Appendix H Cultural Analysis/Cultural and Paleontological Resources Studies Letter Report (Calipatria I, Midway I and Midway II)

Appendix H Cultural Analysis/Cultural and Paleontological Resources Studies Letter Report (Calipatria I, Midway I and Midway II)

AECOM 1420 Kettner Boulevard Suite 500 San Diego, CA 92101 www.aecom.com 619.233.1454 tel 619.233.0952 fax March 25, 2011 Tom Buttgenbach 8minutenergy renewables LLC 9903 South Santa Monica Blvd. Suite 900 Beverly Hills, CA 90212 Dear Mr. Buttgenbach: Subject: Literature Review for the Calipatria Solar Farm I Project This letter report documents the literature review conducted for the proposed Calipatria Solar Farm I project site, located in eastern Imperial Valley, Imperial County, California. The proposed project area includes four parcels located northeast of the community of Calipatria and southwest of Calipatria State Prison, in areas of active agricultural lands. The studied area is approximately 981 acres, which includes the proposed project area of approximately 610 acres. An archival records search was conducted at the South Coastal Information Center located at San Diego State University. The search included a 1-mile radius surrounding the proposed project site. The archival search consisted of an archaeological and historical records and literature review. The data reviewed included archaeological and historic site forms, historic maps, the California Register of Historical Resources, and the National Register of Historic Places (NRHP) information for the two project areas. This research provides a background on the types of sites that may be expected in the region. The research was also used to determine whether previous surveys had been conducted in the area and what actual resources had been previously recorded within the project limits. The records search indicated that 29 previous cultural investigations have been conducted within a 1- mile radius of the proposed project area (Table 1). These consists of 18 survey investigations, seven environmental impact reports, two historic properties survey reports, one monitoring program, and one history of local development in the area. Of these, 11 previous investigations are located within the proposed project area (Archaeological Consulting Services 1996, Pigniolo 1998, Singer et al. 1993, SWCA Environmental Consultants 2006, WESTEC 1981a through e). These consist of linear investigations. Table 1. Previous Conducted Investigations within a 1-Mile Radius of the Project Area. Author Title Date Within 1-mile radius Within Proposed Project Area AEI Consultants California State Historic Preservation Office-Superior, AEI Consultants. 2002 X -- 1996 -- X Archaeological Consulting Services Crafts Crafts Imperial Irrigation District An Archaeological Assessment of the Niland Imperial Pipeline Expansion Corridor, Imperial County, California. Negative Archaeological Survey Report for the Proposed Widening of Shoulders on State Route 111 in Imperial County between the Cities of Brawley and Calipatria. Historic Property Survey Report-Negative Findings- Widening the Shoulders on State Route 111 in Imperial County between the Cities of Brawley and Calipatria. Draft Environmental Impact Report for East Lowline and Trifolium Interceptors and Completion Projects. 1998 X -- 1998 X -- 1993 X --

Author Title Date Within 1-mile radius Within Proposed Project Area Johnson Archaeological, Historical, and Paleontological 1976 X -- Assessment of a Certain Location of the Campus of Calipatria High School. Pigniolo Cultural Resources Study of the Imperial County Prison 1988 -- X Alternatives Imperial County, California. Singer et al. Cultural Resources Records Search for Southern 1993 X California Gas Company Line 6902 South Imperial County, California. Stuart Draft Environmental Impact Report Airport Land Use 1982 X SWCA Environmental Consultants Plan. Volume I- Cultural Resources Final Report of Monitoring and Findings for the Qwest Network Construction Project, State of California. 2006 -- X Von Werlhof Final Report Archaeological Survey of Bigfoot. 1985 X -- Von Werlhof Archaeological Examinations of the Proposed Calipatria 1993 X -- Garden Apartments. Von Werlhof Archaeological Examinations of the Proposed Calipatria 1993 X -- Garden Apartments Phase IV. Von Werlhof Archaeological Investigations at Calipatria, California, 1994 X -- The Proposed Calipatria Eagle Subdivision. Von Werlhof Archaeological Investigations at the Proposed Bonita Place Apartment Complex in the City of Calipatria, California. 1994 X -- Von Werlhof Archaeological Examinations and Assessments of the Dominguez Home in Calipatria, Imperial County, California. 2001 X -- Von Werlhof Negative Archaeological/Historic Survey Report on 2001 X -- Calipatria City/County Library Building. Von Werlhof Delfino and Martha Ortiz Residence, 210 West Barbara 2001 X -- Street Calipatria, Imperial County California. Von Werlhof Examinations and Assessments of Juana Lopez 2002 X -- Property. Von Werlhof Prospective Housing Rehabilitation for Calipatria. 2003 X -- Von Werlhof and Von Werlhof Archaeological Examinations of a Waste-Water Treatment System for the City of Calipatria. 1977 X -- Wallace and County of Imperial Bicycle Master Plan. 1999 X -- Todd WESTEC Appendix A; History of Local Development. 1980 -- X WESTEC Salton Sea Anomaly Cultural Review Data-Support 1981a -- X Package. WESTEC Salton Sea Anomaly Master Environmental Impact 1981b -- X Report. WESTEC Volume I- Salton Sea Anomaly Master Environmental Impact and Magma Power Plant #3 (49MW) Environmental Impact Report Draft. 1981c -- X WESTEC WESTEC Wirth Associates, Inc. Volume II Salton Sea Anomaly Master Environmental Impact Report and Magma Power Plant #3 (49MW) Environmental Impact Report Appendices. Final Salton Sea Anomaly Master Environmental Impact Report and Magma Power Plant #3 (49MW) Environmental Impact Report Comments ad Responses APS/SDG&E Interconnection Project Environmental Study Phase II Corridor Studies- Native American Cultural Resources Appendices. 1981d -- X 1981e -- X 1980 -- X 2

