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STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
PO Box 47600, Olympia,WA 98504-7600 • 360-407-6000
January 10, 2024
William Davis, P.E.
Managing Engineer, Utilities
345 6th Street, Suite 100
City of Bremerton
Bremerton, Washington 98337
Re: Section 106 of the National Historic Preservation Act
City of Bremerton, Manette Decommission Beach Sewer OF-4 to EB-2
Washington Clean Water State Revolving Fund
Invitation to Sign Final Memorandum of Agreement
Dear Bill:
I am pleased to present the final Memorandum of Agreement (MOA), developed to offset any
potentially adverse effects on Eligible Site 45KP9, the Manette Site, associated with the City of
Bremerton, Manette Decommission Beach Sewer OF-4 to EB-2 project.
This effort represents the hard work of the Suquamish Tribe of the Port Madison Indian
Reservation, City of Bremerton, Department of Archaeology and Historic Preservation and
Washington State Department of Ecology working together to ensure the appropriate
protection of pre-historic archaeological discoveries. We have kept both the U.S. Army Corps of
Engineers, Seattle District and the U.S. Environmental Protection Agency, Region 10, informed
as this agreement progressed.
Please follow these instructions to have your signatory sign the MOA:
Steps for Signing:
1. Present this cover letter to the Signatory.
2. Advise the Signatory all parties agree to this MOA.
3. Advise the Signatory appropriate legal counsels have reviewed and approve the agreement.
4. Advise the Signatory there is no further comment period.
5. Present the Signatory with the agreement and ask they sign the stand-alone signatory page
with their signature line.
JANUARY 2024
MEMORANDUM OF AGREEMENT
BETWEEN
THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10,
THE WASHINGTON STATE DEPARTMENT OF ECOLOGY,
THE WASHINGTON STATE DEPARTMENT OF ARCHAEOLOGY AND HISTORIC
PRESERVATION,
THE SUQUAMISH INDIAN TRIBE OF THE PORT MADISON RESERVATION, AND
THE CITY OF BREMERTON,
REGARDING THE MANETTE DECOMMISSION BEACH SEWER FROM OF-4 TO
EB-2 AGREEMENT, DAHP 2022-04-02418,WASHINGTON STATE
WHEREAS the Washington State Department of Ecology (Ecology) agrees to fund the City of
Bremerton's Agreement WQC-2020-BremPW-00066,Manette Decommission Beach Sewer from
OF-4 to EB-2 (Undertaking) as authorized through the Clean Water State Revolving Fund
(CWSRF) Program under Title VI of the Clean Water Act, as amended; and
WHEREAS the United States Environmental Protection Agency(EPA)has designated Ecology
as the non-federal representative under Section 106 of the National Historic Preservation Act
(NHPA), 16 U.S.0 § 470f, (Section 106) and its implementing regulations at 36 Code of Federal
Regulations (CFR) Part 800 for projects offered financial assistance through the Washington
CWSRF; and
WHEREAS to ensure Section 106 requirements were carried out for the CWSRF as applicable,
a Programmatic Agreement (PA) was executed on March 28, 1990, between the Advisory
Council on Historic Preservation(ACHP),the EPA, and the National Conference of State
Historic Preservation Officers (NCSHPO)concerning compliance with the NHPA through
EPA's CWSRF Program pursuant to 36 C.F.R. § 800.13; and
WHEREAS the PA stipulates that the EPA shall require the State CWSRF Agency,which in
this case is Ecology,to carry out the requirements of 36 CFR 800.4 through 800.6, with
reference to 36 CFR 800.1, 800.2, 800.3, 800.8, 800.9, 800.10, 800.11, 800.12 and 800.14 for
actions receiving CWSRF assistance; and
WHEREAS the City of Bremerton("the City") completed the required Section 106 consultation
in June of 2023 (DAHP Log 2022-04-02418), with the Undertaking consisting of the City
installing a new upland sewer system to replace the existing gravity fed sewer main located in
the tidelands of the Port Washington Narrows, Bremerton, Kitsap County, Washington; and,
WHEREAS during April of 2022,the City's consulting archaeologists observed historic
properties within the boundaries of the Undertaking (Attachment B —Gardner, J. CRC. 2022.
Cultural Resources Assessment for the Manette Beach Sewer Upgrades EB-2 to OF-4.
Parametrix Project No. 2331896179, Bremerton, Kitsap County, Washington. April 27, 2022. 85
pp. Available in WISAARD.); and
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Bremerton MOA DAHP 2022-04-02418
WHEREAS additional investigations during early phases (1 & 2)of the Undertaking were
positive for historic resources resulting in the potential for an adverse effect; and
WHEREAS in response, Ecology,the DAHP, the City,the City's archaeologist and the EPA
convened a meeting on October 5, 2022, to learn more about the Undertaking; inviting the
following recognized tribes:the Suquamish Indian Tribe of the Port Madison Reservation,
Puyallup Tribe of Indians, Jamestown S'Klallam Tribe, Lower Elwha S'Klallam Tribe, Port
Gamble S'Klallam Tribe, Nisqually Tribe, Squaxin Island Tribe, Tulalip Tribes, Muckleshoot
Indian Tribe, Sauk-Suiattle Indian Tribe, Snoqualmie Indian Tribe, and Skokomish Indian Tribe;
and
WHEREAS the Suquamish Indian Tribe of the Port Madison Reservation, a federally
recognized Indian tribe, agreed to continue participation in this consultation; and
WHEREAS Ecology, in consultation with the Parties to this Agreement, has identified the Area
of Potential Effect(APE)for Phase 3, construction as shown in the Work Plan (Attachment A)
and Figure 31 on page 40 of the Manette Decommission Beach Sewer from OF-4 to EB-2
Project, 45KP9, Geotechnical Monitoring and Site Characterization Report(Johnson, P. et. al.
2023. Willamette Report No. 22-112, Prepared for Parametrix. May 4, 2023. 42 pp. Available in
WISAARD, see Attachment B).
WHEREAS Ecology, in consultation with the Washington State Department of Archaeology
and Historic Preservation (DAHP),the Suquamish Indian Tribe of the Port Madison Reservation
Tribal Historic Preservation Officers (Suquamish THPO) and the City, by consensus
recommended the Manette historic property eligible for inclusion in the National Register of
Historic Places (NRHP)under Criterion A due to its association with broad patterns of
Indigenous settlement and subsistence as evidenced by the lithic tools and debitage, and under
Criterion D due to the ability of site 45KP009 to provide additional data to the archaeological
record of Bremerton (36 CFR 60.4)(See Attachment C); and
WHEREAS Ecology has consulted with the Parties to this agreement in accordance with
Section 106 of the NHPA and its implementing regulations (36 CFR Part 800)to resolve adverse
effects of the undertaking on the historic property; and Ecology, in consultation with the Parties
to this Agreement, concurs that historic properties as defined by 36 C.F.R. § 800.16 (1)(1) and
properties eligible for inclusion in the NRHP, have previously been discovered within the APE
and may continue to be discovered within the APE; and
WHEREAS the EPA, DAHP, the City, and the Suquamish THPO agreed to participate in this
consultation and development of this Memorandum of Agreement (Agreement),to resolve
adverse effects; and
WHEREAS the United States Army Corps of Engineers, Seattle District(Corps)expressed
interest in being kept informed on the Undertaking.
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WHEREAS a Department of the Army permit(NWS-2022-492), pursuant to Section 10 of the
Rivers and Harbors Act of 1899 and Section 404 of the Clean Water Act, would be required from
the Corps to conduct activities related to the decommission of the beach gravity sewer; and
WHEREAS Ecology and the Corps have agreed that EPA will act as Lead Federal agency for
Section 106 compliance and will act on the Corps behalf; and
WHEREAS per 36 CFR 800(c)(1)the following parties are defined as Signatories:
• The Agency Official—United States Environmental Protection Agency.
• The Agency Representative —The Washington State Department of Ecology.
• The State Historic Preservation Officer- Washington Department of Archaeology and
Historic Preservation.
• The Tribal Historic Preservation Officer— Suquamish Indian Tribe of the Port Madison
Reservation
WHEREAS per 36 CFR 800(c)(2)the agency official may invite additional parties to be
signatories to a memorandum of agreement. The following are invited Signatories:
• City of Bremerton.
WHEREAS together the Signatories and Invited Signatories shall be referred to as Signatories
and Invited Signatories (together, Signatories)to this Agreement.
WHEREAS each of the Signatories has identified a party representative (together,Parties)as
the primary contact for implementation of the stipulations; and
NOW THEREFORE, Ecology and the Parties agree the Undertaking will be implemented in
accordance with the following stipulations to take into account the adverse effects of the
undertaking upon the identified historic property.
STIPULATIONS:
Ecology, in cooperation with DAHP, the Suquamish Indian Tribe of the Port Madison
Reservation and the City, shall ensure that the following stipulations are met to account for the
adverse effects upon the discovered and potentially unrecovered cultural resources:
I. AUTHORIZATION TO PROCEED WITH UNDERTAKING
Execution of this Agreement constitutes authorization to the City to proceed with the
Undertaking and implement the Work Plan—Construction Phase, which is Attachment A.
The City believes there is the highest probability for finding cultural resources, and the City
developed a Work Plan prior to construction. This authorization is solely for purposes of
compliance with the NHPA and does not constitute any authorization for approvals that may be
required under other state and federal statutes.
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II. POST-REVIEW DISCOVERIES
The remainder of the work for this project will also utilize the existing inadvertent discovery
plan(IDP) included as an Attachment of this MOA(Attachment D)in the event further cultural
material or unanticipated effects are identified.
III. STANDARDS AND HUMAN REMAINS
All work carried out pursuant to this Agreement shall meet the Secretary of the Interior's
Standards for Archaeology and Historic Preservation(SOI's Standards webpage:
https://www.doi.gov/pam/asset-management/historic-preservation/pqs ), considering the
suggested approaches to new construction in the SOI's Standards for Rehabilitation.
The City shall ensure that all work carried out pursuant to this Agreement shall be done by or
under the direct supervision of historic preservation professionals who meet the Secretary of
the Interior's Professional Qualifications Standards. Ecology and the City shall ensure that
consultants retained for services pursuant to the Agreement meet these standards.
Historic and prehistoric human remains from non-federal,non-tribal lands are subject to
protection under the Washington burial/unmarked grave/cemetery laws. As such, if human
remains are discovered during construction,the Section 6.0 SPECIAL PROCEDURES FOR
THE DISCOVERY OF HUMAN SKELETAL MATERIAL of the DAHP-reviewed
Ecology Inadvertent Discovery Plan (Attachment D) will immediately apply per RCW
27.44.055, RCW 68.50, and RCW 68.60, DAHP will have jurisdiction over non-forensic human
remains. Ecology staff will participate in consultation as needed. Refer to Attachment A:
Work Plan for further details.
IV. MONITORING
The Signatories approve, adopt and ratify, and concur with the monitoring protocol set forth in
the attached Work Plan (Attachment A). Its terms and provisions shall govern and control the
areas, process, procedures, and methods for handling cultural resources and any human remains
discovered in the APE.
If the City archaeologist identifies a project activity proposed to take place outside of the areas
identified in the Work Plan,this will constitute a material change. If the archaeologist believes
that a material change has been made,then the archaeologist will provide the City with a
narrative description of the material change and an archaeological testing strategy in writing that
considers the aerial and vertical extent, which should match the project activity where possible.
The City will notify Ecology that an additional level of testing is requested. Ecology will notify
the Party Representatives. The written archaeological testing request will be appended to the
weekly archaeological report for the week of the request.
If the City makes any changes to the APE,the Consulting Parties will discuss the appropriate
level of monitoring to be conducted in that area prior to any ground disturbance. The City will
convey the change in the APE and proposed testing strategy to Ecology, for distribution to the
Party Representatives for review and comment.
The Party Representatives shall have minimum of 48 hours and a maximum often working days
to review and approve the material change and proposed testing strategy and respond to Ecology
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and the City with questions and concerns. Ecology shall have a minimum of 48 hours and a
maximum of ten working days to review the responses from Party Representatives, unless all the
Party Representatives agree to a longer period (not more than 20 working days). Ecology shall
notify the Party Representatives of its approval of the testing protocol via email and will include
the revised Treatment Plan. The revised Work Plan will replace the Work Plan currently
included as Attachment A to this Agreement and shall be subject to all of the stipulations
contained herein.
V. REPORTING
Following the execution of this MOA until it expires or is terminated,the City's archaeologist
will follow the Work Plan Communication Plan,for pre-field notifications, discoveries, and
field updates to all parties to this MOA. Updates will include a summary via email detailing
work undertaken pursuant to its terms. Summary shall be provided on a weekly basis for any
week that monitoring is conducted. Such report shall include any scheduling changes proposed,
any problems encountered, and any disputes and objections received in the City's efforts to
carry out the terms of this MOA.
If other persons or entities outside of this Agreement request copies of any weekly summary
Ecology shall notify Party Representatives of such request and afford a reasonable opportunity
for any Party Representative to object to the release of such report based on the application of
specific exemptions from release found in the Public Records Act (RCW 42.56)or other state or
federal law. If a Party Representative objects to the release of such report where no exemption
applies, the Party Representative may seek an injunction preventing release as provided by RCW
42.56.540.
By January 31 of each year, until a determination in writing is issued that the project is complete
or the Agreement is terminated,the City shall prepare and provide an annual report based upon
DAHP Washington State Standards for Cultural Resource Reporting to Ecology
Ecology will provide the annual report to the Parties to this Agreement. The Party
Representatives shall review the annual report and provide comments to Ecology, who shall
provide them to the City.
Following completion of the Undertaking as defined in Stipulation XII below, or Termination as
defined in Stipulation IX below, the City shall provide to Ecology, who will distribute to all
Party Representatives, a final summary report detailing work undertaken pursuant to its terms,
including pursuant to the Treatment Plan.
A final draft archaeological report will be prepared within 90 days after completion of the
archaeological fieldwork. The City will provide the report to Ecology who will distribute it to
the other Party Representatives.
VI. NATIONAL REGISTER NOMINATION
The City, in collaboration with the Suquamish THPO, will provide to Party Representatives an
independent evaluation of the significance of the property, including preparation of
documentation supporting its significance. The professional will prepare the NRHP nomination
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form (10-900 form)for 45KP9 within 1 (one)year following notice of substantial completion.
The final document will conform to the format and requirements of the National Register
Bulletin 36. This document will be completed by a professional meeting the Secretary of the
Interior's Professional Qualification Standard for Archaeology.
VII. EDUCATION AND INTERPRETATION
The City will design, fabricate, finance, and install one (1) interpretive sign in a public location
educating the public about the importance of the Manette area to Native American Tribes.
1. The City will coordinate with the Suquamish THPO regarding the content of the
interpretive sign.
2. The City will ensure that draft content on the sign is submitted to the consulting parties
within one year of the final signature on this agreement.
3. The City will ensure that the sign incorporates text and images constructed of a durable,
weather-resistant design.
4. The City will ensure the signage is onsite one year after notice of substantial
completion of the construction of this project.
VIII. DATA RECOVERY
Legacy and current data on the Manette site will be appropriately catalogued according to
Washington State Standards and/or Federal Standards (36 CFR Part 79). The Suquamish THPO
recommends developing one comprehensive report on the Manette Site.
Methodology:
For previous or additional data recovery, see the section on Data Recovery in the Phase 3
Work Plan. For Phase 3, controlled excavation sampling through identified stratigraphy
using controlled units is recommended. Any additional data recovered will be presented to
the Suquamish Indian Tribe of the Port Madison Reservation for curation.
Curation and Legacy Collections:
The collection of historical information on the Manette Site at the Suquamish Indian Tribal
Museum requires cataloguing to Washington State Standards and/or Federal Standards (36
CFR Part 79). There are multiples boxes of artifacts and records. The Suquamish THPO
will present a work plan for curation prior to the end of Phase 3, or the Burke Museum
Curation Guidelines will be adopted, Version 1.11.2023 (see
https://www.burkemuseum.org/sites/default/files/2023-01/curation-guide-vl.11-2023.pdf)
IX. DURATION OF AGREEMENT
This MOA will expire if its terms are not carried out within five (5)years from the date of its
execution. Prior to such time, Ecology may consult with the other parties to reconsider the
terms of the MOA and amend it in accordance with Stipulation VIII below.
X. DISPUTE RESOLUTION
Should any Signatory or invited Signatory(Signatories)to this MOA object at any time to any
actions proposed or the manner in which the terms of this MOA are implemented,the EPA shall
consult with such party to resolve the objection. If EPA determines that such objection cannot be
resolved, EPA will:
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1. Forward all documentation relevant to the dispute, including the EPA's proposed
resolution,to the ACHP. The ACHP shall provide EPA with its advice on the resolution
of the objection within thirty(30) days of receiving adequate documentation. Prior to
reaching a final decision on the dispute, EPA shall prepare a written response that takes
into account any timely advice or comments regarding the dispute from the ACHP,
signatories, and provide them with a copy of this written response. EPA will then proceed
according to its final decision.
2. If the ACHP does not provide its advice regarding the dispute within the thirty (30) day
time period, EPA may make a final decision on the dispute and proceed accordingly.
Prior to reaching such a final decision, EPA shall prepare a written response that takes
into account any timely comments regarding the dispute from the signatories to the
MOA, and provide them and the ACHP with a copy of such written response.
3. EPA's responsibility to carry out all other actions subject to the terms of this MOA that
are not the subject of the dispute remain unchanged.
XI. AMENDMENTS
Any Signatory to this MOA may request that the Agreement be amended, whereupon the
Parties to this Agreement will consult in accordance with 36 C.F.R. § 800.6(c)(7)to
consider such amendment. This MOA may be amended when such an amendment is
agreed to in writing by all Signatories. The amendment will be effective on the date a
copy is signed by all Signatories.
XII. TERMINATION
1. If any Signatory to this MOA determines that the terms will not or cannot be carried out,
after pursing the Dispute Resolution process set out in the Stipulation VII above, and
after attempting to craft an amendment per Stipulation VIII above,that Party may
terminate the MOA upon written notification to other signatories.
