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Santa Fe National Forest Geothermal Leasing EIS: Cultural Resource Specialist Report Prepared by: Kye Miller, Ben Hammer, and Jason Chuipka PaleoWest Archaeology Submitted to: EMPSi Environmental Management and Planning Solutions, Inc. 54½ Lincoln St. Santa Fe, NM 87501 May 2016 602.261.7253 | paleowest.com | 115 West Main Street | Farmington, NM 87401

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Page 1: Santa Fe National Forest Geothermal Leasing EIS: Cultural ...a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akam… · Hot Spot map of currently identified site distribution

Santa Fe National Forest Geothermal Leasing EIS: Cultural Resource Specialist Report

Prepared by:

Kye Miller, Ben Hammer, and Jason Chuipka PaleoWest Archaeology

Submitted to:

EMPSi Environmental Management and Planning Solutions, Inc. 54½ Lincoln St.

Santa Fe, NM 87501

May 2016

602.261.7253 | paleowest.com | 115 West Main Street | Farmington, NM 87401

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May 2016 SFNF Geothermal Leasing EIS Cultural Resources Specialist Report i

TABLE OF CONTENTS

TABLE OF CONTENTS ................................................................................................................................................... i

ACRONYMS AND ABBREVIATIONS ....................................................................................................................... iv

SUMMARY .......................................................................................................................................................................... v

1. INTRODUCTION ................................................................................................................................................... 1

1.1 Project Overview ................................................................................................................................................... 1 1.2 Relevant Policy, Regulation and Guidance ........................................................................................................ 1 1.3 Scope of this Report .............................................................................................................................................. 7

2. ANALYSIS AREA ...................................................................................................................................................... 7

2.1 Direct and Indirect Effects Boundaries ............................................................................................................. 9 2.2 Cumulative Effects Boundaries ............................................................................................................................ 9

3. METHODOLOGY ................................................................................................................................................... 9

3.1 Data Sources ........................................................................................................................................................... 9 3.2 Analysis Tools ......................................................................................................................................................... 9 3.3 Assumptions .......................................................................................................................................................... 10 3.4 Limitations .............................................................................................................................................................. 10 3.5 Methods .................................................................................................................................................................. 10

4. AFFECTED ENVIRONMENT .............................................................................................................................. 10

4.1 Culture History ..................................................................................................................................................... 10 4.2 Cultural Inventory Status ................................................................................................................................... 16 4.3 Site Summary ......................................................................................................................................................... 18

4.3.1 Number of Recorded Sites ........................................................................................................................ 18 4.3.2 Estimation of Additional Sites ................................................................................................................... 32 4.3.3 Existing Condition of Cultural Sites ......................................................................................................... 34

5. ENVIRONMENTAL CONSEQUENCES .......................................................................................................... 35

5.1 Effects Common to All Alternatives ................................................................................................................ 35 5.1.1 Direct and Indirect Effects ......................................................................................................................... 36 5.1.2 Cumulative Effects ........................................................................................................................................ 37

5.2 Effects by Each Alternative ................................................................................................................................. 38 5.3 Irreversible or Irretrievable Effects .................................................................................................................. 47 5.4 Effects of Plan Amendment ................................................................................................................................ 47

6. CONSISTENCY WITH LAWS, REGULATIONS, AND EXISTING FOREST PLAN ........................... 47

7. REFERENCES ........................................................................................................................................................... 49

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ii SFNF Geothermal Leasing EIS Cultural Resources Specialist Report May 2016

LIST OF FIGURES Figure 1. Map showing overview of the project area and planning units. ............................................................ 8

Figure 2. Map showing the extent of survey coverage in the project area. ...................................................... 17

Figure 3. Map showing the previously recorded sites and survey coverage in the project area. ................. 19

Figure 4. Map showing the distribution of previously recorded sites in the project area, specific to the North Unit (Map 1 of 5). ................................................................................................................................... 22

Figure 5. Map showing the distribution of previously recorded sites in the project area, specific to the Lease Interest Unit (Map 2 of 5). .................................................................................................................... 23

Figure 6. Map showing the distribution of previously recorded sites in the project area, specific to the Middle Unit (Map 3 of 5). .................................................................................................................................. 24

Figure 7. Map showing the distribution of previously recorded sites in the project area, specific to the JNRA Unit (Map 4 of 5). .................................................................................................................................... 25

Figure 8. Map showing the distribution of previously recorded sites in the project area, specific to the South Unit (Map 5 of 5). .................................................................................................................................... 26

Figure 9. Map showing the distribution of site type in the project area, specific to the North Unit (Map 1 of 5). ............................................................................................................................................................ 27

Figure 10. Map showing the distribution of site type in the project area, specific to the Lease Interest Unit (Map 2 of 5). ............................................................................................................................................. 28

Figure 11. Map showing the distribution of site type in the project area, specific to the Middle Unit (Map 3 of 5). ............................................................................................................................................................ 29

Figure 12. Map showing the distribution of site type in the project area, specific to the JNRA Unit (Map 4 of 5). ............................................................................................................................................................ 30

Figure 13. Map showing the distribution of site type in the project area, specific to the South Unit (Map 5 of 5). ............................................................................................................................................................ 31

Figure 14. Hot Spot map of currently identified site distribution and density in the project area. ............. 33

Figure 15. Alternative 2; map showing areas closed to leasing. ........................................................................... 39

Figure 16. Alternative 2; map showing areas subject to controlled surface use. ............................................. 40

Figure 17. Alternative 2; map showing areas subject to no surface occupancy. .............................................. 41

Figure 18. Alternative 2; map showing areas subject to timing limitations. ....................................................... 42

Figure 19. Alternative 4; map showing areas closed to leasing. ........................................................................... 43

Figure 20. Alternative 4; map showing areas subject to controlled surface use. ............................................. 44

Figure 21. Alternative 4; map showing areas subject to no surface occupancy. .............................................. 45

Figure 22. Alternative 4; map showing areas subject to timing limitations. ....................................................... 46

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May 2016 SFNF Geothermal Leasing EIS Cultural Resources Specialist Report iii

LIST OF TABLES

Table 1. Summary of Survey Coverage in the Project Area .................................................................................. 16

Table 2. Summary of Levels of Survey Coverage in the Project Area ................................................................ 18

Table 3. Summary of Sites Recorded in the Project Area ..................................................................................... 20

Table 4. Summary of Frequency of Site Eligibility in the Project Area ............................................................... 21

Table 5. Summary of Cultural Affiliation of Sites in the Project Area ................................................................ 21

Table 6. Summary of Frequency of Sites Recorded in the Project Area ............................................................ 32

Table 7. Frequency of Sites Located within Lease Stipulation Areas for Alternative 2 .................................. 38

Table 8. Frequency of Sites Located within Lease Stipulation Areas for Alternative 4 .................................. 47

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iv SFNF Geothermal Leasing EIS Cultural Resources Specialist Report May 2016

ACRONYMS AND ABBREVIATIONS

AMSL Above Mean Sea Level BLM Bureau of Land Management CEQ Council on Environmental Quality COM Complete Cultural Resource Surveys CFR Code of Federal Regulations EIS Environmental Impact Statement EO Executive Order ESRI Environmental Systems Research Institute FSH Forest Service Handbook ft feet GIS Geographic Information System IO Isolated Occurrence Jemez Jemez Mountains LTC Less Than Complete Cultural Resource Surveys m meters NEPA National Environmental Policy Act NHPA National Historic Preservation Act NRHP National Register of Historic Places OHV Off Highway Vehicles PEIS Programmatic Environmental Impact Statement SFNF Santa Fe National Forest SHPO State Historic Preservation Office TCP Traditional Cultural Property THPO Tribal Historic Preservation Office USFS United States Forest Service USGS United States Geological Survey

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May 2016 SFNF Geothermal Leasing EIS Cultural Resources Specialist Report v

SUMMARY

The Santa Fe National Forest (SFNF) is analyzing the effects of proposed geothermal leasing on cultural and other resources in the Jemez Mountains, New Mexico. In 2008, a Record of Decision for the Programmatic Environmental Impact Statement (PEIS) for geothermal Leasing for Exploration and Development on Federal Lands Administered by the Bureau of Land Management (BLM) and United States Forest Service (USFS) was completed. The SFNF determined that additional site-specific environmental analysis was required to supplement the PEIS to make decisions about the availability of lands for geothermal leasing by the BLM. Environmental Management and Planning Solutions, Inc. (EMPSi) was contracted by the SFNF to prepare an Environmental Impact Statement (EIS) that addresses geothermal leasing on lands within the SFNF. As part of the EIS, this report summarizes the potential environmental impacts on cultural resources by geothermal electrical power generation on the SFNF. The purpose of this report is to provide a broad-scale GIS overview and a general analysis of the cultural resources in the project area.

Cultural resources in New Mexico and on the SFNF are subject to a variety of federal guidelines, policies, and programmatic agreements including the National Environmental Policy Act of 1969, National Historic Preservation Act of 1966, Archaeological Resource Protection Act of 1979, the Programmatic Agreement among the United States Department of Agriculture Forest Service Region 3, First Amended Agreement Regarding Historic Property Protection and Responsibilities. Currently, no site-specific areas are planned for development and no ground-disturbing undertaking will directly result from the preparation of this EIS. The preparation of this document as the cultural resources portion of the larger EIS is in compliance with the National Environmental Policy Act of 1969, and associated regulations, as it outlines the potential impacts the proposed project could impose on cultural resources. Though this report summarizes relevant Federal law and regulations, this report does not specifically address compliance with the National Historic Preservation Act of 1966, as amended, and therefore does not meet the requirements specified in the Region 3 Programmatic Agreement for approving cultural resource clearance. Separate environmental compliance will be required for the project for subsequent phases of leasing and development for subsequent project specific activities associated with leasing and development if a decision is made to authorize geothermal leasing.

The project area encompasses approximately 194,910 acres in the Jemez Mountains (Jemez) that the United States Geological Survey (USGS) identified as having significant geothermal potential. Land ownership in the project area consists of 26,212 acres of private land, 48 acres owned by the State of New Mexico or other government (non-USFS) agencies, and 168,650 acres owned by the USFS. The BLM has received expressions of interest of leasing approximately 46,260 acres of the SFNF on the Jemez, Cuba, Coyote, and Espanola Ranger Districts of the SFNF for the exploration and development of geothermal energy production.

Archaeologists have surveyed a total of 102,002 acres, or 52.33 percent, of the project area including all levels of survey on SFNF, private, and State lands. Many previous surveys (of various survey levels) are overlapping and therefore cultural resource surveys have covered 233,643 acres in 965 survey projects. A total of 1962 cultural resources sites have been identified within the 102,002 total surveyed acres in the project area.