The records search indicated that three cultural resources have been recorded within a 1-mile radius of the proposed project area (Table 2). These consists of historic elements that represent a component of the historic Estelle Siding associated with railroad activity within Imperial Valley, the remnants of the Bonita School, constructed in the 1910s, and a portion of the Niland to Calexico Railroad. The Niland to Calexico Railroad is located within the proposed project area, along the western boundary, running north to south. Table 2. Previously Identified Cultural Resources within a 1-Mile Radius of the Project Area. Primary Number (P-13-) Permanent Trinomial (CA-IMP-) Site Description Date Recorded Within 1-mile of the Proposed Project Area Within the Proposed Project Area 005951 050951 Estelle Siding 1996; X -- 1988 007056 07056 1910s Bonita School 1994 X -- 008682 08166 Niland to Calexico Railroad 2005; 2003 -- X One historic address was also identified within a 1-mile radius of the proposed project area. This consists of a single family dwelling constructed in the California Bungalow style sometime during the 1920s or 1930s. No historic addresses were identified within the proposed project area. Cultural sensitivity levels for project areas are rated low, moderate or high based on the results of the record searches and AECOMs past experience in the area. A low sensitivity level indicates that there are few or no previously recorded resources within the project site and the surrounding area. Resources at this level would not be expected to be complex in nature, with little to no site structure no artifact diversity. The potential for the identification of newly identified resources at such project sites would be low. A moderate sensitivity level indicates that previously recorded resources were identified with the project site and/or the surrounding area. These are more complex resources, consisting of more site structure, diversity of feature types, and artifact types. The potential for the identification of newly identified resources at such project sites would be moderate. Areas identified as high sensitivity would indicate that the record search identified previously recorded sites within the project site and/or the surrounding area. These resources may range from moderately complex to highly complex, with more defined living areas or specialized work space areas, and a large breadth of features and artifact assemblage. The potential for the identification of newly identified resources at such project sites would be high. For the proposed Calipatria Solar Farm I project area, based on the records search review, the potential for cultural resources within the proposed project area is low. One area in which prehistoric cultural materials appear to be concentrated in this region is the shoreline of ancient Lake Cahuilla, which would have encompassed the present-day Salton Sea. The lake covered much of the Imperial Valley and created an extensive lacustrine environment. Lake Cahuilla experienced several fill-recession episodes before it finally dried up about 300 years ago. In 1905, the Colorado River overflowed into the Salton Basin creating the present-day Salton Sea. While the project site is located within an area of recessional activity related to ancient Lake Cahuilla, based on the records search information and intensive agricultural use of the area, the potential for cultural resources within the proposed Calipatria Solar Farm I site is low. As the majority of the project area has not been previously surveyed, a pedestrian survey investigation of the proposed project area would need to be conducted to identify any undocumented cultural resources within the area. In the event resources are identified during the survey, avoidance would be the preferred mitigation measure. If cultural resources cannot be avoided, these resources would need to be evaluated for significance under the California Environmental Quality Act (CEQA) 3

for inclusion in the California Register of Historical Resources (CRHR). A testing and evaluation program would need to be developed and conducted. If a cultural resource cannot be avoided and is found to be significant under CEQA, a mitigation program would be required. For archaeological resources, this typically involves a research design and data recovery excavations. Should you have any questions concerning this letter or need additional information, please feel free to contact me by telephone at (619) 233-1454 or by e-mail. Sincerely, Cheryl Bowden-Renna Archaeologist/Associate cheryl.bowden-renna@aecom.com 4