2. Termination shall include the submission of a technical report and/or other
documentation by the City to the Signatories on work done up to and including the date
of termination.
3. Once the Agreement is terminated, Ecology must either(a) execute an Agreement
pursuant to 36 C.F.R. § 800.6; or (b) request, take into account, and respond to any
comments from the ACHP under 36 C.F.R. § 800.7(c)(4). Ecology shall notify the
Parties to this Agreement as to the course of action it will pursue. Prior to Ecology's
decision or after,the City may request and Ecology may authorize the City to proceed
with the Undertaking if the City can demonstrate compliance with 36 CFR §800.4.
XIII. EXPIRATION
This Agreement shall be effective for five (5)years from the date of the last signature
below.
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XIV. ANTI-DEFICIENCY ACT
1. This Agreement is neither a fiscal nor a funds obligation document of Ecology or EPA.
Any funding to be provided by the Ecology will be done pursuant to a separate funding
agreement.
2. Nothing in this MOA, in and of itself, obligates EPA to expend appropriations or to enter
into any contract, assistance agreement, interagency agreement, or incur other financial
obligations that would be inconsistent with Agency budget priorities.
XV. SCOPE OF AGREEMENT
1. This Agreement is limited to the Undertaking and is entered into solely for that purpose.
2. Nothing in this Agreement is intended to or shall be construed to diminish or affect in any
way any of the Signatories' rights, obligations, or remedies under other state or federal
laws, including but not limited to Washington's Indian Graves and Records Act, RCW
Ch. 27.44, and Archaeological Resource and Sites Act, RCW Ch. 27.53, or the right of
any Tribe to take any lawful action to protect Native American graves from disturbance
or desecration or to protect archaeological sites or cultural resources from damage.
3. This Agreement in no way restricts any Signatory or Invited Signatories from
participating in any activity with other public or private agencies, organizations, or
individuals, except as provided for in the Work Plan. This Agreement will be subject to,
and will be carried out in compliance with, all applicable laws,regulations, and other
legal requirements.
4. This Agreement does not create any right or benefit, substantive or procedural,
enforceable by law or equity, by persons who are not a Signatory or Invited Signatory to
this Agreement, against the DAHP, Ecology,the City, Suquamish THPO, or the EPA, or
their officers, agents, and employees. Nothing in this Agreement is intended to or shall
be construed to waive the sovereign immunity of any Signatory or Invited Signatory.
5. If, following execution of this Agreement, Ecology decides not to offer financial
assistance from the CWSRF to the City for the Undertaking that is the subject of this
Agreement,this Agreement will automatically become null and void.
6. This Agreement shall not be interpreted as limiting, superseding, or otherwise affecting
the EPA's normal operations or decisions in carrying out its statutory or regulatory duties.
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XVI. PRINCIPAL CONTACTS/PARTY REPRESENTATIVES
All notifications required pursuant to this Agreement shall be made to the Party
Representatives in this Stipulation. The parties may designate different Party
Representatives by informing Ecology by official letter or email, and Ecology will inform the
other parties. The principal contacts for this Agreement are as follows:
EPA:
Signatory:
Caleb Shaffer
Acting Director, Water Division
US Environmental Protection Agency, Region 10
1200 Sixth Avenue, Suite 155, Mailstop 19-009
Seattle, Washington 98101
Phone: +1 503-326-5015
Mobile: +1 503-307-3076
Party Representative:
David Carcia
Project Officer, Clean Water State Revolving Fund
Water Division
Environmental Protection Agency, Region 10
1200 Sixth Avenue, Suite 155
Seattle, WA 98101
Phone: (206) 553-0890
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Bremerton MOA DAHP 2022-04-02418
Ecology:
Signatory:
Vincent McGowan, P.E.
Water Quality Program Manager
Washington Department of Ecology
P.O. Box 47600
Olympia, Washington 98504-7600
Email vincent.mcgowan@7ecy.wa.gov
Phone: 360-407-6405
Alternate: 360-407-6000
Party Representative:
Liz Ellis, Environmental Review Coordinator
Water Quality Program
Washington Department of Ecology
P.O. Box 47600
Olympia, Washington 98504-7600
liz.ellis@ecy.wa.gov
Phone: (360) 628-4410
DAHP:
Signatory:
Dr. Allyson Brooks, State Historic Preservation Officer
Washington Department of Archaeology & Historic Preservation
1063 S. Capitol Way, Suite 106
PO Box 48343
Olympia, WA 98504-8343
allyson.brooks@dahp.wa.gov
Phone: (360) 480-6922
Party Representative:
Rob Whitlam, State Archaeologist
Washington Department of Archaeology & Historic Preservation
1063 S. Capitol Way, Suite 106
PO Box 48343
Olympia, WA 98504-8343
rob.whitlam@dahp.wa.gov
Phone: (360) 890-2615
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Bremerton MOA DAHP 2022-04-02418
Bremerton(City of):
Signatory:
Mayor Greg Wheeler
City of Bremerton, WA
345 6th Street
Bremerton, WA 98337
Email: greg.wheeler@ci.bremerton.wa.us
Phone (360)473-5266
Party Representative:
William Davis
Managing Engineer
345 6th Street
Bremerton, WA 98337
Email: william.davis@ci.bremerton.wa.us
Phone: (509) 754-4601 x. 114
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Bremerton MOA DAHP 2022-04-02418
Suquamish Indian Tribe of Port Madison Reservation
Signatory
Chairman Leonard Forsman
P.O. Box 498
Suquamish, WA 98392
Email: lforsman@suquamish.nsn.us
Phone: (360) 598-3311
Alternate: (360)
Party Representative:
Stephanie Trudel, THPO
P.O. Box 498
Suquamish, WA 98392
Email: strudel@suquamish.nsn.us
Phone: (360) 394-8533
Alternate: (360) 509-1321
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XVII. EXECUTION OF AGREEMENT
1) This Agreement may be executed in counterparts, with a separate page for each
Signatory. Ecology will ensure that each Party Representative is provided with a copy of
the fully executed Agreement.
2) Execution of this Agreement by Ecology and the SHPO and its submission to the ACHP
in accordance with 36 C.F.R. 800.6(b)(1)(iv), will, pursuant to 36 C.F.R. 800.6(c), be
considered to be an agreement pursuant to the regulations issued by the ACHP for the
purposes of Section 110(1)of the NHPA, 16 U.S.C. 470h-2(1). Execution, submission,
and implementation of the terms of this Agreement demonstrate that the EPA has
afforded the ACHP an opportunity to comment on the proposed Undertaking and its
effect on historic properties and that the EPA has taken into account the effect of the
Undertaking on historic properties in accordance with Section 106 of the NHPA, 16
U.S.C. 470(F).
3) This Agreement shall be effective on the date of the latest signature below.
Each undersigned official certifies that he or she is fully authorized to enter into the terms and
conditions of this Agreement and to execute and legally bind the Party he or she represents to
this document.
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Bremerton MOA DAHP 2022-04-02418
DocuSign Envelope ID: F10A6C49-D5E8-4329-A75B-EFD80A04C600
SIGNATORY:
THE CITY OF BREMERTON
�DocuSigned by:
2/6/2024
By: -BAF46O95E8E747B... Date:
Mayor Greg Wheeler
City of Bremerton
SIGNATORY:
THE WASHINGTON DEPARTMENT OF ECOLOGY
By: Date: 1/19/2024
Vincent McGowan, P.E.
Water Quality Program Manager
DocuSign Envelope ID:6AA801 FB-0EA8-4405-9AC2-4593B13BFB5A
SIGNATORY PARTY:
THE SUQUAMISH INDIAN TRIBE OF PORT MADISON RESERVATION
c—DocuSigned by:
��_ 01/24/2024
By: _—F19A5D9A5D7A4A4.. Date:
Leonard Forsman
Chairman
SIGNATORY:
WASHINGTON STATE DEPARTMENT OF ARCHAEOLOGY AND HISTORIC
PRESERVATION
By: AOyscli ok5 b14,202412:0TPST) Date: Feb 14,2024
Dr. Allyson Brooks
State Historic Preservation Officer
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Bremerton MOA DAHP 2022-04-02418
SIGNATORY:
THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
CALEB DHAFF4gned by CALEB
By:SHAFFER 06 18208'00'9 Date:
Caleb Shaffer
Acting Director, Water Division
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Bremerton MOA DAHP 2022-04-02418
Attachment A—Work Plan
(Construction Phase)
To view, please visit WISAARD and log into Secure-Side Access.
Bring up DAHP Project:
2022-04-02418 - Manette Beach Sewer Upgrades (EB-2 to OF-4)
https://wisaard.dahp.wa.gov/Projects/204612/Overview
Pull up Inventory and Evaluations > Reports, and click on:
Johnson, P. and A. Taylor, WCRA. 2023. City of Bremerton Manette Decommission Beach
Sewer Phase 3 Archaeological Work Plan
December 1, 2023. 40 pp.
https://wisaard.dahp.wa.gov/Projects/204612/ProjectResources/881198/Report/772440
Reports will be provided upon request.
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Attachment B
Cultural Resources Reports
Reports are too large for attachment. To view,please visit WISAARD and log into
Secure-Side Access, bring up DAHP Project 2022-04-02418 - Manette Beach Sewer
Upgrades (EB-2 to OF-4)
https://wisaard.dahp.wa.gov/Projects/204612/Overview
Pull up Inventory and Evaluations > Reports, and click on:
• Gardner, J. CRC. 2022. Cultural Resources Assessment for the Manette Beach
Sewer Upgrades (EB-2 to OF-4) (Parametrix Project No. 2331896179),
Bremerton, Kitsap County, Washington. April 27, 2022. 85 pp.
• Johnson, P., Kopperl, B., Kramer, S. and A. Jenkins. WCRA. 2023. Manette
Decommission Beach Sewer from OF-4 to EB-2 Project, 45KP9 Geotechnical
Monitoring and Site Characterization Report. May 4, 2023. 42 pp.
• Johnson, P. and A. Taylor. WCRA. 2022. City of Bremerton Manette
Decommission Beach Sewer Phase 2 Archaeological Work Plan. December 9,
2022,updated January 24, 2023. 29 pp.
Reports will be provided upon request.
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Attachment C
Nomination Form Placeholder
Nomination by Consensus has occurred. Any associated forms will be inserted here.
Eligibility statement has been drafted and uploaded to WISAARD. To view please visit
WISAARD and log into Secure-Side Access, bring up DAHP Project 2022-04-02418 -
Manette Beach Sewer Upgrades (EB-2 to OF-4). Click on Inventories and Evaluations >
Reports, and click on 45KP0009:
https://wisaard.dahp.wa.gov/Projects/204612/ProjectResources/882113/Archaeologylnve
ntory/56550
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Attachment D
Inadvertent Discovery Plan
Please visit DAHP's WISAARD and go to:
2022-04-02418 - Manette Beach Sewer Upgrades (EB-2 to OF-4)
https://wisaard.dahp.wa.gov/Projects/204612/Overview
Go to Inventory and Reports
or click on:
Bremerton Inadvertent Discovery Plan
https://wisaard.dahp.wa.gov/Projects/204612/ProjectResources/881018/Report/772299
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Bremerton MOA DAHP 2022-04-02418
JANUARY 2024
MEMORANDUM OF AGREEMENT
BETWEEN
THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10,
THE WASHINGTON STATE DEPARTMENT OF ECOLOGY,
THE WASHINGTON STATE DEPARTMENT OF ARCHAEOLOGY AND HISTORIC
PRESERVATION,
THE SUQUAMISH INDIAN TRIBE OF THE PORT MADISON RESERVATION, AND
THE CITY OF BREMERTON,
REGARDING THE MANETTE DECOMMISSION BEACH SEWER FROM OF-4 TO
EB-2 AGREEMENT, DAHP 2022-04-02418,WASHINGTON STATE
WHEREAS the Washington State Department of Ecology (Ecology) agrees to fund the City of
Bremerton's Agreement WQC-2020-BremPW-00066,Manette Decommission Beach Sewer from
OF-4 to EB-2 (Undertaking) as authorized through the Clean Water State Revolving Fund
(CWSRF) Program under Title VI of the Clean Water Act, as amended; and
WHEREAS the United States Environmental Protection Agency(EPA)has designated Ecology
as the non-federal representative under Section 106 of the National Historic Preservation Act
(NHPA), 16 U.S.0 § 470f, (Section 106)and its implementing regulations at 36 Code of Federal
Regulations (CFR) Part 800 for projects offered financial assistance through the Washington
CWSRF; and
WHEREAS to ensure Section 106 requirements were carried out for the CWSRF as applicable,
a Programmatic Agreement (PA) was executed on March 28, 1990, between the Advisory
Council on Historic Preservation(ACHP),the EPA, and the National Conference of State
Historic Preservation Officers (NCSHPO)concerning compliance with the NHPA through
EPA's CWSRF Program pursuant to 36 C.F.R. § 800.13; and
WHEREAS the PA stipulates that the EPA shall require the State CWSRF Agency, which in
this case is Ecology,to carry out the requirements of 36 CFR 800.4 through 800.6, with
reference to 36 CFR 800.1, 800.2, 800.3, 800.8, 800.9, 800.10, 800.11, 800.12 and 800.14 for
actions receiving CWSRF assistance; and
WHEREAS the City of Bremerton("the City") completed the required Section 106 consultation
in June of 2023 (DAHP Log 2022-04-02418), with the Undertaking consisting of the City
installing a new upland sewer system to replace the existing gravity fed sewer main located in
the tidelands of the Port Washington Narrows, Bremerton, Kitsap County, Washington; and,
WHEREAS during April of 2022,the City's consulting archaeologists observed historic
properties within the boundaries of the Undertaking (Attachment B —Gardner, J. CRC. 2022.
Cultural Resources Assessment for the Manette Beach Sewer Upgrades EB-2 to OF-4.
Parametrix Project No. 2331896179, Bremerton, Kitsap County, Washington. April 27, 2022. 85
pp. Available in WISAARD.); and
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Bremerton MOA DAHP 2022-04-02418
WHEREAS additional investigations during early phases (1 & 2) of the Undertaking were
positive for historic resources resulting in the potential for an adverse effect; and
WHEREAS in response, Ecology, the DAHP,the City, the City's archaeologist and the EPA
convened a meeting on October 5, 2022, to learn more about the Undertaking; inviting the
following recognized tribes: the Suquamish Indian Tribe of the Port Madison Reservation,
Puyallup Tribe of Indians, Jamestown S'Klallam Tribe, Lower Elwha S'Klallam Tribe, Port
Gamble S'Klallam Tribe, Nisqually Tribe, Squaxin Island Tribe, Tulalip Tribes, Muckleshoot
Indian Tribe, Sauk-Suiattle Indian Tribe, Snoqualmie Indian Tribe, and Skokomish Indian Tribe;
and
WHEREAS the Suquamish Indian Tribe of the Port Madison Reservation, a federally
recognized Indian tribe, agreed to continue participation in this consultation; and
WHEREAS Ecology, in consultation with the Parties to this Agreement, has identified the Area
of Potential Effect(APE)for Phase 3, construction as shown in the Work Plan (Attachment A)
and Figure 31 on page 40 of the Manette Decommission Beach Sewer from OF-4 to EB-2
Project, 45KP9, Geotechnical Monitoring and Site Characterization Report(Johnson, P. et. al.
2023. Willamette Report No. 22-112, Prepared for Parametrix. May 4, 2023. 42 pp. Available in
WISAARD, see Attachment B).
WHEREAS Ecology, in consultation with the Washington State Department of Archaeology
and Historic Preservation (DAHP),the Suquamish Indian Tribe of the Port Madison Reservation
Tribal Historic Preservation Officers (Suquamish THPO) and the City, by consensus
recommended the Manette historic property eligible for inclusion in the National Register of
Historic Places (NRHP) under Criterion A due to its association with broad patterns of
Indigenous settlement and subsistence as evidenced by the lithic tools and debitage, and under
Criterion D due to the ability of site 45KP009 to provide additional data to the archaeological
record of Bremerton (36 CFR 60.4) (See Attachment C); and
WHEREAS Ecology has consulted with the Parties to this agreement in accordance with
Section 106 of the NHPA and its implementing regulations (36 CFR Part 800)to resolve adverse
effects of the undertaking on the historic property; and Ecology, in consultation with the Parties
to this Agreement, concurs that historic properties as defined by 36 C.F.R. § 800.16 (1)(1) and
properties eligible for inclusion in the NRHP, have previously been discovered within the APE
and may continue to be discovered within the APE; and
WHEREAS the EPA, DAHP, the City, and the Suquamish THPO agreed to participate in this
consultation and development of this Memorandum of Agreement(Agreement), to resolve
adverse effects; and
WHEREAS the United States Army Corps of Engineers, Seattle District(Corps) expressed
interest in being kept informed on the Undertaking.
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Bremerton MOA DAHP 2022-04-02418
WHEREAS a Department of the Army permit(NWS-2022-492), pursuant to Section 10 of the
Rivers and Harbors Act of 1899 and Section 404 of the Clean Water Act, would be required from
the Corps to conduct activities related to the decommission of the beach gravity sewer; and
WHEREAS Ecology and the Corps have agreed that EPA will act as Lead Federal agency for
Section 106 compliance and will act on the Corps behalf; and
WHEREAS per 36 CFR 800 (c)(1)the following parties are defined as Signatories:
• The Agency Official—United States Environmental Protection Agency.
• The Agency Representative—The Washington State Department of Ecology.
• The State Historic Preservation Officer- Washington Department of Archaeology and
Historic Preservation.
• The Tribal Historic Preservation Officer—Suquamish Indian Tribe of the Port Madison
Reservation
WHEREAS per 36 CFR 800 (c)(2)the agency official may invite additional parties to be
signatories to a memorandum of agreement. The following are invited Signatories:
• City of Bremerton.
