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California Department of General Services Resources Building Replacement Project Draft EIR 4.12-1

CULTURAL RESOURCES AND TRIBAL CULTURAL RESOURCES

Cultural resources are buildings, structures, objects, sites, landscapes, or districts that are important for historical, scientific, or religious reasons and are of concern to cultures, communities, groups, or individuals. Cultural resources may include buildings and architectural remains, archaeological sites, or other artifacts that provide evidence of past human activity. There are specific definitions for historical resources, archeological resources, and tribal cultural resources provided in CEQA, and these are provided in below in Section 4.12.1, “Regulatory Background.”

This section describes the regulatory setting and existing conditions related to cultural resources at the Resources Building Replacement Project (project) site. Historic and prehistoric background information is presented below so that cultural resources associated with this project area may be understood within their appropriate context. Impacts associated with the project are identified.

4.12.1 Regulatory Background

FEDERAL PLANS, POLICIES, REGULATIONS, AND LAWS

Section 106 of the National Historic Preservation Act Section 106 of the National Historic Preservation Act (NHPA) (Title 54 of the United States Code, Section 306108 [USC 54 306108]) does not apply specifically to the proposed project because it is not funded in whole or in part by a Federal agency. However, it is discussed in this section because it establishes criteria for determining eligibility for listing in the National Register of Historic Places (NRHP).

Federal protection of resources is legislated by (a) the NHPA (54 USC 300101 et seq., (b) the Archaeological Resource Protection Act of 1979, and (c) the Advisory Council on Historical Preservation. These laws and organizations maintain processes for determination of the effects on historical properties eligible for listing in the NRHP.

Section 106 of the NHPA and accompanying regulations (36 Code of Federal Regulations [CFR] Part 800) constitute the main federal regulatory framework guiding cultural resources investigations and require consideration of effects on properties that are listed in, or may be eligible for listing in the NRHP. The NRHP is the nation’s master inventory of known historic resources. It is administered by the National Park Service and includes listings of buildings, structures, sites, objects, and districts that possess historic, architectural, engineering, archaeological, and cultural districts that are considered significant at the national, state, or local level.

The formal criteria (36 CFR Section 60.4) for determining NRHP eligibility are as follows:

1) The property is at least 50 years old (however, properties under 50 years of age that are of exceptional importance or are contributors to a district can also be included in the NRHP);

2) It retains integrity of location, design, setting, materials, workmanship, feeling, and associations; and

3) It possesses at least one of the following characteristics:

A Association with events that have made a significant contribution to the broad patterns of history (events).

B Association with the lives of persons significant in the past (persons).

Cultural and Tribal Cultural Resources Ascent Environmental

California Department of General Services 4.12-2 Resources Building Replacement Project Draft EIR

C Distinctive characteristics of a type, period, or method of construction, or represents the work of a master, or possesses high artistic values, or represents a significant, distinguishable entity whose components may lack individual distinction (architecture).

D Has yielded, or may be likely to yield, information important to prehistory or history (information potential).

Listing in the NRHP does not entail specific protection or assistance for a property but it does guarantee recognition in planning for federal or federally-assisted projects, eligibility for federal tax benefits, and qualification for federal historic preservation assistance. Additionally, project effects on properties listed in the NRHP must be evaluated under CEQA.

The National Register Bulletin also provides guidance in the evaluation of archaeological site significance. If a heritage property cannot be placed within a particular theme or time period, and thereby lacks “focus,” it is considered not eligible for the NRHP. In further expanding upon the generalized NRHP criteria, evaluation standards for linear features (such as roads, trails, fence lines, railroads, ditches, flumes, etc.) are considered in terms of four related criteria that account for specific elements that define engineering and construction methods of linear features: (1) size and length; (2) presence of distinctive engineering features and associated properties; (3) structural integrity; and (4) setting. The highest probability for NRHP eligibility exists within the intact, longer segments, where multiple criteria coincide.

STATE PLANS, POLICIES, REGULATIONS, AND LAWS

California Environmental Quality Act CEQA requires public agencies to consider the effects of their actions on “historical resources,” “unique archaeological resources,” and “tribal cultural resources.” Pursuant to Public Resources Code Section 21084.1 (PRC 21084.1), a “project that may cause a substantial adverse change in the significance of an historical resource is a project that may have a significant effect on the environment.” Section 21083.2 requires agencies to determine whether proposed projects would have effects on unique archaeological resources. Sections 21084.2 and 21084.3 apply to effects on tribal cultural resources.

Historical Resources “Historical resource” is a term with a defined statutory meaning (PRC 21084.1); determining significant impacts to historical and archaeological resources is described in the State CEQA Guidelines, Sections 15064.5[a] and [b]). Under State CEQA Guidelines Section 15064.5(a), historical resources include the following:

1) A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (CRHR) (PRC 5024.1).

2) A resource included in a local register of historical resources, as defined in PRC 5020.1(k) or identified as significant in a historical resource survey meeting the requirements of PRC 5024.1(g), will be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant.

3) Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be a historical resource, provided the lead agency’s determination is supported by substantial evidence in light of the whole record. Generally, a resource will be considered by the lead agency to be historically significant if the resource meets the criteria for listing in the CRHR (PRC 5024.1), including the following:



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 construction, 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.

4) The fact that a resource is not listed in or determined to be eligible for listing in the CRHR, not included in a local register of historical resources (pursuant to PRC 5020.1(k)), or identified in a historical resources survey (meeting the criteria in PRC 5024.1(g)) does not preclude a lead agency from determining that the resource may be an historical resource as defined in PRC 5020.1(j) or 5024.1.

Unique Archaeological Resources CEQA also requires lead agencies to consider whether projects will impact unique archaeological resources. PRC 21083.2, subdivision (g), states that unique archaeological resource means 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.

Tribal Cultural Resources CEQA also requires lead agencies to consider whether projects will impact tribal cultural resources. PRC 21074 states the following:

a) “Tribal cultural resources” are either of the following:

1) Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either of the following:

A) Included or determined to be eligible for inclusion in the CRHR.

B) Included in a local register of historical resources as defined in subdivision (k) of Section 5020.1.

2) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Section 5024.1. In applying the criteria set forth in subdivision (c) of Section 5024.1 for the purposes of this paragraph, the lead agency shall consider the significance of the resource to a California Native American tribe.

b) A cultural landscape that meets the criteria of subdivision (a) is a tribal cultural resource to the extent that the landscape is geographically defined in terms of the size and scope of the landscape.

c) A historical resource described in Section 21084.1, a unique archaeological resource as defined in subdivision (g) of Section 21083.2, or a “nonunique archaeological resource” as defined in subdivision (h) of Section 21083.2 may also be a tribal cultural resource if it conforms with the criteria of subdivision (a).



California Register of Historical Resources All properties in California that are listed in or formally determined eligible for listing in the NRHP are automatically listed in the CRHR. The CRHR is a listing of State of California resources that are significant within the context of California’s history. The CRHR is a statewide program of similar scope and with similar criteria for inclusion as those used for the NRHP.

A historical resource must be significant at the local, state, or national level under one or more of the criteria defined in the California Code of Regulations (CCR) Title 14, Chapter 11.5, Section 4850 et seq. to be included in the CRHR. The CRHR criteria are similar to the NRHP criteria and are tied to CEQA because any resource that meets the criteria below is considered a significant historical resource under CEQA. As noted above, all resources listed in or formally determined eligible for the NRHP are automatically listed in the CRHR.

The CRHR uses four evaluation criteria:

1 Is associated with events or patterns of events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States.

2 Is associated with the lives of persons important to local, California, or national history.

3 Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of a master, or possesses high artistic values.

4 Has yielded, or has the potential to yield, information important to the prehistory or history of the local area, California or the nation.

Similar to the NRHP, a resource must meet one of the above criteria and retain integrity. The CRHR uses the same seven aspects of integrity as the NRHP.

Public Resources Code, Section 5024 and 5024.5 The California State Legislature enacted PRC 5024 and 5024.5 as part of a larger effort to establish a state program to preserve historical resources. These sections of the code require state agencies to take a number of actions to ensure preservation of state-owned historical resources under their jurisdictions. These actions include evaluating resources for NRHP eligibility and California Historical Landmark (CHL) eligibility; maintaining an inventory of eligible and listed resources; and managing these historical resources so that that they will retain their historic characteristics. PRC 5024 requires State agencies to evaluate whether a state-owned building is eligible for inclusion in the Master List of State-Owned Historical Resources. PRC 5024.5 requires the State agency to consult with the State Historic Preservation Officer (SHPO) before a State-owned building on the master list is to be altered, transferred, relocated or demolished.

California Native American Historical, Cultural, and Sacred Sites Act The California Native American Historical, Cultural, and Sacred Sites Act applies to both state and private lands. The Act requires that upon discovery of human remains, construction or excavation activity cease and the County coroner be notified. If the remains are of a Native American, the coroner must notify the Native American Heritage Commission (NAHC), which notifies and has the authority to designate the most likely descendant (MLD) of the deceased. The Act stipulates the procedures the descendants may follow for treating or disposing of the remains and associated grave goods.

Health and Safety Code, Sections 7052 and 7050.5 Section 7052 of the Health and Safety Code states that the disturbance of Native American cemeteries is a felony. Section 7050.5 requires that construction or excavation be stopped in the vicinity of discovered human remains until the coroner can determine whether the remains are those of a Native American. If determined to be Native American, the coroner must contact the NAHC.



Assembly Bill 52 Assembly Bill (AB) 52, signed by the California Governor in September of 2014, establishes a new class of resources under CEQA: “tribal cultural resources.” It requires that lead agencies undertaking CEQA review must, upon written request of a California Native American tribe, begin consultation once the lead agency determines that the application for the project is complete, prior to the issuance of a NOP of an EIR or notice of intent to adopt a negative declaration or mitigated negative declaration. AB 52 also requires revision to CEQA Appendix G, the environmental checklist. This revision would create a new category for “tribal cultural resources.” CEQA Sections 21084.2 and 21084.3 apply to effects on tribal cultural resources.

LOCAL PLANS, POLICIES, REGULATIONS, AND LAWS The Resources Building Replacement Project is located on State-owned property, has been authorized and funded by the State of California through the State Projects Infrastructure Fund, and would be implemented by the California Department of General Services (DGS). As explained in Section 4.2 “Land Use” of this DEIR, under Section 4.2.1 “Local Plans, Policies, Regulations, and Laws,” State agencies are not subject to local plans, policies, and zoning regulations. Nevertheless, in the exercise of its discretion, DGS does reference, describe, and address local plans, policies, and regulations that are applicable to the project. This evaluation is also intended to be used by local agencies for determining, as part of their permit processes, the project’s consistency with local plans, policies, and regulations.

City of Sacramento 2035 General Plan The following goal and policies from the City of Sacramento 2035 General Plan Historic and Cultural Resources Element are relevant to the analysis of effects on cultural resources.

Goal HCR 2.1: Identification and Preservation of Historic and Cultural Resources. Identify and preserve the city’s historic and cultural resources to enrich our sense of place and our understanding of the city’s prehistory and history.

Policy HCR 2.1.1: Identification. The City shall identify historic and cultural resources including individual properties, districts, and sites (e.g., archaeological sites) to ensure adequate protection of these resources.

Policy HCR 2.1.2: Applicable Laws and Regulations. The City shall ensure compliance with City, State, and Federal historic preservation laws, regulations, and codes to protect and assist in the preservation of historic and archaeological resources, including the use of the California Historical Building Code as applicable. Unless listed in the Sacramento, California, or National registers, the City shall require discretionary projects involving resources 50 years and older to evaluate their eligibility for inclusion on the California or Sacramento registers for compliance with the California Environmental Quality Act.

Policy HCR 2.1.3: Consultation. The City shall consult with appropriate organizations and individuals (e.g., California Historical Resources Information System (CHRIS) Information Centers, the Native American Heritage Commission (NAHC), the CA Office of Planning and Research (OPR) “Tribal Consultation Guidelines,” etc.,) and shall establish a public outreach policy to minimize potential impacts to historic and cultural resources.

Policy HCR 2.1.5: National, California, and Sacramento Registers. The City shall support efforts to pursue eligibility and listing for qualified resources including historic districts and individual resources under the appropriate National, California, or Sacramento registers.

Policy HCR 2.1.7: Historic Resource Property Maintenance. The City shall encourage maintenance and upkeep of historic resources to avoid the need for major rehabilitation and to reduce the risks of demolition, loss through fire or neglect, or impacts from natural disasters.



