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Executive Summary The City of Santa Clarita should request to be a
signatory and consulting party to a MOA to guide
the implementation of Section 106. [800.6(a)(2)]. The
The purpose of the research work completed for this
MOA would specify the scope of additional surveys and
review of the EIR and EIS for the Southdown-Transit Mix
other studies, the nature and scope of historic property
Concrete project was to determine if the studies completed
evaluation efforts, and procedures for resolving adverse
for these documents accurately, fairly, and completely
effects. Other interested parties may be invited to
described the cultural properties within the TMC project
participate in the MOA and these may include Native
boundary. For the purposes of this analysis, cultural
American tribes. This agreement should be used to
properties were defined as archaeological and historic sites,
ensure that the cultural properties in the TMC project
locations of ethnohistoric and ethnographic significance,
boundary and Area of Project Effect are not destroyed
and plants and animals with cultural value to contemporary
either inadvertently or deliberately by Southdown-TMC
native Californians. The research revealed:
or cultural resource consultants retained by the applicant.
Extraordinary measures should be applied to the study and
I. The project area is within an area that is
protection of these sites.
recognized as significant for its archaeological record of
Tataviam history and lifeways.
Impacts to cultural resources effect both native Californian
descendents and the scientific community which serves as
II. The project area contains many native plants that
the custodian of the ideas, research interests, and cultural
were important to native peoples as food, construction
history which is embedded in cultural properties. The
material and medicine.
EIR and EIS fail to address the historic, archaeological
and ethnographic resources present in ths project area.
III. The project area contains at least three Native
The findings of this preliminary report on the cultural
American sites. The sites contain different artifacts and
properties within the TMC property bounday require
features and were apparently camps used for different
reopening the public review process for this project.
purposes. Site records documenting these deposits are
filed along with a copy of this report at the South Central
Archaeological Information Center at CSU Fulerton.
IV. The archaeological evaluation used to prepare the
EIR and EIS is substandard and does not conform with
practices of current anthropological and archaeological
methods of evaluation. As a consequence of deficiencies in
method, at least three significant cultural properties were
not identified.
V. Closure of the BLM public review and analysis
process for cultural resources is premature and this process
must be reopened to avoid a foreclosure situation under the
Historic Preservation Act.
VI. A complete survey and testing program needs to
be performed under the guidance of the BLM and SHPO
to adequately determine the impacts of this project on
the cultural resources within the project boundary and
immediately adjacent areas which will be effected by
riparian water drawn-down.
VII. The cultural resource evaluation did not include
proper review of archaeological, ethnographic,
ethnohistoric, or historic source materials.
VIII. The evaluation also failed to include any
assessment of the impacts of the project or its effects
on living native Californian groups or individuals with
historic or cultural ties to the Southdown-TMC property.