PROJECT APPROACH

As a first step, the project team examined, through a literature review, resources on making determinations of No Effect and No Adverse Effect for a wide range of transportation project types and classes of historic properties often encountered by transportation projects and began an analysis on trends and practices across the country. Resources examined included federal and state level guidance, policies, memoranda, and manuals; forms and tools used by state DOTs to explicitly document and communicate with consulting parties on effects determinations; published project examples and case studies; Section 106 trainings provided by the ACHP, FHWA, state DOTs, and other organizations; statewide delegation PAs; property-specific PAs; and protocols and procedures for consultation with Tribes.

After analysis of the information and data gathered during the literature review, the project team distributed an online questionnaire to obtain further information on the state of practice around the country from the perspective of different types of practitioners and consulting parties in the Section 106 review process, and to identify practitioners and consulting parties for follow-up interviews, in addition to case studies for further review. Using Google Forms, WSP developed three versions of the survey for the following categories of respondents: (1) local, state, and federal agencies (e.g., state DOTs, FHWA Division Offices, SHPOs); (2) preservation organizations and private-sector consultants; and (3) THPOs and NHOs. Copies of the questionnaires are included in Appendices A-C. All respondents were given the option of forgoing the online survey and participating in a telephone interview with WSP or completing a Microsoft Word version of the survey. Respondents were given approximately one month to complete the online survey.

WSP distributed the survey to staff from state DOTs, SHPOs, FHWA Division Offices, THPOs, NHOs, and select FPOs via direct email. The project team contacted Transportation Research Board (TRB) state representatives to assist in the distribution of the survey to appropriate state DOT staff. Using national directories, WSP also distributed the survey to NHOs and THPOs. WSP sent the online survey to NHOs listed in the U.S. Department of the Interior Native Hawaiian Organization Notification List maintained by the Office of Native Hawaiian Relations; however, no responses were received from any of the NHOs.

After the initial online survey, WSP sent out the survey a second time to increase the number of THPO responses and also sent the survey again to the NHOs. WSP also consulted with state DOTs, and SHPOs to compile a list of Tribes without THPOs and reached out to these Tribes, asking if they would respond to the online survey or participate in an interview. These efforts were not successful. No responses were received from Tribes.

To reach the private sector, local governments, and preservation organizations, WSP coordinated with the American Cultural Resources Association (ACRA), the Society of Commercial Archaeologists (SCA), and the National Alliance of Preservation Commissions (NAPC) to post the survey on the organizations’ listserv groups, newsletters, and blogs. WSP also posted the survey to a highly active social media group, titled “Historic Preservation Professionals” on Facebook.

After completing the state of practice online survey, the project team reviewed the survey responses and identified respondents for potential follow-up interviews. Respondents were chosen for interviews based on the substantive nature of their responses to the survey. Agencies and consultants were also chosen for an interview if they provided a specific case study and/or if their responses elicited further inquiries about their approaches to and experiences with findings of No Effect and No Adverse Effect. In addition, the NCHRP 25-65 panel instructed WSP to include interviews with the FHWA Headquarters staff, ACHP, National