Plan Half Moon Bay
Plan Half Moon Bay
Cultural Resources Local Coastal Land Use Plan August 2017 Planning Commission Working Draft
www.planhmb.org
Plan Half Moon Bay Cultural Resources Local Coastal Land Use Plan
August 2017 Planning Commission Working Draft
Prepared by City of Half Moon Bay
Table of Contents Foreword ........................................................................................................... .................... i Coastal Act Framework .......................................................................................................1 Coastal Act Policy ...………………………......................................................................1 Federal and State Regulations ……......................................................................................1 Historic Context ……………….…….....................................................................................3 Archaeological and Historic Resources ..............................................................................5 Archaeological Resources...........................................................................................5 Historic Resources ……………………………..............................................................6 Land Use Plan Framework ……..…………………......................................................9 Cultural Resources Policies ……………………….......................................................9
Foreword This First Public Draft Local Coastal Land Use Plan was published in April 2016 for General Plan Advisory Committee (GPAC) and community input. This document - the August 2017 Planning Commission Working Draft Cultural Resources chapter of the Local Coastal Land Use Plan - is an update to the April 2016 version. In the April 2016 draft, Cultural Resources was a section in the Coastal Resources chapter. Cultural Resources has been made into a stand-alone chapter for the new draft. Input from the GPAC and community members has been incorporated into the August 2017 revision for oversight by the Planning Commission. The following is provided as a readers’ guide to the August 2017 revision.
All but minor editorial revisions are indicated in strikethrough for deletions and underline for additions. The document is substantially reorganized as follows: o Relevant California Coastal Act policies are provided in full at the beginning of the document. o Policies, sections, figures, and tables are simply numbered. o Policies are not differentiated as they were in the first public draft document (e.g. guiding and implementing). o Some sections of the document have been re-ordered. “Shall” language in the policies and indicated in bold. The bold font will not be retained in any final document. Each policy is followed by a reference in blue indicating one or more of the following: o Applicable policy number in the first public draft (demarcated with “FPD”) document. Policy numbering is substantially different in this revision, thus this system will be maintained to provide continuity from one version to the next. o Indication if the policy is new to the August 2017 revision – “Planning Commission Working Draft new Policy” Notes to the Reader are not intended to be included in any final document. They are provided to give context about particular subjects and GPAC decisions. There is one figure brought forward from the April 2016 draft. It will be updated at a future time on GIS map layers for the final draft.
Planning Staff is happy to review the various conventions used in this draft with any interested reader. Contact us at 650-726-8270 to make an appointment. i
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Cultural Resources Half Moon Bay values its cultural resources which include a plentiful variety of historic resources, as well as a limited number of archaeological sites. Because archaeological sites are a nonrenewable resource, they need to be preserved for future generations and study over time. The historic sites serve important commercial, recreational, and educational roles in the community while evoking the city’s unique heritage. This chapter provides policies for protection and enhancement of Half Moon Bay’s cultural resources.
Coastal Act Framework The California Coastal Act provides extensive policies concerning the protection, use, and experience of the natural coastal environment. This section summarizes Coastal Act policies regarding coastal resource management.
CULTURAL RESOURCES Section 30244 of the Coastal Act requires mitigation for development that would adversely impact archaeological or paleontological resources, reinforcing other state laws to that effect. Coastal Act Policy 30244 Archaeological or paleontological resources Where development would adversely impact archaeological or paleontological resources as identified by the State Historic Preservation Officer, reasonable mitigation measures shall be required.
Federal and State Regulations National Historic Preservation Act Significant archaeological and built environment resources are protected by the National Historic Preservation Act (NHPA). The National Register is an inventory of the United States' historic resources and is maintained by the National Park Service. The inventory includes buildings, structures, objects, sites, districts, and archeological resources meeting the following criteria as specified in the Code of Federal Regulations:
Local Coastal Land Use Plan: Cultural Resources August 2017 Planning Commission Working Draft The quality of significance in American history, architecture, archaeology, engineering, and culture is present in districts, sites, buildings, structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling and association and that: (a) Are associated with events that have made a significant contribution to the broad patterns of our history; or (b) Are associated with the lives of persons significant in our past; or (c) Embody the distinctive characteristics of a type, period, or method of installation, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or, (d) Have yielded, or may be likely to yield, information important in prehistory or history. (36 Code of Federal Regulations 60.4) National Register resources may be rehabilitated pursuant to the Secretary of Interior’s Standards. California Environmental Quality Act The California Environmental Quality Act (CEQA) requires consideration of impacts on significant paleontological, historical, and archaeological resources. Significant impacts by projects on such resources are to be avoided or mitigated to less than significant levels. If the project may cause damage to a significant resource, the project may have a significant effect on the environment. Achieving CEQA compliance with regard to treatment of impacts to significant cultural resources requires that a mitigation plan be developed for the resource(s). Preservation in place is the preferred manner of mitigating impacts to archaeological resources. The CEQA guidelines require that any properties that can be expected to be directly or indirectly affected by a proposed project be evaluated for California Register of Historical Resources (CRHR) eligibility. The purpose of the register is to maintain listings of the state’s historical resources and to indicate what properties are to be protected, to the extent prudent and feasible, from material impairment and substantial adverse change. The term “historical resources” includes a resource listed in, or determined to be eligible for listing in, the CRHR, a resource included in a local register of historical resources, and any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant. The criteria for listing properties in the CRHR were expressly developed in accordance with previously established criteria developed for listing in the NRHP. A resource may be considered historically significant at the state level if it retains integrity and meets at least one of the following criteria:
(1) Is associated with events that have made a significant contribution to the broad patterns of California's history and cultural heritage; (2) Is associated with the lives of persons important in our past; (3) Embodies the distinctive characteristics of a type, period, region or method of installation, or represents the work of an important creative individual, or possesses high artistic values; or (4) Has yielded, or may be likely to yield, information important in prehistory or history. (Public Resources Code Section 5024.1(c)1–4) 2
Local Coastal Land Use Plan: Cultural Resources August 2017 Planning Commission Working Draft Under CEQA, if an archeological site is not a historical resource but meets the definition of a “unique archeological resource,” impacts to the resource should be avoided or fully mitigated. A unique archaeological resource is defined as follows:
An archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria: (1) Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information. (2) Has a special and particular quality such as being the oldest of its type or the best available example of its type. (3) Is directly associated with a scientifically recognized important prehistoric or historic event or person. (Public Resources Code, Section 21083.2) California Senate Bill 18 and Assembly Bill 52
State planning law requires cities and counties to consult with California Native American tribes during the local planning process for the purpose of protecting Traditional Tribal Cultural Places. Senate Bill (SB) 18 requires cities and counties to contact, and consult with California Native American tribes prior to amending or adopting any general plan or specific plan, or designating land as open space. For purposes of consultation with tribes, the NAHC maintains a list of California Native American Tribes with whom local governments must consult. Assembly Bill 52 furthers SB 18 and provides for consideration of tribal cultural values. Tribal cultural values may include a site feature, place, cultural landscape, sacred place or object. The cultural value must be either on or eligible for the CAHR; or treated as a tribal cultural value pursuant to the discretion of the city or county.
