SHPO-CON-66:

This document is a Section 106 letter continuing consultation for the SLC-4 to SLC-6 Waterline Replacement Project with the California State Historic Preservation Office (SHPO). The letter reiterates the request of Vandenberg Air Force Base (VAFB) for concurrence on the base's determination that the archaeological sites CA-SBA-1678 is eligible for the National Register of Historic Places (NR), and that the project finding of no adverse effect to historic properties is appropriate. The letter follows with an additional reiteration of the project description and a brief summary and review of the previously submitted report. The SHPO states that the report was exemplary and provides comments on the submitted material. The letter specifically addresses the Area of Potential Effect (APE) and reads that the APE was not delineated appropriately in regards to the actual areas that will be subjected to direct and indirect impacts. The SHPO suggests that the APE should be reduced in scope in order to reduce the number of resources that are actually subjected to impacts and thereby avoid the need to assess impacts on resources unnecessarily. Next the letter addresses the NR eligibility of archaeological site CA-SBA-1678. While VAFB has determined that the site is eligible for inclusion in the NR based on Criterion D, the SHPO feels that the lack of chronological data and redundant nature of the artifacts does not support an eligible determination. Based on the question of delineation of the APE and disagreement of eligibility for CA-SBA-1678 the letter closes with the SHPO informing VAFB that additional comment for the project is unwarranted until agreement can be reached.