Evaluating Cultural Resource Significance: Implementation Tools (2005)

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The National Cooperative Highway Research Program (NCHRP) contracted with URS Group, Inc. (URS), to conduct a two-phased study on improving current approaches to evaluating cultural resource significance (i.e., National Register eligibility) in the con- text of both transportation projects and compliance with Section 106 of the National His- toric Preservation Act. The first phase examined current methods used nationwide to manage and organize cultural resource inventory data and historic contexts. The study also determined if information technology (IT) applications have been useful in devel- oping inventories and contexts. Finally, the study provided recommendations regarding IT applications to improve the development and use of resource inventories and historic contexts as tools for determining National Register eligibility. The second phase focused on the development and testing of two prototype IT applications that would streamline and improve how resources are evaluated for National Register eligibility. The two prototypes that were fully developed are the Historic Property Screening Tool (HPST) and the Electronic Cultural Resource Evaluation Library (ECREL). The HPST is a tool that guides a user through the National Register eligibility evaluation steps, using the evaluation components of a historic context, as defined in National Register Bulletin 15 and the Secretary of the Interior’s Standards for Historic Preser- vation Planning. The HPST database allows users to select a historic context and the property type most appropriate to the resource being evaluated. The “registration” cri- teria for the property type (based in part on aspects of integrity) are then used to deter- mine National Register eligibility. ECREL is a web-based tool that includes searchable historic contexts and other documents used in making decisions on National Register eligibility. Development of this tool involved (1) designing a document profile (i.e., index values [metadata] collected for each document), (2) defining acceptable index values and a keyword baseline, and (3) collecting and scanning paper documents and loading the documents into the database. Electronic documents were also placed within the database. State departments of transportation (DOTs), state historic preservation offices (SHPOs), and cultural resource management (CRM) consultants assisted URS in the testing and validation of these two tools by using the tools and completing an evaluation form on each tool. SUMMARY EVALUATING CULTURAL RESOURCE SIGNIFICANCE: IMPLEMENTATION TOOLS

The evaluations of ECREL were uniformly positive. Most reviewers felt that ECREL would benefit all historic preservation professionals. Though ECREL would not in itself result in an increase in the development of historic contexts, reviewers noted that the tool would at least result in the production of more useful historic contexts when these documents were created. The HPST, however, is more problematic. Reviewers all noted that this tool would not be used without direction and approval from upper management within agencies. The tool’s use requires changes in the existing evaluation processes used by most states. Further, unless agencies are willing to replace one or more existing evaluation and reporting requirements with the HPST, historic preservation profession- als are not likely to use this tool. Most reviewers, nevertheless, felt that the HPST would be a useful tool, but indicated that more work would be required to refine the tool’s fea- tures and to integrate the tool into current SHPO and DOT processes. Based on the evaluations of ECREL and the HPST, URS recommends several options for implementing one or both of these tools: • ECREL Option 1: Voluntary Implementation. This option involves (1) locat- ing a host for the ECREL database and website, (2) developing a document sub- mittal protocol in consultation with the primary parties involved in the Section 106–related National Register evaluation process, (3) developing a document load- ing procedure, (4) advertising the establishment of ECREL, and (5) having state DOTs, SHPOs, tribal historic preservation offices (THPOs), and consultants volun- tarily send in electronic versions of documents to the organization maintaining ECREL. • ECREL Option 2: National Implementation. This option is the same as Option 1, with the addition of collecting hard copies of documents from SHPOs and DOTs around the country. This step is recommended because the majority of documents within states are in a paper, not electronic, format. • HPST Option 1: Voluntary Implementation. This option involves (1) advertis- ing the tool nationally and highlighting the utility of this tool, (2) sending HPST CDs to all DOTs and SHPOs and making the CD available to CRM consultants, and (3) making the HPST source code available on CD to anyone who wants to use all or part of the tool in his or her own system. • HPST Option 2: Pilot Program. This program involves the participation of a small number of states (involving both the SHPO and DOT of each state) to fully implement the HPST. States would input existing historic contexts in the HPST and use the tool in actual project-related National Register evaluations. If possible, this option would also include using the HPST to create a new historic context from scratch. It is also recommended that ECREL be integrated into this pilot program, as the two tools can be used together (e.g., searching ECREL for appropriate historic contexts and then placing the contexts into the HPST program). Table 1 shows the pros and cons of each option. The HPST and ECREL were not created to increase the workload of state and fed- eral agency staff by adding yet another level of documentation. Rather, these tools will provide consistency—in terms of the format, presentation, and content of evaluation documents—that is sorely lacking in current documentation. These tools will also decrease development and review time for eligibility evaluations because the docu- mentation levels needed for effective decision making are made explicit and readily accessible, eliminating extraneous materials often inserted into current documents. These tools will replace currently used evaluation report formats, forms, and corre- spondence. The majority of decision-making efforts are documented and captured in a single format. Also, historic contexts that are developed in the HPST will be no more 2