WHEREAS together the Signatories and Invited Signatories shall be referred to as Signatories
and Invited Signatories (together, Signatories)to this Agreement.
WHEREAS each of the Signatories has identified a party representative (together,Parries) as
the primary contact for implementation of the stipulations; and
NOW THEREFORE, Ecology and the Parties agree the Undertaking will be implemented in
accordance with the following stipulations to take into account the adverse effects of the
undertaking upon the identified historic property.
STIPULATIONS:
Ecology, in cooperation with DAHP, the Suquamish Indian Tribe of the Port Madison
Reservation and the City, shall ensure that the following stipulations are met to account for the
adverse effects upon the discovered and potentially unrecovered cultural resources:
I. AUTHORIZATION TO PROCEED WITH UNDERTAKING
Execution of this Agreement constitutes authorization to the City to proceed with the
Undertaking and implement the Work Plan—Construction Phase, which is Attachment A.
The City believes there is the highest probability for finding cultural resources, and the City
developed a Work Plan prior to construction. This authorization is solely for purposes of
compliance with the NHPA and does not constitute any authorization for approvals that may be
required under other state and federal statutes.
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II. POST-REVIEW DISCOVERIES
The remainder of the work for this project will also utilize the existing inadvertent discovery
plan(IDP) included as an Attachment of this MOA(Attachment D)in the event further cultural
material or unanticipated effects are identified.
III. STANDARDS AND HUMAN REMAINS
All work carried out pursuant to this Agreement shall meet the Secretary of the Interior's
Standards for Archaeology and Historic Preservation(SOI's Standards webpage:
https://www.doi.gov/pam/asset-management/historic-preservation/pqs ), considering the
suggested approaches to new construction in the SOI's Standards for Rehabilitation.
The City shall ensure that all work carried out pursuant to this Agreement shall be done by or
under the direct supervision of historic preservation professionals who meet the Secretary of
the Interior's Professional Qualifications Standards. Ecology and the City shall ensure that
consultants retained for services pursuant to the Agreement meet these standards.
Historic and prehistoric human remains from non-federal, non-tribal lands are subject to
protection under the Washington burial/unmarked grave/cemetery laws. As such, if human
remains are discovered during construction,the Section 6.0 SPECIAL PROCEDURES FOR
THE DISCOVERY OF HUMAN SKELETAL MATERIAL of the DAHP-reviewed
Ecology Inadvertent Discovery Plan(Attachment D) will immediately apply per RCW
27.44.055, RCW 68.50, and RCW 68.60, DAHP will have jurisdiction over non-forensic human
remains. Ecology staff will participate in consultation as needed. Refer to Attachment A:
Work Plan for further details.
IV. MONITORING
The Signatories approve, adopt and ratify, and concur with the monitoring protocol set forth in
the attached Work Plan (Attachment A). Its terms and provisions shall govern and control the
areas, process,procedures, and methods for handling cultural resources and any human remains
discovered in the APE.
If the City archaeologist identifies a project activity proposed to take place outside of the areas
identified in the Work Plan,this will constitute a material change. If the archaeologist believes
that a material change has been made,then the archaeologist will provide the City with a
narrative description of the material change and an archaeological testing strategy in writing that
considers the aerial and vertical extent, which should match the project activity where possible.
The City will notify Ecology that an additional level of testing is requested. Ecology will notify
the Party Representatives. The written archaeological testing request will be appended to the
weekly archaeological report for the week of the request.
If the City makes any changes to the APE,the Consulting Parties will discuss the appropriate
level of monitoring to be conducted in that area prior to any ground disturbance. The City will
convey the change in the APE and proposed testing strategy to Ecology, for distribution to the
Party Representatives for review and comment.
The Party Representatives shall have minimum of 48 hours and a maximum of ten working days
to review and approve the material change and proposed testing strategy and respond to Ecology
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Bremerton MOA DAHP 2022-04-02418
and the City with questions and concerns. Ecology shall have a minimum of 48 hours and a
maximum of ten working days to review the responses from Party Representatives, unless all the
Party Representatives agree to a longer period (not more than 20 working days). Ecology shall
notify the Party Representatives of its approval of the testing protocol via email and will include
the revised Treatment Plan. The revised Work Plan will replace the Work Plan currently
included as Attachment A to this Agreement and shall be subject to all of the stipulations
contained herein.
V. REPORTING
Following the execution of this MOA until it expires or is terminated,the City's archaeologist
will follow the Work Plan Communication Plan, for pre-field notifications, discoveries, and
field updates to all parties to this MOA. Updates will include a summary via email detailing
work undertaken pursuant to its terms. Summary shall be provided on a weekly basis for any
week that monitoring is conducted. Such report shall include any scheduling changes proposed,
any problems encountered, and any disputes and objections received in the City's efforts to
carry out the terms of this MOA.
If other persons or entities outside of this Agreement request copies of any weekly summary
Ecology shall notify Party Representatives of such request and afford a reasonable opportunity
for any Party Representative to object to the release of such report based on the application of
specific exemptions from release found in the Public Records Act(RCW 42.56) or other state or
federal law. If a Party Representative objects to the release of such report where no exemption
applies, the Party Representative may seek an injunction preventing release as provided by RCW
42.56.540.
By January 31 of each year, until a determination in writing is issued that the project is complete
or the Agreement is terminated,the City shall prepare and provide an annual report based upon
DAHP Washington State Standards for Cultural Resource Reporting to Ecology
Ecology will provide the annual report to the Parties to this Agreement. The Party
Representatives shall review the annual report and provide comments to Ecology, who shall
provide them to the City.
Following completion of the Undertaking as defined in Stipulation XII below, or Termination as
defined in Stipulation IX below, the City shall provide to Ecology, who will distribute to all
Party Representatives, a final summary report detailing work undertaken pursuant to its terms,
including pursuant to the Treatment Plan.
A final draft archaeological report will be prepared within 90 days after completion of the
archaeological fieldwork. The City will provide the report to Ecology who will distribute it to
the other Party Representatives.
VI. NATIONAL REGISTER NOMINATION
The City, in collaboration with the Suquamish THPO, will provide to Party Representatives an
independent evaluation of the significance of the property, including preparation of
documentation supporting its significance. The professional will prepare the NRHP nomination
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Bremerton MOA DAHP 2022-04-02418
form (10-900 form)for 45KP9 within 1 (one)year following notice of substantial completion.
The final document will conform to the format and requirements of the National Register
Bulletin 36. This document will be completed by a professional meeting the Secretary of the
Interior's Professional Qualification Standard for Archaeology.
VII. EDUCATION AND INTERPRETATION
The City will design, fabricate, finance, and install one (1) interpretive sign in a public location
educating the public about the importance of the Manette area to Native American Tribes.
1. The City will coordinate with the Suquamish THPO regarding the content of the
interpretive sign.
2. The City will ensure that draft content on the sign is submitted to the consulting parties
within one year of the final signature on this agreement.
3. The City will ensure that the sign incorporates text and images constructed of a durable,
weather-resistant design.
4. The City will ensure the signage is onsite one year after notice of substantial
completion of the construction of this project.
VIII. DATA RECOVERY
Legacy and current data on the Manette site will be appropriately catalogued according to
Washington State Standards and/or Federal Standards (36 CFR Part 79). The Suquamish THPO
recommends developing one comprehensive report on the Manette Site.
Methodology:
For previous or additional data recovery, see the section on Data Recovery in the Phase 3
Work Plan. For Phase 3, controlled excavation sampling through identified stratigraphy
using controlled units is recommended. Any additional data recovered will be presented to
the Suquamish Indian Tribe of the Port Madison Reservation for curation.
Curation and Legacy Collections:
The collection of historical information on the Manette Site at the Suquamish Indian Tribal
Museum requires cataloguing to Washington State Standards and/or Federal Standards (36
CFR Part 79). There are multiples boxes of artifacts and records. The Suquamish THPO
will present a work plan for curation prior to the end of Phase 3, or the Burke Museum
Curation Guidelines will be adopted, Version 1.11.2023 (see
https://www.burkemuseum.org/sites/default/files/2023-01/curation-guide-v1.11-2023.pdf)
IX. DURATION OF AGREEMENT
This MOA will expire if its terms are not carried out within five (5)years from the date of its
execution. Prior to such time, Ecology may consult with the other parties to reconsider the
terms of the MOA and amend it in accordance with Stipulation VIII below.
X. DISPUTE RESOLUTION
Should any Signatory or invited Signatory (Signatories)to this MOA object at any time to any
actions proposed or the manner in which the terms of this MOA are implemented,the EPA shall
consult with such party to resolve the objection. If EPA determines that such objection cannot be
resolved, EPA will:
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Bremerton MOA DAHP 2022-04-02418
1. Forward all documentation relevant to the dispute, including the EPA's proposed
resolution, to the ACHP. The ACHP shall provide EPA with its advice on the resolution
of the objection within thirty (30) days of receiving adequate documentation. Prior to
reaching a final decision on the dispute, EPA shall prepare a written response that takes
into account any timely advice or comments regarding the dispute from the ACHP,
signatories, and provide them with a copy of this written response. EPA will then proceed
according to its final decision.
2. If the ACHP does not provide its advice regarding the dispute within the thirty (30) day
time period, EPA may make a final decision on the dispute and proceed accordingly.
Prior to reaching such a final decision, EPA shall prepare a written response that takes
into account any timely comments regarding the dispute from the signatories to the
MOA, and provide them and the ACHP with a copy of such written response.
3. EPA's responsibility to carry out all other actions subject to the terms of this MOA that
are not the subject of the dispute remain unchanged.
XI. AMENDMENTS
Any Signatory to this MOA may request that the Agreement be amended, whereupon the
Parties to this Agreement will consult in accordance with 36 C.F.R. § 800.6(c)(7)to
consider such amendment. This MOA may be amended when such an amendment is
agreed to in writing by all Signatories. The amendment will be effective on the date a
copy is signed by all Signatories.
XII. TERMINATION
1. If any Signatory to this MOA determines that the terms will not or cannot be carried out,
after pursing the Dispute Resolution process set out in the Stipulation VII above, and
after attempting to craft an amendment per Stipulation VIII above, that Party may
terminate the MOA upon written notification to other signatories.
2. Termination shall include the submission of a technical report and/or other
documentation by the City to the Signatories on work done up to and including the date
of termination.
3. Once the Agreement is terminated, Ecology must either(a) execute an Agreement
pursuant to 36 C.F.R. § 800.6; or(b)request, take into account, and respond to any
comments from the ACHP under 36 C.F.R. § 800.7(c)(4). Ecology shall notify the
Parties to this Agreement as to the course of action it will pursue. Prior to Ecology's
decision or after, the City may request and Ecology may authorize the City to proceed
with the Undertaking if the City can demonstrate compliance with 36 CFR §800.4.
XIII. EXPIRATION
This Agreement shall be effective for five (5)years from the date of the last signature
below.
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Bremerton MOA DAHP 2022-04-02418
XIV. ANTI-DEFICIENCY ACT
1. This Agreement is neither a fiscal nor a funds obligation document of Ecology or EPA.
Any funding to be provided by the Ecology will be done pursuant to a separate funding
agreement.
2. Nothing in this MOA, in and of itself, obligates EPA to expend appropriations or to enter
into any contract, assistance agreement, interagency agreement, or incur other financial
obligations that would be inconsistent with Agency budget priorities.
XV. SCOPE OF AGREEMENT
1. This Agreement is limited to the Undertaking and is entered into solely for that purpose.
2. Nothing in this Agreement is intended to or shall be construed to diminish or affect in any
way any of the Signatories' rights, obligations, or remedies under other state or federal
laws, including but not limited to Washington's Indian Graves and Records Act, RCW
Ch. 27.44, and Archaeological Resource and Sites Act, RCW Ch. 27.53, or the right of
any Tribe to take any lawful action to protect Native American graves from disturbance
or desecration or to protect archaeological sites or cultural resources from damage.
3. This Agreement in no way restricts any Signatory or Invited Signatories from
participating in any activity with other public or private agencies, organizations, or
individuals, except as provided for in the Work Plan. This Agreement will be subject to,
and will be carried out in compliance with, all applicable laws, regulations, and other
legal requirements.
4. This Agreement does not create any right or benefit, substantive or procedural,
enforceable by law or equity, by persons who are not a Signatory or Invited Signatory to
this Agreement, against the DAHP, Ecology, the City, Suquamish THPO, or the EPA, or
their officers, agents, and employees. Nothing in this Agreement is intended to or shall
be construed to waive the sovereign immunity of any Signatory or Invited Signatory.
5. If, following execution of this Agreement, Ecology decides not to offer financial
assistance from the CWSRF to the City for the Undertaking that is the subject of this
Agreement,this Agreement will automatically become null and void.
6. This Agreement shall not be interpreted as limiting, superseding, or otherwise affecting
the EPA's normal operations or decisions in carrying out its statutory or regulatory duties.
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Bremerton MOA DAHP 2022-04-02418
XVI. PRINCIPAL CONTACTS/PARTY REPRESENTATIVES
All notifications required pursuant to this Agreement shall be made to the Party
Representatives in this Stipulation. The parties may designate different Party
Representatives by informing Ecology by official letter or email, and Ecology will inform the
other parties. The principal contacts for this Agreement are as follows:
EPA:
Signatory:
Caleb Shaffer
Acting Director, Water Division
US Environmental Protection Agency, Region 10
1200 Sixth Avenue, Suite 155, Mailstop 19-009
Seattle, Washington 98101
Phone: +1 503-326-5015
Mobile: +1 503-307-3076
Party Representative:
David Carcia
Project Officer, Clean Water State Revolving Fund
Water Division
Environmental Protection Agency, Region 10
1200 Sixth Avenue, Suite 155
Seattle, WA 98101
Phone: (206) 553-0890
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Bremerton MOA DAHP 2022-04-02418
Ecology:
Signatory:
Vincent McGowan, P.E.
Water Quality Program Manager
Washington Department of Ecology
P.O. Box 47600
Olympia, Washington 98504-7600
Email vincent.mcgowan@7ecy.wa.gov
Phone: 360-407-6405
Alternate: 360-407-6000
Party Representative:
Liz Ellis, Environmental Review Coordinator
Water Quality Program
Washington Department of Ecology
P.O. Box 47600
Olympia, Washington 98504-7600
liz.ellis@ecy.wa.gov
Phone: (360) 628-4410
DAHP:
Signatory:
Dr. Allyson Brooks, State Historic Preservation Officer
Washington Department of Archaeology & Historic Preservation
1063 S. Capitol Way, Suite 106
PO Box 48343
Olympia, WA 98504-8343
allyson.brooks@dahp.wa.gov
Phone: (360) 480-6922
Party Representative:
Rob Whitlam, State Archaeologist
Washington Department of Archaeology & Historic Preservation
1063 S. Capitol Way, Suite 106
PO Box 48343
Olympia, WA 98504-8343
rob.whitlam@dahp.wa.gov
Phone: (360) 890-2615
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Bremerton MOA DAHP 2022-04-02418
Bremerton(City of):
Signatory:
Mayor Greg Wheeler
City of Bremerton, WA
345 6th Street
Bremerton, WA 98337
Email: greg.wheeler@ci.bremerton.wa.us
Phone (360)473-5266
Party Representative:
William Davis
Managing Engineer
345 6th Street
Bremerton, WA 98337
Email: william.davis@ci.bremerton.wa.us
Phone: (509) 754-4601 x. 114
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Bremerton MOA DAHP 2022-04-02418
Suquamish Indian Tribe of Port Madison Reservation
Signatory
Chairman Leonard Forsman
P.O. Box 498
Suquamish, WA 98392
Email: lforsman@suquamish.nsn.us
Phone: (360) 598-3311
Alternate: (360)
Party Representative:
Stephanie Trudel, THPO
P.O. Box 498
Suquamish, WA 98392
Email: strudel@suquamish.nsn.us
Phone: (360) 394-8533
Alternate: (360) 509-1321
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XVII. EXECUTION OF AGREEMENT
1) This Agreement may be executed in counterparts, with a separate page for each
Signatory. Ecology will ensure that each Party Representative is provided with a copy of
the fully executed Agreement.
2) Execution of this Agreement by Ecology and the SHPO and its submission to the ACHP
in accordance with 36 C.F.R. 800.6(b)(1)(iv), will, pursuant to 36 C.F.R. 800.6(c), be
considered to be an agreement pursuant to the regulations issued by the ACHP for the
purposes of Section 110(1) of the NHPA, 16 U.S.C. 470h-2(1). Execution, submission,
and implementation of the terms of this Agreement demonstrate that the EPA has
afforded the ACHP an opportunity to comment on the proposed Undertaking and its
effect on historic properties and that the EPA has taken into account the effect of the
Undertaking on historic properties in accordance with Section 106 of the NHPA, 16
U.S.C. 470(F).
3) This Agreement shall be effective on the date of the latest signature below.
Each undersigned official certifies that he or she is fully authorized to enter into the terms and
conditions of this Agreement and to execute and legally bind the Party he or she represents to
this document.
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Bremerton MOA DAHP 2022-04-02418
DocuSign Envelope ID: F10A6C49-D5E8-4329-A75B-EFD80A04C600
SIGNATORY:
THE CITY OF BREMERTON
DocuSigned by:
IKAMARA,
✓J ti2.Cv
By: BAF46095E8E747B... Date: 2/6/2024
Mayor Greg Wheeler
City of Bremerton
SIGNATORY:
THE WASHINGTON DEPARTMENT OF ECOLOGY
By: Date:
Vincent McGowan, P.E.
Water Quality Program Manager
15
Bremerton MOA DAHP 2022-04-02418
SIGNATORY:
WASHINGTON STATE DEPARTMENT OF ARCHAEOLOGY AND HISTORIC
PRESERVATION
By: Date:
Dr. Allyson Brooks
State Historic Preservation Officer
16
Bremerton MOA DAHP 2022-04-02418
SIGNATORY:
THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
By: Date:
Caleb Shaffer
Acting Director, Water Division
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Bremerton MOA DAHP 2022-04-02418
SIGNATORY PARTY:
THE SUQUAMISH INDIAN TRIBE OF PORT MADISON RESERVATION
By: Date:
Leonard Forsman
Chairman
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Bremerton MOA DAHP 2022-04-02418
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Bremerton MOA DAHP 2022-04-02418
Attachment A—Work Plan
(Construction Phase)
To view, please visit WISAARD and log into Secure-Side Access.
