HomeMy WebLinkAboutAAC Min 1997-08-27
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NOTICE OF ADJOURNED MEETING
ARCHAEOLOGICAL ADVISORY COMMITTEE
NOTICE IS HEREBY GIVEN THAT
THE ARCHAEOLOGICAL ADVISORY
COMMITTEE ADJOURNED MEETING
OF AUGUST 27, 1997 HAS BEEN
ADJOURNED TO WEDNESDAY,
SEPTEMBER 17, 1997, AT 5:30 P.M. AT
THE CITY HALL COUNCIL
CHAMBERS, 211 EIGHTH STREET,
SEAL BEACH
bt'
'r
August 29. 1997
Date
~ Whittenberg, Secretary
~~li'aeological Advisory Committee
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CITY OF SEAL BEACH
ARCHAEOLOGICAL ADVISORY COMMITTEE
ADJOURNED MEETING MINUTES
AUGUST 27, 1997
CALL TO ORDER
ChaiIperson Johnston called the meeting to order at 5:35 P.M. in the City Council
Chambers
ROLL CALL
Present:
Goldberg, Fitzpatrick, Willey, Young, and Chairperson Johnston
Also
Present:
Lee Whittenberg, Director of Development Services
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APPROVAL OF AGENDA
MOTION by Goldberg, SECOND by Willey to approve the agenda as presented.
MOTION CARRIED:
5-0
AYES:
NOES:
Fitzpatrick, Goldberg, Willey, Young, and Chairperson Johnston
None
ORAL COMMUNICATIONS
Adrea Stoker * Long Beach
Ms. Stoker asked, "Have the Native Americans been consulted about the Hellman
project? Where do I get my answer? Chairperson Johnston stated, "I don't know. I
can't talk for other Native Americans. I think you need to talk to Mr. Cleland or Mr.
Baksh .... I know that I have been sent a letter and received a voice mail. But I have
not been called a second time. Nor have I called them."
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Ms. Stoker stated, "It says that they are to be consulted before this gets started. Who
do I talk to? Anybody here? Mr. Whittenberg stated, "I'm not understanding what the
comment is. Is the question .." Ms. Stoker interrupted, "The question is ..." Mr.
Whittenberg asked to complete his question, "Is the question regarding have Native
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Americans been contacted about the Environmental Impact Report (EIR) or about the
Research Design document. Which are we talking about? Ms. Stoker said, "The
Native Americans were to be contacted before this got off the ground." Mr.
Whittenberg asked, "Before what got off the ground? Ms. Stoker said, "The EIR.
Before the Research Design." Mr. Whittenberg stated, "No. They were to be
contacted as part of the Research Design. We are not talking about the Research
Design this evening madam. We're talking about the EIR. I'd like to make sure we're
talking about the information that's before the Board." Ms. Stoker said, "Well, I
misread this. I understood that the Native Americans were to be contacted as a process
of putting this EIR together." Mr. Whittenberg stated, "They have been. They have
been made aware of the Public Hearings. There have been people in attendance at the
meetings before this Committee in the past on the Draft Environmental Impact Report.
Ms. Stoker said, "I don't mean that kind of contact. I mean to sit down --- the Mayor,
Mayor Forsythe said months ago, to Lillian Robles that she would be in contact with
Lillian. And that they would work with the Native Americans." Mr. Whittenberg
stated, "That's the Mayor's comment. I can't comment on whether or not the Mayor
has been in contact with Lillian Robles or not. She indicated she would do that as an
individual. The Public Hearing process on the EIR has been a public process from the
very beginning. Native Americans have been informed of that process. They've had
an opportunity to provide comments. Comments are provided in the EIR. They have
been responded to. So, I'm not sure what it is ---." Ms. Stoker stated, "My question
is, they're not a part of this process." Mr. Whittenberg said, "They're here in the
audience this evening to participate in the process madam." Ms. Stoker said', "I
thought they were to be closely --- working closely --- with the archaeologists from
moment ...." Mr. Whittenberg said, "There's two different processes going on and I
want to make sure you're understanding the processes. An EIR is a document that is
prepared by a City. The City puts that document out for public review and comment.
That has been done by the City. The City does not bring in private individuals to help
write the EIR. The City hires a consultant to do that work. That has been done. The
document went out for public review and comments. Comments have been received.
A Final EIR is now before this Board and eventually it will before the Planning
Commission for comment. The other process which is going on at this point in time is
the initial phases of, hopefully, a future archaeological investigation on the Hellman
Ranch property. The fIrst step of that process is the preparation of a Research Design
document. That process is being undertaken separate from this EIR process. In a
parallel time period but it's a separate process all together. As part of that process,
there has been --- and it's indicated in the Research Design document --- there are a
number of Native Americans that have been contacted by the frrm that the City has
hired to do that Research Design. To seek clear input into the Research Design
process." Ms. Stoker said, "Well that was my question --- who are they?" Mr.
Whittenberg said, "It's in the Research Design document. I don't have it in front of
me." Ms. Stoker stated, "Names?" Mr. Whittenberg said, "We're not talking about
that document tonight." Ms. Stoker: asked, "Do you know who they are?" Mr.
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Whittenberg stated, "I just answered the question. I don't have it in front of me." Ms.
Stoker said, "Well, it just seems to me ---. Mr. Whittenberg said, "It's about fIfteen
individual Native Americans that have been provided a copy of the Research Design.
They were sent that document by the City. They were sent agendas of the meetings
when the Research Design was considered by this Board on August the 6th and August
the 13th. They were invited to come, to make comments at those meetings. They were
also made aware that the comment period for the Research Design is open until
September 1st. If they could not be at a meeting, they could provide comments to my
offIce by September 1"t. They have been given every opportunity to come and sit in
meetings, provide comments to the City on the process. Ms. Stoker said, "I
understand that thoroughly. My question is, is anyone from KEA sitting with Native
Americans, consulting with them now? Before this process starts? Before the fIrst
shovel is put in the ground?" Mr. Whittenberg said, "No shovels are going to be put
into the ground for quite some period of time. I don't know if KEA has actually
started meeting with individuals. I know they sent letters out informing Native
Americans of the process. And that they will be contacting them for follow-up
interviews and so on. Whether or not they have actually started that process at this
point I don't know. And that's not a process that is part of the EIR. I want to make
that very clear. That's not the process that we're here to talk about this evening." Ms.
Stoker stated, "All right. When the monitor is chosen, my big concern is --- and I
know --- I understand that that will not be done now --- but when the monitor is
chosen, time after time after time, if it's in --- many people that have worked for SRS
are involved in it --- things disappear, like 700 sacks, bags of artifacts from Hellman
Ranch already. I don't want that to happen again. So, I'm still concerned as to who
the monitor will be. And if someone will be able to monitor the monitor from the
Native American people. Mr. Whittenberg stated, "The monitor will be selected by
the Most Likely Descent for the project that has been identifIed by the Native American
Heritage Commission. The Most Likely Descent is Vera Rocha. She will select the
Native American monitor." Ms. Stoker asked, " So is there any other committee of
Native Americans, of her choice, that will be able to ---." Mr. Whittenberg stated,
"You would have to discuss that issue with Ms. Rocha." Ms. Stoker said, "Okay. All
right. Thank you. "
Chairperson Johnston thanked Ms. Stoker for her comments and asked if there was
anyone else wishing to address the Committee. Mr. Whittenberg responded to a
question from the audience that could not be heard, stating, "I think what the question
is, will you allow people to comment on the Final Environmental Impact Report
(FEIR) when you get to that item on the Agenda? And I would suggest that you allow
people to provide any comments to you when you get to that item.
Chairperson Johnston indicated the Committee will go on to Scheduled Matters.
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CONSENT CALENDAR - No Items
SCHEDULED MATTERS
1. RECEIPT OF PUBliC COMMENTS AND COMMITTEE REVIEW -
Cultural Resources Section of Hellman Ranch SpecifIc Plan Final EIR
Recommendation:
Upon conclusion of recelvmg all appropriate public comments, staff
recommends the Committee review the discussion and the proposed mitigation
monitoring measures for the Hellman Ranch SpecifIc Plan Final EIR. The
Committee should forward a recommendation to the Environmental Quality
Board as to the adequacy of the information provided, and forward a
recommendation to the Planning Commission as to the adequacy of the proposed
"Mitigation Measures". Approval should be through the adoption of Resolution
No. 97-1 or 97-1A and Resolution 97-2 or 97-2A (Attachments 1 and lA, and 2
and 2A, respectively).
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Chairperson Johnston asked if the Committee wanted to go right on to public comments
before Committee discussion?
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Mr. Whittenberg
Mr. Whittenberg stated, "I think it might be helpful just for the audience and for the
members of the Committee both for me to make a couple of introductory comments.
Kind of what the purpose of your session is this evening and a brief review of the
FEIR. And then at that point, if you wish to receive comments from the public, you
may do that. We also have representatives from P&D here this evening-- Bob Rusby
and Sylvia Salenius, who were responsible for the preparation of the EIR itself. And
they can respond to questions you may have of them. And also, I am available to try
and respond to any questions or comments you may have. You are here this evening
for basically two purposes. As the Archaeological Advisory Committee (AAC) to the
City you have two separate charges before you. The fIrst is to make a recommendation
to the Environmental Quality Control Board (EQCB) as to adequacy of the information
that's provided in the Cultural Resources section of the FEIR. In that FEIR there's
been a complete re-write of the Cultural Resources section and you have that in your
information packet as part of the FEIR. We've prepared draft resolutions for your
consideration this evening. They give you two options. One is to say that the FEIR, in
the form as it exists at this point in time, is adequate under CEQA. The second
alternative is to say that you feel there are defIciencies in the document as it exists at
this point in time. And the alternate resolution allows you then, as members of the
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Committee, to specify to the EQCB what you feel those inadequacies are. So that's
one action you're going to be asked to consider taking this evening.
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The second action is to make a recommendation to the Planning Commission regarding
the adequacy of the mitigation measures that are included in the FEIR in relation to
Cultural Resource protection measures. And again, we have two resolutions for you.
One which says the measures, as they are presented, in your opinion are adequate.