Historic Context The Planning Area is of high sensitivity for the presence of archaeological and built environment resources. The Half Moon Bay region has a long, documented prehistory and history. It was and is an important piece of the development of Central California and the protection and identification of its known and unknown cultural resources is of utmost importance for future planning needs. No paleontological resources of known significance have been identified in Half Moon Bay and they are extremely limited throughout the San Mateo County Coastal Zone. Ethnography The Planning Area is in a region historically occupied by the tribelets of the Costanoan linguistic group.1 Descendants of Costanoan speakers prefer to be called by the name of the tribelet from which they are descended. When their heritage is mixed or the specifics have been lost over generations, they prefer the use of a native term, Ohlone, rather than the European-imposed term 1
Levy, Richard 1978. Costanoan. In California, edited by R. F. Heizer, pp.485–495. Handbook of North American Indians, Vol. 8, William C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C.
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Local Coastal Land Use Plan: Cultural Resources August 2017 Planning Commission Working Draft Costanoan (“coastal dwellers”).2 The rich resources of the ocean, bays, valleys, and mountains in the region provided Ohlone-speaking peoples with food and all their material needs.3 The primary food staple was the acorn, supplemented by a great variety of animal and plant resources. Prehistory The Planning Area lies in what generally is described as the San Francisco Bay Region, which is one of eight arbitrary organizational divisions of the state.4 This archaeological region includes all of today’s San Mateo and Marin Counties, and western, northern, or southern portions of Alameda, Contra Costa, Napa, Santa Clara, Santa Cruz, Solano, and Sonoma Counties bordering the Bay Area.5 The prehistory of this region is divided into six periods: Early Holocene (Lower Archaic, cal 80003500 B.C), Early period (Middle Archaic, 3500 to 500 cal B.C.), Lower Middle period (Initial Upper Archaic, 500 cal B.C. to cal A.D. 430), Upper Middle period (Late Upper Archaic, cal A.D. 430 to 1050), Initial Late Period (Lower Emergent, cal A.D. 1050 to 1550), and Terminal Late Period (cal A.D. 1550 to 1776).6 History The Post-Contact history for the state of California generally is divided into three periods: the Spanish period (1769–1822), the Mexican period (1822–1848), and the American period (1848– present). Although there were brief visits by Spanish, Russian, and British explorers from 1529 to 1769, the beginning of Spanish settlement in California occurred in 1769 with a settlement at San Diego and the first of 21 missions (Mission San Diego de Alcalá) established from 1769 to 1823. Word of Mexican victory after a decade of revolt against the Spanish crown reached California in 1822, marking the beginning of the Mexican period. This period was marked by an extensive era of land grants, most of which were in the interior of the state, and by exploration by American fur trappers west of the Sierra Nevada Mountains. With the signing of the Treaty of Guadalupe Hidalgo in 1848, ending the Mexican-American War, California became a territory of the United States. The discovery of gold in 1848 at Sutter’s Mill near Sacramento and the resulting Gold Rush influenced the history of the state and the nation. The rush of tens of thousands of people to the goldfields also had a devastating impact on the lives of indigenous Californians, with the introduction and concentration of diseases, the loss of land and territory (including traditional hunting and gathering locales), violence, malnutrition, and starvation. Thousands of settlers and immigrants continued to pour into the state, particularly after the completion of the transcontinental railroad in 1869. The Miramontez family established Rancho San Benito on the southern bank of the arroyo in about 1841. They built an adobe residence in present-day Half Moon Bay, which was said to have 2
Margolin, Malcolm 1978. The Ohlone Way: Indian Life in the San Francisco-Monterey Bay Area. San Francisco: Heyday Books. 3 Levy, Richard 1978. Costanoan. In California, edited by R. F. Heizer, pp.485–495. Handbook of North American Indians, Vol. 8, William C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C. 491-492. 4 Moratto, Michael 1984. California Archaeology. New York: Academic Press. 5 Moratto, Michael 1984. California Archaeology. New York: Academic Press. 6 Milliken, Randall, Richard T. Fitzgerald, Mark G. Hylkema, Randy Groza, Tom Origer, David G. Bieling, Alan Leventhal, Randy S. Wiberg, Andrew Gottsfield, Donna Gillette, Viviana Bellifemine, Eric Strother, Robert Cartier, and David A. Fredrickson. 2007. Punctuated Culture Change in the San Francisco Bay Area. In California Prehistory: Colonization, Culture, and Complexity, edited by Terry L. Jones and Kathryn A. Klar, pp. 101, 114-118. Altamira Press, Lanham, Maryland.
