ࡱ> % bjbj [-W]8>Z\(:TTTw, F8 $% j7@wTT.TTn}6T<@ ?(Manuscript 21May2004; 6000 words) Acoustic Ecology at Husahkiw Chumash Wind Caves (CA-SBA-509) Steven J. Waller THIS IS A PRE-PUBLICATION DRAFT, SO PLEASE DO NOT QUOTE EXACT PHRASES WITHOUT PERMISSION OF THE AUTHOR, ALTHOUGH PARAPHRASING IS OK. Steven J. Waller, Ph.D., 5381 Wellesley Street, La Mesa, CA 91942 (member, American Rock Art Research Association) Acoustic measurements are presented that document the presence of strong echoes and reverberation at the Husahkiw Chumash Wind Caves rock art site (CA-SBA-509). This observation is culturally significant, since there are many myths from around the world that attest to the belief that echoes were attributed to supernatural spirits. Thus the presence of echoing at Husahkiw may have contributed to the belief that this site is sacred, and may help explain the motivation for the rock art placement there. These results are consistent with the observations of unusual acoustics at over 300 rock sites on six continents. Also documented at Husahkiw was the presence of gunshot noise from the nearby Winchester Gun Club. It was noted that the sound of these gunshots were not only significantly above background level, but also have a greater than expected auditory impact because of the amplification caused by the echoing and reverberation in the rocky amphitheater-like site. In light of the spiritual significance of echoes and the need for a quiet background to experience and practice religious rituals including those involving echoes, the disruptive and intrusive noise from gunshots near Husahkiw should be discontinued. Conservation of the natural acoustics at rock art sites including Husahkiw is urged. Accumulating evidence suggests that acoustics may help explain the motivation for the production of a substantial proportion of globally distributed prehistoric rock art, including deep cave paintings and petrogyphs etched high on canyon walls. Sound -- in the form of echoing, reverberation, and resonance (Bjork 1997; Hedges 1993; Dauvois 1996; Dauvois and Boutillon 1990; Ouzman 1997, 2001; Reznikoff 1995; Reznikoff and Dauvois 1988; Steinbring 1992; Waller 1993a, 1993b, 2000a, 2003, in press) -- appears to have been a determinate for the selection of location and subject matter for a large number of rock art sites found around the world. It is a fact known through numerous ethnographically documented myths that most ancient cultures held the belief that certain natural phenomena were caused by supernatural beings. This type of belief is categorized as animism, which is a form of personification. One complex natural phenomenon that was personified by ancient cultures is echoing, which has been explained only in modern times as reflections of invisible sound waves. Myths documented from around the world show that echoes were perceived as emanating from spirits or were considered spiritually important (see examples in Appendix). It should not be considered an affront to a culture's intelligence that echoing was personified. It is important to distinguish "intellectual capabilities" vs. the use of different paradigms or world views. To attribute phenomena of nature to supernatural spirits was a quite common paradigm in ancient times, even for intellectually-advanced cultures such as the Greeks. The reflection of sound waves is quite a complex phenomenon. For instance, if a person makes a loud enough noise while standing more than about 15 meters away from a flat or concave rock wall, that person might (if the surface is sufficiently smooth, dense and properly oriented) hear a delayed repeat of the sound coming from the wall. Yet simultaneously, a second person standing much closer to that wall would hear only the first person's original sound, and not the echoed repeat. The second person would swear that no sound came from the wall (because of insufficient time delay at that position to distinguish the closely-spaced original and reflected sounds), while the first person would swear that there was indeed sound coming from the wall. When the two people switch positions and try it again, they confirm the paradoxical (hence magical) observation of sound coming from the wall that can only be heard from a distance. That this experience of a paradoxical phenomenon could lead to thoughts and feelings of the supernatural is evident in various synonyms used to express the numinous: miraculous, mysterious, impenetrable, inscrutable, mystical, unaccountable, unguessed, unknowable, obscure, enigmatic, baffling, perplexing, puzzling, beyond understanding (Merriam-Webster, 2001). Given the propensity of ancient cultures for attributing echoes to spirits, it follows that the actual rock surfaces that produce echoes would have been considered dwelling places for those spirits. It is reasonable