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PC - Item 3B - Exhibit F - Appendix E Paleontological AssessmentPALEONTOLOGICAL ASSESSMENT FOR THE 8601 MISSION DRIVE PROJECT CITY OF ROSEMEAD, LOS ANGELES COUNTY, CALIFORNIA APNs 5389-009-029, -30, and -031 Prepared on Behalf of: Borstein Enterprises 11766 Wilshire Boulevard, Suite 820 Los Angeles, California 90025 Prepared for: City of Rosemead 8838 East Valley Boulevard Rosemead, California 91770 Prepared by: Brian F. Smith and Associates, Inc. 14010 Poway Road, Suite A Poway, California 92064 March 7, 2022 Paleontological Assessment for the 8601 Mission Drive Project _____________________________________________________________________________________________________________________ Paleontological Database Information Author: Todd A. Wirths, M.S., Senior Paleontologist, California Professional Geologist No. 7588 Consulting Firm: Brian F. Smith and Associates, Inc. 14010 Poway Road, Suite A Poway, California 92064 (858) 679-8218 Report Date: March 7, 2022 Report Title: Paleontological Assessment for the 8601 Mission Drive Project, City of Rosemead, Los Angeles County, California Prepared on Behalf of: Borstein Enterprises 11766 Wilshire Boulevard, Suite 820 Los Angeles, California 90025 Prepared for: City of Rosemead 8838 East Valley Boulevard Rosemead, California 91770 Prepared by: Brian F. Smith and Associates, Inc. 14010 Poway Road, Suite A Poway, California 92064 Assessor’s Parcel Numbers: 5389-009-029, -030, and -031 USGS Quadrangle: Section 18, Township 1 South, Range 11 West, on the USGS El Monte, California Quadrangle (7.5-minute) Study Area: 3.38 acres Key Words: City of Rosemead; Paleontological assessment; Holocene alluvial fan deposits; Low sensitivity; no monitoring recommended. Paleontological Assessment for the 8601 Mission Drive Project _____________________________________________________________________________________________________________________ Table of Contents Section Page I. INTRODUCTION AND LOCATION .........................................................................1 II. REGULATORY SETTING .........................................................................................1 State of California .....................................................................................................1 City of Rosemead ........................................................................................................4 III. GEOLOGY ...................................................................................................................4 IV. PALEONTOLOGICAL RESOURCES........................................................................4 Definition ....................................................................................................................4 Fossil Locality Search ................................................................................................6 V. PALEONTOLOGICAL SENSITIVITY ........................................................................6 Overview .....................................................................................................................6 Professional Standards ..............................................................................................6 Field Survey ................................................................................................................7 VI. CONCLUSIONS AND RECOMMENDATIONS .......................................................7 Paleontological MMRP..............................................................................................8 VII. CERTIFICATION ......................................................................................................10 VIII. REFERENCES..........................................................................................................10 Appendices Appendix A – Qualifications of Key Personnel Appendix B – Paleontological Records Search List of Figures Figure Page Figure 1 General Location Map .................................................................................2 Figure 2 Project Location Map ...................................................................................3 Figure 3 Geologic Map ...............................................................................................5 Paleontological Assessment for the 8601 Mission Drive Project _____________________________________________________________________________________________________________________ 1 I. INTRODUCTION AND LOCATION A paleontological resource assessment has been completed for the 8601 Mission Drive Project, located northeast of the intersection of Mission Drive and Walnut Grove Avenue in Rosemead, Los Angeles County, California (Figures 1 and 2). The 3.36-acre project occupies three parcels (Assessor’s Parcel Numbers 5389-009-029, -030, and -031). On the United States Geological Survey 7.5-minute, 1:24,000-scale El Monte, California topographic quadrangle map, the project is located in unsectioned Township 1 South, Range 11 West (projected), San Bernardino Baseline and Meridian (see Figure 2). The project will include the construction