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Local Coastal Land Use Plan: Cultural Resources August 2017 Planning Commission Working Draft remained standing into the 1900s (Hoover et al. 2000).7 The community was originally called San Benito and later “Spanishtown,” in part because of the influence of its founding Hispanic families. It was first platted in 1863. By the mid-late 1800s, stores, churches, and at least one saloon had been built (Hoover et al. 2000).8 The area was remote compared to other population centers; agriculture was the main source of local commerce. In the History of San Mateo County, California, Half Moon Bay was described as “one of the finest agricultural districts of [the] county, located upon what was formerly one of the largest and prettiest streams of the county”.9 The developing port was renamed in honor of the bay’s unique form in 1874 and a United States Post Office was established (as “Halfmoon” Bay). By 1905, the spelling was revised to the current three-word combination of Half Moon Bay. The turn of the twentieth century brought limited growth to the small town. In 1905, a group of wealthy San Francisco-based investors undertook building a new railroad that would connect San Francisco to Santa Cruz, following the Pacific coastline. The 40-linear-mile Ocean Shore Railroad, as it was known, was bitterly opposed by some residents of Half Moon Bay, who are said to have plowed over the newly built sidewalks that were intended to accommodate the expected tourist trade.10 It was an excursion line as well as a freight corridor, which facilitated movement of local farmers’ goods as well as lumber. The 1906 San Francisco earthquake brought the small rail line extreme financial hardship, but it was nonetheless completed by 1908. Despite successful bond sales to stay financially solvent, the new rail line went into in receivership in 1910. The strained rail line was abandoned a decade later. The City of Half Moon Bay was incorporated in 1959.
Archaeological and Historic Resources A complete list of documented archaeological and historic resources in the Planning Area can be obtained through the California Historical Resources Information System Northwest Information Center (NWIS). The following information is based on a records search through NWIS and is presented as a snapshot of the Planning Area’s resources. The NWIS’ data is frequently constantly updated as new resources are recorded, and should be consulted for the most current documentation of resources.
ARCHAEOLOGICAL RESOURCES Prehistoric examples of the types of archaeological sites that are known to exist within the Planning Area and vicinity include:
Shell middens and shell mounds are characterized by concentrations of marine shells that were harvested and processed for consumption.
Lithic debris and tool scatters are characterized by the presence of tool stone manufacturing waste flakes, core fragments, and formed flaked stone tools such as projectile points, knives, and scrapers.
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Hoover, Mildred B., Hero E. Rensch, Ethel G. Rensch, and William N. Abeloe 2002. Historic Spots in California. 5th ed. Rev. by D. E. Kyle. Stanford, Calif.: Stanford University Press. 8 Hoover, Mildred B., Hero E. Rensch, Ethel G. Rensch, and William N. Abeloe 2002. Historic Spots in California. 5th ed. Rev. by D. E. Kyle. Stanford, Calif.: Stanford University Press. 9 Alley B. F. 1883. History of San Mateo County, California. San Francisco: B. F. Alley, 1883: 239. 10 Drury, Wells, and Aubrey Drury 1913 Authentic Description of Routes of Travel and Points of Interest in California. Berkeley, Calif.: Western Guidebook Company: 65 and 99.
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Local Coastal Land Use Plan: Cultural Resources August 2017 Planning Commission Working Draft
Habitation sites are characterized by long-term, extended use, with various activity areas, which may include evidence of food processing, tool manufacturing, and ceremonial events.
Temporary campsites are generally limited use sites may contain evidence of food manufacturing or tool production.
Historic examples of the types of archaeological sites that are known to exist within the Planning Area include ranching, dairy, and whaling facilities structures and remnants.
There are 15 documented archaeological resources in the Planning Area, including prehistoric shell middens and lithic scatters, historic debris scatters, and historic structural remnant.
HISTORIC RESOURCES Historic resources consist of resources in the built environment resources, including standing buildings and structures, roads, fences, water conveyance features, and bridges, which are greater than fifty years in age. There are 51 documented built environment resources in Half Moon Bay. Given the historical development and importance of the region, it can be assumed that many of the historic-era (i.e. greater than 50 years) buildings and structures within the Planning Area may in fact be considered historical resources or historic properties. Figure 1 depicts cultural resources in the Planning Area in 2015. Half Moon Bay’s historic resources are especially important in the context of the Coastal Zone. Resources are predominately associated with historic era farms or the town’s first buildings clustered around what is today Downtown Main Street. The Scenic and Visual Resources chapter of the LUP identifies historic resources to be critical visual resources and therefore they are afforded additional protection through the City’s implementation of the California Coastal Act. The City’s historic resource inventory is not comprehensive. It has been assembled over time as individual and groupings of structures were evaluated. Many structures have been identified as potentially eligible for resource listing, at least at the local level, but have not been evaluated. Also, there are no designated historic districts in Half Moon Bay, even though there are several clusters of structures that may be eligible for district designation is so far as they collectively represent a significant time in the town’s history or authentically retain historic architectural integrity. Half Moon Bay’s historic resources include numerous properties on or eligible for the NRHP and/or CRHR. Many more are locally eligible. At the time of this LUP update, Main Street Bridge was the City’s most recent National Register listing.
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Figure 2.4-7: Figure 1: Cultural Resources (2015)
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Local Coastal Land Use Plan: Cultural Resources August 2017 Planning Commission Working Draft LAND USE PLAN FRAMEWORK The LUP includes policies intended to ensure the protection and preservation of cultural resources in Half Moon Bay. Policies provide for the identification and documentation of historical and archaeological resources by requiring that the City maintain an updated local historic resources inventory and archaeological resources map to aid in identifying opportunities for preservation as well as situations in which a more in-depth archaeological survey would be required to ensure that development does not have adverse impacts on potential resources. The policies call for an archaeological survey for projects located in archaeologically sensitive areas, and requires that a qualified archeologist document the resources on a site as well as any potential impacts. The LUP also requires that a mitigation plan be created to avoid or minimize any identified impacts, as well as the development of monitoring plans for projects on sensitive sites that provide for the selection of expert and Native American monitors and procedures to mitigate impacts if additional or unexpected resources are encountered during development. In light of rising sea levels, policies also seek to protect cultural resources from potential impacts. The LUP also establishes a requirement for Native American consultation consistent with the provisions of SB 18 and AB 52. The policy requires the City to notify the appropriate Native American organizations of developments or land use actions that have a potential to affect tribal cultural resources, giving Native Americans an opportunity to participate in the treatment of sites of cultural significance. Additionally, the LUP makes provisions for raising public awareness of the region’s culture and history to encourage appreciation and promote preservation of cultural resources.