to theorize that locations with such echoing surfaces would have therefore been considered sacred. Characteristic sound-reflecting locations include caves, canyons, cliff faces, outcroppings and large boulders precisely the typical locations where rock art is found. One question that has baffled rock art researchers is: why are some rock surfaces selected in preference over other nearby surfaces for the depiction of petroglyph and/or pictographs? The author has found that rock art often occurs at the exact location of the source of sound reflection and/or at a good spot in which to stand for hearing an echo come from elsewhere. If acoustics were indeed an influence for the production of some portion of rock art as theorized, then those locations decorated with rock art should be expected to possess unusually strong acoustical properties relative to non-decorated locations. The possibility that the surfaces of rock art sites were decorated with images that were evoked upon hearing echoes is suggested by the authors experimental observations. For example, echoes of percussion noises such as clapping can mimic the sound of hoof beats, and hoofed animals are a frequent rock art theme. Voices appear to emanate from rock surfaces on which anthropomorphic beings are depicted. Furthermore, the literature shows that the forms mythical echo spirit beings have taken include: human males, females and children (anthropomorphs); animals such as sheep, lizards, snakes, and birds (zoomorphs); part human - part animal (therianthropes); inanimate objects such as rocks, water, relatives of lightning/thunder, the sun and moon (representational images); spirals and non-corporeal spirits (non-representational abstracts); indeed these same motifs occur globally as major rock art subject matter themes. This suggests the artists may have been attempting to depict the spirits who they felt inhabited the rocks and who were responsible for the sounds. Thus, motivation for both the context (location) and the content (subject matter) of rock art can be directly derived from the phenomenon of sound reflection via the ethnographically-documented animism of echoing. This acoustic theory does not necessarily conflict with other theories (reviewed by Bahn 1997) that attempt to explain the motivation for rock art, since sound can be an integral part of activities such as hunting magic, shamanistic rituals involving trance, etc. (see also Lever 1998). While it would be impossible to prove exactly what the ancient artists were thinking, the hypothesis that rock art occurs preferentially at sound reflecting locations is experimentally testable. The author has tested over 200 sites in France, Australia and the U.S. for sound reflection, and found echoes and/or reverberations at almost every one of them. A list of these sites, plus a large number described by other researchers as having acoustical properties, is being maintained on the Rock Art Acoustics page of the world wide web at  HYPERLINK http://www.geocities.com/CapeCanaveral/9461 http://www.geocities.com/CapeCanaveral/9461 (Waller 2004). For objective, quantitative measurements of acoustics, a device for generating reproducible impulse sounds was used in conjunction with portable electronic audio recording equipment, and analysis of the recordings was accomplished by use of sound level meters and specialized computer programs. While sounds were recorded on analog tape for most studies, some of the more recent studies have used digital equipment (Waller, Lubman and Kaiser 1999). The digital results served to confirm both the evidence from analog recordings and the subjective impressions of echoes. Acoustical testing of rock art sites has thus progressed from subjectively listening for the existence of echoes at sites, to performing objective measurements for determining if rock art occurs specifically at locations that echo best relative to the non-decorated surroundings. An analysis of acoustic data systematically collected in a portion of Horseshoe Canyon in Utah showed that the five art sites within the study area correlate exactly with the five locations within the canyon possessing the greatest intensity of echoing (Waller 2000a). The present paper reports results from an acoustic study conducted in Husahkiw Chumash Wind Caves rock art site (CA-SBA-509). This site was selected for testing because of its cultural significance to indigenous peoples, as well as its importance to the scientific community of rock art researchers, and because of complaints of intrusive noise of gunshots from the nearby Winchester Gun Club (see Appendix). METHODS The methodology used to quantitatively measure the presence of sound reflection at Husahkiw is similar to that previously described for Horseshoe Canyon (Waller 2000a). Briefly, for each test a single loud