And the second one, which says they are not adequate, you need to do these following
things to make them adequate. And so, that's the ultimate action we'll be asking you
to consider taking some time this evening. And I want to indicate at this point that if
you're not comfortable in taking those actions this evening, you may continue this
matter to a future meeting to consider'making those recommendations. I will let you
know thought that the Planning Commission Public Hearing is scheduled for next
Wednesday, September 3rd. So if you defer this matter and take an action at a point
after that meeting, or after the Commission ultimately makes a decision on the project,
your recommendation may not go to the Commission. It may go directly to the City
Council for their consideration. And that just depends on the timing of when you
might ultimately decide to take an action, compared to when the Planning Commission
might ultimately decide to take an action. The EIR document that is before you this
evening represents the culmination of about a seven-month process. You saw the DEIR
in April and May of this year. And there were extensive comments regarding the
archaeological Cultural Resources section of that document. As part of the required
California Environmental Quality Act (CEQA) evaluation process, once the EIR has
been prepared and circulated, a document which is called the Responses of Comments,
must be prepared. That is included in your FEIR. And, we've provided in that
document copies of all the minutes of the meetings that this board held, copies of all
the written documents that were either presented to this Committee or received by the
City commenting on the Cultural Resources section of the document. And each of
those documents are reproduced in the packet along with responses that have been
prepared both by our consultant staff, by our staff, and reviewed entirely by our legal
counsel also. So, those represent, at this point, what the City feels are adequate
responses to the comments. I should also note that the document itself, particularly for
cultural resources, has been completely revised. There has been extensive revisions to
the document which are shown in a red-line/strike-out format, so it's hopefully fairly
understandable to you as Committee members and to the public, as to what changes
have been made based on the comments that were received.
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The one point I do want to conclude with, is that there were an extensive number of
comments received on the document. The comments themselves did not change the
initial evaluations of the sites, and the initial determination of signifIcance of impact to
those sites that the City made in the DEIR. In the DEIR the City indicated that all the
archaeological sites on the property either, based on current information, are deemed to
be signifIcant or do not have enough analysis done of them at this point to be --- to
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make that determination one way or the other. But the City's conclusion was that since
there wasn't enough information on those sites, we considered all of them to be
signifIcantly impacted by the project. Therefore, each site on the project has been
determined to face an ultimate signifIcant impact on the FEIR. A lot of the information
that has been provided to you through the meetings you've had, and tlrrough the public
comments, were providing additional information regarding artifacts found at the
locations, differences of opinions as to which site was where, what artifacts were found
at what site based on the mapping program that was undertaken as part of the fmal
DEIR process. But the ultimate conclusions that each of the sites may be signifIcant
and that each of those sites would be impacted by the project, and therefore each of
those sites requires further evaluation and potential mitigation have not changed from
the issuance of the DEIR itself. And those conclusions still remain in the document.
And that is the reason why the Cultural Resources section of the document was not re-
circulated for additional review and comments --- as were some other sections of the
document - back a number of months ago, particularly regarding biology and
hydrology. Because in those areas there were new impacts that came forward as part of
that public review process that we had not anticipated and discussed in the initial DEIR.
In the staff report itself, we go back and provide you some information as to what,
under CEQA, is an adequate EIR. I won't go into the language of that at this point in
time. But once you've had your public comments and had some discussion among
yourselves, if that becomes a point of concern with the members of the board, I think
then we could return to what legally, under CEQA, is an adequate EIR. And what you
need to be considering as to what makes up an adequate EIR. And with that, I
conclude my comments and turn it back to the Chairperson."
Chairperson Johnston thanked Mr. Whittenberg and asked for any public comments.
Moira Hahn * Seal Beach
Ms. Hahn addressed the AAC, indicating she distributed comments to the members of
the Committee which should be in front of you on the table, and there are a few extra
copies for members of the audience that would like one. Ms. Hahn stated, "I'm not
going to read my comments verbatim because you have them to look at and I don't
want to take up your time. But I would like to mention a few points in here for your
consideration before you begin discussing the issue of the acceptance of the EIR or
what changes should be made before it's accepted.
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First off, it still doesn't consider the question of whether the archaeological sites on the
Hellman Ranch property are or are not part of the Puvunga complex. And that's a
unique group of sites that has tremendous cultural and religious signifIcance to Native
Americans and to others. So, I understand that KEA will be doing some kind of --- I
think, it's not really very clear from reading the Research Design --- but it seems to me
that the FEIR indicates that KEA will be doing something about the question of
Puvunga. But, it's not among the research questions that KEA has written that it will
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be addressing through the Research Design. And I'm also concerned about the EIR
sort of passing the buck to KEA on that question, because I think it really has to be
answered in the EIR.
2. The ethnographic component. Although a contact letter has been sent to some
Native Americans to inform them of the project, neither the EIR nor the
Research Design describes the ethnographic component in detail. I think that
merely sending a contact letter to Native Americans that will be affected is not
enough. Here's --- this is from a letter that's in the EIR. It came to the City
from the California Coastal Commission and this is a direct quote, "The City
must ensure that appropriate Native American groups have been consulted in the
development of the investigation". Now, the word consulted is key here. It
doesn't simply say you must notify the Native Americans or some of the Native
Americans. The word consulted implies a collaborative process. And I think
the intent is to include them in the planning of the investigation. So, KEA's
Jamie Cleland says that after the Research Design has been approved, when the
testing process begins, that's the point at which KEA will take some testimony
from the Native Americans. In my opinion, that's too late. They can't help
plan the testing program if they're not brought in .until the middle of it. So
that's my second point.
3.
The FEIR still contains a multitude of false and misleading statements that will
lead readers to form false conclusions regarding historic resources know to have
been discovered on sites on the Hellman Ranch. Number four --- artifact
diversity data. Oh, I'm sorry, let me go back. Especially conclusions
regarding burials that have been found on the project site and evidence that it
was used, the project site was used, as a religious or ceremonial area. First off,
fmding burials implies it was a religious or ceremonial area. But beyond that,
there have been artifacts found that any archaeologist will tell you are found in
that context are burial artifacts. Or they were medicine to. It's a shaman thing,
it was used for religious purposes.
4. Artifact diversity. In the FEIR is still incomplete. Now SRS justifIes this by
stating that it doesn't have to give every little detail of every artifact found on
the property. And I understand that. But, the FEIR's data base as to the site's
value, chronology, how rare things are, that's all coming from their artifact
catalog. So, they need to present the facts in total in order to reach scientifIc
conclusions.
5.
The FEIR still does not consider the sites directly across the street on the Naval
Weapons Station (NWS). But, if the facts are examined within the context of
them being part of the same complex, the EIR's conclusions of occupational
chronology and site usage diversity and value for the archaeological sites that
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are on the Hellman Ranch development project site are inaccurate. They need
to look at the whole picture. For example, across the street, 260, where it's
322/1,118. They found what looks like glass debitage and other things that
would have a historic connotation. We wouldn't know that if we didn't
consider them as part of the picture --- it changes things.
6.
This is very important. SRS has deferred answering a lot of questions regarding
the archaeological sites because, as it states in the EIR, KEA will be doing the
fIeld investigation to determine those facts. Now, I know you guys want to
protect the City and CEQA, as well as numerous recent court decisions, forbid
this practice. You can't defer a study and say we'll fIgure that out later. We're
doing it but for now, just approve the EIR. You have to answer the questions
and present the full range of archaeological information before the EIR is
considered. So, I would be concerned about the City passing something that
isn't fInished yet. The EIR cannot be fmalized until KEA's fIeld investigation
has been completed and the facts about historic resources remaining on the
project site have been fully disclosed and understood.
7.
SRS and KEA have obfuscated important issues in the EIR as well as the
Research Design concerning reported ancient human burials discovered on the
project site. There are a number of different ways they have done that and I've
stated what all of them are. In particular there are a couple of things that I'm
concerned about. Site Ora-262 has been re-named Area D. And, that's where
Cottrell and Cooley, previous archaeological researchers, said several aboriginal
burials were found. The present investigation as outlined by KEA calls for only
two standard units to be excavated there. It is highly unlikely to provide an
accurate assessment of potential remaining human burials. Another issue, SRS
in the DEIR and FEIR has stated that due to the fact that Redwine's original
maps were lost, a lot of researchers from the 1970's through the 1990's were
using the wrong site numbers. Now if this is true, the site that was called Ora-
263 is really Redwine's Landing Hill 9 or Ora-264. The reason this makes a
difference is because Redwine's one or two burials, as well as religious and
ceremonial artifacts, therefore are likely to have been discovered on the
Hellman Ranch project site rather than to the north of it, where Rockwell and
the Police Station now stand. Up until now we thought that was gone --- it was
history, it had been destroyed decades ago. The fact that --- if they're right
about the mapping system, that means that those burials are quite likely to have
been on the project site.
8.
Leonard Cutuli, the dentist that lives on the Hill in Seal Beach. I don't see any
discussion in either the Research Design or in the EIR regarding the map that
his patient provided of an ancient burial ground on the Hellman Ranch project
site. Another issue that hasn't been addressed is Mr. Glenn Peasley's testimony
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regarding two burials and a steatite artifact he found in site 852; it's also on the
project site. I couldn't fmd a discussion in either document. Now whether the
City agrees or not, I think it is required to present the full range of information
in the EIR.
9.
Project alternatives. I couldn't fInd anything in the FEIR, any discussion of
project alternatives that would avoid the archaeological sites. The developer
only considered alternative confIgurations that would also destroy the sites.
Maybe they could come up with a different plan. But the plans that they
presented wouldn't be any better in terms of preserving cultural resources. And
I don't understand why that is the case. I don't see why they couldn't have just
put a pocket park somewhere, done something, took out a unit, moved
something, to preserve part of the sites. So that's a question I have. Okay.
10.
And then fmally, the rings and ellipses 15' to 25' in diameter that appear on
computer enhancements of infra-red photographs taken last year of the Hellman
Ranch project site have not been investigated. This is important because one of
the things CEQA and the National Historic Preservation Act for that matter
wants you to consider is whether unique resources exist. Now, if they can't
fInd any historical basis for those rings and ellipses, that would make them very
unique. And it needs to be taken into consideration by the City. Thank you
very much."
Chairperson Johnston thanked Ms. Hahn and asked for any other public comments.
