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HomeMy WebLinkAboutCT 97-13; CARLSBAD OAKS NORTH; ARCHAEOLOGICAL MITIGATION PROGRAM REVISED PROPOSAL; 2003-12-10I • Brian F.-~mith &Associates Archaeological/Historical/Paleontological Consulting December 10, 2003 Ted Tchang Tech Construction Corporation 3575 Kenyon Street San Diego, California 92110 RECEIVED DEC 16 tfm Re: Carlsbad Oaks North/ Faraday A venue Archaeological Mitigation Program, Revised Proposal Dear Mr. Tchang: The archaeological mitigation program for Carlsbad Oaks North I Faraday A venue I Agua Hedionda Sewer Project will require various tasks to be completed as part of the conditions of approval. The basic elements of the archaeological mitigation program were presented in the technical report we prepared in 2002, as well as cultural resources sections presented in the project EIR. Basically, five significant prehistoric sites are present within the areas to be impacted by the development (Faraday A venue extension, Agua Hedionda sewer construction, or the grading of the lots for Carlsbad Oaks North). The five significant sites are all located within the corridor for Faraday Avenue Extension, and the construction of this road will be the primary source of the adverse impacts to significant cultural resources. Because the potential impacts are significant, measures are needed of mitigate the impacts to a level below significant. These measures include the recovery of a sufficient level of information and artifacts to exhaust the research potential of the sites and permit the grading of the sites. The mitigation program will fall into three main elements: (1) preparation of a research design to be submitted to and approved by the City of Carlsbad; (2) data recovery programs for significant sites to be impacted by development; and (3) monitoring of grading for archaeology and paleontology. The following proposal will include a scope of work and budget for all three elements of the mitigation program, which are summarized below. For this revised proposal, I have changed the sampling design to utilize fewer test units for the initial indexing of the important sites and more units for the focused excavations in the areas of greatest importance. The net consequence of this revision is still the mitigation of impacts; however, this will be accomplished with fewer test units overall but a higher number of units in the central portions of the sites. The foundation for any data recovery is to exhaust the research potential of the site, and the design focused more on the central elements of the sites rather than the indexing of the outer areas of the site will accomplish the goal of exhausting the research potential of the sites. This revision of the design and plan will result in the reduction of the cost of mitigation field work by nearly 30%. • Mitigation Program: (1) Preparation of the Research Design: Prior to the initiation of any field investigations, a research design document must be presented to the City of Carlsbad which outlines the mitigation program to be used to reduce the significant impacts. This research design will list the research questions that will be pursued during the study, the level of effort required to achieve the mitigation levels required by the City, the methods to be employed to recover the targeted samples, and the types of analyses to be used to enhance the interpretation of the sites. 14010 Poway Road, Suite A, Poway, California 92064; Phone (858) 484-0915 or (909) 681-9950; Fax (858)679-9896; www.bfsa-ca.com Business Office: 14678 Ibex Court, San Diego, California 92129 Page 2 -Brian F. Smith and Associates (2) Data Recovery Program: The archaeological evaluation program completed for the project EIR identified five cultural resources that are important and will be directly impacted by the grading of the development. Two other significant sites were located off-site on the proposed conidor of the gravity sewer alignment for Agua Hedionda Sewer, but this alignment was not selected for the project. The sites included in the mitigation program include: ( 1) SDI-2776 (3) SDI-16,048 (5) SDI-16.054 (2) SDI-5231 (4) SDl-16,049 To mitigate the potential impacts, measures have been proposed to exhaust the research potential of these resources through the implementation of a data recovery program. The data recovery process has been described in the Cultural Resources Management Plan presented in the archaeological evaluation report (Tuma and Smith 2002). The data recovery program will focus upon the recovery of a statistical sample of each important resource to be impacted. Samples will be comprised of a series of standard archaeological test units and block excavations. Each site to be investigated has a specified level of sampling that must conform to the City's Archaeological Guidelines to qualify for the data recovery effort. This level of sampling must be completed prior to the grading of the individual sites. All artifacts gathered from the data recovery excavations must be subjected to standard laboratory analysis and cataloging processing. More specific descriptions of the data recovery program are provided in the following pages. (3) Archaeological and Paleontological Monitoring of Grading: Grading of the proposed development must be monitored to detect any archaeological or paleontological deposits that might be uncovered. BFSA has the unique asset of having experts in both