appendix h - Amador County
Transcription
appendix h - Amador County
APPENDIX H A Cultural Resources Survey for the Newman Ridge Project Amador County, California Eric Strother, M.A./R.P.A. and Lauren Del Bondio May 6, 2011 A Cultural Resources Survey for the Newman Ridge Project Amador County, California Prepared by: _________________________________ Eric Strother, M.A., Register of Professional Archaeologists (#15381) and Lauren Del Bondio Tom Origer & Associates Post Office Box 1531 Rohnert Park, California 94927 (707) 584-8200 (707) 584-8300 (fax) origer@origer.com Requested by: Newman Minerals, LLC 3740 Hwy 104 PO Box 1730 Ione, CA 95640 May 6, 2011 ABSTRACT Tom Origer & Associates conducted a cultural resources survey for the Newman Ridge Project, Amador County, California. The project area consists of approximately 391 acres of land. This study included archival research at the North Central Information Center, California State University, Sacramento (NCIC Record Search No. AMA-10-24), examination of the library and files of Tom Origer & Associates, contact with the Native American community, and field inspection of the study area. Field survey resulted in the finding of five previously recorded cultural resources and six newly identified cultural resources. Documentation pertaining to this study is on file at the offices of Tom Origer & Associates (File No. 10-102). Synopsis Project: Location: Quadrangle: Study Type: Scope: Finds: Newman Ridge Project Near Ione, Amador County, California Portions of Ione and Irish Hill 7.5’ series Intensive survey ~391 acres of land Nine historic-era cultural resources and two prehistoric-era cultural resources i Project Personnel Tom Origer participated in the field phase of this study and provided project oversight. Mr. Origer obtained a Master of Arts degree in Anthropology from San Francisco State University in 1983, after obtaining a Bachelor of Arts degree in Anthropology at Sonoma State University in 1974. He has over thirty years of experience in cultural resources management throughout Northern California. His experience includes work that has been completed in compliance with local ordinances, CEQA, NEPA, and Section 106 (NHPA) requirements. Mr. Origer has been teaching archaeological analysis and field archaeology classes at Santa Rosa Junior College since 1979. He is affiliated with the Society for California Archaeology (Presidential duties from April 1998 to April 2001), the International Association for Obsidian Studies (charter member and President from 1990-1992), the Archaeological Institute of America (President of the North Coast Society from 1985 to 1987), the Society for American Archaeology, the Society for Historical Archaeology, and the Register of Professional Archaeologists (#10333). Eric Strother prepared this report. He has over twelve years of professional archaeological experience working throughout California, and has been with Tom Origer & Associates since November 2010. Mr. Strother holds a Master of Arts in Anthropology with an emphasis in human and non-human osteology, and meets the Secretary of the Interior’s standards for archaeology. Mr. Strother has prepared numerous technical reports meeting CEQA and Section 106 standards, as well as direct field crews on both large and small-scale projects. Mr. Strother has also taught Physical Anthropology and Field Archaeology at California State University, East Bay, and assisted Sonoma County law enforcement with forensic assessments. He is listed on the Register of Professional Archaeologists (#15381) and is a member of the Society for California Archaeology. Lauren Del Bondio participated in the field phase of this study and assisted in the preparation of this report. She is pursuing a Bachelor of Arts degree in Anthropology at Sonoma State University and has been involved in Northern California archaeology for seven years. Eileen Barrow participated in the field phase of this study. Mrs. Barrow has been with Tom Origer & Associates since 2005. She holds a Master of Arts in cultural resources management from Sonoma State University. Professional affiliations include the Society for California Archaeology, the Cotati Historical Society, the Sonoma County Historical Society, and the Western Obsidian Focus Group. ii CONTENTS i i ii iii 1 2 3 3 5 5 7 9 9 9 9 13 14 16 18 ABSTRACT Synopsis Project Personnel CONTENTS INTRODUCTION REGULATORY CONTEXT Resource Definitions Significance Criteria PROJECT SETTING Study Area Location and Description Cultural Setting STUDY PROCEDURES AND RESULTS Native American Contact Archival Study Procedures Archival Study Results Field Survey Procedures Field Survey Results SUMMARY MATERIALS CONSULTED APPENDIX A Native American Contacts FIGURES 2 6 Figure 1. Project Vicinity Figure 2. Study Location iii INTRODUCTION Tom Origer & Associates conducted a cultural resources survey for the Newman Ridge Development Project. The study area comprises approximately 391 acres of land located along the west end of the Ione Valley near Ione, Amador County, California (Figure 1). The Newman Ridge Project proposes to develop a new hard rock quarry (“Newman Ridge Quarry” or “Quarry”), and a new industrial center that includes various material processing plants and a railroad loadout facility directly off of the existing Union Pacific-Ione Branch rail line (“Edwin Center”). The proposed Newman Ridge Quarry and Edwin Center served as the archaeological study areas for the present project. Proposed project improvements are described below: 1. The Newman Ridge Quarry is located south of the Edwin Center. It comprises approximately 278 acres of land and will serve for hard rock quarrying. A Conditional Use Permit (CUP) and Reclamation Plan (RP) are required for the proposed Newman Ridge Quarry. 2. The Edwin Center is located to the north of the proposed Newman Ridge Quarry. The Edwin Center is currently designated for aggregate and construction material processing as well as loadout of aggregate material to trucks and railcars. The proposed Edwin Center will include a railroad loadout facility directly off of the existing Union Pacific Ione Branch rail.. Establishment of the Edwin Center will require approval of a General Plan Amendment (GPA) and re-zone for a 113-acre area. 3. An existing road will connect the proposed Edwin Center to the Newman Ridge Quarry. This road will be extended to include a new bridge span over Dry Creek, and will be used by haul units and/or an overland conveying system to haul shot rock or crushed rock from the Newman Ridge Quarry. The road will also be used by Quarry personnel vehicles and rolling stock equipment to access the Quarry. The proposed permit modifications for the Newman Ridge Project are governed by Amador County's Surface Mining Ordinance (County Code Chapter 7.36) and the State Surface Mining and Reclamation Act (SMARA). Additional approvals and permits will be sought as part of the project including those from federal, state, and local public agencies. Therefore, the following "Regulatory Context" includes requirements specified in both Section 106 of the National Historic Preservation Act (Section 106) and the California Environmental Quality Act (CEQA) and its guidelines (Title 14 CCR §15064.5). The archaeological field inspection involved approximately 391 acres of land, which comprises the Newman Ridge Project area. This study was requested and authorized by Newman Minerals, LLC. 1 REGULATORY CONTEXT The proposed project is subject to the California Environmental Quality Act (CEQA) and because the project will likely require federal permitting it will also be subject to Section 106 of the National Historic Preservation Act (Section 106). These acts require that historic properties be considered as part of the environmental review process. This is accomplished by an inventory of resources within a study area and by assessing the potential that cultural resources could be affected by development. Compliance with Section 106 requires that agencies make an effort to identify historic properties that may be affected by a project, and gather information to evaluate the property's eligibility for inclusion in the National Register of Historic Places (National Register). If historic resources are identified within a project area, they are evaluated using National Register criteria promulgated in 36CFR60. Figure 1. Project Vicinity (adapted from the 1957 [revised 1970] Sacramento, CA 1:250,000-scale USGS map). For National Register purposes, the age requirement is generally 50 years; however, more recent resources could be eligible for listing. The California Environmental Quality Act (CEQA) requires that cultural resources be considered during the environmental review process. This is accomplished by an inventory of resources within a study area and by assessing the potential that cultural resources could be affected by development. 