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-kqGpfWoRuVbIyfYJjaCv1XyIodDD-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-7AF5B78C6BF1/0/2006FieldworkCRspecs.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-7AF5B78C6BF1/0/2006FieldworkCRspecs.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]
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
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