percussion noise (comparable to a natural hand clap) was produced via a spring-loaded device designed to reproducibly deliver a percussive impulse. Each experiment at each location was conducted in replicate to assess reproducibility of the impulse, intensity of the reflected sound, and echo delay time. Ambient sounds before, during and after each impulse were recorded on Type II tape with a Realistic Stereo-Mate SCP-29 Model 14-1068A portable cassette analog recorder using an (uncalibrated) omnidirectional Realistic stereo Electret microphone model 33-1065 placed one meter from the impulse generating device. These recordings were then digitized at a sampling rate of 22 kH and quantitatively analyzed for sound intensity as a function of time and frequency using SoundEdit Pro v1.0 on a Macintosh Quadra Power PC. The data was exported into MicroSoft Excel v4.0 for mathematical analysis. The average dB for each 6 millisecond interval was calculated over 0.5 to 7.5 kH, then plotted on the Y-axis, vs. time in seconds on the X-axis. During the recording, gunshots were heard coming from the direction of the Winchester Gun Club. One of these gunshots captured on the recording was analyzed in the same manner as above, except that since analysis of the frequency spectrum showed the main noise was in the lower frequency range, the average dB for each 6 millisecond interval was calculated over 0.5 to 1 kH, then plotted on the Y-axis, vs. time in seconds on the X-axis. RESULTS Acoustic measurements plotted in Figure 1 document the presence of strong echoes and reverberation at the Husahkiw Chumash Wind Caves rock art site (CA-SBA-509). These measurements substantiate the subjective impressions of the experimenter, who heard sounds echoing within the amphitheater-like canyon, and in particular heard a very strong distinct echo emanate from the decorated cave. Also documented was the presence of gunshot noise from the nearby Winchester Gun Club; see Figure 2. It was noted that these gunshots were not only significantly above background level, but also have a greater auditory impact than expected because of the amplification caused by the echoing and reverberation in the rocky amphitheater-like site. DISCUSSION This observation of strong echoes and reverberation at the Husahkiw Chumash Wind Caves rock art site (CA-SBA-509) is culturally significant, since there are many myths from around the world that attest to the belief that echoes were attributed to supernatural spirits. Therefore echoes at Husahkiw may have contributed to the belief that this site is sacred, and may help explain the motivation for the rock art placement there. This is consistent with patterns of decoration documented at over 300 rock sites on six continents. In light of the spiritual significance of echoes and the need for a quiet background to experience and practice religious rituals including those involving echoes, the disruptive and intrusive noise from gunshots should be discontinued. The use of standard acoustic measurements that average noise over periods of time from several minutes to many hours may be useful for general environmental noise, but are intuitively inappropriate for assessing the impact of loud percussion noises. Impulsive noise bursts can be startlingly loud and intrusive. It is misleading to average these noise bursts with long periods of silence, since the resulting low decibel levels are not representative of the impact on the psyche. Especially in cases where the listener is near sound-reflective surfaces such as rock walls, the effect can be to amplify the sound intensity many fold via echoing, and prolong the duration via reverberation, such that these sounds become even more intrusive and impossible to ignore. Background noise should be low in order to appreciate and hear echoes clearly. The cultural significance of echoes is shown by myths attesting to the spiritual significance of echoes; many examples of echo myths are given in the Appendix. The findings in many parts of the world of an association of acoustics with rock art, together with relevant ethnographic information, suggest that a substantial proportion of rock art around the world may have been motivated by sound. The magnitude of this proportion remains to be determined by acoustic tests such as those described herein. In view of the known spiritual significance of echoes, and the association found between echoes and the Husahkiw site, conservation of the natural acoustics at rock art sites including Husahkiw is urged. Acknowledgements. The author thanks Monique Sonoquie for her guidance and encouragement. I also express appreciation to my family Patrice, Jason and Julia for their patience and understanding. REFERENCES CITED Bahn, P.G. 1997 The First Artists (Special Report / Archaeology). In Science Year, The World Book Annual Science Supplement. Bednarik, R.G. 1994 Epistemology and Palaeolithic rock art. Rock Art Research 11:118-120. Berrier, M. 2000 Proposed Documentation and Storage of Data Related to Acoustical Phenomena at Rock Art Sites. 