archaeology and paleontology in-house, and has monitors who are qualified to conduct archaeological and paleontological monitoring simultaneously. One monitor to cover both disciplines will obviously same money during the monitoring process. During monitoring, any cultural resources (either archaeological or paleontological) that are uncovered and which have not been previously identified must be subjected to a brief recording and evaluation program. If such deposits are determined to be significant, emergency mitigation may be required. A more detailed discussion of the mjtigation monitoring program is provided below. The most significant element of the mitigation process is the data recovery program. The scope of work for the data recovery program is provided below by site, and is based on the data recovery plan presented in the archaeology technical report included in the EIR. Scope of Work -Data Recovery Program Data Recovery Program In accordance with CEQA (Section 15064.5) and the guidelines of the City of Carlsbad, the sites that have been evaluated as important which will be adversely impacted by the proposed project will require mitigation measures in the form of avoidance and/or data recovery programs to reduce the significance of potential impacts. In order to reduce impacts to a level below significant, data recovery programs will be necessary at those sites that are important and wil! be impacted. The data recovery program must include adequate subsurface samples of the significant deposits. Special studies, including radiocarbon dating, faunal analysis, obsidian hydration and sourcing, and flake attribute analysis, shall be conducted to exhaust the research potential of the site areas to be impacted. The recovered materials should be treated according to standard archaeological procedures--each specimen should be cleaned, cataloged, and analyzed, and a technical report will be prepared in accordance with professional archaeological standards and guideline requirements. Page 3 -Brian F. Smith and Associates Methodology A plan for a program to carry out the necessary data recovery procedures is presented below. The program is consistent with the policies and guidelines of the City of Carlsbad and with the Advisory · Council on Historic Preservations's Ideal Data Recovery Program. In order to mitigate potential impacts to the sites in accordance with CEQA, and also to retrieve the data needed to comply with City guidelines, a sample of the site areas to be impacted (i.e., the limits of impacts) will be required. The governing parameters to be used to determine the level of the sampling will be the redundancy of the recovered artifacts and the research potential of the site. Field Methods The data recovery program will focus upon the excavation of test units measuring one meter square to a minimum depth of 50 centimeters. If cultural materials are present beyond this depth, the excavation shal1 continue until one sterile level is exposed. The units will be excavated in controlled, ten-centimeter levels. All removed soils will be sifted through 1/8-inch mesh hardware cloth. If a source of water is available near the areas of excavation, all soils from test units will be transported to a wet screen staging area where soils will be hydroscreened. This method is considered a superior method to separate artifacts and ecofacts from the soil matrix and to maximize recovery. All artifacts recovered during the screening process shall be properly labeled with provenience information in the field, and subsequently subjected to standard laboratory procedures of washing (if appropriate) and cataloging. The excavation of the units will be documented with field notes, illustrations, and photographs. At the conclusion of the test unit excavations, backhoe trenches may be excavated to investigate the site(s) further and search for any unusual features or artifact concentrations. When a backhoe is used, the methodology to be followed shall include: • All trenches must be excavated under the supervision of the project archaeologist. • All trenches must be mapped, measured, photographed, and sketched. • Periodic screening of the excavated material from the trenches will be conducted. • Provenience data for all screened soil shall be recorded. Based on data from the backhoe trenches, the data recovery program could be expanded to focus upon features or unique deposits that differ from the materials already studied. Any features which are discovered during the archaeological excavations shall be exposed through careful hand-excavation. Additional test units may be needed to fully expose the features, which wiH then be recorded by sketching and photography. Any datable materials found in association with discovered features shall be collected for radiocarbon dating. If obvious datable samples cannot be found at the sites in the data recovery program, then several bulk soil samples may be collected and processed in an attempt to date the deposits. At each site, column samples will be taken to permit microanalysis of midden contents. The columns will measure ten centimeters square, and will conform to the walls of selected completed test units to the bottom of the deposit. All of the soi] from the column will be collected, and not screened in the field. The samples will be returned to the laboratory for analysis. In addition, during hand excavation, special attention will be given to the identification