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HomeMy WebLinkAboutCC AG PKT 2007-07-23 #R e AGENDA REPORT DATE: July 23,2007 TO: Honorable Mayor and City Council TIIRU: David Cannany, City Manager FROM: Lee Whittenberg, Director of Development Services SUBJECT: AUTHORIZIATION FOR CITY MANAGER TO EXECUTE PROGRAMMATIC AGREEMENT RE: CULTURAL RESOURCE ASSESSMENT FOR PUBLIC- PRIVATE VENTURE FOR FAMILY HOUSING ON THE SEAL BEACH NAVAL WEAPONS STATION SUMMARY OF REQUEST: e Waive further reading and adopt Resolution Number -' A Resolution of the City Council of the City of Seal Beach Authorizing the City Manager to execute on behalf of the City of Seal Beach, as a "Concurring Party" the Final "Programmatic Agreement Among the Commanding Officer, Naval Weapons Station Seal Beach, the California State Historic Preservation Officer, the Advisory Council on Historic Preservation, Regarding the Public-Private Venture for Family Housing, Naval Weapons Station Seal Beach." BACKGROUND: The City has received a request from the Seal Beach Naval Weapons Station to join as a "concurring party" in a "Programmatic Agreement Among the Commanding Officer, Naval Weapons Station Seal Beach, the California State Historic Preservation Officer, the Advisory Council on Historic Preservation, Regarding the Public-Private Venture for Family Housing, Naval Weapons Station Seal Beach." This proposed Programmatic AgreC!Dent ("Agreement'') is the outgrowth of a consultation process between the Navy and the California State Historic Preservation Officer and the Advisory Council on Historic Preservation, regarding a proposal to modify the current Navy program offamily housing management on the Weapons Station. Project Summary: e The .proposal is form a limited liability corporation (LLC) partnership to lease, demolish, construct, operate and maintain military family housing on the Station. The Navy would Agenda Item /? Z:\My OOaJmenlslNAVWPSTAlPublio-Prtvale Venture Housing Programmatic Agreement.CC Staff Report,docILW\07-13- 07 Authorizationfor City Manager to Execute Programmatic Agreement Re: Cultural Resource Assessment for Public-Private Venture for Family Housing on the Seal Beach Naval Weapons Station _ City Council Stqff Report _ July 23, 2007 lease the land for a 50-year time period. The new LLC would then demolish the existing l80-unit Sea Breeze Village, comprised of 160 2-bedroom units and 20 4-bedroom units and construct 180 new units of family housing with a mix of 3- and 4-bedrom units within the same area. Programmatic Agreement: The purpose of the Agreement is to obtain clearances from Federal and State agencies regarding the necessary level of historic resource investigations and determinations related to the proposed project. The primary signatories to the Agreement are the Naval Weapons Station Seal Beach, the California State Historic Preservation Officer, and the Advisory Council on Historic Preservation. All actions necessary to undertake the project in compliance with the Agreement will be the responsibility of those parties. Among the various Federal and State requirements are the: o Section 106 of the National Historic Preservation Act (NHPA); o National Environmental Policy Act (NEP A); o Archaeological Resources Protection Act (ARPA); o American Indian Religious Freedom Act (AIRFA); and o Native American Graves Protection and Repatriation Act (NAGPRA). The "Agreement" includes several "Concurring Parties" that are being requested to execute the document, including the City of Seal Beach. Other "Concurring Parties" identified are: e o Gabrielinoffongva Nation o Gabrielinoffongva Tribal Council o Seal Beach Historical and Cultural Society o Coalition of Gabrielinorrongva People o Juaneno Band of Mission Indians Staffhas reviewed the subject Agreement and accompanying documentation and is of the opinion that authorizing the City Manager to execute on behalf of the City of Seal Beach does not place any responsibilities or burdens upon the City in the undertaking proposed that is subject to the Agreement. The Agreement is provided as Attachment 2 for the information of the City Council. A "Final Cultural Resources Summary Report for Privatization of Family Housing at NAVWPNSTA Seal Beach", dated May 2007 is not provided due to the length of the document, 42 pages. It is available at the Department of Development Services for review by any interested party. The Agreement has not been executed by the responsible parties as of yet. The authorization of the City Council is to allow the City Manger to exe~ute the final document upon concurrence of the City Attomey. e 2 Public-Privale Venture Housing ProJll'llDllDlllic AsIoementCC StaffRcport e e e Authorizationfor City Manager to Execute Programmatic Agreement Re: Cultural Resource Assessment for Public-Private Venturefor Family Housing on the Seal Beach Naval Weapons Station City Council Staff Report July 23, 2007 The "Final Cultural Resources Summary Report for Privatization of Family Housing at NAVWPNSTA Seal Beach" document have not been reviewed by the Archaeological Advisory Committee, and they will scheduled for review and provide any comments directly to the Navy regarding the Cultural Resources Snmmllry Report at the August 13 meeting of the Committee. FISCAL IMPACT: None. RECOMMENDATION: Adopt Resolution Number --J A Resolution of the City Council of the City of Seal Beach Authorizing the City Manager to execute on behalf of the City of Seal Beach, as a "Concurring Party" the Final "Programmatic Agreement Among fhe Commanding Officer, Naval Weapons Station Seal Beach, the California State Historic Preservation Officer, the Advisory Council on Historic Preservation, Regarding the Public-Private Venture for Family Housing, Naval Weapons Station Seal Beach." NOTED AND APPROVED: cv', ~ David Carmany City Manager Attachments: (2) Attachment 1: Resolution Number ----> A Resolution of the City Council of the City of Seal Beach Authorizing the City Manager to execute on behalf of the City of Seal Beach, as a "Concurring Party", the Final "Programmatic Agreement Among the Commanding Officer, Naval Weapons Station Seal Beach, the California State Historic Preservation Officer, the Advisory Council on Historic Preservation, Regarding the Public-Private Venture for Family Housing, Naval Weapons Station Seal Beach" Attachment 2: Transmittal letter and "Programmatic Agreement Among the Commanding Officer, Naval Weapons Station Seal Beach, the California State Historic Preservation Officer, the Advisory Council on Historic Preservation, Regarding 3 Public-Private Ven_Housing ProJP'1llllllllllic Agrecmcnt,CC StalfReport Authorization for City Manager to Execute Programmatic Agreement Re: Cultural Resource Assessment for Public-Private Venturefor Family Housing on the Seal Beach Naval Weapons Station City Council Staff Report July 23, 2007 e the Public-Private Venture for Family Housing, Naval Weapons Station Seal Beach", dated June 27, 2007 e e 4 P~blic-Pnvale VOIllIml HousiDg Programmatic AgreementCC SIlIffRcport e e e AuJhorizationfOr City Manager to Execute Programmatic Agreement &: Cultural Resolll'CiJ Assessment for Public-Private Venturefor Family Housing on the Seal Beach Naval Weapons Station City Council Stqff Report July 23, 2007 ATTACHMENT 1 RESOL~ON ~ER . A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SEAL BEACH AUTHORIZING THE CITY MANAGER TO EXECUTE ON BEHALF OF THE CITY OF SEAL BEACH, AS A "CONCURRING PARTY", THE FINAL "PROGRAMMATIC AGREEMENT AMONG THE COMMANDING OFFICER, NAVAL WEAPONS STATION SEAL BEACH, THE CALIFORNIA STATE HISTORIC PRESERVATION OFFICER, THE ADVISORY COUNCIL ON HISTORIC PRESERVATION, REGARDING THE PUBUC-PRIVATE VENTURE FOR FAMILY HOUSING, NAVAL WEAPONS STATION SEAL BEACH" ,. 