1999 IRAC Proceedings 1:718. Bjork, C. 1997 Why Here? Bay Area Rock Art News Vol. XV(2):1,7 Bonnefoy, Y. 1992 Greek and Egyptian Mythologies. Translated by W. Doniger, University of Chicago Press, Chicago. County of Santa Barbara 2002 San Jose Creek Baseline Conditions Report. Electronic document: http://www.countyofsb.org/project_cleanwater/Documents/SanJoseDraftWatershedPlan_AppendixD.pdf Dauvois, M. Sons et Musique palolithiques. Les Dossiers de lArchologie 142:2-11. 1996 Evidence of Sound-Making and the Acoustic Character of the Decorated Caves of the Western Paleolithic World. International Newsletter on Rock Art 13:23-25. Dauvois, M. and X. Boutillon 1990 Etudes acoustiques au Rseau Clastres: salle des peintures et lithophones naturels. Bulletin de la Socit Prhistorique Ariege-Pyrnes 45:175-1 Gill, S. D., and I. F. Sullivan 1992 Dictionary of Native American Mythology. Oxford University Press, Oxford. pp. 4,5,79. Hedges, K. 1993 Places to see and places to hear: rock art and features of the sacred landscape. In Time and space: dating and spatial considerations in rock art research, edited by J. Steinbring, A. Watchman, P. Faulstich, and P. Taon, Occasional Aura Publication No. 8:121-127, Australian Rock Art Research Association, Melbourne. Highwater, J. Ritual of the Wind. Methuen Publications, Toronto. p. 40. Jobes G. 1961 Dictionary of Mythology, Folklore and Symbols. Scarecrow Press, Inc., New York. P. 490. Lever, J. 1997 Sound Within Rock Art. In Utah Rock Art Papers Presented at the 16th Annual Symposium Vol. XVI:9/1-5, Utah Chapter ARARA, Salt Lake City, UT. Merriam-Webster Collegiate Thesaurus  HYPERLINK http://www.m-w.com/cgi- http://www.m-w.com/cgi-bin/thesaurus Ouzman, S. 1997 Hidden in the common gaze: collective and idiosyncratic rock paintings at Rose Cottage Cave, South Africa. Navorsinge van die Nasionale Museum, Bloemfontein 13(6):225-256. 2001 Seeing is deceiving: rock-art and the non-visual. Archaeology and Aesthetics World Archaeology. (in press). Reznikoff, I 1995 On the sound dimension of prehistoric painted caves and rocks, in Tarasti, E. (ed.), Musical Signification: Essays on the Semiotic Theory and Analysis of Music (Approaches to Semiotics 121:541-557), Mouton de Gruyter, New York. Reznikoff, I and M. Dauvois 1988 La dimension sonore des grottes ornes. Bulletin de la Socit Prhistorique Franaise 85: 238-246. Steinbring, J. 1992 Phenomenal Attributes: Site Selection Factors in Rock Art. American Indian Rock Art 17:102-113. Waller, S. J. 1993a Sound and Rock Art. Nature 363:501. 1993b Sound Reflection as an Explanation for the Content and Context of Rock Art. Rock Art Research 10:91-101. 1994 Taphonomic Considerations of Rock Art Acoustics. Rock Art Research 11:120-121. In press. Acoustical Characteristics of North American Rock Art Sites. American Indian Rock Art. Ms 1994. In press. Acoustical Studies of Rock Art Sites on Three Continents. In From Rock Art to Tribal Art: A Global Perspective, Chakraverty, S. (ed.), India, Ms 1994. 2000a. Spatial correlation of acoustics and rock art exemplified in Horseshoe Canyon, American Indian Rock Art 24:85-94. 2003 Conservation of Rock Art Acoustics: "Unexpected" Echoes at Petroglyph National Monument. Rock Art Papers 41 Vol 16:31-38. 2004 Rock Art Acoustics web page: http://geocities.com/CapeCanaveral/9461 Waller, S.J., D. Lubman and B. Kiser Digital Acoustic Recording Techniques Applied to Rock Art Sites. American Indian Rock Art 25:179-190. Williamson, R. A. 1984 Living Sky: The Cosmos of the American Indian. Houghton Mifflin Company, Boston. P. 99. FIGURE CAPTIONS  Figure 1. Echogram of impulse recorded at CA-SBA-509 facing the mouth of the decorated cave from a distance of approximately 50 meters. The investigational impulse sound created is plotted at 0.0 seconds. Reflected sounds show as peaks above background after 0.1 seconds; these were subjectively experienced as echoes and reverberation. The estimated reverberation time is 0.5 seconds. See Methods section for details.  