CAL FIRE Archaeology Program: Common CAA Errors

Written by: CAL FIRE Archaeology Program Staff
Date revised: October 2014


Statement of Purpose:
This document describes commonly-seen errors in and omissions to completed Confidential Archaeological Addenda (CAA) to Timber Harvesting Plans (THPs) and Nonindustrial Timber Management Plans (NTMPs) during review by the California Department of Forestry and Fire Protection (CAL FIRE) Archaeology Program staff. It includes those most common major errors which usually result in CAL FIRE being required to return the plan to the submitting without accepting it for filing and also identifies common correctable errors found during review of CAAs. The information presented in this document is intended to provide a useful tool for Registered Professional Foresters (RPFs) in their task of completing (or supervising completion) of CAAs that conform to applicable requirements of the California Forest Practice Rules. Detailed instructions for the completion of a CAA, titled Instructions for Completing CAL FIRE’s CAA Report Form, are posted on the CAL FIRE Archaeology Program Website and are not repeated here. The following list of common CAA errors is presented in the order in which each topic appears in the CAA format.


Key to abbreviations used: Each of the common errors listed below is preceded by an abbreviation indicating its level of importance: 
RI = Return Issue: Errors of this type result in a recommendation to the Review Team to return the plan to the submitter without filing.
PRI = Potential Return Issue: Errors of this type may result in a recommendation to the Review Team to return the plan to the submitter without filing. 
CE = Correctable Error: Errors of this type do not usually trigger a recommendation to return the plan but instead are corrected by the RPF during CAL FIRE’s review of the plan. Correction of such errors is usually made a condition of recommendation for approval of the plan. However, if a CAA is found to contain a multitude of correctable errors, the CAL FIRE Archaeology staff reviewer may recommend return of the plan.

Note: CAL FIRE Archaeology staff recognizes the hardship placed upon RPFs and the timberland owners they represent when a submitted plan is returned for serious errors contained in the CAA. In preparing a CAA—particularly the written notifications to Native Americans—any questions regarding the required contents of such notifications and/or whether or not a particular written notification will meet those requirements—should  be directed to the appropriate CAL FIRE Archaeologist by telephone or email PRIOR to submitting the plan. Such pre-filing consultations have been proven to both save time and needless frustration during the review process.
Disclaimer: This document is not intended to be all-inclusive (i.e., it does not attempt to list ALL potential reasons why a CAA and the plan it is part of might be returned.) It simply consists of a list of the most common problems seen by CAL FIRE Archaeology Program staff involved in CAA review.
Revision Schedule:  CAL FIRE plans to regularly update this list as new issues become identified. We welcome suggestions from RPFs to improve its content and usefulness. Send comments to CAL FIRE Senior State Archaeologist Richard Jenkins at rich.jenkins@fire.ca.gov

 


 

Report Revision Steps

CE – The required signature of either the RPF or the Archaeological Surveyor is missing.
CE – The correct name of the county within which the plan is located was omitted.

CE – Incorrect legal descriptions used (e.g., incorrect township/range &/or section numbers used; omission of the correct baseline and meridian name).
CE – Incomplete or incorrect information such as project acreage or correct name of USGS 7.5’ Quadrangle.

RI – Records Check Request Map does not include the entire area of the proposed plan. (The entire acreage included within the plan area must be addressed in the Records Check.) 
RI – The Records Check was conducted more than five years prior to submission of the plan. (A “Current Archaeological Records Check” in Section 895.1 of the Rules is defined as one that was conducted within five years prior to the date a plan was submitted to CAL FIRE for review.)
PRI – Failure to include required information such as a copy of the Archaeological Records Check Request Form which includes the Confidentiality Agreement signed by the RPF (or person requesting the records check) or failure to include a copy of the records check results map provided by the Information Center.

RI – One or more of the contents required to be included in the Native American written notifications are missing. (CAL FIRE has posted sample written plan notifications on its Archaeology Program Web Site to assist RPF’s in ensuring that all required elements are included in such notifications. RPFs are encouraged to utilize these sample notifications and adapt them as necessary. However, given the importance of providing adequate written notification about proposed timber harvesting plans to Native Americans, when required elements are missing CAL FIRE has no option but to return the plan until documentation of adequate Native American notification is received.
RI – The most recent version of the CAL FIRE Native American Contact List (NACL) was not used. This List, posted on the CAL FIRE Archaeology Program Web Site, is revised at least twice annually. It is the CAA preparer’s responsibility to use the most current version of the List available at the time the written notification to Native Americans is prepared. 
RI – Insufficient response time provided. The Rules specify that Native American groups and individuals be provided a minimum of 10 days to respond to a written notification of preparation of a plan. Plans submitted to CAL FIRE prior to the conclusion of the 10 day period will be returned unless the RPF or CAA submitter provides documentation of contact with telephone, email or in-person with a representative of each named Native American group and/or individual whose contact information is included on the applicable portion of the NACL prior to the conclusion of the 10 day period.
RI – Failure to provide sample copies of the written notifications sent to Native Americans—including copies of the maps that accompanied the written notifications.
CE – Failure to include a “No reply received as of…” date (if no replies to the written notifications were received prior to plan submittal).

