W HAT H APPENS TO A C ULTURAL R EPORT O NCE IT IS S ENT TO BFO?
-
Upload
veronica-gilliam -
Category
Documents
-
view
215 -
download
1
Transcript of W HAT H APPENS TO A C ULTURAL R EPORT O NCE IT IS S ENT TO BFO?
WHAT HAPPENS TO A CULTURAL REPORT ONCE IT IS SENT TO BFO?
BFO ADMIN STAFF RECEIVES THE REPORT Date stamped
Given a BFO specific number and logged into the BFO database
Report is placed in the “To Be Reviewed” files
COMPONENTS REVIEW
One cultural staff person is assigned to do component reviews each month. PODs are not accepted unless they contain all
the important components, including a cultural report.
The component review sheet is signed off if BFO has two copies of the report The report is not reviewed, the files are simply
checked to see if we physically have the report
POD TEAM ASSIGNMENT• Once a POD is “on the shelf” and
ready to work, teams are assigned– Cultural staff are assigned by the
assistant field manager somewhat randomly based on their experience with nearby PODs, possible unique issues and workload concerns
• POD teams include an NRS, wildlife biologist, legal assistant, legal instruments examiner, geologist, petroleum engineer, hydrologist, realty specialist, civil engineer and cultural specialist
INITIAL REVIEW
Upon POD assignment, the cultural specialist performs a cursory review of the report with the following in mind: Does the inventory cover the entire POD Does the report contain all the necessary forms Are there any outstanding issues that may delay
POD approval (Native American consultation, settings issues, Bozeman Trail, etc.)
INITIAL TEAM MEETING Within one week of POD assignment, an
initial team meeting is held to: Schedule the Operator Initial meeting (OIM) and
onsite dates Determine if there are any issues with the
cultural report that need to be resolved before the OIM or onsite
Ensure the infrastructure on the POD map matches that portrayed in the cultural report
OPERATOR INITIAL MEETING
POD team, landowners, the operators representative and various operators’ consultants attend the meeting
Occasionally contract archeologists are asked to attend
The operator receives deficiencies for the entire POD, including any deficiencies with the cultural report Cultural report deficiencies typically need to be
corrected after the onsite
ONSITE The cultural resource specialist typically attends
every onsite They check to see if the report accurately
recorded sites and IF’s They will spot check many areas within the
inventory to ensure report accuracy They will discuss any well or infrastructure moves
with the NRS and operator
POST ONSITE DEFICIENCIES Changes made during the onsite must be accounted
for BFO determines the APE at this point and there may
be additional inventory/site recording requirements Changes to the report may be required in order to
conform to SHPO Class III report standards Additional inventory may be required Additional testing or recordation may be required at
specific sites Report deficiencies are sent to the operator along
with other specialists’ deficiencies Any violations of permit conditions are reported to
the CRUP and BLM State Office
BFO DETERMINATIONS
Determinations of eligibilityCRUPs recommendations are considered, but
BFO is legally responsible for eligibility determination
Even if the CRUP evaluates a site, BFO may leave it unevaluated if they determine there is not enough information supporting that determination and it is not in the APE
BFO can make determinations that don’t match the recommendation
Determinations of effectAre the legal responsibility of BFOPertain to the entire project
BFO DETERMINATIONS, CONT.
Determinations by BFO may not match the CRUPs recommendations
The CRUP is not systematically informed if their recommendations are not used
CRUPs must not assume that their recommendations were accepted by BFO when considering future undertakings Check WYCRO Check CRMTracker Ask BFO
“NO HISTORIC PROPERTIES AFFECTED”(SITE IS ELIGIBLE UNDER CRITERIA “D” AND IS AVOIDED)
“NO HISTORIC PROPERTIES AFFECTED”(SITE IS NOT ELIGIBLE, AND IS IMPACTED)
“NO ADVERSE EFFECT”(SITE IS ELIGIBLE, NON-CONTRIBUTING PORTION IS IMPACTED)
“ADVERSE EFFECT”(SITE IS ELIGIBLE, CONTRIBUTING PORTION IS IMPACTED)
“ADVERSE EFFECT”(SITE IS ELIGIBLE UNDER CRITERION “A”, HAS HISTORIC STRUCTURES, AND RETAINS INTEGRITY OF SETTING)
REPORT IS ACCEPTED BY BFO AND SENT TO SHPO
BFO becomes legally responsible for the findings in the report, as if BFO actually performed the inventory
BFO digitizes the inventory and site boundaries
If the consultation is a simple notification, the report goes directly to WYCRO in Laramie, where it is filed (no SHPO review)
If there is SHPO review time, the report is sent to the SHPO office in Cheyenne
SHPO CONSULTATION If there are no historic properties, SHPO is notified. If there are historic properties but none are affected,
SHPO is notified. If there is “no adverse effect” to a site/sites eligible
under criterion “d” - SHPO is notified. If there is “no adverse effect” to a site/sites eligible
under criterion “a”, “b” or “c” – SHPO is allowed 15 days to comment.
If there is “no adverse effect” to a site/sites eligible under criterion “a”, “b” or “c” where setting is an important aspect of integrity – SHPO is allowed 30 days to comment.
If there is an “adverse effect” to any historic property – SHPO is allowed 30 days to comment and an MOA to resolve the adverse effect may be necessary.
ACCEPTED REPORT
Information from the cultural report will be used in order to complete the NEPA document
The inventory and sites will be listed on WYCRO and plotted on WYCRIS, but there can be significant lag time The WYCRO web site will show site eligibility
determinations made by BFO and whether or not SHPO reviewed those determinations
CONDITIONS OF APPROVAL
Monitoring Required in order to locate buried cultural
materials AND ensure that the operator constructs infrastructure in approved areas
Data Recovery Details are determined through SHPO
consultation Additional Inventory Conditions Site Avoidance/Protection
Site fencing Simple avoidance
IMPORTANT NOTES
Report deficiencies are common, they are primarily as a result of changes to POD by the operator, NRS, or other BFO specialists
Determinations made by BFO may not necessarily match a contractors recommendation
Once it is sent to SHPO, BFO is legally responsible for the report as if it were their own document