Research of Anthropological / Archeological Resources
Guidelines for Dealing with Anthropological or Archeological Resources in Big Bend National Park
I. All research on anthropological and archeological resources of Big Bend National Park must be done under an approved research proposal and resource activity permit. Activities having an affect or potential to affect cultural resources are considered “undertakings” and are governed by the National Environmental Policy Act (NEPA), the National Historic Preservation Act, as amended (NHPA) and the Archeological Resources Protection Act, as amended (ARPA).
The park must receive research proposals in written form. Telephone conversations or verbal presentations of the research proposal will not suffice, although such means may be desirable to clarify the proposed work. There are at least three reasons for this:
A. the proposal may be reviewed by a number of different people in different locations in order to ascertain the need for and appropriateness of the research (This information is also required by the Texas State Historical Commission for their review and approval of the project);
B. the proposal should serve as the initial form of written documentation of the project, should the project be approved; and,
C. to provide a basis against which the results of the completed research can be compared.
II. All written research proposals for projects that do not involve collections and that anticipate very little or no impact to the preservation of the resources must be received at least 30 days in advance of the time fieldwork is scheduled to begin. Written research proposals for complex projects, particularly involving ground disturbing activity or collections, must be received at least 120 days in advance of the time fieldwork is scheduled to begin. Projects which might jeopardize cultural resources – e.g., through collection, excavation, or any ground disturbing activities will require special permits [e.g., Archeological Resources Protection Act (ARPA) Permits], or in certain cases may require consultation with affiliated American Indian tribes. At least 120 days lead-time may be necessary for such situations, depending on the nature of the permit required.
III. The written research proposal should specifically address the following elements (minimally), as well as other materials common to a formal research design.
A. Purpose: There should be a clear, concise statement of the purpose of the proposed research, its relevance to the advancement of regional archeology and to the mission of the National Park Service (NPS), its public benefit, and the specific goals the project intends to accomplish. Most importantly, there should be a statement which clearly demonstrates the need to carry out the proposed research in a National Park area, rather than in other areas under the jurisdiction of an agency which does not have such a strict conservation mandate.
B. Theoretical Framework: The theoretical aspects of the research should be discussed in detail and should include specific research questions, underlying assumptions, hypotheses and test implications, as well as justification for the selection of the specific sites or areas to be visited.
C. Methodology: Data gathering, data analysis, and data storage methods should be discussed in detail, to include the following (minimally):
1) Data Gathering: Pre-field methodology - including assessment of background information, summary of prior work done, location and search of existing records, initial data requisites (remote sensing, environmental information, etc.).
Field methodology including sampling methods, on site analytic methods/forms, recording methods/forms, photo records, collection methods, etc. The inclusion of examples of the field and laboratory forms to be used will assist in determining efficacy.
2) Data analysis: Analytic techniques, sampling methods, quantitative methods, classification and typological schemes to be employed, etc.
3) Data Storage: Disposition of records, artifacts, and other data; arrangements for permanent curation; protection of sensitive data as required by NHPA and ARPA against accessibility to information by the general public, and the accessibility of information to other researchers.
4) Data Security: Information regarding the location or nature of archeological sites and resources is exempt from the Public Freedom of Information Act and must not be released or published in any form without written consent by the Park Archeologist and the Park Superintendent. Measures to be taken to safeguard archeological data must be provided in the research design.
D. Logistics/Impacts: Field logistics should be discussed in detail, including the means of arriving at the site location, the nature of anticipated on site activities, the number of people and kinds of equipment expected on site, and a general summary of the total impacts to the resource anticipated by the actual on site activities as well as the impacts that might result from the completion of the project and publication of the findings.
E. NPS Participation: Provide a detailed list of what National Park Service participation will be needed and how the NPS involvement is expected to contribute toward the study. Any cooperative agreements or memoranda of understanding or memoranda of agreement as appropriate must be in place in advance of the project.
F. Scheduling: The actual scheduling of the research should be detailed, including time frames to start and complete the various elements of the research, a priority of objectives (in case not all can be met), and the anticipated date of completion of the final report.
G. Reporting: Staged progress reports should be discussed and scheduled if project activities continue over several months. The nature of the final report should be presented, including an outline of the topics to be covered, identification of the authors, the expected length of the report, protection of sensitive site locational data according to NHPA and ARPA restrictions, and the anticipated means of disseminating the report to professional audiences.
H. Principal Investigator (PI): The PI should be identified, along with a summary of his or her qualifications to serve as PI and the institutional affiliation claimed.
I. Vita: Current vita of the PI as well as other senior project members should be included.
J. Accountability: The PI must demonstrate the ability to carry out the full scope of the project including, the fieldwork, the laboratory analysis, the curation, accessioning, and conservation of collected specimens, and the production of final report(s). The PI must demonstrate fiscal responsibility sufficient to carry the project to completion, by including a budget that indicates the funding on hand for all project phases.
IV. The review and evaluation of the proposal will follow standard procedures. Proposals should be submitted to the Park Archeologist (PA), through the Park Hydrologist (who reviews all research activities for the park), for initial review. If warranted, the PA will send copies to other NPS, agency, or non agency archeologists for their review and evaluation, and will compile their comments when received. If necessary, comments and suggestions will be referred back to the PI for incorporation into the research design. The PA will also determine the permitting requirements (e.g., ARPA Permit or Texas Antiquities Permit for work on State Archeological Landmarks located on park land) and if necessary, will send the proposal with recommendations for review and issuance of the appropriate permits.
The Park Hydrologist and Park Archeologist will work together to determine the extent to which fieldwork should be monitored while in progress, and the means of so doing. This will vary according to the nature of the on site activities planned, the character of the proposed research, and the sensitivity of the proposed work to American Indians, other affiliated ethnic groups, the lay public, etc.
V. If research is proposed at both Park Service and non Park Service areas, the role of the NPS vis-à-vis other agencies needs to be clarified. The PA will ensure that copies of the research proposal are sent to all relevant agencies, and that the agency archeologists coordinate the review and evaluation of the proposal. If it is anticipated that the NPS would act as lead agency for the purposes of NHPA Section 106, American Indian Religious Freedom Act (AIRFA), or other permitting actions, then the PA will coordinate with the appropriate agencies to determine who should represent the permitting agency in monitoring on site activities.
VI. All reports are to be submitted within the scheduled time frame to the Park Superintendent. Non compliance with this and other requirements determined applicable to each project will affect future cooperation by the NPS, as well as the granting of permits for future research.
VII. All archeological collections, field data, analysis data, and electronic/magnetic media will remain the property of the National Park Service. All collections, written data, photographic data, and electronic media formats must be clearly identified by appropriate labeling, as property of the National Park Service. During analysis and writing phases of the research, these materials will be on loan to the PI, who is responsible to provide for secure storage while under the PI’s control.
Upon completion of fieldwork and prior to leaving the park, the PI must provide park curatorial staff with a field inventory of materials removed from the park. Upon conclusion of the research project, all material related to the project must be turned over to the National Park Service.
Project materials may be retained in a repository provided that the repository meets Secretary of the Interior Standards and National Park Service Museum Standards for collections. Loans by the National Park Service for research purposes, or for storage in a non-NPS facility must be arranged with the park curatorial staff. Collections on loan are subject to random museum inventories and the PI may be required to verify the location and condition of specimens.
VIII. Research proposals, reports, curatorial concerns, and correspondence are to be sent to: