Evaluating Cultural Resource Significance: Implementation Tools (2005)

Below is the uncorrected machine-read text of this chapter, intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text of each book. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

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

21 • Obtaining support of upper agency management in the use of these tools; • Shifting some agency activities away from project- specific actions to preproject planning efforts; • Replacing existing reporting formats; and • Training staff and consultants in the use of the new formats. These actions are expanded upon below. Implementing ECREL and the HPST Based on the evaluations of ECREL and the HPST, URS recommends several options for implementing one or both of these tools. Table 1 (on page 3) shows the pros and cons of each option. ECREL Although ECREL must be hosted by an application ser- vice provider (ASP) (which could be a commercial vendor) or by a government agency, URS recommends two options for implementing ECREL: • ECREL Option 1: Voluntary Implementation. This option involves (1) locating a host for the ECREL data- base and website, (2) developing a document submittal protocol in consultation with the primary parties involved in the Section 106–related National Register evaluation process, (3) developing a document loading procedure, (4) advertising the establishment of ECREL, and (5) hav- ing state DOTs, SHPOs, THPOs, and consultants volun- tarily send in electronic versions of documents to the organization maintaining ECREL. To implement this option, funding is needed to pay for an entity to host ECREL and to develop a document sub- mittal protocol and a document loading procedure. Also, given the Phase 1 findings, some type of training on the importance of using historic contexts for making deci- sions on resource significance is highly recommended. Current use of historic contexts is infrequent (with the exception of a few states), and new agency and consul- tant staff most likely have no background in their use. Training will likely increase the use of ECREL and his- toric contexts in general. Therefore, a mechanism for this training needs to be identified. One option is to include such training in the National Highway Insti- tute’s soon-to-be-developed historic preservation train- ing course. • ECREL Option 2: National Implementation. This option is the same as Option 1, with the addition of col- lecting 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. Funds would be needed for SHPOs and DOT staff to participate in this effort and to pay for the collection and scanning of documents. The estimated cost of com- pleting this option is about $200,000. This includes the cost of sending personnel to each state (other than those that participated in the prototype) for 2–3 days to work with CRM staff to collect, copy, and fill out the cover sheet for the documents to be scanned. The copied doc- uments would be sent to a central location for scanning. (The actual cost to scan, index, and convert documents to searchable PDFs is estimated at $0.075/page for more than 10,000 pages and $0.10/page for less than 10,000 pages.) Funding is clearly a key impediment to implementing either of these two options. Engaging institutional and indi- vidual leaders is therefore critical in obtaining funding for the implementation of this tool. These institutional leaders include the FHWA, AASHTO, the NCSHPO, and the National Asso- ciation of Tribal Historic Preservation Officers (NATHPO). Key individuals within these organizations who would need to be involved in this effort include the FHWA’s historic preservation officer, the executive director of the NCSHPO, the president of NATHPO, the director of AASHTO’s environ- mental programs, and the chair of AASHTO’s Standing Committee on the Environment. Possible funding sources include transportation enhance- ment funds or the FHWA’s stewardship and streamlining program funds. Sources that may be more readily available are project-specific funds. Some state DOTs direct project funds toward the development of planning tools that have a direct link to project needs, so using some of these funds for a planning tool such as ECREL would not be an unusual step. For example, funds for the treatment of a category of historic property within a project area might be directed toward the col- lection of historic contexts nationwide that relate to this prop- erty type, and the contexts would be placed within ECREL. Some project funding could also be used to support the main- tenance of ECREL. Several DOTS already assist in updating and maintaining statewide GIS databases. ECREL could be an added component of these databases. Another source of funding is other federal agencies. The development of ECREL will benefit all other agencies that make determinations of National Register eligibility in the context of the Section 106 process. These agencies include the Federal Aviation Administration (FAA), U.S. Army Corps of Engineers (USACE), the Federal Emergency Management Administration (FEMA), and several land-managing agen- cies such as the Bureau of Land Management (BLM), the NPS, and the National Forest Service (NFS). Each of these agencies has a stake in the development and implementation of a tool such as ECREL. The joint funding of historic preser- vation planning tools is not new to these agencies. For exam-

