Our Archaeology

We've just one chance to treat it right

Part 1 | Part 2

To better enforce our environmental protection laws, when Oakland City Council made its contract with Forest City LLC, they required the developers to open their plan for studying and excavating the archaeology to a focused community review.

To assist the developer's archaeologist in preparing their research and recovery plan, we provided the contractor with a compilation of community research about the site.

In partnership with Forest City, the City held a public meeting to give feedback on developers' archaeological plan on Thursday, May 19th, 2005, 6:00 p.m. in the City Administration Building (250 Frank Ogawa Plaza), 3rd Floor. For a free copy of the draft plan, download here, or for a paper copy, contact the City Planner at (510) 238-6168 or lwarner@oaklandnet.com.

Community members have deep expertise about the site, and provided helpful feedback to the developer's archaeologist, who noted this work is unlike that which they've done previously. One detailed set of comments on the contractor's draft plan is reproduced below. The Oakland Asian Cultural Center and the Oakland Heritage Alliance are both watching this issue. In addition, this feedback is from the Chinese Historical Society of America.


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Claudia Cappio, Development Director
Community and Economic Development Agency
250 Frank H. Ogawa Plaza
Oakland, CA 94612

Re:  Uptown Redevelopment Project MMRP Hist 2a and 2b, initial review of draft Archaeological plan dated January 2005, prepared by Archeo-Tec.

May 19, 2005

Dear Development Director Cappio:

Thank you for the opportunity to comment on the Uptown Project’s Draft Archaeological Study and Testing Plan, in partial fulfillment of mitigation measures Hist 2-a and 2-b. This letter constitutes comments from the Chinese Historical Society of America.  Established in 1963, CHSA is the oldest not-for-profit organization dedicated to the promotion, education, and preservation of Chinese American history. 

The CHSA incorporates by reference the comments and recommendations in “Oakland’s San Pablo Avenue Chinatown: A compilation of research to aid the upcoming archaeological sensitivity study and treatment plan to be drafted by the archaeological contractor for Forest City’s Uptown redevelopment project” (Naruta 2005).

This letter comments on a number of important areas that have been left out of Archeo-Tec’s draft document.  We focus on remains anticipated to be associated with the historic San Pablo Avenue Chinatown.  These comments first address major procedural problems that jeopardize the mitigation’s ability to comply with CEQA.  The latter portion of this letter address some factual errors and omissions.  The lack of background research on the San Pablo Avenue Chinatown has hampered the testing design to a degree that a new draft should be prepared for focused community review. 

The relation of this draft document to the process of complying with the mitigation monitoring and reporting plan needs to be clarified.  Currently there is no definition of how the mitigation process will work from start to finish.  While there will need to be some flexibility to be able to respond to what’s actually discovered, the whole process needs to be mapped out in advance to be effective and avoid project delays. 

The Introduction (pages 1-5) confusingly refers to three different types of documents (SS, MMRP, SSTP), suggesting the current draft may be just a partial effort.  The purposes of those different documents and their relationship to this plan are not adequately explained.  A quick review of this document reveals important gaps.  The most important shortcomings are the scant details about how evaluations will take place and the absence of any provisions for accomplishing mitigation.  Since there are good reasons to believe legally significant archaeological resources are present within that project area, all aspects of the work must be spelled out clearly and comprehensively up front.  Major problems will ensue if additional documents need to be prepared at a later date while resources are left exposed and subject to damage.  The comments below provide more detail. 


ARCHAEOLOGICAL TESTING PROGRAM (Draft Document Section 9; Summary of Recommendations pages 4-5)

The sequencing and methods outlined for the archaeological testing program are likely to cause unnecessary project delays and damage potential legally significant archaeological remains. 

The Summary of Recommendations (pages 4-5) recognize a sequence of activities including monitoring building demolition, testing, evaluation, data recovery, and selective construction monitoring.  While it is useful to recognize those "steps,” the first four tasks must be carried out continuously or at least in very close succession.  If resources are discovered and then left exposed or even covered in some fashion,  they will be more likely to be damaged by looters, the elements (rain, trench collapses, etc.), and the need for further destructive exposure later in time because they are no longer clearly visible in fresh soil exposures.  24-hour onsite security cannot adequately address this problem.  To wait until after resources are discovered to define the full details of the evaluation and mitigation steps jeopardizes potenial legally-significant archaeological resources and the redevelopment project schedule. 

