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Common CAA Errors

Written by:
CAL FIRE Archaeology Program Staff
Date revised: August 9, 2005

Statement of Purpose

This report lists the most commonly seen errors and omissions to a completed Confidential Archaeological Addendum (CAA) to a Timber Harvesting Plan (THP) during its review by CAL FIRE. It includes those most common major “fatal” errors which, unfortunately, result in CAL FIRE being required to return the THP to the submitter without filing. It also identifies the most common correctable errors found during first review by the CAL FIRE staff or contract professional archaeologist assigned to review them. This information is intended to provide a useful tool for Registered Professional Foresters (RPFs) in their task of completing CAAs that conform to the Forest Practice Rules. By sharing this information with those RPFs that prepare CAAs, we hope this might be helpful to avoid repeating mistakes made by others, which will reduce or eliminate the time and cost associated with having plans returned or having to correct omissions or errors. Detailed instructions for the completion of a CAA have also been published by CAL FIRE. Those are available in a separate document entitled Instructions for Completing CAL FIRE’s CAA Report Form and will not be repeated here. For convenience, this list of common errors is presented in groupings that correspond to the organization of the CAA report format.

Key to abbreviations used

Each of the common errors listed is preceded by an abbreviation indicating its level of significance.

RI = Return Item. Errors of this type will probably result in the plan being returned to the submitter without filing.

PRI = Return Item. Errors of this type might result in the plan being returned to the submitter without filing.

CE = Correctable Error. Errors of this type will generally not result in the plan being returned, but can be corrected during CAL FIRE’s review of the plan, and such corrections are usually made a condition for recommendation for approval. It is possible, however, if the plan contains a multitude of correctable errors, CAL FIRE may return the plan to the submitter.

Note: CAL FIRE does not enjoy having to return plans and understands the hardships placed on RPFs and the landowners they represent when we must return a submitted CAA rather accept if for filing. In preparing your CAAs, particularly the Native American Notification Letters, if you have any questions about the required contents or whether or not a particular letter will meet the requirements, by all means contact the appropriate CAL FIRE Archaeologist in your area by phone or e-mail PRIOR to submitting the Plan. Such pre-consultation can both save time and prevent needless frustration during the review process.

Disclaimer: This report does not attempt to list ALL potential reasons why a CAA might be returned. It does contain a listing of the most common problems seen by CAL FIRE staff involved in CAA review.

Revision Schedule: CAL FIRE plans to make frequent updates to this checklist as new issues become identified. We welcome suggestions from RPFs to improve its content and usefulness. Send comments to Dan Foster at dan.foster@fire.ca.gov

Report Title, Authorship, Date, Signature

CE - The required signature of either the RPF or Archaeological Surveyor is sometimes omitted. A corrected page with original signature may be required as a condition for plan approval.

Part 1: Project Information

CE - Incorrect legal descriptions (e.g., incorrect township/range &/or sections given; omission of the baseline and meridian name).

CE - Incomplete information such as project acreage or name of quad map.

Part 2: Archaeological Records Check Information

RI - Records Check request map does not cover entire area in THP. All THP acreage must be addressed in the Records Check. Plans with incomplete Records Check coverage must be returned.

RI - Non-current Records Check. The Forest Practice Rules define a current Records Check as one that is 5 years or less old. Plans with non-current Records Checks are to be returned.

PRI - Forgetting to include information that is required by the Rules such as a copy of the Archaeological Records Check Request Form which includes the Confidentiality Agreement. If such items are specifically required to be attached, their omission may result in the plan failing to pass the complete and accurate standard for THP acceptance, and could be returned. In some instances CAL FIRE may choose to allow the omission to be corrected as a condition for plan approval.

Part 3: Native American Consultation Information

RI - One or more of the required items in Native American notification letters are missing. Two commonly missing elements include the statement about the earliest possible THP approval date which must be quoted verbatim from the Rules, (see 929.1 [949,1,969.1](a)(2)(D)) and the required statement that all replies should be directed to the RPF. CAL FIRE has posted a sample letter on the Archaeology Program Web Site to help RPFs ensure that all required elements in their notification letters are included. RPFs are encouraged to download that sample letter and customize their own form letter with blank spaces to fill-in specific to individual plans. CAL FIRE has no discretion here. If a plan has not been noticed correctly, it will be returned.

RI - The most recent Native American Contact List was not used. This list is posted on the CAL FIRE web site, is usually updated monthly, and revised postings usually occur in the first week on each month. Your responsibility is to use the most current list that was available at the time the THP was being researched and developed. If, due to using the improper list, you missed contacting all the required names or addresses, then the plan would be returned. You would need to send out additional letters and wait 10 days for a possible response.

