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A
Practical Guide To Cultural Resource
Compliance Back to New South Associates' Main
Page
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-Contents- ·
The Section
106 Process o
Phase I - The Cultural Resources Survey o
Phase II Assessment of Specific Sites o
Phase III - Mitigation of Adverse Effect ·
The Parts
of a Project o
The Proposal
o
Curation of
Artifacts and Data o
Acceptance by the
Federal Agency ·
Some Suggestions
to Ease the Process o
And a Few
Don'ts ·
A Glossary
of Useful Terms Introduction
The nation's
cultural resources are its historic buildings and structures, archaeological
sites and traditional cultural properties. Over the past 25 to 30 years,
certain sectors of the construction and engineering industries have come to
grips with these laws. These firms now realize that it is less costly to
address cultural resources early in a project and to get through the process
correctly the first time. Today, local
governments and others who have not previously been required to comply with
the federal regulations are being introduced to them. This pamphlet provides
these newcomers with a practical overview of the federal compliance process
as it is practiced in the southeast. This pamphlet
addresses the three main phases of cultural resource projects as generally practiced in the
southeast and what to expect when confronted with a letter from a federal
agency or the State Historic Preservation Officer (SHPO). The pamphlet also suggests ways to make
the process easier and less costly for all concerned. A glossary at the back
provides some help interpreting cultural resource jargon. Not all federal
agencies and states carry out their various mandates in the same way. Some
states and localities have their own cultural resource regulations to
supplement the federal laws. This pamphlet does not pretend to cover every
situation and is not an infallible guide. However, we hope it provides you
with some of the practical information you need to get the best results for
the least cost. We encourage you to contact your SHPO, and the federal agency
you are dealing with, and ask questions about the compliance process in your
particular case. New South Associates The Section 106
Process
Section 106
of the National Historic Preservation Act (NHPA) is the reason for most of the
cultural resource work being conducted in the The President's
Advisory Council on Historic Preservation (ACHP) is responsible for developing regulations to enforce Section
106 compliance. In its Citizens Guide to Section 106 Review the ACHP
states: Section 106 requires Federal
agencies to consider the effects of their actions on historic properties and
provide the ACHP an opportunity to comment on Federal projects prior to
implementation. Section 106 review encourages, but
does not mandate, preservation. Sometimes there is no way for a needed
project to proceed without harming historic properties. Section 106 review
does, however, ensure that preservation values are factored into Federal
agency planning and decisions. Because of Section 106, Federal agencies must
assume responsibility for the consequences of their actions on historic
properties and be publicly accountable for their decisions. To successfully complete Section
106 review, Federal agencies must: ·
determine if Section 106 of NHPA
applies to a given project and, if so, initiate the review; ·
gather information to decide which
properties in the project area are listed in or eligible for the National
Register of Historic Places; ·
determine how historic properties
might be affected; ·
explore alternatives to avoid or
reduce harm to historic properties; and ·
reach agreement with the
SHPO/tribe (and the ACHP in some cases) on measures to deal with any adverse
effects or obtain advisory comments from the ACHP, which are sent to the head
of the agency. How this is
actually done in practical terms in the southeastern Some of the agencies
which issue permits or financially assist projects that often fall under
Section 106 review in the southeast include: the Corps of Engineers; the
Federal Energy Regulatory Commission; the Federal Aviation Administration;
the Department of Housing and Urban Development; the Federal Highway
Administration; the Natural Resource Conservation Service; the U.S. Forest
Service; and even the Federal Deposit Insurance Corporation. Usually, the primary
federal agency becomes the lead agency with respect to cultural resources and
Section 106 enforcement. This agency is responsible for making sure that your
project does not adversely affect cultural resources until the State Historic
Preservation Officer (SHPO), Tribal Historic Preservation Officer (THPO) and other interested parties have had
a chance to comment. Each agency also may have its own rules and regulations
for compliance with Section 106 and for public involvement. Section 106 is
intended to protect significant historic properties from federal or federally
sponsored actions, and if that is not possible to mitigate the effects of the
actions. Significant historic properties are historic properties that are listed on the National Register of Historic
Places (NRHP), have been
determined to be eligible for such listing whether or not they have been evaluated, or
perhaps even identified. The following paragraphs discuss the practicalities
of how such properties are found and evaluated for significance, and how to
mitigate the impacts of construction projects on such properties. To the uninitiated,
and even to the experienced, getting through the compliance process can be
complex and frustrating. The following presents the major steps in the
process. It will also show how the process brings together the five actors in
the process: you, the federal agency, the SHPO/THPO, the public, and your
consultant. Recent regulatory changes have emphasized the position of the
public and Native Americans in the process. While the following generally
holds true most of the time in most southeastern states, you may have a
project that does not follow the norm. If you feel that you have special
circumstances, consult with the lead federal agency or your SHPO and ask
questions. Initially, you are
required to apply for a federal permit or have entered into a contract
involving federal moneys or federal land. The lead agency then notifies the
SHPO/THPO as part of the project review process. One of the first things that
must be decided is the Area(s) of Potential Effects (APE) of your project. For historic
