Cultural Resources Management

CRM or Cultural Resources Management can be defined as the practice of managing cultural resources in response to some legal or policy mandate. The goal of CRM is to manage important cultural properties for the public benefit. This is achieved by the application of law and public policy. The CRM process is usually set in motion when an activity is proposed and the potential impacts are reviewed by a public agency to comply with an environmental protection law.

YPG CRM and Archaeologist – names and contact information

Catherine S. Vaughn, Cultural Resources Manager – email:  phone: 928-328-2520

What is the role of the YPG environmental science department in managing cultural resources on YPG?

As a Federal land manager, YPG is obligated to comply with Federal laws and regulations regarding NHPA and Section 106 as they pertain to actions that occur on YPG lands. The Garrison Manager has direct responsibility for establishing an installation cultural resources management program by means of an ICRMP that successfully integrates cultural resources management within the process of achieving daily mission objectives. AR 200-1 outlines the responsibilities of the Garrison Manager for compliance with federal cultural resources laws and regulations.

In the completion of their CRM duties, The YPG CRM works with local, state, federal and tribal entities on project based initiatives and in correlation with mandated state and federal laws and regulations.  The following is a list of agencies that YPG CRM collaborates with:

  1. BLM
  2. DOI
  3. U.S. Fish and Wildlife Service
  4. BOR
  6. Army Corps of Engineers
  7. USCBP
  8. AZGFD
  9. Arizona SHPO
  10. ADOT
  11. City of Yuma – YPD
  12. County of Yuma – YCSO
  13. Tribes
  1. Description of CRM process
    1. NHPA and NEPA

National Historic Preservation Act (NHPA) and Section 106

– Public involvement activities under the NHPA are largely focused within two sections of the Act— Sections 106 and Section 110. Section 110 considers agency responsibilities when identifying, evaluating, nominating, and protecting historic properties and indicates that the agency shall ensure . . .that the [agency’s] preservation-related activities are carried out in consultation with other federal, state, and local agencies, Indian tribes, Native Hawaiian organizations carrying out historic preservation planning activities, and with the private sector . . . (NPS n.d.)

The primary focus on public participation under the NHPA is in the Section 106 review process. This section of the Act provides for active participation by the public in various ways, depending on their particular interests. Useful principles of the public participation process include:

  • Public participation in Section 106 review should support historic preservation objectives and help the federal agency meet its program responsibilities;
  • Both federal agencies and members of the public have responsibilities in a public participation program;
  • Public participation objectives should be approached with flexibility;
  • The level and type of public participation should be appropriate to the scale and type of undertaking and to the likelihood that historic properties may be present and subject to effect.

To support these principles, the AZ SHPO, Tribal Historic Preservation Officers (THPOs), and Advisory Council on Historic Preservation (ACHP) can assist agency officials with ways of identifying interested persons and involving them in the review process, and in evaluating agency public participation programs.

NOTE: More information on public involvement in the NHPA and Section 106 process can be found in sections– of the Integrated Cultural Resources Management Plan (ICRMP).

YPG Programmatic Agreement (PA)

USAG YPG currently operates under a PA among USAG YPG, the AZ SHPO and the ACHP regarding the operations, maintenance, and development of YPG. USAG YPG consulted with federally-recognized Indian tribes who attach traditional, religious, and/or ceremonial significance to YPG lands or cultural resources therein that may be affected by the undertakings and invited them to sign the PA as concurring parties. This agreement, finalized in November 2014, outlines the responsible parties and their duties related to potential undertakings at USAG YPG and the associated Section 106 review process. The PA provides information on the present state of knowledge concerning historic properties, the status of archaeological and architectural surveys, areas exempted from survey, activities that are exempt from the Section 106 review process, SOPS for inadvertent discoveries, and Annual Report requirements.

National Environmental Policy Act (NEPA)

– Under NEPA, agencies have the responsibility to consider any potential effects that their activities might have on the environment—including historic properties. In many cases, NEPA undertakings may trigger the NHPA Section 106 review process. As a result, the two Acts are often linked when issues involving cultural resources identification and protection arise. Compliance with one Act does not necessarily satisfy the requirements of the other Act; however, recent revisions of 36 CFR 800 now allow agencies to use the NEPA process for Section 106 coordination as long as they notify the AZ SHPO in advance that they intend to do so. In addition, agencies frequently coordinate studies (e.g., surveys to identify historic properties) and solicit public participation to satisfy the needs of both. The timing and interrelationship between NEPA and Section 106 public involvement efforts include:

  • Consultation with participants for the identification, evaluation, and effect determination on any historic properties can take place concurrent with the development and preparation of NEPA documents (environmental assessments [EAs] and environmental impact statements [EISs]);
  • Draft EAs and EISs can be used as the basis for consultation under NEPA;
  • Results of consultation and public participation can be included in the final NEPA document.

Unlike the public involvement processes associated with cultural resources-specific legislation, NEPA’s implementing regulations (40 CFR Part 1500-1508) stipulate formal timelines for certain types of public coordination and review and it is during these specified periods that issues related to cultural resources frequently come to light. The critical time periods include:

  • The public scoping period, which can be appropriate for either an EA or an EIS depending on the scope and magnitude of the project. For an EIS, public scoping meetings are generally held after publishing a “Notice of Intent” (NOI) (to prepare an EIS) in the Federal Register. The public scoping period is approximately 30 days in length; however, there is no statutory guidance for the duration of this period and the ending date is generally determined by the agency (i.e., the period is generally of sufficient length to give the public adequate time to provide comment after scoping meetings are held). For particularly controversial projects, early public scoping meeting are sometimes held (i.e., before the NOI release) in order to determine the degree of interest and/or concern by the public. As a part of the scoping process, agencies are required to invite the participation of affected federal, state, and local agencies; any affected Native American tribes; the proponent of the action; and other interested persons. This can be accomplished by providing public notices of NEPA-related public meetings or hearings and the availability of draft documents. In all cases, agencies must mail notices to those requesting them. Depending on the nature of the action, agencies may also be required to notify Indian tribes, publish notices in newspapers or through other local media, use direct mailings, or post notices on, or off site, where the action will take place.
  • The public comment period begins on the date that a draft EIS is published. Public hearings to consider comments (agency and public) on the draft are generally held after the draft EIS is published, but not before the public has had an opportunity to review the document for at least 15 days. The public comment period extends for 45 days, during which time public meetings are held to gather public citizen and agency input on the draft document. During this period, no decision on the project can be made.
  • The public review period occurs after the final EA or EIS is published. For the EA, this is generally a 30-day period, within which the final EA and Finding of No Significant Impact must be available for public review at public libraries or other public information centers. For an EIS, the public review period is also 30 days, and begins when the final EIS is filed with the Environmental Protection Agency. This 30-day period allows the preparing agency and the public to consider the conclusions of the document before the decision- maker makes a final decision on whether or not to proceed with the project. After the 30- day period ends, a Record of Decision (ROD) is published that formalizes the decision, as well as any significant factors that were used in the decision process.