Cultural Resource Review of Borrow Areas
So, you got your contract with WVDOH, you found a
borrow or waste area, you're ready to go, and you think you're home
free - then you read in the standard specifications that you must go
to the State Historic Preservation Officer (SHPO) for a cultural
resource review of the waste or borrow area.
You say: The state what?
- The State Historic Preservation Officer (SHPO) is responsible for compliance with state and federal laws protecting cultural resources.
- Cultural resources are historic structures and archaeological sites.
- Compliance in West Virginia is overseen by the Division of Culture and History's Historic Preservation Unit. Their job is to determine the effect of construction projects on archaeological sites and historic structures listed or eligible for listing on the National Register of Historic Places (National Register).
You have to put together a package so SHPO can review the borrow site in terms of its potential to affect a cultural resource.
What do you do?
Background:
Why do I have to do this?
Because this part of the Standard Specifications brings WVDOH into compliance with Federal law:
207.3.4-Archeological and Historical Findings:
Should the Contractor's excavation operations encounter remains of prehistoric people's dwelling sites or artifacts of historical or archeological significance, the operation in that locality shall be temporarily discontinued. The Engineer will contact appropriate authorities to determine the disposition thereof. When directed by the Engineer [and there is no way will this happen], the Contractor shall excavate the site in such manner as to preserve the artifacts encountered and shall remove them for delivery to the custody of the proper State authorities
211.3-General: All borrow site grading plans will be submitted by the Contractor to the State Historic Preservation Officer (SHPO) for determination of the effects on cultural resources, such as Indian Burial Grounds. If the SHPO feels that there could be an effect on cultural resources a lengthy investigation could be undertaken. The cost of any investigation would be borne by the Contractor.
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What are National Register criteria?
First, a property usually is not evaluated for eligibility until it is at least 50 years old
Then, there is the question of integrity - is the property largely unchanged and intact?
Then there are 4 criteria, any of which can qualify it for the National Register:
- Associated with events important in our history
- Associated with a person important in history
- A building with architectural merit, or part of an historic district
- Archaeological significance, prehistoric or historic
Certain types of properties - churches and cemeteries in particular - are generally not eligible except under special circumstances.
SHPO evaluates the effect - and that can include visual intrusion on an historic property or a take from its land parcel.
SHPO needs 30 days because of bottlenecks and other project reviews. Sometimes they have questions that must be answered by the applicant.
Getting it through review the first time
Your aim is to get the application through the first time. The biggest step you can take is to obtain an acceptable borrow site to begin with.
Best chance of a successful office review:
-- get borrow from disturbed areas:
- Existing borrow areas
- Previously disturbed areas, like old push piles
Next best chance of a successful office review:
-- get borrow from low probability areas - where there is little expectation of archaeological sites or encroaching on historic structures:
- Avoid flat areas - try to get a hillside of greater than 20% slope (i.e., 20 feet of fall for 100 feet of travel)
- Avoid stream and river terraces above the floodplain (floodplains are seasonally inundated).
- Avoid rock shelters
- Avoid ridgetops, particularly saddles and ridge junctions
- Keep your distance from older houses
- Keep your distance from marked cemeteries -a 100' buffer, like strip mines
- Ask residents in the area about unmarked cemeteries. Often the headstones are down in old ones, assuming they had headstones
Use a reporting format that is complete and easy to read:
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Borrow Area Cultural Resource Inquiry
ALLOW AT LEAST 30 DAYS FOR PROCESSING
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| 1. Company identification |
| Company Name: |
Contact person: |
| Address: |
Fax |
| City: |
Phone: |
| Date: |
Email: |
| 2. Project identification |
Project Name:
| State Project #: |
|
| County: |
Federal Project #: |
| 7½' USGS Quad: |
| 3. Description of borrow area |
| a. Dimensions: |
| b. Topography: |
| c. Prior physical disturbance: |
| d. Observations: |
| Attachments: |
| Photographs |
| Borrow area plan map |
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| Topographic map |
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You can use the format provided on right side of this page, or
click here to download a form you can use in your word processor,
or, if you enjoy writing, you can compose a cover letter that contains all the information on the form.
Examples of how to describe the borrow area
a. Dimensions:
- ______ feet N-S by ______ feet E-W, or
- ______ feet NE-SW by ______ feet NW-SE
b. Topography:
- fill
- manmade landscape
- hillside slope >20%
- v-shaped valley
- hill toe slope
- gently or moderately rolling valley floor
- sharp or broad ridge
- high stream terrace
c. Prior physical disturbance:
- existing borrow area
- abandoned logging road
- old push pile
d. Observations:
- Any other information that might be helpful
Mandatory attachments - use them well
Topographic Map
- Xerox the area from a USGS 7½' topographic quadrangle (1:24,000 scale)
- Clearly mark the borrow site
- Be accurate -- avoid exaggerating the borrow area size. Apparent spillover into a sensitive area will hold you up.
- Quadrangles are available at surveyor or drafting supply stores.
- You may be able to use part of the DOH project documentation -- Xeroxes of topo maps if clear
- Go to Topozone.com or other web site as a last resort -- these maps are small and difficult to manipulate
Borrow Area Plan Map
- Sketch the borrow area and surroundings to approximate scale
- Include landmarks -- e.g., roads, streams
- Include standing structures
- Show borrow limits and a north arrow.
- Clearly label everything (e.g., CR 7/11, Residence #1, Barn #2, borrow limits)
- Showing photo orientations helps
Quality photos are very important.
- You need to illustrate the borrow area's relationship to visible landmarks and standing structures.
- A 360º panorama is advisable.
- Label the photos to match your project plan map
- Clearly mark the borrow site, or include a photo key -- direction and orientation of each photograph
- Photograph features of interest -- older houses and other structures
- Xeroxed or faxed photos are not acceptable.
- SHPO prefers actual photographic prints and discourages digital files.
- Clear color inkjet prints of digital photos (two per page) are acceptable.
- Polaroids are acceptable if they are of good quality (usually they aren't).
- Do not just slap something together. You need to convince the reviewer that the photos fairly represent your project.
Use common sense.
Applications are not graded on size
- 1 page w/ topo and photos should do it for a straightforward case. Unnecessary enclosures just slow down the review.
What they don't need
Here is a partial list of some of the unnecessary material SHPO has received in the past:
- Request to DOH for approval of borrow site
- Landowner agreement
- General notes from the plans
- CE documentation - cover memo to FHWA, WVDOH's cultural resource report on the bridge, RTE letters
- ACE correspondence -- 404 clean water act permit application, ACE public notice
- Field review notices
Borrow area clearance is not a responsibility of the Division of Highways.
We have coordinated with the West Virginia Division of Culture and History to present this information as an aid to our contractors. The regulatory relationship is between the Division of Culture and History and the contractor.
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