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17 CHAPTER THREE INTERNAL BUSINESS PRACTICES AND PROJECT DELIVERY It became evident from the DOT survey responses that inter- or engineering firms as the prime consultant on projects, and nal business practices within a transportation agency have an the prime consultant hires CRM firms as their subconsul- impact on an agency's ability to streamline the management tants. In such cases, there is less flexibility in conducting of archaeological investigations and to enhance the results of archaeological investigations, as changes in a scope of work these efforts. Internal practices include the size and make-up involve a level of administration that does not exist under the of DOT staff, the structure of consultant contracting, and the Parent Agreements with CRM firms. location of decision-making authority. Another important aspect of internal practices is the way in which archaeologi- Some of the DOTs voiced concerns about outsourcing the cal investigations (and Section 106 compliance) are inte- majority of their archaeological investigations. For example, grated into project design and the NEPA decision-making in the past, the Nevada DOT conducted most of its work process. If these investigations are not appropriately inte- in-house and, as a result, it was able to "get out in front" of grated into the NEPA process and project design, delays and the projects during the development phase, conducting conflicts result. archaeological surveys before the engineers got too far along on design. DOT archaeologists were able to influence design and avoid significant sites. Given the openness of the land in INTERNAL BUSINESS PRACTICES western states, the agency had the flexibility to change the Staffing and Consultant Contracting design to avoid sites. This minimized the number of large- scale mitigation projects that were needed. Staff archaeolo- State DOTs use private-sector firms or sister state agencies to gists worked with design engineers on a one-to-one basis, so perform the majority of archaeological investigations. Cal- that there was continual communication between the archae- trans district offices typically use an on-call contracting for- ologists and designers. mat to hire outside consultants. Individual task orders are written for specific projects and given to one of the on-call With recent increases in outsourcing, this type of close consultants. This results in a faster project start-up because interaction with the project designers is no longer possible, the district does not have to go through the procurement particularly when design is also done by outside contractors. process to obtain a consultant for each project. For smaller This linkage between design and the results of archaeologi- projects, Caltrans' districts and headquarters have on-call cal studies is diminished even more when the designers work arrangements (interagency agreements) with state universi- for one firm, the environmental and NEPA specialists work ties. The agency also uses in-house staff or a combination of as a subcontractor to the design firm, and the archaeologists in-house staff and outside consultants for these small projects. are in yet another firm, working as a subcontractor to the NEPA firm. Given the almost exclusive use of contractors The Wyoming DOT uses master consultant contracts for and the reduction of in-house archaeological staff, Nevada survey and site evaluation projects, keeping consultants on DOT's CRM staff focuses on managing contracts and retainer. This agency uses a standardized scope of work and consultants. a two-page task order so that contractors can immediately begin to work on a project. The Utah DOT has in-house archaeological expertise in each regional office. Agency engineers and planners believe The Delaware DOT uses cultural resource management that in-house staff is more responsive to project needs than Parent Agreements, setting up a dollar ceiling for each 3-year outside experts. There is also more consistency when regional consultant contract. Then, the agency negotiates the scope archaeologists do the work. The Utah DOT does outsource and budget for each task order with the consultants. Because large archaeological projects. In these cases, the regional the contract funds have already been established, the DOT's archaeological staff oversees the outsourced work to ensure CRM staff simply requests the specific task amount from the quality and consistency. department's financial management office, sets up the task- specific funds, and then authorizes the consultant to begin PennDOT found that hiring in-house professional archae- work. In this system, it takes 1 week to have a funded task ologists (whom the agency refers to as "qualified profession- order in place. The Delaware DOT also uses environmental als"), and placing these individuals in the district offices, has

