Interagency Cultural Programs Meeting for Cultural Consultants 9:00am-12:00pm State Capital Building Auditorium 3/22/2011

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1 Interagency Cultural Programs Meeting for Cultural Consultants 9:00am-12:00pm State Capital Building Auditorium 3/22/2011 Agency representatives (speakers / contributors): Byron Loosle, BLM state archaeologist, Utah State Office Byron_Loosle@blm.gov Jeanette Matovich, BLM archaeologist, Utah State Office Jeanette_Matovich@blm.gov Laurel Glidden, BLM district archaeologist, Cedar City District Laurel_Glidden@blm.gov Kenny Wintch, SITLA state archaeologist kennywintch@utah.gov Betsy Skinner, UDOT cultural resource program manager eskinner@utah.gov Kelly Beck, PLPCO/governor s office, state archaeologist kellybeck@utah.gov Kevin Jones, Division of State History state archaeologist ktjones@utah.gov Ron Rood, Division of State History assistant state archaeologist rrood@utah.gov Ari Leeflang, Division of State History archaeology records manager ALEEFLANG@utah.gov Will Reed, USFS Region 4, regional heritage program lead. wgreed@fs.fed.us I. Utah Bureau of Land Management (BLM) key topics (Byron Loosle) a. There is confusion regarding compliance with BLM policy and guidance. The technology and standards for data collection listed in the 2001 handbooks are obsolete. BLM is currently updating the policy and guidelines, which will be integrated into updated handbooks, available TBD, depending on how this field season goes. b. Digital data will replace hard copies. Base data (photos, maps, site forms, GIS), and records and project reports, data is shifting to electronic vs. hard copies, and will be more easily accessible. c. Federal priorities that have changed as a result of the Obama administration: A new National Programmatic Agreement may not be developed after all, despite a two-year revision process. Stay tuned Some administration policies, like youth involvement, don t always directly affect consultants. Other changes, like renewable energy, impact their workload. Consultants need to be aware of two other new federal priorities public and tribal consultation on the Section 106 process. While contractor reports should summarize measures of public and tribal involvement or assist with logistical aspects, only the affected agencies are authorized to consult government-to-government. DOI and ACHP are crafting national policy regarding public and tribal involvement and government consultation, which

2 may affect how consultants do business. Consultants cannot represent a position on a project on behalf of the government, but the government may ask the consultants to act as logistical advisors. d. Permit information. BLM is aware of the confusion regarding how to interpret the guidelines in the BLM handbooks, whether the guidance is consistent, and where to even find permitting information. Unfortunately, BLM imposes inflexible rules about how its websites are designed. Consequently, the permitting information is more obscure than other agencies, because it is embedded deeply within the public website. See the agenda for the links and breadcrumbs to UT BLM s cultural resource use permitting process. The permit guidance is also there, and is fairly straightforward. e. Project authorization vs. a cultural resource use permit (CRUP). Utah SO issues three types of permits: survey/recordation; limited testing/collection; and excavation/removal. Most consultants hold survey/recordation permits, and apply for testing and collection permits on a project-by-project basis. Project authorizations are issued on a Field Office level; consultants need to notify and coordinate with the appropriate field manager and field office archaeologist prior to commencing fieldwork in a particular district. If a Class I survey is proposed, or if the project requires limited testing, collection, or excavation, the consultant, FO archaeologist and SO archaeologist need to coordinate, because depending on the nature or size of the project, the public and tribes will become involved. We will probably receive national direction to drop the limited testing/collection permit. f. Geographical area qualification requirements. In the past, BLM UT has been fairly liberal in granting permit authority to crew members based on their regional experience. This will no longer be the case. There have been too many problems with deficient reports from personnel who are unfamiliar with Utah archaeology, and inexperienced consultants have struggled with particular areas, primarily the San Juan region. BLM Utah recognizes two regions: Great Basin and Anasazi. From now on, crew chief CVs will have to demonstrate their qualifications consistent with BLM Utah standards. The qualification standards for geographic regions, PIs vs. crew chiefs, and research vs. field experience are outlined in the permitting section of the BLM UT website. In the past, permit authority has been granted to individuals for historical expertise only. Again, this will no longer be the case. Crew leaders need to be able to conduct a complete inventory, and that means recognizing historic and prehistoric sites. However; involving specialists (e.g. historic archaeology, human remains) makes sense on a specific data recovery project.