Figure 2. Gunshot from Winchester Gun Club heard and recorded at CA-SBA-509. The primary impulse of the gunshot is plotted at time 0.0 seconds. Reflected sounds show as peaks above background after 0.1 seconds. The gunshot was subjectively experienced as particularly loud and intrusive due to echoes and reverberation. See Methods section for details. APPENDICES Appendix 1 Text of a 2003 publication attesting to the sacredness of the rock art site, and containing complaints about gunshots noise: THE COALITION TO SAVE HUSAHKIW - CHUMASH WIND CAVES and the Los Padres Sierra Club The Coalition to Save Husahkiw and the Los Padres Sierra Club Chapter are opposed to the further extension or renewal of the Winchester Canyon Gun Club Permit located in and close proximity and effecting ancient Chumash Sacred Sites. There are also numerous environmental issues relevant to the Coalition and general publics opposition to the further extension and/or renewal of the special use permit. CULTURAL RESOURCES The Husahkiw Chumash Wind Caves, along with the Rock Art associated with the Winchester Canyon Gun Club site is well documented as CA-SBA-509, commonly known as the Knapp site, or Indian caves. The Husahkiw site qualifies for State and National Registrar designation. It is an internationally recognized archaeological site, known to be one of the most significant in North America due to the unique polychrome images. For thousands of years the Chumash held sacred the rock shelters and caves in and immediately around the site presently occupied by the gun club shooting range. On the interior walls of these caves they created highly decorative and symbolic multi-colored rock paintings. These abstract images were created from natural pigments and may depict the artists visions of their sprit world as reviled during ritual vision quests, creatures that inhabit the earth, and tribal and personal exploits. Unfortunately, the presence of the shooting range at the site creates an unreasonably dangerous risk of harm, and exposure to lead and otherwise interferes with the rights of the indigenous peoples to access, and to express and exercise traditional religious and cultural practices. In addition, the discharge of weapons has caused serious and irreparable damage to the sacred rock paintings, and unreasonably interferes with the sanctity and quiet enjoyment of these sacred places. The American Indian Religious Freedom Act (42 USCS 1996 ) requires that American Indians have the inherent right of freedom to believe, express, and exercise their traditional religious practices, and to have unimpeded access to sites, use and possess sacred sites and objects, and have the freedom to worship through ceremonials and traditional rights without impediments. Moreover, the Act further requires that administrative practices, regulations or directives of the federal government, or agencies such as the Forest Service, not impede the inherent right of any Native American to believe, express, and exercise his or her traditional religion, or otherwise discourage the freedom of religious expression by Native Americans. All of the previously enacted protective measures taken by both the Gun Club and the Forest Service have failed to adequately and effectively protect the rock art sites from physical destruction. The further extension of , or re-issuance of the gun club permit, by its very nature constitutes a serious and significant impediment to the practices and preservation of Native American traditional values in this sensitive cultural resource area. Notwithstanding the risk of endangerment to the individuals within the vicinity of the shooting range, the noise and aesthetic impact of shooting upon traditional practices, the physical impact on the rock art paintings caused by the discharge of weapons, the nexus of the gun club facilities are inherently inappropriate, in conflict with, and substantially in interferes with and inhibits the traditional ceremonial, religious, and sacred use and preservation of these cultural resources. Such Native American sacred sites are an integral and vital part of the Native American community, tribal vitality and cultural integrity, which is so much a part of the Native American cultural renaissance. Lack of sensitivity to Native Americans heritage sites and cultural values is exactly what compelled Congress to enact legislation which restricts an agencies discretion for the sake of site specific requirements associated with the free exercise of Native American religions. Furthermore, the Forest Service in this undertaking has failed to properly comply with the notification and conference of tribal members as required by the Historic Preservation Act, 106, and failed to consult with interested parties, and the Coalition pursuant to the mandate of 36 CFR section 800 & 803 et seq. therefore the whole process is flawed. THE FOREST SERVICE HAS NOT CONSULTED WITH THE COALITION The Forest Service has not consulted with the Coalition or the general public regarding our long-standing position that the location and proximity of the Gun Club and its shooting activities are inappropriate and violate the applicable laws as previously stated above. ( The Native American Religious Freedom Act ( 42 USCS 1996; 36 CFR section 800 et seq. ) The position and concerns of the Coalition as stated on the record in this undertaking are not consistent with a No Adverse Effect