HomeMy WebLinkAboutAppendix K.2 - Archeological Addendum Letter
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SAN DIEGO | OAKLAND | TUCSON
July 19, 2023
Ms. Janice Kluth, AICP City of Chula Vista
Development Services Department
276 Fourth Avenue
Chula Vista, CA 91910
Reference: Nakano Project - Addendum to Historical Resources Inventory and Evaluation Report for the Nakano
Project (RECON Number 3396-1)
Dear Ms. Kluth:
The letter serves as an addendum to the Historical Resources Inventory and Evaluation Report for the Nakano
Project (project), City of Chula Vista, San Diego County, California dated February 2022, prepared by Dudek.
Subsequent to approval of the Dudek report (2022), the applicant incorporated proposed off-site trail improvements
in addition to the proposed on-site trails already evaluated as part of the Dudek report. Additionally, an off-site wetland mitigation area is now proposed. To complete the February 2022 Dudek report, this letter details the results of additional cultural resources surveys conducted for the off-site trail improvement area (Figure 1) and the wetland
mitigation area (Figure 2).
Additionally, based on RECON’s review of the Dudek report, minor clarifications are provided below to clarify the use
of terms.
Cultural Resources Surveys for Off-site Trail Improvement Area and Nakano Wetland Mitigation Area
Since approval of the February 2022 Dudek Report, off-site trail improvements are now proposed just north of the project parcel within the Otay Valley Regional Park (OVRP) on a property known as the Davies Property (Assessor’s
Parcel Number 02-41-346-02), as depicted on Figure 1. The proposed trail would follow the location of an existing
informal trail alignment within disturbed land on the Davies property. The off-site trail improvements would consist of
placement of decomposed granite within an eight-foot-wide trail alignment. Peeler pole fencing would be installed
on one side of the trail. No grading is required for the off-site trail improvement and ground disturbance associated
with the off-site trail improvement would be limited to digging fence post holes for the trail fencing.
Nakano wetland mitigation area is located off-site, in the city of San Diego, south of State Route 905 and east of Interstate 805 (see Figure 2). The mitigation area is approximately three miles southeast of the project area within
Spring Canyon, in the City of San Diego Multi-Habitat Planning Area (MHPA) Preserve, on Tri Pointe Homes property.
The mitigation area is surrounded by open space and occurs within existing riparian and disturbed habitat. The
proposed compensatory mitigation project would provide 0.80 acre of wetland mitigation via the restoration of
degraded wetlands which would be achieved off-site at the Spring Canyon location.
RECON conducted additional cultural resources surveys of the off-site trail improvement area and the wetland
mitigation area. The primary goal of the pedestrian reconnaissance investigation was to survey the additional project
impact areas associated with the trails and the wetland restoration area and determine if there are previously
unrecorded cultural resources present, and if so, document the resources’ locations and what they consist of. RECON
archaeologist Nathanial Yerka accompanied by Clinton Linton from Red Tail Environmental conducted the on-foot
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survey of the off-site trail improvement area on November 1, 2022, using no more than two-meter spacing. Mr. Yerka
was later accompanied by Anthony LaChappa from Red Tail Environmental on June 15, 2023, and conducted the
on-foot survey of the Nakano wetland mitigation area using no more than 15-meter spacing. The survey areas were
inspected for evidence of archaeological materials such as flaked lithic debris, flaked and ground stone tools,
ceramics, milling features, and human remains.
Background Research
RECON reviewed the record search materials obtained by Dudek (2022) and confirmed no previously recorded
cultural resources occur within the proposed off-site trail improvement area. RECON also reviewed topographic maps
and historic aerial photographs and confirmed that no buildings or structures have existed within the additional
survey area. The earliest available aerial photograph is from 1953 and exhibits the survey area subject to agricultural
disturbance. Between 1978 and 1980 the eastern portion of the survey area suffered surface materials dumping and
by 1989, the survey area was fully graded and was used as a vehicle or trailer storage area (Converse Consultants
2022).
For the wetland mitigation area, RECON reviewed in-house record search materials obtained for the concurrent
Tri Pointe Homes Southwest Village project (Confidential Figure 1; RECON 2023) and noted one previously recorded
cultural resource is located within the wetland mitigation area—CA-SDI-10,811. RECON also reviewed topographic maps and historic aerial photographs and confirmed that no buildings or structures have existed within the wetland
mitigation area. The earliest available aerial photograph is from 1953 and exhibits the survey area with several footpaths and off-road vehicle (ORV) alignments running alongside as well as crossing the drainage area of Spring Canyon. By 1964, the prominent east-west ORV alignment crossing the southern end of the mitigation area is
exhibited along with the associated culvert. Subsequent years represent little variation other than certain alignments becoming overgrown with vegetation where others appear to be favored for use (Nationwide Environmental Title
Research LLC 2023).