3 g. Repository agreements and receipts. Many permits are now issued for multiple-years, but repository agreements are renewed on a yearly basis. Updated versions need to be provided to BLM prior to commencing fieldwork for that year. Also, BLM will be requiring repository documentation for collected artifacts. The collections and repository information should be included along with the report, using the repository receipt forms attached to the agenda. The issue is accountability: BLM needs to know what types of artifacts are collected, and how many. This information helps BLM determine and justify the amount of funding annually provided to repositories. II. Utah BLM Proposed Digital Standards powerpoint presentation (Laurel Glidden) a. Background/Purpose and Need: BLM is required to share cultural information with the SHPO, per a programmatic agreement as well as the protocol. b. Presently CURES is the tool for management of cultural reports; contains spatial and encoded data, and is the statewide database. c. New standards for submitting and recording digital data need to be established for several reasons: there are upcoming policy changes; there is confusion between the consultants and BLM archaeologists over how to interpret existing guidelines; improve the efficiency of the process; and there needs to be consistency in the quality of reports received. d. BLM needs to revise its outdated forms. Currently, the required BLM forms are: UT (BLM cover page) UT-8110-x (Isolates Form) UT-8110-x (Photo Log Forms) UT SHPO cover page e. In addition to the required number of hard copies, the following documents must be submitted in digital formats. The data will be organized in five (5) folders titled: Report Site Form Photos Maps GIS data f. Data will be burned to CD or DVD. g. Discussion: ideas for accessing digital information among consultants and BLM. These files contain volumes of information. Server space might be problematic. Creating an ftp

4 site might work, if we can get around the issue of government firewalls. The consultant might be able to create a site, that gvt archaeologists can access, rather than vice versa. h. Data Submission: Reports and site forms will be.pdf Photos will be.jpg or.tiff Discussion: which shapefiles should be reported as polygons. Project boundary, what was actually inventoried, or recorded sites. BLM uses polygons to calculate acreage. Do not need polygons for isolates. Discussion whether to GPS entire sections, or whether hand-drawn maps will suffice. Taking numerous additional GPS coordinates will increase the labor cost for bidding projects, and is arguably unnecessary. Moreover, GPS can be unreliable, because accuracy depends on weather conditions. A solution would be to use the BLM s or proponent s boundary maps, or simply estimate the boundaries. If the consultants had to walk entire boundaries or buffer zones taking GPS points, it would add 10% to the cost of the project. The consultants and FO archaeologist should work with what is reasonable and practical. i. BLM needs to show where the project is located, and what s out there for the Section 106 process public review. Need to evaluate the effect of a potential undertaking to cultural resources. Two (2) shape files for inventoried area and recorded sites Map of project boundary When labeling the digital files: s = site, and p = project boundary j. Discussion: keep all data organized in appropriate files, or break up large reports by volume and chapter? Very large reports would be exceptional otherwise keep all like data together. This will be worked out over the upcoming field season, and will revisit this issue next fall. k. GPS and GIS standards: Key Points all sites/inventory areas recorded as polygons linear sites and inventories are exceptions Map of entire site boundary datum point taken at the approximate center GPS accuracy should be +/- 3 meters accuracy Differentially corrected using BLM s data dictionary

5 l. GIS software cost and labor solutions: Free GIS software is available: Map Windows Udig DNR Garmin (link) min/dnrgarmin.html Other options: m. BLM Data Dictionary Partner with a larger firm and contract out the GIS workload There are relatively inexpensive professional grade GPS units available BLM data dictionary is designed to acquire spatial data that can be easily integrated into the CURES database. information can be modified so long as base information is present: inventory boundary inventory lines site boundary site lines Discussion: NPS developed national standards that BLM isn t fully adhering to. Why aren t DOI agencies consistent? Answers: BLM has a different level that actually demands better accuracy than national standards. The national policy exists, but is vague. BLM is still developing its standards which do adhere to NPS standards. This issue will be revisited in the fall, following the field season. Basically, the CURES database was developed based on national standards, and the proposed BLM standards have been developed based on CURES. And current BLM standards are vague and not adequate. n. Archival vs. digital photos Interagency standards are inconsistent. Fire program is developing its own standards. Often projects cross state boundaries, and the state standards are different. This is problematic. BLM requires in digital format as a.jpg or a.tiff

6 an additional copy of each photo can be embedded in the report as a.pdf If field office requests an archival photo, give it to them. SHPO still requires hard copies of archival photos BLM may remove the language relating to hard copy photos (whether they should be put in sleeves, how many are required, etc.) out of the standards document because our focus is on digital standards. Requirements for number of hard copy photographs, etc. will still come from individual contracts. Discussion: archival photos and taking numerous additional photos will drive up the price of projects, some of which have already been bid. All this additional equipment, software and time costs the consultants money that was not figured into the bid. o. BLM: these are just guidelines. We intend to try out these proposed guidelines this field season and revisit all of what was just discussed in the fall, and look at what worked and what to improve. During the summer, think about: how SHPO policy factors into application of the proposed BLM standards. how can the proposed BLM standards be applied to large, ongoing projects; how to make the rules reasonable and flexible. how to enforce the standards for all consultants- need language in the guidelines to ensure consistency and make sure everyone plays by the rules. how to access to large files and digital data- Large servers? ftp sites? Bear in mind that the SHPO is not authorized to release shapefiles without permission from the agency, per a partnership agreement.

