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20 CHAPTER 4 IMPLEMENTATION PLAN AND CONCLUSIONS IMPLEMENTATION PLAN apply these tools unless the SHPO requires their use. Chang- ing such attitudes requires a cultural shift within DOTs and In order to implement ECREL and/or the HPST, it is impor- the FHWA whereby these agencies recognize that (1) under tant to examine the impediments to the use of these two pro- existing historic preservation laws and regulations, they, not totypes. If these impediments are not addressed, implemen- the SHPO, define how resources are to be identified and eval- tation of these tools will not advance beyond this second uated and (2) such tools would enhance and streamline the phase of the NCHRP study. decision-making process when these tools consult with the SHPO on National Register eligibility. The use of the HPST also requires the replacement of cur- Impediments to Use of Tools rent reporting and documentation efforts. If this replacement The impediments to the use of ECREL are not as great as does not occur, the HPST will never be used. This tool cannot those for the HPST. ECREL does not require new types of be simply added on to existing practices; it needs to replace documentation or processes, as is necessary for the use of the existing processes and documentation. SHPO, THPO, and HPST. A tool such as ECREL does not add a new step in the DOT staffs do not need an additional form to complete or evaluation process, but enhances the current process employed process to implement. Agency staff, therefore, should be by SHPOs, THPOs, DOTs, and their consultants. ECREL required to develop new in-house procedures and processes provides easy access to documentation that can assist deci- to accommodate this tool. There should be new expectations sion making. Nevertheless, the following questions must be on the types and level of documentation that are developed addressed prior to implementing ECREL: Who would be in support of National Register evaluations. responsible for maintaining and updating this system? How The HPST should not simply be an alternative reporting will the system be funded? Where will it be housed? How format. As discussed above, it is an electronic, standardized, will new documents be added to the database, and who will and dynamic decision-making tool. Current reporting for- do this? mats, for the most part, do not have these characteristics, nor Implementing the HPST, on the other hand, requires more do they provide a readily accessible database on how deci- dramatic changes to existing procedures and processes. Use sions are made. With the HPST, decisions can be easily built of the HPST requires that one or more organizations popu- upon during future resource evaluations and historic preser- late the tool with data (i.e., historic contexts). This will take vation planning efforts. time and effort away from other tasks currently performed Senior agency management must provide support for any within SHPOs, THPOs, and/or DOT offices. In addition, of these changes to occur. Senior managers must allow their agency staff will need to be trained in the use of this tool. If staff the time and provide them the resources to create the consultants are the ones to place historic contexts into this databases needed to populate the HPST. If consultants are the tool, they will need to be given time, money, and training ones populating and using the HPST (along with DOTs and to do so. SHPOs), agency managers will need to approve the expendi- As found in the Phase 1 survey, historic context develop- ture of funds to contract with the private sector to use this tool. ment and use has not been a high priority among agencies. Given these impediments, the following actions are neces- The focus is on project-specific activities and reviews, not on sary in order to successfully implement the HPST and ECREL: the development of planning and decision-making tools such as the HPST. The use of a tool like the HPST requires a com- · Identifying and procuring funding sources; mitment within agencies to spend the time and resources nec- · Locating an agency or organization to maintain and essary to put the tool into place, understanding that the "pay- update the tools, particularly ECREL; off" comes later during future project efforts. Also, as evident · Improving, through training, practitioners' understand- from the review comments on the HPST, state DOTs may not ing of the utility of historic contexts;