Eugene Ruyle * Professor. Cal State Long Beach
Mr. Ruyle stated, "I just wanted to endorse Moira Hahn's analysis. I really think that
the --- I hope that the AAC will ask the --- I don't know how this EIR can be made
good personally. But I hope --- I could think that you could just take her comments
and make them your recommendation because they are very good and to the point. But
a couple of other things I wanted to say. I live in Long Beach, as you know . You may
know about Long Beach's attempts to take over the Naval Station there and lease it for
a shipping terminal. And you probably know also that the court intervened and
blocked that process, because Long Beach had already decided that it was going to
build a shipping terminal in the port. And they didn't consider any alternatives such as
preservation and things like that and the court intervened. And that project is still on
hold. And I think the same thing's true here in Seal Beach. The Hellman Company
and the City of Seal Beach have already decided to destroy those archaeological sites.
They've decided they're going to do that. And now they haven't considered any
alternatives. They haven't proposed any mitigation measures. I never considered
mitigation a dirty word but recently I've started to think of it that way, because
mitigation simply is another way of destroying those sites. And I've heard members of
the AAC say well the sites are going to be destroyed anyway. They don't say what is
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feasible or not feasible. Again, I really have a lot of problems with bringing in an
archeologist to determine the signifIcance of sites. And again, I don't think Indians
need archaeologists to tell them sites are signifIcant. They know which sites are
signifIcant. They know if their ancestors are buried there. Those are signifIcant sites.
And you can see that these archaeologists really don't know what they're doing.
They've spent forty years digging out there and they still can't fIgure out what the sites
are, where they are, what the boundaries are or anything like that. So again, these
archaeologists are now going to tell Indians what the signifIcance of the site is. And
again, I think the process is all-wrong. Indians have been coming to the AAC, they've
been coming to the Planning Commission asking that their concerns be met. This has
been dodged around, it's been shuffled back and forth between SRS and KEA. No one
is taking responsibility for dealing with the concerns of Native Americans. People
have said well, we'll deal with that later. We're going to consult them sometime in the
future. But again, once the EIR is passed, it's going to be like a steamroller and
they're going to pass right forward unless there's a lawsuit to stop them. And again,
there are alternatives. It's not written in the laws of nature or anything else that those
sites have to be destroyed. They're only going to be destroyed because Hellman needs
to make money. And I was kind of interested. I always knew the Hellman family was
a rich family but I didn't realize until reading the EIR here just how rich they are.
They are one of the richest and most powerful families in Southern California history.
The founder of the family, Isaias Hellman, made his fortunes primarily in land
speculation here in Southern California. One of the places that got him started was
purchasing Los Alamitos and this site here. So, they've already made millions of
dollars out of this site. And if you look at income statistics about what's going on in
our county in the last decade or so, the richest families in the United States have been
involved in the most massive transfer of wealth from the rest of us to them. So, I don't
know how much more the Hellman family needs to made out of this property. Again,
I'd urge you to reject this EIR. It does not consider any alternatives. It does not --- it
has absolutely 110 protection for the concerns that Native Americans --- many of them
have come here again and again asking you to listen to their concerns. The
archaeologists haven't done this. The City Council hasn't done this. They major hasn't
done this. And I hope that you will."
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Chairperson Johnston thanked Mr. Ruyle.
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Dave Bartlett * representing Hellman Properties
Mr. Bartlett stated he wanted to make a few comments, stating, " First of all, Jerry
Tone and Susan Hori are here to answer any questions. I think I'll have Susan address
the CEQA issue that was brought up. But the alternatives, or actually the project, does
include the preservation of the sites in Gum Grove Park. If you look in the EIR, one
of those sites, I believe, has a very high cultural diversity index. And so, the project
does include the preservation of the park and those sites in it. The project also includes
the restoration of the degraded wetlands system. And it includes a significant amount
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of open space for everybody to enjoy. The point regarding CEQA I'd like Susan to
address. It's a very important to us. Our attorneys have reviewed the mitigation
measures in the FEIR as well as the fmal Cultural Resources report. It's very
important to us that it meets the legal standard and goes beyond in some cases. We're
in agreement with the City Attorney's OffIce that it does so. I think maybe we can
clarify the CEQA issue real quick. And then we're available for questions if there's
any questions by the Committee. "
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Susan Hori * representing Hellman Properties
Ms. Hori stated, "I'm representing Hellman Properties and I'm an attorney. And I
wanted to only address one specifIc issue and that was the issue that Ms. Hahn brought
up regarding whether or not the City would be improperly deferring studies if they
were to approve this EIR. There is a line of cases that talks about the deferral of
studies and how local agencies should not do that in order to avoid --- by doing so they
avoid making a determination as to whether or not there is a signifIcant impact on the
environment. In this situation, however, Seal Beach I think is taking a very
conservative approach in addressing cultural resources. Because after reviewing all of
the data that has been reported from the site, based on all the prior archaeological
excavations, the City has determined that a number of the sites would have a signifIcant
impact if the development were to occur. And for those sites where there is
insufficient information because either they haven't been tested or there is a lack of
complete data --- rather than saying that the impact would be insignifIcant, the City has
taken a very conservative stance and said, no we believe that those impacts are also
signifIcant even though we don't have the data to make that determination. And
therefore, we're going to require the developer, prior to being able to develop this site,
to implement a series of mitigation measures which are set out in your Archaeological
Element and also in CEQA, which requires the completion of the Research Design, the
preparation of test programs and test excavations on that site to make sure that before
any development and grading occurs on that site that those sites have been looked at
and have been examined. So there really hasn't been a deferral of any studies. And in
fact what has occurred, based upon the current studies that have been done to date, the
City has very conservatively said, these sites are important and therefore, before any
development can occur, mitigation measures have to be applied to each of the sites.
And those mitigation measures are in total compliance with CEQA and are consistent
with State law and State procedures regarding the protection of cultural resources. I
wanted to just clarify that point. "
Chairperson Johnston asked, "Does anybody have any questions about that or wanted
to make comments?"
.
Moira Hahn * Seal Beach
Ms. Hahn stated, "I just wanted to understand --- how is following the City's
Archaeological Element of its General Plan going overboard on mitigation measures?
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Wouldn't the Hellman's be required to do that? It's part of our General Plan. That's
the procedure. And also, I'd like to know more about the specillc mitigation measures.
I know Gum Grove Park will be saved. Beyond that, what will be done? Thank you. "
Chairperson Johnston asked, "Can anyone answer that?"
Mr. Whittenberg suggested, "Rather than trying to get into answering each question
that somebody comes up with, and keep coming up and back and up and back, I think
it'd be better to get all the comments and then allow us and the consultants who
prepared the document to respond to those questions and comments that people may
have. "
Chairperson Johnston stated, "Okay. Did we have any more public comment on this?"
Mr. Ruyle
Mr. Ruyle stated, "I mean, I just want to make sure I'm not missing something.
Mitigation measures are covered on pages 66 through 68, right? That's it? Those are
the mitigation measures? Towards the back here. Under --- sixty --- I just want to
make sure that I'm reading correctly. I have --- "
Mr. Whittenberg stated, "If I might, the mitigation measures are shown on Table 15-1.
~ Mitigation measures CR-3 through CR-I1. And, once we've gone through the
comments, I will kind of go through those individually to go over what the proposed
mitigation measures are in the EIR document itself. Are there any other comments
from the public at this point in time?"
Ms. Hahn
Ms. Hahn stated, "One of the mitigation measures is that the Research Design will be
peer reviewed. Who is selecting the peers this time and when will that be done? Will
the Committee get a vote?" Mr. Whittenberg respnded, "It's being done at this point
in time. The peer review people were indicated in the proposal from the frrm itself, at
the time they were selected." Ms. Hahn stated, "So KEA selected its own peer
reviewers?" Mr. Whittenberg stated, "They were approved by the City when the City
approved the contract with them." Ms. Hahn stated, "But KEA selected the
archaeological fIrms that will be reviewing ... ." Mr. Whittenberg stated, "KEA
suggested people that the City concurred with." Ms. Hahn stated, "That seems a little
out of whack to me. It seems ----." Mr. Whittenberg stated, "You can take that issue
up at the City Council, they approved the agreement and approved the Research Design
people, and that's not part of the EIR that we're talking about at this point." Ms. Hahn
stated, "It's not part of the EIR? But we were just told that this is part of the
compliance for the EIR." Mr. Whittenberg responded, "The people who have been
selected is not required as part of the EIR. The EIR requires a peer review to be done.
'-'" A peer review is being done. Whether or not you, professionally or personally, may
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care for the people that are doing that peer review is a separate issue from a peer
review being done." Ms. Hahn stated, "Okay, but to satisfy the EIR, one of the steps
that's being taken is that the developer is following the City's Archaeological Element,
part of the General Plan. By following their steps, they need to do a Research Design
and it is going to be reviewed but not independently. By three --- by how many
consultants this time Lee?" Mr. Whittenberg stated, "It's being reviewed by three."
Ms. Hahn stated, "By three fIrms selected by KEA." Mr. Whittenberg responded, "By
three individuals, not particularly fIrms. Two of them happen to be professors at
universities within the State of --- one in California and one in Oregon." Ms. Hahn
asked, "Was this run by the Committee or was it just the Council's decision?" Mr.
Whittenberg responded, "It was run by the Committee when they considered the frrms.
It was included in the proposal that the Committee members considered when they
interviewed the fIrms. It was considered by the Council when they hired the fIrm."
Ms. Hahn stated, "Okay, so it's not independent. It was up to KEA who would review
them." Mr. Whittenberg stated, "I don't know what you mean by independent. When
it was reviewed by this Committee, the Committee made no objections to those people.
The Council had no concerns. So I'm not sure what you mean by independent." Ms.
Hahn stated, "Okay, I know what I mean by independent. It seems to me that you're
not getting a pure review if KEA can select who will review them. But anyway, that's
it. Thank you. I'll have more comments later, maybe on the Council level. "
'-"
Chairperson Johnston thanked Ms. Hahn and asked is there any other comments?
There was no one else wishing to address the Committee.
Mr. Whittenberg
Mr. Whittenberg stated, "I think at that point I would like to respond to a couple of the
comments and concerns that you've heard this evening. And then I'll let P&D if they
feel I haven't responded to some of the things that they think still need to be responded
to - allow them to do that also.