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1. INTRODUCTION

1.1 Project Overview

The Santa Fe National Forest (SFNF) is analyzing the effects of proposed geothermal leasing on cultural and other resources in the Jemez Mountains, New Mexico. In 2008, a Record of Decision for the Programmatic Environmental Impact Statement (PEIS) for geothermal Leasing for Exploration and Development on Federal Lands Administered by the Bureau of Land Management (BLM) and United States Forest Service (USFS) was completed. The SFNF determined that additional site-specific environmental analysis was required to supplement the PEIS to make decisions about the availability of lands for geothermal leasing by the BLM. Environmental Management and Planning Solutions, Inc. (EMPSi) was contracted by the SFNF to prepare an Environmental Impact Statement (EIS) that addresses geothermal leasing on lands within the SFNF. As part of the EIS, this report summarizes the potential environmental impacts on cultural resources by geothermal electrical power generation on the SFNF.

1.2 Relevant Policy, Regulation and Guidance

Cultural resources in New Mexico and on the SFNF are subject to a variety of federal guidelines, policies, and programmatic agreements. The relevant administrative directives that structure the current project as it applies to cultural resources on USFS lands are summarized below.

Federal Laws

The Antiquities Act of 1906: This act provided the earliest, and most basic, legislation for protecting cultural resources on Federal lands. It provides misdemeanor-level criminal penalties to control unauthorized uses. Appropriate scientific uses may be authorized through permits, and materials removed under a permit must be permanently preserved in a public museum. It also authorized the President to proclaim national monuments for the purpose of protecting sites and objects of antiquity. The Antiquities Act of 1906 is broader in scope than the Archaeological Resources Protection Act of 1979, which partially supersedes it.

The Historic Sites Act of 1935: This legislation declared “a national policy to preserve for public use historic sites, buildings, and objects.” It established the Historic American Buildings Survey and Historic Engineering Record, as well as the National Historic Landmarks Survey.

The National Historic Preservation Act of 1966, as amended: This act created the National Register of Historic Places (NRHP) and the posts of State Historic Preservation Offices (SHPOs), to encourage the preservation of historical and archaeological sites on federal, state, and private lands. The act requires Federal agencies to consider the effects of their undertakings on National Register properties through a process commonly known as the “Section 106 review.” The act was amended in 1976 to clarify that National Register eligible—not just listed—properties were to be considered in the review and again amended in 1992 to emphasize, among other things, that the interests and involvement of Native Americans and Native Hawaiians were critical in the review as well.

The National Trails System Act of 1968: This act authorized a national system of trails and defined four types of trails including National Scenic Trails (NST), National Historic Trails (NHT), National Recreational Trails (NRT), and Connecting or Side Trails. The act provided expansion of “opportunities

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for the American people to use and enjoy the natural, scenic, historic, and outdoor recreational areas of the Nation.”

The National Environmental Policy Act of 1969: This act requires that federal agencies employ systematic and interdisciplinary approaches to integrate the natural and social in planning and decision-making about actions that may have an impact on the environment and biosphere. It outlined a national policy to “preserve important historic, cultural, and natural aspects of our national heritage.”

Archeological and Historic Preservation Act of 1974: This legislation amended the Reservoir Salvage Act of 1960 to provide for the preservation of significant scientific, prehistoric, historic, and archeological materials and data that might be lost or destroyed as a result of federally sponsored projects. It provided that up to one percent of project costs could be applied to survey, data recovery, analysis, and publication of the results.

The Federal Land Policy and Management Act of 1976: This act declared that “…the public lands be managed in a manner that will protect the quality of scientific, scenic, historical, ecological, environmental, air and atmospheric, water resource, and archeological values.” It also states that “Terms and conditions must minimize damage to scenic and aesthetic values and fish and wildlife habitat and otherwise protect the environment.”

The American Indian Religious Freedom Act of 1978: This act established national policy designed to protect and preserve, for Native Americans, their inherent right of freedom to believe, express, and exercise their traditional religions (including the rights of access to religious sites, use and possession of sacred objects), and freedom to worship through traditional ceremonies and rites.

The Archaeological Resources Protection Act of 1979, as amended: This act provided for the protection of archaeological resources and sites that are on public lands, and Native American tribal lands, and encouraged increased cooperation and the exchange of information between governmental authorities and other appropriate parties to improve protection of these resources. It defined archaeological resources as material remains of past human activities that are of archeological interest and at least 100 years old. It requires federal permits for excavation and removal of archaeological materials and established penalties for violators. In addition, it provided for preservation and custody of these materials and associated records and data, and required the confidentiality of archaeological site locations.

The Native American Graves Protection and Repatriation Act of 1990: This act provides a process for museums and Federal agencies to inventory and identify the cultural affiliations of Native American human remains and associated funerary objects in their possession or under their control in order to provide for repatriation of these items. A similar process required summaries of information about unassociated funerary objects, sacred objects, and objects of cultural patrimony in order to repatriate these objects to the appropriate lineal descendants, culturally affiliated Indian tribes, or Native Hawaiian organizations when they request them. The act assigns ownership or control of Native American human remains, funerary objects, sacred objects, and other objects of cultural patrimony excavated or discovered on federal or tribal lands after 1990 to identified lineal descendants, affiliated tribes or Native Hawaiian organizations; it also provides for criminal penalties for trafficking in human remains, funerary objects, or objects of patrimony.

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Federal Regulations

Title 36 CFR Part 60: This addresses the nomination to, as well as, the removal of sites from, the National Register of Historic Places.

Title 36 CFR Part 63: This lays out the process for federal agencies to obtain determinations of National Register eligibility for properties.

Title 36 CFR Part 68: This contains the Secretary of the Interior’s standards for historic preservation projects, including protection, stabilization, preservation, and rehabilitation.

Title 36 CFR 79: This provides for the curation of federally owned and administered archaeological collections and specifies standards, procedures and guidelines for long term storage and research access to such collections.

Title 36 CFR Part 800: This provides for the protection of historic properties and includes regulations to implement Section 106 of the National Historic Preservation Act, as amended.

Title 43 CFR Part 3: This provides procedures for permitting excavation and collection of prehistoric and historic objects on federal lands.

Title 43 CFR Part 7, Subparts A and B: This contains necessary definitions, standards, and procedures for federal land managers to protect archeological resources, and clarifies permitting procedures and issues regarding civil penalties.

Title 43 CFR Part 10: These are the regulations for determining how lineal descendants, Indian tribes, and Native Hawaiian organizations can establish affiliation with and claim possession of human remains, funerary objects, sacred objects, or objects of cultural patrimony.

Presidential Executive Orders

Executive Order 11593 (1971): This EO instructs all federal agencies to identify and nominate to the National Register cultural properties under their jurisdiction and to exercise caution that any potentially eligible property is not inadvertently transferred, demolished, or substantially altered.

Executive Order 12898 (1994): This EO urges federal agencies to avoid disproportionate and adverse effects on low-income people and minority groups and their heritage in their actions.

Executive Order 13007 (1996): This EO instructs federal land management agencies to accommodate access to Indian sacred sites to the extent practicable, permitted by law, and not inconsistent with essential agency functions.

Executive Order 13084 (1999): This EO provides instructions with regard to consultation and coordination with Native American tribal governments.

Executive Order 13195 (2001): This EO specifies agency support and interagency coordination regarding the implementation of a national program protecting and interpreting recreational, historic, and cultural trails.

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Executive Order 13287 (2003): This EO establishes a new program, Preserve America, designed to provide leadership in preserving America’s heritage by actively advancing the protection, enhancement, and contemporary use of the historic properties owned by the federal government.

In addition to the laws, regulations, and policies listed above, there is a Programmatic Agreement, the First Amended Programmatic Agreement Regarding Historic Property Protection and Responsibilities Among New Mexico Historic Preservation Officer and Arizona State Historic Preservation Officer and Texas State Historic Preservation Officer and the Advisory Council on Historic Preservation and United States Department of Agriculture Forest Service Region 3 and its associated protocols, regarding the manner in which USFS will meet its responsibilities under the National Historic Preservation Act.

Cultural Resource Site Definition on the SFNF

The criteria for cultural resource sites in USFS Region 3, including on the Santa Fe National Forest, are defined in the Forest Service Handbook (FSH) 2309.24. The FSH 2309.24 defines cultural resources sites as a locus of purposeful human activity that resulted in the deposition of cultural material, excluding the deposit of one or more unintentionally deposited/lost artifacts. Criteria for cultural resource sites on the SFNF include:

• One or more features.

• At least one formal tool if associated with other cultural materials.

• An occurrence of cultural materials (such as pottery sherds, chipped stone or historic items) that contains one of the following:

three or more types of artifacts or raw materials.

two types of artifacts or materials in a density of at least 10 items per 100 square meters.

a single type of artifact or material in a density of at least 25 items per 100 square meters.

The boundaries of sites minimally include all features, formal tools, and identifiable activity areas and all areas of artifactual debris exhibiting evidence of ten or more cultural items per 100 square meters. These criteria may be modified based upon the judgment of the recording archaeologist. Cultural material remains that do not meet the above criteria are considered isolated occurrences (IOs).

National Register of Historic Places (NRHP) Eligibility

The significance of cultural resource sites in USFS Region 3 and on the SFNF are evaluated by the property’s eligibility for inclusion in the National Register of Historic Places (NRHP), which are outlined in 36 CFR 60. As defined in 36 CFR 60.4, cultural resources may be eligible for inclusion in the NRHP if they "possess integrity of location, design, setting, materials, workmanship, feeling and association" and if the resources in question are resources:

a) that are associated with events that have made a significant contribution to the broad patterns of our history; or

b) that are associated with the lives of persons significant in our past; or

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c) that embody the distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or

d) that have yielded, or may be likely to yield, information important in prehistory or history.

Prehistoric archaeological sites are typically considered eligible in the NRHP under Criterion D for their local and regional significance and their potential to yield important information, although they may be nominated under any of the four Criteria. Historic archaeological sites are more frequently nominated under Criteria A–C, because the historic record allows them to be tied with greater confidence to specific themes, persons, and styles or construction techniques; however, they too may be nominated under Criterion D for the potential to yield important information. The NRHP eligibility recommendations used for the project consisted of eligible for inclusion in the NRHP, not eligible for inclusion in the NRHP, or undetermined. IOs, by definition, are considered not eligible for inclusion in the NRHP.

If significance has been established, it is necessary to determine if the resource retains the integrity for which it is significant. The evaluation of integrity is often subjective but must always be grounded in an understanding of a resource's physical features and how they relate to its significance. A resource that retains its integrity will possess several, and usually most, of the following:

• Location—the place where the historical resource was constructed or the specific place where the historical event took place. Location involves relationships that exist between the resource and place.

• Setting—the physical environment of a historic property. Setting relates to the character of the place in which the resource played its historical role.

