This harkens back to the early days of 106 where survey was performed by people with little to no knowledge of archaeology with horrible results. Archaeologists with a BA have gone through somewhat rigorous training and can in theory identify artifacts, read landscapes, comprehend simple to complex strata and understand nuances of terrain that might require deep testing. The crux of the issue is the end result. A survey produces artifacts at the most basic and far more info beyond the most basic, so the result is that a manager type might “influence” a no further work recommendation without a deeper contextual understanding of the artifacts or much of anything else. Archaeologists generally operate under a Code of Ethics that is not necessarily operational with non-professionals.
The big picture view of the “nose of the camel under the tent” approach that is proposed is a significant dumbing down of professional archaeological responsibilities of all of us in the profession. the old argument that you don’t go to a plumber when you need brain surgery is applicable here.
On the other hand, it behooves archaeologists to understand big picture CRM wherein not every single site is “lying in front of the bulldozer” worthy, or the usual negation of ethical responsibility by “recommend further work”. The real issue is that the next level up in competence in the proposed scheme is not going to know as much about a site as a professional by virtue of not having seen it and thus being forced to work with incomplete data. Survey acreage size has zero relationship to site importance.
That said, there are multiple states with avocational archaeology programs that provide training for people who are interested. Virginia is one such example. Arkansas is another. Both are related in their avocational training origins.
A BA, MA, PH.D. degree is akin to a union ticket and not a guarantor of archaeological expertise. There are avocationals who have, can and do find sites that are significant under 106. And there are degreed archaeologists who fail to comprehend site significance outside their areas of expertise. Excluding both ends of the competence spectrum, hiring a professional archaeologist is definitely going to be less expensive in the long run. What the managers are really looking for is for someone to guide them through the 106 process and not some newbie who finds every single site of some importance. This approach may lead to less cost in the short run, until a significant site is encountered and all the king’s horses and all the king’s men cannot undo a supremely stupid mistake by someone who did not his area.
Lyle Browning, RPA
> On Aug 16, 2017, at 11:08 PM, Al Dart <[log in to unmask]> wrote:
>
> Good day Mr. Davis and colleagues,
>
> As yet I have not learned of any peer-reviewed publications that have
> evaluated either whether the size of a survey area should be limited when
> the survey is performed by trained persons who are not archaeologists or
> whether survey crew sizes should be limited to certain numbers of trainees
> with or without an archaeologist in direct supervision.
>
> I don't have any hard figures about what percentage of surveys completed by
> the NRCS in Arizona would be covered by the proposed limit of acreage or
> linear distance but would estimate that it would be less than 50%. Many of
> NRCS's conservation effort here are brush management projects to improve
> grasslands for cattle grazing and most of the study areas for those projects
> exceed 100 acres, so must be surveyed with a qualified archaeologist in the
> lead. I appreciate your suggestion of identifying and comparing other
> states that might allow nonarchaeologists (as specified in the Arizona PPA)
> to conduct fieldwork without professional archaeologists in the lead, thank
> you. I wasn't doubting your word that other states may require anyone
> conducting an archaeological survey to have certain minimum qualifications
> including specific degrees.
>
>
> 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
> [log in to unmask]
> ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
>
> -----Original Message-----
> From: HISTORICAL ARCHAEOLOGY [mailto:[log in to unmask]] On Behalf
> Of Davis, Daniel B (KYTC)
> Sent: Tuesday, August 15, 2017 6:26 AM
> To: [log in to unmask]
> Subject: Re: USDA Natural Resources Conservation Service seeks public
> comment on draft programmatic agreement
>
> Mr. Dart,
> I'm not certain of the number of peer-reviewed publications that would show
> the efficacy of non-archaeologists conducting survey based on the size of
> the survey area - I suspect that it would be very limited, though
> potentially informative. Any idea what percentage of surveys completed by
> the NRCS in Arizona would be covered by the proposed limit of acreage or
> linear distance? I can say that, for the KYTC it would be close to 100%,
> though our surveys tend to be primarily linear. Your best bet would be
> identifying other states that allow non-archaeologists (as specified in the
> Arizona PPA) to conduct fieldwork and comparing the results to surveys of
> similar size and in similar terrain conducted using only archaeological
> staff. I suspect you will have more luck with western than with eastern
> states.