626 Wilshire Boulevard Suite 1100 Los Angeles, CA 90017 213.599.4300 phone 213.599.4301 fax www.esassoc.com October 5, 2011 Mr. Michael Joh 8Minutenergy Renewables 10100 Santa Monica Boulevard, Suite 300 Los Angeles, CA 90067 Subject: Cluster I Solar Project Cultural and Paleontological Resources Studies Letter Report Dear Mr. Joh: This letter report provides the results of cultural and paleontological resources studies completed for the proposed Cluster I Solar Power project (project). The cultural resources study included archival research at the South Coastal Information Center (SCIC), a Sacred Lands File check with the Native American Heritage Commission (NAHC), and a pedestrian survey. The paleontological study included a records check at the Los Angeles County Museum of Natural History (LACMNH). The following letter report summarizes the results of these studies. The studies were conducted in compliance with the California Environmental Quality Act (CEQA). CEQA requires lead agencies to determine if a proposed project would have a significant effect on historical or archaeological resources (Sections 21083.2 and 21084.1). If a project may cause a substantial adverse change in the significance of a historical or archaeological resource, the lead agency must identify potentially feasible measures to mitigate these effects (Sections 15064.5(b)(1), 15064.5(b)(4)). Paleontological resources are also afforded protection by CEQA. Appendix G (Part V) of the CEQA Guidelines provides guidance relative to significant impacts on paleontological resources. Project Understanding The project would develop a 255-megawatt solar photovoltaic (PV) power generating facility on three separate project areas in Imperial County, totaling 1,731 acres of land. The three solar farm project areas include: 1) Calipatria Solar Farm I (Calipatria I); 2) Midway Solar Farm I (Midway I); and 3) Midway Solar Farm II (Midway II). The Imperial County Planning and Development Services Department is the lead agency for this project. Project Location The project areas (Calipatria I, Midway I, and Midway II) are located on three discrete locations that are currently being used for agricultural purposes. These three project areas are located within Imperial County, about 2.5 miles north of the City of Calipatria, California.

Mr. Michael Joh October 5, 2011 Page 2 Calipatria I The Calipatria I project area is located directly north of the City of Calipatria in an unincorporated area of the County of Imperial. The site is bounded by Blair Road to the east, Young Road to the south, West Lindsey Road to the north, and farmland to the west, and includes approximately 609 acres of land. The site is subdivided into four agricultural parcels. The property is identified as Assessor s Parcel Numbers 023-020-016 and 023-020-012 (north half) and is legally described as a portion of Section 10, Township 12S, Range 14E, SBB&M [San Bernardino Base & Meridian]. Midway I The Midway I project area is located approximately 2.5 miles northwest of the City of Calipatria and is bounded English Road to the east, West Sinclair Road to the north, East Peterson Road to the south, and private roads to the west, and inlcudes approximately 319 acres of land. The property is identified as Assessor s Parcel Number 022-130-008-000 and is legally described as the Eastern half of Section 31, Township 11S, Range 14E, SBB&M. Midway II Midway Solar Farm II is located approximately 1 mile northwest of the City of Calipatria and is bounded by English Road to the west, East Hoober Road to the north, Montgomery Road and West Lindsey Road to the south, and a private road to the east, and includes approximately 803 acres of land. The property is identified as Assessor s Parcel Numbers 022-130-005-000, 022-160-005-000 and is legally described as the South half of Section 32, Township 11S, Range 14E, SBB&M and the South half of the North half and the Southwest quarter of Section 5,Township 12 South, Range 14 East, SBB&M. Project Components The project includes development of the following components: Installation of up to 2.1 million solar PV panels installed on fixed-tilt or tracker mount systems; PV panel steel support structures and possible tracker motors; Combiners, electrical inverters and transformers; Three electrical substations and three 20 to 30 foot high dead-end towers to allow connection of overhead electric conductor wires to the 230 kv Midway-Bannister transmission line (one of each at each of the three sites); Buried electrical conduit, transmission and collection lines; Three operations and maintenance (O&M) buildings (one at each site); Three septic systems and leach fields (one at each site); On site access roads; Low voltage 8 foot high security fencing (no barbed wire at top); and Temporary construction laydown areas, equipment, and structures