Policy HCR 2.1.11: Compatibility with Historic Context. The City shall review proposed new development, alterations, and rehabilitation/remodels for compatibility with the surrounding historic context. The City shall pay special attention to the scale, massing, and relationship of proposed new development to surrounding historic resources.

Policy HCR 2.1.12: Contextual Features. The City shall promote the preservation, rehabilitation, restoration, and/or reconstruction, as appropriate, of contextual features (e.g., structures, landscapes, street lamps, signs) related to historic resources.

Policy HCR 2.1.15: Demolition. The City shall consider demolition of historic resources as a last resort, to be permitted only if the rehabilitation of the resource is not feasible, demolition is necessary to protect the health, safety, and welfare of its residents, or the public benefits outweigh the loss of the historic resource.

Policy HCR 2.1.16: Archeological & Cultural Resources. The City shall develop or ensure compliance with protocols that protect or mitigate impacts to archaeological and cultural resources including prehistoric resources.

Policy HCR 2.1.17: Preservation Project Review. The City shall review and evaluate proposed development projects to minimize impacts on identified historic and cultural resources, including projects on Landmark parcels and parcels within Historic Districts, based on applicable adopted criteria and standards.

The following goal and policy from the City of Sacramento 2035 Land Use Element are relevant to the analysis of effects on cultural resources.

Goal LU 1.1: Growth and Change. Support sustainable growth and change through orderly and well-planned development that provides for the needs of existing and future residents and businesses, ensures the effective and equitable provision of public services, and makes efficient use of land and infrastructure.

Policy LU 2.4.2: Responsiveness to Context. The City shall require building design that respects and responds to the local context, including use of local materials where feasible, responsiveness to Sacramento’s climate, and consideration of cultural and historic context of Sacramento’s neighborhoods and centers.

City of Sacramento Landmark Ordinances Codified in Title 17 of the City Code, the City of Sacramento compiles ordinances adopted by the City Council to add or delete individual landmarks, historic districts, and contributing resources to the Sacramento Register of Historic & Cultural Resources. Resources included in the register are historical resources for the purposes of CEQA.

4.12.2 Existing Conditions

PROJECT SITE The project site, located on the two blocks between 7th and 8th and O and P Streets and 7th and 8th and N and O Streets in downtown Sacramento (Exhibit 4.12-1). The proposed office building site is the block bounded by 7th and 8th Streets and O and P Streets (referred to as the P Street Block). The approximately 2.5-acre block is currently occupied by a surface parking lot and the Heilbron House, a historical resource. The Heilbron House is located on the northwest corner of the block at 704 O Street and is the only extant building on the block. The house was designed by Nathaniel Goodell in the Italianate style for August Heilbron in 1881. The Heilbron House is described further below.



Exhibit 4.12-1 Project Study Area



The State’s Employment Development Department (EDD) Subterranean Building, referred to in this EIR as the “Subterranean Building,” is located immediately north of the P Street Block. This block, between 7th and 8th and N and O Streets, comprises the second of the two blocks that make up the project site. The Subterranean Building would not be removed as part of the proposed project. Temporary construction offices could be placed on the roof plaza of the building and limited equipment and vehicle staging could occur consistent with the load bearing capacity of the roof. The project also proposes placement of portable structures to provide a child care facility for 60 to 70 children on the roof plaza of the Subterranean Building. Neither the temporary use of the roof for construction staging nor the long-term use for child care facilities would alter normal activity in the Subterranean Building.

STUDY AREA

Archaeological Resources Study Area The primary study area for the archaeological resources evaluation consists of the project site described above. However, an archival and literature search encompassing a 1/8th-mile radius around the project site was performed on May 3rd, 2017 at the North Central Information Center (NCIC) of the California Historical Resources Information System, housed at California State University, Sacramento. The record search included a review of site location base maps and other records on file at the NCIC, listings in the NRHP (National Park Service 1998), California Inventory of Historic Resources (California Department of Parks and Recreation 1976), California Historical Landmarks (California Department of Parks and Recreation 1996), and California Points of Historical Interest (1992 and updates) (California Department of Parks and Recreation 1992). Archival research was conducted using Sandborn Fire Insurance Maps available at the Sacramento Public Library. Additional field reconnaissance of the project site was conducted January 24, 2017. Geotechnical borings were monitored March 11th, 2017.

Digging test pits at the project site was not feasible because the site is developed with buildings, parking lots, and facilities. However, archival, aerial, and satellite imagery indicate that no significant earth moving occurred between the demolition of the original buildings and structures and the installation of the present-day facilities. This suggests that there was limited potential for disturbance of potential subsurface features.

Historic Architecture Study Area The study area for the historic architecture evaluation (Exhibit 4.12-1) encompasses the blocks within the project site to address direct impacts. For indirect impacts, the study area includes the buildings on each block located across the street from the project site. The overall study area is bounded by 9th Street on the east, Q Street on the south, 6th Street on the west, and N Street on the north between 6th and 9th Streets, and the alley behind N Street between 7th and 8th Streets (to capture 751 N Street). Buildings located in the study area are identified in Table 4.12-1.

Table 4.12-1 Buildings Located in the Study Area Address Building Name Year Built

1500 7th Street Capitol Towers 1964

750-751 N Street Employment Development Department (EDD) Solar-Subterranean Building Complex

1983

800 N Street Stanford Mansion 1857; 1871

704 O Street Heilbron House 1881

714 P Street Office Building No. 8 1970

744 P Street Office Building No. 9 1970

1416 9th Street Resources Building 1965

806 O Street Capital Athletic Club (former Klumpp Mortuary Building) 1939



Table 4.12-1 Buildings Located in the Study Area Address Building Name Year Built

1600 9th Street Bateson Building 1981

1516 9th Street Energy Resources Conservation and Development Building 1983

625 Q Street DGS Central Plan 1968/Complete renovation 2010 Note: regarding nomenclature: For the purposes of this analysis, buildings will be named according to their current, rather than their original/historic name. Whenever possible, former names will be noted.

REGIONAL PREHISTORY The project site is in the southern end of California’s Sacramento Valley, in downtown Sacramento. The City of Sacramento was developed near the confluence of the American River and the Sacramento River. The low-lying region was prone to winter flooding. Historic maps and other materials identify the general project study area as being near the edge of a marsh, thus indicating slightly higher ground. High ground near marshes or other freshwater environments was ideal for resource extraction by Native Americans. For this reason, coupled with the generally benign weather in the region, the general project area has a high likelihood of subsurface prehistoric resources (Hamilton et al 2005).

Archaeological Setting The earliest presence of humans in California dates to the Paleo-Indian Period (10,000–6000 before the current era [BCE]) of the Late Pleistocene. People lived in small and highly mobile bands, hunting and gathering along ancient pluvial lakeshores and coastlines. Such behavior has been evidenced by fluted projectile points and chipped stone crescent forms (Fredrickson 1973; Moratto 1984).

Few archaeological sites have been found in the Sacramento Valley that date to the Paleo-Indian or the subsequent Lower Archaic (6000–3000 BCE) time periods. This may be because of high sedimentation rates at the confluence of the Sacramento and American rivers, leaving the earliest sites deeply buried and inaccessible. Archaeologists have recovered a great deal of data from sites occupied by the Middle Archaic Period (3000–1000 BCE).

In the Sacramento region, the Windmiller Pattern dates to the Middle Archaic Period. The Windmiller Pattern is recognized by an increased emphasis on acorns, a continuation of hunting and fishing activities, as well as more intensive procurement practices. Ground and polished charmstones, twined basketry, baked-clay artifacts, and worked shell and bone are hallmarks of Windmiller culture. Widely ranging trade patterns brought goods in from the Coast Ranges and trans-Sierran sources, as well as closer trading partners. Distinctive burial practices (ventrally extended, oriented westward) identified with the Windmiller Pattern also appeared in the Sierra Nevada foothills, indicating possible seasonal migration into the Sierra Nevada (Stevens et al 2009).

Sociopolitical complexity continues through the Upper Archaic Period (1000 BCE–500 into the current era [CE]). Formalized and regular sustained trade between groups are demonstrated for the first time. Assemblages dating to this period in the lower Sacramento Valley are consistent with the Berkeley Pattern. Distinguished by distinctive stone and shell artifacts and a reliance on acorns as a food source. Flex burials accompanied with red ocher predominated. Minimally shaped mortar and pestle technology was much more prevalent than the mano/metate, and nonstemmed projectile points became more common. Berkeley traits may have developed in the San Francisco Bay area and were spread through the migration of Plains Miwok Indians (Bennyhoff and Fredrickson 1969).

Significant technological and social developments characterized the Emergent Period (CE 500–1800). The introduction of the bow and arrow ultimately replaced the dart and atlatl. Distinctions in an individual’s social status could be linked to acquired wealth. Later in this period (CE 1500–1800), highly regularized and



sophisticated exchange relations utilized the clamshell disk bead as a monetary unit. Various aspects of material goods production and exchange as well as inter and intra-group rituals were regulated by specialists. Territorial boundaries between ethno-linguistic groups encountered at the time of European contact became well established (Hamilton et al. 2005).

The Emergent Period in the lower Sacramento Valley is represented by the Augustine Pattern (Bennyhoff and Fredrickson 1969), a widespread central California pattern assigned to the Late Horizon. Cultural evolution may have been stimulated by the southern migration of Wintuan people from north of the Sacramento Valley. Food procurement strategies, as well as trade activities intensify along with fishing, hunting, and gathering. Complex exchange systems, and a wider variety in mortuary practices including cremation for some high-status individuals are hallmarks of this pattern.

Initial work in the Sacramento region, from the 1950s and earlier, generally indicates that the northern portion of the Sacramento Valley was culturally more closely affiliated with the Shasta/Oroville area. The associations between the cultures of the southern Sacramento Valley, northern San Joaquin Valley and the Sacramento-San Joaquin Delta became apparent during the 1950s and 1960s.

While the problem of alluvial deposition covering older sites has been discussed in relation to Sacramento Valley archaeology (Moratto 1984), numerous sites in the Sacramento region have been identified and excavated, guiding archaeologists toward a more refined interpretation of local cultural patterns. Most recently, excavations in downtown Sacramento in 2004 and 2005 (the City Hall Site at Ninth and I streets, another on H Street) recovered artifacts more than 15 feet below street level at the Ninth Street site, but have also demonstrated that prehistoric sites (including human remains) can be found just a few feet below the current street grade (Farris and Tremaine 2008).

Ethnographic Setting The area east of the Sacramento River between modern Sacramento and Marysville was inhabited by the eastern Valley Nisenan. In the Sacramento Valley, the tribelet, consisting of a primary and a few satellite villages, served as the basic political unit (Moratto 1984). Permanent settlements were often populated by over one hundred people, living in earthen, tule, grass, or bark structures, concentrated on raised ground near water. Valley Nisenan territory was divided into three tribelet areas, each populated with several large villages (Kroeber 1925). Momol and Sama are two such villages, recorded historically in the vicinity of the project site.

Valley Nisenan people gathered a wide variety of food resources year round, but hunting and gathering activities were at their most intense in late summer and early fall. Food staples included acorns, buckeyes, pine nuts, hazelnuts, various roots, seeds, mushrooms, greens, berries, and herbs. Preferred game included mule deer, elk, antelope, black bear, beaver, squirrels, rabbits, and other small animals and insects. Salmon, whitefish, sturgeon, and suckers, as well as freshwater shellfish, were also caught for food (Kroeber 1925). Descendants of these indigenous people are contemporarily organized as the Federally-recognized Wilton Rancheria, United Auburn Indian Community of the Auburn Rancheria, and the Shingle Springs Rancheria.

REGIONAL HISTORY

European and American Settlement California was visited by every major European naval power, but was claimed by the Spanish Empire ca. 1602. The first California mission was established in 1769, in San Diego. Over the next 50 years, the Spanish government with the aid of various Roman Catholic orders established 21 missions throughout “Alta California.” Lieutenant Gabriel Moraga and 13 soldiers traveled to the Sacramento Valley from Mission San Jose in 1808, but reported that the area would not be suitable for a mission site. However, a member of the expedition, enamored with the trees and the rivers, compared the region’s beauty to the Catholic Eucharist, or sagrado sacramento.