of 37 single-family residential lots with associated landscaping and infrastructure. Currently, the subject property is vacant. As the lead agency, the City of Rosemead has required the preparation of a paleontological assessment to evaluate the project’s potential to yield paleontological resources. The paleontological assessment of the project included a review of paleontological literature and fossil locality records in the area; a review of the underlying geology; and recommendations to mitigate impacts to potential paleontological resources, if necessary. II. REGULATORY SETTING The California Environmental Quality Act (CEQA), which is patterned after the National Environmental Policy Act, is the overriding environmental regulation that sets the requirement for protecting California’s paleontological resources. CEQA mandates that governing permitting agencies (lead agencies) set their own guidelines for the protection of nonrenewable paleontological resources under their jurisdiction. State of California Under “Guidelines for Implementation of CEQA,” as amended in December 2018 (California Code of Regulations [CCR] Title 14, Division 6, Chapter 3, Sections 15000 et seq.), procedures define the types of activities, persons, and public agencies required to comply with CEQA. Section 15063 of the CCR provides a process by which a lead agency may review a project’s potential impact to the environment, whether the impacts are significant, and provide recommendations, if necessary. In CEQA’s Environmental Checklist Form, one of the questions to answer is, “Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?” (Appendix G, Section VII, Part f). This is to ensure compliance with California Public Resources Code Section 5097.5, the law that protects nonrenewable resources, including fossils: Paleontological Assessment for the 8601 Mission Drive Project _____________________________________________________________________________________________________________________ 4 a) A person shall not knowingly and willfully excavate upon, or remove, destroy, injure or deface any historic or prehistoric ruins, burial grounds, archaeological or vertebrate paleontological site, including fossilized footprints, inscriptions made by human agency, rock art, or any other archaeological, paleontological or historical feature, situated on public lands, except with the express permission of the public agency having jurisdiction over such lands. b) As used in this section, “public lands” means lands owned by, or under the jurisdiction of, the state, or any city, county, district, authority, or public corporation, or any agency thereof. c) A violation of this section is a misdemeanor. City of Rosemead The General Plan Update of the City of Rosemead does not discuss paleontological resources (City of Rosemead 2010). III. GEOLOGY The project is located within the San Gabriel Valley Basin of the larger Los Angeles Basin, a large structural sedimentary basin bounded and cut through by several active fault systems in the Los Angeles metropolitan area (Hillhouse et al. 2002). The concrete-lined Rubio Wash, a tributary to the Rio Hondo, flows southward approximately a quarter mile east of the project. As mapped by Tan (1998), the project is underlain by unconsolidated Holocene sandy and gravelly young alluvial fan and valley deposits (pale tan and yellow areas labeled “Qyfa” and “Qyfag,” respectively, on Figure 3). IV. PALEONTOLOGICAL RESOURCES Definition Paleontological resources are the remains of prehistoric life that have been preserved in geologic strata. These remains are called fossils and include bones, shells, teeth, and plant remains (including their impressions, casts, and molds) in the sedimentary matrix, as well as trace fossils such as footprints and burrows. Fossils are considered older than 5,000 years of age (Society of Vertebrate Paleontology 2010) but may include younger remains (subfossils), for example, when viewed in the context of local extinction of the organism or habitat. Fossils are considered a nonrenewable resource under state and local guidelines (see Section II of this report). Paleontological Assessment for the 8601 Mission Drive Project _____________________________________________________________________________________________________________________ 6 Fossil Locality Search A prior paleontological locality and records search was performed for the nearby 12247 Elliott Avenue Project by the Natural History Museum of Los Angeles County (LACM) (Bell 2021 [Appendix B]). The 12247 Elliott Avenue Project is located in El Monte, approximately four miles southeast of the current project, and covered an area several miles distant. The records search indicates that no fossil localities were identified within the current project boundaries or within a five-mile radius. The closest-known fossil localities are located at the Puente Hills Landfill, about five-and-a-half to six miles southeast of the 8601 Mission Drive Project, consisting of Pleistocene-age marine vertebrates and invertebrates (LACM VP 6350- 6362; LACM IP 16968-16991). The nearest terrestrial Pleistocene locality is identified near Monterey