The first issue, and it goes back to the comments that Ms. Hori provided to you, is that
in our mind the EIR does not defer studies unreasonably to a point at a future date. As
we have indicated, the document clearly indicates that from the City's viewpoint each
of those sites has the potential to be a signifIcant site and would be signifIcantly
impacted by the project as proposed, and then recommends a number of steps to
investigate those sites to do a couple of things. The fIrst is to determine if they
important under CEQA. If a site is important under CEQA then there's mitigation that
needs to be undertaken for that site if it is not able to preserve it in place. And the
CEQA guidelines very clearly indicate what is considered an important site. The
CEQA guidelines defme what is important. And that is the definition that is used in
this document for what is an important site. And I'd like to just read those both for the
Committee and also for the audience. And this is the criteria that you as Committee
'--" members need to be considering when you're looking at the documentation itself.
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There are fIve different criteria that defme a site as being important under CEQA. The
first is the site associated with an event or a person of recognized signifIcance in
California or American history or a recognized scientifIc importance in pre-history.
Secondly, can the site provide information which is both of demonstrable public
interest and useful in addressing scientifIcally consequential and reasonable or
archaeological research questions. Third, has a special or particular quality such as the
oldest, best example, largest or last surviving example of its kind, (D) is at least 100
years old and possesses substantial stratigraphic integrity and (E) involves important
research questions that historical research has shown can be answered only with
archaeological methods. Those are the criteria that the City considered when it made a
determination that each of the sites on the property may be important. Whether or not
those sites ultimately are determined to be important will be an action that would be
determined by KEA as part of a Phase IT test level investigation. That is when you
actually determine whether a site is signifIcant. And as you might recall, in reviewing
your Research Design document, they will be looking at it from both CEQA
requirements and also from eligibility standards for National Register of Historic
Places. Those actions will be taken once, or if, a project is approved. And at that
point, then the test level investigations would occur. If a project is not approved, there
is no impact to the sources that are out there at this point in time, so there'd be no
additional actions taken.
'-"
The second comment I had is that the EIR itself has been gone through in an extreme
amount of detail by our offIce, by our consultant and by the City Attorney. And the
point that you need to keep in mind is, again, it kind of goes back to a number of the
issues that have been brought of in the comments --- that information may not be
directed to the right site. It may be misleading. Different people may disagree as to
what the importance of those areas may be. But that doesn't change the conclusion in
the document. The document still says each of the sites has the potential to be
signifIcant and that needs to be evaluated at a later point in time. And that is what is
required of CEQA. CEQA doesn't require you to do all of the evaluation before a
project is approved. It requires you to indicate if there's a potential impact and if there
is, how can you mitigate that? Mitigation does not require that a site be not impacted.
Very clearly, in the appendices to the CEQA documents, it indicates that mitigation is
an allowable action to take on archaeological sites and mitigation may include testing of
sites and excavation of areas to determine what is or is not signifIcant in those areas.
And that is very clearly outlined in the CEQA guidelines. So, I just want to make sure
that you understand that there are certain things in the CEQA guidelines that control
what the City's information is at this point in time. The Research Design process is a
separate process from what you're considering at this point. What you're needing to
focus on, is whether or not this document, in the form it is in, would allow the
Planning Commission and City Council to understand that the project would have an
impact on archaeological resources. And that's the extent that CEQA requires you to
go. You must be able to forward a document that gives them a reasonable
'-"
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understanding of the impacts of the project and a reasonable basis on how to base the
mitigation measures that are proposed in the document. And whether or not you feel
those mitigation measures are adequate to address the impacts to the best of the ability
of science as it exists at this point in time for the project. I think that would kind of
conclude my comments. If either Sylvia or Bob might have a couple of other
comments before we turn it back to you for some deliberations."
Sylvia Salenius * P&D Consultants
Ms. Salenius stated, "I'm with P&D Consultants. I think I just want to stress one key
point that Lee has made. Again, we know as a result of this project that up to ten
archaeological sites are going to be directly impacted by the development. There are
another fIve that are in Gum Grove Park which would not be disturbed. But we know
that, we have determined that this is going to be a signifIcant impact and that is our
obligation under CEQA is to determine whether the impact could be signifIcant or not
signifIcant. We have stated it will be signifIcant. We've identifIed the mitigation
measures that we think should be followed up according to the requirements of CEQA
when you have signifIcant sites. So that's the essence of what the archaeological report
is all about. And I think we're real clear about that one --- that one call on signifIcance
here. Thank you. "
Ms. Hahn
'-" Ms. Hahn stated, "I have a question if you don't mind. You say up to ten
archaeological sites will be impacted and fIve are in Gum Grove. What is impacted?
Ms. Salenius responded, "Impacted is essentially disturbed and destroyed by
development. So, the question is though --- I mean --- we have a Research Design that
allows the retrieval of information from those sites before the actual construction
occurs. That's the parallel track that's going on here, while this environmental
document is being considered. And the Research Design is intended to determine
additional scientifIc information from these sites. So the actual activity of research
disturbs sites too, obviously because you've got to excavate them. But once you've
gotten the information that you intended to get out of the Research Design and if the
development project is approved then construction would occur. Is that clear? Ms.
Hahn continued, "Okay, then a question that I have is okay, ten of the sites are going
to be destroyed by development. And what we'll get out of this is whatever scientifIc
information can be gotten through the testing investigation and the writing the Research
Design as a sort of planning document for how that test investigation will be done.
But, none of the research questions involve Puvunga. Now, I think if it's a forgone
conclusion that these sites are history, they are going to be destroyed, that we need to
know whether or not is Puvunga and they need to do a very thorough job of analyzing
the data on those sites so that we get something out of this before they're destroyed.
That's all I wanted to say. Thank you very much."
'-'
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Chairperson Johnston said, "Excuse me, I have a question Moira. Are you talking
about comparisons to Puvunga? Whatever artifacts are removed, are you saying that
they need to compare it to Puvunga?" Ms. Hahn responded, "Yeah, and just to do the
ethnographic component. Talk to the Indians. See what they can fmd out. Get as
much data as possible about the times of occupations, the types of artifacts in order to
answer the question whether or not this was part of Puvunga. Because right now KEA
has drafted, I believe it's ten, proposed research questions and none of them involve
Puvunga. It's the fIrst thing in my mind. And I think it's something the City should
want to know and it should be part of it. Thank you."
Member Goldberg
Member Goldberg stated, "I think we're getting things mixed up. We're mlxmg
oranges and apples together, Moira. That KEA is doing a Research Design, we're not
talking about that this evening. We're talking about the EIR. She answered your
question as a follow-up for what they found. And then what the next step would be. "
Chairperson Johnston asked how the Committee should proceed?
Mr. Whittenberg
Mr. Whittenberg stated, "At this point it's really, I think, up to the AAC to proceed as
you feel appropriate. I would want to indicate though that you may want to go through
.,-, those mitigation measures particularly, to ensure that those, in your mind, are either
adequate or inadequate. You'll be asked sometime this evening or at a later point in
time, to make a recommendation to the Planning Commission regarding those measures
particularly. So, at some place along this evening, I'd suggest you focus your attention
to those. But fIrst you may want to go back to the general issue of the EIR document
with the revisions and responses to comments. As to whether you feel that the Cultural
Resources section that's been provided in the FEIR adequately presents enough
information for a Planning Commission and Council to make an informed decision
regarding the project. And that may be where you want to make your focus, your
discussion at initially.
Member Young asked, "What's the defInition of a resource?" Mr. Whittenberg
responded, "A cultural resource? That is a site. Well, that's what they're suggesting.
And let me go back, because I think there's some discussion on that someplace else.
And we've indicated in the past that KEA will be providing --- and they've already
provided to you in your Research Design document, a proposed test level excavation
plan. You might recall a discussion that Lorraine kind of addressed that issue at the
last meeting. Regarding the appropriateness of the number of test pits and shovel test
probes that were being proposed in the Research Design. So, this is what the
suggestion is in the EIR. You need to keep in mind that that is a minimum and that the
Research Design will be defIning something different than that."
'-'
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Mr. Whittenberg
Mr. Whittenberg responded to a question regarding Mitigation Measure CR-5.b,
stating, "Well, that's your call. I would suggest, in that particular area, since we know
that KEA is already proposing something different than that, that you may wish to
change the language of that just to indicate that that should be determined by the actual
fIeld investigator on the site. I think that would be the most appropriate
recommendation for that. Chairperson Johnston stated, "Okay, so if we like decide to
approve it, that would be one of the modifIcations we could add to it." Mr.
Whittenberg stated, " Yes. If, you know, the Committee agrees with that. I would
think that would be a reasonable suggestion. "
Dave Bartlett
Dave Bartlett stated, "I would like to make a brief comment. And hopefully we can
stick to the subject at hand here. But, excuse me, the subject at hand, which is the
EIR. On page 41 of the Research Design it clearly states that there are questions
going to be asked about Puvunga and that relationship. So, I just wanted to make it
clear that the Research Design does cover that issue. And, it's an important issue that
KEA has covered. And, it's not part of the CEQA process. And if we can stick to that
issue. We're here for this meeting on the CEQA aspect. I just wanted to make that
issue clear. "
'-' Member Willey
Member Willey stated, "I don't know why it is, but I spent a great deal of time trying
to fIgure out exactly what I'm going to say this evening. Because there are a variety of
things that need to be addressed. And I'm not sure whether this comment should be at
the beginning or the end, but I'll start with it since it's something that concerns me. It
is an unfortunate situation that SRS was the one that, either through the intervention of
Hellman Properties or through the intervention of the City, obviously approved by the
City, or the choice of P&D that SRS did this design for the EIR. It is unfortunate
because no matter what decision we make, whether we accept it, whether we reject it
either whole-heartedly or otherwise, or whether we accept part of it, the Native
American community are certainly not going to be happy. Because they have been
totally unhappy with SRS. So, I feel that to some degree we were put in an untenable
situation. Now, aside from that, there are two sections here. We have the Appendix
section, Section B, which is I believe an addendum and truly an appendix to the EIR.
What is of concern in the EIR is Table 1-2, pages 18. A qualifIed archaeologist
retained by the City of Seal Beach has conducted a literature research from baseline
survey and cultural resource records and has confirmed whether each archaeological
site on the Hellman Ranch SpecifIc Plan is important under CEQA. Well, as Lee has
particularly stated, there isn't enough information. And the City has said that they're
all important and need to be investigated further certainly, before any type of
destruction can take place. No matter what SRS has determined, in terms of whether
'-'" low, medium or high, it's inadequate. This statement, and of course I will question,
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qualifIed archaeologist as well. But in any case, this statement, it goes too far. I don't
believe that SRS is capable, from the information given, of making a determination
about the value of those sites. Not enough information is known. And therefore, the
City is right, in terms of their evaluation, that more information needs to be acquired to
make the determination. This is --- we have here a conflict. This is saying one thing,
the City is saying something else. I don't believe that this should say this.