CULTURAL AND PALEONTOLOGICAL RESOURCES POLICIES General Policies 1. Paleontological Cultural Resources Protection. Protect and preserve Half Moon Bay’s archaeological, paleontological, and historic resources Cultural Resources Preservation. Preserve the community’s cultural resources through identification, education and awareness, and standards for siting and design of new development. (FPD Policy 2.4-G.16 and 2.4-G.18) 2. Cultural Resources Awareness. Promote community education and awareness of the region’s culture, history, and historical resources through a variety of means, including the provision of arts and cultural offerings and exhibits accessible to all members of the community. (FPD Policy 2.4-I.190 partial) 3. Cultural Resources Archive. Establish a comprehensive archive of archaeological surveys, historical and archaeological resources mapping, and other relevant studies, inventories, and information for sites throughout the city to support cultural resource protection. (FPD Policy 2.4-I.193) 4. Development Impacts on Cultural Resources. Mitigate the impact of development on historic, archaeological or Native American resources through avoidance, preservation in place, or site sampling and salvage. The preferred alternatives for mitigating impacts to archaeological and Native American resources are avoidance or preservation in place. (FPD Policy 2.4-I.196)
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Local Coastal Land Use Plan: Cultural Resources August 2017 Planning Commission Working Draft 5. Human Remains. Recommend Require that if when human remains are uncovered during development, no further disturbance of the site shall occur until the County Coroner has made the necessary finds as to origin and disposition of the remains. (FPD Policy 2.4-I.197) 6. Sea Level Rise Impacts on Cultural Resources. Ensure that cultural resources are protected from the impacts of sea level rise. State Coordination. Work with the State Historic Preservation Officer to identify actions to protect archaeological, paleontological, and historic resources at risk from sea level rise impacts such as inundation and erosion. (Sea Level Rise Vulnerability Assessment and FPD Policy 2.4-G.18 and 2.4-I.200)
Native American Cultural Resources Policies 7. Native American Cultural Sites. Work with local Native American tribes to protect sacred and culturally significant sites. (FPD Policy 2.4-G.17) 8. Native American Consultation. Notify Native American organizations of proposed developments or land use actions that have the potential to adversely impact cultural resources early in the development review process, providing an opportunity for concerned Native American parties to comment on or participate in any treatment plan for sites with cultural or religious significance to the Native American community. Development on sensitive sites requires on-site monitoring by appropriate Native American consultant(s) and a qualified archaeologist for all grading, excavation, and site preparation activities that involve earth-moving operations. (FPD Policy 2.4-I.194) 9. Native American Coordination for Sea Level Rise Management. Coordinate with the appropriate Native American Tribe(s) or entity to develop a coordinated management plan for artifacts at risk from inundation, erosion, or other sea level rise impacts. (Sea Level Rise Vulnerability Assessment and FPD Policy 2.4-I.195) Archeological Resources Policies 10. Archaeological Resources Mapping. Maintain an updated generalized archaeological resource map that designates archaeologically sensitive areas and identifies where archaeological reports may be required for future development. (FPD Policy 2.4-I.191)
Note to the Reader: Archaeological resources maps are intended for City staff use. Detailed archaeological resources maps are viewable by authorized persons only, and are not available to the general public due to the sensitive and fragile nature of the identified resources. 11. Archaeological Survey with Development Applications. Require the submission of a report by a qualified archaeologist as part of applications for new development within any archaeologically sensitive area as designated on the archaeological resources map. In areas vulnerable to sea level rise impacts, require a site-specific evaluation of potential sea level rise impacts to any archaeological resources on the development site. A report shall include findings on actual and potential resources on the site, impacts of the development proposed, and recommended mitigation measures. All feasible mitigation measures shall be incorporated in the specific plan or development plan prior to the issuance of a permit for development. (FPD Policy 2.4-I.192)
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Local Coastal Land Use Plan: Cultural Resources August 2017 Planning Commission Working Draft 12. Cultural Archaeological and Paleontological Resources Monitoring. Require, where there is a potential to affect archaeological, Native American, or paleontological resources, the submittal of a monitoring plan that identifies monitoring methods and describes the procedures for selecting archeological and Native American monitors and procedures that will be followed if additional or unexpected resources are encountered during development of the site. Procedures may include, but are not limited to, provisions for cessation of all grading and construction activities in the area of the discovery that has any potential to uncover or otherwise disturb cultural deposits in the area of the discovery and all construction that may foreclose mitigation options to allow for significance testing, additional investigation and mitigation. (FPD Policy 2.4-I.198) 13. Monitoring of Sea Level Rise Impacts to Cultural and Paleontological Resources. Require that a monitoring program and plan be established as a condition of approval for development located on a site with cultural and/or paleontological resources vulnerable to sea level rise. (Sea Level Rise Vulnerability Assessment and FPD Policy 2.4-I.199)
Historic Resources Policies 14. Historic Resources Inventory. Prepare and maintain a comprehensive inventory of buildings, structure, objects, and areas of historic, architectural, and engineering significance in Half Moon Bay. (FPD Policy 2.4-I.186) 15. Historic Resource Designation. Assess potential historic resources; and if eligible, resources shall be brought forth for resource designation to the highest level to which they are eligible. (Planning Commission Working Draft Cultural Resources Chapter of the LUP) 16. Historic Preservation Ordinance. Review and update the Historic Preservation Ordinance periodically, ensuring continued compliance with CEQA and the Secretary of Interior’s Standards for preservation, rehabilitation, restoration, and reconstruction. (FPD Policy 2.4-I.17) 17. Historic Resource Protection. Continue to protect, preserve, and/or restore identified historic resources through the Historic Preservation Ordinance. (FPD Policy 2.4-I.188) 18. Historic Resource Evaluation. Require historic resource evaluations for all development applications associated with potential historic resources on or adjacent to the proposed project site. When resources are identified through this process, include them in the historic resources inventory. (Planning Commission Working Draft Cultural Resources Chapter of the LUP) 19. Historic Resource Training. Provide periodic training to the Planning Commission and City staff regarding the Historic Preservation Ordinance and Secretary of Interior’s Standards. (Planning Commission Working Draft Cultural Resources Chapter of the LUP) 20. Adaptive Reuse of Historic Resources. Encourage adaptive reuse of historic structures compatible with surrounding development and preserving the historical integrity of the structures. Establish guidelines for adaptive reuse in the Historic Resources Preservation Ordinance. (FPD Policy 2.4-I.189) 21. City-Owned Historic Resources. Maintain historic City-owned properties such as the Johnston House, Historic Train Depot, Half Moon Bay Historic Jail, Johnston Barn and others and make them available to the public. (FPD Policy 2.4-I.190 partial) 11
Cultural Resources Local Coastal Land Use Plan August 2017 Planning Commission Working Draft
www.planhmb.org
Plan Half Moon Bay Cultural Resources Local Coastal Land Use Plan
August 2017 Planning Commission Working Draft
Prepared by City of Half Moon Bay
Table of Contents Foreword ........................................................................................................... .................... i Coastal Act Framework .......................................................................................................1 Coastal Act Policy ...………………………......................................................................1 Federal and State Regulations ……......................................................................................1 Historic Context ……………….…….....................................................................................3 Archaeological and Historic Resources ..............................................................................5 Archaeological Resources...........................................................................................5 Historic Resources ……………………………..............................................................6 Land Use Plan Framework ……..…………………......................................................9 Cultural Resources Policies ……………………….......................................................9
Foreword This First Public Draft Local Coastal Land Use Plan was published in April 2016 for General Plan Advisory Committee (GPAC) and community input. This document - the August 2017 Planning Commission Working Draft Cultural Resources chapter of the Local Coastal Land Use Plan - is an update to the April 2016 version. In the April 2016 draft, Cultural Resources was a section in the Coastal Resources chapter. Cultural Resources has been made into a stand-alone chapter for the new draft. Input from the GPAC and community members has been incorporated into the August 2017 revision for oversight by the Planning Commission. The following is provided as a readers’ guide to the August 2017 revision.
