EXAMPLE OF AN ARCHEOLOGICAL REVIEW PROCEDURE USING PREDICTIVE DATA
After ENVIRONMENTAL ASSESSMENTS OF HISTORICAL AND ARCHEOLOGICAL RESOURCES: POLICIES AND PROCEDURES OF THE STATE HISTORIC PRESERVATION OFFICER AND THE DEPARTMENT OF CULTURAL RESOURCES.
Division of Archives and History, Department of Cultural Resources, State of North Carolina, October, 1975.
Review Procedure: North Carolina Department of Cultural Resources
To provide for the most expeditious, efficient and professionally responsible review possible, the State Historic Preservation Officer and the Department of Cultural Resources have established a set of environmental assessment review procedures. These have been systematized over the past few years in accordance with Federal and State legislation. Because all proposals reviewed by the SHPO and the Department of Cultural Resources must be submitted to two similar but technically different reviews (one for impact on historic structures and another for archeological resources), the review procedures will be outlined in two sections.
When project documentation is received by the Archeology Section, the first step in the review is to examine the material to ascertain if there is sufficient information for review. In many cases, the information provided is incomplete and more data must be requested before the review can proceed. The most common omissions are locational data, construction schedules, and amount and location of new ground disturbance. If the supplied documentation does not exactly locate the project and indicate in detail how much and where the surface of the earth will be disturbed, it is impossible to assess the project's impact on archeological resources. If no schedule for site work is supplied, it is very difficult to arrange any needed archeological investigations. Whenever additional information must be requested, the review process is held up. Because of this, project planners are urged to contact the SHPO or the State Archeologist at the earliest stages of planning to insure that the review will not be shelved to await more complete information.
At this first level of review, approximately 80 percent of all projects are cleared. This results when it is obvious that no archeological resources will be affected by the project. The paving of previously graded streets, the laying of water lines in previously graded rights-of-way, and projects in highly urbanized areas are examples of such automatically cleared projects. As a general rule, any project that occupies a previously disturbed area, or an area that was unfit for human occupation in the past, will fall into the automatically cleared category. There are, of course, exceptions to this rule but, most will result from an inability on the part of the reviewer to determine if the above criteria apply.
The second level of review is to check the project location against existing archeological site files. As very little of the State has been subjected to intensive archeological reconnaissance, the files are often not very helpful in the review process. If the project is in a previously surveyed area, however, it will be cleared if it can be established that it will not have an adverse impact on known sites. If the project will have an adverse impact, comments so indicate and suggest steps for the mitigation of the impact.
For projects that can be assessed at levels one or two, the review is usually completed within two days. Whenever possible, problems arising during the first two levels of review are resolved by telephone. Completion of the review process as rapidly as possible is a basic policy.
The third level of archeological review deals with those projects located in unsurveyed areas of the State that are judged as having a potentially adverse impact on archeological resources. At this level professional training and judgment are crucial elements. As mentioned above, only a small portion of the State's archeological resources are known. It is important to note that lack of knowledge concerning a project's impact is not sufficient for a declaration of "negative impact." In essence, where there has been no reconnaissance, the commenting duties of the staff archeologists can be fulfilled by pointing out that assessment of the project's impact is impossible due to lack of data. The assumption must be made that the impact will be adverse until such time as the applicant can demonstrate otherwise. Thus, the burden of proof falls to the applicant.
In practice, and in line with the belief that the review procedure is a service that is performed for the people of the State, projects are reviewed on the basis of a series of probability models for site location. That is, it is possible to predict that if certain ecological and topographic features are present, there is a high probability that the location was inhabited by man. For example, high ground near a source of fresh water provided an ecological setting with an extremely high probability of containing archeological sites. If the project will impact such a location, a reconnaissance survey is required. If it can be determined that the ecological setting is unfavorable for human habitation, the project is cleared. It is at this level that historical documents are examined to assess the possibility of the project impacting on historic period archeological sites.
A certain amount of confusion has resulted from archeological review comments due to the applicant's unfamiliarity with the nature of archeological materials and processes. Almost any archeological work involved with clearing an applicant's responsibility to assess impact on cultural resources could involve three separate, but related, operations. First, the area must be examined to see if it contains archeological sites. This usually involves an archeologist walking over the area, collecting and mapping evidence of previous occupations. This kind of surface collecting and mapping can often tell the archeologist approximately when a site was occupied, how long it was occupied, and indicate the relative archeological value of the site. If no sites are found, or if those located are not significant, the project can be cleared. At times, however, a surface collection does not return enough evidence to assess the site's significance. When this is the case, the site must be tested to see if the surface indications are a true reflection of the site's potential.
Archeological testing is a limited excavation designed to answer specific questions about the value of a site. In the environmental assessment process, testing will tell the archeologist if the site is of sufficient value for nomination to the National Register. When this is the case, the project's impact on the site must be mitigated. However, it must be pointed out that the final determination of eligibility to the National Register lies with the Heritage Conservation and Recreation Service and not with the SHPO or with archeologists in the Department of Cultural Resources.
Archeological sites are, in the truest sense of the phrase, finite and nonrenewable resources. Thus, the most favorable action to mitigate impact is preservation. If projects can be designed so that they do not disturb sites that is preferable to salvage excavations, which can only collect a limited amount of the information contained in a site. It is possible to preserve an archeological site by covering it and building on top. Blacktop or a concrete pad can effectively preserve a site if it can be put in place without ground disturbance.
The final step in mitigating impact comes once it has been determined that a lack of construction alternatives means that a significant site must be destroyed. In cases of this nature, salvage archeology is the only recourse. A salvage excavation attempts to recover as much information as possible from a site before it is destroyed. This may mean total excavation or it may mean extensive excavations of only the more important parts of the site.