3time consuming (and may be less time consuming) to create than the current method of compiling information using word processing software. The use of the HPST for context development also increases the likelihood that the resulting historic context will contain the information and guidance needed to evaluate National Register eligibility. If development and testing of these IT tools is to continue, state DOTs, SHPOs, and organizations such as the Transportation Research Board’s Historic and Archaeologi- cal Preservation in Transportation Committee (ADC50) and the American Association TABLE 1 Pros and cons of ECREL and HPST options Option ECREL Option 1 ECREL Option 2 HPST Option 1 HPST Option 2 Pros This option requires the least cost and time commitment for an organization or agency to host ECREL and to develop the document submittal protocol and loading procedure. The format of documents placed with ECREL will be consistent given the control over the documents obtained from DOTs and SHPOs. A single organization or agency will be responsible for collecting documents and entering them into ECREL. The resulting electronic library will be much more complete than under ECREL Option 1. This larger, more comprehensive library will encourage greater use of the site and its adoption by a broader audience. This option is the least costly. This option provides an easy and efficient mechanism for distributing the HPST. This option provides a mechanism to demonstrate the value of this tool to potential users, as the tool will be implemented in a real-world setting, such as an SHPO or DOT office, using real data from the resource inventories and historic contexts. The results of the pilot study will serve as evidence that this tool will actually help agencies and the private sector in their day- to-day decision making. Cons There is no mechanism to maintain consistency in the format of documents placed into ECREL by users (this option assumes that the organization hosting ECREL is not reviewing or vetting the format of documents submitted for placement into ECREL). As a result, sharing of information and data sets may become problematic. This option is the most expensive in terms of time and money. It may be difficult to get the SHPOs to participate in this effort given current staff and budgetary cut-backs. The SHPOs may not have the resources to assist in the collection of the documents to be placed within ECREL. This option does not provide a strong mechanism to demonstrate the value of this tool to potential users, as the tool has not been implemented in a real-world setting, such as an SHPO or DOT office, using real data from the resource inventories and historic contexts. As a result, there may be little interest in the HPST. There is little evidence that this tool will actually help potential users in their day-to-day decision making. This HPST option is the most expensive because it requires funding additional SHPO and DOT staff and funding an organization to conduct the pilot study. This option would require much more time and effort than HPST Option 1 would require.

of State Highway Transportation Officials (AASHTO) will hopefully provide leader- ship to secure funding to support additional prototype testing and refinement. As the February 2004 Santa Fe, New Mexico, “Working Conference on Historic Preservation and Transportation: Enhancing and Streamlining Compliance with Section 106 of the National Historic Preservation Act” illustrated, federal and state agencies clearly want to move away from a project-by-project approach to embrace new processes that empha- size examination of issues at a preplanning phase of project development. Tools such as ECREL and the HPST would greatly assist in supporting preproject planning efforts. As this study concluded, these tools have been shown to function extremely well and seem to represent two of the most innovative historic property–based IT tools yet devel- oped to achieve environmental streamlining. The beneficiaries of this paradigm shift—primarily state DOTs and SHPOs—are in the best position to encourage federal agencies, such as the FHWA, or organizations, such as AASHTO or the NCHRP, to consider funding a pilot implementation program for continued prototype testing and refinement. Selected state DOTs and SHPOs should consider participating in the prototype testing effort. (Based on comments received in this study, those states might include, but not be limited to, California, Florida, Mary- land, Minnesota, Rhode Island, Texas, Vermont, and Washington.) The authors of this report have come to realize that impediments that prevent these products from becoming useful tools are institutional, not technological, and will take institutional leadership to implement. The authors also believe that a pilot implementa- tion program will show the many benefits of these tools and should be seriously con- sidered for future national implementation. Long-term implementation has the greatest potential for success through adoption of a national initiative, such as the FHWA’s envi- ronmental streamlining program. Encouraging agencies to use standardized tools such as ECREL and the HPST would most successfully be achieved through a combination of requirements and financial incentives implemented through a national memorandum of understanding (MOU). (This MOU might be modeled on the MOU signed on Decem- ber 14, 2001, by 23 state agencies in support of the Efficient Transportation Decision Making system.) Implementation and ongoing system maintenance, as well as provision for staff training at state DOT and SHPO offices, could be supported through multiyear cost-sharing agreements among multiple federal agencies and the states. 4