5 PubJio.Private v..._ Housing I'>............atic AgreemontCC Staff Report e e e Authorizationfor City Manager to &ecute Programmatic Agreement Re: Cultural ResoUl'ce ASsessment for Public-Private Venturefor Family Housing on the Seal Beach Naval Weapons Station City Council Stoff Report July 23, 2007 RESOLUTION NUMBER A RESOLUTION OF ,'!HE CITY COUNCIL OF '!HE CITY OF SEAL BEACH AUlHORIZING 1HE CITY MANAGER TO EXECUlE ON BEHALF OF THE CITY OF SEAL BEACH, AS A "CONCURRING PARTY", TIffi FINAL "PROGRAMMATIC AGREEMENT AMONG THE C,OMMANDING OFFICER, NAVAL WEAPONS STAT(ON SEAL BEACH, ,THE CAliFORNIA STATE HISTORIC PRESERVATION OFFICER, THE ADVISORY COUNCIL ON HISTORIC , - PRESERVATIOlf, : REGARDING THE PUBf.JC- PRIVATE VENTURE FOR, F~Y HOUSING, NA VAL WEAPONS STATION SEAL BEACH" WHEREAS, the City of Seal Beach has received a request from the Seal Beach Naval Weapons Station to jom: 'as a "concurring party" ,in a "Programmatic Agreement Among the Commanding Officer, Naval Weapons Station Seal Beach, the California' State Historic Preservation Officer, the Advisory Council on l1zstoric Preservation, Regarding the Public-Private Venture for Family Housing, Naval Weapons Station Seal Beacll'; and WHEREAS, the purpose of the "Programmatic Agreement" is to obtain clearances from Federal and State agencies regarding the necessary level of historic resource investigations and determinations related to the proposed project; and WHEREAS, The primary signatories to the Programmatic Agreement" are the Naval Weapons Station Seal Beac~ the California State Historic Preservation Officer, and the Advisory Council on Historic Preservation; and WHEREAS. All actions necessary to undertake t1ie project in compliance with the "Programmatic Agreemenf' will be the responsibility of those parties NOW, THEREFORE BE IT RESOLVED that the City Council of the City of Seal Beach does hereby authorize the City Manager to execute the Final "Programmatic ." Agreement Among the Commanding Officer, Naval Weapons Station Seal Beach, the California State IrtStoric Preservation Officer, the Advisory Council on Historic 6' PubIic-PrivIlo v_ Housing l'rognmmaIic AgtecmontCC StaffRt:port Authorizationfor City Manager to Execute Programmatic Agreement Re: Cultural Resource Assessment for Public-Private Venturefor Family Housing _ on the Seal Beach Naval WI!<gJOllS Statum . City Council StaffReporl July 23, 2007 Preservation, Regarding the Public-Private Venture for Family Housing, Naval Weapons Station Seal Beach", upon concurrence by the City Attorney PASSED, APPROVED AND ADOPlED by the City Council of the City of Seal Beach at a meeting thereof held ,on the day of .2007. AYES: Councilmembers NOES: Co~cilmembers ABSENT: Councilmembers ABSTAIN: Councilmembers e Mayor AlTEST: Linda Devine, City Clerk STAlE OF CALIFORNIA' ) COUNTY OF ORANGE ) SS CITY OF SEAL BEACH ) I, Linda Devine, City Clerk of the City of Seal Beach, California, do hereby certify that the foregoing resolution is an original copy of Resolution Number on file in the Office of the City Clerk, passed, approved and adopted by the City Council of the City of Seal Beach at a meeting thereof held on the day of ,2007. Linda Devine, City Clerk City of Seal Beach e .' 7 Publ.ic-hivalll VOIllUle Housm& ProgrammJIicAgrecmOlll.CC StaffRepart e e e Authorizati01lf01' City MlZNlger to &eCllte Programmatic Agreement Re: Cultural ResOll1'ce Assessment for Public-Private Venturefor Family Housing 011 the Seal Beach Naval Weapo1lS Stati01l City COlUlcil Staff Report July 23, 2007 ATTACHMENT 2 TRANSMITTAL LETTER AND "PROGRAMMATIC AGREEMENT AMONG THE COMMANDING OFFICER, NAVAL WEAPONS STATION SEAL BEACH, THE CALIFORNIA STATE HISTORIC PRESERVATION OFFICER, THE ADVISORY COUNCIL ON HISTORIC PRESERVATION, REGARDING THE PUBLIC-PRIVATE VENTURE FOR FAMILY HOUSING, NAVAL WEAPONS STATION SEAL BEACH", DATED JUNE 27, 2007 " .' 8 Public-Private Venture Housing Programmalic AgIoematt.CC Staff Report DEPARTMENT OF THE NAVY NAVAL WEAPONS STAnON SEAL BEACH .'0 SEAL BEACH BOULEVARD SEAL BEACH, CA. 10740-5000 Ctr or SslII BlllICb IN REPLY REFER ~O: 5758 Ser 045W/012l 27 June 2007 City of Seal Beach Attn: Lee Whittenberg 211 Eighth Street Seal Beach, CA 90740-6376 JIm 2 8 2001 Dear Mr. Whittenberg: The Naval Weapons Station Seal Beach (NWS Seal Beach) initiated consultation on February 26, 2007, for the Military Family Housing (MFH) Privatization (referred to as the "Undertaking") by defining the area of potential effects (APE) and our plan for consultation. The APE was concurred with by the California State Historic Preservation Officer (CASHPO) in a letter dated April 20, 2007, provided as Enclosure (1). Addressed below are the following: Department or IlewIopmem ServIces . A summary of the proposed Undertaking; . Cultural resources summary addressing the Navy's identification of historic properties within the APE; . A request for comment and concurrence on a draft Programmatic Agreement (PA), which proposes an alternative process for protection of historic ~roperties in the APE; . Application of the criteria of adverse effect, as defined in 36 CFR 800.5(b), with specific reference to 36 CFR 800.5(a) (2) (vii); and . A request for your comments on the Navy's finding of No Adverse Effect for the Undertaking. ~ Undertakinq Our previous correspondence described the subject Undertaking as a modification of the Navy's program of family housing management. The , Undertaking will form a limited liability corporation (LLC) partners~~to lease, demolish, construct, operate, and maintain military family housing at the NWS Seal Beach. The Navy will outlease underlying land and transfer ownership and management of the existing housing inventory and ancillary facilities located within privatization areas to the LLC for a period of fifty years. It is our intent for specific activities in conjunction with the Undertaking to be developed and reviewed in accordance with the procedures established in a Programmatic Agreement. Cultural Resources Summary A Cultural Resources SlUli.mary Report for Privatization of Family Housing at NAVWPNSTA Seal Beach (Summary) is provided as Enclosure (2) Attachment (1) which presents an overview of previous investigations and consultations to support our identification of historic propertie~ within the APE. Data gaps within existing inventories were supplemented with