• Design—the combination of elements that create the form, plan, space, structure, and style of a property.

• Materials—the physical elements that were deposited during a particular period of time and in a particular pattern or configuration to form a historic property (a site, building, structure, object, or district).

• Workmanship—the physical evidence of the crafts of a particular culture or people during any given period in history or prehistory.

• Feeling—the property's expression of the aesthetic or historical sense of a particular period of time.

• Association—the direct link between an important historical event or person and a historic property.

Resources that have been substantially altered after the period of significance may not retain sufficient integrity to reflect their original character. A single major change and/or the cumulative effect of numerous minor changes may diminish the integrity of cultural resources. Integrity is always evaluated with respect to the significance of the resource and the period of significance.

Certain kinds of properties are not usually considered for listing in the National Register: religious properties, moved properties, birthplaces and graves, cemeteries, reconstructed properties,

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commemorative properties, and properties achieving significance within the last fifty years. These properties can be eligible for listing under the following conditions:

• A religious property is eligible if it derives its primary significance from architectural or artistic distinction or historical importance.

• A property removed from its original or historically significant location can be eligible if it is significant primarily for architectural value or it is the surviving property most importantly associated with a historic person or event.

• A birthplace or grave of a historical figure is eligible if the person is of outstanding importance and if there is no other appropriate site or building directly associated with his or her productive life.

• A cemetery is eligible if it derives its primary significance from graves of persons of transcendent importance, from age, from distinctive features, or from association with historic events.

• A reconstructed property is eligible when it is accurately executed in a suitable environment and presented in a dignified manner as part of a restoration master plan and when no other building or structure with the same associations has survived. All three of these requirements must be met.

• A property primarily commemorative in intent can be eligible if design, age, tradition, or symbolic value has invested it with its own exceptional significance.

• A property achieving significance within the past fifty years is eligible if it is of exceptional importance.

Another kind of cultural significance a property may possess and that may make it eligible for inclusion to the NRHP is traditional cultural significance. "Traditional" in this context refers to those beliefs, customs, and practices of a living community of people that have been passed down through the generations, usually orally or through practice. A traditional cultural property (TCP) can be defined generally as one that is eligible for inclusion in the National Register because of its association with cultural practices or beliefs of a living community that (a) are rooted in that community's history, and (b) are important in maintaining the continuing cultural identity of the community. A separate ethnographic overview and assessment of traditional and current land uses by Native Americans and other communities is in preparation by the Forest Service and therefore ethnographic information including the location and impact on TCPs is not extensively discussed in this report.

Definition of Adverse Effect for Cultural Resources

Agencies, in consultation with SHPO/THPO, make assessments of adverse effect on historic properties prior to any undertaking. If the agency and SHPO/THPO agrees that there will be no adverse effect on cultural resources from the undertaking, the agency can proceed. If they agree there is an adverse effect, the agency must consult to avoid, minimize, or mitigate the adverse effects. As defined in 36 CFR 800.5.a.1, adverse effects include any undertaking that:

may alter, directly or indirectly, any of the characteristics of a historic property that qualify the property for inclusion in the National Register in a manner that would diminish the integrity of the property's location, design, setting, materials, workmanship,

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feeling, or association. Consideration shall be given to all qualifying characteristics of a historic property, including those that may have been identified subsequent to the original evaluation of the property's eligibility for the National Register. Adverse effects may include reasonably foreseeable effects caused by the undertaking that may occur later in time, be farther removed in distance or be cumulative.

Examples of adverse effect are provided in 36 CFR 800.5.a.2 and include, but are not limited to:

• Physical destruction of or damage to all or part of the property

• Alteration of a property, including restoration, rehabilitation, repair, maintenance, stabilization, hazardous material remediation and provision of handicapped access, that is not consistent with the Secretary’s Standards for the Treatment of Historic Properties (36 CFR 68) and applicable guidelines

• Removal of the property from its historic location

• Change of the character of the property’s use or of physical features within the property's setting that contribute to its historic significance

• Introduction of visual, atmospheric or audible elements that diminish the integrity of the property's significant historic features

• Neglect of a property which causes its deterioration, except where such neglect and deterioration are recognized qualities of a property of religious and cultural significance to an Indian tribe or Native Hawaiian organization

• Transfer, lease, or sale of property out of Federal ownership or control without adequate and legally enforceable restrictions or conditions to ensure long-term preservation of the property's historic significance.

1.3 Scope of this Report

The purpose of this report is to provide a broad-scale GIS overview and a general analysis of the cultural resources in the project area. The analysis resulted in summary data on the affected environment and the potential for adverse impacts on cultural resources. Though this report summarizes relevant Federal law and regulations, this report does not specifically address compliance with the National Historic Preservation Act (NHPA) of 1966, as amended, and therefore does not meet the requirements outlined in Section 106 and specified in the Region 3 Programmatic Agreement for approving cultural resource clearance. Separate environmental compliance will be required for the project for subsequent phases of leasing and development.

2. ANALYSIS AREA

The project area encompasses approximately 194,900 acres that the United States Geological Survey (USGS) identified as having significant geothermal potential (Figure 1). Land ownership in the project area consists of 26,212 acres of private land, 48 acres owned by the State of New Mexico or other government (non-USFS) agencies, and 168,650 acres owned by the USFS. The BLM has received expressions of interest of leasing approximately 46,260 acres of the project area on the Jemez, Cuba,

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Figure 1. Map showing overview of the project area and planning units.

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Coyote, and Espanola Ranger Districts of the SFNF (Lease Interest Unit) for the exploration and development of geothermal energy production. The project area is divided into five planning units including (from north to south) the North Unit (67,975 acres), Lease Interest Unit (39,225 acres), Middle Unit (14,101 acres), JNRA Unit (39,244 acres), and South Unit (34,355 acres). All of the current pending geothermal leases are located within the Lease Interest Unit.

2.1 Direct and Indirect Effects Boundaries

Direct and indirect effects boundaries are restricted to within and near the project area in specific geothermal leasing areas planned for development. The vast majority of the direct effects are limited to the areas where infrastructure will be developed (e.g., geothermal power plants, access roads, transmission lines, and other related infrastructure). Indirect effects are primarily expected within the project area, often outside of construction or developed areas. For example, the development of access roads and other infrastructure can alter the drainage patterns of a given area and impact areas down slope outside of developed areas. Boundaries of direct and indirect effects are further discussed in the effects common to all alternatives section later in the document.

2.2 Cumulative Effects Boundaries

Unlike direct and indirect effects, cumulative effects have the potential to extend outside of the project area. Cumulative effects of the project can impact larger existing boundaries, such as traditional cultural properties and use-areas, canyons/valleys, drainage channels and watersheds, and vegetation/environmental zones. Boundaries of cumulative effects are further discussed in the effects common to all alternatives section later in the document.

3. METHODOLOGY

3.1 Data Sources

The geographic information system (GIS) data used in this project was provided by EMPSi and was originally compiled by the USFS. The data provided to PaleoWest included the project boundary, five planning unit boundaries, 965 previous pedestrian survey boundaries, and polygons of the 1963 cultural resource site locations. Pedestrian survey attributes include, but are not limited to, survey number, survey protocol (complete, less than complete, and not applicable), method, project type, and acreage. Cultural resource site attributes associated with the site polygons include, but are not limited to, site number, site type (prehistoric, historic, both, and unknown), NRHP eligibility, and site area. Details concerning the previous surveys and identified cultural resource sites are presented in the cultural inventory status and site summary sections later in the document.

3.2 Analysis Tools

ESRI’s ArcGIS 10.3 was used to create GIS maps of the project area and site distributions as well as determine acreage and site frequency and distribution by planning unit. QGIS, an open source GIS, was used to produce the “hot spot” map showing projected site density. No complex analyses were conducted as part of this project.

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3.3 Assumptions

• The cultural resource GIS data provided by the USFS is current and accurate as of the Fall of 2015.

• If a decision is made to lease in the area, the SFNF and BLM will ensure the requirements of NHPA and other pertinent Federal laws, regulations, and programmatic agreements are met during the development process.

3.4 Limitations

Because the purpose of this document is simply to provide a broad-scale GIS overview and a general analysis of the cultural resources in the project area, limitations are restricted to the variation in levels of survey and gaps in survey coverage. As discussed later in the document, not all of the project area has been subjected to cultural resource surveys (see Cultural Inventory Status section). Not all of the current survey areas were completely covered by valid or complete surveys and many of those surveys do not meet current SFNF standards.

3.5 Methods

For the current document, the GIS data was reviewed and summarized for both the project area and specific planning units. Maps were created to show the distribution of identified sites and previous surveys within the project area. Estimation of additional sites were based on the amount of previous survey coverage in each planning unit in conjunction with currently known site densities.

4. AFFECTED ENVIRONMENT

4.1 Culture History

The culture history of the Jemez Mountains (Jemez) reflects the broad framework developed for the Northern Rio Grande region. The project area lies on the west side of a cultural-historical region that archaeologists variously designate as the Northern Rio Grande (Crown et al. 1996; Fowles 2004) or the Upper Rio Grande (Stuart and Gauthier 1981), although Cordell (1979) includes the area in her Middle Rio Grande. Crown et al. (1996) divide the northern Rio Grande cultural-historical region into six districts (Taos, Gallina, Chama, Pajarito, Santa Fe, and Jemez), three of which (Chama, Jemez, and Pajarito) encompass the project area.

During the Paleoindian period (9,500–6,500 B.C.), highly mobile groups of the Southwest subsisted by hunting now-extinct large mammals using distinctive lanceolate projectile points and gathering wild resources (Cordell 1997; Willey and Phillips 1958). These groups primarily inhabited lower elevations in the plains-grassland environments and following bison or other big game species (Cordell 1979; Stuart and Gauthier 1981). The Paleoindian occupation of the Jemez was relatively sparse, though these early hunter-gatherers utilized Jemez flaked stone sources and perhaps hunted and foraged within the mountains (Elliot 1986; Wolfman 1994). Few Paleoindian sites have been documented in the Jemez including one site on Cañones Mesa and one on the Pajarito Plateau (Anschuetz and Merlan 2007). Jemez obsidian and Pedernal chert Clovis points and debitage have been found at the Demolition Road site near Albuquerque, from the Mockingbird Gap site south of Socorro, and at other sites in New Mexico (Hamilton et al. 2013; Huckell et al. 2008; Kilby et al. 2005; Warren 1974). Few Folsom, Agate

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Basin, and Milnesand points have been found in the eastern and southern Jemez (Powers and Zandt 1999). A late Paleoindian James Allen point was found near Chama, New Mexico that was made from the El Rechuelos obsidian source (known by archaeologists as Polvadera Peak) located on the northern end of the Jemez (Dello-Russo and Walker 2008). Jemez obsidian has also been found on other Paleoindian sites in central New Mexico and west Texas. Because Jemez obsidian is present in alluvial gravels down the Rio Grande, the raw material for these artifacts were not necessarily procured in the Jemez (Anschuetz and Merlan 2007).