Mexico’s independence from Spain in 1822 resulted in the secularization of the missions, in part to limit influence of Roman Catholics loyal to Spain. Foreign fur trappers, primarily Canadian and American, gained a regional foothold. In 1826, Jedediah Smith camped near the present site of California State University, Sacramento, on assignment for the Hudson Bay Company. His success spurred an influx of trappers. They depleted the area until the early 1840s, when hunting and trapping were no longer profitable. The rapid influx of European and American trappers caused epidemics of malaria and smallpox that killed thousands of the Patwin and Nisenan people along the Sacramento River. Depopulation of the indigenous people from the project area through disease, relocation, and murder continued during Mexican secularization of Alta California (Lindsay 2012).

The vast northern territory of Alta California lacked the military capacity to protect Mexico’s lucrative interests in the trans-Pacific economy. The Mexican government continued the practice started by Imperial Spain of awarding large land grants to foreign citizens, nominally loyal to Mexico, as a bulwark against competitors in the frontier. John Sutter, born a citizen of Switzerland, was awarded such a land grant by President Juan Bautista Alvarado of Mexico in 1834. His party disembarked at the site of present-day Sutter’s Landing Park on 28th Street August 12, 1839. Sutter had constructed an adobe fort, a settlement he called New Helvetia, by 1841 (now Sutter’s Fort State Park on L and 27th Streets). He immediately disavowed his loyalty to the Mexicans at the initiation of the Mexican-American War in 1846 and raised the Stars and Stripes over New Helvetia.

California was ceded as a territory to the United States following the end of the Mexican-American War in 1848. During that time, the steadily growing population of New Helvetia expanded into the surrounding countryside. The lumber mill built by one of Sutter’s employees, James Marshall, was originally planned to support Sutter’s conceptual city, Sutterville. The Coloma mill yielded gold, instead. Unable to keep news of the gold secret, word reached San Francisco and the rest of the world.

The fort of New Helvetia was steadily abandoned. Sutter’s men and associates were lured away by prospecting. Creditors, assuming Sutter had claim to the gold at Coloma (he did not), forced the Swiss émigré to transfer his holdings to his son, John. John, seeking to pay off his father’s debts, designated four-square miles of the original Mexican land grant as the site for the new town, Sacramento. He sold lots within the new town between $200 and $500 (Hamilton et al. 2005).

The same lots sold for 10 times their original price, and stores, saloons, and gambling houses sprang up to empty the newly filled pockets of the miners arriving at the embarcadero on Front Street. As the commercial center of Sacramento began to favor the riverfront, more and more canvas and semi-permanent structures opportunistically arose. When California was admitted to the Union in 1850 the populace of Sacramento, nearly 12,000 people, had already experienced a disastrous flood. Subsequent floods and fires would shape civil policy and urban planning for the next several decades.

Life in a Modern Capitol

After the discovery of gold in the Sierra Nevada Mountains in 1848, the focus of the small settlement that would become Sacramento was the busy port exchanging goods and passengers between the goldfields in the mountains to the east and the ocean to the west. The emerging town experienced rapid growth, fueled by the boggling riches generated by the region’s gold boom (JRP Historical Consulting, LLC 2013). This development led to the establishment of a modern city in the late nineteenth and early twentieth centuries, replete with thriving commercial and residential areas. The California State Legislature designated Sacramento as the state capital in 1854. (California Department of General Services [DGS] 2016).

While industries supporting the Gold Rush and the growing population of Sacramento boomed, the city itself suffered multiple catastrophes. A fire in 1852, and the floods in 1853, 1854, 1861-1862, and 1878 motivated wealthy members of the city to construct levees, bulwarks, and raised streets to protect people, homes, and businesses (Downey 2010). Between 1862 and 1878 the area bound by the east bank of the Sacramento River, 12th, H and L Streets was systematically raised using convict labor, press gangs, and



private contractors. Bulwarks were constructed with locally-fired bricks and the first stories of many downtown buildings became subterranean. Residents began developing the Project site in the late 1850s and early 1860s. Most residents were born in the United States or Ireland and held jobs such as stage agent, drayman, saloonkeeper, or laborers, as well as government officials. The opening of a grocery store in 1855 by James Lonergan, represents some of the earliest residential and commercial development in Sacramento.

Around 1856, R. L. Jones opened another grocery store on the block at the corner of Seventh and P streets. While changing owners many times, it remained open as a neighborhood market and early commercial hub until sometime after 1951. Although some of the parcels in this block were divided in the 1870s and 1880s, many lots were much larger than those on surrounding blocks, and consequently the block contained fewer homes. Philetus Burnett, a wealthy carpenter, owned the largest lot. In the early 1870s. He was selected to construct staircases for the new Capitol Building. Soon afterwards, he was chosen to become the Capitol construction superintendent and would oversee completion of the building.

The 1870s brought more residents and more construction. Adolph Heilbron, who, with his brother Augustus, made a fortune in cattle and butchering operations, settled at the corner of Seventh and O streets in 1871 with his wife Louisa and their children. Nelson Slater, who later became school superintendent for Sacramento County, moved into the old Davenport home. Slater’s 1851 book Fruits of Mormonism, was the first book copyrighted in California. In 1874, a grocery store was established at the corner of Eighth and O streets. The McGinnis family ran this store until almost 1900.

As time went on, the neighborhood continued to change. In the 1880s, there were at least three rental units in previously single-family homes. There were also at least four boarders and/or lodgers renting rooms from families during that decade. Residents were primarily U.S. born citizens, but European and Canadian families were also present. These residents had a variety of skilled and unskilled professions. The 1895 Sanborn map portrays the block as an established neighborhood. Only two possible privies are depicted, and they are associated with homes constructed in the 1850s and 1860s.

By the 1900s, there were just as many renters as there were owners occupying homes in the block. The ethnic makeup remained similar to past decades, with the addition of a Swiss family, and an African American family from Tennessee. Many of the families that originally settled the block, including the Heilbrons, still remained in the 1900s.

Residences north of the alley remained virtually unchanged in 1915, but by 1951 more than half would be demolished, leaving vacant lots. Conversely, many of the homes south of the alley running through the block had been converted into flats or apartments by 1915. Those rentals continued to thrive until the 1950s and 1960s, when the state acquired the property, demolished all structures except for those on the Heilbron parcel, and converted the block into surface parking.

West End Neighborhood Sacramento’s West End neighborhood is among its oldest, laid out as part of the grid established by John J. Sutter in 1848. It extends from the Sacramento River on the west, the State Capitol building at 10th Street on the east, the Southern Pacific Railroad yard on the north, and Y Street (now Broadway) on the south. In the late nineteenth century, the West End was Sacramento’s commercial center and featured some of its most coveted residential addresses. Prominent individuals, such as Leland Stanford, Collis P. Huntington, Mark Hopkins, and Charles Crocker, all had associations with this vicinity (Sacramento Bee 2013). In or adjacent to the study area, two former homes are still extant that date to the late 19th century: The Heilbron House at 704 O Street and the Leland Stanford House at 800 N Street.

Heilbron House August Heilbron arrived in Sacramento in 1855, began work in a family grocery store and soon became successful in the butchering and stock-raising business, eventually owning a 69,000 acre cattle ranch in Fresno (Price 1975). August Heilbron bought the lot with the current address of 704 O Street in 1871. The



first house built on this lot was later moved down O Street to a lot purchased from William Yule. The second house on the 704 O Street lot, build in the Italianate style, was completed in 1885. The architect of the Heilbron House was Nathaniel Goodell. The Heilbron house has undergone a number of alterations. In 1905, second floor sleeping porches were added to the eastern and western elevations. In 1930, there was a fire that damaged the parlor, library, and dining room. After Marie Heilbron died in 1953, the building was converted to Antonia’s Restaurant (later Sadie’s Restaurant). During that time, the front and rear parlors were converted into a cocktail bar and the kitchen was modernized. By 1970, the stairway to the western porch was removed. In 1973, the building went through a major remodel at a cost of $851,000 for the San Diego Federal Savings and Loan Association to convert it to a bank. Some door openings were enlarged and most historic doors removed, but the most noticeable alterations occurred in the basement level where a bank vault was installed. In 1992, the building was converted to a gallery and bookstore operated by the La Raza Galeria Posada, and the most noticeable alterations were the conversion of some of the upper floor rooms to gallery space (DPR 2013).

Stanford House/Mansion Built in 1857 as a two-story structure for prominent businessman Shelton Fogus, the primary elevation originally had five symmetrical bays as designed by architect Seth Babson. The home was sold in 1861 to Leland Stanford, President of the Central Pacific Railroad Corporation, who became California’s eighth governor in January of 1862. In that year, Stanford has a 1-story, 2-room detached brick office built to the east of the house. After serving a two-year term as governor, Stanford returned to private life and traveled frequently on railroad business. The State then rented Stanford’s furnished home for the next governor, Frederick Low. Henry Haight, who succeeded Low as governor, rented Stanford’s office until a new governor’s office was opened in the Capitol in 1869. In an extensive renovation in 1871, the main house and the office were elevated on-site, and the present ground-floor level inserted beneath them, the office was joined to the main building. Among other alterations to enlarge the building, two bays facing north were added to the east side, one was added to the west side, and a Mansard style roof was added (Regnery and Charleton, 1987).

By the 1950s, the West End neighborhood had become overcrowded and was considered a blighted part of the city. The neighborhood contained a mixture of residential and commercial uses. The block upon which the Bateson Building now stands was fully developed with primarily residential structures, including single-family houses, 2-flats, and 4-flats. Within a few blocks, commercial properties included warehouses for the Goodwill Industries and the Shasta Water Company, in addition to many other residences and office buildings (Sanborn Map Company 1952:56).

During the late 1950s and early 1960s a large area of the West End neighborhood was razed and redeveloped, although a two-block-wide sliver adjoining the waterfront survives today as Old Sacramento (DGS 2016).

Urban Renewal in Sacramento Like many other American cities, a marked decline of Sacramento’s downtown neighborhoods began during the Great Depression and was subject to postwar redevelopment policies that favored urban renewal. After World War II, federal funding and loans encouraged families to relocate and build new housing in the emerging suburbs in the green fields outside the city center. Lack of investment, declining property values, and an ebbing tax base all conspired to accelerate the decline of these neighborhoods, including the West End (JRP Historical Consulting, LLC 2013).

Corresponding to these trends, Sacramento responded to this decline by developing a series of plans designed to renew its urban core. The West End neighborhood was the first post–World War II urban redevelopment project in California. It was one of several federally funded redevelopment plans undertaken by the city in the postwar period and throughout the late twentieth century. In 1950, the Sacramento City Council identified “Urban Redevelopment Area No. 1,” which encompasses most of the West End neighborhood. The plan that accompanied it called for demolition of structures that had been identified as sub-standard and included construction of housing. Opposed by some in the business community, this initial



plan was eventually replaced by three separate plans for individual geographies that covered the entire area. These geographies were the “Capitol Mall Project Area No. 2A,” the “Capitol Mall Extension Project Area,” and the “Capitol Mall Riverfront Project Area.” Implementation of these plans began in 1954 and continued in phases throughout the remainder of the 1950s and into the 1960s.

California State Capitol Plan In 1960, the State prepared a California State Capitol Plan to support the growth of State government and to guide development of needed office space in an orderly fashion. This plan focused on the area south of L Street, near the Capitol, and recommended the demolition of the existing buildings and the construction of a new high-rise complex in a park-like setting. Most of the buildings in the area were demolished, and Office Buildings 8 and 9, the Resources Building, and the Central Heating and Cooling Plant were constructed as part of the plan. (DGS 2016)

The entire State Capitol Plan, however, was not built out. By 1975, the State was accommodating office workers in leased space, a costly option. Tasked by the California Legislature with updating the plan in 1976, the DGS engaged a Capitol Plan Advisory Committee, including departmental professional staff and consultants. The primary goal of the committee, as expressed in the Capitol Area Plan, was to consolidate State office functions and workers within buildings owned by the State (DGS 2016).

Resources Building The Resources Building, located at 1416 9th Street, was constructed as part of the State Capitol Plan. The 1965 Commission Annual Report stated that by December of 1964, more than $6 million of property planned for the State Capitol Plan had been acquired by the State, with an additional $9 million of property in the process of acquisition. By the mid-1960s, the State Capitol Plan was underway and development was progressing. On January 8, 1965, the Retirement Building (now the Resources Building), so named because the public employee retirement system loaned the state $15 million to construct the building and moved its staff into the then-new 17-story tower. The Retirement/Resources Building was the first major structure built within the State Capitol Plan area (DGS 2015).