additional survey and archaeological testing. The methods and results are reported in the enclosed Summary. Historic Properties ~ Only one known historic property is subject to potential adverse affects by this privatization action: National Register-eligible archaeological site CA- ORA-322/lll8. Based on past evaluations and Section 106 consultations and on additional building evaluations attendant to the Undertaking and discussed in the Summary Report, no built historic properties are present within the APE. 5758 Ser 045W/0121 27 June 2007 Archaeoloqical Potential In conjunction with the current identification effort, the Navy conducted supplemental archaeological survey and shovel testing within the APE in areas outside the recorded boundaries of CA-ORA-322/1118. The archaeological testing identified evidence of culturally-derived marine shell in some of the shovel test pits in these areas. However, the level of disturbance in these deposits strongly suggests a general lack of integrity that would preclude their contributing to National Register eligibility. Despite their obvious past disturbance, the Navy is recommending that any of these areas that might harbor intact components within their generally-disturbed deposits will be subject to archaeological monitoring during any future ground disturbing activities. Assessment of Adverse Effect under a Programmatic Aqreement (PAl The Navy requests your comment and concurrence with the draft PA [enclosure (2)]. With this PA we propose to establish an alternative program for the management of historic properties affected by the proposed Undertaking. In accordance with 36 CFR 800.l4(b), this PA provides a strong basis for ensuring appropriate protection of historic properties is an integral part of the program of implementation for the proposed Undertaking, and demonstrates a program for ongoing management of these historic properties. This PA incorporates appropriate measures to govern individual activities in compliance with Section 106 of the NHPA. Absent execution of a PA, the subject Undertaking generally would meet the criteria for an adverse effect under 36 CFR 800.5(a) (2) (vii), being a "transfer, lease, or sale of property out of Federal ownership or control without adequate and legally enforceable restrictions or conditions to ensure long-term preservation of the property's historic significance." However, the alternative program to be established under the PA, and parallel stipulations to be included within the LLC lease language, both provide for the "adequate and legally enforceable restrictions or conditions" required to otherwise support a determination of no adverse effect. Consistent with this understanding, the Navy finds that a no adverse effect determination is appropriate for the proposed Undertaking Thank you for your support with this important initiative. The Navy respectfully requests your comments and/or concurrence by completing enclosure (3) Interested Party Response Form and mailing it back in the pre-addressed envelop provided by July 20, 2007. Please, contact Lisa Ellen Bosalet at (562)626-7637, or e-mail Lisa.Bosalet@navy.milif you have guestions. DA LLIE Environmental Director By direction of the Commanding Officer Enclosures: (1) CASHPO ltr of 20 Apr 07 (2) Draft Programmatic Agreement (3) Interested Party Response Form 2 e e e e e e STATE OF CALIFORNIA -lliE RESOURCES AGENcy OFACE OF HISTORIC PRESERVAnON DEPARTMENT OF PARKS AND RECREATION ..0,__ SACRAMENTO. CA 9"298 0001 (918)653-61124 Fax (916)853- coIshpaOol1p.parka.ca.gov www.ohp_parks.ca.gay ARIIIOLD SCHWARZENEGGER, _ @ April 20, 2007 In reply refer to: USNo70302A David Baillie Environmental Director U.S. Department of the Navy Naval Weapons Station Seal Beach 800 Seal Beach Boulevard Seal Beach, CA 9074O-S000 Ae: PubliclPrivate Venture Family Housing Program, Naval Weapons Station Seat Beach, Orange County, Califomia Dear Mr. Baillie: Thank you for your letter of 26 February requesting my review and comment with regard to the referenced undertaking. You are initiating consultation with me, in order to comply with Section 106 of the National Historic Preservation Act of 1966 (16 U.S.C. 470f), as amended, and its implementing regulation at 36 CFA Part 800. The Navy is proposing to implement !l PublicIPrivate Venture (PPV) family housing program at Naval Weapons Station (NWS) Seal Beach. Under this program, the Navy would enter into a long-term partnership with a private entity that would build/replace, maintain, and manage military family housing on the station. The length of the partnership is currently anticipatect to be 50 years. In accordance with 36 CFA ~ 800.4(a)(1), the Navy has established an Area of Potential Effects (APE) for the undertaking and has requested my comments. Based upon my review of the materials submitted along with your letter, I concur that the Navy has properly determined and documented the APE, as defined by 36 CFR ~ 8OO.16(d). Thank you for seeking my comments and considering historic properties as part of your project planning. 1 look forward to continuing this consultation with you. In the meantime, if you have any questions or concems, please contact David Byrd, Project Review Unit historian, at (916) 653-9019 or at dbvrd@Darks.ca.aov. Sincerely, J.-..) K ~rJIn. r Milford Wayne Donaldson, FAIA State Historic Preservation Officer MWD:db Draft PPV P A for NWS Seal Beach - 5 JUN 07 e PROGRAMMATIC AGREEMENT AMONG THE COMMANDING OffiCER, NAVAL WEAPONS STATION SEAL BEACH, THE CALIFORNIA STATE mSTORIC PRESERVATION OffiCER, THE ADVISORY COUNCIL ON mSTORIC PRESERVATION, REGARDING THE PUBUC-PRIV ATE VENTURE FOR FAMILY HOUSING NAVAL WEAPONS STATION SEAL BEACH WHEREAS, the Department of the Navy (Navy), acting pursuant to the Military Housing Privatization Initiative (10 USC 2871 et seq.), has determined to privatize family housing by entering into a Public Private Venture (pPV) in order to fu1fi11 family housing needs; and WHEREAS, the PPV is a partnering of the Navy and a private firm in the fonn of a Limited Liability CoIporation (LLC), which will operate, maintain, design, finance, demolish, construct, own, manage, acquire, lease, and rehabilitate family housing units and related improvements for a period of 50 years (Undertaking); and e WHEREAS, the Commantling Officer Naval Weapons Station Seal Beach (CONWSSB) will oversee implementation of the Undertaking at Naval Weapons Station Seal Beach (NWSSB), and has determined that the Undertaking includes a variety of future activities (undertakings; as defined under [36 CFR 800.16(y)] with the potential to affect NWSSB archaeological properties eligible for listing in the National Register of Historic Places; and WHEREAS, CONWSSB provides professional cultural resources oversight with the direct support of the Commander Navy Region Southwest (CNRSW) Cultural Resources Management Program (CRMP); and WHEREAS, the CONWSSB has consulted with the California State Historic Preservation Officer (CASHPO) and the Advisory Council on Historic Preservation (ACHP) pursuant to 36 CFR 800, regulations implementing Section 106 of the National Historic Preservation Act (NHPA) 16 U.S.C. 470(, and pursuantto such consultation, has developed this Programmatic Agreement (PA) in accordance with 36 CFR 800.14 in order to establish an efficient program altemative for taking into account the effects ofLLC activities on historic properties; and WHEREAS, CONWSSB will ensure coordination ofaII Section 106 compliance with other requirements ofNHP A and other statues, as applicable, including the National Environmental Policy Act (NEP A), the Archaeological Resources Protection Act (ARPA), the American Indian Religious Freedom Act (AIRF A), and the Native American Graves Protection and Repatriation Act (NAGPRA); and WHEREAS, CONWSSB has consulted with the City of Seal Beach, the Seal Beach Historical and Cultural Society, and other individuals and organizations with a demonstrated interest in . archaeological properties entrusted to CONWSSB, and has requested their concurrence in this PA; and e Page 1 oft8 Draft PEV P A for NWS Seal Beach - S JUN 07 WHEREAS, while understanding that there is no federally-recognized Indian tribe culturally affiliated with NWSSB, CONWSSB has identified and consulted with such non-federally- recognized Gabrielino and Juaneiio Indian claimant groups as may attach, or be assumed to attach, religious or cultural significance to historic properties within NWSSB, including the Gabrielinorrongva Nation, Gabrielinorrongva Tribal Council, Coalition of Gabrielino/Tongva People, and the Juaneno Band of Mission Indians, and has invited these parties to concur in this PA, in accordance with 36 CFR 800.6(c)(3); and e WHEREAS, the LLC will participate in this PA as an Invited Signatory, during or following execution of the PPV agreement, in accordance with 36 CFR 800.6(c)(2)(iii); and NOW, TIIEREFORE, CONWSSB, CASHPO, and ACHP, the Signatories to this PAin accordance with 36 CFR 800.6(c)(I), agree that CONWSSB will implement its housing privatization and related activities within the identified portions ofNWSSB in accordance with the following Stipulations in order to take into account the effects of these activities on historic properties, and that these stipulations will govern CONWSSB compliance with Section 106 of the NHP A for these activities until this P A expires or is tenninated. STIPULATIONS In cooperation with ACHP, CASHPO, the LLC, and other parties to this P A, CONWSSB will ensure that the following measures are carried out as indicated: e T. Antllicability This P A applies to all activities initiated within the area subject to the PPV within identified portions ofNWSSB, as shown in Attachment I. The P A sets forth'the process by which CONWSSB will meet its responsibilities under Section 106 of the NHP A with respect to the provision offamily housing and activities within the family housing area at NWSSB. II. General Provisions A. Roles and Responsibilities The terms of this P A are binding on all Signatories and the Invited Signatory, and their respective successors and assigns. 1. CONWSSB, as the agency official as defined under 36 CFR 800.2(a) for activities subject to Section 106, will ensure compliance with this P A; 2. The Navy Business Agreements Manager (BAM), acting as the PPV projects coordinator on behalf of the CONWSSB, will forward project proposals to the CONWSSB Public Works Officer (PWO), who coordinates the reviews by the CONWSSB Cultural Resoun:es Manager (CRM) and others, prior to approval; e Page 2 of18 Draft PPV P A for NWS Seal Beach - 5 JUN 07 e 3. The LLC will provide qualified professional cultural resources reviews, as defined in part B.1 of this Stipulation, to proposed actions with the potential to affect archaeological and other historic properties, and will ensure that all proposed projects are approved by the BAM prior to implementation; 4. The CONWSSB CRM will provide timely review of actions proposed by the LLC, and will coordinate with the PWO, BAM, and CNRSW CRMP to ensure that appropriate, qualified professional review, as defmed in part B,2 of this Stipulation, is conducted before proposed actions are approved. 5, CASHPO will provide timely reviews of projects submitted for formal consultation on adverse effects, and will participate in informal reviews when requested by the Navy. 6. ACHP will participate in dispute resolution consistent with Stipulation Vll.D of this P A, and will monitor the effectiveness of this P A consistent with Stipulation VIII.D.2 of this PA. B. Professional Qualifications 1. All work (activities) pursuant to this P A regarding historic properties will be carned out, reviewed by, or conducted under the supervision of' individuals meeting the appropriate professional qualifications standards identified in The Secretary a/the Interior's Standards and Guidelines/or Archeology and Historic Preservation, 36 CFR 61 (Federal Register Vol. 62, No. 119. 1997), or as amended in the future, Personnel meeting this standard are hereinafter referred to as qualified personnel. e 2. Confirmation of findings under Stipulation m.B. of this PA will be made by qualified personnel authorized by the CONWSSB or CNRSW to fulfill that function. Personnel meeting this standard (qualified Navy personnel) include the CRM. C. Standards of Review I. The Secretary of the Interior's Standards for the Treatment of Historic Properties (36 CFR 68), with emphasis on the standards and guidelines' for rehabilitation (Standards) will be followed for all reviews to evaluate the effect of proposed activities with the potential to affect historic properties. 2. When proposed activities have the potential to affect historic buildings and structures, emphasis will be given to the Standards for Rehabilitation (36 CFR 68.3(b). e Page 3 of18 Draft PPV P A for NWS Sea! Beach - S JUN 07 D. Notifications and Time Periods e 1. Notifications required pursuant to this P A will be in writing. 2, All notices, submissions, consents, demands, requests, or other communications which mayor are required pursuant to this P A to be given hereunder to the Signatories, the Invited Signatory and Concurring Signatories will be sent by (a) hand delivery (which will be deemed to have been received when the sender receives a signed receipt), (b) reputable overnight courier (which will be deemed to have been received one business day after the date sent), (c) United States mail (which will be deemed to have been received upon date stamp of the receiver), or (d) facsimile, with a copy sent by reputable overnight courier (which will be deemed to have been received when the sender receives a confirmation of successful transmission of the facsimile), or by other means available as technology changes that may be agreed to by the parties to this P A. All parties to this P A are responsible for updating the information below and providing current contact information to all Signatories, the Invited Signatory and the ConcUIIing Signatories. 