Good day everyone,
 
This message is a follow-up to my June 17 posting below that invited public
comment on a draft prototype programmatic agreement (PPA) among the Arizona
State Office of the USDA Natural Resources Conservation Service (NRCS), the
Arizona State Historic Preservation Officer, and the Arizona State Land
Department regarding cultural resources investigations for NRCS's
conservation assistance in Arizona. The draft PPA is posted on the NRCS
website at
https://www.nrcs.usda.gov/wps/portal/nrcs/detail/az/newsroom/pnotice/?cid=NR
CSEPRD1333251. 
 
My message today is to seek input to address comments NRCS has received
regarding limits that the draft PPA sets for cultural resources survey crew
size and for the maximum area that persons who are not professional
archaeologists are allowed to survey for federal undertakings. Stipulation
VI.A of the draft PPA says that persons who are not professional
archaeologists but who have completed NRCS's National Cultural Resources
Training Program (NCRTP) may lead surveys of up to 100 acres (block survey)
or up to 10 miles (linear survey) without direct supervision of a qualified
archaeologist. Stipulation VI. B says that crews led by an NCRTP-trained
surveyor shall not include trainees, Stipulation VI.C says no more than
three NCRTP-trained surveyors may survey as a crew without the presence of a
qualified archaeologist, and Stipulation VI.D says pedestrian cultural
resources surveys led by a qualified archaeologist shall be limited to crews
of no more than seven persons, including the qualified archaeologists, and
that each crew shall include no more than two trainees per qualified
archaeologist. 
 
One of the public comments NRCS has received on the draft PPA asks whether
there is something in the professional peer-reviewed archaeological
literature that tested a hypothesis that the 100-acre and 10-linear-miles
limits are needed for block and linear surveys, respectively. 
 
Another comment suggests that the number of surveyors in Stipulation VI.C be
doubled to six and that the number in VI.D be doubled to 14 including the
qualified archaeologist.
 
To help us address these comments, NRCS would appreciate hearing from anyone
who can refer us to peer-reviewed publications that have evaluated (1)
whether the size of a survey area should be limited (for example, to 50 or
100 acres for a block survey or to a certain number of miles for a linear
survey) when the survey is performed by persons who are not qualified
archaeologists but who have been trained in archaeological survey
techniques; and (2) whether survey crew sizes should be limited to certain
numbers of trainees, with or without the presence of qualified
archaeologists as the field supervisors. 
 
"Trainee" and "qualified archaeologist" as used in the draft PPA are defined
in that document's Appendix D. 
 
The NRCS training program (NCRTP) is a nine-module curriculum that includes
as well as face-to-face training. Information about the modules can be found
on the NRCS website at these links:
 
https://www.nrcs.usda.gov/wps/portal/nrcs/main/national/nedc/training/cultur
al/ 
https://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs143_024032.pdf 
https://directives.sc.egov.usda.gov/viewerFS.aspx?hid=26429 
http://www.achp.gov/docs/tribaltraining.pdf 
 
Please note that NCRTP-trained persons who are not qualified archaeologists
are only allowed to search for, identify, describe, and record locations of
archaeological sites and materials that they may find during surveys, but
are not allowed to evaluate the sites/materials for National Register
eligibility or to delineate site boundaries for avoidance. Site evaluations
and boundary delineations for NRCS undertakings must be done by qualified
archaeologists.
 
My apology for any inconvenience caused by posting this on multiple
listserves.
 
 
Thank you,
 
al
 
Allen Dart, RPA, State Cultural Resources Specialist/Archaeologist
USDA Natural Resources Conservation Service
Tucson Area Office
2000 East Allen Road, Building 320
Tucson, Arizona  85719   USA
     520-647-9056 desk, 602-908-4692 mobile, 855-848-4340 tollfree fax
      <mailto:[log in to unmask]> [log in to unmask] 


~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
 
From: [log in to unmask] [mailto:[log in to unmask]] 
Sent: Saturday, June 17, 2017 11:25 AM
To: Arizona Archaeological Council <[log in to unmask]>; 'HISTORICAL
ARCHAEOLOGY' <[log in to unmask]>; 'Archaeological Society of N.M. List'
<[log in to unmask]>; Colorado Council of Professional Archaeologists
<[log in to unmask]>; [log in to unmask]; UPAC
<[log in to unmask]>
Cc: Kristen Bastis <[log in to unmask]>; Dana Vaillancourt
<[log in to unmask]>; Steve Smarik <[log in to unmask]>;
'Mary-Ellen Walsh' <[log in to unmask]>; 'Kathryn Leonard'
<[log in to unmask]>; Ann Howard <[log in to unmask]>; Jim
Cogswell <[log in to unmask]>; Matt Behrend <[log in to unmask]>;
Lisa Atkins <[log in to unmask]>
Subject: [AAC-L] USDA Natural Resources Conservation Service seeks public
comment on draft programmatic agreement
 




The Arizona State Office of the USDA Natural Resources Conservation Service
(NRCS) seeks public comment on a draft "prototype programmatic agreement"
(PPA) among NRCS, the Arizona State Historic Preservation Office, and the
Arizona State Land Department regarding Section 106 compliance for NRCS's
conservation assistance in Arizona. The draft PPA and a notice of public
listening sessions that will be held about it in Springerville (July 11),
Tucson (July 14), and Flagstaff (July 19) is posted on the NRCS website at
https://www.nrcs.usda.gov/wps/portal/nrcs/detail/az/newsroom/pnotice/?cid=NR
CSEPRD1333251. 
 
My apology for any inconvenience caused by posting this on multiple
listserves.
 
 
al
 
Allen Dart, RPA, State Cultural Resources Specialist/Archaeologist
USDA Natural Resources Conservation Service
Tucson Area Office
2000 East Allen Road, Building 320
Tucson, Arizona  85719   USA
     520-647-9056 desk, 602-908-4692 mobile, 855-848-4340 tollfree fax
      <mailto:[log in to unmask]> [log in to unmask] 


 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
 




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