'-"
Mr. Whittenberg
Mr. Whittenberg responded, "Let me just go back, because I'm not sure where the
disagreement is. The mitigation measure says that the City will select an archaeologist
to evaluate the sites prior to site preparation, grading or construction. The City started
that process using KEA ---, CR-3. Prior to any site preparation, grading or
construction activities." Member Willey stated, "It says that a qualified archaeologist
retained by the City of Seal Beach has conducted a literature research." Mr.
Whittenberg responded, "No. The City shall verify that a qualifIed archaeologist ---
right, but it's prior to construction on the property. Not at this point in time." Member
Willey stated, "It's not clear. And that needs --- to me that's not clear. Given the fact
that you have a document as the Appendix E, which goes into great detail to say this is
low or high, it appears that this part has essentially already been done. I would be
more comfortable, it said, that a qualifIed archaeologist retained by the City of Seal
Beach will conduct --- you know --- it's just --- it seems to give more import to SRS' s
report that I feel is justifIed." Mr. Whittenberg stated, "That change, I think, is one
that doesn't change the basic condition. And as staff, I wouldn't have any objection ---
. " Member Willey stated, "And when someone reads this. And if I see it this way,
someone else is likely to see it this way, and say, oh, this is already done. The City
has accepted it. This is what we're going to go by and that would make me extremely
uncomfortable. Okay? Okay." Mr. Whittenberg stated, "I understand the
clarifIcation then."
'-'
Member Willey
Member Willey stated, "CR-4, as you pointed out, it should say ten sites, it says seven.
CR-5, CR-5 I had a problem with in the fact that, and this is I think something that
was mentioned previously. The mitigation plan is very detailed. One unit per
resource, wants a mechanical program, preferably auguring to verify boundaries, et
cetera. I'm uncomfortable with that as a part of it, simply because it seems to defme
what KEA should do. And I feel that that is out of place. Yes, it is right to say
mitigation measures. I would much prefer if it say something to the effect of,
excavation needs to be done in order to determine site boundaries and signifIcance of
the site, rather than describing how the next archaeological group that is selected should
do it. That is to me totally out of place. Because again, it's the same problem. It's
not that I don't trust the City, it's just that the composition of the Council, the
composition of a variety of other institutions that are involved in this may change. And
as that change takes place, to come back to here and say well, this is the way it says it
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should be done, creates a level of discomfort because I believe this is an inadequate
design for mitigation or for even testing. Whatever KEA does later, we'll deal with
when we're dealing with the Research Design. Mr. Whittenberg stated, "Maybe just to
go along with that comment, if the suggestion would be that we change the language
just to reference that the actual fIeld investigation program would be determined by the
City-appointed archaeologist and that program will be set forth in the Research Design
document. Does that address the issue?" Member Willey stated, "To me, I would be
much more comfortable, simply because I don't want, in essence, for someone to come
back and say, well, it's in the EIR and this is the way we're going to do it, whether it's
right or it's wrong. And because I feel it's wrong, I'd rather leave it --- rather than
more specific, more general. So that we can deal with it on a level of a true Research
Design with the archaeological frrm involved. And be really detailed in terms of our
analysis of it at that level. Okay, I concur in CR-6 where the need for additional
excavations at each site. That statement I'm happy with. I'm happy, at least at one
level, all construction-related documents will include notations clearly identifying those
areas on the site that shall be preserved as environmentally sensitive areas. I would
also, somewhere in the document, and I did not see it, like a statement that would say
that a qualifIed archaeologist and monitor would be on the site even after the
excavations are done. Simply because no excavation can fully --- unless you literally
dig every square inch of the affected area --- no archaeological excavation can fully
fmd everything that's there. So if you're going to disturb the entirety of that area, it
would be of great benefIt both from understanding of the site that an archaeologist and
a Native American monitor be there during any grading and excavation in the area just
in case something is found. Because it is human nature that you want to get a job done
and it's oh so easy to just not see what flipped up with the backhoe or the grading
machine. I just like extra monitoring to be sure that indeed, we are not trampling on
the cultural resources if the project is approved and if the sites are truly destroyed.
Yes, it's mentioned that the design for fInal mitigation will be prepared. I noticed
through there that there was an understanding that the Research Design involves initial
testing upon which determination for a phase three --- and I am glad that is clarifIed. I
see in CR-lO that information has been added that the research both archaeologically
and ethnographically will --- one of the questions that will be focused on are related
areas, Puvunga et cetera. Okay, it does say all site preparation, grading and
construction activities will be monitored by a qualified archaeologist --- which is what I
wanted. I did not see that a Native American --- so please, in CR-12 which does
address my previous point, I believe it would be important to say that a Native
American monitor as well as a qualifIed archaeologist will be there. "
'-'
Mr. Whittenberg
Mr. Whittenberg stated, "Just going on that point, if you go back up to CR-9, the last
sentence in the non-highlighted paragraph, it says when all site disturbance activities
are complete, a Native American monitor will prepare a final monitoring report for
submittal to the City of Seal Beach." Member Willey responded, "Yes, but that is in
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reference to the archaeological fIeld activities. I want to see also a reference to the
grading and the construction activities as well. I don't see that. Yeah. I see that as
the monitoring of the archaeological fIeld activities. Which of course I agree. In
addition, location of all archaeological resources that require grading shall be
indicated (fInished reading). Yeah. It's not as specifIc as I would like to see." Mr.
Whittenberg stated, "You'd like, actually, some more clarifIcation in that highlighted
paragraph under CR-9 --- perhaps would be the place to put the language." Member
Willey stated, "Oh, I'm sorry. It's --- CR-12 is the historic resources. The same kind
of thing needs to be said for the pre-historic resources. But, once you have an
archaeologist on the site and once you have a Native American monitor whether the
content that's found is historic or pre-historic, both, any archaeologist should be
cognizant of. That is essentially my comments. In terms of the EIR itself, have lots of
markers in terms of the appendix. I don't know whether I should bother to go into
that." Mr. Whittenberg stated, "The appendix is a supplemental document to the EIR.
And I would be more concerned if you have comments on the revised Cultural
Resources section of the EIR itself. If you feel there is still inadequate information in
there to allow the Council to make an informed decision is really what you need to be
looking at. "
'-'
Member Willey
Member Willey continued, "Right. To tell you the truth, as much as I read through
this document, the only section that I could fmd that dealt with it was the mitigation
and the appendix. Where did I miss it? Mr. Whittenberg asked, "Where did you miss
what? The revised Cultural Resources section? I'm sorry, Appendix A is the revised
Cultural Resources report." Member Willey stated, "That's what I was wondering,
whether or not you wanted me to go into detail." Mr. Whittenberg said, "No, I don't.
Let me --- the revised Cultural Resources section of the document is Appendix F.
That's the actual chapter of the EIR itself. That is the actual body of the EIR document
that has been revised, based on the comments received during the public comment
period." Member Willey stated, "I looked through this and somehow missed that ---
unless I made some comments on it. Oh I see why. Because it looked to me like it
was pretty much a paraphrase of ---." Mr. Whittenberg stated, "It's a distillation ---
may be is a good word to use. It distills the information from Appendix A, which is
kind of a technical background document and summarizes it in an EIR format."
Member Willey said, "The green page stuck together. However, what I can do, I can
briefly cover the things in E. And if you fInd them in F --- that you used them in F ---
those are the things I'm uncomfortable with. Let's go to page 1 of the introduction in
terms of Appendix E. All right, second paragraph towards the bottom it says the
location of prehistoric shellfish scatters on these knolls have been noted by
archaeologists over the last 43 years. If you use this statement, I would not --- it
minimizes the extent of the occupation. It's a nice comment that in essence --- there
nothing but shellfIsh scatters. It's not true. Perhaps as you go through the whole
document, yes, it pales in signifIcance with the information given. But if you follow
~
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'-'
the rule that several college students I have known well follow, of reading the fIrst and
last sentence of any paragraph, and then assuming that they have acquired the
knowledge, I feel that it minimizes and it makes me uncomfortable. On page 3 it says
the LSA work was not completed, we don't really know the extent that they completed
it unfortunately. I've heard various conflicting stories that they did excavate everything
and have the records for it but they were all lost. I've also heard they never completed
it because they were stopped before they completed the excavation. The fact is we just
don't know. And so again, if you use that statement anywhere it's not valid because
we don't know. Yeah.
Ms. Salenius * P&D Consultants
Ms. Salenius stated, "My question there would be, I know that the folks at SRS talked
with the LSA principal investigator about that and she indicated that they had been
stopped and that the cultural materials were given to the property owner." Member
Willey stated, "As we understand it, the cultural materials were given to the property
owner. But I have heard a variety of statements that conflict with the amount that was
actually completed. Yes."
Ms. Hahn
Ms. Hahn stated, "There's an article in the Seal Beach Journal in August of 1990 that it
had been completed because at that time Mola still wanted to build even though the
'-'" City Council had voted it down." Member Willey stated, "That's what I thought."
Mr. Whittenberg stated," If I might, I'd prefer we not get into a lot of comments
back and forth again. I think that's going to take away from your purposes. The one
comment I would make is that there may be a disagreement as to whether or not the
work was done but does that change the information in the document to where ... it
makes the information not understandable to the Council as they're determining
whether or not there's a signifIcant impact, and I think that's what you need to focus
on. Does that detail make it uncertain to the Council that there are signillcant impacts
to the site?