Bring up DAHP Project:
2022-04-02418 - Manette Beach Sewer Upgrades (EB-2 to OF-4)
https://wisaard.dahp.wa.gov/Projects/204612/Overview
Pull up Inventory and Evaluations > Reports, and click on:
Johnson, P. and A. Taylor, WCRA. 2023. City of Bremerton Manette Decommission Beach
Sewer Phase 3 Archaeological Work Plan
December 1, 2023. 40 pp.
https://wisaard.dahp.wa.gov/Projects/204612/ProjectResources/881198/Report/772440
Reports will be provided upon request.
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Attachment B
Cultural Resources Reports
Reports are too large for attachment. To view,please visit WISAARD and log into
Secure-Side Access, bring up DAHP Project 2022-04-02418 - Manette Beach Sewer
Upgrades (EB-2 to OF-4)
https://wisaard.dahp.wa.gov/Projects/204612/Overview
Pull up Inventory and Evaluations > Reports, and click on:
• Gardner, J. CRC. 2022. Cultural Resources Assessment for the Manette Beach
Sewer Upgrades (EB-2 to OF-4) (Parametrix Project No. 2331896179),
Bremerton, Kitsap County, Washington. April 27, 2022. 85 pp.
• Johnson, P., Kopperl, B., Kramer, S. and A. Jenkins. WCRA. 2023. Manette
Decommission Beach Sewer from OF-4 to EB-2 Project, 45KP9 Geotechnical
Monitoring and Site Characterization Report. May 4, 2023. 42 pp.
• Johnson, P. and A. Taylor. WCRA. 2022. City of Bremerton Manette
Decommission Beach Sewer Phase 2 Archaeological Work Plan. December 9,
2022,updated January 24, 2023. 29 pp.
Reports will be provided upon request.
21
Bremerton MOA DAHP 2022-04-02418
Attachment C
Nomination Form Placeholder
Nomination by Consensus has occurred. Any associated forms will be inserted here.
Eligibility statement has been drafted and uploaded to WISAARD. To view please visit
WISAARD and log into Secure-Side Access, bring up DAHP Project 2022-04-02418 -
Manette Beach Sewer Upgrades (EB-2 to OF-4). Click on Inventories and Evaluations >
Reports, and click on 45KP0009:
https://wisaard.dahp.wa.gov/Proiects/204612/Prof ectResources/882113/Archaeologylnve
ntory/56550
22
Bremerton MOA DAHP 2022-04-02418
Attachment D
Inadvertent Discovery Plan
Please visit DAHP's WISAARD and go to:
2022-04-02418 - Manette Beach Sewer Upgrades (EB-2 to OF-4)
https://wisaard.dahp.wa.gov/Projects/204612/Overview
Go to Inventory and Reports
or click on:
Bremerton Inadvertent Discovery Plan
https://wisaard.dahp.wa.gov/Projects/204612/ProjectResources/881018/Report/772299
23
Bremerton MOA DAHP 2022-04-02418
6. Ecology will compile all received signatory pages into one secured document. You will
receive an electronic copy, and it will be uploaded to WISAARD. Paper versions will be
provided at request.
Deadline
Please have your signatory sign within 14 days upon receipt of this email. Should you need
more time, please let Ecology(Liz Ellis) know. Suggested deadline: January 26, 2024
Please send any comments, concerns, or questions to:
Liz Ellis, Environmental Review Coordinator
Clean Water State Revolving Fund
Water Quality Program
Department of Ecology
P.O. Box 47600
Olympia, WA 98504-7600
(360) 628-4410
Liz.ellis@ecy.wa.gov
Thank you for your hard work on this Agreement.
Sincerely,
Liz Ellis
Environmental Review Coordinator
Clean Water State Revolving Fund
Water Quality Program
Department of Ecology
(360) 628-4410
cc: David Powell, Engineering Project Manager
Paula Johnson, Willamette Cultural Resources Associates, Ltd.
Enclosure: FINAL Memorandum of Agreement (2024)
Signatory Page
ce1WILLAMETTE
CULTURAL RESOURCES ASSOCIATES,LTD.
City of Bremerton Manette Decommission Beach Sewer
Phase 3 Archaeological Work Plan
Prepared by Paula Johnson, M.A., RPA and Amanda Taylor, Ph.D., RPA
December 1 , 2023
Project Description
The City of Bremerton (City) is planning a sewer project in the Manette Beach area between E
16th Street and the Manette Bridge. Many of the residences (single family homes,
condominiums, and apartments) in the area are connected to a gravity-fed sewer main located
in the tidelands of the Port Washington Narrows. The existing sewer infrastructure in the
tidelands is difficult to maintain and potentially deleterious to the marine environment. To
address this issue, the City will be installing an upland sewer system and abandoning the beach
main and lateral connections (Project). A new City pump station (EB-7) and individual grinder
pump stations will pump flow from individual residences into an existing upland sewer on
Wheaton Way.
Project Location
The Project is located in Section 13 of Township 24 North, Range 1 East, Willamette Meridian.
(Figure 1) in the City of Bremerton, Washington. The Project is located within the rights-of-way
of E 16th St, E 13th St, and Marlow Ave, and on numerous adjacent private parcels (Figure 2).
Archaeological site 45KP9 is located within the Project's Area of Potential Effects (APE). Human
remains have been reported at this site since the 1930s. Human remains have been identified in
the 1930s, 1940s, 1960s, and 1970s. The site is recorded at a location known to the native
community as xaxa meaning "to cry out" or "to be taboo," described as a camping and clam
gathering place with canoe burials in trees (Snyder 1968). This large shell midden site extends
approximately 180 meters northwest to southeast along the Port Washington Narrows shoreline
and extends inland approximately 20 meters from the current bulkhead. See Taylor et al. 2023
for a more comprehensive description of the site. Archaeological site 45KP9 is recommended
Eligible for listing in the National Register of Historic Places (NRHP) under Criterion A and D
(Taylor et al. 2023:30).
Regulatory Environment
This Project is receiving federal funding from the Environmental Protection Agency (EPA) and
administered by the Washington State Department of Ecology (Ecology). Ecology requires all
655 S Orcas St#220, Seattle, WA 98108
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Figure 2. Project Elements
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work conducted under their auspices to follow the provisions in Ecology's Inadvertent Discovery
Plan (IDP). This Work Plan follows the discovery sequence required by Ecology and the IDP is
attached as Appendix A.
Previous Archaeological Monitoring
Phase 1 monitoring outside the boundary of 45KP9 associated with pre-construction
geotechnical and utility locate tasks was conducted by WillametteCRA on November 10 and 23,
2022. Nine potholes were excavated by vactor truck and sediment consisted of glacial outwash,
in some cases mixed with fill. No cultural materials were identified. WillametteCRA monitored
Phase 2 geotechnical investigations inside the 45KP9 site boundary on March 2, 2023. Phase 2
tasks included hand-dug geotechnical holes placed behind the existing bulkheads located on
properties where human remains have been previously reported. This monitoring encountered
shell midden behind the seawall the Shores East Condo southern building at 122-127
centimeters below surface (cmbs). That investigation and another investigation previously
conducted for the Project both identified intact shell midden deposits, which indicates isolated
intact portions of the site are still present (Gardner 2022; Taylor et al. 2023). Presence of
artifacts on the beach is also consistent with cultural deposits that are still present despite
substantial development. Intact shell midden has been observed below fill in three locations with
an upper depth between 18-50 inches (44-127 cm) below surface. Most excavation for the
project will be between 2 to 4 feet (24-48 inches or 61-121 cm) below surface.
Project Phasing
The City proposes conducting Project tasks in phases. This Work Plan is for Phase 3 work
which includes all construction tasks inside and outside the 45KP9 site boundary (Table 1).
Construction will involve installation of new grinder pumps, trenching for new pipes, and a new
City pump station (EB-7). Existing gravity sewer lines on private property will be capped and
abandoned in place; these activities require minimal additional excavation. Existing gravity
sewer lines on the beach will be capped and abandoned in place, however the manholes will be
excavated to demolish them approximately 3 feet below surface.
Phase 3 will be split into two subphases: Phase 3a and 3b. The purpose of this approach is to
give the archeologist and contractor adequate time to investigate the sites. This approach
reduces the risk of construction delays and associated costs and improves preservation.
1. Phase 3a is excavation for the 5 grinder pumps within the 45KP9 site boundary and 1
grinder pump in the Manette Shores Condo Association parking lot.
2. Phase 3b is all other excavation.
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Phase 3a
Phase 3a will be completed first; the schedule will include adequate time to conduct data
recovery if human remains or cultural resources are present. Up to a week will be scheduled for
excavation for each grinder pump within the 45KP9 site boundary or Manette Shores Condo
Association parking lot. Phase 3a will also inform expectations for cultural resources to be
present in trenches. When Phase 3a excavation is complete, the excavation will be lined (such
as with geotextile fabric or a tarp) and backfilled with spoils (either non-cultural material or
screened cultural material) and/or imported material.
Phase 3b
Phase 3b will be initiated once Phase 3a is complete. Phase 3b is all other excavation and
construction activities for the overall Project, both inside and outside the 45KP9 site boundaries.
Table 1. Project Ground Disturbance
Ground Disturbance Inside 45KP9 Ground Disturbance Outside of 45KP9 Boundaries
Boundaries
PHASE 3a: PHASE 3a:
• Grinder Pump Stations: 5 locations, • Grinder Pump Station: 1 location (in Manette Shores
each assumed to be maximum 8 feet x Condo Association parking lot), assumed to be
8 feet [or 7.5 feet in diameter] and up maximum 8 feet x 8 feet [or 7.5 feet in diameter]and up
to 8 feet deep. to 8 feet deep
PHASE 3b: PHASE 3b:
• Trenching: 650 linear feet, dimensions • Grinder Stations: 6 locations, each assumed to be
assumed to be maximum 4 feet deep maximum 8 feet x 8 feet [or 7.5 feet in diameter]and up
and 2 feet wide. to 8 feet deep.
• Manhole Abandonment on beach: 2 • Trenching: 3,400 linear feet, dimensions assumed to
locations, dimensions to be 6 feet x 6 be maximum 4 feet deep and 2 feet wide.
feet and 3 feet deep. Note this will be
in the intertidal zone. • Manhole Abandonment: 3 locations, dimensions to be
6 feet x 6 feet and 3 feet deep. Note this will be in the
intertidal zone.
• EB-7 Pump Station:
O 8-inch-diameter gravity sewer, dimensions assumed
to be 4 feet wide x 50 feet long and 12 feet deep.
o Wet well, dimensions of 12 feet x 12 feet and 15 feet
deep
o Valve vault, dimensions of 13 feet x 10 feet and 8
feet deep
• EB-7 Force Main Trenching: 450 linear feet,
dimensions assumed to be average of 4 feet deep and
2 feet wide, with maximum of 6 feet deep and 3 feet
wide.
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Areas Requiring Monitoring
Three monitoring approaches will be used within the APE: On-Site, On-Site with potential to
reduce level of effort, and On-Call (Table 2, Figure 3).
Table 2. Monitoring Approach
Monitoring Approach Locations
On-Site Any ground disturbance within current site boundaries
On-Site with potential to Any ground disturbance outside of current site boundaries within the
reduce level of effort Manette Shores Condo Association property, Shores East Condo property,
and Sunset Shore Apartment property
On-Call Any ground disturbance outside of site boundaries and north of Manette
Shores Condos
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•q As - - t - RECOMMENDATIONS
eOn-Site Monitoring(within 45KP09)
t '1 eon-Site Monitoring with Potential to
Reduce Level of Effort
, •
4 eon-Call Monitoring
:, at• ..�.st
. --- Beach Survey Area(within 45KP09)
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-WILLAMETTECRA 2021 Kitsap Co.Air photo , ti •
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Figure 3. Monitoring Approach.
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Phase 3 Monitoring Methods
Archaeological Personnel and Roles
The Project Archaeologist will be the primary point of contact for the Contractor and City. The
Project Archaeologist will coordinate on staffing of Archaeological Monitors and schedule,
conduct notifications if archaeological deposits or human remains are identified, and submit
weekly reporting. The Project Archaeologist meets the Secretary of the Interior's Professional
Qualifications for Archaeology (48 FR 44738).
The Principal Investigator will direct field investigations in coordination with the City and
Contractor if cultural resources are identified and data recovery is required. The Principal
Investigator meets the Secretary of the Interior's Professional Qualifications for Archaeology (48
FR 44738).
Archaeological Monitors will observe excavation during construction in accordance with this
work plan. At times, multiple Archaeological Monitors will observe work in order to facilitate
screening of spoils and/or if ground disturbing activities are occurring in more than one location.
At least one Archaeological Monitor will be skilled in identification of human remains.
Tribal Monitors may observe work over the course of the project.
Monitoring Approach
Construction Crew Orientation
Prior to construction the Project Archaeologist (Paula Johnson) and Lead Monitor (TBD) will
conduct an onsite orientation for all construction crew members involved in ground-disturbing
work. The focus of the orientation is to inform and familiarize construction personnel with the
monitoring protocols, inadvertent discovery protocols, and notification requirements. On-going
orientation will be required when new construction staff join the Project; this will be provided by
the Lead Monitor at weekly tailgate meetings.
The Project Archaeologist will coordinate with the City and the construction team to understand
the staffing needs. If work is occurring in multiple areas more than one Archaeological Monitor
may be needed.
Monitoring Techniques
Archaeological Monitors and Tribal Monitors will be required to wear proper Personal Protective
Equipment (PPE) when within construction boundaries. Archaeological Monitors will observe
excavation and soil removal from multiple perspectives in front of and around working
equipment, requiring close communication with construction supervisors and equipment
operators. Archaeological Monitors may request that excavation be conducted in thin lifts
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(approximately 4 inches) to allow controlled exposure of suspected cultural materials.
Archaeological Monitors may request permission to enter excavation areas to obtain samples or
take photographs. Tribal monitors may observe work over the course of the project.
Excavation within the site boundaries must be conducted with a toothless bucket until glacial till
is encountered. If the Contractor encounters subsurface conditions that cannot be excavated
with a toothless bucket, a toothed bucket can be used upon approval of the Archaeological
Monitor. The Contractor shall not use a toothed bucket within site boundaries without prior
written approval by the Archaeologist. If there are no cultural materials identified in an
excavation area, monitoring the excavation of glacial till will not be required.
Monitoring Level of Effort
Table 3 below describes the monitoring level of effort for various construction activities. If
excavation in one area identifies cultural materials, work may continue in other areas of the
project. Flowcharts depict the process to be followed if cultural materials or human remains are
identified during excavation of grinder pumps or trenches (Figure 4 and Figure 5).
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Table 3. Monitoring Level of Effort by Location
Construction Activity Monitoring Level of Effort
Pump Grinder Excavation WITHIN SITE BOUNDARIES and Manette Shores Condo
Association Parking Lot
(19 cubic yards [CY] of • On-Site Monitoring required.
anticipated disturbance per • Archaeologist to direct whether spoils must remain on site
grinder pump) temporarily (contain cultural) or may be hauled offsite
(glacial or non-cultural deposits). Where there is
insufficient space to store culturally significant spoils on
the site due to space constraints, the Archaeologist will
direct the Contractor to move spoils off-site to a pre-
determined location for temporary storage and screening.
The screening location will be identified in the construction
plans.
• 0-2 feet below surface excavated at moderate pace
• 2-4 feet below surface excavated in 4" lifts (slow pace)
• Archaeologist will have opportunity to enter excavation
zone prior to excavation below 4 feet. Contractor will
provide safe access and egress for Archaeologists.
• If cultural deposits are encountered, mechanical
excavation will be paused. Archaeologists will determine if
the cultural deposits are intact or disturbed. If intact, data
recovery will be conducted (see Data Recovery section
below). If disturbed, archaeologists will screen spoils (see
Screening section below).
• If human remains are identified or suspected, mechanical
excavation will be paused. The notification procedures in
Section 6 of the IDP will be followed.
• Once Data Recovery is completed, mechanical excavation
may resume. Cultural deposits (disturbed or intact) will be
stockpiled for screening (see Screening section below).
• If cultural materials are present in sidewalls, Archaeologist
will continue to monitor all ground disturbance.
OUTSIDE OF SITE BOUNDARIES
• On-Call monitoring.
o No archaeological monitor will be present.
• Follow IDP protocols if artifacts identified during
excavation.
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Construction Activity Monitoring Level of Effort
Trench Excavation WITHIN SITE BOUNDARIES
• On-Site Monitoring required.
• Archaeologist to direct whether spoils must remain on site
temporarily or may be hauled offsite.
• 0-2 feet below surface excavated at moderate pace
• 2-4 feet below surface excavated in 4" lifts (slow pace)
• If a feature is identified, sampling will be conducted (see
Sampling section below).
• If cultural deposits are encountered, mechanical
excavation will be paused. Archaeologists will determine if
the cultural deposits are intact or disturbed. If intact,
sampling will be conducted (see Sampling section below).
If disturbed, archaeologists will screen spoils (see
Screening section below).
• If human remains are identified or suspected, mechanical
excavation will be paused. The notification procedures in
Section 6 of the IDP will be followed.
• Once Data Recovery and/or Sampling is completed,
mechanical excavation may resume. Cultural deposits
(disturbed or intact) will be stockpiled for screening (see
Screening section below).
• Once excavation encounters glacial material, excavation
may proceed at typical pace. If cultural materials are
present in sidewalls, Archaeologist will continue to monitor
all ground disturbance.
WITHIN MANETTE SHORES CONDO, SHORES EAST
CONDO, and SUNSET SHORE APARTMENT PARKING
LOTS
• On-Site Monitoring required until glacial encountered.