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18 significantly improved management of archaeological inves- museum, it is available and can quickly respond. The tigations and project delivery. The primary reason for this museum also handles all of the day-to-day management of improvement is that the cultural resource decision makers are the archaeological investigations and is responsible for con- in-house, and the designers and engineers within the depart- trolling the quality of work performed by its subconsultants. ment respond better to this in-house expertise than to outside DOT CRM staff can then focus on project design, NEPA and reviews and comments. This is particularly the case after New York State Environmental Quality Act decision mak- some trust building has occurred among internal archaeolog- ing, and Section 106 compliance. The New York State DOT ical staff and DOT engineers and designers. Another benefit noted that their program with the State Museum results in is the improved communication among agency staff working standardization in reporting and documentation, which facil- on a project. There is no need to schedule every meeting or itates and streamlines SHPO reviews, because the SHPO is interaction, as would be the case if an outside consultant were comfortable with the standards that are used. This program used. Having the qualified professionals serve as both Sec- is also cost-effective for the DOT, as they do not have to deal tion 106 process managers and liaisons with archaeological with layers of engineering or environmental consultants to consultants also results in a consistency in approaches and reach the CRM professionals who do the work. standards used within the districts. The Wyoming DOT also stressed the importance of hav- Funding of Positions for SHPOs ing qualified in-house staff. New archaeologists hired by a DOT should have a demonstrated record of research, publi- One approach that some DOTs have used to streamline the cation, and standing in the larger professional community review of archaeological projects is to fund a project review within the state. This approach results in better decision mak- position(s) within their respective SHPO. Eight of the DOTs ing, because decisions are based on a depth of experience. and FHWA division offices responding to this survey cur- rently fund review positions at SHPOs. The Ohio DOT funds Some DOTs use state universities to conduct their archae- two positions at its SHPO and this staff works only on DOT ological investigations, rather than contracting with private projects. Having these two dedicated positions facilitates Sec- CRM firms. The Oklahoma DOT, for example, has an inter- tion 106 consultation, because these individuals can easily agency agreement with the University of Oklahoma. The attend field and office meetings and immediately respond to university does the bulk of the agencies' work (85% to 95%), project needs as they arise. Unlike other SHPO staff, these and the university's staff, which is assigned to do only DOT individuals do not have conflicting project review priorities. work, is under the direction of the agencies' archaeologist. The DOT oversees the work load of these two individuals and Flexibility and decreased administrative and contractual bur- sets their work priorities. The DOT and FHWA meet every dens are the primary reasons why DOTs like to work with month with the two funded SHPO reviewers. It should be state universities. With this type of arrangement, the univer- noted that even though these individuals are dedicated to DOT sity can easily respond to changes in project design and projects and work under the direction of the agency, they do NEPA issues early in the project development phases. The not always agree with the DOT's positions. Because there is a Oregon DOT also noted that their university contractor is constant dialogue between the agency and SHPO staff, how- well known and respected by the SHPO and the state's tribes. ever, they can more easily resolve any differences of opinion. As a result, archaeological consultations proceed very smoothly because of this high level of trust. The Idaho DOT has a cooperative agreement with the Idaho SHPO to help fund a position at the SHPO. The indi- In New York, the State Museum (part of the state's vidual in this position reviews the DOT's cultural resource Department of Education) provides archaeological services reports, and the SHPO charges the DOT an hourly rate for to the New York State DOT. The museum has a large staff these reviews. The Louisiana DOT funds both a review posi- available for DOT work. Regional DOT offices develop tion and a student worker at the SHPO through an interagency estimates of the department's annual needs in terms of agreement. The Arkansas DOT and FHWA have an MOA archaeological work and forward this information to the with the SHPO that establishes a SHPO review position. This DOTs' Cultural Resources Section of the Environmental individual does not review DOT projects to avoid any conflict Analysis Bureau (located in Albany), which then coordinates of interest, but assumes a significant portion of the workload these needs with the museum. The museum works with the from the other SHPO reviewer, allowing the latter to devote agency to set up an annual CRM program based on the more time to DOT reviews. The Kentucky FHWA division regions' needs. Approximately 50% of the DOT annual work office funds a position within the SHPO. FHWA noted that program is done by museum staff and crews. The other half having a person dedicated to transportation activities has is accomplished through subcontractual arrangements the helped expedite the project review process, and that no other museum has made with four universities and three private approach has been as successful within the state. firms. The DOT participates in the subconsultant selection process, which takes place every 3 to 5 years. The partner- Caltrans has an exchange program with the SHPO ship with the museum saves time; when the agency needs the wherein three or four Caltrans employees go to the SHPO on