The Archaic period (6500 B.C.–A.D. 600) marked a transition in the subsistence strategy to reliance on the hunting of modern species of animals and the gathering of various wild plants (Willey and Phillips 1958). Irwin-Williams (1973) developed a chronological classification to characterize the Archaic period in the greater Southwest, known as the Oshara Tradition. The classification was developed based on archaeological investigations in the Arroyo Cuervo region, located between the Rio Puerco of the East and the Jemez River and incorporating a portion of the project area. The Oshara Tradition comprises five phases including Jay (5500–4800 B.C.), Bajada (4800–3200 B.C.), San Jose (3000–1800 B.C.), Armijo (1800–800 B.C.), and En Medio (800 B.C.–A.D. 600). Although the overall utility of the Oshara Tradition as a developmental sequence has been questioned by some (Matson 1991; Stuart and Gauthier 1981; Berry and Berry 1986), associated projectile point styles appear to have some validity as chronometric indicators (Acklen et al. 1997; Turnbow 1997). The Archaic period marked a period of gradual increase in the use of the Jemez by hunter-gatherer groups. Pollen cores in the Jemez suggest period of decreased effective moisture occurring ca. 6500–4400 B.C., between dates for the Late Paleoindian and Early Archaic occupation of the mountains, though few isolated Jay and Bajada phase camps and quarry sites have been identified in the Jemez (Irwin-Williams 1973; Vierra et. al 2012). This environmental change had a significant impact on the subsistence strategies of Early Archaic hunter-gatherers and they adapted to a north-south residentially mobile settlement pattern throughout the Northern Rio Grande region. Higher moisture regimes returned to the Jemez in the Middle Archaic that allowed for the expansion of pinyon-juniper woodlands to the Northern Rio Grande and Jemez, likely resulting in logistical trips for pinyon collection in the fall season. Several small Middle Archaic campsites/workshops have been identified in the southern Jemez and numerous Archaic period sites have been found and investigated in the Valles Caldera, the Redondo Valley, the Rio del Oso and Chama River Valleys, and other localities suggesting use of a large portion of the mountain range (Anschuetz 1996; Cordell 1979:23; Wolfman 1994). During the Late Archaic, populations increased in the Jemez. The earliest maize in the Jemez was found at the Late Archaic site Jemez Cave that yielded a radiocarbon date of 1040 B.C. (Vierra and Ford 2007). The cave was used seasonally, likely in the spring and fall, by mobile Late Archaic foragers. Ojala Cave in the eastern Jemez (Pajarito Plateau) also yielded maize kernels dating to 670 and 590 B.C. (Powers and Zandt 1999). Based upon investigations in the Rendondo Creek Valley, the most intensive Archaic use of the Jemez occurred during a period between 600 B.C. and A.D. 400 (Anschuetz and Merlan 2007).

The Developmental period (A.D. 600–1200) marks the appearance of ceramics in the Jemez and greater Northern Rio Grande region (Wendorf and Reed 1955). Around this time, subsistence strategies in the Jemez changed from hunting and gathering to an increased reliance on agriculture (Anschuetz and Merlan 2007). During the seventh century, ceramic types in the southern Jemez consisted of Lino Gray, White Mound Black-on-white, San Marcial Black-on-white, and brown wares indicating ties to the Colorado Plateau and Middle/Lower Rio Grande Valley (Anschuetz 1996; Elliot 1986). Eighth and ninth century ceramics found in the region include Kana-a Gray, Alma Neck-Banded, Kiatuthlana Black-on-

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white, La Plata Black-on-red, Abajo Black-on-orange, and brown and red wares (Anschuetz and Merlan 2007). The presence of these ceramic types also suggests ties to groups in the Four Corners region including some trade with Mogollon groups to the south. Developmental period sites are conspicuously absent from the majority of the Jemez and greater Northern Rio Grande region, though few small sites have been identified in the Jemez River Valley near modern Jemez Pueblo and a higher density has been found on the Pajarito Plateau (Anschuetz 1996; Powers and Zandt 1999; Wolfman 1994). The initial colonization of pueblo farmers in the eastern Jemez (Pajarito Plateau) occurred during the late Developmental period (ca. A.D. 1100s) and continued into the subsequent early Coalition period (Powers and Orcutt 1999).

The frequency and density of occupation in the Jemez increased significantly during the Coalition period (A.D. 1200–1325), primarily with the southern Jemez and Pajarito Plateau, likely resulting at least in part from immigration of groups who abandoned the Four Corners region, Western Pueblos, and the Gallina region (Anschuetz 1996; Elliot 1986). During the Coalition period, at least ten substantial villages were established in the southern Jemez and up to 19 pueblos existed on the Pajarito Plateau (Anschuetz and Merlan 2007). Two sites in the southern Jemez exhibit evidence of local production of Mesa Verde Black-on-white and St. Johns Polychrome, also suggesting groups from the Colorado Plateau migrated to the Jemez (Sundt 1991). The appearance of organic-painted pottery (e.g., Santa Fe and Galisteo Black-on-white) during this period has also has been interpreted as evidence of migration of groups from the Four Corners area (Powers and Zandt 1999). Gallina ceramics appear in the southern Jemez in greater abundance after A.D. 1250, coinciding with the abandonment of the Gallina area (Elliot 1986) and few instances of Gallina-like architecture has been noted in the southern Jemez area (Anschuetz 1996). Two separate large-scale population increases attributed to immigrations onto the Pajarito Plateau, probably from groups abandoning the Four Corners region, occurred ca. A.D. 1220–1250 and 1290–1325 (Powers and Orcutt 1999). Larger, aggregated settlements appeared in the southern Jemez, the eastern Jemez (Pajarito Plateau), and north and northeastern Jemez (Chama River Valley). During this time, ceramic and architectural practice and site layout differed among each of the pueblo groups living in and around the Jemez. In the early Coalition period, pueblos in the southern Jemez consisted of contiguous structures of generally up to 50 rooms (and sometimes up to 100-150 rooms as the case with Vallecito Viejo I and II, LA248 and 258, respectively) and Santa Fe Black-on-white dominated ceramic assemblages (Anschuetz 1996; Wolfman 1994). On the Pajarito Plateau, habitation structures consisted of an average of 28 rooms, with one pueblo comprised of over 100 rooms, and ceramic assemblages primarily consisted of Kwahe’e and Santa Fe Black-on-white. Vallecito Black-on-white, a local variant of Santa Fe Black-on-white, appeared in the southern Jemez during the late Coalition period. The population again increased during the late Coalition period, perhaps from migrants to the west and northwest. On the Pajarito Plateau, villages ranged from 10 to 300 rooms and many included several plazas and multiple kivas.

The Classic period (A.D. 1325–1700) represents a peak in population density in the Jemez, beginning with a substantial population increase around A.D. 1350 (Anschuetz 1996; Elliot 1986). Settlements shifted from the floodplains and valley bottoms to mesa tops. In the southern Jemez, pueblos consisted of up to 1,850 rooms with over 30 pueblos comprised of 250 or more rooms (including several listed on the National Register) and Jemez Black-on-white dominated ceramic assemblages (Wolfman 1994). Field house sites (1-2 room structures) were abundant, comprising 75 percent of recorded Classic Period site components in the SFNF Jemez River District site database (Anschuetz 1996). Some of the highest elevation farming in the Northern Rio Grande region occurred in the southern Jemez during this

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time (up to ca. 8,400 ft AMSL). In the eastern Jemez, the population contracted and aggregated to large villages. At this time, 18 pueblos averaging 400 rooms each were concentrated on the southwest edge of the Pajarito Plateau. Architectural changes reflected the need to accommodate larger populations and pueblos were constructed up to three stories in height (Powers and Orcutt 1999). Ceramic assemblages on the eastern and northern Jemez more closely resembled Northern Rio Grande wares (Wiyo Black-on-white, Biscuit A and B, and Tsankawi Black-on-cream), distinct from the southern Jemez traditions (e.g., Jemez Black-on-white). In the northern Jemez along the Chama River, farmers began to construct extensive pebble-mulch grid gardens and terraces (Lightfoot and Eddy 1995; Periman 1995). The gardens were typically constructed above the river valleys on Pleistocene fluvial terraces with sandy sediment. Pollen samples recovered from few of the gardens have yielded evidence of maize and native cotton production. Gridded agricultural terraces/gardens have also been identified in the southern Jemez (Anschuetz 1996). In the southern Jemez along Jemez Canyon, groups farmed flat areas and field houses and small caves used for storage dotted the landscape (Fliedner 1975). These field house sites were generally clustered along the edges of level/flat areas, adjacent to farm plots. The field houses typically contained fireplaces, stone-chests (for storage), and ground stone tools such as metates. Additional rectangular structures, known as ‘observation cabins’, also dot the landscape an average of 400 m apart in the higher elevations of Jemez Canyon. These structures have been interpreted as features similar to watch towers, perhaps to guard the canyon from raiding Athapaskan and other Pueblo groups. Populations were concentrated in multi-roomblock pueblos comprised of up to 2,000 rooms (Anschuetz 1996). In the late Classic period within the lands of Bandelier National Monument, few large pueblos were constructed but cavates accounted for nearly two-thirds of habitations (Powers and Orcutt 1999). By A.D. 1450, the Chama River Valley and the northern Jemez was abandoned as Tewa groups moved to the south and east. Approximately 100 years later (ca. A.D. 1550), the Pajarito Plateau was abandoned for aggregated villages along the Rio Grande to the east. Prior to and after the arrival of the Spanish in New Mexico, the southern Jemez area was continuously occupied except for a few brief hiatuses during and after the Pueblo Revolt.

The first Spanish expedition, led by Francisco de Barrionuevo, reached the southern Jemez in A.D. 1541 and recorded seven pueblos (Anschuetz and Merlan 2007; Holmes 1905). Additional Spanish expeditions reached the southern Jemez in A.D. 1581 (Rodriguez-Chamuscado expedition) and A.D. 1583 (Espejo-Beltran expedition), leaving little effect on the southern Jemez (Towa) people. Don Juan de Oñate y Salazar visited the southern Jemez in A.D. 1598, crossing the Valles Grande and encountering eight villages and learning of the presence of other inhabited villages around the area. The Spanish officially colonized New Mexico in A.D. 1598 and established the first European capital in the United States at San Juan de los Caballeros. The capital was located west of the meeting of the Rio Grande and Chama River near Espanola, New Mexico. The Spanish relocated the capital to the abandoned Tewa pueblo of Caypa the following year and named the settlement San Gabriel de Yungue. In A.D. 1598, the first priest, Fray Alonso de Lugo, was assigned to the Jemez mission at Giusewa (Elliot 1986). The population of the Jemez region remained relatively steady from contact in the mid-16th century until the establishment of permanent missions in the A.D. 1620s (Liebmann et al. 2016). Kulisheck (2001,2005) examined 30 field house sites and found an increase in the use of the region between A.D. 1525 to 1650, suggesting that disease may not have been a major factor in demographic change during the 17th century in the Jemez.