CA-SDI-10,811
CA-SDI-10,811 is described as being located on a small river terrace bench on the eastern side of the Spring Canyon drainage where Spring Canyon meets Wruk Canyon. The site was described as a habitation site based upon the dark
color of the soil, the types and distribution of artifacts, and presence of subsistence debris in the form of marine
shellfish remains. The site was measured as occupying a 50-by-50-meter area and was surface-collected and tested in
1986 by WESTEC Services, Inc. The surface collection yielded 247 flakes, 94 angular waste fragments, 1 scraper
fragment, and 5 utilized/modified flakes, while the subsurface component yielded 77 flakes, 141 angular waste
fragments, 3 cores, 2 mano fragments, and 1 scraper. It was noted that the eastern portion of the site appears to be
intact save for areas of bioturbation; however, the eastern portion of the site may have eroded away by the action of
the Spring Canyon drainage. The site was determined not a significant historical resource by WESTEC Services
(Cheever 1986).
Survey Results
Off-Site Trail Improvement Area
No additional prehistoric or historic cultural material was observed during the survey. The survey started at the northwest project area corner and proceeded east along the proposed trail improvement alignment (see Figure 1;
Photographs 1 and 2). The area is fully disturbed by grading and surface debris, as well as current off-road vehicle
usage. Noted surface items include piled and dispersed concrete and asphalt rubble, construction debris including
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assorted metal, plastics, ceramics, and dimensional lumber, a dilapidated chain-link fencing alignment, discarded
whole and fragmented wooden utility poles, a discarded reinforced concrete stormwater/sewer pipe section,
imported base gravel, dumped vegetation waste materials, and dispersed modern rubbish.
Nakano Wetland Mitigation Area
No prehistoric or historic cultural material was observed within the wetland mitigation area during the survey. The
survey commenced from the southern end of the wetland mitigation area, on the east side of the drainage and moved north. The survey finished on the west side of the drainage at the southern end of the survey area. The
wetland mitigation area exhibited moderately shallow to approximately 15-foot-tall side slopes that varied in severity
of steepness, with dense riparian vegetation cover, along with several smaller areas that were flat and open with
dense and matted seasonal grasses. The drainage bottom is a scoured cobble-laden channel that varied in width
between 3 to 10 feet with 1- to 5-foot-tall vertical sidewalls. RECON visited the South Coastal Information Center
(SCIC) mapped location of CA-SDI-10,811 and did not observe any site material. The absence of site material is
consistent with the provided information within the recording of CA-SDI-10,811, that the cultural material within the
site area was surface collected; however, the provided locational description of CA-SDI-10,811 is inconsistent with the physical setting of the current mapped boundary. RECON believes the terrace upslope and adjacent to the east—
outside of the current project boundary—better fits the physical setting provided within the recording of CA-SDI-10,811. Several isolated lithics were observed at the crest of the upslope terrace, near the wetland mitigation
area but no tools or concentrations were noted. These isolated flakes are interpreted as part of the erosion of the likely location of CA-SDI-10,811.
Management Recommendations
No significant or potentially significant prehistoric or historic cultural resources were located during the survey of the
trail improvement area. The South Coastal Information Center (SCIC) records search results do not indicate previously
recorded cultural resources mapped within the additional survey area; however, the Dudek (2022) study did identify
two previously recorded resources (P-37-007983 and P-37-026987) as well as two newly recorded resources
(NK-S-001, and NK-S-002) within the project site; these resources were all recommended not significant under the California Environmental Quality Act (CEQA; Dudek 2022). The possibility of buried significant cultural resources being
present within the developed trail improvement area is considered low due to the fact that no grading is required
and limited disturbance would occur associated with installation of fence posts. Additionally, considerable past
ground disturbance has reduced the likelihood of any near surface resources. Because of the disturbed condition of
the additional survey area, including its current use as an informal trail, RECON recommends no additional work or monitoring in this area. Impacts to cultural resources associated with off-site trail improvements would be less than significant. However, since the Dudek historical resources report (2022) recommends archaeological monitoring
during construction as project mitigation, this requirement would be applied to the entirety of the site including off-site improvement areas. The required mitigation measure entails preparation of an archaeological monitoring
exhibit which would allow the areas that require monitoring to be refined based on the sensitivity and proposed disturbance.