3. All time periods will be counted in calendar days unless specifically stated otherwise. ill, Proiect Review Processes and Findinlls e This Stipulation applies to all future LLC projects and actions within NWSSB. The LLC will undertake no project or cause or permit actions to be undertaken that could affect historic properties at NWSSB without prior review and approval by the BAM. A. Project Review Processes 1. For each proposed project, the LLC will prepare project documentation for review to evaluate potential effects to historic properties prior to implementation. 2. The LLC's qualified personnel will prepare a written finding of effect on historic properties, either individually or as contributors to a historic district for review by the ~AM and CRM. 3. Documentation submitted to the BAM will at minimum include the following: a map showing the project location; a description of the proposed work; photographs of existing conditions; and, as appropriate, sketches/drawings illustrating the proposed work. 4. As part of its overall review and coordination responsibility on behalf of the CONWSSB, the BAM will forward documentation of proposed e Page 4 of1B e e B. Findings Draft PPV P A for NWS Seal Beach - 5 JUN 07 projects to the CONWSSB CRM, and will ensure that projects are not approved prior to concurrence from the CRM; 5. If the LLC's qualified personnel determine the project will have an adverse effect on historic properties, the LLC will notifY the BAM and CRM, and will study the feasibility of revising the project in a manner consistent with the Standards. If that study concludes that treating said historic resource in a manner consistent with the Standards is not feasible, the LLC will provide the BAM and CRM with documentation, and will afford the BAM 30 days to respond. If the BAM concurs in the necessity of the adverse effect, the BAM and CRM will consult with the CASHPO in accordance with 36 CFR 800.5 and 800.6. 6. If the CRM does not concur with the lLC's finding of effect, or requires additional information evaluate potential effects, the CRM will notifY the BAM and the LLC within fourteen (14) days. The lLC will consult with the BAM and CRM for an additional thirty (30) days. If after reasonable efforts the lLC and CRM do not agree, then either party may recommend that the CRM request informal consultation with the SHPO in accordance with Stipulation vm of this PA. To facilitate the planning offuture actions, Attachments 2 and 3 to this PA identifY routine actions in two categories: those requiring no review for cultural resources compliance (Attachment 2), and those requiring no formal consultation with CASHPO or local parties, provided they are approved by the BAM and CRM as consistent with relevant specifications (Attachment 3). In all cases, the lLC must consult the BAM to confinn applicability and to obtain approval prior to implementation. 7. 1. No Historic Properties Affected Findings: When qualified Navy personnel concur that an activity will not affect historic properties, in accordance with part A of this Stipulation and consistent with 36 CPR 800.4(d(1), no further review or consultation under this P A will be required, and the activity may proceed, absent post-review modifications. Documentation regarding fmdings made hereunder will be made available upon request to the ACHP and the CASHJ.>O in accordance with Stipulation IX. 2. No Adverse Effect Findings: When qualified Navy personnel concur that an activity will have no adverse effect no further review or consultation under this P A will be required, in accordance with part A of this Stipulation and consistent with 36 CFR 800.5(b), and the activity may proceed, absent post-review modifications, Qualified personnel will monitor the activity and document the fmdings made hereunder in accordance with Stipulation IX. e Page 5 of18 DIaft PPV P A for NWS Seal Beach - 5 JUN 07 3. Adverse Effect Findings: When qualified Navy personnel concur that an activity may adversely affect a historic property, in accordance with part A of this Stipulation and consistent with 36 CFR 800.S(d)(2), CONWSSB and the LLC will attempt to redesign the activity or take such other measures as may be necessary to avoid the potential adverse effect. If as a result of such efforts, the potential adverse effect can be avoided, either a "no historic properties affected" or "no adverse effect" finding will be made, no further review or consultation under this P A will be required, and the activity may proceed, absent post-review modifications. When a finding of "no adverse effect" is made hereunder, qualified personnel will monitor the activity to ensure conformance with the measures prescribed to avoid adverse effects. CONWSSB will document the findings made hereunder in accordance with Stipulation IX. e If the potential adverse effect of the activity cannot be avoided, qualified Navy personnel shall make a fmding of adverse effect, consistent with 36 CFR 800.S( d)(2), and CONWSSB will initiate consultation pursuant to 36 CFR 800.6. Findings made hereunder will be documented in accordance with Stipulation IX. IV. Detezmininl!" and Documentinl!" APEs Qualified Navy personnel will confum and document the area of potential effects (APE) for the following classes of activities in accordance with 36 CFR 800.l6(d). e A. Activities involving ground disturbing activities: For these activities, APEs will include the planned area of surface and subsurface disturbance, including any associated lay down or staging areas and a 30-meter buffer around each area of ground disturbance. If any part of a known archaeological site falls within an APE, the entire documented site will be included in the APE. B. Activities limited to the construction, maintenance, repair or renovation of buildings or structures: When this activity is located 100 meters or more from the edge of a NRHP listed or eligible historic district or from an individual NRHP- listed or eligible building or structure, APEs will be defined as the discrete site of the activity and any associated lay down or staging areas, C. Activities where the construction, maintenance, repair or renovation of buildings or structures will occur within a NRHP listed or eligible historic district, or within 100 meters of a NRHP listed or eligible historic district or individually NRHP listed or eligible building or structure: For these activities, APEs will be defined to include the historic district or individual historic property along with the discrete construction site for the individual building or structure and any associated lay down or staging areas. e Page 6 of 18 Dmft PPV PA for NWS Seal Beach - 5 JUN 07 e D, Detenninations of APEs will not consider potential visual or acoustic effects on NRHP listed or eligible archaeological properties unless such properties are of religious or cultural significance to Native Americans and fonnally established as traditional cultural properties (rCPs) in recuning ceremonial or other religious use by Native Americans. V, Archaeolol!ical Monitorine: and Other Aoolied Historic Preservation Measures CONWSSB will