Procedures and ProcessesPhase III: Mitigation

CRM Phases I-III

This presentation uses materials taken from Ricardo Elia’s Cultural Resources Archaeology MATRIX course prepared for the Society for American Archaeology

Mitigation? What’s that?

Mitigate: to make less severe; to lessen the impact

Let’s say that:

•A Phase I survey for a Section 106 project discovered cultural resources, and a Phase II study found that they were likely to be significant.

•The federal agency official responsible for handling the Section 106 process has to determine if the proposed project will have an adverse effect on the sites.

• If so, efforts must be made to "avoid, minimize, or mitigate" the adverse effects.

Mitigation by Avoidance

One way is simply to avoid the adverse effects altogether by changing the project

The cultural resources are no longer subject to impact.

From a preservation standpoint, this is the preferred alternative because the sites are left alone.

Excavation is not preferable!

In most cases even at a Phase III level excavation usually means sampling the site, not full excavation, and it is better to leave the site intact if possible.

Redesigning the project to avoid impacts to the site(s) is another matter.

It may be impossible, given constraints of topography, available land, or excessive costs.

Avoidance isn’t perfect!

Once a decision is made to avoid a site, it is no longer subject to the jurisdiction of the preservation laws.

A significant prehistoric site, for example, now removed from a Section 106 project area, will probably revert to the unrestricted use of the landowner.

Avoidance does not guarantee preservation.

Wever Site, Lee County, Iowa example

Mitigation by Site Burial

Avoid impacts to cultural resources by burying them sufficiently deep so that the construction of a project will not affect them.

This technique is not without controversy.

Long-term effects of burial on factors such as a site's soil chemistry, remain matters for concern.

To what degree is a significant cultural resource really preserved if the site burial effectively makes it impossible for the site to ever be investigated.

For site burial as a technique, see Robert M. Thorne, "Intentional Site Burial: A Technique to Protect Against Natural or Mechanical Loss," Archeological Assistance Program, Technical Brief No. 5, Sept. 1989.

The Rock Creek Site, Natchez Trace Parkway, Alabama: Buried site approximately two years later showing damage from farm equipment.

The contractor who does the Phase I and Phase II may not do the Phase III.

Why? Mitigation is a costly operation, and agencies usually want to put the project up for bid.

Excavation of 13JN169, Palmer Church Site, a

Congregational Church on the Bowen’s Prairie

site, Jones County, Iowa

Data Recovery Issues

Mitigation by Phase III Data Recovery

The Final Stage in the Three-Step Process

Used if not prudent and feasible to avoid or otherwise minimize the adverse effects on significant archaeological resources,

The likely form of mitigation will be to conduct a full-scale archaeological investigation designed to realize the site's research potential through excavation.

The research design for data recovery projects must address the specific research questions that were identified in the Phase II report as part of the site's significance.

Mystery Feature at Bowen’s Prairie

The Memorandum of Agreement

In Section 106 projects, data recovery projects are stipulated as part of an agreement between the federal agency, SHPO/THPO, and other consulting parties.

A model MOA

A Bowen’s Prairie Cistern before and after excavation

Key MOA Elements

The MOA contains:

• the basic facts about the project,

•the determination of eligibility by the federal agency and SHPO,

•the statutory authority, and

•the stipulations for mitigating adverse impacts.

•Normally the stipulations simply require data recovery projects or other kinds of mitigation (e.g., technical recording of historic structures) without a lot of detail; that is taken care of by the specific data recovery plan that must be developed.

•Notice who the signatories are.

Limestone Well at Prairie Springs Site, 13JN203

Data Recovery PlansDifficult to generalize about data recovery projects because each site is unique.

The Phase III project the research design must be specifically tailored to the particulars of the site and the research questions being asked of it.

Phase III excavation is both more intensive and extensive than in any other phase.

The research is more detailed and more focused.

The analytical techniques brought to bear are more specialized and more systematically applied.

Miniature vessel from Cowan Site

About those research questionsThe State Plan again…

A Maryland Example: Blueberry Hill

Just recovering more data is not enough.You need to do what is necessary to characterize and understand that data.

Examples:

Geophysical remote sensing might be used to identify buried features or to delineate subsurface walls and foundations.

Radiocarbon dating will be attempted at prehistoric sites in order to learn the chronology of sites.

Floral and faunal analysis, soils analysis to understand the ecological nature of the site and its use by people

The goal is to mitigate the loss of the site so that its research potential can be met.

This is parallel to Phase II but vastly more intensive.

Phase III Proposals and Budgets 1 Scoping out and budgeting a Phase III project is a challenging enterprise.

There is greater variation in both the scope of work—how much excavation will be done, how many artifacts are anticipated, what types of analyses will be conducted—and in the budget estimates among Phase III proposals than among Phase I and Phase II proposals

Large and complex projects may run into the millions of dollars.

They may involve a host of techniques rarely seen in the other phases.

Rainbow Site, Plymouth County, Iowa

Phase III Proposals and Budgets 2

Deciding how much of a site to sample is a major challenge.

What percentage of a prehistoric occupation site is sufficient?

Complexity of many Phase III sites may require a host of specialists for both field and laboratory specialists or consultants.

On-site public interpretation and other popular forms of disseminating the results of the project (e.g., brochures, booklets, exhibits) may be required or useful.

Large-scale Phase III excavations require comprehensive managerial skills to manage, schedule, and coordinate the various components of the project from start to finish.

Phase III Proposals and Budgets 2

About competitive bidding for Phase III projects:

•Clients tend to worry less about the budget

•They worry more about making sure the project receives the necessary approvals and gets done on time.

•For this reason they pay close attention to the qualification of the firm and its principals, its reputation, and its previous experience in successfully managing similar projects.

On big projects this may push them to go with big firms like Louis Berger, Geo-Marine, Brockington

Some Bowen’s Prairie Cisterns

Public Archaeology

Volunteer Excavation at the Maxwell Great Oasis Site, Dallas County, Iowa

Remember: CRM is by the People and for the People!

Society for American Archaeology Principles of Archaeological Ethics 4

Public Education and Outreach

Archaeologists should reach out to, and participate in cooperative efforts with others interested in the archaeological record with the aim of improving the preservation, protection, and interpretation of the record.