22 ple, many of these agencies jointly fund the development and maintenance of cultural resource inventory databases (including databases using GIS) housed within SHPOs. HPST URS recommends two options for implementing the HPST: • HPST Option 1: Voluntary Implementation. This option involves (1) advertising the tool nationally and highlighting the utility of this tool, (2) sending HPST CDs to all DOTs and SHPOs and making the CD avail- able 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. NCHRP could distribute these CDs in the same man- ner in which NCHRP reports are currently distributed nationwide (e.g., on-line ordering). The availability of these CDs could be advertised at national historic preservation and transportation conferences. • 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 imple- ment 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 the creation of a new historic context from scratch using the HPST. It is also recom- mended that ECREL be integrated into this pilot pro- gram, as the two tools can be used together (e.g., search- ing ECREL for appropriate historic contexts and then placing the contexts into the HPST program). Funding is needed to pay for an organization to direct and implement the program and to fund SHPO and DOT staff participation in the pilot program. The latter task is important because SHPO and DOT staffs are having great difficulty meeting their current agency responsi- bilities. Adding another responsibility would only be pos- sible through the funding of additional staff. States will also need programming support and training for the dura- tion of the pilot program. The results of the pilot pro- gram would be shared and advertised nationwide to his- toric preservation and transportation professionals. Funding approaches for this option would be similar to those discussed above for ECREL. CONCLUSIONS As noted in the previous chapter, the responses to 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 devel- opment 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 is more problematic. It is clear that it will not be used without direction and approval from upper manage- ment within agencies. The HPST use will also require some changes in the existing evaluation processes used by most states. In addition, all reviewers made it clear that they did not want to do more work. Therefore, unless agencies were willing to replace one or more existing evaluation and report- ing requirements with the HPST, historic preservation pro- fessionals are not likely to use this tool. Most reviewers, nevertheless, felt that the HPST met the intended objectives, but that more work would be required to refine its features and integrate it into current SHPO and DOT processes. Unlike ECREL, which can and should be imple- mented centrally, the HPST would have to be implemented individually within each SHPO, DOT, and consultant offices, with specific requirements for each organization. For exam- ple, many reviewers wanted the HPST linked to their GIS; however, since each GIS may be organized differently, the HPST would have to be customized for each customer. The HPST and ECREL were not created to increase the workload of state and federal agency staff. Rather, these tools should 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 as the documentation levels needed for effective decision making are made explicit and readily accessible, elim- inating extraneous materials often inserted into current doc- uments. The HPST, in particular, would replace currently used evaluation report formats, forms, and correspondence, and the majority of decision-making efforts would be docu- mented and captured in a single format. Also, historic con- texts that are developed in the HPST will be no more time consuming (and may be less time consuming) to create than the current method of compiling information using word pro- cessing software. The use of the HPST for context develop- ment also increases the likelihood that the resulting historic context will actually 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, organizations such as TRB’s Historic and Archaeological Preservation in Transportation Commit- tee (ADC50), and AASHTO will hopefully provide leader- ship to secure funding to support additional prototype testing and refinement. As the February 2004 Santa Fe, New Mex- ico, “Working Conference on Historic Preservation and Trans- portation: Enhancing and Streamlining Compliance with Sec- tion 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 emphasize 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 fed- eral agencies such as the FHWA or nonfederal 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. (According to comments received in this study, those states might include, but not be limited to, California, Florida, Maryland, Min- nesota, Rhode Island, Texas, Vermont, and Washington.) The authors of this report have come to realize that imped- iments that prevent these products from becoming useful tools are institutional, not technological, and will take institu- 23 tional leadership to implement. The authors also believe that a pilot implementation program will show the many benefits of these tools and should be seriously considered for future national implementation. Long-term implementation has the greatest potential for success through adoption of a national initiative, such as the FHWA’s environmental 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 MOU. (This MOU might be modeled on the MOU signed on December 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 sup- ported through multiyear cost-sharing agreements among multiple federal agencies and states.