ensure that ground-disturbing activities include appropriate measures to protect archaeological resources. A. As appropriate, and with the approval of CONWSSB, the LLC will provide for qualified archaeological monitoring of ground disturbing activities within areas of a known archaeological site or of known archaeological sensitivity, as determined by CONWSSB. B. In further consultation with pertinent parties to this P A and with the assistance of the CNRSW CRMP, CONWSSB, the BAM and the LLC will develop maps for identifying areas within NWSSB which will require monitoring by a qualified archaeologist and, where appropriate, a Native American monitor, Conversely, this process will also explicitly map areas where existing conditions, including previous disturbance and land areas created by cutting and filling, gencra1ly preclude the potential for archaeological deposits, and where, at the discretion of qualified personnel, archaeological monitoring will not be required. e C. Any required archaeological testing or monitoring shall be implemented in accordance with a developed archaeological research framework for NWSSB and environs, and in compliance with other standards and requirements ofNHP A, ARPA, NAGPRA and their implementing regulations, including 36 CFR 79, Such archaeological testing or monitoring shall also be implemented under appropriate consultation with SHPO and other required consulting parties. The LLC will provide records, reports and other documentation on the findings of these testing and monitoring activities to CONWSSB through the BAM, and provide notice of the resulting reports in accordance with Stipulation IX. VI. Addressinl!: Discoveries and Unanticipated Effects In ord,er to avoid or m;n;m;7.e harm to hi$>ric properties, CONWSSB and the LLC will address discoveries and unanticipated effects as follows: A. The LLC will establish and enforce working procedures and contracting stipulations to ensure that: 1. Contractors and other authorized agents engaged in ground-disturbing activities will be required to stop work in the vicinity of any discovered potential archaeological deposit until further direction is provided the BAM; e Page 7 of 18 Draft PPV P A for NWS Seal Beach - 5 JUN 07 2. The LLC will immediately notify the BAM of the discoveIy, who will notify CONWSSB; and e 3, Construction in the vicinity of the discoveIy will not be resumed until the BAM and CONWSSB have completed the review prescribed in paragraph C., below, of this Stipulation. B. CONWSSB will notify the CASHPO and other parties to this P A, as appropriate, at the earliest possible time, if it appears that an activity covered by this P A will affect a previously unidentified property that may be eligible for the NRHP, or affect a known historic property in an unanticipated manner. CONWSSB may assume for purposes of this P A that the affected property is eligible for inclusion in the NRHP. CONWSSB will consult with the CASHPO and other appropriate parties to this P A to develop actions that take into account the effects of the activity. C. CONWSSB will provide ACHP, SHPO, liC, and other parties as appropriate with written recommendations reflecting the consultation. D, The LLC will modify the scope of work as necessary to implement these recommendations. E. Any consultation carried out hereunder shall not exceed thirty (30) days. CONWSSB will provide parties to this P A with written recommendations reflecting the consultation and will modify the scope of work as necessary to implement these recommendations. e VIT. Emem:encies A. In the event that natural disasters, fires, spill events or other emergencies occur, the LLC may take actions that may affect historic properties without consultation to protect life and safety, to stabilize historic properties, and to prevent further property damage. Emergency response work will be undertaken in a manner that seeks to avoid or minimi '''l effects on historic properties to the extent possible. The liC will notify the BAM of the emergency as soon as practicable. The BAM will notify CONWSSB as soon as practicable, B. Should historic properties be discovered during emergency repair or response activity, work in the immediate area of the discoveIy will cease ifCONWSSB has determined that a work stoppage at the site will not impede emergency response activities. C. Ai> early as possible given the nature of the emergency, CONWSSB will provide telephonic or email notification of the discoveIy to the CASHPO and other appropriate parties to this P A. Notification will include the steps being taken to . address the emergency, the discovered property and its apparent significance, and e Page 8 ofl8 Draft PPV P A for NWS Seal Beach - 5 JUN 07 e a description of the emergency work and potential effects on the discovered property. Within thirty (30) calendar days following this notification, CONWSSB will provide CASHPO and other appropriate parties to this P A with a written report documenting the actions taken to avoid or minim;7.. effects, present status and planned treatment of the property. This action will be included in the report developed in accordance with Stipulation IX. VIll. Resolvin2 Obiections A. Should the LLC or CONWSSB disagree about findings of effect, the LLC and CONWSSB will consult for an additional thirty (30) days to resolve the disagreement. If the disagreement remains unresolved, the LLC will have the option of requesting that CONWSSB contact CASHPO for infonna1 consultation. Within fifteen (IS) days of receiving a written request from the LLC, CONWSSB will contact CASHPO to initiate consultation consistent with 36 CFR 800.5. B. Should any Signatory or the Invited Signatory object in writing to CONWSSB regarding the manner in which the terms of this P A are carried out, CONWSSB will immediately notifY the other parties to this P A of the objection and proceed to consult with the objecting signatory to resolve the objection. CONWSSB will honor the request of any other parties to this P A to participate in the consultation and will take any comments provided by such parties into account. CONWSSB will establish a reasonable time frame for such consultation. e C, If the objection is resolved through consultation, CONWSSB may proceed with the action subject to objection in accordance with the terms of such resolution. D. If after initiating such consultation CONWSSB detennines that the objection cannot be resolved through consuJtation, it will forWard all documentation relevant to the objection to the ACHP, including CONWSSB's proposed response to the objection. Within thirty (30) days after receipt of all pertinent documentation, the ACHP will exercise one of the, following options: 1. Advise CONWSSB that the ACHP concurs in CONWSSB's proposed response to the objection, whereupon CONWSSB will respond to the objection accordingly; or 2. Provide CONWSSB with recommendations, which CONWSSB will take into account in reaching a' final decision regarding its response to the objection; or 3. Notify CONWSSB that the objection will be referred for comment pursuant to 36 CFR 800.7(a)(4) and proceed to refer the objection and comment. In this event, CONWSSB will ensure that the agency official is prepared to take the resulting comment into account in accordance with 36 CFR 800.7(c)(4). e Page 9 oil 8 Dndl: PPV P A for NWS Seal Beach - 5 JUN 07 4. Should the ACHP not exercise one of the above options within 30 days after receipt of the pertinent documentation, CONWSSB may assume the ACHP's concurrence in its proposed response to the objection. e 5. CONWSSB will take into account any ACHP recommendation or comment and any comment from the other parties to this PAin reaching a final decision regarding the objection. CONWSSB' s responsibility to carry out all actions under this PA that are not the subjects of the objection will remain unchanged. . CONWSSB will provide all other parties to this P A with a written copy of its final decision regarding any objection addressed pursuant to this Stipulation. 