROUND RESEARCH

The records search indicates twelve cultural resources investigations have been completed previously within a 1-mile radius of the Project Area and four investigations cover the entire Project Area itself (See Table 3). The results of the records searches indicate while there are no known archaeological resources within the Project Area, there are two known archaeological resources within a 1-mile radius of the Project Area (See Table 2). Review of additional sources also resulted in negative findings (See Table 3, below). Historic aerials depict the years of development of the property from 1938 use as an agricultural area, to 1963 as a graded area, and 1972 where the tanks are first visible (Figures 4-6).

Table 1. Additional Sources Consulted for the Project

Source Results

National Register of Historic Places (1979-2002 & supplements) Negative

Historical United States Geological Survey topographic maps (USGS 2012)

Negative

Historical United States Department of Agriculture aerial photos Negative

California Register of Historical Resources (1992-2010) Negative

California Inventory of Historic Resources (1976-2010) Negative

California Historical Landmarks (1995 & supplements to 2010) Negative

California Points of Historical Interest (1992 to 2010) Negative

Local Historical Register Listings Negative

Bureau of Land Management General Land Office Records Negative

Table 2. Previous Resources within 1-mile Buffer of Project Area

Primary Number

Trinomial Age Attributes NRHP/CRHR Proximity to API

P-30-001532

Prehistoric AP16-Other (shell scatter) Unknown 1/2-mile

P-30-176946

Historic HP11-Engineering Structure Ineligible 1/4-mile

Table 3. Previous Conducted Resource Investigations within 1-mile Buffer of Project Area

CHRIS Report Number

Author(s) Year Report Title Affiliation

OR-00001 Ahlering, Michael L. 1973 Report of a Scientific Resources Survey and Inventory: Conducted for the City of Huntington Beach, California

Archaeological Research, Inc

OR-00270 Leonard, Nelson N. III and Matthew C. Hall

1975 Description and Evaluation of Cultural Resources Within the US Army Corps of Engineer’s Santa Ana River Project

Archaeological Research Unit, UC Riverside

OR-00801 Langenwalter, Paul E. and James Brock

1985 Phase I Archaeological Studies Prado Basin and the Lower Santa Ana River

N/A

OR-00880 Padon, Beth 1987 A Cultural/Scientific Assessment of the Waterfront Project City of Huntington Beach, County of Orange

LSA Associates, Inc

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CHRIS Report Number

Author(s) Year Report Title Affiliation

OR-02033 Mason, Roger D. 1987 Research Design for Evaluation of Coastal Archaeological Sites in Northern Orange County, California

Scientific Resource Surveys, Inc.

OR-02134 Lapin, Philippe 2000 Cultural Resource Assessment for Pacific Bell Wireless Facility CM 294-12, County of Orange

LSA Associates, Inc

OR-02229 Duke, Curt 2000 Cultural Resource Assessment for the AT&T Wireless Services Facility Number C871.2, County of Orange, California

LSA Associates, Inc

OR-02256 Demcak, Carol R. 1999 Cultural Resources Assessments for Orange County Sanitation Districts

Archaeological Resource Management Corp.

OR-02456 Hoover, Anna M. 2000 Cultural Resources Literature and Records Review for the Southeast Coastal Industrial Area Redevelopment Project, Huntington Beach, California

RMW Paleo Associates, Inc.

OR-03450 Bonner, Wayne H. 2007 Cultural Resource Records Search and Site Visit Results for Royal Street Communications, LLC Candidate La2739a (Magnolia & Hamilton), West of Magnolia Street on Hamilton Avenue, Huntington Beach, Orange County, California

Michael Brandman Associates

OR-03582 Losee, Carolyn 2009 Cultural Resources Investigation for T-Mobile LA33422A “Landmark Liquor” 8491 Atlanta Avenue, Huntington Beach, Orange County, California 92646

Archaeological Resources Technology

OR-03614 Mason, Roger D. 2003 Cultural Resources Records Search and Field Survey Report for a Verizon Telecommunications Facility: Magnolia in the City of Huntington Beach, Orange County, California

Chambers Group, Inc.

OR-03678 Bonner, Wayne H. 2007 Cultural Resources Records Search and Site Visit Results for Royal Street Communications, LLC Candidate LA2526D (Presbyterian Church), 225 West Main Street, Tustin, Orange County, California

Michael Brandman Associates

OR-03842 Brown, Joan and Patrick Maxon

2010 Phase 1 Cultural Resources Assessment for the Poseidon Seawater Desalination Project, Huntington Beach, Orange County, California

BonTerra Consulting

OR-04152 Ehringer, Candace 2011 Outfall Land Section and Ocean Outfall Booster Pump Station Piping Rehabilitation Project, Phase I Cultural Resources Assessment

ESA

OR-04313 N/A 2013 Historic and Cultural Resources Element- Huntington Beach

City of Huntington Beach

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Figure 4. Project Area (depicted on 1938 aerial photograph)

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Figure 5. Project Area (depicted on 1963 aerial photograph showing area cut/filled for tanks)

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Figure 6. Magnolia Tank Farm Project Area (depicted on 1972 aerial photograph – first visual presence of tanks)

PREVIOUSLY RECORDED RESOURCES WITHIN 1-MILE BUFFER

There are two previously recorded resources within the 1-mile buffer of the Project Area. The first, P-30-001531, is recorded as a prehistoric shell midden consisting of approximately 100 shell fragments (Chione spp., Pecten spp., Turritella spp., and Haliotis spp.), none of which were diagnostic. No associated artifacts were observed at time of recording. Additional studies within the area with observations of shell fragments lacking any additional artifacts have determined such deposits are not the result of human activity and are instead naturally occurring (Department of Toxic Substances Control 2013: 30). It has also been concluded that any potential prehistoric settlements during the late Pleistocene and early Holocene in the general region may have been submerged by rising sea levels during the early and middle Holocene (California State Lands Commission 2017).

The second resource, P-30-176946, is recorded as four fuel oil tanks. This resource has no association with events that have made a significant contribution to the history of the area, Huntington Beach, Orange County, or the State. It has no association with any persons important locally, regionally or statewide and has no significance for

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its design or physical qualities; it has thus been found ineligible for listing for CRHR and NRHP (Brown and Maxon 2009). There are already proposed plans to replace these tanks for the Poseidon Seawater Desalination Project (Brown and Maxon 2009).