2 This cultural resources survey was designed to satisfy environmental issues specified in both Section 106 and CEQA and its guidelines (Title 14 CCR §15064.5) by: (1) identifying all cultural resources within the project area; (2) offering a preliminary significance evaluation of the identified cultural resources; (3) assessing resource vulnerability to effects that could arise from project activities; and (4) offering suggestions designed to protect resource integrity, as warranted. Resource Definitions The National Register of Historic Places defines a historic property as a district, site, building, structure, or object significant in American history, architecture, engineering, archaeology, and culture, and may be of value to the Nation as a whole or important only to the community in which it is located (National Park Service [NPS] 1985:2;). These resource types are described by the National Park Service (2002) and the California Office of Historic Preservation (OHP 1995:2) as follows. Site. A site is the location of a significant event, a prehistoric or historic occupation or activity, or a building or structure, whether standing, ruined, or vanished, where the location itself possesses historic, cultural, or archaeological value regardless of the value of any existing structure. Building. A building, such as a house, barn, church, hotel, or similar construction, is created principally to shelter any form of human activity. "Building" may also be used to refer to a historically and functionally related unit, such as a courthouse and jail, or a house and barn. Structure. The term "structure" is used to distinguish from buildings those functional constructs made usually for purposes other than creating shelter. Object. The term "object" is used to distinguish from buildings and structures those constructions that are primarily artistic in nature or are relatively small in scale and simply constructed. Although it may be, by nature or design, movable, an object is associated with a specific setting or environment. District. A district possesses a significant concentration, linkage, or continuity of sites, buildings, structures, or objects united historically or aesthetically by plan or physical development. Significance Criteria Under Section 106 the importance of an identified historic property, or archaeological site is evaluated in terms of National Register of Historic Places criteria put forth in 36CFR60, as follows: 3 The quality of significance is present in properties that possess integrity of location, design, setting, materials, workmanship, feeling, and association, and: A. That are associated with events that have made a significant contribution to the broad patterns of our history; or B. That are associated with the lives of persons significant in our past; or C. That embody the distinct characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or D. That have yielded or may be likely to yield, information important in prehistory or history. Under CEQA, when a project might affect a cultural resource (Site, Building, Structure, Object, or District) the project proponent is required to conduct an assessment to determine whether the effect may be one that is significant. Consequently, it is necessary to determine the importance of resources that could be affected. The importance of a resource is measured in terms of criteria for inclusion on the California Register of Historical Resources (Public Resources Code §5024.1; Title 14 CCR, §4850.3) listed below. A resource may be important if it meets any one of the criteria below, or if it is already listed on the California Register of Historical Resources or a local register of historical resources. An important historical resource is one which: 1. Is associated with events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States. 2. Is 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. 4. Has yielded, or may be likely to yield, information important to the prehistory or history of the local area, California or the nation. Under CEQA, if an archaeological site does not meet any of the above criteria it should be evaluated under the criteria of Public Resources Code 21083.2 to determine if it is a “unique archaeological resource”. A “unique archaeological resource” is: 4 . . . an archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria: (1) Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information (2) Has a special and particular quality such as being the oldest of its type or the best available example of its type (3) Is directly associated with a scientifically recognized important prehistoric or historic event or person. The California OHP suggests that all resources over 45 years old be recorded for inclusion in the OHP filing system (OHP 1995:2), although professional judgment is urged in determining whether a resource warrants documentation. PROJECT SETTING Study Area Location and Description The study area consists of approximately 391 acres that will be subject to ground disturbance. The study area comprises the Edwin Center (113 acres) and the Newman Ridge Quarry (278 acres) as shown on the Ione and Irish Hill, California 7.5’ USGS topographic quadrangles (Figure 2). The study area consists of both hilly and flat land. Dry Creek runs northeast to southwest between the Edwin Center and the Newman Ridge Quarry, and numerous seasonal drainages are located throughout the study area. Newman Hill marks the peak elevation of the Newman Ridge Quarry and Dutschke Hill (the 1957 USGS Sutter Creek quad labels this “Jones Butte”) is located in the southern portion of the Edwin Center (Figure 2). The Southern Pacific Railroad passes through the northern end of the study area. Four recognized soil types are located within the study area (USDA Web Soil Survey 2011). The Edwin Center is characterized by the Inks loam and Rock land (IrE, 3%-45% slopes) and Red Bluff-Mokelumne complex (RbD, 5%-16% slopes). IrE soils are described 5 Figure 2. Study Location (adapted from the 1962 Ione and Irish Hill, California 7.5’ USGS maps). 6 as a very cobbly loam typically located over unweathered bedrock and are somewhat excessively drained. These soils are located on hills and terraces. Soils within the Newman Ridge Mine are identified as Auburn-Argonaut silt loams (AwC, 0%-16% slopes) and Auburn-Argonaut very rocky silt loams (AxD, 3%-31% slopes). Both are found on hilly terrain and are well drained soils. The study area is underlain by two basic rock units: the basement complex, found in the Newman Ridge Quarry, and the overlying sedimentary rock sequence found in the Edwin Center (Chapman and Bishop 1975:7). The basement complex is composed of highly folded, metamorphosed volcanic and sedimentary rocks and related rocks of pre-Cenozoic age. The basement complex consists of metamorphic rocks of the Calaveras Formation, Amador Group, Mariposa Formation, intrusions of plutonic rocks, and serpentine. The Amador Group, believed to be of the late Middle and early Late Jurassic, consists almost entirely of greenstone (metamorphosed andesitic and basaltic lavas) and amphibole schist of the Logtown Ridge Formation. Outcroppings of these rocks can be seen throughout the Newman Ridge Quarry study area. The vicinity surrounding the Edwin Center is underlain by at least four sedimentary rock formations; pre-Ione beds, Ione Formation, Valley Springs Formation, and the Mehrten Formation. According to the Geologic Map of Amador County, California (Carlson and Clark 1954: Plate 1), the northern half of the Edwin Center is underlain by the Ione Formation. Alternating lenticular beds of sandstone and claystone with lenses of brown carbonaceous claystones and lignite make up the Ione Formation. These beds are commonly white but may be colored red, yellow, or purple by mineral staining. Within the Ione region of Amador County, layers from this formation were mined for lignite during the early 1860s to the mid-1940s (Carlson and Clark 1954:203). The vicinity surrounding Dutschke Hill is composed of the Ione Formation and Valley Springs Formation. The Valley Springs Formation dates to the Miocene and is characterized by rhyolitic ash, pumice and tuff, green clay. According to Carlson and Clark (1954), the Edwin Mine (or "Edwin Deposit") was located around the base of Dutschke Hill, just outside the southern boundary of the Edwin Center study area. Laterite, a low silica clay derived from heavily weathered Jurassic greenstone, is located just north of the Edwin clay area, around Dutschke Hill. Cultural Setting Archaeological evidence indicates that human occupation of California began at least 10,000 years ago (Moratto 1984:71). Early occupants appear to have had an economy based largely on hunting, with limited exchange, and social structures based on the extended family unit. Later, milling technology and an inferred acorn economy were introduced. This diversification of economy appears to be coeval with the development of sedentism and population growth and expansion. Sociopolitical complexity and status distinctions based on wealth are also observable in the archaeological record, as evidenced by an increased range and distribution of trade goods (e.g., shell beads, obsidian tool stone), which are possible indicators of both status and increasingly complex exchange systems. 