Cultural resource regulations are tricky. Different agencies can interpret the rules differently, and the process can often be slow and arduous. Let’s unpack efficiencies to help move your project from plan to implementation…
The most important takeaways from this blog are ‘start early’ and ‘minimize risk.’ Cultural Resource Management (CRM) success hinges on starting as early as possible.
Many stages and overall project timelines are dependent on agency reviews. Agencies are backlogged, overworked, and stretched thin. Even with the correct relationships, a strong knowledge of the applicable laws and regulations, and a tight strategy to deal with cultural resources, you need to have realistic expectations around what a timely turnaround can look like. Projects can take from a few weeks to months and sometimes years, depending on the scale and complexity of the project and the resources found.
The other key to efficient management is anticipating risk.
Your project needs to be appropriately scoped—do enough to minimize surprises and manage expectations, but don’t do more than is necessary. For example, what if research and/or field work uncovers an archaeology site in your project area? Do you proceed with the expensive and lengthy process of excavating the site? Do you rescope, replan, and build around the site? Being aware of the risks and knowing your next steps is what keeps a project on track. 106 Group excels at providing strategic thinking to support your project needs and minimize risks.
But that’s only scratching the surface. Other areas to consider for streamlining your cultural resource management include…
Consult with Tribes Early
During the Section 106 process—an important component of the National Historic Preservation Act (NHPA) of 1966—government-to-government consultation is required and integral in instances where a project could adversely affect a site of religious or cultural significance to Native American Tribes. Many regulations—including the NHPA, the National Environmental Protection Act (NEPA), federal treaties, executive orders, various agency policies, and state and/or local statutes governing the treatment of cultural resources and burials–mandate some level of tribal consultation. Meaningful consultation takes time and intentionality and is not a box-checking exercise.
Synchronize NHPA and NEPA Processes
There can be a fair amount of overlap between Section 106 of NHPA and NEPA requirements. Ideally, the same agency will make Section 106 and NEPA related decisions, and agency decisions will be synchronized. This helps minimize changes to the level of detail and design, and avoid duplication of efforts, which can delay projects. We can help you synchronize NHPA and NEPA processes to align schedules to minimize agency review delays. We strongly recommend starting both the Section 106 and NEPA processes together to minimize duplication of efforts or delays around missing key steps.
106 Group strategies and efficiencies make your project more successful
At its core, cultural resource management is highly specialized and technical. It goes beyond knowing how to document an old building or dig archaeology sites. When working with 106 Group, you’re working with real experts. Our experience encompasses regional, federal, and tribal regulations. Our decades of strong relationships with key tribal and agency personnel help us advise you on meaningful project strategies.
Keep Reading About Cultural Resources Management
Ben Duckworth
Ben is a proposal writer for 106 Group, with a background in copywriting and professional communications.
Anne Ketz
Anne’s career in cultural resources management and planning extends over 30 years and three continents. Anne has worked with a broad range of stakeholders, including Native American tribal communities, community leaders, and thought leaders to ensure respect for each community’s heritage within the planning process.