The arrival of Spanish missionaries and settlers in the early seventeenth century resulted in increased interaction between pueblo and Spanish people and considerable depopulation of the Jemez region due to labor exploitation and disease (Wolfman 1994). During the seventeenth century, four or five missions

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were established among the southern Jemez groups. Beginning in the A.D. 1620s, the establishment of missions resulted in widespread depopulation of the southern Jemez area through pestilence, warfare, and famine as well as probable low-density out-migration. Liebmann et al. (2016) found the majority of the southern Jemez (Towa) depopulation occurred in the six decades between AD 1620-1680, declining from approximately 6,500 to 850 individuals, and representing a decline in population of 87 percent. Tensions escalated among the pueblo and the Spanish and eventually priests at Jemez and Taos were killed in the 1630s (Roberts 2004). In the mid-seventeenth century, the vast majority of the upland sites were abandoned in the southern Jemez and the remaining population was forcibly relocated to new areas in the Jemez River Valley.

Because of the harsh treatment of the Spanish, the Jemez and numerous other Pueblos participated in the Pueblo Revolt of 1680, resulting in the death of one of the Jemez missionaries. Po’Pay (or Popé), a religious leader from Ohkay Owingeh, led the revolt and planned the orchestrated attacks in Taos during his stay in the northern Tiwa pueblo. The Pueblo Revolt was conducted by most of the pueblos throughout northern Arizona and New Mexico, though southern Tiwa groups declined to participate and Piro groups were not invited.

Governor Antonio de Otermin undertook the initial reconquest of New Mexico in 1681 (Dougherty 1980). At this time, he found the Towa villages along the Jemez River completely abandoned for so-called refugee pueblos. These pueblos were located in highly defensive positions, some of which still contain piles of throwing stones at the edge of mesas near defensive walls and habitation structures. After the Pueblo Revolt, a number of these refugee pueblos were occupied in and around the Jemez including the Towa villages of Astialakwa and Patokwa, the Towa and Keres village of Boletsakwa, the Keres villages of Cerro Colorado and Kotyiti, the Tewa village on Black Mesa, and several others (Elliot 2002; Liebmann and Preucel 2007). Most of these post-Revolt refugee pueblos in the southern and eastern Jemez represent what Liebmann and Preucel (2007) refer to a post-Revolt pueblo revitalization movement that included the construction of new, planned dual-plaza pueblos on defensible mesas. The dual plazas reflected moietal societal organization in architecture and settlement patterns, perhaps linked to Po’pay’s call for revivalism. The villages attracted refugee puebloans from a myriad of pueblo groups from the Jemez (Towa), Keres, Tiwa, and Tewa regions. Small pueblo groups also occupied other smaller settlements in the Jemez, including cavates in the eastern Jemez (Powers and Zandt 1999).

After the Revolt of 1680 and subsequent failed reconquests, the Spanish retreated from the New Mexico province and settled at Nuestra Señora de Guadalupe near El Paso, Texas for 12 years. Additional Spanish reconquests occurred during A.D. 1692 and 1693. The Spanish eventually re-conquered and resettled Santa Fe in A.D. 1694 and subsequently turned their attention to the Northern Rio Grande pueblos (Anschuetz and Merlan 2007). During the reconquest in late April of 1694, De Vargas attacked Kotyiti. The Spanish and their allies killed 8 pueblo warriors, captured 13 warriors and 342 pueblo people and their food supplies, and subsequently burned the pueblo. A few days later, the pueblo people launched a counter-attack, only losing four pueblo warriors and freeing more than half of the 342 captives (Roberts 2004). In July of 1694, De Vargas attacked Astialakwa and killed 84 pueblo people, captured over 350 women and children, and sacked and burned the pueblo. In September of 1694, de Vargas attacked the refugee pueblo on Black Mesa with allies from other pueblo groups including the Jemez. The Black Mesa refugees surrendered after several days of attack from the Spanish and their allies. In 1696, crop failure, food shortages, and uprisings in Taos, Picuris, Santo Domingo, Cochiti, San Ildefonso, and Jemez led the pueblo people to once again occupy refugee pueblos around

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the Jemez. Other refugees left for settlements among the Navajo and other pueblos. The reoccupation of the refugee pueblos in and around the Jemez was short-lived as the Spanish again attacked and eventually subdued and relocated the refugee pueblo groups to pueblos along the rivers.

In 1703, the Jemez people had returned to Walatowa to build the current pueblo and mission (Elliot 2002). After A.D. 1700s, use of the Jemez was restricted to Walatowa Pueblo and occasional seasonal use of the mountains. By the A.D. 1730s, several Spanish settlers arrived immediately north of the Jemez in the Chama River Valley and established the town of Santa Rosa de Lima de Abiquiu (Glover 1990). At that time the settlement was the third largest in New Mexico. Ute and Comanche raids on the settlement in A.D. 1747 resulted in the temporary abandonment of the area and subsequent raids took a toll on local Hispanic and Genizaro residents. In the eighteenth century the Spanish government approved land grants to Spanish and Genizaro families in and around the Jemez, aimed at expanding the Spanish resettlement of New Mexico. Selected grants around the Jemez include the Cañada de Cochití Grant in 1728, Rito de los Frijoles around 1740 (though was abandoned after probable Athapaskan raids), Abiquiu Genizaro Land Grant in 1754, Ojo de San José Grant on Vallecitos Creek in 1768, and the Canyon de San Diego Land Grant in 1798 (Anschuetz and Merlan 2007; Glover 1990). By the late eighteenth century, Hispanic pastoralists began to use the Valles Caldera.

The Anglo and Hispanic use of the Jemez in the nineteenth century represented sheep and cattle grazing, logging, hunting, and mining. During this time, Navajo and Apache groups continued to conduct raids in the Northern Rio Grande region, including Navajo attacks in and around the Jemez on small Anglo and Hispanic settlements in A.D. 1851, 1853, and 1857 (Anschuetz and Merlan 2007). In A.D. 1810 Mexico declared independence from Spain, which was officially recognized in A.D. 1821 with the singing of the Treaty of Cordova. In A.D. 1829, Antonio Armijo led 60 individuals and 100 mules from New Mexico to California paving a route that ultimately became known as the Old Spanish Trail. The Old Spanish Trail was used throughout the 19th century as a trade route that connected New Mexico with various tribes and California. In A.D. 1846, the United States Army (Army of the West) began to occupy New Mexico. Shortly after in A.D. 1848 the lands of New Mexico were ceded to the United States under the Treaty of Hidalgo, beginning American influence, primarily in the form of the United States military, in the region. Lieutenant James Simpson is credited for leading one of the first American explorations into the Jemez in A.D. 1849 (Elliot 1986). He led an expedition up the Jemez River valley and observed the ruins of Giusewa. In A.D. 1863, the U.S. Army established Camp Valles Grande in the Valles Caldera as a deterrent to the Navajo and Apache occupation of the Jemez area (Anschuetz and Merlan 2007).

Archaeological and ethnographic research in the Jemez region began in the late nineteenth century with the work of Bandelier (1890). Around the same time, sheep and cattle grazing occurred in the valleys of the Jemez by Spanish and Basque herders. In the late nineteenth century, the Atchison, Topeka, and Santa Fe (AT&SF) and the New Mexican Railroad, a subsidiary of the AT&SF, were planned to run through Jemez Canyon, though the plans were temporarily abandoned (Glover 1990). The Jemez Forest Reserve was created in 1905 and in 1915 the SFNF was created by combining the Jemez and Pecos Forest Reserves. By the early twentieth century, private American companies began purchasing land in and around the Jemez to exploit the coal, copper, and sulfur mining as well as harvest the vast timber forest.

In the early twentieth century, Parsons (1925) conducted ethnographic investigations at Jemez and Jeancon (1923) excavated portions of Poshuouinge in 1919, a large Classic Period Tewa pueblo in the

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north Jemez along the Chama River. Around the same time, pueblo flintknappers continued to use flaked stone sources in the northern Jemez, such as Cerro Pedernal (Warren 1974). The planned AT&SF railroad spur was eventually constructed in 1922, primarily for large-scale timber harvesting by the White Pine Lumber Company that began in the Jemez in 1924. The rail line ran through Jemez Pueblo land, authorized by the (Federal) Pueblo Lands Condemnation Act of 1926 that was enacted in 1928 (Anschuetz and Merlan 2007). Timber extracted from the mountains was transported by train to the south and milled in Bernalillo, New Mexico. In the 1930s, four Civilian Conservation Corps camps were located within the SFNF that constructed numerous features in the Jemez including cattle fences and guards, dams and erosion control, roads, trails, and picnic areas. Timber extraction eventually ceased in 1941 when the Rio Guadalupe and Jemez River flooded, effectively destroying several miles of track and several bridges. During World War II most of the locomotives from the rail line were scrapped for metal to supplement the war effort (Glover 1990). In the 1960s, geothermal potential was discovered in the Jemez, centered on the Valles Caldera (Anschuetz and Merlan 2007).

Contemporary Native American and Hispanic land grant-descendant communities have ties to the Jemez Mountains and forest lands and maintain religious and traditional cultural practices, and economic and resource uses. These interests include natural landscape features seen as sacred, shrines, trails, ancestral archaeological sites, springs, minerals, medicinal and subsistence plants, hunting, fishing, and livestock grazing. These interests and communities are not limited to the many Pueblos and Hispanic communities in the vicinity of the forest, but include other groups in Northern New Mexico that have associations with the Jemez Mountains, either through intertribal relationships, or more sporadic occupation of lands or resource use.

Recreation, logging, hunting, and low-density habitation dominate modern activities in the Jemez. These activities are primarily seasonal with recreation concentrated in the warm seasons, hunting in the fall, and snowshoeing and skiing in the winter. A few families currently live on private inholdings in the Jemez.

4.2 Cultural Inventory Status

Archaeologists have surveyed a total of 102,002 acres, or 52.33 percent, of the project area including all levels of survey on SFNF, private, and State lands (Table 1; Figure 2). Many previous surveys are overlapping and therefore cultural resource surveys have covered 233,643 acres in 965 survey projects. Most of the higher-density of survey coverage is in the central and southern portion of the project area in the South and Middle Units. Two categories of surveys are recognized on the SFNF, including valid/complete (COM) and less than complete (LTC) (Table 2). The distinctions between intensive or complete and less than complete surveys are outlined below.