No significant or potentially significant prehistoric or historic cultural resources were located during the survey of the wetland mitigation area. The SCIC records search results indicate the previously recorded CA-SDI-10,811 as mapped within the project area. RECON visited this mapped location and did not observe any site material. This observation is
consistent with the recording of CA-SDI-10,811 as the site was surface-collected. The locational description provided with the recording of CA-SDI-10,811 is inconsistent with the physical setting of the current mapped boundary within
the wetland mitigation area. RECON believes the terrace upslope and adjacent to the east—outside of the current project boundary—better fits the physical setting provided within the recording of CA-SDI-10,811. The possibility of
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buried significant cultural resources being present within the wetland mitigation area is considered low due to the
naturally disturbed condition of the active drainage. Furthermore, CA-SDI-10,811 was determined not a significant
historical resource by WESTEC Services (Cheever 1986). Because of the lack of observed cultural material within the
survey area, as well as the naturally disturbed condition of the survey area, RECON recommends no additional
cultural resources work or monitoring for the wetland mitigation area. Impacts to cultural resources associated with
the implementation of restoration efforts within the survey area would be less than significant.
Report Clarifications
Some clarification to the terms used in the Dudek report are provided herein as the term “historical resources” and
“cultural resources” are not interchangeable terms. Cultural resources are generally categorized into two subtopics:
archaeological and historic. Archaeological resources (generally located below ground surface) are divided into two
categories: prehistoric and historic age. In our region, prehistoric archaeological resources date from before the onset
of the Spanish Colonial period (1769 to 1848) and historic archaeological resources date from and after the onset of
the Spanish Colonial period. An historic resource (generally located above ground) is any building, structure, or
object that is at least 50 years of age and that is, or may be, significant architecturally or culturally in local, state, or
national history.
As defined in CEQA Section 15064.5, historical resources, also called significant resources, are cultural resources,
prehistoric or historic, that have been evaluated for their significance and determined eligible for listing in the
California Register of Historical Resources (CRHR). According to CEQA Section 15064.5 (a), a historical resource includes the following:
1. A resource listed in, or determined to be eligible for listing on, the CRHR.
2. A resource included in the local register.
3. A resource which an agency determines to be historically significant. Generally, a resource shall be
considered to be “historically significant,” if the resource meets the criteria for listing on the California Register of Historical Places (Public Resources Code Section 5024.1 Title 14 California Code of Regulations,
Section 4852) including the following:
a. Is associated with events that have made a significant contribution to the broad patterns of California’s history or cultural heritage;
b. Is associated with the lives of persons important in our past;
c. Embodies the distinctive characteristics of a type, period, region or method of construction or represents
the work of an important creative individual, or possesses high artistic values; or
d. Has yielded, or maybe likely to yield, information important to prehistory or history.
4. The fact that a resource is not listed in or determined to be eligible for listing in the CRHR or a local register
does not preclude a lead agency from determining that the resource may be an historical resource as defined in Public Resources Code Sections 5020.1(j) or 5024.1.
Table 1 identifies instances in the 2022 Dudek report where the term “cultural resources” should be used in place of “historical resources”. While the Dudek report will not be updated, this memo is provided to clarify the use of terms.
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Table 1 2022 Dudek Report Instances of the term “Historical Resources” that should be replaced with “Cultural Resources”
Section Page Paragraph Sentence Revised Sentence
Management Summary vii 2 3 The records search identified 52 cultural resources within 1 mile of the APE,…
Management Summary vii 3 2 The NAHC responded on March 4, 2020,
indicating that the search was negative
for cultural resources within the project
APE.
Management Summary vii 5 3 Though recommended not eligible, the
presence of the four cultural resources
within the APE increases the probability
that ground disturbing activities may
encounter buried cultural resources.
2.3 SCIC Records Search 23 1 1 An examination of existing maps.
Records, and report was conducted by
Dudek to determine if the project could
potentially impact previously recorded
cultural resources.
2.3 SCIC Records Search 23 Header Cultural Resources
2.3 SCIC Records Search 23 2 1 The records search identified 52 cultural
resources within 1 mile of the APE,…
2.3 SCIC Records Search 23 2 4 Of the 52 cultural resources identified within 1 mile of the APE, two cultural
resources, P-37-007983 and P-37-026987,
intersect the APE.
2.3 SCIC Records Search/ Previous
Cultural Studies
25 1 2 Two of these reports describe cultural
resources identified within the current
project APE.