• Archaeologist may recommend reducing monitoring level
of effort to On-Call depending on observations.
• Archaeologist to direct whether spoils must remain on site
temporarily or may be hauled offsite.
• If cultural materials (disturbed or intact) are present, follow
trenching procedures for within site boundaries (above).
OUTSIDE OF SITE BOUNDARIES AND NORTH OF
MANETTE SHORES CONDOS
• On-Call monitoring.
o No archaeological monitor will be present.
• Follow IDP protocols if artifacts identified during
excavation.
979-
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Construction Activity Monitoring Level of Effort
Manhole Abandonment WITHIN SITE BOUNDARIES
• On-Site Monitoring required. _
OUTSIDE OF SITE BOUNDARIES
• On-Call monitoring.
o No archaeological monitor will be present.
Follow IDP protocols if artifacts identified during excavation.
EB-7 Pump Station • On-Call monitoring.
o No archaeological monitor will be present.
• Follow IDP protocols if artifacts identified during
excavation.
EB-7 Force Main • On-Call monitoring.
Trenching o No archaeological monitor will be present.
• Follow IDP protocols if artifacts identified during
excavation.
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Phase 3a
Excavation of Grinder Pump
Cultural Materials Identified I No Cultural Materials Identified
Excavation pauses.Archaeologist determines if deposits are intact or disturbed.
Archaeologist monitors until glacial till is
encountered. Once desired depth is
Disturbed Cultural Humans remains identified in Intact Cultural Materials reached,the excavation will be lined
Materials Identified grinder pump excavation area Identified (such as with geotextile fabric ortarp)
and backfilled with excavated spoils
t _ ♦ and/or imported fill.
Implement Notification Procedures Archaeologist conducts data recovery and excavates one 1
Excavation resumes. in Section 6 of the OP. Await further x 1-meter test unit(TU).Excavation will be conducted in 10
Archaeologist monitors instructions. cm arbitrary levels until 10 cm below cultural deposits,or
mechanical excavation of upon encountering glacialsediments.If a feature is found
disturbed cultural materials by and extends outside of the TU,Archaeologist excavates an
Contractor. Disturbed spoils adjacentTU(lx 1-meter or smaller).
will be mechanically removed
by Contractor for screening. Once data recovery is complete,excavation may resume.
Remaining cultural deposits will be mechanically removed
by Contractor for screening.
Archaeologist will conduct screening of cultural materials,either adjacent to grinder pump or at Screening Area.Contractor places spoils for screening as directed by
Archaeologist.Archaeologistwill collectformed tools and will examinre faunal materialsto identify potential fragmentary human remains.
Human remains NOT identified 4 Humans remains identified in screen
Implement Notification Procedures in Section 6
of the IDP. Continue screening.
•
Screening is completed,excavation may resume until desired depth is reached.Once desired depth is reached,the excavation will be lined(such as with geotexti le
fabric or tarp)and backfilled with excavated spoils(mix of screened cultural and non-cultural spoils)and/or imported material.
Figure 4. Process for Phase 3a excavation of grinder pumps (within 45KP9 site boundaries and in Manette Shores Condo
Association parking lot).
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Phase 3a
Excavation of Trenches
Cultural Materials Identified No Cultural Materials Identified
E'.ce.e:r pcu_e_.;;rc hczo nzs=d-pcs-cre ncce o-d scu-bed.
Archaeologist monitors until glacialtill is
encountered. Once desired depth is
Disturbed Cultural Humans remains identified in Intact Cultural Materials reached,monitoringwill be complete.
Materials Identified trenches or Feature Identified
•
Implement Notification Procedures Archaeologist conducts
Excavation resumes. in Section 6 of the IDP. Await further sampling.
Archaeologist monitors instructions.
mechanical excavation of
disturbed cultural materials by Once sampling is complete,
Contractor. Disturbed spoils excavation may resume.
will be mechanically removed Remaining cultural deposits will
by Contractor for screening. be mechanically removed by
Contractor for screening.
♦ j I
Archaeologist will conduct screening of cultural materials,either adjacent to trenches or at Screen ing Area.Contractor places spoils for screening as directed by
Archaeologist.Archaeologistwill collect formed tools and will examine faunal materialsto identify potential fragmentary human remains.
Human remains NOT identified a sp Humans remains identified in screen
Implement Notification Procedures In Section 6
of the IDP. Continue screening.
•
Screening is completed.Once desired depth is reached,monitoringwill be complete.
Figure 5. Process for Phase 3a excavation of trenches within 45KP9 site boundaries.
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Beach Survey
In addition to completing monitoring working, WillametteCRA archaeologists will complete
weekly surveys of the beach within site boundaries to recover any artifacts that may be eroding
out. These surveys will be timed for lower tides. Formed tools will be collected and stored
temporarily at the WillametteCRA Seattle laboratory for documentation and analysis. GPS
points will be collected for each artifact; artifacts will be analyzed and curated as described
below. Photographs of the tools will be included in the report.
Communications
A list of contacts will be finalized and distributed by the Project Archaeologist prior to
construction following the pre-construction meeting (see also Appendix B).
Pre-Field Notification
Prior to Phase 3 fieldwork, the WillametteCRA Project Archaeologist will notify Ecology, DAHP
(archaeology and physical anthropology representatives), USACE, and affected Tribes of the
proposed field schedule (see Appendix B for contact information). Representatives of affected
Tribes will be invited to join us for fieldwork and/or contribute information to inform the cultural
resources work. A minimum of 72 hours of advance notice will be provided.
Discovery Notifications
If an intact archaeological feature (such as a hearth, layer of dark soil, or cluster of fire modified
rock) or intact cultural deposits are identified, work will be stopped in this location and the
WillametteCRA Project Archaeologist will notify the City and Ecology Project Managers as
required in Section 3 Step D of the IDP. Ecology will notify DAHP as required in Section 3 Step
E of the IDP. Ecology will notify USACE as required in Section 5 of the IDP. Depending upon
the location of the find, the data recovery or sampling procedures outlined below will be
followed, pursuant to Section 3 Step C of the IDP.
Pursuant to Section 6 of the IDP: If human remains are found or suspected, all work will cease
at this location and the WillametteCRA Principal Investigator will contact the Bremerton Police
(using the non-emergency number) and the Kitsap County Coroner by telephone. The Principal
Investigator will notify the City Project Manager by telephone. Following these telephone
notifications, the Principal Investigator will make a courtesy email notification to Ecology, the
State Physical Anthropologist, the State Archaeologist, and the Consulting Parties. An
archaeologist will stay at the work location to provide information to the Police and Coroner and
to keep members of the public from the area. If the Coroner determines the human remains are
non-forensic, the archaeologist will be available to assist the State Physical Anthropologist as
requested. WillametteCRA will have clean tarps and plywood unit covers to cover the area if
requested.
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Field Updates
The WillametteCRA Principal Investigator will provide a weekly email update to all of the
contacts listed in Appendix B for each week that Phase 3 monitoring is conducted. The update
will summarize the progress and observations. If artifacts are collected, a brief summary of the
nature and extent of the collections will be included. If human remains are identified,
notifications will be made the same day as outlined in Section 6 of the IDP.
Research Questions
If shell midden or other cultural deposits or features are observed during construction
monitoring, work will cease in the area of the discovery. After City and Ecology are notified,
WillametteCRA will begin data recovery or sampling designed to investigate three questions:
1. What meaningful information can be provided to contribute to knowledge about the
people who lived here in the past?
2. What were subsistence practices and environmental conditions at Manette in the past?
3. Do features, if present, represent different times of occupation?
Data Recovery
If intact cultural deposits are identified at a grinder pump location, one 1 x 1-meter test unit (TU)
will be placed at the discretion of the Principal Investigator. The TUs will be excavated by trowel
and flat shovel in 10 cm arbitrary levels within natural stratigraphic levels until we reach 10 cm
below cultural deposits or natural glacial sediments. All sediment will be screened through 1/8-
inch mesh. Faunal material, charcoal, and artifacts will be collected along with 1-to 3-liter bulk
sediment samples for paleobotanical analysis. We will draw and photograph stratigraphic
profiles upon completion of each TU.
If a feature is identified, the feature will be excavated to expose the feature in plan view,
photograph and sketch it, and collect samples (charcoal, sediment), if appropriate. We will
bisect the feature, collecting half of the feature deposit for analysis, and draw and photograph
the profile. WillametteCRA will excavate the remaining half of the feature. If a feature extends
outside of the TU, an adjacent TU (1 x 1-meter or smaller)will be excavated.
Locations of features will be recorded using an R1 Trimble GPS device. Photographs and notes
will be recorded of each arbitrary 10-cm level excavated within natural stratigraphic units. The
bulk sample will be submitted for botanical analysis. If charcoal is collected it will be evaluated
to minimize the potential for "old wood effect" prior to being submitted for dating. We will record
general information about each FMR fragment including material type of the stone (coarse or
fine-grained), maximum dimension of each fragment, and describe breakage pattern. FMR will
not be collected.
confidential—not for general distribution 16
Once TU excavation is complete, the Contractor may resume mechanical excavation at this
location. Remaining cultural deposits will be removed and stockpiled on site for Screening.
Stockpiles from different areas must be separated. The Archaeologist will photograph and
sketch the sidewalls of the completed excavation before the excavation is backfilled.
This process will be followed at each grinder pump location with intact cultural deposits.
Sampling
If intact cultural materials are identified during trenching, Archaeologists will conduct sampling.
Archaeologists will collect samples every 5 meters along the length of the trench where cultural
deposits are exposed. Archaeologists will collect 1-liter bulk samples from every 50 cm of depth,
or at least two samples (one from the top of the deposit and one from the bottom of the deposit).
Samples will be transported by WillametteCRA staff to WillametteCRA's laboratory temporarily.
Archaeologists will log samples with field numbers and photograph sample locations.
If a feature is identified during trenching, WillametteCRA will sample the feature.
• If the feature is fully exposed in the trench, WillametteCRA will document the feature in
plan view, photograph and sketch it, and collect samples (charcoal, sediment), if
appropriate. We will bisect the feature, collecting half of the feature deposit for analysis,
and draw and photograph the profile. WillametteCRA will remove and screen the
remaining half of the feature.
• If the feature extends into the trench sidewalls, WillametteCRA will document the
exposed portion of the feature in plan view, photograph and sketch it, and collect
samples (charcoal, sediment) if appropriate. If it appears that the exposed portion of the
feature represents more than half of the feature, WillametteCRA will bisect the exposed
portion of the feature, collect half of the exposed feature deposit for analysis, and draw
and photograph the profile. WillametteCRA will remove and screen the remaining half of
the feature. If it appears that the exposed portion of the feature represents less than half
of the feature, the entire exposed portion will be collected for analysis. WillametteCRA
will draw and photograph the profile.
Once sampling is complete, the Contractor may resume mechanical excavation. Remaining
cultural deposits will be removed and stockpiled on site for Screening. Stockpiles from different
areas must be separated. The Archaeologist will photograph and sketch the sidewalls of the
completed excavation before the trench is backfilled.
Screening
Stockpiled cultural materials will be screened through %-inch mesh. Stockpiled cultural
materials will include disturbed or intact sediments removed from grinder pump and trench
locations. Archaeologists will collect formed tools and will examine faunal remains to identify
potential fragmentary human remains. If suspected human remains are found in the screen they
confidential—not for general distribution 17
will be collected and an Archaeologist skilled in identification of human remains will evaluate. No
other materials will be collected.
If human remains are identified during screening, the notification procedures in Section 6 of the
IDP will be followed.
The City will provide a dry and secure area for screening activities if screening cannot be
accommodated adjacent to excavation due to site constraints.
Excavated materials will be transported to the screening area and off-loaded by the Contractor
under supervision of the Archaeologist if there is insufficient space at the excavation location.
The screening area will have adequate space to keep stockpiled cultural materials from different
locations separate from each other.
Laboratory and Analysis
Collected artifacts and samples will be temporarily held at WillametteCRA's laboratory. Artifacts
will be cleaned as appropriate and samples will be dried.
Precontact lithic artifacts, shellfish, and historic artifacts will be analyzed at WillametteCRA
Seattle by Amanda Taylor. Vertebrate faunal material will be analyzed by Bob Kopperl.
Paleobotanical analysis will be completed by WillametteCRA ethnobotanist Joyce Mastenbrook
and charcoal identification will be completed by Jennie Shaw (Salix Archaeological Services).
Lithic Analysis
All collected precontact lithic artifacts will be processed in the WillametteCRA laboratory in
Seattle and prepared for curation at an appropriate repository or as determined through
consultation. Stone tools will be analyzed to determine raw material, manufacturing technology
and technique, the types of modification from production and use. These tools will be placed
within functional categories based on attributes that include their morphology, character of flake
scars, breakage, and use wear. Tools will be photographed. All lithic debitage will be subject to
a technological analysis that identifies raw material type and each individual attribute analysis
will be recorded for flakes.
Historic Artifact Analysis
Historic artifacts will be analyzed in the WillametteCRA Seattle lab and documented with
photographs, and function, material type, and temporal ranges when possible. Artifacts will be
analyzed using a modified Sprague functional classification system (Sprague 1980). Artifacts
will be classified to assign each artifact into a primary functional group and two sub-groups.
Items that cannot be definitively assigned to a functional group will be placed in the Indefinite
category. This group often comprises a large portion of an historic assemblage at
archaeological sites due to the difficulty in designating highly fragmentary items to definitive
confidential—not for general distribution 18
functional groups. Date ranges for individual artifacts will be assigned based on material types,
manufacture techniques, and production dates of specific products when possible.
Faunal Analysis
If faunal remains are observed, the assemblage will be identified to the finest taxonomic
category possible in the field, using published shellfish and osteology guides and the expertise
of WillametteCRA staff. Specimens that cannot be confidently assigned to a particular
taxonomic group will be categorized to gross size class using a size gradient (large, medium, or
small mammal). Other information considered will be the segment of the element present, the
side of the element, and the approximate age of the individual (neonate, sub-adult, adult) based
upon epiphyseal fusion and/or tooth eruption. The data will then be quantified using the number
of identified specimens (NISP) and the minimum number of individuals (MNI), when applicable.
All faunal specimens will be inspected for natural and cultural bone surface modifications. The
faunal materials will be examined for carnivore reduction, rodent gnawing, root etching, and
weathering. Burning is categorized as either not burned, burned black, or burned white. Lastly,
all faunal materials will be inspected for the presence of butchery marks.
Radiocarbon Analysis
We estimate that approximately 1 to 2 radiocarbon samples will be taken per 1 cubic meter of
intact shell midden. All charcoal samples will be selected by charcoal analysis specialist Dr.
Jennie Shaw (Salix Archaeological Services) because short-lived hardwoods minimize potential
for "old wood effect" where wood from outer rings of a tree is much older than the date that the
wood burned. Shell can also be used for radiocarbon dating in this context.
Macrobotanical Analysis
If intact cultural deposits are found, we will collect 5-liter bulk samples from each Test Unit for
flotation and macrobotanical analysis. Sediment samples will be processed using mechanical
flotation to disaggregate low-density materials from the sediment matrix. Low density materials
will be dried and passed through 4.0 mm, 2.0 mm, 1.0 mm, .5 mm, and .3 mm sieves. Once
sieved, charred remains will be separated from the low-density portion of the sample using a
dissecting microscope at 10x magnification. Charred macrobotanicals will be quantified and
identified to the lowest taxonomic species possible using 30-50x magnification. Non-botanical
materials pulled from the light fraction will be quantified by count. Assemblage composition will
be assessed by ranking absolute counts of identified taxa and by calculating the ubiquity index,
which measures the percentage of samples in which a taxon appears.
confidential—not for general distribution 19
Curation
Artifacts, samples, and associated records will be prepared for curation at the Suquamish
Museum, in consultation with Affected Tribes. Curation will be consistent with the curation
standards outlined in 36 CFR Part 79.
Reporting
Within 90 days of completion of construction, WillametteCRA will prepare a technical report that
presents the results of the monitoring. If data recovery is conducted, the report will also detail
the results of fieldwork and analysis. The report will be prepared to state and professional
standards and for submittal to Ecology, Consulting Parties, and Tribes. WillametteCRA will also
prepare an updated Washington State Archaeological Site Inventory Form for 45KP9.
WillametteCRA will submit a final report within 14 days of receiving all comments. As part of the
report, WillametteCRA will also present a condensed narrative summary without technical
jargon to describe findings at the site.
References
Gardner, Jessica
2022 Cultural Resources Assessment for the Manette Beach Sewer Upgrades (EB-2 to OF-4)
(Parametrix Project No. 2331896179), Bremerton, Kitsap County, Washington. CRC Report
on File at the Washington State Department of Archaeology and Historic Preservation,
Olympia.
Hudson, Lorelea, Robert Kopper!, Eileen Heideman and Sharon Boswell
2008 Cultural Resources Assessment for the Manette Bridge Replacement Project Kitsap
County, Washington. NWAAIEnvironmental History Company Report Prepared for
Washington State Department of Transportation.
Jermann, Jerry
1983 Archaeological Investigations at the Manette Site 45KP9, Bremerton, Washington.
Office of Public Archaeology Report 42, University of Washington.
Sleight, Ann C.
1972 A Burial Excavated Near Bremerton, A Preliminary Report. The Washington
Archaeologist 16(3).
Snyder, Warren
1952 Archaeological site Inventory Form 45KP9. On File at the Washington State Department
of Archaeology and Historic Preservation, Olympia.
Taylor, Amanda, Paula Johnson, Yonara Carrilho, and F. Scott Pierson
2023 Manette Decommission Beach Sewer from OF-4 to EB-2 Project, 45KP9 Geotechnical
Monitoring and Site Characterization Report. Willamette Cultural Resources Associates, Ltd.
report prepared for City of Bremerton.
confidential—not for general distribution 20
Appendix A: Inadvertent Discovery Plan
5 OAEARsO INADVERTENT DISCOVERY PLAN
"®" PLaNAND PROCEDURES FOR THE DISCOVERY OF
CULTURAL RESOURCES AND HUMAN SKELETAL
��o OLD REMAINS
To request ADA accommodation, including materials in a format for the visually
impaired, call Ecology at 360-407-6000 or visit https://ecology.wa.gov/accessibllity.