Table 1. Summary of Survey Coverage in the Project Area Planning Unit Acres Surveyed Total Acres in Unit Percent Surveyed North Unit 21081.21 67975.32 31 South Unit 26541.99 34355.62 77 JNRA Unit 20180.58 39243.82 51 Middle Unit 13834.03 14100.89 98 Lease Interest Unit 20364.39 39224.93 52 TOTAL 102002.21 194900.60 52

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Figure 2. Map showing the extent of survey coverage in the project area.

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Table 2. Summary of Levels of Survey Coverage in the Project Area

Planning Unit COM Surveys

COM Acreage

LTC Surveys

LTC Acreage

Unknown (N/A) Surveys

Unknown (N/A) Acreage

North Unit 40 7928.78 40 16994.41 29 10308.10 South Unit 68 19162.16 103 23693.88 135 42911.28 JNRA Unit 121 15663.53 120 9317.79 105 21335.03 Middle Unit 35 4760.99 22 5263.64 21 16410.73 Lease Interest Unit 47 7042.55 41 11295.11 38 21554.61 TOTAL 311 54558.01 326 66564.83 328 112519.8

Intensive Surveys

Valid or complete (COM) surveys on the SFNF consist of surveys led or conducted by a trained archaeologist with transect intervals spaced 15 meters or less apart in 100% of the survey area. Some areas of high angle slopes (i.e., 40 degrees or more) may not have been systematically surveyed during these surveys because of the low probability of cultural resources on high angle slopes, which is consistent with modern USFS standards. Intensive/complete surveys were summarized in technical reports submitted to the USFS that included a methodological section outlining the survey methods. A total of 53 percent of the surveyed area or 28 percent of the total project area, has been subjected to 311 valid or complete surveys.

All Levels of Surveys

Less than complete (LTC) surveys consist of surveys that do not meet the SFNF standards of valid (complete) surveys. These surveys are not considered valid for several reasons including the projects were led or conducted:

• by a trained archaeologist

with transect intervals greater than 15 meters (up to 25 meters), or

lacking verifying documentation (i.e., technical report) submitted to the SFNF, or

that submitted a technical report lacking a methodological section outlining the survey methods, or

in less than 100% percent of a given project area (sample surveys)

• by a para-archaeologist (non-archaeologist with brief training in archaeological methods)

A total of 65 percent of the project area has been subjected to 326 not valid or less than complete surveys. Over 100,000 acres has been subjected to 328 surveys where the level of survey is unknown or not applicable.

4.3 Site Summary 4.3.1 Number of Recorded Sites

A total of 1962 cultural resources sites have been identified within the 102,002 surveyed acres in the project area (Table 3; Figure 3). A single National Historic Trail, the Old Spanish National Historic Trail, is located just north of (but not included in) the project area. The recorded boundaries of five sites span two planning units, which creates some overlap that is reflected in the tabular summaries below.

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Figure 3. Map showing the previously recorded sites and survey coverage in the project area.

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20 SFNF Geothermal Leasing EIS Cultural Resources Specialist Report May 2016

Table 3. Summary of Sites Recorded in the Project Area Planning Unit Total Sites NRHP Eligible Sites NRHP Listed Sites North Unit 219 18 — South Unit 1216 218 5 JNRA Unit 454 48 1 Middle Unit 15 — — Lease Interest Unit 63 6 — TOTAL 1962 288 6

These numbers do not include TCPs or other ethnographic sites. General areas of concern as traditional use areas in the Jemez are known, but specific locations of traditional cultural resources, plant gathering areas, and other important locations are not generally revealed unless imminently threatened. The SFNF regularly consults on a government-to-government basis with federally recognized tribes and engages with communities on the impacts of their actions and programs.

It should also be noted that the project area and therefore the number of sites described does not include those on adjacent lands at the Valles Caldera National Preserve and Bandelier National Monument. It is understood that there are extensive cultural resources bordering the project area in these Park Service units. These lands are closed to leasing, but effects on historic properties and TCPs and traditional cultural resources that could be affected by subsequent leasing and development would be included in the required environment compliance for those actions.

Cultural resource sites in the project area include (but are not limited) to rock art panels, rubble mounds/habitations (including several substantial pueblo villages), field house and agricultural sites, campsites, activity areas, lithic scatters and quarries, ranching and livestock grazing sites, railroad and logging sites, and other various prehistoric and historic site types. Cultural resource sites in the project area are of various shapes and sizes and each site and site type require site type-specific treatment plans.

The most highly visible sites in the project area are more recent historic sites from the last 100 years or so including railroad and logging sites, easily observable from the modification of the local topography and the presence of surface trash dumps/scatters. The majority of historic sites in the project area are more visible and easier to identify and evaluate than other proto- and prehistoric sites that are buried by alluvium, colluvium, and thick duff. Large Coalition through Post-Revolt settlements are also fairly easy to identify during survey because of the presence of rubble mounds and extensive artifact scatters. Small lithic scatters and other limited activity sites that often include buried features are often difficult to identify from pedestrian survey only.

Before the late Developmental Period (ca. A.D. 1100), the vast majority of sites in the Jemez generally consisted of smaller sites with few artifacts and features reflecting seasonal use of the mountains. An exception to this is large lithic procurement sites that surround obsidian and chalcedony outcrops that occur in the mountains, which have been visited since Paleoindian times. After the late Developmental Period, large contiguous masonry and adobe structures were constructed that represents the Towa and Keres migrations into the southern and eastern Jemez, respectively. Smaller field house sites near areas of agricultural productivity also dot the landscape. These large structures and associated field house, limited activity area, and other types of sites were constructed in the Jemez until the late 17th century (aside from Walatowa in the early 18th century). Small herding sites from land grants and other individuals are found within the mountains during the 18th through 20th centuries. During the 20th

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century, Anglo groups (companies) began to exploit the mountains for its resources, leaving logging and mining camps and other associated infrastructure and sites.

In the GIS data provided by EMPSi, only 405 sites included eligibility recommendations. Eligibility recommendations of 1557 sites were not reported and should be treated as Unevaluated for the purpose of the EIS. Of the sites with eligibility recommendations, six are listed on the National Register, 288 are recommended eligible, 21 are recommended not eligible, and 90 are unevaluated (Table 4; Figures 4–8).

Table 4. Summary of Frequency of Site Eligibility in the Project Area Planning Unit Total Sites Eligible Listed Not Eligible Unevaluated Not Reported North Unit 219 18 — 1 32 168 South Unit 1216 218 5 11 38 944 JNRA Unit 454 48 1 5 10 390 Middle Unit 15 — — — 2 13 Lease Interest Unit 63 6 — 4 9 44 TOTAL 1962 288 6 21 90 1557

Six properties in the project area are listed on the National Register of Historic Places including one in the JNRA Unit (LA56557 [Virgin Logging Camp #2]) and five in the South Unit (LA303 [Sayshukua], LA475 [Totaskwina], LA478 [Wabakwa], LA386, and LA5920). LA675, known as Gíusewa Pueblo (Jemez State Monument), is listed on the National Register of Historic Places, a National Historic Landmark (#12001007), and located within the project area but is on land owned by the State of New Mexico. All of the above sites aside from the logging camp (LA56557) were listed under a National Register Multiple Property nomination (Jemez Cultural Developments in North-Central New Mexico).

Human occupation of the Jemez spans from the earliest identified culture in the United States (Paleoindian) to the present (Table 5; Figures 9–13). The vast majority of cultural resource sites identified in the project area are prehistoric (n=1054; 54 percent). A total of 143 sites (7 percent) are historic, 368 sites (19 percent) have both prehistoric and historic components, 388 sites (20 percent) are unknown, and the cultural affiliation of 9 sites (less than 1 percent) was not reported. Eight sites are linear sites such as roads and trails.

Table 5. Summary of Cultural Affiliation of Sites in the Project Area Planning Unit Total Sites Prehistoric Historic Both Unknown Not Reported North Unit 219 51 23 8 137 — South Unit 1216 769 71 208 163 5 JNRA Unit 454 221 39 152 39 3 Middle Unit 15 — 2 1 11 1 Lease Interest Unit 63 14 9 — 40 — TOTAL 1962 1054 143 368 388 9

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22 SFNF Geothermal Leasing EIS Cultural Resources Specialist Report May 2016

Figure 4. Map showing the distribution of previously recorded sites in the project area, specific to the North Unit (Map 1 of 5).

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Figure 5. Map showing the distribution of previously recorded sites in the project area, specific to the Lease Interest Unit (Map 2 of 5).

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24 SFNF Geothermal Leasing EIS Cultural Resources Specialist Report May 2016

Figure 6. Map showing the distribution of previously recorded sites in the project area, specific to the Middle Unit (Map 3 of 5).

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Figure 7. Map showing the distribution of previously recorded sites in the project area, specific to the JNRA Unit (Map 4 of 5).

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26 SFNF Geothermal Leasing EIS Cultural Resources Specialist Report May 2016

Figure 8. Map showing the distribution of previously recorded sites in the project area, specific to the South Unit (Map 5 of 5).

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May 2016 SFNF Geothermal Leasing EIS Cultural Resources Specialist Report 27

Figure 9. Map showing the distribution of site type in the project area, specific to the North Unit (Map 1 of 5).

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28 SFNF Geothermal Leasing EIS Cultural Resources Specialist Report May 2016

Figure 10. Map showing the distribution of site type in the project area, specific to the Lease Interest Unit (Map 2 of 5).

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May 2016 SFNF Geothermal Leasing EIS Cultural Resources Specialist Report 29

Figure 11. Map showing the distribution of site type in the project area, specific to the Middle Unit (Map 3 of 5).

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30 SFNF Geothermal Leasing EIS Cultural Resources Specialist Report May 2016

Figure 12. Map showing the distribution of site type in the project area, specific to the JNRA Unit (Map 4 of 5).

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Figure 13. Map showing the distribution of site type in the project area, specific to the South Unit (Map 5 of 5).

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32 SFNF Geothermal Leasing EIS Cultural Resources Specialist Report May 2016

More than half of the sites in the project area (n=1152) are situated between 7,000 and 8,000 feet AMSL. One site occurs at an elevation of less than 6,000 feet, 201 sites are between 6000–7000 feet, 494 sites are between 8000–9000 feet, and 113 sites occur at elevations over 9000 feet. Only 11 have been located over 10,000 feet in elevation.

4.3.2 Estimation of Additional Sites

Although a predictive model is outside of the scope of this report and was not completed, current site distribution of previously surveyed areas allows for an informed estimation of site density in non-surveyed areas. A total of 1962 sites were recorded in 52 percent of the project area. If the current survey areas are representative of the entire project area then approximately 3,500–4,000 total sites are expected in the project area with 100% survey coverage (Table 6). A hot spot analysis was conducted to show the current distribution and density of recorded sites and is presented in Figure 14. Areas with the highest density are in red, orange, and yellow and areas with the lowest density are in green.