All but minor editorial revisions are indicated in strikethrough for deletions and underline for additions. The document is substantially reorganized as follows: o Relevant California Coastal Act policies are provided in full at the beginning of the document. o Policies, sections, figures, and tables are simply numbered. o Policies are not differentiated as they were in the first public draft document (e.g. guiding and implementing). o Some sections of the document have been re-ordered. “Shall” language in the policies and indicated in bold. The bold font will not be retained in any final document. Each policy is followed by a reference in blue indicating one or more of the following: o Applicable policy number in the first public draft (demarcated with “FPD”) document. Policy numbering is substantially different in this revision, thus this system will be maintained to provide continuity from one version to the next. o Indication if the policy is new to the August 2017 revision – “Planning Commission Working Draft new Policy” Notes to the Reader are not intended to be included in any final document. They are provided to give context about particular subjects and GPAC decisions. There is one figure brought forward from the April 2016 draft. It will be updated at a future time on GIS map layers for the final draft.
Planning Staff is happy to review the various conventions used in this draft with any interested reader. Contact us at 650-726-8270 to make an appointment. i
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Cultural Resources Half Moon Bay values its cultural resources which include a plentiful variety of historic resources, as well as a limited number of archaeological sites. Because archaeological sites are a nonrenewable resource, they need to be preserved for future generations and study over time. The historic sites serve important commercial, recreational, and educational roles in the community while evoking the city’s unique heritage. This chapter provides policies for protection and enhancement of Half Moon Bay’s cultural resources.
Coastal Act Framework The California Coastal Act provides extensive policies concerning the protection, use, and experience of the natural coastal environment. This section summarizes Coastal Act policies regarding coastal resource management.
CULTURAL RESOURCES Section 30244 of the Coastal Act requires mitigation for development that would adversely impact archaeological or paleontological resources, reinforcing other state laws to that effect. Coastal Act Policy 30244 Archaeological or paleontological resources Where development would adversely impact archaeological or paleontological resources as identified by the State Historic Preservation Officer, reasonable mitigation measures shall be required.
Federal and State Regulations National Historic Preservation Act Significant archaeological and built environment resources are protected by the National Historic Preservation Act (NHPA). The National Register is an inventory of the United States' historic resources and is maintained by the National Park Service. The inventory includes buildings, structures, objects, sites, districts, and archeological resources meeting the following criteria as specified in the Code of Federal Regulations:
Local Coastal Land Use Plan: Cultural Resources August 2017 Planning Commission Working Draft The quality of significance in American history, architecture, archaeology, engineering, and culture is present in districts, sites, buildings, structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling and association and that: (a) Are associated with events that have made a significant contribution to the broad patterns of our history; or (b) Are associated with the lives of persons significant in our past; or (c) Embody the distinctive characteristics of a type, period, or method of installation, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or, (d) Have yielded, or may be likely to yield, information important in prehistory or history. (36 Code of Federal Regulations 60.4) National Register resources may be rehabilitated pursuant to the Secretary of Interior’s Standards. California Environmental Quality Act The California Environmental Quality Act (CEQA) requires consideration of impacts on significant paleontological, historical, and archaeological resources. Significant impacts by projects on such resources are to be avoided or mitigated to less than significant levels. If the project may cause damage to a significant resource, the project may have a significant effect on the environment. Achieving CEQA compliance with regard to treatment of impacts to significant cultural resources requires that a mitigation plan be developed for the resource(s). Preservation in place is the preferred manner of mitigating impacts to archaeological resources. The CEQA guidelines require that any properties that can be expected to be directly or indirectly affected by a proposed project be evaluated for California Register of Historical Resources (CRHR) eligibility. The purpose of the register is to maintain listings of the state’s historical resources and to indicate what properties are to be protected, to the extent prudent and feasible, from material impairment and substantial adverse change. The term “historical resources” includes a resource listed in, or determined to be eligible for listing in, the CRHR, a resource included in a local register of historical resources, and any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant. The criteria for listing properties in the CRHR were expressly developed in accordance with previously established criteria developed for listing in the NRHP. A resource may be considered historically significant at the state level if it retains integrity and meets at least one of the following criteria:
(1) Is associated with events that have made a significant contribution to the broad patterns of California's history and cultural heritage; (2) Is associated with the lives of persons important in our past; (3) Embodies the distinctive characteristics of a type, period, region or method of installation, or represents the work of an important creative individual, or possesses high artistic values; or (4) Has yielded, or may be likely to yield, information important in prehistory or history. (Public Resources Code Section 5024.1(c)1–4) 2
Local Coastal Land Use Plan: Cultural Resources August 2017 Planning Commission Working Draft Under CEQA, if an archeological site is not a historical resource but meets the definition of a “unique archeological resource,” impacts to the resource should be avoided or fully mitigated. A unique archaeological resource is defined as follows:
An archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria: (1) Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information. (2) Has a special and particular quality such as being the oldest of its type or the best available example of its type. (3) Is directly associated with a scientifically recognized important prehistoric or historic event or person. (Public Resources Code, Section 21083.2) California Senate Bill 18 and Assembly Bill 52
State planning law requires cities and counties to consult with California Native American tribes during the local planning process for the purpose of protecting Traditional Tribal Cultural Places. Senate Bill (SB) 18 requires cities and counties to contact, and consult with California Native American tribes prior to amending or adopting any general plan or specific plan, or designating land as open space. For purposes of consultation with tribes, the NAHC maintains a list of California Native American Tribes with whom local governments must consult. Assembly Bill 52 furthers SB 18 and provides for consideration of tribal cultural values. Tribal cultural values may include a site feature, place, cultural landscape, sacred place or object. The cultural value must be either on or eligible for the CAHR; or treated as a tribal cultural value pursuant to the discretion of the city or county.