determination. The unique natural acoustics and geography of the site and its nexus to the traditional religious and cultural practices by Native Americans at the site has not been adequately addressed and documented. The simple fact is the Gun Club operation and noise dramatically impacts the sanctity of the area. Simply halting the shooting by the Gun Club several days annually fails to avoid the negative noise impacts to the sacred site. The location of the Gun Club adjacent to and in close proximity to Husahkiw is akin to having a shooting range in similar proximity to the Vatican. Moreover, the Los Padres Sierra Club Chapter recently adopted an additional formal resolution endorsing the formal designation of the entire Area of Potential Effect as a State Historic Site, and further supporting the efforts of Native Americans to seek appropriate preservation of the Rock Art wind caves. Further, the Coalition is opposed to limiting Native American access to the site, as well as the interested public. Therefore, concern over the proposal to limit access to the site is opposed by the Coalition. The Coalition features prompt closure and clean up of the Gun Club, development of a Husahkiw Historic Park. The facility should include a visitor center, museum, cultural center, village site, trails, restrooms, parking and security by Native Americans. LEAD AND TOXIC CONTAMINATION FROM FIRING RANGES First of all, lead is universally recognized to be one of the most persistent and toxic substances known to man. Lead migrates readily when introduced into the environment. Shooting results in adverse noise impacts on wildlife and forest users. Shooting threatens public safety and endangers hikers, bird watchers and residents. One person was hit by an errant built while watching a forest fire from a public road. In another, instance a Gun Club employee went on a shooting rampage. Risk of fire danger is increased due to the discharge of weapons and large quantities of broken glass in and around the area. Illegal discharge of weapons has historically been associated with the shooting range, and has cumulatively resulted in the general trashing of the entire area. Anyone can access the wealth of factual informational resources on the internet relevant to the subject of shooting ranges, lead and toxic antimony, arsenic, chromium, copper, and Polycyclic aromatic hydrocarbon ( PHA) contamination which results from the operation and maintenance of outdoor firing ranges. The specific Best Management Practices and industry policies employed by various other outdoor shooting ranges, and various regulatory and governmental agencies are well known, and well published. Some of these relevant documents are attached hereto and incorporated herein as set forth in full by this reference, other relevant documents will be provided under separate cover. The Winchester Canyon Gun Club site is located in the Los Padres National Forest, approximately fifteen miles north of the Santa Barbara metropolitan area. The site is approximately five miles west of Highway 154 on West Camino Cielo. The Gun Club site comprises approximately 85 acres, in addition to lead fallout sites off the actual permitted Gun Club site. The shooting ranges and fallout zones at the site are located at the top of San Jose Creek watershed, runoff from which may contaminate plants, animals, humans, and local creeks, ground water, and ultimately Lake Cachuma, and/or the Santa Inez River. The file for this matter contains no discharge permit as required pursuant to the Clean Water Act 404. The environment in the area supports a dense chaparral growth and its accompanying fauna including but not limited to, California Ground Squirrel, Dusky-footed Woodrat, Mule Deer, Mountain Lion, Black Bear, Coyote, Gray fox, Bobcat, Raccoon, and Ring-tailed Cat. The common bird species include but are not limited to, Scrub Jay, Brown Towhee, Spotted Towhee, Red-tailed Hawk, Turkey Vulture, Valley Quail, Mourning Dove, and numerous other raptors. In addition numerous residential properties are located adjacent, and down slope from the shooting range, all of which are potentially threatened by lead contamination. Native Americans and the interested public are unreasonably threatened by exposure to lead and other toxics at the site. MITIGATION MEASURES Many established Best Management Practices which are required in order to implement proper mitigation measures and best technologies as set forth by the Environmental Protection Agencys guidelines titled Best Management Practices for Lead at Outdoor Shooting Ranges and other Best Management Practices for outdoor shooting ranges that are the industry standard are further set forth in the attachments. Best Management Practices are defined, such as discontinuing the use of lead, construction of