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]
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
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