NATIVE AMERICAN OUTREACH AND BACKGROUND RESEARCH

On September 1, 2017, an Material Culture conducted a phone interview with Andrew Salas and Matt Teutimez of the Gabrieleño Band of Mission Indians – Kizh Nation. During this phone interview, the Tribe highlighted a number of key historical interests and cultural significance that the area where the Project Area is located. This included several prominent known villages within the area such as Lukupangna, Moyogna, Kenyaangna, and Motuucheyngna; past historical topographical maps depict a potential natural spring located southwest of the Project Area (marked as Water Tank in modern maps), which would have been in close proximity of the shoreline and would have held spiritual/ceremonial significance to the Tribe; Historical maps also depicts the area as part of an upland area within the marshland environment, which would have been used not only as access routes, but would have been an overhang for the neighboring villages that would have been a good source for foraging/hunting activities year-round; and lastly, development during the 1950s would have most likely used local of nearby fill to replace the marsh environment and such fill could hold secondary depositions of cultural artifacts that would still hold cultural significance to the tribe. Based on all of these points, the Kizh Nation recommends monitoring, spot checking at minimum, with both Archaeologist and Native American Monitor during ground disturbance activities. On September 1, 2017, Joyce Perry of Juaneño Band of Mission Indians Acjachemen Nation- Belardes left a voice message stating that the Tribe has no concerns to the Project Area and defers to closer tribes.

As of September 8, 2017, no additional groups or individuals have responded with information about the Project Area. Material Culture Consulting did not conduct consultation with the Native American representatives as per AB52. All written NAHC and Native American correspondence materials and our communication log are provided as Appendix B.

PALEONTOLOGICAL RECORDS SEARCH

The record search results from the LACM (Appendix C) do not indicate any fossils have been found directly within the Project Area, nor within 1 mile of the Project. The geologic unit underlying this Project is mapped as younger Quaternary Alluvium, derived as fluvial deposits from the Santa Ana River that currently flows to the east (McLeod 2017) with most of the area is young alluvial fan arenaceous deposits (Qyfa) with the most southern portion within young axial channel silt deposits (Qyas) and small southwestern portion within Eolian deposits (Qe), all within late Holocene epoch (Morton 2004). Shallow excavations within these deposits will most likely not uncover significant vertebrate fossil remains; however deeper excavations in the proposed Project Area could extend into possible underlying older Quaternary deposits that may contain significant vertebrate fossils. LACM has the nearest recorded fossil localities from similar older Quaternary deposits is north-northwest and have produced fossils including marine, freshwater and terrestrial species at undocumented depths. LACM has suggested any substantial excavations in underlaying, older sedimentary deposits of the Project Area should be closely monitored to recover any fossil remains discovered, as well as sediment samples be collected and processed to determine the small fossil potential (McLeod 2017).

CULTURAL AND PALEONTOLOGICAL FIELD SURVEY

During the course of fieldwork, survey conditions were very good and ground visibility averaged good (80- 95%) throughout most of the 29-acre Project Area. Vegetation cover was almost non-existent due to recent grading activities with the removal of the oil tanks previously onsite. A dense concentration of unidentifiable marine shells and shell fragments was observed throughout approximately 50% of the Project Area, mostly within the western and northwestern portions of the Project Area. While concentrations of shell may indicate presence of prehistoric cultural deposits and/or middens, nearby studies, including the one conducted for Ascon Landfill site, discussed similar findings near the Project Area. These previous studies only observed shell without any other evidence of human activity or cultural material associated with the shells (State of California- Department of Toxic Substances Control 2013: 30) and were interpreted as naturally occurring deposits.

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It is also noted that the Project Area is located adjacent to a Pleistocene marine terrace with deposits of soil and shell similar to those observed in the Project Area (State of California- Department of Toxic Substances Control 2013: 30). Aerial photographs depict the area being developed from an estuary ecozone to development of the tank yards, which indicate that these terraces may have been excavated used as artificial fill in these portions of the Project Area. According to the geotechnical report (LGC Valley, Inc. Geotechnical Consulting 2017), fill is anticipated to extend 2.5 feet below surface throughout the site, with the exception of the surrounding containment berms, where fill extends to 8 feet below surface. Based on these findings and those of the previous studies, it is believed that this shell scatter is natural and not cultural. No significant cultural or paleontological resources were identified during the survey. Representative photos of the area and the shells were taken (Figures 7-10).

Figure 7. Project Overview from entrance of site (View West)

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Figure 8. Project Overview from most Southern area (View North)

Figure 9. Project Overview from West stockpile (View North)

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Figure 10. Representative photo of shells observed in Project Area (likely derived from fill soils used at the site)

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CONCLUSIONS AND RECOMMENDATIONS

CULTURAL RESOURCES CONCLUSIONS

The Project Area is considered to have a moderate to high sensitivity for the presence of prehistoric or historical archaeological deposits or features. Although no archaeological resources have been recorded within the Project Area, and the surface of the Project Area is covered in imported fill soils, the general region and coastal setting has evidence of dense Native American occupation with previously recorded resources within the 1-mile Project Area buffer. In addition, several prominent village sites and significant cultural resources have been found in close proximity to the project, even within densely populated and modern urban settings. The cultural sensitivity of the Huntington Beach coastal area is well documented. While the presence of the shell within the Project Area is most likely not cultural, there is still a high probability this assumption could change with the discovery of cultural materials discovered during ground disturbance activities. The only development at the site appears to be the construction of three water tank facilities. Therefore, subsurface sediment and matrix are anticipated to be intact deposits, which could reveal significant cultural resources that have not been previously disturbed in the modern era.

CULTURAL RESOURCES RECOMMENDATIONS

Based on the results of the cultural resources records search and survey, and our knowledge of the existing resources in the area, there is a moderate chance that crews could encounter significant cultural resources during the course of Project development. In order to mitigate potential significant impacts to nonrenewable cultural resources, as required by State and County regulations, we recommend the following procedures:

• During the initial vegetation removal and rough grading of the site, we recommend full time culturalresources monitoring by an Orange County Qualified Archaeologist. The current anticipation of verticalground disturbance is approximately 5 feet below surface. Fill is expected to extend up to 2.5 feet belowsurface, but this could fluctuate throughout the Project Area. Excavations below five feet in depth arelikely to reach below the soil horizon where cultural resources are typically located, especially in coastalsettings such as the Project Area. The Project Archaeologist, in coordination with the City of HuntingtonBeach, may re-evaluate the necessity for monitoring after the initial five feet of excavations have beencompleted, if work is anticipated to extend deeper than current project plans.

• In the event that resources are discovered during ground-disturbing activities, work must be halted within50 feet of the find until it can be evaluated by a qualified archaeologist. Construction activities couldcontinue in other areas. If the discovery proves to be significant, additional work, such as data recoveryexcavation, may be warranted and would be discussed in consultation with the appropriate regulatoryagency(ies).

• Any potentially significant artifacts, sites or features observed shall be collected and recorded inconjunction with best management practices and professional standards. Any cultural items recoveredduring mitigation should be deposited in an accredited and permanent scientific institution for the benefitof current and future generations.

• A report documenting the results of the monitoring efforts, including any data recovery activities and thesignificance of any cultural resources will be prepared and submitted to the appropriate City and Countypersonnel.

