Phase III Mitigation/Data Recovery
Description: Avoiding adverse impacts to significant sites; excavating and analyzing significant sites; realizing a site's potential through data recovery.
Learning Objectives:
• Categorize and assess alternatives for mitigating adverse impacts on cultural resources.
• Appraise the essentials of data recovery projects.
• Review a specific data recovery project.
Readings:
Advisory Council on Historic Preservation, "Recommended Approach for Consultation on Recovery of Significant Information from Archeological Sites" (1999). Available at http://www.achp.gov/archguide.html
Stephen L. Black and Kevin Jolly, Archaeology by Design. Archaeologist's Toolkit 3. Walnut Creek, CA: Altamira (2003), 67-126.
David L. Carmichael et al., Excavation. Archaeologist's Toolkit 3. Walnut Creek, CA: Altamira (2003).
Neumann and Sanford, Cultural Resources Archaeology, 159-210.
U.S. Department of the Interior, National Park Service, "Archaeology and Historic Preservation; Secretary of the Interior's Standards and Guidelines," Federal Register, vol. 48, no. 190, pp. 44728–44742.
U.S. Department of the Interior, National Park Service. National Register Bulletin: Guidelines for Evaluating and Registering Archeological Properties (2000). Available at http://www.cr.nps.gov/NR/publications/bulletins/arch/
I. Mitigation of Adverse Impacts
Let us assume that your Phase I survey for a Section 106 project discovered cultural resources, and that a Phase II study found that they were likely to be significant. The federal agency official responsible for handling the Section 106 process now has to determine if the proposed project will have an adverse effect on the sites. If it will, then efforts must be made to "avoid, minimize, or mitigate" the adverse effects. For archaeological sites, adverse effects may be dealt with in several different ways.
A. Avoidance: One way is simply to avoid the adverse effects altogether by changing the project in such a way that the cultural resources are no longer subject to impact. From a preservation standpoint, this is the preferred alternative because the sites are left alone. One might imagine that excavation is preferable, because we will learn something from the excavation, but remember that in most cases even excavation at a Phase III level means sampling the site, not full excavation, and it is better to leave the site intact if possible. Whether a project proponent is able to redesign the project so as to avoid impacts to the site(s) is another matter. It may be impossible, given constraints of topography, available land, etc. Or it may not be prudent and feasible from a financial perspective if the cost of redesign is excessive, or from a scheduling standpoint, for example if the realignment itself needs to be surveyed for cultural and environmental impacts, which would result in substantial delays of the project.
Avoidance is not a perfect solution either. Once a decision is made to avoid a site, it is no longer subject to the jurisdiction of the preservation laws. A significant prehistoric site, for example, now removed from a Section 106 project area, will probably revert to the unrestricted use of the landowner. Avoidance does not guarantee preservation.
B. Site Burial: In a relatively small number of cases, it might be possible to avoid impacts to cultural resources by burying them sufficiently deep so that the construction of a project will not affect them. This technique is not without controversy, though, and the long-term effects of burial on factors such as a site's soil chemistry, remain matters for concern. It may also be questioned to what degree a significant cultural resource is in fact preserved if the site burial effectively makes it impossible for the site to ever be investigated. For site burial as a technique, see Robert M. Thorne, "Intentional Site Burial: A Technique to Protect Against Natural or Mechanical Loss," Archeological Assistance Program, Technical Brief No. 5, Sept. 1989.
II. Phase III Data Recovery
A. The Final Stage in the Three-Step Process: Assuming that it is not prudent and feasible to avoid or otherwise minimize the adverse effects on significant archaeological resources, the likely form of mitigation will be to conduct a full-scale archaeological investigation designed to realize the site's research potential through excavation. This is usually called a Phase III data recovery project. The research design for data recovery projects must address the specific research questions that were identified in the Phase II report as part of the site's significance.
B. Memorandum of Agreement (MOA): In Section 106 projects, data recovery projects are stipulated as part of an agreement between the federal agency, SHPO/THPO, and other consulting parties.
1) The Advisory Council on Historic Preservation has a model MOA on its website (www.achp.gov/archguide.html).
2. Class Discussion—The MOA: Hand out copies of executed MOAs to the class. Review their essential components. Notice how the MOA contains the basic facts about the project, the determination of eligibility by the federal agency and SHPO, the statutory authority, and the stipulations for mitigating adverse impacts. Normally the stipulations simply require data recovery projects or other kinds of mitigation (e.g., technical recording of historic structures) without a lot of detail; that is left for the specific data recovery plan that must be developed. Also notice who the signatories are.