People with impaired hearing may call Washington Relay Service at 711. People with a
speech disability may call TTY at 877-8, vv33-63�4�1..
Site Name(s): Manette Beads Sewer Upgrades(E8.2 to OF•4) Location: Bremerton, A
Project Lead/Organization: City of Bremerton County: Kitsap
if this Inadvertent Discovery Plan (/DP) is for multiple (batched) projects, ensure the
location information covers all project areas.
1. INTRODUCTION
The IDP outlines procedures to perform in the event of a discovery of archaeological
materials or human remains, in accordance with applicable state and federal laws. An
IDP is required, as part of Agency Terms and Conditions for all grants and loans, for
any project that creates disturbance above or below the ground. An IDP is not a
substitute fora formal cultural resource review (Executive 21-02 or Section 106).
Once completed, the IDP should always be kept at the project site during all project
activities. All staff, contractors, and volunteers should be familiar with its contents and
know where to find it.
2. CULTURAL RESOURCE DISCOVERIES
A cultural resource discovery could be prehistoric or historic. Examples include (see
images for further examples):
• An accumulation of shell, burned rocks, or other food related materials.
• Bones, intact or in small pieces.
• An area of charcoal or very dark stained soil with artifacts.
• Stone tools or waste flakes (for example, an arrowhead or stone chips).
• Modified or stripped trees, often cedar or aspen, or other modified natural
features, such as rock drawings.
• Agricultural or logging materials that appear older than 50 years. These could
include equipment, fencing, canals, spillways, chutes, derelict sawmills, tools,
and many other items.
• Clusters of tin cans or bottles, or other debris that appear older than 50 years.
• Old munitions casings. Always assume these are live and never touch or
move.
• Buried railroad tracks, decking, foundations, or other industrial materials.
• Remnants of homesteading. These could include bricks, nails, household items,
toys, food containers, and other items associated with homes or farming sites.
ECY 070-560 (rev. 06/21) 1 IDP Form
The above list does not cover every possible cultural resource. When in doubt, assume
the material is a cultural resource.
3. ON-SITE RESPONSIBILITIES
If any employee, contractor, or subcontractor believes that they have uncovered
cultural resources or human remains at any point in the project, take the following steps
to Stop-Protect-Notify. If you suspect that the discovery includes human remains,
also follow Sections 5 and 6.
STEP A: Stop Work.
All work must stop immediately in the vicinity of the discovery.
STEP B: Protect the Discovery.
Leave the discovery and the surrounding area untouched and create a clear,
identifiable, and wide boundary (30 feet or larger) with temporary fencing, flagging,
stakes, or other clear markings. Provide protection and ensure integrity of the discovery
until cleared by the Department of Archaeological and Historical Preservation (DAHP)
or a licensed, professional archaeologist.
Do not permit vehicles, equipment, or unauthorized personnel to traverse the discovery
site. Do not allow work to resume within the boundary until the requirements of this IDP
are met.
STEP C: Notify Project Archaeologist (if applicable).
If the project has an archaeologist, notify that person. If there is a monitoring plan in
place, the archaeologist will follow the outlined procedure.
STEP D: Notify Project and Washington Department of Ecology (Ecology)
contacts.
Project Lead Contacts
Primary Contact Alternate Contact
Name: David Powell Name: William Davis
Organization: City of Bremerton Organization: City of Bremerton
Phone: 360-979-7682 Phone: 360-473-2312
Email: David.Powell@ci.bremerton.wa.us Email: william.davis@ci.bremerton.wa.us
Ecology Contacts (completed by Ecology Project Manager)
Ecology Project Manager Alternate or Cultural Resource Contact
Name: Madison Diaz Name: Liz Ellis
Program: NV\(RO Program: \tfater Quality Program,Clean Water State Revolving
Phone: 425-495-1777 Phone: 360-628-4410
Email: mdia461@ecy.wa.gov I Email: Ile11461@ecy.wa.gov
ECY 070-560 (rev. 06/21) 2 IDP Form
STEP E: Ecology will notify DAHP.
Once notified, the Ecology Cultural Resource Contact or the Ecology Project
Manager will contact DAHP to report and confirm the discovery. To avoid delay, the
Project Lead/Organization will contact DAHP if they are not able to reach Ecology.
DAHP will provide the steps to assist with identification. DAHP, Ecology, and Tribal
representatives may coordinate a site visit following any necessary safety protocols.
DAHP may also inform the Project Lead/Organization and Ecology of additional
steps to further protect the site.
Do not continue work until DAHP has issued an approval for work to proceed in
the area of, or near, the discovery.
DAHP Contacts:
Name: Rob Whitlam, PhD Human Remains/Bones:
Title: State Archaeologist Name: Guy Tasa, PhD
Cell: 360-890-2615 Title: State Anthropologist
Email: Rob.Whitlamadahp.wa.gov Cell: 360-790-1633 (24/7)
Main Office: 360-586-3065 Email: Guy.Tasac dahp.wa.gov
4. TRIBAL CONTACTS
In the event cultural resources are discovered, the following tribes will be contacted.
See Section 10 for Additional Resources.
Tribe: Suquamish Tribe Tribe: Puyallup Tribe
Name: Stephanie Trudel J Name: Jennifer Keating
Title: THPO Title: Assistant THPO
Phone: 360-394-8533 Phone: 253-549-5397
Email: strudel@Suquamish.nsn.us Email: jennifer.m.keating@ puyalluptribe-nsn.gov
Tribe: ] Tribe:
Name: —1 Name:
Title: Title:
Phone: Phone:
Email: Email:
Please provide contact information for additional tribes within your project area, if
needed, in Section 11 .
5. FURTHER CONTACTS (if applicable)
If the discovery is confirmed by DAHP as a cultural or archaeological resource, or as
human remains, and there is a partnering federal or state agency, Ecology or the
Project Lead/Organization will ensure the partnering agency is immediately notified.
ECY 070-560 (rev. 06/21) 3 IDP Form
Federal Agency: State Agency:
Agency: US Army Corps of Engineers Agency: J
Name: Lance Lundquist Name: 7
Title: Cult Res Program Mgr 7 Title:
Phone: 206-764-6909 Phone:
Email: lance.a.lundquist@usace.army.mil Email:
6. SPECIAL PROCEDURES FOR THE DISCOVERY OF HUMAN SKELETAL
MATERIAL
Any human skeletal remains, regardless of antiquity or ethnic origin, will at all times be
treated with dignity and respect. Follow the steps under Stop-Protect-Notify. For specific
instructions on how to handle a human remains discovery, see: RCW 68.50.645: Skeletal
human remains—Duty to notify—Ground disturbing activities—Coroner determination—
Definitions.
Suggestion: If you are unsure whether the discovery is human bone or not, contact Guy
Tasa with DAHP, for identification and next steps. Do not pick up the discovery.
Guy Tasa, PhD State Physical Anthropologist
Guy.Tasaadahp.wa.gov
(360) 790-1633 (Cell/Office)
For discoveries that are confirmed or suspected human remains, follow these steps:
1 . Notify law enforcement and the Medical Examiner/Coroner using the contacts
below. Do not call 911 unless it is the only number available to you.
Enter contact information below (required):
• Local Medical Examiner or Coroner name and phone:
Jeff Wallis, 360-337-7077
• Local Law Enforcement main name and phone:
Bremerton Police, 360-473-5220
• Local Non-Emergency phone number (911 if without a non-emergency
number): 360-473-5220
2. The Medical Examiner/Coroner (with assistance of law enforcement personnel) will
determine if the remains are human or if the discovery site constitutes a crime
scene and will notify DAHP.
3. DO NOT speak with the media, allow photography or disturbance of the
remains, or release any information about the discovery on social media.
4. If the remains are determined to be non-forensic, Cover the remains with a tarp or
other materials (not soil or rocks) for temporary protection and to shield them from
being photographed by others or disturbed.
ECY 070-560 (rev. 06/21) 4 IDP Form
Further activities:
• Per RCW 27.44.055, RCW 68.50, and RCW 68.60, DAHP will have jurisdiction
over non-forensic human remains. Ecology staff will participate in consultation.
Organizations may also participate in consultation.
• Documentation of human skeletal remains and funerary objects will be agreed
upon through the consultation process described in RCW 27.44.055,
RCW 68.50, and RCW 68.60.
• When consultation and documentation activities are complete, work in the
discovery area may resume as described in Section 8.
If the project occurs on federal lands (such as a national forest or park or a military
reservation) the provisions of the Native American Graves Protection and Repatriation
Act of 1990 (NAGPRA) apply and the responsible federal agency will follow its
provisions. Note that state highways that cross federal lands are on an easement and
are not owned by the state.
If the project occurs on non-federal lands, the Project Lead/Organization will comply
with applicable state and federal laws, and the above protocol.
7. DOCUMENTATION OF ARCHAEOLOGICAL MATERIALS
Archaeological resources discovered during construction are protected by state law
RCW 27.53 and assumed eligible for inclusion in the National Register of Historic
Places under Criterion D until a formal Determination of Eligibility is made.
The Project Lead/Organization must ensure that proper documentation and field
assessment are made of all discovered cultural resources in cooperation with all
parties: the federal agencies (if any), DAHP, Ecology, affected tribes, and the
archaeologist.
The archaeologist will record all prehistoric and historic cultural material discovered
during project construction on a standard DAHP archaeological site or isolate
inventory form. They will photograph site overviews, features, and artifacts and
prepare stratigraphic profiles and soil/sediment descriptions for minimal subsurface
exposures. They will document discovery locations on scaled site plans and site
location maps.
Cultural features, horizons, and artifacts detected in buried sediments may require the
archaeologist to conduct further evaluation using hand-dug test units. They will
excavate units in a controlled fashion to expose features, collect samples from
undisturbed contexts, or to interpret complex stratigraphy. They may also use a test
unit or trench excavation to determine if an intact occupation surface is present. They
will only use test units when necessary to gather information on the nature, extent, and
integrity of subsurface cultural deposits to evaluate the site's significance. They will
conduct excavations using standard archaeological techniques to precisely document
the location of cultural deposits, artifacts, and features.
The archaeologist will record spatial information, depth of excavation levels, natural
and cultural stratigraphy, presence or absence of cultural material, and depth to sterile
soil, regolith, or bedrock for each unit on a standard form. They will complete test
excavation unit level forms, which will include plan maps for each excavation level and
artifact counts and material types, number, and vertical provenience (depth below
ECY 070-560 (rev. 06/21) 5 IDP Form
surface and stratum association where applicable) for all recovered artifacts. They will
draw a stratigraphic profile for at least one wall of each test excavation unit.
The archaeologist will screen sediments excavated for purposes of cultural resources
investigation through 1/8-inch mesh, unless soil conditions warrant 1/4-inch mesh.
The archaeologist will analyze, catalogue, and temporarily curate all prehistoric and
historic artifacts collected from the surface and from probes and excavation units. The
ultimate disposition of cultural materials will be determined in consultation with the
federal agencies (if any), DAHP, Ecology, and the affected tribe(s).
Within 90 days of concluding fieldwork, the archaeologist will provide a technical report
describing any and all monitoring and resultant archaeological excavations to the
Project Lead/Organization, who will forward the report to Ecology, the federal agencies
(if any), DAHP, and the affected tribe(s) for review and comment.
If assessment activities expose human remains (burials, isolated teeth, or bones), the
archaeologist and Project Lead/Organization will follow the process described in
Section 6.
8. PROCEEDING WITH WORK
The Project Lead/Organization shall work with the archaeologist, DAHP, and
affected tribe(s) to determine the appropriate discovery boundary and where work can
continue.
Work may continue at the discovery location only after the process outlined in this plan
is followed and the Project Lead/Organization, DAHP, any affected tribe(s), Ecology,
and the federal agencies (if any) determine that compliance with state and federal laws
is complete.
9. ORGANIZATION RESPONSIBILITY
The Project Lead/Organization is responsible for ensuring:
• This IDP has complete and accurate information.
• This IDP is immediately available to all field staff at the sites and available by
request to any party.
• This IDP is implemented to address any discovery at the site.
• That all field staff, contractors, and volunteers are instructed on how to implement
this IDP.
10. ADDITIONAL RESOURCES
Informative Video
Ecology recommends that all project staff, contractors, and volunteers view this
informative video explaining the value of IDP protocol and what to do in the event of a
discovery. The target audience is anyone working on the project who could
unexpectedly find cultural resources or human remains while excavating or digging.
The video is also posted on DAHP's inadvertent discovery language website.
Ecology's IDP Video (https://www.youtube.com/watch?v=ioX-4cXfbDY)
ECY 070-560 (rev. 06/21) 6 IDP Form
Informational Resources
DAHP (https://dahp.wa.gov)
Washington State Archeology (DAHP 2003)
(https://dahp.wa.govisites/default/files/Field%20Guide%20to%20WA%20Arch 0.pdf)
Association of Washington Archaeologists (https://www.archaeologyinwashington.com)
Potentially Interested Tribes
Interactive Map of Tribes by Area
(https://dahp.wa.gov/archaeology/tribal-consultation-information)
WSDOT Tribal Contact Website
(https://wsdot.wa.gov/tribal/TribalContacts.htm)
11. ADDITIONAL INFORMATION
Please add any additional contact information or other information needed within this
IDP.
Contact Project Archaeologist if you need assistance identifying a possible cultural
resource:
Paula Johnson
WillametteCRA
206-706-1659
paula@willamettecra.com
If you cannot reach Paula contact:
Amanda Taylor
WillametteCRA
206-214-8506
amanda@willamettecra.com
ECY 070-560 (rev. 06/21) 7 IDP Form
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ECY 070-560 (rev. 06/21) 8 IDP Form
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ECY 070-560 (rev. 06/21) 9 IDP Form
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ECY 070-560 (rev. 06/21) 10 IDP Form
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j , r.
;, ,, ir- (Courtesy of DRHP). ,� - =4
1l'i illr' v Right, Top to Bottom: Artifacts from ''"'`' ..;
r� �`�, �, 4' " " Mud Bay, Olympia: Toy war club, two ` . - . :i
' strand cedar roe wet basketry. s i'
p rY
:. „t, 1 ..1 t i .,..;11*, ,' 't, . ti - _ , rF4.
r.
J I 4
i,
b .,..; 0.11:i. NilIllk\ Sil,;7:,.1:,..
Of
! i 1,1161.*** ' %4 ' b - _
•s 114 , i I j 0 1kt. -TV, .. , . _ -err'
I i Lit 1 11:' ' 7
i 1 1 , VI*gt -- . '
:. - .
� 4,.
i f t tea.
r ! k . ` �' y 1 i u Yl 1 r t
r ► f f I, ; . • .!t, +yam++_ ie,� • • ` _ •• q�� _, ,."
‘. .r rt .4 21 t4 f - I_ ' - :1- ..-4-,--_-if • ,o§ •-,,,, l'', . ,f7o-, ' -4,%.*
1K f. 1 • _, ,joci ,
ir.,,-•l . ' .' - - . z.41 y
Y '. , h Y. 'Sri,k / #.
ECY 070-560 (rev. 06/21) 11 I DP Form
4-,3.�/b'i T��ia-F ir 3}4 i, i,e- t''-'.!,i,'.:::'W
Implement the IDP if you see... ,y} ; ,��(•��< • '6- ,: , �'
Strange, different, or interesting looking dirt, rocks, or shells. :' _...r, ;;; , � ,�:, „ , .•4.
Human activities leave traces in the ground that may or may not �� .
a5 �`ry�cy � .� ✓.u3x 3F% ,
.„A - F .7 S " i.J yykV `V .f � .- "rla
have artifacts associated with them. Examples are: f _ h � .� ^; p5,
• ``Unusual" accumulations of rock (especially fire-cracked rock). .'4 ;' 5 „, ,,; jt4
• "Unusual" shaped accumulations of rock (such as a shape �" J r
similar to a fire ring). �.. f
• Charcoal or charcoal-stained soils, burnt-looking soils, or soil ,, r 't4.
that has a "layer cake" appearance. 4d 4
• Accumulations of shell, bones, or artifacts. Shells may be .-%i-, 4,:•q,, t, �r .
crushed. - :► . -, ;.• 4
• Look for the "unusual" or out of place (for example, rock piles Shell Midden pocket in modern fill discovered in
in areas with otherwise few rocks). sewer trench.
0
* 95.vc25F !�c
!II Shell midden with fire cracked rock. -- = - N-'y
.ar 4164taiAbil Pi 17-4.''',t'Lk.-tirr'32*!:* , ':14':' , , ". . -,-%- ''.-4.
4111011b0
0__ i t, . 1 , .,,, ,, , . - _ . 1 lib imair lk, H
•. A%Anakidris joi
;51�yt _ -,
EI. _- ! `, y' r �,a/ max
Underground oven. Courtesy of ,DAHP. - �� .�
Hearth excavated near Hamilton, WA.
ECY 070-560 (rev. 06/21) 12 IDP Form
Implement the IDP if you see...
Historic period artifacts (historic archaeology considered
older than 50 years).
Examples are:
i#41r, 1i. "*.• Agricultural or logging equipment. May include equipment, fencing, L � �
canals, spillways, chutes, derelict sawmills, tools, etc. II .r �i ,. .
• Domestic items including square or wire nails, amethyst colored glass, ,-
or painted stoneware.
Left: Top to Bottom: Willow pattern
serving bowl and slip joint pocket ,.
knife discovered during Seattle
4 Smith Cove shantytown (45- 2do'•, , ,.. °. _
KI-1200) excavation. , ~:
Right: Collections of historic r t . r -: '"y
t, r artifacts discovered during '� ' , ° .4;'r 4z
excavations in eastern -
fsi
'T GS M�..
Washington cities. - 1
.. , .,,,_ ,
„.„
, ,
lip. .. ._ . ,... ,,,, ,�s ya4-
-,-r r y xy. f .4" "ski] s
ECY 070-560 (rev. 06/21) 13 IDP Form
MINA ION
Implement the IDP if you see...
Historic period artifacts (historic archaeology considered
older than 50 years).
Examples are:
• Railway tokens, coins, and buttons.
• Spectacles, toys, clothing, and personal items.
• Items helping to understand a culture or identity.
• Food containers and dishware.
/--- Right, from Top to Bottom:
l II '� "_
Coins, token, spectacles
T I �, _ and Montgomery Ward
'�' 'ai"'�.,� = ' <ti`=_ • '' pitchfork toy discovered
, ', 4 , `. � - r ',/, v. �_ .,,, . yam :;
' during Seattle Smith Cove
k shantytown(45-K1-1200)
_ excavation.
i c 4, k -
..a,„ .... .
1'4- . .,zi\
4 ,,:,,--,,Z-tfi-,-- .,- -ci.,, ,w, .-f:.,4-- .-.= ':-''Ir; ,.-' • It'
/ e-,. -- - .,
A .. 1 , K{. !r f r t: 4
.,( A-'1., _ ,.,� -
iiimimmmomEN-1 ..
.E` F.
:Ali- our
I. '` 4��:�� iK �`I*10.
Main Image: Dishes, bottles, workboot found at the North Shore Japanese bath
house (ofuro) site, Courtesy Bob Muckle, Archaeologist, Capilano University,
B.C. This is an example of an above ground resource.
ECY 070-560 (rev. 06/21) 14 IDP Form
Implement the IDP if you see...
• Old munition casings — if you see ammunition of any type —always assume they are live and never touch or move!
• Tin cans or glass bottles with an older manufacturer's technique — maker's mark, distinct colors such as turquoise, or
an older method of opening the container.
Al •�4 Far Left: .303 British ' r/
ily i ' -. "_ ? cartridge found by a WCC
M �. . a planting crew on Skagit
1\ . , -,. -46:‘ , A River. Don't ever touch
k-ir
Mf M something like this!
• +. `i Left: Maker's mark on
. - 4 G bottom of old bottle. ``
1
611 ill ! - .1krt' iii-
li\ t = }' Right: Old beer can found ` •t ' �
j in Oregon. ACME was �.
1 owned by Olympia �`� .: _- }
e §' Brewery. Courtesy of
•r Heather Simmons. lilt i
-` .
't'4. •.,j h .1 ' ` ,s,ti{ 1934-1963+ 1962-1965 1965-1975
ti P.R. _
"",4t - '-,- - it. ,.._.0.i..V..z.-7,:: ..-,
_4,,.
,.
• iY,.4.0._:_ %I„
- Logo employed by Whithall
Tatum & Co. between 1924 to
1938 (Lockhart et al. 2016). Can opening dates, courtesy of W.M. Schroeder.
ECY 070-560 (rev. 06/21) 15 IDP Form
Implement the IDP if you see... : - ' iii.„
You see historic foundations or buried structures.
i • -•_ J.�or . ,- STRATUM IiII
Examples are: 1 _ , --
• Foundations. - - - -.'� �:,- -rsTRATUM I
• Railroad and trolley tracks. '
,. ,-.:- • , fry ti� : STRATUM Y —_,
• Remnants of structures. f- .,, ++ r� . .y _tsgp,. ,F • t
�' �l'. _1 .-_ ,�-� ST-RATUM V1
r. t* �T _ fit` . . r
4,, A 1 , A.*:!.••..
'.441P81111i0ep
•y Snl vEl' .� y
A % -
1rir:Ir
! � 1
118...=Iiiiii.ign . . ., h.hur
- -.: ..._:- .y-.., - -._ --
•
_ _
7-.„. !..._ ___ _
— -41r---: , ' 4 _
. ..
,. '-- �: Counter Clockwise, Left to Right: Historic structure 45KI924, in WSDOT right of way for
j' - V SR99 tunnel. Remnants of Smith Cove shantytown (45-KI-1200) discovered during
•
- _ - _ Ecology CSO excavation, City of Spokane historic trolley tracks uncovered during
_ - _ '- stormwater project, intact foundation of historic home that survived the Great Ellensburg
'„ = -51' -% Fire of July 4, 1889, uncovered beneath parking lot in Ellensburg.
ECY 070-560 (rev. 06/21) 16 IDP Form
1
Implement the IDP if you see... 1 - _ ,
E
Potential human remains. ' --- _ e-it•.
Examples are: �•' :t . - ." ,
• Grave headstones that appear to be older than 50 years.
• Bones or bone tools--intact or in small pieces. It can be difficult to ' --
differentiate animal from human so they must be identified by an �: ' i _ _
expert. /, — , r
• These are all examples of animal bones and are not human. ti , '
Center: Bone wedge tool, --_,__ ' s
courtesy of Smith Cove —
Shantytown excavation , , t ' , , -
(45K19200). . i 4 /11 l •
,,' F
Other images(Top Right,
Bottom Left, and Bottom) 14; "'"";.,,j :. • ` r .,•_,,.....
Center: Courtesy of DAHP, s" ir `� ►y "� �`;,
IIIIIII nuiiI * , x'``
c
fi r r N.
Iiii
` {. "°\ _ �►i _ -r+ # -tom _ . ._-.
fir ' ., �_l '� .r • ` - • 7 114 's,
ik:
. . .
..Ap ----7,,,_., ., . - ,- ! ,
,,.... . .
„,.\
,_- �[.+ .J Directly Above: This is a real discovery at an
.i.; f ,,
_ ,
' Ecology sewer project site.
_ ,
r, +�'�y What would you do if you found these items at
' ,a. a site? Who would be the first person you
c; x + r would call?
,� '. ` ter
Hint: Read the plan!
ECY 070-560 (rev. 06/21) 17 IDP Form
Appendix B: Contact List
TribelAgencyl Contact Name Email Address Phone Number
Organization
David Powell, Project 360-473-5268
David.powell@ci.bremerton.wa.us
Manager 360 979 7682 (cell)
City of Bremerton
William Davis, William.davis@ci.bremerton.wa.us 360-473-2312
Managing Engineer
Parametrix Joel Linke jlinke@parametrix.com 253-604-6638
Washington State
Department of Ecology Liz Ellis Le11461 @ecy.wa.gov 360-628-4410
Cultural Resources
Specialist
Washington State
Department of Ecology Madison Diaz mdia461@ecy.wa.gov 425-495-1777
Project Manager
Willamette Cultural
Resources Associates, Ltd. Paula Johnson paula@willamettecra.com (206)706-1659
(Project Archaeologist)
Willamette Cultural
Resources Associates, Ltd. Dr. Amanda Taylor amanda@willamettecra.com (206)214-8506
(Principal Investigator)
DAHP State Archaeologist Dr. Rob Whitlam Rob.whitlam@dahp.wa.gov (360)890-2615
DAHP State Physical Dr. Guy Tasa Guy.Tasa@dahp.wa.gov (360) 790-1633
Anthropologist
Bremerton Police Non-emergency contact - 360-473-5220
Kitsap County Coroner Jeff Wallis - 360-337-7077
US Army Corps of Lance Lundquist Lance.lundquist@usace.army.mil (206)764-6909
Engineers
Stephanie Trudel,
Suquamish Tribe THPO strudel@suquamish.nsn.us 360-394-8533
Puyallup Tribe Jennifer Keating, Asst. Jennifer.m.keating@puyalluptribe- (253)549-5397
THPO nsn.gov
5 OAEARsO INADVERTENT DISCOVERY PLAN
"®" PLaNAND PROCEDURES FOR THE DISCOVERY OF
CULTURAL RESOURCES AND HUMAN SKELETAL
��o OLD REMAINS
To request ADA accommodation, including materials in a format for the visually
impaired, call Ecology at 360-407-6000 or visit https://ecology.wa.gov/accessibllity.
People with impaired hearing may call Washington Relay Service at 711. People with a
speech disability may call TTY at 877-8, vv33-63�4�1..
Site Name(s): Manette Beads Sewer Upgrades(E8.2 to OF•4) Location: Bremerton, A
Project Lead/Organization: City of Bremerton County: Kitsap
if this Inadvertent Discovery Plan (/DP) is for multiple (batched) projects, ensure the
location information covers all project areas.
1. INTRODUCTION
The IDP outlines procedures to perform in the event of a discovery of archaeological
materials or human remains, in accordance with applicable state and federal laws. An
IDP is required, as part of Agency Terms and Conditions for all grants and loans, for
any project that creates disturbance above or below the ground. An IDP is not a
substitute fora formal cultural resource review (Executive 21-02 or Section 106).
Once completed, the IDP should always be kept at the project site during all project
activities. All staff, contractors, and volunteers should be familiar with its contents and
know where to find it.
2. CULTURAL RESOURCE DISCOVERIES
A cultural resource discovery could be prehistoric or historic. Examples include (see
images for further examples):
• An accumulation of shell, burned rocks, or other food related materials.
• Bones, intact or in small pieces.
• An area of charcoal or very dark stained soil with artifacts.
• Stone tools or waste flakes (for example, an arrowhead or stone chips).
• Modified or stripped trees, often cedar or aspen, or other modified natural
features, such as rock drawings.
• Agricultural or logging materials that appear older than 50 years. These could
include equipment, fencing, canals, spillways, chutes, derelict sawmills, tools,
and many other items.
• Clusters of tin cans or bottles, or other debris that appear older than 50 years.
• Old munitions casings. Always assume these are live and never touch or
move.
• Buried railroad tracks, decking, foundations, or other industrial materials.
• Remnants of homesteading. These could include bricks, nails, household items,
toys, food containers, and other items associated with homes or farming sites.
ECY 070-560 (rev. 06/21) 1 IDP Form
The above list does not cover every possible cultural resource. When in doubt, assume
the material is a cultural resource.
3. ON-SITE RESPONSIBILITIES
If any employee, contractor, or subcontractor believes that they have uncovered
cultural resources or human remains at any point in the project, take the following steps
to Stop-Protect-Notify. If you suspect that the discovery includes human remains,
also follow Sections 5 and 6.
STEP A: Stop Work.
All work must stop immediately in the vicinity of the discovery.
STEP B: Protect the Discovery.
Leave the discovery and the surrounding area untouched and create a clear,
identifiable, and wide boundary (30 feet or larger) with temporary fencing, flagging,
stakes, or other clear markings. Provide protection and ensure integrity of the discovery
until cleared by the Department of Archaeological and Historical Preservation (DAHP)
or a licensed, professional archaeologist.
Do not permit vehicles, equipment, or unauthorized personnel to traverse the discovery
site. Do not allow work to resume within the boundary until the requirements of this IDP
are met.
STEP C: Notify Project Archaeologist (if applicable).
If the project has an archaeologist, notify that person. If there is a monitoring plan in
place, the archaeologist will follow the outlined procedure.
STEP D: Notify Project and Washington Department of Ecology (Ecology)
contacts.
Project Lead Contacts
Primary Contact Alternate Contact
Name: David Powell Name: William Davis
Organization: City of Bremerton Organization: City of Bremerton
Phone: 360-979-7682 Phone: 360-473-2312
Email: David.Powell@ci.bremerton.wa.us Email: william.davis@ci.bremerton.wa.us
Ecology Contacts (completed by Ecology Project Manager)
Ecology Project Manager Alternate or Cultural Resource Contact
Name: Madison Diaz Name: Liz Ellis
Program: NV\(RO Program: \tfater Quality Program,Clean Water State Revolving
Phone: 425-495-1777 Phone: 360-628-4410
Email: mdia461@ecy.wa.gov I Email: Ile11461@ecy.wa.gov
ECY 070-560 (rev. 06/21) 2 IDP Form
STEP E: Ecology will notify DAHP.
Once notified, the Ecology Cultural Resource Contact or the Ecology Project
Manager will contact DAHP to report and confirm the discovery. To avoid delay, the
Project Lead/Organization will contact DAHP if they are not able to reach Ecology.
DAHP will provide the steps to assist with identification. DAHP, Ecology, and Tribal
representatives may coordinate a site visit following any necessary safety protocols.
DAHP may also inform the Project Lead/Organization and Ecology of additional
steps to further protect the site.
Do not continue work until DAHP has issued an approval for work to proceed in
the area of, or near, the discovery.
DAHP Contacts:
Name: Rob Whitlam, PhD Human Remains/Bones:
Title: State Archaeologist Name: Guy Tasa, PhD
Cell: 360-890-2615 Title: State Anthropologist
Email: Rob.Whitlamadahp.wa.gov Cell: 360-790-1633 (24/7)
Main Office: 360-586-3065 Email: Guy.Tasac dahp.wa.gov
4. TRIBAL CONTACTS
In the event cultural resources are discovered, the following tribes will be contacted.
See Section 10 for Additional Resources.
Tribe: Suquamish Tribe Tribe: Puyallup Tribe
Name: Stephanie Trudel J Name: Jennifer Keating
Title: THPO Title: Assistant THPO
Phone: 360-394-8533 Phone: 253-549-5397
Email: strudel@Suquamish.nsn.us Email: jennifer.m.keating@ puyalluptribe-nsn.gov
Tribe: ] Tribe:
Name: —1 Name:
Title: Title:
Phone: Phone:
Email: Email:
Please provide contact information for additional tribes within your project area, if
needed, in Section 11 .
5. FURTHER CONTACTS (if applicable)
If the discovery is confirmed by DAHP as a cultural or archaeological resource, or as
human remains, and there is a partnering federal or state agency, Ecology or the
Project Lead/Organization will ensure the partnering agency is immediately notified.
ECY 070-560 (rev. 06/21) 3 IDP Form
Federal Agency: State Agency:
Agency: US Army Corps of Engineers Agency: J
Name: Lance Lundquist Name: 7
Title: Cult Res Program Mgr 7 Title:
Phone: 206-764-6909 Phone:
Email: lance.a.lundquist@usace.army.mil Email:
6. SPECIAL PROCEDURES FOR THE DISCOVERY OF HUMAN SKELETAL
MATERIAL
Any human skeletal remains, regardless of antiquity or ethnic origin, will at all times be
treated with dignity and respect. Follow the steps under Stop-Protect-Notify. For specific
instructions on how to handle a human remains discovery, see: RCW 68.50.645: Skeletal
human remains—Duty to notify—Ground disturbing activities—Coroner determination—
Definitions.
Suggestion: If you are unsure whether the discovery is human bone or not, contact Guy
Tasa with DAHP, for identification and next steps. Do not pick up the discovery.
Guy Tasa, PhD State Physical Anthropologist
Guy.Tasaadahp.wa.gov
(360) 790-1633 (Cell/Office)
For discoveries that are confirmed or suspected human remains, follow these steps:
1 . Notify law enforcement and the Medical Examiner/Coroner using the contacts
below. Do not call 911 unless it is the only number available to you.
Enter contact information below (required):
• Local Medical Examiner or Coroner name and phone:
Jeff Wallis, 360-337-7077
• Local Law Enforcement main name and phone:
Bremerton Police, 360-473-5220
• Local Non-Emergency phone number (911 if without a non-emergency
number): 360-473-5220
2. The Medical Examiner/Coroner (with assistance of law enforcement personnel) will
determine if the remains are human or if the discovery site constitutes a crime
scene and will notify DAHP.
3. DO NOT speak with the media, allow photography or disturbance of the
remains, or release any information about the discovery on social media.
4. If the remains are determined to be non-forensic, Cover the remains with a tarp or
other materials (not soil or rocks) for temporary protection and to shield them from
being photographed by others or disturbed.
ECY 070-560 (rev. 06/21) 4 IDP Form
Further activities:
• Per RCW 27.44.055, RCW 68.50, and RCW 68.60, DAHP will have jurisdiction
over non-forensic human remains. Ecology staff will participate in consultation.
Organizations may also participate in consultation.
• Documentation of human skeletal remains and funerary objects will be agreed
upon through the consultation process described in RCW 27.44.055,
RCW 68.50, and RCW 68.60.
• When consultation and documentation activities are complete, work in the
discovery area may resume as described in Section 8.
If the project occurs on federal lands (such as a national forest or park or a military
reservation) the provisions of the Native American Graves Protection and Repatriation
Act of 1990 (NAGPRA) apply and the responsible federal agency will follow its
provisions. Note that state highways that cross federal lands are on an easement and
are not owned by the state.
If the project occurs on non-federal lands, the Project Lead/Organization will comply
with applicable state and federal laws, and the above protocol.
7. DOCUMENTATION OF ARCHAEOLOGICAL MATERIALS
Archaeological resources discovered during construction are protected by state law
RCW 27.53 and assumed eligible for inclusion in the National Register of Historic
Places under Criterion D until a formal Determination of Eligibility is made.
The Project Lead/Organization must ensure that proper documentation and field
assessment are made of all discovered cultural resources in cooperation with all
parties: the federal agencies (if any), DAHP, Ecology, affected tribes, and the
archaeologist.
The archaeologist will record all prehistoric and historic cultural material discovered
during project construction on a standard DAHP archaeological site or isolate
inventory form. They will photograph site overviews, features, and artifacts and
prepare stratigraphic profiles and soil/sediment descriptions for minimal subsurface
exposures. They will document discovery locations on scaled site plans and site
location maps.
Cultural features, horizons, and artifacts detected in buried sediments may require the
archaeologist to conduct further evaluation using hand-dug test units. They will
excavate units in a controlled fashion to expose features, collect samples from
undisturbed contexts, or to interpret complex stratigraphy. They may also use a test
unit or trench excavation to determine if an intact occupation surface is present. They
will only use test units when necessary to gather information on the nature, extent, and
integrity of subsurface cultural deposits to evaluate the site's significance. They will
conduct excavations using standard archaeological techniques to precisely document
the location of cultural deposits, artifacts, and features.
