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]] On Behalf Of Al Dart
Sent: Friday, August 04, 2017 12:44 AM
To: [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=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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