2.4 NAHC Sacred Lands File Search 26 1 1 The NAHC responded on March 4, 2020
via a letter indicating that the search was
negative for cultural resources within the
project APE.
2.4 NAHC Sacred Lands File Search 26 2 2 After explaining the project area and the
known cultural resources in the area,
Ms. Cumper asked to be on the
distribution list.
4.1 Survey 31 3 1 Documentation of cultural resources
complied with the Office of Historic
Preservation….
5.1 Survey Results 33 1 1 The pedestrian survey of the project APE
included the revisiting of two previously
identified resources and the identification
of two new cultural resources….
Ms. Janice Kluth, AICP
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Table 1 2022 Dudek Report Instances of the term “Historical Resources” that should be replaced with “Cultural Resources”
Section Page Paragraph Sentence Revised Sentence
5.1.1 Previously Identified Historical Resources 33 Header 5.1.1 Previously Identified Cultural Resources
5.1.2 Newly Identified Historical
Resources
34 Header 5.1.2 Previously Identified Cultural
Resources
5.2 Archaeological Testing Results 34 1 1 The current study identified four cultural
resources within the project APE.
6.1 Resource Evaluation 37 1 1 The current study identified four cultural
resources that are located within the
project APE that could have been
potentially impacted by project
activities:…
Table 4. Historical Resources
Management Recommendations
39 Table 4. Cultural Resources Management
Recommendations
6.2 Impacts Analysis and
Recommendations
39 1 2 Though recommended not eligible, the
presence of the four cultural resources
within the APE increases the probability
that ground disturbing activities may
encounter buried cultural resources.
6.3 Mitigation Measures 39 1 1 Although all currently known cultural
resources within the project APE are
recommended no significant under CEQA,
mitigation measures were developed to
reduce the impacts to previously
undiscovered potentially significant
cultural resources.
6.3 Mitigation Measures 39 1 4 Both project scenarios propose the same
development footprint and same impacts
to cultural resources.
This addendum letter with noted clarifications and updates completes the Dudek report. Please call me at (619) 308-
9333 ext. 133 if you have any questions.
Sincerely,
Carmen Zepeda-Herman, RPA Nathanial Yerka
Senior Archaeologist Archaeologist
CZH:NDY:sh
Confidential Figure
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References Cited
Cheever, Dayle
1986 Site Form for CA-SDI-10811 on file at the South Coastal Information Center located at San Diego State
University.
Converse Consultants 2022 Phase I Environmental Site Assessment Report Assessor’s Parcel Number (APN) 624 071 02 00, Chula Vista,
California. March 10.
Dudek
2022 Historical Resources Inventory and Evaluation Report for the Nakano Project, City of Chula Vista, San Diego County, California. February.
Nationwide Environmental Title Research LLC 2023 Environmental Records, Property Records, Public Records & Historic Aerial Images.
https://www.historicaerials.com/viewer. Accessed June 14, 2023.
RECON Environmental, Inc. 2023 Results of the Historical Resources Investigation of the Southwest Village Specific Plan, San Diego,
California. Project No. 614791. June 28.
FI GURE 1Project Impacts with Trail Improvem ents
G O LDEN S K Y W A Y
BLUE COR
AL C
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CE A N M I S T P L
D E N N E R Y R D
§¨¦805
G O LDEN S K Y W A Y
BLUE COR
AL C
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CE A N M I S T P L
D E N N E R Y R D
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Image Source: Ne arMap (flown January 2023)
0 300Feet [Parcel Boundar y
Impact L im its
Trail Im provement
M:\JOBS\3396-1\common_gis\Reports\Arc_Paleo\Fig1.mxd 06/02/2023 bma
FIGURE 2
Project Locations on Aerial Photograph
UV905§¨¦805
§¨¦5
UV905§¨¦805
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Image Source: NearMap (flown January 2023)
0 2,000Feet [Parcel Boundary
Impact Limits
Trail Improvement
Nakano Wetland Mitigation Area
M:\JOBS\3396-1\common_gis\Reports\Arc_Paleo\Fig2.mxd 07/19/2023 bma
P:\3396-1\Arc\Photos\photos1-2.docx 11/03/22
PHOTOGRAPH 1 Overview of Trail Improvement Alignment from Northwest Project Corner, Looking Northeast
PHOTOGRAPH 2 Overview of Eastern Portion of Trail Improvement Alignment, Looking West
CONFIDENTIAL FIGURE 1
Not for Public Review