well said.
Linda Derry
Site Director, Old Cahawba Archaeological Park
Alabama Historical Commission
9518 Cahaba Road, Orrville, AL 36767
park: 334/ 875-2529
[log in to unmask]
On Thu, Aug 17, 2017 at 5:57 PM, Lyle Browning <[log in to unmask]> wrote:
> 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]> >
> > _____
> >
> >
> >
> > Community email addresses:
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> AAC-L
> > Link to AAC Home Page:
> > <http://www.arizonaarchaeologicalcouncil.org/>
> > http://www.arizonaarchaeologicalcouncil.org/
> >
> > <http://geo.yahoo.com/serv?s=97476590/grpId=361641/grpspId=
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