7 At the time of European settlement, the study area was situated in an area controlled by the Plains and Northern Sierra Miwok (Levy 1978: 399-400). The Miwok were hunter-gatherers who relied heavily upon the use of the acorn. Other nuts, seeds and grasses were harvested, and both small and large game were hunted. They settled in large, permanent villages about which were distributed seasonal camps and task-specific sites. Primary village sites were occupied throughout the year and other sites were visited in order to procure particular resources that were especially abundant or available only during certain seasons. Sites often were situated near fresh water sources and in ecotones where plant life and animal life were diverse and abundant. For more information about the Plains and Northern Sierra Miwok see Levy (1978), and Kroeber (1925). Historic Setting The study area is located within a portion of the Mexican-era Rancho Arroyo Seco Land Grant. The Arroyo Seco, consisting of 11 leagues of land, was granted to Teodosio Yerba (Yorba) on May 8, 1840 by Mexican Governor Juan Bautista Alvarado (Thompson and West 1881:243). Following at least 20 years of cattle and sheep ranching, geologists discovered that lands within the rancho offered a variety of mining opportunities. Clay mining began in Amador County as early as 1864 with the opening of the Dosch Pit between Ione and Carbondale (Carlson and Clark 1954:216). Prized for its highly refractory properties, Edwin clay has been mined from this area since at least the mid-1920s. Edwin clay was seen as especially valuable since it is a very refractory clay and produced the highest grade of heatresistant fire bricks. These bricks were used in high-temperature furnaces employed by the steel, glass, and smelting industries (Waechter et al. 2007:5). Four underground mines and four open pits were utilized to extract Edwin clay from near the base of the lower member of the Ione formation. The Edwin clay bed normally ranged up to 12 ft. thick. The clay was shipped to Pittsburg, California where it was used for the manufacture of fire brick (Carlson and Clark 1954:223). Deep red laterite and lateritic clay were mined just north of the Edwin clay area, around Dutschke Hill. The economic value of laterite was in its low silica content, which was found at the upper (more weathered) profile of the deposit. It was not until the mid-twentieth century that a commercial use for laterite was found, although it had been discovered by geologists working in the area of Jones Butte prior to that. Permanente Cement Company, located in Santa Clara County, began using laterite in their portland cement in 1949. The laterite was blasted and loaded onto trucks with a power shovel. It was then hauled to the railroad about a half-mile away where it was shipped by rail to Permanente (Carlson and Clark 1954:223). In addition to clay, deposits of coal and iron were found within several areas of the rancho. By the early 1890s, the Ione Coal and Iron Company owned approximately 33, 300 acres of land within the Rancho Arroyo Seco (Boyde 1917). The site of Coal Mine No. 3 and its underground workings were located within the northern portion of the current Edwin Center. 8 STUDY PROCEDURES AND RESULTS Native American Contact On January 7, 2011, Tom Origer & Associates contacted local Native American representatives Glen Villa, Jr. and Glen Villa, Sr. to solicit information about the potential for Native American cultural resources within the study area. The Villa's indicated that the areas within the vicinity of Dry Creek were sensitive for the presence of cultural resources. Additionally, Glen Villa Jr. provided photographs of rock art that had been observed in the Comanche vicinity (Villa and Villa personal communication 2011). Archival Study Procedures Archival research included examination of the library and project files at Tom Origer & Associates. A review (Record Search Number AMA-10-24) was completed of the archaeological site base maps and records, survey reports, and other materials on file at the North Central Information Center (NCIC), California State University, Sacramento. Sources of information included but were not limited to the current listings of properties on the National Register of Historic Places, California Historical Landmarks, California Register of Historical Resources, and California Points of Historical Interest as listed in the Office of Historic Preservation’s Historic Property Directory (OHP 2009). The Office of Historic Preservation has determined that structures in excess of 45 years of age should be considered potentially important historical resources, and former building and structure locations could be potentially important historic archaeological sites. Archival research included an examination of historical maps to gain insight into the nature and extent of historical development in the general vicinity, and especially within the study area. Maps ranged from hand-drawn maps of the 1800s (e.g., General Land Office) to topographic maps issued by the United States Geological Survey (USGS) and United States Army Corps of Engineers (USACE). In addition, ethnographic literature that describes appropriate Native American groups, county histories, and other primary and secondary sources were reviewed. Sources reviewed are listed in the "Materials Consulted" section of this report. Archival Study Results Archival research conducted at the NCIC found that five previously recorded archaeological sites are located within the study area. All five of these sites are located within the Edwin Center (Table 1). No previously recorded sites are located within the Newman Ridge Quarry. Six previously recorded archaeological sites are located within a one-mile radius of the Edwin Center and 15 previously recorded sites are located within a one-mile radius of the Newman Ridge Quarry (Table 2). 9 Table 1. Previously recorded archaeological sites located within the study area (NCIC: AMA-10-24). Primary No. Trinomial Site Description Reference P-3-765 CA-AMA-540H Segment of the Southern Pacific Railroad's Ione Larson and Flores Branch. (2002) P-3-899 Small concrete building constructed circa 1948 Napoli (1998a) for explosives storage associated with laterite mining in the area. P-3-900 Small concrete building constructed circa 1948 Napoli (1998b) for explosives storage associated with laterite mining in the area. P-3-901 CA-AMA-614H Site consists of collapsed and water-filled shafts Windmiller (1998a) and pits associated with Ione Coal and Iron Company's Coal Mine No. 3. Other site features include a small earthen reservoir, ditches, prospects, a road and historic debris. P-3-902 CA-AMA-615H Truck scales foundations reportedly used by Windmiller (1998b) Kaiser Permanente during post-World War II mining of laterite south of Edwin siding. Table 2. Previously recorded archaeological sites located within a one-mile radius of the study area (NCIC: AMA-10-24). P# Trinomial Site Description P-3-173 CA-AMA-138 Prehistoric dance houses with trade beads, chert arrows, and obsidian dart. P-3-179 CA-AMA-144 Bedrock mortars (five cups) on rock outcropping near seasonal drainage. One pestle located at site. P-3-180 CA-AMA-145 Lithic scatter and bedrock mortars (14 cups) on rock outcropping near seasonal drainage. Artifacts include 35+ pestles, 2 manos, flakes, hammer stones and core choppers. P-3-182 CA-AMA-147 Exogenous caves and cave sites. Artifacts include ground stone and one mano. P-3-384 CA-AMA-349H Mining area with an open, excavated mine trench and covered shaft. Numerous pits and ditches throughout area; some show tailings and refuse accumulations. P-3-383 CA-AMA-348/H Site consists of the remains of stone buildings and other farm appurtenances that constitute the Dixon property; partially buried BRM with 16+ cups. P-3-387 CA-AMA-352 Prehistoric BRM food processing station (33 cups) and occupation area marked by a large scatter of basalt and chert flakes. P-3-903 CA-AMA-616 Two BRM loci with possible housepit depressions. P-3-904 CA-AMA-617 Two BRM loci on greenstone outcroppings with six cups. P-3-905 CA-AMA-618 BRM on greenstone outcropping showing three cups. P-3-906 CA-AMA-619 BRM on weathered lava flow showing 12+ cups. P-3-907 CA-AMA-620H Earthen dam that spans shallow seasonal drainage. Drainage originates at clay pit 945 ft. to the north. P-3-908 CA-AMA-621H Clay mine: large rectangular pit, stockpiles of white clay; small surface scatter of trash and road trace. Artifacts include remnants of cable, small condiment jar, broken glass tumbler, and unidentified can fragment. P-3-909 CA-AMA-622 Greenstone quarry workshop and BRM's (four cups). P-3-910 CA-AMA-623 Greenstone quarry and workshop. Clusters of stones seen in are may represent hearths. P-3-911 CA-AMA-624 BRM on greenstone outcropping located on south side of east-west seasonal drainage; two shallow (incipient) cups noted. P-3-912 CA-AMA-625 Possible late period village site marked by eight saucer-shaped depressions on a sandy hill. 10 P# P-3-913 Trinomial CA-AMA-626 P-3-914 CA-AMA-627 P-3-915 CA-AMA-628/H P-3-917 CA-AMA-630H Site Description Small greenstone quarry and workshop located on five rock outcroppings. Lithic shatter observed throughout the area. Possible late period village site marked by six saucer-shaped depressions on hill. Several BRM loci in vicinity. Historic mining loci with debris: square nails, fragmented white porcelain, dark green bottle glass, and purple glass. Prehistoric site indicators include BRM (13 cups) on rock exposure and one pestle. Clay mine: large irregular-shaped pit with levee and stockpile remnants. In 2007, Far Western Anthropological Research Group conducted a cultural resources sensitivity and constraints analysis (Waechter et al. 2007). The study encompassed a 16,100acre area of Ione Valley between the Sacramento/Amador County line and the city of Ione. The current Newman Ridge Study Area was included in the larger 2007 study. Archival research, records searches, historical map review, and discussions with local Native Americans was carried out during the 2007 study. Field inspections were not conducted as part of the study. As a result of the 2007 analysis, six reported (but not previously recorded) cultural resources were identified within the current Newman Ridge Study Area (Table 3). Each of these reported locations was inspected during the current survey (see Field Survey Results below). Table 3. Cultural resources identified within the Newman Ridge Study Area according to archival and historical map research results from the Rancho Arroyo Seco/Howard Ranch Cultural Resources Sensitivity and Constraints Analysis (Waechter et al. 2007). Field No.* Description Location Reference HR-64 McDonald's North portion of Edwin Center Boyde (1917) Rancho Map Ditch HR-69 Road to Coal North portion of Edwin Center Boyde (1917) Rancho Map Mine HR-75 Reservoir North portion of Edwin Center Boyde (1917) Rancho Map HR-81 Pump House Northwestern portion of Edwin Center Boyde (1917) Rancho Map HR-82 Road From Galt Western portion of Edwin Center Boyde (1917) Rancho Map NA-21 "Pumphouse" Southern end of access road between Edwin Native American Personal Milling Station Center and Newman Ridge Quarry. Communication *HR: Historic-Period Resources; NA: Native American Cultural Sites. Portions of the study area have been surveyed in the past, including three studies conducted in the Edwin Center (AM-5213, AM-5240, and AM-6336) and one within the Newman Ridge Mine (AM-5218). In 1998, as part of the Reed Minerals permit study, Archaeological Consultant, Ric Windmiller conducted a 28-acre survey in what is now the northeastern portion of the Edwin Center (Windmiller et al. 1998, AM-5213). As a result of the study, two small post-World War II buildings used for explosives storage (P-3-899 and P-3-900), features associated with the Ione Coal and Iron Company's late 19th century Coal Mine No. 3 (P-3-901), and a modern truck scales site (P-3-902) were identified within the study area. Recommendations regarding project findings indicated that each of the cultural resources observed during the study either did not meet the criteria of eligibility for the California Register of Historical 11 Resources, or lacked the integrity to convey their historical importance (Windmiller et al. 1998). In 2004, the California Department of Transportation (Caltrans), contracted with Far Western Anthropological Research Group, Inc., conducted a cultural resources inventory of segments of rural conventional highways in Caltrans Central Region District 10, which included the segment of Hwy 104 that borders the northern edge of the Edwin Center (Leach-Palm et al. 2004, AM-5240). As a result of the study, a segment of the Southern Pacific Railroad's Ione Branch (P-3-765) was recorded within the Caltrans right-of-way. As noted in Table 1 above, P-3-765 passes through the north-northeastern portion of the Edwin Center. The State of California DPR 523 form originally prepared for P-3-765 was amended during the current project to include the approximately 2,850 ft. segment of track within the study area. The amendment also included the previously un-recorded Edwin Siding and loading ramp. In 1976, Ann S. Peak & Associates conducted a cultural resources study of the Interpace Properties located within Amador and Sacramento Counties (Ann S. Peak & Associates 1976, AM-6336). Approximately 10% of the landholdings near Ione, California were assessed during the project. A small portion of the 1976 study included what is now the north third of the Edwin Center. Although no cultural resources were identified within the current study area, three prehistoric sites were identified within the vicinity (P-3-179, -180, and 182). The project area is located within the vicinity of ethnographic villages Chakanesü and Upüsüni. Levy (1976:400, Fig.2) places Chakanesü on the south bank of Sutter Creek near Ione, and Upüsüni near Jackson Creek, approximately seven miles southeast of the Newman Ridge Study Area. The 1917 Map of the Ranch Arroyo Seco, Sacramento and Amador Counties (Boyde 1917) was reviewed during the current study. The 1917 map shows subdivisions of land within the Rancho (as surveyed by J.B. Robinson in 1893, and resurveyed by J.C. Boyde in July 1917), and depicts land owned by the Ione Coal and Iron Company, containing an area of 33,276.47 acres. It shows a number of features that were located within the study area, specifically within the Edwin Center. It does not depict any features within the Newman Ridge Quarry study area. The 1917 map suggests that the portal for Coal Mine No. 3 is located near the north corner of the Edwin Center, between State Hwy 104 and the Amador Branch Railroad right-of-way. This area also shows a reservoir located just south of the portal with a pipeline leading in and out of the reservoir to the east and west. The pipeline is referred to as "McDonalds Ditch" approximately one-mile to the northeast of the Edwin Center. Additional map features include the Amador Branch Railroad passing through the north portion of the study area, "Road to Coal Mine" entering the property from the northwest, a "Pump House" located on the west side of the Amador Ranch Railroad, "Road to Galt" entering the property from the west, and "Air Shafts" south of the "Road to Galt." The railroad siding at Edwin is not depicted on the 1917 Ranch map. The "Road from Martin Place to Coal Mine" runs northeast to southwest through the southern end of the proposed access road, along the north side of 12 Dry Creek. Up to the late 1950s this road connected with the current Dutschke Road, located to the northeast. Early historical maps do not show any buildings within the Edwin Center or Newman Ridge Mine (GLO #1 1859; Thompson 1877; USGS 1888 and 1907). The 1962 Sutter Creek USGS 15-minute map shows that the Edwin siding railroad spur is present and Loch Lane (the reservoir bordering the proposed access road) is present. Clay mining is prevalent within Dutschke Hill. However, no mining is indicated in the Edwin Center. The 1957 Sutter Creek USGS 15-minute map shows that Dutschke Hill is referred to as "Jones Butte." Clay mining is occurring on Jones Butte at this time. Edwin Siding is present but Loch Lane is absent, suggesting that the reservoir was constructed sometime between 1957 and 1962. The 1957 USGS map clearly shows that Dutschke Road connects to the historic county road to the southwest, referred to as "Road from Martin Place to Coal Mine" on the 1917 Boyde Rancho Arroyo Seco map. The 1941 and 1944 Sutter Creek USGS 15-minute maps show that the Edwin railroad siding is present but is shorter than that seen on the 1957-1962 USGS maps. A structure is located at the end of the spur, on the north side. No indications of clay mining are seen on Jones Butte. However, Carlson and Clark (1954:220) state that mining of Edwin clay at Jones Butte started as early as 1925. Field Survey Procedures Field survey of the Edwin Center and Newman Ridge Quarry was conducted by Eileen Barrow, Lauren Del Bondio, Phil Loyd, Tom Origer, and Eric Strother between December 20 and 22, 2010. Surface visibility was generally good, ground vegetation being a slight hindrance. A hoe was used as necessary to clear small patches of vegetation so that the soils could be inspected. A second field visit was conducted by Lauren Del Bondio, Tom Origer, and Eric Strother between January 10 and January 11, 2011, to record cultural resources identified during the December 2010 survey. Based on the results of pre-field research it was anticipated that cultural resources could be found within the study area. Prehistoric archaeological site indicators expected to be found in the region include but are not limited to: obsidian and chert flakes and chipped stone tools; grinding and mashing implements such as slabs and handstones, and mortars and pestles; bedrock outcrops and boulders with mortar cups; and locally darkened midden soils containing some of the previously listed items plus fragments of bone, shellfish, and fire affected stones. Historic period site indicators generally include: fragments of glass, ceramic, and metal objects; milled and split lumber; and structure and feature remains such as building foundations and discrete trash deposits (e.g., wells, privy pits, dumps). Knowing that the Edwin Center study area was the location of the Ione Coal and Iron Company Coal Mine No. 3 (P-3-901), it was anticipated that historic cultural materials would be present in the study area. Additional potentially sensitive areas identified by Waechter et al. (2007): HR-64, HR-69, HR-75, HR-81, and HR-82, were inspected during the survey. In the Newman Ridge Quarry study area, particular attention was given to areas near drainages and within the vicinity of Dry Creek, knowing that 11 bedrock mortar sites have 13 been identified within a one-mile radius. Rock outcroppings in the Newman Ridge Mine study area were inspected for evidence of rock shelters, quarrying and rock art. The previously recorded site locations of P-3-899 (concrete explosives storage building), P-3-900 (concrete explosives storage building), P-3-901 (site location of Coal Mine No. 3), and P-3902 (truck scales) within the Edwin Center were revisited and observations were made of their current condition. The reported location of NA-21, the Pumphouse Milling Station (Waechter et al. 2007:22), was inspected during the survey. Field Survey Results Archaeology Six historic archaeological resources were observed in the Edwin Center, one cultural resource was observed within the proposed road between the two study areas, and four archaeological resources were observed in the Newman Ridge Quarry during the field survey. No evidence of HR-64 (McDonald's Ditch), HR-69 ("Road to Coal Mine"), HR-75 (Reservoir), HR-81 (Pump House), HR-82 ("Road to Galt"), and NA-21 (Pumphouse Milling Station) was observed during the survey. Evidence of a possible assay pit was observed near the center of the Newman Ridge Quarry. A low-grade red siliceous stone was exposed at this location and appeared to have been disturbed by heavy equipment in the past, evidenced by bedrock exposure and tailings. It is likely that this disturbed area is evidence of earlier quarry exploration south of Newman Hill. Aside from three cut tree stumps located in the vicinity, no other cultural materials were observed, and no evidence of prehistoric quarrying was indicated at the exposure. Edwin Center P-3-765 (CA-AMA-540H), consisting of a segment of the Southern Pacific Railroad's Ione Branch, is located within the northern portion of the Edwin Center. The segment within the study area runs northwest to southeast and measures approximately 2,852 ft. in length. The previously unrecorded Edwin Siding (spur) diverts from the main line, on the east side of the tracks, for a distance of 1,414.50 ft. A wood and iron loading ramp is located on the east side of the spur. An earthen ramp is built up at the base of the loading ramp. P-3-901 (CA-AMA-614H) consists of collapsed mine shafts and water-filled pits that were likely associated with the Ione Coal and Iron Works Coal Mine No. 3. Features including collapsed shafts, water-filled depressions, trash scatter, earthen reservoir, and a dirt road, described by Windmiller (1998), were relocated during the current study, as the site is located within a portion of the Edwin Center. No changes were noted to any of the features within the previously recorded boundaries of P-3-901. However, at least four additional collapsed shaft pits and four trash scatters, likely associated with P-3-901, were identified within the current survey area (outside the previously recorded site boundaries), which resulted in the expansion of the site boundaries of P-3-901 to the north and northeast. A large mound of clay tailings intermixed with historic debris, is possibly the portal location of Coal 14 Mine No. 3 in the northern corner of the Edwin Center. This area is located between Hwy 104 and the Union Pacific Railroad. Artifacts include highly fragmented embossed brown bottle glass, aqua glass, brownware ceramics, non-diagnostic metal fragments, and metal strapping. P-3-902 (CA-AMA-615H), the location of the remains of a truck scale utilized during the post-World War II mining of laterite, was relocated during the current field inspection. Since its original recording in 1998, a wood and iron bridge has been built over the top of the scale to allow for the passing of heavy equipment in the area. Aside from the construction of the bridge, no additional changes were noted at P-3-902. NR-1 Trash Scatter. NR-1 consists of a small scatter of historic debris located north of Dutschke Hill, within the western portion of the Edwin Center. Artifacts, likely dating to the mid-twentieth century, include three screw-top condiment bottles (mustard, mayonnaise, and ketchup), one rusted coffee can, one clear glass milk bottle neck and lip, one rusted bucket (with handle), and one brown glass embossed Purex bottle. The scatter of artifacts measured approximately 25 ft. east-west, 18 ft. north-south, and was located on the north side of a unnamed seasonal drainage. Newman Ridge Quarry NR-2 Red Rock Rail Grade. NR-2 consists of a lightly-used quarry area, road cut, and historic metal debris scatter, located upslope near the eastern boundary of the road that will connect the Edwin Center with the Newman Ridge Quarry. A shallow graded road diverts from the main dirt road and continues upslope to the southeast to the site area, which is at the base of several rock exposures. Two semi-square pits have been dug out of the hillside. A site datum was established at the highest elevation in the southeast portion of the site, marked by a craggy Oak tree set back from the more southern of the two dug out areas. A segment of railroad switch track, measuring approximately 15.5 ft. long, was located in the center of the road cut near the southern end of the site. Two additional rusted metal equipment parts were also observed in the site area including the frame of a possible rail cart and a metal frame with hooks. An additional graded road is located down slope from the site. NR-3 Water Diversion Canal. NR-3 is a shallow water diversion canal located near the base of the northwest slope of Newman Ridge. The canal is oriented north-south and measures approximately 1,240 ft. long, 5-7 ft. wide, and is 4-6 ft. deep. Portions of the canal had standing water at the time of the survey, due to recent rains. This structure prevents erosion and diverts water runoff away from the agricultural pasture and dirt road located to the west. Map research indicates that the canal was constructed prior to 1962. NR-4 Quartz Biface. NR-4 is an isolated non-diagnostic quartz biface that was found on a gentle slope with eastern exposure, approximately 35 meters north of an unnamed seasonal drainage, and 35 meters west of the jeep road that runs north-south along Newman Ridge. The bifacially worked artifact measures 4.5 cm in length, 1.5 cm in width, and is 1 cm thick. 15 NR-5 Rock Alignments. Site NR-5 represents ten rock alignments (A-J) located in the southeast portion of the Newman Ridge Mine study area (Table 4). The approximate center of each alignment was recorded with GPS. Table 4. NR-5 Rock Alignments Locations and Attributes Rock Alignment Length Width Height A 21 ft. 2.5 ft. ~2.5 ft. B 13.5 ft. 2.5 ft.-3 ft. ~3 ft. C ~54 ft. 3 ft.-5.5 ft. 1.5 ft.-3 ft. D E F G H I J 79 ft. 14.5 ft. 20 ft. 8 ft. 15 ft. 34 ft. 7.5 ft. ~1 ft.-3.5 ft. 3 ft. 2 ft.-3 ft. ~3 ft. ~2 ft.-3.5 ft. ~2 ft. 2 ft.-3 ft. 9 in.-3 ft. 1.5 ft.-2 ft. 2 ft.-3 ft. ~3.5 ft. ~3 ft. ~1.5 ~2 ft. Orientation 114° E/SE 140° SE 170° S 145° S/SE 133° SE 160° S/SE 137° SE 162° S 102° E 150° SE 80° E Courses High 2-3 3-4 2-4 1-2 2-3 2-3 3-4 2-3 1-2 2-4 These rock alignments generally run in-line with one another (north-to-south), and most are connected by larger rock outcroppings. Stacked rocks within the alignments range from about 1 ft. to 3.5 ft. in diameter. Some smaller rocks are placed between rock outcroppings. It is unknown when these alignments were constructed, or what they represent. NR-6 Bedrock Mortar.NR-6 is the location of two bedrock mortars on a rock outcrop, approximately 30 m south of an unnamed drainage. NR-6 is located near the southern boundary of the Newman Ridge Mine study area. The mortars are circular in shape and are situated 50 cm apart from one another. Cup "A," located northwest of Cup "B" is 14 cm in diameter and 4.25 cm deep. Cup "B" is 12 cm in diameter and 4.5 cm deep. Built Environment P-3-899 and P-3-900 are two identical concrete storage buildings located in the northwest portion of the Edwin Center, south of the main access road. They are separated by approximately 110 ft. These small structures were put up by Permanente Cement Company around 1948 to store explosives for clay mining in the area (Napoli 1998a and 1998b). This standing structures were observed in a similar condition as they were described during their initial recording in 1998 (Napoli 1998a and b; Windmiller 1998a). SUMMARY Tom Origer & Associates conducted a cultural resources survey for the Newman Ridge Project, Amador County, California, in compliance with requirements specified in both Section 106 and CEQA (Title 14 CCR §15064.5). The study was requested and authorized by Edwin Clays LLC. 16 Field survey resulted in the finding of five previously recorded cultural resources and six newly identified cultural resources. Documentation pertaining to this study is on file at the offices of Tom Origer & Associates (File No. 10-102). 