Table 6. Summary of Frequency of Sites Recorded in the Project Area

Planning Unit Acres Surveyed Total Sites Sites per

100 Acres Percent Surveyed

Additional Estimated Sites

North Unit 21081 219 1.04 31 500 South Unit 26542 1216 4.59 77 400 JNRA Unit 20181 454 2.26 51 450 Middle Unit 13834 15 0.11 98 <5 Lease Interest Unit 20364 63 0.31 52 60 TOTAL 102002 1962 1.92 52 1500

Planning unit-specific expectations for additional sites are presented below. These estimations are based on the recorded site density and percentage of the unit surveyed; assuming current surveys and site density are representative of the entire planning unit areas. However, less than complete surveys likely have missed sites and therefore the actual site density may be slightly higher throughout much of the project area.

• North Unit: approximately 500 additional sites are expected because of the moderate site density (roughly 1 per 100 acres) and relatively low survey coverage (31 percent).

• South Unit: a few hundred additional sites (approximately 400) are expected because of the high site density (roughly 4.6 per 100 acres) and high amount of survey coverage (77 percent).

• JNRA Unit: approximately 450 sites are expected based on site density (roughly 2.3 per 100 acres) and approximately half survey coverage (51 percent).

• Middle Unit: few additional sites (less than 5) are expected in the Middle Unit because of the high amount of survey coverage (98 percent) and low density of sites (0.11 sites per 100 acres).

• Lease Interest Unit: several dozen sites (approximately 60) sites are expected based on the low site density (roughly 0.3 per 100 acres) and approximately half survey coverage (52 percent).

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Figure 14. Hot Spot map of currently identified site distribution and density in the project area.

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34 SFNF Geothermal Leasing EIS Cultural Resources Specialist Report May 2016

Some of the surveys conducted in the project area are considered not valid or less than complete and therefore may have failed to document every cultural resource site (as defined by the SFNF) within a given survey area (see Cultural Inventory Status section above). In addition, heavy pine duff and dense downed trees are present throughout a substantial portion of the project area which may have obscured the ground surface and therefore cultural resource sites. Because sites may have been missed by previous surveys, the actual frequency of sites within the project area may be higher than the provided estimates. Additional cultural resource clearance work would be conducted prior to subsequent phases of leasing and development and would include identification, evaluation, effects analysis, consultation and resolution of adverse effects.

4.3.3 Existing Condition of Cultural Sites

Historic and modern use of the Jemez Mountains includes livestock grazing, timber sales (logging), forest thinning, public wood cutting, wildland and prescribed fire, and recreation/vandalism. Unintended adverse effects occurred to cultural resources prior to implementation of federal preservation law as a result of past activities including many that are limited to isolated, small-scale disturbances. However, continued small-scale disturbances to these sites are cumulative and eventually lead to larger-scale impacts if the effects are not monitored and reduced or mitigated.

Livestock grazing, primarily of cattle in the Jemez, reduces ground cover and expedites erosion of cultural resources sites. Livestock trails and grazing disturb the surface distribution of artifacts and has the potential to break/destroy artifacts though compaction due to the immense weight of grazing livestock. In addition, grazing infrastructure such as stock tanks, fence lines, and other developments has the potential to adversely impact cultural resources.

For nearly 40 years, timber sales (logging) and thinning projects have been considered Federal undertakings. During much of that time sites were avoided as the preferred treatment measure to reduce the effects on sites. Avoiding thinning in the vicinity of cultural resource sites has resulted in “islands” of isolated vegetation patches and increased fuel loads on significant sites. These increased fuel loads have the potential to adversely impact sites through intense burning (see fire effects below). As outlined in the Region 3 Programmatic Agreement, more recent projects undertaken on the SFNF have reduced these fuel-load issues by hand clearing within sites and surface features to prevent intense burning on significant resources. In addition to logging and thinning, wood cutting by the public also poses a threat to the integrity of cultural resource sites. Live and deadwood cutting by the permitted public affects the surface distribution of artifacts and can damage surface features because the public is unaware of the location of and potential disturbances to cultural resource sites and features.

Fire has a profound effect on cultural resources across the Jemez and other public and private lands. Early fire management methods (twentieth century) concentrated on fire suppression, which increased fuels loads on cultural resource sites and in the forest in general. Fire suppression methods led to the preservation of many historic wooden features such as structures, fence lines, and so on. Modern methods of fire management focus on burning excess fuel loads that accumulated over the past century. Ryan et al. (2012) summarized effects of fire on cultural resources, specifically in relation to sites on Forest Service lands. Effects wildland and prescribed fires have on cultural resources include, but are not limited to, burning of wooden structures and other features, spalling of architectural stone/rubble and rock art panels, increased erosion/runoff that expedites site destruction, paint oxidation and color change of ceramic artifacts, and chemical alteration and fracturing of lithic debitage and tools.

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The Jemez is a modern recreation destination for many New Mexicans and tourists because of the many trails, scenic views, developed campsites, hot springs, and other geologic features. The abundance of recreational visitors in the Jemez has led to many user-created trails and roads, OHV trails, and other disturbances to cultural resource sites including site visitation and vandalism/looting. User-created trails and roads can displace artifacts, adversely impact surface features, and increase surface erosion. Several cultural resource sites, including a few sites listed on the National Register in the southern Jemez, have been vandalized by illegal digging/looting on the sites including within rubble mounds/rooms. Recreation on the forest has likely led to small-scale surface looting of highly-visible artifacts including projectile points and decorated sherds. Though these surface looting disturbances by recreational visitors are likely small-scale (few to a few dozen artifacts per person on each site per visit), the effects are compounded by numerous visits and eventually lead to larger-scale disturbances. The recent implementation of the Travel Management Rule may lessen the impacts on cultural resources by recreational users of the SFNF.

5. ENVIRONMENTAL CONSEQUENCES

5.1 Effects Common to All Alternatives

The Council on Environmental Quality (CEQ) defines three types of effects (or impacts) on resources including direct, indirect, and cumulative effects. Direct effects are defined as effects caused “by the action and occur at the same time and place” and indirect effects are defined as effects caused by “the action and are later in time or farther removed in distance, but are still reasonably foreseeable. Indirect effects may include growth inducing effects and other effects related to induced changes in the pattern of land use, population density or growth rate, and related effects on air and water and other natural systems, including ecosystems” (40 CFR 1508.8). Cumulative effects are defined as “the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonable foreseeable future action regardless of what agency (Federal or non-Federal) or person undertakes such other actions” (40 CFR 1508.7).

The significance of a historic property (i.e., a NRHP eligible district, site, structure, or object) is defined against a set of eligibility criteria summarized earlier in this document. A fundamental part of significance is the integrity of a cultural resource. Integrity refers to quality of context or state of completeness of a historic property. A site that has gradually fallen into “ruin” but not been disturbed by significant erosion or human actions since it was abandoned almost certainly still has integrity. Conversely, a site that has been greatly affected by either natural forces or human actions might have to be tested to see if it still has integrity. Sites that have been substantially altered may not retain sufficient integrity to reflect their original character. A single major change, or more often, the cumulative effect of numerous minor changes, may diminish integrity to the point where the significance of a site or group of sites becomes compromised.

The direct and indirect impacts of geothermal development in the Jemez place the integrity of cultural resource sites at risk. Site integrity is a key issue with regard to assessing the impacts on cultural resources in the project area. More specifically, the setting and feeling of cultural resources will be under increasing pressure. The setting of a resource refers to the physical environment and relates to the character of the place in which the resource played its role in the past. The feeling aspect of integrity refers to the property’s expression of the aesthetic or sense of a particular period of time.

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Ongoing consultation with representatives of pueblo and tribal groups indicates that the Jemez

Mountains are important as a sacred place, as a sacred landscape, or as a historic landscape. Groups fear

that geothermal energy development will have devastating effects on the area. This includes fears of

impacting the availability of water resources and the quality of water and effects on other resources that

are important to their heritage and ceremonies. In general, the representatives of the groups

interviewed were not in favor of geothermal energy development, or they expressed concerns regarding

the effects upon water quality and availability. Native American and Hispanic groups are also interested

in recovering ownership of lands that were part of their original land base and, therefore, they would be

concerned about committing lands to other uses. Many traditional sites are known only to the tribe and

sometimes knowledge is limited to only a handful of tribal members. Because some groups choose not

to report the location of site-specific ethnographic activities, reducing or mitigating effects to these

unrecorded ethnographic resources requires site-specific consultation by groups who traditionally used

and continue to use the Jemez.

5.1.1 Direct and Indirect Effects

Consent to leasing and leasing decisions do not grant any rights or authorize any activities that would

directly affect cultural or ethnographic resources. Direct effects of geothermal development typically

have the potential to destroy, damage, or alter the physical integrity of the historic properties and

ethnographic sites in proximity to the development activities. If a cultural resource is considered

significant for reasons in addition to its scientific use (i.e., it is eligible under NRHP criteria A, B, or C),

direct effects may also include the introduction of audible, atmospheric, or visual elements that are out

of character with the values of setting, feeling, and association for which the site was considered

significant. These types of effects should be evaluated as to their potential impact to the integrity of the

both cultural resource sites, TCPs, and other ethnographic sites. Development of geothermal

production within the Jemez would involve local areas of ground disturbance including exploration

drilling locations, geothermal power plants, staging areas, access roads, transmission lines, water

pipelines, and additional supporting structures and facilities. This development will result in direct

adverse effects to sites within construction areas requiring archaeological investigation that will

effectively destroy cultural resource and features while gathering significant archaeological data.

Although the disturbance associated with the construction of individual components of geothermal

development would be localized, the scale of development within the study area as a whole necessarily

will result in a much greater scale of disturbance. Any ground-disturbing activities have the potential to

destroy or diminish cultural and ethnographic resources, as well as the setting and context that may

contribute to their importance. Direct physical impacts are often irreversible.

Indirect impacts associated with geothermal development (i.e., alteration of the physical environment,

noise) change the setting and feeling of the landscape surrounding cultural resource and ethnographic

sites. Indirect effects may also redirect localized drainage patterns sites and allow for greater access and

unanticipated vandalism or OHV disturbance. Indirect effects are of greater concern than one might

initially expect. The degree to which geothermal development will affect the feeling and setting (i.e.,

integrity) of both individual sites and groups of sites (landscapes) is contingent upon cumulative effects.

For example, a single access road through a valley may not affect individual sites, but increased use of

this road to develop geothermal sites and the installation of transmission lines over a period of years

may diminish the setting and feeling of groups of sites. It also may indirectly contribute to increased

vandalism or off-road use of the area, which often results in significant long-term cumulative adverse

effects.