of lithic tools found in situ and their potential for residue analysis. When possible, such tools will be bagged separately, thereby excluding them from the wet- screening process. A sample of the surrounding soil wil1 be collected to serve as a control sample, should the artifact be chosen for pollen, phytolith, and blood residue analyses. Page 4 -Brian F. Smith and Associates The scope of work for the individual sites in the data recovery program is described below for each site. Included in this description is the listing of the number of test units to be utilized to achieve the sampling levels required by the City of Carlsbad. . ( 1) Site 2776 This site is a large prehistoric seasonal camp situated on a terrace near the main drainage on the project. The site is affiliated with the late prehistoric Luiseno Indians, based on artifacts recovered from the site. The archaeological site measures 210 feet by 435 feet, with cultural materials recovered from depths of 90 centimeters. The overall archaeological deposit measures 3,783 square meters. The sampling program for the site will focus on a uniform indexing of the significant areas of the site. • Moderate Significance Rating for SDI-2776 • Size of Significant Subsurface Deposit -3,783 square meters • Phase 1 -.1 % sample of 38 test units • Phase 2 -10% sample of 40 test units in the area stratified as high potential based on the results of the Phase I test results, although this total will vary depending on the stratification of the subsurface deposit into areas of greater research potential. • A third phase of mitigation sampling is likely at SDI-2776, as this site is considered a candidate for intense artifact deposits or substantial subsurface features. A final sample sized of 10% of the area of greatest potential or features is recommended, with a total of 20 test units allotted for the focused recovery effort. • Total proposed sample size for data recovery -98 square meters, representing approximately 6% of the areas of greatest research potential and an overall site sample of 2.5%. (2) SDl-5231 This site is a widely dispersed prehistoric camp located on two knolls and an intervening swale in the southwestern portion of the project. A total of 843 artifacts were recovered from the site, in addition to the ecofacts and charcoal. The site encompasses an area of 800 feet by 260 feet, with a subsurface deposit measuring 580 feet by 280 feet and reaching a depth reaching 40 centimeters. Artifacts recovered indicate a late prehistoric occupation. The area of the subsurface deposit is approximately 15,045 square meters. For the mitigation program, the sampling program for the site will focus on a uniform indexing of the significant areas of the site. • Moderate Significance Rating for SDI-5231. • Size of Significant Subsurface Deposit -12,075 square meters. • Phase 1 -.5% sample of 72 test units. • Phase 2-4% sample of 40 test units, although this total wil1 vary depending on the stratification of the subsurface deposit into areas of greater research potential. • Total proposed sample size for data recovery -112 square meters, representing approximately 2.5% of the areas of greatest research potential. • A third phase of mitigation sampling is not likely at SDI-5231, as this site is not considered a candidate for intense artifact deposits or substantial subsurface features. ( 3) SDI-16.048 This site is a large prehistoric seasonal camp that is tentatively projected as representative of the Page 5 -Brian F. Smith and Associates Late Prehistoric Period. The site measures 435 feet by 175 feet, and is characterized by a dispersed scatter of artifacts with some examples of fire-affected rocks. The subsurface expression at the site included evidence of deposits covering an area of 525 feet by 180 feet, reaching depths of 60 to 100 centimeters. The subsurface deposit covers an area of 7,797 square meters. Within the deposit, the testing program identified three areas of concentrated cultural materials that will likely yield a wide variety of artifacts. • Moderate Significance Rating for SDI-16,048. • Size of Significant Subsurface Deposit-7,797 square meters. • Phase 1 -.5% sample of 40 test units. • Phase 2 -5% sample of 44 test units, although this total will vary depending on the stratification of the subsurface deposit into areas of greater research potential. • A third phase of mitigation sampling is likely at SDI-16,048, as this site is considered a candidate for intense artifact deposits or substantial subsurface features. The third phase of work will include 20 test units to recover materials from areas of concentrated deposition or features. • Total proposed sample size for data recovery -104 square meters, representing approximately 8% of the areas of greatest research potential and 1.3% of the overall archaeological deposit. (4) SDI-16.049 This site is a prehistoric camp with a sparse surface scatter of artifacts but a large subsurface deposit. The site contains an expansive, subsurface component that measures approximately 265 feet by 250 feet; however, many large bedrock outcrops are present which reduce the volume of the archaeological deposit. The area of the deposit is approximately 4,949 square meters, but the actual deposit is closer to 2,980 square meters when the bedrock outcrops are removed from the area calculation. The deposit of artifacts reaches depths of approximately 80 centimeters. The artifact recovery from the testing program was not extensive, but the variety of materials indicates a wide spectrum of activities took place at the seasonal camp. • Moderate Significance Rating for SDI-16,049 • Size of Significant Subsurface Deposit -2,980 square meters • Phase 1 -1 % sample of 25 test units • Phase 2 -10% sample of 32 test units, although this total will vary depending on the stratification of the subsurface deposit into areas of greater research potential. • Total proposed sample size for data recovery -58 square meters, representing approximately 7% of the areas of greatest research potential and 2.1 % of the total deposit. • A third phase of mitigation sampling is not likely at SDI-16,049, as this site is not considered a candidate for intense artifact deposits or substantial subsurface features. (5) SDJ-16.054 This site is a large Late Prehistoric camp situated on ridge overlooking the main drainage through the project. The site consists of numerous features dispersed over a wide area represented by knolls with extensive bedrock boulders and outcrops. The site includes scattered surface artifacts and features and subsurface deposits that encompass an area of approximately 375 feet by 158 feet, with a subsurface deposit of 100 feet by 83 feet The subsurface deposit achieved a depth of Page 6 -Brian F. Smith and Associates 80 centimeters. Like SDI-16,049, this site has a moderate quantity of artifacts in the recovery collection, but a wide variety of artifact types • • Moderate Significance Rating for SDI-16,054 • Size of Significant Subsurface Deposit -750 square meters • Phase 1 -1.5% sample of 11 test units • Phase 2 -5% sample of 10 test units, although this total will vary depending on the stratification of the subsurface deposit into areas of greater research potential. • Total proposed sample size for data recovery -21 square meters, representing approximately 3.0% of the areas of greatest research potential. • A third phase of mitigation sampling is not likely at SDI-16,054 , as this site is not considered a candidate for intense artifact deposits or substantial subsurface features. Laboratory Analysis All of the materials recovered from the field excavations will be subjected to standard laboratory analysis. Artifacts may be washed, if necessary, to permit proper identification. The artifacts will be sorted and cataloged, including counts, materials, condition, weight, provenience, and unique artifact identification numbers. The lithic artifacts recovered from the project will be subjected to analysis which will include recordation of critical measurements and weight, and inspection for evidence of use wear, retouch, patination or stains. The recovered flakes (or a representative sample) will be subjected to an analysis of attributes such as size, condition, type, termination, and material. The attribute analysis will include the flake collections recovered during the testing program. Non-lithic materials, such as ecofacts (shell and bone), shall be subjected to specialized analyses. The shell will be cataloged by species and weight of recovery per level. The bone material will be weighed and subsequently submitted for specialized faunal analysis. The laboratory analysis of the column samples will include flotation procedures to remove seeds and other microfaunal remains from the soil, followed by the screening of the remainder through a 1/16-inch mesh sieve. The recovered materials, such as fish bone or seeds, will be sorted and subjected to further analysis. Other specialized studies which will be conducted if the appropriate materials are encountered during the data recovery program will include marine shell species identification, faunal analysis, otolith analysis (for seasonality), oxygen isotopic analysis (also for seasonality), radiocarbon dating, obsidian sourcing and hydration, and blood residue and phytolith studies. These specialized studies are briefly described below: (a) Shell Analysis (b) The recovery of shell is likely at sites within the project. Analysis of the shell would include the speciation of all shell fragments collected. The shell will be recorded by weight, and will include a count of hinges to determine the minimum number of individuals represented by the recovery. Fauna] Analysis Prehistoric food bone has been documented at most of the sites within the project Any bone material recovered during the data recovery program should be analyzed by a faunal expert to identify species, types, age, and evidence of burning or butchering. The prehistoric bone recovery will provide information concerning diet, activity areas within the sites, the habitats exploited, and methods of processing. Page 7 -Brian F, Smith and Associates ( c) Radiocarbon Dating This dating technique will be attempted at all of the sites to be included in the data recovery program. The radiocarbon dating will be useful in conjunction with the stratigraphic recovery of cultural materials to establish the chronology of the sites. Therefore, the collection of samples for dating should be based on the presence of diagnostic artifacts, features, or geological strata delineations. In conjunction with the research topics, any possible opportunities to delineate parts of sites into Late Prehistoric and Archaic periods will be advanced through the use of dating. (d) Blood Residue Studies Organic residue on lithic artifacts may be useful in the determination of the species of animals represented by the residue. However, the use of blood residue studies is necessarily dependent upon the identification of such residues on artifacts. The detection of blood residue must be made prior to any washing of artifacts, or the residue samples will be lost. (e) Isotopic Profiles The analysis of Oxygen-18 isotopic profiles from shells may be used to determine the season during which the shells were collected. This process measures the ratio of isotopes of oxygen, which is determined by water temperature. A minimum of five shells shall be used in this analysis, particularly if no other means of determining seasonality can be utilized. (f) Obsidian Hydration and Sourcing Any recovered obsidian artifacts will be submitted to a specialist to determine the source of the Jithic material. The obsidian shall also be analyzed to produce hydration readings, which may then be used to provide relative dates for the use of the artifacts. (g) Po11en and Phytolith Residue Analysis The research objectives of this program are focused upon the cultural differences of the subsistence patterns of the Luisefio Indians and the La Jolla Complex. The analysis of organic residue on tools such as manos and scrapers could hold the key to discerning the focus of each culture's subsistence pattern. Every attempt should be made to conduct this type of analysis on materials from the sites in the data recovery program. Curation All of the prehistoric cultural materials recovered from the project, including those from the testing program, shall be eventually returned to the Luiseno Indian representatives (San Luis Rey Band) under an agreement with the project ownership and the Native American representatives. Native American Consultation Local Native American representatives shall be contacted and included as part of the mitigation program. Native American monitoring will be required at all times that archaeological excavations are underway. A pre-excavation agreement should be made with the local Native American representatives. This agreement will describe the procedures to be invoked in the event any human remains are encountered or items of sacred or religious significance are discovered. Provisions-for the Discovery of Human Remains The possibility exists that human remains may be discovered during the data recovery programs, although no human bone material was identified during the testing program. In the event that human burials are encountered, standard procedures for such discoveries will be implemented, including notification of the San Diego County Coroner's Office, the City of Carlsbad, and the Native American Heritage Commission in Sacramento, and Luiseno representatives. Field work will be discontinued in the area of any such discovery. The Native American representative and the City of Carlsbad will be consulted to determine a preferred course of action, and the burial will be treated accordingly. Page 8 -Brian F. Smith and Associates Fee Proposal for Mitigation Program The mitigation of adverse impacts to cultural resources will be achieved through the implementation of a data recovery program. Data recovery will be conducted by excavating standard one-meter-square test units to recover sufficient levels of cultural materials to compensate for the destruction of archaeological sites within the development area. The calculation of a budget for the data recovery process will be based on a unit cost per test unit. The number of test units for each site has been represented in the EIR as attributable to the requirements listed in the City of Carlsbad's archaeological guidelines for data recovery programs. The actual number of test units excavated during the data recovery program is somewhat dependent on the levels of recovery, as the number of units could be reduced if the area of the subsurface deposits is smaller than estimated, or increased in the areas expand or the intensity of the deposit increases substantially. For this budget projection, the number of test units stipulated in the City's guidelines for data recovery for each of the sites to be impacted will be used for the unit price extension. A total of 392 test units will be needed for the data recovery program at Sites (1) SDI-2776, (2) SDI- 5231, (3) SDI-16,048, (4) SDI-16,049, and (5) SDI-16,054. Using a unit fee of $500.00 per test unit typically covers the labor needed to hand excavate a standard test unit, screen the soil and recover any Rate .Jot~.• .. C<>~t •·········· $J,?9.Q.()Q (2) I)at.i Recovery Prograil1 Constrt1~t Wet§c:r~t!n Qpt!ratie>11. • • • ........ $,5,QQ.9.()Q Fiel<i'vVCl!~... ••••.•.•.• .. •.•.••. j92_i;~i.0~itd, $~QO.OQ/~~it{ . $J96,0QQ.()O_ . ........ .. Fi(!\d\V()f!{~.13,1~kJ:i()e. ~t!I1~hi11g... : ......... $?,99.9-09. .......... L.?~()f<1t()ry A11.il y~is~ .Ge.11erc1L S. pt!cia\. :L.,c1l:>qr.i~()!Y $tll<i.it!s . . .. .. . . . . . F'repc1ra.ti on.. 9f <;9I le.c:tiq11~ for. <;µrati9n ..•.... ............ Qraphi~s(Si~t! ;M:<1ps, Illll~~ratio:ris.) .... R.esearc:t. . . . . )._{ep9rt }Jrt!pll!ati.C>t:J .. · ..... M iscell i111~9us C::~iirge.s. (C::opy, 111i lt!age,. 111c1te.ri.ils.) ... .... Natiye /\yne~ican fy1q11i~o.rin.g_ .. (3) Mi.tigatio11.MonitC>ring Pr9gram_ Archaeological MClnitoring .... Pa.leont9logical.M9nito.~i11g . pual Arch/Paleo M()nito~ing TBD TBD TBD *TBD -To Be Detennined TBD* ·························-··················--········ . • ..... ... ... H9,99.0-9Q . . ....... $5,()()()_()() ............. •-········· .. $6,QQ.