17 MATERIALS CONSULTED Ann S. Peak & Associates 1976 Cultural Resource Assessment of the Interpace Properties, Amador and Sacramento Counties, California. Document AM-6336 on file at the North Central Information, California State University, Sacramento. Boyde, J.C. 1917 Map of the Rancho Arroyo Seco in Sacramento and Amador Counties, California. Carlson, D.W. and W.B. Clark 1954 Mines and Mineral Resources of the Amador County, California. In California Journal of Mines and Geology, pp. 149-285. Vol. 50, No.1., San Francisco, CA. Chapman, R.H. and C.C. Bishop 1975 Geophysical Investigations in the Ione Area, Amador, Sacramento, and Calaveras Counties, California. California Division of Mines and Geology, Special Report 117 Sacramento, California. General Land Office 1859 Plat of Rancho Arroyo Seco (GLO#1). Department of the Interior, Washington, D.C. Hoover, M., H. Rensch, E. Rensch, W. Abeloe 1966 Historic Spots in California. 3rd edition. Stanford University Press. Stanford. Hoover, M., H. Rensch, E. Rensch, W. Abeloe, and D. Kyle 1990 Historic Spots in California. 4th edition, Stanford University Press. Stanford. 2002 Historic Spots in California. 5th edition, Stanford University Press. Stanford. Kroeber, A. 1925 Handbook of the Indians of California. Bureau of American Ethnology, Bulletin 78, Smithsonian Institution, Washington, D.C. Larson, B. and R. Flores 2002 Record prepared for P-3-765. On file at the North Central Information Center, California State University, Sacramento. Leach-Palm, L., J. King, J. Hatch and B. Larson 2004 Cultural Resources Inventory of Caltrans District 10 Rural Conventional Highways. Volume II B: Amador County. Document AM-5240 on file at the North Central Information Center, California State University, Sacramento. 18 Levy, R. 1978 Eastern Miwok. In California, edited by R. Heizer, pp. 398-413. Handbook of North American Indians, Vol. 8, W. Sturtevant, general editor. Smithsonian Institution, Washington, D.C. Moratto, M. 1984 California Archaeology. Academic Press, San Francisco. Napoli, D.S. 1998a Record prepared for P-3-899. On file at the North Central Information Center, California State University, Sacramento. 1998b Record prepared for P-3-900. On file at the North Central Information Center, California State University, Sacramento. Office of Historic Preservation (OHP) 1995 Instructions for Recording Historic Resources. Office of Historic Preservation, Sacramento. 2009 Historic Property Directory. Office of Historic Preservation, Sacramento. State of California Department of Parks and Recreation 1976 California Inventory of Historic Resources. Department of Parks and Recreation, Sacramento. Thompson & West 1881 History of Amador County, California. Pacific Press Publishing House, Oakland, California. Thompson, T.H. & Co. 1877 Historical Atlas of Amador County, California. T.H. Thompson & Co., Oakland, California. United States Department of Agriculture (USDA) 2011 Web Soil Survey. Online document accessed http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx United States Geological Survey 1888 Jackson 15’ quadrangle. Geological Survey, Washington, D.C. 1907 Carbondale 15’ quadrangle. Geological Survey, Washington, D.C. 1957 Sutter Creek 15’ quadrangle. Geological Survey, Washington, D.C. 1962 Ione 7.5’ quadrangle. Geological Survey, Washington, D.C. 19 January 2011: 1962 Irish Hill 7.5’ quadrangle. Geological Survey, Washington, D.C. Villa, G., Sr. and G. Villa Jr. 2011 Personal Communication. Notes on file with Tom Origer & Associates, Rohnert Park, California. Waechter, S.A., J. Meyer, J. King, S. King, and J. Marvin 2007 Rancho Arroyo Seco/Howard Ranch Cultural Resources Sensitivity and Constraints Analysis. Unpublished document on file with Mintier & Associates, Sacramento. Windmiller, R. 1998a Record prepared for P-3-901. On file at the North Central Information Center, California State University, Sacramento. 1998b Record prepared for P-3-902. On file at the North Central Information Center, California State University, Sacramento. Windmiller, R., D.S. Napoli and J. Russell 1998 Phase I Cultural Resources Inventory, Reed Minerals Permit Area, Amador County, California. Document AM-5213 on file at the North Central Information Center, California State University, Sacramento. 20 Ric Windmiller C O N SU LTIN G AR C H AEO LOG IST 2280 G R ASS VALLEY H IG H W AY #205 AU BU RN , C ALIFO R N IA 95603 530/878-0979 FAX 530/878-0915 January 30, 2012 Raney Planning & Management, Inc. 1501 Sports Drive Sacramento, CA 95834 Attn: Mr. Rod Stinson, Division Manager Re: Newman Ridge Project EIR Dear Mr. Stinson: The following review covers four documents that you submitted to me: · · · · Draft cultural resources section from the EIR Tom Origer and Associates May 6, 2011 Cultural Resources Survey (report) for the Newman Ridge Project, Amador County, California (Authors: Eric Strother and Lauren Del Bondio). Tom Origer and Associates October 11, 2011 Cultural Resources Survey (report) for the Newman Ridge Project, Edwin Center North Option, Amador County, California (Author: Eileen Barrow). Site record forms for Ione Coal and Iron Company Coal Mine No. 3 (CA-AMA-614-H) Strother and Del Bondio Report On July 8, 2011, I completed a review of the May 6, 2011 report, “A Cultural Resources Survey for the Newman Ridge Project, Amador County, California” by Eric Strother and Lauren Del Bondio, Tom Origer and Associates. In that review, I pointed out that the objective of the report was to provide information sufficient to address the cultural resources checklist of CEQA’s Appendix G. The cultural checklist includes any historical resources, archaeological resources, unique paleontological resources, unique geological features and any human remains including those interred outside formal cemeteries. Historical resources include any object, site, building, structure or district listed in or eligible for the California Register of Historical Resources (PRC §15064.5). Archaeological resources may also be “historical resources” or meet criteria as “unique archaeological resources” (PRC §21083.2). Unique paleontological resources are referenced in PRC §5097.5. Human remains are covered in CEQA §15064.5 and PRC §5020-5024, 21084.1. Page 1 The Strother and Del Bondio report did not include a database search or field inspection by a qualified paleontologist to identify paleontological resources or to evaluate the potential for finding unique paleontological resources once the project is underway. Although the report did identify other cultural resources, it did not evaluate those resources for California Register of Historical Resources eligibility or determine if they meet criteria as “unique archaeological resources” under CEQA. The report did not assess potential impacts to cultural resources, nor did it recommend mitigation measures. The report did not include the usual technical appendices such as the records search report from the information center, a map showing the location of identified cultural resources and DPR 523 series forms, which constitute an important part of the cultural resources identification process and documentation necessary for determining significance. A second copy of the May 6, 2011 Strother and Del Bondio report was included in the current package of documents for peer review. This latest copy of the report appears unaltered from the original, which was reviewed back in July, 2011. Therefore, the conclusions from the review back then still apply. Barrow Report The Strother and Del Bondio report covered both Newman Ridge Quarry and Edwin Center. Edwin Center is a proposed location for material processing plants and a railroad load-out facility. The proposed location of industrial plants and load-out construction encompassed a triangular-shaped property on the northeast side of the Union Pacific tracks between Dutschke Road on the southeast and the intersection of Highway 104 and the railroad on the northwest. The location also included a polygon-shaped area on the southwest side of the tracks between the railroad and Dutschke Hill. On October 11, 2011, Tom Origer and Associates issued a second report titled, “A Cultural Resources Survey for the Newman Ridge Project, Edwin Center North Option, Amador County, California” by Eileen Barrow. This second report encompassed an optional configuration for Edwin Center encompassing the northwest portion of the previous triangular-shaped property between Highway 104 and the railroad and a polygon-shaped piece along the south side of Highway 104 northwest of the triangle formed by the intersection of 104 and the railroad. Although the Ione basin and surrounding lands are rich in history, the historic context write-up in the Barrow report is a brief two pages. The Native American Heritage Commission sacred lands file search and contact with Native Americans listed by the commission was deferred to the EIR consultant. The records search was apparently conducted by Tom Origer and Associates at the North Central Information Center and not by information center staff, as no copy of the records search letter report and the usual attachments are appended to Barrow’s report. This is not unusual, but it can lead to an omission of records if the visitor to the information center has less experience than information center staff. Field methods described in the Barrow report indicate that four people expended two days inspecting the subject property. However, the description does not indicate the specific field methods such as distance between transects walked, so that the reader can assess the adequacy of the field survey. The use of historic maps and discussion with the property manager were well-thought-out methods to help