buildings and traditional cultural properties the range of possible impacts
that help determine the APE might include visual and noise impacts
outside the actual project limits, for example the visual impacts of a cell
tower on a historic district or the noise of traffic from a new highway on
the quiet setting of a traditional Native American ceremonial site, as well
as physical destruction of buildings and traditional cultural properties by
construction activities. For archaeological sites, impacts are usually
confined to the physical limits of the subject property, and may include
direct impacts from construction excavation and use to more indirect impacts
from changes in soil compaction and erosion from nearby construction. The
federal agency in consultation with the SHPO/THPO, you and the public, must
determine the various APEs, the historic properties that they contain, and
how to mitigate the impacts to them. While the federal
agency is only required to "make a good faith effort" to locate and
consider historic properties, most agencies and states have, through custom
and practice, developed a three-staged approach to achieving this good faith
effort: identification of the resources present in the various APEs; evaluation
of their significance; and mitigation of impacts to the significant
resources. The first phase is
usually accomplished through background research
and a field survey, the second phase is the assessment
or evaluation of specific properties, and the third is mitigation of adverse impacts
on significant properties, including traditional cultural properties (TCPs). These are normally called Phases I,
II, and III in the southeast. These terms sometimes cause confusion, because
in some regions a preliminary Reconn is called Phase I or Ia, and an intensive survey is called Ib or
II, sometimes survey and testing are combined into a single phase and called
Phase II. In nearly all cases, however, mitigation of adverse impact is
called Phase III. While the ACHP's
regulations go into some detail on scoping projects as the first step to implementing
Section 106, in practice, most projects do not have a long drawn out scoping
process as this would add significant time and cost to projects. Only on
larger, more complex projects, such as reservoirs, new highways, and gas
pipelines is there usually a clear scoping phase. Since SHPOs and agencies
are overwhelmed and under-budgeted as it is, the more they can standardize
the common project types (road widenings, small developments affecting
wetlands, cell towers, etc.) the easier and faster, and thus less expensive,
it is for all concerned, while at the same time insuring that a "good
faith effort" has been made to consider historic properties. Phase I - The
Cultural Resources Survey
The purpose of a survey is to gain an understanding of what is
present within the project area and whether any of the archaeological sites,
historic buildings and structures or traditional cultural properties (TCPs) may be significant resources. TCPs
are a relatively new concept in the East, and there are no hard and fast
rules about how they are dealt with. Most states require that archaeological
resources be examined by an archaeologist and that buildings be examined by
an architectural historian. A survey is designed to find all such properties
that will be affected by a project, and failing that, all significant
resources. The survey usually
consists of various parts that are sometimes accomplished separately, and
thus at a higher cost to the client, or accomplished together as a single
survey project. The first step in a survey is background research on what is
already known and recorded about the historic properties in the project area.
Such research normally includes: examination of the state archaeological site and historic structure files, which contain a list of
previously recorded archaeological and historic sites in the state; general
background research on the prehistory, history, and environment of the project area to provide a
context within which to evaluate any newly discovered sites or buildings; and
informal interviews with other archaeologists and historians who may have
worked near the project area, and with local experts and inhabitants who may
know the locations of TCPs and otherwise undocumented sites. In areas with a
Native American presence, it is necessary to consult with them through the
proper channels even if they do not have a THPO. Once this is
completed, a brief inspection of the project area may be made separately or
incorporated into a more intensive field survey. This brief inspection,
sometimes called a reconnaissance, is usually not sufficient to satisfy
federal or SHPO/THPO requirements. These require that all significant sites
and structures affected by a project be identified. However, a reconnaissance
can be useful in certain cases. It may be advantageous to conduct a brief
reconnaissance of all the alternative locations for a project to see which may
have the least impact on cultural resources. This, when considered with other
environmental variables such as wetlands and endangered species, provides a
more objective basis for selecting the final alternative. The intensive survey
must be of sufficient intensity to locate all significant historic properties
in the project area. Archaeological sites are located in several ways. A
common method is surface survey, but this is only acceptable in areas where
the ground surface (i.e., bare earth) is visible. The survey crew lines up at
evenly spaced distances and walks transects, closely inspecting the ground surface for artifacts or topographic
anomalies. In areas of heavy ground cover, such as is commonly found in the
eastern As sites are
located, the field crew records them on project maps, and enters appropriate
information on site forms. The archaeologists may also collect artifacts at
this time to determine the age and function of an archaeological site. Normally, it is not
possible, nor is it the intent of a survey, to completely define the
horizontal extent, the depth, the period of occupation, the state of
preservation, and therefore the significance of a site during an intensive
archaeological survey. In such cases, assessment
or testing of specific sites found during the survey may
be recommended to provide sufficient information for the regulatory agencies
to determine their significance. A survey of historic
structures will normally involve consultation with historic maps of an area.