Capitol Area The following context statement is an excerpt in relevant part from the Final Draft State Government Historic Context Statement as printed in the City of Sacramento’s 2035 Master Plan Technical Background Report prepared by Ruth Todd and Meg de Courcy, Page & Turnbull (2014). The context focuses on the development of the area surrounding the Heilbron House. Headings and some text has been added to highlight buildings in the study area. The area is commonly referred to as the Capitol Area because properties are near the State Capitol and is largely characterized by government institution buildings and multi-family apartments:

The expansion of California State Government coincided largely with redevelopment efforts in Sacramento. In fact, the majority of redevelopment efforts were spurred by the presence of the State Government and a desire to present the city as a clean, beautiful, and well-planned State Capital. Efforts in Sacramento were part of a national movement of postwar urban renewal to clean up cities—especially downtown areas (Cohen 2007). The West End neighborhood, located between Tower Bridge on the Sacramento River and the Capitol, was one of the first areas slated for redevelopment. As presented in Architectural Forum in 1959, “Visualize first, one of the strongest and most stable cities in the nation that is also the Capital of the State of California. Visualize too, almost 200 acres of land extending from the existing Central Business District and the State Capital buildings to the Sacramento River to be wiped clean of almost all building and made available for new construction.”

By 1960, the state occupied twenty-three publicly owned buildings (including annexes), and nineteen leased buildings (including offices, special purpose buildings, and warehouses). The state owned 69.8 acres in central Sacramento that included Capitol Park, garages, parking lots, warehouses, and the Governor’s Mansion. Grouping the departments of State Government made it easier for staff to gather for meetings and exchange information. However, as traffic increased in the city and offices became dispersed, the legislature



desired a master plan for the Capitol and state government buildings. In July 1960, the State Legislature created the Capitol Building and Planning Commission, which created the first California State Capitol Plan later that year. The California State Capitol Plan was a physical plan that specified the location and design of buildings, forms, parks, plazas, pedestrian ways, drives, streets, and parking facilities. It focused on the area bound by L Street on the north, Q Street on the south, 7th Street on the west, and 17th Street on the east. To provide greater design flexibility and to accommodate larger programs, the plan promoted the creation of seven superblocks, or pedestrian islands, by closing streets within the plan area to vehicular traffic. Purchase of land within the plan area was encouraged before implementation began and property values increased. The California State Capitol Plan promoted the removal of the State Office Building and Library and Courts buildings in the Capitol Extension area. The California State Capitol Plan envisioned L Street from 7th to 17th Streets as a growing commercial district akin to San Francisco’s Union Square.

Capitol Towers West of 7th Street between N and P Streets, the Capitol Towers project was completed in 1964 (Lastufka 1985). Capitol Towers assembled four blocks to create a ‘super block,’ closing public streets and alleys between the four blocks and demolishing everything on the parcels. Noted San Francisco architectural firm Wurstrer Bernardi & Evans, and landscape architect Lawrence Halprin were hired to create a residential complex of both towers and lower scale multi-family units in a park-like setting. Though some of the original designs were not realized and some modifications have occurred, the complex is relatively intact (Geghard et al 1985).

Central Heating and Cooling Plant and Office Buildings No. 8 and No. 9 Within the study area, the state built completed the Central Heating and Cooling Plant at 625 Q Street in 1968, and two state office buildings in 1970 as part of the first Capitol Plan Area: Office Building No. 8 at 714 P Street and Office Building No. 9 at 744 P Street. A complete renovation of the Central Heating and Cooling Plant was completed in 2010 and almost none of the original facility elements remain.

Capitol Building In the 1970s, the deterioration of the Capitol building and the state government’s need for more space prompted discussion of demolishing the Capitol. Two towers were proposed on the same site as the existing Capitol. In 1974, this plan was struck down in favor of restoring the 1861 Capitol building (California State Capitol Museum 2015). A major project to seismically strengthen the State Capitol was initiated in 1976. Renovation work undertaken to structurally reinforce the entire building—including the dome—cost $68 million and continued until 1982.

Second State Capitol Plan/Capitol Area Plan In 1977, a second California State Capitol Plan, titled the Capitol Area Plan (CAP) was drafted to update the 1960 Capitol Plan. As the 1977 CAP explained, the State had purchased lands south of L Street and demolished extant buildings to construct high-rise office buildings within park-like campus settings. The state legislature approved funding for the 1960 Capitol Plan, purchased ninety percent of the land and demolished many of the buildings, reducing the residential population downtown from 4,000 to about 1,000. Two buildings, the Central Heating and Cooling Plant and the State Retirement (Resources) Building, were constructed in the 1960s. Additional cleared sites were used for surface parking lots. However, the election of Governor Ronald Reagan in 1967 and the change in administration caused the 1960 Capitol Plan building program to be curtailed. Rather than build new state government buildings that consolidated governmental departments, the new administration encouraged the State to lease space from the private sector to meet state office needs. In the early 1970s, Reagan’s administration also centralized in Sacramento many state offices which had been regionally based throughout the state, relocating state employees to Sacramento—by 1976, the state was leasing 1,190,000 net square feet of office space at fifty-five office locations in Sacramento, including properties, such as the Julia Morgan-designed Public Market building, which often suffered unfortunate interior remodeling to accommodate the new offices. The 1977 CAP called for the consolidation of these offices in state-owned buildings and revisions to the 1960 Capitol Plan.



Under the 1977 CAP, DGS was appointed as the advisory committee of the Plan. The new plan sought to clarify the relationship of the state to the local city government, coordinate planning efforts, and ensure that the Capitol Area received public services. The state recognized that, as a “major landholder and employer in Sacramento, it had an obligation to ensure that developmental actions be of the highest quality.”

Since 1977, DGS and the Capitol Area Development Authority (CADA), a joint powers authority between the state of California and the City of Sacramento, have administered the CAP to guide smart growth development of the Capitol Area (DGS 2012). CADA was founded in 1978 to “implement the residential and neighborhood commercial objectives of the State Capitol Plan. The organization operates a business model that closely parallels a private real estate management and development company. CADA responds to government mandates, including rebuilding the areas demolished by the 1960 State Capitol Office campus plan.

Bateson Building Opened in May 1981, and located in the study area at 1600 9th Street, the Bateson Building (also known as the Bateson State Building or the Gregory Bateson Building) is considered one of the pre-eminent architectural expressions of 1970s era environmentalism in California under the administration of Governor Edmund G. “Jerry” Brown. Designed as an energy efficiency demonstration piece by State Architect Sim Van der Ryn, it is an exceptionally significant example of energy efficient, environmentally sensitive architecture applied to a state government office building. (DGS 2016)

EDD Solar-Subterranean and Energy Resources Conservation and Development (Energy Commission) Buildings In 1983, the state constructed a solar annex and subterranean building for the Employment Development Department at 750 and 751 N Streets. Benham-Blair and Associates designed the Solar-Subterranean Building as part of Governor Jerry Brown’s newly initiated building program, with the objective of consolidating State offices into government-owned facilities within the capitol area neighborhood. Brown appointed Sim Van der to State Architect in 1976 and tasked him to participate in the development of a State building plan, a primary objective of which was to reduce the seeming scale of the large office buildings and as a result create a more humane, user-oriented environment. Coupled with a more humane approach to the working environment was the plan to construct new positive examples of state office buildings that represent energy efficiency. The Solar-Subterranean Building was among the four buildings included in this endeavor (the three others were Bateson, Bonderson, and Energy Commission Buildings). The Solar-Subterranean Building consists of two connected buildings, the six-story Solar Annex portion located at 751 N Street (which is connected to the EDD Headquarters via sky bridges) and the single-story Subterranean Park Complex located at 750 N Street that connects to the Solar Annex building by way of a walkway beneath N Street.

Energy Resources Conservation and Development Building Designed by Nacht & Lewis, The Energy Resources Conservation and Development Building (Energy Commission Building) at 1516 9th Street shares many of the distinguishing energy-efficiency measures as the Solar-Subterranean Building, including its permanently affixed sun shading elements and metal vertical louvers that block the windows. Daylighting is supported by an internal atrium in the Energy Commission Building.

PROJECT SITE HISTORY

As described above, the project site was initially comprised of private residences within the Capitol Park neighborhood. 20th century development of the project area began as these private residences became boarding houses. Sanborn Fire Insurance maps from 1915 show many of the homes in this upper-class neighborhood with garages for Sacramento’s first autos. However, several other homes on the project site had also been converted to apartments. The residential neighborhood shifted to office buildings for the government bureaucracy during the inter-bellum period.



A considerable portion of the project site has been excavated for modern office construction, much of the archaeological record has likely been removed. This location coincides with the back lots of many of the residences that once occupied the neighborhood. Back lots are often the location where intact historical features are discovered in the form of artifact-filled privies or trash pits. Some back lots on the P Street Block may not have been disturbed during prior construction. However, given the intensive construction of the present-day facilities, the potential to locate undisturbed archaeological resources appears to be low within the project area.

Currently, the project area is surrounded by surface streets, Sacramento Regional Transit Light Rail lines. The P Street Block, the portion of the project site where ground disturbance would occur, consists of a vacant parking lot and the historic Heilbron House. The site was examined during the field investigation portion of the current project. Recent Underground Service Alert markings highlighted the extensive underground utilities present below the surface.

RESULTS OF INFORMATION REVIEW AND CONSULTATION The identification of CEQA cultural resources within the project study area included a review of existing sources of information regarding previously identified cultural resources and consultation with interested parties. The outcome of this review and consultation is described below.

Archaeological Resources

North Central Information Center Results

Cultural-Resources Studies in or Near the Project Site A review of previous surveys and recordation efforts in the vicinity as well as field investigations of the proposed project site was performed. An archival and literature search was completed May 3rd, 2017 at the North Central Information Center (NCIC) of the California Historical Resources Information System (CHRIS), housed at California State University, Sacramento. The record search covered a 1/8th mile radius around the project site and included a review of site location base maps and other records on file at the NCIC, listings in the NRHP (National Park Service 1998), California Inventory of Historic Resources (California Department of Parks and Recreation 1976), California Historical Landmarks (California Department of Parks and Recreation 1996), and California Points of Historical Interest (1992 and updates) (California Department of Parks and Recreation 1992). Archival research was conducted using Sandborn Fire Insurance Maps available at the Sacramento Public Library. Eleven archaeological and historic studies have been conducted within 1/8th mile of the project site. Four of these included portions of the project site (Table 4.12-2).

Table 4.12-2 Results of NCIC Records Search; Studies Performed within 1/8th mile of Project Site. Report Year Author Contains Project Site (Yes/No)

002006 1998 Derr, Eleanor No

003313 2000 John Dougherty, Mary L. Maniery, and Cindy L. Baker No

003313 2000 John Dougherty, Mary L. Maniery, and Cindy L. Baker No

004439 2002 Nettles, Warren, and Hamilton No

008513 2007 Adrian Praetzellis No

009673 2004 Ric Windmiller Yes

009999 2008 Carolyn Losee No

011406 2014 Jeremy Adams and Stephen Pappas Yes

011478 2014 Cindy L. Baker No



Table 4.12-2 Results of NCIC Records Search; Studies Performed within 1/8th mile of Project Site. Report Year Author Contains Project Site (Yes/No)

011509 2014 Jeremy Adams and Stephen Pappas Yes

011675 2014 Christopher McMorris and Chandra Miller Yes

Known Cultural Resources in or Near the Project Site Three archaeological resources are known to exist within the 1/8th mile record search area. One, an extensive historic-era resource excavated in the 1970’s, is across 8th Street from the project site. A second resource, extending from 3rd to 7th Street, and including portions of Q, R, and S Streets, was excavated during the construction of the CalPERS Headquarters Building. The historic sites included dozens of historic features. Similarly crowded historic blocks are located throughout Sacramento.

The third resource near the project site was recorded in the 1930’s and is located near the intersection of 10th and P Streets; this is a prehistoric site but otherwise no information is recorded. There are likely many more prehistoric sites in the downtown Sacramento area that have not yet been uncovered. Construction in 2008 near the historic Folsom Power Station in downtown Sacramento (between G, 6th, H, and 7th Streets) revealed multiple Native American burials and possible cremations (Farris and Tremaine 2008).