• Procedures of conduct following the discovery of human remains on non-federal lands have beenmandated by California Health and Safety Code §7050.5, PRC §5097.98 and the California Code ofRegulations (CCR) §15064.5(e). According to the provisions in CEQA, should human remains beencountered, all work in the immediate vicinity of the burial must cease, and any necessary steps toinsure the integrity of the immediate area must be taken. The Orange County Coroner will be immediatelynotified. The Coroner must then determine whether the remains are Native American. If the Coronerdetermines the remains are Native American, the Coroner has 24 hours to notify the NAHC, who will, inturn, notify the person they identify as the most likely descendent (MLD) of any human remains. Furtheractions will be determined, in part, by the desires of the MLD. The MLD has 48 hours to makerecommendations regarding the disposition of the remains following notification from the NAHC of the

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discovery. If the MLD does not make recommendations within 48 hours, the owner shall, with appropriate dignity, reinter the remains in an area of the property secure from further disturbance. Alternatively, if the owner does not accept the MLD’s recommendations, the owner or the descendent may request mediation by the NAHC.

PALEONTOLOGICAL RESOURCES CONCLUSIONS

This study reviews definitions of paleontological significance and definitions for rock units that have high potential and high sensitivity for the presence of nonrenewable paleontological resources. The results of the records search and field surveys conducted for this Project show younger Quaternary Alluvium deposits present on the surface within the Project Area. The potential for older Quaternary sedimentary deposits of moderate paleontological sensitivity underlaying the surface deposits and the presence of numerous LACM fossil collection localities from similar deposits in the vicinity of the project site suggest the potential for construction of the proposed project to result in impacts to paleontological resources.

PALEONTOLOGICAL RESOURCES RECOMMENDATIONS

No significant paleontological resources were identified within the Project Area during the locality search or field survey. However, the records search results indicating that significant fossils have been found in similar and adjacent geologic formations in the area, and may be found at an unknown depth greater than five feet below surface within the Project boundaries. In order to mitigate potential adverse impacts to nonrenewable paleontological resources, as required by State and County regulations, we recommend the following procedures:

• At this time, excavation is only planned to extend to a depth of five feet, so paleontological impacts are not anticipated. However, a Qualified Orange County Paleontologist should perform paleontological monitoring of any ground disturbing activities impacting native soils at a depth greater than five feet below surface. The monitor will have the ability to redirect construction activities to ensure avoidance of significant impacts to paleontological resources. The Project Paleontologist, in coordination with the City of Huntington Beach, may also re-evaluate the necessity for monitoring after the initial five feet of excavations have been completed.

• Any potentially significant fossils observed shall be collected and recorded in conjunction with best management practices and SVP professional standards.

• Any fossils recovered during mitigation should be deposited in an accredited and permanent scientific institution for the benefit of current and future generations.

• A report documenting the results of the monitoring, including any salvage activities and the significance of any fossils will be prepared and submitted to the appropriate Lead Agency personnel.

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REFERENCES

Bean, L. J. 1974 “Social Organization in Native California”. In 'Antap: California Indian Political and Economic Organization, edited by L. Bean and T. King, pp. 13–34. BP-AP No. 2, L. J. Bean, Series Editor. Ramona, California: Ballena Press.

Bean, L.J. and C.R. Smith 1978 “Gabrielino.” In Handbook of North American Indians, Volume 8. California. Volume edited by Robert F. Heizer, pp. 538-549 (W. T. Sturtevant, general editor). The Smithsonian Institution, Washington, D.C. Belcourt, T., C. Richards, and S. Gust 2014 Cultural Resources Assessment for the Lake House Residential Project, City of Anaheim, California.

Prepared by Cogstone Resource Management, Inc., Orange, CA.

Bureau of Land Management (BLM) 2016 Potential Fossil Yield Classification (PFYC) System for Paleontological Resources on Public Lands.

Instruction Memorandum No. 2016-124. Released July 20, 2016 BLM GLO (Bureau of Land Management Government Land Office) 2008 Land Grant Records Search Tool. Retrieved: http://www.glorecords.blm.gov/PatentSearch/Default.asp.

Accessed August 25, 2017. Brown, J.C. and P.O. Maxon 2009 Phase I Cultural Resources Assessment for the Poseidon Seawater Desalination Project, Huntington Beach,

Orange County, California. Prepared for RBF Consulting. California Department of Fish and Wildlife 2017 Bolsa Chica Ecological Reserve. Retrieved: https://www.wildlife.ca.gov/Lands/Places-to-Visit/Bolsa-Chica-

ER#9948266-species. Accessed August 25, 2017. California State Lands Commission 2017 Part III – Final Supplemental EIR: Final Supplemental Environmental Impact Report for the Seawater

Desalination Project At Huntington Beach: Outfall/Intake Modifications & General Lease – Industrial Use (PRC 1980.1) Amendment (State Clearinghouse No. 2001051092), October 2017.

City of Huntington Beach 2017 Climate Retrieved: http://www.huntingtonbeachca.gov/about/climate/ Accessed August 25, 2017 Cooper, J. D. and P.J. Eisentraut 2002 Orange County Archaeo/Paleo Curation Guidelines, Procedures and Policies - Draft Document. Prepared

for County of Orange, Board of Supervisors. Department of Toxic Substances Control 2013 Initial Study Remedial Action Plan for Ascon Landfill Site, Ascon Landfill Site, Huntington Beach, California.

Prepared for Southern California Cleanup Operations Branch. Galvin Preservation Associates Inc. 2014 City of Huntington Beach Historic Context and Survey Report. Prepared for City of Hunting Beach Planning

and Building Department.

Harrington, J. P. 1942 Culture Element Distribution XIX: Central California Coast. University of California Anthropological Records

(1).

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Johnson, B. E. 1962 “California’s Gabrielino Indians”. Fedrick Webb Hodge Anniversary Fund Publication No. 8, Southwest

Museum, Los Angeles. Koerper, H., Mason, R., and Peterson, M. 2003 “Complexity, Demography and Change in Late Holocene Orange County”. In Erlandson, J. and T. Jones

(eds), Catalysts to Complexity: The Late Holocene on the California Coast. Perspectives in California Archaeology, Institute of Archaeology, University of California, Los Angeles.

Kroeber, A.L. 1976 Handbook of Indians of California. Reprint of 1925 original edition, Dover Publications, New York. LGC Valley, Incorporated 2017 Geotechnical Study for the Preparation of an Environmental Impact Report for the Proposed Development

Located at 21845 Magnolia Street within the City of Huntington Beach, California. Mason, R., Koerper, H., and Langenwalter, P. 1997 “Middle Holocene adaptations on the Newport Coast of Orange County”. In Erlandson, J. and M. Glassow,

Archaeology of the California Coast during the Middle Holocene, Perspectives in California Archaeology, Institute of Archaeology, University of California, Los Angeles

Mellen, G. and J. Collins 2016 “$500 million project plans to turn Huntington Beach oil tank farm into housing, businesses.” Orange

County Register August 24, 2016: Web. August 25, 2017. McCawley, W. 1996 First Angelinos: The Gabrielino Indians of Los Angeles. Malki Museum Press/Ballena Press, Banning, CA.