Information from the maps will be compared to the existing buildings in the
project area to help determine which are of the proper age to be considered
historic. All buildings older than 50 years will receive some form of
documentation in most states. In most southeastern states this means
completing a state historic building form and 35 mm photographs of the
building and its setting. In others, a visit to each building may be video
taped for presentation to the review agencies. Normally, a survey does not
involve visiting the interior of houses, sketching floor plans, drawing sketch
maps, writing detailed architectural descriptions, or researching chains of
title and other detailed historic documents. It is impossible to
realistically budget for such detailed work until a survey has determined the
number of buildings requiring such comprehensive work. Unlike
archaeological survey, it is expected that a historic building survey will
result in eligibility statements for all historic buildings found, along with
recommendations for mitigation of impacts. To assess historic structures the
architectural historian must collect detailed information about the property,
its ownership and its history; photograph it; describe the structure, any
additions and outbuildings; provide a floor plan, map the structures and
surrounding landscape; and discuss the site's significance. At the conclusion of
the survey you should receive a report with recommendations for any Phase II
or Phase III work. You should submit this report to the lead agency for
approval of the recommendations before doing any more work. It is possible
that the lead agency, in consultation with the SHPO, will require more or
less Phase II work than is recommended by your consultant. Phase II -
Assessment of Specific Properties
This phase usually
requires a separate proposal and contract. Most historic buildings will have
been assessed during the initial survey. For archaeological sites whose
significance could not be determined during the identification phase,
evaluative testing usually means digging more, and more closely spaced, shovel
tests to define the length and width of the site. It will also usually
include transit mapping of the site and excavating several square test
excavations or units. The test units examine the soil stratigraphy, gather artifacts for dating and functional analysis, and determine the site's state of preservation. With these
data, the significance of an archaeological site can be judged, and if the site is
significant, data are readily available upon which to base a research design
for mitigation. Historic
archaeological sites frequently require additional historical research. A
qualified historian should conduct this work, normally consisting of
researching a chain-of-title on the property to discover who owned and
occupied the site, and when. The researcher will also determine what records would
be available if data recovery were to be conducted. On urban sites it is critical that
extensive historic map research be conducted to determine how the area
developed. The presence of a good chain-of-title, census, probate, and tax
records will aid greatly in understanding the site's significance. At the conclusion of
testing, you should receive a report with conclusions on the eligibility of
each site tested and recommendations for any further work. Avoidance of
significant sites should be one of the recommendations. You should submit
this report to the lead agency, in consultation with the SHPO, for approval
of the recommendations before doing any more work. If the lead agency
determines that a site is EligibleNRHP for the National Register of Historic Places (NRHP), you will probably need to mitigate
any adverse impacts to the site. It is possible that the lead agency will
require more or less work than is recommended by your consultant. If the lead
agency determines that Phase III work is required, you should obtain a
memorandum of agreement (MOA) in consultation with the agency, the SHPO/THPO and the ACHP.
The memorandum of agreement should spell out what is required of you during
Phase III. Phase III -
Mitigation of Adverse Effect
" Mitigation of adverse effect " means to alleviate any destructive impacts your project
may have on the historic property. This may take various forms. Some mitigation measures are
relatively inexpensive and take little time, while others are not. If you can
find a way to avoid the site and not affect it at all, this may be best. But
you usually must also convince the lead agency and the SHPO/THPO that you
will not affect the property in the future. This is, of course, the least
expensive form of mitigation. If you cannot avoid
and protect the property, then you may be required to mitigate
your impacts. Recently, there has been much discussion of the new buzzword,
"creative mitigation", which might mean developing a video on the
property or cultural resources for school children, donation of collections
or preparation of a display to a local museum, preparing a traveling exhibit
concerning the property. The ACHP
regulations see the mitigative process as a consultive process that allows
for and encourages great leeway in the actual details. If the site consists
of architecturally or historically significant
standing structures, you may be able to have them properly
recorded to the Historic American Building Survey or Historic American
Engineering Record (HABS/HAER) standards (i.e., measured drawings, measured floor plans, and
large format photographs) or some other standard before moving or demolishing
them. For an archaeological site you may be asked to go to data
recovery. If archaeological data recovery is chosen for
mitigation, this means digging large areas by hand or by a combination of
hand- and machine-assisted excavation. If the site is historic then the
historic documents consulted during the testing phase will need to be
obtained and analyzed by a qualified historian. The final report of the Phase
III work is more extensive than the other phases since this report is the
only record of the site once it has been destroyed by construction. Consultants,
agencies and even SHPOs sometimes propose another form of Phase III work.