In Oakland, rapid and CEQA-compliant archaeological testing programs have been developed and their effectiveness proved for evaluating areas both large and small with no project delay (Praetzellis 1994, 2004; van Buren 2004; [van Buren 2002]).  Oakland City Council awarded a proclamation in recognition of the effectiveness of the methods used in the Cypress Freeway Project (Praetzellis 1994; Praetzellis and Praetzellis 2004).  In the case of the methods for the Thomas L. Berkley Square Project (Praetzellis 2004), the research methods have already met community review.

To be CEQA-compliant, the testing program needs to be revised according to the methods demonstrated in the adjacent Thomas L. Berkley Square Project (Praetzellis 2004:25-26, Appendix A of this document); the Mandela Park and Ride Relocation Project (van Bueren 2004: 30-40, in Appendix B of this document); and the Cypress Freeway Replacement Project (Praetzellis 2004: 7-9, Appendix C of this document). 

As demonstrated in the backhoe trenching and subsequent broad area exposure of the Mandela Park and Ride Relocation Project (van Bueren 2004, map page 35), backhoe trenching is likely to fail to discover or to destroy legally significant archaeological remains. [view full-size map]  Backhoe trenching could be used to test for the presence of shellmound deposits far below the lowest extent of Mexican-period and post-Mexican period deposits, but must be eliminated as a discovery method in any portion of the project area in order for the mitigation to be compliant with CEQA standards for the treatment of anticipated resources.  See photos in Appendix B. 

It is important that the archaeological and the developer coordinate the archaeological work and the demolition schedule so that any demolition work proceeds in compliance with CEQA and the project will not be unnecessarily delayed.  Planning for this must begin now and spelled out this document. 


RESEARCH DESIGN AND DATA REQUIREMENTS (Section 8):

This is generally thoughtful and specific to the types of properties anticipated, but some discussion of data requirements must be offered for each research topic.  This will further define what is an important resource under CEQA, and guide decision-making in the field. 

The data requirements essentially define what material remains will contribute to the resolution of the issue (and are thus significant or eligible) and what methods (e.g., field collection, lab analysis, etc.) are required to elucidate those topics.  For example, while building remains are rarely eligible if they are well documented on maps, architectural evidence of a Chinese enclave may have the potential to yield important information (as the research design appropriately acknowledges).  Hence, fieldwork should devote attention to finding and documenting architectural evidence of the Chinese settlement indicated in the northwestern portion of the project area and how it related to the construction of the east-west roads between San Pablo and Telegraph Ave.  This is only one example.  Again, precedent for conducting a CEQA-compliant archaeological evaluation of this area is given in the community-reviewed archaeological document for the adjacent project, the Thomas L Berkley Square Project (Praetzellis 2004: 10-24, reproduced in Appendix A).  This plan must clearly spell out the research design and the data required to address it.  See also Naruta 2005:10.


EVALUATION, DATA RECOVERY AND LAB ANALYSIS

The characteristics a deposit or feature should possess in order to trigger an evaluation process entailing controlled manual sampling must be defined.  The document must specify how other types of archaeological remains--those not considered “potentially significant”--are to be documented.  This should be tied to the data requirements in the Research Design (something omitted in Section 8) and the types of deposits that are anticipated (Section 7).  All large pit features, especially ones that appear to be privies and wells, should be sampled to justify a decision regarding eligibility to the California Register. The manual testing should be strictly stratigraphic for historical resources, to ensure the timing and relationships among deposits and features are recorded and understood.  Pit features are appropriately sectioned (half of their horizontal area is sampled in stratigraphic levels to expose a profile).  California Register-eligible features should be then excavated in full to prevent their destruction.  

More detail is needed on the evaluation procedure introduced on pages 97-101.  The evaluation guidelines (pp. 97-98) for “association” are too restrictive, since archaeology is particularly likely to enhance understandings of poorly documented groups like the Chinese.  A deposit associated with a Chinese business or domicile may be eligible even if we do not know the specific names of the people.  In other words, a lack of documentation sometimes enhances the value of what archaeology can tell us.

Lab analysis of artifacts must be carried out at least to the stage of temporal and MNI analysis in order to be able to evaluate and interpret the archaeological deposits. 

The document must specify how planned lab methods and specialized analysis will be arranged to meet the data requirements of the research design.  Methods used should follow those successfully employed at the Mandela Park and Ride Relocation Project (van Bueren 2004: 40-42, reproduced in Appendix B) and the adjacent Thomas L. Berkley Project (Praetzellis 2004:27-30, reproduced in Appendix A). 