McLeod, S.A 2017 Paleontological Records Search-Huntington Beach Tank Project. Natural History Museum of Los Angeles

County. Moratto, M.J. 1984 California Archaeology. San Diego: Academic Press. Morton, D.M 2004 Preliminary Digital Geological Map of the Santa Ana 30’ x 60’ Quadrangle, Southern California. Retrieved:

https://pubs.usgs.gov/of/1999/of99-172/. Accessed August 30, 2017. Murphey, P.C. and D. Daitch, 2007 Paleontological Overview of Oil Shale and Tar Sands Areas in Colorado, Utah and Wyoming: U.S.

Department of Energy, Argonne National Laboratory Report. Prepared for the U.S. Department of Interior Bureau of Land Management, 468 pp. and 6 maps (scale 1:500,000).

Orange County 2011 Orange County General Plan Resources Element. Available online at:

http://ocplanning.net/planning/generalplan2005

Paddison, J., Ed. 1999 A World Transformed: Firsthand Accounts of California before the Gold Rush. Berkeley: Heyday Books,

1999.

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State of California- Department of Toxic Substances Control 2013 Initial Study Remedial Action Plan for Ascon Landfill Site, Ascon Landfill Site, Huntington Beach, California.

Prepared for State of California- California Environmental Protection Agency.

Scott, E. and K. Springer 2003 CEQA and Fossil Preservation in Southern California. The Environmental Monitor, Winter: 4-10, 17. Scott, E., K. Springer, and J. C. Sagebiel 2004 “Vertebrate Paleontology in the Mojave Desert: The Continuing Importance of “Follow-Through” in

Preserving Paleontological Resources” in The Human Journey and Ancient Life in California’s Deserts, Proceedings from the 2001 Millennium Conference, M. W. Allen and Reed, J. editors: 65-70.

Society of Vertebrate Paleontologists (SVP) 2010 Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources.

Online: http://vertpaleo.org/PDFS/68/68c554bb-86f1- 442f-a0dc-25299762d36c.pdf

Talley, R. Paige 1984 Prehistory and History Ethnographic Summary. Addendum to Eastern Corridor Alignment Study, Orange

County, California. R. D. Mason. Scientific Resource Surveys, Inc. On file, South Central Coastal Information Center, Report Number O-752.

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Appendix A:

Qualifications

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Tria Belcourt, M.A., RPA

Consultant III – Senior Archaeologist and Principal Investigator

Tria is the President of Material Culture Consulting, Inc., and is a qualified environmental project manager and Registered Professional Archaeologist. She brings twelve years of professional experience in the consulting industry along with long-standing personal and professional relationships with multiple utility sector clients and state/federal regulatory agencies. She is a recognized NEPA and CEQA regulatory expert and is highly regarded as an excellent writer of legally defensible technical documents, plans and reports. She is listed as the company’s Principal Investigator on California and Nevada statewide and regional BLM CRUPs and has held multiple ARPA permits in various regions for work on federal lands such as military installations, national parks, national forests, and national monuments. Regional experience includes California, Nevada, the Great Basin, and the Southeastern United States. Sector experience includes: in-depth expertise with California publicly regulated utilities, renewable energy generators, transportation (rail, road and air), and private developers.

Education

2014 – Graduate Certificate in Environmental Management of Military Lands, Colorado State University 2010 – Professional Certificate in CEQA/NEPA – ICF International Corporation 2009 – M.A., Anthropology (Archaeology) and GIS, University of Florida, Gainesville, Florida 2006 – B.A., Anthropology (Concentration in Archaeology) and Certificate in GIS, University of California, Los Angeles, California

Professional Utility Sector Experience

SCE On-Call and Emergency Projects – Archaeological Principal Investigator and Project Manager; throughout California,

2013 – Present. Belcourt provides oversight of all task orders and project management of on-call task orders involving

cultural resource desktop reviews, records searches and field reviews for deteriorated poles, system upgrades, initial

studies to support capital projects, and monitoring support to replace facilities due to natural disasters. Material Culture

also provides full-time analyst support to EHSync projects under this contract. This high-volume program includes preparing

and submitting budgets, managing support staff and overseeing work, tracking and reporting efforts, maintaining project

schedules, and preparing technical reports and GIS datasets for submittal to prime contractor (SWCA).

Archaeological Survey for the SCE Transmission Line Rating and Remediation Program – Kern River 66kV, Control-Silver

Peak 55kV, Control-Haiwee 115kV, Ivanpah-Coolwater-Kramer-Inyokern 115kV, Eldorado-Pisgah-Lugo 220kV, Mono,

Inyo, Kern, Los Angeles, and San Bernardino Counties, California; Clark and Esmeralda Counties, Nevada; 2016 – Present.

Tria is the program lead for five major TLRR projects under contract to Arcadis. Tria oversees preparation of all work plans,

GIS data management and deliverables, project management, project oversight, QA/QC of technical reports, logistics

planning and support for field crews. Several state and federal agencies are overseeing each of these projects, and Tria has

developed close working relationships with the BLM Bishop, Ridgecrest, Barstow and Palm Springs California Field Offices,

as well as Tonopah and Las Vegas BLM Nevada Field Offices. These projects also cross state lands such as Tejon State

Historic Park, California Lands Commission School Lands, Los Padres, Sequoia, Inyo, Toiyabe National Parks, Mojave

National Preserve, and China Lake Naval Air Weapons Station. These five projects together amass over 500 miles of

pedestrian survey within a 300-foot linear corridor – equaling over 20,000 acres and assessing impacts/effects to over 2,000

cultural resources. The initial phase of work is expected to extend through 2018, to support preparation of the Proponent’s

Environmental Assessment, after which the second phase will take place to support five separate EIRs/EISs.

SCE Small Capital Projects – Archaeological Principal Investigator and Program Manager; throughout California, 2014 –

Present. Belcourt provides oversight of all task orders and project management of task orders involving cultural resources

for this contract with ICF. This includes preparing and submitting budgets, managing support staff and overseeing work,

tracking and reporting efforts, maintaining project schedule, and preparing technical reports and GIS datasets for submittal

to prime contractor. Task orders – Kelly Cutover (Extends throughout the city of Daggett and surrounding area), Colton

Substation (located in Colton), Utah 12kV (Located at Joshua Tree National Park).