Pass Road, about six miles to the southwest, just southwest of Monterey Park (LACM VP 3363). Other, more distant localities are summarized in the records search in Appendix B. A review of published and unpublished literature was conducted for potential paleontological resources that are known in the vicinity of the project. The sources reviewed, Miller (1971) and Jefferson (1991), did not indicate the presence of any known fossil localities within or nearby the project. V. PALEONTOLOGICAL SENSITIVITY Overview The degree of paleontological sensitivity of any particular area is based on a number of factors, including the documented presence of fossiliferous resources on a site or in nearby areas, the presence of documented fossils within a particular geologic formation or lithostratigraphic unit, and whether or not the original depositional environment of the sediments is one that might have been conducive to the accumulation of organic remains that might have become fossilized over time. Holocene alluvium is generally considered to be geologically too young to contain significant nonrenewable paleontological resources (i.e., fossils), and is therefore typically assigned a low paleontological sensitivity. Pleistocene (more than 11,700 years old) alluvial and alluvial fan deposits in the Los Angeles Basin, however, often yield important Ice Age terrestrial vertebrate fossils, such as extinct mammoths, mastodons, giant ground sloths, extinct species of horse, bison, and camel, saber-toothed cats, and others (Jefferson 1991). These Pleistocene sediments are accorded a high paleontological resource sensitivity. Professional Standards The Society of Vertebrate Paleontology has drafted guidelines that include four categories of paleontological sensitivity for geologic units (formations) that might be impacted by a proposed project, as listed below: Paleontological Assessment for the 8601 Mission Drive Project _____________________________________________________________________________________________________________________ 7 • High Potential: Rock units from which vertebrate or significant invertebrate, plant, or trace fossils have been recovered. • Undetermined Potential: Rock units for which little information is available concerning their paleontological content, geologic age, and depositional environment; further study is needed to determine the potential of the rock unit. • Low Potential: Rock units that are poorly represented by fossil specimens in institutional collections or based on a general scientific consensus that only preserve fossils in rare circumstances. • No Potential: Rock units that have no potential to contain significant paleontological resources, such as high-grade metamorphic rocks and plutonic igneous rocks. Under these criteria, a low potential may be assigned to the surface geology mapped project, based on the lack of significant fossil localities and Pleistocene deposits near the project. Field Survey BFSA staff conducted a pedestrian survey on February 18, 2022 under the direction of Principal Investigator Todd A. Wirths. The project is flat and appeared to be previously graded; remnants of an old asphalt driveway remain. The majority of the ground surface was covered with short grasses and weeds, with several palm trees present. No paleontological resources were identified during the field survey. VI. CONCLUSIONS AND RECOMMENDATIONS Research has confirmed the existence of Holocene young alluvial fan and valley deposits that are mapped at the surface of the project. Based on the lack of known significant fossil localities nearby and a low sensitivity rating typically assigned to Holocene-aged young alluvial deposits for yielding paleontological resources, it is recommended that paleontological monitoring not be implemented during mass grading and excavation activities, since impacts to potential paleontological resources are considered to be less than significant without mitigation. Monitoring for paleontological resources does not appear warranted at the project. However, should paleontological resources be discovered at any time during earth disturbance activities at the project, a paleontological Mitigation Monitoring and Reporting Program (MMRP) is provided below. Paleontological monitoring may be reduced or increased based on the observations and recommendations of the professional-level project paleontologist. The following MMRP, when implemented, would reduce potential impacts of paleontological resources to a level below significant: Paleontological Assessment for the 8601 Mission Drive Project _____________________________________________________________________________________________________________________ 8 Paleontological MMRP 1. If paleontological resources (fossils) are discovered, earth disturbance activities should stop, and the fossil location shall be protected and cordoned off at a distance of 50 feet in all directions. A qualified paleontologist should be notified immediately to determine the significance of the discovery. After examination of the fossil(s), and if the paleontologist determines the fossil(s) to be significant, monitoring for paleontological resources may be warranted. The guidelines and procedures for monitoring are detailed below. 