Flotation sample and wetscreen sample procedures in Voss, et al., 1999: 2-8 should also be evaluated for fit with the research design’s data requirements.  At a minimum, some 1/8 inch mesh screened samples should augment the outlined 1/4 inch mesh screening. 


DOCUMENTARY RESEARCH INCOMPLETE AND INADEQUATE

The research presented in the study is inadequate for planning the testing of potentially legally significant archeological remains relating to the historic San Pablo Avenue Chinatown.  Pre-1889 period research is virtually absent.  The information in Naruta 2005 will help.  Further research directions are spelled out there and below. 


PLANNED TESTING LOCATIONS AND METHODS AT ODDS WITH A CEQA-COMPLIANT PROGAM

The new background research will necessitate complete redesign of the testing program.  For example, with the 1870s depiction of the area likely showing the Chinatown aligned east-west, there are large unexplained gaps in the current sampling design.  Also, the eastern portion of the project area may have highly significant archaeological deposits associated with the filling of the former pond (see especially Naruta 2005:11).  Whether the construction of the east-west roads displaced portions of the Chinatown is also a significant question for understanding the site.  Research should include the dwelling of Edmund Hogan, former resident of the project area and possible landlord to the Chinatown.  Hogan is also significant for being a resident both before and after the establishment of the city grid in the project area. Substantial prior work in Oakland suggests backyards of lots occupied before 1900 should be considered sensitive.  The proposed extent of areal exposure shown in Maps 9.2-9.4 is inadequate. 

None of the maps show the locations of areas most likely to contain the Potential Resources discussed on pages 3-4.  Anticipated sensitive areas should be mapped.  (Producing an overlay of all the Sanborn maps with other historic data can be of use.)  Previous testing in the area should be mapped.  Historic land uses should be tabulated and the information used to help map anticipated sensitive areas.  The tax assessor rolls from 1860 onwards, block books, chains of title, parcel maps, and old maps archived with City Blueprint Services will be of use here. Portions of this information can be extracted from OCHS Forms, when available. Proper research here can greatly expedite the field work. 

The map or maps should be designed so as to be able to be reproduced in black and white—the current draft is unreadable.   Also, Figure 9.1 currently has little informational value and should be re-evaluated to include research into the historic land uses. 

All of the address-specific historical detail would be best put into an appendix with a brief summary offered in the text.  Pre-1880 census information should be researched with the aid of City Directories, tax assessor rolls, block books, and chains of title. 


PROJECT OVERSIGHT

Enforcement of CEQA-compliant treatment must be addressed.  How will the program be monitored for compliance?  This is of particular concern given the developer’s involvement in having to settle with the City of San Francisco over the “demolition of portions of the former [historic Emporium] structure that were supposed to be preserved” (San Francisco Chronicle, May 3, 2005, p.B1,B5). 

On a project this size it would be worth the City hiring an independent professional archaeologist to offer input at the developer’s expense.  Or perhaps, as many jurisdictions require, the developer could place funding in an escrow account so that the City hires the consultant to perform the work and ensures it is completed in a fully professional manner with appropriate public input.

Additionally, the best time to involve interested parties and the City is after preliminary evaluations have taken place, not after initial discovery when little objective information is available.  Field forms can be designed to tally in a preliminary manner data used to assess significance (temporally diagnostic materials, variety/quantity of artifacts).  Data recovery should proceed at features/deposits that are clearly eligible, while those that are more borderline could be subject to some kind of input.

Looking to the successful conclusion of the project, what will be the process for designing and reviewing the public interpretation?  Reporting, curation, and public interpretation need to be spelled out.


CULTIVATING PROJECT SUCCESS

Hist 2a and 2b’s provisions for futher community involvement should be planned.  The project can greatly benefit from association with the San Pablo Avenue Chinatown history.  Let’s explore having at least one day—if not more—where the public can come by the site and observe the excavation.  This can help generate interest in and positive exposure for the Uptown project. 

The archaeological study should also plan for how its results will be processed, and how they will articulate with the mitigation for public interpretation of the results.  Where will the artifacts and other material be curated?  (The 2004 revisions to CEQA further enforce the importance of CEQA-compliant handing of excavated materials, which need to be treated in accordance with the Office of Historic Preservation’s 1993 Guidelines for the Curation of Archeological Collections.)  The treatment should be equivalent to that specified for the adjacent Thomas L. Berkley Square Project (Praetzellis 2004:30, reproduced in Appendix A)  How will the artifacts be accessible to researchers and members of the interested public? A solution that could generate positive synergy for the project would be to curate and display them in the 120-year-old Victorians at 1972-1966 San Pablo Avenue, one building of which new research has discovered seems to be the last remnant of the turn-of-the-century Chinese garment district on San Pablo Ave, which developed more than a decade after the eradication of the “official” Chinatown on San Pablo Avenue (Fong 2005).  There is great potential for the Uptown Project to aid its future success by connecting with this past heritage. 