The archaeologist will record spatial information, depth of excavation levels, natural
and cultural stratigraphy, presence or absence of cultural material, and depth to sterile
soil, regolith, or bedrock for each unit on a standard form. They will complete test
excavation unit level forms, which will include plan maps for each excavation level and
artifact counts and material types, number, and vertical provenience (depth below
ECY 070-560 (rev. 06/21) 5 IDP Form
surface and stratum association where applicable) for all recovered artifacts. They will
draw a stratigraphic profile for at least one wall of each test excavation unit.
The archaeologist will screen sediments excavated for purposes of cultural resources
investigation through 1/8-inch mesh, unless soil conditions warrant 1/4-inch mesh.
The archaeologist will analyze, catalogue, and temporarily curate all prehistoric and
historic artifacts collected from the surface and from probes and excavation units. The
ultimate disposition of cultural materials will be determined in consultation with the
federal agencies (if any), DAHP, Ecology, and the affected tribe(s).
Within 90 days of concluding fieldwork, the archaeologist will provide a technical report
describing any and all monitoring and resultant archaeological excavations to the
Project Lead/Organization, who will forward the report to Ecology, the federal agencies
(if any), DAHP, and the affected tribe(s) for review and comment.
If assessment activities expose human remains (burials, isolated teeth, or bones), the
archaeologist and Project Lead/Organization will follow the process described in
Section 6.
8. PROCEEDING WITH WORK
The Project Lead/Organization shall work with the archaeologist, DAHP, and
affected tribe(s) to determine the appropriate discovery boundary and where work can
continue.
Work may continue at the discovery location only after the process outlined in this plan
is followed and the Project Lead/Organization, DAHP, any affected tribe(s), Ecology,
and the federal agencies (if any) determine that compliance with state and federal laws
is complete.
9. ORGANIZATION RESPONSIBILITY
The Project Lead/Organization is responsible for ensuring:
• This IDP has complete and accurate information.
• This IDP is immediately available to all field staff at the sites and available by
request to any party.
• This IDP is implemented to address any discovery at the site.
• That all field staff, contractors, and volunteers are instructed on how to implement
this IDP.
10. ADDITIONAL RESOURCES
Informative Video
Ecology recommends that all project staff, contractors, and volunteers view this
informative video explaining the value of IDP protocol and what to do in the event of a
discovery. The target audience is anyone working on the project who could
unexpectedly find cultural resources or human remains while excavating or digging.
The video is also posted on DAHP's inadvertent discovery language website.
Ecology's IDP Video (https://www.youtube.com/watch?v=ioX-4cXfbDY)
ECY 070-560 (rev. 06/21) 6 IDP Form
Informational Resources
DAHP (https://dahp.wa.gov)
Washington State Archeology (DAHP 2003)
(https://dahp.wa.govisites/default/files/Field%20Guide%20to%20WA%20Arch 0.pdf)
Association of Washington Archaeologists (https://www.archaeologyinwashington.com)
Potentially Interested Tribes
Interactive Map of Tribes by Area
(https://dahp.wa.gov/archaeology/tribal-consultation-information)
WSDOT Tribal Contact Website
(https://wsdot.wa.gov/tribal/TribalContacts.htm)
11. ADDITIONAL INFORMATION
Please add any additional contact information or other information needed within this
IDP.
Contact Project Archaeologist if you need assistance identifying a possible cultural
resource:
Paula Johnson
WillametteCRA
206-706-1659
paula@willamettecra.com
If you cannot reach Paula contact:
Amanda Taylor
WillametteCRA
206-214-8506
amanda@willamettecra.com
ECY 070-560 (rev. 06/21) 7 IDP Form
Implement the IDP if you see... ;' «.
Chipped stone artifacts. _ , -145
GAT , ..1.
it i .. ..
Examples are: _ :. -�E
• Glass-like material.
• Angular material. i
• "Unusual" material or shape for the area. -
. Regularity of flaking.
. Variability of size. —
Stone artifacts from Oregon.
__., -is.- _,',,'"7:cl;,'_.-- f... 911110:;,,,,,:arAritr: 111111re
+�` �~ ,' � 4 J� u ` is ,5 i-Y -
ti to
I if -A:� ��
4.
.t +- Ji
t S
, _ :.._ - . A , , _ 'I .11110thii ...„ . ''''';Viadbi_ .' . .. Aim" i/ d
„ \ \ * '"".4 r F Id :Nit\ . , 1, , ,
Stone artifacts from Washington. •�-A •. . + '' — }'1
Biface-knife, scraper, or pre-form found in NE Washington. Thought to be a well
knapped object of great antiquity" Courtesy of Methow Salmon Rea Foundation"
ECY 070-560 (rev. 06/21) 8 IDP Form
Implement the IDP if you see...
Ground stone artifacts.
•
Examples are: ,-'
• Unusual or unnatural shapes or unusual stone. .
▪ Striations or scratching.
• Etching, perforations, or pecking. '_
• Regularity in modifications.
. Variability of size, function, or complexity.
Above: Fishing Weight- credit CRITFC Treaty Fishing Rights website.
. i�.�----* .,
-1: - '--- '.. • . gall,
-
M
11111
1111
, vidll
iiii)
Artifacts from unknown locations (left and right images). . ,*
ECY 070-560 (rev. 06/21) 9 IDP Form
Implement the IDP if you see...
Bone or shell artifacts, tools, or beads. :,1,7 el,. 1. ,
Examples are: ; 1
• Smooth or carved materials. ,- •
4
• Unusual shape. MINI
. Pointed as if used as a tool. -
. Wedge shaped like a "shoehorn". - 7 _ .
• Variability of size. 1 I j • ' ''
la
. Beads from shell (-'- `-'' ' or tusk. AC.-. _ r:if 1 i �y
0,11',71: , 10/
Illi
_ I{1. '
. 7' •• ..4
a ifs as ,' ,.,filt 1 11 . I: lieVt, i
Y41•;rr,'... -•.'!r-.:,t'•��!t'• rli\--`•_:-ai•.�.`• 4•.+t i�/d a •/iia�4..•/ i#..
aal:.til: .ai:rr.i.:a'•:,./lY+f/•. I$(I,�� .rf.. r \�: / `A:•.ter 4
Upper Left:Bone Awls from Oregon. - ,a•,:.;t.,,a;,.4ti',:.r:.h,r . •.•rr;;a'':::Z.s. ' %;';�.a:•r,,
�\.::/... ,E.,as':•9,.. .;I4 4 1,J. !4'.:4%\ .//1.ra
Upper Center: Bone Wedge from California. - • '.,F-rye 4. .4 . •I;,•;a;` . ;:
Upper Right: Plateau dentalium choker and bracelet, from Nez `..„ / j ,,..:
Perce National Historical Park, 19th century, made using Antalis . : a ,
pretiosa shells Credit. Nez Perce- Nez Perce National Historical - '• .0 'F{ " �''' r{f ,•
Park NEPE 8762, Public Domain. = +`::; :::;r,. ' •:,,' :tii:{' a,',; '..,f,—, .. ,''':
• :\`':• ...r•..4a`':.'r* :'r♦I.4 h'.'a �.'THi aka 1 '``/
ah Ia•. y y ,- Iy
Above: Tooth Pendants. Right. Bone Pendants. Both from Oregon ;,,,.,. .,.•;r/;;„•,.,! , "•.'+*,;,r•�'r• ;q::.*.% ' �irr•:
j _ ,,w0 01.:i rr:,`001.1.1•i I ,.lr 14,....y0.1 I Ia.' .,. f 4.\\•..Jlr'.
and Washington. r ;,�...,u ..'. :,,-.�.a•,:,.... C�•..P1•a 6.4.; r,, - r...r..4a*",,,.•,
�+- ,,,.'�/.:."�''r:::\.•::r..�f \h•'r/�asi• �a.:,.01f{ 1,.,I,/i i.\\a•�.i.f/.
•
ECY 070-560 (rev. 06/21) 10 IDP Form
Implement the IDP if you see... .•,',- '#.;« 71
Culturally modified trees, fiber, or wood artifacts. ; %�'► • _ u •:�
Examples are: '' a..y #1 as 4 Al `'id
__
• Trees with bark stripped or peeled, carvings, axe cuts, de-limbing, y
wood removal, and other human modifications. x- - 4
• Fiber or wood artifacts in a wet environment. • ) 101,
• Variability of size, function, and complexity. . . . . ,.'' .' _ ,
T Left and Below: Culturally modified ` :.-le' * • ' c P. r ll,F s
�' w 1 tree and an old carving on an aspen - - .i
j , r.
;, ,, ir- (Courtesy of DRHP). ,� - =4
1l'i illr' v Right, Top to Bottom: Artifacts from ''"'`' ..;
r� �`�, �, 4' " " Mud Bay, Olympia: Toy war club, two ` . - . :i
' strand cedar roe wet basketry. s i'
p rY
:. „t, 1 ..1 t i .,..;11*, ,' 't, . ti - _ , rF4.
r.
J I 4
i,
b .,..; 0.11:i. NilIllk\ Sil,;7:,.1:,..
Of
! i 1,1161.*** ' %4 ' b - _
•s 114 , i I j 0 1kt. -TV, .. , . _ -err'
I i Lit 1 11:' ' 7
i 1 1 , VI*gt -- . '
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� 4,.
i f t tea.
r ! k . ` �' y 1 i u Yl 1 r t
r ► f f I, ; . • .!t, +yam++_ ie,� • • ` _ •• q�� _, ,."
‘. .r rt .4 21 t4 f - I_ ' - :1- ..-4-,--_-if • ,o§ •-,,,, l'', . ,f7o-, ' -4,%.*
1K f. 1 • _, ,joci ,
ir.,,-•l . ' .' - - . z.41 y
Y '. , h Y. 'Sri,k / #.
ECY 070-560 (rev. 06/21) 11 I DP Form
4-,3.�/b'i T��ia-F ir 3}4 i, i,e- t''-'.!,i,'.:::'W
Implement the IDP if you see... ,y} ; ,��(•��< • '6- ,: , �'
Strange, different, or interesting looking dirt, rocks, or shells. :' _...r, ;;; , � ,�:, „ , .•4.
Human activities leave traces in the ground that may or may not �� .
a5 �`ry�cy � .� ✓.u3x 3F% ,
.„A - F .7 S " i.J yykV `V .f � .- "rla
have artifacts associated with them. Examples are: f _ h � .� ^; p5,
• ``Unusual" accumulations of rock (especially fire-cracked rock). .'4 ;' 5 „, ,,; jt4
• "Unusual" shaped accumulations of rock (such as a shape �" J r
similar to a fire ring). �.. f
• Charcoal or charcoal-stained soils, burnt-looking soils, or soil ,, r 't4.
that has a "layer cake" appearance. 4d 4
• Accumulations of shell, bones, or artifacts. Shells may be .-%i-, 4,:•q,, t, �r .
crushed. - :► . -, ;.• 4
• Look for the "unusual" or out of place (for example, rock piles Shell Midden pocket in modern fill discovered in
in areas with otherwise few rocks). sewer trench.
0
* 95.vc25F !�c
!II Shell midden with fire cracked rock. -- = - N-'y
.ar 4164taiAbil Pi 17-4.''',t'Lk.-tirr'32*!:* , ':14':' , , ". . -,-%- ''.-4.
4111011b0
0__ i t, . 1 , .,,, ,, , . - _ . 1 lib imair lk, H
•. A%Anakidris joi
;51�yt _ -,
EI. _- ! `, y' r �,a/ max
Underground oven. Courtesy of ,DAHP. - �� .�
Hearth excavated near Hamilton, WA.
ECY 070-560 (rev. 06/21) 12 IDP Form
Implement the IDP if you see...
Historic period artifacts (historic archaeology considered
older than 50 years).
Examples are:
i#41r, 1i. "*.• Agricultural or logging equipment. May include equipment, fencing, L � �
canals, spillways, chutes, derelict sawmills, tools, etc. II .r �i ,. .
• Domestic items including square or wire nails, amethyst colored glass, ,-
or painted stoneware.
Left: Top to Bottom: Willow pattern
serving bowl and slip joint pocket ,.
knife discovered during Seattle
4 Smith Cove shantytown (45- 2do'•, , ,.. °. _
KI-1200) excavation. , ~:
Right: Collections of historic r t . r -: '"y
t, r artifacts discovered during '� ' , ° .4;'r 4z
excavations in eastern -
fsi
'T GS M�..
Washington cities. - 1
.. , .,,,_ ,
„.„
, ,
lip. .. ._ . ,... ,,,, ,�s ya4-
-,-r r y xy. f .4" "ski] s
ECY 070-560 (rev. 06/21) 13 IDP Form
MINA ION
Implement the IDP if you see...
Historic period artifacts (historic archaeology considered
older than 50 years).
Examples are:
• Railway tokens, coins, and buttons.
• Spectacles, toys, clothing, and personal items.
• Items helping to understand a culture or identity.
• Food containers and dishware.
/--- Right, from Top to Bottom:
l II '� "_
Coins, token, spectacles
T I �, _ and Montgomery Ward
'�' 'ai"'�.,� = ' <ti`=_ • '' pitchfork toy discovered
, ', 4 , `. � - r ',/, v. �_ .,,, . yam :;
' during Seattle Smith Cove
k shantytown(45-K1-1200)
_ excavation.
i c 4, k -
..a,„ .... .
1'4- . .,zi\
4 ,,:,,--,,Z-tfi-,-- .,- -ci.,, ,w, .-f:.,4-- .-.= ':-''Ir; ,.-' • It'
/ e-,. -- - .,
A .. 1 , K{. !r f r t: 4
.,( A-'1., _ ,.,� -
iiimimmmomEN-1 ..
.E` F.
:Ali- our
I. '` 4��:�� iK �`I*10.
Main Image: Dishes, bottles, workboot found at the North Shore Japanese bath
house (ofuro) site, Courtesy Bob Muckle, Archaeologist, Capilano University,
B.C. This is an example of an above ground resource.
ECY 070-560 (rev. 06/21) 14 IDP Form
Implement the IDP if you see...
• Old munition casings — if you see ammunition of any type —always assume they are live and never touch or move!
• Tin cans or glass bottles with an older manufacturer's technique — maker's mark, distinct colors such as turquoise, or
an older method of opening the container.
Al •�4 Far Left: .303 British ' r/
ily i ' -. "_ ? cartridge found by a WCC
M �. . a planting crew on Skagit
1\ . , -,. -46:‘ , A River. Don't ever touch
k-ir
Mf M something like this!
• +. `i Left: Maker's mark on
. - 4 G bottom of old bottle. ``
1
611 ill ! - .1krt' iii-
li\ t = }' Right: Old beer can found ` •t ' �
j in Oregon. ACME was �.
1 owned by Olympia �`� .: _- }
e §' Brewery. Courtesy of
•r Heather Simmons. lilt i
-` .
't'4. •.,j h .1 ' ` ,s,ti{ 1934-1963+ 1962-1965 1965-1975
ti P.R. _
"",4t - '-,- - it. ,.._.0.i..V..z.-7,:: ..-,
_4,,.
,.
• iY,.4.0._:_ %I„
- Logo employed by Whithall
Tatum & Co. between 1924 to
1938 (Lockhart et al. 2016). Can opening dates, courtesy of W.M. Schroeder.
ECY 070-560 (rev. 06/21) 15 IDP Form
Implement the IDP if you see... : - ' iii.„
You see historic foundations or buried structures.
i • -•_ J.�or . ,- STRATUM IiII
Examples are: 1 _ , --
• Foundations. - - - -.'� �:,- -rsTRATUM I
• Railroad and trolley tracks. '
,. ,-.:- • , fry ti� : STRATUM Y —_,
• Remnants of structures. f- .,, ++ r� . .y _tsgp,. ,F • t
�' �l'. _1 .-_ ,�-� ST-RATUM V1
r. t* �T _ fit` . . r
4,, A 1 , A.*:!.••..
'.441P81111i0ep
•y Snl vEl' .� y
A % -
1rir:Ir
! � 1
118...=Iiiiii.ign . . ., h.hur
- -.: ..._:- .y-.., - -._ --
•
_ _
7-.„. !..._ ___ _
— -41r---: , ' 4 _
. ..
,. '-- �: Counter Clockwise, Left to Right: Historic structure 45KI924, in WSDOT right of way for
j' - V SR99 tunnel. Remnants of Smith Cove shantytown (45-KI-1200) discovered during
•
- _ - _ Ecology CSO excavation, City of Spokane historic trolley tracks uncovered during
_ - _ '- stormwater project, intact foundation of historic home that survived the Great Ellensburg
'„ = -51' -% Fire of July 4, 1889, uncovered beneath parking lot in Ellensburg.
ECY 070-560 (rev. 06/21) 16 IDP Form
1
Implement the IDP if you see... 1 - _ ,
E
Potential human remains. ' --- _ e-it•.
Examples are: �•' :t . - ." ,
• Grave headstones that appear to be older than 50 years.
• Bones or bone tools--intact or in small pieces. It can be difficult to ' --
differentiate animal from human so they must be identified by an �: ' i _ _
expert. /, — , r
• These are all examples of animal bones and are not human. ti , '
Center: Bone wedge tool, --_,__ ' s
courtesy of Smith Cove —
Shantytown excavation , , t ' , , -
(45K19200). . i 4 /11 l •
,,' F
Other images(Top Right,
Bottom Left, and Bottom) 14; "'"";.,,j :. • ` r .,•_,,.....
Center: Courtesy of DAHP, s" ir `� ►y "� �`;,
IIIIIII nuiiI * , x'``
c
fi r r N.
Iiii
` {. "°\ _ �►i _ -r+ # -tom _ . ._-.
fir ' ., �_l '� .r • ` - • 7 114 's,
ik:
. . .
..Ap ----7,,,_., ., . - ,- ! ,
,,.... . .
„,.\
,_- �[.+ .J Directly Above: This is a real discovery at an
.i.; f ,,
_ ,
' Ecology sewer project site.
_ ,
r, +�'�y What would you do if you found these items at
' ,a. a site? Who would be the first person you
c; x + r would call?
,� '. ` ter
Hint: Read the plan!
ECY 070-560 (rev. 06/21) 17 IDP Form