Mr. Bartlett
Mr. Bartlett stated, "Let me just clarify that they weren't given to the property owner,
they were given to Mola. "
Member Willey
Member Willey said, "You're right, my apologies. There are a number of comments
along that line as well. One of the things that I must laud SRS for was their mapping
efforts. They appear to be well done. Certainly the discovery of the Redwine maps,
the real one, are of extreme importance. From my reading of several documents I do
not doubt their validity. What I'm unhappy about, and this is just an aside just for your
general information, what I am unhappy about is I do not know when those came to
'-' light. And if they came to light at any point prior to SRS contact with P&D to do this
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'-"
study, SRS is in serious violation of archaeological ethics for not immediately turning
them over to UCLA. Comment aside, but I needed to make it. Let's see,
interpretations. There is a great deal of discussion, and I've marked more than one
place, where discussion has gone on which site is which. At this point there are a lot
of conflicting ideas in terms of how the sites should be named and so forth. It does not
impact on its signifIcance in some respects but in other respects, given what SRS placed
as signifIcant it certainly has an effect. I believe at this point, that the only people who
can make that determination are UCLA and later KEA, or whoever eventually does the
excavation. I think that those groups must sit down together and make a fmal
determination and issue a paper that will resolve the question once and for all about
which is the proper designation to be given --- just so that all the information from the
various sites can be put together properly. Because it would be a great shame if in the
mix-up that we misplace artifacts and therefore misplace the signifIcance of an area if
we misinterpret the relationships of areas because of this semantic fIght. And there are
just whole sections of this that are of concern. Another section I was concerned with,
I'll try to wrap this up very quickly, the diversity index that was done appears to be to
be simply an attempt to minimize the value of the sites on the Hellman Ranch property.
To limit the diversity index and their evaluation of the sites to Redwine's collections is
wrong. If you're going to use Redwine's surface collections, you need to use the
surface collections of every group that worked on that site. It is unfortunate we don't
have everything. I would, however, concur that the hearsay evidence of so-and-so
happened to fmd --- you're welcome to note it but at this point scientillcally you can't
say that this has an impact. But it can give you a direction to start looking. You
know, they say that these things were found. It does provide a direction that this
possibility exists. But it cannot be included in terms of analysis, simply because it's
not verifIable. But I do believe that SRS in their analysis and in their designation that
the majority of the sites that are on the property right now are of low signifIcance is
incorrect. I would like to see it removed from any quotes that P&D may have used
because Lee has admitted the City considers them all signillcant. And I don't like to
see anything in the EIR that would allow people to go back and say but this is what the
EIR says and they're not of signillcance. Essentially that I would throw out. Again,
there are comments all over here in that section of something being valid doesn't take
into account surveys. Let's see, again there's all sorts of inequalities by not using all
the data that was collected, and at that point I will essentially quite talking and let
anyone else who wishes to comment do so."
~
'-"
Member Fitzpatrick
Member Fitzpatrick stated, "My only concern at this point were the infrared
photographs. They didn't show up and I'd certainly like to know why. I've been out
of the country for six weeks so I might not be exactly in the loop on that. But I think
they're very signifIcant. And I think we're selling ourselves short by not having
them." Mr. Whittenberg said, "I can address that. From the City's standpoint, we
have sent a letter to the individuals that prepared that document and evaluated the
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'-"
photographs requesting to purchase the photographs that they have in their possession.
They have not answered the City's letter to this point in time." Mr. Whittenberg,
responding to a question from Member Fitzpatrick, stated, "The letter was actually sent
--- not that long ago, sent about three weeks ago. Again, I'd indicate the EIR indicates
that information is available. Because of the quality of the Xeroxes they really can't
make a judgment. But the City's determination is that regardless of that at this point,
we still consider all the sites signifIcant."
Member Willey
Member Willey stated, "I only had one comment on that in terms again of what SRS
said. And that was how they determined it was done at an oblique angle. I have seen
those and in fact, I have seen the enhanced photographs. And I'm just real curious
where they saw it as being taken as an oblique angle. If you have included that
information you need further clarifIcation from SRS on how they made that
determination. Especially if the Xeroxes are so bad that they can't really see the data.
I just found that very difficult to understand. So that's another point that needs
clarifIcation. "
Member Young
Member Young stated, "Well, I still think that it shouldn't be just one two-meter
square excavation because of these resources are several hundred or thousand square
....... meters. And one --- excavation isn't going to tell you anything. And let's see. I also
believe that the infrared photos need to be studied. And if we can't get the originals,
maybe it should be done again because there are things there. Those photos did show
ellipses and circles. So you can't say the things are there. And if you can't get the
original photos then maybe it should be done again. And in the EIR, I believe to
alternative was considered that was avoidance of the sites. If there's any way to avoid
any of the sites, especially like 264 --- at least save something. I wish they would have
had something in there about that. And, let me see, okay that's all."
Chairperson Johnston
Chairperson Johnston said, " I just have a few things I'd like to say, especially about
Ora-262. I'm real disturbed about that. Either it's in or it's out or it's destroyed or
it's there. And this is the area; this is the site where the burials come up from. I'm,
you know, real disturbed about that and I'm real concerned about that. Because that's
the area that no one really does anything with or says anything definite about. Any
time there are burials it is signifIcant. It's a burial ground. As a Native American I
am opposed to any destruction of any sacred site or ceremonial site. And to me this is
a sacred site. We do not have methods of mitigation. We do not want our burials
destroyed. We want our burials left alone and that's our preference. I am not an
expert and I don't know much about archaeology, I'm going to admit that or anything
like that. I just know how I feel. I'm being taught by good, smart people. I listen to
'-' people like Lori and the Committee members who also are friends, our professional
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'-'
friends who are here to help us. I have a lot of problem with this EIR. I have a lot of
problems with SRS. I vehemently opposed them in the beginning and still do. They
have been a part to the destruction of many of our ancestral burial grounds. And I
cannot resolve or reconcile to them --- maybe never. So, I've had a problem with this
from the very beginning --- that SRS was employed to do the EIR. And at this point
that's all I have to say, thank you."
'-'
Mr. Whittenberg
Mr. Whittenberg said, "I think at this point, I don't know if you wish to try to deal
with the resolutions that we've suggested you consider this evening or if you want to
continue this matter to another meeting to do that. It's really up to you as Committee
members as to where you wish to go from here. Again, understand that if you do not
take some sort of an action before September 3r'" you may not be making
recommendations to the Planning Commission, you may just be making
recommendations directly to the City Council. The Planning Commission Public
Hearing is scheduled for September 3rd. Given the track record of the Planning
Commission, I would be surprised if they make any determinations that night. They
will be in the position to. So I don't want you to think they will not. They could if
they felt they were ready to. They may not. If they do not, they would continue the
matter to their meeting of September 17th. And then at that point, they still may
continue the matter again --- it's hard to predict where --- how long it will take them to
deliberate the matter. So, I just want you to be aware that if you postpone from tonight
until some time after September 3rd, you may not be making any recommendations to
the Commission but just directly to the City Council." Chairperson Johnston asked,
"How is the wording on your resolutions?" Mr. Whittenberg indicated they are in
your agenda packet, stating, "They're the ones that were delivered in your agenda
packet - in the mail to you. Actually, they were delivered about a week ago. But
before you consider the resolutions, I think we need to go back to the purpose of your
review. It's to determine whether or not this document is adequate under CEQA for
the purposes of CEQA legislation. And I just want to read the section of CEQA that
talks about what is an adequate document; it says An EIR should be prepared with a
sufficient degree of analysis to provide decision makers with information which enables
them to make a decision which intelligently takes account of environmental
consequences. An evaluation of the environmental effects of a proposed project need
not be exhaustive. But the sufficiency of an EIR is to be reviewed in light of what is
reasonably feasible. Disagreement among experts does not make an EIR inadequate.
But the EIR should summarize the main points of disagreement among the experts. The
courts have to look not for perfection but for adequacy, completeness and a good faith
effort at full disclosure. That is Section 15151 of Guidelines for Implementation of
CEQA. " Mr. Whittenberg continued, stating , "To follow on that point, to just
reiterate it, we as staff, the consultant team, the City Attorney's OffIce has reviewed all
the comments. Particularly, the City Attorney's OffIce and us have spent a lot of time
in reviewing the responses to ensure that we feel that the responses to the comments are
'-'
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Archaeological Advisory Committee
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'-'
adequate under CEQA and under case law that has come about over the years since
CEQA has existed. In the City Attorney's opinion and in our opinion as staff, we feel
that the document before you is an adequate document in accordance with that section
of the CEQA Guidelines that I just read to you. You as Committee members obviously
have the discretion to disagree with our judgment and that is perfectly fme. But I just
want you to understand when you're making your responses to either the Planning
Commission, the EQCB or the City Council as to the adequacy of the document, the
adequacy should be judged within the framework of the language of that section of
CEQA. Whether or not there's again a concern as to which site is or is not in the
project, what artifacts mayor may not be attributed to one site over another site, in our
mind those are details that don't change the determinations in the document. The
document says yes there are number of sites on the property, and there are more sites
now on the property than there were at the beginning of this process. And that each of
those sites has the potential to be a signifIcant site. Each of those sites needs to be
evaluated. And you need to make a determination as to whether or not that information
is adequate for the Council to make an informed decision once they consider whether or
not to approve the project. "
'-"
Member Goldberg
Member Goldberg stated, "I think the Committee should make some type of a decision
tonight --- either accepting it or rejecting it, because I think it is important that we
present all of our fmdings to the Planning Committee. If there are some minority that
oppose it or accept it and they're the minority, then I think that have the privilege of
going to the Planning Committee and making their statement. I don't have a problem
with having another meeting for the public but I do have a problem if we don't make
some kind of decision so the Planning Committee gets it on September 3rd. "
Member Young
Member Young stated, "Well, Bruce hasn't had a chance to go into it in any detail. If
four of us vote, because he'd probably abstain, right? Member Young asked Member
Fitzpatrick, "Are you ready to vote? You are, okay. Well, I don't think we should
rush it, either way. The Planning Committee might not vote on it is what Lee said."
Mr. Whittenberg said, "All I said, was given their previous track record, it's unusual
for them to make a decision on a project of this nature at the very fIrst meeting. But I
can't guarantee that they won't. And I just want you to be aware that if you defer
taking some sort of recommendation until after September 3rd, you may not be
providing any information to that particular reviewing body." Member Young stated,
"But actually the City Council is who makes the decision ultimately." Mr.
Whittenberg indicated that is correct.
Member Young continued, stating, "So our recommendations would hold a lot of
weight to them. They would to the Planning Commission too, but, I mean, it's not the
'-'" determining body." Mr. Whittenberg stated, "It's just that I don't want you to assume
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'-'
that if you don't do something by September 3f'\ that the Planning Commission is
going to consider it, because they may not be in a position to do that if they've already
made their decision." Member Young stated, "Okay, I would be willing to come back
on the 10th, a week before. If anyone else wants to." Member Goldberg indicated the
Commission is meeting on the third of September.
MOTION by Goldberg; SECOND by Fitzpatrick that the Committee make a decision
tonight.