6. CONWSSB may authorize any action subject to objection under items 1-5 of this Stipulation to proceed, provided the objection has been resolved in accordance with the terms of items 1-5 of this Stipulation. 7. Should an objection be raised by a Concurring Party or a member of the public to the manner in which the terms of this P A are implemented, CONWSSB will notify the other Signatory Parties, the Invited Signatory, and the Concurring Parties. CONWSSB will consult with the objecting party to consider the objection. CONWSSB will establish a reasonable time frame for this consultation. Within fifteen (15) days after the consultation period reasonably established by CONWSSB expires, CONWSSB will render a decision regarding the objection and respond in writing to the objecting party. CONWSSB's decision regarding the objection will be final. Following issuance of its final decision, CONWSSB may authorize the action subject to objection hereunder to proceed in accordance with the terms of that decision. CONWSSB will notify the other Signatory Parties, the Invited Signatory, and the Concurring Parties of the resolution under this Stipulation. e IX. Rqlortinl!: Requirements and Prol!l'l1Ill Monitorin~ A. Documentation 1. Project documentation will conform to documentation standards in 36 CPR 800.11. 2. The LLC will maintain a file on all work accomplished pursuant to Stipulation ill.A.7., including information on what work was undertaken on the historic property, on what date, and pursuant to whose review and approval. e Page 10 of18 Draft PPV P A for NWS Seal Beach - 5 JUN 07 e 3. The LLC will maintain a case file on any archaeological work undertaken pursuant to this P A. A1i completed, a duplicate copy of each case file shall be provided to CONwSSB and the CNRSW CRMP for inclusion in their program files. The information from these case studies will be provided by the BAM or the LLC as appropriate. Any such case file will include documentation related to: archaeological issues; correspondence related to consultation with the CASHPO; determinations of eligibility; and reports on any surveys conducted or excavations undertaken. The case files will be provided to the Navy and CASHPO upon request. The case files will be transferred to the BAM, CONWSSB and the CNRSW CRMP upon expiration or termination of the Ground Lease. Archaeological site information will be kept confidential consistent with the provisions of ARPA. B, Annual Reports e Beginning twelve (12) months aflerthe date of execution of this PA, the LLC will prepare and provide to the BAM and CONWSSB annual reports summarizing the activities undertaken toward the implementation of this P A. The BAM and CONWSSB will review and comment on the reports. The reports will include, but not be limited to, a report on: the status and condition of historic housing; actions taken by the LLC. Exempt Activities and the Standards where CASHPO notification was not required; information on consultation conducted pursuant to this PA; a s1lIIlIlll1l'Y of meetings with the CRM; descriptions of unanticipated problems that have arisen or that could affect the integrity of upkeep of the historic housing; information regarding any unanticipated subsurface discoveries and archaeological work related thereto, and any other activity or policy that may affect the historic resources. C. Public InspeCtion and Comment The LLC, BAM and CONWSSB will ensure that annual reports are available for public inspection and comment upon written request. If comments are received, the party receiving the LLC will provide these comments will provide them to the Signatories and Invited Signatory, as appropriate, other Signatory parties for their review before CONWSSB responds responding to the comments. D. Program Monitoring 1. Within the first year of this P A, the LLC will initiate a cycle of annual reporting to the BAM and CONWSSB to support a review of work undertaken pursuant to this P A. 2. Upon written request, the ACHP and the CASHPO may monitor and review the activities caIried out pursuant to this P A. The CONWSSB and e Page 11 of 18 Draft PPV P A for NWS Seal Beach - 5 JUN 07 LLC will cooperate with the CASHPO and ACHP in their monitoring and review responsibilities. e X, Anti-Deficiencv Act A. The Anti-Deficiency Act, 31 USC 1341, prohibits federal agencies from incurring an obligation of funds in advance of or in excess of available appropriations. Accordingly, the parties to this P A agree that any requirement for the obligation of funds arising from the terms of this PA shall be subject to the availability of appropriated funds for that pUIpose, and that this P A shall not be interpreted to require the obligation or expenditure of funds in violation of the Anti-Deficiency Act. B. The obligations of this PA as to the Navy are severable. If the Navy cannot perform aiJ.y obligation set forth in this P A because of the unavailability of funds, the Signatory Parties and the Invited Signatory intend that the remainder of the P A be executed to the greatest extent practicable. The Signatory Parties and the Invited Signatory agree to consult on any obligation of the P A that cannot be performed because of the unavailability of funds. XI, Amendments Any Signatory party and the Invited Signatory may at any time propose amendment of this P A whereupon all parties to this P A shall consult to consider such amendment pursuant to 36 e CPR 800.6(c)(7) and 800.6( c)(8). This P A may be amended only upon written concurrence of the Signatories. Attachments to this PA may be individually amended through consultation of the Signatories and the-Invited Signatory without requiring amendment of the P A, unless the Signatories and the Invited Signatory through such consultation decide otherwise. XII. Confidentiality All Signatories and the Invited Signatory acknowledge that information about historic properties, prospective historic properties, or properties considered historic for pUIposes of this PA are or may be subject to the provisions of Section 304 of the NHPA relating to the