This is monitoring. Monitoring usually involves the presence of a single
archaeologist during the earth moving portions of construction, who watches
for significant cultural resources. Initially, this may seem to be an
inexpensive alternative to avoidance or data recovery or some other form of
archaeological data recovery. In reality, it rarely is. In the few states
where monitoring is acceptable to the SHPO, the archaeologist has the duty to
stop construction if a site that may be a significant resource is found. The
lead agency then determines whether the resource is significant. If the
resource is determined to be significant, data recovery may delay a project
for months in the middle of construction. This is obviously more costly than
simple avoidance or data recovery alone, since there are unknown construction
delay costs involved. The Parts of a
Project
This discussion has
so far concentrated on the field portion of the survey, testing or data recovery work. In the following, we will discuss the parts of projects,
primarily archaeological projects that are the same for all three phases. The Proposal
Whether you use a
single consultant, or put a project out for bids, you should always ask for a
written proposal. A proposal normally describes what the potential consultant
understands to be the tasks involved and the general limits of the project.
It should clearly state what the consultant will do and why. It should also
contain a schedule showing project milestones. The main project milestones
usually are: completion of fieldwork; completion of laboratory work;
completion of the draft report; and completion of the final report. The
proposal should indicate the qualifications of the responsible individuals
assigned to the project. It should also describe the qualifications and
facilities of the consultant, whether these are a garage or a formal office
and laboratory. Once you have chosen
your consultant, you should include the proposal as a part of the signed
contract. The contract should also clearly state how and when the agreed upon
fee is to be paid. A single payment may be reasonable for projects of less
than a month. For larger projects, it is customary to pay by milestones met
or by work accomplished on a monthly basis. Background Research
This research varies
in intensity depending on the type of project conducted, as noted above.
Failure to conduct such research may mean that work will be duplicated, or
previously recorded information will not be considered early enough in the
project. This may end up causing cost overruns; or even worse, the lead
agency or the SHPO/THPO may not concur with the consultant's report. Field Work
This is usually the
easiest phase to budget and schedule, but it is relatively labor-intensive.
As far as overall project scheduling, the fieldwork is usually about one
third of the total of an archaeological project. Archaeologists do most of
their work in the laboratory and in front of a computer. Analysis
To be able to write
a final report, the consultant must analyze the artifacts, drawings, maps,
photographs, and other data collected during the historic research and
fieldwork. While more artifacts and data will be collected during a Phase III
project than a Phase I or II, all the artifacts have to be washed, cataloged,
labeled, analyzed and eventually curated. The analysis
answers such questions as: where do the different types of
artifacts come from within the site? how old are they? how did they function?
and what does all of this tell us about who used and discarded the artifacts?
This work is slow and painstaking, and indeed, often takes longer than the
fieldwork. Report Preparation
The archaeologist
normally begins the project report toward the end of the analysis phase. This
report is ultimately the product that you are purchasing from the consultant.
A report usually consists of the following parts: a cover; a title page; an
abstract; acknowledgments; a table of contents; an introduction; a discussion
of the cultural and environmental setting of the project area; a discussion
of the methods employed; a discussion of the results; a set of conclusions
and recommendations; a list of references cited; appendices; and all
pertinent photographs, maps, and drawings. The introduction
should include the reasons for conducting the work and the objective of the
project, against which the remaining chapters can be placed in perspective.
The project setting will include the data gathered during the background
research and will frame the research criteria by which the significance of
sites can be determined. The discussion of methods and results should clearly
state what was done and how, so that the validity of the results can be
judged. The report must discuss the results in sufficient detail so that the
reader (i.e., the lead regulatory agency, the SHPO/THPO and the client) can
independently come to the conclusions reached at the end of the report. This
includes sufficient photographs, maps and drawings so that the reader has a
complete understanding of what was accomplished. The report must present
conclusions that clearly follow from the supporting data. Of most importance
to you are the recommendations. The background research, the project results,
and the conclusions must fully support the recommendations. Recommendations
will normally concern the significance of sites relative to the National Register
eligibility criteria, and what further steps are necessary
to comply with regulations. If a Phase II or III is recommended, it must be
justified, and the steps to accomplish the recommended work should be stated
clearly. You should be able to use such recommendations as the basis of a
request for proposals for the additional work. You should also be able to
understand the conclusions and the reasons for them. After all, this is not
rocket science. The appendices
should include, in most cases, a complete inventory of the artifacts found by
the project and where they were found. Many states also require that the
proposal, resumes of key project personnel, and any state site forms be submitted either
as appendices within the report or separately. Draft and final
versions of the final report are common on most large projects and on
virtually all Phase II and III projects. On most large projects you must
