USAEC Environmental Performance Assessment System (EPAS) Installation Cultural Resources Program Administrative Assessment SOP

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Anthony Haynes
5 years ago
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1 USAEC Environmental Performance Assessment System (EPAS) Installation s Program Administrative Assessment SOP Purpose: Using all documentation available, many cultural resource Environmental Performance Assessment System (EPAS) assessments can be completed using administrative assessments with a focus on assisting the installation on determining best management practices and corrective actions for any negative findings that result from the EPAS assessment. This procedure standardizes the method for conducting administrative assessments of the s Program at installations undergoing an EPAS assessment. Selection of Installations: Installations will be selected to have an administrative assessment (vs. an on-site assessment) based on the complexity of the cultural resources managed and recommendations from the IMAE-IS subject matter experts (SME). Recommendations from SMEs, which will at a minimum take into account the criteria below, will be taken into consideration when determining if an administrative assessment is appropriate. Determination of an administrative assessment vs on-site assessment will be evaluated based on the following criteria by the SME: - Complexity and status of known cultural resources compliance actions and associated mitigation (if applicable) within last three years. - Review of current Integrated s Management Plan (ICRMP), to include future and anticipated projects (both O&M and MILCON) requiring consultation under federal regulations and AR Preliminary phone discussion with the installation s s Manager to ascertain the current status of the cultural resources program. - Preliminary status update of consultations with federally-recognized tribes with an interest in the installation under evaluation, if applicable. - Performance of the s media area at prior EPAS assessments. Administrative Assessment Process: 1) Prep work: Your EPAS team leader will request all documents in Attachment 1 for you during the scoping visit. If the TL is unable to obtain all the necessary documents, the SME will coordinate with the installation environmental POC prior to the assessment to obtain any remaining documents. Coordination with functional area POCs at the installation may be necessary to obtain additional documentation necessary to complete the assessment.

2 2) Complete a basic review of documentation necessary to provide an overall evaluation of the installation s cultural resources program. Assessors should use the Cultural Resources Program Checklist (Attachment 2), to ensure adequate coverage of the installation s program. 3) Complete a review of the installation s ICRMP, consultation letters with state and federal regulators, tribal consultation documentation, any executed programmatic agreements and/or memorandum of agreements, and curation agreements, past EPAS reports and findings, and other relevant documents as applicable to the installation. 4) Conduct telephone interviews with appropriate installation representatives and other cultural resources program stakeholders. Telephone interviews are necessary to verify that SOPs and planned activities noted in the ICRMP, and other plans reviewed, are being programmed for and executed. 5) Complete EPAS software entries and Media Out Brief: a. Starting in fiscal year 2013 administrative assessors will be required to complete the administrative assessment one week prior to the on-site assessment as directed by the Team Lead. This will ensure that the installation staff is available to support both the administrative portion of the assessment and the on-site portion of the assessment. b. Communicating during the assessment. The cultural resources EPAS assessor should communicate fully with the EPAS TL, Installation cultural resources POC, and other installation representatives in the same way as an on-site assessment. Any issues, concerns, or potential cultural resources findings will be raised to the EPAS TL on a daily basis during the assessment. c. The TL should also be advised of the work schedule of the assessor daily. If the assessor has no EPAS activities to complete on any given day during the assessment, the TL should be notified. The designated cultural resources EPAS assessor will be available the entire week of the assessment to answer any questions and handle any issues that may arise on an as-needed basis. d. The cultural resources media summary will be written by the cultural resources assessor and include an annotation that an- administrative assessment was performed. Identify in the media summary what aspects of the program were reviewed and the evaluation approach used. The media summary should also include statements about what the cultural resources assessor was able to validate or not validate through the administrative assessment e. Findings will be input in the EPAS software by the cultural resources assessor to document any negative findings. The finding assessor comment field for each finding should contain the following statement: A cultural resources administrative assessment was performed. This information will help with making data/trend analysis. Findings can be entered prior to the on-site period or at the same time as the on-site assessors at Team Lead discretion. f. A cultural resources assessment out brief will be scheduled and conducted via teleconference with the cultural resources POC, EPAS TL, and other installation

3 representatives, as necessary, following the same process used for on-site assessments at the close of the assessment.

4 Attachment #1: Review Documents for Administrative and In-Person EPAS Assessments of Cultural Resource Programs ICRMP to include historic property inventory and supporting documentation (concur ltrs) Previous EPAS Reports Archeological site forms and maps, if necessary National Historic Preservation Act (NHPA) Memorandums of Agreement (MOAs) and Programmatic Agreements (PAs) NHPA mitigation documentation in accordance with NHPA MOAs and PAs Section 106 documentation for planned construction (including maintenance, demolition, rehabilitation, etc.) activities: findings of no historic properties affected, findings of adverse effect, SHPO concurrence letters, etc. National Environmental Policy Act (NEPA) list of projects National Register of Historic Places (NRHP) Nominations and SHPO correspondence Standardized Operating Procedures (SOPs) ARPA permits Curation inventories and agreements Inventory of historic properties Accuracy of Integrated Facilites System (IFS) which transitioned to the General Fund Enterprise Business System or GFEBS) historic property status codes Cultural resources reports, contracts, and scopes of work Tribal consultation letters and other documentation, such as letters demonstrating Government-to-Government consultation, Comprehensive Agreements, Plans of Action, Memoranda of Understanding, files relating to Native American Grave Repatriation Act (NAGPRA) consultation, etc.) (NAGPRA review should be consistent with type of collections and should provide 1:1 cross-walk between cultural items and their disposition.)