Consultation Efforts During project planning, a Native American contact program was initiated pursuant to California Assembly Bill 52. An electronic communication dated December 5, 2016 requested from the NAHC a search of the Sacred Lands Database managed by the NAHC. Eight Tribal contacts identified by the NAHC were sent letters dated December 12, 2016 regarding construction at the project site. The United Auburn Indian Community of the Auburn Rancheria (United Auburn) responded by letter dated January 4, 2017 indicating that the project area is within the tribal territory of their ancestors and requesting consultation pursuant to AB 52. The consultation is underway.

Wilton Rancheria (Wilton) also responded by letter dated December 20, 2016 indicating that the project area is within the tribal territory of their ancestors. Wilton further requested results of any archival, archaeological, and geotechnical reporting on the project location. Therefore, CHRIS results were transmitted electronically January 5, 2017.

The Shingle Springs Band of Miwok Indians (Shingle Springs Miwok), via e-mail sent on March 27, 2017, provided preliminary information regarding two Native American village sites known in the general project area. The Shingle Springs Miwok were contacted via telephone and relevant information is incorporated into this DEIR.

While other federally-recognized Tribes may claim the project area as part of their ancestral territory, no other Tribes have requested consultation or additional information as a result of the NAHC request.

Historical Resources

Previous Historic Resources Evaluations

Data Sources The following sources of information were reviewed to identify previously evaluated historical resources in the study area.

National Register of Historic Places, National Historic Landmarks California Register of Historical Resources, California Inventory of Historic Resources,



California Historical Landmarks (State of California 1996) et seq., California State Historic Resources Inventory (HRI), California Master List of State-Owned Historical Resources, Context Statement from the City of Sacramento, Sacramento Register of Historic & Cultural Resources, and Archival collections at the Center for Sacramento History.

Historic Resources Inventory Results The HRI included two resources located in the project study area that have been assigned a California Historical Resources code of “1S,” signifying their status as properties individually listed in the NRHR and also listed in the CRHR. These two properties are 800 N Street (Leland Stanford Mansion) which was found eligible in 1987 through the National Historic Landmark Program and 704 O Street (Heilbron House) which was found eligible in 1976 through the National Parks Service. The two properties were also given a status code of “3S” in 1976 (no agency listed), indicating that the properties appear eligible for the NRHP as an individual property through evaluation. The building at 806 O Street (Klumpp Mortuary Building) is listed as “3S” as well but no date or agency name was provided by the HRI. In addition, the Capitol Towers at 1500 7th Street, was formally determined eligible for the NRHP by the National Park Service on December 31, 2014, and this determination was reported to the SHPO on January 16, 2015.

State Master List of Historical Resources PRC 5024 requires State agencies to evaluate whether a state-owned building is eligible for inclusion in the Master List of State-Owned Historical Resources.

The Heilbron House is included on the Master List. The Stanford Mansion is included on the Master List. The Bateson Building at 1600 9th Street was included on the Master List in 2015. The Resources Building at 1416 9th was included on the Master List in 2015.

Sacramento Register of Historic & Cultural Resources Most recently updated in August 2015, the Sacramento Register of Historic & Cultural Resources lists all resources that have been designated by the City of Sacramento. Because each of these resources has been so designated by Sacramento’s city council via city ordinance, these resources are considered historical resources for the purposes of CEQA.

One historical resource located within the project study area was designated by the City of Sacramento and is included in the Sacramento Register of Historic & Cultural Resources, as follows:

Klumpp Mortuary Building, 806 O Street, APN: 006-0206-023, Ord. No. 82-046, enacted: June 15, 1982, n.d.

As part of a development project on the block of 8th and O Streets in 1984, CADA, with assistance from the Office of the State Architect, determined by way of Resolution No. 84-27 that the structural work required to bring the Klumpp Mortuary building to code would “destroy the integrity of both the interior and exterior architecture, thereby justifying demolition and historic replication” of the building (CADA 1984). The visible result of this 1984 “preservation by replication” is the façade that currently fronts O Street.

Summary Results of Previous Historic Resources Evaluations As identified above, among the buildings in the project study area, two are listed in the NRHP and automatically listed in the CRHR, one is formally determined eligible for the NRHP and automatically listed in the CRHR, one has been previously evaluated as eligible for inclusion the NRHP and the Master List, and one has been designated by Sacramento City Council and is included in the Sacramento Register of Historic & Cultural Resources. These five buildings are historical resources for the purposes of CEQA.



Current Historic Resources Evaluations Five additional state owned buildings and structures in the study area have not been evaluated for the Master List. Four of the five are presumed to be CEQA historical resources for purposes of this EIR as a result of their association with the 1960s Capitol Master Plan (Office Buildings 8 & 9), and with architectural manifestations of 1970s environmentalism (EDD Solar-Subterranean Building and the Energy Commission Building)

An ICF architectural historian exceeding the Secretary of the Interior’s Professional Qualification Standards in the areas of history and architectural history determined there are no additional buildings or structures within the project study area beyond those described above as previously determined — or presumed for the purposes of this analysis — to be CEQA historical resources.

Although the Central Heating and Cooling Plant at 625 Q Street began construction in 1967 (50-years ago), the plant underwent extensive structural and operational upgrades that were completed in 2010. Almost none of the original plant features remain. Because of the lack of historical integrity to the structure’s 1967 period of historical significance (year built), it is not considered a historical resource for the purposes of CEQA, and is therefore not included in the discussion of impacts and mitigation measures.

Historical Resources within the Study Area The following tables 4.12-3 and 4.12-4 summarize the ten CEQA historical resources located in the study area. The locations of these resources are shown in Exhibit 4.12-2. A more detailed discussion of each of these resources is provided below.

Table 4.12-3 CEQA Historical Resources Located in the Study Area Resource Name Address Status

Heilbron House 704 O Street 1S – Individual property listed in NRHP. Listed in the CRHR.

Stanford Mansion 800 N Street 1S – Individual property listed in NRHP. Listed in the CRHR.

Capitol Towers 1500 7th Street 2S - Individual property determined eligible for NRHP. Listed in the CRHR.

Klumpp Mortuary building 806 O/1515 8th Streets 5S1 – Individual property that is listed or designated locally.

Bateson Building 1600 9th Street 2S, 4CM – Master List – State Owned Properties – PRC 5024.

Resources Building 1416 9th Street 2S, 4CM – Master List – State Owned Properties – PRC 5024. Sources: NPS NRHP Database, NPS letter to CA SHPO, HRI, Sacramento Register of Historic & Cultural Resources, DGS 2016.

Table 4.12-4 Presumed CEQA Historical Resource Resource Name Address Status

Office Building No. 8 714 P Street Presume 4CM for the purposes of CEQA

Office Building No. 9 744 P Street Presume 4CM for the purposes of CEQA

EDD Solar-Subterranean Building

750-751 N Street

Presume 4CM for the purposes of CEQA

Energy Resources Conservation and Development Building

1516 9th Street Presume 4CM for the purposes of CEQA

Source: ICF 2017



Exhibit 4.12-2 Historical Resources within the Study Area



The following summarizes the previously determined CEQA historical resources, describing their historic significance and important character-defining features.

Heilbron House - 704 O Street The Heilbron House is located at 704 O Street, on the P Street Block. The Heilbron House was designed by Nathaniel Goodell in the Italianate style for August Heilbron in 1881. The Heilbron House was listed in the NRHP on December 12, 1976. Although the NRHP listing does not explicitly identify which criteria the property met, a Historic Structure Report prepared in October 2003 indicates “it appears the Heilbron House is eligible under Criterion B for its association with Sacramento cattle king August Heilbron and under Criterion C as the work of prominent local architect Nathaniel Goodell.” Because it is already listed in the NRHP, the Heilbron House is automatically listed on the CRHR pursuant to Title 14 CCR Section 4851(a)(1) and is a historical resource for the purposes of CEQA pursuant to Section 15064.5(a)(1) of the CEQA Guidelines. Because it is listed in the NRHP and owned by the State of California, the Heilbron House is also included in California’s master list of State-owned properties maintained by the SHPO pursuant to PRC 5024(d).

The period of significance of the Heilbron House is from 1881, when the house was designed and built by Nathaniel Goodell, to 1893 when August Heilbron died. Although the building continues to retain most aspects of integrity, it has undergone alterations since the end of its period of significance. In 1905, second floor sleeping porches were added to the eastern and western elevations. In 1930, there was a fire that damaged the parlor, library, and dining room. After Marie Heilbron died in 1953, the building was converted to Antonia’s Restaurant (later Sadie’s Restaurant). During that time, the front and rear parlors were converted into a cocktail bar and the kitchen was modernized. By 1970, the stairway to the western porch was removed. In 1973, the building went through a major remodel at a cost of $851,000 for the San Diego Federal Savings and Loan Association to convert it to a bank. Some door openings were enlarged and most historic doors removed, but the most noticeable alterations occurred in the basement level. In 1992, the building was converted to a gallery and bookstore operated by the La Raza Galeria Posada, and the most noticeable alterations were the conversion of some of the upper floor rooms to gallery space. Other alterations noted during the field survey include the complete replacement of the main exterior staircase on O Street, probably within the last five years. The Historic Structures Report prepared in October 2003 contains more detail on the history and construction history of the Heilbron House. (DPR 2003)

Stanford Mansion – 800 N Street The Stanford-Lathrop House (Stanford Mansion), located at 800 N Street, was listed in the NRHP on December 9, 1971 and designated as a National Historic Landmark in 1987. Because it is already listed in the NRHP, the Stanford Mansion is automatically listed on the CRHR pursuant to 14 CCR 4851(a)(1) and is a historical resource for the purposes of CEQA pursuant to Section 15064.5(a)(1) of the CEQA Guidelines. The Stanford Mansion is also listed as a California State Landmark (# 614) and is represented in the Historic American Buildings Survey (CA-1709). Because it is listed in the NRHP and owned by the State of California, the Stanford Mansion is also included in California’s master list of State-owned properties maintained by the SHPO pursuant to PRC 5024(d).

Built about 1856 as a two-story structure for prominent businessman Shelton Fogus, it was sold in 1861 to Leland Stanford, President of the Central Pacific Railroad Corporation, who became California’s eighth governor in January of 1862. Soon thereafter, Stanford added new landscaping and a wing to the east side of the building to become his governor’s office. After serving a two-year term as governor, Stanford returned to private life and traveled frequently on railroad business. The State then rented Stanford’s furnished home for the next governor, Frederick Low. Henry Haight, who succeeded Low as governor, rented Stanford’s office until a new governor’s office was opened in the Capitol in 1869. Meanwhile, the Stanfords moved back into the home in late 1867.

By early 1872 the Stanfords had remodeled and greatly enlarged the home. The next year the Central Pacific Railroad offices moved to San Francisco and in 1874 the Stanford family followed, though they still used their Sacramento home on occasion. In 1900, the widowed Jane Stanford gave the home and most of its furnishings to the Diocese of Sacramento to become a home for “friendless children.” For nearly 90 years, it



was a haven for youngsters, mostly girls, of various ages and backgrounds. In the late 1950’s, the expense of upkeep led Bishop Alden Bell to write to the governor to suggest the State buy the home to restore. The State purchased the historic property in 1978, which included some remaining Stanford furnishings (Regnery & Charleton 1987).

Capitol Towers - 1500 7th Street The summary description and significance statement from the NRHP nomination of the Capitol Towers (Chou 2014) is quoted as follows: “Capitol Towers is a large-scale, multi-family modern residential complex with low-rise garden apartment buildings, a high-rise tower, and pedestrian-oriented landscapes on an approximately 10-acre superblock in downtown Sacramento, California. Constructed between 1959 and 1965, Capitol Towers was among the first privately sponsored urban redevelopment projects in California. A talented design team that included architecture firms Wurster, Bernardi, and Emmons (WBE), Edward Larrabee Barnes, and DeMars & Reay, as well as landscape architect Lawrence Halprin collaborated on the design of the property. The site planning, building design and landscape architecture reflect the designers' concern less with style, trends, or architectural doctrines than with functionality, comfort, and livability. The modest, stucco-clad, deep-eave, low-rise garden apartment buildings, consisting of staggered unit modules to prevent monotonous linear blocks, fan across the superblock and shape exterior spaces such as landscaped courts, pedestrian walkways, and surface parking lots. The horizontality of the garden apartment buildings also complements the concrete and glass high-rise building on-site and those on adjacent properties in a dynamic interplay between well-scaled horizontal and vertical elements. At the center of the property is a central plaza and swimming pool. Derived from Garden City principles, Capitol Towers is an internal, pedestrian-oriented property with shared interior landscaped areas, and automobile and service uses placed at the periphery. Unlike garden apartment complexes that are insular and in suburban settings, Capitol Towers maintains an urban street presence with the low-rise units fronting city streets, parking lots pulled inward as interior courts, and a sense of openness, order, and permeability that connects with the surrounding street grid. Despite alterations of some features on resources across the property, Capitol Towers retains adequate integrity of its primary spatial relationships, residential buildings, and landscape features to convey its significance.