>
> In Kentucky the PPA between the SHPO and the NRCS references the SHPO's
> specifications for qualifications for conducting a survey. The PPA can be
> found here:
> http://www.achp.gov/mwg-internal/de5fs23hu73ds/progress?id=YtYEIHUh-kqGpfWoR
> uVbIyfYJjaCv1XyIodDD-7cMuI, and I have been informed by the SHPO's office
> that the minimum qualification for conducting a survey under the agreement
> is a bachelor's in anthropology, archaeology, or a related field. So you
> don't have to take my word for it, the SHPO's specs are included in the back
> of the PPA, but here's a straight link to the SHPO's specifications
> http://heritage.ky.gov/NR/rdonlyres/5757C6A1-E8E0-4B5E-BE0F-7AF5B78C6BF1/0/2
> 006FieldworkCRspecs.pdf and here is a link to those of the Transportation
> Cabinet (starting on page 26 for archaeologists and cultural historians)
> http://heritage.ky.gov/NR/rdonlyres/5757C6A1-E8E0-4B5E-BE0F-7AF5B78C6BF1/0/2
> 006FieldworkCRspecs.pdf
>
> If you find anything, I'd like to see it on the list here. I'd love to run
> some comparative stats for that.
>
> Thanks,
>
> Daniel B. Davis
> Administrative Branch Manager, Cultural Resources Section Kentucky
> Transportation Cabinet Division of Environmental Analysis
> 200 Mero Street
> Frankfort, KY 40622
> (502) 564-7250 or (502) 782-5013
> KYTC Archaeology and KYTC Cultural Historic
>
> -----Original Message-----
> From: HISTORICAL ARCHAEOLOGY [mailto:[log in to unmask]] On Behalf
> Of Al Dart
> Sent: Saturday, August 05, 2017 2:11 PM
> To: [log in to unmask]
> Subject: Re: USDA Natural Resources Conservation Service seeks public
> comment on draft programmatic agreement
>
> In his post to the Historical Archaeology listserve below, Mr. Davis
> indirectly raises the important point that standards for cultural resources
> management vary from state to state. That likely was part of the reason the
> National Historic Preservation Act of 1966 (NHPA) established in every state
> a State Historic Preservation Officer with whom federal agencies are
> required to consult for federal undertakings in that state, rather than
> relying on a single, independent federal agency such as the Advisory Council
> on Historic Preservation (ACHP) to be the arbiter for all projects that
> might affect historic properties nationwide. The Arizona SHPO, which is a
> party to the Natural Resources Conservation Service (NRCS) prototype
> programmatic agreement (PPA) regarding cultural resources investigations for
> NRCS's conservation assistance in Arizona, has approved the use of people
> who aren't archaeologists but who have been trained in archaeological survey
> techniques to do land inspections (surveys) to IDENTIFY* cultural resources
> that might be affected by NRCS-assisted (funded) projects, and Arizona's
> SHPO has agreed to the 100-acre and 10-mile maximum limits on areas those
> individuals are allowed to survey without direct supervision of a qualified
> archaeologist. We understand that other states have tighter limits on the
> amount of training required for approval to lead archaeological surveys and
> on the maximum acreages that someone who is not a qualified archaeologist
> (another term for which definitions may vary from state to state) is allowed
> to survey independently; and that some states (e.g., Kentucky, according to
> Mr. Davis) require a degree in archaeology or a related field, and some
> require more field experience for persons to lead surveys than is required
> in the Arizona NRCS-SHPO PPA.
>
> To reply to Mr. Davis's query about how this agreement came about: Section
> 800.14(b) of the 36 CFR Part 800 regulations for implementing Section 106 of
> the NHPA allows federal agencies to enter into programmatic agreements (PAs)
> with the ACHP to govern the implementation of a particular program or the
> resolution of adverse effects from certain complex project situations or
> multiple undertakings. Such Pas may be used when effects on historic
> properties are similar and repetitive or are multi-state or regional in
> scope; when effects on historic properties cannot be fully determined prior
> to approval of an undertaking; when nonfederal parties are delegated major
> decision-making responsibilities; where routine management activities are
> undertaken at federal installations, facilities, or other land management
> units; or where other circumstances warrant a departure from the normal
> Section 106 process. A PA between the ACHP and NRCS is appropriate because
> NRCS's conservation-assistance program involves some complex project
> situations and multiple undertakings; the effects of NRCS undertakings on
> historic properties are similar, repetitive, and multi-state in scope; and
> the effects of NRCS undertakings on historic properties cannot be fully
> determined prior to approval of an undertaking. Therefore, in 2014 the NRCS
> national office, the ACHP, and the National Conference of State Historic
> Preservation Officers (NCSHPO) entered into a "prototype programmatic
> agreement" that is to serve as the model for each individual NRCS state
> office to create a PPA with that office's SHPO and with Indian tribes or
> Native Hawaiian Organizations in each state who claim cultural or religious
> interest in the state's historic properties. The draft PPA among the NRCS
> Arizona State Office, the Arizona SHPO, and the Arizona State Land
> Department is an example of a PPA that has been developed at the state level
> in accordance with the national NRCS-ACHP-NCSHPO PPA. (Visit
> https://www.nrcs.usda.gov/wps/portal/nrcs/detail/az/newsroom/pnotice/?cid=NR
> CSEPRD1333251 to read the Arizona draft PPA.)
>
> The difference in CRM standards nationwide wasn't the point of my August 4
> post, however. In it, I was (and still am) seeking references 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. Any such
> references that readers can refer us to would be appreciated.