Mr. Michael Joh October 5, 2011 Page 3 Cultural Resources Studies Cultural resources studies were conducted for the project, including archival research by AECOM and a pedestrian survey of the three project areas by ESA. The following section summarizes the methods and results of these studies. Archival Research A records search for the project was conducted on September 20, 2010, and December 6, 2010, at the SCIC. The records search included a review of all recorded cultural resources within a 1-mile radius of the study area 1, as well as a review of cultural resource reports on file. In addition, the California Register of Historical Resources (California Register), the National Register of Historic Places (National Register), and the California State Historic Resources Inventory (HRI) listings were reviewed. Available historic maps and aerial photographs have also been consulted. Previous Investigations The records search indicated that a total of 32 cultural resources studies have been conducted within a 1-mile radius of the study area. Approximately 10 percent of the records search study area has been previously surveyed. Of the 32 previous investigations, 11 cross portions of the proposed project areas. These consisted primarily of linear investigations and covered less than 1 percent of the project areas (AECOM, 2011a; 2011b; 2011c). None of the project areas have been systematically surveyed for cultural resources. Previously Recorded Resources A total of four cultural resources have been recorded within 1 mile of the study area, including one within the Calipatria I project area (Table 1). The resources include: a historic-era archaeological site (CA-IMP-5951H); remnants of an early 20 th century school house that was demolished in the 1960s (CA-IMP-7056H); and an early 20 th century residence (P-13-008651). The remaining resource (CA-IMP-8166H) is a railroad line located in the Calipatria I project area and is described in more detail below. None of these resources appear to have been previously evaluated for their eligibility to the National Register or California Register. 1 The Calipatria I project area was reduced after the SCIC records search; therefore, the records search study area covers a larger area.

Mr. Michael Joh October 5, 2011 Page 4 Table 1 Previously Recorded Cultural Resources within 1 Mile of the Study Area Permanent Trinomial (CA-IMP-) P- Number (P-13-) Description Date Recorded Eligibility Distance from Project Areas 5951H 005951 Estelle Siding 1996; 1988 Unknown 1.8 miles N of Calipatria I 7056H 007056 1910s Bonita School 1994 0.7 mile S of Unknown Calipatria I In Calipatria I 8166H 008682 Niland to Calexico Railroad 2003; 2005 Unknown - 008651 1930s Single family home 2001 Unknown Source: SCIC, 2010 0.8 mile SW of Calipatria I CA-IMP-8166H Resource CA-IMP-8166H is the Niland to Calexico Railroad, which was constructed between 1902 and 1904 by the Southern Pacific Company and runs 65 miles from Niland to Calexico. The resource was recorded in 2003 by Collins and Pflaum as a standard gauge track on a gravel base and is still in use today (AECOM, 2011c). Native American Contact The NAHC was contacted on November 29, 2010 to request a search of their Sacred Lands File. In a letter response dated December 3, 2010, the NAHC indicated that no sacred sites are known to exist within ½ mile of the project areas. The letter included a list of Native American individuals and groups that are affiliated with the area. Contact letters were sent to all individuals and groups indicated by the NAHC as having affiliation with the project vicinity on March 18, 2011. The letters described the project and included a map depicting the location of the projects. Recipients were requested to reply with questions, comments, or concerns about the project. To date, one response has been received. On April 5, 2011, Bridget R. Nash-Chrabascz, Quechan Tribe Historic Preservation Officer, responded via email and indicated that the Quechan Cultural Committee did not have any concerns regarding the Midway I or II projects. Field Survey A cultural resources survey of the project areas was conducted on September 14 and 15, 2011. All accessible areas were surveyed on foot with survey intervals spaced at 30 meters; parcels covered with dense grasses or tall crops were not surveyed. About 40 percent of the Calipatria I project area, 100 percent of the Midway I project area, and 60 percent of the Midway II project area were surveyed. Ground visibility ranged from 0 to 50 percent across the surveyed portions of the project areas. Observed soils consisted of grey-brown silty loam and red clay. The previously recorded resource identified as the Niland to Calexico Railroad (CA-IMP-8166H) and one newly recorded resource, a cement-lined canal temporarily designated as CAL-1, were documented during the survey. Non-cultural fragments of obsidian were also noted. The fragments were located on either side of English Road between Sinclair Road and Hoober Road. The origin of the obsidian fragments could not be determined, but may have been imported as road fill.