submit the draft to the lead federal agency and the SHPO/THPO for comments
before producing the final version, which should incorporate or address these
comments. Artifacts should not be curated and the project is not complete
until the final report is accepted by you and the lead agency in consultation
with the SHPO/THPO. You may require a
management summary at the end of the fieldwork, especially for testing and
data recovery projects. This report is written after the fieldwork is
completed and before the analysis is well underway. The purpose of this short
report is to provide you with the preliminary conclusions about the project
to aid you in planning for future work. It may also allow the lead agency to
determine that the fieldwork was sufficient to grant clearance of a site
before the final report is submitted. This does not waive the laboratory
analysis and final report, however. Such clearance should allow construction
to proceed. The possibility of obtaining clearance after the data recovery
field phase and before a final report is completed also requires a close
relationship with the SHPO/THPO during the project, along with adequate
fieldwork. Even though the final decision belongs to the lead agency, most
agencies usually accede to most SHPO/THPOs' requests. Curation of Artifacts and Data
The last thing to do
on a project is to permanently curate the artifacts and project notes and
data. These must be curated in perpetuity, which is usually taken to mean
that they be stored by a museum, university or state agency. The proposal
should discuss the responsibility for curation and identify the curation
facility and attendant costs. Acceptance by the
Federal Agency
Once you have been
able to show that you have completed an adequate survey of archaeological and
historical sites in your project area, assessed their significance, and
mitigated any adverse impacts to them, the lead federal agency should
officially notify you that you have satisfied the Section 106 process has been
satisfactorily completed, and you may continue with your project. Some Suggestions to
Ease the Process
-Some Do's-
DO - Start Early in the Process. By taking cultural
resources into account early in the process, it may be possible to avoid
problems down the road. With planning, you may be able to creatively
interface cultural resources with construction plans. DO - Contact the SHPO/THPO Early and Often. Do not hesitate
to talk to your State Historic Preservation Officer representative. This
person is knowledgeable about the applicable laws and procedures in your
state. The SHPO/THPO staffs are more than willing to work with you to
understand the process, provide advice, and in some states, provide you with
a list of consultants. They may even help you select the proposals that
appear to minimally satisfy their requirements. However, they are not
businessmen and usually have little experience with labor laws, overhead, and
safety regulations. DO - Consider the Possibility of Tax Savings. In some areas
certain types of repairs to commercial structures listed on the National Register can be
deducted from federal taxes. It may also be possible to donate the artifacts
and project data to a non-profit organization for a tax deduction. See your
tax attorney. DO - Put Projects Out for Bid. If there is time for a
formal bid procedure, do so. You will gain the best results and prices if you
submit your work to competitive bidding. Let your consultants know that all
three phases of the project may be competitive. Unfortunately, some
consultants will offer unreasonably low estimates for Phase I, expecting to
make up for their losses by charging higher fees for subsequent phases. Such
consultants are more likely than a reputable firm to recommend marginally
significant sites for more study in Phases II or III. If you are comfortable
with your consultant's prior work and ability to meet lead agency and
SHPO/THPO review, you should use a non-competitive process. But if you are
new to cultural resources, it is definitely to your advantage to submit your
work to competitive bids. DO - Select a Reputable Firm. Most cultural resource
consulting firms have staffs consisting of at least Principal Investigators, Archaeologists, Historians, Architectural Historians, Technicians or Research Assistants. Some firms are too small or inexperienced to bid or respond
properly to the needs of their clients, or even to have their reports pass
agency and SHPO/THPO review causing project delays. Other firms put their needs
or the perceived needs of archaeology ahead of their client and are not willing to talk about ways to
trim costs while doing an acceptable job. Consideration should be given to a
firm that maintains good relations with the SHPO/THPO and regulatory
agencies, and yet understands budgets, schedules, and working with you and
your special circumstances. A minimum requirement you might consider when
selecting an archaeological consultant might be the Register of Professional
Archaeology (RPA) certification for
the principals in the consulting firm. Some states now require such
certification or its equivalent. You might also contact the American Cultural
Resources Association (ACRA) for a list of members in the disciplines you need. ACRA
members subscribe to a professional code of business ethics. DO - Expect to Understand. You should require that you
receive an understandable proposal and report of the project. Do not accept unintelligible
jargon. The basic concepts and procedures of archaeology and history are not
difficult to understand. If you do not understand your consultant or the
SHPO/THPO, ask for a response in plain English. You need to know in a
proposal what will be done, why, when, and for how much. You do not need a
degree in archaeology or history to understand these things if they are
clearly stated. Make sure you understand the goals of the project, how they
will be achieved, and what could happen next. DO - Provide As Much Information As Possible. The more
information you supply to prospective bidders about the circumstances of the
project and the project area (maps, notes, letters from the SHPO/THPO, other
reports, etc.) the better. The consultant will be able to respond to your
request for proposals in a cost-effective manner with such information.
Keeping potential consultants in the dark is ultimately self-defeating.