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SCE Large Capital Projects – Archaeological Principal Investigator and Program Manager; throughout California, 2017 –

Present. Belcourt provides oversight of all task orders and project management of task orders involving cultural resources

for this contract with ICF and SWCA. This includes preparing and submitting budgets, managing support staff and

overseeing work, tracking and reporting efforts, maintaining project schedule, and preparing technical reports and GIS

datasets for submittal to prime contractor.

SCE Coolwater Lugo Transmission Project –– Environmental Project Manager; San Bernardino County, California; 2014 –

Present. Belcourt provided oversight of all project management on CWLTP: tracking and reporting efforts of subconsultants

(Pacific Legacy, Paleo Solutions and Urbana Preservation and Planning), maintaining project schedule and timely submittal

of project deliverables to agency reviewers. She also served as communication facilitator between SCE and BLM/CPUC

agency reviewers.

SCE Eldorado Ivanpah Transmission Project – In-house Consultant for Archaeology; San Bernardino County, California and

Clark County, Nevada; 2010-2012. Belcourt provided regulatory oversight and project management regarding cultural and

paleontological resource management. She developed environmental compliance training to inform and guide construction

activities and major capital project teams. She also developed and implemented internal cultural resource management

programs based on the mitigation measures in the FEIR/EIS. Tria coordinated with BLM archaeologists on discovery and

management of previously unknown cultural resources discovered during construction. She provided environmental

analyses and clearance documentation on over 20 project modifications during construction without delay to project.

Developed the cultural resources geodatabase for EITP and coordinated regularly with the project GIS team.

SCE Tehachapi Renewable Transmission Project, Segments 1-3 and Segments 6-11, Kern, Los Angeles and Orange County,

CA; 2009 -2016. Tria provided service to this project for seven years in multiple roles – archaeological/paleontological field

monitor, project coordinator, in-house consultant at SCE, and principal investigator. She provided regulatory oversight and

project management regarding cultural and paleontological resource management for all segments of TRTP. Developed and

implemented internal cultural and paleontological resource management programs based on the mitigation measures in

the Final Environmental Impact Report/Environmental Impact Statement (FEIR/EIS) for TRTP, and for the existing Special

Use Permits and Record of Decision for TRTP, issued by the Angeles National Forest (ANF). Oversaw preparation of the

Historic Properties Treatment Plans, fieldwork and technical report preparation for two large-scale Phase III Data Recovery

excavations on Angeles National Forest, and provided final review of all paleontological monitoring reports. Coordinated

with ANF archaeologists on discovery and management of previously unknown cultural resources identified during

construction. Provided environmental analyses and clearance documentation on over 100 project modifications during

construction without delay to project. Maintained the cultural resources geodatabase TRTP and coordinated regularly with

the project GIS team.

SCE Silver State South Substation, Clark County, Nevada; 2010-2012. Provided regulatory oversight and project

management regarding cultural and paleontological resource management during project licensing and scoping. Identified

potential impacts to cultural and paleontological resources, developing appropriate mitigation measures in preparation for

and projecting alternative conclusions. Lead In-house Consultant Archaeologist at Southern California Edison.

PG&E NERC Alert Program – Archaeological Principal Investigator; throughout California; 2015 – Present. Belcourt

provides oversight of all task orders and project management of on-call task orders involving cultural resource desktop

reviews, records searches and field reviews for the PG&E NERC Alert program – PG&E’s program for addressing GO 95

discrepancies. Tasks include tracking and reporting efforts, maintaining project schedule, and timely submittal of data to

prime contractor (Arcadis).

PG&E In-Line Inspections and Pigging Program – Archaeological Principal Investigator and Program Manager, throughout

California, 2016-Present. Belcourt provides oversight of all task orders and project management of on-call task orders

involving cultural resource desktop reviews, records searches and field reviews for the PG&E NERC Alert program: tracking

and reporting efforts, maintaining project schedule, and timely submittal of data to prime contractor (Parsons).

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Jennifer Kelly, M.Sc.Consultant III – Senior Paleontologist and Principal Investigator

Jennifer has experience in all aspects of paleontology. She has extensive experience with monitoring, salvage, fieldwork, project management, and report writing, as well as volunteer experience from the La Brea Tar Pits/Page Museum and the Cooper Center of Orange County (Paleontology department) and field experience as a Staff Geologist for Leighton Geotechnical. Her expertise is Geology, and she has her M.S. in Geological Sciences, emphasis in Geochemistry. Jennifer has taught lab courses in paleontology and general geology, and also assisted with field mapping classes. Jennifer is HAZWOPER 40-hour certified and a registered Orange County paleontologist. She has co-authored more than 60 paleontological compliance documents, including PRMPs, EIR, EIS, PEA, final monitoring reports, survey reports, and other compliance documents, in compliance with NEPA, CEQA, Caltrans and city and county laws, ordinances, regulations, and statutes.

Education:

2012 M.S. Geology, California State University, Long Beach 2005 B.S., Geology (preliminary work for entry to M.S. Geology Program), California State University, Long

Beach 2004 B.A., Theater Arts, California State University, Long Beach

Professional Experience

Tehachapi Renewable Transmission Project (TRTP) — Southern California Edison (LSA), Kern County, Los Angeles County, San Bernardino County, California, Assistant PM/Research Specialist, Ms. Kelly has conducted and led surveys along this project’s right of way. She additionally has been in charge of scheduling monitoring crews during grading in areas of paleontological sensitivity, managing and reviewing log sheets, and tracking data that is incorporated to final reports. Ms. Kelly played a valuable role with scheduling for the project’s needs. She has monitored, surveyed, and reported on all paleontological facets of this project as the Lead Paleontological Monitor for segment 3B and 4-11. She has co-authored more than 10 of the compliance reports for this project. She has also performed monitoring on every segment of this Project.

OC Access Road Grading , Southern California Edison, Orange and Riverside County, California, Assistant PM/Research Specialist., Ms. Kelly assisted in documentation for the cultural resources portion, which include information regarding the location and condition of archaeological and paleontological sites recorded at or near the access roads, and recommends impact avoidance measures for future years in implementing the Protocol for 73 known archaeological sitesThis required extensive coordination with Orange County Fire Authority grading department, SCE’s O&M (operations and maintenance), and Orange County Parks. Trimble units were used for the documentation before and after grading of access roads. Communication played a key role when strategizing which locations were being graded where and when. The company came in under budget because of Jennifer’s efficiency and ability to coordinate and schedule.

SDG&E Laguna Niguel Reliability Project, Laguna Niguel, Orange County, California, Assistant PM/Research Specialist Jennifer performed initial research for this Project, and co-authored the final report on the monitoring efforts for this project in the Capistrano Formation.

