Introduction to the Revised Environmental Review Primer for Connecticut s Historic Properties

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Susan Matthews
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1 Introduction to the Revised Environmental Review Primer for Connecticut s Historic Properties March 20, 2012

2 The first formal revision to SHPO s Environmental Review guidance in 25 years. Dave Poirier circa 1987

3 Major Changes Guidance for the identification and assessment of a wider range of historic properties Buildings, Structures, Districts Traditional Cultural Properties Rural Historic Landscapes Underwater Resources Cemeteries Emphasis on Guidance from the Secretary of the Interior

4 Major Changes Emphasis on Consultation with Additional Parties Native American Tribes Local Preservation Organizations State Preservation Organizations Local Historic District/Properties Commissions General Public

5 Major Changes Emphasis on public interest in preservation Why is a resource significant to the public interest? How is the public interest in preservation reflected in your project? When mitigation is necessary, how does the public benefit from the treatment of historic properties?

6 Major Changes Emphasis on the development of appropriate Historic Contexts Where are the gaps in our current knowledge? Gaps may be expressed in national, state (regional) or local contexts. Evaluation of significance in local contexts are and important aspect of addressing information gaps.

7 Major Changes Additional guidance on appropriate scoping of identification, evaluation and mitigation efforts under Section 106 and the Connecticut Environmental Policy Act. The intent is to provide for both consistency in efforts while retaining flexibility to address project specific considerations.

8 Role of Qualified Professionals Projects that may affect archaeological properties should be assessed by an archaeologist. Projects that may affect historic architectural properties should be assessed by an architectural historian. Other qualified professionals may be needed depending on the types of properties anticipated.

9 All consultant submittals to SHPO must include a statement establishing the specific regulatory context of the project. It is critical that agencies and consultants understand that projects that are subject to review under CEPA may also be subject to Section 106 considerations. Identifying Section 106 responsibilities, such as the use of federal funds for state projects or requirements for federal permits, is necessary at the earliest possible stage of project planning to ensure that all consulting parties are afforded an opportunity to participate in the process.

10 Range of Historic Properties Addressed in the Revised Primer

12 Properties with Historic Engineering Significance

13 20 th Century Properties

14 Rural Historic Landscapes

Spatial organization, concentration of historic characteristics, and evidence of the historic period of development distinguish a rural historic landscape from its immediate surroundings.

15 Spatial organization, concentration of historic characteristics, and evidence of the historic period of development distinguish a rural historic landscape from its immediate surroundings. Agriculture Industry including mining, lumbering, fishculturing, and milling Maritime activities fishing, shellfishing, and shipbuilding Recreation including hunting or fishing camps transportation systems conservation including natural reserves sites adapted for ceremonial, religious, or other cultural activities, such as camp meeting grounds.

16 Traditional Cultural Properties

The consideration of Traditional Cultural Properties under Section 106 of the National Historic Preservation Act is becoming a significant part of agency, SHPO, and consultant efforts in Connecticut.

17 The consideration of Traditional Cultural Properties under Section 106 of the National Historic Preservation Act is becoming a significant part of agency, SHPO, and consultant efforts in Connecticut. All parties need to be familiar with process for identifying TCPs and the evaluation of project effects to TCPs. Early and on-going consultation with affected communities is crucial to the process. Be mindful of the Governmentto-Government relationship between federally-recognized Tribes and Agencies.

18 Archaeology Revised Primer formalizes the conventional Phases of investigation Old Primer Archaeological Assessment Archaeological Reconnaissance Intensive Survey Data Recovery Revised Primer Phase IA Phase IB Phase II Phase III

19 Phase IA SHPO emphasizes the need to involve consulting parties at this stage in the process. If Tribal Consultation under Section 106 is required, it must be initiated by the lead federal agency. Consultants may be directly involved in subsequent consultations if that is determined to be acceptable to the Tribe(s) and Agency. Federal Agencies are strongly encouraged to establish protocols for the protection of sensitive information before formal consultations are initiated. Recommendations resulting from Phase IA surveys should be supported by both field and background investigations. Phase IA surveys should result in a reasonable delineation of any archaeologically sensitive areas within the APE.

20 Phase IB There is no one-size fits all methodology SHPO recommends a minimum testing interval (spacing between shovel test pits) of 15 meters within archaeologically sensitive areas or approximately 16 test pits/acre. This assumes 50 cm by 50 cm square test pits or round test pits with a diameter of 56 cm. Smaller test pits may be appropriate, but they should be excavated at a higher density to provide an equivalent sample. Example: 50 cm diameter test pits would require a density of approximately 20 test pits/acre to achieve the target sample. SHPO does not recommend test pits smaller than 40 cm by 40 cm as the identification of cultural features and characterization of soils may be compromised.

21 SHPO does not mandate specific testing methods or levels of effort. Surveys must be tailored to the specific conditions within an APE and the types of significant resources that may be present. Where testing methods deviate significantly from the general level of effort recommended, SHPO requests that consultants contact out office to discuss the approach.

22 A Reminder! All test pits should be depicted on project maps and labeled so that other parties can readily identify them. Maps should be produced at an appropriate scale to clearly convey the location and general results of the subsurface survey.

23 Phase II SHPO recommends that most archaeological sites subject to Phase II surveys be sampled at 5 meter intervals or less. Testing must be sufficient to identify the horizontal and vertical limits of the resource within the APE. Larger excavation units may be necessary to collect sufficient information for a determination of National Register eligibility.

24 National Register Eligibility Based on appropriately developed historic context. Be specific in your research. Avoid Rules of Thumb in your assessments, i.e. Projectile points in the subsoil means it is eligible. Establish how the resource may or may not yield information important to our understanding of the past.

The nature of important information is linked to the theories or paradigms that drive the study of past societies.

26 All archeological sites have some potential to convey information about the past, however, not all of that information may be important to our understanding of the pre and post-contact periods of our history. The nature of important information is linked to the theories or paradigms that drive the study of past societies. It is important to realize that historic contexts, and therefore site significance, should be updated and changed to keep pace with current work in the discipline. NRB 36

27 Phase III Phase III excavations are an adverse effect and require a Memorandum of Agreement if the project is subject to consideration under Section 106. Agencies should demonstrate that they have considered alternatives to actions that will result in adverse effects to NReligible properties BEFORE planning for Phase III excavations.

28 Mitigation does not always mean excavation. Agencies and consultants should carefully evaluate the public benefits of any mitigation effort before pursuing any course of action. Plan for public involvement in the development of the MOA and specifically address public needs in the stipulations. Conveying the significant information gained through excavations is as important as recovering the information. Public benefits from mitigation need to address the non-professional community.

29 State Level Documentation

30 Implementation Environmental Review Primer for Connecticut s Historic Properties will be published in early April The implementation of the new standards and guidance will be phased in starting in July 2012

SHPO Position on The Roles of Archaeological Testing

SHPO Position on The Roles of Archaeological Testing Matthew H. Bilsbarrow March 17, 2003 Many excavations begin with test pits, and in fact many end with test pits. Hole and Heizer (1969:146) In general, testing is the limited examination of an archaeological