Encourage questions from consultants to maintain the best communications
possible about your needs. DO - Require Regular Contact. On large projects you might
consider requiring written monthly progress reports. Weekly telephoned
reports might supplement the formal monthly reports. These reports should
give you a good idea of how the work is progressing, whether the project is
on schedule, and prepare you early in the project for any unforeseen problems
or delays. DO - Require an Executed Contract. Before commencing any
work you should have a contract that clearly states what the goals of the
project are, and how these are to be achieved. You should also have a
schedule, a budget, and the names of the principal personnel assigned to the
project. This is to protect you and the consultant. On projects with a
potential public liability, you might consider having your contract require
current professional and general liability insurance certificates. DO - Consider Cost-Plus Contracts. If the scope of work is
clearly defined, a lump-sum contract may be cost-effective. When there are
significant unknowns in a project, which is often the case in archaeology,
consider a cost-plus contract with a not-to-exceed amount. This is only good
risk management. Base this amount on clearly understood quantities of
fieldwork (person days, the number of excavations, or the collection of
certain types or amounts of data, etc.) With lump sum contracts two things
usually happen. First, reputable firms make their best cost estimate and add
a little to cover unforeseen contingencies. They expect to stick to the
agreed upon price. Other firms come in too low, just to get the project.
Sooner or later they demand more money or produce work that does not pass
muster with review agencies. DO - Work Closely with Your Consultant. A reputable firm
encourages questions and is willing to explain what is happening and why.
Archaeologists are naturally hesitant about making hard conclusions about the
archaeology until the laboratory work is completed. On the other hand, they
should be willing to work with you to give you the best service for the
money. DO - Request a Management Summary after Data Recovery. In
situations where you are required to conduct a data recovery project (often a
large scale excavation or HABS/HAER documentation), explore the possibility of having your
consultant work closely with the SHPO/THPO during the fieldwork. The
SHPO/THPO may be able to convince the lead agency to grant you clearance at
the conclusion of the fieldwork, and before a final report is submitted and
approved. This will not negate the need for laboratory analysis or a final
report, but will allow you to begin construction much more quickly. DO - Consider the Judicious Use of Heavy Equipment. Some
archaeologists have an unfounded fear of using heavy equipment on
archaeological sites. In many cases, the use of such equipment is not only
less expensive and quicker, but will actually produce more and better
archaeological information. DO - Provide No or Low-Cost Items. If you have low-cost
housing available for field crews or have access to heavy equipment or
transportation, consider providing these to the consultant at no cost. Since
housing and heavy equipment are usually pass-through costs for consultants,
this will not change their balance sheets, but could save you thousands of
dollars. DO - Use the Project for Public Relations. Archaeological
sites and projects, particularly in urban settings, bring out the curiosity
in many people. Since you are required to do the project anyway, obtaining
some good public relations at the same time is a bonus. You might consider
contacting local television stations and newspapers, as well as local
archaeological and historical societies. You might also consider some form of
public involvement on larger data recovery projects, tied in with the local
school system. On larger more interesting projects, it is possible to produce
an inexpensive brochure, a continually updated website, or perhaps even a
video, for the public summarizing the project. Artifacts displayed in local
museums or, perhaps, in a lobby of a newly constructed building, frequently
go a long way toward maintaining good public relations. Your consultant can
do many of these things for little additional cost to the project. DO - Get Involved. By asking questions and periodically
visiting the site, you may learn a lot about local prehistory and history.
Believe it or not, archaeology and historic preservation can be interesting.
At the same time you may learn enough to make your next project more cost
effective. -And a Few Don'ts-
DO NOT - Select a Consultant By Price Alone. You will probably
get what you pay for. DO NOT - Make Arbitrary Demands. Archaeologists in some
government agencies think that by being very explicit about the fieldwork
(the numbers of holes, exact locations of excavations, etc.) they will
receive superior proposals. However, this is not often the case. Such
arbitrary limits set by a single archaeologist usually do not allow for a
creative approach to your situation. A creative approach might be cheaper and
faster, and still address the concerns of the lead agency and SHPO/THPO. A Glossary of Useful
Terms
ACRA: (American Cultural Resources Association)
Incorporated in 1995, ACRA is the only national trade association organized
to promote the professionalization of the cultural resource industry and all
its disciplines. Visit http://www.acra-crm.org for more information. (New South was instrumental in founding
ACRA and currently houses the executive directorship.) ACHP: (Advisory Council on Historic Preservation)
The President's Advisory Council carries out the mandates of the National
Historic Preservation Act of 1966, as amended. They have a very good site with much useful and detailed information concerning the
Section 106 process and the roles of the various players, with brochures and
guidelines for various procedures. Analysis: The archaeological study of the properties of
artifacts and other objects (e.g., bones and seeds), their associations, and
their provenience. This involves the cataloging and labeling of the
artifacts, as well as special studies such as floral and faunal analyses. APE: (Area of Potential Effect) This is the area in
and around the project area that may contain cultural resources that will be
affected by the project. There may be differing APEs for historic buildings,
traditional cultural properties and archaeological sites. For historic
buildings and traditional cultural properties the range of possible impacts
might include visual and noise impacts outside the actual project limits, for
example the visual impacts of a cell tower on a historic district or the
noise of traffic from a new highway on the quiet setting of a traditional
Native American ceremonial site, as well as physical destruction of buildings
and traditional cultural properties by construction activities. For
archaeological sites, impacts are usually confined to the physical limits of
the subject property, and may include direct impacts from construction
excavation and use to more indirect impacts from changes in soil compaction
and erosion from nearby construction. The federal agency must determine the
various APEs, the historic properties that they contain, and how to mitigate
the impact within them. Archaeological Technician or Research Assistant: A person, usually with a B.A. degree in anthropology, or
equivalent experience, who does the archaeological field and laboratory work. Archaeology/Archeology: The study of the undocumented remains of the
past, also the techniques used in such studies. Among American
archaeologists, archaeology is commonly divided into prehistoric and historic
(after the arrival of Europeans in the New World) periods. Architectural
Historian: An individual
with a degree in the history of architecture capable of identifying the age,
style, and social context of historic buildings. Artifact: Any object made or modified by man. Assessment: The process of determining whether a site or
structure is significant. Also called Phase II. (See Testing.) Background Research: The first step on a project wherein previously recorded
information (whether archaeological, historical, cartographic, etc.) is
sought about the project area. Cataloging: Making a list or catalog of the artifacts
found during a project. Cultural Period: A period of
time that has similar artifacts, social organization, and other factors, and
is located within a defined geographic area. The major Cultural Periods of
the Eastern United States are the Paleoindian, the Archaic, the Woodland, the
Mississippian and the Historic. Cultural Resources: A term coined with the appearance of historic
preservation laws in the 1960s and 1970s, and intended to mean all
archaeological and historical properties and data, including traditional
cultural properties, in a given area. Data Recovery: Term meaning a large scale excavation of an
archaeological site; the detailed recording of structures; or the gathering
of extensive historic data on a site. Data Recovery is conducted during Phase
III. Eligible for the NRHP: Term meaning that a
site or structure is intact, significant, and appears to meet one or more of
the National Register of Historic Places Significance
Criteria even though it is not actually listed. Excavation Block: Term meaning a large
square or rectangular area of ground, usually excavated by hand in smaller
sections, or squares, called units. Feature: Soil discoloration or arrangement of artifacts
in the soil that represents past human activity. Examples are postmolds,
privies, trash pits, building foundations, builders' trenches, and burials. Field
Director/Supervisor: A person
usually with an M.A. degree in anthropology, or equivalent experience, who is
capable of the day-to-day supervision of an archaeological project under the
overall direction of a Principal Investigator. Floral or
Ethnobotanical Analysis: The study of
seeds, and sometimes pollen (palynology) and larger plant remains. Faunal or
Zooarchaeological Analysis: the study of non-human bones and animal remains from
archaeological sites. HABS/HAER: Historic American Building Survey and
Historic American Engineering Record. Two national agencies that set the
standards for recording standing architecture and historic structures such as
bridges and canals. Historic Property: term used by the National Historic
Preservation Act and the President's Advisory Council on Historic
Preservation to indicate archaeological sites, buildings, structures, and
traditional cultural properties that are historic in nature, often considered
to be over 50 years old. Integrity/Intact: Terms used to mean that all parts or major
portions of a site are undisturbed. In situ: A term that refers to an artifact that is
still in the location where it was discarded or left by an occupant of a
site. Labeling: Writing numbers on artifacts, which identify
the provenience of the artifact and occasionally the type of artifact. Level: A horizontal layer of soil in a unit that is
usually excavated together, although it may be excavated in sub-levels. A
level may be arbitrary (10 cm deep, for example) or natural (yellow sandy
clay, for example). Listed on the NRHP: A historic property that has been nominated
to the National Register of Historic Places and has been officially accepted.
