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29 CHAPTER FIVE INNOVATIVE APPROACHES TO STEPS IN SECTION 106 PROCESS In addition to employing innovative approaches to pre- ical survey methods and is working with the Kentucky project planning, several DOTs apply project-specific Transportation Cabinet (the state DOT) to demonstrate the practices that enhance and streamline archaeological inves- value of these methods on transportation projects. CRAI has tigations and project review. These practices are applied to successfully used conductivity surveys to locate buried struc- several stages of the Section 106 process--identification, tures and features on historic period archaeological sites. National Register evaluations, and resolution of adverse They have also used this method, along with a site magnetic effects. susceptibility study, to locate and define subsurface struc- tures on complex Mississippian village sites (32). IDENTIFICATION NATIONAL REGISTER EVALUATIONS Among the responding DOTs only one innovative method was discussed, that in their view enhanced the identification In his response to the survey questionnaire, the Minnesota and evaluation of archaeological resources: remote sensing/ SHPO archaeologist raised concerns about the value and ade- geophysical studies. The Alabama DOT, for example, con- quacy of archaeological mitigation projects. Based on a pre- ducts remote sensing during the early stages of site evalua- liminary study of major mitigation projects undertaken in the tions. The goal of these studies is to locate signatures of state during the 1990s, he found that the majority of these potential burials, especially on historic period Native Ameri- projects failed to fulfill most of the objectives listed in the can sites. The resulting information is used to plan subsequent projects' research designs. The reasons for this problem were work. The DOT has found that methods such as ground pen- (1) inadequate assessments of research potential during the etrating radar (GPR) work well on such sites. The DOT is also site testing/evaluation phase, and (2) a lack of understanding contracting with the University of Mississippi to conduct a of what National Register criterion D really means. The Min- suite of remote sensing tests for DOT projects. The university nesota SHPO recommended that states carefully evaluate is very well known for its geophysical and archaeological previous archaeological investigations to learn from past work, and the Alabama DOT expects that contracting with the work and improve future site evaluation efforts. university will both expand the use and efficacy of these remote sensing methods on transportation projects and The Montana DOT has implemented a new approach for enhance the DOT's credibility in the eyes of the SHPO. dealing with one of the state's problematic archaeological sites--tipi rings. The agency noted that the technique for Caltrans has in-house remote sensing capabilities; evaluating these sites has not changed over the past 30 years. although the use of remote sensing is still in the experimen- On one occasion, in consultation with the SHPO, the DOT tal stages and the agency is evaluating which types of geo- spent additional time and money to more fully test a tipi ring physical methods work best within different environmental site than had been done in the past. The entire ring was exca- settings and conditions. When remote sensing is used early vated in a detailed study to determine whether anything was in a project, it is anticipated that the DOT will be able to bet- present that had research value. The DOT may do this a few ter target locations for subsequent work. The agency also more times, focusing on single tipi rings, to learn more about plans to test the utility of remote sensing for reducing sub- these types of sites. It is hoped that the results of this work surface excavations during site evaluations and identifying will aid in future National Register evaluations of these types internal site patterning without extensive subsurface testing. of sites and streamline future projects. The Oregon DOT is also testing the efficacy of various geo- physical methods in different regional contexts. For exam- The Kentucky FHWA division office noted that most ple, the DOT is conducting GPR surveys of known house pit evaluation studies, which use standard test excavations, sites to identify the signature of these subsurface features. resulted in findings that sites were not National Register eli- This information will be used to identify these features dur- gible. Given the consistency of these findings, the FHWA felt ing future surveys. that less costly site evaluation methods should be employed. Such approaches might include better sampling techniques Cultural Resource Analysts, Inc. (CRAI), a CRM firm and use of available information. The Kentucky Transporta- located in Lexington, Kentucky, routinely employs geophys- tion Cabinet noted that as a result of discussions among