2. Monitoring of mass grading and excavation activities in areas identified as likely to contain paleontological resources shall be performed by the paleontological monitor. Monitoring will be conducted in areas of grading or excavation in undisturbed sediments. The duration of monitoring shall be determined by the qualified project paleontologist. 3. Paleontological monitors will be equipped to salvage fossils as they are unearthed to avoid construction delays. The monitor must be empowered to temporarily halt or divert equipment to allow removal of abundant or large specimens in a timely manner. Monitoring may be reduced if the potentially fossiliferous units are not present in the subsurface, or, if present, are determined upon exposure and examination by qualified paleontological personnel to have low potential to contain fossil resources. The monitor shall notify the project paleontologist, who will then notify the concerned parties of the discovery. 4. Paleontological salvage during trenching and boring activities is typically from the generated spoils and does not delay the trenching or drilling activities. Fossils are collected and placed in cardboard flats or plastic buckets and identified by field number, collector, and date collected. Notes are taken on the map location and stratigraphy of the site, which is photographed before it is vacated, and the fossils are removed to a safe place. On mass grading projects, discovered fossil sites are protected by flagging to prevent them from being overrun by earthmovers (scrapers) before salvage begins. Fossils are collected in a similar manner, with notes and photographs being taken before removing the fossils. Precise location of the site is determined with the use of handheld GPS units. If the site involves remains from a large terrestrial vertebrate, such as large bone(s) or a mammoth tusk, that is/are too large to be easily removed by a single monitor, a fossil recovery crew shall excavate around the find, encase the find within a plaster and burlap jacket, and remove it after the plaster is set. For large fossils, use of the contractor’s construction equipment may be solicited to help remove the jacket to a safe location. 5. Isolated fossils are collected by hand, wrapped in paper, and placed in temporary collecting flats or five-gallon buckets. Notes are taken on the map location and stratigraphy of the site, which is photographed before it is vacated, and the fossils are Paleontological Assessment for the 8601 Mission Drive Project _____________________________________________________________________________________________________________________ 9 removed to a safe place. 6. Particularly small invertebrate fossils typically represent multiple specimens of a limited number of organisms, and a scientifically suitable sample can be obtained from one to several five-gallon buckets of fossiliferous sediment. If it is possible to dry screen the sediment in the field, a concentrated sample may consist of one or two buckets of material. For vertebrate fossils, the test is usually the observed presence of small pieces of bones within the sediments. If present, multiple five-gallon buckets of sediment can be collected and returned to a separate facility to wet-screen the sediment. 7. In the laboratory, individual fossils are cleaned of extraneous matrix, any breaks are repaired, and the specimen, if needed, is stabilized by soaking in an archivally approved acrylic hardener (e.g., a solution of acetone and Paraloid B-72). 8. Recovered specimens are prepared to a point of identification and permanent preservation (not display), including screen-washing sediments to recover small invertebrates and vertebrates. Preparation of individual vertebrate fossils is often more time-consuming than for accumulations of invertebrate fossils. 9. Identification and curation of specimens into a professional, accredited public museum repository with a commitment to archival conservation and permanent retrievable storage (e.g., LACM) shall be conducted. The paleontological program should include a written repository agreement prior to the initiation of mitigation activities. Prior to curation, the lead agency (e.g., the City of Rosemead) will be consulted on the repository/museum to receive the fossil material. 10. A final monitoring and mitigation report of findings and significance will be prepared, including lists of all fossils recovered and necessary maps and graphics to accurately record their original location(s). The report, when submitted to, and accepted by, the appropriate lead agency, will signify satisfactory completion of the project program to mitigate impacts to any potential nonrenewable paleontological resources (i.e., fossils) that might have been lost or otherwise adversely affected without such a program in place. Paleontological Assessment for the 8601 Mission Drive Project _____________________________________________________________________________________________________________________ 10 VII. CERTIFICATION I hereby certify that the statements furnished above and in the attached exhibits present the data and information required for this paleontological report, and that the facts, statements, and information presented are true and correct to the best of my knowledge and belief, and have been compiled in accordance with CEQA criteria. March 7, 2022 Todd A. Wirths Date Senior Paleontologist California Professional Geologist No. 7588 VIII. REFERENCES Bell, Alyssa. 