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Indirect physical impacts to cultural and ethnographic resources by geothermal development may also

include deterioration of structures, shrines, springs, or rock art from vibration, dust, or exhaust

produced by construction, drilling, or operation of geothermal facilities. Erosion and changes to

vegetation that result from off-site construction may also change the characteristics and integrity of

resources. TCPs and other ethnographic sites require site-specific consultation to reduce direct impacts

to these important traditional sites. Construction activities and operating geothermal power plants and

other infrastructure have the potential to alter the visual and auditory environment, which could

effectively diminish not only integrity of cultural resource sites but also the significance and traditional

power of ethnographic sites. Some important viewsheds from high peaks and mountains within and

surrounding the project area could be impacted by geothermal development. If the setting and feeling of

a site contribute to its importance, visual or auditory intrusions or deterioration of the local

environment could also constitute an indirect impact to the aesthetic quality of a site.

The construction of access roads to testing locations, geothermal production facilities, along

transmission lines, and other associated infrastructure has the potential to change localized drainage

patterns and direct them onto sites. Unimproved road maintenance often consists of continual road

blading that can eventually adversely impact deeply buried intact subsurface deposits. These activities can

ultimately lead to adverse impacts and destruction of intact subsurface deposits which contribute to the

site’s NRHP eligibility and importance as a TCP or other ethnographic site.

Another potential indirect impact of natural geothermal development in the Jemez is the increase in

human activity made possible by construction of access roads or transmission corridors in areas

containing cultural resource sites. Although these roads will be constructed for geothermal production,

roads and transmission corridors have the potential for use by motorized vehicles (particularly Off

Highway Vehicles or OHVs) to access previously remote areas surrounding sites associated with

geothermal production. This accessibility has the potential to result in greater incidental deterioration of

cultural resource sites through off-road traffic, vandalism, and looting. For example, uncontrolled OHV

use has been cited as the most "immediate and pervasive threat to cultural resources on BLM lands" in

southeastern Utah (Schiffman 2005).

5.1.2 Cumulative Effects

In simplest terms, cumulative effect refers to the outcome of multiple actions that result in additive or

interactive effects that can become greater than the sum of individual actions. The CEQ’S handbook

Considering Cumulative Effects Under the National Environmental Policy Act provides a framework for

advancing impact analysis by addressing cumulative effects. The handbook presents practical methods for

addressing coincident effects (adverse or beneficial) on specific resources, such as archaeological sites,

and not just the proposed project or alternatives that initiate the assessment process.

Clearly, the infrastructure (i.e., roads, new transmission lines, and other similar construction) associated

with intensive development of geothermal resources in the area has the potential to yield direct effects

to cultural and ethnographic resources in that they may be disturbed by construction. However, the

cumulative impact of indirect effects may pose an equal, or greater, problem. The cumulative effects of

geothermal development may diminish the feeling and setting aspects of integrity, as well as the

increasing long-term increase in access to the area, may endanger the eventual eligibility of a site or

group of sites to the NRHP several decades from now. The challenge of archaeological site protection is

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38 SFNF Geothermal Leasing EIS Cultural Resources Specialist Report May 2016

that it is not just for the next year or two, but for the long-term. If cultural resource sites were

renewable resources, this would not be such a problem, but these resources are not renewable.

Federal agencies routinely address the direct and (to a lesser extent) indirect effects of the proposed

action on the environment. Analyzing cumulative effects on cultural and ethnographic resources is more

challenging, primarily because not all of the resources have been identified (especially the ethnographic

resources) or fully understood from survey alone. Only by reevaluating and modifying alternatives in

light of the projected cumulative effects can adverse consequences to cultural resources be effectively

avoided or minimized. Considering cumulative effects is also essential to developing appropriate

mitigation and monitoring measures.

A cumulative effects analysis evaluates resource impacts on a larger scale than the type of impact analysis

conducted for single projects, or individual components of a given undertaking. Determining the

cumulative consequences of an action such as geothermal development requires delineating the cause-

and-effect relationships between the multiple actions of this undertaking and the cultural and

ethnographic resources within the region. The significance of cumulative effects depends on how they

compare with the baseline condition of sites in the study area and relevant regulatory standards for

cultural resources. Monitoring the accuracy of predictions and the success of mitigation measures is

critical to the ongoing study of cumulative effects.

5.2 Effects by Each Alternative

The direct, indirect, and cumulative effects for each alternative remain the same to cultural and

ethnographic resources as discussed in the effects common to all alternatives section above. The

differences between the alternatives are that each alternative has the potential to affect different

frequencies of cultural resource sites in different locations within, and outside of, the proposed lease

area. Cultural resource and ethnographic sites that lie within areas proposed as no surface occupancy,

controlled surface use, and timing limitations are subject to direct as well as indirect and cumulative

effects. Cultural resource and ethnographic sites that lie within areas proposed as closed to leasing are

subject to indirect and cumulative effects, though are not subject to direct effects.

Alternative 3 (No Leasing) would result in no direct effect to cultural resources. Alternatives 1 (No

Action), 2 (Proposed Action) and 4 (Development Alternative) could result in effects to cultural

resources. Alternative 1 does not specify lease stipulation areas, but as with the other alternatives there

would be site-specific analysis, and potential effects on cultural resources and their settings could be

avoided or reduced. The frequencies of sites located in each planning unit and lease stipulation area for

Alternatives 2 and 4 are summarized in Table 7 and Table 8. Figure 15 through Figure 18 show the

planning units, lease stipulation areas, and locations of recorded cultural resource sites for Alternative 2

and Figure 19 through Figure 22 show the same information for Alternative 4.

Table 7. Frequency of Sites Located within Lease Stipulation Areas for Alternative 2

Lease Stipulation North

Unit

South

Unit

JNRA

Unit

Middle

Unit

Lease Interest

Unit TOTAL

Closures 5 3 259 4 0 271

Controlled Surface Use 103 993 175 6 23 1300

No Surface Occupancy 132 1194 175 11 55 1567

Timing Limitations 4 854 151 9 1 1019

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Figure 15. Alternative 2; map showing areas closed to leasing.

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40 SFNF Geothermal Leasing EIS Cultural Resources Specialist Report May 2016

Figure 16. Alternative 2; map showing areas subject to controlled surface use.

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Figure 17. Alternative 2; map showing areas subject to no surface occupancy.

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Figure 18. Alternative 2; map showing areas subject to timing limitations.

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Figure 19. Alternative 4; map showing areas closed to leasing.

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Figure 20. Alternative 4; map showing areas subject to controlled surface use.

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Figure 21. Alternative 4; map showing areas subject to no surface occupancy.

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46 SFNF Geothermal Leasing EIS Cultural Resources Specialist Report May 2016

Figure 22. Alternative 4; map showing areas subject to timing limitations.

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Table 8. Frequency of Sites Located within Lease Stipulation Areas for Alternative 4

Lease Stipulation North Unit

South Unit

JNRA Unit

Middle Unit

Lease Interest Unit TOTAL

Closures 0 0 259 0 0 259 Controlled Surface Use 123 1036 175 10 51 1395 No Surface Occupancy 95 1195 175 15 42 1522 Timing Limitations 4 855 151 13 1 1024 5.3 Irreversible or Irretrievable Effects

Irreversible or irretrievable effects (or commitment of resources) refer to permanent impacts on resources that cannot be recovered or reversed. These effects are generally associated with non-renewable resources such as minerals or cultural resources (archaeological sites), but can also affect Traditional Cultural Properties and other ethnographic cultural resources. As previously discussed in this document, cultural resource sites are non-renewable resources, meaning once a site has been adversely impacted (including archaeological investigation or complete destruction), the resource cannot be restored or replicated. When a cultural resource site is impacted all scientific data is either fully documented/recovered by archaeological investigation (testing/data recovery) or lost by unintentional/uncontrolled site destruction. The same can occur with ethnographic resources, where sites such as springs, shrines, plant-gathering resources, and other sites can be impacted by development or alterations to setting which may result in the loss of traditional cultural significance by modern tribes.

5.4 Effects of Plan Amendment

There are no amendments to the plan at the current time.

6. CONSISTENCY WITH LAWS, REGULATIONS, AND EXISTING FOREST PLAN

Currently, no site-specific areas are planned for development and no ground-disturbing undertaking will directly result from the preparation of this EIS. The preparation of this document as the cultural resources portion of the larger EIS is in compliance with the National Environmental Policy Act (NEPA) of 1969, and associated regulations, as it outlines the potential impacts the proposed project could impose on cultural resources. This report does not specifically address compliance with the NHPA, ARPA, and other Federal laws, regulations, executive orders, and programmatic agreements. Because this report does not address compliance with the NHPA, it does not meet the requirements outlined in Section 106 and the Region 3 Programmatic Agreement for approving cultural resource clearance. The NHPA also requires Federal agencies, including the USFS and BLM, to provide the New Mexico SHPO an opportunity to comment on the proposed project. If leasing is approved in the area, the BLM and USFS will complete steps to meet the requirements of law and procedure prior to development including consultation with the New Mexico SHPO and American Indian Tribes.

Separate environmental compliance will be required for the project for subsequent phases of leasing and development. Compliance will include addressing direct effects with additional survey to standard and consultation on identification, evaluation and resolution of adverse effects which may include testing data recovery and other measures. If significant cultural resources are located, appropriate measures will be developed in consultation with the NM SHPO and consulting parties to address mitigation of adverse effects which may include data recovery and other measures. Areas covered by less than complete

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surveys will require resurveying and areas within and area development areas lacking survey coverage will require valid surveys. Modern site management practices focus on site protection/preservation and typically seek avoidance of significant cultural resource sites by development projects. The precedent for protecting cultural resource sites is outlined in the current SFNF forest plan. If significant cultural resources (i.e., NRHP eligible sites) are located within development areas and cannot be avoided, archaeological excavations will be required to mitigate the impacts to these resources. Monitoring should follow development to determine the impacts of indirect and cumulative effects on cultural resources within and near the project area. Additional mitigation may be required to reduce indirect and cumulative effects on cultural resources within and outside of the project area.

The current SFNF forest plan was originally published in July of 1987. Several amendments have been added to the plan since the initial publication. The USFS recognized the outdated nature of the forest plan and is currently in the process of completing an updated Forest plan, which was unavailable during preparation of the current document. Inventory, protection, evaluation, nomination, interpretation, and enhancement of cultural resources are the primary goals of activities related to cultural resources outlined in the current forest plan. Additional goals include coordinating with the New Mexico SHPO, other State and Federal agencies, and American Indian Tribes. Because no sites are currently threatened by development, this EIS acts in accordance with the forest plan.

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7. REFERENCES

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