Mr. Michael Joh October 5, 2011 Page 5 CA-IMP-8166H The previously recorded cultural resource identified as the Niland to Calexico Railroad (CA-IMP-8166H) was updated as part of this survey (Plate 1). The resource crosses the westernmost portion of the Calipatria I project area. Dates painted on the rails in this area indicate that they were replaced from March 26-30, 1999. One new feature of the railroad was recorded during the survey. The new feature consists of a culvert undercrossing at the intersection of Lindsey Road and the rail line (Plate 2). Rock and cement diversion walls bracket either side of a concrete pipe that crosses under the rail line. The walls are composed of thin slabs of shale-like rock stacked horizontally on top of each other and held together by cement mortar. The walls are poorly constructed and appear to have been built in haste. The cement mortar contains small pebbles and is very friable. The wall on the western side of the railroad line is in disrepair and appears to have partially collapsed into the adjacent canal. The wall on the eastern side of the railroad line is in good condition. No dates of construction or other markings were observed in the cement. Plate 1. Resource CA-IMP-8166H Niland to Calexico Railroad, view to the south.

Mr. Michael Joh October 5, 2011 Page 6 Plate 2. Culvert Undercrossing Eastern Side, view to the west. CAL-1 One newly recorded cultural resource (CAL-1) was identified during the survey. The resource consists of a cement-lined canal located adjacent to Peterson Road in the Midway II project area. The canal wall is stamped with Ryerson 1966 (Plate 3). However, based on limited archival research and an examination of a 1940 historic topographic map, this canal has likely been in existence since at least 1940, and possibly earlier (USGS, 1940; Clark, 1918: 287-290).

Mr. Michael Joh October 5, 2011 Page 7 Plate 3. Resource CAL-1 Cement-lined Canal Stamped Ryerson 1966, view to the south. Paleontological Resources Study A paleontological records check was conducted at the LACMNH on September 21, 2011 (McLeod, 2011). The sediments within the project area are composed of surficial deposits of lacustrine and fluvial Quaternary Alluvium with Late Pleistocene or Holocene Lake Cahuilla beds beneath. Lake Cahuilla deposits have produced terrestrial and freshwater vertebrate fossils, as well as diatoms, land plants, clams, snails, and crustaceans from nearby localities, though no vertebrate fossil localities have been recorded in the project areas. While excavation into Quaternary Alluvium will not impact paleontological resources, any substantial excavation below the uppermost layers and into the underlying Lake Cahuilla deposits has the potential to uncover significant vertebrate fossil remains (McLeod, 2011). Summary and Recommendations The following section summarizes the results of the cultural and paleontological resources studies and provides recommendations for the treatment of identified cultural resources, as well as recommendations for the protection and treatment of any unknown cultural and paleontological resources that may be present in the project areas. Summary Cultural Resources As a result of the cultural resources studies, two cultural resources have been identified in the project areas. Resource CA-IMP-8166H, the Niland to Calexico Railroad, is located within the westernmost portion of the

Mr. Michael Joh October 5, 2011 Page 8 Calipatria I project area. Resource CAL-1, an irrigation canal, is located along Peterson Road in the Midway II project area. Neither of these resources has been evaluated for their significance. Because portions of the project areas could not be accessed due to existing vegetation/crops and visibility was generally poor in those areas that were surveyed, there exists the possibility that additional cultural resources could be present at the surface. Additionally, there also exists the possibility that buried and intact cultural resources could be present below the agricultural plow zone which typically extends a maximum of two feet. Paleontological Resources The results of the paleontological records check indicate that the soil units within the project areas are sensitive for paleontological resources. Substantial excavation within the project areas has the potential to unearth significant vertebrate fossils. Recommendations Known Cultural Resources The project is not anticipated to impact either resource CA-IMP-8166H or CAL-1. In the event that either resource will be impacted, the project proponent should retain a qualified architectural historian, defined as an architectural historian meeting the Secretary of the Interior s Standards for architectural history (Department of the Interior, 2008), to fully document these two resources and evaluate them for their eligibility to the National Register and California Register. If resources CA-IMP-8166H and CAL-1 and determined to be eligible by the qualified architectural historian, and avoidance is not feasible, then prior to issuing any grading or excavation permits and prior to any project-related ground disturbing activities a detailed treatment plan should be prepared and implemented by the qualified architectural historian. Unknown Cultural Resources Though low, there remains a potential for uncovering previously unknown, buried cultural resources during project implementation. If such resources are encountered, the resources should be evaluated by a qualified archaeologist, defined as an archaeologist meeting the Secretary of Interior s Standards for archaeology (Department of the Interior, 2008). If the qualified archaeologist determines that the resources may be significant, then an appropriate treatment plan for the resources should be developed. If human skeletal remains are uncovered during project implementation, the project proponent should halt work, contact the Imperial County Coroner, and follow the procedures and protocols set forth in Section 15064.4 (e)(1) of the CEQA Guidelines. Paleontological Resources While no fossil localities have been recorded in the project areas, the types of sediments that underlie the project areas are known to contain fossils. Although excavation in the uppermost layers will not impact paleontological resources, any substantial excavation into the underlying Lake Cahuilla deposits has the potential to uncover significant vertebrate fossil remains. If paleontological resources are encountered during the course of construction, all activity in the vicinity of the find should cease until a qualified paleontologist has assessed the find. The qualified paleontologist should document the discovery as needed, evaluate the significance of the find, and develop an appropriate treatment plan.