2021. Paleontological resources for the 12247 Elliott Avenue Project. Natural History Museum of Los Angeles County. Prepared for Brian F. Smith and Associates, Inc., Poway, California. City of Rosemead. 2010. City of Rosemead general plan update. Electronic document, https://www.cityofrosemead.org/government/city_departments/community_development/ planning, accessed March 3, 2022. Hillhouse, J.W., Reichard, E.G., and Ponti, D.J. 2002. Probing the Los Angeles Basin – Insights into ground-water resources and earthquake hazards. U.S. Geological Survey Fact Sheet 086-02. Electronic document, https://pubs.usgs.gov/fs/2002/fs086-02/fs086-02.pdf, accessed March 3, 3033. Jefferson, G.T. 1991. A catalogue of late Quaternary vertebrates from California: Part two, mammals. Natural History Museum of Los Angeles County, Technical Reports, no. 7:I– v + 1–129. Miller, W.E. 1971. Pleistocene vertebrates of the Los Angeles Basin and vicinity (exclusive of Rancho La Brea). Bulletin of the Los Angeles County Museum of Natural History; Science (Number 10, 124 pp.). Society of Vertebrate Paleontology. 2010. Standard procedures for the assessment and mitigation of adverse impacts to paleontological resources; by the SVP Impact Mitigation Guidelines Revision Committee. Electronic document, http://vertpaleo.org/Membership/ Paleontological Assessment for the 8601 Mission Drive Project _____________________________________________________________________________________________________________________ 11 Member-Ethics/SVP_Impact_Mitigation_Guidelines.aspx, accessed March 3, 2022. Tan, S.S. 1998a. Geologic map of the El Monte 7.5' quadrangle, Los Angeles County, California: a digital database. California Division of Mines and Geology Open-file report 98-29. Paleontological Assessment for the 8601 Mission Drive Project _____________________________________________________________________________________________________________________ APPENDIX A Qualifications of Key Personnel To dd A. W ir ths , MS, PG No. 7588 Senior Paleontologist Brian F. Smith and Associates, Inc. 14010 Poway Road — Suite A — Phone: (858) 679-8218 — Fax: (858) 679-9896 — E-Mail: twirths@bfsa-ca.com Education Master of Science, Geological Sciences, San Diego State University, California 1995 Bachelor of Arts, Earth Sciences, University of California, Santa Cruz 1992 Professional Certifications California Professional Geologist #7588, 2003 Riverside County Approved Paleontologist San Diego County Qualified Paleontologist Orange County Certified Paleontologist OSHA HAZWOPER 40-hour trained; current 8-hour annual refresher Professional Memberships Board member, San Diego Geological Society San Diego Association of Geologists; past President (2012) and Vice President (2011) South Coast Geological Society Southern California Paleontological Society Experience Mr. Wirths has more than a dozen years of professional experience as a senior-level paleontologist throughout southern California. He is also a certified California Professional Geologist. At BFSA, Mr. Wirths conducts on-site paleontological monitoring, trains and supervises junior staff, and performs all research and reporting duties for locations throughout Los Angeles, Ventura, San Bernardino, Riverside, Orange, San Diego, and Imperial Counties. Mr. Wirths was formerly a senior project manager conducting environmental investigations and remediation projects for petroleum hydrocarbon- impacted sites across southern California. Selected Recent Reports 2019 Paleontological Assessment for the 10575 Foothill Boulevard Project, City of Rancho Cucamonga, San Bernardino County, California. Prepared for T&B Planning, Inc. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2019 Paleontological Assessment for the MorningStar Marguerite Project, Mission Viejo, Orange County, California. Prepared for T&B Planning. Report on file at Brian F. Smith and Associates, Inc., Poway, California. Brian F. Smith and Associates, Inc. 2 2019 Paleontological Monitoring Report for the Nimitz Crossing Project, City of San Diego. Prepared for Voltaire 24, LP. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2019 Paleontological Resource Impact Mitigation Program (PRIMP) for the Jack Rabbit Trail Logistics Center Project, City of Beaumont, Riverside County, California. Prepared for JRT BP 1, LLC. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2020 Paleontological Monitoring Report for the Oceanside Beachfront Resort Project, Oceanside, San California. Prepared for S.D. Malkin Properties. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2020 Paleontological Resource Impact Mitigation Program for the Nakase Project, Lake Forest, Orange County, San California. Prepared for Glenn Lukos Associates, Inc. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2020 Paleontological Resource Impact Mitigation Program for the Sunset Crossroads Project, Banning, Riverside County. Prepared for NP Banning Industrial, LLC. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2020 Paleontological Assessment for the Ortega Plaza Project, Lake Elsinore, Riverside County. Prepared for Empire Design Group. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2020 Paleontological Resource Record Search Update for the Green River Ranch III Project, Green River Ranch Specific Plan SP00-001, City of Corona, California. Prepared for Western Realco. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2020 Paleontological Assessment for the Cypress/Slover Industrial Center Project, City of Fontana, San Bernardino County, California. Prepared for T&B Planning, Inc. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2020 Paleontological Monitoring Report for the Imperial Landfill Expansion Project (Phase VI, Segment C-2), Imperial County, California. Prepared for Republic Services, Inc. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2021 Paleontological Assessment for the Manitou Court Logistics Center Project, City of Jurupa Valley, Riverside County, California. Prepared for Link Industrial. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2021 Paleontological Resource Impact Mitigation Program for the Del Oro (Tract 36852) Project, Menifee, Riverside County. Prepared for D.R. Horton. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2021 Paleontological Assessment for the Alessandro Corporate Center Project (Planning Case PR-2020- 000519), City of Riverside, Riverside County, California. Prepared for OZI Alessandro, LLC. Report on file at Brian F. Smith and Associates, Inc., Poway, California. 2021 Paleontological Monitoring Report for the Boardwalk Project, La Jolla, City of San Diego. Prepared for Project Management Advisors, Inc. Report on file at Brian F. Smith and Associates, Inc., Poway, California. Paleontological Assessment for the 8601 Mission Drive Project _____________________________________________________________________________________________________________________ APPENDIX B Paleontological Records Search Research & Collections e-mail: paleorecords@nhm.org August 18, 2021 Brian F. Smith and Associates, Inc. Attn: Todd Wirths re: Paleontological resources for the 12247 Elliott Avenue Project Dear Todd: I have conducted a thorough search of our paleontology collection records for the locality and specimen data for proposed development at the 12247 Elliott Avenue project area as outlined on the portion of the El Monte USGS topographic quadrangle map that you sent to me via e-mail on August 10, 2021. We do not have any fossil localities that lie directly within the proposed project area, but we do have fossil localities nearby from the same sedimentary deposits that occur in the proposed project area, either at the surface or at depth. The following table shows the closest known localities in the collection of the Natural History Museum of Los Angeles County. Locality Number Location Formation Taxa Depth VPLACM6350- 6362; LACM IP 16968-16991 Puente Hills Landfill Fernando Formation; Repetto Member (massive clayey siltstone) Herring (Ganolytes), hake (Merluccius), rattail (Coelorhynchus), lanternfish (Lampanyctus, Diaphus), white shark (Charcharodon carcharias); marine mammals (Cetacea); Invertebrates (unspecified) unknown LACM VP 7701- 7702 Intersection of 26th St and Atlantic Blvd, Bell Gardens Unknown Formation (Pleistocene; silt) Fish (Gasterosteus); Snake (Colubridae), Rodents (Thomomys, Microtus, Reithrodontomys); Rabbit (Sylvilagus) 11 – 30 ft bgs LACM VP 3363 W of Monterey Pass Road in Coyote Pass; E of the Long Beach Freeway & S of the N boundary of Section 32; Monterey Park Unknown Formation (Pleistocene; sand and silt) Horse (Equus) unknown LACM VP 3347 11204 Bluefield; La Habra Formation Horse (Equus) 2 feet bgs Whittier (lacustrine silt with caliche and plant detritus) LACM VP 7508 Near intersection of Vellano Club Dr. and Palmero Dr., Oakcrest Development; N of Serrano Canyon Unknown formation (Pleistocene) Ground sloth (Nothrotheriops); elephant family (Proboscidea); horse (Equus) Unknown LACM VP 1728 W of intersection of English Rd & Peyton Dr, Chino Unknown (light brown shale with interbeds of very coarse brown sand; Pleistocene) Horse (Equus), camel (Camelops) 15-20 ft bgs VP, Vertebrate Paleontology; IP, Invertebrate Paleontology; bgs, below ground surface This records search covers only the records of the Natural History Museum of Los Angeles County (“NHMLA”). It is not intended as a paleontological assessment of the project area for the purposes of CEQA or NEPA. Potentially fossil-bearing units are present in the project area, either at the surface or in the subsurface. As such, NHMLA recommends that a full paleontological assessment of the project area be conducted by a paleontologist meeting Bureau of Land Management or Society of Vertebrate Paleontology standards. Sincerely, Alyssa Bell, Ph.D. Natural History Museum of Los Angeles County enclosure: invoice