SDG&E Camp Pendleton Project, Counties of San Diego and Orange. On-Call Paleontological Services (2009-2012), Assistant PM/Research Specialist, Ms. Kelly was a key facet in report production and research which enabled her firm to perform all survey and monitoring work required on Camp Pendleton for CEQA/NEPA check list assessments requested from SDG&E. Ms. Kelly was cleared from the Department of Defense in order to conduct work on the base. Site assessments and monitoring include all work related to: future location of power poles and towers, water control features, trenching and subsurface excavations, access roads, grading impacts to develop substations and other facilities, work pads, staging yards, and gas pipelines.

342 Cucamonga Avenue, Claremont, California 91711 | 626-205-8279 | [email protected] www.materialcultureconsulting.com

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Kelly CV 2016 Page 2 of 2

Holy Sepulchre Cemetery Expansion Project, Diocese of Orange, Santa Ana, Orange County, California, Assistant PM/Research Specialist Jennifer assisted with scheduling monitoring for this project, and was the co-author for the final report, as well as performing all project-related research. The project consisted of grading and leveling several new areas for expansion of the Holy Sepulchre Cemetery, including portions that lie in paleontologically sensitive rock formations and had the potential to produce fossils.

UC Irvine Alumni Center Project, Irvine, Orange County, California, Assistant PM/Research Specialist She performed all monitoring scheduling and coordination duties, as well as research and writing for the final report and the initial monitoring guidelines. This project was a high-visibility construction project for a new alumni center on the grounds of UC Irvine, in a paleontologically sensitive area.

Peters Canyon County Park Restrooms Project, Orange County, California, Assistant PM/Research Specialist Ms. Kelly performed all paleontological monitoring scheduling and coordination duties, as well as research and writing for the final paleontological resources letter report. This project involved the leveling of a pad and significant trenching through paleontologically sensitive soils in order to install a new restroom at the northern end of this park.

El Casco System-Transmission Line — Southern California Edison, Riverside County, California, Paleontological Field Technician, Ms. Kelly performed monitoring, salvaged small and large fossils, Screen washed and sorted fossils. Ms. Kelly aided in the processing of microfossils collected from bulk sampling of fossil bearing sediment, and documenting stratigraphic locations of fossil bearing units. This project was incompliance with both CEQA and the CPUC.

Paleontological Mitigation Plans (PMP) for Caltrans Cherry/Citrus Ave I-10 interchange Project — PCR/Caltrans, San Bernardino, California, Assistant PM/Research Specialist Jennifer Kelly conducted all aspects of surveying, and literature searches for both projects.

UHS Temecula Medical Center— Turner Construction, Temecula , Riverside County, California, Assistant PM/Research Specialist. She was in charge of day to day scheduling and occasional monitoring as well as writing the final report.

Ocotillo Wind Express Project — ASPEN, Imperial County, California, Assistant PM/Research Specialist, Ms. Kelly was responsible for managing and collecting all field forms and data that was electronically mailed daily, and incorporating these forms in the final DEIR/EIS Report. She conducted all technical research and compiled both geological and compliance documentation into the final report that was then incorporated into the EIR/EIS.

Manzana Wind Express Project, Kern County, California, Assistant PM/Research Specialist Ms. Kelly assisted in writing the Paleontological Mitigation Monitoring Resource Plan, which allowed her to develop a key role in presenting environmental training programs to construction workers and other environmental compliance monitors. She co-authored the final paleontological monitoring report. The Manzana Wind Energy Project site was found to have the potential for scientifically significant paleontological resources that could be impacted by construction-related ground disturbance. Project construction consisted of the installation of 107 to 300 wind energy turbines, aligned along approximately 26 rows, on the 6,275-acre proposed site. She co-authored the final paleontological mitigation report in compliance with CEQA and Kern County guidelines.

Pacific Wind Express Project, Kern County, California, Assistant PM/Research Specialist Ms. Kelly assisted in writing the Paleontological Mitigation Monitoring Resource Plan, which allowed her to develop a key role in presenting environmental training programs to construction workers and other environmental compliance monitors. She co-authored the final paleontological mitigation report.

Cadiz Ground Water Project, ESA, San Bernardino County, California, Assistant PM/Research Specialist, Ms. Kelly conducted all research and data collection for the Cadiz Groundwater Conservation and Storage Project, located in eastern San Bernardino County, California in order for Paleo Solutions personnel to complete a DEIR section on paleontological resources. The project included the pipeline corridor but not the Well Field Area and Spreading Basins. Based on the results of the analysis, mitigation measures were developed and are designed to reduce potential adverse impacts to paleontological resources as a result of proposed Project construction to a less than significant level. Only one Project alternative was analyzed for impacts on paleontological resources). The paleontological analysis for the Cadiz Project is a requirement of the California Environmental Quality Act (CEQA).

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Appendix B:

NAHC and Native American Correspondence

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342 Cucamonga Avenue, Claremont, California 91711 | 626-205-8279 | www.materialcultureconsulting.com

EXAMPLE LETTER

RE: Proposed Huntington Beach Tank Yard Project, City of Huntington Beach; Newport Beach

USGS Quadrangle, Orange County, California.

Greetings, SLF-HB Magnolia, LLC is proposing to convert a currently vacant and graded lot into a parking area in Huntington Beach, Orange County, California (see attached map). Material Culture Consulting, Inc. is conducting the cultural resources review of the project to support preparation of the environmental documents. As part of our review, we would like to request your input on potential cultural resources within the project area. Our firm contacted the Native American Heritage Commission (NAHC) on August 09, 2017 to request review of the Sacred Lands File and for a list of tribes with traditional lands and/or cultural places within the area. The NAHC responded on August 23, 2017, stating that the Sacred Lands File review resulted in negative results, and provided your contact information as part of the list. We understand that negative results do not preclude the existence of cultural resources, and that a tribe may be the only source of information regarding the existence of a tribal cultural resource, which is why we are contacting you. Project Location and Description The proposed project is located in the Huntington Beach Tank Yards, on Magnolia St. south of Hamilton Ave., north of Pacific Coast Highway-1, and east of the Huntington Beach Channel (see attached map). The area of potential impact (API) includes two parcels that encompass a total of approximately 28 acres and located within Section 18 of Township 6 South and Range 10 West (San Bernardino Base Meridian).