Mr. Michael Joh October 5, 2011 Page 9 References Cited AECOM, Literature Review for the Midway Solar Farm I Project, prepared for 8minutenergy renewable LLC, January 7, 2011a. AECOM, Literature Review for the Midway Solar Farm II Project, prepared for 8minutenergy renewable LLC, January 7, 2011b. AECOM, Literature Review for the Calipatria Solar Farm I Project, prepared for 8minutenergy renewable LLC, March 25, 2011c. California Office of Historic Preservation (OHP), Instructions for Recording Historical Resources, Office of Historic Preservation, Sacramento, CA, March 1995. Clark, Harry H., Calipatria and Niland, in The History of Imperial County, California, edited by Finis C. Farr, pp. 287-290, Elms and Franks, Berkeley, CA, 1918. Department of the Interior, Secretary of the Interior s Standards and Guidelines for Archaeology and Historic Preservation (As Amended and Annotated), http://www.nps.gov/history/local-law/arch_stnds_0.htm, accessed August 28, 2008. McLeod, Samuel A., Paleontological Resource for the Proposed Cluster I Project, prepared for ESA, September 21, 2011. U.S. Department of the Interior, National Park Service, National Register Bulletin: How to Apply the National Register Criteria for Evaluation, National Park Service, Washington, DC., 1995. U.S. Geological Survey (USGS), Calipatria 7.5-minute topographic quadrangle, USGS, 1940.

Mr. Michael Joh October 5, 2011 Page 10 Contact Information If you have any questions about the information provided in this letter report, please do not hesitate to contact me. I can be reached by phone at (626) 375-2785 or email at cehringer@esassoc.com. Sincerely, Candace Ehringer, MA, RPA Cultural Resources

AECOM 1420 Kettner Boulevard Suite 500 San Diego, CA 92101 www.aecom.com 619.233.1454 tel 619.233.0952 fax January 7, 2011 Tom Buttgenbach 8minutenergy renewables LLC 10100 Santa Monica Blvd., Suite 300 Los Angeles, CA 90067 Dear Mr. Buttgenbach: Subject: Literature Review for the Midway Solar Farm I Project This letter report documents the literature review conducted for the proposed Midway Solar Farm I project site, located northwest of Calipatria State Prison on parcels bordered by W. Sinclair Road to the north, English Road to the east, E. Peterson Road to the south, and Brandt Road to the west, in Imperial Valley, Imperial County, California. The proposed project is located on approximately 339 acres of active agricultural lands. An archival records search was conducted at the South Coastal Information Center located at San Diego State University. The search included a 1-mile radius surrounding the proposed project site. The archival search consisted of an archaeological and historical records and literature review. The data reviewed included archaeological and historic site forms, historic maps, the California Register of Historical Resources, and the National Register of Historic Places (NRHP) for the project area. This research provides a background on the types of sites that may be expected in the vicinity of the project area. The research was also used to determine whether previous surveys had been conducted in the area and what cultural resources have been previously recorded within the project limits. Previous Investigations The records search indicated that three previous cultural investigations have been conducted within a 1-mile radius of the proposed project area (Table 1). These consist of two survey investigations and one environmental impact study. No previous investigations have been conducted within the proposed project area. Table 1. Previous Conducted Investigations within a 1-Mile Radius of the Project Area. Within Proposed Project Author Title Date Within 1-mile radius Area 2004 X -- Perry, Laureen M. Negative Cultural Resource Survey Calipatria Proposed Pilot Wetlands Brawley Wetlands Project Von Werlhof, Jay Wirth Associates, Inc. Imperial Valley College Foundation Environmental Studies for Ten Geothermal Exploration Wells. APS/SDG&E Interconnection Project Environmental Impact Study Phase II Corridor Studies Native American Cultural Resources Appendices. 1980 X -- 1980 X --