RI - Insufficient response time. The Forest Practice Rules specify that tribal groups be allowed a minimum of 10 days to respond to RPF letters. Plans submitted to CAL FIRE prior to the conclusion of this 10 day period are to be returned unless the RPF has documented contact with all groups prior to the conclusion of the 10 day period.

CE - Need to provide a “No reply received as of…” date (if there are no replies to the notification letters). Need to provide complete summaries of the results of any field visits by tribal representatives.

CE - Don’t place tribal correspondence letters with other correspondence located elsewhere in the THP. They must be included with the CAA.

CE - You must provide a copy of the maps you included with the Native American notification letter. Don’t forget, only a sample letter is required. You don’t need to provide a copy of each letter sent to each contact.

Part 4: Pre-Field Research

RI - Failure to conduct pre-field research. The Forest Practice Rules require the RPF to conduct pre-field research (929.1A(4) & 929.1C(5)). Pre-field research is research other than the records check and the Native American notification letters. You must ask at least one knowledgeable person about the project area and you must list at least one reference used to help with the survey or history of the project area. If the RPF fails to list and demonstrate the completion of pre-field research, the plan must be returned.

CE - Certain Rule changes that took effect 1/1/03 require more information on pre-field research than was previously required. CAL FIRE continues to encounter many problems with inadequate pre-field research information included on CAAs, and may require RPFs to provide additional information as a condition of approval. The purpose of this research is to get prepared to conduct the survey, become familiar with the types of resources likely to be encountered within the project area, and to be ready to interpret, record, and evaluate these findings within the context of local prehistory and history. Determine which tribal group(s) occupied the area being studied and review information about those groups. Indicate on the CAA who these groups were, how they used the land and what types of artifacts and archaeological sites you expect to encounter within the project area. Likewise, in terms of history, briefly summarize major historical activities that took place in the area (e.g., railroad logging, homesteading, ranching….) and summarize the types of sites one could expect to find as a result of these activities. Also indicate what else was reviewed (e.g., GLO plat maps, old topographic maps, aerial photos) and what features were indicated as being within the project area. People that might have important information might include the landowners, local ranchers, or neighbors. You should also summarize what you learned from those old maps and from talking with local old timers. RPFs that continue to have difficulty presenting adequate prefield research information to satisfy CAL FIRE’s first review are encouraged to study the specific guidance given on this topic found on pages 3, 4 and 8 of the Instructions for Completing CAL FIRE’s CAA Report Form.

CE - RPFs should address any potential resources identified in the records check letters or other pre-field research (e.g., roads/trails/buildings shown on the historic maps, reported village sites, previously recorded sites, etc.)

Part 5: Training and Experience of Archaeological Surveyors

RI - No archaeological training. The Forest Practice Rules (929.4) require that a professional archaeologist or a person who has attended a training program approved by the Director be retained to conduct the project archaeological survey. If no training or professional credential is indicated the plan is to be returned.

RI - Expired training certification. The Forest Practice Rules (929.4) require that the RPFs training be current at time of THP submittal. Current means within the last five years. Plans that contain an archaeological survey performed by a person who last attended a CAL FIRE training course more than five years prior to submission are to be returned. Persons who have signed-up for a refresher course in the same calendar year that their training expires are considered qualified, even if their 5-year certification expires prior to taking the refresher courses.

CE - RPFs need to include the names of any individuals who conducted previous archaeological surveys within the plan area.

Part 6: Survey Methods and Procedures

RI - A plan that fails to include an attempt to relocate archaeological site(s) recorded within the plan area as mentioned in the archaeological records check.

CE - RPFs often provide incomplete information in Part 6 which prevents CAL FIRE staff from evaluating the adequacy of the survey effort. Common data fields insufficiently described include the description of survey strategy, time spent conducting the field survey, date or dates of the field survey, survey coverage intensity, and/or ground visibility.

CE - Terms such as “high intensity” or “low intensity,” must be defined. While most RPFs do not run formal transects we suggest you provide a description of transect intervals, especially in areas that were cruised or marked.

Part 7: Survey Results

RI - All archaeological sites known for the THP area are to be listed and described in this section of the report. The plan can be returned if archaeological sites mentioned in the archaeological Records Check, tribal response letters, or other sources attached to the CAA are not addressed. Don’t forget to list ALL sites, not just significant ones, not just newly discovered sites. Give a short description of each site, including size, type, and condition.

CE - The CAA is the only place where specific locations of archaeological sites are mapped or discussed. Don’t show sites on THP maps located in other parts of the plan.

CE - Revision of this section of the CAA may be required as a condition of plan approval if CAL FIRE determines that the information as originally submitted is not complete or accurate. Examples of items often needing correction include a description of each identified site that includes site type, site contents (artifacts and features), site size, and site condition.

CE - In Survey Results, Significance Assessment, Protection Measures, Attachments, Coverage Map, and Site Records, the site designations must all be the same. If you named a site “Cooper Cabin” or “Site 1” in this section, then you must consistently use that name throughout the CAA and site records.