disclosure of sensitive information, and having so acknowledged, will ensure that all actions and documentation prescribed by this P A are, where necessary, consistent with the requirements of Section 304 of the NHP A. xm. Termination A. Only the Signatories and the Invited Signatory may terminate this P A. If this P A is not amended as provided for in Stipulation X., above, or if any Signatories and the Invited Signatory proposes termination of this P A for other reasons, the party proposing termination shall notify all parties to this P A, in writing, explain the reasons for proposing termination, and consult with the Signatories and the Invited Signatory for no more than 30 days to seek alternatives to termination. e Page 12 of18 e Draft PPV P A for NWS Seal Beach - 5 JUN 07 B. Should such consultation fail, the party proposing termination may tenninate this P A by promptly notifying the Signatories and the Invited Signatory in writing. C, Should this P A be terminated, then CONWSSB shall either consult in accordance with 36 CFR 800.l4(b) to develop a new PA or request the comments of the ACHP pursuant to 36 CFR Part 800. D. Beginning with the date of termination, CONWSSB shall ensure that until and unless a new PAis executed for the activities covered by this P A, such activities shall be reviewed individually in accordance with 36 CFR 800,4-800.6. XIV. Term of this PA This PA shall remain in effect for a period often (10) years, unless it is tenninated prior to that time, following execution by the CONWSSB, CASHPO, and ACHP, and shall automatically terminate and have no further force or effect at the end of this ten year period unless it is terminated prior to that time. Not later than six months prior to the tennination date of this P A, the CONWSSB shall initiate consultation with the other Signatories and the Invited Signatory to determine if this P A should be allowed to terminate automatically or whether it should be extended for an additional term, with or without amendments, as the Signatories and the :rnvited Signatory may determine. Unless the Signatories llnHniml)llsly agree through such consultation on an alternative to automatic tennination of this P A, this P A shall automatically terminate and have no further force or effect in accordance with the timetable stipulated herein. e xv. Execution and Effect of the PA B. C. e A, This P A shall take effect on the date that it has been executed by the Signatory Parties. Additional attachments or amendments to this P A shall take effect on the dates they are executed by the Signatory Parties. This P A may be executed in multiple original counterparts, each of which will be deemed an original, and which together will constitute one and the same P A. Execution and implementation of this PA evidences that CONWSSB has afforded the ACHP a reasonable opportunity to comment on the Undertaking, that CONWSSB has established an efficient program alternative to take into account the effects of future activities on historic properties within the APE to comply with Section 106 of the NHPA and 36 CFR 800 for all individual activities subject to this P A. Page 13 of18 Draft PPV P A for NWS Seal Beach - 5 JUN 07 Sil!Ilatories e Commanding Officer, Naval Weapons Station Seal Beach By: Date: J. D. Kurtz, Captain, U.S. Navy Commanding Officer, Naval Weapons Station Seal Beach California State Historic Preservation Officer By: Date: Milford Wayne Donaldson, California State Historic Preservation Officer Advisory Council on Historic Preservation e By: Date: John M. Fowler, Executive Director Invited Sil!Ilatories LLC By: Date: Title Concurrinl!: Parties City of Seal Beach e Page 14 of18 . By: Title Seal Beach Historical and Cultural Society By: Title Gabrielino/Tongva Nation By: . Gabrielino/Tongva Tribal Council By: Title Coalition of Gabrielino/Tongva People By: Juaneiio Band of Mission Indians By: , Title . Draft PPV P A for NWS Seal Beach - 5 JUN 07 Date: Date: Date: Date: Date: Date: Page 15 of IS DIlIft PPV PA for NWS Seal Beach - 5 JUN 07 Attachment 1 e Final Cultural Resources Summary Report for Privatization of Family Housing at N aval Weapons Station Seal Beach (without Appendices) (May 2007) e ~ e Page 16 of18 DIlIft PPV P A for NWS Seal Beach - 5 JUN 07 e Attachment 2 Routine Activities Not Reauirlnl! Cultural Resource Review As defined below, the following routine activities have no potential to adversely affect historic properties. They are exempt from review for cultural resources compliance, provided they are confirmed by the Business Agreements Manager (BAM) as conforming to the definitions in this attachment. Other non-historic preservation reviews may be required by the BAM under provisions of the Ground Lease and Management Plan. A. General 1. Activities involving ground-disturbing activities beyond 30 meters outside areas of known archaeological sites or known archaeological sensitivity, as determined by CONWSSB. 2. Activities involving buildings not listed or eligible for listing on the National Register of Historic Places, unless within 100 meters of an eligible building or historic district. " B. Interior and Exterior Work on Non-Elil!ible Built ProDerties 1. All interior or exterior work on non-eligible buildings beyond 30 meters_outside areas of known archaeological sites or archaeological sensitivity, as determined by CONWSSB. e 2. All interior work on non-eligible buildings with a ground-disturbing component on or within 30 meters_outside areas of known archaeological sites or areas of archaeological sensitivity, as determined by CONWSSB. e Page 17 of18 DIlIft PPV P A for NWS Seal Beach - 5 JUN 07 Attachment 3 e Activities Reauirinl! Navv Review without Further smo Consultation Provided they are reviewed and approved consistent with Stipulation ill of the P A, and are determined by qualified Navy personnel as either "no historic properties affected" or ''no adverse effect" the following routine activities are consistent with applicable standards and require no consultation with CASHPO. The LLC's qualified cultural resources professional will prepare written confirmation that planned activities confonn to the requirements. Final approval and other possible reviews will be provided by the Business Agreements Manager (BAM) acting on behalf of the CONWSSB. A. General 1. Undertakings involving ground,-disturbing activities on, or within 30 meters of, known archaeological sites and areas of known archaeological sensitivity, as determined by CONWSSB. This includes ground-disturbing activities with a maximum depth of twelve (12) inches or less. 2. Undertakings involving aspects of the built enviromnent that are within 100 meters of listed or eligible for listing on the National Register of Historic Places. B. Interior and Exterior Work on Non-Elil!ible Built Pro.perties e 1. All exterior work on non-eligible buildings with a ground-disturbing component on or within 30 meters_outside areas of known archaeological sites or areas of archaeological sensitivity, as determined by CONWSSB. e Page 18 orI8