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19 a rotating basis to assist in the review of other agencies' proj- survey noted that in its state the DOT believed that it was ects. Owing to the size of the state and the volume of Caltrans important to always please the SHPO. projects, Caltrans reviewers may also assist in the review of agency projects from outside their own DOT district. SHPO PROJECT DELIVERY--INTEGRATION OF supervisory staff also ensure that a "firewall" remains in SECTION 106, NATIONAL ENVIRONMENTAL place between the Caltrans staff and other SHPO review POLICY ACT, AND PROJECT DESIGN staff. In the past, SHPO staff has also worked for Caltrans on a temporary basis. This exchange effort helps the SHPO with As noted in chapter one, an important aspect of environmen- their workload, and it also promotes a good relationship tal streamlining is the reduction and elimination of delays and between the agencies as staff get to experience the "other unnecessary duplication in environmental review procedures. side" of the Section 106 consultation process. The survey, therefore, asked that DOTs and FHWA describe effective practices that integrate the timing and scope of archaeological investigations into the NEPA and project Who Are the Decision Makers? development processes. The focus was on practices that resulted in expedited project reviews and reduction of costs. The survey showed that internally, decisions to implement innovative archaeological studies were made by the DOT On widening projects and bridge replacements where staff archaeologist or CRM specialist. If the approach NEPA compliance often involves an EA, the majority of was new and required funds not originally budgeted for a DOTs conducted comprehensive archaeological surveys project, the ultimate decision was made by upper project early in project development because alternatives for these management. projects are spatially restricted. National Register evalua- tions and the development of plans for mitigation of adverse The survey responses also showed that the majority of effects are frequently finished by the time a FONSI is issued. DOTs made decisions on both standard and innovative On widening projects in Georgia, the DOT generally con- archaeological investigations in consultation with the SHPO, ducts an intensive level survey at the conceptual design and that a consensus on these approaches was usually stage. At times, however, fieldwork is not done until after the reached. The Ohio DOT noted that every decision on com- completion of the analysis to identify practical and reason- plex projects is a multidisciplinary decision, where all able alternatives. Archaeology is rarely an issue during the aspects of design and resource review associated with a proj- alternative screening process. Rather, alternatives are selected ect are considered. The DOT needs to ensure that they do not for further detailed environmental study on the basis of his- create problems in other areas when they make a decision toric architecture, Section 4(f), and ecological issues. about one particular resource category or project design action. For projects that are CEs under NEPA, the DOTs generally complete archaeological surveys and National Register site As noted previously, some DOTs reported having poor evaluations before the release of the CE document. In Pennsyl- relationships with their SHPOs. One of these DOTs stated vania, however, the DOT has problems integrating archaeo- that it tended to give the SHPO's views precedence and that logical studies into CE level projects, because the CE process the state's FHWA division office took the same position. moves very quickly. To deal with this situation and with proj- The agency did not attempt to negotiate a solution with the ects where access to private property is not granted before the SHPO when there was a disagreement, because this took conclusion of NEPA compliance, the agency executes individ- too much time and affected project delivery schedules. ual Section 106 programmatic agreements for CEs. The PAs Another DOT commented that recently their SHPO was stipulate the process to be followed once the DOT purchases becoming more resistant to innovative approaches; there- the ROW for the project. PennDOT recognizes that this process fore, it was difficult to reach a consensus on using these results in the execution of too many project-specific PAs. approaches. On large projects with multiple alternatives, the DOTs A third DOT noted that the use of creative mitigation for often use a phased approach to archaeological survey. The archaeological resources was generally opposed by its DOTs conduct a literature and records search of the alterna- SHPO. The SHPO was not willing, for example, to "sacri- tives being studied, followed by a field survey of high prob- fice" portions of an archaeological resource to gain a higher ability areas; that is, areas that may contain a fatal flaw such public benefit on a project. This same DOT also stated that as sites with burials. A comprehensive survey is done only there was a general feeling within the department and FHWA on the preferred alternative, before the final EIS or release of that the SHPO "must be appeased" to avoid project delays. an EA for public review and comment. In most cases, the Any disagreement could affect a project's schedule. One of DOTs noted that their FHWA division offices wanted the responding FHWA division offices made the same obser- National Register eligibility evaluations conducted on all vations in terms of the relationship between its DOT and the sites within the preferred alternative before the final EIS or SHPO. In addition, one of the CRM firms responding to the before issuing a FONSI.