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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.
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