().()O . ......... $:3,,SQO.QQ. $8,500.00 ······-:·•-···-··-······-·--·-················· ...... •.... $3,()00.Q() $4~.()0/hqur • • $~5,00!hOllf TBD IBD IBD Page 9-Brian F. Smith and Associates artifacts present, bag and label all artifacts by provenience, and send the recovery to the laboratory for cataloging. While the budget will be estimated in Table 1, the actual invoicing will be based on hourly rates listed in Table 2. Use of hourly rates in a time and material billing process will keep charges in line with actual time spent on the project. For this proposal, the laboratory analysis for artifacts recovered from the field excavations has not been factored into the budget, as the quantity of materials that may be recovered is unknown. Once the field work is completed, a subsequent budget entry will be presented that will cover the analysis of the recovered artifacts. Entries for some of the other laboratory work has been included based on the types of special analyses typically used for projects of this scope. Radiocarbon dating, residue analysis, and obsidian hydration dating have been given a budget based upon projects of similar size and scope. An entry has also been included for the archaeological and paleontological monitoring of grading. The rates listed for the monitoring include an archaeologist or paleontologist, or a dual monitor who is guahfied as both an archaeological and paleontological monitor. Wherever possible, a dual monitor will be used to save costs where otherwise two individuals would be needed. Any meetings or public hearings which require my attendance will be billed on an hourly basis, at a rate of $90.00 per hour, in addition to the budget total listed in Table 1. Mileage will be charged at a rate of $0.40 per mile. Any materials needed to expedite or complete the field work process will be included in our billing at cost. Invoices will be submitted monthly based on the hours worked and billed according to the rates listed in Table 2. PAYMENT TERMS: Bills shall be rendered complete by the 10th of each month, to be paid by the 10th of the following month. Schedule Table 2 General Schedule of Hourly Rates Individual/Position Archaeological Consultant Principal Archaeologist Field Supervisor Historian Archaeologist -Field Archaeologist -Level 1 Archaeologist -Field Archaeologist -Level 2 Archaeologist -Laboratory Supervisor . Archaeologist -Laboratory Assistant Graphics Word Processing/Data Entry Base Hourly Rates $90.00 $65.00 $50.00 $50.00 $28.00 $35.00 $45.00 $28.00 $35.00 $28.00 The field investig~tions must be completed prior to the grading of sites. However, the City will typically accept a letter clearing certain sites for grading before all sites are finished and prior to the completion of the laboratory analysis, if the consulting archaeologist will verify that the field excavations are complete and complied with the mitigation requirements. Because of the length of time that will be necessary to complete the archaeological excavations, sites will be prioritized to coincide with the grading process. As the mitigation process at each site is completed, the Ci!Y of Carlsbad will b~ not~fied b~ letter to reiease the sites for grading. It is anticipated that the excavation of all 393 test umts w1l1 reqmre four to five months to complete, depending upon the size of ~he field crew. We can adjust the length of t~e s~hedule to meet the needs of the grading program by addmg crew members to the field team. If gradmg 1s • Page JO-Brian F. Smith and Associates planned for any time in the next few months, the archaeological mitigation program should begin as soon as possible in order to clear the areas targeted first for grading. * * * * The base budget for the archaeological mitigation program is $244,000.00, with the laboratory analysis still to be added to the project costs, as well as Native American monitoring of the archaeological excavations, and archaeological and paleontological monitoring during grading. The possibility exists that the City may review our research design and perhaps have a third-party review to determine the adequacy of the mitigation proposal, and subsequently request hat he sample sizes be increased to recovery a larger sample of the sites. Any changes to the program required by the City may affect the cost and scope of the recovery effort. The potential exists that features, deposits, or even human burials may be encountered that will require an expansion of the data recovery effort, which may in tum affect the budget. Should any circumstances arise that will affect the budget for this program, you will be notified immediately. During our efforts, representatives from San Luis Rey Band will be present to monitor our work. Any charges that may be generated by the Native American monitors will be reimbursable. We are prepared to begin the data recovery process at any time. We will require access to water on the property to conduct wet screening and artifact washing, and the first task of the mitigation program will involve the construction of a wet screen platform to process all of the excavated soils. If you have any questions about the scope or budget estimate for the data recovery program, please contact me. If you wish to proceed, please let me know what contract format you would like to use, or sign and return a copy of this document to initiate the program. -, Authorized by: Date: