Commission accepts pedestrian survey for Willits cell tower with discovery clause; urges stronger documentation of mineral‑soil observations

The Mendocino County Archaeological Commission accepted a pedestrian archaeological survey for a proposed 65‑foot “monopine” cellular facility northwest of Willits, approved adding a discovery clause, and admonished the consultant to provide clearer mineral‑soil observations or conduct shovel testing in future surveys.

The use permit application (USE‑2024‑0004) from SELCO Partnership proposes a 65‑foot tall cell tower in a 40‑by‑40‑foot lease area on a parcel at 28401 Timberline Road (parcel 037‑700‑14). Applicant agent Matthew Moore said a survey report by EBI Consulting recommended a finding of no historic properties in the project area. EBI archaeologist Chris Grant confirmed he conducted a pedestrian survey and submitted the report.

Commissioners pressed Grant on field methods. Several commissioners asked whether shovel testing or mineral‑soil observations had been completed; Grant said the work was a pedestrian survey and that shovel testing had not been conducted. Commissioners emphasized that a valid survey must document mineral‑soil observations (exposing native soil) or include subsurface shovel testing where surface visibility is limited. The commission discussed project disturbance estimates: the lease area is 40 by 40 feet with an existing access and utility easement and an estimated 5,600 square feet (0.42 acres) of ground disturbance across the site and access route.

After discussion the commission voted to accept the survey with the condition that a discovery clause be included in permit conditions; the motion passed with a 3–0 vote (one commissioner recused due to involvement with the project). Commissioners additionally directed the archaeologist to include more explicit mineral‑soil observations or to perform shovel testing in future surveys when surface visibility is poor.