MOTION CARRIED:
AYES:
NOES:
3-2
Goldberg, Fitzpatrick, and Willey
Young and Chairperson Johnston
Mr. Whittenberg stated, "The first set of resolutions begin on page 10 of your staff
report. The alternate resolution on page 13. Given the comments you've provided at
this point in time, I would think you might want to go to the resolution on page 13,
which says that the EIR itself, you feel, is adequate subject to certain changes being
made in it. And what I've heard at this point is that the changes that were discussed in
the mitigation measures would be included in this resolution as things that would need
to be corrected to consider the document adequate. The comments regarding the
information in Appendix E document would be carried along, into the Appendix F
'-' document if that same language appears in the Appendix E. In all cases I'm not sure
that's the case --- in some cases it is. And so I think that's my understanding of the
concern that I've heard expressed by one member of the Committee. And that may be
where you want to start to focus on. And then if there are additional issues that you
feel need to be added to that consideration of things that still need to be considered for
changes that's probably what you should focus on."
Member Goldberg
Member Goldberg stated, "One thing I'd like to see be added onto that would be the
photos. I agree with Barbara, if we can't get the original, is it a possibility that we
could have them taken again?" Mr. Whittenberg stated, "I understand the concern. At
this point, I think that's probably a more appropriate item to deal with as part of the
Research Design. That's my suggestion to you. Because again, having photographs
done at this point isn't going to change the conclusions that the City's already reached,
that each of those sites are signifIcant and each one of them is going to be impacted.
The importance of those photographs, in my mind, is to assist the actual fIeld
investigator when they're doing their test level investigations --- as to where to focus
those investigations. I don't think --- I think the appropriate place for that type of
concern is in the Research Design so that it's very clear that the City has a concern that
where those aerial photographs show an area of concern, that those areas be focused on
as part of the test level investigations."
'-r
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'-'
Member Willey
Member Willey said, "In looking at Appendix F, now that I've had an opportunity to do
so, certainly from page 160 to the middle of page 164, that is simply a reiteration of the
table I went over so very thoroughly. All of my comments, I feel that in order to even
begin to say I approve it, those changes would have to be made in that section of it. I do
note that in terms of level of significance after mitigation, it does say that the proposed
project will impact ten important archaeological sites. I am gratified to see that. I wish
there were a way that Appendix E could simply be dumped, it would make life much
simpler." Mr. Whittenberg stated, "If I might, just from the City's standpoint it's a
technical document that's used to prepare the rest of the information and it's really needed
as an administrative record for the City's protection." Member Willey responded, "I
recognize that, I just don't like it. "
'-"
Mr. Whittenberg
Mr. Whittenberg stated, "Maybe if I might then, what I would recommend to you us
that the Committee may wish to consider the adoption of Resolution 97-1a, which is on
page 13 of your staff report. On page 16 is an Exhibit A, which indicates the AAC
met on August 2~ to review the above-referenced portion of the FEIR. The following
is a summary of what we believe are the key inadequacies of this section of the EIR.
And in that section then we would go through and list the changes that are felt to be
appropriate to the mitigation measures and provide direction from the previous
discussion we've already had as to which areas of the Cultural Resources Section itself
should be considered for revision based on the comments of the Committee." Member
Willey said, "There is no question that we have a list of things, I don't know whether
the AAC agrees with my comments on those mitigation measures. Those certainly, I
feel, need to be in there. Obviously we need to vote whether you agree as well. I don't
know whether we're ready for a motion, I think we need to start listing the
inadequacies. "
Mr. Whittenberg
Mr. Whittenberg stated, "From my point, the inadequacies that you have listed as far
as the mitigation measures, we would go through those and list those in the document
here. I would then go back to the tape and list the inadequacies that you indicated in
your comments and that the other members have listed in their comments in this section
and forward that on to the Committee. "
Member Willey
Member Willey asked, "Would you have that done in time that we would review it and
see if there are any other additional ones that need to be put in there or not?" Mr.
Whittenberg said, "At this point I can only put in the ones you have stated on the
tape." Member Willey stated, "Well, that's what I'm saying --- but would we see that
to make sure you didn't happen to miss any?" Mr. Whittenberg said, "If you would ---
""" what I would suggest to you, we could have it in a draft form for you to consider on
08-27-97 Minutes.doc
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'-'
September 3 at 5:30 p.m. before the Planning Commission meeting that night."
Member Willey said, "I think we need to look at it. Unless we can fully formalize
everything right now. "
Member Goldberg
Member Goldberg stated, "Let me say something. The question I have is you that you
could get together with Lee and see if everything's in there, and if it isn't you could go
before the Planning Committee that night and add anything additional to it." Mr.
Whittenberg indicated, "Sure that's a possibility. The other thing we're going to
attempt to do before the Planning Commission meeting, if not, we will do a set of
minutes from this meeting for presentation to them that evening so they will have a
record of your discussion. We usually go into a fair amount of detail as to what the
discussion and concerns were. And we usually try to get particular concerns very exact
in the minutes. So that is also something that the Planning Commission would have by
that point in time. I can't guarantee we'll have them ready for September 3rd because
we only have tomorrow and Tuesday to get them done because of the holiday and the
work schedule.
In response to a question from the Committee, Mr. Whittenberg stated, "I'm not going
to guess what they're going to do. People always ask me what are you going to do or
what's EQCB --- yeah. Well, I don't know what they'll do. And it's really what you
'-" as a Committee have a comfort level. If you want --- we can pretty well have the
general comments drafted ftrst thing Tuesday morning, probably. Because I happen to
work Thursday and Friday both this week so I can have this part pretty much done by
Friday afternoon to where I can get it out to you over the weekend. Hopefully, if not,
it'd be Tuesday morning."
Member Willey
After discussion among the Committee, Member Willey said, "1 found the same section
in terms of the letter which .., if the concerns Exhibit A are addressed we consider it
adequate. It's such a hard thing because what CEQA requires this probably does meet
if these concerns are taken care of. And much as I, to some degree, hate to admit it,
simply because of the archaeological concerns that I naturally have. Because we're
being put into this framework of CEQA, if the concerns are addressed, essentially it
does. It does not necessarily make me feel warm and fuzzy that everything that we
want as archaeologists are going to happen. I can only hope that our detailed
discussions with KEA will resolve those. But obviously, we're going to end up going
to the next step, one or the other. And either we take some action and make sure that
our concerns are known before we get steamrollered --- I don't want this Committee to
end up being ineffective, saying that because we don't like everything about it we're
just not going to do anything. In that I think we would not fulfill the purpose for
which the City has appointed us. So, my recommendation is that we --- I make a
'-'" Motion that we approve Attachment lA as written, that we will recommend that the
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'-'
EIR is adequate as far as the Cultural Resources section is concerned, if the changes as
addressed on the tape by all of the individuals involved are listed. "
Mr. Whittenberg
Mr. Whittenberg said, "Let me clarify one point. When you say by all the individuals
involved is that as articulated by the members of the Committee? Okay. I just wanted
to make sure what the intent of that comment was."
MOTION by Willey; SECOND by Goldberg to recommend to the Environmental
Quality Control Board that the EIR Cultural Resources section is adequate subject to
the modifIcations that were discussed regarding the mitigation measures, and the
language in Appendix F that members of the Committee had a concern with the
language in Appendix E that might be carried over into that section.
MOTION CARRIED:
AYES:
NOES:
3-2
Goldberg, Fitzpatrick, and Willey
Young and Chairperson Johnston
Member Goldberg
After discussion among the Committee regarding reconsideration of the motion,
Member Goldberg said, "Let me ask a technical question. If we approve this on a vote
~ tonight and it comes back next Wednesday, does it get voted on again? I mean --- this
is getting to be too complicated. It think that if we vote and it's passed 3 -2, it has to
go now before the Planning Committee as we assume the things that we want changed
or suggested in changes will be there. And if members disagree with that, in a negative
or the positive, have a right to come to the Planning Committee and make another
statement." Mr. Whittenberg said, "I think that's a determination of the Committee.
What I would suggest to you --- you may want to have some more discussion on this.
If you, as a Committee, take an action to have another meeting to review it, the
resolution before it goes to the Planning Commission, whether it's Wednesday or
Tuesday, what your motion should be at this point is to instruct us to prepare the
resolution for your review based on the comments. If you feel though that you do not
want to have another meeting to look at the resolution before that meeting, then your
resolution should just be to approve it subject to us putting information in, forwarding
that to the Planning Commission, and then you as members of the Committee always
have a right to come down and address the Planning Commission and say they didn't
get it quite right, this is really what else should be in it. It's really a choice as to how
you as a Committee want to proceed. "
After further discussion among the Committee, Chairperson Johnston said, "We're a
democracy I see and the motion is passed." Mr. Whittenberg said, "That motion has
been approved on a 3-2 vote. The motion at this point that's been approved instructs
'-"' me to prepare a resolution for submission to the Planning Commission that includes all
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'-"
of the concerns as expressed by the Committee to this point in your meeting. Now if
there's a motion for reconsideration in that, we'd need a motion and a second to
reconsider. And that would need to be an approved motion before you can reconsider
it.
MOTION TO RECONSIDER
MOTION by Young; SECOND by Johnston to reconsider the previous motion of the
Committee.
MOTION FAILS:
AYES:
NOES:
2-3
Young and Chairperson Johnston
Goldberg, Fitzpatrick, and Willey
Mr. Whittenberg
Mr. Whittenberg stated, "We will try to distribute the Resolution, with the attachment,
Exhibit A, based on the discussion, to all the members of the Committee prior to the
Planning Commission meeting." Member Willey asked, "I understand that even if you
didn't actually get it out to us, if we come to the Planning Commission that resolution
will be there because it will be in their packets. Is that correct?" Mr. Whittenberg
stated, "It will probably be delivered to them that day." Member Willey inquired, "So
\w. we would still get it as long as we showed up before the meeting so we can double-
check it quickly?" Mr. Whittenberg said, "Yes, we'll have copies available for you."
Member Willey
Member Willey said, "The other thing, if I may, that I wanted to point out is, because
you voted "no" you will be in the NAY section. It's not as if --- oh yeah --- oh
absolutely. But it's not as if we're just not letting them know there was disagreement."