Historic Context The Planning Area is of high sensitivity for the presence of archaeological and built environment resources. The Half Moon Bay region has a long, documented prehistory and history. It was and is an important piece of the development of Central California and the protection and identification of its known and unknown cultural resources is of utmost importance for future planning needs. No paleontological resources of known significance have been identified in Half Moon Bay and they are extremely limited throughout the San Mateo County Coastal Zone. Ethnography The Planning Area is in a region historically occupied by the tribelets of the Costanoan linguistic group.1 Descendants of Costanoan speakers prefer to be called by the name of the tribelet from which they are descended. When their heritage is mixed or the specifics have been lost over generations, they prefer the use of a native term, Ohlone, rather than the European-imposed term 1
Levy, Richard 1978. Costanoan. In California, edited by R. F. Heizer, pp.485–495. Handbook of North American Indians, Vol. 8, William C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C.
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Local Coastal Land Use Plan: Cultural Resources August 2017 Planning Commission Working Draft Costanoan (“coastal dwellers”).2 The rich resources of the ocean, bays, valleys, and mountains in the region provided Ohlone-speaking peoples with food and all their material needs.3 The primary food staple was the acorn, supplemented by a great variety of animal and plant resources. Prehistory The Planning Area lies in what generally is described as the San Francisco Bay Region, which is one of eight arbitrary organizational divisions of the state.4 This archaeological region includes all of today’s San Mateo and Marin Counties, and western, northern, or southern portions of Alameda, Contra Costa, Napa, Santa Clara, Santa Cruz, Solano, and Sonoma Counties bordering the Bay Area.5 The prehistory of this region is divided into six periods: Early Holocene (Lower Archaic, cal 80003500 B.C), Early period (Middle Archaic, 3500 to 500 cal B.C.), Lower Middle period (Initial Upper Archaic, 500 cal B.C. to cal A.D. 430), Upper Middle period (Late Upper Archaic, cal A.D. 430 to 1050), Initial Late Period (Lower Emergent, cal A.D. 1050 to 1550), and Terminal Late Period (cal A.D. 1550 to 1776).6 History The Post-Contact history for the state of California generally is divided into three periods: the Spanish period (1769–1822), the Mexican period (1822–1848), and the American period (1848– present). Although there were brief visits by Spanish, Russian, and British explorers from 1529 to 1769, the beginning of Spanish settlement in California occurred in 1769 with a settlement at San Diego and the first of 21 missions (Mission San Diego de Alcalá) established from 1769 to 1823. Word of Mexican victory after a decade of revolt against the Spanish crown reached California in 1822, marking the beginning of the Mexican period. This period was marked by an extensive era of land grants, most of which were in the interior of the state, and by exploration by American fur trappers west of the Sierra Nevada Mountains. With the signing of the Treaty of Guadalupe Hidalgo in 1848, ending the Mexican-American War, California became a territory of the United States. The discovery of gold in 1848 at Sutter’s Mill near Sacramento and the resulting Gold Rush influenced the history of the state and the nation. The rush of tens of thousands of people to the goldfields also had a devastating impact on the lives of indigenous Californians, with the introduction and concentration of diseases, the loss of land and territory (including traditional hunting and gathering locales), violence, malnutrition, and starvation. Thousands of settlers and immigrants continued to pour into the state, particularly after the completion of the transcontinental railroad in 1869. The Miramontez family established Rancho San Benito on the southern bank of the arroyo in about 1841. They built an adobe residence in present-day Half Moon Bay, which was said to have 2
Margolin, Malcolm 1978. The Ohlone Way: Indian Life in the San Francisco-Monterey Bay Area. San Francisco: Heyday Books. 3 Levy, Richard 1978. Costanoan. In California, edited by R. F. Heizer, pp.485–495. Handbook of North American Indians, Vol. 8, William C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C. 491-492. 4 Moratto, Michael 1984. California Archaeology. New York: Academic Press. 5 Moratto, Michael 1984. California Archaeology. New York: Academic Press. 6 Milliken, Randall, Richard T. Fitzgerald, Mark G. Hylkema, Randy Groza, Tom Origer, David G. Bieling, Alan Leventhal, Randy S. Wiberg, Andrew Gottsfield, Donna Gillette, Viviana Bellifemine, Eric Strother, Robert Cartier, and David A. Fredrickson. 2007. Punctuated Culture Change in the San Francisco Bay Area. In California Prehistory: Colonization, Culture, and Complexity, edited by Terry L. Jones and Kathryn A. Klar, pp. 101, 114-118. Altamira Press, Lanham, Maryland.
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Local Coastal Land Use Plan: Cultural Resources August 2017 Planning Commission Working Draft remained standing into the 1900s (Hoover et al. 2000).7 The community was originally called San Benito and later “Spanishtown,” in part because of the influence of its founding Hispanic families. It was first platted in 1863. By the mid-late 1800s, stores, churches, and at least one saloon had been built (Hoover et al. 2000).8 The area was remote compared to other population centers; agriculture was the main source of local commerce. In the History of San Mateo County, California, Half Moon Bay was described as “one of the finest agricultural districts of [the] county, located upon what was formerly one of the largest and prettiest streams of the county”.9 The developing port was renamed in honor of the bay’s unique form in 1874 and a United States Post Office was established (as “Halfmoon” Bay). By 1905, the spelling was revised to the current three-word combination of Half Moon Bay. The turn of the twentieth century brought limited growth to the small town. In 1905, a group of wealthy San Francisco-based investors undertook building a new railroad that would connect San Francisco to Santa Cruz, following the Pacific coastline. The 40-linear-mile Ocean Shore Railroad, as it was known, was bitterly opposed by some residents of Half Moon Bay, who are said to have plowed over the newly built sidewalks that were intended to accommodate the expected tourist trade.10 It was an excursion line as well as a freight corridor, which facilitated movement of local farmers’ goods as well as lumber. The 1906 San Francisco earthquake brought the small rail line extreme financial hardship, but it was nonetheless completed by 1908. Despite successful bond sales to stay financially solvent, the new rail line went into in receivership in 1910. The strained rail line was abandoned a decade later. The City of Half Moon Bay was incorporated in 1959.