>
>
> * As I noted in my August 4 post to the listserves (see below),
> 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. Any archaeological features or
> artifact concentrations they find that might meet Arizona's minimum
> definition of an archaeological site must be recorded by a professional
> archaeologist, and the professional is responsible for evaluating whether
> the find is eligible for the National Register.
>
>
> 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
> [log in to unmask]
> ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
>
> -----Original Message-----
> From: HISTORICAL ARCHAEOLOGY [mailto:[log in to unmask]] On Behalf
> Of Davis, Daniel B (KYTC)
> Sent: Friday, August 4, 2017 10:26 AM
> To: [log in to unmask]
> Subject: Re: USDA Natural Resources Conservation Service seeks public
> comment on draft programmatic agreement
>
> Good morning/afternoon (depending on your time zone), So two people who
> aren't archaeologists but who have had a training course and a one day field
> school of sorts can undertake survey with no actual archaeologists, as long
> as the survey area is less than 10 miles in length or 100 acres in size? I'm
> curious, do archaeologists only find sites on larger projects? If most of
> the surveys conducted by NRCS are less than 100 acres or 10 miles in length,
> this just seems to greatly increase the chance for something to go terribly
> awry. How often will a professional archaeologist be employed to conduct
> surveys, based on this agreement?
>
> The minimum requirement to conduct any level of survey here in KY is a
> bachelor's degree in anthropology or archaeology, along with a year of field
> experience, so I'm sort of curious as to how this agreement came about. I
> think I missed the initial request for public comment, so pardon me if I
> seem a little taken aback.
>
> Thanks,
>
> Daniel B. Davis
> Administrative Branch Manager, Cultural Resources Section Kentucky
> Transportation Cabinet Division of Environmental Analysis
> 200 Mero Street
> Frankfort, KY 40622
> (502) 564-7250 or (502) 782-5013
> KYTC Archaeology and KYTC Cultural Historic
>
> -----Original Message-----
> From: HISTORICAL ARCHAEOLOGY [ <mailto:[log in to unmask]>
> mailto:[log in to unmask]] On Behalf Of Al Dart
> Sent: Friday, August 04, 2017 12:44 AM
> To: <mailto:[log in to unmask]> [log in to unmask]
> Subject: Re: USDA Natural Resources Conservation Service seeks public
> comment on draft programmatic agreement
>
> 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=N
> R>
> 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/cultu
> r>
> 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://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs143_024032.pdf
> <https://directives.sc.egov.usda.gov/viewerFS.aspx?hid=26429>
> https://directives.sc.egov.usda.gov/viewerFS.aspx?hid=26429
> <http://www.achp.gov/docs/tribaltraining.pdf>
> 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]> mailto:[log in to unmask]>
> <mailto:[log in to unmask]> [log in to unmask]
>
>
> ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
> From: <mailto:[log in to unmask]> [log in to unmask] [
> <mailto:[log in to unmask]> mailto:[log in to unmask]]
> Sent: Saturday, June 17, 2017 11:25 AM
> To: Arizona Archaeological Council < <mailto:[log in to unmask]>
> [log in to unmask]>; 'HISTORICAL ARCHAEOLOGY' < <mailto:[log in to unmask]>
> [log in to unmask]>; 'Archaeological Society of N.M. List'
> < <mailto:[log in to unmask]> [log in to unmask]>; Colorado Council of Professional
> Archaeologists < <mailto:[log in to unmask]>
> [log in to unmask]>; <mailto:[log in to unmask]>
> [log in to unmask]; UPAC < <mailto:[log in to unmask]>
> [log in to unmask]>
> Cc: Kristen Bastis < <mailto:[log in to unmask]> [log in to unmask]>; Dana
> Vaillancourt < <mailto:[log in to unmask]>
> [log in to unmask]>; Steve Smarik <
> <mailto:[log in to unmask]> [log in to unmask]>; 'Mary-Ellen
> Walsh' < <mailto:[log in to unmask]> [log in to unmask]>; 'Kathryn
> Leonard'
> < <mailto:[log in to unmask]> [log in to unmask]>; Ann Howard
> < <mailto:[log in to unmask]> [log in to unmask]>; Jim Cogswell
> < <mailto:[log in to unmask]> [log in to unmask]>; Matt
> Behrend < <mailto:[log in to unmask]> [log in to unmask]>; Lisa Atkins <
> <mailto:[log in to unmask]> [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=N
> R>
> 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]> mailto:[log in to unmask]>
> <mailto:[log in to unmask]> [log in to unmask]
>
>
> ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
>
>
>
>
> __._,_.___
> _____
>
> Posted by: "Al Dart" <
> <mailto:[log in to unmask]:[log in to unmask]>
> [log in to unmask] <mailto:[log in to unmask]> >
> _____
>
>
>
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