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33 CHAPTER SIX OBSTACLES TO IMPLEMENTING INNOVATIVE AND EFFECTIVE APPROACHES TO ARCHAEOLOGICAL INVESTIGATIONS Survey respondents noted that one of the main obstacles to the should be used as a lesson to improve how the practice is use of new, innovative approaches to archaeological investi- applied in the future, not a reason for abandoning the prac- gations is a lack of funds. Several of the respondents reported tice. For example, the Oregon DOT had a situation where a that as a result of this constraint they were not able to flexible data recovery design contained unclear wording that lead to contentious and open-ended discussions about when Develop historic contexts; the data recovery plan was fulfilled. This caused conflicts Improve tribal consultation, which often requires meet- with the CRM contracting firm, the municipality where the ing tribes outside the state or paying for tribes to travel project took place, the DOT, the SHPO, and the tribes who to meetings and conferences (this is especially difficult were consulted about the project. Ultimately, these issues given current state government restrictions on travel); were resolved, but it was a long process and one that could and have been handled much more effectively if the data recov- Conduct research on new field and analytical methods, ery plan and anticipated project impacts had been more fully such as remote sensing. defined at the initiation of the work. The DOT noted that data recovery plans must always allow some flexibility, but Some DOTs and FHWA division offices identified their that they can become a source of contention when the objec- SHPO's reluctance to concur with nonstandard approaches tives of the data recovery are not clearly delineated and as a stumbling block to creativity in managing archaeologi- included in the data recovery plan and associated Section cal investigations. The DOTs also noted that the culture of 106 agreement. their own agencies constrained the use of innovative and effective practices. Their colleagues and managers often take Ways identified to address these types of obstacles are the attitude that we have always done it this way, so why do similar to the practices that improve and maintain good com- we need to change and try something new? DOT staff munication among the Section 106 parties. As demonstrated is sometimes too focused on day-to-day Section 106 compli- by the many examples discussed in the previous chapters, the ance activities and therefore are not open to approaches that following practices counter, or at least soften, resistance to move beyond the standard compliance process. Making innovation and change: changes to existing agency procedures and processes is given a low priority. One DOT noted that from time to time their Having regular meetings that review ongoing and CRM consultants are resistant to innovative approaches. future projects and programs; These approaches often do not conform to the types of things Participating in collaborative efforts; that their contractors are interested in or want to do. One Establishing joint agency objectives, goals, and processes; SHPO noted that the biggest constraint to implementing and innovative practices was a lack of talented, capable archaeo- Having upper management support and directives to logical consultants to work with FHWA and the DOT, as implement and maintain effective, innovative practices. well as inadequate project funding and restricted project schedules. The Oklahoma DOT noted that it is helpful to work slowly rather than propose major changes all at once. Inter- Another constraint is DOT staff turnover. The North Car- nal proposals for innovative practices are best received by olina DOT noted that it was experiencing a high turnover in upper management when it can be determined that, in addi- environmental and engineering staff, and that incoming staff tion to benefiting the goals of historic preservation or being are not familiar with the requirements for archaeology and required by the "letter of the law," they would effectively how it is done in the department. As a result, there is a need address identified DOT needs in terms of quicker project to continually train new staff to keep existing effective prac- delivery or maintaining smooth relationships with the SHPO tices moving forward. This is very important to maintain and other state regulatory agencies. When such processes are trust with other agencies, such as the SHPO. already working well, upper management is generally unlikely to support large-scale innovation solely because it Another constraint results from the use of an innovative better serves historic preservation goals or is perceived as a approach that does not work well. In such cases, the event best practice by historic preservation professionals.