Please respond at your earliest convenience if you wish to share any knowledge of cultural resources within or adjacent to the API. Any information, concerns, or recommendations regarding cultural resources within the API can be shared with me via telephone, email, or via standard mail. City of Huntington Beach will be the Lead Agency for the project, and can be reached directly for formal consultation requests. Thank you very much for your assistance. Kindest regards,

-

Tria Belcourt, M.A., RPA President and Principal Archaeologist 626-205-8279 [email protected]

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GABRIELEÑO BAND OF MISSION INDIANS – KIZH NATION

Historically known as The San Gabriel Band of Mission Indians

recognized by the State of California as the aboriginal tribe of the Los Angeles basin

Andrew Salas, Chairman Nadine Salas, Vice-Chairman Christina Swindall Martinez, secretary

Albert Perez, treasurer I Martha Gonzalez Lemos, treasurer II Richard Gradias, Chairman of the Council of Elders

PO Box 393, Covina, CA 91723 www.gabrielenoindians.org [email protected]

Material Culture Consulting

342 Cucamonga Ave

Claremont, CA 91711

August 31, 2017

Re: Archaeologist’s request for Huntington Beach Yard Project City of Huntington Beach, Newport Beach USGS

Quadrangle Orange County, CA

Dear Tria Belcourt,

We have received your request for information regarding our tribal history and its relationship to the above-mentioned

project. Pursuant to AB52, consultation with the lead agency or applicant is confidential (Public Resources Code

21082.3, subd. (c)(2)(A)). To minimize confusion and/or risk a breach of this confidentiality, we politely request that

you contact the lead agency for the information you are looking for. Additionally, your presence at the consultation

appointment is encouraged.

(21082.3.) (c) (1Any information, including, but not limited to, the location, description, and use of the tribal cultural

resources, that is submitted by a California Native American tribe during the environmental review process shall not be

included in the environmental document or otherwise disclosed by the lead agency or any other public agency to the

public, consistent with subdivision (r) of Section 6254, and Section 6254.10 of, the Government Code, and subdivision

(d) of section 15120 of Title 14 of the California Code of Regulations, without the prior consent of the tribe that

provided the information. If the lead agency publishes any information submitted by California a Native American tribe

during the consultation or environmental review process, that information shall be published in a confidential

appendix to the environmental document unless the tribe that provided the information consents, in writing, to the

disclosure of some or all of the information to the public. This subdivision does not prohibit the confidential exchange

of the submitted information between public agencies that have lawful jurisdiction over the preparation of the

environmental document.

With Respect,

Andrew Salas, Chairman

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9/7/2017 Material Culture Consulting Mail - MCC written summary of today's conference call

https://mail.google.com/mail/u/1/?ui=2&ik=641502eb01&jsver=EfWGX3tyASk.en.&view=pt&search=inbox&th=15e43002c7b59165&siml=15e3e97b943… 1/2

Sonia Sifuentes <[email protected]>

MCC written summary of today's conference call 3 messages

Sonia Sifuentes <[email protected]> Fri, Sep 1, 2017 at 10:58 AMTo: Andy <[email protected]>, "Matt Teutimez.Kizh Gabrieleno" <[email protected]>Cc: Tria Belcourt <[email protected]>

Hello Andy and Matt,

As Tria has mentioned, thank you both for taking time out of your morning to talk to me about Magnolia Tank FarmProject (also known as Huntington Beach Tank Yard). As I mentioned on the phone call, there are two phases of theproject: the first phase is a parking lot and the second phase is the development of residential community with some retailunits that will occur within the next 5 to 10 years. The following is a summary of the information you both offered duringour phone call.

Date: 09/01/17

Informants: Andrew Salas and Matt Teutimez

*There are several prominent known villages within the region of the Project Area:

-Lukupangna, located on the east side of the channelized Santa Ana River within Huntington Beach andCosta Mesa limits, near Fairview Park (also a known burial location), south/southeast of Project Area

-Moyogna, also located on the further east closer to Newport Beach, south/southeast of Project Area

-Kenyaangna, coastal village close to the shore line in Newport Beach limits, south/southeast of ProjectArea

-Motuucheyngna, located within Seal Beach area of Long Beach limits, north/northwest of Project Area

*Due to past historical topography of potential natural spring located southwest of the Project Area (marked asWater Tank in modern topo maps), which would have been in close proximity of the shoreline, would have heldspiritual significance and ceremonial activities would have occurred in such a location.

-The historical topography also depicts that the area, while still within the marsh lands, would have beenan upland area located within the setting (being over 7 ft AMSL). This is indicated by roads/paths depicted onhistorical maps. Such an area would have been ideal for not only access paths, but it would have provided aslight overhang to the known villages to the east and would have been a good source for foraging/huntingactivities year-round.

*Development during the 1950s most likely used local or nearby fill to replace the marsh environment. This fillcould hold secondary depositions of cultural artifacts that while might not be insitu, still holds culturalsignificance to the tribe.

Based on the above information, the Kizh Nation recommends monitoring, spot checking at minimum, with bothArchaeologist and Native American monitor during ground disturbance activities.

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9/7/2017 Material Culture Consulting Mail - MCC written summary of today's conference call

https://mail.google.com/mail/u/1/?ui=2&ik=641502eb01&jsver=EfWGX3tyASk.en.&view=pt&search=inbox&th=15e43002c7b59165&siml=15e3e97b943… 2/2

If there is anything I missed or wrote down incorrectly, please let me know! Once we get verification on the summary, wewill be including this within our report. Once again, thank you both for your help. Have a great holiday weekend!

Sincerely,

Sonia

-- Sonia Sifuentes, M.Sc., RPAArchaeological Field Director

Material Culture Consulting, Inc.Claremont, CaliforniaCell: 909-730-8829www.materialcultureconsulting.com

Matt Teutimez <[email protected]> Fri, Sep 1, 2017 at 10:55 PMTo: Sonia Sifuentes <[email protected]>Cc: Andy <[email protected]>, Tria Belcourt <[email protected]>

Thank you for preparing the summary of our phone consultation. It captures our conversation very well. I have nothingfurther to add at this time.

Best,

Matt Teutimez [Quoted text hidden]

Tria Belcourt <[email protected]> Sat, Sep 2, 2017 at 7:30 AMTo: "Matt Teutimez.Kizh Gabrieleno" <[email protected]>Cc: Sonia Sifuentes <[email protected]>, Andy <[email protected]>

Hi Matt,

Thank you for your feedback. Hope you All have a wonderful weekend!

Tria Belcourt, M.A., RPA President and Principal Archaeologist

Material Culture Consulting, Inc. Claremont, California 626.205.8279 www.materialcultureconsulting.com [Quoted text hidden]

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Magnolia Tank Farm Project Native American Outreach Communication Log September 2017

Name/Affiliation Date and Method of 1st Contact

Date of 1st Follow Up Attempt

Date of 2nd Follow-Up Attempt

Results

Andrew Salas, Chairperson Gabrielino Band of Mission Indians- Kizh Nation

August 24, 2017 – Mailed letter via USPS at address provided by NAHC

Not necessary

Not necessary

Letter emailed on Aug 31: Tribe has deferred us to contact Lead Agency for any additional information/correspondence; Phone call on Sept 1: Tribe offered additional information about the Project Area and the general region and recommended that monitoring by both Archaeologist and Native American Monitor occur during ground disturbance activities

Anthony Morales, Chairperson Gabrielino/Tongva San Gabriel Band of Mission Indians

August 24, 2017 – Mailed letter via USPS at address provided by NAHC

September 1, 2017- email

September 7, 2017- email

Sandonne Goad, Chairperson Gabrielino/Tongva Nation

August 24, 2017 – Mailed letter via USPS at address provided by NAHC

September 1, 2017- email

September 7, 2017- email

Robert Dorame, Chairperson Gabrielino Tongva Indians of California Tribal Council

August 24, 2017 – Mailed letter via USPS at address provided by NAHC

September 1, 2017- email

September 7, 2017

Phone Call Sept 1: Requesting survey results and asking if verbal discussion on knowledge is okay with the client. Will be getting back to them next week. Email on September 6 and subsequent call on September 7, Mr. Dorame said if there were any comments, the Tribe would get back by the end of the week.