5 Status of on-going or unresolved noncompliance issues (as applicable) s Management Plan (ICRMP) Attachment #2: s Administrative EPAS Assessment Checklist Description Checklist Item Requirement Verify that corrective measures were implemented, since the negative findings of prior EPAS reviews CR.1.1.US. Verify that ICRMPs are developed for use as an internal planning tool. Verify that the ICRMP is revised and approved by appropriate command levels at least every 5 years. See Active Army CR.1.6.A. Personnel/Communication Mission Support Program Management Verify that a federally employed cultural resources manager responsible for s Program Management is appropriately trained (DODI ) Verify that there is a process that implements early coordination between the CRM and all staff elements, tenants, proponents of projects and actions, and other affected stakeholders to allow for proper identification, planning, and programming for cultural resource requirements. Verify that SHPO and others are consulted with in association with the identification of historic properties. Verify cultural surveys include the identification and evaluation of resources against National Register criteria by an SOI qualified professional. DOE(s) must be approved by DAC Verify that current and planned installation programs, plans, and projects are integrated and compatible with the s Program Verify that the installation avoids adversely affecting properties that are 50-years old or older that have not been evaluated for eligibility against NHPA criteria. Treat (assume) all sites are eligible until the SHPO concurs with the federal finding of non-eligibility for the NRHP Verify a systematic approach to ensuring that prior to the start of a new undertaking, Federal agencies are required to take into account the effects of the undertaking on historic properties. Verify an up-to-date listing of historic properties is CR.5.2.US., CR.5.3.US., Active Army CR.1.3.A., CR.1.10.A.; See Active Army CR.1.8.A.,, CR 5.1.US., CR.5.2.US., CR.5.4.US., Active Army

6 Program Execution Tribal Consultation Program (as applicable) maintained and historic status is maintained in conjunction with real property inventory Verify that the installation maintains an up-to-date listing of all historic (NRHP eligible and listed) properties, and where applicable, maintains historic status in conjunction with real property inventory and reporting guidelines. Verify that all NHPA compliance documents are coordinated through the chain of command to obtain HQDA technical and legal review prior to execution. Verify that alternatives are considered for historic properties, including reuse, when they are not needed for projected installation mission requirements. Verify an economic analysis is done on all National Register (eligible or listed) properties that are being considered for demolition and/or replacement. Verify that there is consultation with tribal governments before taking actions that affect Federally-recognized Indian Tribes. Verify that there is consultation with Federallyrecognized Indian Tribes to provide access to sacred sites on Army installations. Verify that reasonable notice is provided to Federally recognized Indian Tribes when proposed actions may adversely affect or restrict access to the ceremonial use of, or the physical integrity of, sacred sites. Verify that access to sacred sites to allow the practice of traditional religions, rights and ceremonies is provided consistent with appropriate health, safety mission constraints. Verify that the physical integrity of sacred sites is not adversely affected. Verify that a government-to-government relationship with Federally-recognized Indian Tribes has been established as needed. Initial formal government-to-government consultation with Federally-recognized Indian Tribes will occur CR.5.2.US., Active Army CR.5.3.A., CR5.4.A., CR.5.2.US., CR.10.1.US., Active Army CR.10.1.A., CR.15.1.A.,

7 Curation Agreements/Compliance Archaeological Site Protection and NAGPRA Compliance only between the Garrison Commander and the heads of tribal governments. Follow-on activities may be accomplished by staff. Verify that museum objects and documents are identified and preserved. Verify that installations maximize the use of offinstallation facilities that are better able to provide for adequate long-term curatorial services for archaeological materials from Army lands, where possible. Verify archaeological collections meet specific curation standards per 36 CFR 79. Verify that searching for or collection of historic properties (including archaeological resources) is prohibited on Army installations except when authorized by the GC and pursuant to a permit issued under ARPA. Verify that information concerning the nature and location of any archaeological resource for which the excavation or removal requires a permit or other permission under ARPA or under any other provision of Federal law is not disclosed to the public. Verify that all NAGPRA cooperative agreements are coordinated through HQDA prior to execution Verify that the consultation process associated with intentional and inadvertent discoveries follows regulations and procedures. CR.20.2.US., CR.20.3.US., CR.20.4.US., CR.20.5.US., CR.20.6.US., CR.20.7.US., US., Active Army CR.20.1.A. CR.15.2.US., CR.15.3.US., CR.15.4.US., CR.15.5.US., CR.15.6.US., CR.15.7.US., CR.15.8.US., CR.15.9.US., CR US., CR US., Active Army CR.15.2.A., CR.4.A.,

Bureau of Land Management is the lead federal agency (available online at:

Bureau of Land Management is the lead federal agency (available online at: PROGRAMMATIC AGREEMENT AMONG THE BUREAU OF LAND MANAGEMENT, THE OFFICE OF HISTORIC PRESERVATION, AND THE ADVISORY COUNCIL ON HISTORIC PRESERVATION, REGARDING RENEWABLE ENERGY DEVELOPMENT ON A PORTION OF