RI – Failure to adequately document the pre-field research effort conducted prior to beginning the archaeological survey documented in the CAA.
CE – Failure to include the name of at least one knowledgeable person who was consulted about sites that may be located within the plan area.
CE – Failure to include citations of the specific articles reviewed in the Reference Manual and Study Guide for the CAL FIRE-CLFA Archaeological Training Program For Registered Professional Foresters and Other Resource Professionals and/or Volume 8: California of the Handbook of North American Indians (1978); simply listing one or both of these volumes by title is insufficient.
CE – Failure to address potential sites identified in the records check results letter or other pre-field research (e.g., roads/trails/buildings shown on historic maps, reported Native American village sites, previously recorded sites, etc.).
CE – Failure to include a list of the types of sites expected to be found within the plan area, based upon the pre-field research that was conducted.

RI – Failure to include documentation of the archaeological surveyor’s current CAL FIRE-provided archaeological site recognition training.
CE – Failure to include the name(s) of those individuals who conducted previous archaeological surveys within the plan area.

RI – Failure to include a description of attempts to re-locate archaeological sites recorded within the plan area identified in the archaeological records check response from the Information Center.
CE – Failure to provide sufficient information for CAL FIRE staff to evaluate the adequacy of the survey effort (e.g., the survey strategy(ies) used, time spend conducting the field survey, the date or dates of the field survey, survey coverage intensity and/or ground visibility)..
CE – Failure to adequately describe the survey strategies used during the archaeological survey. Terms used to describe survey strategies must be consistent with those described in Instructions for Completing CAL FIRE’s CAA Report Form (available on the CAL FIRE Archaeology Program Web Site) (i.e., “complete, general, intuitive, and cursory”).

RI – Failure to include a description of each archaeological and/or historical site known to exist within the site survey area (i.e., any site mentioned in the archaeological records check response letter, tribal response letters and/or other sources attached to the CAA such as General Land Office (GLO) plats. ALL sites—not just significant ones or newly-discovered sites—within the plan area are to be described, including their size, type and condition.)  
CE – Failure to provide sufficient information for CAL FIRE staff to evaluate the adequacy of the survey effort (e.g., the survey strategy(ies) used, time spend conducting the field survey, the date or dates of the field survey, survey coverage intensity and/or ground visibility).

CAL FIRE has not encountered frequent problems with Part 8 of the CAA recently.

CE – Failure to present the proposed protection measures in clear enforceable language.  
CE – Failure to include consideration of the area(s) within 100 feet of site boundaries in proposed protection measures.

CAL FIRE has not encountered frequent problems with Part 10 of the CAA recently.

RI – Failure to include completed historical resource records (“site records”) for each significant site identified within the site survey area.  
CE – The following are errors frequently observed on completed historical resource records (“site records”):

  • Incorrect pagination. Each page of the historical resource record package must contain the page number (placed on the top left) and site name (top right). Pagination of all parts of the record should be continuous. (For example, if a record package includes a Primary Record, Archaeological Site Record, Photographic Record, Location Map and Site Map the pagination would begin with the Primary Record as “Page 1 of 5”, the Archaeological Site Record would be “Page 2 of 5”, etc.)
  • The Location Map must consist of a clean 1:1 scale copy of the appropriate portion of the applicable USGS Quadrangle (NOT a copy of the Archaeological Survey Coverage Map or the THP/NTMP map) and must show the location of the site being recorded only. The site boundary/boundaries must be clearly marked.
  • Primary Record Section P1: “Resource Name” – Insert the Site Name (i.e., the name of the site already assigned to it by a previous recorder or the site name given a recently recorded site by the recorder).
  • Primary Record Section P2: Place an “X” next to “Confidential”. (The use of the accompanying option—“Unrestricted” is used for publicly owned buildings and structures.)
  • Primary Record Section P2d: UTM Coordinates. Northing coordinates must contain seven digits and Easting Coordinates six digits; provide two sets of coordinates for linear features and four sets of coordinates for sites 10 acres or more in size.
  • Primary Record Section P2e: This statement must contain a description that will permit someone unfamiliar with the site to easily find it in the future. For future management purposes, directions as to how to find the site must be sufficiently detailed to allow someone unfamiliar with the site to find it.
  • Primary Record Section P3a: Information in this section must include—at a minimum—the site type, contents (artifacts and features), size and condition—especially if the Primary Record stands alone without resource-specific detailed records such as a completed Archaeological Site Record. Since you, as the site recorder, may be the only person who will scientifically inspect this site, providing a good, thorough description of the site and its surroundings in this section of the Primary Record is critical.
  • Primary Record Section P4: If a building or structure is not habitable or useable, then it is an archaeological site; archaeological ruins of historic buildings or structures are classified as sites.
  • Primary Record Section P11: List the name of the CAA author, date the CAA was completed and the CAA title and partially complete the THP number (e.g., THP _-__-___ ___); the CAL FIRE archaeological reviewer will complete the THP number prior to sending a copy of the completed CAA (after plan approval) to the appropriate Information Center.

CAL FIRE has not encountered frequent problems with Part 12 of the CAA recently.

RI – Failure to include an Archaeological Coverage Map at a 1:1 scale equivalent to that of a 7.5’ USGS topographic Quadrangle.
CE- Failure to include on the Archaeological Coverage Map depictions of the various survey intensity(ies) utilized during the archaeological survey.
CE- Failure to include on the Archaeological Coverage Map the labeled locations of all of the archaeological and historical sites identified within the site survey area—both those sites that were previously recorded as well as those that were discovered and recorded during survey effort documented in the CAA.