Charles Alvarez, Chairperson Gabrielino-Tongva Tribe

August 24, 2017 – Mailed letter via USPS at address provided by NAHC

September 1, 2017- email

September 7, 2017-email

Sonia Johnston, Chairperson Juaneño Band of Mission Indians

August 24, 2017 – Mailed letter via USPS at address provided by NAHC

September 1, 2017- email

September 7, 2017-email

Matias Belardes, Chairperson Juaneño Band of Mission Indians Acjachemen Nation-Berlades

August 24, 2017 – Mailed letter via USPS at address provided by NAHC

September 1, 2017- phone call VM left

Not Necessary

VM left by Joyce Perry on Sept 1: Did receive our letter and the Tribe has no concerns in regards to the Project Area.

Joyce Perry, Chairperson Band of Mission Indians Acjachemen Nation- Belardes

August 24, 2017 – Mailed letter via USPS at address provided by NAHC

September 1, 2017- email

Not Necessary

VM left by Joyce Perry on Sept 1: Did receive our letter and the Tribe has no concerns in regards to the Project Area.

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Magnolia Tank Farm Project Native American Outreach Communication Log September 2017

Teresa Romero, Chairperson Juaneño Band of Mission Indians Acjachemen Nation- Romero

August 24, 2017 – Mailed letter via USPS at address provided by NAHC

September 1, 2017- email

September 7, 2017-email

John Valenzuela, Chairperson San Fernando Band of Mission Indians

August 24, 2017 – Mailed letter via USPS at address provided by NAHC

September 1, 2017- email

September 7, 2017- email

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Appendix C:

Paleontological Records Results from Natural History Museum of Los Angeles County

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Vertebrate Paleontology SectionTelephone: (213) 763-3325

e-mail: [email protected]

17 August 2017

Material Culture Consulting342 Cucamonga AvenueClaremont, CA 91711

Attn: Tria Belcourt, President and Principal Archaeologist

re: Paleontological resources for the proposed Huntington Beach Tank Project, Project #SHOP 17-001, in the City of Huntington Beach, Orange County, project area

Dear Tria:

I have conducted a thorough check of our paleontology collection records for the localityand specimen data for the proposed Huntington Beach Tank Project, Project # SHOP 17-001, inthe City of Huntington Beach, Orange County, project area as outlined on the portion of theNewport Beach USGS topographic quadrangle map that you sent to me via e-mail on 7 August2017. We do not have any fossil localities that lie directly within the proposed project areaboundaries, but we do have fossil localities nearby from the same sedimentary deposits that occursubsurface in the proposed project area.

The entire proposed project area has surface deposits that consist of younger QuaternaryAlluvium, derived as fluvial deposits from the Santa Ana River that currently flows just to theeast. These deposits typically do not contain significant vertebrate fossils in the uppermostlayers, but they are usually underlain by older Quaternary deposits that frequently do containsignificant vertebrate fossils. Our closest fossil vertebrate locality from similar deposits isLACM 7366, west-northwest of the proposed project area north of the Pacific Coast Highway(Highway 1) between Lake Avenue and Beach Boulevard, that produced specimens of marine,freshwater, and especially terrestrial specimens including leopard shark, Triakis, three-spinedstickleback, Gasterosteus, garter snake, Thamnophis, desert shrew, Notiosorex, and mostprominently, pocket gopher, Thomomys. Just north-northwest of locality LACM 7366 but still

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south of Atlanta Avenue, we have a series of vertebrate fossil localities, LACM 7422-7425, thatproduced fossil specimens of mammoth, Mammuthus, bison, Bison, and horse, Equus, from thesedeposits as well as locality LACM 7679 that produced a rich suite of freshwater and terrestrialfossil vertebrates including three-spine stickleback, Gasterosteus aculeatus, western toad, Bufoboreas, pacific treefrog, Hyla regilla, arboreal salamander, Aneides lugubris, slender salamander,Batrachoseps, lungless salamander, Ensatina, western pond turtle, Clemmys marmorata,southern alligator lizard, Gerrhonotus multicarinatus, legless lizard, Anniella pulchra, fencelizard, Sceloporus, side-blotched lizard, Uta stansburiana, ringneck snake, Diadophis punctatus,kingsnake, Lampropeltis getulus, coachwhip, Masticophis, gopher snake, Pituophismelanoleucus, long-nosed snake, Rhinocheilus lecontei, garter snake, Thamnophis, scaled quail,Callipepla squamata, virginia rail, Rallus limicola, ornate shrew, Sorex ornatus, broad-footedmole, Scapanus latimanus, brush rabbit, Sylvilagus bachmani, meadow vole, Microtuscalifornicus, wood rat, Neotoma, deer mouse, Peromyscus maniculatus, harvest mouse,Reithrodontomys megalotis, pocket gopher, Thomomys, pacific kangaroo rat, Dipodomys agilis,and squirrel, Eutamias. The specimens from localities LACM 7366 and 7679 were obtained byscreen washing matrix and thus they consist solely of small elements.

Very shallow excavations in the younger Quaternary Alluvium exposed throughout theproposed project area probably will not uncover significant vertebrate fossil remains. Deeperexcavations in the proposed project area that extend down into the older Quaternary deposits,however, have a good chance of encountering significant fossil vertebrate specimens. Anysubstantial excavations in the sedimentary deposits of the proposed project area, therefore,should be monitored closely to quickly and professionally recover any fossil remains discoveredwhile not impeding development. Sediment samples should also be collected and processed todetermine the small fossil potential in the proposed project area. Any fossils recovered duringmitigation should be deposited in an accredited and permanent scientific institution for thebenefit of current and future generations.

This records search covers only the vertebrate paleontology records of the Natural HistoryMuseum of Los Angeles County. It is not intended to be a thorough paleontological survey ofthe proposed project area covering other institutional records, a literature survey, or any potentialon-site survey.

Sincerely,

Samuel A. McLeod, Ph.D.Vertebrate Paleontology

enclosure: invoice