7 SUBMIT YOUR COMMENTS BY APRIL 15 IN ORDER TO INCORPORATE YOUR FEEDBACK INTO THE EXPERIMENTAL GUIDELINES! Laurel Glidden, District Archaeologist Cedar City District Office 176 E. DL Sergeant Drive Cedar City, UT Tel: Fax: Anonymous comments: p. Discussion (Byron Loosle): BLM s revised guidelines will be available by the end of April, and we ll meet again this fall. If fieldwork is expected to last multiple years, do these guidelines anyway for this field season and we ll revisit by If you can t meet standards, give a legitimate excuse. Work with the field office archaeologist. The standards have to be consistent across the whole state, and BLM manages diverse geographical terrain, vegetation, cultural resources, etc. It s difficult to establish standards for such a diverse state. Contracts to implement one Programmatic Agreement might very well differ for another undertaking from another area. p. BLM Annual Reports see the new annual report framework in the BLM hand-outs (attached) Note new category: public participation. BLM is being asked to provide examples of what type of work is being done in the state, and how the public is involved. Consultants are excellent sources of this information. Per the permit conditions, annual reports are DUE AT THE END OF THE CALENDAR YEAR. Next year, reminder letters will be sent out after March 1. The new handbook will tighten up the existing rules. Serial case numbers do not always apply to Utah projects, but other states use them, so if your projects cross state boundaries, include serial numbers where appropriate. BLM Utah usually references state numbers instead.

8 Repository Information. If artifacts were collected and given to repositories, BLM requires a repository receipt for collections (attached). Also, even though many consultants hold multi-year permits, please remember that current curation agreements must be submitted annually. Cultural history sections in the reports do not have to be generic or boilerplate. Make them relevant to the reports. Focus on the resources you expect to find, or what is already recorded. Class I: be more specific. Demonstrate your knowledge of regional history. Write for a public audience, using non-technical language where possible. Report must be geared toward a public review, not a professional review. BLM may start using NEPA information based on Section 106 report information. V. Utah School and Institutional Trust lands Administration (SITLA) Key Points (Kenny Wintch) a. SITLA cooperates with BLM for section 106 compliance consultation on projects involving both BLM and state trust land. BLM often consults on behalf of SITLA as a lead agency. The Utah SHPO prefers this as well. b. Excavation projects on trust land: Please remember to consult with SITLA early in the process and work with their archaeologists in developing the research design. SITLA staff will submit Data Recovery Permit application to PLPCO, SHPO and the Antiquities Section on behalf of the consultant. Please leave adequate time for all this to occur normally. c. SITLA has a fieldwork authorization process that is similar to BLM s, but is handled out by SITLA archaeological staff (in Salt Lake City). It is an easy, relatively painless and quick process. SITLA has in the past required fieldwork authorization only when new fieldwork was about to be conducted on trust land; that is changing to a requirement for any type of work that will result in reporting of data from trust lands (e.g., Class I inventories, in addition to Classes II and III). Information about the requirements for working on trust lands can be found on their website: as well as a fillable pdf document that can be sent electronically, by fax or by mail to SITLA:

9 d. SITLA ultimately wants to know what s happening on trust lands, but the fieldwork authorization system is driven by more than just academic curiousity or bureaucratic anality it ultimately comes back to fulfilling requirements in SITLA s cultural resource (R850-60) and, especially, their rights-of-entry rules (R850-41). Please contact either Kenny Wintch or Kristine Curry if you have questions or concerns about SITLA s fieldwork authorization requirement. IV. Public Lands Policy Coordination Office (PLPCO) Key Points (Kelly Beck) a. Reminder that a state permit is good for three (3) years, and is only issued to PI s, not crew chiefs. b. Excavations on state lands are considered undertakings. Before an excavation permit is granted, PLPCO conducts a coordinated review with the SHPO, and other agencies where appropriate. Prepare a good research design Year-end reports are not required. c. Permitting information is online: V. Division of State History Key Points: (Kevin Jones, Ron Rood, Arie Leeflang) SHPO is almost finished entering its data backlog, including the tabular data. If a project in not currently in the database, the consultant may need to provide the missing pieces. SHPO is on board with BLM s proposed new standards. Improved quality/accuracy of data is a good thing, and SHPO will accept any digital data consultants are willing to submit. Discussion how to reach out to consultants, and encourage digital data contributions from statewide projects. Maybe start a blog? UPAC site? Archaeology Week is May 7-14, New posters are available. No human remains updates.