Archaeological and Historic Resources A complete list of documented archaeological and historic resources in the Planning Area can be obtained through the California Historical Resources Information System Northwest Information Center (NWIS). The following information is based on a records search through NWIS and is presented as a snapshot of the Planning Area’s resources. The NWIS’ data is frequently constantly updated as new resources are recorded, and should be consulted for the most current documentation of resources.
ARCHAEOLOGICAL RESOURCES Prehistoric examples of the types of archaeological sites that are known to exist within the Planning Area and vicinity include:
Shell middens and shell mounds are characterized by concentrations of marine shells that were harvested and processed for consumption.
Lithic debris and tool scatters are characterized by the presence of tool stone manufacturing waste flakes, core fragments, and formed flaked stone tools such as projectile points, knives, and scrapers.
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Hoover, Mildred B., Hero E. Rensch, Ethel G. Rensch, and William N. Abeloe 2002. Historic Spots in California. 5th ed. Rev. by D. E. Kyle. Stanford, Calif.: Stanford University Press. 8 Hoover, Mildred B., Hero E. Rensch, Ethel G. Rensch, and William N. Abeloe 2002. Historic Spots in California. 5th ed. Rev. by D. E. Kyle. Stanford, Calif.: Stanford University Press. 9 Alley B. F. 1883. History of San Mateo County, California. San Francisco: B. F. Alley, 1883: 239. 10 Drury, Wells, and Aubrey Drury 1913 Authentic Description of Routes of Travel and Points of Interest in California. Berkeley, Calif.: Western Guidebook Company: 65 and 99.
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Local Coastal Land Use Plan: Cultural Resources August 2017 Planning Commission Working Draft
Habitation sites are characterized by long-term, extended use, with various activity areas, which may include evidence of food processing, tool manufacturing, and ceremonial events.
Temporary campsites are generally limited use sites may contain evidence of food manufacturing or tool production.
Historic examples of the types of archaeological sites that are known to exist within the Planning Area include ranching, dairy, and whaling facilities structures and remnants.
There are 15 documented archaeological resources in the Planning Area, including prehistoric shell middens and lithic scatters, historic debris scatters, and historic structural remnant.
HISTORIC RESOURCES Historic resources consist of resources in the built environment resources, including standing buildings and structures, roads, fences, water conveyance features, and bridges, which are greater than fifty years in age. There are 51 documented built environment resources in Half Moon Bay. Given the historical development and importance of the region, it can be assumed that many of the historic-era (i.e. greater than 50 years) buildings and structures within the Planning Area may in fact be considered historical resources or historic properties. Figure 1 depicts cultural resources in the Planning Area in 2015. Half Moon Bay’s historic resources are especially important in the context of the Coastal Zone. Resources are predominately associated with historic era farms or the town’s first buildings clustered around what is today Downtown Main Street. The Scenic and Visual Resources chapter of the LUP identifies historic resources to be critical visual resources and therefore they are afforded additional protection through the City’s implementation of the California Coastal Act. The City’s historic resource inventory is not comprehensive. It has been assembled over time as individual and groupings of structures were evaluated. Many structures have been identified as potentially eligible for resource listing, at least at the local level, but have not been evaluated. Also, there are no designated historic districts in Half Moon Bay, even though there are several clusters of structures that may be eligible for district designation is so far as they collectively represent a significant time in the town’s history or authentically retain historic architectural integrity. Half Moon Bay’s historic resources include numerous properties on or eligible for the NRHP and/or CRHR. Many more are locally eligible. At the time of this LUP update, Main Street Bridge was the City’s most recent National Register listing.
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Figure 2.4-7: Figure 1: Cultural Resources (2015)
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Local Coastal Land Use Plan: Cultural Resources August 2017 Planning Commission Working Draft LAND USE PLAN FRAMEWORK The LUP includes policies intended to ensure the protection and preservation of cultural resources in Half Moon Bay. Policies provide for the identification and documentation of historical and archaeological resources by requiring that the City maintain an updated local historic resources inventory and archaeological resources map to aid in identifying opportunities for preservation as well as situations in which a more in-depth archaeological survey would be required to ensure that development does not have adverse impacts on potential resources. The policies call for an archaeological survey for projects located in archaeologically sensitive areas, and requires that a qualified archeologist document the resources on a site as well as any potential impacts. The LUP also requires that a mitigation plan be created to avoid or minimize any identified impacts, as well as the development of monitoring plans for projects on sensitive sites that provide for the selection of expert and Native American monitors and procedures to mitigate impacts if additional or unexpected resources are encountered during development. In light of rising sea levels, policies also seek to protect cultural resources from potential impacts. The LUP also establishes a requirement for Native American consultation consistent with the provisions of SB 18 and AB 52. The policy requires the City to notify the appropriate Native American organizations of developments or land use actions that have a potential to affect tribal cultural resources, giving Native Americans an opportunity to participate in the treatment of sites of cultural significance. Additionally, the LUP makes provisions for raising public awareness of the region’s culture and history to encourage appreciation and promote preservation of cultural resources.