Capitol Towers is locally significant under Criterion A in the area of Community Planning and Development as the residential component and inaugural privately sponsored development in Sacramento's first realized urban redevelopment area, the Capitol Mall Redevelopment Project. The initial construction of 92 garden apartment units, starting in 1959 and completed in 196o, represented the first private investment in Sacramento to replace the blighted neighborhoods demolished by the Sacramento Redevelopment Agency (SRA) under slum clearance. As SRA's Capitol Mall Redevelopment Project was the first to use tax increment financing, the construction of Capitol Towers was at the forefront of redevelopment in California that would reshape many of the state's urban areas in the second half of the twentieth century.

Capitol Towers is also locally significant under Criterion C as a well-planned example of urban redevelopment housing. Not only does its pedestrian-oriented design combine low-rise and high-rise buildings, integrated landscape features, and amenities for its residents, the design also maintains a strong urban presence while balancing privacy and community for its residents. Capitol Towers exhibited thoughtful and people-oriented design and planning features from conception through completion, even as the designers refined the design while adhering to the requirements that came with federal funding. In addition, Capitol Towers was the first redevelopment project constructed by many of its talented design team that included Wurster, Bernardi, and Emmons, Edward Larrabee Barnes, DeMars & Reay, and Lawrence Halprin, and reflects their social and aesthetic philosophies. In particular, Capitol Towers embodies the design and planning approach of Wurster, Bernardi, and Emmons applied to a large urban property, and is considered by Lawrence Halprin to be his first urban plaza.

As the final components of the property, the high-rise tower, and the four-level parking garage were completed in early 1965, the period of significance under Criterion C is 1965.



Klumpp Mortuary Building - 806 O Street The Klumpp Mortuary Building located within the project study area was designated by the City of Sacramento through City ordinance and is included in the Sacramento Register of Historic & Cultural Resources:

806 O Street, APN: 006-0206-023, Ord. No. 82-046, enacted: June 15, 1982, n.d., partially demolished. The Klumpp Mortuary building was built in 1939. George L. Klumpp was elected Mayor of Sacramento in 1947.

As a result of being on a local register of historical resources, the Klumpp Mortuary building is a historical resource under CEQA, as defined by Section 15064.5(a)(2) of the CEQA Guidelines.

Bateson Building - 1600 9th Street The following information from the technical report prepared for consideration on the Master List of Historical Resources (DGS 2016) is quoted as follows: “Opened in May 1981, the Bateson Building (also known as the Bateson State Building or the Gregory Bateson Building) is the pre-eminent architectural expression of 1970s era environmentalism in California under the administration of governor Edmund G. “Jerry” Brown. Designed as an energy efficiency demonstration piece by State Architect Sim Van der Ryn, it is an exceptionally significant example of energy efficient, environmentally sensitive architecture applied to a state government office building."

The Bateson Building is eligible under Criterion A and Criterion 1 as an expression of 1970s era environmentalism under Governor Edmund G. “Jerry” Brown. Brown’s tenure as California governor in the 1970s was distinguished by a noted commitment to environmental issues. Indeed, Brown’s interest in environmentalism was so marked and so unusual that it earned him the derisory moniker, “Governor Moonbeam.” Among the hallmarks of this commitment were his appointment of Sim Van der Ryn, noted for his environmentally sensitive work throughout his career, as State Architect and the creation of the Office of Appropriate Technology. Opened in May 1981 and incorporating cutting-edge environmental features including energy-efficiency measures and human sensitive design, the Bateson Building is the pre-eminent architectural manifestation of 1970s era environmentalism in California. For the reasons stated above, the Bateson Building is considered exceptionally significant under Criterion A of the NRHP at the state level of significance and Criterion 1 of the CRHR. Because it is eligible for listing on the NRHP and owned by the State of California, the Bateson Building is also included in California’s master list of State-owned properties maintained by the SHPO pursuant to PRC 5024(d).

For the following reasons, the building is eligible for listing in the NRHP/CRHR under Criterion C/3: Opened in 1981 as an energy efficiency demonstration piece, the Bateson Building is an exceptionally significant example of energy efficient, environmentally sensitive architecture applied to a state government office building. Incorporating an integrated suite of features that utilized daylighting, sunshading, thermal mass, and energy control systems, the Bateson Building was designed to use energy resources appropriately and create an environment to support occupant comfort and productivity. The Bateson Building is an exceptional example of the cutting-edge technologies and approaches to environmentally sensitive design as applied to a state office building.

Resources Building - 1416 9th Street The following text is an excerpt from the SHPO’s letter of concurrence regarding the PRC 5024 determination of eligibility of the Resources Building (SHPO 2015):

The Resources Building is locally significant within the context of Community Planning and Development for its association with the development of the Capitol Master Plan. This plan was envisioned as a long-range plan for the construction and expansion of State facilities surrounding the Capitol. In the post-war years and in the 1950s, California experienced a large population growth and required expansion of the State workforce to keep up with demands placed on State government. In 1959, the 13-person Capitol Building and Planning Commission was founded by act of the Legislature. The Resources Building was the first construction project of the Capitol Master Plan. Not only was the Capitol Master Plan significant



within the development of State facilities, the plan had a significant impact within Sacramento. In 1860, the City of Sacramento granted the State the land between L and N Streets and 10th and 12th Streets for a new capitol building. In 1960, the State still owned 69.8 acres originating from the City land grant, which had not been used for the construction of the Capitol. Within the City of Sacramento, it can certainly be argued that there is no other plan that has had as many impacts on the character and design of the City. It is further important to note that it was significant enough in Sacramento for the design committee of the Capital Master Plan to solicit suggestions for committee members based on recommendations from both the Sacramento Mayor and Sacramento County Board of Supervisors. While the Resources Building was the first property of the Capitol Master Plan to be built, the plan had a 20-year outline for land acquisition and 40-year build-out of buildings, structures, parking lots, and landscaping improvements, and throughout the 1960s and 1970s, construction of office buildings and facilities continued.

Under NRHP Criterion C, The 1964 Resources Building fits within the period of International Style architecture (1930-70s); other examples include Sacramento’s SMUD Headquarters Building (1959), the New York IBM Building (1971), and the 1955 Police Station, in the Civic Center of Los Angeles. The Resources Building displays many characteristics and design elements of the International Style, such as the display of regularity without symmetry, the use of rectilinear forms, the use of open interior spaces or openly planned interiors without definite fixed partitions; the use of a cantilever building construction to imply a visually weightless building quality; the balancing of the building in axial symmetry, flat roofs; smooth wall surfaces, and the lack of ornamentation and the use of design building elements as ornamentation.

Therefore, it is my determination that, for purposes of PRC 5024, the Resources Building is eligible for inclusion in the NRHP under Criteria A and C and, thus, shall be included on the Master List of state-owned historical resources.

Because it is eligible for listing in the NRHP and owned by the State of California, the Resources Building is also included in California’s master list of State-owned properties maintained by the SHPO pursuant to PRC 5024(d).

Four Other State-Owned Buildings As identified in Table 4.12-4, for the purposes of this EIR, the following four state owned buildings are presumed to be historical resources under CEQA:

State Office Building 8 at 714 P Street built in 1970 State Office Building 9 at 774 P Street built in 1970 EDD Solar-Subterranean Building at 750-751 N Street built in 1983 Energy Resources Conservation and Development Building built in 1983



4.12.3 Environmental Impacts and Mitigation Measures

ANALYSIS METHODOLOGY For purposes of discussion throughout the following impacts and mitigation measures, the term “historical resources” describes extant buildings and structures as well as subsurface historic-era features (such as wells, privies, or foundations). Prehistoric resources refer to Native American sites, features, or burials.

While there is a low likelihood that intact cultural deposits are present within the project site, background research indicates that substantial prehistoric and historic deposits containing significant data have been discovered in similar settings in downtown Sacramento. Past projects have located buried cultural resources using historic maps, photographs, archival data, and consultation.

Restricted surface visibility in urban areas provides only basic information on the impact of construction on subsurface archaeological deposits. Consequently, the results of a review of historical documents and previous research provide the primary basis for assessing project impacts on archaeological resources. Factors taken into account include the general history of the area, the time frame of residential development, potential for the presence of artifact-filled features, and later period development that would have disturbed archaeological features. All these factors were assessed to rate the potential for the presence of archaeological resources as high, moderate, or low:

High potential for impacts on cultural resources was considered likely when the proposed component or alternative was in an area where no known subsurface disturbances had previously occurred and archival research indicated the presence of residential components before water and/or sewer hookup and municipal garbage pickup.

Moderate potential for impacts on cultural resources was considered likely when the proposed component or alternative was in an area where no known belowground disturbances had previously occurred and archival research indicated a potential for artifact-filled features.

Low potential for impacts on cultural resources was considered likely when the proposed alternative occurred in an area of known ground disturbance. While the potential to encounter archaeological deposits was considered low under these circumstances, the possibility that isolated deposits may remain intact cannot be dismissed.

The analysis below does not address the potential effects on sub-surface historic or prehistoric resources from the proposed child care facility to be placed on the roof plaza of the Subterranean Building, located immediately north of the P Street Block (see Chapter 3, “Project Description”). This child care facility would not result in impacts to subsurface resources because it would be placed on the roof plaza of the existing building and would require no ground disturbing activities.

THRESHOLDS OF SIGNIFICANCE An impact on cultural resources is considered significant if implementation of the Resources Building Replacement Project would do any of the following:

cause a substantial adverse change in the significance of a unique archaeological resource or a historical resource as defined in PRC 21083.2 and Section 15064.5 of the State CEQA Guidelines, respectively;

directly or indirectly destroy a unique paleontological resource or site or unique geological feature; or

disturb any human remains, including those interred outside of formal cemeteries; or



cause a substantial adverse change in the significance of a tribal cultural resource as defined in PRC 21074.

Section 15064.5 of the State CEQA Guidelines defines “substantial adverse change” as physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings.

ISSUES OR POTENTIAL IMPACTS NOT DISCUSSED FURTHER As described in Section 4.9.2, “Existing Conditions,” in Section 4.9, “Geology and Soils, the project site lies within the urban environment of downtown Sacramento where underlying soils consist of Holocene alluvium deposits less than 11,000 years old. Objects must typically be older than the Holocene epoch to be considered a fossil; therefore, it is highly unlikely that soils underlying the project site contain unique paleontological resources. There are no unique geological features on the project site. Therefore, these topics will not be addressed further in this EIR.

ENVIRONMENTAL IMPACTS

Impact 4.12-1: Potential for Impacts on Significant Historic Archaeological Resources Construction of the Resources Building Replacement office building would result in the expansion of the existing facilities on the P Street Block. Excavations required to build and remove various structures on the block over time, and to install underground utilities, have likely removed or degraded significant historic archaeological features that may be on the P Street Block. However, there are areas that may yet be undisturbed, thus potentially retaining significant historic archaeological resources. Because earthmoving activities could potentially affect significant historic archaeological resources within these undisturbed areas, this impact is considered potentially significant.

The present-day P Street Block has supported residential and commercial activity since the 1850s, likely represented by archaeological remains. Such remains may represent some of the earliest residential development within Sacramento. Artifact-filled features from at least the 1850s through the 1880s could contain information about the lives of early important Sacramento citizens. Important data about other lesser-known residents, including professionals, skilled workers, servants, and immigrants could also be present. However, reconnaissance of the project area found that underground utility infrastructure has been installed in much of this block. Installation of these systems required substantial earthmoving activities that would have likely removed or degraded any historic archaeological features that may have been encountered. Excavations required to build and remove various structures over time may have also removed or degraded historic archeological features that may have been present. However, there is a that portions of the P Street Block may remain undisturbed and contain significant intact historic archaeological deposits. If these areas have not been disturbed by previous construction activities, remaining artifacts and features could be disturbed or destroyed during project construction.