impoundments, traps, impermeable liners, sumps, recycling of lead, use of limestone, prevention of lead migration, grading, channeling, and collection of toxics, all should be required to be implemented before consideration of any extension of the permit. The Special Use Permit should not be issued until the existing contamination present at the site is cleaned up and all of the Best Management Practices and mitigation measures are effectuated, and a sufficient bond posted, to insure proper cleanup of the site. The use of the Gun Club site as a shooting range should be discontinued entirely since this use directly impacts and deprecates the sacred rock art sites in the line of fire in that area, and constitutes an unreasonable and outrageous safety risk to Native Americans who exercise ceremonial use of those sites. POSTING OF A BOND TO INSURE CLEANUP RESPONSIBILITY One important Best Management Practice as specifically set forth in the attached relevant industry literature, is the best management practice which dictates that the Gun Club should be required to implement the best available technologies directed toward mitigation, as well as post a bond to be used to clean up the contamination already existing at the site, as well as future cleanups. Pursuant to relevant informational resources on the subject, the average outdoor shooting range can within two to three years have accumulated lead contamination equivalent to a five-acre superfund site. The Winchester Canyon Gun Club site has been in use without any clean up or mitigation measures since the 1940s, with the location of the various ranges changing over time. The site location itself is inherently unsuitable for an outdoor shooting range because it is located on steep terrain, which is covered with dense chaparral with numerous rock outcroppings rather than the typical flat range cleared of all vegetation. This presents a more complex and costly problem for monitoring , mitigation, and clean up. Further, the Gun Club has for decades failed to implement any industry standard Best Management Practices, and continues to state on the record that the Gun Club has no money for such standard industry operational costs. The Gun Club also has repeatedly complained that it cant even afford to pay the de minimus yearly fee currently charged by the Forest Service, as per the Special Use Permit. Therefore, it is suggested that the minimum bond required for an outdoor shooting range site of this size, and complexity, ( over 85 mountainous acres ) and used for over 50 years, be at least one million dollars. Otherwise, in this day and age of business entities routinely using the bankruptcy statues to escape liability, the taxpaying public will end up paying the cleanup costs for the gun club. The Forest Service would be doing a disservice to the public to continue to allow a small group of gun owners to forever destroy and pollute such an important Historic Monument as Husahkiw , just to practice shooting their weapons for recreation. A shooting range can be relocated , unfortunately Sacred Sites cannot. FAILURE OF THE GUN CLUB TO COMPLY WITH THE SPECIAL USE PERMIT TERMS The Gun Club has failed to comply with the express terms and limitations of the existing Special Use Permit and therefore no further extension, and or renewal should occur. There are numerous documented accounts of unauthorized shooting and lead testing contained in incident reports in the file regarding Gun Club members shooting shot guns and sporting clays outside the club boundaries. As well as the Gun Clubs practice of Wild West Days shooting of target dummies dressed as American Indians. The Gun Club has failed to protect the cultural resource sites, and has failed to prevent the continued desecration of the rock art. The Gun Club has also failed to implement any Best Management Practices, and/or to properly clean up the tons of broken glass and trash on the site. CONCLUSION The Forest Service attempted to perpetrate a fraud on the Office of Historic Preservation, by requesting concurrence with its alleged consultation and determination of No Adverse Effect, not only for the continued unreasonable temporary one year permits, (temporary since 1996) but for the permit for the long-term Gun Club operation before the completion of NEPA review, and the public release of an environmental assessment, and subsequent environmental impact statement. Following our letter writing efforts last month, SHPO has refused the Forest Service the ten-year No Adverse Effect finding. However, the Forest Service did receive a one-year extension No Adverse Effect letter from SHPO recently. The continued operation of the gun club shooting range, and/or extension of the special use permit is inherently depreciating of the environment, and incompatible with the long-term preservation of the adjacent Sacred Chumash Rock Art sites. Further repeated extensions of the gun club permit under the circumstances violates the express provisions of the American Indian Religious Freedom Act which bar directives or administrative practices by Federal Agencies that interfere with Indian peoples access to their historic religious sites. Further, repeated extensions of the gun club permit under the circumstances not only violates the Historic Preservation Act and applicable laws, it is clearly a bad faith effort to avoid full environmental review as required by law. The Coalition, as well as members of the public is tired of government agencies subsidizing the destructive practices of special interests groups, such as logging, mining, grazing, and shooting ranges, on public lands. The Gun Club has turned the site into a mountain of lead. The Gun Club should be required to clean up the site, so Husahkiw can finally be preserved and designated as a National Historic Site. Appendix 2 Excerpt from a report by the Count of Santa Barbara attesting to the significance of site SBA-509: Prehistoric Cultural Resources Overview: Two notable prehistoric sites along the San Jose Creek corridor are SBA-509, Indian Cave, at the head of the creek and SBA-46, Mescalitan Island, at the Goleta Slough. SBA-509 is a large north facing sandstone rock shelter associated with a smaller rock shelter, both containing rock art depictions of stylized human figures, chains of circles, anthropomorphic figures, curves, crosses, and other abstract elements. This site has extensive previous damage by modern human activity including historic debris, campfires within the rock shelter, graffiti, gunfire, and looting. The LPNF Heritage Resource Center has instituted a monitoring program for the site and installed signs and a visitor register to create an official presence at the site. http://www.countyofsb.org/project_cleanwater/Documents/SanJoseDraftWatershedPlan_AppendixD.pdf Appendix 3 Examples of myths attesting to the spiritual significance of echoes include the following: Europe: The Greek nymph Echo was thought to be responsible for repeated words (Bonnefoy 1992). South Pacific: Echo as the bodiless voice, is the earliest of all existence (Jobes 1961). North America: 3A) A Paiute legend describes witches (tso-a-vwits) living in the belly of mountain sheep and in snakeskins hidden among rocks, from which they take great delight in repeating in mockery the words of passersby. (Gill and Sullivan 1992:79). 3B) The Acoma migration story describes Masewa (son of the sun) leading the people out of the place of emergence, heading for a place called Aako. As they travel they come upon different places they suspect might be Aako. To test each one, Masewa calls out in a loud voice, 'Aaaakoooooo!'. If the echo resounds, the people stay to test the place further. If the echo is not good, they simply pass it by. At a place just east of Acoma, the echo is perfect, and Masewa announces that this is Acoma." (Gill and Sullivan 1992:4,5). (Interestingly, Petroglyph National Park is located at the eastern border of the Acoma aboriginal land claims, and was found by the author to produce excellent echoes.) 3C) A site called Wikwip in California contains rock art for which there exists ethnographic information that the paintings were made by men preparing for ceremonial dances. The site name means Echo Rock, and is derived from the sound-focusing acoustical characteristics of the cave (Hedges 1993). 3D) The Navajo Night Chant (Yeibichai) includes offering of prayers to the divinity Echoing Stone on the first day of purification (Highwater 1984). 3E) The Twin Palongawhoya (Echo) features prominently in Hopi creation myths (Williamson 1984). 3F) Diverse Native American traditions describe Talking Rocks or hold that the "rocks will speak". (Perhaps this phrase should be taken literally, since at many rock art sites one can experience words bouncing off the rock surface where the art occurs, and it does indeed give the impression that the rock is speaking.) Central America: The Aztec earth and cave god called Tepeyollotl was thought to cause echoes. South America: In Chile, rock art is found in locations associated with a mythological being known as sereno, who lives where the water sounds; also in Chile there is a rock art painting called Diablo at a site that makes a noise that frightens the villagers when the wind of a dust devil strikes the rock (Claudio Mercado, personal communication 1998). Asia: Echoes have religious significance to members of an indigenous tribe of India called the Korku. This tribe continues to produce rock art today, using echoes as a selection criteria for choosing which caves to paint (Somnath Chakraverty, personal communication 1996). 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