Mr. Whittenberg
Mr. Whittenberg stated, "If I might, you have one other resolution to consider. The
resolution you took an action on is actually a resolution that goes to the EQCB
regarding the adequacy of the Cultural Resources section. You also have a resolution
and I think you would want to go to page 21 of the staff report. This is the actual
resolution to the Planning Commission that indicates whether or not you agree or
disagree with the mitigation measures. And again, Exhibit A would list those changes
to the mitigation measures that have been discussed by the Committee. And it would
be appropriate to have a Motion to approve that resolution with those corrections to the
mitigation measures. And then that resolution will be forwarded to the Planning
Commission. And this is the one that will actually go to the Planning Commission."
MOTION by Goldberg; SECOND by Fitzpatrick to approve Resolution No. 97-2,
'-'" subject to corrections to the mitigation measures as set forth by Member Willey.
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'-'
In response to a question of the Committee, Mr. Whittenberg stated, "It's different in
the fact that this will only deal with the mitigation measures. It won't deal with the
discussion in Appendices E and F and what should or shouldn't be in that part of it.
Because this is only for mitigation measures only. In the EIR - and the changes that
have been discussed by the Committee this evening. And the changes. Those will be
indicated in Exhibit A. "
Chairperson Johnston asked for the vote, indicating the motion passed 3 -2.
MOTION CARRIED:
3-2
AYES:
NOES:
Goldberg, Fitzpatrick, and Willey
Young and Chairperson Johnston
Mr. Whittenberg
Mr. Whittenberg stated, "Thank you very much. I appreciate your struggling. I know
it's not been an easy process for the Committee to go through. Your next item on your
agenda is Committee Concerns. "
'-' COMMITTEE CONCERNS - None
STAFF CONCERNS
Mr. Whittenberg
Mr. Whittenberg stated, "The regular meeting is not until October 8th --- I think the 8th
is the date. As you discussed at your last meeting regarding the Research Design, the
public comment period on the Research Design ends September I 8t. We're suggesting
that you may want to schedule a meeting for September 10th to review the Final
Research Design. That will be the revised document based on the comments received
during the public comment period, prior it going to the Council on September 22nd. I
would indicate to you at this point that's a date that's tentative, assuming that we have
everything done by that date. But we would suggest that you continue this meeting to
that date to consider the Final Research Design." Member Goldberg suggested meeting
on September 17th. Mr. Whittenberg indicated, "That's perfectly fme. It gives us
more time in case we're not done by that point in time. But we would anticipate being
done by then. "
'-'
After discussion among the Committee, Mr. Whittenberg indicated there would need to
be a motion to continue this meeting to September 17 at 5:30 p.m. to consider the Final
Research Design on the Hellman Ranch project.
08-27-97 Minutes.doc
31
Archaeological Advisory Committee
Adjourned Meeting Minutes
August 27, 1997
'-'
MOTION by Goldberg; SECOND by Willey to continue this meeting to September 17,
1997 at 5:30 p.m. to consider the Final Research Design on the Hellman Ranch
project.
MOTION CARRIED:
5-0
AYES:
NOES:
Goldberg, Fitzpatrick, Willey, Young, and Chairperson Johnston
None
Mr. Whittenberg
Mr. Whittenberg stated, "I have one other document that was just given you at your
desk this evening. It's a document we received from the Navy regarding IR site 1. In
accordance with your directives to us from a number of meetings ago, we're providing
the document to you at this time for your review. It will be on your regular agenda for
October for consideration at that point. There's no time limits indicated in the
document one way or the other so we're assuming none. If there's a change that we
become aware of we would do something to make you aware of that and try to schedule
a special meeting. "
ADJOURNMENT
'-'
There being no objections, Chairperson Johnston adjourned the meeting at 7:37 p.m.
~
Archaeological Advisory Committee
~k~
~hittenberg. Secretary ~
Archaeological Advisory Committee
Note: These Minutes are tentative until approved by the Archaeological Advisory
Committee.
The Archaeological Advisory Committee Minutes of August 27, 1997 were approved on
OC-ThS~ 8 ,1997.
'-"
08-27-97 Minutes.doc
32
To: The City of Seal Beach
From: Moira Hahn
'-' Date: August 26,1997
Subject: Initial Comments and Questions about the Final Environmental Impact
Report (FEIR) for the Hellman Ranch Specific Plan
I hereby object to approval of the project in it's present form. The following
comments and all references contained therein are hereby incorporated
into the official record of proceedings of this project and it's successors.
(PRC 21177(b).)
I have not had time to prepare a full listing of the inadequacies of this FEIR. I
intend to submit further comments to the City prior to the close of the review
period for the FEIR.
'-'
1. Many local Native Americans and archaeologists believe that the
archaeological sites on the Hellman Ranch project site are part of the Puvungna
Village complex, a unique group of sites that has tremendous cultural and
religious significance in Native American cultural history. Puvungna is believed
to have been the birth place of Wiyot and his descendant Chinigchinich, figures
revered as Gods by many California and other Great Basin Indian tribes.
Puvungna should therefore be considered analogous to Jerusalem in the latter
city's importance to Christian and Jewish believers. The Hellman
archaeological sites' relationship to Puvungna has not been explored in
the FEIR or in the Research Design.
2. The ethnographic component is missing. Although a contact letter has
been sent to some Native Americans to tell them about the project, both the FEIR
and the Research Design describe an "ethnographic component" that will
somehow bring the Indians into the process, However, neither the FEIR nor the
Research Design specifies how, when, where, or by whom local Native
Americans will be interviewed to permit them to contribute expertise and
knowledge to the development of a testing program.
It is not clear whether any Indians will be interviewed, the time frame during
which the ethnographic intake part of the process will take place, whose
knowledge will be sought, how that determination will be made, or how
information that may be received will be incorporated into the planning of the
investigation,
Mr. Jamie Cleland of KEA stated at the SBAAC meeting on August 13 that the
ethnographic study will not be in the Research Design because it will be
conducted after that document has been approved, during the testing program,
This is a backwards approach. The Native Americans have indicated they want to
be involved from the beginning of the process. They can't contribute to the
~ development of a testing program that they will not be invited to participate
in until it has been approved by the City and is already underway,
~
Furthermore, the California Coastal Commission stated in it's May 27, 1997
letter to the City (included in the FEIR) that the City must ensure "that the
appropriate Native American groups have been consulted in the
development of the investigation".
3. The FEIR contains a multitude of false and misleading statements that lead
readers to form false conclusions regarding Historic Resources known to have
been discovered at the sites, Key examples that contradict the documented facts
on record with the Planning Department at Seal Beach City Hall and with the
State's regional archive at UCLA include a denial that numerous human burials
have been found on the project site, and a denial that the project site was ever
used as a religious or ceremonial area.
4. Artifact diversity data in the FEIR is still incomplete, which SRS states is
sufficient because it is not required to provide every detail and artifact; yet the
FEIR relies on these incomplete artifact diversity inventories and descriptions to
make determinations concerning the archaeological sites' values, Thus the City
is basing it's scientific conclusions on an incomplete data base. Much of the
data left out of the FEIR concerns ceremonial artifacts and materials and burials
found there by previous investigators,
~
5. The FEIR does not consider the sites directly across the street that were
contiguous before Seal Beach Blvd. existed, yet they are, by all professional
accounts, continuations of the same sites on the property. If the facts are
examined within this context, the FEIR's conclusions of occupational
chronology and site usage/diversity/"value" for the archaeological sites on
the project site are inaccurate.
6. SRS, the firm that drafted the Historic Resources chapter of the FEIR, has
deferred answering most questions regarding the archaeological sites, because
(SRS states in the FEIR) KEA will be doing the field investigation to determine
those facts. CEQA and numerous recent court decisions forbid this practice.
It is putting the cart before the horse, The facts regarding Historic Resources
present on the development site must be disclosed in the EIR before the City
can consider it. The EIR can not be finalized until KEA's field investigation
has been completed, and the facts about Historic Resources remaining on
the project site are fully disclosed and understood.
7. SRS and KEA have obfuscated important issues, both in the FEIR and in the
Research Design, concerning reported ancient human burials discovered on the
project site, The firms have accomplished this by renaming state registered
archaeological sites, moving sites off the project site, claiming sites are mapped
elsewhere on the property than what is shown in the latest State Registered site
survey forms; and, at least in the FEIR, 'confusing' the documented facts about
'-' the burials found there.
?
Examples include SRS' 'confusion' regarding the metacarpal from CA-Ora-852,
Chief Stearns' comments regarding the presence of human remains as reported
"-" by Archaeological Associates (AA) in it's 1980 survey (FEIR incorrectly denies the
passage in AA's report exists), the 1990 Coroner's report that the FEIR implies
the City and SRS still haven't seen (even though the report is actually in the '
FEIR, because I submitted it), and what appears to be a deliberate attempt to
confuse readers to the source of two separate ancient skulls, one identified as
Gabrielino and the other showing Paiute characteristics, found in different places
on the Hellman Ranch and in the river bed that forms a project border, 22 years
apart.
CA-Ora-262 has been renamed Area 0, for some reason, and that's where
previous archaeological investigators said "several aboriginal burials" were found
in the 1970's. The present investigation calls for only two units to be excavated
there; this is highly unlikely to provide an accurate assessment of potential
remaining burials.
The FEIR states that what had later been mistakenly mapped as CA-Ora-263 is
really Redwine's LH-9, or CA-Ora-264. This makes a difference, because one or
two burials Redwine discovered as well as a substantial portion of the
inventories of religious and ceremonial artifacts therefore are likely to have
been discovered on the project site, rather than to the north of it on ground that
was destroyed by development. From the 1970's until this year, previous
professional archaeological researchers believed that sites 264 and 265 had long
\..... since been destroyed. This point was not made in the FEIR.
8. There is an inadequate discussion in the FEIR and in the Research Design of
how Seal Beach resident Dr. Leonard Cutulli's Native American cemetery map of
the proposed project site, and Mr. Glenn Peaseley's testimony regarding two
burials and an artifact he found in site 852 (on the project site) will be
investigated. I couldn't find any discussion in either document.
9, The FEIR does not consider project alternatives that avoid the archaeological
sites. The developer only considered alternate configurations that would also
destroy the sites,
10. The 15-25' rings and ellipses apparent on computer enhancements of infrared
photographs taken last year of the proposed project site have not been
investigated. If these features can not be explained by post-contact activity, they
would be unique resources of great interest to the Native American, educational
and scientific communities.
'-"
1