identify the age and function of features found during the field inspection. Thus, potential problems in evaluating the significance of those features were avoided. Omitted from the report’s “Cultural Setting” is discussion Page 2 of the Nisenan Indian village of Homit, which is reputed to have been located on Indian Hill immediately adjacent to the Edwin Center project area. It would have been interesting to investigate the bedrock mortar site, CA-AMA-145, for buried cultural materials to see if any are historic and therefore potentially associated with the occupation of nearby Homit. However, as Barrow indicated, the bedrock mortar site is located outside the project area. Barrow’s description of the surface remnants of identified cultural resources located within the project area is brief, but appears adequate. The report concludes with a brief summary. There is no evaluation of the identified cultural resources for California Register of Historical Resources eligibility or identification of “unique archaeological resources” or unique paleontological resources under CEQA. The report does not include an analysis of effect, nor does the report recommend any mitigation measures. The report did include an appendix of DPR 523 series record forms documenting each identified archaeological resource. The Barrow report is strictly a cultural resources inventory. Neither the Barrow report nor the earlier Strother and Del Bondio report address the questions asked in the CEQA Checklist, Appendix G such as: Will the project cause “ . . .substantial adverse change to a historical resource?” To answer this question, both the Barrow and Strother and Del Bondio reports would have to include an evaluation of the identified cultural resources for California Register eligibility and “unique archaeological resources” and determine the effect of the project on those resources. In addition, there are omissions in the historic context statements in both reports that could have made a difference in how the field inspections were conducted and what was found by the field survey teams. For example, there is no mention of the historic townsite of Doschville and no discussion as to whether or not some of Doschville may have been located within the Edwin Center project area. Also omitted from the historic context statements is the early history of the Rancho Seco land grant when the first settlers took up residence on the land with the understanding that it was government owned, only to be evicted years later by the land grant’s owners. Understanding these and other elements of local history may have given the field teams cause to look for more subtle features on the landscape indicative of buried historic sites and features relating to Doschville and early homesteads never recorded in public domain. However, for purposes of this review, it is assumed that the field inspections were adequate and no significant cultural resource was overlooked. Site Record Forms for Ione Coal and Iron Company Coal Mine No. 3 The record forms for Coal Mine No. 3 document additional surface features for the site of Ione Coal and Iron Company’s Coal Mine No. 3. The record forms include two loci. The northernmost locus represents the mound on which the sealed portal of the mine’s inclined shaft is located. The southernmost locus is a broad area on both sides of the railroad tracks where surface features such as subsidence pits and collapsed ventilator shafts overlie the underground workings. Previous drill tests over the site identified voids as little as 34 feet below the ground surface. Although there is readily accessible information on the mine, the Archaeological Site Record form does not provide any information on “A4. Features,” “A5. Cultural Constituents,” “A7. Site Condition,” “A11.Historical Information,” “A12. Age,” “A13 Interpretations,” “A15. References,” all of which could have been filled in with information from an adequate records search at the information center. Page 3 Cultural Resources Section of the Draft EIR The cultural resources section of the draft EIR includes an introduction, existing environmental setting, regulatory setting, impacts and mitigation measures. The primary basis for analysis presented in the Cultural Resources Section is the Amador County General Plan, the Strother and Del Bondio report and the Barrow report. Six cultural resources were identified on the Edwin Center portion of the project. One cultural resource was found within the proposed road between Edwin Center and the Newman Ridge Quarry and four resources were identified within the boundaries of the Newman Ridge Quarry. The Edwin Center cultural resources include the Southern Pacific Railroad Ione Branch (now, Union Pacific), Ione Coal and Iron Company’s Coal Mine No. 3, a post-World War II truck scales, a historic trash scatter and two concrete explosives storage buildings. Three cultural resources were identified in the Barrow report for the Edwin Center North Alternative project area: the Southern Pacific Railroad, Ione Branch segment, surface remnants of Ione Coal and Iron Company’s Coal Mine No. 3 and the Newman Pond and Ditch. The Strother and Del Bondio report identified the Red Rock Rail Grade site within the proposed road between Edwin Center and the Newman Ridge Quarry. The draft EIR states that the site had been previously recorded, therefore, “destruction of the resource due to implementation of the proposed project would not be considered a significant impact” (page 4.4-7). The four cultural resources identified by Strother and Del Bondio within the Newman Ridge Quarry project area includes a previously recorded water diversion canal, quartz biface and rock alignments. The above resources had all been documented on site record forms prior to the Strother and Del Bondio study. In addition, Strother and Del Bondio identified two bedrock mortars on a rock outcrop located near the southern boundary of the proposed quarry. The Draft EIR does not formally evaluate any of the above cultural resources for California Register eligibility, nor does it address the potential for assessing archaeological resources as “unique archaeological resources” under CEQA. Previously documented cultural resources are addressed with the statement: “It should be noted that this resource has been previously recorded. As such additional historical information cannot be obtained from this resource; thus, destruction of the resource due to implementation of the proposed project would not be considered a significant effect” (pages 4.4-7, 4.4-8). If the respective cultural resources have been previously evaluated for California Register eligibility and/or as “unique archaeological resources,” then those analyses should be documented in the EIR and any updated information on their condition evaluated to determine if there has been a significant change to warrant a change in the previous evaluation. The formal evaluation for California Register eligibility must have been completed either in a prior study or in the EIR. Lacking such an evaluation, all cultural resources identified must be considered eligible for the California Register. Page 4 Newman Ridge Quarry With respect to the Newman Ridge Quarry portion of the project, it is unlikely that either the water diversion canal, isolated quartz biface or the rock alignments (probably the remnants of a rock and brush or rock and wire fence line) are eligible for the register. Nonetheless, no argument for or against any one or more criteria of eligibility was made in any of the documents presented for review. On the other hand, the two bedrock mortars identified within the Newman Ridge Quarry project area were determined potentially eligible for the California Register also without a formal evaluation. In this consultant’s experience, isolated bedrock mortars are usually not eligible for the California Register under any criterion of eligibility. These days, it is customary to conduct test excavations around such bedrock milling stations to identify any buried cultural deposit. While the merits of such excavation are debatable, this approach does add another point of argument either for or against California Register eligibility. Such testing was apparently not undertaken. Road between Newman Ridge Quarry and Edwin Center The Red Rock Rail Grade site located within the proposed road between the quarry and Edwin Center may or may not be eligible for the California Register, or qualify as a “unique archaeological resource.” Apparently, it was recorded during a previous cultural resources study. If it had been evaluated for California Register eligibility at that time, or even if it had been evaluated under CEQA’s old Appendix K, then the results of that evaluation should be presented and an update on its condition should help to determine whether or not it retains that same eligibility or ineligibility today. Edwin Center With respect to the Edwin Center project area, the two concrete structures documented in a previous study are treated in the Draft EIR with this statement: “It should be noted that this resource has been previously recorded. As such, additional historical information cannot be obtained from this resource; thus, destruction of the resource due to implementation of