Previous Recorded Resources The records search indicated that no cultural resources have been recorded within the proposed project area or within a 1-mile radius of the proposed project area. Cultural Sensitivity Cultural sensitivity levels for project areas are rated low, moderate or high based on the results of the record searches and AECOM s past experience in the area. A low sensitivity level indicates that there are few or no previously recorded resources within the project site and the surrounding area. Resources at this level would not be expected to be complex in nature, with little to no site structure no artifact diversity. The potential for the identification of newly identified resources at such project sites would be low. A moderate sensitivity level indicates that previously recorded resources were identified with the project site and/or the surrounding area. These are more complex resources, consisting of more site structure, diversity of feature types, and artifact types. The potential for the identification of newly identified resources at such project sites would be moderate. Areas identified as high sensitivity would indicate that the record search identified previously recorded sites within the project site and/or the surrounding area. These resources may range from moderately complex to highly complex, with more defined living areas or specialized work space areas, and a large breadth of features and artifact assemblage. The potential for the identification of newly identified resources at such project sites would be high. For the proposed Midway Solar Farm I project area, based on the records search review, the potential for cultural resources within the proposed project area is low. One area in which prehistoric cultural materials appear to be concentrated in this region is the shoreline of ancient Lake Cahuilla, which would have encompassed the present-day Salton Sea. The lake covered much of the Imperial Valley and created an extensive lacustrine environment. Lake Cahuilla experienced several fill-recession episodes before it finally dried up about 300 years ago. In 1905, the Colorado River overflowed into the Salton Basin creating the present-day Salton Sea. While the project site is located within an area of recessional activity related to ancient Lake Cahuilla, based on the records search information and intensive agricultural use of the area, the potential for cultural resources within the proposed Midway Solar Farm I site is low. As the project area has not been previously surveyed, a pedestrian survey investigation of the proposed project area would need to be conducted to identify any undocumented cultural resources within the area. In the event resources are identified during the survey, avoidance would be the preferred mitigation measure. If cultural resources cannot be avoided, these resources would need to be evaluated for significance under the California Environmental Quality Act (CEQA) for inclusion in the California Register of Historical Resources (CRHR). A testing and evaluation program would need to be developed and conducted. If a cultural resource cannot be avoided and is found to be significant under CEQA, a mitigation program would be required. For archaeological resources, this typically involves a research design and data recovery excavations. Should you have any questions concerning this letter or need additional information, please feel free to contact me by telephone at (619) 233-1454 or by e-mail. Sincerely, Cheryl Bowden-Renna Archaeologist/Associate cheryl.bowden-renna@aecom.com 2

AECOM 1420 Kettner Boulevard Suite 500 San Diego, CA 92101 www.aecom.com 619.233.1454 tel 619.233.0952 fax January 7, 2011 Tom Buttgenbach 8minutenergy renewables LLC 10100 Santa Monica Blvd., Suite 300 Los Angeles, CA 90067 Dear Mr. Buttgenbach: Subject: Literature Review for the Midway Solar Farm II Project This letter report documents the literature review conducted for the proposed Midway Solar Farm II project site, located northwest of Calipatria State Prison on parcels bordered by E. Hoober Road to the north, Highway 111 to the east, W. Lindsay Road to the south, and English Road to the west, in Imperial Valley, Imperial County, California. The proposed project is located on approximately 1,222 acres of active agricultural lands. An archival records search was conducted at the South Coastal Information Center located at San Diego State University. The search included a 1-mile radius surrounding the proposed project site. The archival search consisted of an archaeological and historical records and literature review. The data reviewed included archaeological and historic site forms, historic maps, the California Register of Historical Resources, and the National Register of Historic Places (NRHP) for the project area. This research provides a background on the types of sites that may be expected in the vicinity of the project area. The research was also used to determine whether previous surveys had been conducted in the area and what cultural resources have been previously recorded within the project limits. Previous Investigations The records search indicated that 13 previous cultural investigations have been conducted within a 1- mile radius of the proposed project area (Table 1). These consist of eight environmental impact reports/studies three survey investigations (six for the Salton Sea Anomaly Project), one master plan, and one local history. Of these, only one crosses the proposed project area (Wirth Associates, Inc. 1980). Table 1. Previous Conducted Investigations within a 1-Mile Radius of the Project Area. Within Proposed Project Author Title Date Within 1-mile radius Area Imperial Irrigation Draft Environmental Impact Report for East Lowline and 1993 X -- District Trifolium Interceptors and Completion Projects. Perry, Laureen Negative Cultural Resource Survey Calipatria Proposed 2004 X -- M. Pilot Wetlands Brawley Wetlands Project 1977 X -- Von Werlhof, Jay and Sherilee Von Werlhof Wallace, Roberts, and Todd Weaver, Richard A. Archaeological Examinations of a Waste Water Treatment System for the City of Calipatria. County of Imperial Bicycle Master Plan. 1999 X -- Environmental Impact Evaluation Archaeology of the Proposed Sewer Treatment Plant for the City of Calipatria. 1974 X --