Part 8: Evaluation of Significance

CE - Revision of this section of the CAA may be required as a condition of plan approval if information needs to be updated. Note that significance assessments must address each of the five criteria set forth in the definition for significant archaeological or historical site outlined in Section 895.1 (Definitions) of the Forest Practice Rules.

Part 9: Protection Measures

CE - Make sure your protection measures are written in clear enforceable language.

CE - Protection measures must include consideration of the area(s) within 100 feet of site boundaries as well as cultural resources within 100 feet of areas of operation.

CE - If CAL FIRE requires additional protection measures for archaeological sites, this section will need to be revised as a condition for plan approval. Common situations include changes to the proposed archaeological site protection plan such as a provision for the directional felling of adjacent trees or adding a protection plan for a site that was overlooked and not originally discussed in this section of the CAA.

Part 10: Meeting with the Licensed Timber Operator

CAL FIRE has not encountered frequent problems with Part 10 of the CAA, and has no suggestions to offer.

Part 11: Site Recording

RI - Upon submission of a plan the rules require the RPF to submit completed site records for all significant sites. The plan can be returned if acknowledged significant sites are not recorded or these site records are not provided at the time of plan submission.

CE - The following are common errors we see on completed site record forms:

· Overall Site Record Presentation: Each page of the site record package must contain the page number (placed on the top left) and site name (top right). Page number each site as a total package. For example, if a record has a primary record, archaeological site record, photographic record, location map, and site map you would start with the primary record as page 1 of 5, the archaeological site record as page 2 of 5, the photographic record page 3 of 5, etc.

· Overall Site Record Presentation - Complete all sections of the form (especially Item P11 – Report Citation). The Site Location Map must consist of a clean 1:1 scale copy of the appropriate portion of the USGS quadrangle map (NOT a copy of the Archaeological Survey Coverage Map or the THP Location Map.) Each Site Location Map should show the location of the site being recorded only. The site boundary/boundaries must be clearly marked. All sites recorded must be recorded according to the current standards set by the State (refer to Instructions for Recording Historical Resources cited in the Rule Section 929.4).

· Primary Record Section P1: Resource Name - don’t leave this blank, this is the name already assigned to the site or the one you give to it.

· Primary Record Section P2: Check “Confidential.” Unrestricted is used for publicly owned buildings or structures.

· Primary Record Section P2d: Problems with UTM coordinates. Northing coordinates must contain seven digits and Easting coordinates six digits; linear features must have two sets of coordinates; sites ten acres or larger must have four sets of coordinates.

· Primary Record Section P2e: Problems with directions. This statement must contain a description that will permit someone to easily relocate the site in the future. Give good directions to get to the site. Your directions are necessary for future management purposes. The site directions should be sufficiently detailed to allow someone else to relocate the site.

· Primary Record Section P3a: We often see incomplete site descriptions. Remember to include the site type, contents (artifacts and features), site size, and condition at minimum; especially if the Primary Record stands alone without resource-specific detailed record such as the Archaeological Site Record. You may be the only person who will ever scientifically look at this site. Give a good, thorough description of the site and its surroundings.

· Primary Record Section P4: If the building or structure is not habitable or useable, then it is a site. Archaeological ruins of historic buildings or structures are classified as sites.

· Primary Record Section P5: While attached photographs of sites are highly desirable, but optional, they are required if you are recording a building or structure. Provide two original photos, or if digital photos, provide two first generation photo pages. These will be provided to the IC when the plan is approved.

· Primary Record Section P11: For report citation, provide complete title of the CAA, RPF name, date report prepared, and partially complete the THP, number (e.g. THP #4-03- ___ /Eld-___). CAL FIRE will fill in the THP number prior to sending to the Information Center.

Part 12: Other Applicable Information

CAL FIRE has not encountered frequent problems with Part 12 of the CAA, and has no suggestions to offer.

Part 13: List of Attachments

RI - The Forest Practice Rules require the submittal of an Archaeological Coverage Map. The plan will be returned if the required map is missing.

CE - On your Survey Coverage Map and Location Map place a dot, line, or outline to show the specific site location. Don’t use stars or triangles, as you are showing the approximate site size and configuration. Use an arrow to highlight where your site is, but don’t have the arrow touch the actual dot. Don’t fill in your site outline as this may cover topographic lines, springs, etc.

CE - You must provide a 1:1 scale copy of the USGS 7.5’ quadrangle as the base map for the Archaeological Coverage Map and Site Location Map. Common error we see is for RPFs to include enlarged versions of these maps and failing to include the 1:1 scale map. We do encourage enlarged maps to provide clarity, especially with small acreage THPs, but the 1:1 scale maps must also be included.