CULTURAL AND PALEONTOLOGICAL RESOURCES POLICIES General Policies 1. Paleontological Cultural Resources Protection. Protect and preserve Half Moon Bay’s archaeological, paleontological, and historic resources Cultural Resources Preservation. Preserve the community’s cultural resources through identification, education and awareness, and standards for siting and design of new development. (FPD Policy 2.4-G.16 and 2.4-G.18) 2. Cultural Resources Awareness. Promote community education and awareness of the region’s culture, history, and historical resources through a variety of means, including the provision of arts and cultural offerings and exhibits accessible to all members of the community. (FPD Policy 2.4-I.190 partial) 3. Cultural Resources Archive. Establish a comprehensive archive of archaeological surveys, historical and archaeological resources mapping, and other relevant studies, inventories, and information for sites throughout the city to support cultural resource protection. (FPD Policy 2.4-I.193) 4. Development Impacts on Cultural Resources. Mitigate the impact of development on historic, archaeological or Native American resources through avoidance, preservation in place, or site sampling and salvage. The preferred alternatives for mitigating impacts to archaeological and Native American resources are avoidance or preservation in place. (FPD Policy 2.4-I.196)
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Local Coastal Land Use Plan: Cultural Resources August 2017 Planning Commission Working Draft 5. Human Remains. Recommend Require that if when human remains are uncovered during development, no further disturbance of the site shall occur until the County Coroner has made the necessary finds as to origin and disposition of the remains. (FPD Policy 2.4-I.197) 6. Sea Level Rise Impacts on Cultural Resources. Ensure that cultural resources are protected from the impacts of sea level rise. State Coordination. Work with the State Historic Preservation Officer to identify actions to protect archaeological, paleontological, and historic resources at risk from sea level rise impacts such as inundation and erosion. (Sea Level Rise Vulnerability Assessment and FPD Policy 2.4-G.18 and 2.4-I.200)
Native American Cultural Resources Policies 7. Native American Cultural Sites. Work with local Native American tribes to protect sacred and culturally significant sites. (FPD Policy 2.4-G.17) 8. Native American Consultation. Notify Native American organizations of proposed developments or land use actions that have the potential to adversely impact cultural resources early in the development review process, providing an opportunity for concerned Native American parties to comment on or participate in any treatment plan for sites with cultural or religious significance to the Native American community. Development on sensitive sites requires on-site monitoring by appropriate Native American consultant(s) and a qualified archaeologist for all grading, excavation, and site preparation activities that involve earth-moving operations. (FPD Policy 2.4-I.194) 9. Native American Coordination for Sea Level Rise Management. Coordinate with the appropriate Native American Tribe(s) or entity to develop a coordinated management plan for artifacts at risk from inundation, erosion, or other sea level rise impacts. (Sea Level Rise Vulnerability Assessment and FPD Policy 2.4-I.195) Archeological Resources Policies 10. Archaeological Resources Mapping. Maintain an updated generalized archaeological resource map that designates archaeologically sensitive areas and identifies where archaeological reports may be required for future development. (FPD Policy 2.4-I.191)
Note to the Reader: Archaeological resources maps are intended for City staff use. Detailed archaeological resources maps are viewable by authorized persons only, and are not available to the general public due to the sensitive and fragile nature of the identified resources. 11. Archaeological Survey with Development Applications. Require the submission of a report by a qualified archaeologist as part of applications for new development within any archaeologically sensitive area as designated on the archaeological resources map. In areas vulnerable to sea level rise impacts, require a site-specific evaluation of potential sea level rise impacts to any archaeological resources on the development site. A report shall include findings on actual and potential resources on the site, impacts of the development proposed, and recommended mitigation measures. All feasible mitigation measures shall be incorporated in the specific plan or development plan prior to the issuance of a permit for development. (FPD Policy 2.4-I.192)
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Local Coastal Land Use Plan: Cultural Resources August 2017 Planning Commission Working Draft 12. Cultural Archaeological and Paleontological Resources Monitoring. Require, where there is a potential to affect archaeological, Native American, or paleontological resources, the submittal of a monitoring plan that identifies monitoring methods and describes the procedures for selecting archeological and Native American monitors and procedures that will be followed if additional or unexpected resources are encountered during development of the site. Procedures may include, but are not limited to, provisions for cessation of all grading and construction activities in the area of the discovery that has any potential to uncover or otherwise disturb cultural deposits in the area of the discovery and all construction that may foreclose mitigation options to allow for significance testing, additional investigation and mitigation. (FPD Policy 2.4-I.198) 13. Monitoring of Sea Level Rise Impacts to Cultural and Paleontological Resources. Require that a monitoring program and plan be established as a condition of approval for development located on a site with cultural and/or paleontological resources vulnerable to sea level rise. (Sea Level Rise Vulnerability Assessment and FPD Policy 2.4-I.199)
Historic Resources Policies 14. Historic Resources Inventory. Prepare and maintain a comprehensive inventory of buildings, structure, objects, and areas of historic, architectural, and engineering significance in Half Moon Bay. (FPD Policy 2.4-I.186) 15. Historic Resource Designation. Assess potential historic resources; and if eligible, resources shall be brought forth for resource designation to the highest level to which they are eligible. (Planning Commission Working Draft Cultural Resources Chapter of the LUP) 16. Historic Preservation Ordinance. Review and update the Historic Preservation Ordinance periodically, ensuring continued compliance with CEQA and the Secretary of Interior’s Standards for preservation, rehabilitation, restoration, and reconstruction. (FPD Policy 2.4-I.17) 17. Historic Resource Protection. Continue to protect, preserve, and/or restore identified historic resources through the Historic Preservation Ordinance. (FPD Policy 2.4-I.188) 18. Historic Resource Evaluation. Require historic resource evaluations for all development applications associated with potential historic resources on or adjacent to the proposed project site. When resources are identified through this process, include them in the historic resources inventory. (Planning Commission Working Draft Cultural Resources Chapter of the LUP) 19. Historic Resource Training. Provide periodic training to the Planning Commission and City staff regarding the Historic Preservation Ordinance and Secretary of Interior’s Standards. (Planning Commission Working Draft Cultural Resources Chapter of the LUP) 20. Adaptive Reuse of Historic Resources. Encourage adaptive reuse of historic structures compatible with surrounding development and preserving the historical integrity of the structures. Establish guidelines for adaptive reuse in the Historic Resources Preservation Ordinance. (FPD Policy 2.4-I.189) 21. City-Owned Historic Resources. Maintain historic City-owned properties such as the Johnston House, Historic Train Depot, Half Moon Bay Historic Jail, Johnston Barn and others and make them available to the public. (FPD Policy 2.4-I.190 partial) 11