Westec Services, Inc. Westec Service, Inc. Westec Service, Inc. Westec Service, Inc. Westec Service, Inc. Westec Service, Inc. Westec Service, Inc. Wirth Associates, Inc. Appendix A History of Local Development. 1980 X -- Salton Sea Anomaly Cultural Resource Review Data- Support Package. Salton Sea Anomaly Master Environmental Impact Report. Volume I - Salton Sea Anomaly Master Environmental Impact Report and Magma Power Plant #3 (49 MW) Environmental Impact Report Appendices. Volume II - Salton Sea Anomaly Master Environmental Impact Report and Magma Power Plant #3 (49 MW) Environmental Impact Report Appendices. Final Salton Sea Anomaly Master Environmental Impact Report and Magma Power Plant #3 (49 MW) Environmental Impact Report Volume I. Final Salton Sea Anomaly Master Environmental Impact Report and Magma Power Plant #3 (49 MW) Environmental Impact Report Comments and Responses. APS/SDG&E Interconnection Project Environmental Impact Study Phase II Corridor Studies Native American Cultural Resources Appendices. 1981 X -- 1981 X -- 1981 X -- 1981 X -- 1981 X -- 1981 X -- 1980 -- X Previous Recorded Resources The records search indicated that no cultural resources have been recorded within the proposed project area or within a 1-mile radius of the proposed project area. Cultural Sensitivity Cultural sensitivity levels for project areas are rated low, moderate or high based on the results of the record searches and AECOM s past experience in the area. A low sensitivity level indicates that there are few or no previously recorded resources within the project site and the surrounding area. Resources at this level would not be expected to be complex in nature, with little to no site structure no artifact diversity. The potential for the identification of newly identified resources at such project sites would be low. A moderate sensitivity level indicates that previously recorded resources were identified with the project site and/or the surrounding area. These are more complex resources, consisting of more site structure, diversity of feature types, and artifact types. The potential for the identification of newly identified resources at such project sites would be moderate. Areas identified as high sensitivity would indicate that the record search identified previously recorded sites within the project site and/or the surrounding area. These resources may range from moderately complex to highly complex, with more defined living areas or specialized work space areas, and a large breadth of features and artifact assemblage. The potential for the identification of newly identified resources at such project sites would be high. For the proposed Midway Solar Farm II project area, based on the records search review, the potential for cultural resources within the proposed project area is low. One area in which prehistoric cultural materials appear to be concentrated in this region is the shoreline of ancient Lake Cahuilla, which would have encompassed the present-day Salton Sea. The lake covered much of the Imperial Valley and created an extensive lacustrine environment. Lake Cahuilla experienced several fill-recession episodes before it finally dried up about 300 years ago. In 1905, the Colorado River overflowed into the Salton Basin creating the present-day Salton Sea. While the project site is located within an area of recessional activity related to ancient Lake Cahuilla, based on the records search information and intensive agricultural use of the area, the potential for cultural resources within the proposed Midway Solar Farm II site is low. 2

As the majority of the project area has not been previously surveyed, a pedestrian survey investigation of the proposed project area would need to be conducted to identify any undocumented cultural resources within the area. In the event resources are identified during the survey, avoidance would be the preferred mitigation measure. If cultural resources cannot be avoided, these resources would need to be evaluated for significance under the California Environmental Quality Act (CEQA) for inclusion in the California Register of Historical Resources (CRHR). A testing and evaluation program would need to be developed and conducted. If a cultural resource cannot be avoided and is found to be significant under CEQA, a mitigation program would be required. For archaeological resources, this typically involves a research design and data recovery excavations. Should you have any questions concerning this letter or need additional information, please feel free to contact me by telephone at (619) 233-1454 or by e-mail. Sincerely, Cheryl Bowden-Renna Archaeologist/Associate cheryl.bowden-renna@aecom.com 3