DoD Memo #2 – The 4 Sites of Historic Significance Identified at Andy South “Will Not Be Affected” by Buildup Plans


Guam – The Department of Defense has determined that 4 properties of historic significance identified at Andersen South in Mangilao will not be impacted by the possibility of future construction related to the military buildup.

A new memo, Memo #2, concerning the ongoing review of historic sites on Andy South, states that “no historic properties will be affected by the proposed action.”

A release from NAVFAC Pacific advises that the new Memo #2 [along with the earlier Memo #1] is available for review on the  Cultural  Resources Information  (CRI)  website  at   Public comment is encouraged.

The posting of these memos is required  by the Programmatic Agreement in order to allow the public to provide comments on the identification and evaluation of historic properties. And the Programmatic Agreement also requires that DoD allow for a 45 day period to receive and evaluate public comments. 

Memo #1 posted, on August 16 2013, identified the 4 historic sites and concluded that these 4 sites are eligible for listing in the National Register of Historic Places.

* Historic Property 1 is a Latte Period artifact scatter.
* Historic Property 2 is a Latte Period artifact scatter.
* Historic Property 3 is comprised of displaced, bulldozed remnants of a Latte set.
* Historic Property 4 is a Latte Period ceramic scatter.

NAVFAC says no comments on Memo #1 were received from the public on these ancient and historic Chamorro sites. The only comments received came from the Guam Historic Resources Division (GRHD).

Memo #2, posted this past Friday, October 10th,  refers to GRHD’s comments and provides DoD’s responses to those comments.

* Comment 1 – concurred with the DoD that the above mentioned sites are eligible for listing in the National Register of Historic Places.

* Comment 2 – requested clarification regarding the 15 foot buffer around each of the sites shown on the accompanying PA memo map.

DoD Response: The size of the buffer was chosen based upon the type and condition of historic property, general topography of the area and the nature of the proposed work, which involves only geotechnical and topographic studies and possibly, munitions of explosive concern (MEC) removal.

Comment 3 – stated that the reports cited in PA Memo #1 are a compilation of reports and not the original survey reports that indicated the area of study.

DoD Response: The reports cited in PA Memo #1 do in fact comprise the original survey documentation for all four historic properties in the proposed APE.

Comment 4 – stated in part that reconnaissance surveys with no subsurface testing should not be considered as complying with Section 106.

DoD Response: 36 CFR §800.4 (b)(1) does not require subsurface testing to meet Section 106 compliance to identify historic properties. Rather, it clarifies that “The agency official shall make a reasonable and good faith effort to carry out appropriate identification efforts, which may include background research, consultation, oral history interviews, sample field investigation, and field survey.”

Further, the Advisory Council on Historic Preservation (ACHP) also states that regulations “do not require the identification of all of the archaeological sites within the area of potential effects (APE). Rather, federal agencies are expected to make a “reasonable and good faith effort” to identify historic properties, including archaeological sites listed or eligible for listing on the National Register in the APE.

DoD’s Determination of Affect:

The DoD has determined that no historic properties will be affected by the proposed action for the following reasons:

1. No ground altering disturbance or other activity affecting any characteristic which makes the four historic properties in the project area eligible for listing in the National Register of Historic Places will occur.

2. Prior to the onset of the work described in this memo, each historic property will be relocated by the DPRI CRM, who will establish a 15 foot protective buffer around each of the four historic properties and supervise the placement of high visibility vinyl fencing.

3. As per PA stipulation VI.F., the DPRI CRM will provide site checks to ensure the protective site buffers have not been breached.

The full report can be viewed at NAVFAC’s Cultural  Resources Information  (CRI)  website  at

Comments must be submitted within 45 calendar days. The comment deadline for the proposed “Andersen South Future Defense Policy Review Initiative Project Design Studies ” are due Nov. 25, 2013.

Those without internet access may pick‐up a written description of this project and a mail‐in comment sheet from the Guam Historic Resources Division located within the Department of Parks and Recreation at 490 Chalan Palasyo, Agana Heights (across from U.S. Naval Hospital Guam).