MISCELLANEOUS ERRORS AND CONFUSIONS

Some corrections and needs for clarifications are noted here. 

BACKGROUND RESEARCH   Page 5:
In the list of institutions at which background research was conducted, there is no specification of what resources were consulted at the National Archives, Oakland Asian Cultural Center, Oakland Public Library, etc., and the results of those searches are not evident from the bibliography.  Please specify. 

This error is compounded by the study’s failure to give references for historical assessments, such as “according to the historic record (p. 77),” or “according to historic research (p. 78).”  This ... prevents current or future researchers from critically evaluating or building on the results.  Please also specify sources for all maps and illustrations.

SECTION FIVE: PREVIOUS ARCHAEOLOGICAL INVESTIGATIONS:
The purpose of discussing previous archaeological studies is to consider their major findings as a way to further define how potential archaeology in the study area is a legally significant resource under CEQA, and to elucidate what may be important to learn from these resources.  Merely mentioning the name of a project does not even begin to accomplish that task.  This section should set the stage for the research design in Section 8.  There are some major gaps in the discussion of previous historical archaeology.  Those gaps include the Cypress Freeway Replacement Project, Mandela Park and Ride, and other significant Bay Area urban historic data recovery investigations at the very least.  There is also no mention of three major studies of Oversees Chinese communities in Sacramento (Praetzellis & Praetzellis 1982, 1990, and 1997) and Walnut Grove (Costello & Maniery 1988).

Page 23:
This study notes that present-day San Pablo Avenue In the Spanish period was a route connecting East Bay ranches. Given the antiquity of the road, and that the project area is located near one of its termini, what evidence leads the study to conclude remains from the period of 1776 - 1848 would be absent?

Page 24:
Absent biographical information about Josef Irving, it's unwarranted and likely incorrect to assume the map shown in Figure 6.2 is related to the time of his death. 

Regarding discussion of Figures 6.4  and 6.3, with what Figure 6.4 4 labels "pond " is likely a pond associated with Lake Meritt, as indicated on earlier maps. Refer to Naruta 2005, especially page 11.

It's incorrect to assume Oakland's street grid or grades did not undergo much change in the period leading up to and following the opening of the transcontinental railroad. See DeWitt 1939; Naruta 2005; volumes one and two of Oakland City Council Resolutions. 

Relevant biographical information about Frederick William Delger and his family can be found at the Bancroft library.

Page 25:
Please remember the illustration in Figure 6.5 may show speculative plans for redevelopment.

Explain how the conclusions are being drawn from Figure 6.6.

Regarding the Uptown Chinatown, please see Naruta 2005.  Also, be wary of drawing conclusions about this area’s architecture based on other areas of Oakland.  This area is particularly unique and should be investigated.

Page 26:
When, if, and how Chinese Oaklanders left the Uptown area should be investigated, not assumed.

Tax rolls and city directories will allow you to do research with the 1860 and 1870 censuses.

Page 71:
Please clarify confusing wording about sheet refuse and architecture.

Page 76:
Remember the ca. 1870 illustration may be omitting portions of the Chinatown.

Page 77:
Regarding research questions, add: What occurred in the Project area in the period between the explusion of the Chinatown and the creation of the turn of the century Chinese garment district? What residents may have been displaced by the introduction of Hobart and other street additions?

Page 78:
Add to research questions: What kind of settlement was the Upper Chinatown? Was it dormatories or quartering?  Or a design of the residents’ own?  This will be more relevent than page 77’s discussion of Feng Shui.

Page 79:
Be wary of positing a monolithic Chinese identity.

Page 80:
Recall that the association of Chinese with opium, a British product, is a nineteenth century stereotype given a lot of play in the popular press.  Research questions involving opium consumption will require comparative data on opium use across the U.S., as opium was legal and even available, in a variety of forms, from Sears.

Pages 81-82:
There is a disjunct between goals of addressing residental urban life during Oakland’s Victorian period—such as drawing comparison among “several children living on the same street (81)”—and the lack of research on “families with no commercial affiliation (81).”

Page 83:
Study should also research the Edmund Hogan family for reasons including the association of his land with the Chinatown, and for the information looking into this household’s history can provide about the transition of this area from the outskirts of town to life on the grid.

Page 87:
Backhoe scraper excavation must use a flat-edged blade and should remove no more than 3-4 inches of soil at a time.


“SECTION 9: DATA RECOVERY”:
The streets between San Pablo Ave and Telegraph Ave (20th, William, 19th, etc.) did not exist until into the 1870s (City Council Resolutions Vol 1., Naruta 2004a, UptownChinatown.org 2004a)—even the City’s new map of 1868, the Boardman map (DeWitt 1939 p.84, Map no. 103), indicated roads that did not exist at the time or for years later, if ever (Naruta 2004a).


“Aerial exposure” should be changed throughout the document to “areal exposure” or “broad area exposure.”  References to the City of San Francisco should be changed to the city [of] Oakland.


Thank you for your attention to enforcing the project’s Conditions of Approval.  We look forward to a successful redevelopment project that connects Oakland’s past with its future!


Sincerely,
Anna  Naruta
2005-2007 Board Member
Chinese Historical Society of America

[naruta@berkeley.edu]
(For identification purposes only:
Ph.D. Candidate, Historical Archaeology
Archaeological Research Facility
University of California, Berkeley
P.O. Box 1514
Oakland, CA 94604)



References Cited:

DeWitt, Josephine  (1939)  Printed Maps of Alameda County and Its Larger Cities   M.A. thesis in Librarianship, University of California, Berkeley. 

Fong, Kelly.  (2005)  Nineteenth-Century Oakland Chinese Businesses.  Manuscript and maps prepared for Anth 197: Independent Research in Oakland Cultural Resources and Cultural Heritage.  Fall 2004-Spring 2005, University of California, Berkeley. 

Naruta, Anna.  (2005)  “Oakland’s San Pablo Avenue Chinatown: A compilation of research to aid the upcoming archaeological sensitivity study and treatment plan to be drafted by the archaeological contractor for Forest City’s Uptown redevelopment project.”  Oakland: UptownChinatown.org.  January 2005.  On file at the Oakland Cultural Heritage Survey, Oakland Public Library, and the Oakland Asian Cultural Center.

Naruta, Anna.  (2004a)  The San Pablo Avenue Chinatown.   Exhibit at Oakland Asian Cultural Center, 388 Ninth Street, Suite. 290, Oakland, CA 94607.  Presented by UptownChinatown.org

UptownChinatown.org  (2004a)  “Maps” section.  UptownChinatown.org website edited by Anna Naruta for UptownChinatown.org.  Contents copyright 2004 unless indicated otherwise

UptownChinatown.org  (2004b)  “Seeking Memories of Uptown Chinatown” section.  UptownChinatown.org website edited by Anna Naruta for UptownChinatown.org.  Contents copyright 2004 unless indicated otherwise

Praetzellis, Adrian (2004) Research Design and Archaeological Testing Plan for the Thomas Berkley Square Project, Oakland, California.  Rohnert Park, CA: Anthropological Studies Center.  April 2004. 

Praetzellis, M., Ed. (1994). West Oakland -- A Place to Start From. Volume I: Research Design and Treatment Plan for Historical Archaeology, Cypress I-880 Reconstruction Project, Contract No. 0F841-EP, ALA-80 P.M. 31.9/34.0. Rohnert Park, CA, Anthropological Studies Center, Sonoma State University Academic Foundation. Submitted to California Department of Transportation, District 4, Oakland.

Praetzellis and Praetzellis, Ed. (2004) Cypress Freeway Final Report.  (available online)
   
Van Bueren, Thad M., Jack Meyer, and Brian A. Ramos. (2002) Report on Archaeological Testing for the Broadway-Jackson Interchange Improvement Project in the City of Oakland, California. Report submitted to Robert Gross of the California Department of Transportation by Thad M. Van Bueren, Jack Meyer, and Brian A. Ramos, Oakland, CA. Report S-25247 on file at the Northwest Information Center, Sonoma State University, Rohnert Park, CA.

Van Bueren, Thad, Ed.  (2004)  Mandela Park and Ride Relocation Project.  CalTrans. 

Voss, B., A. Ramsay, and A. Naruta.  (1999)  Final Report: Funston Avenue Archaeological Research Project, Presidio of San Francisco, 1999. Archaeological Research Facility. Submitted to the Presidio Trust, San Francisco, October 1999.  (available online and at the Bancroft Library, University of California, Berkeley)


---Appendices coming soon---