C. Research Designs for Data Recovery Projects: It is difficult to generalize about data recovery projects because each site is unique. While the Phase I and Phase II surveys tend to be fairly standardized in terms of the amount of research and the nature of the testing, in the Phase III project the research design must be specifically tailored to the particulars of the site and the research questions being asked of it. Still, it is safe to say that Phase III excavation is both more intensive and extensive than in any other phase; the research is more detailed and more focused; and the analytical techniques brought to bear more specialized and more systematically applied.
D. Phase III Proposals and Budgets: Scoping out and budgeting a Phase III project is a challenging enterprise. It is safe to say that there will be greater variation in both the scope of work—how much excavation will be done, how many artifacts are anticipated, what types of analyses will be conducted—and in the budget estimates among Phase III proposals than among Phase I and Phase II proposals. Large and complex projects may run into the millions of dollars and may involve a host of techniques rarely seen in the other phases. Deciding how much of a site to sample is a major challenge. What percentage of a prehistoric occupation site, for example, is sufficient? Ten percent? Fifty? The complexity of many Phase III sites will also mean that a host of specialists will be called to the project—not only laboratory specialists but consultants in particular aspects of archaeology. Public information is also an important part of Phase III archaeology, and most data recovery plans call for on-site public interpretation as well as other popular forms of disseminating the results of the project (e.g., brochures, booklets, exhibits). Finally, large-scale Phase III excavations require comprehensive managerial skills to manage, schedule, and coordinate the various components of the project from start to finish.
In terms of competitive bidding for Phase III projects, clients tend to worry less about the budget and more about making sure the project receives the necessary approvals and gets done on time. For this reason they pay close attention to the qualification of the firm and its principals, its reputation, and its previous experience in successfully managing similar projects.
III. Case Study of a Data Recovery Project
A. Present a case study of a data recovery project, describing the discovery and evaluation of the site(s) and explaining the process of developing a research design for the project. Show how the research design was implemented and evaluate the success of the project. Did it, in fact, make a significant contribution to our knowledge about the past?
B. I have used my excavations of the 19th-century almshouse cemetery in Uxbridge, Massachusetts as a case study in this context. The report has been published (Ricardo J. Elia and Al B. Wesolowsky, eds., Archaeological Excavations at the Uxbridge Almshouse Burial Ground in Uxbridge, Massachusetts (1991). BAR International Series 564, Oxford: Tempvs Reparatvm), so the students have an opportunity to examine the document in detail. The excavation was not a Section 106 project but came about in response to the requirements of a state unmarked burial law. The significance of the site was the incredibly detailed picture it provided of the bioarchaeology of an underdocumented class of 19th-century Americans (paupers) living in the context of a town-run poor relief system.
A highly focused program of historical research was conducted. Deed research served to identify the site as an almshouse in operation between 1831 and 1872 and gave us the boundaries of the property. After excavation was completed, an extensive list of documentary sources was consulted, including federal and state census, county deeds, county probate records, state pauper reimbursement records, as well as records of town meetings, the town selectmen, town treasurer, town reports, and vital records. Our historical narrative included numerous topics, including general history of Uxbridge, site history, history of the Uxbridge Poor Farm, organization of poor relief, overseers of the poor, superintendents of the Poor Farm, pauper demography, life at the Poor Farm, and death and burial at the Poor Farm (including coffins, coffin hardware, shrouds, and pins).
Osteological Analysis of the skeletal remains of 32 individuals was analyzed. Burial position was described, and osteological observations made on the cranium, mandible, skeleton, and dentition. Analysis included mortality distribution (age and sex), reconstructure of stature, assessment of race (required to identify possible Native Americans among the paupers who would be reburied in a tribal cemetery), and pathology. Comparanda were adduced from contemporary historical burial grounds.
Material culture analysis included study of gravestones, coffins (wood, shapes, lid types), hinges, nails, screws, tacks, glass viewplates, and burial clothing (pins, textiles, and fasteners).
A prosopography of paupers was developed, including biographical summaries for all paupers known and suspected to have died and/or been buried at the almshouse during the period 1831-1872. An attempt was made to identify the skeletal remains with known paupers through a study of the documents, osteology, and archaeology.
Finally, the project included a public component. There was daily coverage of the excavations by local newspapers. Following the project, we assisted the local historical commission in the reburial of the skeletal remains and participated in preservation-related activities at that time.