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23 Transportation Agency (VTrans) completes all of the follow- and a few have stopped taking in any new collections (24). To ing activities without additional consultation with the Vermont address this issue, several states have instituted innovative SHPO and ACHP: approaches to artifact collection and analysis, both in the field and in laboratories. Identifies historic properties, Determines National Register eligibility, The Nevada DOT has stopped collecting artifacts during Makes formal findings of "no historic properties survey. This was initially done at the behest of federal land affected," managing agencies when a DOT project crossed federal Makes formal findings of "no adverse effect" or lands. The DOT has also developed sampling methods for "adverse effect," and certain categories of material that occur in high frequencies, Implements standard mitigation measures to resolve such as waste flakes and some types of historic artifacts. In adverse effects to historic properties (22,23). addition, the DOT analyzes some categories of material in the field, such as ground stone and bulk historic materials, To implement this PA, VTrans has on staff two full-time and leaves these materials on the site. When testing for historic preservation professionals. These individuals serve National Register eligibility, the DOT collects only enough as Deputy Historic Preservation Officers within the DOT, material to support a decision on eligibility. one responsible for archaeological resources and the other the built environment. The PA also establishes a process Oklahoma DOT's preliminary National Register eligi- whereby the SHPO or any other party can intervene in the bility evaluations often involve the use of shovel testing. In process if they have a concern. All VTrans decisions are such cases, artifact analyses are performed in the field and fully documented using standardized procedures and the artifacts are placed back into the shovel test pits, unless forms, and these documents are readily accessible to all a landowner has specifically given the DOT the right to parties. Since its execution in 2000, the PA has worked remove artifacts from their private property. When extremely well and has extensively streamlined and short- National Register evaluation efforts involve excavation of ened the project review process (G. Peebles, personal com- test units and trenching, the artifacts are returned to the munication, 2002; Scott Newman, personal communica- landowner, if he or she wishes, after laboratory analyses are tion, 2002). completed. As noted previously, procedural PAs can be used to address For the past 20 years, some federal land managing agen- a category of resource. The Illinois DOT has a PA for resolv- cies in Wyoming have required the collection of only diag- ing adverse effects to prehistoric habitation sites in the state. nostic artifacts during surveys. On nonfederal lands, the The PA involves only sites that are significant solely for their Wyoming DOT uses the same process and requests that the information potential. These sites do not have the potential to landowner sign a donation agreement for the curation of contain human remains nor do they possess traditional cultural diagnostic materials at the University of Wyoming's curation values for Native Americans or other traditional communities. facility. For test excavations evaluating National Register These habitation sites are the most common archaeological eligibility, the DOT uses the professional standards in federal sites encountered on Illinois DOT projects and usually involve regulations dealing with collections (36 CFR Part 79); how- the use of data recovery to mitigate project impacts. The pro- ever, bulk materials such as brick on historic period sites are cedures stipulated in the PA eliminate the need for individual measured and discarded in the field. project-by-project MOAs (4). In Oregon, according to Archaeological Investigations NW, The AASHTO Center for Environmental Excellence website Inc., a local CRM consulting firm, state policy allows survey provides an on-line "how-to" tool kit for creating Section 106 teams to take digital photographs of artifacts in the field rather programmatic agreements (17). The tool kit serves as a step-by- than collecting them. This process, however, requires that the step tutorial, presenting information, guidance, and recommen- team include highly skilled individuals who can identify and dations on developing and implementing agreements among record these materials in the field. This process reduces subse- state DOTs, FHWA, SHPOs, and ACHP. The tool kit not only quent laboratory analysis time and curation costs. describes how to write an agreement, but also provides guidance on how to build trust among parties to create an effective agree- The Montana DOT, in two instances, conducted extensive ment that streamlines and enhances Section 106 compliance. testing and data recovery on a group of sites and agreed to turn the artifacts over to tribes after the analyses were completed. The tribes reburied the artifacts near the sites, and the locations COLLECTION AND CURATION STANDARDS of the reburied materials were recorded using a Global Posi- AND GUIDELINES tioning System device. In some cases on tribal land, the DOT has put artifacts back into test units after testing is completed. A growing problem area associated with archaeological investigations is artifact curation. Many repositories for The New Jersey DOT has an Archeological Collections archaeological materials are reaching their storage capacity, Donation Agreement, which offers local repositories the