the proposed project would not be considered a significant impact” (page 4.4-10). In fact, the two small concrete storage buildings were previously evaluated for the California Register and the National Register of Historic Places by my colleague, architectural historian Donald S. Napoli, Ph.D. Napoli concluded that neither building was eligible for listing on either register. However, his evaluation did not hinge on the fact that he recorded the site on DPR 523 series forms and no additional information could be obtained from the buildings. His analysis states, “The structure lacks historical importance because the episode it recalls occurred within the past 50 years and had only minimal impact on Amador County.” However, that evaluation was made in 1998. The two buildings are now over 50 years old and should be re-evaluated for the California Register. The other cultural resources identified for Edwin Center include the Southern Pacific Railroad Ione Branch segment, truck scales, trash scatter and Ione Coal and Iron’s Coal Mine No. 3. The railroad is mentioned in the Draft EIR as having been previously recorded. As such, any effect would not be considered a significant impact. Again, if the railroad was previously evaluated for California Register Page 5 eligibility, then the results of that evaluation should be referenced and any changes in the railroad since that evaluation should also be evaluated. The result would be a current assessment of the railroad’s eligibility for the California Register. The remnants of the old truck scales were previously evaluated for California Register eligibility in the same study in which Napoli documented and evaluated the concrete storage buildings. At the time (1998), the truck scales were considered to be less than 50 years old, which was part of the reason why they were not eligible for the California Register. Now, the scales site may be older than 50 years and may require re-evaluation. The trash scatter identified by Strother and Del Bondio in the western portion of Edwin Center is identified on the basis of surface debris only. Apparently, there is a potential for buried trash at this site. Further testing is required in the Draft EIR. However, prior to any archaeological test excavation, it would be prudent to first gain as much information as practical on historical association(s) of the trash scatter. Find out what household or mining operation with which it was associated. Then, make a decision as to whether test excavations would be advisable. For example, excavation of trash deposits in the backyards of historic Washington, D.C. houses provided information on differences between historic neighborhoods. Such information not available in written histories can be important to understanding day to day life if the trash deposit can be linked to a specific household, class of households, mine or other entity. The segment of the Southern Pacific Ione Branch located within the Edwin Center project area was apparently recorded in a previous study not accessed by the EIR team. The Draft EIR states that the railroad was previously recorded. Therefore, additional historical information cannot be obtained from the resource and so any effect caused by the proposed project would not constitute a significant impact. There is no reference in the EIR as to whether the railroad was indeed previously evaluated for the California Register and determined not eligible (page 4.4-8). The Draft EIR states that the significance of Ione Coal and Iron Company’s Coal Mine No. 3 is currently unknown and that further testing is required to determine whether recordation is necessary and whether or not the proposed project would have a significant effect on the cultural resource (page 4.4-9). Coal Mine No. 3 was evaluated for the California Register in 1998. At that time, we considered the mine potentially eligible for the California Register under criterion 1: “is associated with events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States.” However, the portion of the surface features of the mine located within our limited project area were not considered eligible for the register under any criterion. Our study did not include the mine portal or the area between the portal and our project area. Coal Mine No. 3 was active between 1886 and 1900. Eileen Barrow’s report and the Draft EIR are correct when they identified the large mound in the north corner of Edwin Center as the location of Coal Mine No. 3's inclined shaft portal. Apparently, the portal was located on an elevated mound to facilitate loading of lignite onto railroad cars. Published sources available in the Bureau of Mines Library in Sacramento specify the methods of underground mining at Coal Mine No. 3. It is unknown whether or not surface cultural deposits exist within the Edwin Center project area that would add significantly to our limited knowledge of operations Page 6 on the ground surface and whether or not we could discern and explain, for example, any meaningful differences and similarities between this and other similar mines on the basis of technology, environment, social class and social structure. Further archival research as well as testing should be recommended for this potentially important site. Edwin Center North Alternative The Edwin Center North Alternative includes three identified cultural resources: a segment of the Southern Pacific Railroad Ione Branch, some of the surface features of Ione Coal and Iron’s Coal Mine No. 3 and the Newman Pond and Ditch (see discussion above for the first two cultural resources). The Draft EIR states that further testing would be required to determine whether recordation is necessary. I would suggest that further archival research and interview(s) with knowledgeable local old timers would best help determine whether or not the resource is eligible for the California Register under any of the four criteria of eligibility. Consideration may then be given the pond and ditch as a“unique archaeological resource.” Mitigation Measures In view of the above comments, I would recommend incorporating the following changes to the Mitigation Measures: 4.4-1(a). If the coal mine and trash scatter features cannot be avoided, then an evaluation plan should include archival research and/or interviews with knowledgeable individuals followed by archaeological test excavations if the results of archival research and/or interviews indicate testing as the most feasible means of determining significance. If the cultural resource is determined eligible for the California Register under one or more criteria of eligibility and cannot be avoided, then a data recovery plan or other mitigation shall be determined and executed. 4.4-1(b) Incorporate same changes as in 4.4-1(a). In summary, it is apparent that the cultural resources consultant conducted only cultural resources inventories of the proposed Newman Ridge Quarry, connecting road, Edwin Center and Edwin Center North Alternative. There was no effort on the part of the cultural resources consultant to evaluate the identified resources for California Register of Historical Resources eligibility, or in the case of previously evaluated resources, to conduct an updated evaluation based on current condition of the resources. Also, the cultural resources consultant did not evaluate the potential effect of the project on resources significant under CEQA nor did the consultant propose any mitigation measures. The EIR consultant was left with the task of determining eligibility, which was done by assuming that all of the identified resources are significant, then assigning further tasks to evaluate significance as “mitigation.” This approach is all too commonplace in EIRs, according to California Office of Historic Page 7 Preservation staff. The problem is a “blind spot” in CEQA where decisions on significance can end up in the laps of non-cultural resource EIR writers. Even though evaluation for California Register eligibility is deferred to the Newman Ridge Project Draft EIR mitigation measures, your staff has done a much better job than found in a lot of similar EIRs, in my opinion. I made a few suggestions with respect to wording in the mitigation measures to show that in some cases, it is more appropriate to begin the evaluation of a historic site by more intensive archival research and/or contact with local old-timers or avocational historians who may be familiar with the resources. If such research meets with success, with for example finding a historic connection between the trash scatter and a specific household or mine, then significance may possibly be determined without archaeological test excavations. The reverse, conducting test excavations without prior archival research or oral history, may yield no clues as to specific historic associations and therefore may waste time and money and result in a possible spurious evaluation. In some cases, it may be necessary to conduct extensive archival research, interviews and test excavations to arrive at an appropriate evaluation of the site for California Register eligibility or to determine if the site is a “unique archaeological resource.” If you have further questions, please feel free to contact me. Yours sincerely, Ric Windmiller Page 8