Construction of the Resources Building Replacement office building would result in the expansion of the existing facilities on the P Street Block. In addition, the excavation of a basement for the Office Building may result in excavations going deeper than past construction disturbance and encountering previously undisturbed native soils. Overall, the project site is considered to have a low to moderate potential for the existence of intact archaeological deposits. However, because there is some potential for earthmoving activities associated with project construction to potentially affect significant historic resources in previously undisturbed areas, this impact is considered potentially significant.

Mitigation Measure 4.12-1: Monitoring and Response Measures for Potential Unknown Historic Archaeological Resources. Where ground disturbing activities occur in native soils, or there is no evidence of extensive past ground disturbances, a qualified archaeologist meeting the United Sates Secretary of Interior guidelines for



professional archaeologists will monitor ground- disturbing activities. If evidence of any historic-era subsurface archaeological features or deposits are discovered during construction-related earth-moving activities (e.g., ceramic shard, trash scatters), all ground-disturbing activity in the area of the discovery shall be halted until a qualified archaeologist can access the significance of the find. If after evaluation, a resource is considered significant, all preservation options shall be considered as required by CEQA, including possible data recovery, mapping, capping, or avoidance of the resource. If artifacts are recovered from significant historic archaeological resources, they shall be housed at a qualified curation facility. The results of the identification, evaluation, and/or data recovery program for any unanticipated discoveries shall be presented in a professional-quality report that details all methods and findings, evaluates the nature and significance of the resources, analyzes and interprets the results, and distributes this information to the public.

Significance after Mitigation Implementation of this mitigation measure would reduce Impact 4.12-1 to a less-than-significant level by requiring construction monitoring and, in the case of a discovery, preservation options (including data recovery, mapping, capping, or avoidance) and proper curation if significant artifacts are recovered.

Impact 4.12-2: Potential for Impacts on Significant Prehistoric Archeological Resources and Tribal Cultural Resources There are no known significant prehistoric archeological resources or tribal cultural resources on the project site. However, earthmoving activities associated with project construction could disturb or destroy previously undiscovered significant subsurface prehistoric archaeological resources and/or tribal cultural resources. This impact is considered potentially significant.

Evidence of prehistoric occupation of the Sacramento region dates back several thousand years. Cultural deposits of most early or long-term occupation sites in the region are marked by cultural layers alternating with flood-deposited silts. Sites, such as one discovered on I Street, have cultural layers that are now 15 to 20 feet below the current street level (Hamilton et al. 2005). As described above for Impact 4.12-1, while the P Street Block has been developed with various uses over time, and past construction activities may have damaged or removed subsurface cultural resources, there is the potential for subsurface resources, including significant prehistoric archeological resources and resources that would qualify as a tribal cultural resource, to be present where there has been less ground disturbance or where native soils are still intact. It is also possible that artifacts and materials of importance to tribal entities could also have been deposited at the site with imported fill. Components of the project which require substantial earthmoving could disturb or destroy undisturbed and significant prehistoric deposits. In addition, the excavation of a basement for the Office Building may result in excavations going deeper than past construction disturbance and encountering previously undisturbed native soils. There are no known significant prehistoric archeological resources or tribal cultural resources on the project site. Overall, the project site is considered to have a low to moderate potential for the existence of intact archaeological deposits. Because there is some potential for earthmoving activities associated with construction on the P Street Block to potentially affect significant prehistoric archeological resources, or resources that would qualify as tribal cultural resources, this impact is considered potentially significant.

Mitigation Measure 4.12-2: Monitoring and Response Measures for Potential Unknown Prehistoric Archaeological Resources and Tribal Cultural Resources. This mitigation measure expands on the actions included in Mitigation Measure 4.12-1 to also address encountering unknown prehistoric cultural resources and tribal cultural resources. Where ground disturbing activities occur in native soils, or there is no evidence of extensive past ground disturbances, or evidence suggests that imported soils have a high probability of containing artifacts and materials of importance to tribal entities, a Native American monitor and a qualified archaeologist meeting the United Sates Secretary of Interior guidelines for professional archaeologists will monitor ground- disturbing activities. The determination for initiating or ending monitoring disturbance of imported soils will be made based on coordination between the qualified archeologist and Native American monitor, with a final determination made by DGS. The Native



American monitor will be provided the opportunity to conduct a site meeting with construction personnel to convey cultural resources awareness information. If evidence of any prehistoric subsurface archaeological features or deposits are discovered during construction-related earth-moving activities (e.g., lithic scatters, midden soils), all ground-disturbing activity in the area of the discovery shall be halted until a qualified archaeologist and Native American representative can access the significance of the find. If after evaluation, a resource is considered significant, or is considered a tribal cultural resource, all preservation options shall be considered as required by CEQA, including possible data recovery, mapping, capping, or avoidance of the resource. If artifacts are recovered from significant prehistoric archaeological resources or tribal cultural resources, they shall be transferred to an appropriate tribal representative, or housed at a qualified curation facility. If artifacts or other materials must be removed, preference shall be given to transferring materials to an appropriate tribal representative and re-interring the material at a location on the P Street Block. The results of the identification, evaluation, and/or data recovery program for any unanticipated discoveries shall be presented in a professional-quality report that details all methods and findings, evaluates the nature and significance of the resources, analyzes and interprets the results, and distributes this information to the public.

Significance after Mitigation Implementation of this mitigation measure would reduce Impact 4.12-2 to a less-than-significant level by requiring construction monitoring and, in the case of a discovery, preservation options (including data recovery, mapping, capping, and avoidance) and proper care of significant artifacts if they are recovered, including re-interring material on the P Street Block.

Impact 4.12-3: Potential Discovery of Human Remains There are no known past cemeteries or burials on the project site. However, earthmoving activities associated with project construction could disturb or destroy previously undiscovered human remains. This impact is considered potentially significant.

As identified above in the discussions of Impact 4.12-1 and 4.12-2, overall, the project site is considered to have a low to moderate potential for the existence of intact archaeological deposits. This assessment would also apply to the potential presence of human remains, whether associated with historic, or pre-historic occupation. There are no known past cemeteries or burials on the project site. However, because there is some potential for earthmoving activities associated with project construction to potentially encounter buried human remains in areas with little or no previous disturbance, or in imported material that may have inadvertently contained Native American remains, this impact is considered potentially significant.

Mitigation Measure 4.12-3: Response protocol in case human remains are uncovered. Consistent with the California Health and Safety Code and the California Native American Historical, Cultural, and Sacred Sites Act, if suspected human remains are found during project construction, all work shall be halted in the immediate area, and the county coroner shall be notified to determine the nature of the remains. The coroner shall examine all discoveries of suspected human remains within 48 hours of receiving notice of a discovery on private or State lands (Health and Safety Code Section 7050.5[b]). If the coroner determines that the remains are those of a Native American, he or she shall contact the NAHC by phone within 24 hours of making that determination (Health and Safety Code Section 7050[c]). The NAHC shall then assign an MLD to serve as the main point of Native American contact and consultation. Following the coroner’s findings, the MLD, in consultation with the State, shall determine the ultimate treatment and disposition of the remains.

Significance after Mitigation Implementation of this mitigation measure would reduce Impact 4.12-3 to a less-than-significant level by requiring work to stop if human remains are found and communication with the county coroner and the proper identification and treatment of the remains consistent with the California Health and Safety Code and the California Native American Historical, Cultural, and Sacred Sites Act.



Impact 4.12-4: Potential for impacts on historic architectural resources Physical alteration of the immediate surroundings of the Heilbron House at 704 O Street would cause a substantial adverse change in the significance of historic architectural resources. This would result in a significant impact on the environment as described in State CEQA Guideline 15064.5(b)(1).

Nine of the 10 historical resources in the project study area boundary would not be subject to risk of substantial adverse change as a result of project-related physical demolition, destruction, relocation, or alteration of the resources per CEQA Guidelines 15064.5(b)(1). Although the proposed Resources Building Replacement office building would change the immediate surroundings of each of these historical resources, as described below, the impact for these nine buildings would not be significant:

Stanford Mansion – 800 N Street. The Stanford Mansion is located directly across 8th Street and approximately 80 feet to the east of the closest portion of the project site. The mansion is a historic structure that is the focal point of the Leland Stanford Mansion State Historic Park. The Stanford Mansion is listed in the NRHP and CRHR, designated as a National Historic Landmark, listed as a California State Landmark (# 614), and is represented in the Historic American Buildings Survey (CA-1709). The Stanford Mansion is located one block northeast of the Resources Building Replacement office building with the existing Resources Building located between the new building and the Stanford Mansion. The proposed project would not obstruct any views to the Stanford Mansion and views of the new office building from the Stanford Mansion would be blocked by the existing Resources Building from almost all viewpoints. The tallest portion of the proposed Resources Building Replacement office building is evaluated in this DEIR as being up to 300 feet tall. Based on the shade and shadow analysis (see Section 4.15, “Aesthetics, Light, and Glare”), the Resources Building Replacement office building would not add any shadow or shading to the Stanford Mansion beyond what is already caused by the existing Resources Building. Because the project would leave views of the Stanford Mansion unobstructed, the physical characteristics that convey the mansion’s significance would remain highly visible to the public. Therefore, the introduction of a new office building would not result in a substantial adverse change to the immediate surroundings of Stanford Mansion or to the physical characteristics that convey its significance.

Capitol Towers - 1500 7th Street. The Capitol Towers are located directly across 7th Street and approximately 80 feet to the west of the project site. Capitol Towers is a residential complex comprised of low-rise apartments, a high-rise tower, and pedestrian oriented landscapes on a 10-acre superblock. In addition to providing an approximately 80-foot separation between the complex and the project site, 7th Street is also lined on both sides with mature trees, providing a buffer that would help obscure visibility of the proposed office building. Capitol Towers was given an OHP status code of “2S” as an individual property determined NRHP eligible. The tallest portion of the proposed Resources Building Replacement office building is evaluated in this DEIR as being up to 300 feet tall. Based on the shade and shadow analysis (see Section 4.15, “Aesthetics, Light, and Glare”), the easternmost portion of the Capitol Towers complex would be in shadow from the proposed project during the morning hours, particularly during the winter months. Access to light, however, is not a character-defining feature of the property. Because the project would leave street-level views of the Capitol Towers mostly unobstructed, the physical characteristics that convey the complex’s significance would remain highly visible to the public. Therefore, the introduction of a new office building would not result in a substantial adverse change to the immediate surroundings of Capitol Towers or to the physical characteristics of the complex that convey its significance.

Klumpp Mortuary building - 806 O/1515 8th Streets. The Klumpp Mortuary building is located directly across 7th Street and approximately 75 feet to the east of the project site. Klumpp Mortuary building is a low-rise building with a series of wings originally used as a funeral parlor and chapel. It is generally surrounded on three sides by dense urban development, including the high-rise existing State Resources Building to the north across O Street. With the proposed project, unobstructed views to the primary elevation of the Klumpp Mortuary building would be unchanged from the existing condition when the



observer faces east, southeast, or south. The proposed project building would not obstruct views of Klumpp Chapel of the Flowers, however, it would be visible in the background of the historic building particularly when the observer faces southwest. Klumpp Chapel of the Flowers was given an OHP status code of “5S1” as an individual property that is listed or designated locally because it is included in the Sacramento Register of Historic & Cultural Resources. Based on the shade and shadow analysis (see Section 4.15, “Aesthetics, Light, and Glare”), the Klumpp Chapel of the Flowers would be in shadow cast by the proposed project during the afternoon hours, particularly during the winter months. Access to light, however, is not a character-defining feature of the property. Because the project would leave street-level views of the Klumpp Chapel of the Flowers unobstructed, the physical characteristics that convey the building’s significance would remain highly visible to the public. Therefore, the introduction of a new office building would not result in a substantial adverse change to the immediate surroundings of Klumpp Chapel of the Flowers or to the physical characteristics of the building that convey its significance.