10 e. A staff directory and SHPO compliance information is on the State History website: Staff Directory: SHPO compliance: VI. Utah Department of Transportation (UDOT) Key Points (Betsy Skinner) a. UDOT s archaeological guidelines were revised last spring, and are posted on the website: or: Utah@udot.gov >Department Directory> Environmental >Cultural Resources Guidance. b. The revised Project Authorization (formerly field work authorization ) form has additional fields, like APE information. c. Architecture guidelines will be out by this summer. d. It is important to consult UDOT early in the process. Cultural resources specialists will determine the APE and inventory methods. UDOT Regional archaeologists and the architectural historian need to be involved from the beginning. e. UDOT and BLM will soon have a PA regarding coordination for UDOT projects on UDOT ROW that cross BLM land and for BLM projects that cross UDOT ROW easements across BLM land. The federal agency has jurisdiction, whether it is the Federal Highway Administration (FHWA) or BLM. Research the land status prior to fieldwork. Turn in the project authorization early, so agencies have time to conduct a coordinated review. The executed PA is anticipated by late spring or early summer. f. UDOT will most likely use the same standards as the BLM regarding digital data standards, but it may not be implemented by this field season. VII US Forest Service Key Points (Will Reed) a. Refer to the Ashley National Forest website. It s easy to navigate, and has everything you need to know.

11 b. Forest Service s (FS) Heritage Manual is available. FS is now working on the handbook, which should also be out soon. c. FS issues permits at the Forest or District level depending on the scope ; always contact the forest archaeologist prior to fieldwork. d. The FS national database has information about 340,000 sites from 40 states. The database project has been building for 20 years, and includes basic data from sites and projects. We are now in beta testing for a comprehensive geospatial interface. The FS national database is divided into two (2) categories: sites and events. e. An ongoing issue is the need to develop a national database. FS recognizes the need to agree on basic standards, and develop a national site, in consultation with the SHPOs. The states differ in basic standard requirements, and it complicates FS policy implementation. f. The national, interagency wildland fire program is insisting on national standards: because when resources and values are at risk, the incident commander needs to make sound decisions. The IC needs to have cultural resource information readily available: what are the cultural resources in the area, how many fire archaeologists are needed, what are appropriate mitigation measures, and where are the guidelines? For example: The FS is reviewing a national EIS regarding wildland Fireaerial application of fire retardant. Need to delineate what areas are protected for terrestrial and aquatic resources. Cultural resources are affected across state boundaries. g. All agencies manage similar resources, but data gathering across boundaries is difficult, and a duplication of efforts. The FS is trying to resolve this issue: the agencies need to agree on the basic standards that they all adhere to. VIII Wrap-up/ Takeaway information (Byron Loosle, Kelly Beck) a. State and Federal land and resource management agencies are responsible for all actions on their lands. They are accountable to the public. It is imperative that consultants to coordinate with affected, appropriate agencies early in the process. The agency drives public involvement based on the information provided by contractors. It is the consultant s responsibility to report back to the agency what s out there. Example: the West Tavaputs process. The cultural work had already been done, when ACHP demanded that consulting parties be involved. The public did not like the APE boundaries, so the Class I had to be redone.

12 b. What the consultants are asked to do will be outlined in a PA, so they are better informed when they bid on a project. BLM will delineate the work, so the consultants don t find out about additional (and potentially costly) demands after they have won the bid. c. Remember, the proponent pays the bills, but the consultants are ultimately working for the agency. The information reported by consultants helps the agencies public processes. d. Suggest calling the affected agency prior to bidding, or immediately after winning a bid to find out the project scope. Need to coordinate so that the scope is identified and understood from the very beginning. e. BLM will prompt public participation early on to mitigate problems and clarify what to focus on. f. This is a positive step forward. Our common goal is to protect cultural resources, and inform the public.

STATEMENT OF WORK Environmental Assessment for the Red Cliffs/Long Valley Land Exchange in Washington County, Utah

I. Introduction STATEMENT OF WORK Environmental Assessment for the Red Cliffs/Long Valley Land Exchange in Washington County, Utah The Bureau of Land Management s (BLM) St. George Field Office (SGFO) requires