(See Eligible for the NRHP) A complete list of historic properties on the National
Register can be found at http://www.cr.nps.gov/nr/research/index.htm Memorandum of
Agreement: (MOA) a formal
agreement among the lead federal agency, the SHPO/THPO, the project owner,
and the Advisory Council on Historic Preservation about the steps to be taken
to mitigate adverse impacts to National Register listed and eligible
properties. Mitigation: Term meaning to alleviate the adverse effects
of project construction. Mitigation may take the form of data recovery
(thereby obtaining the data contained in the site) or avoidance (thereby not
affecting the site at all). Also referred to as Phase III. NHPA: (National
Historic Preservation Act) An act passed in 1966 to govern
federal involvement in cultural resource management. NHPA includes Section
106. Nominated to the
NRHP: a site that appears
eligible for nomination and which has been formally nominated, but not yet
accepted. NRHP: (National Register of Historic Places) A
listing of historically or archaeologically significant sites maintained by
each state. The NRHP does not contain all significant sites. It only lists
those currently identified and that the owner has allowed to be listed. There
are many eligible sites that have not been registered, either because they
have not been found or they have not yet been nominated. Phases I, II, and
III: Terms corresponding to the normal
phases of a cultural resource project in the southeast. Phase I is survey (to
locate sites in a project area); Phase II is evaluative assessment or testing
(to determine significance of sites in a project area); and Phase III is
mitigation (to mitigate the adverse effects of construction on significant
sites). Potentially Eligible
for the NRHP: An informal designation for sites found during survey that
appear to be significant and therefore eligible for the NRHP, but which
require further evaluation to be certain. Prehistory: Term dealing with the archaeology of
preliterate peoples. Principal
Investigator: A person, usually with an M.A. or PhD. degree or extensive
experience, who designs research projects and oversees the field and
laboratory tasks, and has the principal responsibility for preparing the
report. Projectile Point: Jargon for arrowhead. Archaeologists
like to point out that such objects may have been used on darts and lances,
etc., and that a particular artifact may not have been used on an arrow. Preservation: The degree to which the environmental
conditions of a site have preserved bone, seeds, shell and other organic
material. Provenience: An individual location in three-dimensional
space within an archaeological site. Reconnaissance: A very preliminary walkover of a site to see
if it requires more intensive survey. It sometimes includes background
research and a written report of findings. Remote Sensing: A set of field techniques that permit the
location of underground features and/or concentrations of artifacts without
excavation. To date, remote sensing techniques have limited usefulness since
excavation is still required to obtain artifacts for analysis purposes,
although this is changing. Remote sensing techniques often represent an
unnecessary added cost to a survey project or where excavation will be
required anyway. However, these techniques are often useful in locating
burials in cemeteries, to help pinpoint where to excavate or on sites where
virtually nothing is known of the occupation. RPA (Register of Professional Archaeologists): A
national certification organization for professional archaeologists. Some
states are currently requiring that cultural resource projects be conducted
by RPA-certified or equivalent archaeologists to help insure that research is
conducted satisfactorily. Visit http://www.rpanet.org for more
information. Section 106: The section of the NHPA dealing with the
enforcement of federal preservation activities. Ground-disturbing activities
that involve a federal permit, land, funding or other assistance fall under
Section 106. The President's Advisory Council on Historic Preservation's
implementing regulations for Section 106 can be found at 38CFR800. Shovel Test: (Shovel Test Pit, ST, STP, etc.) a survey and
testing method used to determine the horizontal limits of a site where ground
cover prevents examination of the ground surface. These are usually the size
of a shovel and are dug to sterile (no artifacts) soil. Soil is usually
screened to find artifacts. SHPO: (State Historic Preservation Officer) The
federally mandated person and office responsible for federal cultural
resource compliance at the state level. Every state has one, with a staff
that varies in size and specialties. There is usually at least one
archaeologist and one architectural historian on the SHPO's staff. Significance
Criteria: The criteria listed
in the NHPA, which, if answered affirmatively, indicate
that a site is significant and eligible for the NRHP. Also called eligibility
criteria. Significant: Term used to refer to a cultural resource
that is important in local, regional, and national prehistory or history, or
which is likely to yield answers to current research questions in archaeology
and history. Site or Archaeological Site: A frequently vague term used to describe a horizontal and
vertical area of ground that has been used intensively by people in the past
and which contains or is likely to contain artifacts and features associated
with that past activity. The actual boundaries of sites may be based on the
density of features and artifacts or on other criteria. State Site Files: The state repository where completed state
site forms are kept. This is sometimes at the SHPO, and sometimes elsewhere. State Site Form: Forms filled out by
archaeologists on archaeological sites. All southeastern states have an
accepted statewide form, and most SHPOs are presently requiring that these be
filled out at the completion of cultural resource projects. Stratigraphy: The soil levels and strata at a site and how
these are associated with each other and the cultural aspects of the site
(artifacts and features, etc.). Survey: A phase of archaeological investigation
during which surface collection and limited subsurface techniques are
employed to identify archaeological sites or their absence. Also referred to
as Phase I. TCP: (Traditional Cultural Property) Holy places,
ceremonial sites, and other traditionally important places, often associated
with Native American groups, but could be any cultural group. Testing: A phase of archaeological investigation that
assesses the horizontal and vertical extent of a particular site, its degree
of preservation, and its potential for containing significant data. It
usually involves STPs and Test Units. Also referred to as Phase II assessment
or evaluation. Transect: Term used to define the location of a line
followed by archaeologists during survey and testing. THPO: (Tribal Historic Preservation Officer) Here
used to mean the federally mandated person and office responsible for federal
cultural resource compliance on federally recognized tribal lands, or other
person designated by the tribe to represent its cultural interests. Tribal
equivalent of the SHPO. Unit or Test Unit: a formal hand excavation, usually one or two
meters square or three, five, or ten feet square. When combined, units are
referred to as an excavation block. Back to New South
Associates' Home Page
Copyright 1992 by
New South Associates, Inc.
Revised 2006. |
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