Bateson Building - 1600 9th Street. The Bateson Building is located to the southeast of the proposed project site approximately 100 feet away, on the block diagonally across 8th Street and P Street. The Bateson Building is a high-rise office building in a dense urban environment, largely surrounded by other office buildings. The Bateson Building was given an OHP status code of “2S, 4CM” as an individual property determined NRHP eligible and on the Master List – State Owned Historical Resources under PRC 5024. Opened in 1981, it is significant as an example of energy efficient, environmentally significant architecture applied to a state government office building. Views of the Bateson Building from all directions except the northwest would be unobstructed by the proposed office building, although the proposed project would be visible in the background from a limited number of locations along P Street and 8th Street. Views from the intersection of P Street and 8th Street would also remain unchanged, but more distant views from the northwest across the existing parking lot would be obstructed by the proposed project. Based on the shade and shadow analysis (see Section 4.15, “Aesthetics, Light, and Glare”), the proposed project would not cast a shadow on the Bateson Building. This is critical because a key feature of the building’s design is access to sunlight, Sunlight is intentionally admitted to the building’s interior atrium through the Bateson Building’s roof. Additionally, although now removed, solar water heating apparatus was located on the building’s roof. The proposed project would not obstruct any views to the Batson Building and the physical characteristics that convey the building’s significance would remain highly visible to the public. Therefore, the introduction of a new office building would not result in a substantial adverse change to the immediate surroundings of the Bateson Building or to the physical characteristics of the building that convey its significance.

Resources Building - 1416 9th Street The existing Resources Building is located to the northeast of the proposed project site approximately 100 feet away, on the block diagonally across 8th Street and O Street. The Resources Building is a high-rise office building in a dense urban environment, largely surrounded by other office buildings of mixed heights. The Resources Building was given an OHP status code of “2S, 4CM” as an individual property determined NRHP eligible and on the Master List – State Owned Historical Resources under PRC 5024. The existing Resources Building would be vacated after construction of the proposed project is completed, but it would be protected and maintained until new tenants are obtained. Views of the Resources Building from all directions except the southwest would be unobstructed by the proposed office building, although the proposed project would be visible in the background from a limited number of locations along O Street and 8th Street. Views from the intersection of O Street and 8th Street would also remain unchanged, but more distant views from the southwest across the existing parking lot would be obstructed by the proposed project. Based on the shade and shadow analysis (see Section 4.15, “Aesthetics, Light, and Glare”), the proposed project would cast a shadow on the Resources Building in the afternoon hours of the spring, fall and winter months. Access to light, however, is not a character-defining features of the Resources Building. The proposed project would not obstruct any views to the Resources Building and the physical characteristics that convey the building’s significance would remain highly visible to the public. Therefore, the introduction of a new office building would not result in a substantial adverse change to the immediate



surroundings of the Resources Building or to the physical characteristics of the building that convey its significance.

Under the proposed project, the Resources Building would be vacated by 2021. The temporary vacation of the existing building would introduce the potential for physical and structural neglect and damage while vacant. Until some future rehabilitation activities occur, DGS would implement a maintenance program—commonly referred to as mothballing—that would close the Resources Building, protect it from weather, and secure it from neglect, physical decay, and vandalism. Because the building would be protected through a maintenance program, vacating the building and retaining it with no occupants, or limited occupants, would not result in a substantial adverse change to the immediate surroundings of the Resources Building or to the physical characteristics of the building that convey its significance.

Office Building No. 8 - 714 P Street. Office Building 8 is located to the south of the proposed project site approximately 75 feet away, across P Street. Office Building 8 is a high-rise office building in a dense urban environment, largely surrounded by other high rise office buildings and a parking lot. Office Building 8 is presumed to have an OHP Status Code of 4CM and is considered a historical resource for the purposes of CEQA in the context of this analysis. Views from the west, south and east towards Office Building 8 would be unobstructed, although the proposed project would be visible in the background from some angles. Views from the north side of P Street would also remain unchanged, but more distant views from the north across the existing parking lot would be obstructed by the proposed project. Based on the shade and shadow analysis (see Section 4.15, “Aesthetics, Light, and Glare”), the proposed project would not cast a shadow on Office Building 8. The proposed project would not obstruct most views to Office Building 8 and the physical characteristics that convey the building’s significance would remain highly visible to the public. Therefore, the introduction of a new office building would not result in a substantial adverse change to the immediate surroundings of Office Building 8 or to the physical characteristics of the building that convey its significance.

Office Building No. 9 - 744 P Street. Office Building 9 is located to the south of the proposed project site approximately 275 feet away, across P Street and the plaza that is part of the Office Building 8 and 9 complex. Office Building 9 is a high-rise office building in a dense urban environment, largely surrounded by high rise and mid-rise office buildings. Office Building 9 is presumed to have an OHP Status Code of 4CM and is considered a historical resource for the purposes of CEQA in the context of this analysis. Views to all sides of Office Building 9 would remain unchanged and unobstructed with the proposed project, other than the proposed office building being visible in the background from some vantage points. Based on the shade and shadow analysis (see Section 4.15, “Aesthetics, Light, and Glare”), the proposed project would not cast a shadow on Office Building 9. The proposed project would not obstruct views to Office Building 9 and the physical characteristics that convey the building’s significance would remain highly visible to the public. Therefore, the introduction of a new office building would not result in a substantial adverse change to the immediate surroundings of Office Building 9 or to the physical characteristics of the building that convey its significance.

EDD Solar-Subterranean Building – 750-751 N Street. The EDD Solar-Subterranean Building is located to the north of the proposed project site approximately 60 feet away, across O Street. The Subterranean Building portion of EDD Solar-Subterranean Building, the portion closest to proposed office building, is a partially submerged office building with a landscaped roof plaza accessible to the public. The Subterranean Building features a low above-ground profile and is set in a dense urban environment, largely surrounded by office buildings of mixed heights and a residential complex. The EDD Solar-Subterranean Building is presumed to have an OHP Status Code of 4CM and is considered a historical resource for the purposes of CEQA in the context of this analysis. The Subterranean Building portion of the overall EDD Solar-Subterranean Building (750 N Street) is the portion closest to the proposed office building. Views from the west, north, and east towards the Subterranean Building would be unobstructed, although the proposed project would be visible in the background. Views from the south side of O Street would also remain unchanged, but more distant views from the south across the existing surface parking lot would be obstructed by the proposed project. Based on the shade and shadow



analysis (see Section 4.15, “Aesthetics, Light, and Glare”), the proposed project would not cast shadows that would reach Solar Building portion of the EDD Solar-Subterranean Building, and only cast a shadow on the Subterranean Building portion in the mid-day and afternoon hours of the winter months. The building’s roof plaza is an important feature and requires access to light to maintain. The limited number of hours of additional shade introduced by the proposed building, however, will not prevent the continued provision of vegetative landscaping on the roof plaza. The proposed project would not obstruct views to the EDD Solar-Subterranean Building and the physical characteristics that convey the building’s significance would remain highly visible to the public. Therefore, the introduction of a new office building would not result in a substantial adverse change to the immediate surroundings of the EDD Solar-Subterranean Building or to the physical characteristics of the building that convey its significance.

The proposed project includes installation of a childcare facility on the northwest corner of the roof plaza of the Subterranean Building. The roof top plaza of the Subterranean Building consists of a raised landscape of soft and hardscape features that embody the building’s character defining features as one of the pre-eminent architectural displays of humane workspaces and 1970s era environmentalism in California. The childcare facility would include modular buildings and an outdoor play area at the northwest corner of the rooftop plaza large enough to accommodate 60-70 children. The introduction of new facilities on the roof plaza of the Subterranean Building could result in a substantial adverse change to the physical characteristics of the building per CEQA Guideline 15064.5(b)(2)(A) which states that a resource is materially impaired when project work demolishes or materially alters in an adverse manner those physical characteristics of an historical resource that convey its historical significance and that justify its inclusion in the CRHR. However, this implementation is temporary and reversible (i.e., use of modular buildings), limiting the magnitude of the action, which in turn will minimize potential effects to a degree of less than significant as the proposed childcare facility will consist of temporary modular buildings that can be removed from the roof plaza at a future date and the plaza returned to its pre-project condition.

Energy Resources Conservation and Development Building – 1516 9th Street. The Energy Resources Conservation and Development Building (California Energy Commission Building) is located to the east of the proposed project site approximately 200 feet away, across 8th Street. The California Energy Commission Building, designed by Nacht & Lewis, features several energy-efficiency measures, including its permanently affixed sun shading elements and metal vertical louvers that block the windows. Daylighting is supported by an internal atrium. The California Energy Commission Building is presumed to have an OHP Status Code of 4CM and is considered a historical resource for the purposes of CEQA in the context of this analysis. Views to all but the west elevation—which has always been obstructed by the east elevation of the Klumpp Mortuary Building— of the California Energy Commission Building would remain unchanged. Based on the shade and shadow analysis (see Section 4.15, “Aesthetics, Light, and Glare”), the proposed project would not cast a new shadow on the California Energy Commission Building. The proposed project would not obstruct views to the California Energy Commission Building and the physical characteristics that convey the building’s significance—affixed sun shading elements and metal vertical louvers—would remain highly visible to the public. Therefore, the introduction of a new office building would not result in a substantial adverse change to the immediate surroundings of the California Energy Commission Building or to the physical characteristics of the building that convey its significance.

Although the proposed project would not result in a substantial adverse effect to the nine buildings listed above, the change from a parking lot to a high-rise office building in the immediate surroundings of the Heilbron House would cause a substantial adverse change in the significance of this building. Therefore, the project would cause a significant impact on the environment as described in State CEQA Guideline 15064.5(b)(1), as discussed below.

Heilbron House – 704 O Street. The Heilbron House would be protected during construction, remain in its original location, and not be altered as a result of the proposed project. The proposed project would respect the historic site and lot configuration of the Heilbron House, would have low rise construction in



closest proximity to the Heilbron House, and high rise construction further away on the same block. The Heilbron House would remain at its current location but would be vacated during construction. In accordance with the Capitol View Protection Act’s height restriction map, the northeast corner of the P Street Block site is located within the 250-foot height limit. The specified height limit does not apply to decorative building caps or rooftop mechanical equipment that is screened and placed in the farthest possible location when viewed from the State Capitol or Capitol Park. Any portion of the proposed office building in the northwest corner of the block would comply with the 250-foot height limit. The portion of the building outside of the Capitol View Protection Act would likely be taller than 250 feet, and is evaluated in this DEIR as being up to 300 feet tall. The tallest tower of the proposed project is anticipated to be located in the southeast corner of the P Street Block, the furthest possible distance it can be from the Heilbron House and still be on the same block. Based on a conceptual massing for the building, a four-story section of the tower would back up adjacent to east side of the House lot. Based on the shade and shadow analysis (see Section 4.15, “Aesthetics, Light, and Glare”), the Heilbron House will be in shadow almost all day in the winter months and mornings through mid-day in the spring and fall months. The Heilbron House is listed on the NRHP, is automatically listed on the CRHR, and is therefore considered a historical resource under CEQA Guidelines 15064.5(a)(3). The physical alteration of its immediate surroundings of this historical resource by the introduction of an office building of this scale would result in a substantial adverse change per CEQA Guideline 15064.5(b)(2)(A) which states that a resource is materially impaired when project work demolishes or materially alters in an adverse manner those physical characteristics of an historical resource that convey its historical significance and that justify its inclusion in the CRHR.

Mitigation Measure 4.12-4: Landscape elements to soften the visual transition between the historical resource and the proposed new building. Because of the difference in scale between the Heilbron House and the proposed Resources Building Replacement office building, landscape elements will be designed and planted between the Heilbron House property and the proposed office building to soften the visual transition between the two, and minimize the change to the immediate surroundings of the Heilbron House.

Mitigation Measure 4.12-5: Restoration of Lost Features and Spaces of the Historical Resource. The Heilbron House has been substantially altered by others over the years for its changes in use from a residence to a restaurant, then bank, and now for the Parks Department. Because the Heilbron House would be vacated during construction, it would be an opportune time to restore some of the lost historic features and spaces so the house better represents its original historic appearance and can be available to better educate individuals on what residential conditions were like in Sacramento during the late 19th century. In conjunction with the exterior repairs included as part of the proposed project, implement, consistent with the project budget available for Heilbron House repairs, restoration of lost historic features. Implementation would be done in consultation with the SHPO through PRC 5024.5.

Significance after Mitigation Mitigation Measure 4.12-4 would partially minimize the impact caused by the change in the immediate surroundings of the Heilbron House by softening the visual transition between the Heilbron House and the proposed replacement building. However, there would still be significant shade and shadow effects on the Heilbron House. Mitigation Measure 4.12-5 would partially minimize the impact caused by the change in the immediate surroundings of the Heilbron House by restoring the historic character of the interior of the Heilbron House. However, there would still be significant effects on its immediate setting by the introduction of a high-rise office building. This impact would be significant and unavoidable.

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